DRC-2013-002818 - 0901a068803a2f47

JTC., AW
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
"DRC-2013-002818"
June 21, 2013
Jo Ann S. Tischler, Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Radioactive Material License No. UT1900479
2013 Radiation Protection Inspection, Module RADMOD-RPP-02
Dear Ms. Tischler:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on June 13 and June 14,2013 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 Respiratory Protection Program
were found to be in compliance with relevant requirements. Several suggestions and recommendations for
your consideration are included in the enclosed Inspection Report.
Additionally, the attention the Mill personnel have given to the issue of facial hair and the use of
respirators identified in the previous inspection is laudable. It was evident that all those encountered
during this inspection have accepted and embraced the need for compliance in this regard.
If you have any question, please contact Boyd Imai at [phone].
Sincerely,
DncHr T nn/inarrr llirQ/»f /*vr» • *^ Rusty Lundberg, Director
RL/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] • T D D [phone]
www deq Utah gov
Printed on 100% recycled paper
1
INSPECTION REPORT
Inspection Module: RADMOD-RPP-02: Respiratory Protection Program
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): June 13, 2013 through June 14, 2013
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Daniel Hillsten, Ronnie Nieves, Travis Oneil,Terry Slade, David Turk
Inspection Summary
The inspection was opened on June 13, 2013 with a meeting with D. Hillsten, and R. Nieves,
Kevin Carney from the DRC was also in attendance.
Areas inspected included:
• Previous inspection follow-up
• Respirator issuance
• Respiratory Protection Program Training
• Medical surveillance/evaluation
• Quantitative fit testing
• Respirator maintenance
The inspector held a closeout meeting on June 14, 2013 with D. Hillsten, R. Nieves, T. Slade,
and Dave Turk of Energy Fuels Resources with K. Carney of DRC to review the inspection
activities, observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Previous Inspection Follow-up
During the inspection conducted in November 2012 the issue was raised of facial hair
compromising the designed seal of a respirator. The Utah Division of Radiation Control (DRC)
issued a position statement that "facial hair shall not be present where any part of the sealing
surface of a tight-fitting, full face respirator contacts the skin qf the respirator wearer." The
Licensee concurred with DRC's position and committed to revise the language in the Respiratory
Protection Program to clarify that no facial hair will be permitted that could potentially interfere
with the face to facepiece seal, including goatees. The Licensee provided a copy of the revised
procedure showing the changes were implemented.
Page 1 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-RRP-02\InspectionReportRev0.doc
A number of interviewed workers who were issued respirators for the day were cognizant of the
requirement. All were compliant in this respect. Several emphasized the need to be clean shaven
for respirator use. The Radiation Safety Officer (RSO) indicated that he impressed upon all the
technicians that they are responsible for ensuring there is no excessive facial hair before issuing a
respirator.
Also a reminder of the requirement was added to the posting found in the respirator shop.
Respirator Issuance
Respirator issuance occurred prior to the arrival of the inspector; therefore, the process was not
directly observed. However, the process was explained and appears to satisfactorily control the
issuing activities.
The "Respiratory Approval Information 2013" sheet is a personnel roster maintained by the RSO
that indicates the qualifications each individual has in order to be issued a respirator. The
issuing technician refers to this roster to determine whether or not an individual is qualified to
wear a respirator and, if so, which respirator size is authorized to be worn.
There is also a list posted that indicates individuals that are not to be issued a respirator because
they fail to meet minimum qualifications to wear a respirator.
Respirators ready for use are bagged and stored in a locked cabinet in the shop.
When a respirator is issued the qualitative tests, i.e. positive and negative pressure tests, and the
irritant smoke tests are performed. When asked, the workers verified that the tests were
performed when the respirators were issued.
Pertinent information is entered in a log each time a respirator is issued.
Observations:
The Respiratory Approval Information sheet contains an "Annual Training Conducted" data field
but on the sheet provided the field was empty/blank. A sample of personnel records indicated
that the training had been completed.
The Licensee utilizes two MSA respirator models, the Advantage and the Ultra. The. Advantage
is newer and is the favorite for the workers. The RSO indicated that the Ultra respirators are
maintained and are used as "back-ups" (in case the supply of the Advantage models is depleted).
It was indicated that the workers were fit tested with the Advantage respirator and therefore are
not qualified to use the Ultra respirator. The approval sheet only indicates the size of respirator
the worker tested in for fit but not the model. Both models are stored in the same cabinet in the
respirator shop. Based on size alone, the issuer could potentially issue a respirator on which a fit
test was not performed.
Respiratory Protection Program Training
Respiratory protection training is covered in the annual training required for all workers,
including respirator users and supervisors. Respirator maintenance is covered in the standard
Page 2 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-RWP-02\Radmod-RRP-02\InspectiorjReportRev0.doc
«
operating procedure, RPP-1 Book 14. The technicians that maintain the respirators have
documented that they have been trained and understand the requirements presented in the
procedure.
Medical Surveillance/Evaluation
The Respiratory Approval Information sheet indicates the Medical Clearance date for each
worker. A medical evaluation is required that indicates an individual is medically fit to use a
respirator. Further, Regulatory Guide,8.15 Sec. 5.1.3, 10 CFR 20.1703(c)(5) and UAC R313-15-
703(3)(e) all indicate that this evaluation must be performed prior to respirator fit-testing.
A review of the approval sheet showed that 64 individuals' fit test preceded the date of the
"Medical Clearance." The records for the medical evaluations were not immediately available
for review to ascertain whether or not an earlier evaluation had been performed. However, prior
to the inspection closeout meeting the Licensee was able to produce the records necessary to
verify that a medical evaluation had been conducted prior to the current fit test.
Observation:
The RSO was unable to access the records to substantiate compliance and the information that
was available suggested noncompliance with the regulations. The Licensee may want to address /
this situation, keeping in mind that medical records must remain private.
Quantitative Fit Testing
No quantitative fit testing was being performed during the inspection and therefore was not
evaluated. A records review indicated that the tests are being performed annually. Interviews
with personnel indicated that qualitative testing is performed each time a respirator is issued.
Respirator Maintenance
A room dedicated to the maintenance and storage of respirators was inspected. The room
appeared clean and orderly. Respirators ready for issue were bagged and locked in a cabinet.
When a respirator is returned after use it is disassembled and placed in a bath of water and
cleaning solution prescribed by the manufacturer (MSA). After soaking for a minimum of 10
minutes the components are scrubbed by the technician who also looks for any damage. The
components are dried and reassembled. A contamination wipe sample is taken and analyzed for
alpha contamination. A 100 dpm/100 cm2 limit is applied. If the limit is exceeded the area is
cleaned and resampled. The results are documented on the "Respirator Contamination Survey"
form.
Two models of full-face respirators are utilized at the mill site, the MSA Advantage and the
MSA Ultra. Typically only the Advantage respirators are utilized by the workers. The
Advantages are a newer model and are favored by the workers. The Ultras are maintained and
available as needed. Samples of both types in the storage cabinet were found to have been
serviced within the last quarter as specified in the procedure.
Half-face or quarter-face respirators are not used at the mill. Supplied air hoods and supplied air
suits are not used at the mill.
Page 3 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Rao^od-RWP-02\Raa^od-RRP-02\mspectionReportRevO
Breathing Air Quality
The Licensee utilizes Self Contained Breathing Apparatuses (SCBAs) but for only emergency
situations. Since time constraints did not allow an evaluation of the SCBA breathing air quality
during the inspection it was suggested to the Licensee that the quality be checked. The Licensee
assured that the SCBA breathing air meets the quality standards.
Conclusion
All aspects of the Respiratory Protection Program assessed during the inspection were found to
be in compliance with relevant requirements.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, R. Nieves, T. Slade, and D. Turk of
Energy Fuels Resources (USA) on June 14, 2013. Also in attendance was K. Carney of the
DRC. The observations described above were summarized during the meeting.
Recommendations for the Licensee
• On the "Respirator Contamination Survey" form it is suggested that the type of radiation
being measured be indicated on the form, i.e. alpha (a).
• The RSO should have access to all records relating to the radiation safety program,
including the medical records.
• Regarding the medical evaluation for qualifying a worker to use a respirator, a non-
private medical-approval document/form might be prepared that states whether or not an
individual may use respirators, or which devices may be used and which may not be used.
Other details of the medical evaluation need not be disclosed on the form. Control of
such documents would not need to be as strict as that of the medical records and would be
available to staff on a broader basis.
• The "Annual Training Conducted" field on the "Respiratory Approval Information 2013"
form should show the date the individual was last trained on the use of a respirator. This
will assist the technician issuing respirators in assessing the individual's qualifications.
• The make and model of the respirator(s) that the worker passed in the fit testing should
also be indicated on the "Respiratory Approval Information 2013" form in addition to the
information already presented, e.g. MSA, Advantage 3200. This will avoid the issuance
of a respirator in which the worker was not fit tested.
Recommendations for future Inspections
• Assess the condition of the SCBAs and the breathing air quality used.
• Observe a fit test. Compare results with the associated Assigned Protection Factor.
• Instead of reviewing medical records, review the fit test records which should indicate
that the worker was medically cleared before the test was administered.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai
(Name) (Signature)
June 20, 2013
(Date)
Page 4 of4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-RWT-02\Radmod-RRP-02te
Inspection Report
ana
RADMOD-RPP-02 Checklist
INSPECTION REPORT
Inspection Module: RADMOD-RPP-02: Respiratory Protection Program
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): June 13, 2013 through June 14, 2013
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Daniel Hillsten, Ronnie Nieves, Travis Oneil,Terry Slade, David Turk
Inspection Summary
The inspection was opened on June 13, 2013 with a meeting with D. Hillsten, and R. Nieves,
Kevin Carney from the DRC was also in attendance.
Areas inspected included:
• Previous inspection follow-up
• Respirator issuance
• Respiratory Protection Program Training
• Medical surveillance/evaluation
• Quantitative fit testing
• Respirator maintenance
The inspector held a closeout meeting on June 14, 2013 with D. Hillsten, R. Nieves, T. Slade,
and Dave Turk of Energy Fuels Resources with K. Carney of DRC to review the inspection
activities, observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Previous Inspection Follow-up
During the inspection conducted in November 2012 the issue was raised of facial hair
compromising the designed seal of a respirator. The Utah Division of Radiation Control (DRC)
issued a position statement that "facial hair shall not be present where any part of the sealing
surface of a tight-fitting, full face respirator contacts the skin of the respirator wearer." The
Licensee concurred with DRC's position and committed to revise the language in the Respiratory
Protection Program to clarify that no facial hair will be permitted that could potentially interfere
with the face to facepiece seal, including goatees. The Licensee provided a copy of the revised
procedure showing the changes were implemented.
Page 1 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013VRadmod-RRP-02\InspectionReportRev0.doc
A number of interviewed workers who were issued respirators for the day were cognizant of the
requirement. All were compliant in this respect. Several emphasized the need to be clean shaven
for respirator use. The Radiation Safety Officer (RSO) indicated that he impressed upon all the
technicians that they are responsible for ensuring there is no excessive facial hair before issuing a
respirator.
Also a reminder of the requirement was added to the posting found in the respirator shop.
Respirator Issuance
Respirator issuance occurred prior to the arrival of the inspector; therefore, the process was not
directly observed. However, the process was explained and appears to satisfactorily control the
issuing activities.
The "Respiratory Approval Information 2013" sheet is a personnel roster maintained by the RSO
that indicates the qualifications each individual has in order to be issued a respirator. The
issuing technician refers to this roster to determine whether or not an individual is qualified to
wear a respirator and, if so, which respirator size is authorized to be worn.
There is also a list posted that indicates individuals that are not to be issued a respirator because
they fail to meet minimum qualifications to wear a respirator.
Respirators ready for use are bagged and stored in a locked cabinet in the shop.
When a respirator is issued the qualitative tests, i.e. positive and negative pressure tests, and the
irritant smoke tests are performed. When asked, the workers verified that the tests were
performed when the respirators were issued.
Pertinent information is entered in a log each time a respirator is issued.
Observations:
The Respiratory Approval Information sheet contains an "Annual Training Conducted" data field
but on the sheet provided the field was empty/blank. A sample of personnel records indicated
that the training had been completed.
The Licensee utilizes two MSA respirator models, the Advantage and the Ultra. The Advantage
is newer and is the favorite for the workers. The RSO indicated that the Ultra respirators are
maintained and are used as "back-ups" (in case the supply of the Advantage models is depleted).
It was indicated that the workers were fit tested with the Advantage respirator and therefore are
not qualified to use the Ultra respirator. The approval sheet only indicates the size of respirator
the worker tested in for fit but not the model. Both models are stored in the same cabinet in the
respirator shop. Based on size alone, the issuer could potentially issue a respirator on which a fit
test was not performed.
Respiratory Protection Program Training
Respiratory protection training is covered in the annual training required for all workers,
including respirator users and supervisors. Respirator maintenance is covered in the standard
Page 2 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Ratood-RWP-02\Radmod-RRP-02\InspectionReportRev0.doc
operating procedure, RPP-1 Book 14. The technicians that maintain the respirators have
documented that they have been trained and understand the requirements presented in the
procedure.
Medical Surveillance/Evaluation
The Respiratory Approval Information sheet indicates the Medical Clearance date for each
worker. A medical evaluation is required that indicates an individual is medically fit to use a
respirator. Further, Regulatory Guide 8.15 Sec. 5.1.3,10 CFR 20.1703(c)(5) and UAC R313-15-
703(3)(e) all indicate that this evaluation must be performed prior to respirator fit-testing.
A review of the approval sheet showed that 64 individuals' fit test preceded the date of the
"Medical Clearance." The records for the medical evaluations were not immediately available
for review to ascertain whether or not an earlier evaluation had been performed. However, prior
to the inspection closeout meeting the Licensee was able to produce the records necessary to
verify that a medical evaluation had been conducted prior to the current fit test.
Observation:
The RSO was unable to access the records to substantiate compliance and the information that
was available suggested noncompliance with the regulations. The Licensee may want to address
this situation, keeping in mind that medical records must remain private.
Quantitative Fit Testing
No quantitative fit testing was being performed during the inspection and therefore was not
evaluated. A records review indicated that the tests are being performed annually. Interviews
with personnel indicated that qualitative testing is performed each time a respirator is issued.
Respirator Maintenance
A room dedicated to the maintenance and storage of respirators was inspected. The room
appeared clean and orderly. Respirators ready for issue were bagged and locked in a cabinet.
When a respirator is returned after use it is disassembled and placed in a bath of water and
cleaning solution prescribed by the manufacturer (MSA). After soaking for a minimum of 10
minutes the components are scrubbed by the technician who also looks for any damage. The
components are dried and reassembled. A contamination wipe sample is taken and analyzed for
alpha contamination. A 100 dpm/100 cm2 limit is applied. If the limit is exceeded the area is
cleaned and resampled. The results are documented on the "Respirator Contamination Survey"
form.
Two models of full-face respirators are utilized at the mill site, the MSA Advantage and the
MSA Ultra. Typically only the Advantage respirators are utilized by the workers. The
Advantages are a newer model and are favored by the workers. The Ultras are maintained and
available as needed. Samples of both types in the storage cabinet were found to have been
serviced within the last quarter as specified in the procedure.
Half-face or quarter-face respirators are not used at the mill. Supplied air hoods and supplied air
suits are not used at the mill.
Page 3 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Raa^od-RWP-02\Radmod-RRP-02\InspectionReportRev0.doc
Breathing Air Quality
The Licensee utilizes Self Contained Breathing Apparatuses (SCBAs) but for only emergency
situations. Since time constraints did not allow an evaluation of the SCBA breathing air quality
during the inspection it was suggested to the Licensee that the quality be checked. The Licensee
assured that the SCBA breathing air meets the quality standards.
Conclusion
All aspects of the Respiratory Protection Program assessed during the inspection were found to
be in compliance with relevant requirements.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, R. Nieves, T. Slade, and D. Turk of
Energy Fuels Resources (USA) on June 14, 2013. Also in attendance was K. Carney of the
DRC. The observations described .above were summarized during the meeting.
Recommendations for the Licensee I
• On the "Respirator Contamination Survey" form it is suggested that the type of radiation
being measured be indicated on the form, i.e. alpha (a).
• The RSO should have access to all records relating to the radiation safety program,
including the medical records.
• Regarding the medical evaluation for qualifying a worker to use a respirator, a non-
private medical-approval document/form might be prepared that states whether or not an
individual may use respirators, or which devices may be used and which may not be used.
Other details of the medical evaluation need not be disclosed on the form. Control of
such documents would not need to be as strict as that of the medical records and would be
available to staff on a broader basis.
• The "Annual Training Conducted" field on the "Respiratory Approval Information 2013"
form should show the date the individual was last trained on the use of a respirator. This
will assist the technician issuing respirators in assessing the individual's qualifications.
• The make and model of the respirator(s) that the worker passed in the fit testing should
also be indicated on the "Respiratory Approval Information 2013" form in addition to the
information already presented, e.g. MSA, Advantage 3200. This will avoid the issuance
of a respirator in which the worker was not fit tested.
Recommendations for future Inspections
• Assess the condition of the SCBAs and the breathing air quality used.
• Observe a fit test. Compare results with the associated Assigned Protection Factor.
• Instead of reviewing medical records, review the fit test records which should indicate
that the worker was medically cleared before the test was administered.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai
(Name) (Signature)
June 20, 2013
(Date)
Page 4 of 4
F:\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-RWP-02\Radmod-RRP-02\InspectionReportRev0.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-RPP-02 Rev 2
RESPIRATORY PROTECTION PROGAM
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Requirements, Procedures, Policies, Standards:
o Radioactive Materials License UT1900479
o NRC Regulatory Guide 8.15: Acceptable Programs for Respiratory Protection
6 License Renewal Application Appendix L
o Utah Administrative Code R313 -15
R313-15-703. Use of Individual Respiratory Protection Equipment
If the licensee or registrant uses respiratory protection equipment to limit the intake of radioactive
material:
(1) Except as provided in Subsection R313-15-703(2), the licensee or registrant shall use only
respiratory protection equipment that is tested and certified by the National Institute for Occupational
Safety and Health.
(2) The licensee or registrant may use equipment that has not been tested or certified by the National
Institute for Occupational Safety and Health or for which there is no schedule for testing or certification,
provided the licensee or registrant has submitted to the Director and the Director has approved an
application for authorized use of that equipment. The application must include a demonstration by
testing, or a demonstration on the basis of reliable test information, that the material and performance
characteristics of the equipment are capable of providing the proposed degree of protection under
anticipated conditions of use.
(3) The licensee or registrant shall implement and maintain a respiratory protection program that
includes:
(a) Air sampling sufficient to identify the potential hazard, permit proper equipment selection, and
estimate doses; and
(b) Surveys and bioassays, as necessary, to evaluate actual intakes; and
(c) Testing of respirators for operability, user seal check for face sealing devices and functional check
for others, immediately prior to each use; and
(d) Written procedures regarding
(i) Monitoring, including air sampling and bioassays;
(ii) Supervision and training of respirator users;
(iii) Fit testing;
(iv) Respirator selection;
(v) Breathing air quality;
(vi) Inventory and control;
Inspectors
Inspection Dates:
V
Page 1 of 5
(vii) Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection
equipment;
(viii) Recordkeeping; and
(ix) Limitations on periods of respirator use and relief from respirator use; and
(e) Determination by a physician prior to initial fitting of respirators, before the first field use of non-
face sealing respirators, and either every 12 months thereafter or periodically at a frequency determined
by a physician, that the individual user is medically fit to use the respiratory protection equipment; and
(f) Fit testing, with fit factor greater than or equal to ten times the APF for negative pressure devices,
and a fit factor greater than or equal to 500 for positive pressure, continuous flow, and pressure-demand
devices, before the first field use of tight fitting, face-sealing respirators and periodically thereafter at a
frequency not to exceed one year. Fit testing must be performed with the facepiece operating in the
negative pressure mode.
(4) The licensee or registrant shall advise each respirator user that the user may leave the area at any
time for relief from respirator use in the event of equipment malfunction, physical or psychological
distress, procedural or communication failure, significant deterioration of operating conditions, or any
other conditions that might require such relief.
(5) The licensee or registrant shall also consider limitations appropriate to the type and mode of use.
When selecting respiratory devices the licensee shall provide for vision correction, adequate
communication, low temperature work environments, and the concurrent use of other safety or
radiological protection equipment. The licensee or registrant shall use equipment in such a way as not to
interfere with the proper operation of the respirator.
(8) The licensee shall ensure that no objects, materials or substances, such as facial hair, or any
conditions that interfere with the face and facepiece seal or valve function, and that are under the control
of the respirator wearer, are present between the skin of the wearer's face and the sealing surface of a
tight-fitting respirator facepiece.
(9) In estimating the dose to individuals from intake of airborne radioactive materials, the concentration
of radioactive material in the air that is inhaled when respirators are worn is initially assumed to be the
ambient concentration in air without respiratory protection, divided by the assigned protection factor. If
the dose is later found to be greater than the estimated dose, the corrected value must be used. If the dose
is later found to be less than the estimated dose, the corrected value may be used.
Respiratory Protection Program
1) Have the respirators that the licensee uses for respiratory protection been tested and certified by the
National Institute for Occupational Safety and Health? (R313-15-703)
Yes • No • N/A •
Comments:
2) Upon review of the Respirator Protection Program and Mill procedures, are written procedures in the
following areas implemented and maintained? (R313-15-703(3)(d))
Page 2 of 5
Written procedures Yes No
Monitoring, including air sampling and bioassays; l 4 KPf \ . • \'3 ^ „ ^ f •
Supervision and training of respirator users; fock- /f R f P - ( s*^. -z, 3 •
Fittesting; ^^U.^^ ? fl^LU^w if <ePf-1 z.<f 5 •
Respirator selection; •
Breathing air quality; 0 •
Inventory and control; 5^ 2_, •
Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection
equipment; *S*-e-~ ^% c 2.^ 1 o •
Recordkeeping; •
Limitations on periods of respirator use and relief from respirator use; 0 •
Comments: So-y»oft5t>re gg^-& o-^^rr f^ca*^ <-ftM]L SO-KJUE, p^^aX0-^^ jp^^cje^^fy^
Respirator Issuance
3) Have the licensee provide a list of 10 respirator users. Do the following users meet the requirements of
R313-15-703 for respirator training? . JKI^-GL****
Name
5- k^ew &e 1
6- |<^rS*w L
Exams
55
Initial/ Refresher
Training Records
Yes p NoQ
Yes P NoD
Yes t)3 No •
Yes [^t No •
Yes tfi No •
Yes |jcl No •
Medical Clearance
Yes B NoQ
Yes 0 No •
Yes •
Yes 0 NoQ
Yes H No •
Yes p3 No •
Fit Tests .
Yes H No •
Yes 0 NoQ
Yes • No •
Yes 0 No •
Yes H No •
Yes p No •
Page 3 of 5
Yes 13 No • Yes B No • 7. f^5 Yes $f\ No •
Yes E No •
f3
3^ fas* Yes L)3 No • Yes JE] No •
Yes • No • Yes L^l No • 'Yes • No •
Yes H No •
10.
Yes No • Yes H No •
Comments: ^g^nrj^ tn&-c>jU ft^viaAAo JM*X: o^i PaoJl ^WAOSJ^ ux^g_
Respirator Maintenance
4) Has the licensee provided documentation for training of personnel responsible for respirator
maintenance and repair? / t
^os/df/c- Yes^ No • N/AQ
Comments: ""Iv^m* G>' [An* X . ^ u^A^w -fe^C
5) Are used respirators being surveyed after each use?
Yes j£] No • N/A •
Comments: ^&<L^\MJ^J^^-^ fc^pyrdo-c Ce^-V^y*. -U-*-c^ -Su^r
6) Are respirators surveyed for removable contamination?
Page 4 of 5
Yes No • N/A •
Comments:
7) Do respirator surveys properly document the survey performed?
Yes Kl No • N/A •
Comments:
8) Are respirators decontaminated as per Manufacturers Instructions?
Yes g NoD N/A •
Comments: -U^L ^v-il CQ^S
9) Are respirators inspected in accordance with the licensee's Respiratory Protection Program?
Yes H NoD N/A •
Comments: Sfcc Z. to 3
Page 5 of 5
Other Supporting Documentation
• Respiratory Approval Information
• Respirator Checkout log
• Respirator Contamination Survey
Form
• Radiation Salety Training Outline
RESPIRATORY APPROVAL INFORMATION
Name Hire Date
Annual
Training Medical
Conducted Clearance Fit-Tester
Arthur, April
Arthur, Tayton
Atcitty, Leron
Atcitty, Roy
Atwood, Matt
Bailey, Amanda
Barlow, Craig
Bavk-s, Joe
Beaver, David
Begay, Tenaya
Begaye, Shawn
Ben, Jacoby
Bena
Bena
Bena
Bena
Bena
Bena
Bena
lly, Derek
I ly, Jaymes
lly, Jerome
lly, Johnson
lly, Kendall
lly, Matthew
lly, Stephone
Bennett, Herschel
Billsie, James
Bitsinnie, Ty
Black, Ted
Blackhorse, Kaluni
Blackhorse, Tyrone
Brown, Ken
Boy, Verdale
Bunting, Tyler
3/1/2010
1/14/2013
8/11/1997
7/16/2003
2/22/2007
2/9/2009
1/7/2007
4/14/2008
2/15/2010
9/2/2008
3/8/2010
2/11/2013
10/18/2007
1/13/2006
5/22/2006
2/28/2005
1/10/2011
1/14/2013
2/22/2006
3/8/2010
2/11/2013
5/14/2012
12/22/2011
6/19/2006
4/2/2012
6/28/2010
8/11/2008
1/21/2013
1/10/2013
1/21/2013
1/9/2013
1/21/2013
1/19/2013
1/23/2013
1/9/2013
1/25/2013
1/9/2013
1/7/2013
2/12/2013
1/23/2013
1/21/2013
1/23/2013
1/7/2013
1/28/2013
1/9/2013
1/7/2013
1/9/2013
2/5/2013
1/23/2013
1/7/2013
1/9/2013
1/7/2013
1/23/2013
1/21/2013
1/16/2013
1/15/2013
1/9/2013
1/9/2013
1/15/2013
1/16/2013
1/23/2013
1/9/2013
1/18/2013
1/9/2013
1/16/2013
2/12/2013
1/7/2013
1/21/2013
1/16/2013
1/7/2013
1/28/2013
1/15/2013
1/7/2013
1/9/2013
2/12/2013
1/16/2013
1/7/2013
1/9/2013
1/9/2013
1/16/2013
1/21/2013
Size Full-Face PAPR SCBA
S X
M X
M X
L X
M X
S X
L X
M X
S X
L X X
L X X
M X
M X
L X
L X
L X
M X
L X
L X
L X
M X
M X
L X
M X
M X
L X
M X
RESPIRATORY APPROVAL INFORMATION
Name Hire Date
Annual
Training Medical
Conducted Clearance Fit-Tester
Burtenshaw, Blake
Burtenshaw, Rachele
Bylilly, Albert
Carr, David
1/10/2008
2/11/2013
2/28/2005
11/30/2009
1/21/2013
2/4/2013
1/7/2013
5/21/2013
1/16/2013
2/12/2013
1/7/2013
5/20/2013
Charley, Marvin
Cerros, Salvador
Chanthapannha, Kevin
Christensen, Scot
Cly, Dedrick
Cly, Kevin
Cly, Larry
Clah, Nathaniel
Clinger, Benjamin
Cosby, Cody
Cowboy, Jordan
Cowboy, Tremayne
Curley, Ben
Davis, Cody
Dayish, Chuck
Denny, Bobby
Eddie, Messiah
Fowler, Lane
Frisbie, Nathan
2/15/2010
9/10/2012
2/11/2013
5/26/1994
2/11/2013
2/11/2013
2/11/2013
11/16/2011
7/9/2012
10/10/2011
4/2/2012
3/28/2011
2/11/2013
2/11/2013
12/22/2011
1/10/2011
9/10/2012
4/2/2012
3/8/2010
1/9/2013
2/4/2013
2/14/2013
1/21/2013
2/4/2013
2/12/2013
2/6/2013
1/9/2013
1/7/2013
1/9/2013
1/28/2013
1/7/2013
1/25/2013
2/7/2013
1/7/2013
1/9/2013
1/21/2013
1/9/2013
2/5/2013
1/9/2013
1/9/2013
2/12/2013'
1/16/2013'
2/12/2013
2/12/2013
2/12/2013
1/9/2013
1/16/2013
1/9/2013
1/16/2013 '
1/7/2013
2/12/2013'
2/12/2013
1/7/2013
1/9/2013
1/21/2013
1/9/2013
1/9/2013
Gappmayer, Brett
Graf, Michelle
Hancock, Wade
Hatalie, Ramon
Hatalie, Ramsey
8/13/2012
5/23/2010
5/26/1994
3/7/2011
1/14/2013
1/17/2013
1/23/2013
1/23/2013
1/9/2013
1/9/2013
1/7/2013 '
1/16/2013 '
1/17/2013 -
1/9/2013
2/25/2013
Size Full-Face PAPR SCBA
L X
S X
M X
_L X
V X X
M X X
M X
L X
M X X
M X
L X
L X
L X
L X X
M X
L X
M X
M X
L X X
M X
L X
M X
M X X
X
X X
X
X
X
RESPIRATORY APPROVAL INFORMATION
Name Hire Date
Annual
Training Medical
Conducted Clearance Fit-Tester
Hathale, Randy
Haws, Ben
Hawkins, Blain
Haycock, Chad
Helquist, Steven
Hillsten, Dan
Holiday, Kyle
Holiday, Theo
Holliday, Tanner
Holliday, Wayne
Holt, Thayne
Imel, Noah
Ingels, Macen
James, Michael
Jaramillo, Floyd
Jensen, Zackery
Joe, Christopher
Joe, Gerald
John, Robbie
John, Terry
Jones, Davis Jeremy
Jones, Christine
Jones, Jayrando
Jones, Jeremey
Jones, Kenneth
Jones, Lorenzo
Jones, Sheridan
Jones, Stan
Jones, Sterling
4/14/2008
7/9/2012
4/2/2012
4/2/2012
1/1/2011
1/5/2009
2/28/2011
3/1/2010
5/12/2008
2/15/2010
4/8/2002
2/13/2012
4/2/2012
2/11/2013
12/8/2011
4/2/2012
1/14/2013
3/1/2010
12/22/2011
2/1/2010
1/14/2013
3/10/2006
9/10/2012
5/5/2008
9/2/2008
3/19/2020
8/13/2012
8/4/1997
8/16/2010
1/28/2013
2/22/2013
1/23/2013
1/7/2013
1/21/2013
1/23/2013
1/28/2013
1/7/2013
1/7/2013
1/21/2013
1/7/2013
1/23/2013
1/21/2013
2/6/2013
1/23/2013
2/5/2013
1/10/2013
1/23/2013
1/7/2013
1/9/2013
1/10/2013
1/21/2013
1/21/2013
1/21/2013
1/7/2013
1/28/2013
1/9/2013
1/21/2013
1/7/2013
1/28/2013
1/9/2013 -
1/15/2013 -
1/7/2013
1/15/2013 -
1/16/2013 -
1/28/2013
1/7/2013
1/9/2013
1/21/2013
1/7/2013
1/16/2013 '
1/21/2013
2/12/2013
1/16/2013 -
1/9/2013 '
1/15/2013
1/16/2013-
1/10/2013
1/9/2013
1/15/2013
1/17/2013-
1/21/2013
1/16/2013 -
1/7/2013
1/28/2013
1/9/2013
1/18/2013 '
1/7/2013
Size Full-Face PAPR SCBA
M
M
S
S
M
L
L
L
M
L
M
M
M
L
M
M
L
M
L
L
L
M
L
M
M
M
L
L
M
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
RESPIRATORY APPROVAL INFORMATION 2013
Name Hire Date
Annual
Training Medical
Conducted Clearance Fit-Tester Size Full-Face PAPR SCBA
June, Danner
Kaye, Christian
Kaye, Clifford
Keith, Charles
Keith, Shawn
Kemner, Paul
Kreth, Tad
Lacy, David
Lacy, Karson
Lacy, Megan
Lameman, Tully
Lameman, Zackery
Latham, Heath
Laws, Darin
Laws, James
[Little, Chad
Little, Mike
Little, Tyrone
Lyman, David
Maryboy, Milfred
Mays, Sinn Keno
Mendoza, Abel
Mendoza, Abel Jr.
Mendoza, Billy
Mix, Renaldo
Montella, Cortney
Montella, James
Morris, Thomas
Morris, Timothy
9/10/2012
1/14/2013
3/7/2011
9/10/2012
4/4/2011
2/28/2011
5/14/2012
10/10/2011
5/23/2010
7/9/2012
7/9/2007
9/10/2012
12/22/2011
7/27/2007
1/16/2012
8/16/2010^
3/15/2012
12/8/2011
5/14/2012
3/15/2012
4/4/2006
2/23/2007
12/6/2006
5/20/2002
9/10/2012
10/22/2007
1/9/2013
1/14/2013
3/8/2010
1/21/2013
1/10/2013
1/28/2013
1/28/2013
1/28/2013
1/21/2013
1/21/2013
1/7/2013
1/7/2013
1/21/2013
1/7/2013
1/7/2013
1/21/2013
1/9/2013
1/21/2013^
1/21/2013
1/7/2013
1/7/2013
2/27/2013
1/7/2013
1/21/2013
1/21/2013
1/7/2013
1/23/2013
2/27/2013
1/21/2013
1/21/2013
1/9/2013
1/7/2013
1/16/2013 "
1/15/2013
1/28/2013
1/28/2013
1/15/2013 ~
1/16/2013 -
1/15/2013 -
1/10/2013
1/16/2013
1/9/2013 "
1/7/2013
1/7/2013
1/16/2013 ^
1/9/2013
Jt/21/2013
1/21/2013
1/7/2013
1/7/2013
1/21/2013^
1/7/2013
1/29/2013
1/17/2013-
1/19/2013
1/10/2013 -
1/28/2013 -
1/16/2013-
1/9/2013 -
1/15/2013
1/7/2013
M
L
L
L
L
M
M
L
M
M
M
M
S
M
S
M
M
L
M
L
M
M
M
M
L
M
M
M
L
X
X
X
X
X
X
X
X
X
X
X
X
X
X
_x_
x^
X
X
X
X
X
X
X
X
X
X
X
X
X
RESPIRATORY APPROVAL INFORMATION
Name Hire Date
Annual
Training Medical
Conducted Clearance Fit-Tester
Mustache, Watson
Neal, Henry
Nakai, Ivan
Nakai, Kelsey
Nez, Kevin
Nielson, Arden
Nieves, Ronnie
Oneil, Travis
Oshley, Tisdale
Oshley, Truitt
Palmer, Chad
Palmer, Derrick
Palmer, Garrin
Palmer, Wayne
Parker, Oliver
Paul, Roydale
Perkins, Chad
Perkins, Justin
Pilling, Tyrel
Pipkin, Milton
Plott, Travis
Reed, Dustin
Rentz, Phillip
3/28/2011
4/30/2007
3/8/2010
2/11/2013
1/17/2011
7/9/2007
2/23/2007
2/13/2012
6/7/2010
11/1/2010
5/2/2012
3/15/2012
2/15/2010
5/1/2003
12/22/2011
6/23/2008
5/17/2005
3/8/2010
4/2/2012
11/30/2009
5/16/2011
7/30/2012
9/11/2000
1/9/2013
1/21/2013
1/28/2013
2/4/2013
1/28/2013
1/21/2013
1/9/2013
1/21/2013
1/28/2013
1/23/2013
1/28/2013
1/7/2013
1/9/2013
1/21/2013
1/21/2013
1/28/2013
1/22/2013
1/7/2013
2/4/2013
1/21/2013
1/23/2013
1/25/2013
1/7/2013
1/9/2013
1/16/2013
1/16/2013
2/12/2013
1/9/2013
1/16/2013
1/9/2013
1/17/2013
1/28/2013
1/9/2013 "
1/28/2013
1/7/2013
1/9/2013
1/10/2013-
1/21/2013
1/16/2013
1/7/2013
1/7/2013
1/17/2013
1/9/2013 •
1/15/2013
1/28/2013
1/7/2013
Roberts, Kenneth
Rock, Jordan
Romero, Roy
Sandoval, Reeves
Scalplock, Sheldon
3/8/2010
3/19/2012
1/9/2013
2/11/2013
4/2/2012
1/9/2013
1/21/2013
1/8/2013
2/13/2013
1/21/2013
1/9/2013
1/21/2013
1/9/2013
2/12/2013
1/21/2013
Size Full-Face PAPR SCBA
L X
M X
M X
L X
L X X
L X
L X
M X
L X
M X
M X X
L X
S X
M X
M X
M X X
L X
L X
M X
S X
S X
S X X
M X
RESPIRATORY APPROVAL INFORMATION
Name Hire Date
Annual
Training Medical
Conducted Clearance Fit-Tester
Sharpe, Brinton
Sharpe, Tranner
Shepherd, Marlon
Sherrow, Jayson
Sh urn way, Logan
Simpson, Philbert
Simpson, Wesley
Singer, Casey
Slade, Terry
Snyder, Steve
Stanley, Herbert
Sterling, Gage
Stevens, Michael
Taylor, Aaron
Taylor, Josh
Tree, Kevin
Tsosie, Pernell
Turk, David
Vc.leii-u.ek-, Kiu;
Vcuueeneu, bVoi
Vanreenan, James
Warner, Collin
Warren, Frank
Waterman, Jacob
West, Cornelius
West, Deswood
Whitehorse, Nicolas
Yellow, Clarence
2/11/2013
1/9/2013
9/10/2012
2/11/2013
6/14/2010
8/29/2011
8/16/2010
8/15/2011
5/26/1994
5/29/2007
4/28/2008
1/17/2011
9/10/2012
12/14/2009
2/1/2010
2/11/2013
8/16/2010
8/18/1997
3/28/2011
5/16/2011
2/1/2010
3/19/2012
6/28/2010
8/11/2008
5/19/2008
9/23/2007
2/12/2013
1/8/2013
1/21/2013
2/12/2013
1/21/2013
1/7/2013
1/21/2013
1/29/2013
1/7/2013
1/28/2013
1/7/2013
1/9/2013
1/7/2013
1/28/2013
1/7/2013
2/5/2013
1/28/2013
1/21/2013
1/23/2013
1/7/2013
1/28/2013
1/7/2013
1/21/2013
1/7/2013
6/4/2013
2/12/2013
1/9/2013
1/16/2013
2/12/2013
1/16/2013
1/7/2013
1/16/2013
1/16/2013
1/7/2013
1/16/2013
1/7/2013
1/9/2013
1/7/2013
1/28/2013
1/7/2013
2/12/2013
1/28/2013
1/10/2013
1/9/2013 1/9/2013
1/15/2013
1/7/2013
1/16/2013
1/7/2013
1/9/2013 •
1/7/2013
6/3/2013 •
Size Full-Face PAPR SCBA
L X
L X X
L X
L X
M X
L X
M X
M X
M X
M X
L X
S X
M X
L X
M X
S X
M X
_M X X_
M X
M X
M X
M X
L X X
M X
M X X
M X
RESPIRATORY APPROVAL INFORMATION 2013
Annual
Training Medical
Name Hire Date Conducted Clearance Fit-Tester Size Full-Face PAPR SCBA
Young, Ryan 6/15/2005 1/21/2013 1/17/2013 ^ M X X
Zohnnie, Wilson 12/8/2011 1/9/2013 1/9/2013 L X
Individuals highlighted in RED are not authorized to be issued a respirator. Contact the RSO if
these individuals request respiratory protection.
67W13 State of Utah Mail-Question
Boyd Imai <[e-mail]>
Question
1 message
Ronnie Nieves <[e-mail]> Wed, Jun 19, 2013 at 10:00 AM
To: "[e-mail]' <[e-mail]>
Boyd, the re-issue means that a respirator was issued out to an employee but did not use the respirator. So
they bring back the respirator and we do a radiological survey on the respirator and re-issue the same respirator
back to the employee. This way they show the daily exchange was done, and can keep the same respirator for
the next day.
Energy Fuels Resources (USA) Inc.
Ronnie Nieves
Radiation Safety Officer
t: 435-678-2221 x115 | f 435-678-2224
6425 S. Highway 191 PO Box 809
Blanding, UT, US, 84511
http//www.eneng yfuels.com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipients). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you are not the
intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or copy
this message if you are not the intended recipient(s).
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If removable contamination is greater than 100 dpm/100cm2 the area needs to be cleaned and resampled prior to use.
White Mesa Mill ^ Date: Wl2 Revision: EFR-2.3
Book #13 Training Manual 63 of 101
APPENDIX A
RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED INEXPERIENCED
MILL WORKERS
White Mesa Mill Date^^l2 Revision: EFR-2.3
Book #13 Training Manual 64 of 101
RADIATION AND RESPIRATORY PROTECTION SAFETY TRAINING OUTLINE
FOR NEWLY HIRED INEXPERIENCED MILL WORKERS:
1. Video - "Practical Radiation Safety" or "Radiation Naturally"
2. Fundamentals of Health Protection
a. The radiologic and toxic hazards of exposure to uranium and its daughters
i. U-238 is a kidney toxin
ii. Lungs
iii. Liver
iv. Skin
b. How uranium and its daughters enter the body
i. Inhalation
ii. Ingestion
iii. Skin penetration
c. Why exposures to uranium and its daughters should be kept ALARA
i. Definition/explanation of the ALARA principle
ii. Identification of postings in elevated areas
iii. Reference potential hazards with material and why it is important to
maintain levels to ALARA
d. Different types of radiation
i. Alpha
1. Will not penetrate dead layer of skin
2. Travels about 2 inches in air
3. Can be blocked by a single sheet of paper
4. Large particle that is the easiest to protect against, but the one that can
cause the most damage when taken internally. The delicate internal
workings of the living cell forming the lining of the lungs or internal
organs, most certainly will be changed (mutated) or killed outright by
the energetic alpha particle.
5. Housekeeping and good personal hygiene are critical.
ii. Beta
1. Can be blocked with plastic or PPE
2. Penetration greater than Alpha
3. Can penetrate the first two layers of skin
4. Second largest particle.
5. Travels about one meter in the air.
iii. Gamma
1. Smallest in size
2. Can be blocked by lead
3. Is capable of damaging living cells as it slows down by transferring
energy to the surrounding cell components
iv. Radon Progeny
1. Inert gas
2. Transported by carrier (water, diesel smoke, etc...)
White Mesa Mill
Book #13 Training Manual
Date: 12 Revision: EFR-2.3
65 of 101
3. Ventilation is principle remedy
4. Found in soils worldwide
e. Various types of radiation exposure potential at the Mill
i. Conventional Ore - stockpiles and in process
ii. Yellowcake product - in process and final product
iii. Alternate feed materials - stockpile (by various supplier) and in process
iv. Miscellaneous - sealed sources
3. Personal Hygiene at the White Mesa Mill
a. Wearing protective clothing
i. Importance - how the PPE protects against Alpha and/or Beta/Gamma
activity
ii. Types of PPE available
1. Tyvex
2. Coveralls
3. Rubber suits/gloves
4. Respiratory Protection
b. Using respiratory protective equipment correctly - See item 4
c. Eating, drinking and smoking only in designated areas
i. Regulated by the State of Utah and MSHA
ii. Weekly alpha survey
iii. Reducing potential for exposure
iv. Wash hands regardless of job assignment
d. Using proper methods for decontamination
i. Showers requirements
1. Mandatory for Yellowcake Operators
ii. Laundry facility
4. Respiratory Protection Training
a. General
i. Video on Respiratory Protection
ii. Program evaluation and revisions and record keeping
iii. Employee training and documentation
iv. Fit Testing
1. Medical Clearance
2. Fit Tester 3000
3. Irritant smoke
v. Exchange/Issuance requirements - Daily Exchanges are required for all
devices
vi. Storage and care of device
b. Hazards to which the respirator wearer may be exposed, the effects of
contaminants on the wearer if the respirator is not worn properly and the
capabilities and limitations of each device that may be used
i. Respiratory Hazards
1. Uranium airborne and effect
2. Radon daughters and effect
White Mesa Mill
Book #13 Training Manual
Date™ 12 Revision: EFR-2.3
66 of 101
3. Chloride and effect
4. Ammonia and effect
5. Airborne vanadium dust and effect
6. Acid gases and effect
7. Other potential effects
ii. Respirator selection
1. Types of respirators, their function, limitations
a. Full-face with combo cartridges - good for all environments at the
facility (pf of 50)
b. PAPR's - good for only dusty environments, not good for any
environment that may contain chemical mists (pf 1000)
c. SCBA's - good for all environments, has only thirty minute bottle of
air (pf 10000)
d. NIOSH and MSHA approved respirators only
2. Identification of hazards
a. O2 content
b. Routine hazards
c. Non-routine hazards
c. Spectacle adapters, communications equipment and other equipment that will be
used directly in conjunction with the respirator are to be attached and operated
properly
i. At the White Mesa Mill, we only use the spectacle adapters. Spectacle
adapters are used for individuals who have prescription eyewear. The
adaptor is used so that there is not an issue with the arms of the glasses
potentially breaking the seal of the device.
ii. Each employee who has to wear prescription eyewear must present a copy
of their current prescription to the Safety Department and the devices will be
ordered.
iii. After the spectacle adapter has arrived, the Safety Department will train
each wearer on the proper care, maintenance and installation of the device.
This training is documented with a signed training certificate by both the
instructor and wearer and the document is then placed in the file in the
Radiation Office files.
d. Demonstration in donning, using and removing each type of respiratory protective
device that may be used
i. Wearing Instructions and training
1. Donning, wearing and removing the respirator
2. Adjusting the respirator so that its respiratory-inlet covering is properly
fitted on the wearer and so that the respirator causes a minimum amount
of discomfort to the wearer
3. Allowing the respirator wearer to wear the respirator in a safe
atmosphere for an adequate period of time to ensure that the wearer is
familiar with the operational characteristics of the respirator
4. Have each employee perform the donning for each device they may have
to wear while on property
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e. Instruction in how to inspect each type of respiratory device that may be used and
be instructed to perform such an inspection before donning any device
i. Field Inspection
1. Valves
2. Body of Mask
3. Straps
4. Lens
5. Air lines
ix. Respirator Sealing Problems
1. A person who has hair (stubble, mustache, sideburns, beard, low
hairline, bangs) which passes between the face and the sealing surface of
the face piece of the respirator shall not be permitted to wear such a
respirator.
2. A person who has hair (mustache, beard) which interferes with the
function of a respirator valve(s) shall not be permitted to wear such a
respirator.
3. A spectacle which has temple bars or straps which passes between the
sealing surface of a respirator full face piece and the wearer's face shall
not be used.
4. A head covering which passes between the sealing surface of a respirator
face piece and the wearer's face shall not be used.
5. The wearing of a spectacle, or goggle, a face shield, a welding helmet, or
other eye and face protective device which interferes with the seal of a
respirator to the wearer shall not be allowed.
6. If scars, hollow temples, excessively protruding check bones, deep
creases in facial skin, the absence of teeth or dentures, or unusual facial
configurations prevent a seal of a respirator face piece to a wearer's face,
the person shall not be permitted to wear the respirator.
7. If missing teeth or dentures prevent a seal of a respirator mouthpiece in a
person's mouth, the person shall not be allowed to wear a respirator
equipped with a mouthpiece.
8. If a person has a nose of a shape or size which prevents the closing of
the nose by the nose clamp of a mouthpiece/nose clamp type of
respirator, the person shall not be permitted to wear this type of
respirator.
k. Instruction in how to perform a user seal check on face sealing devices and how
to perform this user seal check each time mis type of device is donned
1. Refer to "d" of this section,
2. Demonstrate the proper techniques for performing a field positive and
negative pressure test.
3. Have each employee perform this task, (pass/fail)
4. Emphasis to each employee the importance of performing this task each and
every time the^seal has been broken.
1. Information that any respirator user may leave the work area at any time for relief
from respirator is in the event of equipment malfunction, physical or
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psychological distress, procedural or communications failure, significant
deterioration of operating conditions, or any other condition that might necessitate
such relief
1. A respirator wearer shall be permitted to leave the hazardous area for any
respirator-related cause. Reasons which may cause a respirator wearer to
leave a hazardous area include, but are not limited to, the following:
a. Failure of the respirator to provide adequate protection
b. Malfunction of the respirator
c. Detection of leakage of air contaminant into the respirator
d. Severe discomfort in wearing the respirator
e. Increase resistance to breathing
f. Illness of the wearer, including: sensation of dizziness, nausea, weakness,
fatigue, breathing difficultly, coughing, sneezing, vomiting, fever or chills.
g. Claustrophobia, anxiety, or other psychological factors that may affect the
wearer
h. Emergency respirator use
i. SCBA - Self-Contained Breathing Apparatus
ii. Emergency respirator issuance
iii. Only Certified individuals may use these devices
Be advised that in case of respirator malfunction or wearer distress, the respirator
may be removed as the respirator user exits the airborne contamination area
m. Each respirator wearer must understand that during any problem with the device
or distress, the device can be removed upon exiting the contamination area. A
report of the incident should be given the Safety Watch and the Safety
Department immediately.
5. Facility Provided Protection
a. Ventilation systems and effluent controls
i. Explain the Demister and Scrubber system
ii. Negative pressure is Yellowcake Dryer and Packaging Enclosures
b. Cleanliness of the work place
i. ALARA and the importance of the principle
ii. Prevention of the spread of materials
iii. Wash down of work areas
iv. Prompt notice and cleanup of materials if spilled
v. Wash hands regardless of job assignment
c. Features designed for radiation safety for process equipment
i. Ventilation system in the process areas
ii. Remote access for packaging operations
d. Standard operating procedures
i. Each circuit's SOP addresses the specific radiation concerns
ii. Knowledge of the SOP's and radiation concerns of one's circuit is
needed prior to commencement of any work activity
iii. Radiation Work Permit (RWP)
e. Security and access control to designated areas
i. Restricted Area requirements
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ii. Identification cards needed to access the Restricted Area
iii. Access to the Product Storage Yard
iv. Surveillance cameras around the facility
v. 24 hour coverage by a member of the Radiation Staff
f. Electronic data gathering and storage
g. Automated processes
i. Nuclear Density Gauges
h. Postings
i. "Radioactive Materials Area" - This sign designates the Restricted
Area and signifies that one may come in contact with radioactive
materials once one has pasted the signage.
ii. "Caution Radiation Area" - Beta/Gamma values at or above 5.0
mR/hr. This posting means reduction in time and increase distance
from source or added shielding is required.
iii. "Caution Airborne Radioactivity Area" - Alpha activity value at or
above 25% of the corresponding DAC value. Respirators required
prior to entering area and increased bioassays.
6. Health Protection Measurements
a. Measurements of airborne radioactive materials
i. Alpha Monitoring
ii. Area Airborne
iii. Radon Progeny
iv. Beta/Gamma
v. Breathing Zones
b. Bioassays to detect uranium (urinalysis)
i. Entrance/Exit Monitoring
ii. Schedule
1. Monthly during production periods for all employees
2. Bi-monthly for employees working in ore handling and yellowcake
packaging operations. Also for declared pregnancy workers.
iii. Action limits of uranium detection in the bioassays
1. 0 to 14 pig/L
a. Continue to review further bioassay results
2. 15 to 35 jig/L
a. Obtain additional sample
b. Identify the cause of the elevated sample
c. Examine air sampling data to determine the source of intake
d. Determine if other workers could have been exposed.
e. Consider work assignment limitations
f. Improve uranium confinement controls or respiratory
protection
3. Over 35 u,g/L
a. Take actions given above
b. Continue operations only if it is virtually certain no other
worker will exceed the concentration
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c. Establish work restrictions for affected employees
d. Weekly bioassays
iv. Investigation of potential uptake
v. Mitigation of uptake
c. Surveys to detect contamination of personnel and equipment
i. Exit Alpha Monitoring - leaving the Restricted Area
ii. Break Times - Entering into an designated eating area
iii. Spot checks
iv. Equipment releases and the limits for the facility
1. Alpha Personnel Release Rate (1,000 dpm/100 cm2)
2. Alpha values for unrestricted release
a. Removable 1,000 dpm/100 cm2
b. Average 5,000 dpm/100 cm2
c. Maximum 15,000 dpm/100 cm2
3. Beta/Gamma limits for unrestricted release
a. Average 0.20 mR/hr
b. Maximum 1.0 mR/hr
d. Personnel dosimetry
i. OSL
e. Potential Sources of Exposure at the facility
i. Conventional Ore Dust
ii. Alternate feed materials
iii. Yellowcake
iv. Tailings
v. Obsolete Equipment
f. Ways to reduce exposure
i. Time - limiting the amount of time one spends in a given work
environment. Example is only allowing a certain amount of time to be
allowed in an RWP.
ii. Distance - creating a separation between one self and the source of
exposure. Example is remote handling of material.
iii. Shielding - placing a barrier between one self and the source.
Example is a respirator.
7. Radiation Protection Regulations
a. Regulatory authority of NRC, MSHA and State of Utah
b. Employee rights in 10 CFR Part 19
c. Radiation protection requirements in 10 CFR Part 20
d. State of Utah R313 rules
e. 30 CFR Parts 47 and 56
f. Previous Radiation Exposure Information requests
8. Emergency Procedures
a. Emergency Response Plan
b. Facility notification cards
c. Decontamination procedures during an emergency
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9. Alpha Contamination Training
a. Proper use of the personnel alpha monitor
b. What to do if the alarm were to sound and who to contact
c. Documentation of the training session and acceptance of possible disciplinary
actions for failure to comply with the regulation
10. Prenatal Radiation Exposure
a. Presentation of NRC information (see Appendices I and J)
b. Discussion of increased monitoring
c. Completion of Form
11. Any Handouts
12. Radiation Protection Quiz
13. Respiratory Protection Quiz
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APPENDIX B
FORMS