< . . JUN 3 01988 APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION REGION IV URANIUM RECOVERY FIELD OFFICE NRC Inspection Report: 40-3453/88-001 Docket: 40-3453 Licensee: Atlas Minerals 743 Horizon Court, Suite 202 Grand Jurction, Colorado 81506 Facility: Atlas Uranium Mill Inspection at: Office and Mill Facilities, Moab, Utah Inspection Conducted: May 23-24, 1988 Inspectors: /5/ JUN 3 01988 H.D. Rose, Project Manager, Team Leader Date /S / JUN 3 01988 V.R. Scovill, Project Manager Date Approved: /5/ Date: JUN 3 01988 Harry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office | Region IV Inspection Summary Inspection conducted on May 23-24, 1988 (Report 40-3453/88-001) Areas Inspected: Routine unannounced inspection of Atlas Minerals Division's uranium mill and radiation safety program, including: Management Organization and Controls / Operations Review; Operator Training and Retraining; Maintenance, Surveillance and Testing; Radiation 4 Protection; Radioactive Waste Management; Transportation of Radioactive Material; Environmental Protection; Emergency Preparedness; and ( 8807120313 080630 PDR ADOCK 0400 ,3 C .
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APPENDIX CU.S. NUCLEAR REGULATORY COMMISSION
REGION IV
URANIUM RECOVERY FIELD OFFICE
NRC Inspection Report: 40-3453/88-001
Docket: 40-3453
Licensee: Atlas Minerals743 Horizon Court, Suite 202Grand Jurction, Colorado 81506
Facility: Atlas Uranium Mill
Inspection at: Office and Mill Facilities, Moab, Utah
Inspection Conducted: May 23-24, 1988
Inspectors: /5/ JUN 3 01988
H.D. Rose, Project Manager, Team Leader Date
/S / JUN 3 01988V.R. Scovill, Project Manager Date
Approved: /5/ Date: JUN 3 01988Harry J. Pettengill, ChiefLicensing Branch 2Uranium Recovery Field Office
| Region IV
Inspection Summary
Inspection conducted on May 23-24, 1988 (Report 40-3453/88-001)
Areas Inspected: Routine unannounced inspection of Atlas MineralsDivision's uranium mill and radiation safety program, including:Management Organization and Controls / Operations Review; Operator Trainingand Retraining; Maintenance, Surveillance and Testing; Radiation 4
Protection; Radioactive Waste Management; Transportation of RadioactiveMaterial; Environmental Protection; Emergency Preparedness; and
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Independent Measurements. In addition, soil samples were collected at10 various locations arouri the mill site, the results of which will beprovided at a-later date.
Results: Within the nine areas inspected, three apparent violations andone apparent deviation were identified in two areas as follows: Failureof the licensee to' provide proper training for embankment inspections;failure to calibrate survey instruments semiannually; failure to performoperational checks on radiation survey instruments prior to each days'use; and failure to calibrate raoiation survey instrumentation inaccordance with written procedures.
1. Persons Contacted
* Wayne Jensen, Moab Area Operations Manager* Dale Edwards, Radiation Safety Coordinator-Sue Davis, Administrative Assistant
*0enotes those present at exit interview.
2. Licensee Action on Previous Inspection Findings
(Closed) Violation (40-3453/87-001). Failure to develop writtenprocedures for the control of blowing tailings. The inspectorsnoted that the licensee has developed written procedures.
(Closed) Violation (40-3453/87-001). Unauthorized discharge ofliquids to tailings impoundment. The licensee had disconnected theflange to the discharge line to further reduce any potential forrepeat violations.
I 3. Management Srganization Controls / Operations Review
A license renewal was granted to Atlas on February 25, 1988. The millcurrently is shut down and is designated as being in stand-by status.The NRC inspectors reviewed the orga'nizational structure of the radiationsafety staff at the mill at the time of the inspection and over theperiod since the last inspection. The Radiation Safety Coordinator (RSC)implements the radiation safety program and reports to the RegulatoryAffairs Manager, who is located offsite at the Grand Junction, Coloradooffice.
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The highest corporate official normally onsite is the Moab Are.aOperations Manager. The licensee has assigned the Operations Manager tothe mill site on a full time basis. In prolonged absences, he formallydelegates responsibility to the mill coordinator. This closes the openitem (40-3453/87-001-01) identified during the previous inspection.
The' required weekly inspections and monthly reports-to management by theRSO were reviewed by the inspectors and found to be adequate. ALARAaudits required to be performed on a semiannual basis by the renewedlicense were reviewed by the inspectors and found to be in accordancewith requirements of the license. However, no ALARA audit for 1986 couldbe located. The licensee indicated that this was not a requirement ofthe license prior to renewal. A review of the previous licenae confirmed
-a requirement under License Condition No. 46C for documentation andsubmission of ALARA reports on an annual basis. Upon the request of theinspectors, Atlas did provide a copy of the 1986 annual ALARA audit onJune 10, 1988.
The inspectors examined the conditions at the mill and determined thatthey were similar to conditions found during prior inspections.Yellowcake stored on-site was secured behind a locked chain link fencewithin an open storage building.
No apparent viciations or deviations were identified by the NRCinspectors.
4. Operator Training and Retraining
The RSC attended radiation safety refresher training offered by RadiantEnergy Management through Union Carbice in July of 1987. An annual twohour radiation safety refresher for non-administrative employees was heldon December 2, 1987, taught by the RSC. Examinations were required with80% considered a passing grade. Course content, attendance and testquestions were consistent with regulatory guidance.
No female employees work in the mill area with the exception ofadministrative offices. Respirator training is conducted annually.
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Visitors and contractors are also provided with basic radiation safetytraining.
Regulatory Guide 8.31 recommends that all employees sign a statement thatthey have received job-specific radiatien safety training co-signed bythe instructor. Job-specific training for contractors was properly
documented with the exception of the instructor's signature, but no suchdocumentation existed for employees. This is considered an open item(40-3453/88-001-01).
No apparent violation or deviations were identified by the NRCinspectors. One open item was identified.
5. Maintenance, Surveillance and Testing
Very little routine maintenance is performed at the site. Access to therestricted area in which the mill is located is controlled by an outerperimeter fence. All personnel must enter the main mill office wherevisitors and contractors are required to check in. All other entrancesto the facility are locked and chained. The inspectors noted that the
- perimeter fences were in good repair and appropriately posted. Theentrances to the mill site were posted in compliance with LicenseCondition No. 14.
No apparent violations or deviations were identified by the NRCinspectors.
6. Radiation Protection
a. Air Sampling
The NRC inspectors reviewed Atlas's program for in plant airsampling which determines the airborne natural uranium
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' concentrations to which employees are exposed. Since the mill isnow in a standby status, airborne activity monitoring is only'
required to be conducted monthly at five locations within the mill.Radon samples are collected at the same five locations and analyzedusing the modified Kusnetz method. Routine breathing zone samples-are collected once a month from the workers who frequent the millproper. All air samples had been analyzed fluorometrically. Lowvolume air samplers had been calibrated quarterly using an airflowcalibrator that had been calibrated annually. Lapel samplers were,
i calibrated monthly using the airflow calibrator or bubble-tube| method. The Atlas representative stated that the turnaround time| for analysis of air samples was one day.!
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b. Exposure Determination
Atlas requires that internal exposure determination to airborneuranium be based upon breathing zone samplers. Each individualworking at the mill wears a personal sampler for one eight hour'shift while working in the mill. The U-nat concentration recordedduring this period is used as the basis for calculating exposures.The inspectors reviewed records of the exposure determinations andfound that the breathing zone results indicated the calculatedexposure to be below 10 percent of weekly maximum permissibleexposures. Respiratory protection is not required for use in themill in its current standby status. There were no RWPs issued sincethe previous inspection.
c. Bioassay
Atlas did have a bioas,ay program; however, since all work in themill ceased in April 1984, no bioassays have been taken,
d. External Exposure Control
Determination of employee external radiation exposure is madethrough thermoluminescent dosimeters (TLD's). The badges areexchanged and road quarterly by an offsite vendor. When employeesare not at work, the badges are kept in the guard house at the plantentrance. A control badge is maintained with the employee badgesand exchanged with the quarterly shipment of new badges. Theinspectors reviewed the vendor's 1987-1988 analyses and determinedthe results were provided to Atlas in a timely manner. The highestquarterly exposure recorded was well below the quarterly limit of1.25 rem.
Atlas also performs quarterly surveys for external radiation withinthe mill. Atlas' written procedures for calibration of surveyinstruments requires that survey instrumentation, utilized forexposure rate determination, be calibrated at a specific distancewhich would create at least one exposure rate for each rangeutilized. However, documentation indicated that the licenseedeviated from their written calibration procedure. Exposure rateinstrumentation was routinely calibrated only at three of the sixrequired distances and none of the ranges calibrated wereappropriate for measurements made in the yellowcake storage area.Upon further review, the inspectors determined that calibrationprocedures established by Atlas also deviated significantly fromthose procedures recommended in Regulatory Guide 8.30. This is an
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apparent deviation from the licensee's written survey instrumentcalibration procedures and regulatory guidance.
Further, Atlas is required by License Condition No. 32 of SourceMaterial' License SUA-917, to calibrate survey instrumentssemiannually. Upon a review of the calibration records theinspectors determined that Ludlum Model 12, Serial Number 17077 waslast calibrated in June 1987. This is an apparent violatinn ofLicense Condition No. 32. In addition, License Condition No. 32requires that all radiation survey instruments be checked for properoperation using a radiation check source prior to each days use.However, the licensee stated that operational checks were performedinfrequently, usually only once or twice per month, while manyinstruments were used daily in the performance of area and perscnnelsurveys. This is an apparent violation of License Condition No. 32.
e. Contamination Control
The inspectors reviewed elements of the Atlas contamination controlprogram which included surveys, showering, and the use of protectiveclothing when required under the license. Surveys were conducted inall eating areas that are in use every 2 weeks. If any area wasfound to be above 500 dpm/100cm2, it was surveyed weekly. Theadministrative offices that are in use were surveyed quarterly.
The alpha survey meter used by employees exiting the mill throughthe main office building is at the receptionist's desk where theymust check themselves and then sign out.
Two apparent violations and one apparent deviation were identified by theNRC inspectors.
; 7. Radioactive Waste Management
The inspectors reviewed the results of tailings area inspectionsperformed every four hours to confirm operation of the seepago pumpsystem and observe tailings movement under windy conditions. Daily, the
j licensee conducts and documents an inspection of wind direction andspeed, pump operations, pond levels, and any indications of blowingtails. License Condition No. 30A specifies a requirement that fieldinspectors be properly trained by the professional responsible for theannual technical evaluation to recognize and assess signs of possible
| distress or abnormality. Contrary to this requirement, field inspectors
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have not received specialized training of this nature. This isconsidered an apparent violation of License Condition No. 30A.Approxiaately 50 feet of beach was exposed and continues to be a sourceof windblown contamination. On one recent event, a tailings areainspection indicated strong winds were moving tailings to an areanorthwest of the pile, Following the inspectors report, the RSC sampledthe area and verified the movement of tailings. The licensee cleaned upthe affected area and resampled. NRC inspectors surveyed the clean-uparea and located several apparently contaminated areas nearby. Soilsamples were taken from the area to determine the need for more thoroughclean-up. The soil samples will be analyzed for U-nat and Ra-226 by anNRC contractor lab.
One apparent violation was identified by the NRC inspectors.
8. TransportationofRadioactiveMateri,a3
Since the previous inspection, the licensee has shipped yellowcake to twouranium conversion facilities. The total volume of approximately163,000 pounds transported was properly documented with a Bill of Lading,packing list, 741 form and emergency procedures accompanying theshipment.
Remaining inventory consists of 123,000 pounds stored within the securedyellowcake storage area.
No apparent violations or deviations were identified by the NRCinspectors.
9. Environmental Protection
Atlas' environmental monitoring program includes the taking of airparticulate, surface water, ground water, and radon t,amples. The datahad been submitted to the NRC in accordance with 10 CFR 40.65. Theinspectors reviewed the current data for 1987, and noted that theRadon-222 at the air sampler site S2 has increasc<: significantly over thelast three years. The licensee indicated that the increases, which occurduring the winter months, could be attributed to temperature inversionsand exposed beaches in the tailings impoundi.:ent. The NRC will continueto monitor the Radon-222 levels to determine if additional licensingaction will be necessarily. All other offsite releases were belowapplicable limits.
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Air samplers (three on perimeter, one background two miles down river,one in the Arches area) are changed weekly, composited quarterly and sentto an outside laboratory for analysis. Each location also includes'an-area TLD and Track-Etch passive radon monitoring device.
No apparent violations or deviations were identified by the NRCinspectors.
10. Emergency Preparedness
The fire protection system at the mill consists of fire extinguisherslocated throughout the mill, an automatic foam fire suppression system inthe solvent extraction area, and an autorratic fire suppression sprinklersystem in the main mill building. In consideration of the small numberof personnel at the mill available to respond to a fire emergency, Atlas'stated policy is to call the Moab, Utah fire department. The firehouseis 5 minutes travel time from the mill complex.
. Fire fighting apparatus and equipment on site had been inspected monthly.On a weekly basis, licensee staff inspects the SX foam system andverifies the operating capability of the diesel backup system. Theinspectors reviewed records of inspections of the equipment in thefac'lity and determined that they were in order.
License Condition No. 23 requires in part, that the licensee establishspecial written procedures when the plant is in an extended standby orshutdown condition. Further, Regulatory Guide 8.31 recommends writtenprocedures for' response to fire emergencies. Atlas has not modifiedtheir emergency response procedures to reflect the current standbystatus. The current procedures assume the availability of a full staffunder operating conditions. - The licensee has also not revised theprocedure to reflect their policy of utilizing the Moab fire departmentfor fire protection. According to the licensee representative,modifications correcting this situation are in progress. This isconsidered an open item (40-3453/88-001-02) to be reviewed during thenext inspectica.
No apparent violations or deviations were identified by the NRCinspectors. One open item was identified.
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11. Independent Measurements
The inspectors collected eight soil samples around the perimeter of therestricted area and two within an area previously cleaned of windblowncontamination.~ Results of these samples, which were split with thelicensee, will be reviewed upon receipt of laboratory data.
12. Exit Interview
The NRC inspectors met with the Atlas representatives at the conclusionof the inspection on May 24, 1988. The inspectors summarized thepurpose, scope, and findings of the inspection. The Atlasrepresentatives indicated that they had the impression that they had oneyear from the issuance of the renewed license to comply with the fieldinspector training requirement, and that equipment calibration was onlyrequired annually on the previous license. The inspectors stated thatthe licensee had not made a reasonable effort to bring themselves intotimely conformance with the requirements of the renewed license, and thatthe apparent violations would therefore be brought to the attention ofNRC management.
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License Conditicn No. 32 requires, in part, that all radiationt
survey instruments be checked for proper operation using a,
4.radiation check source prior to each days' use.
Contrary to this requirement, the licensee routinely utilizedt
radiation survey instruments which were not checked for proper* operation. Specifically, the instruments utilized to conduct'- daily personnel contamination surveys were checked for proper
operation only once or twice per month.e
This is a Severity Level IV Violation (Supplement VI).
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Atlas' written standard procedure for calibration of surveyt~
fnstruments requires that they be calibrated at six specific* distances which produce known exposure rates for each distance.Further, Regulatory Guide 8.30 recommends that each instrument bet
calibrated at two points at about one-third and two-thirds of each,
linear scale ;outinely used or with a calibration at one point near-
* the midpoin' of each decade of logarithmic scales that are routinely,. used.
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Contrary to this commitment, the licensee calibrated surveyinstruments only at three of the six required distances. Further,*
the licensee had not addressed, in their written survey instrumentacalibration procedure, calibration at two points at about one-third"- at two-thirds of each linear scale or at the midpoint of each decadeof logarithmic scales.u
