DRC-2011-006596 - 0901a068802450cb

Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denisonmines.com
June 16,2011
VIA PDF AND FEDERAL EXPRESS
Mr. Rusty. Lundberg
Executive Secretary
Utah Radiation Control Board
State of Utah Department ofEnvironmental Quality
195 North 1950 West
Sah Lake City, UT 84114-4850
Re: Inspection Conducted April 19 and 20, 2011; Notice of Violation: Radioactive
Materials License Number UT1900479
Dear Mr. Lundberg:
This letter is in response to the above-referenced Notice of Violation, received by Denison Mines
(USA) Corp. ("Denison") on May 19, 2011, which Hsts one violation of the Utah Radiation
Control Rules, based on an inspection of the White Mesa Mill (the "Mill") conducted by
representatives of the Utah Division of Radiation Control ("DRC") on April 19 and 20, 2011.
The Notice of Violation requires Denison to provide a written response within 30 days after
receipt of the Notice, including:
a) The corrective actions which have been taken and the results achieved;
b) The corrective steps which have been taken to prevent recurrence; and
c) The date full compliance will be achieved.
Denison is also aware that R313-18-11(1 )(d) requires that Denison post a copy of the Notice in a
conspicuous place.
Specifically, the Notice of Violation lists the following violation:
"Radioactive Material License Renewal Application dated February 28, 2007, Appendix E.
Section 1.2.3, Monitoring Procedure, step I, states: "The alarm rate meter is adjusted within
the range of 500 to 750 dpm/100 cm^ to ensure a margin of 250 dpm/100 cm^ due to the low
efficiency of this instrumentation. "
N:\lnspections and NOVs\05.17.11 Radiation Inspection NONALr in response to 5.17.11 RML NOV.doc
Contrary to this requirement, instrument alarm settings at three (3) of the restricted area exits
were found to be set at higher set-points than is required by this procedure. The findings were
as follows:
Exit
Location
Instrument Alarm Set
Point As
Found
Instrument
Efficiency
Equivalent Set
Point in
DPM7100cm^
Exit
Location Model # Serial #
Alarm Set
Point As
Found
Instrument
Efficiency
Equivalent Set
Point in
DPM7100cm^
Admin Gate L-177 264740 200cpm 10.3% 3883
Lab Exit L-177 264743 lOOcpm 11.2% 1786
West Door L-177 116481 125cpm 11.5% 2174
The Notice also states that:
"The DRC encourages the licensee to exercise more attentiveness in regards to the Personnel
Monitoring Program. Although the DRC recognizes that the licensee has made significant
improvements to the personnel monitoring program in recent years, attention to detail in all
aspects of the program is important to ensure adequate employee radiological safety and the
safety of the general public. "
Denison responds as follows:
1. Root Cause of the Noncompliance
This violation resulted from the following:
The Mill's restricted area exit alarm rate meters (the "Meters") were either re-adjusted by Mill
personnel between routine radiation safety staff inspections or were inaccurately inspected or set
by radiation staff during those inspections.
We have reviewed this matter carefully and have concluded that the root causes of this violation
are as follows:
2.
a) The lack of a mechanism to prevent adjustments of the Meters by unauthorized
personnel; and/or
b) Misunderstanding by Mill radiation safety staff of the proper Meter function check
calculations required to ensure that the Meters are set properly at all times.
Corrective Actions Which Have Been Taken and the Results Achieved
Denison takes this violation very seriously, and as a result, the following corrective actions have
been taken by Denison:
a) Radiation safety staff have been provided re-training on the proper Meter function check
calculations required to ensure that the Meters are set properly at all times;
DENISON
MINES
b) Radiation safety staff are now required to document for each routine inspection the
Meter settings on the Mill's existing meter function check sheet. This allows the Mill's
Radiation Safety Officer to review radiation safety staff calculations periodically to
ensure that the calculations are performed properly;
c) Mill staff has constructed a Plexiglas box for each Meter location on site. Each box has
a hole for the power cord, a hole for the probe cord and a hole for the reset button. Other
than these three holes there is no access to the Meter. The boxes are padlocked and the
meters are screwed down to the box surfaces. There is therefore no way for
unauthorized personnel to adjust the settings on the Meter; and
d) Mill personnel have been reminded in recent training sessions of the importance of
properly scaiming prior to leaving the restricted area and the consequences of failing to
follow proper procedures, including making unauthorized adjustments to Meter settings.
3. Corrective Steps Which Have Been Taken to Prevent Recurrence
The actions listed in paragraph 2 above are also considered to have been taken to avoid further
items of non-compliance.
In addition, proper adherence to scanning procedures, including the consequences of failing to
follow proper procedures and/or making unauthorized adjustments to Meter settings, is covered
in all new-hire employee training.
4. Date Full Compliance Will be Achieved.
Denison considers that the actions taken as listed in paragraph 2 above are sufficient to ensure
compliance in the future and that full compliance has now been achieved.
A copy of the Notice of Violation has been posted in the Administration Building, in accordance
with R313-18-1 l(l)(d).
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
Jo Aim Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
DENISO
MINES