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Home My WebLink AboutDRC-2012-001901 - 0901a06880307b9bState of Utah GARYR HERBERT Goveinor GREG BELL Lieutenant Governor Department of Environmental Quality Amanda Smith Executive Director DRC-2012-001901 DIVISION OF RADIATION CONTROL Rusty Lundberg Director January 30, 2012 David Frydenlund Vice President and General Counsel Denison Mines (USA) Corp 1050 Seventeenth Street, Suite 950 Denver, Colorado 80265 RE DRC Inspection Module RADMOD-IEM-01, January 18 through January 19, 2012, RMLUT1900479 Dear Mr Frydenlund Inspection Module RADMOD-IEM-01 was conducted January 18 through January 19, 2012, by the Division of Radiation Control (DRC) at the White Mesa Mill The inspection focused on the Mill's radiological air monitonng, bioassay program and use of personnel dosimetry Although several discrepancies were noted, all items inspected met applicable regulatory requirements and site procedures A copy of the Inspection Report is attached outlining these discrepancies 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 concems regarding this letter, please contact Kevin Carney at (801) 536-4250 UTAH RADIATION CONTROL BOARD Rusty Lundberg, Executive Secretary RL/KJC kc Enclosure cc David Turk, Site RSO 195 North 1950 West • Salt Lake City, UT Maihng Address PO Box 144850 • Salt Lake City UT 84114-4850 Telephone (801) 536-4250 • Fax (801-533-4097 -TDD (801) 536-4414 11 u \\ deq Utah gtn Printed on 100% recycled piper INSPECTION REPORT Inspection Module RADMODIEM-01 Inspection Location White Mesa Mill, Blanding Utah RM License UT1900479 Inspection Items Internal and External Monitonng Inspection Dates January 18 through 19, 2012 Inspectors Ryan Johnson, Kevin Carney, Utah Division of Radiation Control (DRC) Personnel Contacted David Turk, Ron Nieves and Dan Hillsten Governing Documents Radioactive Matenal License UT1900479, Amendment 4 NRC Regulatory Guide 8 13 NRC Regulatory Guide 8 22 White Mesa Mill Radiation Protection Manual, Section 5 Utah Administrative Code R313-15 Utah Administrative Code R313-12-3 10CFR20 Inspection Summary The inspection was a venfication of compliance with Utah Rules, 10CFR20, NRC Regulatory Guides 8 13 and 8 22 and White Mesa Mill (the Mill) procedures as they pertain to air sampling, bioassay sampling and external monitonng at the Mill The inspection consisted of a review of records, site observations and interviews with the Radiation Protection Staff as well as other personnel on site Discrepancies Several discrepancies were noted dunng the inspection These discrepancies are hsted below and will be discussed under the Findings section m this document • Elevated DAC values on Breathing Zone (BZ) samples • Documentation of abnormal circumstances • Timely unnalysis sampling Inspection Items The inspection was divided into three main sections • Air Sampling • Bioassay Program • External Monitonng 1 of Page 3 C \Documents and Settings\kcamey\My DocumentsM Ie2 RMLs\Denison - White Mesa\lnspections\2012 lnspections\rEM-OI\lEM-OI Inspection Report 1-18-2012 doc The inspection outlines are noted below according to section Air Sampling The inspection consisted of a review of records of BZ and General Area (GA) air sampling inside the Mill's Restncted Area (RA) as well as personal external monitonng devices (OSL badges) Although the Mill's sampling program was found to be properly managed, discrepancies were found regarding elevated DAC values at the Yellowcake Packaging Enclosure and the North Alternate Feed Pad These are discussed in the Findings section below Bioassay Program The inspection looked at the Mill's uranium unnalysis program Although the Mill's bioassay program was found to be sound, it was found that several employees' bioassay samples were not collected within the frequencies set forth in the Mill's Radiation Protection Manual dunng 2011 These are discussed in the Findings section below External Monitonng The inspection looked at the Mill's use of Optically Stimulated Luminescence (OSL) badges for monitonng external personnel exposure Workers were found to be weanng and stonng their OSL badges appropnately No discrepancies were noted under this segment ofthe inspection Findings Air Sampling Dunng a records review of BZ sample results, it was discovered that several BZ samples showed elevated DAC values Most notably were a value of 5,184 85% DAC at the Yellowcake Packaging Enclosure on December 10, 2011 and a value of 7,267 41 % DAC on August 8, 2011 at the North Alternate Feed Pad In either case, the areas were posted as Airborne Radioactivity Areas and the BZ wearers were weanng appropnate respiratory protection at the time these samples were taken The inspectors discussed these findings with the Mill's RSO and stressed that the Mill need's to evaluate these values and develop methods to keep exposures ALARA Bioassay Program 1) Dunng the records review of bioassay unnalysis sampling, it was noted that there was an employee whose unne sample was never collected This was discussed with the RSO who informed the inspectors that the employee had been incarcerated at the time his sample was to be collected Therefore, due to this abnormal circumstance, the Mill was unable to obtain the employee's sample There was no documentation of this situation or any wntten explanation of the circumstances The inspectors suggested that the Mill document these types of situations as they occur to prevent having to explain them at a later date and thereby rely solely on memory The RSO concurred 2) Dunng the records review of bioassay unnalysis sampling, it was noted that several employees' unnalysis samples were given later than required (for example within 2 weeks from working under an RWP in an area with airborne concentrations > 25% DAC) In all cases, unne samples 2 of Page 3 C \Documents and Senings\kcamey\My DocumentsM le2 RMLs\Denison While Mesa\lnspections\2012 lnspections\IEM-01\IEM-OI Inspection Report 1-18-2012 doc were collected a short time later The RSO was advised that the HP Staff needs to be more diligent in collecting unne samples in a timely manner External Monitonng No findings were noted under this segment of the inspection Conclusion and Recommendations No violations are recommended for this inspection The findings noted were of a minor nature and the RSO's outlook on addressing the findings was reasonable to the inspectors The RSO was notified that these issues would be revisited dunng subsequent inspections Recommendation for Next Inspection 1 Check BZ results at YC Enclosure and North AF Pad 2 Check records for abnormal circumstances 3 Check unnalysis frequencies Inspection Note At the time of the inspection, the Mill was hosting a tour of the facility by members of several govemment agencies m preparation for a future IAEA visit The DRC inspectors' Mill tour was conducted concurrently with the group tour Dunng the Mill tour, several members of the tour group were bothered by some of the pungent chemical odors throughout the Mill The Mill Staff agreed that some people who tour the Mill are sensitive to the chemical odors that occur throughout their process However, they are confident that the levels of airborne hazardous matenals are within all regulatory parameters An NRC representative on the tour voiced concems to the inspectors about this issue and asked if the DRC had a Memorandum of Understanding with OSHA The inspectors informed the NRC representative that we did not have a MOU with OSHA On January 30,2012, the DRC forwarded these concems to the Mine Safety and Health Administration (MSHA) Prepared By Kevin Carney Ryan Johnson Reviewed By Phillip Goble January 30, 2012 - January 30. 2012 January 30, 2012 3 of Page 3 C \Documents and Settmgs\kcamey\My DocumentsM Ie2 RMLs\Denison - White Mesa\lnspeclions\2012 lnspections\IEM-OI\lEM-OI Inspection Report 1-18-2012 doc < /^/3//rr A-L5 y<^Pl^^j 'ZA^C^Y ^^AJ^ r A* 1 ! i ! ! 1 • • - • • - • - f • /