DRC-2009-007883 - 0901a068802579af

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State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
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Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Diieclor
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October 14, 2009
Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 Seventeenth Street Suite 950
Denver, Colorado 80265
RE: Semi-Annual Effluent Monitoring Report for the period January 1, 2009 through June 30, 2009,
DRC Inspection Module EM-Ol, RML UTI900479.
Dear Mr. Landau,
An inspection was performed of the Semi-Annual Effluent Monitoring Report for the White Mesa Mill
in Blanding, Utah by representatives of the Division of Radiation Control (DRC). The inspection was
an examination of the effluent monitoring conducted at your facility as it relates to compliance with
the Utah Radiation Control Rules and the conditions of the license. The inspection consisted of
examination of the Semi-Annual Effluent Monitoring Report for the period January 1, 2009 through
June 30, 2009.
During this inspection, the items reviewed were found to be conducted in compliance with the
Utah Radiation Control Rules and requirements for this license. Please continue to remember that
radiation safety is the responsibility of the licensee. Thank you for cooperating in this matter.
If you have any questions or concems regarding this letter, please contact Kevin Carney at (801) 536-
4250.
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
DLF/KJC:kjc
cc: David Frydenlund, Vice-President and General Counsel
David Turk, Radiation Safety Officer
168 Norlh 1950 West • Salt Lake City, UT
Mailing Address; P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: Semi-Annual Effluent Monitoring Report (Module EM-Ol)
Inspection Location: DRC Office, Salt Lake City, Utah
Inspection Item: Semi-Annual Effluent Monitoring Report for Reporting Period January 1, 2009
through June 30, 2009.
Inspector(s): Kevin Carney
Personnel Contacted: Steven Landau, Manager, Environmental Affairs, Denison Mines
Governing Documents:
o White Mesa Environmental Protection Manual
o RML UTI900479
o NRC Reg Guide 4.14, Radiological Effluent and Environmental Monitoring at Uranium
Mills
o 10CFR20 Table II of Appendix B
o Utah Radiation Control Rules R313
Inspection Summarv
Inspection Module EM-Ol was performed by review of the White Mesa Mill Semi-Annual Effluent
Monitoring Report for Reporting Period January 1, 2009 through June 30, 2009 which was received by
the DRC on August 31, 2009.
The inspection evaluated adherence to the Mill's procedures and compared the effluent monitoring
results with 10CFR20 limits, Utah Rules and Regulatory Guide 4.14 recommendations.
Findings
Utah Administrative Code R313-24-4, incoiporating by reference I0CFR40.65(a)(l), states:
(1) Within 60 days after January I, 1976 and July 1, 1976, and within 60 days after January 1
and July 1 of each year thereafter, submit a report to the Director of the Office of Nuclear
Material Safety and Safeguards, using an appropriate method listed in § 40.5, with a copy to the
appropriate NRC Regional Office shown in appendix D to part 20 ofthis chapter; which report
must specify the quantity of each ofthe principal radionuclides released to unrestricted areas in
licjuid and in gaseous effluents during the previous six months of operation, and such other
information as the Commission may require to estimate maximum potential annual radiation
doses to the public resulting from effluent releases.
The Report was submitted 62 days after June 30, 2009. However, the inspector does not want to cite
Denison Mines for the Report being only two days overdue.
The EM-Ol inspection for the previous period, July 1, 2008 through December 31, 2008, was found to
have several findings associated with it. There were reporting deficiencies due to quality control
problems with the laboratory that Denison Mines had contracted with and the DRC had issues with the
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radon sampling results (Alpha Track) which were reported. Denison Mines has since contracted with
another laboratory and has seemingly resolved the previous quality control concems. In the DRC's letter
to Denison Mines, dated July 16, 2009, it was requested that Denison discontinue reporting the measured
radon results in the Semi-Annual Effluent Monitoring Report since the results were not intended to be used
to demonstrate compliance. Denison has complied with this request and continues to cite the MILDOS
AREA modeling to demonstrate compliance with radon effluent limits.
There are no findings associated with the Semi-Annual Effluent Monitoring Report for Reporting Period
January 1, 2009 through June 30, 2009.
Prepared by: Kevin Carney
(Print Name) "XSigfiature)
October 13, 2009
(Date)
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UTAH DIVISION OF RADIATION CONTROL
RML # UTI900479
DENISON MINES WHITE MESA MILL
INSPECTION MODULE EM-Ol
SEMI-ANNUAL EFFLUENT MONITORING REPORT
REPORTING PERIOD: January 1, 2009 through June 30, 2009
References: Utah Administrative Code R3I3-24-4; 10CFR40.65; Radioactive Materials License
UTI900479; 10CFR20 Table II of Appendix B; NRC Regulatory Guide 4.14; 2007
License Renewal Application
Inspector Kevin Carney Date October 13. 2009
I0CFR40.65(a)(l) requires the licensee to submit a report within 60 days after January 1 and July 1 of
each year. The report must specify 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.
1. Did the licensee submit the report within 60 days of the end of the reporting period i.e., January 1^' or
July I"? (10CFR40.65(a)(I))
Yes n No|E
Comments: Report was received hy the DRC nn August 31, 2009, 62 days after June 30, 2009.
2. Were the stack samples analyzed for U-nat, ^^^Th, ^^^Ra and ^'°Pb? (NRC Reg Guide 4.14)
Yes Kl NoD
Comments: Stack samples fnr the North YC Dryer fnr the 1'' quarter and the North YC dryer, Griz/ly
Baghouse and Yellnwcake Baghnuse fnr the l" and 2"*^ quarters were analyzed for the appropriate
radionuclides.
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3. Were site boundary effluent air samples analyzed for U-nat, ^^°Th, ^^^Ra and ^'Vb? (NRC Reg
Guide 4.14)
Yes IEI NoD
Comments: Air samples frnm statinns BHV-1, BHV-9 BHV-4, BHV-5 and BHV-6 were analyzed fnr
the appropriate radionuclides fnr both quarters 1 and 2.
4. Were soil samples analyzed for U-nat, ^^^Ra and ^'Vb? (NRC Reg Guide 4.14)
Yes n NoD N/A IE
Comments: Annual snil samples are mllected hy the Mill .staff during the third quarter nf each year
and are, therefnre. nnt repnrted fnr this perind.
5. Were vegetation samples analyzed for ^^Va and ^'Vb? (NRC Re^ Guide 4.14)
Yes El NoD
Comments: Vegetatinn samples were cnllected in NnrthwesI, Nnrtheast, and Sniithwest Incatinns
arniind the mill periphery in the eariy spring and were apprnpriately analyzed for the above
radionuclides. [
6. Were radon samples taken at Sample Stations BHV-1, BHV-2, BHV-4, BHV-5 and BHV-6? (NRC
Reg Guide 4. i4)
Yes D NoE
Comments: Radnn sampling was nnt included in this repnrt. The licensee has Hemnnstrated
cnmpliance with the radnn reporting requirements, as aiithnriz.ed hy the NRC, by calciilatinn using the
MILDOS AREA codes. ^_
Page 2 of 6
7. Were radon samples analyzed for ^^^Rn? (NRC Reg Guide 4.14)
Yes D NoD N/AE
Comments: See number 6 ahnve.
8. Were the ^^Vn results within the calculated ECL's for the yearly average results for 2007?
Yes n NoD N/AE
Comments: See number 6 ahnve
License Condition 11.2.D requires the licensee to utilize lower limits of detection in accordance with
Section 5 ofthe NRC Regulatory Guide 4.14, as amended, for analysis ofeffiuent and environmental
samples.
9. Were lower limits of detection (LLD) for analysis of stack effluent samples 10% or less of the limits
found in 10CFR20 Table II of Appendix B for U-nat, "^Th, ^^Va and ^'Vb? (NRC Reg Guide 4.14)
10CFR20 Table II of Appendix B, ECL's:
U-nat 9.0E"'^ pCi/ml 10%= 9.0E"'^ |aCi/ml
"Vh 2.0E""* |jCi/ml 10% = 2.0K'^ pCi/ml
^^Va 9.3E"'^ pCi/ml 10% = 9.3E''VCi/ml
^'°Pb 6.0E'^ pCi/ml 10% = e.OF''* pCi/ml
Yes n NoD N/AE
Comments: Since the stack sample results were higher than the lower limits nf detectinn, the abnve
listed limits were nnt required tn he met. ; -.—
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10. Were lower limits of detection (LLD) for analysis of site boundary air effluents within the limits
listed
4.14)
listed in NRC Regulatory Guide 4.14 Section 5 for U-nat, "°Th, "Va and ^'Vb? (NRC Reg Guide
NRC Regulatorv Guide 4.14 Section 5 LLD values (in air):
U-nat l.OE"'^ |aCi/ml
"Vh l.OE'VCi/ml
"Va l.OE'VCi/ml
^'Vb 2.0E"'^ pCi/ml
Yes n NoD N/AE
Comments: Since the .site hnnndary air effluent sample results were higher than the Inwer limits nf
detectinn. the abnve listed limits were nnt required tn he met.
11. Were lower limits of detection (LLD) for analysis of site boundary soil samples within the limits
listed in NRC Regulatory Guide 4.14 Section 5 for U-nat, "Va and ^'Vb?
NRC Regulatorv Guide 4.14 Section 5 LLD values (in soil):
U-nat 2.0E'^ |aCi/g
"Va 2.0E-^ nCi/g
^'Vb 2.0E-^ ^Ci/g
Yes n NoD N/AE
Comments: Annual snil samples are cnllected hy the Mill staff during the third quarter nf each year
and are, therefore, nnt repnrted fnr this perind.
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12. Were lower limits of detection (LLD) for analysis of site boundary vegetation samples within the
limits listed in NRC Regulatory Guide 4.14 Section 5 for "Va and ^'Vb?
NRC Regulatorv Guide 4.14 Section 5 LLD values (in vegetation):
"Va 5.0E"^ pCi/kg
-'Vb l.OE"'^ pCi/kg
Yes n NoD N/AE
Comments: Since the soil .sample results were higher than the Inwer limits nf detectinn, the abnve
listed limits were nnt required to be met.
13. Were lower limits of detection (LLD) for analysis of radon samples within the limits listed in NRC
Regulatory Guide 4.14 Section 5 for ""Rn?
NRC Regulatorv Guide 4.14 Section 5 LLD values for radon:
"Vn 2.0E"'°iaCi/ml (0.2pCi/L)
Yes n NOD N/A E
Comments: See number 6 ahnve.
White Mesa Environmental Protection Manual Section 1.4, STACK EMMISIONS MONITORING
PROCEDURES, sub-section I.O, INTRODUCTION, states, "These sampling methods are also
consistent with guidance contained in the U.S. Nuclear Regulatory Commission's Regulatory Guide
4.14, "Radiological Effluent and Environmental Monitoring at Uranium Mills."
14. Were the yellowcake dryer and packaging stacks sampled in accordance with Regulatory Guide 4.14
Section 2.1.1?
Quarterlv samples at North Yellowcake Drver and Yellowcake Baghouse for:
U-nat
Semi-annual samples at North Yellowcake Dryer and Yellowcake Baghouse for:
"Vh
"Va
210pb
Yes El NoD
Comments: l" and 2"'^ quarter stack samples were analyzed for all ofthe ahnve radionuclides.
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15. Were the site boundary effluent air sample results within applicable limits for U-nat, " Th, Ra and
-'Vb? (10CFR20 Table II of Appendix B)
10CFR20 Table II of Appendix B, ECL's:
U-nat 9.0E"''* pCi/ml in air
"Vh 2.0E"'^ pCi/mlinair
"Va 9.3E'-' pCi/mlinair
-'Vb 6.0E"'^ |jCi/m] in air
Yes El NoD
Comments: All bniindnry effluent air sample results met their respective FCLs with the vast majority
being helnw I % nf the respective ECT. and the highest being 3.61 % nf the RCI. fnr "Vh at the BHV-5
Monitoring Station.
16. Did the results of the effluent monitoring for this reporting period achieve the site's ALARA
objective of 25% of the ECL's? (2007 License Renewal Application Vol. 1 Section 6.5; 10CFR20
Table II of Appendix B)
10CFR20 Table II of Appendix B. ECL's:
U-nat 9.0E"'VCi/ml in air 25% = 2.25E'"* pCi/ml in air
"Vh 2.0E"'VCi/ml in air 25% = 5.I5E''^ |aCi/ml in air
"Va 9.3E'^|jCi/mlinair 25% = 2.33E"'^ pCi/m! in air
^'Vb ..6.0E"'VCi/mlinair 25%= 1.50E"'^ pCi/ml in air
Yes El NoD
Comments: See explanatinn in # 1 5 ahnve.
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