DRC-2006-001181 - 0901a0688080cc72

NI LJC
Tel:[phone]
Fax [phone]
April 14,2006
VIA US MAIL
Mr. John Hultquist
LLW/Uranium Mills Section Manager
Division of Radiation Control
State of Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
,rrr*to*AL uRANruM (usA) coRPoRAroN
[e-mail]
www.intluranium.com
Re:Radioactive Materials License UT 1900479: Review of the July 1 through
December 31, 2004, Semi-Annual Environmental Monitoring Effluent Report
for the White Mesa Uranium Mill, lnternational Uranium (USA) Corporation
Dear Mr. Hultquist:
This letter is in response to your November 18,2005 letter, in which you provided the
results of your review of the July 1 through December 31, 2004, Semi-Annual
Environmental Monitoring Effluent Report for lnternational Uranium (USA) Corporation's
("lUSA's") White Mesa Uranium Mill (the "Mill').
ln your letter, you asked us to address the following two issues:
Environmental Radon
You have asked us to provide the "computational methods" that are used to demonstrate
compliance with the requirements of R313-15-302 (2) (a) (10 CFR 20.1302 (b) (1)), and
have requested that future Semi-Annual Effluent Monitoring reports include the data,
data calculations and a discussion of the results.
As indicated in your letter and in the Mill's Semi-Annual Effluent Reports, radon 222 is
not directly measured at the Mill's boundary. IUSA demonstrates compliance with the
limits and requirements of R313-15-301 by calculation, authorized by the United States
Nuclear Regulatory Commission, and contemplated by 10 CFR 20.1302 (b) (1) (R313-
15-302 (2) (a)).
This calculation is performed by use of the MILDOS code for estimating environmental
radiation doses for uranium recovery operations (Strenge and Bender 1981). The
MILDOS code was applied in 1991 in support of the Mill's 1997 license renewal and
more recently in 2003 by use of the updated MILDOS AREA code (Argonne 1998). The
analysis under both the MILDOS and MILDOS AREA codes assumed the Mill to be
I f050 Seventeenth St., Suite 950 I
! Oenver, Colorado, USA 80265 I
processing high grade Arizona Strip ores at full capacity, and calculated the
concentrations of radioactive dust and radon at individual receptor locations around the
Mill. Specifically, the modeling under these codes assumed the following conditions:
. 730,000 tons of ore per yearo Averoge grade of 0.53% U3O8o Operating 24 hrs/day for 340 days per yearo Yellowcake production of 4,380 tons of U3O8 per year (8.8 million lbs/yr).
Based on these conditions, the MILDOS and MILDOS AREA codes calculated the
combined total effective dose equivalent from both air particulate and radon at the
current nearest residence (approximately 1.2 miles north of the Mill), i.e., the individual
member of the public likely to receive the highest dose from Mill operations, to be below
the ALARA goal of '10 mrem/yr for air particulate alone as set out in R313-15-101(4).
Mill operations are constantly monitored to ensure that operating conditions do not
exceed the conditions assumed in the above calculations. lf conditions are within those
assumed above, radon has been calculated to be within regulatory limits. lf conditions
exceed those assumed above, then further evaluation will be performed in order to
ensure that doses to the public continue to be within regulatory limits. lt should be
noted that Mill operations to date have never exceeded the licensed conditions assumed
above. During 2004 and 2005, Mill operations did not come close to approaching these
assumed conditions.
Disclosure to the foregoing effect was included in the Semi-Annual Effluent Report for
the period July 1 - December 31, 2005, which was sent to the Executive Secretary on
March 3,2006.
Proposed Chanqe to Effluent Monitorinq Requirements
ln your letter, you have noted that, based upon a review of the many years of analytical
results of vegetative sampling, it is difficult to obtain sufficient vegetative material for
samples, especially during drought conditions, and you have proposed that IUSA
entertain the replacement of vegetation sampling with the addition of two new air-
monitoring stations.
We agree that it is very difficult if not impossible to make any meaningful comparisons of
vegetation sampling results, due to the different quality and quantity of samples that can
be obtained from period to period. By necessity, these samples typically are comprised
of varying proportions of different types of vegetation. This fact, along with the fact that
results to date have shown no upward trend in contamination, leads to the conclusion
that continued vegetation sampling provides little if any benefit. We agree that the Mill's
license should be amended to eliminate the need for vegetation sampling.
However, we do not believe that the removal of the requirement to conduct vegetation
sampling should be conditional upon adding two new air particulate monitoring stations,
as you have proposed. ln your Attachment 1 Proposed Air Sampling Station Locations
(a copy of which is enclosed with this letter), you propose two locations for new air
particulate monitoring stations, which you suggest would be located downwind from the
mill in the prevailing wind direction. However, as you can see from the enclosed wind
.II.JC
rose, which has been copied out of the Semr'-Annual Meteorological Monitoring Repoft,
July Through December 2005 And Annual Meteorological Summary Report For 2005
For lnternational Uranium Blanding, Utah, prepared by McVehil-Monnett Associates, lnc.
(February 2006), a copy of which is maintained at the Mill for inspection, the prevailing
wind direction is not southeast to northwest, as you have suggested. Rather, the
predominant wind direction is from the northeast to the southwest, followed by north to
south and northwest to southeast, which is in line with existing air particulate monitoring
stations BHV-4 and BHV-6. The predominant wind direction from the south is from the
southwest to the northeast, which is in line with BHV-1, located near the Mill's property
boundary, about 0.50 miles short of the nearest residence. Winds from the southeast to
the northwest, which you have suggested is the prevailing wind direction, are among the
lightest at the site.
We also enclose a map showing the current locations of the Mill's air particulate (BHV)
stations, with the predominant winds from the north (northeast to southwest) and from
the south (southwest to northeast) indicated thereon. The map includes BHV-6, which is
not indicated on your Attachment 1. BHV-6 was added in July 1999 at the request of the
White Mesa Ute community to provide added air particulate monitoring to the southeast
of the Mill site, in line with the White Mesa Ute community which is over 3 miles away in
that direction.
Since the existing air particulate monitoring stations are in the path of the prevailing
winds, IUSA does not believe there is a need to add any additional monitoring stations.
However, as mentioned above, IUSA does agree that there is no useful purpose in
continuing with vegetation sampling at the site, and proposes that that requirement be
deleted from the Mill's radioactive materials license.
lf you have any questions or require any further information, please give me a call.
cc: Ron F. Hochstein
Harold R. Roberts
David Turk
"IIJC
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OATAPERIOO:
2005
Jan I -Dec3lfl):00 - 23:fl1
COMPAI.IY NAME:
lntemational Uranium Corpor{ion
MODELER:
McVdril-llionnettAssociates
FIGURE 4-1CALM WINDS:
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TOTAL COUNT:
7178 hls-
AVG. wlND SPEED:
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OATE:
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PROJECT NO.:
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Figure 3.9 - 2
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