Text

Informs of Completion of Groundwater Review of Naturita, Colorado Final Completion Rept Dtd Nov 1998.Determined That All Monitor Well Abandonment Repts & Maps Have Been Correctly Signed & Approved by Licensed Engineer
	ML20217P306
Person / Time
Issue date:	06/21/1999
From:	William Ford; NRC
To:	Robert Carlson; NRC
Shared Package
ML20217N400	List: IA-99-336, Informs of Completion of Groundwater Review of Naturita, Colorado Final Completion Rept Dtd Nov 1998.Determined That All Monitor Well Abandonment Repts & Maps Have Been Correctly Signed & Approved by Licensed Engineer; ML20217N392; ML20217N670; ML20217N740; ML20217N774; ML20217N831; ML20217N946; ML20217N965; ML20217P011; ML20217P041; ML20217P045; ML20217P055; ML20217P139; ML20217P306;
References
	FOIA-99-336 NUDOCS 9910290263
	Download: ML20217P306 (106)
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. l Anne Ramirez - ncturita final complGtion report groundwater reEw.wpd Page 1 l 1: -

' From: William Ford J s To: Robert Carlson , c ni 3 Date: Wed, Jul 21,1999 - 3:16 PM

Subject:

Naturita Final Completion Report Gnmdwater Review

]

Dear Robert,

I have completed the groundwater review of the Naturita, Colorado Final Completion Report )

dated November,1998. I have reviewed the monitor well abandonment reports. All monitor well abandonment reports and maps have been correctly signed and approved by a Colorado j licensed professional engineer. The groundwater concems in the final completien rr port have been adequately addressed.

Sincerely, !

William Ford CC: James Kennedy I

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1 9910290263 991027 -

PDR FOIA MIDDLET99-336' PDR L .. .-

o UKETCO MINERALS CORPORATION

_, 1600 UTE AVENUE-

- . GRAND JUNCTION, COLORADO 81502 Pursuant to the Radiation Control Act, Title 25, Article 11, C.R.S. (1989,

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Replacement Volume) as amended, and the State of Colorado " Rules and Regulations Pertaining to Radiation Control", Part 3,.and in reliance on statements and representations heretofore made by the licensee designated below, COLORADO RADIOACTIVE MATERIALS LICENSE No. 660-02 IS HEREBY AMENDED IN FULL, authorizing such licensee to receive, possess and transfer the radioactive material (s) designated below and to use such radioactive materials for the purpose (s) and at the place (s) designated below. This license is subject to all applicable rules, regulations, and orders now or hereafter in effect of the colorado Department of Health (the " Department") and to.any conditions specified below.

2.0 LICENSEE NAME UMETCO MINERALS CORPORATION 2.0 LICENSEE ADDRESS Recional Address 1600 Ute Avenue P.O. Box 1029 Grand Junction, CO 81502 Local Address P.O. Box 860 Nucla, CO 81424 660-02 AMENDMENT NUMBER O2 3.0 LICENSE NUMBER 4.0 EXPIRATION DATE December 31, 1991 5.O REFERENCE NUMBER SUA-673 AUTHORIZATIONS 6.0 RADIOACTIVE MATERIALS 6.1 Natural uranium and radioactive decay products of uranium, in

-particular uranium-238, uranium-234, thorium-230, radium-226, radon-222 and progeny.

6.2.1 Cesium-137.

6.2.2 - Americium-241:Be.

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License No. 660-02 Amendment No. 02 April 4, 1991 Page 2 of 45 7.0 CHEMICAL AND/OR PHYSICAL FORM 7.1 Milling and cleanup residues, including tailings, evaporation crystals and sludges; milling refuse, including decommissioned equipment and building materials.

7.2 Four (4) Sealed Sourcess 7.2.1 Troxler Drawing No. A-102112 (2 sources);

7.2.2 Troxler Drawing No. A-102451 (2 sources).

8.0 MAXIMUM OUANTITY LICENSEE MAY POSSESS AT ANY ONE TIME 8.1 12,500,000 dry tons (11,000,000 metric tonnes) of tailing or other residues; unepecified quantities of milling refuse; 900,000 dry tons of Naturita materials.

8.2.1 Two (2) sources, no single source to exceed 9 mil 11 curies of cesium-137; 8.2.2 Two (2) sources, no single source to exceed 44 millicuries of Americium-241:Be.

9.0 AUTHORIZED USES 9.1 The licensee is authorized to store and dispose ores, milling residues, taili . *, and refuse consistent with the Remedit Action Plan to which rs? <ance is made in LC 11.1.

The licensee is authorized to receive, own, possess, and permanently

' dispose of radioactive materials removed from the Naturita UMTRCA Title I site at the Uravan facility.

In addition to all other requirements of_the license and this license amendment, the licensee shall receive, possess, and dispose of the Naturita tailings in accordance with final plans and specifications to be submitted to and approved by the Radiation Control Div,sion pursuant to LC 17.4, in accordance with the Consent Decree and RAP (LC 11.1), in accordance with any applicable I requirements of the Remedial Action Plan for the remediation of the Naturita UMTRA site and in accordance with LC 11.7.

9.2 To be used in Troxler 3400 model series moisture / density gauges,to )j determine the moisture content and density of soils and construction j materials.

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e 4 License No. 660-02 Amendment No. 02 April 4, 1991 Page 3 of 45 10.0 AUTHORIZED PLACE OF USE 10.1 The licensee's uranium processing facilities at Uravan in Montrose County, Colorado, located as follows:

Those portions of Township 47 North, Range 17 West, New Mexico Principal Meridian, Section 4, and Township 48 North, Range 17 West, New Mexico Principal Meridian, Sections 28, 29, 33 and 34, delineated in Annex A, and any other portion of the Uravan Facility, as defined in the Consent Decree, to which reference is made in LC 11.1.

1s.2 Radioactive materials described in LC 6.1.1 and 6.1.2 may be used at temporary job sites of the licensee anywhere in the State of Colorado where the State of Colorado maintains jurisdiction for regulating the use of radioactive material.

LICENS E COND I T IONS (LCs) 11.0 LICENSEE PROPOSALS AND COMMITMENTS ("PEFERENCED DOCUMENTS")

Except as specifically provided otherwise by this license, the licensee shall possess and use radioactive materials described in Items 6, 7, 8 and 9 of this license in accordance with statements, representations, and procedures contained in the licensee's:

11.1 Uravan Uranium Millsite Remedial Action Plan (hereafter " RAP") which is attached as Appendix I to the Consent Decree, Order, Judgement, and Reference to a Special Master Filed in the United States District Court, Civil Action No. 83C2384, " State of Colorado, Plaintiff, vs. Union Carbide Corporation, a New York Corporation, and Umeteo Minerals Corporation, a Delaware Corporation, Defendants" (hereafter " Consent Decree").

11.2 Procedures Manual for Plant Operations at Uravan, dated March 31, 1982, as subsequently revised pursuant to LC 20.

11.3 Final Plans and Specifications submitted in accordance with LC 11.1, when such Final Plans and Specifications become Final Submittals as defined by the Consent Decree.

11.4-1 Procedures Manual for Environmental Monitoring at Uravan, dated March 31, 1982, as subsequently revised pursuant to LC 20.

11.4-2 When the Quality Control / Quality Assurance, Monitoring and Performance Evaluation Plan (Quality Plan) submitted in accordance with LC 11.1, becomes a Final Submittal, as defined by the Consent Decree, the Final Submittal shall replace in full the Procedures Manual for Environmental Monitoring'at Uravan designated as LC 11.4-1.

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1 License No. 660-02 Amendment No. 02 l April 4, 1991 (

Page 4 of 45 11.5 Financial assurance requirements stated in Section XVII of the consent Decree, which shall, upon becoming fully effective, .

j replace in full the Reclamation Surety Agreement, dated September '

22, 1981, as revised pursuant to LC 32.

11.6 Long term monitoring and maintenance requirements as stated in Section IV(G) of the Consent Decree, as may be revised pursuant to LC 33.

11.7 Letter of April 20, 1987 form Roger Jones to Alber. J. Hazle, with 1 enclosure; letter of July 20, 1987 from Roger to Edd Kray, with l J

enclosures. l I

11.8 Amendment application dated October 22, 1990, as revised December 6, f

1990. l P

12.0 CErERAL CONDITIONS 12.1 DEFINITION OF TERMS 12.1.1 Unless otherwise provided in this license, terms used herein are as defined in the State of Colorado " Rules and Regula'. ions Pertaining 1007-1-1 et eeo., hereafter the

' to Radiation Control" (6 C.C.R.

" Radiation Regulations").

12.1.2 The terms used herein are to be interpreted in a manner consistent with the Consent Decree and LC 11.1.

12.2 OBTAIN PERMITS OF OTHER AGENCIES Prior to beginning any new construction or new operations, or any other activities authorized by this license, the licensee shall obtain all applicable permits and other authorizations of local, state and federal agencies having authority over health, safety, and environmental protection aspects of the activities authorized by Items 6, 7, 8, and 9 of this license. The licensee shall maintain in force such applicable permits from beginning to end of the project.

The licensee shall inform the State through'the On-Site Coordinator (as that term is defined in paragraph III(h) of the Consent Decree, hereafter "OSC") and provide a copy to the Radiation Control Division of the Department (hereinafter referred to as the

" Division") thirty (30) days prior to, or as soon thereafter as it is available but in no event later than the date of filing of, any application to permitting agencies for modification or renewal of such permits or other authorizations.

12.3 COMPLY WITH PERMITS within the scope of applicable statutes and lawful regulations thereunder, the licensee shall operate in full compliance with the requirements of each other division of the Department.

6 licente 'No. 660-02 !

.Anendment No. 02 l Jgell 4,1991

.Bage $ of <45 i

Violation af tych other requirenerts shall .not try itself constitute violation of this' license, unless the Department makes an l l

independent finding of violation of the ' Radiation Regulations or a condition of this license other than this LC 32.3. t l

12.4 STATUS OF REFERENCED DOCUMENTE f Proposals and commitments in referenced document 4 are in effect license conditions.

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Where the word "will" or "should" in used in the documents referenced in LC 11 above, it shall denote a requirement.

Where statements in referenced documents conflict, the most recent document shall prevail unless the Division determines otherwise.

j The Radiation Regulations shall control provisions of the referenced l documents which conflict with said Radiation Regulations unless the i provisions of the referenced document are more restrictive than the Radiation Regulations.

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A requirement pursuant to revised regulations or policy shall be !

considered a modifications of this license for the purposes of judicial review under colorado law.

12.5 SEVERABILITY If any part of the Radiation Regulations, Department or Division policy, or this license is held invalid, the remainder shall not be affected.

12.6 HAZARDOUS RELEASES authorize, By this License, the Department does not permit, concur in, or otherwise approve of, the release or threatened releat,o of hazardous substances, pollutants, or contaminants into the environment, except as specifically authorized by this license.

12.7 WRITTEN APPROVAL

- 12.7.1 Required Department " acceptance", " approval", " authorization", or

" concurrence" shall be obtained in writing from the Division, unless otherwise provided in the Radiation Regulations, or Department or Division policy.

12.7.2 When the Division reasonably and routinely consults with another it State

. party, including, but not limited to, the State Archaeol og s ,

Engineer and Colorado Geological Survey, the licensee shall:

facilities, 12.7.2.1 Permit such party to inspect designated documents, or sites;

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'Liwe.ae %x 460-02 1.tme:ndment No 02

.31:11' 4. Wst

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j 12.7.2.2- Subnit &signated docsmemts es the pq for mrview; and l

12.7.2.3 confc:::s . appl.it.atistna' and awycetiva chc2mener to the written 1

guidelines to or W wur.h p: rey ao. determined" Wy the Division to be applicabis to the per' pct.

' 12.8 LICENSE CONDITIONS MODITf REPTREY;1'5U WMPQ The fo) lowing license conditiero, tc. the enrmt such conditions are j

{

not it.cusik 2 tent with LC 33.2, modify and aM to commitments in the j dr$5 m nts'in LC 21.

1 lbp ~ OWNERSHIP AND CONTPOL 33.1 EVIDENCE OF TITLE I

The licensee shall provide to the Division,7vidence of any change in title to the properties described in LC 10 and Annex A.

13.2 NOTIFICATION OF INTENT As required by Section XII of the Consent Decree, the licensee shall provide the. Division with ninety (90) days advance notification of any proposed change in property ownership or control of the Properties described.in LC 10.0 and Annex A.

13.3 DEPARTMENT AUTHORIZATION REOUIRED i

13.3.1 No transfer of title to any portion of the licensed site may be made l at any time without prior written authorization from the Division.

Any such transfer shall be in accorda7ce with 6 CCR 1007-1-3.15.2 unless otherwise authorized by 1.ne' Division.

13.3.2 No portion of the licensed site may be vacated without notification in accordance with RH 4.33 and' prior written authorization from the {

Division.

13.4 TRANSFERABILITY 4

Ownership or control of the tailings confinement area shall be such that jurisdiction over the property may be readily tran,sferred to the state or federal government under the provisions of 6 CCR 1007-1-1 gj;, agg.

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Liesnse No. 660-02 Amendment'No. 02 April 4, 3991 Vage 7 c1 45 13.5- BANKRUPTCY The licensee shall notify the Department, in writing, immediately following the filing of a voluntary or involuntary petition for bankruptcy under any Chapter of Title 11 (Bankruptcy) of the United State code by or against:

a. The licens.o; b.. An entity (as that_ term is. defined in 11 U.S.c 101(14))

controlling the licensee or listing the license or licensee as property of the estate; or

c. An affiliate (as that term is defined in 11 U.S.c. 101(2)) of the license.

This notification must indicate the bankruptcy court in which the petition for bankruptcy was filed and the date of the filing of the petition. ,

14.0 USERS 14.1' AUTHORIZATION I 'The licensee shall submit resumes and documentation of users' training and experience to the Department and obtain written authorization from the Department for each user.

14.2 LigI l

I The licensee shall maintain throughout use of radioactive materials authorized by this license at least two (2) trained, qualified, and authorized users, to include the Radiation Safety Officer (RSO). ,

14.3 AVAILABILITY An authorized user shall be on hand at the f acility or immediately available at all times during facility operation.

14.4 MINIMUM TECHNICAL OUALIFICATIONS FOR RADIATION PROTECTION OFFICER The RSO shall have at least a B.S. degree in radiological or environmental sciences, or a related field, from an accredited l

college. The RSO shall have intensive formal training of at least '

one year duration with a minimum of one week of the course ;

specifically applied to health physics problems at radioactive materials facilities.. The RSO shall have at least one year of l

" hands on* experience in radiation safety and occupational health in )

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a uranium mill or related facility, at least six months of this experience at the supervisory level. Refresher training in health

- physics (a minimum of 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months ) is required at least every two years.

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M:c-rse Nc '64 0-02 .

Ameadme=c so. 02 Aper; 4, 199's Page B od 45 A Master Degree (or a more adra:md ddgree) may be ;wsbetituted for the two year intensive tralaing requirement akove.

With Department approval, experieme snay also be su.bstituted for training requirements.

14.5 DESIGNATED ASSISTANTS TO THE RADI AMON SATETY 057ICER including The RSO may delegate to trained assistants functions, quality assurance / quality control measures, required by this license for which a written procedure is included in LCs 11.1 through 11.4, so long as quality is maintained and dcaumented and minimum qualifications for health physics technicians and other members of the radiation safety staff are specified in Lc 11.2.

14.6 NON-SAFETY ASSIGNMENTS The licensee's radiation safety and environmental control staff shall fulfill requf-ements of this license prior to being given assignments not related to health, safety and environmental protection, unless otherwise authorized by the Department.

15.0 EMERGENCY ACTIONS 15.1 REPORT OF ACCIDENTS The licensee shall, immediately upon discovery, notify the OSC and Director, Radiation Control Division, Colorado Department of Health, 4210 East 11th Avenue, Denver, Colorado 80220 by telephone (303-331-8480, or 370-9395 after office hours) and in writ!ng, of any failure or-imminent threat of failure in any process, diversion,

' ** or retention system which results or may result in a release of radioactive material into uncontrolled areas. This requirement is in addition to the requirements of 6 CCR 1007-1-4.29 and -4.31.

15.2 EMERGENCY RESPONSE CAPABILITY The following shall be approved by the Department:

15.2.1 Warnino System The licensee's system for warning in the event of a tailings impoundment break shall be as specified in LCs 11.2 through 11.4.

Liquid emergency catchment basins shall have alarms tested at a frequency specified in LC 11.2, and LC 11.4-1 or 11.4-2.

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Licensa No. 660-02 Amendment No. 02

.Apr.ll 4,1991 Tage 9 c2 45 (

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l 15.2.2 Response Plans i

f The licensee r5all use plans, approved by the Lepartment in l I conjunction with such agencies as the Division of Disaster Emergency '

Services and specified in LC 11.2, and LC 33.4-1 or 11.4-2, to l respond;to accidents and fires in the mill complex and in I

! transportation of radioactive material. These plans shall include provisions for prompt retrieval of any radioactive material released l j

to uncontrolled areas by rupture of any storage or disposal area or ;

pipeline. l 15.2.3 Eauipment The licensee shall have available, every calendar day all year, sufficient personnel, equipment and supplies to respond to accidents, fires, and other emergencies in accord with the plans specified in LC 11.2, and LC 11.4-1 or 11.4-2, as approved by the Department.

25.2.4 Trainino The licensee shall maintain a documented emergency response training program to insure that sufficient trained persons are always available.

16.0 FACILITY OR PROCESS ADDITIONS OR CHANGES 16.1 The licensee shall provide the Department thirty (30) days advance notification of any proposed addition or change to a facility or process which potentially has a significant health, safety or l environmental protection aspect. Potential public health or environmental impacts not previously assessed, or greater than previously assessed, require notification.

16.2 If the Department makes a preliminary finding of significant health, l safety, or environmental impact, the licensee shall provide the l Department with a written assessment of impacts resulting from the facility or process addition or change.

16.3 If the Department, upon review of the licensee's written assessment, determines that written approval or a license amendment is required, the licensee shall apply for and obtain the prescribed authorization prior to modifying the facility or process feature. I 16.4 The licensee shall provide to the Department an acceptable plan of action to eliminate or effectively control any unexpected harmful effects or irreversible damage detec.ed during operation and not otherwise identified in LC 11 or other license conditions.

11wnse No. 660-02 .

Amaninest .tto. 02 A3111 4, 233.1 Page 1D c:t 4LS 17.0 DESIGN AND ENGINEERING 17.1 GENERAL CONSTRUCTION REOUIREMEffTG All. construction related to Items 6, 7, S, and 9 of this license shall be in accord with detailed plans approved by the Department as specified (and such other agencies as the Department designates) in Lc 11 Land as follows:

17.2 SUPERVISION The licensee shall supervise all licensed construction activities in accordance with the regulations which govern the activities of the State Engineer and such additional requirements as are determined to be necessary pursuant to the Consent Decree and applicable State of Colorado rules and regulations.

s-Jr 17.3 FINAL PLANS AND SPECIFICATIONS The licensee shall make available fifteen (15) copies of the detailed Final Plans and Specifications for all work for distribution by the Department to such other-agency representatives as the Department designates.

17.4 REVISED FINAL PLANS AND SPECIFICATIONS The licensee shall submit, within 45 days of receiving notification as the successful bidder for disposal of the Naturita materials, revised plans and specifications for Tailings Piles 1-2 and the Burbank~ Repository.

17.5 The licensee shall provide written confirmation of the average radium concentration of the Naturita tallings and earthen materials at the time of submittal of the revised plans and specifications required by LC 17.4.

28.0 GENERAL REOUIREMENTS FOR ACTIVITIES 18.1 FACILITY STATUS .

The licensee shall obtain prior authorization by license amendment from the Department at such time as any part of the Uravan Facility is to change from stand-by status.

18.2 PRODUCTION RATE

'The licensee shall not store or crush ores or refine and produce uranium product without prior authorization by license amendment from the Department.

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l License No. 660-02 j

Amendment No. 02

. April 4. J.991 2 age 21 ci 45 18.3 CENERAL MAINTENANCE All mill, storago, processing, trans; ort, isepcur.dment , containment, monitoring, and safety systems which shall be operated pursuant to l this License shall be maintained in good working order. The !

licensee shall document a system of routine preventive maintenance so that safety-related equipment is checked for proper working order according to a regular schedule.

l 18.4- ALARA (AS LOW AS REASONAPLY ACHIEVABLE)

The licensee shall keep exposures as low as reasonably achievable 1 (ALARA) as provided in LCs 11.1, 11.2, and 11.4-1 or 11.4-2. Final submittals, as defined by the Consent Decree, shall conform to U.S.

Nuclear Regulatory Commission Regulatory Guide 8.10, " Operating j Philosophy for Maintaining Occupational Exposure as Low as Reasonably Achievable", except as aathorized by the Department.

I The ALARA program performance shall be reviewed monthly by the Radiation Safety Officer (RSO) in a monthly written report to the manager.

18.5 PIANAGEMENT The licensee shall provide, by March 31st of each calendar year, updated details of the authority and responsibility of each level of management, noting any changes.

18.6 OFF-SITE DOSE LIMITS l

18.6.1 Limits ,

The licensee shall conduct. activities in such a manner as to provide ,

l reasonable assurance that the annual radiation dose equivalent of 25 millireme to the whole body, 75 millireme to the thyroid, and l' 25'millirees to any other organ of any member of the public is not exceeded as the result of exposures of radioactive materials resulting from planned discharges of radioactive materials, radon and its progeny excepted, to the general environment.

18.6.2 Performance Determination of performance in relation to LC 18.6.1 shall be based upon the annual reports required by LC 30. l 18.6.3 Specific Recuirements 18.6.3.1 The licensee shall insure, and specify in LC 11.4-1 or 11.4-2, a method to document that no garden produce is grown for human I consumption on licensee-controlled property at Uravan.

I 18.6.3.2 ' The licensee shall not permit any building or improvement at the l Uravan Facility to be constructed for or occupied as a residence. )

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4 Licent.e Sa. 660-02 JLactrawst Po. 02 1.pr il 4, 1991 f2ge 12 of 4 5 18,7 BASELINE INFORMATION For the purpose of rs' viewing site ele.ancp and is,clxnation, the following shall be included as baseline xwferencen:

18.7.1 Environmental Report, dated August 31, 1978 for all baselino data and analyses, in particulars section 2, pages 29-30, 43-50,74-102, 109-113; Section 3, pages 32-34, 47-49, 60-63; Section 5, pages 9-10; Section 6, pages 20-21; Section 7, page 35; Appendices C & D; 18.7.2 Updated Environmental Report, dated March 31, 1982; 11, 1986.

18.7.3 ERI Logan, Inc. Reports, Vols. I and II, August 18.8 LEAK TESTING Radioactive materials authorized in LC 6.1'.5 2 and 6.1.2 shall be 18.8.1 tested for leakage and/or contamination at intervals not to exceed six (6) months.

18.8.2 In the absence of a certificate from a transforor indicating that a test has been made within six months prior to the transfer, a sealed source received from another person shall not be put into use until tested.

18.8.3 The test shall be capable of detecting the presence of 0.005 microcurie of radioactive material on the test sample. The test sample shall be taken f rom the sealed source or from the surf aces of the device in which the sealed scurce is permanently mounted or stored on which one might expect contamination to accumulate.

Records of leak test results shall be kept in units of microucuries and maintained for inspection by the Department.

18.8.4 If the test reveals the presence of 0.005 microcurie or more of removable contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired or to be disposed of in accordance with the Radiation Regulations. A report shall be filed within 5 days of the test with the Director, Radiation Control Division, Colorado Department of Health, 4210 East lith Avenue, Denver, Colorado 80220, describing the equipment involved, the test results, and the corrective action taken.

18.8.4 Teste for leakage and/or contamination shall be perfcrmed by the Radiation Safety Officer, or by other persons specifically authorized by the U.S. Nuclear Regulatory Comuission or an Agreement State to perform such services.

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I License No. 660-02 Amendment No. 02 i

April 4. 1991 l Page:13 of 45 18.9 TRANSPORTATION OF MATERIALS 1

18.9.1 The licensee may transport radioactive materlal cv deliver I

radioactive material to a carrier for transport, in accordance with i the provisions of RH 17 of the State of Colorado Rules and l Regulations Pertaining to Radiation Contral, *TranspoiGtion of Radioactive Material".

18.9.2 The transportation of Colorado radioactive materials shall be subject to all applicable regulations of the colorado Public Utilities Commission, Colorado Department of Highways, Colorado l

Department of Public Safety, Colorado Department of Revenue (Port of

! Entry), U.S. Department of Transportation, and other agencies of the '

l Unites States having jurisdiction. When the U.S. Department of Transportation Regulations (Title 49, Chapter I, code of Federal Regulations) are not applicable to shipments by land of Colorado radioactive material by reason of the fact that the transportation ,

does not occur in interstate or foreign commerce, the licensee must j be in compliance with the requirements relating to packaging of the j ra2toactive material, marked in and labeling of the package, placarding of the transport vehicle, and accident reporting set l forth in the regulations of the U.S. Department of Transportation.

18.10 ELEVATION OF TAILINGS PILE 1-2 The licensee shall not place tailings or other contaminated materials on top of Tailings Pile 1-2 to an elevation greater than 5,550 feet prior to Department approval of a revised written stability analysis (Appendix B of LC 11.7).

19.0 SITE CONTROL AND PERSONNEL SAFETY 19.1 RESPONSIBILlU, 19.1.1 The Plant Superintendent shall be accountable for safety, security, fencing, posting, and area control.

19.1.2 The RSO or RSO's designee shall have authority to remove employees from a work environment or suspend the operation in a particular mill area if he has determined that a condition exists that would likely result in any individual being exposed to radiation that may present an imminent health hazard.

19.1.3 The Plant Superintendent shall act promptly on the recor tons

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of thr,s RSO or RSO's designer pertaining to radiation r l security.

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Licansa No. 660-02 ,

Amendment No. 02 Apcil 4,1391 Pipe 34 of 4 5 19.2 TRAINING !

19.2.1 New employees shall not commence work assigemmts in controlled areas'until they have been adequately tralned in their assignment and in radiation safety, in accordance with a program approved by Such training shall be the Department and~specified in LC 11.2.

documented by dates, nature of training, tests and ccores, and

. written acknowledgment of receipt by employee.

19.2.2 The RSO shall document employee review of (1) procedures applicable to each employee'm assignment and (2) provisions of 6 CCR 1007-1-10.

19.2.3 The licensee shall accumulate at least ninety (90) minutes of training meeting time per year, or alternative amount approved by the Department'and specified in LC 11.2, for each radiation worker

to review radiation protection topics, documenting employee attendance, and re-train radiation workers annually on current developments in radiation safety.

19.3 PROTECTIVE CLOTHING Respirators, gloves, boots, coveralls, helmets, goggles and other protective items shall be used at all times in areas or activities designated by the RSO.

19.4 -RADIATION WORK PERMITS The licensee's RSO or'RSO's designee shall prepare a Radiation Work Permit, prior.to start of any work or maintenance, at any location of.the licensed facility or site, which has radiation safety implications and for which no written procedure exists. The

- *' Radiation Work Permit shall specify appropriate radiological ,

controls. The licensee's Radiation Work Permit program shall be included in LC 11.2, as approved by the Department. A copy of s11 permits shall be retained for no less than five (5) years for inspection by the Department.

19.5 SHOWE3S and

All workers shall shower or monitor head, face, and hands, 2 in document absence of contamination exceeding 1000 dpm/100 cm ,

areas or activities where designated by the RSO.

19.6 CONTROLLED AREA RESTRICTIONS i The licensee shall not allow eating and smokir.g in controlled areas, except in control rooms, offices, and lunchrooms, or other areas designated by the RSO.

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L1 ense.W. 660-02

.Tme2:1mer: No. 02 I

AprrJ 4,1991 Page 1.5 of 45 19.7 SECURITY The licensee r>all fence and post the contrcIled area boundary as specified in LC 11.2 and in accordance with 6 CCD 1007-1-4.14.

l j 19.8 POSTING EXEMPTION 1

I The licensee is hereby exempted from the requirements of 6 CCR 1007-1-4.11 for areas within the exclusion area boundary, provided all entrances to the property are conspicuously posted with the sign:

"Any Area or Container on this Property May contain Radioactive Materials."

l 20.0 HEALTH, SAFETY AND ENVIRONMENTAL PROCEDURES MANUAL 1

20.1 PROVISIONS The licensee shall conduct construction and cleanup operate according to (and maintain) comprehensive written health, safety and environmental procedures manuals, approved by the Department, j governing licensed activities, to wit: LC 11.2, and LC 11.4-1 or 11.4-2. The procedures manual (s) shall contain safety, monitoring, decontamination, and emergency procedures, including:

20.1.1 Administrative and operating procedures relating to radiological 1 health and safety; i 20.1.2 Instructions and precautions to keep exposures ALARA; 20.1.3 Specific information on analytical equipment, laboratories, and procedures for each aspect of'the monitoring program.

20.2 REVISIONS 1

20.2.1 No reduction in monitoring provisions shall be made without l

! Department approval.

I 20.2.2 All procedures manual revisions shall be submitted to the Division j for prior approval.

l 20.2.3 The licensee shall consider proposed procedures manual revisions l

wheneve~ new or revised regulatory guidance requiring such revisions l

is provided to the licensee by the Division.

21.0 POINT SOURCE AIR EMISSIONS CONTROLS Emissions from all activities shall be contrclied in accordance with LC 11.2, and LC 11.4-1 or 11.4-2, and applicable oermits.

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.hmendnent No. 02

.PJri'3 4,. LW4 hge 31 c3 45 22.0 AREA SOURCE AIR EMISSIONS CtWTROJ,4 22.1 RESIDUE STORAGE ARQS The licensee shall implement dust control as apptcreed by the Department and specified in LC 11.2, and 11.4 I or 11.4-2.

22.2 ROADS The licensee shall control dusting from controlled area roads by sprinkling, or chemical crusting agents, and shall limit vehicle speeds to twenty (20) miles per hour.

h K TAILINGS DUSTING 22.3 The licensee shall obtain Department approval for a program, specified in LC 11.4-1 or 11.4-2 by written operating procedures for all conditions, to minimize, to the maximum extent reasonably achievable, dispersion of airborne particulates from the tailings disposal area.

23.0 SOLID WASTE MANAGEMENT 23.1 SUPERVISION The tailings confinement system shall be monitored by persons trained and under the supervision of a professional engineer, or O other engineer, scientist, or person qualified by virtue of training and experience approved by the State as provided in LC 11.1.

23.2 OUALITY CONTROL PLAN FOR TAILINGS The licensee shall strictly adhere to LC 11.4-1 and Annex E, as modified and superseded by LC 11.4-2, at all times, particularly with respect to minimum reserve capacity, freeboard, and beach width, until such time as Final Submittals incorporating all required provisions are approved by the State.

23.3 MAINTENANCE All required Culverts and roads shall be maintained at all times.

maintenance, repair and crocion control shall be undertaken as expeditiously as possible.

23.4 DRAIN SYSTEMS The drain and collection systems shall be monitored and maintained functional at all times. Required maintenance, repair and erosion control shall be as expeditious as possible.

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i Lictense .No. 660-02 Amendment .No. 02 i

April 4,1991 Page 17 et 45 22.5 tilLL REFUSE AND EVAPORATION RESIDUE DISPOSAL Radioactive materials, including insoluble sludges and residues, and waste from construction, operation and decommissioning, may be disposed in tailing pilee 1, 2 and 3, or in a disposal area approved l by the Departoont. All waste materials shall be disposed in accordance with LCs 11.1 through 11.4.

23.5.1 Disposal shall not occur within any current or future external dike l l

of the tallinge ponds; and 23.5.2 The materials shall be disposed in a ranner which minimizes void spaces and future settling abnormalities.

23.6 TOWN RESIDUES AND CONTAMINATED MATERI %

All contaminated materials on licensee-controlled property at Uravan shall be disposed in accordance with the detailed requirements and the schedule in LCs 11.1 through 21.4.

24.0 LIOUID WASTE KANAGEMENT l

The licensee shall meet the following requirements not inconsistent l with LC 11.1.

24.1 consistent with LC 11.1, the licensee shall not discharge radioactive materials or toxic pollutants to SURFACE WATERS. j 24.2 The licensee shall not allow significant pollution to migrate to GROUND WATERS beyond the limited area specified in LCs 11.1 through 11.4.

24.3 The licensee shall control, by diversion or catchment, all SURTACE BUN 0FF duw to a 10-year, 24-hour precipitation event to or from all facilities er areas, as provided by LCs 11.1 through 11.4.

24.4 The licensee shall prepare CONTINGENCY PLANS, including in these corrective action plans remedial measures approved by the Department and specified in LCs 11.1 through 11.3, for any situation in which ongoing seepage threstens degradation of surface and ground waters.

l 24.5 The licensee shall provide by March 31st of each calendar year an updated water balance analysis of all inflows and outflows which are l

occurring and/or may be expected to occur.

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License No. 660-02 -

Amendment No. 02 April 4, 3931 Jage 13 of <45 25.0 TRANSFER OF CONTAMINATED MATEW1 %E 25.1 MILL TAILINGS Mill tailings, other than samples for laboratory analysis or research, shall not be transferred to or from the site without specific prior approval of the Department obtained through application for amendment cf this license. The licensee shall maintain a permanent record of all transfers made under the provisions of this condition.

25.2 CONTAMINATED ITEMS The licensee shall release contaminated equipment, packages (including product) or materials from controlled areas for saic, repair, reuse, resale or disposal only after documented radioactive decontamination meeting the requirements offthe Department, as detailed in Annex C to this license or required pursuant to 6 CCR 1007-1-3.24. Procedures for monitoring filled barrels of U3 Og approved by the Department are to be included in LC 11.2 and/or LC 11.4-1 or 11.4-2.

26.0 GENERAL SPECIFICATIONS FOR INSPECTION AND MONITORING 26.1 RECORDS 26.1.1 Consistent with LC 11.1, the results of sampling, analyses, surveys, instrument calibrations, inspections and audits, employee training, as well as any related reviews, investigations, and corrective actions shall be documented and stored onsite.

26.1.2 All such documentation shall be retained and archived until other disposition is authorized by the Department. Personnel exposure records shall be preserved indefinitely.

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26.2 LOWER LIMITS OF DETECTION 26.2.1 The licensee shall follow the lower limits of detection (LLDs) contained in Annex D for the analysi a of samples collected pursuant to LCs 27 and 28. If the licensee as using other LLDs, such LLDs shall be submitted to the Depa-Laent for review and approval and specified in LC 11.4-1 or 13.4-2.

f 26.2.2 If actual concentrations being measured are sufficiently higher than the lower limitr of cetection specified in LC 26.2.1, the sampling and analysis procedures need only be adequate to measure the actual l

concentrations. In such cases, the standard deviation estimated for 1

'vr,'rbility due to random error of the analysis shall be no greater te t/ con percent (10%) of the measured value.

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1 M uraeIfo. 660-02 Anemdwent No. 02

Agn12 4, :1991 Jage 19 af 45 26.3 OUALITY ASSURANCE /OUALITY CONTROL 26.3.1 The licensee shall maintain a quality assurance / quality control program approved by the Department and specified in LC 11.4-1 or 4 11.4-2.

26.3.2 NRC Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment", as revised, may be followed by the licensee; or the licensee's specifications may provide for an equivalent quality assurance program.

26.4 EOUIPMENT AVAILABLE j

The inventory of monitoring equipment shall be such that operable and calibrated units are always on hand. lI 26.5 CALIBRATION OF EOUIPHENT The licensee shall calibrate all radiation monitoring and sampling ,

equipment after repair and, unless otherwise authorized by the l Department, at least as frequently as the manufacturer's suggested interval, or semiannually if no interval is ag ecified. Also, a check source shall be used to assure that lation detection instruments are operating properly before each use. ,

27.0 PERSONNEL AND FACILITY MONITORING 27.1 Consistent with LC 11.1, the licensee's personnel and f acility monitoring program shall be sufficient to enable the Department to estimate maximum potential occupational dose commitment and to demonstrate compliance with 6 CCR 1007-1-4, and shall bei 27.1.1 As in the procedures manual (Lc 11.2) required by LC 20, as modified by this LC 27; 27.1.2 Revised as necessary in accordance with LC 20.2.

27.2 The RESULTS of personnel and facility monitoring required by LC 27 shall be included in the report required in LC 30.

27.3 PERSONNEL MONITORING 27.3.1 Control badges shall be kept in a background location.

27.3.2 All users of radioactive materials described in LC 6.1.1 and 6.1.2 must be equippe with personnel monitoring devices capable of d

detecting both gamma and neutron radiation.

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Lheenke No. 660-02 .

Amendeccat so. 02 Apri3 4,. 3791 Page 23 cd 45 27.4 BIDASSAy 27.4.1 ,The licensee shall comply with the program as in the procedures manual approved by the Department and NRC Rcgulatory Guide 8.22

" Bioassay at Uranium Nills" (Revision O or as subsequently revised),

unless other conditions of this license or LC 11 are more restrictive, and the following:

Urinalysis for uranium shall be performed for employees assigned to Specimers Radiation Work Permit activities exceeding one' work day.

shall'be collected as close as is reasonably possible to the per' rht 4 beginning 48,. hours and ending 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after the last exposure.

measurement sensitivity shall be 5 ug/l or less. A special urinalysis shall also be performed if there is any reason to suspect an inhalation exposure to yellowcake exceeding 40 x 10-10 uci-br/ml in a period of one work week or to ore dust exceeding 520 x 1010 uCi-hr/ml. in a period of one calendar quarter. The licensee shall make a formal documented evaluation if bioassay measurements exceed any of the following criteria:

27.4.1.1 The urinary uranium concentration exceeds 30 ug/l for any two consecutive sampling periods.

d 27.4.1.2. .The urinary uranium concentration for any measurement excee s 80 ug/1.

27.4.1.3 Action levels based on bioassay measurements shall be in accordance with Tables 1 and 2 of NRC Regulatory Guide 8.22.

In addition, all bioassay results shall be evaluated and acted upon by the RSO and appropriate licensee officials.

27.4.2 Urinalysis results exceeding 15 ug/l shall be reported to the RSO within 20 days of specimen collection.

27.4.3 Urinalysis results exceeding 30 ug/l shall be reported immediately to the RSO by telephone.

27.4.4 Prevention of specimen contamination shall be in accordance with Section C.6 of NRC Regulatory Guide 8.22.

27.4.5 The licensee shall implement a documented quality control program for urine specimers thet includes background samples, blanks, and spikes and also criteria for requiring repeat collection and analysis.

27.4.6 A baseline trine sample shall be obtained from any new worker who will be subject to urinalysis, prior to start of work.

27.5 MILL AIR SAMPLING !

The licepeee shall conduct an air sampling program to assess airbornc radioactivity concentrations to which employees may be exposed, as follows:

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l' 3.1 cense'so. 660-02 Ancz&nst No. 02 April 4, 1991 Page 41 of 45

b. Provide a detailed health and safety analfsis which reflects that.the >esidual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment or scrap, are unlikely to result in an f l unreasonable. risk to the health and safety of the public. !

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Prict to release of premises for unrestricted use, the licensee f 5.

shall make a. comprehensive radiation survey.which establishes that contamination is within the limits specified in Table I. A copy i of the survey report shall be filed with the Radiation Control !

Division, Colorado Department of Health. The survey report shall: I i

a. Identify the' premises. I J b. Show that reasonable effort has been made to eliminate ,

i residual contamination. a

c. Describe the scope of the survey and general procedures

' followed.

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d. State the finding of the survey in units specified in the instruction. I f

I Following review of the report, the Department will visit the facilities to )

confirm the survey.

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2icens.e Jir. 660-02 Jamersisent No. 02 l AJc52 4, 1991 Tkyr 42 of 45 TABLE Is ACCEPTABLE SURFACE CONTAMINATION LEVELS

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bd f be f NUCLIDES

AVERAGE bc f MAXIMUM REMOVABLE Alpha emissions from 1,000 dpm U-nat, U-235, U-23P, 5,000 dpm 15,000 dpm and associated decay per per per 100 cm2 100 cm 2 100 cm 2 products 100 dpm 300 dpm 20 dpm Alpha emissions from Ra-226, Ra-228 per per per Th-230, Th-228, Ac-227 100 cm2 100 cm2 100 cm2 1,000 dpm 3,000 dpm 200 dpm Alpha emissions from Th-nat, Th-232, per per "' per Ra-223, Ra-224, U-232 100 cm2 100 em2 100 em2 Beta-gamma emitters 5,000 dpm 15,000 dpm 1,000 dpm (nuclides with decay modes other than alpha z

per per per emission or spontaneous 100 cm2 100 cm2 100 cm2 flusion) except others noted above.

Where surface contamination by both alpha and beta / gamma-emitting nuclides exists, the limits established for alpha and beta / gamma-emitting nuclides should apply independently, b As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

e Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object.

d The maximum contamination level applies to an area of not more than 2

100 cm ,

The amount of removable radioactive material per 100 pm 2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.

When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.

I The average and maximum radiation levels associated with surface contamination resulting from beta / gamma emitters should not exceed 0.2 mrad /hr at i em and 1.0 mrad /hr at J cm, respectively, -, measuredowners...

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License No. 660-02 Amendment No. 02 April 4, 1991 Page 43 of 45 Annex D Lower Limits of Detection (LLD) for Sample Analysis l U-natural, Th-230, Ra-226 in air 1 x 10 16 uci/ml Pb-210 in air ' 2 x .10- 15 uci/ml Rn-222 2 x 10- 10 uci/ml U-natural, Th-230, Ra-226 in water 2 x 10-10 uC1/ml Po-210 in water 1 x 10 9 uCi/ml

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Pb-210 in water 1 x 10-9 uci/ml .

U-natural, Th-230, Ra-226, Pb-210 in soil and sediment (dry) 2 x 10-7 uci/g U-natural, Th-230 in vegetation, food, and fish (wet) 2 x 10- 10 uci/g I

Ra-226 in vegetation, food, and 5 x 10- 11 uci/g fish (wet)

Po-210, Pb-210 in vegetation, food, 1 x 10- 9 uci/g and fish (wet)

Total alpha in air 1 x 1016 uci/ml Total beta in air 1 x 10-1S uci/mi Exposure rato 2ur/hr 1

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Licer.we No. 650-02 Amendmuzt Db. '02 April 4,1993 Page 44 of 45 Annex E Monitoring Requirements for Club Mesa Repositories consistent with the Consent Decree and LC 11.1 and as stated in LC 11.6, the monitoring program for Club Mesa involves the surveillance of Tailings Piles 1,'2, and 3, the crystal disposal area, and conditions beneath the mesa. Reporte on the Club Mesa monitoring program will address the key factors and components described in the following sections.

IA.ilinos Ponds 1, 2, and 3 The monitoring program for the Club Mesa TLilings Piles is designed to provide information on the phreatic levels in the pile, to ascertain settlement rates cnd amounts, provide data on stability and erosion of the protective. cover, cnd to determine the rate and impact of cliff retreat. To determine these factors the tailings pile monitoring system is divided into four parts: 1) piezometers, 2) surface movement monuments, 3) erosion monuments, and 4) visual inspection / aerial photography. Ground water monitoring for Club Mesa is described in LC 11.1 and includes seepage monitoring for Tailings Piles 1, 2, and 3.

Pierometers: Piezometers are or are to be installed within the tailings piles ct the locations shown in Drawing C-102 (00-831216-03) or alternative locations authorized in LC 11.3. These piezometers are to be designed in cecordance with information provided in drawing C-107 (00-831216-03).

Generally, the piezometers will monitor the change in fluid levels in the piles at the crest of the rock fill buttress, on the embankment face, and on the retirement crest.

Subject to final approval in LC 11.3, eleven (11) piezometers will be used on

' Tailings Pile 1-2 and nine (9) piezometers will monitor Tailings Pile 3.

Readings from the piezometers will be at least every year until the tailings piles no longer contain free liquids as determined by two successive readings.

Data collected from the piezometers should be used to aid in estimating i tailings pile settlement (consolidation) and determining when the toe drain cystem can be abandoned.' Additionally, the monitoring of the piezometers f chould be used to determine if the reclamation plan is operating as proposed. l When all necessary information has been obtained, the piezometers should'be properly plugged with a bentonite slurry, surface Movement Monuments: Subject to final approval in LC 11.3, surface ;

movement monuments are to be installed on the top and sides of the tailings ponds according to Drawing C-102 and designed according to Drawing C-107 (00-831216-03). An additional monument will be used to more fully establish the post-reclamation settlement, erosion, and to determine the amount of movement of the embankments.

Thirteen (13) monuments are set for Tailings Pile 1-2 and ten (10) monuments for Tailings Pile 3. These locations are at each piezometer installation as a well as at additional locations on the reclaimed surface. Monuments currently in place will continue to be read at least every six months until the final j reclamation cover is placed. l

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License No. 660-02 Amendment 14o. 02 April 4, 1991' Page 45 of 45 After final reclamation,:the monuments will_be surveyed for horizontal and

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. vertical movemer.ts on an annual basis until the accumulated settlement is

.within 10% of total settlament' estimated by the monitoring program. Data

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. collected from the surface monuments should be used to determine the integrity

-and effectiveness of,the reclamation cover by ascertaining the amount of

' settlement, erosion, and embankment movement.

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trosion Monuments:' Erosion monitoring monuments will be. installed along the mesa rim and in gully areas according to Drawings..c-102 and c-107

~( 00-831216-03).. These erosion monuments will be us'ed to determine the amount and rats of gully erosion and cliff retreat in the subject area.

Fourteen (14) erosion monuments will be constructed, most of.which will be

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near the mesa rim. These monuments'will be surveyed and their location described.- Additionally, the proximity to the cliff edge and other pertinent observations will-be described and recorded.- The monuments will be observed visually and' surveyed, if necessary, during the long-term monitoring program.

From these observations, the' rate of cliff retreat should be determined.and potential impact.on the integrity of the' disposal area assessed.

Visual Insoection and Aerial Photooraohva The surface monuments and reclamation cover will be visually inspected on an annual basis after reclamation has been completed. -Detailed (large scale) stereoscopic serial-

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photographs of the tailings piles will also be taken after completion of the reclamation cover and drainage channels. ' Additional aerial photographa will be required only if the visual inspection indicates such a necessity.

In conjunction with observation of=the surface monuments and reclamation cover, .the' runof f collection and diversion channels will beTheseobserved for observations evidence of erosion or debris and sediment accumulation.

will be ade at the same time as the monitoring of the erosion monuments.

_ crystal Disposal Area

. Final _ plans and' specifications in Lc 11.2 and LC 11.3 for the new dinposal area for crystals located on Club Mesa will include a method including to determine the settlement, dissolution, and erosion of the reclaimed area, ,

number and location of surface monuments, erosion monuments, aerial (

photographs and visual inspection schedule.

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1 UNETCO MINERALS CORPORATION 1600 UTE AVENUE GRAND JUNCTION, COLORAL. 81502 Pursuant to the Radiation Control Act, Title 25, Art.icle 11, C.R.S. (1989, Replacement Volume) as amended, and the State of Colorado " Rules and Regulations Portaining to Radiation Control", Part 3, and in reliance on statements and representations heretofore mtde by the licensee designated below, COLORADO RADIOACTIVE MATERIALS LICENSE NO. 660-02 IS HEREBY AMENDED IN FULL, l

l authorizing such licensee to receive, possess and transfer the radioactive material (s) designated below and to use such radioactive materials for the purpose (s) and at the place (s) designated below. This license is subject.to all applicable rules, regulations, and orders now or hereafter in effect of the Colorado Department of Health (the " Department") and to any conditions.

specified below.

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! 1.0 LICENSEE NAME l

! UMETCO MINERALS CORPORATION 2.0 LICENSEE ADDRESS Recional Address l

1600 Ute Avenue l P.O. Box 1029 Grand Junction, CO 81502 i

Local Address I P.O. Box 860 Nucla, CO 81424 660-02 AMENDMENT NUMBER O2 3.0 LICENSE NUMBER f

4.0 EXPIRATION DATE December 31, 1991 l

5.0 REFERENCE NUMBER SUA-673 i

AUTHORI ZATIONS 6.0 RADIOACTIVE MATERIALS 6.1 Matural uranium and radioactive decay products of uranium, in particular uranium-238, uranium-234, thorium-230, radium-226, radon-222 and progeny.

6.2.1 Cesium-137.

o 6.2.2 Americium-241:Be.

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License ss.. 660-02 .

Amendnent so. 02 April .4, 3rf91 Page 2 of 45

- 7.0 CHEMICAL AND/OR PHYSICAL FORM 7.1 Milling and cleanup residues,. including tailings, evaporation crystals and sludges; milling refuse, including decommissioned equipment and building materials.

7.2 Four (4) Sealed' Sources:-

- 7.2.1 Troxler Drawing No. A-102112 (2 sources);

7.2.2 Troxler. Drawing No. A-102451 (2 sources).

8.0 MAXIMUM OUANTITY LICENSEE MAY POSSESS AT ANY ONE TIME 8.1 '12,500,000 dry tons (11,000,000 metric tonnes) of tailing or other residues; unspecified quantities of milling refuse; 900,000 dry tons-of Naturita materials.

8.2.1 Two (2) sources, no single source to exceed 9 millieuries of Cesium-137; 8.2.2 Two-(2) sources, no single source to exceed 44 millicuries of Americium-241:Be.

9.0 AUTHORIZED USES 9.1 The licensee is authorized to store and dispose cres, milling residues, tallings, and refuse consistent with the Remedial Action Plan to which reference is made in LC 11.1.

The licensee is authorized to receive, own, possess, and permanently

-' dispose of radioactive materials removed from the Naturita UMTRCA Title I site at the Uravan facility.

In addition to all other requirementa of.the license and this license amendment, the licensee shall receive, possess, and dispose of the Naturita tailings in accordance with final plans and specifications to be submitted to and approved by the Radiation Control Division pursuant to LC 17.4,-in accordance with the Consent Decree and RAP (LC 11.1), in accordance with any applicable requirements of the Remedial Action Plan for the remediation of the Naturita UMTRA site and in accordance with LC 11.7.

9.2 To be used in Troxler 3400 model series moisture / density gauges to determine the moisture content end density of soils and construction-materials.

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License No. 660-02 Amendment No. 02 April 4, 1991 l

Page 3 of 45 10.9 AUTHORIZED PLACE OF USE l 10.1 The licensee's uranium processing facilities at Uravan in Montrose l County, Colorado, located as follows:

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.Those portiona of TowrShip 47 North, Range 17 West, New Mexico Principal Meridian, Section 4, and Township 48 North, Range 17 West, New Mexico Principal Meridian, Sections 28, 29, 33 and 34, delineated in Annex A, and any other portion of the Uravan Facility, as defined ~in the Consent Decree, to which reference is made in LC 11.1. .

10.2 Radioactive materials described in LC 6.1.1 and 6.1.2 may be used at temporary job sites'of the licensee anywhere in the State of Colorado where the State of Colorado maintains jurisdiction for regulating the use of radioactive material.

LICENSE CONDI TIOFS (LCs) 11.0 LICENSEE PROPOSALS AND COHMITMENTS (" REFERENCED DOCUMENTS")

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Except as specifically provided otherwise by this license, the licensee shall possess and use radioactive materials described in

' Items 6, 7, 8 and 9 of this license in accordance with statements, representations, and procedures contained in the licensee's:

l-11.1 Uravan Uranium Milloite Remedial Action Plan (hereafter " RAP") which is attached as Appendix I to the Consent Decree, Order, Judgement, and Reference to a Special Master. Filed in the United States District Court, Civil Action No. 83C2384, " State of Colorado, Plaintiff, vs. Union Carbide Corporation, a New York Corporation, and Umeteo Minerals Corporation, a Delaware Corporation, Defendants" (hereafter " Consent Decree").

11.2 Procedures Manual for Plant Operations at Uravan, dated March 31, 1982, as subsequently revised pursuant to LC 20.

.11.3 Final Plans and Specifications submitted in accordance with LC 11.1, when such Final Plans and Specifications become Final Submittals as j defined by the Consent Decree.

1 11.4-1 Procedures Manual for Environmental Monitoring at Uravan, dated I March 31, 1982, as subsequently revised pursuant to LC 20. l I

j 11.4-2 When the Quality Control / Quality Assurance, Monitoring and Performance Evaluation Plan (Quality Plan) submitted in accordance with LC 11.1, becomes a Final Submittal, as defined by the Consent Decree, the Final Submittal shall replace in full the Procedures Manual for' Environmental Monitoring at Uravan designated as LC'll.4-1.

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Lhcew*e M. 660-02 l

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Page 4 of 45

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l 11.5 Financial assurance requirements stated la sectiom ' XVII of the '

Consent Decree, which shall, upon becoming fully ef fective, dated September replace in full the Reclamation Surety Agreement, 22, 1981, as revised pursuant to LC 32.

11.6 Long term monitoring and maintenance requirements as stated in Section IV(G) of the Consent Decree, as may be revised pursuant to LC 33.

Letter of April 20, 1987 form Roger Jones to Albert J. Hazle, with 11.7 enclosure; letter of July 20, 1987 from Roger to Edd Kray, with enclosures.

11.8 Amendment application dated October 22, 1990, as revised December 6, 1990.

e 12.0 CErCRAL CONDITIONS 12.1 DEFINITION OF TERMS 12.1.1 Unless otherwise provided in this license, terms used herein are as defined in the State of Colorado " Rules and Regula*. ions Pertaining 1007-1-1 et seq., hereafter the to Radiation Control" (6 C.C.R.

" Radiation Regulations").

12.1.2 The terms used herein are to be interpreted in a manner consistent with the consent Decree and LC 11.1.

12.2 OBTAIN PERMITS OF OTHER AGENCIES Prior to beginning any new construction or new operations, or any other activities authorized by this license, the licensee shall obtain all applicable permits and other authorizations of local, state and federal agencies having authority over health, safety, and l environmental protection aspects of the activities authorized by l Items 6, 7, 8, and 9 of this license. The licensee shall maintain in force such applicable permits from beginning to end of the project.

The licensee shall inform the State through'the On-Site Coordinator (eg that term is defined in paragraph III(h) of the Consent Decree, hereafter 'OSC") and provide a copy to the Radiation Control Division of the Department (hereinafter referred to as the

" Division") thirty (30) days prior to, or as soon thereafter as it is available but in no event later than the date of filing of, any application to permitting agencies for modification or renewal of such permits or other authorizations.

12.3 COMPLY WITH PERMTTS Within the scope of applicable statutes and lawful regulations thereunder, the licensee shall operate in full compliance with the

' requirements of each other division of the Department.

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Licenae Wo. 660-02 Amendment No. 02 April 4, 1991 Page 5 of 45 l

Violation of tych other requirements shall not by itself constitute violation of this license, unless the Department makes an independent finding of violation of the Radiation Regulations or a condition of this license other than this LC 12.3.

12.4 STATUS OF REFERENCED DOCUMENTS

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Proposals and commitments in referenced documents are in effect license conditions. l i

Where the word "will" or "should" is used in the documents referenced in Lc 11 above, it shall denote a requirement.

Where statements in referenced documents conflict, the most recent !

document shall prevail unless the Division determines otherwise.

The Radiation Regulations shall control provisions of the referenced documents which conflict with said Radiation Regulations unless the provisions of the referenced document are more restrictive than the Radiation Regulations.

A requirement pursuant to revised regulations or policy shall be ;

i considered a modifications of this license for the purposes of judicial review under Colorado law.

12.5 SEVERABILITY If any part of the Radiation Regulations, Department or Division policy, or this license is held invalid, the remainder shall not be affected.

12.6 HAZARDOUS RELEASES By this License, the Department does not permit, authorize, j concur in, or otherwise approve of, the release or threatened release of hazardous substances, pollutants, or contaminants into the environment, except as specifically authorized by this license. l

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12.7 WRITTEN APPROVAL I

12.7.1 . Required Department " acceptance", " approval", " authorization", or

" concurrence" shall be obtained in writing from the Division, unless l otherwise provided in the Radiation Regulations, or Department or a y

Division policy. :

q When the Division reasonably and routinely consults with another l

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12.7.2 State party, including, but not limited to, the State Archaeologist, l

Engineer and Colorado Geological Survey, the licensee shall .

I facilities, f 12.7.2.1 Permit such party to inspect designated documents, or sites; s .

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1 15cenae No. 660-02 Am' ecd > ten No. 02 Ageil' 4, 19.1:1 7s;e 6 ca 1:3 12.7.2.2 Submit designated documents to the party ?.ce review; and 12.7.2.3 conform applications and supporting docunremu to the written guidelines to or of such party as determined by the Division to be applicable to the pro,ect.

4 12.8 LICENSE CONDITIONS MODIFY REFERENCED DOCUMENTS The following license conditions, to the extent such conditions are not inconsistent with LC 11.1, modify and add to commitments in the documents in LC 11.

13.0 OWNERSHIP AND CONTROL 13.1 EVIDENCE OF TITLE The licenses shall provide to the Division,7vidence of any change in title to the properties described in LC 10 and Annex A.

13.2 NOTIFICATION OF INTENT As required by Section XII of the consent Decree, the licensee shall provide the Division with ninety (90) days advance notification of any proposed change in property ownership or control of the properties described in LC 10.0 and Annex A.

13.3 DEPARTMENT AUTHORIZATION REOUTRED 13.3.1 No transfer of title to any portion of the licensed site may be made at any time without prior written authorization from the Division.

Any such transfer shall be in accordance with 6 CCR 1007-1-3.15.2 unless otherwise authorized by the Division.

13.3.2 No portion of the licensed site may be vacated without notification in accordance with RH 4.33 and prior written authorization from the Division.

13.4 TRANSTERABIL7H ownership or control of the tailings confinement area shall be such that jurisdiction over the property may be readily tran,sferred to the State or federal government under the provisions of 6 CCR 1007-1-1 31 3.gg.

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License No. 660-02 Amendment No. 02 April 4, 1991 Page 7 of 45 !

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13.5 BANKBUPTCY The licensee shall notify the Department, in writing, immediately f following ,the filing of a voluntary or involuntary petition for bt.nkruptcy under any Chapter of Title 11 (Bankruptcy) of the United State Code by or against:

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a. The licensee;

b. An entity (as that term is defined in 11 U.S.C 101(14)) l controlling the licensee or listing the license or licensee as property of the estates or

c. An affiliate (as that term is defined in 11 U.S.C. 101(2)) of the license.

l This notification must indicate the bankruptcy court in which the petition for bankruptcy was filed and the date of the filing of the petition. ,

14.0 USERS 14.1 AUTHORIZATION j

The licensee shall submit resumes and documentation of users' training and experience to the Department and obtain written authorization from the Department for each user.

14.2 LIII

.The licensee shall maintain throughout use of radioactive materials authorized by this license at least two (2) trained, quati.fied, and authorized users, to include the Radiation Safety Officer (RSO).

14.3 AVAILABILITY An authorized user shall be on hand at the f acility or immediately available at all times during f acility operation.

14.4 MINIMUM m HNICAL OUALIFICATIONS FOR RADIATION PROTECTION OFFICER The RSO shall have at least a B.S. degree in radiological or environmental sciences, or a related field, from an accredited college. The RSO shall have intensive formal training of at least one year duration with a minimum of one week of the course specifically applied to health physics problems at radioactive materials facilities. The RSO shall have at least one year of

" hands on" experience in radiation safety and occupational health in a uranium mill or related facility, at least six months of this experience at the supervisory level. Refresher training in health physics (a minimum of 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months ) is required at least every two years.

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31 unas Ab. GGO-02 .

.%cendmend No. 02 Ayr 22 4, 1931 Fape a o3 45 A Master Degree (or a more advanced dagrete) sucy be substituted for

. the two year intensive training req;ireneet :a3cv e.

With Department approval, experience e.sy also be redostituted for training requirements.

14.5 DESIGNATED ASSISTANTS TO TIIE RADIATION _ SAFETY OFFlf:L8 including The.RSO may delegate to trained assistants functions, required by this license quality assurance / quality control measures, for which a written procedure is included in LCs 11.1 through 11.4, so long as quality is maintained and documented and minimum qualifications for health physics technicia,s and other members of the radiation safety staff are specified in Lc 11.2.

14.6 NON-SAFETY ASSIGNMENTS The licensee's radiation safety and environmental control staff shall fulfill requirements of this license prior to being given assignments not related to health, safety and environmental protection, unless otherwise authorized by the Department.

15.0 EMERGENCY ACTIONS 15.1 REPORT OF ACCIDENTS The licensee shall, immediately upon discovery, notify the OSC and Director, Radiation Control Division, Colorado Department of Health, 4210 East lith Avenue, Denver, Colorado 80220 by telephone (303-331-8480, or 370-9395 after office hours) and in writing, of any failure or imminent threat of failure in any process, diversion,

' or retention system which results or may resultThis in arequirement release of is radioactive material into uncontrolled areas.

in addition to the requirements of 6 CCR 1007-1-4.29 and -4.31. )

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15.2 EMERGENCY RESPONSE CAPABILITY l i

The following shall be approved by the Departments

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15.2.1 Warnino System

The licensee's system for warning in the event of a tailings impoundment break shall be as specified in LCs 11.2 through 11.4.

Liquid emergency catchment basins shall have alarms tested at a frequency specified in LC 11.2, and LC 11.4-1 or 11.4-2.

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- Licanse No. 660-02 Amendment No. 02 April 4, 1991 Page 9 of 45 15.2.2 Reeponse Plans The licensee r5all use plans, approved by the Department in conjunction with such agencies as the Division of Disaster Emergency Services and specified in LC 11.2, and LC 11.4-1 or 11.4-2, to respund;to accidents and fires in the mill complex and in transportation of radioactive material. These plans shall include provisions for prompt retrieval of any radioactive material released to uncontrolled areas by rupture of any storage or disposal area or pipeline.

15.2.3 Eauinment The licensee shall have available, every calendar day all. year, sufficient personnel, equipment and supplies to respond to accidents, fires, and other emergencies in accord with the plans specified in LC 11.2, and LC 11.4-1 or 11.4-2, as approved by the Department.

15.2.4 Trainino The licensee shall maintain a documented emergency response training program to insure that sufficient. trained persons are always available.

16.0 FACILITY OR PROCESS ADDITIONS OR CHANGES 16.1 The licensee shall provide the Department thirty (30) days advance notification of any proposed addition or change to a facility or process which potentially has a significant health, safety or environmental protection aspect. Potential public health or eavironmental impacts not previously assessed, or greater than previously assessed, require rotification.

16.2 If the Department makes a preliminary finding of significant health, safety, or environmental impact, the licensee shall provide the Department with a written assessment of impacts resulting from the facility or process addition or change.

16.3 If the Department, upon review of the licensee's written assessment, determines that written approval or a license amendment is required, the licensee shall apply for and obtain the prescribed authorization prior to modifying the facility or process feature.

16.4 The licensee shall provide to the Department an acceptable plan of action to eliminate or effectively control any unexpected harmful ef fects or irreversible damage detected during operation and not otherwise identified in LC 11 or other license conditions.

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licence %c. 660-03 ,

Amendnent mo. 02 April 4,1991 Tage 10 cs! 45 17.0 DESIGN AND ENGIKEERING 17.1 GENERAL CONSTRUCTION REOUIREMENTS All construction related to Items 6, 7, 8, and 9 of this license

'shall be in accord with detailed plans approved by the Department (and such other agencies as the Department designates) as specified in LC 11 and as follows:

1 17.2 SUPERVISION l The licensee shall_ supervise all licensed construction activities in accordance_with the regulations which govern the activities of the State Engineer and such additional requirements as are determined to be necessary pursuant to the consent Decree and applicable State of Colorado rules and regulations.

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17.3 FINAL PLANS AND SPECIFICATIONS The licensee shall make available fifteen (15) copies of the detailed Final Plans and Specifications for all work for distribution by the Department to such other agency representatives l

as the Department designates.

! 17.4 . REVISED FINAL PLANS AND GPECIFICATIONS The licensee shall submit, within 45 days of receiving notification as the successful bidder for disposal of the Naturita materials, revised plans and specifications for Tailings Piles 1-2 and the Burbank Repository.

17.5. 'The licensee shall provide written confirmation of the average i radium concentration of the Naturita tailings and earthen materials at the time of submittal of the revised plans and specifications required by Lc 17.4. I 18.0 GENERAL REOUIREMENTS FOR ACTIVITIES ]

1 18.1 FACILITY STATUS .

i The licensee shall obtain prior author,1 ation by license amendment from the Department at such time as any part of the Uravan Facility is to change from stand-by status.

18.2 PRODUCTION RATE The licensee shall not store or crush ores or refine and produce uranium product without prior authorization by license amendment from the Department.

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License No. 660-02 Amendment No. 02 l

April 4, 19P1 Page 11 of 45 18.3 GENERAL MAINTENANCE

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All mill, storage, processing, t.J maport, impoundment, containment, monitoring, and safety systems which shall be operated pursuant to this License shall be maintained in good working order. The licensee shall document a system of routine preventive maintenance so that safety-related equipment is checked for proper working order according to a regular schedule.

18.4 ALARA fAS LOW AS REASONABLY ACHIEVABLE 1 The licensee shall keep exposures as low as reasonably achievable (ALARA) as provided in LCs 11,1, 11.2, and 11.4-1 or 11.4-2. Final Submittals, as defined by the Consent Decree, shall conform to U.S.

Nuclear Regulatory Commission Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Exposure as Low as j

Reasonably Achievable", except as authorized by the Department. j l

The ALARA program performance shall be reviewed monthly by + 4 Radiation Safety Officer (RSO) in a monthly written report to the manager.

l 18.5 KANAGEMENT l

The licensee shall provide, by March 31st of each calendar year, J updated details of the authority and responsibility of each level of management, noting any changes.

18.6 OFF-SITE DOSE LIMITS 1 18.6.1 Limits ,

The licensee shall conduct activities in such a manner as to provide reasonable assurance that the annual radiation dose equivalent of 25 millirems to the whole body, 75 millirems to the thyroid, and. l 25' millirems to any other organ of any member of the public is not exceeded as the result of exposures of radioactive materials resulting from planned discharges of radioactive materials, radon and its progeny excepted, to the general environment.

18.6.2 Performance Determination of performance in relation to LC 18.6.1 shall be based l upon the annual reports required by LC 30.

18.6.3 Specific Recuirements 18.6.3.1 The licensee shall insure, and specify in LC 11.4-1 or 11.4-2, a method to document that no garden produce is grown for human consumption on licensee-controlled property at Uravan.

18.6.3.2 The licensee shall not permit any building or improvement at the Uravan Facility to be constructed for or occupied as a residence.

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2aretuv No. 660-02 kine.thnent :00. 02 hysay 4, 3950 hqe n vi &&

18.7- BASELINE INFORRATION For the purpose of reviewing site cleanup arh neriamation, the following shall be included as baseline referencer.

18.7.1 Environmental Report, dated Auv a. 31, 1978 for all baseline data and analyses, in particular Section 2, pages 29-30, 43-50,74-102, 109-113; Section 3, pages 32-34, 47-49, 60-63; section 5, pages 9-10; Section 6, pages 20-21; Section 7, page 35; Appendices c & D; 18.7.2 Updated Environmental Report, dated March 31, 1982; 1986.

18.7.3 ERI Logan, Inc. Reports, Vols. I and II, August II, 18.8 LFAK TESTING 18.8.1 Radioactive materials authorized in LC 6.152 and 6.1.2 shall be tested for leakage and/or contamination at intervals not to exceed six (6) months.

18.8.2 In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, a sealed source received from another person shall not be put into use until tested.

18.8.3 The test shall be capable of detecting the presence of 0.005 microcurie of radioactive material on the test sample. The test sample shall be taken f rom the sealed source or from the surf aces of the device in which the sealed source is permanently mounted or stored on which one might expect contamination to accumulate.

Records of leak test results shall be kept in units of microucuries and maintained for inspection by the Department.

18.8.4 If the test reveals the presence of 0.005 microcurie or more of removable contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired or to be disposed of in accordance with the Radiation Regulations. A report shall be filed within 5 days of the test with the Director, Radiation control Division, Colorado Department of Health, 4210 East lith Avenue, Denver, Colorado 80220, describing the equipment involved, the test results, and the corrective action taken.

18.8.4 Tests for leakage snd/or contamination shall be performed by the Radiation Safety Of ficer, or by other persons specifically authorized by the U.S. Nuclear Regulatory Commission or an Agreement State to perform such services.

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License No. 660-02 Amendment No. 02 April 4, 1991 I Page 13 of 45 18.9 TRANSPORTATION OF MATERIALS 18.9.1 The licensee may transport : sdioactive material or deliver radioactive material to a carrier for transport, in accordance with the provisions of RH 17 of the State of Colorado Rules and Regulations Pertaining to Radiation Control, "TranspoiGtion of Radioactive Material".

18.9.2 The transportation of Colorado radioactive materials shall be subject'to all applicable regulations of the Colorado Public I

Utilities commission, Colorado Department of Highways, Colorado Department of Public Safety, Colorado Department of Revenue (Port of i Entry), U.S. Department of Transportation, and other agencies of the Unites States having jurisdiction. When the U.S. Department of Transportation Regulations (Title 49, Chapter I, Code of Federal Regulations) are not applicable to shipments by land of Colorado radioactive material by reason of the fact that the transportation ,

does not occur in interstate or foreign commerce, the licensee must be in compliance with the requirements relating to packaging of the radioactive material, marked in and labeling of the package, l

placarding of the transport vehicle, and accident reporting set forth in the regulations of the U.S. Department of Transportation.

J 18.10 ELEVATION OF TAILINGS PILE 1-2 l The licensee shall not place tailings or other contaminated materials on top of Tailings Pile 1-2 to an elevation greater than 5,550 feet prior to Department approval of a revised written stability analysis (Appendix B of Lc 11.7). i

.19.0 SITE CONTROL AND PERSONNEL SAFETY 19.1 RESPONSIBILITY

.19.1.1 .The Plant Superintendent shall be accountable for safety, security, fencing, posting, and area control. ;

i 19.1.2 The RSO or RSO's designes shall have authority to remove employees '

l from a work environment or suspend the operation in a particular j

mill area if he has determined that a condition exists that would l l likely result in any individual being exposed to radiation that may present an imminent health hazard.

19.1.3 The Plant Superintendent shall act promptly on the recommendations of the RSO or RSO's designee pertaining to radiation safety and !

security.

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License No. 660-02 , l i

Amendment No. 02

. April 4, 1991 Page 14 of 45 19.2 TRAINING 19.2.1 New employees shall not commence work assignments in controlled areas until they have been adequately trained in their assignment and in radiation safety, in accordance with a program approved by the Department and specified in LC 11.2. Such training shall be documented by dates, nature of training, tests and scores, and written ~nowledgment of receipt by employee.

19.2.2 The RSO shall document employee review of (1) procedures applicable to each employee's assignment and (2) provisions of 6 CCR 1007-1-10.

19.2.3 The licensee shall accumulate at least ninety '(90) minutes of training meeting time per year, or alternative amount approved by the Department and specified in LC 11.2, for each radiation worker to review radiation protection topics, documenting employee attendance, and re-train radiation workers annually on current develop tents in radiation safety.

19.3 PROTECTIVE CLOTHING Respirators, gloves, boots, coveralls, helmets, goggles and other protective items shall be used at all times in areas or activities designated by the RSO.

19.4 RADIATION WORK PERMITS The licensee's RSO or RSO's designee shall prepare a Radiation Work Permit, prior to start of any work or maintenance, at any location of the licensed facility or site, which has radiation safety implications and for which no written procedure exists. The

Radiation Work Permit shall specify appropriate radiological controls. The licensee's Radiation Work Permit program shall be included in LC 11.2, as approved by the Department. A copy of all permits shall be retained for no less than five (5) years for inspection by the Department.

19.5 SHOWERS All workers shall shower or monitor head, face, id hands, and 3pm/100 cm 2 , in document absence of contamination exceeding 10s areas or activities where designated by the RSO.

19.6 CONTROLLED AREA RFSTRICTIONS The licensee shall not allow eating and smoking in controlled areas, except in control rooms, offices, and lunchrooms, or other areas designated by the RSO.

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License so. 660-02 Amendment No. 02 l

April 4, 1991 Page 15 of 45 19.7 SECURITY The licensee r>all fence and post the controlled area boundary as specified in LC 11.2 and in accordance with 5 CCR 1007-1-4.14.

19.8 iOSTING EXEMPTION The licensee is hereby exempted from the requirements of 6 CCR 1007-1-4.11 for areas within the exclusion area boundary, provided all entrances to the property are conspicuously posted with

.the sign l

"Any Area or container on this Property May Contain Radioactive Materials."

I 20.0 HEALTH, SAFETY AND ENVIRONMENTAL PROCEDURES MANUAL I

L 20.1 PROVISIONS l

l The licensee shall conduct construction and cleanup operate l

according to (and maintain) comprehensive written health, safety and ;

l environmental procedures manuals, approved by the Department, governing licensed activities, to wit: LC 11.2, and LC 11.4-1 or 11.4-2. The procedures manual (s) shall contain safety, monitoring, decontamination, and emergency procedures, including: l l

20.1.1 Administrative and operating procedures relating to radiological health and safety; 20.1.2 Instructions and precautions to keep exposures ALARA; l 20.1.3 Specific information on analytical equipment, laboratories, and procedures for each aspect of the monitoring program.

20.2 BK?1SIONS 20.2.1 No reduction in monitoring provisions shall be made without Department approval.

20.2.2 All procedures manual revisions shall be submitted'to the Division

.for prior approval.

20.2.3 The licensee shall consider proposed procedures manual revisions whenever new or revised regulatory guidance requiring such revisions is provided to the licensee by the Division. .

21.0 POINT SOURCE AIR EMISSIONS CONTROLS Emissions from all activities shall be controlled in accordance with LC 11.2, and LC 11.4-1 or 11.4-2, and applicable permits.

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License No. 660-02 Amendment No. 02 April 4, 1991 Page 16 of 45 )

22.0 AREA SOURCE AIR EMISSIONS _ CONTROLS \

22.1- RESIDUE STORAGE AREAS The licensee shall implement dust control as approved by the {

Department and specified in LC 11.2, and 11.4-1 or 11.4-2.

22.2 POADS The licensee shall control dusting from controlled area roads by sprinkling, or chemical crusting agents, and shall limit vehicle speeds to twenty (20) miles per hour.

22.3 TAILINGS DUSTING The, licensee shall obtain Department approval for a program, sp4cified in LC 11.4-1 or 11.4-2 by written operating' procedures for all conditions, to minimize, to the maximum extent reasonably achievable, dispersion of airborne particulates from the tailings disposal area.

23.0 ' SOLID WASTE MANAGEMENT 23.1 EERERVISION The tailings confinement system shall be monitored by persons trained and under the supervision of a professional engineer, or other engineer, scientist, or person qualified by virtue of training and experience approved by the State as provided in LC 11.1.

23.2 OUALITY CONTROL PLAN FOR TAILINGE The licensee shall strictly adhere to LC 11.4-1 and Annex E, as modified and superseded by LC 11.4-2, at all times, particularly freeboard, and beach with respect to minimum reserve capacity, width, until such time as Final Submittals incorporating all required provisions are approved by the State.

23.3 MAINTENANCE All required Culverts and roads shall be maintained at all times.

maintenance, repair and erosion control shall be undertaken as expeditiously as possible.

23.4 DRAIN SYSTEMS The drain and collection systems shall be monitored and maintained functional at all times. Required maintenance, repair and erosion control shall be as expeditious as possible.

.. License No. 660-02 Amendment No. 02 April 4, 1991 Page 17 of 45 23.5 MILL REFUSE AND EVAPORATION RESIDUE DISDOSAL

.y Radioactive materials, including insoluble sludges and residues, and waste from construction, operation and decommissioning, may be disposed in tailing piles 1, 2 and 3, or in a disposal area approved by the Department. All waste materials shall be disposed in accordance with LCs 11.1 through 11.4.

23.5.1 Disposal shall not occur within any current or future external dike of the tallings ponds; and 23.5.2 The materials shall be_ disposed in a manner which minimizes void spaces and future settling abnormalities.

23.6 TOWN RESIDUES AND CONTAMINATED MATERIAL All contaminated materials on licensee-controlled property.at Uravan shall be disposed in accordance with the detailed requirements and the schedule in LCs 11.1 through 11.4.

24.0 LIOUID WASTE MANAGEMENT The licensee shall meet the following requirements not inconsistent with LC 11.1.

24.1 Consistent with LC 11.1, the licensee shall not discharge radioactive materials or toxic pollutants to SURFACE WATEEE.

24.2 The licensee shall not allow significant pollution to migrate to GROUND WATERS beyond the limited area specified in LCs 11.1 through 11.4.

~24.3 The licensee'shall control, by diversien or catchment, all SURFACE f' BUNOFF due to a 10-year, 24-hour precipitation event to or from all facilities or areas, as provided by LCs 11.1 through 11.4.

24.4 'The licensee shall prepare CONTINGENCY PLANS, including in these corrective action plans remedial measures approved by the Department i

I and specified in LCa 11.1 through 11.3, for any situation in which ongoing seepage threatens degradation of surface and ground waters.

l 24.5 The licensee shall provide by March 31st of each calendar year an updated water balance analysis of all inflows and outflows which are occurring and/or may be expected to occur. l l

e Licznza No. 660-02 ,

Amendment No. 02 April 4, 1991 Page 18 of 45 25.0 TRANSFER OF CONTAMINATED MATERIALS 25.1 MILL TAILINGS Mill tailings, other than samples for laboratory analysis or research, shall not be transferred to or from the site without specific prior approval of the Department obtained through application for amendment of this license. The' licensee shall maintain a permanent record of all transfers made under the provisions of this condition.

25.2 CONTAMINATED ITEMS The licensee shall release contaminated equipment, packages (including product) or materials from controlled areas for sale, repair, reuse, resale or disposal only after documented radioactive decontamination meeting the requirements Offthe Department, as detailed in Annex C to this license or required pursuant to 6 CCR 1007-1-3.24. Procedures for monitoring filled barrels of U3 Og approved by the Department are to be included in LC 11.2 and/or LC 11.4-1 or 11.4-2.

26.0 GENERAL SPECIFICATIONS FOR INSPECTION AND MONITORING 26.1- RECORDS 26.1.1 Consistent with LC 11.1, the results of sampling, analysos, surveys, instrument calibrations, inspections and audits, employee training, as well as any related reviews, investigations, and corrective actions shall be documented and stored onsite.

26.1.2 All such documentation shall be retained and archived until other disposition is authorized by the Department. Personnel exposure records shall be preserved indefinitely.

26.2 LOWER LIMITS OF DETECTION 26.2.1- The licensee shall follow the lower limits of detection (LLDs)

-contained in Annex D for the analysis of samples collected pursuant to LCs 27 and 28. If the licensee is using other LLDs, such LLDs shall be submitted to the Department for review and approval and specified in LC 11.4-1 or 11.4-2.

26.2.2 If actual concentrations being measured are sufficiently higher than the lower limits of detection specified in LC 26.2.1, the sampling and analysis procedures need only be adequate to measure the actual concentrations. In such cases, the standard deviation estimated for variability due to random error of the analysis shall be no greater j

than ten percent (10%) of the measured value.

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License No. 660-02 Amendment No. 02 April 4, 1991 Page 19 of 45 26.3 OUALITY ASSURANCE /OUALITY CONTROL l

26.3.1 The licensee shall maintain a quality assurance / quality control program approved by the Department and specified in LC 11.4-1 or i 11.4-2. l l

26.3.2 NRC Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment", as revised, may be followed by the licensee; or the

I licensee's specifications may provide for an equivalent quality j

assurance program.

26.4 EOUIPMENT AVAILABLE The inventory of monitoring equipment shall be such that operable and calibrated units are always on hand. !

26.5 CALIBRATION OF EOU1 AENT ,

1 The licensee shall calibrate all radiation monitoring and sampling equipment af ter repair and, unless otherwise authorized by the Department, at least as frequently as the manufacturer's suggested interval, or semiannually if no interval is specified. Also, a check source shall be used to assure that radiation detection instruments are operating properly before each use. j 27.0 PERSONNEL AND FACILITY MONITORING 27.1 Consistent with LC 11.1, the licensee's personnel and facility monitoring program shall be sufficient to enable the Department to estimate maximum potential occupational dose commitment and to demonstrate compliance with 6 CCR 1007-1-4, and shall ben 27.1.1 As in the procedures manual (LC 11.2) required by LC 20, as modified by this LC 27; 27.1.2 Revised as necessary in accordance with LC 20.2.

27.2 The RESULTS of personnel and facility monitoring required by LC 27 shall be included in the report required in LC 30.

27.3 PERSONNEL MONITORING 27.3.1 Control badges shall be kept in a background location.

27.3.2 All users of radioactive materials described in LC 6.1.1 and 6.1.2 must be equipped with personnel monitoring devices capable of detecting both gamma and neutron radiation.

License No. 660-02

Amendre.nt No. 02 April 4 1991 Page 20 of 45 27.4 BIOASSAY 27.4.1 The licensee shall comply with the program as in the procedures manual approved by the Department and NRC Regulatory Guide 8.22

" Bioassay at Uranium Hills" (Revision O or as subsequently revised),

restrictive, and the following: license or LC 11 are more unless other conditions of this Urinalysis for uranium shall be performed for employees assigned to Radiation Work Permit activities exceeding one work day. Specimens shall be collected as close~as is reasonably possible to the period beginning 48, hours and ending 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after the last exposure. .The measurement sensitivity shall be 5 ug/l or less. A special urinalysis shall also be performed if there is any reason to suspect an inhalation exposure to yellowcake exceeding 40 x 10-10 520 x 10 10in a period of one work week or to ore dust exceeding uCi-hr/ml uci-hr/ml in a period of one calendar quarter. The licensee shall make a formal documented evaluation if bioassay neasuremente exceed any of the following criteria:

27.4.1.1 The urinary uranium concentration exceeds 30 ug/l for any two consecutive sampling periods.

27.4.1 2 The urinary uranium concentration for any measurement exceeds 80 ug/1.

7'.4.1.3 Action levels based on bioassay measurements shall be in accordance with Tables 1 .nd 2 of NRC Regulatory Guide 8.22.

In addition, all bioassai results aball be evaluated and acted upon by the RSO and appropriate licensee officials.

27.4.2 Urinalysis results exceeding 15 ug/l shall be reported to the RSO within 20 days of specimen collection.

27.4.3 Urinalysis to the RSO results exceeding 30 ug/l shall be reported immediately by telephone.

27.4.4 Prevention of specimen contamination shall be in accordance with Section C.6 of NRC Regulatory Guide 8.22.

27.4.5 The licensee for urino shall implement specimens that a documented quality control program includes background samples, blanks, and spikes and also criteria for requiring repeat collection and analysis.

27.4.6 A baseline urine sample shall be obtained from any new worker who will be subject to urinalynis, prior to start of work.

27.5 MILL AIR SAMPLING The licensee shall conduct an air sampling program to assess

, airborne as exposed, radioactivity follows: concentrationr to which employees may be

y MEETING

SUMMARY

Date/ Time of Meetina: January 25, 1995/9:00 a.m.

Location of Meetina: U.S. Nuclear Regulatory Commission Headquarter Two White Flint North Attendees: See Attachment 1 The meeting was_ held at the request of the U.S. Department of Energy (DOE) to discuss options' for.the disposal of residual radioactive material (RRM) from the Naturita, Colorado, Title I uranium mill site. The meeting was attended by NRC staff from the Office of State Programs and the Division of Waste Management'and representatives of DOE Headquarters and the DOE Uranium Mill

' Tailings Remedial Action (UMTRA) Project Office. Representatives of the State of Colorado participated via telephone.

DOE representatives began the meeting with a discussion of the Naturita project and the various alternatives for disposal. In order to avoid proliferation of sites, a decision was made to dispose of the Naturita RRM at

.the Umetco Title II Uravan site. They explained that the original plan was to place the RRM on or adjacent to the existing pile at Uravan. The existing pile at' Uravan now contains too much material to allow the additional Naturita RRM to be placed there and the alternative now is the upper Burbank pit. The Burbank pit is a more attractive alternative because disposal will be below

. grade.

The DOE UMTRA Project Office already has possession of the Naturita site and demolition there is complete. In addition, the State of Colorado, as the Agreement State responsible for regulating the Uravan site, has responded to all questions regarding the Uravan site and returned those responses to 00E.

The.NRC staff explained that they were still determining what NRC's role would be if the RRM is placed at Uravan. The preliminary assessment is that NRC would have to maintain some kind of oversight due to its statutory responsibilities under the Uranium Mill Tailings Remedial Action Control Act.

The State of Colorado representatives expressed concern over the potential for NRC involvement in a site regulated by the State. They cited the Riverton, Wyoming, example and noted that the State has the responsibility for the regulatory program in' Colorado'and. acts as NRC's agent to implement the regulations. They also' stated that NRC should review the ' State's responses to DOE's questions regarding the Uravan site.

It was agreed that. all parties would meet again following a final decision by NRC. A follow-up meeting was planned in which NRC legal counsel would also be present.

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TABLE 1.1

SUMMARY

OF OPEN ISSUES l

OPEN ISSUE TER Subsection i

1. DOE should revise the RAP to describe' 5.1 where the process water for the mill was derived.

2. DOE states thrt the uppermost aquifer 5.2.2 at the disrosal site is Class III, based on low yield (< 150 gallons per day). DOE must provide a calculation, based on existing site-characterization.

data,.that shows that the sustained yield of the uppermost aquifer at the disposal site is < 150 gpd.

3. Demonstrate compliance with EPA's final 5.5 ground-water cleanup standards in 40 CFR 192, Subparts B and C.

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5.0 WATER RESOURCES PROTECTION )

5.1 Introduction NRC staff has reviewed the preliminary final Remedial Action Plan (U0E,1993) and auxiliary documents far the Naturita, Colorado UMTRA Project site for compliance with EPA's proposed ground-water protection standards (EPA, 1987) and relevant portions of NRC staff's Standard Review Plan for UMTRA Title I Mill Tailings Remedial Action Plans (NRC,1992).

The Naturita site is unique in the UMTRA program, because there are no mill J tailings piles remaining at the site. The Naturita mill originally operated as a vanadium processing facility from 1939 until the facility was converted to uranium ore processing in 1942. The Naturita milling process extracted uranium and vanadium from the ore by salt roasting and quenching the calcine in a carbonate solution, followed by carbonate leaching and sulfuric acid leaching in percolation tanks.

The mill was shut down at the end of World War II and was reopened in 1947.

The mill operated until 1958 when it was again shut down. An upgrader was operated at the site from 1961 until the mill was dismantled in 1963. The upgrader separated sand from slime, and the slime fraction was sent to the ;

Durango, Colorado mill for further processing. Ranchers Exploration and l Development Corporation purchased the portion of the site which contained the mill tailings, and removed the tailings to the Durita heap-leach facility near Vancorum from 1977 through 1979.

DOE proposes to remove the contaminated materials from the former mill and I tailings properties and the immediately adjacent areas. The contaminated material will be placed in an engineered disposal cell at a location approximately three miles southeast of the mill site (Dry Flats). DOE has concluded that the proposed remedial action complies with the proposed EPA ground-water protection standards at the disposal site under supplemental standards in 6192.22, because the uppermost aquifer at the disposal site meets the limited-use (Class Ill) designation, and that hazardous constituents potentially released from the site do not represent a substantial hazard to human health and the environment.

DOE is proposing to defer the cleanup of existing ground-water contamination at the Naturita site until a later project phase. NRC staff and DOE are consistent with EPA's ground-water protection standards, by distinguishing between the disposal of residual radioactive materials at the disposal site and cleanup of existing ground-water contamination at the processing site. As with all VMTRA Project sites, NRC staff cannot accept DOE's proposal to defer cleanup of existing ground-water contamination, until DOE demonstrates that public health and the environment will not be impacted by the delay of remediation at *he Naturita processing site.

5.2 Hydroaeoloaic Characterization 5.2 l

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[ The hydrogeologic characterization provides the basis for determining which strategies will be appropriate for ground-water resource > protection in the vicinity of the processing and disposal sites. The _aaracterization sets the groundwork for complying with the standards of 40 CFR 192 Subparts A - C.

Critical elements of the hydrogeologic characterization are: (1) identi-fication of the hydrogeologic units, (2) hydraulic and transport properties, (3) geochemical conditions and contamination extent, and (4) present and potential water use. Each of these elements are presented below for the processing and disposal sites, as provided in DOE's Remedial Action Plan (RAP).

5.2.1 Identification of Hydrogeologic Units A. Processing Site The processing site is located in the San Miguel River Valley and is underlain by unconsolidated alluvial floodplain deposits and fill material. The alluvium is underlain by the Brushy Basin Member and the salt Wash Member of the Jurassic Morrison Formation. The alluvial aquifer consists of rounded river gravel and cobbles in a silty to clayey-sand matrix. The alluvium ranges in thickness from about 11 to 34 feet, with an averace thickness of about 20 feet.

The Brushy Basin is composed of varicolored shales with some fine- to very fine-grained sandstones and conglomerates. The thickness of the Brushy Basin Member ranges from about 110 to 185 feet. The Salt Wash consists of fine- to coarse-grained sandstones with some shales. Thr. top of this unit is approximately 130 to 165 feet below the land surface near the site. The total thickness of this member has not been determined at this area, but is at least 80 feet thick in the vicinity of the processing site.

Gruund water is encountered in two distinct and separate hydrogeologic zones in the area of the Naturita site. Ground water occurs within the unconsolidated alluvial deposits, where it is under unconfined conditions; and within the Salt Wash units, where it exists under confined aquifer conditions.

These two aquifers are separated by the laterally extensive Brushy Basin units which act as an aquitard. The alluvial aquifer is considered the uppermost aquifer beneath the processing site.

B. Disposal Site The hydrogeologic units beneath the Dry Flats disposal site are the Cretaceous Dakota Sandstone and the Burro Canyon Formation; and the Brushy Basin and Salt Wash Members of the Jurassic Morrison Formation. The actual thickness and contacts between the formations is difficult to determine at the disposal site because of similarities in lithology and the gradational contact zones between the units.

l The uppermost portion of the Dakota Sandstone at the site is a sandstone unit underlain by a gray / black shale-claystone unit with a thin coal seam at the base. The total formation thickness varies greatly over a short distance, due to changes in depositional facies; however, the Dakota is about 100 to 150 5.3

feet thick in the area. The Burro Canyon consists of greenish mudstone in the upper part and mainly sandstone in the lower part. The Burro Canyon is approximately 100 feet thick:in the site vicinity. The distinction between

.the Dakota and.the Burro Canyon is poorly defined at the site because of the discontinuous natu're of the major sandstone units. The Brushy Basin is

. composed of. variegated, interbedded shales, mudstones, sandstones, and conglomerate lenses. .The brush basin is estimated to be about 450 feet thick in this area'. The Salt Wash is , composed predominately of interbedded sandstones with siltstones wit some shales. Based on the thickness of the overlying units in this a'rea7)1t is estimated that .the top of the Salt Wash is

-about 700 feet below the 1 s d surface. The bedrock in this area dips to the northeast at about 2 to'4 degrees.

Ground water occurs in two distinct 1e and separate zones beneath the disposal site. - Ground water initially occursdn the basal sandstones of the Burro Canyon at depths from.185 to 200 feet below ground surface. Ground water in the Burro Canyon is unconfined and has a' saturated thickness ranging from 5 to

22. feet. The Burro Canyon is considered the uppermost aquifer at the Dry Flats site. -The next occurrence of ground water is-in the sandstones in the lower part of the Brushy Basin at a depth of about 500 feet below the ground surface. The Brushy Basin aquifer is confined by the regionally extensive mudstones in the upper portion of the Brushy Basin Member. There is no observed hydraulic connection between the Burro Canyon aquifer and the deeper Brushy Basin aquifer.

NRC staff has reviewed the hydrogeologic characterization of the Naturita site and agrees with the . designation of the San Miguel River alluvium as the uppermost aquifer g

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5.2.2 Hydraulic and Transport Properties A. Processing Site The hydraulic and advective transport properties of the uppermost aquifer were evaluated by DOE with single-well . slug tests and water level measurements at the processing site and surrounding area. A-potentiometric surface map was constructed to; determine the direction and hydraulic gradient of the water table. Ground water in the alluvial aquifer flows northwest through the

narrow San Miguel River Valley with a horizontal gradient of approximately 0.005. An averaged hydraulic conductivity of about 3.0 ft/ day was ca'1culated for the alluvial aquifer from slug test measurements of the monitoring wells.

4tMI*' site. .An average linear ground-water velocity of 0.06 ft/ day was calculated using Darcy's Law with the above measured hydraulic gradient and.

conductivity, and an estimated effective porosity of 0.20. ,#

Th'e deeper Salt Wash aquifer was penetrated with only two monitoring wells, which does not allow the development of a potentiometric surface map at the site. However,. ground-water flow is expected to follow the dip direction of the bedrock tOthe; 2rn , which dips toward the northeast. The average hydraulic conductivity is 0.06 ft. day, as determined by slug-test measurements. An upward vertical hydraul.ic gradient of 0.04 was measured between the Salt Wash aquifer and the shallower alluvial aquifer. This strong 5.4 m .J

I L upward gradient and the 110 to 145 feet thickness and low conductivity of the Bushy Basin Member provides reasonable assurance that contamination from the

. alluvial aquifer will not migrate into the Salt Wash aquifer.

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B. Disposal Site The hydraulic and advective transport properties of the uppermost aquifer were l evaluated by DOE with three pumping tests, single-well slug tests, and water-level measurements at the site and the surrounding area. The pumping tests confirmed the unconfined hydraulic condition of the aquifer with delayed yield l

during the later stages of the tests. The average horizontal hydraulic

! conductivities measured from the pumping tests is 1.7 ft/ day. The specific yield was obtained from the late time / drawdown data and is estimated to average about'8.12 x 10'3 . By comparison, the hydraulic conductivities from l the slug tests are less reliable than those derived from the pumping tests, and were used by DOE only to provide a relative indication of the variability

! in the hydraulic conductivity in the formation.

Ground-water flow is generally southwesterly t'ord the Yampa River, and generally follows the gentle slope of surface topography. DOE calculated the average horizontal hydraulic gradient in the vicinity of the site as approximately 0.04. DOE's RAP text provides an estimate of 0.085 ft/ day for

the average liner velocity at the site, however, this estimate is based on an

( average hydraulic gradient of 0.01 which is substantially different than the

! value of 0.04 in calculation MAY-08-90-14-06-00. Additionally, calculation l MAY-08-90-14-07-00 is titled ' Calculation of Average Linear Velocity of Ground Water'; however, the provided calculation is a hydraulic gradient estimation.

DOE must review the measured potentiometric data for the site and provide an accurate estimate of the horizontal hydraulic gradient and the average linear i velocity. This is an open issue.

l 5.2.3 Geochemical Conditions and Extent of Contamination Ambient ground-water quality in the uppermost aquifer is influenced by the presence of naturally occurring uranium mineralization. Several unreclaimed open pit mines are located near the tailings pile. A characteristic feature

! of the Naturita ore deposits is the large amount of low-grade to sub-economic mineralized material that is still present in the Browns Park Formation. The background water quality at the site is described as a calcium bicarbonate /

sulfate type with a pH that ranges from 4.94 to 7.56.

The average ambient Total Dissolved Solids (TDS) concentration in the !

uppermost aquifer is approximately 1680 mg/L. Background water quality is !

also characterized by low concentrations of chloride and nitrate, both of ,

which are contaminants present in the tailings leachate. DOE's assessment indicates that ground-water contamination from the processing site is readily distinguished from ambient ground-water conditions, due to the elevated nitrate levels in the contaminated waters.

Ambient ground-water quality measurements within the uppermost aquifer i indicate that arsenic, selenium, and uranium exceed the proposed EPA maximum I contaminant levels (MCLs) upgradient of the site. Additionally, iron, 5.5

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L manganese, and sulfate are elevated above the Secondary Drinking Water Standards _ in wells upgradient of the pile and in wells downgradient, but likely beyond the hydraulic influence of the pile. These constituents likely result from the ore bodies and mineralized zones in the Browns Park. Mining activities may also have contributed to high levels of these constituents in the ambient ground water.

00E's assessment of the site's geochemical characteristics indicates that conditions beneath the tailings pile are favorable for neutralizing the acidic tailings seepage: but removal of some of the hazardous constituents is only partially effective, because of relatively low ion exchange capacities in the Browns Park Formation. Neutralization of the tailings seepage _and precipitation of acid-soluble iron in the unsaturated zone appears to enhance the sorption'of some hazardous metals such as arsenic, molybdenum, selenium, radium, and uranium. The sorption-of these contaminants by the sub-pile soils may partially explain the relatively low concentration of these constituents in ground-water samples collected downgradient of the tailings pile.

l Seepage from the tailings materials has created a measurable mound in the i potentiometric surface beneath the pile. The mound has distorted local flow patterns in the immediate vicinity of the pile and caused some contamination to travel 'upgradient' of the tailings pile. The contaminated ground water is characterized by elevated nitrate concentrations and appears to be limited to radius of about 2000 feet or less from the pile.

l DOE has documented that tailings fluids had been released into Johnson Wash i and Lay Creek on several occasions during the operation of the site. These releases have caused varying degrees of soil contamination, which have been characterized by DOE. Soils with elevated radium-226 levels in these areas will be remediated and incorporated into the disposal cell.

NRC staff.has reviewed the geochemical characterization of the site and agrees that measurements indicate elevated concentrations of arsenic, selenium, and uranium in the ambient, upgradient ground water. However, DOE has not addressed the potential ground-water contamination'resulting from the prior releases of tailings fluids into Johnson Wash and Lay Creek. DOE must provide and evaluation of the ground-water impact from these prior tailings fluid

! releases, considering that at least one domestic well is situated within the i alluvial soils of Lay Creek (see TER section 5.2.4) downgradient of the site.

! This is an open issue.

! 5.2.4 Water Use A. Processing Site B. Disposal Site 1

DOE performed an inventory of domestic, municipal, agricultural, and )

industrial wells surrounding the Naturita site. The inventory consisted of reviewing well registration records at the Colorado Division of Water Resources. The well records indicate that there are no domestic wells within a 3-mile radius of the tailings pile. The nearest domestic well is located 5.6 A

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more than 3 miles southwest of the pile in the alluvium of Lay Creek. Several domestic wells'are in and near the town of Naturita, about 5 miles southwest of the site. These wells are typically less than 130 feet in depth and are situated in the Yampa River Alluvial Valley, with the exception of one well located in the Browns Dark Formation. DOE indicates that the domestic and municipal wells near the town of Naturita will not be impacted by the tailings leachate because of favorable geochemical conditions which prevent the downgradient movement of contaminants.

The Browns Park Formation provided water for the uranium milling operations during the active life of the facility. No industrial ground-water users are currently extracting water from the Browns Park Formation within a 3-mile !

radius of the site. Two windmill-powered wells yield water for livestock l watering within a three mile radius of the site. One windmill is located about 2.3 miles northeast of the site, and the second windmill is about I mile south of the site within Johnson Wash. ]

DOE performed an engineering evaluation of the treatability of the ambient ground water in the vicinity of the site. This evaluation was based on the concentration of naturally-occurring hazardous and non-hazardous constituents that would require treatment to make the ground-water potable. The particular constituents of concern are selenium and uranium, which occur at levels above l the Primary Drinking Water Standards (40 CFR 141) or the 9192 Subpart A MCLs; '

and also iron, manganese, and sulfate which are present above the Secondary Drinking Water Standards (40 CFR 142). The treatment-train needed to treat the Naturita ground water to Drinking Water Standards would require several conventional treatment processes performed in series or the use of reverse osmosis. DOE also confirmed ^. hat ground water is not normally treated, beyond l chlorination, for drinking water purposes in Colorado; except where I alternative drinking water sources are not readily available. l Historically, there has been little ground-water development in the vicinity !

of the Naturita tailings pile. DOE's assessment indicates that future ground- l water use in the affected hydrogeological environment well be minimal, because ;

of the remoteness of the tailings site to the existing and potential future ground-water users; and the general poor ground-water quality in the site vicinity. Additionally, the ready availability of alternative water supplies, including the Yampa River Valley Alluvium near the town of Naturita, will also likely curtail the development of ground-water in the area of the tailings I pile. Given these factors, the expected future value of the Browns Park l Formation for water supply appears to be low in the area of the tailings pile.

NRC has reviewed the water-use information and treatability evaluation provided by DOE and agrees that future development of the ground-water !

resource in the vicinity of the tailings pile will likely be minimal.

5.3 Conceptual Desian Features to Protect Water Resources DOE has included several factors, both enginee. ing design and siting considerations, which will provide protection of the water resources at the Naturita site. DOE proposes to incorporate the tailings and contaminated

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materials from the Naturita processing site into an engineered disposal cell at the present location of the tailings materials. The existing tailings will be pre-loaded with contaminated soil materials to induce tailings consolidation, and the relocated contaminated materials will ultimately be placed in the lifts and compacted at near optimum moisture levels.

The disposal cell's cover design consists of the following five components, in ascending order: (1) l\-foot-thick radon barrier constructed of clayey sands amended with 10 percent bentonite and compacted. The constructed radon barrier will have a saturated hydraulic conductivity of approximately 1 x 10'7 cm/sec; (2) four-foot-thick frost protection layer composed of sandy soils; (3) 6-inch drainage / bedding layer which will serve as a capillary break and hydraulically separate the radon barrier and frost protection layer from the overlying cover component. and (4) 8-inch riprap layer for erosion protection.

All cover components will be constructed of natural, stable materials to ensure the long-term stability of the disposal cell. The disposal cell components are designed to comply with the EPA ground-water protection standards and ensure that long-term performance does not rely on active maintenance. The overall low permeability of the cover is designed to mitigate the long-term seepage from entering the tailings.

The main natural components that will serve to protect the water resources at the disposal site are the chemical attenuation capacity of the unsaturated portion of the Browns Park Formation, and the favorable climate conditions.

Measurements and modeling performed by DOE indicate that the majority of the hazardous constituents have been attenuated within the upper few feet of the Browns Park Formation. A summary of the attenuation capacity is presented in TER Section 5.2.3. The. climate at the Naturita site is considered semi-arid with a mean annual precipitation of about 13.3 inches with an annual pan evaporation rate of 48 inches. DOE has also stated that the available capecity within the Browns Park should be sufficient to neutralize all of the tailings porewater that is expected to seep from the disposal cell.

NRC staff has reviewed the conceptual design features of the disposal cell and agrees that the combination of the engineered features, the natural attenuation component, and the favorable climate conditions should protect the uppermost aquifer in accordance with 40 CFR 192.20(a)(3)(iii). However, DOE has not evaluated the potential adverse impact on the ground-water quality caused by the proposed preloading of the existing tailings pile. By preloading to accelerate consolidation, additional tailings leachate will be forced into the underlying subsoil; at an increased rate and contribute to the existing contaminant plume beneath the site. DOE must quantify the amount of anticipated seepage into the underlying soils caused by the preloading and evaluate the impact to the ground-water quality beneath the site. This is an open issue.

5.4 Disposal and Control of Residual Radioactive Materials (RRM)

DOE must demonstrate that the planned RRM disposal complies with the site-i 5.8

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r I specific ground-water protection standards and closure performance standards in 40 CFR 192 Subparts A and C. The four areas that must be addressed are:

(1) Water Resources Protection Standards for Disposal; (2) Performance i

Assessment; (3) Closure Performance Demonstration; and (4) Ground-Water Monitoring and Corrective Action Plans.

5.4.1 Water Resources Protection Standards for Disposal The three elements needed for the disposal compliance demonstration with the l l water resources protection standards in 40 CFR 192.02 include: (1) a list of l hazardous constituents associated with the tailings material; (2) a corresponding list of concentration limits for the listed constituents; and (3) a Point of Compliance for monitoring the hazardous constituent concentrations in the uppermost aquifer. 40 CFR 192.22(a) allows for the implementation of supplemental standards for compliance, which can be applied I in lieu of standards in Subparts A or B; if one or more of the criteria of 9192.21(a) through (g) applies. DOE proposes to apply supplemental standards l for ground-water compliance at the disposal site under 9192.21(g) - Class Ill Ground Water. Details of DOE's compliance demonstration for the Naturita disposal cell are presented below.

5.4.1.1 Hazardous Constituents Hazardous constituents were identified from the tailings pore fluid characterization, and from knowledge of the uranium recovery process at the processing site. Hazardous constituents are those compounds listed in Table A of 40 CFR 192, or Table 1 of 40 CFR 264, or Appendix VIII of Part 261. DOE has identified seven inorganic hazardous constituents in the tailings pore fluids that exceed the maximum contaminant limit (MCL) from Table A of Part 192, and Table 1 of Part 264. These constituents are: arsenic, cadmium, molybdenum, nitrate, combined radium-226 and radium-228, selenium, and uranium.

Additionally, the following seven hazardous constituents or elements of hazardous constituents listed in the 9261 Appendix Vill were also detected in the tailings fluids: aluminum, antimony, beryllium, copper, nickel, vanadium, and zinc. Aluminum and zinc are components of aluminum phosphide and zinc phosphide. Copper and zinc are components of copper cyanide and zinc cyanide.

Vanadium is a component of vanadium pentoxide. The phosphide and cyanide anion components were not detected in the tailings fluids, when analyzed, and are not expected to occur under the geochemical conditions within the tailings. Vanadium pentoxide is also not expected to occur under the geochemical conditions in the tailings. Aluminum, copper, vanadium, and zinc should not be included in the list of hazardous constituents; however, antimony, beryllium,. and nickel have been identified in the tailings through analysis and should be included in the list of hazardous constituents.

DOE did not. provide any information in the RAP regarding the analysis or evaluation of organic hazardous constituents listed in Appendix VIII of 40 CFR 261. The presence or absence of these constituents should be addressed in the RAP, given that solvent extraction was used in the milling process from 1976 through 1981.

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NRC staff has reviewed DOE's hazardous constituent characterization according to the following three criteria: (1) whether the constituents are reasonably expected to be in or derived from the tailings; (2) whether they are listed in Table A of 40 CFR 192 or Appendix VIII of 40 CFR 261; and (3) whether they were detected in the tailings or ground water at the site (NRC, 1988). Based on this review, DOE should revise the list of hazardous constituents in the RAP to include antimony, beryllium, and nickel; and provide information on the organic hazardous constituent concentrations in the tailings. This is an open issue.

5.4.1.2 Concentration Limits DOE proposes a narrative supplemental ground-water compliance standard at the Naturita site, rather than establishing numerical concentration limits at a specified Point of Compliance. DOE indicates that a narrative supplemental standard is appropriate at the site because: (1) the background ground-water ,

quality in the uppermost 3quifer is variable with concentrations of several I hazardous constituents ranging from below the method detection limit to well above the MCL; (2) the ground water in the vicinity of the tailings pile has no historic or current beneficial use downgradient of the affected area; and (3) the proposed remedial action at Naturita comes as close to meeting the otherwise applicable standards as is reasonable under the circumstances.

NRC staff has reviewed the ambient ground-water quality data, water use, and conceptual disposal design from the disposal site and agrees with using a narrative compliance standard at the Naturita site.

5.4.1.3 Point of Compliance i

The Point of Compliance (P0C) is defined as a vertical surface that extends downward into the uppermost aquifer along the hydraulically downgradient limit of the disposal area. Monitoring wells should be located as close to the disposal cell as practicable, without disturbing the engineered components intended for the long-term tailings isolation.

DOE does not propose to conduct monitoring along the P0C at the Naturita site, because monitoring for the purpose of numerical compliance would not provide additional protection of human health and the environment beyond the narrative compliance standards for a Class III aquifer.

NRC staff has reviewed the ambient ground-water quality data, water use, and conceptual disposal design from the disposal site and agrees with using a narrative compliance standard at the Naturita site. Additionally, NRC staff agrees that P0C monitoring at the Naturita site is not appropriate for protecting human health and the environment.

5.4.2 Performance Assessment 00E must demonstrate that the disposal cell performance will comply with EPA's l ground-water protection standards in 40 CFR 192 Subparts A and C. DOE i evaluated the potential flux through the bottom of the disposal cell and the impact to ground water in calculations MAY-08-90-12-06-00 and MAY-09-90-14 f

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00; however, the calculations use a cover infiltration flux of 1 x 10-8 cm/sec, while the hydraulic conductivity specified in the design is 1 x 10'7 cm/sec. Additionally, these calculations do not account for the flux resulting from preloading the existing tailings to induce consolidation.

NRC staff has reviewed the information and calculations used to evaluated the flux from the disposal cell and the resulting ground-water impact. DOE must revise calculations MAY-08-90-12-06-00 and MAY-09-90-14-03-00 to reflect the hydraulic conductivity specified in the design and account for the additional flux resulting from the preloading of the tailings pile. This is an open issue.

5.4.3 Closure Performance Demonstration In accordance with the closure performance standards of 40 CFR 192.02(a)(4),

DOE is required to demonstrate that the proposed disposal design will: (1) minimize and control contaminant releases to ground water and surface water, (2) minimize the need for future maintenance, and (3) meet the initial design performance standards. DOE's remedial design for combining the off-pile contaminated soils with the exiting tailings materials in an engineered disposal cell will minimize contaminant releases to ground water and surface water. In particular, limiting the infiltration flux with a compacted, bentonite-amended radon barrier with an anticipated hydraulic conductivity of 1 x 10'7 cm/sec, will minimize future contaminant releases to the ground water. Future maintenance of the disposal cell will be minimized through the use of stable, natural earth materials.

DOE proposes to apply supplemental standards for ground-water protection, which means that compliance will be based on a narrative standard of coming "as close to meeting the otherwise applicable standard as is reasonable under the circumstances." As a primary component of the remedial design, DOE performed various engineering assessments to evaluate whether the design would meet the disposal compliance standards in Subpart A. Designating an uppermost aquifer as limited use (Class III) assures that the same level of protection for human health and the environment will be provided by conforming to the narrative standards as would complying with the numerical standards at a site with an unrestricted water-use designation.

Since numerical ground-water standards are established and measured at the P0C, complying with the narrative standards may not necessarily include a P0C monitoring program. Sites which utilize narrative, rather than numerical compliance standards and do not include a ground-water monitoring program at the P0C require a heavier reliance on a performance monitoring program to provide reasonable assurance that the disposal cell is performing according to the engineering design. Consequently, NRC staff considers it necessary for DOE to provide a conceptual description of a performance monitoring system in the RAP to comply with 6192.02(b). At sites with a P0C monitoring system, that system could serve the dual purpose of demonstrating compliance with the numerical ground-water standard and demonstrating that the disposal cell is performing according to the engineering design.

In describing the conceptual monitoring plan in the RAP, DOE should name the 5.11

preferred type of monitoring methodology or provide a listing of several monitoring techniques that would adequately show that during the post-closure period, the disposal cell is performing according to the design. DOE should also describe how the proposed method would demonstrate compliance or non-compliance. Details of the monitoring plan such as, monitoring locations and measurement schedules, can be provided at a future date in the Long Term Surveillance Plan (LTSP). Additionally, DOE could substitute a different performance monitoring methodology in the LTSP if a new technology became available or the originally proposed methodology has been shown .to be less than effective in demonstrating design performance.

The critical need for conducting the performance monitoring at sites with narrative standards and no P0C monitoring is that without the post-disposal performance monitoring, there would be next to no mechanism to initiate corrective action for ground-water restoration under fl92.02(c) unless there was a visible, catastrophic failure of_ the disposal design.

The NRC staff agrees with 00E's. assessments and evaluations concerning the anticipated performance of the disposal cell. However, NRC staff does not ;

agree with DOE's proposal to defer the development of a conceptual performance l monitoring program to the LTSP. At a minimum for demonstrating compliance l with fl92.02(b), DOE should provide a conceptual monitoring program or (

alternative measures which will be effective in demonstrating the disposal 1 cell performance during the specified post-closure period. Details of the monitoring' plan can be provided in the LTSP. This is an open issue.

5.4.4 ' Ground-Water- Monitoring and Corrective Action Plans A. Processing Site B. Disposal Site DOE is required to develop ground-water monitoring and corrective action plans which will be carried out-during the post-disposal period, in accordance with the proposed ground-water protection standards in 40 CFP. 192.02(a).and (b).

DOE does not plan to monitor ground-water quality in the uppermost aquifer through' the POC wells along the downgradient edges of the disposal cell. DOE has stated in the RAP that the appropriate method for performance monitoring well be determined and provided in the LTSP.

DOE is required by 40 CFR 192.02(c) to provide an evaluation of alternative corrective actions that could be implemented if the disposal cell monitoring

. program indicates that the cell is not performing adequately. DOE will i provide a detailed corrective action plan in the LTSP for conturrence by NRC.

DOE has'provided reasonable failure scenarios of the disposal unit and also provided a conceptual corrective action to address each failure scenario. DOE has agreed to provide and-implement a corrective action plai no later than 18 months after detecting an excursion.

NRC staff has reviewed the ambient ground-water quality data for the Naturita site and agrees that P0C ground-water monitoring of the uppermost aquifer would not be necessary for protection of human health and the environment, !

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given the limited use (Class III) designation of the Browns Park Formation.

NRC has also reviewed the credible failure scenarios provided in the RAP and agrees with the conceptual corrective actions proposed by 00E. However, as discussed in the previous TER section, NRC does not agree with DOE's proposal to defer developing the conceptual performance monitoring program .until the LTSP.

5.5 Cleanup and Control of Existina Contamination DOE must demonstrate compliance with the EPA standards listed in 40 CFR Part 192, Subparts B and C, for the cleanup and control of existing ground-water ,

contamination. DOE proposes to defer the ground-water cleanup compliance i demonstration at the Naturita site. Ground-water restoration will be (

addressed under a separate DOE program as part of the National Environmental Policy Act (NEPA) process. The NRC staff considers that the ground-water cleanup may be deferred, as provided by the UMTRCA amendments of 1982.

Ground-water cleanup of the Naturita site may be deferred if DOE can j demonstrate that: (1) ground-water cleanup of the site will not be impacted by the tailings disposal, and is separable from the remedial actions, and I (2) public health and the environment will be protected. l i

Combining the off-pile contaminated soils with the mill tailings at the l present location of the tailings pile should not impact the future ground- {

water restoration activities at the Naturita site. DOE has determined that the Browns Park aquifer in the vicinity of the tailings pile meets EPA's limited use (Class III) ground-water classification, due to wide-spread ambient contamination not resulting from the milling operations. The ground water in the aquifer is presently used for limited stock watering and is not a source of drinking water.

NRC staff concurs with DOE's deferral of ground-water cleanup at the processing site. DOE must demonstrate compliance with EPA's final ground-water cleanup standards in 40 CFR 192, Subparts B and C. l 5.6 Conclusions DOE, with NRC's concurrence, has proposed to defer the ground-water cleanup of the Naturita processing site until a later project phase, The following open issue presently remains unresolved:

7. Demonstrate compliance with EPA's final ground-water cleanup standards in 40 CFR 192, Subparts B and C.

5.7 References DOE (U.S. Department of Energy),1993, " Remedial Action and Site Design for Stabilization of the Inactive Uranium Mill Tailings Site at Naturita, 5.13

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' Colorado, Preliminary Final," UMTRA-00E/AL/62350-40PF.

EPA (U.S. Environmental Protection Agency),1987, " Health and Environmental

. Performance Standards for Uranium Mill Tailings", Code of Federal Regulations, Title 40, Part-.192, . Subparts A'through C, Federal Register Vol . 52., No.185.

NRC (U.S. Nuclear Regulatory Commission),1992, " Final Standard Review Plan

!. for Review of Remedial Action of Inactive Mill Tailings Sites under Title I of l the UMTRCA, Rev. 1,"~ Division of Low-Level Waste Management and Decommissioning, December 1992.

-NRC,~(U.S. Nuclear Regulatory Commission),'1988, " Draft Technical Position on

Information'Needs to Demonstrate Compliance with EPA's Proposed Groundwater

. Protection' Standards, in 40 CFR- Part 192, Subparts A - C," Technical Branch, LLWM/NMSS.

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1. DDE indicates tnat at tne process ug site. tne strong acward--

vertical nydraulic gradient cetween tne alluvial aquiter and the Salt Wash aqui fer ti.e., 0.u40 ft/ft) and tne targe thickness and low nycraulic conduc ti vity of the con t ining uni t (i.e., the Brushy Basin Member) separating the two aquifers shculd result in no downward migration of groundwater.

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Accordingly, I w that DOE install at least one add 1tiona1 mo .e i 1 within tne sa1t Wash aqu11er to turther c ha r a c ts : 2- groundwater quality conditions. Inis well should ce delated in the area ot wnere the talling were formerly located.

2. In characterizing the water quality in the alluvial and tne Salt Wash aquifers at the processing site, DOE did not test for nitrite even thougn it is one of the constitutes listed in Table 8.1 of the tecnnical Approach Document tTAD). No explanation is given as to wny It was not tested for. LOE snould either test for nitrite or provide justification for why no testing is needed, t

3. DOE i n r11 c a t ed that t-om 1977 through 1 9'7 9 , tallings at the processing site were removed to a new neap leaching reprocessing plant locaters along Colorado State Highway 90, about three miles soutN46t of the intersection of State Highways 141 and 70; however, no information is provided on whether or not this site should De included in consideration with the processing and disposal sites, and whether or not this site is contaminated. DOE needs to clarify this issue.

4 In describing the g e c. cdwater use within the area of tne processing site, DOE admits that there are two wells down-gradient from the site, but indicates that there is no potential for contamination of these wells. It is unclear as to whether the basis for this assessment is 1) Decause of the wells location with respect to the river; 2) the wells are pumping from ditterent aquifers; or 3) the wells are at a great distance from the site (note no map is provided of the wells location with respect to the processing site). DOE needs to clarify this issue by 1) providing a map of the well locations with respect to the processing sitet 2) identity I %

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which units the Wells are receiving their water from; and !!

clearly state the basis for their conclusion that there is no potential for contamination of these wells.

5. In characterizing tne extent of groundwater contamination within the alluvial aquifer at the processing site. DOE has not considered possible contamination of the aquifer on the east side of the San Miguel River. in as much as no wells or boreholes were installed over there. DOE should characterize the groundwater quality in that area since wind blown contaminants have been identified on that side of the river.

6. DOE's basis for meeting proposed concentration limits at the POC, at the disposal site, is the isolation of the uppermost aquiter (1.e., the Salt Wasn Member). DOE has concluded that this aquiter is isolated based upon 1) the large thickness of the conf ining units (i.e., the Brushy Basin Member) and 2) the low hydraulic conductivity of tne confining unit.

Although DOE is probably correct in their assessment tnat tne thickness (i.e. >200 feet) of the confining unit will increase contaminant travel times (note: DOE has provided no travel estimates), tnere is no casis to conclude that the Brusny Basin Member has a low nydraulic conouctivity. DOE claims that the confining cenpecties of the Brushy Basin Member is evidenced by the potentiometric sur f ace rising 100 to 150 f eet above the top of the Salt Wash Member; however, this is only evident in one well (since the other well was dry). To further support their argument that Wash Memoer aquifer is isolated, DOE should C M} n e S a l tr47(E ,thLyydraulic p roper ',les o f the Brushy Basin Member and damnnstrate that the unit is uni t ormi l y . thick throughout the region. Further, DOE needs to provide',' Fa'vY1 time calculations to show that contaminants will not reach this unit within the 1000 year design lite of the cisposal pile.

7. In characterizing the hydrogeologic system at the disposal

. site, DOE has concluded that the groundwater system in the Dakota / Burro Canyon (D/BC) is not the upper-most aquifer because it is a perched system of limited extent, with a permeability insufficient to deliver 150 gallons per day.

While I agree that the permeability of the material is what one would expect from a aquitard and not an aquifer, permeability alone is insufficient to determine the expected yield to a well. Further, only two of the wells dellled into the D/BC units were dry, whicn may only inoicate that the groundwater system nas a linear pattern. Accordingly, DOE needs to provide more information to support their claim that this should not be considered the upper-most aquifer. This information should include well yields and/or drawdown data from observation wells.

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l S. In describing the Salt Wash Member aquifer, at the processing site, DOE indicates that .this aquifer is a major regional !

groundwater system, and then on the other hand indicate that Decause of its low hydraulic conductivity it may not be i capable of y ielding an adequa te supply of water to a domestic well. This contradiction needs to clarified.

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9. DOE has indicated their intentions to use the background groundwater quality of the Sal t Wash Member , at the processing site, as the background groundwater que'Ity of the Salt Wash Member at the disposal site. No'information has been provided j

to support the conclusion that the water quality at these two locations should b e s i rr, t l a r . Further, at least one of the two wells (i.e., well 502) at the processing site should not be considered an up-gradien t wel l , since it is drilled within an area that could be influenced by contamination of the mill yard.

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U.S. NUCLEAR REGULATORY COMMISSION STAFF REMEW COMMENTS ON THE U.S. DEPARTMENT OF ENERGY REMEDIAL ACTION PL2MIR NATURITA, COLORADO The following U.S. Nuclear Regulatory Commission (NRC)'stef con.snents are in reference to )

its review of the U.S. Department of Energy (DOE) Remedia' Actic.n Plan (RAP) for the I Naturita, Colorado, Uranium Mill Tailings Remedial Action Project s.ite, transmitted by cover letters on April 10 and June 12,1998. NRC staff comments are in the technical areas of groundwater hydrology, surface water hydrology and erosion protection, and soil clean-up and radon attenuation. All other technical areas of the Naturita RAP were considered acceptable by the NRC staff.

1 When responding to the NRC staff comments, DOE should ensure it maintains the current numbering system used below to facilitate proper tracking and closure of issues.

j HYDROLOGY 1 COMMENT: Concentration Limit for Strontium and Tin at Upper Burbank Disposal Site DISCUSSION:

RAP Table 3.1 of Appendix C identifies groundwater quality concentration limits for i strontium and tin at the Upper Burbank Disposal site. According to this table, these !

limits were derived from ground water quality samples collected at the disposal site from Wells CM-93-1 and CM-93-2. However, data on strontium and tin concentrations are not reported in the tables of site water quality data (i.e., tables of " Groundwater Analyses, CM-93-1, CM-93-2, Burbank Repository", Appendix B). Therefore, it is not clear how concentration limits for these parameters were derived.

ACTION NEEDED:

DOE should provide on-site water quality data collected for strontium and tin to establish the concentration limits in RAP Table 3.1 of Appendix C, or describe how data to derive concentration limits for strontium and tin will be obtained.

SURFACE WATER HYDROLOGY AND EROSION PROTECTION

2. COMMENT: Delineation of Drainage Areas DISCUSSION:

Based on the NRC staff's review of information provided by DOE in Construction Resolution Revision (CRR) No. 25 and recent site visits to the Upper Burbank disposal cell, it appears there may be some potential for drainage areas of the various drainage channels to be different from that assumed in DOE's flood analyses. It is not apparent that the drainage areas assumed in DOE's present calculations are correct, or would be

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' [ Anne Ramirezy Nat_ rap.com ,[ Page 2 {

so in the future (i.e., if grading modifications occur). This issue is important for the following reasons: (1) DOE intends to use smaller rock in the channels, but the flows in these channels could actually be larger, depending on the drainage area; (2) DOE assumes that the interceptor ditch could overtop (if filled by sediments), whereby any increases in overtopping flow could affect the toe design at the base of the steep slope, and therefore could affect the design of the downstream drainage ditches; and (3) flows could be larger at various locations entering the diversion channel, resulting in the need to design an interceptor channel and large sandstone riprap for flow concentrations.

ACTION NEEDED:

DOE should provide revised analyses that clearly delineate the drainage areas of the various channels and should consider the potential for these drainage areas to change in the future. Unless specific drainage area configurations can be identified, DOE should assume worst-case scenarios and provido detailed calculations and drawings of various possible drainage area configurations. Additionally, DOE should provide the following:

a) design of the riprap for the interceptor and diversion channels; b) design of the interceptor channel for sediment accumulation, and analyses of the potential for the channel to ovenop and allow concentrated flood flows to affect the design of the downstream channels, aprons, and toes; and c) design of the large sandstone and side slope riprap for concentrated flows produced by different possible drainage area configurations.

3. COMMENT: Design of Sandstone Benches DISCUSSION:

Based on NRC staff review of CRR No. 25. site visit observations at the Upper Burbank disposal cell, and discussions with DOE and contractor personnel, the sandstone bench area on the upstream side of the interceptor channel will need some design

modifications to prevent undesirable flow patterns from occurring (e.g., sudden

! drop-otis). It appears that if the sandstone bench is placed as currently designed, flood

! flows will not transition smoothly onto the side slope riprap, and there is a potential for erosion of the riprap to occur.

ACTION NEEDED:

DOE should revise the design and placement of the sandstone bench upstream of the interceptor channel. As discussed and agreed during a recent NRC staff site visit, DOE should provide a revised design that allows for no sudden drop-offs or undesirable flow transitions in this area. DOE should provide revised drawings indicating these l changes. l

Page 3 l l

' . [ Anne Ramirez - Nat_ rap.com _

SOIL CLEANUP & RADON ATTENUATION

4. COMMENT: Long-Term Moisture Value of Windblown Material DISCUSSION:

RAP Section 6.2.1 of the Naturita Remedial Action Selection (RAS) Report (Processing Site) indicates that the long-term moisture value of windblown material was not measured, but was assumed to be similar to mill yard material (i.e., the same value of 12 percerit was used). However, RAP Calc-010 of Appendix F indicates that four samples of windblown material were measured to have a long-term moisture value of 13 percent. RAP Sections 6.2.2 and 6.2.4 of the RAS also mention radon model values that are obsolete.

ACTION NEEDED:

DOE should revise RAP Section 6 of the RAS to reflect the values used in the current radon flux model, which appears to be Calc-010 of Appendix F.

5. COMMENT: Missing Information in Section 6.3 of the RAS DISCUSSION:

RAP Section 6.3, page 6-4 of the RAS (Processing Site) is titled " Evaluation of Radon Barrier;" however, there is no evaluation. Also, this section does not refer to another part of the RAP as to where the evaluation can be found.

ACTION NEEDED:

DOE should provide the aforementioned evaluation for RAP Section 6.3 of the RAS, or revise the existing section accordingly.

6. COMMENT: Missing Information in Attachment 4 DISCUSSION:

in Attachment 4 (Processing Site) the title pages for the sections labeled " Soil Verification Using Cobbles-to-Fines Correction" (OP-003-4) and " Uranium Cleanup and Verification at Naturita"(RAC-OP-007; adicate the inclusion of DOE /NRC correspondence; however, this information was not included.

ACTION NEEDED: -

DOE should either provide the referenced correspondence or revise the existing title pages accordingly.

~

l #L I Anne Ramiraz Nat rap.com

] Pags 4 j

7. COMMENT: Conflicting Data in Attachmens l and4 DISCUSSION:

i i Both Attachments 1 and 4 (Processing Site) cantara ccedethy data in the sections labeled " Contaminated Material Excavation - Cobbles-to-Fre Ratio" (Calc.

17-730-03-02) and " Cobbles-to-Fine Test Pit Analysis," respectively. Specifically, both l

sections contain Calc. 17-730-03-02; however, Sheet 7 of Attachment 4 was not updated from the previous version of the calculation.

l l ACTION NEEDED:

l

! DOE should revise both referenced sections in Attachments 1 and 4 in order to be consistent, or delete any duplicable data that is conflicting in either section.

8. COMMENT: Incomplete HistoricalInformation and Missing Evaluation in Attachment 4 DISCUSSION:

The section labeled " Cobbles-to-Fine Test Pit Analysis"in Attachment 4 (Processing ;

Site) contains a table of uranium and radium data from the cobbles-to-fines test pits.

This data sheet was also provided to the NRC in 1996 as part of a response to issue 19 regarding the characterization of uranium and Th-230. However, DOE's evaluation l

of the data was not provided. Based on its review, the NRC staff determined the data demonstrates that tailings material exists at 6 to 9 feet deep, or that the in-situ i mineralized materialis not in equilibrium. Additionally, Appendix B of the "

Cobbles-to-Fine Test Pit Analysis" section contains data (see Sheet B-9) showing Th-230 concentrations from the test pits; however, there is no indication of the s' ample depth or the corresponding Ra-226 value.

ACTION NEEDED:

DOE should provide a discussion in the referenced section regarding the site history of i process-related uranium and Th-230, and where they may exist at higher concentration I levels (pCi/g soil) than the Ra-226. An evaluaticn of all uranium and Th-230 data for i the site should also be provided.

9. COMMENT: Incomplete Data and Missing Supplemental Standard Application DISCUSSION: !

The section labeled " Radiological Data Collected During Excavation of Uranium Under Former Mill Site" in Attachment 4 (Processing Site) consists of a DOE trip report, dated July 28,1997, that includes some analytical data indicating Area 2 was excavated to the water table; however, elevated uranium levels were still present. Additional testing is recommended in the report. Mention is also made in the report where State of Colorado staff feel that adapting the generic thorium protocol for uranium is I

- l Anne Ramirez- Nat rap.com _

Page 5 {

inadequate.

. ACTION NEEDED:

DOE should provide the supplemental standard applica5m tr uranium in the RAP and

- include the additional data collected, as well as the health ardysis per its commitment in Section 6 of the RAS Report. DOE should also indicalea4here in the RAP it proposes to adapt the thorium protocol for uranium.

10. COMMENT: Calculation 17-730-01-02 (Excavation Extent & Depths, Volume, !

Ra-226)in Attachment 1 (

DISCUSSION:

Appendix D of Attachment 1 (Processing Site) contains estimated Ra-226 concentrations for windblown Areas F and G. However, there are elevated levels (32 to 213 pCi/g) at depths of 12 to 42 inches. Based on these depths, this does not appear to be windblown.

ACTION NEEDED:

DOE should explain why there is elevated Ra-226 at depths greater than 1 foot in these " windblown areas," and why the full depth of the contamination was not characterized.

11. COMMENT: Calculation 17-730-02-04 (Proposed Supplemental Standards Areas) in Attachment 1 S

DISCUSSION:

The summary of proposed areas for Supplemental Standards is on Sheets 2 and 3 in Attachment 1 (Processing Site). Comparison to the previous version of this calculation indicates that windblown Area B is no longer mentioned.

ACTION NEEDED:

DOE should indicate if the Supplemental Standards area in Area B is encompassed by the state right-of-way for the highway (NT-058), or if the contamination was removed.

12. COMMENT: Conflicting Supplemental Standards Information in Attachments 1 and 4 DISCUSSION:

The proposed Supp'emental Standards area (Processing Site) for vicinity property (VP)

NT-065 on sheet 16 of Attachment 1 (Calc.17-730-02-03) do not match he same Supplemental Standards area delineated on the map in Attachment 4. It is not clear which map is correct.

l

- l AnnQ RamirGz - Nat_ rap.com Page G l l _.

l l I l l l ACTION NEEDED:

DOE should revise the maps in Attachments 1 and 4 to ensure that the Supplemental Standards area for VP NT-065 is consistent and accurate.

1

13. COMMENT: Missing Supplemental Standards Information in Attachment 4 ,

f l DISCUSSION: )

( ;

l The section labeled " Supple nental Standards Areas for Naturita Processing Site and ]

Surrounding Vicinity Proper.ies"in Attachment 4 (Processing Site) contains a map l l

indicating areas proposed for Supplemental Standards -- one of which includes a small l

area around power poles near the gas line within the former tailings area. The associated calculation does not address this area.

l ACTION NEEDED: ,

DOE should provide the necessary information to include the referenced area as part of its proposed Supplemental Standards area.

.14. COMMENT: Missing Supplemental Standards Information in Attachment 1 DISCUSSION: l In Appendix C of Attachment 1 (Processing Site), Sheets C-17 and C-20 indicate that VP NT-065 Areas E and G contain windblown contamination that averages 111 and 46 pCi/g Ra-226, respectively. Additional Ra-226 data for Areas E, F, and G are in Calculation 17-730-01-02, which indicates contamination extends to 42 inches in depth or beyond.

ACTION NEEDED:

When DOE provides the Supplemental Standards application for VP NT-065, the discussion of Areas E and G should consider if the depth of the elevated Ra-226 levels are due to in-situ material, or provide an explanation why there is contamination greater than 2 feet deep. Additionally, DOE should provide a map clearly indicating the property lines for VP NT-065 and the excavated portions of Areas E, F, and G, and include all Ra-226 data as appropriate.

15. COMMENT: Missing and Conflicting Supplemental Standards Information in Attachment 1 DISCUSSION:

Sheets 9 and 10 of Attachment 1 (Processing Site) indicate that Supplemental Standards are proposed within 5 feet of the gas !ine in Area E. Area E appears to be part of VP NT-065, but the gas line is not listed under this property. Also, Sheet B-21 of Appendix B indicates that there will be no excavation within 10 feet of the gas line.

In contrast, Sheet F-2 of Appendix F (phone record dated November 11,1992)

J Anne RamirGz - Nat_ rap.com Page 7 {

Indicates that excavation must be by hand 3 feet on 6the sde 'of the line.

ACTION NEEDED:

DOE should indicate what property the gas line is on and ccvtirm that the discussion on Sheets 9 and 10 of Attachment 1 is correct in stating that Supplemental Standards will be applied to the area 5 feet on either side of the gas line.

16. COMMENT: Missing and Conflict.iig Data in the RAS and Attachment 4 DISCUSSION:

Table 1.1 of the RAS (Disposal Site) lists contaminated material types and volumes at the Naturita site. The section labeled " Site-Specific Hazardous Constituents"in Attachment 4 (Processing Site) provides a more comprehensive list of hazardous materials at the Naturita site. The.e appears to be a discrepancy in volume amounts for some hazardous constituents between the two sections of the RAP. Also, DOE has provided little or no discussion in either RAP section as to how disposal of this -

contaminated material has met regulatory, safety, and environmental requirements.

ACTION NEEDED:

DOE should provide some discussion in both referenced sections of the RAP regarding hazardous waste disposal, and show how this disposal met regulatory, safety, and environmental requirements. DOE should also update disposed volume amounts in all relevant portions of the RAP.

i

17. COMMENT: Conflicting Information in Sections 6.2 and 6.4 of the RAS DISCUSSION:

In Section 6.2 of the RAS (Disposal Site), it is unclear in the fourth paragraph as to what thickness of radon barrier will be placed on the top slope of the disposal cell i

(Section 6.4 states there will be the same thickness on the top and sides).

ACTION NEEDED: !

DOE should revise the fourth paragraph c.f RAS Section 6.2 so that it states the cover layers and thicknesses are the same for t 'o top and side slopes.

18. COMMENT: Incorrect References in Sections 6.3 and 7.0 of the RAS DISCUSSION:

In Section 6.3 of the RAS (Disposal Site), the second line indicates the wrong reference for the RADON code. It should appropriately reference *NRC 1989." Also, Section 7.0 of the RAS should be revised to replace the NRC 1984 reference with " Calculation of Radon Flux Attenuation by Earthen Uranium Mill Tailings Covers," NRC Regulatory

[ Ann 3 R mirsz - N tt_rsp.com_

[ Page 8 l Guide 3.64, July 1989. The 1984 document discusses the RAECOM code.

ACTION NEEDED:

DOE should revise Sections 6.3 and 7.0 to incorporate the correct reference as mentioned above.-

19. ' COMfAENT: Inconsistent Radon Attenuation Data DISCUSSION:

In Section 6.3 of the RAS (Disposal Site), the last sentence indicates that radon flux code input parameters are presented in Appendix F, NAT-CALC-010. However, Section 6.3.4 presents densities and specific gravity input values for the former tailings pile area and the windblown material that don't match the values used in NAT-CALC-010.

ACTION NEEDED:

DOE should ensure that parameter values presented in the radon attenuation section match values used in the radon flux modeling calculation.

20. COMMENT: Unreadable Map in Appendix I DISCUSSION:

Sheet 10 of RAP Appendix I(Disposal Site)is a xerox copy of a folded map. The copy ;

of this map is unreadable in this state. !

l ACTION NEEDED:

DOE should provide a full copy of the map, i

[ l6nne Ramirez - N120398a.wpd_ _

Page1]

i;

Dear John,

Please find below my evaluation of DOEs' response to Comment 1 of the final Remedial Action Plan (RAP) for the Naturita, Colorado,' UMTRA Project Site dated November 17,1998.

Sincerely, William Ford

50. COMMENT: Concentration Limit for Strontium and Tin at Upper Burbank Disposal Site EVALUATION OF RESPONSE: DOE was asked by the staff to explain how the concentration limits for strontium and tin at the Upper Burbank Disposal site were derived. DOE replied that concentration limits for strontium and tin will be determined during routine sampling of CM 93-1 and CM 93-2 during long-tenn site surveillance activities. Since, DOE will sample for many other parameters other than Tin and strontium, the ground-water protection program should detect any potential contamination in the ground water from the Upper Burbank Disposal site, even if concentration limits have not yet been established for strontium and tin. The staff considers this comment closed.

Status: Closed i

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[ Anne Ramirez - Nat_ rap.com Page 1 j j

U.S. NUCLEAR REGULATORY COMMISSION STAFF REVIEW COMMENTS ON THE U.S. DEPARTMENT OF ENERGY REMEDIAL ACTION PLAN FOR NATURITA, COLORADO I

The following U.S. Nuclear Regulatory Commission (NRC) staff comments are in reference to its review of the U.S. Department of Energy (DOE) Remedial Action Plan (RAP) for the j Naturita, Colorado, Uranium Mill Tailings Remedial Action Project site, transmitted by cover letters on April 10 and June 12,1998. NRC staff comments are in the technical areas of groundwater hydrology, surface water hydrology and erosion protection, and soil clean-up and radon attenuation. All other technical areas of the Naturita RAP were considered acceptable )

by the NRC staff.

When responding to the NRC staff comments, DOE should ensure it maintains the current numbering system used below to facilitate proper tracking and closure of issues.

HYDROLOGY 1 COMMENT: Concentration Limit for Strontium and Tin at Upper Burbank Disposal Site DISCUSSION:

RAP Table 3.1 of Appendix C identifies groundwater quality concentration limits for strontium and tin at the Upper Burbank Disposal site. According to this table, these .

limits were derived from ground water quality samples collected at the disposal site l from Wells CM-93-1 and CM-93-2. However, data on strontium and tin concentrations are not reported in the tables of site water quality data (i.e., tables of " Groundwater Analyses. CM-93-1, CM-93-2, Burbank Repository", Appendix B). Therefore, it is not clear how concentration limits for these parameters were derived.

ACTION NEEDED:

DOE should provide on-sito water quality data collected for strontium and tin to establish the concentration iMs in RAP Table 3.1 of Appendix C, or describe how data to derive concentration limits for strontum and tin will be obtained.

SURFACE WATER HYDROLOGY AND EROSION PROTECTION

2. COMMENT: Delineation of Drainage Areas DISCUSSION:

Based on the NRC staff's review of information provided by DOE in Construction Resolution Revision (CRR) No. 25 and recent site visits to the Upper Burbank disposal cell, it appears there may be some potential for drainage areas of the various drainage l

i channels to be different from that assumed in DOE's flood analyses. It is not apparent that the drainage areas assumed in DOE's present calculations are correct, or would be

~

l Ann 3 R:mir;z - Nat_ rap.com Page 2 l so in the future (i.e., if grading modifications occur) Tths isme.is important for the following reasons: (1) DOE intends to use sme!!er rockir,2he tchannels, but the flows in these channels could actually be larger, depending on the dra:nage area; (2) DOE assumes that the interceptor ditch could overtop (if Med by sediments), whereby any increases in overtopping flow could affect the toe desyt at the base of the steep slope, and therefore could affect the design of the downstream drainage ditches; and (3) flows could be larger at various locations entering the diversion channel, resulting in the l need to design an interceptor channel and large sandstone riprap for flow i concentrations. l ACTION NEEDED:

DOE should provide revised analyses that clearly delineate the drainage areas of the l various channels and should consider the potential for these drainage areas to change in the future. Unless specific drainage area configurations can be identified, DOE should assume worst-case scenarios and provide detaHed calculations and drawings of various possible drainage area configurations. Additionally, DOE should provide the following:

a) design of the riprap for the interceptor and diversion channels; b) design of the interceptor channel for sediment accumulation, and analyses of the potential for the channel to overtop and allow concentrated flood flows to ;

affect the design of the downstream channels, aprons, and toes; and c) design of the large sandstone and side slope riprap for concentrated flows i I

produced by different possible drainage area configurations.

1

3. COMMENT: Cesign of Sandstone Benches DISCUSSION:

Based on NRC staff review of CRR No. 25, site visit observations at the Upper Burbank disposal cell, and discussions with DOE and contractor personnel, the sandstone bench area on the upstream side of the interceptor channel will need some design modifications to prevent undesirable flow patterns from occurring (e.g., sudden drop-offs). It appears that if the sandstone bench is placed as currently designed, flood flows will not transition smoothly onto the side slope riprap, and there is a potential for erosion of the riprap to occur.

ACTION NEEDED:

DOE should revise the design and placement of the sandstone bench upstream of the

, interceptor channel. As discussed and agreed during a recent NRC staff site visit, DOE l should provide a revised design that allows for no sudden drop-offs or undesirable flow transitions in this area. DOE should provide revised drawings indicating these changes.

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l Anne Ramirez - Natyp.com Page 3 l i

SOIL CLEANUP & RADON ATTENUATION

4. COMMENT: Long-Term Moisture Value of Windblown Material DISCUSSION:

RAP Section 6.2.1 of the Naturita Remedial Action Selection (RAS) Report (Processing Site) indicates that the long-term moisture value of windblown material was not measured, but was assumed to be similar to mill yard material (i.e., the same value of 12 percent was used). However, RAP Calc-010 of Appendix F indicates that four samples of windblown material were measured to have a long-term moisture value of 13 percent. RAP Sections 6.2.2 and 6.2.4 of the RAS also mention radon model values that are obsolete.

ACTION NEEDED:

DOE should revise RAP Section 6 of the RAS to reflect the values used in the current radon flux model, which appears to be Calc-010 of Appendix F.

5. COMMENT: Missing Information in Section 6.3 of the RAS DISCUSSION:

RAP Section 6.3, page 6-4 of the RAS (Processing Site)is tit led " Evaluation of Radon Barrier;" however, there is no evaluation. Also, this section does not refer to another part of the RAP as to where the evaluation can be found.

ACTION NEEDED:

DOE should provide the aforementioned evaluation for RAP Section 6.3 of the RAS, or revise the existing section accordingly.

6. COMMENT: Missing Information in Attachment 4 DISCUSSION:

In Attachment 4 (Processing Site) the title pages for the sections labeled " Soil Verification Using Cobbles-to-Fines Correction" (OP-003-4) and " Uranium Cleanup and Verification at Naturita" (RAC-OP-007) indicate the inclusion of DOE /NRC correspondence; however, this information was not included.

ACTION NEEDED:

DOE should either provide the referenced correspondence or revise the existing title pages accordingly.

[ Anne Rrmirez - Nat_, rap.com Page 4 }

7. COMMENT: Conflicting Data in Attachments 1 and 4 DISCUSSION:

Both Attachments 1 and 4 (Processing Site) contain conflicting data in the sections labeled " Contaminated Material Excavation - Cobbles-to-Fine Ratio" (Calc.

17-730-03-02) and " Cobbles-to-Fine Test Pit Analysis," respectively. Specifically, both sections contain Calc. 17-730-03-02; however, Sheet 7 of Attachment 4 was not

! updated from the previous version of the calculation.

ACTION NEEDED:

DOE should revise both referenced sections in Attachments 1 and 4 in order to be l consistent, or delete any duplicable data that is conflicting in either section.

8. COMMENT: Incomplete HistoricalInformation and Missing Evaluation in Attachment 4 DISCUSSION:

l l

The section labeled " Cobbles-to-Fine Test Pit Analysis" in Attachment 4 (Processing l Site) contains a table of uranium and radiurn data from the cobbles-to-fines test pits.

l This data sheet was also provided to the NRC in 1996 as part of a response to issue 19 regarding the characterization of uranium and Th-230. However, DOE's evaluation j of the data was not provided. Based on its review, the NRC staff determined the data {

demonstrates that tailings material exists at 6 to 9 feet deep, or that the in-situ i mineralized materialis not in equilibrium. Additionally, Appendix B of the " f Cobbles-to-Fine Test Pit Analysis" section contains data (see Sheet B-9) showing Th-230 concentrations from the test pits; however, there is no indication of the sample depth or the corresponding Ra-226 value.

ACTION NEEDED:

DCE should provide a discussion in the referenced section regarding the site history of process-related uranium and Th 230, and where they may exist at higher concentration levels (pCi/g soil) than the Ra-226. An evaluation of all uranium and Th-230 data for the site should also be provided.

9. COMMENT: Incomplete Data and Missing Supplemental Standard Application DISCUSSION:

The section labeled

Radiological Data Collected During Excavation of Uranium Under Former Mill Site" in Attachment 4 (Processing Site) consists of a DOE trip report, dated ,

July 28,1997, that includes some analytical data indicating Area 2 was excavated to l the water table; however, .ilevated uranium levels were still present. Additional testing j is recommended in the report. Mention is also made in the report where State of Colorado staff feel that adapting the generic thorium protocol for uranium is

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Page 5 l inadequate.

ACTION NEEDED:

DOE should provide the supplementalSundad a;#icaten ter uranium in the RAP and l include the additional data collected, arwell as the heah andysis per its commitment in Section 6 of the RAS Report DOE should also ir,dicate.wbare in the RAP it proposes to adapt the thorium protocottor uranium

10. COMMENT: Calculation 17-730-ObO2 (Excavation Extent & Depths, Volume, Ra-226)in Attachment 1 DISCUSSION:

l Appendix D of Attachment 1 (Processing Site) contains estimated Ra-226 I concentrations for windblown Areas F and G. However, there are elevated levels (32 to 213 pClig) at depths of 12 to 42 inches. Based on these depths, this does not appear to be windblown.

ACTION NEEDEP-1 DOE should explain why there is elevated Ra-226 at depths greater than 1-foot in these " windblown areas," and why the full depth of the contamination was not characterized.

11. COMMENT: Calculation 17-730-02-04 (Proposed Supplemental Standards Areas)in Attachment 1 DISCUSSION:

The summary of proposed areas for Supplemental Standards is on Sheets 2 and 3 in Attachment 1 (Processing Site). Comparison to the previous version of this calculation indicates that windblown Area B is no longer mentioned.

ACTION NEEDED:

DOE should indicate if the Supplemental Standards area in Area B is encompassed by the state right-of-way for the highway (NT-058), or if the contamination was removed.

12. COMMENT: Conflicting Supplemental Standards Information in Attachments 1 and 4 DISCUSSION:

The proposed Supplemental Standards area (Processing Site) for vicinity property (VP)

NT-065 on sheet 16 of Attachment 1 (Calc.17-730-02-03) do not match the same Supplemental Standards area delineated on the map in Attachment 4. It is not clear which map is correct.

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ACTION NEEDED:

DOE should revise the maps in Attachments 1 and 4 to ensure that the Supplemental Standards area for VP NT-065 is consistent and accurate.

13. COMMENT: Missing Supplemental Standards Information in Attachment 4 DISCUSSION:

The section labeled " Supplemental Standards Areas for Naturita Processing Site and Surrounding Vicinity Properties"in Attachment 4 (Processing Site) contains a map )

indicating areas proposed for Supplemental Standards -- one of which includes a small )

area around power poles near the gas line within the former tailings area. The l associated calculation does not address this area.

ACTION NEEDED:

DOE should provide the necessary information to include the referenced area as part of its proposed Supplemental Standards area.

14. COMMENT: Missing Supplemental Standards Information in Attachment 1 DISCUSSION:

)

in Appendix C of Attachment 1 (Processing Site), Sheets C-17 and C-20 indicate that VP NT-065 Areas E and G contain windblown contamination that average.s 111 and 46 pCi/g Ra-226, respectively. Additional Ra-226 data for Areas E, F, and G are in Calculation 17-730-01-02, which indicates contamination extends to 42 inches in depth l or beyond.

ACTION NEEDED:

When DOE provides the Supplemental Standards application for VP NT-065, the !

discussion of Areas E and G should consider if the depth of the elevated Ra-226 levels are due to in-situ material, or provide an explanation why there is contamination greater than 2 feet deep. Additionally, DOE should provide a map clearly indicating the property lines for VP NT-065 and the excavated portions of Areas E, F, and G, and include all Ra-226 data as appropriate.

15. COMMENT: Missing and Conflicting Supplemental Standards Information in Attachment 1 DISCUSSION:

I Sheets 9 and 10 of Attachment 1 (Processing Site) indicate that Supplemental Standards are proposed within 5 feet c' the gas line in Area E. Area E appears to be part of VP NT-065, but the gas line is not listed under this property. Also, Sheet B-21 of Appendix B indicates that there will be no excavation within 10 feet of the gas line.

In contrast, Sheet F-2 of Appendix F (phone record dated November 11,1992)

{ Anne Ramirez - Nit _ rap.com __

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' indicates that excavation must be by hand 3 feet on either side of the line.

. ACTION NEEDED:

DOE should indicate what property the gas line is on and confirm that the discussion on l Sheets 9 and 10 of Attachment 1 is correct in stating that Supplemental Standards will l be applied to the area 5 feet on either side of the gas line.

16. COMMENT: Missing and Conflicting Data in the RAS and Attachment 4

- DISCUSSION: i Table 1.1 of the RAS (Disposal Site) lists contaminated material types and volumes at the Naturita site. The section labeled " Site-Specific Hazardous Constituents"in Attachment 4 (Processing Site) provides a more comprehensive list of hazardous, ,

materials at the Naturita site. There appears to be a discrepancy in volume amounts i for some hazardous constituents between the two sections of the RAP. Also, DOE has provided little or no discussion in either RAP section as to how disposal of this contaminated material has met regulatory, safety, and environmental requirements.

ACTION NEEDED:

DOE should provide some discussion in both referenced sections of the RAP regarding hazardous waste disposal, and show how this disposal met regulatory, safety, and environmental requirements. DOE should also update disposed volume amounts in all relevant portions of the RAP.

17. COMMENT: Conflicting Information in Sections 6.2 and 6.4 of the RAS DISCUSSION:

In Section 6.2 of the RAS (Disposal Site), it is unclear in the fourth paragraph as to what thickness of radon barrier will be placed on the top slope of the disposal cell

. (Section 6.4 states there will be the same thickness on the top and sides).

I ACTION NEEDED:

- DOE should revise the fourth paragraph of RAS Section 6.2 so that it states the cover !

layers and thicknesses are the same for the top and side slopes.

18. COMMENT: Incorrect References in Sections 6.3 and 7.0 of the RAS i

l . DISCUSSION:

L In Section 6.3 of the RAS (Disposal Site), the second line indicates the wrong reference for the RADON code. It should appropriately reference "NRC 1989." Also, Section 7.0 of the RAS should be revised to replace the NRC 1984 reference with " Calculation of Radon Flux Attenuation by Earthen Uranium Mill Tailings Covers," NRC Regulatory t-

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Guide 3.64, July 1989. The 1984 document discusses the RAECOM code.

ACTION NEEDED:

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c DOE should revise Sections 6.3 and 7.0 to incorporate the correct reference as j l

( mentioned above.

19. CO' AMENT: Inconsistent Radon Attenuation Data l

DISCUSSION: )

I' In Section 6.3 of the RAS (Disposal Site), th'e last sentence indicates that radon flux code input parameters are presented in Appendix F, NAT-CALC-010. However, Section 6.3.4 presents densities and specific gravity input values for the former tailings pile area and the windblown material that don't match the values used in NAT-CALC-010.

[

ACTION NEEDED:

DOE should ensure that parameter values presented in the radon attenuation section l match values used in the radon flux modeling calculation.

20. - COMMENT: Unreadable Map in Appendix 1 DISCUSSION:

Sheet 10 of RAP Appendix 1 (Disposal Site)is a xerox copy of a foIded map. The copy J

j of this map is unreadable in this state.

ACTION NEEDED:

DOE should provide a full copy of the map.

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Mr. George Rael, DireStor

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, U.S. Department of Energy -

1 Albuquerque Operations Office; ERD /UMTRA .

P.O.- Box 5400 Albuquerque, NM 87185-5400

SUBJECT:

REVIEW OF NATURITA REMEDIAL ACTION PLAN

Dear Mr. Rael:

The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of the Naturita, Colorado final Remedial Action Plan (RAP) for both the processing and disposal sites, which were transmitted by U.S. Department of Energy (DOE) via transmittal letters dated April 10 and June 12,1998. Enclosed are the NRC staff comments, which cover the technical areas of groundwater hydrology, surface water hydrology and erosion protection, and soil clean-up) radon attenuation. All other technical areas of the Naturita RAP were considered acceptable -

by the NRC staff.

3 If you have any questions concerning this subject,' please contact Mr. Robert Carlson of my l

staff at (301) 416-8165..

Sincerely, Joseph J. Holonich,- Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards 4

Enclosure:

As stated l r

cc: R. Comish, DOE Alb ;

F. Bosiljevac,- DOE Alb l E. Artiglia, TAC Alb a '

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a

' Mr. George Rael, Director

. U.S. Department of Energy -

Albuquerque Operations Office ERD /UMTRAL

. P.O. Box 5400 Albuquerque; NM 87185-5400

SUBJECT:

- REVIEW OF NATURITA REMEDIAL ACTION PLAN

Dear Mr. Rael:

The U.S. No"1r Regulatory Commission (NRC) staff has completed its review of the Naturita, Colorado finali.tmedial Action Plan (RAP) for both the processing and disposal sites, which .

. were transmitted by U.S. Department of Energy (DOE) via transmittal letters doted April 10 and June 12,1998.' Enclosed are the NRC staff comments, which cover the technical areas of '

groundwater hydrology, surface water hydrology and erosion protection, and soil clean-up and radon attenuation.' All other technical areas of the Naturita RAP were considered acceptable '

by the NRC staff.

If you have any questions concerning this subjectiplease contact Mr. Robert Carlson of my '

~

staff at (301) 415-8165. l

{

Sincerely, Joseph'J. Holonich, Chief Uranium Recovery Branch. .

Division of Waste Management Office of Nuclear Material Safety and Safeguards

Enclosure:

As st'ated cc: R. Cornish, DOE Alb F. Bosiljevac, DOE Alb

E. Artiglia, TAC Alb DISTRIBUTION (w/ encl): File Center PUBLIC NMSS r/f URB r/f EBrummett CCain, RIV CNWRA ACNW AGarcia BFord TJohnson

- (w/o encl): MWeber ' CAbrams MLayton

' DOCUMENT NAME: S:\DWM\ URB \RDC\NAT;_ RAP.COM OFC- URB l URB URB l l l NAME RCarlson DGillen - JHolonich l DATE. / . /98 l / /98 l / /98 l. l l OFFICIAL RECORD COPY

l AnniRimirez - N060898a.wpd A Pageij ms COMMENTi Concentration Limit for Strontium and Tin at Upper Burbank Disposal Site DISCUSSION: Table 3.1 of Appendix C of U.S. DOE,1998, identifies groundwater quality concentration limits for strontium and tin at the Upper Burbank Disposal site. According to the table, these limits were derived from ground water quality collected at the disposal site from wells CM-93-1 and CM-93-2. However, data on strontium and tin concentrations are not reported in the tables of site water quality data (Tables of " Groundwater Analyses, CM-93-1, CM-93-2, Burbank Repository", Appendix B, U.S. DOE,1998. Therefore, it is not clear how concentration limits for these parameters were derived.

ACTION NEEDED: Provide on-site water quality data collected for strontium and tin to establish the concentration limits in Table 3.1 or describe how data to derive concentration limits will be obtained.

REFERENCES:

U.S. Department of Energy,1998, " Remedial Action Plan and Site Design for Stabilization of the Naturita Title l Residual Radioactive Materials at the Upper Burbank Repository, Uravan, Colorado", March.

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_WaLTON - B'7 NO. OF COLUMNS = 10.

NO. OF ROWS = 10 GENERAL DATA BASE:

Number'of simul'ation periods for which drawdown or recovery is to be calculated 1 Simulation period number: 1 Duration of' simulation period in days: 1.000 Number of grid columns: 5 Number of grid rows: 5 Grid spacing in ft= 10.00 X-coordinate of upper-left grid node in ft: 0.00 Y-coordinate of upper-left grid node in ft= 0.00 Simulation period number = 1 Number of production, injection. and image wells active during simulation period: 1 Well number: 1 X-coordinate of well in ft: 30.00 Y-coordinate of well in it: 30.00 Well discharge in gpm: -0.10 Duration of pump operation during simulation pericd in days: 1.000 Well radius in ft: 0.50 Number of observation wells ror which time-I drawdown tables are desired 1 Observation well number: 1 I-coordinate of observation well: 4 ;

J-coordinate of observation well: 4 j Aquifer transmissivity in gpd/ft: 0.v4 )

Aquifer storativity as a decimal: 0.000100 {

NODAL COMPUTATION RESULTS: ;

l SIMULATION PERIOD DURATION IN DAYS: 1.000 1

VALUES OF DRAWDOWN OR ' RECOVERY ( FT ) AT NODES:

J-ROW I-COLUMN 1 ;2 3 4 5 6 7 8 9 10 l 1 -0.00 -0.07 -0.37 -0.67 -0.37 2 -0.07 -1.22 -8.02 -15.73 -8.02 3 -0.37 -8.02 -70.58-180.10 -70.58 4 -0.67 -15.73-180.10%-1965.38-180.10 5 -0.37 -8.02.-70.58-180.10 -70.58 l

.4

'0BSERVATION- WELL COMPUTATION RESULTS WITH FULL WELL PENETRATION.AND WITHOUT WELLBORE STORAGE:

TIME-DRAWDOWN OR RECOVERY TABLE OBSERVATION WELL NUMBER: 1 )

' TIME (DAYS) DRAWDOWN OR RE00VERY(FT) 1.000 -1965.38

' GENERAL' DATA BASE: i Number of simulation periods for which drawdown or recovery is to be calculated 1~

Simulation period number: 1

-Duration of simulation period in days: 1.000 Number.of grid columns: 10 Number of grid rows: 10 GrilEspacing in ft: 10.00 X-coordinate of upper-left grid node in it: 0.00

.Y-coordinate of upper-left grid node in ft 0.00 Simulation period number: 11 Number of production, injection, and image welic active during simulation period: 1 Well number: 1 X-coordinate of well in ft=~ 3u.00-(-coordinate - of well in ft: 30.GG Well' discharge in gpm: -0.lu Duration of pump operation during simulation period .

in: days: 1.000

.Well radius in ft= 0.50 Number of observation wells for which time- '

drawdown tables are desired 1:

Observation well number: 1 I-coordinate of observation well: 4 J-coordinate'of observation well: 4 Aquifer transmissivity in gpd/ft=' O.04 Aquifer specific yield as a decimal: 0,010000 NODAL COMPUTATION RESULTS:

SIMULATION PERIOD DURATION IN DAYS: 1.000 VALUES OF DRAWDOWN OR RECOVERY ( FT) AT NODES:

J-ROW 1-COLUMN 1 2 3 4 5 6 7 8 9 10 1 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2 0.00 0.00 0.00 0.00 0.00~ 0.00 0.00 0.00 0.00 0.00 3 10.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 4 0.00 0;00 0.00-482.17 0.00 0.00 0.00 0.00 0.00 0.00 6 0.00' O.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

<6 0.001 0.00 0.00 0.00 0.00 0.00 0.00 0.00. ~0.00 0.00 7 0.00- 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8 0.00 0.00- 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 9 0.00 0.00- 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 10; 0.00 0.00 0 00

. 0.00 0.00 0.00 , 0.00 0.00 0.00 0.00

2 SERVAT 10N WELL COMPUTATION RESULT 5 WiIti FULL .vhLL PENETRATION AND WITHOUT WELLBORE STURAGE:

i'IME-DRAWDOWN OR' RECOVERY TABLE OBSERVATION WELL-NUMBER: 1 l'IME( DAYS ) DRAWDOWN OR RECOVERY lLU:,

1.000 -482,17 i

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r Table 8.1 Constituents and detection limits for water analysis a Laboratory method Laboratory method detection detection Constituent limit (mg/1) Constituent limit (mg/1)

Major Anio_n_1 ' Cyanide 0.01 Bicarbonatt 1.0 Iron 0.03 Carbonate 1.0 Lead 0.01

/ Chloride 1.0 Manganese 0.01 sSulfate 0.1 Mercury 0.0002

/ Fluoride 0.1 Molybdenum 0.01

/t!itrate 1.0 Nickel 0.04

~ Nitrite 0.1 /Seleniun 0.005

, Nitrate ~and Nitrite 1.0 Silver 0.01

' Phosphate 0.1 (as P) ' Sulfide (as H 2S) 0.1

< Strontium 0.1 Maior Cations # Thallium 0.01

/ Ammonium 0.1 Tin 0.005 Calciu.n 0.01 Uranium 0.003 Magnesium 0.001 Vanadium 0.01

. Potassium 0.01 Zinc 0.005

. Sodium 0.002 .-Total dissolved solids 10.0 M ilica 2.0 Oroanic Hazardous Constituentsb Minor and Trace Constituentsc (ma/1)

Aluminum 0.1 . Total organic carbon 1.0

/ Antimony 1

0.003 l Arsenic 0.01 Radionuclide (DCi/1) I Barium 0.1 Gross alphad 1.0 Beryllium 0.01 Gross betad 0.5 Boron 0.1 Lead-210 1.5 Bromide 0.1 Polonium-210 1.0

< Cadmium 0.001 Radium-226 1.0

' Chromium 0.01 . Radium-228 1.0

< Cobalt 0.05 , Thorium-230 1.0

, Copper 0.02 afield parameters including temperature, total alkalinity, pH, and specific conductance will be measured. Dissolved oxygen, Eh, and redox couples may be measured at specific work sites for further characterization. mg/l =

milligrams per liter.

bAppendix IX of 40 CFR 264 will be analyzed to satisfy the requirements of organic analyses required in Appendix I of 40 CFR 192.

cElemental concentrations ill be analyzed to satisfy the requirements of l' 40 CFR 192.

dThese analyses must be determined on samples with less than 500 mg/l total dissolved solids.

Note: Detection limits above are those specified to laboratories subcontracted to p:i form analyses for the UMTRA Project. These levels are considered reasonably achievable, and consistent with Project goals and regulatory requirements.

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Table 8.1 Constituents and detectka limrts fur oder amilysis a l Laboratory method k b boratory method detection detection Constituent limit (mg/1) Constituent liimit (mg/1)

Ma_ior Anions Cyanide 0.01 Bicarbonate 1.0 Iron 0.03 Carbonate 1.0 Lead 0.01 Chloride 1.0 Manganese 0.01 Sulfate 0.1 Mercury 0.0002 Fluoride 0.1 Holybdenum 0.01 Nitrate 1.0 Nickel 0.04 '

Nitrite 0.1 Selenium 0.005 Nitrate and Nitrite 1.0 Silver 0.01 Phosphate 0.1 (as P) Sulfide (as H25) 0.1 Strontium 0.1 Ma_ior Cations Thallium 0.01 Ammonium 0.1 Tin 0.005 Calcium 0.01 Uranium 0.003 Magnesium 0.001 Vanadium 0.01 Potassium 0.01 Zinc 0.005 Sodium 0.002 Total dissolved solids 10.0 Silica 2.0 Oroanic Hazardous Constituentsb

iinor and Trace Constituentsc (mo/1)

Aluminum 0.1 Total organic carbon 1.0 Antimony 0.003

)

Arsenic 0.01 Radionuclide fCi/1)

Barium 0.1 Gross alphad 1.0 Beryllium 0.01 Gross betad 0.5 I

Boron 0.1 Lead-210 1.5 Bromide 0.1 Polonium-210 1.0 Cadmium 0.001 Radium-226 1.0 Chromium 0.01 Radium-228 1.0 Cobalt 0.05 Thorium-230 1.0 Copper 0.02 afield parameters including temperature, total alkalinity, pH, and specific conductance will be measured. Dissolved oxygen, Eh, and redox couples may be measured at specific work sites for further characterization. mg/l =

milligrams per liter, bAppendix IX of 40 CFR 264 will be analyzed to satisfy the requirements of organic analyses required in Appendix I of 40 CFR 192.

cElemental concentrations will be analyzed to satisfy the requirements of 40 CFR 192.

dThese analyses must be determined on samples with less than 500 mg/l total dissolved solids.

Note: Detection limits above are those specified to laboratories subcontracted to perform analyses for the UMTRA Project. These levels are considered reasonably achievable, and consistent with Project goals and regulatory requirements.

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~) l MEETING ON NATURITA/URAVAN OPTIONS i

On January 26, 1995, representatives of the U.S. Department of Energy (DOE) met with NRC Division of Waste Management and Office of State Programs staff to discuss the disposal of residual radioactive material from the Naturita, .

Colorado, Title I site. Representatives of the State of Colorado were linked l into the meeting via telephone. The meeting was held at DOE's request for DOE i representatives to present its options for placement of the Naturita material I at the Umetco Uravan site in Colorado. The staff will meet to discuss its i position regarding disposal of the Naturita tailings on February 3,1995.

Following that meeting, rians are to meet with DOE and other interested parties on February 9, 1995.

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MEElING WITH REPRESENTATIVES OF THE GEMRlME.UJ DF ENERCV URANIUM MILL TAILINGS

' REMEDIAL ACTION PROJECT-0FFICE On January _ 5,_1995, Division of Waste Managenerat shff_ and a representative of the Office of the General Ccusel : met with re7reser;tatives of the Department of- Energy (DOE) Ura:Ju Mill Tallings Remedial Action -(UMTRA)

' Project Office to discuss.the status of activit-ies related to the clean-up of various Title 1. sites. Discussions predninantly focused on site'-specific issues related to the Naturita, Colorado, site. For the Naturita project, DOE had originally. proposed moving the contaminated material' to a site located at Dry flats, Colorado. .However, the current proposal is to move the material to a separate cell on the Umetco Minerals Corporation Title II facility property at Uravan, Colorado. Although the Uravan site is licensed by the State of

. Colorado:as an Agreement State, the staff indicated that placement of Title I material in a separate pile at that location would still require land acquisition-and site characterization by DOE and review of the design by the NRC, as is the case for normal Title I remedial actions. The NRC staff agreed to' follow-up the meeting with a letter describing NRC's position regarding its role if DOE uses _ the Uravan option for the Naturita remedial action. In addition, the attendees discussed specific aspects of the Canonsburg, Pennsylvania, site, and generic issues related to land transfer concurrence actions and the definition of residual radioactive material after the UMTRA Project is terminated.

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i COLORADO DEPARTMENT OF PUBLIC IIEALTIl t ENYlRONMENT llazardous Materials & Waste Management Division INTEROFFICE COMMUNICATION TO: All concemed narties FROM: Jeff Deckler

((

DATE: August 25,1995

SUBJECT:

UMTRA Statutory Changes Enclosed is a.first draft of proposed statutory changes and short explanations of the issues. As we discussed in the August iI meeting. I have tried to tie these issues to closure of the program. Please take a look and give me your comments as soon as possible. I am specifically interested in comments from NRC regarding whether the Title 1/ Title 11 change is what they need to allow us to proceed under Title !! at Naturita.

Other language has been floating around lately, and I would caution everyone that we need to develop one set of langurge that we all agree to. The only way to do this is by having one person responsible for coordinating the effort and drafting the language. I would like to be the person responsible for this, and suggest at all language and comments corre through me as the focal point. When we finalize the language, I i will then pass it on to Dave Blair for introduction into SB 341. ]

You may FAX comm nts to me at (303) 759-5355,o, mail them to l 1

Colorado Department of Public ilcalth and Environment ;

liazardous Materials and Waste Management Division 4300 Cherry Creek Drive South - IIMWMD-B2 Denver, Colorado 80222-1530 cc: Joe llolonich, NRC !W Tom Crandall, DOEeDL (301) 427 1823 Steve !{ amp, DOE /AL (505) 845-4023 Jim Lampley, DOEiGJ (970) 248-6040 Craig Glogowski Sen. Brown /GJ Lee Miller Sen. Brown /DC (202) 224-6471 Dave Blair, Sen. Campbell /DC (202)224-1933 Senator Tilman Bishop (970) 243-9676 Senator Don Ament (303) 866-2012 Rep. Russell George Rep. Ken Chlouber Steve Colby DOLA (303) 666-2251 Dick Guay, JEG (703) 358-8821 Jim Monaghan, Monaghan & Assoc. (303) 592-8910 Bruce Phillips. Elder & Phillips (970) 243 8743 Howard Roitman. CDPilE/ Den Bud Franz, CDPIIE/GJ l

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3. Title I / Title 11 l Title I and Title 11 of UMTRCA are essentially equivalen:. The technical requirements are the same.

flowever, since Title 11 regulatory responsibilities can be designated to states, the states may be the l concurring authority, whereas under Title I the NRC is always the concurring authority. At the Naturita l Title I site,it has been determined that the most cost effective solution is to dispose of the material at the nearby Uravan Title 11 site, which is licensed to accept this material, The local community strongly supports l 6.s uernative. Ilowever, NRC will not allow this disposal u,nder the Title 11 license, because they feel l respons6le under Title I to concur on the plan. This decision by NRC is costing the project millions of dollars :n delayed review, and in property acquisition costs required under Title. Since disposal under the Title 11 license will be faster and willcost less,it is recommended that the following be added to Section 108(a)(1):

l Residual Radioactive Material from processing sites designated under this title may be disposed of l at licensed Title 11 facilities under the administrative and technical tequirements of Title 11. Such disposal shall be considered equivalent to the requirements of this title "

In order to insure that the disposal costs are an allowable expense. Section 115(a) should also be amended by adding the following.

"Nothing herein shall preclude the disposal of residual radioactive material at licensed sites or the expenditure of amounts for such disposal."

4. Lone Term Radon Man'acement The UMTRA program willleave over one milhon cubic yards of material at vicinityproperties nation-wide through the use of supplemental standards, averaging of hot spots, and failure to include shielded deposits which were missed. Approval of supplemental standards applications for a majority of these tailings is on hold by NRC, until a long term plan is in place to manage these tailings when they are redisturbed in the future. DOE and the affected states and tnbes have worked out a plan for this long term management which is cost effective, addresses the problem of tailings management for the local communities, and allows closcout of the program by facilitating approval of supplemental standards applications by NRC in order to implement the program, DOC must obtain authority to continue operation the Cheney disposal cell in Grand Junction, Colorado. It is recommended that the following language be added to Section 112(ah "The Secretary shall be authorized to continue operation of the Cheney disposal cell in Grand Junction, Colorado until such time that residual radioactive matenal from vicinityproperties as defined by this title fills the cell to its designed capacity."

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ML20217P306

Contents

Text

Subject:

Dear Robert,

SUMMARY

SUMMARY

Dear John,

SUBJECT:

Dear Mr. Rael:

Enclosure:

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Dear Mr. Rael:

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ML20217P306

Text

Subject:

Dear Robert,

SUMMARY

SUMMARY

Dear John,

SUBJECT:

Dear Mr. Rael:

Enclosure:

SUBJECT:

Dear Mr. Rael:

Enclosure:

REFERENCES:

SUBJECT:

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