ML20247H272
| ML20247H272 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1984 |
| From: | Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hazle A COLORADO, STATE OF |
| Shared Package | |
| ML20197H170 | List: |
| References | |
| FOIA-89-242 NUDOCS 8907280329 | |
| Download: ML20247H272 (6) | |
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DISTRIBUTION SIS 6/ HAP /84/08/06/0 URF0 s/f SIS 6 URF0 r/f JCollins MG13 M PGarcia URFO: HAP SIS 6 Albert J. Hazle, Director Radiation Control Division Colorado.. Department of Health 4210 East lith Avenue Denver, CO 80220
Dear.Mr. Hazle:
We have reviewed your April 27, 1984 letter to Union Carbide Corporation rejecting their proposal for the Spring Creek Mesa tailings impoundment.
We agree that any new tailing impoundment to be licensed at this time must meet the standards of both.40 CFR 192 and the State of Colorado..
If the proposed plan does not meet both standards, then other alternatives should be considered.
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We have also completed our review of the Preliminary Executive Licensing Review Summary (PELRS) for the Uravan Uranium Mill. We have enclosed our comments on the document.
If you have any questions, please contact me at 234 7232.
Sincerely, b
R. Dale Smith, Director Uranium Recovery Field Office Region IV
Enclosure:
As Stated i
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Case Completed:
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s NRC Comments on Uravan PELRS 1.
Section 4.4.2.1.1 UCC states that the plant superintendent is responsible "for approval and adherence to procedures for operation of the plant in reference to the ALARA concept as well as deciding what actions are to be taken in cases of unusual exposures." The CDH has responded that the renewal will include a condition giving the RSO authority to immediately halt any operation deemed unsafe.
It is not clear what position in the millsite hierarchy the plant superintendent holds or to whom the RSO reports.
The individual with overall responsibility for adherence to the ALARA concept and employee occupational safety should be the highest corporate official onsite.
If the plant superintendent is not the highest corporate official onsite, then the delegation of responsibility for radiation safety matters to the plant superintendent is not acceptable. This should be clarified.
Further, the line of authority between the RSO and the highest corporate official onsite should include no positions having production responsibilities.
This should be specifically addressed.
2.
Section 4.5.2.1.2 This section addresses the discharge of liquid, including filtrate from the yellowcake precipitation circuit and seepage from the hillside collection system to the San Miguel River under WQCD Permit C0-0000515. The section indicates that "although the facility has an earlier history of spills and operational difficulties in meeting conditions of previous permits by exceeding permit limits for ammonia, TSS, TDS, uranium, radium-226, pH, zinc and iron, current data indicate an improvement in operations resulting in few violations within the past two years." While this may indicate some improvement, the discharge of liquid to the San Miguel River is not consistent with the ALARA concept (for example, uranium values downstream of the mill for the period 1978-1982 show a 70% increase over upstream values).
Serious consideration should be given to a requirement for immediate cessation of discharge to the river, and further consideration should be given to water conservation measures l
such as recycling to the mill.
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3.
Section 5.4.1.4 This section states that the closest monitor well to the River Ponds is 1600 feet from the ponds. Closer wells are needed to assess the impact from the ponds. This is especially true since Section
.5.4.2.4 states that the ground water monitoring system will determine the need for remedial actions if natural processes are not adequate to clean up ground water.
4.
Section 5.4.2 The River Ponds consist of seven separate ponds while six separate ponds comprise the Club Ranch Ponds, Although it is stated that discharge to these ponds will cease by July 1, 1985, consideration should be gi/en to a phased cessation of discharge (i.e., half of the ponds will not be used after January 1, 1985). This will result in a reduction of impacts to ground water as several of the ponds will dry sooner.
5.
Section 5.5.2.3 This section discusses compliance with the 40 CFR 190 dose standard.
An effort should be made to quantify,the dose resulting from current milling activities. For example, the air particulate sampler located west of Tailings Pond #2 (see Section 4.6.1.1) could be relocated east of Tailings Pond #2 to provide some data on the contribution of the sources on the mesa (i.e., ore pads, tailings ponds, crusher stacks, etc.) to doses in the town of Uravan. More frequent sampling of the yellowcake stack could provide data on the contribution of sources in the valley as can data comparing concentrations during operations and during periods of mill
. shutdown. Without this data, the licensee and the CDH will be unable to determine compliance with the standard and proposed License Cor'dtion 18.6.1.
6.
Section 5.5.3.4 The discussion in Item 5 of this section regarding the possible L
placement of a radon-limiting cover on the face of. piles 2 and 3 is not clear.
The cover should be placed as soon as practicable.
The placement of the cover material should be a license requirement.
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7.
Section 5.6.3 It is stated that the preliminary licensing decision does not include authorization for the proposed new disposal site.
Yet, it is stated elsewhere that use of the existing tailings pend will cease by July 1, 1985.
It does not. appear that there would be adequate time for regulatory review of an alternative proposal and construction of the approved facility in order to begin dircharge i
f of tailings on July 1, 1985 if the licensee desired to operate the mill. This issue should be discussed in the text and consideration given to including in the renewed license a requirement for submittal of an alternative proposal. The submittal of the proposal should allow adequate time for review and construction.
8.
Section 5.7.2 The discussion under Criterion 4 does not seem logical.
It is stated that reduction of slopes from 3H:1V to 5H:1V would remove outcr embankment material that provides the basic stability of the p'.es.
Reduction of slopes should result in addition of material, not removal. Unless physical constraints make impossible the flattening of slopes, all such slopes should be flattened to SH:1V.
9.
Section 5.7.2 The discussion under Criterion 5 indicates that "the reclamation plan will continue to collect seepage from the toe of the impoundments and along the mesa rim...."
No information is provided regarding how the seepage water will be disposed. Recycling back to the piles will greatly affect the drying time required before placement of the reclamatica cover can proceed while discharge to the river is not considered acceptable (see Comment 2).
10.
Sections 9.5.1.2, 9.5.2.2, 9.5.3.2, 9.6.2.2 Visual examination is not an acceptable method for determining extent of soil contamination. This option should be deleted from cleanup requirements.
In addition to the scintillometer readings, e.nalysis of soil samples for Ra-226 content should be required in accordance with the EPA 40 CFR 192 standard.
- 11. Section 9.5.2.3 The reclamation schedule for the Atkinson Creek Disposal Area requires that the licensee begin the renoval of contaminants by January 1, 1992. To minimize leaching of the raffinate crystals and resulting impacts to ground water, the removal activities should
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commence in the very near future.
There does not appear to be a valid reason for postponing cleanup activities until 1992.
13 Section 9.6.1.2 The information regarding the side slope cover does not present the criteria by which the reclamation cover was designed.
The EPA 40 CFR 192 standard specifies radon attenuation and longevity i
criteria which must be met. The proposed reclamation plan should be evaluated against those criteria.
14 Section 9.6.2.3 The reclamation plan for the Club Mesa Spray Area calls for cessation of spraying by July 1, 1985, and initiation of contaminant removal activities by January 1,1990. The cessation of spraying should be effective immediately, and the removal of contaminants should commence in the very near future.
The sprays to accelerate evaporation should be moved to the tailings beaches, where they will help minimize blowing.
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Dat, o' Docuoset o.t...r. sw.o no
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Relicensing of UCC's Uravan l
facility.
PGarcia 5/11 f13l8$
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Due date:
5/25/84 Staff hours: 3 u 5 %vc6taa.. cut.fon. couuission so.
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