ML20248C593
| ML20248C593 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1984 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20248C571 | List:
|
| References | |
| FOIA-89-242 NUDOCS 8908100097 | |
| Download: ML20248C593 (9) | |
Text
. - . .
7
\- ~.,
h 1' - G.
l'< .
Ref: SA/JFK s gg,p 2e BM
-t N t
~
MEMORANDUM FOR: John T. Collins Regional Administrator Region IV FROM: G. Wayne Kerr, Director Office of State Programs
SUBJECT:
REGION IV PROPOSAL FOR RESPONSE TO EDF LETTER TO CHAIRMAN CONCERNING RADIATION EXPOSURES IN URAVAN, COLORADO -
This is in reference to your memo of September 14, 1984 resulting from the September 6 meeting with you and your staff on the above subject.
At that meeting, it was agreed that Region IV would prepare the letter of findings to the State. We also agreed that the response to EDF should be prepared by Region IV. So as not to hold up inordinately long on the finding, we believe the letters to, Colorado and to EDF should be completed and dispatched by October 31, 1984.
Upon review of the proposed plan, it is our opinion that Region IV has most, if not all, the necessary infomation to prepare letters to Colorado and the EDF.
Information available to Region IV, i.e., special study group report, supplemental information from members of study group, and information gained from the recent periodic review, should allow one person to prepare the necessary letters. Another comittee should not be necessary and if any additional infomation needs to be obtained, Region IV should da so.
Regardit.g the proposed timetable, Attachment 1, the following coments are offered:
- 1. Item 1 - This task can easily be completed by the Region IV State Agreement officer with inputs .already provided. -
2,. Item 2 - This step is probably not necessary, but if Region IV feels a meeting at the staff level is required, they should proceed to do so promptly.
- 3. Item 3-WedonotbelievethattheEDFconce[nhedd preclude a finding of adequacy and compatibility for t Colorado program. If a finding can't be made its for s s other reason. OSP believes the study group report supports this view. ,
890s100097 890801 r PDR FDIA "
_._ BOLOTING9-242 PDR ,
ame r> l
.... . . . . . . . . . . . . . . .. . . + . *. * * . **
- T Of.T3 M e * * ' ' * ** ** *
.e e. . . . . . . . . . . . . . - .e * . * .
'1
-__m___ _ r-NNar Dn A n O' CON MN
T f
- .. -J i s
y
-4. ' Item 5 - how is Colorado to. provide assurance? What if licensee appeals the final license? Who is going to give the assurance, the Director of the Radiation Controi Division, the Director of Department of licalth, the Attorney General, the Governor? A statement by the State that it will pro:eed with the renewal and address the exposure situation in Uravan should be sufficient. Region IV would need to follow State actions.
Regarding the general subject areas Attachment 2. OSP believes Regien IV has the necessary information in hand to prepare the response to the State and EDF.
It is recomended that. Region IV prepare the review report, letter to Colorado, and response to EDF. The draft letter should be sent to members of the review team and study group members for verification of infomation contained in such letter / reports and, following this, final drafts should be sent to OSP for concurrence using the routine procedure. OSP will coordinate the letters with NMSS. Draf t letters should be completed by October 19, 1984 and office concurrence by October 26, 1984. The project should be completed by October 31, 1984.
N!!SS concurs with this approach. ,
G. Wayne err, Director Office of State Programs Distribution:
SA R/F Dir R/F gGWKerr DANussbaumer gUravan Colorado M n -NiflS$
file (fc) p I V r bAf
"""> ,,,NM$$
.....QQP ,,, , ,,,,,,,,,,,,,, ,,,,,,,,,,,,, ,,,,,,,,,,,,, ,,,,,,,,,,,,
DANu' baumer/bh. GWff, er.. ..JDavis..... .............. ............. ............. ............
-> .9/28/84...y. . 9 #f 84. . . ..9g/84... ............. ............. ............. . .......
.y.a
{ '
}
J. .
.. . .. Y 4. -Item 5 -. how is Colorado to provide assurance? What- if licensee appeals the final license? Who is going to give the' assurance, the Director of the Radiation Control Division, the Director of Department of Health, the Attorney General, the Governor? A statement by the State that it will proceed with the renewal and address the exposure situation in Uravan should be sufficient. Region IV would need to follow State actions.
Regarding the general subject areas. Attachment 2, OSP believes Region IV has the necessary information in hand to prepare the response to the State and EDF..
It is recommended that Region IV prepare the. review report, letter.to'-
Colorario, and response to EDF. The draft letter should be sent to members of the review team and study group members for verification of infonaation ~ contained in such letter / reports and, following this, final .
drafts should be sent to OSP for concurrence using the routine procedure. OSP will coordinate the letters with HMSS. Draft letters should be completed by October 19, 1984 and office concurrence by October 26, 1984. . The project should be completed by October 31,'1984.
HMSS concurs with this approach.
C G. Wayne err, Director Office of State Programs Distribution:
SA R/F
'Dir.R/F gGWKerr.
DANussbaumer Urava g Colorado d m*ile-A/ (fc) MSS l
i r
""C'> ... . ... ... 0$P ,, , , , NMM ,k f ,,,,,,,,,,,,, ,,,,,,,,,,,,, ,,,,,,,,,,,,, ,,,,,,,,,,,
' * * > DANuMbaser/bh. GWr#rr.. ..JDavis..... ............. ............. ............. .... .......
" ^ " > .9/28/84.... ..9N/64...
..9h/84...
DEd d 41985 Thomas M. Vernon, M.D.
Executive Director Colorado Department of Health 4210-East lith Avenue Denver, Colorado 80220
Dear Dr. Vernon:
This confirms the discussions Messrs. Ralph S. Heyer and Donald A. Nussbaumer
~I held with Dr. Arnott and Mr. Hazie of your staff on October.25, 1985, fnllowing our review of the Colorado radiation control program. The review covered the principal administrative and technical aspects of the program. This included an examination of the program's legislation and regulations, organization, management and administration, personnel, and licensing and compliance activities.
Our review used as a reference the Nuclear Regulatory Comission's (NRC)
" Guidelines'for NRC Review of Agreement State Radiation Control Programs,"
which was published in the Federal Register on December 4, 1981, as an NRC I Policy Statement. The guidelines contain 30 indicators for program evaluation.
A description of how the indicators are used in reporting the results of the program review to State management is enclosed (Enclosure 1).
Our review of the State's program and the routine exchange of infonnation program between the Nuclear Regulatory Commission (NRC) and the State of Colorado resulted in several cements concerning, " Technical Quality of Licensing Actions," a Category I indicator. These concerns are identified in Enclosure 3 to thi. letter. While each coment taken separately would not be a significant Category I coment we believe the number of coments made concerning this indicator justify a Category I comment. We believe that imediate steps are needed to achieve improvements in this particular program area. We would appreciate a response from you as to the type of action taken to improve the
" Technical Quality of Licensing Actions," including any coments you may have regarding the implementation of the Radiation Control Division's (RCD) policy on 40 CFR 190 compliance determinations. Specifically, we would like to know when the RCD intends to complete these determinations for its mill licensees.
In addition, we would appreciate any coments you may have regarding the decrease of staff years dedicated to the uranium mill program identified under the Category II indicator, " Staffing Level." Although this is a Category II indicator, the decrease of technical staff from 1.7 staff years found during :
the previous review, to .97 staff years has had an effect on two other program indicators, " Technical Quality of Licensing Actions" mentioned above and "Inspe'ction Reports," a Category II indicator. We believe deficiencies in these program areas may be attributable to the decrease in staff resources for j the uranium mill regulatory program.
RSHeyer/vT RJDoda / & Kerr WJ rcks RDMartin
's s
// /jf/85
~
11/p'/85 /yc/85 G/ Y/85 ll /q/85 45R@7t9Hg t.d;
~ y -
e.
'4-
. j
. Thomas M.-Vernon, M.D. c In view of these findings we cannot offer a staff opinion on the adequacy and compatibility of the program until we have received and evaluat'e(your 4
responses to our comments and recommendations. .
Enclosed with this letter are the specific comments regarding the technical-aspects of the program (Enclosures 2 and 3). You may wish to have Mr. Hazie respond directly to these comments. I am also enclosing a copy of this letter for placement in the State Public Document Room or to otherwise be made available for public review.
I appreciate the courtesy.and cooperation you and your staff extended to our representatives during the review meeting.
Sincerely.
- ORic NAL SlCNE gy ROBERT D. Manny Robert D. Martin Regional Administrator
Enclosures:
As stated cc w/encis:
Dr. Robert A. Arnott. Assistant Director Mr. Albert J. Hazle Division Director Mr. G. Wayne Kerr, Office of State Programs State Public Document Room NRC Public Document Room bec w/encls:
W. J. Dircks, EDO V. Stello, Jr. , DED/ROGR R. D. Martin, RA P. S. Check, DRA C. E. Wisner, PA0 R. L. Bangart, DRS&S R. E. Hall, RSPD W. L. Brown, RC R. J. Doda, SGAS G. F. Sanborn, SLO R. S. Heyer, SGAS,-
.D. A. Nussbaumer, SP Colorado File DMB for Distribution (SP01)
t-m., #.
7
. y Enclosure 1 Application of " Guidelines for NRC Review of Agreement State Radiation Control Programs" The " Guidelines for NRC Review of Agreement State Radiation Control Programs,"
were published in the Federal Register on December 4, 1981, as an NRC Policy Statement. The Guide provides 30 indicators for evaluating Agreement State program areas. Guidance as to their relative importance to an Agreement State program is provided by categorizing the indicators into 2 categories.
~ Category I indicators address program functions which directly relate to the State's ability to protect the public health and safety. If significant problems exist in several Category I indicator areas, then the need for improvements may be critical.
, Category II indicators address program functions which provide essential technical and administrative support for the primary program functions. Good performance in meeting the guidelines for these indicators is essential in order to avoid the development of problems in one or more of the principal program areas, i.e., those that fall under Category I indicators. Category II indicators frequently can be used to identify underlying problems that are causing, or contributing to, difficulties in Category I indicators.
It is the NRC's intention to use these categories in the following manner. In reporting findings to State management, the NRC will indicate the category of each coment made. If no significant Category I coments are provided, this will indicate that the program is adequate to protect the public health and safety. If at least one significant Category I coment is provided, the State will be notified that the program deficiency may seriously affect the State's ability to protect the public health and safety and should be addressed on a priority basis. When more than one significant Category I coment is provided, the State will be notified that the need of improvement in the particular program areas is critical. The NRC would request an immediate response, and may perform a followup review of the program within six months. If the State program has not improved or if additional deficiencies have developed, the NRC may institute proceedings to susp.end or revoke all or part of the Agreement.
Category II coments would concern functions and activities which support the State program and therefore would not be critical to the State's ability to protect the public. The State will be asked to respond to these comments and the State's actions will be evaluated during the next regular program review.
4 -' '
.g p .
J l: ;U , l 1
.\ )
Enclosure 2 " 3
' Technical Coments and Recommendations l; on the Colorado Radioactive Materials Program (not including the uranium mill program)
I. COMPLIANCE A. Responses to Actual and Alleged Incidents (Minor Category I) l
'Coment:
The review of selected incident files and reports identified that not all cases included the following: in-depth reviews of circumstances surrounding the. respective incidents, reenactments and time-study measurements and investigation _results documenting the complete incident, and subsequent enforcement action and closeout information.
Recommendation:
It is recommended that when incidents occur or allegations are received the Radiation Control Division (RCD) maintain a written format and a formal tracking mechanism which clearly outlines the course of action taken to resolve the issues, and to obtain as complete and accurate information as possible for the files. In addition, when the incidents or allegations are documented and completed, all pertinent
. information should be incorporated in the respective incident file.
It is further recommended that a formal tracking system be established to ensure that RCD management can identify timely resolution to the respective cases.
B. Inspection Reports (Category II)
Coment:
During the review of selected compliance files and associated inspection reports, it was identified that not all reports adequately
' and completely documented the results of the inspection. It was noted that in some cases the reports did not include the following: a discussion of the current status of previous. items of noncompliance, detailed results of the inspector's independent physical measurements, and under the " scope of the licensees program." did not detail the inspector's observations and document licensed activities which have not been implemented by the licensee (per RCD internal policy).
Recommendations:
It is recomended that all inspectinn reports, whether partial,
- special, or complete, document the information inspected to clearly
. _ _ _ _ . _ _ _ _ _ _ . , _ _ . _ _ _ _ __.____a__ _ _ . _ _ _ _ _ . _
4 substantiate all findings identified. All previous items of noncompliance should be specifically cddressed to determine appropriate resolution or whether further action may be required. In addition, any changes, additions, revisions, or updates to final inspection reports (as was identified in inspection reports reviewed) should be done through a formal mechanism, i.e., per memorandum or canagement approved policy.
It was noted that in some inspection reports handwritten notations were apparently made af ter supervisory review. The RCD management should be aware of any changes to final inspection reports and should ensure that they are appropriately substantiated through formal documentation.
t i
i L_-- -__ _--_ !
^
r c:V "Hg Ffc:e .S t! iHE c; 4 !'* A M v >.0 'u Ccn: etl or !: ^ le - . . & ? G,IC?H .Ja'aS'"C : % '"5A Enclosure 3 l Technical Comments and Recommendations on the Colorado Uranium Mill Program I. LICENSING A. Technical Quality of Licensing Actions (Category I)
- 1. Comment:
l The review of the " Preliminary Executive Licensing Review Summary" (PELRS) for Uravan dated May 22, 1984, identified that no updated information was incorporated into the PELRS either by formal written memorandum or amendment. The NRC reviewers recognize that the RCD's actions may be limited by the current hearing process.
Recommendation:
It is recommended, pending hearing results, that the RCD maintain an updated and current copy of the Uravan PELRS. The NRC reviewers' concerns are for the timeliness of the PELRS and whether the PELRS is current to support any future licensing actions.
- 2. Conment:
The review of the Uravan license amendments numbers 21, 22, and 23, idencified limited review documentation supporting or substantiating the RCD's findings for each amendment. It was also identified that of the more than 10 license amendments issued by the RCD for the entire uranium mill program, since the last review, selected major license amendments were not supported with documentation substantiating RCD findings. (It should be noted that the Cotter Amendment No. 19, denying the licensee's -
request, was completely and appropriately documented.)
Recommendation:
It is recommended that each license amendment be substantiated with supporting written documentat' ion which specifies the iicensee's request and the basis for the RCD's decision.
- 3. Comment:
At the time of this review, the RCD had developed a written memorandum entitled " Policy for an Annual Review of Compliance with Off-Site Dose Standards at Existing Facilities," which was
c/ j 9
effective on' October 11, 1985. (This was recommended during the previous program review.) However, based upon the review of
' Cotter Corporation and Uravan's license and compliance files, the reviewer could not identify if the RCD specifically identified and outlined a conclusion on whether the respective licensees meet the 40 CFR 190 standards. (A copy of an NRC memorandum for the review of 40 CFR 190 compliance determination of an NRC uranium mill was provided to the RCD staff as guidance.)
p Recommendation:
p The RCD should prepare written docuraentation which clearly identifies whether or not the mill licensees meet 40 CFR 190 standards. (This is a repeat comment from the previous program review.) .
- 4. Comment:
At the time of this review, the only action taken by the RCD to
- implement 40 CFR 192 was a letter to affected licensees stating that the RCD will use these standards in evaluating all current and future licensing actions. The RCD has not taken action to set groundwater monitoring programs under 40 CFR 192 or corrective actions. It was identified that the current mitigative action of the licensees are not designed to clean up the groundwater but are only to prevent further spread of contamination.
Recommendation:
The RCD should request the licensees to propose specific groundwater background values for their aspective mills. If acceptable background values are known then this should be done within 60 days of the letter to the licensee. If acceptable background values are not known, then the licensee should be l required to establish appropriate background values within a reasonable time period. (These actions could be accomplished in conjunction with the CERCLA proceedings which Colorado has underway.)
i II. COMPLIANCE Inspection Procedures (Category II)
Comment:
The most recent inspection reports for the Cotter and Uravan mills did not document inspection findings regarding compliance with 40 CFR 190 and f 40 CFR 192 standards, j I
f w m. n Recommendation:
To ensure' licensee's conformance to the respective standards and in order to identify whether the licensee maintains appropriate documentation, as committed by the licensee to the RCD, the RCD inspector should document findings in the inspection report with respect to compliance with 40 CFR.190 and 40 CFR 192. This will. ensure complete documentation from the initial licensing action through to the final compliance determination.
211. PERSONNEL Staffing Level (Category II)
During the review of the RCD uranium mill program it was identified that personnel utilized to process major license renewals, which includes administrative, technical, and legal staff, has decreased from the previous program.
It should be noted that although this is a Category II indicator, it has affected two other indicators, as identified above. (This is a repeat comment from the previous program review.)
Comment:
NRC guidelines indicate that 2.0 to 2.75 total professional (technical and consultant) person years of effort are needed to process a new conventional mill license, in situ license or major renewal to meet requirements of UMTRCA. This number includes the effort for the environmental , assessment and in-plant safety review.
During this review, it was identified that the two licensed conventional mills have 1.95 staff years dedicated. This is approximately .97 staff years per uranium mill. This has decreased from 1.7 staff years from the previous program review.
In addition, it was noted that the secretarial and legal support was below the recomended NRC staffing level and may have adversely affected the license and compliance program.
Recommendation:
It is strongly recomended that program management take the steps necessary to augment the staff so that the program meets NRC guidelines.
~
3 '
%C *1 ? W #
- n M a- [0g.co ,
O p 31!,3 P O S @ .? $ ' d N M4TW L r? % w -J>ee~a,e n- & v a-y pin, e. y b - - - C "9 5:,
d , 6-.- Ci s COLORADO DEPARTMENT OFThomasHEALTH
- ***~# ,* M. Vernon. M.D.
p, chard D. Lamm Jg Executive Director Govemor February 4, 1986 Robert.D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission, Region IV - I p .,
611 Ryan Plaza Drive, Suite 1000
~ Arlington, TX 76011 .- ._.
t- i
Dear Mr. Martin:
The following is in responea to your letter of December 4, 1985, regarding the NRC's review of the Colorado Radiation Control Program.
To reduce the number of letters in responding to your agency's review comments, all items will be addressed in this letter.
The following are the Department's responses to the items in Enclosure 3 (Uranium Mill Program).
With regard to the " Technical Quality of Licensing Actions", a Category I indicator, the Department definitely believes that the items identified are not worthy of a Category I comment. Enclosure 2 item 1A and Enclosure 3 items IAl, 2, 3, and 4 indicate after the facts are considered that only differences in of fice policy on style and format, and information processing conventions exist and therefore have no health and safety implications, whatsoever.
With regard to the Uravan PELRS (Preliminary Executive Licensing Review Summary), that document was finalized when the Notice of Hearing was issued on May 22, 1984. Any revision of the PELRS is contrary to procedures defined in our regulations. The FLS (Final Licensing Sumuary) is issued when the Departmental action is taken; The FLS is the documentation for the action taken and includes any necessary changes to the PELRS. The issusace of the FLS has been delayed pending CERCLA Section 107 lawsuit discussions. There are presently negotiations going on in both the Cotter Canon City and Umeteo Uravan CERCLA lawsuits. The respective PELRS' are points of negotiation in both cases. The FLS will be consistent with any CERCLA judgunt or decree. There will be substantial negotiation and discussion involving a number of state personnel in both cases over the next several months. The program is definitely moving forward with regard to the Uravan situation, but because of the hearing status and lawsuit activities the actions are not visible to non-parties to the action.
l 3
NM O " _ _ _ _ _ _ mD* 1
. . ,
- n F.
14
_ Robert D. Martin',1 Regional Administrator February 4, 1986 Page 2 With regard to the comment on documentation - supporting uranium mill license amendments, the NRC reviewer did identify that the amendments were : adequately supported; however, due to -the extensive nature - of the submissions and evaluations there needed to be a short concise summary ;in support of the action. We agree with the reviewer's suggestion and will incorporate. this documentation concept into our program policy.
With regard to RCD determinations of compliance with 40 CFR 190, RCD
' has recently completed two reviews for two (2) convential mills . and
- one (1)- ore sorter modeled after the information provided by the reviewer. The referenced reviews are enclosed for your review.
With regard to implementation of 40 CFR 192, we disagree with the reviewer's comment. This matter is of prime concern in the lawsuits taknu under CERCLA. As stated in Al Hazle's letter to EPA (Doda of NRC Region' IV copied) on the implementation of 40 CFR 192, setting standards for such wells would unnecessarily complicate the lawsuit The resolution of the lawsuits may. result in situation.
concentrations below the levels specified in NRC regulations and to a greater degree than anticipated by the EPA standard. Amendment #20 to the Uravan license, issued March 29, 1984, required cessation of tailings discharge to the unlined impoundments by July 1, 1985. No tailings deposition in the ponds from active milling is occurring at the Uravan site. Both CERCLA lawsuits will address removal of sources of contamination. Source control has been and will continue to be an important component of contemplated remediation at the CERCLA sites. In conjunction with the foregoing, the state will strongly advocate restoration of groundwater quality in its lawsuits. Colorado is in a corrective action phase rather than just detection or compliance monitoring!
With regard to RCD compliance inspection efforts on license conformance with 40 CFR 190 and 192, our files indicate the l
1 l
following: The RCD cited Union Carbide /Umeteo in July 1984 inspection for non-compliance with 40 CFR 190 (Item #12). The December 1983 Cotter Catson City inspection noted off-site dose compliance as an Item of Concern (Item #5). Corrective actions were
. proposed and taken by the ifcensees in each case. With regard t*o 40 CFR 192, recognize that the December 12-16, 3 983 Cotter Canon City inspection compliance letter (Item #12) was probably the first citation to the generally-applicable requirements nationwide. As a result of non-compliance item #14 of the July 9-13, 1984 inspection of Umetco's Uravan mill, a new well was installed as a compliance ;
monitoring point and or January 9,1986, Union Carbide /Umetco began a 75-100 day drilling _rtogram at Uravan under State supervision. It '
should be also noted that at the time the Department conducted these inspections and took the above actions NRC had not defined nor i
^ #
C Robert D. Martin, Regional Administrator February 4, 1986 i Page 3 implemented their policy on 40 CFR 192. RCD will continue to incorporate e xamination of these standards into the annual inspections using updated guidance when provided by NRC. The system of documentation will be improved so that state evaluations and actions are clearly demarcated within the inspection reports and compliance letters.
With regard to staffing level in the uranium group, over the past 5 years various efforts to raise the staff level have failed, primarily due to the decline of the uranium industry. However, the levels of NRC and EPA requirements have increased, along with our own ef forts regarding ultimate site closures and CERCLA Section 107 lawsuito. It should also be pointed out that the NRC's guidelines fail to take sufficient cognizance that our numerous small site actions demand disproportionate staff time. In addition, it needs to be recognized that the CERCLA cases have added staff, personnel r.nd resources to address the issues involved with the Canon City and Uravan sites.
The state has hired numerous consultants to address the myriad issues at the two sites and they are presently working t;ogether with our regulatory staff to determine proper remediations for the sites. The RCD is using the CERCLA suits in an integrated enforcement approach to the Canon City and Uravan sites. We generally concur with the reviewer's comment, but need make no apologies for the effort put forward by the Department's regulatory staff, the quality of work done by them, or any delay caused by the CERCLA lawsuits.
The following are the Department's responses to the items of Enclosure 2 (Radioactive Material - non-uranium mill related):
With regard to responses to incidents, we agree that the documentation format used must identify the course of action taken, to have a complete record compiled where the effort is over an extended period of time, and an incident closeout procedure. While we do take some execption with regard to the need to do reenactments and time-study ' measurements on the majority of incidents that we experience, the report must make an evaluation of the impact of the incident. .
With regard to the content of the inspection reports, we concur in the reviewer's recommendations and will act accordingly. 1
9 A
' 4 Robert D. Martin, Regicnal Administrator February.4, 1986 Page 4 We wish to express our appreciation for the effort extended by' Ralph Heyer and I those that assisted him in the Colorado Radiation Control Program review.
While' we may take exception to some of the perceptions expressed by the reviewers., we deeply appreciate and value their ~ constructive input on the conduct of our program.
Should there be any questions regarding the above responses, please feel free to contact.Al Hazle, Bob Arnott or myself.
Sin ely,
~~ # .m - f.b .
'ihomas M. Vernon, M.C.
Executive Director Colorado Department.of Health AJH/ms Enclosures (3) cc: Al Hazie Bob Arnott i
- - e , ,. .,
Au; ,
k OFF-SITE DOSi COMPL1 ANCC sun.tARY REVIEk' 3.,
COTTER CORPORATION CANON CITY ORAN10M MILL, 1984 OPERATIONS C]-
LICENSE NUMeda: 359-015 DATE: November 12, 1965
- 1. INTRODUCTION: The Cotter Corporation Canon City Mill is located south of Canon City, Colorado. At the present time it processes ore trucked to the site f rom Cotter's Schwartswalder Mine outside of '
Colden, Colorado. No other active uranium processing f acilities are located in the immediate vicinity. The Cyprus Mineral's Hansen Project located approximately 24 miles northwest of the site contains uranius ore bodies which have been mined in the past. Although Cotter has asserted that the mill site is an area of naturally elevated concentrations' of U-238, U-235 and Th-232 series radionuclides no evidence of this has been documented.
The Canon City subdivision of Lincoln Park is located approximately ]
1.5 miles north of the mill and contains the nearest residence. This ;
area is characterized by numerous homes and a semi-rural atmosphere.
Many of the resider ces have significant gardens and small numbers of livestock. Orchards are maintained in a number of locations. j i
Cotter is required by LC 36.3 to perform environmental monitoring J adequate to determine the maximum potential dose commitment to residents of this area and by LC 36.5 to use this data to assess compliance with the 25 mrem per year of f-site limit. It is the purpose of this review to assess the acceptability of Cotter's conclusions.
II. LICENSEE'S SUBMISSION Within their semi-annual report, submitted March 29, 1985 the )
licensee stated that the mill operated only ten days per month during 1984 and that there had been no significant increases in sill emissions during this period. CDH was referred to Cotter's mill l
renewal application of March 29, 1984 for calculations of of f-site doses.
Section 5 of the application presents the licensee's assessment of these doses. Various scenarios are considered and esiculations made for each. Interpretation of the sacerial is made difficult because hypothetical situations are not clearly labeled as such. For example. Table 5 2-8 presents a calculation which includes a water i ingestion dose at a location at which the water is not consumed.
Table 5.2-9, " Total Annual Dose Commitment to the Manimally Exposed f Individual" also includes a deso from a water supply that is not cc'nsumable. The licensee's assessment of the actual dose that tne
~
nearest, maximally exposed resident receives is given on p. 3-24 as follows:
.(
l 8&d43$6-d&fm gg
- (
Whole Bcdy: 0.13 mrem /yr Bone: 0.83 mrem /yr -
Liver: 0.16 crem/yr Kidney; U.33 mrem /yr Lung: 0.12 mrem /yr A number of problems were noted in the licenrew's s u basi s s ion.
Cotter uses data accumulated over the. period of a numbec of rears in determining compliance. The use of this pooled data results in an overestimate of the 1984 doses because of the influence of the tailings transfer operation which was concluded in 1983. In accordance with Departmental policy of f-site dose reports are to be based on data from the prior 12-month period.
Cotter presents calculations done by the NUREG-0859 method (site specific monitoring) and MILDOS (computer modeling from source farms). The licensee's statement that their MILDOS calculations are to be used in preferance to doses calculated based on site specific monitoring data is unacceptable. Present RCD policy, consistent with NUREC-0859, specifies that 25 millires limit compliance will be assessed based on site specific monitoring data. MILDOS modeling is based on numerous assumptions that may introduce significant errors.
In Cotter's case, stack sampling data f rom. recent years has been acknowledged to be of questionable validity and must not be used in place of environmental monitoring data. MILDOS calculations may be useful in predicting results of future modifications to an operation.
One of the most significant flaws in the application is the failure by Cotter to adequately assess the background concentrations for the af fected area (Lincoln Park). Cotter used data from the Hansen Project site for background values. The mineralized nature of this site makes it inappropriate as an estimate for Lincoln Park backgrounds In assessing doses to Lincoln Park for this review the Department has used the Canon City (Dosier Road) monitoring data as an estimate of Lincoln Park background. The data for this site was used as the best available estimate of background at this time. A revision of the monitoring program to determine appropriate !
background conditions will be necessary.
III. PATEWAYS Six potential pathways which may lead to radiation exposures to man from milling operations have been identified. This section esamines -
the applicaellity of each of these pathways to the Canon City situation. _
A. External Dose - Direct Caema Radiation - The licensee's submission compares TLD readings in Lincoln Park to those at
~
l their chosen background site (The Kansen Project) and concludes that no net effect exists since background readings are higher, <
e
- . e ,. ** ,'
, e e e
___-__._._.____-____________.________..___.-___m_ _ _ - _ _ _ _ _ _ . . _ - _ . _ _ _ _ _ _ _ _ _ _ _ - _ . . _ _ _ _
s- ~ . , .
.e The Departegnt does not accept tr.e Hansen site as bockground.
Using CanonjCity as:the best available comparison location a net positive dose exists. This pathway is included in tne Department's dose assessment.
B. Indalation - The licensee acknowledges a contribution f rom the inh >lation pathway and the Department agrees on its presence.
The embqgt of this contribution is discussed in section IV.
C .' Intestion of Contaminated Vegetables - The licensee provides data (faele 5.2-1, dates for which are not indicated) showing that radionuclides concentrations in Lincoln Park vegetation are less than those at tne background location (dansen). Based on this data, the pathway for vegetation ingestion is stated by the licensee not to exist.
As the Department does not accept Gotter's Lackground eite this statement was reexamined. It was observed that, based on Cotter's data, (Table 5.2-1) Lincoln Park vegetation did exceed that of Canon City in radionuclides concentrations and that a net positive dose could be calculated.
When data for 1984 was examined it was found that the licensee's a assertion of no net effect was supported for this time period.
The following figures were considered:
1984 Vegetation Data (average of 3 samplings)
U-na t pCi/g wet Ra-226 pCi/g vet Lincoln Park O.02b 0.056 Canon City 0.045 0.066 Therefore, based on 84 figures and use of the Dosier dead site for comparison, no net concentrations of radionculides in Lincoln Park vegetation are indicated. Fathways based on ingestion of contaminated vegetation will therefore not be included in this assessment.
It must be noted that (as shown in Table 5.2-1) vegetation data for years prior to 1954 have shown concentrations in Lincoln Park in escess of those in Canon City. Specifically, based on past data (Table 5.2-1) a whole body dose of 3.13 mrom per year and a bone dose of 31.3 seen per year could be calculated.
Additiocelly, it is noted that this calculation does not include a Th-23L cor.tribution as this element has not been monitored in the pesc.
- Were Lincoln Park vegetation radionuclides to Rhow excessive concentrations in the future the Department would have
~
difficulty la assessing the actual doses received due to lack of knowledge of the actual crop production and consumption in the area.
' ~
4
, 4 e e
l
- * . n Based on the above, several recoenendations to the licensing staff cust be made: .1) analysis for Th-230 in vegetation must be required; 2) a garcen survey tu deter: sine the actual extent !
of crop production and conou:sption at each individual Lincoln Park residence must be done; and 3) identification of the types of vegetation sampled in the environmental monitoring progran must be documentec.
Additionally, considering the sensitivity of the direct ingestion pathway, the compliance staff must examine methods for acquisition and use of vegetation data very carefully in the future, particularly in the course of the annual 25 millirma limit review, D. Ingestion of Meat or Milk From Livestock Grazed on Contaminated yegetation - The comments included in section C, above, apply j and therefore this pathway will not be included in this 1984 )
assessment. l Its applicability to next year's dose calculation will depend on acasured vegetation concentrations, and results of the garden survey.
E. Ingestien of Contaminated Vater - The presence of groundwater contamination in the Lincoln Park area is well documented. The assessment of off-site doses associated with this contamination is complicated by the conflicting and incomplete knowledge of water usease in the area. Most residences in the area are supplied with city water taps but also possess wells which are sometimes unused but at other times used for various combinations of irrigation and/or stock watering. From available information, some residents do use well vater for i drinking purposes.
The licensee's dose assessment (p. 5-24) states that the nearest resident does act use contaminated water for drinking; therefore ;
I the licensee excludes this pathway from its assessment.
i The fact that some Lincoln Park residents do consume ]
conem=4asted water has been documented within the time period l since the writing of the licensee's application. This pathway i will therefore be included in the Depertment's evaluation of 25 milliren limit compliance.
F. Iagestion of Meat or Milk Free Livestock Watered With Contaminated Water - The licensee lista doses f rom these sc4 trees on Table 5.2-8 of the application but does not appear to include them in the sua.
Although data is lacking in regard to livestock watering and consumption by specific residents, the preseece of algnificant numbers of cattle in Lincoln Park, as observed by Department inspectors necessitates the inclusion of this pathway in ths
. analysis until a " garden survey" can prove otherwise.
_i_________-._
- v. . .
I V. - DOSE ANALYSIS BY PATHWAY A. T External Dose - Direct Gamma Radiatiob - As discussed. Cotter's use of background exposure rates from the Hansen site are not acceptable. CDd, as dascussed, wi11 ~ temporarily use Canon City site (Dosier Road) data for comparison.
The licensee's 1984 report indicates sa 11.15 ud/hr (yearly average) gamma exposure rate in Canon City. The Lincoln Park rate as 12' .25 uR/nr. The net exposure attributable to the mill' is 1.10 ut/hr or 9.636 at/yr. Using an 0.95 conversion factor (Roentgen to rea in tissue) yields a yearly exposure of 9.15 area, or 361 of the 25 arem limit.
- 5. Inhalatier. - The differences between Cotter's calculated doses for inhalation and those presented by the Department are due to CDR's use of Canca City for background and 1984 versus earlier data.
The following air data from Gotter's 1984 Annual Report was used:
U-nst pCi/m Th-230 pCL/m ta-226 pci/m Lincoln Park (avg) 2.78 4 10-1 2.68 K 10-7 1.18 K 10-7 1984 Background (CC) 3.2 6 X 10-7 2.07 K 10-7 1.67 X 10-7 Net air concentrations 0 0.61 X 10-7 0 The resulting dose commitments attributable to mill operations are:
Whole Body Bone Luna U-nat 0 0 0 Th-230 1.01 K 10-5 3.63 x 10-4 1.96 x 10-4 Re-226 0 0 0 Total 0.000010 arem 0.00036 meme 0.00020 ares It should be noted that 1964 air concentrations are insignificant regardless of the choice of a background locatfon. Crosa doses to the residents calculated with no subtraction of background, are:
Whole Body (ares) Bone (ares) Lung (area)
, U-mac 1.28 1 10-6 2.20 1 10-5 4.69 K 10-3 Th-230 4.45 1 10-5 1,39 x 10-3 8.63 10-4 Ra-226 3.65 x 10-6 3.65 K 10-5 7.80 X 10-4 Total inhalation 0.000049 ares 0.0016 ares 0.0017 mese Thus the inhalation pathway is an insignifica'at fraction of the off-site dose limit. ,
4
.-_r___---___--_-__-_-____-___-_-
. .s. m -
C. Ingestion of Contaminated Vegetation - Pathway not applicable in 1984 (see section 111> .
- D.- Ingestion of Milk or :! eat From Livestock Grazed on Contaminated Vegetation - Pathway not applicable in 1986 (see section 111).
E. Ingestion of Contaminated Water - CDH staff have identified well
- 169 (McFarlane,1725 Incust) as belonging to the nearest resident actually consuming contaminated water. Although at a greater distance from the mill, well #189 (Haines,1427 Hickory) is closer to the plume of contamination and will be used as the ,
closest residence in this dose assessment. i
~
Data obtained from the licensee shows the following ;
concentrations in the walls of concern
~
Well # Owner U-n a t Th-230. _Ra-226 169 McFarlane 6.7 pC1/1 0.0 pC1/1 0.1 pCi/1 i 189 Haines 28 pC1/1 0.0 pC1/1 0.1 pC1/1 129 Caldwell 40 pci/1 - 0.0 pCi/1 0.1 pC1/1 111 Salardino 2 pC1/1 0.0 pCi/1 0.1 pC1/1 Comparison Cyprus-Hansen 14.2 pC1/1 1.76 pC1/1 1.0 pC1/1 Cotter's comparison figures were not accepted in this case as they appear to exceed the unaffected wells in Lincoln Park.
Licensing staff must require a . sore supportable determination in the future. Well 111 (Salardino) is used for comparison in this review as it appears to be representative of uneffected groundwater. ,
j Well #129 is included in the above chart ?ue to inadegesacy in the well #189 data. Well #189 was samplod in the summer when the diluting effect of the De Weese Dye Ditch is likely to cause reduced concentrations of contaminants. Well #129 is in very close proximity to well #189 and since the average available for f.129 is based on a larger number of samples it is assumed ta be more representative of the water consumed at the Haines residence.
Net concentration (minus background) of radioactive comemminants i aret U-nat 38 pC1/1 Th-230 0 pC1/1 l Ra-226 0 pC1/1 poses calculated for ingestion of the above are:
~
Whole Body Bose Liver Kidney U-na t 0.68 ares 11 aren 0 2.6 ares Th-230 0 0 0 0 0
Ren6 0 0 0 l
, . . . The bone and kidney doses from ingestion of uranium in water are significant (although well below the 25 arem limit).
. m
+
,1 ..
F. Ingestion of Meat or !!1lk From Livestock Watered With ~
Containinated Wate r - These doses are calculated f rom the above states concentrations at well #129 Whole Body Be ne Liver Kidne y U-aat U.0924 mren u.063 - 0.0095 Th-230 0 0 - 0 Ra-226 0 0 - 0 Milk Ingestion Whole Body Bone Liver Kidney U-aa t 0.0088 aren U~iT -
D.UJ6 Th-230 0 0 - 0 Ra-226 0 0 - 0 These ingestion doses are not significant portions of the limit.
V. DOSE COMMITMENT SIDORRY The following chart suma the doses from the various pathways found to exist la Lincola Park. Accepted procedures regarding significant
- j. figures wer
- used throughout the calculations.
Path Whole Body Bone L'iver Lun Kidney External- 9.L5Z ares 0 0 0 l Inhalation 0.00001 0,00036 0 0.000196 0 Vegetable Ingestion 0 0 0 0 0 Meat from Cont.
l Vegetables 0 0 0 0 0 l Water lagestion 680 11.2 0 0 2.63 Memt, Milk ir'on Cont. Water 0.0112 0.207 0 0 0.04328 T0yAL 9.8 area 11 area I~mren "li~00020 aren 2.7 aren VI.
SUMMARY
AND CONCLUSIONS At present the facility is in compliance with LC 36.1 specifying a 25mram per year off-site dosa limit.
Based on the limited data available the only pathways resulting in significant off-site doses are 1) external samma radiation to the j whole body (36%), 2) water ingestion doses to the bone (452), and 3) the unter ingmation dose to the kidney (105).
Aside from the above mentioned pathways the vegetation ingestion pathsay should be esamined cassfully in the future as minor differences in radiennelide concentrations any have major effects os off-site does commitments.
Based on the 40 CFR 190 compliance review for the Cotter Corporation l Csaca City facility the Department askes the fol. lowing
. .. . s. . *. ' recoensadations:
( l l i l
J
- m n l
1 1
- 1. Background determination for the Lincoln Park area is i inad eq ua t e . The licensee nust be required to take actions, including installation of additional wells and air sampling stations, and an expanded vegetation sampling program to correct this.
- 2. Additional information is needed regarding vegetable and stock production and consumption and water use in Lincoln Park. The licensee should be required to complete a " garden survey
- which will provide this information for each residence in Lincoln Park.
- 3. The license must be amended to require Th-230 analys,ts of all vegetation samples and the sampling of multiple vegetation types representative of what is consumed by both residenta stad their stock animals.
4 A 25 millires limit compliance assessment consistent with recently adopted Departmental policy and based on current data aust be submitted by the licensee semiannually. A notice of "no significant change" is unacceptable at this time.
- 5. The licensee's compliance assessment should state clearly the "real" situation in Lincoln Park. Overemphasis on worst case scenarios is not necessary.
- 6. A regular samp1'ing program of well #189 should be required. All wells used for human and stock consumption should be identified.
- 7. TLD data should be reported in aren/yr.
- 8. LC's 36.3.1 and 36.3.1 having been impienented may be deleted.
Although thi Jose assessment is based on actual exposures occurring in Lincoln Park, additional sention aust be made of the potential for exposure which exists due to the groundwater contamination in the area. Numerous wells have cecome unusable due to contaminant seep:ge from the mill. If these wells were used for human consumption doses would exceed the 25 ares per year standard. Corrective action for this problem is presently being negotiated by unit licensing staff.
O Y
- e a O 5 y e
e
. m_____, . . _ _ _ . _ _ . _ _ . _
} Qfrg? Jq f .g 33-g; p-- g---
ny_ _ __-_ _ _
'~ Y] c:T: M C G . ; = j .;
^
( 3 PF' ? /M - -) H 't R .Q y W -CDJTTi,*L I a 40 CFR PART 190 COMPLIANCE StMMARY REVIEW UMETCO URAVAN URANIUM MILL, 1984 LICENSE NUMBER: SUA-673 DATE: Decembe r 17, 1985 1 INTRODUCTION: The Uravan Uranium Mill is -located approximately 90 miles southwest of Crand Junction, Colorado along state highway 141 in Montrose County within the canyonlands section of the Colorado Pla teau. The mill is situated along the canyon of the San Miguel River and recovers uranium and vanadium from ores nined underground in the Uravan Mineral Belt. Numerous uranium mines, tapping local deposits,
- are present in the immediate area, some being visible from the mill itself. ,
l-l The mill' facility is -divided into two par ts. The B-Plent is located on :
the canyon plateau and includes the crushing, grinding and leaching portions of the mill curcuit. The tailings disposal and raf tinate j spray evaporation areas are located adjacent to B-Plant on the plateau. The A-Plant is located directly below the B-Plant on the canyon floor and includes the processes from product separation by fon exchange and solvent extraction to the final drying and packaging.
l The town of Uravan extends in both directions along the river from the mill and is cwned and operated by Umetco as a housing complex for l company workrers. At one time support facilities such as a boarding 1 house, storo, alementary school and recreation hall operated _ within the i town. These have been closed in recent years. During 1984, at which time the mill was operating, the town had a maximum population of 321.
Rare-setals processing has taken place at the the Uravan site since the early 1900's. Radium was processed in the early years of this century. After a period of inactivity, vanadium processing became important in the 1930's under the direction of the U.S. Vanadium Company, o Union Carbide Subsidiary. Urnnium and radium were at that time discarded with the tailings. In the early 1940's the U.S. Army f Corp of Engineers undertook efforts to recover uranium from the tailings as part of the Manhattan project. In 1943 after several years i of inactivity, the mill resumed production in response to the AEC's buying program. At the conclusion of the AEC program Union Carbide continued production, providing yellowcake to private buyers. On April ,
2,1964 an internal reorganization occurred in which Umetco, a Union- 1 Carbide subsidiary, assumed responsibility for the mill.
The nearest residences to the mill are those within the town of Uravan m
directly across the San Miguel Liver from the restricted area of l A-Plant. Aside from those in the town of Uravan no other residences
. . exist within 5 miles (8 km) of the mill. j I l 1
.1 I
h.. ~. . . . . . . .
y d '
- 9 D
+. .
. l l
.e
- '. - m The population of the town has varied considerably over the year
- and hks been directly related to the operational status of the mill. At times'the population has exceeded 500 individuals. During the compliance period being reviewed (1984) the maximum population was 321. Recognizing the risks associated with (*ravan residency (prinarily
-from radon daughter exposure) and the exceedance of the 25 mrem standard in the town, the De pa rtmen t issueu acendment 20 on ?brch 31, 1984. This amendment contained provisions banning the growing of garden vegetables in town (Lc 18.2.3) and forbiding reoccupancy of vacated residences in blocks closest to the mill. As a combined result of this amendment and the mill shutdown (December 1984) town residence has been reduced to approximately 50 people at this time.
The licensee's initial of f-site dose compliance assess.sent was submitted on November 30, 1983, based on 1980-1982 data and indicated exceedance of the standard. A phased compliance program was submitted at that time includit.g 4 steps which were calculated to result in emission levels resulting in doses meeting the standard. By 1984 only the first of these 4 steps had been instituted (cre stockpile and road dust control). During 1985 step 2 (tailings pile side slope cover) was be gun. Steps 3 and 4, addition of emissions controls to mill crushing circuits, has been put off due to the 4 hut down of the mill.
Ihis review assesses the mill's compliance with the 25 mrem standard for the 1984 operating period.
II. LICENSEE'S SUBMISSION:
The licensee's 1984 off-site dose assessment together with an updated land use report were submitted on May 15, 1985 es required by the conditions of licensure. Doses, calculated by NUREC-0859 methods, are included for 5 sampling locations within the unrestricted area of the town ot' Uravan. Their summary states that lung doses exceed the standardat three monitoring locations. The following figures are provided:
Doses (mrem)
SITE Whole Body Bone Liver Kidney ,Ltrn g Skin Clarifier 0.746 25.1 1.41 6.88 25.8 1 55 x 10-7 l
l Sewage Plant 0.747 23.8 1 30 6.39 .- 35.0 2 62 x 10-7 Swimming Pool 0.635 20.4 1.,12 5 49 28.8, 2.20 x 10-7
'C-Riock O.884 28.6 1.57 7.73 38.1, 2.96 x 10-7 {
. F-Block 0.3?A 10.9 0.607 2.98 10.9 9.14 x 10-8 l
. . I Dose commitments exceeding the 25 mres standard are underlined for i emphasis. It is noted that the lung dose exceeds the ststidard at 4 l locations and the bone dose at two.
ve ? b 1.
- y .u .*... s u -- .aw.. , .
d' e
l
I
[0 ins
.A A I, - The Department finds the majority cf the methods and values presented in the report to be acceptable. One major discrepancy was noted in the assessment of external Catmo exposures and is discussed in section IV.
III. PATHWAYS Six potential pathways which may Acad to radiation exposure to man f rom milling operations have been identified. This section discusses the Departeent's assessment of t he applicability of each of these to the Uravan situation.
A. _E__xternal Dose-Direct Gamma Radiation The licensee's submission calculates external gamma doses based on
' air concentrations by calculating (1) a cloud immersion dose and (2) a ground plane dose based on deposition of the- 1984 particulate.
It is' the Department's position that an external gamma pathway is evident in the town but that the above method is inappropriate for its calculation. Determination of the gamma dose by this calculational method results in galues lower than those measured at the site by factors of up to 10~
The major factor complicating the gamma dose determination is 'the long history of the town area in rare-metals precessing. Deposite are known to exist in the town which are due to activities which took place under the management of other entities (U.S. Army Corps of Engineers, f ar example) besides the present owners Umetco management denies responsibility for these deposits.
Appendix A to NUREG-0859 states: " Doses which are due to preoperationsi natural background and extraneous sources should be subtr'acted from those measured at the nearest receptor". The deposits contributing to the gamma exposures in Uravan are not natural background and cannot be classified by the Department as
" extraneous".' On the contrary, their presence and affect to the Uravan residents is undoubtedly relevant.
NUREC-0859 also states: "the contributions from non-mill sources should also be determined based on actual measurements at representative background locations". ( Although not stated, the implication is that these doses may also be subtracted.) The deposits in Urevan do not meet this criterie either. Their origin must be assumed to be the mill itself.
40 CFR 140, indicates that the 25 arem limit applies to " doses received by members of the general public as the result of 1
. . operations which are part of the nuclear fuel cycle'. The )
- definition of the term operations is problematical. It ie the interpretation of the Deportment that deposits and releases froe the mill facilities to the town of Uravan, being ccupany owned and
,.,,m.....
' .. . -n-s..---_-,-,_,,_a_ -
A e 4_
t' centrolled by feetco Corp rat-ion, fall within the realm of
'" operation s" f or toe Uravan mill. Being thus classified the company is responsible for all radiation doses resulting in the town including any historical deposits within. Additionally, although the deposits may have originated prior to implementation of 40 CFR 190 in 1960, they may be considered part of the present contribution f rom operations in the area and are the responsibility of Umetco.
It is acknowledged that since the time period being reviewed (1984), Umeteo has taken action to remove discrete town deposits.
Both legal and political questions arr. involved in the determination of the responsibility for the town deposits.
Nevertheless it is highly likely that gamma exposures exceeding
. simple cloud immersion and ground plane exposure, as calculated by the licenset are attributable to mill operations. Until such tiac L
as the licensee can document the specific sources and values to be subtracted from gross TLD readings due to sources other than
- mill operations" the Department must use these readings (minus the Tabequache background) in this compidsace review. (
B. Inhalation The licensee acknowledges a contribution from the inhalation pathway and the Department agrees on its presence. The extent of this contribution is discussed in section IV.
C. Inges tion of Contaminated Vegetable s Although the vegetable ingestion pathway was a signaticant contributor to offsite dose in the 1983 assessment by the licensee, action has been taken to correct this. LC 18 2 3 of amendment 20, issued March 31, 1984 prohibited the growing of' vegetable gardens in Uravan. During the routine inspection of July 1984 no vegetable gardens were observed in the town. i Although a small contribution vis this pathway say still be present due to fruit grown in town it is not likely to be significant.
This pathway will not be analysed further in section IV.
D. Ingestion of Meat or Kilk from Livestock Crazed on Contaminated Ve ge ta tion .
J Usecco's 1984 land use report states that no milk cattle are raised in the area of the mill and that the beef cattle raised are not ,
locally consumed. 1 l
Although the observation of cattle grasins within the restricted l s - area boundaries in the past has raised concern to Department )
. . inspectors, the above statesents are accepted. Much of the area surrounding Uravan is open range and the cattle are known to traverse wide areas during the season. This coupled with the .
stated absente of local ecasumption makes the existence of f significant effects f rom this pathway less likely.
0, . . . . . . . .
m-- _ _ _ _ _ _ _ . _ .
n .
,. - j
~
E. Ing tstion of Contonineted Wst: r i
Drinking water in the town of Uravan is obtained from the l Tabequache #2 well which is located several miles upgradient of the ]
mill. this is the same well that is considered as background in l the dose assessment.' Although radiu:n-226 levels in the well show ]
naturally elevated concentrations. The water la treated for its I removal prior to distribution for consumption.- No effect from the I mill'is assessed by this pathway at this time. I F. Ingestion of Meat or Milk from Cattle Watered on Contaminated Water Consistent with sections D and E no effect is assessed for this 1 pathway. De only stock watering well in tha area is on Spring .f Creek Mesa and, due to its distance, independent of any seepage l from the mill. i IV DOSE ANALYSIS BY PATHWAY A. External comma TLD readings are taken in 5 areas of the town. The Sewage Plant sample is herein chosen as most representative of maximuu resident exposure. Although not in a housing block itself, it is far enough north-in the town to receive effects from the full mill operation but yet still upwind of several of the most highly occupied housing blocks.
TLD Readings - 1984 Sewage Plant 303.16 mres/1984 Tttbequache 104 30 mres/1984 Nek 198.9 aren This valu[ indicates a significant enesedance of the 25 arem standard. Although the licenses states that the majority of this dose is not attributable to mill operations, the license's inference cannot be accepted without proof.
B. Inhalation Air particulate concentrations show the following not
- . concentrations of ter subtraction of the Tabaquache background:
U-nat (pCi/s 3) th-230 (p':1/m3 ) Ra-226 (pCi/m 3 )
SITE
. . C-Block .00340 .0046 .00340
. .. . Sewage Plant .00256 .0038 .00343 g . . ,
. . Swisusing Pool .00226 .0033 .00273 Clarifiers .0C156 .0041 .00383
.,. F-Bloc k .00156 .0018 .00073 l -
y.ya y. .. n.e ., . ~. :... . .. . . . . .. .
l..-.......... .... .
- a .5.*,"*-
- ***C" P G
i'.
I The folicving desa commitments were calculated from the above data:
I SITE Wholg body (aren/yr) Bone (arem/yr) Lung (ares /yr) j s
C-Block 0.884 28.7 37.9 )
Sewage Plant 0.749 23.9 35.3 )
Swimming Pool - 0.632 20.6 29.0 1 Clarifiers 0 744 25.1 25 6 )
F-Block 0 328 11.1 10.9 -
It is noted that lung doses exceed the standard at 4 of 5 locations ;
and bone doses at 2 of 5. The licensees calculated doses were virtually identical to the above.
. C. Vegetation ingestion: pathway not applicable in 1984 D. Msat or Milk Ingestion: pathway not applicable in 1984 E. Water ingestion: pathway not applicable in 1984 ]
1 F. Stock Watered on Contaminated Water: pathway not applicable in 1984 i i
I V. DOSE COP 9(ITHENT
SUMMARY
l The following chart suas the doses from the various pathways found to be significsat at the Sewage Plant site Pa th Vhole body (ares /yr) Bone (ares /yr) Lung (ares /yr) $
External samma 199 Inhalation 0.749 23.9 35.3 Total, 200 73~7 3T.7 Based on TLD data the whole body dose exceeds the 25 aren standard at {'
the clarifier, sewage plant, swimming pool and C-block sampling sites.
Lung doses exceed the standard at these same sites.
Bona doses exceed the standard at C-block and t.he clarifier s%e. !
VI. StD9(ARY AND CONCt.USIONS l
- 1. In 1964 the 25 arem per year limit was exceeded due to external samma exposures from sources not clearly defined and from airborne particulate levels likely due primarily to the ore crushing and j
grinding circuits of the active mill. j
- 2. 'The shutdown of the mill in December 1984 plus the installation of f side cover on the tailings piles is likely to have reduced the
. - inhalation pathway exposures to within acceptable levels in 1985.
Data in the upcoming annual report should be reviewed to confirm
. . . . this.
~ ~ * ' ; '*
&;spp.:r~ , a s. . e a. n,~ . - - -
,g*e. ..***. o* % * * * * *-
s.: at. * .* .<. C . v . . .x t a j w .. : .
a---
i j
,4 '
o .
! 3. .To precluda further ncn-cropliance, the crushing-grinding circuit emissions-control improvements propose'd-in 1983 mus t be required by amendment portor to any restart of this circuit.
- 4. The existence of the comprehensive samma survey of the town done in spring of 1985 and the removal of discrete inatown deposits subsequent to this is ackncviedged. .this action should serve to improve in-town gamma exposure rates and may lead to compliance via this pathway. A report of- samma exposure levels should be requested immediately after completion of the removal of discrete de posit s. If levels continue to exceed the standard the Department.
abould determine whether residence in the townsite is appropriate for any member of the general public.
Signed W/ ff/Is/(/p G
Reviewed by h /h /
j , .
Keviewed by 1
1
- l ll/
I i Q
Reviewed by
.s i
l l
l l
. l
- *- # N'**'***M*~**
- gs.,,g. . . . . t ,. . 4. + v . se
. . - - - -.2- 86~** . -
e.. . v=. , * . ,e ? . *e - * * * *** * ' * *
- e* .a ..
,. *t,... ,.=,..e . * = *- * ' * %# ** * ** * * **
- e
4
. ut -biIE ~Jbt L4M1A cutirL & A!.LL SUMMAM ht. W .W
. COTTER CORE...ATION SCHWARTZWALDER ORE SORTEL 1984
,. LICENSENNMBER: 369-035
.DATE: November . 14, 1985 INTRODUCTION N
- I-The Cotter Corporation Sch Artzwalder Mine is located in the Ralston Creek Canyon about six miles northwest of Golden, Colorado in Jefferson County. Facilities at the site include an underground uranium mine from which a relatively high grade ore (0.35% average) is extracted, an ore sorter for separation of useful material from vaste rock and a water treatment plant for removal of uranium end radium from the facilities waste water prior to its release to Ralston Creek.
The mine itself is not under the authority of the Department nor the radioactive materials license. Only the ore sorter and water treatment plant are regulated by CDH. The proximity of the nine to the licensed facilities is a potential problem in separating out the environmental effects.
Two locations are worthy of consideration as the " nearest residence" for of f-site dose limit compliance determination purposes. East of the freility the nearest residences are on Pine Ridge Road about four miles down the canyon frca Schwartzwalder. An environmental sampling station is located at the home which was closest to the eine at the time of original licensure (5565 Fine Ridge Road).
! Since the licensing of the facility a residence has been constructed j northwest of the ore sorter at the top of the Ralston Creek Valley. '
Although closer than the Pine Ridge Road resideuce by several siles the prevailing wind patterns would indicate that it might receive a lesser effect from the Cotter facility.
l- For the purpose of this evaluation the Pine Ridge Road location will be used as the nearest residence. Planned revisions to the licensee's monitoring program will enable assessment of releases traveling in the direction of the home to the northwest.
II. i.ICENSEE'S SUBMISSION The licensee's saatannual submissions of September 25, 1984 and April 1,1985 did not contain calculations based on recent site specific data and are therfore unacceptable. In the June 1985 inspections the licensee was cited for noncompliance with LC 13.3.3.2 for the inadequate contents of their of f-site dose assessment.
( '~
,r>
. [i 3
)
> .. t
.
- e
, . . - , . . . . . . . .....w..,.. . .
(.
- ~
, ,. m m The as terial. submitted stated that a MILDOS calculation for Cotter's Whitewater ore sorter showed that facility to meet the 25 mrem standard and that Schwartzwalder being a smaller but similar facility vill also do so. Calculations performed by the licensee as prescribed by NUREG-0859 were stated to be inappropriate for a compliance determination due to the locations of the sampling.
The Department agrees with both the above statements but must emphasize that they do not meet the requirements for a dose assessment based on current site specific monitoring data. This review will present a Department assessment consistent with NUREG-0859 methods.
III. PATHWAYS A. External Dose - Direct Camma Radiation - The licensee measures direct gamma exposure at the Fine Ridge Road location by means of TLD's located on and off site and read quarterly. The extent of the dose via thit_ pathway is analyzed in the next section of this report.
B. Inhalation - Environmental air monitoring is performed at the Pine Ridge Road residence. The dose from the inhalation pathway will be analyzed in section IV.
C. Ingestion of Contaminated Vegetation - The distance of the nearest residence from the facility, the lack of crop production at the nearest residence specifically and the area generally and the low radionuclides concentrations at the of f-site sampling locations indicate the insignificance of pathways involving the ingestion of vegetation. 1984 average vegetation concentrations at the Pine Ridge Road Location were:
U Th-230 Ra-226 T767 pCi/g D.02 pCi/g D.02 pC1/g Altho;:gh the licensee has not established background concentrations with which to compare these values, the values listed above do not indicate any elevation. This pathway will not be analyzed further in section IV.
The ingestion of vegetation contaminated by irrigation with water from Ralston Creek or Ralstou Reservoir was considered. It must be noted that 1) this analysis is for the 1984 compliance period and contaminants contributed prior to this time are not to be
. considered; 2) present (1984) ore sorter effluents are relatively low in radioactive contaminants and contribute little to that already present in the creek and reservoir; and 3) the nearest residents do not cousume water from these sources.
D. Ingestic>n of Maat or Milk Crazed on Contaminated Vegetation -
Consistent with the remarks above further analysis of this pathway
- is unnecessary for 1984- data.
*?
QW.re ..% r.
- a - - -
g*
,.' - m 3 E. Ingestion of Contaminated Vater - All water used within the or e-sor te,r .is trea ted by the water-treatment plant at the facility before discharge into Ralston Creek. Treated water generally meets state drinking water criteria for radionuelldes and ef fluent iloits as set by a permit frem the Water Quality Control Division.
No contaminant seepage to grout.Jwater has been observed f rom the facility. If seepage vere to occur it would be unlikely to ef fect the wells of the nearest resident. Therefore, the waterborne contaminant pathways to the nearest resident will not be analyzed further.
Elevated levels of uranium series nuclides are present in Ralston Creek which leads to Ralston Reservoir and serves as a drinking l
water supply for Arvada and North Table Mountain. It should be noted that since the commencement of operation of the facility's vaste water- treatment plant and the reduction of the plant's radionuclides release to Ralston Creek elevated levels of radionuclides have remained in the creek's lower reaches near Ralston Reservoir. Present thinking attributes these levels to seepage of underground water from natural areas of uranium mineraliza tion. Although reasonable, this position is yet to be proven.
P. Ingestion of Meat or Milk From Stock Watered on Contaminated Water
- In consideration of the facts presented above and the lack of consumable livestock in the Pine Ridge Road area this pathway is assessed to be insignificant in this situation.
IV. DOSE ANALYSIS A. External Dose - Direct Gamma Radiation - Environmental TLD's are placed by the licensee at the ore sorter, the water treatment plant and the, Pine Ridge Road residence. An additional TLD is stored in s' lead box on site for use as a control in determining exposure in transit. Repiscenent and reading occurs quarterly.
The icilowing results were obtained for 1984:
" Control" 330 arem Water Treatment Plant 122 ares Ore Sorter 222 arem Pine Ridge Road 137 arem Determination of the net dose caused by ore sorter operations is precluded by the lack of availability of an appropriate background and a method of separating out the effects of the mine from those of the sorter.
The " control' TLD is not useful as a background .due to its placement in a lead box on site and is, apparently, also not useful for its intended purpose (a measure of exposure in transit) as indicated by its quarterly exposures approaching and sometimes exceeding those of the off-site TLD. The reason for the exposure to .the control TLD appears to be inadequate shielding.
- . . .,*.ss, , . .- - ', . .
e 9
(_
I
~
n .
, 7-Tha futura plac: ment of a true backgrcund TLD in ocas arco distant from the s, ige and free of mine and sorter influence is necessary and must be required by the licensing staf f. Unt(1 such time as this is accomplished a true net Pine Ridge Rosa exposure cannot be determined. It is noted that the gross exposure at the location,
- 137 mees / year, equates to approximately 16 uR/hr and is a typical background exposure for the area. BEIR III (1980) states the f natural radiation exposure in Colorado to be 164 mres/yr for terrestrial cosmic and internal sources. The Department's estimate is in the range of 250 arem/yr.
As the Pine Ridge Road exposure is in the range of natural background and data is unavailable to calculate an exact figure the Department vill use a net value of aero in this assessment for 1984 Procurement of adequate background data will allow a more
~
ezact determination within the next review.
B. Inhalation - Lacking a background determination, this review will determine a gross inhalation dose from all local sources to the Pine Ridge Road location.
l Concentrations (1984 average) of airborne radionuclides at the peerest residence:
9.17 X 10-8pC1/g 1.2575 X 10-7p ci/g 1.08975 X 10-7 pC1/m3 Doses calculated for the above:
Whole Body Bone I.un g U-cat 4.23 X 10-7 9.98 X 10-6 1.e4 X 10-5 Th-230 1.52 X 10-5 7.4 X 10-4 3.50 X 10-4 Re-226 2.'83 x 10-6 3.88 K 10-5 7.20 r 10-4 TOTAL 0.0000185 mres 0.000797 mres 0.00109 aren The inhalation dose is an insignificant fraction of the 25 mrem limit.
C. Other Pathways - Section 111 discusses reasons for elimination of all other pathways from consideration for 1984.
V. DOSE CO MITMENT
SUMMARY
.. Whole Body Bone g -
External Exposure -
Inhalation . 0.0000185 ares 0.000797 aree 0.00109 ares TtffA1. 0.0000185 ares 0.000iW ares 0.00109 arem
- Whole body external exposure is undetermined in 1984 due to the lack of an neceptable background sample. Available data indicates little if any contribution from the facility.
--_ m. _ _ _ _ _ _ _ _ _ _ _
iv
^
3 hI .. - StHMARY AND CONCLtfSIONS We of f-site dise for th'e licensed Schwartzwalder facility as calculated is well within the 25 aren limit for the year of 1984 Although the past monitoring pr ogram was noted to be inadequate in a number of respects, revisions to the program have been recently submitted and approved by the Det,artment to be instituted by the beginning of 1986.
The following additional recoseendations are made:
- 1. Realistic background values for all measured parameters need to be established for application in assessing net doses to the nearest residences. It should be noted that the present lack of a control location for environmental air monitoring ta a violation of LC 13.4.11.1. D e current inspection letter addresses this problem.
- 2. An assessment of the fac!'ity's effects on the residence northwest of the mill must be included in the next 40 CFR 190 compliance report. Monitoring of the residence may be necessary.
- 3. A diret:eefen of the relative effects of the ore sorter / water treatment plant versus the mine itself should be included in the next compliance report. It is recognised that the combined i effects of these facilities do not presently exceed license limits at this time, nevertheless the information will be useful to both the licensee and the Department.
- 4. Sect-annual of f-site dose compliance reports consistent with the Departmental policy statement dated July 1, 2*85 are required.
Comparisons or MILDOS calculations as provided in the past are not acceptable. 3 4
A A l 9
& n r-e.
A
// /
\
I
- _ _ _ _ _ _ _ _ _mm.-._. - _ _ _
.0 s' ~
MAR 2 e 1986 :.
i s
Thomas A. Vernon, M.D. ,
Executive Director Department of Health 4210 East lith Avenue Denver, Colorado 80220 -
Dear Dr. Vernon:
Thank you for your letter of February 4,1986, responding to our coments and recommendations following our 1985 review of your Department's radiation control program. Our review of the State's program and the routine exchange of infor-mation program between the Nuclear Regulatory Commission (NRC) and the State of Colorado had disclosed problems in two Category I indicators.
Your letter provided specific responses to the two Category We I and to the three recognize the Category II comments identified during our program review. Your positive effort set forth by the Radiation Control Division (RCD).
detailed answers to our comments have addressed our primary concerns and are acceptable.
Based on our overall review, your response to the* Category I and Category 11 comments, and the routine exchange of information between the State and the NRC, we believe'the Colorado radiation control program is' adequate to protect the public healt'h and safety and is compatible with the NRC's program for the regulation of similar materials.
I appreciate the courtesy and cooperation you and your staff extended to Mr. Ralph S. Heyer and other NRC representatives during the program review meeting. I am also enclosing a copy of this letter for placement in the State Public Document Room or to otherwise be made available for public viewing.
Sincerely.
071t$ntl etgned W-Robert D. Mcm.:a Robert D. Martin Regional Administrator ,
3
Enclosure:
As stated
/ f cc w/o enclosure:
Dr. Robert A. Arnott, Assistant Director /
{f Mr. Albert J. Hazle, Division Director {s Mr. G. Wayne Kerr, Office of State Programs, NRC N State Public Document Room \ /
bec: (see next page)
EDO AI: 86-063 RIV:S RSHryer;ap k SGAS RJ in 3/t1/B6 )/j'y86 / B6 j/ /86 $ / $6/86 unpam gy
g mn ., - c - -
.j
, , n..
' ' ' ,- .-' ,/.'5 -
l
. '. : 4 ;-
<z _
,15; ;
l .s i* s f l9 l- Y
,..,', ~
2- l L"atterL.to Thomas .' A.'.' Vernon. MlD. -
l
' i bec w/o enclosure:-
- PDR-(DMB SP01)
K LVStello, Jr., Acting-EDO-H , .RDMartini
.PScheck-
.'RLBangart g
CEWisner. .
!' P.JEverett :
RJDoda'
- .i lGFSanborn
- RSHeyer/
.RDSmith,'URF0 '
'DANussbaumer, OSP Colorado File de 6
l
__-_-_-_._._.___._.__..-_._.__.._.m__