DRC-2018-013511 - 0901a0688097b71a

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
lieutenanl Governor
Kathy Weinel
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
December 5, 2018
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-RWP
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
FILE COPY
On November 26, 2018 and November 27, 2018, an inspection was conducted at your facility by a
representative of the Division of Waste Management and Radiation Control. Observations from the
inspection were discussed at the closeout meeting with White Mesa Uranium Mill staff. The inspection
was an examination of the activities conducted at the facility as they relate to compliance with Utah's
Radiation Control Rules, the license conditions of the referenced license 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 for your review. The Division considers this inspection closed. The
Division would like to thank the Mill staff for their cooperation during this inspection.
If you have any questions, please contact Ryan Johnson at [phone] or by email at
"[e-mail]".
Sincerely,
,C:.ACC:2
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
DRC-2018-012452 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.11.tah.gov
Printed on I 00% recycled paper
(Over)
STA/RMJ/kb
Enclosure: RADMOD-RWP Inspection Report (DRC-2018-012473)
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer
Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
INSPECTION REPORT
Inspection Module: RADMOD-R WP: Radiation Work Permits
Inspection Location: Energy Fuels -White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Work Permits and Supporting Documentation
Inspection Dates: November 26 & 27, 2018
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted:
Terry Slade, Energy Fuels Resources Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Justin Perkins, RST
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UTl900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Terry Slade (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. The Mill was not operating and maintenance activities were being
performed. The Mill staff reminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 6/15/2019
Inspection Summary
The inspection consisted of a RSO interview, reviewing documentation and a mill tour. The following
discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The inspector reviewed RWPs from the beginning of 2018 to
present.
Observations: The DWMRC inspector observed:
• The Mill's RWPs were appropriately filled out and contained the following information:
o A unique identification number;
o The date the R WP was issued;
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o A description of the work to be done;
o The location were the work is to be done;
o Identified the personnel working on the job being done and how much time they were
working on the specific job assignment;
o The estimated time that it would take to do the job;
o The PPE requirements for the job;
o The radiological and occupational monitoring requirements for the job;
o The radiation technician observations and surveillance of the job; and
o The RSO's signature indicated that he reviewed everything associated with the work
that was done under the R WP.
• Other documents attached to the RWPs included:
o The Mill's Safe Work permits, which document occupational safety concerns;
o The Mill 's Confined Space Work permits (when applicable); ·
o Lock out/tag out information (when applicable);
o Breathing Zone air sample results (when applicable); and
o Bio assay results of personnel working on the RWP (when applicable).
• All forms that were observed were legible and complete.
Deficiencies: None
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the tailing cells, solvent the extraction building and the alternate feed
circuit.
Observations: The DWMRC inspector also observed:
• Alternate feed being stockpiled on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE.
Rd' I . I d. b a 10 021ca rea 1m~s o serve d d . M01l urme I tour
Location Dose Rate (a.LR/hr)
Ore Pad 500
Mill 150
Product Yard 480
Tailine lmpoundment # I 15
Tailine lmpoundment #3 900
Deficiencies: None
Item 3. Other Items: During the Inspection the Inspector was able to observe the tailing
impoundment's leak detection systems being vacuumed out, observed the alternate feed storage areas
and checked on the startup of the Vanadium Circuit.
Observations: The DWMRC Inspector observed with the leak detection system:
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• Tailing impoundmcnt # I leak detection pipe being vacuumed out \\.ith a large ,acuum truck:
o I he contractor had to use pre urized \\ater on t\\O different occasions to loo en up the
mud and debris; and
o fl to k the contractor three times to vacuum all of the debris and v.ater out of the leak
detection pipe ;
• Tailing impoundment #3 leak detection pipe being vacuumed out with a large vacuum truck;
o No water was used but it did take the truck two attempts to vacuum out the debris; and
• The Inspector did not observe the leak detection pipe for tailing impoundment #2 being
vacuumed out.
The DWMRC Inspector observed with the alternate feed storage
• Call:ine. Regen. KF. Sequoyah Fuels. Dawn Mining and Fansteel alternate feeds are current!)
at thc Mill :
• A II alternate feeds are being stored on the ore pad:
• Calcine. Regen and KF are being tored in drums: Sequoyah Fuels and Da>v\n Mining are being
stored in supcrsacs; and Fansteel is in a large pile: and
• The drum s and the supersacs appear to be in good condition and the pile of Fansteel is covered
"'ith top soil.
The Vanadium Circuit is not operating but will be soon.
Deficiencies : one
Closeout Meeting
Energy Fuel :
Logan Shum,\a) (Mill Manager)
Terr) Slade (R. 0)
Garrin Palmer (R. I)
Utah DWM RC:
Ryan Johnson (Health Physics Inspector)
Find ings
None
Recommendation for Next Inspection
I. Spills (ycllow<.:ake and other materials) being cleaned up in the mill immediately:
2. Personnel Exit Monitoring; / i
Prepared By: Ryan Johnson ~ _.---// -2 9 -,7 <> /'is
(l'cint Name) P , ~re~/ (Date)
Reviewed By : Phil Goble ~ ___ ;;__h-r /-z~l?
(Print ame) ( ignalure) (Date)
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(' -l 's.:r<·rmjohn,llll I),"' nlum.blln,pc~tion Repon Rt\DMOD-R WI' 11 -27-2018-p~ (I) due(
.UTAH DIVISION OF 'WASTE MANAGEMENT AND R).(DIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-R WP
RWPs and EXTERNAL MONITORING
ENERGY FUELS RESOURCES -WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Ref rences: Radioactive Material License UTl 900479, License Renewal Application dated February 28, 2007,
R '.diation Protection Manual, Section 5, 1 OCFR20, NRC Regulatory Guide 8.30, NRC Regulatory Guide 8.3 1,
·Jta:h Administrative Code R3 l 3-l 5.
DA TE //-it-2& ;g Opening Meeting
MEETING MEMBERS
Name Organization Telephone No. Email Address
/. !e/9 stJe cr/tL
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DISCUSION
SITE STAFF COMMENTS
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Mill Tour
1) During the Mill tour observe general dose rate/contamination measurements and record.
~;rea of the Mill Dose Rate (µR/hr)/
Contamination
( dpm/100cm2)
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DRC Meters Used Model Serial Number Calibration Due Date
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Dose Rate Ludlum 19 /& l(/J--:J,-7 It -rs--u;/~;
RADIATION WORK PERMITS (Appendix E Section S, 2007 License Renewal)
Rad;,·1tion Protection Manual Section 5 Radiation Work Permits (RWPs) (Appendix E license renewal)
~: .: According to the Radiation Protection Manual R WPs are required to contain the following information and
copies of the RWPs are kept on file for five years. Review RWPs from the past year. Verify (Yes or No)
that the forms contain all of the information that is required.
Date RWP Work to Location
Number be Done of Work
Duration
of Work
Personnel
Working
PPE Monitoring
Required Required
RSO
Signature
3) Were all of the RWPs that were reviewed complete? Yes No
Comments: .--
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4) Was supporting documentation (i.e. Safe Work Permits and Confined Space Permits) attached to the RWPs?
Comments: Yes )(, No
S) Were,non-applicable items on the RWPs lined out or marked with an NA?
Comments:
6) Does the R WP form adequately cover all of the information required?
Comments:
Yes >{ No
Yes_){__ No __
7) On average, how much time does the RSO and Radiation Safety staff has to review requests for R WPs
before they approve them?
Comments:
,1Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT 1900479 EnergyFuels Res -White Mesa UMill\HP Inspection modules\2018\lnspection
.Vlod ules\RADMOD-R WP.docx
8) Eo~ does the RSO/Radiation Safety ,staff y e.r riiffyy), !JJ~R WPs are being foho"wed?
S0m1:1ents: ~::, 6:T: /le,/ ~~~...)~~-~a""'~-V-~7"7--...-;--~L~~~--~-----------
9) Section 5.1 of the Mills Radiation Protection manual says "The receipt, handling or processing of any
alternate feed material, which has been determined by the RSO, not to within existing operating procedure".
What is the Alternate feed being processed in the Alternate feed Circuit?
Comments: ,I.A 12<-ti; ,,__:;r'< (2.6Js f#j !iMJCutl'=-{ 7
I 0) If no SOP for the alternate feed is there a R WP?
Comments:
Yes No ---
JJzl
11) Observe the Alternate Feed Circuit are the employees following the SOP or R WP for the material they are
processing? Yes No
Comments:
.11-;I
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12) Identify a R WP that is being worked under during the inspection and go o that work site and verify that the
RWP is being followed. What are the details of the job? ·-If
Comments: ,1(/o ~ LtJ b a,') tvpd[..A' /;: //le,~=
13) What precautions are necessary to reduce exposure to Uranium and daughters
Comments:
14) What are the monitoring requirements for the R WP?
Comments:
15 ) Are the following being done for the RWP being observed?
Monitoring requirements being done?
Mill personnel wearing the appropriate PPE?
Other ALARA practices being done?
Was there specialized training documented?
Comments:
l ,
Yes
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No
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16) Are RWP jobs being documentea on the daily and weekly inspectio5 ?/
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17) Any non-compliance issues observed?
Comments:
18) If yes, was it corrected and how was it corrected?
Comments:
External Monitoring
19) Section 1.3 Beta-Gamma Surveys -Were all observed personnel wearing a personal monitoring badge
while in the Restricted Area? Yes ~ No D
'~t ents ,f rf 12 ~Z£~ /lh:5.~ w...,,,-~
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Section 1.3.1 Monitoring Proce ures
The monitoring procedures consist of
1. Personnel issued personal monitoring devices will wear the device on the trunk (torso) of the body or visibly
on the exterior of their hard hat. The personal monitoring device records beta/gamma radiation as well as other
forms of penetrating radiation such as x-rays. A personal monitoring device is an exposure record of an
individual's personal exposure to radiation while on the job. Therefore, personal monitoring devices are to
r<!main at the Mill in the personal possession of eaeh individual, in a locker or other secure area. All exposure
records obtained by a personal monitoring device which are not consistent with the exposure rates of work
tasks or work location measurements made throughout the Mill will be evaluated by the RSO. This evaluation
will result in an investigation by the RSO and a written explanation of the findings. These written records will
be maintained at the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be exchanged by the Radiation
Safety Department. Missing or lost badges will be reported to management.
3. Female employees that become pregnant and continue to work during the course of their pregnancy will be
placed on a monthly personal monitoring device exchange during this period. NRC Regulatory Guide 8.13
provides guidelines to be followed during pregnancy and is made part of this procedure.
20) Under routine conditions, were observed employees wearing monitoring badges properly o~e torso?
Yes~ NoD
Comments:
--··------------------------------------------
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21) Has the licensee assured that personal monitoring devices are being kept at the Mill in the possession of the
individual, in a locker or in another secure area? YesyNo D
Comments:
22) Check the dosimeter boards in the locker rooms, maintenance building and administration building. Are the
badges properly stored? Yes ?1 No D
Comments:
23) Have any female workers declared their pregnancy in the past i years?
Comments:
YesD No ~
24) If yes to 3 I above, has the declared pregnant worker been placed on a monthly personal monitoring device
exchange during this period? Yes D No D N/ A ~
Comments:
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Follow-up Items
25) The Mill is planning on processing Vanadium. Check the Vanadium Circuit.
Corv nen~~ !f,1!.,~:t ~ 5,£~ /,4.-, ,.4-__ C/d.,._T w,((
26) What alternate feeds are onsite? Will the Mill continue to process alternate feeds while the Mill processes
.Vanadium?
Comments:
27) How and where are the different alternate feeds being stored?
Corr·nents:
28) The alternate feeds that are being stored in supersacs: How long have they been stored and do the supersacs
appear to be in good conditions? ~
52::":_~:"J de c,1t::z
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State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
lieutenant Governor
Kathy Weinel
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
June 7, 2018
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-IM
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
FILE COPY
On May 21 and 22, 2018, an inspection was conducted at your facility by representatives of the Division
of Waste Management and Radiation Control. Observations from the inspection were discussed at the
closeout meeting with White Mesa Uranium Mill staff. The inspection was an examination of the
activities conducted at the facility as they relate to compliance with Utah's Radiation Control Rules, the
license conditions of the Radioactive Material License Number UT1900479 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 for your review. The Division considers this inspection closed. The
Division would like to thank the Mill staff for their cooperation regarding this inspection.
If you have any questions, please call Ryan Johnson at [phone].
Sincerely,
,C:;x:?2
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
DRC-2018-005401 195 North 1950 West• Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on I 00% recycled paper
(Over)
STA/ RMJ/ka
Enclosure: RADMOD-IM Health Physics Inspection Report (DRC-2018-005525)
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer
I
Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
INSPECTION REPORT
RADMOD-IM: Internal Monitoring
Energy Fuels -White Mesa Uranium Mill, Blanding Utah.
Occupational Air Sampling and Bioassay
May 21 & 22, 2018
Inspectors: Ryan Johnson. Utah Division Waste Management and Radiation Control
(DWMRC)
Spencer Wickham, DWMRC
Personne I Contacted:
David Turk, Energy Fuels Resources Radiation Safety Officer (RSO)
Justin Perkins, Radiation Safety Technician (RST)
Terry Slade. Chemist/Assistant RSO
David Lacy, Laboratory Technician
Governing Documents:
• UACRJIJ-15
• Radioactive Materials License (RML) UTl900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
David Turk (RSO)
Justin Perkins (RST)
Terry Slade
Utah DWMRC:
Ryan Johnson (I lealth Physics Inspector)
Spencer Wickham (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The main portion of the Mill was not in operation during this inspection. The Mill
staff reminded the inspector of the safety requirements for the Mill.
DRC Meters Used
Dose Rate
Model
Ludlum 19
Serial Number Calibration Due Date
101673 7/1 2/18
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Inspection Summary
The inspection consisted of a RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
• Calibration sheets for general area and breathing zone sample pumps;
• General area air sampling worksheets;
• Breathing zone sampling worksheets; and
• Bioassay analytical results and chain of custody fonns.
While reviewing the paperwork for breathing zone sampling, the inspector noticed that there were some
very high derived air concentration (DAC) values being recorded during the last year. The DAC values
observed up to 598, 122% DAC. The work at the Mill has been done under Radiation Work Permits
(RWPs) or according to Standard Operating Procedures (SOPs). The inspector followed up with the RSO
and verified that:
• Respirator protection was being used by the mill personnel performing the work;
• Bioassay samples were being collected from the mill personnel performing the work;
• Bioassay results indicated that the mill personnel were not inhaling uranium; and
• Bioassay sampling and analysis standard operating procedure (SOP) was being followed.
Deficiencies: None
Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the alternate feed circuit and solvent extraction building.
Observations: The DWMRC inspector also observed:
• Alternate feed material being stored on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill; and
• Locations where general area air samples are collected.
After collecting bioassay samples, the Mill analyzes its bioassay samples in its own lab. The Inspector
interviewed the Laboratory Technician that analyzes the bioassay samples. In that interview the Inspector
verified:
• The Laboratory follows a procedure that uses ANSI/HPS NI330-20/ 1 Performance Criteria/or
Radiobioassay as a guide (which is referenced in NRC Regulatory Guide 8.22 Bioassay at Uranium
Mills);
• Results are reviewed by the Laboratory Technician and given to tbe RSO;
• 25% of the samples are sent to an off site laboratory as a quality control check; and
• The sample preparation area is regularly surveyed for Alpha to prevent contamination of the
samples.
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..
:
I
UT AH DIVISION OF WASTE MANAGEMENT & RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-TRAINING-01
RADIATION PROTECTION TRAINING/
RADIATION SAFETY OFFICER & RADIATION TECHNICIAN TRAINING
DENISON MINES -WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Radioactive Material License UTl 900479, License Renewal Application dated February 28,
2007, Training Manual, addendums 9 and 10, Radiation Protection Manual, Section 1, 10CFR20, NRC
~egulatory Guide 8.30, NRC Regulatory Guide 8.31 , Regulatory Guide 8.15 , Utah Administrative Code
R313-15.
DATE 2--,/7-20/Y OPENING MEETING
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
Z2u.~~ -;;;~ Er~? , -
f
.L-·-Jtvi~ ;A/r/c__
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D,u,,=. 1 r.f I/
--
DISCUSSION
SITE STAFF COMMENTS
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--
Mill Tour
I) Durin the Mill tour observe eneral dose rate/contamination measurements and record.
Area of the Mill
DRC Meters Used Model Serial Number
Dose Rate Ludlum 19
R313-18-12. Instructions to Workers.
Dose Rate (µR/hr)/
Contamination
(d rn/I00cm2)
•• #
' .: l
T I L
Calibration Due Date
).-!<l'
(1) All individuals who in the course of employment are likely to receive in a year an occupational dose
in excess of 1.0 mSv (100 mrem):
(a) shall be kept informed of the storage, transfer, or use of sources of radiation in the licensee's or
registrant's workplace;
(b) shall be instructed in the health protection considerations associated with exposure to radiation or
radioactive material to the individual and potential offspring, in precautions or procedures to minimize
,;xposure, and in the purposes and functions of protective devices employed;
( c) shall be instructed in, and instructed to observe, to the extent within the worker's control, the
applicable provisions of these rules and licenses for the protection of personnel from exposure to
radiation or radioactive material;
( d) shall be instructed as to their responsibility to report promptly to the licensee or registrant a condition
which may constitute, lead to, or cause a violation of the Act, these rules, or a condition of the licensee's
license or unnecessary exposure to radiation or radioactive material;
( e) shall be instructed in the appropriate response to warnings made in the event of an unusual
occurrence or malfunction that may involve exposure to radiation or radioactive material; and
(f) shall be advised as to the radiation exposure reports which workers shall be furnished pursuant to
R3 13-1 8-13.
(2) In determining those individuals subject to the requirements of R3 l 3-l 8-l 2( I), licensees must take
into consideration assigned activities during normal and abnormal situations involving exposure to
radiation or radioactive material which can reasonably be expected to occur during the life of a licensed
facility . The extent of these instructions shall be commensurate with potential radiological health
protection considerations for the workplace.
R313-18-13. Notifications and Reports to Individuals.
(1) Radiation exposure data for an individual and the results of measurements, analyses, and calculations
0f radioactive material deposited or retained in the body of an individual shall be reported to the
individual as specified in R3 l 3-18-l 3. The information reported shall include data and results obtained
pursuant to these rules, orders, or license conditions, as shown in records maintained by the licensee or
registrant pursuant to R313-15-l 107. Notifications and reports shall:
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(a) be in writing;
(b) include appropriate identifying data such as the name of the licensee or registrant, the name of the
individual, and the individual's identification number, preferably social security number;
(c) include the individual's exposure information; and
( d) contain the following statement:
"This report is furnished to you under the provisions of the Utah Administrative Code Section RJ 13-18-
13 . You should preserve this report for further reference."
1) Review the Radiation Safety material with the instructor or attend a training class and identify if the
requirements found in RJ 13-18-12 and RJ 13-18-13 are being done.
R313-18-12 and R313-18-13
R313-18-12
(1) All individuals who in the course of employment are likely to receive in a year an occupational
dose in excess of 1.0 mSv (100 mrem):
(a) shall be kept informed of the storage, transfer, or use of sources of radiation in the
;icensee's or registrant's workplace;
i (b) shall be instructed in the health protection considerations associated with exposure to
radiation or radioactive material to the individual and potential offspring, in precautions or
procedures to minimize exposure, and in the purposes and functions of protective devices
employed;
(c) shall be instructed in, and instructed to observe, to the extent within the worker's control,
the applicable provisions of these rules and licenses for the protection of personnel from
exposure to radiation or radioactive material;
( d) shall be instructed as to their responsibility to report promptly to the licensee or registrant
a condition which may constitute, lead to, or cause a violation of the Act, these rules, or a
condition of the licensee's license or unnecessary exposure to radiation or radioactive
material;
(e) shall be instructed in the appropriate response to warnings made in the event of an
unusual occurrence or malfunction that may involve exposure to radiation or radioactive
material; and
(f) shall be advised as to the radiation exposure reports which workers shall be furnished
pursuant to R313-18-13.
(2) In determining those individuals subject to the requirements of R313-18-12(1), licensees
must take into consideration assigned activities during normal and abnormal situations
involving exposure to radiation or radioactive material which can reasonably be expected to
occur during the life of a licensed facility. The extent of these instructions shall be
commensurate with potential radioloe:ical health protection considerations for the workplace.
R313-18-13
(1) Radiation exposure data for an individual and the results of measurements, analyses, and
calculations of radioactive material deposited or retained in the body of an individual shall be
reported to the individual as specified in R313-18-13. The information reported shall include data
and results obtained pursuant to these rules, orders, or license conditions, as shown in records
maintained by the licensee or registrant pursuant to R313-15-1107. Notifications and reports
shall:
(a) be in writing;
(b) include appropriate identifying data such as the name of the licensee or registrant, the
name of the individual, and the individual's identification number, preferably social security
number;
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(c) include the individual's exposure information; and
( d) contain the following statement:
"This report is furnished to you under the provisions of the Utah Administrative Code
Section R313-18-13. You should preserve this report for further reference."
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 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 R3l3-15-101 (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 instructed by means of an established course in the inherent risks of
exposure to radiation and the fundamentals 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 Concerning Prenatal Radiation Exposure" (Ref. 10), and Regulatory Guide 8.29,
"Instruction Concerning 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,
• Using proper methods for decontamination (i.e., showers).
3) Facility-Provided Protection
• Ventilation systems and effluent controls,
• Cleanliness of the work place,
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• 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.
4) Health Protection Measurements
• Measurement of airborne 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
• Regulatory authority ofNRC, 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 instructor 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
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 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 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 instructor. Radiation safety matters
of concern 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 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 appropriate 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 prior work assignments at the facility or have evidence of recent and
relevant radiation safety training elsewhere.
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1) Review the Radiation Safety material with the instructor or attend a training class and identify if
each subject is covered. Was the following information covered in the licensee Radiation Safety
training as outlined in NRC Reg. Guide 8.31 Section 2.5.
NRC Reg. Guide 8.31 section 2.5
Section 1 :Fundamentals of Health Protection -1 -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
-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 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
Section 4:Health Protection Measurements
-Measurements of Airborne radioactive materials
-Bioassays to detect Uranium (Urinalysis and in Vivo Countin2:)
-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 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 __ 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
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