ML19254B448

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Comments on Final Executive Review Summary Re Expansion U Mill.Nrc Can Neither Recommend Issuance Nor Deny Amended License Re Proposed Expansion
ML19254B448
Person / Time
Issue date: 08/22/1979
From: Scarano R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Hazle A
COLORADO, STATE OF
References
REF-PROJ-M-6 NUDOCS 7909270828
Download: ML19254B448 (4)


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UNITED STATES 4

y h s.,(f' g NUCLEAR REGULATORY COMMISSION WASHINCTON, D. C. 20555 c.4 #, - l k' b 8

WMUR:J3L AUG 2 21979 Project M-6 Colorado Department of Health Radiation & Hazardous Wastes Control Division ATTN: Mr. A. J. Hazle, Director 4210 East lith Avenue Denver, Colorado 80220 Gentlemen:

In response to your August 1,1979 letter to the Nuclear Regulatory Commission's (NRC) Uranium Reco$ery Licensing Branch, enclosed are the NRC's comments on the " Final Executive Licensing Review Sumary" for the Cotter uranium mill. These coments were discussed in my August 15th telephone conversation with Mr. R. Gamewell of your staff.

Please note that our review focused specifically on those areas, tailings management and off-site radiological assessment, aF essed in our

" Environmental Assessment of the Tailings Management Program and Radiological Effluents for the Proposed Expansion of the Cotter Corporation Craniua Mill at Canon City, Colorado". Our review did not include an evaluation of other areas, such as dam stability and occupational radiation safety and monitoring. Therefore, in light of the above we are not in a position to either recommend issuance or denial of an amended license for the proposed mill expansion.

Regarding the proposed license conditions, we cannot coment on their adequacy since we have not reviewed the numerous documerts listed in Condition No. 9.

We assume that these specific 'licen:;e conditions are only meant to supplement the basic comitments made by Cotter in the documents listed in Condition No. 9.

If you have any questions on the above. or need additional assistance, please do not hesitate to call me.

Sincerely, M

&~

/Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management

Enclosure:

As stated 4909 27o h8 1044 283

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URANIUM RECOVERY LICENSING BRANCH COMMENTS ON COLORADO DEPARTMENT OF HEALTH'S " FINAL EXECUTIVE LICENSING REVIEW

SUMMARY

" RELATED TO EXPANSION OF THE COTTER CANON CITY URANIUM MILL Page Paragraph Connent 1.

5 1st Item no. 3 - Delete reference to occupational radiological monitoring. The NRC staff did not evaluate any portion of the occupational redi-ation safety program.

2.

5 2nd First line - change " Deposition" to " Dosimetry" 3.

5 2nd Last two lines should be changed to read the NRC arranged for additional field sampling to determine the impact of using the contaminated groundwater for irrigation."

4.

8 4th Delete last sentence.

5.

8 6th The offsite water monitoring program should include analyses for Ra-226, Th-230, Po-210, and P b-210.

6.

12 2nd Add the following to the end of the last sentence

"..., including pumping of contaminated aquifers with the withdrawn liquid being transferred to the new tailings impoundment."

7.

16 7th Revise second line to read as follows:

required to propose a tailings neutralization program and a dewatering system for use prior to initiation of reclamation procedures."

8.

17-8th

. Third line, change " design" to either " system" or " concept". The NRC evaluated the general program and was not requested by the state to evaluate the dam design for stability.

9.

17 9th First line, change " design" to either " system" or " concept"

10. 18 1st First line, change " design" to either " system" or " concept" 1044 284

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4 Page Paragraph Coment 11.

18 4th First sentence - Insert "by trench burial" after incremental reclamation.

12.

18 4th Last sentence - change "were not required" to "were not considered viable options."

13.

19 lst NRC staff did not inspect the dam or the liner.

14.

19 6th Delete last word of paragraph.

15.

25 last The NRC staff does not agree with this paragraph.

,,e 16.

31 7th Suggest comparing predicted doses to doses from natural background radiation.

17.

34 last The answer to 4.6.2.2 #2 should be NO.

18.

35 1st Delete last sentence. NRC is not doing this.

19.

38 2nd The NRC did not loak at the radiological risks associated with these accidents.

20.

45 2nd First lino - Add" state"between the words reviewing and agencies.

21.

46 last The NRC has not recomended license approval.

See specific coments in our cover letter to this enclosure.

1044 285

I COMMENTS ON PROPOSED LICENSE Condition No.

Coninent 1..

4 Suggest adding wording that makes it clear that the state will not tenninate the license until specific requirements are met.

2.

17(G)

The licensee should be required to report any release of tailings, not only releases into unrestricted areas.

3.

22(F)

There should also be similar controls over smoking.

4.

25(A)

The yellowcake stack sampling should be both

" isokinetic" and representative.

5.

31 (A)

Periodic should not be used to define the fre-cency of any required actions. A minimum acceptable freq ency should be specified.

6.

33 There shoulo be minimum technical qualifications,

specified in the license, that an individual must meet to be in charge of radiation safety. Specific individuals should not be named.

I 1044 286

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