Regulatory Guide 3.5

Standard Format and Content of License Applications for Uranium Mills

ML003740157
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Issue date:	11/30/1977
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1 ,4 November 1977 S&

1 U.S. NUCLEAR REGULATORY COMMISSION

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REGULATORY GUIDE

,e OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 3.5 STANDARD FORMAT AND CONTENT OF LICENSE

APPLICATIONS FOR URANIUM MILLS

A. INTRODUCTION

paragraph what information the

'plicant wishes to reference and hwsuch info n sprtinent.

In order to process or refine ores containing by weight 0.05% or more of uranium, after removal Changes to existing (lic e) pr s require the from their place of deposit in nature, an NRC Source issuance of an approp 'ate ense hendment. An Material License is required. An applicant for a new application for such nt should describe license or renewal of an existing license to receive, the proposed cha possess, and use source materials is required to pro- I

vide detailed information on his proposed facilities, G

PPLICATION

equipment, experience, and procedures. This infor- An app n

a uranium milling license mation is used by the Commission in determining shout

• ing Form NRC-2 in accordance whether the applicant's proposed activities will, wj4th

,

ments specified in § 40.31 of 10 CFR

among other things, result in undue risk to the health re uired by § 40.31(t() of 10 CFR Part 40,

and safety of the public. General guidance for filing m~lic on for a new license should be filed at an application is approved in § 40.31 of 10 CFR Part e_

__n for to cense ou ction for peciic icenes."Thee months prior to commencing construction

40, "Applications for Specific Licenses." The pur-'*i proposed mill. An application for renewal of pose of this guide is to provide specific guidan n existing license should be filed at least thirty days the format and content of an application for oir to the expiration of the existing license. Appli Source Material License authorizing uranium cations may be filed with the Director, Office of NU

activities. The information in this guide BecainmybefldwtthDrcoOfcefNu aveTi his gclear Materials Safety and Safeguards, U.S. Nuclear provide instructive guidance and sho not*

-

Regulatory Commission, Washington, D.C. 20555.

sidered a substitute for a careful ev ation Applications may also be filed in person at the Com proposed program by the mission's offices at 1717 H Street NW, Washing that the application clearly and adequate s

escribes ton, D.C. or 7915 Eastern Avenue, Silver Spring, the radiation safety procedes that will be followed.

Maryland.

Information not spe cal

.scussed in this guide The National Environmental Policy Act of 1969 should be included int I

n if it is an impor-

(83 Stat. 852), implemented by Executive Order tant part of an t'l diation protection pro-

11514 and the Council on Environmental Quality's gra

m. An inco n

lete liction will result in delay Guidelines of August 1, 1973 (38 FR 20550), re of issuance ens nd may result in denial of a quires that all agencies of the Federal Government license ic

0

prepare detailed environmental statements on propos Informa submitted to the Commission may be als for legislation and other major Federal actions incorporated the application by reference. How- significantly affecting the quality of the human envi ever, each reference should be clear and specific, ronment. The principal objective of the National En i.e., the reference should indicate by date, page, and vironmental Policy Act of 1969 is to build into the USNRC REGULATORY GUIDES

Comments should be sent to the Secretary of the Commission, US. Nuclear Regu Regulatory Guides are issued to describe and make available to the public methods latory Commission. Washington. D.C.

20555. Attention: Docketing and Service acceptable to the NRC staff of implementing specific parts of the Commission's Branch.

regulations, to delineate techniques used by the staff in evaluating specific problems The guides are issued in the following'ten broad divisions:

or postulated accidents, or to provide guidance to applicants. Regulatory Guides are not substitutes for regulations, and compliance with them is not required.

1. Power Reactors

6. Products Methods and solutions different from those set out in the guides will be accept-

2. Research and Test Reactors

7. Transportation able if they provide a basis for the findings requisite to the issuance or continuance

3. Fuels and Materials Facilities

8. Occupational Health of a permit or license by the Commission.

4. Environmental and Siting

9. Antitrust Review

5. Materials and Plant Protection

10. General Comments and suggestions for improvements in thest guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and Requests for single copies of issued guides (which may be reproduced) or for place to reflect new information or experience.

However, comments on this guideif ment on an automatic distribution list for single copies of future guides in specific received within about two months after its issuance, will be particularly useful in divisions should be made in writing to the US. Nuclear Regulatory Commission.

evaluating the need for an early revision.

Washington, D.C.

20555, Attention:

Director. Division of Document Control.

agency decisionmaking process an appropriate and careful consideration of environmental aspects of proposed actions, Title 10 CFR Part 51, "Licensing and Regulatory Policy and Procedures for Environ mental Protection,"

sets forth the NRC policy and procedures for the preparation and processing of en vironmental impact statements and related documents pursuant to section 102(2)(C) of the National En vironmental Policy Act of 1969 in connection with the Commission's licensing and regulatory activities.

The provisions of 10 CFR Part 51 and § 40.31(f) of

10 CFR Part 40, "Licensing of Source Material,"

require the submittal of environmental reports by ap plicants for NRC permits and licenses for certain facilities, including uranium mills. Thus, an applica tion for a uranium milling license must be accom panied by an environmental report.*

C. CONTENTS OF AN APPLICATION

The application should contain the information specified in items I through 8 of Form NRC-2. The information required in items 9 through 14 of Form NRC-2 should be incorporated into the various items identified below. Each subject should be treated in sufficient depth to permit the Commission independ ently to determine whether the applicant's proposed activities will be conducted in accordance with NRC

rules and regulations. All pages of the application should be numbered and dated.

1. PROPOSED ACTIVITIES

This section should briefly discuss the overall mill ing proposal for which a license is requested, includ ing the following: a brief description of the proposed mill and its location; the corporate entities involved;

the maximum design throughput of the mill; U3Os content of the ore to be processed; concentrate yield;

milling process; tailings management; estimated time schedules for construction and startup; and antici pated lifetime of the mill.

2. SITE CHARACTERISTICS

This section should provide information on the lo cation of the mill and a description of the geograph ical, demographic, meteorological, hydrological, seismological, and geological characteristics of the site and surrounding vicinity. Sufficient information should be provided to permit an independent evalua tion of site characteristics from a safety viewpoint.

Applications may reference the pertinent section in the accompanying environmental report, prepared in conformance with NRC Regulatory Guide 3.8.'

• NRC Regulatory Guide 3.8, "Preparation of Environmental Reports for Uranium Mills," provides specific guidance on the contents of art applicant's environmental report.

2.1 Geography and Demography

2.1.1 Geography A geographic description of the area in which the mill is located should be provided, including (1)

maps showing the location of the site with respect to State, county, and local subdivisions, plus nearby in habited areas and (2) maps (topographic, if available)

showing the mill, mill perimeter, tailings location, exclusion area boundary, company property, abutting and adjacent properties, nearby water bodies, and in habited areas, plus other relevant details.

2.1.2 Demography A description of the potentially affected population within a 5-mile radius of the mill should be provided.

Current resident population information, based on most recent census data, should be provided as well as the projected population for the anticipated life of the mill. Significant transient or seasonal population variations should be identified and discussed, includ ing bases for assumptions and projections.

2.2 Meteorology This section should provide a meteorological de scription of the site and surrounding area. Sufficient information should be included to permit an inde pendent evaluation by the NRC staff of atmospheric diffusion characteristics of the local area. The sources of information and data supplied should be stated and should include (1) diurnal and monthly av erages and extremes of temperature and humidity; (2)

monthly wind characteristics including speeds and di rection, annual joint frequency of wind speed, and direction by stability category; (3) data on precipita tion; and (4) frequency of occurrence and effects of storms.

2.3 Hydrology Sufficient information should be provided to allow an independent review to be made of all hy drologically related design bases, performance re quirements, monitoring specifications, and operating procedures important to safety. Identify the sources of the hydrological information, the types of data col lected, and the methods and frequency of collection.

2.3.1 Groundwater Describe the regional and local groundwater aquif ers, formations, sources, and sinks. Describe the re charge potential of the immediate plant area, includ ing vertical and horizontal permeabilities of the natu ral and modified terrain, as well as that of tailing areas. Describe the present and projected regional use; tabulate existing private users within the area in fluenced by the proposed activities and all local and regional public users (amounts, water levels, loca-

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tions, and drawdown); indicate gradients and sea sonal variations in groundwater levels beneath the site.

2.3.2 Surface Water Describe the location, size, shape, and other hy drologic characteristics of streams, rivers, lakes, marshes, estuaries, etc., of the environs. Include a description of any upstream and downstream river control structures and downstream water supply users (including location, amount, and purpose, e.g.,

domestic, agricultural), and provide a map (topo graphic, if available) showing major hydrologic fea tures of the area.

2.4 Geology and Seismology Provide the geologic and seismic characteristics of the area and site, the nature of the investigations per formed, the results of investigations, conclusions, and identification of information sources. Supple ment the written description with tables and legible graphics as appropriate.

2.4.1 Geology Describe the geologic aspects of the site. The dis cussion should note the broad features and general characteristics ot the site and environs including stratigraphy and structural geology. Describe charac teristics of the subsurface soil or rock including the identification and evaluation of zones of deformation that might act as conduits for contaminants.

2.4.2 Seismology Discuss the seismicity (including history) of the region. Where possible, associate seismic events with tectonic features identified in the geology discussion.

Furnish a regional earthquake epicenter map showing site location.

3. MILL PROCESS AND EQUIPMENT

Provide sufficient information in this section on the mill process and operating equipment to permit the independent assessment of the radiological protec tion factors associated with the proposed milling operations.

3.1 Mill Process Provide a quantitative flow diagram of the mill process showing the maximum mill throughput per unit time including the anticipated moisture content of the ore and the composition of all flow streams for each major step in the process.

3.2 Mill Equipment Provide a physical description and the operating characteristics for all major items of mill process equipment. Include a diagram of the mill layout indi cating areas and points where dusts, fumes, and gases are generated. The diagram should also show the lo cation of the ventilation, filtration, confinement, and dust collection systems referenced in item 4.1 and the location of radiation monitoring equipment refer enced in items 5.5(1) and 5.5(2).

3.3 Instrumentation Provide a description of all process instrumentatiot.

and control systems relevant to safety and all radia tion safety sampling and monitoring instrumentation, including their minimum specifications and operating characteristics. Also, describe and identify by make, model number, purpose, and location each radioac tive source and/or gauging device used throughout the mill for which a license is required under the pro visions of 10 CFR Part 30, "Rules of General Applicability to Licensing of Byproduct Material." *

The instrumentation associated with leak testing such sources and/or devices should be identified in this section.

4. WASTE MANAGEMENT SYSTEM

4.1 Gaseous Provide a description of all ventilation, filtration, confinement, and dust collection systems that are used during mill operations to control gaseous radioactive materials. Include the type, specifica tions, and locations of such systems, e.g., ore trans fer points, crushing, grinding, etc. Include an analy sis of the efficiency of the equipment as designed and operated to prevent radiation exposures to employees and to limit such exposures to as low as is reasonably achievable. Also, include a description of mill dis charge stacks, including stack heights, types and concentration of effluents discharged, and methods (i.e., scrubbers, filters, etc.) for controlling releases of radioactive materials and for limiting such releases to as low as is reasonably achievable.

4.2 Liquids and Solids

1. Where retention systems such as levees, dikes, ponds, etc., are used to prevent the release of liquid or solid wastes containing radioactive material to offsite areas, provide the information specified in the regulatory position of Regulatory Guide 3.11,

"Design, Construction, and Inspection of Embank ment Retention Systems for Uranium Mills" (appli cable information concerning this subject provided in section 2 above need not be repeated here).

• These sources will be authorized in the mill operating license rather than separate NRC byproduct material licenses.

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2. If effluents are to be released into waters of the United States, provide a discussion of the status of efforts to obtain a water quality certification under Section 401 and discharge permits under Section 402 of the Federal Water Pollution Control Act, as amended, or submit copies of these items if already issued.

4.3 Contaminated Equipment Provide a description of the methods for disposing of contaminated waste solids (such as filters, filter presses, obsolete or worn-out equipment) that are generated in the milling process.

5. OPERATIONS

Compliance with the statements, representations, and procedures provided in this section will normally be made a specific condition of the NRC operating license. Thus, the following should be considered as specific commitments on the part of the applicant for conducting mill operations and radiological protec tion programs. In order to facilitate administration of the license by the licensee and NRC, this section should be complete in itself, insofar as possible, without references to other submittals. Also, the bases for all programs addressed in this section, as well as demonstration of their adequacy, should be provided.

5.1 Corporate Organization and Administrative Procedures

1. Provide a detailed description of the applicant's organization, including authority and responsibility of each level of management and/or supervision in regard to development, review, approval, implemen tation, and adherence to operating procedures, radia tion safety programs, routine and nonroutine mainte nance activities, and changes in any of the above.

2. Describe the management control program and administrative procedures to ensure that all activities are conducted in accordance with written operating procedures that are approved and reviewed at speci fied frequencies by radiation safety staff. This pro gram should provide a method for ensuring that any nonroutine work or maintenance activity, not covered by an effective operating procedure, is conducted in accordance with a special work permit reviewed and approved by the radiation safety staff.

3. Describe the management audit and internal in spection program, including types and scopes of re views and inspections, frequencies, action leyels, and corrective action measures in regard to the foregoing activities. Also identify by management position the individual responsible for each phase of the audit and inspection program.

4. Provide a detailed description of the program for ensuring that employee exposures (both airborne and external radiation) and effluent releases are "as low as is reasonably achievable."

5.2 Qualifications Provide a description of the minimum qualifica tions and experience required of personnel to hold positions in the applicant's organization assigned the responsibility for developing, conducting, and ad ministering the radiation safety program for the mill.

Also, provide as an appendix the qualifications of the individuals currently holding these positions.

5.3 Training Provide a description of the employee radiological protection training program addressing the following:

content of the initial training or indoctrination, test ing, on-the-job training, and extent and frequency of retraining. As an appendix, provide a copy of the written radiological safety instructions provided em ployees. These instructions should include provisions for personal hygiene including washing, contamina tion surveying prior to eating or leaving the mill, in structions for wearing personnel monitoring devices and respirators, and instructions for good housekeep ing requirements and for cleaning up dust and spills within the mill.

5.4 Security Provide a description of the method for preventing unauthorized entry to both the mill and the tailings systems.

5.5 Radiation Safety Provide a description of the radiation safety pro gram that has been developed for determining that occupational radiation exposures and effluent releases will be as low as is reasonably achievable. Include the following:

1. A description of the methods, instrumentation, and equipment for determining exposures of employ ees to external radiation during normal and non routine operations, maintenance, and cleanup ac tivities. Provide the type of surveys conducted, criteria for determining survey locations, frequency of surveys, action levels, management audits, and corrective action requirements. For personnel monitoring devices such as film badges, indicate the number and category of personnel involved in the program and the sensitivity and range of the devices.

For survey instruments, provide instrument sen sitivities, ranges, and calibration methods (in an ap pendix) and frequencies.

3.5-4

2. A description of the sampling program that is followed to determine concentrations of airborne radioactive materials (including radon) within the mill during routine and nonroutine operations, maintenance, and cleanup activities. In the descrip tion of the sampling program include a. The criteria for determining sampling loca tions with respect to process operation: and personnel occupancy and b. The frequency of sampling, type of analysis, sensitivity of overall sampling and analysis, action levels, management audits, corrective action re quirements, and instrumentation calibration fre quency. Procedures for sample analysis and instru ment calibration should be included as an appendix.

3. A description of the procedure followed in de termining the intake of radioactive materials, in con formance with § 20.103 of 10 CFR Part 20, for each employee who occupies areas where airborne radioac tive materials exist. Include exposures incurred dur ing nonroutine operations, maintenance, and cleanup activities as well as routine activities.

4. A description of the bioassay program to be conducted to confirm the results derived from the programs identified in items 2 and 3 above. Indicate the number and category of personnel involved in the program, the types and frequencies of bioassays per formed, and action level criteria to be applied to bioassay results.

5. A description of the survey program to deter mine that employees (plus their workclothes or coveralls, etc.) entering clean areas (lunchrooms, of fices, etc.) of the mill or leaving the mill site are not contaminated with radioactive materials. Include good housekeeping and cleanup requirements and specifications in mill process areas to control con tamination, frequency of surveys of clean areas, sur vey methods, and minimum sensitivity, range, and calibration frequency of survey equipment. Provide contamination criteria or action levels for clean areas and for the release of materials, equipment, and workclothes to clean areas or from the site. Proce dures for instrument calibration should be included as an appendix.

6.* A description of the survey program, methods, and procedures for determining concentrations and quantities of airborne radioactive materials released to the environs and a description of the environmental monitoring program to be conducted plus the techni cal basis therefor (i.e., a correlation of stack heights, meteorological characteristics, etc.) to determine en vironmental concentrations.

• 40 CFR Chapter 1, Part 190, and Regulatory Guide 4.14,

"Measuring, Evaluating, and Reporting Radioactivity in Re leases of Radioactive Materials in Liquid and Airborne Effluents from Uranium Mills," should be reviewed in connection with this section.

For both environmental and effluent monitoring, the frequency of sampling and analysis, the types and sensitivity of analysis, action levels and corrective action requirements, and the minimum number and criteria for locating environmental and effluent monitoring stations should be provided. Proposed lo cations should be indicated on a figure of the mill and surrounding area in an appendix.

7.* A description of the liquid effluent survey pro gram to determine if process effluents are reaching subterranean or surface water supplies. This should include the technical basis therefor, the minimum number of monitoring locations, the criteria for locat ing sampling stations, the frequency of sampling, and action levels and corrective action requirements. Pro vide the step-by-step procedure for sample analysis of natural uranium, radium-226, and thorium-230 as an appendix. Also, the proposed monitoring locations should be shown on a figure of the mill and surround ing area in an appendix.

8. A description of the radiation safety program associated with the radioactive sources and. gauges identified in section 3.3 above. Include methods and frequencies for leak testing the radioactive source.

9. A description of the interim stabilization proce dures (during milling operations) to eliminate the blowing of tailings from the tailings retention system to unrestricted areas and the ore dust from the ore piles should be provided, including the demonstration of the adequacy of these procedures under potential wind and weather conditions at the site location.

10. Provide the minimum performance specifica tions, such as filtration or scrubber efficiency and air flow, for operating the mill ventilation, filtration, confinement, and dust collection systems throughout the mill and associated laboratories at their rea sonably expected best performance and the frequency of tests and inspections to ensure that these specifica tions are being met.

11. Provide a decommissioning program that in cludes reclamation of the mill site at the termination of milling activities and the surety arrangements to ensure that sufficient funds are available to complete this decommissioning program.

12. Provide a tailings management and reclama tion program addressing the following performance objectives:

a. Reduce direct gamma radiation from the im poundment area to essentially background.

b. Reduce the radon emanation rate from the impoundment area to about twice the emanation rate in the surrounding environs.

c. Eliminate the need for on ongoing monitoring and maintenance program following successful reclamation.

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d. Provide surety arrangements to ensure that suf ficient funds are available to complete the full recla mation plan.

6. ACCIDENTS

A spectrum of potential mill accidents ranging from trivial to serious should be established by classes of occurrence, and each class of accidents should be appropriately evaluated. The evaluation should include a discussion of measures that have been implemented to prevent accidents and a demon stration of the adequacy of the methods. Emergency plans and training for coping with accidents should also be described. For example, potential accidental fires should be discussed in terms of occurrence, pre vention, detection and suppression mechanisms (both manual and automatic), and emergency plans for cop ing therewith. The adequacy of the program should also be discussed.

7. QUALITY ASSURANCE

The quality assurance program for all. phases of the milling project including design, construction, start- up and operation, and the radiation safety program (including the in-plant, effluent, and environmental monitoring programs)* should be defined and dis cussed. Also discuss the corrective action measures established to ensure that conditions adverse to qual ity are identified and corrected and that the cause of significant conditions adverse to quality is deter mined and corrective action taken to preclude repeti tion.

8. EVALUATION OF ALTERNATIVES

Where the proposed course of action was based on the consideration of various alternatives, the benefit-cost analysis used in arriving at the "as low as is reasonably achievable" concept should be pre sented, and the rationale for the recommended course of action should be included.

• The NRC staff is preparing a regulatory guide on quality as surance for radiological effluent and environmental monitoring programs that is scheduled to be published for comment in De cember 1977.

3.5-6

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