ML18200A068
| ML18200A068 | |
| Person / Time | |
|---|---|
| Site: | 04008903 |
| Issue date: | 07/17/2018 |
| From: | Wohlford T P Homestake Mining Co of California |
| To: | Jeffrey Whited Office of Nuclear Material Safety and Safeguards, NRC/OE |
| References | |
| EA-16-114 | |
| Download: ML18200A068 (2) | |
Text
Grants Project Director, Office of Enforcement (OE) U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 17July2018 Homestake Mining Company of California Thomas Wohlford Closure Manager Deputy Director, Division of Decommissioning, Uranium Recovery and Waste Programs Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Mr. Jeffrey Whited Project Manager, Materials Decommissioning Branch (Mail Stop: T-8F5) Decommissioning, Uranium Recovery & Waste Programs Office of Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Homestake Mining Company of California
-Grants Reclamation Project -March 28, 2017 Confirmatory Order Modifying License No. SUA-1471, EA-16-114, Condition 2 Root Cause Analysis Corrective Action Plan for 5 Apparent Violations Update
Dear Mr. Whited:
To satisfy Condition 2 of the March 28, 2017 Confirmatory Order, Homestake Mining Company of California (HMC) completed a Root Cause Analysis Corrective Action Plan and submitted it to the Nuclear Regulatory Commission (NRC) on November 15, 2017 (ML 17320A 128). The Root Cause Analysis was used to determine the reasons for the five apparent violations documented in the NRC's October 4, 2016 letter (ADAMS Accession No. ML 16251A526).
This memo serves to provide an update to the estimated project schedule for implementation of each of the proposed additional corrective actions (see attached Table 1). Changes from the original proposed schedule, e.g., that a corrective action has been completed or the proposed date is different than originally proposed, are shown in Bold. Two notable changes are identified for Action Numbers 12 and 14. Specifically; Action Number 12: HMC is currently working on completing an Environmental Monitoring Plan with associated Standard Operating Procedures and expects this plan to be
- completed by July 31, 2018. Action Number 14: Instead of hiring a Water Treatment Plant Professional, HMC has reached out to water treatment plant consultants such as Engineering Analytics and the vendors for the individual plant components such as Pall Corporation, Westech and Avista, which have detailed operations knowledge of the micro-filtration, clarifiers and RO units. HMC has made the decision to satisfy this action by combining the use of this
- Homestake Mining Company P.O. Box 98, Grants, NM 87020 Tele: (505) 287-4456 Fax: (505) 287-9289
' Letter to NRC RE: Corrective Action Plan Update July 17, 2018 expert help with the hiring of a site staff engineer who has been assigned operations and troubleshooting of the RO remediation system. This action was completed on April 9, 2018. Thank you for your time and attention on this matter. If you have any questions, please contact me via e-mail at twohlford@homestakeminingcoca.com or via phone at 505.290.2187.
Respectfully, Thomas P. Wohlford, CPG Closure Manager Homestake Mining Company of California Office: 505.287.4456 x34 I Cell: 505.290.2187 Copy To: NRC Document Control Desk (Hard Copy} W. Pearson, NMED (electronic copy} S. Appaji, EPA (electronic copy} M. McCarthy, Barrick, Salt Lake City, Utah (electronic copy} G. George, Davis Wright Tremaine, San Francisco, California (electronic copy) C. Burton, Barrick, Henderson, Nevada (electronic copy} G. Hoffman, Hydro-Engineering, Casper, Wyoming (electronic copy} R. Whicker, Environmental Restoration Group, Albuquerque, New Mexico (electronic copy} Page 12 Homestake Mining Company P.O. Box 98, Grants, NM 87020 Tele: (505) 287-4456 Fax: (505) 287-9289 Table 1. Summary of Additional Corrective Actions by Root Cause Action Applicable Date Action to Root Cause Number<*)
Apparent Corrective Actions Responsible Parties Begin Date to Complete Violation(s)
I l ,3, 4 , and5 Lead frequent conference calls with the NRC HMC Closure Manager 1nitiated On-going through Site closure 2 l ,3, 4 , and5 Lead monthly conference calls with the NRC and other regulatory agencies HMC Closure Manager Initiated On-going through Site closure Poor communications between HMC " Culture change" in willingness ofHMC to work closely with NRC and get and the NRC 3 I NRC " buy-in" before proceeding with any new action or change HMC and Barrick management Initiated On-going through Site closure 4 I Modify HMC SOP-10 on SERPs HMC management and staff Completed February 26, 2018 with subsequent updates 5 I Prepare a revised groundwater CAP upon completion of Self-Assessment to HMC management and staff Sep.4,2018 One year after initiation align CAP with subsequent License revisions 6 I and 5 Hire an Environmental Compliance Professional HMC and Barrick management Completed March 12, 2018 HMC did not clearly understand 7 I and 5 Prepare an Environmental Obligations Register HMC management and staff Completed October 19, 2017 with regulatory obligations subsequent updates 8 I and 5 Develop and implement a Regulatory Training Program for Site personnel HMC management and staff Initiated February 12 , 2018 with monthly training events there after 6 I , 4 , and 5 Hire an Environmental
.Compliance Professional HMC and Barrick management Completed March 12, 2018 1nadequate HMC resources for compliance-related matters Hire additional full-time on-Site staff (two Environmental Technicians , one 9 1 and4 Engineer, and one Hydrologist)
HMC and Barrick management Completed April 9 , 2018 Poor communications between HMC 10 1 , 2 , 3 , 4 , and5 Increase communications between Site management and staff , and corporate HMC and Barrick management 1nitiated On-going through Site closure Site management and corporate management Prepare a QAP, and formalize and implement routine Management management 11 2 and 3 Assessment Reviews as outlined in the QAP HMC and Barrick management Initiated On-going through Site closure 6 2 Hire an Environmental Compliance Professional HMC and Barrick management Completed March 12, 2018 7 2 and 3 Prepare an Environmental Obligations Register HMC management and staff Completed October 19, 2017 with subsequent updates Insufficient focus on compliance by 8 2 Develop and implement a Regulatory Training Program for Site personnel HMC management and staff Initiated February 12 , 2018 with monthly HMC Closure Managers trainin2 events there after . 11 2 and 3 Prepare a QAP , including a DMP HMC management and staff Completed February 15, 2018 12 2 and 3 Prepare an EMP with associated SOPs HMC management and staff Initiated July 31, 2018 9 2 Hire additional full-time on-Site staff(two Environmental Technicians , one HMC and Barrick management Completed April 9 , 2018 1nsufficient HMC resources to resolve Engineer , and one Hydrologist)
RO Plant performance issues, and lack Contract third-parties with expertise in RO water treatment systems to of preventative maintenance program 13 2 HMC and Barrick management Completed October 20, 2017 for RO Plant improve operations to achieve design capacity 14 2 Hire a Water Treatment Plant Professional HMC and Barrick management Completed
<2> April 9, 2018 Table 1. Summary of Additional Corrective Actions by Root Cause Action Applicable Date Action to Root Cause Number<1> Apparent Corrective Actions Responsible Parties Begin Date to Complete Violation(s) 15 2 Use KPA Analyzer to provide quick-turnaround screening results for uranium HMC management and staff Initiated
- On-going through Site closure at SP2 6 2, 3, and 4 Hire an Environmental Compliance Professional HMC and Barrick management C o mpleted March 12, 2018 HMC's misunderstanding of October 19, 2017 with compliance obligations due to 7 3 and 4 Prepare an Environmental Obligations Register HMC management and staff Completed subsequent updates ambiguous language in the License February 12 , 2018 with monthly 8 2 , 3, and 4 Develop and implement a Regulatory Training Program for Site personnel HMC management and staff Initiated training events there after 6 4 Hire an Environmental Compliance Professional HMC and Barrick management Completed March 12, 2018 Insufficient QC and data management 8 4 Develop and implement a Regulatory Training Program for Site personnel HMC management and staff Initiated February 12 , 2018 with monthly trainin2 events there after procedures 11 4 Prepare a QAP , including a DMP HMC management and staff Completed February 15, 2018 12 4 Prepare an EMP with associated SOPs HMC management and staff Initiated July 31, 2018 6 5 Hire an Environmental Compliance Professional HMC and Barrick management Completed March 12, 2018 HMC did not clearly understand the definition of "byproduct" material 8 5 Develop and implement a Regulatory Training Program for Site personnel HMC management and staff Initiated February 12, 2018 with monthly training events there after Footnote:
(1) Denotes Action Number as identified in Section 4 of CAP (2) Action Satisfied by hiring Civil Engineer assigned to RO operations. 2