uranerz energy corporation - submittal of draft quality ... · effective date: october 1, 2013...

2 UranerzENERGY CORPORATION

October 3, 2013

Attn: Document Control DeskDirector, Office of Federal and State Materials andEnvironmental Management ProgramsU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Attn: Document Control DeskU.S. Nuclear Regulatory CommissionDeputy Director, Decommissioning and Uranium Recovery Licensing DirectorateDivision of Waste Management and Environmental ProtectionOffice of Federal and State Materials and Environmental Management ProtectionMail Stop T-8F511545 Rockville PikeTwo White Flint NorthRockville, MD 20852-2738

RE: Uranerz Energy Corporation, Nichols Ranch Project, Source Materials License SUA-1597, DocketNo. 40-9067, License Condition 12.13

Dear Mr. Director and Deputy Director,

License Condition 12.13 states "At least 30 days prior to the preoperational inspection, the licensee willsubmit a Quality Assurance Program (QAP) to the NRC for review to verify the license applicationstatement that the QAP will be consistent with Regulatory Guide 4.15."

In response to License Condition 12.13 please find the attached "Quality Assurance Plan (QAP)-Radiological Effluent and Environmental Monitoring Program for Nichols Ranch facility.

Upon review and acceptance of the QAP we request that License Condition 12.13 be removed from thelicense.

If you should have any questions regarding this matter or this proposed plan, please contact me by phoneat 307-265-8900 or by e-mail at [email protected].

Sincerely,

Mike T =1Vice President, Regulatory AffairsUranerz Energy Corporation

MT/rs

cc: Ron Linton, Project Manager, NRCLinda Gersey, Lead Inspector, NRC

USA OPERATIONS CANADA OPERATIONS NYSE MKT: URZP.O. Box 50850 T: 307 265 8900 Suite 1410 T: 604 689 1659 Toronto Stock Exchange: URZ1701 East 'E" Street F: 307 265 8904 800 West Pender Street F: 604 689 1722 Frankfurt Stock Exchange: U9ECasper WY 82605-0850 Vancouver B.C. V6C 2V6 www.uranerz.com

URANERZ ENERGY CORPORATION

Revision Number: NEW Document: RAD-SOP- 16Effective Date: October 1, 2013 Page: 1 of 18

Approved by: Date:

Department Manager

Mine Manager

Radiation Safety Officer

QUALITY ASSURAN tVROGRW (QAP) k\->RADIOLOGICAL EFFLUENT AND ENVIR6 N MONITORt PROGRAMS

PURPOSE/SCOPE

The Quality Assurance PJtfýAP).ias been •' t q Xf the results of measurementsof radioactive materials e effluents from, and •ieheNc•: t0 iRProject~:ýifsi e ofltis Thehe Ni hos...h

Project Facilities. TheQ documensbow data WiI*,4ollected, iLsssed and analyzed. Theresponsibilities and object't describj telow have,' 'n designed to ensure compliance and furtherimplement a p9g • for proQvi' s a" fie w .•kn atmos'here that is protective of the environment withcost effecti%'o of pib,,ok jfhy of apiin,,•,.iation exposures As Low as is Reasonably

),rA R th, •a' i th ALA gram (RAD-SOP-02), for all employees,contractfuVlySltOrs and tl ic . .

In order fo.r A ,RA to be succ sfu'lly impiinted all individuals including management, supervisors,radatonand workers.st take rt in and share responsibility for keeping exposures

ALARA. Quality A.44ance (QA) &]41Quality Control (QC) for radiation protection and radiologicaleffluent monitoring is"`4bmponet(if external radiation exposure monitoring, airborne radiationmonitoring, bioassays d contamination controls. The QAP provides a framework forquality control for the site. r i.dOperating Procedures (SOP) developed for the site provide theimplementation of the QAP el '-nents.

As defined in the Nuclear Regulatory Commission (NRC) Regulatory Guide 4.15, Quality Assurancecomprises planned and systematic actions that are necessary to provide adequate confidence in theassessment of monitoring results. QC comprises those QA actions that provide a means to measure andcontrol the characteristics of measurement equipment and processes to meet established standards. QAincludes QC and the terms may overlap for some actions. Thus, Uranerz documents do not distinguishbetween the terms QA and QC.


Revision Number: NEWEffective Date: October 1, 2013

Document: RAD-SOP-16Page: 2 of 18

The QAP will take into account the need for special controls, processes, test equipment, tools, and skillsto attain the required quality, and the need for verification of quality by inspection and test. QA/QC willprovide for training of personnel performing activities affecting quality as necessary to assure thatsuitable proficiency is achieved and maintained. The Environmental, Safety, and Health (ESH) Manager/Radiation Safety Officer (RSO) shall regularly review the status and adequacy of the Uranerz QAP.

SAFETY

The performance of this task does not have any safety hazards

ENVIRONMENTAL

The performance of this task does not have any environmeft

RADIATION

The performance of this task does not have any ra n issue!

EQUIPMENT LIST

The performance of this task does not reii 1 use of any e

PROCEDURE

with it.

ociated with it.

1. OrganizationalThe authorities,developing, revii

flinagedrilg•d Operational Personnelis within the organization responsible forenforcing the QAP are designated.

1.1-t anerz Senior

g ce pertaipers nd orýorgani lsolutions, •

1.2. Vice President

Officer; Vice President, Production)

nsible forF1verall implementation of programs, policies, and,Wg activities at Uranerz. Senior management will ensure thatiVA functions will have sufficient authority anduahity problems and to initiate, recommend, or provide

Affairs

The Vice President 6-'kegulatory Affairs has responsibility and authority for oversight ofenvironmental monitoring programs for Uranerz. The Vice President of Regulatory Affairs, willprovide input to Mine Manager and ESH or RSO to ensure that all ESH, radiation safety,environmental compliance, QA/QC, and permitting/licensing programs are conducted in aresponsible manner, and in compliance with all regulations and permit/license conditions. Thisperson will report directly to a Senior Manager (e.g., the Chief Operating Officer, Uranerz;President, Uranerz).

1.3. Mine Manager



The Mine Manager is responsible for uranium mining activity at the mine site. All siteoperations, maintenance, construction, environmental safety and health, and support groupsreport to the Mine Manager. The Mine Manager reports to the Vice President, Operations. TheMine Manager has the authority to immediately suspend, postpone, or modify an action or workwhich may be deemed threatening to human health or the environment or deemed in violation ofstate or federal regulations. The Mine Manager is responsible for:

" Implementing industrial, radiation safety and environmental protection programsassociated with operations;

* Assist in the development, administration, and enf'q• ent of the QAP;" Designate a person that will oversee the QAP; t'* Ensuring that personnel adhere to SOPs for tation, review, and evaluation of

monitoring data and reports;Ensuring that adequate technical and Q is pV for personnel performing

activities important to the QAP; d* Reviewing and approving writte ures;* Ensuring contractors provide reco id reporting and mainta i . uality Assurance

Manual (or equivalent) as needed to A the erz E nvir i QAP; and" Investigating and correc quality

1.4. Environmental, Safety and HelaffZI _ anager

The ESH Supervisor reports to the' ce M ,nd coordinkes with the Vice President ofRgltr ff-al,, ManH res 0n day-i operations ofteESH forRegulatory Affa•Q • V Manalg••m~ \avo h

the project. Tbh menting the QAP.

1.5. Radiation Saf (f tihee E

T Nponst *an tent of the radiation safety program including-Fmt r fQA ,iremen dt .ne radiation safety program. The RSO reports

the ESH Mah The rovides a *ness of events and issues that could affect the\ ity of progra. m -rmai

1 Health Physi eclinie Health Ph s. Technician (HPT) or Radiation Safety Technician (RST) shall

tithe RSO the implementation of the QAP. The HPT reports directly to theRS

1.6. Supervisors

Workplace supervisors are responsible for developing, implementing, and maintaining SOPs thatimplement the QAP. The supervisors document proficiency for quality-related activities initiallythrough task training and at least annually during performance reviews in accordance with theTask Training procedure (SFT-SOP-3 1). Supervisors are responsible for coordinating qualityprocedures with the QA Manager. With assistance from the QA Manager and upper levelmanagement, supervisors also identify, investigate, report and correct quality problems.

1.7. Employees


Revision Number: NEW Document: RAD-SOP-16Effective Date: October 1, 2013 Page: 4 of 18

Employees are responsible for implementing the QAP as required by SOPs. Employees providerecommendations, implement corrections, and verify effectiveness of quality improvements asneeded.

1.8. Contractors

Contractors providing support activities (e.g., sampling, analysis, evaluations, and records) forenvironmental programs are required to retain records sufficient for Uranerz to maintain theQAP.

2. Specifications of Qualifications of Personnel

Uranerz employees and staff will have proper quali•latiunis for tle$"sitions they hold. Qualificationsof personnel involved with the Radiation Safety POP 4h are listed &i anization andAdministration of the Radiation Safety Progra .V"D-SOP-01). QualTfN ions of individualscarrying out assigned radiological monitoring':fihtions are defined in thelbldiij escriptions.Individuals performing quality-related activities ~ained and. ualified in tfihpinciples andtechniques of the activities. Proficiency is maintainiid.f retracbiq, reexamining!iertification, orby periodic performance review. Ci6nual training, t T1, ' her and on the j"training will beconducted as needed to ensure that 'cwkmaintain a"" ess of events and issues that couldaffect the quality of performance.

2.1 Initial Training '

All employees"pi :eceive afiltialtrai(inig 'e. a!!•g gene.ety and radiation safety asoutlined in Ura'i mploye&',raainmg (SI•t'-P-32) and ALARA Program (RAD-SOP-02).Uranerz policy i n" tran coiiqtctors to tlie~l~opriate level of hazards as dictated by the RSOand Safqt3ePersonnelWi, Wri1 jiblt exam-s i%.be given to show proficiency, and will be filedand1ainiane--n site.',

2A.01i'he Job Training,,.Z ý

All " ees will be g'ii specialf' instructions on the health and radiation safety aspects ofthe sp obwthey will pormi. Thtwill be on-the-job training (OJT) and is outlined inTask Traifingt•SFT-SOP-3.,,

2.3 Refresher Traln'i•i•v< {K

Refresher training fori*diation safety will be given annually. Training is an abbreviated coursethat may include, exposure trends, relevant information that became available the past year, orother changes in the regulations or license. Oral or written tests may be given to show proficiencyin accordance with ALARA Program (RAD-SOP-02).

3. Operating Procedures and Instructions

Guidelines for writing standard operating procedures are outlined in Standard Operating Procedureand Log Sheet Guidelines (ADM-SOP-04). Written SOPs are suggested for all activities that generate



Document: RAD-SOP- 16Page: 5 of 18

data applicable to this QAP. This may include but is not limited to the following activities forUranerz:

* Dose calculations and measurements;* Sample collection;* Sample management;* Chain of Custody;* Sample preparation and analysis;* Data reduction and recording;* Data assessment and reporting;* Final sample disposal;• Training;

Preparation of QC Samples;• Collection of meteorological data;* Corrective actions;

*Audits;* Records; f.r n t

Ancillarv laboratorv functions (incl,,dinTi' .ining nf or1.qWqrP n.'iintion control I nnd.......... j---.. -... -.... j . ... . . .. -.. . .

storage of standards and chemicals);* Calibration and QC of ins tation

laboratory Performance Te 4,.i 11

" Timetable for Verification andtaii"

and5

criteria for the

4. Record Keeping A

Records includingkwill be readily avaitermination. The Bwide or work.lace-

be maid , 'ard c'ififor stored electronically. Recordsnspec:t• ~ m ay be ntl hsferred to the NRC after license

6sible for e:& that required records are maintained in site-K in inh\,al SOPs. Requirements for documentation andepar'r• eN approval, issue, use, and revision of documentsecify r s, or establish design. Records must be•ed, and mai ined according to Uranerz policy found in

Field and Laboratory data will be sufficiently documentedreý,factivities and analysis performed. Records of field

Chain-of-Custody forms, and project reports will be used toStandardized forms and log sheets will be designed to eliminate

actors performing support activities shall retain records sufficient

to provid pientvariance," i' aldetermine theerrors made du11eto access QA/QC.

4.1. Types of and Reports

Uranerz will generate and maintain sufficient records, and reports to demonstrate regulatorycompliance. These records may include but are not limited to:

* Procedure revisions;* Personnel training and qualification;* Analytical results;* Audits;* Corrective actions;



Document: RAD-SOP-16Page: 6 of 18

* Intermediate activities or calculations;* Records of tracking and control (e.g., chain of custody);* Field logs with sufficient information describing environmental conditions and data

documenting the nature of the sample and where and how it was taken;* Laboratory notebooks;* Electronic data collection and algorithms;* QA documentation;* Calculations (including data reduction, analysis, and verification);* QC for radiation monitoring equipment, including resul•t•of:

* Radioactive source checks;* Calibrations;" Instrument background determinations* Maintenance activities affecting eq"uni per ce;

* Notifications to qualified staff that proced rIhanges affe data quality have band

* QC for laboratory counting systems, sMPOrt instrumentation and j ment, includ* Calibrations;

een made;

ing:

* Maintenance or repair;* QC sample results,* Traceability of staýNri

4.2. Validation and Verification for Ac

The RSO is pr'r . onsibl(could have a ct on t vircto review and logboo Caccuracy (RAD- Ope rnave ad validatee •n

'ylputer pro and s sheumented, vern \d hva

c uter program. icati~ent Da

4.2.1 Field D

w i' derific&fon of activities, whose failurer sr saf e RSO or designee is responsiblelogs at least monthly for completeness andafety Program). Technical data is routinely4sufficient quality and quantity.

ts ursw.eeeimplementation of radiological monitoring isbefore iPnial routine use and after each modification of the

kqks are performed on all routine data-transfer and data-

Field data verifi't e.Urja••e s that data is collected in accordance with designatedprocedures and per iiq2'*° schedules. The data should be reviewed for completeness,transcription errors, ,c)mpliance with procedure, and accuracy of calculations.The individual validating the data, in consultation with RSO or designee, may correct problemsthat are found or noted in the documentation by lining through the incorrect entry with a singleline, correcting the information, then initialing changes made to the document. Care must bemade not to obscure the erroneous information. The person validating the data must also ensurethat erroneous data is not entered into the database.

4.2.2 Laboratory Data




Data received from external laboratories is verified for completeness and validated bypersonnel qualified in data validation. Analysis should be in accordance with accepted analyticalprocedures.

QA/QC data provided by the laboratory (blanks, spikes, etc.) will be evaluated to see if they fallwithin an acceptable range. If QA/QC samples are not within the set range, samples areevaluated to determine if corrective action is warranted

4.2.3 Quality Control Samples

QA/QC samples, blanks, duplicates, spikes, orthe data validation process. The number and fndetermined for each data set taking in to consicSOPs.

4.2.4 Anomalous Data Al-VR,

The determination of anomalous data is done-Iscreening of the data, technical review, and corindeed anomalous.

4.2.4.1 Screening of the Data

Sampling datais screened fAr44lues tFThe hist~ iifn are s

4.2.4.2 Technr l)gview

)I samples, are evaluated in)C samples are individuallyy requirements and individual

tion nroae,[it involvesis

ranges.

r,eening 49 points and determining if the point is• need•t,, Evaluation takes into consideration

points, analyte concentration, magnitude of therical dat 'and location of sample point in regards to other. If point is not acceptable corrective action is taken.

Corr~t* actionstalbw for further investigation into the reasoning behind anomalousdata. C " tv' """t'ns may include requesting a laboratory check of calculations anddilutions, 4' Ianalysis. re-sampling, and comparison of data to next samplingevent. Based 0cnthe corrective action the RSO or designee can then determine if thedata point is acceptable or an anomalous point. Anomalous points are included inthe site specific validation report with justification for being anomalous. Anomalouspoints are considered unusable.

4.3. Record Retention

Each record owner ensures specific requirements for record retention are included in applicableSOPs. Requirements include the following:




" Records are to be legible and identifiable, retained in predetermined locations, andprotected against damage, deterioration, or loss;

* Records should be easily retrievable;* The document retention system should allow reconstruction of activities associated with

the generation of analytical results; and* Records are to be retained for a time as required by license condition, if a record retention

time is not known, records are to be retained indefinitely until otherwise determined.

4.4. Electronic Records

If the media for storage of records is electronic,present the data in an uncorrupted form.

4.5. Reporting Requirements 4Reports of the Radiological Effluent andthe NRC semi-annually in compliance wit urecovery solutions and process chemicals,ýCFR 40.60, and SUA-1597 Licose ConditionlManager by telephone or electI* R ail withinsubmitted to the NRC Headqu ect Manincident, corrective action, and wrl t _"w 0

are submitted to, excursions of. 20 part M, 10

biluarters Projectft en report isof the spill or

The reports al(assessments, a

5. QA/QC in

5.1.

eI'rom th "' s filedlknaintained on site for alles. •

-hl Nical and environmental regulatory limits astechnical report, and NRC regulations throughout all pre-ftnd decommissioning reclamation activities. Limits for, rldual SOPs and within the license application.

ical Exposure Monitoring

indi,

5.2 Radiologic

5.2.1 Survey

Passive gammY. air particulates, and radon measurements are conducted in the vicinity ofthe project site to determine the potential dose to the general public from off-siteexposure. Radiological effluent and environmental monitoring is conducted according toestablished procedures prepared to be in compliance with regulatory requirements, seeRadiological Effluent and Environmental Monitoring Program (ENV-SOP- 18).

Health physics surveys are performed to protect workers at Uranium recovery facilitiesfrom radiation exposures in excess of background and chemical toxicities of uraniumwhile on the job. Occupational Exposure surveys are performed according to established



procedures prepared to be in compliance with regulatory requirements ContaminationControl and Personnel Monitoring (RAD-SOP-05) and Decontamination and Release ofEquipment and Material for Unrestricted Use (RAD-SOP-06).

5.2.2 Quality Control of Radiological Exposure Monitoring Measurements.

The radiological effluent and environmental monitoring program generates valid dataof a defined level of quality. Sample and monitoring procedures are designed to identifysampling and measurement processes, including deficiencies and report them, provideconfidence that the monitoring results can be validat The QA for these proceduresinclude provisions for analytical sampling, sa I ment, chain of custodydocumentation, radiological measurement datf d ution, data evaluation, and reporting.

5.2. Radiological Effluent and Environmental Moni "ig

Radiological effluent and environ. . Imonitoring QA//Q ective is to ensure thatall radiation safety, radiological e t, and environmental mn -. ring measurementsare conducted in a safe manner and . pliance th regulato idance.

Air particulate sample ollected contl' 6 air particulate s ling locations.Air filters are collected N-1 omposited, nalyzed quarterly to determine U-nat,Th-230, Ra-226, and Pb- n Dose A. ment (RAD-SOP- 14) andRadiological Effluent and iron 1onitorin r ogram (ENV-SOP- 18) detail theQA/QC inv v.cd with air a ulate sa

Rado s monit continuo alp etch detectors or equivalent.vi change Q rterly an ff for analy is. The sensitivity of the devises is

0.33 pCi . 90 dayIbf exposure utlined in section 5.7.3.2 TR. Locations may have%• &It n iritoi" .e ' of QA N in accordance with Radiological Effluent and

m Or]-e V i (rm E s OP-18).

Passive is"meýd conti nu" y with quarterly analysis using passiveintegrating dAits or ejt]ibent. The devices shall have a sensitivity of at least lmrem.ocations ma to tigring devices as part of QA/QC in accordance with

•ological Efflucii and Enironmental Monitoring Program (ENV-SOP-18).

Sam rograirii i be periodically assessed to determine if additional samplinglocation ro ý gulatory requirements or enhance the ability to demonstratepublic 1 osures above background.

5.3.1. Air Particulate Monitoring QA/QC considerations

Errors in estimates of volume of air that has passed through filters should be avoided byaccurate calibration of the flow rate and by preventing or correcting for the loss of flowcaused by accumulation of material on the filter. As material accumulates on the filtermaterial the air flow drops, thus less air volume is sampled. Air flow rates through filtersshould be determined by calibrating pumps with filter in place once every 12 months to ±20%.




5.3.2. Liquid Effluent

11 e. (2) by product material is produced at the site in the form of liquid process wasteincluding chemicals from the laboratory, "affected" groundwater generated during welldevelopment and operations, and groundwater generated during aquifer restoration. Theliquid 1 le(2) by product generated during the project is managed by deep well injection.Monitoring of the 11 e(2) liquid stream is in accordance with the established procedureTransportation and Handling of Radioactive Materials (RAD-SOP-07).

5.3.3. Quality Control of Radiological Effluent and En!4hirinental Monitoring Measurements

Monitoring site conditions requires thesampling tools, and supplies. Proper insequipment is required to ensure fieldthe use of approved procedures,of equipment and supplies, and tiobjectives are to obtain reproduciblNSaccuracy consistent with the intended d

Field duplicates, field d trip 1:and qualitatively evalua a a]external and internal efct he asamples ari.g. uely identiI .i.

of instruments, equipment,Ia q maintenance, and use of eacheld' 9C is implemented throughde~on' ~ation, protective storageluring fiettivities. QA/QCmeasurem a degree of

opriate are used to quantitativelyof external laboratories to access

ipuability of reported results. These

developing.

5.3.

Jfi•tw:ich allows it to be traced from collection toa de inN e hold time, methods are in place to preclude theto determine the applicability to results if the time can be

Chain of•dy forms awed to provide a document trail of persons who have custody of agiven sample e form des descriptions, sources, packaging, and preparation, hold time,shipping, requi - K: 'Naates/times, as applicable to ensure the quality of the sample andanalysis. Sample i ity, i s maintained through the use of chain of custody and may includecustody seals as appr,'iate. Currently, for Radiological Effluent and Monitoring Programsamples, Nichols Ranch uses two laboratories and their chain of custodies are attached inAddendum A.

5.5 Quality Control Samples

Environmental data must be of sufficient quantity and quality to determine if performance criteriaare being met. The type and quality of data provided to appropriate regulatory agencies is used todocument performance of the uranium recovery operation and later attainment of reclamation and




restoration goals. Data should be of sufficient quality to withstand scientific and legal scrutiny,acquired in accordance to established procedure appropriate for the intended use, of knownaccuracy and precision, complete, representative, and comparable. To assist in the achievement ofthe objectives, quality control samples are necessary.

Field duplicates verify representativeness, indicating that results are representative of theenvironment. Field duplicates are two samples of the same material, collected in similar locationsat the same time and under the same conditions as is practical.

5.6 Sample Handling, Storage, and Shipping for RadiologicalMonitoring Samples.

Procedures for handling, storing, cleaning, packag' 'S I]included in Uranerz SOPs. Storage consideratio hnel udesample integrity, and sample identification. •

5.7 Spatial and Temporal Variation

Spatial or temporal variations are considered anncdoccur when analytes vary by sole location. Fopumped from a monitoring w p taking a sa

The frequency of sampling and n o and lvariability and amrt4f radioactiv.0, Lfraiaciv3

ent and Environmental

and preserving samples areance of sample characteristics,

needed. S variations cancan include t i of water

level of

Temporal v,Continuous

ýa time cycle, such as seasonally.to assess temporal variability.

5.8 Ut

Ok each ty ple based on measurement requirements. For.!ýjon is given•"r the density/composition of the matrix, countingioniv•laboratory, applicable analytical chemical recovery,iomo jty of the sample. Air particulate volumes are impacted by:er dust l'ading, and flow rates of sampling equipment. Methods for:result are found in specified environmental sampling and analysisegulatory requirements.

filter

6.0 Laboratory Quality Control

Performance indicators are used in the on-site Plant and Radioanalytical Laboratories to determine ifthe laboratory's measurement processes are in control. The type, frequency, and evaluation criteriafor QC samples are developed during SOP development for specific analyses.

Performance indicators are selected to provide a management tool for tracking and trendingperformance and to identify precursors to nonconforming conditions. Laboratories consider necessarylevels of precision, acceptable bias, and applicable detection limits. This is documented in applicableSOPs. Definitions are as follows:




* Precision is the closeness of agreement between independent test results and can be assessedusing replicate samples. It may be expressed as the standard deviation.

* Bias of a measurement process is a persistent deviation of the mean from the acceptedreference value of the quantity being measured. It does not vary if a measurement is repeated.

* The term "detection limit" can be used as a synonym for "Minimum DetectableConcentration (MDC)" or for "Minimum Detectable Value". When necessary, the MDC iscalculated to confirm that radioactivity levels are below a specified fraction of an establishedconcentration limit.

Uranerz is responsible for the validity of any analytical result j '•ed to demonstratecompliance. The Effluent and Environmental Monitoring P4 tiis dependent on radio-analyticallaboratories to show compliance, therefore prior onsite ai "tM aboratories may be conducted toensure that the laboratory is capable of completing des"tRIS . with accuracy and precision. Toensure quality of results Uranerz may require externfiU aboratorie ).articipate in performanceevaluations program or inter-laboratory comparjs Pf.eseprogram§•ke• check accuracy of resultsand identify possible biases. The results of th Vgram should be trac d trended as aperformance indicator of the laboratory.

6.1 Laboratory documentation

The format and content of lab zorts depend nothe contract requirement, regulatoryrequirements, and if additional 41 needed A11rorts should include the analyticalmethod used, date and time of anan's, ustody & sample receiving documentation,detection limits, actors, a analv certaiin Juding a confidence level.Log sheets as Ps are usef rec servari' ns of analysts, and otherconditions as tpconill afe'" ions pe _1'* can be done electronically or be

handwritten. "

7.0 ing Devices, and Test Equipment forProgram.the

used for~easuring radioactivity should be operated,%nalytical specification are met. The requirement for howL d maintained are found in the established SOPs.

7.1 Flow

All flow-rate mea•WALIFWes associated with the radiological effluent and environmentalmonitoring programy to determine actual flow rates at the conditions of temperatureand pressure under whic the instrument will operate. These flow rates are calibrated annually andthe flow rates are monitored throughout the year to determine if calibration is needed morefrequently.

7.2 Radiological Survey Instruments

Radiation survey instruments are calibrated to manufactures instruction and regulatoryrequirements as outlined in UP Instrumentation Quality Control and Procedures (RAD-SOP-04).Instruments are externally calibrated using certified reference materials of known and documented



value traceable to a national standards body, such as the National Institute of Standards andTechnology (NIST).

Upon reception of instruments sent for calibration, an internal review of the calibration isperformed to ensure no harm came to the instrument during transit. Check sources are used forinstrument reliability checks as described in HP Instrumentation Quality Control and Procedures(RAD-SOP-04). Calibration QC checks are tracked and compared with predetermined ranges ofacceptable performance.

Background counting rates are performed on regular, predefi&Mrequencies for instruments inroutine use. Instrument backgrounds used to determine a Unt rate should replicate actualsample measurement conditions as closely as possible in appropriate sample containersand geometries).

7.3 Sampling Equipment and Containers

Sampling equipment to make precise mea ents, such as thermom balances, conductivitymeters, and sample collection containers are a'"ted acco ing to manu terecommendations or using best practices as .ate tp requirement se quality

controls are outlined in individ Ps for each ii'

8.0 Assessments, Audits, and Surveilla

Assessments, audits, a eillace ar Is use aiuate t ectiveness of the QA/QCprogram, and to con ...... Hof the r logic nd en .t onmental monitoring

program. The poli roces or perfo n -ran e radiological and environmentalmonitoring prograr outlined .stablishea ard operatin procedures ALARA Program(RAD-SOP-02), and iting Staard (ADM- •.-02). It is the responsibility of both managementand empi to parti c dfse s, audi rveillance, and inspections.

n of Insp Auditors

ke minimum qua. cation >n experience levels required of personnel assigned theri.i'sibility of co ning ions, assessments, surveillances, and audits are described

in O ization and inistratibi of the Radiation Safety Program (RAD-SOP-01).Supervt.s having res fusibility in the area under review will document and review theresults o s e activiti

It is the resp nthe RSO and the radiation safety staff to conduct radiation safetysurveillances an •estigations to ensure occupational exposures are as far below thespecified limits as is reasonably achievable. The RSO is assigned sufficient authority toenforce safe ALARA operations, and employees are trained to understand and apply theALARA philosophy.

8.2 Annual Audit: Verification and Validation of License Compliance and ALARA

A comprehensive review of the radiation protection and ALARA program is performedannually. The audit is conducted by individuals that are knowledgeable concerning radiation



protection programs at uranium recovery facilities. The ESH or RSO assists the audit team,but is not be a member of the team and does not assist in the writing of the ALARA AuditReport.

The purpose of the audit should be to (1) determine the effectiveness of the radiation safetyand ALARA program including veracity of radiation measurements and calculations, (2)ensure compliance with applicable regulations, procedures, and policies,(3) ascertain trendsin employee and public exposure, potential explanations as well, (4) Look for methods tofurther mitigate employee and public exposure to radionuclides. The report is submitted tocorporate management and the report's findings and the' .plications should be discussedwith all employees during annual radiation safety tr

The Annual ALARA Audit Report shall specif trends in personnel exposuresfor identifiable categories of workers and ty, operati ctivities, whether equipmentfor exposure control is being properly us rintained, an cted, and recommend waysto further reduce personnel exposures; ranium and its daug' s. The report should alsosummarize:

* Employee exposure record-,* Bioassay results l" ,* Inspection re aily, week* Documented tr " vities• Radiation safety tiai* Radiological survey d sa .1 data"3

" R•,,••

• -\Ii overexpo• ,- •-ncedures'-, w .V,23

,ýgergenc, Sjarednes

8.3 Routine Ope ra Ins ns

Dai ectosre performed as outlined in Operational Radiation Safety

Progra

Weekly Ipi ctions

ey :ctions are performed as outlined in Operational Radiation SafetyP 1 D-SOP-3).

8.3.3 Monthly Report

The RSO provides a monthly report as outlined in Operational Radiation SafetyProgram (RAD-SOP-3).

8.4 Safety and Environmental Review Panel (SERP)

The Safety and Environmental Review Panel is responsible for monitoring any proposedchange in the facility or process, making changes to procedure, and conducting tests or



experiments not contained in the current NRC license. No license amendment or NRCapproval is needed in the SERP process as long as they do not conflict with any requirementsspecifically stated in the license or impair licensee's ability to meet all applicable NRCregulation, there is non-degradation in the essential safety or environmental commitments inthe license application or those provided in an approved reclamation plan, and they areconsistent with NRC conclusions regarding actions analyzed and selected in the facilityenvironmental assessment. An annual report that describes all changes, tests, or experimentsincluding a summary of the SERP evaluation of each change will be submitted to the NRC.

8.5 Documentation and Record Retention for Assessments, ,1,veys, and Audits

All assessments, audits, and surveillances are documented and a record of all assessment,audits, surveillance findings, corrective action sandf'irni closeouts are maintained on siteas specified in ALARA Program (RAD-SOP N-02

9.0 Preventive and Corrective Actions

Continuous improvement processes are impleme .,to ensureAlality of m66ements and evolutionof the QAP are maintained as necessary.

Deficiencies and non-conformance• ai•f'tified through' . ssment, audits, inspections, andsurveillance. Input to management frot e~s r allovdtions to be taken to correct deficienciesand identify more efficient methods of I oph g•tasks. C6i~etive action is taken whenconditions fall outside quahty or regulatcP ccept C tria. Tl rrective action processinvolves the basic et•el.,,

* 1dentif n an~ entationa* ClassifpiQn" Cause ana x]\,,J.,

*- Cop'riections . • •

SC losurt \

Fi and correcti ca•tions artocumented, tracked, and reported to management orregulateil.agencies if needed. Follow reviews are performed to verify the effectiveness andadequacfy e correctiv L$tion. Violations or corrective actions should be reviewed bypersonnel , ý4ihave the autIIirity to correct the problem.

RESPONSIBILITY •,

It is the responsibility of all personnel at Uranerz to achieve quality, identify problems, and recommendimprovements. Uranerz management establishes and cultivates principles and practices that integrateQAP requirements and performance standards into their management approach and control systems.

TRAINING

Personnel are trained on the QAP during task-specific and SOP training. Additional training is requiredfor certain tasks under this SOP. Training is specified in applicable SOPs.



ADDENDA

Chain of Custody examples

REFERENCES

10 CFR 20, Part M10 CFR 40.60ADM-SOP-02 Auditing StandardADM-SOP-03 Recordkeeping StandardADM-SOP-04 Standard Operating Procedure and Log SheeENV-SOP-18 Radiological Effluent and Environmental M . .ogramNRC License Condition 11.6NRC Regulatory Guide 4.15, Quality Assurance N

RAD-SOP-01 Organization and Administration of-tkadiation Safety mRAD-SOP-02 ALARA ProgramRAD-SOP-03 Operational Radiation Safety Progr'i-.RAD-SOP-04 HP Instrumentation Quality Control a 4,lced •,RAD-SOP-05 Contamination Contro ersonnel Mo '"•RAD-SOP-06 Decontamination and Equipment aterials for Unrestricted UseRAD-SOP-07 Transportation and Handl•.nioactive 1RAD-SOP- 14 Radiation Dose AssessmeRAD-SOP-3 Operationa *ation Safe gramSFT-SOP-31 Task Tr' jSFT-SOP-32 Urane, - love

ENEýRGYLABOFIý

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Visit our web site at www.enercvtab.com for additional Informnation, downloalable fee schedule, forms. and links.

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uranerz energy corporation - submittal of draft quality ... · effective date: october 1, 2013...

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