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HomeMy WebLinkAboutDRC-2011-007584 - 0901a0688028c80aState of Utah GARY R. HERBERT Govemor GREG BELL Lieutenant Governor Department Qf . EiivironiT^^ntal Quality Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rust Lundberg Director November 15, 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-Training-01 Dear Mr. Frydenlund: On November 9 and 10, 2011, an inspection was conducted at your facility by Ryan Johnson and John Hultquist, representatives of the Division of Radiation Control (DRC) of the Utah Department of Environmental Quality. Observations from the inspection were discussed with Ronnie Nieves and Dan Hillsten 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 records, interviews of personnel, and observations by the inspector. During the closeout meeting, the DRC inspector made recommendations regarding items for improvement. These recommendations can be found at the end of the inspection report under recommendations. Enclosed is the inspection report regarding this inspection for your review. The DRC considers this inspection closed. 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 (801)536-4250. UTAH RADIATION CONTROL BOARD Rusty Lundberg, Executive Secretary RL/RJ:rj Cc: David Turk, Site Radiation Safety Officer Enclosures 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801-533-4097 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper INSPECTION REPORT Inspection Module: RADMOD-Training-01: Radiation Safety Training Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah. Inspection Items: Inspection Dates: Inspectors: New Employee Radiation Safety Training, Respiratory Protection Training, Refresher Training, Radiation Safety Technician Training and Radiation Safety Officer (RSO) Training November 9 and 10, 2011 Ryan Johnson, Utah Division of Radiation Control (DRC) Personnel Contacted: Ronnie Nieves (Radiological Coordinator) Justin Perkins (Radiation Safety Technician) Cornelius West (Utilities Crew) David Turk (RSO) via telephone Devin Nez (Maintenance Crew) Philbert Simpson (CaF2 Circuit Crew) Cody Cosby (Laboratory Technician) Goveming Documents: • UACR313-15 • Radioactive Materials License (RML) UTI 900479 • Applicable Mill procedures and manuals Opening Meeting Denison Mines: Dan Hillsten (Mill Manager) Ronnie Nieves (Radiological Coordinator) Utah DRC: Ryan Johnson (Inspector) John Hultquist (DRC Section Manager) During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed during the inspection. Only the Altemate Feed Circuit ofthe Mill was in operation during this inspection, the remainder of the Mill was in annual shut down for maintenance. The Mill staff reminded the inspector of the safety requirements for the Mill. David Turk, the Mill's RSO, was not at the Mill during the inspection but was available by phone. 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. 1 ofPage 4 U:\rad\COMMON\Uranium mills\lle(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\2011\Inspection ReportsMnspection ReportRADMOD-Training-0111-10-llRJ-pg.doc Item 1. MiU Tour: The inspector walked through the restricted area on a general site tour. The tour included the ore pad, the new decontamination pad, the mill, the altemate feed circuit. The SX building, the warehouse and the tailings ponds. Observations: The DRC inspector observed: • Proper PPE was being wom by Mill employees within all observed areas ofthe Mill; • . Proper Radiological Posting were being used within all observed areas ofthe Mill; • OSL badges were appropriately being used by all observed employees at the Mill; and • New concrete pad had been poured and being used as a dmm managing area next to the drum loading area of Altemate feed circuit. Deficiencies: The inspector observed the following deficiencies: • Large cracks in the cement floor in the Altemate Feed Circuit area; • The Ore receiving gate and the Rad gate were left open even when vehicles were not going through them; and • The Radiation Coordinator informed the inspectors that a recent yellowcake shipment had Alpha contamination on the tmck above the receiving company's contamination limits. Item 2. Employee Interviews: The inspector interviewed five employees on the radiation safety and respiratory protection training that they have had while employed at the Mill. Observations: The DRC inspector observed: • Initial and refresher radiation safety and respiratory protection training was being done at the Mill; • Employees knew how to properly wear and store their assigned dosimeters (OSL badges); and , • Employees knew how to properly use and store respirators. Deficiencies: The inspector observed the following deficiencies: • All but one of the employees interviewed did not know: o What types of radiation are they exposed to at the Mill ( e.g. Alpha, Beta and Gamma); o What are the health concems associated with the types of radiation that they are exposed to at the Mill; and o How do they limit the exposure to radiation while working at the Mill. Item 3. Documentation: Employee Training Documentation: The Inspector reviewed the training documentation for the employees interviewed plus one additional employee. The Inspector also reviewed the training outlines used by the radiation safety staff to confirm that all of the training topics outlined in NRC Regulatory Guides 8.15 and 8.31 were covered during training. Observations: The Employee training records consisted of the following documentation: • Exams for initial and refresher trainings for the Radiation Safety and Respiratory Protection 2 of Page 4 U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMillNHP Inspection modules\201 IMnspection ReportsMnspection ReportRADMOD-Traimng-0lll-10-riRJ-pg.doc training; • The MSHA 5000-23 form, which is used by the Mill to document that training had been completed; • The Personnel Monitoring form to document that the employee was trained on how to survey themselves out of the restricted area; • Prenatal Training had been performed (Women only); • Employee Medical clearances for respirator use; and • Respirator fit tests. RSO and Radiation Safety Technician Training Documentation: The Inspector reviewed the documentafion to determine if they met the requirements for the RSO and the Radiation Safety Technicians in NRC Regulatory Guide 8.31. Observations: • The RSO and the Radiation Coordinator (the RSO's designee) have both received Radiation Safety Officer training and were current on refresher training; and • Radiation Safety Technician staff was being trained appropriately and the training was being documented. Deficiencies: None Closeout Meeting Denison Mines: Dan Hillsten (Mill Manager) Ronnie Nieves (Radiological Coordinator) Utah DRC: Ryan Johnson (Inspector) John Hultquist (DRC Section Manager) Findings The following findings were observed during this inspection: 1. Large cracks were observed in the concrete floor of the Altemate Feed Circuit area; 2. The Ore receiving gate and the Rad gate were left open even when vehicles were not going through them; and 3. Employees need additional training on the following topics: . a. What types of radiation are they exposed to at the Mill ( e.g. Alpha, Beta and Gamma); b. What are the health concems associated with the types of radiation that they are exposed to at the Mill; and c. How do they limit the exposure to radiation while working at the Mill. . Recommendations The following are DRC recommendations regarding items for improvement: 1. The cracks in the concrete floor of the Altemate Feed Circuit are repaired; 3 ofPage 4 U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 IMnspection ReportsMnspection ReportRADMOD-Training-0in-10-llRJ-pg.doc 2. Keep the Ore receiving gate and the Rad gate closed unless a vehicle is entering or exiting the restricted area through them; and 3. The radiation safety topics that the interviewed employees did not know are reviewed and retaught in upcoming Mill safety meetings. Recommendation for Next Inspection 1. Spills (yellowcake and other materials) being cleaned up in the mill immediately; 2. Personnel Exit Monitoring; 3. Next fime radiafion safety training and respiratory protecfion training is reviewed by the DRC. The inspector should sit in a training session; 4. DRC Engineers and Hydrogeologists inspect the cracks in the foundation in the Mill buildings and Altemate Feed circuit; 5. Follow-up on the Alpha Contaminafion on the Yellowcake shipment; and 6. Follow-up on the Findings of this inspectio^^^^" Prepared By: Ryan Johnson /^^^ • _ //~/5^ // (Print Name) rSmnature)^ (Date) Reviewed By: Phil Goble .^^^^ ^V^^ /'^'^U (Print Name) (Signature) (Date) 4 ofPage 4 U:\rad\COMMON\Uranium mills\lle(2)UT 1900479 Denison Mines - White Mesa UMillMlP Inspection modules\201 IMnspection ReportsMnspection Report RADMOD-Training-Ol 11-10-11 RJ-pg.doc UTAH DIVISION OF RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-TRAINING-01 RADIATION PROTECTION & RESPIRATORY PROTECTION TRAINING/ RADIATION SAFETY OFFICER & RADIATION TECHNICIAN TRAINING DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT 1900479 References: Radioactive Material License UTI900479, License Renewal AppUcation dated Febmary 28, 2007, Training Manual, addendums 9 and 10, Radiation Protection Manual, Section 1, 10CFR20, NRC Regulatory Guide 8.30, NRC Regulatory Guide 8.31, Regulatory Guide 8.15, Utah Administrative Code R313-15. , , • OPENING MEETING DATE //-/O -/ / MEETING MEMBERS NAME DRC/COMPANY CONTACT INFORMATION Q^:^}^ pc^.^.^'^c^ / F:\wp\White Mesa\RADMOD-Training-01 .doc DISCUSSION 2.J77^ -jy TT- •• : L 7 —7" —^ SITE STAFF COMMENTS F:\wp\WhiteMesa\RADMOD-Training-01.doc Po^<> T r.f I T R313-15-101. Radiation Protection Programs. (1) Each licensee or registrant shall develop, document, and implement a radiation protection program sufficient to ensure compliance with the provisions of Rule R313-15. See Section R313-15-1102 for recordkeeping requirements relating to these programs. (2) The licensee or registrant shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members ofthe public that are as low as is reasonably achievable (ALARA). (3) The licensee or registrant shall, at intervals not to exceed 12 months, review the radiation protection program content and implementation. (4) To implement the ALARA requirements of Subsection R313-15-101 (2), and notwithstanding the requirements in Section R313 -15-301, a constraint on air emissions of radioactive material to the environment, excluding radon-222 and its decay products, shall be established by licensees or registrants such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 0.1 mSv (0.01 rem) per year from these emissions. If a licensee or registrant subject to this requirement exceeds this dose constraint, the licensee or registrant shall report the exceedance as provided in Section R313-15-1203 and promptly take appropriate corrective action to ensure against recurrence. TRAINING MANUAL (Appendix J, 2007 License Renewal Revised) Addendum 9: Radiation Safety Training In the ALARA program (Appendix I license renewal) 2.5.2 states that the Radiation Training for new employees will follow NRC Reg. Guide 8.31 section 2.5. NRC REG. Guide 8.31 Section 2.5 Radiation Safety Training All new employees should be instmcted by means of an established course in the inherent risks of exposure to radiation and the frmdamentals of protection against exposure to uranium and its daughters before beginning their jobs. Other guidance pertinent to this course is found in Regulatory Guide 8.13, "Instmction Conceming Prenatal Radiation Exposure" (Ref 10), and Regulatory Guide 8.29, "Instmction Conceming Risks from Occupational Radiation Exposure" (Ref 11). Additionally, the training should be commensurate with the risks and hazards of the task. This course of instruction should include the following topics: 1) Fundamentals of Health Protection • The radiological and toxic hazards of exposure to uranium and its daughters, • How uranium and its daughters enter the body (inhalation, ingestion, and skin penetration), • Why exposures to uranium and its daughters should be kept ALARA. 2) Personal Hygiene at UR Facilities • Wearing protective clothing, • Using respiratory protective equipment correctly, • Eating, drinking, and smoking only in designated areas, • Usirig proper methods for decontamination (i.e., showers). 3) Facility-Provided Protection • Ventilation systems and effluent controls, • Cleanliness of the work place, • Features designed for radiation safety for process equipment, • Standard operating procedures, • Security and access control to designated areas, • Electronic data gathering and storage, • Automated processes. F:\wp\WhiteMesaMlADMOD-Training-01.doc 4) Health Protection Measurements • Measurement of airbome radioactive materials, • Bioassays to detect uranium (urinalysis and in vivo counting), • Surveys to detect contamination of personnel and equipment, • Personnel dosimetry. 5) Radiation Protection Regulations • RegulatoryauthorityofNRC, MSHA, and State, • Employee rights in 10 CFR Part 19, • Radiation protection requirements in 10 CFR Part 20. 6) Emergency Procedures. A written or oral test with questions directly relevant to the principles of radiation safety and health protection in UR covered in the training course should be given to each worker. The instmctor should review the test results with each worker. The instmctor should discuss any wrong answers to test questions with the worker until the worker understands the correct answer. Workers who fail the test should be retested after receiving additional training. These tests and results should be maintained on file. Each pennanent worker should be provided an abbreviated retraining course annually. Documented successful completion of the retraining course should also be maintained on file. Retraining should include relevant information that has become available during the past year, a review of safety problems that have arisen during the year, changes in regulations and license conditions, exposure trends, and other current topics. In addition, all new workers, including supervisors, should be given specialized instmction on the health and radiation safety aspects and on the non-radiological hazards of the specific jobs they will perform. This instmction should be in the form of individualized on-the-job training. Supervisors should be provided additional specialized training on their supervisory responsibilities in the area of worker radiation protection. Retraining should be conducted annually and documented. All employees should sign a statement that they received job-specific radiation safety training. The statement should indicate the dates the training was received and it should be cosigned by the instmctor. Radiation safety matters of concem that arise during plant operation should be discussed with all workers during regular monthly or bimonthly meetings. All visitors who have not received training should be escorted by someone properly trained and knowledgeable about the hazards of the facility. At a minimum, visitors should be instmcted specifically on what they should do to avoid possible radiological and non-radiological hazards in the areas of the facility they will be visiting. Contractors that have work assignments in a UR facility should also be given appropriate training and safety instmction. Contractor workers who will perform work on heavily contaminated equipment should receive the same training and radiation safety instmction normally required of all permanent workers. Only job-specific radiation safety instmction is necessary for contract workers who have previously received frill training on prior work assignments at the facility or have evidence of recent and relevant radiation safety training elsewhere. F:\wp\White MesaMlADMOD-Training-01 .doc 1) Review the Radiation Safety material with the instmctor or attend a training class and identify if each subject is covered. Was the following information covered in the licensee Radiation Safety NRC Reg. Guide 8.31 section 2.5 Yes No Section 1: Fundamentals of Health Protection - The radiological and Toxic hazards of exposure to Uranium and its daughters -How Uranium and its daughters enter the body (Inhalation, Ingestion and Skin Penetration) y Section 2: Personal Hygiene at UR Facilities -Wearing Protective Clothing -Using Respirator Protective Equipment Correctly -Eating, Drinking, and Smoking only in designated areas -Using proper methods for decontamination Section 3:Facility Provided Protection -Ventilation Systems and Effiuent Controls -Cleanliness of the work place -Features designed for Radiation Safety for process equipment X -Standard Operating Procedures >< -Security and Access Control to designated areas -Electronic data gathering and storage X -Automated processes >< Section 4:Health Protection Measurements -Measurements of Airborne radioactive materials -Bioassays to detect Uranium (Urinalysis and in Vivo Counting) -Surveys to detect contamination on personnel and equipment -Personnel Dosimetry Y Section 5: Radiation Protection Regulation -Regulatory Authority of the NRC, MSHA and the State ?^ -Employee Rights in 10CFR19 (R313-18) -Radiation Protection Requirements in 10CFR20 (R313-15) >< Section 6: Emergency Procedures 2) Does the Radiation Protection training cover the information sufficiently to enable onsite personnel to properly implement the Radiation Protection program and the ALARA program? Yes 'T^: No ' Have the employee's demonstrated sufficient understanding of the material to be able to implement the Radiation Protection program and the ALARA programs? Yes No Has this training been properly documented? Yes No Comments: F:\wp\White MesaMlADMOD-Training-01 .doc Section 3.1 Pre-Employment Instmction - Items I and J. 3) Did the licensee provide training to female employees on 'Prenatal Radiation Review'? Comments: ^ Yes ^-^^^ No Training Manual Section 2.0 On-Site Contractors. "New hire training, as outlined in Section 3.1, is included in the training program, as applicable to the site work specifications, for on-site contractors." 4) Has the licensee documented initial training of on-site contractors? Comments: y Yes No r\s/^A-r&, Training Manual Section 3.1 Pre-employment Instmction. "Classroom instmction of all new employees is conducted under the supervision of the Radiation Safety Officer and Safety Coordinator, covering plant and personal safety, including radiation protection." 5) Has the lic^see documented initial training of new employees? ^ / \y ^ ' ^''-"-^^ <^c?L?rc^l^^7:^^ />^->S /iJ o^. 'jZr/l.f^ Yes Comments: /)C>^f,^_^y-: Ccyjrc/l^^TT^^ r/pQ'^ %U Yes /V No 6) Did the licensee provide annual refresher training on'Radiation Protection'? Comments: Yes X No F:\wp\White MesaMlADMOD-Training-01.doc 7) Does the licensee have employee's take a Radiation Safety Test each year? . Is the test documented and kept in the employee's training file? Comments: Record Review 8) Look at the training records. Radiation Safety Name Exams Initial/ Refresher Training Records Personnel Monitoring Prenatal Training/ Pregnancy Form A/A- W7h 3 ^ / ^ y >^ \<r V }x7 X A/A-. Y Additional Comments or Observations: Addendum 10: Respirator Protection Training In the ALARA program (Appendix I license renewal) 2.7.5. states that the Respirator Protection Program win follow NRC Reg. Guide 8.15 NRC Reg. Guide 8.15 Section 5.2 Training A training program, including hands-on training, must be established and implemented for respirator users (see 10 CFR 20.1703(c)(4)). When face-seating respirators will be used, this training should take place prior to fit-testing. As a minimum, each trainee should: • Be informed of the hazard to which the respirator wearer may be exposed, the effects of contaminants on the wearer if the respirator is not wom properly, and the capabilities and limitations of each device that may be used. • Be shown how spectacle adapters, communications equipment, and other equipment that will be used directly in conjunction with the respirator are to be attached and operated properly. • Be able to demonstrate competency in donning, using, and removing each type of respiratory protective device that may be used. F:\wp\White Mesa\RADMOD-Training-01 .doc • Be instmcted in how to inspect each type of respiratory protective device that may be used and be instmcted to perform such an inspection before donning any device. • Be instmcted in how to perform a user seal check on face-sealing devices and be instmcted to perform this user seal check each time this type of device is donned. • Be informed that any respirator user may leave the work area at any time for relief from respirator use in the event of equipment malfunction, physical or psychological distress, procedural or communications failure, significant deterioration of operating conditions, or any other condition that might necessitate such rehef • Be advised that in case of respirator malfiinction or wearer distress, the respirator may be removed as the respirator user exits the airbome contamination area. - 9) Review the Respirator Protection Training rnaterial with the instmctor or attend a training class and identify if each subject is covered. Was the following information covered in the licensee Respirator NRC Reg. Guide 8.15 Section 5.2 Training Yes No Be infonned ofthe hazard to which the respirator wearer may be exposed, the effects of the contaminants on the wearer if the respirator is not wom properly, and the capabiHties and limitations of each device that may be used. Be shown how spectacle adapters, communications equipment and other equipment that will be used directly in conjunction with the respirator are to be attached and operated properly. Be able to demonstrate competency in donning, using, and removing each type of respiratory protective device that may be used. Be instructed in how to inspect each type of respiratory protective device that may be used and be instmcted to perform such an inspection before donning any device. 7 Be instructed in how to perform a user seal check on face-sealing devices and be instmcted to perform this user seal check each time this type of device is donned. Be informed that any respirator user may leave the work area at any time for relief from respirator use in the event of equipment malfunction, physical or psychological distress, procedural or communications failure, significant deterioration of operating conditions, or any other condition that might necessitate such rehef y Be advised that in case a respirator malfunction or wearer distress, the respirator may be removed as the respirator user exits the airbome contamination area. 7- 10) Does the licensee provide training on the 'Respirator Protection Program'? Yes How did they dociLment that training? Comments: ^ No F:\wp\White Mesa\RADMOb-Training-01 .doc Dorro e rvf 10 11) Does the training cover all of the outlined material? If no what needs to be added or expanded? Yes No Comments: — i7>^ -'/4^fLrhK /i^'/~ ^oio-y^ 12) Did personnel that were interviewed have a good knowledge of the Respirator Protection Program? Yes><^' No If no what areas do they need to be retrained in? Comments: 13) Look at the Respirator training records. Name Exams Initial/ Refresher Training Records Medical Clearance Fit Tests X 7>^ X r 7X7 Additional Comments or Observations / V 1 Ar^. ( 1 V ( ?^ Jl is ^f^/^<^ 9f7e^yhJ:^ yy^^/^ . '^^^ "fT^^-C^T^ F:\wp\White M6sa\RADMOD-Training-01 .doc Porro Q n Appendix I (ALARA Program) section 2.4.1 requires that the RSO should have the education, training and experience as specified in NRC Regulatory Guide 8.31. Section 2.5 the RSO shall also receive health and safety refresher training every two years. Section 2.4.2 The Radiation Safety Technician (RST) shall have the qualifications specified in NRC Regulatory Guide 8.31. 14) Who is the RSO's designee when the RSO is not available? /A.^^IA^ Does the named designee have the same RSO education, training and experience as outlined in Reg. Guide8.31? Yes X No Does the RSOs designee receive additional training in health and safety? Comments: ' , Yes X No 15) Do the RSTs have the required education, training and experience as outlinec in Reg. Guide 8.31? Name of RST QualifiedY/N Time in Position Trained Y/N Assigned Duties / ^...^ V Comments: . ^ y-1 / • F:\wp\White Mesa\RADMOD-Training-01 .doc CLOSEOUT MEETING DATE JJ-ZQ - MEETING MEMBERS NAME COMPANY CONTACT INFORMATION ^<zU/^— 1 F:\wp\White Mesa\RADMOD-Training-01 .doc Dorro 11 n DISCUSSION of FINDINGS 7 ^ ^ ' IP • ~~~ ^c-^ ^ .Z^ ^>^>'^ /<i/i^^^ S/yc^^ SITE STAFF COMMENTS F:\wp\WhiteMesaMlADMOD-Training-01.doc Ti.yr,c. n n . Employee Interviews 1) Employee Name Z^/P^/^ ^<^S^^. 2) Employee Job Title ^^/^^ ^TZ^s 3) Length of Employment X /^o-^V^^ 4) Did Employee receive training when hired? Yes "X No 5) Did that training cover Radiation Safety? Yes ^ No 6) Did that training cover Respiratory Protection? Yes No 7) If employed longer than a year, Have they received any refresher training? Yes No^ V^k/^ 8) Did that training cover Radiation Safety? Yes No NA 9) Did that training cover Respiratory Protection? Yes No NA 10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA .^N^^ 11) Where do they wear their dosimetry? /-f- //^^/ 7 • . . . 12) Where do they store their dosimetry? ^^ PU ^j^'^H/y 77/ 13) What are the main types of radiation expected at this facility? ykyf /^^-..g^^ 14) What are the health risks associated with the types of radiation found at this facility? ' 15) What are the main routes of exposure? j/l^^-^s'S , /^•^'/-'^/^^^ rT^^-''^'^ 3 16) How do you limit your exposure? f^/jlL , ^-'^ -^^ w// ^dC-^-S^/Z^, /^c^^'^^/Zs^ 17) Do you use a respirator? Yes No NA >^ ^7^/'>-v, ^^^^--^^ {^J7'Aaz^^''J^'^ < 18) How often do you use a respirator? _ / "n^' ^ 19) How often do you exchange your respirator? ^L^i /9 /^^^jl^-^ 20) Where do you store your respirator? y7b 21) Have the employee demonstrate the proper method for donning and removing a respirator. Have them include any inspection of the respirators and positive and negative checks. Did they do it correctly? Yes No What do you look for when inspecting your respirator? w What do you look for when you do a positive and negative test of your respirator? Additional Comments: U:\rad\C0MM0N\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMillMIP Inspection modules\201 Uhispection Modules\RADMOD- Training-01.doc Employee Interviews 1) Employee Name T^r/lA JU^ 2) Employee Job Titie /^<7.^ '^^ CJ^ Jj^c.^^fi-'^^ 3) Length of Employment u^-^J^S 4) Did Employee receive training when hired? Yes X No_ 5) Did that training cover Radiation Safety? Yes X No 6) Did that training cover Respiratory Protection? Yes y No 7) If employed longer than a year. Have they received any refresher training? Yes No ._ NA^^^ 8) Did that training cover Radiation Safety? Yes No NA 9) Did that training cover Respiratory Protection? Yes_ No NA 10) If applicable did training cover 'Prenatal Radiation Review'? Yes No_ NA^^^^ 11) Where do they wear their dosimetry? (pc^^/cJ-C. /%^cAfJr~^c-^ 12) Where do they store their dosimetry? ^06^ . -A_ /^^j ^J^^^. S ^-^^^ 13) What are the main types of radiation expected at this facihty? ^/^A/.^>w.>t^ y Z^ir,^ /^^^— , h^//'^^-^o 14) What are the health risks associated with the types of radiation found at this facility? /^/•t^-N—- 15) What are the main routes of exposure? ^5%^^^-^— 16) How do you limit your exposure? T^Z^ . /^<>3/Pf 17) Do you use a respirator? Yes No ____ NA 18) How often do you use a respirator? / 19) How often do you exchange your respirator? A/f^ 20) Where do you store your respirator? Z^-^ I/^7^Z^ /.^^^^\ 21) Have the employee demonstrate the proper method for donning and removing a respirator. Have them include any inspection of the respirators and positive and negative checks. Did they do it correctiy? Yes No What do yo^^ look for when inspecting your respirator? What do you look for when you do a positive and negative test of your respirator? /ocP5-(^ ^\^r . Additional Comments: U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMilhHP hspection niodules\201 l\hispection ModulesMlADMOD- Training-01.doc ^ Employee Interviews 1) Employee Name A A:.^ _s 2) Employee Job Titie //'^ 3) Length of Employment 2^ CT^^^ A /^c^^;^>^ 4) Did Employee receive training when hired? Yes No 5) Did that training cover Radiation Safety? Yes 7^ No 6) Did that training cover Respiratory Protection? Yes, ^ No_ 7) If employed longer than a year. Have they received any refresher training? Yes_ XNO NA_ 8) Did that training cover Radiation Safety? Yes No NA 9) Did that training cover Respiratory Protection? Yes No NA 10) If apphcable did training cover 'Prenatal Radiation Review'? Yes_ No NA 11) Where do they wear their dosimetry? 12) Where do they store their dosimetry? CP^ 7^ l^^^^'j^ 13) What are the main types of radiation expected at this facility? ()^ 14) What are the health risks associated with the types of radiation found at this facility? ^cS^/yg- ^s>>^6^y^ '._ 15) What are the main routes of exposure? ^^^^^ Ai^ ^'J^ , ^JS^ 0^(7^9^^ Z'7<7^ I 16) How do you limit your exposure? Ty^^^ , ,^5>/<^^-.^ ^ja/AZ 17) Do you use a respirator? Yes X! No NA 18) How often do you use a respirator? 19) How often do you exchange your respirator? ^^jLnp 20) Where do you store your respirator? 21) Have the employee demonstrate the proper method for donning and removing a respirator. Have them include any inspection of the respirators and positive and negative checks. Did they do it correctly? Yes X^ No What do you look for^hen inspecting your respirator? ' / What do you look for when you do a positive and negative test of your respirator? Additional Comments: U;\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMilhHP hispection modules\201 I Vhispection Modules\RADMOD- Training-01.doc Employee Interviews 1) Employee Name 4^ fZt-^7 ^v.^^ ^ -^ 2) Employee Job Title <X C^y.^y^y - ^'^ 3) Length of Employment ^ ^^c^^ 'y^S 4) Did Employee receive training when hired? Yes No__ 5) Did that training cover Radiation Safety? Yes_^__ No 6) Did that training cover Respiratory Protection? Yes yC No 7) If employed longer than a year. Have they received any refresher training? Yes No NA 8) Did that training cover Radiation Safety? Yes No NA ><r 9) Did that training cover Respiratory Protection? Yes No_ NA 10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA 11) Where do they wear their dosimetry? ^^t^7 -K.—^ , 12) Where do they store their dosimetry? cA(?^ /2^^— i^*^^ ^ 13) What are the main types of radiation expected at this facility? Jy^ Ji 14) What are the health risks associated with the types of radiation found at this facility? .J/^.$7,X< ^7;>^ X 15) What are the main routes of exposure? y?.^//^ U^- y^ y^J^ ^ /^Z^ . 16) How do you limit your exposure? /x<) 7^ ^C/2^ycy( , 17) Do you use a respirator? Yes ^ No NA .. 18) How often do you use a respirator? ^ yy^^J^ ^ t^,^^j^^l_ 19) How often do you exchange your respirator? ^l^tx^x^ y^'^ 20) Where do you store your respirator? /$^^ -^>^ /^^^^/7"Aa 21) Have the employee demonstrate the proper method for donning and removing a respirator. Have them include any inspection of the respirators and positive and negative checks. Did they do it correctiy? Yes No ; , What do you look for when inspecting your respirator? /^/4xL.^, ^, /^-^^^^^ yi.yyi What do you look for when you do a positive and negative test of your respirator? Ar /p^.Jy^ . . Additional Comments: U:\rad\C0MM0N\Uranium millsM le(2)Utl 900479 Denison Mines - White Mesa UMillMiP hispection modules\2011\hispection ModulesMlADMOD- Training-01.doc Employee Interviews 1) Employee Name y7 2) Employee Job Title_ 3) Length of Employment / oj^^^^ /^:^7^—^5 / X 4) Did Employee receive training when hired? Yes No 5) Did that training cover Radiation Safety? Yes No 6) Did that training cover Respiratory Protection? Yes X No 7) If employed longer than a year. Have they received any refresher training? Yes No NA 8) Did that training cover Radiation Safety? Yes No NA 9) Did that training cover Respiratory Protection? Yes No NA X 10) If applicable did training cover 'Prenatal Radiation Review'? Yes _No_ NA^^ 11) Where do they wear their, dosimetry? £P'^ A ^y Syp 12) Where do they store their dosimetry? /^<r x^^ /^^-^ /^^^ 13) What are the main types of radiation expected at this facility? ^i^^^-^^ 14) What are the health risks associated with the types of radiation found at this facility? <^ 15) What are the main routes of exposure? Qj^-J ^xcT 16) How do you limit your exposure? C/iS^ /^^y^JT^^s ^:^^AC^ 17) Do you use a respirator? Yes No NA 18) How often do you use a respirator? 'y^^^^^i^ x^ £^v^<^^^^ 19) How often do you exchange your respirator? \p^7/t^ ,__ 20) Where do you store your respirator? 21) Have the employee demonstrate the proper method for donning and removing a respirator. Have them include any inspection of the respirators and positive and negative checks. Did they do it correctly? Yes y<!^' No What do you look for when inspecting your respirator? ^ ^7/^-€^ What do you look fo^ when you do a positive and negative test of your respirator? yZ^y/c^y. /y^ .o;.^ yhr^Jrs Additional Comments: U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMillMIP hispection modules\201 l\hispection ModulesMlADMOD- Training-01.doc titled: ine of Radioactive Materials David Turk Transportation and Packaging (S(0mSerlO-12,2OlO Approved for continuing education units by AAHP, course Mo. 2008-00-006 Instructor imjtaim<«^^-^^^^ 1 Has successfuCCy com Ronnie B. Nieves ms certificate presen t,^t« La m CaGforma, marcd 26, 2009 cBy 3fe^adaT:ecfmcdM^ Approval codes for C.E. onite are %g6ertHoBway,(Ph7B. Coiim C^rdinator This c e rtifi c at e is presented to D e n i s o n M ^9 n ay a ^ e j ay ^^^ij} recm^nition of comp letion of DUSA's Radiation Technician Trainu Date OINISON MINES This certificate is presented to z e V e s D en i s o n M t^y^^c^ognition of completion of DUSA's Radiation Technician Traini DINISO MINSS This cert ifi cate is presented to af y- Denison M mer *'l'n ^re cogn i ti 0 n oj completion of DUSyi's Radiation Technician T r a i n i ^•:g-7'.fl^^^ Mil LL Date MINES UNITED STATES DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION OSHA Training Institute, Region Vlll Education Center l\/iountain West OSHA Training Center This Certifies that Wayne Palmer has coinpleted a Continuing Education Post Graduate course entitled OSHA 511: Occupational Safety and Health Standards for General Industry February 9-12, 2010 CREDITS: 2.6 CEUs / 4.34 Safety CM Points (ABIH Approval #09-3383) Connie Crandall, MBA, MA Continuing Education Director The University of Utah ^^i^ IVIountain West OSHA Training Center Henry E. Payne Director OSHA Training Institute SHA Occupa^nal Safety «iMf Health AdminlBCraition Assistant Professor SALT LAKE COMMUNITY COLLEGE Page 1 of 1 Ryan, below are a few notes I took during the inspection. Badge Board exposure rate recorded on 11/10/11 @10:30 AM was 14-16 uR/hr, using the Bicron, (don't have the serial or model number, or cal date) 3rd qtr OSL control badge 14 mrem/qtr (See dosimetry report) Year to date 36 mrem Average background dose to public per year at Blanding, Utah: 240 mrem -(this was found in a training section of radiation safety) (Book #13 Radiation Safety manual, page 57 of 102, rev. DUSA 2) "front of your person or the back of your hard hat" We had discussed this with the licensee and they indicated they would remove the "back of your hard hat" location from the safety manual. file://C:\Documents and Settings\rmjohnson\Local Settings\Temp\XPgrpwise\4EC4C62F... 11/17/2011 I (J @!pgloI iHH<z6 998=8z F,q992E] ;ts=*=8; * frl>J =g )mJq{I rm!oI{ Fz -v - -La,htI ocr-@0)o:J io)Ooc ;e-.q(D +-<0e8d --t^ rr:Sdsoo o !.4- (r{f- t$oo< (,)(no 3 cbrl3 @OO =O)O0)5 ooo- CLoEI o:n c>:h6(D:. +a )I3=6rq<o8.a^--o -i: i.@ o o -toarEeg-.JX< oN =.4 (n!?o)'DJ -(,l @@O)o Y (l)@ N)5 CcCczG):ol5:c,o(o o@ -!mfr z toY{(o=Gloo4oaOY(t6 u lqoi \fss\: J ICo trq\ xso >=dl rn'_\ ol -u =iot 6: ar zaea UT 8$ $ fr(r B $ E $ $ $ g !o !o qr tD !! = q! < q! ar (,t r u z ur Ur ut c- sr x (,r l,P P 1\} m N O 6 lll N !- N > N H t\, Z N ct I\t > N -o O E z, @ 2 tr t- o > @ - (.) m (o < 6 =io ? i6 E eeHi$EsE gfi 8Efi EHE5IildsEGEO O>JCl 5<! a.n \t(rd!mE{=--aDe- N _ (o!- o N { o > qt:i6, Lci o r(}<octavFtrD-sEo,'oisFaHeHaisiaE 9EI\r(,rNZrt)+<I\,, --O O Ct j- lPE(o (O aO (4) (O (o (lt (o (o (o >>6 N (r, N O 5 O -r j 57AEE -. - I-e,- -lct7F-c, !ut'DHtt )ennrrcrenur. 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