DRC-2008-002281 - 0901a0688080cdd6

@
State
JoN M. HUNTSMAN, JR.
Govemor
GARY HERBERT
Lieutenant Govemor
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
Re:
September 25,2008
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, Colorado 80265
Semi-Annual Effluent Monitoring Report for Period January 1, 2008 through June 30, 2008.
Radioactive Materials License W 190047 9.
Dear Mr. Landau:
Denison Mines White Mesa Mill (Denison) Semi-Annual Effluent Monitoring Report for Period
J'anuary 1, 2008 through June 30, 2008 has been reviewed by the Utah Division of Radiation
Control, (DRC), as per the DRC's White Mesa Mill Inspection Module EM-01, Semi-Annual
Effluent Monitoring Report. Two discrepancies were noted:
l) The report was received by the DRC on September 2,2008; a total of 64 days after July 1,
2008. Utah Administrative Code R313-24-4, incorporating by reference 10CFR40.65(a)(1),
requires the licensee to submit an effluent monitoring report within 60 days after January 1 and
July 1 of each year. The DRC reminds the licensee that the Semi-Annual Effluent Monitoring
Reports are due no later than 60 days after the end of the reporting period.
2) Results for all l't and 2nd quarter samples are below the calculated Effluent Concentration
Limits (ECLs) for Rn-222 at their respective stationS except for Station BHV-2. Second quarter
Rn-222 results for all sample stations were. reported as "below 0.4 pCilL." Station BFIV-2 has a
calculated ECL of 0.34 pCifi-. This result needs to be quantified because the "below 0.4 pCilL"
value is possibly higher than the 0.34 pCill- ECL. There is no way of knowing whether or not
the result was below the ECL.
Since the quarterly results for Rn-222 are averaged over the year for calculating the annual
exposure to the public, the effluent monitoring results should be accurate for each quarter they
are reported. The second half, (July l, 2008 through December 31, 2008), Effluent Monitoring
168 North I 950 West . Sah Lake City, UT
Mailing Address: P.O. Box 1,t4850 . Salt Lake City, UT 841 144850
Telephone [phone]. Fax [phone]. T.D.D. (80i) 536-4414
www.deq.utah.got'
Printed on 10070 recycled paper
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Inspection
Inspection
Inspection Item:
INSPECTION REPORT
Semi-Annual Effluent Monitoring Report (Module EM-01)
Location: DRC Office, Salt Lake City, Utah
Semi-Annual Effluent Monitoring Report for Reporting Period January 2008
through June 2008.
September 9 through September 22,2008
Kevin Carney
Inspection Dates:
Inspector(s):
Personnel Contacted:
Governing Documents:
o White Mesa Environmental Protection Manual
o RML UT1900479
o NRC Reg Guide 4.14, Radiological Effluent and Environmental Monitoring at Uranium
Mills
o 10CFR20 Table II of Appendix B
o Utah Rules R313, Environmental Quality, Radiation Control
Inspection Summarv
Inspection Module EM-01 was performed between September 9 and September 22,2008 by review of
the White Mesa Mill Semi-Annual Effluent Monitoring Report for Reporting Period January through
June 2008 which was received by the DRC on September 8, 2008.
The inspection evaluated adherence to the Mill's procedures and compared the effluent monitoring
results with 10CFR20limits and Regulatory Guide 4.14 recommendations.
Findines
Only minor discrepancies were noted:
o The report was received by the DRC on September 2,2008; a total of 64 days after July 1, 2008.
Utah Administrative Code R313-24-4, incorporating by reference 10CFR40.65(aX1), requires
the licensee to submit an effluent monitoring report within 60 days after January I and July I of
each year.
o Results for all l" and 2od quarter samples are below the calculated ECLs for Rn-222 at their
respective stations except for Station BIIV-2. This report covers the first half of 2008 and
therefore, the final yearly average cannot be calculated. Second quarter Rn-222 results for all
sample stations were reported as "below 0.4 pCiil-." Station BHV-2 has a calculated ECL of 0.34
pCitL. The sample result for the l't qtr was reported as 0.7 pCitL (2067o above the calculated
None
Page I of 2
ECL) and the 2"d qtr was reported as less than 0.4 pCitL. This result needs to be quantified
because the "less than 0.4 pCiI-" value is possibly higher than the 0.34 pCi[- ECL. There is no
way of knowing whether or not the result was below the ECL.
Recommended Corrective Actions
o Denison needs to again be reminded that the Semi-Annual Effluent Monitoring Reports are due
no later than 60 days after the end of the reporting period.
o Denison needs to quantify the results from Station BHV-2 forRn-222.
Follow-up Items
None.
Other Observations
o While reviewing the LLD values for stack effluent analyses, it was noted that he report stated,
"The matter of laboratory detection limits for stack sampling was addressed in recent
correspondence to the division [DRC] subsequent to these analyses. Consequently, future (post
July, 2008), data will be compliant with Regulatory Guide 4.14 guidance with regard to LLD's
for stack sample analyses." This is consistent with the schedule agreed to between Denison and
the DRC in the letter to Denison dated August 27, 2008. Therefore, no violation exists for this
inspection item.
o Annual soil samples were not included in the report because soil samples are collected by the
Mill staff during the third quarter of each year and are, therefore, not reported for this period.
o NRC Regulatory Guidp 4.14 rccommends that the yellowcake dryer and packaging stack be
sampled for U-Nat quarterly. However, the Mill did not sample the Yellowcake Dryer and
Baghouse for U-Nat during the second quarter due to the fact that the Mill was in a process
transition from alternate feed materials to unrefined ore processing and yellowcake drying was
not conducted during the quarter.
Closeout Meeting
N/A
Recommendations for Next Inspection
The second half, 2008, effluent report should be reviewed to ensure it includes actual numbers
when reporting RN-222 results for Station BHV-2 going back all four quarters of 2008.
The second half, 2008, effluent report should be reviewed to make sure it includes LLD values
for stack effluent analyses as per the letter to Denison dated August 27 ,2008.
Kevin Carney September 23.2008Prepared by:
(Print Name)(Date)
PageZ of 2
UTAH DIVISION OF RADIATION CONTROL
RML # UT1900479
DENISON MINES WHITE MESA MILL
INSPECTION MODULE EM-O 1
SEMI-ANNUAL EFFLUENT MONITORING REPORT
REPORTING PERIOD: January 2008 through June 2008
References: Utah Administrative Code R3l3-24-4; 10CFR40.65; Radioactive Materials License
U-t1900479; I0CFR20 Table II of Appendix B; NRC Regulatory Guide 4.14;2007
License Renewal Application
10CFR40.65(aXl) requires the licensee to submit a report within 60 days after January I and July I 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 l't or
July l't? (10cFR40.65(aXl))
Yes_No X
Comments:
Report received by DRC on September 2. 2008: a total of 64 days after Julv 1. 2008.
2. Were the stack samples analyzedfor U-nat, 23ofh, 226kaand 2lhb? (NRC Reg Guide 4.14)
Yes X No
Comments:
3- Were site boundary effluent
Guide 4.14)
Comments:
air samples analyzedfor U-nat, 23hh, 226Ra and 2'hbt (NRC Reg
Yes X No
Page I of6
4. Were soil samples analyzed for U-nat, 226Ra and '''Pb? (NRC Reg Guide 4.14)
Yes_No_N/A X
Comments:
Annual soil samples are collected by the Mill staff during the third quarter of each year and are.
therefore. not reported for this period.
5. Were vegetation samples analyzedfor 226Ra and 2r0Pb? (NRC Reg Guide 4.14)
Yes X No
Comments:
6. Were radon samples taken at Sample Stations BHV-I, BHV-2,
Reg Guide 4.14)
Comments:
BlfV-4, BHV-5 and BHV-6? (NRC
Yes X No
7. Were radon samples analyzed
Comments:
for222kn? (NRC Reg Guide 4.14)
Yes X No
8. Were the 222Rn results within the calculated ECL's for the yearly average results for 2007?
Yes X* No
Comments:
* Results for all 1't and 2'd qtr samples are below the calculated ECLs for Rn-222 at their respective
stations except for Station BHV-2. This report covers the first half of 2008 and therefore. the final yearly
average cannot be calculated. Second quarter Rn-222 results for all sample stations were reported as
"below 0.4 pCill." Station BHV-2 has a calculated ECL of 0.34 pCi/L. The sample result for the I't qtr
was reported as 0.7 pCil[- (2067o above the calculated ECL) and the 2'd qtr was reported as less than 0.4
pCill. This number needs to be quantified because the ECL is below the "less than 0.4 pCi/L" value.
There is no way of knowins whether or not the result was below the ECL.
Page 2 of 6
License Condition ll.2.D requires the licensee to utilize lower limits of detection in accordance with
Section 5 of the NRC Regulatory Guide 4.14, as amended, for analysis of effluent and environmental
samples.
9. Were lower limits of detection (LLD) for analysis of stack effluent samples l07o or less of the limits
found in 10CFR20 Table II of Appendix B for U-nat, "oTh, 226Ra and 'rhb? NRC Reg Guide 4.14)
I0CFR20 Table Il of Appendix B. ECL's:U-nat. .....ffi .... loro= 9.0E-rs prci/ml
"hh. ......2.08-ta pCi/ml. ..107o = 2.08-1s pCi/rnl
"6Ra. ......9.38-13 pCi/ml. .lOvo = 93814 pCi/ml
"hb. ......6.0E-13 pCiiml. ..lo7o = 6.0E-ra trrCi/ml
Yes
-
No X*-
Comments:
* The report states. "The matter of laboratory detection limits for stack sampling was addressed in recent
correspondence to the division IDRCI subsequent to these analyses. Consequently. future (post July.
2008). data will be compliant with Regulatory Guide 4.14 guidance with regard to LLD's for stack
sample analyses." This is consistent with the schedule asreed to between Denison and the DRC in the
letter to Denison dated August 27. 2008. Therefore. no violation exists for this inspection item.
10. Were lower limits of detection (LLD) for analysis of site boundary air effluents within the limits
listed in NRC Regulatory Guide 4.14 Section 5 for U-nat, "oTh,226Ra and "hb? (NRC Reg Guide
4.t4)
NRC Reeulatory Guide 4.14 Section 5 LLD values.(in air):
U-nat. .....1.0E-r6 pCi/ml
'3oTh. ......1.0E-r6 prci/ml
"uRa. .....1.0E 16 prci/ml2'hb. ......2.0E-rs pci/ml
Yes X No
Comments:
Page 3 of 6
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 lJ-nat, 226Raand 2r0Pb?
NRC Reeulatory Guide 4.14 Section 5 LLD values (in soil):
U-nat. ..2.08'1 pCitg226Ra. ...2.081 pcilg2rhb. .....2.0r.-7 pCitg
Yes_No_N/A X
Comments:
Annual soil samples are collected by the Mill staff during the third quarter of each lrear and are.
therefore. not reported for this period.
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 226Ra and ''oPb?
NRC Regulatory Guide 4.14 Section 5 LLD values (in veqetation):
"uRa. .....5.0E-8 pci/kg2'hb. ....1.0E-6 pciikg
Yes_No_N/A X
Comments:
The report states. "Regarding lower limits of detection, all analyses indicated detected concentrations
labove the Ree Guide 4.14 LLD limits for vegetationl."
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 "'Fin?
NRC Reeulatory Guide 4.14 Section 5 LLD values for radon:
"'Rn. ....2.0E-10prci/ml
Comments:
(0.zpcitt-)
Yes _ No _ N/A _X_
Page 4 of 6
White Mesa Environmental Protection Manual Section 1.4, STACK EMMISIONS MONITORING
PROCEDURES, sub-section 1.0, 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.t.1?
Quarterly samples at North Yellowcake Dryer and Yellowcake Baghouse for:
U-nat
Semi-annual samples at North Yellowcake Dryer and Yellowcake Baghouse for:
23OTh
,ruRa
2rhb
Yes X{< No
Comments:
The Mill did not sample the Yellowcake Dryer and Baghouse for U-Nat durins the second quarter due to
the fact that the Mill was in a process transition from alternate feed materials to unrefined ore processing
and yellowcake drying was not conducted during the quarter.
15. Were the site boundary effluent air sample results within applicable limits for U-nat, "oTh, 226Ra and
"hb? (locFR2o rabte II of Appendix B)
prCi/ml
prCi/ml
prCi/ml
prCi/ml
tn alr
in air
in air
in air
Yes X No
Comments:
Page 5 of 6
16. Did the results of the effluent monitoring for this reporting period achieve the site's ALARA
objective of 257o of the ECL's? (2007 License Renewal Application Vol. I Section 6.5; I0CFR20
Table II of Appendix B)
luutKZU laDIe lI ot ADp€rlcux rt, trlL s:U-nat. ..ffir.....257o=2.25E-ta pCi/ml in air
"hh. ......2.08-raprCi/ml in air. ....25Vo = 5.15E-rs prCi/ml in air
'2uka. ... ...9.3E r3 pCi/ml in air. ....257o = 2.33E-13 pCi/ml in air2'hb. ......6.0E-r3pCi/ml in air. ....257o = 1.50E-r3 pCi/ml in air
Yes X No
Comments:
Page 6 of 6
UTAH DIVISION OF RADIATION CONTROL
RML # UT1900479
DENISON MINES WHITE MESA MILL
INSPECTION MODULE EM-01
SEMI-ANNUAL EFFLUENT MONITORING REPORT
REPORTING PERIOD: January 2008 through June 2008
References: Utah Administrative Code R3l3-24-4; 10CFR40.65; Radioactive Materials License
I-IT1900479; 10CFR20 Table II of Appendix B; NRC Regulatory Guide 4.14;2007
License Renewal Application
10CFR40.65(a)(1) requires the licensee to submit a report within 60 days after January I and July I 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 l" or
July I't? (10CFR40.65(a)(1))
Yes No X
Comments:
Report received by DRC on September 2. 2008: a total of 64 days after July 1. 2008.
2. Were the stack samples analyzedfor U-nat,'3hh, 226Ra and "hb? NRC Reg Guide 4.14)
Yes X No
Comments:
3. Were site boundary effluent air samples analyzed
Guide 4.14)
Comments:
for U-nat,'30Th, 226Ra and 21hb? (NRC Reg
Yes X No_
Page 1 of6
4. Were soil samples analyzed for U-nat, 226Ra and "oPb? (NRC Reg Guide 4.14)
comments, "es -
No
-
N/A x
Annual soil samples are collected by the Mill staff during the third quarter of each year and are.
therefore. not reported for this period.
5. Were vegetation samples analyzedfor 226Ra and 21hb? NRC Reg Guide 4.14)
Yes X No
Comments:
6. Were radon samples taken at Sample Stations BHV-1, BHV-2,
Reg Guide 4.14)
Comments:
BHV-4, BI{V-5 and BHV-6? (NRC
Yes X No
7. Were radon
Comments:
samples analyzed for222Ftn? (NRC Reg Guide 4.14)
Yes X No
8. Were the 222Rn results within the calculated ECL's for the yearly average results for 2OO7?
Yes Xx No
Comments:
* Results for all I't and 2'd qtr samples are below the calculated ECLs for Rn-222 at their respective
stations except for Station BHV-2. This report covers the first half of 2008 and therefore. the final yearly
average cannot be calculated. Second quarter Rn-222 results for all sample stations were reported as
"below 0.4 pCi/L." Station BFIV-2 has a calculated ECL of 0.34 pCi/L.,The sample result for the I't qtr
was reported as 0.7 pCi/L (2067o above the calculated ECL\ and the 2nd qtr was reported as less than b.4
pCi/L. This number needs to be quantified because the ECL is below the "less than 0.4 pCi/L" value.
There is no way of knowing whether or not the result was below the ECL.
Page 2 of 6
License Condition ll.2.D requires the licensee to utilize lower limits of detection in accordance with
Section 5 of the NRC Regulatory Guide 4.14, as amended, for analysis of effluent and environmental
samples.
9. Were lower limits of detection (LLD) for analysis of stack effluent samples I0Vo or less of the limits
found in 10CFR20 Table II of Appendix B for U-nat, "oTh, 226Ra and 2thb? (NRC Reg Guide 4.14)
10CFR20 Ta
'3orh. ......2.08-14226Ra. ... ...9.3E-132rhb. ......6.0E-r3
prCi/ml. . l0Vo =pCi/ml. ..107o =pCi/ml. ..107o =pCi/ml. ..107o =
9.0E-rs trrCi/ml
z.OB-rs pCi/rnl
g3E-14 prCi/ml
6.0E-r4 prCi/ml
Yes
-
No X*
Comments:I The report states. "The matter of laboratory detection limits for stack sampling was addressed in recent
correspondence to the division IDRCI subsequent to these analyses. Consequently. future (post July,
2008). data will be compliant with Regulatory Guide 4.14 euidance with regard to LLD's for stack
sample analyses." This is consistent with the schedule agreed to between Denison and the DRC in the
letter to Denisbn dated August 27. 2008. Therefore. no violation exists for this inspection item.
10. Were lower limits of detection (LLD) for analysis of site boundary air effluents within the limits
listed in NRC Regulatory Guide 4.14 Section 5 for U-nat, "hh, 226Ra and "hb? NRC Reg Guide
4.14)
NRC Regulatory Guide 4.14 Section 5 LLD values (in air):
U-nat. ....... ...1.0E-r6 pCi/rnl23oTh. ...l.oE-r6 pci/ml
"uka. ....1.0E-r6 prci/ml
"oPb. ....2.0E-1s pci/ml
Yes X No
Comments:
Page 3 of 6
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 lJ-nat, 226Ra and ''hb?
NRC Regulatory Guide 4.14 Section 5 LLD values (in:soil):
U-nat. ...2.08'7 pCi/g226Ra. .....2.08-1 yCilg
Yes_No_N/A X
Comments:
Annual soil samples are collected by the Mill staff during the third quarter of each year and are.
therefore. not reported for this period.
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 226Ra and 21hb?
"'Ra. ....5.0E-" pCi/kg
"hb. ...1.0E-6 pCi/kg
Yes_No_N/A X
Comments:
The report states. "Regarding lower limits of detection. all analyses indicated detected concentrations
labove the Reg Guide 4.14 LLD limits for vegetationl."
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 "'Ftn?
(o.zpCitL)
Yes _ No _ NiA _X_
Comments:
pCi/ml
Page 4 of 6
White Mesa Environmental Protection Manual Section 1.4, STACK EMMISIONS MONITORING
PROCEDURES, sub-section 1.0, 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?
Quarterly samples at North Yellowcake Dryer and Yellowcake Baghouse for:
U-nat
Semi-annual samples at North Yellowcake Dryer and Yellowcake Baghouse for:
,rolh
216F.a
,rhb
Yes Xx No
Comments:
The Mill did not sample the Yellowcake Dryer and Baghouse for U-Nat durins the second quarter due to
the fact that the Mill was in a process transition from alternate feed materials to unrefined ore processing
and vellowcake drying was not conducted durinq the quarter.
15. Were the site boundary effluent air sample results within applicable limits for U-nat, "oTh, 226Ra and2'hb? (10cFR20 Table II of Appendix B)
10CFR20 Table II of Appendix B. ECL's:
U-nat. ......9.0E-r4 trrCi/ml in air
'3hh. ......2.08-14 pCi/ml in air
"6Ru. ......9.3E 13 pCi/ml in air21hb. ......6.0E 13 trrCi/ml in air
Yes X No
Comments:
Page 5 of 6
16. Did the results of the effluent monitoring for this reporting period achieve the site's ALARA
objective of 25Vo of the ECL's? (2007 License Renewal Application Vol. I Section 6.5; 10CFR20
Table II of Appendix B)
10CFR20 Table II of Appendix B. ECL's:
U-nat. .....q.08-'opCi/ml in air. ....257o =2.25E-ta pCi/ml in air
"*th. .....2.08'14 pCi/ml in air. ....257o = 5.15E-r5 prCi/ml in air2'6Ra. .....938-13 prCi/ml in air. ....25Vo =2.338-13 prCi/rnl in air
"hb. ......6.0E-r3pCi/ml in air. ....257o = 1.50E-r3 pCi/ml in air
Yes X No
Comments:
Page 6 of 6