DRC-2013-001159 - 0901a06880345ad0

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith ^
Executive Director
DIVISION OF RADIATION CONTROL
Rust Lundberg
Director
January 3, 2013
Jo Ann Tischler
Director of Compliance and Permitting
Energy Fuels Resources (USA) Inc
225 Union Blvd., Suite 600
Lakewood, CO 80228
DRC-2013-001159
RE. Radioactive Material License (RML) Number UTI 900479 Health Physics Inspection
RADMOD-Training-01
Dear Ms. Tischler
On December 18, 2012, an inspection was conducted at your facility by Ryan Johnson a
representative of the Division of Radiation Control (DRC) of the Utah Department of
Environmental Quality Observations from the inspection were discussed with David Turk,
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 Rulers, 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
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
[phone]
Sincerely,
Rusty Lundberg, Director ( ) ,
RL/RJrj
Cc Ronnie Neives, Site Radiation Safety Officer
Enclosures
195 North 1950 West • Salt Lake City. UT
Mailmg Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq utah gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module RADMOD-Traming-Ol Radiation Safety Training
Inspection Location Energy Fuels- White Mesa Uranium Mill, Blanding Utah
Inspection Items
Inspection Dates
Inspectors
Personnel Contacted*
New Employee Radiation Safety Training, Respiratory Protection Training,
Refresher Training, Radiation Safety Technician Training and Radiation
Safety Officer (RSO) Training
December 18, 2012
Ryan Johnson, Utah Division of Radiation Control (DRC)
David Turk (Corporate Radiation Safety Officer (CRSO))
Ronnie Nieves (Radiation Safety Officer (RSO))
Justin Perkins (Radiation Safety Technician)
Goveming Documents
• UAC R313-15
• Radioactive Matenals License (RML) UTI900479
• Appllcable Mill procedures and manuals
Opening Meeting
Denison Mines
David Turk (CRSO)
Ronnie Nieves (RSO)
Utah DRC:
Ryan Johnson (Inspector)
Dunng the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed dunng the inspection The Mill was in operation dunng this inspection processing both
ore (Colorado Plateau ore) and altemate feed The Mill staff reminded the inspector of the safety
requirements for the Mill.
DRC Meters Used Model Senal Number Calibration Date
Contamination Ludlum 2360 237303 6/20/12
Dose Rate Bicron B288K 6/20/12
Inspection Summary
The inspection consisted of an RSO interview, review of documentation and a mill tour The
following discussion provides more detail of the specific items
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Item 1. Mill Tour: The inspector walked through the restncted area on a general site tour The
tour included the ore pad, the mill, the altemate feed circuit, the SX building, and the tailings
ponds
Observations: The DRC inspector observed
• Proper PPE was being wom.by Mill employees within all obseryed areas of the Mill,
• Proper Radiological Posting were being used within all observed areas of the Mill; and
• OSL badges were appropnately bemg used by all observed employees at the Mill,
Deficiencies: None
Item 2. Documentation: ^
Employee Training Documentation: The Inspector reviewed the training documentation for the
five randomly selected employees. The Inspector also reviewed the traimng 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
Observations: The Employee training records consisted of the following documentation
• Exams for imtial and refresher trainings for the Radiation Safety and Respiratory
Protection trainmg,
• The MSHA 5000-23 form which is used by the Mill to document that training had been
completed However, Radiation Safety and Respirator Protection training was not recorded
on the forms observed by the inspector in the section of the form marked "Other",
• The Personnel Monitonng form to document that the employee was trained on how to
survey themselves out of the restncted area,
• Prenatal Traimng had been performed (Women only),
• Employee Medical clearances for respirator use, and '
• Respirator fit tests
Recommendations:
• In past inspections, the Mill requested to use the MSHA 5000-23 form to document all
training done at the Mill (training required by MSHA and the DRC) to reduce the amount
of paper work The DRC agreed to this request as long as Radiation Safety and Respiratory
Protection training is also documented on the form. The form has a "Respiratory devise"
section that is used by the Mill for documenting Respiratory Protection and an "Other"
section. Wnte Radiation Safety training in the "Other" section and mark the box.
• As documeiited in past inspections, the Mill does their annual refresher traimng dunng
monthly safety meetings. This practice is appropriate and a good way in fiilfilling the
requirement. The CRSO said in the closeout meeting that Radiation Safety and Respiratory
Protection traimng is done dunng the first quarter The new Mill RSO was not aware of a
set schedule of when this traimng is to be done The Mill needs to develop a schedule that
outlines and documents which months and what radiation safety and respiratory protection
topics are covered dunng the monthly safety meetings
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RSO and Radiation Safety Technician Training Documentation: The Inspector reviewed the
documentation to determine if they met the requirements for the RSO and the Radiation Safety
Technicians m NRC Regulatory Guide 8 31
Observations:
• The CRSO, the RSO and the Chief Chemist (the RSO's designee) have received Radiation
Safety Officer training and were current on refresher training;
• The inspector asked the Chief Chemist if he had a degree from an accredited college or
University, the Chief Chemist's response was that he did not have a degree He has
worked at the Mill for over 20 years but there was no documentation to indicate how many
of those years were working within Health Physics/Radiation Safety NRC Regulatory
Guide 8 31 states that 2 years of expenence can be substituted for one year of formal
education but the expenence needs to be in Health Physics/Radiation Safety Therefore 8
years of Health Physics/Radiation Safety related expenence need to be documented and
kept on file, and
• Radiation Safety Technician staff was being trained and the training was being
documented RST training consists of
o Radiation detection instrument training at Ludlum,
o Hands on training with an expenenced RST, and
o Reading training matenal and taking a test.
/
Recommendations:
• Since Energy Fuels took over the Mill, the RSO is now the CRSO and the Mills Radiation
Coordinator is now the Mill RSO Both individuals meet the requirements for an RSO as
descnbed in NRC Regulatory Guide 8 31 The new RSO informed the inspector that he
will be taking an RSO refresher course in January 2013 It was recommended that the Mill
email a copy of the training certificate when that course is done so the DRC can have a
current copy
• The inspector spoke with one of the Radiation Safety Technicians (RST) In that
discussion, the RST indicated that there has not been a lot of RST training since qualifying
for the position. The Mill needs to develop a continual training program for RSTs
• Document the Chief Chemists Health Physics/Radiation Safety related expenence and keep
the documentation with his RSO training course documentation
Closeout Meeting
Energy Fuels:
Dan Hillsten (Mill Manager)
David Turk (CRSO)
Rormie Nieves (RSO)
Utah DRC:
Ryan Johnson (Inspector)
Findings
None
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Recommendations
The following are DRC recommendations regarding items for improvement.
1 Wnte Radiation Safety traimng in the "Other" section and mark the box of the MSHA 5000-
23 form,
2 Develop a schedule that outlines and documents which months and what radiation safety and
respiratory protection topics are covered dunng the monthly safety meetings,
3 Email the DRC a copy of the training certificate for the RSO refresher course the Mill's RSO
is taking in January 2013 so the DRC can have a current copy, and
4 Develop a continual training program for RSTs This is to keep their job specific traming
current and help them learn and develop additional health physics skills.
5 Document the Chief Chemists Health Physics/Radiation Safety related expenence and keep
the documentation with his RSO training course documentation
Recommendation for Next Inspection
1 Spills (yellowcake and other matenals) being cleaned up in the mill immediately,
2 Personnel Exit Monitonng,
Prepared By
Reviewed By.
Ryan^ Johnson
(Pnnt Name)
Phil Goble
(Pnnt Name) (Signature) (Date)
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UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-TRAINING-01
RADIATION PROTECTION & RESPIRATORY PROTECTION TRAINING/
RADIATION SAFETY OFFICER & RADIATION TECHNICIAN TRAINING
ENERGY FUELS (formally DENISON MINES) - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTI900479
References Radioactive Matenal License UTI 900479, License Renewal Application dated February 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 /2-/if^/-^
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
/ *-
-
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DISCUSSION
SITE STAFF COMMENTS
'nil iopo^^-^ " r^'^^S'S'^ y^^r^J^_ .^^T^^gw / Jjfr^fJT^ i
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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 engineenng controls based
upon sound radiation protection pnnciples to achieve occupational doses and doses to members of the
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 matenal 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
appropnate corrective action to ensure against recurrence >
TRAINING MANUAL (Appendix 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 instructed by means of an established course m the inherent nsks of
exposure to radiation and the fimdamentals 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,
"Instruction Conceming Prenatal Radiation Exposure" (Ref 10), and Regulatory Guide 8 29,
"Instruction Conceming Risks from Occupational Radiation Exposure" (Ref 11) Additionally, the
training should be commensurate with the nsks 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
• Weanng protective clothing,
• Using respiratory protective equipment correctly,
• Eating, dnnking, and smoking only in designated areas,
• Using 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,
• Secunty and access control to designated areas,
• Electronic data gathenng and storage,
• Automated processes
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Porra 1 1 5
4) Health Protection Measurements
• Measurement of airbome radioactive matenals,
• Bioassays to detect uranium (unnalysis and in vivo counting),
• Surveys to detect contamination of personnel and equipment,
• Personnel dosimetry
5) Radiation Protection Regulations
• Regulatory authonty of NRC, MSHA, and State,
• Employee nghts in 10 CFR Part 19,
• Radiation protection requirements in 10 CFR Part 20
6) Emergency Procedures
A wntten or oral test with questions directly relevant to the pnnciples 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 instructor 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 permanent worker should be provided an abbreviated retraining course annually Documented
successfiil completion of the retraining course should also be maintained on file Retraining should
include relevant information that has become available dunng the past year, a review of safety problems
that have ansen dunng 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 instruction on the health
and radiation safety aspects and on the non-radiological hazards of the specific jobs they will perform
This instruction 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 aimually 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 instructor Radiation safety matters
of concem that anse dunng plant operation should be discussed with all workers dunng 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 instructed 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 appropnate training and
safety instruction. Contractor workers who will perform work on heavily contaminated equipment
should receive the same training and radiation safety instruction normally required of all permanent
workers Only job-specific radiation safety instruction is necessary for contract workers who have
previously received full training on pnor work assignments at the facility or have evidence of recent and
relevant radiation safety training elsewhere
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Do^o /I r.f 1 ^
1) Review the Radiation Safety matenal 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)
Section 2:Personal Hygiene at UR Facilities K
-Wearing Protective Clothing >^
-Using Respirator Protective Equipment Correctly >^
-Eating, Drinking, and Smoking only in designated areas
-Using proper methods for decontamination k Section 3: Facility Provided Protection X -Ventilation Systems and Effluent Controls >< -Cleanliness of the work place
-Features designed for Radiation Safety for process equipment ><
-Standard Operating Procedures X -Security and Access Control to designated areas
-Electronic data gathering and storage V
-Automated processes x Section 4:Health Protection Measurements
-Measurements of Airborne radioactive materials y -Bioassays to detect Uranium (Urinalysis and in Vivo Counting) ,x -Surveys to detect contamination on personnel and equipment
-Personnel Dosimetry ><
Section 5: Radiation Protection Regulation
-Regulatory Authority of the NRC, MSHA and the State
-Employee Rights in 10CFR19 (R313-18)
-Radiation Protection Requirements in 10CFR2Q (R313-15) ><
Section 6: Emergency Procedures K
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 ^ No
Have the employee's demonstrated sufficient understanding of the matenal to be able to implement the
Radiation Protection program and the ALARA programs? Yes
Has this training been properly documented*^ Yes No
Comments
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Section 3.1 Pre-Employment Instruction - 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 Yes No
Training Manual Section 3 1 Pre-employment Instmction
"Classroom instruction of all new employees is conducted under the supervision of the Radiation Safety
Officer and Safety Coordinator, covenng plant and personal safety, including radiation protection "
5) Has the licensee documented initial training of new employees'?
Comments Yes \yi No ments Yes \y1
6) Did the licensee provide annual refresher training on 'Radiation Protection"? .
Comments ^^^e:— Yes ^ No
_CLL^ ^ /^^rU $.JA^ ^^C^
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7) Does the licensee have employee's take a Radiation Safety Test each year'? Yes No
Is the test documented and kept in the employee's training file*? Yes ^ No
Comments
ryy\j ~^
^—L
Record Review
8) Look at the training records of the employees who were interviewed
Name Exams Initial/ Refresher
Training Records
Personnel
Monitonng
Prenatal Training/
Pregnancy Form
2 ^
1—**—
^<>
4 " / w 5
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 will 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-sealing respirators will be used, this training should take
place pnor 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 m donning, using, and removing each type of respiratory
protective device that may be used
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• 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 m the event of equipment malfiinction, physical or psychological distress,
procedural or communications failure, significant detenoration of operating conditions, or any
other condition that might necessitate such relief
• Be advised that in case of respirator malfianction or wearer distress, the respirator may be
removed as the respirator user exits the airbome contamination area
9) Review the Respirator Protection Training matenal 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 informed of the 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 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 donmng, using, and removing each type of respiratory
protective device that may be used
/
Y-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 donmng any device
Be instmcted m 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
m 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 relief /
Be advised that m case a respirator malfunction or wearer distress, the respirator may be removed as
the respirator user exits the airbome contamination area
10) Does the licensee provide training on the 'Respirator Protection Program"? Yes V
How did they document that training'?
Comments J>y^r^ /^^^^ J^H^T^^ ^y^J^tJ^ ^ TPi^^^
No
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11) Does the training cover all of the outlined matenal*?
If no what needs to be added or expanded*?
Comments
Yes y< No
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 ^ :P*^ri/jff^
13) Look at the Respirator training records of the employees who were HrtcrvieWed"
Name Exams Initial/ Refresher
Training Records
Medical Clearance Fit Tests
4 y V
^>
Additional Comments or Observations
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Appendix I (ALARA Program) section 2 4 1 requires that the RSO should have the education, training
and expenence 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*? Urr-^
Does the named designee have the same RSO education, training and expenence as outlmed in Reg
Guide 8 31*? ^YQS No _
Does the RSOs designee receive additional training in health and safety*? (
Comments t/ Afi^^ I Z^<_ 'TT a/c ^^'^/i^ /C^V'es No
(L^ ^
/:^^^'^T no ^ ^^'^
15) Do the RSTs have the required education, training and expenence as outlinec in Reg Guide 8 31*?
Name of RST Qualified Y/N Time in Position Trained Y/N Assigned Duties
TVS
^< JU ^^^'^
' A) 1
Comments
/So S.
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Radiation Safety/Respirator Trainer Interviews
1) Employee Name ^3^^^^^ ^/^^^ Cu^^c^c^ ffofy^'^y^
2) Employee Job Title i^^J^-^o^
3) Length of Employment ^^i^ yf^ c^ S ^
4) What qualifications do they have to be a trainer*?
Comments
5) What additional training did the trainer receive when they were hired/assigned to be a trainer*?
Comments
6) How often do they receive refresher training so they are kept up to date on any changes to Utah
Rules, Federal Regulations, or changes in company programs, procedures and policies'?
Comments
7) What IS a passing grade on a tesf? (** 70% or Higher)
Comments
8) How many times is a person allowed to fail a test*? (** 3 times)
Comments
9) How do you document the training you do*? (** attendance sheet, test exams)
Comments
••Denson Mines response to first round Health Physics Interrogatones dated February 5, 2009, question #27
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Radiation Safety Officer Interview
1) Employee Name //o yf /^^/g <;
2) Length of Employment t*r>
3) Does the named RSO have the required education, training and expenence as outlined in Reg Guide
831*?
Comments Yes No
4) Has the RSO received additional training in health and safety every two years'? If so, when was the
last training*? (ask for copy of certificate)
Comments Yes ^ No
5) How often do trainers receive refresher training so they are kept up to date on any changes to Utah
Rules, Federal Regulations, or changes in company programs, procedures and policies'?
Comments
6) How often do you review your Radiation Safety Training program and Respiratory Protection
Program to stay current with applicable State Rules and Federal Regulations*?
Comments ^
2
7) How often do you review the Mills Standard Operating Procedure so that they are current with
appllcable State Rules, Federal Regulations, RML license conditions and the GWQDP*?
Comments
8) How are the Radiation Safety Technicians trained to do their jobs'?
Comments
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1 t
DATE 72-/^-
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
^^^^ /"^^/i
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Po/><. M r.f H
DISCUSSION of FINDINGS
— /it^/*>/u,X- a<y^ cl(^ /^.^/^yd- (SlPc^ .^J>y>^ L^<^ —
SITE STAFF COMMENTS
U \rad\COMMON\Uranium millsM le(2)UTl 900479 EnergyFuels Resources (Denison Mines) - White Mesa DMillMlP Inspection modules\2012Mnspection
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U.S. Department of Labor
Mine Safety and Health Administration
United States Department of Labor
MSHA
Mine Safety and Health Administration
Certificate of Training
MSHA Form 5000-23, Jan 99 (revised)
Persons are not required to respond to the collection of
information unless it displays a currently valid 0MB control
number.
Public reportmg burden for this collection of information is estimated to average 5 minutes per
response, including the time for reviewing instructions, searching existing data sources, gathenng and
maintaining data needed, and completing and reviewing the collection of information This is a
mandatory collection of information as required by 30 CFR Part 48 9 and 48 29 The information
provides MSHA with a momtonng tool for determining compliance requirements The Certificate of
Training provides a means for operators to record and certify mandatory training received by miners
Send comments regarding the collection of information, including suggestions for reducing this burden
to the U S Department of Labor, Mine Safety and Health Administration, Office of Standards,
Regulations and Variances, 1100 Wilson Boulevard, Arlington, Virginia 22209-3939
DO NOT SEND THE COMPLETED FORM TO THE OFFICE SHOWN ABOVE
Certificate of Training U S Department of Labor
Mine Safety and Health Administration
Approved OMB Number 1219-0009, Expires July 31, 2014
This certificate is required under Public Law 91-173 as amended by Public Law 95-164 FailL -" ^ ^ by sections 11 95-164 FaHure to comply may result in penalties and other sanctions as provided 108 and IfO, Public Law 91-173 as amended by Public Law 95-164
Issue Certificate Immediately Upon Completion of Training
Serial Number (for operator's use)
1 Print Full Name of Person Trained (first, middle, last)
2 Check Type of Approved Training Received
^^"efresher • Experienced Miner
I—I New Task
(specify below) •Newly Employed
Inexperienced Miner
I I Hazard Training
r~| Other (specify)
Date Task Initials Date Task Initials
Instr — ^.^-^^ Studt
Instr —•
^—-— Studt
^.--^
^^^^^ ^^-^^
3 Check Type of Operation and Related Industry
A ri Surface fl Construction fl Underground
B •Goal n'^®*3l •Nonmetal
• Shaft & Slope
4 Date Training Requirements Completed
—• If completed, go to item 6, below
• Check if not completed
and go to item 5, below
5 Check Subjects Completed (Use only
I I Introduction to Work Environment
I I Hazard Recognition
I I Emergency Medical Procedures
I \ H&S Aspects of Tasks Assigned
|~1 Statutory Rights of Miners
I I Self-Rescue & Respiratory Devices
I I Transport & Communications Systems
for partially completed training)
•Roof/Ground Control & Ventilation
, , Mine Map, Escapeways, I I Emergency Evacuation, Barncading
I I Cleanup, Rock Dusting
•Mandatory Health &
Safety Standards
, , Authority & Responsibility
\ \ of Supervisors & Miners
Representatives
E] Health
I I ElectricalHazards
Q First Aid
I I Mine Gases
I I Explosives
I I Prevention of Accidents
I I other (specify)
False certification is punishable under
section 110 (a) and (f) of the Federal Mine
Safety & Health Act (P L 91-173 as
amended by P L 95-164)
1 certify that the above training has been completed
(signature of person respohsible for training)
Mine Name, ID, & Location of Training (if institution, give name & address)
Date 1 verify that 1 have completed the above training
(signature of person trained)
MSHA Form 5000-23, Jan 99 (revised)
DENISON MINES
White Mesa Mill
Test for Scanning Name
Date
Score
The umts used to express the release limits for alpha radiation is*?
a Disintegrations per mmute / 1 OOcm^
b Counts per minute /1 OOcm^.
c Disintegrations per minute / 50cm^
d Counts per minute / 50cm^
The units used to express the release limits for beta-gamma radiation is*?
e Coimts per minute
f Disintegrations per mmute
g mr/hr
h None of the above
The release limit for umestncted use for fixed alpha contamination is an average
of
The release limit for umestncted use for removable alpha contamination is
5 The release limit for umestncted use for beta and gamma radiation at 1 cm from
the surface is an average of
6 The maximum radiation level at 1cm from the surface for beta-gamma
contamination is
7 If an alpha meter response is 4,200 counts per mmute on a 15,400 dpm source,
what IS the meter's efficiency*?
8 If that same meter has a detector surface of 50cm^, what is the efficiency factor
associated with that instrument*?
9 The maxmium acceptable surface contamination level (hot Spot) for umestncted
Use for fixed alpha is*?
m
10 T F A removable alpha survey IS required when the fixed alpha levels
exceed 1000 dpm /lOOcm^
11 T F The only vehicles that require scanmng pnor to leaving the
restncted area are those not dnven by mill employees
12 A fixed alpha level of 80 cpm is observed, the meter's efficiency is 15% and the
efficiency factor is 13 What is the alpha value*? Does this require
a removable alpha swipe*?
13 For removable contamination given the following parameters, what is the
removable value*?
1 The instrument's background is 1 cpm
2 For a 15,000 dpm source the meter's response is 3,750 cpm
3 The swipe count is 40
14 Alpha survey instruments have the following essential surface areas
AC-3 alpha probe cm^ (rectangular)
43-1 alpha probe ^cm^ (round)
15 If one were to use either of the alpha survey meters above with exactly the same
efficiency, which would be the most accurate*? Why*?
16 Beta-Gamma measurements are normally what type of radiation*?
a Surface Contamination e B & C
b Alpha Contamination f A & B
c Dose Rate g C&D
d Extemal Exposure h B& D
White Mesa Mill Dat^j^l 2 Revision EFR-2 3
Book #13 Training Manual 63 of 101
O APPENDIX A
RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED INEXPERIENCED
MILL WORKERS
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Book #13 Tiaimng Manual 64 of 101
RADIATION AND RESPIRATORY PROTECTION SAFETY TRAINING OUTLINE ^
FOR NEWLY HIRED INEXPERIENCED MILL WORKERS:
1. Video - *Tractical Radiation Safety" or "Radiation Naturally"
2. Fundamentals of Health Protection
a The radiologic and toxic hazards of exposure to uramum and its daughters
I U-238 is a kidney toxin
II Lungs
ill Liver
IV Skin
b How uranium and its daughters enter the body
I Inhalation
II Ingestion
ill Skin penetration
c Why exposures to uranium and its daughters should be kept ALARA
I Defimtion/explanation of the ALARA pnnciple
II Identification of postings m elevated areas
ill Reference potential hazards with material and why it is important to
maintain levels to ALARA
d Different types of radiation
I Alpha
1 Will not penetrate dead layer of skin
2 Travels about 2 inches m air {)
3 Can be blocked by a single sheet of paper
4 Large particle that is the easiest to protect agamst, but the one that can
cause the most damage when taken internally The delicate mtemal
workings of the living cell forming the limng of the lungs or intemal
organs, most certainly will be changed (mutated) or killed outright by
the energetic alpha particle
5 Housekeeping and good personal hygiene are cntical
II Beta
1 Can be blocked with plastic or PPE
2 Penetration greater than Alpha
3 Can penetrate the first two layers of skm
4 Second largest particle
5 Travels about one meter m the air
ill Gamma
1 Smallest in size
2 Can be blocked by lead
3 Is capable of damaging living cells as it slows down by transferring
energy to the surrounding cell components
IV Radon Progeny
1 Inert gas
2 Transported by camer (water, diesel smoke, etc )
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White Mesa Mill Date^^l 2 Revision EFR-2 3
Book #13 Training Manual 65 of 101
3 Ventilation is principle remedy
4 Found in soils worldwide
e Various types of radiation exposure potential at the Mill
I Conventional Ore - stockpiles and m process
II Yellowcake product - in process and fmal product
ill Altemate feed materials - stockpile (by vanous supplier) and in process
IV Miscellaneous - sealed sources
3. Personal Hygiene at the White Mesa Mill
a Weanng protective clothing
I Importance - how the PPE protects against Alpha and/or Beta/Gamma
activity
II Types of PPE available
1 Tyvex
2 Coveralls
3 Rubber suits/gloves
4 Respiratory Protection
b Usmg respiratory protective equipment correctly - See item 4
c Eating, drinking and smoking only m designated areas
I Regulated by the State of Utah and MSHA
II Weekly alpha survey
Ul Reducing potential for exposure
IV Wash hands regardless of job assignment
d Using proper methods for decontamination
I Showers requirements
1 Mandatory for Yellowcake Operators
II Laundry facility
4. Respiratory Protection Training
a General
I Video on Respiratory Protection
II Program evaluation and revisions and record keeping
III Employee training and documentation
IV Fit Testing
1 Medical Clearance
2 Fit Tester 3000
3 Irritant smoke
V Exchange/Issuance requirements - Daily Exchanges are required for all
devices
VI Storage and care of device
b Hazards 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
1 Respiratory Hazards
1 Uranium airborne and effect
2 Radon daughters and effect
White Mesa Mill Date^^l2 Revision EFR-2 3
Book #13 Training Manual 66 of 101
3 Chloride and effect
4 Ammonia and effect
5 Airborne vanadium dust and effect
6 Acid gases and effect
7 Other potential effects
11 Respirator selection
1 Types of respirators, their function, limitations
a Full-face with combo cartridges - good for all environments at the
facility (pf of 50)
b PAPR's - good for only dusty environments, not good for any
environment that may contain chemical mists (pf 1000)
c SCBA's - good for all environments, has only thirty minute bottle of
air (pf 10000)
d NIOSH and MSHA approved respurators only
2. Identification of hazards
a O2 content
b Routine hazards
c Non-routme hazards
c Spectacle adapters, communications equipment and other equipment that will be
used directly m conjunction with the respirator are to be attached and operated
properly
1. At the White Mesa Mill, we only use the spectacle adapters Spectacle
adapters are used for individuals who have prescription eyewear The
adaptor is used so that there is not an issue with the arms of the glasses
potentially breaking the seal of the device
II Each employee who has to wear prescription eyewear must present a copy
of their current prescnption to the Safety Department and the devices will be
ordered
III After the spectacle adapter has amved, the Safety Department will tram
each wearer on the proper care, maintenance and installation of the device
This training is documented with a signed traimng certificate by both the
instmctor and wearer and the document is then placed in the file m the
Radiation Office files
d Demonstration in donmng, using and removing each type of respiratory protective
device that may be used
1 Weanng Instmctions and training
1 Donning, wearing and removing the respirator
2 Adjusting the respirator so that its respuratory-inlet covenng is properly
fitted on the wearer and so that the respirator causes a mimmum amount
of discomfort to the wearer
3 Allowing the respirator wearer to wear the respirator in a safe
atmosphere for an adequate penod of time to ensure that the wearer is
familiar with the operational characteristics of the respirator
4 Have each employee perform the donning for each device they may have
to wear while on property
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Book #13 Training Manual 67 of 101
e Instmction m how to inspect each type of respiratory device that may be used and
be instmcted to perform such an inspection before donning any device
1 Field Inspection
1 Valves
2 Body of Mask
3 Straps
4 Lens
5 Air lines
IX. Respirator Seahng Problems
1 A person who has hair (stubble, mustache, sideburns, beard, low
hairline, bangs) which passes between the face and the sealing surface of
the face piece of the respirator shall not be permitted to wear such a
respirator
2 A person who has hair (mustache, beard) which interferes with the
function of a respirator valve(s) shall not be permitted to wear such a
respirator.
3 A spectacle which has temple bars or straps which passes between the
sealing surface of a respirator full face piece and the wearer's face shall
not be used
4. A head covering which passes between the sealing surface of a respirator
face piece and the wearer's face shall not be used
5 The wearing of a spectacle, or goggle, a face shield, a welding helmet, or
other eye and face protective device which interferes with the seal of a
respirator to the wearer shall not be allowed
6 If scars, hollow temples, excessively protmdmg check bones, deep
creases in facial skin, the absence of teeth or dentures, or unusual facial
configurations prevent a seal of a respirator face piece to a wearer's face,
the person shall not be permitted to wear the respirator
7 If missing teeth or dentures prevent a seal of a respirator mouthpiece in a
person's mouth, the person shall not be allowed to wear a respirator
equipped with a mouthpiece
8 If a person has a nose of a shape or size which prevents the closing of
the nose by the nose clamp of a mouthpiece/nose clamp type of
respirator, the person shall not be perrmtted to wear this tyipc of
respirator
k Instmction m how to perform a user seal check on face sealing devices and how
to perform this user seal check each time this type of device is donned
1 Refer to "d" of this section.
2 Demonstrate the proper techniques for performing a field positive and
negative pressure test
3 Have each employee perform this task (pass/fail)
4 Emphasis to each employee the importance of perfomung this task each and
every time the^seal has been broken.
1 Information that any respirator user may leave the work area at any time for relief
from respirator is m the event of equipment malfunction, physical or
White Mesa Mill Date J|U 2 Revision EFR-2 3
Book #13 Training Manual 68 of 101
psychological distress, procedural or commumcations failure, significant
deterioration of operating conditions, or any other condition that might necessitate ^<*v
such relief \_J
1 A respirator wearer shall be permitted to leave the hazardous area for any
respirator-related cause. Reasons which may cause a respirator wearer to
leave a hazardous area include, but are not limited to, the following
a Failure of the respirator to provide adequate protection
b Malfunction of the respirator
c Detection of leakage of air contaminant into the respirator
d Severe discomfort in weanng the respirator
e Increase resistance to breathing
f Illness of the wearer, including sensation of dizziness, nausea, weakness,
fatigue, breathing difficultly, coughing, sneezing, vomitmg, fever or chills
g Claustrophobia, anxiety or other psychological factors that may affect the
wearer
h Emergency respirator use
I SCBA - Self-Contained Breathing Apparams
II Emergency respirator issuance
III Only Certified individuals may use these devices
Be advised that m case of respirator malfunction or wearer distress, the respirator
may be removed as the respirator user exits the airborne contanunation area
m. Each respirator wearer must understand that during any problem with the device
or distress, the device can be removed upon exiting the contamination area A
report of the incident should be given the Safety Watch and the Safety
Department immediately Cj
5. Facility Provided Protection
a Ventilation systems and effluent controls
1 Explain the Demister and Scmbber system
11 Negative pressure is Yellowcake Dryer and Packaging Enclosures
b Cleanliness of the work place
I ALARA and the importance of the prmciple
II Prevention of the spread of materials
ill Wash down of work areas
IV Prompt notice and cleanup of matenals if spilled
V Wash hands regardless of job assignment
c Features designed for radiation safety for process equipment
I Ventilation system m the process areas
II Remote access for packaging operations
d Standard operating procedures
I Each circuit's SOP addresses the specific radiation concems
II Knowledge of the SOP's and radiation concerns of one's circuit is
needed prior to commencement of any work activity
Ul Radiation Work Permit (RWP)
e Secunty and access control to designated areas
1 Restricted Area requirements
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White Mesa Mill Dat^^l 2 Revision EFR-2 3
Book #13 Training Manual 69 of 101
11. Identification cards needed to access the Restricted Area
111 Access to the Product Storage Yard
IV. Surveillance cameras around the facility
V 24 hour coverage by a member of the Radiation Staff
f Electronic data gathermg and storage
g Automated processes
1 Nuclear Density Gauges
h Postmgs
I "Radioactive Matenals Area" - This sign designates the Restricted
Area and sigmfies that one may come in contact with radioactive
materials once one has pasted the signage
u "Caution Radiation Area" - Beta/Gamma values at or above 5 0
mR/hr This posting means reduction in time and increase distance
from source or added shielding is required.
Ill "Caution Airbome Radioactivity Area" - Alpha activity value at or
above 25% of the corresponding DAC value Respirators required
prior to entering area and increased bioassays
6. Health Protection Measurements
a Measurements of airbome radioactive materials
1. Alpha Monitoring
II Area Airborne
III Radon Progeny
IV Beta/Gamma
V Breathing Zones
b Bioassays to detect uranium (urinalysis)
I Entrance/Exit Momtonng
II Schedule
1 Monthly dunng production penods for all employees
2. Bi-monthly for employees working in ore handling and yellowcake
packaging operations Also for declared pregnancy workers.
III Action limits of uranium detection in the bioassays
1. 0tol4|xg/L
a Continue to review further bioassay results
2. 15 to 35 (xg/L
a Obtain additional sample
b. Identify the cause of the elevated sample
c. Examine air sampling data to determine the source of intake
d. Determine if other workers could have been exposed
e Consider work assignment linutations
f. Improve uranium confinement controls or respiratory
protection
3. Over 35 (xg/L
a. Take actions given above
b. Continue operations only if it is virtually certain no other
worker will exceed the concentration
White Mesa Mill Datejj^l 2 Revision EFR-2 3
Book #13 Training Manual 1^ 70 of 101
c Establish work restrictions for affected employees
d Weekly bioassays
IV Investigation of potential uptake \^
V Mitigation of uptake
c Surveys to detect contamination of personnel and equipment
I Exit Alpha Monitoring - leaving the Restncted Area
II Break Times - Entering into an designated eating area
ill Spot checks
IV Equipment releases and the limits for the facility
1 Alpha Personnel Release Rate (1,000 dpm/100 cm^)
2 Alpha values for umestncted release
a Removable 1,000 dpm/100 cm^
b Average 5,000 dpm/100 cm^
c. Maximum 15,000 dpm/100 cm^
3 Beta/Gamma limits for unrestricted release
a Average 0.20 mR/hr
b Maximum 1 0 mR/hr
d Personnel dosimetry
1 OSL
e Potential Sources of Exposure at the facility
I Conventional Ore Dust
II Alternate feed materials
III Yellowcake
IV Tailings
V Obsolete Equipment iy
f Ways to reduce exposure
I Time - limiting the amount of time one spends in a given work
environment Example is only allowing a certain amount of time to be
allowed in an RWP
II Distance - creating a separation between one self and the source of
exposure Example is remote handling of matenal
III Shielding - placing a bamer between one self and the source
Example is a respirator
7. Radiation Protection Regulations
a Regulatory authonty of NRC, MSHA and State of Utah
b Employee nghts m 10 CFR Part 19
c Radiation protection requirements m 10 CFR Part 20
d State of Utah R313 mles
e 30 CFR Parts 47 and 56
f Previous Radiation Exposure Information requests
8. Emergency Procedures
a Emergency Response Plan
b Facility notification cards
c Decontamination procedures during an emergency
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White Mesa Mill Date^Jl 2 Revision EFR-2 3
Book #13 Training Manual ^P 71 of 101
9. Alpha Contamination Training
a Proper use of the personnel alpha monitor
b What to do if the alarm were to sound and who to contact
c Documentation of the training session and acceptance of possible disciplinary
actions for failure to comply with the regulation
10. Prenatal Radiation Exposure
a Presentation of NRC information (see Appendices I and J)
b Discussion of increased monitoring
c Completion of Form
11. Any Handouts
12. Radiation Protection Quiz
13. Respiratory Protection Quiz
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White Mesa Mill Dat^^l 2 Revision EFR-2 3
Book #13 Training Manual ^P ^P 72 of 101
APPENDIX B
o FORMS
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White Mesa Mill Dat^Pl2 Revision EFR-2 3
Book #13 Training Manual ^ ^ 87 of 101
APPENDIX E
RADIATION SAFETY TRAINING OUTLINE FOR ANNUAL REFRESHER TRAINING
The following topics will be discussed m this training
1 Relevant information that has become available during the past year
(a) Processing changes that may affect exposures
(b) Posting changes, if any
(c) Discussion of air, radon and beta/gamma survey results
(d) Changes to SOP's that affect Radiation Safety
2 Review of safety problems that have arisen during the year
(a) Discuss issues that have been raised through daily and weekly inspections
(b) Housekeeping issues
(c) RWP's
3 Changes in regulations and license conditions
(a) Discuss changes that affect the operation or other activities m the Mill
(b) Discuss NOVs or recommendations from the DRC
4. Exposure trends
(a) Average exposure for the previous year
(b) Highest exposure for the previous year
(c) Comparison of exposures versus background
(d) Discussion on the exposures rates received and how those results compare with the
ALARA goals
5 Other current topics
(a) Discuss any problem areas that may have arisen
6 Review of Key Radiation Safety Topics
(a) At the discretion of the instmctor, selected key radiation safety topics, such as one or
more of the topics listed on the handouts included m Appendix C or on the Radiation Safety
Training outline set out as Appendix A, may be reviewed
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West Door PERSONNEL TO BE ALPHA SCANNED Date.
Your Initials will be placed in the box with the corresponding name if the survey indicates no contamination
If the aiarm sounds, resurvey If the alarm sounds again, contact shift foreman, RSO, or radiation staff
There must be an entry fbr each and every survey conducted The person assigned to observe the
monitoring or personnel snail sign and date this form
Launa Armstrong
April Arthur
Leron Atcitty
Roy Atcitty
Matt Atwood
Craig Barlow
. Amanda Bailey
Joel Bayles
David Beaver
Shawn Begaye
Tenaya Begay
Jacoby Ben
Jaymes Benally
Jerome Benally
Johnson Benally
Kendall Benally
Matthew Benally
Herschel Bennett
James Billsle
Ted Black
Tyrone Blackhorse
, Kaluni Blackhorse
Verdale Boy
Ken Brown
Tyler Bunting
Blake Burtenshaw
Albert Bylilly
Salvador Cerros
Marvin Charley
Scot Christensen
Nathaniel Clah
Benjamin Clinger
Lyman Cosby
Jordan Cowboy
Tremayne Cowboy
Chuck Dayish
Bobby Denny
Messiah Eddie
Lane Fowler
Nathan Frisbie
Brett Gappmayer
Michelle Grat
Greg Hamann
Wade Hancock
Ramon Hatalie
Randy Hathale
Blam Hawkins
Ben Haws
Chad Haycock
Steven Helquist
Dan Hillsten
Nona Hillsten
Kyle Holiday
Tanner Holliday
Theo Holiday
Wayne Holiday
Thayne Holt
Noah imel
Macen Ingels
- Floyd Jaramillo
Zack Jensen
Gerald Joe
Robbie John
Terry John
Christine Jones
Jayrando Jones
Jeremy Jones
Kenneth Jones
Lorenzo Jones
Sheridan Jones
Sterling Jones
Stan Jones
DannerJune
Clittord Kaye
Paul Kemner
Charles Keith
Shawn Keith
Tad Kreth
David Lacy
Karson Lacy
^ Megan Lacy
Tully Lameman
Zackery Lameman
Dann Laws
James Laws
Heath Lathem
Chad Uttle
Mike Uttle
Tyrone Little
David Lyman
Miltred Maryboy
Sinn Mays
Abel Mendoza
Abel Mendoza Jr
Billy Mendoza
Renaldo Mix
Cortney Montella
Timothy Morris
Watson Mustache
Ivan Nakai
Kevin Nez
Henry Neal
Arden Nielson
Ronnie Nieves
Travis O'neil
Truitt Qshley
Ttsdale Qshley
Chad Palmer
Derick Palmer
Garrin Palmer
Wayne Palmer
Oliver Parker
Chad Perkins
Justin Perkins
Tyrel Pilling
Milton Pipkin
Roydale Paul
Travis Plott
Jordan Rock
Phillip Rentz
Dustin Reed
Kenny Roberts
Sheldon Scalplock
Marlon Shepherd
Loutse Shonnie
Grady Shumway
Logan Shumway
Philbert Simpson
Wesley Simpson
Casey Singer
Chance Singer
Terry Slade
Steve Snyder
Herbert Stanley
Gage Sterling
Michael Stevens
Aaron Taylor
Josh Taylor
Pernell Tsosie
David Turk
Rita Valenzuela
Georgia VanReenen
James Vanreenen
Lance Vijil
Deanna Walker
Collin Warner
Frank Warren
Jakob Watermann
Cornelius West
Deswood West
Nick Whitehorse
Clearence Yellow
Roger Yazzie Jr
Ryan Young
•""Alison Zohnnie
Supervisor's Signature