Radiation Protection Program Manual Revision2 Prepared for ...Radiation Protection Program Manual Homestake Gran~s Reclamation Project Cibola County, New Mexico Revision2 Prepared

Radiation Protection Program Manual Homestake Gran~s Reclamation Project

Cibola County, New Mexico

Revision2

Prepared for:

Homestake Mining Company of California P. 0. Box98

Grants, New Mexico 87020

Prepared by:

ERG Environmental Restoration Group, Inc.

8809 Washington St. NE, Suite 150

Albuquerque, NM 87113

505-298-4224

October 26, 2018

n

Radiation Protection Program Manual Homestake Grants Reclamation Proiect

APPROVALS

This Radiation Protection Program (RPP) for decommissioning and remediation operations at the Homestake Grants Reclamation Project has been reviewed and approved by the following:

Name Title Date

.~~ Site Closure Manager 12..-os-/P

~---A'~ .• ~~-~~ ~tion Safety Officer

Changes to this RPP must be reviewed and approved by the above management personnel. A controlled hard copy of this RPP Manual will be maintained onsite by the Radiation Safety Officer (RSO) and Radiation Safety Technician (RST).

Revision History

Revision# Date

0 03-01-18

1 03-21-18

2 10-26-18

Revision 2, October 26, 2018 ii


TABLE OF CONTENTS

APPROVALS ............................. ; .................................................................................................... ; ................ ii

1. INTRODUCTION ..................................................................................................................................... 1

2. NECESSITY AND OBJECTIVES ................................................................................................................. 1

2.1 Radiological Exposures .................................................................................................................. 1

2.2 Radiation Dose .............................................................................................................................. 3

2.3 Regula.tory Requirements ............................................................................................................. 4

2.4 ALARA Policy ................................................................................................................................. 5

3. MANAGEMENT AND ADMINISTRATION ............................................................................................... 5

3.1 Organizational Structure and Responsibilities .............................................................................. 5

3.2 Qualifications and Training ........................................................................................................... 6

3.2.1 RPP Staff Qualifications ......................................................................................................... 6

3.2.2 Radiation Safety Training ...................................................................................................... 8

4. RADIATION PROTECTION CONTROLS AND MONITORING .................................................................... 8

4.1 Engineering Controls ..................................................................................................................... 8

4.1.1 Physical Controls on Access ......................................................................•........................... 8

4.1.2 Security of Licensed Radioactive Materials .......................................................................... 9

4.2 Administrative Controls ................................................................................................................ 9

4.2.1 Administrative Controls on Access ....................................................................................... 9

4.2.2 Regulatory and Administrative Limits ................................................................................. 10

4.2.3 Radiation Safety Work Rules ............................................................................................... 12

4.2.4 Standard Operating Procedures for Radiation Protection .................................................. 13

4.2.5 Radiation Work Permits ...................................................................................................... 14

4.2.6 Tracking of Radioactive Materials and Sources of Radiation .............................................. 14

4.2.7 Inspections and Audits ........................................................................................................ 15

4.3 Contamination Control ........................................................................................•. , .................... 15

4.3.1 Inspection and Maintenance of Operational Equipment ................................................... 15

4.3.2 Workplace Contamination Surveys ..................................................................................... 16

4.3.3 Equipment Release Surveys ................................................................................................ 16

4.3.4 Personnel Exit Surveys ........................................................................................................ 16

4.3.5 Decontamination ................................................................................................................ 16

Revision 2, October 26, 2018 iii


4.3.6 Contamination Survey Instruments and Applications ........................................................ 17

4.3.7 Response to Accidental Spills or Releases .......................................................................... 18

4.4 Limitation of Radiological Dose .................................................................................................. 18

4.4.1 Regulatory and Administrative Dose Limits ........................................................................ 19

4.4.2 Occupational Dose Monitoring ........................................................................................... 19

4.5 Effluent Controls ..................................................................................................................... : ... 23

4.5.1 Radiological Waste IY(anagement ........................................................................................ 23

4.5.2 Limits on Radiological Releases to the Environment.. ........................................................ 24

4.6 Environmental Monitoring and Public dose ............................................................................... 24

4.6.1 Monitored Environme.ntal Media and Program Design ...................................................... 24

4.6.2 Radon Flux Measurements ................................................................................................. 24

4.6.3 Public Dose Determination ................................................................................................. 25

4.6.4 Assessment and Response to Trends or Changing Conditions ........................................... 26

4.6.5 Records Keeping and Reporting .......................................................................................... 27

4.7 Quality Assurance ....................................................................................................................... 27

4. 7 .1 Programmatic Performance-based Indicators .................................................................... 27

4.7.2 Quality Control for Radiological Field Measurements ........................................................ 27

5. REFERENCES ............................................................................................................................... ~········· 28

APPENDIX A- Standard Operating Procedures (SOPs) for the Radiation Protection Program .................. 29

APPENDIX B - 2018 Occupational Radiation Exposure Study ..................................................................... 30

Standard Operating Procedure (SOP) numbers and titles:

~,a~~~b::: Ii. ··-\'';·~i.J~;{1:"f'1:: '.}/ '""" ?;') ' \:::+;';,z!::,1,:'l~''·'. ! ?'.!~ tJl~~~:;lt) tF,~i~i°.~ '~I{i~ , . :" _ - '\':>l,JI' T.itte (~:., •. _ ,s~o.ri~. prqc~,t~l~',t~t~·:)·_: ... · .. . ,.f~,'f. ~·-, ..... :\' ' ' .. ,,, '\!:,:: . . · ,,, . " ·, ____ ;;-{, ,' '", .-" ,·., c-·/;-··.· .,.. ._.._ ·.\_·~·,. - ". - "· :. ~

SOP 2 Procedure for Conducting a Field Level Risk Assessment (FLRA) 2 10-15-2018

SOP 11 Radiological Air Monitoring for Occupational Exposures {HP-1) 2 10-15-2018

SOP 12 Radiological Contamination Surveys {HP-2) 14 10-15-2018

SOP 13 Calculation of Radiation Doses to Personnel (HP-3) 12 10-15-2018

SOP 14 Bioassay Sample Collection (HP-8) 15 10-15-2018

SOP 16 Instrument Test and Calibration Procedure (HP-10) 12 10-15-2018

SOP 18 Procedure for Implementing a Radiation Work Permit (HP-16) 9 10-15-2018

SOP20 Environmental Monitoring Except Groundwater (EM-2) 17 09-09-2018 SOP 21 Spill Response and Reporting Procedure (EM-4) 3 10-15-2018

SOP 22 On-Site Disposal of Radiologically-Impacted Waste 1 10-20-2018

SOP 23 Evaporation Pond Operations 1 10-15-2018

SOP 33 HMC ALARA Procedure (HP-6) 1 07-12-1993

Revision 2, October 26, 2018 iv


FIGURES

Figure 1: General Site layout and features of routine operational areas at the HMC Grants Site ........................... 2 Figure 2: Measured gamma exposure rates across routine operational areas at the Site, December 2017 ............ 3 Figure 3: Ludlum 43-93 alpha/beta detector with Model 2360 ratemeter and scaler ........•.................................. 17 Figure 4: Ludlum Model 3030 sample counter with internal alpha/beta detectors and sample holder chamber. 17

TABLES

Standard ,operating Procedure (SOP) numbers and titles: ·······························:···················································· iv Table 1: Summary of Regulatory and Administrative radiological control limits .•......................•.•....................... 11

Table 2: Standard Operating Procedure (SOP) numbers and titles for implementation of this RPP Manual ......... 14

Table 3: Regulatory Dose limits, reproduced from NRC Regulatory Guide 8.30 (Revision 1, 2002) .........•............. 20 Table 4: Occupational exposure/dose monitoring requirements under LC 10 (adapted from Table 3 of the 1993

license amendment request) .......•......................•...•.................................................................................... 20 Table 5: Relevant occupational intake limits from 10 CFR 20 Appendix B ..........•................................................. 21

Table 6: Environmental Monitoring Program excluding Groundwater Monitoring (reproduced from SOP 20) .... 25

Revision 2, October 26, 2018 V

Radiation Protection Program Manual HMC Grants Reclamation Project

1. INTRODUCTION

Uranium milling occurred between 1958 and 1990 at the Homestake Mining Company of California's

(HMC) Grants millsite (Site) . The facility, located approximately 5 miles north of Milan, New Mexico,

currently functions as a site decommissioning and environmental reclamation project under Radioactive

Materials License SUA-1471 with the U.S. Nuclear Regulatory Commission (NRC) . Former milling facility

buildings (e.g. crusher, ore bins, grind/leach, separation and yellowcake drying and packaging) have been

demolished and disposed onsite in accordance with the approved Decommissioning and Reclamation Plan

(AKG and Jenkins, 1993a and 1993b).

Remaining structures include two engineered uranium mill tailings impoundments including the Large

Tailings Pile (LTP) and Small Tailings Pile (STP), three lined evaporation ponds (EP1, EP2, and EP3), two

lined wastewater collection ponds (East Collection Pond and West Collection Pond), a Reverse Osmosis

(RO) water treatment plant, two lined zeolite water treatment facilities (on top of the LTP),

shop/maintenance and administration buildings (Figure 1), and hundreds of groundwater extraction,

injection, and water quality monitoring wells and associated piping infrastructure across the Site.

Containing an estimated 21 million tons of mill tailings, the L TP covers an area of about 200 acres. The

STP contains approximately 1.2 million tons of mill tailings in a 40-acre impoundment with a lined

evaporation pond (EP1) constructed on top. As was standard practice for the uranium industry in the late

1950's, the tailings impoundments were unlined and seepage from the two piles has since resulted in

contamination of shallow underlying groundwater aquifers.

The LTP side slopes have been fully reclaimed with a radon barrier, freeze/thaw protective soil layer, and

rock erosion protection. The top surface has an interim soil cover and the lined zeolite treatment systems

on its top surface. The STP has been partially reclaimed with interim soil cover on the side slopes and top

as well as the lined EP1 on its surface. Portions of the STP are still used for burial of Byproduct material

wastes from reclamation activities. Spray misters are used on the evaporation ponds seasonally to

increase evaporation of stored waters.

The objective of this Radiation Protection Plan (RPP) Manual is to provide a cohesive and detailed

description ofthe methods and procedures used to manage, control, monitor and limit occupational and

public exposures to ionizing radiation from licensed radioactive materials associated with the tailings piles

and ongoing remediation of impacted groundwater. Although most terrestrial sources of licensed

material have been disposed in tailings impoundments that are capped with interim and/or final cover,

there are still residual sources to which workers and the public could potentially become exposed.

2. NECESSITY AND OBJECTIVES

2.1 Radiological Exposures

The primary radioactive elements at the Site include natural uranium (U-nat), radium-226 (Ra-226),

thorium-230 (Th-230), and radon-222 (Rn-222) gas with its short-lived decay products. These

radionuclides, as well as several stable and potentially toxic heavy metals, are found in uranium mill

tailings and residual solids (sludge/evaporites) in evaporation and collection ponds. Because the tailings

Revision 2, October 26, 2018 1


and former mill processing buildings and infrastructure are isolated from the active surface environment

(buried), and since most soil contamination has been cleaned up and disposed with tailings, potential

radiation exposure pathways are limited to the following :

• Accidental ingestion of dissolved radionuclides in process water contained in evaporation or collection

ponds or the Zeolite water treatment facilities .

• Accidental ingestion of radionuclides in tailings or contaminated drill cuttings brought to the surface.

Includes potential offsite transport of associated contamination on personnel or equipment.

Figure 1: General Site layout and features of routine operational areas at the HMC Grants Site.

• Inhalation of long-lived radionuclides in airborne particulates released from dried evaporative salts or

exposed sludge from the ponds, or from liquid aerosols released by turbo misters used to accelerate



evaporation of Site process water. This pathway includes potential offsite transport of associated

contamination on personnel or equipment .

• Inhalation of short-lived radon decay products {radon progeny) in air associated with the escape of

radon gas from the covered ta ilings piles, or from release of radon gas incidental to the water

treatment process in the RO Plant.

• Exposure to external {direct) gamma radiation from buried tailings with relatively thin amounts of

interim cover soil, or from rad ioactive sludge contained in the collection or evaporation ponds.

Figure 2 shows the spatial distribution of gamma exposure rates in routine work areas as measured

in December of 2017.

Expc»ure Rate (uR/hr) .<10 20 30 .,oo . 15 0 25 . 50

~ Exposure Rate (uR/hr)

31? 1 ml 1:j°" IM

·~i .. 2%

31.i ft!

It 83% IU IU 10

1 14% • • 3.16

ijl 0% ....

UI 1

... Quantiles ---100.0% maximum 447

995% 149

975% 35.7

90.0% 203

75.0% quartile 16.6

50.0% median 13.9

25.0% quartile 11 .1

10.0% 9A

2.596 8.1

0.5% 7.2

0.0% minimum 3.6

A ? summary Statistics

Mean 165

Std Dev 21 .7

Std Err Mean O. 1

Upper 95% Mean 16.6

Lower 95% Mean 16.4

N 123148

Figure 2: Measured gamma exposure rates across routine operational areas at the Site, December 2017.

2.2 Radiation Dose

Based on occupational and environmental monitoring data, the potential for radiation doses to workers



or the public from Site operations is low. The maximum annual external dose measured for any worker

over the past 5 years was 23 mrem 1. Annual external dose is generally below the reported detection limit

of 1 mrem, and this trend is expected to continue under routine operational conditions. This contribution

is within the variability in background levels.

With respect to internal doses, occupational air monitoring for internal exposures to long-lived airborne

radionuclides via the inhalation pathway was discontinued in 2010 based on several years of high-volume

air sampling data collected on top of the LTP that showed concentrations of long-lived radionuclides in

airborne particulates consistent with background levels . In 2017, the NRC requested that HMC conduct

an occupational radiation exposure monitoring study to characterize the potential for occupational doses

to workers under current operational circumstances and conditions. The resulting data (ERG, 2018; see

Appendix B) confirmed that there is not a reasonable likelihood of any worker exceeding the 500 mrem/yr

threshold that requires occupational monitoring for radiological exposures as specified in 10 CFR 20.1502.

However, this study also concluded that occupational monitoring is still appropriate for certain

non-routine operational activities at the discretion of the RSO (e .g. under a RWP) as a higher potential for

radiological exposures is still possible for activities involving potential contact with tailings, pond sludge,

or waste streams from RO water treatment.

With respect to intakes of soluble uranium and associated toxicity concerns, bioassay results are typically

below the 5 µg/L analytical detection limit for uranium. Results rarely show uranium levels above the

detection limit, and it is exceedingly rare that a sample result has approached or exceeded any action

level (e .g. 15 µg/L) . In such cases, an actual intake has never been confirmed by follow-up investigations,

which included additional bioassay sampling (i.e. lab error or sample contamination have generally been

determined to be the most likely explanation) .

2.3 Regulatory Requirements

A RPP is required for all NRC licensees by 10 CFR 20.1101 and 10 CFR 20.2102. Environmental monitoring

for effluents and respective estimation and reporting of public exposure is required by 10 CFR 40.65 using

limits and methods specified in 10 CFR 20.1301 and 20.1302 respectively . Annual measurements of

average radon flux from the LTP and STP are required by LC 36(E) . Occupational radiation exposure

monitoring is currently conducted at the discretion of the RSO (see Table 4, Section 4.4.2) to ensure

exposures of workers are being maintained ALARA in accordance with the guidance provided in NRC

Regulatory Guide 8.31. Routine monitoring is no longer necessary as both recent and historic monitoring

data over a number of years indicates that exposures are well below the regulatory threshold that requires

individual monitoring per 10 CFR 20.1502 specifications (generally 10% of any limit, e.g. < 500 mrem/yr) .

A supporting report for an occupational exposure monitoring study directed by the RSO in 2018 (ERG,

2018) is provided in Appendix B.

1 As measured with optically stimulated luminescent (OSL) dosimeters from Landauer.



2.4 ALARA Policy

As stated in 10 CFR 20.1101(b),"The licensee shall use, to the extent practicable, procedures and

engineering controls based upon sound radiation protection principles to achieve occupational doses and

doses to members of the public that are as low as is reasonably achievable (ALARA)." An overarching

objective of this RPP is to keep radiological doses and effluent releases ALARA. Historic Standard

Operating Procedure (SOP) HP-6 (recently renamed "SOP 33") requires an independent ALARA Audit of

the RPP annually in accordance with Section 2.3.3 of Regulatqry Guide 8.31. Accordingly, the following

company policy statement applies:

"HMC will maintain radiation exposures, and releases of radioactive materials in .effluents to unrestricted

areas, as low as is reasonably achievable considering the state of technology, and the economics of

improvements in relation to benefits to the public health and safety, and other societal and socioeconomic

considerations, and in relation to the utilization of atomic energy in the public interest."

In addition, NRC Regulatory Guide 8.31,.Section 2.3.2, specifies monthly ALARA evaluations and summary

reports. Monthly ALARA evaluations of the stc1tus of the RPP are documented and reported to the Closure

Manager, and as indicated above, an· independent 3rd party ALARA Audit of the RPP is conducted annually

with res'ults reported to NRC.

3. - MANAGEMENT AND ADMINISTRATION

3.1 Organizational Structure and Responsibilities

• License Holder

Homestake Mining Company. of California. Ensures that the necessa,ry resources are available to

support the .RPP in compliance with license conditions and applicable regulations, supports general

safety culture, ALARA policy, and recommendation~ of the Site Closure Manager with respect to

radiation protection requirements.

• Site Closure Manager

Reports directly to Barrick Management. Ensures that the necessary human resources and equipment

are in place to support an effective RPP in compliance with license conditions and applicable

regulations, supports general safety culture, ALARA policy, and serves as a member of any Safety and

Environmental Review Panel (SERP) evaluations.

• Radiation Safety Officer (RSO)

Reports directly to the Closure Manager. Responsible for RPP design and oversight including

development of RPP elements and procedures, performs instrument selections, reviews RPP data,

audits program records, performs dose calculations, develops and provides radiation safety training,

reviews/approves corrective action plans, and modifies the RPP and associated SOPs as needed to

keep radiological exposures ALARA. Reviews Field Level Risk Assessments (FLRAs) as needed to

determine any special radiation protection procedures, or if a Radiation Work Permit (RWP) is


Radiation Protection Program Manual HMC Grants Reclamation Proiect

required, reviews/approves the RWP. Develops and submits required reports to applicable regulatory agencies and serves as a member of any SERP evaluations.

• Alternate RSO (ARSO)

Reports directly to the RSO. Responsible for performing monthly ALARA audits and providing supplemental technical support to the RSO for management and onsite implementation of the RPP, and for acting on behalf of the RSO when the RSO is temporarily unavailable for time-sensitive decision making on radiation protection matters. This authority may include determination of the need for a RWP for a given Site activity, and review and approval of RWPs or other documentation that requires sign-off by the RSO.

• Radiation Safety Technician (RST}

Reports to the RSO on all RPP matters, along with the Site Closure Manager where appropriate. Onsite management and implementation of the RPP including administration of personnel dosimetry and bioassay sampling programs, performs workplace surveys and occupational/environmental air monitoring, collects samples from groundwater wells.and air monitoring equipment, inspects and maintain~ effluent control and waste management systems, enforces worker compliance with RPP procedures, ensures proper records keeping and instrument calibrations and maintenance. In addition, the RST evaluates potential exposure circumstances associated with non-routine work activJties, and describes the scope of the work in ;FLRAs (where applica.ble) and to the RSO tq obt13in direction regarding the need for any special radiological controls, ranging from personnel and equipment contamination surveys, to issuance of a RWP with additional monitoring for potential worker exposures to radioactive materials.

• Site Workers

Reports radiation safety issues or concerns to the RST, RSO or Closure Manager. Workers that could receive doses > 100 mrem/yr from occupational sources of radiation are considered "radiation workers" by the NRC. While worker doses are generally not expected to exceed 100 mrem/yr, all workers performing work in controlled or restricted areas are responsible for adhering to requirements of the RPP and associated SOPs.

3.2 Qualifications and Training

3.2.1 RPP Staff Qualifications

In general, qualifications for radiation protection staff are based on regulatory guidance found in NRC Regulatory Guide 8.31. However, since the HMC Grants Site is not an operational uranium mill, qualifications for the RST position (as described below) have been modified to be commensurate with the radiological hazards that are present at the Site. The minimum qualifications and training required for radiation protection staff and Site workers (including contractors) will be as follows:

• Radiation Safety Officer (RSO}

A minimum of a. 4-year degree in physical sciences, health physics, engineering or industrial hygiene with an accredited university, '.or an equivalent combination of training and relevant radiation


(


protection experience at uranium recovery (UR) facilities. Two years of relevant experience can be

considered equivalent to 1 year of academic study. At least 1 year of work experience with applied

health physics at a UR facility or similar industrial setting (this experience must include working with

radiation measurement equipment, not strictly administrative or "desk" work).

In addition, the RSO must have at least 40 hours of specialized academic training in health physics as

applicable to UR facilities, and attend RSO refresher training every 2 years. The RSO must have a

thorough working knowledge of applicable health physics principles and equipment used in the

facility, the procedures used for radiological sampling and monitoring, methods used to calculate

doses from radiological exposures, and a thorough understanding of sources of ionizing radiation at

the Site as well as applicable regulations.

• Alternate RSO (ARSO)

Minimum of a 4-year degree in physical sciences, health physics, engineering or industrial hygiene

with an accredited university, or an equivalent combination of training and relevant radiation

protection experience at uranium recovery (UR) facilities. Two years of relevant experience can be

considered equivalent to 1 year of academic study. At least 1 year of work experience with applied

health physics at a UR facility or similar industrial setting (this experience must include working with

radiation measurement equipment, not strictly administrative or "desk" work). The ARSO m,ust have

a thorough working knowledge of this RPP Manual and associated SOPs, along with an understanding

of onsite sources of radiation, basic radiation protection regulations and applicable license conditions.

• Radiation Safety Technician (RST)

The preferred credential for the RST position is a 2-year (associates) degree in physical sciences,

engineering or a health-related field with an accredited university or community college, though a

high school diploma is acceptable provided that the individual has received at least 40 hours of

relevant training in basic radiation science, radiation protection principles and applicable regulations

and at least two weeks of on-the-job training with respect to RST duties. The RST must demonstrate

sufficient working knowledge of health physics principles and proficiency in the operation of

radiological instruments used at the facility, surveying and sampling techniques, and associated

records keeping requirements.

Previous applied experience with the principles and implementation of RPPs at facilities with a

radioactive materials license may be substituted for the above qualifications at the discretion of the

RSO. Experience with uranium recovery facilities is preferred. The RST must acquire a thorough

working knowledge of all elements of this RPP Manual and associated SOPs. The RST must also attend

annual radiation protection refresher training given to all employees by the RSO. 2

2 Note that staff that work exclusively in the main office and do not access Controlled Areas of the site are not required to receive annual radiation safety training.



• Site Workers

All workers (including contractors) that require access to Controlled Areas beyond the administration building (i.e. not including purely administrative staff or visitors confined to the administrative office) must at minimum watch the prepared video briefing on general radiation safety topics and Site-specific radiation protection practices, and must have the ability to understand and adhere to technical aspects of the RPP and associated SOPs, as well as sufficient knowledge, skills and abilities to perform assigned duties and responsibilities associated with the worker's role at the Site. All regular (full time) Site employees (except purely administrative staff) will receive at least 2 hours of radiation safety refresher training'annually, including an exam (this training will be given by the RSO).

3.2.2 Radiation Safety Training

All new employees and contractors (not including purely administrative staff) will review a radiation safety awareness video (with exam) and will receive specific instruction from the RST for operational activities that require worker awareness and/or participation in elements of the RPP. On an annual basis, all regular Site personnel that work in areas of the Site other than the Administrative building will receive at least 2 hours of refresher radiation protection training regarding the following general topics:

• Site-specific radiological hazards.

• Basic radiological science concepts (physics, units, etc.).'

• Health effect.s of .radiation exposure.

• Principles of radiation protection Uustification, optimization and limitation).

• Regulatory jurisdictions and radiation protection requirements (e.g. NRC, EPA, NMED, dose limits, personnel/equipment release limits, effluent limits, spill reporting, etc.).

• RPP elements including worker exposure/dose monitoring, rad safety work rules, contamination control, instrument use, and accident and emergency response.

• Recent RPP performance including occupational exposures, accidents or unplanned releases of radioactive materials, identified Program or procedural deficiencies, corrective actions, and special radiation protection precautions based on current data and circumstances.

• Responsibilities and authorities of the pertinent regulatory agencies (NRC, EPA and NMED).

• Rights and responsibilities of workers as described in 10 CFR 19.

4. RADIATION PROTECTION CONTROLS AND MONITORING

4.1 Engineering Controls

4.1.1 Physical Controls on Access

Routine operations associated with the HMC Grants Reclamation Project generally occur in areas where radioactive byproduct materials are isolated from the environment with long-term or permanent engineering controls on containment. Two basic areas have been defined with respect to controls on access to the Site: 1) a Controlled· Area of about 1,500 acres as depicted in Figure 1, and 2) small, temporary "Restricted Areas" as needed for any Site activity where the RSO determines that the potential for radiologically significant contamination and/or worker exposures is sufficient to warrant special



; radiological controls (e.g. dosimetry, air monitoring, bioassay, and personnel/equipment release surveys).

Controlled and Restricted Areas at the Site are defined as follows:

Controlled Area (CA): An area where signage and/or physical barriers (e.g. fencing) discourage or

prevent unauthorized access to HMC property for any reason, including trespass, theft, vandalism,

exposure to physical or radiological hazards, etc.

Restricted Area: An area where access is restricted to secure licensed radioactive material from

unauthorized access, exposure, use or possession. Access to restricted areas requires specific training

on radiological hazards and appropriate controls as determined by the RSO, including at minimum_

contamination surveys for all personnel, vehicles and equipment when exiting such areas.

4.1.2 Security of Licensed Radioactive Materials

To the extent possible, all radioactive waste materials associated with past milling (e.g. tailings) or current

groundwater treatment (residual solids from water treatment and non-compliant extracted groundwater)

will be maintained in engineered repositories within the Controlled Areas depicted in Figure 1. Most

radioactive waste materials are contained within the LTP and STP, within enclosed piping or tanks, or in

lined ponds. Releases of small amounts of waste material beyond these containment systems are possible

(e.g. pipe breaks/leaks, radon flux from the, tailings piles, and overspray from turbo misters on EPl). In

the case of radioactive check sources for instrument quality control (QC) measurements, these sources

are kept in a secured safe or locked drawer when not in use by authorized personnel (the RST or RSO). An

inventory of all check sources is maintained, and inspections are performed at least annually. Annual leak

or removable activity tests are also performed on all check sources used for instrument QC

measurements.

4.2 Administrative Controls

In addition to the engineering controls described above, administrative controls will be used to help

ensure that radiation protection is optimized in accordance with ALARA principles. In some cases, both

types of controls are utilized as described below.

4.2.1 Administrative C:ontrols on Access

• Controlled Areas

In addition to physical barriers (fences), administrative controls will be used to restrict access to

Controlled Areas (Figure 1). Controlled Area fences will be posted near main access points (gates)

with "Caution Radioactive Materials" signs, and "No Trespassing" or similar signs may also be posted. 3

Only authorized and trained Site personnel are permitted within Controlled Areas without escort by

3 Per 10 CFR 20.1902 (Posting requirements), the licensee must post each area in which the quantity of licensed material that is stored or used exceeds 10 times the applicable quantities specified in appendix C to part 20 with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIOACTIVE MATERIAL(S)" or "DANGER, RADIOACTIVE MATERIAL(S)." Controlled Areas at the Site meet the criteria requiring such posting, and posting near primary access gates must be "conspicuous" and appropriate to meet this requirement.



authorized personnel. Temporary contractors and Site visitors are required to log personal

information (name, organization, date) along with Site arrival and departure times on a sign-in sheet maintained at the entrance to the Administrative Building. Egress from Controlled Areas does not

require contamination release surveys for personnel and equipment as most radioactive materials are

isolated from the active surface environment by engineering controls (i.e. the potential for

contamination during routine operations is essentially absent).

• Restricted Areas

Restricted Areas are areas that require administrative controls, and possibly additional radiological I ', < ••

monitoring, to_ limit and quantify potential exposure to radioactive materials due to non-routine

activities. Restricted Areas are delineated and enforced by the RST at the direction of the RSO. The

boundaries of Restricted Areas may be marked with stanchions and rope/caution tape, pilons, or by

other means. When physical demarcation of the Restricted Area is not practicable, these boundaries

shall be verbally communicated to workers and enforced by the RST. Restricted Areas represent areas

with temporary controls on access until the work in question has been completed (afterwards, access

will no longer be restricted provided that radiological surveys revealed no contamination of

equipment or personnel, and exposure levels in the area do not exceed any action level). 4

4.2.2 Regulatory and Administrative Limits

Administrative limits are a means of ensuring ~.ompliance with the ALARA policy to keep radiological

exposures/doses, contamination and effluent releases as low below regulatory limits as is reasonably

achievable. Typically, administrative limits are set at 10% of the regulatory limit. A summary of regulatory

and administrative limits is provided in Table 1.

4 Temporary Restricted Areas are justified by the fact that the vast majority of radioactive materials at the Site are isolated from the active surface environment and are generally not subject to potential human exposures.



Table 1: Summary of Regulatory and Administrative radiological control limits.

Limits on Occupational Exposure Levels

Occupational Dose Limits

Public Dose Limits

Environmental Effluent Liniits

Contamination Limits

External Gamma Radiation

Airborne Particulate

Radionuclides

Airborne Radon

Total Effective Dose Equivalent

(TEDE)

TEDE

External Gamma Radiation

Airborne Particulate

Radionuclides

Airborne Radon

Personnel

Equipment & Work Areas

5 mrem/hour @ 30 cm (ll

DAC: (2, 3l

U-nat: 2E-11 µCi/ml Th-230: 3E-12 µCi/ml Ra-226: 3E-10 µCi/ml

30 pCi/l (4l

5,000 mrem/yr

100 mrem/yr

50 mrem/yr (7l

Effluent Cone.: (2, 7• 81

U-nat: 9E-14 µCi/ml Th-230: 2E-14 µCi/ml Ra-226: 9E-13 µCi/ml

1.3 pCi/l above background (9l

5,000 dpm/100 cm2 (lll

1,000 dpm/100 cm 2 (12l

5,000 dpm/100 cm2 (lll

1,000 dpm/100 cm2 (12l

(ll Higher dose rates require "Radiation Area" posting (10 CFR 20.1003).

(2l Most restrictive DAC or Effluent Limiti~y solubility class is assumed applicable. 'i

(3l Applicable only for continu.ous annual occupational exposure (2,000 hrs/yr).

(4l Assuming an equilibrium fraction of 1 (unity).

i,000 µR/hr

10% of DAC: U-nat: 2E-12 µCi/ml

Th-230: 3E-13 µCi/ml Ra-226: 3E-11 µCi/ml

8.1 pCi/L (5l

500 mrem/yr (10% of regulatory limit)

100 mrem/yr (5l

5 mrem/yr (10% of regulatory limit)

10% of Effluent Cone.: U-nat: 9E-15 µCi/ml

Th-230: 2E-15 µCi/ml Ra-226: 9E-14 µCi/ml

1 pCi/l above background (10)

Background

200 dpm/100 cm2,

25 µR/h r (l3l

(5l IAEA recommended action level (equivalent to 300 Bq/ m3) to limit public dose to 100 mrem/yr.

(5l Due to a recognized non-representative background radon location (low bias), 10% of the regulatory limit is not a reasonably achievable administrative limit.

(7) Considered a "limit" only if compliance with public dose limits is demonstrated based on the method specified in 10 CFR 20.1302 (2).

(5l Assumed to result in 50 mrem/yr public dose.

(9l Assuming an equilibrium fraction of 20%, and 75% occupancy.

(lo) Assuming an equilibrium fraction of 20%, and 100% occupancy (an admin. limit of 10% of the regulatory limit is impractical and unlikely to be measurable above variability in background).

(lll Fixed plus removable gross alpha (or beta) activity above background (NRC Reg Guide 8.30).

(l2l Removable gross alpha (or beta) surface activity above background (NRC Reg Guide 8.30).

(13l Removable gross alpha (or beta) surface activity and gamma radiation above background (SOP 12).



4.2.3 Radiation Safety Work Rules

All workers and visitors will be instructed in the importance of adherence to the below radiation safety work rules. These work rules will be enforced by the RST, RSO and Site Closure Manager.

1. Personal Hygiene - all personnel must wash hands before eating or drinking in the designated lunch room or offsite after leaving Restricted Areas.

2. Workspace Organization and Cleanliness - all personnel are required to keep work areas clean and well organized, particularly in Controlle~ Areas where radioactive materials may be present.

3. Eating, Drinking and Tobacco Use - eating and tobacco use are prohibited within Controlled or Restricted Areas, except in designated locations (e.g. eating is permitted in the lunch room, but only after washing hands). Drinking of water or non-alcoholic beverages in Controlled Areas is allowed to prevent dehydration, but care must be taken to use only single-use containers (i.e. commercial bottled water in plastic bottles with a screw-type lid) to help avoid soiling of containers and accidental ingestic;:,n of trace amounts of contaminated material.

4. Personal Protective Equipment - standard personal protective equipment (PPE) is specified in Policy Guidance Document (PGD) 14 in the HMC Manual of Standard Practices and in individual SOPS, as appropriate. Disposable latex-type gloves will be worn when working with environmental samples, chemicals, transferring solutions or Zeolite media, or in any other circumstance involving the handling of materials with potential for radiological contamination.

5. Dosimeter Usage - As may be required by RWPs or at the discretion of the RSO for tasks that could involve external exposure rates> 1000 µR/hr (See Table 3). External doses to workers may be measured with optically stimulated luminescent (OSL) dosimeters or similar integrating dosimeters (e.g. "pocket" ionization chambers or digital solid-state dosimeters) or estimated based on measured exposure rates and occupancy times at the discretion of the RSO. The RSO is responsible for tracking external doses for workers, but it is the responsibility of workers to wear assigned dosimeters and report any badge loss to the Rsr.')nd/or RSO.

6. Bioassay Sampling - Bioassay (urinalysis) sampling is required as part of the pre-employment process for all regular HMC employees that will work in Controlled Areas (entry bi.oassay), and again at termination of employment at the Site (exit bioassay). 5 Additionally, bioassay sampling may be required by RWPs or otherwise at the discretion of the RSO based on potential for intake (e.g. physically handling or working with tailings or solid residues from the evaporation ponds, a reasonable probability of average airborne uranium concentrations exceeding 10 % of the DAC, or if surface contamination is detected on the face of a worker). Additional detail on the bioassay program is provided in Section 4.4.2.3.

5 It is recognized that gaining cooperation of terminated employees to give an exit bioassay sample may not be possible. Entry/exit bioassay may also be required by the RSO for contractors hired to perform short-term work in Restricted Areas under a RWP.


t \


7. Breathing Zone Air Monitoring - at the discretion of the RSO, breathing zone (BZ) air monitoring

with lapel-type samplers will be required for select workers, primarily those engaged in projects

with significant potential for exposure to airborne particulate radionuclides under a RWP.

Applicable procedures are given in SOP 11 as developed based on the recommendations provided

in NRC Regulatory Guide 8.25, Sections 3 and 5.

8. Authorized Access to Controlled or Restricted Areas - only Site management and authorized and

trained workers are allowed unescorted access to Controlled or Restricted Areas. Contractors

who have received the training described in Section 3.2 .. 2 are permitted unescorted access to

Controlled and Restricted areas.

9. Personnel and Equipment Release Surveys - all personnel must perform exit contamination

surveys before leaving Restricted Areas, and no equipment, vehicles or materials may be released

from these areas unless radiological surveys (conducted 'by the RST) verify compliance with

release limits for contamination associated with uranium decay series radionuclides (see

Table 1).6

10. Decontamination - any detected contamination on personnel, equipment, vehicles or designated

"clean area" workspaces shall be decontaminated in accordance with SOP 12 provisions.

11.· Reporting of Potential Radiological Hazards - Site personnel must report activities suspected of

having the potential for significant exposure to radioactive materials (e.g. tailings, solid or liquid

water treatment residuals) to the RST. This information will be incorporated into the Field Level

Risk Assessment (FLRA) for the activity (see SOP 2), and the RSO will review the FLRA for a

determination of the need for any special radiological controls that may be needed (e.g. under a

RWP). All personnel have the authority to stop any work activity if radiological hazards are

identified that have not already been identified and evaluated by the RSO and/or RST.

12. Reporting of Accidents and Equipment Malfunctions - all accidents, equipment malfunctions or

failure to follow procedures that has (or may have) resulted in unplanned radiological exposures

or releases of radioactive materials to the environment must be reported to the RSO immediately.

4.2.4 Standard Operating Procedures for Radiation Protection

Radiation protection staff and workers (where applicable) will follow approved standard operating

procedures (SOPs) for radiation protection under this RPP· Manual. A current listing of respective SOP

titles is given in Table 2, and these SOPs are included in Appendix A to this RPP Manual.

6 Note that there are some potentially contaminated Site materials and used equipment that are currently stored in "boneyards" located within Controlled Areas (e.g. piping, pumps, etc.). The planned disposition or future use of these materials has not. been established at this time. If these materials are to be released from the Site for unrestricted future use, they will need to be surveyed for radiological surface contamination to verify compliance with release limits (Table 1), even though they are not located in "Restricted Areas" as defined in this RPP.



SOP 11 Radiological Air Monitoring for Occupational Exposures (HP-1) 2 10-15-2018 SOP 12 Radiological Contamination Surveys (HP-2) 14 10-15-2018





SOP 20 Environmental Monitoring Except Groundwater (EM-2) 17 09-09-2018 SOP 21 Spill Response and Reporting Procedure (EM-4) 3 10-15-2018 SOP 22 On-Site Disposal of Radiologically-Impacted Waste 1 10-20-2018 SOP 23 Evaporation Pond Operations 1 10-15-2018 SOP 33 HMC ALARA Procedure (HP-6) 1 07-12-1993

4.2.5 Radiation Work Permits

At the discretion of the RSO, a Radiation Work Permit (RWP) will be issued for all work or nonroutine maintenance jobs where the potential for significant exposure to radioactive material exists and for which no standard written procedure already exists. RWPs will be approved by the RSO (or ARSO) and shall describe, at a minimum, the following:

• The scope of work to be performed.

• A summary description of the RSO's evaluation and determination that a RWP is needed.

• Any precautions necessary to reduce exposure to uranium and it progeny.

• Radiological monitoring and sampling that is necessary prior, during and following completion of the work.

Examples may include spill mitigation and equipment repair, non-routine maintenance, manual transfer of sludge or contaminated drill cuttings from tailings or contaminated areas to evaporation ponds, etc. The RSO will determine the need for a RWP and what radiological controls "re appropriate as described in SOP-18, Procedure for Implementing a Radiation Work Permit.

4.2.6 Tracking of Radioactive Materials and Sources of Radiation

Up-to-date records will be maintained of all known check sources, both in storage and those routinely used for instrument calibrations or QC function checks. All check sources will be kept in a locked safe, or in locked drawers under the control of the RST. Leak tests will be conducted annually on all routinely used check sources, or for any stored source before being brought into use. Radioactive waste materials at the Site (e.g. tailings buried in the impoundments, pond sludge or evaporative salts, contaminated drill cuttings, etc.) will not be tracked or inventoried as their presence is generally known and approximate volumes and total activities can be estimated. However, all potentially contaminated waste materials disposed in the waste disposal trenches on the STP must be characterized in accordance with SOP 22 (e.g.


\

( \_ __ ,


\ .. _) dates, descriptions, photos and representative contamination surveys) and documented to help inform

the final cover design.

4.2.7 Inspections and Audits

Periodic inspections and audits associated with the RPP will be conducted to ensure compliance with the

specifications o.f this RPP Manual, applicable license conditions, and all applicable regulations. These

administrative controls are used to identify deficiencies, develop corrective actions, and determine any

necessary modifications to this RPP Manual and associated SOPs to ensure continued compliance with all

regulatory requirements and to further improve overall radiation safety performance. Proper

implementation of individual RPP elements requires continual inspection by the RST, and the RSO must

be notified of any deviations or problems. ALARA Audits are conducted monthly by the RSO (or ARSO),

and annually by a qualified independent contractor in accordance with Regulatory Guide 8.31 Sections

2.3.2 and 2.3.3 respectively. Summary findings of inspections/audits and any recommendations will be

documented along with any corrective actions. The NRC also inspects elements of the RPP, typically on

an annual or semiannual basis.

4.3 Contamination Control

Contamination control will be achieved by 1) following Radiation Safety Work _Rules (Section 4.2.3), 2)

regularly inspecting and performing maintenance on operating equipment to ensure proper function, 3)

routine surveys of the surfaces of structures, equipment and personnel with radiation detection

instruments, 4) use of proper decontamination procedures, and S) records keeping and data analysis to

identify trends and develop corrective actions as needed to keep contamination ALARA. Details of these

elements of the Contamination Control Program are provided in the following Sub-Sections and in SOP 12,

Radiological Contamination Surveys and Decontamination.

4.3.1 Inspection and Mainienance of Operational Equipment

Operational equipment and process systems (e.g. groundwater pumps, piping, RO equipment and pond

operations) that could result in an unplanned release of liquids or solids containing radioactive byproduct

material are visual!Y inspected by the RST during routine operational activities, as specified in specific

SOPs, and as otherwise directed by the Site Closure Manager. For example, inspection of evaporation

pond operations is performed/documented on a daily schedule in accordance with SOP 23. Maintenance

occurs at regularly scheduled intervals and as necessitated by any performance issues, including

unplanned release/contamination events. These inspections are intended to ensur(;! that systems are

sufficiently maintained and operated to minimize the potential for unplanned release of licensed

materials and to identify corrective actions as needed to ensure compliance with all regulatory

requirements and to further improve the control and containment of liquids/solids that may contain

radioactive constituents. These inspections and any recommendations are documented along with any

follow-up modifications to the SOPs and/or implementation of any corrective actions.



4.3.2 Workplace Contamination Surveys

NRC regulations provide no specific limit on surface contamination levels in restricted work areas (NRC Regulatory Guide 8.30, Rev. 1, Section 2.5). NRC staff considers surface contamination levels of 10·3

µCi/cm2 acceptable to meet the ALARA concept in UR facilities, which equates to a gross alpha or beta activity of 220,000 dpm/100 cm2

. Homestake procedures specify 200 dpm/100 cm2 as the administrative limit for surface contamination in work areas (see SOP 12). Monthly surveys will be conducted in office and administrative areas and results will be documented in accordance SOP 12 specifications.

4.3.3 Equipment Release Surveys

Like work area contamination surveys, surveys performed to release equipment and Vehicles from Restricted Areas will be generally be conducted with a dual channel alpha/beta radiation detector (Section 4.3.6). Methods to be used will be consistent with SOP 12 specifications based on the recommendations provided in Regulatory Guide 8.30, Section 2.7. The regulatory and administrative limits given in Table 1 will be used to qualify any equipment or vehicles for release from Restricted Areas. Routine surveys of vehicles or equipment leaving the Controlled Areas of the Site need not be conducted unless the RSO has determined that a Restricted Area designation is appropriate for a given work task.

4.3.4 Personnel Exit Surveys

Exit surveys for personnel leaving the Restricted Area will·be made with a zinc sulfide alpha scintillation instrument (Section 4.3.6) in accordance with SOP 12 specifications followin·g the recommendations of Regulatory Guide 8.30, Section 2.6. Personnel working in a Restricted Area under a RWP are to scan their clothing, exposed skin, and' shoes upon leaving the Area and document results on the Personnel Contamination Survey Form (EDF-15). Although NRC standards for releasing personnel with contamination on skin or clothing are the same as for equipment release surveys (Table 1), the· administrative limit for personnel exit surveys will be set at values consistent with normal background levels (i.e. no measurable contamination). In this case, the administrative limit will be treated as a primary clearance criterion. In cases where this criterion cannot be met, the regulatory limit (Table 1) will be applied as a secondary standard since associated doses would be very low.

4.3.5 Decontamination

Contamination of structures, equipment or personnel in excess of applicable limits as specified in the preceding Sections will require decontamination in accordance with the decontamination procedures outlined in SOP 12 (Section 7). Decontamination procedures for personnel will generally consist of brushing off visible accumulations of dirt/mud, and if needed to meet the release criterion, washing the affected areas with water and/or mild soap as appropriate at the boundary of the Restricted Area. For equipment and vehicles, a special decontamination area, likely to be located near one of the water towers, will include a pressure washer and coarse gravel to "plate" the decontamination pad and contain wash-down water and residues prior to cleanup and transfer to the radiological waste disposal trench area on the STP. Secondary containment of the decontamination pad will be provided, and decontamination residues may periodically require maintenance cleaning prior to final decommissioning ofthe pad (when closure of the STP with the final radon barrier placement is eminent).


1\·

_.,../

Radiation Protection Program Manual

4.3.6 Contamination Survey Instruments and Applications

Surface contamination surveys will be conducted by the RST with

a dual channel alpha/beta scintillation instrument pairing

(Figure 3) to permit detection of alpha and/or beta radioactivity on

the surfaces of work areas, equipment and personnel. 7 If

significant contamination is present, the count rate indicated by

the ratemeter will become elevated while scanning close to the

surface across the affected area, and a static, 1-minute scaler

count will be performed in accordance with SOP 12 to evaluate

surface activity relative to applicable release limits (Table 1).

If detected, surface contamination will be cleaned

(decontaminated) in accordance with SOP 12, Section 7 and

follow-up measurements will be made for comparison against

applicable release limits, and "swipe" samples may be taken to

test for removable contamination with special absorbent pads

that are subsequently measured in a special counting tray with an

alpha/beta counter (Figure 4) .8 Designated eating/drinking or

"clean areas" inside of the Admin Building will be surveyed

monthly (see Section 4.3.2) for fixed and removable surface

contamination and must meet applicable surface activity limits

(Table 1).

Exit surveys for personnel leaving Restricted Areas will be

performed with the same alpha/beta scintillation instrument used

for other contamination surveys (Figure 3) in accordance with SOP

12, Section 6 and personnel will be trained accordingly. A target

release criterion representing the maximum background reading

for each specific instrument will be determined by the RST and

specified on the exit survey form to be filled out by all personnel

leaving Restricted Areas.

HMC Grants Reclamation Project

Figure 3: Ludlum 43-93 alpha/beta detector with Model 2360 ratemeter and scaler.

Figure 4: Ludlum Model 3030 sample counter with internal alpha/beta detectors and sample holder chamber.

7 All instrument types and models described in this RPP are based on instrumentation commonly used at uranium recovery facilities in the U.S. Actual instrument manufacturers and models selected for use at the Grants Reclamation Project may vary but will be functionally equivalent to the instruments ind icated in this RPP. The instruments and procedures specified in the previous revision of SOP 12 (Revision 12) are still acceptable, but Revision 13 of SOP 12, as provided in Appendix A of this Manual, has been revised to accommodate new alpha/beta scanning instruments that will be acquired by HMC to improve detection sensitivity and to simpl ify contam ination survey procedures.

8 Note that swipe testing is not necessary if scanning shows that fixed + removable act ivity is below the removable (only) limit. However, swipe samples must always be taken for major equipment to be released for unrestricted future use.



4.3.7 Response to Accidental Spills or Releases

When a significant spill and/or unauthorized discharge is discovered, the need for an emergency response

"SWIMS" process as outlined below and as described in the Emergency Response Procedure (SOP-1) must

be determined quickly and executed without delay when warranted . The degree of urgency in spill

response and the nature of health and safety precautions required depend on the type of hazardous

material, volume of material released, and circumstances that could present immediately hazardous

exposure conditions. Spills of highly hazardous chemicals (e .g. acids, caustic, etc.) shall always be treated

with SWIMS protocols:

Stop the leak

Warn others

Isolate the area

Minimize exposure

Standby for help to arrive

In general, leaks or spills of radiologically impacted groundwater are unlikely to warrant SWIMS measures

as described above for emergency response situations. However, all unplanned groundwater releases

shall at minimum be stopped, contained, documented and reported to the Closure Manager and/or RSO.

In addition, immediate due diligence actions as described in HM C's Accident I Incident Reporting Policy

(PDG-5) shall also be followed. Further details of the procedures for response and

documentation/reporting of spills, leaks or other unplanned releases of radioactive or other hazardous

materials are provided in SOP 21 (Spill Response and Reporting).

4.4 Limitation of Radiological Dose

Individual occupational radiation exposure monitoring is required under the conditions specified in 10 CFR

20.1502. Recent and historical occupational exposure data has consistently indicated the conditions

requiring individual monitoring as defined in 10 CFR 20.1502 are not met at the HMC Site . A supporting

report for an occupational exposure monitoring study directed by the RSO in 2018 (ERG, 2018) is provided

in Appendix B. Accordingly, as described elsewhere in this manual, use of personnel dosimeters (OSLs),

air sampling for uranium and/or progeny and requirements for bioassay (urinalysis) will be based at the

discretion of the RSO on specific conditions or circumstances that warrant radiological controls (e.g. RWPs,

tasks may involve external exposure rates~ 1000 µR/hr, air concentrations~ 10 % of the applicable DAC,

or detection of contamination on the face) .

In the event that a pregnant female worker is asked to participate in any activity determined by the RSO

to warrant radiological exposure monitoring, the worker has a right to declare her pregnancy and receive

appropriate radiological monitoring for the remaining duration of the gestation period. This notification

must be made in writing to the Closure Manager whom will in turn notify the RSO. The dose limit to the

fetus is 500 mrem for the duration of the pregnancy, equivalent to 50 mrem/month . In this circumstance,

the declared pregnant worker will be issued two dosimeter badges, one to be worn as normal and the

other to be worn at waist level near the position of the fetus. Both badges will be analyzed on a monthly

basis . At the discretion of the RSO or by request, the worker will also be issued a BZ air sampler for the



duration of the work activities in question. The RSO will estimate dose to the fetus based on the resulting

radiological monitoring data.

4.4.1 Regulatory and Administrative Dose Limits

Regulatory and Administrative Dose Limits are summarized in Table 1. A detailed accounting of NRC

regulatory dose limits for uranium recovery facilities is given in Table 3. 9 These limits are further discussed

in SOP 13 (Calculation of Radiation Doses to Personnel).

4.4.2 Occupational Dose Monitoring

Individual occupational exposure monitoring and assessment will be performed for all HMC e,mployees

and contractors working on the HMC Grants site under (1) a RWP approved by the RSO that requires use

of individual dosimetry, breathing zone sampling or bioassay, or (2) for any other reason at the discretion

of the RSO. The components of the Occupational Monitoring Program are shown in Table 4. For

contractors, consultants, and other vendors who are expected to perform routine work within Controlled

Areas ofthe Site (Figure 1), completion of the site's radiation training video, ALARA training, and Hazards

Briefing Form are required. Once completed, an OSL dosimeter badge will be issued where applicable as

described above.

4.4.2.1 Dosimetry Monitoring

All HMC employees and contractors working on the HMC Grants site will be issued OSL dosimeters if

required under the conditions specified in Section 4.4.2 above. Employees and vendors who provide

services to the Site, but only do so (or are only expected to do so) within the administrative areas (e.g. the

main office) do not require dosimetry. For each task or project requiring dosimetry, OSL badges are

returned to the manufacturer on a quarterly basis for analysis and reporting. The net accumulated deep ·

dose equivalent (DDE), calculated as the issued badge DOE minus the control badge ODE, is documented

to represent external occupational dose.

Personnel OSL dosimeters, when required by the RSO, will be exchanged and evaluated in accordance

with· SOP 13, Procedure for Calculating Radiation Doses to Personnel. Currently, there are no

occupationally exposed locations within Controlled Areas with gamma exposure rates in excess of 500

µR/h (Figure 2). In the event that gamma radiation readings in any future work area exceed 1,000 µR/h,

this will automatically trigger dosimetry for all exposed personnel.10 Pocket ion chamber dosimeters or

digital electronic dosimeters may be used for such non-routine monitoring. Alternatively, external doses

may be calculated by the RSO based on documented occupancy time and measured exposure rates in

subject areas.

9 Note that there is an additional dose limit of 500 mrem to the fetus during pregnancy that will be observed in accordance with RG 8.13, Instruction Concerning Prenatal Radiation Exposure.

10 Exposure to a gamma field of 1,000 µR/hr for 8 hours per day over a two-month period would theoretically result in an ambient dose equivalent (as measured with OSL dosimeters) that approaches the 500 mrem/yr dose threshold which requires monitoring under 10 CFR 20.1502.



Table 3: Regulatory Dose limits, reproduced from NRC Regulatory Guide 8.30 (Revision 1, 2002).

Dose Limits and Associated Terminology

Type ofExposure

Total \Vhole Body Dose (Sum of External and Internal)

External Dose

Internal Whole Body Dose

Total Organ Dose (Sum ofExtemal and Internal)

Internal Organ Dose

Skin Dose

Extremity Dose

Eye Dose

10 CFR Part 20 Designation

Total Effective Dose Equivalent (TEDE) TEDE = DDE+ CEDE

Deep Dose Equivalent (DDE)

Committed Effective Dose Equivalent (CEDE)

Total Organ Dose Equivalent (TODE) TODE= DDE + CDE

Committed Dose Equival~ (CDE)

Shallow Dose Equivalent (SDE), Skin of Whole Body

Shallow Dose Equivalent (SDE), :Maximum Extremity

Eye Dose Equivalent to Lens of the Eye (IDE)

Dose Limit

5rem/year

(a)

(a)

50rem/year

(a)

50rem/year

_50 rem/year

15 rem/year

(a) Included in limits for .. nole body and individual organs. In the absence of any internal exposure, external dose is limited to 5 rem per year. In the absence of any external exposure, internal exposure is limited to 2000 DAC-hours per year or 1 annual limit on intake (ALI) (50 rem/yr non-stochastic, 5 rem/yr stochastic). ·

Table 4: Occupational exposure/dose monitoring requirements under LC 10 (adapted from Table 3 of the 1993 license amendment request).

Lapel Personal As required by RWP or As required by RWP SOP 11 (HP-1)

As required by RWP or at Alpha, U-nat

Air Sample at RSO discretion (2-3 L/min or equivalent) RSO discretion

Lapel Air Sampler All units in current use N/A

Manufacturer As required by RWP Flow rate Calibration Specifications

Release of As required by RWP

Potentially Contaminated SOP 12 (HP-4) As required by RWP Alpha, beta gamma Equipment Equipment and Materials

ALARA N/A As required by RSO HP-6' N/A As required by RSO

Respiratory As required by RWP As required by RWP N/A (HP-7) 8 N/A N/A Protection '

Bioassay Entry/exit samples and

As required by RWP SOP 14 (HP-8) Entry/exit samples and as

U-nat in urine as required by RWP required by RWP

Instrument Variable

Radiation Detection SOP 16 (HP-10) Annually N/A Calibration Instruments in use

Dosimetry As required by RWP or

Personnel SOP 13 (HP-3) As required by RWP or at

Gamma at RSO discretion RSO discretion

Personnel As required by RWP As required by RWP SOP 12 (HP-12) As required by RWP Alpha Contamination

Radiation Taught by RSO or Initial & annual refresher for

Training class & As required HMC site personnel that work in Protection Training RST designee. c Controlled Areas.

written test

'In 2018 HP-6 was added to the.current list of SOPs in the Radiation Protection Program (RPP) Manual as SOP 33.

• Respiratory protection not expected to be necessary for current site decommissioning and reclamation activities. Procedure HP-7 has been inactivated and is not

included in current RPP Manual or in the HMC Manual of Standard Practices. ·

c Annual refresher training is given by the RSO for all regular HMC employees that work in Controlled Areas. Temporary contractors are generally trained by the

Radiation Safety Technician (RST) as a designee of the RSO, often with the aid of a previously developed radiation safety video followed by testing.



, 4.4.2.2 Occupational Air Monitoring \._./

Airborne Particulate Radionuclides

Occupational air monitoring for long-lived radionuclides was

discontinued in 2010 based on several years of high-volume

air monitoring on top of the LTP. In late 2017 the NRC

requested that HMC conduct a new occupational exposure

monitoring study to better characterize the potential for

occupational doses to workers under current operational

circumstances and conditions. The results of this new study

(ERG, 2018; see Appendix B) demonstrate that routine

occupational monitoring for radiological exposures is not

required under 10 CFR 20.1502 criteria. 11 This determination

is based on 1) an estimated maximum potential Total Effective

Dose Equivalent (TEDE) to any worker on the order of 53

mrem/yr, 2) potential intakes well below 10% of the annual

limit on intake (ALI), and 3) average air concentrations well

below 10% of the derived air concentration (DAC) for

Table 5: Relevant o.ccupational intake limits

from 10 CFR 20 Appendix B.

u:nat Th-230 Ra-226

(µCi) (µCi)' . (µCi)

NALl;ngest* 10 4 2

SALl;ngest* 20 9 5

NALl1nhal* 1 0.006

SALl;nhal* 2 0.02 0.6

U-nat-". , Th-230 Ra-226·

(µCi/n_iL) . (µCl/mL)·. (µCi/m°LJ ,· . DAC(day) SE-10

DAC(week) 3E-10 3E-12 3E-10

DAC(year) 2E-11 6E-12

NAU =Non-stochastic AU

SAU =Stochastic AU

* Most restrictive solubllity class assumed: day for U-nat,

week forTh-230 and Ra-226

applicable radionuclides as given in 10 CFR 20, Appendix B. Applicable ALI and DAC limits for relevant

radionuclides are compiled in Table 5. Based on the results of this study, routine occupational radiation

exposure monitoring will be discontinued, though non-routine monitoring will continue at the discretion

of the RSO (e.g. under a RWP) in accordance with applicable SOPs.

Airborne Radon

Radon-222 (Rn-222) gas is widely known as an important radionuclide with respect to radiation dose, but

it is the short-lived decay products of radon (progeny) that impart most of the dose via the inhalation

pathway. Occupational DAC limits given in 10 CFR 20 Appendix B range from 4,000 pCi/L for radon gas

without progeny present, to 30 pCi/L when the concentration of progeny is in secular equilibrium with

Rn-222 gas (the latter value is equivalent to a DAC of 0.33 "working level" when only the progeny

concentration is measured).

The International Atomic Energy Agency (IAEA) currently recommends an action level of 27 pCi/L (1,000

Bq/m3) for indoor radon gas in the workplace, and 8.1 pCi/L (300 Bq/m3

) for members of the public,

assuming a progeny/gas equilibrium fraction of 0.4 (IAEA, 2014). Absent robust data on indoor or outdoor

equilibrium fractions at the Site, the administrative action level for radon gas will be set at 8.1 pCi/L since

this is the action level recommended by IAEA to limit public dose from indoor radon to 100 mrem/yr (the

public dose limit under NRC regulations). An equilibrium fraction of 0.4 is conservative relative to relative

to the 0.34 maximum average equilibrium ratio measured at the Site during the 2018 occupational

radiation exposure monitoring study (ERG, 2018).

11 Environmental monitoring for public dose at Site boundaries will continue until the RML is terminated.


C


Because these limits are based on long-term average concentrations, indoor radon levels (in the RO plant and main office building) will be monitored with time-integrating alpha track-etch detectors as detailed in SOP 11 (Air Monitoring). In the highly unlikely event that the administrative limit for indoor radon gas is exceeded (see the 2018 occupational radiation exposure study report in Appendix B), follow-up radon progeny air sampling may be directed by the RSO, and an evaluation of potential sources and adequacy of ventilation or other factors will be conducted to determine if there are potential corrective actions that could be taken to either lower radon concentrations or to limit worker occupancy times at subject locations. Should radon progeny measurements become necessary, the Kusnetz method as specified in SOP 11 will be used.

4.4.2.3 Bioassay

Urine bioassay samples will be collected in accordance with the procedures given in SOP 14, Procedure for Bioassay Sample Collection. This includes "entry" bioassay sampling prior to employment to establish initial baseline uranium values, "exit''. bioassay sampling upon termination of employment for comparison, and special bioassay sampling if appropriate at the discretion of the RSO. Circumstances for special bioassay sampling may include working with tailings or pond sludge or evaporative salts under a RWP, or if there is evidence that continual exposure to average air concentrations exceeding 10% of the DAC may have occurred.

If a bioassay result exceeds the lab's 5 µg/ml detection limit for uranium, the lab has been instructed to immediately notify the RSO, and a follow-up investigation will be conducted including additional bioassay sampling at the discretion of the RSO. Note that laboratory analysis or sample contamination issues are not uncommon, and follow-up bioassay samples may not be possible for temporary contractors that are no longer onsite by the time results are known.

If any bioassay sampling result exceeds 15 µg/ml, the responses recommended in Table A-1 of NRC Regulatory Guide 8.22 (Revision 2, 2014) will be followed. Unless the approximate time of a potential intake of uranium is known (e.g. if on a given day an air monitoring sample shows unusually high airborne radioactivity levels or contamination on the face is discovered), calculation of the amount of uranium intake (based on published intake retention fractions) may be grossly inaccurate. However, because special bioassay sampling is limited to RWPs at the discretion of the RSO, and since most RWPs are relatively short in duration (e.g.< 1 mon~h), special bioassay samples are considered sufficient to evaluate compliance with NRC Regulatory Guide 8.22 (Revision 2, 2014) action level criteria and the NRC's occupational intake limit of 10 mg of soluble uranium per week (per 10 CFR 20.1201).

As noted previously in this RPP Manual and as documented in previous annual ALARA Audit reports, bioassay results have consistently remained below the 5 µg/ml detection limit for uranium for many years, and semi-annual sampling provides data of little value unless the date of the suspected intake is known. Accordingly, semiannual bioassay sampling has been discontinued.

4.4.2.4 Records Keeping and Reporting

Per the requirements of 10 CFR 20.2103, all occupational radiation monitoring data used in the evaluation of doses to workers will be retained by HMC until the license is terminated by the NRC. Records of


)


contamination surveys will be retained by HMC for at least three years after the record is made.

Occupational radiation monitoring data and associated dose estimates for workers, along with any NRC

or internal inspection findings, will be summarized in the Annual ALARA Audit report to be submitted to

the NRC by March 31 of the following year.

4.5 Effluent Controls

The NRC defines "effluent" as "Liquid or· gaseous waste containing plant-related, licensed radioactive

material, emitted at the boundary of the facility (e.g., buildings, end-of.pipe, stack, or container) as I

described in the final safety analysis report {FSAR)" NRC Regulatory Guide 1.21, 2009. "Effluent discharge"

is defined as "The portion of an effluent release that reaches an unrestricted area".

The primary effluents from the HMC Grants Reclamation Project Site include migration of impacted

groundwater beyond Controlled areas, and release of radon gas from the LTP and STP that may increase

ambient radon concentrations above background levels beyond Controlled Areas. Mechanical

acceleration of process water evaporation (e.g. with Turbo Misters on EPl) is a source of releases of

particulate radionuclides to air (in the form of liquid aerosols), but these releases are not expected to

measurably impact environmental media (air, water, soil or vegetation) beyond Controlled Areas of the

Site.

The primary controls on effluents are engineering based, including capture and treatment of impacted

groundwater. under the Corrective Action Plan (CAP), and interim cover materials (e.g. clean soil) placed

above mill tailings contained in the LTP and STP (to prevent release of windblown tailings and reduce

radon gas emissions). Administrative controls on effluent releases include environmental monitoring and

comparison of results against regulatory and administrative limits.

4.5.1 Radiological Waste Management

Because the Site is no longer an operational uranium mill, the total inventory of radioactivity in wastes at

the Site is static. While no new radioactive wastes are being generated at the Site, the spatial distribution

of existing radioactive wastes is changing over time as radionuclides in impacted groundwater are

removed and consolidated in the form of residual solids (sludge and evaporative salts) within the

collection and evaporation ponds. ·1n addition, contaminated equipment and operational wastes are being

buried in waste disposal trenches on the STP. Because management of radioactive wastes (including

handling, transfer and containment) can impact effluent releases beyond Controlled Areas, this aspect of

Site operations is subject to consistency with ALARA principles.

4.5.1.1 Inspection of Process and Waste Containment Systems

Per SOP 23 (Evaporation Pond Operations), pond conditions are visually inspected at least weekly,

including documentation ofwater/freeboard levels, fluid volumes discharged into or transferred between

ponds, and inspection of leak detection systems. Tailings impoundments are also visually inspected at

least weekly, and the Professional Engineer of record formally inspects and documents the structural



integrity of the impoundments on an annual basis. Water treatment systems (RO and Zeolite plants) are also inspected periodically in accordance with applicable SOPs.

4.5.2 Limits on Radiological Releases to the Environment

Limits on gaseous effluent releases to the environment for site-specific radionuclides are summarized Table 1 of this RPP, based on "effluent concentrations" provided in 10 CFR 20 Appendix B. 12 Because these values are benchmarked against a hypothetical radiation dose of 50 mrem/yr, they provide a conservative means for direct evaluation of individual environmental monitoring parameters in terms of dose-based limits on effluent releases from the facility. The overall public dose limit for effluent releases from all sources of radiological emissions from the Site is 100 mrem/yr at Controlled Area boundaries. Public dose estimation at the HMC Grants facility is based on measured above-background concentrations of airborne radionuclides and ambient external dose rates, with semiannual reporting per 10 CFR 40.65 requirements (due to NRC by March 31 and September 30). In addition, 10 CFR 40 Appendix A, Criterion 6 gives a numeric limit on radon releases from the tailings impoundments (20 pCi/m2-s), and in accordance with LC 36(e), the average radon flux from the STP and the top of the LTP are measured directly on an annual basis (these values are also provided in semiannual reports required by 10 CFR 40.65).

4.6 Environmental Monitoring and Public dose

4.6.1 Monitored Environmental Media and Program Design

Because contaminated soil cleanup at the Site is largely completed, the primary environmental media that are monitored for radiological effluents are air and groundwater. Groundwater sampling is conducted in accordance with SOP 17. All other environmental monitoring, which includes sampling for long-lived radionuclide concentrations in air particulates, ambient radon gas levels, and gamma radiation dose rates, is conducted in accordance with SOP 20 specifications (Table 6).

4.6.2 Radon Flux Measurements

In addition to the above effluen.t and environmental monitoring parameters, average radon flux rates from the top of the LTP and accessible portions of the STP are measured on an annual basis in accordance with LC 36(E) using methods consistent with EPA Method 115. Radon flux measurements provide direct quantification of gaseous radon releases from the source, though associated effluent concentrations are measured at or near the boundaries of the Controlled Areas as shown in Figure 1 and Table 6. Results of all environmental monitoring parameters are reported in semiannual Effluent and Environmental Monitoring Reports in accordance with 10 CFR 40.65 and LC 36(e) requirements.

12 Note that "effluent concentrations" in Appendix B of 10 CFR 20 are considered "limits" only if compliance with public dose limits is demonstrated based on the method specified in 10 CFR 20.1302 (2).


1

\ ..._ __ ,/

I ,~·


Table 6: Environmental Monitoring Program excluding Groundwater Monitoring (reproduced from SOP 20).

, ' ' -Type of· Number Locatic:ms Method Frequ_ency

Analytical Sample Parameters

HMC1, HMC1A, HMC2, and HMC3 at or near the site Weekly filter change, or as

Natural Uranium, Air 4 boundary in sectors that have Continuous needed_ Samples

Radium-226, Thorium-Particulates the highest predicted (High Vol) composited and analyzed

230 concentrations of radioactive quarterly_ airborne particulates.

Weekly filter change, or as Natural Uranium, Air 2

HMC4 and HMC5 at nearest Continuous needed. Samples Radium-226, Thorium-Particulates occupied residences (High Vol.) composited and analyzed 230

quarterly.

Air HMC6 as a background Continuous Weekly filter change, or as

Natural Uranium, 1 needed. Samples

Particulates location (High Vol) composited and analyzed Radium-226, Thorium-

quarterly. 230

2 Each at the locations described in Air - Particulates, Continuous

Radon Gas 30 HMC7 on south boundary, Track-etch

Quarterly Rn-222 HMC10FF, and HMC16 as a backoround location

Direct Locations described in Air - Continuous Radiation

8+2TC Particulates and HMC16 as a OSL Semi-Annual Gamma Exposure Rate background location

NOTE: The total number of OSL detectors needed for direct radiation measurements is 10. This includes the 8 needed for deployment on site and 2 transit controls (TC).

4.6.3 Public Dose Determination

The primary criterion for limitation of effluent releases from the facility is the 100 mrem/yr public dose

limit at Controlled Area boundaries. Public dose estimation is based on effluent and environmental

monitoring data collected and reported per 10 CFR 40.65 requirements, including semi-annual reporting

(due to NRC by March 31 and September 30). Dose to the nearest member of the public is estimated

based on results at environmental monitoring locations HMC-4 and HMC-5 based on proximity to the

nearest resident.

4.6.3.1 Special Considerations/or Public Dose Estimation

Only terrestrial effluents (airborne radionuclides and sources of external gamma radiation) are considered

in public dose estimates as local residents obtain water for domestic use only from treated municipal

water supplies (i.e. an intake pathway for impacted groundwater ingestion does not exist). In addition,

because the radionuclides of concern in Site effluents are naturally occurring in the environment, public

dose estimates based on environmental monitoring data include a subtraction of background

concentrations.

It is well known that radon is the primary driver for calculated public dose estimates at the Site. It is also

recognized that the background radon monitoring station (HMC-16), located on a ridge above the

ephemeral San Mateo Creek basin, is not representative of background radon levels along the floor of this

basin, and the San Mateo Creek drainage runs through Controlled Areas at the Site and adjacent areas



where the nearest members of the public reside. The result of this circumstance is that public dose estimates are believed to be artificially inflated because background radon levels at HMC-16 are about halfthat of background levels in the San Mateo Creek drainage (ERG, 2013).

Radon modeling with the MILDOS-AREA computer code indicates that effluent concentrations of radon at air monitoring stations HMC-4 and HMC-5 due to measured radon flux rates from the LTP and STP are consistent with the above observations (ERG, 2017). The modeling suggests that the levels of radon at the nearest resident location are very low, within the variability in background radon levels. Modeling, measurements and qualitative observation support a contention that the current method for estimating public dose is inaccurate, biasing estimates high by as much as a factor of two.

Homestake previously studied this issue (ERG, 2017) and proposed to NRC a new background location at HMC-lOFF, but NRC has not approved (as of issue date of this RPP manual) a new background location. In the first half of 2018, HMC conducted a r~don monitoring study to help further evaluate equilibrium ratios upgradient of the LTP (HMC-lOFF), on top of the LTP, and hydrologically downgradient of the LTP (HMC-5) (ERG, 2018; see Appendix EI). The study-was based on the premise that radon gas, being denserthan-air, will flow in a hydrologically downgradient direction under relatively calm wind conditions, and any influence of releases from the LTP might be measurable at the downgradient location. Results indicate that radon gas levels on top of the LTP are higher than at the downgradient location (HMC-5), but average radon levels at HMC-5 are statistically indistinguishable from those at the upgradient location (HMC 1-0FF) (ERG, 2018). Although non-parametric testing indicates that me.dian radon gas concentrations at HMC-5 are statistically slightly higher than at HMC 1-0FF, no statistical differences in measured radon progeny levels were observed between any ofthese locations (ERG, 2018). These results provide further evidence that the current method of estimating public dose from radon emissions from the tailings piles is biased high as noted above.

On July 31, 2018, NRC issued to HMC a Request for Additional Information (RAI) regarding demons.tration of compliancE:? with public dose limits given in 10 CFR 20.1301 and 20.1302 (ADAMS Accession No. ML18159A366). HMC responded with a proposal to estimate public dose to the nearest resident based on annual MILDOS-AREA modeling with a source term defined by annual radon flux measurements on the LTP and STP, along with an assumed equilibrium ratio if 0.5 and 100% occupancy (HMC, 2018f This approach would eliminate potential overestimation of public radon dose from the facility due to an inappropriate background radon monitoring location. As of the date of this RPP, NRC has not approved this proposal. Until issues of public radon dose estimation are resolved, HMC will continue to use "background" radon data from HMC-16 for estimation of public dose in the same manner as was done in 2017 and in previous years.

4.6.4 Assessment and Response to Trends or Changing Conditions

All environmental monitoring data, including gaseous and liquid effluents, will be evaluated for potential temporal trends that may occur due to changing conditions over time. Increasing trends will be assessed in terms of potential corrective actions that may be employed to reverse such trends, and this inform.ation will be reported to the NRC in semiannual effluent and environmental monitoring reports.


J "- /


4.6.5 Records Keeping and ·Reporting

All effluent and environmental monitoring data and estimates of public dose will be reported per the

requirements of 10 CFR 40.65, and will be retained by HMC until the license is terminated by the NRC.

4.7 Quality Assurance

4.7.1 Programmatic Performance-based Indicators

Performance-based indicators of the quality and effectiveness of the RPP will be reflected in measured

doses, contamination levels, effluent concentrations, and environmental monitoring results. Compliance

with respective regulatory limits or levels will meet minimum performance criteria for the RPP, but

compliance with administrative limits will ensure optimal program performance and consistency with the

ALARA policy.

4.7.2 Quality Control for Radiological Field Measurements

Quality control (QC) for individual measurement data refers to ensuring acceptable degrees of accuracy

(deviation from the true value) and precision (reproducibility). · Collectively, these ':leasurement

parameters determine the degree of analytical uncertainty reflected in the data. Analytical uncertainty

can be minimized and quantified with proper instrument calibrations and routine QC measurements. The

purpose. of this Section is to provide an overview of the practices that will be used to ensure that

measurements made under the RPP are of a defined and acceptable quality.

4.7.2.1 Calibration

Calibration of radiological measurement instruments and devices is necessary to ensure that the· degree

of accuracy achieved is sufficient to meet measurement objectives. All·electronic radiation measurement_

instruments will be calibrated independently by the manufacturer or by a vendor that is qualified to

perform such services. Calibrations will be performed in accordance with manufacturer SOPs, or using

methods or standards that have been established, or are otherwise widely accepted, by relevant

international agencies.

All electronic radiation measurement instruments will be calibrated at minimum on an annual basis as

specified in SOP 16. Calibration is also required in the event of instrument maintenance or repair.

Instruments will be used only if the calibration is current. Passive measurement devices such as

dosimeters or radon track etch detectors will include analyses that are calibrated by the

qualified/accredited vendor against accurately known (certified) quantities. All instrument calibration

status will be tracked by the RSO and RST.

4.7.2.2 Quality Control Measurements

The continuing stability and performance of each field instrument after calibration will be monitored with

QC measurements taken each day prior to and after use, the results of which will be documented in an electronic form on HMC computers in accordance with SOP 16 [Instrument Test and Calibration Procedure

(HP-10)]. Quality control measurements must meet uncertainty (precision) limits of± 20% of the nominal



(average) reading for background and a check source over time in a consistent location/geometry to demonstrate acceptable instrument performance.

5. REFERENCES

AK Geoconsult, Inc. and Jenkins Environmental Inc. (AKG and Jenkins). 1993a. Homestake Reclamation Plan Revision 10/93. Volume I Text, Tables and Figures. October.

AKG and Jenkins. 1993b. Homestake Reclamation Plan Revision 10/93. Volume 2, Appendices. October.

Environmental Restoration Group, Inc. (ERG). 2013. Basis for Selection of a Representative Background Monitoring Location for the Homestake Uranium Mill Site, SUA-1471. September 2013.

Environmental Restoration Group, Inc. (ERG). 2017. Technical Memorandum: Proposal to address radon flux NOV for the LTP (NRC Docket No. 040-08903/2016-001, License No. SUA-1471). September 5, 2017. Submitted to NRC as an attachment to a letter from HMC entitled "Reply to Notice of Violation, Docket No. 040-08903/2016-001, License No. SUA-1471" as submitted on September 13, 2017.

Environmental Restoration Group, Inc. (ERG). 2018. Occupational Radiation Exposure Study, Final Report. August 20, 2018. This report, reviewed by NRC at the September 10-12, 2018 Inspection of the HMC Grants facility, is provided in Appendix B to this RPP.

Homestake Mining Company of California (HMC). 2018. Reply to "Request for Additional Information -Compliance of Homestake Grants, New Mexico Site with 10 CFR 20.1301 and 10 CFR 20.1302." Docket No. 040-08903, License No. SUA-1471. August 20, 2018.

International Atomic Energy Agency (IAEA). 2014. Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards. General Safety Requirements Part 3. Safety Standards Series No. GSR Part 3.

US Nuclear Regulatory Commission (USNRC). 2014. Evaluations of Uranium Recovery Facility Surveys of · Radon and Radon Progeny in Air and Demonstrations of Compliance with 10 CFR 20.1301. FSME Interim Staff Guidance. FSME-ISG-01. March.


/


APPENDIX A - Standard Operating Procedures (SOPs) for the

Radiation Protection Program

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,' ' ,..,-, - -."

SOP 2 Procedure for Conducting a Field Level Risk Assessment (FLRA) 2 10-15-2018

SOP 11 Radiological Air Monitoring for Occupational Exposures (HP-1) 2 10-15-2018

SOP 12 Radiological Contamination Surveys (HP-2) 14 10-15-2018





SOP 20 Environmental Monitoring Except Groundwater (EM-2) 17 09-09-2018

SOP 21 Spill Response and Reporting Procedure (EM-4) 3 10-15-2018

SOP 22 On-Site Disposal of Radiologically-Impacted Waste 1 10-20-2018

SOP 23 Evaporation Pond Operations 1 10-15-2018

SOP 33 HMC ALARA Procedure (HP-6) 1 07-12-1993



APPENDIX B - 2018 OCCUPATIONAL RADIATION EXPOSURE STUDY


ATTACHMENT 4

Third-Party Review Comments for Radiation Protection Plan with HMC Responses

# ·section Pg.

1 Many

2 General

3 General

4 General

5 General

6 2.2 4

7 2.2 4

Homestake Mining Company ~f California Grants Reclamation Project

NRC License SUA-1471 Response to 3rd Party Review Comments Regarding Radiation Protection Plan

Nov. 07, 2018

There are many places in the RPP and the associated SOPS where "should" is used in instances where "shall" is more appropriate. Conduct a generic review of all uses of "should."

A statement should be made in the RPP that minors are not employed at the site due to the radiological and chemical risk that exist at the site.

Information on declaring a pregnan'cy and the dose recommendations/limits for declared pregnant workers should be included. A form for declaring a pregnancy should be added to an SOP or to the RPP.

A form should be developed that facilitates the c9llection of prior occupational dose history for the current calendar year and should be used to collect that data when new employees are hired. This form an~ this requirement should be discussed in the RPP.

A form for a termination bioassay should be added to an SOP or the RPP. This form should request information on how to contact the employee in the future (in case their termination bioassay sample has a positive result and additional bioassay is required).

Since you are conducting workplace air monitoring and especially breathing zone monitoring, these should be factored into your internal dose assessment. In addition, although no doses or radon concentrations are provided, it appears that occupational radon doses may exceed the measured external doses. Since the NRC is requiring you to conduct new occupational exposure monitoring, that monitoring should include internal dose, especially since it may provide more dose than external pathways.

Why would you discontinue the occupational air monitoring program based on the high-volume air sampling to determine the airborne particulate concentration? That is a much more sensitive option for evaluating potential intakes and can be used to show that the worst-case dose is minimal. If the measured airborne concentrations continue to remain at background levels, then that would preclude internal monitoring via urine bioassay. Elimination of urine bioassay would eliminate the problem of results above the action level, which often appears to be due to lab errors

A global review was conducted for the RPP and all associated SOPs and "shall" or "must" replaced "should" where appropriate.

Radiological and chemical risks at the site are very low. The reason that minors are not employed at the site is related to company policy, not health risks.

Dose Limits to the fetus for declared pregnant workers are given in Footnote 10 in the RPP. Additional information has been added to Section 4.4 of the RPP. Detailed training for women of child-bearing age is given annually to applicable employees. Declaration of pregnancy need not be done on an official form, but does need to be in writing to the Closure Manager as is now indicated in Section 4.4 of the RPP.

Given that radiological risks at the site are too low to warrant occupational radiation monitoring under 10 CFR 20.1502, determination of prior occupational dose is not required under 10 CFR 20.2104.

A "Bioassay Participation Form" has been added to SOP 14. This form is not specific to exit bioassay, but does contain complete contact information for the reason cited.

A comprehensive occupational radiation exposure study was conducted in 2017. Results are provided in a report attached to the RPP in Appendix B. This study included evaluation of potential internal doses from radon, air particulates and external gamma radiation. Results confirm that the potential for the TEDE to exceed the 500 mrem/yr threshold for occupational monitoring given in 10 CFR 20.1502 is not met. This section has been revised accordingly.

High-volume air monitoring was conducted as part of the above referenced occupational radiation exposure study. Results confirm the earlier conclusion that concentrations are very low, well below effluent concentrations given in 10 CFR_ 20 Appendix B, even on top of the tailings piles. The study concluded that BZ air sampling, bioassay and possibly dosimetry are still appropriate for certain non-routine activities at the discretion of the RSO (e.g. under a RWP). This section has been revised accordingly.

.. Sectioli -

a,,,

:n_ l'g.

8 3.1, RSO 5

9 3.1, RST 6

10 3.1 6

11 3.2.2 7

12 4.1.2 8

4.2.1, 13

bullet 2 9

14 Table 1 10

15 4.2.3#3 11

16 4.2.3#4 11

17 4.2.3#6 11

Homestake Mining Company of California

Grants Reclamation Project NRC License SUA-1471

Response to 3rd Party Review Comments Regarding Radiation Protection Plan

Nov. 07, 2018

.. -- . _.,_ ,,'\ - • --- : J~ -- • - -·- ·- --<- --- ·~Y::':e', ;: --- >; -- - ----- _3rd Party·R~view C~ipment -

._

HMC Response to Corri:ment· · ' - ' -- ' ' ,,. . ·. . . ., . --

or sample contamination. The air sampling route is most likely the least expensive approach, too.

The RSO should have dotted line reporting to a leader at Homestake Mining As per Regulatory Guide 8.31, the RSO reports directly to the

Company of California. resident site manager (in this case the Closure Manager). Reporting to a higher authority at HMC is not necessary for the Grants site.

When is it appropriate for the RST to skip the RSO and report directly to the When it is a non-radiological issue.

Site Closure Manager? Site workers: Are all site workers considered to be Radiation Workers? Are The NRC definition is referenced, along with expected doses in only those that enter controlled or restricted areas considered to be relation to that definition. This label is not important, but the Radiation Workers? Are none of the site workers considered to be specification that all workers performing work in Controlled or Radiation Workers? This should be clarified. Restricted areas must follow the RPP and SOPs is important.

The Radiation Safety Training should include discussion of the information found in 10CFR19 .. This was one of the gaps identified in the gap analysis. A bullet referencing worker rights and responsibilities under 10 CFR Radiation safety training provides an excellent opportunity to discuss many 19 has been added to this section. of these items. Annual leak tests are performed on all sealed sources. You cannot leak test You can test a plated source for removable activity-the sentence a plated source, which is what several of your check sources are. has been modified accordingly. Restricted areas may be needed for routine (recurrent) tasks. Delete "due

There are no locations of routine activities at the site that warrant a to non-routine ... " Similarly, the controls are described as temporary. Are

permanent Restricted Area designation. there no areas where permanent controls are needed?

Site instruments are not tissue equivalent dose meters - RSTs need Be consistent with units. Use mrem/hr instead of uR/hr for the external to know the administrative limit expressed as exposure rate, not gamma administrative limit. dose rate. Dose rate is a regulatory definition for "Radiation Area"

and there are no such areas at the site.

There should be a requirement that only single-use containers should be used for drinking in the Controlled Area. This will prevent re-use of a A statement to this effect has been added to this section. container that has become soiled and potentially contaminated.

Most of the SOPs contain little to no description of PPE needed. This is a Many of these SOPs require no PPE. Exceptions are bioassay sample prep, contamination surveys, spill respons'e, trash pit

major shortcoming of the SOPS. Eac~ SOP should describe the PPE needed disposal, and evaporation pond operations. In each of these SOPs,

for the various tasks covered by the SOP. statements have been added concerning PPE requirements.

There should be mention of when one is required to submit a "baseline" or "termination" bioassay sample. These requirements can be discussed in

This information is already explicitly stated in bullet #6. more detail elsewhere, but the need for these types of samples should be addressed here too.

..

It·· Section· .P~. '"• '>',;-

18 4.2.3#7 11

19 4.2.3#9 11

20 4.2.3#10 12

21 4.2.3#11 12

4.2.5, 22 footnote 12

4

23 4.2.6 13

/~

(

Homestake Mining Company of California Grants Reclamation Project


Nov. 07, 2018

,, ·'' . . ·< . . . " ~'' .,. .. .· . . '. . ,

,!; •. . ?rd ~arty~e,vi~~:9~rn.rn~rr .·""·'· '{'" '';/'.: . Ii.ii"':, : ,;.,: . HjVIC. R§spOl}!i~.1t01,C1:,n1rr1enf, .· . \ . ::~, ,' ,-.. . . ;·f . f ~.. , / •' .,s_/ -." ~ :. - -· ··;'., ,'•."

This use of breathing zone air sampling should be included in the discussion in the 2nd paragraph of Section 2.2. the use of breathing zone air samples

See responses to comments #6 and #7. to monitor potential intakes by workers is much more sensitive than urine bioassay Who is allowed to complete exit surveys? This really should be performed

Personnel are trained by the RST to perform personal exit surveys. by the RST or RSO as most workers do not have a·proper understanding of

This has been clarified in SOP 12. how to complete a proper contamination survey. Who is allowed to perform decontamination in accordance with SOP 12? Any survey completed after decontamination should be performed by the The RST performs all equipment release surveys and RSO or RST as most other employees are not going to perform a proper decontamination procedures as indicated in SOP 12. survey.

There is nothing here about workers, the RST, or the RSO having stop work authority when radiological hazards are identified. This authority should be A statement to this effect has been added to this bullet point. clearly stated here.

Most of the-contamination in these boneyards is limited to surface One of the assumptions in your contamination control process is that the activity inside of old pipes. Levels are relatively low and are not Controlled Area outside of restricted areas is clean and thus surveys are not expected to exceed release limits, though formal surveys have not needed for exit of personnel and equipment from the Controlled Area. been conducted on all materials in the boneyards. Walking into However, this footnote is describing an exception to that assumption. This boneyards presents virtually zero chance of contamination or deserves·more than a footnote. This should be its own Section 4.2.X exposures and does notwarrant a Restricted Area provision (i.e. describing the specials controls to be used for this boneyard area(s). It with personnel exit surveys, etc.). The disposition of boneyard sounds like the boneyard should be a permanent restricted area. Is the materials is to be determined by the Closure Manager alone and no contaminated equipment in the boneyard plastic wrapped or otherwise one else has authority to remove, handle, release or reuse any of sealed to prevent the spread of contamination? What are the this material without the approval and direction of the Closure contamination control provisions used? Manager. A footnote is adequate to describe this exception to the

assumptions applied to Controlled Areas.

The' statement in question is reproduced verbatim from License Condition 24 (i.e. no quantitative definition for this term is given in LC 24). Presumably air concentrations> 10% of the DAC or

What constitutes a potential for significant exposure to radioactive potential doses> 500 mrem would be reasonable thresholds for "significance", but such thresholds are unlikely to ever exist (based material? on recent occupational exposure studies) and in any case, the quantitative degree of significance would not be known in advance. We believe the term "significant" in this context should continue to be a qualitative professional judgement call by the RSO.

#.· Section P,g.

24 4.2.8 13

25 4.3#3) 13

26 4.3.1 14

27 4.3.4 14

28 4.3.4 14

29 4.3.6 15

30 4.4 17

• _J



Nov. 07, 2018

What is the frequency of the periodic inspections and audits? This is not stated in the RPP unless this is referring to the monthly ALARA audits and the annual ALARA audit. Continual inspection by the RST shouldn't be considered as an audit/inspection. Is there an SOP for this? Task-related surveys are described in various provided SOPs, but not routine surveys of "clean" areas to monitor for contamination.

The frequency of visual inspections should be included here as well as how those inspection will be documented. Reference to a procedure that outlines these inspections would be appropriate, too. The maintenance schedule should also be discussed or a reference provided to a document where the schedule can be found. The section states that records of these inspections/audits will be documented. Who will maintain those records for review?

Any RWP requiring personnel exit surveys should include establishment of a temporary restricted area.

Are the individual workers allowed to complete their own exit surveys? This is concerning as most employees do not know how to perform a proper survey.

What is the survey frequency for designated eating/drinking or "clean/areas" inside the Ad min Building? Who will perform these surveys? Where will the records be stored? Who will review the survey results?

The logic behind limiting routine dosimetry and bioassay sampling is reasonable. Has the site considered the value of continuing with dosimetry and breathing zone sampling as a bare minimum? There is a value in a "negative" result.

HMC Respo~se to,Comm~~t·

The frequency of RSO/ARSO audits is monthly, and the RSTs are required to continually monitor/inspect compliance with the RPP and SOPS.

Yes - SOP 12 gives the procedures for contamination surveys. Clean area surveys are specifically described in Section 6.4, and a quarterly schedule specification has been added.

Inspection activities occur during routine operations and/or as specified in applicable SOPs depending on the system being inspected. Maintenance for various types of equipment (e.g. RO systems) is done in accordance with manufacturer and/or SOP specifications and as required by any performance issues. This section has been modified for clarity, including citation of example SOPs. Inspection procedures are generally described in the RPP, but specifics are given only where applicable in certain SOPs (some of which do not directly pertain to the RPP).

This is already the case, and the paragraph has been edited for clarity in this regard.

Yes, SOP 12 specifies that the RST will train applicable personnel in the proper procedure for personal exit surveys and documentation.

A monthly schedule is specified in this section. As indicated in SOP 12, the RST performs these surveys, and this has been clarified in this section.

Dosimetry, bioassay and BZ sampling are limited to non-routine activities at the discretion of the RSO. RWP monitoring results consistently show "negative" results for non-routine activities under RWPs as well as routine operations, but potential exposures to radioactive materials are higher under RWP conditions. While monitoring data for RWPs is considered appropriate under ALARA principles, the value of also obtaining proof of negative monitoring results for routine operations is not an effective use of resources with respect to worker safety. Physical hazards at the site are much greater than radiological hazards, and where possible in terms of

, ..

·. #· Section Pg. , c";"t!•c

31 4.4.2.2 20

32 4.4.2.3 21

33 4.6.3.1 24

34 4.7.2 25

35 4.7.2.1 25



Nov. 07, 2018

,, : id· ~artyitevi¢w Commebt ..

. ':"·-- , .. . , '•,' .·. .. . . ·· HMC Response to Comment .

. ·.-'.. .. . __ :<: F~- '- ~ : ·• A ' ', ,. :;·.- . ,: ... · . :· 1:, . . .. • ,, ' , -- ' : ~ -~: ..... : ~ ':-:_; .-regulatory compliance, take precedence in terms of resource allocation. This approach is consistent with optimization objectives underlying ALARA principles.

~ SOP 13 has been revised to eliminate the inconsistency- moving

This Section says that TED Es will be calculated, but SOP 13 says CEDE and forward, both external and internal dose estimates will be calculated, but only for workers that require radiological monitoring

thus TEDE will not be calculated. for non-routine activities under RWPs or otherwise at the discretion of the RSO.

While it is hard to determine the dose from positive routine sampling if a specific intake date is not known, the data can be used to determine the BZ Air monitoring will be used to estimate internal dose. This has potential internal dose from a chronic exposure over one's entire career. been clarified in SOP 13. Bioassay results will be compared against This is a positive aspect of routine sampling that should be considered. toxicity-based concentration criteria (predetermined action levels) Another option is to perform RWP based breathing zone air sampling and found in NRC Regulatory Guide 8.22. This has been clarified in SOP use that to determine the potential internal dose to employees. One or the 14 (bioassay) and in the RPP. other should be used, but both would be redundant.

True, but radon will also mix, disperse and become rapidly diluted in Radon will flow hydrologically downgradient under calm or near-calm wind turbulent wind conditions. The highest concentrations at locations conditions. Otherwise, it will flow with the prevailing wind. distant from the source would occur downgradient during relatively

calm nighttime and early morning hours.

The RPP and SOP 16 specify control limits of± 20% of average or typical readings. QC readings are taken daily when instruments are

Reference is made to routine QC measurements. We would expect these in use. Spare instruments are available in the event that QC control measurements to include trending in instrument performance, but SOP 16 limits are exceeded. Separate trend analysis of instrument includes no such provisions. (Need forms) performance over time (e.g. control charts) is not crucial, but a form

has been added to generate initial QC limits (EDF-28D), and daily QC forms (EDF-28A- 28C) have been updated to include QC limits.

The procedures which use instruments should explicitly include a check to make sure the calibration is not expired. While the date is recorded, A statement to this effect has been added to SOP 16. instruction to not use an expired calibration is not present.

J

: '

.. # · Section

.. . Pg: ..

36 4.7.2.2 26



Nov; 07, 2018

~r~_Pa~i'R~~!~vit Cri~ment . ,· .. ' ·,·- t.· ..

.t\\ · .. HIVICR,~s~C?r,s~\tc:, Cqmment ' . .. '.: C

The process to conduct these QC measurements and compare to the 20% -

uncertainty criteria overtime is not present in SOP 16 or EDF-13. The SOP See response to comment #34. and form need improvement to include the process to do this trending.

.. ',,'",

ATTACHMENTS

NRCForm313

i '

NRC FORM 313 (10-2017) 10 CFR 30, 32, 33, 34, 35, 36, 37, 39, and 40

U.S. NUCLEAR REGULATORY COMMISSION

APPLICATION FOR MATERIALS LICENSE

APPROVED BY 0MB: NO. 3150-0120 EXPIRES: 06/30/2019 Estimated burden per response to comply with .this mandatory collecfion request 4.3 hour.. Submittal of the appfication is necessary lo determine that the applicant Is qualified and that adequate procedunes exist lo protect the public health and safety. Send comments regarding burden estimate lo the Information Services Branch {T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail lo [email protected], end to the Desk Officer, Office of Information and Regulatory AffaiJS, NEOB-10202, (3150-0120), Office of Management and Budget Washington, DC 20503. If a means used to impose an Information coUection does not display a currently valid 0MB control number, the NRC may not conduct or sponsor, and a per.on Is not required to respond to, the information collection.

INSTRUCTIONS: SEE THE CURRENT VOLUMES OF THE NUREG.-1556 TECHNICAL REPORT SERIES ("CONSOLIDATED GUIDANCE ABOUT MATERIALS LICENSES") FOR DETAILED INSTRUCTIONS FOR COMPLETING THIS FORM: http;//www.nrc,govlrea<!!ng,nnldoc-colleclions/nyrags/staff/sd5561. SEND lWD COPIES OF THE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH:

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ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS:

IF YOU ARE LOCATED IN:

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SEND APPLICATIONS TO: LICENSING ASSISTANCE TEAM DIVISION OF NUCLEAR MATERIALS SAFETY U.S. NUCUEAR REGULATORY COMMISSION, REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 .


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SEND APPLICATIONS TO:

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PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAR REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS ANO USE LICENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REGULATORY COMMISSION JURISDICTIONS. 1. THIS IS AN APPLICATION FDR (Check appropriate item)

D A. NEW LICENSE

[ZJ ·B. AMENDMENT TO LICENSE NUMBER

D C. RENEWAL OF LICENSE NUMBER

SUA-1471

3. ADDRESS WHERE LICENSED MATERIALS WILL BE USED OR POSSESSED

2. NAME AND MAILING ADDRESS OF APPLICANT (Include zip code)

Homestake Mining Company of California P.O. Box98 Grants, NM 87020

4. NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION

Thomas Wohlford Homestake Mining Company of California 560 Anaconda Road BUSINESS TELEPHONE NUMBER BUSINESS CELLULAR TELEPHONE NUMBER

Route 605 Milan, NM 87021

(505) 287-4456 ext. 34

BUSINESS E-MAIL ADDRESS

[email protected]

(505) 290-2187

SUBMIT ITEMS 5 THROUGH 11 ON B-112 X 11" PAPER. THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE. 5. RADIOACTIVE MATERIAL 6. PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE USED.

a. Element and mass number, b. chemical and/or physical fonn; and c. maximum amount 7. INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAININ.G AND which will be possessed at any one lime. EXPERIENCE. 8. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS. 9. FACILITIES AND EQUIPMENT. 10. RADIATION SAFETY PROGRAM. 11. WASTEMANAGEMENT.

(See 10 CFR 170 and Section 170.31) CA-ie~ORY

12. LICENSE FEES (Fees required only for new applicafions, with few exceptions') E I *Amendments/Renewals lhat Increase the scope of the existing license to a new or higher fee category wlll require a fee.

PER THE DEBT COLLECTION IMPROVEMENT ACT OF 1996 (PUBLIC LAW 104-134), YOU ARE REQUIRED TO PROVIDE YOUR TAXPAYER IDENTIFICATION NUMBER. PROVIDE THIS INFORMATION BY COMPLETING NRC FORM 531: lll!Jls;llwww,nrc.govlreadlng-nn/doc-collectionsl(onns/nrc531Jnfo.html 13. CERTIFICATION. (Must be completed by applicant} THE APPLICANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE IN THIS APPLICATION ARE BINDING UPON THE APPLICANT.

THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT, NAMED IN ITEM 2, CERTIFY THAT THIS APPLICATION IS PREPARED IN CONFORMITY WITH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 30, 32, 33, 34, 35, 36, 37, 39, ANO 40, ANO THAT ALL INFORMATION CONTAINED HEREIN IS TRUE AND CORRECT TO THE BEST OF THEIR KNOWlEDGE AND BELIEF. WARNING: 18 U.S.C. SECTION 1001 ACT OF JUNE 25, 1948 62 STAT. 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATIER WITHIN ITS JURISDICTION.

CERTIFYING OFFICER - TYPED/PRINTED NAME AND TITLE DATE

Thomas P. Wohlford Closure Manager r1-,n-1i

NRC FORM 313 (10-2017)

() Stantec HOMESTAKE MINING COMPANY

Grants Reclamation Project

MAR Action Plans

ID Task No. IMAR No. lTask Name I Start !Finish

0 MAR Action Plans Schedule rdd Mon 12/3/18 Tue 12/15/20 1 Project Start Mon 12/3/18 Mon 12/3/18 2 Field Investigation Begins Wed 2/20/19 Wed 2/20/19

3 Lab Testing Complete Tue 11/5/19 Tue 11/5/19

4 1 3.4 Roles and Responsibilities - Trigger Action and Response Plans Tue 3/10/20 Mon 7/20/20 5 1.1 3.4.1 Develop Trigger Action and Response Plans Tue 3/10/20 Mon 7/20/20

6 2 3.6 Geotechnical Criteria - Seismic Hazard Assessment Mon 1/14/19 Mon 3/9/20 7 2.1 3.6.1 Update SHA Mon 1/14/19 Fri 3/29/19

8 2.2 Field Investigation Activities (Geophysics, CPT, Drilling, Sampling, Begin Lab Testing) Wed 2/20/19 Tue 7/2/19

9 2.3 3.6.2 Assess Liquefaction potential, re-evaluate stability of LTP and STP Wed 7/3/19 Fri 12/6/19

10 2.4 3.6.3 Develop slope stability risk mitigation action plan Mon 12/9/19 Mon 3/9/20

11 3 3.9 Monitoring, Inspections and Reviews - Review Frequency Mon 12/3/18 Fri 6/28/19 12 3.1 3.9.1 Develop Inspection Template Mon 12/3/18 Wed 1/30/19

13 3.2 3.9.2 Conduct DSR Wed 1/2/19 Fri 6/28/19

14 4 3.12 Document Management - Closure Plan Wed 1/2/19 Tue 12/15/20 15 4 .1 3.12.1 Review TSF Closure Plan Wed 1/2/19 Fri 6/28/19

16 4 .2 3.12.2 Update Decommissioning and Reclamation Plan Tue 10/1/19 Tue 12/15/20

17 5 3.13 Document Management - Care and Maintenance Manual Wed 1/2/19 Fri 6/28/19 18 5.1 3.13 .1 Develop Care and Maintenance Manual Wed 1/2/19 Fri 6/28/19

19 5.2 3.13 .2 Develop Compliance Plan Wed 1/2/19 Fri 6/28/19

20 5.3 3.13 .3 Carry out FRA for TSFs Wed 5/1/19 Wed 5/1/19

21 5 .4 3.13 .4 Develop EPRP for TSFs (pending EAP review by NMOSE) Wed 1/2/19 Fri 6/28/19

22 5.5 3.13 .6 Develop QPOs for TSFs Wed 1/2/19 Fri 6/28/19

23 5.6 3.13 .7 Develop Training Guidelines Wed 1/2/19 Fri 6/28/19

24 6 Project Management and Administration Mon 12/3/18 Tue 12/8/20 50 Project Complete Tue 12/15/20 Tue 12/15/20

DRAFT

Project: MAR Action Plans Schedule_rdd Task

Date: Fri 11 /30/18 Milestone • Summary I , Project Summary 1

Page 1

I Duration 2, 2018 I Hair, 20119 I Halfi2' 2019 I Hair, 20

120 I Half 12, 2010 I Hair, 2oi21

s l N J MM J s l N J M M J s N J MM

532 days 0 days ~ • Dec 3 '18

0 days ,+ Feb 20 '19

0 days · - Nov 5 '19 .T 95 days I I

95 days

301 days

=6-I

55 days - H 95 days -. 113 days ~

66 days r= :::-i

150 days I

43 days -...I ::::}-

128 days

510 days I

128 days "'l

316 days _) ~

128 days I I

128 days ..._

128 days

1 day .. '

128 days

128 days

I 128 days I

527 days I I I I I I I I I I I I I I I I I I I I I I I 11

0 days .. ... Dec 15 '20 • T

1 Progress

Documents

Radiation Protection Program Manual Revision2 Prepared for ...Radiation Protection Program Manual Homestake Gran~s Reclamation Project Cibola County, New Mexico Revision2 Prepared