ML20028C056
| ML20028C056 | |
| Person / Time | |
|---|---|
| Issue date: | 12/23/1982 |
| From: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Traylor F COLORADO, STATE OF |
| References | |
| NUDOCS 8301050470 | |
| Download: ML20028C056 (4) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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$j REGIGN IV 611 RYAN PLAZA DRIVE. SUITE 1000 ARL:NGTON. TEXAS 76011 December 23, 1982 Frank Traylor, M.D.
Executive Director Department of Health 4210 East lith Avenue Denver, Colorado 80220
Dear Dr. Traylor:
This is to confirm the discussions Mr. R. S. Heyer and other NRC staff members held with Dr. Robert Arnott, Mr. Albert Hazle, and other members of your staff on August 27, 1982. The review of the Colorado uranium mill regulatory pro-gram was initially planned for August 23-27, 1982, to cover the principal administrative and technical aspects of that program. However, based on the technical findings developed during thjs review, we believe an additional visit will be necessary to examine the State's procedures used to evaluate the design, construction, and inspection of the embankment retention systems for uranium mill tailings.
It is our understanding that the Division of Water Resources under the Department of Natural Resources (DNR) provides geotechnical
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services to the Department of Health, Division of Radiation Control (.as detailed under a Memorandum of Understanding, dated January 29,1982).
It is, therefore, our plan to review the procedures that'DNR uses for evaluation of tailings dams at conventional uranium milling operations in accordance with reconmended Regulatory Guides 3.11 and 3.11.1. Mr. Heyer will be in touch with your staff to arrange for the completion of our. review.
In the interim, I would like to report our findings thus far.
The partial review of August 23-27, 1982, disclosed that most program indicators were within NRC guidelines. However, several technical comments and recommenda-tions were developed and are enclosed with this letter.
I would appreciate receiving your responses to these comments or you may wish to have Mr. Albert Hazie respond directly to these connents.
I am also enclosing a copy of this letter for placement in the State Public Document Room or to otherwise be made for public review.
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w Frank Traylor, M.D. December 23, 1982 I appreciate the courtesy and cooperation extended to R. S. Heyer and'other NRC representatives during the review meeting.
Sincerely.
.;bedfb John T. Collins Regional Administrator
Enclosure:
as stated cc w/ enclosure Dr. Robert Arnott Mr. Albert Hazie G. W. Kerr, SP NRC Public Document Room State Public Document Room 9
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i TECHNICAL COMMENTS AND RECOMMENDATIONS ON THE COLORADO URANIUM MILL PROGRAM During this part of the review, several licenses, safety evaluation reports (SER), final environmental statements (FES), and inspection reports were evaluated, and the following comments and recomendations developed.
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A.
Enforcement Procedures (Category I Indicator)
Comment and Recommendation We recommend that the goal for issuance of enforcement letters sent to the uranium mills be within 30 days following completion of the inspection. These letters should employ appropriate regulatory language clearly specifying all items of noncompliance and health and safety matters identified during the inspection and reference the appropriate regulations and license conditions being violated; i.e., Cotter Corporation, License Number: 369-01S and Union Carbide Corporation, License Number: C0-SUA-673.
B.
Licensing Procedures (Category II Indicator)
Two complete conventional mill license files were reviewed:
Homestake Pitch Project, License Number: 150-01S and Pioneer Slick Rock, License Number: 418, including the respective FES's and SER's.
No major problems were, identified in either case. However, the following coments were developed.
Comments and Recommendations 1.
It is recomended that when preparing the license, that more restrictive regulatory terminology be implemented.
Such language as " assure it," "if possible," and "as appropriate" are nonspecific and may pose potential enforcement problems.
2.
It is recommended that the SER detail the complete responsibility and authority of the plant radiation safety officer.
In addition, complete radiation safety training criteria should be completely developed and outlined for all workers; e.g.,, female - prenatal radiation, exposure.
3.
It is recommended that whenever addressing special work permit procedures (SWP) in the SER, that identification of areas requiring the SWP are specifical.ly addressed. There should also be appropriate procedures developed for obtaining the SWP from higher level management who can prescribe any special activities that are necessary.
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C.
Inspection Reports (Category II Indicator)
Two complete inspection reports were reviewed: Cotter Corporation, License Number: 369-01S and Union Carbide Corporation, License Number: C0-SUA-673, and the following comments and recommendations developed.
1.
Cotter Corporation, Canon City Comments and Recommendations It is recommended that the inspection report specifically detail the results of all records reviewed during the inspection. Regarding the inspectors review of data of measurements made by the license, e.g., airborne radioactivity
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measurements, 48 MPC hour control measurements, bioassay and personnel dosimetry measurements, the report should state whether the results were in compliance with State regulations, or license conditions. Also, a statement should be provided regarding the results of independent measurements made by the inspector, e.g., area surveys and wipe tests.
2.
Union Carbide Corporation, Uravan Comment This inspection report did not identify the previous items'of noncompliance, the type of inspection conducted (routine, special, announced, or unannounced), or the date of the previous inspection.
It was noted by the NRC reviewer that an incident was witnessed by the inspector during a mill tour. The report detailed this incident, however, it did not explain if any corrective action was taken by the licensee in response to activa ~ tion of the warning lights for the yellow cake dryer in j
the control room.
l In addition, it was also noted that the inspector did not record whether he reviewed the licensee's respiratory program.
I Recommendation It is recommended that the inspector fully document the scope j
of the inspection that was conducted.
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