ML20198B664

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Ack Receipt of Analysis Results for Background & Heap Leach Area Soil Samples Submitted for Unnamed Heap Leach Site. Results Indicate That Sufficient Activities of Byproduct Matl Remain on Old Heap Leach Pad to Warrant Addl Work
ML20198B664
Person / Time
Issue date: 09/24/1985
From: Rich Smith
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Roberts H
ENERGY FUELS NUCLEAR, INC.
References
REF-WM-186, TASK-TF, TASK-URFO NUDOCS 9801070028
Download: ML20198B664 (2)


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BBrown, RW URF0:GRK URP WM-186 040WM186101E Mr. Harold Roberts Energy Fuels Corporation Three Park Central, Suite 900-1515 Arapahoe Denver, CO 80202

Dear Mr. Roberts:

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We are in receipt of the analysis results for the background and heap leach area soil samples you submitted for the unnamed heap leach site.

The results indicate that sufficient activities of byproduct materials remain on the old heap leach pad to warrant additional reclamation work.

Two potential options may possibly be exercised for this site:

1.

EFN could commit to the removal of the residual byproduct materials for disposal at an approved site.

In this case, EFN should propose a dispcsal site for the contaminate 6 ; oils.

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Verification 6 site decontamination down to 5 pCi/g averaged over the first 15 centimeters as well as 15 pCi/g averaged over lower layers will be required.

Additionally, a final radiological survey with supporting soil samples would be required to ve.ify that cleanup in accordance to 40 CFR 192, 6192.32 closure standards, had been achieved.

mV 2.

EFN coulo propose to reclaim the residual byproduct materials in place.

Should this option be chosen, closure under 40_CFR 192, 6192.32 performance standards which state that radiological hazards shall be controlled _for 1000 yee rt to the extent achievable, and in any case for at least 200 years, and that releases of Radon-222 to the atmosphere, are limited to an average release rate of 20 pCi/m's, would be required.

Additionally, you should characterize the quantities of

-byproduct materials and discuss whether transfer of title, and long-term monitoring and maintenance of the site is warranted as specified under Criteria 10 and 11 of Appendix A to 10 CFR

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.2-Part 40 and Section 83 of the Atomic Energy Act of 1954, as amended.

Please review the cleanup options and' submit a plan to the Uranium Recovery Field Office for review and approval. The plan should include a discussion of the preferred reclamation alternative as well as a schedule for completion in calendar year 1985

- Should your office desire any assistance in further discussion of these alternatives, please contact Gary Konwinski of my staff.

R. Dale Smith, Director O

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