DRC-2013-003161 - 0901a068803be970

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
September 20, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: Inspection Conducted June 13,2013; Notice of Violation: Radioactive Materials License
Number UT1900479
Division of Radiation Control ("DRC") Letter Dated August 22, 2013
Dear Mr. Lundberg:
This letter responds to the above-referenced DRC letter of August 22, 2013. Energy Fuels Resources
(USA) Inc. ("EFRI") received a Notice of Violation ("NOV"), on July 8, 2013, which lists two
violations of the Utah Radiation Control Rules, based on an inspection of the White Mesa Mill (the
"Mill") conducted by representatives of the Utah Division of Radiation Control ("DRC") on June 13,
2013. EFRI responded by letter on August 6, 2013, requesting that Violation 2, regarding EFRI
shipping sewage to an off-site treatment facility without radiological characterization be rescinded. As a
result of a telephone conversation with Mr. Phil Goble and Mr. Kevin Carney on August 19, 2013, EFRI
withdrew its contention that Violation 2 should be rescinded. This letter responds to DRC's August 22,
2013 letter which required that EFRI provide a response containing the following items for Violation 2:
1) The corrective actions which have been taken and the results achieved;
2) The corrective steps which have been taken to prevent recurrence; and
3) The date full compliance will be achieved.
Violation 1 was fully addressed in our letter of August 6, 2013. The root cause of Violation 2 was also
addressed in the same letter. The response below summarizes the root cause, and addresses the three
remaining items listed above, for Violation 2.
Violation 2
10 CFR 20 Appendix B, Radionuclide Table lists the Effluent Concentration Limit, Annual Limit of
Intake and Derived Air Concentration for radionuclides. Each radionuclide listed includes three (3)
tables: Table 1, Occupational Values; Table 2, Effluent Concentrations (air and water); and Table 3,
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"DRC-2013-003161"
he
JF ENEi
ENERGYFUELS
Received
SEP 2013
Division of
Waffon Control
Letter to Rusty Lundberg
September 20, 2013
Page 2 of 4 )
Releases to Sewers.
Utah Rule R313-15-1 003, Disposal by Release into Sanitary Sewerage states, in part:
"(1) A licensee or registrant may discharge licensed or registered material into sanitary sewerage if
each of the following conditions is satisfied:
(a) The material is readily soluble, or is readily dispersible biological material, in water;
and
(b) The quantity of licensed or registered radioactive material that the licensee or registrant releases
into the sewer in one month divided by the average monthly volume of water released into the sewer by
the licensee or registrant does not exceed the concentration listed in Table HI of Appendix B of 10 CFR
20.1001 to 20.2402,(201 0), which is incorporated by reference"
Utah Rule R313-15-501. Surveys and Monitoring - General states, in part:
"(I) Each licensee or registrant shall make, or cause to be made, surveys that:
(a) Are necessary for the licensee or registrant to comply with Rule R313-15; and
(b) Are necessary under the circumstances to evaluate:
(i) The magnitude and the extent of radiation levels; and
(H) Concentrations or quantities of radioactive material; and
(Hi) The potential radiological hazards. "
Contrary to the above requirements, the DRC inspector found, based on a records review, that on
March 1, 2013, a contractor had entered the Mill's Restricted Area (RA) to pump out the Office
Building's Sewage Vault. Although the vault's contents are from the rest rooms located outside of the
RA, the vault itself resides inside of the RA. A review of the release form for this event entitled the
'Radiation Survey of Equipment Released for Unrestricted Use' shows that the contents that were
removed from the vault and pumped into the contractor's truck were only surveyed for dose rate. The
release form contains a comment that reads, "Material was wet, did not take an alpha reading. The
inspector agrees that since the material was volumetric in nature, (i.e., liquid, sludge and/or soil-like
material), an alpha scan or swipe sample would not be an appropriate survey method. However, this
type of material would necessitate bulk sampling and analysis to determine its isotopic concentrations.
The truck was released with an external alpha survey and documented on the form entitled 'Daily
Vehicle Scan for Vehicles Leaving the Restricted Area'. Although process knowledge would assume that
the material inside the truck was radiologically releasable, radioanalysis of the material was not
conducted to confirm this prior to it being released from the RAfor unrestricted use.
As a follow up, I asked a member of Energy Fuels' staff to contact the contractor to determine where the
material was taken. Via email from the Energy Fuels' staff member on June 19, 2013, the DRC was
informed that the material was taken, "directly to the sewer lagoons." This would confirm that the
material was released to sanitary sewerage which is defined by 10 CFR 20.1003 as, "a system of public
sewers for carrying off waste water and refuse, but excluding sewage treatment facilities, septic tanks,
v
Letter to Rusty Lundberg
September 20, 2013
Page 3 of 4
and leachfields owned or operated by the licensee.
The violations of Utah Rule R313-15-501, Utah Rule R313-15-1003 and 10 CFR 20 Appendix B
identified during the June 13, 2013 inspection have been characterized as Severity Level IV. The base
penalty for this Severity Level is $750. Level IV Violations are of more than a minor concern; however,
if left uncorrected, could lead to a more serious concern. In this case, the DRC does not believe that
radioactive material had been released for unrestricted use. However, the Mill made no effort to verify
that the material was suitable for release. If left uncorrected, similar materials that contain significant
radioactive concentrations may unknowingly be released to the general public.
EFRI Response
Root Cause of Noncompliance
A review of the circumstances indicates that the event on March 1, 2013 was the first time in the
history of the Mill that the main office septic leachfield required pumping out by vacuum truck. Since
the off-site shipment is such an untypical activity (that is, has never occurred before), neither the RSO
and radiation staff, nor the Mill management were aware that additional requirements beyond release
surveys were applicable to the shipment.
Corrective Actions Which Have Been Taken and the Results Achieved
As discussed with DRC during our phone call on August 19, 2013, EFRI has agreed to perform
sampling and radiological analysis of the main office sewage vault. Preparations for sampling of the
main office sewage vault are underway. The Mill Environmental Management has reviewed Utah
State Health Department regulations to determine what immunizations are required for workers in
potential contact with human sewage. The designated sample team is scheduled to begin the series of
hepatitis injections beginning the week of September 23, 2013. Sampling is scheduled to begin during
or after the first week in October 2013. As discussed with Kevin Carney of DRC on September 16,
2013, samples will be analyzed for the same radionuclides of concern as monitored and reported in the
Mill's Semi-Annual Effluent Report, specifically:
• Pb-210
• Ra-226
• Th-230
• U-nat
Corrective Steps Which Have Been Taken to Prevent Recurrence
To prevent a recurrence, EFRI has made the following steps:
1. Language has been added to the Mill's Radiation Protection Manual, Section 2.7, requiring that
prior to shipment of any sewage or recyclable fluids off-site from the Mill, samples will be
collected and analyzed for radionuclide content, for the same radionuclides of concern as
monitored and reported in the Mill's Semi-Annual Effluent Report. The revision to Section 2.7
Letter to Rusty Lundberg
September 20, 2013
Page 4 of 4
of the RPM is provided in Attachment 1 to this letter.
2. In addition to sampling of the Main office sewage vault, the Mill has scheduled sampling of
the remaining four septic sewage vaults on site. All five septic sewage vaults will be
resampled and analyzed periodically to ensure relatively current radionuclide data is available
for each vault in the event of a future need to evacuate and ship any sewage vault contents.
3. The Mill Manager, Environmental manager, RSO and radiation technicians have been re-
educated regarding the need for radiological characterization (in addition to vehicle surveys) of
materials leaving the Mill's restricted area.
Date Full Compliance Will Be Achieved.
Compliance will be achieved when analytical data is received from the laboratory confirming that the
radionuclides of interest are at or below the limits in 10 CFR 20 Appendix B for the four radionuclides
of concern listed above for the samples from the Main Office sewage vault. EFRI expects that the
data will be available by early to mid-November 2013. A copy of the radiological results will be
available at the Mill for DRC review at that time.
As mentioned in our letter of August 6, 2013, a copy of the NOV has been posted in the
Administration Building, in accordance with R313-18-1 l(l)(d).
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Kevin Carney, Utah DRC
• Ronnie Nieves
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
ATTACHMENT 1
I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/133 Revision: EFR 34
Page 1 of 17
2.0 RADIATION MONITORING - AREA
2.1 HIGH VOLUME AIRBORNE AREA AIR SAMPLING
Area air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airborne
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high volume sampler or similar high
volume pump will be used for this purpose. Samples will be analyzed as per standard
gross alpha analysis procedures using a sensitive alpha detector.
2.1.1 Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of 40 1pm or
greater for one hour or longer. A variety of equipment may be used for area air sampling,
however normally the equipment used is an Eberline RAS-1, Scientific Industries Model
H25004, or equivalent. Equipment is calibrated prior to each usage as per Section 3.6 of
this manual.
2.1.2 Frequency/Locations
Area dust monitoring frequency is monthly for the locations shown in Table 2.1.2-1.
Table 2.1.2-1
Airborne Radiation Sample Locations
Code
BA1
BA2
BA6
BA7
BA8
BA9
BA10
BA11
BA12
BA12A
BA12B
BA13
BA13A
BA14
BA15
Location/Description
Ore Scalehouse
Ore Storage
Sample Plant
SAG Mill Area
Leach Tank Area
Washing Circuit CCD Thickness
Solvent Extraction Building/Stripping Section
Solvent Extraction Building/Control Room
Yellowcake Precipitation & West Storage Area
North Yellowcake Dryer Enclosure
South Yellowcake Dryer Enclosure
Yellowcake Drying & Packaging Area
Yellowcake Packaging Enclosure
Packaged Yellowcake Storage Room
Metallurgical Laboratory Sample Preparation Room
I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 2 of 17
Code Location/Description
BA16 Lunch Room Area (New Training Room)
BA17 Change Room
BA18 Administrative Building
BA19 Warehouse
BA20 Maintenance Shop
BA21 Boiler
BA22 Vanadium Panel
BA22A Vanadium Dryer
BA23 Filter Belt/Rotary Dryer
BA24 Tails
BA25 Central Control Room
BA26 Shifter's Office
BA27 Operator's Lunch Room
BA28 Dump Station
BA29 Emergency Generator Station
BA30 Truck Shop
B A31 Women's Locker Room
BA32 Oxidation
BA33A AF South Pad
BA33B AF North Pad
Areas BA-10 and BA-12 are soluble uranium exposure areas. These areas are areas
where the uranium compounds that are produced are soluble in lung fluids and are
comparatively quickly eliminated from the body. All the other areas are insoluble
exposure areas. Insoluble uranium areas are areas where the uranium compounds are not
readily soluble in lung fluids and are retained by the body to a higher degree.
Temperature of drying operations has a significant impact on solubility of uranium
compounds. High drying temperatures produce insoluble uranium compounds. Area
uranium dust monitoring, during production periods, is weekly in the designated
yellowcake production areas. Monitoring increases to weekly in other monitored areas
with the observance of levels exceeding 25% of 10 CFR 20 limits and reverts to monthly
upon a continued observance of levels below 25% of 10 CFR 20 limits as determined by
the RSO. The RSO may also perform any additional samplings at his or her discretion.
The RSO will designate those areas involved in area monitoring during non-production
periods. Non-production period monitoring becomes effective one month following the
cessation of production.
Annually, the licensee shall collect, during mill operations, a set of air samples covering
eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40
liters per minute), in routinely or frequently occupied areas of the mill. These samples
shall be analyzed for gross alpha. In addition, with each change in mill feed material or at
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I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 3 of 17
least annually, the licensee shall analyze the mill feed of production product for U-Nat,
Ra-226 and PB-210 and use the analysis and results to assess the fundamental constituent
composition of air sample particulates.
1. A RAS-1 or similar high volume pump shall be used for area grab sampling. Insure
the pump has been recently calibrated within the past month.
2. The locations selected for area air samples should be representative of exposures to
employees working in the area.
3. For routine sampling, the sampling period should be for a minimum collection
duration of 60 minutes at a flow of 401pm or greater.
4. Insert a clean filter into the filter holder on the sampler. Note start time of pump and
record unusual mill operating conditions if they exist.
A. Stop sample collection and note time. Normally, an automatic timer is
connected to the sampler and a 1 hour sample collection time is used.
6. Remove the filter from the sampler and place in a clean glassine envelope or the
package supplied by the manufacturer for delivery to the Radiation Department.
7. Count the sample by gross alpha counting techniques and enter the result and
sampling information into the record.
2.1.4 Calculations
Perform calculations as specified in Section 4.0.
2.1.5 Records
Logs of all samples taken are filed in the Radiation Safety Officer's files. Data is utilized
to calculate radiation exposures as specified in Section 4.0.
2.1.6 Quality Assurance
Calibration checks on each air sampler are made at least monthly to ensure accurate
airflow volumes are being collected. Usage of tweezers and new filter storage containers
minimizes contamination potential. Field logging of data during sampling and logging of
identifying data on sampled filter containers minimizes sample transposition. Samples
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2.1.3 Sampling Procedures
I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 4 of 17
may periodically be submitted for chemical analysis and a comparison of these results to
the radiometric measurements will be made.
Review of data by the RSO and by the ALARA audit committee further assure quality
maintenance.
2.2.1 Definitions
Working Level:
A. The exposure to 1.3E + 05 MEV of alpha energy or the potential alpha energy
in one liter of standard air containing 100 pCi each of RaA (Polonium-218), RaB
(Lead-214), RaC (Bismuth-214), and RaC prime (Polonium-214). (Exposure
level, not a dose rate)
Kusnetz Method: Method of radon progeny measurement and calculation based
upon a 10 liter sample and at least 40 minutes decay time before counting.
2.2.2 Equipment
The equipment utilized consists of the following, or appropriate equivalents:
• Portable personal sampler
• Gelman 25 mm filter holder with end cap, or equivalent
• Gelman Type A/E 25 mm diameter glass fiber filters, or equivalent
• Counter-Sealer - Eberline MS-3 with SPA-1 probe, or equivalent
2.2.3 Frequency/Location
Radon progeny samples are obtained monthly at those locations included for area
particulate uranium monitoring during production periods. Monitoring is increased to
weekly upon observance of levels exceeding 25% of 10 CFR 20 limits. Monitoring is
reduced to monthly upon the continued observance of levels belovy 25% of 10 CFR 20
limits. During non-production periods, monitoring is done monthly for only those
locations occupied by personnel where exposures may have the potential of exceeding
25% of 10 CFR 20 limits. The RSO shall so designate those areas to be monitored during
non-production periods.
2.2.4 Procedures
The procedures to be utilized are as follows:
2.2 RADON PROGENY
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I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 5 of 17
1. Assemble filter trains.
2. Ensure pump batteries are fully charged.
3. Calibrate pump (see Section 3.5).
4. Attached filter trains at sample locations; disconnect end plug.
5. Collect sample in the breathing zone of the employee.
6. Collect sample for five minutes at 4.01pm.
7. Log sample site, time started, time stopped, and filter pump number prior to leaving
each site on the field log notebook.
8. Samples are counted between 40 minutes and 90 minutes after collection using
sensitive alpha detector.
9. Check the calibration and function check information to ensure the detector is
calibrated and operating.
10. If the calibration check correlates, proceed with sample analysis.
11. Radon progeny samples are normally counted for three minutes, however any sample
count time may be selected for counting.
12. Run background detector count prior to running sampled filters.
13. After counting, calculate working levels.
Equation: (CPM - Bkg)
(oceff) (20 liters) (Time Factor) = W.L.
Where: CPM - sample count per minute
Bkg - counter-detector background count per minute
a Efficiency - The efficiency of the counting system (See Section
3.2.3.3)
Time Factor - Values determined from Kusnetz method (See
attached Table 2.2.4-1)
W.L. - Working Levels
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White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 6 of 17
TABLE 2.2.4-1
Time Factors
Min. Factor Min. Factor
40 150 71 89
41 148 72 87
42 146 73 85
43 144 74 84
44 142 75 83
45 140 76 82
46 138 77 81
47 136 78 78
48 134 79 76
49 132 80 75
50 130 81 74
51 128 82 73
52 126 83 71
53 124 84 69
54 122 85 68
55 120 86 66
56 118 87 65
57 116 88 63
58 114 89 61
59 112 90 60
60 110
61 108
62 106
63 104
64 102
65 100
66 98
67 96
68 94
69 92
70 90
2.2.5 Exposure Calculations
The personnel exposure calculations are a job-weighted average of those areas and
concentrations that an individual is exposed to. The procedure is:
1. Determine areas and durations (hrs.) each individual worked during the period (month
and quarter).
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White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 7 of 17
2. Determine monitored concentrations (W.L.) for each area so noted.
3. The multiplication of the hours worked in each area by the area concentration (W.L.)
noted is added to the result for each area involved in the period.
4. The result is the Working Level Hours exposed (WLH) for the period.
5. The working level hours (WLH) divided by 173 (30 CFR 57.5-40 note); or hours per
month gives the working level months (WLM) exposure. (The limit is 4 working
level months exposure per year.)
6. If calculated per quarter, the working level hours summed for the quarter are divided
by 519 (173 X 3) to obtain the working level quarter exposure.
See Section 4.0 for details on how to perform exposure calculations and maintain the
exposure records.
2.2.6 Records
Data records, which are filed in the Radiation Safety files, include:
1. Sample location
2. Date and time of sample
3. Time on and off of sample pump
4. Counts per minute of sample
5. Elapsed time after sampling
6. Background detector count
7. Appropriate Kusnetz time factor
8. Working level
9. Sampler identification
Employee exposure records include:
1. Month monitored
2. Areas and duration worked
3. Employee identification
4. Concentrations (W.L.) observed
5. Calculated WLMs
2.2.7 Quality Assurance
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White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 8 of 17
Calibration checks each month assure proper calibration of the counting equipment.
Documented semi-annual calibrations of the counting equipment using certified alpha
calibration and pulse meter sources ensure proper calibration of the equipment over the
anticipated ranges. The air sampling system has documented calibration prior to each
use, ensuring sampling the appropriate air volumes. Duplicate counts of select data may
be counted to assure instrument precision. Field documentation is maintained for each
sample during monitoring. This methodology provides assurance in data quality.
Review of data by the RSO and the ALARA audit committee further assures quality
maintenance.
2.3 ALPHA SURVEYS
2.3.1 Equipment
Equipment to be utilized in area alpha surveys is shown in Appendix 1. Pre-use function
checks will be performed on all radiation survey equipment as specified in Section
3.1.2.3.2.
2.3.2 Frequency/Locations
Fixed and removable alpha surveys are made at those general locations on the Table
2.3.2-1, "Alpha Area Survey Locations." Surveys are completed weekly during
production periods. During non-production periods, only those areas designated by the
RSO as authorized lunchroom/break areas are monitored. Designated eating areas are
listed in Table 2.3.2-2.
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Benches
Maintenance Lunchroom Tables
CCR Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
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I White Mesa Mill - Standard Operating Procedures Date: 4309/133 Revision: EFR-34
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 9 of 17
Table 2.3.2-2
White Mesa Mill
Designated Eating Area Locations
Maintenance Supervisor Break Room
Main Lunch/Training Room
Administrative Break/Conference Rooms
Administrative Office Desks
2.3.3 Procedures
2.3.3.1 Respirators
Respirators are monitored utilizing a removable alpha smear that is read using alpha
scaler meter such as a Ludlum Model 2200 or other equivalent radiological instruments.
Readings exceeding 100 dpm/100 cm2 result in re-cleaning or discarding of the respirator.
Respirator cleaning and monitoring is a function of the Radiation Safety staff assigned to
this duty. The meter's performance is checked prior to each use period.
2.3.3.2 Fixed Alpha Surveys
Alpha surveys for fixed alpha contamination are performed using a variety of alpha
detecting instruments, as listed in Appendix 1. Each instrument is checked using a
calibrated alpha source for proper function and operation prior to use, as described in
Section 3.1.2.3.2.
Adjustments to the surface area being measured must be made to convert from the
particular detector's surface area to the commonly used surface area of 100 square
centimeters. Therefore when converting a measurement to the commonly used unit of
dpm/100cm2, a multiplying area factor must be applied to the measurement. For the
Ludlum instrument with a 43-1 detector of 75 cm2 surface, multiply the value by 1.33 (i.e.
100cm2 divided by 75cm2).
The procedures are:
1. Turn the meter on and check the meter battery condition.
2. Check alpha detector mylar surface for pinholes, etc. Replace if necessary and repeat
calibration.
3. As specified in Section 3.1.2.3.2, perform a function calibration check using
calibrated alpha source.
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I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 10 of 17
4. If check is acceptable, proceed with monitoring.
5. At each designated site, monitor designated surfaces, table tops, etc., holding within
lA inch of the surface.
6. Record data, location, cpm/cm2 monitored on data sheet.
7. At the conclusion of the survey, transpose results to the file log, correcting to
dpm/100 cm2, using correction for detector's surface area and cpm/dpm conversion
factor.
2.3.3.3 Removable Alpha Surveys
The Ludlum Model 2200 scaler with 43-17 detector, or a variety of other sensitive alpha
detection instruments such as Model 2929 or equivalent, counts wipe samples collected
during removable alpha surveys. Glass fiber filters, sized to fit the detector sample slot,
are utilized as the wipe medium. A template having a 100 square centimeter surface area
maybe used to standardize the surface area wiped.
The procedure is:
1. Perform function check calibration of the sealer/detector. Ensure that this
measurement is within ± 10% of the value obtained from the calibration laboratory.
2. If so proceed with the survey and counting.
3. Obtain clean filters and clean envelopes for filter storage.
4. At a location to be surveyed, remove the filter from the envelope and wipe the surface
covering approximately 100 cm2. This is easily accomplished by making a "S"
shaped smear for approximately 10 inches using normal swipes (approximately 2.5
cm diameter).
5. Record on envelope the date and location of the sample.
6. Upon returning to counting lab, place an unused filter in the counting unit for at least
1 minute and obtain a background count rate.
7. Repeat procedure for each used filter, extracting filter from envelope, immediately
prior to counting, using tweezers and placing in the detector slot with the wiped
surface facing the detector, and count for at least 1 minute.
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SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 11 of 17
8. Convert results from cpm/filter to dpm/filter (100 cm2 wiped) after subtracting the
blank background count.
9. Record on the alpha survey form the following information:
A. Sample location and conditions
B. Sample date
C. Sampler identification
D. Wipe count dpm/100 cm2
10. Discard the filters and envelopes
2.3.4 Action Limits
2.3.4.1 Respirators
Levels greater than 100 dpm/100 cm2 squared require re-cleaning or discarding of a
respirator.
2.3.4.2 Fixed Alpha Surveys
Levels greater than 1,000 dpm/100 cm2 squared require remedial action by management.
ALARA criterion ensures that the RSO takes action where necessary to maintain levels as
low as reasonably achievable.
2.3.4.3 2.3.4.3 Removable Alpha Surveys
Levels greater than 1,000 dpm/100 cm2 squared require remedial action and
decontamination. ALARA criteria ensures that the RSO takes action where necessary to
maintain levels as low as reasonably achievable.
2.3.5 Records
Records of fixed and removable alpha surveys are maintained in the Radiation Safety
office files. Records include:
1. Sample location/conditions
2. Sample date
3. Sampler identification
4. Fixed alpha determination - dpm/100 cm
5. Removable alpha determination - dpm/100 cm2
6. Remedial action taken, where necessary
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2.3.6 Quality Assurance
Calibration function checks of detector performance and visual observation of detector
surfaces prior to each survey ensures counting reliability and consistency. Usage of clean
containers and tweezers minimizes contamination of wipe samples. Field logs of sample
LD.'s on sample containers minimizes transposition of samples. Data review by the RSO
and by the Audit Committee further assures quality maintenance.
Beta/Gamma surveying instruments used for beta-gamma surveys are listed in Appendix
1 and the sources used are listed in Appendix 2.
Some instruments read directly in mrem/hour while others read in cpm (with a conversion
to mrem/hour). The model 44-6 detector has a removable beta shield allowing
discrimination between beta and gamma contributions. Each instrument has a
manufactures user's manual which describes the function, use and capability of each
instrument. These manuals must be understood before surveying proceeds. Calibration
of Beta/Gamma and functional checks are performed using calibrated Cs-137 or Sr-Y 90
sources
2.4.2 Frequency/Locations
The sites noted on Table 2.4.2-1 are monitored on a monthly basis by of the Radiation
Safety staff during production periods. During non-production periods, only areas
routinely occupied by personnel are monitored as designated by the RSO.
2.4 BETA-GAMMA SURVEYS
2.4.1 Equipment
Table 2.4.2-1
Beta-gamma Survey Locations
Description of Possible
Identification Number Source of Area of Exposure
Mill Feed Hopper & Transfer Chute
SAG Mill Intake-Feed Chute
Screens-Area Floor Between Screen
Leach Operator's Desk
Leach Tank Vent #3
Leach Tank #3-Wall
CCD Thickeners
Pumphouse Tailings Discharge
Oxidant Makeup Room-Sump Pump
Shift Foreman's Office-Work Desk
Distance from Source in cm
WM-1
WM-2
WM-3
WM-4
WM-5
WM-6
WM-7
WM-8
WM-9
WM-10
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Description of Possible
Identification Number Source of Area of Exposure Distance from Source in cm
WM-11 SX Operator's Area 1
WM-12 Precipitation Tanks #1 Tank; Wall 1
WM-13 Precipitation Section "Lab Bench" 1
WM-14 Precipitation Vent 1
WM-15 Yellowcake Thickener #1; Wall 1
WM-16 Centrifuge Discharge-Chute Wall 1
WM-17 Yellowcake Thickener #2; Wall 1
WM-18 Yellowcake Packaging Room 1
WM-19 Yellowcake Dryer 1
WM-20 Yellowcake Dust Collector 1
WM-21 SX Uranium Mixer # 1 Extractor 1
WM-22 SX Uranium Mixer #1 Stripping 1
WM-23 SX Vanadium Mixer #1 Stripping 1
WM-24 Vanadium Dryer 1
WM-25 Mill Laboratory Fume Hood 1
WM-26 Chemical Laboratory Work Area 1
WM-27 Metallurgical Laboratory Work Area 1
WM-28 Lunchroom Eating Area 1
WM-29 Lunchroom Wash Area 1
WM-30 Maintenance Shop - Work Area 1
WM-31 Maintenance Shop - Rubber Coating 1
WM-32 Tailings Impoundment Discharge 1
WM-33 Tailings Impoundment Dike 1 1
WM-34 Tailings Impoundment Dike 2 1
WM-35 Tailings Impoundment Dike 3 1
WM-36 Scalehouse 1
WM-37 Tailings Impoundment Dike 4 1
2.4.3 Procedures
The monitoring procedures are:
1. Check meter battery condition.
2. Check detector using a check source.
3. If the calibration function check indicates that the instrument is operating within
calibration specifications, proceed with monitoring.
4. Survey each designated location on Table 2.4.2-1 and record in the field log:
A. Site location/condition
B. Date
C. Instrument used
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D. Sampler's initials
E. Meter reading (beta + gamma)
F. Meter reading (gamma)
5. Upon returning to the office, record the mr/hr reading into a permanent file which is
maintained for beta-gamma exposure evaluation.
2.4.4 Action Levels
The ALARA concept is utilized in action levels. Responses include operative cleaning of
the area or isolation of the source. The Radiation Safety Department will ensure levels
ALARA.
2.4.5 Records
Records maintained in the Radiation Safety office files include:
1. Date monitored
2. Site location/condition
3. Instrument used
4. Sampler's initials
5. Beta/Gamma level, mr/hr
6. Remedial action taken, if necessary
2.4.6 Quality Assurance
Quality of data is maintained with routine calibration and individual function checks of
meter performance. Personnel utilizing equipment are trained in its usage. Records of
the operational checks and calibrations are maintained in the files. The RSO routinely
reviews the data and the ALARA audit committee periodically analyzes the performance
of the management of the monitoring and administrative programs.
2.5 EXTERNAL GAMMA MONITORING
External gamma area monitoring is conducted at various locations around the Mill site in
order to provide Radiation Safety Staff with area-specific gamma measurements. The
procedures applicable to such monitoring are set out in Section 4.3 of the Mill's
Environmental Protection Manual.
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2.6 EQUIPMENT RELEASE SURVEYS
2.6.1 Policy
Materials leaving a Restricted Area going to unrestricted areas for usage must meet
requirements of NRC guidance for "Decontamination of Facilities and Equipment Prior
to Release for Unrestricted Use" (dated May 1987).
All material originating within the restricted area will be considered contaminated until
checked by the Radiation Safety Department. All managers who desire to ship or release
material from the facility will inform the RSO of their desires. The RSO has the authority
to deny release of materials exceeding NRC guidance for "Decontamination of Facilities
and Equipment Prior to Release for Unrestricted Use" (dated May, 1987). No equipment
or materials will be released without documented release by the RSO or his designee.
2.6.2 Limits
The release limits for unrestricted use of equipment and materials is contained in the
NRC guidance listed above in Section 2.6.1 and are summarized as follows:
Limits for Alpha emissions for U-Nat and its daughter products are:
Average 5,000 dpm/100 cm2
Maximum 15,000 dpm/100 cm2
Removable 1,000 dpm/100 cm2
Limits for Beta-gamma emissions (measured at a distance of one centimeter) for
Beta/Gamma emitting radioisotopes are:
Average 0.2 mr/hr or 5,000 dpm/100 cm2
Maximum 1.0 mr/hr or 15,000 dpm/100 cm2
2.6.3 Equipment
Radiological survey instruments are listed in Appendix 1.
2.6.4 Procedures
Upon notification that materials are requested for release, the Radiation Safety
Department shall inspect and survey the material. Surveys include fixed and removable
alpha surveys and beta-gamma surveys. An equipment inspection and release form is to
be prepared and signed by the RSO or his designee. Any material released from the mill
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will be accompanied with the appropriate release form. If contamination exceeds levels
found in NRC guidance "Decontamination of Facilities and Equipment Prior to Release
for Unrestricted Use", dated May, 1987, then decontamination must proceed at the
direction of the RSO. If the material cannot be decontaminated, then it will not be
released.
2.6.5 Records
Documented records for each released item are filed in the Radiation Safety Department
files.
2.6.6 Quality Assurance
The RSO and the ALARA Audit Committee periodically review the policy and
documented release forms to ensure policy and regulatory compliance.
2.7 PRODUCT SHIPMENT SURVEYS
2.7.1 Policy
The Radiation Safety Department, prior to shipment release, will survey product
shipments from the facility. Product shipments include uranium concentrate and solid
vanadium products.
The Radiation Safety Department is to be notified in advance of each shipment. The
shipment will not be released prior to the Radiation Safety Department's authorization.
2.7.2 Equipment
Equipment used for product shipment surveys is the same as equipment used for material
release surveys and is listed in Appendices 1 and 2.
2.7.3 Frequency
All barrels are fixed alpha and gamma scanned prior to shipment. A minimum of 25
percent of the barrels consigned are also wipe tested.
2.7.4 Solid Vanadium Shipments
The procedure to be followed for solid vanadium shipments were detailed in the
Radiation Safety Manual in Section 2.7.4. These procedures have been replaced with
procedures No.: PBL-15 Book 10, "Release and Shipping of Vanadium Blackflake".
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2.7.5 Uranium Concentrate Shipments
The procedures for exclusive use uranium concentrate shipments are:
1. Inspect each product barrel that makes up the consigned shipment for leaks, holes in
the barrels, cleanliness, etc.
2. Barrels requiring repair shall be repaired prior to the radiation survey.
3. Perform a total and removable alpha survey of each barrel, using the procedures and
equipment specified in Section 6.0. The release limits for total and removable alpha
radiation contamination is an average of 5,000 dpm/100 cm2 and a maximum of
15,000 dpm/100 cm2. Any barrel that exceeds 1,000 dpm/100 cm2 total alpha
radiation contamination requires a removable alpha smear/wipe test to be performed.
Perform a removable alpha survey of each barrel exceeding 1,000 dpm/100 cm2 total
alpha contamination. The release limit for removable alpha radiation contamination is
1,000 dpm/100 cm2. Perform a smear/wipe test and analyze filters for removable alpha on
25% of the barrels at a minimum, and perform a smear/wipe test and analyze the filters
for removable alpha on any barrels that exceed 1,000 dpm/100 cm2 total alpha
contamination.
2.7.6 Records
The attached form servos as a record of shipment and is retained in the Radiation Safety
files.
2.7.7 Quality Assurance
Periodic reviews of transport forms and policies by the RSO and the ALARA Audit
Committee ensures quality assurance for product shipment surveys.
2.7.6$ Miscellaneous Releases
The Radiation Safety Department will monitor, prior to leaving the Restricted Area, any
material that will shipped off siter not permit any sewage or recyclable fluids to leave the
Restricted Area unless (a) a characterization sample of the sewage or fluid, which is
analyzed for Ra-226. Pb-210. U-nat, and Th-230. is taken or is on file at the Mill: and (b)
based on the results of the sample, the release is in compliance with the requirements of
R313-15-1003 and R313-15-302(2)(fr)(T,. as applicable. A copy of the results of each
characterization sample will be maintained on file at the Mill. This includes, but not
limited to. sewage and oil. Along with radiological survey information, these materials
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will also havo laboratory analysis performed for a sot list of radioisotopes as specified by
Corporate Management and a copy of thoso results maintained on filer
2.7.7 Records
The attached form serves as a record of shipment and is retained in the Radiation Safety
files.
2.7.8 Quality Assurance
Periodic reviews of transport forms and policies by the RSO and the ALARA Audit
Committee ensures quality assurance for product shipment surveys.
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