DRC-2010-005447 - 0901a068801cae44

1»\ OF 'UlsSi.
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
.Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director DRC-2010-0G5447
September 29, 2010
David Frydenlund, Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17"^ Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Materials License (RML) UTI900479
Dear Mr. Frydenlund:
action taken to
0. The
Thank you for your letter dated September 10, 2010, informing us of the corrective
rectify the violations identified in a Notice of Violation (NOV) dated August 5, 201
corrective action of training the staff at the White Mesa Mill on current DOT requirements for
shipping papers of radioactive material is appropriate. We have no further questions at this time
and consider the NOV dated August 5, 2010 closed. We will review the effectiveness of your
corrective action during a future inspection.
Thank you for your cooperation in this matter. If you have any question please contact Mr. Ryan
Johnson at [phone] or at [e-mail].
UTAH RADIATION CONTROL BOARD
Rusty Lundberg, Executive Secretary
RL/RJ:rj
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt LakeCity, UT 84114^850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utali.gov
Printed on 100% recycled paper
#RC-Z010>004«|1
DENISO
MINES
September 10, 2010
VIA E-MAIL AND OVERNIGHT DELIVERY
Rusty Lundberg
Utah Deparfmenf of Envlronmenfal Qualify
195 North 1950 West
P.O.Box 144810
Salt Lake Ci/y, UT 84114-4620
Oanl«4n MInM (USA) Corp.
lOMlhh Street, SURB MO
Danvof, CO 802BS
USA
T«i: 3ta m-rm
Fu:3p3M»41U
www.aeni8oniiilnM.coni
1i
Re: Sfafe of Utab Radioacfive Maferials License ("RMLj UT1900479
Response fo Ufab Department of Environmental Qualify C"UDEQ°)
Notice of Proposed Imposition of Civil Penalty August 5, 2010
Dear Mr. Lundberg:
Vbis letter responds fo C/DEQ's Nofice of Proposed Imposition of Civil Penalty Augtjsf
findings resulting from a July 20 and 21, 2010 inspection of Denison Mines (USA; Corp
Mesa Mill Cfbe "MiU";.
Tbe sections and numbering of tbis letter follow tbat of UDEQ's August 5, 2070 tetfer. E^cb violation idenfified
by UDEQ is shown in italics, below, followed by Denison's response.
/. 49 CFR 172.203(d) states: Tbe description for a shipment of a Class 7 (radioacti\\e) material must
include the following additional entries:
49 CFR 172.203(d)(1) states: "The name of each radionuclide in the Class 7 (radioactive)
that is listed in § 173.435 of this subchapter. For mixtures of radionuclides, the
required to be shown must be determined in accordance with § 173.433(g) ofthls
Contrary to the above, the Licensee failed to record the radionuclides of fbe L/3O3 (Uranium
yellowcaKe) on multiple shipping papers dated from February 9, 2010 to July 16,2010.
49 CFR 172.203 (d)(2) states: "A description ofthe physical and chemical form ofthe material, if
the material is not in special form (generic chemical description is acceptable for qhemical form).
Contrary to the above, the Licensee recorded the chemical form but failed to recoid the physical
form (e.g. solid, liquid, gas) ofthe U3O8 (Uranium yellowcake) on multiple shipping papers dated
from February 9, 2010 to July 16, 2010.
49 CFR 172:203(d)(3) states: "The activity contained in each package ofthe shipifient
the appropriate SI units (e,g,, Becquerels (Bq), Terabecquerels (TBq), etc.). The
also be stated in appropriate customary units (Curies (Ci), milliCuries (mCi), micrdiCuries
5, 2010 regarding
s ("Denison's") Wbife
material
radionuclides
subchapter,'
in terms of
^cf/v/fy may
(uCi),
Letter to Mr. Rusty Lundberg
September 10, 2010
Page 2
efc.j in parentheses following the S/ un/ts ..."
Contrary to the above, the Licensee failed to record the radiological actA//ty ofi the UaOg (Uranium
yellowcake) on mu/t/p/e sh/pp/ng papers dated from February 9, 2070 to July 16,2010.
a) Root Cause of the Noncompliance
Mill environmental personnel were insufficiently trained regarding the requirements of 40 CFR 172.203(d)(1),
(2), and (3) - specifically relating to the requirements that the Shipper's Paper must include information on
radionuclides, physical form, chemical form, and activity of the contents of each package. Environmental
personnel mistakenly assumed that the term "uranium oxide,* which has historically been used since the Mill's
inception, was sufficiently descriptive of physical, chemical and radionuclide content. In addition, the Shipper's
Paper form did not include a location to record activity levels.
b) Steps That Have Been Taken to Correct the Violation
The following steps have been taken to correct the violation:
Mill environmental staff have been re-trained, specifically with respect to the DOT requirement in 40 CFR
172.203, that the Shipper's Paper must have enough information to address each of the parameters:,
radionuclides, physical form, chemical form, and activity. As of August 2, 2010, the Shipper's Papers have
been modified to slate that the contents are "drums of natural uranium (Unat) in the form of U^Og powder.' Per
our discussion with Mr. Ryan Johnson on August 12, 2010, we understand that this designation is acceptable
for the following reasons:
• The term "natural uranium (Unat)" indicates the presence of the distribution of uranium radionuclides
^y234 (j235^ y238j speclflc to natural uranium and sufficiently describes the radionuclide content to
comply with 40 CFR 172.203(d)(1),
• The term "U3O3" sufficiently defines the chemical form (triuranium octoxide) to comply with 40 CFR
172.203(d)(2), and
• The description "in the form of yellowcake powder" sufficiently defines the physical form (powder) to
comply with 40 CFR 772.203(d)(2).
In addition, the Shipper's Paper form has been modified to include a space requiring the recording of the
activity. Mill environmental staff have also been re-trained, specifically with respect to the DOT requirement in
40 CFR 172.203(d)(3), that activity must be recorded at this location on every form.
c) Date When Compliance Was or Will be regained
Compliance was regained on August 2, 2010 when use of the new Shipper's Paper form, containing all the
required information described above, was put into place.
d) Steps Taken to Prevent Reoccurrence of the Noncompliance
Mill staff involved in preparing the Shipper' Papers have been retrained to understand that only the updated
Shipper's Paper form, instituted on August 2, 2010 fully complies with the requirements of 40 CFR 172.203(d).
The previously used template for the Shipper's Paper form has been destroyed. The training clarifies that only
the updated form may be used.
DENISO MINES Mi
Letter to Mr. Rusty Lundb
September 10, 2010
Page 3
49 CFR 772.203(d)(9) states; "For a shipment required by this subchapter to be
exclusive use; (/) An indication that the shipment is consigned as exclusive use;
descriptions on the shipping paper are consigned as exclusive use, fben tbe
Use Shipment" may be entered only once on the shipping paper in a clearly visibly
consigned as
(ii) If all the
statelfnent "Exclusive
location. °
Contrary to the above, the U'censee did not indicate that the U^Oa (Uranium Yellowcake)
shipments are "Exclusive Use"on multiple shipping papers dated from February ^ 2070 fo July
16, 2070.
e) Root Cause of the Noncompliance
Mill environmental personnel were insufficiently trained regarding the requirements of 40 CFR
addition, the Shipper's Paper form did not include a specific section or entry for the statement
f) Steps That Have Been Taken to Correct the Violation
The following steps have been taken to correct the violation:
Miii environmentai staff has been re-trained, specifically with respect to the DOT requirem<jnt
172.203(d)(9), that each Shipper's Paper must include the statement "Exclusive Use.". As
the Shipper's Papers have been modified to include a section for the entry "Exclusive Use
g) Date When Compliance Was or Will be regained
Compliance was regained on August 2, 2010 when use of the new Shipper's Paper, conta ning the entry
"Exclusive Use," was put into place.
h) Steps Taken to Prevent Reoccurrence of the Noncompliance
Mill staff involved in preparing the Shipper" Papers have been retrained to understand that
Shipper's Paper form, instituted on August 2, 2010 fully complies with the requirements of
172.203(d)(9). The previously used template for the Shipper's Paper form has been
clarifies that only the updated form may be used..
172.203(d)(9). In
'Exclusive Use".
in 40 CFR
ofAugust 2, 2010,
only the updated
40 CFR
destnjyed. The training
Denison has also enclosed with this letter a check for $1,500.00 in payment of the ciyil penalty imposed in
UDEQ's August 5, 2010 letter.
Please contact the undersigned if you have any questions or require any further information
DENISO
MINES
Letter to Mr. Rusty Lundberg
September 10, 2010
Page 4
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
K. Weinei
Central files
DENISON MINES lUSA) CORP. 47284
Vendor ID " " Name -i . '••'••••i. J>ayment Number. . Cheque l)ato OocMment Nuinber v,!-'
UTA005 State of Utah 00000000000020306 9/10/2010 0047284
Our voucher Number • ; jOate i - Amount - r AoKMint'Pald .'.L :;jp|scbunt i < %8t AmoiijntPaid
UT1900479PENALTY 8/5/2010 $1,500.00 $1,600.00 $0.00 $1,500.00
$1,500.00 $1,500.00 $0.00
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$1,500.00
DENISO MINES
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RE: July inspection / RJ
David C Frydenlund
Vice President & General Counsel
Denison Mines (USA) Corp (DUSA)
1050 17th ST STE 950
Denver CO 80265 _ ^
PS Form,3800'. AuC|iisr2006
'See Wevei se - to 1.1 n a 11 ui: t iq h s
State ofUtah
GARY R. HERBERT
Govemor
GREG BELL
LieuienanI Governor
Department of
Environmental Quality
Amanda Smith
Execulive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
Augusts, 2010
CERTIFIED MAIL
RETURN RECEIPT REQUIRED
David Frydenlund, Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17* Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Materials License (RML) UTI900479
Dear Mr. Frydenlund:
On July 20 and 21, 2010, an inspection was conducted at your facility by Ryan Johnson,
Division of Radiation Control of the Utah Department of Environmental Quality. Result^
were discussed with David Turk (Site Radiation Safety Officer) and Ronnie Nieves at the
inspection.
relate The inspection was an examination of the activities conducted in your facility as they
the Utah Radiation Control Rules, the conditions of the facilities Radioactive Materials
Regulations. The inspection consisted of the examinations of procedures and representat
of personnel, independent measurements, and observations by the inspector. It was noted
activities were conducted in compliance with Federal Regulations.
To aid you in correcting these non-compliant activities, a Notice of Violation and Notice
Imposition of Civil Penalties is enclosed. The particular violations are described in the
UTAH RADIATION CONTROL BOARD
representative of the
of the inspection
conclusion of the
to compliance with
License mid Federal
jve records, interviews
that not all of your
of Proposed
enclosed Notice.
Rusty Lundberg, Executive Secretary^
RL/RJ:rj
Cc: David Turk, Site Radiation Officer
Enclosures
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
UTAH RADIATI«)N CONTROL BOARD
NOTICE OF VIOLATION
AND
y NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTY
Denison Mines (USA) Corp.
Independence Plaza, Suite 950 i iTT-innr>/no 1050 Seventeenth Street License Number:UT 1900479
Denver, Colorado 80265
An inspection of the licensee's activities was conducted on July 20 and 21, 2010. As a result of the
inspection, violations of U.S. Department of Transportation regulations as referenced in Utah Radiation
Control Rules were identified. The Executive Secretary of the Utah Radiation Control Board proposes a
civil penalty. The authority for this proposed action is Utah Code Annotated (1953, as amended) Section
19-3-109. The proposed penalties have been arrived at by using R313-14 of the Utah Radiation Control
Rules. The particular violations and the associated proposed civil penalty are set forth below:
Radiation Control Rule R313-19-100(5)(a) states: "Each licensee who transports licensed material
outside the site of usage, as specified in the license issued by the Executive Secretary, the U.S. Nuclear
Regulatory Commission or an Agreement State, or where transport is on public highways, or who
delivers licensed material to a carrier for transport, shall comply with the applicable requirements ofthe
U.S. Department of Transportation regulations in 49 CFR parts 107, 171 through 180, and 390 through
397 (2006), appropriate to the mode of transport."
1. 49 CFR 172.203(d) states: "The description for a shipment of a Class 7 (radioactive) material must
include the following additional entries:
49 CFR 172.203(d)(1) states: "The name of each radionuclide in the Class 7 (radioactive) material
that is listed in § 173.435 of this subchapter. For mixtures of radionuclides, the radionuclides
required to be shown must be determined in accordance with § 173.433(g) of this subchapter."
Contrary to the above, the Licensee failed to record the radionuclides of the U3O8 (Uranium
yellowcake) on multiple shipping papers dated from February 9, 2010 to July 16, 2010.
49 CFR 172.203(d)(2) states: "A description of the physical and chemical form of the material, if
the material is not in special form (generic chemical description is acceptable for chemical form).
Contrary to the above, the Licensee recorded the chemical form but failed to record the physical
form (e.g. solid, liquid, gas) of the U3O8 (Uranium yellowcake) on multiple shipping papers dated
from February 9, 2010 to July 16, 2010.
49 CFR 172.203(d)(3) states: "The activity contained in each package of the shipment in terms of
the appropriate SI units ( e.g., Becquerels (Bq), Terabecquerels (TBq), etc.). The activity may
also be stated in appropriate customary units (Curies (Ci), milliCuries (mCi), microCuries (uCi),
etc.) in parentheses following the SI units...."
Contrary to the above, the Licensee failed to record the radiological activity of the U30g (Uranium
yellowcake) on multiple shipping papers dated from February 9, 2010 to July 16, 2010.
w UTAH RADIATION CONTROL BOARD
NOTICE OF VIOLATION
AND
NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTY
Page 2
Denison Mines (USA) Corp. License Number: UT 1900479
The above violation has been characterized as Severity Level IV. The base penalty for this
Severity Level is $750.00. Therefore, a civil penalty of $750.00 is proposed.
49 CFR 172.203(d)(9) states: "For a shipment required by this subchapter to
exclusive use: (i) An indication that the shipment is consigned as exclusive uSe:
descriptions on the shipping paper are consigned as exclusive use, then the statement
Use Shipment" may be entered only once on the shipping paper in a clearly v i
Contrary to the above, the Licensee did not indicate that the U3O8 (Uranium
shipments are "Exclusive Use" on multiple shipping papers dated from February
16,2010.
This violation has been characterized as Severity Level IV. The base penalty
Level is $750.00. Therefore, a civil penalty of $750.00 is proposed.
be consigned as
or(ii) If all the
"Exclusive
sible location."
Yellowcake)
9, 2010 to July
for this Severity
Therefore, a total civil penalty for both of the violations of $1,500.00 is proposed
m
The licensee may, within 30 working days of receipt of this Notice, pay the civil penalty
cumulative amount of $1,500.00, or may protest the imposition of the civil penalty i
a written answer. Should the licensee fail to answer in the time specified, the Utah
Board will issue an order imposing a civil penalty in the amount proposed.
in the
whole or in part by
Radiation Control
Any reply to the Notice of Violation should include, for each violation: (1) the correictive
have been taken and the results achieved; (2) the corrective steps which have been taken
recurrence; and (3) the date full compliance will be achieved. A response protesting
Civil Penalties shall include: (1) an admission or denial of the item of non-compliance
demonstration of extenuating circumstances; (3) a showing of error in the Notice of Violation
other reasons why the penalty should not be imposed.
steps which
to prevent
the Imposition of
;(2)a
;or(4) '
Any response or written answer to this Notice of Violation/Notice of Proposed Imposition of Civil
Penalty should be addressed to Rusty Lundberg, Executive Secretary, Utah Radiation Control Board, 168
North 1950 West, P.O. Box 144850, Salt Lake City, Utah 84114-4850. The licensee's attention is
directed to the Administrative Procedures set forth ih UCA 63G-4. If a hearing is recjuested, the
Executive Secretary of the Utah Radiation Control Board will designate the time and place of the hearing.
1 UTAH RADIATION CONTROL BOARD
NOTICE OF VIOLATION
AND
NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTY
Page 3
Denison Mines (USA) Corp. License Number: UT 1900479
Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the
applicable provisions of UCA 19-3-109 and R313-14, the matter may be referred to the Attomey General,
and the civil penalty may be collected by civil action pursuant to UCA 19-3-109(5).
Dated atSalt Lake City, Utah
This day of August, 2010
UTAH RADIATION CONTROL BOARD
Rusty Lundberg, Executive Secretary
State ofUtah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Execulive Director
DIVISION OF RADIATION CONTROL
Rust Lundberg
Director
August 4, 2010
David Frydenlund, Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 \ Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Material License (RML) Number UTI900479
Dear Mr. Frydenlund:
On July 20 and 21, 2010, an inspection was conducted at your facility by Ryan Johnson, a
representative of the Division of Radiation Control of the Utah Department of Environmental
Quality. Observations from the inspection were discussed with Dave Turk and Ronnie Nieves 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 and the 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. JDuring 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 conclusions and
recommendations. A Notice of Violation has been issued in a separate document in regards to
two ofthese recommendations.
Enclosed is the inspection report regarding this inspection for your review. The DF.C would like
to thank the Mill staff for their cooperation regarding this inspection. If you have ar y questions
conceming 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 Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801-533^097 • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-SSS-01: Surveys/Shipping Papers/Sources
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Release Surveys, Shipping Papers and Sealed Sources
July20and July21,2010
Ryan Johnson, Utah Division of Radiation Control (DRC)
Inspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted: Dave Turk (Radiation Saftey Officer (RSO)), Ronnie Nieves (Radiation
Coordinator), Charles Orvin. (Radiation Technician) and Justin Perkins
(Radiation Technician)
Goveming Documents:
Opening Meeting
UAC R313-15
49 CFR
NRC Regulatory Guide 8.30
Radioactive Materials License (RML) UTI 900479
RML UTI 900479 License Renewal Application (2/28/07|) Appendix E
(Radiation Protection Manual),
Denison Mines White Mesa Mill Procedures: End Dump Trailer
Acceptance, Handling and Release, PBL-9, Rev No R-O and Intermodal
Container Acceptance, Handling and Release, PBL-2, Key No R-3
Denison Mines: Dave Turk (Radiation Safety Officer)
Ronnie Nieves (Radiation Coordinator)
Utah DRC: Ryan Johnson (Inspector)
During the opening meeting, the inspector discussed the inspection items, follow-up items and
documentation to be reviewed during the inspection.
Inspection Summarv
The inspection consisted of employee interviews, review of documentation and a mil|l tour. The
following discussion provides more detail of the specific items.
Item 1. Employee Interviews:
Two employees of Denison Mines were interviewed during this inspection. The inspector asked
questions to the mills Radiation Technicians, who are responsible for performing and documenting
surveys to release ore trucks, product dmms, intermodal containers and equipment from the
restricted area. The questions related to the training they have received the requirements for a
1 of Page 5
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proper release survey and source checking instruments. Each employee was asked the same
questions and their answers were written on a questionnaire by the inspector.
The employees interviewed were:
Charles Orvin (Radiation Technician) Justin Perkins (Radiation Technician)
Deflciencies:
The answers from the two employees varied depending on their experience and specific job
responsibilities. The radiation technicians have been working less than one year at their present
job assignments. Both of the technicians had difficulty with the release limits and survey
techniques. These interviews indicated a lack of a formal training program at the mill for the
Radiation Safety Technicians which has led to an inconsistency in the level of training.
Item 2. Documentation:
Survey Documentation:
The inspector reviewed release surveys for product dmms, ore trucks, intermodal containers, and
equipment to verify that they were complete and adequately covered all ofthe radiation safety
concems. Specifically, the inspector looked for completeness and the information that is needed to
properly document how the surveys are performed and the results ofthe surveys.
Deflciencies:
The release limits on the ore truck surveys were not the DOT release limits of 2,200 dpm/100 cm
Alpha and Beta and 0.5 mrem dose (49 CFR 172.443). This standard v^^as adopted by the Licensee
in response to interrogatories of the Mills RML renewal application and put into the revised
Radiation Protection Program in section 6.4.1 Restricted Release Standards dated September 14,
2009.
Sealed Sources Documentation:
The Mill maintains an inventory of sources for use in performing daily function checks on
radiological instrumentation used throughout the Mill site. The inspection included reviewing
records of these sources and verifying that the sources are securely stored at the Mill site. All of
the sealed sources in the Mill's inventory that are used for this purpose are exempt from leak
testing requirements due to their low activity (less than or equal to 100 |iCi for beta-gamma
emitting isotopes and less than or equal to 10 ^Ci for alpha emitting isotopes). The inventory of
source, isotopes and activities are listed in Appendix 2 of the Radiation Safety Manual. Sources are
stored in a small combination safe located in the Radiation Safety Office.
Deflciencies:
The Mill has acquired a new source that was not on the inventory list.
Shipping Documentation
The inspector reviewed the shipping papers for ore trucks and yellowcake shipments. The
inspector complied a list of information that was required on the shipping paperwork from 49 CFR
172.201 (a)(d)(e), 202(a) and 203(d). The shipping papers are to have the following information:
• : 2 of Pages ...
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• A Description of the material (i.e. UN#, Proper Shipping, Hazard Class and etc.)
(172.202 (a) «fe(b)).
• Physical and Chemical form of the material (172.203 (d)(2)).
• Radionuclides present (172.203 (d)(1)).
• Activity ofthe shipment. (172.203 (d)(3)).
• Emergency Phone number (172.201 (d)).
• Exclusive-use Shipment (172.203 (d)(9)).
• Shippers Certification (172.204).
The inspector then compared the reviewed paperwork to that list. The inspector al^o took copies
of the Uranium Yellowcake shipping paperwork back to the DRC office and consuljted with other
DRC personnel and identified other deficiencies that were not addressed at the closeout meeting.
The Licensee was informed of the additional deficiencies via email.
Deflciencies:
The Licensee incorrectly used an old Material Shipping Description.49CFR 172.202(a)(2) states: "
The proper shipping name prescribed for the material in Column (2)of the 49CFR 172.101 table."
Column 2 ofthe 49 CFR172.101 for UN-2919 Says "Radioactive material, low specpific activity
(LSA-I) non fissile or fissile excepted."
The Licensee failed to record the radionuclides of the U3O8 (Uranium yellowcake) shipments on
mulfiple shipping papers dated from Febmary 9, 2010 to July 16, 2010 as required by 49 CFR
172.203(d)(1).
The Licensee recorded the chemical form but failed to record the physical form (e.g. solid, liquid,
gas) of the U3O8 (Uranium yellowcake) shipments on mulfiple shipping papers dated from
February 9, 2010 to July 16, 2010 as required by 49 CFR 172.203(d)(1).
The Licensee did not record the Acfivity of the U3O8 (Uranium yellowcake) shipments on mulfiple
shipping papers as required by 49 CFR 172.203(d)(3); The Shipping papers reviewed were dated
from February 9, 2010 to July 2, 2010.
The Licensee did not indicate that the U3O8 (Uranium Yellowcake) shipments are exclusive use
shipments on multiple shipping papers dated from February 9, 2010 to July 2, 2010 as required by
49 CFR 172.203(d)(9).
Item 4. Mill Tour:
The inspector walked through the restricted area on a general site tour. The tour included the ore
pad, the ore receiving trailer, the new decon pad, the mill, and the tailings ponds.
Deflciencies:
None
Closeout Meeting
3 of Page 5
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Denison Mines: Dave Turk (RSO)
Ronnie Nieves (Radiation Coordinator)
Utah DRC: Ryan Johnson (Inspector)
Findings
Deficiencies were observed in seven areas during the inspection. The particular findings that were
observed by the inspector are set forth below:
1. The release limits on the ore truck surveys were not the DOT release limits of 2,200
dpm/100 cm^ Alpha and Beta and O.S mrem dose as required by 49 CFR 172.443.
2. The Mill has acquired a new source that was not on the source inventory list.
3. The Licensee incorrecfiy used an old Material Shipping Descripfion. 49CFR 172.202(a)(2)
states: " The proper shipping name prescribed for the material in Column (2)of the 49CFR
172.101 table." Column 2 ofthe 49 CFR172.101 for UN-2919 Says "Radioactive material,
low specific activity (LSA-I) non fissile or fissile excepted."
4. The Licensee failed to record the radionuclides of the U3O8 (Uranium yellowcake)
shipments on multiple shipping papers dated from Febmary 9, 2010 to July 16, 2010 as
required by 49 CFR 172.203(d)(1).
5. The Licensee recorded the chemical form on the shipping papers, but failed to record the
physical form (e.g. solid, liquid, gas) of the U3O8 (Uranium yellowcake) shipments on
multiple shipping papers dated from Febmary 9, 2010 to July 16, 2010 as required by 49
CFR 172.203(d)(2).
6. The Licensee failed to record the Acfivity of the U3O8 (Uranium yellowcake) shipments on
mulfiple shipping papers as required by 49 CFR 172.203(d)(3). The Shipping papers
reviewed were dated from February 9, 2010 to July 2, 2010.
7. The Licensee did not indicate that the U3O8 (Uranium Yellowcake) shipments are
"Exclusive Use" shipments on multiple shipping papers dated from February 9, 2010 to
July 2, 2010 as required by 49 CFR 172.203(d)(9).
The first three observations the DRC will use discretion and will treat them as recommendations at
this time to allow the Licensee fime to correct them. However, regarding the other four findings a
Nofice of Violafion, Severity Level IV with a proposed civil penalty has been issued in separate
document. R313-14-15(2)(b)(iii)(E) states "The civil penalty may be increased as much as 50%
where multiple examples of a particular violafion are idenfified during the inspecfion period." The
DRC will not pursue an increase of the civil penalty for these violafions at this time. Due to the
fact that this is the first fime the DRC has made these observafions.
Conclusions and Recommendations
The following are DRC recommendations regarding items for improvement:
1. Perform the proper release surveys and using the appropriate release criteria as described in
the revised Secfion 6.0 of the Mill's Radiafion Protection Program Dated September 14,
2009.
2. Update the source inventory list.
3. Update Material Shipping Descripfion on U30g (Uranium Yellowcake) shipments as
' 4 of Page 5
C:\DOCUME~l\R>4JOHN~I\LOCALS~I\Temp\GWViewer\Impection Report RADMOD-SSS^
required by 49CFR 172.202(a)(2) to the current descripfion in Column 2 of the 49
CFR172.101 for UN-2919 "Radioacfive material, low specific acfivity (LSA-I) non fissile
or fissile excepted."
Recommendation for Next Inspection
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately, and
2. Radiafion Technician Training.
3. Survey Documentation
4. Survey Procedures
5. Perform an independent survey on an Intermodal container
6. Perform an independent survey on Yellowcake drums
Prepared By:
7" (Print Name) (Date)
5 ofPage 5
C:\iXX;UME~l\RMJOHN~l\LOCALS~l\Temp\G'WViewerMnspection Report RADMOD-SSS-01 7-20-10 RJ2.dpc
David,
Page 1 of 1
2.
3.
I looked into the issues that we discussed in the close out meeting on July 21, 2010. I have Reviewed
copied paperwork that I brought back to the DRC office and researched U.S. DOT regulations. Additional
findings were observed. All ofthe finding found in this inspection are as follows with the additional findings
marked with a (*);
1. The release limits on the ore truck surveys were not the DOT release limits of 2,200 dpm/100
cm Alpha and Beta and 0.5 mrem dose (49 CFR 172.443). This standard was adopted by the
Licensee in response to interrogatories of the Mills RML renewal applicafion apd put into the
revised Radiafion Protection Program in secfion 6.4.1 Restricted Release Standards dated
September 14, 2009
The Mill has acquired a new source that was not on the source inventory list.
(*)The Licensee incorrecfiy used an old Material Shipping Description 49CFR 172.202(a)(2)
states: " The proper shipping name prescribed for the material in Column (2)of the 49CFR
172.101 table." Column 2 ofthe 49 CFR172.101 for UN-2919 Says "Radioactive material, low
specific activity (LSA-I) non fissile or fissile excepted."
(*)The Licensee failed to record the radionuclides of the U^Og (Uranium yello|vcake) shipments
on multiple shipping papers dated from February 9, 2010 to July 16, 2010 as required by 49 CFR
172.203(d)(1).
(*)The Licensee recorded the chemical form but failed to record the physical f^rm (e.g. solid,
liquid, gas) of the U^Og (Uranium yellowcake) shipments on multiple shipping papers dated
from February 9, 2010 to July 16, 2010 as required by 49 CFR 172.203(d)(2).
The Licensee did not record the Activity of the U^Og (Uranium yellowcake) shipments on
mulfiple shipping papers as required by 49 CFR 172.203(d)(3). The Shipping papers reviewed
were dated from February 9, 2010 to July 2, 2010.
The Licensee did not indicate that the U^Og (Uranium Yellowcake) shipments
Use" shipments on multiple shipping papers dated from February 9, 2010 to July 2, 2010 as
required by 49 CFR 172.203(d)(9).
5.
are "Exclusive
A Severity Level IV Nofice of Violafion has been recommended for items 4-7. Copibs of the NOV and
the Inspection report will be sent to you. If you have any quesfions please contact me at (435) 536-
4250 or at rmjohnson(a),utah.gbv.
Thank you for cooperation during this inspection.
Ryan Johnson, P.G.
Environmental Scientist/ Health Physicist
Utah Division of Radiafion Confrol
file://C:\Documents and Settings\Rmjohnson\Local Settings\Temp\XPgrpwise\4C592BF0E... 8/4/2010
Yes it is exclusive use.
Sent from my Verizon Wireless BlackBerry
Page 1 of 1
From: Ryan Johnson <[e-mail]>
Date: Tue, 3 Aug 2010 13:47:36 -0400
To: David Turk<[e-mail]>
Cc: John Hultquist<[e-mail]>
Subject: Follow-up on HP inspecfion conducted 7-20-10
David,
I wanted to confirm that the U308 (Uranium Yellowcake) shipments are sent from the Mill are sent as
"Exclusive Use" shipments.
Thank you
Ryan Johnson, P.G.
Environmental Scienfist/Health Physicist
Utah Division of Radiafion Control
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and any attached files with it are confidential and may contain
privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You m^y not use, distribute print or
copy this message if you are not the intended recipient(s).
David Turk
Radiation Safety Officer
1:435-678-2221 x113 | f: 435-678-2224
6425 8. Highviray 191, PO Box 809, Blanding, UT 84511
DENISON MINES (USA) CORP
www.denisonmines.com
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and any attached files writh it are cjnfidential and may contain
privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or
copy this message if you are not the intended recipient(s).
file://C:\Documents and Setfings\Rmjohnson\Local Setfings\Temp\XPgrpwise\4CS8062CE... 8/3/2010
Page 1 of 1
Ryan,
Thursday at 3:30pm or later works best for me. Should I call you at your office at that time?
Dave
David Frydenlund
Vice Piesident, Regulatory Affairs. Counsel and Corp
Secretary
t: [phone] | f: [phone]
1050 17th street. Suite 950, Denver, CO 80265
DENISON MINES (USA) CORP
www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s). This message and any attached files with it are confidential and may
contain privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute
print or copy this message if you are not the intended recipient(s).
From: Ryan Johnson [mailto:Rmjohnson(g)utah.gov]
Sent: IWonday, August 09, 2010 7:39 AM
To: David Frydenlund; David Turk
Cc: Jo Ann Tischler; John Hultquist
Subject: RE: Addendum to Close Out meeting for inspection on July 20,
Dave,
I am doing an inspection at another facility this week. I can be available any time between 3:30 to 6:00 p.m.
Tuesday, Wednesday or Thursday. What is best for you.
Ryan
file://C:\Documents and Setfings\Rmjohnson\Local Settings\Temp\XPgrpwise\4C6104A6... 8/12/2010
TS/V^
State ofUtah
GARY R, HERBERT
Govemor
GREG BELL
Lieutenant Govemor
)epartment of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
TO:
MEMORANDUM
File
THROUGH: John Hultquist
FROM: Ryan Johnson
DATE: August 10, 2010
SUBJECT: Shipping Paper NOV for Inspecfion conducted on July 20 & 21, 2010
On July 20 and 21, 2010, an inspecfion was conducted at Dension Mines White Mesa Mill by
Ryan Johnson. Results of the inspection were discussed with David Turk (Site Radiation Safety
Officer) and Ronnie Nieves at the conclusion of the inspection. Further finding were emailed to
David Turk and David Frydenlund on August 4, 2010.
Deficiencies were observed in seven areas during the inspection,
observed by the inspector are set forth below:
The particular findings that were
1. The release limits on the ore tmck surveys were not the DOT release limits of 2,200
dpm/100 cm^ Alpha and Beta and 0.5 mrem dose as required by 49 CFR 172.443^
2. The Mill has acquired a new source that was not on the source inventory list.
3. The Licensee incorrecfiy used an old Material Shipping Descripfion 49CFR 172.202(a)(2)
states: " The proper shipping name prescribed for the material in Column (2)of the 49CFR
172.101 table." Column 2 ofthe 49 CFR172.101 for UN-2919 Says "Radioacfive
material, low specific acfivity (LSA-I) non fissile or fiissile excepted."
4. The Licensee failed to record the radionuclides of the U3O8 (Uranium yellowcake)
shipments on multiple shipping papers dated from Febmary 9, 2010 to July 16, 2010 as
required by 49 CFR 172.203(d)(1).
5. The Licensee recorded the chemical form but failed to record the physical form (e.g. solid,
liquid, gas) of the U3O8 (Uranium yellowcake) shipments on mulfiple shipping papers
dated from Febmary 9, 2010 to July 16, 2010 as required by 49 CFR 172.203(d)(2).
6. The Licensee did not record the Acfivity of the U3O8 (Uranium yellowcake) shipments on
mulfiple shipping papers as required by 49 CFR 172.203(d)(3). The Shipping papers
reviewed were dated from Febmary 9, 2010 to July 2, 2010.
7. The Licensee did not indicate that the U3O8 (Uranium Yellowcake) shipments are
"Exclusive Use" shipments on mulfiple shipping papers dated from Febmary 9, 2010 to
July 2, 2010 as required by 49 CFR 172.203(d)(9).
195 North 1950 West • Salt Uke City, UT
Mailing Address: P O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 • T.D D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Page 2
The first three observations the DRC will use discretion and will treat them as recommendations
at this time to allow the Licensee time to correct them. However, the other four observations a
Notice of Violation Severity Level IV with a proposed civil penalty has been issued in separate
document. R313-14-15(2)(b)(iii)(E) states "The civil penalty may be increased as much as 50%
where multiple examples of a particular violation are idenfified during the inspection period."
The DRC will not pursue an increase of the civil penalty for these violations at this time. This is
based on this is the first time the DRC has made these observations.
Radiation Control Rule R313-19-100(S)(a) states: "Each licensee who transports licensed
material outside the site of usage, as specified in the license issued by the Executive Secretary, the
U.S. Nuclear Regulatory Commission or an Agreement State, or where transport is on public
highways, or who delivers licensed material to a carrier for transport, shall comply with the
applicable requirements of the U.S. Department of Transportafion regulafions in 49 CFR parts
107, 171 through 180, and 390 through 397 (2006), appropriate to the mode of transport." (i) "The
licensee shall particularly note DOT regulations in the following areas:" (E) "Shipping papers and
emergency informafion-49 CFR part 172: subparts C (49 CFR 172.200 through 49 CFR 172.205)
and G (49 CFR 172.600 through 49 CFR 172.606) (Also in 10CFR71.5)." Therefore the
Inspector is within his authority to review Denison Mines' Shipping Papers.
During the close out meefing conducted on July 21, 2010 the Denison Mines White Mesa Mill
RSO was under the impression that the DOT requirements that 1 cited did not come into effect
until later this year. After reviewing several Federal Registers the Inspector was able to determine
that these requirements came into effect on October 1, 2004.
. \ • ' ' ' • •
_ • , •- , y . . _
-/^» tp' •'^^ '."' — ...... ,.- . . f—— . —— L-^Q/^'"^— •—- • • •
Nuclear Regulatory Commission §71.8
must be filed with, or made to, the Di-
rector, Office of Nuclear Material Safe-
ty and Safeguards, U.S. Nuclear Regu-
latory Commission, Washington, DC
20555-0001.
[69 FR 3786, Jan, 26 . 2004;
29, 2004] FR 58038, Sept,
§ 71.6 Information collection require-
ments: OMB approval.
(a) The Nuclear Regulatory Commis-
sion has submitted the information
collection requirements contained in
this part to the Office of Management
and Budget (OMB) for approval as re-
quired by the Paperwork Reduction
Act (44 U.S.C. 3501 el seq.). The NRC
may not conduct or sponsor, and a per-
son is not required to respond to, a col-
lection of information unless it dis-
plays a currently valid OMB control
number. OMB has approved the Infor-
mation collection requirements con-
tained in this part under control num-
ber 3150-0008.
(b) The approved information collec-
tion requirements contained in this
part appear in §§71.5, -71.7, 71,9, 71.12,
71,17, 71,19, 71.20, 71.22, 71.23, 71.31, 71.33,
71,35, 71.37, 71.38, 71,39, 71.41, 71.47, 71.85,
71,87, 71,89, 71.91, 71.93, 71,95, 71,97,
71,101, 71,103, 71.105, 71,107, 71,109, 71,111,
71,113, 71.115, 71,117, 71,119, 71,121, 71,123,
71,125, 71.127, 71,129, 71,131, 71,133, 71,135,
71,137, and Appendix A, Paragraph II.
§ 71.7 Completeness and accuracy of information.
(a) Information provided to the Com-
mission by a licensee, certificate hold-
er, or an applicant for a license or CoC;
or information required by statute or
by the Commission's regulations, or-
ders, license or CoC conditions, to be
maintained by the licensee or certifi-
cate holder, must be complete and ac-
curate in all material respects.
(b) Each licensee, certificate holder,
or applicant for a license or CoC must
notify the Commission of information
identified by the licensee, certificate
holder, or applicant for a license or
CoC as having, for the regulated activ-
ity, a significant implication for public
health and safety or common defense
and security. A licensee, certificate
holder, or an applicant for a license or
CoC violates this paragraph only if the
licensee, certificate holder, or appli-
cant for a license or CoC fails to notify
the Commission of information that
the licensee, certificate holder, or ap-
plicant for a license or CoC has identi-
fied as having a significant implication
for public health and safety or common
defense and security. Notification must
be provided to the Administrator of the
appropriate Regional Offioe within 2
working days of identifying the infor-
mation. This requirement is not appli-
cable to information which is already
required to be provided to the Commis-
sion by other reporting or updating re-
quirements.
§71.8 Deliberate misconduct.
(a) This section applies to any—
(1) Licensee;
(2) Certificate holder;
(3) Quality assurance program ap-
proval holder;
(4) Applicant for a license, certifi-
cate, or quality assurance program ap-
proval;
(5) Contractor (including a supplier
or consultant) or subcontractor, to any
person identified in paragraph (a)(4) of
this section; or
(6) Employees of any person identi-
fied in paragraphs (a)(1) through (a)(5)
of this section,
(b) A person identified in paragraph
(a) of this section who knowingly pro-
vides to any entity, listed in para-
graphs (a)(1) through (a)(5) of this sec-
tion, any components, materials, or
other goods or services that relate to a
licensee's, certificate holder's, quality
assurance program approval holder's,
or applicant's activities subject to this
part may not:
(1) Engage in deliberate misconduct
that causes or would have caused, if
not detected, a licensee, certificate
holder, quality assurance program ap-
proval holder, or any applicant to be in
violation of any rule, regulation, or
order; or any term, condition or limita-
tion of any license, certificate, or ap-
proval issued by the Commission; or
(2) Deliberately submit to the NRC, a
licensee, a certificate holder, quality
assurance program approval holder, an
applicant for a license, certificate or
quality assurance program approval, or
a licensee's, applicant's, certificate
holder's, or quality assurance program
335
§71.5 10 CFR Ch. I (1-1-10 Edition)
(20 mlcrocuries/cm^) for beta and
gamma and low toxicity alpha
emitters, or 8 x 10'' Bq/cm^ (2 micro-
curies/cm^) for all other alpha
emitters.
Transport index (Tl) means the [
dimensionless number (rounded up to
the next tenth) placed on the label of a
package, to designate the degree of
control to be exercised by the carrier
during transportation. The transport
index is the number determined by
multiplying the maximum radiation
level in millisievert (mSv) per hour at
1 meter (3,3 ft) from the external sur-
face of the package by 100 (equivalent
to the maximum radiation level in
millirem per hour at 1 meter (3.3 ft)).
Type A quantity means a quantity of
radioactive material, the aggregate ra-
dioactivity of which does not exceed A,
for special form radioactive material,
or A2, for normal form radioactive ma-
terial, where Aj and A2 are given in
Table A-1 of this part, or may be deter-
mined by procedures described in Ap-
pendix A of this part.
Type B quantity means a quantity of
radioactive material greater than a
Type A quantity.
Unirradiated uranium means uranium
containing not more than 2 x 10^ Bq of
Plutonium per gram of uranium-235,
not more than 9 x 10« Bq of fission prod-
ucts per gram of uranium-235, and not
more than 5 x 10-3 g of uranium-236 per
gram of uranium-235,
Ur.qniurri—natural,-depleted,.enriched:
f(-l)--Natiiral-uranium-means-u'ranium
with the naturally occurring distribu-
tion of uranium isotopes (approxi-
mately 0,711 weight percent uranium-
235, and the remainder by weight essen-
tially uranium-238),
(2) Depleted uranium means uranium
containing less uranium-235 than the
naturally occurring distribution of ura-
nium isotopes.
(3) Enriched uranium means uranium
containing more uranium-235 than the
naturally occurring distribution of ura-
nium isotopes,
[69 FR 3786. Jan, 26 , 2004 ; 69 FR 58038, Sept,
29. 2004]
§'7lT5^t¥ianspdft'ati6h"of-ricerised-mate-rial.
(a )"• Each" 1 i censeje-wh^^traJispjSr 11-
censed''"materlal....6utslde-.the-^'slte-rof«
iisager:as-sp^plfleajin':toe-N
orj;wh'er?^ransport-is-onipubU
'-ways~oriwXQr^enWrs'iice :
Wpl5G£MDsr"for'Uaiisport, shalL coinply '
_jyith,the-applicable-requlrements of the
-DOT^-regulations-in''49-"- CF'R' parts 107,, ,
i;7Kthrough 180„and-390.through'397, ap-'i'
fpropriate to^the mode of-transport, *"
(1) The licensee shall particularly
note DOT regulations in the following
areas:
(1) Packaging—49 CFR part 173: sub-
parts A, B, and I.
(ii) Marking and labeling—49 CFR
part 172: subpart D; and §§172.400
through 172.407 and §§172.436 through
172.441 of subpart E.
(iii) Placarding—49 CFR part 172: sub-
part F, especially §§172,500 through
172,519 and 172.556; and appendices B
and C.
(iv) Accident reporting—49 CFR part
m:JfmA5^ndm.l6.
^v-).^^s5lSfiig7^peFs^^
[THformation-^9-eFR--paft'^"l7^-^
rcrand-CJT-"'
(vi) Hazardous material employee
training—49 CFR part 172: subpart H.
(vii) Security plans—49 CFR part 172:
subpart I.
(viii) Hazardous material shipper/car-
rier registration—49 CFR part 107: sub-
part G.
(2) The licensee shall also note DOT
regulations pertaining to the following
modes of transportation:
(1) Rail—49 CFR part 174: subparts A
through D and K,
(ii) Air—49 CFR part 175.
(iii) Vessel—49 CFR part 176: subparts
A through F and M,
(iv) PubUc Highway—49 CFR part 177
and parts 390 through 397,
(b) If DOT regulations are not appli-
cable to a shipment of licensed mate-
rial, the licensee shall conform to the
standards and requirements of the DOT
specified in paragraph (a) of this sec-
tion to the same extent as if the ship-
ment or transportation were subject to
DOT regulations, A request for modi-
fication, waiver, or exemption from
those requirements, and any notifica-
tion referred to in those requirements.
334
§172.101 49 CFR Ch. I (10-l<oOdition)7
o o
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< X
cnt:
is S
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CD O O
to « 52 -r cn > OJ
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^^^
CN CO CVJ CO - (N CNJ • CSJ CvJ - Tj- Tf TT
of CO - CN CN
Q. 5 ^ :
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OJ E rn Z
; to p a> 3-6 a to t o u o o
Ct) C
"to tu
(J to •>- o to -a: 0) CO : .2 c5 .o
in i O '-•s
S —-6 S —-o ,S _g -r _o = 2 1^
To ^ y ro W " ira
.-^ to o •
2 E T3 O ro ^
a:
242
785910 Federal Register/Vol^^ No. 250/Friday, December 29, 2006^^es and Regulations
DEPARTMENT OF TRANSPORTATION Contents
Pipeline and Hazardous Materials
Safety Administration
49 CFR Parts 171,172,173,175,176,
178 and 180
[Docket No. PHMSA-06-25476 (HM-2151)]
RIN 2137-AE16
Hazardous Materials: Harmonization
With the United Nations
Recommendations, International
Maritime Dangerous Goods Code, and
International Civil Aviation
Oganization's Technical Instructions
AGENCY: Pipeline and Hazardous
Materials Safety Administration
(PHMSA), DOT.
ACTION: Final rule.
SUMMARY: This final rule revises the
Hazardous Materials Regulations to
maintain alignment with international
standards by incorporating various
amendments, including changes to
proper shipping names, hazard classes,
packing groups, special provisions,
packaging authorizations, air transport
quantity limitations and vessel stowage
requirements. These revisions will
harmonize the Hazardous Materials
Regulations with certain recent changes
to the International Maritime Dangerous
Goods Code, the International Civil
Aviation Organization's Technical
Instructions for the Safe Transport of
Dangerous Goods by Air, and the United
Nations Recommendations on the
Transport of Dangerous Goods.
DATES -^iEffective^jitei^
Voluntary Compliance Date: PHMSA
is authorizing voluntary compliance
beginning January 1, 2007.
Delayed Compliance Date: Unless
otherwise specified, mandatory
compliance with the amendments
adopted in this final rule is required
beginning January 1, 2008.
Jncorporafjon by Reference Date: The
incorporation by reference of the
publications adopted in § 171.7 of this
final rule has been approved by the
Director of the Federal Register as of
January 1, 2007.
FOR FURTHER INFORMATION CONTACT:
Charles Betts, Office of Hazardous
Materials Standards, telephone (202)
366-8553, or Shane Kelley,
International Standards, telephone (202)
366-0656, Pipeline and Hazardous
Materials Safety Administration, U.S.
Department of Transportation, 400
Seventh Street, SW., Washington, DC
20590-0001,
SUPPLEMENTARY INFORMATION:
I. Background
II. Overview
A. Amendments Adopted in this Final
Rule
B. International Standards Not Being
Adopted in this Final Rule
III. Section-By-Section
IV. Regulatory Analyses and Notices
A. Statutory/Legal Authority for this
Rulemaking
B. Executive Order 12866 and DOT
Regulatory Policies and Procedures
C. Executive Order 13132
D. Executive Order 13175
E. Regulatory Flexibility Act, Executive
Order 13272, and DOT Procedures and
Policies
F. Paperwork Reduction Act
G. Regulatory Identifier Number (RIN)
H. Unfunded Mandates Reform Act
I. Environmental Assessment
J. Privacy Act
I. Background
By notice of proposed rulemaking
(NPRM) published August 31, 2006, the
Pipeline and Hazardous Materials Safety
Administration (PHMSA, we) published
proposed revisions to the hazard
communication, classification, and
packaging requirements of the
Hazardous Materials Regulations
(HMR), 49 CFR parts 171-180, to align
with updates and revisions to the
United Nations Recommendations on
the Transport of Dangerous Goods (UN
Recommendations), the International
Maritime Dangerous Goods (IMDG)
Code and the International Civil
Aviation Organization (ICAO) Technical
Instructions for the Transport of
Dangerous Goods by Air. The UN
Recommendations are amended and •
updated biennially by the UN
Committee of Experts on the Transport
of Dangerous Goods and on the Globally
Harmonized System of Classification
and Labeling of Chemicals and serve as
the basis for national, regional, and
international modal regulations,
including the IMDG Code, and the ICAO
Technical Instructions.
The harmonization of domestic and
international standards becomes
increasingly important as the volume of
hazardous materials transported in
intemational commerce grows.
Harmonization facilitates international
trade by minimizing the costs and other
burdens of complying with multiple or
inconsistent safety requirements for
transportation of hazardous materials to
and from the United States. By
facilitating compliance, harmonization
also tends to enhance safety for
international movements, but only if the
international standards themselves
provide an appropriate level of safety.
To that end, PHMSA actively
participates in the development of
intemational standards for the
transportation of hazardous materials,
frequently advocating the adoption in
international standards of particuleir
HMR requirements. When considering
the adoption of international standards
under the HMR, we review and consider
each amendment on its own merit. Each
amendment is considered on the basis
of its overall impact on transportation
safety and the economic implications
associated with its adoption into the
HMR. Our goal is to harmonize without
diminishing the level of safety currently
provided by the HMR and without
imposing undue burdens on the
regulated public.
To maintain alignment of the HMR
with international requirements, in this
final rule, we are incorporating changes
into the HMR based on the Fourteenth
revised edition of the UN
Recommendations and UN Manual of
Tests and Criteria, Amendment 33 to the
IMDG Code, and the 2007-2008 ICAO
Technical Instructions, which become
effective January 1, 2007. We are also
addressing petitions for rulemaking
concerning harmonization with
intemational standards and additional
measures to facilitate international
transportation.
The comment period for the proposed
rule closed on October 16, 2006.
PHMSA received 28 comments in
response to the proposed rulemaking.
The following individuals, companies
and organiza,tions submitted comments:
(1) Georgia Department of Public Safety
(GPS; PHMSA-06-25476-4);
(2) North American Transportation
Consultants (NATC; PHMSA-06-
25476-7);
(3) Lawrence Laude (Laude; PHMSA-
06-25476-8);
(4) United Parcel Service (UPS;
PHMSA-06-25476-9);
(5) Christopher L. Botteri (Botteri;
PHMSA-06-25476-10);
(6) Dennis Eisenhofer (Eisenhofer;
PHMSA-06-25476-11);
(7) HMT Associates (HMT; PHMSA-06-
25476-12);
(8) Phillip Adamo (Adamo; PHMSA-
06-25476-13);
(9) Institute of Makers of Explosives
(IME; PHMSA-06-25476-14);
(10) J & S Warehouse (J&S; PHMSA-06-
25476-17);
(11) Rising Star Transportation (RST;
PHMSA-06-25476-18);
(12) National Tank Truck Carriers
(NTTC; PHMSA-06-25476-19);
(13) Air Products and Chemicals (AP&C;
PHMSA-06-2 54 76-20);
(14) All Chemical Transport and Leasing
(AllChem; PHMSA-06-25476-21);
7860'2 Federal Register/Vol^^, No. 250/Friday, December 29, 2006^^Ies and Regulations
II or IU liquid absorbed into a solid
material are excepted from the HMR
provided there is no free liquid in the
packet or article.
• Special Provision 77 applies to use
of the Division 5.1 subsidiary risk label.
We are revising this special provision
for consistency with the wording in the
UN Recommendations. As a result,
Special Provision 77 will no longer
apply only to "domestic
transportation." Further, we are
clarifying that a Division 5.1 label is not
required for mixtures containing not
more than 23.5% oxygen by volume.
Also, the provision is assigned to the
entry "Compressed gas, n.o.s.,"
UN1956, which is the most appropriate
description for mixtures currently
described as "Carbon dioxide and
oxygen mixtures, compressed." In this
final rule, we are removing the enfry for
"Carbon dioxide and oxygen mixtiues,
compressed."
• Special Provision 146 is amended
to authorize the domestic classification
of a material as environmentally
hazardous if it is designated as such by
a foreign competent authority. The
provision as currently worded only
allows such classification for
international shipments. Due to current
differences in criteria for the
classification of environmentally
substances world-wide, we believe the
amended provision will afford
additional flexibility to industry and
reduce shipping costs by allowing both
domestic and international shipments to
be treated identically. Although
generally the HMR do not authorize
materials not meeting the definition of
a hazardous material to be transported
as regulated materials, due to the low
risk posed by these materials, and the
fact that the HMR already authorize
domestic movement in association with
international air and vessel transport,
we believe this change will not result in
a significant impact other than to lower
costs for our stakeholders.
• Special Provision 147 applies to
non-sensitized emulsions, suspensions
and gels consisting primarily of a
mixture of ammonium nitrate and fuel,
intended to produce a Type E blasting
explosive only after further processing
prior to use. In accordance with the UN
Recommendations, this special
provision is revised to specify the
composition of mixtures for suspensions
and gels and to specify these substances
be tested in accordance with Test Series
8 of the UN Manual of Tests and
Criteria.
• Special Provision 166 authorizes
non-friable, tablet form calcium
hypochlorite, dry or hydrated, to be
transported as a Packing Group III
material. In accordance with the UN
Recommendations, we are revising
Special Provision 166 to remove the
authorization for "hydrated" non-friable
tablet forms of calcium hypochlorite to
be transported as a PG III material.
• A new Special Provision 175 is
added to require stabilization for certain
substances when transported in
concentrations of not more than 99%.
• Special Provision 101 is removed.
This special provision required the
name of the particular substance or
article to be specified. With the
introduction of the letter "G" in Column
(1), which requires the n.o.s. and
generic proper shipping names to be
supplemented with the technical name
ofthe hazardous material, Special
Provision 101 became obsolete.
• A new Special Provision A105 is
added to specify the quantity of
hazardous materials allowed in
equipment or apparatus.
Section 172.202
rShippirig^DescriptioirSequence-r^
Section a72:2^2'establishes
requirements for shipping descriptions
on shipping papers. Currently, the basic
description of a hazardous material
consists of the proper shipping name,
hazard class, ID number and packing
group, in that order. The HMR also
authorize an alternative description
sequence, which lists the identification
number first, followed by the proper
shipping name, hazard class, and
packing group. Bjeginriingljaffiwy^
200 7,4hejlternative_~sKipping"~"" 1
^jiescription.sjBquence will b
(C)n^sKipping'documents prepafedTn^
"accbrdance with-the lCAO Techiiical
Instmctions and the IMDG Code. In the
NPRM, we proposed to adopt the
current, alternative shipping description
sequence as the mandatory basic
description of a hazardous material on
a shipping paper. We also proposed a
two-year transition period to allow
offerors adequate time to convert to the
new shipping description sequence.
A total of 19 commenters addressed
this proposal. Eight commenters INPCA,
AP&C, ATA, GPS, LabCorp, NTTC, UPS,
and VHOMA] support the proposal.
NPCA notes that many of its members
have already implemented this change
to simplify internal shipping processes.
Eleven commenters [Adamo;
AllChem; Botteri; Eisenhofer; ISSA, J&S;
NACD; NATC; RST; and two
unidentified commenters] oppose this
proposal, suggesting that the change is
not necessary, lacks an economic
justification, and will have a negative
impact on safety. These commenters
note that, because the current
regulations allow the international
sequence as an alternative, the proposed
change merely removes the existing
sequence with no positive safety
rationale. These commenters further
assert that the proposed change could
result in significant cost impacts to
companies that utilize computer
systems for the preparation of shipping
documents and to frack associated
packaging and training requirements.
According to these commenters,
potential costs could include database
reorganization, employee training, and
related revisions to product labels that
also include shipping information.
Commenters suggest that costs could
also result from confusion on the part of
enforcement and inspection personnel
that could lengthen inspections and
delay shipments. These commenters are
also concerned that the proposed
revision could have a negative impact
on safety because it could result in
confusion for emergency response
personnel, most of whom eue volunteers
and receive limited training,
Commenters note that confusing
emergency response information could
expose emergency responders to
unnecessary danger,
PHMSA does not believe this
proposal is unnecessary or will
adversely impact transportation safety.
A uniform system for describing and
identifying hazardous materials on
shipping papers, as proposed in this
NPRM, will increase safety by helping
to eliminate potential indecision and
confusion during emergency situations.
For example, when incidents occur
during transportation, it is crucial to
promptly identify packages of
hazardous materials present in a given
shipment. Emergency responders at the
scene of an incident would use a
standard description of hazardous
materials on shipping papers to quickly
determine that they have accounted for
all hazardous materials in both
domestically- and internationally-bound
packages. In addition, following the
release of a hazardous material, it is
vital for emergency responders to
quickly identify the hazardous materials
to facilitate their emergency response
decision-making. A standardized
shipping description for both domestic
and international shipments will aid in
this process and will lead to a potential
reduction in the loss of life and
property.
PHMSA analyzes potential cost
impacts of proposed regulations on the
regulated community. Our justification
regarding this proposal in the
Regulatory Evaluation is located under
the Docket Management System [http://
dms.dot.gov). In the Regulatory
Federal Register/Vo^^, No. 250/Friday, December 29, 200(^^les and Regulations 78603
Evaluation, we determined that this
NPRM, including this specific proposal,
shoidd result in cost savings by easing
the regulatory compliance burden for
shippers and carriers engaged in
international commerce, including
trans-border shipments within North
America. In addition, shippers and
carriers will not need to revise shipping
papers to address differing domestic and
international requirements for shipping
descriptions. We acknowledge the
proposal to require one basic
description of a hazardous material on
a shipping paper will necessitate
additional training and software
revisions. However, to allow for the
training of hazmat employees and to
ease the minimal burden on entities
affected by the adoption ofthe proposed
amendments, we are authorizing an
extended transition period. An extended
transition period will allow businesses
to incorporate this requirement into
their training material for both new and
current hazardous materials employees,
and to upgrade system software over the
course of normal computer upgrades
and revisions with a minimal economic
impact.
The NPRM proposed a two-year
transition period to allow shippers
sufficient time to convert to the new
shipping description sequence. Three
commenters [NTTC, ATA, and VOHMA]
suggest the proposed transition period is
unnecessary and recommend a one-year
transition. These commenters state that
the industry is able to alter current
software systems and deplete pre-
printed shipping paper inventory within
a relatively short time period. VOHMA
asserts lengthy transition periods create
confusion and increased training
burdens. Six commenters [ATA; GPS;
LabCorp; NTTC; UPS; VOHMAl state
that the proposed transition period is
too short, recommending up to six years
to permit shippers to convert to the new
sequence. These commenters suggest a
longer transition period would allow the
new shipping sequence to be
incorporated into responder training
programs and the next revision of the
Emergency Response Guidebook (ERG).
The ERG lists hazardous materials in
numerical order of ID number and in
alphabetical order of material name.
We understand commenters' concerns
regarding the length of the transition
period for this proposal. However, it is
our intention to specify a imiform
method to describe a hazardous material
on a shipping paper in order to promote
the universal recognition of hazardous
materials, while allowing sufficient time
for affected parties to properly train
personnel, reconfigure internal
computer systems, and deplete existing
Re-
stock. We do not believe a time period
less than six years would allow
businesses to adequately accomplish
these objectives. Moreover, a six-year
transition period would allow for the
incorporation of this requirement into
the initial and recurrent training cycle
for hazardous materials employees and
emergency responders.
Therefore, for the reasons described
above, in this final rule, we are adopting
the requirement that the shipping
description of a hazardous material be
indicated on a shipping paper in the
following manner: Identification (ID)
number listed first, followed by the
proper shipping name, hazard class, and
packing group._In addition, we are
i;^autEpnzing.a-six-year_tr^^
Quantity Limitations
The description of a hazardous
material on a shipping paper must
include the total quantity of hazardous
material (by mass or volume) covered by
the description (see § 172.202(a)(5)). The
majority of quantity limitations set forth
for transportation by aircraft, in
Columns (9A) and (9B), are "net"
quantities. Section 175.75 limits the
quantity of hazardous materials,
expressed in net mass, aboard an
aircraft. To facilitate compliance with
the aircraft operator's requirements, in
the NPRM we proposed that, for
transportation by aircraft, the total
qucUitity per package be shown,
expressed as net mass, except as
otherwise specified. For example:
UN1263, Paint, 3, PG II, 5 fiberboard
boxes X 5 L each
As proposed, different size packages
containing different quantities of the
same hazardous material must be clearly
identified. For example:
UN1263, Paint, 3, PG II, 5 fiberboard
boxes X 5 L, 6 fiberboard boxes x 10 L
As proposed, where the letter "G"
follows the quantity in Column (9A) or
(9B), the gross mass rather than the net
quantity must be indicated.
A commenter [DGAC] opposes the
proposal to require the quantity of a
hazardous materials shipment by
aircraft to be expressed as a net quantity
per package. The commenter questions
the safety benefit of adopting the
requirement and states that the costs to
industry associated with the change,
such as computer software upgrades,
may be substantial. The commenter did
not provide data to support this
argument. We disagree that there is no
safety benefit in expressing the quantity
of hazardous material in terms of "net
quantity" for air shipments. Quantity
limitations aboard aircraft, as prescribed
in § 175.75, are specified in the HMR as
net quantities; thus, an indication of the
net quantity per package on shipping
papers facilitates load planning and
compliance. We do not believe the cost
of indicating net quantity rather than
total quantity, as previously required, is
increased substantially. Therefore, in
this final rule, we are adopting the
amendment as proposed.
In the NPRM, we also proposed the
following additional requirements:
—For empty uncleaned packaging, only
the number and type of packaging
must be shown;
—For chemical kits and first aid kits,
the total net mass of hazardous
materials must be shown. Where a kit
contains solids and/or liquids, the net
mass of liquids within the kit is to be
calculated on a 1 to 1 basis, i.e., 1 liter
equals 1 kilogram;
—For dangerous goods in machinery or
'3 apparatus, the individual total
quantities of dangerous goods in
solid, liquid or gaseous state,
contained in the article must be
shown;
—For dangerous goods transported in a
salvage packaging, an estimate of the
quantity of dangerous goods per
package must be shown;
—For cylinders, the total quantity may
be indicated by the number of
cylinders, for example, "10
cylinders;"^
—For items where "No Limit" is shown
in Column (9A) or (9B) ofthe HMT,
the quantity shown should be the net
mass or volume of the material,
except for UN2800, UN2807, UN3072,
UN3166 and UN3173, where the
quantity should be the gross mass of
the article.
On the proposal to identify the total
quantity of each hazardous material in
machinery or apparatus, a commenter
[UPS] states that the "precision implied
in this proposal is unrealistic." UPS
suggests that, absent a precise quantity,
a shipper should be permitted to
estimate the quantity of hazardous
material. We agree and are amending
paragraph (a)(6)(iii) accordingly.
Another commenter [Laude] requests
we include net quantity provisions for
Class 7 materials transported by aircraft.
Similar provisions for transportation by
other modes are contained in paragraph
(a)(5). We agree with the commenter and
are amending paragraph (a)(6)
accordingly.
The same commenter points out that
in proposed paragraph (a)(6)(vi) ID
numbers UN2807 and UN3173 do not
exist in the HMT; (ID number UN2807
is assigned to "magnetized material" in
the ICAO Technical Instructions). We
are removing UN2807 and UN3173 in
this final rule.
7862^6 Federal Register/Vc!^^, No. 250/Friday, December 29, 200^^1es and Regulations
• 6. In Appendix B to § 172.101, the List
of Marine Pollutants, the entry "Copper
chloride" is amended by adding the
designation "PP" in Column (1) and the
entries "Alcohol C-13—C-15 poly (1-6)
ethoxylate" and "1,2-Dichlorobenzene"
are removed.
• 7. In § 172.102, paragraph (c)(1).
Special Provisions 15, 47, 77, 146, 147,
and 166 are revised; new Special
Provision 175 is added; Special
Provision 101 is removed; and in
paragraph (c)(2), new Special Provision
A105 is added.
The revisions and additions read as
follows:
§172.102 Special provisions.
*****
(c) * * *
(1) * * *
Code/Special Provisions
*****
15 This entry applies to "Chemical
kits" and "First aid kits" containing one
or more compatible items of hazardous
materials in boxes, cases, etc. that, for
example, are used for medical,
analytical, diagnostic, testing, or repair
purposes. For transportation by aircraft,
materials forbidden for transportation
by passenger aircraft or cargo aircraft
may not be included in the kits.
Chemical kits and first aid kits are
excepted from the specification
packaging requirements of this
subchapter when packaged in
combination packagings. Chemical kits
and first aid kits are also excepted from
the labeling and placarding
requirements of this subchapter, except
when offered for transportation or
transported by air. Chemical and first
aid kits may be transported in
accordance with the consumer
commodity and ORM exceptions in
§ 173.156, provided they meet all
required conditions. Kits that are carried
on board transport vehicles for first aid
or operating purposes are not subject to
the requirements of this subchapter.
*****
47 Mixtures of solids that are not
subject to this subchapter and
flammable liquids may be transported
under this entry without first applying
the classification criteria of Division 4.1,
provided there is no free liquid visible
at the time the material is loaded or at
the time the packaging or transport unit
is closed. Except when the liquids are
fully absorbed in solid material
contained in sealed bags, each
packaging must correspond to a design
type that has passed a leakproofness test
at the Packing Group II level. Small
inner packagings consisting of sealed
packets and articles containing less than
10 mL of a Class 3 liquid in Packing
Group II or III absorbed onto a solid
material are not subject to this
subchapter provided there is no free
liquid in the packet or article.
*****
77 Mixtures containing not more
than 23.5% oxygen by volume may be
transported under this entry when no
other oxidizing gases are present. A
Division 5.1 subsidiary risk label is not
required if this special provision
applies.
*****
146 This description may be used
for a material that poses a hazard to the
environment but does not meet the
definition for a hazardous waste or a
hazardous substance, as defined in
§ 171.8 of this subchapter, or any hazard
class, as defined in part 173 of this
subchapter, if it is designated as
environmentally hazardous by another
Competent Authority. This provision
may be used for both domestic and
international shipments.
147 This entry applies to non-
sensitized emulsions, suspensions, and
gels consisting primarily of a mixture of
ammonium nitrate and fuel, intended to
produce a Type E blasting explosive
only after further processing prior to
use. The mixture for emulsions typically
has the following composition: 60-85%
ammonium nitrate; 5-30% water; 2-8%
fuel; 0.5-4% emulsifier or thickening
agent; 0-10% soluble flame
suppressants; and trace additives. Other
inorganic nitrate salts may replace part
of the ammonium nitrate. The mixture
for suspensions and gels typically has
the following composition: 60-85%
ammonium nitrate; 0-5% sodium or
potassium perchlorate; 0—17%
hexamine nitrate or monomethylamine
nitrate; 5-30% water; 2-15% fuel; 0,5-
4% thickening agent; 0-10% soluble
flame suppressants; and trace additives.
Other inorganic nitrate salts may replace
part of the ammonium nitrate. These
substances must satisfactorily pass Test
Series 8 of the UN Manual of Tests and
Criteria, Part I, Section 18 (IBR, see
§ 171,7 of this subchapter), and may not
be classified and transported unless
approved by the Associate
Administrator,
*****
166 When transported in non-friable
tablet form, calcium hypochlorite, dry.
may be transported as a Packing Group
III material,
*****
175 This substance must be
stabilized when in concentrations of not
more than 99%.
(2) * * *
Code/Special Provisions
* * * * *
A105 The total net quantity of
dangerous goods contained in one
package, excluding magnetic material,
must not exceed the following:
a. 1 kg (2.2 pounds) in the case of
solids;
b. 0.5 L (0.1 gallons) in the case of
liquids;
c. 0.5 kg (1.1 pounds) in the case of
Division 2.2 gases; or
d. any combination thereof.
• 8. In § 172.202,,paragraphs (a) and (b)
are revised to read as follows:
§ 172.202 Description of hazardous
material shipping papers.
(a) The shipping description of a
hazardous material on the shipping
paper must include:
(1) The identification number
prescribed for the material as shown in
Column (4) ofthe § 172.101 table;
(2) The proper shipping name
prescribed for the material in Column
(2) ofthe §172.101 table;
(3) The hazard class or division
number prescribed for the material, as
shovm in Column (3) of the § 172.101
table. Except for combustible liquids,
the subsidiary hazard class(es) or
subsidiary division number(s) must be
entered in parentheses immediately
following the primary hazard class or
division number. In addition—
(i) The words "Class" or "Division"
may be included preceding the primary
and subsidiary hazard class or division
numbers.
(ii) The hazard class need not be
included for the entry "Combustible
liquid, n.o.s."
(iii) For domestic shipments, primary
and subsidiary hazard class or division
names may be entered following the
numerical hazard class or division, or
following the basic description.
(4) The packing group in Roman
numerals, as designated for the
hazardous material in Column (5) of the
§ 172.101 table. Class 1 (explosives)
materials, self-reactive substances,
organic peroxides and entries that are
not assigned a packing group are
excepted from this requirement. The
packing group may be preceded by the
letters "PG" (for example, "PG II"); and
(5) Except for transportation by
aircraft, the total quantity of hazardous
materials covered by the description
must be indicated (by mass or volume,
or by activity for Class 7 materials) and
must include an indication ofthe
applicable unit of measurement. For
example, "200 kg" or "50 L." The
following provisions also apply:
Federal Register/V No. 250/Friday, December 29, 200^Kiles and Regulations 78627
(i) For Class 1 materials, the quantity
must be the net explosive mass. For an
explosive that is an article, such as
Cartridges, small arms, the net explosive
mass may be expressed in terms of the
net mass of either the article or the
explosive materials contained in the
article.
(ii) For hazardous materials in salvage
packaging, an estimate of the total
quantity is acceptable.
(iii) The following are excepted from
the requirements of paragraph (a)(5) of
this section:
(A) Bulk packages, provided some
indication of the total quantity is
shown, for example, "1 cargo tank" or
"2 IBCs."
(B) Cylinders, provided some
indication of the total quantity is
shown, for example, "10 cylinders."
(C) Packages containing only residue.
(6) For transportation by aircraft, the
total net mass per package, must be
shown unless a gross mass is indicated
in Columns (9A) or (9B) of the § 172.101
table in which case the total gross mass
per package must be shown; or, for Class
7 materials, the quantity of radioactive
material must be shown by activity. The
following provisions also apply:
(i) For empty uncleaned packaging,
only the number and type of packaging
must be shown;
(ii) For chemical kits and first aid kits,
the total net mass of hazardous
materials must be shown. Where the kits
contain solids and/or liquids, the net
mass of liquids within the kits is to be
calculated on a 1 to 1 basis, i.e., 1 L
equals 1 kg;
(iii) For dangerous goods in
machinery or apparatus, the individual
total quantities or an estimate ofthe
individual total quantities of dangerous
goods in solid, liquid or gaseous state,
contained in the article must be shown;
(iv) For dangerous goods transported
in a salvage packaging, an estimate of
the quantity of dangerous goods per
package must be shown;
(v) For cylinders, total quantity may
be indicated by the number of cylinders,
for example, "10 cylinders;"
(vi) For items where "No Limit" is
shown in Column (9A) or (9B) of the
§ 172.101 table, the quantity shovra
should be the net mass or volume of the
material, except for UN2800, UN3072,
and UN3166 where the quantity should
be the gross mass of the article; and
(7) The number and type of packages
must be indicated. The type of packages
must be indicated by description ofthe
package (for example, "12 drums").
Indication of the packaging specification
number ("IHI") may be included in the
description of the package (for example,
"12 IHl drums" or "12 drums (UN
lAl)"). Abbreviations may be used for
indicating packaging types (for example,
"cyl." for "cylinder") provided the
abbreviations are commonly accepted
and recognizably
liquid hazardous materials, single
packaging fitted with vents, or open
cryogenic receptacle intended for the
fransport of refrigerated liquefied gases
must be:
(1) * * *
(2) Legibly marked with package
orientation markings that are similar to
the illusfration shown in this paragraph,
on two opposite vertical sides of the
package with the arrows pointing in the
correct upright direction. The arrows
must be either black or red on white or
other suitable contrasting background
and commensurate with the size of the
package. Depicting a rectangular border
around the arrows is optional.
*****
(c) * * *
(7) Class 7 radioactive material in
Type A, IP-2, IP-3, Type B(U), or Type
B(M) packages.
• 10. In § 172.407, paragraph (d)(2)(i) is
amended by removing "; and" at the
end of the paragraph and adding a
(b)'Except as provided in this subpart',";) period in its place, and paragraph
>rhe basic description specified in r~-' (d)(2)(iii) is added to read as follows:
.paragraphs (a)(1), (2), (3) and (4) of this ~7
i section must be shown in sequence with'~j§ 172.407 Label specifications,
no additional information interspersed. / * * * * *
^For example, "UN2744, Cyclobutyl
chloroformate, 6.1, (8, 3), PG IL"
* —** * - • —* _ _ J
• 9. In § 172.312, paragraphs (a)
introductory text, and (a)(2)
introductory text are revised and a new
paragraph (c)(7) is added to read as
follows:
§ 172.312 Liquid hazardous materials in
non-bulk packaging.
(a) Except as provided in this section,
each non-bulk combination package
having inner packagings containing
(d) * * *
(2) * * *
(iii) White may be used for the symbol
for the ORGANIC PEROXIDE label.
• 11. Section 172.427 is revised to read
as follows:
§ 172.427 ORGANIC PEROXIDE label.
(a) Except for size and color, the
ORGANIC PEROXIDE label must be as
follows:
§172.202 49 CFR Ch. I (10-l-07_Editioh)
and must include an indication of the
applicable unit of measurement. For
example. "200 kg" or "50 L." The fol-
lowing provisions also apply:
(i) For Class 1 materials, the quan-
tity must be the net explosive mass.
For an explosive that is an article,
such as Cartridges, small arms, the net
explosive mass may be expressed in
terms of the net mass of either the ar-
ticle or the explosive materials con-
tained in the article.
(li) For hazardous materials in sal-
vage packaging, an estimate of the
total quantity is acceptable.
(iil) The following are excepted from
the requirements of paragraph (a)(5) of
this section;
(A) Bulk packages, provided some in-
dication of the total quantity is shown,
for example, "1 cargo tank " or "2
IBCs."
(B) Cylinders, provided some indica-
tion of the total quantity is shown, for
example, "10 cylinders."
(C) Packages containing only residue.
(6) For transportation by aircraft.
the total net mass per package, must
be shown unless a gross mass is indi-
cated in Columns (9A) or (98) of the
§172,101 table in which case the total
gross mass per package must be shown;
or, for Class 7 materials, the quantity
of radioactive material must be shown
by activity. The following provisions
also apply:
(i) For empty uncleaned packaging,
only the number and type of packaging
must be shown;
(ii) For chemical kits and first aid
kits, the total net mass of hazardous
materials must be shown. Where the
kits contain solids and/or liquids, the
net mass of liquids within the kits is to
be calculated on a 1 to 1 basis, i.e., 1 L
equals 1 kg;
(iii) For dangerous goods in machin-
ery or apparatus, the individual total
quantities or an estimate of the indi-
vidual total quantities of dangerous
goods in solid, liquid or gaseous state,
contained in the article must be shown:
(iv) For dangerous goods transported
in a salvage packaging, an estimate of
the quantity of dangerous goods per
package must be shown;
(v) For cylinders, total quantity* may
be indicated by the number of cyl-
inders, for example, '10 cylinders; "
(vl) For items where "No Limit" is
shown in Column (9A) or (9B) of the
§172.101 table, the quantity shown
should be the net mass or volume of
the material, except for UN2800,
UN2807, UN3072. UN3166 and UN3171
where the quantity should be the gross
mass of the article; and
(7) The number and type of packages
must be indicated. The type of pack-
ages must be indicated by description
of the package (for example. "12
drums"). Indication of the packaging
specification number ("11-11") may be
included in the description ofthe pack-
age (for example, "12 IHl drums" or "12
drums (UN lAl)"). Abbreviations may
be used for indicating packaging types
(for example, "cyl," for "cylinder")
provided the abbreviations are com-
monly accepted and recognizable.
(b) Except as provided in this sub-
part, the basic description specified in
paragraphs (a)(1), (2), (3) and (4) of this
section must be shown in sequence
with no additional information inter-
spersed, _ _For example, i"UN27447
Cyclobutyl chloroformate,_6.i, (8,_ 3),
'PG II," J ~
"(c)'The total quantity of the material
covered by one description must appear
before or after, or both before and
after, the description required and au-
thorized by this subpart. The type of
packaging and destination marks may
be entered in any appropriate manner
before or after the basic description.
Abbreviations may be used to express
units of measurement and types of
packagings.
(d) Technical and chemical group
names may be entered in parentheses
between the proper shipping name and
hazard class or following the basic de-
scription. An appropriate modifier,
such as 'contains" or "containing."
and/or the percentage of the technical
constituent may also be used. For ex-
ample: "Flammable liquids. n,o,s, (con-
tains Xylene and Benzene). 3. UN 1993,
11".
(e) Except for those materials in the
UN Recommendations, the ICAO Tech-
nical Instructions, or the IMDG Code
(IBR, see §171.7 of this subchapter), a
material that is not a hazardous mate-
rial according to this subchapter may
not be offered for transportation or
transported when its description on a
356
Research and Special Programs Admin., DOT §172.101
£S r: "^
CO •^ CM CJ CO CJ CO
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251
I
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252
Research and Special Programs Admin., DOT §172.101
•^co'^co'^co'^'co
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253
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-SSS-01
SURVEYS/SHIPPING PAPERS/SOURCES
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTI900479
References: Radioactive Material License UTI 900479, License Renewal Application dated February 28,
2007, Radiation Protection Manual, Section 5, 10CFR20, NRC Regulatory Guide 8.30, NRC Regulatory
Guide 8.31, Utah Administrative Code R313-15.
DATE ZJO •' /'^
OPENING MEETING
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
U:\rad\COMMON\Uranium millsM Ie(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspeclion modules\2010\Inspection Modules\RADMOD-
SSS-02 rev 1 ,doc
•
DISCUSSION
SITE STAFF COMMENTS
RELEASE SURVEYS for Product Drums, Intermodals and Ore Trucks
Radiation Protection Manual Section 2.6 Equipment Release Surveys and 2.7 Product Shipment Surveys
(Appendix E 2007 license renewal)
1. Observe the RSO or designee perform a release survey on the filled product drums. Describe what
they did.
Comments: j
U:\rad\COMMON\Uranium mills\lle(2)UTl 900479 Denison Mines - White Mesa UMill\HP Inspection modules\20IO\lnspection Modules\RADMOD-
SSS-02 rev l.doc
Po.... -I ^r A
2. Observe the RSO or designee perform an unrestricted release survey on the Intermodals. Describe
what they did.
Comments:
3. Observe the RSO or designee perform a DOT Empty release survey on the Intermodals. Describe
what they did.
Comments:
4. Observe the RSO or designee perform a release survey on an Ore Truck. Describe what they did.
Cmnments:
6>£^'>^ ^ s-^-^^ ^- j^ ^ //^ 5 r^'"^^
5. Perform an independent Survey on each of the above items and describe how you did your survey
and document the results.
Comments: (Product Drums) ^
Comments: (Unrestricted Intermodal)
Comments: (DOT Empty Intermo^l)
U;\rad\C0MM0N\Uranium millsM Ie(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2010\Inspection Modules\RADMOD-
SSS-02 rev 1 doc
Comments: (Ore Truck)
6. Was a survey (dose rate measurement) taken of the transport vehicle interior surfaces?
1. How did the RSO or designee document their surveys?
Comments:
8. Review the release surveys for the past year.
Comments: • , ^
/4i//£^iA O//^ ^7^^^ jZrr^< T^i^^^^JU. <^^JL^< f ^'^P^
SHIPPING PAPERS, LABELING AND PACKAGING
9. Observe an Ore Truck(s). Describe how they are labeled/placard. (49 CFR 172)
Comnients:
10. Observe Yellowcake drums how are they labeled. (49 CFR 172)
Comments: ^
'^-n. .
U:\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - While Mesa UMill\HP Inspection modules\2010\Inspection Modules\RADMOD-
SSS-02rev l.doc
11. Observe Yellowcake shipment truck how is it placard. (49 CFR 172)
Comments:
12. Review Shipping papers on ore shipments. (49 CFR 172)
Date on shipping paper
Description
(UN#, Proper shipping
name, hazard class) r Physical and/or
Chemical form
Radionuclide
Activity
Class
Emergency phone #
Exclusive shipment
(Y/N)
Certified
Comments ^uiiniicms. / J
O^s .XAL
13. Review Shipping papers on yellowcake shipments. (49 CFR 172)
Date on shipping paper f-f^-fC
Descripfion
(UN#, Proper shipping
name, hazard class)
Physical and/or
Chemical form /.^
Radionuclide % $
Activity /C/o /Uo /UD J\)0
Class %h
Emergency phone # %> /-^
Exclusive shipment
(Y/N) ,Jd /U}
r—
AJO AJo M /iJo
1
Certified '7V>
Comments:
Vrw^ <rJ^ y^rJ. /^C7JJL.JL ^'5 ^JF /c^ ri-jT^.y .^,7^ ^^
U:\rad\COMMON\Uranium milIsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2010\hispection Modules\RADMOD-
SSS-02 rev 1 .doc
Pono ^ of 1 H
SOURCE CHECKS. INVENTORY AND SECURITY
Radiafion Protecfion Manual Section 3.0 Equipment/Calibration (Appendix E 2007 license renewal)
14. Observe the RSO or designee perform an Instrument Source Check. Describe what they did.
Comments:
15. How do they document their source Inventory
Comments: .
16. Where are the sources kept?
17. Any new source received?
Comments:
18. Any source disposed of?
Comments:
19. Were leak tests performed on the sources?
Comments: y
Jb^^ /^r^X. >o.^^^ ^ \
U:\rad\COMMON\Uranium millsM le(2)UTI900479 Denison Mines - White Mesa UMill\HP Inspection modules'\201 OMnspection Modules\RADMOD-
SSS-02 rev l.doc
Por,o <; of 1 /I
Release Limits
Alpha (Unrestricted and Product)
Beta-Gamma (Unrestricted Only)
Ore Trucks (Sole Use Transport)
49CFR173.443(d)
Average
Maximum
Removable
Average
Maximum
Intemal Surfaces: 10 mKfbi y contact 2 mR/hr y at 1 meter
Extemal Surfaces: 2|2,00^dpm/100cm2 a Removable
5,000 dpm/cm2
15,000 dpm/cm2
1,000 dpm/cm2
0.2 mr/hr or 5,000 dpm/cm2
1.0 mr/hr or 15,000 dpm/cm2
49CFR173.443(d)(l) states: A survey of the interior surfaces of the empty vehicle shows that the
radiation dose rate at any point does not exceed 0.1 mSv per hour (10 mrem per hour) at the surface or
0.02 mSv per hour (2mrem per hour) at 1 m (3 feet) from the surface.
U;\rad\COMMON\Uranium millsM I e(2)UTl 900479 Denison Mines - White Mesa UMill\HP Inspection modules\2010\hispection Modules\RADMOD-
SSS-02 rev 1 .doc
Reciprocity for Gauge User for the 4B Cell Construction
DIVISION OF RADIATION CONTROL
INSPECTION FORM
License Geosyntec Consultants License #: No. 5339-37
State of Califomia
Licensee
Address
10875 Rancho Bemardo Rd. Ste 200
San Diego, Califomia 92127
Last Amendment # Licensee
Address
10875 Rancho Bemardo Rd. Ste 200
San Diego, Califomia 92127
Date of Amendment
Inspection
At
Denison Mines
White Mesa Mill
License Expiration
Date
Inspection
At
Denison Mines
White Mesa Mill
Inspection Date 7-2^- /o
Licensee
Contact:
Closeout Date
Telephone
Number
Previous Inspecfion
Inspecfion Priority: I II III IV V For Previous & Present Findings - See
Compliance History
Type of
Inspection
(Circle
Appropriate
Types)
Roufine
Or
Initial
^^^^^^inounced
Or
Announced
jyiodules
'Used IP 87124
Persons Contacted
(Name & Title)
/9y
-n (#)Present at Entrance
Violafions: Yes
Inspector:
No
(+)lnten>iewed
Approyed:
Present at Close-out
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 OMnspection Modules\RADMOD-
SSS-02 rev 1 .doc
Poo» e of I /I
)
DIVISION OF RADIATION CONTROL
INSPECTION FORM
Security and Control of Licensed Material ^
Are entrances to facilifies, buildings^RAM use and storage areas secure? c^S'xV A-^^^t-
f^'yT^/C^i^ ^p-t- /^S-y- c/r^,^/^ A'^/
Who can access keys and RAM? ^_
&^<f^ C^fe^-'^-'^ ^'^^
Do RAM storage areas have appropriate locks?
Who has keys?
Is there appropriate security during transport? T^'^^V^^'' e^^^ ^''(^. f>D)C r S
Is there appropriate security during use at temporary job/ite??
Is RAM appropriately secure during breaks and/or ovemight trips VjJ
Is there a receipt/transfer/disposal procedure for RAM?
Does licensee properly secure package receipt/transfer areas?
Does licensee inspect gauge shipping containers for damage? A/^n^
Does licensee perform appropriate receipt surveys?
Does licensee open packages in a safe manner?
Does licensee assure that packages are properly prepared for transport?
Are packages controlled in a secure manner prior to pickup?
Are there complete records of receipt/transfer/disposal? /iZ-A"
Did licensee verify eligibility to receive? p^iA—
Is licensee keeping a current and accurate inventory?
Have there been any unusual incidents involving lost, missing or stolen RAM?
Shieldins of Licensed Material
Does licensee have current SSD sheets?
What manuals/instructions do they have for devices? i
How are doses kept ALARA?
\
What maintenance does licensee perform? |
Who performs non-roufine maintenance? ^
Comprehensive Safetv Measures ^_
What types of non-radiological hazards are there? ^y^57?M,—-A^
Is there a fire protection program? ^ ^^ry-f^rx'-Cy /^C^
Is there contact with local fire departments? ^ ^
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Is labeling visible on all gauges/gauge containers/storage and use areas?
Is transportation safe and within regulations?
Are packages blocked and braced and locked with 2 independent means? pJe 5?
Are shipping papers in kept in truck cab within easy reach?
(Emergency contact and RAM information) ^ /
Radiation Dosimetry Prosram
How has licensee shown compliance with public dose limits? , /£^
(IS IT OBVIOUS?)
Have surveys been completed? j^/J)^
Did the surveys included occupied adjacent areas?
What exposure rates does inspector fmd? jJ ^
What survey instruments does licensee possess? pfg,
Are workers issued dosimetry badges? >/ ^
If not, does licensee have appropriate documentafion that monitoring is not required?
How is a workers dose kept ALARA? l^Oi^
Are there records of previous Leak Tests? l/l/J^'
Are the leak tests being completed at a frequency on the SSD sheet? '^^^^
Have leak tests shown any leaking sources? (/^
Are stored gauges properly secured in a controlled and safe manner?
Radiation Instrumentation and Surveys
Does licensee own survey instruments? ^^/^ J^J- ^^.^J^^ Oi.^ '7^/*^i/ls
If not, do they have ready access to a survey instrument?
Are appropriate survey records kept?
Radiation Safety Trainins and Practices
What are the names of all authorized users?
What training have they received?
What are the dates of training?
Has each received general gauge training?
Has each received annual hazmat training?
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Are workers knowledgeable of what to do in an emergency?
Examine Operafing and Emergency procedures.
Are the proper items posted?
The license or where it can be accessed.
The mles or where they can be accessed.
Sufficient copies of DRC-04 for workers to observe.
Manasement Oversisht
What is the path fi"om Management to RSO, AU's, etc.?
Is the radiation program properly staffed?
Does the RSO have the proper authority to stop unsafe practices?
Is the licensee completing annual intemal audits?
Open and Close with Management.
Violation, Incident, Investisation Follow-up
Check compliance history.
Check incident history?
Other
10. Violations
1. Non-Cited Violations
12. Special Items discussed with Licensee
Closeout with DRC Manasement
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Interview with the Radiation Safety Tech.(s)
1. Name:
2. Job Tifie:
3. How long have you been a Radiafion Safety Tech?
4. How were/are you trained to be a Radiation Safety Tech?
5. How long did your training last?
6. Describe how you would survey product drums before they leave the restricted area?
7. What are the release limits for product drums?
8. Describe how you would survey an Ore Truck out of the restricted area?
9. What are the release limits for the Ore Tmck?
10. Describe how you would perform an unrestricted release survey on an Intermodal Container?
11. What are the release limits for an unrestricted release?
12. Have them demonstrate how to source check an instrument.
13. How often are instruments source checked?
14. Where are the procedures kept that tell you how to perform a survey or source check an instrument?
15. Have you read those procedures?
16. Ifyou have a question about your job, how would you get it answered?
Comments:
U;\rad\COMMON\Uranium millsM I e(2)UTl 900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 OMnspection Modules\RADMOD-
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Pono n of l/l
1 • ^
DATE
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
/^^^, So^
J
1
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DISCUSSION of FINDINGS
SITE STAFF COMMENTS
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'fy Interview with the Radiation Safety Tech,(s)
1. Name:
2. Job Tifie:
3. How long have you been a Radiation Safety Tech? ^ /*f ,
4. How were/are you trained to be a Radiation Safety Tech? xj2 ^ 5 ,vys-^rc^?^^ tA'^LA c/^^^ ^^^^^
5. How long did your training last? 3 ^^y.^'^g
6. Describe how you would survey product dmms before they leave the restricted area?^h.J/:iTz-jy^ u
1C ^ ,-.fJ^ ^- J^^_ ^ y J ^
7. What are the release limits for product dmms? //^i^ ^ /j^^ ^ ^^y^-s^v.-^
8. Describe how you would survey an Ore Tmck out of the restricted area? j^/^z^^ <i:/( <^/c r
9. What are the release limits for the Ore Tmck? ^^SP^ • /'j'fx>/-r^j?'r=L
pA^ ^ X- .^(^/id^
10. Describe how you would perform an unrestricted release survey on an Intermodal Container?
11. What are the release limits for an unrestricted release?
\2JLaye them demonstrate how to source check an instmment. ~Z30 Sa^^ J^^^
13. How often are instmments source checked? ^cAyy Pf^-^
14. Where are the procedures kept that tell you how to perform a survey or source check an instmment?
15. Have you read those procedures? /^g^S
16. Ifyou have a quesfion about your job ?now would you get it answered? ^J^f^y<€-^ _/^-n/i
Comments:
U:\iad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMill\HP hispection modules\201 OMnspection Modules\RADMOD-
SSS-02 rev 1 ,doc
y y Interview with the Radiation Safety Tech.(s)
1. Name: /"24^.rl<^ ^/ /y/^_
2. Job Tifie: /^^.JJ
3. How long have you been a Radiation Safety Tec^? / ^ ^
4. How were/are you trained to be a Radiafion Safety Tech? /l.^/)^.
5. How long did your training last? JT /U}o6-^\ ^/c^
6. Describe how you would survey product dmms before they leave the restricted area?
ijei/e.^ i^f {/a^- ^^^^^ ^i.'ycAe^ 4,
7. What are the releaselimits fofproduct dmms^ \ Rj^TZ^/^.^^ <^/2-
8. Describe how you would survey an Ore Tmck out of the restricted area?
9. What are the release limits for the Ore Tmck?
10. Describe how you would perform an unrestricted irelease survey on an Intermodal Container?
11. What are the release limits for an unrestricted relejse?
12. Have them demonstrate how to source check an inkmment. pi. 't _5'g/-</-o.^ "f^
13. How often are instmments source checked? _oyg '
J
14. Where are the procedures kept that tell you how to perform a survey or source check an instrument?
15. Have you read those procedures? / -/".^^L^
16. If you have a quesfion about your job, how would ypu get it answered? /^z> ^5>^
Comments:
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SSS-02 rev I ,doc I
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WorkCentre 7346
Transmi ss i on Report
4 35 673 2 224 Date/T ime: 07/16/2010; 07: O SAM
Page: 1 (Last Page)
Local Name Denison Mines
Logo White Mesa M.M Blanding, Ut
Document has been sent.
Document Size 3. 5X11"SEP
DENISO MINES
DMIIMO Mnu Corp.
S4H 9. HlBhoay 1», PO Bn S09
aiaf)dlna.UT M511
Facsimile Transmittal
Companv:
j-MHO.: (, SCI.^ci. I'ifB
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Total pages Scanned: 3 Totat Pages Sent
No. Doc. Remote Station Start Time ation Pages C Q n T e n t s Stat us
1 2764 301903199S -16; 7 : O 1 AM
r-J o t e : RE : R e s e n d PG: Polling
SA: Send Agai
MB: Serid to Mailbox
RB: Relav Broadcast EN: Engaged
BC: B r oa d c ast
RS : Re lav Send AS: Auto Send
MP: Multi Polling
BP: Box Pax Forward
TM; Terminated
RV :
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demote Ser\ Completed
Shipment No. YC-14
Shippers Paper
Shipper:
DENISON MINES HOLDINGS CORP.
6426 SOUTH HIGHWAY 191. P.O. BOX 809
BLANDING. UT 84512
CONSIGNEE:
Honeywell
2768 N. US45RD, P.O. Box 430
Metropolis, IL 62960
Incoterm: Exworks
DATE:
CONTRACT NO:
LOT NO:
7/16/2010
97-538
YC-14
DELIVERING CARRIER
RSB Logistic Inc.
TRACTOR NO:
TRAILER NO:
SEAL NO:
43316
253081
7519
Seal #:007519
PARTIAL LOT:
COMPLETE LOT: xxx
GROSS WEIGHT (Ibs / kg): 74,380
Material Shipping Description:
Radioactive Material, low specific activity, n.o.s.
Class 7, UN-2912
43 Drums of Uranium Oxide
Received in good condition, except as noted:
Received By:
Date:
Emergency Contact Phone Number;
Chemtrec 1 -800-424-9300
Signature of Driver
This is to certifiy that the above named materials are properly
classified, described, packaged, marked and labeled, and are in
proper condition for transportation according to the applicable
regulations of the Department of Transportation.
Signature:
Denison Mines Representative.
Date: '^}lle>lt^/0
ftnison Mines (USA) cUp.
White Mesa Mill
Notice of Product Shipment Date: 16-Jul-lO
Product: U3O8
AMV"
Other"
X
Lot No.: YC-14 Gross Weight 74,380
Trans. No. 577 Tare Weight 33,780
Net Weight 40,600
Net Mat'l. Weight (lb.) 38,729
Weight as U308 (lb.) 35,139
Weight as U (lb.) 29,797
Net Mat'l. Weight (kg.) 17,567
Weight as U308 (kg.) 15,939
Weight as U (kg.) 13,516
Customer P.O. or Order Number: N/A
Destination: Honeywell International, Inc.
P.O. Box 430, 2768 N. US45 Rd.
Metropolis, Illinois 62960
Shipper Denison Mines via RSB Logistics
Signed
White Mesa Mill Yellowcake Production
LOT 14 YELLOWCAKE
FROM: Denison Mines (USA) Corp.
6425 South Hwy. 191, White Mesa Mill
Blanding, Utah 84511
TO: Converdyn
P.O. Box 430
Metropolis, Illinois 62960
SHIPPED:7/5/10 SEAL NO.: 007824
Drum No. Gross Tare Net Transportation
Index
1 989 44 945 0.9
2 969 41 928 0.9
3 960 47 913 0.9
4 966 46 920 0.9
5 962 39 923 0.9
6 1,041 46 995 0.9
7 967 42 925 0.9
8 996 46 950 0.9
9 993 45 948 0.9
10 1,000 44 956 0.9
11 999 40 959 0.9
12 1,000 46 954 0.9
13 952 46 906 0.9
14 947 41 906 0.9
15 949 38 911 0.9
16 945 46 899 0.9
17 948 38 910 0.9
18 944 38 906 0.9
19 1,000 44 956 0.9
20 991 46 945 0.9
21 992 38 954 0.9
22 942 46 896 0.9
23 854 39 815 0.9
24 855 39 816 0.9
25 962 40 922 0.9
26 896 38 858 0.9
27 976 46 930 0.9
28 939 40 899 0.9
29 906 46 860 0.9
30 958 45 913 0.9
31 923 45 878 0.9
32 977 45 932 0.9
33 971 44 927 0.9
34 971 45 926 0.9
35 947 44 903 0.9
36 924 46 878 0.9
37 913 40 873 0.9
38 933 38 895 0.9
39 930 41 889 0.9
40 917 37 880 0.9
41 875 44 831 0.9
42 717 46 671 0.9
43 774 46 728 0.9
Totals: 40,570 1,841 38,729
JUL-14-2010 12:45 RSB LOGISTIC 270 444 6721 P.01/03
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JUL-14-2010 12:45 RSB LOGISTIC 270 444 6721 P.02/03
RSB LOGISTiC Driver Routing Instruction
Product: Radioactive Malerial. Law Specific Activitv. (LSA) n.o.s Class: _7 UN # 2912
Shipper: Denison Mines. Blandim. UJ. Consignee: Honeywell. Meiropolis. IL
Tn an Emergency, contact 911 or loc:il authorities, then notify RSB [phone].
The following route must be followed. Any deviations must be reported to RSB immediately to ensure regulatory and
customer compl iarice.
St/Prv Route Interchange Leg Total
UT South 13S-191 (to UT/A2 State Line) 51.1 51.1
AZ South lJS-191 + US-191 US'160 5.2 S6.3
US-160 + US-160 US.64 29.2 85,5
East US-64 (to AZ^NM State Line) 4.1 89.6
MM East US-64 + US-64 US-491 2L9 111.5
South US-491 + US-491 Ramp 91.4 202.9
Left Ramp + Ramp I 40 0.2 203.1
East 140 (to NM/TX State Line) 35L4 554.5
TX East 140 (to TX/OK State Line) 176.6 731.1
OK East 140 + 140 Exitl47A 146.3 877.4
Hear right Exit 147A + Exit 147AT44 0.5 877,9
West I 44 (Will Rogers Expy) +144 1 240 4.3 882.2
Easi 1240 (State Hwy 3) +1240 Ramp 15.8 898
Slraight Ramp + Ramp I 40 0.8 898.8
We.<;t 140 (Tinker Expy) (to OK/AR State Line) 165.8 1064,6
AR Ea,st 140 + 140 Exit 277 276.3 1340.9
Bear riKhl Exit 277 + Exit 277 1 55 0.6 134I.S
North 155 (to AR/MO State Line) 65.1 1406.6
MO North 155 + 155 Exit 66A 65.8 1472.4
Bear right Exit 66A + Exit 66AI 57 0.5 1472.9
North I 57 (US 60) (to MO/IL State Line) 21.7 1494.6
TL North 157 + 157 Exit 8 7.4 1502
Bear right Exit 8 + Exit 8 Roulc 8 0.3 1502.3
Right Route 8 -1- Route 8 n--37 1.4 1503.7
North IL-37 + 11,-37 iL-169 13.7 1517.4
East lL-169 + IL-169 US-45 9 1526.4
South US-45 Metropolis, IL, 62960 12.4 1538.8
Fum 1/036
Revised April, J007
Page 2 Upditcd: Augusl. 2007
JUL-14-2010 12:45 LOGISTIC 270 444 6721 P. 03/03
Guide 162
Radioactive Materials (Low to Moderate Level Radiation)
POTENTIAL HAZARDS
Health • RadlBiion presencs mminial risk to tnmspon wodun, emergency response personnel and the public duiing
(nuupoitBtion accidents. PBckA|ing duiAbili^ increases «s poicndal hazaid of radioactive content increases. « Undamaged packages ate safe. Contents of dainaged packaea may cause higher external isdiaQon expo.suie, or Inih eztemBi and intenial radiation exposuic if contents are released.
* Low radiation hazard when nuuerial is inside container. If maieria] is reltased from package or bullc container, hazard win •vary from low to modec^te. • Level of huKartl will depend on the type and amount of ladioactivity, the kind of material ic ia in, andOr tlie
surfaces it is on. • Some maieiial may be released fram packages during acddenta of modeiatc ncvciiiy but risks to people are not great
« Released radioactive materials or contaminated objecla usually will be viaitile if packaging fails.
4 Some exclusive uae shipments of bulk and packaged naieilals will not have RADIOACTiVBIatiels. Placards, markings and shipping papers provide identification.
« Some packages may have a RADIOACnVEIabcl an da second bazanl label. Tbe second hazoid is usually
greater than the radiaiion bazatd;so follow this GUIDE aa well aa the icsponse GUIDB for the second hazard class label. • Some radioactive mateiials cannot be detected by conunonly available instruments.
• Runoff ftom contiol of cargo fire may cause low-level pollution.
PIreer
explosion
• Sonae of these malerials may bun, but most do not ignite readily. « Uranium and Thorium metal cuitliies may ignite spontaneously if exposed to air (see GUIDE 136).
« Nitrates arc oxidiacni and may ignite ottier combustibles (see GUIDB 141).
PiiBLic SAFETY
• CALL Emergency Response Telephone Number on Sbippiiw Pitper Ont If Shipping Pnper not avofloble or no anawer, ref^r to appropriate telephone luimber Usted at tbe end of this SMtlotL • Priorities tor rescue, lifc-saVinj:, first aid, fin: control and other hazards are higher than the priority for measuring nuUstlan levels.
« Radiation Authority must be notified of accident conditions. Radiation Audiority is usually responsible for decisions about radiologieal consequences and closure of emergencies.
• As an immediate pncaudonaiy measum, isolate spilt or leak area for at least 25 meters (75 feet) in all directions. • Stay upwind. • Keep unauthniized personnel away.
• Detain or isolate unlnjired persons ot equipmeni suspected to be containinaiedulelay decoiUaminaiion and cleanup until
instrucdons are received from Radiation Authority.
Protective * Posibve pressure self-contained breathing apparatus (SCBA) and structural firefighters'protective clothing will
Clothing provide ade<)uate protection.
Evacuation L*nt»
* Consider initial downwind evacuadon for at least 100 meters (330 feet).
» Win a large quantity of this material is involved in a m^r file, consider aa initial evacuadon distance of 300
meten (1000 feet) in all direcdons.
EMERGENCY RESPONSE
Fire * Presence of radioacdve material will not influeoce tbe fiie connol processes and should not influence selection of
techniques. • Move container? from fire sica if you can do it without risk.
« Do nol move damaged packages wove undamaged packages out of fiie zone,
Small FIna • Dry chemical, CO., water spray or regular foam. LMrg» Ftrett * ilfer spray, fog (flcxiding amoniUs).
• Dike Ore-control water for later disposal.
Spill or • Do not touch damaged packages or spilled matcnsl. L«ak * Cover liquid spill with sand, eanh or other non-combusdble absoiteiu material.
• Dike to collect large liquid spills. • Cover powder spill with plaoic sheet or taip to minimize spicading.
Pint Aid « Medical problems take priority over radiological coocetrts. ~
• Use first aid licatment according to the namre of the iiQity.
• Do not dilay caic and nanspoit ofa seriously iojued person.
« Give anlSeial tesplradon If victim is not bieathiog.
• Administer oxygen if breathing is difficult
• Io case of contact widt substance, wipe from skin iRunediatelyidush skin or t yes widi nmning water for at least 20
miinites,
• Inpied peivona contaminated by contact widi released ma tetial are oot a serious hazard to health caie peisoooel,
equipment or facilities.
• Ensure that medical peraonnel aic aware of the mBterial(s) involved and take precautions to protect ihemiselves and
prevent spread of conlaminatioa,
O Oaratec Bductmorud Services Ud Excerpts fiom the 20O4 Emergenty Keiponst Guidebook page 645
Page 3
TnTQI P n"^
DenHon Mines (USA)^orp.
Material Safety Data Sheet
Denison Mines (USA) Corp. requests that users of this DUSA product study this data sheet to become
aware of the product's hazards, and promote safe handling of the product by making this information availble
to its employees, agents and contractors. If the material is resold, Denison Mines (USA) Corp. requests
that the purchaser be fumished a copy of this data sheet and advised to provide the information herein to its
employees, agents and contractors.
Section I Product Indentification
Product Name: Yellowcake
Creation Date: December 6, 1993
Revision Date: April 20, 2008
C.A.S. Numbers: 1344-59-8; 13721-34-1;
1314-64-3; 1309-37-1; 7778-18-9; 12136-45-7; 7757-82-6;
1314-62-1; 7631 -86-9; 1344-28-1
Chemical/Alloy Name: Uranium.Uranyl Oxides,
Uranium Octaoxide
Formula/Composition: UjOg (65-95%); Na2U207
(2-21%; UO2SO4 (2-14%); Fe203 (0-2%); CaS04 (0-4%);
K2O (.6-2.5%); Na2S04 (0-10%); V2O5 (0-1.5%); Si02
(0-1%); AI2O3 (0-4%)
Synonyms: V^O^, Uranium Concentrates
Formula/Composition: UjOg (65-95%); Na2U207
(2-21%; UO2SO4 (2-14%); Fe203 (0-2%); CaS04 (0-4%);
K2O (.6-2.5%); Na2S04 (0-10%); V2O5 (0-1.5%); Si02
(0-1%); AI2O3 (0-4%)
Formula/Composition: UjOg (65-95%); Na2U207
(2-21%; UO2SO4 (2-14%); Fe203 (0-2%); CaS04 (0-4%);
K2O (.6-2.5%); Na2S04 (0-10%); V2O5 (0-1.5%); Si02
(0-1%); AI2O3 (0-4%)
Section II Physical Dala
Size: 0.25 inch (0.64 cm) Solubility in Waier: (g/100 cc) UO2SO4
soluble; CaS04 0.21; Na2S04 4.8; V2O5 0.8; KnO V. Sol;
U3O8, Na2U207, Fe203, SiO,, AI2O3 insoluble
Specific Gravity: (H2O =1)8.3 Melting Point: °F (°C) UjOg 2372 (1300)
decomp; FejO, 2849 (1565); CaS04 2642 (1450); K2O
662 (350) decomp; Na2S04 1623 (884); VjOj 1274 (690);
Si02 2930 (1610); AI2O3 3762 (2072); Na2U207, UO2SO4
not available
Odor: None
Melting Point: °F (°C) UjOg 2372 (1300)
decomp; FejO, 2849 (1565); CaS04 2642 (1450); K2O
662 (350) decomp; Na2S04 1623 (884); VjOj 1274 (690);
Si02 2930 (1610); AI2O3 3762 (2072); Na2U207, UO2SO4
not available
Appearance: Yellow to olive-green powder
Melting Point: °F (°C) UjOg 2372 (1300)
decomp; FejO, 2849 (1565); CaS04 2642 (1450); K2O
662 (350) decomp; Na2S04 1623 (884); VjOj 1274 (690);
Si02 2930 (1610); AI2O3 3762 (2072); Na2U207, UO2SO4
not available
Bulk Density: 80-190 lbs/ft" (1.3-3.0 g/cm")
Melting Point: °F (°C) UjOg 2372 (1300)
decomp; FejO, 2849 (1565); CaS04 2642 (1450); K2O
662 (350) decomp; Na2S04 1623 (884); VjOj 1274 (690);
Si02 2930 (1610); AI2O3 3762 (2072); Na2U207, UO2SO4
not available Molecular Weight: UjOg 842; Na2U207 634; UO2SO4
336; FejOj 160; CaS04 136; K2O 94; Na2S04 142; V2O5 182;
SiO2 60; AI2O3 102
Melting Point: °F (°C) UjOg 2372 (1300)
decomp; FejO, 2849 (1565); CaS04 2642 (1450); K2O
662 (350) decomp; Na2S04 1623 (884); VjOj 1274 (690);
Si02 2930 (1610); AI2O3 3762 (2072); Na2U207, UO2SO4
not available Molecular Weight: UjOg 842; Na2U207 634; UO2SO4
336; FejOj 160; CaS04 136; K2O 94; Na2S04 142; V2O5 182;
SiO2 60; AI2O3 102
Boiling Point: SiOz 4046 (2230); AI2O3 5396 (2980);
Others not available.
Vapor Pressure: Essentially nil. Percent Volatile: Not applicable
Evaporation Rate: Not applicable.
Section III Hazardous Ingredients
Material or Component (CAS #) Weight % TLV
Uranium-Uranyl Oxides, UjOg, (1344-59-8)
(Insoluble Compound) (As U)
Sodium Diuranate, Na2U207 (13721-34-1)
(65-95)
(2-21)
0.2mgW-TWA8(l)(3)
0.6 mgW-STEL (1)(3)
Uranyl Sulfate, UO2SO4 (1314-64-3) (2-14) 0.05 mgW-TWA8(l)
0.2 mg/rn - TWA8 (3)
0.6 mg/rn - STEL (3)
Iron Oxide, FejOj (1309-37-1) (0-2) 10 mglm, fume (1)
5 mg Fe/m'' fume (3)
Calcium Sulfate, CaS04 (7778-18-9) (0-4) 10 mglm - TWA8 (total)(3)
15mgW-TWA8 (total)(3)
5 mg/m' - TWA8 (respirable)(l)
Potassium Oxide, KjO (12136-45-7) (0-2) No PELs listed (1)(2)(3)(4)(5)
Sodium Sulfate, Na2S04 (7757-82-6) (0-5) No PELs listed (1)(2)(3)(4)(5)
Denison Mines (USA) Corp.
Vanadium Pentoxide, VjOg (1314-62-1) (0-1.5) 0.05 mg/m^ - TWA8 (respirable dust)(l)(3)
0.05 mg - TWA8 (fume)(l)(3)
Silica, Amorphous, SiOz (7631 -86-9) (0-1) 10mg/m'-TWA8 (total)(3)
6mg/m^-TWA8(l)
Aluminum Trioxide, AI2O3, (1344-28-1) (0-4) 10 mg/m^ - TWA8 (total)(as Al)(3)
15 mg/m^ - TWA8 (total)(as Al)(l)
5 mg/m^ - STEL (respirable)(as Al)(l)
References: 1 OSHA Standard 1910 2. MSHA Slandard 3 Currenl AGGIH 4 NIOSH Recommendation 5 DUSA Internal Standard
For Chemical Emergency, Spill, Leak, Fire, Exposure or Accident - Call CEMTREC Day or Night
Domestic North America 1.800.424.9300 (Chemtrec)
International, call 1.703.527.3887 (collect calls accepted)
Denison Mines (USA) Corp. - 6425 South Highway 191- P.O. Box 809 - Blanding, UT 84511
Section IV Health Hazard Data
EFFECTS OF A SINGLE OVEREXPOSURE(*)
Swallowing: May cause mouth and throat irritation, nausea.
Skin Absorption: No evidence of adverse effects from availabel information.
Inhalation: May cause irritation ofthe respiratory tract, with cough, throat redness and pain. May cause
kidney and lung injury.
Skin Contact May cause dermatitis.
Eye Contact May cause irritation and redness. Harmful amounts may be absorbed.
EFFECTS OF REPEATED OVEREXPOSURES(*)
May cause injury to lungs, lymph nodes, kidneys, liver, blood and other organs.
OTHER EFFECTS OF OVEREXPOSURE(*)
None currently known.
SIGNIFICANT LABORATORY DATA WITH
POSSIBLE RELEVANCE TO HUMAN HEALTH
HAZARD EVALUATION
Causes cancer in animals, principally involving the lungs, bone, and blood-forming organs.
AGGRAVATION OF PRE-EXISTING CONDITIONS
Breathing dust may aggravate pre-existing asthma and inflammatory or fibrotic pulmonary
disease.
EMERGENCY AND FIRST AID PROCEDURES
Swallowing: Drink at least two glasses of water immediately and induce vomiting. See a physician promptly.
Skin: Remove contaminated clothing. Promptly wash contaminated skin with soap and water. If
irritation is present, see a physician.
lff( Denfson Mines (USA) 8 orp.
Inhalation: Remove victim to fresh air. Give oxygen if breathing is difficult. Call a physician promptly. If
breathing has stopped, perform artificial respirations
Eyes: Flush eyes promptly with large quantities of water for at least fifteen minutes. If irritation is
present, see a physician promptly.
NOTE TO PHYSICIAN
Treat poisoning with intravenous bicarbonate to facilitate renal excretion. Prompt administration
of EDTA enhances removal of uranium.
(*)Failure to follow the precautionary measures recommended in Sections V, VI, VII, VIII and IX may result in overexposure.
Section V Fire and Explosion Data
Combustibility: Essentially non-combustible Flammable Limits: Not applicable
Flash Point (Test method): Not applicable Autoignition Temperature: Not applicable
Explosion Tendency: None
Extinguishing Media: No fire hazard.
Special Fire-Fighting Procedures: Avoid procedures which may create dust. When fighfing a fire involving this
material, wear full protective equipment including positive-pressure breathing
apparatus. Minimize spread of water-borne solids.
Unusual Fire and Explosive Hazard: None.
Section VI Reactivity Data:
Stability: Stable in air and water. Soluble in HNO3 with formation of uranyl nitrate. Soluble in HF/H2SO4.
Decomposes in UO2 at 2372°F (1300°C)
Conditions to Avoid: None.
Hazardous Decomposition Products: None. See "Stability" for possible reaction products.
Materials to Avoid: None.
Section VII Spill. Leak, and Disposal Information
Steps to be taken if Material is Spilled or Released: Restrict persons not involved with cleanup from the area of the spill
until cleanup is completed. Use HEPA dust collection or temporary cover, if available, to control the level of
airborne dust. Use shovel, vacuum, or mechanical means to collect spilled material. Avoid maneuvering with
compressed air or any other method which generates dust. Cleanup personnel should wear skin and eye
protection and avoid the inhalation of dust by the use of appropriate respiratory protection. Radioactive
materials license condition must also be followed.
Neutralizing Agents: None.
Waste Disposal Method: Steps to be taken if material is spilled or released: This material contains ingredients which are
included in 40 CFR 302, Table 302.4, "List of Hazardous Substances and Reportable Quantities". This material
is a "low specific activity" radioactive regulated material and must be disposed of in accordance with Nuclear
Regulatory Commission, state and local regulations.
Section VIII Special Protection Information
Ventilation: Provide sufficient mechanical HEPA dust collection, combined with administrative controls, if
applicable and needed to keep exposures below the permissible exposure limit.
Eye Protection: Dust resistant safety glasses should be worn. Facilities to flush the eyes with water should be
readily available.
Denison Mines (USA) Corp
Gloves/Clothing: Gloves should be worn. Avoid contaminafion of clothing with dust.
Other: None.
Section VIII Special Protecfion Information (Confinued)
Personal Protective Equipment: (I)
Full face piece high efficiency particulate filter respirator (as per 30 CFR 11) required when
handling this material unless otherwise directed by the Radiafion Safety Officer.
Fire Fighting:
Self-contained breathing apparatus with a full facepiece operated in pressure demand or other
positive mode.
(1) Based on Revised 10 CFR 20, Appendix A
Secfion IX Special Precaufions
Precaufionary Statements: Caution
OVEREXPOSURE* TO DUST MAY CAUSE DERMATITIS; IRRITATION AND REDNESS OF THE EYES WITH POSSIBLE
HARMFUL ABSORPTION; IRRITATION OF THE MOUTH AND THROAT WITH NAUSEA; AND RESPIRATORY TRACT
IRRITATION. WITH COUGH, THROAT REDNESS, AND PAIN. MAY ALSO CAUSE KIDNEY AND LUNG INIURY.
REPEATED OR PROLONGED OVEREXPOSURE MAY CAUSE INJURY TO LYMPH NODES, KIDNEYS, LIVER, BLOOD,
AND OTHER ORGANS. BREATHING DUST MAY AGGRAVATE PRE-EXISTING ASTHMA AND INFLAMMATORY OR
FIBROTIC PULMONARY DISEASE.
OTHER PRECAUTIONS
Soluble uranium compounds cause cancer of the lungs, bones and blood forming organs in laboratory animals. Adhere to
the recommended PEL to keep exposures to soluble uranium compounds below 0.05 mg U/m^ (OSHA PEL).
Avoid swallowing or breathing dust.
Avoid contact with eyes, skin or clothing.
Keep container closed.
Avoid actions which generate dust.
Use only with adequate ventilafion.
Wear approved respiratory and protective
clothing in dusty areas.
Wash thoroughly after handling.
"Overexposure is based on tiine of exposure and air concentrations. Refer to Revised 10 CFR 20, App. A.
Dei^son Mines (USA)^orp.
FOR INDUSTRIAL USE ONLY
Precaufions for handling and storage: "Material should be stored in tighfiy closed containers and kept dry. Eafing
or smoking should not be permitted in areas where dust is present. Avoid contamination of clothing with this
material and wash hands thoroughly with soap or mild detergent and water before eating, smoking, or using
toilet facilifies.
Other Precaufions:
Carcinogen Lisfings:
Nafional Toxicology Program Annual Report (NTP): Not Listed
Intemafional Agency for Research on Cancer (lARC): Not Listed
OSHA 29 CFR Part 1910, Subpart 2: Not Listed
Denison Mines (USA) Corp. believes that the data herein are current as of the
effective date of this data sheet and that the opinions herein are those of qualified experts.
Since the product and the information herein will be used outside the control of Denison
Mines (USA) Corp., it is the user's responsibility to establish conditions for safe iise
ofthe product. The data herein relate only to the product of Denison Mines (USA) Corp.
and may not be applicable for products of other manufacturers.
Denison tUIines Corp.
6425 S. Highway 191, PO Box 809
Blanding, UT 84S11
USA
Tel: [phone]
Fax : [phone]
www.denisonmines.coin
SHIPMENT SURVEY
CONTRACT NO.
TRACTOR NO.
LOT NO.
TRUCK CARRIER
TRAILER NO.
e.5.gi Le<^oT^3
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
FACTOR
MDA b.o
ALPHA SURVEY INSTRUMENTS
TOTAL
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
FACTOR
ALLOWABLE LIMITS (FIXED) 5.000 DPM AVG. 15,000 DPM MAX (REMOVABLE) 1.000 DPM
REMOVABLE
'b ' 5'"''fc-- to
1.0
SURFACE AREA OF PROBE
100 cm^
X EFFICIENCY OF INSTRUMENT (%) = FACTOR
100
(EFFICIENCY/1 OOcm^)
Factor X counts/minute = Dislntegrations/minute/IOOcm'
INSTRUMENT NO.
SERIAL NO.
CALIBRATION
TRAILER SURFACE
SIX FEET DISTANCE
DRIVERS SEAT
SLEEPER
GAMMA SURVEY (49 CFR 173.441 (b) (1))
MEASURED IN MILLIREMS/ HOUR
Z^-<Apr-l- to (MR/HR)
200 MR/HR ALLOWABLE
10 MR/HR ALLOWABLE
2 MR/HR ALLOWABLE
2 MR/HR ALLOWABLE
ALL DRUMS WERE INSPECTED PRIOR TO LOADING. ALL DRUMS WERE TIGHTLY
SEALED. NONE LEAKED AND THERE WAS NO LOOSE MATERIAL IN THE VEHICLE.
INSPECTOR SIGNATURE DATE IO
C^ison Mines (USA) Qgrp.
DRUM CONTAMINATION SURVEY
Type of Shipment: \j^\{o\y^c^<^ Lot #: \*^^
Page 2
Date: ^/a/)<J
Drum
#
Total Alpha
dpm/100 cm^
Top Sides
Rernovable Alpha
dpm/100 cm^
Top Sides
P/Y
Average
mrem/hr
1 l.S
2 1.5
3
4 ) /
5 J (
6 /
7 ( v.s
8 \ /
9 /
10 / (
11 / \
12 ( / 5.0 1%
13 /
14 )
15 / \ i />~0 A 1-1
16 ( ) !
17 /
• 1
18
19 J \
20 )
21 ( /
22 C 1.^
23 )
24 /
25 V SP \ %0f^
* If total Alpha is greater than or equal to 1,000 dpm/100 cm^, a removable smear is required.
Alpha Meter
Model #:
SN#:
Removable Alpha
Cal. Date: tli-ftpoV-yo
Model #:
SN #: VM^T^bV
Beta/Gamma Meter
Model #
SN #:
Check Date: \^' 3»V( - lo
Cal. Date: -t..>:^o*'c-io
Check Date: "^-"tf-io
Th 230 @ 33,000 dpm
dpm Average: t>.Hbo
Efficiency: i13.7o
Bkg: lO
Th 230 @ 33,000 dpm
Efficiency: 'bxl^^k
Bkg: i?.2>T-
Cal. Date: Z-b-^frU-lo
Check Date: il - ^oW '/Q
Cs137SN#2
Reading: ^.C^^P/HP-
Bkg: 0.O(>r^rli-iC~
MDA:
Page 3
Drum
#
Total Alpha
dpm/100 cm^
Top Sides
Removable^lpha
dpm/100 cm^
Top Sides
P/Y
Average
mrem/hr
26 i (s>0 17
27 / l.>
28 ( I 5.0 l.S
29 \ l.%
30 ) \ \.7
31 / l.b
32 / I \.5
33 /
34 l.>
35 V 1.4
36 \ 1 if
37 I
38 / \
39 / j l.S
40 / J ll.l
41 [ / I.e.
42 (
43 l.b
44
45 /
46
47
48
49
50
Comments:
j/pru/ivj[X
•I7 5...to:^euado
CW) qi iZieZ.££ sauei
qi m'BT.^L sssoug
T E f 5 90 0 103/91/7.0
•ot\j uo T: q.3??stie..4j
.LWaWdlHS DA SI"IOdOy.L3W
uApjaAU03 uApaaAU0:3
S UI
SQI "uiq.saa
SQI iv?taaq.BW
IQl uauMQ
SQI q. uno ooy
5(11 uaiteji
** /.^7S 10560 0T/9T//.0 V ^q paq.ui:uday
TTsve m ButpuFia
T.6I .-^eMqBTH "S S3t'9
TITW esaiAi aq.TMM
"(daoo cysn) sauiw uostuaQ
.i.N3(.'4d.lH& JA Sl IGdOy.i.BW 'Ql "un-saa
sa q.eu^.ua..3Uo;;j lan T. ue^n ueiud x qQ "Ql '(/ex .JS ^.•<s\4
'-•i l id!Zi90i/ : =ai J^ip-*n
<.'•( I ft'iWiJ'VZ. f S5oa«f) : ai ua i tHjj_
•SM^©—9tE£<?—QBH "OI a lotqan
I 11^) • 6 V! 0 10 c! / 9 !:/•,:_ 0 : a A 0
f r T 5 98 010.3/91. /Z0 SUT.
•['-'^S '•5'i'Ti. fl'j.SQ X-* /,^7"!:0:60 0T/9T//.0 4*=^ '''M pBq.UiUda;-J -a.*
in nucuueie
c:.2i-:93 16't A!?MMn^|...i "B i^ybg
"' j!'.; u (;) T s u \= .j. j T I !• W s s a|A1 T t..|fv^
"CAOQ i.HSf!) sauiw aDSTiiS(i
c
DEMISON MINES (USA) Corp,
White Mesa Mill
KadiaMom Survey of Eqsinpmeut Released for UmirestD'icted Use
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with the foUowing procedure.
1. Monitor for Gross alpha contamination with the appropriate sui-vey meter.
2. If calculated assay exceeds 1,000 dpm/lOOcm^ then perfonn swipe analysis at applicable points.
3. Decontaminate if a removable alpha exceeds 1,000 dpm/lOOcm^ or fixed alpha exceeds 5,000 dpm/lOOcm^.
4. Release equipment or material if alpha contamination and Beta-Gamma levels are below the following
limit:
Removable alpha - 1,000 dpm/lOOcm^
Fixed alpha- 5,000 dpm/lOOcm^ average
15,000 dpm/lOOcm^ maximum
Beta-Gamma- 0.2 mr/hr @ 1 cm average
1.0 mr/hr @ 1cm maximum
Released frpm White Mesa Mill to:
TRT /ct^M\tov\.vm^[. "POC ,
Released by: ^o/\Aie^ Z^* Date: ^IIHIIO
List of Equipment Total Alpha dpm/lOOcm^ Removable Alpha
dpm/lOOcm^
Beta/Gamma mr/hr
3.
4.
5.
Instrument Function checks
Alpha Meter:
Inst. Model SN i'j'»5'i>
Th-230 Source SN S^lVQQ
dpm33^OoO cpmM,cco eff
Efficiency Factor "^fV
Bkg_ '^0>
Beta-Gamma Meter:
Inst. Model 3
Cs-137 Source SN -^rp-
Inst. Response dl.^«»>rf4lP.
SN \\^^^<\-b
MDA ayf.Q Comments:
Removable Alpha;
Inst. Model AsJ
Th-230 Source
dpm cpm
Efficiency Factor
Data; Zlzhhd
Bsm'mon Mm&s. (USA) Corp.
Ore Hawlage Sunfay for Restricteiu; Release ^—-7
SurvejfefS By: I ' Ffaifer IB:
Outside Locations Tfac-tor iD i?
Designates
top
Location #
Total Alpha/
Beta^^amma
cpm
' o
' 00
« 00
Location #
o
00
00
Total Alpha/
8eta.<Banuna
1:
2:
3: f 4:
5:
6:
Truck Ext.:
Trailer Tires
00 00 7
« 00
11 00
00
00
8
10
12
Removable alplia -
Mxed alpha
ieta-Gamma
lOOOdpm/IOOcm^
5000 dpm/IOOcm^ average
15000 dpm/l OOcm^ maximum
0.2 mr/hr @ 1cm average
1.0 mr/hr @ 1 cm maximum
lomments:
Sfty \o,2c:?0
Instrument Data
Total Alplia/
Beta/Gamma
Model #:
SN:
Cai. Date:
Source:
Efficiency:
Factor
Baclcg round:
MDA
/o
2 _ •• 30
Total Alpha/
Beta-Gamma
Location # cpm
7 i 6ICS
8 /
9 (
10 (
11 \
12
h230 Reading
Ore l-taulage 2
DENISON MINES (USA) CORP.
DECONTAMINATION FINAL RELEASE
I have verified that tractor NA and/or container
Tractor Number
CJFLU oom^d) has been checked for any contamination and has been
Container Number
authorized for final release.
Radiation Technician 7 ft ho
Radiation Department Title Date
http://intranet.denisonmines.com/whitemesamill/Radiation/radiation/Forms/decon.doc
Denison Mines (USA) Corp.
Equipment Survey for Unrestricted Release
Date: "?A^/L Container ID: LU <^€>i^;^h Surveyed By:
Inside Locations
Front
19
L. Side
13 14
23
15 16
R Side
17 18
7 8
22
9 10
21
11 12
1 2 3 4 5 6
20
Tailgate
Location #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Total
Alpha
Total Removable
Alpha Alpha Beta
dpm/IOOcm' dpm/100cm= Gamma
5 (M.fl^4
'"7
7
i 4-
Outside Locations
dpm/100cm'
Total
Alpha
Removable
Alpha Beta
Truck
and Tire Survey
1 0 0 2
3 00 004
5 00 OOe
Total Alpha/
Beta-Gamma
Location # dpm/100cm' dpm/100cm' Gamma Location i cpm
20 io .oi 1:
21 t 2: 1
22 3:
23 4:
24 5:
25 6:
26 Truck Ext.:
27
28
29
30 TRAILER TIRES
31
32 7 00 oo 33
34 9 00 oo 35
36 11 00 oo 37 i-m
Rails Total Alpha/
Instrument Data
Beta-Gamma
Location cpm
Instrumenl:
SN
Cal. Date:
Function Check (5x1 min.)
Th 230 @ 33000 dpm
Bkg Average: X^Q
Dpm Average: T,OCV
Efficiency;
Eff Factor:
MDA JLl.
'movable alpha
id alpha -
'III
/i8--.r
1000dpm/100cm^
5000 dpm/100cm' average
15000 dpm/100cm'maximum
Beta - Gamma - 0.2 mr/hr @ 1cm average
1.0 mr/hr @ 1cm maximum
Removable
Alpha
Model: 'Z'Loo
SN: /?5'^^
Cal. Oate: rhul'^
Function Check (5x1 min.)
Alpha Bkg Ave: ^. S~
Alpha eff:
Alpha Factor:
Comments: Ctx\no\- Co-^i'
Total
Beta/Gamma
Model #:
SN: ^
Cal. Date;
Source:
Reading;
10
11
12
Chassis Ext. r
§ 173.426 49 CFR Ch. 1 (10-1-09 Edition)
TABLE 4—ACTIVITY LIMITS FOR LIMITED QUANTITIES, INSTRUMENTS, AND ARTICLES
Nature of contents
Instruments and adicies
Limited quantity package limits' Nature of contents Limits for each Instru-
ment or article' Package limits'
Limited quantity package limits'
Solids:
10 ' A, A, 10-' A,
10-' A; A2 10 ' Az
Liquids;
Tritiated water;
<0.0037 TBq/L (0.1 CVL) 37 TBq (1,000 Ci)
0.0037 TBq to 0.037 TBq/L 37 TBq (100 Ci)
(0.1 Ci to 1.0 Ci/L).
>0.037 TBq/L (1.0 Ci/L) 0.037 TBq (1.0 Ci)
Other Liquids 10 ' A; ' 10-1 A; 10-' AJ Gases:
Tritium 2 2x10 'A; 2 X 10 -1 Al 2 X10-' A;
10 ' A, 10-' Al 10-' A,
Normal form 10 ' A; 10-' AJ 10 ' AJ
^ For mixtures of radionuclides see § 173.433(d).
2 These values aiso apply to tritium In activated luminous paint and tritium adsorbed on solid carriers.
[Amdt. 173-244 . 60 FR 50307. Sept. 28. 1995, as amended by Amdt. 173-244 , 61 FR 20751, May 8, 1996; 63 FR 52849, Oct. 1, 1998; 65 FR 58630, Sept. 29, 2000; 66 FR 45383, Aug. 28, 2001; 69 FR 3676,
Jan. 26. 2004]
§ 173.426 Excepted packages for arti-
cles containing natural uranium or
thorium,
A manufactured article In which the
sole Class 7 (radioactive) material con-
tent Is natural uranium, unirradiated
depleted uranium or natural thorium,
and its packaging, are excepted from
the requirements in this subchapter for
specification packaging, labeling,
marking (except for the UN identifica-
tion number marking requirement de-
scribed in § 173.422(a)), and if not a haz-
ardous substance or hazardous waste,
shipping papers and the requirements
of this subpart if:
(a) Each package meets the general
design requirements of §173.410;
(b) The outer surface of the uranium
or thorium is enclosed in an inactive
sheath made of metal or other durable
protective material;
(c) The conditions specified in
§ 173.421(a) (2), (3) and (4) are met; and
(d) The article Is otherwise prepared
for shipment as specified in § 173.422.
[Amdt. 173-244 , 60 FR 50307, Sept. 28, 1995, as
amended by Amdt. 173-244 , 61 FR 20752, May
8, 1996; 69 FR 3676, Jan. 26 , 2004]
§ 173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) materials and surface
contaminated objects (SCO).
(a) In addition to other applicable re-
quirements specified in this sub-
chapter, LSA materials and SCO, un-
less excepted by paragraph (c) or (d) of
this section, must be packaged in ac-
cordance with paragraph (b) of this sec-
tion and must be transported in ac-
cordance with the following conditions:
(1) The external dose rate may not
exceed an external radiation level of 10
mSv/h (1 rem/h) at 3 m from the
unshielded material;
(2) The quantity of LSA and SCO ma-
terial in any single conveyance may
not exceed the limits specified in Table
5;
(3) LSA material and SCO that are or
contain fissile material must conform
to the applicable requirements of
§173.453;
(4) Packaged and unpackaged Class 7
(radioactive) materials must conform
to the contamination control limits
specified in §173.443;
(5) External radiation levels may not
exceed those specified in §173.441; and
(6) For LSA material and SCO con-
signed as exclusive use:
648
Pipeline and Hazardous Materials Safety Admin., DOT §173.427
(1) Shipments shall be loaded by the
consignor and unloaded by the con-
signee from the conveyance or freight
container in which originally loaded;
(ii) There may be no loose radio-
active material in the conveyance;
however, when the conveyance is the
packaging, there may not be any leak-
age of radioactive material from the
conveyance;
(111) Packaged and unpackaged Class
7 (radioactive) materials must be
braced so as to prevent shifting of lad-
ing under conditions normally incident
to transportation;
(iv) Specific instructions for mainte-
nance of exclusive use shipment con-
trols shall be provided by the offeror to
the carrier. Such instructions must be
included with the shipping paper infor-
mation;
(v) Except for shipments of
unconcentrated uranium or thorium
ores, the transport vehicle must be
placarded In accordance with subpart F
of part 172 of this subchapter;
(vi) For domestic transportation
only, packaged and unpackaged Class 7
(radioactive) materials containing less
than an A2 quantity are excepted from
the marking and labeling requirements
of this subchapter. However, the exte-
rior of each package or unpackaged
Class 7 (radioactive) materials must be
stenciled or otherwise marked "RA-
DIOACTIVE—LSA" or "RADIO-
ACTIVE—SCO", as appropriate, and
packages or unpackaged Class 7 (radio-
active) materials that contain a haz-
ardous substance must be stenciled or
otherwise marked with the letters
"RQ" in association with the descrip-
tion In this paragraph (a)(6)(vi); and
(vii) Transportation by aircraft Is
prohibited except when transported in
an Industrial package In accordance
with Table 6 of this section, or in an
authorized Type A or Type B package.
(b) Except as provided in paragraph
(c) of this section, LSA material and
SCO must be packaged as follows:
(1) In an industrial package (IP-1, IP-
2 or IP-3; §173.411), subject to the limi-
tations of Table 6;
(2) In a DOT Specification 7A
(§178.350 of this subchapter) Type A
package;
(3) In any Type B(U) or B(M) pack-
aging authorized pursuant to §173.416;
(4) In a packaging which meets the
requirements of §§173.24, 173.24a, and
173.410. but only for domestic transpor-
tation of an exclusive use shipment
that Is less than an A2 quantity.
(5) For exclusive use transport of liq-
uid LSA-I only, in either:
(i) Specification 103CW, 111A60W7
(§§173.31, and 179.201-1 to 179.201-11 of
this subchapter) tank cars. Bottom
openings in tanks are prohibited; or
(ii) Specification MC 310, MC 311, MC
312, MC 331 or DOT 412 (§178.348 or
§178.337 of this subchapter) cargo tank
motor vehicles. Bottom outlets are not
authorized. Traller-on-flat-car service
is not authorized.
(c) LSA material and SCO in groups
LSA-I and SCO-I may be transported
unpackaged under the following condi-
tions:
(1) All unpackaged material, other
than ores containing only naturally oc-
curring radionuclides, shall be trans-
ported in such a manner that under
normal conditions of transport there
will be no escape of the radioactive
contents from the conveyance nor will
there be any loss of shielding;
(2) Each conveyance must be under
exclusive use, except when only trans-
porting SCO-I on which the contamina-
tion on the accessible and the inacces-
sible surfaces Is not greater than 4.0
Bq/cm^ for beta and gamma emitters
and low toxicity alpha emitters and 0.4
Bq/cm2 for all other alpha emitters;
and
(3) For SCO-I where it is suspected
that non-fixed contamination exists on
inaccessible surfaces in excess of the
values specified in paragraph (c)(2) of
this section, measures shall be taken
to ensure that the radioactive material
is not released into the conveyance or
to the environment.
(d) LSA and SCO that exceed the
packaging limits in this section must
be packaged in accordance with 10 CFR
part 71.
(e) Tables 5 and 6 are as follows:
TABLE 5—CONVEYANCE ACTIVITY LIMITS FOR
LSA MATERIAL AND SCO
Nature of material
1. LSA-I
2. LSA-II and LSA-ltl; Non-combustible solids .
Activity limit for convey-ances
No limit.
No limit.
649
§173.428 49 CFR Ch. I (10-1-09 Edition)
TABLE 5—CONVEYANCE ACTIVITY LIMITS FOR
LSA MATERIAL AND SCO—Continued
Activity
Nature of material limit for
convey-ances
3. LSA-II and LSA-III; Combustible solids and all 100 A2
liquids and gases.
4. SCO 100 A: 100 A:
TABLE 6—INDUSTRIAL PACKAGE INTEGRITY
REQUIREMENTS FOR LSA MATERIAL AND SCO
Contents
Industrial pack-aging type
Contents Exclu-sive
use ship-ment
Non exclu-
sive
use ship-ment
1. LSA-I:
Solid IP-1 ... IP-1
Liquid IP-1 ... IP-2
2. LSA-II;
Solid IP-2 ... IP-2
Liquid and gas IP-2 ... IP-3
3. LSA III IP-2 ... IP-3
4. SCO-I lP-1 ... IP-1 5. SCO-II IP-2 ... IP-2
[69 FR 3676, Jan. 26, 2004 ; 69 FR 55118, Sept. 13, 2004; 69 FR 58843, Got, 1, 2004: 70 FR 56098, Sept. 23, 2005]
§173.428 Empty Class 7 (radioactive) materials packaging.
A packaging which previously con-
tained Class 7 (radioactive) materials
and has been emptied of contents as far
as practical, is excepted from the ship-
ping paper and marking (except for the
UN identification number marking re-
quirement described in § 173.422(a)) re-
quirements of this subchapter, pro-
vided that—
(a) The packaging meets the require-
ments of § 173.421(a) (2), (3), and (5) of
this subpart;
(b) The packaging Is in unimpaired
condition and is securely closed so that
there will be no leakage of Class 7 (ra-
dioactive) material under conditions
normally incident to transportation;
(c) The outer surface of any uranium
or thorium in its structure is covered
with an inactive sheath made of metal
or some other substantial material;
(d) Internal contamination does not
exceed 100 times the limits in
§ 173.443(a);
(e) Any labels previously applied in
conformance with subpart E of part 172
of this subchapter are removed, obliter-
ated, or covered and the "Empty" label
prescribed in § 172.450 of this subchapter
is affixed to the packaging; and
(f) The packaging is prepared for
shipment as specified in §173.422.
[Amdt. 173-244 , 60 FR 50307, Sept. 28, 1995, as
amended by Amdt. 173-244, 61 FR 20752, May
8, 1996; 64 FR 51919. Sept. 27, 1999; 69 FR 3677,
Jan. 26, 2004]
§ 173.431 Activity limits for Type A and Type B packages.
(a) Except for LSA material and SCO,
a Type A package may not contain a
quantity of Class 7 (radioactive) mate-
rials greater than Ai for special form
Class 7 (radioactive) material or A2 for
normal form Class 7 (radioactive) ma-
terial as listed in §173.435, or, for Class
7 (radioactive) materials not listed in
§173.435, as determined in accordance
with §173.433.
(b) The limits on activity contained
in a Type B(U) or Type B(M) package
are those prescribed in §§173.416 and
173.417, or in the applicable approval
certificate under §§173.471, 173.472 or
173.473.
[Amdt. 173-244, 60 FR 50307, Sept. 28, 1995, aa
amended at 69 FR 3677, Jan. 26 , 2004]
§ 173.433 Requirements for deter-mining basic radionuclide values,
and for the listing of radionuclides
on shipping papers and labels.
(a) For individual radionuclides list-
ed in the table in §173.435 and §173.436:
(1) Al and A2 values are given in the
table in § 173.435; and
(2) Activity concentration exemption
values and consignment activity ex-
emption values are given in the table
in § 173.436.
(b) For individual radionuclides
which are not listed In the tables in
§173.435 or §173.436:
(1) the radionuclide values in Tables 7
or 8 of this seotion may be used; or
(2) other basic radionuclide values
may be used provided they are first ap-
proved by the Associate Administrator
or, for international transport, multi-
lateral approval is obtained from the
pertinent Competent Authorities.
(c) In calculating Ai or A2 values for
a radionuclide not listed in the table in
§173.435:
650
Hazard Communications for Class 7 (Radioactive) Materials
Shipping Papers (49 CFR Part 172, Subpart C)
NOTE: IAEA, ICAO, and iMO may require additional hazard communication information for international shipments. This table must not be used as a substitute for the DOT and NRC regulations on the transportation of radioactive materials.
Entries Alvyays Required Entries Sometimes Required Optional Entries
The basic description, in sequence:
Proper Sliipping Name,
Hazard Class (7),
U.N. Identification Number
[§ 172.202(a)&(b)]
Proper page numbering
(i.e.. Page 1 of 4) [§172.201(c))]
24 hour emergency response
telephone number (Use of a number
that requires a call back - e.g.,
answering machine - is not authorized)
[§§ 172.201(d) and 172.604]
The total quantity of the material
described (mass, volume, or activity) in
appropriate units (Ibs, mL . . .)
[§172.202(a)(5)]
The number and type of pacl^ages
[§172.202(a)(6)]
The name of each radionuclide (as
determined by §173.433(g)). The
activity must be in SI units (e.g., Bq,
TBq), and may be in customary units
(e.g., Ci, mCi) in parentheses following
SI units. Abbreviations are authorized.
[§172.203(d)(1)&(3)]
If not special form, a description of
chemical and physical form
[§172.203(d)(2)]
For each labeled paclcage:
- The category of label used;
- The transport index of each
package with a Yellow-ll or Yellow-
Ill label [§172.203(d)(5)]
- The criticality safety index of a
package with a Fissile label
[§172.203(d)(6)]
Shipper's certification (not required
for private carriers) and signature
[§172.204]
Materials-Based Requirements:
If Hazardous substance (§171.8), "RQ" as part
ofthe basic description [§172.203(c))(2)]
"Highway Route Controlled Quantity" or
"HRCQ", entered in association with the basic
description [§172.203(d)(10)]
For a package containing fissile material, the
words "Fissile Excepted", ifthe package Is
excepted by §173.453 or otherwise the
criticality safety index for that package [§
172.203(d)(6)]
If the material is considered hazardous waste
and the word "waste" does not appear in the
shipping name, then "waste" must precede the
shipping name (e.g.. Waste Radioactive
material, Type A package, 7, UN2915)
[§172.101(c))(9)]
Package-Based Requirements:
Package identification marking for DOE or NRC
certified packages [§172.203(d)(7)]
IAEA Certificate of Competent Authority ID
number for export shipments or shipments
using foreign-made packaging (see §173.473)
[§172.203(d)(8)]
Administrative-Based Requirements:
"Exclusive Use-Shipment" [§ 172.203(d)(9)]
If a DOT exemption is being used, "DOT-E"
followed by the exemption number [§
172.203(a)]
"Cargo Aircraft Only" [§ 172.203(f)]
If subsidiary hazard is present, the hazard
class or division number [§ 172.202(a)(2)]
Additional information is
permitted (e.g., functional
description of the product),
provided it is not inconsistent
with the required basic
description [§172.201 (a)(4)]
Except for Pu-239 and Pu-241,
the weight in g or kg of fissile
radionuclides may be inserted
instead of activity units. For
Pu-239 and Pu-241 the weight
in 9 of fissile radionuclides may
be inserted in addition to
activity units [§ 172.203(d)(3)]
Emergency response
information may be entered on
the shipping papers, or may be
a separate document carried
with the shipping papers
[§ 172.602(b)]
Special Considerations/Exceptions for Shipping Papers
Excepted packages, [e.g., Limited quantity (UN 2910), Instruments or Articles (UN 2911), Manufactured articles of uranium and
thorium (UN 2909), and Empty packages (UN 2908)] are excepted from shipping papers. For limited quantities, this is only true ifthe
limited quantity is not a hazardous substance (RQ) or hazardous waste [§173.422(e)].
Shipping paper accessibility - accident or inspection [§177.817(e)].
For shipments of multiple cargo types, any HAZMAT entries must appear as the first entries on the shipping papers, be designated by
an "X" (or "RQ") in the hazardous material column, or be highlighted in s contrasting color [§172.201(a)].
Instructions for maintenance of exclusive use shipment controls for LSA or SCO material must be included with the shipping papers
[§§ 173,403 and 173.427(a)(6)(iv)].
Shipping paper retention, 375 days [§172.201(e)] for shipper. Each mode of transport has a similar requirement (Rail § 174.24(b); Air
§ 175.30(a)(2); Vessel § 176.24(b); Highway § 178.817(f)). Rev. i October 1,2004
Attachment Description
F Revised Forms Nos. F-23, -25. and -26 of Revision 4.0 of the
Reclamation Plan
G Schedule of Amendments to be Inserted at the Beginning of
Revision 4.0 of the Reclamation Plan (before the Table of
Contents), Indicating the Revisions made to Revision 4.0 of
the Reclamation Plan
Accompanying this letter is a package that contains two copies of each of the items in the
foregoing Attachments. Those copies are to be inserted directly into the two copies of Revision
4.0 of the Reclamation Plan or the 2007 License Renewal Application, as the case may be, that
have previously been provided to the Executive Secretary. In the case of Attachment G, the two
accompanying copies of the Schedule of Amendments are to be inserted at the front of each of
the two copies of Plan (prior to the Table of Contents). This will allow the copies contained in
the Attachments to remain a part of this letter.
Each Interrogatory is shown in italics below, followed by Denison's response to the question
and/or request for information.
1. SECTION I, HEALTH PHYSICS INTEROGATORIES -ROUND 3
1.1 HEALTH PHYSICS ROUND 3 INTERROGATORY STATEMENT-Release Surveys:
Round One Interrogatory Statement 14-17 "Explain how the survey techniques, tlie release standards
used and documentation of surveys of Equipment are sufficient to demonstrate regulatory compliance
and maintain public fiealth and safety. Explain why surveying techniques such as the use of Large
Area Wipes and swipes to look for removable contamination are not being used on all items being
surveyed for release "
Round Two Interrogatory statement 8 "In response to the method outlined in 49 CFR 173.443(a)(1)
Denison Mines states "Using portable alpha detection equipment that measures the combined fixed
and removable contamination is therefore "another method" contemplated by paragraph 2. (49CFR
173.443(a)(2) "equal or greater efficiency"), because the Mill applies the removable contamiruition
standard to a combined reading of fixed and removable contamination" Provide efficiency
calculations to determine the ^ciency of this method Include the survey procedure used, the
efficiency ofthe meters and probes used in relation to U-238. Show that the meters and probes that
are/will be used has the appropriate sensitivity to provide a small enough reading to measure the
required release limits."
Based on marmfacturer calibration sheets and information provided by the site RSO, Cs-137 is used
to calibrate the Ludlum Model-3 meters with the 44-9 GM pancake probes, thus they are not
calibrated for Alpha radiation. Also Sr-90 is used to perfonn a function check on the Model-3 meters
with 44-9 GM pancake probes. Both Cs-137 and Sr-90 are high energy Beta emitters and will
produce a higher efficiency than U-238, thus they are inappropriate to use for calibration or function
tests. Re-evaluate the efficiency for the Ludlum Model-3 survey meters with the 44-9 GM pancake
probe using U-238 or equivalent alpha source.
DENISOl
MINES
BASIS FOR INTERROGATORY:
During the review of the calculations provided by Denison Mines, the reviewer requested
additional information from the Site RSO. The reviewer requested copies of the calibration
information and what sources were used when performing function checks on survey
instruments. In addition the reviewer contacted Ludlum to find out what the typical efficiency for
U-238 for Ludlum Model-3 survey meters with the 44-9 GM pancake probe. Ludlums response
was 15%. Using 15% in the same calculations that Denison Mines used in their response, the
Ludlum Model-3 survey meters with the 44-9 GM pancake probe is not sensitive enough to detect
U-238 at the applicable regulatory levels. A different meter and/or probe may need to be used to
do release surveys for ore trucks. (See attached emails)
Example: Using 15% efficiency and background used in Denison example.
MDC= 3 + 4.65 X <[J8b = 2906 dpm/lOOcm^ Alpha I
(1)(0.15)(0.15)
Denison Response:
Denison agrees that the alpha MDC for the Ludlum Model-3 survey meter with a 44-9 GM
pancake probe is 2,906 dpm/lOOcm^. However, when that meter and probe are used to measure
contamination on an ore truck or other equipment, it is reading both alpha and beta. A combined
alpha and beta reading of less than 2,906 would be indicated as a non-detect. In the 14
radionuclides in the U-238 decay series in uranium ores, there are eight alpha particle and six
beta particle emitters. Considering that the 44-9-GM probe is more sensitive to beta radiation,
the total count rate could be considered roughly equally divided between alpha and beta counts.
Therefore, a total count reading of non-detect (<2,200 dpm/lOOcm^) would mean that, for ore
trucks, the total alpha contamination would be less than about 1,500 dpm/lOOcm^ This is less
than the DOE standard for restricted release of 2,200 dpm/IOOcm" alpha. The Mill's practice
with these detectors is to send equipment back for re-decontamination if the meter shows any
reading higher than non-detect. For these reasons, Denison is comfortable that the release
criteria for ore trucks and intermodal containers etc. have been applied conservatively at the site.
However, Denison realizes that the use of a combined alpha/beta meter such as the Ludlum
Model-3 survey meter with a 44-9 GM pancake probe has raised some concems. As a result,
commencing on or before April 30, 2010, Denison will use alpha detectors (as opposed to
alpha/beta detectors) with the same or equal efficiency as the alpha detectors currently being
used at the Mill for surveying equipment for unrestricted release at the site, such as the Ludlum
Model 177 counter and 43-5 alpha detector, for measuring potential alpha contamination on
trucks and other vehicles and equipment.
Methods to estimate the MDA (minimum detectable activity) for survey instruments and
counters are discussed in NRCS NUREG-1507 (Minimum Detectable Concentrations with
Typical Radiation Survey Instruments for Various Contaminants and Field Conditions, 1998).
DENISO
MINES
From NUREG-1507 (Equation 3-10), the following is given for the MDA when measuring
surface contamination:
^P^^3 + 4.65VCB
Kt
Where:
MDA = minimum detectable activity in disintegrations/min/100 cm ;
CB = background count rate (cpm);
t = counting time (min); and
K = proportionality constant which includes adjustments for detector efficiency and geometry
(e.g. coverage relative to 100 cm^).
Typical Denison data for the Model 177 counter with 43-5 alpha detector are:
Background count rate (CB) = 20 cpm
Background counting time (t) = 1 min !
Detector alpha efficiency = 11 % (0.11) 1
Probe active area = 50 cm^ (or 0.50 of 100 cm^ area under consideration)
Using these values in Equation (1), the MDA is estimated as:
3-1-4.65V2O MDA = (0.11x0.50x1)
= 430 dpm/100 cm (rounded to two significant figures).
This MDA is well below both the 49 CFR173.443 standard of 22 dpm/cm^ (2200 dpm/100 cm^)
for non-fixed alpha contamination for restricted release of ore trucks and other equipment, and
NRC's 1000 dpm/100 cm^ standard for non-fixed alpha contamination for unrestricted release of
trucks and all other equipment from the Mill's restricted area (see NRC Regulatory Guide 8.30,
Health Physics Surveys in Uranium Recovery Facilities at Table 2 and Section 2.7).
2. SECTION 2, ENGINEERING COMMENT INTERROGATORIES - ROUND 1
2,1 INTERROGA TORY STA TEMENT - The Reclamation Plan:
I-B DRC Round 1 dated July 2. 2009:
Please update and complete the Section 8 of the License Renewal Application, regarding the
Reclamation Plan. Please include the current approved version of the Reclamation Plan as an
Appendix to the License Renewal Application.
DUSA Responded by Submitting a Letter dated Ausust 14, 2009. statins Revision 4.0 of the
Reclamation Plan would be forthcoming. Revision 4.0 of the plan was sent by DUSA by letter
dated November 24. 2009:
DENISO
MINES
§172.200
plastic bags, plastic film bags, textile bags, paper bags, IBCs and bulk packagings.
W41 When offered for transportation by
water, this material must be packaged In bales and be securely and tightly bound
with rope, wire or similar means,
[Amdt. 17^-123, 55 FR 52582, Dec. 21, 1990]
EorroRiAL NOTE: For FEDERAL REGISTER cl-
. tatlons affecting §172.102, see the List of CFR
Sections Affected which appears in the Find-,' ing Aids section of the printed volume and
on GPO Access.
Subpart C—Shipping Papers
§ 172.200 Applicability.
(a) Description of hazardous materials
required. Except as otherwise provided
in this subpart, each person who offers
a hazardous material for transpor-
tation shall describe the hazardous ma-
terial on the shipping paper in the
manner required by this subpart.
(b) This subpart does not apply to
any material, other than a hazardous
substance, hazardous waste or marine
pollutant, that is—
(1) Identified by the letter "A" In col-
umn 1 of the §172.101 table, except
when the material is offered or In-
tended for transportation by air; or
(2) Identified by the letter "W" in
column 1 of the §172.101 table, except
when the material is offered or in-
tended for transportation by water; or
(3) An ORM-D, except when the mate-
rial is offered or intended for transpor-
tation by air.
[Amdt, 172-29A, 41 FR 40677, Sept. 20, 1976, as amended by Amdt, 172-58, 45 FR 34697, May
22. 1980; Amdt. 172-74. 47 FR 43065. Sept, 30, 1982; Amdt, 172-112, 53 FR 17160. May 13. 1988;
Amdt. 172-127, 57 FR 52938, Nov. 5. 1992]
§ 172.201 Preparation and retention of shipping papers.
f(3L^^Gcintmuyj.VJjkeni.a, j.'descrlptlp_n_- 6t^
hazardous material is required to be in-
cluded on a shipping paper, that de-
scription must conform to the fol-
lowing requirements:
(1) When a hazardous material and a
material not subject to the require-
ments of this subchapter are described
on the same shipping paper, the haz-
ardous material description entries re-
quired by §172.202 and those additional
entries that may be required by
§172.203:
49 CFR Ch. I (10-1-05 Edition)
(1) Must be entered first, or
(li) Must be entered in a color that
clearly contrasts with any description
on the shipping paper of a material not
subject to the requirements of this sub-
chapter, except that a description on a
reproduction of a shipping paper may
be highlighted, rather than printed, in
a contrasting color (the provisions of
this paragraph apply only to the basic
description required by § 172.202(a)(1),
(2), (3), and (4)), or
(111) Must be identified by the entry
of an "X" placed before the proper
shipping name In a column captioned
"HM." (The "X" may be replaced by
"RQ," if appropriate.)
(2) The required shipping description
on a shipping paper and all copies
thereof used for transportation pur-
poses, must be legible and printed
(manually or mechanically) in English.
(3) Unless it Is specifically authorized
or required in this subchapter, the re-
quired shipping description may not
contain any code or abbreviation.
(4) A shipping paper may contain ad-
ditional information concerning the
material provided the information is
not inconsistent with the required de-
scription. Unless otherwise permitted
or required by this subpart, additional
information must be placed after the
basic description required by
§ 172.202(a).
(b) [Reserved]
. (c). Continuation page. A shipping
paper may consist of more than one
page, if each page is consecutively
numbered and the first page bears a no-
'tation specifying the total number of
pages included in the shipping paper.
For example, "Page 1 of 4 pages,"
^( d) r.£mer ffSTic^^re^
befrExcept as provlded In § 172.604(c), a
shipping paper must contain an emer-
gency response telephone number, as
prescribedjn subpart G of this part.
(e)J]gach-perfs6n Avhojpr
plng^paperlmust - retain - a -cgpy.^of" the
siiipping paper Teq'uife(i'"b'y §172,200(a),
or an electronic image thereof, that is
accessible at or through its principal
place of business and must make the
shipping paper available, upon request,
to an authorized official of a Federal,
State, or local government agency at
reasonable times and locations. For a
hazardous waste, the shipping paper
348
Pipeline and Hazardous Materials Safety Admin., DOT §172.202
copy must be retained for three years
after the material is accepted by the
initial carrier. For all other hazardous
materials, the shipping paper copy
must be retained for 375 days after the
material is accepted by the Initial car-
rier. Each shipping paper copy must in-
clude the date of acceptance by the ini-
tial carrier, except that, for rail, ves-
sel, or air shipments, the date on the
shipment waybill, airbill, or bill of lad-
ing may be used in place of the date of
acceptance by the Initial carrier. A
motor carrier (as defined in §390,5 of
subchapter B of chapter III of subtitle
B) using a shipping paper without
change for multiple shipments of one
or more hazardous materials having
the same shipping name and identifica-
tion number may retain a single copy
of the shipping paper, instead of a copy
for each shipment made, if the carrier
also retains a record of each shipment
made, to include shipping name, identi-
fication number, quantity transported,
and date of shipment.
[Amdt, 172-29A, 41 FR 40677, Sept. 20, 1976]
EDITORIAL NOTE; For FEDERAL REGISTER ci-tations affecting §172,201, see the List of CFR Sections Affected which appears in the Find-
ing Aids section of the printed volume and on GPO Access.
§ 172.202 Description of hazardous ma-
terial on shipping papers.
^(aO^Tlie^shipping descrlptlon-of.a.haz][7
ardous material on the shipping paper
must Includ^^
(1 )^Th_e~__ proper., shrpplng-nameofe-7
scJllDed-fgr^^thejjnaterlahln-coliirn'
the §mj^l_table;
(2)-TWeTha5afd"-class^F^dlvislon-ni^
ber prescribed for the material, as
shown in Column (3) of the §172.101
Table, Except for combustible liquids,
the subsidiary hazard class(es) or sub- '
sidiary division number(s) must be en-
tered in parentheses immediately foi-.
lowing the primary hazard class or di-
vision number.
In addition—
(I) The words "Class" or "Division"
may be included preceding the primary
and subsidiary hazard class or division
numbers,
(II) The hazard class need not be in-
cluded for the entry "Combustible liq-
uid, n,o,s.".
(iii) For domestic shipments, pri-
mary and subsidiary hazard class or di-
vision names may be entered following
the numerical hazard class or division,
or following th^basl£ description.
(3) 3TOeTl'dentl'flcatl6n-^number.::c,pre--P
scrlbed~for the material as shown in
column 4 of the §172,101^able;
(4) 'The packing group in; Roman nil;"?
meralsras designated for the hazardous
material in Column 5 of the §172.101
Table. Class 1 (explosives) materials,
self-reactive substances, organic perox-
ides and entries that are not assigned a
packing group are excepted from this
requirement. The packing group may
be preceded by the letters "PG" (for
example^"PG II"); and _^
IJh) The "to tal "quairti tyj;;of;ifazardou,s
materials covered by the description
must be indicated (by mass or volume,
or by activity for Class 7 materials)
and must Include an Indication of the
applicable unit of measurement. For
example, "200 kgs." or "50 L." The fol-
lowing provisions also apply:
(i) For Class 1 materials, the quan-
tity must be the net explosive mass.
For an explosive that is an article,
such as Cartridges, small arms, the net
explosive mass may be expressed in
terms of the net mass of either the ar-
ticle or the explosive materials con-
tained in the article.
(II) For hazardous materials in sal-
vage packaging, an estimate of the
total quantity is acceptable,
(III) The following are excepted from
the requirements of paragraph (a)(5) of
this section:
(A) Bulk packages, provided some in-
dication of the total quantity is shown,
for example, "1 cargo tank" or "2
IBCs,"
(B) Cylinders, provided some indica-
tion of the total quantity is shown, for
example, "10 cylinders".
(C) Packages containing only residue.
(BfTlfeTimmbeFa^
must""be Indicated, The type of pack-""
ages must be Indicated by description
of the package (for example, "12
drums"). Indication of the packaging
specification number ("IHl") may be
included in the description of the pack-
age (for example, "12 IHl drums" or "12
drums (UN lAl)," Abbreviations may
be used for indicating packaging types
(for example, "cyl." for "cylinder")
349
§ 172.203 49 CFR Ch. I (10-1-05 Edition)
provided the abbreviations are com-
monly accepted and recognizable.
(b) Except as provided In this sub-
part, the basic description specified in
paragraphs (a)(1), (2), (3) and (4) of this
section must be shown in sequence
with no additional information inter-
spersed. For example, "Cyclobutyl
chloroformate, 6.1, (8,3), UN2744, PG
II", Alternatively, the basic descrip-
tion may be shown with the identifica-
tion (ID) number listed first. For exam-
ple, "UN2744, Cyclobutyl
chloroformate, 6,1, (8, 3), PG II."
(c) The total quantity of the material
covered by one description must appear
before or after, or both before and
after, the description required and au-
thorized by this subpart. The type of
packaging and destination marks may
be entered in any appropriate manner
before or after the basic description.
Abbreviations may be used to express
units of measurement and types of
packagings,
(d) Technical and chemical group
names may be entered in parentheses
between the proper shipping name and
hazard class or following the basic de-
scription. An appropriate modifier,
such as "contains" or "containing,"
and/or the percentage of the technical
constituent may also be used. For ex-
ample; "Flammable liquids, n.o.s, (con-
tains Xylene and Benzene), 3, UN 1993,
II".
(e) Except for those materials in the
UN Recommendations, the ICAO Tech-
nical Instructions, or the IMDG Code
(IBR, see §171.7 of this subchapter), a
material that is not a hazardous mate-
rial according to this subchapter may
not be offered for transportation or
transported when its description on a
shipping paper includes a hazard class
or an identification number specified
in the §172.101 Table.
[Amdt, 173-101, 45 FR 74665. Nov. 10. 1980, as
amended by Amdt, 172-103, 51 FR 5970, Feb.
18, 1986; Amdt. 172-123 , 55 FR 52589, Dec. 21,
1990; 56 FR 66252, Dec. 20, 1991; Amdt. 172-127,
57 FR 52938, Nov. 5, 1992; Amdt. 172-130, 58 FR
51531, Oct. 1, 1993; 66 FR 33425, June 21, 2001;
68 FR 45030, July 31, 2003; 68 FR 75741, Dec. 31,
2003: 69 FR 34611, June 22, 2004; 69 FR 54046,
Sept, 7, 2004; 69 FR 76153, Dec, 20, 2004: 70 FR
34397, June 14, 2005]
§ 172.203 Additional description re-
quirements.
(a) Exemplions. Each shipping paper
Issued in connection with a shipment
made under an exemption must bear
the notation "DOT-E" followed by the
exemption number assigned and so lo-
cated that the notation is clearly asso-
ciated with the description to which
the exemption applies.
(b) Limited quantities. The description
for a material offered for transpor-
tation as "limited quantity." as au-
thorized by this subchapter, must in-
clude the words "Limited Quantity" or
"Ltd Qty" following the basic descrip-
tion.
(c) Hazardous substances. (1) Except
for Class 7 (radioactive) materials de-
scribed in accordance with paragraph
(d) of this section, if the proper ship-
ping name for a material that is a haz-
ardous substance does not identify the
hazardous substance by name, the
name of the hazardous substance must
be entered in parentheses in associa-
tion with the basic description. If the
material contains two or more haz-
ardous substances, at least two haz-
ardous substances, including the two
with the lowest reportable quantities
(RQs), must be identified. For a haz-
ardous waste, the waste code (e.g,,
DOOl), if appropriate, may be used to
identify the hazardous substance.
(2) The letters "RQ" shall be entered
on the shipping paper either before or
after, the basic description required by
§172.202 for each hazardous substance
(see definition in §171.8 of this sub-
chapter). For example: "RQ, Allyl alco-
hol, 6,1, UN 1098, I"; or "Environ-
mentally hazardous substance, solid,
n.o.s.. 9, UN 3077^, III, RQ (Adipic acid)".
(d)j^,^Rqdio'active':.fndl'm
.tlon.foFa shlpment-praXjass'Xfradio-
'activel-material"'must Include the fol-
lowing additional entries as appro-
priate:
(l-)-Th_e£nam_e"of-each ra4^
the'Class 7 (radlbact'ive)'material that
is listed in §173,435 of this subchapter.
For mixtures of radionuclides, the
radionulides that must be shown must
be determined In accordance with
§ 173.433(g) of this subchapter. Abbre-
viations, e.g.,J'^Mo," are authorized.
5^2)7J^escnMionZ6f.^Ker
cheiTiioal form of the material, if^the
350
Pipeline and Hazardous Materials Safety Admin., DOT §172.203
material is not in special form (generic
chemical description is acceptable for
chemical form),
(3) _,The..;actiyity^cpntained--in,..each
pa'cka;ge~of ^he shipment' in~terms ''6f
the appropriate , SL-;.--units (e.g.,
Becquerels (Bq), Terabecqiierels (TBq),
etc.). The activity may also be stated
in appropriate customary units (Curies
(Ci), milliCuries (mCi), microCuries
(uCi), etc) in parentheses following the
SI units. Abbreviations are authorized.
Except for plutonium-239 and pluto-
nlum-241, the weight in grams or kilo-
grams of fissile radionuclides may be
inserted Instead of activity units. For
plutonium-239 and plutonium-241, the
weight in grams of fissile radionuclides
may be inserted in addition to the ac-
tivity units,
(4) The category of label applied to
each package in the shipment. For ex-
ample: "RADIOACTIVE WHITE-I,"
(5) The transport index assigned to
each package in the shipment bearing
RADIOACTIVE YELLOW-II or RADIO-
ACTIVE YELLOW-IIl labels.
(6) For a package containing fissile
Class 7 (radioactive) material:
(I) The words "Fissile Excepted" if
the package is excepted pursuant to
§173,453 of this subchapter; or other-
wise
(II) The criticality safety index for
that package.
(7) For a package approved by the
U.S, Department of Energy (DOE) or
U,S, Nuclear Regulatory Commission
(NRC), a notation of the package iden-
tification marking as prescribed in the
applicable DOE or NRC approval (see
§173.471 of the subchapter).
(8) For an export shipment or a ship-
ment in a foreign made package, a no-
tation of the package identification
marking as prescribed in the applicable
International Atomic Energy Agency
(IAEA) Certificate of Competent Au-
thority which has been issued for the
package (see §173,473 of the sub-
chapter).
(9) For a shipment required by this
subchapter to be consigned as exclusive
use:
(i) An indication that the shipment is
consigned as exclusive use; or
(ii) If all the descriptions on the ship-
ping paper are consigned as exclusive
use, then the statement "Exclusive Use
Shipment" may be entered only once
on the shipping paper in a clearly visi-
ble location,
(10) For the shipment of a package
containing a highway route controlled
quantity of Class 7 (radioactive) mate-
rials (see §173.403 of this subchapter)
the words "Highway route controlled
quantity" or "HRCQ" must be entered
in association with the basic descrip-
tion.
(e) Empty packagings. (1) The descrip-
tion on the shipping paper for a pack-
aging containing the residue of a haz-
ardous material may include the words
"RESIDUE: Last Contained * * *" in
association with the basic description
of the hazardous material last con-
tained in the packaging,
(2) The description on the shipping
paper for a tank car containing the res-
idue of a hazardous material must in-
clude the phrase, "RESIDUE: LAST
CONTAINED * * *" before the basic de-
scription,
(f) Transportation by air. A statement
indicating that the shipment is within
the limitations prescribed for either
passenger and cargo aircraft or cargo
aircraft only must be entered on the
shipping paper,
(g) Transportation by rail (1) A ship-
ping paper prepared by a rail carrier
for a rail car, freight container, trans-
port vehicle or portable tank that con-
tains hazardous materials must include
the reporting mark and number when
displayed on the rail car, freight con-
tainer, transport vehicle or portable
tank.
(2) The shipping paper for each DOT-
113 tank car containing a Division 2,1
material or its residue must contain an
appropriate notation, such as "DOT
113", and the statement "Do not hump
or cut off car while in motion,"
(3) When shipments of elevated tem-
perature materials are transported
under the exception permitted in
§173,247(h)(3) of this subchapter, the
shipping paper must contain an appro-
priate notation, such as "Maximum op-
erating speed 15 mph.".
(h) Transportation by highway. Fol-
lowing the basic description for a haz-
ardous material in a Specification MC
330 or MC 331 cargo tank, there must be
entered for—
351
§172.203 49 CFR Ch. I (10-1-05 Edition)
(1) Anhydrous ammonia, (i) The words
"0.2 PERCENT WATER" to indicate
the suitability for shipping anhydrous
ammonia in a cargo tank made of
quenched and tempered steel as author-
ized by § 173.315(a), Note 14 of this sub-
chapter, or
(ii) The words "NOT FOR Q and T
TANKS" when the anhydrous ammonia
does not contain 0.2 percent or more
water by weight.
(2) Liquefied petroleum gas. (i) The
word "NONCORROSIVE" or
"NONCOR" to Indicate the suitability
for shipping "Noncorrosive" liquefied
petroleum gas in a cargo tank made of
quenched and tempered steel as author-
ized by § 173.315(a), Note 15 of this sub-
chapter, or
(11) The words "NOT FOR Q and T
TANKS" for grades of liquefied petro-
leum gas other than "Noncorrosive".
(1) Transportation by water. Each ship-
ment by water must have the following
additional shipping paper entries;
(1) The name of the shipper.
(2) Minimum flash point if 61 °C or
below (in °C closed cup (cc.) In associa-
tion with the basic description,
(3) For a hazardous material con-
signed under an "n.o.s," entry not in-
cluded in the segregation groups listed
in section 3.1.4 of the IMDG Code but
belonging, in the opinion of the con-
signor, to one of these groups, the ap-
propriate segregation group must be
shown in association with the basic de-
scription (for example, IMDG Code seg-
regation group—1 Acids). When no seg-
regation group is applicable, there is
no requirement to indicate that condi-
tion,
(j) [Reserved]
(k) Technical names for "n.o.s." and
other generic descriptions. Unless other-
wise excepted, if a material is de-
scribed on a shipping paper by one of
the proper shipping names identified by
the letter "G" in column (1) of the
§172.101 Table, the technical name of
the hazardous material must be en-
tered in parentheses in association
with the basic description. For example
"Corrosive liquid, n,o,s,, (Octanoyl
chloride), 8, UN 1760, II", or "Corrosive
liquid, n.o.s., 8, UN 1760, II (contains
Octanoyl chloride)". The word "con-
tains" may be used in association with
the technical name, if appropriate. For
organic peroxides which may qualify
for more than one generic listing de-
pending on concentration, the tech-
nical name must include the actual
concentration being shipped or the con-
centration range for the appropriate
generic listing. For example, "Organic
peroxide type B, solid, 5.2, UN 3102
(dibenzoyl peroxide, 52-100%)" or "Or-
ganic peroxide type E, solid, 5,2, UN
3108 (dibenzoyl peroxide, paste, <52%)".
Shipping descriptions for toxic mate-
rials that meet the criteria of Division
6,1, PG I or II (as specified in §173,132(a)
of this subchapter) or Division 2.3 (as
specified in §173.115(cj of this sub-
chapter) and are identified by the let-
ter "G" in column (1) of the §172,101
Table, must have the technical name of
the toxic constituent entered in paren-
theses in association with the basic de-
scription,
(1) If a hazardous material is a mix-
ture or solution of two or more haz-
ardous materials, the technical names
of at least two components most pre-
dominately contributing to the hazards
of the mixture or solution must be en-
tered on the shipping paper as required
by paragraph (k) of this section. For
example, "Flammable liquid, corrosive.
n,o,s,. 3, UN 2924, II (contains Meth-
anol, Potassium hydroxide)",
(2) The provisions of this paragraph
do not apply—
(i) To a material that is a hazardous
waste and described using the proper
shipping name "Hazardous waste, liq-
uid or solid, n.o.s,". classed as a mis-
cellaneous Class 9. provided the EPA
hazardous waste number is Included on
the shipping paper in association with
the basic description, or provided the
material is described in accordance
with the provisions of § 172.203(c) of this
part,
(ii) To a material for which the haz-
ard class is to be determined by testing
under the criteria in §172.101(c)(ll).
(iii) If the n.o.s. description for the
material (other than a mixture of haz-
ardous materials of different classes
meeting the definitions of more than
one hazard class) contains the name of
the chemical element or group which is
primarily responsible for the material
being included in the hazard class indi-
cated.
352
Pipeline and Hazardous Materials Safety Admin., DOT §172.204
(lv) If the n,o,s, description for the
material (which is a mixture of haz-
ardous materials of different classes
meeting the definition of more than
one hazard class) contains the name of
the chemical element or group respon-
sible for the material meeting the defi-
nition of one of these classes. In such
cases, only the technical name of the
component that is not appropriately
Identified in the n.o.s, description shall
be entered in parentheses.
(1) Marine pollutants. (1) If the proper
shipping name for a material which is
a marine pollutant does not identify by
name the component which makes the
material a marine pollutant, the name
of that component must appear in pa-
rentheses in association with the basic
description. Where two or more compo-
nents which make a material a marine
pollutant are present, the names of at
least two of the components most pre-
dominantly contributing to the marine
poUutant designation must appear in
parentheses in association with the
basic description.
(2) The words "Marine Pollutant"
shall be entered in association with the
basic description for a material which
is a marine pollutant.
(3) Except for transportation by ves-
sel, marine pollutants subject to the
provisions of 49 CFR 130,11 are excepted
from the requirements of paragraph (1)
of this section if a phrase indicating
the material is an oil is placed in asso-
ciation with the basic description,
(4) Except when transported aboard
vessel, marine pollutants in non-bulk
packagings are not subject to the re-
quirements of this subchapter (see
§ 171.4 of this subchapter),
(m) Poisonous Materials. Notwith-
standing the hazard class to which a
material is assigned, for materials that
are poisonous by Inhalation (see §171.8
of this subchapter), the words "Poison-
Inhalation Hazard" or •'Toxic-Inhala-
tion Hazard" and the words "Zone A",
"Zone B", "Zone C", or "Zone D" for
gases or "Zone A" or "Zone B" for liq-
uids, as appropriate, shall be entered
on the shipping paper immediately fol-
lowing the shipping description. The
word "Poison" or "Toxic" need not be
repeated if it otherwise appears in the
shipping description.
(n) Elevated temperature materials. If a
liquid material in a package meets the
definition of an elevated temperature
material in §171,8 of this subchapter,
and the fact that it is an elevated tem-
perature material Is not disclosed in
the proper shipping name (for example,
when the words "Molten" or "Elevated
temperature" are part of the proper
shipping name), the word "HOT" must
immediately precede the proper ship-
ping name of the material on the ship-
ping paper,
(0) Organic peroxides and self-reactive
materials. The description on a shipping
paper for a Division 4,1 (self-reactive)
material or a Division 5.2 (organic per-
oxide) material must include the fol-
lowing additional information, as ap-
propriate:
(1) If notification or competent au-
thority approval is required, the ship-
ping paper must contain a statement of
approval of the classification and con-
ditions of transport.
(2) For Division 4.1 (self-reactive) and
Division 5.2 (organic peroxide) mate-
rials that require temperature control
during transport, the control and emer-
gency temperature must be Included on
the shipping paper,
(3) The word "SAMPLE" must be in-
cluded in association with the basic de-
scription when a sample of a Division
4,1 (self-reactive) material (see
§ 173.224(c)(3) of this subchapter) or Di-
vision 5,2 (organic peroxide) material
(see §173,225(b)(2) of this subchapter) is
offered for transportation.
[Amdt. 172-29A, 41 FR 40677, Sept. 20, 19761
EDITORIAL NOTE: For FEDERAL REGISTER ci-
tations affecting §172,203, see the List of CFR
Sections Affected which appears in the Find-ing Aids section of the printed volume and
on GPO Access.
§ 172.204 Shipper's certification.
(a) General. Except as provided in
paragraphs (b) and (c) of this section,
each person who offers a hazardous ma-
terial for transportation shall certify
that the material is offered for trans-
portation in accordance with this sub-
chapter by printing (manually or me-
chanically) on the shipping paper con-
taining the required shipping descrip-
tion the certification contained in
paragraph (a)(1) of this section or the
certification (declaration) containing
353
§172.204 49 CFR Ch. I (10-1-05 Edition)
the language contained in paragraph
(a)(2) of this section.
(1) "This is to certify that the above-
named materials are properly classi-
fied, described, packaged, marked and
labeled, and are in proper condition for
transportation according to the appli-
cable regulations of the Department of
Transportation.''
NOTE: in line one of the certification the words "herein-named" may be substituted
for the words "above-named".
(2) "I hereby declare that the con-
tents of this consignment are fully and
accurately described above by the prop-
er shipping name, and are classified,
packaged, marked and labelled/plac-
arded, and are in all respects in proper
condition for transport according to
applicable international and national
governmental regulations,"
(b) Exceptions. (1) Except for a haz-
ardous waste, no certification is re-
quired for a hazardous material offered
for transportation by motor vehicle
and transported:
(1) In a cargo tank supplied by the
carrier, or
(ii) By the shipper as a private car-
rier except for a hazardous material
that is to be reshipped or transferred
from one carrier to another,
(2) No certification is required for the
return of an empty tank car which pre-
viously contained a hazardous material
and which has not been cleaned or
purged.
(c) Transportation by atr—(1) General.
Certification containing the following
language may be used in place of the
certification required by paragraph (a)
of this section;
I hereby certify that the contents of this
consignment are fully and accurately de-
scribed above by proper shipping name and are classified, packaged, marked and labeled, and in proper condition for carriage by air
according to applicable national govern-mental regulations.
NOTE TO PARAGRAPH (c)(1); In the certifi-cation, the word "packed" may be used in-
stead of the word "packaged" until October 1, 2010,
(2) Certificate in duplicate. Each per-
son who offers a hazardous material to
an aircraft operator for transportation
by air shall provide two copies of the
certification required in this section.
(See §175,30 of this subchapter,)
(3) Additional certification require-
ments. Effective October 1, 2006, each
person who offers a hazardous material
for transportation by air must add to
the certification required In this sec-
tion the following statement:
"I declare that all of the applicable
air transport requirisments have been
met."
(i) Each person who offers any pack-
age or overpack of hazardous materials
for transport by air must ensure that:
(A) The articles or substances are not
prohibited for transport by air (see the
§172.101 Table);
(B) The articles or substances are
properly classed, marked and labeled
and otherwise in a condition for trans-
port as required by this subchapter;
(C) The articles or substances are
packaged in accordance with all the
applicable air transport requirements,
including appropriate types of pack-
aging that conform to the packing re-
quirements and the "A" Special Provi-
sions in §172.102; inner packaging and
maximum quantity per package limits;
the compatibility requirements (see,
for example, §173,24 of this subchapter);
and requirements for closure for both
inner and outer packagings, absorbent
materials, and pressure differential in
§173.27 of this subchapter. Other re-
quirements may also apply. For exam-
ple, single packagings may be prohib-
ited, Inner packaging may need to be
packed in intermediate packagings,
and certain materials may be required
to be transported in packagings meet-
ing a more stringent performance
level,
(ii) [Reserved]
(4) Radioactive malerial. Each person
who offers any radioactive material for
transportation aboard a passenger-car-
rying aircraft shall sign (mechanically
or manually) a printed certificate stat-
ing that the shipment contains radio-
active material intended for use in, or
incident to, research, or medical diag-
nosis or treatment,
(d) Signature. The certifications re-
quired by paragraph (a) or (c) of this
section:
(1) Must be legibly signed by a prin-
cipal, officer, partner, or employee of
the shipper or his agent; and
354
Pipeline and Hazardous Materials Safety Admin., DOT §172.205
(2) May be legibly signed manually,
by typewriter, or by other mechanical
means,
[Amdt. 172-29A. 41 FR 40677, Sept. 20, 1976]
EDITORIAL NOTE: For FEDERAL REGISTER ci-tations affecting §172.204, see the List of CFR Sections Affected which appears in the Find-ing Aids section of the printed volume and
on GPO Access.
§ 172.205 Hazardous waste manifest.
(a) No person may offer, transport,
transfer, or deliver a hazardous waste
(waste) unless an EPA Form 8700-22
and 8700-22A (when necessary) haz-
ardous waste manifest (manifest) is
prepared In accordance with 40 CFR
262.20 and Is signed, carried, and given
as required of that person by this sec-
tion,
(b) The shipper (generator) shall pre-
pare the manifest In accordance with 40
CFR part 262,
(c) The original copy of the manifest
must be dated by, and bear the hand-
written signature of, the person rep-
resenting:
(1) The shipper (generator) of the
waste at the time it is offered for
transportation, and
(2) The initial carrier accepting the
waste for transportation.
(d) A copy of the manifest must be
dated by, and bear the handwritten sig-
nature of the person representing:
(1) Each subsequent carrier accepting
the waste for transportation, at the
time of acceptance, and
(2) The designated facility receiving
the waste, upon receipt,
(e) A copy of the manifest bearing all
required dates and signatures must be:
(1) Given to a person representing
each carrier accepting the waste for
transportation,
(2) Carried during transportation In
the same manner as required by this
subchapter for shipping papers,
(3) Given to a person representing the
designated facility receiving the waste,
(4) Returned to the shipper (gener-
ator) by the carrier that transported
the waste from the United States to a
foreign destination with a notation of
the date of departure from the United
States, and
(5) Retained by the shipper (gener-
ator) and by the initial and each subse-
quent carrier for three years from the
date the waste was accepted by the Ini-
tial carrier. Each retained copy must
bear all required signatures and dates
up to and including those entered by
the next person who received the
waste,
(f) Transportation by rail. Notwith-
standing the requirements of para-
graphs (d) and (e) of this section, the
following requirements apply:
(1) When accepting hazardous waste
from a non-rail transporter, the initial
rail transporter must:
(1) Sign and date the manifest ac-
knowledging acceptance of the haz-
ardous waste;
(11) Return a signed copy of the mani-
fest to the non-rail transporter;
(lii) Forward at least three copies of
the manifest to:
(A) The next non-rail transporter, if
any;
(B) The designated facility, if the
shipment is delivered to that facility
by rail; or
(C) The last rail transporter des-
ignated to handle the waste in the
United States; and
(iv) Retain one copy of the manifest
and rail shipping paper In accordance
with 40 CFR 263,22.
(2) Rail transporters must ensure
that a shipping paper containing all
the information required on the mani-
fest (excluding the EPA identification
numbers, generator certification and
signatures) and, for exports, an EPA
Acknowledgment of Consent accom-
panies the hazardous waste at all
times. Intermediate rail transporters
are not required to sign either the
manifest or shipping paper.
(3) When delivering hazardous waste
to the designated facility, a rail trans-
porter must;
(i) Obtain the date of delivery and
handwritten signature of, the owner or
operator of the designated facility on
the manifest or the shipping paper (if
the manifest has not been received by
the facility); and
(11) Retain a copy of the manifest or
signed shipping paper in accordance
with 40 CFR 263,22.
(4) When delivering hazardous waste
to a non-rail transporter, a rail trans-
porter must:
(i) Obtain the date of delivery and
the handwritten signature of the next
355
§172.300 49 CFR Ch. I (10-1-05 Edition)
non-rail transporter on the manifest;
and
(ii) Retain a copy of the manifest in
accordanoe with 40 CFR 263,22.
(5) Before accepting hazardous waste
from a rail transporter, a non-rail
transporter must sign and date the
manifest and provide a copy to the rail
transporter.
(g) The person delivering a hazardous
waste to an initial rail carrier shall
send a copy of the manifest, dated and
signed by a representative of the rail
carrier, to the person representing the
designated facility.
(h) A hazardous waste manifest re-
quired by 40 CFR part 262. containing
all of the information required by this
subpart, may be used as the shipping
paper required by this subpart.
(i) The shipping description for a haz-
ardous waste must be modified as re-
quired by §172,101(c)(9).
[Amdt, 173-58 , 45 FR 34698, May 22, 1980, as
amended by Amdt, 172-90, 49 FR 10510, Mar,
20, 1984; 49 FR 11184, Mar, 26, 1984; Amdt, 172-
248, 61 FR 28675, June 5, 1996; 70 FR 34075,
June 13, 2005]
Subpart D—Marking
§ 172.300 Applicability.
(a) Each person who offers a haz-
ardous material for transportation
shall mark each package, freight con-
tainer, and transport vehicle con-
taining the hazardous material In the
manner required by this subpart.
(b) When assigned the function by
this subpart, each carrier that trans-
ports a hazardous material shall mark
each package, freight container, and
transport vehicle containing the haz-
ardous material in the manner required
by this subpart.
[Amdt, 172-101. 45 FR 74666, Nov, 10, 1980]
§ 172.301 General marking require-ments for non-bulk packagings.
(a) Proper shipping name and identi-
fication number. (1) Except as otherwise
provided by this subchapter, each per-
son who offers a hazardous material for
transportation in a non-bulk packaging
must mark the package with the prop-
er shipping name and identification
number (preceded by "UN" or "NA," as
appropriate) for the material as shown
in the §172.101 Table. Identification
numbers are not required on pack-
agings that contain only ORM-D mate-
rials or limited quantities, as defined
in §171.8 of this subchapter, except for
limited quantities marked in accord-
ance with the marking requirements In
§172.315.
(2) The proper shipping name for a
hazardous waste, (as defined in §171.8 of
this subchapter) is not required to in-
clude the word "waste" if the package
bears the EPA marking prescribed by
40 CFR 262,32.
(3) Large quantities of a single haz-
ardous material in non-bulk packages. A
transport vehicle or freight container
containing only a single hazardous ma-
terial in non-bulk packages must be
marked, on each side and each end as
specified in the §172,332 or §172,336,
with the identification number speci-
fied for the hazardous material in the
§172.101 Table, subject to the following
provisions and limitations;
(i) Each package is marked with the
same proper shipping name and identi-
fication number;
(11) The aggregate gross weight of the
hazardous material is 4,000 kg (8,820
pounds) or more;
(iii) All of the hazardous material is
loaded at one loading facility;"
(iv) The transport vehicle or freight
container contains no other material,
hazardous or otherwise; and
(v) The identification number mark-
ing requirement of this paragraph (a)(3)
does not apply to Class 1, Class 7, or to
non-bulk packagings for which identi-
fication numbers are not required.
(b) Technical names. In addition to the
marking required by paragraph (a) of
this section, each non-bulk packaging
containing hazardous materials subject
to the provisions of §172.203(k) of this
part shall be marked with the tech-
nical name in parentheses in associa-
tion with the proper shipping name in
accordance with the requirements and
exceptions specified for display of tech-
nical descriptions on shipping papers in
§172.203(k) of this part.
(c) Exemption packagings. The outside
of each package authorized by an ex-
emption shall be plainly and durably
marked "DOT-E" followed by the ex-
emption number assigned.
356
# #
Transportation Policv for Shipments of Colorado Plateau Uranium Ores to
the White Mesa Uranium Mill
Purpose:
The purpose of this policy is to describe the shipping responsibilities and practices to be
employed when shipping uranium ore from a Colorado Plateau mine (the "Mine") by truck to the
White Mesa Uranium Mill (the "Mill"). The policy outlines specific shipping precautions and
necessary documentation to maintain compliance with applicable requirements of the U.S.
Department of Transportation ("DOT") regulations at Title 49 of the Code of Federal
Regulations. Safe transportation of uranium ore from the Mine to the Mill is paramount to
Denison Mines (USA) Corp. ("DUSA"), and strict adherence to this policy is required.
Scope:
This policy encompasses uranium ore shipping and transportation requirements and the specific
responsibilities of the Mine operator/owner, the transport contractor (the "Transportation
Contractor") and Mill personnel with regard to: maintaining exclusive use shipments, personnel
training, vehicle marking, preparation of shipping papers, transportation requirements,
emergency response, radiation control, record retention and other matters.
Policy
1. Summary of Responsibilities
1.1. Mine Operator/Owner Responsibilities
The Mine operator/owner will be responsible for:
• Providing training to Mine operator/owner and/or Transportation Contractor personnel
relating to the appropriate safe handling practices specific to uranium ores during
loading, transport and unloading operations (see Section 3.1.2).
• Ensuring that the required shipping papers are completed, signed, and delivered to the
transport driver (see Section 5).
• Verifying that ore shipments from the Mine are not A2 quantities of Class 7 radioactive
material and hence not subject to certain marking and labeling requirements (see Section
2).
• Ensuring that gamma and removable contamination limits for ore shipments from the
Mine are satisfied (see Sections 8.2 and 8.3).
1.2. Transportation Contractor Responsibilities
Transportation contractor personnel will be responsible for:
• Providing appropriate vehicle markings (see Section 4).
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• Transporting uranium ore to the Mill in accordance with Section 6 below.
• Unloading transported uranium ore at the Mill.
• Maintaining exclusive (sole) use of the transport vehicle for uranium ore shipment and
providing a closed conveyance trailer while shipping uranium ore to the Mill (see
Sections 2 and 6.1).
• Carrying and delivering to the Mill a copy of the shipping papers which will accompany
the uranium ore shipment (see Section 5).
• Ensuring that the training requirements described in Section 3.1.1 are satisfied.
• Preparing and adhering to an Emergency Response Plan (see Section 7).
• Contacting DUSA personnel listed on the shipping documents and providing emergency
response and cleanup personnel should accidental spillage of uranium ore occur during
transport to the Mill (see Section 7).
• Requesting an unrestricted use release survey from Mill radiation safety personnel when
the transport vehicle is planned for uses other than uranium ore haulage (see Section
8.3.2).
1.3. DUSA Responsibilities
DUSA personnel will be responsible for:
• Assisting in emergency response situations if accidental spillage of uranium ore during
transport has occurred (see Section 7).
• Completing radiation surveys of the transport vehicles prior to retum to service for
unrestricted use and shipment of commodities other than uranium ore (see Section 8).
• Signing and retaining all shipping and survey records pertaining to shipments of uranium
ore (see Sections 5 and 9).
2. Classification of Ore and Exclusive Use Shipments
The Colorado Plateau uranium ore that will be shipped from the Mine to the Mill is classified as
Class 7 Radioactive LSA-I "hazardous material" under 49 CFR 171.8. However, shipments of
32 tons or less per trailer will generally not constitute an A2 quantity of any Class 7 radioactive
material, within the meaning of 49 CFR 173.403, due to the relatively low specific activity ofthe
uranium ore. This means that the shipments will generally be exempt from most ofthe marking
and labeling requirements (see Section 2(e)). It is the responsibility ofthe Mine operator/owner
to ensure that ore shipments from the Mine are not A2 quantities of Class 7 radioactive material.
An A2 quantity means that the activity from Unat or from any of its daughters in any ore
shipment exceeds the activity level set out in the table in 49 CFR 173.435.
Although the Colorado Plateau uranium ore will generally not on average have a high enough
specific activity level to constitute a "hazardous substance" under 49 CFR 171.8, DUSA has
concluded that it is nevertheless prudent that shipping papers and an emergency response plan,
normally required only for shipments of hazardous substances under 49 CFR 177.200, 177.817
and 172.600, be required for each load of uranium ore (see Sections 5 and 7 below).
July 5,2007 2 RevO
The uranium ore will be consigned as exclusive use shipments of uranium ore in accordance with
the provisions of 49 CFR 173.427(a)(6) and will be shipped unpackaged in accordance with the
provisions of 49 CFR 173.427(c). Accordingly,
a) Shipments must be loaded by the Mine operator/owner or the Transportation Contractor
at the Mine and unloaded by the Transportation Contractor at the Mill, in accordance
with directions from Mill personnel, from the truck trailer in which it was originally
loaded;
b) The Transportation Contractor must ensure that there is not any leakage of uranium ore
from the truck trailer;
c) Specific instructions for maintenance of exclusive use shipment controls will be
provided by the Mine operator/owner to the Transportation Contractor with the shipping
paper information (see Section 5.2 below);
d) Because the shipments will be of uranium ore, the transport vehicle is not required to be
placarded (see 49 CFR 173.427(a)(6)(v)); and
e) Because shipments of Colorado Plateau uranium ores of 32 tons or less will generally
contain less than an A2 quantity of any Class 7 Radioactive material, the shipments are
generally exempted from the marking and labeling requirements set out in 49 CFR 172
Subparts D and E (see 49 CFR 173.427(a)(6)(vi)), provided that the trailers are marked
"RADIOACTIVE-LSA" in accordance with Section 4(a) below. It is the responsibility
of the Mine operator/owner to ensure that each shipment of ore from the Mine contains
less than an A2 quantity of any Class 7 radioactive material.
3. Training Requirements
3.1. Shipment Personnel
3.1.1. Training Required to be Provided by the Transportation Contractor
In accordance with the requirements of 49 CFR 177.800 and 177.816, each truck driver and any
other Transportation Contractor personnel involved in the loading or unloading of uranium ore
onto and from the uranium ore truck must be trained in the applicable requirements of 49 CFR
parts 390 through 397 and the procedures necessary for the safe operation of the vehicle. Driver
training must include the following subjects:
a) Pre-trip safety inspection;
b) Use of vehicle controls and equipment, including operation of emergency equipment;
c) Operation of vehicle, including turning, backing, braking, parking, handling, and vehicle
characteristics including those that affect vehicle stability, such as effects of braking and
curves, effects of speed on vehicle control, dangers associated with maneuvering through
July 5,2007 3 RevO
curves, dangers associated with weather or road conditions that a driver may experience
(e.g., blizzards mountainous terrain, high winds), and high center of gravity;
d) Procedures for maneuvering tunnels, bridges, and railroad crossings;
e) Requirements pertaining to attendance of vehicles, parking, smoking, routing, and
incident reporting; and loading and unloading of materials.
This training is the responsibility of the Transportation Contractor and may be satisfied by
compliance with the current requirements of a (Commercial Driver's License with a hazardous
materials endorsement.
3.1.2. Additional Training to be Given by the Mine Operator/Owner
It is the responsibility of the Mine operator/owner to ensure that Mine operator/owner and
Transportation Contractor personnel involved in loading, transporting and unloading the
consigned uranium ore shipment also receive additional specialized training relating to the
appropriate safe handling practices specific to uranium ore shipments. A training record will be
documented by the Mine operator/owner.
This training should include at a minimum the following radiation safety topics:
a) basic radiation concepts (alpha, beta and gamma radiation);
b) dust and contamination control measures necessary during loading, unloading and
uranium ore shipment:
• avoid inhalation during loading and unloading operations
• tarpaulin covers and tailgate closure requirements (i.e. closed transport vehicle)
• avoid spillage onto the vehicle during loading operations
• avoid shipment during muddy mine site conditions;
c) vehicle survey requirements to release vehicles for unrestricted use;
d) exclusive use transport provisions; and
e) emergency response contact information in the event of accidental uranium ore spillage
during transport (who should be contacted at DUSA and what information should be
conveyed).
4. Vehicle. Marking
Each exclusive use transport conveyance (trailer) shall be marked as follows:
July 5,2007 4 RevO
a) The words "RADIOACTIVE LSA" must be stenciled or otherwise affixed to the surface
or on a label, tag or sign in 3 inch letters in a conspicuous place on both sides of the
trailer (see Section 2(e) above); and
b) The words "FOR RADIOACTIVE MATERIALS USE ONLY" must be stenciled in 3
inch letters in a conspicuous place on both sides of the trailer (see Section 8.3.1(b)
below).
Such markings must remain affixed to the trailer during the entire period of exclusive use,
regardless of whether the vehicle is loaded with uranium ore or not. These markings can be
removed from the transport trailer only after the vehicle has been surveyed for unrestricted
release at the Mill, at which time the vehicle is free to ship commodities other than uranium ore.
VEHICLES SHALL NOT BE USED FOR THE SHIPMENT OF ANY OTHER
MATERIALS UNLESS THEY HAVE BEEN SURVEYED FOR UNRESTRICTED
RELEASE BY MILL RADIATION SAFETY STAFF. Upon release of any vehicles for
unrestricted use in accordance with the provisions of Section 8.3.2 below. Mill staff will remove
or paint over such markings. However, prior to re-use for transporting uranium ore to the Mill,
such markings must be re-affixed to the trailer by the Transportation Contractor.
5. Shipping Papers
5.1. Material Description & Shipment Information
Each uranium ore shipment must be accompanied with signed shipping papers that comply with
the requirements of 49 CFR Part 172, and shall include, in the case of uranium ore from
Colorado Plateau mines, the following information:
Exclusive Use Shipment
Date of Acceptance:
Shipping Name: Radioactive Material-LSA 1 (non-fissile)
Hazard Class: Class 7
Identification Number: UN 2912
Packaging: Bulk-Unpackaged
Quantity: TBq ( 0.30 Ci)
Radionuclide(s): U-Nat. and associated decay chain progeny
Form: Solid (Unrefined Uranium Ore)
Transport Index:
Emergency Response
Telephone Number:
The shipping papers will be prepared by the Mine owner or operator. The Transportation
Contractor shall ensure that the shipping papers are readily available to, and recognizable by,
authorities in the event of an accident or inspection, in accordance with the requirements of 49
CFR 177.817(e).
July 5,2007 5 RevO
5.2. Exclusive Use Statement
The following exclusive use statement must be printed onto the shipping papers:
This shipment of uranium ore is being shipped as an exclusive (sole) use shipment.
Accordingly, the contents of this shipment must be loaded at the Mine and unloaded
at the White Mesa Mill, absent any unloading or additional loading prior to delivery
at the Mill. The transportation conveyance trailer must be utilized only for
uranium ore transport until such time that Mill personnel conduct a survey of the
interior and exterior of the trailer and determine that the trailer can be released for
unrestricted use. At such time that the trailer is released for unrestricted use, all
markings related to the radioactive material shipment must be removed from the
conveyance trailer.
5.3. Certification
The Mine owner or operator shall certify that the uranium ore is offered for transportation in
accordance with the applicable DOT regulations by printing the following certification on the
shipping papers:
This is to certify that the above-named materials are properly classified, described,
packaged, marked and labeled, and are in proper condition for transportation according to
the applicable regulations of the Department of Transportation.
This certification must be legibly signed by an employee of the Mine operator or owner.
6. Transportation Requirements
6.1. Vehicles to be Kept Closed at all Times
The trailers must be kept closed at all times, when containing uranium ore and when empty, by
use of a tarpaulin or other suitable mechanism, other than loading and unloading (see Section
8.3.1(c) below).
6.2. Transportation Route
The Transportation Contractor shall advise DUSA of the route to be taken from the Mine to the
Mill. It should be noted, however, that shipments of uranium ore are not a "highway route
controlled quantity" within the meaning of 49 CFR 403 and the applicable provisions of Title 49.
6.3. No Unnecessary Delay in Movement of Shipments
As required by 49 CFR 177.800, all shipments of uranium ore to the Mill must be transported
without unnecessary delay, from and including the time of commencement of loading of the
uranium ore until its final unloading at the Mill.
July 5, 2007 6 Rev 0
6.4. Use of Safe Havens
If necessary in order to coordinate delivery times at the Mill, the Transportation Contractor may
designate suitable safe havens for the temporary storage of transportation vehicles along the
transportation route from the Mine to the Mill. The location and use of such safe havens will be
subject to the approval of DUSA.
7. Emergency Response
Emergency response in the event of an accident resulting in the spillage of uranium ore (or other
spillage during transport) is the contractual responsibility of the Transportation Contractor.
DUSA's role in such incidents will be to provide technical support, if required, during the
emergency situation and, if necessary, to verify that cleanup requirements have been met. In
addition, DUSA must be contacted, at the telephone number listed on the Shipping Papers, as
immediately as possible in order to coordinate any necessary reporting to regulatory agencies.
The Transportation Contractor shall prepare an Emergency Response Plan for transportation of
the uranium ore to the Mill, in accordance with 49 CFR 172 Subpart G, and shall provide a copy
of such plan to DUSA for review and approval.
It should be noted that typical uranium grades for Colorado Plateau uranium ores (0.25-0.30%
UaOg) do not represent a "Reportable Quantity". As such, reporting of spills to the National
Response Center is not generally required. However, the National Response Center must be
notified as soon as practical but no later than 12 hours after the occurrence of an incident listed in
49 CFR171.15, such as where the general public is evacuated for one hour or more; a major
transportation artery or facility is closed or shut down for one hour or more or suspected
radioactive contamination occurs. In addition, a written report must be filed by the
Transportation Contractor in accordance with 49 CFR 171.16. These notification requirements,
including contact information, shall be included in the Transportation Contractor's Emergency
Response Plan.
8. Radiation Control
8.1. Gamma Radiation Survey (Transportation Index)
Based upon a typical uranium ore grade of 0.25-0.30 % UsOg for Colorado Plateau uranium ores,
the gamma exposure rate from the transport vehicle is expected to be less than 1 mrem/hr. As a
result, the requirements of 49 CFR 173.427(a)(1) that the extemal dose rate may not exceed an
external radiation level of 1,000 mrem/hr at 3 meters from the unshielded material, and the
requirements of 49 CFR 173.427(a)(5) and 173.441 (a) that under conditions normally incident
to transportation:
• the radiation level does not exceed 200 mrem/hr at any point on the extemal surface of
the package; and
• the transport index does not exceed 10,
July 5,2007 7 RevO
are expected to be satisfied in all cases. It is also expected that the average reading in the
occupied space of each truck cab will not exceed the DOT limit of 2 mrem/hr, specified in 49
CFR 173.441(b)(4).
8.2. Gamma Radiation Survey (Transportation Index)
It is the responsibility of the Mine operator/ovmer to ensure that the radiation levels fall within
the applicable limits summarized in Section 8.1 above At a minimum, the Mine operator/owner
will perform the following surveys at the Mine site on a representative number of uranium ore
shipments from the Mine:
a) A beta/gamma survey will be conducted at various locations on all sides of the transport
vehicle to determine if the radiation level exceeds 200 mrem/hr at any point on the
extemal surface ofthe vehicle;
b) A gamma survey will be conducted at one meter from all sides of the transport trailer.
The average reading in mrem/hr will be recorded as the Transport Index for all uranium
ore shipments from the Mine; and
c) A gamma survey will be conducted within the cab of the transport tractor. The average
reading in mrem/hr will be recorded to verify that the occupied space will not exceed the
2 mrem/hr limit.
These surveys will be recorded and kept on file.
In addition, the Mine operator/owner will perform (and document for the record) spot gamma
surveys on uranium ore shipments from time to time as it deems appropriate in order to ensure
that the regulatory standards are satisfied.
8.3. Removable Contamination Surveys
8.3.1. Vehicles Used Solely for Purposes of Transporting Ore from the Mine to the Mill.
49 CFR 177.843 provides that routine surface contamination surveys are not required at the Mine
site or at the Mill for any vehicle used solely for transporting bulk-unpackaged uranium ore from
the Mine to the Mill provided that:
a) a survey ofthe interior surface ofthe conveyance trailer (when empty) shows that the
radiation dose rate does not exceed 10 mrem/hr on contact or 2 mrem/hr at 1 meter from
the interior surface. Since the conveyance, when filled with uranium ore is not expected
to exceed 2mrem/hr on contact, a surveyed dose rate from the interior surface (or any
other point on an empty trailer) should not exceed these limitations;
b) the vehicles are stenciled with the words "FOR RADIOACTIVE MATERIALS USE
ONLY" as described under Section 4(b) above; and
July 5,2007 8 RevO
. c) the vehicles must be kept closed (such as through the use of a tarpaulin) at all times other
than loading and unloading.
In order to verify that the radiation dose rate of the empty vehicles will not exceed the limits set
forth in paragraph (a) above, and routine surveys to demonstrate compliance with this limit are
not warranted. Mill Radiation Staff will verify (and document for the record) that this is the case
by surveying a representative number ofthe initial vehicles as they are released from the Mill for
retum to the Mine. In performing such surveys. Mill Radiation Staff will follow existing Mill
standard operating procedures.
It should be noted that, in order for vehicles to be released from the Mill site, Mill staff will also
be required to survey the vehicles in accordance with the requirements of Nuclear Regulatoiy
Commission Regulatory Guide 1.86 ("Reg. Guide 1.86"), unless and to the extent exempted by
the Utah Division of Radiation Control. Reg. Guide 1.86 does not apply to releases of vehicles
from the Mine site.
Unless the Transportation Contractor advises Mill staff otherwise, Mill staff will assume that
each vehicle released from the Mill site will be retuming to use solely for transporting uranium
ore from the Mine to the Mill, and will not be released for unrestricted use.
The Transportation Contractor will advise Mill staff prior to sending any vehicle in for repairs or
servicing, so that Mill staff can ensure that the vehicle to be serviced or repaired has been
released for unrestricted use. No vehicle may be sent in for servicing or repair unless it has been
released for unrestricted use by Mill staff.
8.3.2. Vehicles That Will Not be Used Solely for Transporting Ore From the Mine to the Mill
(Free Release)
49 CFR 177.843 provides that each motor vehicle used for transporting uranium ores under
exclusive use conditions in accordance with 49 CFR 173.427(c) must be surveyed with radiation
detection instruments after each use. A vehicle may not be retumed to service (i.e., released
from the Mill for unrestricted release) until the radiation dose rate at every accessible surface is
0.5 mrem/hr or less and the removable (non-fixed) radioactive surface contamination is not
greater than 2,200 dpm/100 cm^ as required under 49 CFR 173.443(a).
As a result, if the Transportation Contractor advises Mill personnel that any particular vehicle
will not be retuming for use solely for purposes of transporting uranium ore from the Mine to the
Mill or is to be sent in for servicing or repairs. Mill Radiation Safety staff will survey the vehicle
prior to releasing it from the Mill site to ensure that it satisfies these criteria, as well as the
applicable provisions of Reg. Guide 1.86. In performing such surveys. Mill Radiation Staff will
follow existing Mill standard operating procedures.
Once a vehicle is surveyed for unrestricted release in accordance with this Section, Mill staff will
remove or paint over the markings on the vehicle, described in Section 4 above.
July 5,2007 9 RevO
9. Records
Records ofall shipments will be maintained at the Mill office for at least 375 days or such longer
period of time as may be required by applicable regulations.
10. Compliance With Laws
It is the responsibility of the Transportation Contractor to comply with all other applicable laws
and regulations relating to the transportation of uranium ore from the Mine to the Mill that are
not specifically mentioned in this procedure.
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