DRC-2010-006406 - 0901a068801ea50d

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State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DPVISIGN OF RADL\TION CONTROL
Rust Lundberg
Director
RC-2010-006406
December 14, 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 UTl900479: Health Physics Inspection
RADMOD-Emergency-01
Dear Mr. Frydenlund:
On November 30, 2010, an inspection was conducted at your facility by Ryan Johnson, a
representative of the Division of Radiation Control (DRC) of the Utah Department of
Environmental Quality. Observations from the inspection were discussed with Rich Bartlet arid
David Turk at the closeout meeting. The inspection was an examination of the activities
conducted in your facility as they relate to compliance with the Utah Radiation Control Rules, the
license conditions of the Mills RML and Federal Regulations. 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 of the inspection report under
recommendations.
Enclosed is the inspection report regarding this inspection for your review. The DRC would like
to thank the Mill staff for their cooperation regarding this inspection. If you have any questions
concerning this letter contact Mr. Ryan Johnson [phone].
UTAH RADIATION CONTROL BOARD
Rusty Lundberg, Executive Secretary
RL/RJ:rj
Cc: David Turk, Site Radiation Officer
Enclosures
195 North 1950 West • Salt Uke City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq. iiiait.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-Emergency-01: Emergency Response
Inspection Location: Denison Mines- White Mesa Uranium Mill (Mill), Blanding Utah.
Inspection Item(s): Emergency Response Plan
Inspection Date(s): November 30, 2010
Inspector(s): Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted:
Dave Turk (Radiation Safety Officer (RSO)) Ronnie Nieves (Radiation Coordinator)
Ryan Palmer (Environmental Technician)
Governing Documents:
• UACR313-15
• NRC Regulatory Guide 8.31
• Radioactive Materials License (RML) UTl 900479
• RML UTl 900479 License Renewal Application (2/28/07)
Opening Meeting
Denison Mines: Dave Turk (RSO)
Utah DRC: Ryan Johnson (DRC Inspector)
Phil Goble (DRC Inspector)
During the opening meeting, the inspector discussed the items of the inspection. These items
included the documentation to be reviewed and the specific areas of the Mill that the inspector
wanted to see during the inspection.
Inspection Items:
• Evacuation Drill
• Documentation
• Mill Tour
Item 1. Evacuation Drill: The inspector observed the Mill perform an evacuation Drill. During
the drill the Mill tested both the evacuation alarm and the fire alarm. The inspector was able to
verify that Mill personnel evacuated the site in orderly fashion and went to their designated
evacuation assembly areas. All Mill personnel, contractors, truck drivers and visitors evacuated
the Mill in 5 minutes. An assessment of the drill was written up immediately afterwards.
Deficiencies: None
1 ofPage 2
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Item 2 Documentation: The inspector reviewed documentation associated with the Mills
Emergency Preparedness Plan. The inspector verified that the Mill has a letter of agreement with
San Juan County for emergency services. The inspector also reviewed the written assessments of
the evacuafion drills for 2010 and all of the weekly checklist that are done on all emergency
equipment and supplies.
Observation: The written assessments of the evacuation drills indicate that none of the evacuation
drills included an emergency scenario or a joint activity with local emergency responders (i.e.
sheriff, ambulance, hospital and fire department).
Item 3. Mill Tour: During the Mill tour the inspector was able to observe fire suppression
equipment and emergency cabinets. The inspector was also able to confirm that fire extinguishers
and other emergency equipment are checked on a regular basis. The inspector was also able to
confirm that the designated evacuation assembly areas are clearly posted.
Deficiencies: None
Closeouf Meeting
Denison Mines: Rich Bartlet (Mill Manager)
David Turk (Radiation Safety Officer)
Utah DRC: Ryan Johnson (Inspector)
Phil Goble
Findings
None
Observation
During the inspecfion the inspector made the following observafion:
1. The written assessments of the evacuation drills indicate that none of the evacuation drills
included an emergency scenario or a joint acfivity with local emergency responders (i.e.
sheriff, ambulance, hospital and fire department).
Recommendations
During the close out meeting the DRC inspector made the following recommendafions regarding
items for improvement:
1. At least once a year do an emergency scenario when doing an evacuafion drill. If it can be
arranged include local emergency responders in that drill.
Recommendation for Next Inspection
1. Employee Exit Monitoring
2. Confinue to do verificafion surveys on intermodals and ore trucks
3. Spills (yellowcake and other materials^being cleaned up in the mill immediately
Prepared By: Ryan Johnson /^^VU^^^ ^ 12/7/10
(Print Name) ^^-^^ (Signature) (Date)
2 ofPage 2
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Report RADMOD-Emergency-01 12-06-10 RJ.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-Emergency-01
EMERGENCY/FIRE PREPAREDNESS PROCEDURES
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTl900479
References: Radioacfive Materials License UTl 900479, NRC Regulatory Guide 8.31, NRC Inspecfion
Manual: Inspecfion Procedure 88050 Emergency Preparedness, License Renewal Application Appendix D
Emergency Response Plan Rev. 2, Utah Administrafive Code R313-15. R313-22
DATE // 5^^ - y^-
OPENING MEETING
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
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Page 1 of 8
DISCUSSION
SITE STAFF COMMENTS
R313'22-32. Filing Application for Specific Licenses.
(8)(a) Applications to possess radioacfive materials in unsealed form, on foils or plated sources, or sealed
in glass in excess of the quantifies in Secfion R313-22-90, "Quantities of Radioactive Materials Requiring
Consideration of the Need for an Emergency Plan for Responding to a Release", shall contain either:
(c) An emergency plan for responding to a release of radioactive material submitted under Subsection
R313-22-32(8)(a)(ii) shall include the following information:
(i) Facility description. A brief description of the licensee's facility and area near the site.
(ii) Types of accidents. An identification of each type of radioactive materials accident for which
protective actions may be needed.
(iii) Classification of accidents. A classification system for classifying accidents as alerts or site area
emergencies.
(iv) Detection of accidents. Identification of the means of detecting each type of accident in a timely
manner.
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(v) Mitigation of consequences. A brief description of the means and equipment for mitigating the
consequences of each type of accident, including those provided to protect workers on-site, and a
description of the program for maintaining equipment.
(vi) Assessment of releases. A brief description of the methods and equipment to assess releases of
radioactive materials.
(vii) Responsibilities. A brief description of the responsibilities of licensee personnel should an accident
occur, including identificafion of personnel responsible for promptly nofifying off-site response
organizafions and the Executive Secretary; also responsibilities for developing, maintaining, and updating
the plan.
(viii) Notification and coordination. A commitment to and a brief description of the means to promptly
notify off-site response organizations and request off-site assistance, including medical assistance for the
treatment of contaminated injured on-site workers when appropriate. A control point shall be established.
The notification and coordination shall be planned so that unavailability of some personnel, parts of the
facility, and some equipment will not prevent the nofificafion and coordination. The licensee shall also
commit to notify the Executive Secretary immediately after notification of the appropriate off-site
response organizations and not later than one hour after the licensee declares an emergency.
NOTE: These reporting requirements do not supersede or release licensees of complying with the
requirements under the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Public
Law 99-499 or other state or federal reporting requirements, including 40 CFR 302, 2005 ed.
(ix) Information to be communicated. A brief description of the types of information on facility status,
radioactive releases, and recommended protective actions, if necessary, to be given to off-site response
organizations and to the Executive Secretary.
(x) Training. A brief description of the fi-equency, performance objectives and plans for the training that
the licensee will provide workers on how to respond to an emergency including special instructions and
orientation tours the licensee would offer to fire, police, medical and other emergency persormel. The
training shall familiarize personnel with site-specific emergency procedures. Also, the training shall
thoroughly prepare site personnel for their responsibilities in the event of accident scenarios postulated as
most probable for the specific site including the use of team training for the scenarios.
(xi) Safe shutdown. A brief description of the means of restoring the facility to a safe condition after an
accident.
(xii) Exercises. Provisions for conducting quarterly communications checks with off-site response
organizations and biennial on-site exercises to test response to simulated emergencies. Quarterly
communications checks with off-site response organizations shall include the check and update of all
necessary telephone numbers. The licensee shall invite off-site response organizations to participate in the
biennial exercises. Participation of off-site response organizations in biennial exercises although
recommended is not required. Exercises shall use accident scenarios postulated as most probable for the
specific site and the scenarios shall not be known to most exercise participants. The licensee shall critique
each exercise using individuals not having direct implementation responsibility for the plan. Critiques of
exercises shall evaluate the appropriateness of the plan, emergency procedures, facilities, equipment,
training of personnel, and overall effectiveness of the response. Deficiencies found by the crifiques shall
be corrected.
(xiii) Hazardous chemicals. A certification that the applicant has met its responsibilities under the
Emergency Planning and Community Right-to-Know Act of 1986,|Title III, Public Law 99-499, if
applicable to the applicant's activities at the proposed place of use of the radioactive material.
(d) The licensee shall allow the off-site response organizations expected to respond in case of an accident
60 days to comment on the licensee's emergency plan before submitting it to the Executive Secretary. The
licensee shall provide any comments received within the 60 days to the Executive Secretary with the
emergency plan. j
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Emergency Response Plan Rev. 2
Section 1.2.3 Assembly and Relocation Areas
When the evacuation alarm sounds or when personnel are verbally notified by radio or other means all
personnel will assemble at:
• The parking lot south of the office;
• The Scale house;
• North side of Tailings Cell; or
• North of the Mill.
1) Are these areas marked as assembly areas? .
Comments: Yes y\ No
2) Are there any posfings in the Mill/work areas that identify assembly areas?
Comments: Yes No_\^
3) During the Mill tour ask several Mill employees if they loiow where the emergency assembly areas
are. Do Mill workers know where the Emergency assembly points are?
Comments: Yes/\ No
Section 7.3 Drills and Exercises
The drill and evacuafion acfivifies are documented by the Mills Safety Coordinator and maintained within
plant files Management reviews all drills at quarterly ALARA Committee Meefings
4) Review the documentation of the drills fi-om the past year. Did the Mill perform quarterly
Emergency/Fire drills?
Comments: Yes No ,
5) If possible, observe an Emergency/Fire drill.
Comments: Yes No_
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6) According to the NRC Inspection Manual: Inspection Procedure 88050 Emergency Preparedness: an
effective drill requires three (3) critical elements:
• A credible, technically correct, and challenging scenario to test key elements of the Emergency
Plan, procedures, equipment, and the onsite and offsite response organizations;
• Adequate facilities and resources; and
• Critical and candid assessment of the response using trained controllers and evaluators.
Comments: / Yes No
7) Who does the assessment of the emergency/fire drills?
Commits: Yes No_
8) Check the different fire stafions during the Mill tour. Have they been recently checked to see if they
are in working order ,
Comments: Yes No
General Comments and Observations:
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9) Observe a fire drill. According to the NRC inspecfion manual Inspecfion procedure 88055 Fire
Protecfion Annual Inspection. During the annual observation of a fire brigade drill in a plant area
important to safety, evaluate the readiness of the licensee or certificate holder's personnel to prevent
While observing a fire drill Yes No
Does the Mills fire brigade have Protective clothing/tumout gear and know how to properly
don the gear? X
Does the Mill have Self-contained breathing apparatus (SCBA) equipment and is the Mills fire
brigade know how to properly wear and use?
Are Fire hose lines are capable of reaching all necessary fire hazard locations, the lines are laid
out without flow constrictions, the hose is simulated being charged with water, and the nozzle
is pattern (flow stream) tested prior to entering the fire area of concem?
Was the fire area of concem entered in a controlled manner (e.g., fire brigade members stay
low to the floor and feel the door for heat prior to entry into the fire area of concem).
Is there sufficient fire fighting equipment brought to the scene by the fire brigade to properly
perform their firefighting duties?
Was the fire brigade leader's fire fighting directions are thorough, clear, and effecfive?
Was radio communications with the Mill operators and between fire brigade members efficient
and effective?
Did members of the fire brigade check for fire victims and propagation into other plant areas?
Was effective smoke removal operations simulated?
Was the fire fighting pre-plan strategies were used?
Was the licensee's pre-planned drill scenario followed, and the drill objectives acceptance
criteria met?
/L /.^^ ^ Comments: ^j, -_^^s^ y ^
10) _Documentation
Are the following documentation being kept at the Mill Yes No
Quarterly Communication Checks with off-site emergency responders. y
Letters of agreement with off-site emergency responders
>< Incident reports
Emergency Response drills documentation
Records of Emergency equipment checks
Comments: , ^ Yes No
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DATE /2 ~Z—/l7
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
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DISCUSSION of FINDINGS
y?-^ Z/fX^Ji^ r:£/'rf('h /"^ )^<::.LyA,&. C>>S''^Jf^ 4f^u^^,^^ Cy , gf^^of-^ -^o'f '(^
SITE STAFF COMMENTS
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Page 8 ofS
LETTER OF AGREEMENT
BETWEEN
SAN JUAN COUNTY FIRE AND EMERGENCY SERVICES
AND
INTERNATIONAL URANIUM (USA) CORPORATION
This letter of agreement, signed this 3*^ day of Tvv'^ , 2006 between San
Juan County Fire and Emergency Services, hereinafter referred to as the
"County" whose address is 117 South Main Street #202, Post Office Box 9,
IVIonticello, Utah 84535-0009 and International Uranium (USA) Corporation,
herein after referred to as "lUSA" whose address is 6425 South IHighway
191, Blanding, Utah 84511.
This letter of agreement shall be approved by the Board of County
Commissioners of San Juan County and its Fire Marshal and Director of
San Juan County Fire and Emergency Services and the President of
International Uranium Corporation and shall be valid for the period of three
years from the date of approval. The agreement shall be reviewed and
updated on at least an annual basis.
This letter of agreement outlines standard operating procedures for
preparation, training, and response by lUSA's Mine Rescue Team and the
County's Emergency Response Teams for facilities located in and around
San Juan County including but not limited to uranium mine rescues or
other technical rescue responses.
Point of contact the County will the Fire Marshal and Director for the
County's Fire and Emergency Services and point of contact for lUSA will be
lUSA's Radiation Safety Officer. These points of contact may be changed
at any time by either party by giving written notice.
County will provide first response type services to include law
enforcement, traffic control, emergency medical services, rescue services,
technical rescue such as rope rescue, emergency services, planning,
exercises, communications, public information, coordination and
correlation of services and needs through the State of Utah and the Federal
Government.
The County will provide for unified command system during any incident
and will allow for participation by lUSA to the maximum extent possible.
The County will provide for a joint information center (JIC) and will allow
for participation by lUSA to the maximum extent possible and would work
to providing joint press releases approved by both the County and lUSA.
The County, as required by Federal Statutes and rules and regulations will
operate under the National Incident Management Systems (NIMS). The
County will provide coordination and training to lUSA personnel to become
more familiar with this system and if desired, to become certified in this
program.
The County will assist lUSA with emergency planning and exercising as
requested and needed by lUSA in order to maintain and increase both the
County and lUSA's response capabilities.
lUSA agrees to assist the County with responses in other areas in the
County at the County's requests and upon availability of the company's
resources.
The County and lUSA agrees to be responsible for it's owns operations,
providing for its own liability insurance, workers compensation coverage
and agrees to hold each other harmless in its individual actions.
APPROVALS:
Lynn H. Stevens, Chairman
Sai^Jwan County Commission
Rick M. Bailey, Fire Marsiial and Director
San Juan County Fire Marshal and Director
1 Ron F. Hochstein, President
International Uranium (USA) Corporation
/Ncjrlrian L. Johnson, Ct6rk-Auditor
S^in Juan County C>^k-Auditor
WITNESS:
IntQfffational Uranium (USAfCorporation
APPROVED AS TO FORM:
Walter J. Bird, Deputy Attorney
San Juan County Attorney's Office
WHITE MESA MILL
FIRE/EVACUATION DRILL
Conducted Bv;/)r?\//r/ %lrk "/?. S. f).
Time: 9/^/- q:53
Did the Sirens woric? (Y) N
and f.Ve S/>en /^of^ tesTed
Department Check-Off
How long did it take to evacuate? f) IK
Maintenance: Operations: Labor: Office:
Coritlracitoi-s
Comments
WHITE MESA MILL
FIRE/EVACUATION DRILL
Date: Time: 1^3 2>
Conducted By: - gUA ^ ^.^U.
Did the Sirens work? Y N How long did it take to evacuate? ID
Department Check-Off
Maintenance: X Operations: X Labor: Office:
jA_il
Comments
1^
WHITE MESA MILL
FIRE/EVACUATION DRILL
Conducted By: \/^r)t//W I i^f-1< - Rnrlintinh i^afe-.tij DPflC^lr
Did the Sirens work?^|^ N How long did it take to evacuate? ^ yy^i ir\ S-
Department Check-Off
Maintenance: ^ Operations: ^ Labor: Office: *•
Comments
be oft be oft
QlTiC vnnrite^ia|c; ,. ^Ine nf -fl^ I n<d~ penile ~i,n Or ri
it ,
*Olire(rN, The ioudiness of tke S'lmeh eft -b|r,dl loCotv Ovx \s
( )
y )
WHITE MESA MILL
FIRE/EVACUATION DRILL
Date:idai^^jLii^^^^ Time: ,2lZIZii41_
Conducted By: ar,r.l C^je ^~tn\ C\lq^ irv^ - YY\\ c:.A\a\(>,c{ plf]OY\er h?imi3e<-
Did the Sirens work? ^ N How long did it take to evacuate?<^ kv^ i' i^.<^.. f] .<^f>^ _
Department Check-Off
Maintenance: y Operations: Labor: Office:
Comments
Jzvna.nntmh tij^i^- /nos. /o^^ i^'^.<^. ulk'fck U)os
h(^f~ ton Ipno r^.n/^.s/V^^/ny on iSite.
WHITE MESA MILL
FIRE/EVACUATION DRILL
Date:/^/.. 9.1^ Pnin Time: ZQ ff^
Conducted By: aCf^ jyci Oyy^tn^J ol^Xk/yrJ ,
Did the Sirens work?(^ N How long did it take to evacuate? Sry\mS. i^)
Department Check-Off
Maintenance: Operations: Labor: Office:
Comments
WHITE MESA MILL
FIRE/EVACUATION DRILL
Date:/>^ij^. 7^ jOiO Time: c3 : olQ P A/]
Conducted By: (W.C^LAO^J/^L ({[
Did the Sirens work? ^ N How long did it take to evacuate? KVnin.
Department Check-Off
Maintenance: ^ Operations: i/ Labor: ^ Office:
Comments
CJJtXyyjJZ'
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top catwalk level middle/inside south sidlj
top catwalk level inside! middle north side]#2
#6 west outer wall of elec. Panel room
#5 west outer wall of office
#4 east end of the elec. Panel room
#3 office north wall near bathroom
#7 office west wall near coffee maker
#1 outside office door
#2 outside rear office door
second level-yellowcake rake drive
Pump second level
ecip
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bottom level - sulfate - east end
bottorti level - yeirowcake area - west end
#1 floor level - indoors east end South wall
#2 floor level - indoors rniddle South wall
#3 flC)or level indoors west end South wall
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iadium #1 Ground floor _^
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Month Year
Ware, CCD CCR Boiler Maint SX Van. Lab. Scale Truck
Band-Aids standard size 3/4 x 3; 1 x 3 y y y ^A y y y
Fingertip Band- Aids •y> y y y^ y y y
Band- Aids extra large 2" x 4" / c.
V y y^ y y y y^
; Gauze pads 2" x 2" y y y y y y y y y
' Gauze pads 3" x 3" y y •y y y y y y y
( Gauze pad 4"x4" y y \y \y y y y y y
[Eye pads oval .y y y y y y y y K
Compress dressing (extra large) y' y y <y y y y \y y
|Triangular bandage y y y \/ y y y y
^^Gauze roll y \y y ty \y y y y y V
^Medical Tape y y y y y y y y y
lEFaistic bandage rolls /v/ y y y ! y y y y . y .
^.Alcohol Prep. Pads y y \y ^/ y y y y y
lAnitbiotic ointment/ Neosporin \y y y iy y y y y
'fAnti- itch cream y y !/• y y y y y y \y
;|Moisturizing skin conditioner Hy y y Qy y y y y
|Burn Jel y y \y y \y y y y
XoldPack y V 1 y y y y •••/ •• fiEyeWash y y y y y y y-• v ••••••
/ Calgpnate (calcium gluconate gel) y y y y y y y^ y y
;^^BIopd Sugar Relief y y y y y y y y ':y.
^Gipyes y -y y y y y y y y
'Barrier Device y y y y y y y y
^Tweezers y y y y y y \y y 0
iScissors y y y y / y y y y
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