ML25055A058
| ML25055A058 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/2025 |
| From: | Huda Akhavannik, Douglas Mandeville NRC/NMSS/DMSST |
| To: | |
| References | |
| Download: ML25055A058 (1) | |
Text
Abandoned Uranium Mine (AUM)
Waste Remediation Guidance Development February 27, 2025, Public Meeting Huda Akhavannik, Project Manager NRC Office of Nuclear Materials Safety and Safeguards Division of Materials Safety, Security, State, and Tribal Programs Douglas Mandeville, Senior Project Manager NRC Office of Nuclear Materials Safety and Safeguards Division of Decommissioning, Uranium Recovery and Waste Programs 1
Agenda
2 Background
Definitions Review Considerations Notifications: Initial and Demobilization Reciprocity Future Activities Q&A
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Background===
3 On June 28, 2023, the NRC staff issued SECY-23-0055, Options for Licensing Emerging Technologies Used for Remediation of Mine Waste, which included four options on licensing emerging technologies used for remediation of abandoned uranium mine waste. (ML25017A229)
On September 25, 2024, the Commission approved Option 2B in SRM-SECY 0055 to license emerging technologies under a source material framework in 10 CFR Part 40 via a service provider license. (ML23121A271)
The NRC established a joint NRC and Agreement State working group to meet the SRM requirements.
Agreement State representatives from Colorado, Utah, Washington, and Wyoming
SRM Direction 4
Develop ore definition in consultation with public.
Develop license conditions as appropriate.
Limit authorized use of AUM waste remediation technology to verified AUMs.
Require licensee to notify the NRC of the commencement of remediation activities prior to installing equipment and beginning operations at an AUM temporary job site and after remediation is complete.
Require service provider licensee provide financial assurance, consistent with 10 CFR 40.36.
Maintain publicly available list of remediation sites including the status of remediation up to and including verification that site release criteria has been met.
Discusses considering an applicant proposed pilot project to provide a useful initial approach to licensing and to keep Commission informed of progress from any first-of-a-kind application.
Expected Working Group Products
- Update RIS 2000-23, Recent Changes to Uranium Recovery Policy (ML003773008) which contains definition of ore with updated definition.
- Develop Interim Staff Guidance (ISG) to NUREG-1556, Volume 18, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses (ML17242A055)
- Provide supplemental information to Volume 18, provide appropriate references to other guidance documents, and will provide additional definitions besides ore.
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Definition Challenges
- Meeting Commission direction while minimizing impacts to existing regulatory framework in 10 CFR Part 40, Appendix A, for uranium milling activities.
- Minimizing impacts to existing NRC and Agreement State regulations and legislation. The working group has been reviewing existing legislation and definitions.
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Proposed Definitions: Ore
- Option A
- Ore is a natural or native matter, other than abandoned uranium mine waste, that may be mined and treated for the extraction of any of its constituents or any other matter from which source material is extracted in a licensed uranium or thorium mill.
- Option B
- Source Material Ore means ores processed primarily for their source material content at a licensed uranium or thorium mill. Source Material Ore includes (i) natural or native ores; and (ii) other approved feedstocks. Source Material Ore does not include abandoned uranium mine waste unless approved as an Alternate Feed [or under subsection (ii)].
- Alternate Feed means any approved feedstock within the definition of Source Material Ore, subsection (ii).
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Proposed Definitions: Abandoned Uranium Mine
- Option A
- Abandoned uranium mine means a mine where there was documented production of uranium or thorium and operations have ceased for a minimum of 5 years with no evidence the operator plans to resume active mining and lacks financial assurance or a responsible party.
- Option B
- Abandoned uranium mine means a mine where there was documented production of uranium or thorium, and that the site is no longer in use for that purpose.
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Proposed Definitions: Abandoned Uranium Mine Waste
- Option A
- Abandoned Uranium Mine (AUM) waste means waste rock removed from its place of deposit in nature containing uranium or thorium that: (1) is located at an abandoned uranium mine, (2) presents a radiological hazard to public health and safety and the environment, and (3) requires remediation to meet a state, local, or federal standard for protection of public health or the environment from a radiological hazard.
- Option B
- Abandoned Uranium Mine (AUM) waste means waste rock material containing uranium or thorium that: (1) exists at a uranium mine that has been abandoned for a minimum of 5 years (2) presents a radiological hazard to public health and safety and the environment, and (3) requires remediation to meet a state, local, or federal standard for protection of public health or the environment from a radiological hazard.
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NUREG-1556, Vol. 18 ISG
- Reference Rev. 1 of RIS 2000-23 and updated definition of ore.
- Describe considerations for a safety review specific to licensing remediation of an abandoned uranium mine that are not already described in Vol. 18.
- Describe considerations for NRC environmental review.
- Provide considerations for Agreement States with respect to reciprocity and environmental review.
- Provide considerations for NRC and Agreement States with respect to Tribal interaction.
- Provide any license conditions.
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NUREG-1556, Vol. 18 ISG
- The ISG will refer to various NRC guidance documents including:
- NUREG-1556, Vol. 12, Rev. 1, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Possession Licenses for Manufacturing and Distribution, Final Report.
- NUREG-2126, Standard Review Plan for Conventional Uranium Mill and Heap Leach Facilities, Draft Report for Comment.
- NUREG-1569, Standard Review Plan for In Situ Leach Uranium Extraction License Applications, Final Report.
- NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs.
- NUREG 1757, Consolidated Decommissioning Guidance.
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Considerations for a Service Provider License
- Service provider licensee can be authorized to perform work at temporary jobsites within the jurisdiction of the licensing agency.
The license does not specify an exact location where the work will be performed.
- How would inspectors access the site?
- When you do not specify an exact location, how do you meet environmental requirements? Consultations?
- How do you confirm that characteristics of a temporary job site are consistent with information provided relative to the safety review?
- How do you confirm adequate financial assurance for specific temporary job sites?
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Using Notifications as a Licensing Tool
- The application may not be able to address all possible safety, environmental, and tribal considerations without specifying the location of a temporary jobsite. However, the application can describe reasonable bounded conditions for NRC approval of the initial service provider license with license conditions that supplemental information will be provided through notifications for NRC review.
- Notifications are a regulatory tool providing the NRC with required site-specific safety and environmental information.
- The SRM directs staff to incorporate a requirement for the licensee to notify the NRC of the commencement of remediation activities prior to installing equipment and beginning operations at an AUM temporary job site and after remediation is complete.
- NRC guidance will provide for initial notifications and demobilization notifications.
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Initial Notifications: Addresses Where the Licensed Material Will be Used or Possessed 14 In advance of commencing work at a temporary job site certain information would need to be provided to the regulatory authority:
The licensee would need to provide specific means of identification, such as GPS coordinates to allow for inspector access to project site.
Anticipated date(s) of mobilization and start of operations as well as the anticipated duration of operations.
Initial Notifications: Radioactive Material -
Unsealed Radioactive Material 15 Preliminary data developed by the applicant for each project site to include concentrations of U and Th in the waste rock and the surface soils prior to mobilization, waste rock volumes expected to be processed and the anticipated number of treatment units, and survey data used to establish background radiation levels that will be used in subsequent public dose calculations.
Approximate mass of source material that the applicant will possess (this can later be refined for inventory and material accountability).
Methodology used to determine that the project site will meet NRC release criteria, including justifications based on land use in the vicinity of the site and other site characteristics for scenarios and parameters used to calculate public dose.
Initial Notifications: Environmental A description of the site to include anticipated land disturbance activities (e.g., constructing temporary roadways, grading of soil for equipment placement, approximate volume of soils/waste rock to be processed, whether large volumes of soil/waste rock will be moved at the project site to facilitate processing).
Information developed by the licensee regarding consultations with property owners and government representatives concerning any native or endangered species at the project site as well as cultural or historical information of interest and existing and proposed future land use.
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Initial Notification: Financial Assurance 17 An updated site-specific decommissioning cost estimate, as applicable.
A certification that financial assurance for decommissioning has been provided in an amount that is at least that of the updated decommissioning cost estimate.
Demobilization Notification: Waste Management When the licensee has completed operations at a temporary job site certain information would need to be provided to the regulatory authority:
Final data and analysis results for materials used and processed at the site in addition to any remaining materials on site (should include concentrations of source material and total volume).
Description of how any materials used in processing was dispositioned (e.g., remains onsite, transferred to other licensee for disposal, etc.).
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Demobilization Notification: Termination of Activities (Decommissioning)
Final survey data and methodology used to determine that the project site meets NRC release criteria, including justifications based on land use in the vicinity of the site and other site characteristics for scenarios and parameters used to calculate public dose.
In addition, the licensee would have to demonstrate any residual radioactivity remaining on the site is below licensable quantities.
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Considerations for Reciprocity
- A service provider licensee can work in other jurisdictions under reciprocity.
- Compatibility: Agreement States can be more restrictive than the NRC to approve remediation activities in their state.
- Agreement States can have their own environmental and Tribal considerations separate from the NRC.
- Agreement States may have different notification requirements.
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Using NRC License for Reciprocity in Agreement State NUREG 1556, Vol. 19 provides guidance on reciprocity.
Licensee should contact Agreement State in advance to understand any additional Agreement State requirements.
Be aware that Agreement States need time to review and so notification for reciprocity should be submitted as soon as possible.
While under reciprocity, if licensed activities are not anticipated to be completed within the 180-day limit, the licensee would need to obtain a license from the Agreement State.
Notifications sent to both NRC and Agreement States even while licensee is in an Agreement State.
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Abandoned Uranium Mine Remediation Site List 22 The NRC intends to create a page on nrc.gov providing status updates on abandoned uranium mines undergoing remediation.
The NRC and Agreement States will work jointly to ensure this information is up-to-date.
Initial Notifications and Demobilization Notifications from licensees will provide the needed information for this website.
Next Steps
- Working group to review feedback from public and Government-to-Government meetings and prepare public meeting summary.
- Expecting to issue ISG and RIS 2000-23, Rev. 1 update for public comment by Fall 2025.
- Additional public meeting when guidance is issued for comment.
- Additional Tribal and Agreement State outreach.
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Questions?
Contact Information:
Huda Akhavannik Huda.Akhavannik@nrc.gov Douglas Mandeville Douglas.Mandeville@nrc.gov 24