DRC-2011-002589 - 0901a0688020e50d

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieuienant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rust Lundberg
Director
ORC- 201 1-00 25
March 9, 2011
David Frydenlund, Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17'''Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Material License (RML) Number UTI 900479: Health Physics Inspection
RADMOD-IEM-01
Dear Mr. Frydenlund:
On February 23, 2011, an inspection was conducted at your facility by Ryan Johnson and Kevin
Camey, representatives of the Division of Radiation Control (DRC) of the Utah Department of
Environmental Quality. Observations from the inspection were discussed with Rich Bartlet,
David 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, the license conditions of the RML UTI 900479 and Federal Regulations. The inspection
consisted of an examination of representative reeordSj^-interviews of-personnel, and observations
by the inspector. During the closeout meeting the DRC inspector made recommendations
regarding items for improvement. These recommendations can be found at the end ofthe
inspection report under recommendations.
Enclosed is the inspection report regarding this inspection for your review. The DRC would like
to thank the Mill staff for their cooperation regarding this inspection. If you have any questions
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 [phone] • T.D.D. [phone]
www.deq.utah.gov
INSPECTION REPORT
Inspection Module: RADMOD-IEM-01: Internal/External Monitoring
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Breathing Zone (BZ) and General Air Sampling, Dosimetery and Bioassay
February 22 and 23,2011
Ryan Johnson, Utah Division of Radiation Control (DRC)
Inspection Items
Inspection Dates
Inspectors:
Personnel Contacted: Dave Turk (Radiation Safety Officer (RSO)), Ronnie Nieves (Radiation
Coordinator)
Goveming Documents:
UAC R313-15
NRC Regulatory Guide 8.30
NRC Regulatory Guide 8.25
Radioactive Materials License (RML) UTI 900479
RML UTI 900479 License Renewal Application (2/28/07) Appendix E
(Radiation Protection Manual)
Openine Meeting
Denison Mines: Dave Turk (Radiation Safety Officer)
Ronnie Nieves (Radiation Coordinator)
Utah DRC: Ryan Johnson (Inspector)
Kevin Camey (Inspector)
During the opening meeting, the inspector discussed the inspection items, follow-up items and
documentation to be reviewed during the inspection. The Vanadium Circuit is the only part ofthe
Mill that is operating. The other circuits (Yellowcake and Altemate Feed) were not running at the
time of the inspection for maintenance. The UF4 altemate feed is complete and the Mill will be
starting CAF 2 altemate feed soon.
Inspection Summary
The inspection consisted of employee interviews, review of documentation and a mill tour. The
following discussion provides more detail of the specific items.
Item 1. Employee Interviews:
During the inspection the Inspector discussed the different items for the inspection with the Mills
Radiation Coordinator and RSO.
Deficiencies: None
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Item 2. Documentation:
Breathing Zone Air Monitoring Documentation:
The inspector reviewed the calibration forms and result forms for BZ samples. The inspector also
reviewed the computer spreadsheets used by the Mill to calculate Derived Air Calculation (DAC)
values.
Observation and Recommendation:
The following are recommendations for BZ air monitoring:
1. Password protect the formula cells on the spreadsheets used to calculate DAC values.
2. Radiation Protection Manual indicates that Time on/Time off will be recorded. The
spreadsheet documents total time. Spreadsheet should be consistent with procedure.
3. Radiation Protection manual indicates that each BZ sample will have its own unique sample
number. Document that number on the calibration sheets so that the pump calibration and the
sample results can be correlated.
General Area Air Monitoring Documentation:
The inspector reviewed the calibration forms and result forms for general area air monitoring
samples. The inspector also reviewed the computer spreadsheets used by the Mill to calculate
DAC values.
Observation and Recommendation:
The following are recommendations for general area air monitoring:
1. Password protect the formula cells on the spreadsheets used to calculate DAC values.
2. Radiafion Protecfion Manual indicates that Time on/Time off will be recorded. The
spreadsheet documents total time. Spreadsheet should be consistent with procedure.
3. Document on the calibrafion sheets the area where the sampling pump is going to be used to
correlate sample results with pump used.
Bio Assay Documentation:
The inspector reviewed the bioassay results and was able to confirm that bioassay samples were
being collected monthly from all Mill employees and twice a month for employees working in the
packaging and drier areas of the Mill. The inspector was able to confirm that bioassay procedures
in the Radiafion Protecfion Manual are being followed. An exit bioassay for one former employee
was above action levels however the Mill RSO has not been able to find the former employee to
collect another sample.
Deficiencies: None
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, the altemate feed circuit, the tailings
ponds, the warehouse and the maintenance shops. During the tour the inspector had the RSO show
where general air samples are collected throughout the facility. The Inspector was able to observe
that OSL badges were being wom correctly by Mill employees and were being stored in approved
areas.
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Observation and Recommendation:
During the Mill tour the Inspector and the Mills RSO and Radiafion Coordinator discussed where
general area air samples were collected in the different work areas around the Mill facility. In
some of the work areas the air sample pumps were being placed on the floor because there was no
other place to put the pumps. The inspector informed the Mill RSO that the general area air
samples should be taken as close to the breathing zones of the workers as possible but he would
look up the requirement to verily. The inspector also asked if any air samples have been taken
from the new decon pad, which recently started operation. The answer from the Mill's RSO was
air samples have not been taken yet in the new decon pad area.
The inspector looked up regulatory guidance for air sampling in NRC Regulatory Guide 8.30
which is referenced by the Licensee in the Mills ALARA Program as to be followed for all
radiological surveys and monitoring. Regulatory Guide 8.30 references in its secfion references
Regulatory Guide 8.25. Also Table 1 of Regulatory Guide 8.25 is referenced in the Mills Radiafion
Protection Manual. The following are excerpts of Regulatory Guidance for general air sampling in
the work place.
REGULATORY GUIDE 8.25 AIR SAMPLING IN THE WORKPLACE, Section 2.3
Selecting Sampler Locations, paragraph 3 states "When the purpose of sampling is to determine
worker intakes, each frequenfiy occupied work location should have its own sampler. The air
samplers should be placed as close to the breathing zone of the worker as practical without
interfering with the work or the worker. In addition, air flow pattems in the area should be
considered in placing samplers so that the sampler is likely to be in the airflow downstream ofthe
source and prior to or coincident with the locafion of the worker. An estimate should be made of
the time the worker spends at the work locafion (unless personal air samplers are being used)."
Also in NRC Regulatory Guide 8.25 Table 1 says when a "worker's estimated annual intake as a
concentrafions as a fracfion of ALI is less than 0.1 or the estimated airbome fracfion of DAC is less
that 0.01, air sampling is generally not necessary. However, monthly or quarterly grab samples or
some other measurement may be appropriate to confirm that airbome levels are indeed low."
There are two recommendafions for placement of general air sampling at the Mill:
1. It is recommended in the areas where the sampling pump have to be placed on the floor due to
lack of work space, the Licensee should attach a "gooseneck" or an "S" shaped pipe to the
intake of the pump which will allow the general air sample to be collected in the breathing
zone of the workers working in that area as indicated in NRC Regulatory Guide 8.25 Secfion
2.3.
2. It is recommended that periodic general air samples be collected from the new decon pad to
confirm DAC values in that work area and to ensure proper respiratory protecfion is being
used by Mill works assigned to that area as recommended in NRC Regulatory Guide 8.25
Table 1.
Item 5. FoIIow-up Items:
During an inspecfion in November 2010, DRC inspectors observed a vacuum truck cleanout the
leak detecfion pipes for the Mills tailing cells. When Denison Mines sent the video documentafion
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of that work they did not include the release surveys of the vacuum truck and equipment used. The
inspector obtained copies of those release surveys.
Also during the Mill tour the inspector looked for altemate feed being stored off of the ore pad to
verify that those containers were being stored according to procedure. The UF4 material has been
processed and is no longer on tailing cell #2. The Regen altemate feed material is being stored
near the Altemate Feed Circuit and is being stored per procedure.
Deficiencies: None
Closeout Meeting
Denison Mines: Dave Turk (RSO)
Rich Bartlet (Mill Manager)
Rormie Nieves (Radiafion Coordinator)
Utah DRC: Ryan Johnson (Inspector)
Findings
None
Observations and Recommendations
The following are DRC recommendations regarding items for improvement:
1. Password protect the formula cells on the spreadsheets used to calculate DAC values.
2. Radiafion Protecfion Manual indicates that Time on/Time off will be recorded. The
spreadsheet documents total time. Spreadsheet should be consistent with procedure.
3. Radiation Protection manual indicates that each BZ sample will have its own unique sample
number. Document that number on the calibration sheets so that the pump calibration and the
sample results can be correlated.
4. Document on the calibration sheets the area where the sampling pump is going to be used to
correlate sample results with pump used.
5. It is recommended in the areas where the sampling pump have to be placed on the floor due to
lack of work space, the Licensee should attach a "gooseneck" or an "S" shaped pipe to the
intake of the pump which will allow the general air sample to be collected in the breathing
zone of the workers working in that area.
6. It is recommended that periodic general air samples be collected from the new decon pad to
confirm DAC values in that work area and to ensure proper respiratory protection is being
used by Mill works assigned to that area.
Recommendation for Next Inspection
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately, and
2. Air Monitoring in the New Decon Pad.
Prepared By: Ryan Johnson ^^^'^^^^ ' 3 " ^(
(Print Name) ^-"^^y^ (Signature) (Date)
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UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-IEM-01
INTERNAL/EXTERNAL MONITORING
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, Secfion 5, 10CFR20, NRC Regulatory Guide 8.13, NRC Regulatory Guide 8.22,
Utah Administrative Code R313-12-3, R313-15.
DATE ^^^2^" / (
OPENING MEETING
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
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y DISCUSSION
//F'-'' .
SITE STAFF COMMENTS
AIR SAMPLING
Radiation Protection Manual, Section 1.1.2, Breathing Zone Sampling,
Section 1.1.2.2, Applicability
Breathing zone samples are required:
• for all calciner maintenance acfivities,
• at least quarterly during routine operating and maintenance tasks on
representative individuals performing these tasks,
• when radiafion work permits are issued in which airbome concentrations
may exceed 25% of 10CFR20 limits,
• weekly for yellowcake operafions, or
• at the discrefion of the RSO.
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1 .,f 1 /f
1) Are BZ air samples being taken:
• for all calciner maintenance activities? Yes^A? No
• at least quarterly during roufine operating and maintenance tasks on representative individuals
performing these tasks? Yes 7^ No
• when radiation work permits are issued in which airbome concentrations may exceed 25% of 10CFR20
limits? Yes ^ No
• weekly for yellowcake operation?, or Yes . 'No
• at the discretion of the RSO. Yes ^ No
Comments:
2) Secfion 1.1.2.3 is the procedure for BZ sampling. Is this procedure being followed?
Comments: Yes^XL— No_
3) Secfion 1.1.2.6 lists the Data Records that are to be kept. Are they being kept?
Comments: / . ^ yYes ^ No
4) Secfion 1.1.2.7 shows the calculations to be used. Are these calculafions being used? Yes No_
Are they being used correctly?
Comments: . / ' /' / • Yes ^ No
Radiation Protection Manual, Section 1.1.2.4, Calibration
3.2 PERSONNEL AIR SAMPLERS
The calibration procedure for persormel air samplers involves primary and secondary calibration procedures
Samplers will be calibrated prior to each use by either of two methodologies bubble tube or mass flow
determinations Air samplers may be calibrated to standard air conditions.
3.2.1 Bubble Tube Calibration Method
3.2.3 Electronic Calibration Method
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5) Are calibrations for BZ air samplers being performed and documented prior to each use?
Comments: / > / 7 Yes^ No
6) For BZ air samples being taken, are calibrations for BZ air samplers being performed and documented lAW
Section 3.2.1 or 3.2.3 of the Radiation Protection Manual?
Conynents: ^ Yesy^ No
^/^^ />t.
7) Observe a BZ being calibrated. Which procedure was used and was it done correctly?
Comments: Yes^-'-xy No_
8) Is the RSO reviewing results that exceed 20% of 10FR20 limits? (Section 1.1.2.8)
Comments: Yes No_
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Radiation Protection Manual, Section 1.1.3.1, Frequency and Locations
The following principles used for the collection of area grab samples must be considered when collecting a
sample in order to obtain a representative concentration that workers may be exposed to during their assigned
work tasks.
1. The locations selected for sampling should be representative of exposures to employees working in the area.
2. For special air sampling, the sampling period should represent the conditions during the entire period of
exposure. This may involve sampling during the entire exposure period.
3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow rate of 40 liters per
minute for at least 60 minutes.
4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector.
5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or non-
routine situations.
9) Are area grab samples obtained in areas representative of workers exposure?
During the Mill tour Have the RSO show where the air samples are being taken. ^
Comments: Yes^^>c^ No
^^.''^ ^4// z£ c^y-^^" — —- —
10) For roufine sampling, did the licensee sample at a minimum flow rate of 40 liters per minute for at least 60
minutes?
Comments: Y^xO No
11) Were air sample filters analyzed for gross alpha using a sensifive alpha detector?
Comments: Yes ^^XZ No
fyf!^ ^^^^ Z^2^ r?y ^\ /"r.c/A ^Pr^r^ _J
Table 1.1.1-1 for areas where the ALI <.01 and the DAC is <0.01 it state, "Air sampling is generally not
necessary. However monthly or quarterly grab samples or some other measurement may be appropriate to
confirm that airbome levels are indeed low."
12) Are periodical grab samples taken on a Monthly or Quarterly frequency to confirm that airbome radioactivity
remain below ALI <.01 and the DAC is <0.01 values? /
Comments: / / / Yes /\ No
^^-lie-*-^^ I :
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RML License Condition 11.4
Annually, the licensee shall collect, during mill operations, a set of air samples covering eight hours of sampling,
at a high coUection flow rate (i.e., greater than or equal to 40 liters per minute), in routinely or frequenfiy
occupied areas of the mill. These samples shall be analyzed for gross alpha. In addition, with each change in mill
feed material or at least annually, the licensee shall analyze the mill feed or production product for U-nat, Th-230,
Ra-226, and Pb-210 and use the analysis results to assess the fundamental constituent composition of air sample
particulates.
13) Did the licensee perform high volume alpha air sampling in routinely or frequently occupied areas of the mill
in accordance with L.C. 11.4? .
Comments: YQPC/ No
14) Did the air samples cover eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to
40 liters per minute)?
Comments: Yes,.^"'ky No
15) With each change in mill feed material or at least annually, did the licensee analyze the mill feed or
-n producfion product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the
fundamental constituent composition of air sample particulates?
Comments: Yes M No
Radiation Protection Manual, Section 1.1.3.2 Sampling Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for one
hour or longer. Equipment utilized will be an Eberline RAS-1, or a Scientific Industries Model H25004, or
equivalent. Filter media will have a maximum of 0.8 micron pore diameter. Equipment is calibrated prior to each
usage as per Section 6, [3] (typo), of this manual.
16) Are calibrations for area air samplers being performed and documented prior to usage?
Comments: Yes
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17)Is the licensee using air sample filters that have a maximum of 0.8 micron pore diameter? .^^^
Comments: Yes^j^L. No_
18) Are calibrations for area samplers being performed and documented in accordance with Section 3.3 ofthis
Manual? \ X
Comments: Yes No
19) Has the licensee provided proper documentafion of the results of calibration for the following air sampling
equipment?
Air Sampler ^/ S/N Yes ^ No
Air Sampler C/k' S/N / Yes ^ No
Air Sampler S/N p ^^5^ Yes No
Air Sampler ~ /J/^C \i^ ^ S/N ^-gT^^^ Yes No
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20) Secfion 2.1.2 Frequency/Locafions
Has the Licensee performed monthly uranium dust monitoring in the following areas? (Table 2.1.2-1)
Airborne Radiation Sample Locations
BAI Ore Scalehouse Yes )<C No
BA2 Ore Storage Yes V No_
BA7 SAG Mill Area Yes ^ No_
BA8 Leach Tank Area Yes /< No_
BA9 Wash Circ CCD Thickness Yes > No_
BAIO Sol Ex Bldg/Stripping Sec Yes X No
BAI 1 Sol Ex Bldg/Control Room Yes ><' No
BA12 YC Precip/W Storage Area Yes V No"
BA12A No. YC Dryer Enclosure Yes Y- No
BA12B So. YC Dryer Enclosure
-BAI3 YC Drying/Pkging Area
BA13A YC Pkging Enclosure
BAH Pkgd YC Storage Room
BAI5 Met Lab Sample Room
BA16 Lunch Room Area
Yes y.
Yes X"' No_
Yes No_
Yes V No
Yes No_
" No
No"
Yes
Yes"
Comments:
/g/f-3/
-BAI7 Change Room
BAI 8 Administrative Building
BAI9 Warehouse
BA20 Maintenance Shop
BA21 Boiler
BA22 Vanadium Panel
BA22A Vanadium Dryer
BA23 Filter Belt/Rotary Dryer
BA24 Tails
BA25 Central Control Room
BA26 Shifter's Office
BA27 Operator's Lunch Room
BA28 Dump Stafion
BA29 Filter Press
BA30 Tmck Shop
Yes No_
Yes_^ No
Yes
Yes
Yes ?<'•'
Yes X
Yes 3c7
Yes V
No_
No_
No_
No_
No_
_No_
Yes X No_
Yes No_
Yes >P No_
Yes X No
Yes No^
Yes >C No
Ye&^ No
Yes No
HAJJL
10CFR20 Table 1 of Appendix B DAC values for "^U retention class Y: 2E-lluCi/ml Footnote 3 (for ^^^U):
If a mixture of radionuclides consists of uranium and its daughters in ore dust (10 |am AMAD particle distribution
assumed) prior to chemical separafion of the uranium from the ore, the following values may be used for the DAC
of the mixture: 6E-1 l^xCi of gross alpha acfivity from uranium-238, uranium-234, thorium-230, and radium-226
per milliliter of air; 3 E-11 |iCi of natural uranium per milliliter of air; or 45 micrograms of natural uranium per
cubic meter of air.
21) Where any of the air sample results from the above areas found to be in excess of the DAC values listed in
10CFR20 Table 1 of Appendix B? Yes ^ No_
Areas ideruified: _Area DAC Value Area
Comments:
DAC Value . I; 'Area DAC Value
2JdllIL^\ih2=k a-n
I, -^ct 'fo^nv^/l/r b,^^/B -/(
1.12 C'/U^
Yes No_
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Utah Rules R313-12-3. Definitions
"Airborne radioactivity area" means: a room, enclosure, or area in which airbome radioactive material exists in
concentrations:
(a) In excess of the derived air concentrations (DACs), specified in Rule R313 -15, or
(b) To such a degree that an individual present in the area without respiratory protective equipment could exceed,
during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on intake (ALI), or
12 DAC hours.
Utah Rules R313-15-902, Posting Requirements
(4) Posting of Airbome Radioactivity Areas. The licensee or registrant shall post each airbome radioacfivity area
with a conspicuous sign or signs bearing the radiafion symbol and the words "CAUTION, AIRBORNE
RADIOACTIVITY AREA" or "DANGER, AIRBORNE RADIOACTIVITY AREA."
22) If yes to Hi,, were the areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of Appendix B
properly posted?
Cormnents^ . ^ ^ Yes^ No
^ Ay^ ^^^g^ /)Le^ ,'Pr/'^y in-^'i'^ t 7^ r^^^^ ^/^^
BIOASSAY PROGRAM
Radiafion Protecfion Manual. Section 1.4.1 Frequency
Urinalysis will be performed on those employees that are a) exposed to airbome yellowcake or involved in
maintenance tasks during which yellowcake dust may be produced, or b) routinely exposed to airbome uranium
ore dust. Baseline urinalysis will be performed prior to inifial work assignments.
Urine samples are collected on a routine basis from mill employees as required in Regulatory Guide 8.22. Urine
samples will be collected from employees who have worked in yellowcake packaging, yellowcake precipitafion,
grind area (SAG Mill), ore feed, sample plant, scale house, and the sample preparafion room every two weeks
during producfion periods. Samples will be collected from all other employees monthly during producfion
periods. During non-production periods, bi-weekly samples will be collected if individual exposures are expected
to exceed 25% ofthe DAC value otherwise samples will be collected from all employees quarterly. Non-roufine
urinalysis will usually be performed on employees who have been working on assignments that require a
Radiation Work Permit, and always on any individual that may have been exposed to airbome uranium or ore
dust concentrafions that exceed 25%) of the DAC level.
23) Are urine samples being collected from workers who are working under an RWP?
Comments: Yes No
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24) Are bi-
Comments:
urine samples being collected from workers in the following areas during producfion?
Yellowcake Packaging Yes No
Yellowcake Precipitation Yes No
Grind Area (SAG Mill) Yes y-No
Ore Feed Yes Y No
Sample Plant Yes >^> No
Scale House Yes No
Sample Prep Room Yes No
4
Yes No
25) During producfion periods, are monthly urine samples being collected from all employees working in areas
other than those listed above?
Comments: J / Yes^X^ No
26) Are urine samples being collected from Radiafion Safety Personnel evetjv two weeks during production
periods? (Radiation Safety Personnel routinely work in areas listed in #H-^bove).
Cornments: Yes No
Section 1.4.3 Sample Preparation
Sample preparation will be done in an area decontaminated to less than 25 dpm alpha (removabk;)Der 100 cm^
prior to preparation of samples. All of the equipment that is used in sample preparation will be clean
maintained in such condition.
27) Are the sample preparation area contamination levels maintained below 25dpm/100cm^ a (removable)?
Comments: Yes No
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PlOO in of 1 /I
EXTERNAL MONITORING
28) Section 1.3 Beta-Gamma Surveys
Were all observed persormel wearing a personal monitoring badge while in the Restricted Area?
Comments: Yes^^^' No
Section 1.3.1 Monitoring Procedures
The monitoring procedures consist of
1. Persormel issued personal monitoring devices will wear the device on the tmnk (torso) of the body or visibly
on the exterior of their hard hat. The personal monitoring device records beta/gamma radiation as well as other
forms of penetrating radiation such as x-rays. A personal monitoring device is an exposure record of an
individual's personal exposure to radiation while on the job. Therefore, personal monitoring devices are to remain
at the Mill in the personal possession of each individual, in a locker or other secure area. All exposure records
obtained by a personal monitoring device which are not consistent with the exposure rates of work tasks or work
location measurements made throughout the Mill will be evaluated by the RSO. This evaluation will result in an
investigation by the RSO and a written explanation of the findings. These written records will be maintained at
the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be exchanged by the Radiation
Safety Department. Missing or lost badges will be reported to management.
3. Female employees that become pregnant and continue to work during the course of their pregnancy will be
placed on a monthly personal monitoring device exchange during this period. NRC Regulatory Guide 8.13
provides guidelines to be followed during pregnancy and is made part of this procedure.
29) Under routine conditions, were observed employees wearing monitoring badges properly on the torso?
Comments: ^ Yes 'V' No ments: Yes
IT
30) Has the licensee assured that personal monitoring devices are being kept at the Mill in the possession of the
individual, in a locker or in another secure area?
Conun^ts: Yes >C No
C^^ •'"'^ /^'f ^vt fC^0^i^ly^JL^y^ 'TL^ :^jiCM
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMillMlP Inspection modules\2011 Mnspection Modules\RADMOD-lEM-01 rev2.doc
Vl..na 11 .^f 1,1
31) Check the dosimeter boards in the locker rooms, maintenance building and administrafion building. Check to
see if any are missing from that board and had been taken home.
Comments:
32) Have any female workers declared their pregnancy in the past 2 years?
Comments: . Yes ^7 No_
33) If yes to 31 above, has the declared pregnant worker been placed on a monthly personal monitoring device
exchange during this period? ^
Comments: Yes No
Follow-up
34) Altemate feed: Check to see where all of the altemate feed material is being stored. If it is not in the ore pad
area then where is it and how is it being stored?
Comrnents: ^
35) During the last inspection Denison had a vacuum tmck onsite cleaning out the leak detecfion systems ofthe
tailings pond. Obtain a copy of the release surveys of the tmcks and equipment used on that job.
Comments:
U:\rad\C0MM0N\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMillVHP hispection modules\201 IMnspection ModulesMlADMOD-lEM-01 rev2.doc
Dono n /^f 1/1
DATE
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
f^^!''y'^
^ 53^^-—
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 IMnspection Modules\RADMOD-IEM-01 rev2.doc
P..r,o n r,f 1/1
DISCUSSION of FINDINGS
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SITE STAFF COMMENTS
U:\rad\C0MM0N\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMilhHP hispection modulesVZOl IMnspection Modules\RADMOD-lEM-01 rev2.doc
Dooo 1/1 /.t* 1/1
BREATHING ZONE PUMP CALIBRATION FORM •
CALIBRATE AT 4 LITERS PER MINUTE
PUMP# l(sl00^ DATE
READING 1. 4<^5 0
READING 2. ^
READING 3._il5AL
AVERAGE M^*^^
TEMPERATURE 10
PURPOSE OF BREATHING ZONE RV/P ^{^
RADIATION/SAFETY TECHNICIAN (jA^tYO^ ^o\)(</\t^
NAME OF EMPLOYEE WEARING SAMPLE 6-ftj6 S4-Ck\l'y\j
COMMENTS
BREATHING ZONE PUMP CALIBRATION FORM
CALIBRATE AT 4 LITERS PER MINUTE
PUMP # DATE
READING 1.
READING 2. Y//<^
READING 3.
AVERAGE V//£>
TEMPERATURE <^f'
PURPOSE OF BREATHING ZONE fO. PfCfi
RADIATION/SAFETY TECHNICIAN
NAME OF EMPLOYEE WEARING SAMPLE / <»v*>«>
COMMENTS
BREATHING ZONE PUMP CAUBRATION FORM
CALIBRATE AT 4 LITERS PER MINUTE
PUMP# yYS^O- DATE
READING 1. */<;t/fe TEMPERATURE '7<?V'
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READING 3._V^^«L__
AVERAGE yjV?
PURPOSE OF BREATHING ZONE "fC Pk6
RADIATION/SAFETY TECHNICIAN •7!/>c^/.'''gyey>-»^
NAME OF EMPLOYEE WEARING SAMPLE
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m
e,
jiarvey of Equlpmeit Relm:
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with the following procedure.
1. Monitor for Gross alpha contamination with the appropriate survey meter.
2. If calculated assay exceeds 1,000 dpm/lOOcm^, then perform 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/1 OOcm^ average
15,000 dpm/lOOcm^ maximum
Beta-Gamma-0.2 mi'/hr @lcm average
1.0 miVhi- @ 1cm maximum
Released fi-om White Mesa Mill to:
Released by: C^^lffoii M fAjy^
Instrument Function checks
Alpha Meter:
Inst. Model 3-15 SN ^1 |i \
Th-230 Source SNSftV-ffl
dpm^J^M^cpm (tf(m eff ty.ly.
Efficiency Factor
Bkg X(/
MDA Comments
Date: U^-ii-t^
List of Equipment Total Alpha dpm/lOOcm^ Removable Alpha
dpm/lOOcm^
Beta/Gamiha mr/hr
—
i 6lc(. to.o ^
' Ree( — 5 0.0 ^
4.
5.
Beta-Ganmia Meter:
Inst. Model J
Cs-137 Source SNj^
Inst. Response ^.0 y^^Vy
Removable
Inst. Mod
Th-230 Sol
dpm >^pin
Efficiency Factor
DEMISON MIMES (USA) Corp
White Mesa
jiarvey off
r-ns
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with the following procedure.
1. Monitor for Gross alpha contamination with the appropriate survey 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 (^Icm average
1.0 rar/hr @lcm maximum
Released fi^om White Mesa Mill to:
Released by: COi^^yaVx fetlfHgf^ Date : U'JLHO
List of Equipment Total Alpha dpm/lOOcm^ Removable Alpha
dpm/lOOcm^
Beta/Gamiiia mr/hr
—
' Noxr.<»\i —
3.
4.
5.
Instrument Function checks
Alpha Meter:
Inst. Model ^-Jj m ^SH)l
Th-230 Source SNSVI*!-^^
dpm3j^0fl& cpm 6^600 eff i^.[y.
Efficiency Factor (sM
Bkg AC?
MDA /^y
Beta-Gamma Meter:
Inst. Model 3
Cs-137 Source SN #J
SNjiliiil
Inst. Response J^.O wiv/ky^
Removable /i^ha:
Inst. Mode/
Th-230 S(
dpm V ci6i4 7
Efficiency Fa
Comments: