ML20207A835

Informs of Completion of Review of 980616 & 990408 Submittals Re Proposed Termination of Radioactive Matl License L02704 Issued to Uri,Inc.Concurs That All Stds & Requirements for Health & Safety Met

ML20207A835
Person / Time
Issue date:	05/13/1999
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Ratliff R TEXAS, STATE OF
References
NUDOCS 9905270328
Download: ML20207A835 (12)

Text

Mr. Rich rd A. Ritliff, P.E., Chief Burru of Ridi1 tion Control Texas Departm:nt of Herith gg ;3 gg 1100 West 49th Street

' Austin, Texas 78756-3189

Dear Mr. Ratliff:

We have completed our review of your June 16,1998 and Apri 8,1999 submittals regarding I

the proposed termination of the Radioactive Material License No. LO2704 issued to URI, Inc.,

an in-situ leach uranium recovery facility located near Bruni, Texas.

Closure'of an in-situ leach uranium recovery site requires a demonstration that the groundwater has been adequately restored, all the wells have been closed and plugged according to the appropriate Texas statute, disposal or transfer of radioactive material is documented, and radiation surveys and confirmatory soil samples indicate that the site meets unrestricted release requirements.

]

The information you have submitted indicates that the groundwater has been restored by the licensee to the satisfaction of the Texas Water Commission (TRC). All the wells have been plugged and abandoned by the licensee as authorized by the Texas Natural Resource

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Conservation Commission (TNRCC). Based on the Texas Department of Health's (TDH) review of the license termination, you reported that proper disposition of radioactive materials took place at the site and there has been no on-site disposal of radioactive materials; therefore, there is no need to transfer ownership of land to the State or the Federal Government.

TDH has reviewed the results of radiation surveys submitted by the licensee and performed

. confirmatory surveys for the subject site. Post-cleanup surveys conducted by TDH indicate that the site has been decontaminated to'a radiation level that meets the State criteria. ' According to the TDH report, the analysis of soil samples indicates that average radium-226 and uranium concentrations were below release criteria of 5 pCi/g and 30 pCl/g, respectively. The i

statements made in the June 16,1998 and April 8,1999 submittals indicate that the TDH has

~ dequately determined that all license obligations have been met by the licensee.

a i

The most recent review of the Texas Ag eement State Program, conducted under the Integrated Materials Performance Eval',ation Program (IMPEP) in June 1997, indicates that the

- Texas program is adequate to proter'. public health and safety, and compatible with NRC's program. This finding is conskient with the previous Texas program evaluations. Based on our

. review of the above information and in ~accordance with 10 CFR 150.15a(a), we concur that all applicable standards and requirements for the protection of the public health, safety and the environment have been met for the termination of the Radioactive Material License No. LO2704.

If we can be of further assistance in this regard, please contact me or Kevin Hsueh at (301) 415-2598.

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,y Sincerely, f Chirspigrwd Dir:

p;pO CW G ["[h a

ly g u L t M M U 6 scLiJ k A Paul H. Lohaus, Director Office of State Programs Distribution:

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DSollenberger DCD (SP08 )

PDR (YES_f_ NO

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SDroggitis -

JMyers/ASPO -

Texas File DOCUMENT NAME: G:\\KPH\\RATRURI.WPD

• See previous concurrence.

70 steelve o ese r of thle sleeumont. inlitecte in the boa: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N"is No copy OFFICE OSP l

NMSS l

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OSP:D l

NAME KHsuch:kk -

CPaperiello SATreby PHLohaus DATE 04/28/99*

05/11/99*

05/06/99*

04/28/99*

I 9905270328 990513 OSP FILE CODE: SP-AG-27 PDR STPRO ESOTXPM i

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UNITED STATES E) j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565-0001 g%n May 13, 1999 Mr. Richard A. Ratliff, P.E., Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, Texas 78756-3189

Dear Mr. Ratliff:

We have completed our review of your June 16,1998 and April 8,1999 submittats regarding the proposed termination of the Radioactive Material License No. LO2704 issued to URI, Inc.,

an in-situ leach uranium recovery facility located near Bruni, Texas.

Closure of an in-situ leach uranium recovery site requires a demonstration that the groundwater has been adequately restored, all the wells have been closed and plugged according to the appropriate Texas statute, disposal or transfer of radioactive material is documented, and radiation surveys and confirmatory soil samples indicate that the site meets unrestricted release requirements.

The information you have submitted indicates th'at the groundwater has been restored by the licensee to the satisfaction of the Texas Water Commission (TRC). All the wells have been plugged and abandoned by the licensee as authorized by the Texas Natural Resource Conservation Commission (TNRCC). Based on the Texas Department of Health's (TDH) review of the license termination, you reported that proper disposition of radioactive materials took place at the site and there has been no on-site disposal of radioactive materials; therefore, there is no need to transfer ownership of land to the State or the Federal Government.

TDH has reviewed the results of radiation surveys submitted by the licensee and performed confirmatory surveys for the subject site. Post-cleanup surveys conducted by TDH indicate that the site has been decentaminated to a radiation level that meets the State criteria. According to the TDH report, the analysis of soil samples indicates that average radium-226 and uranium concentrations were below release criteria of 5 pCi/g and 30 pCi/g, respectively. The statements made in the June 16,1998 and April 8,1999 submittals indicate that the TDH has adequately determined that alllicense obligations have been met by the licensee.

The most recent review of the Texas Agreement State Program, conducted under the integrated Materials Performance Evaluation Program (IMPEP) in June 1997, indicates that the Texas program is adequate to protect public health and safety, and compatible with NRC's program. This finding is consistent with the previous Texas program evaluations. Based on our review of the above information and in accordance with 10 CFR 150.15a(a), we concur that all applicable standards and requirements for the protection of the public health, safety and the environment have been met for the termination of the Radioactive Material License No. LO2704.

If we can be of further assistance in this regard, please contact me or Kevin Hsuch at (301) 415-2598.

' erely, sa e

Paul H. Lohaus, Director Office of State Programs

E" Mr. Rich;rd 'A Ritliff, P.E., Chi;f j

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Bureau of R;diation Control -

Texas Depirtmtnt of Hstith -

'1100 West 49th Str ct -

.c Austin, Texas 78756-3189

Dear Mr. Ratliff:

We have completed our review of your June 16,1998 and Apr' 8,1999 submittals regarding the proposed termination of the Radioactive Material License

o. LO2704 issued to URl, Inc.,

. an in-situ leach uranium recovery facility located near Bruni, xas.

Closure of an in-situ leach uranium recovery site requires a emonstration that the groundwater has been adequately restored, all the wells have been close and plugged according to the appropriate Texas statute, disposal or transfer of radioactiv material is documented, and radiation surveys and confirmatory soil samples indicate th t the site meets unrestricted release

. requirements.

The information you haye submitted indicates that the gr ndwater has been restored by the licensee to the satisfaction of the Texas Water Commissi n (TRC). All the wells have been.

plugged and abandoned by the licensee as authorized b the Texas Natural Resource Conservation Commission (TNRCC). Based on the Tex s Department of Health's (TDH) review of the license termination, you reported that pro r disposition of radioactive materials took place at the site and there has been no on-site di sal of radioactive materials; therefore, there is no need to transfer ownership of land to the St te or the Federal Government.

TDH has reviewed the results of radiation surveys su itted by the licensee and performed confirmatory surveys for the subject site. Post-clean surveys conducted by TDH indicate that the site has been decontaminated to a radiation leve that meets the State criteria. According to the TDH report, the analysis of soil samples indicat s that average radium-226 and uranium -

concentrations were below release criteria of 5 pCi/ and 30 pCi/g, respectively. The adequately determined that all license obligations /1999 submittals indicate that the statements made in the June 16,1998 and April 8, ve been met by the licensee.

1The most recent review of the Texas Agreement ate Program, conducted under the Integrated Materials Performance Evaluation Pro ram (IMPEP) in June 1997, indicates that the.

Texas program is adequate to protect public hea h and safety, and compatible with NRC's program. This finding is consistent with the prev us Texas program evaluations. Based on our review of the above information and in accorda e with 10 CFR 150.15a(a), we concur that all applicable standards and requirements for the otection of the public health, safety and the environment have been met for the termination of the Radioactive Material License No. LO2704.

if we can be of further assistance in this regar, please contact me or Kevin Hsueh at I

-(301) 415-2598.

Sincerely,

[

Paul H. Lohaus, Director Office of State Programs

DIR RF.

DSollenberger DCD (SP08 - ) ~

SDroggitis -

JMyers/ASPO PDR (YES f_. NO

)

Texas File i

DOCUMENT NAME: G:\\KPH\\RATRURI.WPD

• See previous concurrence.

' T' veoeive e cop r of thle docupient,indicato in the teos: "C" = Copy attachrnent/ enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE

=OSP-

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NAME-KHsush:kk '

CPapehelhi - /

SATreby PHLohaus DATE

= 04/28/99*-

05A\\ /9#

05/06/99*

04/28/99*

OSP FILE CODE: SP-AG-27 J

Mr. Richtrd A. Ritliff, P.E., Chilf Burnu of Ridi: tion Control Taxis D ptrtm:nt of Hacith 1100 West 49th Street Austin, Texas 78756-3189

Dear Mr. Ratliff:

We have completed our review of your June 16,199 and April 8,1999 submittals regarding the proposed termination of the Radioactive Material icense No. LO2704 issued to URI, Inc.,

an in-situ leach uranium recovery facility located near runi, Texas.

Closure of an in-situ leach uranium recovery site requi es a demonstration that the groundwater has been adequately restored, all the wells have been losed and plugged according to the appropriate Texas statute, disposal or transfer of radio etive material is documented, and radiation survey and confirmatory soil samples indicate hat the site meets unrestricted release requirements.

The information you have submitted indicates that the groundwater has been restored by the licensee to the satisfaction of the Texas Water Commission (TRC). All the wells have been plugged and abandoned by the licensee as authorized bfthe Texas Natural Resource Conservation Commission (TNRCC). Based on the Texas Department of Health's (TDH) took place at the site and there has been no on-site dispos (disposition of rad review of the license termination, you reported that proper al of radioactive materials; therefore, there is no need to transfer ownership of land to the State r the Federal Government.

TDH has reviewed the results of radiation surveys submitted by the licensee and performed confirmatory surveys for the subject site. Post-cleanup surveys conducted by TDH indicate that no elevated radiation level was found on site. According to the TDH report, the analysis of soil samples indicates that average radium-226 and uranium coricentrations were below release criteria of 5 pCi/g and 30 pCl/g, respectively. The statements made in the June 16,1998 and April 8,1999 submittals indicate that the TDH has adequatel determined that all license obligations have been met by the licensee.

The most recent review of the Texas Agreement State Program, conducted under the Integrated Materials Performance Evaluation Program (IMPEP) in June,1997, indicates that the Texas program is adequate to protect public health and safety, and compatible with NRC's program. This finding is consistent with the previous Texas program evaluations. Based on our review of the above information and in accordance with 10 CFR 150.15a(a), we concur that all applicable standards and requirements have been met for the tdrmination of the Radioactive Material License No. LO2704.

If we can be of further assistance in th regard, please contact me or Kevin Hsueh at (301) 415 2598.

f b

g/0l Sincerely, I '/1. A Paul H. Lohaus, Director a/

/ Office of State frograms j

Distribution:

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DIR RF DSollenberger DCD (SP08 )

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PDR (YES_f_ NO SDroggitis JMyers/ASPO Np %,w Q s) t[#/

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DOCUMENT NAME: G:\\KPH\\RATRURI.WPD 6

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' 04/23/99 04/ /99 04/ /. /99 i04/ 2/99

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OSP FILE CODE

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. Mr. Richard A. Ritliff, P.E., Chi f l

Burmu of Radiation Control -

Texts Departm:nt of Harith 1100 Wrst 49th Str ct Austin, Texas 78756-3189 l

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Dear Mr.' Ratliff:

i We have completed our review of your June 16,1998_and April 8,1999 submittals regarding the proposed termination of the Radioactive Material License No. LO2704 issued to URI, Inc.,

an in-situ leach uranium recovery facility located near Briuni, Texas.

~/-

Closure of an in-situ leach uranium recovery site requires a demonstration that the groundwater has been adequately restored, all the wells have been closed and plugged according to the appropriate Texas statute, disposal or transfer of radioactive material is documented, and radiation survey and confirmatory soil samples indicate that the site meets unrestricted release requirements.

~

The information you have submitted indicates that the groundwater has been restored by the licensee to the satisfaction of the Texas Water Commission (TRC). All the wells have been plugged and abandoned by the licensee as authorized by the Texas Natural Resource Conservation Commission (TNRCC). Based on thejTexas Department of Health's (TDH) review of the license termination, you reported that proper disposition of radioactive materials took place at the site and there has been no on-site disposal of radioactive materials; therefore, there is no need to transfer ownership of land to the State or the Federal Government, TDH has reviewed the results of radiation surveys,b submitted by the licensee and performed confirmatory surveys for the subject site. Post-cleanup surveys conducted by TDH indicate that no elevated radiation level was found on site. Acprding to the TDH report, the analysis of soil samples indicates that average radium-226 and uranium concentrations were below release criteria of 5 pCi/g and 30 pCi/g, respectively.~ The statements made in the June 16,1998 and April 8,1999 submittals indicate that the TDH has adequately determined that all license obligations have been met by the licensee.

/

I The most recent review of the Texas Agreement State Program, conducted under the Integrated Materials Performance Evaluation Program (IMPEP) in June,1997, indicates that the Texas program is adequate to protect pubpc health and safety, and compatible with NRC's program. This finding is consistent with the previous Texas program evaluations. Based on our review of the above information and in accordance with 10 CFR 150.15a(a), we concur that all applicable standards and requirements have peen met for the termination of the Radioactive Material License No. LO2704.

If we can be of further assistance in this regard, please contact me or Kevin Hsueh at

-(301) 415-2598.

Sincerely, Paul H. Lohaus, Director Office of State Programs Distribution:

DlR RF DSollenberger DCD (SP08 )

SDroggitis JMyers/ASPO PDR (YESJ NO

)

. Texas File DOCUMENT NAME: G:\\KPH\\RATRURI.WPD vw

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SATreby PHLohaissT")

1 DATE 04/2f/99 04/ /99 04/ /99 04/ 8 /99 OSP FILE CODE: SP-AG-27

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Termination of Uranium Licenses in Agreement States Reviewer Guidance Licensee: URI, Inc.

Licensee No.: LO2704 Location: Bruni, Texas Area: approximately 952 acres Type of License: Non-conventional (in-situ leach) uranium mill license Full / Partial License Termination: Full license termination The following items were reviewed based on the OSP procedure SA-900 " Termination of Uranium Mill Licenses in Agreement States."

1.

A brief description of licensee's activities associated with license termination.

i Comment:

This information is provided in the TDH letter dated June 16,1998. In addition, I had a phone conversation with Eugene Forrer in TDH on April 27 regarding the total area of the subject site being terminated. He provided the following information:

Benaviks Project:

229.6, acres Longoria Project:

722.7 acres Based on the above information, a total area of 952 acres was documented 2.

Groundwater information which demonstrates that the groundwater has been adequately restored to meet the State restoration criteria.

1 Comment:

This information is provided in the Texas Water Commission (TRC) letters dated February 10,1988, May 16,1991, June 5,1989, October 31,1986 and February 11,'1988 (two letters).

]

I 3.

Documentation that the production, injection, and monitoring wells have been closed and plugged in accordance with the State criteria. Such documentation could be a copy of correspondence from the State to the licensee which confirms that all wells have been clot.ed and plugged in accordance with the State criteria or a statement from the

' appropriate State regulatory agency to that effect.

Comment:

This 'information is provided in the Texas Natural Resource Conservation Commission (TNRCC) inspection reports dated August 20,1998 and l-November 18,1998.

1

a l

4.'

Decommissioning information which documents that all contaminated materials have been removed from site.

Comment:

This information is provided in the TDH letter dated June 16,1998, and also in the licensee letter dated April 13,1993.

5.

Discussion of results of radiation survey and confirmatory soil samples which indicates that the subject site meets unrestricted release requirements.

Comment:

This information is provided in the TDH letter dated June 16,1998 and in four TDH memos.. Two of the memos were dated March 13,1998; the other two were dated August 30,1994 and August 23,1994, respectively.

6.

Discussion of results of the State's site closure inspection.

j Comment:

This information is provided in the four TDH memos mentioned in item 5.

7.

IMPEP review of the Texas uranium recovery regulatory program Comment:

Based on 1997 IMPEP review, the Texas uranium recovery regulatory program was found satisfactory with recommendations for improvement.

After reviewing the above information, the reviewer recommends that we concur in the State's determination and in accordance with 10 CFR 150.15a(a) have determined that all applicable standards have been met for the termination of the Radioactive Material License No. LO2704.

l 4/27[ff Reviewer:

$1rf[o A

Date:

' Kevin Hsueh' l

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Texas Department of Health William R. Archer III, M.D.

1100 West 49th Street Patti J. Patterson. M.D., M.P.H.

Comnussioner Austin. Texas 78756-3189 Executive Deputy Commissioner (512) 458-7111 Radiation Control (512) 834-6688 June 16,1998 0

h United States Nuclear Regulatory Commission M7 ATTN: Richard Bangart, Director A

Office of State Programs 2

'J i

Mail Stop 03H2O Washington, D.C.

20555 T-a"

Dear Mr. Bar.gart:

gy The Texas Department of Health (TDH)URI, Inc., located near Bruni, Texas.has received Material License No. LO2704, issued to This site was operated from 1979 to 1989 when production operations were ceased. The license authorized iz1 siig leach mining and processing.

From 1984 until 1991 groundwater restoration was performed along with limited surface reclamation. The Texas water Commission authorized ceasing groundwater restoration and final plugging of all injection, production, and monitoring welfs m May 1991 Enclosure 1).

Followmg plugging of all wells, full scale surface reclamation and decommiss(ioning bega During surface reclamation and decommissioning all material and equipment was surveyed for radioactive contamination. Any material and/or ecui disposed of by utilizing one of the following method.s:pment which was contaminated was transfer to another licensed mine site;

&4 decontamination and release for unrestricted use; or disposal at a licensed byproduct disposal facility.

Proper disposal of all material and/or equipment was documented by the licensee.

Surveys to confirm the effectiveness of reclamation and decommissioning activities were perforraed by direct and/or swipe surveys of equipment and structures to be turned over to the landowner, direct survey orland by walking 2 meters apart moving across the wellfield pattern and/or defining a ten meter by ten meter area around hot spots and taking five samples from the area. The licensee subsequently requested termination of their license (Enclosure 2).

Reclamation and decommissioning activities were completed in 1997.

Q 09aWC W N @'

.7 Richard Ba_nprt June 16,1995 Page 2 g

Tn August 19CTDH personnel performed confumatory surveys of the facility. Tiie surveys were performed using one-by-one sodium iodide probes and Ludlum 14C survey meters. Two dmes background was used as an allowable limit (Regulatory Guide 5.10, Guidelines for Conducting Close Out Surveys of Open Lands and Requestmg Release for Unrestricted Use). The survey was performed by walking 10 meters apart movinJ across the wellfield pauern. Background readings were approxunately 1000 cpm on al meters except one which had ba,ckground readings of approxunately 1500 cpm. As a result of the surveys, six areas were xlentified as havmbrearmNseater than 9 500 cpm. These areas were decontaminated

'or to sampling.

area readings slightly greater than twice background. Five es were takenTrom a 100 square meter area around all seven areas.

Samples were also from all former pond areas. Analysis of all samples indicated that average radium and uranium ccvntrations were below the release criteria of 5 pCi/g and 30 pCi/g, respectively.

In January 1998, located at the site.TDH personnel performed confirmatory surveys of the creek concrete blocks One concrete block at the edge of " Pond B" had elevated radiation readings.

The block was transported to Rosita Project for i

decontamination and releaseTor unrestricted use. No other readings above background were detected.

In January 1998 TDH personnel also performed confirmatory The area was f'ound to have elevated radium-226 levels durm, surveys of a discharge area.

g the survey and samplmg accomplished in August 1993. A survey of the discharge area indicated no readings above background. A sod sample was taken and results were within regulatory limits.

The discharge area is not part of the licensed area.

On-site disposal of solid radioactive material or byproduct material was not authorized at this facility, thus there is no land to be transferred to the State of Texas or the Federal Government.

As a result of these findings,l is kept on file,g to terminate this license (Enclosure 3). A we are proposin data supporting our proposa and available, at TDH should it be necessary for reference at a future date. Please advise if the U.S. Nuclear Regulatory Commission wishes additional material or information in order to make a determinauon regarding concurrence with our proposal to terminate this license.

If additional information is required, please contact Mr. Eugene Forrer of my staff.

Your expeditious processing of this request is appreciated.

Sincerely, ichard A. Ratliff,

.E, Chief Bureau of Radiatio C 1

Enclosures

.p.u e

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l l

l Enclosure 1

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TE,,.e5 WATER COMMISSION

,,p.

J. D. Head, General Cournal Paul Hopkins, Chairman MichaelE. Field, Chief Exammer John O.Houchins,Commasoner Karen A.PhEhes, Chief Clerk B.J.Wynne RI,Commasoner Allen Beinks. Executive Drector February 10,'1988

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Mr. Mark S. Felissa Environmental Manager Urani a Resources Inc.

12377 Merit Drive Suite 750, L314 Dallas, Texas 75251 Restoration Determination of Production Area No. 1 of the Senavides Mine Re:

Site, Permit No. UR02312-011 Dear Mr. Felissa I

1 The Texas Water Consission has received the restoration data for Production Area A review of the data indientes that Production Ns.1 of the Benavides Mine Site.

Are's No. I has been restored in accordance with the spie'1Tications contained in as required by 31 TAC section 333.107. Your are hereby pe'rtit number UR02312-011 cuthorized to cease any restoration activities, including monitoring, at Production Area No. 1.

Within 120 days of receipt of this letter closure of the we11 field shall be accorplished in accordance with the approved plugging and abandonment plans for this Production Area. Any modifications to the plugging and abandonnent procedure must be approved in writing by the Commission.

Please notify the Commission prior to coseencing plugging activities to provide the opportunity for TVC personnel to be present. If you have any questions please contact Dale P. Kohler of the In Situ Uranium Mining Unit at (512) 463-8278.

81meerely, I rry =D. 2ru$.

ett Director, Water Rights & Uses Division DK jt se TVC District 11 Office - Weslaco Mr. David Locker - Texas Department of Realth Bureau of Radiation Control e Area Code 512 463 7630 P.O.Som 13087 Capnot $tstion

• 1700 North Conyees Ave. e Austm.Tenas 787213087

aErAS WATER COMMISSivN y,',.. A J. Wynne. M. Chairman t

[

John J. Vay. General Counsel John E. Birdwou. C-.. 2 r s

• %'* 0 :(

Michael E. Field Chief Hearings E aminer C11ff Johnson C-...! '=s Gloria A. Vasquez, Chief Clerk Allen Beinks. Executive Director May 16, 1991 WM g/

Mr. Mark Pelizza pd URI, Inc.

12377 Merit Drive Suite 750, LB14 Dallas, Texas 75251 Re:

Restoration Determination of Production Area No. 2 of the Benavides Mine Site, Permit No. UR02312-021

Dear Mr. Pelizza:

The Texas Water Commission has received the restoration data for Production Area No. 2 of the Benavides Mine Site.

A review of the data indicates that Production Area No. 2 has been restored in accordance with the specifications contained in permit number UR02312-021 as required by 31 TAC Section 331.107.

Your are hereby authorized to cease any restoration activities, including monitoring, at Production Area No. 2.

Within 120 days of receipt of this letter closure of the wellfield shall be accomplished in accordance with the approved plugging and abandonment plans for this Production Area.

Any modifications to the plugging and abandonment procedures must be approved in writing by the Commission.

Please notify the Commission prior to commencing plugging activities to provide the opportunity for TWC personnel to be 1

present.

If you have any questions please contact Dale P. Kohler of the Ground Water Section at 512/371-6322.

Sincerely, h

Ha/;

.i UE'. b.r.

rry D. Pruett, P.E.

URL DA1.t_&S Director, Water Rights & Uses Division tiAY 171991 EDP/DPK/km 9

I i

I cc:

TWC District Office ill = Weslaco ggggy3J l

1 David Lacker - Texas Department of Healtf Bureau of Radiation Control P. O. Box 13087 Capuol Stauone 1700 North Congress Ave.* Austin, Texas 787113087* Area Code f12/463 7830 nn amam.cmwu

TE

• .S WATER COMMISSIOI.

j f

se I

h Allen O*in!'e.Emecutw Direnor B.J.Wynne DI. Chairman Paul Hopkins, Commissoner i.

Mice.-l r". '~ield, Generet Coumel f.~ 4 '

Bre+h ?/. 'oster, Ch.ef Clerk John O.Houchins, Commesioner June 5, 1989 gfI e9 gLP Mr. Mark S. Pelizza Environmental Manager Uranium Resources, inc.

12377 Merit Drive Suite 750, LB14 Dallas, Texas 75251 Re: Restoration Determination of Production Area No. 3 of the Benavides Mine Site, Permit No. UR02312-031

Dear Mr. Pelizza:

The Texas Water Commission has received the restoration data for Production Area No. 3 of the Benavides Mine Site. A review of the data indicates that Production Area No. 3 has been restored in accordance with the specifications contained in permit number UR02312-031 as required by 31 TAC Section 331.107.

You are hereby aut,horized to cease any' restoration activities, including monitoring, at Production Area No. 3.

Within 120 days of receipt of this letter closure of the we11 field shall be acpomplished in accordance with the approved plugging and abandonment plans for this Production Area. Any modifications to the plugging and abandonment procedure must be approved in writing by the Commission.

Please notify the Commission prior to commencing plugging activities to provide the opportunity for TWC personnel to be present.

If you have any questions please contact Dale P. Kohler of the In Situ Uranium Mining Unit at (512) 463-8278.

Sincerely, A_

s e

Harry D. Pruett Director, Water Rights & Uses Division l

DPK:aa ec: TWC District 11 Dffice - Weslaco E. EC-Mr. David Lacker - Texas Department of Health W DAllAI j

Bureau of Radiation Control hJUN 9 19B9 imeeovF j

l P. O Bos 13087 Captot staton

• 1700 North Conress Aw.

• Austm. Tem 787113067

• Area Cr& b12 4t3 7630 l

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• 4 aMS WATER COMMISSava.

<,Y Larry R. Soward, Executive Director C.Y.p?

Paul M ;' ' = Chairman Ralph Romins C....

=4r Mary Ann Hefner, Chief Clerk John O. Houchins, C-...

=4r hi.y,'.-

James K. Rourke Jr., General Counsel October 31, 1986 gen 6e h...fhi Mr. Mark 5. Pelizza Environmental Manager g

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Uranium Resources, Inc.

Suite 735. Promenade Bank Tower 1600 Promenade Center i

Richardson, Texas 75080 Re:

Restoration determination, Uranium Resources. Inc., Benavides Mine Site, Permit No. UR02312-041 Duval County

Dear Mr. Pelizza:

The Texas Water Commission has received the three consecutive sampling sets as required by 31 TAC Section 331.107.

A review of the restoration data indicates that Production Area No. 4 at the Benavides Mine Site has been restored in accordance with the specifications contained in permit number UR02312-041 and as required by 31 TAC Section 331.107.

You are hereby authorized to cease any restoration activities including monitoring at this production area.

Within 320 days of receipt of this letter, closure of the we11 field shall be accomplished in accordance with the approved plugging and abandonment plans submitted as part of the permit application.

Any codification to plugging and abandonment plans must be approved in writing by the Commission.

Please notify the Commission prior to conducting plugging activities.

If you have any questions, please call Mr. Dale Kohler of the Commission's Ground Water Conservation Section at (512) 463-8278.

Sincerely, Larry R. Soward Executive Director cc:

TWC District 11. Weslaco Mr. David Lacker, Chief. Bureau of Radiation Control.

Texas Department of Health P.o.noxisos7 cenisation

• Ausan.Temm7s7n e Ar codeswen7s,s

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TL.'AS WATER COMMISSIO? )

b,....ll J. D. Head. General Counsel Paul Hopkins.Channan e

k......;

MichaelEField Chief Enemmer JohnO.Houchins Commasoner

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B. J. Wynne. Bl. C... -

Maren A.Phithys. Chief Clerk Allen Beinke.Emecutive Dweesor February 11, 1988 h[.

l FECI6t':.

Mr. Mark S. Pelizza Environmental Manager Prenium Resources. Inc.

12377 Merit Drive Suite 750,1.314 Dallas, Texas 75251 Ret Restoration Determination of Production Area No.1 of the Longoria Mine Site.

Permit No. UR02222-011

Dear Mr. Pelissa:

The Texas Vater Commission has received the restoration data for Production Area No.- 1 of the Longoria Mine Site. A review of the data indicates that Production Area No. I has been restored in accordance with the specifications contained in permit number UR02222-011 as required by 31 TAC Section 331.107. Your are hereby authorized to cease any restoration activities, including monitoring, at Production Area No. 1.

Within 120 days of receipt of this letter closure of the wellfield shall be cecesplished in accordance with the approved plugging and abandonment plans for this Production Area. Any modifications to the plugging and abandonnent procedure must be approved in writing by the Connission.

Please notify the Commission prior to cessencing plugging activities to provide the opportunity for TWC personnel to be present. If you have any questions please contact Dale P. Kohler of the In Situ Uranium Mining Unit at (512) 463-8278.

Sincerely.

Y-_ $

i tr'y W Pruett Director, Water Rights & Uses Division DK:jt i

ect TWC Dist II Office - Weslaco Mr. David Lacker - Texas Department of Health Sureau of Radiation Control i

p.O. goa 13087 Capnot $istion

• 1700 Nonh Conyeu Ave.

• Austm. Team 78713 3087

• Area Code 512 407810

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TE AS WATER COMMISSION )

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J.D. Hand, Genera 1 Counsel Pau1 Hopkins, Chairman h,..., i' Michael E. Field, Chief Examiner John O. Hoochins, C era;'

=.n B.J.Wynne.Bl. Commissioner Karen A.Phillips, Chief Clerk Allen Beinke,Emeeviive Drector February 11. 1988 Mr. Mark S. Pelissa Environmental Manager Uranium Resources. Inc.

12377 Merit Drive Suite 750.1314 Dallas. Texas 75251 Re: Restoration Determination of Production Area No. 2 of the Longoria Mine Site.

Permit No. UR02222-021

Dear Mr. Pelissa:

The Texas Water Commission has received the restoration data for Production Area No.

l 2 of the Longoria Mine Site. A review of the data indicates that Production Area No. 2 has been restored in accordance with the specifications contained in permit number UkO2222-021 as iequired by 31 TAC Section 331.107. Tour are hereby l

cuthorized to cease any restoration activities including monitoring at Production Area No. 2.

l Vi hin 120 days of receipt of this letter closure of the wellfield shall be occomplished in accordance with the approved plugging and abandonnent plans for this Production Area. Any modifications to the plugging and abandonssent procedure cust be approved in writing by the Cossaission.

i i

Please notify the Co mission prior to commencing plugging activities to provide the opportunity for TWC personnel to be present. If you have any questions l

please contact Dale P. Rohler of the in situ Uranium Mining Unit at (512) 463-8278.

Sincerely.

end Ilarry D A rnett l

Director. Water Rights & Uses Division DKtj t cc TWC Dist il Office - Weslaco Mr. David Lacker - Texas Department of Nealth Sureau of Radiation Control l'

P.O Boa 13087 Capnol54 sten e 1700 Nonh Conyens Ave.

• Austm Tenas 787113067

• Area Code 512,463 7830 l

l 1

l 331.101-331.107 Subchapter F Standards for Class III Well Production Area Development 55331.101-331.107 These new sections are adopted under the authority of Texas Water Code, 555.103, and 27.019, which provide the Texas Water commission with the authority to adopt rules reasonably required for the performance of its powers and duties under the Texas Water Code and other laws of the state.

.5331.101. Applicability.

This subchapter establishes addi-tional standards for Class III well injection activities regarding the development of production or other areas authorized by an area permit and/or production area authorization.

5331.102.

Confinement of Mining solution.

Mining solutions shall be confined to the production zone within the area of des-ignated production zone monitor walls.

5331.103.

Production Area Monitor Wells.

i (a)

Production zone monitoring.

Designated Production Zone Monitor Wells shall be spaced no greater than 400 feet j

from the production area and no greater than 400 feet between the walls.

The angle formed by lines drawn from any production well to the two nearest monitor wells will not be greater than 75*.

Changes or adjustments in designated production zone monitor well locations may be authorized by the executive director so as to assure adequate containment.

These walls shall be subject to the sampling, corrective action, and reporting require-ments in 5331.105 of this title (relating to Monitoring 1

Standards) and 5331.106 of this title (relating to Remedial Action for Excursion).

(b)

Nonproduction zone monitoring.

At a minimum, designated non-production zone monitor walls shall be completed in the production area in any freshwater aquifer overlying the production zone.

These wells shall be located not more than 50 feet on either side of a line through the center of the production area with a minimum of one per every four acres of production area for wells completed in the first overlying freshwater aquifer and one per every eight acres for wells completed in any additional

~

overlying freshwater aquifers.

Changes or adjustments in designated non-production zone monitor well locations may be authorized by the executive director so as to assure adequate containment.

Those wells completed in the first overlying freshwater aquifer shall be subject to sampling, remedial action, and reporting requirements of 5331.105 of this title (relating to Monitoring standards) and 5331.106 of this title (relating to Remedial Action 1

331.101-331.107 for Excursion).

Monitor wells completed in any addition-al overlying freshwater aquifers shall be subject to monitoring,. remedial action, and reporting requirements specified in the permit.

5331.104.

Establishment of Baseline and Restoration Values.

(a)

One or more water samples shall be collected from each designated monitor well (Production and Non-Production Zone) and each designated production well in the permit or production area.

These samples will be analyzed and the results for each well submitted and summarized on forms provided by the executive director as follows:

(1) mine area baseline - The averages and ranges of the parameter values determined for the designated production zone monitor wells; (2) production area baseline - The averages and ranges of the parameter values determined from at least five designated production zone walls in the produc-tion area; and, (3) nonproduction zone baseline - The averages and ranges by zone of the parameter values determined for designated nonproduction zone monitor walls.

(b)

All samples shall be collected, preserved, analyzed, and controlled according to accepted methods as stated in the permit.

(c)

The baseline water quality values for a permit or produc-i tion area shall be ured to determine control parameter upper limits.

(d)

The baseline water quality values for a permit or produc~

tien area shall be used to determine restoration table values.

Each production area authorization shall contain a restoration table.

The table may be developed by using either:

(1) the higher value in either the column headed "Mine Area Average" or the column headed " Production Area Average" for parameters shown on the production area baseline water quality form for the production zones or (2) predictions of restoration quality that are rea-sonably certain after giving consideration to the factors specified in 5331.107 (f) of this title (relating to Restoration).

5331.105.

Monitoring Standards.

The following shall be occomplished to detect mining solutions in designated monitor walls.

(1)

Routine sampling - Water samples shall be taken at least twice a month at two-week intervals from all monitor walls for permit / production area (s) in which mining solutions have been introduced.

These shall be analyzed for the Control Parameters by the second 2

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331.101-331.107

• A working day and reported as required in 5331.85(e) of this title (relating to Reporting Requirements).

The determined values shall be entered on appropri-att forms within three working days after analysis.

These data shall be kept readily available on site i

for review by TWC representatives.

1 (2)

Duration of monitoring program - The program of monitoring detailed in paragraph (1) of this sub-section shall be continued in each permit / mine area until the executive director is officially notified l

that restoration has commenced.

Further monitoring as required by permit shall continue until aquifer restoration and stabilization in that particular permit /mine area has been achieved in compliance with 5331.107 of this title (relating to Restora-tion).

(3)

Verifying analysis - If the results of a routine sample analysis show that the value of any control I

Parameter is equal to or above the Upper Limit established for that permit /mine area, the operator shall complete a verifying analysis of samples taken from each apparently affected well within two days.

(4)

Sampling frequency when mining solutions present -

During the period of time when mining solutions are present in a designated monitor well, water samples will be taken at least 2. times per week, and an-alyzed for all control parameters by the second day j

after the sample is taken.

$331.106.

Remedial Action for Excursion.

If the verifying analysis indicates that mining solutions are present in a designat-ed monitor well, the operator shall take the following actions:

(1)

Notification - Notify the district office by the next working day by telephone and notify the execu-tive director by letter postmarked within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> identifying the affected monitor well and submitting l

the control parameter. concentrations.

This letter shall be-addressed to the a~ecutive director in care l

x of the Director, Hazardous and Solid Wasta Division.

(2)

Analysis - Complete a groundwater analysis report for each affected well on forms provided by the executive director (including Accuracy Checks and Stiff Diagram) for the following:

pH, Calcium, Magnesium, Sodium, Potassium, Carbonate, Ricar-bonate, Sulfate, Chloride, Silica, Total Dissolved Solids (180'C), Specific Conductance and dilute conductance, and any other specified constituents.

Results shall be reported in accordance with

$ 331. 85 (e) of this title (relating to Reporting Requirements).

3 l

I H'

331.101-331.107 l

l.

i (A)

Clean-up - The permittee will clean up all designated monitor walls, all zones outside of the production zone, and the production zone outside of the mine area that contain mining solutions.

The permittee may use any method 1

l judged necessary and prudent to define the extent of the mining solutions and to effect this clean-up in an expeditious and practical manner.

Well clean-up is deemed to be accom-plished when the water quality in the affected monitor well(s) has been restored to values consistent with current local baseline water quality as confirmed by three consecutive daily samples for the Control Parameters.

(B)

The executive director may determine that cleanup is not necessary if the permittee can r

demonstrate th.at the change in water quality is not due to the presence of mining solutions or fluids from other mining activities.

5331.107.

Restoration.

i (a)

Restoration table.

Upon issuance and renewal, Class III permits and production area authorizations shall contain a restoration table listing restoration goals as provided by 5331.104 of this title (relating to Establishment of Baseline and Restoration Values).

(b)

Mining completion.

When the mining of a permit or production area is completed, the permittee shall notify the appropriate Texas Water Commission district office, and the executive director, and shall proceed to reestab-lish groundwater quality in the affected' permit or nine area aquifers to levels consistent with the values listed in the restoration table for that permit or mine area.

Restoration efforts shall begin as soon as practicable but no later than 30 days after mining is completed in a particular production area.

The executive director, subject to commission approval, may grant a variance from the 30-day period for good cause shown.

(c)

Timetable.

Aquifer restoration, where appropriate for each permit or mine area, shall be accomplished in accordance with the timetable specified in the currently approved mine plan, unless otherwise authorized by the commission.

Authorization for expansion of mining into new production areas may be contingent upon achieving restoration progress in previously mined production areas within the schedule set forth in the mine plan.

The commission may amend the permit to allow an extension of the time to complete restoration after considering the following factors:

(1) efforts made to achieve restoration by the original date in the mine plan; l

4 i

I

331.101-331.107 (2) technology available to restore groundwater for particular parameterar (3) the ability of existing technology to restore groundwater to baseline quality in the arear (4) the cost of achieving restoration by a particular methods (5) the amount of water which would be used or has been used to achieve restoration (6) the need to make use of the affected aquifers and (7) complaints from persons affected by the permitted activity.

(d)

Reports.

Beginning six months after the date of ini-tiation of restoration of a permit or production area, as defined in the mine plan, the operator shall provide to the executive director semi-annual restoration progress reports until restoration is accomplished for the permit or mine area.

(e)

Stability sampling.

The permittee shall obtain stability samples'and complete an analysis for certain parameters listed in the restoration table from all production area baseline wells.

Stability samples shall be conducted at a minimum of 30-day intervals for a minimum of three sample sets and reported to the executive director.

The permittee shall notify the executive director at least two weeks in advance of sample dates in order to provide the opportunity for splitting samples and for selecting additional walls for sampling, if desired.

To insure water quality has stabilized, a period of 180 days must elapse between cessation of restoration operations and the final set of stability samples.

The executive director shall determine within 45 days of the receipt of all sample analysis results whether or not restoration has been achieved.

Upon acknowledgament in writing by the executive director confirming achievement of final restoration, the permittee shall accomplish closure of the area in accordance with $331.86 of this title (relating to Closure).

(f)

Restoration table values not achieved.

After an appro-priate effort has been made to achieve restoration to levels consistent with values listed in the restoration table for a production area, the permittee may cease restoration operations, reduce bleed and request that.

the restoration table be amended.

With the request for amendment, the permittee shall submit the results of three consecutive sample sets taken at a minimum of 30-day intervals from all production area baseline wells used in determining the restoration table to verify current water quality, stabilization sampling may commence 60 days after cessation of restoration operations.

5

1 0

G !.102-331. 2 07 (1)

In determining whether the restoration table should be smended, the commission will consider the following items addressed in the requests (A) uses for which the groundwater was suitable at baseline water quality levels; (B) actual existing use of groundwater in the area prior to and during mining; (C) potential future use of groundwater of baseline quality, and of proposed restoration quality; (D) the effort made by the permittee to restore the groundwater to baselines (E) technology available to restore groundwater for particular parameters; (F) the ability of existing technology to restore groundwater to baseline quality in the area under consideration; (G) the cost of further restoration efforts; (H) the consumption of groundwater resources during further restoration; and (I) the harmful effects of levels of particular 1

parameter.

(2)

The commission may amend the restoration table if it finds that (A) reasonable restoration efforts have been under-taken giving consideration to the factors i

listed in paragraph (1) of this subsection; (B) the values for the parameters describing water quality have stabilized for a period of 180 days; (C) the formation water present in the aquifer 4

would be suitable for any use to which it was reasonably suited prior to mining; and (D) further restoration efforts would consume energy, water, or other natural resources of the state without providing a corresponding benefit to the state.

(3)

If the restoration table is amended, restoration sampling shall commence and proceed as' described in subsection (e) of this section.

a e

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s am URI, INC.

agi rne (A Subsidisty of Uranium Resounas, Inc.i ErYLaT P.o a m sass nauw i.no. ars asas amanmeans

o. m.t e n tsess Krssdie.Tenas 7 ass 3 a.e= sso.La s teiepeone (tta) sp.777T

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t py April 13,1993 lbu 5 RECEIVED TDH Mr. Richard Ratliff Director Division of Compliance and inspection APR 161998 Bureau of Radiation Control TEXAS DEPARTMENT OF HEALTH BUREAU OF 1100 West 49tn Street RADIATION CONTROL Austin, TX 78756 3189 RE: U:ense LO2704

Dear Mr. Ratliff:

The purpose of this correspondence is to initiate the closecut of the subject license.

The Loncoria site has been completely decommissioned and surveyed.

Those area that showed contamination above 2x background were cleaned, and the residual soll placed in the approved south pond at the Rosits facility.

The survey results are attached.

The Benavides site is nearing final decommissioning. The we!! field has been cecommissioned and surveyed. The final decommissiohing of the plant area will be completed shortly. We are presently awaiting approval by the TWC to dispose of pond water into our Rosita disposal well.

Closecut of the surface discharge locations is also progressing. The status of the Longoria surface discharge will be dependent on the outcome of the sampling program that will be conducted with our staff on April 21, 1993. We anticipate the amount of cleanup to be small. The cleanup of We will be the Senavides discharge location is essentially complete.

submitting surveys of the Benavides surface discharge location, Senavides wellfields and Benavides pond area prior to closecut surveys.

)

Letter t; R. Ratim

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~

April 13,1993 P;p 2 By this letter, we are requesting the participation of the Agency in the final closecut of the subject license. We would anticipate beginning with surveys of the Longoria sites, followed by the Senavides site. Our goal would be final closure by July 1st of this year.

Please feel free to contact me with questions, or Ms. Lille Canales to

' schedule a tirne to conduct the surveys.

Youru very b )

Maik S. Pe i a j

Environmenta anager l

MSP/ dig Encl.

cc:

Lille Canales/URI Rosita Bill McKnight/URI Corpus Christi G

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TEXAS DEPARTMENT OF HEALTH MEMO 1

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l TO:

GENE FORRER I.JCENSE FILE LO2704 ROBERTFREE.f h

/

THRU:

^

ARTHUR TATE RUTH MCBURNEY hg,p FROM:

OSCARLESSARD CL

SUBJECT:

RFI. EASE FOR UNRESTRICTED USE

^

BENAVIDES FACILITY NEW bp 4 -

URI, BRUNI, TX DATE:

MARCH 13,1998 The confumatory close-out survey and analytical results for Benavides facility are attached (dated August 30,1994, prepared by Thomas Cardwell). The surveys and sampling were accomplished in August 1993 by TDH.

Brad Caskey and Russ Meyer performed confirmatory surveys of the creek beds and concrete blocks on January 14 and 15,1998. One concrete block at the edge of " Pond B" had elevated i

radiation readings. The block was transported to Rosita Project for decontamination and release for unrestricted use. No other readings above background were detected.

The discharge area was found to have elevated radium-226 levels during the survey and sampling accomplished in August 1993. In January 1998, a survey of the discharge area was accomplished and no readings above background were detected. A soil sample was taken and results were within regulatory limits. The discharge area is not pan of the licensed area.

Recommend Benavides facility be released for unrestricted use.

.~

TEXAS DEPARTMENT OF HEALTH AUSTIN, TEXAS INTER-OFFICE MEMORANDUM

\\

AUGUST 30,1994 THRU:

BOB FREE l

BRAD CASKEY HELEN WATKINS ART TATE TO:

LIC #LO2704 FROM:

THOMAS CARDWELL SUBJ:

CLOSE OUT SURVEY OF URI BENAVIDES WELLFIELDS AND PLANT SITE FOR RELEASE TO UNRESTRICTED USE I

On August 4,

1993, I organized a survey team composed of Eric Skotak, Robin Cooksey, Erick Conard, Rick Munoz, Muhammad Zara, and Vic Whadford.

A survey was conducted of the wellfields, plant site, pond areas, and drainage areas at the URI Benavides facility.

The Survey was performed with one-by-one sodium iodide probes held approximately four to six inches above ground level.

The background readings were approximately 1000 counts per minute (cpa) on all the instrumentu except one which averaged approximately 1500

^

cym.

The survey was performed in straight lines approximately 10 meters apart with readings recorded every 10 meters. The surveyors were instructed to survey the entire line and if elevated readings were encountered, to stop and locate the area of highest reading.

The areas were then flagged for sampling or further clean-up.

The readings were plotted on the graphs included as attachment 1.

The areas as indicated on the graphs correspond to the areas as i

marked on the map marked as URI, Inc Benavides Project, included as l

attachment 2.

The grids as marked in attachment 1 are not drawn to scale.

Each grid represents approximately a 10-meter by 10-meter i

square.

The grids in attachment 1 with green borders indicate t

areas of elevated readings which were marked and decontaminated to background readings.

The grids outlined in red are areas which were sampled.

The sample results are included as attachment 3.

t The grids on the plot marked as area 3 in attachment 1, indicates readings of 10,000 cpm in three grids and 12,000 cpm in one grid which was sampled, and 9,500 cpm in another grid.

The grids were marked during the survey.

The grids were decontaminated and sampled.

1

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l The plant area and ponds were also surveyed.

No readings over background were encountered.

Soil samples were collected from the pond areas.

The results of the sample analyses are included in attachment 3.

Surveys of the Benavides discharge area were also performed.

However, areas of elevated readings were encountered. Soil samples were collected and, at the request of URI, submitted to Jordan Laboratories for analyses.

The results of the sample analyses are included as attachment 3.

The concentrations of natural uranium and radium-226 in the discharge area at the Benavides site exceeded the limits for release to unrestricted use.

Therefore, the survey readings were not plotted.

The discharge area will need to be resurveyed prior to release.

l i

i

1

.l TEXAS DEPARTMENT OF HEALTH H

uEuo TO:

GENE FORRER LICENSE FILE LO2704 THRU:

ROBERTFREN '

ARTHUR TATE RUTH MCBURNEY FROM:

OSCARLESSARD OL

SUBJECT:

RELEASE FOR UNRESTRICTED USE LONGORIA FACILITY URI, BRUNI, TX DATE:

MARCH 13,1998 The confirmatory close-out survey and analytical results for Longoria facility are attached (dated August 23,1994, prepared by Thomas Cardwell). The surveys and sampling were accomplished in April and May 1993 by TDH.

Brad Caskey and Russ Meyer performed confirmatory surveys of the creek beds on January 14 and 15,1998. No readings above background were detected.

R==

end Longoria facility be released for unrestricted use.

TEXAS DEPARTMENT OF HEALTH AUSTIN, TEXAS INTER-OFFICE MEMORANDUM AUGUST 23,1994 THRU:

BOB FREE ART TATE TO:

LIC LO2704 FROM:

THOMAS '3RDWELL SUBJ:

SURVEY AND SAMPLING OF THE URI LONGORIA FACILITY FOR UNRESTRICTED USE On April 21,

1993, Robin Cooksey, Victor Whadford, Muhammad Zareabbaszadehk, and I surveyed and sampled the Longoria discharge area.

The readings on the sodium iodide probes were slightly elevated.

Several samples were collected from the creek area. The sample analyses indicated that the average concentration of radium and uranium in the creek sediment meets the limits for unrestricted use.

On April 22,

1993, Robin Cooksey, Victor Whadford, Muhammad Zareabbaszadehk and I surveyed and sampled wellfield #2, the plant pad area and the ponds at the Longoria facility.

The survey was performed on a ten-meter grid using Ludlum 14Cs and one-by-one sodium iodida probes.

The background for the instruments averaged approximately 1100 counts per minute (cpm). Readings were recorded every 10 meters.

The highest reading encountered was 2400 cym.

One area, as indicated on the attached plot of the area, which had a reading of 2200 cpm was sampled and five samples were collected from each pond as indicated on the laboratory forms.

The samples were submitted to the Bureau of Laboratories for analyses.

The analyses have been completed and copies of the results are attached to this meno.

The analyses indicated that the areas sampled meet the unrestricted use limits.

'l URI Longoria August 23. 1994 Page 2 On May 4, 1993, Robin Cooksey, Karan Raines, Eric Skotak and I surveyed and sampled wellfield #3'at the Longoria facility.

The

• survey was performed with the same procedures as the April 22 survey discussed previously. Again two of the meters had a average background of _ approximately 1100 cpm and the third meter had a background of approximately 2000 cym.

The survey was performed along lines running south of southwest to north of northeast.

All readings in the wellfield were less than twice background and uniform readings were noted.

Therefore, one area was randomly select in the wellfield for sampling.

Samples were collected from 0 - 15 centimeters and from 15 - 30 centimeters from the center and the four corners of a 100 square meter area.

The samples were submitted to the Texas Department of Health, Bureau of Laboratories for analyses.

The analyses of the area sampled indicate that wellfield #3 meets the limits for unrestricted use.

The plots of the wellfields and plant area surveys are included as attachments to this meno.

Also, the Agency sample analyses of the wellfields and discharge area are attached.

The Licensee's sample plot of the discharge area and sample results are included as attachments to this mano.

e, AP3-22-93 1C: 10 FROM TDH-RADIATION CONTROL 10:512 034 GGSD PACE 1/2 c

1 FAX TRAXSMISSION DIVISION OF LICENSING, RIGISTRATION, AND STANDARDS BUREAU OF RADIATION CONTROL I I OC WcsT 497H AUSTIN. TcxAs 78756 (512)834-6680 fax: (51218344090 To:

Kevin Hsuch Date:

April 22,1999 Fax #:

(301)415-3502 Pages:

2. including this cover sheet.

Frorn:

Eugene Forrer

Subject:

Correction to letter of April 8,1998 COMMENTS:

Let me know if you need anything else.

i l

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• . APR-22-09 10:10 FROM.TDH-RADIATION CONTROL 1D:512 034 GGDD PAGE 2/2

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T_D_H_

Texas Department of Health Wilham R. Archer III. M.D.

!!00 West 49th Street Pani J. Panerson, M.D., M.P.H.

Commissioner Ausdn, Teus 78756-3189 Execudve Deputy Commissioner (512) 458-7111 Radiation Control l

(512) 834-66SS l

April 8,1999 l

UNITED STATES NUCLEAR REGULATORY COMMISSION ATTN PAUL H LOHAUS DIRECTOR i

OFFICE OF STATE PROGRAMS l

MAIL STOP 03H2O WASIDNGTON D C 20555

Dear Mr. l.ohaus:

l Please find attached the additional information requested by your office, in a letter dated February 23,1999, l

regarding our request for concurrence on termination of Radioactive Material License No. IA2704.

As maintaining this site places an undue economic burden and hardship on the licensee we request expeditious processing of this request.

l If you have any questions, please call me at (512) 834-6688 extension 2208.

Sincerely.

b

<~

l Eugene (Gene) Forrer l-Chief, Uranium Licensing Project Division of Licensing, Registration, and Standards l

Bureau of Radiation Control

' Enclosure I

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John M. aaker. conrrminiorner Jettrey A. sastas Executive Director TEXAS NATURAL RESOURCE CONSERVATION COMMISSIONRE ED Protecting Texas bg Reducing and Presenting Pollution gpg g y 1999 g@gATION CONTROL UREAU OF ugust 20,1998 g

CERTIFIED MAIL 2 707 667 708 RETURN RECEIPT REQUESTED Mr. Mark elizza Vice Presid nt, Environmental Affairs g g.g ( 2 f URI, incorpo ted 12750 Merit rive Dallas, TX 75 1

Re:

Benavide Project, Class 111 Permit No. UR02312 001

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ebruary 25,199 inspection at the URI, Inc. Benavides Project located in Duval Q TN An inspection by Muhammadali Abbaszadeh and Victor W. Whadford

Dear Mr. Pelizra:

The inspection on the date and location indicated above was an examination of the activities conducted under your Underground injection Control (UlC) permits that involve compliance with the Texas Natural Resource Conservation Commission's (TNRCC) rules found in Title 30 Texas Administrative Code (TAC) Chapter 331 (effective dates April 28, 1997), and the conditions of your permits. This inspection included interviews and inspection of locations and observations by the inspectors.

An inspection report was prepared and submitted to the technical staff of the Underground injection Control and Radioactive Waste Section of the Industrial and Hazardous Waste Division in Austin. No items of noncompliance were found during the February 25,1998 inspection concerning the permit listed above. With regard to the area inspection, this permit appears to be in compliance with the permit conditions, applicable rules, and regulations of the Commission.

1 The production areas at this site have been released by the Commission and the Class lit wells have been plugged and abandoned properly. Therefore, any additional routine UIC permit inspection et this site is not anticipated. If you have any questions concerning this inspectior,

or wish to receive a copy of the Benavides Project inspection report, please feel free to contact P.O. Box 13087 Austin, Texas 787113087

• 512/239-1000

• Internet address: www.tnrce. state.tx.us u,.-.. m.

.. :,6

e-Mr. Mark Polizza Page 2 August 20,1998 Mr. Muhammadali Abbaszadeh of the inspection and Compliance Team at (512) 239-6078, mail code MC131. Thank you for the cooperation and assistance provided during this inspection.

Sincerely, SDl v

Alice Hamilton Rogers, P.E., Manager Underground injection Control & Radioactive Waste Section AHR/MA/jb cc:

Mr. Muhammadali Abbaszadeh, inspection and Compliance Team, TNRCC Mr. Victor W. Whadford, inspection and Complie:.ce Team, TNRCC 1:\\URW\\MABBAszA\\BENV98oK.WPD c

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65E9/.

Barry R. McBee. Chairrnan j

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3elfrey A. Saitas, Executite Director TEXAS NATURAL RESOURCE CONSERVATION COMMISSION Protecting Teras by Reducing andPresenting Pollution RECEIVED E,PR 0 71999 BUREAU OF November 18,1998 RADIATION CONTRO:

i CERTIFIED MAIL Z 707 67 894 o'

RETURN RECElPT REQUESTED Mr. Mark Pelizza Vice President, Environmental Affairs URI, incorporated gf 12750 Merit Drive

[ce,vn /o7 7 0 I Dallas, TX 75251 Re:

Longoria Project, Class ill Permit No. UR0222-001 September 30,1998 inspection at the URI, Inc. Longoria Project located in Duval County, TX An inspection by Muhammadali Abbaszadeh and Victor W. Whadford

Dear Mr. Pelizza:

The inspection on the date and location indicated above was an examination of the activities conducted under your Underground injection Control (U!C) permit that involves compliance with the Texas Natural Resource Conservation Commission's (TNRCC) rules found in Title 30 Texas Administrative Code (TAC) Chapter 331 (effective dates April 28, 1997), and the conditions of your permit. This inspection included interviews and inspection of locations and observations by the inspectors.

An inspection report was prepared and submitted to the technical staff of the Underground injection Control and Radioactive Waste Section of the Permits Division in Austin. No items of noncompliance were found during the September 30,1998 inspection concerning the permit listed above. With regard to the area inspection, this permit appears to be in compliance with the permit conditions, applicable rules, and regulations of the Commission.

l P.O. Box 13087

• Austin. Texas 78711-3087

• 512/239 1000

• Internet address: www.tnrce. state.tx.us remkJ em se.kd pace v mg wn h.rd ne

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Y 4, Mr. Mark Polizza Page 2 November 18,1998 The production areas at this site have been released by the Commission and the Class 111 wells have been plugged and abandoned properly. Therefore, any additional routine UIC permit inspection at this site is not anticipated. If you have eny questions concerning this inspection, or wish to receive a copy of the Longoria Project inspection report, please feel free to contact Mr. Muhammadali Abbaszadeh of the inspection and Compliance Team at (512) 239-6078, mail code MC131. Thank you for the cooperation and assistance provided during this inspection.

Sincerely, hw Alice Hamilton Rogers, P.E., Manager Underground injection Control & Radioactive Waste Section AHR/MA/jb Mr. Muhammadall Abbaszadeh, inspection and Compliance Team, TNRCC cc:

Mr. Victor W. Whadford, inspection and Compliance Team, TNRCC 1:\\uRW\\MABBASZA\\LoNGo198.WPD