ML20134K747
| ML20134K747 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/1995 |
| From: | Doda R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hibbs M TEXAS, STATE OF |
| Shared Package | |
| ML20134K703 | List: |
| References | |
| FOIA-96-527 NUDOCS 9702140215 | |
| Download: ML20134K747 (56) | |
Text
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~, <f p* "Tky*% UNITED STATES 7
r ; NUCLEAR REGULATORY COMMISSION t
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- e R EClON IV -
S .f 611 RYAN PLAZA DRIVE, SulTE 400
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SUBJECT:
ALLEGATION RIV-95-A-0073
Dear Mr. Hibbs:
The enclosed allegation was received by NRC. The allegation relates to a !
. number of concerns involving Hycro Resources, Inc., a uranium recovery ,
facility in Texas.
We request that you conduct abatever Mscections or investigations that are :
necessary to reascrably prove or dis: rove the allegation. Additionally, we '
request that you ir. form NRC, Region IV of any findings from your investigation, s
Should you have any further :uestions ::ncerr.ing our requests or our role in this .atter, please contact .ussell 'ni:e, our allegations Coordinator, at i (800) 352-9677. ,
I'ncerely, n g
.rhj 0 -
b 2.00ert 3. 30C3 State Agreements Officer Encl 0sure* As stated i
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9702140215 970212 PDR FOIA t,. JORDAN 96_527_ PDR
Rvdro Resources. Inc.
a List of Concerns A number of concerns were raised regarding operations, radiological, environmental and other issues. The concerns are sumarized as follows:
I.
Uranium Resources, Inc. (URI) may have followed a practice of lying to the State of Texas (Texas Natural Resources Conservation Comission) and been ;
involved in covering up ' accidents." i
- 2. Environmental sampling and recordkeeping was not in accordance with !
license conditions.
- 3. Various spills and leaks from pipelines and evaporation ponds have been
~i reported by URI. Delay of repairs to evaporation pond leaks was implied in two instances. ;
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- 4. URI was " caught
- by the State in " improperly disposing" of waste water l through land application without state authorization in June 1991. j l
- 5. A Texas Dept. of Health interoffice memo recommends not granting a license '
amendment, alleging that URI disposed of prohibited byproduct material in
] in+erim storage ponds at Rosita, in violation of a license condition.
- 6. [ Transcript op.85-86] URI has followed a practice of misrepresentation to the State of Texas aoout their operation.
- 7. [ Transcript pp.27-29] (a) Hydro Resources, Inc.'s (HRI's) process will destroy the crinking water, in violation of the Safe Orinking Water Act.
Companies have not been able to restore drinking water quality. The water still contains various secified metals. HRI and its parent company, URI, have a bad past record in Texas - spills, mining solution excursions, accidents, lack of proper monitoring, misrepresentation to the State. i I
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URI - EING8VILLF DCME A.LLEGED VIOLATIONS AND INCIDENTS NEEDING IWYESTICATION AND INF01CEKZWT
& SAFETY CODE A. ALLEGED VIOLATION CF CHAPTER 401 TEXAS HEALTH DOCUMF$TED IN THE TILES OF TNRCC The alleged violations listed below are identified in the files ofM TNRCC for URI's licenses . In many cases of lav violated, as spe..ified by TNRCC documents.
there are apparently multiple violations and violation of related laws, rules and license conditions.
Since =any of these alleged violations involved situations whero the violation likely continued for a nu=ber of days er resulted in or from additional violations, va seeX your investigatien and appropriate penalties fer all : elated violatiens and for each day of violation.
1993
- 1. March 23, 1993 - Oata of !nspectien-January 28, Although required to Violatica of _ License C:ndition 39:
analyze process fluids f:: radiun, *JRI decided to discontinue these tests, without prier approval from this Agency. The violation continued fer approximately 1 year.
2.
March 23, 1993 - Date of Inspecticn-January 26, 1993 ~he Violation of TFCR 36.13 and License Condition required 31: physical instrumentation utilized to conduct radiation surveys and analyze vipe sa=ples for contaminati:n were not calibrated at six-nonth intervals, as required.
- 3. Xay 6, 1992 - Cate of Inspecti:n-January 24, 1992 Docunentation of daily Violation of License C:nditi:n 23:
inspections f or yellowcake contamination was not available f er review by the Agency.
- 4. April 16, 1992 - Data of Inspection-July a;.: URI 25, 1991to maintain failed Violation of TRCR 36.2 et.
records to document compliance with the requirements 'Asdiation specified in Part 36 of the Texas Reculations for Control of (Well Logging Regulations, as referenced in License Condition 10).
May 24, 1991 - Date of :nspection-March 21, 1991 Violations of License tondition 39.As sampling violation, 5.
including (a) Only one sarpio was taken at each surf ace water source; (b) Sediment samples were not taken at all surface water locations as required.
- 5. August 13, 1990 - Date of Inspectien-June 13, URI 1990 failed to Violation of License Ccnditien 45.A.: severely
-aterials stored in repackage / dispose of vaste indicates that the required corroded drums. (This also
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release report fo: 1992, although
- 2. The first semi-annual complete, had not been sant to TDH vithin 60 days from July 1, 1992 (Condition. 38)
URI reported a spill en June 9, 1988 caused by a leak 3.
-- developing in the manifold. Approximately 8,000 gallons were spilled, contaminating soils.
- 4. Airborne uranium exceeded the 200 ng/m3 limit in the dryer for the Veek of April 16 through the 22.
- 5. Cn April 21, 1989 a leak vas discovered in the south pond at the Xingsv111e Doce on Apr;,1 20.
- 5. A spill was reported by URI on March 29, 1989 of approximately 3,000 gallons ,of Injecticn Sciution.
7 A spill was reported by GI on March 29, 1989 of approx 1:stely 12,000 gallens of pregnant Solution from Extracticn Lateral.
and en August 29, 1989, URI reported
- 3. On March 7, 1959 exceedances in its release of Raden 222.
- 9. On December 27, 1989 six laaks '.ere reported by URI. The creaks resulted in the spilling :f one 15,000 gallons of injection fluid er extraction fluid into surrounding soils.
- 10. On September 13, 1988, **RI reported leaks in the south pond first detected by it on March :5, *.988 and not repaired until July 15, 1988. URI also report ed leaks in the north pond. ,
UBI identified the leaks en June 7, 1988 and but did not l repair them until July 19, 1988.
- 11. In June :.9 91, the state caught URI improperly disposing of veeta by land application without state authorization. The activity had gone on for a significant period of time before the state became aware of the action through an anonymous complaint. The disposal of vaste and the f ailure to remediate violates Texas lav and regulations governing uranium nines.
- 12. URI ceased mining operations on er before October 1990 and has failed to begin restoration as required by its license and ;
state law. i
- 13. On July 5, 1994 and septenber 28, 1994, URI reported leaks in its south pond. '
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O ATTACHMENT B
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Texas Department of Health Robert Bernstein, M.D., F. A.C.P. 1100 West 49th Street Robert A. MacLean, M.D.
Commissioner Austm. Texas 78756-3189 Deputy Commissioner (512) 458 7111 Radiation Control (512) 835 7000 August 28,1990 URI, Inc. Ref: Compliance No. L900936 Attn: William J. Chapman License No. LO3653 12377 Merit Drive Inspection of July 26,1990 Suite 750, LB 14 By Thomas Cardwell s Dallas, Texas 75251 At URI, Rosita
.) HCO 1 Box 50 San Diego, Texas Site 001
Dear Mr. Chapman:
After reviewing the repon of the inspection conducted by Thomas Cardwell on July 26,1990, we are pleased to inform you that your radiation protection program, with regard to the records reviewed and procedures observed, appears to be in compliance with the applicable Texas Regulations for Control of Radiation and/or Conditions pertaining to the above referenced License.
Thank you for the cooperation and assistance provided during the inspection.
Since, rely,
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Michael L. Dunn Technical Review and Enforcement Frogram Radioactive Material Inspection and Enforcement Branch Division of Compliance and Inspection Bureau of Radiauon Control MLD/df ;
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TEXAS DEPARTMENT OF HEALTH I s-ta Bureau of Radiation Control Division of Compliance and Inspection 1100 West 49th Street Austin, Texas ~<8756-3189 COMPLIANCE NO: L920244 Page 1 of 1
"* NOTICE OF VIOLATION ***
LICENSEE / REGISTRANT DATE OF NOTICE URI, Inc. May 6,1992 Attn: Mark Pelizza 12377 Merit Drive
-, January 22,1992 Robin Houston LICENSEE /REGISTR ANT REPRESENTATIVE Lille Canales ;
INSPECTION LOCATION STAFF REVIEWER 1
Rosita Project Robert L. Green, Jr. i Duvual County l Please refer to the above COh!PLIANCE NDIBER when responding to this notice.
The following violations were found during the inspection of operations under License No.
LO3653:
- 1. Violation of License Condition :0:
The Licensee failed to sarnple the septic *anks on the pre nises, as recuired.
This is a Seventy III Violation.
- 2. Violation of License Concition 54:
The Licensee failed to document daily inspections for yellowcake contamination, as required.
This is a Severity IV Violation.
DO NOT RETURN THIS ORIGIN AL " NOTICE OF VIOLATION" WITH YOUR R ESPONSE.
TRCR 22.11(a)(4) REQUIRES Til AT ANY SUCH NOTICE BE POSTED. OR IN THE ALTERNATIVE,31ADE AVAILABL E FOR E31PLOYEE REVIEW, AS PER311TTED REVIEWER RLG:T.r MIU M PM
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13.8(b)
When the Agency contemplates modification, revocation, or suspension, the C2 (b) licensee / registrant shall be afforded the opportunity for hearing. Notice of the contemplated action, along with a complaint, shall be given to the licensee / registrant 1
by personal service or certified mail, return receipt requested. If no request for L hearing is received by the Director, within 30 days of personal service or the date of mailing, the Agency may proceed to take the action set out in the notice.
(c) The licensee / registrant shall have the burden of showing cause why the license or certificate of registration shot id not be suspended, revoked, or amended, 13.9 Assessment of Administrative Penaltic (a) When the Agency determines that monetary penalties are appropriate, proposals for assessment of and hearings on administrative penalties shall be made in accordance with Section 15C of the Act and applicable sections of the Formal Hearing Procedures.
- 6) Assessment of administrative penalties shall be based on the following criteria:
(1) the seriousness of the violation (s);
(:) previous compliance historv:
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l (3) the amount necessary to deter future violations. i i
(1.) efforts to correct the violation; 2.nd (5) any other mitigating or enhanc:ng factors. ,
9 sc) Severity Levels l (1) The seriousness of violations snail be categorized by one of the following seventy levels: l (i) Severity Level 1 - Violations that are most significant and have a direct l negatise impact on occupational and/or public health and safety or on {
the environment.
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tii) Severity Level 11 - V:alations that are sery significant and have an !
impact on occupation:d and/or public health and safety or on the environment.
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- 13.9(c)(1)(iii)
(iii) Severity level III - Violations that are significant and which, if not corrected, could threaten occupational and/or public health and safety or the environment.
(iv) Severity 12 vel IV - Violations that are of more than minor significance, but if left uncorrected, could lead to more serious circumstances.
(v) Severity Level V - Violations that are of minor safety or environmental significance. l (2) Examples of severity levels are set out in Appendix 13-A.
(d) Application The Agency may impose differing levels of penalties for different severity level violations and different classes of users.
l (1) Administrative penalties may be imposed for Severity Level I and II violations.
Administrative penalties will be considered for Seventy Level III, IV, and V violations when they are combined with those of higher severity level (s) or for repeated violations which could have been prevented by corrective action and for whicn the licensee / registrant did not take effective corrective action.
f;) Tables IA and IB show the base administrative penalties.
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a ATTACHMENT C i
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TEXAS DEPARTMENT OF HEALTH Bureau of Radiation Control Division of Compliance and Inspection 1100 West 49th Street Austin, Texas 78756-3189 COMPLIANCE NO: L930155 Page 1 of 1
"* NOTICE OF VIOLATION *" _.~.m.-.,
LICENSEE / REGISTRANT DATE OF NOTICE URI, Inc. March 23,1993 Attn: Lille Canales 12750 Merit Drive . !
Suite 1210, LB 12 Dallas, Texas 75251 DATE OF INSPECTION INSPECTOR (S)
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January 28,1993 LICENSEE /REGISTR ANT REPRESENTATIVE Robin Cooksey -
.h Lille Canales T INSPECTION LOCATION
- STAFF REVIEWER Kincsville Dome Robert L. Green, Jr.
3::- Kleberg County ,
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Please refer to the above COSIPLIANCE NU51BER uhen responding to this notice.
' The following violations were found during the inspection of operations under License No.
1A3653:
- 1. Violation of License Condidon 39:
Although recuired to analv e process Suids for Ra-226 and Rn-222 concentrations, the Licensee ma'de a willful' management decision in May of 1992 to discontinue these tests, without pr:or approval from inis Agency.
This is a Severity III Violation.
- 2. Violation of TRCR 36.13 and License Condition 31:
Instrumentation utilized to conduct recuired physical radiation surveys and analyze wipe samples for contamination were not dalibrated at six-month intervils, as required (re:
y -- -- Ludlum 14-C. number 81915; and Ludlum 2200, number 50060).
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This is a Severity IV Violation.
30 NOT RETURN THIS ORIGIN AL " NOTICE OF VIOL ATION" WITH YOUR 3ESPONSE.
TRCR 22.11(a)(4) REQUIRES THAT ANY SUCH NOTICE BE POSTED. OR IN THE ALTERNATIVE. 51ADE AVAILABLE FOR EMPLOYEE REVIEW, AS PER311TTED BY TRCR 22.11(b).
REVIEWER A --
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URI, INC.
(A Subsidiary of Uranium Resources, Inc.) i 12377 Ment Orve l 5656 Soum S'apies Sune 750. LB 14 P O Box 5391 Suite 250. LB 8 Corpus Chnsti. TX 76411 Dallas. Texas 75251 Route 1. Box 425 Teiepnone (214) 934 7777 Kingsone. Teaas 78363 i
- eiephone (512) 993-7731 Teiecopy (214) 934 7779 Teleohone (512) 595 5731 '
Telecopy ($12) 933 5744 wx 330 667 4701 Telecupy. (m12) 595-c403 '
Apnl 14,1993 c,
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Mr. Robert '.. Green, Jr.
0 ;; 1 Staff Revie.ver TEXAS DEPARTMENT OF HEALTH Q5,-n
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Bureau of Radiation control p s
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Division of Compliance and inspection '
1100 West 49th Sir,et @
RE: Compliance Log No. L930155 License No. LO3653
Dear Mr. Green:
The following letter is in response to your Notice of Violation dated March 23,1993, I have formatted this response Dy first restating the alleged violation and then responding accordingly.
- 1. Violation of License Condition 39:
Although required to analyze process fluids for Ra 226 and Rn.222 concentrations, the Licensee made a willful management decision in May of 1992 to discontinue these tests, wrthout prior approval from this Agency.
RfsDonse:
As will be discussed below, URI does not agree that there has been a Violatior .af Condition
- 39. However, at the request of the Bureau's staff, and to maintain a cooperative ur it with the Bureau, we will perform sampling of fluids being injected into the disposal well consistent with Condition 39 requirements for process fluid.
The reason that we take exception to this violation is that the Kingsville Dome plant was in the standby mode during the penod covered by the inspection (see attached memo), and process fluid, as we understand it, was not flowing through the plant, more specifically, through a surae tank or Dreanant lixiviant surae tank. as specified for sampling in Condition 39. A sample was not obtained dunng the standby mode because there was simply no process fluid flowing through a surge tank. not because of willful neglect, as specifieo in the alleged violation.
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Letter to R. L. Green -
C5 3 l April ;S.1993 ;
Page 2 4
- of the subject license, the disposal well is clearly to serve as the disposal source for byproduct ,
i material as defined in Section 401,003(7)(3) of the Texas Health and Safety Code, and not process l fluid, as specified in Condition 39. It was our understanding that the sampling requirement for the
- disposal wellis stated under Coritien 28(d) of the license.
As I mentioned at the onset of this discussion, URI will sample the disposal wellinjection fluid .
j at Kingsville Dome and Rosita on a quarterly Lasis, pursuant to license Condition 39, as process fluids, and compliance can be considered complete at this time. However, for all the reasons mentioned above, we request that the BRC re-evaluate this alleged violation, and make a final determination as to whether a violation has occurred at all. i
- 2. Violation of TRCR 36.13 and License Condition 31:
Instrumentation utilized to conduct required physical radiation surveys and analyze wipe g samples for contamination were not calibrated at six-month intervals, as required (re: Ludlum
", p 14-C, number 81915: and Ludlum 2200, number 50060).
Resoonse:
The calibration frecuency for all instruments was changed with Amendment #15 of the subject license. Because this was not the intent of Amendment a15, the change in calibration frequency did not draw our attention, and calibrations, according to the new schedule, inadvertently
- were not performed.
l Pursuant to the amended condition 31 A. we are now calibrating all instruments two per year. I As shown on the attached memo, we also intend to file a request to return to a once-per-year schedule, i
We are in full compliance at this time.
i Please feel free to contact the undersigned with questions pertaining to this response.
)
{ Yours very truly a
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hMark}s!) I AN S. Pelizz Environmental Manager j MSP/ dig Encl.
cc Craig Bartels/URI - Kingsville Dome Plant Lille Canales/URI - Rosita Plant l Ruth McBurneyiTDH - Austin Texas l l
Bill McKnight/URI - Corpus Christi, Texas I e
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i URI, INC.
(A Subsidiary of Uranium Resources. Inc.)
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' 12377 Merd Dnve !
5656 south Staples sane 750, La 14 P.o. Box 5391 '
i sude 250. LB 8 Danas. Texas 75251 Route 1, Box 425
< Corpus Chnsti. TX 78411 Teiephone (214) 934 7777 Kingsvdle. Texas 78363 ,
l Teephone (512) 993 7731 Teecopy (214) 934 7779 Teephone (512) 595 5731 !
- 'e'ecopy (512) 993-5744 Twx 910 867-4701 Tetecopy- (512) 595-0403,
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April 19,1993 E'd -2 cm - q% ,
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m m Mr. Robert L. Green, Jr. N l' 4
Staff Reviewer j P TEXAS DEPARTMENT OF HEALTH Bureau of Radiation control j Division of Compliance and Inspection i 1100 West 49th Street j Austin, Texas 78756-3189
! RE: Compliance Log No. L930155 4
License No. LO3653 i
Dear Mr. Green:
i Your office was mailed a response to the subject compliance item dated April 14,1993. This response contained a word-processing omission.
l Please substitute the attached, corrected response in place of the version mailed on April 14.
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{ Youth ver r,uly, j I /
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i Mark S. Peliir)a ,
Environmenta(Manger
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cc: Craig Bartels/URI - Kingsville Dome Plant 4
Lille Canales/URI- Rosita Plant i j Ruth McBurney/TDH - Austin, Texas
- Bill McKnight/URI - Corpus Christi, Texas i
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URI, INC.
(A Subsidiary of Uranium Resources, Inc.)
12377 Ment Onve 5656 South L:aoles sorte 750. LB 14 P O Box 5391 Suite 250. LB B Danas Texas 75251 Route 1, Box 425 Corpus Chnsti, TX 78411 Telephc,w (214) 934-7777 Kingsene. Texas 78363
- eiephone (512) 993 7731 Teiecopy (211) 934 7779 Telephone (512) 595 5731 Teiecopy (512) 993 5744 Twx 91c.667 4701 Te>ecopy (512) 595-0403 April 19,1993 Mr. Robert L. Green, Jr.
Staff Reviewer TEXAS DEPARTMENT OF HEALTH
, Bureau of Radiation control
' jf Division of Compliance and Inspection 1100 West 49th Street Austin, Texas 78756-3189 RE: Cornpliance i.c:: No.L930155 License No. LO3653
Dear Mr Green:
The following letter is in response to your Notice of Violation dated March 23,1993. I have formatted this response by first restating the alleged violation and then responding accordingly, i- 1. Violation of License Condition 39:
i l Although required to analyze process fluids for Ra-226 and Rn 222 concentrations, the
, Licensee made a willful management decision in May of 1992 to discontinue these tests, without prior approval from this Agency.
Response
. As will be discussed below, URI does not agree that there has been a Violation of Condition
- 39. However, at the request of the Bureau's staff, and to maintain a cooperative spirit with the Bureau, we will perform sampling of fluids being injected into the disposal well consistent with
- Condition 39 requirements for process fluid.
i The reason that we take exception to this violation is that the Kingsville Dome plant was in I the standby mode during the period covered by the inspection (see attached memo), and process
- fluid, as we understand it, was not flowing through the plant, more specifically, through a surae tank or oreanant lixiviant surae tank, as specified for sampling in Condition 39. A samp!e was not obtained during the standby mode because there was simply no process fluid flowing through a surae tank, not because of willful neglect, as specified in the alleged violation.
The Bureau's inspection staff concluded that in the event of plant shutdown, the default sampling point for " process fluids" should be the disposal well. If this is so, we will sample the !
disposal well fluid, which is essentially wellfield bleed during standby, as if it were process fluid. ;
However, we disagree with this interpretation of
- process fluid
- because at the disposal well, we are !
of the opinion that the fluid is byproduct material. As specified under license condition Sic) and 44, l
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Letter to R. L. Green April 19,1993 Page 2 of the subject license, the disposal well is clearly to serve as the disposal source for byproduct material as defined in Section 401,003(7)(3) of the Texas Health and Safety Code, and not process t fluid, as specified in Condition 39. It was our understanding that the sampling requirement for the disposal wellis stated under Condition 28(d) of the license.
As I mentioned at the onset of this discussion, URI will sample the disposal well injection fluid ,
at Kingsville Dome end Rosita on a quarterly basi., pursuant to license Condition 39, as process ,
fluids, and compliance can be considered complete at this time. However, for all the reasons mentioned above, we reouest that the BRC re-evaluate this alleged violation, and make a final determination as to whether a violation has occurred at all, t
- 2. Violation of TRCR 36.13 and Licer ;e Condition 31: !
instrumentation utilized to conduct required physical radiation surveys ar d analyze wipe I g samples for co~ ' amination were not calibrcted at six-month intervals, as required (re: Ludlum !
.3e+ 14-C, number t 315; and Ludlum 2200, number 50060).
Response
The calibration frequency for all instruments was changed with Amendment #15 of the subject license. Because this was not the intent of Amendment #15, the change in calibration frequency did not draw our attention. and calibrations, according to the new schedule, inadvertently were not performed.
Pursuant to the amended condition 31-A, we are now calibrating all instruments two per year.
As snown on the attacned memo, we also intend to file a request to return to a once-per year schedule.
We are in full compliance at this time.
Please feel free to contact the undersigned with questions pertaining to this response.
Yours very truly
, I jQ<Di g IAark S. Pelizz Environmental Man ger MSP/ dig Encl.
cc: Craig Bartels/URI Kingsville Dome Plant Lille Canales/URI Rosita Plant Ruth McBurney<TDH - Austin. Texas Bill McKnight/URI Corpus Christi. Texas I
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Texas Department of Health Decid R. smith. M.D. !!OO West 49th Stred Robert A. MacLean. M.D.
Commissioner Austin. "rcus 78756-3189 Deputy Commissioner (510) 45B 7111 Radiation Control (512) E34-6688 i May 3,1993 g URI, Inc. Ref: Compliance No. L930155 Attn: Lille Canales License No. LD3653 12750 Merit Drive Inspection of Jan. 28,1993 Suite 1210, LB 12 By Robin Cooksey Dallas, Texas 75251 At Kingsville Dome Klecerg County
Dear Ms. Canales:
We received Mr. Ma-k Pelir.za's letter dated April 19. 1993, informine us of the steps vou have taken to correct the violations cited in our ietter and NOTICE OF VI~OLATION or March 23, 1993. The corrective aedons noted appear to bring de items into compliance with the Texas Reculations for Co-: oi of Radiation incior Conci5ons of your License.
Re: Response to Vicinion 71 - According to 6e inspector. Ms. Cooksev, an agreement was made with vour R.S.O. that if disposal fluics were sampled at the well head monthlv and analyzed foi Ra-226. Rn-222 and 16:21 U 2.~ 5. the recuirements of License Condicons 19 and 2S(d) would be fulfilled. T.. Acenev has de:erminec that the violadon as cited is valid, but not willful. Therefore, de seve: .ylevel of violation F1 is hereby reduced to a Severity Level IV.
The results of your corrective aedons will be veritied during our next inspection. Thank you
~
for the coopera' tion and assistance.
Sincerely. l Robert L. Green Technical Review and Enforcement Procram ~
Radioactive Material Inspection and i
Enforcement Branch '
Division of Compliance and Inspection Bureau of Radiauon Control ,
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TEXAS DEPARTMENT OF HEALTH _O
- Bureau of Radiation Control a-Division of Compliance and Inspection ,
1100 West 49th Street Austin, Texas 78756-3189 ,
COMPLIANCE NO: L920325 Page 1 of 1
"* NOTICE OF VIOLATION *"
LICENSEE / REGISTRANT DATE OF NOTICE URI, Inc. May 6,1992 Attn: Lille A. Canales .
12377 Merit Drive SuR- 750, LB 14 Dallas, Texas 75251 ,
DATE OF INSPECTION INSPECTOR (S)
.. , January 24,1992 Robin Houston LICENSEE /REGISTR ANT REPRESENTATIVE i
Lille Canales INSPECTION LOCATION STAFF REVIEWER Kingsville Dome Robert L. Green, Jr.
Klebert County Please refer to the abose COSIPLIANCE NDIBER when responding to this notice.
The following violations were found during the inspection of operations under License No.
LO3653:
- 1. Violation of License Condition 23:
Documentation of daily inspections for yellowene contamination was not available for review by the Agency.
This is a Severity IV Violation.
DO NOT RETURN THIS ORIGINAL " NOTICE OF VIOLATION" WITH VOUR RESPONSE. .
r TRCR 22.11(a)(4) REQUIRES THAT ANY SUCH NOTICE BE POSTED OR IN THE ALTERNATIVE, MADE AVAILABLE FOR ESIPLOYEE REVIEW, AS PERS11TTED BY TRCR 22.11(b).
REVIEWER JL @" Rf4L-RLG:mr Sce: Fike. :nsp. F1:e mee. .
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URI, INC.
(A Subsidiary of Uranium Resources. Inc.)
5656 South Simo;es 12377 Ment Drive Sune 750. LB 1a //
c.ft O Closita Piant Sune 250. LB B Deas. Temas 75251 7 HC01 Boa 50 Corpus Chnsk TX 7B411 Teconone (218193a 7777 San Diego. Texas 78384
- eieonone (512) 993 7731
'eecopy (512) 993 5744
'eec:Dy (218) 934 7779 Tm 910 B67.47C1 g 4 ie ephone (512) 279 33d2 ee:opy (512) 279 3343 MO a:> -
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Dil i Texas Department of Health David R. Smith. M.D.
Comnussioner I100 West 49th Street Austm. Texas 78756-3189 Robert A. MacLean, M.D.
Deputy Commiunoner (512) 456-7111 Radiation Control (512) 834-6688 July 16,1992 URI, Inc.
Attn: Lille A. Canales Ref: Compliance No. L920325
-^' -
12377 Merit Drive License No. LO3653 Suite 750, LB 14 Inspection of Jan. 24,1992 Dallas, Texas 75251 By Robin Houston A't Kingsville Dome Klebert County
Dear Ms. Canales:
We have received your le:ter dated May 15, 1992, informing us of the steps you ha correct the violation cited in our letter and NOTICE OF VIOLATION of May 6,1992. The corrective action noted appears to 'cring the item into com !
fe.t Control of Radiatio . and/or Condiuons of your License.pliance with the Texas Reculations for the cooperaiion and assistance.The results of vour corr:ctive action will Sincerely, WL Robert L. Green, Jr.
Technical Review and Enforcement Program Radioactive Materials Insp-a tion and Enforcement Branch Division of Compliance r.d Inspection Bureau of Radiacon Control RLG/vj 1
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Bureau of Radiation Control Division of Compliance and Inspection i
O( 1100 West 49th Street Austin, Texas 78756-3189 Page 1 of 1
' COMPLIANCE NO: L911735
- " NOTICE OF VIOLATION *"
D_ ATE OF NOTICE LICESSEFiREGISTRANT_ April 16,1992 URI, Inc.
Attn: Mark Pelizza 12377 Merit Drive. Suite 750, LB 14 Dallas, Texas 75251 INSPECTOR (S)
DATE OF INSPECTION _ j Robin Houston
July 25,1991 l LICENSEF> REGISTRANT REPRESENTATIVE Mark Pelizza STAFF REVIEWER I_NSPECTION LOCATION Roben L. Green, Jr.
j Kingsville Dome l Kleberg County Kingsville, Texas Please refer to the above COMPLIANCE NUMBER uben resp l No.
The following violations were found during the inspection of op IA3653:
- 1. Violation of TRCR 36.2 et. al.. !
The Licensee failed to maintain records to document compl Logging specified in Part 36 of the Texas Reeulations for Control !
Regulations, as referrenced in License Condition 10). l I This is a Severity III Violation.
l i DO RESPONSE.
NOT RETURN THIS ORIGIN AL " NOTICE TRCR 22.11(a)(4) REQUIRES TH AT ANY SUCH NOTICE ITTED
~
ALTERN ATIVE, MADE AVAILABLE FOR EMPLOYEE REVIE BY TRCR 22.11(b).
eM REVIEWER _
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I 4 URI, INC. i (A Subsidiary of Uranium Resources, Inc.) !
a 12377 Ment Dnve 5656 South S:apies Sune 750. LB 14 P O Box 5391 Sude 250. LB 8 DaHas. Texas 75251 Acute 1.. Box 425 Corpus Chrtsb. IX 78411 Teiepnone f214) 934 7777 Kingsvihe. Texas 78363 !
Teiepnone (512) 933 7731 e'ecco, :2* 4) 934-7779 Teiecnone (512) 595-5731 t Telecopy 1512) 993-5744 TNx 910 B67 4701 Te ecepy (512) 595-0403 l
May 35, 1992 to N r :
Mr. Robert L. Greene, Jr.
Staff Reviewer N
. -. I TEXAS DEPARTMENT OF HEALTH ; G ".~ !
Bureau of Radiation Control = *
.:n Division of Compliance and Inspection n ~J -
,, 1100 West 49th Street O
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Austin, Texas 78756-3189 m Q1 M i
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Dear Mr. Greene:
O r- :
1 This letter is in response to your Notice of Violation dated i April 16, 1992, where the following was alleged:
- 1. Violation of TRCR 36.2 et.al.: ,
The Licensee failed to maintain records to document compliance with the regulations specified in Part 36 of the ;
Texas Reculations for Control of Radiation (Well Logging i Regulation, as referred in License Condition 10). i This is a Severity III Violation. ,
Before responding to the corrective actions, URI would like to take exception to the severity of the alleged violation.
According to TRCR 13.9 (c) (i) (iii) , Severity Level III violations are ones that are significant and which, if not corrected, could threaten occupational and/or public health and safety or the environment. ,
We feel the allegation in this case, the records on the !
logging truck were not maintained in a logbook as is required in !
TRCR 36, actually may lead to a circumstance described in TRCR !
- 13. 9 (c) (1) (iv) , for Severity Level IV violations - violations that i are of more than minor significance, but if left uncorrected, !
could lead to more serious circumstances. In fact, in Appendix !
13-8, Section D, examples of Severity IV violations, Example #7 ,
was described as, " Failure to maintain complete records and/or ,
forms required by TRCR."
r We feel the alleged violation, which is being discussing in this correspondence and tne Severity Level IV example in Appendix 13-A are identical, which supports a reduction from III to IV in ;
the Notice of Violation.
.. . . - ..- - .. . . - . . - . - . - . . -. . .. . . _ - _ . - . . . ~ - - . - . . . .
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' Letter to Mr. R.L. Green May 15, 1992 i Page 2 ;
i Since the inspection of July.25, 1991, URI has revised the records of the logging truck, created a logbook, and in general, assured compliance with TRCR 36. We feel full compliance is in effect as of the writing of this letter. ;
Please feel free to contact me with any questions you may ;
have pertaining to this matter. !
Your vbry trul ,
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l' Enviren= ental Manager MSP/ dig .
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._f_p . Commissioner David .g"i Rc g,Smith" . . , . - - , M.D.d%.
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1100 West 49th Street Robert A. MacLean, M.D.
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Ref: Compliance No. L911735 Attn: Mark Peliz.za 12377 Merit Drive, Suite 750, LB 14 License No. LO3653 Dallas, Texas 75251 Inspection of July 25,1991 By Robin Houston
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At Kingsville Dome
.CCL _ Kleberg County Kingsville, Texas .
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Dear Mr. Peliz.za:
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We have received your letter dated May 15, 1992, informing us of the steps vou have taken to f' =.;. . .
- correct the violation ci:ed in o.r letter and NOTICE OF VIOLATION of April 16,1992. The
- ~ correcdve actions nou d appears to bring the item into com for Control of Radiation and/or Conditions of your License.pliance with the Texas Regulati
~
rc The Agency agrees that the violation cited was improperly assigned as a Severity I.evel III. It should have been listec as a Seventy Level IV.
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J T. the Ior he cooperation results of ano your corrective assistance. action will be verified during our next inspection. Thank y u
,:.q,; .. Sincerely, - -
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Robert L. Green, .
Technical Review and Enforcement Program .
~ "~ Radioactive Materials Inspection and
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Division or Compliance and Inspecu. on p.s . - Bureau of Radiauon Control
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L O3453 - Og g TEXAS DEPARTMENT OF llEALTII Bureau of Radiation Control L
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Division of Compliance and Inspection I100 West 49th Street Austin, Texas 78756-3189 CO51PLIANCE NO: L910512 Page 1 of 1
"* NOTICE OF VIOLATION "*
LICENSEE /R EGISTR ANT DATE OF NOTICE URI, Inc.
May 24,1991 Attn: Mark Pelizza 12377 Merit Drive Suite 750, LB 14 Dallas, Texas 75251 DATE OF INSPECTION INSPECTOR (S) 3 March 21,1991
~
Robin Houston LICENSEE /REGISTR ANT REPR ESENTATIVE Lilly Canales INSPECTION LOCATION i STAFF REVIEWER Kingsville Dome Robert L. Green, Jr.
Kleberg County Please refer to the above COSIPLIANCE NU51BER when responding to this notice. i l
l The following violations were found during the inspection of operations under License No.
LO3653:
1.
Violations of License Condition 39.A: '
a) Only one water sample was taken at each surface water source.
b) Sediment samples were not taken at all surface water locations,as required.
This is a Severity IV Violation. I DO NOT RETURN tills ORIGINAL " NOTICE OF VIOLATION" WITH YOUR R ESPONSE.
TRCR 22.11(a)(4) REQUIRES TIIAT ANY SUCII NOTICE BE POSTED, OR IN THE ALTERNATIVE, MADE AVAILAF a FOR EMPLOYEE REVIEW, AS PERMI'ITED BY TRCR 22.11(b).
REVIEWER RLG:mr l
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9 Texas Department of Health 1 Robert A. MacLean, M.D. I100 West 49th Street Actmg Comnussioner Ausun Texas 78756-3189 (512) 458-7111 Radiation Control (512) 835 7000 July 31,1991 CERTIFIED MAIL NO.C) %-a Q RETURN RECEIPT REQUESTED URI, Inc. Ref: Compliance No. L910512 Attn: Mark Pelizza License No. LO3653
~s 12377 Merit Drive Inspection of March 21,1991 Suite 750, LB 14 By Robin Houston Dallas, Texas 75251 At Kingsville Dome Kleberg County
Dear Mr. Pelizza:
On May 24, 1991 we sent you a NOTICE OF VIOLATION concerning a violation found during an inspection conducted by Robin Houston on March 21, 1991. A copy of that NOTICE is enclosed for your reference.
Iince we have not received a reply to that $0T CE, we rec,uire that you inform this of5ce of your corrective action within ten days after receiving this letter.
Sincerely, 7 E O y; William A. Silva Actinc C" -
Technical Review and Er'ifo
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7 SI!G \ - LO% B Radioactive Matenal Insm SENDER: i 6 and. . Enforcement Branc'h .* comsne ,tems i a,a or 2 for ace tenadev.co. ! 8 8'so *isa to rece'* :he Compiete cems 3. and da & b.
DWislon of Compliance and e Pnnt your name anc acdress on the reve'se of this form so i feenfollowing serv'ces (f Bureau of Radiation Contrc "*t *e c*a '"u'a t' s ca'a to = -
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- A tach this form to tre front of the maac<ece, or on the 3.
- aca if space does not permit, ~ Addressee's Address
Enclosure:
NOTICE OF N e
.m wnte -a nturn e article umoer. accest neauestea" n tre ma,io, ce next to! 2. a, sestncted cei.very
- 3. Artic,e Addressea to: Consuit oestmaster for 'ee.
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- 9. Addresse'e's Address ionly if recuested and fee 's Daid)
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f's Form 3811 octetser 1990 % 3 ,,o .eoo- m ,
i,.,. DOMESTIC RETURN RECEIPT !
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URI, INC. b$ -
(A Subsidiary of Uraniurn Resources. Inc.)
- 2377 Vent Dov e '
5656 Sosm StaDies Su te 750 LB 14 P O Box 5391 Su te 250. LB B CaLas 7enas 75251 Route 1. Ben 425 Cypus Chresti. TX 78411 ~ecano*ef2*4:934 7777 Kingsvdie, femas 78363
'e.ephonei512)933 7731 te e:cor t2'd, h34 7779 Te+-"" '5'2)S95 5731 ,
"e.e:Ory 4512)933 5744 '.9 9 0 557 4701 Terecocy (512) S95-0403 August 2, 1991 Mr. Villiam A. Silva, Acting Chief g Technical Review and Enforcement Program ;; -
Radioactive Material Inspection and ;.,
g Enforcement Branch -
c, y Division of Compliance and Inspection .
g Bureau of hadiation Control I.
Texas Department of Health f. .g 1100 West 49th Street c. . c.a Austin, Texas 78756-3189 3c -
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Dear Mr. Silva:
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The following is in response to your letter dated July 31,1991whic$
requested a reply to the May 24, 1991 Notice of Violation from the Bureau, and a response to that alleged violation which is the subject of that Notice. I have formatted this response by first restating the alleged violation followed with the appropriate answer:
- 1. Violations of License condition 39.A: ,
l a) only one water sample was taken at each surface water source, b) Sediment samples were taken at all surface water locations, as required.
This is a Severity IV Violation.
Response
3ecause of the geographic extent of the license area, there has been difficulty accessing sampling locations along Jeboncillo's Creek, upstream and drawnstream of the license area. Therefore, to satisfy the purpose of this license condition, URI will sample water quarterly, when present, and sed.iment quarterly, upstream and downstream of all licensed activities. These locations may fall within the licensed area if access if impractical.
A map with future sample locations is shown. The department will be informed of any changes in these locations.
. _.. _ . . _ . ___ .-_ _ .. . . . _ . . _ _ - _ _ . . ~
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Letter to Mr. Villiam A. Silva !
August 2, 1991 [
Page 2 l Implementation o' this saspling program will begin when the next set of l quarterly _ samples is due.
Please feel free to contact me with que i 1ons pertai ng t this matter.
Yo s ver t ly, '
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M rk SI Pelia
. Environmenta1\Mynager r
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CC: Lille Canales, URI Phil Shaver, TDH ,
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l .C -21 Texas Department of Health Robert A. MacLean, M.D.
Acting Cornaussioner I100 West 49th Stree Austin, Texas 78756-3189
($12) 456-7111 Radiation Control (512) 835 7000 i
August 26,1991 URI, Inc.
Attn: Mark Pelizza Ref: Compliance No. L910512
) 12377 Merit Drive. Ste. 750, LB 14 License No. LO3653 Dallas, Texas 75251 Inspection of Mar. 21,1991 By Robin Houston '
At Kingsville Dome Kleberg County, Texas !
Dear Mr. Pelizza:
We have received your letter dated August 2,1991, informing us of the steps you hav to correct the violations cited in our letter and NOTICE OF VIOLATION of May 24,1991 .
Please note that a Licensee may not unilaterally implement changes to their opei procedures or to their sampling program without plicI approval from the Agency. Your
" proposal" has been forwarded to the Division of Licensing, Registration and Standards fo review, if additional information is required, you will be contacted.
Although no additional response to Compliance No. 910512 is required, full complianc environmental sampling program.be achieved only upon issuance of an A If you have any quesdons, please contact me at (512) 835-7000, ext. 410.
Sincerely, ll t u Robert L. Green, Jr.
Technical Review and Enforcement Program Radioactive Materials Inspection and Enforcement Branch Division of Compliance and Inspecdon Bureau of Radiauon Control RLG/vj s
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TEXAS DEPARTMENT OF IIEALTII Bureau of Radiation Control Division of Compliance and Inspection 1100 West 49th Street Austin, Texas 78756-3189 CO3IPLIANCE NO: L900874 Page 1 of 1
"* NOTICE OF VIOLATION "*
LICENSEE / REGISTRANT DATE OF NOTICE URI, Inc. August 13, 1990 Attn: William J. Chapman 12377 Merit Drive Suite 750, LB 14 Dallas, Texas 75251 DATE OF INSPECTION INSPECTOR (S)
June 13,1990 Arthur Flores LICENSEE /REGISTR ANT REPRESENTATIVE Bill Chapman, RSO John Colt, Environmer/.21 Tech.
INSPECTION LOCATION STAFF REVIEWER Kinesville Dome Proiec:
~ ' Robert L. Green, Jr.
Kingsville, Texas Please refer to the abos e CO31PLIANCE NU3IBER when responding to this notice.
The following violation was found during the inspection of operations under License No.
LO3653.
- 1. Violation of License Condition .:5 A.:
The Licensee failed to repackage / dispose of by-product raaterit ' ; ent resin, etc.)
s:ored in severelv corroded drums. (This indicates that the requitec. .nonthly inspection or such drums :an,ed to result in the necessary correcuve acuon.)
This is a Severi:y III Violation.
DO NOT RETURN TIITS ORIGIN AL " NOTICE OF VIOLATION" WITII YOUR RESPONSE.
TRCR 22.11(a)(4) REQUIRES TIIAT ANY SUCII NOTICE BE POSTED, OR IN THE ALTERNATIVE,31ADE AVAILABLE FOR ESIPLOYEEREVIEW, AS PERMITTED BY TRCR 22.13(b).
0/
REVIEWER Ns.J2ew -
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2 URI, INC.
(A Subsidiary of Uranium Resources. Inc.)
? 2377 Ment Dnve
%56 Soum S:ases Ss te 753 LB 14 P O Box 5391 Ssoe253 LB8 Datas Teras 752M Route 1. Bcx 425 Corpus Chrt. TX 78411 Te>eonomer2'41934 7777 6ngsvine. Texas 78363
- e.ephone(512i993-7731 *e eccoy'214)934 7779 Teleonone(5121595-5731 Te'ecopy(5'2:'v93 5744 r!.7 9'D 567 4701 *e<eccoy 1512) 595-0403 August 23, 1990 n sa '
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v Texas Department of Health * -
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- m Division of C7&rliance and Inspection '
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-A o.3 c.a RE: :::pliance !!o. : L900874 x ,
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- entlemen: I The f e'.1: wing is a response to your !!otice cf violatien dated 2.ugust 13, '990. . I have f:reatted this-respense by first restating the alleged violatien and then the ccrrective acticn.
".. Violat::n of License Cendition 45.A.: The Licensee failed to repacka;e/ dispose Of by product :aterial spend resin, etc.)
stored tn severely cerroded drums. This indicates that the required :enthly inspecticn of such drums failed to result in the necessary cctrective actien. This is a Severity III Violation.
Fespense:
- n the future, by-product :aterial will be disposed of in plastic drums which will not cerrode. All material at Kingsville Dome has been transferred from the steel drums to the plastic drums, and we are in full cc:pliance at this time.
One area where URI takes exception to this alleged violation is the severity level. TECR 13.9 (c) (iii) * (iv) define severity levels as folicws:
'iii) Severity Level ::I - Violations that are stgnificant and which, id not corrected, could threaten Occupational and/or public health and safety er the environment.
.iv) Severity Level :V - violati:ns that are of ore than minor signif;cance, but if left uncorrected. ceuld lead to : ore serious circu: stances.
The sub;ect drum was placed on a eurbed cenerete pad and was not
'. e a k i n g . Therefore, even if no corrective set:en, and the drum leaked, there would he no ;ctential to threaten ecenpatienal and/cr public r]
health and safety or *he ir.virenrent'as :s the case wl h a-Severity
l c 24 Letter to TDH August 23, 1990 Page Two Level III violation. .More correctively characterized, the corroded drum was of ninor significance, and if left uncorrected, could lead to more serious circumstances (i.e. they .ay leak) as is the case with Level IV violations.u By this letter, we request a change in the status of the violation from Severity Level III to IV.
Please feel free to centact e with questions pertaining to this
.atter.
youre very T
! Y l*aly,f *
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Mark S. Pelizza Environrental Manager l MSP/dl; i
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Texas Department of Health Robert Bernstein, M.D., F. A.C.P. I100 West 49th Street Commissioner Robert A. MacLean, M.D.
Austin. T*tas 78756-3189 Deputy Commissioner (512) 458 7111 Radiation Control (512) 835-7000 September 11,1990 URI, Inc.
Ref: Compliance No. L900874 Attn: William J. Chapman License No. LO3653 12377 Merit Drive Inspection of June 13,1990 Suite 750, LB 14 By Arthur Flores Dallas, Texas 75251 At Kingsville Dome Project ,
Kingsville, Texas '
Dear Mr. Chapman:
We have received Mr. Pelizza's letter date! August 23,1990, informing us of the steps you have taken to correct the violation cited in wr letter and NOTICE OF VIOLATION d August 13, 1990. The corrective action noted appears to bring the item into com Texas Regulations for Control of Radiation and/or Conditions of your License.pliance wi
'After review of additional facts concerning the cited violation which you have provided
- (principally that the drum was on a curbec paa), the Agency agrees with your assessment of Ireduced risk to the public and/or the environment. Therefore, the violation of License Gondition 45. A. in Compliance No. L900874 is hereby reduced to a Severity IV.
'The results of your corrective action will be verified during our next inspection
. Thank you for the cooperation and assistance.
Sincerelv.
. + -
Rob'ert L. Green, Jr.
Technical Review and Enforcement Program Radioactive Materials Inspection and Enforcement Branch Division of Compliance and Inspection Bureau of Radiation Control l
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bcc: File, ;,scect:r's File 'legien ,,
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ATTACHMENT D l
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43.31(c)
! (c) Each pr.: son licensed by. the Agency pursuant to this part shall confine --
. his us6 and possession of the licensed material to the locations and purposes authorized in the license.
(d) (1) Each licensee shall notify the Agency, in writing, immediately following the fi'.in; of a voluntary or involuntary petition for
, bankruptcy under any Chapter of Title 11 (Bankruptcy) of the United States Code (11 U.S.C.) by or against:
(i) a licensee; (ii) an entity [as that term is defined in 11 U.S.C. 101(14)]
controlling a licensee or listing the license or licensee as property of the estate; or (iii) an affiliate (as that term is defined in 11 U.S.C. 101(2)]
of the licensee.
(2) This notification must indicate:
(i) the bankruptcy court in which the petition for bankruptcy was filed; (ii) a ecpy of the bankruptcy petition; and (iii) the date of filing of the petition.
(e) Operations shall be conducted so that all effluent releases are D reduced to as 1:w as is reasonaoly achievaole below the limits of part 21 of these rules.
(f) Daily inspection of any tailings or waste retention systems shall be conducted by the licensee. General qualifications for such indivi-duals conducting such inspections sna11 be approved by the Agency.
Records of the inspections shall be maintained for review by the Agency.
(g)/ The licensee shall immediately notify the Agency of the following:
,./
(1) any failure in a tailings or waste retention system which results in a release of tailings or waste into unrestricted areas; (2) any release of radioactive material wnich exceeds the concentra-tions for water listed in Appendix 21-A, Table II, Column 2, in part 21 of these rules and whien extends beyond tne licensed boundary; (3) any spill which exceeds 20,000 gallons and wai:h exceeds the concentrations for water listed in Appendix 21-A, Table 11 Column 2, in part 1 of these rules; cr G) any release of solids wnich exceeds the contamination limit s in 21.108 anc vni:h extends oeyond the licensed boundary.
43 - 3 'Aoril 1990)
9 43.31(h)
(h) The licensee shall notify the Agency within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the following:
(1) any spill that extends:
(i) beyond the wellfield monitor well ring; (ii) core than 400 feet from an injection or production well pipe artery to or from a recovery plant; or (iii) more than 200 feet from a recovery plant; or (2) any spill which exceeds 2,000 gallons and which exceeds the concentrations for water listed in Appendix 21-A, Table II, Col umn 2, in Part 21 of these rules.
43.32 Expiration and Termination of License (a) Except as provided in 43.33(b) and 43.32(d)(4), each specific license shall expire at the end of the day, in the month and year stated in the license.
(b) Each licensee sigli notify the Agency immediately, in writing, and request ter=ination of tne license shen the licensee decides to terminate all ac tivities involving sacerials authorized under the license. This notification and request for ter=ination of the license cust include the reports and information specified in 43.32(d)(1)(iii) 1 and (f). The licensee is subject to the provisions of 43.32(d) and i
- e), as applicable.
(c' No less than 90 days before the expiration date specified in a specific lic ense, the licensee shall either:
'1) submit an application for license renewal under 43.33; er
- ) notify the Agency in vriting, under 43.32( b), if the licensee decides to discontinue all ac tivities involving radioac tive l material.
(d) (1) If a licensee does not submit an application for license renewal under 3.33, the licensee shall on or be fore the expiration date specified in the license:
(i) terminate use of radioactive material; i (ii) properly dispose of radioactive material; and (iii) s u bmi t a record of disposal of radioactive material and radiation survey (s) of licensee's permanent location (s) of
- se and/or storage. Levels of radiation shall be reported as required by
- 1.108, :1.109, and 3.90(1). The survey or e a s ur emen t in s t r umen t ( s ) used for conducting the survey snall be specified.
9 (April 1990)
ATTACHMENT E I
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. E-3 _ t URI, INC.
(A Subsidiary of Uraniun Resources, Inc.)
'2377 Ment Drve 3333 Everhart Acad Sule 750. LB 14 P O Box 5391 5#te 126 La tas Tenas 75251 227 West King Avenue Cypus Chnstt Texas 76411
- e ecnone (214) 924 7777 Kingsv+e Texas 78363
- e conone iS12) 851 *!91 'e eco::y (21e1934.7779 Teieonone (512) 595 5731 e.e: coy 512) 8524441 /.'x 910 867-4701 Terecopy (512) 595 0403
- (' -N U September 13, 1988 t
)i Mr. Tommy Ctrdwell Texas Department of Health 1100 West 49th Street Austin, Texas 78756
Dear Mr. Cardwell:
This letter is in response to our recent telephone !
conversation where you requested further information l regarding the leaks in the ponds at the Kingsville Dome '
Project.
The leak in the south pond was first detected on March )
, 25, 1988 and repaired on July 15, 1988. The leak in the north pond began on June 7, 1988 and was repaired July 19, 1988. The cause of the leak was diagnosed as faulty pump jackets which caused pump vibration to cut the liner. No damage resulted in the second liner so there was no risk of by-product material being released.
e Repair of the south pond was delayed because of a !
pending amendment to the disposal well which prevented its l use. The north pond was filled with dissolved HCO3 at the ;
time, so there was no disposal source for the fluids. Water j was continuously pumped from the south pond leak detection j well into the pond while the pond contained water. '
i Please feel free to contact me with any cther questions
! pertaining to this matter. :
Ve r/y )truly yours, s
- ', s' r -
arE S. Pe V l Environmenta,1' Manager f MSP/ dig s
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ATTACHMENT F i
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,< . e n5~1' d' RF' BC' TC, HW TEXAS DEPARTMENT OF HEALTH
^us= = ^s 3CO INTER-OFFICE COMPLAINT RLE NO. )JQ THRU: xalph S. Heyer Qf (-?tN ce5 , /
4 Ruth E. McBurney 6ygfd FROM: Philio Shaver TO: Richard Ratliff [ AM 6l-' 7 g.
SUBJECT:
Possible Unauthorized Activities by Licensee The Agency has received information from an individual claiming that URI, Inc. (License No. LO3653) is irrigating with fluids frem either the mine or the plant process at the Kingsville Dome facility (Site No.
000). URI informed C. D. Rao and Gary Smith on Apnl 26,1991, that they were planning to conduct a pilot irrigation study at the Kingsville Dome facility. URI was advised in a letter dated May 14, 1991 (copy attached), that approval by license amendment was necessary before beginning the pilot project and requested to provide additionalinformation regarding the proposed pilot project. URI responded in a letter dated May 20,1991. To date authorization has not been granted for any type of irrigation project, including the proposed pilot project, at the Kingsville Dome facility, if URI is conducting an irrigation project at the Kingsville Dome facility, it may be without the appropriate Texas Water Commission (TWC) permit. Therefore, the TWC may need to be notified. ;
Please take de action (s) that you deem appropriate.
SIGNED v+
h.' .
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DATE June 21.1091
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TEXAS DEPARTMENT OF HEALTH P-L AUSTLN TEXAS ' - t INTER-OFFICE DATE: July 11,1991 f
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TIIRU: RICHARDAATLlyF _f V s. i
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BOB FJ.EE r0 C BRAD CASKEDV ,
i HELEN WATKINS k TO: COM# 739 LIC# 3653 FROM: THOMAS CARDWELL Yevneg ,vM
SUBJECT:
INVESTIGATION OF UNAUTHORI7.ED DISPOSAL OF BYPRODUCT MATERIAL AT URI KINGSVILLE DOME In a memo date June 21,1991, Phil Shaver indicated he had received an anonymous complaint alleging that URI Kingsville Dome was disposing of process fluids by irrigation. On June 28, 1991, I contacted Mr. Ray Newton of the Water Commission concerning the URI projected and informed Mr. Newton that the Agency would be performing an investigation of the project. I inquired concerning a joint investigation with the Water Commission. Mr. Newton indicated he would contact the Water Commission's Regional Office in Corpus Christi and that I should contact Mr. Volz at their Corpus Office when I arrived in Corpus. On, July 1,1991, I traveled to Corpus Christi and contacted Mr. Volz. Mr. Volz indicated he was short staffed and that the Water Commission would not be accompanying us to perform the investigation.
We then continued on to the URI Kingsville Dome project located near Kingsville, Texas to perform an investigation of the complaint. After arrival at the Kingsville Dome Project we met with the URI officials as listed in /.ttachment I to this memo. Mr Pelizza further explained that URI had met with Mr. Thibodeau of the Water Commission on April 26, 1991, and was under the impression that a permit was not needed. URI also met with Mr. Gary Smith and Mr. C.D. Rao of the Agency and was under the impression that the project would not require a License amendment which is supported by C.D. Rao's memo dated April 30, 1
1991. However, Mr. Phil Shaver sent Mr. Pelizza a letter dated May 14, 1991, intorming URI that any method of by-product disposal would require a license amendment (the April 30 memo and Phil's letter dated May 14 are included as attachment 2).
Mr. Craig Bartels explained the barium chloride treatment an radium removal process. The procedure t
for barium chloride addition is included as Attachment 3 to this memo. Dr. Duane Ut ey, a soils chemist consultant, explained the land ap are three soil types in the area considered for irrigation. plication Two main crops of the are grown treated within the solution area. URI marked off a 20 by 20 foot area for each soil type and each crop. Each 20 by 20 foot area was further divided into four separate blocks. A total of nine blocks were used in the research. The test area is northwest of the plant facility as indicated by the red dots on Attachment 4 of this memo. The total amount of 6uids which would have been applied at the conclusion of the project would have been approximately 36,000 gallons. The total amount of i Guids applied as of June 28,1991, at the time the project was halted, was 14,588 gallons as i indicated in attachment 5 to this memo. The analyses of the fluids used are included as !
attachment 6. Page 1 of attachment 6 is the chemical' analyses performed by URI of the Duids prior to irrigation. Page 2 of attachment 6 is the analyses of the treated water from the barium chloride treatment tank prior to being loaded in the irrigation tank. Page 3 of attachment 6 is the analyses from a composite sample collected from six trailer loads of Guid prior to being !
used for irrigation during the 6rst week of the project. Page 4 to attachment 6 is the composite sample : rom the irnganon tank tor the second week of the project. Page 3 to attachment 6 is the analyses of the fluids prior to treatment. After review of the analyses, arsenic is the only
.g-F-3 L i
' groundwater protection standard which was exceeded. However, the land has been used for i
cotton production where arsenic is routinely use at much higher concentrations and would mask any soil analyses for arsenic.
After review of the records and discussing the purposes and procedures of the project, we !
proceeded to the irrigation areas. A total of 12 soil samples were collected from the irrigation plots. The samples were submitted to the Bureau of Laboratories for radium, uranium,
- molybdenum, copper, and arsenic. A list of the samples collected are included as attachment ;
7.
i On July 10,1991, I contacted Mr. Jack Thibodeau concerning his contact with URI and discussions about the irrigation project. Mr. Thibodeau indicated he had discussed the project ;
with Mr. Pelizza and had determine that a project of this size and limited amount of fluids used i would not require a permit from TWC. Mr. Thibodeau had verbally authorized the project. !
In conclusion, the project appears to be for research only and not for waste disposal. URI is I trying to determine if the soil can be treated with sulfur or gypsum to offset the sodium build- !
up in soil. The main problem appears to be the build-up of sodium in the soil to levels which j would prevent agricultural use of the land. The fluids were successfully treated to remove :
radium and uranium to concentrations below the release to unrestricted limits. Also, the Duids #
4 are used for a useful purpose and can not be considered as waste. Therefore, the fluids do not !
fit the definition of byproduct material. After review of the License, Agency staff could not determine that URI was in violation of the License by diverting fluids to the byproduct removal i
system. URI, apparently, has not violated the Rxas Regulations for Control of Radiation or i their License. Should URI determine that irrigation with treated Guids is feasible, the Agency !
will need to determine if irrigation would be a major change of operations and if a License amendment would be required.
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Texas Department of Health Robert Bernstein, M.D., F. A.C.P.
Commimoner 1100 West 49th Street Robert A. MacLean.M D.
Austin. Texa 78756-3189 Deputy Commissioner (5i2) 458-7111 Radiation Control (512) 835 7000 May 14,1991 Mr. Mark S. Pelizza URI, Inc. Re: Radioactive hiaterial 12377 Merit Drive License No. LO3653 Suite 750, LB 14 Dallas, Texas 75251
Dear Mr. Pelizza:
This letter will serve to confirm our telephone conversation of this date. On April 26,1991, you and Dr. Gardiner of Texas A & I University visited with Dr. Rao and Dr. Smith of the Agency at our of6ces in Austin to discuss a proposed pilot project involving irrigating land with treated waste fluids from the Kingsville Dome (KVD) uranium mining project. Waste fluid from a uranium recovery process is considered byproduct material. Any deviations from or changes in procedures i
by licenseapproved currently amendment. by the Agency for management of byproduct materials require Agency approval The proposed pilot project constitutes a change in byproduct material management license procedures. Before initiating the pilot project, URI must obtain Agency approval by amendment.
information: The amendment request should, as a minimum, provide the following
- 1) provide a diagram of the treatment process indicating where the process connects with current process circuitry; 2) describe the method for treatment of the Guids; 3) describe the equipment used in this treatment process; 4) describe the containment system where the treatment process is located; 5) provide an updated map of the KVD plant site indicating the location of the Guid treatment circuitry; 6) describe how the material removed by the treatment process will be managed; 7) indicate the types of test (parameters checked) performed to demonstrate that the treated Guids meet limits for release; 8) describe the type, method, and frequency of sampling of the treated Guid; 9) indicate the frequency of analysis of the samples; 10) indicate who will perform the analysis of the samples; and 11) desenbe the analytical methodology.
. Please provide two copies of all material submitted supponing an amendment request. If you ha any questions regarding this matter, please contact either Mr. Ralph S. Heyer or myself.
Sincerely, Philip . Shaver, Chief Uramum and Nuclear Waste Management Program -
Division of Licensing, Registration and Standards n , , ,,,, , , n e p - a:- . : - e ~ . - '
D lb $ ,
i l 1 Texas De3artment o -ea t1 Robert Bemstein, M D., F.A C.P. 1100 West 49th Street Members of the Board i Commissioner Austin, Texas 78756 3199 Ron j_ Anderson. M D.. F.A C P., Chairman Robert A. Mactean. M D. (512)458-7111 Ch a"**n Ra,les,h,R-gteIV g gcM Dg'Q Deputy Commissioner loan wood Bigge staff Robert E Bonham. M D.
Don L. Brewer rAye Frank Bryant, Jr.. M D.. F.A.A.F.P.
(59)4$g7477 Ramiro R. Cuso. M D.
Da ud L. Collins. P E.
Gill Harber. D D s.
Larry D Krupala Donald M. Pereeson. D O.. F A C C P.
Susan B. P! ace. O D.
Wilham D Potect Ill. F.A C.H E.
witon L. Risinger. D V.M.
Wilham A Scott Barbara T. 51over. R.Ph.
g .
3q .$ 4 *,j Ruth F. Stewart. R.N C. The Honorable Irma Rangel Texas House of Representatives P.O. Box 2910 Austin, Texas 78768-2910 A1TN: Ms. Myra Leo
Dear Representative Rangel:
Enclosed is a copy of the Texas Department of Health Bureau of Radiation Control investigation at the Uranium Resources Inc. Kingsville Dome facility that you requested last week. The inspection determined that no violations had occurred in the pilot irrigation project. If you have any questions, please contact Mr. Richard A. Ratliff, Director of the Division of Compliance and Inspection, Bureau of Radiation Control at 835-7000. Sincerely, I P.Orort A. P.iacLeaa ' ' D. Cspu:y Comm.ss.cru Robert A. MacLean, M.D. Acting Commissioner of Health Enclosure I bec: RAR: Soard, ca1 License\File #LO3653, :nspector's File (Reg. 9), RAM, Lillian Gilligan FRoM T.4E OFFICE OF Bl'REAU OF ?ADIATION CONTROL k
S 1 J e 9 t 4 ATTACHMENT G 4 i f t 1 e 4 1
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TEXAS DEPARTMENT TEXAS OF HEALTH AUSTIN InrrER-OFFICI TO Phil Shaver - - rADW fartivn Preusse sV5Jac; Pseuest fer 0-madrent of URI's ti ense pecardiae *rterim sterece cf evereduct Material at Resita In reply to your .eamo of 1/14/93, I Oppose the granting of Amendment cf license no. LO3653 for the Rosita site (001) at requested by Mr. Mark Polissa in his letter of 12/2/92. The licensee has clearly violated conditica 530 of the license by placing materiale in the interLa storage pond which are specLfically prohLbited. It is a mockery of the Agency's efforts to regulate through license c=ndition for a licensee to knowi'ngly violate a license condition and then request Leendment of the license condition so that ' complete compliance with the license can be achieved.* Condition 53 was put into the license in Amendmant 7, dated 6/14/90, to allow interLS storage of specified byproduct aterial f cm deccepissicning of 77I's Senavides and tongoria projects because cf 77:'s ar;wrent that no disposal sit. was availacle at that ti.ve (Polissa's letter of 8/23/33). All of condition 53 (Parts A - L) was carefully and delLberately written so as to restrict the types of typr0 duct Sater al to be placed in the interla storage pond and to require procedures which would not jeopardise the liner system and would f acilitate :etrieval of the typrcduct rater;41.
~
Staf f cenearns a:cus UR:'s 4/23/89 pr:pesal are clearly indicated by the recced tt
- cmmunicatien with 7RI in the license fi;: agency lettere dated 9/21/89 and 1/30/90; URI's letters dated 10/23/89, 2/13/90, and $/22/90; documentatien of telephone d L ocuss icas between Mr. Polizza and . e dated 1/16/90 and 5/7/90s C.D. Rao's como
- ated 4/4/90s Stil Price's trtp re;:rt name dated */i/903 and my license review sreet i for log no. 5-107-89. Mr. Polissa -as aware of the staf f's concerns, understood '.nat
. waterials were ret to be placed in ,ns interts escrage pond (e.g., his letter of 2/13/tt), and agreed to the it:ense ::ndition (his letter of 5/16/90). The only subsequent chan;es to CondLtten 53 ere made in Amendments a and 11 et the license
* ' concerned clarification that tne south pond at Pesita is the designated interte n, sgo pond and information r egarding ::nstructicn plans.
The license authorizatica f or taterim storage at Resita expLres 6/3C/93 (Condition 53A). ly that tL 4, all byproduct ratettal in the interim storage pend should to removed and dispesed of in a licensed ,dtsposal site, and condition $3L should be complied with. : recommend that ths prohibited eaterial which has been placed in en antarim stora;e pend be allowed to remain until the other material is reeeved, but n later than 6/30/93. This would avoid any pessible damage to the 1Lt.or system f rcm attempttng to remove the prohlbLted ratorial tef ers then. However, VRI should c.ct t relieved of any other enfercement action resulting from their violation of the license. With respect to the expiration date fer .no autnortsation of interLa storage, ; reco nend that tne Agency net grant any extension if requested by URI. The staff's intention in granting the authorisation criginally was that the escrage be temporar-There are acw avatlable to URI both in-state and cut-of-state lleensed byproduct etterial dispcsal sites. Any continued use of the interim storage ;ond at R=sita beyond 6/30/93 conf 1Lets 't - guidance from the U.S. Nuclear Regulatory Csamies ten (attached positten transettted 9/6/91) because ef t-site disposal opttens are available and because URI has not
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TEXAS DEPARTMENT OF HEALTH Bureau of Radiation Control Division of Compliance and Inspection 1100 West 49th Street Austin, Texas 78756-3189 1 COMPLIANCE NO: L930146 Page 1 of 1
, . . , . . , . . , _ *" NOTICE OF VIOLATION *"
LICENSEE / REGISTRANT DATE'OF NOTIC.E URI, Inc. March 23,1993 Attn: Lille Canales 12750 Merit Drive Suite 1210, LB 12
- Dallas, Texas 75251 DATE OF INSPECTION INSPECTOR (S)
I- - January 26,1993 Robin Cooksey - LICENSEE /REGISTR ANT REPRESENTATIVE
-{- Lille Canales
- INSPECTION LOCATION STAFF REVIEWER Rosita Project Robert L. Green, Jr. i Duval County Please refer to the above COMPLIANCE NLNBER when responding to this notice.
The following violations were found during the inspection of operations under License No. LO3653:
- 1. Violation of License Condition 53.D.:
The Licensee has placed prohibited materials (rocks)in Rosita Pond A. Based on ' employee interviews and correspondence form the Licensee, this action was a willful violation. This is a Seved:y III Violation.
- 2. Violation of TRCR 36.11(c):
1.^. " Logging sources were not s ored in a bunker or in down-hole storage. (They were stored m a locxed, unoccupied ofEce.) M=
"2 - .
- This is a Severity IV Violation.
K. 3.,i: _. 3. Violation of License Condition 31. A.:
-r 4.- - .
Instruments used to conduct required physical radiatica survevs were not calibrated at
;* six-month intervals, as reouired re:
- e number 839; and Ludlum l'4C, nu(mber 81859).Eberline PRS-2, number 378; Eberlin This is a Severity IV Violation.
- DO RES NOT PONS RETURNE. THIS ORIGIN AL " NOTICE OF VIOLATION" WITH YOUR TRCR 22.11(a)(4) REOUIRES THAT ANY SUCH NOTICE BE POSTED. OR IN THE ALTERNATIVE MAD'E AVAILABLE FOR EMPLOYEE REVI W, AS PERMITTED
._, BY TRCR 22.11(b).
1 - - - -- - REVIEWER _a-
\. . _ _ . t_.. _ _ ~
W nwm N N.Pyed
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URI, INC. (A Subsidiary of Uraniurn Resources, Inc.) 8'N 12377 Ment Dnve 5656 Sov n Stapies Swte 750, LB 14 P O. Box 5391 Sute 250. LB B Dattas, Texas 75251 Route 1. Box 425 Corpus Chnsti. TX 78411 Te:epnone (214) 934 7777 Kingsvme. Texas 78363 Telephone (512) 993 7731 Te ecocy (214) 934 7779 Telephone (512) 595-5731 Telecopy (512) 993 5744 TNx 910-867 4701 Teiecopy: (512) 595-0403 April 13,1993 o <a n
> L) R C ; i. y <
Mr. Robert L. Green, Jr. -. -> --. , Staff Reviewer G :o . c :. . ~ 5 TEXAS DEPARTMENT OF HEALTH E '] Bureau of Radiation control O SC ~2 -: Division of Compliance and Inspection 1100 West 49th Street []
- o "
j' Austin, Texas 78756 3189 " 3= l RE: Licensa No. LO3653 Compliance No. L930146
Dear Mr. Green:
The following is being written in response to your Notice Of Violation dated March 23,1993. We have formatted this response by first restating the alleged violation and then responding
' according to the TDH
- Explanation and Guide for Response".
- 1. Violation of License Condition 53.D.:
- The Licensee has placed prohibited materials (rocks) in Rosita Pond A. Based on employee interviews and correspondence from the Licensee, this action was a willful violation.
Response
' URI notified the Agency of this incident by letter on December 2,1992, after the placement of the rocks was brought to our attention during a corporate ALARA audit. The December 2nd letter requested authorization to place the coarse materials into the south pond, providing the integrity of t
the liner was maintained by placing fine material between the liner and the coarse materials. Authorization was given on February 24,1993. The reason for this incident was a result of lack of understanding by URI field operations personnel as to what was authorized for disposal into the ponds. This situation was discussed in detail with TDH staff at a meeting which included Richard Rathff and Ruth McBurney on March f, 1993. As discussed at this meeting, URI is taking corrective action by adopting " Standard Operatin
- Procedures Relative to Inter Departmental Communications
- These procedures with a directive frori 4
the President of URI is attached. I Full compliance with this violation via license amendment and these Procedures is in effect at this time. t . l
. , . ,- - - _ _ _ __ ._ \
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1 Leuer to R. L. Green April 13,1993 i , Page 2 i
- 2. Violation of TRCR 36.11(c):
, Logging sources were not stored in a bunker or in down-hole storage. (They were stored in a locked, unoccupied office.)
Response
2
' Following the subject inspection, the down-hole storage facility for the sources was constructed and storage was performed in compliance with TRCR 36.11(c). We are in full :
compliance with this violation at this time. ' 4 l 3. Violation of License Condition 31.A.:
)i instruments used to conduct required physical radiation surveys were not calibrated at six- i month intervals, as required (re: Eberline PRS 2, number 378; Eberline MS-2, number 839, .
and Ludlum 14C, number 81859). I
Response
The calibration frequency for all instruments was changed with Amendment #15 of the subject license. Because this was not the intent of Amendment #15, the change in calibration frequency did not draw our attention, and calibrations, according to the new schedule, inadvertently were not performed. Pursuant to the amended condition 31-A. we are now calibrating allinstruments two per year.
- As. shown on the attacned memo, we also intend to file a request to return to a once-per-year schedule.
We are in full compliance at this time. Please feel free to contact the undersigned with questions pertaining to this response. Your very trul ,
, p' -
lark S. Pelizz s Env;ronmental Manager 3 MSP/ dig Encl. cc: Kelly Biddle/URI Rosita Lille Canales/URI - Rosita Bill McKnight/URI Corpus Christi
+5 3 e
MEMORANDUM 1 TO: Harry Anthony ; Craig Bartels Kelly Biddle Lille Canales t Dick Clement Bill McKnight Mark Pelizza Martin Utley A FROM: Ray Larson I DATE: April 13,1993 '
SUBJECT:
Standard Operating Procedures Relative to inter-Departmental Communications It has recently been brought to my attention that a lack of communications between various environmental and operations personnel and lack of communications between levels of operations personnel has resulted in the unauthorized placement of materials in the waste storage ponds at Rosita, which, in turn, has resulted in a significant violation. An 1 incident such as this is intolerable under any circumstances. i By this memorandum, I am directing management to implement the attached Standard Operating Procedures Relative to Inter-Departmental j Communication. l l 1 will be following this matter closely to assure the Procedure is l implemented and a situation such as the Rosita waste storage problem does not occur again. R. Larson f
1s.6 Standard Operating Procedures Relative to Inter-Departmental Communication As the Radiation Protection Officer is involved with activities of both the environmental and production groups, it is vital that information and activities of each group be coordinated to facilitt.a proper regulatory compliance and environmental safety. The following basic guidelines are offered as standard operating procedures for both groups. Inter-Company Communications
- 1. The Radiation Safety Officer will meet, either in person or by telephone, with the Corporate Environmental Manager on a bi-weekly basis. The officer will update current activities, highlight suspected problem areas and discuss any problems encountered interfacing with the production group.
2, The Radiation Safety Officer will meet, either in person or by telephone, with the Plant Manager on a daily basis. Included in discussions will be results of plant inspections, updates of employee records, potential problems, and employee compliance with regulations.
- 3. The Plant Manager will be responsible for ensuring proper compliance of rules and regulation at that facility. The Plant Manager will also ensure that a cordial and effective working relationship is maintained between plant employees and the
- Radiation Safety Officer.
l 4. Following an outside audit of environmental activity and compliance, the Corporate ; Environmental Manager will issue a management memorandum synopsizing results ) ] and assigning corrective actions as required. Memorandum addressees will include Production Vice President, Plant Managers, and the Radiation Safety Officer. ! 5. Following semi annual inspections by regulatory agencies, the Radiation Safety i Officer will review the inspection in writing including suggested corrective action for deficiencies. Corrective action will be coordinated with plant managers prior to release of the report. Copies of the report will be sent to Production Vice President, Corporate Environmental Manager and Plant Managers. l J
l
- 1 d_ ;
New or Revised Rules and Regulations
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- 1. The Radiation Safety Officer will be responsible for ensuring that appropriate production personnel are fully informed of all new or newly revised regulatory rules ;
and regulations. '
- 2. Upon receipt of new or newly revised regulations, the Radiation Safety Officer will ensure that the Plant Managers are informed of the revision, and that a copy of the revisions is made available to the Plant Managers, j
- 3. Plant Managers, after reviewing the regulations, will meet with the Radiation Safety
/th W Officer to discuss the regulations and to devise revised policies and procedures as required.
- 4. The Plant Managers will meet with appropriate supervisory subordinates to explain and implement the revised policies and procedures.
- 5. The Radiation Safety Officer will conduct spot inspections as the officer deems ;
necessary to ensure that amended plant policies and procedures have been instituted j and are being followed. ' l
- 6. Observation, by the Radiation Safety Officer, of violations of revised policies and procedures will be followed by implementation of steps for reporting and correcting violations. .
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- 7. The Radiation Safety Officer will ensure that publicly displayed permits, rules and regulations are updated to include revisions and new policies. '
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1 \ i Reporting and Correcting Violations i 1 4 l 1 l i
- 1. If, during inspections or audits, the Radiation Safety Officer detects a violation of company rules or permit regulations, the officer will immediately report the violation ,
to the appropriate plant manager. l
- 2. The Plant Manager will take appropriate steps to cease or alter those activities deemed by the Radiation Safety Officer to be in violation. The Plant Manager will l ensure that all subordinates are adequately informed of the violation of changes in procedure to eliminate the violation.
j 3. If the Plant Manager is unavailable at the time of the occurrence, those activities I g deemed to be in violation by the Radiation Safety Officer willimmediately cease and c l' will not be recommenced without involvement of the Plant Manager.
- 4. The Corporate Environmenta! Manager will be contacted if the Radiation Safety Officer and the Plant Manager disagree concerning a violation of regulations. The Corporate Environmental Manager shall serve as the final arbiter of the disagreement.
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- 5. If the Corporate Environmental Manager is unavailable at the time of the 2
disagreement, the Production Vice President shall serve as the arbiter.
- 6. If neither arbiter is available at the time of the disagreement, those activities believed by the Radiation Safety Officer to be in violation of the permit shall cease until I arbitration is available, j
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3 I d Texas Department of Hea_th Deid R. Smith 1100 West 49th Strea Commissioner . M.D. Austin, Texas 78756 3189 Robert A. Mactean. M.D. Deputy Commissioner ! (512) 458 7111 Radiation Control f512) 8 r4688 May 3,1993 URI, Inc. 3) Attn: Lille Canales Ref: Compliance No. L930146 License No. LO3653 12750 Merit Dnve Inspection of Jan. 26,1993 Suite 1210, LB 12 By Robin Cooksey Dallas, Texas 75251 At Rosita Project Duval County
Dear Mr. Canales:
We received Mr. Mark Pelizza's letter dated April 13,1993, informine us of the steps you have taken to correct the violations cited in our letter and NOTICE OF VI~OLATION or March 23, 4 1993. The corrective actions noted appear to brine the items into compliance with the Texas i Regulations for Control of Radiation and/or Conditions of your License. 6 The results of your corrective actions will be verified during our next inspection. Thani vou for the cooperation and assistance. , Sincerelv Roben L. Green Technical Review and Enforcement Proeram ' Radioactive Material Inspection and Enforcement Branch Division of Compliance and Inspection Bureau of Radiauon Control l RLG/nd bec: ' y t t ', . . ;, ,, re. -
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