ML20198H075

Discusses Review of State of Nm Request for USNRC Review of Proposed Termination of Gulf Minerals Resources Co Radioactive Matl License NM-GUL-IX-00

ML20198H075
Person / Time
Issue date:	07/24/1984
From:	Brich R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
TASK-TF, TASK-URFO NUDOCS 9801130189
Download: ML20198H075 (4)

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. DISTRIBUTION URF0 s/f SIS-31 URF0 r/f JCollins SIS.31/RFB/84/07/17/0 RBrich 1 MHood JUL 24 w URF0:RFB SIS-31 63000330100E MEMORANDUM FOR: File No. SIS-31 FROM: Randall F. Brich, Project Manager Licensing Branch 1 Uranium Recovery Field Office, Region IV G

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SUBJECT:

REVIEW OF STATE OF NEW MEXICO REQUEST FOR USNRC REVIEW 0F PROPOSED TERMINATION OF GULF MINERALS RESOURCES COMPANY RADI0ACT:VE MATERIAL LICENSE NM.GUL.IX-00

Background

On June 14, 1984, Mr. D. A. Nussbaumer of the Office of State Programs of NRC requested our review of the State of New Mexico, Environmental Improvement Division's (NM-EID) proposed termination of Radioactive Material License, NM-GUL-IX.00 currently held by Gulf Minerals Resources Company (GMRC) for operation of an ion exchange facility associated with mine dewatering at the Mariano Lake Project, McKinley County, New Mexico.

O By 1etter dated ">> ts.1984. (F a D. A. Nussbaumer, NRC) New Mexico requested NRC review of the proposed

"$ era ar " a to termination of subject radioactive materials license and all associated amendments. Enclosed with the May 15, 1r34 letter to D. A. Nussbaumer was a letter dated April 20, 1984, from Bureau of Land Management (BLM) to New Mexico stating that they had reviewed NM.EID's report and concur l with the proposed licen.;e terminetion as explained in detail in the letter dated April 11, 1984, from NM.EID to BLM.

The April 11, 1984 letter contains pertinent information concerning the objective of the remedial action at the Gulf Mariano Lake ION exchange facility which was, to:

1. decontaminate and dismantle the Ion exchange pl.vit for resale; f

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2. drain the three lagoons and remove radioactive sludge;

3. recontour the land to its original condition; and

4. revegetate the site with an appropriate grass seed mixture native to this region.-

The reclamation of the underground mine, mine yard, ore storage pad, associated equipment and buildings, and Ion exchange complex was considered a joint management effort between the BLM and the NM-EID. BLM assumed overall jurisdiction and provided techaical support to the Bureau of Indian Affairs (BIA), since the project was situated on Indian Allotted Lands.

Both PLM and NM-EID supplied similar radiological cleanup criteria to Gulf to make certain that the remedial action efforts would be compatible. BLM assumed management responsibility over the reclamation of the following areas; underground mine closure, abovc-ground mine yard and ore storage pad restoration, associated mine complex buildings and equipment dismantling and decontamination, surface land decontamination and contouring, and revegetation for the main mining yard complex. The NM-EID was responsible for assur'ng that the edjacent ion exchange plant and associated lagoons were reciaimed in accordance with NM-EID criteria.

The following discussion highlights the salient features identified during my review of the NM-EID report on the reclamation of the Ion exchange plant and associated lagoons.

ION Exchange Facility According to the letter dated April 11, 1984 from NM-EID to BLM, the Ion O Exchange facility was decontaminated to NM-EID criteria, dismantled and sold. NM-EID personnel surveyed the Ion exchange and holding tanks, piping network, plant building and equipment in order to terify that decontamination procedures were in accordance with the criteria for release to unrestricted use. This letter states that the facility and associated equipment were decontaminated to acceptable levels for unrestricted use. The NM-EID decontamination levels were identical to those centeined in Table 1, Annex C (WM-7601, November 1976).

Lagoons The lagoons which held the mine water were drained and the radioactive sludge was removed and mixed with available uranium ore, whereupon this

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SIS-31/RFB/84/07/17/0 JUL 2 4 084 ore was transported to a licensed mill fcr future processing. The synthetic liners from the lagoon were monitored and taken to the main nine yard former ore storage pad area for burial beneath mine overburden ma terial .

Vegetation Tne letter states that the land was recontoured to approximately the original condition and reseeded with plant species native to the region, and reclamation efforts appear successful.

Protocol for Radiological Su,rveys q The area was gridded on 10-foot centers (100 square feet) and gamma ray O exposure rate measurements were made at the grid points and in the center of each grid at one (1) r.eter above the grcJnd With micro R meters cross calibrated to a pressurized ionization chamber. Representative surface soil samples were collected at the grid intersection points across the ion exchange complex with both surface and subsurface soil samples composited at five other locales including the former ion exchange building. All soil samples were sent to the NH State Laboratory for Ra-226 and Unat analysis. One split sample was sent to an independent laboratory for quality assurance comparison purposes. In addition, a continuous radon sampler was operated for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in the center of the project site.

Discussion The results of the gamme ray exposure rate monitoring indicates that one

- localized hot spot (240 uR/hr) in the rortheast quadrant of the property

( ,) of approximately 1 square meter was decontaminated immediately. A resurvey of the location on July 14, 1983, identified about 25 uR/hr or approximately twice background. Review of the entire licensed facility surface measurement <. shows that all were below the NM-EID target level of 25 uR/hr.

A 6-hour continuous measurement of radon-222 averaged 0.356 pCi/l compared with 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Tedlar Bag samples yielding an estimated annual concentration level of 0.254 0.252 pCi/1. Background for this area was .

previously reported at 0.55 0.07 pCi/1. The Ra-226 and Unat soil samples averaged 0.377 0.416 pC1/g and 8.8 12.4 ug/g respectively.

Background for Ra-226 in this area was 0.5 0.2 pCi/g.

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- - M 24 W The gama ray exposure rate, radon-222 concentration and Ra-226 ,

concentration in soils were well below the minimum cleanup standards and '

less than the target levels NM-EID provided to Gulf by letters dated July 2, and November 4,1982. These target levels were 10 pct /g for Ra-226, 25 uR/hr for the gamma ray exposure rate, and 3 pC1/1 for ambient radon '

in air.

• l All equipment at the plant was dismantled and decontaminated to levels ,

below these listed in Enclosure 1 of the letter dated July 2,1982 l (NM'EIDtoGulf).

Conclusions Based on my review of the information submitted by the NM-EID, I conclude O

that GMRC has adequately decomissioned the site for release for unrestricted use. Based on a telephone conversation with Mr. Sam Simpson of the NM-EID, I understand that the proper land records will be amended to include a description of the former use of the property.

In accordance with the provisions of 10 CFR 150.15a, my review indicates that cleanup and reclamation of the ion exchange site meets all applicable standards pertaining to the decontamination, decomissioning and reclamation of the site. Therefore, I recommend that NM-EID be informed that USNRC has no objection to termination of the subject license.

Randall F. Brich, Project Manager Licensing Branch 1 O- uranium Recovery rie1d Office Oricirmi sienna ty Region IV Approved by:

Edward F. Hawkins, Chief Licensing Branch 1 Uranium Recovery Field Office, Region IV Case Closed: 63000330100E

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