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Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
DirectorGARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
March 10, 20Il
David Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp.
1050 Seventeenth Street, Suite 950
Denver, Colorado 80265
RE: DRC Inspection Module RADMOD-RPP-02, February 23-24,2OII,RML UT1900479
Dear Mr. Frydenlund:
Inspection Module RADMOD-RPP-02 was conducted on February 23-24,201lby the Division of
Radiation Control (DRC) at the White Mesa Mill. The inspection focused on aspects of the
Respiratory Protection Program at the Mill including respirator training, maintenance, personnel
qualifications and records. Overall performance of inspection items was found to be good with no
deficiencies noted during the inspection.
All items inspected met applicable regulatory requirements and site procedures and no further
action is required in regard to this inspection. Please continue to remember that radiation safety is
the responsibility of the licensee. Thank you for your cooperation in this matter.
If you have any questions or concerns regarding this letter, please contact Kevin Carney at (801)
536-4250.
UTAH RADIATION CONTROL BOARD
Executive Secretary
RUKJC:kc
Enclosure
cc: David Turk, Site RSO
195 North 1950 West ' Salt Lake City, UT
Mailing Address: P.O. Box 144850. Salt l-ake City, UT 84114-4850
Telephone (801 ) 536-4250. Fax (80l) 533-4097 ' T.D.D. (801) 536-Ml4
www.deq.utah. gov
Printed on l00o/, recYcled PaPer
Rusty Lund
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-RPP-02 Rev 1
RESPIRATORY PROTECTION PROGAM
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Inspectors: Kevin Carney
Inspection Dates: Start: February 23.2011 End: February 24.2011
Requirements, Procedures, Policie^^^
o Radioactive Materials License UTI900479
o NRC Regulatory Guide 8.31
o NRCRegulatory Guide 8.15
o License Renewal AppHcation Appendix L
^ o Utah Administrative Code^
R313-15-703. Use of Individual Respiratory Protection Equipment
If the licensee or registrant uses respiratory protection equiprnent to limit the intake of radioactive
material:
(1) Except as provided in Subsection R313-15-703(2), the licensee or registrant shall use only
respiratory protection equipment that is tested and certified by the National Institute for Occupational
Safety and Health.
(2) The licensee or registrant may use equipment that has not been tested or certified by the INfational
Institute for Occupational Safety and Health or for which there is no schedule for testing or
certification, provided the licensee or registrant has submitted to the Executive Secretary and the
Executive Secretary has approved an application fbr authorized use of that equipment. The application
must include a demonstration by testing, or a demonstration on the basis of reliable test information,
that the material and performance characteristics of the equipment are capable of providing the
proposed degree of protection under anticipated conditions of use.
(3) The licensee or registrant shall implement and maintain a respiratory protection program that
includes:
(a) Air sampling sufficient to identify the potential hazard, permit proper equipment selection, and
estimate doses; and
(b) Surveys and bioassays, as necessary, to evaluate actual intakes; and
(c) Testing of respirators for operability, user seal check for face sealing dcA^ices and functional check
for others, immediately prior to each use; and
(d) Written procedures regarding
(i) Monitoring, including air sampling and bioassays;
(ii) Supervision and training of respirator users;
(iii) Fit testing;
(iv) Respirator selection;
(v) Breathing air quality;
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(vi) Inventory and control;
(vii) Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection
equipment;
(viii) Recordkeeping; and
(ix) Limitations on periods of respirator use and relief from respirator use; and
(e) Determination by a physician prior to initial fitting of respirators, before the first field use of non-
face sealing respirators, and either every 12 months thereafter or periodically at a frequency
determined by a physician, that the individual user is medically fit to use the respiratory protection
equipment; and
(f) Fit testing, with fit factor greater than or equal to ten times the APF for negative pressure devices,
and a fit factor greater than or equal to 500 for positive pressure, continuous flow, and pressure-
demand devices, before the first field use of tight fitting, face-sealing respirators and periodically
thereafter at a frequency not to exceed one year. Fit testing must be performed with the facepiece
operating in the negative pressure mode.
(4) The licensee or registrant shall advise each respirator user that the user may leave the area at any
time for relief from respirator use in the event of equipment malfunction, physical or psychological
distress, procedural or communication failure, significant deterioration of operating conditions, or any
other conditions that might require such relief.
(5) The licensee or registrant shall also consider limitations appropriate to the type and mode of use.
When selecting respiratory devices the licensee shall provide for vision correction, adequate
communication, low temperature work environments, and the concurrent use of other safety or
radiological protection equipment. The licensee or registrant shall use equipment in such a way as not
to interfere with the proper operation of the respirator.
(8) The licensee shall ensure that no objects, materials or substances, such as facial hair, or any
conditions that interfere with the face and facepiece seal or valve function, and that are under the
control of the respirator wearer, are present between the skin of the wearer's face and the sealing
surface of a tight-fitting respirator facepiece.
(9) In estimating the dose to individuals from intake of airbome radioactive materials, the
concentration of radioactive material in the air that is inhaled when respirators are wom is initially
assumed to be the ambient concentration in air without respiratory protection, divided by the assigned
protection factor. If the dose is later found to be greater than the estimated dose, the corrected value
must be used. If the dose is later found to be less than the estimated dose, the corrected value may be
used.
Respiratory Protection Program
1) Have the respirators that the licensee uses for respiratory protection been tested and certified by the
National Institute for Occupational Safety and Health? (R313-15-703)
Yes iEI No • N/A •
Comments: The Mill uses MSA brand respirators. All respirator types currently used at the Mill are
NIOSH approved.
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2) Upon review of the Respirator Protection Program and Mill procedures, are written procedures in the
following areas implemented and maintained? (R313-15-703(3)(d))
Written procedures Yes No
Monitoring, including air sampling and bioassays; m •
Supervision and training of respirator users; m •
Fit testing; ' m •
Respirator selection; m •
Breathing air quality; m •
Inventory and control; ' M •
Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection
equipment; X •
Recordkeeping; m •
Limitations on periods of respirator use and relief from respirator use; m
Comments: All above listed procedures can be found in the White Mesa Mills "'Respiratory
Protection Program'' found in the White Mesa Mill - Standard Operating Procedures, RPP-1, Book 14.
(see attached) . ' ' - • . . • • ( —
Respirator Issuance
3) Have the licensee provide a list of 10 respirator users. Do the following users meet the requirements
of R313-15-703 for respirator training?
Name Exams Initial/Refresher
Training Records
Medical
Clearance Fit Tests
1. Kenneth Jones Yes lEl No • Yes IE! No • Yes 13 No • Ye s M N o •
2. Chad Little Yes X No • Yes IE! No • Yes 13 No • Yes 13 No O
3. James Laws Yes IEI No • Yes 13 No • Yes X No • Yes 13 No •
4. Josh Taylor Yes 13 No • Yes 13 No • Yes 13 No Q-Yes 13 No •
5. Gordon Allred Yes ^ No • Yes 13 No • Yes X No • -Yes El No •
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6. Nate Clark Yes 13 No • Yes X No • Yes 13 No • Yes X No •
7. Devon Mitchell Yes 13 No • Yes No • Yes 13 No • Yes 13 No •
8. Logan Shumway Yes 13 No • Yes ^ No • Yes X No • Yes 13 No •
9. Terry John Yes 13 No • Yes 13 No • Yes X No • Yes 13 No •
10. Riley Holmes Yes 13 No • Yes 13 No • Yes 13 No • Yes X No •
Comments: Names were chosen from the ^^Respirator Issuance and Fit Testing Log/' The names
were then given to the RSO who provided the personnel files to the inspector for review. The files
contained training, fit test and medical surveillance dates and results as well as copies of the
employees' written tests. \ • •
Respirator Maintenance
4) Has the hcensee provided documentation for training of personnel responsible for respirator
maintenance and repair?
Yes IEI No • N/A •
Comments: The current lead respirator technician at the Mill is Charles Orvin. He is responsible for
maintenance and repair of respirators as well as respirator issuance and smoke testing respirator users
upon issuance. Mr. Orvin is also responsible for the housekeeping responsibilities and the inventory
and upkeep of equipment in the respirator room. Training for these duties are given to all Radiation
Technicians as part of the Radiation Technician Training.
5) Are used respirators being surveyed after each use?
Yes IEI No • N/A •
Comments: Respirators are surveyed post decon and prior to placing back into service.
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6) Are respirators surveyed for removable contamination?
Yes 13 No • N/A •
Comments: Respirators are surveyed using a wipe technique and wipes are counted using a count
rate instrument (scaler). • .• • .' ' / - . •
7) Do respirator surveys properly document the survey performed?
Yes IEI No n N/A •
Comments: Respirator surveys are documented on the Mill's ^'Respirator Contamination Survey"
form, (see attached copy> ' : .
8) Are respirators decontaminated as per Manufacturers Instructions?
Yes IEI No • N/A •
Comments: Respirators are deconned as per the respirator manuals and utilizing the manufacturers
decontamination products YMSA Confidence Plus® cleaning solution. Part Number 100099711
Respirators are disassembled and hand washed and rinsed in a two-basin sink. All parts are washed
separately. ^ .
9) Are respirators inspected in accordance with the licensee's Respiratory Protection Program?
Yes IEI No • N/A •
Comments: Stored respirators are visually inspected approximately once per quarter. Most
respirators are used routinely and rotated for issuance. According to the respirator tech. no respirators
stay stored for a year. Approximately 15-25 respirators are issued per day. All respirator parts are
inspected for damage and functionality after cleaning and during respirator reassembly.
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10) Are respirators properly stored?
Yes ^ No • N/A •
Comments: Respirators are kept in a locked cabinet in the respirator room. Each respirator is Stored
in a separate plastic bag. However, respirators are currently stored with the mask's sealing surface face
down. Tt was suggested hy the inspector that they he placed in storage face UP to minimiz.e the
possibility of distorting the face piece's sealing surface.
11) Of the respirator users observed, did any have facial hair or any other obstruction that would restrict
the proper fitment of their respirator?
Yes • No ^ N/A •
Comments: Several workers on the vanadium circuit were observed as well as two workers carrying
respirators on their way to work inside the Mill. All were clean shaven and were otherwise compliant
with the rules for face-to-sealing-surface requirements. _ —-
12) Inspection of stored respirators.
Respirator
Number Respirator Type Face Shield
Damaged?
Mouth Piece
Damaged?
Straps
Damaged?
Miscellaneous
Parts
Damaged?
789 MS A Full Face Yes No 13 Yes No 13 Yes No 13 Yes No 13
767 "MSA Fiiir Face" "Yes NF|3" "Yes N6|3 Yes No^" Yes No 13
752 MSA Full Face Yes No 13 Yes No 13 Yes No^ Yes Noy
254 MSA Full Face Yes No 13 Yes No 13 Yes No^ Yes No^
225 MSA Full Face Yes No|3 Yes No 13 Yes No 13 Yes No^
308 MSA Full Face Yes No 13 Yes No 13 Yes No 13 Yes No 13
754 MSA Full Face Yes No 13 Yes No 13 Yes No^ Yes No 13
279 MSA Full Face Yes No 13 Yes No 13 Yes No 13 Yes No^
856 MSA Full Face Yes No 13 Yes No 13 Yes No 13 Yes No^
54 MSA Full Face Yes No|3 Yes No 13 Yes No 13 Yes No 13
775 MSA Full Face Yes No 13 Yes No 13 Yes No 13 Yes No 3
201 MSA Full Face Yes No ^ Yes No 13 Yes No 13 Yes No 13
Comments: 12 randomly chosen respirators, that were ready for issue, were inspected. This was a
visual inspection through the plastic bag. None of the respirator bags were opened in order to maintain
their cleanliness. All observed respirators were found tn he in good condition and readv for issuance.
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13) Are records being kept for the Respiratory Protection Program?
Yes IEI No • N/A^ n
Comments: Various records were observed at different times during the course of the inspection.
14) Were the observed records found to be legible and compliant? '
Yes IEI No • N/A Q
Comments: All records observed were found to he legible and complete. No records were found to
be out of compliance. Observed records included individual employee training/medical/fit test records,
respirator issuance logs, radiological surveys and MSHA certificates. - :,- ' •
15) Are records kept at the facility?
Yes IE! No • N/A • :
Comments: Above observed records were located in the RSO's office. Administrative Vault and the
Respirator Rppm. . : ^ - \ • ^ /. ' -——
16) Observe a respirator user being fit tested (smoke test).
Yes • No • N/A IEI
Comments: No respirator users were available for this test^t the time of the inspection. However,
Mr. Orvin explained and demonstrated the procedure for the inspector. The techniques described were
sufficient for completing the task. — •' •' ' - ' • —-
17) Observe a respirator user performing a seal test.
Yes • No • N/A IE!
Comments: No respirator users were available for this test at the time ofthe inspection. However, as
above. Mr. Orvin explained and demonstrated the procedure for the inspector. The techniques
described were sufficient for completing this task. . ^ ___ • . - • • , . -^
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Additional Comments:
The inspector found no deficiencies in the Respiratory Protection Program. The personnel interviewed
were found to be knowledgeable about the duties assigned to them. Program records were found to be
complete and in compliance with Utah Rules and the Mill's Respiratory Protection Program. The
conditions in the respirator room were found to be clean and compliant. The Mill maintains a good
safety culture in respect to respirator use. The current Lead Respirator Technician is knowledgeable of
the Mill's Respiratory Protection Program and appears to be implementing the program in an efficient
manner. .
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