ML19340B917
| ML19340B917 | |
| Person / Time | |
|---|---|
| Issue date: | 10/27/1980 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Baca T NEW MEXICO, STATE OF |
| Shared Package | |
| ML19340B915 | List: |
| References | |
| NUDOCS 8011120565 | |
| Download: ML19340B917 (2) | |
Text
.
=~
- @o
/,
- [ g h
UNITE! STATES
[
NUCLEAR REGULATORY COMMISSION i
.C WASHING TON D. C. 20555 t
O
,%,o, 3,$f
....f Oct., M 60 Ref: SA/CG Mr. Thomas E. Baca, Director Environmental Improvement Division I
Department of Health and Environment P.O. Box 968 Santa Fe, New Mexico 87503
Dear Mr. Baca:
This is to confirm the discussion Mr. Kendig and Mr. Gordon held with Dr. T. Wolff, Mr. C. Clayton, and yourself on October 3,1960, concerning the results of our partial review and evaluation of the New Mexico Environmental Improvement Division's radiation control program.
Our review differed this year from past reviews in that we focused on two primary areas, the administrative aspects of the program and the licensing and inspection case work related to uranium mills. Our review was a partial one in that additional case work needs to be reviewed. We plan to complete the review during L
the week of hovember 4,1980.
j i
The first portion of our schedule was spent accompanying the State inspectors on i
a complete inspection of the United Nuclear Homestake Partners (UNHP) mill and tailing impoundment and an inspection of the 50hio tailing impoundment area.
Assisting in the evaluation was Dr. Owen Thompson of the Nuclear ~ Regulatory Commission's Office of Nuclear Reactor Regulation, Hydrologic and Geotechnical Engineering Branch along with Mr. Don Lopez from the New Mexico State Engineer's O f fice.
We conducted a review of the administrative aspects of the State's program. With respect to case work, we reviewed the State's evaluation of the in-plant radiological safety program of both the Gulf Mineral Resources Mt. Taylor ar.d Bokum Marque projects, and the environmental assessment of the Gulf facility.
In April of this year, URC staff issued recommendations to the State with respect
-l to the Bokum license. We reviewed that license in light of these recommendations.
During'both the UNHP and 50hio visits, we found that a clear understanding did not exist between the State Engineer and the EID representative as to responsibilities for conduct of the tailing dam inspection. The State engineer stated that his responsibility and areas of. interest related to aspects of dam construction and stability. The EID inspector presumed the State engineer was also responsible for evaluation of the performance of the licensee in carrying out requirements of either daily, weekly, or monthly inspection procedures. We recommend that the responsibilities and coordination between the two offices be clearly defined and documented to ensure that in future inspections no item is excluded.
8 01113g $%
-~
p I
1 Mr. Thomas E. Baca ;
Regarding the Gulf Mt. Taylor license application analysis, the document did i
not' address surety arrangements to assure that sufficient funds are available to completely carry out the full reclamation plan.
Furthermore, many NRC recommendations for license conditions were omitted in this document. Other recommendations for license conditions which were contained in the Pre-Hearing Ground Water Discharge Plan analysis were also not incorporated. We recommend the staff go through these recommendations and rewrite them for clarification.
Similarly, we noted the same deficiencies when comparing the Bokum license with 3
the NRC assessment. We reccamend the Bokum license be amended to include those NRC recommendations that were not incorporated into the license. We have now i
received your letters of October 7 and 9 responding to these ccmments and we will provide you additional comments, if appropriate, in the near future.
Our comments relating to the technical aspects of the program and day-to-day i
routine activities have been discussed with Dr. Wolff in detail.
I am enclosing a copy of a letter to Dr. Wolff confirming our discussion with himself and the staff. Also enclosed is an extra copy of these letters for distribution in the i
State Public Document Room or equivalent.
4 I would appreciate your response to the above comments. We will offer our i
recommendations for adequacy and compatibility of your program for protection j
of the~ public's health and safety upon completion of our review in November.
I appreciate the courtesy and cooperation extended to Messrs. Gordon and Kendig during their meeting with your staff.
Sincerely,
$UGAf G. WaynFKerr, Director Office of State Programs
Enclosures:
As stated I
cc: Ted Wolff, Chief Cubia Clayton, Deputy Director NRC Public Document Room State Public Document Room
~
3 i
l i
(
- r j
ms -
l 'h,
< A
.n-
.c r,.e
,r,
,.-w--
.-*v.
x<-,.
-