ML19210D010
| ML19210D010 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/2019 |
| From: | Andrea Kock NRC/NMSS/DMSST |
| To: | Forbes A State of TX, Energy Conservation Office |
| Stephen Poy, NMSS/SALB | |
| Shared Package | |
| ML19210D074 | List: |
| References | |
| R06065 | |
| Download: ML19210D010 (7) | |
Text
September 18, 2019 Ashley Forbes, Director Radioactive Materials Division TX Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF THE FINDINGS FOR THE BREVARD PROJECT AND BROWN PROJECT SITES OF THE R06065 LICENSE
Dear Ms. Forbes:
The U.S. Nuclear Regulatory Commission (NRC) staff has completed the review of your June 17, 2019, final Completion Review Report (CRR) (Agencywide Documents and Access Management System [ADAMS] Accession No. ML19175A204) regarding the proposed termination of the Signal Equities, LLC Brevard Project and Brown Project sites (Texas Radioactive Material License No. R06065) located in Bee and Live Oak Counties in Texas. A final revision of the CRR was provided on August 23, 2019 (ADAMS Accession No. ML19238A175). Based on the NRCs review as specified in the Office of Nuclear Material Safety and Safeguards Procedure SA-900, Termination of Uranium Milling Licenses in Agreement States, and in accordance with the provisions at Title 10 of the Code of Federal Regulations Section 150.15a(a) and Section 274c of the Atomic Energy Act of 1954, as amended, the staff has determined that all applicable standards and requirements for the protection of the public health, safety, and the environment have been met for the Brevard and Brown Project sites listed on the Radioactive Material License No. R06065, and the site may be released for unrestricted use. The State of Texas may amend License No. R06065 to remove the Brevard and Brown Project sites.
A. Forbes 2
A copy of our evaluation report, entitled NRC Review of the License Termination Findings of the Signal Equities, LLC Brevard Project and Brown Project sites (Texas Radioactive Material License No. R06065) located in Bee and Live Oak Counties Submitted by the Texas Commission on Environmental Quality, is enclosed.
If you have any questions or comments, please contact Paul Michalak at 301-415-5804 or paul.michalak@nrc.gov.
Sincerely,
/RA K Williams for/
Andrea L. Kock, Director Division Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated
ML19210D010 (Letter) ML19210D074 (Package)
NAME MSST/SALB DUWP: D OGC MSST/SALP:BC MSST:D OFFICE SPoy PHolahan JEzell PMichalak KWilliams for:
AKock DATE 08/26/19 09/5/19 08/26/19 09/6/19 09/18/19
Enclosure U.S. Nuclear Regulatory Commission (NRC) Review of the Full License Termination Findings for the Brevard Project and Brown Project sites of the R06065 License Submitted by the Texas Commission on Environmental Quality (TCEQ)
Licensee:
Signal Equities, LLC License No.:
R06065 Type of License:
In-Situ Recovery Uranium Milling License Location:
Bee and Live Oak Counties, Texas Full/Partial Termination:
Full License Termination Site Being Terminated:
Brevard Project and Brown Project sites Area Being Terminated:
Approximately 1,558 acres The NRCs review of the final Completion Review Report (CRR) submitted by TCEQ was performed in accordance with the Office of Nuclear Material Safety and Safeguards (NMSS)
Procedure SA-900, Termination of Uranium Mill Licenses in Agreement States.
On November 1, 2018, TCEQ submitted a draft CRR regarding the proposed full license termination of the Signal Equities, LLC license resulting in the release of the Brevard Project and Brown Project sites (Agencywide Documents and Access Management System [ADAMS]
Accession No. ML18305B470). The draft CRR was reviewed in accordance with the NMSS Procedure SA-900, and a response to the draft CRR submittal was transmitted to TCEQ on May 28, 2019 (ADAMS Accession No. ML19108A391). On June 17, 2019, TCEQ submitted the final CRR to NRC (ADAMS Accession No. ML19175A204). A final revision of the final CRR was provided on August 23, 2019 (ADAMS Accession No. ML19238A175).
The NRC conducts a review to determine whether all applicable standards and requirements have been met prior to full termination of an Agreement State license. This review is based on:
(1) the CRR submitted by the State containing the States conclusions that all applicable standards and requirements have been met; and (2) the results of NRC reviews of the States uranium recovery program conducted under the Integrated Materials Performance Evaluation Program (IMPEP), which provides a basis for confidence on the determinations and conclusions reached by the Agreement State in the CRR and a basis for confidence that the States reviews, licensing actions, and inspections associated with license termination have been conducted appropriately.
The following items were reviewed based on the NMSS Procedure SA-900:
1.) A brief description of licensees activities associated with decommissioning and license termination.
Comment: This information is provided under item 1 in Section II of the final CRR attached to the letter sent to NMSS from TCEQ dated June 17, 2019, and has been found acceptable.
The NRCs review and concurrence in this matter will result in a full license termination and the release of the Brevard and Brown sites for unrestricted use.
2 2.) Groundwater information which demonstrates that groundwater has been adequately restored to meet applicable standards and requirements.
Comment: This information is provided under item 2 in Section II of the CRR and has been found acceptable.
The site was never fully developed such that no licensable uranium production activities occurred at the Brown or Brevard Project sites. Thus, no groundwater restoration was necessary. Wells were installed, but these had no affect on the groundwater at the site.
3.) Documentation that the production, injection, and monitoring wells have been closed and plugged in accordance with applicable standards and requirements.
Comment: This information is provided under item 3 in Section II of the CRR and has been found acceptable.
Plugging reports were received by TCEQ on August 13, 2018, which detailed plugging activities at the sites. The reports were reviewed by TCEQ staff for compliance with the closure plans listed in the UIC permits. Following review of the reports, revocations for the Class III permits were requested by Signal Equities, LLC, and later issued by TCEQ.
A letter dated October 16, 2018, from TCEQ to Signal Equities, LLC provided the following information: In accordance with Title 30, Texas Administrative Code Section 305.67, Signal Equities, LLC, the holder of permits UR03080, UR03080 PAA1, and UR03085, has consented to the revocations of these permits. All Class III wells, not transferred to the landowner, were plugged as of May 2018 and certifications have been received from Signal Equities, LLC, and an independent registered water well driller that plugging was accomplished in accordance with the plugging and abandonment plan in the permits.
4.) Decommissioning information which documents that all radiologically contaminated materials have been properly disposed of, transferred to licensee(s) authorized to possess such materials, or meet applicable standards and requirements for release.
Comment: This information is provided under items 1 and 4 in Section II of the CRR and has been found acceptable. TCEQ stated that the site was never fully developed, and mining activity did not occur at the Brevard and Brown Project sites. As such no radiologically contaminated waste was generated at the site.
5.) Discussion of the results of radiation surveys and soil samples analyses which confirm that the licensed site meets applicable standards and requirements for release.
Comment: The results of radiation surveys and soil sample analyses are provided under items 5 and 6 in Section II of the CRR and have been found acceptable.
The survey results indicated measurements above background near one well on the Brown Project site. On October 4, 2018, TCEQ performed a follow-up survey on the related to this well. This survey showed measurements at background except in the immediate vicinity of the well, where 9.7 micro-roentgen per hour (µR/hr) (three times
3 above background) was detected. Based on these results, it was initially suspected that the well casing was the cause of the elevated measurements, but as a precaution two composite soil samples around the base of the well were collected. The two, five-spot composite samples were collected at depths of 0-6 inches and 6-12 inches within a 100 square meters (m2) area with the well as the center point. TCEQ analyzed the samples using an Alpha spectrometry method and the results indicated 23.7 and 9.71 picocuries per gram (pCi/g) radium-226 for 0-6 inch and 6-12 inch depths, respectively.
TCEQ determined that the source of the elevated survey measurements and associated soil sample results is due to the accumulation of radium from groundwater deposition.
TCEQs determination was based on a review of historic information about the site and the fact that production of uranium never occurred at the site. As a result, TCEQ concluded that the survey measurements and associated soil sample results were due to naturally occurring radioactive material (NORM). Title 25, Texas Administrative Code Section 289.259(d)(1)(B) has a NORM exemption limit for radium of 30 pCi/g averaged over 100 m2 in the first 15 centimeters (cm) of soil. Baseline monitoring that was conducted for the underground injection control area permit indicated radium concentrations in the groundwater as high as 15 picocuries per liter (pCi/L). The well itself has groundwater concentration values of 1.5 pCi/L of radium. These values are below the NORM exemption limit. Since the site was never fully developed and no uranium production activities occurred, the NRC agrees with TCEQs determination that radiologically contaminated waste was not generated at the site.
6.) Discussion of results of States site closure inspection(s).
Comment: This information is provided under item 6 in Section II of the CRR and has been found acceptable.
As noted in Item 5 above, TCEQ performed confirmatory surveys and collected soil samples in 2018. These surveys and analyses indicated that the site could be released for unrestricted use and serve as the States closure inspections. TCEQ also conducted inspections to verify that all wells were plugged. Fifty-six wells were plugged on the Brevard Project site and three were transferred to the landowner. All wells were plugged on the Brown Project site. Further inspections by TCEQ will not be necessary after the site has been released for unrestricted use.
7.) For partial terminations, documentation that release of a portion of the site will not negatively impact the remainder of the site to be closed at a later date.
Comment: N/A - This CRR is for a full license termination.
8.) IMPEP review of the Texas uranium recovery program.
Comment: According to results of the January 2018 IMPEP review, the Texas uranium recovery regulatory program was found to be satisfactory based on the IMPEP evaluation criteria. A satisfactory rating is the highest rating possible for each IMPEP common and non-common performance indicator. The overall Texas Agreement State program was found adequate and compatible with the NRC program.
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Conclusion:==
Based on the NRCs review, detailed above, as specified in NMSS Procedure SA-900, and in accordance with the provisions at 10 Title 10 of the Code of Federal Regulations Section 150.15a(a) and Section 274c of the Atomic Energy Act of 1954, as amended, the staff has determined that all applicable standards and requirements for the protection of the public health, safety, and the environment have been met for the Brevard and Brown Project sites listed on the Radioactive Material License No. R06065, and the site may be released for unrestricted use. The State of Texas may amend License No. R06065 to remove the Brevard and Brown Project sites.