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HomeMy WebLinkAboutDRC-2013-003918 - 0901a068803f6d4dDepartment of Environmental Quality Amanda Smith Executive Director State of Utah GARY R HERBERT Governor DIVISION OF RADIATION CONTROL Rusty Lundberg Director DRC-2013-003918 GREG BELL Lieutenant Governor October 8, 2013 Jo Ann S. Tischler, Director, Compliance Energy Fuels Resources (USA) Inc. 225 Union Boulevard, Suite 600 Lakewood, CO 80228 Subject: Compliance—Radioactive Material License No. UT1900479 2013 Radiation Protection Inspection, Module RADMOD-IEM-01 Dear Ms. Tischler: This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT on September 26 and September 27,2013 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 work area air monitoring and internal and external personnel monitoring were found to be in compliance with relevant requirements. The Inspection Report is enclosed. As usual, your staff at the mill was cordial, cooperative, and accommodating in facilitating the inspection. If you have any question, please contact Boyd Imai at (801) 536-4250. Sincerely, 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 (801) 536-4250 • Fax (801) 533^097 • T D D. (801) 536-4414 www deq utah gov Printed on 100% recycled paper INSPECTION REPORT Inspection Module: RADMOD-IEM-01: Internal/External Monitoring Radioactive Material License No. UT 1900479 Inspection Location: Energy Fuels Resources (USA), Blanding, UT Inspection Date(s): September 26,2013 to September 27,2013 Inspector: Boyd Imai, Utah Division of Radiation Control (DRC) Personnel Contacted: Dan Hillsten, Ronnie Nieves, David Turk Inspection Summary The inspection was opened on September 26,2013 with a meeting with R. Nieves and D. Turk of Energy Fuels. Kevin Carney from the DRC was also in attendance. Areas inspected included: • Work Area Air Monitoring • Bioassay Program • External Dosimetery The inspector held a closeout meeting on September 27,2013 with D. Hillsten, R. Nieves, and Dave Turk of Energy Fuels Resources with K. Carney of DRC to review the inspection activities, observations, and conclusions. No citable violations or deficiencies were observed during the inspection. Inspection Items Work Area A ir Monitoring At the outset, the Licensee indicated that no production work activities were being conducted at the time of the inspection; therefore no air sampling was being performed. R. Nieves conducted a tour of the facility and pointed out the locations where routine high volume air samples are drawn as specified in Table 2.1.2-1 of the Radiation Protection Manual. The monthly sampling for September 2013 had been completed and was documented in the monthly report. Breathing Zone (BZ) sampling was reviewed. BZ sampling is required whenever it is specified in the Radiation Work Permit or when air concentrations are >25% of the DAC (derived air concentration). Page 1 of3 U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013VRadmod-IEM-01\InspectionReportRevO doc Findings The worker's identification and sampling location are indicated on the calibration sheet. BZ filters are counted on detection equipment, e.g. Ludlum 2929 or 3030 and the results are entered into a Breathing Zone Sampling Field Sheet along with start and stop times and flow rates. The spread sheet compiles the data and calculates the values with respect to the applicable DAC. R. Nieves demonstrated how the BZ pumps are calibrated. The pumps are attached to a DryCal instrument that measures the flow rate of the pump. Three measurements are taken and an average is computed. The Breathing Zone Pump Calibration Form is filled out which indicates who will be wearing the sampler and the activities involved. It was later noted that the DryCal instrument was last calibrated on 3/12/12. The high volume air pumps were stored in the respirator maintenance shop where flow meters are adjusted prior to use. The pumps are calibrated annually. The Licensee provided calibration records for the four pumps inspected at the maintenance shop. All had been calibrated within the last 12 months. Filters with 0.8 micron pore diameter are utilized for BZ sampling and for the work area samples filters with 1.0 micron pore diameter are used. Bioassay Program Urine samples are collected as prescribed by Regulatory Guide 8.22. Sampling is tracked monthly on the Monthly Urinalysis Report. Blank, duplicate, and spike samples are analyzed for quality control purposes. Sample preparation area is monitored for a contamination to prevent cross contarnination of samples. Radiation Safety personnel submit urine samples every two weeks during production periods. External Dosimetry All personnel encountered during the inspection were observed wearing their Optically Stimulated Luminescence (OSL) dosimetery. This included adrninistrative, laboratory, and operations staff. All OSLs were being worn at chest level. The "badge boards" located at the locker room area and in the admimstration building were inspected. Badges not in use were clipped to the board at positions designated by employee's name. A control dosimeter was clipped to each board. Little can be done to ensure that dosimeters are "in the possession of each individual, in a locker or other secure area" as required; however, the Radiation Safety staff does inventory the badge board to ensure badges are returned to the board when not in use.. The number of total staff is relatively small so it is known whether a dosimeter is missing. An investigation is conducted by Radiation Safety to locate a missing dosimeter. Typically, in these instances the employee failed to return the dosimeter tO the badge board when departing the site and it was found with the work clothes in the locker room. This is a positive effort to confirm compliance. Page 2 of3 U.\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-IEM-01\InspectionReportRevO doc f There are currently no declared pregnant workers at the mill nor have there been any for the past several years. Closeout Meeting The inspector held a closeout meeting with D. Hillsten, R. Nieves, and D. Turk of Energy Fuels Resources (USA) on September 27,2013. Also in attendance was K. Carney of the DRC. The observations described above were summarized during the meeting. R. Nieves indicated that the BZ pumps are sent out for an annual calibration in addition to having the flow rate checked before each use. Recommendations for the Licensee • Have the DryCal instrument calibrated and ensure that breathing zone samples obtained during the period one year beyond the last calibration date (3/12/13 to present) are accurately evaluated. • Periodically verify that the Breathing Zone Sampling Field Sheet spreadsheet has not been altered or corrupted by validating the accuracy of the formulae within the spreadsheet. • Update/revise the Radiation Protection Manual, Section 3.2.3 to reflect the current method the breathing zone sampling pumps are calibrated. Recommendations for future Inspections • Verify that the DryCal iristrument used for calibrating the breathing zone sampling pumps had been calibrated. Assess the "as found" status of the instrument. If the mstrument was out of calibration in the "as found" condition assess the actions taken by the Licensee regarding the sampling performed between calibrations. This matter was discussed with the Licensee during the Closeout Meeting. • Evaluate Licensee's approach to Regulatory Guide 8.25. Air Sampling in the Workplace, Section 6.5, Annual Review of Air Sampling Measurements. Recommendation for the DRC Director Regarding the findings of this inspection, it is recommended that no enforcement action be taken at this time. Prepared By: Boyd M. Imai Q^^^^October 3,2013 (Name) ' Signature) (Date) Page 3 of3 U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UTA2013\Radmod-ffiM-01\InspectionReportRevO doc Inspection Report entt RADMOD-IEM-01 Checklist INSPECTION REPORT Inspection Module: RADMOD-IEM-01: Internal/External Monitoring Radioactive Material License No. UT 1900479 Inspection Location: Energy Fuels Resources (USA), Blanding, UT Inspection Date(s): September 26, 2013 to September 27,2013 Inspector: Boyd Imai, Utah Division of Radiation Control (DRC) Personnel Contacted: Dan Hillsten, Ronnie Nieves, David Turk Inspection Summary The inspection was opened on September 26, 2013 with a meeting with R. Nieves and D. Turk of Energy Fuels. Kevin Carney from the DRC was also in attendance. Areas inspected included: • Work Area Air Monitoring • Bioassay Program • External Dosimetery The inspector held a closeout meeting on September 27, 2013 with D. Hillsten, R. Nieves, 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 Work Area Air Monitoring At the outset, the Licensee indicated that no production work activities were being conducted at the time of the inspection; therefore no air sampling was being performed. R. Nieves conducted a tour of the facility and pointed out the locations where routine high volume air samples are drawn as specified in Table 2.1.2-1 of the Radiation Protection Manual. The monthly sampling for September 2013 had been completed and was documented in the monthly report. Breathing Zone (BZ) sampling was reviewed. BZ sampling is required whenever it is specified in the Radiation Work Permit or when air concentrations are >25% of the DAC (derived air concentration). 1 Page 1 of3 U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-lEM-01\InspectionReportRev0 doc The worker's identification and sampling location are indicated on the calibration sheet. BZ filters are counted on detection equipment, e.g. Ludlum 2929 or 3030 and the results are entered into a Breathing Zone Sampling Field Sheet along with start and stop times and flow rates. The spread sheet compiles the data and calculates the values with respect to the applicable DAC. R. Nieves demonstrated how the BZ pumps are calibrated. The pumps are attached to a DryCal instrument that measures the flow rate of the pump. Three measurements are taken and an average is computed. The Breathing Zone Pump Calibration Form is filled out which indicates who will be wearing the sampler and the activities involved. It was laternoted that the DryCal instrument was last calibrated on 3/12/12. The high volume air pumps were stored in the respirator maintenance shop where flow meters are adjusted prior to use. The pumps are calibrated annually. The Licensee provided calibration records for the four pumps inspected at the maintenance shop. All had been calibrated within the last 12 months. Filters with 0.8 micron pore diameter are utilized for BZ sampling and for the work area samples filters with 1.0 micron pore diameter are used. Bioassay Program Urine samples are collected as prescribed by Regulatory Guide 8.22. Sampling is tracked monthly on the Monthly Urinalysis Report. Blank, duplicate, and spike samples are analyzed for quality control purposes. Sample preparation area is monitored for a contamination to prevent cross contamination of samples. Radiation Safety personnel submit urine samples every two weeks during production periods. External Dosimetry All personnel encountered during the inspection were observed wearing their Optically Stimulated Luminescence (OSL) dosimetery. This included administrative, laboratory, and operations staff. All OSLs were being worn at chest level. The "badge boards" located at the locker room area and in the administration building were inspected. Badges not in use were clipped to the board at positions designated by employee's name. A control dosimeter was clipped to each board. Little can be done to ensure that dosimeters are "in the possession of each individual, in a locker or other secure area" as required; however, the Radiation Safety staff does inventory the badge board to ensure badges are returned to the board when not in use. The number of total staff is relatively small so it is known whether a dosimeter is missing. An investigation is conducted by Radiation Safety to locate a missing dosimeter. Typically, in these instances the employee failed to return the dosimeter to the badge board when departing the site and it was found with the work , clothes in the locker room. This is a positive effort to confirm compliance. Page 2 of3 U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-IEM-01\InspectionReportRevO doc There are currently no declared pregnant workers at the mill nor have there been any for the past several years. Closeout Meeting The inspector held a closeout meeting with D. Hillsten, R. Nieves, and D. Turk of Energy Fuels Resources (USA) on September 27, 2013. Also in attendance was K. Carney of the DRC. The observations described above were summarized during the meeting. R. Nieves indicated that the BZ pumps are sent out for an annual calibration in addition to having the flow rate checked before each use. Recommendations for the Licensee • Have the DryCal instrument calibrated and ensure that breathing zone samples obtained during the period one year beyond the last calibration date (3/12/13 to present) are accurately evaluated. • Periodically verify that the Breathing Zone Sampling Field Sheet spreadsheet has not been altered or corrupted by validating the accuracy of the formulae within the spreadsheet. • Update/revise the Radiation Protection Manual, Section 3.2.3 to reflect the current method the breathing zone sampling pumps are calibrated. Recommendations for future Inspections 7 • Verify that the DryCal instrument used for calibrating the breathing zone sampling pumps had been calibrated. Assess the "as found" status of the instrument. If the instrument was out of calibration in the "as found" condition assess the actions taken by the Licensee regarding the sampling performed between calibrations. This matter was discussed with the Licensee during the Closeout Meeting. • Evaluate Licensee's approach to Regulatory Guide 8.25. Air Sampling in the Workplace, Section 6.5, Annual Review of Air Sampling Measurements. Recommendation for the DRC Director Regarding the findings of this inspection, it is recommended that no enforcement action be taken at this time. Prepared By: Boyd M. Imai />H#^<^f \MJ^ October 3, 2013 (Name) C(Signature) (Date) Page 3 of3 U \MON_WAST\Bimai\vvp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-IEM-01\InspectionReportRevO doc UTAH DIVISION OF RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-IEM-01 INTERNAL/EXTERNAL MONITORING DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT1900479 Inspector(s): J&Jj^3^ Date(s): - ?A//A3 References: • Radioactive Material License UT 1900479 • License Renewal Application dated February 28, 2007 • Radiation Protection Manual, Section 5 • 10CFR20 • NRC Regulatory Guide 8.13 • NRC Regulatory Guide 8.22 • Utah Administrative Code R313-12-3 • Utah Administrative Code R313 -15. AIR SAMPLING Radiation Protection Manual, Section 1.1.2, Breathing Zone Sampling, Section 1.1.2.2, Applicability: Breathing zone samples are required: for all calciner maintenance activities, at least quarterly during routine operating and maintenance tasks on representative individuals performing these tasks, when radiation work permits are issued in which airborne concentrations may exceed 25% of 10CFR20 limits, weekly for yellow cake operations, or at the discretion of the RSO. 1) Are BZ air samples being taken: for all calciner maintenance activities? at least quarterly during routine operating and maintenance tasks on representative individuals performing these tasks? when radiation work permits are issued in which airborne concentrations may exceed 25% of 10CFR20 limits? weekly for yellowcake operation?, at the discretion ofthe RSO? Yes IS NoQ YesH NoD YesCS NoQ Yesgl NoD Yes[S NoD Comments: Page 1 of 11 2) Section 1.1.2.3 is the procedure for BZ sampling. Is this procedure being followed? YesD NoD Comments: r5?- sa>*^£*wo^ JL«v»a- AJU^C>«^ i^^Lgc^"t»w 3) Section 1.1.2.6 lists the Data Records that are to be kept. Are they being kept? YesD NoQ Comments: J, M^. — ru^-l,t^^ 1 t^tftldw^L* ^*&H^_ XC>4 - t)>k / Settle. 4 - fSf-c^U^ 5**>-ft^~^ f y«^J. 5»*up/<. £<VCLW\ - ^ j ^ ' 4) Section 1.1.2.7 shows the calculations to be used. Are these calculations being used? Yes]Z] NoD Are they being used correctly? Yes [3 NoD Comments: ^ syr*-»* sv*«j^ Radiation Protection Manual, Section 1.1.2.4, Calibration 3.2 PERSONNEL AIR SAMPLERS The calibration procedure for personnel air samplers involves primary and secondary calibration procedures Samplers will be calibrated prior to each use by either of two methodologies bubble tube or mass flow determinations Air samplers may be calibrated to standard air conditions. 3.2.1 Bubble Tube Calibration Method — U^h^ 3.2.3 Electronic Calibration Method 5) Are calibrations for BZ air samplers being performed and documented prior to each use? YesNoD Comments: Page 2 of 11 6) For BZ air samples being taken, are calibrations for BZ air samplers being performed and documented in accordance with Section 3.2.1 or 3.2.3 of the Radiation Protection Manual? YesQ NoQ Comments: /Waf |*A.~fo 7) Observe a BZ being calibrated. Which procedure was used and was it done correctly? Procedure: 3. ^. 3 Yes • NoD Comments: ?<scxu>^ £ ^W-/" ordo ^XMS* 4U u^fe«.u.a 1 ^ j-^fle^ 5 v>*° 8) Is the RSO reviewing results that exceed 2j0% of 10FR20 limits? (Section 1.1.2.8) Yesjg] NoD Comments: Radiation Protection Manual, Section 1.1.3.1, Frequency and Locations The following principles usedfor the collection of area grab samples must be considered when collecting a sample in order to obtain a representative concentration that workers may be exposed to during their assigned work tasks. 1. The locations selected for sampling should be representative of exposures to employees working in the area. 2. For special air sampling, the sampling period should represent the conditions during the entire period of exposure. This may involve sampling during the entire exposure period. 3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow rate of 40 liters per minute for at least 60 minutes. 4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector. 5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or non-routine situations. Page 3 of 11 9) Are area grab samples obtained in areas representative of workers exposure? (During the Mill tour Have the HP Staff show where the air samples are being taken.) YesJS NoQ Comments: *R-> Mlg-0*S j*rJl*JC^4*-^ t^fc-wn^ cM^w^ 10) For routine sampling, did the licensee sample at a minimum flow rate of 40 liters per minute for at least 60 minutes? Yes [ST No • Comments: 11) Were air sample filters analyzed for gross alpha using a sensitive alpha detector? * Yes(S NoD Comments: 2-?Z-7 -C^5<a^^ t z Table 1.1.1-1 for areas where the ALI <.01 and the DAC is <0.01 it state, "Air sampling is generally not necessary. However monthly or quarterly grab samples or some other measurement may be appropriate to confirm that airborne levels are indeed low. " 12) Are periodical grab samples taken on a Monthly or Quarterly frequency to confirm that airborne radioactivity remain below ALI <.01 and the DAC is <0.01 values? YesgJ NoD Comments: , ' Page 4 of 11 RML License Condition 11.4 Annually, the licensee shall collect, during mill operations, a set of air samples covering eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per minute), in routinely or frequently occupied areas of the mill. These samples shall be analyzed for gross alpha. In addition, with each change in mill feed material or at least annually, the licensee shall analyze the mill feed or production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the fundamental constituent composition of air sample particulates. 13) Did the licensee perform high volume alpha air sampling in routinely or frequently occupied areas of the mill in accordance with L.C. 11.4? Yesg| NoD Comments: P^^K^-A fl*^ Z*)3 " fXx»v<fcjLt cXjreq AtrWhj QA(Q0_ 14) Did the air samples cover eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per minute)? YesH NoD Comments: 4gC> Kcu^. °fc> j_ 15) With each change in mill feed material or at least annually, did the licensee analyze the mill feed or production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the fundamental constituent composition of air sample particulates? Yes^Sl NoD Comments: pyw^M^fr ,00 <jL^2J2vAr~cW<je- ^/uucO^t* <u^^tSe^NLi gteKayJ? Page 5 of 11 Radiation Protection Manual, Section 1.1.3.2 Sampling Equipment Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for one hour or longer. Equipment utilized will be an Eberline RAS-1, or a Scientific Industries Model H25004, or equivalent. Filter media will have a maximum of 0.8 micron pore diameter. Equipment is calibrated prior to each usage as per Section 6, [3] (typo), of this manual. 16) Are calibrations for area air samplers being performed and documented prior to usage? YesQ NoQ Comments: 17) Is the licensee using air sample filters that have a maximum c^QrS'micron pore diameter? YesQ NoD Comments: /MAS; 18) Are calibrations for area samplers being performed and documented in accordance with Section 3.3 of this Manual? YesQ NoD Comments: A-b^u^r J^ij^jr- y^jjjfcsuy' - r a.li^^fc^j) *3***Ui»Q-&*/f 19) Has the licensee provided proper documentation of the results of calibration for the following air sampling equipment? Air Sampler ^S/N /Q?</5 g/W* Yes g] NoD Air Sampler ^S/N Ttt S r/'f//3 Yes H No • Air Sampler ^ S/N ^ * rt-({£Jd ?//r/Yes § NoD Air Sampler • S/N 11 0H\ tftrfq Yes H No • Comments: Page 6 of 11 20) Section 2.1.2 Frequency/Locations Has the Licensee performed monthly uranium dust monitoring in the following areas? (Table 2.1.2-1) Airborne Radiation Sample Locations S^V* 2^o> BA1 Ore Scalehouse Yes E No D BA17 Change Room Yes E No • BA2 Ore Storage Yes g] No • BA18 Administrative Building Yes a Nop BA7 SAG Mill Area Yes E No • BA19 Warehouse Yes 3 NoD BA8 Leach Tank Area / Yes B No D BA20 Maintenance Shop • Yes [El NoD BA9 Wash Circ CCD Thickness / Yes E No D BA21 Boiler Yes E No D BA10 Sol Ex Bldg/Stripping tf&s' Yes S No D BA22 Vanadium Panel Y Yes Sol Ex Bldg/Stripping Ro'orm/ Yes B No D Vanadium Dryer ^< Kj NoD BA11 BA22A Yes a Nop BA12 YC Precip/W Storage Area / Yes M No D BA23 Filter Belt/Rotary Dryer Yes ENOD BA12A No. YC Dryer Enclosure • Yes E No D BA24 Tails Yes HNOD BA12B So. YC Dryer Enclosure f' Yes [X] No D BA25 Central Control Room ^ Yes HNOD BA13 YC Drying/Packaging Arear"^ Yes E No D BA26 Shifter's Office Yes E No D BA13A YC, Packaging Enclosure s' Yes E No D BA27 Operator's Lunch Room Yes S] NoD BAH Packaged YC Storage Roomvx Yes E No D BA28 Dump Station Yes K|NoD BA15 Met Lab Sample Room Yes gl NoD BA29 Fitter Press Yesjcl No r~| BA16 Lunch Room Area Yes E No D BA30 Truck Shop Yes g| No D Comments: t> AZ^- e^Jr — ft & ^ S- 3» 3^ Yes 'yes 1X9 A torf AU^Ufia<f ^ U retention class Y: 2E-lluCi/ml Footnote 3 (for 10CFR20 Table 1 of Appendix B DAC values for Z3*U): If a mixture of radionuclides consists of uranium and its daughters in ore dust (10 tim AMAD particle distribution assumed) prior to chemical separation of the uranium from the ore, the following values may be used for the DAC of the mixture: 6E-lljuCi of gross alpha activity from uranium-238, uranium-234, thorium- 230, and radium-226 per milliliter of air; 3E-lljuCi of natural uranium per milliliter of air. or 45 micrograms of natural uranium per cubic meter of air. 21) Where any of the air sample results from the above areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of Appendix B? YesD Nog Areas Identified S*f^W * Area DAC Value Area DAC Value Area DAC Value Comments: Page 7 of 11 Utah Rules R313-12-3. Definitions "Airborne radioactivity area" means: a room, enclosure, or area in which airborne radioactive material exists in concentrations: (a) In excess ofthe derived air concentrations (DACs), specified in Rule R313-I5, or (b) To such a degree that an individual present in the area without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on intake (ALI), or 12 DAC hours. ^ Utah Rules R313-15-902. Posting Requirements (4) Posting of Airborne Radioactivity Areas. The licensee or registrant shall post each airborne radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words "CA UTION, AIRBORNE RADIOACTIVITY AREA" or "DANGER, AIRBORNE RADIOACTIVITY AREA." IK 22) If yes to yf, were the areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of Appendix B properly posted? BIO ASSAY PROGRAM Radiation Protection Manual, Section 1.4:1 Frequency Urinalysis will be performed on those employees that are a) exposed to airborne yellowcake or involved in maintenance tasks during which yellowcake dust may be produced, or b) routinely exposed to airborne uranium ore dust. Baseline urinalysis will be performed prior to initial work assignments Urine samples are collected on a routine basis from mill employees as required in Regulatory Guide 8.22. Urine samples will be collected from employees who have worked in yellowcake packaging, yellowcake precipitation, grind area (SAG Mill), ore feed, sample plant, scale house, and the sample preparation room every two weeks during production periods. Samples will be collected from all other employees monthly during production periods. During non-production periods, bi-weekly samples will be collected if individual exposures are expected to exceed 25% of the DAC value otherwise samples will be collected from all employees quarterly. Non-routine urinalysis will usually be performed on employees who have been working on assignments that require a Radiation Work Permit, and always on any individual that may have been exposed to airborne uranium or ore dust concentrations that exceed 25% of the DAC level. 23) Are urine samples being collected from workers who are working under an RWP? ^re- < {NAT *fl^o^ Yes Comments: Page 8 of 11 24) Are bi-weekly urine samples being collected from workers in the following areas during production? ^Yellowcake Packaging Yes No O </Yeliowcake Precipitation Yes 0 NoQ Grind Area (SAG Mill)\_ ' Yes • No • tf* \ s^^\ Ore Feed- ^ , Yes • No • fit* Sample Plant ^ — ?=^K w Yes-H-Ne-B" N A /Scale House Yes Q NoD Sample Prep Room ^ W*,U>"--\ r^^^ Yes 0 No Q Comments: 25) During production periods, are monthly urine samples being collected from all employees working in areas other than those listed above? Yes0 NoD Comments: 26) Are urine samples being collected from Radiation Safety Personnel every two weeks during production periods? (Radiation Safety Personnel routinely work in areas listed in #21 above). Comments: "T^VAS ^(^WtU - >r^ - 3 < Sy/ U Section 1.4.3 Sample Preparation Sample preparation will be done in an area decontaminated to less than 25 dpm alpha (removable) per 100 cm2 prior to preparation of samples. All of the equipment that is used in sample preparation will be clean and maintained in such condition. **/' f /' *- 27) Are the sample preparation area contamination levels maintained below 25dpm/100cm2 a (removable)? Yes [gf NoD Comments: \jOr\^^ 5^n^ ^y^-S Page 9 of 11 EXTERNAL MONITORING 28) Section 1.3 Beta-Gamma Surveys Were all observed personnel wearing a personal monitoring badge while in the Restricted Area? Yesjg] NoD Comments: Z-^Wr 2- 4°^^ ^rf^ p^ftA^Avinf \ Section 1.3.1 Monitoring Procedures 77ze monitoring procedures consist of: 1. Personnel issued personal monitoring devices will wear the device on the trunk (torso) of the body or visibly on the exterior of their hard hat. The personal monitoring device records beta/gamma radiation as well as other forms ofpenetrating radiation such as x-rays. A personal monitoring device is an exposure record of an individual's personal exposure to radiation while on the job. Therefore, personal monitoring devices are to remain at the Mill in the personal possession of each individual, in a locker or other secure area. All exposure records obtained by a personal monitoring device which are not consistent with the exposure rates of work tasks or work location measurements made throughout the Mill will be evaluated by the RSO. This evaluation will result in an investigation by the RSO and a written explanation of the findings. These written records will be maintained at the Mill. 2. Personal monitoring devices will be issued at a minimum quarterly and will be exchanged by the Radiation Safety Department. Missing or lost badges will be reported to management. 3. Female employees that become pregnant and continue to work during the course of their pregnancy will be placed on a monthly personal monitoring device exchange during this period. NRC Regulatory Guide 8.13 provides guidelines to be followed during pregnancy and is made part of this procedure. 29) Under routine conditions, were observed employees wearing monitoring badges properly on the torso? Yes^l NoD Comments: ^) ^b^ylj Page 10 of 1! 30) Has the licensee assured that personal monitoring devices are being kept at the Mill in the possession of the individual, in a locker or in another secure area? Yesjgl NoD Comments: 31) Check the dosimeter boards in the locker rooms^vmaintcnancc building and administration building. Are the badges properly stored? YesB NoD Comments: &vlv^ Ji&s^^J^cs ^res^J 32) Have any female workers declared their pregnancy in the past 2 years? YesD Noja Comments: 33) If yes to 31 above, has the declared pregnant worker been placed on a monthly personal monitoring device exchange during this period? Yes • No • N/A g Comments: Follow-up 34) AltematelbedLfJheck to see where all of the alternate feed material is b$ pad area then wherelsTt-andhow is it being stored? Eofed If it is not in the ore Comments: Supporting Documentation BREATHING ZONE PUMP CAUBRAT10N FORM DATE -Hit CALIBRATE AT 4 LITERS PER MINUTE READING lA^61 READING 2. Mt>W5 READING 3.JDVM_ AVERAGE MO^M TEMPERATURE PURPOSE OF BREATHING ZONE "fo CfrltWftT^^/$fA**^^l^ RAQIATIQN/SAFETY TECHNICIAN RoA^-a . NAME OF EMPLOYEE WEARING SAMPLE r\g<Ak. LA\-W COMMENTS Ac AattfialEiaSBoaSnulBU Wee*, lit877-477-0711 • Billings, MT BQ0-739-44B9 • Casper, WY 888-235-1515 KBrthtWf KM88-71T5* Rapid CH&SDMB-B7M225 • College Station, TX88M8M211 LABORATORY ANALYTICAL REPORT Prepared by Casper, WY Branch Client: Denison Mines USA Corp Project: AF Composite Lab ID: C12030336-001 Client Sample ID: KF Material Report Date: 04/16/12 Collection Date: 03/06/1213:30 DateReceived: 03/08/12 Matrix: Solid Analyses Result Units Qualifier RL MCU QCL Method Analysis Date / By METALS-TOTAL •'Uranium 7010 mg/kg-dry 1.0 SW6020 03/13/12 15:29/smm RADIONUCLIDES Lead 210 Lead 210 precision (±) Lead 210 MDC t/Radium 226 Radium 226 precision (±) Radium 226 MDC •Thorium 230 Thorium 230 precision (±) Thorium 230 MDC Thorium 232 Thorium 232 precision (±) Thorium 232 MDC 0.6 0.1 0.2 0.6 0.05 0 02 53 29 3.0 0.9 1.6 2.8 pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry pCi/g-dry E909.0 E909.0 E909.0 E903.0 E903.0 E903.0 E908.0 E908.0 E908.0 E908.0 E908.0 E908 0 03/26/12 03/26/12 03/26/12 03/27/12 03/27/12 03/27/12 03/22/12 03/22/12 03/22/12 03/22/12 03/22/12 03/22/12 02:24 / eh-cs 02.24 / eli-cs 02:24/eh-cs 01:34/lbb 01:34 / Ibb 01 -34 / Ibb 08:41 /dmf 08:41 / dmf 08:41 / dmf 08:41 / dmf 08:41 / dmf 08.41 / dmf Report Definitions: RL - Analyte reporting limit. QCL - Quality control limit. MDC - Minimum detectable concentration MCL - Maximum contaminant level. ND - Not detected at the reporting limit. U - Not detected at minimum detectable concentration Page 3 of 9 Sample # 2233 2234 2235 2236 2237 2238 2239 2240 2241 2242 2243 2244 2245 2246 2247 2248 2249 2250 2251 2252 2253 2254 2255 2256 2257 2258 2259 2260 2261 2262 Employee Name Chad Haycock Wade Hancock Cortney Montella Thayne Holt Jeremy Jones Chad Perkins Albert Bylilly Kenneth Jones Nick Whitehorse Christine Jones Spike Blank Duplicate of 2233 Abel Jr. Wayne Palmer David Lyman Spike Travis Plott Darin Laws Milton Pipkin Tyrone Little Chad Little Noah Imel Arden Nielson Milfred Maryboy Mathew Benally Ken Brown Spike Blank Duplicate of 2258 Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Spike Blank DUP Monthly Monthly Monthly Spike Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Spike Blank DUP 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/3/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/4/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 9/5/2013 11 <5 <5 <5 <5 <5 <5 <5 <5 <5 10 <5 11 <5 <5 <5 21 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 30 <5 <5 10 20 30 100% 105% 100% Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2263 Clarence Yellow Monthly 9/3/2013 9/5/2013 <5 2264 Shawn Begaye Monthly 9/3/2013 9/5/2013 <5 2265 Tremayne Cowboy Monthly 9/3/2013 9/5/2013 <5 2266 David Beaver Monthly 9/3/2013 9/5/2013 <5 2267 Ramone Hatalie Monthly 9/3/2013 9/5/2013 <5 2268 David Lacy Monthly 9/3/2013 9/5/2013 <5 2269 Scot Christensen Monthly 9/3/2013 9/5/2013 <5 2270 Karson Lacy Monthly 9/3/2013 9/5/2013 <5 2271 Dustin Reed Monthly 9/3/2013 9/5/2013 <5 2272 Sterling Jones Monthly 9/3/2013 9/5/2013 <5 2273 Spike Spike 9/3/2013 9/5/2013 10 10 100% 2274 Blank Blank 9/3/2013 9/5/2013 <5 2275 Duplicate of 2271 DUP 9/3/2013 9/5/2013 <5 2276 Marvin Charley Monthly 9/3/2013 9/5/2013 <5 2277 Ryan Young Monthly 9/3/2013 9/5/2013 <5 2278 Stephone Benally Monthly 9/3/2013 9/5/2013 <5 2279 Ted Black Monthly 9/3/2013 9/5/2013 10 2280 Henry Neal Monthly 9/3/2013 9/5/2013 <5 2281 Terry Slade Monthly 9/3/2013 9/5/2013 <5 2282 Jerome Benally Monthly 9/3/2013 9/5/2013 <5 2283 Deanna Walker Monthly 9/3/2013 9/5/2013 <5 2284 Ronnie Nieves Monthly 9/3/2013 9/5/2013 <5 2285 Roy Atcitty Monthly 9/3/2013 9/5/2013 <5 2286 Spike Spike 9/3/2013 9/5/2013 18 20 90% 2287 Blank Blank 9/3/2013 9/5/2013 <5 2288 Duplicate of 2276 DUP 9/3/2013 9/5/2013 <5 2289 Bobby Deny Monthly 9/3/2013 9/5/2013 <5 2290 2291 2292 Herbert Stanley David Turk Casey Singer Monthly Monthly Monthly 9/3/2013 9/3/2013 9/3/2013 9/5/2013 9/5/2013 9/5/2013 <5 <5 <5 Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2293 Heath Latham Monthly 9/3/2013 9/5/2013 <5 2294 David Carr Monthly 9/3/2013 9/5/2013 <5 2295 Hersheal Bennett Monthly 9/3/2013 9/5/2013 <5 2296 Reeves Sandoval Monthly 9/3/2013 9/5/2013 <5 2297 Spike Spike 9/3/2013 9/5/2013 28 30 93% 2298 Blank Blank 9/3/2013 9/5/2013 <5 2299 Duplicate of 2289 DUP 9/3/2013 9/5/2013 <5 2300 Blake Burtenshaw Monthly 9/3/2013 9/6/2013 <5 2301 Philbert Simpson Monthly 9/3/2013 9/6/2013 <5 2302 Wilson Zohonnie Monthly 9/3/2013 9/6/2013 <5 2303 Frank Warren Monthly 9/3/2013 9/6/2013 <5 2304 Clifford Kaye Monthly 9/3/2013 9/6/2013 <5 2305 Nathan Frisbie Monthly 9/3/2013 9/6/2013 <5 2306 Verdale Boy Monthly 9/3/2013 9/6/2013 <5 2307 Truitt Oshely Monthly 9/3/2013 9/6/2013 <5 2308 Roy Romero Monthly 9/3/2013 9/6/2013 <5 2309 Sheridan Jones Monthly 9/3/2013 9/6/2013 <5 2310 Spike Spike 9/3/2013 9/6/2013 10 80% 2311 Blank Blank 9/3/2013 9/6/2013 <5 2312 Duplicate of 2301 DUP 9/3/2013 9/6/2013 <5 2313 Derick Palmer Monthly 9/3/2013 9/6/2013 <5 2314 Tayton Arthur Monthly 9/3/2013 9/6/2013 <5 2315 Tranner Sharpe Monthly 9/3/2013 9/6/2013 <5 2316 Chad Haycock Monthly 9/3/2013 9/6/2013 <5 2317 Collin Warner Monthly 9/3/2013 9/6/2013 <5 2318 Justin Perkins Monthly 9/3/2013 9/6/2013 <5 2319 Chuck Dayish Monthly 9/3/2013 9/6/2013 <5 2320 Tully Lameman Monthly 9/3/2013 9/6/2013 <5 2321 Theo Holiday Monthly 9/3/2013 9/6/2013 <5 2322 Johnson Benally Monthly 9/3/2013 9/6/2013 <5 Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2323 Spike Spike 9/3/2013 9/6/2013 18 20 90% 2324 Blank Blank 9/3/2013 9/6/2013 <5 2325 Duplicate of 2319 DUP 9/3/2013 9/6/2013 <5 2326 Garrin Palmer Monthly 9/3/2013 9/6/2013 <5 2327 Stan Jones Monthly 9/3/2013 9/6/2013 <5 2328 Tanner Holiday Monthly 9/3/2013 9/6/2013 <5 2329 Deswood West Monthly 9/3/2013 9/6/2013 <5 2330 Steven Helquist Monthly 9/3/2013 9/6/2013 <5 2331 Steve Snyder Monthly 9/3/2013 9/6/2013 <5 2332 Kyle Holiday Monthly 9/3/2013 9/6/2013 <5 2333 Jaymes Benally Monthly 9/3/2013 9/6/2013 <5 2334 Josh Taylor Monthly 9/3/2013 9/6/2013 <5 2335 Travis Oneil Monthly 9/3/2013 9/6/2013 <5 2336 Spike Spike 9/3/2013 9/6/2013 28 30 93% 2337 Blank Blank 9/3/2013 9/6/2013 <5 2338 Duplicate of 2332 DUP 9/3/2013 9/6/2013 <5 2339 Tad Kreth Monthly 9/3/2013 9/6/2013 11 2340 Terry John Monthly 9/3/2013 9/6/2013 <5 2341 Ben dinger Monthly 9/3/2013 9/6/2013 <5 2342 Ty Bitsinnie Monthly 9/3/2013 9/6/2013 <5 2343 Shawn Keith Monthly 9/3/2013 9/6/2013 <5 2344 Gerald Joe Monthly 9/3/2013 9/6/2013 <5 2345 Billy Mendoza Monthly 9/3/2013 9/6/2013 <5 2346 Spike Spike 9/3/2013 9/6/2013 10 90% 2347 Blank Blank 9/3/2013 9/6/2013 <5 2348 Duplicate of 2342 DUP 9/3/2013 9/6/2013 <5 2349 Tyler Bunting Monthly 9/3/2013 9/6/2013 <5 2350 2351 2352 Logan Shumway Leron Atcitty Lyman Cosby Monthly Monthly Monthly 9/3/2013 9/3/2013 9/3/2013 9/6/2013 9/6/2013 9/6/2013 <5 <5 <5 Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2353 Tyrone Blackhorse Monthly 9/3/2013 9/6/2013 <5 2354 Michelle Graf Monthly 9/3/2013 9/6/2013 <5 2355 Launa Armstrong Monthly 9/3/2013 9/6/2013 <5 2356 Abel Mendoza Sr. Monthly 9/3/2013 9/6/2013 <5 2357 Spike Spike 9/3/2013 9/6/2013 16 20 80% 2358 Blank Blank 9/3/2013 9/6/2013 <5 2359 Duplicate of 2352 DUP 9/3/2013 9/6/2013 <5 2360 Tenaya Begaye Monthly 9/3/2013 9/9/2013 <5 2361 Zack Lameman Monthly 9/3/2013 9/9/2013 <5 2362 Salvador Cerros Monthly 9/3/2013 9/9/2013 <5 2363 Rachele Burtenshaw Monthly 9/3/2013 9/9/2013 <5 2364 Michael James Monthly 9/3/2013 9/9/2013 <5 2365 Jamie Laws Monthly 9/3/2013 9/9/2013 <5 2366 Kevin Nez Monthly 9/3/2013 9/9/2013 <5 2367 Paul Kemner Monthly 9/3/2013 9/9/2013 <5 2368 Randy Hatalie Monthly 9/3/2013 9/9/2013 <5 2369 Wesley Simpson Monthly 9/3/2013 9/9/2013 <5 2370 Spike Spike 9/3/2013 9/9/2013 29 30 96% 2371 Blank Blank 9/3/2013 9/9/2013 <5 2372 Duplicate of 2366 DUP 9/3/2013 9/9/2013 <5 2373 Dan Hillsten Monthly 9/3/2013 9/9/2013 <5 2374 Kenneth Roberts Monthly 9/3/2013 9/9/2013 <5 2375 Amanda Bailey Monthly 9/3/2013 9/9/2013 <5 2376 Jeremy D Jones Monthly 9/3/2013 9/9/2013 <5 2377 Spike Spike 9/3/2013 9/9/2013 19 20 95% 2378 Phillip Rentz Monthly 9/3/2013 9/10/2013 <5 2379 Pernell Tsosie Monthly 9/3/2013 9/10/2013 <5 2380 Aaron Taylor Monthly 9/3/2013 9/10/2013 <5 2381 2382 Matt Atwood Spike Monthly Spike 9/3/2013 9/3/2013 9/10/2013 9/10/2013 <5 10 90% Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2383 Jolly Bayles Monthly 9/3/2013 9/10/2013 <5 2384 Thomas Morris Monthly 9/3/2013 9/10/2013 <5 2385 Spike Spike 9/3/2013 9/10/2013 30 30 100% 2386 2387 2388 Tisdale Oshley Roydale Paul Spike Monthly Monthly Spike 9/3/2013 9/3/2013 9/3/2013 9/11/2013 9/11/2013 9/11/2013 <5 <5 22 20 110% Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2389 Ted Black EXIT 9/16/2013 9/18/2013 <5 2390 Jolly Bayles EXIT 9/16/2013 9/18/2013 <5 2391 Philbert Simpson EXIT 9/16/2013 9/18/2013 <5 2392 Timothy Morris EXIT 9/16/2013 9/18/2013 <5 2393 Pernell Tsosie EXIT 9/16/2013 9/18/2013 <5 2394 Tranner Sharpe EXIT 9/16/2013 9/18/2013 16 2395 Chad Haycock EXIT 9/16/2013 9/18/2013 <5 2396 Kyle Holiday EXIT 9/16/2013 9/18/2013 <5 2397 Tisdale Osheley EXIT 9/16/2013 9/18/2013 <5 2398 Wesley Simpson EXIT 9/16/2013 9/18/2013 <5 2399 Spike Spike 9/16/2013 9/18/2013 10 80% 2400 Blank Blank 9/16/2013 9/18/2013 <5 2401 Duplicate of 2394 DUP 9/16/2013 9/18/2013 15 2402 Paul Kemner Bi-Monthly 9/16/2013 9/18/2013 <5 2403 Clifford Kaye Bi-Monthly 9/16/2013 9/18/2013 <5 2404 Kenneth Roberts EXIT 9/16/2013 9/18/2013 <5 2405 Salvador Cerros EXIT 9/16/2013 9/18/2013 <5 2406 Ty Bitsinnie EXIT 9/16/2013 9/18/2013 <5 2407 Tayton Arthur EXIT 9/16/2013 9/18/2013 <5 2408 Roydale Paul EXIT 9/16/2013 9/18/2013 <5 2409 Derick Palmer EXIT 9/16/2013 9/18/2013 <5 2410 Gerald Joe Bi-Monthly 9/16/2013 9/18/2013 <5 2411 Arden Nielson Bi-Monthly 9/16/2013 9/18/2013 <5 2412 Spike Spike 9/16/2013 9/18/2013 17 20 85% 2413 Blank Blank 9/16/2013 9/18/2013 <5 2414 Duplicate of 2407 DUP 9/16/2013 9/18/2013 <5 2415 Nathan Frisbie Bi-Monthly 9/16/2013 9/18/2013 <5 2416 Chad Little EXIT 9/16/2013 9/20/2013 <5 2417 2418 Milton Pipkin Roy Romero EXIT EXIT 9/16/2013 9/16/2013 9/20/2013 9/20/2013 <5 <5 Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2419 Tremayne Cowboy EXIT 9/16/2013 9/20/2013 <5 2420 Mathew Benally EXIT 9/16/2013 9/20/2013 <5 2421 Zack Lameman EXIT 9/16/2013 9/20/2013 <5 2422 Kenneth Roberts EXIT 9/16/2013 9/20/2013 <5 2423 Theo Holiday EXIT 9/16/2013 9/20/2013 <5 2424 Sheridan Jones EXIT 9/16/2013 9/20/2013 <5 2425 Reeves Sandoval EXIT 9/16/2013 9/20/2013 <5 2426 Spike Spike 9/16/2013 9/20/2013 27 30 90% 2427 Blank Blank 9/16/2013 9/20/2013 <5 2428 Duplicate of 2421 DUP 9/16/2013 9/20/2013 <5 2429 Albert By I illy EXIT 9/16/2013 9/20/2013 <5 2430 Ramone Hatalie EXIT 9/16/2013 9/20/2013 <5 2431 Sterling Jones EXIT 9/16/2013 9/20/2013 <5 2432 Herbert Stanley EXIT 9/16/2013 9/20/2013 <5 2433 Ty Bitsinnie EXIT 9/16/2013 9/20/2013 <5 2434 Cortney Montella Bi-Monthly 9/16/2013 9/20/2013 <5 2435 Jeremy D Jones EXIT 9/16/2013 9/20/2013 <5 2436 Shawn Keith EXIT 9/16/2013 9/20/2013 <5 2437 Tommy Morris EXIT 9/16/2013 9/20/2013 <5 2438 Deswood West EXIT 9/16/2013 9/20/2013 <5 2439 Spike Spike 9/16/2013 9/20/2013 10 10 100% 2440 Blank Blank 9/16/2013 9/20/2013 <5 2441 Duplicate of 2435 DUP 9/16/2013 9/20/2013 <5 2442 2443 2444 2445 2446 2447 2448 Stephone Benally Kyle Holiday Spike David Lacy Casey Singer Chuck Dayish Kevin Nez EXIT EXIT Spike Bi-Monthly Bi-Monthly Bi-Monthly Bi-Monthly 9/16/2013 9/16/2013 9/16/2013 9/16/2013 9/16/2013 9/16/2013 9/16/2013 9/20/2013 9/20/2013 9/20/2013 9/23/2013 9/23/2013 9/23/2013 9/23/2013 <5 <5 18 <5 <5 <5 <5 20 90% Sample # Employee Name Location MONTHLY URINALYSIS REPORT MONTH: September 2013 Date To Lab From Lab Spike Comments 2449 Milfred Mayrboy Bi-monthly 9/16/2013 9/23/2013 <5 2450 Bobby Deny Bi-monthly 9/16/2013 9/23/2013 <5 2451 Travis O'neil Bi-monthly 9/16/2013 9/23/2013 <5 2452 Spike Spike 9/16/2013 9/23/2013 32 30 106% 2453 Blank Blank 9/16/2013 9/23/2013 <5 2454 Duplicate of 2450 DUP 9/16/2013 9/23/2013 <5