ML20059L873
| ML20059L873 | |
| Person / Time | |
|---|---|
| Issue date: | 10/12/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-279, NUDOCS 9311170466 | |
| Download: ML20059L873 (19) | |
Text
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October 12, 1993 POLICY ISSUE SECY-93-279 (NEGATIVE CONSENT)
FOR:
The Commissioners FROM:
James H. Taylor Executive Director for Operations
SUBJECT:
MEMORANDUM 0F UNDERSTANDING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION, REGION IV, AND THE U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 6, FOR REMEDIAL ACTIONS AT THE HOMESTAKE MINING COMPANY'S URANIUM MILL SITE PURPOSE:
To provide the Commission an opportunity to review the content of a proposed Memorandum of Understanding (MOU) (Enclosure 1) for the Homestake Mining Company's Uranium Mill site (Homestake site), near Grants, New Mexico, before signature.
BACKGROUND:
As discussed in SECY-88-197, when the State of New Mexico returned regulatory authority over uranium mills to the U.S. Nuclear Regulatory Commission in 1986, a situation was created where two mills subject to NRC licensing were also on the U.S. Environmental Protection Agency's (EPA's) National Priority List (NPL) (i.e., the sites are "Superfund" :ites).
EPA has the authority to place both NRC and Agreement State licensed sites on the NPI for remedial action; however, as a matter of policy, EPA does not place NRC licensed sites on the NPL. The United Nuclear Corporation's site at Church Rock (Church Rock site), New Mexico, and the Homestake site, had been placed on the NPL at New Mexico's request before New Mexico's returning regulatory authority to NRC.
NOTE:
TO BE MADE PUBLICLY AVAILABLE
Contact:
WHEN THL FINAL SRM IS MADE Ramon E. Hall, URF0 AVAILABLE (303) 231-5800 9'3Y11 dkS6 931012
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The Commissioners 2
Once a facility is listed, it is EPA's policy not to delist until the conditions causing the listing are corrected. NRC's objective is to close the site in compliance with applicable NRC regulations.
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Thus, NRC and EPA now have concurrent jurisdiction and responsibility for j
remediation of these sites. The regulations applied by both agencies differ j
slightly. EPA regulations are based on the Comprehensive Environmental Response Compensation and Liability Act of 1980, as amended; NRC regulations-are based on the Atomic Energy Act of 1954, as amended, and the Uranium Mill j
Tailings Radiation Control Act of 1978.
For the Church Rock site, NRC, Region IV and EPA, Region 6 worked for a year and a half to resolve how to best satisfy each agency's responsibilities while minimizing duplication of effort and avoiding counter-productive situations.
The staff developed a proposed M00 and determined roles and responsibilities that each respective agency would take to achieve final remediation of the Church Rock site. On July 18, 1988, SECY-88-197 was provided to the
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Commission as an opportunity to review the Church Rock site MOU before Region IV signed the agreement. On August 26, 1988, after Commission approval, NRC, Region IV and EPA, Region 6 signed this MOU.
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In SECY-88-197, the NRC staff had determined that the Homestake site did not at that time require coverage by an MOU similar to the Church Rock site MOU.
i Subsequently, because of the effective and efficient working relationship resulting from the Church Rock site MOU, EPA suggested development of a j
similar MOU for the Homestake site.
Experience at the Church Rock site also showed that the MOU helped clarify each agency's responsibilities for the licensee.
I On October 2, 1989, SECY-89-306 was provided to the Commission.
It included a
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proposed MOU for the Homestake site. Two memoranda from the Commission dated i
November 14, 1989, and December 1, 1989, indicated that supporting the MOU was l
not advisable at that time, because of the uncertainty associated with EPA's deferral policy, and ongoing NRC and EPA discussions to eliminate dual l
regulation.
EPA has since reconsidered its deferral consideration and intends to prepare a 1
3 preliminary closecut report, after the MOU is functional; this would place the 2
Homestake site on its long-term remedial action list.
The concept of dual regulation was addressed in the March 16, 1992, NRC and EPA MOU. This document encourages cooperation between the agencies, in an effort to minimize regulatory overlap.
Since the issuance of the December 1, 1989, Commission memorandum, the NRC staff, in the absence of an' MOU, has maintained a close-working relationship with EPA.
Because EPA intends to issue preliminary closecut documentation, r
based on NRC being the lead regulatory agency, it has requested the MOU as a basis for this action.
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i The Commissioners 3
The willingness and desire to complete the MOU is demonstrated in the November 17,1992 (Enclosure 2), and December 3,1992 (Enclosure 3), letters exchanged between Regional Administrators of EPA, Region 6, and NRC, i
Region IV.
In this correspondence, both administrators have endorsed the creation of an M00 and have directed their staffs to prepare appropriate documentation.
DISCUSSION:
To appropriately define each agency's role and to minimize duplication of effort, a proposed MOU for the Homestake site has now been negotiated between EPA, Region 6 and NRC, Region IV. The staff considers the MOU to represent a workable arrangement for coordinating EPA and NRC action, in light of the concurrent authorities.
The staff modeled the Homestake site MOU after the Church Rock site MOU; however, there are some differences, including the following:
1.
Unlike the Church Rock site, the Homestake site reclamation plan has not h
been approved, although it has been submitted to the Uranium Recovery Field Office for review.
The proposed MOU requires NRC to keep EPA informed of NRC progress in reviewing the reclamation plan.
2.
For the Church Rock site, a Record of Decision (ROD) to address ground-water contamination had not been issued at the time the MOU was signed.
The Homestake site, however, was placed on the NPL approximately 15 years ago, because of ground-water contamination.
EPA issued an R0D that required the Homestake Mining Company to provide a public water supply to residents in a small subdivision, downgradient of the tailings impoundment, that used the contaminated water for domestic purposes.
Additionally, the Homestake Mining Company instituted a ground-water injection /pumpback program that maintains the contaminated plume near the impoundment and within lands owned by it. However, this was only an interim measure, and a long-term solution is still needed to remedy i
ground-water contamination at the site.
3.
Although EPA's inclusion of the Homestake site on the NPL was due to ground-water contamination, radon became an issue when a study by the State of New Mexico indicated that there were radon-caused gaseous effluents in some homes in the area of the site (radon was not an issue at the Church Rock site). However, based on a subsequent study by Homestake Mining Company, EPA concluded that elevated levels of radon in some homes in the area were related to construction quality and naturally occurring radon, rather than to the Homestake site.
Therefore, radon levels were not initially an issue for the Homestake site and are not an issue now, and consequently have not been addressed in the proposed MOU.
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The Commissioners 4
i NRC, Region IV and EPA, Region 6 staffs have developed an MOU, for the Homestake site, that reflects the differences, yet contains the same key provisions as the Church Rock site MOU.
This MOU would continue to reduce NRC and EPA duplication of effort; demonstrate a cooperative effort in accordance with the March 16, 1992, MOU; and clearly define each agency's responsibilities.
COORDINATION:
The Office of the General Counsel has reviewed this paper and the MOU, and has j
no legal objection.
RECOMMENDATIONS:
1.
Unless advised to the contrary by the Commission, Region IV plans to sign l
the M00 no less than 10 working days from the date of this paper.
l 2.
After being signed by both Regional Administrators, the MOV will be noticed in the Federal Reoister.
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ylor xecutive Director for Operations
Enclosures:
1.
Proposed MOU i
2.
Letter, EPA to NRC, dated November 17, 1992 3.
Letter, NRC to EPA, dated December 3, 1992 l
l SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Wednesday, October 27, 1993, that the Commission, by negative consent, assents to the action proposed in this paper.
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MEMORANDUM OF UNDERSTANDING I
BETWEEN REGION 6 0F THE U.S. ENVIRONMENTAL PROTECTION AGENCY AND REGION IV 0F THE U.S. NUCLEAR REGULATORY C0fMISSION FOR REMEDIAL ACTION AT THE HOMESTAKE MINING COMPANY URANIUM MILL i
IN CIBOLA COUNTY, NEW MEXICO I.
PURPOSE l
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This document establishes the roles, responsibilities, and relationships between Region 6 of the U.S. Environmental Protection Agency (EPA) and Region IV of the U.S. Nuclear Regulatory Commission (NRC), hereinafter l
collectively referred to as the " Parties," regarding remedial action at the Homestake Mining Company (HMC) uranium mill in Cibola County, New Mexico. The Parties have overlapping authority in connection with this site and,
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2 consistent with the purposes of the March 16, 1992, interagency Memorandum of l
Understanding between EPA and NRC entitled " Guiding Principles for EPA /NRC l
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Cooperation and Decision Making," this Memorandum of Understanding (M0U) will help assure that remedial actions occur in a timely and effective manner.
II.
BASIS FOR AGREEMENT 4
NRC will assume the role of lead regulatory agency for the byproduct material disposal area reclamation and closure activities and EPA will monitor all such activities and provide review comments directly to NRC. The objective of EPA's review and comment will be to assure that activities to be conducted under NRC's regulatory authority will allow attainment of applicable or relevant and appropriate requirements under the Comprehensive Environmental Response Compensation and Liability Act of 1980, as amended (" CERCLA").
42 U.S.C. Section 9601 at sea, outside of the byproduct material' disposal site. NRC will require the Licensee to implement an approved disposal site reclamation plan which meets the requirements of 10 CFR Part 40, Appendix A, as amended at 52 Fed. Rec. 43553 through 43568 (November 1987), " Uranium Mill 1
i Tailings Regulations; Ground Water Protection and other Issues," which conforms with the EPA 40 CFR Part 192, Subpart D.
EPA and NRC agree that the requirements of 10 CFR Part 40, Appendix A, are the Federal environmental and public health requirements applicable or relevant and appropriate to the J
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disposal site.
EPA and NRC believe that conformance with 10 CFR Part 40, Appendix A, will generally assure conformance with CERCLA requirements.
However, each party will be responsible for assuring compliance with its specific regulatory requirements as discussed in this section. The parties believe that the U.S. Department of Energy or another responsible State or Federal authority will assume responsibility for long-term care of the byproduct material disposal site following remediation of the site.
III. BACKGROUND The State of New Mexico was responsible as an " Agreement State" for licensing and regulating uranium mills within the State until June 1,1986, at which time, NRC reassumed this authority at the request of the Governor of New Mexico. Prior to this change, EPA had placed the HMC site on the National Priority List (NPL) of sites for response action under CERLCA.
EPA's policy is to list only those uranium mills meeting criteria for placement on the NPL which are located in Agreement States, i.e., States which have entered into agreements with NRC pursuant to Section 274 of the Atomic Energy Act of 1954, as amended, to regulate certain nuclear activities in a manner compatible with NRC's program. Mills in States where NRC has direct licensing authority have not been placed on the list. Although New Mexico is no longer an Agreement State insofar as uranium recovery operations are concerned and NRC has reassumed primary jurisdiction, the site was properly placed on the NPL and the physical conditions resulting in that placement are still present. After completion of the closure of the disposal area and other remedial measures
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undertaken in full compliance with 10 CFR Part 40, Appendix A (the applicable Federal standards for disposal site reclamation), EPA, pursuant to 40 CFR Parts 425(e) and 515(c)(3) and in consultation with the State of New Mexico, shall determine whether all required response actions with respect to the site have been implemented. Following such a determination, the site may be considered for deletion from the NPL.
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IV.
AGREEMENT In order to achieve satisfactory cleanup of the HMC site, NRC and EPA agree to do the following:
1.
The Parties shall cooperate witn each other in the oversight of reclamation and remedial activity at the HMC site.
2.
EPA will review the amendments to the site reclamation plan ("the plan") and will provide comments to NRC. NRC will review and, if necessary, require revisions to the plan to assure conformance to 10 CFR Part 40, Appendix A, as amended, prior to approving the plan via license amendments. NRC will provide EPA with copies of all license amendments which affect the site closure plan prior to issuance for comment.
If no comments are received within 30 calendar days, NRC will issue the amendment.
3.
If EPA determines that remedial actions are deficient or unsatisfactory, then EPA shall provide notice to NRC of the defici ency. NRC shall assume the lead role for notification to HMC, except for such notification as EPA might statutorily be i
required to provide in certain events. The notification shall specify a time period within which regulatory compliance is expected to be achieved. Should compliance not be achieved in this time period, EPA will assume the lead for taking or seeking any enforcement action within its area of regulatory responsibility and NRC will assume the lead for any enforcement actions necessary within its area of regulatory responsibility.
Both Parties reserve all rights under this MOU to take whatever actions are determined to be necessary, including the conduct of remedial actions within and outside the disposal area, in order to fulfill their regulatory requirements.
In any event, no actions 4
affecting site remediation will be taken by either Party without prior consultation with the other Party.
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4.
Both Parties shall appoint a facility coordinator who shall be responsible for oversight of the implementation of this MOU and
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the activities required herein. The facility coordinators shall
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be appointed by each Party within seven (7). days of the effective date of this MOU. Each Party has the right to appoint a new i
facility coordinator at any time. Such a change shall be accomplished by notifying the other Party, in writing, at least five (5) days prior to the appointment, of the name, telephone number, and mailing address of said facility coordinator.
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5.
The Parties will meet periodically at the request of either Party and at least semiannually insofar as it is necessary to accomplish j
l the objectives of this MOU. The facility coordinators should communicate with each other on a routine basis by telephone.
6.
The Parties will provide technical advice and any necessary l
2 regulatory consultation to one another upon ' request.
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7.
The Parties will generally provide each other with copies of all official correspondence and documents related to remedial actions at the site. The Parties will also normally provide copies of f
Other information upon request.
In the event that one of the Parties does not wish to furnish certain specific information, documents, or correspondence to the other, then said material shall be identified to the other Party along with the reasons for withholding it.
8.
Whenever notice or information is required to be forwarded by one party to another under the terms of this MOU, it shall be given by and directed to the individuals at the addresses specified as
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follows:
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4 EPA: Director Hazardous Waste Management Division (6H)
U.S. EPA, Region 6,1445 Ross Avenue, Suite 1200 Dallas, Texas 75202-2733 NRC: Director Uranium Recovery Field Office Region IV, U.S. Nuclear Regulatory Commission P.O. Box 25325 Denver, Colorado 80225 1
9.
Routine communications may be exchanged verbally, in person, or by telephone between the Parties to facilitate the orderly conduct of work contemplated by this MOU.
10.
EPA enforcement documentation provided under this MOU will be kept as exempt material by EPA and NRC, to the extent legally possible, according to the policies and procedures under 40 CFR Part 2 and 10 CFR Part 2.790, respectively.
11.
The Parties shall notify each other of any pending visits to the HMC property which relate to the site closure plan. To the extent that they are otherwise authorized to do so, either party and their consultants may, at their option, accompany the other party on such visits.
V.
AGENCY RESPONSIBILITIES A.
NRC Responsibilities 1.
NRC will ensure that the owners / operators of the HMC uranium mill implement an approved reclamation plan that meets all relevant NRC requirements, including 10 CFR Part 40, Appendix A, as amended.
The reclamation plan will require HMC to assure long-term stability of the tailings, reduce gamma radiation to background levels, and dimir.ish radon exhalation to appropriate regulatory 5
standards.
If any part of such plan is not complied with by HMC, NRC will take whatever actions it deems appropriate to ensure compliance.
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2.
NRC will ensure that the owners / operators of the HMC uranium mill implement a compliance monitoring program for hazardous constituents that meets all relevant NRC requirements, including 10 CFR Part 40, Appendix A, for the establishment of ground water i
protection standards and points of compliance. NRC will l
verify implementation by HMC of any required compliance monitoring and/or ground water corrective action at the HMC uranium mill site resulting from the establishment of ground water protection standards as soon as such is reviewed and accepted by NRC.
If any l
I ground water requirements are not complied with by HMC, NRC will take appropriate action to. ensure compliance.
r 3.
NRC will direct HMC to provide both Parties with copies of major l
work product submittals as they become available. Such work products will include a reclamation plan and any other plans and specifications for assessment, remediation, and monitoring, including all analytical data.
i 4.
NRC agrees to provide EPA with progress reports on HMC's i
remediation, semiannually.
i 5.
NRC will assist in the development of information to support EPA's deletion of the site from the NPL upon completion of the remedial i
action, if appropriate.
I B.
EPA Responsibilities 1.
EPA will provide formalized review, consultation, and comment
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throughout the entire project.
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2.
EPA will review and provide comments on the various components of the reclamation plan, ground water monitoring, and corrective action submittals, and other related documentation, within timeframes as agreed to between NRC and EPA.
In the event that j
EPA determines that the implementation of the site reclamation plan, closure activities, and/or ground water corrective action l
has not resulted in, or may not result in,-cleanup conditions that I
meet applicable or relevant and appropriate requirements under -
CERCLA, then EPA may take whatever action it deems appropriate.
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VI.
DISPUTE RESOLUTION i
In the event of a dispute between EPA and NRC concerning site activities, the persons designated by each Agency as facility coordinators, or in their absence, alternate contact points will attempt to promptly resolve
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such disputes.
If disputes cannot be resolved at this level, the problem will l
l be referred to the supervisors of these persons for further consultation. The supervisory referral and resolution process will continue, if necessary to resolve the dispute, to the level of the Regional Administrators of NRC and l
EPA. Both Parties shall continue to maintain their respective rights or 8
responsibilities under this MOU during the dispute resolution process.
i VII. EXECUTION AND TERMINATION 1
l This agreement shall take effect upon execution by EPA and the NRC.
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j shall remain in effect for the duration of the program addressed herein unless
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terminated by mutual agreement by the two Agencies; or this MOU may be terminated unilaterally if any of the conditions set forth below are present:
1.
The planning or conduct of reclamation plan, closure activities, and/or ground water cleanup actions fail to meet standards set forth in the Basis for Agreement (Section II) of this MOU.
2.
The site is deleted from the NFL.
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3.
The site is turned over to the Department of Energy or other responsible State or Federal authority for long-term care.
4.
Regulatory, statutory, or other events occur which make this MOU unnecessary, illegal, or otherwise inappropriate.
VIII. MODIFICATION The Parties may modify this MOU from time to time in order to simplify and/or define the procedures contained herein.
Each Party shall keep the other informed of any relevant proposed modifications to its basic statutory or regulatory authority, forms, procedures, or priorities. This MOU shall be revised, as necessary, by the adoption of such modifications. The MOU should be reviewed on an annual basis by both the Director, Uranium Recovery Field Office, Region IV, NRC, and the Director, Hazardous Waste Management Division, Region 6, EPA, or their designated representatives.
IX.
RESERVATION OF RIGHTS The Parties reserve any and all rights or authority that they may have, including but not limited to legal, equitable, or administrative rights.
This specifically includes EPA's and NRC's authority to conduct, direct, oversee, and/or require environmental response in connection with the site, as well as the authority to enter the site and require the production of information, within each of their own areas of responsibility.
X.
SEVERABILITY The nullification of any one or more sections or provisions of a section of this MOU, either by Agreement of the Parties or by Administrative or Judicial Action, shall not affect the other sections / provisions of this MOU.
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Executed and agreed to:
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James L. Milhoan Date Regional Administrator U.S. Nuclear Regulatory Commission Region IV, Arlington, Texas P
l Date Regional Administrator U. S. Environmental Protection Agency
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Region 6 Dallas, Texas t
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I Mr. James L. Milhoan
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U.S. Nuclear Regulatory Commission I
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600 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064
Dear Mr. Milhoan:
On March 16, 1992, the top administrators of the Environmental Protection Agency (EPA) and the Nuclear Regulatory Commission (NRC) signed a Memorandum Of Understanding (MOU) to achieve an increased level of cooperation and reduced regulatory overlap between EPA and NRC.
Prior to that, on August 26, 1988, our regional offices signed an MOU concerning reclamation and remediation of the Church Rock uranium recovery facility near Gallup, New Mexico. A similar MOU was drafted in April 1990, for the Homestake Mining Co. (HMC) facility near Milan, New Mexico. However, NRC requested that it not be implemented until the interagency MOU was in place. Both of the above mentioned facilities are listed on the National Priorities List (NPL).
j In October 1987, the NRC revised 10 CFR Part 40, Appendix A, to be compatible with EPA's 40 CFR Part 192. These revisions will assure long-tern control of radiological hazards, attenuation of radon emissions to prescribed limits and restoration of ground water to regulatory standards. To provide for continued control of the mill tailings after completion of reclamation, NRC also revised 10 CFR Part 40 in October 1990, to issue general license to the Department of Energy, or the state in which the tailings reside at their option.
Therefore, an MOU addressing remediation and reclamation of the HMC Milan Site would eliminate dual Federal regulation.
Now that our interagency MOU is in place, and based on our understandings stated above, EPA Region 6, requests that efforts to develop a site specific MOU for the HMC Milan Site be reactivated.
Both our agencies have the primary motivation to assure that the Homestake Site is reclaimed in a manner that protects human health and the environment. Implementation of an MOU for this site would assure completion of orderly site closure, elimination of duplicate Federal regulation, and provide for the eventual removal of the Homestake site from the NPL.
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A summary of our recent efforts is enclosed. This background material is the likely sequence of events leading to long-term care for the site, and has been jointly developed by the project coordinators of my staff, and your Uranium Recovery Field Office.
Our experience of working together for the United Nuclear Church Rock MOU should provide a basis for completion of an MOU for the Homestake Milan Site. A draft MOU along the lines of the United Nuclear Church Rock MOU is enclosed for review by your staff.
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. Wynne Regional Administrator Enclosures (2) l i
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B. J. Wynne, Regional Administrator l
U.S. Environmental Protection Agency Region 6 1445 Ross Avenue, Suite 1200 Dallas, Texas 75202-2733 1
Dear Mr. Wynne:
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Your November 17, 1992, letter discusses the duplicate regulatory efforts at j
the Homestake Mining Company facility near Milan, New Mexico, and proposes a Memorandum of Understanding (MOU) between our agencies.
I agree with your l
conclusion that cooperative efforts at the site can reduce regulatory overlap between EPA and NRC through minimization of duplicative regulatory oversight, j
I support the finalization of a MOU between EPA,-Region 6, and NRC, Region IV to define each agency's role as well as accomplish the objectives stated in the March 16. 1992, interagency MOU.
I We have reviewed your proposed MOU and have several areas needing clarifi-cation or updating. Our Denver Uranium Recovery Field Office has schedulea a i
meeting with your staff at your Dallas office for December 10, 1992, at i
10:00 a.m.
This meeting should provide an opportunity to modify the proposeo MOU such that a mutually agreeable document can be readied for our respective agency senior management. After their endorsement. we will arrange a mutually l
acceptable time-to sign the final M00.
i The NRC point of contact for developing an interagency M00.for the Homestake Mining Company facility near Milan, New Mexico is Mr. Ray Hall, Director of j
the Uranium Recovery Field Office (303-231-5800).
Sincerely, i
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J.:c ;ames 1. Milhoas J ~4' 2 a a '
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