ML20035B112
| ML20035B112 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1993 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-5 NUDOCS 9303310151 | |
| Download: ML20035B112 (4) | |
Text
4 MEMORANDUM T0:
Leonard J. Callan, Director Division of Radiation Safety and Safeguards, RIV MAfi 191993 FROM:
Richard L. Bangart, Director Division of Low-Level Waste Management
.nd Decommissioning Office of Nuclear Material Safety and Safeguards
SUBJECT:
1993 NATIONAL PROGRAM REVIEW FOR THE URANIUM RECOVERY PROGRAM Enclosed is a copy of the material to be used in the National Program Review (NPR) for 1993 for the Uranium Recovery Program. This was provided to Ray Hall by John Surmeier during his visit on March 11, 1993.
The dates for the NPR review were agreed to be March 31 and April 1.
Myron Fliegel and Allan Mullins will be in URf0's offices on those dates to discuss the material in the enclosure. No written response to the questions is requested.
John Surmeier will attend the close-out in Arlington, Texas.
Cxighal Signed By RiclPJMD8anWt%irector Division of Low -level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
R. Hall, URf0 Mark Small Boxes in Concurrence Blockito Define Distribistion Copy Preference.
In small Box on "0FC:" line enter: ~ C = Cover E = Cover' & Enclosure N = No Copy
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i MEMORANDUM T0:
Leonard J. Callan, Director Division of Radiation Safety and Safeguards, RIV FROM:
Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
SUBJECT:
1993 NATIONAL PROGRAM REVIEW FOR THE URANIUM RECOVERY FIELD OFFICE s
Enclosed is a copy of the material to be used in the National Program Review (NPR) for 1993 for the Uranium Recovery Field Office (URF0). This was provided to Ray Hall by John Surmeier during his visit on March 11, 1993. The dates for the NPR review were agreed to be March 31 and April 1.
Myron Fliegel and Allan Mullins will be in URF0's offices on those dates. John Surmeier will attend the close-out in Arlington, Texas.
Richard L. Bangart, Director Division of Low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
R. Hall URF0 MaWSmall?B6sFislConiiurferid 816ck"t6'Dsfihe DistribiitiorFC6F~ 'Piefpfeschil
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NAME AMullirIsNb HFliegel JSur)[ibr BBrach RBangart DATE 03//f/93 R
03///-/93 1/
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03/ /93 03/ /93 S:\\LLWNTYPE\\EDIE\\LJCNPR.ATM OFFICIAL RECORD COPY In small Box on "DATE:" line enter: M = E-Mail Distribution Copy H = Hard Copy PDR : YES l ' NO Category:
Proprietary or CF Only ACNW: YES NO
/
Delete file after distribution Yes No IG: YES NO.
/
DISTRIBUTION: Central File LLWM r/f Plohaus JAustin DGillen NMSS r/f i
i
1993 NATIONAL PROGRAM REVIEW URANIUM RECOVERY PROGRAM I
The emphasis this year for the National Program Review of the Uranium Recovery Program will focus on the Uranium Recovery Field Office's responsibilities for j
reclamation-closure issues to ensure that the requirements in Section 83c. of i
the Atomic Energy Act will be met, upon license termination.
I Section 83c.
Section 83c. of the Atomic Energy Act of 1954, as amended, requires that, upon termination of licenses regulated under Appendix A of 10 CFR Part 40, the Nuclear Regulatory Commission determine that the licensee "has complied with i
all applicable standards and requirements under such license." The ability of 1
the NRC staff to make such determinations requires that_the issues raised in the questions listed below be resolved-(
1.
Appendix A lists 13 criteria that the licensee must meet to'be granted an l
NRC license.
In approving the reclamation plan for the UNC Church Rock j
facility for example, staff documented how the licensee met each of the 4
criteria in Appendix A which are applicable to reclamation plans.
l a.
Please list licensees which have not addressed reclamation criteria in i
Appendix A in a license application or amendment submittal.
b.
For those reclamation plans that do not have such documentation, on what basis would NRC staff determine that relevant criteria in r
Appendix A have been met?
a c.
How did the Uranium Recovery Field Office (URFO) document staff review l
and reach conclusions with respect to Appendix A for reclamation plans other than Church Rock?
A t
2.
How does URF0 ensure that the licensees are following the approved reclamation plans to meet the applicable requirements in Appendix A7 j
How many licensees have an NRC-approved quality assurance (QA) and a.
quality control (QC) program for their reclamation plan? Do licensees j
have QA/QC plans that are not NRC approved?
If NRC inspections or i
licensee audits show that reclamation is lacking adequate quality i
control, what actions are taken by the licensee or NRC?
If actions are not taken on an ongoing basis, how can the site later be demonstrated to be built to comply with Appendix A criteria for long-term safety?
i L
b.
How many QA/QC licensee programs provide "as-built" drawings for use by NRC in making a determination that the reclamation activities have
{
been built according to the approved reclamation plan? If the 1
licenses do not require "as-built" drawings, how will NRC be able to i
make a determination that the tailings impoundments were constructed according to the approved plan?
Enclosure
'I
s What criteria were used by URF0 to select licensees for inspections of c.
the tailings impoundment reclamation activities during 19927 Are i
reclamation inspections primarily audits of records or field observations, or confirmatory measurements, or a combination? What type of a review plan was used by URF0 for these inspections? Were the inspectors qualified per NRC Inspection Manual Chapter 1245? Does URF0 plan to use these inspections as a basis in determining that all
[
reclamation requirements in the licenses have been met?
d.
For those licensees that have only an approved reclamation plan for purposes of financial surety but still are proceeding with reclamation activities (e.g., Atlas Minerals), has URF0 staff reviewed the ongoing reclamation activities to ensure that they will be acceptable to incorporate into a final NRC-approved reclamation plan? If staff has not been reviewing (or inspecting) these on-going activities, what additional testing will URF0 require to provide the basis for making a determination that all license conditions for reclamation standards have been met?
e.
How is the timing P. a reclamation inspection determined?
Is there an established procedure for conducting a reclamation inspection? A field check list?
3.
There are a number of licensees that had reclamation plans approved by NRC in the early 1980's. Many of these licensees have completed reclamation of the tailings impoundments. The approved cover designs for some of the tailings impoundments may not meet the long-term structural stability requirements required in Appendix A.
As a result, URF0 sent letters to these licensees in 1990 and 1991 on this issue. The licensee was informed that under 10 CFR 40.41(e), NRC may require that the licensee's site meet current standards, unless it can demonstrate that meeting such standards will not further enhance the protection of health nor further minimize the danger to life or property. The licensees were requested to review their reclamation plans and compare the design with current reclamation criteria, as described in Appendix A.
a.
How many of the licensees have submitted such analyses to URF07 b.
What is the current status of this review? How many of the analyses has URF0 staff reviewed? How many were approved? What actions were taken on those not approved?
c.
What staff resources were budgeted for these reviews?
2
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