ML19256E780
| ML19256E780 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1979 |
| From: | Martin J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Brown R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| CON-FIN-A-2143 NUDOCS 7911150203 | |
| Download: ML19256E780 (8) | |
Text
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_. A u-l' UNITED STATES 83
'N NUCLEAR REGULATORY COMMISSION
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WASHtNGTON, D. C. 20555 SEP 11 1979 MEMORANDUM FOR: Robert S. Brown, Jr.
Assistant to Director and Chief, Program Support Branch, MMSS l
FROM:
John B. tiartin, Director Division of 1laste Management
SUBJECT:
REVISION TO WORK SCOPE FOR URANIUM MILLIEG GEIS PREPARATION AT ANL (FINA2:43)
This memorandum requests a change to contract FIN A2143 with Argonne National Laboratory (ANL) and is intended to replace my previous memo dated July 17, 1979. Specifically, chang 0s are necessary to Tasks 2 and 3, and new Tasks 6 and 7 should be added to the Statement of Work for recaining FY 79 and FY 80 work on the generic environmental impact statement (GEIS) on uranium milling. Reporting requirements for Task 7 necessitate a change to section 3.2 cf the current S0W (Attachment No.
6).
Task 2 (Att.chment No.1) involves the resoltdon of comelt on the draft GEIS.
In light of the volume and complexity of comments which we have already received, we have detennined that it will be necessary to obligate an additional 50K for FY 79 to ANL for this task.
The primary purpose of Task 3 (Attachment No. 2) is to provide an overview of research activity conducted over the past several years under NRC sponsorship, and also to provide a systematic and methodical review of radiological source tenns presented in the draft GEIS in light of the research work. The specific changes which should be made to Task 3 are provided in Attachme-No. 3.
The major change required in Task 3 relates to the necessity of outside peer review of several selected aspects of the draft GEIS source tenn estimates and radiological assessment.
The primary purpose of Task 6 (Attachment No. 4) is to obtain aerial photographs of milling sites. The data obtained from these photographs will be used to assess the current situation at all tailings impoundments as well as develop a better indication of what tailings dust source tenns should be.
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R. S. Brown, Jr. SEP 11 1979 The primary purpose of Task 7 (Attachment No. 5) is to provide fact-finding assistance related to financial assurance mechanisms addressed in the GEIS. These efforts will include a pulling together of experience and recent infonnation related to surety arrangements in support of resolution of coments on the draft GEIS.
You are requested to provide ANL with 165K in additional FY-79 funds with the work order to allow imediate initiation of this work. Funds are available under NMSS FIN A2143. These additional funds should be allocated as follows:
1.
50K to ANL to supplement the resolutica of comments on the draft GEIS.
2.
107 to ANL to support the critical review effort (Attachment No. 3).
3.
80K to ANL for aerial photographs of milling sites (Attachment No. 4).
4.
25K to ANL for assistance related to financial assurance mechanisms (Attachment No. 5).
/
/ [k k n. Mar n, Director vision of Waste Management Attachments: As stated 13361237
4 ATTACHMENT 1 the GEIS, will be issued in a separate (but related) report:
(Originally, this material was to be issued,in conjunction with the main report, but to reduce the volume of material in the GEIS and because it is of second order importance to the specific decisionmaking aspects of the GEIS, the material is being issued as a separate report.) The report will be printed by NRC; no comments will be solicited on this factual, background report.
Task 2 - Resciution of Comments The contractor will provide technical support to resolve public comments en the Draft GEIS.
Comments on the Draft GEIS are expected to deal with both policy and non-policy aspects of regulatic.g uranium mills. The contractor will analyze those portior.s of public comments that deal with the non-policy aspects of regulating uranium mills. The NRC will respcnd to those portions of public comments that deal with policy aspects of regulating uranium mills. At the completion of this task, the contractor will submit a letter report that proposes responses to the non-policy portions of the public comments on the Draft GEIS.
This report will be reviewed by NRC prior to preparation of the Final GEIS. This report should include as a minimum:
(1) a statement of public. comments; (2) responses to public comments; and (3) an index to cross reference public comments and proposed responses.
Upon receipt of public comments, the NMSS ' Project Manager (PM) will determine those specific comments requiring resolution by the contractor. The primary decisionmaking matters treated in the GEIS (that is, those matters being incorporated into regulations that the GEIS has been developed to support) relate to the folicwing:
radiological health impacts, hazards presented by radioactive and non-radioactive contaminants in tailings solutions seeping from the impcundment, cos.t analysis, engineering aspects of tailings manage-ment and disposal practices which are analyzed in the Draf t GEIS, and long-term stability of tailings disposal impoundments. As concluded in the Draft GEIS, the majority of the non-radiological impacts are extremely site specific and must be dealt with in individual cnvironmental statements.
Therefore, the primary areas of expertise required will be those identified above.
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[P ti ATTACHMENT 2 L
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9 Tash 3 - Overview of Research Activities and Review of
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j Racioactive Scurce Terms t
The draft GEIS states that results of fielc studies perfor d over the past.several years at uranium mills by NRC centractors are being
. documented in formal reports and that these reported resuits will be incorporated explicitly into the final GEIS.
The contractor
- will summarize in general terms the nature and extent of field studies and other research programs which have been conducted by various NRC contractors at active mills and in the laboratory over the past several years.
This would include generally sutrcari zi ng:
(a) the type of measurements made (e.g., continuous particulate samoling);
(b) length and duration of measurements and number of mills involved; and (c) the general nature of results reported (including as appropr' ate, selected tables, graphs, figures, etc.).
Based on this review (which will be about 15 to 20 pages icng ar.d submitted in connection with the proposed resolution of cc:ments in the Task 1 report), the contractor will recorrend whether the source terms developed in Appendix G-1 and Chapter 5 of the Draft GEIS should be revised or qualified. This work will ce=ence during the comment period as it will be a comprehensive undertaking.
.in.itsel f.
The general cbjective is to make it clear that a solid
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base of data collected by various NRC contractors underlies the source term estimates and radiological assessments which have been conducted--that the initial stated goals of. the GEIS and uranium mill tailings research programs of developing a sound dat. base regarding radiological effluents and associated impacts, which previously did not exist, have been met.
Task 4 - Assistance in Conduct of Public Meetings Assistance will be provided by the contractor in conducting two public meetings on the GEIS and the associated proposed rule to aid the public in understanding and co=.onting upon them.
The ir.etings are to be held about 60 days af ter start of the coment period.
The meetings will be held in two western cities ( Albuquerque, N'1 and Denver, CO), each lastir. two days.
(A more detailed description of meeting purpose and format is attached.)'
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ATTACHMENT 3 CHANGES TO GEIS S0W FIN A2143 Add to Task 3 write-up the fellowing:
The contractor will arrange for outside peer review of the assumptions and methods used in estimating dusting from tailings piles as calculated by the UDAD Code [NUREG/CR-0553//ANL/ES-72]. Specifically, methods described in Section 4.3 of NUREG/CR-0553 should be reviewed.
In conducting this review the overall programatic needs of the NRC in licensing uranium mills should be kept in mind. The needs are for models that can be easily adapted to any potential milling site given a relatively simple set of meteorological and tailings parameters. This stems from the need to perform predictions of radiological impacts in advance of any milling operations for a continuing and rapid succession of licensing cases.
The model should allow for site specific inputs such as relative joint frequency distribution of winds (in tenns of direction, speed, and stability class), specific activity of radionuclides in the tailings, exposed area subject to dusting, and dusting control factors. However, overly involved analytical procedures.<hich require.an undue number of site specific para-meters should be aw.ded if little is gained in the process.
The schedule for this work should be as follows:
OReview validity of assumptions in UDAD Code and made of application of resuspension source terms from tailings with incorporation of field data to the maximum extent possible.
-On about December 31, 1979.
T 0Apply data from uranium mill tailings studies to improve definition
. of particle source term and issue final report.
-On about January 31, 1980.
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ATTACHMENT 4 CHANGES TO GEIS S0W FIN A2143 Add Task 6 to S0W write-up as follows:
The contractor should obtain aerial photographs of all uranium tailings piles. This would include obtaining photographs already available as well as having new stereo-pair, color photographs taken of approximately 13 uranium tailings sites.
Specific sites to be surveyed will be identified by the NMSS Project Manager, The photographs will allow more exact estimates of tailings source terms based on areas of dry beach, wet beach, and solution coverage. The photographs should be submitted to the NMSS Project Manager on an -
as-available-basis.
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AiTACHMENT 5 CHANGES TO GEIS S0W FIN A2143 Add Task 7 to S0W write-up as follows:
NkC has prorosed regulation changes containing financial surety provisions based on previous analysis prepared by the contractor.
The r.ature of this required effort is not further analysis, but I
gathering of facts and information related to financial surety problems. Much of this information, particularly that which relates to the Office of Surface Mining regulation, has become available over the pact year. The staf.f wil' perform analysis and draw conclusions nn facts gathered in this investigation. This investigation is ir. tended to establish a complete base of infomation upon which to respond to coments on the NRC staff proposed regulation changes.
Specific subtasks include:
A.
Follow up on the Office of Surface Mining (OSM) experience with the bonding provision (Subchapter J) of t..
!r recent regulation.
Investigate bases for comments on the OSM proposed regulation through communicaticns with state representatives regulating coal reclamation activities. Specifically, report on the track record and availability of surety bonds as perfomance guarantees.
Preliminary findings should be comunicated via brief (1-2 page) letter reports submitted approximately monthly to the NMSS Project Manager.
B.
Obtain specific information en the use of irrevocable letters of credit and certificates of de;;osit in other areas (besides uranium milling and mining) where relatively long-tem perfomance guarantees are required (e.g., reclamation perfomance assurance for a twenty year coal operation). Detailed explanation of how these mechanisms would work in practice.
(Giveexamples.)
C.
Rigorously explore various scenarios in which collection of sureties could be made difficult, to verify that NRC has not left any loopholes in the provisions of the regulation (44 FR 50012).
It 4 estimated that this will require approximately four man-months of effort. This task should be completed by November 1,1979 and a complete sumary of the findings should be submitted to the N?.SS Project Manager by letter report by November 15, 1979.
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ATTACHEMENT 6 Hubert J. Miller, Uranium Recovery Licensing Branch, NMSS -
one copy.
Ross A. Scarsno, Uranium Recovery Licensing Branch, NMSS -
one copy.
John B. Martin, Division of Waste Management, NMSS - one copy.
Office of the Director, NMSS (ATTN: Program Support) - one copy.
3.2 Task Reports i
The contractor will submit four reports in the course of this project. The first is the, Supplemental Volume (NUREG/CR-0597) described in Table 1; this will be due May 15, 1979. The second, in the fonn of a letter report (Task 2 and 3) will be due within four weeks of identification by the NMSS PM of those public coments to be resolved by tne contractor. The third report will be the preliminary Final GEIS (Task 5) which will be due within four weeks following completion of the review of the Task 2 report by the NMSS PM.
It is difficult to predict the nature and extent of coments that will be received on the draft GEIS and in public meetings. The time periods c-
.ified for the seccnd and third report are objectives; these may be relaxed by fe NMSS PM in writing on the basis of a very large coment load.
The contractor will provide a final camera-ready copy of the Supplemental \\'olt.e (Task 1, NUREG/CR-0597) to the NMSS PM who will handle printing and issue. The preliminary Final GEIS will be provided to the NMSS PM as a camera-ready copy which, upon integration of NRC policy sections, will be put ished by NRC as a NUREG document.
The reporting requirem'.au for Task 7 will be a number of letter reports, as identified in that section.
4.0 MEETINGS AND TRAVEL The contractor will be required to meet with the NMSS Project Manager at NRC office in Silver Spring, Maryland, about five times during the course of this contract. This is in addition us travel required for public meetings on the GEIS.
5.0 NRC FURNISHED MATERIAL The NMSS PM will prepare the policy sections of the Final GEIS.
6.0 PERIOD OF PERFORMANCE The work herein shall comence on May 1,1979, and continue through September 30, 1980.
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