DRC-2003-001161 - 0901a06880adec68

Michael 0. Leavitt
Governor
Dianne R. Nielson, Ph.D.
Executive Director
William J. Sinclair
Dilector
lltnh)
Where ideas connect
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
P.O. Box 1,14850
Salt Lake City, Utah 84114-4850
[phone]
(801) 533-,097 Fax
(801) 536-,1414 T.D.D.
www.deq.utah.gov
MEMORANDUM
Re:
From: Brian Hamos g\ tf
To: Bill Sinclairff
July 3, 2003
NRC Inspection of IUC Millsite Located at Rlanding, Utah
Introduction
The purpose of this memorandum is to document my observations during the annual inspection
conducted by the Nuclear Regulatory Commission (NRC) at the International Uranium
Corporation (IUC) Blanding, Utah millsite on June 24, 25, and 26, 2003. In anticipation of the
State of Utah receiving agreement state status over uranium mills from the NRC later this year, I
was in attendance as training for conducting uranium mill inspections.
The lead inspector from the NRC was Louis Carson. In addition, NRC chemical process
engineers Nick Baker and Diana Diaz-Toro were present on June 24 to inspect chemical safety
procedures at the facility. NRC staff Bill Von Till and Ron Linton were also part of the
inspection team to review groundwater issues at the site. Terry Brock, a recent hire of the NRC
Office of State and Tribal Programs, was present during the inspection primarily to observe as
part of his internal training.
Chemical Safety
The primary focus of the NRC inspection was on chemical safety. NRC personnel indicated that
within the past few years, the NRC has determined that at uranium millsites, the health and
safety risks are typically greater from the chemicals used in the processing of the feed material
than from the radioactive material itself. IUC personnel were surprised that chemical safety was
the focus of the inspection, and questioned if Occupational Safety and Health Administration
(OSHA) or Mine Safety and Health Administration (MSHA) might not have the jurisdiction over
chemical issues. NRC response was that as long as the chemicals are used in the processing of
uranium, NRC also has authority. NRC personnel also indicated this was the first such
t
t
July 3, 2003
inspection conducted at a millsite, so there still may need to be some procedures that would
require clarification internally before they could offer more guidance to the Licensee regarding
NRC chemical inspections.
Alternate Feed Material Processing
The most recent mill run conducted by IUC was completed at the end of May 2003. The mill
was processing alternate feed material from June 2002 through May 2003. All of the bulk feed
material has been processed. None of the feed material from drums was processed, and is still
being stored onsite in 55-gallon drums. The site is receiving between 7 to 15 trucks per day of
bulk alternate feed material from Linde, and is again stockpiling the material on the ore pad
pending another mill run at a future, undetermined time. The recently completed mill run
processed approximately 266,000 tons of feed material. The end result is approximately 5500
pounds of uranium currently in the thickener stage of mill processing. The next step would be
drying the material to produce yellowcake. This final stage of the mill process was not
completed because there is not yet enough material to efficiently operate that stage of the plant.
Background Radiation Levels
Louis Carson noted that he has been inspecting the mill site since 1994. He observed the highest
ambient background radiologic readings that he has ever seen at the site. He did not expect this,
given that the bulk alternate feed material was gone. Speculation was that the alternate feed
material had been shielding doses from the ore pad, but that was inconclusive.
Corporate Radiation Safety Officer
NRC observed that Dave Frydenlund is now the corporate radiation safety officer since Michelle
Reymund is no longer with the company. NRC was concerned that Dave (an attorney) does not
have a scientific background and has not had any type of appropriate training such as a 40-hour
radiation safety course. Dave committed to getting such training.
Document Control Procedures
One potential violation observed by NRC was a lack of document control procedures. There
were a few instances where IUC was still using standard operating procedures (SOPs) written by
UMETCO, the previous millsite owner/operator. The inspection was not formally closed during
the onsite inspection, so this may or may not be cited in the final inspection closeout.
UNITED STATES
NUCLEAR REGULATORY COTiTIISSlON
REGIOil lV
6II RYAN PLAZA DRIVE, SUITE 4OO
ARLINGTOI, TEXAS 7601 l.|(n5+**tx
March 10, 2004
David C. Frydenland, Vice-President and
GeneralCounsel
lnternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRCINSPECTIONREPORT040-08681/04-001
Dear Mr. Frydenland:
On February 19, 2004, the NRC completed an inspection at your White Mesa Mill near
Blanding, Utah. This inspection consisted of a review of site status, management organization
and controls, radiation protection, and site operations. The inspection results were provided to
members of your staff at the conclusion of the inspection. The enclosed report presents the
results of that inspection.
No violations or deviations were identified during this inspection; therefore, no response to this
letter is required.
ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be made available electronically for public inspection in
the NRC Public Document Floom or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
Public Electronic Reading Room).
Should you have any concerning this
Mr. Louis C. Carson ll at 17) 860-8221 or Jack 197.
Licensing Branch
Docket No.: 040-08681
License No.: SUA-1358
Enclosure:
NRC lnspection Report
040-08681/04-00'1
lnternational Uranium (USA) Corporation
cc w/enclosure:
Mr. Ron Hochstein, President
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Mr. Kenneth T. Miyoshi, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Mr. Dane Finerfrock, Director
State of Utah
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
-2-
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGlON IV
Docket No. 040-08681
License No. SUA-1358
Report No. 040-08681/04-001
Licensee: lnternational Uranium (USA) Corp.
Facility: White Mesa Mill
Location: San Juan County, Utah
Dates: February 18-19,2004
lnspector: Louis C. Carson ll, Health Physicist
Nuclear Materials Licensing Branch
Accompanied by: R. William VonTill, Senior Project Manager
Fuel Cycle Safety and Safeguards (FCSS)
Uranium Processing Section
Approved By: Jack E. Whitten, Chief
Nuclear Materials Licensing Branch
Attachment: Supplemental lnspection lnformation
-2-
EXECUTIVE SUMMARY
White Mesa Mill
NRC lnspection Report 040-08681/04-001
This inspection included a review of site status, management organization and controls,
radiation protection, and site operations. Overall, the licensee was conducting operations in
compliance with license and regulatory requirements.
Management Organization and Controls
. The licensee had maintained an organization structure that agreed with the
requirements of the license (Section 2.0).
. The licensee had adequately implemented the performance-based conditions of the
license (Section 2.0).
. The licensee had adequately reviewed and properly used site procedures (Section 2.0).
Operations Review
. Operational activities were being conducted safely by the licensee in accordance with
the license and NRC regulations (Section 3.0).
. lnspection of the licensee's alternate feed material operations revealed that the material
was handled in an orderly and controlled fashion (Section 3.0).
Badiation Protection
. The radiation protection program areas reviewed by the inspectors and found to be
acceptable were facility postings, personnel exposures, and radiation surveys
(Section 4.0).
Radioactive Waste Management and Environmental Protection
. Environmental, groundwater, and radioactive waste activities were being conducted
safely by the licensee and in accordance with the license and NRC regulations
(Section 5.0).
2.1
-3-
Report Details
Site Status
The NRC issued Source Material License SUA-1358 to Energy Fuels Nuclear during
August 1979. lnternational Uranium Corporation (lUC) assumed ownership of the White
Mesa Mill on May 10,1997, with the NRC's approval of License Amendment 2.
The licensee had not received and processed any natural ore containing uranium or
vanadium since December 1999. The licensee is authorized by License
Conditions 10.6 through 10.17 to receive and process alternate feed materials.from
certain out-of-state entities. The mill processed alternate feed material during calendar
years (CY) 2002 and 2003. There were no yellowcake drying operations in progress
during the inspection. License Condition 10.5 authorizes the licensee to dispose of
11e.(2) byproduct material waste on site. However, 1 1e.(2) disposal operations had not
taken place since the last inspection.
Management Organization and Controls (88005)
lnspection Scope
The organization structure was reviewed to ensure that the licensee had maintained
effective organization and management controls necessary to maintain compliance with
NRC requirements. Also reviewed was the utilization and implementation ol the
licensee's performance-based license (PBL) and selected procedures.
Observations and Findings
Management Organization
The licensee's required organization structure is described in License Condition g.3,
which references the NRC-approved license renewal application dated
January 30, '1997. No changes have been made to the licensee's organization structure
since the previous inspection. The current organization structure was found by the
inspectors to be in agreement with the intent of License Condition 9.3. At the time of
this inspection, White Mesa's staff included 15 employees. The inspectors determined
that the licensee's staffing level was adequate based on current limited facility
operations.
Performance-Based License Review
License Condition 9.4 states, in part, that the licensee may, under certain conditions and
without prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application.
The licensee's implementation of the PBL provisions was reviewed to ensure that any
changes made by the licensee did not negatively impact the licensing basis of the site.
The NRC granted the licensee a PBL in March 1997.
2.2
b.
2.3
.4-
Pursuant to License Condition 9.4, the licensee is authorized to make certain changes
to the licensed program as long as they are reviewed by the safety and environmental
review panel (SERP). Proposed changes and SERP deliberations are required to be
documented in accordance with the provisions of License Condition 9.4(D). On
August 26,2003, the licensee submitted its annual SERP report to the NRC. During the
licensee's current SERP period (July 1 ,2002 - June 30, 2003), the licensee held eight
SERP meetings. The inspectors reviewed the meeting summaries from the SERPs
conducted during the period and found them to be adequate.
Site Procedures
ln accordance with License Condition 9.6, the licensee is required to establish and
follow standard operating procedures (SOPs) for all operational process activities
involving radioactive materials that are handled, processed, or stored under the
provision of the NRC license. Based on reviews of the licensee's SOPs and SERP
minutes, the inspectors determined that the radiation safety officer (RSO) had reviewed
and approved procedures as required by the provisions of License Condition 9.6.
During this inspection, the inspectors reviewed the health physics manual, SOPs for
plant process operations, and the emergency response plan. The RSO and staff had
updated the SOPs, reviewed the SOPs on a quarterly basis, and approved procedures
as required by the provisions of License Condition 9.6. The inspectors noted
improvement by the licensee in the quality of the SOP review process. However, the
inspectors did identify one example where an established SOP was not adequately
maintained by the licensee. The Respiratory Protection Program SOP had not been
updated to reflect that the licensee had started using a new powered air-purifying full-
face respirator in July 2003. However, the inspectors noted that new respirator was
appropriately addressed under the radiation work permit program.
Conclusions
The licensee had maintained an organization structure that agreed with the
requirements of the license and had correctly implemented the provisions of the SERP
and PBL license conditions. The licensee's review and use of site procedures met
requirements.
Operations Review (88020)
lnspection Scope
The objective of this portion of the inspection was to verify that site operations were
being conducted in accordance with applicable regulations and license conditions, and
to ensure that operational controls were adequate to protect the health and safety of
workers and members of the general public. There are three operations authorized by
the IUC White Mesa license: (1) conventional uranium ore processing, (2) non-
conventional ore processing of alternate feed material, and (3) commercial 11e.(2)
byproduct waste disposal. However, the licensee has not processed conventional ore
since 1999.
3
3.1
3.2
tr'rJ-
Observations and Findinqs
Alternate Feed Material Operations
The first licensed operation involving processing of either alternate feed or uranium ore
material occurred on June 13,2002, the licensee had not processed alternate feed
material or uranium ore since CY2000. License Conditions 10.6 through 10.17
authorizes the licensee to receive and process alternate fded materialfrom
11e.(2) providers. Some of the sites identified on the license that the IUC White Mesa
was authorized to receive alternate feed materials includ: (1) Honeywell Corporation,
formerly Allied Signal lncorporated, Metropolis, lllinois; (2) Ashland and Linde Formerly
Utilized Sites Remedial Action Program (FUSRAP) sites near Tonowanda, New York,
and Saint Louis, Missouri; (3) drummed calcined byproduct materials from Cameco
Corporation's Blind River and Port Hope facilities, Ontario, Canada; (4) W.R. Grace
material from Chattanooga, Tennessee; (5) Heritage Minerals, Lakehurst, New Jersey,
and (6) Molycorp, Mountain Pass, California.
The licensee had not processed any alternate feed material since May 2003. As of this
inspection, the only alternate feed material remaining unprocessed consisted of a total
of 45,221tons; 39,036 tons of Linde feed material and 6,185 tons (42,740 drums) of
Cameco material. The license does not plan to resume alternate feed material
processing until this summer.
Conclusions
Operational activities were being conducted safely and in accordance with the license
and NRC regulations. Observations of the licensee's alternate feed material operations
revealed that the material was handled in an orderly and controlled fashion.
Radiation Protection (838221
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the license as well as the requirements of 10 CFR Part20-
Observations and Findings
Site Tour
The inspectors toured the facility to observe activities in progress at various locations
throughout the mill and around the ore pad. Licensee radiation measurements were
found to be consistent with the licensee's previously recorded radiation survey results.
During the inspectors' site tour, radiation levels were measured using an NRC
microRoentgen (pR) meter, Serial Number 15540 with a calibration due date of
March 2,2004. The background radiation level measured offsite ranged between
10-15 pR/hr. Radiation surveys were conducted in various locations throughout the mill
3.3
4.1
a.
4.2
b.
-6-
and around the ore pad. No "radiation areas" as defined by 10 CFR 20.1003 were
identified within the process facility. Site perimeter postings required by License
Condition 9.9 were in place at the appropriate entrances to the mill. No radiological
health or safety concern was identified during the tour.
lnternal and External Fladiation Exposures and Bioassay Results
The inspectors reviewed the deep dose equivalent (DDE) radiation exposures since the
previous inspilction. The RSO had issued dosimeters and reviewed the DDE results of
each radiation worker's dosimeter. The inspectors observed that all radiation workers
were wearing dosimeters in the restricted area.
The highest worker total effective dose equivalent (TEDE) recorded for CY 2003 was
280 millirems based on combined dosimeter and air sampling analyses. During
CY 2003, all workers'TEDEs were less than 10 percent of the 5,000 millirem annual
limit specified in 10 CFR 20.1201.
The inspectors reviewed the licensee's bioassay results for CY 2003. The licensee had
implemented the bioassay program specified in NRC Regulatory Guide 8.22, "Bioassay
at Uranium Mills." Employee urinalysis results were required to be investigated if
bioassay samples exceeded the action level of 15 micrograms per liter uranium. No
bioassay results had exceeded the action level during CY 2003. The inspectors
observed the licensee preparing bioassays for processing. The licensee's bioassay
program was found to be adequate.
Conclusions
The radiation protection program was found to be adequate. Personnel exposures
during CY 2003, were well below limits, and bioassay results were acceptable.
Radioactive Waste Management (88035) and Environmental Monitoring (88045)
lnspection Scope
The environmental, effluent and groundwater monitoring programs were reviewed by the
inspectors to assess the effectiveness of the licensee's programs and to evaluate the
affects, if any, of site activities on the local environment.
Observations and Findings
Groundwater Detection Monitoring Program
License Condition 11.3(A) requires, in part, that the licensee implement a groundwater
detection monitoring program. The licensee's internal proceduie entitled "Groundwater
Monitoring Plan and Standard Operating Procedures," was reviewed along with
monitoring records maintained by the licensee since the last inspection. The inspectors
focused on the licensee's performance when following and implementing the
4.3
5
5.1
5.2
b.
-7-
groundwater sampling procedure. lnspectors reviewed the implementation of the
licensee's procedures and results from groundwater, springs, and surface water
sampling. The inspectors observed licensee staff performing leak detection of cell4A.
ln addition, the inspectors observed corrective action activities related to an effort to
remediate chloroform in the groundwater. The inspectors determined that the licensee
had adequately followed their procedures on groundwater sampling and monitoring.
1 1e.(2) Radioactive Waste Receipts and Disposal Operations
l-icense Condition 10.5 authorizes the licensee to dispose of 1 1e.(2) byproduct material
from licensed in-situ leach facilities subject to several conditions, including a 5000 cubic
yard limit from a single source. During the site tour, the inspectors noted that Disposal
Cell 3 was being used for disposal of. offsite 11(e).2 byproduct waste, as authorized in
License Condition 10.5(C). Disposal Cell2 was being used for disposal of White Mesa
waste. During the site tour, the inspectors did not observe any problems with the
1 1(e).2 disposal area.
The inspectors determined that the licensee had not received 1 1e.(2) byproduct waste
shipments since the last inspection.
Conclusions
Environmental, groundwater, and radioactive waste activities were being conducted
safely and in accordance with the license and NRC regulations
Exit Meeting Summary
The inspectors presented the inspection results to representatives of the licensee at the
conclusion of the inspection on February 19,2004. The licensee did not identify any
information reviewed by the inspectors as propriety information.
5.3
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
Fl. Bartlett, Maintenance Manager
R. Berg, Radiation Safety Officer
D. Frydenlund, Vice President and General Counsel
R. Hochstein, President
K. Miyoshi, Mill Manager
Utah Department of Environmental Quality-Division of Radiation Controls
B. Hamos, Environmental Scientist
B. lmai, Environmental Scientist
INSPECTION PROCEDURES USED
Radiation Protection
Management Organization and Controls
Operations Review
Radioactive Waste Management
Environmental Monitoring
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
None
Discussed
None
CFR
CY
DDE
FUSRAP
IUC
aNhr
PBL
PDR
SERP
SOP
TEDE
-2-
LIST OF ACRONYMS USED
Code of Federal Regulations
calendar year
deep dose equivalent
Formerly Utilized Sites Remedial Action program
I nternational Uranium Corporation
microRoentgen/hour
Performance-Based License
Public Document Room
safety and environmental, review panel,
standard operating procedure
total effective dose equivalent
o
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UI{ITED STATES
GLEAR REGULATORY CO]f, MIS
REGION IV
611 RYA!{ PLA:ZA DRIVE, SUITE /r00
ARLIilGTON, TEXAS 7601t-8064
April 19, 2002
David C. Frydenland, Vice-President and
GeneralCounsel
lnternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/02-ol
Dear Mr. Frydenland:
On April 3,2002, the NRC completed an inspection at your White Mesa Mill near Blanding,
Utah. This inspection consisted of a review of site status, management organization and
controls, radiation protection, site operations, radioactive waste management, and
environmenta! protection. The inspection results were provided to members of your staff at the
conclusion of the inspection. The enclosed report presents the results of that inspection.
No violations or deviations were identified during this inspection; therefore, no response to this
letter is required.
ln accordance with 10 CFR 2.790 of the NRC's'Rules of Practice,'a copy of this letter, its
enclosure(s), and your response (if any) will be made available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, please contact
Mr. Louis C. Carson ll at [phone] or the undersigned at [phone].
Sincerely,
[t,rt" /. 0q1,r
Charles L. Cain, Chief
Nuclear Materials Licensing Branch
Docket No.: 40-8681
License No.: SUA-1358
Enclosure:
NRC lnspection Report
40-8681/02-01
o
sto
lnternational Uranium (USA) Corporation -2-
cc Menclosure:
Mr. Ron Hochstein, President
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, CO 80265
Ms. Michelle Rehmann
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, CO 80265
Mr. Kenneth T. Miyoshi, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
lilr. William J. Sinclair, Director
State of Utah
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No. 40-8681
License No. SUA-1358
Report No. 40-8681/02-01
Licensee: lnternational Uranium (USA) Corp.
Facility: White Mesa Mill
Location: San Juan County, Utah
Dates: April2-3,2002
lnspector: Louis C. Carson ll, Health Physicist
Nuclear Materials Licensing Branch
Accompanied By: Charles L. Cain, Chief
Nuclear Materials Licensing Branch
Approved By: Charles L. Cain, Chief
Nuclear Materials Licensing Branch
Attachment: Supplementary lnformation
-2-
EXECUTIVE SUMMARY
White Mesa Mill
NRC lnspection Report 40-8681/02-01
This inspection included a review of site status, management organization and controls,
radiation protection, site operations, radioactive waste management, and environmental
protection programs. Overall, the licensee was conducting operations in compliance with
license and regulatory requirements.
Management Organization and Controls
' The licensee had maintained an organizationalstructure that agreed with the
requirements of the license (Section 2.0).
. The licensee had adequately implemented the safety environmentat review paneland
performance-based license conditions (Section 2.0).
' The licensee's review and use of site procedures met requirements (Section 2.0).
Radiation Protection
' The radiation protection and'As Low As is Reasonably Achievable" (ALARA) programs
were found to be adequate. Personnel exposures during year 2001 were well below
limits, and bioassay results were acceptable (Section 3.0).
Operations. Radioactive Waste Management. and Environmental Protection
' Operational activities were being conducted safely and in accordance with the license
and NRC regulations (Section 4.0).
' Observations of the licensee's alternate feed material receipt operations revealed that
the material was handled in an orderly and controlled fashion (Section 4.0).
' The licensee was noted to have cotlected environmental monitoring samples as required
by the license and as reported in the January - June 2001 semi-annual effluent report.
Sample results were less than the associated effluent release limits specified in
10 CFR Part 20. No adverse trends were identified (Section 4.0).
2.1
2.2
Report Details
Site Status
The NRC issued Source Material License SUA-I358 to Energy Fuels Nuclear during
August 1979. lnternational Uranium Corporation (lUC) assumed ownership of the White
Mesa Mill on May 10,1997, with NRC's approval of License Amendment 2.
The licensee had not received and processed natural ore for uranium or vanadium since
December 1999. As authorized by License Condition 10.5, the licensee was disposing
of 11e.(2) byproduct material waste on site. The millwas in a preoperational state
during this inspection with an anticipated restart of operations in June 2002.
The millwas actively receiving alternate feed material during this inspection. Alternate
feed material is ore other than natural uranium ore. The licensee is authorized to
receive and process alternate feed materials from certain out-of-state entities by License
Conditions 10.6 through 10.17. !n December 2001, the licensee was granted
permission by the NRC to receive and process approximately 17,750 tons of alternate
feed materials from Molycorp of Mountain Pass, California. This alternate feed material
from Molycorp resulted from the extraction of lanthanides and other rare earth metals
that were processed from bastnasite ore. The residuals of the processed ore were
stored in ponds as lead sulfide sludge with an estimated uranium content of
0.15 percent or more.
Management Organization and Controls (S8005)
lnspection Scope
The organization structure was reviewed to ensure that the licensee had maintained
effective organization and management controls to maintain compliance with NRC
requirements. Also reviewed was the utilization and implementation of the licensee's
performance-based license (PBL) and selected procedures.
Observations and Findinqs
Management Organization
The organization structure requirements are provided in License Condition 9.3 as
described in the NRC-approved license renewal application dated January 30, 1997.
No changes had been made to the organization structure since the previous inspection.
However, the licensee had hired a process engineer to fill the position of mill manager.
There were 23 workers employed at the mill at the time of this inspection. The
licensee's organization structure was found to be in agreement with the intent of License
Condition 9.3.
b.
-4-
Performance-Based License (PBL) Review
License Condition 9.4 states that the licensee may, under certain conditions and without
prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application.
The licensee's implementation of the PBL provisions was reviewed to ensure that any
changes made by the licensee did not negatively impact the licensing basis of the site.
The NRC granted the licensee a PBL in March 1997.
Pursuant to License Condition 9.4, the licensee is authorized to make certain changes
to the licensed program as long as they are reviewed by a safety and environmental
review panel (SERP). Proposed changes and SEFIP deliberations are required to be
documented pursuant to License Condition 9.4(D).
Since the previous inspection, the licensee had completed one SERP meeting. SERP
meeting No. 01/02-03 involved reviews of changes to six environmentalstandard
operating procedures (SOPs). The SERP meeting minutes and changes were reviewed
and found to be acceptable. The NRC inspector found that the SERP changes met the
requirements of License Condition 9.4.
Site Procedures
ln accordance with License Condition 9.6, standard operating procedures are required
to be established and followed for all operational process activities involving radioactive
materials that are handled, processed, or stored. The inspector reviewed SOPs for
plant process operations, environmental monitoring, and the emergency response plan.
Based on reviews of the licensee's SOPs and SERP minutes, the inspector determined
that the radiation safety officer (RSO) had reviewed and approved procedures as
required by License Condition 9.6.
The inspector observed the licensee's implementation of SOPs for the release of
intermodal containers, tailings capacity evaluation, and leakage detection at Pond 4A.
The licensee was observed to have been following the established SOPs as required by
License Conditions 9.4 and 9.6.
Conclusions
The licensee had maintained an organization structure that agreed with the
requirements of the license and had correctly implemented SERP and PBL license
conditions. The licensee's review and use of site procedures met requirements.
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the license as well as the requirements of 1O CFR Part 20.
2.3
3.1
3.2
-5-
Observations and Findings
Site Tour
The inspector toured the facility to observe activities in progress. The inspector
measured radiation levels using an NRC microRoentgen (pR) meter (Serial Number
15525, calibration due date December 10,2OO2\. Radiation surveys taken by the
inspector at various locations throughout the mill, around the ore pad, and radioactive
material storage areas were consistent with radiation levels from previous inspections.
The inspector's radiation measurements were found to be consistent with the licensee's
routine survey results. No "radiation areas" as defined by 10 CFR 20.1003 were
identified within the process facility. Site perimeter postings required by License
Condition 9.9 were in place at the appropriate entrances to the mill. No health or safety
concern was identified during the tour.
As low As ls Reasonablv Achievable Program
In accordance with License Condition 11.6, an annual ALARA audit of the radiation
safety program is required to be performed in accordance with Regulatory Guide 8.31.
This ALABA audit was also required by Section 3.6 of the license application. The most
current ALARA audit was conducted December 5-6, 2001, and was found to have been
adequate. The report provided useful information pertaining to the implementation of
the radiological program. No significant health or safety issue was identified.
Since the last inspection, the licensee had conducted several routine ALARA committee
meetings. The inspector reviewed the third quarter ALARA committee meeting minutes
and the ALARA Action ltems Tracking List. The tracking list contained 47 action items
that the ALARA committee had prioritized for improving the White Mesa radiation
protection program. The inspector determined that the ALARA program was adequate.
lnternal and External Radiation Exposures and Bioassay Results
The inspector reviewed the deep dose equivalent (DDE) radiation exposures from year
2001. According to dosimeter results, 12 workers had DDEs that measured 100-260
millirems. The inspector noted that the RSO had monitored radiation exposures of all
radiation workers.
The highest worker total effective dose equivalent (TEDE) recorded was 290 millirems
of which 200s millirem was background radiation. Allworkers TEDE were less than
10 percent of the 5,000 millirem annuallimit specified in 10 CFR 2O.12O1.
The inspector reviewed the licensee's bioassay results for year 2OO1. The licensee had
implemented the bioassay program as specified by NRC Regulatory Guide 8.22,
"Bioassay at Uranium Mills." Employee urinalysis results were required to be
investigated if bioassay samples exceeded the action levelof 15 micrograms per liter
uranium. No bioassay results had exceeded the action level during year 2001. The
licensee's bioassay program was found to be adequate.
b.
3.3
-6-
Equipment Release Surveys
The inspector observed the licensee's process for the release of intermodalcontainers.
The licensee conducted contamination surveys on each intermodal container before
being released and transported from the White Mesa facility. The licensee was required
to assure that external radiation contamination on the containers was not in excess of
Department of Transportation (DOT) limits per 49 CFR 173.428. The DOT's external
radiation contamination limit was22 disintegrations per minute per square centimeter
loose beta-gamma contamination. The inspector reviewed container release survey
records and determined that the licensee was meeting the DOT's contamination limit.
The inspector concluded that the licensee was continuing to release and ship empty
alternate feed material containers in accordance with applicable license conditions, NRC
regulations, and DOT requirements.
Conclusions
The radiation protection and ALARA programs were found to be adequate. Personnel
exposures during year 2OO1 were well below limits, and bioassay results were
acceptable.
Operations Review (88020), Radioactive Waste Management (88035), and
Environmental Monitoring (88045)
lnspection Scope
The environmental monitoring, effluent monitoring, radioactive material storage, and
waste management programs were reviewed to assess the effectiveness of the
licensee's programs and to evaluate the effects, if any, of site activities on the local
environment.
Observations and Findings
Alternate Feed Material Operations
During calendar year 2001, and so tar in 200{ the licensee had not processed alternate
feed material or uranium ore. License Conditions 10.6 through 10.17 authorizes the
licensee to receive and process alternate feed material from 11 providers. Some of the
sites that the licensee was authorized to receive alternate feed materials from included:
(1) Honeywell Corporation, formerly Allied Signal lncorporated, in Metropolis, lllinois;
(2) Ashland and Linde Formerly Utilized Sites RemedialAction Program (FUSRAP) sites
near Tonowanda, New York, and Saint Louis, Missouri; (3) drummed calcined byproduct
materials from Cameco Corporation's Blind River and Port Hope facilities in Ontario,
Canada; (4) W.R. Grace materialfrom Chattanooga, Tennessee; (5) Heritage Minerals
in Lakehurst, New Jersey, and (6) Molycorp in Mountain Pass, California. Since the
previous inspection, the licensee has continued to receive alternate feed materialfrom
the Cameco, Ashland, Linde, Heritage sites, and 35 barrels from Molycorp.
4
4.1
4.2
a-
b.
-7-
During this inspection, the license was preparing for receiving bulk alternate feed
materials from Molycorp in May 2002, and for commencing operations in June 2002,
processing alternate feed material. License Condition 10.17 and related
correspondence for Molycorp alternate feed material required the licensee to implement
several protective measures prior to receiving bulk shipments of Molycorp feed material.
The licensee was required to certify the concentration of hazardous and radioactive
waste constituents in the Molycorp material. White Mesa was required to determine if
their tailings impoundments had adequate capacity to store the waste generated from
the Molycorp material. Additionally, the licensee was required to assure that the
Molycorp material would be stored on a concrete pad that was bermed to prevent liquid
runoff from the material. The licensee was also required to utilize a water spray process
for dust suppression.
The inspector verified that the licensee had conducted a tailings capacity evaluation on
December 19, 2001, for tailings Cells 1 ,2, and 3. The evaluation included projecting
waste generated from 11(e).2 materia! from Texas and Wyoming and alternate feed
material waste from Ashland l, Linde, Heritage, and Molycorp. The licensee had also
received an alternate feed material report from the Molycorp site which certified that
hazardous waste constituents met specifications. The inspector observed that the
licensee had prepared a concrete storage area for the receipt of Molycorp materialthat
was bermed using plastic liner materialand stacked barrels around the perimeter. The
inspector observed the licensee's dust suppression in operation. The inspector
determined that the licensee had met the protective requirements of
License Condition 10.17.
Environmental and Effluent Monitoring Programs
The environmental monitoring program requirements are identified in License
Condition 11.2. The licensee must implement the effluent and environmental monitoring
programs specified in Section 5.5 of the renewal application. The inspector reviewed
the semi-annual effluent report for the second half of calendar year 2001.
The licensee's environmental monitoring program consisted of continuous air,
groundwater, surface water, and vegetation, as wellas ambient gamma exposure rate
measurements. The licensee had collected and analyzed the required samples at the
sampling stations, including one at the nearest resident and at a background location.
The inspector observed the operation of two environmental monitoring stations.
(1) EnvironmentalAirSamplino
Particulate air sampling was performed at the sampling stations using
continuous high volume samplers. The sample filters were exchanged weekly
and analyzed quarterly for natural uranium, radium-226, thorium-230, and
lead-210 concentrations. All sample results were less than 2 percent of the
concentrations specified in 10 CFR Part 20, Appendix B. No adverse trends
were identified.
(2)Environmental Exposure Rates
Ambient gamma radiation levels were continuously measured at the sample
stations with dosimeters. The dosimeters were exchanged and analyzed on a
quarterly basis. The environmental dosimeter results were approximately
4.5 pR/hr, which was consistent with the background station dosimeter located at
an onsite sample station (East Tailings Area). Ambient gamma exposure rates
were determined to be below the limits established in 10 CFR 20.1301(a).
Tailinqs Cell Leak Detection Prooram
The inspector condugted a tour of the licensee's disposal cells. Cells 1 and 3 were
actively being used for waste water recirculation and evaporation processing. Cell 4A
water was being pumped into Cell 3. Liquid recovered from Cell 2 operations was being
transferred to Cell 3. No abnormalconditions such as leaks or berm failures were
obserued at any of the other cells during the site tour.
License Condition 11.3(B-E) requires the licensee to implement a monitoring program of
the leak detection systems for the disposal cells. The inspector toured the four cell
areas with mill staff responsible for the leak detection system and field monitoring.
During year 2001, the licensee had reported to the NRC that the 1-gallon per minute
(gpm) flow rate specified in License Condition 11.3(D) was being exceeded at Cell 44.
During this inspection, the inspector observed the licensee implementing the corrective
actions in Cell 4A that included dissolving crystalized vanadium material and keeping
control of the water level in Cell 44. The inspector observed a licensee technician
measure the liner leakage at Cell 44 and enter the results into the "Cell 44 Leak
Detection System Database." The inspector reviewed the Cell 44 leakage data from
March 1 to April 3, 2001, and the average leakage measured 4.8S gpm.
The inspector concluded that the licensee was properly implementing License
Condition 11.3 regarding disposal cel! management.
11e.(2) Radioactive Waste Receipts and Disposal Operations
License Condition 10.5 authorizes the licensee to dispose of 1 1e.(2) byproduct material
from licensed in-situ leach facilities subject to several conditions, including a 5000 cubic
yard limit from a single source. Disposal Cell3 was being used for disposal of offsite
11(e).2 byproduct waste, as authorized in License Condition 10.5(C). Cell2 was being
used for disposalof White Mesa waste. During the site tour, the inspector did not
obserue any problems with the 11(e).2 disposal area.
The inspector determined that the licensee had not received 11e.(2) byproduct waste
shipments since the last inspection.
d.
4.3
-9-
Conclusions
Operationalactivities were being conducted safely and in accordance with the license
and NRC regulations. Observations of the licensee's alternate feed material receipt
operations revealed that the materialwas handled in an orderly and controlled fashion.
The licensee was noted to have collected environmental monitoring samples as required
by the license and as reported in the July - December 2001 semi-annual effluent report.
Sample results were less than the associated effluent release limits specified in 10 CFR
Part 20. No adverse trends were identified.
Exit Meeting Summary
The inspector presented the inspection results to representatives of the llcensee at the
conclusion of the inspection on April 3,2002. The licensee did not identify any
information reviewed by the inspector as propriety information.
5
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee'
R. Berg, Radiation Safety Officer
R. Bartlett, Maintenance Mariager
K. Miyoshi, Mill Manager
M. Rehmann, Environmental Manager
INSPECTION PROCEDURES USED
83822 Radiation Protection88005 Management Organization and Controls88020 Operations Review88035 Radioactive Waste Management88045 Environmental Monitoring
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYMS USED
ALARA as low as reasonably achievableCFR Code of Federal RegulationsDDE deep dose equivalentDOT Department of Transportationgpm gallons per minutepH/hr microRoentgen/hourPBL Performance Based LicensePDR Public Document RoomRSO Radiation Safety OfficerSERP Safety and Environmental Review PanelSOP Standard Operating ProcedureTEDE totaleffective dose equivalent
UNITED STATES
NUCLEAR REGULATORY COUTISSION
REGION IV
6ll RYAI{ PLAZA DR|VE, SUTTE 400
ARLINGTON, TEXAS 76011-806/0
REGION IV
October 16, 2001
David C. Frydenland, Vice-President and
General Counsel
lnternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/01-02
Dear Mr. Frydenland:
On September 19, 2OO1, the NRC completed an inspection at your White Mesa Mill near
Blanding, Utah. This inspection consisted of a review of site status, management organization
and controls, radiation protection, site operations, radioactive waste management, and
environmental protection. The inspection results were provided to members of your staff at the
conclusion of the inspection. The enclosed report presents the results of that inspection.
No violations or deviations were identified during this inspection; therefore, no response to this
letter is required.
ln accordance with 10 CFR 2.790 of the NRC's'Rules of Practice," a copy of this letter, its
enclosure, and your response, if any, will be made available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records (PARS) component
of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/NRC/ADAMS/|ndex.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, please contact
Mr. Louis C. Carson ll at [phone] or the undersigned at [phone].
Sincerely,
OltaJ.s 7. Qall
Charles L. Cain, Chief
Nuclear Materials Licensing Branch
Division of Nuclear Materials Safety
Docket No.: 40-8681
License No.: SUA-1358
Enclosure: NRC lnspection Report 40-8681/01 -02
frf',:"\ll rc:i' ,, -6'
6' i;;t.-''rot 6..
& "id,uo $
lnternational Uranium (USA) Corporation -2-
cc w/enclosure:
Mr. Ron Hochstein, President
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Ms. Michelle Rehmann
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Mr. Richard E. Bartlett, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Mr. William J. Sinclair, Director
State of Utah
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & !ntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
Docket No.
License No.
Report No.
Licensee:
Facility:
Location:
Dates:
lnspector:
Accompanied By:
Approved By:
Attachment:
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
40-8681
suA-1358
40-8681/01-02
lnternational Uranium (USA) Corp.
White Mesa Mill
San Juan County, Utah
September 18-19, 2001
Louis C. Carson ll, Health Physicist
Nuclear Materials Licensing Branch
Jack E. Whitten, Senior Health Physicist
Nuclear Materials Licensing Branch
Charles L. Cain, Chief
Nuclear Materials Licensing Branch
Supplementary lnformation
-2-
EXECUTIVE SUMMARY
White Mesa Mill
NFIC lnspection Report 40-8681/01 -02
This inspection included a review of site status, management organization and controls,
radiation protection, site operations, radioactive waste management, and environmental
protection programs. Overall, the licensee was conducting operations in compliance with
license and regulatory requirements.
Management Organization and Controls
. The licensee had maintained an organizational structure that agreed with the
requirements of the license (Section 2.0).
. The licensee had adequately implemented the Safety Environmental Review Panel and
performance-based license conditions (Section 2.0).
. The licensee's review and use of site procedures met requirements (Section 2.0).
Radiation Protection
. The radiation protection and 'As Low As is Reasonably Achievable" programs were
found to be adequate. Personne! exposures during year 2001 have been below limits,
and bioassay results were acceptable (Section 3.0).
Operations. Radioactive Waste Management. and Environmental Protection
. Operational activities were being conducted safely and in accordance with the license
and NRC regulations (Section 4.0).
o fi review of the licensee's handling of the alternate feed material and 11e.(2) byproduct
material demonstrated that they were maintaining control of radioactive material
shipments in an orderly, controlled fashion (Section 4.0).
. The licensee was noted to have collected environmental monitoring samples as required
by the license and as reported in the January - June 2001 semiannual effluent report.
Sample results were less than the associated effluent release limits specified in
10 CFR Part 20. No adverse trends were identified (Section 4.0).
2
2.1
-3-
Report Details
Site Status
The NRC issued Source Material License No. SUA-1358 to Energy Fuels Nuclear during
August 1979. Ownership ol the site was eventually transferred to Umetco Minerals,
back to Energy Fuels Nuclear, and finally to lnternational Uranium (USA) Corporation
(lUC). IUC assumed ownership of the White Mesa Mill on May 10,1997, with NRC's
approvalof License Amendment No. 2.
The millwas actively receiving alternate feed material during this inspection. Alternate
feed material is materialother than natural uranium ore. The licensee is authorized to
receive and process alternate feed materials from certain out-of-state entities by License
Conditions 10.6 through 10.16. The licensee had not received and processed ore for
uranium or vanadium since the previous inspection. The licensee as authorized by
License Condition 10.5 was disposing of 11e.(2) byproduct material waste on site.
Management Organization and Controls (88005)
lnspection Scope
The organization structure was reviewed to ensure that the licensee had maintained
effective organization and management controls and maintained compliance with NRC
requirements. Also reviewed was the utilization and implementation of the licensee's
performance-based license (PBL) and selected procedures.
Obseruations and Findinqs
Management Orqanization
The organizationalstructure requirements are provided in License Condition 9.3, which
references the NRC-approved license renewal application dated January 30, 1997.
No changes had been made to the organization structure since the previous inspection.
However, the licensee had assigned another individualto the position of mill manager.
The licensee's organizational structure was found to be in agreement with the intent of
License Condition 9.3.
Performance-Based License Review
License Condition 9.4 states that the licensee may, under certain conditions and without
prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application.
The licensee's implementation of the PBL provisionswas reviewed to ensure that any
changes made by the licensee did not negatively impact the licensing basis of the site.
The NRC granted the licensee a PBL in March 1997.
2.2
a.
b.
3
3.1
Pursuant to License Condition 9.4 the licensee is authorized to make certain changes to
the licensed program as long as they are reviewed by a safety and environmental review
panel (SERP). Proposed changes and SERP deliberations are required to be
documented pursuant to License Condition 9.4(D).
Since the previous inspection, the licensee had held two SERP meetings. The SERP
reviews involved changes to the "Heritage Alternate Feed Managemenf procedure.
The SERP meeting minutes and changes were found to be acceptable. The NRC
inspector found that the SERP changes met the requirements of License Condition 9.4.
Site Procedures
ln accordance with License Condition 9.6, standard operating procedures (SOPs) are
required to be established and followed for all operational process activities involving
radioactive materials that are handled, processed, or stored. The inspector reviewed
the health physics manual, SOPs for plant process operations, and the emergency
response plan. Because of the potentialfor personnel being exposed to thorium during
the handling of ore from the Heritage site, the licensee established an SOP, "Heritage
Alternate Feed Management," for that activity. Based on the licensee's SERP and
ALARA committee minutes, the inspector determined that the radiation safety officer
(RSO) had reviewed and approved the procedure as required by License Condition 9.6.
The inspector obserued the licensee's execution of the SOP during the receipt of
alternate feed material and release of intermodal containers. The license was observed
to have been following the established SOP as required by License Conditions 9.4
and 9.6.
Conclusions
The licensee had maintained an organization structure that agreed with the
requirements of the license and had correctly implemented SERP and PBL license
conditions. The licensee's review and use of site procedures met requirements.
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the license as well as the requirements of 10 CFR Part 20.
Observations and Findinqs
Site Tour
The inspector toured the facility to observe activities in progress. Site perimeter
postings, required by License Condition 9.9, were in place at the appropriate entrances
to the mill. The inspector measured radiation levels using an NRC microRoentgen (pR)
3.2
a.
b.
-5-
meter (Serial Number 15544, calibration due date November 29,2001). Radiation
surveys taken by the inspector at various locations throughout the mill and around the
ore pad were consistent with radiation levels from the previous inspection. The
inspector's radiation measurements were found to be consistent with the licensee's
routine survey results. No "radiation areas" as defined by 10 CFR 20.1003 were
identified within the process facility. lt was determined that the site restricted area was
posted as required by License Condition 9.9. No health or safety concern was identified
during the tour.
As low As ls Reasonably Achievable Proqram
Since the last inspection, the licensee had conducted routine "As low As is Reasonably
Achievable" (ALARA) committee meetings. The inspector reviewed the third quarter
ALARA committee meeting minutes and the third quarter ALARA Action Tracking List.
The tracking list contained 29 action items that the ALARA committee had prioritizedtor
improving the White Mesa radiation protection program. The inspector determined that
the ALARA program was adequate.
The Heritage Ore Radiation Work Permit
The inspector reviewed activities, since the previous inspection, that required the
licensee to issue a radiation work permit (RWP) due to a significant potentialfor workers
to be exposed to radioactive material. The only licensed activity that required the
issuance of an RWP was the handling of the Heritage ore during the period
July 31 - August 4,2001. RWP-370 was issued by the RSO to work in conjunction with
the SOP, "Heritage Alternate Feed Management." The inspector reviewed the RWP
and the SOP for the Heritage activity. The RSO explained that personnel conducting
the Heritage operation received training on the RWP and the SOP. The inspector
reviewed the training records of the workers who signed onto RWP-370 and determined
that they were adequately trained. RWP-370 required personnel to don protective
equipment such as full-face respirators, coveralls, and rubber gloves.
The inspector reviewed the results of airborne radioactivity samples that were collected
during the Heritage work. With the exception of one air sample that was collected
during a windstorm, the airborne concentrations were less than the licensee's action
level of 25 percent of the derived air concentration level for the Heritage ore. The
licensee had collected breathing zone measurements and analyzed them for radon,
uranium, and thorium. Overall, the workers'total effective dose equivalent results were
less than 1 percent of the 5,000 millirem annual limit specified in 10 CFR 20.1201.
External Radiation Exposures and Bioassay Results
The inspector reviewed the deep dose equivalent (DDE) radiation exposures during
calendar year 2001. According to dosimeter results though July 2001, there were only
four workers with DDEs of at least 100 millrem (102, 103, 110, and 152 millirem). The
inspector noted that the radiation safety officer was continuing to track the radiation
exposures of all radiation workers. The RSO gave the inspector a report that showed
that the licensee actively used ALARA assessments to ensure that workers'dosimeters
d.
3.3
4.',1
-6-
were being worn and stored properly. Additionally, the RSO showed the inspector that
they varied the work assignments of individuals at the ore pad and scalehouse to assure
that worker exposures were ALARA.
The inspector reviewed the licensee's bioassay results since the previous inspection.
The licensee had implemented the bioassay program as specified by NRC Regulatory
Guide 8.22,"Bioassay at Uranium Mills." Employee urinalysis results were required to
be investigated if bioassay samples exceeded the action level of 15 micrograms per liter
uranium. No bioassay results had exceeded the action level duiing the period. The
licensee's bioassay program was found to be adequate.
Conclusions
The radiation protection and ALARA programs were found to be adequate. Personnel
exposures during year 2001 were below limits, and bioassay results were acceptable.
Operations Review (88020), Radioactive Waste Management (88035), and
Environmental Monitoring (88045)
lnspection Scope
The environmental monitoring, effluent monitoring, radioactive materialstorage, and
waste management programs were reviewed to assess the effectiveness of the
licensee's programs and to evaluate the effects, if any, of site activities on the local
environment.
Obseruations and Findinos
Alternate Feed Material Operations
So far during calendar year 2001, the licensee had not processed alternate feed
material or uranium ore.
License Conditions 10.6 and 10.7 authorize the licensee to process alternate feed
material from Allied Signal. ln accordance with License Conditions 10.10, 10.11, 10.12,
10.14,10.15 and 10.16, the licensee was authorized to receive bulk alternate feed
materials in soilform from the following sites: (1) Ashland and Linde Formerly Utilized
Sites RemedialAction Program (FUSRAP) sites near Tonowanda, New York, and Saint
Louis, Missouri; (2) drummed calcined byproduct materials from Cameco Corporation's
Blind River and Port Hope facilities in Ontario, Canada; (3) W.R. Grace materialfrom
Chattanooga, Tennessee; and (4) Heritage Minerals in Lakehurst, New Jersey. So far
during year 2001, the licensee only stockpiled alternate feed material. Since the last
inspection, the licensee received and stockpiled ore from the Cameco, Ashland, Linde,
and Heritage sites.
4.2
a.
b.
-7-
The inspector obserued the licensee's process for the release of intermodal containers.
The licensee conducted contamination surueys on intermodal containers before being
released and transported from the White Mesa facility. The licensee was required to
assure that external radiation contamination on the containers was not in excess of
Department of Transportation (DOT) limits per 49 CFR 173.428. The inspector
observed radiation protection personnel affix "Empty'' labels on containers leaving the
site. The labels stated that the package conformed to the limitations of 49 CFR 173.428
for radioactive material. Specifically, the DOT's external radiation contamination limit
was 22 disintegrations per minute per square centimeters (dpm/cm2) loose beta-gamma
contamination. The inspector observed the licensee use a beta-gamma detector for the
surveys and noted the level of sensitivity that the detector exhibited during the conduct
of the surveys. The inspector reviewed container release survey records and
determined that the licensee was meeting the DOT's contamination limit. The inspector
concluded that the licensee was continuing to release and ship empty alternate feed
material containers in accordance with applicable license conditions, NRC regulations,
and DOT requirements.
Environmental and Effluent Monitoring Programs
The environmental monitoring program requirements are identified in License
Condition 11.2. The licensee must implement the effluent and environmental monitoring
programs specified in Section 5.5 of the renewal application. The inspector reviewed
the semiannual effluent report for the first half of calendar year ZOO1.
The licensee's environmental monitoring program consisted of continuous air,
groundwater, surface water, and vegetation, as well as ambient gamma exposure rate
measurements. The licensee had collected and analyzed the required samples at the
sampling stations, including one at the nearest resident and at a background location.
(1) EnvironmentalAirSampling
Particulate air sampling was performed at four stations using continuous high
volume samplers. The sample filters were exchanged weekly and analyzed
quarterly for natural uranium, radium-226, thorium-23O, and lead-210
concentrations. All sample results were less than 2 percent of the
concentrations specified in 10 CFR Part 20, Appendix B. No adverse trends
were identified.
(2) Environmental Exposure Rates
Ambient gamma radiation levels were continuously measured at the four sample
stations with thermoluminescent dosimeters (TLDs). The TLDs were exchanged
and analyzed on a quarterly basis. The environmental TLD results were
approximately 6 pH/hr, which was consistent with the background station TLD
located at an onsite sample station (East Tailings Area). Ambient gamma
exposure rates were determined to be below the limits established in 10 CFR
20.1301(aX2).
(3)
-8-
Vegetation
Vegetation samples were collected at three locations around the mill during
spring 2OO1. The samples were analyzed for radium-226 and lead-210
concentrations. Sample results were comparable to those taken in 2000, with no
observable adverse trends.
Surface Water Sampling
ln accordance with Section 5.5 of the license application, surface water samples
are required to be obtained from two locations. Water samples were obtained
from Westwater Creek and quarterly from Cottonwood Creek. The samples
were analyzed for natural uranium, radium-226, thorium-23O concentrations, and
total dissolved solids. Surface water sample results were comparable to those
taken in 2000, with no observable adverse trends.
(4)
d.
Tailings Cell Leak Detection Proqram
License Condition 11.3(B-E) requires the licensee to implement a monitoring program of
the leak detection systems for the disposal cells. The inspector toured the four cell
areas with millstaff responsible for the leak detection system and field monitoring.
During year 2001, the licensee had reported to the NRC that the 1-gallon per minute
(gpm) flow rate specified in License Condition 11.3(D) was still being exceeded for
Cell 4A. Cell 44 had been built for disposal of byproduct waste material; however,
byproduct had not been placed into the cell. During this inspection, the inspector
obserued that the licensee had initiated corrective actions in Cell 44 that included
dissolving crystalized vanadium material and keeping the water level in Cell 44 very low.
The licensee stated that they planned to replace the damaged polyvinyl liner in Cell 44.
The inspector conducted a tour of the licensee's disposal cells. Cells 1 and 3 were
actively being used for waste water recirculation and evaporation processing. Cell 4A
water was being pumped into Cell 3. Liquid recovered from Cell 2 operations was being
transferred to Cell 3. No abnormal conditions, such as leaks or berm failures, were
obserued at any of the other cells during the site tour.
The inspector concluded that the licensee was properly implementing License
Condition 11.3 regarding disposal cell management.
11e.(2) Radioactive Waste Receipts and Disposal Ooerations
License Condition 10.5 authorizes the licensee to dispose of 11e.(2) byproduct material
from licensed in-situ leach facilities subject to several conditions, including a 5000 cubic
yard limit from a single source. Disposal Cell 3 was being used for disposalof offsite
11(e).2 byproduct waste, as authorized in License Condition 10.5(C). Cell2 was being
used for disposal of White Mesa waste.
4.3
-9-
The inspector reviewed the licensee's most current 11e.(2) summary for year 2001.
So far in 2001, the licensee had received 11e.(2) byproduct waste for disposal from two
waste generators. The inspector reviewed nine waste shipping manifest records and
the licensee waste receipt process. The inspector determined that the licensee's
11e.(2) byproduct waste receipt inspection process was adequate.
Shipments of 11e.(2) waste were found to have been conducted within the 5000 cubic
yard limit of License Condition 10.5.
Conclusions
Operationalactivities were being conducted safely and in accordance with the license
and NRC regulations. A review of the licensee's handling of the alternate feed material
and 11e.(2) byproduct material demonstrated that they were maintaining control of
radioactive material shipments in an orderly, controlled fashion. The licensee was noted
to have collected environmental monitoring samples as required by the license and as
reported in the January - June 2001 semiannual effluent report. Sample results were
less than the associated effluent release limits specified in 10 CFR Part 20 .
No adverse trends were identified.
Exit Meeting Summary
The inspector presented the inspection results to representatives of the licensee at the
conclusion of the inspection on September 19, 2001 . The licensee did not identify any
information reviewed by the inspector as propriety information.
5
o
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
B. Berg, Radiation Safety Officer. R. Bartlett, Mill Manager
M. Rehmann, Environmental Manager
INSPECTION PROCEDURES USED
83822 Radiation Protection88005 Management Organization and Controls88035 Radioactive Waste Management88045 Environmental Monitoring
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
None
Discussed
None
o
LIST OF ACRONYMS USED
ALARA as low as reasonably achievableCaF calcium fluorideCFR Code of Federal RegulationsDOT Department of Transportationdpm disintegrations per minuteIUC lnternational Uranium Corporationmg/l milligrams per literpR/hr microRoentgen/hourPBL Performance Based LicensePDR Public Document RoomRSO Radiation Safety OfficerSERP Safety and Environmental Review PanelSOP Standard Operating ProcedureTLD thermoluminescent dosimeter
-2-
UNITED STATES
NUCLEAR REGULATORY COT]UIISSION
REGION IV
6I' RYAN PLAZA DRIVE, SUITE 4OO
ARLINGTON, TEXAS 7801 1-806'l
April 27, 200L
David C. Frydenland, Vice-President and
General Counsel
lnternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/01-01
Dear Mr. Frydenland:
On April 4,2001, the NRC completed an inspection at your White Mesa Mill near Blanding,
Utah. This inspection was an examination of activities conducted under your license as they
relate to safety and compliance with the Commission's rules and regulations and your license
conditions. The inspection included an examination of selected procedures and representative
records, observations of activities, and interviews with personnel. This inspection consisted of a
review of site status, site operations, radioactive waste management, environmental monitoring,
and followup of previously identified NRC inspection findings. The preliminary inspection
results were provided to members of your staff at the conclusion of the onsite inspection. The
enclosed report presents the results of that inspection.
No violations or deviations were identified during this inspection; therefore, no response to this
letter is required.
ln accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response will be made available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.goviNRC/ADAMS/index.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, please contact
Mr. Louis C. Carson ll at [phone] or the undersigned at [phone].
,.1
irl
t..l
Sincerely,ffiD. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Docket No.: 40-8681
License No.: SUA-1358
lnternational Uranium (USA) Corporation -2-
Enclosure:
NRC lnspection Report 40-8681/00-01
cc Menclosure:
Mr. Ron Hochstein, President
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Ms. Michelle Rehmann
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Mr. William Deal, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Mr. William J. Sinclair, Director
State of Utah
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REG]ON IV
Docket No. 40-8681
License No. SUA-I358
Report No. 40-8681/01-01
Licensee: lnternational Uranium (USA) Corp.
Facility: White Mesa Mill
Location: San Juan County, Utah
Dates: April3-4, 2001
lnspector: Louis C. Carson ll, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Approved by: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Attachment: Supplementary lnformation
-2-
EXECUTIVE SUMMARY
White Mesa Mill
NRC lnspection Report 40-8681/01 -01
This inspection included a review of site status, management organization and controls, site
operations, radioactive waste management, radiation protection and environmental protection
programs. Also, a followup review was performed of previously identified NRC inspection
findings. Overall, the licensee was conducting operations in compliance with license and
regulatory requirements.
Management Organization and Controls
. The licensee had maintained an organization structure that agreed with the
requirements of the license (Section 2.0).
. The licensee had adequately implemented the As Low As is Reasonably Achievable
(ALARA) committee, the Safety Environmental Review Panel (SERP), and
performance-based license conditions (Section 2.0).
. The licensee's review and use of site procedures met requirements (Section 2.0).
Radiation Protection
. The radiation protection and ALARA programs were found to be adequate. Personnel
exposures for year 2000 were below limits, and bioassay results were acceptable
(Section 3.0).
Operations. Radioactive Waste Management. and Environmental Protection
. Operational activities were being conducted safely and in accordance with the
conditions of the license as well as NRC regulations (Section 4.0).
o I review of the licensee's onsite control of the alternate feed material demonstrated that
the licensee was maintaining control of the material in an orderly, controlled fashion
(Section 4.0).
o. The licensee was noted to have collected environmental monitoring samples as required
by the license and as reported in the year 2000 semiannual effluent reports. Sample
results were less than the associated effluent release limits specified in 10 CFR Parl20
during year 2000. No adverse trends were identified (Section 4.0).
Followup
. Five open items were closed which included four violations and one inspection followup
item (Section 5).
2
2.1
-3-
Report Details
Site Status
The NRC issued Source Material License SUA-I358 to Energy Fuels Nuclear during
August 1979. Ownership of the site was eventually transferred to Umetco Minerals,
back to Energy Fuels Nuclear, and finally to lnternational Uranium (USA) Corporation
(lUC). IUC assumed ownership of the White Mesa Mill on May 10,1997. The NHC
approved the transfer via Amendment 2 of the revised License and issued to IUC on
May 9, 1997.
The mill was actively receiving alternate feed material during the inspection. Alternate
feed material is material other than natural uranium ore. The licensee is authorized to
receive and process alternate feed materials from certain out-of-state entities by License
Conditions 10.6 through 10.16. The licensee had not received and processed ore for
uranium or vanadium since the previous inspection. The licensee as authorized by
License Condition 10.5 was disposing of 1 1e.(2) byproduct material waste.
Management Organization and Controls (88005)
lnspection Scope
The organization structure was reviewed to ensure the licensee had maintained effective
organization and management controls to ensure compliance with NRC requirements.
Also, reviewed was the utilization and implementation of the licensee's
performance-based license (PBL).
Observations and Findings
Management Organization
The organizationalstructure requirements are provided in License Condition 9.3, which
references the NRC-approved license renewal application dated January 30, 1997. No
changes had been made to the organization structure since the previous inspection.
The licensee's organizational structure was found to be in agreement with the intent of
License Condition 9.3.
Performance-Based License Review
License Condition 9.4 states, that the licensee may, under certain conditions and without
prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application.
The licensee's implementation of the performance-based license provisions was
reviewed to ensure that any changes made by the licensee did not negatively impact the
licensing basis of the site. The NRC granted the licensee a performance-based license
in March 1997.
2.2
a.
b.
2.3
-4-
Making changes pursuant to License Condition 9.4 are required to be reviewed by a
safety and environmental review panel (SERP). Proposed changes and the
deliberations are required to be documented pursuant to License Condition 9.4(D).
Since the previous inspection, the licensee had held eight SERP meetings. Some of the
SERP reviews involved changes to the following procedures: instrument calibration and
functional checks, environmental monitoring, alternate feed material receipt, and release
of intermodalcontainers. The SERP meeting minutes and changes were found to be
acceptable. The SERP changes since July 2000 met the requirements of License
Condition 9.4.
Site Procedures
ln accordance with License Condition 9.6, standard operating procedures (SOPs) are
required to be established and followed for all operational process activities involving
radioactive materials that are handled, processed, or stored. The inspector reviewed
the health physics manual, SOPs for plant process operations, and the emergency
response plan. The inspector noted improvements in the quality of the licensee's
procedures since the last inspection. The radiation safety officer (RSO) had reviewed
and approved updates to procedures as required by License Condition 9.4. Additionally,
the inspector observed the licensee's performance of SOPs associated with the receipt
of alternate feed material and release of intermodal containers. The license was
observed to have been following the established SOPs as required by License Condition
9.6.
Conclusions
The licensee had maintained an organization structure that agreed with the
requirements of the license and had correctly implemented the performance-based
conditions of the license. The licensee's review and use of site procedures met
requirements.
Radiation Protection (83822)
lnspection ScoLe
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the conditions of the license as well as the requirements of 10 CFR
Part 20.
Observations and Findinqs
Site Tour
A facility tour was performed to observe activities in progress. Site perimeter postings,
required by License Condition 9.9 were in place at the appropriate entrances to the mill.
During the inspector's site tour, radiation levels were measured using an NRC
3.1
3.2
a.
b.
-5-
microRoentgen (pR) meter (Serial Number 15544, calibration due date November 29,
2001). The background radiation level offsite was 10-15 pR/hr. Surveys taken in
various locations throughout the mill and around the ore pad showed the following
radiation levels:
. Central Mill - 200 pH/hr. Main Grizzly - 800 pF/hr. Truck Wash/Decon Pad - 200-600 ;rH/hr. Ore Pad Area - 300 - 1,000 pH/hr. Truck Checkpoint - 7O pF/hr
The inspector's radiation measurements were consistent with the licensee's routine
survey results. No "radiation areas" as defined by 10 CFR 20.1003 were identified
within the process facility. lt was determined that the site restricted area was posted as
required by License Condition 9.9. No health or safety concern was identified during the
tour.
As low As Reasonablv Achievable Program Review
ln accordance with License Condition 11.6, an annual As Low As is Reasonably
Achievable (ALARA) audit of the radiation safety program is required to be performed in
accordance with Regulatory Guide 8.31. The most current ALARA audit was conducted
December 5-6, 2000, and was found to have been adequate. This ALARA audit was
also required by Section 3.6 of the ALARA Program section of the license application.
The report provided useful information pertaining to the implementation of the
radiological program. No significant health or safety issue was identified.
Since the last inspection, the licensee had conducted routine ALARA committee
meetings. The inspector reviewed the ALARA committee meeting minutes and the
ALARA Action Tracking List. The tracking list contained 38 action items that the ALARA
committee had prioritized for improving the White Mesa radiation protection program.
The inspector determined that the ALARA audit and program were adequate.
Personnel Radiation Exposure and Bioassav Results
The inspector reviewed the Annual Report of Dose to Employee - 2000 letters dated
March 15, 2000, that the licensee had issued pursuant to 10 CFR 19.13. The highest
worker total effective dose equivalent (TEDE) recorded was 566 millirem of which
449 millirem was committed effective dose equivalent (CEDE). All other worker's TEDE
were less than 10 percent of the 5,000 millirem annual limit specified in 10 CFR
20.1201.
The licensee's bioassay results for year 2000 were reviewed. The licensee had
implemented the bioassay program as specified by NRC Regulatory Guide 8.22,
"Bioassay at Uranium Mills." Employee urinalysis results were required to be
investigated if bioassay samples exceeded the action level of 15 micrograms/ liter
uranium. No bioassay results had exceeded the action level during the period. The
licensee's bioassay program was adequate.
c.
-6-
3.3 Conclusions
The radiation protection and ALARA programs were found to be adequate. Personnel
exposures for year 2000 were below limits, and bioassay results were acceptable.
Operations Review (88020), Radioactive Waste Management (88035), and
Environmental Monitoring (88045)
lnspection Scope
The environmental, effluent, radioactive material storage and waste, and groundwater
monitoring programs were reviewed to assess the effectiveness of the licensee's
programs and to evaluate the effects, if any, of site activities on the local environment.
Observations and Findinqs
Alternate Feed Material Operations
During year 2000, the licensee had not processed alternate feed material or uranium
ore. Conventional uranium ore operations last occurred in November-December 1999.
The licensee plans to process alternate feed material in June 2001.
License Conditions 10.6 and 10.7, authorizes the licensee to process alternate feed
materialfrom Allied Signal. This material, referred to as "CaF'(calcium fluoride), had
been stockpiled for future processing. ln accordance with License Conditions 10.10,
10.1 1, 10.'12, 10.14, 10.15 and 10.16, the licensee was authorized to receive bulk
alternate feed materials in soilform from the following sites: (1) Ashland and Line
Formerly Utilized Sites RemedialAction Programs (FUSRAP) near Tonowanda, New
York and Saint Louis, Missouri; (2) drummed calcined byproduct materials from Cameco
Corporation's Blind River, Port Hope facilities in Ontario, Canada; (3) W.R. Grace
materialfrom Chattanooga, Tennessee; and (4) Heritage Minerals in Lakehurst, New
Jersey. During year 2000, the licensee only stockpiled alternate feed material. Since
the last inspection, the licensee had been authorized to receive alternate feed material
from the Linde, W.R. Grace, and Heritage sites. However, the licensee was only
stockpiling Linde material.
The inspector noted that License Condition 10.14 for Linde alternate feed material,
required the licensee to certify that the Linde material did not contain hazardous waste
material, and determine if the White Mesa tailings impoundment had adequate capacity
to store the waste generated from the Linde material. The inspector verified that the
licensee had conducted a tailings capacity evaluation on September 25, 2000, for
tailings Cells 1 ,2, and 3. The evaluation included projecting waste generated from USX
11e.2 material, Ashland l, Molycorp, Heritage, and Linde. The licensee had also
received an alternate feed material report from the Linde site which certified that
hazardous waste constituents met specifications. The inspector determined that the
licensee had met the requirements of License Condition '10.14.
4
4.1
4.2
a.
b.
-7-
The licensee's onsite control of the alternate feed material demonstrated that the
licensee was maintaining control of the radioactive waste shipments in an orderly,
controlled fashion. The inspector concluded that the licensee had been receiving
alternate feed material in accordance with the detail of the applicable license conditions.
Environmental and Effluent Monitorinq Proorams
Environmental monitoring program requirements are identified in License
Condition 11.2, which specifies that the licensee implement the effluent and
environmental monitoring programs specified in Section 5.5 of the renewal application.
During the inspection, the inspector reviewed the semiannual effluent reports for
year 2000.
The licensee's environmental monitoring program consisted of continuous air,
groundwater, surface water, and vegetation, as well as ambient gamma exposure rate
measurements. The licensee had collected the required samples at the sampling
stations, including a nearest resident and a background location.
Environmental Air Sampling
Particulate air sampling was performed at four stations using continuous high volume
samplers. The sample filters were exchanged weekly and analyzed quarterly for natural
uranium, radium-226, thorium-23O, and lead-210 concentrations. All sample results for
year 2000 were less than 2 percent of the concentrations specified in 10 CFR Part 20,
Appendix B. No adverse trends were identified.
Environmental Exposure Rates
Ambient gamma radiation levels were continuously measured at the five sample stations
with thermoluminescent dosimeters (TLDs). The TLDs were exchanged and analyzed
on a quarterly basis. The environmental TLD results for year 2000 were approximately
10 pR/hr, which was consistent with the background station TLDs located at an onsite
sample station (East Tailings Area). Ambient gamma exposure rates were determined
to be below the limits established in 10 cFR 20.1301(ax2).
Vegetation
Vegetation samples were collected at three locations around the mill during early spring,
late spring, and fall. The samples were analyzed for radium-226 and lead-210
concentrations. Sample results for year 2000 were comparable to those taken in 1999,
with no observable adverse trends.
Surface Water Sampling
ln accordance with Section 5.5 of the license application, surface water samples are
required to be obtained from two locations. Water samples were obtained from
Westwater Creek and quarterly from Cottonwood Creek. The samples were analyzed
for their natural uranium, radium-226, thorium-230 concentrations, and total dissolved
d.
t.
g.
solids. Surface water sample results for year 2000 were comparable to those taken in
1999, with no observable adverse trends.
Tailinqs Cell Leak Detection Program
License Condition 11.S(B-E) requires the licensee to implement a monitoring program of
the leak detection systems for the disposal cells. The licensee's procedures for tailings
management, training and quality assurance were reviewed. The inspector toured the
cell area with millstaff responsible for the leak detection system and field monitoring.
The licensee notified the NRC that the 1-gallon per minute (gpm) flow rate specified in
License Condition (LC) 11.3(D) has been exceeded for Cell 4A, and that it may have
been exceeded since January 2001. The licensee noted that they were fulfilling the
requirement in License Condition 11.3(DX3) to report this exceedence to the NRC within
48 hours. Millstaff had not reported this exceedence until recently due to equipment
problems. The licensee had initiated corrective action by pumping the leak detection
sump. During this inspection, the licensee was investigating this matter in order to issue
a written report to the NRC in 30 days as specified in LC 11.3(DX3). The inspector
determined that the licensee was properly implementing License Condition 11.3.
11e.(2) Radioactive Waste Receipts and Disposal Operations
License Condition 10.5 authorizes the licensee to dispose of 1 1e.(2) byproduct material
from licensed in-situ leach facilities subject to several conditions, including a 5000 cubic
yard limit from a single source.
The licensee's most current annual 11e.(2) summary for year 2O0O was reviewed.
During 2000, the licensee received 1 1e.(2) byproduct waste for disposal from one waste
generator. Shipments of 11e.(2) waste were found to have been conducted within the
5000 cubic yard limit of License Condition 10.5.
A field inspection of the licensee's disposal cells was conducted. Cells 1 and 3 were
actively being used for process solution evaporation and recycling. Cell 3 was also used
for disposal of White Mesa's tailings and wastes from offsite, as authorized in License
Condition 10.5. Cell2 was being used for disposal of White Mesa waste and had been
covered as the cell was filled. Liquid recovered from Cell2 operations was being
transferred to Cell 3. No abnormal conditions, such as leaks or berm failures were
observed at any of the other cells during the site tour.
Conclusions
Operational activities were being conducted safely and in accordance with the
conditions of the license as well as NRC regulations. A review of the licensee's onsite
control of the alternate feed materialdemonstrated the licensee was maintaining control
of the radioactive waste shipments in an orderly, controlled fashion. The licensee was
noted to have collected environmental monitoring samples required by the license at the
intervals specified in the license, as reported in the 2000 semiannual effluent reports.
4.4
5.1
-9-
Sample results were less than the associated effluent release limits specified in 10 CFR
Part 20 during year 2000. No adverse trends were identified.
Followup (92701)
(Closed) lFl 40-8681/9903-01: Receipt of Hazardous Waste Material at the White Mesa
Miil
On October 26,1999, the licensee inadvertently received and accepted a shipment of
potentially hazardous waste materialfrom the Massachusetts Highway Department
Central Artery Tunnel project. The waste material sample result showed a lead
concentration of 5.75 milligrams per liter (mg/l) which was above the criteria of 5.0 mg/l
for classifying the material as hazardous waste.
The waste material had been erroneously shipped to the site because of a duplication in
shipping container numbers. Several programmatic weaknesses contributed to the
problem including poor control of shipping manifests and use of generic versus specific
ore receipt inspection procedures. The licensee's random sampling program would not
have identified the wastes because the hazardous constituent (lead) was not one of the
constituents that the licensee tested for incoming material. Finally, the shipment of the
materialwas determined not to be under the jurisdiction of the NRC.
An NRC lnspection Followup ltem (lFl) was opened to ensure the licensee resolves the
mixed waste concerns, disposes of the waste material, and implements corrective
actions to prevent recurrence of the incident. The inspector observed that the licensee
had completely excavated the hazardous material and stored the hazardous material in
an intermodal container. The licensee was expecting the intermodal container to be
shipped in August 2000. This matter was to remain open untilthe waste materialwas
removed from the site. The licensee had established a new SOP "lntermodal Container
Acceptance, Handling, and Release," to preclude the recurrence of this type of situation.
During this inspection, the inspector verified that the container of hazardous material
had been shipped off the White Mesa site. This matter is closed.
(Closed) VIO 40-8681/0001-01: Failure to follow procedures for alpha detector
functional checks
License Condition 9.6 required that SOPs be established and followed for all operational
process activities involving radioactive materials that are handled, processed, or stored.
Additionally, written procedures were to be established for non-operational activities to
include instrument calibrations. Section 3.1.2.3.2 of the licensee's SOP "Checks,"
required that instrument checks were made for each detector using an appropriate
calibrated source. A comparison of the results with those obtained at the calibration
was to be conducted to determine field performance. lf deviations exceeding 10 percent
were noted, a recalibration of the detector was required. However, alpha detector
functional check results for June and July 200O were not compared to the results of the
instruments'calibration to determine the field performance of the alpha detectors.
5.2
5.3
-10-
During this inspection, the inspector verified that the licensee had implemented
corrective actions as stated in the violation response letter to the NRC dated
October 13, 2000. The licensee's corrective actions included retraining radiation
protection staff, revising the SOP concerning functional checks, and providing new
instructions to the instrument calibration vendor. This matter is closed.
(Closed) VIO 40-8681/0001-03: Failure to follow the Performance Based License and
use the SafeV and Environmental Review Panel to change the procedure in the license
application for uranium and vanadium product surveys
License Condition 9.4 subjected the licensee to specific conditions regarding changes to
procedures presented in the application. The licensee must maintain records of any
changes made pursuant to this condition until license termination. These records
include written safety and environmental evaluations made by the SERP that provide the
basis for determining if changes are in compliance with the requirements referred to in
Part B of this condition. License application Section 2.7, required that product be
monitored by the radiation protection department before released and shipped from the
site. Product shipments included uranium and vanadium. Section 2.7 of the license
application required that all barrels be fixed alpha and gamma scanned; inspected for
leaks and cleanliness; and all the results documented. tn December 1998, the licensee
determined that the procedure in license application Section 2.7, "Product Shipment
Surveys," did not apply to vanadium product shipments. Therefore, the licensee
stopped performing fixed alpha and gamma scan surveys and inspections on all
vanadium product barrels. Records of this change and a written safety and
environmenta! evaluation that provided the basis for determining that the change met
the requirements in License Condition 9.4(B) were not maintained.
During this inspection, the inspector verified that the licensee had implemented
corrective actions as stated in the violation response letter to the NRC dated
October 13, 2000. The inspector noted that the licensee increased the level of
administrative rigor associated with conducting SERP and ALARA meetings, especially,
pertaining to potential changes to the license application. This matter is closed.
(Closed) VIO 40-8681/0001-04: Failure to conduct free release surveys on vanadium
product shipments as required by the license
License Condition 9.10 required that releases of equipment or packages from the
restricted area be in accordance with "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use of Termination of Licenses for
Byproduct, Source, or Special Nuclear Material," dated May 1987, or suitable alternative
procedures approved by the NRC prior to any such release. Section 2.7.5.(3) of the
SOP "Procedures - Uranium & Vanadium Concentration Shipments," required the
licensee to perform removable alpha contamination (smear/swipe) surveys on any barrel
that exceeds 1,000 disintegrations per minute per 100 square centimeters
(dpm/l00cm2) fixed alpha contamination. However, on March 17 andApril 14,2000,
three barrels containing vanadium product were released from the site restricted area
with measured fixed contamination that exceeded 1,00O dpm/100cm2. The licensee
measurements were not capable of determining the fraction of this radioactivity that was
5.4
5.5
11-
alpha contamination. Therefore, the licensee did not perform surveys for removable
alpha contamination as required. Specifically, the three barrels had fixed contamination
levels of 1,200, 1,600, and 2,000 dpm/l00cm2, respectively.
During this inspection, the inspector verified that the licensee had implemented
corrective actions as stated in the violation response letter to the NRC dated
October 13, 2000. This matter is closed.
(Closed) NCV 40-8681/0001-05: Failure to follow procedures for surveyinq equipment
such as intermodal containers for unrestricted release
On June 22,2000, the licensee reported to the NRC that they had failed to implement
their SOP for releasing intermodal containers offsite. Failure to implement the SOP for
releasing intermodal containers for restricted use was a violation of License
Conditions 9.6 and 9.10. The inspector determined that the licensee had satisfactorily
implemented corrective actions, and the contamination levels that were detected on the
containers had a low safety consequence to members of the public. This matter was
considered non-repetitive, licensee-identified and corrected. Therefore, the violation
was treated as a non-cited violation, consistent with Section Vl.A(8) of the NRC
Enforcement Policy.
During this inspection, the inspector obserued the decontamination and release surveys
of intermodal containers. The inspector noted that the licensee's program for releasing
intermodalcontainers was extensive. Due to the licensee's implementation of its
corrective actions, this matter is closed.
Exit Meeting Summary
The inspector presented the inspection results to representatives of the licensee at the
conclusion of the inspection on April 4,2AO1. The licensee did not identify any
information reviewed by the inspector as propriety information.
ATTACHMENT
PARTIAL L]ST OF PERSONS CONTACTED
Licensee
R. Berg, Radiation Safety Officer
W. Deal, Mill Manager
M. Rehmann, Environmental Manager
83822
88005
88035
88045
92701
INSPECTION PROCEDURES USED
Radiation Protection
Management Organization and Controls
Radioactive Waste Management
Environmental Monitorin g
Followup
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
40-8681/9903-01 lFl Receipt of hazardous was at the White Mesa Site
40-8681/0001-01 VIO Failure to follow procedures for alpha detector functional checks
(License Condition 9.6).
40-8681/0001-03 VIO Failure to follow the PBL and utilized the SERP to change the
procedure in the license application for uranium and vanadium
product surveys (License Condition 9.4).
40-8681/0001-04 VIO Failure to conduct free release surueys on vanadium product
shipments as required by the license (License Condition 9.10).
40-8681/0001-05 NCV Failure to follow procedures for surveying equipment such as
intermodal containers for unrestricted release.
(License Condition 9.6)
Discussed
None
-2-
LIST OF ACRONYMS USED
ALARA as low as reasonably achievableCaF calcium fluorideCFR Code of Federal Regulationscpm counts per minuteDOT Department of Transportationdpm disintegrations per minutelN lnformation NoticeIUC lnternational Uranium Corporationmg/l milligrams per literpR/hr microRoentgeilhourPBL Performance Based LicensepCi/g picocuries/gramPDR Public Document RoomRSO Radiation Safety OfficerSERP Safety and Environmental Review PanelSOP Standard Operating ProcedureTLD thermoluminescent dosimeter
\\
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION lV
6I.I RYAN PLAZA DRIVE, SUITE 4OO
ARLlNGTON, TB(AS 7601't -8064
September 6, 2000
David C. Frydenland, Vice-President and
General Counsel
lnternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/00-01 AND NOTICE OF VIOLATION
Dear Mr. Frydenland:
On July 27,2000, the NRC completed an inspection at your White Mesa Mill near Blanding, Utah.
The inspection consisted of selective examinations of procedures and representative records,
interviews with personnel, and observations of activities in progress. The preliminary inspection
findings were presented to you and members of your staff at the conclusion of the onsite
inspection. A telephonic briefing was held with Mr. Hochstein and members of your staff on
August 22,2000, following the completion of additional in-office inspection. The enclosed repod
presents the results of that inspection.
Based on information developed during the inspection, the NRC has determined violations of NRC
requirements occurred. Three violations are cited in the enclosed Notice of Violation (Notice) and
the circumstances surrounding them are described in detail in the enclosed inspection report.
The first violation involved the failure to follow established standard operating procedures (SOPs)
for performing functional checks of radiation detection instruments in accordance with License
Condition 9.6. The second violation involved a failure to implement the Performance-Based
License condition, a violation of License Condition 9.4. Specifically, your staff changed a radiation
survey procedure that is described in the license application, but failed to maintain records
required by the license, of the basis for determining the change was in compliance with the
requirements referred to in the license. The thinl',yiolation was for failuro to perform unrestricted
release surueys of ceftain vanadium product drums prior to shipment as specified by your
license. Additionally, the inspection found that some vanadium product drums exhibited elevated
levels of radioactivity. This finding is the subject of an Unresolved ltem in this repoft. An
Unresolved ltem is a matter about which the NRC needs additional information in order to
ascedain whether the issue in question is an acceptable item, a deviation, a nonconformance, or
a violation. The issues which appear to be unresolved center on jurisdiction of the NRC over the
radioactivity in your vanadium product and any safety controls which may be needed for this
material. With respect to these issues, we are in receipt of your letter dated August 25,2000,
which describes your position on the subject. Until these matters are resolved, we understand
that you committed to make no shipments of contaminated vanadium product currently in storage.
lf your understanding of this commitment is different than stated above, please contact us
immediately.
{r.:\S 9...r ...r" Ig -s:t*
$,\e,,-,:g
lnternational Uranium (USA) Corporation -2-
A fourth violation concerning the release of contaminated intermodal containers is being treated as
a Non-Cited Violation (NCV), consistent with Section Vl.A(8) of the Enforcement Policy. This NCV
is described in the subject inspection report. lf you contest the violation or the significance of this
NCV, you should provide a response with 30 days of the date of this inspection report, with the
basis of your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory
Commission, Region lV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with regulatory
requirements. For your consideration and convenience, NRC lnformation Notice 96-28,
"SUGGESTED GUIDANCE RELATING TO DEVELOPMENT AND IMPLEMENTATION OF
CORRECTIVE ACTION," is enclosed.
ln accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document Room
or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS).
ADAMS is accessible from the NHC Web site at http://www.nrc.oov/NRC/ADAMS/index.html (the
Public Electronic Reading Room).
Should you have any questions concerning this inspection, please contact Mr. Louis C. Carson ll
at [phone] or Dr. D. Blair Spitzberg at [phone].
Sincerely,
il*rltA &hrh
Owffnt D. Chamberlain, Director
Division of Nuclear Materials Safety
Docket No.: 40-8681
License No.: SUA-1358
Enclosures:
1. Notice of Violation
2. NRC lnspection Report 40-8681/00-01
't
lnternational Uranium (USA) Corporation -3-
cc w/enclosures:
Mr. Ron Hochstein, President
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Ms. Michelle Rehmann
lnternational Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Mr. William Deal, Mill Manager
lnternational Uranium (USA) Corp.
6425 S_outh Highway 191
P.O,8ox 809
BJanding, Utah 84511
t/ Mr. William J. Sinclair, Director
State of Utah
Depadment of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
ENCLOSURE 1
NOTICE OF VIOLATION
lnternational Uranium (USA) Corporation
San Juan County, Utah
Docket No.: 40-8681
License No.: SUA-1358
During an NRC inspection conducted on July 24-27,2000, violations of NRC requirements were
identified. ln accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG-1600, the violations are listed below:
A. License Condition 9.6 states, in part, that standard operating procedures (SOPs) shall be
established and followed for all operational process activities involving radioactive materials
that are handled, processed, or stored. Additionally, written procedures shall be established
for non-operational activities to include instrument calibrations.
Section 3.1.2.3.2 of the licensee's procedure "Checks" required that instrument checks are
made for each detector using an appropriate calibrated source. Comparison of the results
with those obtained at the calibration is utilized to determine field pedormance. lf deviations
exceeding 10 percent are noted, recalibration of the detector is required.
Contrary to the above, alpha detector functional check results for June and July 2000, were
not compared to the results of the instruments' calibration to determine the field
performance of the alpha detectors.
This is a Severity Level lV violation (Supplement Vl).
B. License Condition 9.4(A&B) states, in part, that the licensee may, subject to the conditions
specified in this condition, make changes in procedures presented in the application. The
licensee shall maintain records of any changes made pursuant to this condition until license
termination. These records shall include, written safety and environmental evaluations,
made by the safety, environmental, and review panel (SERP) that provide the basis for
determining if changes are in compliance with the requirements referred to in Paft B of this
condition.
The January 1991 License Application, Section 2.7, "Ptoduct Shipment Surueys," states, in
part, that product shipment from the facility will be monitored by the radiation protection
department prior to shipment release. Product shipment includes uranium and vanadium.
Section 2.7 of the license application requires that all barrels are fixed alpha and gamma
scanned; inspected for leaks, holes, and cleanliness; and the inspection is documented.
ln December 1998, the licensee determined that the procedure in License Application
Section 2.7 "Product Shipment Surueys," did not apply to vanadium product shipments and
therefore, the licensee stopped performing fixed alpha and gamma scan surveys and
inspections on all vanadium product barrels as specified in Section 2.7 ol the license
application. Contrary to the above, records were not maintained of this change with a
written safety and environmental evaluation that provided the basis for determining that the
change was in compliance with the requirements referred to in License Condition 9.a(B).
This is a Severity Level lV violation (Supplement Vl).
License Condition 9.10 requires those releases of equipment or packages from the
restricted area shall be in accordance with "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use of Termination of Licenses for Byproduct,
Source, or Special Nuclear Material," dated May 1987, or suitable alternative procedures
approved by the NRC prior to any such release.
Section 2.7.5.(g) and (4) of the SOP "Procedures - Uranium & Vanadium Concentration
Shipments" required, in part, the licensee to perform removable alpha contamination
(smear/swipe) survey on any barrel that exceeds 1 ,000 disintegrations per minute per 100
square centimeters (dpm/100cm2 ) fixed alpha contamination.
Contrary to the above, on March 17 and April 1 4,2OOO, three barrels containing vanadium
product were released from the site restricted area with measured fixed contamination that
exceeded 1,000 dpm/100cm2. The licensee measurements however were not capable of
determining the fraction of this radioactivity that was alpha contamination. Therefore, the
licensee did not perform surueys for removable alpha contamination as required.
Specifically, the three barrels had fixed contamination levels of 1,200, 1,600, and 2,000
dpm/1 00cm2, respectively.
This is a Severity Level lV violation (Supplement Vl).
Pursuant to the provisions of 10 CFR 2-201, lnternational Uranium (USA) Corporation, is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator,
U.S. Nuclear Regulatory Commission, Region lV, 61'l Ryan Plaza Drive, Suite 400, Arlington,
Texas 76011, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each
violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or
severity level, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid fudher violations, and (4) the date when full compliance
will be achieved. Your response may reference or include previous docketed correspondence, if
the correspondence adequately addresses the required response. lf an adequate reply is not
received within the time specified in this Notice, an order or a Demand for lnformation may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will be
given to extending the response time.
-3-
lf you contest this enforcement action, you should also provide a copy of your response, with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent
possible, it should not include any personal privacy, proprietary, or safeguards information so that it
can be placed in the PDR without redaction. lf personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. lf you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.9., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.790(b) to support a request for withholding confidential commercial or financial
information). lf safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21 .
ln accordance with 10 CFR 19.1 1 , you may be required to post this Notice within two working days.
Dated this 6th day of September 2000
ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No. 40-8681
License No. SUA-1358
Report No. 40-8681/00-01
Llcensee: lnternational Uranium (USA) Corp.
Facility: White Mesa Mill
Location: San Juan County, Utah
Dates: July 24-27, 2000
lnspector(s): Louis C. Carson ll, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Judith L. Walker, lnspector-ln-Training
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Accompanied by: R. William VonTill, Geotechnical Engineer
Uranium Recovery Section
Fuel Cycle Safety and SafegUards
Phillip Ting, Branch Chief
Fuel Cycle Licensing Branch
Fuel Cycle Safety and Safeguards
Approved by: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Attachment: Supplementary lnformation
-2-
EXECUTIVE SUMMARY
White Mesa Mill
NRC lnspection Report 40-8681 /99-01
This inspection included a review of site status, management organization and controls, site
operations, radioactive waste management, radiation protection and environmental protection
programs.
Manaqement Orqanization and Controls
. The licensee had maintained an organization structure that agreed with the requirements of
the license (Section 2.0).
. With one exception that is discussed in Section 3.2(f) of this report, the licensee had
adequately implemented the pedormance-based conditions of the license (Section 2.0).
. The licensee's review and use of site procedures were adequate with two exceptions that
are discussed in Sections 3.2 (c) and (f) of this report (Section 2.0).
Radiation Protection
. The radiation protection program areas that were reviewed and found to be acceptable were
facility posting and access control, personnel air sample analyses, and as low as
reasonably achievable (ALARA) program reviews (Section 3.0).
. Violations were identified in the radiation safety area for failure to follow procedures for
compliance with instrument functional checks, radioactive material and contamination
controls, and material and equipment free release surveys. Three cited violations and one
non-cited violation were identified in these areas. An Unresolved ltem was identified
concerning the controls for vanadium product (Section 3.0).
Radioactive Waste Manaqement and Environmental Protection
. Operational activities were being conducted safely and in accordance with the conditions of
the license as well as NRC regulations (Section 4.0).
o fl review of the licensee's onsite control of the alternate feed material demonstrated the
licensee was maintaining control of the material in an orderly, controlled fashion (Section
4.0).
. The licensee was noted to be collecting environmental monitoring samples as required by
the license and as reported in the 1999 semi-annual effluent reports. All sample results
were less than the associated effluent release limits specified in 10 CFR Part 20 during
1999. No adverse trends were identified (Section 4.0).
-3-
One open item remained open regarding a shipment of soil containing hazardous waste that
had to be reclaimed and shipped (Section 5).
2.1
-4-
Report Details
Site Status
The NRC issued Source Material License SUA-1358 to Energy Fuels Nuclear during
August 1979. Ownership of the site was eventually transferred to Umetco Minerals, back to
Energy Fuels Nuclear, and finally to lnternational Uranium (USA) Corporation (lUC). IUC
assumed ownership of the White Mesa Mill on May 10, 1997. The NRC approved the
transfer via Amendment 2 of the revised License SUA-I358. This amendment was issued
to IUC on May 9, 1997.
The millwas actively receiving alternate feed material during the inspection. Alternate feed
material is material other than natural uranium ore. The licensee is authorized to receive
and process alternate feed materials from certain out-of-state entities by License Conditions
10.6 through 10.13.
The licensee is also receiving and processing bulk uranium ore from active mines through
private contractors. Since the previous inspection, the licensee had processed vanadium
from Colorado Plateau Ore and reprocessed old vanadium that had been stored at the site
since 1988. The licensee had shipped 30 lots of vanadium product since the last
inspection. Additionally, the licensee as authorized by License Condition 10.5 was
disposing of 1 1e.(2) byproduct material waste.
Management Organization and Controls (88005)
lnspection Scope
The organization structure was reviewed to ensure the licensee had maintained effective
organization and management controls in place to ensure compliance with NRC
requirements. Also, the utilization and implementation of the licensee's performance-based
license (PBL) was reviewed.
Observations and Findinqs
Management Oroanization
The organization structure requirements are provided in License Condition 9.3, which
references the NRC-approved license renewal application dated January 30, 1997. The
licensee had made no changes to the organization structure since the previous inspection.
The licensee's organization structure was found to be in agreement with the intent of
License Condition 9.3.
2.2
b.
-5-
Performance-Based License Review
License Condition 9.4 states that the licensee may, under ceftain conditions and without
prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application. The
licensee's implementation of the pedormance-based license provisions was reviewed to
ensure that any changes made by the licensee did not negatively impact the licensing basis
of the site. The NRC granted the licensee a performance-based license during March 1997.
Making changes pursuant to License Condition 9.4 are required to be reviewed by a safety
and environmental review panel (SERP). Proposed changes and the deliberations are
required to be documented pursuant to License Condition 9.4(D). On July 7, 2000, the
licensee submitted its annual SERP report to the NRC pursuant to License
Condition 9.4(D). During the licensee's SERP period (July 1 , 1999 - June 30, 2000), the
licensee held six SERP meetings. The licensee has held three SERP meetings since the
previous inspection. The inspectors reviewed the meeting minutes from SERP No. 00/01
and 02 dated July 21 and24,2000, and found them to be adequate. However, the licensee
held a SERP meeting in December 1999, that resulted in a change to a procedure that is in
the license application, and the SERP's decision was not documented in accordance with
License Condition 9.4. This matter is further discussed in Section 3.2(f) of this report.
Additionally, License Condition 9.4 states that the licensee's SERP shall function in
accordance with the SOP submitted to the NRC on June 10, 1997. The inspector reviewed
SOP No. PBL-1, "Safety and Environmental Review Panel," Revision 2, dated June 7, 1997,
which implemented the PBL process. The inspectors did not identify any changes in the
SOP as approved by the NRC.
Based on review of the 1999 and the July 2000 SERP minutes, the inspectors determined
that the SERP met the requirements of License Condition 9.4, with the exception that is
discussed in Section 3.2(f) of this report.
Site Procedures
ln accordance with License Condition 9.6, SOPs are required to be established and
followed for all operational process activities involving radioactive materials that are handled,
processed, or stored. The inspectors reviewed the health physics manual, SOPs for plant
process operations, and the emergency response plan. The inspectors noted continual
improvements in the quality of the licensee's procedures since 1994. The radiation safety
officer (RSO) had been updating, reviewing, and approving procedures as required by
License Condition 9.4. However, the inspectors identified an example where an established
radiation protection SOP was not consistent with the procedure described in the license
application. Additionally the inspectors identified an example where radiation protection staff
was not following the established procedure. The specific examples of these
inconsistencies are further discussed in Sections 3.2 (c) and (f) of this repofi.
2.3 Conclusions
The licensee had maintained an organization structure that agreed with the requirements of
the license. With one exception, the licensee had correctly implemented the pedormance-
based conditions of the license. The licensee's review and use of site procedures were
adequate with two exceptions that are discussed in Sections 3.2 (c) and (f) of this report.
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify compliance
with the conditions of the license as well as the requirements of 10 CFR Part 20.
Observations and Findinqs
Site Tour
A facility tour was performed to obserue activities in progress. Site perimeter postings,
required by License Condition 9.9 were in place at the appropriate entrances to the mill.
During the inspectors' site tour, radiation levels were measured using an NRC
microRoentgen (pR) meter. The background radiation level offsite was 10-15 pR/hr.
Surveys taken in various locations throughout the mill and around the ore pad showed the
f ollowing radiation levels:
. Sag Mill - 200 pR/hr. Ash Lot No. 133 - 500 pR/hr. Main Grizzly - 800 pR/hr. Pulp storage tank area - 2O0 pR/hr. Truck Wash/Decon Pad - 700 pR/hr. Ore pad near fenceline - 300 pR/hr. Truck checkout Point - 50 pR/hr. Cell2, 11e.(2) area - 60 pR/hr
The inspectors' radiation measurements were consistent with the licensee's routine survey
results. No "Radiation Areas" as defined by 10CFR20.1003 were identified within the
process facility. The inspectors identified that the vanadium storage area had elevated
radiation levels of 300-400 pR/hr. lt was determined that this area was part of the site
restricted area and was adequately posted as required by License Condition 9.9. No health
or safety concern was identified during the tour.
As low As Reasonably Achievable Prooram Review
ln accordance with License Condition 11.6, an annual as low as reasonably
achievable (ALARA) audit of the radiation safety program is required to be performed in
accordance with Regulatory Guide 8.31. The most current ALARA audit was conducted in
1999 and was found to have been adequate. Portions of the radiation safety officer's daily,
weekly and monthly inspection reports were reviewed. These repofts were required by
Section 3.6 of the ALARA Program section of the license application. The reports provided
3.1
3.2
b.
(1)
-7-
useful information such as in-plant radiological sampling and survey results. No significant
health or safety issue was identified.
On June 14 and 16,2000, the licensee conducted ALARA Meetings. The inspectors
reviewed the ALARA committee meeting minutes. The licensee's ALARA meeting covered
several topics including the investigation of intermodal container management, vanadium
circuit operations, reviewing and establishing SOPs, and assuring compliance with
regulatory requirements. The inspector determined that the ALARA meeting minutes were
adequate.
I nstrument Calibrations
Requirements
License Condition 9.6 states, in paft, that standard operating procedures shall be
established and followed for all operational process activities involving radioactive materials
that are handled, processed, or stored. Additionally, written procedures shall be established
for non-operational activities to include instrument calibrations. An up-to-date copy of each
written procedure shall be kept in the mill area to which it applies.
All written procedures for both operational and non-operational activities shall be reviewed
and approved in writing by the radiation safety officer (RSO) before implementation and
whenever a change in the procedure is proposed to ensure that proper radiation protection
principles are being applied. The inspectors found that the licensee used several
procedures for calibrating and conducting efficiency checks on instruments.
Section 3.0 of the license application from January 1991 addresses the site's required
radiation protection procedures for instrument calibrations. Section 3.0 of the license
application had been duplicated as the established calibration SOP in the January 1991 ,
Radiation Protection Manual, Section 3, Appendix D. ln December 1998, Pages 29-31 of
the health physics manual was drafted as the licensee's latest written SOP for calibrating
and performing efficiency checks of alpha radiation detection instruments. The inspectors
noted that the 1991 procedure identified the specific brands and models of radiation
instruments used at the site. The 1998 SOP did not identify specific instrument brands; it
was generically written for performing calibrations and efficiency checks on instrument
types like alpha meters. The licensee also used the vendor manual to operate the
instruments to provide guidance during calibrations and efficiency checks. The RSO
explained that they were continuing to revise instrument calibration procedures.
lnstrument Functional Checks
Section 3.'1.2.3.2 of the licensee's procedure "Checks" required the following:
"Checks are made for each detector using an appropriate calibrated source.
Mounting a source a fixed repeatable distance from the detector, a reading is made.
Comparison of the results with those obtained at the calibration is utilized to
determine field performance. lf deviations exceeding 10 percent are noted,
recalibration of the detector is required."
(2)
d.
The inspectors reviewed the June and July 2000 alpha instrument efficiency check records.
It was determined that the licensee did not compare the results of the instrument efficiency
checks to the results of the instrument calibration. Therefore, the licensee had not been
conducting alpha detector checks in accordance with the established procedure. This was
identified as a violation of License Condition 9.6 for failure to follow established procedures
for instrument calibrations (40-8681/0002-01 ).
Additionally, the inspectors noted that the alpha detectors were calibrated with
plutonium-239, but efficiency checked with a thorium-232 check source. The inspector
observed the RSO perform a conventional efficiency check on an alpha detector. The
inspectors noted that the apparent efficiency of the alpha detector using thorium-232 was
7-8 percent. The inspectors compared the 7-8 percent efficiency to the revised
plutonium-239 calibration efficiency of 15-17 percent. The inspectors determined that the
different instrument responses to thorium and plutonium illustrated the importance of
assuring that the calibration efficiency check source was equivalent to calibration source.
ln summary, the licensee had not been conducting alpha instrument functional checks in
accordance with the approved SOP, which was a violation of License Condition 9.6.
Air Samples Analyses
License Condition 11.4 requires that on an annual basis, the licensee collects, during mill
operations, 8 hours of air samples in routinely and frequently occupied areas of the mill. ln
addition, with each change in millfeed material, the licensee must analyze millfeed or
production product for natural uranium, thorium-23O, radium-226, and lead-210. The
inspectors reviewed air sample results from January 1999 to March 2000. The RSO had
collected annual 8-hour air samples for the Ashland-2 alternate feed material and for
materials that were in storage that contained both uranium and vanadium. The RSO found
that airborne thorium-230 concentrations were significantly higher from the Ashland-2
material than other feedstock such as the Colorado Plateau Ore. The RSO determined that
operators who worked with the Ashland-2 material had to be assigned an additional 100
millirem dose for 1999 based on the 8-hour air sample results. The inspectors concluded
that the licensee had met the requirements of License Condition 11.4.
Contaminated Vanadium
During site tours the inspectors conducted radiation surveys using an NRC calibrated
microRoentgen meter. The inspectors noted that the offsite background levels measured
10-15 pR/hr. However, the inspectors found a fenced area of the owner controlled property
that measured 300-400 pR/hr at the fence. The inspectors noted that blue S5-gallon drums
were stored behind the fenced area. Based on the inspectors' inquiry about the contents of
the barrels, the licensee revealed that the drums contained vanadium product that was
contaminated with radioactive material. Vanadium is a constituent of some ores (Colorado
Plateau Ore) and is present in the uranium recovery process raffinate as a dissolved solid.
The licensee's vanadium process involves processing the uranium recovery raffinate
through a solvent extraction process in order to precipitate and recover vanadium as a
commercial product. This vanadium recovery process was designed to remove all
radioactive material from the vanadium product. The RSO had notified IUC management
that the vanadium was radioactively contaminated by a letter dated May 5, 2000. Although
not required, the licensee did not inform the NRC of this situation. The inspectors surveyed
the barrels containing vanadium and the contact radiation readings measured by the
inspector were as follows:
Lot 45 Drum No. 39 - 210 pR/hr
Lot 45 Drum No. 22 - 2OO pR/hr
Lot 44 Drum No. 45 - 100 pR/hr
Lot 49 Drum No. 41 -1,600 pR/hr
Lot 51 Drum No. 61 - 700 pR/hr
Lot 51 Drum No. 34 - 7OO pR/hr
Lot 52 Drum No. I -1,000 pR/hr
Lot 52 Drum No. I -1,000 pR/hr
The licensee's energy compensated Geiger-Mueller detector measured 1,500 pR/hr on
contact at Drum No. 41. The inspectors' review of the licensee's May 5, 2000, letter from the
RSO to the IUC president revealed the following:
. Each vanadium lot consisted of 66 barrels.
. Lots 34-52 were ready for shipment when a buyer was found.
. Lots 34-52 had total uranium concentrations between 32-850 picocuries/gram
(pci/g) and total thorium concentrations between 232-1462 pCilg.
The licensee's course of action regarding the contaminated vanadium product was to blend
the higher contaminated lots of vanadium with the lower contaminated lots. This strategy
was in order to get the amount of source material in each lot below the 0.05 percent by
weight "Unimpoftant Quantities" limit from 10CFR40.13. According to the licensee, they had
not determined a root cause for the vanadium product lots being contaminated. However,
they believed the problem was due to a possible failure in the process circuit and that they
had reprocessed contaminated vanadium that had been stored since 1988. The inspeitors
noted however that Section 3.9 of the July 1991 license application "Byproduct Vanadium
Recovery," states that the vanadium is not radioactive. ln addition, Section 3.2.2.2 of the
White Mesa Environmental Statement Report, "Byproduct Vanadium Recovery''states that
less than 0.005 percent UrOrwill be contained in the vanadium product.
The inspectors noted that radioactive material labels had not been placed on the vanadium
barrels that were in the storage area. Additionally, the inspectors noted that Lots 1-33 had
been shipped as non-radioactive material. The inspectors noted that the licensee's
vanadium shipping records routinely included a non-radiological analyses of the constituents
that were in the vanadium product. However, the licensee did not routinely perform
radioisotopic analyses on the vanadium product, and they had no requirement to conduct
such analyses. The licensee provided vanadium shipment records from the previous
shipments that occurred in 1988. The radiation suruey records for these releases of the
product measured 300-1100 dpm/100cm2 fixed contamination and 0.1 millirem/hour.
f.
(1)
10-
The inspectors determined that this matter would be considered an Unresolved ltem (URl)
pending further review by the NRC. An Unresolved ltem is a matter about which the NRC
needs additional information in order to asceftain whether the issue in question is an
acceptable item, a deviation, a nonconformance, or a violation (40-8681/0001-02).
Meanwhile, the IUC president committed that White Mesa would not release and ship the
contaminated vanadium product that was in storage until this URI is resolved.
The inspectors also found the licensee had decided that Section 2.7 ol license application
"Product Shipment Surveys" and SOP 2.7.5, "Procedures - Uranium & Vanadium
Concentrates Shipments," were no longer applicable to vanadium product shipments. The
inspectors questioned whether this change degraded licensee safety conimitments as
specified in the license application Section 2.7. Llcense Condition 9.4 allows the licensee,
without prior NRC approval, to make changes in procedures presented in the application if
there is no degradation in the essential safety or environmental commitments. The
licensee's SERP did not document the reason for the change. This aspect is further
detailed in Section 3.2.t(2) of this repoft. However, the licensee's decision to drop vanadium
product surveys as a license requirement is considered part of the URI pending resolution of
the question of jurisdiction over the contaminated vanadium product.
Release Surveys for Equipment and Packages
Release Survey Requirements
License Condition 9.10 requires that releases of equipment or packages from the restricted
area shall be in accordance with "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use of Termination of Licenses for Byproduct,
Source, or Special Nuclear Material," dated May 1987, or suitable alternative procedures
approved by the NRC prior to any such release.
Section 2.7 of the January 1991 license application "Product Shipment Surveys," states, in
part, that product shipments from the facility will be monitored by the radiation protection
department prior to shipment release. Section 2.7 of the license application requires that all
barrels are fixed alpha and gamma scanned; inspected for leaks, holes, and cleanliness;
and the inspection is documented. Additionally, Section 2.7.4 provides detailed procedural
steps to be followed when surveying the product drums for release.
Reduction in Product Drum Surveys
ln December 1998, the licensee determined that the procedure in License Application
Section 2.7 "Product Shipment Surveys," did not apply to vanadium product shipments and
therefore, the licensee stopped perforrning fixed alpha and gamma scan surueys and
inspections on all barrels as specified in Section 2.7 of the license application. Additionally,
the licensee's SERP did not maintain a record of this change with a written safety and
environmental evaluation that provided the basis for determining that the change was in
compliance with the requirements referred to in License Condition 9.4(B). The inspectors'
review of vanadium shipment records of Lots 1-33 from March-June 2000 confirmed that
the licensee was no longer conducting radiological surveys in accordance with the
instructions in Section 2.7 of the license application.
(2)
(3)
11-
Further discussions with the RSO and corporate management revealed that it was decided
in either a December 1998 ALARA or SERP meeting that the survey requirements for
product shipments did not apply to vanadium product shipments and therefore, these
surveys were no longer performed. At the time of this inspection, the licensee could not
provide the inspectors with the December 1998 ALARA Committee or SERP minutes.
License Condition 9.4 states, in part, that the licensee may, subject to the conditions
specified in this condition make changes in procedures presented in the application. The
licensee shallfile an application for an amendment to the license, unless the following
conditions are satisfied: There is no degradation in the essential safety or environmental
commitments in the license application. The licensee shall maintain records of any changes
made pursuant to this condition until license termination. These records shall include written
safety and environmental evaluations, made by the safety, environmental, and review panel.
These records shall include written safety and environmental evaluations made by the
SERP that provide the basis for determining that changes are in compliance with the
requirements referred to in Part B of this condition.
ln summary, in December 1998 the licensee changed the requirements of Section 2.7 ol lhe
license application for conducting radiological surveys on vanadium product shipments.
However, the licensee did not maintain records of the safety evaluation made by the SERP
for determining that the change was in compliance with the performance-based license.
This was a violation of License Condition 9.4 (40-8681/0002-03).
Contaminated Drums of Vanadium Released Offsite
The licensee's equipment and material release limits are found in the White Mesa
"Equipment Release/Radiological Survey Procedure," which incorporates the "Guidelines
for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use of
Termination of Licenses for Byproduct, Source, or Special Nuclear Material," (Guidelines)
dated May 1987. Table 1 of the Guidelines "Acceptable Surface Contamination Levels" for
natural uranium contamination has a release limit of 5,000 dpm/l00cm2 average fixed
contamination and 1000 dpm/100cm2 removable contamination. The Guidelines specifies
release limits for thorium-230 and radium-226 which are 100 dpm/l00cm2 average fixed
contamination and 20 dpmil00cm2 removable contamination. Natural uranium,
thorium-230, and radium-226 are part of the White Mesa site's radiological profile.
Additionally, the Guidelines states, in part, that the average and maximum radiation levels
associated with surface contamination resulting from beta-gamma emitters should not
exceed 0.2 millirad/hour at 1 centimeter for beta radiation and 1.0 millirad/hour at 1
centimeter for gamma radiation.
The inspectors reviewed release survey records of vanadium product that had been
released out of the restricted area since March 2000. The inspectors reviewed vanadium
shipment records associated with 33 lots. One lot normally consisted of 66 barrels (drums)
that weighed on average 550 pounds. The inspectors' review of the other vanadium lots
that were shipped revealed that some barrels were released with measured contamination
levels of more than 1,000 dpm/100cm2. However, the RSO stated that the barrels had been
washed off before leaving the site in accordance with the SOP. The inspectors examined
g.
the shipping records associated with Lot Nos.7 and 9 that were shipped on March 17 and
April 1 4, 2000, respectively. Records indicated that barrel Nos. 32 and 44 in Lot No. 7 had
measured radiation readings of 0.16 and 0.2 millirem/hour, respectively. Likewise, the
licensee's records indicated that Barrels 32 and 44 had total contamination levels of 1 ,600
and 2,000 dpm/100cm2. Records indicated that barrel No. 37 in Lot No. t had measured
radiation reading of O.12 millirem/hour. Likewise, the licensee's records indicated that
Barrel No. 37 had total contamination level of 1,200. Additionally, there were four other
barrels that measured fixed contamination at 1,000 dpm/l00cm2.
Sections B(1, 3, and 5) of the SOP "Determination of External Contamination of Product
Drums," dated December 1998, required, in paft, that product drums must be swiped with
filter paper discs to determine if they are externally contaminated. The filter swipe must be
counted via standard gross alpha counting techniques. The results of the contamination
surveys for each drum must be logged onto the drum contamination report. The inspectors
fufther noted that the drum contamination repofts stated that if total alpha contamination is
greater than or equal to 1000 dpm/100cm2, a removable smear is required.
Section 2.7.5.(3) and (4) of the SOP "Procedures - Uranium & Vanadium Concentration
Shipments" required, in part, that the licensee to perform removable alpha contamination
(smear/swipe) surveys on any barrel that exceeds 1 ,000 disintegrations per minute per 100
square centimeters (dpm/1 00cm2) fixed alpha contamination.
However, on March 17 and April 14, 2000, three barrels containing vanadium product were
released from the site restricted area that exceeded 1 ,000 dpm/100cm2 fixed
contamination, and the licensee did not conduct fixed or removable alpha contamination
(smear/swipe) surveys on the barrels. The three barrels surveyed had contamination levels
of 1,200, 1,600, and 2,000 dpm/100cm2. However, the licensee had not determined if the
contamination was from alpha radioactivity The inspectors determined that the licensee's
failure to conduct required fixed or removable alpha contamination release surueys on the
barrels from Lots 7 and 9 was a violation of License Condition 9.10 (40-8681/0002-04).
lntermodal Container Releases
During the period from January 2lo April 18, 2000, the licensee had determined that
17 intermodal containers had been released from the White Mesa facility with external
radiation contamination in excess of Department of Transportation (DOT) limits. The
licensee repofted this finding to the NRC on March 1, 2000. The licensee conducted an
extensive investigation of the circumstances surrounding the release of the contaminated
containers. The licensee had implemented short and long term corrective actions
associated with this matter. The inspectors reviewed the following licensee investigation
reports and corrective actions concerning the inadvertent intermodal container releases:
. lnvestigation Report of lntermodal Container Management at the lnternational
Uranium Corporation White Mesa Mill, May 26,2000.
. SERP No. 00/01-02: Meeting Minutes, July 21 and 24,2000.
. ALARA Committee Meeting Minutes, June 14 and 16,2000.
. SOP: "lntermodal Container Acceptance, Handling, and Release," July 27,2000.
13-
The licensee found that out of approximately 6,000 intermodal containers released from the
site, 17 were found to have been contaminated with radioactive materialfrom the White
Mesa site in excess of the DOT shipping limit of 22,0OO dpm/100cm2. A review the survey
data revealed that contaminated containers measured between 2,31 5-37,791 dpm/100cm2.
The inspectors determined that these contamination levels did not represent a significant
safety potential to members of the public because the containers were empty and in transit
during most of the time they were in the public domain. The licensee determined that the
cause of the inadvertent releases were as follows:
. Failure to adhere to the general SOP for equipment releases and failure to establish
an SOP that was specific to intermodal container releases.
. Wet radioactive materialfrom within the site restricted area splattered on the
underside of the container and would not be decontaminated.
. The amount of traffic accessing the restricted area had increased the probability of
releasing contaminated containers.
The licensee's corrective actions included the following:
. On July 24,2000, the licensee implemented a new SOP "lntermodal Container
Acceptance, Handling, and Release."
. Truck routes on the site were modified. Trucks that transport feed material to White
Mesa have limited site access, if any, to the restricted area. Most trucks have
access to the owner controlled area where the trailer or intermodal container of
material is disconnected and transferred to the licensee's truck. The licensee's staff
now unloads the contents of the container at the ore pad.
. The licensee instituted new intermodal trailer/container washing and
decontamination procedu res.
lnspectors observed the licensee's implementation of the new intermodal container SOP.
Licensee personnel were observed satisfactorily conducting contamination surveys on both
the intermodal containers and licensee vehicles that were exiting the restricted area.
ln a letter dated June 22,2000, the licensee stated that during a telephone call with the NRC
project manager regarding the intermodal container issue, that they concluded that they
failed to implement their SOP for releasing intermodal containers for restricted use.
Failure to implement the SOP for releasing intermodal containers for restricted use was a
violation of License Conditions 9.6 and 9.10. The inspectors determined that the licensee
had satisfactorily implemented corrective actions, and the contamination levels that were
detected on the containers had a low safety consequence to members of the public. This
matter was considered non-repetitive, licensee-identified and corrected. Therefore, this
violation is being treated as a non-cited violation, consistent with Section Vl.A(8) of the NRC
Enforcement Policy (NCV: 40-8681/0001 -05).
-14-
3.3 Conclusions
The radiation protection program areas that were reviewed and found to be acceptable were
facility posting, personnel air sample analyses, and ALARA program reviews.
Violations were identified in the radiation safety area for failure to follow procedures for
instrument calibrations and functional checks, radioactive material and contamination
controls, and material and equipment free release surveys. Three cited violations and one
non-cited violation were identified in these areas. An Unresolved ltem was identified
concerning controls for vanadium product.
4 Radioactive Waste Management (88035) and Environmental Monitoring (88045)
4.1 lnspection Scope
The environmental, effluent and groundwater monitoring programs were reviewed to assess
the effectiveness of the licensee's programs and to evaluate the effects, if any, of site
activities on the local environment.
4.2 Observations and Findings
a. Site Operations
The licensee was not processing alternate feed material or uranium ore during this
inspection. Conventional uranium ore operations occurred from April-October 1999. From
November-December 1999, the licensee had processed Colorado Plateau Ore that
contained both uranium and vanadium, and the licensee also reprocessed vanadium that
had been storage since 1989.
ln accordance with License Conditions 10.6 and 10.7, IUC is authorized to process alternate
feed materialfrom Allied Signal. This material, referred to as "CaF'(calcium fluoride), had
been stockpiled for future processing.
ln accordance with License Conditions 10.1 0, 10.1 1 , 10.12, and 1 0.13, the licensee was
receiving bulk alternate feed materials in soil form from the Ashland Formerly Utilized Sites
Remedial Action Program near Tonowanda, New York, and drummed calcined byproduct
materials from Cameco Corporation's Blind River and Port Hope facilities in Ontario,
Canada.
License Condition 10.5 authorizes the licensee to dispose of 1 1e.(2) byproduct material
generated at licensed in-situ leach facilities subject to several conditions, including a
5000 cubic yard limit from a single source.
The inspectors specifically reviewed the licensee's implementation of License Condition
Nos 10.5, 10.10, 10.11 ,10.12, and 10.'13 in the areas of airborne contamination, radiation
safety, and vehicle scanning. The inspectors found that the licensee had been receiving
and processing the alternate feed material and disposing of the 1 1e.(2) materials in
accordance with the detail of the applicable license amendment request commitments.
b.
15-
Environmental and Effluent Monitorinq Proqrams
Environmental monitoring program requirements are identified in License Condition 11.2,
which specifies that the licensee implement the effluent and environmental monitoring
programs specified in Section 5.5 of the renewal application. During the inspection, the
inspectors reviewed the semi-annual effluent report for the second half of 1999. The first
half of 2000 had not been issued, however, the raw data was reviewed for consistency.
The licensee's environmental monitoring program consisted of continuous air, groundwater,
sudace water, and vegetation, as well as ambient gamma exposure rate measurements.
The licensee collected the required samples at the five sampling stations, including a
nearest resident and a background location.
Environmental Air Sampling
Particulate air sampling was performed at four stations using continuous high volume
samplers. The background sampling station (BHV-3) was taken down due to vandalism.
The sample filters were exchanged weekly and analyzed quaderly for natural uranium,
radium-226, thorium-230, and lead-210 concentrations. All sample results for
July 1999-December 1999 were 6.4 percent or less of the concentrations specified in 10
CFR Part 20, Appendix B. No adverse trends were identified.
Environmental Exposure Rates
Ambient gamma radiation levels were continuously measured at the five sample stations
with thermoluminescent dosimeters (TLDs). The TLDs were exchanged and analyzed on a
quaderly basis. The sample results varied from 9.7 pR/hr at the background station to
11.1 pR/hr at an onsite sample station (East Tailings Area) for 1999. Ambient gamma
exposure rates were found to be below the limits established in 10 CFR 20.1301.
A review of TLD data revealed that each TLD location was less than 12 pRlhr. The average
dose rate offsite was determined to be 10-15 pR/hr by surveys, which was comparable to
the readings at each TLD location. The licensee reported each TLD location as background
corrected.
Vegetation
Vegetation samples were collected at three locations around the mill during early spring, late
spring, and fall. The samples were analyzed for radium-226 andlead-210 concentrations.
Sample results for the second half of 1999 were comparable to those taken in the first half
of 1999, with no obseruable adverse trends.
Surface Water Sampling
ln accordance with Section 5.5 of the license application, surface water samples are
required to be obtained from two locations. Water samples (or sediment samples if the
streams are dry) are to be obtained annually from Westwater Creek and quarterly from
Cottonwood Creek. The samples were analyzed for their natural uranium, radium-226, and
thorium-230 concentrations, as well as their quantity of total dissolved solids. The natural
uranium concentration was 2.2 percent of the concentration specified in Appendix B to
10 CFR Part 20.
c.
d.
t.
-16-
g.Groundwater Detection Monitoring Proqram
License Condition 11.3(A) requires the licensee to implement a groundwater detection
monitoring program. The licensee's internal procedure entitled "Groundwater Monitoring
Plan and Standard Operating Procedures," revised May 1g9g, was reviewed along withrecords since the last inspection. Staff involved in groundwater sampling were interuiewed.
It was determined that the licensee was following proper procedures in this area.
Tailinqs Cell Leak Detection Proqram
License Condition 11.S(B-E) requires the licensee to implement a monitoring program of theleak detection systems for the disposal cells. The licensee's procedures toitaitings
management, training and quality assurance were reviewed. The inspector toured the cell
area with mill staff responsible for leak detection system field monitoring and observed
demonstrations of field protocol. Based on observations of mill staff and the review ofrecords, it was determined that the licensee was properly implementing License Condition
11.3.
Radioactive Waste Receipts and Disposal lnspections
The licensee is required to submit an annual summary to the NRC of wastes disposed offrom offsite generators in accordance with Condition io.s.o. The licensee's most currentannual summary dated February 17, 2O0O, was reviewed. During 1ggg, the licensee
received 57 shipments of 1 1e.(2) byproduct waste for disposal from three individual wastegenerators. Seven shipments of 1 1e.(2) waste had been received from offsite generators in2000. Shipments of 11e.(2) waste were found to have been conducted within the limits ofthe license.
A review of the licensee's four disposal cells was conducted. Cells 1 and 3 were actively
being used for process solution evaporation and recycling, with Cell 3 also used for dispbsal
of tailings generated onsite and wastes generated offsite (as authorized in License
Condition 10.5). Cell 2 was being used for disposal of solid wastes generated onsite, and
was covered as the cell was filled. Any liquid recovered from Cell 2 operations was
transferred to Cell 3. Since Cell 4 was not in service during the inspection, receiving onlyprecipitation. Cell 4 had multiple tears and channels in the liner system, the licensee statedthat Cell 4 would not be used until the liner is replaced. No abnormal conditions, such asleaks or berm failures were observed at any of the other cells during the site tour.
Conclusions
Operational activities were being conducted safely and in accordance with the conditions of
the license as well as NRC regulations. A review of the licensee's onsite control of the
alternate feed material demonstrated the licensee was maintaining control of the radioactive
waste shipments in an orderly, controlled fashion. The licensee was noted to be collecting
all environmental monitoring samples required by the license at the interuals specified in the
license, as reported in the 1999 semi-annual effluent reports. All sample results were less
than the associated effluent release limits specified in 10 CFR Parl2O during 1999. No
adverse trends were identified.
h.
i.
4.4
5.1
-17-
Followup (92701)
(Qpen) lFl 40-8681/9903: Receipt of Hazardous Waste Material at the White Mesa Mill
On October 26,1999, the licensee inadvertently received and accepted a shipment of
potentially hazardous waste material from the Massachusetts Highway Department Central
Artery Tunnel project. On the basis of a single analyzed sample, the material contained
lead, a hazardous waste. The result of the sample showed a lead concentration of
5.75 milligrams per liter (mg/l) which was above the criteria of 5.0 mg/l for classifying the
material as hazardous waste. The lead contaminant most likely originated from automotive
exhaust particles that had settled into the soil prior to excavation.
The waste material was erroneously shipped to the site primarily because of a duplication in
shipping container numbers. Several programmatic weaknesses helped contribute to the
problem including poor control of shipping manifests and use of generic versus specific ore
receipt inspection procedures. The licensee's random sampling program would not have
identified the wastes because the hazardous constituent (lead) was not one of the
constituents that the licensee tested for incoming material. Finally, the shipment of the
material was determined not to be under the jurisdiction of the NRC.
An NRC lnspection Followup ltem (lFl) was opened to ensure the licensee resolves the
mixed waste concerns, disposes of the waste material, and implements corrective actions
to prevent recurrence of the incident. The inspectors obserued that the licensee had
completely excavated the hazardous material and stored the hazardous material in an
intermodal container. The licensee was expecting the intermodal container to be shipped in
August 2000. This matter will remain open untilthe waste material is removed from the site.
On July 24,2000, the licensee established a new SOP "lntermodal Container Acceptance,
Handling, and Release," to preclude the recurrence of this type of situation. The inspectors
noted that the licensee had improved the process for verifying shipment manifests.
Exit Meeting Summary
The inspectors presented the preliminary inspection results to the representatives of the
licensee at the conclusion of the inspection on July 27,2OOO. A telephonic exit briefing was
held on August 22,2OO0, to discuss the results of the inspection as presented in this report.
Licensee representatives acknowledged the findings as presented. The licensee did not
identify any information reviewed by the inspector as propriety information.
6
a
AfiACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Hochstein, President
R. Berg, Radiation Safety Officer
W. Deal, Mill Manager
M. Rehmann, Environmental Manager
INSPECTION PROCEDURES USED
83822 Radiation Protection88005 Management Organization and Controls88035 Radioactive Waste Management88045 Environmental Monitoring92701 Followup
ITEMS OPENED, CLOSED AND DISCUSSED
Ooened
40-8681/0001-01 VIO Failure to follow procedures for alpha detector functional checks
(License Condition 9.6).
40-8681/0001-02 URI NRC determination on whether radioactively contaminated vanadium
is a byproduct material or is it an Unimpofiant Quantity pursuant to10
cFR 40.13.
40-8681/0001-03 VIO Failure to follow the PBL and utilized the SERP to change the
procedure in the license application for uranium and vanadium
product surveys (License Condition 9.4).
40-8681/0001-04 VIO Failure to conduct free release surveys on vanadium product
shipments as required by the license (License Condition 9.10).
40-8681/0001-05 NCV Failure to follow procedures for surveying equipment such as
intermodal containers for unrestricted release.
(License Condition 9.6)
Closed
none
Discussed
40-8681/9903 lFl Receipt of hazardous was at the White Mesa Site
ALARA
CaF
CFR
cpm
DOT
dpm
IN
IUC
mg/l
pR/hr
PBL
pCi/g
PDR
RSO
SERP
SOP
TLD
URI
LIST OF ACRONYMS USED
as low as reasonably achievable
calcium fluoride
Code of Federal Regulations
counts per minute
Department of Transpoftation
disintegrations per minute
lnformation Notice
lnternational Uranium Corporation
milligrams per liter
microRoentgen/hour
Performance Based License
picocuries/gram
Public Document Room
Radiation Safety Officer
Safety and Environmental Review Panel
Standard Operating Procedure
thermol uminescent dosimeters
Unresolved ltem
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION tV
611 RYAN PLAZA DRIVE, SUITE 4OO
ARLINGTON, TEXAS 7601 1{064
August L7, 1999
Harold R. Roberts, Executive Vice-President
!nternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, Cotorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/99-02
Dear Mr. Roberts:
On July 29, 1999, the NRC completed an inspeotion at your White Mesa Mill near Blanding,
Utah. The inspection consisted of selective examinations of procedures and representative
records, interviews with personnel, and obseruations of activities in progress. The inspection
findings were presented to you and members of your staff at the conclusion of the onsite
inspection. The enclosed report presents the results of that inspection. Overall, the inspection
determined that you have continued to operate the uranium production facility in a safe and
effective manner.
Based on the results of this inspection, no violations or deviations were identified; therefore, no
response to this letter is required.
ln accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response, if any, will be placed in the NRC Public Document
Room (PDR).
Should you have any questions concerning this inspection, please contact
Mr. Douglas Simpkins at [phone] or myself at [phone] .
Fuel Cycle and Decommissioning Branch
Docket No.: 40-8681
License No.: SUA-1358
Enclosure: NRC !nspection Report 40-8681/99-02
\
6ouoh
flk*t-)p" '$-ffi*-R
&,
QQ". nrr/
D. Blair Spitzberg, Chief
lnternational Uranium (USA) Corporation -2-
White Mesa Mill
cc Menclosure:
Ms. Michelle Rehmann
lnternational Uranium (USA) Corp.
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Mr. William Deal, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
1Ar. William J. Sinclair, Director
State of Utah
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake city, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No. 40-8681
License No. SUA-1358
Report No. 40-8681/99-02
Licensee: lnternational Uranium (USA) Corp.
Facility: White Mesa Mill
Location: San Juan County, Utah
Dates: July 28-29, 1999
lnspector: Douglas S. Simpkins, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Accompanied By: Randolph W. Von Till, Project Manager
Uranium Recovery and Low LevelWaste Branch
Division of Waste Management
Approved By: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Attachment: Supplementary lnformation
-2-
EXECUT]VE SUMMARY
White Mesa Mill
NRC lnspection Report 40-8681/99-02
This inspection included a review of site status, management organization and controls, site
operations, radioactive waste management, radiation protection and environmental protection
programs. Overall, the licensee was operating the facility in a safe and effective manner.
Manaoement Orqanization and Controls
. The licensee's organizational structure was in agreement with the license requirements,
and adequate oversight had been provided for site activities (Section 2.2).
. The licensee had correctly implemented the requirements of its performance-based
license (Section 2.3).
Radioactive Waste Manaqem enVOSHA ! nterf ace Activities
. Operational activities were being conducted safely and in accordance with the
conditions of the license and NRC regulations (Section 3.2).
o I review of the licensee's onsite control of the alternate feed material demonstrated the
licensee was maintaining control of the incoming alternate feed material in an orderly,
controlled fashion. Several examples of OSHA health and safety findings were brought
to the attention of the Safety Officer and management (Section 3.3).
Radiation Protection
. The radiation protection program areas reviewed were found to be acceptable, including
audit program review, decommissioning recordkeeping, radiation and contamination
surveys, bioassay and'respiratory protection activities (Sections 4.2-4.6).
Environmental Protection
. The licensee was noted to be collecting all environmental monitoring samples required
by the license at the intervals specified in the license, as reported in the first half of 1999
semiannual effluent report. All sample results were less than the associated effluent
release limits specified in 10 CFR Part 20 during the tirst half of 1999. When the 1999
sample results were compared to those from 1998, no adverse trends were identified
(Sections 5.2-3).
2
2.1
-3-
Reoort Details
Site Status
The NRC issued Source Material License No. SUA-1358 to Energy Fuels Nuclear during
August 1979. Ownership of the site was eventually transferred to Umetco Minerals,
back to Energy Fuels Nuclear, and finally to !nternational Uranium (USA) Corporation
(lUC). IUC assumed ownership of the White Mesa Mill on May 10, 1997. The NRC
approved the transfer via Amendment No. 2 of the revised License No. SUA-I358. This
amendment was issued to IUC on May 9, 1997.
The millwas actively processing alternate feed materialduring the inspection.
(Alternate feed material is material other than natural uranium ore.) The licensee is
authorized to receive and process alternate feed materials from four out-of-state firms
by License Conditions 10.6 through 10.13. ln accordance with License Conditions 10.6
and 10.7, lUC is authorized to process alternate feed materialfrom Allied Signal. This
material, referred to as "CaF (calcium fluoride), is being processed as alternate feed.
ln accordance with License Conditions 10.10, 10.11 and 10.13, the licensee is receiving
bulk alternate feed nlaterials in soilform from the Ashland 2 Formerly Utilized Sites
Remedial Action Program near Tonowanda, New York. Only fingerprint analysis of the
Ashland 2 material is being conducted in preparation for future processing. The
licensee is also receiving and processing bulk uranium ore from active mines through
private contractors.
The licensee was conducting yellowcake and vanadium drying and packaging
operations. To date, approximately 160,000 pounds of yellowcake had been produced
for the year, but none had been shipped offsite. An additional 60-70 thousand pounds
of yellowcake are in the process tanks.
The licensee currently employs 101 individuals, with 6 additional employee vacancies.
Management Organization and Controls (88005)
lnspection Scope
The organizational structure was reviewed to ensure the licensee had established an
effective organization with defined responsibilities and functions and appropriate
controls were in place to ensure compliance with NRC requirements. Also, the -
utilization and implementation of the licensee's pedormance-based license was
reviewed.
Manaqement Oroanization
The organizational structure requirements are provided in License Condition 9.3, which
references the NRC-approved license renewalapplication dated January 30, 1997. The
licensee had made no changes to the structure since the previous inspection.
2.2
2.3
-4-
ln summary, the licensee's organizational structure was in agreement with License
Condition 9.3.
Perf ormance-Based License Review
The NRC granted the licensee a performance-based license during March 1997.
License Condition 9.4 states that the licensee may, under certain conditions and without
prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application.
The licensee's implementation of the performance-based license provisions was
reviewed to ensure that any changes made by the licensee did not negatively impact the
licensing basis of the site.
The licensee's determinations under License Condition 9.4 are required to be made by a
Safety and Environmental Review Panel (SERP). No SERP reviews had been
conducted since the previous inspection.
Site Procedures
ln accordance with License Condition 9.6, standard operating procedures (SOPs) are
required to be established and followed for all operational process activities involving
radioactive materials that are handled, processed, or stored. During the inspection, the
inspector observed operating procedures being properly implemented.
Conclusions
The licensee had established an organizational structure that agreed with the
requirements of the license. Also, the licensee had correctly implemented the
performance-based conditions of the license. Standard operating procedures were
correctly implemented.
Radioactive Waste Management (88035)
OSHA lnterface Activities (93001)
lnspection Scope
The objective of this portion of the inspection was to verify site activities were being
conducted in accordance with applicable regulations and the conditions of the license,
and to ensure operational controls were adequate to protect the health and safety of the
workers and the members of the general public.
Site Operations
A facility tour was performed to obserye activities in progress. Site perimeter postings,
required by License Condition 9.9, were in place at all entrances to the site. Several
OSHA health and safety concerns were identified during the tour and relayed to the
onsite Safety Officer and management:
2.4
2.5
3.1
3.2
3.3
-5-
. Although posted appropriately as a high noise area with hearing protection
required, at least two workers were observed to be in designated high noise
areas without hearing protection.
. Auger guards at the exit stage of the vanadium filter presses had been removed
for maintenance. However, no compensatory measures were in place to
minimize risk to personnel (e.9., actual workers, barriers, signs, etc.)
. Several hot pieces of machinery were observed, without appropriate hazard
warning signs or barriers.
. An oven used to melt vanadium for processing had an approximate 2 foot flame
shooting out of a vent on one end at head height with no barriers or warning
mechanisms.
. Approximately one-half of the fire extinguishers had been last checked in May
1999, even though the safety program required monthly checks.
o fl liquid process tank was dramatically overflowing in the process circuit, creating
a 6-S" flooding condition. Several electricalwires were dangling into the liquid,
creating a potential electrical hazard.
A review of the licensee's four disposal cells was conducted. Cells 1 and 3 were actively
being used for process solution evaporation and recycling, with Cell 3 also used for
disposal of tailings generated onsite and wastes generated offsite (as authorized in
License Condition 10.5). Cell 2 was being used for disposal of solid wastes generated
onsite, and was covered as the cellwas filled. Any liquid recovered from Cell 2
operations was transferred to Cell 3. Finally, Cell 4 was not in service during the
inspection, receiving only precipitation. Since the cell had multiple tears and channels in
the liner system, the licensee stated that Cell4 would not be used untilthe liner is
replaced or repaired. No abnormal conditions, such as leaks or berm failures, were
observed at any of the cells during the site tour. An inspection of all four cells was
performed by the radiation safety technicians.
Conclusions
The licensee was maintaining control of site operations in accordance with the
conditions of the license and NRC regulations. Although several OSHA health and
safety issues were identified, both the Safety Officer and management committed to
increased attention to these safety concerns.
4.1
4.2
-6-
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the conditions of the license as wellas the requirements of 10 CFR
Part 20.
Audit Program Review
The radiation safety officer's monthly reports were reviewed. These reports are required
by Section 3.6.3, "Monthly Reviews," of the ALARA Program section of the license
application. The reports provided useful information such as in-plant radiological
sampling and survey results.
Finally, the licensee's weekly inspection reports were reviewed. These reports are
required by Section 3.6.2, 'Weekly lnspections," of the license application. No
significant health or safety issue was identified.
Decom missioninq Recordkeepinq
ln accordance with 10 CFR Part 40.36(f)(1), records are required to be permanently
maintained, including a description of the restricted area, spills, and any unusual events.
The licensee was noted to be maintaining these records in onsite files, specifically the
"Spill Containment and Countermeasures Plan and Reports" file. Licensee
representatives stated that they had not added any new information to this file since
1 995.
The licensee was operating in compliance with the recordkeeping requirements of 10
CFR Part 40.36.
Bioassay Proqram Review
License Condition 9.6 requires written procedures for a bioassay program. The licensee
had maintained extensive records related to bioassay sampling. During 1999, bioassay
samples were obtained from site workers at the appropriate frequency and analyzed by
the onsite laboratory, including blank and spiked samples for quality control purposes.
At least ten percent of the samples were split and sent to an offsite laboratory forquality
assurance purposes. No verified sample result exceeded the lowest action level of
15 micrograms of natural uranium per liter of urine.
The sample results for 1999 were compared to 1998 sample results. No individual
exceeded the action level during these years, suggesting that the licensee was
effectively controlling intake of radioactive materials through the use of respirators,
control of the radioactive materials and engineering controls.
4.3
4.4
-7-
4.5 Respiratory Protection
The respiratory protection program was reviewed during the inspection. Respirators
were maintained in the control room area with smoke tubes to assure proper fit when
donning. Plant personnelwere interviewed and demonstrated appropriate knowledge of
respiratory protection equipment usage. Since the previous inspection, the licensee had
revised procedures for establishing airborne radiation areas, establishing consistency
for respiratory requirements. However, airborne radiation area signs were incorrectly
posted on a set of external entrance doors to the mill. The licensee stated the signs
would be removed.
Radiation and Contamination Surveys
Radiation and contamination surveys were reviewed, including breathing zone, alpha,
beta-gamma, radon and personnelcontamination as required by the license and NRC
requirements. Surueys had been conducted as required. Although extensive surueys
were conducted, no levels exceeding regulatory limits were found.
Conclusions
Radiation protection program areas reviewed and found acceptable included audit
program review, recordkeeping of decommissioning activities, bioassay, radiation and
contamination surueys and respiratory protection programs.
Environmental Monitoring (88045)
!nspection Scope
The environmental monitoring program was reviewed to assess the effectiveness of the
licensee's program and to evaluate the effects of site activities on the local environment.
Environmental Monitoring Program Review
License Condition 11.2 states, in part, that the licensee shall implement the effluent and
environmental monitoring program specified in Section 5.5 of the renewalapplication.
Also, the results of the environmental monitoring program are required to be submitted
to NRC on a semiannuat basis in accordance with License Condition 11.3.C. The
semiannual effluent report for the second half of 1998 was reviewed. The 1998 sample
results were compared to those from 1997 to ascertain whether any adverse trends
existed.
Air Particulate Samplinq
The licensee collected particulate air samples at four locations around the site. (The
operation of the air sampler at the background station was discontinued by the licensee
with NRC approvalseveralyears ago.) The sample filters are required to be changed
4.6
4.6
5
5.1
5.2
a.
b.
-8-
weekly, composited quarterly, and analyzed for their natural uranium, radium-226,
thorium-23O, and lead-210 quantities. The sample results, all appropriately sampled as
required by the license and NRC regulations, were less than 3 percent of the respective
10 CFR Part 20, Appendix B, effluent concentration limits. Also, the laboratory's lower
limit of detection was equal to or better than the limits specified in License
Condition 11.2.D.
The 1998 sample results were compared to those from 1997. Overall, the 1998 sample
results were down from the previous year. Therefore, no adverse trends were noted in
this area of the environmental monitoring program.
Ambient External Gamma Exposures
Environmental gamma thermoluminescent dosimeters (TLDs) were located at all five
sample stations. The TLDs were changed out and analyzed on a quarterly basis.
The site perimeter sample stations measured an ambient gamma exposure that was
comparable to the background value. Historically, the difference between the site
stations and background rarely exceeded 10 millirems per quarter. The sample results
for 1999 were comparable to those from 1998 and no adverse trend was observed.
Surface Water Samples
!n accordance with Section 5.5 of the license application, surface water samples are
required to be obtained from two locations. Water samples (or sediment samples if the
streams are dry) are to be obtained annually from Westwater Creek and quarterly from
Cottonwood Creek. The samples were analyzed for their natural uranium, radium-226,
and thorium-230 concentrations, as well as for the quantity of total dissolved and
suspended solids.
Sample results were less than 2 percent of the natural uranium effluent concentration
limit specified in Appendix B of Part 20. Also, the 1999 sample results were noted to be
comparable to those from 1998.
Ground Water Samples
The wellwater samples, all appropriately sampled per the license and NRC regulations,
were analyzed for chloride, potassium, nickel, and uranium concentrations. No trends
were observed with the groundwater sample results.
I nstrument Calibrations
Air Sampler Calibration
!n accordance with License Condition 11.2.E, the licensee is required to perform a
semiannual inspection as well as a biennialcalibration of the criticalorifice assembly.
This device was used to check the accuracy of the environmental air sampler flow rates.
c.
d.
5.3
a.
b.
-9-
Records for inspection and calibration of the critical orifice assembly were reviewed
satisfactorily, as well as calibration records for the air sampling pumps;
I nstrument Calibrations
The Health Physics Manualstates all radiation and environmental monitoring, sampling,
and detection equipment shall be recalibrated after repair and as recommended by the
manufacturer or at least annually, whichever is more frequent. The licensee's
calibration records and availability of equipment were reviewed. The licensee had
maintained calibrated equipment available for use, and had maintained records
indicating all equipment was routinely calibrated.
Conclusions
A cursory review of the licensee's implementation of the environmental monitoring
program requirements was performed. The licensee was noted to be collecting all
samples required by the license at the intervals specified in the license, and reporting
these sample results in their 1999 semiannual effluent report. All sample results were
less than the associated limits specified in 10 CFR Part20. When the 1999 data was
compared to the 1998 sample results, no adverse trend was identified. Sampling
equipment and instruments had been calibrated as required.
Followup (92701)
NRC lnformation Notice 96-70: Year 2000 Effect on Computer System Software
This Notice was issued to alert licensees of the potential problems that may occur with
their computer systems and associated software as a result of the upcoming change to
the new century. During this inspection, the licensee's actions taken in response to this
NRC lnformation Notice were reviewed. ln summary, the licensee had established that
there were no operational equipment controllers affected by the Year 2000 effect.
(Closed) Violation 40-8681/9901-01 Failure to Follow Procedures
During the previous inspection, three examples were observed of failure to follow
procedures: 1) an individual did not conduct face seal checks when donning respiratory
protection equipment, 2) personneldid not sign in on Radiation Work Permits but rather
were listed, and 3) an emergency evacuation drill had not been conducted within-the
semiannual periodicity.
During this inspection, several individuals were observed donning respiratory protection
equipment and properly conducting face seal checks, personnelwere trained to sign in
on Radiation Work Permits, and an emergency evacuation drill had been conducted
within the previous six months. Corrective actions for this violation have been
completed. This violation is now closed.
5.4
6.1
6.2
-10-
7 Exit Meeting Summary
The inspector presented the preliminary inspection results to the representatives of the
licensee at the conclusion of the inspection on July 29, 1999. Licensee representatives
acknowledged the findings as presented. The licensee did not identify any information
reviewed by the inspector as propriety information.
Attachment 1
PARTIAL LIST OF PERSONS CONTACTED
Licensee
H. Roberts, Executive Vice-President
R. Berg, Radiation Safety Officer
W. Deal, Mill Manager
M. Rehmann, Environmental Manager
INSPECTION PROCEDURES USED
83822 Radiation Protection88005 Management Organization and Controls88035 Radioactive Waste Management88045 Environmental Monitoring92701 Followup93001 OSHA lnterface Activities
ITEMS OPENED, CLOSED AND DISCUSSED
Ooened
None
Closed
40-8681/9901-01 VIO failure to follow procedures
Discussed
NRC lnformation Notice 96-70: Year 2000 Effect on Computer System Software
LIST OF ACRONYMS USED
ALARA as low as reasonably achievableCaF calcium fluorideCFR Code of Federal RegulationsPDR Public Document RoomRWP radiation work permitSERP Safety and Environmental Review PanelSOP Standard Operating ProcedureTLD thermoluminescent dosimeters
+11arr
UNITED STATES
REGULATORY COMMI
REGION IV
611 RYAN PLAZA DRIVE, SUITE 'IOOARLINGTON, TEXAS 7601 1 €064
April 21, L999
Harold R. Roberts, Executive Vice-President
International Uranium (USA) Corporation
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/99-01 AND NOTICE OF VIOLATION
Dear Mr. Roberts:
On March 25, 1999, the NRC completed an inspection at your White Mesa Mitl near Blanding,
Utah. The inspection consisted of selective examinations of procedures and representative
records, interviews with personnel, and observations of activities in progress. The inspection
findings were presented to you and members of your staff at the conclusion of the onsite
inspection. The enclosed report presents the results of that inspection. Overall, the inspection
determined that you have continued to operate the uranium production facility in a safe and
effective manner.
However, based on information developed during the inspection, the NRC has determined a
violation of NRC requirements occurred. The violation is cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding it are described in detail in the enclosed
inspection report. The violation involved the failure to follow Standard Operating Procedures
(SOPs). Specifically, three examples were found of failure to follow established SOPs, a
violation of License Condition 9.6. The violation is of concern because it was identified by the
NRC, and demonstrates a lack of attention to detail to procedural requirements.
Since you committed to corrective actions during the inspection, you are not required to
respond to this letter.
ln accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response, if any, will be placed in the NRC Public Document
Room (PDR).
Should you have any questions concerning this inspection, please contact
Mr. Douglas Simpkins at [phone] or Dr. D. Blair Spitzberg at [phone] .
Docket No.: 40-8681
License No.: SUA-1358
Enclosures: (See next page)
o
NUCLEAR
a
SSION
.=". >!c);"r; iDu =l)r' ^ 4i, ;r' ti )rit?J,7;: ',,
E
Sincerely,
Division of Nuclear Materials Safety
lnternational Uranium (USA) Corporation
White Mesa Mill
Enclosures:
1. Notice of Violation
2. NRC lnspection Report 40-8681/99-01
cc denclosure:
Ms. Michelle Rehmann
International Uranium (USA) Corp.
lndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Mr. William Deal, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Mr. William J. Sinclair, Director
State of Utah
Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
-2-
ENCLOSURE 1
NOT]CE OF VIOLATION
lnternational Uranium (USA) Corporation
San Juan County, Utah
Docket No.: 40-8681
License No.: SUA-1358
During an NRC inspection conducted on March 23-25,1999, a violation of NRC requirements
was identified. ln accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG-1600, the violation is listed below:
License Condition 9.6 states, in part, standard operating procedures shall be
established and followed for all operational process activities involving radioactive
materials that are handled, processed, or stored.
Contrary to the above, the licensee did not follow established SOPs in three separate
occasions:
. The Health Physics Manual requires personnel donning respiratory protection
equipment to conduct positive or negative face seal checks. Contrary to this
requirement, on March 24, 1999 an individual was obserued to have not
conducted face seal checks when using respiratory protection for protection from
radionuclides.
. The Ore Receiving, Feed and Grinding Manual requires personnelconducting
work under a radiation work permit to sign the permit. Contrary to this,
personnelwere simply listed on six radiation work permits since the previous
inspection.
. The Emergency Response Plan requires emergency evacuation drills be
conducted, documented and reviewed by management semi-annually. Contrary
to this, as of March 25, 1999, the last drill had been conducted in June, 1998, the
last documented drill had been conducted April 29, 1996, and no record of drill
reviews was found.
This is a Severity Level lV violation (Supplement V!).
The NRC has concluded that information regarding the reason for the violation, the corrective
actions taken and planned to correct the violation and prevent recurrence and the date when
full compliance will be achieved is already adequately addressed on the docket in this
inspection report. However, you are required to submit a written statement or explanation
pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective
actions or your position. ln that case, or if you choose to respond, clearly mark your response
as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional
Administrator, Region lV, 61 1 Ryan Plaza Drive, Suite 400, Arlington, Texas 7601 1, within
30 days of the date of the letter transmitting this Notice of Violation.
-2-
lf you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
lf you choose to respond, your response will be placed in the NRC Public Document Room
(PDR). Therefore, to the extent possible, the response should not include any personal privacy,
proprietary, or safeguards information so that it can be placed in the PDR without redaction. lf
personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. lf you
request withholding of such material, you must specifically identify the portions of your response
that you seek to have withheld and provide in detail the bases for your claim of withholding
(e.9., explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.790(b) to support a request for
withholding confidential commercial or financial information). lf safeguards information is
necessary to provide an acceptable response, please provide the levelof protection described
in 10 CFR 73.21.
ln accordance with 10 CFR 1 9.1 1 , you may be required to post this Notice within two working
days.
Dated this 21"tday of April 1999
ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISS]ON
REGION IV
Docket No. 40-8681
License No. SUA-I358
Report No. -8681/99-01
Licensee: lnternational Uranium (USA) Corp.
Facility: White Mesa Mill
Location: San Juan County, Utah
Dates: March 23-25, 1999
lnspector: Douglas S. Simpkins, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Accompanied By: Ted Johnson, Senior Technical Reviewer
Uranium Recovery and Low LevelWaste Branch
Division of Waste Management
Daniel Rom, Geotechnical Engineer
Uranium Recovery and Low LevelWaste Branch
Division of Waste Management
Approved and Accompanied By:
D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Attachment: Supplementary lnformation
-2-
EXECUTIVE SUMMARY
White Mesa Mill
NRC lnspection Report 40-8681/99-01
This inspection included a review of site status, management organization and controls, site
operations, radioactive waste management, radiation protection and environmental protection
programs. Overall, the licensee was operating the facility in a safe and effective manner.
Manaoement Orqanization and Controls
. The licensee's organizational structure was in agreement with the license requirements,
and adequate oversight had been provided for site activities (Section 2.2).
o I review of the licensee's implementation of the performance-based license showed the
licensee had correctly utilized a performance-based license (Section 2.3).
. Three examples of a failure to follow established procedures were noted, a violation of
License Condition 9.6 (Section 2.4).
Radioactive Waste Manaqement
. Operational activities were being conducted safely and in accordance with the
conditions of the license as well as NFIC regulations (Section 3.2).
o fi review of the licensee's onsite control of the alternate feed material demonstrated the
licensee was maintaining controlof the radioactive waste shipments in an orderly,
controlled fashion (Section 3.3).
Radiation Protection
. The radiation protection program areas reviewed were found to be acceptable with the
exception of the noted procedural compliance violations, including audit program review,
decommissioning recordkeeping, radiation work permits (RWPs), bioassay and
respiratory protection activities (Sections 4.2-4.6).
Envi ronmental Protection
. The licensee was noted to be collecting all environmental monitoring samples required
by the license at the intervals specified in the license, as reported in the 1998
semiannual effluent reports. All sample results were less than the associated effluent
release limits specified in 10 CFR Part 20 during 1998. When the 1998 sample results
were compared to those from 1997, no adverse trends were identified (Sections 5.2-3).
2.1
-3-
Report Details
Site Status
The NRC issued Source Material License No. SUA-1358 to Energy Fuels Nuclear during
August 1979. Ownership of the site was eventually transferred to Umetco Minerals,
back to Energy Fuels Nuclear, and finally to lnternational Uranium (USA) Corporation
(lUC). IUC assumed ownership of the White Mesa Millon May 10, 1997. The NRC
approved the transfer via Amendment No. 2 of the revised License No. SUA-1358. This
amendment was issued to IUC on May 9, 1997.
The mill was actively processing alternate feed material during the inspection.
(Alternate feed material is material other than natural uranium ore.) The licensee is
authorized to receive and process alternate feed materials from four out-of-state firms
by License Conditions 10.6 through 10.13.
ln accordance with License Conditions 10.6 and 10.7, IUC is authorized to process
alternate feed materialfrom Allied Signal. This material, referred to as "CaP (calcium
fluoride), is currently being stockpiled for future processing.
ln accordance with License Conditions 10.10, 10.11 and 10.13, the licensee is receiving
bulk alternate feed materials in soilform from the Ashland 2 Formerly Utilized Sites
RemedialAction Program near Tonowanda, New York, and drummed calcined
byproduct materials from Cameco Corporation's Blind River and Port Hope facilities in
Ontario, Canada. Although the Cameco material is currently being processed, only
fingerprint analysis of the Ashland 2 material is being conducted in preparation for future
processing.
The licensee is also receiving and processing bulk uranium ore from active mines
through private contractors.
Management Organization and Controls (88005)
lnspection Scope
The organizational structure was reviewed to ensure the licensee had established an
effective organization with defined responsibilities and functions and appropriate
controls were in place to ensure compliance with NRC requirements. Also, the
utilization and implementation of the licensee's performance-based license was
reviewed.
Management Organization
The organizational structure requirements are provided in License Condition 9.3, which
references the NRC-approved license renewal application dated January 30, 1997. The
licensee had made no changes to the structure since the previous inspection.
2.2
2.3
-4-
ln summary, the licensee's organizational structure was in agreement with the intent of
License Condition 9.3.
Performance-Based License Review
License Condition 9.4 states that the licensee may, under certain conditions and without
prior NRC approval, make changes in the facility or processes, make changes to
procedures, or conduct tests and experiments not presented in the license application.
The licensee's implementation of the performance-based license provisions was
reviewed to ensure that any changes made by the licensee did not negatively impact the
licensing basis of the site. The NRC granted the licensee a performance-based license
during March 1997.
The licensee's determinations under License Condition 9.4 are required to be made by a
Safety and Environmental Review Panel (SERP). The licensee held three SERP
meetings since the previous inspection as discussed below:
August 3. 1998 - The SERP reviewed two areas:
The utilization of Cell No. 2 for storage of process tailings after dewatering from Cabot
uranium/tantalum ores.
The use of resin lX for the purification and concentrating step in place of liquid lX, or
solvent extraction.
August 21. 1998 - The SERP reviewed two areas:
Formal review and discussion of the Draft Sampling and Analysis Plan ("SAP") for
confirmatory sampling of the Ashland 2 material.
Discussion of the detection of naphthalene in one of the 15 characterization samples
obtained by ICF Kaiser Engineers.
December 2. 1998
The SERP reviewed a modification to the front-end processing procedures of Ashland 2
ore material to incorporate a trommel screening mechanism for gross separation of feed
materials.
All SERP panel conclusions were technically adequate. However, the SERP review
accounting process was in need of improvement. The licensee stated it would develop
a formal indexing and enumeration system.
Site Procedures
ln accordance with License Condition 9.6, SOPs are required to be established and
followed for all operational process activities involving radioactive materials that are
2.4
b.
-5-
handled, processed, or stored. However, the licensee did not follow established SOPs
in three separate occasions as discussed below:
The Health Physics Manual requires personneldonning respiratory protection
equipment to conduct positive or negative face seal checks. Contrary to this
requirement, on March 24, 1999 an individual was observed to have not conducted face
seal checks when using respiratory protection for protection from radionuclides. The
licensee committed to a corrective action to include a review and emphasis of
respiratory protection requirements at the next safety meeting.
The Ore Receiving, Feed and Grinding Manual requires personnelconducting work
under a RWP to sign the permit. Contrary to this, personnelwere simply listed on six
RWPs since the previous inspection. The licensee committed to a corrective action of
supervisory training on the proper use of RWPs at the next daily meeting.
The Emergency Response Plan requires emergency evacuation drills be conducted,
documented and reviewed by management semi-annually. Contrary to this, as of
March 25, 1999, the last drill had been conducted in June 1998, and the last
documented drill had been conducted April29, 1996, with no record of drill reviews
found. The licensee committed to corrective actions of conducting and documenting an
emergency drill in the next 7-10 days, and subsequent timely review by appropriate
management personnel.
The corrective actions committed during the inspection were adequate to resolve this
violation (40-8681 /9901 -01 ).
Conclusions
The licensee had established an organizational structure that agreed with the
requirements of the license. Also, the licensee had correctly implemented the
performance-based conditions of the license. Three examples of failing to follow
procedures were obserued, a violation of License Condition 9.6. The licensee
committed to adequate corrective actions during the inspection.
Radioactive Waste Management (88035)
Inspection Scope
The objective of this portion of the inspection was to verify site activities were being
conducted in accordance with applicable regulations and the conditions of the license,
and to ensure operational controls were adequate to protect the health and safety of the
workers and the members of the general public.
Site Operations
A facility tour was performed to observe activities in progress. Site perimeter postings,
required by License Condition 9.9, were in place at all entrances to the site, although
2.5
3.1
3.2
3.3
-6-
many were faded and in need of replacement. The licensee indicated an intent to
replacing the signs on an as-needed basis. No significant health or safety concern was
identified during the tour.
A review of the licensee's four disposal cells was conducted. Cells 1 and 3 were actively
being used for process solution evaporation and recycling, with Cell3 also used for
disposal of tailings generated onsite and wastes generated offsite (as authorized in
License Condition 10.5). Cell2 was being used for disposal of solid wastes generated
onsite, and was covered as the cell was filled. Any liquid recovered from Cell 2
operations was transferred to Cell 3. Finally, Cell 4 was not in service during the
inspection, receiving only precipitation. Since the cell had multiple tears and channels in
the liner system, the licensee stated that Cell 4 would not be used until the liner is
replaced. No abnormal conditions, such as leaks or berm failures, were observed at
any of the cells during the site tour. An inspection of all.four cells was performed by the
radiation safety technicians.
Radioactive Waste Receipts
License Condition 10.5 authorizes the licensee to dispose of byproduct material
generated at licensed in-situ leach facilities subject to several conditions, including a
5000 cubic yard limit from a single source. The licensee is also required to submit an
annual summary to the NRC of wastes disposed of from off-site generators in
accordance with Condition 10.5.D. The licensee's most current annual summary was
reviewed during the inspection. Eleven shipments from three offsite generators in 1998
and one in 1999 were conducted within the limits of the license.
Conclusions
The licensee appeared to have maintained control of site operations and radioactive
waste receipts in accordance with the conditions of the license and NRC regulations.
No detrimental health or safety issue was identified.
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the conditions of the license as well as the requirements of 10 CFR
Part 20.
Audit Program Review
ln accordance with License Condition 11.6, an annual as low as reasonably
achievable (ALARA) audit of the radiation safety program is required to be performed in
accordance with Regulatory Guide 8.31. The most current audit was found to be
thorough and comprehensive.
3.4
4.1
4.2
-7-
The radiation safety officer's monthly reports were reviewed. These reports are required
by Section 3.6.3, "Monthly Reviews," of the ALARA Program section of the license
application. The reports provided useful information such as in-plant radiological
sampling and survey results.
Finally, the licensee's weekly inspection reports were reviewed. These reports are
required by Section 3.6.2, 'Weekly lnspections," of the license application. No
significant health or safety issue was identified.
4.g Decommissioning Recordkeepinq
ln accordance with 1O CFR Part 40.36(f)(1), records are required to be permanently
maintained, including a description of the restricted area, spills, and any unusual events.
The licensee was noted to be maintaining these records in onsite files, specifically the
"Spill Containment and Countermeasures Plan and Reports" file. Licensee
representatives stated that they had not added any new information to this file since
1 995.
The licensee was operating in compliance with the recordkeeping requirements of 10
CFR Part 40.36.
4.4 Radiation Work Permits
Radiation Work Permit (RWP) requirements are provided in the Health Physics Manual.
The licensee issued six RWPs since the previous inspection. Allwere reviewed, and
were within the scope of the RWP procedure. However, some RWP's were completed
in pencil, allowing smudges and alterations to completed forms. The licensee indicated
that they would have future forms completed in ink. !n addition, a procedural violation;
previously discussed in Section 2.4, was identified for the failure to have workers sign
RWPs prior to performing the work covered by the RWP.
4.5 Bioassay Prooram Review
License Condition 9.6 requires written procedures for a bioassay program. The licensee
had maintained extensive records related to bioassay sampling. During 1998,
220 bioassay samples were obtained from site workers and were analyzed by the onsite
laboratory, including 34 blank and spiked samples for quality control purposes. At least
ten percent of the samples were split and sent to an offsite laboratory for quality
assurance purposes. No sample result exceeded the lowest action level of
15 micrograms of natural uranium per liter of urine.
The sample results for 1998 were compared to 1997 sample results. No individual
exceeded the action level during these years, suggesting that the licensee was
effectively controlling intake of radioactive materials through the use of respirators,
control of the radioactive materials and engineering controls.
4.6
-8-
Respiratory Protection
The respiratory protection program was reviewed during the inspection. Respirators
were maintained in the control room area with smoke tubes to assure proper fit when
donning. However, of three individuals interviewed, one incorrectly stated that a half-
face respirator was appropriate for protection from radionuclides, contrary to site training
protocols. Upon review of various procedures, several examples were found of
inconsistencies of respirator usage. For example, in the Ore Receiving, Feed and
Grinding Manual, a half-face respirator is required during semiautogenous grinding mill
operations, even though this area is posted as an airborne radiation area. The licensee
stated it would review and update procedures to establish consistency for respiratory
requirements. ln addition, a proceduralviolation, previously discussed in Section 2.4,
involved an individual observed not conducting a required face seal check when using a
respirator.
Conclusions
Radiation protection program areas reviewed and found acceptable with the exception
of the noted procedural compliance violations, included audit program review,
recordkeeping of decommissioning activities, radiation work permits, bioassay and
respiratory protection programs.
Environmental Monitoring (88045)
lnspection Scope
The environmental monitoring program was reviewed to assess the effectiveness of the
licensee's program and to evaluate the effects of site activities on the local environment.
Environmental Monitoring Proqram Review
License Condition 11.2 states, in part, that the licensee shall implement the effluent and
environmental monitoring program specified in Section 5.5 of the renewalapplication.
Also, the results of the environmental monitoring program are required to be submitted
to NRC on a semiannual basis in accordance with License Condition 11.3.C. The
semiannual effluent report for the second half of 1998 was reviewed. The 1998 sample
results were compared to those from 1997 to ascertain whether any adverse trends
existed.
Air Particulate Samplino
The licensee collected particulate air samples at four locations around the site. (The
operation of the air sampler at the background station was discontinued by the licensee
with NRC approval several years ago.) The sample filters are required to be changed
weekly, composited quarterly, and analyzed for their natural uranium, radium-226,
thorium-23O, and lead-210 quantities. The sample results were less than 3 percent of
the respective 10 CFR Part 20, Appendix B, effluent concentration limits. Also, the
4.7
5.1
5.2
a.
b.
-9-
laboratory's lower limit of det6ction was equal to or better than the limits specified in
License Condition 1 1.2.D.
The 1998 sample results were compared to those from 1997. Overall, the 1998 sample
results were down from the previous year. Therefore, no adverse trends were noted in
this area of the environmental monitoring program.
Stack Samolino
The licensee is required to sample the stack emissions for natural uranium content on a
quarterly basis during plant operations. Also, sampling for total particulates,
thorium-230, radium-226, and lead-210 content is required on a semiannual basis. ln
addition, License Condition 11.2.A specifically requires the licensee to determine the
stack flow rates.
According to information provided by the licensee, the yellowcake stacks were not used
during the second half of 1998; therefore, stack samples were not obtained during this
time frame.
Ambient External Gamma Exposures
Environmentalgamma thermoluminescent dosimeters (TLDs) were located at allfive
sample stations. The TLDs were changed out and analyzed on a quarterly basis.
The site perimeter sample stations measured an ambient gamma exposure that was
comparable to the background value. Historically, the difference between the site
stations and background rarely exceeded 10 millirems per quarter. The sample results
for 1998 were comparable to those from 1997 and no adverse trend was observed.
Vegetation Sampling
Vegetation samples are required to be obtained three times per year from three
separate locations. The samples were required to be analyzedtor their radium-226 and
lead-210 concentrations. The 1998 sample results showed no increase in radionuclide
concentrations from the 1997 sample results.
Soil Sampling
Soil samples are required to be obtained once each year at all sample stations,
including the background station. The radionuclide concentrations in the soilsamples
were very low, and the site boundary sample results were comparable to the
background value. Also, the 1998 sample results were comparable to those from 1997.
Surface Water Samples
ln accordance with Section 5.5 of the license application, surface water samples are
required to be obtained from two locations. Water samples (or sediment samples if the
streams are dry) are to be obtained annually from Westwater Creek and quarterly from
c.
d.
e.
f.
5.3
g.
a.
.10-
Cottonwood Creek. The samples were analyzed for their natural uranium, radium'226,
and thorium-23o concentrations, as well as for the quantity of total dissolved and
suspended solids.
Sample results were less than 2 percent of the natural uranium effluent concentration
limit specified in Appendix B of Part 20. Also, the 1998 sample results were noted to be
comparable to those from 1997.
The wellwater samples are analyzed for chloride, potassium, nickel, and uranium
concentrations. No trends were observed with the groundwater sample results.
I nstrument Calibrations
Air Sampler Calibration
ln accordance with License Condition 11.2.E, the licensee is required to perform a
semiannual inspection as well as a biennial calibration of the critical orifice assembly.
This device was used to check the accuracy of the environmental air sampler flow rates.
Records for inspection and calibration of the critical orifice assembly were reviewed, as
well as calibration records for the air sampling pumps. Although the orifice assembly
was due for calibration in February 1999, the licensee had used it for calibrating
environmental air sampling pumps in March 1999, two weeks overdue. This finding was
determined to be a violation of minor significance and was therefore not cited. The
licensee committed to getting the orifice calibrated and the environmentalair sampling
pumps recalibrated in a timely manner.
! nstrument Calibrations
The Health Physics Manualstates all radiation and environmental monitoring, sampling,
and detection equipment shall be recalibrated after repair and as recommended by the
manufacturer or at least annually, whichever is more frequent. The licensee's
calibration records and availability of equipment were reviewed. The licensee had
maintained calibrated equipment available for use, and had maintained records
indicating all equipment was routinely calibrated.
Conclusions
A thorough review of the licensee's implementation of the environmental monitoring
program requirements was performed. The licensee had used an out-of-calibration
orifice to calibrate the environmental air sampling pumps, but had committed to orifice
calibration and pump recalibration in a timely manner. The licensee was noted to be
collecting all samples required by the license at the intervals specified in the license, and
reporting these sample results in their 1998 semiannual effluent report. All sample
results were less than the associated limits specified in 10 CFR Part 20 during 1998.
When the 1998 data was compared to the 1997 sample results, no adverse trend was
identif ied.
b.
5.4
6.1
-1 1-
Followup (92701)
NRC lnformation Notice 96-70: Year 2000 Effect on Computer System Software
This Notice was issued to alert licensees of the potential problems that may occur with
their computer systems and associated software as a result of the upcoming change to
the new century. During this inspection, the licensee's actions taken in response to this
NRC lnformation Notice were reviewed. ln summary, the licensee had established that
there were no operational equipment controllers affected by the Year 2000 effect.
NRC Information Notice 99-03: Exothermic Reactions lnvolving Dried Uranium Oxide
Powder (Yellowcake)
This lnformation Notice was issued to alert licensees to the potentialfor drummed
yellowcake to react with hydrocarbons and generate excessive pressures. ln two cases,
excessive pressures were generated in drummed yellowcake from the generation of
orygen from the breakdown of process hydrogen peroxide. ln two additional cases,
hydrocarbon contaminants were introduced into the processes and packaged with the
yellowcake. Subsequent reactions generated excessive heat and gas production.
The licensee's actions taken in response to lnformation Notice 99-03 were reviewed.
The licensee was aware of the oxygen generation problem at other facilities and had
trained dryer operators to incorporate a cool-down period prior to package sealing;
therefore, the licensee had taken the appropriate corrective actions in relation to the
lnformation Notice.
The licensee was also aware of the hydrocarbon contaminant problem. The licensee
stated visual inspections of the processed yellowcake are performed while the product is
being packaged. The licensee planned to take no further specific action related to the
hydrocarbon contaminant incidents discussed in the lnformation Notice.
Exit Meeting Summary
The inspector presented the preliminary inspection results to the representatives of the
licensee at the conclusion of the inspection on March 25, 1999. Licensee
representatives acknowledged the findings as presented. The licensee did not identify
any information reviewed by the inspector as propriety information.
6.2
7
a
Attachment 1
PARTIAL LIST OF PERSONS CONTACTED
Licensee
H. Roberts, Executive Vice-President
R. Berg, Radiation Safety Otficer
W. Deal, MillManager
M. Rehmann, Environmental Manager
State of Utah
G. Ripley, Environmental Scientist, Division of Radiation Control
Environmental Protection Aqency
R. Graham, Health PhysicisUEco-Toxicologist, Office of Pollution Prevention - Toxicology
T. Brown, Environmental Engineer, Pollution-Hazardous Waste
INSPECTION PROCEDURES USED
83822 Radiation Protection88005 Management Organization and Controls88035 Radioactive Waste Management88045 Environmental Monitoring92701 Followup
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
40-8681/9901-01 VIO failure to follow procedures
Closed
None
Discussed
NRC lnformation Notice 96-70: Year 2000 Effect on Computer System Software
NRC lnformation Notice 99-03: Exothermic Reactions lnvolving Dried Uranium Oxide Powder
(Yellowcake)
LIST OF ACRONYMS USED
ALARA as low as reasonably achievableCaF calcium fluorideCFR Code of Federal RegulationsPDR Public Document RoomRWP radiation work permitSERP Safety and Environmental Review PanelSOP Standard Operating ProcedureTLD thermoluminescent dosimeters
IurrnNerro*oD
UneNruvr (use)
ConponATroN
IndependencePlaza, Suite 950 o 1050 Seventeenth Street . Denver, CO 80265 o 303 628 7798 (main) o 303 389 al25 (fax)
July 17, 1998
Bill Sinclair, Director
Utah Department of Environmental Qulaity
Director of Radiation Control
P.O. Box 144850
Salt Lake City, UT 84114-4850
Dear Mr. Sinclair:
Attached for your information is a copy of the July 9, 1998
Commission ("NRC") on the second NRC inspection for
report from the U.S. Nuclear Regulatory
1998 of the White Mesa Mill.
, r. -.]-it
4
'JU[ Iggg i
,ft6at.(lt riv::tco ol
"Er#fl'
Sincerely yours,
\
)
/z-zta
Michelle R. Rehmann
Environmental Manager
MRR/tay
Enclosure: NRC inspection report 40-686198-02
+t*;r
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DBIVE. SUITE .1OO
AFLINGTON, TEXAS 7601 1.8064
-:_-+-:i.
j_
JUL 1 3 tggg
--!
July 9, 1998
Harold R. Roberts, Executive Vice-President
lnternational Uranium (USA) Corporation
!ndependence Plaza, Suite 950
1050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681/98-02
Ig:
t 't' /'
trTtr
Dear Mr. Roberts:
This refers to the inspection conducted on June 9 -11, 1998, at your Wtite Mesa Mill near
Blanding, Utah. The purpose of this inspection was to determine if activities were being
conducted in accordance with NRC regulations and your license which authorizes uranium
milling operations and 11e.(21byproduct material disposal. The enclosed report presents the
results of that inspection.
The inspection disclosed that site operations were being conducted in accordance with NRC
regulations.' The facility was properly staffed, and plant operations, radiation protection,
radioactive waste management, and environmental protection programs had been properly
implemented.
ln accordance with 10 CFR 2.790 of the NRC's 'Rules of Practice,' a copy of this letter and its
enclosure will be placed in the NRC Public Document Room.
Should you have any questions conceming this inspection, please contact Mr. Louis C. Carson ll
at [phone]or Mr. Charles Cain at [phone].
Scarano, Director
of Nuclear Materials Safety
Docket No. 40-8681
License No. SUA-1358
Enclosure:
NRC lnspection Report 40-8681/98-01
Sincerely,
Rdss A.
lnternational Uranium (USA) Corp. -2'
cc w/enclosure:
Mr. William Deal, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Mr. \A/illiam J. Sinclair, Director
Utah Department of Environmenta! Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
ENCLOSURE
U.S. NUCLEAR REGUI-ATORY COMMISSION
REGION IV
Docket No. 40-8681
License No. SUA-1358
Report No. 40-8681/98-02
Licensee: lnternational Uranium (USA) Corporation (lUC)
Facility: \l1/ttite Mesa Mill
Location: San Juan County, Utah
Dates: June 9 -1 1, 1998
lnspector: Louis C. Carson ll, Health Physicist
Nuclear Materials Safety Branch 1
Division of Nuclear Materials Safety
Region lV
Approved By: Charles L. Cain, Chief
Nuclear Materials Safety Branch 1
Division of Nuclear Materials Safety
Region lV
Attachment Supplementary lnformation
-2-
EXECUTIVE SUMMARY
lnternational Uranium (USA) Corporation
NRC lnspection Report 40-8681 /98-02
This inspection included a review of site status, management organization and controls, site
operations, radioactive waste management, radiation protection, and environmental protection
programs.
Site Status and Operations Review
. The site was being maintained in accordance with the NRC license and applicable NRC
regulations for uranium mill sites (Section 1).
. Site security, perimeter postings and security of licensed material were found to be
maintained as required by License Condition 9.9, 10 CFR 20.1801, and
10 CFR 20.1902(e) (Section 1).
Management Organization and Controls
. The licensee had established an organizational structure that agreed with the conditions
of the license. Also, the licensee had established a procedures improvement program
(Section 2).
Radiation Protection
. The licensee had implemented a radiation protection program that was found to be in
accordance with requirements established in 10 CFR Parts 19 and 20 and the license
(Section 3).
. Areas of the radiation protection program that were reviewed and found to be acceptable
included worker occupational dose determination, radiation work permit implementation,
bioassay program, and the respiratory protection program (Section 3).
Radioactive Waste Management
. Radioactive waste management activities were being conducted safely and in
accordance with the conditions of the license as well as NRC regulations (Section 4).
Environmental Protection
. A review of the licensee's environmental monitoring program and the licensee's
semiannual effluent report for the second half of 1997 indicated that the licensee was in
compliance with license requirements and 10 CFR 40.65. All sample results were less
than the associated effluent release limits specified in 10 CFR Pxl20 during 1997, and
no adverse trends were identified (Section 5).
1
1.'.l
-3-
Report Details
Site Status and Operations Review (88020)
Scope
On May 10, 1997, Source Material License No.1358 was transfened to lUC to operate
the Write Mesa uranium mill and 11e.(2) byproduct disposal site. The NRC inspector
reviewed the site status and the state of operations to determine: (1) if licensed activities
were being conducted in accordance with the IUC license and applicable NRC
regulations for uranium mill sites and (2) that operational controls were adequate to
protect the health and safety of the workers and the members of the general public.
Observations and Findings
The Write Mesa Mill is capable of producing 2,000 tons of yellowcake per day. During
this inspection, the millwas shut down and in an outage. On April 3, 1998, the license
ceased processing Cabot altemate feed material. Altemate feed material is material
other than uranium ore. License Conditions (LC) 10.6 through 10.9 authorize receipt and
processing of four altemate feed materials from three out-of-state firms. The licensee
plans to resume processing the Cabot material and conventional uranium ore material
from Colorado during July 1998. The licensee has not produced any yellowcake since
January 1998. The site also produces other nonradiological products such as vanadium.
Additionally, the \Mrite Mesa facility recycles altemate feed material in order to recover
uranium, vanadium, and tantalum.
During this inspection, the licensee was performing maintenan@ on uranium mill
equipment and conducting housekeeping around the millsite during the outage. The
most significant maintenance activity involved the replacement of the liner material in the
semiautogenous grinding (SAG) mill.
A facility tour was performed to observe activities in progress. Site perimeter postings,
required by LC 9.9 and 10 CFR 20.1902(e), were noted to be in place at allentrances to
the site. Site security was maintained by keeping the site ac@ss gate closed to prevent
unauthorized access to the property. No significant health or safety concems were
identified during the tour. The inspector concluded that licensed materialwas secure
within the site property as required by 10 CFR 20.1801.
Conclusion
The site was being maintained in accordance with the IUC license and applicable NRC
regulations for uranium mill sites. Site security, perimeter postings and security of
licensed materialwere found to be maintained as required by License Condition 9.9,
10 CFR 20.1801, and 10 CFR 1902(e). No significant health or safety concems were
identified.
1.2
1.3
2
2.1
.4-
Management Organization and Controls (88005)
lnspection Scope
The inspector reviewed the licensee's organization structure and management controls
to determine: (1) whether functional responsibilities and personnel qualifications had
been ctearly established and fulfilled in accordance with the conditions of the license,
and (2) what controls were in place to ensure compliance with NRC requirements.
Management Organization
The organizational structure requirements are provided in LC 9.3. Also, the licensee
provided details of its organizational structure to the NRC by a letter dated
January 30,1997. The onsite staff consisted of 95 individuals and six contractors.
The inspector determined that the licensee's organization and staff remained consistent
with the license (Figure 3.1, '\Mrite Mesa Uranium MillOrganizationalChart').
Site Procedures and Procedure Revisions
ln accordance with LC 9.6, standard operating procedures (SOPs) are required to be
established and followed for all operationa! process activities involving radioactive
materials that are handled, processed, or stored. Additionally, written procedures must
be established for nonoperational activities to include in-plant and environmental
monitoring, bioassay analyses, and instrument calibrations. An uptodate copy of each
applicable written procedure must be kept in the mill.
The inspector noted that LC 9.6 requires that the RSO review and approve in writing al!
operational and nonoperationa! procedures before implementation and whenever a
change had been proposed to assure that proper radiation protection practices were
applied. Additionally, the RSO is required to perform a documented review of all
operating procedures annually. The inspector found that reviews were being conducted.
The inspector reviewed the following procedures:
a
a
a
a
a
a
SERP
Millequipment SOPs
Bioassays
Environment Protection
Respiratory Protection
Radiation Work Permits (RWP)
The licensee's implementation of the performance-based license provisions was
reviewed to ensure that any changes made by the licensee did not negatively impact the
licensing basis of the site. The NRC granted the licensee a performance-based license
in March 1997. LC 9.4 allows the licensee, under the direction of the Safety and
Environmental Review Panel (SERP), to make changes in the facility or processes, make
2.2
2.3
2.4
changes to procedures, or conduct tests and experiments not presented in the license
application without prior NRC approval.
Although the licensee had a SERP procedure for implementing LC 9.4, the procedure
neither established SERP meeting frequencies nor set requirements for maintaining
meeting records and distributing meeting minutes to responsible personnel. Additionally,
provisions were not made for resolving SERP identified concems. The corporate RSO
and the mill manager were members of the SERP, and the site RSO was the chairman of
the site As Low As is Reasonably Achievable (ALARA) Committee. The licensee, under
the direction of the SERP, had undertaken an extensive site procedures revision
program since the last inspection. The licensee had contracted a consultant to rewrite
\Mrite Mesa procedures by August 1998. The licensee planned to have all revised
procedures reviewed by the SERP. Additionally, the licensee stated that it would
evaluate the need for detailed management procedures for goveming the SERP, the
AI,ARA committee, administrative control, problem identification, and quality assurance
matters.
The environmental protection procedures and mill equipment SOPs were in draft form
and were scheduled to be reviewed and approved by the SERP in the following weeks.
The inspector found that those revised procedures represented a substantial
improvement from the site's cunent procedures. However, many radiation protection
procedures had not been revised and needed updating. For example, IUC had not
developed specific procedures for RWPs or for the respiratory protection program. The
bioassay procedure had not been updated with the cunent methods used to analyze
bioassays. The SERP had not formally reviewed the results of the bioassay program
changes. The inspector also observed that development of \Mite Mesa procedures was
not controlled by any administrative program. ln some instances, White Mesa staff were
still using radiation protection procedures that were written by a previous owner.
No violations were identified during the inspection. However, weaknesses noted above
were being addressed by the licensee as a part of the procedures improvement program.
Nonetheless, the inspector determined that IUC was raising the quali$ standards of the
\Mrite Mesa operation by the procedures improvement program and concluded that the
licensee was in compliance with LC 9.6.
Conclusions
The licensee had maintained organization and staff that agreed with the requirements of
the license. The licensee's SERP procedure improvement program enhanced the quality
standard of the Write Mesa operation and was found to be in compliance with LC 9.6.
3
3.1
.6-
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the conditions of the license as wellas the requirements of 10 CFR
Part 20.
Observations and Findings
Occupational Radiation Exposures
The licensee's intemal and external radiation exposure programs were reviewed. The
inspeclor also reviewed personnel exposures associated with the SAG mill repair project.
The licensee's program included the issuance of thermoluminescent dosimeters (TLD),
sampling for airborne radioactivity using high volume air samplers and lapel air samplers,
and use of urine bioassays. The licensee reported occupational radiation exposures
(total effective dose equivalent) based on TLD and air sample results. Bioassay results
were used to validate the air sampling program. The licensee maintained each worke/s
exposure data in a detailed, computerized spreadsheet that included allthe worke/s air
sampling data, exposure time, and applicable derived air concentrations (DAC) for
specific locations in the facility.
During 1997 the licensee had issued 121 TLDs to workers. Five workers had extemal
exposures between 250 and 750 millirems, 9 workers had exposures between 100 and
249 millirems, and 107 workers had extemal radiation exposures of less than
100 millirems. During 1997, the highest committed effective dose equivalent was 950
millirems. The inspector determined that occupational exposures during 1997 were less
than the 5000 millirems annual limit in 10 CFR 20.1201.
The inspector examined intemalexposure records associated with the SAG mill project.
Air sampling records indicated that uranium-238 airbome concentrations inside of the
SAG mill had been measured as high as 892 percent (5.35E-10 microcuries per cubic
centimeter (UCi/cc)) of the DAC value in late May 1998 and 551 percent
(3.31E-10 UCUcc) of the DAC value in June 1998. The DAC value for uranium-238 in air
is 6.0E-11 pCi/cc. The inspector reviewed the air sample analysis, worker residence
times, protective measures, and internal exposure calculations for 12 SAG mill project
workers. At the time of the inspection, SAG millworkers were being issued full-face
respirators with a protection factor (PF) of 50. Early in the project, workers had been
issued positive air supply respirator protection with a PF of 1000. The inspector
determined that the licensee's calculations of potentialworker intemal exposure were
adequate. lnternalexposures were found to be well below regulatory limits because the
licensee had utilized respiratory protection equipment that was consistent with airbome
concentrations inside the SAG mill .
3.2
d.
-7-
Radiation Work Permits
The inspector reviewed the licensee's radiation work permit (RWP) program. The
inspector noted that many of the licensee's procedures required that workers obtain an
RWP from the radiation protection staff prior to performing work with a significant
potential for radiological exposure. The inspector noted, however, that the licensee had
not established a specific procedure for R\A/Ps. Some general instructions for RWPs
were located in Section 3.5.2 of the ALARA program that was written by the previous
owner.
The SAG mill repair projed was undenivay at the time of the inspection and was being
conducted under RWPs-330 and 331. The inspector reviewed RWPs and found that
both RWPs included the following elements: job description, requirements for
radiological monitoring and sampling protective equipment, respiratory protection
equipment, ALARA considerations, and a listing of personnelwho were assigned to the
RWP. The inspeclor's observation of workers performing the SAG mill project revealed
that the workers were complying with RWP instructions. The inspector determined that
the RWP instructions were adequate to preclude unnecessary personnel exposures.
Bioassays
The inspector reviewed the licensee's bioassay program. The licensee primarily used
urinalysis on a monthly basis for uranium bioassay. However, for workers involved in
work under certain RWPs, additionalsamples were required. According to the license
application, the licensee analyzed urine samples by in-house fluorometrics, but the
inspector found that they stopped using fluorometric analysis as the principal analytical
method in February 1998. According to the licensee, the fluorometric analysis
equipment was obsolete, no longer reliable, and replacement parts were hard to procure.
Therefore, the chemistry department started using an inductively coupled plasma mass
spectrometer (|CP-MS) for urinalysis. The licensee showed the inspector that ten
percent of the urinalysis samples were sent to a certified laboratory as part of their quality
control (QC) program.
The inspector reviewed the licensee's reports of investigations into potentially elevated
bioassay results from 1997 and 1998. The licensee's bioassay investigation levelwas
15 micrograms per liter. The licensee had investigated bioassay results that were
analyzed during the transition from the fluorometric method to the ICP-MS method.
Based on the inspector's reviews and comparisons of ICP-MS, flurometric, and QC
bioassay results, the inspector determined that the licensee's bioassay program was in
compliance with license requirements.
Respiratory Protection Program
The inspector reviewed the licensee's respiratory protection program. The inspector
observed workers wearing full-face respirators and half-face respirators during the SAG
mill project. According to the RSO, the licensee did not take credit for the half-face
respiratory PF during radiological work. However, credit was taken for use of full-face
3.3
-8-
and positive air supply respirators during radiological work that had a significant potential
for exposure like the SAG mill project.
The inspector found that the site maintained the respiratory protection program manual
from a previous owner. The inspector reviewed the training records and medical
certification records for some of the employees that had been issued respiratory
protection equipment. The records certified allthe workers who were qualified to wear
respiratory protection equipment. The inspector toured the area where the licensee
maintained and issued respiratory protection equipment. The inspector determined that
the licensee's respiratory protection program was adequate, and the selection of
respiratory protection equipment was deemed appropriate for airbome concentrations in
the mill.
Conclusions
The licensee had implemented a radiation protection program that was found to be in
accordance with requirement established in 10 CFR Parts 19 and 20 and the license.
Areas of the radiation protection program that were reviewed and found to be acceptable
included worker occupationaldose determination, radiation work permit implementation,
bioassay program, and the respiratory protection program.
Radioactive Waste tanagement (88035)
lnspection Scooe
The objective of this portion of the inspection was to verify that site radioactive waste
management activities were being conducted in accordance with applicable regulations
and the conditions of the license, and to ensure that controls were adequate to protect
the health and safety of the workers and the members of the general public.
Observations and Findings
During the site tour, the licensee's disposal cells were observed and found to be
processing liquid waste through evaporation and recycling. No abnormal conditions,
such as leaks or berm failures, were observed at any of the cells during the site tour.
LC 10.5 authorizes the licensee to dispose of byproduct material generated at licensed
in-situ leach facilities subject to several conditions, including a 5000 cubic yard limit from
a single source. The licensee is also required to submit an annual summary to the NRC
of waste disposed of from off-site generators in accordance with LC 10.5(D). The
licensee's most cunent annual summary dated April6, 1998, was reviewed by the
inspector. This document summarized the waste received during 1997 from offsite
waste generators. The total amount of waste received was within the limit specified in
the license.
4
4.1
4.2
4.3
-9-
Conclusions
The licensee appeared to have maintained radioactive waste in accordance with the
license and NRC regulations. No health or safety issues were identified.
Environmental Monitoring (88045)
lnspection Scooe
The environmental monitoring program was reviewed to assess the effectiveness of the
licensee's program and to evaluate the effects of site activities on the local environment.
Observations and Findings
Environmental Monitoring Program Overview
LC 11.2 states that the licensee shall implement the effluent and environmental
monitoring program specified in Section 5.5 of the renewal application. Also, the results
of the environmental monitoring program are required to be submitted to NRC on a
semiannual basis in accordance with LC 11.3(C) and 10 CFR 40.65. The semiannual
effluent report for the second half of 1997 was submitted to the NRC on March 2, 1998,
and reviewed during this inspection. The results of the 1997 effluent report were
compared to the 1996 reports to ascertain whether any adverse trends existed.
Air Particulate Sampling
The licensee collected particulate air samples at four locations around the site. Sample
filters were required to be changed weekly and analyzed for natural uranium,
radium-226, thorium-23O, and lead-210 quantities. Sample results for the second half of
1997 were reviewed. Sample results were less than 7 percent of the respective 10 CFR
Part 20, Appendix B, effluent concentration limits. Also, the laboratory's lower limit of
detection was equal to or better than the limits specified in LCl1.2(D). The 1997 sample
results were compared to the 1996 sample results, and no adverse trends were noted in
this area of the environmental monitoring program.
Stack Sampling
The licensee is required to sample the stack emissions for natural uranium content on a
quarterly basis during plant operations. Sampling for total particulates, thorium-230,
radium-226, and lead-210 content is required on a semiannual basis. Also, LC 11.2(A)
requires the licensee to determine the stack flow rates. Yellowcake stacks were in
service during the second half of 1997 and were sampled. The licensee also reported
the results of stack samples in the semiannual effluent report for the second half of 1997.
The inspector determined that licensee calculation of stack flowrates, radioactive
material release rates, and radioactive material concentrations were performed
adequately.
5
5.1
5.2
d.
10-
Ambient External Gamma Exoosures
Environmental TLDs were located at five sample stations. One duplicate sample was
used at one station for quality control purposes. The TLDs were replaced and analyzed
on a quarterly basis. The sample results for 1997 were reviewed during the inspection.
The TLD ambient gamma exposure measurements were comparable to the background
radiation and were comparable to the 1996 TLD results. No adverse trend was
observed.
Surface Water and Groundwater Samples
Section 5.5 of the license application requires surface water samples to be obtained from
two locations. Quarterly samples had been collected from Westwater Canyon and
Cottonwood Creek. The samples were analyzed for natural uranium, radium-226, and
thorium-230 concentrations, as well as for the quantity of total dissolved and suspended
solids. Sample results were found to be less than the natural uranium effluent
concentration limit specified in Appendix B of 10 CFR Part 20. Also, the 1997 sample
results were noted to be comparable to the 1996 sample results.
LC 11.3(C) requires monitoring wells to be sampled quarterly and analyzed for chloride,
potassium, nickel, and uranium concentrations. The sample results for the fourth quarter
of 1997 were reviewed. The highest natural uranium concentration (0.05 milligrams per
liter) was measured in a sample obtained from well MW-14. There were no deleterious
trends.
Conclusions
A review of the licensee's environmental monitoring program and 10 CFR 40.65 report
indicated that the licensee was in compliance with license requirements.
Exit Meeting Summary
The inspector presented the preliminary inspection results to licensee representatives
at the conclusion of the inspection on June 1 1, 1998. Licensee representatives
acknowledged the findings as presented. The licensee did not identify any information
reviewed by the inspector as propriety information.
e.
5.3
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Berg, Radiation Safety Officer (RSO)
W. Deal, Mill Manager
W. Palmer, Radiation Technician
M. Rehmann, Environmental Manager and Corporate RSO
INSPECTION PROCEDURES USED
lP 83822 Radiation ProtectionlP 88005 Management Organizational ControlslP 88020 Operations ReviewlP 88035 Radioactive Waste ManagementlP 88045 Environmental Monitoring
ITEIf,S OPENED. CLOSED AND DISCUSSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYTS USED
AI-ARA As Low As Reasonably Achievable
Code of Federal Regulations
derived air concentrationICP-MS inductively coupled plasma mass spectrometer
lntemational Uranium (USA) Corporation
license condition
monitoring well
protection factor
quality control
radiation safety officer
radiation work permit
semiautogenous grinding
Safety and Environmental Review Panel
Standard Operating Procedure
Thermoluminescent Dosimeter
CFR
DAC
tuc
LC
MW
PF
QC
RSO
RWP
SAG
SERP
SOP
TLD
o
NU
a
N
UNITED STATES
CLEAR REGULATORY COMMISSIO
BEGTOil
"'':1i RYAII PLAZA DPIT'E SiTITE.:CC
AirLlllGTOll rEXAS -rC11 o06.1
JuIy 9, 1998
b
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^,o.a-ii', :
't::l:l$
Harold R. Roberts, Executive Vice-President
lnternational Uranium (USA) Corporation
lndependence Plaza, Suite 950
1 050 Seventeenth Street
Denver, Colorado 80265
SUBJECT: NRC INSPECTION REPORT 40-8681198-02
Dear Mr. Roberts:
This refers to the inspection conducted on June I -1 1 , 1998, at your White Mesa Mill near
Blanding, Utah. The purpose of this inspection was to determine if activities were being
conducted in accordance with NRC regulations and your license which authorizes uranium
milling operations and 11e.(2) byproduct material disposal. The enclosed report presents the
results of that inspection.
The inspection disclosed that site operations were being conducted in accordance with NRC
regulations.' The facility was properly staffed, and plant operations, radiation protection,
radioactive waste management, and environmental protection programs had been properly
implemented.
ln accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be placed in the NRC Public Document Room.
Should you have any questions concerning this inspection, please contact Mr. Louis C. Carson ll
at [phone] or Mr. Charles Cain at [phone].
Rdss A. Scarano, Director
Division of Nuclear Materials Safety
Docket No. 40-8681
License No. SUA-1358
Enclosure:
NRC lnspection Report 40-8681/98-01
Sincerely,
lnternational Uranium (USA) Corp. -2-
cc Wenclosure:
Mr. William Deal, Mill Manager
lnternational Uranium (USA) Corp.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Mr. William J. Sinclair, Director
Utah Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, Utah 84115-4850
Mr. Pat Mackin, Assistant Director
Systems Engineering & lntegration
Center for Nuclear Waste Regulatory Analyses
6220 Culebra Road
San Antonio, Texas 78238-5166
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No. 40-8681
License No. SUA-1358
Report No. 40-8681/98-02
Licensee: lnternational Uranium (USA) Corporation (lUC)
Facility:White Mesa Mill
Location: San Juan County, Utah
Dates:June 9 -11, 1998
lnspector: Louis C. Carson ll, Health Physicist
Nuclear Materials Safety Branch 1
Division of Nuclear Materials Safety
Region lV
Approved By: Charles L. Cain, Chief
Nuclear Materials Safety Branch 1
Division of Nuclear Materials Safety
Region lV
Attachment: Supplementary lnformation
-2-
EXECUTIVE SUMMARY
lnternational Uranium (USA) Corporation
NRC lnspection Report 40-8681/98-02
This inspection included a review of site status, management organization and controls, site
operations, radioactive waste management, radiation protection, and environmental protection
programs.
Site Status and Operations Review
. The site was being maintained in accordance with the NRC license and applicable NRC
regulations for uranium mill sites (Section 1).
. Site security, perimeter postings and security of licensed material were found to be
maintained as required by License Condition 9.9, 10 CFR 20.1801, and
10 CFR 20.1902(e) (Section 1).
Manaoement Oroanization and Controls
. The licensee had established an organizational structure that agreed with the conditions
of the license. Also, the licensee had established a procedures improvement program
(Section 2).
Radiation Protection
. The licensee had implemented a radiation protection program that was found to be in
accordance with requirements established in 10 CFR Parts 19 and 20 and the license
(Section 3).
. Areas of the radiation protection program that were reviewed and found to be acceptable
included worker occupational dose determination, radiation work permit implementation,
bioassay program, and the respiratory protection program (Section 3).
Radioactive Waste Management
. Radioactive waste management activities were being conducted safely and in
accordance with the conditions of the license as well as NRC regulations (Section 4).
Environmental Protection
. A review of the licensee's environmental monitoring program and the licensee's
semiannual effluent report for the second half of 1997 indicated that the licensee was in
compliance with license requirements and 10 CFR 40.65. All sample results were less
than the associated effluent release limits specified in 10 CFR Part 20 during 1997, and
no adverse trends were identified (Section 5).
1.1
-3-
Report Details
Site Status and Operations Review (88020)
Scope
On May 10, 1997, Source Material License No.1358 was transferred to IUC to operate
the White Mesa uranium mill and 11e.(2) byproduct disposal site. The NRC inspector
reviewed the site status and the state of operations to determine: (1) if licensed activities
were being conducted in accordance with the IUC license and applicable NRC
regulations for uranium mill sites and (2) that operational controls were adequate to
protect the health and safety of the workers and the members of the general public.
Observations and Findings
The White Mesa Mill is capable of producing 2,000 tons of yellowcake per day. During
this inspection, the millwas shut down and in an outage. On April 3, 1998, the license
ceased processing Cabot alternate feed material. Alternate feed material is material
other than uranium ore. License Conditions (LC) 10.6 through 10.9 authorize receipt and
processing of four alternate feed materials from three out-of-state firms. The licensee
plans to resume processing the Cabot material and conventional uranium ore material
from Colorado during July 1998. The licensee has not produced any yellowcake since
January 1998. The site also produces other nonradiological products such as vanadium.
Additionally, the White Mesa facility recycles alternate feed material in order to recover
uranium, vanadium, and tantalum.
During this inspection, the licensee was performing maintenance on uranium mill
equipment and conducting housekeeping around the mill site during the outage. The
most significant maintenance activity involved the replacement of the liner material in the
semiautogenous grinding (SAG) mill.
A facility tour was performed to observe activities in progress. Site perimeter postings,
required by LC 9.9 and 10 CFR 20.1902(e), were noted to be in place at all entrances to
the site. Site security was maintained by keeping the site access gate closed to prevent
unauthorized access to the property. No significant health or safety concerns were
identified during the tour. The inspector concluded that licensed material was secure
within the site property as required by 10 CFR 20.1801 .
Conclusion
The site was being maintained in accordance with the IUC license and applicable NRC
regulations for uranium mill sites. Site security, perimeter postings and security of
licensed materialwere found to be maintained as required by License Condition 9.9,
10 CFR 20.1801 , and 10 CFR 1 902(e). No significant health or safety concerns were
identified.
1.2
1.3
-4-
2 Management Organization and Gontrols (88005)
2.1 lnspection Scope
The inspector reviewed the licensee's organization structure and management controls
to determine: (1) whether functional responsibilities and personnel qualifications had
been clearly established and fulfilled in accordance with the conditions of the license,
and (2) what controls were in place to ensure compliance with NRC requirements.
2.2 Management Organization
The organizational structure requirements are provided in LC 9.3. Also, the licensee
provided details of its organizational structure to the NRC by a letter dated
January 30,1997. The onsite staff consisted of 95 individuals and six contractors.
The inspector determined that the licensee's organization and staff remained consistent
with the license (Figure 3.1, "White Mesa Uranium Mill Organizational Chart").
2.3 Site Procedures and Procedure Revisions
ln accordance with LC 9.6, standard operating procedures (SOPs) are required to be
established and followed for all operational process activities involving radioactive
materials that are handled, processed, or stored. Additionally, written procedures must
be established for nonoperational activities to include in-plant and environmental
monitoring, bioassay analyses, and instrument calibrations. An up-to-date copy of each
applicable written procedure must be kept in the mill.
The inspector noted that LC 9.6 requires that the RSO review and approve in writing all
operational and nonoperational procedures before implementation and whenever a
change had been proposed to assure that proper radiation protection practices were
applied. Additionally, the RSO is required to perform a documented review of all
operating procedures annually. The inspector found that reviews were being conducted.
The inspector reviewed the following procedures:
. SERP. Mill equipment SOPs. Bioassays. Environment Protection. Respiratory Protection. Radiation Work Permits (RWP)
The licensee's implementation of the performance-based license provisions was
reviewed to ensure that any changes made by the licensee did not negatively impact the
licensing basis of the site. The NRC granted the licensee a performance-based license
in March 1997. LC 9.4 allows the licensee, under the direction of the Safety and
Environmental Review Panel (SERP), to make changes in the facility or processes, make
2.4
tr
changes to procedures, or conduct tests and experiments not presented in the license
application without prior NRC approval.
Although the licensee had a SERP procedure for implementing LC 9.4, the procedure
neither established SERP meeting frequencies nor set requirements for maintaining
meeting records and distributing meeting minutes to responsible personnel. Additionally,
provisions were not made for resolving SERP identified concerns. The corporate RSO
and the mill manager were members of the SERP, and the site RSO was the chairman of
the site As Low As is Reasonably Achievable (ALARA) Committee. The licensee, under
the direction of the SERP, had undertaken an extensive site procedures revision
program since the last inspection. The licensee had contracted a consultant to rewrite
White Mesa procedures by August 1998. The licensee planned to have all revised
procedures reviewed by the SERP. Additionally, the licensee stated that it would
evaluate the need for detailed management procedures for governing the SERP, the
ALARA committee, administrative control, problem identification, and quality assurance
matters.
The environmental protection procedures and mill equipment SOPs were in draft form
and were scheduled to be reviewed and approved by the SERP in the following weeks.
The inspector found that those revised procedures represented a substantial
improvement from the site's current procedures. However, many radiation protection
procedures had not been revised and needed updating. For example, IUC had not
developed specific procedures for RWPs or for the respiratory protection program. The
bioassay procedure had not been updated with the current methods used to analyze
bioassays. The SERP had not formally reviewed the results of the bioassay program
changes. The inspector also observed that development of White Mesa procedures was
not controlled by any administrative program. ln some instances, White Mesa staff were
still using radiation protection procedures that were written by a previous owner.
No violations were identified during the inspection. However, weaknesses noted above
were being addressed by the licensee as a part of the procedures improvement program.
Nonetheless, the inspector determined that IUC was raising the quality standards of the
White Mesa operation by the procedures improvement program and concluded that the
licensee was in compliance with LC 9.6.
Conclusions
The licensee had maintained organization and staff that agreed with the requirements of
the license. The licensee's SERP procedure improvement program enhanced the quality
standard of the White Mesa operation and was found to be in compliance with LC 9.6.
3.1
-6-
Radiation Protection (83822)
lnspection Scope
Portions of the licensee's radiation protection program were reviewed to verify
compliance with the conditions of the license as well as the requirements of 10 CFR
Parl20.
Observations and Findings
Occupational Radiation Exposures
The licensee's internal and external radiation exposure programs were reviewed. The
inspector also reviewed personnel exposures assoclated with the SAG mill repair project.
The licensee's program included the issuance of thermoluminescent dosimeters (TLD),
sampling for airborne radioactivity using high volume air samplers and lapel air samplers,
and use of urine bioassays. The licensee reported occupational radiation exposures
(total effective dose equivalent) based on TLD and air sample results. Bioassay results
were used to validate the air sampling program. The licensee maintained each worker's
exposure data in a detailed, computerized spreadsheet that included all the worker's air
sampling data, exposure time, and applicable derived air concentrations (DAC) for
specific locations in the facility.
During 1997 the licensee had issued 121 TLDs to workers. Five workers had external
exposures between 250 and 750 millirems, 9 workers had exposures betwelen 100 and
249 millirems, and 107 workers had external radiation exposures of less than
100 millirems. During 1997, the highest committed effective dose equivalent was 950
millirems. The inspector determined that occupational exposures during 1997 were less
than the 5000 millirems annual limit in 10 CFR 20.1201.
The inspector examined internal exposure records associated with the SAG mill project.
Air sampling records indicated that uranium-238 airborne concentrations inside of the
SAG mill had been measured as high as 892 percent (5.35E-10 microcuries per cubic
centimeter (pCi/cc)) of the DAC value in late May 1998 and 551 percent
(3.31E-10 ;rCi/cc) of the DAC value in June 1998. The DAC value for uranium-238 in air
is 6.0E-11 pCi/cc. The inspector reviewed the air sample analysis, worker residence
times, protective measures, and internal exposure calculations for 12 SAG mill project
workers. At the time of the inspection, SAG mill workers were being issued full-face
respirators with a protection factor (PF) of 50. Early in the project, workers had been
issued positive air supply respirator protection with a PF of 1000. The inspector
determined that the licensee's calculations of potential worker internal exposure were
adequate. lnternal exposures were found to be well below regulatory limits because the
licensee had utilized respiratory protection equipment that was consistent with airborne
concentrations inside the SAG mill .
32
b
-7-
Radiation Work Permits
The inspector reviewed the licensee's radiation work permit (RWP) program. The
inspector noted that many of the licensee's procedures required that workers obtain an
RWP from the radiation protection staff prior to performing work with a significant
potential for radiological exposure. The inspector noted, however, that the licensee had
not established a specific procedure for RWPs. Some general instructions for RWPs
were located in Section 3.5.2 of the ALAM program that was written by the previous
owner.
The SAG mill repair project was underway at the time of the inspection and was being
conducted under RWPs-330 and 331. The inspector reviewed RWPs and found that
both RWPs included the following elements: job description, requirements for
radiological monitoring and sampling protective equipment, respiratory protection
equipment, ALARA considerations, and a listing of personnel who were assigned to the
RWP. The inspector's observation of workers performing the SAG mill project revealed
that the workers were complying with RWP instructions. The inspector determined that
the RWP instructions were adequate to preclude unnecessary personnel exposures.
Bioassays
The inspector reviewed the licensee's bioassay program. The licensee primarily used
urinalysis on a monthly basis for uranium bioassay. However, for workers involved in
work under certain RWPs, additional samples were required. According to the license
application, the licensee analyzed urine samples by in-house fluorometrics, but the
inspector found that they stopped using fluorometric analysis as the principal analytical
method in February 1998. According to the licensee, the fluorometric analysis
equipment was obsolete, no longer reliable, and replacement parts were hard to procure.
Therefore, the chemistry department started using an inductively coupled plasma mass
spectrometer (ICP-MS) for urinalysis. The licensee showed the inspector that ten
percent of the urinalysis samples were sent to a certified laboratory as part of their quality
control (QC) program.
The inspector reviewed the licensee's reports of investigations into potentially elevated
bioassay results from 1997 and 1998. The licensee's bioassay investigation levelwas
15 micrograms per liter. The licensee had investigated bioassay results that were
analyzed during the transition from the fluorometric method to the ICP-MS method.
Based on the inspector's reviews and comparisons of ICP-MS, flurometric, and QC
bioassay results, the inspector determined that the licensee's bioassay program was in
compliance with license requirements.
Respiratory Protection Program
The inspector reviewed the licensee's respiratory protection program. The inspector
observed workers wearing full-face respirators and half-face respirators during the SAG
mill project. According to the RSO, the licensee did not take credit for the half-face
respiratory PF during radiological work. However, credit was taken for use of full-face
C.
d.
-8-
and positive air supply respirators during radiological work that had a significant potential
for exposure like the SAG mill project
The inspector found that the site maintained the respiratory protection program manual
from a previous owner. The inspector reviewed the training records and medical
certification records for some of the employees that had been issued respiratory
protection equipment. The records certified all the workers who were qualified to wear
respiratory protection equipment. The inspector toured the area where the licensee
maintalned and issued respiratory protection equipment. The inspector determined that
the licensee's respiratory protection program was adequate, and the selection of
respiratory protection equipment was deemed appropriate for airborne concentrations in
the mill.
3.3 Conclusions
The licensee had implemented a radiation protection program that was found to be in
accordance with requirement established in 10 CFR Parts 19 and 20 and the license.
Areas of the radiation protection program that were reviewed and found to be acceptable
included worker occupational dose determination, radiation work permit implementation,
bioassay program, and the respiratory protection program.
4 Radioactive Waste Management (88035)
4.1 lnspection Scope
The objective of this portion of the inspection was to verify that site radioactive waste
management activities were being conducted in accordance with applicable regulations
and the conditions of the license, and to ensure that controls were adequate to protect
the health and safety of the workers and the members of the general public.
4.2 Observations and Findings
During the site tour, the licensee's disposal cells were observed and found to be
processing liquid waste through evaporation and recycling. No abnormal conditions,
such as leaks or berm failures, were observed at any of the cells during the site tour.
LC 10.5 authorizes the licensee to dispose of byproduct materialgenerated at licensed
in-situ leach facilities subject to several conditions, including a 5000 cubic yard limit from
a single source. The licensee is also required to submit an annual summary to the NRC
of waste disposed of from off-site generators in accordance with LC 10.5(D). The
licensee's most current annual summary dated April 6, 1998, was reviewed by the
inspector. This document summarized the waste received during 1997 from offsite
waste generators. The total amount of waste received was within the limit specifled in
the license.
43
5.1
-9-
Conclusions
The licensee appeared to have maintained radioactive waste in accordance with the
license and NRC regulations. No health or safety issues were identified.
Environmental Monitoring (88045)
lnspection Scope
The environmental monitoring program was reviewed to assess the effectiveness of the
licensee's program and to evaluate the effects of site activities on the local environment.
Observations and Findings
Environmental Monitoring Program Overview
LC 11.2 states that the licensee shall implement the effluent and environmental
monitoring program specified in Section 5.5 of the renewal application. Also, the results
of the environmental monitoring program are required to be submitted to NRC on a
semiannual basis in accordance with LC 11.3(C) and 10 CFR 40.65. The semiannual
effluent report for the second half of 1997 was submitted to the NRC on March 2, 1998,
and reviewed during this inspection. The results of the 1997 effluent report were
compared to the 1996 reports to ascertain whether any adverse trends existed.
Air Particulate Sampling
The licensee collected particulate air samples at four locations around the site. Sample
filters were required to be changed weekly and analyzed for natural uranium,
radium-226, thorium-230, and lead-210 quantities. Sample results for the second half of
1997 were reviewed. Sample results were less than 7 percent of the respective 10 CFR
Part20, Appendix B, effluent concentration limits. Also, the laboratory's lower limit of
detection was equal to or better than the limits specified in LC1 1 .2(D). The 1997 sample
results were compared to the 1996 sample results, and no adverse trends were noted in
this area of the environmental monitoring program.
Stack Sampling
The licensee is required to sample the stack emissions for natural uranium content on a
quarterly basis during plant operations. Sampling for total particulates, thorium-230,
radium-226, and lead-210 content is required on a semiannual basis. Also, LC 11.2(A)
requires the licensee to determine the stack flow rates. Yellowcake stacks were in
service during the second half of 1997 and were sampled. The licensee also reported
the results of stack samples in the semiannual effluent report for the second half of 1997.
The inspector determined that licensee calculation of stack flowrates, radioactive
material release rates, and radioactive material concentrations were performed
adequately.
5.2
a.
b.
c.
d.
-10-
Ambient External Gamma Exposures
Environmental TLDs were located at five sample stations. One duplicate sample was
used at one station for quality control purposes. The TLDs were replaced and analyzed
on a quarterly basis. The sample results for 1997 were reviewed during the inspection.
The TLD ambient gamma exposure measurements were comparable to the background
radiation and were comparable to the 1996 TLD results. No adverse trend was
observed.
Surface Water and Groundwater Samples
Section 5.5 of the license application requires surface water samples to be obtained from
two locations. Quarterly samples had been collected from Westwater Canyon and
Cottonwood Creek. The samples were analyzed for natural uranium, radium-226, and
thorium-230 concentrations, as well as for the quantity of total dissolved and suspended
solids. Sample results were found to be less than the natural uranium effluent
concentration limit specified in Appendix B of 10 CFR Part20. Also, the 1997 sample
results were noted to be comparable to the 1996 sample results.
LC 11.3(C) requires monitoring wells to be sampled quarterly and analyzed for chloride,
potassium, nickel, and uranium concentrations. The sample results for the fourth quarter
of 1997 were reviewed. The highest natural uranium concentration (0.05 milligrams per
liter) was measured in a sample obtained from well MW-14. There were no deleterious
trends.
Conclusions
A review of the licensee's environmental monitoring program and 10 CFR 40.65 report
indicated that the licensee was in compliance with license requirements.
Exit Meeting Summary
The inspector presented the preliminary inspection results to licensee representatives
at the conclusion of the inspection on June 1 1, 1998. Licensee representatives
acknowledged the flndings as presented. The licensee did not identify any information
reviewed by the inspector as propriety information.
e.
5.3
6
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Berg, Radiation Safety Officer (RSO)
W. Deal, Mill Manager
W. Palmer, Radiation Technician
M. Rehmann, Environmental Manager and Corporate RSO
INSPECTION PROCEDURES USED
lP 83822 Radiation ProtectionlP 88005 Management Organizational Controls
lP 88020 Operations ReviewlP 88035 Radioactive Waste ManagementlP 88045 Environmental Monitoring
ITEMS OPENED. CLOSED AND DISCUSSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYMS USED
As Low As Reasonably Achievable
Code of Federal Regulations
derived air concentration
inductively coupled plasma mass spectrometer
lnternational Uranium (USA) Corporation
license condition
monitoring well
protection factor
quality control
radiation safety officer
radiation work permit
semiautogenous grinding
Safety and Environmental Review Panel
Standard Operating Procedure
Thermolum inescent Dosimeter
ALARA
CFR
DAC
ICP-MS
IUC
LC
MW
PF
QC
RSO
RWP
SAG
SERP
SOP
TLD