Regulatory Guide 3.5

Standard Format and Content of License Applications for Uranium Mills

ML003740157
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Issue date:	11/30/1977
From:	Office of Nuclear Regulatory Research
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Revision 1 tilN REQ 1 ,4 November 1977 S& 1 U.S. NUCLEAR REGULATORY COMMISSION

,e C REGULATORY GUIDE S)

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 3.5 STANDARD FORMAT AND CONTENT OF LICENSE

APPLICATIONS FOR URANIUM MILLS

A. INTRODUCTION

paragraph what information the wishes to

'plicant 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 §for 40.31 of 10 CFR Part icenes."Thee peciic e_ __nmonths for prior to cense to commencing ouconstruction ction

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 activities. License authorizing The information in this guide uranium cations may be filed with the Director, Office of NU

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 s adequate 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 gram. An inco leten 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 Branch.

acceptable to the NRC staff of implementing specific parts of the Commission's 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 2.1 Geography and Demography careful consideration of environmental aspects of proposed actions, Title 10 CFR Part 51, "Licensing 2.1.1 Geography and Regulatory Policy and Procedures for Environ A geographic description of the area in which the mental Protection," sets forth the NRC policy and mill is located should be provided, including (1)

procedures for the preparation and processing of en maps showing the location of the site with respect to vironmental impact statements and related documents State, county, and local subdivisions, plus nearby in pursuant to section 102(2)(C) of the National En habited areas and (2) maps (topographic, if available)

vironmental Policy Act of 1969 in connection with showing the mill, mill perimeter, tailings location, the Commission's licensing and regulatory activities.

exclusion area boundary, company property, abutting The provisions of 10 CFR Part 51 and § 40.31(f) of and adjacent properties, nearby water bodies, and in

10 CFR Part 40, "Licensing of Source Material," habited areas, plus other relevant details.

require the submittal of environmental reports by ap 2.1.2 Demography plicants for NRC permits and licenses for certain facilities, including uranium mills. Thus, an applica A description of the potentially affected population tion for a uranium milling license must be accom within a 5-mile radius of the mill should be provided.

panied by an environmental report.* Current resident population information, based on most recent census data, should be provided as well C. CONTENTS OF AN APPLICATION as the projected population for the anticipated life of the mill. Significant transient or seasonal population The application should contain the information variations should be identified and discussed, includ specified in items I through 8 of Form NRC-2. The ing bases for assumptions and projections.

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 2.2 Meteorology sufficient depth to permit the Commission independ ently to determine whether the applicant's proposed This section should provide a meteorological de activities will be conducted in accordance with NRC scription of the site and surrounding area. Sufficient information should be included to permit an inde rules and regulations. All pages of the application pendent evaluation by the NRC staff of atmospheric should be numbered and dated.

diffusion characteristics of the local area. The sources of information and data supplied should be

1. PROPOSED ACTIVITIES stated and should include (1) diurnal and monthly av This section should briefly discuss the overall mill erages and extremes of temperature and humidity; (2)

ing proposal for which a license is requested, includ monthly wind characteristics including speeds and di ing the following: a brief description of the proposed rection, annual joint frequency of wind speed, and mill and its location; the corporate entities involved; direction by stability category; (3) data on precipita the maximum design throughput of the mill; U3Os tion; and (4) frequency of occurrence and effects of content of the ore to be processed; concentrate yield; storms.

milling process; tailings management; estimated time schedules for construction and startup; and antici pated lifetime of the mill. 2.3 Hydrology Sufficient information should be provided to allow

2. SITE CHARACTERISTICS an independent review to be made of all hy This section should provide information on the lo drologically related design bases, performance re quirements, monitoring specifications, and operating cation of the mill and a description of the geograph ical, demographic, meteorological, hydrological, procedures important to safety. Identify the sources of the hydrological information, the types of data col seismological, and geological characteristics of the site and surrounding vicinity. Sufficient information lected, and the methods and frequency of collection.

should be provided to permit an independent evalua 2.3.1 Groundwater tion of site characteristics from a safety viewpoint.

Applications may reference the pertinent section in Describe the regional and local groundwater aquif the accompanying environmental report, prepared in ers, formations, sources, and sinks. Describe the re conformance with NRC Regulatory Guide 3.8.' 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

• NRC Regulatory Guide 3.8, "Preparation of Environmental use; tabulate existing private users within the area in Reports for Uranium Mills," provides specific guidance on the fluenced by the proposed activities and all local and contents of art applicant's environmental report. regional public users (amounts, water levels, loca-

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tions, and drawdown); indicate gradients and sea equipment. Include a diagram of the mill layout indi sonal variations in groundwater levels beneath the cating areas and points where dusts, fumes, and gases site. are generated. The diagram should also show the lo cation of the ventilation, filtration, confinement, and

2.3.2 Surface Water dust collection systems referenced in item 4.1 and the location of radiation monitoring equipment refer Describe the location, size, shape, and other hy enced in items 5.5(1) and 5.5(2).

drologic characteristics of streams, rivers, lakes, marshes, estuaries, etc., of the environs. Include a description of any upstream and downstream river 3.3 Instrumentation control structures and downstream water supply users (including location, amount, and purpose, e.g., Provide a description of all process instrumentatiot.

domestic, agricultural), and provide a map (topo and control systems relevant to safety and all radia graphic, if available) showing major hydrologic fea tion safety sampling and monitoring instrumentation, tures of the area. including their minimum specifications and operating characteristics. Also, describe and identify by make,

2.4 Geology and Seismology model number, purpose, and location each radioac tive source and/or gauging device used throughout Provide the geologic and seismic characteristics of the mill for which a license is required under the pro the area and site, the nature of the investigations per visions of 10 CFR Part 30, "Rules of General formed, the results of investigations, conclusions, Applicability to Licensing of Byproduct Material." *

and identification of information sources. Supple The instrumentation associated with leak testing such ment the written description with tables and legible sources and/or devices should be identified in this graphics as appropriate.

section.

2.4.1 Geology Describe the geologic aspects of the site. The dis cussion should note the broad features and general 4. WASTE MANAGEMENT SYSTEM

characteristics ot the site and environs including stratigraphy and structural geology. Describe charac 4.1 Gaseous teristics of the subsurface soil or rock including the Provide a description of all ventilation, filtration, identification and evaluation of zones of deformation that might act as conduits for contaminants. confinement, and dust collection systems that are used during mill operations to control gaseous

2.4.2 Seismology radioactive materials. Include the type, specifica tions, and locations of such systems, e.g., ore trans Discuss the seismicity (including history) of the fer points, crushing, grinding, etc. Include an analy region. Where possible, associate seismic events with sis of the efficiency of the equipment as designed and tectonic features identified in the geology discussion.

operated to prevent radiation exposures to employees Furnish a regional earthquake epicenter map showing and to limit such exposures to as low as is reasonably site location.

achievable. Also, include a description of mill dis charge stacks, including stack heights, types and concentration of effluents discharged, and methods

3. MILL PROCESS AND EQUIPMENT (i.e., scrubbers, filters, etc.) for controlling releases Provide sufficient information in this section on the of radioactive materials and for limiting such releases mill process and operating equipment to permit the to as low as is reasonably achievable.

independent assessment of the radiological protec tion factors associated with the proposed milling

4.2 Liquids and Solids operations.

1. Where retention systems such as levees, dikes,

3.1 Mill Process ponds, etc., are used to prevent the release of liquid or solid wastes containing radioactive material to Provide a quantitative flow diagram of the mill offsite areas, provide the information specified in process showing the maximum mill throughput per the regulatory position of Regulatory Guide 3.11, unit time including the anticipated moisture content

"Design, Construction, and Inspection of Embank of the ore and the composition of all flow streams for ment Retention Systems for Uranium Mills" (appli each major step in the process.

cable information concerning this subject provided in section 2 above need not be repeated here).

3.2 Mill Equipment Provide a physical description and the operating

• These sources will be authorized in the mill operating license characteristics for all major items of mill process rather than separate NRC byproduct material licenses.

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2. If effluents are to be released into waters of the 4. Provide a detailed description of the program for United States, provide a discussion of the status of ensuring that employee exposures (both airborne and efforts to obtain a water quality certification under external radiation) and effluent releases are "as low Section 401 and discharge permits under Section 402 as is reasonably achievable."

of the Federal Water Pollution Control Act, as amended, or submit copies of these items if already issued. 5.2 Qualifications

4.3 Contaminated Equipment Provide a description of the minimum qualifica tions and experience required of personnel to hold Provide a description of the methods for disposing positions in the applicant's organization assigned the of contaminated waste solids (such as filters, filter responsibility for developing, conducting, and ad presses, obsolete or worn-out equipment) that are ministering the radiation safety program for the mill.

generated in the milling process. Also, provide as an appendix the qualifications of the individuals currently holding these positions.

5. OPERATIONS 5.3 Training Compliance with the statements, representations, Provide a description of the employee radiological and procedures provided in this section will normally protection training program addressing the following:

be made a specific condition of the NRC operating content of the initial training or indoctrination, test license. Thus, the following should be considered as ing, on-the-job training, and extent and frequency of specific commitments on the part of the applicant for retraining. As an appendix, provide a copy of the conducting mill operations and radiological protec written radiological safety instructions provided em tion programs. In order to facilitate administration of ployees. These instructions should include provisions the license by the licensee and NRC, this section for personal hygiene including washing, contamina should be complete in itself, insofar as possible, tion surveying prior to eating or leaving the mill, in without references to other submittals. Also, the structions for wearing personnel monitoring devices bases for all programs addressed in this section, as and respirators, and instructions for good housekeep well as demonstration of their adequacy, should be ing requirements and for cleaning up dust and spills provided. within the mill.

5.1 Corporate Organization and 5.4 Security Administrative Procedures Provide a description of the method for preventing

1. Provide a detailed description of the applicant's unauthorized entry to both the mill and the tailings organization, including authority and responsibility systems.

of each level of management and/or supervision in regard to development, review, approval, implemen tation, and adherence to operating procedures, radia 5.5 Radiation Safety tion safety programs, routine and nonroutine mainte nance activities, and changes in any of the above. Provide a description of the radiation safety pro gram that has been developed for determining that

2. Describe the management control program and occupational radiation exposures and effluent releases administrative procedures to ensure that all activities will be as low as is reasonably achievable. Include are conducted in accordance with written operating the following:

procedures that are approved and reviewed at speci fied frequencies by radiation safety staff. This pro 1. A description of the methods, instrumentation, gram should provide a method for ensuring that any and equipment for determining exposures of employ nonroutine work or maintenance activity, not covered ees to external radiation during normal and non by an effective operating procedure, is conducted in routine operations, maintenance, and cleanup ac accordance with a special work permit reviewed and tivities. Provide the type of surveys conducted, approved by the radiation safety staff. criteria for determining survey locations, frequency of surveys, action levels, management audits, and

3. Describe the management audit and internal in corrective action requirements. For personnel spection program, including types and scopes of re monitoring devices such as film badges, indicate the views and inspections, frequencies, action leyels, and number and category of personnel involved in the corrective action measures in regard to the foregoing program and the sensitivity and range of the devices.

activities. Also identify by management position the For survey instruments, provide instrument sen individual responsible for each phase of the audit and sitivities, ranges, and calibration methods (in an ap inspection program. pendix) and frequencies.

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2. A description of the sampling program that is For both environmental and effluent monitoring, followed to determine concentrations of airborne the frequency of sampling and analysis, the types and radioactive materials (including radon) within the sensitivity of analysis, action levels and corrective mill during routine and nonroutine operations, action requirements, and the minimum number and maintenance, and cleanup activities. In the descrip criteria for locating environmental and effluent tion of the sampling program include monitoring stations should be provided. Proposed lo cations should be indicated on a figure of the mill and a. The criteria for determining sampling loca surrounding area in an appendix.

tions with respect to process operation: and personnel occupancy and 7.* A description of the liquid effluent survey pro gram to determine if process effluents are reaching b. The frequency of sampling, type of analysis, subterranean or surface water supplies. This should sensitivity of overall sampling and analysis, action include the technical basis therefor, the minimum levels, management audits, corrective action re number of monitoring locations, the criteria for locat quirements, and instrumentation calibration fre ing sampling stations, the frequency of sampling, and quency. Procedures for sample analysis and instru action levels and corrective action requirements. Pro ment calibration should be included as an appendix. vide the step-by-step procedure for sample analysis of

3. A description of the procedure followed in de natural uranium, radium-226, and thorium-230 as an termining the intake of radioactive materials, in con appendix. Also, the proposed monitoring locations formance with § 20.103 of 10 CFR Part 20, for each should be shown on a figure of the mill and surround employee who occupies areas where airborne radioac ing area in an appendix.

tive materials exist. Include exposures incurred dur 8. A description of the radiation safety program ing nonroutine operations, maintenance, and cleanup associated with the radioactive sources and. gauges activities as well as routine activities. identified in section 3.3 abov

e. Include methods and

4. A description of the bioassay program to be frequencies for leak testing the radioactive source.

conducted to confirm the results derived from the 9. A description of the interim stabilization proce programs identified in items 2 and 3 above. Indicate dures (during milling operations) to eliminate the the number and category of personnel involved in the blowing of tailings from the tailings retention system program, the types and frequencies of bioassays per to unrestricted areas and the ore dust from the ore formed, and action level criteria to be applied to piles should be provided, including the demonstration bioassay results.

of the adequacy of these procedures under potential

5. A description of the survey program to deter wind and weather conditions at the site location.

mine that employees (plus their workclothes or coveralls, etc.) entering clean areas (lunchrooms, of 10. Provide the minimum performance specifica fices, etc.) of the mill or leaving the mill site are not tions, such as filtration or scrubber efficiency and air contaminated with radioactive materials. Include flow, for operating the mill ventilation, filtration, good housekeeping and cleanup requirements and confinement, and dust collection systems throughout specifications in mill process areas to control con the mill and associated laboratories at their rea tamination, frequency of surveys of clean areas, sur sonably expected best performance and the frequency vey methods, and minimum sensitivity, range, and of tests and inspections to ensure that these specifica calibration frequency of survey equipment. Provide tions are being met.

contamination criteria or action levels for clean areas 11. Provide a decommissioning program that in and for the release of materials, equipment, and cludes reclamation of the mill site at the termination workclothes to clean areas or from the site. Proce of milling activities and the surety arrangements to dures for instrument calibration should be included as ensure that sufficient funds are available to complete an appendix. this decommissioning program.

6.* A description of the survey program, methods, 12. Provide a tailings management and reclama and procedures for determining concentrations and tion program addressing the following performance quantities of airborne radioactive materials released objectives:

to the environs and a description of the environmental monitoring program to be conducted plus the techni a. Reduce direct gamma radiation from the im cal basis therefor (i.e., a correlation of stack heights, poundment area to essentially background.

meteorological characteristics, etc.) to determine en b. Reduce the radon emanation rate from the vironmental concentrations. impoundment area to about twice the emanation rate

• 40 CFR Chapter 1, Part 190, and Regulatory Guide 4.14, in the surrounding environs.

"Measuring, Evaluating, and Reporting Radioactivity in Re leases of Radioactive Materials in Liquid and Airborne Effluents c. Eliminate the need for on ongoing monitoring from Uranium Mills," should be reviewed in connection with and maintenance program following successful this section. reclamation.

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d. Provide surety arrangements to ensure that suf up and operation, and the radiation safety program ficient funds are available to complete the full recla (including the in-plant, effluent, and environmental mation plan. monitoring programs)* should be defined and dis cussed. Also discuss the corrective action measures

6. ACCIDENTS established to ensure that conditions adverse to qual A spectrum of potential mill accidents ranging ity are identified and corrected and that the cause of from trivial to serious should be established by significant conditions adverse to quality is deter classes of occurrence, and each class of accidents mined and corrective action taken to preclude repeti should be appropriately evaluated. The evaluation tion.

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 8. EVALUATION OF ALTERNATIVES

also be described. For example, potential accidental Where the proposed course of action was based on fires should be discussed in terms of occurrence, pre the consideration of various alternatives, the vention, detection and suppression mechanisms (both benefit-cost analysis used in arriving at the "as low manual and automatic), and emergency plans for cop as is reasonably achievable" concept should be pre ing therewith. The adequacy of the program should sented, and the rationale for the recommended course also be discussed. of action should be included.

7. QUALITY ASSURANCE

• The NRC staff is preparing a regulatory guide on quality as surance for radiological effluent and environmental monitoring The quality assurance program for all. phases of the programs that is scheduled to be published for comment in De milling project including design, construction, start- cember 1977.

3.5-6

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