DRC-2010-002466 - 0901a068801731c4

State of Utah
GARY R, HERBERT
Governor
GREG BELL
Lieutenant Governor
"^^L-9~C\0 • CO<3'\\c:(^>
Department of
Environmental Quality
Amanda Smith
Execulive Director
DIVISIGN OF RADIATION CONTROL
Dane L. Fineifrock
Director
March 16,2010
David Frydenlund, Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17"'Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Material License (RML) Number UTI 900479
Dear Mr. Frydenlund:
On March 9, 2010, an inspection was conducted at your facility by Ryan Johnson, a representative
ofthe Division ofRadiation Control ofthe Utah Department ofEnvironmental Quality.
Observations from the inspection were discussed with Dave Turk and Ronnie Nieves at the
closeout meeting. The inspection was an examination ofthe activities conducted in your facility
as they relate to compliance with the Utah Radiation Control Rules and the conditions ofthe Mills
RML. The inspection consisted of an examination of representative records, interviews of
personnel, and observations by the inspector. During the closeout meeting the DRC inspector
made recommendations regarding items for improvement. These recommendations can be found
at the end ofthe inspection report under conclusions and recommendations.
Enclosed is the inspection report for your review. The DRC would like to thank the Mill staff for
their cooperation regarding this inspection. If you have any questions conceming this letter
contact Mr. Ryan Johnson [phone].
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
DLF/RJ:rj
Cc: David Turk, Site Radiation Officer
Enclosures
168 North 1950 West • Salt Uke City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.uiah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-Training-01: Radiation Protection & Respiratory Protection
Training/ Radiation Safety Officer (RSO) &, Radiation Technician Training
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Safety and Respiratory Prbtection Training Program/RSO and
Radiation Technician Training
Inspection Dates: March 9, 2010
Inspectors: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted:
Dave Turk (RSO)
Amanda Bailey (Laboratory Technician)
Clarence Yellow (Electrician)
Devon Mitchell (Maintenance Lead man)
Ronnie Nieves (Radiation Coordinator)
Gaylene Sterling (Laboratory Technician)
Hamilton Clark (Operations)
Steve Snyder (Engineer)
Goveming Documents:
Opening Meeting
UAC R313-15
NRC Regulatory Guide 8.31
NRC Regulatory Guide 8.15
Radioactive Materials License (RML) UTI 900479
RML UTI 900479 License Renewal Application (2/28/07)
Denison Mines: Dave Turk (RSO)
Utah DRC: Ryan Johnson (DRC Inspector)
During the opening meeting, the inspector discussed the inspection items ofthe inspection. These
items included the documentation to be reviewed, the employees to be interviewed and the specific
areas ofthe Mill that the inspector wanted to see during the inspection.
Inspection Summarv
The inspection consisted of reviewing the implementation and documentation ofthe revised (Rev.
5/15/09) Radiation Safety Training Program as it pertains to the requirements found in the UAC
R313-15 and the NRC Regulatory Guides 8.15 and 8.31 as referenced in 2007 RML renewal. The
inspection included a review of documentation, employee interviews, a RSO interview, and a mill
tour. The following discussion provides more detail ofthe specific items.
1 of Page 4
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\Inspection Report RADMOD-Training-01 3-15-10 RJ.doc
Item 1. Documentation: Reviewed documents that were associated with the Radiation Protection
Program which includes Respiratory Protection Training. The inspector was able to confirm that
training material followed guidelines in UAC R313-15, NRC Regulatory Guide 8.15 and NRC
Regulatory Guide 8.31 were being used and made available to Mill employees. The inspector was
able to verify that training, medical and fit-test records for each respirator user were being
maintained. The inspector verified training records for radiation safety for employees and
contractors was being maintained. In addition, the inspector was able to confirm that all
documentation was filled out with all relative information required and were complete and legible.
Deflciencies: None
Item 2. Employee Interviews: As part ofthe inspection. Mill employees were interviewed by the
inspector. Questions in the questionnaire were derived from the Mills Radiation Safety
/Respiratory Protection Training Program. Each employee interviewed was asked the same
questions and their responses were written down by the inspector.
The Radiation Coordinator was interviewed to determine his qualifications as a Radiation Safety
Trainer. In addition to his experience and training to date, the Radiation Coordinator will be
attending a RSO training course this year. The Radiation Coordinator committed to sending the
DRC a copy ofthe completion certificate at the end ofthe RSO fraining.
Deficiencies: During each interview the inspector observed that answers varied depending on the
experience of each employee. It was also apparent that all ofthe employees interviewed needed at
least some additional training on Radiation Safety. Recommended topics for additional training:
• The ALARA concepts of Time, Distance and Shielding;
• Routes of Exposure for Alpha, Beta and Gamma radiation; and
• Health effects associated with Alpha, Beta and Gamma radiation exposure.
Note: All ofthese topics were covered in the handout given to employees at the Radiation Safety
Refresher Course.
Item 3. RSO Interview: The inspector discussed with the RSO his qualifications to be the RSO
and the qualification of each Radiafion Technician as compared to the guidelines set in NRC
Regulatory Guide 8.31. The RSO will be complefing his RSO Refresher course this year and will
send the completion certificate to the DRC when it is completed. Additionally the RSO and
inspector discussed how often the RSO reviews training materials, procedure and retrains
personnel as State mles. Federal Regulations and License Conditions change.
Deficiencies: None
Item 4. Mill Tour:
The inspector went through the restricted area on a general site tour. At the time ofthe inspection,
the main Mill is not processing ore and different areas within the mill buildings are under
renovation, repair and cleaning. The tour went to the ore pad, the new decon pad, the mill and the
tailings ponds.
2 ofPage 4
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\Inspection Report RADMOD-Training-01 3-15-10 RJ.doc
While driving through the tailing cells the inspector observed the following:
• The Cameco UF4 Altemate Feed material being stored on Tailings Cell #2. The inspector
verified that the area was properly posted and observed that the Altemate Feed material was
packed in overpack containers.
The inspector was not able to observe ISL material being placed in the slit trenches due to that
work activity was not going on that day.
Other observations made during the mill tour included:
• The inspector observed a copy ofthe Respiratory Protection Program was being kept in the
respirator room;
• The inspector observed a list ofall qualified respirator users with the size of respirator that
they are fit tested for was kept in the respirator room;
• Respirators being decontaminated by hand as per respirator manufactures instructions;
• Other Altemate Feed materials being stored on the ore pad;
• PPE being wom by Mill workers in the main mill; and
• Archeological and earth moving activities in the area of Cell 4B.
Deficiencies: None
Item 5. Radiation Safety/Respiratory Protection Training: In addition to the Mill tour, the
inspector observed the RSO present the annual Radiation Safety Refresher training to company
employees. Observations made during that presentation:
• Radiation Safety training handouts were being used and given to Mill employees;
• Exams were given to Mill employees for Radiation Safety and Respiratory Protection;
• The changes in Radiological Posting were discussed that will occur when the Mill begins
processing ore;
• Annual Exposure Reports were handed out to employees and discussed; and
• A Review last year's (2009) safety and regulatory concems.
The Radiation Safety handout covers most of the topics outlined in NRC Regulatory Guide 8.31.
During the Radiation Safety/Respiratory Protection refresher training the inspector observed the
Radiation Coordinator verbally translate material for an employee. In later discussions with the
Radiation Coordinator, the Radiation Coordinator confirmed that he verbally translates into
Spanish exams and fraining material for a few ofthe Mill employees and for contractor workers.
Deficiencies: During discussions with the RSO and the Radiation Coordinator, there was an Initial
Employee training being done at the Mill the same week ofthe inspection. The Radiation Safety
portion ofthis training was done the day before the inspection was scheduled. Due to the topic of
this inspection, the inspector scheduled this inspection six weeks in advance with the Licensee.
This was done so the inspector could observe the training classes. The RSO informed the inspector
that the Initial Employee training was a last minute decision but the RSO made no attempt (email
or phone message) to notify the DRC inspector ofthe Initial Employee fraining.
Handouts and exams are not written in Spanish for non-English employees and contractors.
3 ofPage 4
C.\DOCUME-lUhultqui\LOCALS~l\Temp\XPgrpwise\lnspection Report RADMOD-Training-Ol 3-15-10 RJ.doc
Closeout Meeting
Denison Mines: Dave Turk (RSO)
Ronnie Nieves (Radiation Coordinator)
Utah DRC: Ryan Johnson (Inspector)
Findings
None
Conclusions and Recommendations
During the close out meeting the DRC inspector made the following recommendations regarding
items for improvement:
1. Have Radiation Safety and Respiratory Protection exams and handouts translated to
Spanish for employees and contractors who are not fluent in English.
2. Continue to develop and use handouts for Radiation Safety and Respiratory Protection
training and use during refresher and new hire fraining.
3. For next inspection on Radiation Safety and Respiratory Protection training coordinate with
the DRC to schedule a time when Initial Employee training is being done and can be
observed by DRC inspectors.
Recommendation for Next Inspection
1. Observe ISL material being placed in slit trenches on Tailing Cell #3
2. Employee Exit Monitoring
3. EvaluationofDesignatedEating Areas within the Restricted Area
4. Spills (yellowcake and other materials) being cleaned up in the mill immediately
Prepared By: Ryan Johnson '^^^^-J^^— — "-~" 3/16/10
(Print Name) ,^:::^y^ (Signatiire) (Date)
4 ofPage 4
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\lnspection Report RADMOD-Training-01 3-15-10 RJ.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-TRAINING-01
RADIATION PROTECTION & RESPIRATORY PROTECTION TRAINING/
RADIATION SAFETY OFHCER & RADIATION TECHNICIAN TRAINING
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Radioactive Material License UT1900479, License Renewal Application dated Febmary 28,
2007, Training Manual, addendums 9 and 10, Radiation Protection Manual, Section 1, 10CFR20, NRC
Regulatory Guide 8.30, NRC Regulatory Guide 8.31, Regulatory Guide 8.15, Utah Administrative Code
R313-15.
R313-15-101. Radiation Protection Programs.
(1) Each licensee or registrant shall develop, document, and implement a radiation protection program
sufficient to ensure compliance with the provisions of Rule R313-15. See Section R313-15-1102 for
recordkeeping requirements relating to these programs.
(2) The licensee or registrant shall use, to the extent practical, procedures and engineering controls based
upon sound radiation protection principles to achieve occupational doses and doses to members ofthe
public that are as low as is reasonably achievable (ALARA).
(3) The licensee or registrant shall, at intervals not to exceed 12 months, review the radiation protection
program content and implementation.
(4) To implement the ALARA requirements of Subsection R313-15-101(2), and notwithstanding the
requirements in Section R313-15-301, a constraint on air emissions of radioactive material to the
environment, excluding radon-222 and its decay products, shall be established by licensees or registrants
such that the individual member of the public likely to receive the highest dose will not be expected to
receive a total effective dose equivalent in excess of 0.1 mSv (0.01 rem) per year from these emissions.
If a licensee or registrant subject to this requirement exceeds this dose constraint, the licensee or
registrant shall report the exceedance as provided in Section R313-15-1203 and promptly take
appropriate corrective action to ensure against recurrence.
TRAINING MANUAL (Appendix J, 2007 License Renewal. Revised )
Addendum 9: Radiation Safety Training
In the ALARA program (Appendix I license renewal) 2.5.2 states that the Radiation Training for new
employees will follow NRC Reg. Guide 8.31 section 2.5.
NRC REG. Guide 8.31 Section 2.5 Radiation Safety Training
All new employees should be instructed by means of an established course in the inherent risks of
exposure to radiation and the fundamentals of protection against exposure to uranium and its daughters
before beginning their jobs. Other guidance pertinent to this course is found in Regulatory Guide 8.13,
"Instmction Conceming Prenatal Radiation Exposure" (Ref. 10), and Regulatory Guide 8.29,
"Instruction Conceming Risks from Occupational Radiation Exposure" (Ref. 11). Additionally, the
training should be commensurate with the risks and hazards of the task. This course of instmction
should include the following topics:
1) Fundamentals of Health Protection
• The radiological and toxic hazards of exposure to uranium and its daughters,
• How uranium and its daughters enter the body (inhalation, ingestion, and skin penetration),
• Why exposures to uranium and its daughters should be kept ALARA.
2) Personal Hygiene at UR Facilities
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMillVHP Inspection modules\2010\Inspection ModulesVRADMOD-
Training-01.doc
Page 1 of 11
o
<: ^7 ^^"''^ X^'i^i.^ic^^ p..''/7^7/^ ^,//.4
--2;:: ^,.:...:—
/ - ^^•••'' V^'^ ^-^''^^i./ ^;^_
/ _ y?..^ ..J7^ .^-^--^-^ T./,.X ^
y ^ .4 //'' ^-7^/0 ^- ^ 3
'fe'^/^;i,/'^-/ ^y-^-^v^^ ^^^/ -^;^ ^'-";^^3.^^^
Wearing protective clothing,
Using respiratory protective equipment correctly.
Eating, drinking, and smoking only in designated areas,
Using proper methods for decontamination (i.e., showers).
3) Facility-Provided Protection
Ventilation systems and effluent controls,
Cleanliness of the work place,
Features designed for radiation safety for process equipment,
Standard operating procedures.
Security and access control to designated areas.
Electronic data gathering and storage,
Automated processes.
4) Health Protection Measurements
Measurement of airbome radioactive materials,
Bioassays to detect uranium (urinalysis and in vivo counting),
Surveys to detect contamination of personnel and equipment.
Personnel dosimetry.
5) Radiation Protection Regulations
Regulatory authority of NRC, MSHA, and State,
Employee rights in 10 CFR Part 19,
Radiation protection requirements in 10 CFR Part 20.
6) Emergency Procedures.
A written or oral test with questions directiy relevant to the principles of radiation safety and health
protection in UR covered in the training course should be given to each worker. The instructor should
review the test results with each worker. The instructor should discuss any wrong answers to test
questions with the worker until the worker understands the correct answer. Workers who fail the test
should be retested after receiving additional training. These tests and results should be maintained on
file.
Each permanent worker should be provided an abbreviated retraining course annually. Documented
successful completion of the retraining course should also be maintained on file. Retraining should
include relevant information that has become available during the past year, a review of safety problems
that have arisen during the year, changes in regulations and license conditions, exposure trends, and
other current topics.
In addition, all new workers, including supervisors, should be given specialized instruction on the health
and radiation safety aspects and on the non-radiological hazards of the specific jobs they will perform.
This instruction should be in the form of individualized on-the-job training. Supervisors should be
provided additional specialized training on their supervisory responsibilities in the area of worker
radiation protection. Retraining should be conducted annually and documented. All employees should
sign a statement that they received job-specific radiation safety training. The statement should indicate
the dates the training was received and it should be cosigned by the instmctor. Radiation safety matters
of concem that arise during plant operation should be discussed with all workers during regular monthly
or bimonthly meetings.
All visitors who have not received training should be escorted by someone properly trained and
knowledgeable about the hazards of the facility. At a minimum, visitors should be instructed specifically
on what they should do to avoid possible radiological and non-radiological hazards in the areas ofthe
facility they will be visiting.
U:\rad\COMMON\Uranium milIsM I e(2)lITI900479 Denison Mines - White Mesa UMill\HP hispection modules\2010\hispection ModulesVRADMOD-
Training-01.doc
Page 2 of 11
>^.yu. ^ <
/hf''-' //
/A-y
../^^ u ' /^5,-/' ;/.
Contractors that have work assignments in a UR facility should also be given appropriate training and
safety instmction. Contractor workers who will perform work on heavily contaminated equipment
should receive the same training and radiation safety instmction normally required of all permanent
workers. Only job-specific radiation safety instmction is necessary for contract workers who have
previously received full training on prior work assignments at the facility or have evidence of recent and
relevant radiation safety training elsewhere.
1) Review the Radiation Safety material with the instmctor or attend a training class and identify if
each subject is covered. Was the following information covered in the licensee Radiation Safety
training as outhned in NRC Reg. Guide 8.31 Section 2.5.
NRC Reg. Guide 8.31 section 2.5 Yes No
Section 1: Fundamentals of Health Protection
The radiological and Toxic hazards of exposure to Uranium and its daughters
-How Uranium and its daughters enter the body (Inhalation, Ingestion and Skin
Penetration)
Section 2:Personal Hygiene at UR Facilities
-Wearing Protective Clothing
-Using Respirator Protective Equipment Correctly
-Eating, Drinking, and Smoking only in designated areas
-Using proper methods for decontamination
Section 3:Facility Provided Protection
•Ventilation Systems and Effluent Controls
-Cleanliness of the work place
-Features designed for Radiation Safety for process equipment </'
•Standard Operating Procedures
-Security and Access Control to designate.d areas
-Electronic data gathering and storage
-Automated processes
Section 4:Health Protection Measurements
-Measurements of Airborne radioactive materials
-Bioassays to detect Uranium (Urinalysis and in Vivo Counting)
-Surveys to detect contamination on personnel and equipment
-Personnel Dosimetry
Section 5: Radiation Protection Regulation
-Regulatory Authority of the NRC, MSHA and the State
-Employee Rights in 10CFR19 (R313-18)
-Radiation Protection Requirements in 10CFR20 (R313-15)
Section 6: Emergency Procedures
^iwf'? J ^^M i/^'^^ fer^.Ay J A^AnJ Sjf-^^^
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMillVHP Inspection modules\2010\hispecdon Modules\RADMOD-
Training-01.doc
Page 3 of 11
•n
,^^^yJ-X- /.^-^-^^ / '}^jfZ-.ey7^^
J r^y/^A
%/^ £L ,"y/ cy-f ^ ll U^^^d'^^^^ ^.^/<--
/C^ ^/^ CLc'l-:' ^J ^.s^ ^ /^•>/^^^''^
:7^ /^^y ^.^^^ f^f^^ ^^^^ ^^
f/6 0(^-' ^
<:::y<k^ A^
..^
/ly s^ ^O^
JliJi^r^ X^ ^-I^ ^v Vy Oi/^f ^ /7^^
t:'
2) Does the Radiation Protection training cover the information sufficiently to enable onsite personnel
to properly implement the Radiation Protection program and the ALARA program? Yes /^-^^No
Have the employee's demonstrated sufficient understanding of the material to be able to implement the
Radiation Protection program and the ALARA programs? Yes __:^_ No
Has this training been properly documented? Yes "-"""^Jo
Comments:
Section 3.1 Pre-Employment Instruction - Items I and J.
3) Did the licensee provide training to female employees on 'Prenatal Radiation Review'?
Comments: / . Yes X^ No
Training Manual Section 2.0 On-Site Contractors.
"New hire training, as outhned in Section 3.1, is included in the training program, as applicable to the
site work specifications, for on-site contractors."
4) Has the licensee documented initial training of on-site contractors?
Comments: Yes V No
Training Manual Section 3.1 Pre-employment Instruction.
"Classroom instruction of all new employees is conducted under the supervision of the Radiation Safety
Officer and Safety Coordinator, covering plant and personal safety, including radiation protection."
5) Has the licensee documented initial training of new employees?
Comments: ^ . , . Yes ^ No Dmjnents: .
/^ .Od? / TC CU&/i^ (f^:ry .Qj/'CT^^ o^/:^ /C O'/lC'^ Tciyey -7^^^
U:\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2010\Inspection Modules\RADMOD-
Training-01.doc
Page 4 of 11
O' So.^-yU .1^
Jp/'^,^^^-^ ^^-/^ ^-^ /^O^ ^/^ J'f'S^
>.../ /^ c^t>^jj r^cS) <^y- JTc^^'^ ^^^
/^:y^T^^J^,^<^ 73 .^^^^x ^/^ /^^ ^.-'^ ^^7^ ^
••-7 '
'-^
-^e^^-
now ^y ^^7^ .^<.v^ y:A /^Jl^ c^e^oj^^-^
6) Did the licensee provide annual refresher training on 'Radiation Protection'?
Comments: Yes
7) Does the licensee have employee's take a Radiation Safety Test each year? Yes
Is the test documented and kept in the employee's training file? Yes
Comments: , / / ,_——- /)
Record Review
7) Look at the training records of the employees who were interviewed.
Radiation Safety
Name Exams Initial/ Refresher
Training Records
Personnel
Monitoring
Prenatal Training/
Pregnancy Form
7w^ct-^cA4- ^/^.•i"
" /j>£-u^ /^^•--lu^ ^/6 L^
3. <^X/a-^-<g^ %(Ai. '(?U^ /JA-
'••A.Ji.^ ^^^/r jJAr
^- P^i/^^ A^y^^i sT^^ja Sc-ij^/^.^ r
Additional CommentsorOhseivatiuiis.
Addendum 10: Respirator Protection Training
In the ALARA program (Appendix I license renewal) 2.7.5. states that the Respirator Protection
Program will follow NRC Reg. Guide 8.15
NRC Reg. Guide 8.15 Section 5.2 Training
A training program, including hands-on training, must be established and implemented for respirator
users (see 10 CFR 20.1703(c)(4)). When face-sealing respirators will be used, this training should take
place prior to fit-testing. As a minimum, each trainee should:
• Be informed of the hazard to which the respirator wearer may be exposed, the effects of
contaminants on the wearer ifthe respirator is not wom properly, and the capabilities and
limitations of each device that may be used.
U;\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\2010\hispection Modules\RADMOD-
Training-01.doc
Page 5 of 11
pb -^ '{ny\^Jy^^ ^
\^ ^h -/-^ /hdiJ^^^^^'^ 5
.^
t-^.^ ,^<^
^:>^
;<b^c^_
^.'4, ^^x- A'U'^A^ ^
^y^ ^ O^^oz-t/^
^
Be shown how spectacle adapters, communications equipment, and other equipment that will be
used directly in conjunction with the respirator are to be attached and operated properly.
Be able to demonstrate competency in donning, using, and removing each type of respiratory
protective device that may be used.
Be instmcted in how to inspect each type of respiratory protective device that may be used and
be instructed to perform such an inspection before donning any device.
Be instructed in how to perform a user seal check on face-seahng devices and be instmcted to
perform this user seal check each time this type of device is donned.
Be informed that any respirator user may leave the work area at any time for relief from
respirator use in the event of equipment malfunction, physical or psychological distress,
procedural or communications failure, significant deterioration of operating conditions, or any
other condition that might necessitate such relief.
Be advised that in case of respirator malfunction or wearer distress, the respirator may be
removed as the respirator user exits the airbome contamination area.
8) Review the Respirator Protection Training material with the instructor or attend a training class and
identify if each subject is covered. Was the following information covered in the licensee Respirator
Training as outlined in NRC Reg. Guide 8.15 Section 5.2.
NRC Reg. Guide 8.15 Section 5.2 Training Yes No
Be informed of the hazard to which the respirator wearer may be exposed, the effects of the
contaminants on the wearer ifthe respirator is not wom properly, and the capabilities and limitations
of each device that may be used.
Be shown how spectacle adapters, communications equipment and other equipment that will be used
directly in conjunction with the respirator are to be attached and operated properly.
Be able to demonstrate competency in donning, using, and removing each type of respiratory
protective device that may be used.
Be instructed in how to inspect each type of respiratory protective device that may be used and be
instructed to perform such an inspection before donning any device.
Be instructed in how to perform a user seal check on face-sealing devices and be instructed to
perform this user seal check each time this type of device is donned. '1^
Be informed that any respirator user may leave the work area at any time for relief from respirator use
in the event of equipment malfunction, physical or psychological distress, procedural or
communications failure, significant deterioration of operating conditions, or any other condition that
might necessitate such relief
Be advised that in case a respirator malfunction or wearer distress, the respirator may be removed as
the respirator user exits the airbome contamination area.
9) Does the licensee provide training on the 'Respirator Protection Program'? Yes
How did they document that training?
Comments: , ^
X No
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP hispection modules\201 OXhispection ModulesVRADMOD-
Training-01.doc
Page 6 of 11
y/a- /o ^o^ ^-r ,c,^^ftT
'^—^ j^ '^^^c^
'^^'SO'--\
^••^'•^ Mr^ea^j
Oy-^vo ^T.TZ^
No 10) Does the training cover all of the outiined material? Yes ^^
If no what needs to be added or expanded?
Commeri,ts: ^ ^
t. J^,-< ^/^'C^:^^ S</, (%/)./^.'^T^ ^.^i.y^/' (yf/JP^^ /^>
^/•^§cZ^6<:^^ ^
M -^/ -/^
^^.rJ/.^.,^ -y^. >^-*^-'^/. / /n^^, ^
11) Did personnel that were interviewed have a good knowledge of the Respirator Protection^Erograml
Yes_^rrNo
If no what areas do they need to be retrained in?
Comments:
12) Look at the Respirator training records of the employees who were interviewed.
Name Exams Initial/ Refresher
Training Records
Medical Clearance Fit Tests
7plAtH.^.J^^~. O^.A.L
i^ A rS'^!7^/>w-^ ^
^i/"<-..^/<>
y 3. a f^/L ^
4. /TIZ.-T^ (CA^/C^
^-./j?^ /n/J^U^
Additional Comments orf Observations
Appendix I (ALARA Program) section 2.4.1 requires that the RSO should have the education, training
and experience as specified in NRC Regulatory Guide 8.31. Section 2.5 the RSO shall also receive
health and safety refresher training every two years. Section 2.4.2 The Radiation Safety Technician
(RST) shall have the qualifications specified in NRC Regulatory Guide 8.31.
U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMillXHP Inspection modules\2010\Inspection ModulesXRADMOD-
Training-01.doc
Page 7 of 11
/Cw^.^ /yi^iy^S 13) Who is the RSO's designee when the RSO is not available? _
Does the named designee have the same RSO education, training and experience as outlined in Reg.
Guide 8.31? Yes No^'
Does the RSOs designee receive additional training in health and safety?
Comments: Yes -.;>-—iNo.
^
14) Do the RSTs have the required education, training and experience as outlined in Reg. Guide 8.31?
Name of RST Qualified Y/N
"i^^
^
Time in Position Trained Y/N Assigned Duties
'^ T^ JtA ^ :^ -^ r -fjz-cJi- /^ '^^ . e<ry^i-
/3^^.^4$ Otyt^/-^— X z 2-I /i/^^%' ^ Xje cJ-^
fi>'A L /V/-^^ 17^ ~Z^ r At^/-^
jJJ^ JZ<^ '9-T' 2^ Y 77:0. /oa y,<^' ^•s. r X (^£yV IC •? % ^
^
Comments: /,
•7^ ^^ Al.
;^^7^. h
^^_Cg^ /-^A/ A'i.'h S(?i/i?^y /gi^^ZZ^ ^4a.-<U^
-^^,' ^ '^^ /^c^y-A y^, y^ f^-^-<\e' •^ 'y'^^^f _^ •oAi^ uyj K.
^. ^y,'Pry^<; ^1-^ ;-> M \i^-ny> 4-^,...^/
-^ '^-^^^•zZ-^ ^ /<A7 £:p^-^ 'tz>, .jt^/\^e,fiy,-^. -A..rf?. ,>^ A/ y^JA^c-^
-A^tA^ V./'ylZ-iJ^ (X,^fy lo Ao. f.^^ ITT^ /^ %/P,..^/^L .^,s y^.^/^
U:\rad\COMMON\UraniumiTiills\l le(2)UT 1900479 Denison Mines - White Mesa UMillVHP hispection modules\2010\hispection Modules\RADMOD-
Training-Ol.doc
Page 8 of 11
Radiation Safety Officer Interview
1) Employee Name lA-^y.c2^ A ^AAL.
2) Length of Employment ly L^'y^'^
3) Does the named RSO have the required education, training and experience as outlined in Reg. Guide
8.31?
Comments: Yes
4) Has the RSO received additional training in health and safety every two years? If so, when was the
last training? (ask for copy of certificate)
Comments^ . ^_.,._ ,- ,. Yes ^—^ No
cAAA "^^Ja^vZ-'cAe- LX-JJ.^ <^ht,xA>7^AA
5) How often do trainers receive refresher training so they are kept up to date on any changes to Utah
Rules, Federal Regulations, or changes in company programs, procedures and policies?
Comments:
A^ rM-*
6) How often do you review your Radiation Safety Training program and Respiratory Protection
Program to stay current with applicable State Rules and Federal Regulations?
Comments:
7) How often do you review the Mills Standard Operating Procedure so that they are current with
applicable State Rules, Federal Regulations, RML license conditions and the GWQDP?
Comments:
y:>-'^G-e t^ 07^''.
^y
8) How are the Radiation Safety Technicians trained to do their jobs?
Wrf-^ 4.^^ O/^'^t^P-^ 'A0r^..A.^-^ 3'r'X-J^ -A^^ ^ ALA
U:\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMillVHP hispection modules\2010\lnspection ModulesVRADMOD-
Training-01.doc
Page 11 of 11
I
s^
White Mesa Mill Date: 08/09 Revision: DUSA 2
Book #13 Training Manual 88 of 102
APPENDIX E
RADIATION SAFETY TRAINING OUTLINE FOR ANNUAL REFRESHER TRAINING
The following topics will be discussed in this training:
1. Relevant information that has become available during the past year
(a) Processing changes that may affect exposures
(b) Posting changes, if any
(c) Discussion of air, radon and beta/gamma survey results
(d) Changes to SOP's that affect Radiation Safety
2. Review of safety problems that have arisen during the year
(a) Discuss issues that have been raised through daily and weekly inspections
(b) Housekeeping issues
(c) RWP's
3. Changes in regulations and license conditions
(a) Discuss changes that affect the operation or other activities in the Mill
(b) Discuss NOV's or recommendations from the DRC
4. Exposure trends
(a) Average exposure for the previous year
(b) Highest exposure for the previous year
(c) Comparison of exposures versus background
(d) Discussion on the exposures rates received and how those results compare with the
ALARA goals
5. Other current topics
(a) Discuss any problem areas that may have arisen
6. Review of Key Radiation Safety Topics
(a) At the discretion of the instructor, selected key radiation safety topics, such as one or
more of the topics listed on the handouts included in Appendix C or on the Radiation Safety
Training outline set out as Appendix A, may be reviewed.
Name: Revised 2/4/2010
Respirator Quiz 2010
1. What is the exchange rate on respirators?
a. Daily
b. Weekly
c. Monthly
d. When I remember.
2. A PAPR has a protection factor of
a. 10
b. 50
c. 1,000
d. 10,000
3. A PAPR can be worn in which environments?
a. Dusty
b. Dusty/Chemical
c. Chemical/Moist
d. Moist
e. All ofthe above.
4. Who is responsible for the maintenance of your spectacle kit?
a. The Safety Department
b. Your immediate supervisor
c. Whoever cleans the respirators
d. Me
5. A field test is not required every time the seal is broken during usage:
a. Tme
b. False
6. Which type of respirator is appropriate for chemical mist environment?
a. PAPR
b. Full Face
c. SCBA
d. None ofthe above
7. Supervisors may keep their respirators for as long as they need.
a. True
b. False
8. An area posted as "Caution Radiation Area "means?
a. You must wear a respirator
b. Beta-Gamma values are at or above 5mrem/hr.
c. Lots of Dust in the air
d. None ofthe above
9. What may cause an individual to not be able to wear a respirator?
a. Big nose
b. Acne scars
c. Facial Hair
d. Hollow temples
e. All the above
10. A weekly exchange of respirators is ok if you have cleared it through the
RSO.
a. True
b. False
White Mesa Mill
Book #13 Training Manual
Date: 08/09 Revision: DUSA 2
82 of 102
RADIATION INFORMATION HANDOUT
(Summaiy of Key Concepts)
The following are items that are central to one's understanding ofthe Radiation Protection
Program for Denison Mines (USA) Corp. at the White Mesa Mill.
Definitions:
DAC - Derived Air Concentration
ALARA - As Low As Reasonably Achievable
NRC - Nuclear Regulatory Commission
DRC - State of Utah Division ofRadiation Control
TEDE - Total Effective Dose Equivalent (total dose from beta/gamma, as
measured by the OSL badge, air particulate and radon)
CEDE - Cumulative Effective Dose Equivalent (dose from radon and air
particulate. Does not include the dose from beta/gamma)
PAPR - Powered Air Purifying Respirator
SCBA - Self Contained Breathing Apparatus
RWP - Radiation Work Permit
OSL - Optically Stimulated Luminescence. Device used to monitor
beta/gamma exposure. Device must be worn in the center ofthe chest not on
the back of the hardhat.
Restricted Area - Consists ofall operational and disposal areas.
DACs:
Radioactive dust (air particulate) has a different impact on our bodies depending on what stage
ofthe process or location ofthe facility we are in. This is because the combinations of uranium
and its daughters (Radium 226, Thorium 230 and Lead 210) are different in the different stages
ofthe process. For example uranium and its daughters have equal radioactivity levels in
conventional ores on the ore pad, but yellowcake is mostly uranium and has hardly any daughters
present. The DAC is the acceptable level of radioactivity in a particular area ofthe Mill, taking
into account the mixtures of radionuclides found in the area. It sets the level of radioactivity in
air particulate that you could breathe on a full time basis for an entire working year in that area
ofthe Mill before exceeding the regulatory limit. For example, the DAC for the ore pad is more
restrictive than the DAC for the yellowcake area, reflecting the fact that the mixture of
radionuclides on the ore pad is more harmful to our bodies for any given level of radiation.
However, even though the mixture of radionuclides found on the ore pad is more dangerous than
the mixture of radionuclides found in the yellowcake packaging area for any given level of
radiation, the radiation levels in the yellowcake area are much higher than on the ore pad, thus
making the yellowcake packaging area an area of higher radiation concem than the ore pad.
Postings:
"Radioactive Materials Area" - signifies that anywhere beyond that point
there is the potential of coming into contact with radioactive materials. That
includes disposal areas, operational areas, product and raw ore.
White Mesa Mill
Book # 13 Training Manual
Date: 08/09 Revision: DUSA 2
85 ofl02
X
o Water sprays on ore pad and roadways
o Dust collection systems at various points in the process
Enclosed areas of high potential exposure to air particulate, such as
yellowcake areas
Use of respiratory protection in areas of high potential exposure to air
particulate
Designated eating areas
Personal hygiene to minimize ingestion (e.g., washing hands before eating,
washing work clothes)
Mandatory showers for yellowcake workers
Mandatory alpha scan for everyone who leaves the Mill's restricted area
Respiratory Protection:
Types of devices on site
o Full-face - with combo cartridges is good for both chemical and dusty
environments. Has a protection factor of 50.
o PAPR - is only good for dusty environments. Will not protect you in
a chemical mist type of environment. Has a protection factor of 1,000.
o SCBA - is good for all environments, but only has a 30 minute bottie
of air. Has a protection factor of 10,000.
Exchange policy - all respirators must be tumed into the Radiation/Safety
Department on a daily basis.
Denison IMines Corp.
6425 S. Highway 191, PO Box 809
Blanding, UT 84511
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
CONTRACTOR SAFETY RULES
Contractor shall be responsible for compliance with all local, State, Federal and Company safety,
health and environmentaJ laws and regulations in effect. Contractor shall also be held to understand
that this site is a State of Utah Division ofRadiation Control licensed facility and is govemed by the
rules and regulations ofthe Owner, State of Utah DRC and MSHA. Owner requires that all work
conducted by Contractor and its employees be performed in a responsible manner with special
attention and mutual cooperation on the part of everyone involved including Contractor, its employees
and the employeies of the Owner.
As part of its Contractual obligation. Contractor and its employees are expected to abide by all
applicable safety mles. Mandatory, (MSHA, OSHA, State or Company, etc.) safety and health
training must be received by all workers prior to starting any work on site. The mles listed belov/ are
minimum basic Owner Safety Rules and Regulations; they do not in any way contain every necessary
rule. Ifthe Contractor has questions concerning Safety Rules and Regulations, Contractor shall
consult with Owner's Representative before starting work.
The fact that other applicable mles, regulations or requirements (Federal, State or local) are not printed
herein will hot be an excuse for any violation. Any violations ofthese mles and regulations be it
accidental or intentional may be cause for termination ofthis contract.
OWNER SAFETY RULES AND REGULATIONS
L TRAINING
All contract employees must receive the training required by Owner prior to starting work
on site.
II. PERSONNEL PROTECTION
Hardhats, safety glasses, identification badges and steel toe shoes will be requured when
entering the mill area, whenever, work is performed in an environment, which requires
special protection, such as respirators, hearing protection, goggles or face shield, wet suits.
etc. this protection must be wom. If there is a question as to whether this special
equipment is required, contact the Owner's Representative.
Persons with hair that extends longer than two (2) inches below the tee shirt collar must
confine the hair.
If respiratory protection is required a respirator fitness physical and fit test are required.
Any question regarding this subject shall be directed to the Owners Representative.
Appropriate fall protection shall be wom at locations where there is a danger of falling
and/or where required by Owner.
III. RADIATION PROTECTION
The White Mesa Mill has a radioactive materials license with the State of Utah Division of
Radiation Control. Under that license, there are certain items that must be observed by all
parties on site. Those are, but not limited to:
a. Eating, drinking and chewing are only authorized in designated areas. These areas are
determined and posted by the Radiation Safety Officer. Potentially contaminated PPE
is not allowed in these areas.
b. All personnel, equipment and vehicles that enter into the restricted area, must be
surveyed for radiological release prior to leaving the restricted area. All mobile
equipment must travel through the decontamination wash station before being
presented for release from the site.
c. Before work assignments commence, the Contractor must present their job assignment
to the Radiation Department. The Radiation Department will determine exposure
potential and will issue a Radiation Work Permit if applicable.
d. All Contractor persoimel must submit to peiriodic bioassay monitoring for the
determination of potential uptake or ingestion Of uranium.
e. Respiratory protection may be needed if there is determined that an area is
contaminated. If respiratory protection is required, the Contractor will provide medical
clearance for their personnel. Respiratory devices will only be issued upon the
successfiil completion ofthe medical evaluation and onsite respirator fit testing.
f Personnel must monitor him or her with the use; of an alpha monitoring device prior to
leaving the restricted area. Monitoring locations are under surveillance to ensure that
proper techniques are being applied. Contractor personnel will be trained in the proper
use ofthese instmments.
g. Failure to comply with these items and others as deemed necessary by the Radiation
Safety Officer will be grounds for immediate termination of services at the facility.
mmm
IV. HOUSEKEEPING AND STORAGE
Debris will not be allowed to accumulate. Regular removal to designated areas is a
requirement. Tools, equipment and materials will be stored in a safe and orderly fashion
that minimizes interference with operations or traffic. Upon completion of the job.
Contractor shall remove all constmction debris and leave the site neat and orderly.
V. FIRE PROTECTION
a. Fire extinguishers are to be provided by Contractor and will be kept immediately
available when buming or welding in areas adjacent to combustible material. They
must not be obtained by removing Owner's extinguishers from established locations.
b. The White Mesa Mill is a smoke free work place. Therefore smoking is prohibited in
the administration building and the restricted area. It is necessary however to post areas
as no smoking areas wherever flammables are stored.
c. No person shall use open flames within 50 feet of where flammable materials are
stored.
d. Combustible material; i.e., grease, lubricants, flammable liquids, etc. shall not be
allowed to acciraiulate where they can create a fire hazard.
e. Personnel must be familiar with site emergency procedures; i.e. fire drills evacuation
drills, etc. as instmcted by the Owrier's Representative.
f Fire alarm procedures will be provided by Owner's Representative.
g. Flammable liquids (flash points below 100°F) shall not be used for cleamng purposes.
h. Containers of combustible or flammable liquids shall be bonded and grounded
whenever liquid is being transferred; hose must be in metallic contact during transfer,
i. Flame permits will be used where required by Owner's Representative,
j. Flammable or combustible materials must be stored in spill proof containers and
properly labeled.
VI. GENERAL
a. Utilities - Connection to or dismption of service of any utility, such as electricity,
steam, water, gas, etc., requires notice to and approval of Owner's Representative
before action is taken.
b. Alcohol and Drugs - No person will be permitted to work while under the influence of
or in the possession of alcohol or dmgs. Persons taking medication will not be
permitted to work it is affects their performance or judgment. A dmg and alcohol
testing policy is in place at this facility. All Contractor personnel will be subject to
random and accident investigation samplings.
c. Signs and Wammgs - Anytime work is performed which could present a hazard to
others; the area must be roped off or barricaded. All posted signs and other wamings
devices shall be strictly observed.
d. Horseplay - Horseplay will not be tolerated.
mmm
e. Eating Areas - Eating, drinking and chewing is permitted only in designated areas by
the Owner,
f Restricted Area - A radiation survey must be performed on all personnel and ,
equipment prior to leaving the restricted area. The restricted area consists ofall
operational and disposal areas,
g. All contractors while working on Company property are subject to Denison Mines
(USA) Corp. Drug and Alcohol Testing Policy. Testing may include accident
investigation, behavioral changes or impaired job performance, perceived dmg or
alcohol influence and random testing. A copy ofthe policy will be provided for each
contracting company.
Vn. SPECIAL PROCEDURES
a. Lockout procedures - When work is to be performed on any equipment, tanks and lines
the "Zero Energy" concept will apply.
Each job, which requires lockout must be authorized by Owner's Representative before
any equipment is tumed off or locked out. Owner's Representative will assist
Contractor to assure proper lockout procedure is followed.
To assure that the correct drive switch has been locked out; an attempt must be made to
start the equipment before work is started. The assurance can be gained on interlocked
systems by attempting to start the equipment at its local control station. If this proves
satisfactory, push the stop switch again.
Any gas or chemical lines that enter work locations must be blanked or have the valve
locked in the closed position. The valve must be locked or tagged so it can easily be
identified as a Contractor lockout. It will be the responsibility ofthe Contractor, to
assure lockout knowledge and compliance from their employees.
b. Flame Permits - A flame permit will be required and must be displayed when welding
or torching anywhere a fire hazard exists. A fire extinguisher and a pressurized water
hose must be ready at the job location during all welding and torching. A person must
be standing by and able to watch for any sparks which could start a fire.
No welding or cutting will be done within 50 feet of fiiel storage areas.
c. Confined Space Entry - Whenever work is done that involves entry into tanks, bins or
similar enclosures, a Confines Space Entry Evaluation and Safe Work Permit will be
required.
Other Safe Work Permit area include: working on chemical lines, working on any high
pressure system, operating equipment close to electrical lines or any hazardous
operation as determined by the Site Safety Coordinator.
Where a hazardous or oxygen deficient atmosphere is possible, special precautions will
be needed in addition the nonnal safety precautions, such as lockout, air fans,,
respirators, safety ropes, etc. Safety precautions may be found in the Safe Work
Procedure, which will be fumished by the Owner's Representative if applicable.
d. Process Lines - Process lines which contain or may have contained hazardous
chemicals or gases can be worked on only with specific approval ofthe Ovmer's
Representative.
VIII. MOBILE EOUIPMENT
Equipment will be kept in safe operating condition and be checked frequently. All
equipment must be operated by experienced operators and will be confined to the work
areas or places designated by the Owner's Representative. Drivers must be licensed if
driving on public roads. Speed limits and traffic rules will be observed. Owner's
equipment has the right-of-way. Observe caution, yield to traffic control signs. Speed
limits on property shall not exceed 15 mph.
Cranes, power shovels and similar equipment will be directed by a responsible person on
the ground when being moved through congested areas. Special attention must be paid to
overhead wires, piping and other obstmctions. (The ten-foot mle must apply)
All suspended loads which are being moved by mobile equipment; i.e., winch tmck, cherry
picker, etc., shall be secured with a tagline to prevent it from swinging.
All persons shall ride inside the cab or truck bed; absolutely no one is to ride on the fenders
or running boards. All persons riding in a vehicle shall keep both body and feet within the
protective area ofthe vehicle frame.
Protmding material that extends (2) feet beyond the rear ofthe vehicle shall be flagged.
Operators of gasoline powered vehicles shall stop the engines and place the ignition in the
off position when refiieling.
Drilling equipment must not be operated within (50) feet of any energized power line.
DC. HEAVY EQUIPMENT
a. All self-propelled equipment shall have adequate overhead protectors (Roll-over
Protective Stirictures - ROPS) to insure worker protection.
b. All self-propelled equipment (except wheeled tractor scrapers) shall be equipped with
backup alarms and the alarms must function when equipment is in use. A second
person will be responsible to guide tractor scrappers when scrapers are in reverse.
J M
c. Buckets, lifts or blades shall be left down when equipment is not in use.
d. Dump truck beds shall be in the down seat position while traveling.
e. No person shall place any part of his/her body under a suspended load. Push, never
pull. A suspended load, thereby keeping one's feet and body in the cleai". Whenever
possible, use a device to direct the load.
f After a piece of equipment has been down, the operator shall walk around and inspect
the equipment before moving it.
g. Persons shall not get on or off moving equipment,
h. Operators of equipment shall not work under overhanging walls until all safety
precautions have been taken and then only after a Safe Work Permit has been issued,
i. Travel speed of equipment shall be consistent with road conditions.
X. TOOLS AND EOUIPMENT
Tools and equipment will be kept in safe condition with all safety devices and guards kept
operable. Electrical tools will be provided with grounding protections (separate ground
wire, double insulated and or Ground Fault Intermpter). All portable electrical lights will
be properly guarded. Extension cords hoses; etc. will be kept in good condition and strung
so as not to create a hazard. All electrical devices will be checked prior to start of work for
resistance to ground to insure proper grounding is provided.
Compressed gas cylinders will be secured in an upright position. Gauged bottles will be
protected and guarded and shut off when unattended. Hoses and leads will be checked for
leaks prior to each use and repaired or replaced if found defective.
The "quick opening" coupling on compressed air, steam or any other high-pressure hose
must be pinned and whip checked. All bull hose must be securely chained.
XI. EXPLOSIVES AND BLASTING
a. All explosives shall be properly stored per ATF "Table of Distance" as to distance.
The construction ofthe magazine shall meet the ATF specifications.
b. All magazines shall be licensed.
c. No open flame shall be permitted in or within 100 feet of any explosive magazine.
d. Explosives and detonators (primers) shall not be fransported together. When being
fransported in the same vehicle, they shall be in different compartments, with
appropriate signs on vehicle (see local regulations).
e. All unused explosives and detonators shall be retumed to their proper magazine,
f All blasts shall be properly guarded.
g. Waming signs shall be used to halt use of two way radios during the loading and
blasting cycle when electrical blasting caps are used,
h. For blasting in open pit works. Owner's Representative shall be notified of each blast
prior to the blast. All blasting plans and guarding procedures shall be approved by the
Owner's Representative.
mmm
i. All blasting materials and magazines will be removed by Contractor upon completion
ofjob.
XII. REGULATORY AGENCIES
Code of Federal Regulations specifies that independent contractors will be held responsible
for compliance with all standards. The regulations require that the independent confractor
provide Owner with the following;
a. Contractor's frade name, business address, telephone number, confractor's ID number
for MSHA/OSHA or State and name of person in charge of project.
b. A description of the work to be performed and the place where it will be performed.
Confractor must provide Owner with the same information for each subcontractor before
each subcontractor begins work on Owner's Work Site.
XIII. ACCIDENT REPORTING
All accidents and/or injuries shall be reported to Owner's Representative immediately.
XIV. TRAFFIC CONTROL
Only those vehicle authorized by the Owner's Representative will be permitted in the
restricted area. All Contractor vehicles, equipment and personnel will be scanned for
radiological release prior to leaving the restricted area.
XV. MONITORING CONTRACTOR'S EMPLOYEES
Owner may perform certain monitoring on Contractor's employees, from time to time, to
ascertain the exposure ofsuch employees to various substances they may encounter in the
course of their work under Confractor's confract with Owner.
Owner will select the times, the conditions and the equipment to be used for such
monitoring. Owner will conduct such monitoring using its own personnel, but will do so
solely as an agent for the Confractor, and on the Confractor's behalf Owner's monitoring
may have for the protection and surveillance ofthe Confractor's employees and the
performance ofsuch monitoring shall not be deemed a waiver by the Contractor or as an
assumption by Owner of such responsibilities.
XVI. ADDITIONS OR CHANGES TO RULES
Additional area resfrictions, rules or procedures not defined in the Special Rules, etc., will
be provided by Owner's Representative or the department supervisor as necessary and must
be observed. Contractor personnel must immediately contact Owner's Representative if
there are any concems about potential hazards or proper methods before proceeding.
XVII. ARCHAEOLOGICAL DETERMINATION
During the course ofany work performed by Contractor, if any archaeological evidence is
discovered, i.e., artifacts or remains, the work must cease immediately and Confractor must
notify the Owner Representative immediately.
XVIII. LIGHTNING
If you hear thunder, lightning is close enough to strike you. Immediately stop what you are
doing and seek safety in a substantial building or metal topped vehicle with the windows
up. In the event that thunderstorm conditions develop, Denison Mines Safety Department
will notify all on site personnel to seek shelter. Stay in until 30 minutes after you hear the
last thunder or until the Safety Department determines it is safe to resume work activities.
By signing this acknowledgement, each Contractor denotes acceptance of all of the above safety
requirements of this Contract and agreement to abide by all federal, state and local laws and
regulations.
Name: Date:
(Print)
Confractor:
Brief Job Description:
Signature:
3 .«
mmm
Radiation Safety/Respirator Trainer Interviews
15) Employee Name
16) Employee Job Title ,/<:-.^^/V-^ /A^c:>
17) Length of Employment 3 (-7^ <:
/CP^A^- //epyes CA^ 7^7-.<^ ^/^/rAA^
18) What qualifications do they have to be a trainer?
Comments:
19) What additional training did the trainer receive when they were hired/assigned to be a trainer?
Comments: , /f / .^^ i -x ^„^ z'
AA ^<^AA.77c>.^A A^^.j-^ ,'A, 'A.'r:> y--7c^A -^^A -^^ -T^^-^
20) How often do they receive refresher training so they are kept up to date on any changes to Utah
Rules, Federal Regulations, or changes in company programs, procedures and policies?
Comments: /
21) What is a passing grade on a test? (** 70% or Higher)
Comments: ^ // /^
22) How many times is a person allowed to fail a test? (** 3 times)
Comments:
23) How do you document the training you do? (** attendance sheet, test exams)
Comments: ,- .;
**Denson Mines response to first round Health Physics Interrogatories dated February 5, 2009, question #27.
Ui\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMillVHP Inspection modules\2010\Inspection ModulesVRADMOD-
Training-01.doc
Page 10 of 11
Employee Interviews
1) Employee Name ;> /^tyJL- -^^^^ ^-A --^
2) Employee Job Title A-^^ r^-^^^...-^
3) Length of Employment 2- yy L^<r..-^S
4) Did Employee receive training when hired? Yes.
5) Did that training cover Radiation Safety? Yes_
6) Did that training cover Respiratory Protection? Yes Z-^-'^o
7) If employed longer than a year, Have they received any refresher training? Yes '^"""^No NA.
8) Did that training cover Radiation Safety? Yes l-A^o NA,
9) Did that training cover Respiratory Protection? Yes_
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA
11) Where do they wear their dosimetry? yAi^'-y /
12) Where do they store their dosimetry? -^.^ A^'^'' -^
13) What are the main types of radiation expected at this facility? A'.AJ-^^ , /v<^^^ / </7^'^'
14) What are the health risks associated with the types of radiation found at this facility?
~ 7 - —- y -
15) What are the main routes of exposure? .J^yXiU --^^'^ /^<"^ ^^ ^^Vv y </?•-. -T
16) How do you limit your exposure? /yr ^- -, "77^-^-t-.^ A 5 -^ -^ ^^~^ y ^ ^n.-^
17) Do you use a respirator? Yes /-^ No NA
18) How often do you use a respirator? /Z>yiy^^ IZ^^ ^ ^ AA^^'''-'''^ ^A^<-' ''^ A'-A '^^'^
19) How often do you exchange your respirator? yA: ^^
20) Where do you store your respirator? /C^p // VT- A^ /y-^-n
21) Have the employee demonstrate the proper method for donning and removing a respirator. Have
them include any inspection of the respirators and positive and negative checks.
Did they do it correctly? Yes_
What do you look for when inspecting your respirator?
What do you look for when you do a positive and negative test of your respirator?
Additional Comments:
U:\rad\COMMON\Uranium millsM le(2)UTI900479 Denison Mines - White Mesa UMill\HP hispection modules\2010\hispection Modules\RADMOD-
Training-Ol.doc
Page 9 of 11
Employee Interviews
1) Employee Name y/h'^-^ , //-^-n y^Y-as-. .^ /C^
2) Employee Job Title ^A^r.-.^y-^ S-
3) Length of Emplovment A i.^y <^
y^
4) Did Employee receive training when hired? Yes.
5) Did that training cover Radiation Safety? Yes /!
6) Did that training cover Respiratory Protection? Yes.
7) If employed longer than a year, Have they received any refresher training? Yes No NA_
8) Did that training cover Radiation Safety? Yes AA^O .NA
9) Did that training cover Respiratory Protection? Yes No NA
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA
11) Where do they wear their dosimetry? ^^^ A '^<^y-^ <P
12) Where do they store their dosimetry? Sfjt^rA'i' A^W % /'^^ A(A^<^ ^^
13) What are the main types of radiation expected at this facility? A'/^'''^^'' • ^y-/"^ <^ (A-^ --
14) What are the health risks associated with the types of radiation found at, this facility? '____
15) What are the main routes of exposure? /•^.oT~ 'p^y-^j..-
16) How do you limit your exposure? />^^>^^--t- .A^A. /^-^/'-^•^ l^/i.<xy /<-^A
17) Do you use a respirator? Yes ^^^-^ No^_^ NA
18) How often do you use a respirator? A-l '<n
19) How often do you exchange your respirator? ^y~A ^^T /:?vyy .^.^ ,'f y//rA'A<^ ^yA/^</^(
20) Where do you store your respirator? i^- A^ A^'7^
21) Have the employee demonstrate the proper method for donning and removing a respirator. Have
them include any inspection ofthe respirators and positive and negative checks.
Did they do it correctly? Yes yA^o
What do you look for when inspecting your respirator?
^Ar y-'u'.'^t:^ £g-..yU^y^r^ /< gj/^t..^ -^ Al <A^ •>y<^
What do you look for when you do a positive and negative test of your respirator?
y^i ^ /^^ ^s
Additional Comments:
ll:Vad\COMMON\Uran)um millsM le(2)UT1900479 Denison Mines - White Mesa UMill\HP hispection modulesMOIOVhispection Modules\RADMOD-
Training-O l.doc
Page 9 of 11
Employee Interviews
1) Employee Name /^C''^^^ A^ 3"^-'/^
2) Employee Job TiUe A-c^//? "/^<:i:4_
3) Length of Employment ( '^-t^^^c>—
4) Did Employee receive training when hired? Yes
5) Did that training cover Radiation Safety? Yes
6) Did that training cover Respiratory Protection? Yes_^
7) If employed longer than a year, Have they received any refresher training? Yes ^^-"-^o NA
8) Did that training cover Radiation Safety? YesAAL No NA
9) Did that training cover Respiratory Protection? Yes
10) If applicable did training cover 'Prenatal Radiation Review'? Yes l/^ No NA
11) Where do they wear their dosimetry? A^ •'"^ C^
12) Where do they store their dosimetry? <^''^ A^ AyJ<^ y^
13) What are the main types of radiation expected at this facility? AnAi-— , A--^^-^—^ T ^^-yi'-\—
14) What are the health risks associated with the types of radiation found at this facility?
15) What are the main routes of exposure? iyi:>/^ ^^ X-<^
16) How do you limit your exposure? Lyi^'^-^' yA A? A/-^-A^ AyA ^AA^C'AA
17) Do you use a respirator? Yes ^^-^""^ No NA
18) How often do you use a respirator? ->-"--i<g-/-^^-^L P-^\ ^^jt^t^^''A<- '^CJ'/J^ <rA.-^^''s:^A
19) How often do you exchange your respirator? A^^' A
20) Where do you store your respirator? A^'-7~'^'^'^ ''^ ^ 'A^ c A^' •'' ''^ '^/A^.-:^
21) Have the employee demonstrate the proper method for donning and removing a respirator. Have
them include any inspection of the respirators and positive and negative checks.
Did they do it correctly? Yes lA^ No
What do you look for wheij inspecting your respirator?
/^Ac ^ >.^ /TA^y: . V -AA/Ps ^y^A i>y^cA^ ~T^ ^^-^ "—y-
.. .^^ — J „u look for when you dc
Air (T A.., ^ A^/
Wh^ do you look for when you doa_positive and negative test of your respirator?
Additional Comments:
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP hispection modules\2010\hispecuon ModulesVRADMOD-
Training-01.doc
Page 9 ofl 1
Employee Interviews
1) Employee Name </S^t^f-^-^^ A7A^/^
2) Employee Job Title A.c,A "^^t:^^.^ -y^-
3) Length of Employment A ^^7-^^^ < -"-^ >W.^^
4) Did Employee receive training when hired? Yes J.-'-'^O
5) Did that training cover Radiation Safety? Yes ^:>-'"^No
6) Did that training cover Respiratory Protection? Yes.
7) If employed longer than a year, Have they received any refresher training? Yes '^'^ No NA.
8) Did that training cover Radiation Safety? Yes/l.!--'^T^o NA
9) Did that training cover Respiratory Protection? Yes.
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA .
11) Where do they wear their dosimetry? /^/^5"'<-^
'/"-^Ac^
12) Where do they store their dosimetry? -^^n. V-^i Afy^y'^ - X
13) What are the main types of radiation expected at this facility? /•"^ "• ' A-^'^
14) What are the health risks associated with the types of radiation found at this facility?
15) What are the main routes of exposure ? /l^,.u^ /A ;•
16) How do you limit your exposure? //5^ A -A^A i AtA'^-'^S^ y^(-^A'y
/A. S<^ $'<.. W ^^^ \
17) Do you use a respirator? Yes !y^ No NA
18) How often do you use a respirator? / O y -=^ •^ o^^'
19) How often do you exchange your respirator? Ck/y.-^-n A^^^
20) Where do you store your respirator? /4v.:^-e' /^ "AJL 3-- ^ ^^^^ r^ ^ A^<A^
21) Have the employee demonstrate the proper method for donning and removing a respirator. Have
them include any inspection of the respirators and positive and negative checks.
Did they do it correctly? Yes iy No
What do you look for when inspecting your respirator? ^^ ,
Ay,^ .^^O.//IA,.:^^-^^ ;-t/cl /^j/cr-s l A A<^^A
What do you look for when you do a positive and negative test of your respirator?
Additional Comments:
U:Vad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMillVHP hispection modules\2010\hispection ModulesVRADMOD-
Training-01.doc
Page 9 of 11
- . - _ Page 9 of 11
Employee Interviews
1) Employee Name iJe A^^^L^ A^y A^/U. y
2) Employee Job Title /^.^/>>'^'^^^^-^^ A.-cAyu,^—-,
3) Length of Employment 6 6^^-^-^ b>
4) Did Employee receive training when hired? Yes.
5) Did that training cover Radiation Safety? Yes
6) Did that training cover Respiratory Protection? Yes
7) If employed longer than a year, Have they recei vedan-y refresher training? Yes /^ No NA_
8) Did that training cover Radiation Safety? Yes No_ NA
9) Did that training cover Respiratory Protection? Yes Jy No NA
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA ,
11) Where do they wear their dosimetry? ^>T- /^ <^'A<z 7
12) Where do they store their dosimetry? jpoc-y^ A •'y A/^-y-^/A^ S ^<^/
13) What are the main types of radiation expected at this facility? Ayf^-^^ Ai^ A- ^ ^ .^.^^ e:;
14) What are the health risks associated with the types of radiation found at this facility?
y^-^T ^^yy \
15) What are the main routes of exposure? A^<-^..jAi— .^ J--^ ^y^,^/e <,
16) How do you limit your exposure? /^•^/'-^T^-^ , /y^C<^-y~ S'J^AJ ^, /s>/^cAS
^_, / , 7 i-^^ ^
17) Do you use a respirator? Yes '^'^ No NA
18) How often do you use a respirator? hol i^^-^ AA'^ ^
19) How often do you exchange your respirator? /V^ ^ ^y
20) Where do you store your respirator? y'i^A -H T^AA
T
21) Have the employee demonstrate the proper method for donning and removing a respirator. Have
them include any inspection of the respirators and positive and negative checks.
Did they do it correctly? Yes_
What do you look for when inspecting your respirator? /
3/yA^ "-^^ ?^^A<^ . A^fi^J, ,A^y:^ff^c^,t y CA^^:A_<.
What do you look for when you do a positive and negative test of your respirator?
yHi^.-k^< <>i/^ /f A^ /<.
Additional Comments:
U:\rad\COMMON\Uranium millsM le(2)UT190O479 Denison Mines - White Mesa UMill\HP hispection modules\20IO\lnspection Modules\RADMOD-
Training-Ol.doc
Page 9 of 11