DRC-2013-001824 - 0901a06880360c01

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
' Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
March 26,2013
Jo Ann S. Tischler, Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood,CO 80228 nRC-20l3-00lB24
Subject: Radioactive Material License No. UT1900479
2013 Radiation Protection Inspection, Module RADMOD-RWP-02
Dear Ms. Tischler:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on March 7 and March 8,2013 by a representative of the Division of Radiation Control (DRC), Utah
Department of Environmental Quality,
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Materials License Number UT 1900479. The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector.
The activities and practices reviewed during the inspection with respect to Radiation Work Permits and
Personal Protection Equipment were found to be in compliance with relevant requirements. Several
suggestions and recommendations for your consideration are included in the enclosed Inspection Report.
The completion of the inspection was facilitated by the attention and cooperation afforded by your
Blanding mill staff. Please extend our appreciation to them.
Ifyou have any question, please contact Boyd Imai at [phone].
Sincerely,
Craig >^ ones. Acting v)irector
V
CWJ/BMI:bi
Enclosure
cc/enc: David Turk, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City, UT
Mailing Address. P O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq Utah gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-RWP-02: Radiation Work Permits/Tersonal Protection
Equipment
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 7 through March 8,2013
Inspector: Boyd Lnai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Daniel Hillsten, Tanner Holliday, Ronnie Nieves, Garrin Pahner, David
Turk
Inspection Summary
The inspection was opened on March 7, 2013 with a meeting among T. Holliday, R. Nieves, G.
Palmer,, and D. Turk. Kevin Carney and Russ Topham from the DRC were also in attendance.
Inspection Objectives were stated which included:
1. Review implementation of Radiation Work Permits (RWP)
2. Assess use of Personal Protection Equipment (PPE)
Areas inspected included:
• Alternate Feed Circuit
• General work areas
The inspector held a closeout meeting on March 8, 2012 with D. Hillsten, T. Holliday, R. Nieves,
and D. Turk of Energy Fuels Resources with K. Carney and R Topham of DRC to review the
inspection activities, observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Radiation Work Permits (RWPs)
The following 10 RWPs prepared in the past 12 months were randomly selected for review:
907 941 981 1029 1048 1053 1057 1059 1062 1075
Each was checked to verify the following:
• Description of the work to be done
Page 1 of 3 '
F\wp\Inspections\Energy Fuel, Biandmg, UT^O 13\Radmod-RWP-02\InspectionReportRev0.doc
• Location of the work
• Duration of the work
• Number of personnel working
• PPE required
• Monitoring required and ^
• RSO Signature
All RWPs contained the above infomiation.
RWP No. 1069 and 969 were checked to confirm supporting documentation, e.g. Confined Space
Hazard Evaluation, Safe Work Permit.
The amount of Radiation Safety coverage (monitoring) is determined when the RWP is
developed. At a minimum, a radiation technician will be at the work site when work begins to
ensure the requirements specified in the RWP are being followed. From that point the coverage
will be continuous or intermittent depending upon the activity.
Typically, there are no standing RWPs. For ongoing activities and operations the RWPs are
replaced by Standard Operating Procedures (SOPs). When a new process starts up, such as with
the Alternate Feed circuit with a new feed stock, the operation will be guided by a RWP written
for that particular process. As the process is refined a SOP is developed capturing in detail the
process and safety ramifications. When the SOP is completed and implemented the RWP is
closed.
RWPs are also generated when non-routine work not covered under a SOP is to be performed. It
was reported that when operational personnel need to conduct non-routine work the Radiation
Safety staff is notified to assess the radiological conditions. The staff will then assess the
location and the planned work activities and develop a RWP as necessary.
SOPs (Calcine, CaF2, UF4, KF) were reviewed to evaluate the manner the RWP-type information
was presented. The SOPs were found lacking in the amount of information offered with respect
to radiological conditions and hazards.
Observations:
There were no signed sheets accompanying the RWPs indicating that the personnel had read
and/or had been briefed on the contents of the RWPs or otherwise had an understanding of the
radiological conditions and hazards associated with the'work task.
No material sampling was observed during the inspection. Apparently there is no formal
guidance on the radiation safety aspects of obtaining samples.
Personal Protection Equipment (PPE)
The RWPs indicate the PPE requirements for the respective activities. At the time of the
inspection no work was being conducted that was performed under an RWP.
PPE requirements are indicated in the SOPs.
Page 2 of3
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Observation:
Only general maintenance activities were observed during the inspection. All workers were
observed wearing standard Level D PPE appropriate for the work activities. No work requiring
respirators was being conducted.
Although mentioned in the SOPs, the PPE requirements lacked specificity in identifying what
PPE was necessary to protect, the worker engaged in the operation.
Conclusion
Work areas are being assessed for radiological conditions and hazards which are addressed
accordingly.
Closeout Meeting ,
The inspector held a closeout meeting with D. Hillsten, T. Holhday, R. Nieves, and D. Turk of
Energy Fuels Resources (USA) on March 8, 2013. Also in attendance were K. Carney and R.
Topham of the DRC. The observations described above were summarized during the meeting.
Recommendations to the Licensee
Subsequent research suggests that RWPs are tools to be used by Radiation Safety Programs and
there is no specific requirement for workers to acknowledge the contents, e.g. a signature sheet
for the employees. The Licensee is encouraged to continue to utilize the RWP as it has and to
somehow connect it formally to the Safe Work Permit which is signed by the worker. This will
docimient the fact that the employee had knowledge ofthe radiological conditions and hazards.
It is recommended that the Licensee review all SOPs and assess the adequacy of radiation safety
information provided. Workers need to be advised regarding what radiological conditions and
hazards can be encountered in the process. This information could be inserted into the "Hazard
Assessment" section ofthe specific activities described in the SOP.
It is suggested that an ALARA review of all sampling activities be performed to determine if
there is a dose reduction possibility.
The SOPs acknowledge that PPE are required for the work but should be more expUcit as to what
equipment is necessary for worker protection.
Recommendation to the DRC Director
Nothing observed during the inspection appeaired to directly violate Hcense or regulatory
requirements. It is therefore recommended that no enforcement action be taken at this time.
Prepared By: BoydM. Imai 'pf^^^A^fl'^^^^ March 26, 2013
(Name) ' M^Signature) (Date)
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Inspection Report
INSPECTION REPORT
Inspection Module: RADMOD-RWP-02: Radiation Work Permits/Personal Protection
Equipment
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 7 through March 8, 2013
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Daniel Hillsten, Tanner Holliday, Ronnie Nieves, Garrin Palmer, David
Turk
Inspection Summary
The inspection was opened on March 7,2013 with a meeting among T. Holliday, R. Nieves, G.
Palmer, and D. Turk. Kevin Carney and Russ Topham from the DRC were also in attendance.
Inspection Objectives were stated which included:
1. Review implementation of Radiation Work Permits (RWP)
2. Assess use of Personal Protection Equipment (PPE)
Areas inspected included:
• Altemate Feed Circuit
• General work areas
The inspector held a closeout meeting on March 8, 2012 with D. Hillsten, T. Holliday, R. Nieves,
and D. Turk of Energy Fuels Resources with K. Camey and R Topham of DRC to review the
inspection activities, observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
y
Radiation Work Permits (RWPs)
The following 10 RWPs prepared in the past 12 months were randomly selected for review:
907 941 981 1029 1048 1053 1057 1059 1062 1075
Each was checked to verify the following:
• Description of the work to be done
Page 1 of 3
F:\wp\Inspections\Energy Fuel, Blanding, UTk2013\Radmod-RWP-02\InspectionReportRevO doc
• Location of the work
• Duration of the work
• Number of personnel working
• PPE required
• Monitoring required and ^
• RSOSignattire '
All RWPs contained the above information.
RWP No. 1069 and 969 were checked to confirm supporting documentation, e.g. Confined Space
Hazard Evaluation, Safe Work Permit.
The amount of Radiation Safety coverage (monitoring) is determined when the RWP is
developed. At a minimum, a radiation technician will be at the work site when work begins to
ensure the requirements specified in the RWP are being followed. From that point the coverage
will be continuous or intermittent depending upon the activity.
Typically, there are no standing RWPs. For ongoing activities and operations the RWPs are
replaced by Standard Operating Procedures (SOPs). When a new process starts up, such as with
the Alternate Feed circuit with a new feed stock, the operation will be guided by a RWP written
for that particular process. As the process is refined a SOP is developed capturing in detail the
process and safety ramifications. When the SOP is completed and implemented the RWP is
closed.
RWPs are also generated when non-routine work not covered under a SOP is to be performed. It
was reported that when operational personnel need to conduct non-routine work the Radiation
Safety staff is notified to assess the radiological conditions. The staff will then assess the
location and the planned work activities and develop a RWP as necessary.
SOPs (Calcine, CaFz, UF4, KF) were reviewed to evaluate the manner the RWP-type infonnation
was presented. The SOPs were found lacking in the amount of information offered with respect
to radiological conditions and hazards.
Observations:
There were no signed sheets accompanying the RWPs indicating that the personnel had read
and/or had been briefed on the contents of the RWPs or otherwise had an understanding of the
radiological conditions and hazards associated with the work task.
No material sampling was observed during the inspection. Apparently there is no formal
guidance on the radiation safety aspects of obtaining samples.
Personal Protection Equipment (PPE)
The RWPs indicate the PPE requirements for the respective activities. At the time of the
inspection no work was being conducted that was perfomied under an RWP.
PPE requirements are indicated in the SOPs.
Page 2 of3
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-RWP-02\InspectionReportRevO doc
Observation:
Only general maintenance activities were observed during the inspection. All workers were
observed wearing standard Level D PPE appropriate for the work activities. No work requiring
respirators was being conducted.
Although mentioned in the SOPs, the PPE requirements lacked specificity in identifying what
PPE was necessary to protect the worker engaged in the operation.
Conclusion
Work areas are being assessed for radiological conditions and hazards which are addressed
accordingly.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, T. Holliday, R. Nieves, and D. Turk of
Energy Fuels Resources (USA) on March 8, 2013. Also in attendance were K. Camey and R.
Topham of the DRC. The observations described above were summarized during the meeting.
Recommendations to the Licensee
Subsequent research suggests that RWPs are tools to be used by Radiation Safety Programs and
there is no specific requirement for workers to acknowledge the contents, e.g. a signature sheet
for the employees. The Licensee is encouraged to continue to utilize the RWP as it has and to
somehow connect it formally to the Safe Work Permit which is signed by the worker. This will
document the fact that the employee had knowledge of the radiological conditions and hazards.
It is recommended that the Licensee review all SOPs and assess the adequacy of radiation safety
information provided. Workers need to be advised regarding what radiological conditions and
hazards can be encountered in the process. This information could be inserted into the "Hazard
Assessment" section of the specific activities described in the SOP.
It is suggested that an ALARA review of all sampling activities be performed to determine if
there is a dose reduction possibility.
The SOPs acknowledge that PPE are required for the work but should be more explicit as to what
equipment is necessary for worker protection.
Recommendation to the DRC Director
Nothing observed during the inspection appeared to directly violate license or regulatory
requirements. It is therefore recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai j/ypyc/l/^ll^^^"^ March 26,2013
OSfame) ' M^Signature) \ (Date)
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F:\wp\Inspections\Energy Fuel, Blanding, 111^2013\Radmod-RWP-02\InspectionReportRev0.doc
InspeeOoH Module
mHOD-sw-02 enemia
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-RWP-02
RADIATION WORK PERMITS/PERSONAL PROTECTION EQUIPMENT
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTl900479
References: Radioactive Material License UTl900479, License Renewal Application dated Febmary 28,
2007, Radiation Protection Manual, Section 5,10CFR20, NRC Regulatory Guide 8.30, NRC Regulatory
Guide 8.31, Utah Administrative Code R313-15.
DATE
OPENING MEETING
MEETING MEMBERS
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DISCUSSION
\f^-XMS'
SITE STAFF COMMENTS
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-RWP-02
RWPs/PPE
. ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTl 900479
References: Radioactive Material License UTl900479, License Renewal Apphcation dated Febmary 28, 2007,
Radiation Protection Manual, Section 5,10CFR20, NRC Regulatory Guide 8.30, NRC Regulatory Guide 8.31,
Utah Administrative Code R313-15.
RADIATION WORK PERMITS (Appendix E Section 5.2007 License Renewal)
Radiation Protection Manual Section 5 Radiation Work Permits (RWPs) (Appendix E license renewal)
1) According to the Radiation Protection Manual RWPs are required to contain the following information and
copies ofthe RWPs are kept on file for five years. Review five (5) RWPs from the past 2 years (starting
from the present year). Verify (Yes or No) that the forms contain all of the infonnation that is required.
Date RWP
Number
Work to
be Done
Location
of Work
Duration
of Work
Personnel
Working
PPE
Required
Monitoring
Required
RSO
Signature
y-5
yi^<.
' L
/ • •
/ / /
lc>L 2--/ 1
\/^ yes
7 //
[ I yes 1 / ^
y^£,s ( J I c
/ 7 • ( /
yes I 7 y^5 { yes
7 (
1 Wi_J
1 /
Y«s
1
^^£^1
2) Were all of the RWPs that were reviewed complete?
Comments:
Yes A- No
3) Was supporting documentation (i.e. Safe Work Permits and Confined Space Permits) attached to the RWPs?
Comments: Yes No
U \rad\COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillNHP Inspection modules\2012\Inspection
Modules\RADMOD-RWP-02 revl doc
4) Were non-applicable items on the RWPs lined out or marked with an NA? Yes No
5) Does the RWP form adequately cover all of the information required? Yes No
Comments: ^
6) On average, how much time does the RSO and Radiation Safety staff hag'to review requests for RWPs
before they approve them?
Comments:
7) How does the RSO/Radiation Safety staff verify the RWPs are being followed?
Comments:
8) Section 5.1 of the Mills Radiation Protection manual says "an RWP is required for: c) The receipt, handling
or processing of any altemate feed material or other radioactive material, which has been determined by the
RSO, not to fall within an existing operating procedure". What is the Altemate feed being processed in the
Altemate feed Circuit?
Comments:
9) If there is no SOP for the altemate feed Is there a RWP? . Yes No
Comments: . / ^S^c\<-
10) Observe the Ahemate Feed Circuit, are the employees following the SOP or RWP for the material they are
processing? Yes No
Comments:
U \rad\COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Resources (Denison Mines) - White Mesa UMill\HP Inspection modules\2012\Inspection
Modules\RADMOD-RWP-02 revl doc
11) Identify a RWP that is being worked under during the inspection and go to that work site and verify that the
RWP is being followed. What are the details of the job?
Comments:
A/e> S^^Q^ (?_COP U>^W tlAAx^ /SUvviL ^^yOv^
12) What precautions are necessary to reduce exposure to Uranium and daughters
Comments:
13) What are the monitoring requirements for the RWP?
Comments:
A;A
14) Are the following being done for the RWP being observed?
Yes No
Monitoring requirements being done?
Mill personnel wearing the appropriate PPE?
Other ALARA practices being done?
Was there specialized training documented?
Comments:
15) Is there a RWP for any routine work, not covered by an operating procedure, that could involve the spread
of radioactive materials? (§5.1(b), Radiation Protection Manual)
Comments:
16) Is there a RWP for any non-routine maintenance work or work for which there is no effective operating
procedure, which may by the determination of the Radiation Safety Officer, exceed 25% ofthe R313-15
limits? (§5.1(a), Radiation Protection Manual)
Comments: (2uof«^ > i I ^ ^
U \rad\COMMON\Uranium miUsM le(2)UT1900479 EnergyFuels Resources (Denison Mines) - White Mesa UMill\HP Inspection modules\2012\Inspection
Modules\RADMOD-RWP-02 revl doc
17) Are all non-routine activities reviewed by the Radiation Safety Officer, and has the Mill Manager been
advised (by the RSO) on a regular basis of any activities that require a RWP? (§5.2, Radiation Protection
Manual)
Comments: .
18) Determine the PPE requirements for each Department/Mill Location from the RSO. Then during mill tour.
Department/Location PPE Requirements (check applicable)
Laboratory
PPE Observed Y/N
Hard Hats Tyyek Disp. Gloves Laboratory
PPE Observed Y/N Safety Glasses Hearing Face Shields
Laboratory
PPE Observed Y/N
Safety Boots ^/ Respirators Rubber Suits
Laboratory
PPE Observed Y/N
Rubber Boots Lab Coats • "Other
Laboratory
PPE Observed Y/N
Coveralls Gloves
Mill
PPE Observed Y/N
Hard Hats Tyyek Disp. Gloves Mill
PPE Observed Y/N Safety Glasses ' Hearing Face Shields
Mill
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Mill
PPE Observed Y/N
Rubber Boots 'Lab Coats Other
Mill
PPE Observed Y/N
Coveralls / Gloves
Alternate Feed Circuit
PPE Observed Y/N
Hard Hats Tyyek Disp. Gloves Alternate Feed Circuit
PPE Observed Y/N Safety Glasses Hearing Face Shields
Alternate Feed Circuit
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
PPE Observed Y/N
Rubber Boots Lab Coats Other
Alternate Feed Circuit
PPE Observed Y/N
Coveralls Gloves
Maintenance
PPE Observed Y/N
Hard Hats • Tyyek Disp. Gloves Maintenance
PPE Observed Y/N Safety Glasses Hearing Face Shields
Maintenance
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Maintenance
PPE Observed Y/N
Rubber Boots • Lab Coats Other
Maintenance
PPE Observed Y/N
Coveralls Gloves
Office
PPE Observed Y/N
Hard Hats Tyyek Disp. Gloves Office
PPE Observed Y/N Safety Glasses Hearing Face Shields
Office
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Office
PPE Observed Y/N
Rubber Boots Lab Coats Other
Office
PPE Observed Y/N
Coveralls Gloves
Ore Receiving
PPE Observed Y/N
Hard Hats • Tyyek Disp. Gloves Ore Receiving
PPE Observed Y/N Safety Glasses Hearing Face Shields
Ore Receiving
PPE Observed Y/N
Safety Boots ' Respirators Rubber Suits
Ore Receiving
PPE Observed Y/N
Rubber Boots Lab Coats Other
Ore Receiving
PPE Observed Y/N
Coveralls Gloves
Warehouse Hard Hats Tyvek Disp. Gloves
U \rad\COMMON\Uranium millsM le(2)UTl 900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillNHP Inspection modules\2012\Inspection
Modules\RADMOD-RWP-02 revl doc
PPE Observed Y/N Safety Glasses Hearing Face Shields PPE Observed Y/N
Safety Boots Respirators Rubber Suits
PPE Observed Y/N
Rubber Boots Lab Coats Other
PPE Observed Y/N
Coveralls Gloves
Utility Crew
PPE Observed Y/N
Hard Hats Tyvek Disp. Gloves Utility Crew
PPE Observed Y/N Safety Glasses Hearing Face Shields
Utility Crew
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Utility Crew
PPE Observed Y/N
Rubber Boots Lab Coats Other
Utility Crew
PPE Observed Y/N
Coveralls Gloves
Decon Crew
PPE Observed Y/N
Hard Hats Tyvek Disp. Gloves Decon Crew
PPE Observed Y/N Safety Glasses Hearing Face Shields
Decon Crew
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Decon Crew
PPE Observed Y/N
Decon Crew
PPE Observed Y/N
Rubber Boots Lab Coats Other
Decon Crew
PPE Observed Y/N
Coveralls Gloves
PERSONAL PROTECTIVE EQUIPMENT (PPE)
19) Were there any areas in the mill that were observed that did not have an appropriate type or amount of PPE
required? Yes No X
Comments:
20) Where do the mill personnel find out what PPE requirements there are for the department or area that they
are working in?
Comments:
21) How does the Mill verify that the mill personnel are wearing their PPE?
Comments: /
22) How is PPE stored and distributed to employee?
Comments:
U.\rad\COMMON\Uranium millsM le^2)UTl 900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillNHP Inspection modules\2012\Inspection
Modules\RADMOD-RWP-02 revl doc)
23) When PPE needs to be replaced what is the Mills policy?
Comments: \JU^>»J^WJ-~^
U \rad\COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillNHP Inspection modules\2012\Inspection
Modules\RADMOD-RWP-02 revl doc
DATE 3/^//3
CLOSEOUT MEETING
MEETING MEMBERS
NAME 1 COMPANY CONTACT INFORMATION
f Ef <^
u
DISCUSSION of FINDINGS
<^!C^^<j^v^Jlr y%aJ?. fi^M^ Ko/^s:-
SITE STAFF COMMENTS
D. f^t f- ^-Mcfis »^n;^Ki>-f SoJ&rycA ^f(4W?g^M/^ reytju^^c^^>u2^,^
H.P. Module Inspection Closeout Meeting Presentation Transcript
Presented by: Boyd Imai, Inspector, Utah Division of Radiation Control
RADMOD-RWP-02
Date: March 8, 2013
Disclaimer: Comments are preliminary. DRC Management will make final determinations.
Initial Objectives:
1. Assess the Radiation Work Permit process including implementation and effectiveness
2. Evaluate the adequacy of the use of Personal Protection Equipment
I regret to say that I fell short of achieving those objectives. In fact, this report is more of an apology
than a critical assessment of these two areas. Throughout the day it became apparent that it was more
of a training exercise for me rather than a true inspection of your activities.
I arrived here thinking I knew what to look for and how things needed to be done based on my previous
experiences, but I was constantly reminded that the paradigm I am accustomed to does not necessarily
apply to U-Mill operations.
Tm not in a position to make compliance determinations at this time because there is some doubt as to
what exactly the regulatory requirements are. Therefore; I probably do not have much to offer in terms
of constructive criticism.
However, what I can offer is some food for thought by way of compliance questions that arose in my
mind as I reviewed the activities and documents.
First: In reviewing the RWPs I didn't see any acknowledgement by the individuals performing the work
that they had been briefed or read and/or understood the radiological conditions and hazards that
confronted them. Tm accustomed to seeing a signed sheet indicating such. Is this a requirement? I
need to research it and find out.
Second: The transition from RWPs to SOPs seems to leave gaps in communicating the radiation safety
practices and requirements. I understand that most activities are initiated under a RWP and that the
radiological conditions and hazards are better understood during the development ofthe SOP.
However, those conditions and hazards are not captured in the SOP. If the SOP is totally replacing the
RWP then the radiological information should be communicated to those that need to read and follow
the procedures. It is universally preached that the individual is responsible for his/her exposures and
doses but how can they be expected to make good decisions if they are not fully informed?
A suggestion would be to include that information in the "Hazard Assessment" section ofthe specific
activities described in the SOP. Indicate the radiation exposure rates that can be encountered when
engaged in the activity and also the radioactivity concentrations. Airborne radioactivity could also be
addressed.
Third: I was unable to observe any process sampling but I was not made aware of any formal guidance
with respect radiation safety the sampler needs to follow to minimize exposures. Maybe none is
needed but Tm asking you to take just a moment to assess the potential for doses to the samplers at all
sampling locations. Basically, Vm suggesting a quick ALARA assessment ofthe sampling activities as an
opportunity for dose reduction.
Fourth: The PPE requirements, like the radiological conditions, aren't always transferred from the RWP
to the SOP. For example: In the Potassium Fluoride (KF) SOP, NODE #2 KF Slurry, Decant, & Storage, the
requirement is:
"Whenever working in, around, or on this process circuit YOU MUST wear PPE. Additional PPE
may be required as defined by a Radiation Work Permit."
This does not help the reader very much, especially in the absence of an additional RWP. A am
recommending more specificity with respect to PPE in the SOPs.
That all being said and in spite of my short comings and whether or not some of these issues are
technically compliance problems, my conclusion is that the work areas are being assessed for the
radiological concerns which is essentially the purpose ofthe RWP. I like the process whereby the
operations staff knows to get a radiological evaluation of an area when non-routine work needs to be
done which requires the radiation safety staff to determine if a RWP needs to be implemented. The fact
that over a 150 RWPs were written in 2012 is an indicator that the evaluations are being done and RWPs
are being used to guide the work activities.
I recognize that my perspective and priorities different from yours. Mine are strictly focused on health
physics and radiation safety aspects and I know you have much more on your plates and radiation safety
may need to take a back seat to other more serious concerns. Just don't let it be totally forgotten or
ignored in the SOPs. -
Bottom line—in my report to my management I will be recommending that not violations or deficiencies
be cited as a result of this inspection.
I appreciate the cooperation, consideration, and open feedback offered by your staff during the
inspection. I may have been duped but I never felt that anyone was attempting to hide anything.
Thanks for your assistance in conducting this inspection.
Are there any Questions?
(There were none)
Energy Fuels Resources Staff discussion comments
D. Hillsten—U-mill operations are not necessarily subject to the same requirements imposed on other
type Radioactive Material Licensees.
D. Turk—Signing a RWP is not a requirement.
R. Nieves—Employees sign the Safe Work Permit which is attached to the RWP.
D. Hillsten—Yes, there are many safety considerations in all operations and radiation safety is always
considered and addressed.
other Supporting aoGumentatlon
White Mesa Mill - Standard Operating Procedures Date: 2/07 Revision: DUSA-1
SOPPBL-RP-1
Book 9: Radiation Protection Manual, Section 5 Page 1 of 2
5. RADIATION WORK PERMITS
5.1 General
A Radiation Work Permit ("RWP") system has been established for non-routine activities
where there is a potential for a significant radiation exposure, or for certain routine
activities where there is a potential to spread radioactive materials.
Specifically, an RWP is required for:
a) All non-routine maintenance work, or work for which there is no effective
operating procedure, which may, by the determination of the Radiation Safety
Officer, exceed 25% ofthe R313-15 limits;
b) All routine work, not covered by an operating procedure, that could involve
the spread of radioactive materials; and
c) The receipt, handling or processing of any altemate feed material or other
radioactive material, which has been determined by the Radiation Safety Officer,
not to fall within an existing operating procedure.
An RWP may also be used on a temporary basis for routine activities in lieu of an
operating procedure, while an operating procedure is being developed for the activity.
5.2 All Non-Routine Activities Require Radiation Safety OfTicer
Review
All non-routine activities require review by the Radiation Safety Officer. The Radiation
Safety Officer will advise the Mill Manager on a regular basis of any activities that
require an RWP.
5.3 Radiation Work Permit
The RWP is a form that describes the work to be performed, the location, duration and
personnel involved, and the radiological controls needed, such as respirator, urine
samples, breathing zone monitoring, time limitations for the activity, etc. The form must
also have an area for the Radiation Safety Officer, or his designee's, signature. A copy of
a form of RWP is attached.
5.4 Procedure for Obtaining a Radiation Work Permit
The procedure for obtaining an RWP is:
White Mesa Mill - Standard Operating Procedures Date: 2/07 Revision: DUSA-1
SOPPBL-RP-1
Book 9: Radiation Protection Manual, Section 5 Page 2 of 2
a) When RWP-type work is to be performed, the Shift Foreman, Maintenance
Superintendent or other supervisory personnel shall complete the top portion of
the RWP, which will provide information on the specific work locations,
estimated work duration, type of work to be performed, and personnel utilized,
and present it to the Radiation Safety Officer;
b) The Radiation Safety Officer will indicate the radiological controls needed
based on the information given and the safety of personnel. The Radiation Safety
Officer or his designee will provide the necessary surveillance and respiratory
protection equipment;
c) No work can be performed until the Radiation Safety Officer or his designee
has approved the RWP;
d) Any maintenance or RWP jobs done in the yellowcake dryer or packaging
enclosures will requue a member of the Radiation Staff to be present for the
duration of the job;
e) All supervisors will be given training in and copies of the requirements for
using RWPs, with the permits remaining on file for five years; and
f) Any supervisor found to be knowingly and willfully violating these
procedures will be issued a v^ritten warning, and the situation will be reviewed by
appropriate management for remedial action.
Energy#iels Resources (USA) cl|
RADIATION WORK PERMIT
RWP#
Requestor
Job Location
Job Description
Date
Rad Tech
Radiological Monitoring and Sampling
At Start Intermittent Continuous At End
(A) Dust (B) Radon Daughters
(D) Gross Alpha
Breathing Zone#
Bioassay
Personnel leaving
Yes
(C) Beta-Gamma
(E) Removable Alpha
Minutes Ran pCi
No
Personnel Protective Equipment
Rubber Gloves Rubber boots
Coveralls Hoods
Rubber suits
Respirators
Name Type1/2full Irritant Smoke Size Proper Fit Worn Fitted by (Initials)
ALARA Considerations
Estimated Job Duration:
Standby Workers
Cleanup
Showers Required
Number of Workers_
Time Limitations
Estimated exposure
APPROVED BY: Date
Name in Out In Out In Out In Out Total Time
Job Status: Completed Changed Cancellec
Permit Terminated
Reviewed By
Date Time
Date
By
No.: PBL-13 DENISON MINES (USA) CORPORATION
Rev. No.: R-l STANDARD OPERATING PROCEDURES Page 3 of 4
Date:-October 13, Title: CaFa Processing
Page 3 of 4
2010
• Repeat the process steps described above for additional dmms of CaF2 material
until the target number of dmms for the cunent batch, as instmcted by your
supervisor, is reached.
• As needed, transfer the sluny of dumped CaF2 material to the digestion tank as
instmcted by your supervisor.
• Turn off the dmm dumper, the weigh scale, and the conveyor.
• Clean up any spilled CaF2 material, dmm parts, tools, etc. and ensure your work
area is free of hazardous obstmctions. Prepare the area to handle the next batch of
dmms.
Special handling of dmms of CaFa material whose contents have solidified will be as
follows:
• Use equipment and methods as instmcted by your supervisor to remove the dmm
from its contents or to remove the contents from the dmm.
• Use equipment and methods as instmcted by your supervisor to break up the
solidified chunks of CaF2 material until the pieces are small enough to be loaded
into dmms and fed to normal processing by the dmm dumping station.
• Load the cmshed CaF2 material into dmms as instructed by your supervisor,
fasten dmm lids, and transport the dmms to the dmm dumping station.
• For any dmms that cannot be re-used, cmsh the dmms for disposal and dispose of
the cmshed drums as instmcted by your supervisor.
• In all steps of special handling, use water as instmcted by your supervisor to
control dust emissions.
Whenever working in, around or on this prbcesscircuit you must wea^
(Sppropriate^PE^wh^ may include Tyvex coveralls, rubber boots, gloves,
(safel^^asses, faceshield or full face respirators or whatever level of respiratory
protection is deemed appropriateJiy-the^Radiation Safetj^-Officer._
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Book 12, ALARA Program, Appendix B 2/07 Revision: DUSA-1
Weekly Mill inspection
To : Denison Mines Supervisors
From :
Date :
For the week of:
The following areas of the White Mesa Mill were inspected. A description of the potential safety hazards,
housekeeping, operational and radiological conditions are described. The color code breakdown is for those
departments I feel are responsible, but not limited to for repair of said items:
Red - Maintenance Green - Safety Blue - Operations/Labor Crew
If an item is underlined, that item must be corrected immediately.
Leach Tank Area:
CCD Area:
Control Room and Lunch Area:
Administration Building:
Soda Ash:
Labor Change Room:
SAG Mill:
Vanadium Circuit:
Book 12, ALARA Program, Appendix B
Page Two
Weekly Mill Inspection
Ore Storage:
Tailings:
SX Building:
Warehouse/Maintenance:
Miscellaneous/Comments:
2/07 Revision: DUSA-1