DRC-1997-001361 - 0901a06880ef6a0c

ENVIRONMENTAL ASSESSMENT
FOR RENEWAL OF
SOURCE MATERIAL LICENSE NO. SUA-1358
ENERGY FUELS NUCLEAR, INC.
WlllTE MESA URANIUM MILL
SAN JUAN COUNTY, UTAH
FEBRUARY 1997
DOCKET NO. 40-8681
U.S. Nuclear Regulatory Commission
Office of Nuclear Material Safety
and Safeguards
Division of Waste Management
TABLE OF CONTENTS
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1 .1 Background Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1. 2 Proposed Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.3 Review Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.3.1 Federal and State Authorities .......................... 4
1 .3.2 Basis of NRC Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2.0 SITE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2.1 Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2.2 Climate and Weather . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2.3 Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.3.1 Regional Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.3.2 Local G<Jology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.3.3 Seismicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.4 Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.4. 1 Surface Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.4.2 Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.5 Topography ........................ : . . . . . . . . . . . . . . . . . . 10
2.6 Demography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
2. 7 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0
3.0 PROCESS DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.1 Mill Circuit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.2 Mill Waste Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.0 EVALUATION OF ENVIRONMENTAL IMPACTS ....................... 14
4. 1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.2 Air Quality Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.3 Historical and Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.4 Impacts to Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 5
4.4. 1 Surface Water Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 5
4.4.2 Groundwater Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
4.5 Impacts on Ecological Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
4.5.1 Endangered Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 6
4.5.2 Wetlands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
4.6 Radiological Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
4.6.1 Operating Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
4.6.2 Radiological Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
4. 7 In-Plant Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
TABLE OF CONTENTS
(continued)
5.0 ENVIRONMENTAL EFFECTS OF ACCIDENTS ......................... 21
5.1 Failure of Chemical Storage Tanks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
5.2 Fires and Explosions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
5.3 Pipeline Failure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
5.4 Minor Pipe or Tank Leakage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
5.5 Tailings Impoundment System Acc:dents ..........•............. 22
6.0 RECLAMATION AND DECOMMISSIONING .......................... 23
7.0 ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
8.0 FINANCIAL SURETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
9.0 CONSULTATION WITH THE STATE OF UTAH ........................ 24
10.0 FINDING OF NO SIGNIFICANT IMPACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
11.0 CONCLUSION INCLUDING ENVIRONMENT.t.L LICENSE CONDITIONS ......• 26
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
LIST OF TABLES
2.1 Population Centers within 60 Kilometers of the
White Mesa Mill Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
LIST OF FIGURES
1 .1 Location of the White Mesa Uranium Mill . . . • . . . . . . . . . . • . . . . . . • . . . . . . 3
2.1 Generalized Stratigraphic Column for the White Mesa Site • • . . . . . . . . . . . . . . 7
3.1 Generalized· Flow Diagram of the Uranium Milling Process
for the White Mesa Mill . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2
4.1 White Mesa Point of Compliance Well Locations . . . . . . . . . . . . . • . . . . . . . . 20
ii
1 .0 INTRODUCTION
By application dated August 23, 1991, and supplements and revisions transmitted by
letters dated December 13 and 17, 1991, January 13 and April 7, 1992, Umetco Minerals
Corporation (Umetco) requested renewal of Source Material License SUA-1358, for
continued authorization of milling activities at the White Mesa Uranium Mill, which is
located in San Juan County, Utah. By letter dated March 29, 1994, Umetco requested
transfer of the license and a change in ownership of the mill to Energy Fuels Nuclear, Inc.
(EFN). On May 25, 1994, the license was amended to change designation of the licensee
to EFN. In the acquisition agreement between EFN and Umetco, EFN agreed to abide by
all commitments and representations made to tne U.S. Nuclear Regulatory Commission by
Umetco.
With this license renewal, NRC will be authorizing continued 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 experir1ents not presented in the application, 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 the license (excluding material
referenced in the Perfo•mance-Based License Condition), or impair the
licensee's ability to meet all applicable NRC regulations.
(2) 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 NRC's conclusions
regarding actions analyzed and selected in the EA.
Otherwise, the licensee is required to submit an application for a license
amendment from NRC. The licensee's determinations whether the above conditions
are satisfied will by 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 expertise in implementation of any changes; and
one member shall 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
1
sciences, and others. Temporary member. or permanent member other than the
three identified above, may be consultants.
The licer1see shall maintain records until license termination of any changes made
pursuant to the PBLC. These records shall include written 2afety 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 shall furnish an annual report to NRC that describes such changes, tests,
or experiments, including a summary of the safety and environmental evaluation of
each. 1.1 addition, the licensee shall annuai!y submit any pages of its license
application that have been revised to reflect changes made under this condition.
EFN has not yet submitted its standard operating procedures (SOPs) for operation of the
SERP. Therefore, NRC will require, by license condition, that EFN submit the SOPs for
NRC review by March 31, 1997, and until such time as NRC approves the SOPs, EFN will
not be authorized to implement the PBLC. EFN agreed to this license condition by
telephone conversations on December 31, 1996.
NRC's inspection function remains unchanged with the administration of Performance-
Based Licensing. Operational changes, regulatory commitments, and recordkeepif'g
requirements implemented by EFN through the PBLC are subject to NRC inspection and
possible enforcement actions.
1.1 Background Information
By letter dated February 6, 1978, Energy Fuels Nuclear, Inc. (EFN) applied to NRC for a
source and byproduct material license to construct and operate the White Mesa uranium
milling facility located approximately 9.5 kilometers (km) (6 miles) south of Blanding, Utah
(see Figure 1 . 1). As a result of studies conducted for the Final Environmental Statement
(FES) (NUREG-0556; NRC, 1979), NRC concluded that mitigative measures proposed and
implemented by the applicant would reduce any adverse environmental impacts associated
with the White Mesa project to acceptable levels. Following issuance of the FES in May
1979 and the staff's Safety Evaluation Report (SER) in August 1979, NRC issued Source
Material License SUA-1358 on August 7, 1979.
SUA-1358 was renewed in 1985, and was due to expire on September 23, 1991.
As stated above, Umetco submitted a license renewal application by letter dated August
23, 1991, and NRC notified Umetco that the license was in timely renewal by letter dated
November 7, 1991 .
Source Material License SUA-1358 and ownership of the White Mesa mill were transferred
from Umetco to EFN in May 1994. The mill was operated on a continual basis from May
1980 until February 1 983, and then intermittently from October 1985 to the present time.
2
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Figure 1.1 Location of the White Mesa Uranium Mill
3
1. 2 Proposed Action
The proposed action is to renew SUA-1358 for operation of the White Mesa mill at a
maximum production rate of 4380 tons of yellowcak<> per year. Additionally, EFN will be
authorized, by license condition, to possess byproduct material in the form of uranium
waste tailings and other uranium byproduct waste generated by ll~ milling operations
authomed by the renewal license.
1. 3 Review Scope
1.3. i Federal and State Authorities
NRC source material licenses are issued under Title 10, Code of Federal Regulations,
Part 40 (10 CFR Part 40). As stated in 10 CFR 40.3, "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 material or residual radioactive material as
defined in this part or any source material after removal from its place of deposit in nature,
unless authorized in a specific or general license issued by the Commission ... " Source
material is defined under 10 CFR 40.4 as ( 11 L'raniu:n or thorium, or any combination
thereof, in any physical or chemical form, or (2) ores which contain by weight 0.05
percent or more of uranium, thorium, or any combination thereof.
In addition, the Uranium Mill Tailings Radiation Control Act of .1973, as amended
(UMTRCAI, requires persons who conduct uranium source material operations to obtain a
byproduct material license to own, use, or possess tailings and wastes generated by the
operations (including above-ground wastes from in situ operations). This EA has been
prepared under 1 0 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 (NEPAl. In accordance with 10 CFR
Part 51, an EA serves to (a) briefly provide sufficient evidence and analysis for determining
whether to prepare an environmental impact statement (EIS) or a finding of no significant
impact (fONSII, (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.
Impacts from the commercial scale operation of the site were previously evaluated in the
FES (NRC, 1979). The EA and SEA for the previous renewal of SUA-1358 were issued by
the NRC staff on September 26, 1985.
A new SEA will accompany this EA. In preparing these two documents, the staff will
evaluate the potential impacts associated with the continued commercial operation of
the White Mesa mill. Should the NRC 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 EFN.
The State of Utah Department of Environmental Quality (UDEQ) administers and
implements the State's rules and regulations.
4
1.3.2 Basis of NRC Review
The NRC, Division of Waste Management, staff has assessed the environmental and safety
impacts associated with the renewal of EFN's commercial license for the White Mesa mill,
and documented the results of the assessment in this report. Tre staff performed this
appraisal in accordance with the requirements of 10 CFR Part 51.
In conducting its assessment, the staff considered the following:
• lnforrration contained in the previous en·;'ronmental evaluations of the White Mesa
project (i.e., the 1979 FES and the 1985 EA);
• Information contained in EFN's August 23, 1991, renewal application, and
supplementary information submitted by letters dated December 13, 1991; July 28,
October 5, and November 22, 1994; and December 13, 1996;
• Information contained in EFN amendment requests, NRC approvals of such
requests, and land use and environmental monitoring reports transmitted
subsequent to August 23, 1991;
• Personal communications with EFN and UDEQ; and
• Information derived from NRC staff site visits and inspections of the White Mesa
mill site.
2.0 SITE DESCRIPTION
2.1 Location
The project site is located in central San Juan County, Utah, approximately 9.5 km
(6 miles) south of the city of Blanding. The mill can be reached by taking a private road
for approximately 0.5 miles west of Utah State Highway 191.
All operations to be authorized by the renewed license will be conducted within the
confines of the existing site boundary. The project site consists of 1971 hectares (ha)
(4871 acres) of private land together with mill site claims. The mill site itself occupies
approximately 20 ha (50 acres) and the tailings disposal cells another 182 ha (450 acres).
2.2 Climate and Weather
Southeastern Utah's climate is classified as arid, with an average annual precipitation of
30 centimeters (em) (12 inches), 75 percent of which falls as rain. Two separate rainfall
seasons can be distinguished in the area, with the first occurring during late summer and
early fall, and the second between the months of December and March. Temperatures in
summer normally range from 4 • C (40 ·F) to 32 • C (90 ·F), while winter temperatures range
between -9·c (15.F) end 13·c (55.F). The yearly normal mean temperature is 9·c
(50. F).
5
The mean annual relative humidity is 44 percent and is normally highest in January and
lowest in July. The average evaporation rate for the period from May through October is
118.8 em (46.8 inches), with the greatest evaporation occurring normally during the
month of July. The dominant wind directions are from the north to northeast
(approximately 30 percent of the time) and out of the south to southwest (approximately
25 percent of the time). Wind speeds are generally less than 15 miles per hour (mph),
with winds faster than 25 mph occurring less than one percent of the time.
2.3 Geology
2.3.1 Regional Geology
The project site lies within a region designated as the Canyon Lands section of the
Colorado Plateau physiographic province. Elevations in the region range from
approximately 923 meters (3000 feet) in the bottom of canyons to over 3385 m
(11 ,000 ftl among the peaks of the Henry, Abajo and La Sal Mountains to the northeast.
The average elevation for the area, excluding deeper canyons and isolated mountain peaks,
is about 1524 m (5000 ft).
The sedimentary rocks exposed in southeastern Utah have a total thickness of
approximately 1828 to 2133 m (6000 to 7000 ft). These sedimentary units range in age
from Pennsylvanian to Late Cretaceous; older rock units which underlie those of
Pennsylvanian age are not exposed in tl,e project area.
Structural features in the project area have been divided into three main categories on the
basis of origin or mechanism of the stress that created the structure. These categories
are: (1) structures relatf!d to large-scale regional uplifting or downwarping directly related
to movements in the basement complex (the Monument Uplift and the Blanding Basin);
(2) structures due to diapiric deformation of tnick sequences of evaporite deposits, salt
plugs and salt anticlines (the Paradox Fold and Fault Belt); and (3) structures formed due to
magmatic intrusions (the Abajo Mountains).
A generalized stratigraphic column for the region is provided as Figure 2.1. The
Summerville Formation, Entrada Sandstone, and Navajo Sandstone are the deepest units of
concern encountered at the site.
2.3.2 Local Geology
The White Mesa mill site is located on the western edge of the Blanding Basin, sometimes
referred to as the Great Sage Plain, lying east of the north/south-trending Monument
Uplift, south of the Abajo Mountains and adjacent to the northwest-trending Paradox Fold
and Fault Belt. The Abajo Mountains are the most prominent topographic feature in the
region, rising over 1 219 m (4000 ft) above the surface of the plain. The lithology of the
immediate area is composed of thousands of feet of multi-colored pre-Tertiary age marine
and non-marine sedimentary rocks. Erosion on the regionally-uplifted sedimentary strata
has produced an array of spectacularly eroded canyons and mesas for which the area is
famous.
6
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Figure 2.1 Generalized Stratigraphic Column for the White Mesa Mill Site
(after Titan, 1994b)
7
The mill rests on alluvial windblown silt and sand which covers sandstones and shales of
Jurassic and Cretaceous age. The surface of the mesa is nearly flat, with a surface relief
of 30. m (98 ft). The maximum relief between White Mesa and the adjacent Cottonwood
Canyon is about 230 m (750 ft).
2.3.3 Seismicity
The historical record of seismicity for the region is about 150 years old. Since 1853,
approximately 1200 seismic events have been recorded within 322 km (200 miles) of the
project area. The nearest of these events occurred in the Glen Canyon Recreation Area,
63 km (38 miles) away, and at a location approxi.r1ately 88 km (53 miles) to the northeast
of the site. An intensity V (Modified Mercalli Scale) event occurred on August 29, 1941,
just east of Durango, Colorado, 153 km (99 miles) away. Based on the region's seismic
history, the probability of a major damaging earthquake occurring at or near the site is
remote.
2.4 Water Resources
2.4. 1 Surface Water
Runoff in the project area is directed by the general surface topography either we$tward
into Westwater Creek, eastward into Corral Creek, or to the south into an unnamed branch
of Cottonwood Wash. Low average annual rainfall, local soil characteristics, and the
porous nature of local stream channels cause these streams to flow intermittently in
response to local snowmelt and rainstorms. These same conditions, in concert with the
gentle slope of White Mesa, also contribute to the lack of perennial surface waters on or in
the vicinity of the site.
North of the site, a small drainage area of approximately 25 ha (62 acres) provides limited
surface runoff to the site. Total runoff from the site is estimated to be less than 1.3 em
(0.5 inches) annually.
The San Juan River, a major tributary to the upper Colorado River, is located approximately
29 km ( 18 miles) south of the mill site.
2.4.2 Groundwater
The Dakota Sandstone is the rock unit that underlies the mill and the tailings disposal cells.
At the mill site, this formation extends to depths of 13 to 20 m (43 to 66 feet) below the
surface, and it is typically composed of sandstones with random discontinuous shale and
siltstone layers. Beneath the site, the Dakota Sandstone is very dry to dry, with an
average volumetric water content of 3 percent. Its porosity is predominately intergranular,
ranging from 13.4 to 26.0 percent, with an average value of 19.0 percent. Measured
saturated hydraulic conductivities from packer tests range from 9.1 E-04 to 2. 71-E06
centimeters per second (em/sec), with a geometric mean of 3.89E-05 em/sec, (Titan,
1994b)
8
The underlying Burro Canyon Formation is similar to the Dakota Sandstone. Composed of
very fine-to coarse-grained sandstones, with discontinuous random shales, the Burro
Canyon becomes argillaceous near its lower contact with the bentonitic mudstones and
claystones of the Brushy Basin Member (Morrison Formation). Beneath the site,
groundwater is first encountered at this contact as a zone of perched water. This zone
occurs at depths of 22 to 33 m (73 to 109 feet) below the surface, and its thickness
varies across the project area, from 17 m (55 feet) in the northern section to less than
1.5 m (5 feet) in the southern area. Potentiometric maps suggest that the predominant
direction of groundwater flow in the saturated portion of the Burro Canyon Formation
benP.ath the site is to the south-southwest (Titan. 1994b).
The Burro Canyon outcrops along the walls of Westwater Cr!3ek Canyon and Corral
Canyon, and groundwater from the perched zone discharges into these canyons, as
evidenced by the occurrence of springs and productive vegetation patterns. Based on the
results of 12 pumping/recovery tests and 30 packer tests, the hydraulic conductivity of
the saturated portion of the Burro Canyon Formation ranges from 1.4E-06 to 1.2E-03
em/sec, with a geometric mean of 1.0E-05 em/sec (Titan, 1994b). Water yields at the
test wells were very low, typically less than 0.5 gallons per minute (gpm), although
slightly higher yields (on the order of 2 gpm) may be possible in localized zones of higher
permeability, resulting from lenses of coarser material or localized fracturing.
The quality of the Burro Canyon perched water be'1eath and downgradient from the site is
poor and extremely variable. The conc:entrations of total dissolved solids (TDS) measured
in water sampled from upgradient and downgradient wells range between approximately
1000 and 5000 milligrams per liter (mg/1). Sulfate concentrations measured in three
upgradient wells varied between 670 and 1740 mg/1.
As stated above, the Brushy Basin Member of the Morrison Formation is composed of
bentonitic mudstones and claystones. In the region, the thickness of this unit ranges from
60 to 135 m (200 to 450 feet). A tote' of approximately 365 m (1200 feet) of
unsaturated, low permeability shales and poorly sorted sands of the Morrison and
Summerville Formations separate the Brushy Basin from the underlying Entrada and Navajo
Sandstones.
The Entrada and Navajo Sandstones are prolific aquifers beneath and in the vicinity of the
site. Water wells at the site are screened in both of these units, and therefore, for the
purposes of this discussion, they will be treated as a single aquifer. Water in the
Entrada/Navajo Aquifer is under artesian pressure, rising 245 to 275 m (800 to 900 feet)
above the top of the Entrada's contact with the overlying Summerville Formation; static
water levels are 120 to 1 50 m (400 to 500 feet) below ground surface. Within the region,
the aquifer is capable of yielding domestic quality water at rates of 150 to 225 gpm, and
for that reason, it serves as the source of water for the mill. Additionally, two domestic
water supply wells drawing from the Entrada/Navajo Aquifer are located 4. 5 miles
southeast of the mill site on the Ute Indian Reservation.
9
2.5 Topography
The mill site is located on a slightly tilted platform that, from the air, appears similar to a
peninsula, as it is surrounded by steep canyons and washes and is connected to the Abajo
Mountains to the north by a narrow neck of land. On the mesa, the topography is
relatively flat, sloping at less than one percent to the south and nearly horizontal from eas:
to west.
2.6 Demography
According to the 1 990 census, the population density of San Juan County, in which the
mill is located, is 0.6 persons per square kilometer (1.6 individuals per square mile); by
comparison, the statewide density is greater than 8 individuals per square kilometer
(20 persons per square mile). The town of Blanding, Utah, approximately 9.5 km (6 miles)
north of the mill, is the largest population center near the project with 3162 persons.
Approximately 5.6 km (3.5 miles) southeast of the project site is the White Mesa
Reservation, a community of approximately 320 Ute Mountain Indians, although only an
estimated 60 to 75 individuals live within 8 km (5 miles) of the site. The nearest resident
is located approximately 5 km (3 miles) to the northeast of the mill, which is in the
prevailing wind direction. Table 2.1 provides population centers located within 60 km
(37 miles) of the mill site.
2.7 land Use
Approximately 60% of San Juan County is Federally-owned land administered by the U.S.
Bureau of land Management, the National Park Service, and the U.S. Forest Service.
Primary land uses includes livestock grazing, wildlife range, recreation, and exploration for
minerals, oil, and gas. A quarter of the county is Indian land owned either by the Navajo
Nation or the Ute Tribe. The area within 8 km (5 miles) of the project site is predominantly
range land owned by residents of Blanding. The White Mesa mill site itself encompasses
approximately 202 ha (500 acres).
A more detailed discussion of land use at the White Mesa site, in surrounding areas, and in
southeastern Utah, is presented in the FES prepared for the project (NRC, 1979). Results
of archeological studies conducted at the site and in the surrounding areas as part of the
original environmental report are also documented in the FES.
EFN 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,
NRC will drop this condition from the license. EFN is already required to comply with
annual dose limits to individual members of the public (1 0 CFR 20.1301), and its
demonstrations of compliance address observed changes in land use.
10
Table 2.1
Population Centers within 60 Kilometers of the White Mesa Mill Site
(modified from Umetco, 1991)
Distance from Distance from
Town 1990 Population Site (km)· Site (miles)
White Mesa, UT 320' 6.4 4
(unincorporated)
Blanding, UT 3162 9.5 6
Bluff, UT 847 25 15
Montezuma Creek, UT 1223 32 20
Monticello, UT 1806 43 27
Aneth, UT 991 43 27
Mexican Hat, UT 495 48 30
Eastland/Ucolo, UT 249 51 32
Dove Creek, CO 623 59 37
Approximate distance from mill site by air
' Approximate population
3.0 PROCESS DESCRIPTION
A simplified flow diagram of the White Mesa mill circuit is provided as Figure 3.1.
3.1 Mill Circuit
Ore and other feed material is delivered to the site by truck. Once at the site, following
weighing of the truck, an ore load is dumped at a specific location on the ore pad.
Preliminary analyses are then conducted, and the moisture content of the ore determined.
Loaders or trucks then haul stockpiled ore to the ore grizzly.
A semi-autogenous grinding (SAG) mill is used to grind the ore, and the resultant slurry is
pumped to two mechanically-agitated storage tanks. Material from these tanks is pumped
to a two-stage acid leach process, in which sulfuric acid, an oxidant, and steam are used
to leach the ore slurry.
Next, a multi-staged counter-current decantation (CCDl washing 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., the first) CCD thickener tank is sent
to the two-stage leach process mentioned above, the overflow of which is clarified prior to
11
Ore Stockpiles
Atmosphere •
:---_ _y_ ___ ~
I 1-------.! H2o~-~
j
l
I i I
I
Crushing and
Grinding Circuit
·I
Pre leach
l
Thickening
I Dust Collection
[+--------;
I
.I
Pregnant Leach
Solution
I
Barre
Organ
n
ic
Pregnar
Strip
I I
I
.t
Organic
I
Solvent
Extraction
Stripping
1 .. NH3 ~ Prec1p1talion
p regnant
Organic
I
Barren
Strip
Acid
Leaching
i H2S04
!+---NaCI03
Steam · and ~---T-hi_c~ke_n_i_n_g _ _j
ceo
Washing
Circuit
~
Tailings Impoundment I
Barren
Leach
• Optional
to
Vanadium
Recovery
I
Atmosphere
Drying
I
l
Yellowcake
Product
Figure 3.1 Generalized Flow Diagram of the Uranium Milling Process
for the White Mesa Mill (modified from NRC, 1979)
12
solvent extraction. The slurry at the bottom of the tank is progressively transferred
"down" the circuit. From the final thickener tank, it is sampled and then pumped to the
tailings retention area.
Meanwhile, the uranium-bearing liquid is transferred to a solvent extraction process which
is carried out in a series of mixing and settling vessels. Amine-type compounds and
kerosene are added to dissolve the uranyl ions from the leach solution. The solution is
then stripped of uranium by acidification and pumped to a precipitation tank.
Within the precipitation tank, the pregnant solution is neutralized and yellowcake is settled.
The yellowcake is next transferred to a centrifuge where it is further concentrated. The
thickened yellowcake slurry is transferred to either of two propane gas/diesel-fired
multiple-hearth dryers. Both dryers feed to a common packaging hopper and drum filling
station, where the dried yellowcake is powdered and packaged in 55-gallon drums.
These drying, powdering, and packaging operations are performed within an enclosure
under negative pressure, with wet scrubbers used to collect airborne particulates. During
the entire route of production, concrete curbing and sumps are designed to intercept any
spillage and return it to the appropriate process circuit.
3.2 Mill Waste Disposal
Mill tailings are deposited within tailin9s cells located at the facility. The tailings, along
with liquid waste, are slurried by pipeline to the impoundment system, which consists of a
series of synthetically-lined cells that are designed for phased construction and
reclamation. Cells are presently designated 1-1, 2, 3, and 4A (the higher the number refers
to the more recently constructed cell).
The four tailings cells are designed to accepl the quantity of waste to be produced during
a 15-year operating period, at an ore processing rate of 2000 tons per day. The tailings
and evaporation cells are designed and constructed as partially below-grade disposal
facilities. Any change in the maximum operational freeboard and tonnage limits for the
cells, as specified in the renewal application, will continue to require NRC approval due to
the safety and environmental concerns involved. EFN also implements procedures to
minimize dispersal of blowing tailings.
Each cell has a leak detection system designed to provide an early warning of catastrophic
liner failure. These systems are checked daily as part of the tailings disposal system
monitoring program, which also includes checks on slurry pipeline connections and wear,
cell fluid levels, liner integrity, and the effectiveness of dust minimization methods. Each
tailings cell embankment is also regularly monitored for stability and the results reported to
NRC. Tailings Cell 4A was designed, constructed, and placed into operation in 1990,
according to an NRC-approved plan and in accordance with U.S. Environmental Protection
Agency (EPA) regulations.
As stated above, all production spillage or wastes, such as tailings and process water, are
either returned to the mill circuit or sent by pipeline to the appropriate tailings
impoundment, while sanitary wastes are disposed of separately in a State-approved
13
seepage system. This is currently required by license condition and will continue to be so
required.
EFN will continue to be required to dispose of mill-generated waste considered as 11 e.(2)
byproduct <naterial (e.g., contaminated equipment and parts) within Tailings Cell'2, in
accordance with its procedure, "Radioactive Contaminated Waste Disposal," amended as
noted in NRC's approval letter of August 1, 1995. EFN also disposes of uncontaminated
wastes in Cell 2.
EFN is authorized currently to accept byproduct ·.1aterial from licensed in-situ leach
facilities for disposal in Tailings Cell 3. Conditions of this authorization will continue
to be specified by license condition. Environmental impacts associated with this disposal
were assessed as part of the NRC licensing action approving EFN's amendment request.
4.0 EVALUATION OF ENVIRONMENTAL IMPACTS
4.1 Introduction
Operation of the mill will directly use about 202 ha (500 acres) of land for mill buildings
and tailings cells. During operation, effluent releases (e.g., fugitive dust, hydrocarbons,
radionuclides) will be maintained at levels as low as is reasonably achievable. Tailings,
which are produced in large quantities and contained in lined disposa! cells, will be
reclaimed at the end of the project, in accordance with an NRC-approved reclamation plan.
Mill operations should not, under proper operating conditions, have a significant impact on
air and water quality. Environmental impacts associated with the original construction of
the facility were assessed in the FES (NRC, 1979).
4.2 Air Quality Impacts
During operation of the mill, hydrocarbon release from the boiler, gaseous emissions from
process chemicals, and fugitive dust and radon emissions from the ore pads will occur.
Dust and radon levels will be controlled through spraying, while the other gaseous
emissions should not exceed regulatory standards. Other emissions will be discussed in
Section 4.6, "Radiological Impacts."
4.3 Historical and Cultural Resources
A historical survey was conducted in the project vicinity as part of the initial license
application, and six historical sites were identified. However, none of these sites is in an
area which will be affected by operations at the mill.
Archaeological surveys of the project site conducted in 1977 and 1979, identified
1 21 prehistoric sites which are affiliated with the San Juan Anasazi Indians who occupied
this area of Utah from about 0 A.D. to 1300 A.D. As a result of the archaeological
findings, a Memorandum of Agreement (MOA) between NRC, the Utah State Historic
Preservation Officer, and the Advisory Council on Historic Preservation was established to
specify requirements necessary to minimize adverse impacts to the previously identified
archaeological sites.
14
The requirements were incorporated into SUA-1358 when initially issued. The
requirements have been modified following subsequent amendments to the MOA. The
most recent modifications were incorporated into SUA-1358 through the issuance of a
license amendment on May 11, 1983. These requirements will be included in the renewed
license.
The licensee will also be required to conduct, as a minimum, an archaeological and
historical artifact survey of areas not previously surveyed prior to their disturbance.
4.4 Impact$ to Water Resources
4.4. 1 Surlace Water Impacts
Continued operation of the mill should have negligible impacts on surface waters on and in
the vicinity of the project site, because ( 1) mill effluents are not discharged to local surface
waters; (2) sanitary wastes are discharged to State-approved leach fields; and (3) tailings
from mill operations are discharged by pipeline to partially below-grade, lined
impoundments. In additior.. 3S noted above, EFN has committed to regular inspections of
the tailings disposal system, including disposal cell embankments.
4.4.2 Groundwater Impacts
For the following reasons, the NRC staff does not believe that groundwater beneath or in
the vicinity of the site will be adversely impacted by continued operation of the mill:
1. Four tailings cell have been constructed to accept tailings slurry and solutions and.
other approved wastes. Each of the cells has been designed and constructed to
minimize seepage of tailings fluids into the subsurface. Cells 1-1, 2, and 3 have a
6-inch compacted sandstone bedding layer, an overlying synthetic liner, and a leak
detection system consisting of: ( 1) a 1 2-inch thick compacted sand layer on the
upstream face of the downstream retention dike, (2) a 3-inch diameter perforated
pipe installed at the toe of the sand layer, and connecting to (3) a 12-inch diameter
access riser pipe.
Cell 4A is constructed with a 12-inch thick clay base layer overlain by a synthetic
liner covering both the bottom and side slopes of the cell. A leak detection system
is located beneath the synthetic liner. This system is composed of 4-inch
perforated pipes embedded in granular materials in synthetically-lined trenches
excavated into the clay base. These pipes are connected in turn to a 12-inch
diameter access pipe.
As part of EFN's inspection procedures for the tailings management system, daily
measurements are taken of liquid levels in the leak detection system for each cell.
If specific changes in these levels are recorded, site management is notified
immediately. Quarterly sampling of a number of monitor wells completed in the
Burro Canyon perched water zone and located around and among the tailings cells,
is also required by EFN's inspection procedures. Further discussion of the
licensee's groundwater detection monitoring program is provided in Section 4.6.1.
15
2. Based on estimates of net infiltration and volumetric moisture content of the vadose
zone (i.e., the unsaturated portions of the Dakota and Burro Canyon Sandstones)
and an average thickness of the vadose zone, EFN estimates that it would take 50
to 1 50 years for moisture to travel from the bottom of a tailings disposal cell to the
perched water zone, depending on the extent of failure of the tailings disposal cell
liner (Titan, 1994). Tailings disposal cell seepage traveling along joints or fractures
in the Dakota Sandstone could potentially reduce this travel time to a few days or
months. Jointing is common in the Dakota along the mesa's rim; however, coring
studies to date have revealed no evidence of continuous fractures or joints with
depth. Once in the saturated portion of the Burro Canyon, the travel time for
seepage from a tailings impoundment to the downgradient edge of the mesa has
been estimated at 8900 to 13,400 years (Titan, 1994b).
3. The Morrison and Summerville Formations form an approximately 1 200-foot thick
low-permeability barrier to ground water flow separating the Entrada/Navajo Aquifer
from the Burro Canyon perched zone. The NRC staff considers that this barrier
makes it •Jnlikely that constituents from the tailings disposal cells would ever
impact water quality of this aquifer.
4. 5 Impacts on Ecological Systems
4.5.1 Endangered Species
In the vicinity of the site, four animal species classified as either endangered or threatened
(i.e., the bald eagle (Haliaeetus leucocephalus), the American peregrine falcon (Falco
peregrinus anatum), the black-footed ferret (Mustela nigripes), and the Southwestern
willuN flycatcher (Empidonax trai!lii extimus)) could occur. While the ranges of the bald
eagle, peregrine falcon, and willow flycatcher encompass the project area, their likelihood
of utilizing the site is extremely low. The black-footed ferret has not been seen in Utah
since 1952 and is not expected to occur any longer in the area.
No populations of fish are present on the project site, nor are any known to exist in the
immediate area of the site. Four species of fish designated as endangered or threatened
occur in the San Juan River 29 km ( 18 miles) south of the site. There are no discharges of
mill effluents to surface waters, and therefore, no impacts are expected for the San Juan
River due to operations of the White Mesa mill.
Currently, no designated endangered plant species occur on or near the plant site.
4.5.2 Wetlands
No true wetlands exist on the project site. Two small catch basins approximately 18 m
(60 feet) in diameter, fill for brief times in the fall or spring if heavy rainfall occurs. These
catch basins are the only "aquatic" habitat found on the project site, and they more
properly represent terrestrial environments. No wetland plants have been found in these
basins.
16
4.6 Radiological Impacts
4. 6. 1 Operating Data
Sampling results discussed in this section were provided by the licensee in accordance
with the requirements of 10 CFR 40.65, as modified by license conditions currently in
SUA-1358. The renewal license will retain these same license conditions, which address:
( 1) stack sampling, (2) surface water sampling, (3) groundwater sampling, (4) lower limits
of detection, and (5) inspections and calibrations of the critical orifice assembly.
a, Air Particulate Sampling
EFN's air particulate monitoring program consists of continuous environmental
sampling stations at four locations, three of which are located at the site boundary,
and one at the nearest residence, which is 5 km (3 miles) northeast of the site.
Samples are collected quarterly and analyzed for U-nat, Th-230, Ra-226, and
Pb-21 0.
Data collected during continuous mill operations in 1989-90. and again in 1995-96,
indicated that measured concentrations of U-nat, Th-230, Ra-226, and Pb-21 0
were small fractions (i.e .. less than ten percent) of the appropriate 10 CFR Part 20
limits for unrestricted areas. Cuncentrations of these. radionuclides measured at the
BHV-5 sampling station tended to be elevated during mill operations due to
increased dust from the ore stockpile and the increased traffic around the ore
stockpile and mill areas.
b. Stack Effluent Sampling
During operations, stack sampling is performed quarterly on the yellowcake stacks
(i.e .. the dryer and baghouse stacks) and semi-annually on the grizzly and demister
stacks. Stack samples are analyzed for U-nat, Th-230, Ra-226, and Pb-21 0.
Measurements performed in 1989 and 1995-96 indicate that emissions of these
radionuclides have been consistently low. In addition, measurements of product
loss through the yellowcake stacks have been well below levels originally predicted
in the FES for the facility (NRC, 1979).
c. Radon Gas Monitoring
Environmental monitoring for radon gas using thermoluminescent dosimeters (TLDs)
was discontinued with NRC approval in September 1995. The licensee will
demonstrate compliance with the 10 CFR Part 20 annual dose limit of 100 mrem
through MILDOS-AREA modeling calculations.
The licensee will still be required to keep radon-222 emissions from an existing mill
tailings pile from exceeding 20 pCi/m2-s of radon-222, in accordance with the
requirements of 40 CFR 61.252.
17
d. Direct Gamma Exposure
Direct radiation exposure measurements are made quarterly at the four air
particulate monitoring stations. The greatest differentiill between measured
exposure rate and background for the same time period sir.ce 1989 was
8.6 mR/qtr. However, measured exposure rates are normally at ot slightly above or
below background rates.
e. Surface Water Sampling
Surface water monitoring is conducted at two sampling locations, known as
Westwater Canyon and Cottonwood Creek, adjacent to the mill. Grab samples are
collected annually from Westwater Canyon and quarterly from Cottonwood Creek.
The samples are analyzed for total and dissolved U-nat, Ra-226, and Th-230, as
well as for pH, specific conductivity, temperature, total dissolved and suspended
solids, gross alpha concentrations. Measured values for these consituents and
parameters over the period of mill operations since 1980 have been consistently
low.
f. Ground Water Sampling
Groundwater monitoring samples have been collected quarterly from seven
monitoring wells and the culinary water well. These samples were analyzed for pH,
specific conductance, chlorides, sulfates, TDS, and U-nat, and water level·
measurements were also taken. Groundwater samples were analyzed semiannually
for arsenic, selenium, sodium, Ra-226, Th-230, and Pb-21 0. No trends ·are
apparent from measurements taken since 1985.
With this license renewal, EFN proposed that groundwater detection monitoring be
conducted in accordance with the program described in the document entitled,
"Points of Compliance, White Mesa Uranium Mill," submitted by letter dated-
October 5, 1994. Under this program, samples will be collected quarterly from five
"point of compliance" (POC) wells, completed in the Burro Canyon Formation (wells
WMMW-5, -11, -12, -14, and -15) (see Figure 4. 1). These samples will be
analyzed for chloride, potassium, and nickel, and water level measurements also
will be taken. EFN selected these indicator parameters, because the concentrations
of these species are significantly higher in the tailings pond fluid than in the perched
water of the Burro Canyon, and they are representative of both anionic and cationic
species.
The data will be analyzed using the Shewhart-Cusum control chart technique.
These charts have been developed on a well-by-well basis, with a separate control
chart for each of the four indicator parameters. If limits on the control charts are
exceeded for a parameter at a well, a program of confirmatory sampling will
commence. This will involve monthly sampling for six months; a separate analysis-
of-variance technique will be employed to determine whether there is a significant
difference between these samples and those collected prior to the confirmatory
18
sampling program. If the data are significantly different, then a corrective action
plan will be developed.
The NRC staff found the proposed groundwater detection monitoring program to be
acceptable, with modifications as follows: (1) that well WMMW-17 be included in
the sampling program; and (2) that uranium be added as an indicator parameter to
be analyzed for. EFN agreed to these modifications in a telephone conversation on
December 11, 1996. EFN will be required, by license condition, to conduct its
groundwater detection monitoring in accordance with the proposed program, as
modified.
Finally, the licensee will continue to be required to (1) analyze liquid found in the
leak detection system during weekly inspections for specified constituents;
(2) conduct statistical analyses to determine if significant linear trends exist, and
(3) propose corrective action for NRC review and approval if such trends do exist.
4.6.2 Radiological Assessment
a. Offsite Impacts
The radiological impacts from milling operations at the White Mesa site have been
assessed previously and documented in the FES (NRC, 1979) and the 1985 EA
(NRC, 1985a). In the previous EA, the staff analyzed.impacts associated with
milling at a nominal rate of 2000 tons of ore per day, and an average ore grade of
0.60 percent, for a yellowcake production rate of 4380 tons per year, and
determined that both site boundary radionuclide concentrations and individual dose
commitments were small fractions of the applicable standards.
As part of its November 22, 1994, amendment request for authorization to install a
second dryer, EFN provided updated MILDOS-AREA calculations and results. In
approving EFN's request, the NRC staff determined, based on its review of the
MILDOS-AREA results, that releases from the mill would not result in a member of
the public receiving a radiation dose in exc.,ss of the 10 CFR Part 20 limit (i.e.,
1 00 mrem per year).
It should be noted that actual radiation doses to the public will likely be less than
modeled, because EFN normally processes lower grade ores, at a rate less than
2000 tons of ore per day.
b. Radiological Impact on Biota Other than Humans
Although no guidelines concerning acceptable limits of radiation exposure have
been established 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
gaseous effluents to terrestrial biota (such as birds and mammals) are quite similar
to those calculated for man and arise from the same dispersion pathways and
considerations. Because the effluents of the facility will be monitored and
19
) \
~-\ ~~ -< •' ::~; L ~~
• 2 ~
f----
'
\ ' ;
:~I
;: ~~L_ ________ .....J >-/1-----.<<0-_-T ·t1
~ ~ ;: '· '-~ \ ~c-----------------------------~------~~~~\ i -.:::...:r
'
LEGEND:
---5550 ..
I }
___ _f_ ____ _
4·:. . ..
:: ~r·:·:...;; -.. =-::~-:.a.~.v£
vr::::.." ~::..-. ~::.t: .
Figure 4.1 White Mesa Point of Compliance Well Locations (after Titan, 1994al
20
maintained within safe radiological protection limits for man, no adverse radiological
impact is expected for resident animals.
4. 7 In-Plant Safety
The licensee has established and conducts an in-plant safety and radiation safety program.
EFN stated that the in-plant safety program meets the requirements of the Mine Safety and
Health Administration (MSHA), as well as those pertinent requirements of the Occupational
Safety and Health Administration (OSHA). The licensee's operation is based on good
saf&~y practicss and procedures. During mill oporations, EFN has a full-time safety official
on staff to meet all safety requirements established by Federal regulations. During routine
radiation safety inspections, NRC, to the best of its ability, observes in-plant industrial
safety for deficiencies and brings any identified deficiencies to the attention of plant
management.
NRC, through 10 CFR Part 20 and license conditions, requires a radiological safety
program that contains the basic elements needed to assure that exposures are kept low or,
in any event, as low as is reasonably achievable (ALARA). Therefore, an in-plant radiation
safety program including the following is required:
• Qualified management of the radiation safety program and appropriate t. ~ming of
personnel;
• Written radiation procedures;
• Airborne and surface contamination sampling and monitoring;
• Internal and external radiation monitoring programs;
• An approved respiratory protection program; and
• An annual ALARA audit and frequent in-house inspections.
NRC considers the program of in-plant safety, as required by Federal regulations, and the
radiation safety program as defined by 1 0 CFR Part 20 to be sufficient to protect the
worker during normal operations. The NRC evaluation of the licensee's radiation safety
program is discussed more fully in the SEA.
5.0 ENVIRONMENTAL EFFECTS OF ACCIDENTS
5.1 Failure of Chemical Storage Tanks
At the mill, tanks are used to store a variety of industrial chemicals, process fluids, and
slurries, as well as flammable liquids. Various systems have been implemented to contain
or direct routine or unplanned spillage. Tanks which are most likely to overflow are
equipped with high-level alarms to reduce the possibility of spillage due to tank overflow.
Spills resulting from the failure of any chemical holding tank would first be contained by
engineered dikes or curbs. If the volume was too great, such as that from a rupture in one
21
or more of the large production tanks, flow would be captured by a lined catchment basin
west of the mill, with a capacity of 1.5 million gallons. As a final containment, if all liquids
within the mill process storage area escaped, Cell No. 1-1 is engineered to capture this kind
,of catastrophic flow.
5.2 Fires and Explosions
The most likely place for a fire to occur would be in the solvent extraction building or in
the yellowcake or vanadium dryers. The possibility of a fire as a result of an explosion in
the yellowcake dryer and solvent extraction builc1ing is remote since Industrial Safety
Codes will be strictly enforced. The solvent extraction circuit is located in a separate
building due to the large quantities of kerosene present.
Additionally, the warehouse, offices, and solvent extraction building are equipped with
sensor-operated fire suppression systems, and hose stations are located in the mill yard.
The main water supply tank has a 250,000-gallon reserve for fire fighting, which is
connected to an automatically-starting, diesel-fired pump if electrical service is interrupted.
All fire suppression systems are routinely checked.
In the event of a line rupture, an explosive ammonia-air mixture could be formed inside the
mill and solvent extraction buildings. Constant operator presence, facility emergency
procedures, emergency vent fans, and piping sized to reduce potenticl ammonia release
amounts all serve to minimize the potential for such an accident. ·
5.3 Pipeline Failure
The rupture of a pipeline between the mill and the tailings impoundments would be caught
by automatic alarms or by routine daily inspection. If a leak did occur, no long-term
damage would result. The pipelines are situated so that the leaking fluids would be
directed into other tailings impoundments. In the event that tailings would leak into an
unwanted area, that material could be retrieved by heavy equipment accompanied by
appropriate radiological safety precautions, including radiological surveys.
5.4 Minor Pipe or Tank Leakage
Minor leaks resulting from, for example, loose connections in piping or tanks overflowing,
will be collected in sumps designed for this type of spill. Sump pumps will be used to
return the material to the circuit, and the reason for the spill will be determined and
corrected.
5.5 Tailings Impoundment System Accidents
The tailings cells at the White Mesa facility were designed and constructed as partially
below-grade impoundments, and in accordance with Regulatory Guide 3.11 and Staff
Technical Position WM-8201. Therefore, the potential failure of the cells is considered to
be unlikely. In addition, each tailings cell embankment is monitored regularly for stability
as part of the licensee's site inspection program, and the results of these ·inspections are
reported to NRC.
22
6.0 RECLAMATION AND DECOMMISSIONING
Following financial difficulties in February 1995, EFN agreed to voluntarily revise its surety
amount to cover reclamation and decommissioning costs for the site in its current state.
EFN is pursuing this action in two phases, with the first having been completed in June
1995 with NRC's approval of a revised surety amount of approximately $10.5 million. In
this initial phase, EFN reviewed all major reclamation cost centers, considering the then
current level of development and disturbance at the site. In the second phase, EFN is
reviewing all elements of the site reclamation plan and will, if necessary, revise the earlier
cost estimate.
The licensee is expected to submit the revised site reclamation plan in early 1997 for NRC
review and approval. NRC will review the plan in accordance with the requirements of
10 CFR Part 40, Appendix A, and applicable staff guidance documents. Because NRC has
yet to receive the reclamation plan, EFN will be required by license condition to provide
the plan to NRC by June 30, 1997, for its review and approval in the form of a license
amendment.
Site decommissioning will be conducted under a plan approved by NRC. EFN will be
required by license condition to submit a detailed decommissioning plan to NRC for
approval at least 12 months prior to. the planned final shutdown of mill operations.
7.0 ALTERNATIVES
The action under consideration is the renewal of Source Material License SUA-1358, for
continued operation of the White Mesa mill, as requested by EFN. The alternatives
available to NRC are to:
( 1) Renew the license with such conditions as are considered necessary or
appropriate to protect public health and safety and the environment; or
(2) 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. It is the staff's conclusion that the impacts
associated with the license renewal are within the realm of impacts anticipated in the FES
(NRC, 1979) and the previous EA (NRC, 1985). Additionally, in the SER prepared for this
action, the staff has reviewed the licensee's proposed action with respect to the criteria
for license issuance specified in 10 CFR Part 40, Section 40.32, and has no basis for
denial of the proposed action.
8.0 FINANCIAL SURETY
Under 10 CFR Part 40, Appendix A, Criterion 9, licensees 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 tailings or waste disposal
areas, (3) ground water restoration, as warranted, and (4) the long-term surveillance fee.
23
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 provi::J the surety arrangenemt through a
financial instrument acceptable to NRC. The licensee's surety me.::hanism will be reviewed
by NRC annually to assure that sufficent funds are available to complete reclam11tion
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.
The surety for the White Mesa mill is carried by Umetco, under an agreement between
EFN and Umetco. The current surety amount of $10,915,647 was reviewed and approved
by NRC in August 1996. EFN 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.
9.0 CONSULTATION WITH THE STATE OF UTAH
A teleconference call was held on January 23, 1997, with representatives of the
UDEO/Divisions of Water Quality and Radiation Control to discuss any comment<> or
concerns tr.<3 State may have had with the NRC staff's discussions and findings, as
documented in a final draft of this EA, which was transmitted· electronically to the State
on January 3, 1997. Issues raised by UDEO in these teleconference calls concerned EFN's
proposed groundwater detection program, as modified by the staff (see Section 4.6.1 ).
UDEQ recommended that the NRC require consistency in the set of indicator parameters
sampled for in the tailings impoundment and groundwater monitoring programs UDEQ
considered this information to be helpful in determining source term concentrations in the
event of an impoundment liner failure. The staff, however, considers that the two sets of
indicator parameters monitored for in these programs are appropriate and sufficient to
meet their intended purpose. UDEO agreed. Details of EFN's impoundment monitoring
program are discussed in Sections 3.2, 4.4.2, and 4.6.1.
UDEQ expressed a concern about the apparent inconsistency between the groundwater
monitoring programs for EFN and the Envirocare site near Clive, Utah. Pointing to
differences in the number of indicator parameters to be sampled for and the "triggers"
used in determining when compliance monitoring would be required, UDEO considered that
both sites should have similar monitoring programs since both accept 11 e.(2) byproduct
material for disposal. NRC considers that the difference in the operations of these two
sites and the amount of byproduct material accepted by each is appropriate justification for
the differences in the monitoring programs.
UDEQ also strongly recommended that NRC require EFN to have a quality assurance (QA)
plan as part of its groundwater monitoring program. The NRC staff notes that EFN did
include a OA plan as an appendix to its hydrogeologic evaluation report submitted in
support of its proposed groundwater monitoring program.
24
10.0 FINDING OF NO SIGNIFICANT IMPACT
EFN has applied to NRC to renew Source Material License SUA-1358 to authorize
continued operations at the White Mesa uranium mill. located in San Juan County, Utah.
NRC has reexamined actual and potential environmental impacts associated with
yellowcake production at the mill site, and has determined that renewal of the source
material license (1) will be consistent with requirements 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 environment.
Therefore, based on an evaluation of EFN'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 is in place to monitor effluent
releases and to detect exceedances of appropriate limits;
• The licensee has implemented an intensive, routine inspection program of the mill
process building, associated facilities, and tailings retention impoundments, and
conducts an annual ALARA audit program;
• Standard operating procedures are in place for all operational process activities
involving radioactive materials that are handled, processed, or stored;
• Mill tailings and process liquid effluents from the mill circuit are discharged to
partially below-grade, lined tailings impoundments, with leak detection systems;
• The licensee will implement an acceptable groundwater detection monitoring
program to ensure compliance with the requirements of 10 CFR Part 40,
Appendix A;
• The licensee will conduct site decommissioning and reclamation activities in
accordance with NRC-approved plans; and
• Because the staff has determined that there will be no significant impacts
associated with approval of the license renewal, there can be no disproportionately
high a'nd adverse effects or impacts on minority and low-income populations.
Consequently, further evaluation of 'Environmental Justice' concerns, as outlined in
Executive Order 1 2898 and NRC's Office of Nuclear Material Safety and
Safeguards Policy and Procedures Letter 1-50, Rev.1, is not warranted.
Based on these findings, the NRC staff recommends that EFN's license for yellowcake
production at the White Mesa uranium mill be renewed. The source material license shall
be based upon the licensee's renewal application, this EA, the SEA, and the license
conditions which address environmental issues (see Section 11 ). License conditions
addressing radiation safety concerns can be found in the SEA.
25
11.0 CONCLUSION INCLUDING ENVIRONMENTAL LICENSE CONDITIONS
Upon completion of the environmental review of EFN's application for renewal of Source
Material License SUA-1358, the NRC staff has concluded that the operation of the White
Mesa uranit;m mill, in accordance with the following conditions to be included in the
renewed source material license, is protective of health, safety, and the environment, and
fulfills the requirements of 1 0 CFR Part 51. Therefore, the NRC staff recommends renewal
of SUA-1358, subject. in part, to the following conditions:
1. The mill production rate shall not excPed ~380 tons of yellowcake per year.
2. A. The licensee may, without prior NRC approval, and subject to the conditions
specified in Part B of this condition:
( 1) Make changes in the facility or process, as presented in the
application.
(2) Make changes in the procedures presented in the application.
(3) Conduct tests or experiments not presented in the application.
B. lhe licensee shall file an application for an amendment ~o 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 NRC regulations.
(2) 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 are consistent with the conclusions
of actions analyzed and selected in this EA.
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 health physics, groundwater hydrology,
surface-water hydrology, specific earth sciences, and other technical
26
disciplines. Temporary members or permanent members, other than the
three above-specified individuals, may be consultants.
D. The licensee shall maintain records nf 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 condition. The licensee shall furnish, in an
annual report to NRC, a description of such changes, tests, or experiments,
including a summary of the safetv and environmental evaluation of each. In
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 shell submit to NRC by March 31, 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.
3. Standard operating procedures (SOPs) shall be established and followed for all
operational process activities involving radioactive materials that are handled,
pr0r::essed, or stored. SOPs for operational activities shall 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 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 RSO before implementation and whenever
a change in procedure is proposed to ensure that proper radiation protection
principles are being applied. In addition, the RSO shall perform a documented
review of all existing operating procedures at least annually.
4. Before engaging in any activity not previously assessed by the NRC, the licensee
shall administer a cultural resource inventory. All disturbances associated with the
proposed development will be completed in compliance with the National Historic
Preservation Act (as amended) and its implementing regulations (36 CFR 800). and
the Archaeological Resources Protection Act (as amended) and its implementing
regulations (43 CFR 7).
In order to ensure that no unapproved disturbance of cultural resources occurs, any
work resulting in the discovery of previously unknown cultural artifacts shall cease.
The artifacts shall be inventoried and evaluated in accordance with
36 CFR Part 800, and no disturbance shall occur until the licensee has received
authorization from the NRC to proceed.
The licensee shall avoid by project design, where feasible, the archeological sites
designated "contributing" in the report, "Archeological Sites Related to the White
27
Mesa Project," submitted by letter dated July 28, 1988. When it is not feasible to
avoid a site designated "contributing" in the attachment, the licensee shall institute
a data recovery program for that site based on the research design submitted by
letter from C. E. Baker of Energy Fuels Nuclear to Mr. Melvin T. Smith, Utah State
Historic Preservation Officer, dated April 13, 1981.
The licensee shall recover through archeological excavation all "contributing" sites
listed in the attachment which are located in or within 100 feet of borrow areas,
stockpile areas, construction areas, or the perimeter of the reclaimed tailings
impoundment. Data recovery fieldwork at 'lach site meeting these criteria shall be
completed prior to the start of any project related disturbance within 100 feet of
the site, but analysis and report preparation need not be complete.
Additionally, the licensee shall conduct such testing as is required to enable the
Commission to determine if those sites designated as "Undetermined" in the
attachment and located within 1 00 feet of present or known future construction
areas are of such significance to warrant their redesignation as "contributing." In all
cases, such testing shall be completed before any aspect of the undertaking affects
a site.
Archeological contractors shall be approved in writing by the Commission·. The
Commission will approve an archeological contractor who meets the minimum
standards for a principal investigator set forth in 36 CFR Part 66·, App11ndix C, and
whose qualifications are found acceptable by the SHPO.
5. The licensee is hereby authorized 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.
7. Freeboard limits for Cells 1-1, 3, and 4A, and tonnage limits for Cell 3, shall be as
s~ated in Section 3.0 to Appendix E of the approved license application.
8. The licensee shall maintain an NRC-approved financial surety arrangement,
consistent with 10 CFR 40, Appendix A, Criteria 9 and 10, 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, 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
28
surety. The revised surety shall then be in effect within 3 months of written NRC
approval.
Annual updates to the surety amount, required by 10 CFR 40, Appendix A, Criteria
9 and 1 0, shall be submitted to NRC at least 3 months prior to the anniversary date
which is designated as June 4 of each year. If NRC has not approved a proposed
revision to the surety coverage 30 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 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 surety instrument, Irrevocable Letter of Credit Nu.
S00017012, issued by The Bank of New York in favor of IIJflC, as amended, May
10, 1994, to include a Standby Trust Agreement, shall be continuously maintained
by UMETCO in an amount not less than $10,915,467 for the purpose of complying
with 1 0 CFR 40, Appendix A, Criteria 9 and 1 0, until a replacement is authorized
by NRC.
9. Disposal of material and equipment generated at the mill. site shall be conducted as
described in the licensee's submittals dated December 1 2, 1994 and May 23,
1995, with the following addition:
A. The maximum lift thickness for materials placed over tailings shall be less
than 4-feet thick. Subsequent lifts shall be less than 2-feet thick. Each lift
shall be compacted by tracking of heavy equipment, such as a Cat D-6, at
least 4 times prior to placement of subsequent lifts.
10. The licensee shall submit a detailed decommissioning plan to the NRC at least
twelve ( 12) months prior to planned final shutdown of mill operations.
11. The licensee shall submit to NRC for review, by June 30, 1997, a detailed
reclamation plar:l for the authorized tailings disposal area which includes the
following:
A. A post-operations interim stabilization plan which details methods to prevent
wind and water erosion and recharge of the tailings area.
B. A plan to determine the best methodology to dewater and/or consolidate the
tailings cells prior to placement of the final reclamation cover.
29
C. Plan and cross-sectional views of a final reclamation cover which details the
location and elevation of tailings. The plan shall include details on cover
thickness, physical characteristics of cover materials, proposed testing of
cover materials (specifications and OA). the estimated volumes of cover
materials and their availability and location.
D. Detailed plans for placement of rock or vegetative cover on the final
reclaimed tailings pile and mill site area.
E. A proposed implementation schedule for items A through D above which
defines the sequence of events and expected time ranges.
F. An analysis to show that the proposed type and thickness of soil cover is
adequate to provide attenuation of radon and is adequate to assure
long-term stability, as well as an analysis and proposal on methodology and
time required to restore ground water in conformance to regu.latory
requirements.
G. The licensee shall include a detailed cost analysis of each phase of the
reclamation plan to include contractor costs, projected costs of inflation
based upon the schedule proposed in item E, a proposed contingency cost,
and the costs of long-term maintenance and monitoring.
12. The licensee shall implement the effluent and environmental monitoring program
specified in Section 5.5 of the renewal application as revised with the following
modifications or additions:
A. Stack sampling shall include a determination of flow rate.
B. Surface water samples shall also be analyzeq semiannually for total and
dissolved U-nat, Ra-226, and· Th-230, with the exception of the Westwater
Creek, which shall be sampled annually for water sediments and analyzed as
above. A sediment sample shall not be taken in place of a water sample
unless a water sample was not available.
C. The licensee shall utilize lower limits of detection in accordance with
Section 5 of Regulatory Guide 4.14 (Revision 1), for analysis of effluent and
environmental samples.
D. The inspections performed semiannually of the critical orifice assembly
committed to in the submittal dated March 15, 1986, shall be documented.
The critical orifice assembly shall be calibrated at least every 2 years against
a positive displacement Roots meter to obtain the required calibration curve.
1 5. The licensee shall implement a groundwater detection monitoring program to ensure
compliance to 10 CFR Part 40, Appendix A. The detection monitoring program
shall be in accordance with the report entitled, "Points of Compliance, White Mesa
30
Uranium Mill," submitted. by letter dated October 5, 1994, as modified by the
following:
A. The leak detection system for all ponds will be checked weekly. If liquid is
present, it shall be analyzed for chloride, sulfate, selenium, and pH. The
samples will be statistically analyzed to determine if significant linear trends
exist, and the results will be submitted to NRC for review.
If a significant linear trend is indicated, the licensee will submit a proposed
corrective action for review and c>pproval to NRC. The corrective action shall
include a discussion on delineation of the areal extent and concentration of
hazardous constituents.
B. The licensee shall sample monitoring wells WMMW-5, -11,-12,-14,-15,
and -17, on a quarterly basis. Samples shall be analyzed for chloride,
potassium, nickel, and uranium, and the results of such sampling shall be
included with the environmental monitoring reports submitted in accordance
with 10 CFR 40.65.
REFERENCES
Titan Environmental Corporation [Titan]. 1994a, "Points of Compliance, White Mesa
Uranium Mill." prepared for Energy Fuels Nuclear, Inc .. September 1994.
Titan, 1994&, "Hydrogeologic Evaluation of White Mesa Uranium Milt." prepared for
Energy Fuels Nuclear, Inc., July 1994.
Umetco Minerals Corporation, 1991, "1991 White Mesa Mill License Renewal," 4 vols.,
August 1 991 .
U.S. Nuclear Regulatory Commission [NRC). 1988, "Bioassays at Uranium Mills," NRC
Regulatory Guide 8.22, Rev. 1, August 1988.
NRC, 1985a, "United States Nuclear Regulatory Commission Environmental Assessment
Prepared by the Uranium Recovery Field Office in Consideration of the Renewal of Source
Material License SUA-1358 for the Umetco Minerals Corporation White Mesa Uranium
Mill." issued September 26, 1985.
NRC, 1985b, "Safety Evaluation Report for Umetco Minerals Corporation White Mesa
Uranium Mill, License SUA-1358, Docket No. 40-8681." issued September 26, 1985.
NRC, 1983, "Hydrologic Design Criteria For Tailings Retention System," NRC Staff
Technical Position WM-8201, January 1983.
NRC, 1980a, "Operational Inspection and Surveillance of Embankment Retention Systems
for Uranium Mill Tailings," NRC Regulatory Guide 3.11.1, October 1980.
31
, , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,
I
NRC. 1980b, "Radiological Effluent and Environmental Monitoring at Uranium Mills," NRC
Regulatory Guide 4. 14, April 1980.
NRC, 1979a, "Final Environmental Statement: Related to Operation of White Mesa
Uranium Project, Energy Fuels Nuclear, Inc.," NUREG-0556, Otf'v'! of Nuclear Material
Safety and Safeguards, May 1979.
NRC, 1979b, "Quality Assurance for Radiological Monitonng Programs (Normal
Operations) ·Effluent Streams and the Enwonment," NRC Regulatory Guide 4.15,
February 1979.
NRC, 1977, "Design, Construction and Inspection of Embankment Retention Systems for
Uranium Mills," NRC Regulatory Guide 3.11, December 1977.
32
Federal Register Notice:
Finding of No Significant Impact
Notice of Opportunity for Hearing
(62 FR 10091; March 5, 1997)
Enclosure 2
Federal Re er I Vol. 62, No. 43 I Wednesday. M.· 5. 1997 I Notices 10091
==========~============~~---
Buildiag. 2120 L Street. NW ..
Washington, OC, and at the local public
document room located at the Osterhout
Free Library, Reference Department, 71
South Franklin Street, Wilkes-Barre,
Pennsylvania. If a request for a hearing
or petition for leave to intervene is filed
by :be above date, the Commission or an
Atomic Safety and Licensing Board,
designated by the Commission or by the
Chairman of the Atomic Safety and
Licensing Board Panel, will rule on the
request and/or petition; and the
Secretary or the designated Atomic
Safety and Licensing Board will issue a
notice of hearing or en appropriate
order.
As required by 10 CFR 2.714, a
petition for leave to intervene shall set
forth with particularity the interest of
the petitioner in the proceeding, end
must provide sufficwnt information to
show that a genuine dispute exists with
the applicant on a material issue of law
or fact. Contentions shall be limited to
matters within the scope of the
amendment under consideration. The
contention must be one ·vhich, if
proven, would entitle the petitioner to
relief. A petitioner who fails to file such
a supplement which satisfies these
requirements with respect to at least one
contention wiil not be permitted to
participate as a party.
Those permitted to intervene become
parties to the proceeding, subject to any
limitations in the order granting leave to·
intervene, and have thP opportunity to
participate fully in the conduct ofth•
hearing, including the opportunity to
present evidence and cross""6xamine
witnesses.
A request for a hearing or a petition
for leave to intervene must be filed with
comment of its proposed finding of no
significant hazards consideration in
accordance with 10 CFR 50.91 and
50.92.
For further details with respect to this
action, see the application for
amendments dated February 11, 1997,
which is available for public inspection
at the Commission's Public Document
Room, the Gelman Building, 2120 L
Street, NW .. Washington, OC. and at the
local public document room located at
the Osterhout Free Library, Reference
Department, 71 South Franklin Street,
Wilkes-Barre, Pennsylvania.
Dated at Rockville, Maryland, thia 28th day
ofFabruary 1997.
For the Nuclear Regulatory Commission.
Joba r. SUb,
Director, Project Directorate 1-2, Division of
Reactor Projects-1/ll, Office of Nuclear
Reactor Regulation. bow that inte""'t may be affected by the
results of the proceeding. The petition
should specifically explain the reasons
why intervention should be permitted
with particular reference to the
following factors: (1) The nature of the
petitioner's right under the Act to be
made a party to the proceeding; (2) the
nature and extent of the petitioner's
property, financial, or other interest in
the proceeding; end (3) the possible
effect of any order which may be
the Secretary of the Commission, U.S. .._.._ CCDI ,__.,,_,.
Nuclear Regulatory Commissio .. ,:n~i'tentioOI'---------"""~-=--­
[FR Doc. 97-5399 F1led 3-4-97: 5,45 ami
enteted in the proceeding on the
petitioner's interest. The petition should
aJao Identify the specific aspect(s) of the
subject matler of the proceeding as to
>'.obich petitioner wishes to intervene.
Any penon who has filed a petition for
leave to intervene or who has been
admitted as a party may amend the
petition without requesting leave of the
Board up to 15 days prior to the first
prehearing conference scheduled in the
proceeding, but such an amended
petition must satisfy the specificity
requirements described above.
Washington, OC 20555-QOOl,"
Docketing and Services Branch,
be delivered to the Commission
Document Room, the Gelman
2120 L Street, NW., Washington,
the above date. Where petitions
during the last 10 days of the
period, it is requested that
promptly so inform the~~=:~ a toll-free telephone call to
Union at 1-{800) 24&-5100 (in Mlaourl
1-[phone]). The Westarn Union
operator should be given IJatasram
Identification Number N1023 and the
following message addressed to John F.
Stolz: petitioner's name and telephone
number; d•te petition was mailed; plant
namei and publication elate and page
numb.Jr of this Federb ~ 1tep.tter notice.
A copy of the petition shoUld alao be
sent to the Office of the General
Counsel, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-
0001, and to Jay Silberg, Esquire, Slutw,
Pittman, Potle and Trowbridga, 2300 N
Street NW, Washington, DC 20037,
attorney for the licenM8. Nontimely 6.linga of petitions for
leave to intervene, amended petitions,
supplemental petitions and/or requeota
for hearing will not be entertained
absent a determination by the
Commission, the presiding officer or the
presiding Atomic Safety and Licensing
Board that the petition and/or request
should be granted based upon a
balancing of the facton specified In 10
CFR 2.714(a)(1)(1Hv.) ana 2.714(d) ..
If a request for a hearing is received,
the Commission's staff may issue the
amendments after it complete~ ita
technical review and prior to ·the
[Docket No. 40-8881)
Energy Fuels Nuclear, Inc.; Final
!"l!'ldlng o1 No Significant Impact Notice
of Opportunity for Hearing
SUMMARY: The U.S. Nuclear.Reguiatory
Commiasion (NRC) proposes to renew
NRC Source Material Ucense SUA-1358
to authorize the. licensee, Energy Fuela
Nuclear, Inc. (EFN), for continued
COIIl1DBrCial operation of the White Mesa
urailium mill, located near Blanding.
Utah. An Envilonmental"-ment
waa perlnrmed by the NRC staff in
accordance with the requirements of 10
CFR Part 51. The conclusion of the
Environmental Assessment is a Finding
of No Significant Impact (FONSI) for the
proposed licensing action.
FOR FUII1l1ER INFORMA11011 CONTACT: Mr.
)amea R. Park, Uranium Recovery ·
Brench, Mail Stop 'lWFN 7-J9, Division
of Wasta Management, Office of Nuclear
Material Safety and Safeguarda, U.S.
Nuclear Regulatory Commiasion,
W8l!hington, D.C. 20555. Telephone
301/415-6699.
SUPPI.EIII!NTARY INFORMATION:
Background
l'lot later than 15 day:::J:or to the first
prehearing conference duled in the
proceMing. a petitioner shall file a
supplement to the petition to intervene
which IIUUilinclude a list of the
contentions which are sought to be
litigated in the matter. Each contention
must conail!t of a apecific statement of ·
the issue of law or fact to be raised or
controverted. In addition, the petitioner
shall provide a brief explanation of the
bases of the contention and a concise
statement of the alleged facta or expert
opinion which support the contention
and on which the petitioner intends to
rely in proving the contention at the
hearing. The petitioner must alao
provida references to thoee specific
sources end documents of which the
petitioner is aware and on which the
petitioner intends to rely to establish
those facts or expert opinion. Petitioner
completion of any required hearing if it
publishes a further notice for public
Source Material License SUA-1358
was originally issued by NRC on Augus
7, 1979, pursuant to Title 10, Code of
Federal Regulations (10 CFR), Part 40,
Domestic Licensing of Source Material.
This license currently authorizes EFN 1
(1) receive, aoquire, possess, and
trenefer urailium at the White Mesa
mill,l2) possess byproduct material in
the form of uranium waste tailings an(
other uranium byproduct waste
generated by operations at the mill, ru
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~ ....... ctaJ l\.~;:o,ttr ' vot. t)L. ~o. 43 , \V~dnesday. March 5. 1997 I Notices
(3) accept. for disposal. limit mounts
of byproduct material from in·;,dU I·
(lSL) ura1.:um r:-·;ning focilities. The
mill was operated on a continual basis
from t-hy 1980 until February !983, and
then intermittentlY from October !985
to the present time. SUA-1358 was
renewed last in 1985.
Summary of the Environmental
Assessment
The NRC staff performed an appraisal
of the environmental impacts associated
with the continued operation of the
White Mesa mill, in accordance with 10
CFR Part 51, Ucensing and Regulatory
Policy Procedures for Environmental
Protection. In conducting its appraisal,
the NRC staff considered the foUowing:
(I) information contained in previous
environmental evaluations of the White
Mesa project; (2) information contained
in EFN's license renewal application; (3)
infonnation contained in EFN's license
amendment requests submitted
subsequent to its renewal application,
and NRC staff approvals of such
requests; ( 4) land usa and
environmental monitoring reports; and
(5) information derived from NRC staff
site visits and inspections of the White
Mesa mill site and from
communicat1.ons with EFN and the State
of Utah Department of Environmental
Quality. The results of the stafrs
appraisal are documented in an
Environmental Assessment. The safety
aspects for the continued operation of
the miU are discussed in a Safety
Evaluation Report.
The license renewal would authorize
EFN to continue operating the White
Mesa mill, at a maximum production
rate of 4380 tons of yellowcake per year.
Additionally, EFN would continue to he
authorized, by license condition, to (1)
possess byproduct material in the form
of uranium waste tailings and other
uranium byproduct waste generated by
its milling operations authorized by the
ronewallicense. and (2) accept, for
disposal, limited amounts of byproduct
material from ISL uranium mining
facilities.
All conditions In the renewal license
and commitments presented in the
licensee's license renewal application
are subject to NRC inspection. Violation
of the license may result in enforcement
action.
Conclusions
wlll not he tnJ!Tlll .!] to !ht; ~Jt~biic b., _dh
Jnd s.afetv. and f:JJ will not have long-
term detnmental impacts on the
environment. The following statements
support the FONSI and summarize the
conclusions resulting from the stafrs
environmental assessment:
1. :\n acceptable environmental
sampling program is in plar,... to monitor
:'fnllt~nt releases ;lJJ.i to detect if
appropriate Urn its are exceeded:
2. The licensee has implemented an
intensive. routint: tnspection program of
the mill process building, associated
facilities, and tailings retention
impoundments. and conducts an annual
"as loW as is reasonable achievable"
(ALARA) audit program;
3. Standard operating procedures are
in place for all operational process
activities in.,olving radioactive
materials that are handled, processed, or
stored;
4. Mill tailings and process liquid
effluents from the mill circuit are
discharged to partially below-grade,
lined tailings impow:dments, with leak
detection systems;
5. The licensee will implement an
acceptable groundwater detection
monitoring program to ensure
compliance with the requirements of 10
CFR Part 40, Appendix A;
6. The licensee will conduct site
decommissioning and reclamatiorl.
activities in accordance with NRC-
approved pi8I1S; and
7. Because the staff has detennined
that there will he no significant impacts
associated with approval of the license
renewal, there can be no
disproportionately high and adverse
effects or impacts on minority and low-
income populations. Ccnsequently,
further evaluation of "Environmental
Justice" concerns, a::; outlined in
Executive Order 12898 and NRC's Office
of Nuclear Material Safety and
Safeguards PoHcy and Procedures Letter
i-50, Rev.l, is not warranted.
Altematl...,. to the 1'1~ Action
The proposed action is to ronew NRC
Source Material License SUA-1358, for
continued operation of the White Mesa
mill, as requested by EFN. Therefore,
the principal alternatives available to
NRC are to:
(1) Renew the license with such
conditions as are considered necessary
or appropriate to protect public health
and safety and the environment; or
e\·alua:ed. ~inc.e the environnwnttll
impacts of the propo::;ed action and t!-w
no-action alternative (i.e., denial of thP
renewal) are similar. there is no need !1
further evaluate alternatives to the
proposed action.
Finding of No Significant lmnact
The NRC staff has prepared an
Environmental Assessment for the
proposed renewal of NRC Source
Material License SUA-1358. On the
basis of this assessment. the NRC staff
has concluded that the environmental
impacts that may result from the
proposed action would not be
significant, and therefore, preparation of
an Environmental Impact Statement is
not warranted.
The Environmental Assessment and
other documents related to this
proposed action are available for public
inspection and copying at the NRC
Public Document Room, in the Gelman
Building, 2120 L Street N.W.,
Washington, DC 20555.
Notice of Opportunity for Hearing
The Commission hereby provides
notice that this is a proceeding on an
applicaUon for a licensing action falling
within the scope of Subpart L, "Informal
Hearing Procedures for Adjudications in
Materials Licensing Proceedings, of the
Commission's Rules of Practice for
Domestic Licensing Proceedings in 10
CFR Part 2" (54 FR 8269). Pursuant to
§ 2.1205(a). any person whose interest
may he affected by this proceeding may
file a request for a hearing. In
accordance with § 2.1205(c), a request
for a hearing must he filed within thirty
(30) days from the date of publication of
this Federal Register notice. The re'1 ........... t
for a hearing must be filed with the
Office of the Secretary either:
(1) By delivery to the Docketing and
Service Branch of the Office of the
Secretary at One White Flint North,
11555 Rockville Pike, Rockville, MD
20852;or
(2) By mail or telegram addressed to
the Secretary, U.S. Nuclear Regulatory
Commission, Washington, DC 20555.
Attention: Docketing and Service
Branch.
Each request for a hearing must also
be served, by delivering it personally or
by mail to:
(1) The applicant, Energy Fuels
Nuclear, Inc., 1515 Arapahoe Street.
Suite 900, Denver, CO 80202;
The NRC staff hils reexamined actual
and potential environmentlll impacts
associated with continued yellowcake
production at the mill site, and has
determined that renewal of the source
material license (1) will he consistent
with requiroments altO CFR Part 40, (2)
(2) Deny renewal of the license.
Based on its review, the NRC staff hils
concluded that there are no significant
environmental impacts associated with
the proposed action; therefore, any
(2) The NRC staff, by delivery to the
Executive Director of Operations, One
White Flint North, 11555 Rockville
Pike, Rockville, MD 20852, or by mail
addresaed to the Executive Director for
Operations, U.S. Nuclear Regulatory
Commission, Washington, DC 20555.
alternatives with equal or greater
environmental impacts need not be
Federal Register VoL bl. No. 43 1 \Veanesaay. March s. ~~~~ 1 Nottces 1UUlM
ln addition ,v meeting other
apnlicable requirements of 10 CfR Part
2 of the Commission's regulations, a
request for a hParing filed by a person
other than an applicant must describe in
detail:
(1) The interest of the requestor in the
proceeding;
(2) How that interest may be affected
by the results of the proceeding,
including the reasons why the requestor
shcnld Lc permitted a hearing, with
particular referenCL to the factors set ._,._.,
in§ 2.1205(g);
(3) the requestor's areas of concern
about tho licensing activity that is the
subject matter of tho proceeding; and
(4) The circumstances establishing
that the request for a hearing is timely
in accordance with § 2.1205(c).
Any hearing that is requested and
granted will be hold in accordance with
the Commission's Informal Hearing
Procedures for Adjudications in
Materials Licensing Proceedings in 10
CFR Part 2, Subpart L.
Dated at Rockville, Maryland, this 26th day
of February 1997.
For the Nuclear Regulatory Commission.
Jooeph J. HoloaiclJ,
Chief. Uranium Recovery /lronch, Division
of Waste M .. nagement, Office of Nuclear
Material Safety and Safeguards.
IFR Doc. 97-5388 Filed 3-4-97; 8:45 ami
K.UIIO·CODa 1110-01..P
~ SMB-17e and SUB-1452-
~40-e12-~
Nucteer Mel8la, tnc.-<loncord, n ch..-: Renewal of Soun:e
Mal8flal Llcen-; Finding of No
Significant Impact and Notice of
Opportunity lor a Hearing (NUREG/CR-
6528)
The U.S. Nuclear Regulatory
Commission is considering the renewal
of Source Material Ucensoa SMB-179
and SUB-1452 for tho continued
operation of Nuclear Metals, Inc. (NMI),
located In Concord, ~usett..
SamDuory of the EnYiromnental
Assm"Ment
Identification· of the Proposed Action ~-The proposed action Is tho renewal of
NMl's Sowce Material Ucenses SMB-
179 and SUB-1452 for at least 5 ye&l'S.
With the.e renewals, the NMl facility
will continue to conduct ongoing ·
operations including the development
and manufacture of castings, extrusions,
machined parts, and metal powders
comprised of depleted uranium and
natural uranium metal. The proposed
action would permit NMl to possess,
under Ucense SMB-179. natural
Uianium metaL allov. or oxide: deplet,
uranium metal. alto)·., x1de. or f!\•oride:
natural thorium metal. alloy. or oxide:
and depleted uranium slab. The
licensPd uranium may be an element of
any compound except uranium
hexafluoride (UF6). The proposed action
would also pennit NMI to possess,
under Licen>e SUB-1452, deplete:'
uranium as contamination in sand;
depleted uranium as coatamination on
metallic components. packaging
materials or equipment, or as waste
solids; and natural thorium as
contamination on metaHic components,
packaging materials or equipment, or as
waste solids.
Prior to September 1985,1iquid and
sludge wastes from the processes were
stabilized and emptied into an unlined
holding basin and adjacent bog located
on site property. The holding besin was
covered by a special membrane in 1986
to reduce infiltration of rain water and
discharge of contaminants to surface
and ground waters. R~med.iation of the
holding basin and contaminated
groundwater is being planned as a
separate decommissioning action;
therefore, this action and subsequent
environmental impacts are outside the
scope of this EA.
The Need for the Proposed Action
The action is to determine if the
licenses should be renewed or denied.
NMl manufactures producta composed
of depleted uronlum and natural
uranium that have military, aerospace,
industrial, and medical application&.
Depleted uranium metal is processed to
form armor penetrators, aircraft
counterweights and radiation shielding
devices. Denial of the license renewals
for NMI is an alternative available to
NRC, but since approximately half of
the U.S. demand for tLese products is
being met by operations at NMl
facilities, denying ~~e licenses would
not be in the nation's best interest.
Environmental Impacts of the PropaJU>d
Action
Both radiological and nonradiological
atmospheric emissions occur and were
assessed during normal (incident-free)
operationa at NMI. The radiological
impacta of the continued operation of
the l\~Al facility were assessed using
atmospheric dispersion modeling to
estimate ambient annual dose to the
public resulting from omissions at the
NMl facility. To assess the impact of
uranium emissions on atmospheric
resources, the COMPLY computer code
was used to determine the maximum
annual dose equivalent received from
uranium concentrations in the ambient
air (at or beyond the site boundary).
fhese estimJted annual doses were
compared to NRC requirements and
EPA standards to gauge impacts to
public health and safety.
Ambient air concentrations (at 0r
beyond the site boundary) resulting
from the primary sources of
nonradiological air emissions were
estimated using the Industrial Sourc.P
Complex-Version 2 (ISC2) air
dispersion model (EPA 1992a). Total
predicted concentrations were
compared to the National Ambient Air
Quality Standards (NAAQS) in order to
gauge impacts on air quality.
Doses From Routine Airborne Releases
Small amounts of uranium are
emitted from 33 stacks at NMI. The
town of Concord permits depleted
uranium emissions of up to 280 JJ,Ci per
calendar quarter for operations
associated with License Nos. SMB-179
and SUB-1452. NRC's regulations (10
CFR 20.1301) require licensees to limit
doses to members of the public to
lOOmrem per year. Emission rates of
depleted uranium in 1994 were less
than 60 percent of the 280 j.lCi per
calendar quarter limit. For tho
modeling, annual emissions were
assumed tn be at maximum permitted
levels (i.e., 1,120 j.lCi/y as by the town
of Concord). Tho assumptions are
conservative in that they result in higher
predicted dooes than are expected to
occur. Tha maximum annual committed
effective dose equivalent predicted was
2.5 mrem. Thlo doae W1lll eatimated to
occur to.a person located 150m (492ft)
from the nearest building. Thlo is about
one-half tho distance to the nearest
resident. Therefore, 150m (492ft) is
considered a sufficiently conservativP
distance to form an upper bound of
doses that could be received by the
public annually. The predicted annual
dose Is 2.5 percent of the NRC limit
The primary sources of
nonradiological air amissions at NMl are
two boilers, which burn 14 fuel oil, and
which omit the following criteria
pollutants: SO.. NO., PM-10, and CO.
Short-term omission rates, calculated
using tho maximum monthly fuel usage
rates, were used In ISC2 for periods of
24 hr or Ieos. Long-term omiaaion ratoa,
calculated using the maximum annual
fuel usage rates. were used in 1SC2 for
the annual time period. Both site
specific data and conservative ·
85SUIDptiona were used In tho modeling
analyolls. Total predicted concentrations
were compared to tho NAAQS in order
to gauge impacts on air quality. The
results of tho analysis show that
maximum 3-hr and 24-hr average SO,
concentrations are about twice their
respective NAAQS. For all other criteri
Safety Evaluation Report
for Renewal of
Source Material License No. SUA-1358
Energy Fuels Nuclear, Inc.
White Mesa Uranium Mill
San Juan County, Utah
Enclosure 3
SAFETY EVALUATION REPORT
FOR RENEWAL OF
SOURCE MATERIAL LICENSE NO. SUA-1358
ENERGY FUELS NUCLEAR, INC.
WlllTE MESA URANIUM MILL
SAN JUAN COUNTY, UTAH
MARCH 1997
DOCKET NO. 40-8681
U.S. Nuclear Regulatory Commission
Office of Nuclear Material Safety
and Safeguards
Division of Waste Management
TABLE OF CONTENTS
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1 . 1 Description of Proposed Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.2 Background Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.3 Review Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.0 AUTHORIZED ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.1 Facility Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.2 Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3.0 FACILITY ORGANIZATION AND ADMINISTRATIVE PROCEDURES ........... 3
3.1 Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3.2 Radiation Safety Staff and Respor.sibilities . . . . . . . . . . . . . . . . . . . . . . 6
3.3 Minimum Technical Qualifications for the Radiation Safety Staff ....... 8
3.3.1 Mill Manager ................................. , . . . 8
3.3.2 Radiation Safety Officer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.3.3 Radiation Technician . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.4 Administrative and Operating Procedures . . . • . . . . . . . . . . . . . . . . . . 8
3.5 Inspections and Audits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.5.1 Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.5.2 ALARA Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.6 Radiation Safety Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
4.0 RADIATION SAFETY CONTROLS AND MONITORING . . . . . . . . . . . . . . . . . . 12
4.1 Ventilation and Effluent Control . . . . . . . . . . . • . . . . . . . . . . . . . . . . 12
4.2 In-Plant Monitoring Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.3 Personnel Monitoring Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.4 External Radiation Control Program . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.4. 1 Occupational Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.4.2 External Radiation Surveys . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.5 Internal Radiation Control Program .............. ·......... . . . 14
4.5.1 Airborne Radioactivity Surveys . . . . . . . . . . . . . . . . . . . . . . . 14
4.5.2 Internal Exposure to Radioactivity . . . . . . . . . . . . . . . . . . . . . 15
4.5.3 Respiratory Protection Program . . . . . . . . . . . . . . . . . . . . . . . 16
4.6 Bioassay . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . · 17
4. 7 Contamination Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
4. 7.1 Personnel Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
4. 7.2 Surface Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 8
4. 7.3 Disposal of Contaminated Equipment . . . . . . . . . . . . . . . . . . . 18
4.8 Quality Assurance and Calibration . . . . . . . . . . . . . . . . . . . . . . . . . . 19
5.0 RESTRICTED AREA MARKINGS AND ACCESS CONTROL . . . . . . . . . . . . . . . 19
TABLE OF CONTENTS
(continued)
6.0 EMERGENCY PROCEDURES AND PREVENTATIVE MEASURES 19
7.0 GROUNDWATER PROTECTION .................................. 20
8.0 MILL SITE DECOMMISSIONING AND RECLAMATION . . . . . . . . . . . . . . . . . 20
9.0 SURETY REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
10.0 INSPECTION HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
11.0 CONCLUSION INCLUDING SAFETY LICENSE CONDITIONS . . . . . . . . . . . . . . 24
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
LIST OF TABLES
Page
TABLE 10.1 Summary of NRC Inspections at Energy Fuels Nuclear, Inc.'s
Figure 2.1
Figure 2.2
Figure 3.1
White Mesa Uranium Mill . . . . . • . . . . . . . . . . . . • . . . . . . . . . . . . . . 21
LIST OF FIGURES
Location of the White Mesa Uranium Mill . . . . . . . . . . . . . . . . . . . . . . 4
White Mesa Uranium Mill, Generalized Process Flow Sheet . . • . . . . . . . 5
White Mesa Uranium Mill, Organizational Chart . . . . . . . . . . . . . . . . . . . 7
ii
1 .0 INTRODUCTION
By application dated August 23, 1991, and supplements dated December 13 and 17,
1991, January 13 and April 7, 1992, Umetco Mir.;;rals Corporation (Umetco) requested
renewal of Source Material License SUA-1358 for the White Mesa Uranium Mill, which is
located in San Juan County, Utah. By letter dated March 29, 1994, Umetco requested
transfer of the license and a change in ownership of the mill to Energy Fuels Nuclear, Inc. ·
(EFN). On May 25, 1994, the license was amended to change designation of the licensee
to EFN. In the acquisition agreement between EFN and Umetco, EFN agreed to abide by •
all commitments and representations made to NRC by Umetco.
With this license renewal, NRC will be authorizing continued mill operations under the
Performance-Based License Condition (PBLCl 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 aoplication, or
• Conduct tests or experiments not presented in the application, 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 the license (excluding material
referenced in the Performance-Based License Condition). or impair the
licensee's ability to meet all applicable NRC regulations.
(2) 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 NRC's conclusions
regarding actions analyzed and selected in the EA.
Otherwise, the licensee is required to submit an application for a license
amendment from NRC. The licensee's determinations whether the above conditions
are satisfied will by 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 expertise in implementation of any changes; and
one member shall be the corporate radiation safety officer or equivalent. Additional
members may be included in the SERPas 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.
1
The licensee shall maintain records until license termination of any changes made
pursuant to the PBLC. These records shall 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
shall furnish an annual report to NRC that describes such changes, tests, or
experiments; including a summary of the safety and environmental evaluation of
each. In addition, the licensee shall annually submit any pages of its license
application that have been revised to reflect changes made under this condition.
EFN has not yet submitted, for NRC review and approval, its standard operating
procedures (SOPs) for operation of the SERF'. Therefore, NRC will require, by license
condition, that EFN submit the SOPs by March 31, 1997, and until such time as NRC
approves the SOPs, EFN will not be authorized to implement the PBLC. EFN agreed to this
license condition by telephone conversations on December 31 , 1996.
NRC's inspection function remains unchanged with the administration of Performance-
Based Licensing. Operational changes, regulatory commitments, and recordkeeping
requirements implemented by EFN through the PBLC are subject to NRC inspection and
possible enforcement actions.
1 . 1 Description of Proposed Action
The proposed action is to renew SUA-1358 for operation of the White Mesa mill at a
maximum production rate of 4380 tons of yellowcake per year.
1.2 Background Information
Source Material License SUA-1358 was originally issued by NRC on August 7, 1979,
pursuant to 10 CFR Part 40. This license authorizes the licensee to possess :; yproduct
material in the form of uranium waste tailings and other uranium byproduct waste
generated by operations at the White Mesa uranium mill, in accordance with the conditions
specified therein. SUA-1358 was renewed in 1985 and was due to expire on September
23, 1991. Umetco submitted a license renewal application by letter dated August 23,
1991, and NRC notified Umetco that the license was in timely renewal by letter dated
November 7, 1 991 .
Source Material License SUA-1358 and ownership of the White Mesa mill were transferred
from Umetco to EFN in May 1994. The mill was operated on a continual basis from May
1980 until February 1983, and then intermittently from October 1985 to the present time.
1.3 Review Scope
The safety review of EFN's request for license renewal included evaluations of (1) the
renewal application dated August 23, 1991; (2) supplementary information submitted by
letters dated December 13, 1996 and January 30, 1997; (3) the compliance history for
the White Mesa mill since September 1985; and (4) the monitoring data required under
SUA-1358.
2
EFN's proposed programs were also evaluated against NRC regulations as specified in
10 CFR Parts 20 and 40, and appropriate NRC staff guidance.
2.0 AUTHORIZED ACTIVITIES
EFN is currently authorized for commercial operation of the White Mesa mill. By license
condition, yellowcake production cannot exceed 4380 tons per year.
2.1 Facility Description
The White Mesa mill is located in San Juan County, Utah, approximately 9.5 kilometers
(6 miles) south of Blanding, Utah (see Figure 2.1 ). Major mill features include the mill
buildings, tailings impoundments, an ore stockpile area, and a small sampling plant which
is used infrequently to determine the uranium content of tolled ores. The ore is initially
processed in the main mill building, which contains a semi-autogenous grinding (SAG) mill,
an acid leach circuit, and a counter current decantation (CCD) circuit. A separate building
houses the two solvent extraction circuits, one for uranium and one for vanadium. The
uranium-bearing solution is returned to the mill building where it is precipitated, dried, and
barrelled. A reproduction of the generalized flow chart for uranium milling is included as ·
Figure 2.2.
The mill occupies approximately 20 hectares (hal (50 acres) and the tailings system
another 182 ha (450 acres). The tailings system consists of four partially below-grade,
synthetically-lined disposal cells.
2.2 Operations
Operations at the White Mesa mill begin with the weighing, sampling and stockpiling of ore
received from various mines. Mine ore, as well as stockpiled and crushed ore, is then fed
to the SAG mill. The ground ore is stored as a wet slurry in two mechanically-agitated
storage tanks. The subsequent processing involves two-stage acid leaching, followed by
the recovery of uranium-bearing pregnant solution in the CCD system. Tailings are slurried
by pipeline to the lined impoundments.
The uranium is recovered from the pregnant solution through a conventional solvent
extraction system. Vanadium, when recovered, is stripped from the barren uranium
raffinate using a separate solvent extraction circuit.
3.0 FACILITY ORGANIZATION AND ADMINISTRATIVE PROCEDURES
3.1 Organization
EFN, the operator of the White Mesa mill, has its corporate headquarters located in
Denver, Colorado. The corporate office supplies any necessary support to the mill staff.
Milling operations are managed from an office located at the site.
By letter dated December 13, 1996, EFN submitted revised organizational charts for full
operational and standby modes at the mill (Figure 3.1 ). During both modes of operation,
3
UINTAH AND OURAY
INDIAN RESERVATION
Figure 2.1 Location of the White Mesa Uranium Mill
4
i H2o--~
.,.
' I
I
I
Ore Stockpiles
___ ,.
Crushing and
Grinding Circuit
• i
Pre leach
Thickening
Acid
Leaching
ceo
Washing
Circuit
H2S04
+--NaCI03
Steam
Atmospher·,o ...
Dust Collection
Pregnant Leach
Solution
Organic
l
Solvent
Extraction
Barren f
1
. 1 Pregnant
Organic Organic _ _,_, ____ __.__
Barren
Leach
NaCI__.,
Pregnant
Strip
Stripping
--'--------"-----,
NH3~ Precipitation
and
I Thickening I
I
; ' I i
~ i
I Drying
Atmosphere
j
Barren
Strip
Tailings Impoundment ' • Optional Wet Scrubbing r-to
Vanadium
Recovery
'
Yellowcake
Product
Figure 2.2 White Mesa Uranium Mill, Generalized Process Flow Diagram
(modified from NRC, 1979)
5
the Maintenance Superintendent, the Mill Superintendent. and the Radiation Safety Officer
(RSO) report directly to tne Mill Manager. In addition, the RSO is authorized to escalate
concerns to the Corporate Environmental Manager or to the President of C:FN.
The Corporate Environmental Manager reports to the President of the company, and
provides services to the various operating units relative to environmental, radiation safety,
occupational health, and permitting activities. This individual performs periodic audits of
the facilities to identify potential liabilities, ensure regulatory and corporate standard
compliance, and, as required, recommend corrective measures.
The Mill Manager is responsible for conducting the firm's uranium milling operations in a
safe and efficient manner. This individual is fully responsible for milling operations,
including safety and environmental programs and security practices.
The Maintenance Superintendent reports directly to the Mill Manager, and has
responsibility for all maintenance activities at the mill, as well as responsibility for ensuring
compliance with applicable health, safety, and envi.ronmental practices and standards.
The RSO is directly responsible for developing, implementing, monitc;ing, and reporting
activities that ensure that the mill radiation safety program meets applicable standards.
NRC finds this organizational structure to be acceptable.
3.2 Radiation Safety Staff and Responsibilities
As stated above, the White Mesa RSO has the direct responsibility for developing,
implementing, monitoring, and reporting activities that ensure that the mill radiation safety
program mee<s applicable standards. This includes monitoring, maintenance, and
evaluation of personnel exposure and plant area surveys; determination of occupational
work modifications relative to radiation protection; personnel radiation protection training;
maintenance of plant radiation monitoring equipment; and report preparation for regulatory
agency compliance. This individual also reviews plant procedures and equipment and
develops and coordinates policy adherence.
The Radiation Technician is responsible for performing radiation monitoring measurement
throughout the mill area. This individual provides all necessary record keeping, survey data
accumulation and analysis, instrument performance calibrations, and quality control
requirements.
The Environmental Technician conducts the monitoring necessary to comply with
regulatory permits and licenses. This individual's responsibilities include mill emission
sources, solid and liquid waste disposal systems, and off-site environmental concerns, as
well as responsibility for the tailings reclamation technology and operating supervision of
the tailings disposal cells.
Although the Radiation Technician and the Environmental Technician report directly to the
RSO, each has the authority to escalate concerns directly to the Mill Manager or to the
6
appropriate level of corporate management. Along with the RSO, individuals in these
positions have the authority to cancel, postpone, or modify any operation or process that
poses an immediate radiological, safety, or environmental hazard.
The staff finds the organization of the Radiation Safety Staff to be acceptable.
3.3 Minimum Technical Qualifications for the ~adiation Safety Staff
EFN will require the following minimum qualifications of radiation protection personnel
associated with uranium processing at the White Mesa mill:
3.3.1 Mill Manager
An individual filling the position of Mill Manager must have a bachelor's degree in
engineering or a related physical science, or equivalent experience in ttie management
and/or operation of uranium processing operations.
3.3.2 Radiation Safety Officer
EFN states that the RSO must meet the requirements of 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 radiation protection; (2) appropriate health physics
experience; (3) specialized classroom and biannual refresher training; and (4) appropriate
specialized knowledge.
3.3.3 Radiation Technician
EFN will require the Radiation Technician to meet the qualification requirements for Health
Physics Technicians, as identified in Regulatory Guide 8.31. These qualifications include
specified levels of education, training, and relevant experience.
The staff finds the above qualifications for radiation safety personnel to be acceptable.
3.4 Administrative and Operating Procedures
Activities at the mill which involve design, procurement, construction, pre-operational
checks, or operations and maintenance of safety-or environmentally-related equipment will
be authorized by written procedures approved by the RSO and/or the Mill Superintendent.
These procedures will comply with EFN's standards, the conditions of the parmits and
licenses, and the existing regulatory requirements. The Maintenance Superintendent will
be responsible for assuring compliance.
Administrative policies and procedures are documented to clearly delineate the authorities
and responsibilities for each level within the facility with regard to environmental, radiation
protection, and safety-related activities. The licensee provided, as appendices to the
renewal application, detailed administrative and operating procedures, as well as the
proposed radiation protection and environmental monitoring procedures. The procedures
8
..,
c5" c ~
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w
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cO
Ol
:1.
N Ol e.
0 :J
Ol
Environmental
Manager
,--I
Maintenance Purcnas1ng
Superintendent Agent
Energy Fuels Nuclear, Inc.
I
I
I
I
I
I
I
I
I
I
White Mesa Mill
Organizational Chart
Prestdent
1-M11J Manager --,
I I
I I
I I
I :
I I
I Rad1at1on Satety I 'I Offtcer I I I
I I l r ____ J I
I I : I
I
Maintenance Electrical I Envuonmental -Safety
Foreman Foreman I Techntcian Tec:hmcian I -I
I
I
I
I
Instrument I Radiation
Technician Technician r-.
Admimstratlvt l ~ Supenotendent and Personn~
l I
Warehouse [-Ch1efC Foreman
Mill
Shift Foremen M1HMet
(4)
al!urg1st
cover all aspects of mill operations. EFN committed to reviewing these procedures
annually.
Although the licensee committed to reviewing th.; SOPs on an annual basis, they did not
state that the RSO will perform and document this review nor that the appropriate SOPs
will be available to workers in their mill work areas. In accordance with recommendations
in Regulatory Guide 8.31, EFN is currently required under SUA-1358 to meet these
conditions, and will continue to be so required.
The licensee has stated that any non-routine maintenance activity which may, by the
determination of the RSO, exceed 25 percent of the 10 CFR Part 20 limits requires a
Radiation Work Permit (RWP). The RSO will provide a monthly updated listing of those
areas that may exceed this criteria to the Maintenance Superintendent and Mill
Superintendent. This listing will be used as a guide by the mill staff; however, all
non-routine activities require review by the RSO.
An RWP will be obtained in the following manner:
1. The Maintenance Superintendent, Mill Superintendent, or their designee, will define,
in writing, the need for the non-routine activities. The request will address the
specific work location(s), the estimated work duration, the type of work to be
performed, and the personnel to be utilized. This information will be included in
the RWP.
2. The RSO, or designee, will review the RWP to ensure that the proposed work will
not present a health hazard to the employee(s) involved, and will give written
approval. The completed RWP will define (1) time limitations for job performance,
(2) the personnel protective equipment to be used, and (3) the monitoring
surveillance needed for the activity.
3. All supervisors will be given training in and copies of the requirements for using
RWPs, with the original permit remaining on file for five years.
4. Any supervisor found to be knowingly and willfully violating these procedures will
be issued a written warning, and the situation will be reviewed by appropriate
management for remedial action.
The staff concludes that the proposed program is in accordance with the recommendations
contained in Regulatory Guide 8.31, and is, therefore, acceptable.
3.5 lnsoections and Audits
3.5.1 lnspec~ona
EFN's proposed program for radiation safety inspections is extensive. The operating mill
foreman, or his designee, will perform and document a daily visual surveillance of all mill
areas to insure proper implementation of good radiation safety practices. On a weekly
basis, the radiation safety staff will perform and document an inspection of all work and
9
storage areas, and report to the RSO any items of noncompliance with operating
procedures, license requirements, or safety practices affecting radiological safety. The
RSO performs a monthly documented walk-through inspection of all work and storage
areas to ensure that the radiation safety program is functioning as required.
A documented daily inspection will be conducted of the tailings impoundment area by
personnel trained to detect visible evidence of impoundment instability or operational
malfunctions.
3.5.2 ALARA Audit
EFN has committed to performing audit reviews to ensure managerial control of the
radiation safety program. An annual ALARA (As Low As is Reasonably Achievable) audit
will be performed by a team of personnel consisting of the RSO, the Maintenance
Superintendent, a member of either the Corporate Occupational Health Protection staff or
the Corporate Environmental Affairs staff, and a corporate representative of EFN. The
results of this audit are provided to the Manager of Environmental Health and Safety, the
Maintenance Superintendent, and the Mill Manager.
The audit review consists of:
1. A summarization of exposure records
2. Bioassay determinations
3. Inspection documentation
4. Training program activities
5. Radiation protection meeting records
6. Mill radiological survey data
7. Environmental effluent and monitoring data
8. Overexposure records
9. Review of modified procedures for the period, and
10. Reviews of RWPs.
The resulting audit report will specifically discuss trends in personnel exposures, control
of effluent equipment, management response to radiological protection concerns, and
recommendations to further ALARA implementation. The Mill Manager is responsible for
remedial action in response to the recommendations made in the audit.
The proposed makeup of EFN's ALARA audit team is not consistent with Regulatory Guide
8.31. In this guidance document, the NRC recommends that the RSO should accompany
the audit team but should not be a member of that team. Therefore, the NRC staff will
require that EFN conduct its annual ALARA audits as outlined in Regulatory Guide 8.31.
EFN agreed to this license condition in a telephone call on March 10, 1997.
The staff concludes that EFN's audit program, as modified by the staff, is acceptable.
10
3.6 Radiation Safety Training
EFN stated that the purpose of an in-house radiation safety training program is ( 1) to place
in proper perspective, for the employee, the potential short and long-term radiation hazards
associated with the job; (2) to acquaint the employee with the practices instituted by
management to keep occupational exposures ALARA; and (3) to ensure that the employee
has an understanding (both initially and over the duration of their employment) of the
radiation procedures which should be followed.
The licensee assured that each person, upon reporting for employment at the mill, will
receive instruction in mill and personnel safety, including radiological protection
procedures, from a qualified instructor. The instruction will include on-the-job
demonstrations of proper safety precautions, and measures to be taken to minimize
radiation exposures. ·each employee will also be provided a safety manual, which covers
radiation safety and industrial safety procedures, including personal hygiene instructions
for use of monitoring and safety equipment and procedures for handling spills and
maintaining clean working conditions. Each employee will be required to pass a written
test addressing their understanding of radiation safety and hygiene.
The employee's understanding and retention of proper practices will be verified by the
supervisor at the work location through periodic checks. If the employee does not exhibit
sufficient understanding of the safety procedures, they will receive further instruction from
their supervisor. This procedure will be repeated until satisfactory retention is
demonstrated. On-the-job training and testing will be conducted and the results recorded
to ensure that each employee understands the applicable radiation protection practices.
In addition, EFN stated that a portion of the monthly mill safety meeting will be set aside
for discussion of radiation protection procedures, and that one monthly meeting per year
will be set aside for reindoctrination of the mill staff in radiation protection. Each
employee will be tested annually by the RSO on their understanding of radiation protection
as it relates to their job. All supervisors will be required to periodically attend specific
training courses in radiation and industrial protection, so that they will be better able to
provide and evaluate specific job-related training.
The licensee also stated that training of on-site contractors would occur prior to the
conduct of their work. The training will consist of topics similar to those used for newly
hired employees. Complete details of the content of all in-house training, including
contractor training, were submitted as Appendix F to the renewal application.
The staff has determined that the radiation safety training program proposed by the EFN is
in accordance with the staff guidance spe·~ified in Regulatory Guide 8.31, and is,
therefore, acceptable.
11
4.0 RADIATION SAFETY CONTROLS AND MONITORING
4.1 Ventilation and Effluent Control
a. Sampling Plant
Effective as of this license renewal, the sampling plant will no longer be used as
part of the process. Ore will be stockpiled at the ore pads and then taken directly
to the grizzly. From the grizzly, ore is fed at a controlled rate to the grinding circuit.
Dust suppressants are used on the ore to m'lintain windblown control.
b. Mill
Dust generated in the ore hopper area is collected in a reverse jet baghouse
dust-collecting system. In addition, a dust suppression spray system installed in
the mill feeding system is used when exceedingly dry ores are being fed to the SAG
mill. Water added for these purposes remains with the ore as it is further
processed.
Yellowcake particles carried in flue gases from the dryer and packaging area pass
through wet fan scrubbers (one on the dryer and one on the packaging process).
The solution and particulates collected from the scrubber. are recycled to the No. 1
yellowcake thickener. ·
Two wet dust collectors also are installed to collect and recycle dust generated
from the vanadium drying operation. An isolated portion of the building is utilized
for precipitation, drying and packaging of the vanadium. Since the uranium is
removed prior to vanadium recovery, a very limited release of radioactivity is
expected in the vanadium drying and fusion step.
In the mill, the processing buildings and equipment are provided with ventilation
fans, hoods and ducting to control the concentration of gaseous effluents. A
forced air ventilation system designed for the entire solvent extraction and stripping
buildings removes kerosene vapors. This ventilation system is designed to provide
up to six air changes per hour. The ventilation fan is checked visually for proper
operation on a daily basis.
c. Area Sources
EFN will conduct a weekly inspection of the ore stockpile area to determine
whether dust suppression measures are necessary. The inspection is documented
by the radiation staff and filed with the radiation safety department. If dusty
conditions are present, the roadways and/or stockpiles will be sprayed with water
or stabilized to minimize dusting. A log sheet of water applications is maintained by
the radiation staff.
Criterion 8 to 10 CFR Part 40, Appendix A. provides requirements concerning monitoring
of effluent control equipment and requires mill licensees to take corrective actions or to
12
suspend yellowcake drying and packaging operations if the effluent control equipment is
not functioning as designed. EFN is required to operate in accordance with the provisions
of Appendix A.
The staff concludes that the mill ventilation and effluent control program is acceptable.
4.2 In-Plant Monitoring Data
Airborne gross alpha (uranium) samples are collected monthly from 26 mill areas, while 5'
additional locations in the yellowcake process an;a are sampled weekly during mill
operations. During mill operations from 1988 to 1990, at which time 23 areas were
sampled, the highest annual average concentration was less than 20 percent of the
maximum permissible concentration (MPC). During mill operations in 1995, area
concentrations were less than 25 percent of the derived air concentration (DAC) at all
sampling locations except for the yellowcake dryer and packaging enclosures, yellowcake
packaging, and the SAG mill. EFN posted these areas as Airborne Radioactivity Areas.
Radon daughter concentra~ions are measured at 27 locations throughout the mill on a
monthly basis. From 1988 to 1990, the highest employee expo~ure to radon daughters
was 26 percent of the maximum permissible exposure at the SAG mill. Concentrations
measured during 1995 were lower than those observed during previous operating periods,
which EFN attributes to modifications made to the mill demister system and improved mill
ventilation systems.
EFN conducts beta-gamma surveys on a quarterly basis at 26 locations throughout the mill
complex. Exposure rates since 1985 have ranged from less than 2 mR/week up to 125
mR/week, measured in the ore storage area in 1985. Ambient gamma levels observed in
1995 were 15 mR/week. EFN has posted the yellowcake storage yards, the top floor of
the yellowcake calciner, the ore stockpile area, the solvent extraction feed lines, the
solvent extractor mix tanks, and the calcium fluoride storage areas as Radiation Areas.
4.3 Personnel Monitoring Data
Employees are required to record on a daily time card the amount of time spent in areas
monitored for uranium dust and radon progeny. Details concerning the methods used by
EFN 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 are calculated.
Personnel exposure records are retained onsite and are accessible only to the radiation
safety staff and the individual employee. Individuals other than the radiation safety staff
can obtain a copy of an employee's exposure history only with the employee's signed
consent to that effect.
13
4.4 External Radiation Control Program
4.4.1 Occupational Exposure
The licensee has committed to using film or thermoluminescent dosimeter (TLDJ badges to
determine individual exposures. Badges will be assigned to each employee working at the
facility within 30 days of employment, and the badges will be analyzed on a quarterly
basis. The cumulative occupational dose of the employee will be filed in accordance with
the requirements of 10 CFR Part 20. Employees receiving an exposure exceeding 25
percent of the 1 0 CFR Part 20 limits will have their job assignments modified, and the
licensee will conduct a review of the conditions which caused the action level to be
exceeded.
The staff concludes that the external exposure monitoring program is in accordance with
Regulatory Guide 8.30, and is, therefore, acceptable.
4.4.2 External Radiation Surveys
The licen:::ee stated that radiation area monitoring will be used throughout the mill to assist
in detecting abnormal operating conditions. A combination of beta and gamma radiation
measurements will be obtained monthly at 37 locations in the restricted area. The
locations are listed in Table 5.4-1 of the renewal application. Measurements will be taken
at a distance of one centimeter from each source. The radiological health monitoring
procedures submitted as Section 2.4 of Appendix D to the renewal application provides
details on all monitoring techniques to be utilized at the White Mesa mill.
The staff finds that the external radiation monitoring program is in accordance with
Regulatory G:Jide 8.30, and is, therefore, acceptable.
4. 5 Internal Radiation Control Program
4.5.1 Airborne Radioactivity Surveys
a. Uranium
EFN proposes to use several forms of airborne radionuclide sampling to determine
personnel exposure to uranium-bearing dust. Area monitoring at 23 mill locations
will provide the main approach to determining personnel exposure. Areas
associated with yellowcake are sampled weekly, while other locations are sampled
on a monthly basis. The monitoring locations are shown on Table 5.4-2 of the
renewal application.
EFN indicated that area monitoring for airborne uranium will be accomplished
utilizing air samplers calibrated to forty liters per minute (lpm) with a sample
duration of sixty minutes. Analysis of samples is performed at the White Mesa
Laboratory using fluorometric methods to achieve standard lower level of detection
(LLD) requirements with sample turnaround times of less than a week. Sampling
will be performed under conditions typical of employee exposures. A record of the
14
state of operation of both process and effluent control equipment L 1d ventilation
conditions will be maintained along with area sampling results.
Yellowcake calciner and packaging operators are required to wear individual air
samplers once per week. In addition, mill operating and maintenance personnel
working in processing areas where the potential exposure is projected to exceed 25
percent of 10 CFR Part 20 limits for uranium dust will be monitored with individual
air samplers on a periodic basis to establish typical uranium dust exposures for
these individuals. Individual air samplers consist of a sampling pump and lapel filter
holder capable of sampling at a rate of two lpm for eight hours.
b. Radon progeny
The licQnsee stated that radon progeny will be measured on a monthly basis at the
23 locations used for air particulate sampling, with weekly sampling in areas that
exceed 25 percent of a working level during production periods. The modified
Kusnetz sampling and analysis procedure will be utilized to determine radon
concentrations.
The staff finds that the proposed program for airborne particulate monitoring is in
accordance with Regulatory Guide 8.30, and is, therefore, acceptable.
4.5.2 Internal Exposure to Radioactivity
Personnel time in the monitored areas is recorded on a daily time card by the employee.
Using this information, and the respective area airborne concentrations, an employee
exposure record is developed. When routine work is performed, assessment of an
individual's exposure to airborne natural uranium and radon daughters are calculated using
the methods described .above. Quarterly breathing zone samples using portable samplers
are collected to assure reliability of this procedure.
When non-routine maintenance work is performed, accurate time records are kept to
calculate exposures to natural uranium. Breathing zone samples are taken using portable
samplers to assure accurate assessment of exposures during non-routine work
assignments.
EFN proposes to review the observed time spent in each area where routine work is
performed. The review will be recorded and the accuracy of the observation reviewed
quarterly, or when major changes are made in job assignments.
If an employee reaches an action level of 25 percent of the DAC based on the
time-weighted exposure over a period of one quarter, the RSO will institute an
investigation of the work record and exposure history to identify any problem areas. If
problem areas are noted, corrective measures will be taken to ensure that the exposure is
as low as is reasonably achievable.
15
The 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
EFN's proposed respiratory protection program includes a management policy statement
and written operating procedures which address (a) engineering controls used to meet
ALARA goals, (b) decontamination of equipment, (c) routine, non,routine and emergency
use of respirators, (d) a list of circumstances duri-.g which re!:ef from respirator use is.
authorized, (e) training requirements, (f) annual fit testing requirements, (g) annual physical
examination requirements, and (h) a maintenance, cleaning and storage policy for
respirators. The licensee stated that only National Institute of Safety and Health (NIOSH)
and Mine Safety and Health Administration (MSHA) certified respirators with approved
High Efficiency Particulate Arrestor (HEPA) filters are to be used.
The Maintenance Superintendent is responsible for ensuring that a respiratory protection
program, meeting or exceeding that specified by regulations, is established and maintained
for the employees under his jurisdiction. The RSO is responsible for the implementation
and direct control of the respiratory protection program.
The RSO has the following responsibilities:
A. Supervision of respirator selection procedure;
B. Establishment of training sessions about respiratory equipment for
employees;
C. Establishment of a continuing program of cleaning and inspection of
equipment;
D. Designation of proper storage areas for respiratory equipment;
E. Establishment of issuance and accounting procedures for uses of respiratory
equipment;
F. Establishment of medical screening program-procedures for employees
assigned to wear respiratory equipment;
G. Establishment of a periodic inspection schedule of those work
places/conditions -requiring respiratory equipment -to determine exposure·
and/or changing situations; and
H. A continuing evaluation of the above aspects to assure tneir continued
functioning and effectiveness. ·
A complete training program for employees and supervisors is included in the program. It
addresses the following topics: ( 1) the need for respirators, (2) respiratory hazards,
16
(3) engineering controls, (4) respirator selection, (5) fit testing, donning, and wearing of
respirators, (6) maintenance, storage and exchange requirements, (7) the circumstances
under which an employee can leave a hazardous area, (8) emergency respirator use,
(9) the regulations for respirator use, and (10) addidonal training requirements for
supervisors.
The NRC staff finds that the proposed respiratory protection program, as presented in
Appendix F of the renewal application, is in accordance with staff guidance as specified in
Regulatory Guide 8.15 and is, therefore, acceptable.
4.6 Bioassay
EFN has stated that urinalysis will routinely be performed on those employees that are
( 1) exposed to airborne yellowcake or involved in maintenance tasks in which yellowcake
dust may be produced, or (2) routinely exposed to airborna uranium ore dust. Specifically,
routine biweekly urinalysis testing will be performed on those employees who have worked
in yellowcake packaging, yellowcake precipitation, the grind area, ore feed area, and
sample preparation room. Baseline urinalysis will be performed on employees who have
been working on assignments that require a radiation work permit, or for any individual
that may have been exposed to airborne uranium or ore dust concentrations that exceed
25 percent of the DAC level.
A detailed procedure for collection, preparation and analysis of urine samples was
submitted under Section 1.4, "Radiation Protection Procedures Manual," to Appendix D of
the renewal application. EFN will perform the analyses in-house using a lower limit of
detection of 5 ug/1. Bioassay laboratory surfaces will be decontaminated to less than 25
disintegrations per minute (dpm) alpha per 100 cm2• EFN will use 25 percent of all
submitted samples for quality control (QC) checks. In addition, spikes and blanks will
accompany the samples, and the analysis will be performed by using fluorometric
techniques. Ten percent of all samples, including the OC spikes, blanks and duplicates,
will be sent to a contractor laboratory for analysis in order to compare results. EFN
committed to following the action levels presented in Regulatory Guide 8.22.
In-vivo body counting for lung burden of natural uranium or U-235 will not be routinely
conducted. Monitoring by an in-vivo body counter will be done at the discretion of the
RSO.
The staff concludes that the bioassay program proposed by EFN is in accordance with
Regulatory Guide 8.22, and is, therefore, acceptable.
4. 7 Contamination Control
4.7.1 Personnel Contamination
Personnel working within the mill area will be provided with change room, shower and
laundry facilities. Employees working in the yellowcake product areas or who perform
maintenance on equipment from these areas will be provided coveralls and will be required
to change and shower prior to leaving the mill. Employees will also be required to monitor
17
themselves with an alpha survey meter prior to leaving the mill site. Alpha contamination
on skin or clothes measured at greater than 1 000 dpm/1 00 cm2 shall be cause for
additional showering or decontamination and an investigation by the radiation safety staff.
On at least a quarterly basis, spot checks with a survey meter will also be made and
documented. Coveralls and contaminated clothing will be laundered on site.
The staff considers the proposed program for personnel contamination to be acceptable.
4. 7.2 Surface Contamination
EFN proposes that a combination of fixed and removable alpha radiation survey
measurements be obtained weekly at lunch rooms and offices in the restricted and
unrestricted areas. Measurements exceeding 1000 dpm/1 00 cm2 will require remedial
action by the management. In addition, the RSO is authorized to take action which is
deemed necessary to maintain levels ALARA. EFN also stated that respirators would be
surveyed prior to use and that activity of greater than 100 dpm/1 00 cm2 found on a
respirator will result in its removal from service for cleaning.
The staff finds EFN's surface contamination program to be acceptable.
4. 7.3 Disposal of Contaminated Equipment
In a submittal dated October 30, 1996, EFN stated that materials leaving the restricted
area must meet the requirements set out in NRC~s guidance document, "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
·Termination of License for Byproduct or Source Materials," dated September 1984. This
guidance document was revised in May 1987, and therefore, the licensee will be required
to follow thi~ more recent version, or a suitable alternative procedure approved by NRC
prior to any such release. EFN agreed to this license condition in a telephone call on
March 10, 1997.
The licensee assured that all material originating within the restricted area will be
considered contaminated until checked by the radiation safety staff. EFN will require any
manager who wishes to ship or release materials from the facility to inform the RSO prior
to any such release. No equipment or materials will be released without a documented
survey by the RSO. The RSO has the authority to deny release of materials exceeding the
guidelines. EFN also stated that the policy and documented release forms will be
periodically reviewed by the RSO and the Audit Committee.
EFN is currently required by license condition to dispose of mill-generated solid waste
materials considered as 11 e.(2) byproduct material (e.g., contaminated equipment and
parts) within Tailings Cell 2, in accordance with its procedure, "Radioactive Contaminated
Waste Disposal," amended as noted in NRC's approval letter of August 1, 1995. This
license condition will be retained in the renewal license. ·
The staff finds the proposed program, as modified, to be acceptable.
18
4.8 Quality Assurance and Calibration
Administrative Procedures (APs) are used by the licensee to provide uniform guidance and
consistency to mill activities. APs cover the sampling and calibration procedures which
are an integral part of the quality assurance program at the mill. APs will be reviewed
annually and updated as necessary to incorporate advances in technology and to prevent
systematic errors in sampling, monitoring and analyses.
Appendices D and E of the EFN renewal application delineate the current proposed
radiation protection and environmental monitoring procedures. Written operating
procedures are detailed in Appendix G for mill operations. Each procedure includes the
quality assurance actions which must be taken in order to properly evaluate measurement
techniques· and effectiveness of the procedure and specifies the type of equipment needed
to carry out the actions.· Each piece of equipment is described along with its specified
calibration frequency, check-out procedure, and specifications for normal operation.
Section 4 of Appendix F is designated as the EFN Quality Assurance Program. All
sampling, recording, inspection and review methc.ds are documented and detailed.
EFN has committed to calibrating all radiation monitoring equipment at least semi-annually,
and all air sampling equipment at least quarterly. In addition, all equipment will be checked
prior to use to ensure that it is operating correctly.
The staff concludes that the quality assurance program proposed by EFN is in accordance
with staff policy as specified in Regulatory Guides 4.15 and 8.31, and is, therefore,
acceptable.
5.0 RESTRICTED AREA MARKINGS AND ACCESS CONTROL
The mill and tailings area is fenced and posted with "Restricted Area" signs in accordance
with 1 0 CFR 20.1902. During operations, the mill normally will run seven days a week,
twenty-four hours a day. All visitors will be required to register at the office and will not
be permitted inside the plant restricted area without proper authorization and escort.
Contractors having work assignments will be given a security, safety, and radiation·
protection orientation t>rior to performing their duties without escort.
The staff concludes that the above markings 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 10 CFR Part 20 for areas within the mill, provided that all entrances
to the mill are conspicuously posted in accordance with Section 20.1902(e) and with the
words, "ANY AREA WITHIN THE MILL MAY CONTAIN RADIOACTIVE MATERIAL."
The proposed program for restricted area markings and access control is acceptable.
6 .. 0 EMERGE!\ICY PROCEDURES AND PREVENTATIVE MEASURES
EFN classified a spectrum of potential mill accidents based on their severity (in terms of
potential impact to health, safety, and the environment) and their probability of
occurrence. Given a specific severity level (e.g., "insignificant") and probability (e.g.,
19
"highly improbable"), EFN defined a risk category, which it used to determine the types of
safeguards that should be in place and functional. EFN ?.lso provided detailed emergency
procedures to address each type of accident.
Among the potential accidents identified and for which appropriate emergency procedures
and/or preventative measures implemented were: 11) major and minor pipe or tank leakage,
(2) fires, (3) tornados, (4) structural failure of the tailings cell dikes, (5) seismic damage
to the mill facilities, and (6) transportation accidents.
7.0 GROUNDWATER PROTECTION
Mill tailings and liquid wastes generated at the site are disposed in partially below-grade,
lined impoundments. These impoundments are equipped with leak detection systems
installed beneath the liner, which are inspected daily as part of EFN's tailings monitoring
program. A drainage system is also incorporated into the impoundment design for use in
dewatering and consolidating the tailings.
In addition, the licensee is re::;Jired under Appendix A to 10 CFR Part 40 to conduct a
groundwater detection monitoring program. EFN's program will involve quarterly sampling
of six point of compliance wells completed in the uppermost aquifer, with water·level
measurements taken and each groundwater sample analyzed for five indicator parameters.
Detailed discussion of EFN's monitoring programs for the tailings impoundments and the
groundwater system are provided in the Environmental Assessm"lnt (EA) prepared by the
staff in conjunction with this license renewal.
8.0 MILL SITE DECOMMISSIONING AND RECLAMATION
The mill decommissioning plan generally involves separating r.eusable 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 are proposed to be
buried within the tailings retention impoundment. Items released to the general" public will
meet the appropriate release guidelines.
The staff will require that a detailed decommissioning plan be submitted for NRC review
and approval at least twelve months prior to a planned final shutdown. The EA prepared
for this license renewal addresses planned site reclamation.
9.0 SURETY REQUIREMENTS
10 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
20
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.
The surety for the White Mesa mill is carried by Umetco, under an agreement between
EFN and Umetco. The current surety amount of $10,915,647 was reviewed and approved
by NRC in August 1996. EFN 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.
Following financial difficulties in February 1995, EFN agreed to voluntarily revise its surety
amount to cover reclamation and decommissioning costs for the site in its current state.
EFN is pursuing this action in two phases, with the first having been completed in June
1995 with NRC's approval of a revised surety amount of approximately $10.5 million. In
this initial phase, EFN reviewed all major reclamation cost centers, considering the then
current level of development and disturbance at the site. In the second phase, EFN is
reviewing all elements of the site reclamation plan and will, if necessary, revise the earlier
cost estimate. The licensee submitted its revised site reclamation plan by letter dated
February 28, 1997, for NRC review and approval.
10.0 INSPECTION HISTORY
NRC has conducted routine announced, routine unannounced, and reactive inspections of
EFN's White Mesa uranium mill since the renewal of SUA-1358 on September 26, 1985.
14 inspections have been conducted since that date, in which a total of 1 9 violations were
cited, the highest of which was of Severity Level IV. A discussion of inspection and
enforcement actions, including severity of violations is provided in NUREG-1600 (NRC,
July 1995). Minor violations are cited at Severity Level IV and major violations are cited at
Severity Levell. Typically, Severity Level IV 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 September 1985 is provided in Table 1 0.1. Severity Level V
violations were elimated with the revision to the NRC's enforcement policy in June 1995.
TABLE 10.1
SUMMARY OF NRC INSPECTIONS AT
ENERGY FUELS NUCLEAR, INC.'S
WHITE MESA URANIUM MILL
#OF SEVERITY
DATE TYPE' VIOLA-LEVEL COMMENTS/RESULTS
TIONS
1/14-16/97 A 0 --
1/23-25/96 A 1 IV Change in mill circuit without NRC approval.
Violation Closed.
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TABLE10.1
SUMMARY OF NRC INSPECTIONS AT
ENERGY FUELS NUCLEAR, INC.'S
WHITE MESA URANIUM MILL
#OF SEVERITY
DATE TYPE• VIOLA-LEVEL COMMENTS/RESULTS
TIONS
8/8-11/95 A 0 --
3/1-2/95 R 0 --Inspection prompted by EFN notification of fi-
nancial difficulties
4/11-13/94 A 4 all IV Failure to ( 1 ) perform adequate radiological
surveys of personnel leaving restricted area;
(2) survey vehicles leaving restricted area; (3)
use proper lower limits of detection for anal-
ysis of effluent and environmental samples;
and (4) conduct complete radiological release
surveys on all barrels of yellowcake in prepa-
ration for transportation to processor. Viola-
tions Closed.
3/11/93 A 2 IV Failure to perform and document exposure
calculations w/in one week of end of regu-
latory compliance period; Failure to perform
complete radiological survey on equipment re-
leased from restricted area. Violations Closed.
10/23/91 u 1 IV Weekly inspections of all mill site areas not
performed. Violation Closed
8/13-16/90 u 3 Two IV Exposure calculations did not use appropriate
One V airborne concentrations; Issuance records not
maintained for yellowcake precipitation
operations; Yellowcake packaging while emis-
sion control equipment not w/in design
performance specifications. Violations Closed
2/12/90 u 0 --
8/7-10/89 u 4 All IV Employee working in airborne radioactivity
area w/o respirator¥ protection; Annual surety
update not provided; RSO had not attended
required refresher training; SOP not reviewed
annually as required. Violations Closed
1/12-13/89 R 0 --
22
TABLE 10.1
SUMMARY OF NRC INSPECTIONS AT
ENERGY FUELS NUCLEAR, INC.'S
WHITE MESA URANIUM MILL
#OF SEVERITY
DATE TYPE• VIOLA-LEVEL COMMENTS/RESULTS
TIONS
4/11-13/88 u 2 IV Portions of tailings cells not wetted or
stabilized as required by 1 0 CFR Part 40
Appendix A; Lab surfaces for bioassay sample
analyses not surveyed for removable alpha
contamination. Violations Closed
3/16-18/87 u 2· IV, V Occupational exposure calculations not
documented; Tailings cell not markeQ as
authorized disposal site. Violations Closed
5/19-21/86 u 4 All IV Airborne radioactivity areas not posted; RWP
not issued for non-routine maintenance work;
Lapel sampling results not used to calculate
exposures; Oc.cupational exposure calcula-
tions not documented. Violations Closed
10/4/85 R 2 IV Required training not given for tailings
impoundment inspections; Site inspections
not performed in required manner. Violations
Closed
• A = Routine Announced; R = Reactive; U = Routine Unannounced
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;
(2) the licensee must have a successful inspection record, with no violations
more serious than Severity Level IV;
(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).
Based on its review, the staff finds that EFN is a qualified licensee, and therefore, a
ten-year license term is appropriate.
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11.0 CONCLUSION INCLUDING SAFETY LICENSE CONDITIONS
Upon completion of the safety review of EFN's renewal application for a source material
license, the staff concludes that the operation of the White Mesa Uranium Mill, in
accordance with the following license conditions, is protective of health and safety and
fulfills the requirements of 10 CFR Parts 20 and 40. The staff, therefore, recommends
renewal of EFN's Source Material License SUA-1358, subject to the following conditions:
1. A. The licensee may, without prior NRC approval, and subject to the conditions
specified in Part B of this condition.
( 1) Make changes in the facility or process, as presented in the
application.
(2) Make changes in the procedures presented in the application.
(3) Conduct tests 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 specifically stated in this license, or impair the licensee's
ability to meet all applicable NRC regulations.
(2) 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 are consistent with the conclusions
of actions analyzed and selected in this EA.
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 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.
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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 condition. 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. In
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 by March 31, 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.
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 shall 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 ccpy 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 RSO before implementation and whenever
a change in procedure is proposed to ensure that proper radiation protection
principles are being applied. In addition, the RSO 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
10 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 within this facility may contain radioactive material. •
4. The licensee shall maintain an NRC-approved financial surety arrangement,
consistent with 10 CFR 40, Appendix A, Criteria 9 and 10, 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, 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 in effect within 3 months of written NRC
approval. ·
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Annual updates to the surety amount, required by 10 CFR 40, Appendix A, Criteria
9 and 10, shall be submitted to NRC at least 3 months prior to the anniversary date
which is designated as June 4 of each year. If NRC has not approved a proposed
revision to the surety coverage 30 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 estima·:ed 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 surety instrument, Irrevocable Letter of Credit No.
SC0017012, issued by The Bank of New York in favor of NRC, as amended, May
10, 1994, to include a Standby Trust Agreement, shall be continuously maintained
by UMETCO in an amount not less than $10,915,467 for the purpose of complying
with 10 CFR 40, Appendix A, Criteria 9 and 10, until a replacement is authorized
by NRC.
5. The licensee shall submit a detailed decommissioning plan to NRC at least twelve
( 1 2) months prior to planned final shutdown of mining operations.
6. Rele<;se of equipment or packages from the restricted area shall be in accordance
with "Guidelines for Decontamination of Facilities and Equipment Prior to Release
for Unrestricted Use or Termination of Licenses for Byproduct or Source Materials,"
dated May, 1987, or suitable alternative procedures approved by NRC prior to any
such release.
7. 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
actions, shall be documented. Unless otherwise specified in the NRC regulations,
all such documentation shall be maintained for a period of at !east five (5) years.
8. The licensee shall perform an annual ALARA audit of the radiation safety program in
accordance with Regulatory Guide 8.31.
Please note that additional license conditions can be found in the Environmental
Assessment, which accompanies this licensing action.
26
REFERENCES
U.S. Nuclear Regulatory Commission !NRC], May 21, 1996, "Ten-Year License Terms for
Uranium Recovery Licensees." SECY-96-112.
NRC, July 1995, "General Statement of Policy and Procedures for NRC Enforcement
Actions (Enforcement Policy)," Office of Enforcement, NUREG-1600.
NRC, August 1988, "Bioassays at Uranium Mills." NRC Regulatory Guide 8.22, Rev. 1.
NRC, May 1987, "Guidelines for Decontamination of Facilities and Equipment Prior to
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special
Nuclear Material." NRC Division of Fuel Cycle, Medical, Academic and Commercial Use
Safety.
NRC, June 1983, "Health Physics Surveys in Uranium Mills," NRC Regulatory Guide 8.30.
NRC, May 1983, "Information Relevant to Ensuring That Occupational Radiation Exposures
at Uranium Mill Will Be As Low As Is Reasonably Achievable," NRC Regulatory Guide
8.31.
NRC, January 1983, "Hydrologic Design Criteria For Tailings Retention System," NRC
Staff Technical Position WM-8201.
NRC, October 1980, "Operational Inspection and Surveillance of Embankment Retention
Systems for Uranium Mill Tailings," NRC Regulatory Guide 3. 11.1 .
NRC, May 1979, "Final Environmental Statement: Related to Operation of White Mesa
Uranium Project, Energy Fuels Nuclear, Inc . ." NUREG-0556, Office of Nuclear Material
Safety and Safeguards.
NRC, February 1979, "Quality Assurance for Radiological Monitoring Programs (Normal
Operations) -Effluent Streams and the Environment," NRC Regulatory Guide 4. 15.
NRC, December 1977, "Design, Construction and Inspection of Embankment Retention
Systems for Uranium Mills," NRC Regulatory Guide 3. 11.
NRC, October 1976, "Acceptable Programs for Respiratory Protection." NRC Regulatory
Guide 8.15.
27
Enclosure 4
NRC Source Material License No. SUA-1358
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I NRC FORM 374
~7-94) U.S. NUCLEAR REGULATORY COMMISSION PAGE _}.__OF 9 PAGES
MATERIALS LICENSE
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title IO, Code of
Federal Regulations, Chapter I, Parts 30, 31, 32, 33, 34, 35, 36, 39, 40, and 70, and in reliance on statements and representations heretofore made
by 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 the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders of the
Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.
I.
2.
Licensee
Energy Fuels Nuclear, Inc.
6425 S. Highway 191
P.O. Box 789
Blanding, Utah 84511
3. License Number
4. Expiration Date
5. Docket or
Reference No.
SUA-1358
March 31 2007
40-8681
6. Byproduct, Source, and/or
Special Nuclear Material
7. Chemical and/or Physical
Form
8. Maximum Amount that Licensee
May Possess at Any One Time
Under This License
Natural Uranium Any Unlimited
SECTION 9: Administrative Conditions
9.1 The authorized place of use shall be the licensee's White Mesa uranium
milling facility, located in San Juan County, Utah.
9.2 All written notices and reports to the NRC required under this license, with
the exception of incident and event notifications under 10 CFR 20.2202 and
10 CFR 40.60 requiring telephone notification, shall be addressed to the
Chief, Uranium Recovery Branch, Division of Waste Management, Office of
Nuclear Material Safety and Safeguards.
9.3
9.4
Incident and event notifications that require telephone notification shall
be made to the NRC Operations Center at [phone].
The licensee shall conduct operations in accordance with statements,
representations, and conditions contained in the license renewal application
submitted by letter dated August 23, 1991, as revised by submittals dated
January 13, and April 7, 1992, November 22, 1994, July 27, 1995, December
13, 1996, and January 30, 1997, which are hereby incorporated by reference,
and May 10, 1994, for the Standby Trust Agreement, except where superseded
by license conditions below.
Whenever the word "will" is used in the above referenced documents, it shall
denote a requirement.
A. The licensee may, without prior NRC approval, and subject to the
conditions specified in Part B of this condition:
NRC FORM 374A
(7·94)
B.
c.
D.
U.S :LEAR REGULATORY COMMISSION PAGES I;
~
PAGE 2 OF 9
MATERIALS LICENSE
SUPPLEMENTARY SHEET
License Number SUA-1358
~Doc~ke~to~,~~7k~ren~re~N~u-4~~_-,8-6-8-1---------------l~
March 14 1997
(1) Make changes in the facility or process, as presented in the
application.
(2} 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.
(1) The change, test, or experiment does not conflict with any
requirement sp~c1{i~l~~~~ip this license, or impair the
licensee'(S.. ~ ... 'b-trto me'et :rl\..li{PJ_(able NRC regulations.
(2) There,~ nJ degradation in the essen~ ~afety or environmental
commi-tJi1 ts in the license application, <fi~rovided by the
appr(l~d reclamation plan. V
(3) ~h~ch~~-;..':~~t, or experiment ar~~Co[.S7st~with the eooclusion'~~~a~tions a~:lyze?t -7. ected 1n this EA.
' "' '· ~"! "\ (::::>-..... ) tf? ~ The Ueensee's d@t~l'i~tio)i:s'co'nc rrP·~<brt B of is condition,
shalT"itle mad~ b~:,a~?:to atfet.y;~_l!~1 Env1 ;~ ~11!-al. R~vie nel (SERP)." The SER~.-.'>Stl .. all c_ Ol\S1St~,~,iNri'iti. i11tlnt-"W-./t. :: _1n. d1v1dual~ One member of the S~P sh~_*Bt!aYe:~~X!l~U.s..e..-iq,j~iilf(enLciJld sh~ be responsible
for ma~ag. e~la1_ .. '<~l .. n .. ~. --~1.1}ilfl.-_hJ:_H":B_· __ ,,·1 &~i!i~~til. ~-".~_erf one§!··· ember shall have exper~$e 1 n.;.()~ratl on~f-;<1!14!~ , s:tructf.~'~ind sh,_ have
res pons-fbi 1 i ty:J~_~i~l~j~i • < , . ,ope_r ·. 15na 1 en~ .. ges; and, one member' .. $1ta 11 b!J..',tl\'j>;~orpohf!;t; , . ~a~i:Q&~. fety o.ffi cer ( CRSO) or
equi va 1 e~, wi tli th~~respon,~i'tfi.hty .J~trzassuri ~ltf..'!Tanges conform to radiatiorvs~fety and envtr\i11111ept)1 tifWlremen~.o:' Additional members
may be inc'!'~-~ in the SERP/.a'stapproprhte, t~ address technical
aspects sucLa1 health physics, groundwat!ll'\ltydrology, surface-water
hydrology, specifi.W~_·~earth sciences, and ot~r technical disciplines. Temp~r~ry f!lem~e~s of" pet,l!Ja'!!llt m~~ other than the three above-
speclf1ed 1nd1v1duals,·Jllay }'I( cotftul(a-nts.
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 condition. 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. In 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.
Ell NRC FORM 374A ll'l (7-94)
9.5
U.S. N, .EAR REGULATORY COMMISSION b--c;--,----___::_:.PA::,:G:.:_E_...d_3 _::::_OF _ __;9[___:_P_:::AG:_:E::::_S -~~
License Number
MATERIALS LICENSE
SUPPLEMENTARY SHEET
SUA-1358
Docket or Reference Number
40-8681
March 14, 1997
The licensee shall submit to the NRC by April 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.
The licensee shall maintain an NRC-approved financial surety arrangement,
consistent with 10 CFR 40, Appendix A, Criteria 9 and 10, 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, 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
in effect within 3 months of written NRC approval.
Annual updates to the surety amount, required by 10 CFR 40, Appendix A,
Criteria 9 and 10, shall be submitted to the NRC at least 3 months prior to
the anniversary date which is designated as June 4 of each year. If the NRC
has not approved a proposed revision to the surety coverage 30 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 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 surety instrument, Irrevocable Letter of Credit No.
S00017012, issued by The Bank of New York in favor of the NRC, as amended,
May 10, 1994, to include a Standby Trust Agreement, shall be continuously
maintained by UMETCO in an amount not less than $10,915,467 for the purpose
of complying with 10 CFR 40, Appendix A, Criteria 9 and 10, until a
replacement is authorized by the NRC.
9.6 Standard operating 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 established for non-operational
activities to include in-plant and environmental monitoring, bioassay
NRC FORM 374A
(7-94)
U.S. N, .EAR REGULATORY COMMISSION PAGE 4 OF 9 PAGES ~L~ice~ns~e~Nu~m~be~,--~~--~--~--L-------
MATERIALS LICENSE
SUPPLEMENTARY SHEET
SUA-1358
Docket or Reference Number
40-8681
March 14, 1997
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 radiation safety officer
(RSO) before implementation and whenever a change in procedure is proposed
to ensure that proper radiation protection principles are being applied. In
addition, the RSO shall perform a documented review of all existing
operating procedures at least annually.
9.7 Before engaging in any activity not previously assessed by the NRC, the
licensee shall administer a cultural resource inventory. All disturbances
associated with the proposed development will be completed in compliance
with the National Historic Preservation Act (as amended) and its
implementing regulations (36 CFR 800), and the Archaeological Resources
Protection Act (as amended) and its implementing regulations (43 CFR 7).
In order to ensure that no unapproved disturbance of cultural resources
occurs, any work resulting in the discovery of previously unknown cultural
artifacts shall cease. The artifacts shall be inventoried and evaluated in
accordance with 36 CFR Part 800, and no disturbance shall occur until the
licensee has received authorization from the NRC to proceed.
The licensee shall avoid by project design, where feasible, the
archeological sites designated "contributing" in the report submitted by
letter dated July 28, 1988. When it is not feasible to avoid a site
designated "contributing" in the report, the licensee shall institute a data
recovery program for that site based on the research design submitted by
letter from C. E. Baker of Energy Fuels Nuclear to Mr. Melvin T. Smith, Utah
State Historic Preservation Officer (SHPO}, dated April 13, 1981.
The licensee shall recover through archeological excavation all
"contributing" sites listed in the report which are located in or within
100 feet of borrow areas, stockpile areas, construction areas, or the
perimeter of the reclaimed tailings impoundment. Data recovery fieldwork at
each site meeting these criteria shall be completed prior to the start of
any project related disturbance within 100 feet of the site, but analysis
and report preparation need not be complete.
Additionally, the licensee shall conduct such testing as is required to
enable the Commission to determine if those sites designated as
"Undetermined" in the report and located within 100 feet of present or known
future construction areas are of such significance to warrant their
redesignation as "contributing." In all cases, such testing shall be
completed before any aspect of the undertaking affects a site.
Archeological contractors shall be approved in writing by the Commission.
The Commission will approve an archeological contractor who meets the
minimum standards for a principal investigator set forth in 36 CFR Part 66,
Appendix C, and whose qualifications are found acceptable by the SHPO.
I~
NRC FORM 374A
(7-94)
U.S. ;LEAR REGULATORY COMMISSION PAGE 5 OF 9 p GES i ~L~i,,-,,-,~Nu-m7~-,--~=s~u-A--1-3_5_8~~----~·~-~~
MATERIALS LICENSE
SUPPLEMENTARY SHEET
Docket or Reference Nu~r-8681
March 14, 1997
9.8 The licensee is hereby authorized 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
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.
9.9
9.10
The licensee is hereby exempted from the requirements of Section 20.1902 (e)
of 10 CFR Part 20 for areas within the mill, provided that all entrances to
the mill are conspicuously posted in accordance with Section 20.1902 (e) and
with the words, "Any area ~t\!=\n ~tt{'Oj.l.J may contain radioactive
materia 1." ~ p.. \ ' C. \.::1 (J {
Release of equiplllll,AU~ packages from the restrlfte,cl area shall be in
accordance witb<'"'!Ji\Jidel ines for Decontamination ovt~n ities and Equipment
Prior to Rel ea'ilt for Unrestricted Use or Termi nat i oej.,,.H Licenses for
Byproduct, Sourte:.~J>! Special Nuclear Material,_" d_~t~ay 1987, or suitable alternativ~ced~~~ . .approved by the NRC~~lil a~uch release.
SECTIOO "' Ope~iooal ~>' 1 , ~~.il~s ~stric{;d"'
10.1 The mill p.tPducti~>r:~~~ . .J:~~s~)~sjto~s of y: lowcake per year.
10.2 All_liquiW1fflu~r~tf;~~~fmm;·~~~~ng,fo4~i~h . ~xception of sa~1~ary ~a_.~tes, $lt.·:l;.· ~.~." .•. be r,~~-_,lf .. -. ~~ n 1t. ·lffi-m11_1_/\;p~CU1t" d1scharged to the
ta1l1ngs l~~~ndmen~~~i~:~lJjJU<~-J·~· c"
10.3
10.4
Freeboard li~i.~s fohCeH,s lei"; 3,.')~~~~ tonna,!Jif'::timits for Cell 3,
shall be as sta,ted in Sect'ioil13;0 tO:Af>peWf~ E of -tit~) approved 1 icense
application. ""1./ ··~r_,,_.\~;' 0 ..
Disposal of materf~ and equipment generated at:'
1
he mill site shall be
conducted as described .fit.= th!!, 1i c.ense11' s .$~mitta 1 s dated December 12, 1994
and May 23, 1995, with the f~Tlo)'l<1;flg .~dition:
A. The maximum lift thickness for materials placed over tailings shall be
less than 4-feet thick. Subsequent lifts shall be less than 2-feet
thick. Each lift shall be compacted by tracking of heavy equipment,
such as a Cat D-6, at least 4 times prior to placement of subsequent
1 ifts.
10.5 In accordance with the licensee's submittal dated May 20, 1993, the licensee
is hereby authorized to dispose of byproduct material generated at licensed
in situ leach facilities, subject to the following conditions:
A. Disposal of waste is limited to 5000 cubic yards from a single source.
NRC FORM 374A
(7-94)
10.6
10.7
U.S ;LEAR REGULATORY COMMISSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
PAGE 6
License Number
SUA-1358
Docket or Reference Nu~lf~ 8681
March 14 1997
OF 9 PAGES
B. All contaminated equipment shall be dismantled, crushed, or sectioned
to minimize void spaces. Barrels containing waste other than soil or
sludges shall be emptied into the disposal area and the barrels
crushed. Barrels containing soil or sludges shall be verified to be
full prior to disposal. Barrels not completely full shall be filled
with tailings or soil.
C. All waste shall be buried in Cell No. 3 unless prior written approval
is obtained from the NRC for alternate burial locations.
D. All disposal activities shall be documented. The documentation shall
include descript-io~q{ tlte ~11t" ~(the disposal locations, as well as all actions req · ;d'-&y' ttfis ~llai ill) An annual summary of the
amounts of waite \i<i posed of from off-~i(.~9j!nerators shall be sent to
the NRC. V V .. ..., )'
The licensee t~uthorized to receive and process s6.U/ce materials from the
Allied Sig~_ Cor~_r.~t~-i-on's Metropolis, Illinol.·sl_Ja~ty in accordance with the a ent ~e, st dated June 15, 199 • 7 ..L.
) .... ~> ··'"' -,
The 1 i ceni-is auth~r.~ o r,'l~~~ a . :: s sourciateri a 1 from
Allied Si~l, Inc. of~ . olii~~-IYli o·. -~ accorda. with the
amendment -~quest __ -_d-_a.te_d _____ -_-_~_-· ____ ~p-· ,t __ e emb~ ~QA 199-__ · $.. _--_'ffii_ .. Jl~-arne. nded 1 etters dated October ~ and N.oy.e. m~~,.., "--99&:<'... ~lJf;~ . , :;:::.
{fj '>~ ''-<:J ~"~~-,;' ! / / ::s.
SECTION 11: Moni5in~;1t~;d:W _ fPP ~~fkee~W Re~rements
11.1 The resu~t(;J sam~i~~~•-r"", .... ijJI~e.n~·t ~. the result~ of
calibrat1on ~~~-eq_u,prnent~\rel)l?,t;t_,;s·· ,'~n::~ud~d 1n_ spe ons, all meet1ngs and training "cpd,;ses requfredC,bf Jt,l\~1 i • .' and subsequent reviews,
investigations,·""Aild correctivevat.t'ihns, sha 1 be~ mented. Unless
otherwise specifledjin the NRC regulations all~!~~ documentation shall be
11.2
maintained for a pttrio~'!£f! .:~ le~st f_ive -~ yea'Fs.
The 1 icensee shall impleinenit'h~{:rfflknt and environmental monitoring
program specified in Section 5.5 of the renewal application as revised with
the following modifications or additions:
A. Stack sampling shall include a determination of flow rate.
B. Surface water samples shall also be analyzed semiannually for total and
dissolved U-nat, Ra-226, and Th-230, with the exception of the
Westwater Creek, which shall be sampled annually for water sediments
and analyzed as above. A sediment sample shall not be taken in place
of a water sample unless a water sample was not available.
C. Groundwater sampling shall be conducted in accordance with the
requirements in License Condition 11.3.
NRC FORM 374A
(7-94)
11.3
11.4
U.S ;LEAR REGULATORY COMMISSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
PAGE ]
License Number SUA-1358
Docket or Reference Nulflrs 8681
March 14, 1997
OF 9 PAGES ~
D. The licensee shall utilize lower limits of detection in accordance with
Section 5 of Regulatory Guide 4.14 (Revision 1), for analysis of
effluent and environmental samples.
E. The inspections performed semiannually of the critical orifice assembly
committed to in the submittal dated March 15, 1986, shall be
documented. The critical orifice assembly shall be calibrated at least
every 2 years against a positive displacement Roots meter to obtain the
required calibration curve.
The licensee shall implement a groundwater detection monitoring program to
ensure compliance to 10 CF!jo.PU}'t ?a ;Apl!6{ldix A. The detection monitoring
program shall be in a~c<if<l•rit~ llit'h ~~-tillfort. entitled, "Points of
Compliance, White ~~.Jiranium Mill," submWd,W letter dated October 5,
1994, as modifi~~\he following: ~.'( ~
A. The leak ·d~ection system for all ponds will b()hecked weekly. If
liquid iil. presen_. t_, it shall be analyzed fo_r c!J-)iil(}le, sulfate,
selenit.lftl; and'-p~ The samples will beitatfs.t'ictll,.v analyzed to
detern\1{1'1! if sig_·"'_:_~.~~. _, ___ ·_. nt 1 inear tre~.-.·· ···.····: ·· ~ and-t!Te results will be submrtt,ed to NRC,,f\\ revie~.;;;--, r.k ~ (')
B.
a proJWsed c!'rrec:ti~., ac}~f. . evJ' );~fld approv o NRC. The corr~~ive -~~_c.~Jp_ n"s~~_;'~lJ_cl __ ude ar,~'t~,_·q'lr __ 'qn del"i: eation of the
are ali extent -~'1!\l conce,nt)'f.im·: i'l.fiifz'iiri:Jo~/t~st i 1; ts.
C. The l{~nsee~-~~i£1~a~~,~-. :~·wel;,,MW-5~1, -12, -14, -15,
and -1ZJ,).on a qUaJt~·erl;w~a~ ,, -'S~~all bet~lyzed for chloride, pot~ssil!!JI-# _.n.· i~kel, a{'d l,lranii.UII};··.'i~_nd-re~ultHYsuch sa'!lpl ing. shall be 1ncludE;«"w1th the env1ronm~nt~H · onng .rt!Pbrts subm1tted 1n
accordanci!.··l)•th 10 CFR 40~~.\J"-0 '-
During extended pe-::?odSJif mill standby, E) i g~t~~~ur. annua 1 . samp ~ i ng for
U-nat! Ra-226, Th-230 a~Pb~g1o may ~e e~~nnated 1~ rout1ne anborne
sampl1ng show levels below II pe,r<tm~<~-tlf the appropnate 10 CFR Part 20
limits.
During periods of standby, sampling frequencies for area airborne uranium
sampling within the mill may be reduced to quarterly, provided measured
levels remain below 10 percent of the derived air concentration (DAC). If
these levels exceed 10 percent of the DAC, the sampling frequency should
follow the recommendations in Regulatory Guide 8.30.
11.5 Calibration of in-plant air and radiation monitoring equipment shall be
performed as specified in the license renewal application, under Section 3.0
of the "Radiation Protection Procedures Manual," with the exception that
in-plant air sampling equipment shall be calibrated at least quarterly and
air sampling equipment checks shall be documented.
~II NRC FORM 374A p (7-94) Ill.
U.S.~ ~EAR REGULATORY COMMISSION I
1-;-L~ice-ns-e""'Nu-m.,-ber PAGE 8 OF 9 PAGES ~~
SUA-1358
MATERIALS LICENSE
SUPPLEMENTARY SHEET
Docket or Reference Number
40-8681
March 14 1997
11.6 The licensee shall perform an annual ALARA audit of the radiation safety
program in accordance with Regulatory Guide 8.31.
SECTION 12: Reporting Requirements
12.1 The licensee shall submit to NRC for review, by June 30, 1997, a detailed
reclamation plan for the authorized tailings disposal area which includes
the following:
A. A post-operations interim stabilization plan which details methods to
prevent wind and water erosion and recharge of the tailings area.
B. A plan to determine the best methodology to dewater and/or consolidate
the tailings cells prior to placement of the final reclamation cover.
C. Plan and cross-sectional views of a final reclamation cover which
details the location and elevation of tailings. The plan shall include
details on cover thickness, physical characteristics of cover
materials, proposed testing of cover materials (specifications and
quality assurance), the estimated volumes of cover materials and their
availability and location.
D. Detailed plans for placement of rock or vegetative cover on the final
reclaimed tailings pile and mill site area.
E. A proposed implementation schedule for items A through D above which
defines the sequence of events and expected time ranges.
F. An analysis to show that the proposed type and thickness of soil cover
is adequate to provide attenuation of radon and is adequate to assure
long-term stability, as well as an analysis and proposal on methodology
and time required to restore ground water in conformance to regulatory
requirements.
G. The licensee shall include a detailed cost analysis of each phase of
the reclamation plan to include contractor costs, projected costs of
inflation based upon the schedule proposed in item E, a proposed
contingency cost, and the costs of long-term maintenance and
monitoring.
-···--------~-==-='~!~~
~~~~~~~~~~~~~~~ ~~ NRC FORM 374A u.s. 1 .EAR REGULATORY COMMISSION I PAGE 9 oF 9 PAGEs 1
;/ <7·94) f-L~ice~ns~e~Nu-m~ber
MATERIALS LICENSE
SUPPLEMENTARY SHEET
SUA-1358
Dockel or Reference Number
40-8681
March 14 1997
12.2 The licensee shall submit a detailed decommissioning plan to the NRC at
least twelve (12) months prior to planned final shutdown of mill operations.
FOR THE NUCLEAR REGULATORY COMMISSION
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Uranium Recovery Branch
Division of Waste Management
Office of Nuclear Material Safety
and Safeguards
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Enclosure 5
"Guidelines for Decontamination of Facilities and Equipment
Prior to Release for Unrestricted Use
·or Termination of Licenses for Byproduct, Source,
or Special Nuclear Material"
May 1987 revision
GliiDFL'IiES FOR DECONTftfol!NATHW OF FACILITIES ftNO EOII!PHENT
PRIOR TO RELEA~E FOR liNRESTRICTEO USE
OP TERMINATION OF LICEN5ES FOR BYPRODUCT, SOURCE,
OR SPECIAL NUCLEAR MATERIAL
U.S. Nuclear Regulatory Commission
Division of Fuel Cycle, Medical, Acadernic,
and Commercial Use Safety
Washington, DC 20555
May 1987 ·
I
ThP 'nstructions in this cu!de, in conjunction witb Table 1, specifv the
radinn•Jcl ides and r~diation exposure ratP. 1 imits which should be •tsed in
rlecontarr.'nation and survey of St!r'aces or prer~ises and eouipment prior to
abandonment nr rplease for unrestricted use. The limits in Ta~le 1 do nnt
apply to premisPs, equipment, or scrap ccntaining induced radioactivity for
which the radiological considerations pertinent to their use may be
different. The release of such facilities or Items from regulatory cc~trol is
crPsidered on a case-by-case.
1. The licensee sh~ll make a reasonable effort to eliminate residual
contamination.
2. Radioactivity on equipment or surfaces shall not be covered by paint,
plating, or other covering material unless tontamination levels, as
determined by a survey and documented, are below the limits specified in
Table 1 prior to the application of the covering. A reasonable effort
must be made to minimize the contamination prior to use of any covering.
3. The radioactivity on the interior surf~ccs of pipes, drain lines, or
ductwork shall be determined b.v makin9 meas~rement.s at all t.raps, and
other appropriate access point~. provided that contamination at these
locations is likely to be rP.present.ative of contam~Pation on the interior
n• the pipes, drain lines, or ductwork. Surface$ nf premises, equipment,
or scrap which are likely to be contaminated but are of such size,
construction, or location as to make the surf~ce inaccessible for purposes
of measurement shall be presumed to be contaminated in excess of the limits.
4. Upon request, the Commission may authorize a licensee to relinquish
possession or contr0l of premises, equipment, or scrap having surfaces
cont~minated with material~ in excess of the limits ~pecified. This may
include, but would not be limited to, special circumstances such ~s razinq
of buildings, transfer to premises to another organization cnntinuing work
with radioactive materials, or conversation of facilities to a long-term
storage or standby ~tatus. Such requests must:
a. Provide detailed, specific information describino the premises,
equipment or scrap, radioactive contaminants, and the nature, e~tent,
and degree of residual surface contamination.
b. Provide a detailed health and safety analysis which reflects that the
residual amounts of materiRls on surface areas, toqether with other
considerations such as prospective use of the premises, equirment,
or scrap, are unlikely to result in an unreasonable risk to the
heal~h and safety of the public.
I
5.
2
Prior to relPase of premises for unre~tricted use, t~e licensee shall
make a comprehensive radiatinr survey which establis~es that contamination is
within the limits specified in Table 1. A copy n' thP ~urvey report shall he fi1p~ ~·ith the niv1~1on Qf Fuel Cycle, Medical, Academic, and Co~Prcial Use
Safety. II. S. Nur'ear Regulatory Cnrrwnission, \olashinot.on, DC 20555, and also
the Administrator of the NRC Reaional Office having j11risdiction. The report
should be filed at least 30 days prior to the planred date of abandonment.
The survey report shall:
a. Ircntify the premises.
b. Show that reasonable effort has been made to e11m1nate residual
contamination.
c. Describe the scope of the survry and qeneral procedures followed.
d. State thP f1ndinos of the survey in un1ts specified in the
instruction,
Followiro review of the repo,·t. the ~qc will consider visiting the
fac i 1 it i es to confi m t.he survey.
•
•
....... ,,.... --·· ... ~ ....
U-nat. U-235, U-238. and
associated dccly products
Transuranics. R3-226. Ra-228.
Th-230, Th-228, Pa-231,
;;c-227. !-125, I-129
Th-nat, Th-232, Sr-90,
~a-223, R•-224, U-232, l-126.
1-131. I-133
Cel.!·<;J~·a emitters (nuclides
with decay ~aCes other than
alph.:s e;:1issi0n or spontaneous
fission) cxc~pt Sr-90 and
others nvt~d above.
TABLE 1
ACCEPTABLE SURFACE COMTAHIMATIOH LEVELS •
AVEAAG[b C f
5,000 d~ n/100 cm2 15,000 dpm n/100 cm2
100 dpm/100 cm2 300 dpon/1 00 ,,.2
1000 dpm/1 00 cm2 3000 dpm/100 m2
5000 dpm 8y/100 cmZ 15,000 d~ e1/lOO cm2
REiiJVABLEb e f
1,000 d~ a/100 0112
20 d~/1 00 Cla2
200 dpm/100 cm2
1000 d~ e1/100 cmZ
•;:hore surface cor.tamination by both alpha-and beta-9anma-emltting nuclides exists, the limits established for •lpha-and beta-galllll3-emittlng
nuclides should apply independently.
bAs used in this table. dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting ihe
counts per minute observed by an appropriate detector for background, effic.lency, and geometric factors associated with the instrumentation.
c:-teasurcncnts of average contaminant should not be averaged over more than l square meter. for objects of less surface area. the average
should be derived for each such object.
dlhe maximum contamination level applies to an area of not snore than 100 cm2.
eihe amount of removable radioactive material per 100 cmZ of surface area should be detennined by wlplng that area with dry filter or soft
.'\hsor ... ;~nt rJpcr. applying moderate pressure. and assessing the arount of radioactive material on the wipe with an appropriate instrument of
koOI·:n efficiency. llhen removable contamination on objects of less surface area is determined, the pertinent levels should be reduced
proportionally and the entire surface should be wiped.
fThe .wcrO!Je and m.J:-dmum radiation levels associated with surface contamination resulting from beta-ganrna ~1tters should not exceed o.z mrad/hr at 1 em and 1.0 mrad/hr at 1 em. respectively, measured through not more than 7 milligrams per square centimeter of
total absorber.
•