ML20024D923
| ML20024D923 | |
| Person / Time | |
|---|---|
| Issue date: | 07/25/1983 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-5 NUDOCS 8308080439 | |
| Download: ML20024D923 (3) | |
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DISTRIBUTION:
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NMSS r/f UL 2 5 gg3 g s/f 414.19.3/DEM/83/07/22/(y/M Re:ctd le VlM Prciect 6
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(Reimn to WM,62TS3) c2 MEMORANDUM FOR:
Leo B. Higginbotham, Chief Low-Level Waste Licensing Branch Division of Waste Management FROM:
Dan E. Martin, Section Leader Uranium Recovery Licensing Section Low-Level Waste Licensing Branch
SUBJECT:
TRIP REPORT FOR TRAVEL TO CHICAG0, ILLIN0IS, AND CHEYENNE, WYOMING Travel to:
(A) Region III offices in Glen Ellyn, Illinois, 5/17-18/83 (B) Cheyenne, Wyoming 5/19 20/83
Purpose:
(A) Participation with FCMS staff as an observer in a Pilot Program Review of regionalized materials licensing activites in Region III.
(B) Attendance at a meeting of the Wyoming Mining Association (WMA), Wyoming Department of Environmental Quality (WDEQ), and URF0 staff to discuss certain technical issues relevant to the licensing and regulation of solution uranium mining.
Discussion (A):
As an observer, I participated in the first in-the-field trial programmatic review of a regionalized licensing function. The review was well planned, and executed smoothly and methodically. Documentation of the review, including all aspects of the process used and results obtained, has been developed by FCMS, and was previously forwarded to cognizant DWM staff.
The agenda for the review was followed as planned, and is attached. To assist in conducting the review, " checklists" of discussion items were OFC
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8308080439 830725 PDR WASTE WM-5 PDR
414.19.3/DEM/83/07/22/0 JUL 2 51333 drawn up before leaving for RIII.
Following these lists assured that all subjects were addressed, and allowed review of discussion topics by all concerned before leaving for the field.
Examination of these checklists indicates an imbalance of attention between field office performance and headquarters support. Also, the majority of attention in the lists, and in the field review, is on matters of management, efficiency, and administrative topics rather than on the adequacy of the licensing work in protecting public health and safety. The area of licensing adequacy was dealt with mostly at headquarters, by review of copies of licenses issued by RIII staff over the preceeding several months. This may not be a practicable mode of review for uranium recovery licensing by RIV/URF0.
Discussion (B):
The meeting was sponsored by WMA with URF0 and WDEQ staff providing representatives as requested.
The meeting agenda is attached, and is indicative of the primarily technical nature of the meeting.
Initial discussion focused on NRC-WDEQ working relationships, authorities, and responsibilities. This was needed to become familiar with the existing informal arrangements for sharing information, coordinating reviews, and avoiding inconsistant or conflicting requirements.
In this regard, there were several commetns to the effect that working relationships had been markedly improved by regionalization to Denver. The WDEQ staff also discussed internal arrangments for handling reviews and responsibilities between the Land Quality Division and the Water Quality Division.
With respect to coordination of reviews, it was pointed out that efforts are being made to hold joint NRC-WDEQ meetings with licensees when practicable, and that NRC and WDEQ want to have the same reporting requirements and application content requirements wherever possible.
URF0 staff expressed a willingness to accept applications in the format specified by WDEQ as long as the content specified in Reg. Guide 3.46 was included.
It was suggested that content which NRC needs, but WDEQ doesn't, such as on radiation safety, could be attached as appendices.
Also, URF0 staff stated that full EIS's may not be needed for commercial-scale in situ proposals, but that could only be determined for certain by first performing the necessary environmental appraisal.
Following this, WDEO staff discussed at some length their procedures fer determining water quality classification among six general use categories. This was important to WMA, and was discussed at length from the standpoint of restoration to baseline versus restoration to pre-mining use category.
The industry viewpoint was expressed, that 0FC :
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DATE :83/07/22
t 414.19.3/DEM/83/07/22/0 jut. t 51983 restoration requirements should be known before embarking on a large-scale mining venture, and they should be " fixed" on the basis of R&D operating and restoration experience.
Technical issues surrounding the question of what is an acceptable pump test were debated in terms of hypothetical "what if?" situations. The general flavor of this conversation seemed to be that, while there was agreement as to the objectives for pump tests, the specifics of design and execution really have to be worked out on a case-by-case basis. WMA
,l proposed that a task group be establithed to pursue standards development for pump tests. There was no objection to this.
Other topics discussed at length, without noteworthy differences, included the WDEQ VIC program, the NRC's to-be-issued Reg. Guide on groundwater monitoring for solution mines, monitoring data reporting format, and the NRC's proposed revised fee schedule.
1 Om gJIAL ggggpgy Dan E. Martin, Section Leader Uranium Recovery Licensing Section Low-Level Waste Licensing Branch Division of Waste Management CC:
R. Dale Smith, RIV/URF0 D. Chape11 0FC
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