DRC-2012-001225 - 0901a068802b758b

-2012-001225
Denison Mines (USA) Corp
105017th Street Suite 950
Denver CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
DENISO
MINES
February 27 2012
VIA E MAIL AND OVERNIGHT DELIVERY
Mr Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
PO Box 144850
Salt Lake City UT 84114 4850
Re Inspection Conducted December 15 16 2011
Notice of Violation Radioactive Materials License Number UT1900479
Dear Mr Lundberg
This letter is in response to the above referenced Notice of Violation { NOV ) received by Denison Mines (USA)
Corp ( Denison ) on January 27 2012 which lists three violations 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 December 15 and 16 2011
The Notice of Violation requires Denison to provide a wntten response within 30 days after receipt of the Notice
including
• The corrective actions which have been taken and the results achieved
• The corrective steps which have been taken to prevent recurrence and
• 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
The specific violations listed in the NOV and Denison s response to each are discussed below
Violation 1
The release limits set forth in NRC Regulatory Guide 8 30 Table 2 and the Mill s Radiation Protection Manual
Section 2 6 2 are summanzed as follows
Limits for Alpha emissions for U Nat and its daughter products are
Average 5 000 dpm/1 OOcm^
Maximum 15 000 dpm/1 OOcm^
Removable 1 000 dpm/1 OOcm^
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Limits for Beta gamma emissions (measured at a distance of one centimeter) for Beta/Gamma emitting
radioisotopes are
Average 0 2 mr/hr or 5 000 dpm/1 OOcm^
Maximum 1 0 mr/hr or 15 000 dpm/1 OOcm^
Contrary to this requirement it was discovered that a rental forklift was released to RSC Equipment Rental of
West Valley City Utah on November 3 2011 with fixed contamination on the forks that was above the release
limits The release survey form indicates that the total alpha contamination on the forks was 10 240
dpm/1 OOcm^ A memorandum provided by the Mills RSO explains that the technician that released the forklift
applied the wrong release cntena
Denison responds as follows
Root Cause of the Noncompliance
This violation resulted from a misunderstanding and misinterpretation by a Mill radiation safety technician of
applicable release limits
On Thursday November 3 2011 a radiation safety technician surveyed a forklift with the following results
Body and tires total alpha dpm/100 cm^ < background
beta/gamma dpm/100 cm^ < 0 05
Forks total alpha dpm/100 cm^ 10 240 (fixed and removable)
Removable (by swipe) dpm/cm^ 7 7
The root cause of this violation was the fact that the technician did not have adequate training in interpreting
measured results from the scans and wipes performed when equipment release testing is conducted under the
Mill s Standard Operating Procedure ( SOP ) PBL RP 2 for Equipment Release Surveys Due to the
inadequate training the technician did not understand that
a) the 10 240 dpm/100 cm^ reading was the average reading and not a maximum/hot spot reading and
b) both the 0 2 mr/hr or 5 000 dpm/1 OOcm^ average and 1 0 mr/hr or 15 000 dpm/1 OOcm^ maximum
conditions have to be met for a piece of equipment to be released
An additional factor in this incident was the fact that the technician had not had pnor occasion to survey a piece
of equipment with alpha contamination at the elevated levels present on the forklift or a situation where the fixed
contamination was very high relative to the removable contamination
Corrective Actions Which Have Been Taken and the Results Achieved
Mill radiation technicians have received additional training regarding the correct application of release limits
In addition Mill practices have been changed to require that
a) the radiation safety department will receive advanced notice when any piece of rented equipment is to
leave the Mill site and
b) the Item to be released will be decontaminated and surveyed before the supplier is notified to pick up
Its equipment
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This practice is expected to ensure sufficient time for release scanning wipe sampling and any required re
decontamination pnor to release This practice will also provide additional time for the technician to consult with
the RSO should there be any uncertainty regarding how to interpret measured results or apply the requirements
of the SOP
It should be noted that the error which occurred on November 3 2011 was identified by the RSO within hours of
the release of the equipment and the forks were returned to the Mill site re scanned and a decision was made
to retain the forks on site indefinitely (i e not to release the forks) the same day as the error was identified
Corrective Steps Which Have Been Taken to Prevent Recurrence
The actions listed above are also considered to have been taken to avoid further items of noncompliance
Date Full Compliance will be Achieved
Denison considers that the actions taken as listed above are sufficient to ensure compliance in the future and
that full compliance has now been achieved
Violation 2
The Mill 8 Radiation Protection Manual Section 1 2 3 Monitonng Procedures step 1 states
The alarm rate meter is adjusted within the range of 500 to 750 dpm/100 CITF to ensure a margin of 250
dpm/100 crrF due to the low efficiency of this instrumentation
Contrary to this requirement instrument alarm settings at three (3) of the restncted area exits were found to be
set at higher set points than is required by this procedure The findings were as follows
Exit Instrument Alarm Set Instrument Equivalent Set
Location Model # Serial # Point as Efficiency Point in DPM/100
Found cm^
Admin Gate L 177 61 159117 60cpm 9 0% 1333
Lab Exit L 177 41298 50cpm 9 6% 1041
West Door L 177 61 159172 60cpm 9 6% 1250
This IS repeat violation An NOV was issued to the Licensee on May 17 2011 for improperly set alarms at the
same three locations The DRC considers that this matter has become of significant concern Therefore the
DRC has increased the severity level of this problem from a Severity Level IV to a Severity Level III Notice of
Violation in accordance with Utah Rule R313 14 10 Severity of Violations
Denison responds as follows
Root Cause ofthe Noncompliance
We have reviewed this matter thoroughly and have concluded that this violation had multiple root causes as
follows
1 Inadequate procedures for documenting background and standard measurement tests and meter function
check calculations required to ensure that the meters are set properly
As a result of DRC s Apnl 19 2011 inspection DRC cited a similar violation regarding the set points of meters
at the same three locations In a June 16 2011 letter in response to the NOV Denison identified four corrective
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actions put in place dunng 2011 including a requirement for the radiation staff to record the meter settings on
the Mill s existing meter function check sheet The corrective actions also included retraining of the radiation
safety staff in compliance with the Mill s radiation scanning SOP Upon review of the results from the actions
taken to date Denison has determined that the requirements in the SOP as written are insufficient
Specifically the SOP does not require the recording of
• information associated with measurement and averaging of background readings
• information associated with measurement of efficiency compared to an alpha source
• the calculations used to determine the meter set point in cpm and
• the background reading to be used in correction of the meter readings
Although the radiation technicians have been retrained to follow the SOP as written the lack of recorded
information has made the RSO unable to properly check calculations and appropriateness of the meter settings
At the time of the December 2011 DRC inspection there was no requirement in the existing SOP to record the
measured and average background for each instrument Consistent with the SOP radiation technicians had
recorded the meter setting for each instrument in question but they had not recorded the background used in
developing the setting Based on past data and experience typical background values at the meter locations in
question vary from 20 to 40 cpm The table below summarizes the equivalent set point values that result if
background values within this range are accounted for in the set point calculation
It should be noted that as indicated in the table based on the most conservative (lowest) typical background
reading of 20 cpm the equivalent set points for all the meters were within the 1 000 dpm/cm^ specified in the
Mill s License Renewal Application Volume 1 Section 6 4 6 which formed the basis of the SOP ^
Various Cases for
Assumed
Background Admin
(cpm) Gate Lab Exit West Door
Instrument efficiency dimensionless 0 09 0 096 0 096
Fraction of standard probe size area/100 cm^ 05 05 05
Setting found at inspection cpm 60 50 60
Equivalent Set Point dpm/lOOcm^
Equivalent Set Point with
Background Correction dpm/lOOcm^ 20 889 625 833
Equivalent Set Point with
Background Correction dpm/lOOcm^ 30 667 417 625
Equivalent Set Point with
Background Correction dpm/lOOcm^ 40 444 208 417
Note Items highlighted in gray were inputs used by DRC identified in the NOV as stated above Items highlighted in brown resulted from
calculations based on those inputs
2 A confusing descnption in the SOP of how the ALARA goal is to be set
' This 1000 dpm/lOO cm^ standard is based on NRC Reg Guides 4 14 and 8 30 and assumes that all alpha contamination
on an individual is removable contamination
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As specified in the SOP PBL RP 1 Section 1 2 6 Limits/ALARA
contamination limits for personnel scans are set at 1 000 dpm/100 cm^
As discussed under root cause #1 above review of the summary table indicates that even given the low
efficiency of the equipment under the current equipment configuration settings equivalent to the 1 000 dpm/cm
limit were achieved at all three meter locations
However the monitoring procedure descnbed under Section 1 2 3 states that
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
This IS somewhat confusing and inconsistent with the requirement in Section 1 2 6 of the SOP and Section
6 4 6 of the Mill s License renewal Application It is also evident that setting the alarm rate within the range of
500 to 750 dpm/cm^ is not reasonably achievable given the background and the efficiency of the instrument
Corrective Actions Which Have Been Taken and the Results Achieved
Denison takes this violation very seriously and as a result the following corrective actions will be taken
1 Denison will revise the existing SOP as follows
a) Denison will revise SOP Section 1 2 6 to clarify that the concentration limit and ALARA limit for
personnel scans is 1 000 dpm/100 cm^ Section 1 2 3 will be revised to eliminate the requirement to
adjust the alarm meter to alarm at less than 1 000 dpm/100 cm^ so it does not conflict with Section
1 2 6 of the SOP and Section 6 4 6 of the Mill s License Renewal Application
b) Denison will amend the existing SOP to require that the radiation staff record the background
efficiency and calculations used to determine the set point to allow the RSO to properly check for
errors The equipment function check sheet will be revised accordingly to accommodate the recording
of this information
2 Radiation personnel will be retrained to ensure they understand how to properly perform and record the
required measurements and calculations used to develop the meter set point
3 The steps will be completed within 30 days of the date of this letter
If after implementing the above corrections to the SOP and providing the associated retraining to the radiation
staff Denison determines that compliance with the 1 000 dpm/100 cm^ limit cannot be achieved with one or
more of the meters Denison will consider replacing the existing meter probes with probes of higher surface
area and higher efficiency
Corrective Steps Which Have Been Taken to Prevent Recurrence
The actions listed above are also considered to have been taken to avoid future noncompliance
Date Full Compliance will be Achieved
Denison considers that the actions taken as listed above are sufficient to ensure compliance in the future and
that full compliance will be achieved within 30 days of the date of this letter
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Violation 3
The Mill s Security Program Section 1 4 Reagent and Ore Garners requires that
Truck drivers hauling reagent and ore into the restricted area of the facility are to receive documented site
safety and radiation protection training prior to access to the site Access is limited by controlling and
documenting gate access Safety and radiation training consists of appropriate training for the activity involved
Contrary to this requirement a reagent delivery driver and an ore delivery driver were found inside the Mill s
radiologically restncted area dunng the inspection without proper site safety and radiation protection training
This violation has been charactenzed as a Severity Level IV
Denison responds as follows
The Mill maintains a list of delivery personnel who have received the hazard awareness training Evidence of
receipt of the training is provided by the signatures of the Mill personnel providing the training and the delivery
person receiving the training on a Hazard Awareness Training form Dunng business hours scalehouse/gate
security personnel are qualified to provide the training to arnving delivery personnel who are not identified on
the list as having previously received the training After business hours the Shifter or A operator is qualified to
provide the required training
Root Cause ofthe Noncompliance
Denison considers the procedure descnbed above to be adequate for access control and protection of delivery
personnel This violation resulted from a breakdown in compliance with the existing procedure
Corrective Actions Which Have Been Taken and the Results Achieved
The Mill has taken multiple steps to correct the breakdown in compliance
1) A notice has been sent to all current suppliers and delivery companies reiterating that all delivery
personnel must have current Hazard Awareness Training to enter the Mill site Dnvers arnving at the site after
business hours must
• already have taken the training (as evidenced by his/her name on the current list of trained delivery
personnel or
• be prepared to take the training on the spot if Mill personnel are available to provide it after hours or
• if Mill personnel are unavailable to provide the training after hours dnvers must be prepared to be
denied access to he Mill site and return to the Mill dunng business hours when the training can be
provided
2) The RSO has developed a spreadsheet that is available to the scalehouse operator and the radiation
technicians as a quick reference indicating which drivers from each supplier/delivery company have the
requisite training The RSO has assumed responsibility for collecting and reviewing signed training forms
generated when additional drivers receive training and for keeping the spreadsheet current with the driver
training forms An example of the training summary spreadsheet is provided in Attachment 1
3) The requirement that delivery drivers must have the requisite training or be denied access to the site
and that such training will be given by the Shifter or A operator after business hours has been reiterated to the
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Shifters and A operators and has been added to the agendas for monthly personnel health and safety training
Mill personnel have also been reminded in recent training sessions of the importance of restncting access to the
site to those who have appropnate training and awareness of the potential hazards on site
Corrective Steps Which Have Been Taken to Prevent Recurrence
The actions listed above are also considered to have been taken to avoid future noncompliance
In addition the RSO or his designed will perform occasional random spot checks to ensure that the employees
responsible for controlling delivery access to the site after business hours (the Shifter or A operator) have
prevented untrained dnvers from entering the site and/or provided the requisite training The spot check will be
performed by occasionally randomly checking the list of after hours delivenes and driver names against a
current list of trained delivery personnel Failure of the responsible employee to prevent access or provide the
requisite training to delivery personnel will subject the employee to disciplinary review
Date Full Compliance will be Achieved
As mentioned above Denison considers that the existing procedure is adequate for controlling access and
protecting delivery personnel Denison considers that the actions taken as listed 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
11(1)(d)
Please contact me if you have any questions or require any further information
Yours very truly
DENISON MINES (USA) CORP
Jo Ann Tischler
Director Compliance and Permitting
cc David C Frydenlund
Ron F Hochstein
Harold R Roberts
David E Turk
K Weinel
Central files
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ATTACHMENT 1
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2012 Hazard Awareness Training
Name Date Organization Training Received Training Conducted By
Angel I Douglas 1/10/2012 Greenfield Logistic 1 le (2) Delivery Personnel Cortney Montella
Armstrong Brandon 1/9/2012 Fastenal Reagent Delivery Personnel Justin Perkins
Beagley Rodney 1/4/2012 Hammon Trucking Ore Delivery Personnel Cortney Montella
Betterton Heidi 1/11/2012 FedEx Reagent Delivery Personnel Justin Perkins
Biondo Jim 1/27/2012 Bulk Transportation Sulfuric Acid Delivery Personnel Nathan Bunting
Bistlme Louis 1/4/2012 Hammon Trucking Ore Delivery Personnel Blake Burtenshaw
Black Ben 1/19/2012 Black Hawk Transportation Reagent Delivery Personnel Nathan Bunting
Black Damon 1/19/2012 Black Hawk Transportation Reagent Delivery Personnel Nathan Bunting
Bolos Chris 1/5/2012 UPS Reagent Delivery Personnel Justin Perkins
Bos Mike 1/4/2012 Thatcher Sulfuric Acid Delivery Personnel Nathan Bunting
Brant Russ 1/11/2012 Thatcher Reagent Delivery Personnel Justin Perkins
Callihan Jeff 1/16/2012 Four Comers Welding Reagent Delivery Personnel Justin Perkins
Cameron Randy 1/10/2012 Page Steel Reagent Delivery Personnel Justin Perkins
Campbell Max 1/13/2012 Max Campbell Trucking Reagent Delivery Personnel Cameron Palmer
Carothers Richard 1/25/2012 Little Maverick Ore Delivery Personnel Cortney Montella
Carroll Lester 1/3/2012 R&R Trucking Reagent Delivery Personnel Blake Burtenshaw
Caiss Lanny 1/3/2012 Thatcher Sulfuric Acid Delivery Personnel Cameron Palmer
Clark Allen 1/27/2012 Trimac Sulfuric Acid Delivery Personnel Tenya Begay
Conover Kasey 1/17/2012 Corlett Express Reagent Delivery Personnel Justin Perkins
David Harold 1/9/2012 Step Saver Reagent Delivery Personnel Justin Perkins
Dayzie Michael 1/25/2012 San Juan Building Supply Reagent Delivery Personnel Justin Perkins
Dean Don 1/3/2012 Thatcher Sulfuric Acid Delivery Personnel Cameron Palmer
DeJong Mike 1/4/2012 Greenfield Logistic 1 le (2) Delivery Personnel Blake Burtenshaw
Donais Ed 1/27/2012 RSB Logistics Ore Delivery Personnel Cortney Montella
Dougloss Wayne 1/3/2012 Thatcher Sulfuric Acid Delivery Personnel Cameron Palmer
Dunsmore Lon 1/5/2012 Greenfield Logistic 1 Ie (2) Delivery Personnel Cortney Montella
Eardley Terry 1/12/2012 Codale Reagent Delivery Personnel Justin Perkins
Emerson Charlie 1/18/2012 Four Comers Welding Reagent Deliveiy Personnel Justin Perkins
Ferguson Cody 1/11/2012 Bamey Trucking Reagent Delivery Personnel Justin Perkins
Fisher David 1/27/2012 R&R Trucking Ore Delivery Personnel Cortney Montella
Flinchum Andrew 1/27/2012 Bulk Transportation Sulfuric Acid Delivery Personnel Nathan Bunting
Comments
Wrong Training
2012 Hazard Awareness Training
Name Date Organization Training Received Training Conducted By
Gambles Todd 1/5/2012 Greenfield Logistic 1 le (2) Delivery Personnel Blake Burtenshaw
Godfrey Charles 1/11/2012 R&R Trucking Ore Delivery Personnel Cortney Montella
Goodenough Gary 1/5/2012 CTI Sulfuric Acid Delivery Personnel Nathan Bunting
Hammon Ethan 1/23/2012 Hammon Trucking Ore Deliveiy Personnel Cortney Montella
Hammon Nathan 1/4/2012 Hammon Trucking Ore Delivery Personnel Blake Burtenshaw
Haywood Fredrick 1/3/2012 IXL Transportation Reagent Delivery Personnel Cortney Montella
Hiatt, J L 1/27/2012 Bison lnd Reagent Delivery Personnel Justin Perkins
Hill Mike 1/22/2012 Step Saver Reagent Delivery Personnel Tenya Begay
Huber Melvin 1/4/2012 CTI Sulfuric Acid Delivery Personnel Justin Perkins
Ince April 1/9/2012 Four Comers Welding Reagent Delivery Personnel Justin Perkins
Jackson Bruce 1/9/2012 R&R Trucking Ore Delivery Personnel Blake Burtenshaw
Jennings Jesse Lee 1/4/2012 Munro Reagent Delivery Personnel Justin Perkins
Jewkes Ronnie 1/5/2012 Kaman Industrial Technologies Reagent Delivery Personnel Justin Perkins
Joesph Danny 1/9/2012 Little Maverick Ore Delivery Personnel Blake Burtenshaw
Johnson Rob 1/3/2012 Hammon Trucking Ore Delivery Personnel Cortney Montella
Jones Dusty 1/4/2012 Hammon Trucking Ore Delivery Personnel Blake Burtenshaw
Karen Craig 1/5/2012 Thatcher Sulfuric Acid Deliveiy Personnel Nathan Bunting
King Kody 1/9/2012 Old Dominion Reagent Delivery Personnel Ronnie Nieves
Kistler Mark 1/30/2012 Bulk Transportation Sulfuric Acid Delivery Personnel Cameron Palmer
Klassen Coiy 1/16/2012 RSB Logistics Ore Delivery Personnel Cortney Montella
Lewis Ricky 1/27/2012 Tnmac Sulfuric Acid Delivery Personnel Tenya Begay
Marsh Gerald 1/20/2012 Promethus Energy Reagent Delivery Personnel Justin Perkins
Mason Mike 1/4/2012 Hammon Trucking Ore Delivery Personnel Cortney Montella
Mikesell Mike 1//28/12 Step Saver Reagent Delivery Personnel Tenya Begay
Newell Ronald 1/20/2012 Bamey Trucking Reagent Delivery Personnel Justin Perkins
Oliver Hamson 1/4/2012 Little Maverick Ore Delivery Personnel Cortney Montella
Osborne Bill 1/5/2012 Reed Hurst Trucking Reagent Delivery Personnel Ronnie Nieves
Palmasano Vincent 1/3/2012 Thatcher Sulfuric Acid Deliveiy Pei^onnel Cameron Palmer
Palmer Ned 1/4/2012 Little Maverick Ore Delivery Personnel Henry Neal
Peterson Kyle 1/18/2012 Step Saver Reagent Delivery Personnel Cameron Palmer
Pnbble James 1/4/2012 Little Mavenck Ore Delivery Personnel Henry Neal
Comments
2012 Hazard Awareness Training
Name Date Organization Training Received Training Conducted By
Reynolds Al 1/18/2012 TSC Reagent Delivery Personnel Cameron Palmer
Robertson Kurt 1/27/2012 Trimac Sulfunc Acid Delivery Personnel Tenya Begay
Rogers Brad 1/10/2012 Little Maverick Ore Delivery Personnel Cortney Montella
Ruiz, Jesus 1/12/2012 CTI Reagent Delivery Personnel Justin Perkins
Sharpe James 1/20/2012 Sharpe Industrial Reagent Delivery Personnel Justin Perkins
Sharpe Tom 1/13/2012 Sharpe Industnal Reagent Delivery Personnel Justtn Perkins
Shirley Marcus 1/4/2012 CTI Sulfuric Acid Delivery Personnel Justin Perkins
Stringham Lanell 1/10/2012 Country Comfort Reagent Delivery Personnel Justin Perkins
Sutherland Lee 1/10/2012 Little Maverick Ore Delivery Personnel Cortney Montella
Tabor Terry 1/6/2012 Little Maverick Ore Delivery Personnel Cortney Montella
Taylor Chris 1/5/2012 Greenfield Logistic 1 le (2) Delivery Personnel Blake Burtenshaw
Topping Dennis 1/23/2012 R&R Trucking Ore Delivery Personnel Cortney Montella
Tucker Matt 1/25/2012 TSC Reagent Delivery Personnel Justin Perkins
Tyler John 1/25/2012 R&R Tmckmg Ore Delivery Personnel Cortney Montella
Willson Lenny 1/4/2012 Old Dominion Reagent Delivery Personnel Justin Perkins
Williams David 1/10/2012 Little Mavenck Ore Delivery Personnel Cortney Montella
Williams Roy 1/5/2012 Little Mavenck Ore Delivery Personnel Cortney Montella
Comments