ML20138J244
| ML20138J244 | |
| Person / Time | |
|---|---|
| Site: | 04006659 |
| Issue date: | 10/21/1985 |
| From: | Konwinski G, Pettengill H, Shopenn N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20100N335 | List: |
| References | |
| TASK-TF, TASK-URFO 40-6659-85-03, 40-6659-85-3, NUDOCS 8510290295 | |
| Download: ML20138J244 (7) | |
See also: IR 05000730/2008001
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
URANIUM REC 0VERY FIELD OFFICE
j NRC Inspection Report: 40-6659/85-003 License: SUA-551
- Docket
- 40-6659
Licensee: Petrotomics Company
P.O. Box 2509 .
Shirley Basin, Wyoming 82615
Facility: Shirley Basin Uranium Mill
Inspection At: Shirley Basin, Wyoming
! Inspection Conducted: July 30-August 1, 1985
Inspectors:
N. M. Shopenn, Team Leader
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G. R. Konwinski, Project Manager
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Date/
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Approved:
Harry J. Pettengill, Chief
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Licensing Branch 2
Uranium Recovery Field Office, Region IV
Inspection Summary
l Inspection Conducted on July 30-August 1, 1985, Report 40-6659/85-003
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l Areas Inspected: Special inspection of uranium decommissioning and
- radiation safety program including
- Management Organization and
. Controls / Operations Review; Operator Training and Retraining; Radiation
Protection; Radioactive Waste Management; and Transportation.of
Radioactive Materials.
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SUA-0551
851023
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The inspection involved a total of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> onsite by two NRC inspectors.
Results: Within the five areas inspected, five violations were
identified in three areas as described in this report.
DETAILS
1. Persons Contacted
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- *J. H. Whitman, Manager
- S. J. Pfaff, Radiation Safety Coordinator
- *J. H. Hines, Assistant Radiation Safety Coordinator
W. H. Schram, Wackenhut Security
R. L. Cook Jr. , Cooks Fabrication Inc.
G. Himes, Radiation Safety Technician
D. R. Tintinger, Mill Maintenance
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H. J. Cochran, Lead Operator
- Denotes those present at the exit interview.
Two mill workers and a security guard were interviewed during the
course of the inspection.
j 2. Licensee Action on Previous Inspection Findings
(Closed) Violation (40-6659/85-002) Failure of licensee to submit a
decommissioning plan 12 months prior to mill decommissioning. The
licensee was given verbal approval by NRC staff during a special
inspection on June 17 and 20, 1985, to proceed with decommissioning
l of the ore crushing, thickeners, grinding, and storage portions of
! the circuit in the absence of an NRC approved formalized plan in the
form of a license amendment. Contrary to such agreements, the
licensee has removed 9 of 13 leach tanks as evidenced during this
inspection. The staff issued full decommissioning approval on
July 29, 1985. Petrotomics' decommissioning is now in accordance
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with this approval.
! (Closed) Violation (40-6659/85-002). Failure of the licensee to
submit a plan and seek approval to dispose of contaminated materials
! in a mine pit. No additional disposal activities have taken place
since this violation was noted during the June 17-20, 1985,
inspection. Approval for such disposal was granted by Amendment
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No. 8 dated July 29, 1985.
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(Closed) Violation (40-6659/85-002). Failure of contract employees
to shower and/or monitor themselves, with an alpha instrument, prior
to leaving the mill. In addition to the previous violation, the
inspectors observed during this inspection that purchasers of
surplus property, who had access to contaminated areas of the mill
property, failed to monitor and/or shower before they left the
property. Therefore, the staff will closely review the area on
future inspections.
(Closed) Violation (40-6659/85-002). Failure of the licensee to
determine airborne concentrations of radioactivity. Records of
airborne radioactivity surveys were observed during this inspection.
They are now being properly conducted during each phase of
decommissioning.
3. Management Organization and Controls / Operations Review
The licensee described the organizational structure and specifically
the organization of the radiation safety staff. The radiation
safety staff consists of two personnel.
The mill had been permanently shut down prior to the time of the
inspection. Mill decoramissioning had begun with the crushing
circuit being the first area to undergo dismantling. Upon
completion of the crushing circuit, dismantling was initiated on
the leach and SX circuits. The NRC inspectors noted that
decommissioning of portions of the SX and leach circuits was
contrary to the license conditions in effect at the time the work
started and not in accordance with the verbal commitments agreed
upon by the licensee and the NRC during the previous inspection.
NRC final approval was granted July 29, 1985, after the
decommissioning of the SX and leach circuits was started. This was
identified as a violation of License Condition No. 29. The
inspectors did, however, determine that the licensee had issued
Radiation Work Permits for these activities. This is normally
adequate for the dismantling and removal of old equipment during
normal mill operation. The conditions at the time of the work were
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not normal mill activities, hence, prohibited under the license
conditions in force at that particular period of time.
There were 43 personnel directly employed by the licensee at the
time of the inspection. Additionally, 10 to 15 outside contractor
personnel were assisting in the mill decommissioning.
Exposure rate surveys throughout the mill were performed by the NRC
inspectors. The levels found were less than 2 mR/hr throughout the
mill. Soil samples were obtained similtaneously by the inspectors
and the licensee. The samples shall be used to verify that the mill
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area cleanup meets the conditions of License Condition No. 29 of the
amended license. These samples will be analyzed for U-238 and
Ra-226 and a comparison made with the licensee's results.
One violation was identified by the inspectors.
4. .0perator Training and Retraining
The inspectors reviewed records of contractor employee training
conducted by the radiation safety staff since the last inspection.
The NRC inspectors noted that all contract employees had received
training in basic radiation safety as well as respiratory
protection. All contract employees successfully completed a written
examination on the above topics. The inspectors found that the
training conformed to the requirements of License Condition No. 37.
The inspectors observed contract personnel performing alpha surveys
upon exiting the mill area. It was apparent, that upon exceeding '
the alpha meter alarm limit, not all contractor personnal clearly
understood the decontamination procedures. The inspectors expressed
concern over this situation and noted that some form of refresher
training may be advised.
No violations or deviations were identified by the inspectors.
5. Radiation Protection
a. Exposure Determination
Utilizing a computer code, the licensee determined internal
exposures for all Petrotomics employees to airborne radioactivity.
The code uses air sampling and personnel time card data as inputs.
The time card data determined occupancy of personnel. The 36 air
particulate sampling locations, which were previously used to
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determine employee exposures, were no longer used due to mill
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decommissioning. Concentrations of airborne radioactivity for each
mill area were determined by using lapel samplers attached to
laborers involved in the decommissioning. These concentrations were
weighted by the general occupancy time of the locations, as
determined from job descriptions accompanying time cards.
Because the mill was undergoing decommissioning, most of the work
being performed had no standard operating procedure. As a result,
most of the work was being performed under Radiation Work Permits
(RWPs). A review of the RWPs by the NPC inspectors noted that all
l necessary information to determine exposures was on file in the
i RSO's office. However, in some' cases the RWPs were issued more than
a day in advance of the job being performed. The inspectors noted
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to the licensee that this practice may not be advisable in that
conditions may change prior to initiation of the work. The
inspectors noted that the tracking of RWPs was not easily determined
and discussed this situation with the RSO and. suggested an
alternative method for tracking RWPs.
The inspectors noted that since June 1985, Petrotomics has not
analyzed nonroutine yellowcake and ore dust samples onsite. As a
result, the turnaround time for analysis of these samples was often
in excess of the two days (up to two weeks) specified in License
Condition No. 30 and therefore a violation of the same.
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One violation was identified by the inspectors.
b. Respiratory Protection
The inspectors reviewed the licensee's respiratory protection
program. Ali Petrotomics employees and contractor employees have
had training in the use of respiratory protection equipment, as
required by Section 5 of the renewal application.
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Since the previous inspection, respirators had been used by laborers
involved in mill decommissioning. However, protection factors had
not been utilized during exposure calculations. The respirators
were used during dusty conditions which primarily. represented glass
fibers from fiberglass insulation. The licensee had moved the
respirator equipment from the mill building (due to removal of the
roof from the office area) to a room which adjoins the cafeteria
building. The inspectors noted that respirators were being washed,
bagged, and dated as required by Section 5 of the renewal
application. However, these activities were taking place in a sink n
which was plumbed to the mill's septic system. Due to this,
i contaminated water was being discharged to an area outside of the
tailings impoundment. This was a violation of License Condition
No. 17.
A tour of the mill area found several used respirators discarded at
various work locations rather-than being returned to the R50 for
cleaning. It was obvious to the inspectors that the respirators had
been laying around for sometime. This is a violation of a
commitment made by the licensee in submittals made to the NRC and
incorporated in License Condition No. 48.
Two violations were identified by the inspectors.
, c. Bioassay
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The licensee's bioassay program consisted of urinalysis and in vivo
lung counting. The NRC inspectors reviewed the program with respect
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to the contractor personnel- and Petrotomics employees. The review
indicated that all contractor employees submit a sample at the
beginning of their shift. The results of the samples indicated that
no sample from any employee had reached the action limits specified
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in License Condition No. 41.
No violations or deviations were identified by the inspectors.
d. Personnel Contamination Control
, Contamination of personnel within the mill had been controlled
through the use of protective clothing, showering, and surveys.
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Petrotomics issues protective clothing of different colors for
personnel working in yellowcake and nonyellowcake areas of the mill.
The clothing is laundered on site and is stored in the mill change
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room. All employees are required to either shower or monitor
themselves prior to leaving the mill. The NRC inspectors compared
the log book maintained at the guard shack with the log book
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maintained at the alpha survey meter. The inspectors determined
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that a few purchasers of surplus property, who potentially had
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access to contaminated portions of the mill, did not shower or
perform alpha surveys prior to leaving the mill site. This is a
violation of License Condition No. 42. ,
(Theinspectorstestedthealphacontaminationsurveyinstrumentat
the exit to the mill that was used by mill personnel for self
surveys. The instrument was in calibration, and the alarm was
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observed to have been set to alarm below 1000 dpm/100 cm2,
One violation was identified by the inspectors.
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6. Radioactive Waste Management ,
j At the time of the inspection, no tailings were being disposed of in
! the tailings impoundment. An extensive misting system was observed
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to be operative. The NRC inspectors noted that catwalks and pump
stands from the 55 foot thickeners had been disposed of in the
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tailings impoundment as authorized by License Condition No. 46. The
inspectors also noted that contaminated materials from mill
decommissioning had been buried within the general mill site' area as
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agreed upon with the NRC and authorized by License Condition No. 29.
( Burials had been in excavated trenches. Upon observing the
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trenches, the inspectors noted that several barrels had not been ;
crushed and large structural steel had been end dumped into open l
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trenches resulting in potential void spaces. The inspectors i
indicated concern over this disposal method and noted that all
future disposals, especially any authorized within the tailings
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area, should assure against voids and its effect on the ultimate
reclamation cover.
No violations or deviations were identified by the inspectors.
7. Transportation of Radioactive Materials
The inspectors reviewed records of contamination surveys performed
on equipment prior to release from the site. The salvage records
indicated that all materials leaving the site were decontaminated
below the levels stated in Attachment No. 1 to SUA-551. The
licensee was therefore in compliance with License Condition No. 18.
The inspectors also reviewed records of transfer of contaminated ma-
terials and. equipment to other licensed uranium recovery facilities.
The transfer records for all shipments were maintained in the RS0's
office. Similarly, the transfer records indicated surveying,
placarding, and shipment in compliance with 10 CFR, Part 71.
The inspectors reviewed records of yellowcake shipments. All
records were found to be in order. All yellowcake had been shipped
from the mill.
No violations or deviatfor.s were identified by the inspectors.
8. Exit Interview
The NRC inspectors met with the licensee representatives at the
conclusion of the inspection on August 1, 1985. The inspectors
i summarized the purpose, scope, and findings of the inspection. All
apparent violations noted in the report were discussed at the exit
interview. Petrotomics concurred in the findings and either
corrected or proposed a correction to each violation prior to the
inspectors leaving the site.
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