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HomeMy WebLinkAboutDRC-2012-002921 - 0901a0688035c92cINSPECTION REPORT Inspection Module: RADMODIEM-01 Inspection Location: White Mesa Mill, Blanding Utah RM License: UT1900479 Inspection Items: Internal and External Monitoring Inspection Dates: January 18 through 19, 2012 Inspectors: Ryan Johnson, Kevin Carney, Utah Division of Radiation Control (DRC) Personnel Contacted: David Turk, Ron Nieves and Dan Hi listen. Governing Documents: Radioactive Material License UTl900479, Amendment 4 NRC Regulatory Guide 8.13 NRC Regulatory Guide 8.22 White Mesa Mill Radiation Protection Manual, Section 5 Utah Administrative Code R313-15 Utah Administrative Code R313-12-3 10CFR20 Inspection Summary The inspection was a verification of compliance with Utah Rules, 10CFR20, NRC Regulatory Guides 8.13 and 8.22 and White Mesa Mill (the Mill) procedures as they pertain to air sampling, bioassay sampling and external monitoring at the Mill. The inspection consisted of a review of records, site observations and interviews with the Radiation Protection Staff as well as other personnel on site. Discrepancies Several discrepancies were noted during the inspection. These discrepancies are listed below and will be discussed under the Findings section in this document: • Elevated DAC values on Breathing Zone (BZ) samples • Documentation of abnormal circumstances • Timely urinalysis sampling Inspection Items ^ ^ ^ " 2 0 1 ^ - 0 0 2 9 2 1 The inspection was divided into three main sections: • Air Sampling • Bioassay Program • External Monitoring 1 of Page 3 C \Documents and Settings\kcamey\My DocumentsM le2 RMLs\Denison - White Mesa\lnspections\2012 lnspections\IEM-01\IEM-01 Inspection Report 1-18-2012 doc The inspection outlines are noted below according to section: Air Sampling The inspection consisted of a review of records of BZ and General Area (GA) air sampling inside the Mill's Restricted Area (RA) as well as personal external monitoring devices (OSLbadges). Although the Mill's sampling program was found to be properly managed, discrepancies were found regarding elevated DAC values at the Yellowcake Packaging Enclosure and the North Alternate Feed Pad. These are discussed in the Findings section below. Bioassay Program The inspection looked at the Mill's uranium urinalysis program. Although the Mill's bioassay program was found to be sound, it was found that several employees' bioassay samples were not collected within the frequencies set forth in the Mill's Radiation Protection Manual during 2011. These are discussed in the Findings section below. External Monitoring The inspection looked at the Mill's use of Optically Stimulated Luminescence (OSL) badges for monitoring external personnel exposure. Workers were found to be wearing and storing their OSL badges appropriately. No discrepancies were noted under this segment ofthe inspection. Findings Air Sampling During a records review of BZ sample results, it was discovered that several BZ samples showed elevated DAC values. Most notably were a value of 5,184.85% DAC at the Yellowcake Packaging Enclosure on December 10, 2011 and a value of 7,267.41 % DAC on August 8, 2011 at the North Alternate Feed Pad. In either case, the areas were posted as Airborne Radioactivity Areas and the BZ wearers were wearing appropriate respiratory protection at the time these samples were taken. The inspectors discussed these findings with the Mill's RSO and stressed that the Mill need's to evaluate these values and develop methods to keep exposures ALARA. Bioassay Program 1) During the records review of bioassay urinalysis sampling, it was noted that there was an employee whose urine sample was never collected. This was discussed with the RSO who informed the inspectors that the employee had been incarcerated at the time his sample was to be collected. Therefore, due to this abnormal circumstance, the Mill was unable to obtain the employee's sample. There was no documentation of this situation or any written explanation of the circumstances. The inspectors suggested that the Mill document these types of situations as they occur to prevent having to explain them at a later date and thereby rely solely on memory. The RSO concurred. 2) During the records review of bioassay urinalysis sampling, it was noted that several employees' urinalysis samples were given later than required (for example: within 2 weeks from working under an RWP in an area with airborne concentrations > 25% DAC). In all cases, urine samples 2 of Page 3 C VDocuments and Settings\kcaniey\My DocumentsM le2 RMLs\Denison - White Mesa\lnspections\2012 Inspections\IEM-01\IEM-01 Inspection Report 1-18-2012 doc were collected a short time later. The RSO was advised that the UP Staff needs to be more diligent in collecting urine samples in a timely manner. External Monitoring No findings were noted under this segment of the inspection. Conclusion and Recommendations No violations are recommended for this inspection. The findings noted were of a minor nature and the RSO's outlook on addressing the findings was reasonable to the inspectors. The RSO was notified that these issues would be revisited during subsequent inspections. Recommendation for Next Inspection 1. Check BZ results at YC Enclosure and North AF Pad 2. Check records for abnormal circumstances 3. Check urinalysis frequencies Inspection Note: At the time of the inspection, the Mill was hosting a tour of the facility by members of several government agencies in preparation for a future IAEA visit. The DRC inspectors' Mill tour was conducted concurrently with the group tour. During the Mill tour, several members of the tour group were bothered by some of the pungent chemical odors throughout the Mill. The Mill Staff agreed that some people who tour the Mill are sensitive to the chemical odors that occur throughout their process. However, they are confident that the levels of airborne hazardous materials are within all regulatory parameters. An NRC representative on the tour voiced concerns to the inspectors about this issue and asked if the DRC had a Memorandum of Understanding with OSHA. The inspectors informed the NRC representative that we did not have a MOU with OSHA. On January 30,2012, the DRC forwarded these concerns to the Mine Safety and Health Administration (MSHA). Prepared By: Kevin Carney c^^r!^^*'--^^^ January 30.2012 Ryan Johnson ;;7'-7 ^ January 30.2m ^^^^^ Reviewed By: Phillip Goble ^ January 30.2012 3 of Page 3 C \Documents and Settings\kcamey\My DocumentsM le2 RMLs\Denison - White Mesa\lnspections\2012 lnspections\IEM-01\lEM-01 Inspection Report 1-18-2012 doc UTi^DIVISION OF RADIATION ^NTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-IEM-01 INTERNAL/EXTERNAL MONITORING DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT1900479 TnspectorrsV Ryan Johnson. Kevin Carney Date(s): Tamiary 18-19. 2012 References: • Radioactive Material License UT1900479 • License Renewal Application dated February 28, 2007 • Radiation Protection Manual, Section 5 • 10CFR20 • NRC Regulatory Guide 8.13 • NRC Regulatory Guide 8.22 • Utah Administrative Code R313-12-3 • Utah Administrative Code R313-15. AIR SAMPLING Radiation Protection Manual, Section 1.1.2, Breathing Zone Sampling, Section 1.1.2.2, Applicability: Breathing zone samples are required: for all calciner maintenance activities, at least quarterly during routine operating and maintenance tasks on representative individuals performing these tasks, when radiation work permits are issued in which airborne concentrations may exceed 25% oflOCFRlO limits, weekly for yellowcake operations, or at the discretion ofthe RSO. 1) Are BZ air samples being taken: for all calciner maintenance activities? Yes 12 ] No • at least quarterly during routine operating and maintenance tasks • on representative individuals performing these tasks? Yes 12 ] No • when radiation work permits are issued in which airborne concentrations may exceed 25% of 10CFR20 limits? YesE ] No • weekly for yellowcake operation?, Yes^ ] No • at the discretion of the RSO? Yes 12 ] No • Conmients: Page 1 of 11 2) Section 1.1.2.3 is the procedure for BZ sampling. Is this procedure being followed? YeslEI NoD Comments: 3) Section 1.1.2.6 lists the Data Records that are to be kept. Are they being kept? YesKl NoQ Conmients: For yellowcake packaging, documented on. "Breathing Zone for Yellowcake Packaging" form. For other BZs. documented on. "Breathing Zone Calibration Form" and "Breathing Zone Sample Field Sheet." 4) Section 1.1.2.7 shows the calculations to be used. Are these calculations being used? YeslEI NoD Are they being used correctly? YeslSI NoQ Comments: Radiation Protection Manual, Section 1.1.2.4, Calibration 3.2 PERSONNEL AIR SAMPLERS The calibration procedure for personnel air samplers involves primary and secondary calibration procedures Samplers will be calibrated prior to each use by either of two methodologies bubble tube or mass flow determinations Air samplers may be calibrated to standard air conditions. 3.2.1 Bubble Tube Calibration Method 3.2.3 Electronic Calibration Method 5) Are calibrations for BZ air samplers being performed and documented prior to each use? Yes 13 NoQ Comments: Documented on "Breathing Zone Calibration Form." Page 2 of 11 6) For BZ air samples being taken, are calibrations for BZ air samplers being performed and documented in accordance with Section 3.2.1 or 3.2.3 of the Radiation Protection Manual? Yes 13 NoD Comments: The Mill is currently using the method outlined in Section 3.2.3. 7) Observe a BZ being calibrated. Which procedure was used and was it done correctly? Procedure: Rad Prot Man Section 3.2.3. Electronic Calibration Method Yes ^ NoQ Comments: No BZ calibrations were directly observed during the inspection. 8) Is the RSO reviewing results that exceed 20% of 10FR20 limits? (Section 1.1.2.8) YeslEI NoD Conmients: Evidenced by the RSO's initials on observed "Breathing Zone Sampling Field Sheets." Radiation Protection Manual, Section 1.1.3.1, Frequency and Locations The following principles used for the collection of area grab samples must be considered when collecting a sample in order to obtain a representative concentration that workers may be exposed to during their assigned work tasks. L The locations selected for sampling should be representative of exposures to employees working in the area. 2. For special air sampling, the sampling period should represent the conditions during the entire period of exposure. This may involve sampling during the entire exposure period. 3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow rate of 40 liters per minute for at least 60 minutes. 4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector. 5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or non-routine situations. Page 3 of 11 9) Are area grab samples obtained in areas representative of workers exposure? (During the Mill tour Have the HP Staff show where the air samples are being taken.) Yes Q NoD N/A |3 Comments: Mill was not in operation during the inspection. No area grab sampling was observed. 10) For routine sampling, did the licensee sample at a minimum flow rate of 40 liters per minute for at least 60 minutes? Yes 13 NoQ Comments: Documented on the, "Sampling Location Field Sheet." 11) Were air sample filters analyzed for gross alpha using a sensitive alpha detector? Yes 13 NoD Comments: Documented on the. "Monthly Area Airborne Sampling FieldSheet." Table 7.7.7-7 for areas where the ALI <.01 and the DAC is <0.01 it state, "Air sampling is generally not necessary. However monthly or quarterly grab samples or some other measurement may be appropriate to confirm that airborne levels are indeed low." 12) Are periodical grab samples taken on a Monthly or Quarterly frequency to confirm that airborne radioactivity remain below ALI <.01 and the DAC is <0.01 values? Yes 13 NoQ Comments: Page 4 of 11 f RML License Condition 11. Annually, the licensee shall collect, during mill operations, a set of air samples covering eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per minute), in routinely or frequently occupied areas ofthe mill. These samples shall be analyzed for gross alpha. In addition, with each change in mill feed material or at least annually, the licensee shall analyze the mill feed or production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the fundamental constituent composition of air sample particulates. 13) Did the licensee perform high volume alpha air sampling in routinely or frequently occupied areas of the mill in accordance with L.C. 11.4? Yes 13 NoD Comments: 14) Did the air samples cover eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per minute)? Yes 13 NoD Comments: 15) With each change in mill feed material or at least annually, did the licensee analyze the mill feed or production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis resiilts to assess the fundamental constituent composition of air sample particulates? Yes 13 NoD Comments: Page 5 of 11 Radiation Protection Manual, Section 1.1.3.2 Sampling Equipment Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for one hour or longer. Equipment utilized will be an Eberline RAS-1, or a Scientific Industries Model H25004, or equivalent. Filter media will have a maximum of 0.8 micron pore diameter. Equipment is calibrated prior to each usage as per Section 6, [3] (typo), of this manual. 16) Are calibrations for area air samplers being performed and documented prior to usage? Yes 13 NoD Comments: 17) Is the licensee using air sample filters that have a maximum of 0.8 micron pore diameter? Yes NoD Comments: 18) Are calibrations for area samplers being performed and documented in accordance with Section 3.3 of this Manual? Yes 13 NoD Comments: 19) Has the licensee provided proper documentation of the results of calibration for the following air sampling equipment? Air Sampler Air Sampler Air Sampler ^Air Sampler High Vol High Vol BZ S/N S/N S/N S/N mi 8915 7983 5449 Yes 13 NoD Yes 13 NoD Yes 13 NoD Yes 13 NoD Comments: Page 6 of 11 20) Section 2.1.2 Frequency/Cocations Has the Licensee performed monthly uranium dust monitoring in the following areas? (Table 2.1.2-1) Airborne Radiation Sample Locations BAl Ore Scalehouse Yes K No BA18 Administrative Building Yes IE No BA2 Ore Storage Yes IE No BA19 Warehouse Yes IE No ^ BA7 SAG Mill Area Yes 13 No • BA20 Maintenance Shop Yes IE No C BA8 Leach Tank Area Yes 13 No • BA21 Boiler Yes 13 No C BA9 Wash Circ CCD Thickness Yes 13 No • BA22 Vanadium Panel Yes 13 No L BAIO Sol Ex Bldg/Stripping Sec Yes K Na BA22A Vanadium Dryer Yes 3 No BAH Sol Ex Bldg/Stripping Room Yes IE No BA23 Filter Belt/Rotary Dryer Yes 13 No BA12 YC Precip/W Storage Area Yes IE No BA24 Tails Yes 3 No BA12A No. YC Dryer Enclosure Yes 13 No • BA25 Central Control Room Yes 13 No C BA12B So. YC Dryer Enclosure Yes 13 No • BA26 Shifter's Office Yes 13 No C BA13 YC Drying/Packaging Area Yes 3 No • BA27 Operator's Lunch Room Yes E No C BA13A YC Packaging Enclosure Yes E No • BA28 Dump Station Yes IE No BA14 Packaged YC Storage Room Yes E No BA29 Filter Press Yes IE No BA15 Met Lab Sample Room Yes IE No BA30 Truck Shop Yes 13 No BA16 Lunch Room Area Yes E 1^0 BA33A Alt Feed Dump Sta. Yes 13 No BA17 Change Room Yes IE No BA33B No. Alt Feed Pad Yes E No Comments: iqCFR20 Table 1 of Appendix B DAC values for ^^^U retention class Y; 2E-lluCi/ml Footnote 3 (for If a mixture of radionuclides consists of uranium and its daughters in ore dust (10 pm AMAD particle distribution assumed) prior to chemical separation ofthe uranium from the ore, the following values may be used for the DAC of the mixture: 6E-llp,Ci of gross alpha activity from uranium-238, uranium-234, thorium-230, and radium-226 per milliliter of air; 3E-llp.Ci of natural uranium per milliliter of air; or 45 micrograms of natural uranium per cubic meter of air. 21) Where any of the air sample results from the above areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of Appendix B? Yes 13 NoD Areas Identified Date Area DAC Value Date Area DAC Value Date Area DAC Value 11/9/11 BA15 167.45% 12/10/11 BA13A 5,184.85% 1/1/11 BA17 25.89% 8/8/11 BA33B 7,267.41% 10/9/11 BA12A 1,383.31% 7/6/11 BA33B 341.67% 9/9/11 BA33A 47.89% 6/5/11 BA7 26.0% N/A N/A N/A Comments: Page 7 of 11 Utah Rules R313-12-3, Definitions "Airborne radioactivity area" means: a room, enclosure, or area in which airborne radioactive material exists in concentrations: (a) In excess ofthe derived air concentrations (DACs), specified in Rule R313-15, or (b) To such a degree that an individual present in the area without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6 percent ofthe annual limit on intake (ALI), or 12 DAC hours. Utah Rules R313-15-902, Posting Requirements ' (4) Posting of Airborne Radioactivity Areas. The licensee or registrant shall post each airborne radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, AIRBORNE RADIOACTIVFTY AREA" or "DANGER, AIRBORNE RADIOACTIVITY AREA." 22) If yes to 21, were the areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of Appendix B properly posted? Yes 13 NoD Comments: Seven areas were identified. Areas BA7, BA12A. BA13A, BA33A and BA33B are routinely posted as airborne radioactivity areas. According to the RSO, Areas BA7 and BAl5 were posted when the elevated DAC levels were identified and down-posted after decon and subsequent sampling. BIOASSAY PROGRAM Radiation Protection Manual, Section 1.4.1 Frequency Urinalysis will be performed on those employees that are a) exposed to airborne yellowcake or involved in maintenance tasks during which yellowcake dust may be produced, orb) routinely exposed to airborne uranium ore dust. Baseline urinalysis will be performed prior to initial work assignments. Urine samples are collected on a routine basis from mill employees as required in Regulatory Guide 8.22. Urine samples will be collected from employees who have worked in yellowcake packaging, yellowcake precipitation, grind area (SAG Mill), ore feed, sample plant, scale house, and the sample preparation room every two weeks during production periods. Samples will be collected from all other employees monthly during production periods. During non-production periods, bi-weekly samples will be collected if individual exposures are expected to exceed 25% ofthe DAC value otherwise samples will be collected from all employees quarterly. Non-routine urinalysis will usually be performed on employees who have been working on assignments that require a Radiation Work Permit, and always on any individual that may have been exposed to airborne uranium or ore dust concentrations that exceed 25% ofthe DAC level. 23) Are urine samples being collected from workers who are working under an RWP? YesQ No 13 Comments: Documentation for 12 employees were reviewed. 4 were working under an RWP. Of those. 2 BZ air samples were found to be > 25% DAC. Of those 2 workers, one worker's sample was given within 2 weeks. The other worker, a Radiation Safety technician, gave his sample 3 Vi weeks after his exposure. Page 8 of 11 being collected from workers in the^^c 24) Are bi-weekly urine samples being collected from workers in the following areas during production? Yellowcake Packaging Yes ^ No Q Yellowcake Precipitation Yes ^ No Q Grind Area (SAG Mill) Yes |3 NoD Ore Feed Yes |3 NoD Sample Plant Yes ^ NoD Scale House ^ Yes |3 NoD Sample Prep Room Yes ^ NoD Comments: Various workers from the above listed areas have given urine samples. Most are within 2 weeks with a few a day of two over 2 weeks. 25) During production periods, are monthly urine samples being collected from all employees working in areas other than those listed above? Yes^ NoD Comments: The Mill has been diligent in collecting urine samples from workers on a monthly basis. 26) Are urine samples being collected from Radiation Safety Personnel every two weeks during production periods? (Radiation Safety Personnel routinely work in areas listed in #21 above). Yes 13 No • N/A • Comments: Not all Radiation Safety Personnel routinely work in the above listed areas. However, the Mill has been collecting urine samples from technicians assigned to these areas. Section 1.4.3 Sample Preparation Sample preparation will be done in an area decontaminated to less than 25 dpm alpha (removable) per 100 crrf prior to preparation of samples. All ofthe equipment that is used in sample preparation will be clean and maintained in such condition. 27) Are the sample preparation area contamination levels maintained below 25dpm/100cm^ a (removable)? Yes 13 NoQ Comments: Survey records were reviewed from January 2011 through present. Page 9 of 11 EXTERNAL MONITORING 28) Section 1.3 Beta-Gamma Surveys Were all observed personnel wearing a personal monitoring badge while in the Restricted Area? Yes 13 NoD Comments: During a Mill tour, all observed personnel were wearing OSL badges. Section 1.3.1 Monitoring Procedures The monitoring procedures consist of: 1. Personnel issued personal monitoring devices will wear the device on the trunk (torso) ofthe 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 remain at the Mill in the personal possession of each 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. 29) Under routine conditions, were observed employees wearing monitoring badges properly on the torso? Yes 13 NoD Comments: All observed personnel were wearing their OSL badges on the front of the torso. 30) 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? Yes 13 NoD Comments: Dosimeters are stored on 'badge boards' at several locations throughout the Mill. Page 10 of 11 31) Check the dosimeter boa^^in the locker rooms, maintenance bui^mg and administration building. Are the badges properly stored? Yes 13 NoD Comments: Badges were found to be properly stored. 32) Have any female workers declared their pregnancy in the past 2 years? YesD No Comments: No declared pregnancies have been documented at the Mill for several years. 33) If yes to 31 above, has the declared pregnant worker been placed on a monthly personal monitoring device exchange during this period? YesD NoQ N/A Comments: Follow-up 34) Alternate feed: Check to see where all of the alternate feed material is being stored. If it is not in the ore pad area then where is it and how is it being stored? Comments: Alternate Feed drums (approximately 60) are presently stored on the Alternate Feed Pad awaiting processing. Alternate Feed drums (approximately 100) containing calcium fluoride, are presently staged on Cell 2 awaiting sampling. Page 11 of 11 1^ VTJm DIVISION OF RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-IEM-Ol INTERNAL/EXTERNAL MONITORING DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATERL\L LICENSE UT1900479 Date: January 19, 2012 CLOSEOUT MEETING MEETING MEMBERS NAME DRC/COMPANY CONTACT INFORMATION Kevin Carney Utah DRC 801-536-4250 Ryan Johnson Utah DRC 801-536-4250 David Turk Denison Mines 801-649-2010 Ron Nieves ^ Denison Mines 801-649-2010 Dan Hillsten Denison Mines 801-649-2010 RADMOD-IEM-Ol INTERNAL/EXTERNAL MONITORING CLOSEOUT MEETING DISCUSSION OF FINDINGS - Yellowcake Packaging Area (BAHA^ and the Alternate Feed Dump Station rBA33A^ R7 records show several high DAC values recorded in 2011. The Mill Staff was asked to investigate and develop ways to lower these airborne levels. . - Several minor abnormalities were noted throughout the reviewed documentation rsiich as a worker unable to give a timely urine sample due to his being incarceratedV The Mill Staff was asked tn document these situations when they occur. - Tt was noted that several workers failed to give urinalysis samples in a timely manner. - During the Mill tour, several members of the tour group were bothered by some of the pungent chemical odors throughout the Mill. STAFF COMMENTS - Mill Staff agreed to look into the elevated DAC values at B A HA and BA^^ A - Mill Staff agreed that there should he more detailed documentation on abnormalities within the sapling programs - Mill Staff agreed to he more conscientious in collecting urinalysis samples from selected workers - Mill Staff agreed that some people who tour the Mill are sensitive to the chemical odors that occur throughout their process However, they are confident that the levels of airborne ha/ardons materials are within all regulatory parameters An NRC representative on the tour voiced concerns to the inspectors about this issue and asked if the PRC had a Memorandum of Understanding with OSHA The inspectors informed the NRC representative that we did not have a MOU with OSHA but that we would forward their concerns to the Mine Safety and Health Administration rMSHAV ^ ^1 $1 UTAH DIVISION OF RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-IEM-01 INTERNAL/EXTERNAL MONITORING DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATEIOAL LICENSE UT1900479 Date: Tamiary 18, 201? OPENING MEETING MEETING MEMBERS NAME DRC/COMPANY CONTACT INFORMATION Kevin Carney Utah DRC 801-536-4250 Ryan Johnson Utah DRC 801-536-4250 David Turk Denison Mines 435-678-2221 Ron Nieves Denison Mines 435-678-2221 - RADMOD-IEM-01 INTERNAL/EXTERNAL MONITORING OPENING MEETING DISCUSSION The Inspectors informed the Mill Staff ofthe scope ofthe inspection. The Inspectors requested access into the Restri(^ted Area of the site and requested documentation for review for the purposes of completing the inspection. , STAFF COMMENTS The Mill Staff communicated that the Inspectors would have access to any records reqnested and offered a tour inside the Mill's Restricted Area , Note: At the time of the inspection, the Mill was hosting a tour of the facility by members of several government agencies in preparation for a future IAEA visit. The DRC inspectors' Mill tour was conducted concurrently with the group tour ! i 1 1 f t i i • • 1 H ; / ' • •'• "- -' ••• • - — " • err c. } } - f ,.•• .1,.— , -, ,1 .... i / f 1 t 1 } j 1 1 f 1 -iL^U^— —^^f-*^ 'ihlf^ —u ^ ^ —£dtL /mfj>I rO^(JdPi> 1 U-i i^bil(( >^jfl^ 3^<^^y ^7Vj>o / — ^. .... 1 ^ 1 I V f 1 . J . . n . ^ IT m J- ————. 1 1—f ^ f 1 ,x. ' ' —-' yc ^y<(Ai-^ y C f ' I 1 1 i 1 ( • • f- " • •••^ • • y s State of Utah GARY R HERBERT Governor GREG BELL Lieutenant Governor Department of Environmental Quality Q p Q Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rusty Lundberg Director -2012-00 190 1 January 30, 2012 David Frydenlund Vice President and General Counsel Denison Mines (USA) Corp 1050 Seventeenth Street, Suite 950 Denver, Colorado 80265 RE DRC Inspection Module RADMOD-IEM-01, January 18 through January 19, 2012, RMLUT1900479 Dear Mr Frydenlund Inspection Module RADMOD-IEM-01 was conducted January 18 through January 19, 2012, by the Division of Radiation Control (DRC) at the White Mesa Mill The inspection focused on the Mill's radiological air monitoring, bioassay program and use of personnel dosimetry Although several discrepancies were noted, all items inspected met applicable regulatory requirements and site procedures A copy of the Inspection Report is attached outlining these discrepancies Please continue to remember that radiation safety is the responsibility of the licensee Thank you for your cooperation in this matter If you have any questions or concerns regarding this letter, please contact Kevin Carney at (801) 536-4250 UTAH RADIATION CONTROL BOARD Rusty Lundberg, Executive Secretary RUKJC kc Enclosure cc David Turk, Site RSO 195 North 1950 West • Salt Lake City, UT Maihng Address P O Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801-533-4097 -TDD (801) 536-4414 ^ WW M deq Utah gov Printed on 100% recycled paper