DRC-2010-001463 - 0901a068801732f9

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4tranlumone*investing in our energy
Mr. Dane L. Finerfrock, Executive Secretaty
Utah Radiation Control Board
Utah Department of Environmental Quality
PO Box 144810
Salt Lake city, uT 84114-48 10
Re: 2009 Annual Safety and Environmental
ur0900480
Dear Mr. Finerfrock:
January 22,20L0
Review Panel Report; Radioactive Materials License
This submittal constitutes the 2009 Safety and Environmental Review Panel (SERP) Report and the SERP
safety and environmental evaluation documentation required by License Condition 9.4(D). During 2009, the
SERP evaluated one change, which relates to security inspection procedures at the mill site. Specifically, the
SERP evaluated the following proposed modification to the security inspection frequency:
Decrease security inspection frequencv from daily to weekly.
Require that an inspection be required within 24 hours of identification of upset conditions, such as
earthquakes greater than magnitude 5.5, natural fires from outside the licensed area affecting the site
boundary or interior, or any storm event or other severe natural event that could compromise site
security.
All environmental and radiological monitoring program inspections remain unchanged.
Attached to this letter is the SERP safety and environmental evaluation of the proposed change. Based on the
evaluation of the proposed change and regulatory requirements, the following findings were determined.
The proposed reduction in security inspection frequency does not conflict any requirement
specifically stated in the license, or impair our ability to meet all applicable State and Federal
regulations
The proposed reduction in security inspection frequency does not degrade the essential safety or
environmental commitments in the license application or provided by the approved reclamation plan.
The proposed reduction in security inspection frequency is consistent with the conclusions of actions
analyzed and selected in the Environmental Assessment (EA) dated April 1997
rer +1 s7o-231 -.,, :rl:'.?H.1;?l#
3801 Automation Way
Suite 100. Fort Collins
Colorado.80525
www.uraniuml.com
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Mr. Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
January 22,2010
Page2 of 2
o The proposed change does not require any change to the financial surety arrangement or amount.
As per License Condition 9.4(D), this change evaluation serves as the requisite written Environmental and
Safety Evaluation documenting the SERP's basis for determining that the proposed change is in compliance
with the requirements referred to in License Condition 9.4(B).
Should you have any questions, please contact me at [phone].
Toby Wright, PG
Uranium One USA
Environmental Manager
Enclosure
cc:Mill site
John Hultquist (UDEQ\DRC; wlout enclosure)
file
Sincerely,
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Shootaring Canyon Mill
Safety and Environmental Review Panel
Safety and Environmental Evaluation
Proposed Change to Security
lnspection Frequency
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January 201 0
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Shootaring Canyon Mill
Safety and Environmental Review Panel
Safety and Environmental Evaluation 9129109
Security Inspection Frequency Change Proposal
Proposed Change:
Modification of required security inspection frequency for Radioactive Materials License
UT0900480 (formerly NRC License SUA-1371) as identified in the License Renewal
Application dated March l,1996, as amended, Section 5.5.2.2 (erroneously nurnbered in
original submittal as section 5.5.3) and Table 5.5-8, from daily to weekly. In addition, an
inspection will be required within 24 hours of identification of upset conditions, such as
earthquakes greater than magnitude 5.5, natural fires from outside the licensed area affecting the
site boundary or interior, or any storm event or other severe natural event that could compromise
site security.
1.0 Evaluation:
The work scope of the Safety and Environmental Review Panel (SERP), as described in SOP
AP-3, is to review all proposed activities involving:
o Changes in the facility or process, as presented in the approved license application;o Changes in the procedures, except for minor editorial changes; and
o Tests or experiments not presented in the approved license application.
The SERP is to determine if the proposed changes, procedures, or tests comply with License
Condition 9.4
1.1 RequlatorvReouirement:
Radioactive Materials License UT0900480, Amendment#3 (April 30,2007) Condition 9.3
states:
"9.3 The licensee shall conduct operations in accordance with statements, representations
and conditions contained in Sections 1-9 of the license renq,val application dated March
1, 1996 as revised by submittals to the NRC dated September 16 and November i,5, 1996
and April 17, 1997, except where amendments have superseded license conditions
herein".
Further, License Condition 9.4 allows certain changes to the processes and\or procedures as
presented in the approved license application as long as certain conditions have been satisfied.
"9.4 A. The licensee may, without prior Executive Secretary approval, and subject to the
conditions specified in Part B of this condition:
(1) Make changes in thefacility or process, as presented in the approved
license application.
(2) Make changes in the procedures, presented in the approved license
application.
(3) Conduct tests or experiments not presented in the approved license
application.
SCM SERP SEE-9-2009 lnspection Frequency rev-Zclean.doc 1 Of 4 U22lzoto
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Shootaring Canyon Mill
Safety and Environmental Review Panel
Safety and Environmental Evaluation 9129109
Security Inspection Frequency Change Proposal
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The licensee shaleJile an applicationfor an amendment to the License, unless the
following conditions are s atisfi ed.
(t)
(2)
(s)
The change, test or experiment does not conflict with any requirement
specifically stated in this license, or impair the licensee's ability to meet
all applicable State and Federal regulations.
There is no degradation in the essential safety or environmental
commitments in the license application or provided by approved
reclamation plan
The change, test or experiment is consistent with the conclusions of
actions analyzed and selected in the Environmental Assessment (EA)
dated April 1997.
Chapter 5 of the License Renewal Application dated 311196, as updated, addresses the operations
of the mill site, including periods of non-operation more than 30 days. The updates to the
license renewal application dated September 16, andNovember 15,1996, and April 17,1997
identified in License Condition 9.3 relate to the basis for financial surety and do not relate to
security inspections in any way. Specifically, Section 5.5.3 (erroneous section numbering in
original submiffal, Section should be 5.5.2.2) addresses the responsibility of Radiation
Technicians (RT) and EnvironmentaU Safety Technicians (EST). Specifically, this section
identifies that the EST will be responsible for the Interim Environmental Monitoring Program
identified in Table 5.5-8. The last item in Table 5.5-8 indicates that visual security inspections
of the Mill and Tailing Facility will be conducted daily. This is the primary Section that
addresses the Table 5.5-8 program and inspection requirements. SOP HP-6 (Inspection of the
Mill, Tailings Dam/Area and Ores Stockpiles) is used to conduct these inspections but does not
speciff a frequency of inspection.
The April 1997 Environmental Assessment (EA) referenced in License Condition 9.4.8.(3) was
reviewed. Section 3.3 address Inspections of the Tailings Disposal System during both
operations (daily) and stand-by periods (monthly). Section 4.6.2 addresses the radiological
aspects of environmental impacts during stand-by periods. Neither section nor any other portion
of the EA specifically or indirectly addresses security inspection.
1.2 Basis for Chanqe in Security Inspection Frequencv:
The mill is not in standby non-operational status but in long-term care and maintenance status
while a license application is under review for returning to operational status. The mill has been
inactive and has not processed any ore for over two decades. The mill is de-energized except for
overhead lighting and a1l process leach tanks and piping have been drained. In addition, all
solvent extraction (SX) system tanks have been drained and cleaned.
The tailings are unsaturated and fully drained and are covered by and interim cover. The tailings
sump that collects tailings seepage has sufficient capacity to collect several weeks worth of
flows, even under storm conditions. The ore stockpile is similarly covered with an interim soil
cover.
SCM SERP SEE-9-2009 lnspection Frequency rev_2 clean.doc 2of4
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Shootaring Canyon Mill
Safety and Environmental Review Panel
Safety and Environmental Evaluation 9129109
Security Inspection Frequency Change Proposal
Daily activities at the Mill involve only two site personnel performing routine preventative
maintenance to forestall deterioration of the mill equipment and infrastructure. Daily inspections
of the mill, tailings area and ore stock pile area over the past two decades as per SOP HP-6
(Inspection of the Mill, Tailings Dam\Area, and Ore Stockpiles) have shown the site to be very
stable and not subject to abrupt change.
Reducing the security inspection frequency from daily to weekly would remove the necessity for
personnel to inspect and document the site conditions on weekends. Providing the requirement
for prompt inspections following upset conditions (storms, fires, earthquakes, etc.) will ensure
that security of the site will not be compromised from unplanned events. No change is proposed
to the required environmental and\or radiation protection monitoring, which will remain
unchanged.
2.0 Findines
Stable physical and environmental conditions have been documented in the past two decades of
daily monitoring. There are minimal energized systems, only those required to perform routine
maintenance and administrative functions. No mill process or tailings systems are active and all
systems have been stabilized in a manner consistent with long-term care and maintenance.
Changing the inspection frequency has no environmental, social, or ecological impacts on the
actions considered in the 1997 Environmental Assessment. Based on the assessment of the
proposed change and regulatory requirements, the following findings were determined.
o The proposed reduction in inspection frequency does not conflict any requirement
specifically stated in this license, or impair our ability to meet all applicable State and
Federal regulations.o The proposed reduction in inspection frequency does not degrade the essential safety or
environmental commitments in the license application or provided by approved reclamation
plan.
o The proposed reduction in inspection frequency is consistent with the conclusions of actions
analyzed. and selected in the Environmental Assessment (EA) dated April 1997.o The proposed change does not require any change to the financial surety arrangement or
amount.
As per License Condition 9.4(D), this change evaluation will serve as the requisite written
Environmental and Safety Evaluation documenting the SERP's basis for determining that the
proposed change is in compliance with the requirements referred to in License Condition 9.4@).
This evaluation and associated finding will be described in the annual report to the Executive
Secretary summarizing changes made to the approved license application.
SCM SERP SEE-9-2OO9 lnspection Frequency rev-Zclean.doc 3 Of 4 Ll22lTOLO
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Shootaring Canyon Mill
I Safety and Environrnental Review Panel
I Inspection Frequency Change Proposal
Safety and Environrnental Evaluation 9129109
I
T ATTACHMENTA
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SECTION 5 OF TTIE LICENSE RENEWAL APPLICATION
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5.0 oPERATTONS
Section 5.0 presents the corporate organization, managemelt, ALARA commiunent, employee
qualifications, training, security, and monioring pmgrams used to control source materials both wifrin the
mill and in the environment around the mill. Four monitoring programs arepresented:
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Table 5.5-l
Table 5.5-3
Table 5.5--'7
Table 5.5-8
Plateau Resources Limited. Source Material Licensc
No. SUA-1371, NRC Docltet No 40-8698. March I, 1996
Operational Mill Monitoring Program,
Interirn Mill Monitoring Program,
Operational Environmental Monitoring Program,
Interirn Environmental Monitoring Program.
The "Operational' programs apply to the mill when it is in norrral commercial production of yellowcake. In
contrast the "Interim" programs apply to the mill when it is in an interim or sandby stah$ when no
yellowcake is being produced for 30 days or more. Similarly the "Mill Monioring Programs" refer to
monitoring within the mill and the "Environmental Monioring Programsn refer to monitoring in ttre
environment outside the mill.
5. I coRPoRATE ORGANIZATION ANp ApMrM$IRATI\rE PROCEDIJRES
The Plateau Resources Limitd corporate headquarters are Iocated at 877 Norttr 8th West, Riverton, WY
82501 (3ffi) 856-gnl. The Shootaring Canyon Uranium Processing Facility site offices are located at
Ticaboo, Utflh84734.
The Vice President of Milling has overall policy and management responsibilities of the Shootaring Canyon
Uranium Mill. The Mill Superintendent will be responsible to enforce the policies and manageruent, the
Mill Superintendent will be the on-si@ auhority.
The organization structure of the company presented in Figure 5.1-l has been designed to provide separate
reporting ctrannels for the ERHS or his subordinate (in case of the absence of ttre ERIIS) to assure
compliance with the Radiation, Health and Safety pro$ams. Mill production is the responsibility of the Mill
Superintendent. Reponing to ttre Mill Superintendent are all deparrnents within the milling facilities.
The Environmental and Radiological Health Supervisor (ERHS) who serves as the Radiation Safety Officer
(RSO) is responsible for implementing all radiological and environmental monitoring procedures and for
compliance with he regulations and requirements administered by the U.S. Nuclear Regulatory Commission
(IIRC) and the Mine Safety and Healttr Administration. Radiation safety, industial saftty, occupational
monitoring, qualrty assurance, environmenhl monitoring programs and ALARA audits are the responsibility
of EMS. The ERHS prepares and modifies procedures and assists tho Director of Regulatory Aftirs in
licensing activities. In addition ttre ERIIS has ffre authority to partially or fully suspend operations that could
be hazardous to workers. Reporting to tre ERIIS are the Environmental Techniciurs who conduct he
required sampling and monitoring and provide respirators and protective clothing for the mill workers. The
Director of Regulatory Afhirs is responsible for all licensing and pennitting of the mill and for the
submission of surety bonds and License Amendments to the NRC.
5.1.2 MANAGEMENT CONTROL PROGRAM
Written operating procedures have been esublished for routine production activities involving the handling
and processing of radioactive materials and include routine radiation safrty practices. Non-routine
operations posmg a radiological healtr risk to workers require review of the procedures by the ERHS or his
staff and the issuance of a radiation work permit whictr establishes the radiological health protection
measures. Emergency pror:edures are presented in Appendix A. Copies of the operational procedures and
the radiation safety procedures are available at the mill site and are discussed in the following sections.
Plarcau\Permits\s uA-37 I \ I 996\Sec5
Renewal Application 03/01/96
Cornpiled Application 02102198
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Organizational Ghart.l
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Chief Operating Officer
Corporate Headq uarters
Director
of Regulatory
irs
Mce President
Milling
MiII
Superintendent
Environmental &
Radiological
Health
Supervisor
(ERHS) (Rso)
Metallurgical
Accountant
Environmental
& Safety
Technician
Radiation
Technician
Personnel General
Foreman
Operations
shift
Foreman
Maintenance
Foreman
Hourly
Force
Hourly
Force
Metallurgical
SuFervisor
Chernis
Metallurgical
Laboratory
Force
Laboratory
Force
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All written procedures for both operational and nonoperational activities were reviewed and approved in
writing by the Mill Superintendent and ERHS before implemenution and whenever a change in procedure is
proposed to ensure that proper radiation protection principles are being applH. In addition, the ERIIS shall
perform a documented review of all existing operational procedures at least annually during operations and
at least once e\rery two years during extended periods of nonoperations. Obsolete procedures are del*ed or
updated during the review and new procedures are added as required.
5.1.3 VISUAL INSPECTTONS AND REPORT TQ.UI-ANAGEMENT
During normal mill operations the ERHS or a designee conducb a weekly visual walk-through inspection of
ttre mill and the ore stockpiles. The primary purpose of this inspection is to observe work practicq and
working conditions in ttre mill to minimize the spread of contamination and to maintain exposures to levels
that are as low as reasonably achievable. Observations are documented weekly and eactr morth during mill
operations the ERHS provides to the Mill Superintendent and Vice President of Milling a written summary
of visual observations made in the mill. During non+perational periods lasting 30 days or more,
documented visual inspections will occur quarterly.
5. [.4 ALARA PHILOS-p,PHY
The purpose of the radiation protection program at Plateau is to mainain radiation exposures to levels trat
are as low as reasonably achievable (ALARA) for all employees, @ntac'tors, visitors, and members of the
general public. The implemenation of a successful ALARA program is the responsibility of everyone
inrrolved in the processing of uranium ores. Responsibilities for the ALARA program are shared by the
Vice President of Milling, Mill Superintendent, the ERHS, and all mill workers. The ALARA policy for
Plateau Resources Limitd is as follows:
ALARA . POLICY STATEMENT
Plateau Resources Limited is firmly committed o the philosophy that occuptional exposures
to radiation be kept at lwels that are "as low as is rea^sonably achievable (ALARA)."
Implementation of the ALARA prograrn is the responsibility of every employee by adhering
to all rules, notices and operating procedures for radiation safety, by promptly reporting b tlte
ERHS and supervisors any equipment malfunctions or violations of standard procedures that
could result in increased radiological hazxd to any individual, and by submitting suggestions
for improvements in ALARA progam.
The ERHS and staffare responsible for ffre technical adequacy and correctness of he ALARA
progpm, the enfbrcement of the program and tre surveillance to ensure funue compliance
with the program.
In summary, Plateau's commiEnent to ALARA requires the involvement of every employee to
accomplish our objective of maintaining occupational exposures as low as reasonably
achievable.
Semiannual ALARA-Ouality Assurance Audis
The ERHS shall conduct a semiannual audit of operming procedures, o(posure records, monthly inspection
reports, and training programs to evaluate the overall effectiveness of tre program and adherence to the
ALARA philosophy during operational stah$. During nomperational status an annual AI AItr\ audit will
be conducted and documentecl. Audit results and annual ALARA audit shall be documented and sent to the
Vice President of Milling, Mill Superintendent, and to ttre Chiet, High-Level Waste and Uranium Recovery
Projects Branch. Division of Waste Management, Office of Nuclear Materials Safety and Satbguards,
Nuclear Regul atory Comrnission.
Plateau Resourtes Limiled. Source Material License
No. SUA-1371. NRe Docket No 40-8698. Maruh l. 1996
Plareau\Permits\s uA-371 \ I 996\Sec5
Renewal Application 03/01/96
R.evision 0?/02/98
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lo 5.2 OUAL.IFICATTONS
The minimum Enlffications for the ERII,S are:
1. Education: A bachelor's degree in the physical sciences, industrial hygiene, or engineering from an
accredited collqge or university or an equivdem combindion of training and relevant experience in
ruranium mill radiation protection. Tlvo years of relevant experience will generally be considered
equivalentrc one year of academic stndy.
2. Health Phpics experience: At least one year of uranium mill work opuience in applied healtl
physics, radiation protection, indusrial hygiene, or similar area. This e,:rperience should involve
acurally working with radiation detection and measurement equipment, not stictly administrative
work.
3. Specialized taining: At least four weeks of specialized classroom training in health physics.
4. Specialized knowledge: A thorough knowledge of the health physics equipment's used in the mill, the
chemical and analytical procedures used for radiological sampling and monioring, methodologies used
to calculate personnel exposure to uranium and its darghters, the uranium milling process, and the
mill hazards and their control.
The minimum qualifications for an Environmental and-SafEv Technician and Radiation Techdcian are:
I 1. Blucation: An associate degree or two or more years of shrdy in ttre physical sciences, engineering,
or a health-related field,
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2. Training: A btal of four weeks of generalized training (up to two week may be on+he.job taining)
in radiation health protection applicable to uranium mills,
3. Experienco: One year of work experience with sampling and analytical laboratory procedures used in
health physics, industrial hygiene, or industrial safety measures applicable to a uranium mill; or
1. Education: A hrgh school diplom4
2. Training: A total of at least three months of specialized taining (up to two monfts may be on-
the-job training) in radiation health protection
3. Experience: One year of relevant work experience in applied radiation protection, and a working
knowledge of healh physics instnrmenB, surveying and sampling tectrniques, and personnel
dosimetry.
5.3 TRAIMNG
The radiological protection training program coruists of basic radiation protection training for new
employees and contractors, on-the.job training, annual refresher raining. Compluion of each 6pe of
training will be documented on a form which includes (1) the dates of the naining, (2) the content of the
training, (3) the trainee's signature indicating that the raining was received, and (4) the instructor's
signatue. This training record will be mainained on file.
All nEr employees are instmcted in the inherent risks of exposure to radiation and ttre fundamentals of
protection against exposure before beginning ttreir jobs. A copy of the Radiological Safetv Trainine Manual
is included as Appendix C.
Plateau Resources Limited, Source Material License
No. SUA-1371, NRC Dosket No 40-8698. March l, [996
Plareau\Permits\s UA-37 I \ I 996\Sec5
Revision O4lL7l97
Cornpiled Application 0?/02/98
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Plateau Resources Lirnited. Source Material License
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No. SUA-137[, NRC Docket No 40-8698. March I, 1996
A written exam on the principles of radiation protection in uranium milling will be grver b each new
employee. The instnrctor will review the test results witr each worker and discuss any wrong answers ririth
the employee until he understands the correct answers. The minimum acceptable test score is 70%.
Employees who fail the test will be retested after receiving additional training. These tesB and results will
be maintained on file.
All new employees, including superuisors, will receive individualized on-the-job fraining on the health and
radiation zupects of &e specific jobs they will perform. This instnrction may be given by a palified
supervisor experienced in the assigned tasks, or other person experienced in the assigned tasks. In addition,
supenrisors will receive additional specialized raining on their supervisory responsibilities in the area of
worker radiation protection.
Each permanent employee, including supewisors, will receive reftesher training annually. The refresher
trainirry will include a review of &e radiation protection opics applicable to uranium miling, ctranges in
re,gulations and license conditions, exposue teuds, and other curent topics in radiation protection. Exams
will be grven at the end of the reftesher taining @urse.
Safety meetings lasting t least 30 minutes will be held at least once every two months during mill operations
to discuss matters of concern that arise during plant operations and may include instruction as part of the
annual refresher training. The saf*y meetings will also be used to reinforce the AI ARA program by
encouraging employees to participate in the identification of ways to reduce occupational radiation
exposures.
During periods of utended nonoperations lasting 30 days or more, safety meetings will be suspended. The
method for disributing satbty information will be commensurate with the number of employees at the mill
and the tlpe of work being performed. For example, when it is not tbasible to conduct a meeting, satbty
bulletins may be used.
All visitors who have not received uaining in radiation protection will be escorted by someone properly
trained and knowledgeable about ttre hazards of the mill. At a minimum, visitors will be instructed
specifically on whm they should do to avoid possible hazards in areas of the mill they will be visiting.
Contractors having work assignments in the mill will be given radiation protection training applicable to
their work and the radiological conditions they may encounter in the mill. Conuact workers who will
perfurm work on heavily contaminated equipment will receive the same radiation safety instruction normally
required of permanent e-ployffis. After receiving this training, contractors may be allowed to perform their
duties witrout escort.
The ERHS will attend reftesher courses in health physics every two yurs usually at an off-site location.
The Environmental Technician will receive documented retraining every two years ftom the ERIIS or other
qualffied persons.
5,4 SECURITY
The boundary limits of the processing facility are posted and enclosed by a fence except for sectioru where
cliffs or other topographic features form a natural boundary. The process plant, mill ore storage area,
ancillary facilities (such as laborabry, office building, warehouse and maintenance facilities, electrical power
distribution, and reagent storage), and the entire tailings disposal area iue located within the restricted area
boundary of the thcility. The resuicted area is posted with signs that state "Caution Radioactive Materials."
The requirements of l0 CFR 20.19A@) are met by Materials License SUA-1371 Condition 9.9 which allow
Plateau\Permits\S U A-37 I \ I 996\Sec5
Renewal Application 03/01/96
Revised 0?lOZl98
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the posting of all entrances to the mill wittr the words "Any Area Within This Mill May Comain Radioactive
Material.'
Access to all arru, except ttre general office building, employee parking and visitor puking, ue contolled
by fences and gates. Warning and information signs are posted near the main gate. Twenty-foru hour
security will be provided when the processing facility is in operation. During extended periods of
nomperation, access to 0re resnicted uea is through the main gate which is locked when pusonnel are not
present. AII fencing and gates will be inspeced on a semianrual schedule during the extended period of
noaoperation by security personnel or other responsible errployees to insure system integrity. This
inspection will be increased to monthly during operation. The results of the inspections will be recorded in a
log.
Visibrs, including conffict workers to the plant, will be admited only by permission from Mill
Superintendent or ERHS. Eactr visitor will be checked in and out on a visitors' register and will be escorted
while in the resticted area. All visitors are required m read and srgn ahazad training fom. A list of
authorized personnel who have completed training or have been authorized to enter the resticted area is
mainained in the mill office. Visitors are given instnrctions on how to avoid possible hazards in fte mill.
After receiving the training described in Section 5.3, temporary workers such as repairmen or contractors
may be allowed to perform their duties without escort.
5.5 BADIATION SAFETY
Radiation Work Permits (RWPs) will be issued to cover nonroutine activities posing a radiological risk o
employees and for which no stardard writren procedure already exists. The RWP shall be slgnd by the
ERHS or his designee and shall describe the following:
1. The scope of work to beperformed,2. Any precautions necessary to reduce exposureto uranium and its daughters,3. The supplemental radiological monioring and sampling necessary prior to, during and following
completion of ttre work.
The radiological monitoring program to be used wi&in the mill during mill operations is summarized in
Tables 5.5-1. The sampling and monitoring locatiors are listed in Table 5.5-2. The radiological monitoring
program to be used within the mill when the mill is NqIf in operation for 30 days or more (interim period)
is summarized in Table 5.54. Survey instruments and monioring equrpment used in both progralls are
presented in Table 5.54, along with their sensitivities and ranges.
Laboratory procedures when performed in ttre Plateau Resources Limited laboratory are contained in
Appendix E. Table 5.5-5 summarizes the lower limits of detection for the analysis of radionuclides in
different tlpes of samples. All zurvey instrumenE ae calibrated semiannually or at dle manufacturer's
suggested interval, whichever is sooner. Air samplers are calibrated quarterly. Calibration procedures are a
part of the radiological and environmental monioring procedures &at are presented in Appendix F.
The resulE of audie and other reviews of the radiation protection program, and ttre resuls of sunrep and
calibrations will be retained tcr 3 years after the record is made. All ottrer records will be r*ained until the
NRC terminates Materials License SUA-1371. Those records include records to determine dose from
c.(emal sources, records to determine individual intakes of radioactive materials, measurements and
calculations of releases or radioactive effluents o the environment, and records of doses to individual
members of the public.
The purpose of the radiological monioring program is b maintain radiation exposures to levels drat are as
low as reasonably achievable. Sections 5.5.1 through 5.5.8, which follow, address both the operating mill
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Plateau Resources Lirnited. Source Material License
No. SUA-1371. NRC Dockct No 40-8698. March I. 1996
Plateau\Permits\SuA;3 7 1 \ I 996\Sec5
Renewal Application 03101196
Compiled Application 02,10719E
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monitoring prograrns and the interim rnill operating programs for those time periods when the mill is NOT
in operation for 30 days or more. Where program commiments vary betrveen the trpo programs,'the
operational program commitnens will be sated firsq followed by he interim program commitments in
parentheses.
Trend analyses are an ongoing process conducted by the ERHS or his staff. Whenever new monioring data
are available, these data are compared to existing daa to determine if values are abnormally elevated. The
analysis of trends of gradually increasing or decreasing monioring daa requires that data be collected over
enough time to observe the tends. Thus, in addition o the review and analysis of monitoring daa as they
are mllected, an annual trend analysis of mill and environmental monioring data is conducted and
documented.
5,5. 1 suRvEYs ANp ASTION LE\rEr^S FQB- EX*TERNAL RApTAIION
Most, but not all, mill workers receive external gamma radiation doses of less than 1.2 rem per year.
Gamma radiation CI(posure rates are generally below I rnr/hr in contact with incoming ore and are about I
mr/hr in contact with ftesh yellowcake. Due to the build-np of the uranium daughters in fresh yellowcake,
the radition levels increase following yellowcake production.
Gamma radiation surveys are performed semiurnually throughout the mill at a minimum of 20 areas
rryresentative of where workers are exposed. The surveys are used to determine if an area needs to be
posted as a "radiation areas" and to identif sources of elevated gamma lwels. See Table 5.5-2- The ERHS
can then evalude muhods to lower exposure rates to levels that are AI.AtrlA. Gamma surveys perforrred
for this purpose must be represmtative of where both routine and non-routine work is performed so ttrat
their whole-body radiation exposures can be estimatd. Thus, measurements are generally made at about
waist height and L2 inches from surfaces. Surface ncontact" exposure rate measuremenb are not used for
establishing radiation area boundaries or estimating personnel whole-body exposures because ftese exposures
would not be represmtative of the worker's true exposures.
The gamma radiuion surveys are surrunarized in the monthly repor6 submitted from the ERHS to the Vice
President of Milling and Mill Superintendent who review the repors for possible corrective actions to reduce
exposures.
To determine ttre need for personnel monitoring, the radiation exposures expected for each category of plant
worker may be calculated from measured radiation levels and predicted occupancy times. As a general
policy Plateau issues a personnel radiation dosimeter, i.a, a thermolurninescent dosimeter (ILD) to all mill
operabrsr. (During interim period operators are not badged). If external radiation doses to any group of
workers are siguificanfly elevated mmpared to other groups, the ERHS will investigate fie cause and will
take conective actions that will roduce exposures o levels that are ALARA.
During full operations at the mill, TLD badges will be used by mill operations personnel. TLDs are to be
worn at all times when operators are at work. No employee is allowed to take a TLD home. During non-
work time TLD badges are to be stored on TLD racks that have a background control TLD badge, results of
the control TLD badge can be deducted from the individual TLD results.
The sensitivrty and range of the TLD badges are presented in Table 5.54, along with the other suvey
instnrmens and monitors used in ttre program.
5.5.2 S..URVEYS FOR AIRBORNE MDIONUCLIDES
The following sections describe surveys for airborne uranium ore dust, yellowcake and radon progeny.
Appendix E contains laboratory analytical procedures. Appendix F contains tre radiological and
l
Plateau Resourpes Limited. Source Material License
No. SUA-1371. NRC Docket No 40-8698. March l. 1996
Plateau\Perrnits\S UA-3 7 I \ I 996\Sec5
Renewal Application 03/01/96
Cornpiled Application tr210"198
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I(l environmental sampling and monioring procedures. Air sampler calibrations trat are perbrmed quarterly
are presented in that appendix.
5.5.2. I s_uRvEYs AIRBORNE PARTTCULATES
Surveys for airborne uranium ore dust are necessary to:
l. Dernonstate mmpliance with the 10 mg soluble uranium weekly intake limit for workers specified in
10 CFR 20.1201(e).2. Determine the areas that need to be posted as "Airborne Radioactivity Areasu as specified in 10 CFR
20.1003.3. Determine whether precautionary procedures, such as process or o'ther e,ngineering contols,
limiations on working times, use of respiratory equipment, or other precautions need to be
implemented.4. Determine whether exposures to radioactive materials are being mainained to levels ttrat are ALARA.
Breathingzone and area air samples are used to determine the radionuclide concentrations is air breafred by
mill workers. The DAC for uranium ore dust is 6.0E-t I mCi/ml of gross alpha in air or 3E-1 I mCi/ml of
nanrral uranium in air. Where uranium ore dust appmaches or exceeds I DAC, the source of the dust is
identified and mrrective actions implemented to reduce ttre dust concentrations tro levels that are ALARA.
For areas in the mill that are not predomhately ore dust areas, fie DAC is 3E-12 mCi/ml for Th-230 class
W on a DAC for the mixture of radionuclides present in the mill. Plateau's "Procedure for Calculation of
Radiation Doses to Personnel," revision 8 presents tre methods for calculation of DACs for a mixurre.
5.5.3 RESPONSIBTLIIy, pF RADIATION TECHNICIAN (RT) AND_
E-NyIRONMENTAL/SAFETYTECH_LI_rCrAJ!.IFST)
The RT shall be responsible for the sample collection and/or inspection of the following:
r The Mill Radiological Monitoring Program as outlined in Table 5.5-1.. The Interim Mill Radiation Safety Monitoring Program as outlines in Table 5.5-3.. The Radiation Survey Instrumentation and Dosimeters in Table 5.5-4.r The RT will be familiar with all responsibilities of the EST should the EST require a back-up.
The EST shall be responsible for providing respirators and protective clothing for the mill workers and
the sample collection and inspection of the following:
. Program as outlined in Table 5.5-7.. The Interim Environmental Program as outlined in'Table 5.5-8.
o The EST will be familiar with all responsibilities of the RT should the RT require a back-up.
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Plateau Resources Limited, Source Material Licen.se
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No. SUA-1371, I{RC Docket No 40-869E. March l. [996
Plateau\Permits\SuA-37 t \ I 996\Sec5
Revision 04/17197
Compiled Application 02/0?/98
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Plateau Resourcos Limited, Soulre Materia[ License
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No. SUA-1371, MC Docket No 40-8698. March I, 1996
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Plarcau\Permits\s uA-37 I \ I 996\Sec5
Renrlwal Application 03/01/96
Compiled Application O2l0?198
Table 5.5-l
MILI,S RADIOLOGICAL MONITORING PROGRAM - OPERATIONAL
Sample Collection or Inspection
Type Location Frequency Method Parameter to be
Measured
MilI airborne
particulates
See Table 5.5-2 Occupied Areas
Daily > 1.0 DAC
Weekly 0.3-1.0 DAC
YC Precip.
Quarterly 0.01-0.3
DAC.
none < 0.0[ DAC
Breathing zone
samples for > 0.1
DAC, iuea air sarnples
may be used tbr 0.01-
O.T DAC
Yellowcake or ore
dust
Radon progeny See Table 5.5-2 Weekly >0.08 WL
Monthly 0.03-0.08
WL
Quarterly < 0.03 WL
Modified Kusnetz Radon daughters
Mill garnma See Table 5.5-2 Semiannually Gamma suryey meter Gamma
Personnel garnma Mill operations
personnel
Quarterly TLD badge Gamrna
Surface
contamination
Eating irreas, change
ztreas, control rooms
Weekly if above 500
dpm/100 cmz
otherwise every two
weeks
Alpha smear and
surface rneasurement
Removable, average
and mzu( alpha
Administrative offices Quarterly Alpha smear and
surface measurement
Rernovable, average
and max alpha
Personnel Leaving restricted area Alpha surface
measurement
Alpha
Urinalyses Uranium workers,
including packaging
operators, SX-
precip itation op erators
and shift foreman
Monthly Urinalysis U-nat
In-vivo lung count Mill personnel wittr
work assignments in
airborne radio activiry
zlreas
After large accidental
intake
Gamma lung count Uranium
Water flow and
pressure drops
Yellowcake scrubber Approximately every
four hours during
operations
Documented visual
inspection
Water flow and
pressure drops
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I rwhere electrocles are accessible.
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Plateau Resourpes Lirnited, Sourre Material License
I
No. SUA-1371, NRC Docket No 40-8698. March I, 1996
Plateou\Permits\SuA-37 I \ t 9 96\Sec5
Renewal Apptication 03/01/96
Compiled Application O2lOZl98
Table 5.5-l
MILIS RADIOLOGICAL MOhIITORING PROGRAM . OPERATIONAL
Sarnple Collection or Inspection
Type Location Frequency Method Parameter to be
Measured
Instrument
calibrations
All instruments in use Semiannually or mfg's
suggested interval
whichever is sooner
Voltage plateaut
Rrlse
Source
Instrument response
Air sampler
calibrations
Air samplers in use Quarterly Bubble tube or
equivalent
Flow rate
Visual inspections Mill work and storage
areas
Daily
Documented Weekly
Visual inspectiorn Radiation work
practices
Trend analyses N/A fuinually Routine monitoring
programs
Trends
Reports N/A Monthly Summary of mill and
environmental
rnonitoring data
N/A
Radiological &
Operational
Procedures
N/A Annual Review N/A N/A
ALARA audit N/A Annually N/A N/A
Fence Perimeter Monthly N/A N/A
Radiological
survey of
equipment leaving
restricted atea
N/A As required Alpha surface
measurement alpha
smear if > 75 cpm
Beta-Garnma
Alpha, Beta-Garnma
Respiratory
protection program
As required by RWP
600 atea
Weekly in YC precip.N/A N/A
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Ptateau Resourtes Limited, Source Material Licensu
No. SUA-1371. NRC Docket No 40-8698, March l. 1996
Plateau\Permiu\S UA-37 I \ I 996\Sec5
Renewat Application 03/01/96
Compiled Application O?,lOZl98
Table 5.5-2
AIRBORI\E RADIATION SAIUPLE LOCATIONS
l. Ore feed hopper
2. Ore conveyor gallery
3. Ore sampling preparation area
4. Semi-Autogenous mill ore feed iuea
5. Semi-Autogenous mill ore discharge area
6. Leach tank arsa
7 . Countercurrent Decant thickener area
L Solvent extraction area
9. Yellowcake precipitation tank area
[0. Yellowcake thickener area
11. Yellowcake drum filter area
L2. Yellowcake drier area
13. Yellowcake packaging area
L4. Yellowcake storage area
15, Laboratory area
16. Lunch area
l7 . Change room
18. Maintenance shop area
19. Shitt foreman office
20. Main office area
5-10
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2lnstruments nay be calibratal as I group or a given instnrment may be calibrated prior to use.
3Where electrodes are accessible
a,When the radiation source calibration inclicates a loss in detector emciency of l0% or more.
5-11
Plateau Resources Lirnitcd, Source Material Licensc
No. SUA-[371, I*IRC Docket No 40-869E, Marsh l. 1996
Plareau\Permits\SUA-37 I \ I 996\Sec5
Renewal Application 03/01/96
Compiled Application 02102198
Table 5.5€
INTERIM MILL RADIATION SAtrETY MONITORING PROGRAM
(Mill not operational for 30 days or more)
Sample Collection or Inspection
True Location Frequency Method
Mill airborne partlculates Representative
workers performing
maintenance inside
600 area
When maintenance is
performed under an
RWP
Breathing zone
Radon progeny 600 areaz Prior to working in
600 area under an
RWP
Area or lapel sampling,
modified Kusnetz
Mill garffna N/A None N/A
Personnel gamma None None N/A
Surface contamination
suryeys
Offices Semiannually Surface srnear, surface
measurernent
Lunchrooms areas,
control rooms
Semiannually Surface smear, surface
measurement
Change rooms Semiannually Surfacg smear, surface
measurement
Urinalysis Mill employees
performing
maintenance work
under RWP
As required by RWP
with follow-up as per
Reg. Guide 8.22
Fluorirnetry
In-vivo lung count N/A None N/A
Instrument cal ibrations AII instruments in use Semiannually or mfg's
suggested intenral
whichever is sooner'
Voltage plateauo
Pulse
Source
Air sampler calibrations Air sarnples in use Prior to use Bubble tube or equivalent
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Plqteau Resourscs Limited, Source Material License
No. SUtu1371. f{RC Docket No 40-8698. March l. 1996
Plateau\Permits\SuA-37 I \ I 996\Sec5
Renewal Application 03/01/96
Compiled Application W,102198
Table 5.53
INItsRIM MILL RADIATION SATETY MONITORING PROGRAM
(MiII not operational for 30 days or more)
Sample Collection or Inspection
T)rye Losation Frequency Method
Visual inspections Mill work and storage
areas
Quarterly Documented visual inspection
Trend analyses N/A Annually Routine monitoring programs
Reports N/A N/A As specified above
Radiological & Operational
Procedures
N/A Every 2 years Review and approval
Quality assurance audit N/A Annually Audit by quality assuranse
consultant
Fence Perimeter Semianuually Visual inspection of fence and
signs
Radiological survey of
equiprnent leaving restricted
area
N/A As required by Annex
A
As required by Annex A
Resp iratory protection
program
As required by RWP As required by RWP N/A
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Plateau Resources Lirnited. Source Material License
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No. SUA-1371, I.IRC Docket No 40-8698, March l, 1996
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Plateau\Permits\S UA-37 I U 9 96 \S ec 5
Renpwal Application 03/01/96
Compiled Application 02/02/98
Table 5,5-4
RADIATION SURVEY INSTRI.JMENTATION AI\D DOSIMETER.S
Instrument Mfg'Model
No.*
Detector'Sensitivity or
Effisiency
Portability Measurement
Range
Inventory
Alpha
Counter
Eberline SAC-4 ZnS Scint.80% of 2 pi
P\r2 3 e
No Six Decade 2
Count Rate
Meter
Eberline E-140 GM Tube t5% Full
Scale
Yes 0.5 to 50
mr/hr 600 to
6OK CPM
Inv.
Gamma
Sunrey
Eberline E-130M GM Tube t5% Full
Scale
Yes 10 to 1000
mr/hr
1
Micro R
Meter
Ludlum t9 tttx 1 "
NaI(t1)
Scint.
tSTo Full
Scale
Yes 0-5K uR/trr I
Ratemeter-
Scaler
Eberline PRS-2 zEt4
coulombs
Yes Six Decade 2
Portable
Scaler
Eberline PS-2 2ET4
coulombs
Yes Six Decade 2
Alarm Rate
Meter
Ludlum 177 40 MV.No 0 to 500K
crnp
3
Pulse Rate
Meter
Eberline PRM-6 L,SVo Full
Scale
Yes 0 to 500K
cpm
I
Beta-
Gamma
Probe
Eberline HP-At0 GM Tube 40 KEV-
1.25MEV
Yes 2
Alpha Scint
Probe
Eberline AC-3-8 ZnS Scint 59 cpm/dprn Yes 4
Alpha Scint
Probe
Ludlum 43-5 ZnS Scint Yes 3
5-13
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Equivatent instrurnentation or dosimeters may be used.- (.*-/ "Applicable to full mill operations.
Plateau Resourres Limited, Source Material LicenseI No. SUA-1371, hlRC Docket No 40-8698, March l, 1996I
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Plateau\Permits\S UA-3 7 I \ I 996\Sec5
Renewal Application 03/01/96
Compiled Application 07102198
Table 5,5-4
RADIATTON STIRVEY INSTRT'MEI{TATTON AND DOSIMETERS
Instrument Mfg'Model
No.'
Detector'Sensitivity or
Effrciency
Portability Measurement
Range
Inventory
Alpha Scint
Detector
Eberline SPA-[ZnS Scint 75% of 4 pi Yes 2
Scintillation
Probe
Eberline SPA-3 ZxZ NaI
Gl)
1200K cpm
per mr/hr
Yes 2
Air Sample
Pttmp
Bendix 4 Yes E 2
Thermo-
luminescent
Dosimeters
Eberline TLD 10 mrem
giilma
Yes 10-10t mrem
gamma
exchanged
5-14
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If the measured concentration is higher than the LLD, then the laboratory procedure need only be
adequate to measure the actual concentration- Then the sandard deviation should be no greater than
10% of the measured value.
Table I column 3 is abbreviated TlC3.
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Plqteau Resources Limited, Source Matcrial License
No. SUA-137I. I{RC Docket No 40-8698, March t. 1996
Plateau\Permits\Su A-37 I \ I 996\Sec5
Revision I l/15/96
Compiled Application 02102198
Table 5.5-5
LOWER LIMITS OF DETECTIOT{
Radionuclide Sample Type pCi/rnl Source of LLD
U-nafural Occupational Air
Ore Dust
Environ. Air
Water
Soils
Urine
5E-[ 1
2E-t2
9E-15
3E-8
2E:7 pCi/g
5 pg/liter
l0% 10 CFR App.B, TlC3"
l0%o l0 CFR App.B, TlC3
l0Vo l0 CFR App.B, TZCI
l0To 10 CFR App.B, T2Cl
R.G, 4.T4
R.G.8.22
Th-230 Occupational Air
Envirorl. Air
lVater
Soils
Veg., Food, Fish
6E-13
3E-15
lE-8
zB:l
2E:7
IlVo 10 CFR 20 App. B, TlC3
10 % 10 CFR 20 App, B, T2C1
l0To 10 CFR 20 App. B,T2;cz
R.G. 4.14
R.G. 4.L4
R*226 Occupational Air
Environ. Air
Water
Soils
Veg., Food, Fish
3E-11
9E-14
6E-9
7E-7
2E-7
LVTo 10 CFR 20 App. B, T1C3
l0 7o 10 CFR 20 App. B , TZCL
L0% t0 CFR 20 App. B, TzCz
R.G. 4.14
R.G. 4.L4
Rn-222 with daughters Occupational Air
Environ. Air
3E-8
1E-10
10 CFR 20 App. B, TIC3
10 CFR 20 App. B, TzCl
Pb-210 Environ. Air
Water
veg.
6E-14
LE-9
1E-6
10 % t0 CFR 20 App. B, TZCI
10To 10 CFR 20 App. B, TZCZ
R.G. 4.14
Po-210 Environ, Air
Water
9E-14
4E-g
10 % l0 CFR 20 App. B,TZC2,
10 To 10 CFR 20 App. B,TZCZ
External Gamma Air 0. I mR/hr R.G. 8.30
Surtace Contamination Surface 500 dpm/
100cm2
R.G. 8.30
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Plateau Resourues Limitcd. Source Material Licensc
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No. SUA-1371. NRC Docket No 40-8698. March l. 1996
I1;
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The sampling frequency for airborne radionuclides in the mill is dependent on the concentation measured in
the air and ranges from:
Daily: tur > 1.0 DACWeekly: for 1.G0.3 DAC; and in ocorpied yellowcalce precipitation area
Quarterly: for 0.3-0.01 DACNone: for <0.01DAC
Sampling areas ,re specifiod in Table 5.5-2. A summary of the mill monimring data is presented to the Vice
Presideut of Milling and Mll Superintendant monthly for revieur of engineering methods tha could be used
to keep air concentrations to levels that are ALAtrU{.
Exposure to soluble uranium must be limitd to a weekly expo$ures of 40 hours at a concenuation of l0
mg/week in consideration of ttre chemical toxicity of uranium. Nonroutine ore dust and yellowcake samples
are o be analyzd and the results reviewed by the ERIIS or his designee within two working days after fre
receipt of the analyucal results by the ERIIS or his designee. Occupational dose calculations are to be
docuruented within three weeks of fre end of the calendar year. (During the interim program breathing zone
air samples are collected and andSzed when work is conducted under an RWP in the 600 area or
precipitation circuit of the mill).
Under routine mill operating conditions, breathing zone air samples are used to assess particulme
concentdiors in air breathed by mill workers where those concentrations are >0.1 DAC. In contrast area
air samples may be used to measure air concentrations in areas where the particulate concentations range
from 0.01 DAC to 0.1 DAC. Below 0.01 DAC air samples are not reErired. Using the above criteria the
ERHS makes the decision as to the type of air sampler that is most appropriate for the work conditiors.
Plateau's "Occupational Air Sampling Procedure,n revision 8 present the details of how to collect an air
sample in the mill.
The lower limit of detection for uranium air sampling is 1E-11 mCi/ml as specified in Table 5.5-5 and as
recommended in Regulatory Guide 8.30. Plateau's "Procedure for Calcul*ion of Radiation Doses to
Personnel" present how to calculmettre minimal sarpling time needed to detect a given fraction of a DAC.
5.5.2.3 SURVEYSFORRADON-222PROGEI.IY
Significant concentrdions in air of radon aud is daughters may occur near ore storage bins, near cnrshing
and grinding circuits, or in enclosed locations where large quantities of dry ore are found. At Plateau,
indoor radon daughter measurements are made in preference to radon measuremerts because the daughter
producs can build up in concentration and present a greater hazard to workers than is presented by radon
alone.
Working level measureme,ns are made at the 20 sampling locations specified in Table 5.5-2, dependent on
the fullowing working level concentrations observed in those areas:
Weekly: for >0.08 WLMonthly: for 0.08{.03 WL
Quarterly: for <0.03 WL
(Interim program - Working I+vel Measuremens are made prior to working in the 6fi) area under an
RV\D. Samples are taken to be representative of worker exposure.
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Plateau\Permits\s u A-3 7 I \ I 996\Sec5
Renewal Application 03/01/96
Compilcd Application 02/02/98
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The lower limit of detection for rudon-222 daughter measurement is 0.03 working level as specified in
Regulaory Guide 8.30. Measured values less than the lower limit of detection, including neguive values,
are recorded on data sheets.
The annual average for an rea is obtained by averaging all measured values, including yalues obtained that
are below the lower limit of detection.
The modified Kusnetr mdtrod for measur'rng working levels is used at Plateau. The procedure consists of
sampling radon progeny using a high efficiency filter for five minutes and, after a delay of 40 to 90 minutes,
measuring the alpha activity on the filter. High efficiency membrane or glus fiber filten are used to
minimize loss of alpha counts by absorption in tre filter.
5.5.2.4 ESTABLTSHMEI{T OF "AIRBORNE RADIOACII}ry-AREAS'
The yellowcake drier area and yellowcake packaging rooms are usually considered to be airborne
radioactivity areas during periods of active milling operations. In contast, ore crrshing and grinding areas
and locations outside yellowcake drying and packaging areas will not normally need o be classified as
airborne radioactive areas when normal engineering controls are used. Any area, room, or enclosure is an
"airborne radioactivity area" as definecl in l0 CFR 20.1003) if (1) the air mncentratiors exceed the DAC for
ore dust or the mixture of radionuclides present in the mill or, if the DAC for the mixnrre is not available,
ttre DAC for Th-230; or (2) an intake of 12 DAC-hs.
5.5.3 HGOSIJRE qALCI.JLATIONS AND RESPIRATORY PROTECTION PROG.RAM
Plateau"s "Procedure for Calculation of Radiation Doses to Personnel," revision 8 presents the mertrods for
determining DACs for mixtures as occurs inside the mill. In addition the procedure presenB the conversion
of units needed to calculate radiation doses, and ttre medrods for calculating radiation doses. The commiued
effective dose equivalent, the deep dose equivalent, and the total effective dose equivalent are each calculated
in the procedure. Appendix G presenS the respirabry protection program. The program was prepared
using Regulatory Guide 8.15 and NUREG4041. Reftrences within the program b the position of Radiation
Safety Olfrcer are synonymous wittr the position of ERHS used throughout this license renewal application.
5.5.4 BIOASSAY PRO-GRAM
Bioassays are required for all mill departnent personnel during both routine and non-routine operations
where reason exists that an e/rposure could exceed 30Vo of a DAC in a year. Table I of Plateau's
"Occupational Air Sampling Procedure" qpecifies tre mrrective actions to be taken in response to the resuls
of the urinalyses.
5.5.4.1 T.JRINALYSES
The urinalysis program is conducted at the mill following Regulatory Guide 8.22, "Bioassay at Uranium
Mills" and Regulatory Guide 8.25, "Acce,ptable Concepts, Models, Equations, and Assumptions for a
Bioassay Program." Details of ttre urinalysis program are presented in Appendix F. The fluorimetic
determination of uranium is presented in Appendix E. (During the interim program, employees performing
maintenance under a radiation work permit will be reErired to submit bioassay samples.) The actions taken
in response to the resulB of the urinalyses ile outlined in Table 1 of Regulatory Guide 8.22.
5.5.4.2 IN \rn/o,LUNG COUNTS
In vivo lung counts are conducted on mill workers wittr work assignments in Airborne Radioactivity areas.
(Interim prcgram - In vivo lung counts are not conducted). The In Vivo Lung counts are conducted
following Regulatory Guide 8.22, "Bioassay at Uranium Mills." The actions taken in response to the results
of the lung g:uuna counting are outlined in Table 2 of Regrrlatory Guide 8.22.
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Plateau\Permits\SuA-37 I \ I 996\Sec5
Renewal Applicatior 03/01/96
Cornpiled Application 02102198
l(j
Plateau Resources Linrited. Source fulaterial License
I
No, SUA-1371. NRC Docket No 40-8698. March l. 1996
5-17
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-a-).5.5 CoNTAMNAITON SURVEYS
Contamination of skin and personal clothing is controlled in order to prevent the spread of contamination to
umestricted areas, i.e., the workers' cars and homes. Alpha radiation from yellowcake or ore dust on the
skin or clothing is not a direct radiation hazard because the alpha particles cannot percfrate &e dead layer of
the skin. In contrast, uranium is primarily ahazad if it is inhaled or swdlowed. The instnrments used in
conuminatiou surveys are prmented in Table 5.54, along with their sensitivities or ranges. Appendix F
presents the instrument calibration procedures.
5.5.5.1 COM4,MNATTON SURVEY..S OF CLOTITTNG
Employees working in soluble uranium areas and other areas specifiod by the ERHS are provided wittr
protective s[sthing such as coveralls and rubber boots. Gloves ae issued when yellowcake will be handled.
All soiled coveralls are sent to the mill laundry usually at the end of each shift. After being larndered, the
coveralls are monitored once each month for flxed alpha. Coveralls with average readings in o'rcess of
5,000 DPM per 100 cm'or a maximum reading of 15, 000 DPM/10 cm2 are discarded. The laundry
wastewater is discharged to mill ailins.
5.5.5.2 CONTAMINATIONSURYEYS.OFPERSONNEL
Procedures for the determination of alpha emitting radionuclides on personnel leaving the resticted area of
the mill are presented in Appendix F. Table 5.56 presents the maximum allowable levels of surPace
contamination for orit from the mill. To ensure the effectiveness of the employee contamination survelNs,
contamination spot check are performed and documented by the radiation conffol staff..
5.5.5.3 COMAMINATTON SU-BVEYS OF Eq[mMENT
Surface contamination sunreys are conducted before potentially contarninated equipment is released to
umestricted areas- If contamination is detected above the values presented in Table 5.5-6. the contaminded
equipment will not be released tom the restricted area until decontaminated, resurveyed and conamination
is below the values in Table 5.5{.
5.5.5.4 CONTAMINATIONS-URVEYSFORTRANSPORTATION
Prior to shipment of barrelled yellowcake from ttre mill, the following surlrey of extemal conamination is
performed on a representative number of barrels of yellowcake.
Contamination on packages to be shipped cannot exceed Deparrnent of Transportation limis of 49 CFR
173.4E,3. The average measured removable alpha contamination determined by wiping 300 cm2 of the
qrternal strrface of the package with an absorbent material must be below 22 l>-PMlcmz if a non-orclusive
use vdricle is to be used, or 220 DPM/cmz if an exchsiveuse vetricle is to be used. Packages having higher
contaminittion levels must be cleaned and resurveyed prior to shipment. Visible yellowcake should be
cleaned offthe barrels.
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Plateau Resoulres Limited, Source Material License
No. SUA-1371. I.IRC Docket No 40-8698, Marsh l. 1996
Plateau\Pcnnits\S UA-3 7 I U 996\Sec5
Renewal Application 03/01/96
Compiled Application OZIO?198I
5-18
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I 'Where surface confimination by both alpha- and beta-gamrna-emitting nuclides exists, the limits
qstablished for alpha- and beta-gamma emitting nuclides should apply independently.
b'As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive
material as determined by correcting the counts per minute observed by an appropriate detector for
background, efficiency, and geometric factors associated with the instnrmentation.
o Measurements of average contaminant should not be averaged over more than I square meter. For
objecs ofless surface area, the average should be derived for each such object.
d The maximum contrmination level applies to an area of not more than 100 cm2.
' The amount of removable radioactive material per 100 cmz of surface area should be determined by
wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing tho
amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When
renrovable contamination on objects of less surface area is determined, the pertinent levels should be
reduced proportionally and the entire surface should be wiped.
r The average and maximum radiation levels associated with surface contamination resulting from beta-
garnma emitters should not exceed 0.2 mrad/hr at I cm and 1.0 mrad/hr at I cm, respectively,
measured through not more than 7 milligrams per square centimeter of total absorber.
5 Reprinted from U.S. Nuclear Regulatory Commission, "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special
Nuclear Material," November 1976. 5_19
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Plateau Resources Linrited, Source Matcrial License
No. SUA-1371. NRC Docket No 40-8698. March l. 1996
Plateau\Permits\Su A-37 I \ I 996\Sec5
Renewal Application 03/0t/96
Compiled Application 02/02/98I
Table 5,5-6s
ACCEPTABLE STJRFACE CONTffiON LEVEI^S
Nuclides o Average t " t Maxirnum b d r Rernovable b c r
U-nat, U-235, U-238, and associated
decay products
5,000 dprn
alpha/fOO cmz
15,000 dpm
alpha/100 cmz
1,000 dpm
alpha/100 cmz
Tren$urarrics, Ra-226, Ra-228, Th-
230, h-228, Pa-23 l, Ac-227, l-I25,
t-129
100 dpm/100 cm2 300 dprn/100 cmz 20 dpm/100 cmz
Th-nat, Th-232, Sr-90, Ra-223, Ra-
224,TJ-232, I-L26, I-131, I-133
1,000 dpm/100 cm2 3,000 dpm/100 cmz 200 dpm/100 cm2
Beta-garnma emitters (nuclides with
decay modes other than alpha
emissions or spontaneous fission)
except Sr-90 and others noted above
5,000 dpm
beta-gamma/l0O cm2
15,000 dpm
beta-gafirma 100 cmz
1,000 dprn
beta-gailtma/l00 crnz
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o 5.5.5.5 CONTA\,.AIIrATrON SURVEyS OF LUNCH ROOMS, Cr{ANG.E ROOMS. COTNBOL
ROOMS.. Ai{p ApMTMSTRATTVE OFFICES
Every two weeks during mill operations surveys for removable alpha radiation are conducted in all lunctr
rooms, &ange rooms and contol rooms that are in use (interim program - Semiannually in the analytical
laboratory, Iunch rooms). If the observed contamination levels exceed tre Table 5.5{ values, the area will
be resricted from use until the uea is cleaned to below the Table 5.5{ values. If the observed
contamination lerrels exceed 500 DPM/100 cmz, the survey frequency is inqreased to weekly until the
observed levels are below 500 DPM/100 cmz for three week in a row. Administrative offices are sunreyed
parterly for removable alpha radiation and are resricted from use and cleaned if the observed values exceed
those in Table 5.56.
5.5.5.6 CONTAI,VIINATION SURYEyS OF MILL AREAS
Visual suneys are used in the mill process areas to detect accumulations of ore and yellowcake. Yellowcake
can exist as a yellow mrerial in the solvent extraction and precipitation area of the mill or as a yellow or
black material in the packaging area. At least weekly during operations, the ERHS or a member of his saff
conducts visual inspections of accumulated dust levels and spills and work practices. (Interim Program -
Quarterly Visual Inspection.) Wet cleanup methods are used. Dry sweeping is prohibited. Special attention
is given to the cleanup of walkways, railings, areas where accumulated dust, or dried yellowcake spills could
be disnubed to generate airborne dusts for potential inhalation.
5.5.6 ENVIRONMENTAL_AND EFFLUENT MOMTORING PRpGRAM
The environmental monitoring progrcm conducted during mill operations is outlined in Table 5.5-7 and the
sampling and monitoring locmioru are indicated on Figure 5.5-l in Appendix J. The environmental
monitoring program conducted during nonoperational Snterim) periods lasting greder than one month is
presented in Table 5.5-8. The laboratory procedures used in Plateau's environmental laboratory are
presented in Appendix E. During operations, analysis will be completed by the mill laboratory with various
commercial laboratories utilized for quality assurance.on an as needed basis. See Section 7.0 on Qualrty
Assurance and Appendix I. Where program commifnens in the following descriptions vary betneen mill
operations and interim periods, the operational program commitrnents arc stated first, followed by the
interim program comminnents in parentheses.
5.5.6.1 AIBEPRNE EFFLUENT SURVEY PBOG.RAM
Table 5.5'7 presents the effluent monitoring program for the yellowcake drying and packaging stack and ore
cnrsher stack. Quarterly isokinetic samples are collected from the yellowcake stack and semiannual grab
samples from the ore crusher skck. Sampling is not conduced during ttre interim program because stacks
are not operational). The isokinetic sampling procedures are Fesented in Appendix F and were derived
from EPA stack method 5.
The environmental air particulate monitoring sites are illustrated on Figure 5.5-l in Appendix J and are
described in Table 5.5-7 (Interim - Program desoibed in Table 5.5-8). The operational environmental air
particulate monitoring stations operate continuously at five sites around the mill. (fhe interim
environmental air particulate sampling program is conducted at one downwind site for 20 hours each
quarter).
All environmental air particulate monitoring sites are accessible throughout the year, are served by elecuic
power, and meet the tbllowing criteria tor air particulate monitoring site locations as specified in Regulatory
Guide 4.14:
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Plateau Resources Linrited, Source Material License
I
No. SUA-1371. NRC Dockcr No 40-8698. Mar']h l. 1996
Plateau\Perrnirs\S UA€7 1\ I 996\Sec5
Rcnewal Application 03/01/96
Revision OZIOZI9E
s20
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1. Ioctions at or near the site boundaries and in differert sectors that have the high*t prodicted
concentrations of airborne paniarlates,2. At the nearest residence(s),3. Conhol location(s).
Action levels for boh the stack and em,ironmenal monibring Fograms are based on sampling results and
rend analyses. ff individual environmental sampling resuls approactr 10 CFR 20, Appendix B, Table tr
effiueft corcentrations or trends of increasing concenffitions as a ftnction of time from eithe,r the stack or
environmemtal sampling results, the ERIIS investigates fte carse of ttre problem. Corrective actions usrally
require adjusunenb, maintenance, or repair of the stack scnrbber systems.
Environmental rudor,-222 concentrations are moniored mntinuously at each of the five environmental air
particulate monitorfurg locatiorx. Track Etch radon monitor re changed quarterly. The qurterly exchange
ftequency allows the detector sufEcient time to accumulate a response trt is large enough to provide good
counting statistics using routine readout procedures by the vendor. (For the interim environmental
monioring program radon is not monibrd).
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Plateau Resources Limited, Source Material License
No, SUA-1371, I.[RC Docket No 40-8698, March l. 1996
Pl ateau\Permits\s u A-37 I U 9 9 6 \S ecS
Rencwal Application 03101196
Compiled Application 02i,02,/,98I
s-21
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Plateau Resources Limited, Source Material Lisense
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No. SUA-1371, NRC Dodket No 40-8698. March l. 1996
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Plateau\ Permits\S U A-37 I U 9 9 6\Sec5
Revision 04117197
Cornpiled Application 02/0?/98
Table 5.5-7
RAI'IOLOGICAL EilIYIROI{MENTAL MONITORING PR,OGRAM - OPERATIONAL
Tlpe of
Sample
SAMPLE COLLECTION AI{D MEAST]REMBNT
No.Location Method and Frequency Test Frequency Type of
Measurement
Air stack
particulates
1 Ore dump point
stack
Semi-annual grab
sample
Semiannually Natural uranium
Th-230, B;a'-2?6,
Pb-210 and flow
rate
I Yellowcake Dryer Isokinetic sample
and packaging stack
Quarterly Natural uraniun,
Th-230, Ra-226,
and Pb-210
Quarterly Flow rate
Euvironrnental
particulates
3 At site boundaries &
iu different sectors
having highest
predicted
concentrations
Continuous; weekly
filter change or as
required by dust loading
Quarterly
cornposited
Natural uraniuf,,
Th-230, Ra-?26,
and Pb-210
t At uearest residence
- Ticaboo
Continuous; weekly
filter chauge or as
required by loading
Quarterly
composited
Natural uranium
Th-230, Ra-226,
and Pb-210
I Control location Continuous; weekly
filter change or as
required by dust loading
Quartedy
composited
Natural uranium,
Th-230, Rr-226,
Pb-210
Radon )Same as for air
particulates
Continuous Track Etch Quarterly F.n-222
Grounrlwater 3 Down-groundwater-
flow gradient
rnonitoring wells
(RM-4, RM-5,
RM-6)
Semiannually Serriannually Natural uraniurl,
As, CI,
Se, pH
I Groundwater under
tailings
Annually Annually Rate and
direction of flow
I up-gradient control
well (RM-l)
Semiannually Semiannually Natural uraniwl,
As, C[, Se, pH
Surface water 2 Seeps 1 and 2 Semiannually grab
sarnples
Semiannually Natural uranium,
gross alpha, As,
Se, pH
Direct
radiation
5 Same as for ar
particulate samples
TLDs Quarterly Garnrna
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dlf,lhere electrodes are accessible
Plateau Resources Limited, Source Material License
I
No. SUA-1371. hIRC Docket No 40-8698, March I, 1996
Plateau\Permits\SuA-37 I \ I 995\Sec5
Revision 0*ll7l97
Cornpiled Application 02lOZl98
Table 5.5-7
RADIOLOGICAL ENTVIRONMEI{TAL MONITORING PROGRAM - OPERATIONAL
Type of
Sample
SAMPLE C OLLECTION AND MEAST]REIT,IET.IT
No.Location Method and Frequency Test FrequencJt Type of
Measurement
Vegetation I Animal grazing
areas downwind of
mill
Annual grab sample in
sprhg growing season
Hold sanple
for I yr;
Analyze only if
required
Th-230,Ba426,
Pb-z10
Soil 5 Same as for air
particulate samples
Annual grab samples Annually Natural uraniun
Th-230, Rt-226
Instnrment
calibration
All instrumeuts
in use
N/A Serniauntrally or at
mfg's suggested
intervals, whichever is
sooner
Voltage
plateaud
Pulse
Source
Instnrment
fesponse
Instrument
calibrations
Environmental
air samplers
N/A Quarterly Quarterly Flow rate
Surface
Evaluations
N/A Tailings
knpoundment
Daily, Monthly,
Quarterly, Per SOP
N/A ExarninatiOn
Measurements
Surveys
Meteorology 1 Continuously; wind
speed & direction
N/A N/A
Trend analyses Routine
monitoring
programs
N/A Annually N/A N/A
Reports I N/A Semiannually effluent
monitoring report
N/A N/A
Quality
assurance audit
N/A N/A Semiannually N/A N/A
Wildlife N/A Tailings
Impoundment
Daity Visual N/A Record
Observations
Security N/A Mill & Tailing
Facility
Inspection 24br.,Visual
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'Where electrodes are accessible.
Plateau Resourtes Limited, Source Material License
No. SUA-1371. I{RC Dosket No 40-8698. March l. 1996
Plateau\Permits\S U A-3 7 I \ I 9 96\Sec5
Revision 04117197
Revision lll20l97
Cornpiled Application O2l0?l9E
Table 5.5-B
INTERIM EIYVIRONMENTAL MONITORING PR,O GRAM
Mill not operational for 30 davs or more)
Type of
SampIe
Sarnple Collection and Measurement
No.Location Method and trhequency Test Frequency Type of
Measurement
Air
particulates
I Doumwind of
impouudment and ore
stockpiles
20 hrs/quarter Semiannually
composited
Natural uranium
and R^.Q2;6
Radon None N/A N/A N/A N/A
Water -
Groundwater
3 Down-groundwater-flow
gradient monitoring wells
(RM-4, RM-s, RM-6)
Semiaunually Semiannually Nahrral
uranium, As, C[
Se, pH
Water -
Surface
Water
(Seeps)
None N/A N/A N/A N/A
Direct
Radiation
None N/A N/A N/A N/A
Soil None N/A N/A N/A N/A
Vegetation Noue N/A N/A N/A N/A
lnstrument
calibrations
AII
instruruents
in use
N/A Semiannually or at nrofg's
suggested interyals,
whichever is sooner
Voltage plateauT
Pulse
Source
Surface
Evaluations
N/A Tailings Impoundurent Monthly & Yearly Per SOP N/A Examination
Measuremeut
Surveys
N/A Ore stockpiles Mouthly N/A N/A
Meteorology None N/A N/A N/A
Trend
analyses
Routine
monitoring
Drogram
N/A Annually N/A N/A
Reports I N/A Semiennually effluent
ruonitorine report
N/A N/A
Audit I N/A Annuallv ALARA N/A
Security N/A Mill & Tailing Facilitv Inspection Dailv Visual
5-24
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5.5,6.2 LIOT.IID.EFFLI'ENTSURVEYPROC.RAM
Ground and surPace waters are monitored at the locations specifled in Table 5.51, and 5.5-8, as
illustated in Figure 5.5-l in Appendix J. These locations are designed o monitor any seepage
entering surPace waters or groundwaters from the Ailings pond.
The four groundwater monitoring locdions and two surPace water monitoring locations were
selected using the following criteria stipulated in Regulatory Guide 4.14 and in the EPA Healttr and
Environmental Protection Standards for Uranium Mills, 4O CER 192, Subpart D:l. Groundwaters hydrologically down gradient and relatively close to ttre tailings impoundment
and hydrologica[y up gradienq i.e., not influenced by seepage from ailings.2. The use of indicator ctremical and radiological parametas for early detection of ailings
se€,page.3. Surface waters passing ftrough the millsite or oflsite surface wders fiat are sufficienfly close
to fre site to be subject to surface drainage from potentially conaminated areas or that could
be influenced by seepage from he tailinS disposal area. One sample collected upsfteam of
mill site and one sample collected at the dowrsteam site boundary or at a location
immediately downsteam of the location of potential iduence. Surface water results are
compared to t0 CFR 20, Appendix B, Table II effiuent concentrations and to previously
measured concentrations in the Uend analpes.
The groundwater detection monitoring program includm:
I. Location, Number and Typg of Groundwater Monitorine Wells. One up-groundwater-flow-
gradient monioring well and three down-gradient-water-flow-gradient monitoring wells, all
located with respect to the uranium mill tailings impoundment, are sampled for compliance
with the following threshold values: Arsenic = 0.W mg[, Chloride : 40 mg/L, Selenium
= 0.422 mglL, and pH = 6.8 standard units. Uranium is comparod to the 10 CFR 20,
Appendix B effluent concentration of 3E-7 mCi/ml. The up-gradient well RM-l is located
immediately north of the tailings impoundment. All four wells ue completed to ttre bottom of
the uppermost aquifer @ntrada). A summary of the well depths and screen locations for each
of the above wells is given in Table 5.5-9.
Groundwater surface elevation will also be measured semiannually to calculate groundwater
flow rate and direction in the uppermost aquifer.
3. Sanlpling and Analyti.qal Te*niques. Groundwater samples will be obained after each well
has been baild or pumped until the specific conduchnce remains constant or after two well
casing volumes have been removed from each well. Each sample will be filtered, preserved
and analped using EPA analytical procedures or the equivalent. The sampling results will be
used to determine whether a significant increase in any constituents has occurred and to
provide reasonable confidence ttrat the migration of hazardous constituents from the tailings
impoundment into and through the aquifer will be indicated.
2. MonilQlqd Parameters j4d..Frequency. Monitoring wells
sampled serniannually for ttre following pararneters: U-nat;
Background LeJels. Background
monitoring program were collecterl
RM-s and RM{ will be
se; pH
data tbr various constituents tbr the $oundwater
during tlre processing tacility's pre-operational and
sa5
Plateau\Pernrits\S UA-3 7 I \ I 996\Sec5
Renewnl Application 03/01196
Revision OZ|OZI,9E
Plateau Resources Limited. SourcE Msterial License
No. SUA-1371, NRC Docket No 40-869E. March l. 1996I
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operational periods. During the operational period, only the up-groundwater-flow-gradient
well has been utilized to obtain background data.
The monitoring of two seeps near the project constitutes the surface water monibring program. Ttre
program as outlined in Table 5.5-7 is patterned after the groundwater monitoring program whidr is
designed for the early detection of mobile species in any seepage ftom the tailings area.
Action levels for bottr surface water and groundwater monitoring programs are based on sampling
results and tend analyses. If individual sampling resule approach 10 CFR 20, Appendix B, Table I
values for groundwater samples which are obained within the resticted area of the mill, or if trends
of inoeasing concentrations as a function of time re observed, the ERIIS staff investigates the
cause of the problem. Corrective actiors involve identification of the source of ttre contamination
and possible mitigating measures, such as tre irsallation of groundwater flow barrien or seepAge
pump-back s]rstems. Analytical procedures used in the Plateau environmental laboratory are
presented in Appendix E. Currently all analyses, with the exception of pH, and conductivity, aro
performed by commercial laboraories. During operations, analysis will be completed by fte mill
laboratory with vrious commercial laboratories utilized for quality assurance on an as needed basis.
5.5.6.3 OIIIERENVIRONMENTALIVIO-MTORING
Tables 5.5-7 and 5.5-8 present ttre monitoring programs for direct radiation, soil, vegetation, and
meteorolory. Figure 5.5-1 in Appendix J presene the monitoring locations. Appendix E presenb
the analytical procedures used in fre Plateau environmental laboratory; however, all analyses of
environmental samples may be performed by commercial laboraOries.
The operational monitoring program and interim monitoring pro$ams were designed to meet fte
following criteria presented in Regulatory Guide 4.14:
1. Sample vegetation from animal grazing areas near the mill site in &e direction of the hig[rcst
predicted airborne radionuclide concentrations.
2. Sample soils and measure gamma radiation at eadr of the locations chosen for air particulate
samples.
Any increasing tend for a monitored parameter will be investigated by the ERHS or his smff to
determine the cause and identiff potential conective acrions.
Plateau ResouruEs Limited, Source Matcriul Liscnsc
No, SUA-1371, NRC Docket No 40-8698, March l, 1996
Plateau\Permits\SuA-37 I \l 996\Sec5
Renewal Application 03/0I /96
Revision 02102198t
5-26
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Meteorological monioring during operations consists of coutinual wind speed and direction
measuremens recorded on strip ctrars. That ffirmation is of value in the unlikely event of a puff-
qpe release from one of ttre mill stacks (interim program - suspension of meteorological
monitoring).
Fish sampling and sediment sampling is not conducted because of the lack of streams flowing
through the processing facility.
Table 5.$9
ffi OF RADIOIJOGICAL MONITORING WELI-SO
Well
Number
@lev)
Location of Well
Screerr Elevation
(Depth)
Water Level
Elevation
(Depth)
lDateJ
Entrada-Carrnel
Contact
Blevation
@epth)
RM-1
(44s3)
4223 4ff23(230') (430',)
4123 3gg3(330',) (470'.)
4273
(180')
lAp LeTeJ
396s
(498')
t
RM4
(4380)
ML5
(165')
4115
(265')
3915
(465')
M40
(140',)
lAp 1e791
3875
(505',)
RM-5
(4347)
4187
(r60')
4147
(200')
3977
(370',)
3977
(420'.)
4240
(107')
lAp t97el
39W
(44O')t
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RM-6
(4372)
4185
(187')
4145
Q27')
400s
(367',)
3925
(44t')
4240
(132')
lAp 1979)
3915
(457',)
@ Data obtained from Woodward & Clyde Cornultants, June 1979.
Plateau Resourpes Limited, Source Material LicensE
No. SUA-I37!, NRC Dockct No 4&8698, Marsh I, 1996
Platcau\Pcrmits\SU A€ 7l \ I 9 96\Sec5
Rcnewal Application 03/01/96
Compiled Application 02lOZl98
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5.5.7 INTERIMSTABILIZATIONPROCEDI.JRES
Since the mill last operated n PA the mill tailings in ffre tailings impoundment area have dried and have
been covered with at least one foot of soil and/or nrbble rock. The ore stockpile has been covered with at
least six inches of soil. Weekly for operational sanu and quarterly for nonoperational status visual
inspections of both the ailings and the ore stock pile are performed aod are documented. fuiy maintenance
deemed necessary on eittrer cover is performed as soon as possible after identification of the need.
During normal mill opuations, the generation of tailings dusts may be minimized by any of fte following
methods:1. Conrolled deposition of tailings slurry in select areas of each eell, such as on dry tailings beaches,2. The sprinkling of ailings solutions on dry ailings beaches,3. The periodic application of chemical dust suppressants on exposod tailings beactres not weued by
tailings solutions, and4. Covering t1s tailings wittr an interim @ver.
Dusting from the ore stoclqile areas is conholled by any of thefollowing meflrods:1. The formation of a crust on the sorod oreby rainfall,2. Spraying the ore pad area and/or the ore pile wittr a chemical dust suppressant,3. Sprinkling the ore pad area and/or the ore pile with water, and4. Covering the ore with an interim cover.
5.5.8 PERFORMANCE. OF TIIE MILL VENTILATION AND EFFLUENT COLLECTION
SYSTEMS
Plateau's goal is to maintain dust concentrations to lwels that ars Ar-ARA, htr inside the mill where
employees are working and in the mill stacks discharging to the environment. Within the mill, containment
of dusts at their source or origin is an operational objective, as opposed to the unconfined generation of dust
followed by cleanup operations.
All dust collecton are provided with draft gauges to measure the pressure drop betrreen the inside and
outside of the dust enclosures- When the pressure drop falls outside the normal operating range, that portion
of ttre mill generating the dust is shut down. The area is evaluated by the ERHS staff for restricting access.
The employees working in that area may be required to wear respirators. Repair of the dus collection
system and cleanup of the affected area follow such events.
The mill has an ore dust collection system and a ydlowcake dust mllection system, described on Table 3.2-
1. During operation of the yellowcake dust collector system, the efficiencies of the system are as indicaed
on Table 3.2-1. Effiuents from these stacls are monitored as indicated in Table 5.5-7. The operational
efficiency of the ore dust collection system is moniored by mill operations personnel by observing the
pressure drop gauges, the air dust concentrations, and fre buildup of dust around the dust mllector during
mill operatioru. As a backup, the mill ERIIS observes the buildup of dust on his weekly inspections of the
mill. (ntuim Program - no stacks operational. ERHS performs quarte,rly visual inspection.)
5.5.9 MILL SITE DECONTAMINATI-QN J,ND RECLAh{A.TION
5.5.9.I INTRODUCTION
This plan amends the NRC-approved "De@mmissioning and Reclamation Plan", submitted to fte NRC in
1982 and 1988.
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Plateau Resourre.s Limited. Source Material License
No. SUA-1371. NRC Docket No 40-8698. March I, 1996
Plateau\Permits\SUA-3 7I \ t 996\Sec5
Renewal Application 03/01/96
Revision 02102198
sr8
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5.5.9.2 pECOMI,ISSIOMNG
Decommissioning of the processing facility will entail dismantling, deconEminating, and disposing of
buildings, foundations, contaminated equipment, and excavating contaminatod areas as necessary to permit
unrestricted use of the site. The last cells of ttre ailings storage area will be capped and stabilized. The
tailing cells will be progressively covered during the oper*ing life of the processing facility, and an
estimated 6.25 acres will require capping with clay, sand, and gravel at the time of final decommissioning.
When decommissioning is completed, the site will be reclaimed.
prsMANrLrNG. DECONTAMNATION. DISPOSAL
Salvageable equipment and buildings will be dismantled and decontaminated b the maximum allowable
surfuce contamination lwels specified in Table 5.5{ prior to release to unrestided areas. Sandblasing,
scrubbing with detergenre, high-pressure wattr and other mghods of phpical decontamination will be
adopted as prescribed by the ERIIS. Concrete floors, foundations, sump$, subsurPace piping or other
materials with surface contamination levels orceeding the Table 5.5{ values will bo broken up, removed,
and buried in the ailings area. Contaminatd eartlt, such as may be found beneath the foundcions and ore
sockpile pads, where the average F.aA?S conumination in land, ave,raged over areas of 100 m2, which, as a
result of uranium byproduct material, does not er(ceed the background level by more than 5 pCi/g averaged
over the first 15 cm below the surface, and 15 pCi/g, averaged over 15+m thick Iayers more than 15 cm
below the surface, will be excavated and taken to the tailings area for disposal.
Equipmeot and buildings (especially those mnstructed of bolted prefabricated steel construction) that meet
the NRC surface radiation sundards at the time of decommissioning may be sold or reused elsewhene.
The security fence consftucted around the tailings impoundment area will be maintained throughout the life
of the project. This fence may be left in place.
POSTOPERATTONAL MOMTORT-NG..PROGRAM
Monitoring and deconamination during decommissioning will be supendsed by tre ERHS. Supervisory and
industrial sdety requirements will be enforced and the needed prctective equipment provided. The
radiological survey conducted after cessmion of milling will involve making direct and indirect
measuremmts of surface contamination. Surface and sub-surface soil profile sarnpling will be done in
combination with gamma{ose rate measuremenB at the site to demorutrate compliance wittr land cleanup
requiremenB stated above.
5.5.9.3 RECLANIATION
The purpose of this reclamation progr&n is to restore lands dishrbed by project activities (orcept for the
tailings impoundmen$ to a pmductive condition consistent wih past and present uses of the area. This
consists of restoring landscape contours to slopes similar o predisturbance conditions and, in some
instances, replacing a sufficient thickness of topsoil to enable native vegetaion to become reesablished.
Several characteristics of the project area, and souhern Utah in general, are corsidered nonconductive to the
rapid establishment of native plant spocies on disarbed areas. The low average annual precipitation of 6 o
8 inches (15-20 cm); frequent droughts; exteme temperaures; hlgh wind erosion; and a loose,
udifferentiated soil profile with poor moisture-holding capacity and little organic content are a few of those
characteristics.
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Plateau Rcsourucs Limited, Sourre Material Liccnse
No. SUA-I371. NRC Docket No 40-8698, March I, 1996
Platcau\Permits\S UA-37 I \ I 9 9 6 \S ecS
Renewal Application 03/0I/96
Compiled Application OZl0Zl98
lr--'5.29
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Based on the Bpes of disturbances anticipated, the environmental ctraracteristics of the area, the present and
proposed land uses, and the stdsof-he-art knowledge on reclamation in arid environmeils, reclamation of
areas disturbed by the project will include:(a) Covering and stabilizing the tailings impoundment ar€;(b) Removing sfiuchrres and regrading disturbed areas to blend with the sunoundings;(c) Rrylacement of stockpiled topsoil in selected areas amenable to plant growt[; and(d) Revegetating disturbed areas using native and inroduced species.
PRESENT AND PROPOSED USE OF TIIE LAND
Historically, the project area has been used for seasonal livestock grza;@ and as wildlife habial Human
use of the project area for activities, such as camping, hiking, sightseeing, and hunting, has been minimal o
date in part because of the availability of other areas in southeastern Utah for these astivities.
Limited livesbck grazing and wildlife habitat will probably continue to be the principal uses of the affected
area after termination and slosure of the project. Agricultural use of the area, for either crop or hay
production, is not anticipated due to the poor soil stnrchue and scarcity of water. There are presenfly no
urban or industrial developments in the project area other than the facilities related to the project and a boat
repair/storage yard. No other developmenrc are planned for the future.
The purpose of the reclarnation progmm is to resmre those lands disturbed by project activities (excqt the
tailings impoundment area) to an accetable condition for limited livestock grazlrig and as a wildlife habiat.
Since the existing vegetation is generally sparse and is dominated by widely spaced strrubs and by relcively
few grasses that produce usefuI amounE of forage, successful reclamation in ttre project area will result in
ttre establishment of sparse vegehtion with generally low forage production.
LANpS prSrURBEp rpB ORE PROCESSTNG FACrLmy
Approximately 18 aues (7.28 ha) were ler'reled for construction of the plant office, ore stochile pads, plant
buildings, and auxiliary struchres. After topsoil removal and stockpiling, approximately 90% of the area
was graded to develop a smoofr, nearly level surface. Topsoil stockpiling and sabilization have been
acmmplished. The surfuce gradient for runoff is sloped toward the tailings impoundment area. Filling was
required over the balance of the graded area. Typically, cuts rangd ftom zero to about 15 feet (a.57 m) in
depth except in localized areas (such as the ore dump pocke and connecting conveyor tunnel) where
excavation was as d@ as 45 feet. Maximum fill depth was approximmely 40 feet at the souttwest corner of
the ore storage pad.
At project termination all plant structures and facilities will be leveled, and uncontaminatod portions will be
used to fill depressions wihin the plant area, such as the excavation for the ore dump pocket. All
depressions within the plant site will be filled and the general surface gradient of the gaded area will be
maintained so all runoff from the area will continue to flow to the tailings impoundment area. Heavy
equipment will be used to re@ntour the site to blend wifr the natural surrounding topography. Topsoil will
be added where practical to help establish natural veg€{ation. Fertilization, if neoded, and seeding will
follow seed bed preparation to promoe the esablishment of vegetation in accordance with the Utah Mind
Land Reclamation Act. Mulch will be used where necessary. Existing fences will remain standing during
re\regetation. Plant species to be seeded are likely to include: sagebnrsh (ArtemiSi.a spp.), Indian ricegrass
(Oryzopsis hymenoides), Mormon tea @@L1g_Spg.), galleta fiilaria jamesii), Siberian or crested
wheatgrass (Agnop),ron sibiricum or A. desertonrm), Salina wildrye (E[tgBUS-SA[bd, saltbushes (Atiplex
spp.), blackbrush @, Apacheplume (Edlgglg paradox4), and/or desert bitterbrustr
(Rushia glandulosa), and rabbitbnrsh (Chrysothamnus spp.).
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Plateau Resources Limited, Soutre Material Liccnse
I
No. SUA-1371, I.IRC Dockct No 40-8698. March I, 1996
Plateau\Permits\SuA-37 I \ I 996\Sec5
Renewal Application 03/01/96
Compiled Application OZl02l98
5-30
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An area adjacent to the plant site was cleared and graded for use as a construction equipment and materials
storage yard. At closure, the constnrction yard will be closed, all equipment will be removed, the area will
be regraded to conform wifr the general topography of its surroundings, and distnrbed areas will be seedod.
TAILINGS II\,POUNDME}TT AREA
A staged covering and reclamation of the ailing impoundment area will be used to minimize radon and
tailings dust emissions during operation. This tailings management technique consists of dividing the whole
impoundment area into three sections. EacI section represents a storage area for ailing during select time
periods when the mill is operational.
Section I involves a tohl storage area of approximately 25 acres (10.16 ha) and will last for about four years
of operation. This area of the impoundment will conain five tailings collection cells, each having an
underdrainage system of perforated pipes. Opuational procedure will dictate the number of the cells used at
any one time. After the tailings in any cell have reached a predetermine( elevdion, the cell will be
deactivated. The ailings will be allowed to dry sufficienfly to allow the movement of equipment ou the
tailinS. Then the cell will be stabilized.
Constmction of uilings impoundment cells in Section tr of the impoundment area (south of the present crcss-
valley berm) will begin before all cells in Section I are filled. Thus, when all cells in Section I are filled, the
tailings will be placed into the Section tr cell(s) without any intemrption of plant operations. There ue25
acres in the Section I impoundment, and the berm face would cover approximately four acres after regrading
it to a 3H:1V slope. By the ,iros lailings begin to be dischuged ino Section II cells, one or more of the
Section I cells would have been stabilized so the surface area of exposed uilings will not exceed the area
covered by surety. At any time during fte lifu of the project, eactr individual impoundment (Section) will
not orceed 40 acres in size and no more than two impoundments will be in operation at any one time.
When the last of the Section tr cells are being filled with ttre tailings after approximately four to five
additional years of operations, the dam will be raisd to Stage II height (approximately 120 feet (36.58 m)
high), and cells will be comtrusted for Section III. Tailings will then be dis&arged ino the Section Itr cells
while the most recently used cell or cells in Section tr are drying and being stabilized. The surface area of
uncapped tailings will not exceed the area covered by surety. 40 CFR 6l.252limits the numbu and size of
tailings impoundments to no more than two lined impoundments eactr with no more than ,l() acres in
operation at any one time. The size of Pldeau's impoundment are much smaller than the size limis from the
EPA.
I This operational philosophy would leave a very small area to be reclaimed the fuial clostue of
processing facility. After the final stage of the operation, the maximum area left for reclamaion will
f about 25 percent of the 25-ase (10.16 ha) area of the six cells. Operational erperience obained in
I design and construction of Secfion I will be used in the design urd consuuction of subsequent sections.
At project termination, the tailings dam will be approximately 120 feet (36.58 m) high, and will have a
maximum base width of about 500 feet. The crest of the dam will extend about 13 feet (3.96 m) above tho
level of the tailinS against the dam face. Reclamation of the ailings impoundment will be accomplished by
capping the remaining open cells, namely those not cappd during plant operation. Each cell will be covered
with sufficient clay to reduce radon emissions to less than 20 pCi/lrf-sec to the atmosphere, 2 feet (0.6 m) of
locally available sandy soils and I foot (0.3 m) of gravel and cobbles to protect the cover from erosion.
After reclamatiotr, two spillwap will be constructed to protect ttre dam and tailings cap agairut erosion and
flood flows. To provide for the long term stability of the tailings mntainment system, wrer flowing across
the face of the dam will be minimized. One spillway will be er(cavated in the sandstone of the Ieft (eas$
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Plateau Resources Limited, Source Material License
I
. SUA-I37L,I{RC Docket No 40-8698, March l. 1996
Plateau\Permits\SuA-3 7 I \ I 996\Sec5
Renewal Application 03/01/96
Compiled Application 0U0E,DB
s-31
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abutment of the dam to direct drainage to the downsteam portion of the impoundment basin. The other
spillway will be excavated in the sandstone formation along the norttrwest corner of the impoundment. This
spillway would divert drainage to Lost Springs Wash. Both spillways will have crest elevations lhree feet
(0.9 m) above the level of the cap and will be sized to pass the maximum probable flood. Howwer, until
sediment deposition fills in the impoundment to the level of the spillway crests, spillway flows will be rare
even$.
Continuous accrsion of the cap is anticipated due to retention of sediments carrid onb the cap by runoff
from the small tributary waterhsed of tre basin until a dynamic equilibrium betrveen erosion and
sedimenttion ocours. Water flowing onto the cap will seep down through ie upper layers onto the clay
Iayer. This will tend to mainAin the clay's moisture content at near saturation, and enhance the cap's
effectiveness as a barrier to the movement of radon gas emanating from the ailings. The massive bluffwest
of the impoundment provides a windbreak trat is expected to cause a net deposition of wind-borne soil onto
the cap, adding o its thickness.
Should reclamation be required due to unforeseen circumstances prior to the end of the usefirl life of the
procassing facility, any ailings impoundment area not reclaimed during operations will be covered with the
clay, sand, and gravel cap as described above. The cap will extend beyond the outer limis of the tailings m
ensure complete coverage of the tailings to minimize radon emanation. The downstream face of flre cross-
valley bemr will be sloped to a stable configurdion (3H:1V slope) and the cap will be extended to cover dre
face to protect it from erosion.
Given the scenario of the processing facility's shutdown after only one or two cells are partially or
cornpletely filled, reclanration would proceed in much the same manner as dissussed previously, but
additional earthwork will be required. The exposed sides of the dikes benrreerr tre used and unused cells
will be reshaped to lessen their slope, and then they would be reclaimed by continuing dre cap over them.
There are two basic configurations that the covered tailings impoundment could have if this scenario should
happen. If cells 1, 2, and 3 were used, the cap will be extended (at an approximately level grade) to the
north to disallow impoundment of runoff hehind the cells. The extension of the cap that would be
cons0ucted with the pulpose of bringing the low areas up to grade will not necessarily be corutnrcted in the
same manner as the portions of fre cap that covers tailings. The cap exteruiion will be corutructed of locally
available fill materials and will be mvered witr mbble or gravel to prevent erosion.
The second basic configuration would occur if a combination of cells L,2, and 5; or l, 3, and 4 were used.
Either of these combinations could also lead to a sihration in whictr runoff water would be impounded. To
prevent impounding watetr, the berms will be shaped and capped as described previously. The cross-valley
berm will be breached (where it was not conaining the tailings), and a riprapped diversion channel will be
built outside of the tailings cap perimeter. Construction of the channel will prevent nrnoff from eroding the
cap and will divert water trrough fre breached part of the cros-valley berm.
The above nro configurations will mst significantly less than the surety posted for he impoundment area.
Both will entail relatively small expenditures for engineering, fill materials, and haul4ge. Cost of
constructing a riprapped diversion channel and breaching the cross-valley berm will be siguificantly less tran
constructing a level cap to preclude qTxlel impoundmenB.
As stated in Section 3.3.2.1of NTJREG-0583 (FES for the Shootaring Canyon Uranium Project; July, 1979)
and Section 9.4 of the Environmental Report, Shootaring Canyon Uranium Project, Garfield County, Utah,
locally available materials will be used o construct the impoundment cap, Benmnitic clay from the Brushy
Basin Member of the Morison Formation will be compacted to form the clay layer in the tailings cover.
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Plateau Resources Limited. Source Material License
No. SUA-1371, IVRC Docket No 40-8698, March l. 1996
Plareau\Permits\suA37 I \t 996\Sec5
Rcnewal Applicrtion OSlOl 196
Conrpilcd Application 02102198
s-32
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This clay can be obtained from the same borrow area ("Ga") as the clay used for the impoundment liner.
Borrow Area "Ga" is located on Bureau of Land Management (BLM) conEolled land.
The 2-foot (0.6 m) layer of sandy material will be obtained from Borrow Area E. This material is a red,
fine sand, wittr silt varying from a trace to a significant percentage. Borrow Area E is located west of the
processing facility. Material will be removed from this borrow area in a sequential sripping operation so
very litle, ff *y, recontouring will be required. Muctr of ttre area will be snippsp to bedrock and the
remaining parts of it will be reseeded.
Borrow fueas A, A', or C will be the source of the gravel, cobble, sand layer that will protoct the cap from
erosion. Test pit logs for these areas describe the mduials as hard, sub-rounded to sub-angulu cobbles and
gravel, and sand with calcareous cement. Material from these areas was used during constuctioD of the
processing fucility under material sales coffiact U4547 with the BLM.
5.5.9.4 LONG-TERMSURVETLLANCE, MAINTENANCE. ANpCp.NIROL
The design, construction, operation, and closure of the tailings disposal system have been plannod with the
objective of creating a facility that, after closure, will endure for many years without requiring either
monitoring or maintenance while continuing to provide an environmentally safe and satisfrcory
performance. As a minimum, annual site inspections shall be conductod by the government agency rctaining
ultimate arstody of the site where tailings or wastes are stored o confirm &e integrity of the stabilized
tailings or waste systems and o determine the area, if any, fur maintenance and/or monitoring. ResulE of
the inspection shall be reported to ttre Nuclear Regulatory Commission within sixty dap following eactt
inspection. The Commission may require more frequent site inspections if, on the basis of a sitespecific
evaluation, such a need appears necessary due to the feanres of a particular ailings or waste disposal
system.
Factors of long-terrn conc€m with respect to uranium tailings are the dispersal of ailings by erosion, the
contamination of groundwater, and the release of radon to the atnosphere.
TAILINGS DISPERSAL BY EROSION
To control water ero\sion, the final stage of ttre processing facility's tailings impoundment dam has been
designed and constructed with a crest extending above the maximum water level trat would be reached in the
impoundment area under the mnditioru of the maximnm probable precipiation likely to occur at fte site.
Spillways will divert nrnoff orceeding the retention capacfty of the irrpoundment. Because the spillway crest
will be about three feet (0.9 m) higher in elerration than the top of the cap to be placed over the ailings, the
dead sorage volume provided over the cap and below the spillway crest must be filled before any nrnoff is
passed dowrutream from the dam. This storage is provided to ma:rimizb the capture of available moishrre
and thereby keep the cap peryetually moist or wet for purposes of reducing radon emisions without
reducing the safety of the $rucnre. Overtopping of the dam crest, with consequent possible erosion, will
be prevented by the spillway. The toe of tre dam will be protected from erosion during periods of spillway
discharge. The downstream face of the dam is protected from rainfull induced erosion by riprap.
Surveillance to establish that fre dam will continue to perform as designed (no ovetopping) will consist of
visual check of the spillway channels o see that ttrey are unobstructed. Winddepositod sand, rock falls or
slides from fte walls of the channels, and heavy vegetative incrrsions into the channels are conceivable types
of obstructiors. Channel maintenance would involve removal of such obstructions in the unlikely event that
it becomes necessary.
The dam was coruitructed on a sandstone foundation. The techniques employed in corutuction of the dam
yield a stable and dense structrrre. Some deflection in both the vertical and downstream directioru rnrst be
Plateau Resources Limited, Source Material License
No. SUA-1371. hlRC Docket No 40-8598. March l. 1996I
Platcau\Permits\S U A-37 l\ I 99 6\5 ec5
Renewal Application 03/01/96
Compiled Application 02/02/98
s-33
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e)eected. Although not expected b be significant, normal seffleme,nt under and within the darn will cause
the crest of the dam to deflect with respect to the level of the spillway crest. If any settlement is noted by the
annual inspections, instnrment measurements may be necessary to determine the amount of settlement and
the corsequent risk of dam overtopping. Settlement on the order of one foot (0.3 m) or more would reErire
a gootechnical investigation to determine the causes of tre settlement. Nominal sefflement due merely o
internal consolidation of the dam after project closure could be remedied by adding materials to tlte crest, tro
prevent posible overtopping during heavy precipitation. Major settlement due m any cause would probably
require an engineered remedy after the causes of the settlement were established. To prevent dispersal of
project tailings by water erosion, the dam must not be subjected to subsuntial and prolonged overtoppiDg.
The rock and gravel zones on the downstream slope and crest of the dam, and the rock and gravel layer to
be placed at the top at the tailings cap, will prevent wind erosion of those exposed surhces. Also, because
the tailings disposal basin is effectively surrounded by natural clift and hills, net deposition of windbome
soils is expec&d to occur over the impoundment area, rather than loss of covering over the tailings due to
wind erosion. Acmrdingly, nahrral deposition will be exploited to enhance the security of the projected
tailings impoundment.
Surveillance or monitoring to determine the effecB of wind on tre tailings impoundmurt will be by visual
inspection of ttre dam and tre tailings disposal area. If there are any sigus of local erosion, rather than
deposition, measures will be taken in the eroding areas to improve the erosion resistance of the surface.
GROUNDWAT.ER CONTAMNATION
The tailings Eumagement plan for ttre Shooaring Canyon uranium project has been developed to prevent
contamination of groundwater underlying the tailings disposal uea. A clay blanket has been placed over the
natual sandstone of the impoundment area to limit 6e rate of seepage from the tailinp into the foundation
rock. To reduce the amount of tailings Iiquids available for seepage ftom the impoundment, tailings will be
distributed around the basin, in such a manner as to continuously provide a large wetred area exposed for
evaporation. AIso, if excess ailings liErids collect in the drainage system of the impoundment, the tailings
liquids will be recycled to the process circuit. By keeping the tailings wet during and after placement wind
erosion and dispersion of the tailings can be minimized.
At the project sitg net evaporation from exposed water surfaces will average approximately 70 infies (177,8
cm) per year, which is equivalent to approximately 3.6 gallons (13.63 t) per minute per acre of exposed
surface. At an ore processing rate of 1,000 tons (907 m) per day, and assuming a tailings slurry containing
49 percent solids by weight, approximately 175 galloru (662.4 1) per minute of tailings liquids will be
delivered to dre impoundmerrt. Saturated, dense, serled tailings would be expected to have a moisture -
content of approximately 35 percent. Based on this assumption, approximately 90 gallons PZl.l 1) per
minute of ttre uilings liquids will be retained in ttre seuled uilings, leaving approximately 85 gallors PZl.1
1) per minute of liguid available for evaporation and/or collection in the drainage system.
Since the tailings menagement plan provides a meaDs for disposing of all excess tailings liErids during the
project operation, no significant amount of free uilings liquid will remain in the impoundment at project
termination to se€p into the groundwater. Also, after the project is terminated, normal evapordion from the
uilings cap will dispose of much of tle incident precipitation, including runoff from the basin waterhsed, on
the impoundme,nt ba.sin. A limitd potential there,fore exists for groundwater contaminatios ft96 this
project, and the requirements for surveillance of the groundwaters of thd area will be minimal. The
monitoring wells located near the impoundment perimUer for monitoring seepage from the basin during
project operation will be mainained and be available for subsequent groundwater monitoring.
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Plateau Resourses Limited, Source Material Lisense
No. SUA-1371, tlRe Docket No 40-8698, Mareh l, 1996
Plateau\Permits\SuA-37 I \l 996\Sec5
Renewal Application 03/01/96
Cornpiled Application OZl02l98I
s-34
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RApTATTON EMrSS-LQN,S
The cap to be placed over the tailings impoundment area for final reclamation was designed and will be
consbrcted widr the goal of limiting radon gas and gamma radiation emissions from tho tailings. The waste
disposal uea shall be closed in accordance wifr a desigut which shall provide reasonable assurance of
mntrol of radiological hazards to (i) be effectivefor 1,000 years, to the extent reasonably achievablg and, in
any case, for at least 2fi) years, and (ii) limit releases of rudon-?22 ftom uranium blproduct materials to the
afinosphere so as not to orceed an averagee release rate of 20 pCi/Af Sec-t. Direct gamma exposure from
the tailings or wastes should be roduced to background levels.
The design requirements in this criterion for Iongevity and control of radon releases shall apply to any
portion of a licensed and/or disposal site unless such portion contains a concentration of radium in land
averaged over areas of 100 square meters, which, as a result of b5product materid does not exceed the
background lwel by moretran: (i) 5 pCilm of radium-226 averaged over the first 15 cm below the surface,
and (ii) 15 pCilg of radium-226 averaged over l5-cm-thick layers more than 15 cm below the surfrce.
5.5.10 APPENpIT,A SPECIFTCATTONS
The following subsections present the tailings reclamation performance objectives as a part of &e discussion
of compliance with 10 CFR Part 40, Appendix A criteria. Eactr of those criteria is addressed below.
5.5.10.1 TAILINGSRECLAMATIONPEMORMANCEOBIECTNTES
The Plateau mill and tailings area are bottr within 0re restricted area b which access is controlled by a
multi-sfrand barbed wire fence or topographic featrres that fonn natural boundaries. The restieted area is
postd with signs sating, "Any Area Within This Mill May Contain Radioactive Material," along with the
radiation symbol. The site is remote. The nearest residence is in Ticaboo, Utah, approximately 2.5 miles
south of the processing facility. The nearest recreational area , Bullfrog, is 14 miles south and the trearest
town, Hankville, is 56 miles north. The site is gmgraphically isolated as shown in Figure 2.2-1 ta
Appendix J which is a topographic map of the area around the processing facilrty. The site is in a natural
depression in the landscape. The uilings are isolated from groundwater by a}-fwt thick clay liner under
the tailings and then 150 feet of sandstone between the liner and groundwater.
Erosion, disturbancg and dispersion of tailings by natural forces over the long term will be minimized or
prevented by *re actions presented in tre decommissioning and reclamation plan presented in Section 5.5.9.
5.5.10.2 NOMBOLIFEMTION OF SMALL WASTE DISPOSAL.STTES
To avoid prolifermion of small waste disposal sites and ther$y reduce perpetual surveillance obligations,
radioactive materials, contaminated equipment, and mntaminated scrap from milling operatiolls will be
placed, with NRC approval, in ttre tailings impoundment for disposal. Precautions will be uken to place the
materials in the tailings in such a way as to minimize any futrrre subsidence of the area.
5.5.10.3 BE.,LOU/-GRADEDISP.QSAL
Plateau's uilings impoundment is in a natural dryression enclosed on the downsfream end by an engineered,
NRC approved dam. Suctr a tailings area minimizes thedispersion of tailings by wind and water erosion.
hhe staadard amlies to the desig!. Monitoring for radon after insall*ion of an 4propriately desiped cover is not
required.
The standard, howevor, applies only to emissions to the atmospherc from uranium bypro<luct materials in fte tailings as
opposed to the cover. 5-35
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Plateau Resources Lirnited, Source Material License
No. SUA-L3'IL, I{RC Docket No 40-8698, March l. 1996
Plateau\Pcrmits\SuA-37 I \l 996\Scc5
Renewal Application 03/01/96
Compiled Application 02lOZl98I
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5.5.10.4 SrTE ANp DESIGN CRIIERTA
The Plateau tailings disposal facility was designed to minimize the dispersal of ailings by wind and water, to
minimize the upstream rainfall catchment area, to minimize the ernbanlonent and cover slopes, to minimize
erosion of the cover, to locate the imFoundment away from capable faults, and to promote deposition on top
of the cover. Specific design criteria for the ailings impoundment and the final reclamation cover are
provided in Woodwud-Clyde (April 1978); Woodward{lyde (May 1978); and Woodward€lyde Qune
1978). Those documens indicate that an engineered @ver, combined with the desrgn femres of the
impoundment, will provide reasonable assuratr@ of longevity of the ailings disposal facility.
5.5.10.5 SEEPAGE
Cells 1, 3, 4 and 5 of Seaion I of ttre mill tailings disposal area have been lined with a clay blanket of not
less than two feet in thickness. The clay blanket has been overlain with sandy material covered widr gravel,
which is designed to collect slimes. Within the sand layer and adjacent to the clay liner ue drainage pipes
which drain to a collection sump. The collection sump, Iocated downstream of the cross-valley benn, is
equrpped with a pump. The Iiquid that filters through the sand-gravel layers is pumped to surface
evaporation ponds or recycled back to the mill. The mill circuits have been designed to maximize ttre ue of
retum liquid, to reduce the mill water through-put requirements, and to dewater ttre taili"gs slurry as
discharged into the tailings impoundment.
Woodward-Clyde Consultarrts calcrrlated that over the predicred ZC.yw life-qpan of the ailings disposal
system, approxim*ely 413 acre feet of seepage would seep frough the clay liner. Assuming a water table
150 feet below the clay liner, an average porosity ofthe underlying sandstone of25 percent the calculated
voids would be 2600 acre feet. Therefore, the toUI seryage may not be sufficient to saturate the underlying
rock. The Entrada sandstone underlying the disposal system has a high calcite (calcium carbonate) content
and a permeability of 5 x 10{ cm/sec, as computed from field test data.
This high calcite @ntent will effectively nartalize any acid (pH l-2) tailings solution that may contact the
calcite. The acidic uilings are not anticipated to pmetrate more than 10 feet of the underlying sandsone.
Neutalization raises the pH, which in turn precipitates the radionuclides and heavy metal present in fte
tailings liquids.
For a more detailed discussion of fte geology of the underlying material, rder to Section 2,4.
The NRC has selected the following ttuestrold values: Arsenic = 0.AZ mBL, Chloride = 44 mElL,
Selenirrm = O.AZwE|L, and pH = 6.8 standard unis. Uranium is compared o the 10 CFR 20, Appendix
B effluent @ncentf,ation of 3E-7 mCi/nrl-. The up-gradient well RM-l is located immediately north of the
tailings impoundment. The compliance wells are R4, R5, and R6 shown on Figure 5.5-1 in Appendix J.
l0 CFR ,10 Appendix A requires the use of a liner under the ailinS that "is designed, constructed, and
installed to prevent any migration of wastes out of the impoundment to tre adjacent subsurface soil, ground
water, or surface water at any time dtrring the active life (including the closure period) of the imlnundment."
The use of such a liner for new portions of theailings impoundment would preclude any seepage from those
areas. Water used in &e process comes from the Navajo Formation which lies at a dryth of 600 feet below
the surface in the ailings disposal area. The Carmel Formtion separates the Entrada and Narrajo
Formations, providing a barrier to mixing.
Seepage from the ore storage pad will be minimal. The limited rain water runofffiom the ore stoclrpiles and
ore $toragepad is diverted to tre drainage for the tailings area.
)
Plateau Resourses Limited, Source Matcrial Liccnse
No. SUA-I37t, NRC Docket No 40-8698, March I, 1996I
Plateau\Pe rmits\S U A-3 7 I \ I 996\Sec5
Renewal Application 03/01/96
Cornpiled Applicstion OZIUZ|9S
5-36
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5.5.10.6 CONTROL OF RApON RELEASE ANp GAMMA H(POSURE RATES
Woodward4lyde (June 1978), provides a cover design for the ailings impoundrnent consisting of
compacted clay covered by two feet of sandy matuial covered by one foot of cobbles, gravel and sand. That
cover was designed to yield a radon emanation rate of 20 pCi/m%ec or less and gamma exposure levels that
are equivalent to background ganma levels.
5.5.10.7 PRE.OPERATIONAL AND OPERATTONAL EIWIRONMENTAL MOMTORING
PROGRAM
I The pre.operational environmental monitoring program and the data mllected are presentod in the
I Environmental Report, and in the Final Environmental Satement (NRC, 19790)). The operational and
interim environmental monitoring programs are described in Section 5.5.6.
5.5.10.8 CONTROL OF AIRBORNE EFFLUENTS
All airborne effiuents from milling operations will be reduced to levels that are ALARA, which in nrn
controls exposures to populations around the site and site mntamination to the maximum extent reasonably
achievable.
Airborne effluent conEols include:1. Sprinkling the potentidly dry tailings beachx with ailings solutions and the contolled deposition of
ailing slurry as described in Section 5.5.7.
Crust formation, sprinkling with water, and/or the application of chemical dust sabilizers in the ore
pad areas as described in Section 5.5.7.
The use of the dust collection systems in the mill as described in Section 5.5.8. The operational
ctraracteristics of these s]rstems are presented in Table 3.2-1, and the instrumenution and inspection in
Section 3.2.2.lo 4. The use of the yellowcake dust conuol systems in the mill as described in Section 5.5.8. The
operational characteristics of these systems are presented in Table 3.2-1, otfr the instnrmentation and
inspection in Section 3.2.2.
Daily inspections of the ailings retention system will be mnducted and doqmented as specified in Table
5.5-7 (interim program - Table 5.5-8, monthly inspections). The NRC regional office will be notified
immediately of any failure of the tailings retention system which results in a release of tailings or waste inb
unrestricted areas and/or any unusual conditions, not contemplated in fte design of the retention system,
which if not corected could indicate the potential for release of tailings to unrestricted areas.
5.5.10.9 FINANCIAL SURETY
Financial surety affangemens have been established at the First Interstate Bank of GiUettg Wyoming with
an account in the name of: Plateau NRC Surety which names the U.S. Nuclear Regulatory Commision as
thebeneficiary. Thesurety arnountas of April 5, 1995 was $2,648,851.16. Thesefunds aresufrcientto
carry out he decontamination and decommisioning of the facility and site and for the reclamation of the
tailings disposal area. The amout of funds e,rsured by the surety arrangement is based on cost estimates
and the decommissioning plan approved by the Commission in November 1983 and 1988 which provide for
(1) decontamination and decommissioning of mill buildings and the facility site to levels which would allow
unrestricted use of these areas upon decommissioning, and (2) the reclamation of the tailings disposal area in
acmrdance with the approved tedlnical criteria. Plateau has committed to phued reclanration of the tailings
accumulated throughout the operational life of the facility. The surety will provide funds ttrat are sufficient
to @ver the costs of decommissioning and reclamation of the areas that are presently used for the mill and
tailings disposal area.
2-
3.
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Plateau Rcsourccs Limited, Sourcc Material License
No. SUA-137I, NRC Docket No 40-8698. March l, 1996
Plateau\Pcrmits\SuA-37 I \ I 996\Scc5
Renewal Application 03/0I/96
Revision OZ|OZ|9S
s-37
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The surety arrangements are reviewed annually by the licensee and adjusted with the approval of the
Commission, when needed, to account for any increases or decreases resulting from inflmion, changes in
engineering plans, activities performed, and any other conditions affecting costs.
5.5.10-10 LONG-TERMI{AINTENANCE
Prior to the termination of the souroe material license, Plateau will pay to the general treasury of the United
States, or to an appropriate state agency, $250,000 (1978 dollars) to cover he cosb of long-terrr
surveillance.
5.5.10,11 LAND O}VNER.IISE
The processing facility and its ailings disposal area are located on land puchased by Plateau from tre State
of UtahonNovember20, 1981. ThepatentforthispropertywasobtainedonMarctr l, 1982, fromthe
State of Utah, which obtained the land from the U.S. Bureau of I^and Managomurt.
The United Sates reserrred a rightrf-way for ditches and canals constucted by authority of &e United
Sates in the purchased lands and also reserved oil and gas. The grant from tre United States was made
subject to then existing rights+f-way for ttre haulage road and telephone and seryer lines serving the facility.
The State of Utatr reserved coal and other mineral righs. Plateau holG a lease frorn the State of Utah
covering metalliferous minerals. A Garfield Courty road, @nsructed and maintaind by Plateau through an
agreement with the county, provid* access to the processing facility ftom State Highway 776, as shown on
Figure 2.1-2. Beetrive Telephone Company (an indryendenfly owned telecommunications company) that
serves the processing facility, Tony M mine and Ticaboo, Utah, was granted a rightof-way for a buried
telephone cable &at nrns, in part, in a generally norttr to south direction through the eastern portion of the
site.
Prior to termination of the source material license, Plateau will comply with the ownerhsip requiremene of
Criterion 11 of Appendix A to 10 CFR Part 40 for sites used for tailings disposal. Title and custody of the
blproduct material (tailinS), and the ailings disposal uea, including any interest therein, will be
transferred to the Uoited States or the State of Uatr, at the option of the state. As noted abovg mineral
rights are already owned by the Unitd States (as to oil and gas) and the Sate of Utah (as to all other
minerals). Plateau resen es the right of first refusal provided in Section D of Criterion 11. Plateau reserves
the right to mainmin, tansfer, sell or othenvise dispose of its property adjacent to fie tailings disposal area.
5.5.10.12 INSPECTIONS
As described in Section 5.5.9, the design of the reclaimed uilings dispoul area should result in a stable
configuration ttrat will not require ongoing maintenance to preserve isolation after decommissioning.
However, to ensure the continued isolation of the tailings, annual site inspections, unless rnore ftequent
inspectioru are deemed necessary by the Commission, shall be conducted by ttre govenunent agency
retaining ultimate custody of the tailings disposal area to confirm the integrity of the stabilized fiflings and m
determine the need, ff*y, for maintenance and/or monitoring.
5.5.10.13 HAZARDOUSCONSTITUENTS
Plateau does not reasonably oeect any compound on the list of specific constitrents presented in l0 CFR
4O, Appendix A, Criterion 13 to be prCIent in the groundwater under tre Plateau mill or ailings area as a
result of site operations.
5,5.I 1 MDIOLOGICAL DOSE CALCULATTONS _U, SING MILDpS
The computer program MILDOS (NRC, 1981) is used o predict the radiological doses from the opertion
of the Plateau uranium mill and tailings facility. Parameters b be entered into MILDOS ue in part derived
from Table5.5-10.
)
Plateuu Resourres Limited, Source Material License
No. SUA-137I, NRC Docket No 40-8698, March l. 1996I
Plateau\Permits\S U A-3 ? I U 996\Sec5
Renewal Application 03/01/96
Compiled Application OZIOZI9E
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Table 5.5-10
PRINCIPAL Pffi FOR RADIOIOGICAL A,SSESSMEI.IT
Paliulp.[gr
Ore quallty, UrO*
ore activity, u a38, u-234, ua38
Th-23 0, Ra-226, and Pb-z 10,
Operating days per year (plant factor)
Ore process rate
Mill water throughput
fuinual average morning mixing height
Annual average afternoon rnixing height
Ore Handlinrcld-.$torage
Estimated capacity of ore per for delivery
Nurnber of deliveries
Ore dust released in delivery
Average grade of ore range
Capacfy of ore pad:
fuial yeff of operation
average during operation
Murimum area of ore pad
height of ore storage pile
Approximate amount of ore handled
per duy, i.e., unloaded, loaded bulldozd, etc.
Operation time of front-end loaders; hoppers
feeders, ffid other ore pad equipment
Estirnated arnount of fugitive ore dust emission
dust ernission from handling of ore on ore pad
s-39
Plateau Resourres Limited, Source Material Liccnse
No. SUA-1371, NRC Docket No 40-8698, Marsh l, 1996
Value
0.1570
437.9L
365. (340)
3.31E5 ton/yr
1,79 E5 m3/yr
Not available
Not available
35.83 MT
25.32 per d.y,
177 .2 per week
0. kgthr
0.I5To
0.07%4.24%
81967. Mr
87967. h/tl
14800. rl'
3-8. III
907.18 hflTldty
16. hr/day
Not available
Plateau\Permits\S UA-37 I \ 1 996\3 ec5
R.enewal Application 03/01/96
Compiled Application OXl02l98
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Crushers. Grinders, Rod Mills.Fine Ore Blending. Solveut Extr?ction.
Countercurrent Decantdion, Ion ExcLange and Leachins
For each piece of potentid radioactive emission soluce equipment, report the following:
SAG SX CCD LEACH
Operation time 24 24 ?4tulday
0 0 0 MT/yrEstimated dust lost to atnosphere 0
Estimated radon released to atrnosphere - -all sources
Efficiency of emission contol devices (efifective and design)
Estirnated dust Iost to aEnosphere through internal ore
tansportation devices (e.g., conveyor belts)
Efficiency emission controls of internal ore
transportation devices (effective and desigu)
Average daily capacity of temporary bin storage
(fme ore bins)
Efficiency of controls for temporary bin storage
Yellowcake Dryir,rg and Packaging
Processing rates
Dust emission confrol reduction factor by wetting
chemical, or ottrer conEols
Ore storage time
Operation time
Efficiency of control of U3OB dust released
to aunosphere (desrgn & effective)
Estimated U3O8 dust released to atrnosphere
Stack diameter
stack flow rato
Plateau R.csourues Limited, Source Material License
No. SUA-1371, NRC Docket No 40-8698, March I, 1996
9'l .To
I20. days
15.I CI/YR.
99.9%
0.768 MT/yr
99.9%
N/A
N/A
As production requires
N/A Packaging
same Drying
same Packaging
99.l%Drying
N/A Packaging
0.53 MT/yr
0.46 m ID
1.42 rn3/sec
Platc a u \Permits\S UA€ 7 I \ I 996 \Sec5
Rcnewal Application 03/01/96
Compilcd Application OZIOZI9S
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Stack height
Recovery rato of U3O8
Yellowcake yield
Yellowcake quality, U3OB
Hqap_-I-each Pile.$ fif appJlgable)
Dimensions (height, widtlr, Iength)
Volume N/A
Capacity
Pile acrivity for UiZgg ,Th-230,
Ra-226, and Pb-210
Fugitive dust emissions
Control efficiencies for dusting
Solid and Liquid Disposal Impoundments
Sand tailings area
Sand volume
Sand capacity
Slime ffea
SIim volume
Slirn capacrty
Operating tirne for impoundment
Tailings density
Drying time prior to reclamation
Efficiency of controls for fugitive dusting
dusting (wetting, chemicd, etc.)
Activiry, U, Ra-226,Tt1-230, and Pb-210 in slimes
Plateau Resourres Limited, Sourcc Material Liccnse
No. SUA-1371, I{RC Docket No 40-8698, March l, 1996
27.43 ru,
94.%
453.65 tonnes/yr
89.82 X 1.477o
N/A
N/A
N/A
N/A
N/A
0.22 km2
2.5686 m 3
3.98E6 hIT
0.055 km2
6.4tr6 m3
9.95E5 MT
20. yrs
1.55 g/cm3 dry
1.95 glcm3 wet
21 yrs
N/A
Not available
Plateau\Perrnits\SuA-37 I \l 996\Sec5
Renewal Application 03101196
Compilcd Application 02102198
t13
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ro Activiry, U, Ra-226,T1r-230, and Pb-210 in sand
Activity: U-nat, Ra-226, Th-230,
Activity - Total tailings
Total tailings area - Iast year of operations
Tailings pond (solution) area
Tailings solids area
Land Use ani_G..fqzing of CaSI.g
Fraction of year spent grazing locally - near mill
Fraction of feed that is pasture grilze whil e gtming
Fraction of stored feed ttrat is grown locally
Acreage reguired to graze one animal unit (a50kg)
for one month (AUM)
Length of growing season
Fraction of local consumption of locally produced:
LgQadgrU of Sources and Receptors
AII locations should be given in terms of:x kilorneters east of the yellowcake dryer sacky kilometers north of ttre yellowcake dryer stackz, meters elevation from the base of the yellowcake dryer sack
(Denote locations to the south and/or west by a negative value.)
Not available
Not available
Not available
19147. m'
11403. m 2
7743, rt 2
33.%
l00.Vo
(l,To
93An7 ha
7 .5 months/yr
Vegetables ( l.Vo
Meat
Milk
0.To
0.Vo
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Source
Yellowcake dryer
SAG mill
Ore pad 0.04
Tailings pond I (midpoin$
Ottrer sources: d+mister
durnp pocket
Plateau Resourpcs Limited, Source Material License
No. SUA-1371, NRC Docket No 40-8698, March 1, 1996
East
0sn)
0.0
{.03
0. 18
{.55
-0.04
0.03
Norttr
Gm)
0.0
4.005
-3.68
0.09
{.04
0.06
Elevation
@)
27.5
4.23
42.92
14.25
22.21I
l'-J
PlatcaulPermits\suA€ 7 I \ I 996\5 e c5
Rerrewal Application 03/01/96
Compilod Applicttion OAADTI
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Extra_Receptors
Nearest resident - Ticaboo
Nearest resident in prevailing
wind direction-Greenriver, UT
Ranch -Trachyte- Catt
Farm - Fairyiew Ranch
Orchud - Notorn, UT
Grazing - Upper Little Rockies
Grazing - Lower Little Rockies
Garden - Bullfrog
Ranger bunk house - Natural Bridges
Town 1-Boulder, tlT
Town2-Hanlsville,UT
Other nearby residents - recreational
Plateau Resources Limited, Source Materiat License
No, SUA-137I, NRC Docket No 40-8698, March I, 1996
East
(krn)
-1.0
46.0
6.7
4.5
+?,5
0.26
0.0
-2,2
64.0
{5.0
-2,0
-1.0
North
flsn)
4.0
142.0
28.6
56.0
58.0
0,0
-1.0
-20.'l
-15.0
22,0
74,0
74.5
Elevation
tu)
-95.10
-140.82
r77.39
193.55
213.36
4.27
39.62
-238.35
432.21
584.61
:70.7L
2M.45
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Plateau\Pcrrnits\SuA-3 7 I \ I 9 96\SecS
Renewal Application 03/01/96
Compiled Applieation 0ZlOZl98
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Environmental Procedure: AP-3Revision: I
Issue Date: 06-30-97Page I of3
PLATEAU RESOIIRCES LITIITEI)
SATETY AND ENVIRONMENTAL REVIEW PAI{EL
1.0 REGI]I"ATORY BASIS
Materials license SUful37l Condition 9.6 states:
Standord operating procedures shall be established and followed for all operational
process activities inwlving radioactive materials that are hmdled, processed or storcd
SOPsfor operational activities shall enumerate pertinent radiation sSety practices to be
followed. Additionally, written procedures shall be established for non-operafional
activities to include in-plant and emironmental monitoring, bioassay analyses, and
in strument c ali brati on s
Materials License SUA-1371 Condition 9.4 presents the requirements for the "Safety and
Environmental Review Panel (SERP).
2.0 INTRODUCTION
The SERP expands the work scope o{ and replaces the Radiation Safety Committee.
3.0 APPARATUS
None-
4.0 PRQEEpTTRE
4.1 The SERP shall consist ofthe following individuals:
The Mill Superintendent, or the equivalenq who has expertise in management and is
responsible for managerial and financial approval changes.
The General Foreman, or the equivalent, who has expertise in operations and/or
construction and shall have responsibilrty for implementing any operational changes.
The Director of Regulatory Affairs, or the equivalent, who is responsible for all licensing
and permitting of the mill and for the submission of surety bonds and License
Amendments to theNRC.
Sunervi RSO, or the equivalent,
rnonitoringwho is responsible for irnplementing all
rocedures.
5-44
Plateau Resources Limite4 Source Material License
No. SUA-1371, NRC Docket No. 40-8698, March l,1996
and environrnental
Plarcau\Pen7rits\SuAl37 l\I 996\AP-3
NRC Approved and Added 0t/16/98
Compiled Application 0210?,198
radiological
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Environmental Procedure: AP-3
Revision: 1
Issue Date: 06-30-97
Page 2 of 3
Additional members may be added to the SERP as needed to provide technical expertise.
4.2 The work scope ofthe SERP is to review all:
(A) Changes in the facility or process, as presented in the March 1, 1996 License
Renewal Application with revisions.(B) Changes in the procedures, except for minor editorial changes.
(C) Tests or experiments not presented in the applicafion.
4.3 The SERP is to determine ifthe proposed changeq procedures, or tests:
(A) Conflict with any requirement specifically stated in the NRC license, or prevent
Plateau from meeting all applicableNRC regulations,(B) Degrade the essential safety or environmental commitments in Plateau's license
application or approved reclamation plan, or(C) Contradict the conclusions presented in the Environmental Assessment dated Apnl,
1997.
If (A), (B), or (C)is true, Plateau has to file an application for an amendment to the license and
receive approval from the NRC prior to implementation. Otherwise prior approval from theNRC
is not needed for implementation of the change, procedure, or test. In all cases, Plateau has to
document the basis for and the safety and environmental evaluation conducted by the SERP.
4.4 The SERP is to convene whenever changes, procedures, or tests need to be evaluated.
4.5 The licensee shall maintain the following records until license termination:
(A) The basis for and the safety and environmental evaluation conducted by the SERP.
(B) Descriptions ofthe changes, tests, or experiments, including a summary of the safety
and environmental evaluation.
(C) Changed pages to the approved License Renewal Application Sections 3 through 5
to reflect changes to the facility or procesq test or experiment.
4.6 Changes to procedures are to be maintained as described in Material License SUA-1371
Condition 9.6.
4.7 Annually Plateau is to submit to the NRC the descriptions of the changes, page changes to
the License Applicatioq tests, or experimentq including a summary of the safety and
environmental evaluation.
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Plateau Resources Limited Source Material License
No. SUA-1371, NRC Docket No. 40-8698, March I, 1996
Plateau\Permits\SuA 1 37 I \ I 995\AP-3
NRC Approved and Addcd 0l/16/98
Compilcd Application 02/02198I
5-45
T
I iil:.1#:larProcedure: t.,,,,Page 3 of3
l tl
s.o REsPoNsrBrLrrY
I Any member of the SERP can call a meeting of the SERP. Each member of the SERP is
responsible for the ovaluation of items on the agenda.
I 6.0 REFEREN.ES
I Nuclear Regulatory Commission Materials License SUA 1371.
I License Renewal Application dated March l, 1,996 as revised September 16 and
November 15, 1996 and April 25,1997
I 7.0 DrsrRrBUrroN
I This procedure is to be distributed by the ERHS to:
Vice President of Mlling
t M[ Superintendentr Director ofRegulatory Affairs (Corporate Radiation Safety Officer)
General Foreman (Mill Foreman)
I O
Maintenance Foreman
I #fiJlonal
an up-to-date copy of this procedure is to be kept in the mill area to which it
I 8.0 REVISIONS It *.r*,oIl-*,
I
Revision I 09-15-97
9.0 APPROVAL
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I ERIIS
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Plateau Resources Limitcd, Source Material Licensc
I
No. SUA-1371, NRC Docket No. 40-8698, March l, 1996
Plateau\Pcrmits\SUA I 371\1996\AP-3
NRC Approved and Added 0l/16/98
Compiled Application 02lOZl98
5-46
I
Shootaring Canyon MillI ffifi{;lfl*#:lr:llirjrlrlile/oe
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scM sERp sEE-9-2009 tnspection Frequency rev-2 ctean
ATTACHMENTB
RADIOACTIVE MATERIALS LICENSE UTOgOO48O
701812009
t]
ffi JoN r. rlMAI*r,JR.
Governor
CARY HERBERT
Lieutenant Crovernor
State of Utah
rutnrntr
Flr\-r-
ru
rutrttrrtrl
4tr!' fl'l
3l
olcrlelrul
May
f Department of
I Environmental Quality
Dianne R. Nielson, Ph.D.I .J;;ffi;,.N
CONTROL
I
Dane L. Finerfrock
SUBJ: RTVIL UT O9OO48O - LIC AMENDMENT NO 3CHANGE OF OWNERSHIP/JH
TOBY WRIGHT ENVI RON MENTAL MAFJAGERURANIUM (}I-IE IJTAH |r.rc
!Bo1 AuroruAnoN yuAv.sTE 1ooFORT COLLII.JS CO SOSZS
I
CERTIFIEI} MAII.,
RETIJRTX REgEJPT BE qtIESTEn
Toby Wright, Environmental Manager
Uraniurn One Utah, Inc.
3801 Autornation Wry, Suite 100
Fort Collins, CO 80525
Subject Radioactive Materials License UI 0900480 - License Amendmemt No. 3, Change of
Ownership
Dear Mr. Wright:
Enclosed is Amendment No. 3 to Radioactive Material License UT 0900480. This Amendment
incorporates the following changes:
l. Request to amend Licsnse Condition l. Change of ownership and control from Plateau
Resources Ltd., to Uranium One Utah, Inc.
2. Amend Liceirse Condition 2- Change of address.
3. Amend License Condition 9.5 surety tnrst agreement language.
If you have any questions or conrments, please contact me at [phone].
UTAH RADIAT]ON CONTROL BOARD
Dane L. Finerftdck, Executive Secretary
DLF/JH/jh
Enclosure
Cc: William Prince, Dorsey &Whitney, LLP
l6E Noilh I950 wcsr . PiO Box I44E50 . Sah Lake City, UT E4l 144t50 . phone (tol) 5364250 . far (t0l) 5334097
T.D.D. (t0l ) 5364414 . t+rvw.deq.utah.gov
a,ol*xH.IlE'Jtl,,'#,
EBHfl#';ry,,i*t,
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DRC.O3
UTAII DEPARTMENT OF' EI\TVIRONMENTAL QUALITY
DTVISION OF RADIATION CONTROL
RADIOACTIVE MATERIAL LICENSE
Ptrsuant to Utah Code Annotated, Title 19, Chapter 3 and the Utah Radiation Control Rules, Utah
Adminishative Code R313, and in reliance on stat€ments and representations heretoforemadebythe
licensee designated below, a license is hereby issued authorizing such licensee to transfer, receive,
possess and use the radioactive material designated below; and to use such radioactive matErial fot
the purpose(s) and at the place(s) designated below. This licensee is subject to all applicable rules,
and orders now or hereafter in effect and to any conditions speciflred below.
*** rlrt[***,1.*+ *** *** ****'t* ** f *'] *** *** t f ** ****']**** **t +'** *** ** *** *****rt rt**'f ****** {.{.t}*
l. Name
LICENSEE
Uranium One Utah, Inc.
3. License Nurnber UT 0900480
Amendment #3
'f * * * t * * * * * rl. ** * ** * ** rl. ** * * ** t *rfi t **
4. Expiration Date
April 30, 2012
* ** {. ** * ** t * * * * * * d.* {. {.!f * ** * ** rF #*,lc t
5, License Category 2-b
I 2. Address 3801 Automation Wa5 Suite 100
f Fort Collins, Colorado 80525
6. Radioactive material
(elernent and rnass
nurnber)
Natural Uranium
7. Chemical and/or physical form
Any
**t**f***i.************:1.**rl.*{.t**{.*+**************tr*****'}*t***rtt *r,}*,}**+*{.{.******+*
8, Maximum quantity licensee
may possess at any one time
Unlimited
rl +tt* trt* rl.* ***t*+* *:*rI* * *** ** *+** *'t* *!trt *{.:}*rt* *** *** rl.** *r}** *rt* r}* **r} ** * *rf {r *,f * **{.+ *** **
Section 9: Administrative Conditions
9. I The authorized place of use shall be the licensee's Shootaring Canyon uranium milling
facility, Iocated in Garfield County, Utah.
All written notices and reports to the Executive Secretary required under this license, with
the exception of incident and event notifications under the Utah Administrative Codes
(UAC) R313-15-1202 andUAC R313-19-50 (NuclearRegulatoryCommission(NRC), Code
of Federal Regulations (CFR), Title 10, Part 20, Section 20.2202 and l0 CFR 40.6
incorporated by reference), requiring telephone notification, shall be addressed to the
Executive Secretary, Utatr Radiation Control Board, Utah Department of Environmental
Quality (DEQ). Incident and event notifications that requiretelephone notification shall be
made to the Executive Secretary at (801)5364250 during normal business hours or after
hours to the DEQ Duty Officer at (801)536-41?3.
[Applicable NRC Amendment: 7, 8]
9,2
B.
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DRC-03
9,3
9.4
Page 2 of l0
UTAII DIVISION OF' RADIATION CONTROL
RADIOACTIYE MATERIALS LICENSE
SUPPLEMENTARY SIIEET
License # UT 09004-t0
Amendment# 3
The licensee shall conduct operations in accordance with statements, representations and
conditions contained in Sections I -9 of the license renewal application dated March l, 1996,
as revised by submittals to the NRC dated September 16, and November 15, 1996, and April
17,1997, except where amendments have superseded license conditions herein.
Whenever the word "will" is used in the above referenced sections, it shall denote a
reguironent.
[Applicable NRC Amendment: 1 ]
A. The licenseo may, without prior Executive Secretary approval, and subject to the
conditions specified h Part B of this condition:
(1) Make changes in the facilityorprocess, as presented in the approved license
application.
Make changes in the procedures presented
application,
Conduct tests or experiments not presented
application.
The licensee shall file an application for an amendment to the license, unless the
following conditions are satisfied.
(1) The change, test, or experiment does not conflict with any requirement
specifically stated in this license, or impair the licensee's ability to meet all
applicable State and Federal regulations.
There is no degradation in the essential safety or environmental commihents
in the license application, or provided by the approved reclamation plan.
The change, test, or experiment is consistent with the conclusions of actions
analyzel and selected in the Environmental Assessment (EA) dated April
1997.
The licensee's determinations concerning Part B of this condition shall be made by a
Safety and Environmental Review Panel (SERP). The SERP shall consist of a
minimum of three individuals. One member of the SERP shall have expertise in
management and shall be responsible for managerial and financial approval changes;
(2)
(3)
in the approved license
in the approved license
(2)
(3)
C.
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UTAH I}IVISIOFI OF RADIATION CONTROL
RAI}IOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
Page 3 of 10
License # UT.0.900480
Amendment # 3
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9.5
one merrrber shall have expertise in operations and/or construction and shall have
responsibility for implementing any operational changes; and, one member shall be
the corporate radiation safety officer (CRSO) or equivalent, with the responsibility of
assuring changes conform to radiation safety and environmental requirerre,nts.
Additional members may be included in the SERP as appropriate, to address
technical aspects such as health physics, groundwater hydrolory, surface-water
hydrology, specific earth sciences, and other technical disciplines. Temporary
members or pcnnanent members, other than the three above-specified individuals,
may be consultants. At least one mernber of the SERP shall be designated as
Chairman.
D. 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, madebythe SERP,thatprovide thebasis fordetermining
changes are in compliance with the requirements referred to in Part B of this
condition, The licensee shall fumish, in an annual report to the Executive Secretary,
a description of such changes, tests, or experiments, including a summary of the
safety and environmental evaluation ofeach, In addition, the licensee shall annually
submit to the Executive Secretary, a summary of changes made to the approved
license application and copies of the revised documeirts that reflect the changes made
under this condition. The licensee's SERP shall function in accordance with the
standard operating procedures submittod to the NRC by letter dated December 19,
t997.
[Applicable NRC Amendmeirt I ]
The licensee shall have 30 days from the signatory date of this license to submit an updated
revised surety estimate in accordance with the latest approved reclamation and
decommissioning plan for Executive Secretary approval consistent with UAC R3 13-24-4 (1 0
CFR 40, Appendix A, Criterion 9 and 10, as incorporated by refere,nce), The Licensee shall
maintain a financial surety arrangement that satisfies the requireme,nts of UAC R3l3-24
naming the Executive Secretary as the beneficiary to this arrange,nrent. The zurety
arrangement shall assure that suffrcient fuirds will be available to carry out the
decontamination and decommissioning of the mill and site and for the reclamation of any
tailings or waste disposal areas, Etound water restoration as warranted and the long-term
surveillance feq if accomplished by a third party.
Within 30 days of receipt of the Executive Secretary-approved revised surety estimate, the
licensee shall submit, for Executive Secretary approval, correqponding financial surety
documents if the amount in the revised surety estimate excecds the amount covered in the
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DRC.O3
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
Page 4 of 10
License # UT 0-900480
Amendment # 3
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existing financial surety. The revised surety shall then be in effect immediately upon receipt
of written Executive Secretary approval. Annual Updates to the surety amount, required by
UAC R3l3 -24 (10 CFR 40, Appendix A, Criteria 9 and 10, incorporated byreference) shall
be submitted to the Executive Secretary on or before April 23, of each year. Ifthe Executive
Secretary has not approved a proposed revision to the suret5r coverage 30 days prior to the
expiration date of the existing surety arrangernent, the licensee shall extend the existing
surety arrangement for 1 year. Along with each proposed revision or annual update, the
licensee shall submit supporting docume,ntation showing abreakdown of the costs and the
basis for the cost estimates with adjustme,nts for inflation, mainte,nance of a minimum 15
percent contingency fec, changes in engineering plans, activities performed, and any other
conditions affecting estimated costs for site closure. The basis for the cost estimate is the
Executive Secretary-approved reclamation/decommissioning plan or Executive Secretary
approved revisions to the plan. The previouslyprovided guidance entitled "Recommended
Outline for Site Specific Reclamation and Stabilization Cost Estimates" outlines the
minimum considerations used by the NRC in the review of site closure estimates.
Reclamation/decommissioning plans and annual updates should follow this outline, The
curently approved financial surety arrangonent, a Surety Trust Agreement between Uranium
One Utah, Inc. and Wells Fargo Bank, National Association, shall be continuously
maintained in an amount no less than $6,653,049 for the purpose of complying with UAC
R313-24 (10 CFR 40, Appendix A, Criteria9 and 10, as incorporatedbyreference) until a
replacement is authorizdby the Executive Secretary.
[ApplicableUDRC Ame,ndment: 2] [Applicable UDRC Amendment 3]
[Applicable NRC Amendments: 2, 5, 6, 8, 9, I 1] The amount of funds to be ensurod by such
surety arrangements must be based on Executive Secretary-approved cost estimates in an
Executive Secretary-approved plan for decontamination and decommissioning of mill
buildings and the milling site to levels which allow unrestrictd use of these areas upon
decommissioning and the reclamation of tailings and/or waste areas in accordance with
technical criteria delineated in UAC R3l3-24. The lic€nsee shall submit this plan in
conjunction with an environmental report that addresses the expected environmental impacts
of the milling operation, decommissioning and tailings reclamation, and evaluates
alternatives for mitigating these impacts. The surety must also cover the payment of the
charge for long-term surveillance and control required by R3l3-24-4. kr establishing specific
surety arrangernents, the licensee's cost estimates must take into account total costs that
would be incurred if an independent contractorwsehired to perform the decommissioning
and reclamation work. The licensee's surety mechanism will be reviewed annually by the
Executive Secretary to assure that sufficient funds are available for completion of the
reclamation plan. The amount of surety liability shall be adjusted to recognize any increases
or decreases resulting from inflation, changes in engineeringplans, activitiesperformed, and
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DRC-03
UTATI DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
Page 5 of l0
License # UT 0900{8-0
Amendrnent#3
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9.6
9.7
9.8
9.9
any other conditions affecting costs. Regardless of whether reclamation is phased through
the life of the operation or takes place at the end of operations, an apptopriate portion of
surefy liability must be retained until final compliance with the reclamation plan is
determined by the Executive Secretary.
Written procedures shall be established for site reclamation, personnel and environme,ntal
monitoring and survey instrument calibrations. These procedures shall be reviewed and
approved in writing by the CRSO before implementation and whenever a change in
procedure is proposed to ensure that proper radiation protection principles are being applied.
In addition, the CRSO shall perform a documented review of all existing site procedures at
least annually. An up-to-date copy of each written procedure shall be kept by the CRSO.
[Applicable NRC Amendment: l0]
Thelicensee shallhave anarchoological surveyperformed priorto dishlting anypreviously
unsurveyed areas. The licensee shall immediately noti$r the Executive Secretary and the
Office of State Historic Preservation if artifacts are discovered during disturbance.
The licensee is hereby authorized to possess I I e.(2) byproduct material as defined ifl I 0 CFR
20.103 and adopted bytheUAC R3l3-12-3UAC Section R3l3-12-3, inthe formofuranium
waste tailings and other uranium blproduct waste generated by the licensee's milling
operations authorized by this license within the State of Utah where the Division maintains
jurisdiction for regulating the blproduct material. Mill tailings shall not be transferred from
the site without specific prior approval of the Executive Secretary in the form of a license
amendment. The licensee shall maintain a permanent record of all transfers made under the
provisions of this condition.
The liceirsee is hereby exempted from the requireme,nts of Section 20. I 902(e) of l0 CFR Part
20 incorporated by reference UAC R313 -15-902(5) for areas within the mill, provided that
all entrances to the mill are conspicuously posted in accordance with Section 20.1902(e)
IUAC R313-15-902(5)] and with the words, "Any Area Within this Mill May Contain
Radioactive Materi al. u
9.10 The licensee shall have a training program for all site employees as described in the NRC
Regulatory Guide 8.31 "Information Relevant To Ensuring That Occupational Radiation
Exposures At Uranium RecoveryFacilities Will Be As Low As Is ReasonablyAchievable",
and Section 5.3 of the approved license application. The CRSO, or the licensee's designee,
shallhave the education, training and experie,nce as specified inNRC RegulatoryGuide 8,31.
The CRSO shall also receive 40 hours of relatod health and safety refresher training every
two years. Individuals designated as the Radiation Technician (RT) shall report directlyto
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DRC-03
Page 6 of l0
UTAII DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SEEET
License # uT 0900480
Amendment # 3
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the CRSO on matters dealing with radiologrcal safety. In addition, the CRSO shall be
accessible to the RT at all times. The RT shall have the qualifications specified in NRC
Regulatory Guide 8.31, or equivalent. Any person newly hired as an RT shall have all work
reviewed and approved by the CRSO as part of a comprehensive haining prograrn until
appropriate course training is completed, and at least for six months from the date of
appointment.
[Applicable NRC Amendments: 1,1 0]
9.1 I Prior to termination ofthis liceirse, the licensee shall provide for tansfer oftitle to blproduct
material and land, including any interests therein (other than land owned bythe United States
or the State of Utatr), which is used for the disposal of such blproduct material or is essential
to ensure the long-term stability of such disposal site to the United States or the State of
Utah, at the State's option.
[Applicable NRC Amendment: l0]
Section l0: Operational Controls, Limits, and Restrlctions
10.1 DELETED byNRC Amendment No. 10.
10.2 DELETED by NRC Amendment No. 10,
10.3 DELETED by NRC Amendment No. 10.
10.4 DELETED byNRC Amendment No. 10.
10.5 DELETED by NRC Amendment No. 10.
10.6 DELETED by NRC Amendment No. 10.
10.7 DELETED by NRC Amendment No. 10.
1 0.8 DELETED by NRC Amendment No. I 0.
10.9 All radiation monitoring, sampling and detection equipment shall be recalibratd after each
repair and as recommended by the manufacturer, or at least annually, whichever is more
frequent. In addition, all radiation survey instruments shall be operationally checked with a
radiation source each day when in use.
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Page 7 of l0
UTAII DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SSEET
License # UT 0900480
Amendment # 3
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[Applicable NRC Amendmenl l]
10.10 The licensee shall reclaim the tailings disposal area in accordance with the Tailings
Reclamation and Decommissioning Plan for the Shootaring Canyon Uranium Project
submitted by letter to the NRC dated October 24,2002,as amended by NRC submittals dated
February 24, Apil24, Jr;/ry 30, September 5, Novembet 26,2003, January 3, 2005, and
January 10,2005.
[Applicable UDRC Amendment: l]
A. DELETED by NRC Amendment No. 12.
B. DELETED by NRC Amendmerrt No. 10.
C. DELETED byNRC Amendment No. 10.
[Applicable NRC Amendment 12]
Section 11: Monitoring, Recording, and Bookkeeping Requirements
ll.2
The results of sampling, analyses, surveys and monitoring, the results of calibration of
equipment, re,ports on audits and inspections, all meetings and training courses required by
this license and any subsequent reviews, investigations, and corrective actions, shall be
documented. Unless othenvise specified by the Executive Secretary, the licensee shall retain
the records for five (5) years after the record is made.
The licensee shall conduct the environmental monitoringprogram described in Table 5.5-8 of
the lice,nse renewal application and UAC R313-24-3.
Each license renewal, major license amendment, or before engaging in any activity not
previously assessed by the Executive Secretary or specified in the license application or this
License, the licensee shall pre,pare and record an Environmental Analysis environmental
evaluation of such activity(s). When the evaluation indicates that such activity may result in a
significant adverse environmental impact that was not assessed or that is greater than that
assessed, the licensee shall provide a written evaluation describing the proposed action, a
stat€ment of its purposes, and the environment affected. The environmental report shall
present a discussion of the following: (a) An assessment of the radiological and
nonradiological impacts to the public health from the activities to be conducted pursuant to
the license or amendm€nt; (b) An assessment of any impact onwaterways and groundwater
resulting from the activities conducted pursuant to the license or ame,lrdment; (c)
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UTAII DIVISION OF RADIATION CONTROL
RAI}IOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
Page I of t0
License # UT 098p480
Amendrnent # 3
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Consideration of altsrnatives, including alternative sites and engineering methods, to the
activities to be conducted pursuant to the license or amendment; and (d) Consideration of the
long-term impacts includingdecommissioning, decontamination, and reclamation impacts,
associated with activities to be conducted, Commencenrent of such activities prior to
issuance of the license or amendment shall be grounds for denial of the license or
amendment. The Executive Secretary shall provide a written analysis of the environmental
r€,port, which shall be available for public notice and comment pursuant to R313-17-2.
A. DELETED by NRC Amendment No. 10.
B. DELETED by NRC Amendment No. 10.
ll.3 The licensee shall implement a groundwater detection-monitoring program to ensure
compliance with UAC R317-6, Ground Water Quality Protection and UAC R3l3-24 (10
CFR 40, Appendix A, as incorporated by reference) as follows:
A. The licensee shall sample monitoring wells RMl, RM2R, RM7, RM12, RMl4,
RMI 8, and RMl9, on a semiannual basis, with samples taken at least 4 months apart.
The samples shallbe analyzed forarsenic, chloride, selenium, U-naL sulfate,barium,
cadmium, chromium, copper, lead, mercury, molybdenum, silver, zinc, ammonia,
fluoride, nitrate, nitrite, conductivity, total dissolved solids, and pH.
The lice,nsee shall measure water level in monitoring wells RMl, RM2R, RM7,
RM8, RM12, RMl4, RMl8, RM19, RM20, RM2l, and RM22, on a semiannual
basis, with measurements taken at least 4 months apart.
B, The licensee shall compare the analysis results against the following threshold
values:
I DRC.O3
I Page 9 of l0
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License # UT 0909480
Amendment # 3I
I Arsenic -
Chloride :
U-nat :
pH:
0,022 mg/I,
40 mg/I,
0.022 mgI,
0.037 mgll, and
6.8 standard units.I
t If the threshold values listed above or in UAC R3l3-24-4 are exceeded (for pH, an
exceedance is a pH less than 6.8) the licensee shall propose, within 60 days of a
measured exceedance, an expanded detection monitoring program to define the
extent and concentration of hazardous constituents in the uppermost aquifer.
C. The licensee shall submit the data and comparison results required under zubsections
A and B, respectively, with the semiannual reports required under UAC R313-24-3
(10 CFR 40.65, as incorporated by refereuce).
D. The licensee shall report at least annually in accordance with the reporting
requirements specified in subsection C and UAC R313 -24-3,therate and direction of
groundwater flow under the tailings impoundment.
[Applicable NRC Amendment: 10, 12]
11.4 DELETED by NRC Amendment No. 10.
1 1.5 DELETED by NRC Amendment No. 10.
I 1.6 DELETED by NRC Amendment No. 10.
ll.7 The licensee shall perform an annual ALARA audit of the radiation safety program in
accordance with R313-15-101 and in the NRC Regulatory Guide 8.31, "Information
Relevant to Ensuring that Occupational Radiation Exposures at Uranium Recovery Facilities
Will Be As Low As Is Reasonably Achievable",
Section 12: ReportingRequirements
l2.l DELETED by NRC Amendment No. 10.
12.2 The Licensee shall, within 60 days after January I and July 1 of each year, submit a report to
the Executive Secretary. The report which must speciff the quantity of each of the principal
radionuclides released to unrestricted areas in liquid and in gaseous effluents during the
previous six months of operation, and such other information as the Executive Secretary may
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UTAH DIVISION OF'' RADIATION CONTROL
RADIOACTTVE MATERIALS LICENSE
SUPPLEMBNTARY SHEET
Page 10 of l0
License # UT 0900480
Amendrnent # 3
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require to estimate maximum potential annual radiation doses to the public resulting from
eflluent releases. The report shall specifically covsr quantities of radioactive materials
released during the reporting period to etuure compliance with the licensee's requirements.
On the basis of such reports and any additional information the Executive Secretary may
obtain from the licensee or others, the Executive Secretary may from time to time require the
licensee to take such action as the Executive Secretary deerns appropriate. The results of all
effluent and environmental monitoring data required by this liceirse shall be reported in
accordancewithrequirementsof I0CFR40.65 incorporatedbyreference inUAC R313-24-3
and UAC R3l3-17-2, to the Executive Secretary. Monitoring data provided in accordance
with the requirernents of l0 CFR 40.65 shall be reported in the format shown in the NRC
guidance entitled, "Sample Format for Reporting Monitoring Data."
UTAH RADIATION CONTROL BOARD
Executive Secretary
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Shootaring Canyon MillI if,Tff#ffiilx&'l'fllft:,i?x,":ti'r Safety and Environrnental Evaluation 9129109
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ATTACIIMENT C
ENVIRONMENTAL AS SES SMENT FOR
RENEWAL OF SOURCE MATERIAL LICENSE NO. SUA-137 I,
APRIL 1 997 .DOCKET NO. 40-8698
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scM SERPSEFg{ooglnrpection Frequency rev-z ctean Tolslaoos
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I Environmental AssessmentI
source rrr.,#rff1il:',i:. suA-1371
I Ptateau Resources Limited
Shootaring Canyon Uranium Mill
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Garfield County, Utah
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Enclosure 1
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EIWIRONMENTAL A SSESSMENT
FOR REIYEWAL OF
SOT]RCE MATERIAL LICENSE SUA-I}7I
PLATEAU RESOURCES, LTD.
SHOOTARING CANYON W MILL
GARHBLD COI.]NTY, LMATI
APRIL 1997
DOCKET NO. 40-g69g
[I.S. Nuclear Regulatory Commission
Office of Nuclear Materid Safety
and Safeguards
Divlsion of lVaste Management
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l;TABLE OF CONTENTS
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2.O SITE DESCRIPTION 5
2.1 Location ...... 52.2 Climate and Weather 52.3 Geology ...... 6
2.3.1 Regional Geology 6
2.3.2 Locol Geology 6
2.3.3 Seismicity 62.4 Hydrology 72.4.1 Surface Water 7
2.4.2 Groundwater 72.5 Topography... 72.6 Demography 82.7 Land Use 9
3.O PHOCESS DESCRIPTION
1.O INTRODUCTION
1.1
1.2
1.3
3.1
3.2
3.3
4.1
4.2
4.3
4.4
4.5
4.6
Background lnformation 2ProposedAction ......4
Review Scope 41.3.1 Federal andStateAuthorities ......4
1.3.2 Basis of NRC Review . . . 5
Mill Circuit 11
Mill Waste Disposal 12
3.2.1 Mill Tailings... 13
3.2.2 Other Mill-Generated Wastes . . 14
lnspections of the Tailings Disposal System 14
lntroduction... 14
Air Ouality lmpacts 14
Historical andCultural Resources.. ...... 15
lmpacts to Water Resources 154.4.1 Surface Water lmpacts 154.4.2 Groundwaterlmpacts... 15
lmpactsonEcological Systems... ......16
Radiological lmpacts 164.6.1 Operational Mode 164.6.2 lnterim/Standby Mode 194.6.3 Radiological Assessment 20ln-PlantSafety ......21
4.O EVALUATION OF ENVIRONMENTAL IMPACTS 14
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TABLE OF CONTENTS
("ontinued)-o5.O ENVIBONMENTAL EFFECTS OF ACCIDENTS 22
5.1 Failure of Chemical Storage Tanks 22
5.2 Fires and Explosions 22
5.3 Pipeline Failure 22
5.4 Minor Pipe or Tank Leakage 23
5.5 Tailings lmpoundment System Accidents 23
5.6 Transportation Accidents 23
6.0 RECLAMATIONANDDECOMMISSION]NG ..,...24
7.O ALTERNATIVES . 24
8.O FINANCIAL SUBETY 24
9.0 CONSULTATION WITH AFFECTED FEDERAL AND STATE AGENCIES 25
1O.O FINDING OF NO SIGNIFICANT IMPACT 26
11.0 CONCLUSION INCLUDING ENVIRONMENTAL LICENSE CONDITIONS 27
REFERENCES .. 32
2.1
LIST OF TABLES
Paoe
Major Population Centers within 8O Kilometers of the
Shootaring Canyon Mii! Site I
L]ST OF FIGURES
Page
1.1
3.1
Location of the Shootaring Canyon
Generalized Flow Diagram of the U
Uranium Proiect ., . . r . . . . r . . r r . . t . r . . 3
ranium Milling Process
10for the Shootaring Canyon Mill
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lO 1.0 INTRODUCTION
By application dated March 1, 1996, and supplements and revisions transmitted by letters
dated September 16 and November 15, 1996, Plateau Resources Limited (PRL) requested
renewal of U.S. Nuclear Regulatory Commission Source Material License SUA-1371, tor
the resumption of milling activities at the Shootaring Canyon Uranium Project, which is
located in Garfield County, Utah.
With this license renewal, NRC will be authorizing a resumption of mill operations under
the Performance-Based License Condition (PBLC) format. Under Performance-Based
Licensing, the licensee has the burden of ensuring the proper implementation of the PBLC.
The licensee may:
Make changes in the facility or process, as presented in the application,
Make changes in the procedures presented in the application, or
Conduct tests or experiments not presented in the applicalon, without prior NRC
approval, if the licensee ensures that the following conditions are met:
(1) The change, test, or experiment does not conflict with any requirement
specifically stated in this license (excluding material referenced in the PBLC),
or impair the licensee's abiiity to meet all applicable NRC regulations;
There is no degradation in the essential safety or environmental
commitments in the license application, or provided by the approved
reclamation plan; and
The change, test, or experiment is consistent with the NRC's conclusions
regarding actions analyzed and selected in the Environmental Assessment
(EA).
Otherwise, the licensee is required to submit an application for a license
amendment from the NRC. The licensee's determinations regarding whether the
above conditions are satisfied will be made by a Safety and Environmental Review
Panel (SERPI.
The SERP shall consist of a minimum of three individuals. One member of the
SERP shall have expertise in management and shall be responsible for managerial
a^d financial approval changes; one member shall have expertise in operations
and/or construction and shall have expertise in implementation of any changes; and,
one member shall be the corporate radiation safety officer (CRSOI or equivalent.
Additional members may be included in the SERP as appropriate, to address
technical aspects in several areas, such as health physics, groundwater hydrology,
surface water hydrology, specific earth sciences, and others. Temporary members,
or permanent members other than the three identified above, may be consultants.
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1.1
The licens"" ,traintain records until licens",.rrilion of any changes made
pursuant to the PBLC. These records shalf include written safety and environmental
evaluations, made by the SERP that pro,ride the basis for determining that the
change complies with the requirements referred to in the above conditions. The
licensee shall furnish an annual report to the NRC that describes such changes,
tests, or experiments, including a summary of the safety and environmental
evaluation of each. ln addition, the licensee shall annually submit any pages of its
license application that have been rev,sed to reflect changes made under this
condition.
PRL has not yet submitted its standard operating procedures (SOPs) for operation of the
SERP. Therefore, NRC will require, by license condition, that PRL submit the SOPs for
NRC review within 6O days of the date the renewal license is issued, and until such time
as NRC approves the SOPs, PRL will not be authorized to implement the PBLC. PRL
agreed to this license condition by telephone on March 31, 1997.
NRC's inspection function remains unchanged with the administration of Performance-
Based Licensing. Operational changes, regulatory commitments, and recordkeeping
requirements implemented by PRL through the PBLC are subject to NRC inspection and
possible enforcement actions.
Bq.ckglound I nformation
By letter dated May 5, 1978, PRL applied to NRC for a source and byproduct material
license to construct and operate a uranium milling facility in Garfield County, Utah,
approximatelV 22 kilometers (km) (14 miles) by road north of Bullfrog Basin Marina and
about 8O km (48 miles) south of Hanksville, Utah (Figure 1.1). As a result of studies
conducted for a Final Environmental Statement (FES) (NUREG-OS83; NRC, 1979a), NRC
concluded that the adverse environmental impacts associated with PRL's Shootaring
Canyon uranium project were such that the use of the mitigative measures proposed and
implemented by the applicant would reduce any adverse impacts to acceptable levels.
Following issuance of the FES in July 1979 and the staff's Safety Evaluation Report (SEB)
in September 1979, NRC Source Material License SUA-I371 was issued on
September 21, 1979.
Follo..rying start-up testing, PRL operated the Shoo'aring Canyon mill for approximately
three months in 1982. before suspending operat,ons in August 1982 due to the continued
decline in the market price for yellowcake. By application dated November 26, 1984, and
subsequently amended by submittal dated August 13, 1985, PRL applied for renewal of
SUA-I371 authorizing an indefinite shutdown of the mill. SUA-I371 was renewed on
February 3, 1986, for "possession only" status. The NRC staff prepared a suppiemental
EA and SER at that time to document its review.
SUA-I371 was due to expire on December 31, 1993. By letter and attachments dated
November 29, 1993, PRL applied for renewal of SUA-I371 tor continuation of a
"possession only" status, and was notafied in return by the NRC staff that the license was
in timely renewal by letter dated January 1 1, 1994.
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Figure 1 .1 Location of the Shootaring Canyon Uranium Prolect (PRL, 1 997)
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By submittal dated ^;., 1, 1996, PRL amended its r,ror"l,
to request a resumption of milling operations at :h. Shootaring
1 993 renewal application
Canyon site (PRL, 1996).
1.2 Proposed Action
The proposed action is to issue a renewal of the subject license for operation of the
Shootaring Canyon facility at a maximum production rate of 1,OO4,O0O pounds of
yellowcake per calendat yeat. Additionally, PRL raill be authorized, by license condition,
to oossess byproduct material in the form of uranium waste tailings and other uranium
byproduct waste generated by its milling operations authorized by the renewi., ..w€r'lse.
1.3 Review Scope
1 .3.1 Federal and State Authorities
NRC source material licenses are issued under Title 10, Code of Federal Begulations,
Part 4O (1O CFR Part4Ol. As stated in 1O CFR 4O.3, "A person subject to the regulations
in this part may not receive title to, own, receive, possess, use, transfer, provide for long-
term care, deliver or dispose of byproduct materiai or residual radioactive material as
defined in this part or any source material after rerroval from its place of deposit in nature,
unless authorized in a specific or general licerse issued by the Commission ..." Source
material is defined under 1O CFR 4O.4 as (1) uraniurn or thorium, or any combination
thereof, in any physical or chemical form, or (21ores which contain by weight O.O5
percent or more of uranium, thorium, or any combination thereof.
ln addition, the Uranium Mill Tailings Radiation Control Act of 1978, as amended
(UMTRCA), requires persons who conduct uranium source material operations to obtain a
il:H:::ffi:i.Ii:ilTiji-3'lY,i;li3;,3!i^iiil:il1','"il?"Xj:fl 3"if il"jfJ":^"O
prepared under 1O CFR Part 51, "Licensing and Regulatory Policy and Procedures for
Environmental Protection," which implements NRC's environmental protection program
under the National Environmental Policy Act of 1969 {NEPA}. ln accordance with 1O CFR
Part 51, an EA serves to (al briefly provide sufficient evidence and analysis for determining
whether to prepare an environmantal impact statement (ElS) or a finding of no significant
impact (FONS!), (b) facilitate preparation of an EIS when one is necessary, and (c) aid the
NRC's compliance with NEPA when an EIS is not necessary.
lmpacts from the commercial scale operation of the site were previously evaluated in the
FES (NRC, 1979a). The EA and SER for the previous renewal of SUA-I371 for
"possession only" status were issued by the NRC staff on February 3, 1986.
A new SEB will accompany this EA. ln preparing these two doc,rments, the staff will
re-evaluate the potential impacts associated with the commercial operation of
the Shootaring Canyon mill. Should the NBC issue a FONSI, based on the licensee's
application materials, previous operational data, and information in the FES and previous
EA, a renewed commercial source material license would be issued to PRL.
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l;The State of Utah Department of Environmental Ouality IDEO) administers and ir,tplements
the State's rules and regulations.
1.3.2 Basis of NRC Review
The NBC, Division of Waste Management, staff has assessed the environmental and safety
impacts associated with the renewal of PRL's ccrn:'nerciai license for the Shcotaring
Canyon mill, and documented the results of the assessment in this report. The staff
performed this appraisal in accordance with the requirements of 1O CFR Part 51.
ln conducting its assessment, the staff considered the following:
!nformation contained in the previous environmental evaluations of the Shootaring
Canyon project (i.e., the 1979 FES and the 1986 EA);
Information contained in PRL's March 1, 1996, amended renewal application, and
supplementar., information submitted by letters dated September 16 and
November 15, 1996;
lnformation contained in PRL amendment requests, NRC approvals of such
requests, and land use and environmental monitoring reports;
Personal communications with PRL, State of Utah DEQ staff, and the U.S. National
Park Service; and
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2.O
lnformation derived from NRC staff site visits and inspections of the Shootaring
Canyon mill site.
SITE DESCRIPTION
2.1 Location
The prolect site is located in southeastern Utah, in Garfield County, approximately 22
(14 milesl by road north of Bullfrog Basin Marina, which itself is located on the shores
Lake Powell in the Glen Canyon National Recreation Area. The mitl can be reached by
taking a private road for approximately 3.2 km (2 miles) west of Utah State Highway
All operations to be authorized by the renewai license will be conducted within the
confines of the existing site boundary. The project site occupies approximately 40
hectares (1OO acres) within Townships 35 and 36 South, Rang€ 11 East.
2.2 Climate and Weather
km
of
276.
The regional climate is semi-arid, although there are the expected variations in precipitation
and temperature with changes in elevation and terrain. Days are usually sunny, with low
humidity, and high potential evaporation. Daily temperature ranges can be relatively large,
and winds, predominantly from the south, are light to moderate, with an average annual
wind speed of 6.0 knots (7 miles per hour). Precipitation at the site averages
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t yeat,with the majority tl ,",,,nn during tateapproximately 17.8 cm (7 inches) per year, with the m€
summer/early fall or as winter showers and thuncierstorms,
A more detailed discussion of the local and regional climate and weather is contained in
the FES (NRC, 1979a).
2.3 Geoloov
2.3.1 Regional Geology
The project site is located in southeastern Utah in the Henry Mountains Basin cf the
Colorado Plateau. The basin is one of seven major basins that compose approximately
one-third of the Colorado Plateau. lt is bounded on the east by the Monument Uplift, and
on the west by the north/south-trending Waterpocket Fold. Elevations within the Henry
Mountains Basin range from 12OO to 21OO meters (approximately 4OOO to TOOO feet).
Peaks within the Henry Mountains were formed as the result of igneous intrusions of
diorite porphyry, and are between 25OO and 35OO m (82OO and 1 1,5O0 ft) high.
The only faults in the basin are located near Mount Holmes, Mount Ellsworth, and the San
Rafael Swell. These faults trend west-northwest to east-southeast, and displacements
along them range from several meters to several hunored meters.
2.3.2 Local Geology
At the site, the geologic structure is generally simple, with sediments dipping gently
westward at about two degrees. Sedimentary rocks exposed at the site are predominantly
sandstones of Upper Jurassic age. The high buttes and mesas west and north of the site
::;iiii"i,iiJ[",i:*#::Ty,m*T#-:11".'ft ',Ttri',T:'i*;[::i:."l:1i'"?:tilO
comprised of the Summerville and Entrada formations.
The Entrada Formation, a generally massive, fine-grained, calcite-cemented sandstone,
underlies the site. tn the vicinity of ut€ site, the Entrada is approximately 14O m (45O ft)
:hick. Located stratigraphically beneath the Entrada, the Carmel Formation is a
heterogeneous unit approximately 66 m (215 ft) thick, composed of sandstone, siltstone,
mudstone, limestone, and gypsum. The Carmel is itself underlain by approximately 24O m
(8OO ft) of a massive sandstone, the Navajo Formation. The base of the Navajo lies
approximately 45O m (14OO ft) beneath the site.
2.3.3 Seismicity
Since 1853, approximately 150 earthquakes of magnitude 3.5 or greater have been
recorded withan 322 km (2O0 miles) of the site. The largest of these events occurred
approximately 1 77 km (1 1O miles) northwest of the site, with a maximum intensity of Vlll
to lX (Modified Mercalli) and an estimated magnitude of 6.7 on the Richter scale. The
event nearest the site was a magnitude 4.O earthquake, which occurred on August 22,
1986, and was centered approximately 32 km (2O milesl southeast of the site.
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l;2.4 Hvdroloqy
'2.4.1 Surface Water
The facility is located within the Hansen Creek drainage basin. Streams in this 342
square-kilometer (132 square-mile) basin are ephemeral, and the shoreline of the nearest
large permanent body of water, Lake Powell, is found approximately 1 2 km 17 miles) to
the south. SubstoDi,ur surface flows can occur in the stream beds in response to snort,
intense thunderstorms, but these flows are quickly dissipated chiefly through percolation
into the underlying stream channel.
2.4.2 Groundwater
The primary aquifers in the area are the Entrada and Navajo sandstones. Depths to water
in the Entrada range between approximately 43 m (14O ft) below the surface of the
tailings impoundment to approximately 64 m l21O ft) below the surface of the low mesa
beneath the mill buildings. The hydraulic gradient in the Entrada beneath the impoundment
is to the south at approximatety 11.4 mlkm (6O ftlmile). Measured values of permeability
and transmissivity in the formation indicate that the Entrada would be expected to be a
low-yielding aquifer in the area.
Permeability and transmissivity values derived from pump tests indicate that the Navajo is
a much higher yielding aquifer than the Entrada. Depth to water in the Navajo averages
approximately 140 m (45O ft), and the water is confined under artesian conditions. A
more detailed discussion of the characteristics of the Entrada and Navajo aquifers is
provided in the FES (NBC, 1979a).
Wells G-2 and G-3, located near the Tony M Mine (about 5.6 km (3.5 mites) north of the
mill), are completed in the Entrada and Navajo Formations, respectively. Levels of total
dissolved solids, iron, and sulfate in G-2 water exceed drinking water standards, while G-3
water meets both drinking water and livestock standards.
Wells drilled in 1992 as part of a PRL-contracted study to evaluate potential site
environmental liabilities revealed the presence of a perched water zone localized
approximately 18 m (60 ft) beneath the tailings impoundment (lCF Kaiser, 19921. The
presence of this zone was determined from three wells rilM-7, -8, and -91 drilled by the
contractor in the central area of the impoundment; wells located approximately 122 m
(4OO ft) downgradient from these three wells did not encounter this perched zone. This
zone does not appear to have been impacted by the impoundment of generator cooling
water t ehind the main dam during 1981 -82, or the 1982 loss of tailings liquid from above
the cross-valley berm due to the failure of a circuit pump. Samples collected from RM-7,
-8, and -9 show background levels of radioactive and non-radioactive constituents (lCF
Kaiser, 1992).
2.5 Toooqraohv
The mill site is located in rugged terrain about 8 km (5 miles) southwest of Mount
Ellsworth (251O m18,235 ft highl, among bluffs and mesas characteristic of much of
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southeastern Utah.
forms the east side
in a small, isolated
approximately 135
west of this butte.
2.6 Pemoqraphv
The mill buildings are located nn a low mesa, 50 m (165 ft) high, that
of the tailings impoundment. The tailings impoundment is constructed
catchment, and is bordered on the west by a butte that rises
m l44O ft) above the valley floor. Shootering Creek lies just to tire
The mill is located in Garfield County, Utah, which, with a 1995 population of t., -2
spread across 13,512kmz (5,217 mi2), has population density of 0.3 persons per square
kilometer (0.8 persons per square mile). By comparison, the statewide density is 8.9
persons per square kilometer (23.2 persons per square mile). Garfield County's population
density is essentially unchanged since 1977.
Approximately 125O people live within 80 km (50 miles) of the Shootaring Canyon site.
Table 2.1 provides the population centers within 80 km (5O miles) of the mill site.
Table 2.1
Major Population Centers wi.hin 8O Kilometers
ot the Shootaring Canyon Mill Site
[.rrstance from Distance fromTown 1990 Population Site (km)' Site (miles)'
Ticaboo, UT 16 2.5 4
Bullfrog Marinal
Halls Crossing, UT
274 23 15
Boulder, UT 126 71 44
Hanksville, UT 209 80 48
Navajo lndian
Reservation
360'51 -80 32-50
t Approximate distance from rnill site by air
A oproximate population with survey areat
The majority of the mine and mill workers are expected to make their homes in the planned
community of Ticaboo. At the height of mine and mill operations, the population of
Ticaboo may approach 9OO (NRC, 1979a1. Since 1979, infrastructure (water and sewer,
etecuicat service, tetephones, etc.) has been installed at the townsite, and singte famity
and mobile home lots have been laid out. The socioeconomic impacts associated with the
development of the Ticaboo townsite were assessed in detail in the FES (NRC, 1979a).
The NRC staff has reviewed its earlier assessment and finds it still to be valid.
For the purposes of radiological dose calculations to members of the public (see Section
4.6.31, the nearest resident to the mill will be located in Ticaboo.
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2.7 Land Us_e
Greater than 9O percent of Garfield County is either Federally- or State-owned land, and
approximately 60 percent of the county is administered by the U.S. Bureau of Land
Management (BLM). Uses of this land may incluje recreation, mineral development, and
livestock grazing, ar rg others.
The Glen Canyon National Recreation Area (GCNRA) extends to within approximately
1O km (6 miles) of the site, while the boundaries of Capitol Reef National Park (CRNP)
come as close as 20 km (12 miles) to the west of the site. Approximatety 2.5 million
people visited the GCNRA during 1996 (NPS, 1997a1, greatq than 70 percent of whom
entered the recreation area at Wahweap, at the southwestern edge of the area. The 2.5
million visitors in 1996 represents an increase of approximately 8OO percent in the park
visitation rate since 1977. On September 18, 1996, President Clinton created the Grand
Staircase'Escalante National Monument, which encompasses approximately 728,45O
hectares (1.8 millior, acres) in Garfield anu Kane counties. The eastern boundaries of the
newly-created monument abut the western boundaries of the CRNP and the GCNRA.
GCNRA park officials do not believe that tlre creation of this nevr, national monument will
significantly impact visitation rates to the GCNRA based on the profiles developed for the
typical GCNRA visitor (NPS, 1997b).
Access to Lake Powell via State Highway 276 and Bullfrog Basin Marina is popular,
especially during the summer months, when peak use may approach 43,O0O persons per
month (PRL, 1996). Visitation to the marina during all of 1996 numbered 239,275 (NPS,
1997a), which represents a 53 percent increase since 1977.
A more detailed discussion of land use at and in the vicinity of the Shootaring Canyon site
is presented in the FES (NBC, 1979a). Archaeological studies conducted at the site and
vicinity as part of the original environmental report found only a single lithic scatter
of about 4OO m by 1OO m (13OO ft by 330 ft). The site access road was routed to avoid
most of the scatter area, and the State sal,.'aged the artifacts an the area prior to its being
disturbed,
PRL is currently required by license condition to conduct an annual land use survey of the
area within 8 kilometers (5 miles) of the site and to submit a report of the survey to NRC.
However, this survey is not required by the regulations, and therefore, with this renewal,
ilRC will drop this condition from the license. PRL is already required to comply with
annual dose limits to individual members of the public (1O CFR 20.13O1), and its
demonstrations of compliance address observed changes in land use.
3.O PROCESS DESCBIPTION
The mill facility is designed to process approximately 1O0O tons of uranium ore per day.
An average ore grade is expected to be 0.15 weight percent uran,um, and the plant is
expected to harre an overall recovery rate of 90 percent. Based on these values, the mill is
capable of producing approximately 1,004,000 pounds of U.O, per year.
A simplified flow diagram of the Shootaring Canyon mill circuit is provided as Figure 3.1.
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Crushing and
Grinding Circuit
Atmosphere
t
Dust Collection
Orgarric
Pregnant Leach
Solution
Barren
Organic
Pregnant
Organic
l-;2so4
NaCl03 Pregnant
StriP
NH3
Atrrtosphere
Tailings lmpoundment
Yellowcake
Product
Figure 3.1 Generalized Flow Diagram of the Uranium Milting Process
for the Shootaring Canyon tliill
Ore Stockpiles
Solvent
Extraction1st Stage
Leach
StrippingThickening
2nd Stage
Leach
Precipitation
and
Thickening
Drying
CCD
Wa.sl^,ng
Circuit
Wet Scrubbing
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3.1 Mill Circuit
'Mined ore is delivered to the site by truck from mines irr the Henry Mountains region.
Once at the site, following weighing of the truck, an ore load is either deposited on the
various stockpiles, or dumped directly into the ore hopper, A conveyor belt transports the
ore from the dump pocket to the first stage of processing, grinding.
A semi-autogenous grinding (SAG) mill is used to gr ind the ore, and water is introduced to
produce a slurry containing approximately 70 percent solids. This slurry is pumped to two
storage tanks. Material from these tanks is then transferred to a two-stage acid leach
process, in which sulfuric acid and sodium chlorate are used to leach the ore slurry. ln
between the two stages, a decant thickener is ernployed. The decanted liquid, containing
dissolved uranium, is sent to the solvent extraction process, while the thickened solids are
transferred to the multi-staged counter-current decantation (CCD) washing circuit.
The CCD circuit is employed to separate the strong acid liquor and wash the leached
residue. During each CCD stage, solid particles settle to the bottom of the thickener tank,
leaving a clarified uranium-bearing solution at the top. This solution is transferred "up-
stage," where the same process of decantation takes place. Overflow from the top (i.e.,
first) CCD thickener tank is sent to the two-stage leach process mentioned above. The
slurry at the bottom of the tank is progressively transferred "down" the circuit, and then
from the final thickener tank, it is pumped to the tailings disposal impoundment.
Meanwhile, the uranium-bearing liquid is transferred to a solvent extraction process which
is carried out in a series of mixing and settling vessels. First, the clarified and filtered
liquid is mixed with an organic solvent (kerosene), and the two are then allowed to
separate. After this mixing and settling is repeated several times, the resultant uranium-
rich organic solvent is sent to a series of mixing and stripping tanks, in which an
ammonium sulfate solution is used to strip the uranium from the organic solvent. The final
uranium-rich ammonium sulfate solution is transferred to the precipitation circuit.
Within the precipitation circuit, the pregnant solution is neutralized and yellowcake is
settled. The yellowcake is washed to remove soluble impurities, dewatered, and then
dried in a multiple-hearth furnace. From there, tl,e dried yellowcake is powdered and
packaged in 5S-gallon drums. Each drum holds an average of 34O kg (75O lb).
The product will be shipped by truck approximately 13OO miles to a conversion plant, with
each truck shipment containing approximately 48 drums, or 16,300 kg (36,O0O lb) of
yellowcake product. PRL expects that 27 shipments will be made annually, based on mill
capacity.
Air and gases from process vessels are passed through wet dust collectors or de-misters
to remove dust, mists, and gaseous particles. Gaseous effluents and dust are discharged
from any of eight stacks to promote atmospheric dilution and dispersion. Exhaust from
the furnace is vented through a wet dust collector before being emitted to the atmosphere.
Packaging operations are done within an enclosed room, with air from the room vented
through the same wet dust collector as that used for the furnace exhaust. Finally, during
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arethe entire route of production, concrete curbing and sumps
spillage and return it to the appropriate process circuit
designed to intercept any
3.2 Mill Waste Diseosal
3.2.1 Mill Tailings
:',i;!l ta;lings w;!l !:e deposited with!n the tailings impoundnrent that has been cor "cted in
a natural depression to the southwest of the processing facility. Tailings will be slurried
(they are approximately 45 percent solids by weight) through a 4-inch pipeline to the
impoundment system, with a supporting 18-inch half-round pipeline used to collect any
leakage. Currently, a 18-m (6O-ft) high dara is located at the downstream edge of the
impoundment, and a 9-m (3O-ft) high cross-valley berm has been constructed within the
impoundment approximately 61O m (2OOO ft) upstream from the dam. The portion of the
impoundment upstream of the berm was lined by PRL with two feet of compacted clay
prior to starting mill operations in 1982 and partially subdivided further by sand dividers.
A tailings drainage system was installed over the liner to facilitate dewatering of the
wastes. The tailings produced during the three months of operation in 1982 were
disposed in a lined subcell in this area.
PRL has proposed updating its liner design in advance of resuming operations. The
proposed design consists, from top to bottom, of a flexible membrane synthetic liner, a
leak collection/detection system, another flexible membrane liner, and a prepared and
compacted clay base. A tailings leachate collection system would be installed on top of
the upper synthetic liner and would drain to a sump from which the liquid will be used for
tailings dust abatement or recycled back to the mill. The NRC and State of Utah DEO
staffs have agreed to having the State take the lead in the review of PRL's proposed liner
design, which the State is conducting as part of its groundwater discharge permitting
process for the Shootaring Canyon facility (see Section 9 for further information on the
agreement between the NRC and State staffs). Until such time as an updated liner design
is approved by the State and NRC and the liner subsequently installed, PRL will not be
authorized to commence milling operations. PRL agreed to this license condition by
telephone on April 3, 1997.
PRL plans to develop the tailings impoundment incrementally by dividing the 28-hectare
(7O-acre) impoundment in three sections of 8-1O hectares l2O-25 acres) each. lnitially,
tailings produced following mill restart will be disposed in the re-lined portion of the
impoundment upstream of the existing cross-valley berm. Once this area begins to be
filled, a second cross-valley berm will be constructed approximatelv 245 m (8OO ft)
upstream of the main dam, and the area between the two berms lined. Tailings will be
dispused next in this area (i.e., between the two berms) until it toc is filled. The final area
to be filled will be that between the main dam and the second berm. This area will have
been lined with the commencement of tailings disposal in the second subcell.
Each of the three subcells will be subdivided further into a series of smaller disposal cells,
using tailings sand dividers, to allow for interim stabilization, more efficient dewatering,
and progressive reclamation of the cells. At no time du'ing the life of the project will any
of the three subcells exceed 16 hectares (4O acres) in size, and no more than two subcells
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l3 will be in operation at any one time. PRL expects to reduce dust and radon emanation
from the impoundment by covering sufficiently-de^ratered cells with an interim soil cover.
Exposed tailings will be sprayed to further reduce dust generation.
The impoundment has been designed with a net capacity of 26O0 acre-feet, which is
sufficient to contain the total expected tailings to be produced during 15 years of
operation. To reach this net capacity, PRL will need to raise the main dam an additional
12 m (4O ftl to increaoc the holding capacity. By license condition, PBL currently is not
authorized to raise the height of the dam beyond its present level or to construct additional
dims without prior NRC approval; this condition will be retained in the renewal license.
The present dam was designed and constructed in accordance with NRC Regulatory Guide
3.11 (NRC,19771. As such, the potential for instability under static, as well as seismic,
loads and of flood breach of the dam were analyzed by PRL as part of the preliminary and
final designs for the dam. The NRC staff reviewed and approved the final design and
reviewed records during construction of the dam. ln approving the fina! design for the
present dam, the NRC staff determined that PRL's proposed minimum freeboard of 13 feet
provided an adequate margin to contain all upstream runoff resultrng from a design storm
(i.e., from the probable maximum 6-hour precipitation (PMP), 40 percent of the 6-hour'
PMP, and the 1OO-year 6-hour precipitation, all occurring in direct succession) and wave
action coincident with the design flood (NRC, 1979a1. Although PRL does not expect to
be placing tailings against the dam until after 1O years of operation, the NRC staff will
require, by license condition, that PRL maintain a minimum freeboard of 13 feet between
the top of the present dam and the tailings pond level. ln addition, the NRC staff will
require that, at least three months prior to placing tailings against the dam, PRL will submit
a detailed dam instrumentation program to NRC for approval. PRL agreed to these
conditions by telephone on April 3, 1997.
The NRC staff has reevaluated the seismic stability of the taalings impoundment dam at its
current height, based on the work of Bernreuter, et al. (1994), which estimated the
horizontal peak ground acceleration (PGAI for the Shootaring Canyon site to be in the
range of 0.169 to 0.3g. Woodward Clyde Consultants, who prepared the 1979 final
design report for the impoundment dam, had analyzed the dam stability at a PGA of O.O8g.
The NRC staff's analysis determined that the dam would be stable under a PGA of 0.39.
The licensee is, however, required currently to submit the results of a technical evaluation
of the tailings dam and the existing cross-valley berm pnor to a resumDtion of operations.
Since PRL has yet to submit this report, NRC will continue to require, by license condition,
that this technical evaluation be conducted and the results submitted to NRC prior to mill
restart.
Finally, as mentioned in Section 2.4.2, a sump pump located at the downgradient edge ot
the present cross-valley berm failed in 1982. This pump had been installed to redistribute
collected tailings leachate to reduce tailings dust emanation, and during the period when
repairs to the pump were ineffective, an estimated two million gallons of tailings solution
flowed down a clay-lined swale and impounded behind the 6O-foot high tailings dam.
Remedial actions performed by PRL included: {1) investigating the extent of seepage of the
solution into the subsurface, (2! repairing the puop, (3) enhancing evaporation of the
impounded solution through water sprays, (4! pumping the solution back above the cross-
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valley berm, (5) excavating contaminated soil and near-surface rock and placing such
material behind the cross-vally berm, and (6) ccnducting regular groundwater detection
monitoring. The NRC staff verified the completion of these remedial actions in a
subsequent compliance inspection.
3.2.2 Other Mill-Generated Wastes
PRL has committed in its license renewal application to returning all liquid effluents from
the mill process buildings, with the exception of sanitary wastes, to the mill circuit or
discharging them to the tailings impoundment. This is currently required by license
condition and will continue to be so required. Sanitary wastes will be treated a;rd disposed
of through septic tanks and sanitary leach fields, in accordance with a State of Utah
Department of Health permit.
Nonsalvageable solid wastes (e.9., filters, pumps) contaminated in the mill process and
which cannot be decontaminated below NRC unrestricted release limits will be placed in
the tailings impoundment. PRL states that void space in such material will be minimized
prior to its emplacement in the impoundment.
3.3 lnspect_iens of the Tailing$ Disgosal. Svster;r
PRL has committed to conducting and documenting inspections of the tailings disposal
system on a daily basis while the mill is operating and monthly during standby periods.
PRL states that NRC Regulatory Guides 3. 1 1 and 3.1 1 .1 (NRC, 1 9801 were consulted in
developing its inspection program, which will address seepage, settlement and cracking,
tilting, pool level, and abutments.
From PRL's discussion in the renewal application, the NRC staff is not able to determine
how or to what extent PRL's inspection plan addresses the recommendations in the two
Regulatory Guides. Therefore, the NRC staff will require, by license condition, that PRL
conduct its inspection program of the tailings disposal system in conformance with
Regulatory Guide 3.11.1. PRL agreed to this condition by telephone on April 3, 1997.
4.O EVALUATION OF ENVIRONMENTAL IMPACTS
4.1 lntroduction
As noted above, the NRC staff previously has assessed the environmental impacts
associated with the construction and commercial operation of the Shootaring Canyon mill
(NRC, 1979a). Discussion in this section will include summaries of the staff's previous
findings, as well as an assessment of impacts associated with any changes since 1979.
4.2 Aif QuAJity hoaS.tq
Air quality impacts during operational phases of the mill are expected to be below Federal
andStatestandards(NRC, 1979a1. PRLwill contro! fugitivedustandradonreleasesfrom
the tailings impoundment through spraying and interim soil covers. Spraying will be used
to control dust emissions from ore stockpiles which are not immediately processed.
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Volatile fuels and reagents are stored in closed tanks to minimize the escape of vapors to
the atmosphere. Effluents from the laboratory will be collected by fume hoods and
'discharged through a scrubber and stack prior to release to the atmosphere. Other
emissions will be discussed in Section 4.6, Rad;ological lmpacts.
I An historical survey was conducted in the project vicinity as part of the initial application,
and no historical sites within 8 km (5 miles) of the site were identified. As noted
I previously, only a small area of lithic scatter was identified prior to construction, and the
I artifacts were salvaged by the State of Utah.
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I The licensee will continue to be required to conduct, as a minimum, an archaeologicalr artifact survey of areas not previously surveyed prior to their disturbance.
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4.3 Histo-rical, and Qultu,ral B-esogrce,g
r The NRC determined, in consultation with the State Historical Preservation Officer (SHPO),
I that the project will not affect any properties included in or eligible for inclusion in ther National Register (NRC, 1979a).
I 4.4 tmoacts to Water Resourcee
4,4.1 Surlace Water lmpacts
I The NRC staff has determined previously that operation of the mill will have minimal
IO effects on the surface waters in the site vicinity (NRC, 1979a1 because: (11 mill effluents
are not discharged to surface waters; (2) the site is graded so that mill surface runoff is
directed into the tailings impoundment; (3) sanitary wastes are treated in septic tanks and
then dispersed through State-approved buried leach fields; and (4) tailings from mill
I operations are discharged by pipeline to a lined impoundment. Finally, as noted above,
I PRL has committed to regular inspections of the tailings disposal system, including the
main impoundment dam.
t 4.4.2 Groundwater lmpacts
- Groundwater beneath or in the vicinity of the site should not be adversely impacted by the
I resumption of milling operations. The tailings impoundment will be lined with a multi-r layered system, composed of two flexible membrane synthetic liners over a prepared and
compacted clay base. A leak detection system installed between the two synthetic liners
I will be monitored regularly to determine whether there is any leakage from theI impoundment. PRL will be required, by license condition, to oropose corrective actions to
NRC in the event of a leak.
I tn addition, as discussed in Section 4.6.2,groundwater detection monitoring wells located
immediately downgradient of the impoundment dam will be sampled semiannually for
I indicator parameters. Concentrations of these parameters above NRC-approved limits
f would require PRL to propose a broader range of constituents for which to sample to
determine the presence of hazardous constituents related to the tailings impoundment.
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These detection monitoring requirements are currently contained as license conditions in
SUA-1371 and will continue to be so required in the renewal license.
4.5 Impac-tqlln Ecoloqlca,l, Svstems
Surveys for the presence of endangered species, both plant and animal, were conducted
as part of the initial licensing action. White no endangered plant species were identified in
the project area, the surveys did indicate the possible presence of the American peregrine
falcon lFalco peregrinus anatumi. However, the NFC staff did not consider thr, -,,ght
increase in the human population associated with the operation of the mill to have a
significant impact on the peregrine falcon, in light of the large numbers of people already
visiting the GCNRA annually (NRC, 1979a1. The site also is located within the range of
the Southwestern willow flycatcher lEmpidonax traillii extimusli however, this bird's
habitat requirements makes its likelihood of utilizing the site extremely low.
lmpacts to terrestrial and aquatic biota from mill operations were assessed previously by
the NRC staff (NRC, 1979a). At that time, the NRC staff determined that, although the
significant impacts to wildlife were not expected, the actual extent of these impacts could
not be quantified; therefore, the NRC staff requi'ed, at that time, PRL to conduct a wildlife
monitoring program as part of its operational effluent and environmental monitoring
program. Due to the limited extent of the initial mill operations in 1982, this wildlife
monitoring program was not of a sufficient duration to provide results to support the NRC
staff's initial determination. As part of the licensing renewal process, PRL agreed, by
telephone on Apri! 9, 1997, to conduct and document a daily visual inspection of the
tailings impoundment to monitor for wildlife. Depending on the results of this monitoring,
PRL may need to take appropriate corrective actions to mitigate any potential harmful
effects.
4,6 Radiolg,qjgal lmp3.gts
PRL has proposed to define two modes of activity at the mill: (1) "operational" and
(2) "interim" or "standby." The operational mode is defined as any time the mill is in the
normal commercial production of vellowcake, as contrasted with the interim mode which
occurs when no yellowcake is produced for a period of 30 days or mor6. ln examining
potential radiological impacts, the NRC staff has chosen to address these modes
separately in the following discussion.
4.6.1 Operational Mode
The Shootaring Canyon mill operated for only three months in 1982, and therefore,
ope;;tional data is very limated for review. Sampling results discuqsed in this section
were provided bythe licensee in accordance with the requirements of 1O CFR 40.65.
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a. Data
Air oarticulate samplino
PRL's air particulate monitoring program during past operations consisted of five
continuous high volume air samplers: two downwind of the tailings impoundment
and ore stockpiles; one upwind of the tailings impoundment; and one each at the
nearest residerr. drd a background station at the Bullfrog Marina. Measured
airborne concentrations of natural uranium (U-natl, thorium-230 (Th-230),
radium-226 lRa-226), and lead-21O lPb-21O) taken during previous operations were
small fractions (less than one percent) of the applicable 1O CFR Part20 limits for
unrestricted areas.
Stack effluent samolinq
During mil! operations in 1982, PRL sampled the sample preparation and the
yellowcake d!'.,er and packaging staeks once each. Sampl" results showed releases
below the applicable 1O CFR Part 2O limits for U-nat. The lrcensee was required to
perform quarterly sampling of the yellowcake dryerlpackaging stack and semiannual
sampling of the ore crusher stack.
Radon oas_monitorino
Sampkis were collected at the airborne particulate monitoring stations during
1982-84. Levels measured during this timeframe were a small fraction of the
applicable 1O CFR Part 20 limits.
Direct qamma exDosure
Direct gamma exposure measurements were collected at the same locations used
for airborne particulate and radon gas sampling. Measurements taken between
19A2 and 1984 showed little change from background readings, with the highest
readings recorded at the ore stockpile monitoring station.
Surface water samolino
During 1982 to 1984, samples were coltected from four surface seepage ponds and
Shootering Creek. Analysis of these samples shows that sampled constituent
levels were unchanged from pre-operational levels.
Groundwater samolino
Groundwater data collected from four groundwater wells and three drinking water
wells, from 1982 to 1984, indicated that measured concentrations of radionuclide
and chemical constituents were unchanged from pre-operational levels.
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Proposed Operational Monitoring Program
PRL has proposed the following environrnental and effluent monitoring program for
the operational mode:
Air particulate monitoring will be conducted for U-nat, Th-230, Ra-226, and
Pb-210 at five continuous spvirnq6sntal sampling stations. Three stations
are located at s;.e locations expected to see the highest readings (orv pad,
upwind and downwind of the tailings impoundment), one at the nearest
residence in Ticaboo, and one at a control location (background station at
Bullfrog);
Stack samples will be collected semiannually from the ore crusher stack and
quarterly from the yellowcake dryer and packaging stack and analyzed for
U-nat, Th-23O, Ra-226, and Pb-210. Flow rates from both stacks will also
be measured semiannually;
Quarterly environmental radon measurements will be performed at the same
locations as for air particulate sampling;
Direct radiation exposure measurements will be taken quarterly at the air
particulate sampling locations using thermoluminescent dosimeters (TLDs);
Vegetation samples will be collected annually (during the spring growing
season) from animal grazing areas downwind from the mill. Samples will be
held for one year and analyzed, if required, for Th-23O,Ra-226, and Pb-210
Soil sampling will be performed annually at the air particulate sampling
locations and analyzed for U-nat;
Surface water samples will be collected semiannually from two seeps,
located along Shootering Creek. These samples will be analyzed for U-nat,
gross alpha, arsenic, selenium, and pH; ancl
Groundwater samples will be collected semiannually from three monitoring
wells located at the downgradient e..ge of the tailings dam (RM-4. -5, and
-6) and a single upgradient well (RM-l), all of which are completed in the
uppermost aquifer, the Entrada. Samples will be analyzed for U-nat, arsenic,
selenium, chloride, and pH, with the results compared with specified
threshold limits. Corrective actions will be taken if these limits are
approached or if trends of increasing concentrations are observed. PRL also
proposes to measure water level elevations in these four wells in order to
calculate the groundwater flow rate and direction in the Entrada.
The NRC staff has reviewed PRL's proposed operational monitoring program against the
staff's recommendations in Regulatory Guide 4.14 and considers the program acceptable,
given the following modifications:
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t;o The flow rate from the yellowcake dryer and packaging stack shall be
determined quarterly at the time staek sampling is conducted.
. Soil samples shall be analyzed f.rr U-nat, Th-23O, and Ra-226.
These modifications will be required by license condition. PRL agreed to the modifications
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by telephone call on March 31, 1997.
ln addition, PRL will need to comply with the U.S. Environmental Protection Agency's
I requirements under 40 CFR 61.252 to keep radon-222 emissions from its rrill tailings pile
I from exceeding 20 pCilmz-s of radon-222.
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With the renewal of SUA-I371 in 1986 for "possession-only" status, PRL was not
required to: (1) conduct stack sampling, (2) perform radon gas monitoring, (3) take
direct radiation exposure measurements, (4) sample surface water, soil, or
vegetation locations, or (5) conduct meteorological sampling.
Air particulate sampling was conducted semiannually at two locations, one upwind
of the tailings impoundment and one downwind of the ore stockpiles and the
impoundment. Measured airborne concentrations of U-nat, Th-23O, Ra-226, and
Pb-210 were less than one percent of the applicable 1O CFR Part 20 limits for
unrestricted areas, throughout the interim shutdown period.
PRL was required by license condition to conduct a groundwater detection
I monitoring program to ensure compliance with the requirements in 10 CFR Part 40,
f Appendix A. This program required PRL to collect samples from three monitoring
wells located at the downgradient edge of the tailings dam (RM-4, -5, and -6), on a
I semiannual basis, and to analyze these samples for U-nat, arsenic, selenium,
I chloride, and pH. Sampling results were compared with NRC-approved threshold
limits contained in the license, and if these .imits were exceeded, PRL was required
r further to propose, within a set period of time, an expanded monitoring program to
I NRC for approval. Data cotlected since 1985 as part of this detection monitoringr program show negligible changes in the indicator parameters from their originally- sampled levels.
I b. Proposed tnterim Monitoring Program
During the interim mode, PRL proposes that the following not be conducted,
performed, or measured: (1) stack sampling, (2) radon gas monitoring, (3) direct
radiation exposure measurements, (4) surface water, soil, or vegetation sampling,
and l5) meteorologica! sampling.
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ln addition, PRL proposes
Iocation downwind of the
be collected serniannually
to reduce airborne particultampling to a single
tailings irnpoundment and ore stockpiles. Samples would
and analyzed f or U-nat and Ra- 226.
Groundwater samples would continue to be collected semiannually and analyzed for
U-nat, arsenic, chloride, selenium and pH, but only from wells RM-4, -5, and -6.
Groundwater flow rates and direction would not be calculated.
Despite the volatility in the market for yellowcake at the present, the NRC staf, -.,,es not
consider a 3o-day period of non-production to be significant enough to involve a major
modification to a licensee's environmental and effluent monitoring program, such as PRL
proposes. Therefore, the NRC staff does not find PRL's proposed interim monitoring
program acceptable, and will instead require, by license condition, that PRL continue to
conduct its operational monitoring program, with the exception of stack sampling, during
standby periods. Should a standby period become extended, PRL will have the opportunity
to request a license amendment to modify its operational monitoring program. PRL agreed
to this license condition by telephone call on March 31, 1997.
4.6.3 Radiological Assessment
a. Offsite lmpacts
The radiological impacts from milling operations at the Shootaring Canyon site have
been assessed previously and determined to fall well below Federal limits on doses
to individuals and the general public (NRC, 1979a and 1986a).
Although PRL's license was renewed in 1986 for "possession-only" status, the NRC
staff included, as part of the EA prepared at that time, an analysis of the potential
radiological impacts from future operations. Assuming in its analysis a nominal
milling rate of 1OO0 tons of ore per day, an average ore grade of O.1 5 percent, and
a yellowcake production rate of approximately 1,OOO,OOO pounds per year, the
NRC staff determined that both site boundary radionuclide concentrations and
individual dose commitments were small fractions of the then applicable standards.
For the current licensing action (i.e., the proposed resumption of operations), the
NRC staff re-examined the analysis prepar ed in 1986, because PRL did not include
the results from an updated radiological assessment as part of its renewal
application. The NRC staff's review was conducted in light of the NRC's revisions
to the radiation dose standards in 1994, which implemented both a new dosimetry
and a lower public dose limit. Based on its review, the NRC staff finds the 1986
analysis to be still valid, due to the conservative nature of the assumptions used
(e.9., spraying only reduced fugitive dust from the tailings impoundment by 50
percent). The staff determined that the nearest resident (located in Ticaboo) will
receive less than 10 microsieverts (1 millirem (mrem)) per year from site releases,
which falls well below dose limits to a member of the public contained in NRC's
1O CFR Part 20 and the U.S. Environnrental Protection Agency's 40 CFR Part 190
!n addition, a hypothetical individual present continuously where the highest
exposures would be received (i.e., at the east fence line) would receive
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lO approximately 0.9 millisieverts (mSv) (90 mrem) per year from inhaled
radionuclides, which is 0.1 mSv (10 rnreli,) less than the NRC dose limit in 1O CFR
Part 20.
b. Radiological lmpact on Biota Other than Man
f Although no guidelines concerning acceptaole limits of radiation exposure have
I been establishetr for the protection of species other than man, it is generally agreed
that the limits for humans are also conservative for other species. Doses from
I gaseous effluents to terrestria! biota {such as birds and mammals) are quite similar
I to those calculated for man and arise from the same dispersion pathways and
considerations. Because the effluents of the facility will be monitored and
r maintained within safe radiological protection limits for man, no adverse radiological
t impact is expected for resident animals.
I 4.7 ln-Plant Safetv
r fhe NRC, through 10 CFR Part20 and license conditions, requires a radiological safety
r program that contains the basic elements needed to assure that exposures are kept low or,
I in any event, as low as is reasonably achievable (ALARAI. Therefore, an in-plant radiationr satety program which includes the following is required:
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. Qualified management of the radiation safety program and appropriate
training of personnel,
. Written radiation procedures,
Airborne and surface contamination sampling and monitoring,
o lnternal and external radiation monitoring programs,
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. An approved respiratory protection program, and
. An annual ALARA audit and frequent in-house inspections.
I ln addition, during routine radiation safety inspections, rhe NRC staff observes in-plant- industrial safety for deficiencies and brings any deficiencies found to the attention of mill
I ;" il."1l,0"* the program of in-plant safety, as required by Federat resutations, and
the radiation safety program, as defined by 1O CFR Part 2O, to be sufficient to protect the
I worker during normal operations. The NRC evaluation of the licensee's radiation safetyr program is discussed more fully in the SER.
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a5.0 ENVIRONMENTAL EFFECTS OF ACCIDENTS
5. 1 Failure of Chemical Stgrage..f a;)ks
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A variety of industrial chemicals, process fluids, slurries, and flammable liquids, are stored
in tanks at the mill. Various systems have been implemented to contain or direct spillage,
whether routine or unplanned. A railure of an,, chemical holding tank would first be
contained by engineered dikes or curbs. Sumps are installed to collect the spillage, so that
it can be pumped back to the appropriate process circuit. lf the spilled volume was too
great, such as a rupture in one or more of the large production tanks, flow would be
discharged to the tailings impoundment by portable sump pumps or by gravity flow, as for
the CCD tanks.
5.2 Fire and Exp-losions
The greatest fire hazard is found within the solvent extraction (SX) circuit, which is
contained within the main mill building. To address this hazard, the solvent extraction
tanks are covered and protected by a carbon dicride (COr) fire suppression system that as
activated by heat detectors located inside the tank covers. A foam (wet) sprinkler system,
also heat-activated, is installed in the ceiling of the SX area, and two fire hydrants and
hose stations are located outside the SX area.
The plant water storage tank has a 15O,OOO gallon reserve for fire fighting, with constant
water pressure maintained by an electric pump. Diesel-powered water pumps provide a
backup to the electric pump, and these pumps will start if: (1)there is a drop in water
pressure; {2) there is a loss of power to the electric pump; (3) a fire alarm is pulled; or (4)
a mill-wide alarm system, encompassing both automatic sensors and manual pull stations,'is activated.
Other mill buildings (e.9., offices, laboratory areal are equipped with sensor-operated fire
suppression systems. Also available are fire hydrants outside the mill facility and hose
stations located inside the plant buildings. All fire suppression systems will be checked
routinely.
Currently, PRL is required by license condition to make repairs to the wet foam and
sprinkler fire suppression systems prior to a resurnption of mill operations. This condition
will be retained in the renewal license.
5.3 Pioeline Failure
The rupture of the pipeline between the mill and the tailings impoundment would be
caught by automatic alarms or by routine daily inspection. lf a leak did occur, the 18-inch
polyethylene half-pipe supporting the pipeline would catch leaking fluids and transport
them to the tailings impoundment via gravity flow. Fresh water from the mill could be
used to flush any residual material in the half-pipe to the impoundment.
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tanks overflowing,
will be used to
ermined and
I The tailings impoundment is designed to retain the process wastes generated at the
I Shootaring Canyon facility. The tailings dam was designed and constructed in accordance
with NRC Regulatory Guide 3.11, and the impoundment will be lined with a composite
r clay/synthetic liner. The impoundment dam and the liner leak detection system will be
I monitored regulart.; as part of the licensee's site inspectaon program.
I j ;:rr , pte, toose connections in pipins or
f will be collected in sumps designed for this typ; of spill. Sump pumps
I return the material to the circuit, and the reason for the spill will be det
corrected.
t 5.5 Tailinos lmpoundment system Accidents
r To address the potential failure of a cross-valley berm or of a sump pump, as occurred in
I 1982, PRL will tine not only the active cell (i.e., that cel! which is accepting tailingsrcurrently) but also the inactive cell immediately downgradient. ln addition, PRL will
r construct the second cross-valley berm as tailings disposal commences in the existing
I upstream cell. ln this way, tailings solutions released within the impoundment due to ther failure of a berm or pump will not flow into unlined areas. lf such an accident were to
occur, PRL would need to take appropriate corrective actions, including immediate
I notification of NRC, to address the event, actions which would be verified by NRC throughr compliance inspections.
IO s,6 Transoqrtation Ascidents
As noted in Section 2.7, State Highway 276 and Bullfrog Basin Marina may receive heavy
I traffic especially during summer months. For this reason, there is a concern over the
f potential for accidents involving trucks transporting ore or chemicals to the site or barrelled
yellowcake offsite. The NRC staff previously examined potential impacts from
I transportation accidents (NRC, 1979a). ln its analysis, the NRC staff considered: (11the
f amount of material transported per shipment, (2) the number of shipments of the material
pet yeat, (3) the likelihood of an accident; (4) the severity of a potential accident; (5) the
I amount of material potentially released; and (6) potential impacts to the general
I population. ln the case of yellowcake, the NRC staff also used experience gained from a
September 1977 accident at another location. Based on its review, the NRC staff
- determined that the potential impacts would not be significant (NRC, 1979a). For the
f proposed licensing action, the staff has reviewed the 1979 analysis and considers the
- results of the analysis still to be applicable.
I PRL will follow appropriate NRC and U.S. Department of Transportation regulations in
- packaging yellowcake and transporting it offsite. ln addition, PRL will implement
emergency procedures in the event of an accident.I
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ONA6.0 RECLAMATI ND DECOMMISSIONING
PRL submitted a revised detailed site decommissioning and reclamation plan by letter date
January 10, 1997. NRC is reviewing the plan in accordance with the requirements of
1O CFR Part40, Appendix A, and applicable staff guidance documents. PRL will be
required to perform reclamation of the site in accordance with an NBC-approved final
reclamation plan.
The decommissioning of the facility will be conducted under a plan approved by the NRC.
The final plan must be submitted to the NRC for approval at least 12 months pricr to any
planned activity. This requirement will continue to be a license condition in PRL's renewal
license.
7.4 ALTERNATIVES
The action under consideration is the renewal of Source Material License SUA-1371, tor
resumption of mill operations at the Shootaring Canyon uranium mill, as requested by PRL.
The alternatives available to NRC are to:
Renew the license with such conditions as are considered necessary or
appropriate to protect public health and safety and the environment; or
Deny renewal of the license.
Based on its review of the information identified in Section 1.3.2, the NRC staff has
concluded that the environmental impacts associated with the proposed action do not
warrant denial of the license renewal. lt is the staff's conclusion that the impacts
associated with the license renewal are within the realm of impacts anticipated in the FES
(NRC, 1979a) and the previous EA (NRC, 1986a). Additionally, in the SER prepared for
this action, the staff has reviewed the licensee's proposed action with respect to the
criteriafor license issuance specified in 1O CFR Part40, Section40.32, and has no basis
for denial of the proposed action.
8.O FINANCIAL SURETY
Under 1O CFR Part 40, Appendix A, Criterion 9, liuensees are required to establish a
financial surety adequate to cover the estimated costs for (1) decommissioning and
decontamination of the mill and mill site, (2) reclamation of any tailangs or waste disposal
areas, (3) ground water restoration, as warranted, and (41 the long-term surveillance fee.
The surety is based on an estimate which must account for the total costs that would be
incurred if an independent contractor were contracted to perform tire work. The surety
estimate must be approved by NRC and be based on an NRC-approved decommissioning
and reclamation plan. The licensee must also provide the surety arrangement through a
financial instrument acceptable to NRC. The licensee's surety mechanism will be reviewed
by NRC annually to assure that sufficient funds are available to complete reclamation
Additionally, the amount of the surety should be adjusted to recognize any increases or
decreases in liability resulting from inflation, changes in engineering plans, or other
conditions affecting cost.
(1)
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PRL submitted a revised detailed site decommissioning and reclamation plan by letter dated
January 1O, 1997. ln addition to providing in the plan a detailed description of activities
.necessary to complete decornmissioning and reclamation at the site, PRL also estimated
the total cost that an independent contractor hired to perform these activities would incur
to complete the work. PRL estimated this cost to be i6,784,159.
By letter dated Februarv 26, 1997, the NRC staff found this cost estimate tc be adequate
for the purposes of resuming mill operations. PRL supplied documentation, by letter dated
March 14, 1997, that its surety amount for the Shootaring Canyon site was in excess of
$6,784,159. The NRC staff has reviewed the documentation and finds the revised surety
amount to be acceptable.
PRL will be required by license condition to maintain a financial surety arrangement in
accordance with the requirements of Criterion 9. The surety requirements will be reviewed
at least annually by NRC to assure that the funds and the surety arrangement are
acceptable.
9.O CONSULTATION WITH AFFECTED FEDERAL AND STATE AGENCIES
ln the interest of reducing dual regulation and avoiding duplication of reviews, the NRC
and State of Utah DEO staffs agreed in a telephone call on December 3, 1996, that the
DEO would take the lead in the review of PRL's liner design for the tailings impoundment.
This means that the NRC staff would defer to the State on a determination relative to the
liner design, as long as the NRC staff is confident that the State's review is protective of
public health and safety, including radiological hazards. The State of Utah DEO staff is
conducting its review as part of its process for granting a groundwater discharge permit
for the Shootaring Canyon mil! site. The details of PRL's proposed liner design are
summarized in Section 3.2.1.
,
On March 20, 1997, a draft copy of this EA was sent electronically to the State of Utah
DEO and the U.S. National Park Service (NPS) offices in Denver, Colorado, and the Glen
Canyon Nationa! Recreation Area. The State of Utah DEO indicated on March 27, 1997,
that it had no comments on the draft EA. ln a telephone conversation on March 27, 1997,
the NRC staff discussed with NPS representatives the NPS' comments and concerns with
the draft EA.
Concerns raised bythe NPS included: (11the location of thetaalings impoundment in a
drainage (an operational and reclamation concernl; (21 socioeconomic impacts associated
with the development of the planned Ticaboo townsite; (31 the frequency of required
environrnental monitoring sampling; and (41 additional sampling requirements in the areas
of groundwater and wildlife monitoring.
!n response to these concerns, the NRC staff considers the following:
The proposed action isto renew SUA-1371 to authorize the resumption of mill
operations. The environmental impacts associated with sitrng and constructing the
impoundment in its current location were reviewed by the NRC staff in 1979 and -found to be acceptable (NRC, 1979a). The NRC staff is in the process cf reviewing
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PRL's detailed site reclamation plan, and the NPS will have an opportunity to be
involved in this review process.
The socioeconomic impacts associated with the Ticaboo townsite were assessed.in adetail by NRC in 1979 and found to be acceptable (NRC, 1979a). The NRC staff v
still considers that assessment to be valid (see Section 2.6).
The licensee's environmental and effluent monitoring program during operational
periods is in conformance with NRC staff recommendations for such programs at
uranium mills, as is described in Regulatory Guide 4.14. ln addition, with the
exception of stack sampling, PRL will be required to conduct its operational
monitoring program during standby periods also. A site-specific Aroundwater
detection monitoring program was developed between the NRC staff and PRL
during 1984-88 to meet the requirements of Appendix A to 10 CFR Part 40. This
detection monitoring program will continue to be required by license condition in the
renewal license.
With respect to groundwater sampling, llFiC requirements under 1O CFR 40,
Appendix A, require licensees to conduct sampling at the point of compliance (POC)
in the uppermost aquifer. At the Shootarrng Canyon site, PRL has been and will
continue to be required to sample the Entrada aquifer at the designated POC wells
(RM-4, -5, and -6). ln addition, PRL will be ,'equired to conduct regular monitoring
of the impoundment leak detection system and surface water sampling (at seeps)
a's additional groundwater protection measures.
Concerning wildlife monitoring, and specifically use of the tailings impoundment by
wildlife, PRL has agreed to conduct and document a daily visual inspection of the
impoundment to monitor for these purposes (Section 4.5). Based on the results of
this monitoring, appropriate corrective actions can be implemented by the licensee.
1O.O FINDING OF NO SIGNIFICANT IMPACT
PRL has applied to NRC to renew Source Material License SUA-I371 to authorize the
resumption of operations at the Shootaring Canvon uranium mill, located in Garfield
County, Utah. NRC has reexamined actual and potential environmenta! impacts associated
with yellowcake production at the mill site, and has determined that renewal of the source
inaterial license (1) will be consistent with requirements of 1O CFR Part 40, l2l will not be
inimical to the public health and safety, and {3} will not have long-term detrimental impacts
on the environment.
Therefore, based on an evaluation of PRL's renewal request, the NRC staff has determined
that the proper action is'to issue a FONSI in the Federal Register. The following
statements support the FONSI and summarize the conclusions resulting from the staff's
environmental assessment:
An acceptable environmental sampling program will be in place to monitor effluent
releases and to detact if appropriate limits are exceeded;
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I . Standard operating procedures will be in place ior alt operational process activities
involving radioactive materials that are handled, processed, or stored;
I . Mill tailings and process liquid effluents fronr the mill circuit will be discharged to a
lined tailings impoundment, with a leak detection system;
I ^-. o The licensee will implement an intensive, routine inspection program of the millt (' ffi:x""l:H':['J"i'^il,;f:J;i ,;Iri;ild tairinss retention impoundments' and
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I o The licensee will implement an acceptable groundwater detection monitoring
program to ensure compliance with the requirements of 1O CFR Part 4O,
I i:;::; wiu conduct site decommissionins and recramation activities in
I . ;",ffi:::,::;ffi::';:;;.."wi,, benosisnirican,impac,s
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associated with approval of the license renewal, there can be no disproportionately
high and adverse effects or impacts on minority and low-income populations.
Consequently, further evaluation of 'Environmental Justice' concerns, as outlined in
Executive Order 12898 and NRC's Office of Nuclear Material Safety and
Safeguards Policy and Procedures Letter 1-5O, Rev.1, is not warranted.
Based on these findings, the NRC staff recommends that PRL's license for the resumption
of yellowcake production at the Shootaring Canyon uranium mill be renewed. The source
material license shall be based upon the licensee's renewal application, this EA, the SER,
and the license conditions which address environmental issues (see Section 1 1). License
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conditions addressing radiation safety concerns can be found in the SER.
1 1.0 CONCTUSION INCLUDING ENVIRONMENTAL LICENSE CONDITIONS
I Upon completion of the environmentat review of PRL's application for renewal of Source
Materia! License SUA-I371, the NRC staff has ccncluded thatthe operation of the
r Shootaring Canyon uranium mill, in accordance with the following conditions to be
f included in the renewed source material license, is prote.;tive of health, safety, and ther environment, and fulfillsthe requirements of 10 CFR Part 51. Therefore, the NRC staff
recornmends renewal of SUA-1371, subject, in part, to the following conditions:
I 1. The mill production rate shall not exceed 1,OO4,OOO pounds of yellowcake per year.
I 2. A. The licens€e may, without prior NRC approval, and subiect to the conditionsr specified in Part B of this condition:
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(11 Make changes in the facility or process, as presented in the
application.
el Make changes in the procedures presented in the application.
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(3)
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(3) Conduct tests or experiments not presented in the application.
ff J;",,:T;?'H:iH ;J,','"'l'ff :',", :o:"'
a n am e nd m e nt to the I ic e nse' u n ress
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(1) The change, test, or experiment does not conflict with any
requirement specifically stated in this license, or impair the licensee's
ability to meet all applicable NRC regulations.
There is no degradation in the essential safety or environmental
commitments in the license application, or provided by the approved
reclamation plan.
The change, test, or experiment are consistent with the conclusions
of actions analyzed and selected in this EA.
The licensee's determinations concerning Part B of this condition, shall be
made by a "Safety and Environmental Review Panel (SERP)." The SERP
shall consist of a minimum of threa individuals. One member of the SERP
shall have expertise in management and shall be responsible for managerial
and financial approval changes; one member shall have expertise in
operations and/or construction and shall have responsibility for implementing
any operational changes; and, one member shall be the corporate radiation
safety officer (CRSO) or equivalent, with the responsibility of assuring
changes conform to radiation safety and environmental requirements.
Additional members may be included in the SERP as appropriate, to address
technical aspects such as health physics, groundwater hydrology,
surface-water hydrology, specific earth sciences. and other technical
disciplines. Temporary members or permanent members, other than the
three above-specified individuals, may be consultants.
The licensee shall maintain records of any changes made pursuant to this
condition until licenee termination. These records shall include written
safety and environmental evaluations, made by the SERP, that provide the
basis for determining changes are in compliance with the requirements
referred to in Part B of this condition. The licensee shall furnish, in an
annua! report to NRC, a description of such changes, tests, or experiments,
including a summary of the safety and environmental evaluation of each. ln
addition, the licensee shall annually submit to the NRC changed pages to the
Operations Plan and Reclamation Plan of the approved license application to
reflect changes made under this condition.
The licensee shall submit to NRC within 60 days of the issuance date of the
renewal license, for review, the standard operating procedures (SOPsl needed to
implement this license condition. The licensee shall not implement any provision of
this license condition until NRC has found the proposed SOPs acceptable.
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3. Standard operating procedures shall be established and followed for all operational
process activities involving radioactive mc,terials that are handled, processed, or' stored. SOPs for operational activities shall enumerate pertinent radiataon safety
practices to be followed. Additionally, written procedures shall be established for
non-operational activaties to include in-plant and environmental monitoring, bioassay
analyses, and instrument calibrations. An up-to-date copy of each written
procedure shall be kept in the mill area to lvhich it applies.
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All written procedures for both operational and non-operational activities shall be
reviewed and approved in writing by the Environmental and Radiological Health
Supervisor (ERHS) before implementation and whenever a change in procedure is
proposed to ensure that proper radiation protection principles are being applied. ln
addition, the ERHS shall perform a documented review of all existing operating
procedures at least annually.
r 4. The licensee shall notify NRC and the State Historical Preservation Officer
f immediately if artifacts are discovered during disturbance of the mill or tailingsr disposal areas and shall perform an archaeological survey of previously unsurveyed
areas prior to their disturbance.
I 5. The licensee is hereby authorazed to possess byproduct material in the form of
uranium waste tailings and other uranium byproduct waste generated by the
licensee's milling operations authorized by this license. Mill tailings shall not be
transferred from the site without specific prior approval of NRC in the form of a
license amendment. The licensee shall maintain a permanent record of all transfers
made under the provisions of this condition.
6. All liquid effluents from mill process buildings, with the exception of sanitary
wastes, shall be returned to the mill circuit or discharged to the tailings
impoundment.
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r 7. Tlre licensee is not authorized to commence mil! operations until a final tailings
I impoundment liner design has been approved by NRC and the approved liner
installed in the impoundment.
I 8. The licensee shall maintain an NRC-approved financial surety arrangement,r consistent with 1O CFR 40, Appendix A, Criteria 9 and 10, adequate to cover the
estimated costs, if accomplished by a third party, for decommissioning and
I decontaminataon of the mill and mill site, for reclamation of any tailingl or waster disposal areas, ground-water restoration as warranted and for the long-term
surveillance fee. Within three months of NRC approval of a revised
I reclamation/decommissioning plan, the licensee shall submit, for NRC review andI approval, a proposed revision to the financial surety arrangement if estimated costs
in the newly approved plan exceed the amount covered in the existing financial
I iilr}r",lne revised surety shall then be in effect within 3 months of written NRC
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A.
B.
A.
9.
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Annual updates to the surety amount, required by 1O CFR 40, Appendix A, Criteria
9 and 10, shall be submitted to NRC at least 3 months prior to the anniversary of
the effective date of the approve..l surety arrangement. lf NRC has not approved a
proposed revision to the surety coverage 3O days prior to the expiration date of the
existing surety arrangement, the licensee shall extend the existing surety
arrangement for 1 year. Along with each proposed revision or annual update, the
licensee shall submit supporting docu--ntation showing a breakdown of the costs
and the basis for the cost estimates with adjustments for inflation, maintenance of
a minimum 15 percent contingency lee, changes in engineering plans, activities
performed and any other conditions affecting estimated costs for site closure. The
basis for the cost estimate is the NRC-approved reclamation/decommissioning plan
or NRC-approved revisions to the plan. The previously provided guidance entitled
"Recommended Outline for Site Specific Reclamation and Stabilization Cost
Estimates" outlines the minimum considerations used by NRC in the review of site
closure estimates. Reclamation/decommissioning plans and annual updates should
follow this outline.
The currently approved financial surety arrdngement, a Surety Trust Agreement
bitween Plateau Resources Limited and First lnterstate Bank of Commerce, shall be
continuously maintained in an amount no iess than $6,784,159 for the purpose of
complying with 1O CFR 4O, Appendix A, Criterra 9 and 1O, until a replacement is
authorized by the NRC.
Notwithstanding the decommissioning plan in the renewal application, the licensee
shall submit a detailed decommissioning plan to NRC at least twelve 112l months
prior to planned final shutdown of mill operations.
The licensee shall not expand the tailings impoundment area by raising the height of
the dam above its present elevation or by constructing any additional dams without
prior NRC approval in the form of a license amendment.
The licensee shall comply with the following regarding the operation of the tailings
disposal system:
A detailed embankment instrumentation program shall be submitted for NRC
approval at least 3 months prior to placing tailings effluent against the
current dam or raising the current dam above its present height.
A minimum of 13 feet of freeboard shall be maintained between the top of
the current dam and the tailings pond level.
The licensee shall implement a groundwater detection monitoring program to ensure
compliance with 10 CFR 4O, Appendix A, which includes the following:
The licensee shall sample monitoring wells RM-4, RM-s and RM-6, on a
semiannual basis, with samples taken at least 4 months apart. The samples
shall be analyzed for arsenic, chloride, selsnium, U-nat, and pH.
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10.
12.
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r 13. The licensee shall conduct environmental and effluent monitoring described in Table
I 5.5.7 of the license renewa! application, with the following modifications:
B. The licensee shall compare the analysis results against the followi,rg
threshold values: arsenic = O.O22 ''ng/|, chloride = 40 mg/|, selenium :
O.O22 mg/l and pH = 6.8 standard units or less. lf the threshold values
are exceeded, the licensee shall ;r'opose, within 6O days of a measured
exceedance, an expanded detection monitoring program to define the extent
and concentration of hazardous constituents in the uppermost aquifer.
C. The licensee shall submit the data arrd comparison results required under
subsections A and B, respectively, with the semiannual reports required
under 1O CFR 40.65.
D. The licensee shall report at least annually in accordance with the reporting
requirements specified in subsection C, the rate and direction of
groundwater flow under the tailings impoundment.
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A. During periods of standby, stack sampling is not required.
B. The flow rate from the yellowcake dryer and packaging stack shall be
measured quarterly at the time stack sampling is conducted.
C. Soil samples shall be analyzed for U-nat, Th-23O, and Ra-226.
D. A daily visual inspection of the tailings impoundment area shall be conducted
to monitor for use of the impoundment by wildlife and the results
documented.
I This ticense condition shall take effect with the commencement of ore processing
through the mill.
I 14' :ffi::;:'$':11'":1,:liJ'??*i1,",ffi1""h:^:lo"ilil:ffi;sifi:1lTl;":"lli:?:*t :ffi1'#,T,?5*"S ff:H:,?"'::?::i:'"*:"i,'J,ffH:"i#1,'";;:l'; fi'""';::ffi,
construction and operation of the berms and dam, with a copy of the evaluation
I iT:T"H'#:ffi:i,llr"YilliH:""fi:ff:llili,I::Ti::3il.T:.:':.1[".:lt;,*
evaluation reports shall be retained onsite.
I 1 5' ]["T::H:',J.l;'.*"":l,t],"#t'J[:T:iL
pfosram of the tairinss disposa! svstem in
I 16. The wet foam and sprinkler fire suppression systems must be fully functional priorI to the introduction of kerosene into the miil circuit and the resumption of mill
operations.
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REFEBENCES
Plateau Resources Limited, 1997, "Shootaring Canyen Uranium Processing Facility,
Decommissioning and Reclamation Plan," 1 vol. and 5 appendices, dated December 18,
1996, submitted by letter dated January 10, 1997.
Plateau Resources Limited, 1996 "Shootaring Canyon Processing Facility, Garfield
County, Utah: Source Material License Renewal Application SUA-1371, DOCKET r{O.
40-8698," 1 vol., March 1, 1996.
Bernreuter, D., etal., 1994, "Seismic Hazard Analysis of Title ll Reclamation Plans,"
prepared under contract for the NRC by Lawrence Livermore National Laboratory, June
1 994.
ICF Kaiser Engineers, 1992, "Environmental Liabilities at the Shootaring Canyon Uranium
Millsite," report extract as Appendix D, "Tailings lmpoundment Study," to Plateau
Resource Limited's March 1, 1996 amended license renewa! application.
U.S. National Park Service [NPS], 1997a, "Glen Canyon National Recreation Area Visitor
Use Summary - December 1996," summary table received via facsimile on March 20,
1 997.
NPS, 1997b, personal communication between J. Park, NRC Project Manager, and
I fi;,o#e;Bli |,#.
Superintendent's office - Glen canyon National Recreation Area, on
U.S. Nuclear Regulatory Commission [NRCJ, 1986a, "United States Nuclear Regulatory
Commission Environmental Assessment Prepared by the Uranium Recovery Field Office in
Consideration of the Renewal of Source Material License SUA-1371 tor Plateau Resources
Limited Shootaring Canyon Processing Facility," issued February 3, 1986.
NRC, 1986b, "Safety Evaluation Report for License Renewal SUA-I371, Docket No.
40-8698, Platea.r Resources Limi::d Shootaring Canyon Processing Facility," issued
February 3, 1986.
NRC, 1983, "Hydrologic Design Criteria For Tailings Retention System," NRC Staff
Technical Position WM-82O1, January 1983.
NRC, 198Oa, "Operational lnspection and Surveillance of Embankment Retention Systems
for Uranium Mill Tailings," NRC Regulatory Guide 3.11.1, October 198O.
NRC, 198Ob, "Radiological Effluent and Environmental Monitoring at Uranium Mills," NRC
Regulatory Guide 4.14, April 198O.
NRC, 1979a, "Final Environmental Statement: F(elated to Operation of Shootering Canyon
Uranium Project, Plateau Resources, Ltd.," NUREG-0583, Office of Nuclear Material Safe.:'
and Safeguards, July 1979.
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NBC, 1979b, "Quality Assurance for Radiological Monitoring Programs (Normal
Operations) - Effluent Streams and the Environrne,rt," NRC Regulatory Guide 4.15,
'February 1979.
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I NRC, 1 977, "Design, Construction and lnspection of Embankment Retention Systems for
Uranium Mills," NRC Regulatory Guide 3.11, December 1977.
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Enclosurg--2
Federal Registqr Notice:
Finding of No Significant lmpact
Notice of Opportunity tor Hearing
162 FR 22977; April 28, 1997)
I Federal *";" / Vol. 62, No. 8l / Monday, April )rnn, / Notices 22977
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For the Nuclear Regulatory Commission .
Rol.ait G. Schaaf,
Project Manager, Project Direetorate III-1,
Divisian of Reactor Projects-III/IV, Office of
Nualear Reactor Regu lat ion.
[FR Doc. 97-1086a Filed 4-Zs-97; B:45 aml
BILUilG CODE 759trO1-P
NUCLEAR REGULATORY
coMiflssloN
[Docket No. 40-86981
PlatEau Resources Limited
AGENCY: Nuclear Regulatory
Commission.
ACTION: Final finding of no significant
impact notice of opportunity for
hedring.
SUilIilARY: Tho IJ.S. Nuclear Regulatory
Commission (NRC) proposes to renew
NFC Source Material Licens. -'A-1371tu authorize the licensee, Plateau
Resources Limited (PRL), to resume
commercial milling operations at the
Shootaring Canyon trranium mill,
located near Ticaboo, Utah. An
Enrrironmental Assessment was
performed by the NRC staff in
accordance with the requircments of 10
CFR Part 51. The conclusion of the
Environmental Assessment is a Finding
of No Signifrcant Impact (FONSI) for the
proposed licensing action.
FOR FUR|rHER INFORMANOil @T{TACT! Mr.
fames R. Park, Uranium Recovery
Brarrch, Mail Stop TWFN T4g,Division
of Waste Management, OfEce of Nuclear
Material Safety and Safeguards, lJ.S.
Nuclear Regulatory Cornnission,
Washington; DC 20555. Telephone SO1'l
415-O699,
$, PPLEU ETTTTARY I}IFORTATIO}I :
Background
Sourcp Materid License SUA-1371
waa origrnally issued by NRC on
September 21, 1979, ptrrsuant to Titte
10, Code of Federal Regulations (10
Ctr'R). Paft 40, "Domestic Licensing of
Source Matorial." This licenso currently
authorlzes PRt to possess blryroduct
materiel in thc ibrm of nranium wastd
tailings and otter bnroduct wastes
which woro generated by its uraoium. nocovery operations previously
authorizad,under SUA-I 377.' Under the
crurent Ucense, PRL is not authorized to- produce rrranirrrn concentrates. The
tailings and wastes refened to above
wero generated during the thmo months
in 1982 in which the miil vvas operated;
the mill has been on standby status
sirce that time. SUA-1371was runewed
^f. for "possession only" status in 1986.
1,3[mnti5 "fi ffii:$16, PRL
requested authorization to resume
operations at the Shor-,raring Canyon
mill.
Summary of the Environmental
Assessment
The NRC staff performed an appraisal
of the environmental impacts associated
with the resumption of c'peration:j at the
Shootaring Canyon mill, in accordance
with 10 CFR Part 51, Licensing and
Regulatory Policy Procedures fcr
Environmental Frotection. In
conducting its appraisal, the NRC staff
considered the following: (1)
Information contained in previous
environmental evaluations of the
Shootaring Canyon proiect; (Z)
information contained in PRL's license
renewal application; (3) information
contained in PRL's Iicense amendment
Dequests submitted subsequent to its
renewal application, and NRC staff
approvals of sLuh requests; (a) land use
and environmental monitoring reports;
and (S) informetion derived from NRC
staff site visits and inspections of the
Shootaring Canyon mill site and from
communications with PRL, the State of
Utah Department of Environmental
Quality (DEQ), and the National Park
Service. The results of the staffs
appraisal are documented in an
Environmental Assessment. The
radiation safety aspects for tho
rlesumption of operations at the mill are
discussed in a Safety Evaluation Report.
The license renetJat would autho'rize
PRt to resume operating the Shootaring
Canyon mill, at a maximum production
rate of r,004,000 pounds of yellowcake
per year, and to possess blryroduct
material in the form of rrranium waste
tailings and other urnrliun byproduct
wastes generated by the miUing
operations authoriz.ed by the renewal
license. The actual resumption of
operations will be conditional on (r)
The approval of a frnal design for the
tailings impoundment liner by NRC and
the Utah DEQ and tha installation of
that liner, (2) PRt's submittal of a
technical evaluation of the existing
cnoss-valley berm and tailtngs dnm, and
(3) NRC's confirmation during a ptt-
operational site iDspection that standad
operating procdures for operational '
and non-operational activities are in
place.' AII conditions in the renewal license
and commitments presented in the
licensee's license renewal application
are subiect to NRC inspection. Violation
of the license may rcsult in enforcement
action.
C-onclusions
The NRC ctaff has reoxamined actual
and potential environmental impacts
associated with a resumption of
yellowcake production at the mill site,
and has determined that renewal of the
source material license (f ) Will be
consistent with r';quirements of 10 CFR
Part 40, (2) will not be inimical to the
public health and safety, and (3) will
not have long-term detrimental impacts
on the environn rnt. The following
staternc.nts support the F. -NSI and
suirrrnd rize the conclusions resulting
from the staffs environmental
assessment:
1. An acceptable environmental
sampling program will be in place to
monitor effluent releases and to detrct
if appropriate limits 2re exceeded;
2: The licensee wrll implement an
intensive, Doutine inspection program of
the mill process building, associated
facilities, and tailings retention
impoundments, and conduct an annual" low as :s reasonable achievable"
(ALARA) audit program;
3. Standard operating procedures will
be in place for all operational process
activities involving radioactive
materials that are handled, processed, or
stored;
4. Mill tailings and process liquid
effluents from the mill circuit will be
discharyed to a multi-lined tailings
irnponndment, with a leak detection
system;
5. The licensee will implement an
acceptable groundwater detection
monitoring prograrn to enstrre
complianoo with the requirements of 1O
CFR Part 4O, Appendix A;
6. The licensbi witt conduct site
decommissioning and reclamation
activities in accordance with NRC-
approved plans; and- 7. Because ths staff has determined
that there will be no significant impacts
associated with approval of the license
renewal, lhene can-be no
disproportionately high and adverse
efredc ^ impasts on minority and low-
income populations. Consequently,
further evaluation of 'Euvironmental
fustice' concerxs, 8s outlined in
ExecuEvr Order 12898 and NRC's Office
of Nuclear Material Safety and
Safeguards Policy and Procedunes Letter
1-5O, Rev,l, ls not warranted.
Alteraativeg to the Proposed Action
fre propossd action is to renew NRC
Sotrrco Material Licenso SUA-I371, forI nesumpUon of operations at the
Sl^rrutaring Canyon mill, as rsquested by
PRL. Thereforrs, the principal
alternatives available to NRC are to:(f ) Renew the licer^se with such
conditions as aro considerpd necessary
or appropriate to protect public health
and safety and the envirunrnent; or(2) Deny renewal of tho license.
22978 Federal *rrrt, vot. oz,Nc. 81 / Monday, april zalT / Notices
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Based on its review, the NRC staff has
oncluded that there are no significarrt'bnvironmental impacts associated with
the proposed action; therefore, any
plternatives *ith equal or greater_
environmental impacts need not be
bvaluated. Since ti" "nrrironrnentallmpacts of the proposed action and the
no-action alternative (i.e., denial ol the
renewal) are similar, there is no need to
fur&er evaluate altenratives to the
proposed action.
pi"ai"g of No Sigeificant hnpact
I Th, NRC staff has prepared an
vironmental Assessment for the
posed renewal of NRC Source
terial License SUA-7377. On the
of this assessment, the NRC staff
concluded that the environmental
mpacts that may result from the
posed action would not be
frcant, and thereforB, pmparation of
Environrnentrl hpact Statement is
of warranted.
The Environmental Assessment and
documents related to this
posed action aDB available for public
on and copying at the NRC
blic Document Room, in the Celman
lding, 21.20 L Street NW.,
ashington, DC 20555.
of Opportunity hr Hearing
The Commission hereby provides
that this is a proceeding on an
plication for a licensing action falling
thin the scop€ of Subpart L, "Informal
hocedures for Adiudications in
and Operator Licensing
res." of the Commission's
iRul* of hactice for Domestic Licensirg
I@ in 10 CFRPail 2 (s4 FR
8269). Pursur nt to S 2.12O5(a), any
person whose interust may be affected
by thts proceeding may ftle a r€quest for
a hearing. ln accordnnoa with
(2) The NRC staff, by delivery to the
Executive Director of operations, one
White Flint North, 11i55 Rockville
Pike, Rockville, MD 20852, or by mail
addressed to the Executive Director for
Operations, LJ.S. Nuclear Regulatory
Commission, Washington, DC 20555.
In addiiion to meeting other
applicable requirements of 10 CFR Part
2 of, the Commissiori's regulrtions, a
request for a hearing fileu by a person
other than an applicant must describe in
detail:
(1) The interest of the requestor in the
proceeding;- (2) How thst interest may be affected
by the results of the pioceedirrg,
including &e reasons why &e r"questor
should be permitted a hearing, with
particular reference to the factors set out
in S 2.1205(d;
(3) the requestor's aneas of conceur
about the licensing activity that is ihe
subject matter of the proceeding; and
(a) The circumstances establishing
that the request for a hearing is timely
in accordance with S 2.1205(c).Any hearing that is requested and
granted will be held in accordance with
the Commission's "Informal Hearing
Procedures for Adjudications in
Materials and Operator Licensing
Proceedings" in 10 CFR Part 2,
Subpart L.
Dated at Rockville, Maryland, this 21st day
of April 1997.
For the Nuclear Regulatory C.ornnission.
C.herlce L. Caitr,
Acti ng Ch ief , Umnium Recovery Bronch,
Division of Woste Monagement, ffice of
Nuclear Material, Sofety znd Safquards.
lfn Ooc. 97-1OSsz Filed 4-2y97; 8:45 aml
BlLrsB co* 7t*ot-P
OFFTCEOF MANAGEMENT AND
BUDGET
Opdons for Promodng Prlvecy on ttc
NaUonal Intonna[on hlrartucttrt
AOEIICV: Office of lvlanagement and
Budget.
AgnOil: Notice and r€quest for
coulments.
SUIIABV3 OMB nnnounoss the
availability of "Options for Promoting
Privacy on the National Informatiou
tnfrastructurc" (Options Paper) on
bohalf of the fnformation P6Ucy
Cor'rmittee of the Natioual Informatlon
Infrastmcturp Task Forte (IITF). This
Options Paper rwults from work
performed by the Privacy Working
Group and refined by the C.omr'rittee.
The Co'nr"ittee is cbqimd by the
Admhistrator of tlre Offico of
Informe tion and Regulatory Affairf ,
Office of Management and Budget
(OMB). This Options Paper builds upon
the October 1995 report of the Privacy
Working Group, "Privacy and the
National lnformation lnfrastructure :
Principles for Providing and Using
Personal Information " (Privacy
Principles), which was published in
draft form in the Federal Register on
fanuary 20, 1995 (60 FR 4362) and was
Enalized in Iune 1995. None ol the
options pFesented has been adopted as
Administratiorr polic!; they are set forth
in this document in the belief that thry
are worthy of public discussion.
DATES: Comments should be submitted
no later than Iune 27, 1997.
ELECTBONIC AYAIT.AEIUW A}ID ADOBESSES:
The options paper is available
electronically from the IITF site on the
World Wide Web: http://
www. iitf. nist.gov/ipc/ipc-pub. html and
in paper form from the OMB
Publications Offrce, 725 17th Street,
I\nlI., Washington, DC 20503, telephone:
2OZ I 3gF7 332, facsim ile: 2O2lS gS-6 137 .
Comments may be sent to the
Information Policy Committee c/o the
Office of Information and Regulatory
Affairs, Offrce of Management and
Budget, Room 10236, Washington, DC
20503. Comments may also be
zubmitted by facsimile to 202-395-
5167, or by electronic mail to
B ERN STEIN_M@A 1 . EOP. GOV.
Comments submitted by facsimile or
electronic mail need not also be
submitted by regulu mail.
FOR FURTTIER NFORTATIOTI COIiITACT: Ms.
Maya A. Bernstein, Office of
Information and Rsgulatory Aflairs .
OfEce of Managiement and Budget ,
Washington, DC 20503. Voice
telephon e: 2O2-395;4816, Facsimile:
202-395-51 67. Electr',onic mail:BERNW1.EOP.GOV.
St PPLETEilTARV lltFOil TrOll: h the
Report of the Natlonal Perfonmance
Revlew, "CruatiDg a C'overoment that
Worls Better & C,cts [ass:
Reengtnooring through Infomation
Tochology," the Vice Plesident tasked
the Inforuation ffiTask
Force with coneidering privac,y policy
with respect to the National Information
Infrastruchrs (I{U}. The Privary
Working Grcup first developrd "Privacy
and the National Information
tnfrastructuF: Principlea for Providing
and Ueing Persond Infomation" (the
Privacy Principles), which described a
set of fair inforuation pr:acticos
appropriate to the Ntr andwhich were
frnalized in Iune 1995. the next step for
the Privacy Working Group was to
consider how best to promote those
principles. To thgt end, the Working
Gmrrp undertmk eignificant rusearch on
i fapnCr UoUoB. -I-DO r€qrle8t lor a
r hearing aust be filed with the OEcc of
Ez,t.zos(cl. a request for a hearing must
be filod withiq thirty (^0) daye from the
date of publication of this Fcdcral
; the Socrotary eithen: (1) By defivery to the t]ocketing and
- Sorvice Branch of the OtEce of the
Socrotar!, at One White FUnt North,
11555 Rockville PiLe, Roc!ryille, MD
2O852; or
(2) By mail or telegram addressod to
the Secretary, IJ.S. Nuclear Regrlatory
Cornnisslon, WEshington, DC 20555,
Attention: Docketing and Service
Branch.
Each request foi a headng must also
be senred, by delivering it personall3' or
bv mail to:-(r) Tte applicant, Plateeu Resources
Limited. Sz? North 8th Wegt, Riverton,
Wyomtng 82501;
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:o ?zos1so41,* ?zeEa?PbR- -ADtlcK o4ooE8?8C- PDE
Enclosure 3
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Safety Evaluation Report
for Renewal of
Source Material License No. SUA-137 1
Plateau Resources Limited
Shootaring Canyon Uranium Mill
Garfield County, Utah
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I SAFETY EVALUATION REPORTI FOR RENEWAL OF
I
souRcE MATERIAL LTCENSE NO. SUA-L37!
PLATEAU RESOI]RCES LIMITED
r SHooTARTNG CANYON T RANIUM rVr[LT GARFIELD COI.'NTY, UTAH
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IO MAY 1997
DOCKET NO. 40-g69g
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[r.S. Nuclear Regulatory Commission
Office of Nuclear Material Safety
and Safeguards
Division of Waste Management
l'
I;TABLE OF COI,ITENTS
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2.O AUTHORIZED ACTIVITIES
Description of Proposed Action 2
Backgre'':d lnformation 2
Review Scope 3
Organi;.tion 6
Radiation Safety Staff and Responsibilities 6
Minimum Technical Oualifications for the Radiation Safety Staff . . . . . . . I
3.3.1 Environmental and Radiological HealthSupervisor . .. ... I
3.3.2 Radiation Safety Staff . 8
Administrative and Operating Procedures I
lnspections and Audits 10
3.5.1 lnspections... 10
3.5.2 ALARA Audit 10
Radiation Safety Training 11
4,O RADIATION SAFETY CONTROLS AND MONITORING 12
1.0 INTRODUCTION
1.1
1,2
1,3
2.1
2.2
3.1
3,2
3.3
3.4
3.5
3.6
4.1
4.2
4.3
4.4
4.5
4.6
4.7
FacilityDescription... ......3Operations 3
3.0 FACILITY ORGANIZATION AND ADMINISTRATIVE PROCEDURES . . . . . . 6
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Ventilation and Effluent Control 12
ln-Plant Monitoring Data 13
Personnel Monitoring Data 13
External Radiation Control Program
4.4.1 Occupational Exposure
4.4.2 External Radiation Surveys
lnternal RadiationControl Program .....;
4.5.1 Airborne Radioactivity Surveys . .
4.5.2 lnternal Exposure to Radioactivity
4.5.3 Respiratory Protection Program
Bioassay
Contamination Control
4.7.1 Personnel Contamination .
4.7.2 Surface Contamination
4.7.3 Disposal of Contaminated Equipment
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4.8 Ouality Assurance and Calibration 18
5.O RESTRICTED AREA MARKINGS AND ACCESS CONTROL 18
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TABLE OF CONTENTS
(continued)
6.0 EMERGENCY PROCEDURES AND PREVENTATIVE MEASURES
OPage
19
7.O GROUNDWATER PROTECTION aat r t t ataf ! a aalaa! laa tla araaaa lla t
AND RECLAMATION .,. . ! ., . ., . . . . o . .8.O MILL SITE DECOMMISSIONING
9.0 SURETY REOUIREMENTS 20
1O.O INSPECTION HISTORY 21
11.0 CONCLUSION INCLUDING SAFETY LICENSE CONDITIONS 23
REFERENCES 26
LIST OF TABLES
Page
TABLE 10.1 Summary of NRC lnspections at Plateau Besources Limited's
Shootaring Canyon Uranium Mill 21
LIST OF FIGURES
Location of the Shootaring Canyon Uranium Mill
Shootaring Canyon Uranium Mill, Generalized Process Flow Sheet . . . . .
Shootaring Canyon Uranium Mill, Organizational Chart
19
20
Figure 2.1
Figure 2.2
Figure 3.1
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1.0 INTRODUCTION
By application dated March 1, 1996, and supplements and revisions transmitted by letters
dated September 16 and November 15, 1996, and April 17, 1997, Plateau Resources
Limited (PRL) requested renewal of U.S. Nuclear Regulatory Commission Source Material
License SUA-1 371, for the resumption of milling activities at the Shootaring Canyon
Uranium Project, which is located in Garfield Countv, Utah.
With this license renewal, NRC will be authorizing the resumption of mill operations under
the Performance-Based License Condition (PBLC) format. Under Performance-Based
Licensing, the licensee has the burden of ensuring the proper implementation of the PBLC.
The licensee may:
Make changes in the facility or process, as presented in the application,
Make changes in the procedures presented in the application, or
Conduct tests or experiments not presented in the application, without prior
NRC approval, if the licensee ensures that the following conditions are met:
The change, test, or experiment does not conflict with any
requirement specifically stated in the license (excluding material
referenced in the Performance-Based License Condition), or impair the
licensee's ability to meet all applicable NRC regulations.
There is no degradation in the essential safety or environmental
commitments in the license application, or provided by the approved
reclamation plan.
The change, test, or experiment is consistent with NRC's conclusions
regarding actions analyzed and selected in the Environmental
Assessment (EAl.
Otherwise, the licensee is required to submit an application for a license amendment from
NRC. The licensee's determinations whether the above eonditions are satisfied will by
made by a Safety and Environmental Review Panel (SERP).
The SERP will consist of a minimum of three individuals. One member of the SERP will
have expertise in management and wil! be responsible for managerial and financial approval
changes; one member will have expertise in operations andior construction and will have
expertise in implementataon of any changes; and one member will be the corporate
radiation safety officer or equivalent. Additional members may be included in the SERP as
appropriate, to address technical aspects in several areas, such as health physics, surface
water hydrology, specific earth sciences, and others. Temporary members, or permanent
members other than the three identified above, may be consultants.
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The licensee will maintain records until license terminati:n of any changes made pursuant
to the PBLC. These records will include written safety and environmental evaluations,
made by the SERP, that provide the basis for determining that the change complies with
the requirements referred to in the above conditions. The licensee will furnish an annual
report to NRC that describes such changes, tests, or experiments, including a summary of
the safety and environmental evaluation of each. ln addition, the licensee will annually
submit any pages of its license application that have been revised to reflect chanoes made
under this condition.
PRL has not yet submitted its standard operating procedures (SOPs) for operation of the
SERP. Therefore, NRC will require, by license condition, that PRL submit the SOPs for
NRC review within 6O days of the date the renewal license is issued, and until such time
as NRC approves the SOPs, PRL will not be authorized to implement the PBLC. PRL
agreed to this license condition by telephone on March 31, 1997.
NRC's inspection function remains unchanged with the administration of Performance-
Based Licensing. Operational changes, regulatory commitments, and recordkeeping
requirements implemented by PRL through the PBLC are subject to NRC inspection and
possible enforcement actions.
1 .1 Descriotion of Prooosed ActioE
The proposed action is to issue a renewal of the subject license for operation of the
Shootaring Canyon facility at a maximum production rate of 455,4O7 kilograms
(1,OO4,OOO pounds) of yellowcake per calendar year. Additionally, PRL will be authorized,
by license condition, to possess byproduct material in the form of uranium waste tailings
and other uranium byproduct waste generated by its milling operations authorized by the
renewal license.
1 .2 Backqro.Und lnformation
Source Materia! License No. SUA-1?71 was issued to PRL on September 21, 1979. This
license authorized PRL to produce, possess, and transfer uranium at its Shootaring Canyon
mill located in Garfield County, Utah. The mill was constructed between 1978 and 1981,
and operated for approximately three months in 1982, before PRL suspended operations in
August 1982 due to the continued decline in the market price for yellowcake. SUA-1371
was renewed on February 3, 1986, for "possession only" status; the NRC staff prepared a
supplemental EA and Safety Evaluation Report (SER) at that time to document its review.
SUA-i371 was due to expire on December 31, 1993. By letter and attachments dated
November 29, 1993, PRL applied for renewal of SUA-I371 for continuation of a
"possession only" status, and was notified in return by the NRC staff that the license was
in timely renewal by letter dated January 11, 1994.
By submittal dated March 1, 1996, PRL amended its November 1993 renewal application
to request a resumption of milling operations at the Shootaring Canyon site.
O
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- PRL's proposed programs were evaluated also against NRC regulations, as specified in
I 10 CFR Parts 20 and 40, and appropriate NRC staff guidance.
l j "- i=. =.- S:::=
r The safety review of PRL's request for license renewal included evaluations of (llthe
I amended renewal application dated March 1, 1996; (2) supplementary informationIsubmitted by letters dated September 16, and Novenrber 15, 1996, and April 17,1997;
r (3) the compliance history for the Shootaring Ca:ryon mill since February 1986; and (4) the
I monitoring data reqr'' -d under SUA-1371.
2.O AUTHORIZED ACTIVITIES
t Currently, PRL is authorized for possession-only of byproduct.material in the form of
uranium waste tailings and other byproduct wastes generated by PRL's uranium recovery
I operations in 1982, as previously authorized under SUA-I371. In addition, PRL is notf authorized to produutr uranium concentrates without NRC approval.
f 2J Facilitv DescriotionI
The Shootaring Canyon mill site is located in Garfield County, Utah, approximately
I 22kilometers (km) (14 miles) north of Bullfrog Basin Marina and about 8O km (48 miles)
I south of Hanksvilte, Utah (see Figure 2.1). Maior mill features include the main mill
IO
building, the tailings impoundment, an ore stockpile area, and a small laboratory building.
Most of the uranium ore processing occurs in the main mill building, which contains a
semi-autogenous grinding (SAGI mill, an acid leach circuit, the solvent extraction circuit,
and the yellowcake precipitation circuit and packaging enclosure. A counter current
r decantation (CCDI circuit is located immediately outside the mill building. A reproduction
I of the generalized flow chart of the uranium milling process at the site is included asr Figure 2.2.
I The mill buildings and the tailings impoundment together occupy approximately 40r hectares (ha) (1OO acres), with the 28-ha (7O-acrel impoundment located in a natural
depression to the southwest of the mill. A 18-meter (6O-foot) high dam is located at the
I downstream edge ol the impoundment and a 9-m (30-ft) high cross-valley berm wasI constructed approximately 610 m (2OOO ft) upstream of the dam. Currently, only that
portion of the impoundment upstream of the cross-valley berm is lined, with a 0.6 m (2 ft)
I thick clay layer.
2.2 Ooerations
I Operations at the Shootaring Canyon milt begin with the weighing, sampling and
stockpiling of ore received from various mines. Mine ore, as well as stockpiled and
I crushed ore, is then fed to the SAG mill. The ground ore is stored as a wet slurry in two
I mechanically-agitated storage tanks. The subsequent processing rnvolves two-stage acid
leaching, followed by the recovery of uranium-bearing pregnant solution in the CCD
!O
svstem. Tailinss are slurried bv pipeline to the impoundment.
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h9?t6ull'o5-)COLORADO.;
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ZoN,-&
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c!Joot.I.a
C-a>r:= )e2-
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,5,a ,J
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Figure 2.1 Location of the Shootaring Canyon Uranium Mill (PRL, 1997)
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Ore Stockpiles
Atmosphere
Crushing and
Grinding Circuit Dust Collection
Organic
Pregnant Leach
Solutiona7
Solvent
Extraction1st Stage
Leach
Banen
Organic
Thickening Stripping
H2S04
NaClO3 Pregnant
Strip
2nd Stage
Leach
NH3 Precipitation
and
Thickenlng
-1
ccD
Washing
Circuit
Banen
Leach l
\tmosphere
Drying
!
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Tailings lmpoundment Wet Scrubbing
Yellowcake
Product
Pregnant
Organic
Barren
Strip
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I Figure 2.2 Shootaring Canyon Uranium Milt, Generalized Process Ftow Diagram
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Then, the uranium is recovered from the pregnant solution through a conventional solvent
extraction system. Following precipitation, washing, dewatering, and drying, the
yellowcake product is packaged in 5S-gallon drums for eventual shipment to a conversion
facility.
3.0 FACITITY ORGANIZATION AND ADMINISTBATIVE PROCEDURES
3.1 Orqanizaticn
PRL, the operator of the Shootaring Canyon mill, has its corporate headquarters located in
Riverton, Wyoming. The corporate office supplies any necessary support to the mill staff.
Milling operations are managed from an office located at the site. PRL's organizational
chart is provided as Figure 3.1.
The Vice President of Milling, who is located at the corporate offices, has the responsibility
for the overall policy and management of the mill. The Director of Regulatory Affairs is
responsible for all licensing and permitting of the mill and for the submission of surety
bonds and license amendment applications to NRC.
The Mill Superintendent, as the on-site authority, is responsible for enforcing the corporate
policies and for mill management. All departments within the facility report to the Mill
Superintendent.
The Environmental and Radiological Health Supervisor (ERHS) serves as the Radiation
Safety Officer (RSO) for the mill site. As such, this individual is responsible for
implementing all radiological and environmental monitoring procedures and for compliance
with the NRC's regulation and requirements, as well as those of the Mine Safety and
Health Administration (MSHA).
The NRC staff finds this organizational structure acceptable.
3.2 Radiation Safetv Staff ancl Resoonsibilities
As stated above, the ERHS is responsible for implementing all radiological and
environmental monitoring procedures and for compliance with NRC's and MSHA's
regulations and requirements. Therefore, the EBHS's responsibilities encompass radiation
safety, industrial safety, occupational monitoring, quality assurance, and environmental
monitoring programs. This individual also prepares and modifies mill procedures and
assists the Director of Regulatory Aflairs in licensing activities. The ERHS has the
authority to partially or fully suspend mill operations that could be hazardous to workers,
and is authorized to escalate concerns to the Vice President of Milling.
The Radiation Technician (BT) is responsible for performing radiation monitoring
measurement throughout the mill area. This individual provides all necessary
recordkeeping, survey data accumulation and analysis, instrument performance
calibrations, and quality control requirements. Although the RT reports directly to the
ERHS, this individual has the authority to escalate concerns directly to the Vice President
of Milling.
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Organizational Chart
Mce President
Milling
IO Environmental
& Safety
Technician
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@-nslshift i
Foreman
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1 Houriy iI Force I
Chief Operating Officer
Co rpo rate Heado uarters
Director
of Regula+ory
Affairs
Envirootne;,ttal &
Radiologicr,l
Health
Supervisor
(ERHS) (Rso)
Accountant
lVletallurgical
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Figure 3.1 Shootaring Canyon Uranium Mil!, Organizational Chart (PRL, r996)
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The Environmental and Safety Technician (EST) conducts the sanrpling and inspections
required under the environmental monitoring program. This individual's responsibilities
include mill emission sources, solid and liquid waste disposal systems, and off-site
environmental concerns. ln addition, the EST is responsible for providing respirators and
protective clothing to the mill workers.
The NRC staff finds the organization of the raoration safety staff to be acceptable.
3.3 Minimum Technical Oualifications for the Radiation Safetv Staff
PRL will require the following minimum qualifications of radiation protection personnel
associated with uranium processing at the Shootaring Canyon mill:
3.3.1 Environmental and Radiological Health Supervisor
PRL states that the ERHS will meet certain minimum qualifications. The qualifications
identified by the licensee are those recommended for an RSO by NRC in Regulatory Guide
8.31. RSO qualifications in Regulatory Guide 8.31 include; (1)a bachelor's degree in the
physical sciences, industrial hygiene, or engineering, or an equivalent combination of
training and relevant experience in uranium mill raJiatic:r protection; l2l appropriate health
physics experience; (3) specialtzed classroom and biannual refresher traanang; and
(41 appropriate specialized knowledge.
3.3.2 Radiation Safety Starf
PRL states that both the EST and the RT will be qualified based on specific levels of
education, training, and relevant experience. The education, training, and experience
identified by PRL is that specified in Regulatory Guide 8.31.
The NRC staff finds the above qualifications for radiation safety personnel to be in
accordance with its recommendations in Regulatory Guide 8.31, and therefore, acceptable.
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3.4
a.
Administrative and Ooeratino Procedures
Operational versus Standby Radiation Safety Programs
PRL proposes to define two modes of activity at the mill: (11 "operational" and
(21 "interim" or "standby." The operationat mode is defined as any time the mill is
in the normal commercial production of yellowcake, as contrasted with the interim
mode which occurs when no yellowcake is produced for a period of 3O days or
more. PRL proposes to implement a reduced in-plant radiation safety program
during periods of standby.
With the current volatility in the market for yellowcake at present, it is possible that
the mill could be operated intermittently over the next several years. However, the
NRC staff does not consider a 30-day period of non-production to be significant
enough to involve a major modification to a licensee's radiation safety program.
Therefore. the NRC staff does not find PRL's proposed interim program acceptable,
Il3 and will instead require, by license condition, that PRL continue to conduct its
operational radiation safety program during standby periods. Should a standby
period become extended, PRL will have the opportunity to reguest a license
amendment to modify its operational program. PRL agreed to this license condition
by telephone call on April 25, 1997.
In the following discussion, only PRL's operational radiation program will be
addressed. Prior to the commencement of ere processing, PRL will be required, by
license condition, to conduct the interim radiation safety and environmental
monitoring programs outlined in Tables 5.5-3 and 5.5-8, respectively, ol the license
renewal application. PRL agreed to this condition by telephone on May 1 ,1997.
b. Standard Operating Procedures
Written operating procedures have been established for routine production activities'
involving the handling and processing of radioactive material and include routine
radiation safety practices. Non-routine operations posing a radiological health risk
to workers will require review of the procedures by the ERHS or the radiation safety
staff, and the issuance of radiation work permits establishing the radiological health
protection measures for the operations.
The Mill Superintendent and the ERHS review and approve all written procedures
for operational and non-operational activities prior to their implementation and
whenever a change in procedure is proposed, to ensure that proper radiation
protection principles will be applied. The ERHS will perform a documented review
of all existing operational procedures on an annual basis. PRL has committed to
keeping up-to-date copies of the operational and radiation safety procedures
available in each area of the mill to which they apply
The licensee has stated that Radiation Work Permits (RWPs) will be issued to cover
any non-routine activity which poses a radiological risk to employees and for which
no standard.written procedure already exists. The RWP will address:
The scope of the work to be performed;
Any precautions necessary to reduce exposure to uranaum and its
daughters; and
3. The supplemental radiological monitoring and sampling necessary
prior to, during, and following completio,, of the work.
The RWP will be signed by the ERHS or their designee.
PBL states that results of audits and other reviews of the radiation protection
program and the results of surveys and calibrations will be maintained for three {3}
years after the record is made. NRC currently requires uranium recovery licensees
to retain such documentation for a period of at least five (5) years, and therefore,
PRL will be required, by license condition, to retain these results for this longer
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period of time. PRL commits to retaining other records (e.9., records to determine
dose from external sources, measurements and calculations of releases or
radioactive effluents to the environment) until SUA-1371 is terminated. PBL agreed
to this license condition by telephone on April 28, 1997.
The NRC staff concludes that the proposed program is in accordance with the
recommendations contained in Regulatory Guide 8.31, and therefore, is acceptable,
3.5 lnspections and Audits
3.5.1 lnspections
PRL proposes that the ERHS or their designee perform (1) a daily visual walk-through
inspection of the mill and ore stockpiles and (2) a similar documented inspection of the
same areas on a weekly basis. The purpose of these inspections is to observe work
practices and working conditions in the mill so as to minimize the spread of contamination
and to maintain exposures to levels that are "as low as is reasonably achievable" (ALARA).
The ERHS will provide the Mill Superintendent and the Vice President for Milling with a
monthly written summary of the visual inspections and of the mill and environmental
monitoring data.
The NRC staff has reviewed PRL's proposed inspection program against the staff's
recommendations in Regulatory Guide 8.31. Based on this review, the NRC staff will
require, by license condition, that PRL conduct its proposed program with the following
modifications:
. The licensee shall document problems observed during the daily visual walk-
through inspections in writing; and
o The ERHS and the mill foreman, or qualified designees, shall perform weekly
inspections to observe general radiation control practices and to review
required changes in procedures and equipment.
PRL agreed to this license condition by telephone on April 28, 1997.
3.5.2 ATARA Audit
PRL proposes to conduct semiannual audits of operating procedures, exposure records,
monthly inspection reports, and training programs to evaluate the overall effectiveness of
the radiation safety program and adherence to the company's ALARA philosophy. These
audits are to be performed by the ERHS, with results documented and provided to the Vice
President for Milling, the Mill Superintendent, and NRC.
PRL's proposed ALARA audit program is not consistent with the recommendations
contained in Regulatory Guide 8.31. ln this guidance document, NRC recommends, in
part, that:
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I Therefore, the NRC staff wil! require that PRL conduct its annual ALABA audits as outlined
I in Regulatory Guide t 31. PRL agreed to th's license condition b1 ielephone on April 25,
1 997.
I The NRC staff concludes that PRL's ALARA audit program, as modified by the staff, is
acceptable.
o ALARA audits be conducted annually by a team of individuals with
knowledge of the radiation protection progtam at the mill;
o The RSO accompany the audit te.;m but not be a member of that team;
o The audit report summarize, in addition to the items identified by PRL, the
radiation .afety meeting reports, bioassay results, and radiological survey
and sampling data; and
o The audit report specifically discuss: (a) trends in personnel exposure for
identifiable categories of workers and types of operational activities;
(b) whether equipment for exposure control is being properly used,
maintained, and inspected; and (c) recommendations on ways to fuither
reduce personne! exposures from uranium and its daughters.
I 3.6 Radiation Safetv Trainino
- 1}, PRL's radiological protection training program encompasses basic radiation protection
f f training for new employees and contractors, on-the-job training, and annual refresherr
- training for all permanent employees. Training received will be documented and records of
training will be maintained onsite.
I rul n"* employees will be instructed in the inherent risks of exposure to radiataon and the
fundamentals of protection against exposure before beginning their jobs. A written exam
I on the principles of radiation protection in uranium milling wilt be given to all newf employees; those receiving a failing grade on the exam will be retrained and retested.
Exam results will be maintained on file.
I All new employees, including supervisors, witt atso receive individuatizcd on-the-job training
on the health and radiation aspects of the specific jobs they wil! perform. This instruction
I rruil! be given by a qualified supervisor or other person experienced in the assigned tasks.
I Supervisors will receive additional specialized training on their supervisory responsibilities
in the area of worker radiation protection.
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I As noted above, all permanent employees, including supervisors, will receive relreshr radiation safety training annually. This training will include a review of the radiation
r protection topics applicable to uranium milling, changes in regulations and license
I conditions, exposure trends, and other current topacs in radiation protection. Exams- be given at the end of the refresher training course.
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PRL stated that safety meetings will be held at least once every two months to discuss
matters of concern that arise during mill operations and to encourage worker participation
in the identification of ways to reduce occupational radiation exposures
Prior to performing their work assignments without escort, contractors will be given
radiation protection training applicable to their ra,n1[ 3nd the radiological conditions they
may encounter in the mill. Contractors working on heavily contaminated equipment will be
given the same training as that normally given to permanent workers.
The NRC staff has determined that the radiation safety training program proposeci by the
PRL is in accordance with the staff guidance specified in Regulatory Guide 8.31, and
therefore, is acceptable.
4.O
4.1
a.
RADIATION SAFETY CONTROLS AND MONITORING
Ventilation and Effluent Control
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Dust generated in the ore dump pocket is controhed by an automatic dust-
suppression spray system. As ore is transferred from the ore hopper to the
conveyor belt, dust is collected and discharged to a wet dust collector. Exhaust
from the collector is released through a stack about 3O m (1OO ft) above plant
grade. Slurry from the dust collector will be pumped into the process circuit at the
SAG mill.
Yellowcake particles from the hearth dryer and the enclosed packaging area pass
through a wet dust collector before being discharged to the atmosphere at a rate of
0.007 kg (0.0t 6 lbs) per hour.
ln the mill, the processing buildings
fans, hoods and ducting to control
forced-air ventilation system in the
vapors and discharges them to the
and equipment are provided with ventilation
the concentration of gaseous effluents. A
solvent extraction building removes kerosene
atmosphere through three roof ventilators.
PBL has committed to monitoring of effluent control equipment in the yellowcake
drying and packaging area and immediately suspending drying and packaging
operations if the effluent control equipment is not functioning as designed.
Area Sourcas
PRL will control dust generation at the ore stockpile area through water sprinkling
or other dust-suppression techniques. Monthly documented inspections will be
used to assess dusting conditions. Weekly air particulate sampling results from
monitoring locations near the ore stockpile area will be documented and used by
the ERHS or their staff to determine the appropriate method for minimizing dust
generation. When the ore stockpile is being worked, either to add or remove ore,
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the working face of the stockpile will be sprayed with water as needed to control
the dust.
The NRC staff concludes that the mill ventilation and effluent control program is
acceptable.
4.2 In-.PlAnt Monitgring Dat-a
As discussed previously, PRL operated the Shootaring Canyon mill for only three months in
1982; therefore, operational monitoring data is extremely limited. Airborne uranium and
radon daughter concentrations and gamma exposure levels during the three months of
operation and all of 1983 were reviewed by the NRC staff in the SER prepared for the
1986 license renewal. The staff determined at that time that uranium and radon progeny
concentrations rryere all below the applicable 1O CFR Part 20 maximum permissible
concentrations (MPCs), and that average gamma levels were less than 0.25 mR/hr (NRC,
1986).
PRL will conduct routine monitoring for airborne uranium dust and radon progeny, and
surveying for direct radiation (gammal at 20 loca'iions throughout the mill. The
monitoring/surveying locations are identified in Table 5.5-2 of the renewal application and
include: the ore hopper and SAG mill areas, the CCD and solvent extraction areas, various
portions of the yellowcake precipitation, drying, and packaging circuit, and the lunch and
change areas. PRL's proposed frequency for the monitoring and surveying is discussed in
Sections 4.4.2 and 4.5.1.
4.3 Persgnnel Monit.gring Data
PRL will record time spent by employees in areas monitored for uranium dust and radon
progeny. Details concerning the methods and frequencies used by PRL to monitor for
airborne uranium and radon are discussed in Section 4.5.1. Using the monitored air
concentrations and the employee time card information, exposure levels for employees will
be calculated.
4.4 External Radiation Cont(o!, Program
4.4.1 Occupational Exposure
The licensee has committed to using thermoluminescent dosimeter ffLD) badges to
determine individual exposures. During full operations at the mill, each employee working
at the facility will be issued badges and required to wear them at all times on-site. Badges
will be analyzed on a quarterly basis. The cumulative occupational dose of the employee
will be filed in accordance with the requirements of 1O CFR Part 20. lf groups of
employees receive exposures significantly above those received by other groups, the ERHS
will investigate the cause and institute corrective actions, as appropriate.
The NRC staff concludes that the external exposure monitoring program is in accordance
with Regulatory Guide 8.3O, and is, therefore, acceptable.
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4.4.2 Externa! Radiation Surveys
PRL proposes to conduct gamma radiation surveys on a semiannual basis at a minimum of
20 areas in the mill. Surveys will be conducted in locations where both routine and
non-routine work is performed so that whole-body radiation exposures can be estimated.
Measurements will betaken at about waist height and approximately 30.5 on (12 inches)
from surfaces. Survey results will be used to determine if a particular area should be
posted as a "radiation area" and to identify sources of elevated gamma levels. Tne
radiological health monitoring procedures in Appendix F to the renewal application
provides details on the monitoring techniques to be utilized at the Shootaring Canyon mill
site.
The NRC staff finds that the external radiation monitoring program is in accordance with
Regulatory Guide 8.3O, and is, therefore, acceptable.
4.5 lnternal Radiation Control Proqram
4.5.1 Airborne Radioactivity Surveys
a. Uranium
PRL will use area monitoring and breathing zone air sampling for airborne
radionuclides to determine personnel exposures to uranium-bearing dust. The
sampling frequency will depend on the concentration of radionuclides measured in
air, as compared to the appropriate Derived Air Concentration (DAC):
Sampling
Frequency
Concentration in Air
Daily Greater than 1 .O DAC
Weekly Between O.3 and 1.O DAC; ln occupied
yellowcake precipitation area
Ouarterly Between O.O1 and O.3 DAC
None Below 0.O1 DAC
During routine mill operations, breathing zone air samples will be gathered if
concentrations are above 0.1 DAC, while area air samples may be used in areas
where the particulate concentrations are between O.O1 and O.1 DAC. The ERHS
will decide on the more appropriate type of air sampler to use based on the criteria
above.
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b,Radon progeny
As with airborne
of radon progeny
observed:
uranium dust monatoring, PRL proposes determining the frequency
siimpling depending o,r the working level (WL) concentration
--. Personne! time spent in the monitored areas will be recorded on a daily time card by the
lI :iliH:: ",1rx3.'3::":ffi'trl;li; lllJ][:r:::0""'''" area airborne concentrations'
As monitoring data become available, PRL will conduct comparisons and trend analyses of
the measured airborne radionuclide concentrations. Based on the results of these
evaluations, the ERHS can take appropriate actions to ensure that employee exposures
remain ALARA.
Radiation work permits (RWPs) will be issued for non-routine work and maintenance. The
ERHS or their designee will specify on the RWP any precautions necessary to reduce
exposure to uranium and its daughters and any supplementa! radiolonical monitoring and
sampling that is necessary. ln addition, the time spent by employees in accomplishing the
work are recorded on the RWPs.
The NRC staff concludes that the proposed program for measurement of internal exposure
to airborne radioactivity is in accordance with Regulatory Guide 8.30, and is, therefore,
acceptable.
4.5.3 Respiratory Protection Program
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barnpling
Frequency
Concentration
Weekly Greater than O.OB WL
Monthly Between O.O3 and O.OB WL
Ouarterly Below O.O3 WL
The modified Kusnetz sampling and analysis procedure will be utilized to determine
radon concentrations. The samples collected will be representative of worker
exposure.
The NBC staff finds that the proposed program for airborne particulate monitoring is
in accordance with Regulatory Guide 8.3O, and is, therefore, acceptable.
4.5.2 lnterna! Exposure to Radioactivity
PRL's proposed respiratory protection program includes a management policy statement
and written operating procedures which address (a) engineering controls used to meet
ALARA goals, (bl decontamination of equipment, (c) routine, non-routine, and emergency
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use of respirators, (d) circumstances during which relief from respirator use is authorized,
(e) training requirements, (f) fit testing requirements, (g) physical examination
requirements, and (h) a maintenance, cleaning and storage policy for respirators.
The ERHS is responsible for the implementation and direct control of the respiratory
protection program. This individual is aided in the accomplishment of these responsibilities
by the other members of the radiation safety staff.
All employees will be given detailed respiratory use training as part of the initial radiological
safety training. Respiratory use training addresses the following topics: (1) the need for
respirators, (2) respiratory hazards, (3) engineering controls, (4) respirator selection,
(5) fit testing, donning, and wearing of respirators, (6) use and maintenance requirements,
(7) emergency respirator use, (8) hazard recognition and emergency management, and
(9) additional training as deemed necessary by the radiation safety staff.
The NRC staff finds that the proposed respirarory protection program, as presented in
Appendix G of the renewal application, is in accordance with staff guidance as specified in
Regulatory Guide 8.15 and is, therefore, acceptable.
4.6 Bioassav
Bioassays will be performed for all mill department personne! where reason exists that an
exposure could exceed 30 percent of a DAC in a year. This will include all workers
routinely exposed to airborne yellowcake and airborne uranium ore dust, or directly
involved in maintenance tasks in which yellowcake dust may be produced. Specifically,
urine samples wil! be collected every two weeks from those employees whose work
assignments daily expose them to airborne yellowcake dust. ln addition, any employee
assigned.to work in the yellowcake area wil! be required to submit a urine sample following
the most recent occupancy of that area. Baseline urinalysis will be performed on
employees who will be working in such conditions and areas.
Procedures for collection, preparation and analysis of urine samples was submitted under
Section 7, "Bioassay Program," to Appendix F of the renewal application. PRL will
perform the analyses in-house using a lower limit of detection of 5 pgll. Bioassay
laboratory surfaces will be decontaminated prior to sample analysis, and quality contro!
(OC) samples (spikes and blanksl will accompany the samples. The analysis will be
performed by using fluorometric techniques. PRL committed to following the action levels
presented in Regulatory Guide 8.22.
Annual in-vivo body counting for lung burden of natural uranium or U-235 will be
conducted for those employees exposed to uranium ore dust as part of their routine work
assignments. Additional monitoring by an in-vivo body counter will be performed if
warranted by bioassay results. The results of monitoring will be reviewed by the ERHS
and his staff, and appropriate actions will be taken in accordance with the action levels
specified in Regulatory Guide 8.22.
The NRC staff concludes that the bioassay program proposed by EFN is in accordance
with Regulatory Guide 8.22, and is, therefore, acceptable.
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4.7 Contamination Cpntrgl
4.7 .1 Personnel Gontamination
Personnel working within the mil! area wil! be provided with change room, shower and
laundry facilities. Employees working in areas containing soluble uranium, as well as other
areas designated by the ERHS, will be issued protective clothing, such as coveralls, rubber
boots, and gloves. Soiled coveralls will be laundered usually at the end of each shift, and
monitored monthly for fixed alpha.
Employees will also be required to monitor themselves with an alpha survey meter prior to
Ieaving the mill site. Alpha contamination on skin or clothes measured at greater than
lOOO dpm/lOO cm2 shall be cause for decontamination (e.g., washing hands and skin.
hair). To ensure the effectiveness of the employee contamination surveys, spot checks
will also be performed and documented. Coveralls and contaminated clothing will be
laundered on site, and the laundry wastewater will be discharged to the tailings
impoundment.
The NRC staff considers the proposed program for personnel contamination control to be
acceptable.
4.7.2 Surface Contamination
PRL proposes that removable alpha radiation survey measurements be obtained every other
week from all lunch rooms, change rooms, and control rooms within the mill. If
contamination levels exceed lOOO dpm/lOO cm2, the area in question will be restricted
from use until it is cleaned to below this limit. The survey frequency will be increased to
weekly in those areas in which observed contamination levels exceed 5OO dpm/lOO cm2
until observed levels are below 5OO dpm/l00 cm2 for three weeks in a row.
Administrative offices, which are located in a separate building, wil! be monitored quarterly
for removable alpha radiation.
ln additior'r, as discussed in Section
conduct a daily visual walk-through
survey for visual contarnination.
3.5.1, the ERHS or their designee will be reguired to
inspection of the mill. This inspection will include a
Finally,.following work in a respirator-use area, workers will deposit used respirators in a
designated receptacle; workers will be required to use a new respirator if subsequent work
in the same or different area is required. The radiation safety staff will decontaminate
used respirators on a daily basis.
The NRC staff finds PRL's surface contamination program to be acceptable.
4.7.3 Disposal of Contaminated Equipment
PRL will survey potentially contaminated equipment or material before it is released for
unrestricted use. Material registering contamination levels higher than specified limits will
be decontaminated and resurveyed until contamination levels are below the limits. The
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release limits proposed by PRL are consistent with thosq provided in NRC's guidance
document, "Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of License for Byproduct, Source, or Special Nuclear
Material," dated May 1987.
Prior to being surveyed for unrestricted release, contaminated equipment and materials will
be stored temporarily in a designated area within the restricted area. The ERHS or a
member of the radiation staff will monitor this area for external gamma radiation and
possible posting as a radiation/contamination area.
Material not meeting the release limits and considered to be nonsalvageable will be
disposed of in the tailings impoundment. PRL will minimize voids in such material prior to
its placement in the impoundment.
The NRC staff finds the proposed program acceptable.
4.8 Oualitv Assuraoce and Calibration
PRL's proposed radiation protection and environmental monitoring procedures are provided
in Appendix F of the renewal application. These procedures are used by the licensee to
provide uniform guidance and consistency to the monitoring activities, and they cover the
sampling and calibration procedures which are an integral part of the quality assurance
program at the mill. Each procedure discusses quality control actions of which the
technician taking the sample must be aware, the techniques for sample collection,
preservation, and measurement, and the type of equipment needed to carry out the
monitoring. The types of instrumentation to be used in radiation monitoring and their
sensitivity/efficiency and measurement range are provided in Table 5.5-4 of the renewal
application.
The quality assurance (olA) program for PRL's analytical laboratory, which is presented in
Appendix I of the renewal application, is based on NRC staff guidance provided in
Regulatory Guides 4.15 and 8.22. The ERHS will review the OA programs for outside
commercial laboratories contracted to perform sample analyses.
PRL will calibrate all radiation monitoring equipment semiannually or at the manufacturer's
suggested interval, whichever is sooner. All air sampling equipment will be calibrated
quarterly. Calibration procedures are presented in Section 8 to Appendix F of the renewal
application
The lll'lC staff concludes that the quality assurance program propos:d by PRL is in
accordance with staff recommendations specified in Regulatory Guides 4.15 and 8.31, and
is, therefore, acceptable.
5.O RESTRICTED AREA MARKINGS AND ACCESS CONTROL
The mil! and tailings area is fenced and posted with "Restricted Area" signs in accordance
with 1O CFR 2O.19O2 except on the west sade of the impoundment where cliffs form a
natural barrier. The mill normally will run seven days a week, twenty-four hours a day,
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and security will be provided throughout the day and night. PRL will conduct and
document monthly inspections of fences and access gates during mill operations.
All visitors will be required to register at thc of lice and will not be permitted inside the
plant restricted area without proper authorization and escort. Prior to performing their
work assignments without escort, contractors wilf be given radiation protection training
applicable to their worL and the radiological conditions they may encounter in the mill.
The NRC staff concludes that the above ma:'kings and access control procedures are
adequate. A license condition will be issued which exempts the licensee from the
requirements of Section 20.1902(e) of 1O CFR Part 20 for areas within the mill, provided
that atl entrances to the mill are conspicuously posted in accordance with Section
2O.19O2le) and with the words, "ANY AREA WITHIN THE MILL MAY CONTAII',i
RADIOACTIVE MATERIAL. "
The proposed program for restricted area markings and access control is acceptable.
6.0 EMERGENCY PROCEDUBES AND PREVENTATIVE MEASURES
PRL provided a "Radiological Emergency Action Plan" as Appendix A to the renewal
application. ln this plan, PRL identifies the actions to be carried out by the site radiological
response team (i.e., the ERHS, RT, and other support personnel as needed) in the event of
mill site accidents and transportation accidents involving yellowcake shipments.
PRL also evaluated a variety of potential site accidents in the renewal application.
Potential environmental impacts associated with these accidents are assessed in the EA
prepared by the NRC staff in conjunction with this license renewal.
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PRL has proposed updating its liner design in advance of resuming operations. The
proposed design consists, from top to bottom, of a flexible membrane synthetic liner,
leak collection/detection system, another flexible membrane liner, and a prepared and
compacted clay base. A tailings leachate collection system would be installed on top
the upper synthetic liner and would drain to a sump from which the liquid will be used
tailings dust abatement or recycled back to the mill. The NRC and S:ate of Utah
Department of Environmental Ouality (DEO) staffs have agreed to having the State take
the lead in the review of PRL's proposed liner design. This means that the NRC staff
would defer to the State on a determination relative to the liner design, as long as the NRC
staff is confident that the State's review is proteetive of public health and safety, including
radiological hazards. The State of Utah DEO staff is conducting its review as part of its
process for granting a groundwater discharge permit for the Shootaring Canyon mill site.
Until such time as an updated liner design is approved by the State and NRC and the liner
subsequently installed, PRL will not be authorized to commence mitling operations. PRL
agreed to this license condition by telephone on April 3, 1997.
ln addition, the licensee is required under Appendix A to 1O CFR Part 40 to conduct a
groundwater detection monitoring program. PRL's program will involve semiannual
a
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sampling of three point of compliance wells completed in the uppermost aquifer, with each
groundwater sample analyzed for five ir,dicator parameters (natural uranium, arsenic,
selenium, chloride, and pH). Sampling results will be compared with NRC-approved
threshold limits contained in the license, and if these limits are exceeded, PRL will be
required to propose, within a set period of time, an expanded monitoring program to NRC
for approval.
Detailed discussion of PRL's monitoring programs for the tailings impoundment and the
groundwater system are provided in the EA prepared by the NRC staff for this proposed
licensing action.
8.O MILL SITE DECOMMISSIONING AND RECLAMATION
The mill decommissioning plan generally involves separating reusable materials which can
be released to the public or are releasable to another licensed facility from those materials
which require special disposal. Equipment and materials to be disposed of are proposed to
be buried Within the tailings retention impoundment. ltems released to the genera! public
will meet the appropriate release guidelines.
The NRC staff will require that a detailed decommissionrng plan be submitted for NRC
review and approval at least twelve months prior to a planned final shutdown.
Currently, the NRC staff is reviewing PRL's detaaled site reclamation plan in accordance
with the requirements of 1O CFR Part 4O, Appendix A, and applicable staff guidance
documents. PRL will be required to perform reclamation of the site in accordance with an
NRC-approved final reclamation plan.
9.0 SURETY REOUIREMENTS
1O CFR 40, Appendix A, Criterion 9, requires the licensee to establish a financial surety
arrangement to assure that sufficient funds will be available to carry out the
decontamination and decommissioning of the facility. The surety is based on an estimate
which must account for the total costs that would be incurred if an independent contractor
were contracted to perform the work. The surety estimate must be approved by NRC and
be based on an NRC-approved decommissioning and reclamation plan. The licensee must
also provide the surety arrangement through a financial instrument acceptable to NRC.
The licensee's surety mechanism will be reviewed by NRC annually to assure that
sufficient funds are available to complete the reclamation. Additionally, the amount of the
surety should be adjusted to recognize any increases or decreases in liability resulting from
inflation, changes in engineering plans, or other conditions affecting cost.
PRL submitted a revised detailed site decommissioning and reclamation plan by letter dated
January 1O, 1997. In addition to providing in the plan a detailed description of activities
necessary to complete decommissioning and reclamation at the site, PBL also estimated
the total cost that an independent contractor hired to perform these actavities would incur
to complete the work. PRL estimated this cost to be $6,784,159.
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ByletterdatedFebruary 26, 1997, theNRCstaff foundthiscostestimatetobeadequate
, for the purposes of resuming mill operations. PRL supplied documentation, by letter dated
March 14, 1997, that its surety amount for the Shootaring Canyon site was irr excess of
$6,784,159. The NRC staff has reviewed the documentation and finds the revised surety
amount to be acceptable.
1O.O INSPECTION HISTORY
NRC has conducted routine announced, routine unannounced, and reactive inspections of
PRL's Shootaring Canyon uranium mill since the renewal of SUA-1371 on February 3,
1986. 1O inspections have been conducted since that date, in which a total of two
violations were cited, the highest of which was of Severity Level lV. A discussion of
inspection and enforcement actions, including severity of violations is provided in
NUREG-I600 (NRC, July 1995). Minor violations are cited at Severity Level !V and major
violations are cited at Severity Level l. Typically, Severity Level lV violations are cited for
not performing required surveys or incomplete documentation. All cited violations have
been acceptably addressed and corrective measures enacted by the licensee. A summary
of the inspection history for the facility since February 1986 is provided in Table 1O.1.
TABLE 1O.1
SUMMARY OF NRC INSPECTIONS AT
PLATEAU RESOUBCES LIMITED'S
SHOOTARING CANYON URANIUM MILL
# OF SEVERITYDATE TYPE. VIOLA- LEVEL COMMENTS/RESULTS
TIONS
3t24-25197 A o
6t18196 A o
7 t10-1 1 /95 A o
6t29t94 A 1 IV Failure to maintain fire detection and suppres-
sion systems in operating order per license
condition. Violation Closed.
1t10192 R o lnspection prompted by telephone allegation
that unauthorized mill operations had
occurred. lnspector unable to substantiate
basis of allegation through direct
observations, measurements, and interviews.
10t24/91 A o
8t15/90 A o
6t29t89 U o
5t25l88 U o
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On July 2, 1996, the Commission approved increasing the license term for qualified
uranium recovery licensees from the current five-year period to a ten-year period. As
discussed in SECY-96-112 (issued on May 21,1996), the criteria to be used in
determining whether a licensee is "qualified" are as follows:
(1) the licensee must have performed well;
Ql the licensee must have a successful inspection record, with no violations
more serious than Severity Level lV;
(3) the licensee must have had no serious operational problems or reports during
the previous two years; and
(4) the license in question must currently have a specific term of renewal
(uranium mills currently undergoing reclamation would not meet this criteria).
The NRC staff addressed the issue of granting ten-year licenses to new uranium recovery
licensees in a July 9, 1997, letter t'ansmitting SECY-96-1 12 and the Commission's
approval to current and potentia! licensees. ln that letter, the NRC staff stated that. since
new licens-aes are likely to have only limited, if any, operating experience which could be
used by NBC to evaluate the licensee's performance, the NRC staff will continue to issue
five-year licenses to this group of licensees. After two years of operation, if a "nelru"
licensee desires to extend the term of its license to ten years, the licensee can submit an
amendment application to NRC which addresses the criteria above.
As dis-ussed previously, the Shootaring Canyon mill was operated for three months in
1982, and has been on interim shutdown (i.e., standby) status since that time. Also, in
preparing for a resumption of mill operations, PRL will need to hire and train a new set of
employees, who may or may not have prior experience working in a uranium mill. For
these reasons, the NRC staff considers PRL to be a "new" licensee, and therefore, will
renew SUA-I371 lor a five-year period.
TABLE 1O.1
SUMMARY OF NRC INSPECTIONS AT
PLATEAU RESOURCES LIMITED'S
SHOOTARING CANYON UBANIUM M!LL
# OF SEVERITY
DATE TYPE. VIOLA- LEVEL COMMENTS/RESULTS
TIONS
2/24-26t87 U 1 IV Failure to calibrate instruments in accordance
with procedures retercnced by license
condition. Violation Closed.
' A : Routine Announced; R = Reactive; U = Routine Unannounced
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1 1.O CONCLUSION INCLUDING SAFETY LICENSE CONDITIONS
Upon completion of the safety review of PRL's renewal application for a source material
license, the NRC staff concludes that the resur,rption of operations at the Shootaring
Canyon uranium mill, in accordance with the following license conditions, is protective of
health and safety and fulfills the requirements of 1O CFR Parts 20 and 4O. The NRC staff,
therefore, recommend. renewal of PRL's Source Material License SUA-1371, subject to
the following conditions:
The licensee may, without prior NRC approval, and subject to the conditions
specified in Part B of this condition:
Make changes in the facility or process, os presented in the
application.
Make changes in the procedures presented in the application.
(3)Conduct tests or experiments not presented in the application.
The licensee shall file an application for an amendment to the license, unless
the following conditions are satisfied.
The change, test, or experiment does not conflict with any
requirement specifically stated in this license, or impair the licensee's
ability to meet all applicable NRC regulations.
There is no degradation in the essential safety or environmental
commitments in the license application, or provided by the approved
reclamation plan.
The change, test, or experiment are consistent with the conclusions
of actions analyzed and selected in the EA for this action.
The licensee's determinations concerning Part B of this condition, shall be
made by a "Safety and Environmenta! Review Panel (SERP)." The SERP
shall consist of a minimum of three individuals. One n'.imber of the SERP
shall have expertise in management and shal! be responsible for managerial
and financial approval changes; one member shall have expertise in
operations and/or construction and shall have responsibility for implementing
any operational changes; and, one member shall be the corporate radiation
safety officer (CRSO) or equivalent, with the responsibility of assuring
changes conform to radiation safety and environmental requirements.
Additional members may be included in the SERP as appropriate, to address
technical aspects such as health physics, groundwater hydrology,
surface-water hydrology, specific earth sciences, and othor technical
disciplines. Temporary members or permanent members, other than the
three above-specified individuals, may be consultants.
A.
B.
(1)
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D. The licensee shall maintain records of any changes made pursuant to this
condition until license term:nation. These records shall include written
safety and environmental evaluations, made by the SERP, that provide the
basis for determining changes are in compliance with the requirements
referred to in Part B of this condition. The licensee shall furnish, in an
annual report to NRC, a descrip*i^r of such changes, tests, or experiments,
including a summary of the safety and environmental evaluation of each. ln
addition, the licensee shall annually submit to the NRC changed pages to the
approved license application to reflect changes made under this condition.
The licensee shall submit to NRC within 60 days of the issuance date of the
renewal license, for review, the standard operating procedures (SOPs) needed to
implement this license condition. The licensee shall not implement any provision of
this license condition until NRC has found the proposed SOPs acceptable.
2. SOPs shall be established and followed for all operational process activities
involving radioactive materials that are handled, processed, or stored. SOPs for
operational activities shal! enumerate pertinent radiation safety practices to be
followed. Additionally, written procedures shall be established for non-operational
activities to include in-plant and environmental monitoring, bioassay analyses, and
instrument calibrations. An up-to-date copy ef 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 ERHS before implementation and
whenever a change in procedure is proposed to ensure that proper radiation
protection principles are being applied. ln addition, the ERHS shall perform a
documented review of all existing operating procedures at least annually.
3. The licensee is hereby exempted from the requirements of Section 20.1902(e) of
1O CFR 20 for areas within the facility, provided that all entrances to the facility are
conspicuously posted in accordance with Section 20.1902(e) and with the words,
"Any area withan this facility may contain radioactive material."
4. The results of sampling, analyses, surveys and monitoring, the results of calibration
of equipment, reports on audits and inspections, all meetings and training courses
required by this license and any subsequent reviews, investigations, and corrective
actaons, shall be documented. Unless otherwise specified in the NRC regulations,
all such documentation shall be maintained for a period of at least five (5) years.
5. The licensee shall perform an annual ALARA audit of the radiation safety program in
accordance with Regulatory Guide 8.31.
6. The licensee shall conduct the in-plant radiological monitoring program described in
Table 5.5-1 of the license renewal application, with the following modifications:
A. The licensee shall document problems observed during the daily visua! walk-
through inspections in writing; and
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The ERHS and the mill foreman, or qualified designees, shall perform weekly
inspections to observe general radiation control practices and to review
required changes in procedures and equipment.
This license condition shall take effect with the commencement of ore processing
through the mill.
The licensee shall maintain an NRC-approved financial surety arrangement,
consistent with 1O CFR 4O, Appendix A, Criteria 9 and 1 0, adequate to cover the
estimated costs, if accomplished by a third party, for decommissioning and
decontamination of the mill and mill site, for reclamation of any tailings or waste
disposal areas, for ground-water restoration as warranted, and for the long-term
surveillance fee. Within three months of NRC approval of a revised
reclamation/decommissioning plan, the licensee shall submit, for NRC review and
approval, a proposed revision to the financial surety arrangement if estimated costs
in the newly approved plan exceed the amount covered in the existing financial
surety. The revised surety shall then be rn effect within 3 months of written NRC
approval.
Annual updates to the surety amount, required by 1O CFR 40, Appendix A, Criteria
9 and 1O, shall be submitted to NRC at least 3 months prior to the anniversary date
which is designated as June 4 of each year. !f NRC has not approved a proposed
revision to the surety coverage 3O days prior to the expiration date of the existing
surety arrangement, the licensee shall extend the existing surety arrangement for
1 year. Along with each proposed revision or annual update, the licensee shall
submit supporting documentation showing a breakdown of the costs and the basis
for the cost estimates with adjustments for inflation, maintenance of a minimum
15 percent contingency fee, changes in engineering plans, activities performed and
any other conditions affecting estimated costs for site closure. The basis for the
cost estimate is the NBC approved reclamation/decommissioning plan or NRC
approved revisions to the plan. The previously provided guidance entitled
"Recommended Outline for Site Specific Reclamation and Stabilization Cost
Estimates" outlines the minimum considerations used by NRC in the review of site
closure estimates. Reclamation/decomrnissioning plans and annual updates should
follow this outline.
The currently approved financial surety arrangement, a Surety Trust Agreement
between Plateau Resources Limited and First lnterstate Bank of Commerce, shall be
continuously maintained in an amount no lessthan 96,784,159 forthe purpose of
complying with 1O CFR 40, Appendix A, Criteria 9 ano 1O, until a replacement is
authorized by the NRC.
Prior to the commencement of ore processing, the licensee shall conduct the
radiation safety and environmental monitoring programs in Tables 5.5-3 and 5.5-8
of the license renewal application.
The licensee shall submit a detailed decommissioning plan to NRC at least twelve
(121 months prior to planned final shutdown of mining operations.
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rn Environmental
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thePlease note that additional license conditions can be fot'nd
Assessment, which accompanies this licensing action.
REFERENCES
O
Plateau Resources Limited, 1997, "Shootaring Canyon Uranium Processing Facility,
I Decommissioning and Reclamation Plan," 1 vol. and 5 appendices, dated December 18,
I 1996, submitted by letter dated January 10, 1997.
U.S. Nuclear Regulatory Commission [NRC], May 21, 1996, "Ten-Year License Terms for
Uranium Recovery Licensees," SECY-96-1 1 2.
Plateau Besources Limited, 1996, "Shootaring Canyon Processing Facility, Garfield
County, Utah: Source Material License Renewal Application SUA-I371, DOCKET NO.
40-8698," 1 vol., March 1, 1996.
I NRC, July 1995, "General Statement of Policy and Procedures for NRC Enforcemeritr Actions (Enforcement Policy)," Office of Enforcenlent, NUREG-I600.
NRC, August 1988, "Bioassays at Uranium Mills," NRC Regulatory Guide 8.22, Rev. 1.
NRC, 1986, "Safety Evaluation Report for License Renewal SUA-I371, Docket No.
4O-8698, Plateau Resources Limited Shootaring Canyon Processing Facility," issued
February 3, 1986.
NRC, June 1983, "Health Physics Surveys in Uranium Mills," NRC Regulatory Guide 8.3O.
NRC, May 1983, "lnformation Relevant to Ensuring That Occupational Radiation
I Exposures at Uranium Mill Will Be As Low As ls Reasonably Achievable," NRC
I Regulatory Guide 8.31.
I NRC, October 198O, "Operational lnspection and Surveillance of Embankment Retention
I Systems for Uranium Mill Tailings," NRC Regulatory Guide 3.1 1.1.
r NRC, July 1979, "Fina! Environmental Statement: Related to Operation of Shootaring
I Canyon Uranium Project, Ptateau Resources, Ltd.," NUREG-OS83, Office of NuclearE Material Safety and Safeguards.
I NRC, February 1979, "Ouatity Assurance for Radiological Monitoring Programs (Normalr Operalions) - Effluent Streams and the Environment," NRC Regulato;y Guide 4.15.
I NRC, December 1977, "Design, Construction and lnspection of Embankment RetentionI Systems for Uranium Mills," NRC Regulatory Guide 3.11.
I [|fi;?ll?1er 1976, "Acceptable Prosrams for Respiratory Protection," NRC Resulatory
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O Enclosure 4
NRC Source Material License No. SUA-137 1
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PAGE OF . 6 -, PAGESI
NHC FORM 374
(7-e4)O u.s. N,.LEAR REGULAro,ly coM,tsstoN t
MATERIALS LICENSE
uant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10, Code of
ral.Regulations, Chapter I, Parts 30, 3l, 32, 33, 34, 35, 36,39, N, and 70, and in reliance on statements and representations heretofore made
6-y the licensee. a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, source, and special nuclear
material designated below; to use such material for the purpose(s) and at the place(s) designated below; to deliver or transfer such material to
persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conditions
specified in Section 183 of theAtomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders o[the
Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.
Licensee
l. Plateau Resources Lirnited
2. Box 21 11
Ticaboo
Lake Powell, Utah 84533-21 11
6. Byproduct, Source, and/or
Special Nuclear Material
Natural Uranium
3. License Number
suA-137 1
4. Expiration Date April 30,2OO2
7. Chenrical and/or Physical
Form
Any
40-8698
8. Ma,rimum Amount that Licensee
May Possess at Any One Time
Under This License
Unlirnited
5. Docket or
Refere[cs No.
ction 9: Administrative Conditions
9.2
The authorized place.of use shall be the licensee's Shootaring Canyon uranium mitling facility,
located in Garfield County, Utah.
All written notices and reports to the NRC required under this license, with the exception of
incident and event notifications under 1O CFR 20.2202and 1O CFR 40.60 requiring telept cne
notification, shall be addressed to the Chief, Uranium Recovery Branch, Division oiWaste
Management, Office of Nuclear Material Safety and Safeguards.
lncident and event notifications that require telephone notification shall be made to the NRC
Operations Center at (301) 816-51O0.
The licensee shall conduct operations in accordance with statements, representations and
conditions contained in the license renewal application dated March 1, 1996, as revised bysubmittals dated September 16, and November 1 5, 1996, and April 17 , 1997 , except where
superseded by license conditions below.
Whenever the word "will" is used in the above referenced sections, it shall denote a
requirement.
9.3
9.4 A. The licensee may, without prior NRC approval, and subject to the conditions specified in
Part B of this condition:
Make changes in the facility or process, as presented in the application.
Make changes in the procedures presented in the application.
"70s130+Lb ?7(}soePDR ADTIC|( 04(}(}86"AC PDR
(1)
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NRC FORM g74A U.S.ILEAR REGULATORY COMMISSION PAGE 2 OF 6PAGES
License Number
suA- 137 1
MATERIALS LICENSB Ip*t rt oi Reference Number
SUPPLEMENTARY SHEET
May 2, 1997
(3) Conduc' .,sts or experiments not presented in the application.
B. The licensee shall file an application for an amendment to the license, unless the
following conditions are satisfied.
(1) The change, test, or experiment does not conflict with any requirement specificaily
stated in this license, or impair the licensee's ability to meet all applicable NRC
regulations.
l2l There is no degradation in the essential safety or environmental commitments in
the license application, or provided by the approved reclamation plan.
(3) The change, test, or experiment is consistent with the conclusions of actions
analyzed and selected in the EA dated April 1997.
C. The licensee's determinations concerning Part B of this condition, shall be made by a
"Safety and Environmental Review Panel (SERP)." The SERP shall consist of a minimum
of three individuals. One member of the SERP shall have expertise in management and
shall be responsible for managerial and financial approval changes; one member shall
have expertise in operations and/or construction and shall have responsibility for
implementing any operational changes; and, one member shall be the corporate radiation
safety officer (CRSO) or equivalent, with the responsibility of assuring changes conform
to radiation safety and environmental requirements. Additional members may be
included in the SERP as appropriate, to address technical aspects such as heatth physics,
groundwater hydrology, surface-water hydrology, specific earth sciences, and other
technical disciplines. Temporary members or perrnanent members, other than the three
above-specified individuals, ffiay be consultants.
D. 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 SERP, that provide the basis for determining changes are in
compliance with the requirements referred to in Part B of this -ondition. The licensee
shall furnish, in an annual report to NRC, a description of such changes, tests, or
experiments, including a summary of the safety and environmental evaluation of each.
ln addition, the licensee shall annually submit to the NRC changed pages to the approved. l;cense application to reflect changes made under this condition.
The licensee shall submit to the NRC, by June 30, 1997, for review, the standard operating
procedures (SOPs) needed to implement this license condition. The licensee shall not
implement any provision of this license condition until NRC has found the proposed SOPs
acceptable.
9.5 The licensee shall maintain an NRC-approved financial surety arrangement, consistent with
1O CFR 4O, Appendix A, Criteria 9 and 1O, adequate to cover the estimated costs, if
accomplished by a third party, for decommissioning and decontamination of the mill and mill
site, for reclamation of any tailihgs or waste disposal areas, ground water restoration as
warranted and the long-term surveillance fee. Within 3 months of NRC approval of a revised
Printed on recvcled oaoer
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NRC FORM 3744
(7-94)
9,6
9.7
9.9
PAGE ? OF APAGES
License Number
MATERIALS LICBNSE
SUPPLEMENTARY SHEET
Ma
reclamation/decommissioning plan, the licensee shall submit, for NRC review and approval, a
proposed revision to the financial surety arrangement if estimated costs in the newly approved
plan exceed the amount covered in the existing financial surety. The revised surety shal! then
be in effect within 3 months of written NRC approval.
rdnnual Updates to the surety amount, required by 10 CFR 40, Appendix A, Criteria g and 10,
shall be submitted to the NRC at least 3 months prior to the anniversary of the effective date
of the approved surety arrangement. lf the NBC has not approved a proposed revision to the
surety coverage 3O days prior to the expiration date of the existing surety arrangem€nt, the
licensee shall extend the existing surety arrangement for 1 year. Along with each proposed
revision or annual update, the licensee shal! submit supporting documentation showing a
breakdown of the costs and the basis for the cost estimatss with adiustments for inflation,
maintenance of a minimum 15 percent contingency fee, changes in engineering plans,
activitios performed, and any other conditions affecting estimated costs for site closure.
The basis for the cost estimate is the NRC approved reclamation/decommissioning plan or NRC
approved revisions to the plan. The previously provided guidance entitled "Recommended
Outline for Site Specific Reclamation and Stabilization Cost Estimates" outlines the minimum
considerations used by the NRC in the review of site closure estimates.
Reclamation/decommissioning plans and annual updates should follow this outline.
The currently approved financial surety arrangement, a Surety Trust Agreement between
Plateau Resources Limited and First lnterstate Bank of Commerce, shall be continuously
maintained in an amount no less than $6,784,159for the purpose of complying with
1O CFR 40, Appendix A, Criteria 9 and 10, until a replacement is authorized by the NRC.
Standard oporating procedures shall be established and followed for all operational process
activities involving radioactive materials that are handled, processed, or stored. SOPs for
operational activities shall enumerate pertinent radiation safety practices to be followed.
Additionally, written procedures shall be establis\ed for non-operational activities to include
in-plant and environmental monitoring, bioassay analyses, and 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 Environmental and Radiological Health Supervisor (ERHSI before
implementation and whenever a change in procedure is proposed to ensure that proper
radiation protection principles are being applied. ln addition, the ERHS shall perform a
documented review of all existing operating procedures at least annually.
The licensee shalt have an archeotogical survey performed prior to disturbing any previously
unsurvoyed areas. The licensee shall immediately notify the NRC and the Office of State
Historic Preservation if artifacts are discovered during disturbance.
The licensee is hereby authorized to possess byproduct materiat in the form of uranium waste
tailings and other uranium byproduct waste generated by the licensee's milling operations
authorized by this license. Mill tailings shall not be transferred from the site without specific
prior approval of the NRC in the form of a license amendment. The licensee shall maintain a
permanent record of all transfers made under the provisions of this condition.
U.S.IEAR REGU LATORY COMMISSION
Docket nr Reference Number
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T-5--
NRC FORM 3744
17-e4)
U.S.
MATERIALS LICENSE
SU PPL EII,IE NTA RY SHEET
B REGU LATORY COTVIMISSION
Docket or Reference Number
9.9 The licensee is herets','exempted from the requirements of Section 20.1902(e) of
10 CFR Paft 20 for areas within the mill, provided that all entrances to the mill are
conspicuously posted in accordance with Section 20.19O2lei and with the words,
"Any Area Within this Mill May Contain Radioactive Material."
section 1O: Operational Controls, Limits, and Restrictions
10.1 The mill production per calendar yeil shall not exceed ,,0O4,00O pounds of yellowcake.
1O.2 All liquid effluents from mil! process buildings, with the exception of sanitary wastes, shall be
returned to the mili circuit or discharged to the tailings impounonrent.
10.3 The licensee shall notify the NRC at least ninety (90) days in advance of commencing ore
processing through the mill.
1O.4 The licensee is not authorized to commence mill operations until a fina! tailings impoundment
liner design has been approved by NRC and the approved liner installed in the impoundment.
0.5 The licensee shall not expand the tailings impoundment area by raising the height of the dam
above its present elevation or by constructing any additional dams without prior NRC approval
in the form of a license amendment.
10.6 The licensee shall comply with the following regarding the operation of the tailings disposal
system:
A. A detailed embankment instrumontation program shall be submitted for NRC approval at
least 3 months prior to placing tailings effluent against the current dam or raising the
current dam above its present height.
B.' A minimum of 13 feet of freeboard shall be maintained between the top of the current
dam and the tailings pond level.
10.7 Prior to resuming operations, the licensee shall conduct and document a technical evaluation of
all existing cross-valley berms and the tailings dam, including a review of all embankment
instrunnentation data and inspection reports. This evaluation shall be performed by a qualified
geotechnical individual familiar with the design, construction and operation of the berms and
dam, with a copy of the evaluation report submitted to NRC within one month of the
completion of the evaluation. This technical evaluation shall be conducted annually; copies of
these subsequent evaluation reports shall be retained onsite.
tO.8 The wet foarn and sprinkler fire suppression systoms must be fully functional prior to the
introduction of kerosen€ anto the mill circuit and the resumption of mill operations.
Printed on recycled paper
NRC FORM g74A
(7-941
U.S. I.EAR REGULATOBY COMMISBION
MATERIALS LICENSE \
SUPPLEMENTARY SHEET
License Number
Docket or Reference Number
M
PAGE R OF EPAGES
Section 11: Monitoring, Recording, and Bookkeeping Requirements
1 1 .1 The results of sampling, analyses, surveys and monitoring, the results of calibration of
equipment, reports on audits and inspections, all meetings and training cours€s required by this
license and any subsequent reviews, investigations, and corrective actions, shall be
documented. Unless otherwise specified in the NRC regulations all such documentataon shall
be maintained for a period of at least five (5) years.
11 .2 The licensee shat! conduct the environmental and efftuent monitoring program described in
Table 5.5-7 of the license renewal application, with the following modifications:
A. During periods of standby, stack sampling is not required.
B. The flow rate from the yellowcake dryer and packaging stack shall be measured quarterly
at the time stack sampling is conducted.
11.3 The licensee shall implement a groundwater detection monitoring program to ensure
compliance with 10 CFB 40, Appendix A, as follows:
A. The licensee shall sample monitoring wells RM-4, RM-s and RM-6, on a semiannual
basis, with samples taken at least 4 months apart. The samples shall be analyzed for
arsenic, chloride, selenium, U-nat, and pH.
B. The licensee shall compare the analysis results against the following threshold values:
arsenic = O.O22 mg/|, chloride = 40 mg/!, selenium = O.O22 mgfl and pH = 6.8
standard units or less. lf the threshold values are exceeded, the licensee shall propnss,
within 60 days of a measured exceedance, an expanded detection monitoring program to
define the extent and concentration of hazardous constituents in the uppermost aquifer.
C. The licensee shall submit the data and comparison results required under
subsections A and B, respectively, with the semiannual reports required under
10 cFR 40.6s.
D. The licensee shall report at least annually in accordance with the reporting requirements
specified in subsection C, the rate and direction of groundwater flow under the tailings
impoundment.
1 1.4 The licensee shall conduct an inspection program of the tailings disposal system in accordance
with Regulatory Guide 3.11.1.
11.5 The licensee shall conduct the in-plant radiological monitoring program described in
Table 5.5-1 of the license renewal application, with the following modifications:
A. The licensee shall document problems observed during the dally visual walk-through
inspections in writing; and
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NRC FORM 374A U.S. IEAR REGULATORY COMMISSION
(7-e4l
MATERIALS LICENSE
SUPPLEMENTARY SHEET
B. The ERHS and ''':e mill foreman, or qualified designees, shall perform weekly inspections
to observe general radiation contro! practices and to review required changes in
procedures and equipment.
1 1 .6 License conditions 1 1 .3, 11 .4, and 1 1 .5 shall take effect with the commencement of ore
processing through the mill.
Prior to the commencement of ore processing, the licensee shall conduct the radiation safety
and environmental monitoring programs in Tables 5.5-3 and 5.5-8, respectively, of the license
renewal application. ln additior, the licensee shall immediately notify the NRC of any failure in
the tailings embankment or tailings discharge system which results in the release of radioactive
material.
11.7 The licensee shall perform an annual ALARA audit of the radiation safety program in
accordance with Regulatory Guide 8.31.
Section 12: Reporting Requirements
.1 Notwithstanding the decommissioning plan contained in Section 5.5.9 of the renewal
application, the licensee shall submit a detailed decommissioning plan to the NRC at least
twelve (12) months prior to planned decommissioning activities.
12.2 Monitoring data provided in accordance with the requirements of 1o cFR 40.65 shall be
reported in the format shown in the NRC guidanco entitled, "Sample Format for Reporting
Monitoring Data."
FOR THE NUCLEAR REGULATORY COMMISSION
Date:
l^r.Md.
Joseph J. Holonich, Chief
Uraniurn Recovery Branch
Division of Waste Managernent
Office of Nuclear Material
Safety and Safeguards
Docket or Reference Number
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