POWER Smith Ranch -Highland · Highland CPF remains on standby status. It is anticipated that the Highland CPF will remain in standby status for several upcoming reporting periods

POWERRESOURCES

Smith Ranch - HighlandUranium ProjectP. 0. Box 1210Glenrock, Wyoming USA 82637Casper: 307-235-1628Douglas: 307-358-6541Fax: 307-3584533February 9, 2005

ATTN: Document Control DeskGary S. Janosko, ChiefFuel Cycle Facilities Branch,Division of Fuel Cycle Safety and SafeguardsOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory Commission11545 Rockville Pike, Two White Flint NorthRockville, MD 20852-2738

RE: Smith Ranch-Highland Uranium ProjectNRC License SUA-1 548, Docket No. 40-8964Semi-Annual Effluent and Environmental Monitoring Report, July I - December 31, 2004

Dear Mr. Janosko:

In accordance with 10 CFR 40.65 and License Condition No. 12.2 of License SUA-1548, pleasefind enclosed the Semi-Annual Effluent and Environmental Monitoring Report for the SmithRanch-Highland Uranium Project. This report covers the period July I through December 31,2004. A copy of this report is also being forwarded to Mr. John Lusher, USNRC Headquarters,and Mr. Dwight Chamberlain, Director DRSS, Region IV.

If you have any questions regarding the report, please contact me at (307) 358-6541, ext. 62.

Sincerely,

W.F. KearneyManager-Health, Safety& Environmental Affairs

WFK/klm

Enclosure

cc: Mr. John Lusher, USNRC Headquarters (Addressee Only)Mr. Dwight Chamberlain, Director DRSS, Region IV, USNRCS.P. Collings w/o atta

'(c

A member of the Cameco group of companies

C. Foldenauer w/o attaK. L. Milmine w/o attaFile SR 4.6.4.1

/X' (L75

POWER RESOURCES, INC.

SMITH RANCH - HIGHLAND URANIUMPROJECT

SEMI-ANNUAL EFFLUENT ANDENVIRONMENTAL MONITORING

REPORT

FOR THE PERIOD

JULY 1, 2004 THROUGHDECEMBER 31, 2004

USNRC SOURCE MATERIAL LICENSENO. SUA-1548

DOCKET NO. 40-8964

TABLE OF CONTENTS

1.0 RESULTS FROM EMPLOYEE URINALYSES IF AN EXPOSURE EXCEEDS ACTIONLEVELS DESCRIBED IN THE OPERATIONS PLAN OF THE APPROVED LICENSEAPPLICATION ....................................................... 1

2.0 INJECTION RATES, RECOVERY RATES, AND INJECTION TRUNK-LINEPRESSURES FOR EACH SATELLITE FACILITY ....................................................... 1

2.1 SATELLITE NO. I ................................................................... I12.2 SATELLITENO. 2, SATELLITENO. 3, SATELLITE SR-i, CENTRAL PROCESSING PLANT ....................................... 1

3.0 RESULTS OF EFFLUENT AND ENVIRONMENTAL MONITORING INCLUDINGWATER QUALITY ANALYSES AND MONITORING REQUIRED BY THE WDEQPERMIT FOR THE OPERATING IRRIGATION SYSTEMS ................................................... 2

3.1 STACK EMISSION SURVEYS ............... .................................................... 23.2 AIR PARTICULATE, RADON, AND GAMMA RADIATION MONITORING ................................................................. 23.3 WATER SAMPLING DATA .................................................................... 3

3.3.1 Groundwater and Surface Water Monitoring Stations . ................................................................ 33.4 WASTEWATER LAND APPLICATION FACILITIES MONITORING .................................................................. 4

3.4.1 Soil and Vegetation Sampling .43.4.2 Irrigation Fluid .43.4.3 Radium Treatment Systems 53.4.4 Soil Wtater.53.4.5 Satellite No. I Purge Storage Reservoir Monitor Well.............................................................................63.4.6 Satellite No. 2 Purge Storage Reservoir Shallow WTells............................................................................6

4.0 SAFETY AND ENVIRONMENTAL EVALUATIONS ........................................... 6

5.0 RUTH ISL PROJECT ............................................ 7

6.0 NORTH BUTTE ISL PROJECT ........................................... 7

ATTACHMENT A- Data Tables 1-12

ATTACHMENT B- Safety and Environmental Evaluations Completed in 2004

2

1.0 RESULTS FROM EMPLOYEE URINALYSES IF AN EXPOSURE EXCEEDS ACTIONLEVELS DESCRIBED IN THE OPERATIONS PLAN OF THE APPROVED LICENSEAPPLICATION

During the period July 1 through December 31, 2004, two bioassays exceeded the action level of 15pg/L uranium.

One elevated bioassay was taken on September 16, 2004 and contained a uranium concentration of 61ug/L uranium. This bioassay was for an electrician who had voluntarily terminated employment andwas taken on the employee's final day of work as an "exit" sample. As detailed in the investigationreport submitted to the NRC on October 12, 2004, the employee was not around any significant amountof uranium, wore appropriate PPE, washed regularly, and was not involved in any upset conditions.Therefore, it was concluded that there was no readily apparent reason for the result except for samplecontamination. It could not be determined through investigation how the contamination occurred. Thesample was analyzed several times to validate the results and the former employee was contacted oncethe results were known and asked to voluntarily provide another sample. However, no more additionalsamples would be obtained from the individual.

The second elevated bioassay result was from a routine weekly sample taken on November 22, 2004from the dryer operator. The result of this sample was 17.0 ug/L uranium, which was re-analyzedseveral times by the contract laboratory for verification. Investigation determined that it is very likelythe sample was contaminated during sample collection as the employee's hands were not washed priorto opening the sample container and work clothing (coveralls) were not removed prior to obtaining thesample. The individual had just unloaded emptyyellowcake drums. Previous and subsequent bioassaysamples for this employee were all less then 5 ug/L. The employee was refreshed on companyprocedures, which require weekly dryer operator bioassay samples to be taken on Monday morning inclean clothes prior to proceeding with any work activity.

2.0 INJECTION RATES, RECOVERY RATES, AND INJECTION TRUNK-LINE PRESSURESFOR EACH SATELLITE FACILITY

The required information for each Satellite facility for the 3rd and 4h Quarters of 2004 is presented inTables I A, I B, I C, and I D included in Attachment A.

2.1 Satellite No. I

Satellite No. 1 did not operate during the report period since restoration activities in the A and BWellfield are complete. Therefore, no injection or recovery rates are available for the reportperiod.

2.2 Satellite No. 2. Satellite No. 3. Satellite SR-1. Central Processing Plant

The injection rates, recovery rates, and injection pressure data for SatelliteNo. 2, SatelliteNo. 3,Satellite SR-1, and the Central Processing Plant (CPP) are contained in Table IA, 1B, and I C.

1

The injection rates represent the total recovery rates minus the purge (clean-out circuit) flow.The purge from Satellite No. 2 and No. 3 is treated for uranium and radium removal andpumped to the Satellite No. 2 Purge Storage Reservoir prior to disposal by irrigation at theSatellite No. 2 Land Application Facility. Purge from Satellite SR-1 and the CPP is disposed bydeep injection through permitted waste disposal *vells.

3.0 RESULTS OF EFFLUENT AND ENVIRONMENTAL MONITORING INCLUDING WATERQUALITY ANALYSES AND MONITORING REQUIRED BY THE WDEQ PERMIT FORTHE OPERATING IRRIGATION SYSTEMS

3.1 Stack Emission Surveys

When the Central Processing Facility (CPF) at the Highland Uranium Project is operational, PRImonitors the Yellowcake Dryer and Packaging scrubber exhaust stacks to determine theemission rate of particulates, uranium, radium, and thorium. During the report period, theHighland CPF remained on standby status as all yellowcake processing activities (elution,precipitation, drying, and packaging) were conducted at the Smith Ranch Central ProcessingPlant. The dryers at the Smith Ranch Central Processing Plant are zero emission vacuum dryersthat do not require emission stack testing. Therefore, no stack tests were conducted during thereport period. It is anticipated that the CPF at Highland will remain on standby status duringseveral upcoming report periods.

3.2 Air Particulate. Radon, and Gamma Radiation Monitoring

PRI maintains five Air Monitoring Stations at various locations on and around the licensed area.Two of these stations are used to monitor downwind conditions of the Highland CPF, andmonitoring is not required unless the CPF is in operation. The Air Monitoring Stations are usedto monitor air particulates, radon, and gamma radiation. The stations are located as follows:

* AS-1 (Dave's Water Well): This station monitors background conditions, upwind ofboth the Smith Ranch and HUP wellfields and yellowcake processing facilities.

* AS-2 (Smith Ranch Restricted Area): This station monitors conditions downwind of theSmith Ranch CPP Restricted Area Boundary.

* AS-3 (Vollman Ranch): This station monitors the nearest downwind resident to theSmith Ranch CPP Restricted Area.

* AS-4 (HUP Restricted Area): This station monitors conditions downwind of the HUPCPF Restricted Area Boundary (when the HUP CPF is operating).

* AS-5 (Fowler Ranch): This station monitors the nearest downwind resident to the HUPCPF Restricted Area (when the HUP CPF is operating).

2

Monitoring at AS-4 and AS-5 was not conducted during the reporting period since theHighland CPF remains on standby status. It is anticipated that the Highland CPF willremain in standby status for several upcoming reporting periods and monitoring ofdownwind air stations will only resume if the Highland CPF becomes operational.

Table 2 shows the air particulate and radon data collected at these sites during the reportperiod. Review of data collected during the report period shows that the concentrationsof all parameters are significantly less than the 10 CFR 20, Appendix B, EffluentConcentration Limits. Radon concentrations during the report period at the backgroundstation AS-1 (Dave's Water Well) were approximately half of normal radonconcentrations determined from past monitoring at this site during the 3rd quarter andsignificantly higher than normal concentrations in the 4h quarter. PRI can find noapparent cause for this fluctuation in radon levels at the background station, except forpotential laboratory error.

Gamma radiation data for the report period are provided in Table 3. 10 CFR 20Appendix B contains no Effluent Concentration Limit for gamma radiation forcomparison. However, gamma results for the report period are within normalbackground conditions and show no discemable trends with previous data.

3.3 Water Sampling Data

3.3.1 Groundwvater and Surface Water Monitoring Stations

During the report period, monitoring was completed at nine water wells and five stock pondsthroughout the permit area. Water samples are collected from the water wells and stock pondson a quarterly basis for analysis of uranium and radium-226. Table 4 provides the analyticaldata for samples collected during the report period. A review of data collected during the reportperiod shows that the five stock ponds (Stations SW-2, 3, 4, 5, and 9) remained dry during thereport period and three water wells (GW-8, 9, and 10) did not run during the report period. Areview of data collected from the nine water wells and five stock ponds, with the exception ofwater well GW-5, show that the concentrations of uranium and radium-226 are well below the10 CFR 20, Appendix B, Effluent Concentration Limits of 3.01E-07 ptCi/mL and 6.0E-08tiCi/mL, respectively.

Water Well GW-5 is located in an area with shallow uranium mineralization, along with otherradioactive minerals. These areas are referred to as the "Snow Claims", which have a zonedepth from approximately 50 to 120 feet. Well GW-5 has a depth of approximately 100 feet,which falls in this mineralized zone. Due to the shallow nature, portions of the mineralizedzone may dry out seasonally potentially causing uranium to oxidize, and as a result increase itssolubility in water. Therefore, the higher uranium concentrations in this well are naturallyoccurring due to the uranium mineralization in the shallow aquifer in which GW-5 is completed.PRI does not believe that the higher uranium levels are due to impacts from mining operations

3

due to the large distance to the nearest wellfield (approximately 1/2 mile from the F-Wellfieldmonitor well ring), and the known occurrence of these shallow ore basics.

Results for GW-5 obtained during the 4h Quarter of 2004 remained consistent with previousresults from the 4th Quarter of 2003 at approximately 0.882 mg/L.

3.4 Wastewater Land Application Facilities Monitoring

3.4.1 Soil and Vegetation Sampling

In accordance with the approved license application and the WDEQ permits for the Satellite No.I and Satellite No. 2 Wastewater Land Application Facilities, soil and vegetation sampling ofthe irrigation areas is conducted in late summer of each year. The soil and vegetation data arecollected to monitor and evaluate any adverse effects to the irrigation areas. The 2004 soil andvegetation sampling at the irrigation areas was conducted on August 6.

Soil data from the Satellite No. 1 and Satellite No.2 Wastewater Land Application Facilities areprovided in Tables 5 and 6, respectively. Comparison of data from the report period withprevious data shows no significant change in radium-226 concentrations and a slight increase inuranium concentrations at the Satellite No. 1 facility. Uranium concentrations at the zero to six-inch depth remain elevated above baseline conditions for the irrigation area at Satellite No. 1 in2004.

Uranium concentrations at the zero to six-inch depth for the Satellite No.2 irrigation area showno discernable change from the concentrations seen in 2003. Uranium concentrations at the sixto twelve-inch depth and radium-226 concentrations at both depth intervals remain nearbaseline. The approved license applications for the facilities predicted that, at the end ofoperations, uranium concentrations in soil would be elevated above baseline, while radiumconcentrations would remain near baseline. Therefore, PRI does not anticipate any problemswith meeting the criteria in 10 CFR 40 during decommissioning of the facilities.

Vegetation data from the Satellite No. I and Satellite No. 2 Wastewater Land ApplicationFacilities are provided in Tables 7A and 7B, respectively. Comparison of data from the reportperiod with previous data does not indicate any significant changes. Uranium concentrationsremain slightly elevated above baseline conditions and radium-226 concentrations remain nearbaseline.

3.4.2 Irrigation Fluid

In accordance with the approved license application and the WDEQ Wastewater LandApplication permits, PRI monitors the treated irrigation fluid that is disposed of at bothirrigation facilities. Grab samples are collected at the irrigator pivot during each month ofoperation and analyzed for various parameters. Irrigation fluid data collected at the SatelliteNo.1 Land Application Facility during the report period is provided in Table 8. A review of thedata indicates that the concentrations of uranium in the monthly grab samples did not exceed the

4

10 CFR 20, Appendix B, Effluent Concentration Limit (ECL) of 3.OE-07 [iCi/ml and were lessthan the range of concentrations estimated for injection fluid in the original license applicationfor the facility (2.93E-07 to 1.86E-06 ItCi/ml). Similarly, radium-226 concentrations in themonthly grab samples did not exceed the 10 CFR 20, Appendix B, Effluent Concentration Limitof 6.OE-08 gCi/ml (60 pCi/L) or the estimate provided in the original license application for thefacility (3.OE-08 ftCi/ml).

Irrigation fluid data collected at the Satellite No. 2 Land Application Facility during the reportperiod is provided in Table 9. A review of the data indicates that the concentration of uraniumin the monthly grab samples slightly exceeded the 10 CFR 20, Appendix B, EffluentConcentration Limit of 3.OE-07 IiCi/ml, but were significantly less than the estimate provided inthe original license application for the facility (1.4E-06 jiCi/mil). The samples containedradium-226 concentrations below the 10 CFR 20, Appendix B, Effluent Concentration Limit of6.0E-08 ItCi/ml (60 pCi/L) and below the estimate provided in the original license applicationfor the facility (3.OE-09 ItCi/ml).

3.4.3 Radium Treatment Systems

PRI collects grab samples each month to ensure that the radium-226 treatment systems areadequately treating wastewater from Satellites No.2 and No. 3 prior to discharge into the PurgeStorage Reservoir. No samples were collected from the Satellite No. 1 radium treatment systemsince Satellite No. I did not operate during the report period. The monthly radium-226 grabsamples for Satellite No. 2 and No. 3 are collected at the discharge points of the radiumtreatment system at each facility. The results of this monitoring are included in Table 1 OA, 1 OB.Review of the monitoring data shows that all radium-226 concentrations were below the 10

CFR 20, Appendix B, Effluent Concentration Limit of 6.OE-8 pCi/ml (60 pCi/L) at Satellite No.2 during the report period. Review of the monitoring data for Satellite No. 3 shows that thesample taken on September 2,2004 contained radium-226 levels slightly above the 10 CFR 20,Appendix B, Effluent Concentration Limit of 6.0E-8 gCi/ml (60 pCi/L). All other results forthe report period were belowv the Effluent Concentration Limit.

The discharge of wastewater containing slightly higher levels of radium-226 described above isnot expected to have a significant affect on the quality of irrigation fluid. Evidence to this isprovided by the subsequent analytical results of irrigation fluid samples collected from theSatellite No. 2 and No.3 Wastewater Land Application Facility. The radium concentrations inSeptember of 2004 at the Wastewater Land Application Facility was 9.OE- 1O pCi/ml (IrrigatorNo. 2 irrigation fluid), which is significantly less than the 10 CFR 20, Appendix B, EffluentConcentration Limit of 6.OE-8 pCi/ml for radium-226.

3.4.4 Soil Water

In accordance with the approved license application and the WDEQ Wastewater LandApplication Facility permits, PRI collects soil water samples at the irrigation areas in June ofeach year and analyzes them for various parameters, including uranium and radium-226.Sampling was conducted on June 15, 2004, but due to drought conditions and the relatively

5

limited amount of irrigation, there was insufficient soil water available to produce a sample atany of the sample locations for the Satellite No. 1 and Satellite No. 2 irrigation areas.

3.4.5 Satellite No. 1 Purge Storage Reservoir Monitor Well

A shallow monitor well, located southwest of the Satellite No. 1 Purge Storage Reservoir, ismonitored at least weekly for potential seepage from the reservoir. There was no evidence ofseepage during the report period.

3.4.6 Satellite No. 2 Purge Storage Reservoir Shallowe Wells

In accordance with the approved license application, water levels are measured on a quarterlybasis and ground water samples are collected on a semi-annual basis from the two shallowmonitoring wells located adjacent to the Satellite No. 2 Purge Storage Reservoir (PSR-2).Shallow Wells No. 1 and No.2 are located adjacent to the south and east sides of the reservoir,respectively. During the report period, monitoring was conducted on September 28 andNovember 4, 2004. Shallow Well No. 1 contained insufficient water to sample on bothoccasions and as a result, there is no data available for the report period. Table 12 contains theapplicable data for Shallow Well No. 2.

Comparison of the uranium and radium-226 data from Shallow Well No.2 does not indicate anysignificant trends or changes from previous report periods. Comparison of water level datacollected during the report period with previous data continues to show a trend of higher waterlevels during the spring-summer months and lower water levels during the fall-winter months.

4.0 SAFETY AND ENVIRONMENTAL EVALUATIONS

All safety and environmental evaluations made by the Safety and Environmental Review Panel(SERP) and resulting changed pages to the Operations Plan and Reclamation Plan of theapproved license must be submitted on an annual basis. During the period January 1 throughDecember 31, 2004, PRI completed the following Safety and Environmental Evaluations:

Safety and Environmental Evaluation No. 2004-1- Dated April 23, 2004, for start-up of I-Wellfield.

Safety and Environmental Evaluation No. 2004-2- Dated July 22, 2004, for changes to theSmith Ranch general well sampling methods, Highland reporting parameters, and new accessdatabase implementation.

Safety and Environmental Evaluation No. 2004-3- Dated July 30,2004, for revised UCL's formonitor well M-212.

Safety and Environmental Evaluation No. 2004-4- Dated August 27, 2004, for changes to theradiation safety protection staff.

6

Safety and Environmental Evaluation No. 2004-5- Dated October 12, 2004, for changes to theradiation protection program.

Safety and Environmental Evaluation No. 2004-6- Dated December 21, 2004, for temporarymanagement replacement for General Manager of Operations.

Consistent with License Condition 9.4E, the above Safety and Environmental Evaluations and,if applicable, revised pages to the Operations Plan of the approved License Application, areincluded in Attachment B.

5.0 RUTH ISL PROJECT

The Ruth Project is licensed for commercial ISL uranium activities, however none has beeninitiated. The existing buildings and evaporation ponds, along with a few remaining wells, areleft from research and development testing conducted by Uranerz, USA, one of the previouslicensees. The facilities at the project are non-operational and on stand-by status. Therefore,radiation and effluent monitoring was not conducted and is not required by the NRC or theWyoming Department of Environmental Quality. The quantity of radionuclides released tounrestricted areas in liquid and in gaseous effluents is considered negligible and is notapplicable at this time.

Activities conducted during the report period consisted of monthly inspections of the existingfacilities. During September of 2004, water was detected in the East and West EvaporationPond Standpipes. Follow-up sampling of the Evaporation Ponds and standpipes indicates thatthe water is most likely a result of surface water drainage or condensation, but not from pondleaks. Inspection of the perimeter fence, pond embankments, and pond liners yielded nodeficiencies during the report period.

In accordance with License Condition 10.2.2 amended on December 3, 2004, Inspections oftheRuth site will now be conducted quarterly hence fourth.

6.0 NORTH BUTTE ISL PROJECT

The North Butte Project is also licensed for commercial ISL uranium operations, however,construction of facilities has not commenced and is currently on hold. Since there are noradioactive materials present on site, no radionuclides were released to unrestricted areas inliquid or in gaseous effluents.

License Condition 9.5 requires PRI to submit, for the NRC and WDEQ-LQD approval, anitemized cost estimate for implementation of the NRC-approved decommissioning/restorationplan prior to commencement of construction of a commercial facility at the North Butte/Ruthsites. Currently, PRI is in the process of updating the Operations and Reclamation Plan for theNorth Butte ISL Project in pursuit of approval to commence construction activities at the NorthButte site.

7

ATTACHMENT A

DATA TABLES 1-12

TABLE IASATELLITE NO. I INJECTION RATES, RECOVERY RATES, INJECTION PRESSURES

Injection Pressure(PSI)

RO #1 RO #2 R0 0

MONTHJul-04Aug-04Sep-04Oct-04Nov-04Dec-04

O #30

00000

00000

00000

GrounwaterSweep

GPM000000

RadiumPondsGPM

000000

ROFeedGPM

000000

InjectionGPM

000000

ROConcentrate

GPM000000

PurgeFlowGPM

000000

TABLE 1 BAVERAGE INJECTION RATES (GPM)


Satellite No. 22,4112,6952,8272,8392,9252,821

Satellite No. 32,3022,1801,9221,9961,8451,776

Satellite SR-I2,6302,6382,5662,2582,2662,200

Central Processing Plant3,9183,8203,7183,3183,3083,236

TABLE ICAVERAGE RECOVERY RATES (GPM)


Satellite No. 22,4392,7182,8582,8702,9692,869

Satellite No. 32,3402,2271,9572,0421,8921,831

Satellite SR-I2,6442,6502,5802,2702,2782,213

Central Processing Plant3,9463,8953,7523,3543,3363,264

TABLE IDINJECTION TRUNK LINE PRESSURES (PSI)


Satellite No. 2839288928285

Satellite No. 3646161748087

Satellite SR-I727165605961

Central Processing Plant168164161175174171

TABLE 2

AIR SAMPLING DATA - 2004ENVIRONMENTAL MONITORING SITES

3rd & 4th QUARTERS

SAMPLELOCATION

FENCE LINEAir StationRestricted AreaBoundary

SAMPLEPERIOD

3rdQuarter

4thQuarter

VOLLMAN RANCHAir StationDownwind NearestResidence

3rdQuarter

RADIONUCLIDE(pCImI)

U-NatTh-230Ra-226Pb-210Rn-222






CONCENTRATION(pCUmI)

3.47E-16<1.00E-16'1.OOE-161.32E-141.40E-09

4thQuarter

EFF. CONC.ERROR EST. +/- L.LD. LIMIT

(pCIlml) (pC/mi) (pcUml)

2.70E-16<1.00E-16<1.00E-169.58E-151.40E-09

3.34E-16<1.00E-16<1.OOE-161.61E-141.30E-09

6.93E-16<1.00E-16<1.00E-161.42E-142.30E-09

1.08E-16<1.OOE-16<1.OOE-161.37E-147.00E-10

1.53E-16<1.00E-16<1.00E-161.30E-148.50E-09

NMAN/AN/A

1.06E-15NMA

N/AN/AN/A

7.23E-16N/A

N/AN/AN/A

1.11E-15N/A

N/AN/AN/A

7.89E-16N/A

N/AN/AN/A

1.06E-15N/A

1.00E-16 9.00E-141.00E-16 3.00E-141.00E-16 9.00E-132.00E-15 6.00E-133.00E-10 1.00E-08

1.00E-16 9.00E-141.00E-16 3.00E-141.OOE-16 9.00E-132.00E-15 6.002-133.002-10 1.00E-08

1.00E-16 9.OOE-141.00E-16 3.00E-141.OOE-16 9.00E-132.00E-15 6.00E-133.00E-10 1.00E-08

1.00E-16 9.00E-141.00E-16 3.00E-141.00E-16 9.00E-132.00E-15 6.002-133.00E-10 1.00E-08

1.00E-16 9.00E-141.00E-16 3.00E-141,00E-16 9,00E-132.00E-15 6.00E-133.00E-10 1.002-08

1.00E-16 9.OOE-141.00E-16 3.00E-141.00E-16 9.00E-132.00E-15 6.00E-133.00E-10 1.00E-08

% EFF. CONC.LIMIT

0.4<1.0<1.02.2

14.0

0.3<1.0<1.01.6

14.0

0.4< 1.0< 1.02.7

13.0

0.8< 1.0<1.02.4

23.0

0.1<1.0< 1.02.37.0

DAVE'S WATER WELLAir StationBackgroundSite

3rdQuarter

4thQuarter

N/AN/AN/A

7.76E-16N/A

0.2<1.0c1.02.2

85.0

TABLE 3

DIRECT RADIATION (GAMMA) MEASUREMENT DATA - 2004ENVIRONMENTAL MONITORING SITES

3rd & 4th QUARTERS

SAMPLE LOCATION SAMPLE PERIOD EXPOSURE RATE(mR/qtr)

ERROR ESTIMATE(mR/qtr)

FENCE LINEAir StationRestricted AreaBoundary

VOLLMAN'S RANCHAir StationDownwindNearest Residence

DAVE'S WATER WELLAir StationBackgroundSite

3rd Quarter

4th Quarter

3rd Quarter

44 0.9

39 1.3

37 1.9

4th Quarter

3rd Quarter

32 1.1

37 1.5

4th Quarter 35 1.6

SAMPLELOCATION

SW.1Stock PondSection 3

T35N, R74W

SW-2Stock PondSection 2

T35N, R74W


T36N, R74W


T36N, R74W

SW.5Stock PondSection 21

T36N, R73W


T36N, R73W

SAMPLEDATE

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

RADIONUCLIDE

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

CONCENTRATIO(mgL)

0.0017

ND

0.0013

TABLE 4

WATER SAMPLING DATA -2004ENVIRONMENTAL MONITORING SITES

3rd & 4th QUARTERS

N CONCENTRATION ERRC(pCUL) (I

ND

DRYDRY

DRYDRY

DRYDRY

DRYDRY

DRYDRY

DRYDRY

DRYDRY

DRYDRY

DRYDRY

OR EST. +1-pCIUL)

CONCENTRATION(pCIml)

1.2E-09

8.8E-101.1 E-08

EFF. CONC.LIMIT

(PCI/mI)

3.0E-076.0E-08

3.02-076.0E-08

3.OE-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

3.OE-076.OE-08

3.0E-076.OE-08

3.0E-076.02-08

3.OE-076.0E-08

3.0E-076.02-08

% EFF. CONC.LIMIT

0.4

0.00.0

0.318.2

ND

10.9 1.30E+00

TABLE 4 (Continued)

CONCENTRATION(pCIIL)

SAMPLELOCATION


T36N, R73W


T36N, R72W


T36N, R72W


T36N, R72W

GW-IWindmillSection 1

T35N, R74W

GW-2Water WellSection 35

T36N, R74W

SAMPLEDATE

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

RADIONUCLIDE

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-22B

U-NatRa-22B

U-NatRa-22B

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

CONCENTRATION(mgtL)

ND

0.0017

0.0016

0.0047

0.0028

0.0283

0.025

0.025B

ERROR EST. +1-(PCIIL)

ND

1.7

ND

0.9

DRYDRY

DRYDRY

0.3

DRYDRY

NOT RUNNINGNOT RUNNING

3.9

0.8

ND

2.00E-01

3.00E-01

7.00E-01

4.00E-01

CONCENTRATION(pCLfml)

1.22-091.72-09

1.1E-09

3.2E-099.0E-10

1.8E-093.0E-10

1.9E-083.9E-09

1.7E-088.0E-10

1.7E-08

EFF. CONC.LIMIT

(pCUml)

3.OE-07B.OE-08

3.OE-076.0E-08

3.0E-076.OE-08

3.0E-076.0E-08

3.OE-076.OE-08

3.0E-076.04-08

3.0E-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

3.0E-076.0E-08

% EFF. CONC.LIMIT

0.00.0

0.42.8

0.40.0

1.11.5

0.60.5

6.46.5

5.61.3

5.80.0

SAMPLELOCATION

GW-3Windmill

Section 27T36N, R74W

GW-4Windmill


GW-5Windmill


GW-6Windmill


GW-7WaterWellSection 27

T36N, R73W

GW-8Windmill


SAMPLEDATE

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

3rd Quarter

4th Quarter

RADIONUCLIDE

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

CONCENTRATION(mgIL)

TABLE 4 (Continued)

CONCENTRATION(pCUL)


ERROR EST. +1-(pCllL)

0.01233.00E-01

0.073

0.882

0.0413

0.0283

0.029


0.9


1.6

0.8


0.6

ND



3.OOE-01

5.OOE-01

4.OOE2-01

3.0OE-01

CONCENTRATION(iiCI~ml

8.3E-091.OE-09

4.9E-089.OE2-10

6.OE-071.6E-09

2.8E-088.OE-10

1 .9E-08

8.OE-10

2.OE-08

EFF. CONC.LIMIT

(PCI/mI)

3.OE-078.OE2-08

3.OE-076,OE-08

3.OE-076.DE-08

3.01E-078.OE-08

3.OE-076.01E-08

3.OE-076.OE-08

3.OE-076.OE-08

3.0O2-076.OE-08

3.OE-076.OE-08

3.OE2-076.0E-08

3.OE-076.OE-08

3,OE-076.01E-08

% EFF. CONC.LIMIT

2.81.7

0.0

16.51.5

199.02.7

9.31.3

6.41.0

6.50.0

SAMPLE SAMPLELOCATION DATE

GW.9 3rd QuarterWindmill

Section 14T36N, R73W 4th Quarter

GW-10 3rd QuarterWater WellSection 14

T36N, R73W 4th Quarter

GW-11 3rd QuarterWater WellSection 11

T36N, R73W 4th Quarter

GW-12 3rd QuarterWater Well

Section 7T36N, R72W 4th Quarter

RADIONUCLIDE

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

U-NatRa-226

CONCENTRATION(mgIL)

ND

TABLE 4 (Continued)

CONCENTRATION ERROR EST. +N-

(pC[/L) (pCIL)





CONCENTRATION(pCIlml)

3.OE-10

6.OE-10

6.OE-10

EFF. CONC. % EFF. CONC.LIMIT LIMIT

(pCI/ml)

3.OE-076.OE-08

3.OE-076.OE-08

3.0E-076.OE-08

3.OE-076.0E-08

ND

ND

0.3

0.6

0.6


3.O0E-01

2.OOE-01

3,OOE-01

3.OE-076.01E-08

3.01E-07B.OE-08

3.OE-076.OE-08

3.OE-076.OE-08

0.00.5

0.01.0

0.01.0

TABLE 5SATELLITE No. 1

LAND APPLICATION FACILITY (IRRIGATOR 1)ANNUAL SOIL DATA

CONOUCTtMT pHSAMPLE SAT. PASTE SAT. PASTE

DATE mimho stem mId. Unhts

SAR CALCIUM MAGNESIUM POTASSIUM SODIUM Sat% BARIUM BORON URANIUM . NATURAL ARSENIC SELENIUM RADIUM 226 TOTAL ERRORSOLUBLE SOLUBLE

nqtL menSOLUBLE SOLUBLE ABOTPA ABOTPA TOTAL ABOTPA ABDTPAmgAg-dry meq/L mg/kq-ft mog-ht uClig-y rn"vgA9dry mgharkdy uCl/g-

ESTIMATE!SAMPLE IO

Irrigator 91 S.E. Location 1 04'Irejefor#1 S.E. Location 1612?Irrigator t1 S.E. LocatIon 2 04Irrigatort1 S.E. Locatlon2 6-1?tIrgatorS# S.E. Location 3 04-Irntgatortt S.E. Location 3 6-irIntator 91 S.W. Location 4 04'Irrigator l SW. Location 4 8-1rIrrigator 41 S.W. Location 5 O.Irrigator 41 SW. Location s 6.1rIrrigator Si S.W. LocatIon a 0-4Inigatort1 SW. Location 6 61?rItntgor *1 S.W. Location ? 04-Inigatort1 S.W. Location 76-1rIrrtgator l N.W. Location a 0.6IrrIgator 1 N.W. LocatIon S 6-irIrrigator A1 N.W. Location 9 04-Itigator1 N.W. Location 96-1rIrrigator t1 N.W. Location 10 o-WIrrigator S1 N.W. Location 10 6-1rInigator S1 N.E. Location 11 0-Irrigator S1 N.E. Location 116 -1rIrrigador #1 N.E Location 12 04'Irrigator t 1 N E. Location 12 6.1rIrrigator t1 N E. Location 13 0WInigator 1 NE. Location 136.1rIrrigatof 91 N E Location 14 D0Irrigator A1 N.E. Location 146 1rIigator 91 Background a0.nigator Background 8.12

B/5t04Bt5/04Bl5/048/5/04Y/5104BtS1048/5/048/5/048/5/048/5/048/51048/5048/5/048/804t1/5104V5t0485/04tVY5/048/5/048B5/048/5tO4815/048t/5048/5t0485/048/5/0485t048/51048151048i5/04

1.571.371.040.921.121.812.873.081.381.541.381.871.913.051.7

1.731.7

2.021.051.864

5.995.64

71.171.851.482.270.350.31

6.336.285.768.356.837.336,977.216.636.768.987,286.196.686.016.586.827.145.996.586,477.176.77.058.068296.336.497.227.79

3.122.812.272.842.712.843.243.382.442.322.642.653.393.26

32.943.072.832.562.922.923.453.55

42.922.952.542.510.61.58

65.13.83

4.47.91314

5S8.45.98i96.914

6.26.27.49.2368.62435344147

5.58.72.11.2

3.22.72.11.82.34.37.58.33.14.12.94.23.78.13.74.53.94.82.45.312211s232.143

6.31.3

0.79

11.312.210.28.8s13.58.5819.210.313

7.8810.56.1621.922

17.112.417

11.713.313.832.813433.218.716.312.49.699.762.071.15

8.6 45.4 0.45.5 74.7 0.33.9 86 0.54 75.4 1.1

4.9 82.8 1.27 77.2 2.310 78 0.711 82.8 15.1 75.1 085.3 82.5 1.45.5 77.8 1.96.8 83.5 2.77.8 64.9 0.911 82.9 16.7 69.6 0.76.8 87.7 17.3 75.8 1.17.5 77.9 2.24.5 60.1 0.77.1 76 0.612 85.7 '0.21s 78.5 0.818 79. 0.422 80 4 0.64.8 66.5 1.28.9 72.5 1.15.2 60.6 096 9 83.6 1.20.78 64.7 2.81 6 588 2.5

'0.2'0.2'0.2'0.2'0.2'0.2'0.2

<1

'0.2'0.2'02'0.2'0.2'0.2'0.2'0.2'0.2

'0.2

'0.2

'0.2

'0.2

'0.2

'0.2

'0.2

'0.2

'02

'0.2

'0.2

'0.2

'0.2

2 OOE.051.00E066.00s-061.00E-069.OOE-061.00E-063.00E-061.00E-061.00E-051.0062-069ooE-0O300E-0e3.004-061.00E-062.00E-081.00E-067.00E-06ZOOE-0S1.00E-052.00E-065.00sE-9.00E-073.00E-061.00-063 OOE-s200E-0S1.OOE-051.00E-067.00E-077.00E-07

0.008

0 0030 0080.0050.0120.01

0.0260.020.0130.01

0.0220 0190 0290.0170.0090.0090.0250.0250.0270.010 0320.0290.0270.0240.010.0100150 0080 0090.008

0699 1.00E-050 616 1.00E-060.513 1.00E-060.23 1.00E-0e

0.538 2.00E-060.243 2.00E-060.397 1.00E-OS0.239 2.00E-060.602 1.00E-060.267 1.00E-060.774 7.00E-070.479 1.00E-060.39 1.00E-080.33 1.0065-0

0.329 2.00-0160.301 2.00E-060.428 1.006-080.316 1.00E-060.2U4 9.00E-070.217 1.00E4-00.493 1.00E-40.21 1.00E6-

0.411 1.00E-060182 1.00E-060.948 1.00E-61.04 1.00E-061.17 1.00E-060 28 1.00E-060.01 1.00E-060.004 1.006-06

1.00E-072.00E-071.00E-071.OOE-072.00E-072.00E-072.00E-072.00E-071.00E-072 OOE-071.008-071.00E-072.00E-071.00E-072.00E-072.00E-071.00E471.004-071.00E4071.00E-071.00E-071.00E-071.00E-071.00E-071.00E-071.00E-071,00E-07I OOE-071 OOE-071.00E-07

TABLE 6SATELLITE No. 2

LAND APPLICATION FACILITY (IRRIGATOR 2)ANNUAL SOIL DATA

CONDUCTMT pH SAR CALCIUM MAGNESIUM POTASSIUM SODIUM Sat % BARIUM BORON URANIUM- NATURAL ARSENIC SELENIUM RADIUM 226 TOTAL ERRORSAMPLE SAT. PASTE SAT. PASTE SOLUBLE SOLUBLE SOLUBLE SOLUBLE ABDTPA ABDTPA TOTAL ABOTPA ABOTPA ESTIMATE±

DATE mmhosfcm sId. Units moq/L meqfL mghg-dry meq/l. mgkg-dry mghg-dry uCV/g-dry mg/k-fy mg/rg- uCig-dr"SAMPLE ID

"Irator #2SW 114 Location 01 t W804Irrigator #2 SW 1t4 Location t1 6-12 8/904Irrigator #2 SW 114 Location #2n0- 8/9/04Irrigator 2 SW 114 Location #2 8-t1 W104Irrigator #2 SW 1/4 Location t3 04 8/904Irrigator #2 SW 1/4 Location #3 6-1t 8m94Irrigator 2 SW 1/4 Location U 8 /1904Irrigator #2 SW 1/4 LocatIon #46-ITr 819/04Irrigator #2 NW 1/4 Location #5 0-6 8/9/04Irrigator #2 NW 1/4 Location #5 6-1T 8/9/04Irtigator#2 Q W 1/4 Location #S08 8/9/04Irrigator #2 NW 114 Location #6-IT 8/9/04Irrigator n2 NW 1/4 LocatIon #0- 8/9/04irator #2 NW 1/4 LocatIon #7 6-It 804Irrigator n2 NW 1/4 Location 98 0-8 8/9M04Irrigtor #2 NW 1/4 Location #8 6-Ir 8/9/04Irrdgalor #2 NE 1/4 Location #9n -8 8/904"alor n2 NE 1/4 Location #9 6-t 89/04

trtigaor #2 NE 1/4 Location tt100 8/9/04rgtor #2 NE 1/4 Location t10 &-12' 819/04

Irrigator #2 NE 114 Location t11 0-4 8N9D04Irrigator t2 NE 1/4 Location #1 8-I r 819/04Irrigator #2 NE 1/4 Location #12 0- 819104Irrigator #2 NE 1/4 Location #12 6-1r 8/9/0Irrigator t2 SE 114 Location #13 0-D 819/04Irrigalor#2 SE 1/4 Location 013 1r 8/9/04Irrigator #2 SE 1/4 Location t14 0-6 /904Irrigator 2 SE 1/4 Location 914 6-i W9/04Irrigator #2 SE114 Location #150 8/9/04Irrigator 02 SE 1/4 Location t5 6-Ir 8/9/04Irrigator #2 SE 1/4 Location #160-6' 819/04Irrigator n2 SE 1/4 Location #1 6-Ir 8/9/04Irrigator #2 Background 0- 8/9104Irrigator 2 Baclground 6-1r 891/04

3.994.492.681.441.172.431.251.763.783.722.843.633.453.823.183.123.83.822.072.442.953.5

3.143.912.873.571.521.951.492.153.313.210.4

0.34

6 99 1.75 297.47 2,48 316.86 1.15 196.93 1.17 8.67.23 1.4 5.77.58 1.29 198.31 1.49 6.46.27 1.51 106.31 1.96 276.5 1.95 246.92 1.5 20

7.05 2.12 317.2 1.83 277.57 2.07 307.15 1.42 287.45 2.11 268.75 1.93 277.29 1.9 286.69 1.8 136.38 1.6 176.26 1.65 206.51 2.11 256.9 1.39 257.3 2.17 28868 1.75 208 61 1.97 2366 1 .73 86668 1.5 11

6.99 1.49 9.37.17 1.8 148.71 1.33 266.95 1.84 228.74 0.2 3.26.52 0.51 2.2

17149.64

3.77.83.75.916151111131313914137.8101215141712155.37.85

6.e16141.51.3

12.64.939.072.357.995.3

5643.229.184.838.653.112.25.934,782.574.953.452.9

8.127.32.6

6.533.415.1.99

6.922.751386.39

2065.514.462.24

8.4 68.6 '0.212 68.2 14 4 47 1.72.9 51.7 1.23 48.4 1.3

4.7 51.5 0.93.3 57.6 1.14.3 71.3 0.69.1 63.3 0.38.5 75.6 0.35.9 63 069.8 58.5 0.98.2 83.7 1.496 84.4 1.26.4 66 1.48.8 61.8 1.48.7 78.7 0.58.6 74.9 1.45.7 80.3 0.75.9 71.4 1.266 65.7 '0.29.4 74.7 '0.26.1 78.4 0.210 79.5 0 87 68 0.3

8.8 75 0.24.5 71.3 1.44.6 84.8 0.44 81.1 2.4

5.8 75.9 1.36.1 83.2 '0.27.8 73 '0.20.3 55 6 1.60 68 55 2.1

'0.2'0.2'0.2'0.2'0.2

0.2

0.2

0.2

'0.2

'0.2

'0.2

0.2<0.2'0.2

'0.2

'0.2

'0.2

'0.2

'0.2

'0.2'0.2

'0.2

0.2

0.2

'02

'0.2

'0.2

0.2

'0.2

'0.2

'0.2

'0.2

'0.2'0.2

9 OE-083.0E-062.9E-081.55-065.4E-054.0E-063.0E-061.SE-062.8E-061.4E-066.7E-61.4E-064.5E-062.4E4-5.sE-061.00E-31E-061.68E-0

.7E-062.9E-083.6E-061.1E-063.9E-061.3E-067.6E-061.5E-0624E-0614E-066 E-061.8E-064.1E-081.0OE-614-E461.50E-6

0.024 0.426 1.00E46 1.00E-070.029 0.576 2.002-06 1.000-070.012 0.103 1.0015-0 1 o0E-070.01 0 047 9.00E-07 100E-07

0042 0.151 1.00E-06 1.00E-070 045 0.09 1.00E-06 1.004-070 013 0.103 11.0000E 1.00E-070 012 0.148 1.00t-06 1.00E-070.013 0.273 1.000-06 1.00E-070011 o0.50 1.000-06 1.00E-070024 0.178 1.00E-06 1.000-070.02 0.136 1.00E-06 100E-07

0.034 0.256 1.00E-06 1.00E-070.037 0.304 1.00E-06 1.00E-070.021 0.125 1.00E46 1.00E-070.018 0.111 1.00E-06 1.00E-070.019 0.258 1.00E-06 1.00E-070.017 0.399 1.00E-06 1.00E-070.012 0.161 1.00E-06 1.0OE-070.017 0.137 1.00E-06 1.00E-070.016 0.133 1.00E-06 1.00E-070.009 0.267 1.00E-06 1.00E-070.025 0.3 1.00E-08 1.00E-070 02 0.298 1.000-06 1.004-07

o 031 0.269 1.0000E 1.00E-070.013 0.377 2.00E-06 1.00E-070.013 0.137 1.00E-06 1.OOE-070.009 0.19 1.000-6 1.00E-070.031 0.183 1.00E-06 1.00E-070 015 0.169 1.00E-06 10OE-070 041 0.261 1.00E-6 1000-070018 0.296 1.00E-06 100E-070 025 0.032 1.00E-06 1.00E-070.014 0.023 t1.00E-O 1 00i-07

TABLE 7A

SATELLITE NO. I LAND APPLICATION FACILITYANNUAL VEGETATON DATA

2004

SAMPLE SITESAMPLE DATE

TRACE METALS (mglkg): LLDSW3050 Dry Ash Extracted

Quarter 1 (NW) Quarter 2 (NE) Quarter 3 (SE) Quarter4 (5W) Background06-Aug.04 0O-Aug-04 06-Aug-04 06-Aug-04 06-Aug-04

AsBaBSe

0.050.05

50.05

RADIOMETRIC (pCi/kg):SW3050 Dry Ash Extracted

U-NatU-Nat LLD

Ra226Ra226 ERR. EST. *I-Ra228 LLD

<0.0548.89.1

21.4

2.60E-021 .00E-05

5.2E-052.8E-083.OE4061.10E-07

<0.0537.17.2

21.8

1.50E-021.00E-05

1.32E-044.95E-61 .40E-07

<0.0550.09.7

31.0

1.70E-021.OOE-05

1.03E-043.71 E-069.80E-08

'0.0539.47.5

22.9

1 .20E-021.00E-05

7.12E-054.30E-061 .90E-07

<0.0525.48.11.2

5.OOE-051.00E-05

2.41 E-053.1 8E-062.80E-07

TABLE 7B

SATELLITE NO. 2 LAND APPLICATION FACILITYANNUAL VEGETATION DATA

2004

SAMPLE SITESAMPLE DATE

TRACE METALS (mglkg): L.L.D.SW3050 Dry Ash Extracted

Quarter 1 (NW) Quarter 2 (NE) Quarter 3 (SE) Quarter 4 (SW) Background09-Aug404 09-Aug.04 09-Aug-04 09-Aug404 09-Aug.04

AsBaBSe

0.050.05

S0.05

RADIOMETRIC (pCfkg):SW3050 Dry Ash Extracted

U-NatU-Nat LLD

Ra226Ra226 ERR. EST. */-Ra226 LLD

<0.0518.013.117.6

3.70E-021 .OOE-05

2.1 3E-051 .93E-061.30E-07

'0.058.212.411.2

1.30E-021.00E-05

2.89E-052.09E-061.1 OE-07

<0.0514.515.617.2

2.90E-021.00E-05

2.84E-052.14E-061 .20E-07

'0.0512.315.412.1

2.10E-021 .OOE-05

4.10E-063.06E-061.70E-07

<0.05316.73.6

5.00E-041 .OOE-05

4.40E-064.19E-062.80E-07

TABLE 8

SATELLITE NO.1 LAND APPLICATION FACILITY (IRRIGATOR NO.1)MONTHLY IRRIGATION FLUID DATA

IRRIGATION CYCLE

VOLUME (AF)

MAJOR IONS (mglL)

Ca

Mg

Na

KHCO3

S04

Cl

REP. LIMIT

1.0

1.0

1.0

1.01.0

1.0

1.0

JuL04

12.58

150

49.1

116

15.2109

228

368

15.24

136

47.8

123

14.743

228

413

Aug-04 Sep-04 Oct-04 Nov-04 Dec-04

0.31

250

72.5

198

21.0

Irrigator Did Irrigator Did Irrigator DidNot Operate Not Operate Not Operate

397

659

NON-METALSTDS @ 1800 C (mg/L)pH (standard units)SAR

TRACE METALS (mgIL)AsBaBSe

10.0

0.010

0.01

0.001

0.10

0.10

0.001

1000

7.682.11

ND0.400.10

0.110

11508.092.30

0.0040.300.10

0.069

22008.092.83

0.0050.40ND

0.068

RADIOMETRIC

U-nat (uCimL)

Ra-226 (uCUmL)Ra Err. Est. +/-

2.03E-10 9.48E-082.OOE-10 1.20E-09

4.OOE-10

1.07E-07

1.20E-09

2.OOE-1 0

1.1OE-07

1.50E-09

4.OOE-10

TABLE 9

SATELLITE NO. 2 LAND APPLICATION FACILITY (IRRIGATOR NO. 2)MONTHLY IRRIGATION FLUID DATA

IRRIGATION CYCLE

VOLUME (AF)

Jul04 Aug-04 Sep-04 Oct-04 Nov-04 Dec-04

MAJOR IONS (mg/L)CaMgNaKHCO3

So4

CI

REP. LIMIT1.0

1.0

1.0

1.0

1.0

1.0

1.0

33.90

22596.689.924.7109667310

34.00

2179495

23.086

657292

2.70

21694.498.122.7

Irrigator Did Irrigator Did Irrigator DidNot Operate Not Operate Not Operate

696294

NON-METALSTDS @ 1800 C (mg/L)pH (standard units)SAR

TRACE METALS (mglL)AsBaBSe

10.00.0100.01

0.001

0.1

0.10

0.001

16707.941.26

0.006ND

0.200.290

16207.54NIA

NDND

0.100.193

17408.081.40

0.001

ND0.01

0.186

RADIOMETRICU-nat (uCimL)Ra-226 (uCVmL)Ra Err. Est. +1-

2.03E-10 3.39E-072.OOE-10 9.OOE-10

4.00E-10

3.76E-072.60E-096.OOE-1 0

4.03E-079.00E-104.OOE-1 0

TABLE 10A

MONTHLY RADIUM GRAB SAMPLESAT THE DISCHARGE FROM THE RADIUM TREATMENT SYSTEM

SATELLITE NO. 2

SAMPLE DATE

RADIOMETRICRa-226 (uCi/mL)Ra Err. Est.+l-

12-Jul-04 09-Aug-04 02-Sep-04 07-Oct-04 16-Nov-04 13-Dec-04

Rep. Limit2.OOE-10 9.OOE-10 7.40E-09 2.80E-09 2.20E-09 7.50E-09 1.50E-09

5.OOE-10 9.OOE-10 8.OOE-10 6.OOE-10 5.OOE-10 4.OOE-10

TABLE 10B

MONTHLY RADIUM GRAB SAMPLESAT THE DISCHARGE FROM THE RADIUM TREATMENT SYSTEM

SATELLITE NO. 3

SAMPLE DATE 12-Jul-04 09-Aug-04 02-Sep-04 07-Oct-04 16-Nov-04 13-Dec-04

RADIOMETRICRa-226 (uCi/mL)Ra Err. Est.+/-

Rep. Limit2.OOE-10 1.86E-08

1.50E-092.40E-08 7.97E-08 5.64E-08 2.OOE-09 3.OOE-091.50E-09 1.80E-09 2.50E-09 5.OOE-10 6.OOE-10

TABLE 11A

SATELLITE NO.1 LAND APPLICATION FACILITY (IRRIGATOR NO.1)ANNUAL SOIL WATER DATA

SAMPLE SITE 2' 4' 6'NW'1. NWh. NW11.NE% NE% NE%.SW'/. SW/. SW'/.SE%. SE% SE'.

Lysimeter Lysimeter LysimeterComposite Composite Composite

SAMPLE DATE

MAJOR IONS (mglL) REP. LIMITHCO, 1.0

S04 1.0 INSUFFICIANTcl 1.0 WATER FOR

SAMPLINGNON-METALSCond (umholcm) 1.0pH (standard units) 0.010

TRACE METALS (mg/L)B 0.10Se 0.001

RADIOMETRICU-nat: (mg/L) 0.0003Ra-226: (pCi/L) 0.2Ra Err. Est. +/-U-nat (uCVmL) 2.03E-10Ra-226: (uCI~mL) 2.OOE-10Ra Err. Est +I-

TABLE 11B

SATELLITE NO. 2 LAND APPLICATION FACILITY (IRRIGATOR NO.2)ANNUAL SOIL WATER DATA

SAMPLE SITE 2' 4 6'NW'/. NW'/. NW'!.NE%. NEl/. NE'!.SW'. SW'/. SW'.SE'h SE% SE%

Lysimeter Lysimeter LysimeterComposite Composite Composite

SAMPLE DATE

MAJOR IONS (mglL) REP. LIMITHCO, 1.0

S04 1.0 INSUFFICIANTcl 1.0 WATER FOR

SAMPLINGNON-METALSCond (umholcm) 1.0pH (standard units) 0.010

TRACE METALS (mgQL)B 0.10Se 0.001

RADIOMETRICU-nat (mglL) 0.0003Ra-226: (pCi/L) 0.2Ra Err. Est. +/-U-nat (uCVmL) 2.03E-10Ra-226: (uCimL) 2.00E-10Ra Err. Est +I-

TABLE 12

SATELLITE NO. 2 PURGE STORAGE RESERVOIRSHALLOW MONITORING WELLS

QUARTERLY WATER LEVEL DATASEMI-ANNUAL WATER QUALITY DATA

SAMPLE SITE Shallow WellNo. I (South)

Shallow WellNo. 2 (East)

28-Sep-04 4-Nov-04SAMPLE DATE 28-Sep-04 4-Nov-04

WATER LEVEL (DTW) Dry Dry 11.28 11.55

MAJOR IONS (mgIL)HCO3

S0 4

Cl

Rep. Limit1.0

1.01.0

Insufficient WaterFor Sampling 101

2470200

1122480208

45807.04

NON-METALSCond (pmho/cm)pH (standard units)

1.00.01

58706.31

TRACE METALS (mgIL)BaSe

RADIOMETRICU-nat (uCimL)Ra-226 (uCiUmL)Ra-226 Err. Est. +/- (uCi/mL)

0.0010.0025

ND0.092

ND0.086

5.35E-094.70E-098.OOE-10

6.77E-102.OOE-10

4.87E-097.70E-099.OOE-10

ATTACHMENT B

SAFETY AND ENVIRONMENTAL EVALUATIONSCOMPLETED IN 2004

Inter-Company MemorandumDate: April 23, 2004

To: R. Knode, W. F. Kearney, B. Soliz, M. Bryson, J. Hagar

From: Ken Milmine- Senior Environmental Scientist Aloha

Re: Safety and Environmental Review Panel (SERP) No. 2004-1: Start-up of I-Wellfield

cc: File SR 4.6.4.2

A. INTRODUCTION

In accordance with the NRC requirements, the Hydrologic Test Document, baseline waterquality data, and monitoring well Upper Control Limits (UCLs) must be reviewed by a Safetyand Environmental Review Panel (SERP) prior to Wellfield startup to ensure that the results ofthe hydrologic testing and the planned mining activities are consistent with technicalrequirements and do not conflict with any requirement stated in the NRC License. In addition toreview of the above information, the SERP conducts an Operations/Technical Review,Environmental/Radiation Safety/Industrial Safety review, and a Compliance review for a newWellfield prior to start-up.

A SERP was convened on April 21, 2004 to perform the reviews described above for the start-upof the 1-Wellfield at Highland. The I-Wellfield is currently under development and injection andproduction operations are nearly ready for start-up at Headerhouse I-1. Preoperationalhydrologic testing and baseline water quality data have been completed and submitted to theW)DEQ-LQD. The results of the SERP review are presented in the following sections.

B. SAFETY AND ENVIRONMENTAL REVIEW PANEL (SERP)

NRC License condition 9.4d of SUA-1548 requires that any changes, test or experiments madeunder the Performance Based License Condition be evaluated by a SERP consisting of at leastthree individuals. One member must have management expertise and have the financial andmanagement responsibility for approving changes. The second member must have operationaland/or construction expertise and have responsibility for implementing any operational changes.The third member must be the Radiation Safety Officer (RSO), or equivalent, with theresponsibility of assuring that the proposed activities will conform to radiation safety andenvironmental requirements. Individuals selected to perform this SERP review include:

R. Knode- General Manager OperationsM. Bryson- Wellfield Operations SuperintendentB. Soliz- Project GeologistW. F. Kearney- Manager- Health, Safety, and Environmental Affairs/CRSOK. Milmine- Senior Environmental Scientist

J. Hagar- Radiation Safety Officer

C. EVALUATION OF PROPOSED CHANGE/TEST

Hydrological Test Document Review

Review of the hydrologic test results determined that:

* The 30/40 Sand monitor well ring is in communication with the 30/40 Sand Sequenceproduction zone;

* Adequate confinement exists between the 30/40 Sand Sequence production zone and theoverlying and underlying sands;

* The 30/40 Sand has been adequately characterized with respect to hydrogeologicconditions within the I-Wellfield.

These results demonstrate that the testing objectives were met and mining can proceed inaccordance with NRC License SUA-1548.

The baseline water quality data is complete and the proposed UCLs were submitted to theWDEQ-LQD on November 17, 2003. The WDEQ-LQD has reviewed the proposed UCLs andprovided verbal approval.

Operations/Technical Review

Discussions during this review focused on modifications to the groundwater monitoring plan andvalve modifications to the headerhouse design. The groundwater monitoring plan was modifiedto accommodate the decision not to mine the northwest area of the wellfield. As a result, threeperimeter monitor wells (IM-1, IM-2, and IM-22A) will not need to be monitored and will beabandoned, as well as an overlying and underlying monitor well (IMO-6 and IMU-7respectively). An existing production well that was formerly part of the abandoned northwestwellfield area will be renamed Well IM-22 and utilized as a perimeter monitor well. In addition,an interim monitoring plan has been developed to parallel the progression of start-up atHeaderhouses I-1 through I-5. Well IMP-6 will be temporarily used as a perimeter monitor welluntil production is initiated in Headerhouse I-6, at which time the complete monitor well ring,overlying, and underlying monitor wells will be monitored. The UCLs have not been modifiedto accommodate these minor changes (See Table 1 and Figure 1 Attached).

Headerhouse design is essentially a replica of the headerhouses used in D-Wellfield. However, aMotor Activated Valve (MAV) will be installed on the injection trunk line in the headerhouses inthe I-Wellfield. This MAV will shutdown the headerhouse in sequential order during certainabnormal circumstances (loss of flow, loss of pressure, etc.). The MOV will be beneficial inreducing the amount of potential spilled injection fluid during an upset condition.

Environmental/Safety Review

The headerhouses will not require posting as a "Radiation Area" since there will be no filtersystem located inside. It was determined that there is no increased environmental or safety riskfrom start-up of the I-Wellfield and current wellfield start-up procedures are adequate (seeattached Risk Assessment).

Compliance Review

It was noted to the group that the Hydrologic Test Report was submitted to the WDEQ-LQD onOctober 16,2003 and approval was provided by the WDEQ-LQD in a letter dated November 12,2003. The baseline water quality data and the proposed UCLs were submitted to the WDEQ-LQD on November 17,2003. The revised monitoring plan was submitted to the WDEQ-LQDin correspondence dated April 20, 2004. On April 23, 2004, Mr. Steve Ingle of the WDEQ-LQDprovided PRI with verbal permission to start operations at Headerhouse I-1 and utilize therevised monitoring plan. Although Mr. Ingle's review of the information submittal to theWDEQ-LQD was complete, the written correspondence will be forthcoming.

The SERP evaluated the start-up of I-Wellfield against the conditions stated in the LicenseCondition 9.4 as shown in the table below. The SERP concluded that the start-up of I-Wellfieldsatisfied those conditions.

LICENSE REQUIREMENT YES NO N/A

Does the proposed change, test, and/or experiment conflict with the ALARA C 1principle?Does the proposed change, test, and/or experiment conflict with PRI's ability to 1meet all applicable regulations including NRC, WDEQ, and EPA?Is there degradation in the essential safety or environmental commitments in the Flicense application, or provided in the approved reclamation plan?Does the proposed change, test, and/or experiment conflict with any requirement j **-U

specifically stated in the source material license?Is the proposed change, test, and/or experiment not consistent with the conclusions arof actions analyzed in the facilities Environmental Assessment (EA) orsupplemental EAs?Result in any increase in the frequency of occurrence of an accident previously LI 1 0evaluated in the license application (as updated).Result in any increase in the likelihood of occurrence of a malfunction of a L Z LIstructure, system, or component (SSC) important to safety previously evaluated inthe license application (as updated).Result in any increase in the consequences of an accident previously evaluated in n 1 Ithe license application (as updated).Result in any increase in the consequences of a malfunction of an SSC previously flevaluated in the license application (as updated).Create a possibility for an accident of a different type than previously evaluated in O 1the application (as updated).Create a possibility for a malfunction of an SSC with a different result than O 3 Lpreviously evaluated in the license application (as updated).

Result in the departure from the method of evaluation described in the license ] M Oapplication (as updated) used in establishing the final safety evaluation report or theenvironmental assessment (EA) or technical evaluation reports (TERs) or otheranalysis and evaluations. SSC means any SSC which has been referenced in aNRC staff SER, TER, EA, or environmental impact statement (EIS) and allsupplements and amendments. I.I I

D. CONCLUSIONS

The SERP concluded that that the commencement of production at the I-Wellfield would notrequire a License Amendment and does not conflict with any other regulatory requirement.Also, the commencement of production at the I-Wellfield will not result in the degradation ofany essential safety or environmental commitments in the License Application, EnvironmentalAssessments, or current operating procedures. As a result, the SERP approved the start-up of theI-Wellfield.

Signature: Date: 6N/CR. Kiode, General Manager Operations

Signaturey'g•eta~n 2Q A. &)JAV". , 0 _ As _ X

M. Bryson, Wellfield Op~ritions SuperintendentDate: e: 3&q

Date: I? 6//

Signature: /&. _K. Milmine, Senior Environmental Scientist

Signature :: A '7. i l k ?-J. Hagar, Radiation Safety Officer

Date: 2/i3 t

Signature: Date: W1E3 1o0W. F. Keary, Manager alth, Safety, and Environmental Affairs/CRS

TABLE 1

Proposed Upper Control Limits (UCLs) for I-Wellfield Monitor Wells

Upper Control Limits (UCLs)Zone Chloride Bicarbonate Conductivity

Wells Monitored (as mg/L(nmg/L) CaO)(tirhosfcrn)

ProductionIM-3 to IM-22 Zone 17 257 928

Aquifer

IMO-2 to IMO-5 Overlying 18 346 821Aquifer

IMU-2 to IMU-3 Water Level Only

Underlying _____ _ _Aquifer .

IMU-4 to IMU-6 18 236 712

Form EHS-13-2

RISK SCREENING/ASSESSMENT

Section 1

Will the proposed change result in a potential increase ofradiological exposure to employees or the public?Will additional radiological monitoring be required as a result F 1of the proposed change?Will additional radiological controls or personal protective Elequipment be required as a result of the proposed change?Will the proposed change result in an increase intransportation of radioactive materials or require modification [1 O

of current transportation methods?Will the proposed change result in an increased potential for a E Elsignificant release or spill of radioactive material? .Has new equipment, facilities, or processes been proposedthat introduce potential additional hazards or require [ Xengineering controls to reduce hazards?Have new electrical systems been proposed that introducepotential additional hazards or require engineering controls to El Ereduce hazards?Will the proposed change result in an increased exposure to El Eelevated noise levels?Will new potentially hazardous chemicals and/or bulk a Echemical storage areas be introduced?Will the proposed change introduce potentially hazardousconfined space areas or introduce potential hazards to existing E Elconfined spaces?Will the proposed change result in abnormal hazards fromexcavation or construction not predicted in current El Eprocedures?Will the proposed change result in an increased fire hazard or Ewill existing fire protection systems be ineffective?Will the proposed change increase potential for a violation ofan environmental or radiological regulatory permit or E lstandard?Will the proposed change cause significant surface _ _

Page 1 of3

Form EHS-13-2

disturbance outside of the permit area?r I T

Will the proposed change result in a significant increase in .solid, hazardous, or radiological waste generation?Will the proposed change require approval from a regulatoryagency or coverage under a permit?Will special training need to be incorporated beyond the scopeof current training programs?Will additional Standard Operating Procedures or EmergencyResponse Procedures need to be developed prior to change IIIimplementation?Will the proposed change introduce potential legal issues orobligations?Will the proposed change result in nonconformance with Destablished company policies? EWill the proposed change result in damage to the credibility,public perception, reputation, or public good standing ofPower Resources, Crow Butte Resources, or Cameco as areputable company?Are there any other risk scenarios not included in the above O Elquestions that could result from the proposed change?

Section 3

If yes was answered to any questions above, indicate the controls or mitigativeactions to be used to minimize the associated risk:

Page 2 of 3

Form EHS-13-2

Section 4

Section 5Risk Assesment Team Approvals

A. .M 9 4__

Men RI/z YAW 411.

(10,O 6-tc~/ATO / 431

I ,

Page 3 of 3

Inter-Company MemorandumDate: July 22, 2004

To: R. Knode, W. F. Kearney, J. Tremel, M. Bryson, J. Hagar, R. Janssen, K. Lehner

From: Ken Milmine- Senior Environmental Scientist

Safety and Environmental Review Panel (SERP) No. 2004-2: Changes to SmithRe: Ranch General Well Sampling Methods, Highland Reporting Parameters, and New

Access Database Implementation

cc: File SR 4.6.4.2

A. INTRODUCTION

License condition 9.4A of SUA-1548 allows Power Resources, Inc. (PRI) to make the followingchanges through the Safety and Environmental Review Panel (SERP) process at the SmithRanch-Highland Uranium Project (SR-HUP) without obtaining a License Amendment:

1. Changes in the facility as described in the license application (as updated),

2. Changes in the procedures as described in the license application (as updated), and

3. Conduct test or experiments not described in the license application (as updated).

The licensee must obtain a License Amendment if the change test or experiment meets any of theconditions listed in condition 9.4b and 9.4c of SUA-1548. If the SERP concludes the change,test, or experiment does not meet any of the criteria listed in conditions 9.4b and 9.4c, the workmay proceed with the appropriate documentation. If the SERP concludes that the change, test orexperiment does otherwise meet any of the criteria in conditions 9.4b and 9.4c, then a LicenseAmendment must be obtained prior to implementing the proposed change.

Changes have been proposed in relation general monitor well sampling methods for Smith Ranchwells, a reporting parameter change for Highland (bicarbonate to alkalinity), and implementationof a new combined database. General well sampling and analysis methods are described inSection 5.2, (Operational Hydrologic Monitoring Program) of the License Application.Therefore, these changes are required to be reviewed and approved by a SERP.

A SERP was convened on July 13, 2004 to perform the reviews for changes in general monitorwell sampling methods at Smith Ranch; the change from reporting the Upper Control Limits(UCLs) parameter bicarbonate to alkalinity for Highland monitor wells; and implementation ofthe new combined monitor well database. The change in sampling methods at Smith Ranchincluded taking water level measurements for a cluster of wells and sampling that cluster on thesame day as opposed to the current method of taking water level measurements for the entirewellfield which resulted in taking the water sample several days later. These changes willprovide consistency between the Smith Ranch and Highland sampling and reporting methods and

1

also conform to the new combined monitor well database structure. The results of the SERPreview are presented in the following sections. The SERP Review included evaluation of theproposed changes against the criteria listed in condition 9.4b and 9.4c, and also included anoperations/technical review, environmental/safety review, and compliance review.


NRC License condition 9.4d of SUA-1548 requires that any changes, test or experiments madeunder the Performance Based License Condition be evaluated by a SERP consisting of at leastthree individuals. One member must have management expertise and have the financial andmanagement responsibility for approving changes. The second member must have operationaland/or construction expertise and have responsibility for implementing any operational changes.The third member must be the Radiation Safety Officer (RSO), or equivalent, with theresponsibility of assuring that the proposed activities will conform to radiation safety and-environmental requirements. Individuals selected to perform this SERP review include:

R. Knode- General Manager OperationsM. Bryson- Wellfield Operations SuperintendentJ. Tremel- Environmental SpecialistWV. F. Kearney- Manager- Health, Safety, and Environmental Affairs/CRSOK. Milmine- Senior Environmental ScientistJ. Hagar- Radiation Safety OfficerR. Janssen- Wellfield Services SupervisorK. Lehner- Lead Lab Technician


Operations/Technical Review

Discussions during the operations/technical review yielded the following conclusions:

* Water levels will be taken for a cluster of wells and then sampled on the same day.

* Well sampling is scheduled according to the proximity of the wells in relation to oneanother. It was not recommended to reschedule sampling in an effort to normalize thesampling schedule (such as set sampling schedule for each wellfield).

* It was determined that sampling under the new methods will begin on Thursday July 15,2004, since that is the beginning of the second round of sampling for the month.

* K. Lehner noted that the analytical method is the same for alkalinity and bicarbonate.One can be reported as the other by simply multiplying or dividing by a factor of 1.22.

* The monitor well database has been combined. The database is capable of downloadingtext files produced from the Metrohli and Radiometer automatic analyzers. The newcombined Access Monitor Well Database will contain all data for Smith Ranch and

2

Highland monitor wells and is capable of checking data against exceedance values andUCLs. The new database contains all historical data for Smith Ranch and Highlandmonitor xvells. Current and historical bicarbonate data for Highland wells have beenconverted to alkalinity, along with corresponding UCL and exceedance values. Access tothe database will be limited to EHS personnel only to reduce potential for errors. TheEHS Department will develop an operations manual for the program and database.

As a result of the change in sampling methods, a consistent number of samples will bedelivered to the lab daily instead of the lab receiving a large number of samples at oncewith periods of no samples in between. This will make for a more efficient operation ofthe lab.

Environmental/Safetv Review

It was determined that environmental or safety risk is not impacted as a result of the proposedchanges (see attached Risk Assessment). Also, current sampling procedures, as defined in theLicense Application and Operating Procedures, are adequate and do not require revision.

Compliance Review

W. F. Kearney reported that these changes have been previously discussed with the WDEQ onseveral occasions. The reporting changes will be noted inn the Quarterly Report for the SecondQuarter of 2004.

The SERP evaluated the proposed changes in well sampling, reporting parameter change, andnew Access database implementation against the conditions stated in the License Condition 9.4bas shown in the table below. The SERP concluded that these changes satisfied those conditions.


Does the proposed change, test, and/or experiment conflict with the ALARA 1 1principle?Does the proposed change, test, and/or experiment conflict with PRI's ability to H [meet all applicable regulations including NRC, WDEQ, and EPA?Is there degradation in the essential safety or environmental commitments in the F 3 Jlicense application, or provided in the approved reclamation plan?Does the proposed change, test, and/or experiment conflict with any requirement F]lspecifically stated in the source material license?Is the proposed change, test, and/or experiment not consistent with the conclusions F ]of actions analyzed in the facilities Environmental Assessment (EA) orsupplemental EAs?Result in any increase in the frequency of occurrence of an accident previously F ]evaluated in the license application (as updated).Result in any increase in the likelihood of occurrence of a malfunction of a fl ustructure, system, or component (SSC) important to safety previously evaluated inthe license application (as updated).Result in any increase in the consequences of an accident previously evaluated in H F]the license application (as updated).Result in any increase in the consequences of a malfunction of an SSC previously 0 E]levaluated in the license application (as updated).

3

I evaluated in the license application (as updated).Create a possibility for an accident of a different type than previously evaluated in F 1the application (as updated).Create a possibility for a malfunction of an SSC with a different result than F 1previously evaluated in the license application (as updated).Result in the departure from the method of evaluation described in the license H 2 Fapplication (as updated) used in establishing the final safety evaluation report or theenvironmental assessment (EA) or technical evaluation reports (TERs) or otheranalysis and evaluations. SSC means any SSC which has been referenced in aNRC staff SER, TER, EA, or environmental impact statement (EIS) and allsupplements and amendments.

D. CONCLUSIONS

The SERP concluded that the reviewed changes to the well sampling methods, Highlandreporting parameters (bicarbonate to Alkalinity), and implementation of the new Access MonitorWell Database would not require a License Amendment and does not conflict with any otherregulatory requirement. Also, these changes will not result in the degradation of any essentialsafety or environmental commitments in the License Application, Environmental Assessments,or current operating procedures. As a result, the SERP approved the implementation of theproposed changes to the Smith Ranch well sampling methods, the reporting parameter changefrom bicarbonate to alkalinity for Highland monitor wells, and the implementation of the newAccess Monitor Well Database.

* 4,I-5'<- '7' - -Signature:R. Knode, General Manager Operations

Signature: xoi2o~ ly (0 /Jj)Lt-1M. Bryson, Wellfield Ofif tions Superintendent

Date: 7/26 lb4

Date: n 6/C' Y'

Date

Date:27'•

Signature: L /. rue'e/JTremel, Environmental Specialist

1ISignatur rl: A JI- --K. Milmine, Senior Environmental Scientist

Date: j2/J /*¢Signature:

Signature:_

J. Hagar, Radiation Safety Officer

W. F.

.4

Signature:K. Lehner, Lead Laboratory Technician

Date:

Signature:R. Janssen, Wellfield Services Supervisor

Date:

5

Form EHS-13-2

RISK SCREENING/ASSESSMENT

Section 1Title of Proposed Change: Byi S 5 qi31o

Assessment Team: L/,e If- k~r- LeAt ar (,Srt/j~v5eb-'f OIi,/LSr)"~4 JT'e. 'I,, .. I { I .'- ,

Section 2 J..keng

.Will the proposed change result in a potential increase of Elradiological exposure to employees or the public?Will additional radiological monitoring be required as a resultof the proposed change? _n__

Will additional radiological controls or personal protective C 717'equipment be required as a result of the proposed change?Will the proposed change result in an increase intransportation of radioactive materials or require modification O /of current transportation methods?Will the proposed change result in an increased potential for a Elsignificant release or spill of radioactive material?Has new equipment, facilities, or processes been proposedthat introduce potential additional hazards or require E' ElDengineering controls to reduce hazards?Have new electrical systems been proposed that introducepotential additional hazards or require engineering controls to O Elreduce hazards?Will the proposed change result in an increased exposure to O _elevated noise levels?Will new potentially hazardous chemicals and/or bulk Elchemical storage areas be introduced? ___

Will the proposed change introduce potentially hazardousconfined space areas or introduce potential hazards to existing F12 Econfined spaces?Will the proposed change result in abnormal hazards fromexcavation or construction not predicted in current nprocedures?-Will the proposed change result in an increased fire hazard or n EY Owill existing fire protection systems be ineffective?Will the proposed change increase potential for a violation ofan environmental or radiological regulatory permit or E [standard?Will the proposed change cause significant surface a E [_

- - . -j

Page 1 of 3

Form EHS-13-2

disturbance outside of the permit area?Will the proposed change result in a significant increase in A/ 1solid, hazardous, or radiological waste generation? O LWill the proposed change require approval from a regulatory Etagency or coverage under a permit?Will special training need to be incorporated beyond the scope . IVof current training programs?Will additional Standard Operating Procedures or EmergencyResponse Procedures need to be developed prior to change L LIimplementation? _

Will the proposed change introduce potential legal issues or _ nobligations?Will the proposed change result in nonconformance withestablished company policies?Will the proposed change result in damage to the credibility,public perception, reputation, or public good standing of r-YPower Resources, Crow Butte Resources, or Cameco as areputable company?

Are there any other risk scenarios not included in the above El Iquestions that could result from the proposed change? IM

Section 3

If yes was answered to any questions above, indicate the controls or mitigativeactions to be used to minimize the associated risk:

Page 2 of 3

Form EHS-13-2

Section 4Is the risk(s) identified acceptable as a result of the Yes Nocontrols and mitigative actions described above. O LIIf "No", describe additional controls or mitigative actions required to bring therisk(s) back to acceptable levels:

Section 5Risk Assesment Team Approvals

W<- ehic __ ____ ______

, kLe,4 ner L 7/ZI3/

Rv5feCl JAvO- 2 -13 -oL/

.I . /CV 7X

.zS' c7//7

Page 3 of 3


To: R. Knode, K Milmine,

From. W. F. Kearney- Manager Health Safety and Environmental Affairs

Re: Safety and Environmental Review Panel (SERP) No. 2004-3: Revised UCL's forWell M-212

cc: File SR 4.6.4.2

A. INTRODUCTION

On July 15, 2004, during the compilation of the WDEQ-LQD Quarterly Report, Ken Milmine,Environmental Scientist, determined that on two instances during the 2"d Quarter 2004, theroutine monitoring well data reflected that the Excursion criteria had been slightly exceeded atPerimeter Monitor Well M-212 located at Mine Unit 2 at the Smith Ranch Project. Theexceedance was not brought to the attention of or identified by, the EHS Department, nor was itreported to the NRC or WDEQ in the required time frames. Also, an Excursion "confirmation"sample was not obtained in accordance with License Condition 11.5 or Section 5.2.4 of theLicense Application. Therefore, License Condition 9.3 of NRC License No. 1548, whichrequires that operations be conducted in accordance with the License Application, and LicenseCondition 11.5, were violated. The attached Self Identified Violation, dated July 21, 2004 morefully describes the conditions.

Although this incident was unfortunate in that the program and procedures in place used toidentity monitoring well ground water quality data that approach, or exceed Excursion criteriadid not function properly, an Excursion of mining fluids did not actually occur. Theinvestigation in to the incident determined that the slight exceedance of the Alkalinity UpperControl Limits (UCL's) at Well M-212 by 2 mgfL (see attached Monitor Well Report) on April15 and June 15, 2004 and the exceedance ofthe Conductivity UCL by various amounts duringthe period was a result of two factors which were somewhat related. First, a review of thebaseline data and the UCL's for this well show that it has anomalously different water quality(lower conductivity and hence dissolved solids) than all the other Mine Unit 2 Perimeter MonitorWells. Secondly, for this reason, it had its own set of alkalinity and conductivity UCL's thatwere considerably less than those for the other wells.

The alkalinity UCL is currently 170 mgfL compared to 231 mg/L for the rest of the wells. Theconductivity UCL is currently 566 umhos/cm compared to 1 136 unhos/cm for the rest of thewells. When the baseline data was assessed and the UCL's determined in late 2002, it was notpossible to determine why the conductivity at Well M-212 was different and hence it's own setof UCL's were determined. A review of the conductivity data for the well shows that it haschanged (increased) such that it now reflects characteristics similar to the rest of the wells. Noexact explanation for the slow change is apparent as the well was Mechanical Integrity Tested

(MIT) and viewed with a down hole camera on July 19, 2004 to investigate it for any casingdamage or inaccurate completion. No problems of this nature were observed. Therefore, it isconcluded that the water quality at this well is changing to that more closely associated with theother wells monitoring the same zone. Additionally, water samples obtained on July 15, 2004showed no uranium in the water. Given these conditions, and consistent with discussions withthe NRC and WDEQ, it is apparent that the well has not been impacted by mining fluids and anExcursion did not occur.

Consistent with discussions with the NRC and WDEQ, the observed change in ground waterquality at the Well M-212 is such that the UCL's should be revised to be consistent with thoseused for the all the Wellfield 2 Perimeter Monitoring Wells (Chloride= 17 mg/L, Alkalinity= 231mg/L, Conductivity= 1136 urnhos/cm). Therefore, a SERP was convened on July 30, 2004 toevaluate the revision of the UCL's for Well M-212. The results of the SERP review arepresented in the following sections.



R Knode- General Manager OperationsW. F. Kearney- Manager- Health, Safety, and Environmental Affairs/CRSOK. Milmine- Senior Environmental Scientist


It is proposed to change the UCL's for Well M-212 to be consistent with the UCL's for theWellfield 2 Perimeter Monitoring Wells to the following:

Chloride= 17 mgALAlkalinity 231 mg/LConductivity- 1136 umhos/cm

The proposed change should be acceptable as the ground water quality at Well M-212 haschanged such that it is now within the range of water quality characteristics of all the other 23Wellfield 2 Perimeter Monitoring Wells and the observed change in ground water quality doesnot appear to be directly related to the injection of recovery fluids. PRI's intent to change theseUCL's was discussed with representatives of the NRC and WDEQ on July 16, 2003 during

discussions of the Self Identified Violation. Both representatives agreed that the proposed changewas reasonable..

The SERP evaluated the proposed change of the UCL's at Well M-212 against the conditionsstated in the License Condition 9.4 as shown in the table below. The SERP concluded that thechange satisfied these conditions.


Does the proposed change, test, and/or experiment conflict with the ALARA O tprinciple?Does the proposed change, test, and/or experiment conflict with PRI's ability to a imeet all applicable regulations including NRC, WDEQ, and EPA?Is there degradation in the essential safety or environmental commitments in the rlicense application, or provided in the approved reclamation plan?Does the proposed change, test, and/or experiment conflict with any requirement fl2 Ospecifically stated in the source material license?Is the proposed change, test, and/or experiment not consistent with the conclusions O *of actions analyzed in the facilities Environmental Assessment (EA) orsupplemental EAs?Result in any increase in the frequency of occurrence of an accident previously EJevaluated in the license application (as updated).Result in any increase in the likelihood of occurrence of a malfunction of a 0structure, system, or component (SSC) important to safety previously evaluated inthe license application (as updated).Result in any increase in the consequences of an accident previously evaluated in H 1-the license application (as updated).Result in any increase in the consequences of a malfunction of an SSC previously irevaluated in the license application (as updated).Create a possibility for an accident of a different type than previously evaluated in -Fl othe application (as updated).Create a possibility for a malfunction of an SSC with a different result than 0previously evaluated in the license application (as updated).Result in the departure from the method of evaluation described in the license 0application (as updated) used in establishing the final safety evaluation report or theenvironmental assessment (EA) or technical evaluation reports (TERs) or otheranalysis and evaluations. SSC means any SSC which has been referenced in aNRC staff SER, TER, EA, or environmental impact statement (EIS) and allsupplements and amendments.

D. CONCLUSIONS

The SERP concluded that that the change of the UCL's for Well M-212 would not require aLicense Amendment and does not conflict with any other regulatory requirement. Also, thechange will not result in the degradation of any essential safety or environmental commitmentsin the License Application, Environmental Assessments, or current operating procedures. As aresult, the SERP approved the change of the UCL's for Well M-212.

Signature: Date: 7/3o104-R Knode, General Manager Operations

Signature: 44 / hJ p Date : Q a2K. Milnine, Senior Environmental Scientist

Signature: Date:W. F. Ke!Pey, Mangr caith, Safety, and Environmental Affa C


To: File 4.6.4.2

From: W. F. Kearney- Manager- Health, Safety, and Environmental Affairs

Re: SelfIdentified Violation- Failure to Report a Potential Wellfield Excursion

cc: S. P. Collings, R. Knode, K. Milinine, J. Tremel

On July 15, 2004, during the compilation of the WDEQ-LQD Quarterly Report, Ken Milmine,Environmental Scientist, determined that on two instances during the quarter, the routinemonitoring well data reflected that the Excursion criteria had been slightly exceeded at PerimeterMonitor Well M-212 located at Mine Unit 2 at the Smith Ranch Project. The exceedance was notbrought to the attention of, or identified by, the EHS Department, nor was it reported to the NRCor WDEQ in the required time frames. Also, an Excursion "confirmation" sample was notobtained in accordance with License Condition 11.5 or Section 5.2.4 of the License Application.Therefore, License Condition 9.3 of NRC License No. 1548, which requires that operations beconducted in accordance with the License Application, and License Condition 11.5, wereviolated.

Although, this incident was unfortunate in that the program and procedures in place used toidentify monitoring well ground water quality data that approach, or exceed Excursion criteriadid not function properly, an Excursion of mining fluids did not actually occur. This incident,which is more fully discussed below, was conveyed via telephone to the NRC (John Lusher) andthe WDEQ-LQD (Steve Ingle) on July 16, 2004.

The investigation in to the incident determined that-the slight exceedance of the Alkalinity UpperContrpl Limits (UCL's) at Well M-212 by 2 mg/L (see attached Monitor Well Report) on April15 and June 15, 2004 and the exceedance of the Conductivity UCL by various amounts duringthe period was a result of two factors which were somewhat related. First, a review of thebaseline data and the UCL's for this well show that it has anomalously different water quality(lower conductivity and hence dissolved solids) than all the other Mine Unit 2 Perimeter MonitorWells. Secondly, for this reason, it had its own set of alkalinity and conductivity UCL's thatwere considerably less than those for the other wells.

The alkalinity UCL is currently 170 mg/L. compared to 231 mg/L for the rest of the wells. Theconductivity UCL is currently 566 umhos/cm compared to 1136 umhos/cm for the rest of thewells. When the baseline data was assessed and the UCL's determined in late 2002, it was notpossible to determine why the conductivity at Well M-212 was different and hence it's own setof UCL's were determined. A review of the conductivity data for the well shows that it haschanged (increased) such that it now reflects characteristics similar to the rest of the wells. Noexact explanation for the slow change is apparent as the well was Mechanical Integrity Tested

(MIT) and viewed with a down hole camera on July 19, 2004 to investigate it for any casingdamage or inaccurate completion. No problems of this nature were observed. Therefore, it isconcluded that the water quality at this well is changing to that more closely associated with theother wells monitoring the same zone. Additionally, water samples obtained on July 15, 2004showed no uranium in the water. Given these conditions, and consistent with discussions withtheNRC and WDEQ it is apparent that the well has not been impacted by mining fluids and anExcursion did not occur. Additionally, consistent with discussions with the NRC and WDEQ,the observed change in ground water quality at the Well M-2 12 is such that the UCL's should berevised to be consistent with those used for the al the Wellfield 2 Perimeter Monitoring Wells(Chloride= 17 mg/L, Alkalinity= 231 mg/L, Conductivity= 1 136 umhos/cm).

Also of concern was why the EHS Department or the CPP Lab did not identify the slightlyincreasing trend in alkalinity, the more pronounced increasing trend in conductivity, andsubsequent exceedance of excursion criteria (two of the three parameters exceed their UCL's) onApril 15 and June 15, 2004. This part of the investigation showed several contributing factors,which were actually resolved prior to the discovery of this incident because a new monitoringwell database program (Microsoft Access) recently went in to effect that would have preventedthis oversight. In fact, the utilization of the new monitoring well database program on theexisting 2004 data actually identified the oversight.

The failure to identify the change in ground water quality at Well M-212 resulted from the factthat until approximately July 6, 2004 the monitoring well data at the Smith Ranch Project wasassessed and stored in an older Access Program developed by the previous operator, while thedata for the Highland Uranium Project was handled with a Dbase Program. Unknown to theEHIS Department, due to personnel changes in mid 2002 resulting from the acquisition of SmithRanch by PRL the Access Program and supporting programs historically used by Smith Ranchwere never revised with any "exceedance or flag values" for Mine Unit 2 to identify and printouta suspect sample result Unfortunately, although the current days printout of the monitoring welldata for all Smith Ranch Mine Units (Nos. 1-4) was routinely reviewed to identify any concernswith the monitoring data, the program did not '"lg" any anomalous data for Mine Unit 2. Theprogram did fiuction properly for assessing the data for Mine Units 1,3, and 4.

A violation of this nature should not reoccur as the new Access Program that began operation inearly July 2004 replaces both the former programs used to assess and store the monitoring welldata. This new program has been tested to ensure that it is fully operational as designed.Additionally, in concert with the implementation of this new program, the EHS Department isthe sole entity assessing or entering data in to this database. This further decreases theopportunity for a quality control type problem. Therefore, full compliance with NRC LicenseNo.1548 was achieved on July 1,2004 when the new Access Program was implemented.

As discussed with the NRC and WDEQ, due to the observed change in the ground water qualityat Well M-212, the UCL's will be revised to be consistent with the other Perimeter MonitoringWells at Mine Unit 2. This change will be implemented for the NRC License using the SERPprocedure and the WDEQ-LQD will be informed of the change via the 2nd Quarter 2004Quarterly Report. Monitoring results at Well M-212 will continue to be evaluated in the future toensure that no unanticipated conditions develop.

Power Resources Inc.

Monitor WellReportWell ID: M212

... __.Chloride.. _ Alkalinity. .Conductivity

NRC/'WDEQ (mgfL) (mg/L CaCOj) (AwMhos/cm)UCL 18 170 566

07/15/2004 2.5 *159 639

07107/2004 2.3 144 650

06/1512004 2 172 704

06101/2004 2 168 690

05117/2004 3 167 683

05/03/2004 2 168 666

04/15/2004 2 172 650

04/01/2004 3 163 655

03/15/2004 3 169 635

03104/2004 3 166 622

02/18/2004 2 164 588

02/0212004 2 169 587

01/20/2004 2 163 567

01/02/2004 2 - 163 539

(mg/LWater Level

(ft MSL)

z 0.1 5195.28

5196,18

5194.5

5202.1

5198

5201.8

5204.9

5205.3

5205.3

5207.7

5209.5

5210

5210

5209.6

Thrdy_ uy2,20 ae1 f4

. 7hunday, July 22, 2004 - Page 12 of 48

Inter-Company MemorandumDate: August 27, 2004

To: R. Knode, K. Milmine, T. McCullough

From: W. F. Kearney- Manager-Health, Safety & Environmental Affairs/CRSO

Re: Safety and Environmental Review Panel (SERP) No. 2004-4 Changes to theRadiation Safety Protection Staffcc: File SR 4.6.4.2

A. INTRODUCTION

On August 12, 2004 the Radiation Safety Officer (RSO) at the Smith Ranch- Highland UraniumProject terminated employment at the facility. Therefore, W.F. Keamey, Manager- Health,Safety & Environmental Affiiirs/CRSO assumed the role of the Site RSO at that time. Thischange was conveyed to both NRC Region 4 and Headquarters personnel.

Based on past experience that showed the lack of available RSO qualified individuals withuranium recovery facility experience, PRI Management decided to promote from within theorganization to fill this requirement. It was determined, depending on the experience of theindividual chosen for the position, that the individual would be required to function as anRadiation Safety Technician (RST) until such time that they met NRC and PRI requirements forthe position of RSO. Therefore, the CRSO would need to function as the Site RSO until suchexperience and training is completed.

The SERP reviewed this change to the EHS Department and the Radiation Protection Program.The results of the SERP review are presented in the following sections.



R. Knode- General Manager OperationsW. F. Kearney- Manager- Health, Safety, and Environmental Affairs/CRSOK Milmine- Senior Environmental ScientistT. McCullough- Safety Supervisor


The SERP met on August 27, 2004 to review the planned change and assess the qualifications ofthe individual selected to be the RST. It was determined that the new RST (Arlene Crook) willundergo specialized training at the SR-HUP in-accordance with NRC Regulatory Guide 8.31.The training will be under the supervision of W. F. Kearney-CRSO. T. A. McCullough- SafetySupervisor, who was also previously a very well informed RST at the SR-HUP, will assist withthe training and will also assist with covering the RST duties until the RST training is completed.

It was discussed that A. Crook has worked at the project site for approximately 5 years in variouscapacities including the position of Water Sampler. In that capacity she became familiar withseveral aspects of the NRC required ground water monitoring. She has also assisted with otherenvironmental related programs, such as the baseline ground water programs for new mine units.Given her broad experience at the project she is very familiar with the various locations offacilities and she has a good exposure to, and general understanding, of the Safety and RadiationProtection Programs. She has also been a member of the site's Safety Committee for severalyears.

It was also discussed that the vacant Environmental Technician position will be filled in the nearfuture. This position also assists with the Radiation Protection Program as it is responsible forseveral of the environmental monitoring programs and also functions as an alternate RST. Theindividual filling this position will also undergo significant training.

All training for both positions will be documented in writing. W. F. Kearney-CRSO will also actas the Site RSO until such time that the RST incumbent, or another qualified person, assumes theRSO responsibilities. The RSO will review all work (surveys, reports etc.) completed by thenew RST for a period approaching 6 months. Such reviews will be documented by date andinitial. It is planned to send the new RST to an off-site Radiation Safety Class as soon as anapplicable class can be determined. It is expected that the individual will need to function as anRST for at least I to 11/2 years before it will be possible to have obtained the knowledge of thesite's Radiation Safety Program for promotion to RSO.

The existing PRI Environmental, Health, and Safety Reporting Structure contained in Chapter 9of the approved NRC License Application was reviewed. No modification was necessary as theCRSO will simply function as the Site RSO.

Although no change to the License Application was deemed necessary by this planned action,the SERP evaluated it against the conditions stated in License Condition 9.4 as shown in thetable below. The SERP concluded that the planned action satisfied those conditions.


Does the proposed change, test, and/or experiment conflict with the ALARA U 3principle?Does the proposed change, test, and/or experiment conflict with PRI's ability to O Tmeet all applicable regulations including NRC, WDEQ, and EPA?Is there degradation in the essential safety or environmental commitments in the - 1license application, or provided in the approved reclamation plan?Does the proposed change, test, and/or experiment conflict with any requirement J -

specifically stated in the source material license? __Is the proposed change, test, and/or experiment not consistent with the conclusions a 1of actions analyzed in the facilities Environmental Assessment (EA) orsupplemental EAs?Result in any increase in the frequency of occurrence of an accident previously Hl 1evaluated in the license application (as updated).Result in any increase in the likelihood of occurrence of a malfunction of astructure, system, or component (SSC) important to safety previously evaluated inthe license application (as updated).Result in any increase in the consequences of an accident previously evaluated in O Zthe license application (as updated).Result in any increase in the consequences of a malfunction of an SSC previously Cl *t 1evaluated in the license application (as updated).Create a possibility for an accident of a different type than previously evaluated in Cthe application (as updated).Create a possibility for a malfunction of an SSC with a different result than F -J apreviously evaluated in the license application (as updated).Result in the departure from the method of evaluation described in the license a 1application (as updated) used in establishing the final safety evaluation report or theenvironmental assessment (EA) or technical evaluation reports (TERs) or otheranalysis and evaluations. SSC means any SSC which has been referenced in aNRC staff SER, TER, EA, or environmental impact statement (EIS) and allsupplements and amendments. -_I

D. CONCLUSIONS

The SERP concluded that that the planned training of a new RST at the SR-HUP and theresumption of RSO activities by the CRSO would not require a License Amendment and doesnot conflict with any other regulatory requirement. Also, the change will not result in thedegradation of any essential safety or environmental commitments in the License Application,Environmental Assessments, or current operating procedures. As a result, the SERP approvedthe planned change concerning the staffing of the Radiation Protection Program.

Signature:_ Date: 27 05R. Knode, General Manager Operations

Signature: L& MIo eL~-K Milmine, Senior Environmental Scientist

Date: 9 / 9/D -

Signature:_ Date: g 7 7(W. F. Keame), Manager-dtha Safety, and Environmental Affairs/CRSO

Signature: 7 s- Date: -T. A. McCullough, Safety Sup or

Inter-Company Memorandum

Date: October 12, 2004

To: R. Knode, P. Drummond, T. McCullough, A.K. Crook

From: W.F. Kearney - Manager-Health, Safety & Environmental affairs/CRSO{ 4 'L

Re: Safety and Environmental Review Panel (SERP) No. 2004-5 Changes to theRadiation Protection Program

cc: File SR-4.6.4.2

In preparation for the August 2004 NRC Inspection, many components of the RadiationProtection Program were reviewed by the CRSO and the RST. It was determined that severalmodifications to the program needed to be made due to changes since Power Resources, Inc.(PRI) acquired the operation. Most of the proposed changes involve lessening the frequency ofcertain monitoring requirements. These proposed changes are supported by extensivemonitoring data. The proposed changes were discussed in part with the NRC during the August2004 Inspection and with Mr. John Lusher of NRC Headquarters, via telephone, onSeptember 29, 2004.

The SERP reviewed these proposed changes to the Radiation Protection Program. The results ofthe SERP review are presented in the following sections.


NRC License condition 9.4d of SUA-1548 requires that any changes, test or experimentsmade under the Performance Based License Condition be evaluated by a SERP consistingof at least three individuals. One member must have management expertise and have thefinancial and management responsibility for approving changes. The second membermust have operational and/or construction expertise and have responsibility forimplementing any operational changes. The third member must be the Radiation SafetyOfficer (RSO), or equivalent, with the responsibility of assuring that the proposedactivities will conform to radiation safety and environmental requirements. Individualsselected to perform this SERP review include:

R. Knode - General Manager OperationsW.F. Kearney - Manager-Health, Safety, and Environmental Affairs/CRSOP. Drummond - Superintendent CPP & MaintenanceT.A. McCullough - Safety SupervisorA.K. Crook - Radiation Safety Technician


The SERP met on October 7, 2004 to review the proposed changes as listed anddiscussed below. T.A. McCullough was not present at the meeting. He did review draftsand this final SERP review.

Proposed Change No. 1- Discontinue Designating the Pilot Building as a"Restricted Area"

The Pilot Building, located behind the CPP. and adjacent to the Warehouse, hashistorically been designated as a "Restricted Area" thereby requiring the maintenance ofan Alpha Survey Station and daily inspections. This designation resulted from the factthat the initial RAMC ISL Pilot Project processed wellfield fluids at the IX columns andother equipment at this location. This occurred several years prior to the startup of thecommercial operation in 1997.

PRI removed the IX columns, sand filter and other equipment from the Pilot Building in2003 in order to more fully utilize the space for the maintenance and storage of wellfieldequipment. Therefore, the majorradiation protection concern at this area was eliminatedas the gamma radiation producing IX columns and sand filters were removed to a distant,out door location.

Given these conditions it is proposed to remove the "Restricted Area" posting and therequirement that alpha surveying is necessary prior to leaving the Pilot Building. ThePilot Building will still be posted as an area "Containing Radioactive Materials" becausecontaminated downhole pumps and motors, and other similar wellfield equipment, arestored at the site. The Alpha Survey Station located adjacent to the Pilot Building will bemaintained in order that wellfield personnel can survey prior to eating, leaving the site, orat other times. The Pilot Building will continue to be routinely inspected by the EHSstaff on at least a weekly basis.

A review of NRC License 1548 and the License Application shows that this change doesnot conflict with any requirements.

Proposed Change No. 2 - Change Frequency of-Airborne Uranium Monitoring atCPP Dryer Room

Section 9.10.1.2 - "Airborne Uranium Monitoring at the Smith Ranch Central ProcessingPlant (CPP)" specifies that airborne uranium particulate monitoring (Hi Vol Sampling) isconducted monthly at the Precipitation Area and Yellowcake Storage Area and weekly inthe Dryer Room. Significant data exists that shows the lack of significant airborneuranium in the Dryer Room. This condition results from the fact that the "zero emissiondryers" are very effective at containing all uranium during drying. Strict procedures arealso followed when filling yellowcake drums to minimize spillage and the potential forairborne uranium. Additionally, it is required that the area be thoroughly washed down

after packaging of drums is complete to assist in eliminating the potential for airborneuranium.

Table 1 contains the concentrations of airborne uranium in the Dryer Room from Januarythrough September 2004. The highest concentration determined was only 1% DAC andthe average concentrations were approximately 0.3% DAC. Given the consistently lowconcentrations it is justified to reduce the monitoring to a monthly basis, consistent withthe other monitoring locations.

It should be noted that in the case of an unanticipated condition where uranium wasinadvertently released from a dryer or other source, air monitoring would be conducted toassess conditions, the need for respiratory protection, and to determine any exposures toemployees, if necessary.

A review of the NRC License 1548 shows that this change will not conflict with anyrequirements. This change will result in the need to revise Section 9.10.1.2 of theLicense Application (page 9-15). A revised page 9-15 that specifies that the monitoringfrequency for airborne uranium at the Dryer Room has been changed to a monthlyfrequency is included.

Proposed Change No. 3- Change Frequency of Breathing Zone Samples for theDryer Operator

Section 9.10.1.2 - "Airborne Uranium Monitoring at the Smith Ranch Central ProcessingPlant (CPP)" specifies that continuous airborne uranium samples (Breathing Zonesamples) are collected by the Dryer Operator during yellowcake packaging operationsbecause exposure to airborne uranium by these workers is possible during this activity.This data is used to determine the exposure of Dryer Operators to uranium during thepackaging of drums and associated activities where the greatest potential for exposure toairborne uranium exists. It should be noted that Dryer Operators are required to utilize arespirator with a Protection Factor of 1000.

Table 2 contains the Breathing Zone airborne uranium concentration data from Januarythrough September 2004. The review of Table 2 shows that airborne uraniumconcentrations during the yellowcake packaging and associated activities averaged onlyapproximately 22% DAC during the period. Therefore, exposures to the Dryer Operatorsare virtually nil due to the use of an effective respiratory protective program.

Currently, the "daily" Dryer Operator Breathing Zone samples are averaged for the weekand this data is used in the Employee Exposure Program to record exposures for DryerOperators. It is desirable to reduce the continuous monitoring of the Dryer Operator (i.e.one sample each day) to one sample per week, per Dryer Operator. This change willlessen the burden on the Dryer Operator to wear the Breathing Zone Sampler and lessentechnician time in processing the samples. Based on the data collected to date, the use ofa "weekly" Breathing Zone sample to estimate exposures to Dryer Operators will have nodiscemable impact to such determinations, especially given the respiratory protection

used by these individuals. As is typically done in the case of a new Dryer Operator, or asignificant change to the drying system, additional breathing zone samples would berequired.

It was determined at the October 7, 2004 SERP meeting that SOP-2040 "SR-CPPYellowcake Dryer Area Operations" should be revised to reflect this change and toupdate it with more current work practices. SOP-2040 was revised accordingly and therevised SOP-2040 was finalized and distributed on October 12, 2004.

A review of the NRC License 1548 shows that this change will not conflict with anyrequirements. This change will result in the need to revise Section 9.10.1.2 of theLicense Application (pg 9-16). A revised page 9-16 that specifies that Breathing Zonesamples will be obtained at least on a weekly basis for each Dryer Operator in order todetermine routine exposure to uranium is included.

Additionally, the SERP reviewed the three proposed changes against the conditions statedin License Condition 9.4 as shown in the table below. The SERP concluded that theproposed changes satisfied those conditions.


Does the proposed change, test, and/or experiment conflict with the ALARA j 3principle?Does the proposed change, test, and/or experiment conflict with PRI's ability to U 2meet all applicable regulations including NRC, WDEQ, and EPA?Is there degradation in the essential safety or environmental commitments in thelicense application, or provided in the approved reclamation plan?Does the proposed change, test, and/or experiment conflict with any requirement Especifically stated in the source material license? _ _ _ _

Is the proposed change, test, and/or experiment not consistent with the conclusions H 3of actions analyzed in the facilities Environmental Assessment (EA) orsupplemental EAs?Result in any increase in the frequency of occurrence of an accident previously 1evaluated in the license application (as updated).Result in any increase in the likelihood of occurrence of a malfunction of a -rj- Ostructure, system, or component (SSC) important to safety previously evaluated inthe license application (as updated).Result in any increase in the consequences of an accident previously evaluated in Ir Ithe license application (as updated).Result in any increase in the consequences of a malfunction of an SSC previously a o:evaluated in the license application (as updated).Create a possibility for an accident of a different type than previously evaluated inthe application (as updated).Create a possibility for a malfunction of an SSC with a different result than Lipreviously evaluated in the license application (as updated).Result in the departure from the method of evaluation described in the license irapplication (as updated) used in establishing the final safety evaluation report or theenvironmental assessment (EA) or technical evaluation reports (TERs) or otheranalysis and evaluations. SSC means any SSC which has been referenced in aNRC staff SER, TER, EA, or environmental impact statement (EIS) and allsupplements and amendments.

D. CONCLUSIONS

The SERP concluded that that the three proposed changes to the Radiation ProtectionProgram would not require a License Amendment and does not conflict with any otherregulatory requirement. Also, the change will not result in the degradation of anyessential safety or environmental commitments in the License Application orEnvironmental Assessments. As a result, the SERP approved the three changes to theRadiation Protection Program.

Signature:R. Knode, General Manager Operations

Date: /D/L/04

Signature: Date: /0/I ZA -y-W. F. Keamey anager-H , Safety, and Environmental Affairs/CRSO

Signature:_ _____ Date: lo { . oi0P. Drummond, Superintendent CPP & Maintenance

Signature: . Safeerv Date: /Qzlzlv

Signature: (2 (?fOtL.A.K. Crook - Radiation Safety Technician

Date: /D //&/ 4

TABLE I

2004Weekly CPP Dryer Room Airborne Uranium Samples

Week Concentration ( uCiml % DAC

Jan 4 - Jan 10 2.10E-12 0.4%Jan 11 -Jan 17 1.40E-12 0.3%Jan 18- Jan 24 2.40E-12 0.5%Jan 25 - Jan 31 1.30E-13 0.0%Feb 1 - Feb 7 4.90E-12 1.0%

Feb 8 - Feb 14 2.50E-12 0.5%Feb 15 - Feb 21 4.50E-13 0.1%Feb 22 - Feb 28 4.70E-13 0.1%Feb 29 - Mar 6 3.IOE-12 0.6%Mar 7 - Mar 13 1.20E-12 0.2%

Mar 14 - Mar20 1.80E-12 0.4%Mar 21 - Mar 27 2.40E-12 0.5%Mar 28 - Apr 3 2.30E-12 0.5%Apr 4 - Apr 10 2.60E-12 0.5%Apr11 -Apr17 6.50E-13 0.1%Apr 18 - Apr 24 2.1OE-13 0.0%Apr25 - May 1 2.20E-12 0.4%May 2 - May 8 5.1OE-13 0.1%

May 9 - May 15 6.90E-13 0.1%May 16 - May 22 2.20E-12 0.4%May 23 - May 29 7.60E-13 0.2%May 30 - June 5 1.30E-12 0.3%June 6 - June 12 1.70E-12 0.3%

June 13 - June 19 1.50E-13 0.0%June 20 - June 26 2.60E-12 0.5%June 27 - July 3 1.30E-12 0.3%July 4 - July 10 3.50E-12 0.7%July 11 - July 17 1.IOE-13 0.0%July 18 - July 24 9.50E-14 0.0%July 25 - July 31 3.10E-12 0.6%

Aug 1 -Aug 7 7.30E-13 0.1%Aug 8-Aug 14 7.30E-13 0.1%

Aug 22 - Aug 28 1.90E-13 0.0%Aug 29 - Sept 4 2.60E-13 0.1%Sept 5 - Sept 11 1.20E-13 0.0%

Sept 12 - Sept 18 O.OOE+00 0.0%Sept 19 - Sept 25 2.90E-13 0.1%

Average = 1.38E-12 0.3%

DAC = 5.00E-10

TABLE 22004

Daily Dryer Operator Breathing Zone Samples

Average Conc. HHighest Conc. forweek # samples for

Week ( uCuml) % DAC uCi/ml % DAC week

Jan 4-Jan 10 5.80E-11 11.6% 9.70E-11 19.4% 6Jan 11 -Jan 17 2.50E-11 5.0% 3.30E-11 6.6% 7Jan 18 - Jan 24 5.60E-11 11.2% 1.10E-10 22.0% 6Jan 25 - Jan 31 7.60E-11 15.2% 1.90E-10 38.0% 6Feb 1 - Feb 7 1.70E-10 34.0% 7.50E-10 150.0% 6

Feb 8 - Feb 14 9.70E-11 19.4% 1.70E-10 34.0% 7Feb 15 - Feb 21 1.80E-10 36.0% 2.70E-10 54.0% 4Feb 22 - Feb 28 1.90E-10 38.0% 3.60E-10 72.0% 4Feb 29 - Mar6 1.10E-10 22.0% 2.40E-10 48.0% 5Mar 7- Mar13 7.60E-11 15.2% 1.60E-10 32.0% 5

Mar 14 - Mar20 2.OOE-10 40.0% 4.1OE-10 82.0% 6Mar 21 - Mar 27 5.10E-10 102.0% 2.10E-09 420.0% 5Mar28 - Apr 3 5.30E-11 10.6% 9.40E-1 1 18.8% 6Apr 4-Apr10 7.40E-11 14.8% 1.00E-10 20.0% 6Apr11 -Apr17 1.10E-10 22.0% 1.90E-10 38.0% 5Apr 18-Apr24 8.60E-11 17.2% 1.70E-10 34.0% 7Apr25- May 1 7.50E-11 15.0% 1.20E-10 24.0% 5May2 - May8 9.10E-11 18.2% 1.30E-10 26.0% 6

May 9 - May 15 6.20E-11 12.4% 1.40E-10 28.0% 6May 16 - May 22 9.00E-11 18.0% 1.50E-10 30.0% 6May23 - May29 5.60E-11 11.2% 1.30E-10 26.0% 5May 30 - June 5 7.30E-11 14.6% 9.20E-11 18.4% 3June 6 - June 12 9.20E-11 18.4% 1.50E-10 30.0% 5

June 13- June 19 6.50E-11 13.0% 1.40E-10 28.0% 5June20- June26 3.30E-11 6.6% 5.00E-11 10.0% 7June 27 - July 3 7.60E-11 15.2% 1.10E-10 22.0% 4July 4-July10 7.00E-11 14.0% 1.50E-10 30.0% 3July 11 - July 17 6.OOE-11 12.0% 1.20E-10 24.0% 4July 18 - July24 8.00E-11 16.0% 1.40E-10 28.0% 5July25 - July31 7.80E-11 15.6% 1.60E-10 32.0% 5Aug 1 - Aug 7 1.IOE-10 22.0% 2.10E-10 42.0% 5

Aug 8-Aug 14 7.90E-11 15.8% 2.60E-10 52.0% 6Aug 15 - Aug 21 1.20E-10 24.0% 3.50E-10 70.0% 6Aug 22 - Aug 28 1.20E-10 24.0% 2.1OE-10 42.0% 6Aug 29 - Sept4 1.10E-10 22.0% 2.20E-10 44.0% 4Sept 5 - Sept 11 1.40E-10 28.0% 3.00E-10 60.0% 4

Sept 12 - Sept 18 3.40E-10 68.0% 1.30E-09 260.0% 5Sept 19 - Sept 25 1.30E-10 26.0% 2.70E-10 54.0% 5

Average = 1.11E-10 22.2% 2.72E-10 54.5% 201

DAC = 5.00E-10

In the drying and packaging areas at Smith Ranch the potential exists for exposure toyellowcake dust that is classified as 'soluble" since the operating temperature of theVacuum Dryer is low (about 770C or 1700F). In the slurry unloading area the potentialfor exposure to airborne uranium is considerably less than in the drying and packagingareas. The yellowcake dust is classified as soluble in the slurry unloading area. Slurryunloading is performed on a very infrequent basis.

9.10.1.1 Airbome Uranium Monitoring at the Highland Central Plant

When the Highland Central Plant is operating, there is continuous monitoring ofairborne uranium particulates at the drying and packaging areas. During periods ofdrying and packaging activity, the filters of the continuous air monitors are changed andanalyzed daily. During periods that drying and packaging activities are not occurring,the filters are changed and analyzed on a weekly basis.

Exposures to workers are determined from the conservatively estimated uraniumparticulate concentration data, occupancy time studies, and the application of theApplied Protection Factor (APF) of 100 for the routine use of fullface air purifyingrespirators. Consistent with the Respiratory Protection Program, all Highland CentralPlant Operators utilizing negative pressure respirators are required to pass thequantitative fit test.

When the Highland Central Plant is operating, the Precipitation Area of the plant ismonitored on a quarterly basis for airborne uranium. A review of the historic datashows that maximum airborne uranium concentrations were less than 1% of the DACfor soluble uranium (5E-10 giCi/ml).

9.10.1.2 Airborne Uranium Monitoring at the Smith Ranch Central Processing Plant(CPP)

Airborne uranium particulate monitoring at the Smith Ranch CPP and Pilot Building washistorically performed on a monthly basis. Given the extensive data base that exists forthe Pilot Building that shows the virtual lack of airborne uranium in this area, and thefact that IX equipment and tanks have been removed, it is not necessary to furthermonitor this area for airborne uranium.

Airbome uranium particulates at the Smith Ranch CPP are monitored to assess anyunanticipated occurrence of uranium in the air and provide uranium airborneconcentration data used in the exposure determinations for the CPP Operators and theDryer Operators. The monitoring locations and frequency are as follows:

Location FrequencyPrecipitation Area MonthlyYellowcake Storage Area MonthlyDryer Room Monthly

Smith Ranch-Highland Application/Chapter 9 9-15 Revised 10104 1

To estimate the routine exposure of Dryer Operators to uranium, a high volume sampleris set up in the yellowcake packaging area or representative samples are collected witha Breathing Zone (BZ) sampler. Dryer Operators are required to wear respiratoryprotection during yellowcake packaging operations because of the potential release ofairborne uranium during this procedure.

9.10.1.3 Airborne Uranium Monitoring at Satellites

Due to the fact that the uranium bearing fluids at the Satellite facilities are fullycontained within pipes, tanks, and IX vessels the likelihood of any significant quantitiesof uranium in the air is very remote. This is supported by many years of data collectedat both Smith Ranch and Highland Satellites that show virtually no occurrence ofairborne uranium at these facilities. Therefore, uranium particulates are not routinelymonitored at these facilities.

9.10.1.4 Radon Daughter Monitoring

Radon daughters are routinely monitored on a monthly basis at the Highland CPF(when operating), the Smith Ranch CPP, and Satellite facilities. Routine exposures toradon daughters are only determined for Central Plant Operators. The method ofanalysis is the modified Kusnetz method or other commonly accepted method ofmeasurement. In the case that radon monitoring determine concentrations above 0.08WL, the monitoring frequency will be increased to weekly until the following foursamples return to less than 0.08 WL.

During the period 1988 through 1993, weekly and monthly monitoring results atnumerous sites throughout the project showed that radon daughter concentrations wereroutinely less than 10% of the regulatory limit of 0.33 working level. Therefore, it wasdetermined that the routine exposure of workers to radon daughters only needed to bedetermined for Central Plant Workers (Central Plant and Dryer Operators).

9.10.1.5 Airbome Radioactive Areas

Any area, room, or enclosure will be designated an "Airborne Radioactivity Area" asdefined in 10 CFR 20.1003, if at any time the uranium concentration exceeds 5E-10pCi/ml for soluble uranium or 2E-1 1 pCi/ml for insoluble uranium.

When operating, both the Yellowcake Dryer Room and Yellowcake Packaging Room atHighland are posted as Airbome Radioactivity Areas as concentrations of insolubleuranium may at times exceed 2E-1 I pCi/ml. Because the predominant form of airborneuranium in these areas is comprised of high-fired (above 400 0C) dried yellowcake, theinsoluble uranium DAC (2E-11 pCi/ml) is used.

Smith Ranch-Highland Application/Chapter 9 9-16 Revised 10104 1

Inter-Company MemorandumDate: December 21, 2004

To: R. Knode, W. F. Kearney, C. Foldenauer, S. P. Collings

From: Ken Milmine- Senior Environmental Scientist 1 ,Re: Safety and Environmental Review Panel (SERP) No. 2004-6: Temporary

Re Management Replacement for General Manager of Operations

cc: File SR 4.6.4.2

A. INTRODUCTION

Starting in January of 2005, the General Manager of Operations, Ralph Knode, is leaving theSmith Ranch-Highland Uranium Project (SR-HUP) to go on a temporary assignment at anotherCameco in situ operation in Khazakistan. Mr. Knode will be on this assignment forapproximately t-wo years, after which he will resume his duties as General Manager ofOperations at the SR-HUP.

As a replacement, Chuck Foldenauer has been named as Mine Manager of SR-HUP and willfulfill the duties as described for the General Manager of Operations until Mr. Knode's return.Mr. Foldenauer has extensive experience as managing in situ uranium mining operations,including other operations in Wyoming.

The SERP reviewed this change in relation to the qualifications described in the current LicenseApplication. The results of the SERP review are presented in the following sections.


NRC License condition 9.4d of SUA-1 548 requires that any changes, test or experiments madeunder the Performance Based License Condition be evaluated by a SERP consisting of at leastthree individuals. One member must have management expertise and have the financial andmanagement responsibility for approving changes. The second member must have operationaland/or construction expertise and have responsibility for implementing any operational changes.The third member must be the Radiation Safety Officer (RSO), or equivalent, with theresponsibility of assuring that the proposed activities will conform to radiation safety andenvironmental requirements. Individuals selected to perform this SERP review include:

R. Knode- General Manager OperationsC. Foldenauer- Mine ManagerW. F. Kearney- Manager- Health, Safety, and Environmental Affairs/CRSOK. Milmine- Senior Environmental ScientistS. P. Collings- Senior Vice President

1


The SERP met on December 21, 2004 to review the temporary management change in relation tothe qualifications described in the License Application. S. P. Collings was not present at themeeting however he did review and agree with this final SERP. Qualifications for the GeneralManager of Operations stated in the NRC License Application include:

0

A Bachelor's Degree in engineering or science from an accredited College or University.Minimum of five years supervisory experience.Work experience which includes industrial process/production experience and industrialprocess/production management.

A review of Mr. Foldenauer's qualifications showed that he has a Bachelors Degree inMechanical Engineering and also maintains registration as a Professional Engineer in Wyomingand Pennsylvania. It was also shown that Mr. Foldenauer has more than 12 years ofmanagement experience for in situ uranium mining operations in Wyoming and Australia. Hehas fulfilled the responsibility of Mine Manager and understands environmental, safety, andradiation protection requirements. The SERP concluded Mr. Foldenauer's qualificationssatisfied the qualifications described in the License Application for the General Manager ofOperations.

The SERP evaluated the temporary change in management against the conditions stated in theLicense Condition 9.4b as shown in the table below. The SERP concluded that these changessatisfied those conditions.


Does the proposed change, test, and/or experiment conflict with the ALARA fprinciple?Does the proposed change, test, and/or experiment conflict with PRI's ability to HFJegmeet all applicable regulations including NRC, WDEQ, and EPA?Is there degradation in the essential safety or environmental commitments in thelicense application, or provided in the approved reclamation plan?Does the proposed change, test, and/or experiment conflict with any requirement H 1specifically stated in the source material license?Is the proposed change, test, and/or experiment not consistent with the conclusionsof actions analyzed in the facilities Environmental Assessment (EA) orsupplemental EAs?Result in any increase in the frequency of occurrence of an accident previously L 1J Nevaluated in the license application (as updated). _Result in any increase in the likelihood of occurrence of a malfunction of astructure, system, or component (SSC) important to safety previously evaluated inthe license application (as updated).Result in any increase in the consequences of an accident previously evaluated inthe license application (as updated).Result in any increase in the consequences of a malfunction of an SSC previously FJ ESevaluated in the license application (as updated).Create a possibility for an accident of a different type than previously evaluated inthe application (as updated).

2

Create a possibility for a malfunction of an SSC with a different result than fl Fpreviously evaluated in the license application (as updated).Result in the departure from the method of evaluation described in the licenseapplication (as updated) used in establishing the final safety evaluation report or theenvironmental assessment (EA) or technical evaluation reports (TERs) or otheranalysis and evaluations. SSC means any SSC which has been referenced in aNRC staff SER, TER, EA, or environmental impact statement (EIS) and allsupplements and amendments.

D. CONCLUSIONS

The SERP concluded that the temporary change of Mine Managers would not require a LicenseAmendment and does not conflict with any other regulatory requirement. Also, this change willnot result in the degradation of any essential safety or environmental commitments in the LicenseApplication, Environmental Assessments, or current operating procedures. As a result, the SERPapproved the temporary change to replace Ralph Knode, General Manager Operations, withChuck Foldenauer, Mine Manager.

Signature:

Signature:

Signature:

R. Knode, General Manager Operations

N- -

Date: i2/,Io /4

Date: a21t\ to L.

Date: Pt /ld skee

C. IldeIdnauer, Mine Manager

K. Milmine, Senior Environmental Scientist

Signature: I Date: /2-/ ( Yt/W. F. Kearney, anager- th, Safety, and Environmental Affairs/CRSO

Signature: Date:S. P. Collings, Senior Vice President of Operations

3

Ulf U00 h00.j 00. .01 14U21 t 10J.OL, I Lfr'L.I\ ~ -.-

pRmvicusly evaluated InicnsResult in the depagttre= _ "application (as updated) used in establishing the fiis! safet evaluatian report ar theenvironmental assessment (EA) or technital evaluation report (TrIs) or otheranalysis and evaluations. SSC means msy SSC which has been referenced in aN'RC staff S, 7TMR EA, or envirornnental Impact statement (ETS) and allsu lements and emndirents.-

1). CONCLVSIONS

The S.RP concluded that rhe temporary change of Mine Managers woulc not require a LicenseAmendment and does not conflict with any other regulatory requirement Also, this change willnot result in the degradation of any essential safety or nvimronental com ftmxents in the LicenseApplication, Eni;uronental Assesments, ort urrent operatng procedur As a reult, the SIEIapproved the temporaty change to replace Ralph Knode, General Manager Opeaions, withChuck Foldenauer, Mine Manager.

Signatute: s1.$Mt6 1sf~~R. Knode, Genmln Manager Opeallons

Signature:-

C. ldenauer, e Manager

Signature: - _K. Milmine, Senior Rnv m l Scientist

_ t ae. st/V 1,o4

tEate_______IC)__

-Late:; P, 't IJI

Irate:

en al Aitairs/CRSO

Signahre: ,S. P. Callmngctnior Vice President of Operations

L ate: /A/e2

3.

SiLo- to/kl'/d SSSJ. ONI SMOS38 V30-11011 set[ to-12-na

Documents

POWER Smith Ranch -Highland · Highland CPF remains on standby status. It is anticipated that the Highland CPF will remain in standby status for several upcoming reporting periods