ML20127H459

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Forwards Acceptance Criteria That Will Be Used to Judge Adequacy of Groundwater Monitoring Program.If Changes to Program Necessary,Request for Amend to License Should Be Submitted Prior to 840930
ML20127H459
Person / Time
Issue date: 07/10/1984
From: Rich Smith
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
AMERICAN NUCLEAR CORP.
Shared Package
ML20127A611 List:
References
FOIA-84-709 IEA-6.11, NUDOCS 8506260339
Download: ML20127H459 (27)
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URFO:NP IEA 6.11 American Nuclear Corporath n 314 West Midwest Avenue '

Casper, Wyoaing 82601 Gentlerer:

On February 2,1984 I sent you a letter which informed you of the effective date of the Environmental Protection Agency's environmental standard for uraniur. nfl1 tailings, 40 CFR 192. At that tine, you were cdvised that you should assure that all activities and actions undertaken should not be in conflict with the new standards.

The Ccer ion was instructed by the legislation that mandated these

r. t an d> " confom its rules to the new EPA standards. In anticication s, ' tr - . NRC suspended portions of its rules governing the canagem."

rf ure' .. "ill tailings, Appendix A to 10 CFR Part 40. At the present t 1 rc , '. - * .xanission has not taken action to confom its rules and the temocrory susper.sion of portiorts of Apper. dix A has expired with the resi.it that the regulations contained therefn are effective. Since'there are s=.e inconsistencies between 40 CFR 192 anc Appendix A that the ar.ti:: pated rulemaking would address, interic neasures rust be take,) to d d with inis situation.

Section 192.22(a)(2)(iii) of 40 CFR 192 requires that detection l Ocnitoring programs for ground water be in place and operational by Septerter 30,193a. Recognizing that you have a Ground water ponitoring progran, we have developed Acceptance Criteria that we will use to judge the adequacy of your system as a detection r,onitoring system as called

'cr in the EPA standard. A copy of these criteria is attached.

At this tine, you should review your ronitoring prograra against these c-iteria to determi e whether tredifications are necessary in order to rett the acceptance criteria. If your review determines that changes twt be r.ade, you should suboit a request for an arendnent to your license sufficiently in advance of the September 30 deadline to permit l

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IEA 6.11/HJP/84/07/06/1 our review. For example, your present systen would not appear to meet the following criteria:

1. Criterion 2 - The NRC staff has observed that AMC does not have a suitable " point of compliance" well for tailings pond No. 2.
2. Criterion 3 - The NRC staff has observed that ANC does not have background wells for either of its tailings ponds.
3. Criterion 4 - The NRC staff has observed that ANC has not' connitted to a defined procedure to establish background levels of monitored paraneters as part of the monitoring program.
4. Criterion 6 - The NRC staff has observed that ANC has not committed to performing rate and direction of ground-water flow on an annual basis.
5. Criterion 7 - The NRC staff has observed that ANC has not comitted to a defined procedure to identify and report

' statistically significant increases above background of monitored parameters as part of the monitoring program.

The results obtained to date from your monitoring system show the presence of ' indicator species', f.e., chemical changes that indicate contaminants in the ground water. Since the next step will be to

' determine whether or not there are hazardous constituents (as defined by the EPA) present, you should also examine your monitoring systen in terns of its effectiveness to monitor for ha:ardous constituents. Obviously, changes in your analytical procedures would be needed to determine the presence or absence of all possible hazardous constituents.

Until the NRC's rulemaking resolyes the question of which of the hazardous constituents listed by EPA must be analyzed for, we intend to deal with this question on a case-by. case basis. Appendix VIII of 40 CFR Part 261 lists over 300 such hazardaus constituents. As an interin measure, we will concentrate our e' forts on those which are knowr, to be present in mill tailings. To do this, we will need to examine ycur particular situation, including taking independent sapples of taflings pond constituents for analysis. We will contact you in the future to let you knew what is needed.

Both the EPA standard and Appendfx A require that actions be taken when contamination of grcund water occurs. The requirements differ socewhat

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DISTRIBUTION UTJO s/f IEA 6.11 URc0 r/f JCollins IEA 6.11/HJP/S4/07/06/1 HP. css HPettengill dljt 10 W 4 IEA 6.11/HJP/64/07/06/1 in tenns of timing and objectives. We intend to req. ire mitigative actions to prevent deterioration of existing grount water. At some tice in the future, these actions might have tc be modi'ted if the rule.?.aking requires.

If you have any questions regarding cut interin measr.;res to irplenant the EFA standard, please call us.

Sincerely, I

R. Dale Sr.itn, Ofrector Uranium Recovery Field Office Region IV Attaenment: As stated cc: karican Nuclear Project P.O. Box 1520 505 Hursh Street Riverton, WY 82501 9 9

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" w URNi!UK RECOVERY LICENSING PROGRAM PROGPM DIRECTIVE GROUND WATER DETECTION HONITORING REQUIRED BY 40 CFR 192 PURPO3E ,

The" purpose of this directive is to establish criteria for determining the acceptabtitty of ground water detection conitoring programs for surface -

impoundmerts, DISCUSil3?i New EPA standards governing the management of uranium and thorium mill tailings (40 CFR 152) were issued Septeser 30 and becare effective Decenter 6,1983.

NRC is recuired to but has not yet confomed its rules to the new EPA standard.

Absent NRC rules implerenting the EPA standard, 40 CFR 192 requirements apply directly to NRC licensee activities and must be implemented by NRC in its licensing program, Sectics 192,32(a)(2)(iii) of EPA's 40 CFR 192 recuires that detection monitoring crograms for ground water (required by 40 CFR 264.98) be in place and operational within one year of issuance of the rule. All NRC licensees subject to the rule must have a cetection menitoring pragram in operation no later than Septarr.ber 30, 1984, ,

ACCEPTA.%E CRITERI A The fundamental requirement for the detection monitoring program is its '

capability to determine if hazardous constituents are leaking from the mill tailings impoundtnent. This is achieved through the sampling of ground water in the upper cst acuifer passing uncer .the tailings impoundment, and analyzing chemical-physical para.-eters or constituents in the water samples that will -

indicate leakage from the impoundment should it occur.

Deterr.instica of acceptability of proposed or cperating detection monitoring programs at sur' ace impoundments shall include censideration of the following:

Criterfen i .

Tne progra.? must be reliable in indicating the presence of hazardous constituents in tne uppermost aquifer under the impoundment. Reliable

' indicatien snail be basec on tne analyses cf ground water samples for l specified chemicri. physical parameters, waste constituents, or reaction ,

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2 products that are reliable indicators of the leakage of hazardous constituents disposed in the impoundnent.

Criterion 2 The program must provide saecies representative of the ground water passing under the impounement at the point of compliance, Representative samples shall be determined by the sufficiency in number of sampling wells and the adequacy of their locations, including cepths, with respect to the uppermost aquifer and its direction (s) of ficw. point of comoliance is '

specified to' provide promet indication of leakage freci the impoundr.v.nt should it occur.

Criterion 3 The program must include sampling locations suitable to determine background levels of monitored parameters and constituents and to detect leakage cf nazardous constituents from the impoundment should it occur.

Suitability of sampling locations shall be detemined by the placement of sampling wells upgradient (background) and downgradient (leakage) of the surf ace 1rpoundment.

Criterion 4 The program, to be fully operational, must have avtileble reliable data on background levels of monitored parameters and constituents, or a procedure implemented for determining background levels of conitored parameters and constt tuentt .

Cr_iterien 5 The program must provide for analyses of ground water samples from all monitoring wells at a frequency cf at least twice each twelve month period, where the first and last samples at any well are spaced at least four snonths apart in that twelve month period. All meritering wells means all background (upgradient) and all leakage detecticn (dewngradient) sampling locations.

Crit _erion 6 The program must include detemination of the rate and direction of ground water flow in the uppermost a:;uffer under the impounement at a frequency of at least once each twelve month period.

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, M erton 7 The program must provide for the identtfication and reporting of statistically significant increases above background levels of monitored parameters and constituents in ground water samples. Statistically signif t: ant in;reases shall be based on factors suen as: variabiitty and values of background levels of rnonitored constituents and parameters, a:cu. 3: cf analytical methoos, limits of detection of analytical methods, at: tne number of saiples.

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synth4tically 11 nee evaporation ponds wttn approved leak detection systers may use t' ie 'an detection systems in lieu of the leak detection monitoring

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Simpson(sayDRC should regulate niill tailings ,,

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. t By ANDREW MELNYKOVYCH - mental groups. Simpson's latest EPA to a considerable deg~ree in Star-Tribune staff writeE

. proposals are an improvement the day-to-day regulatory activities s ,,..- ,-) l M .-

  • over his earlier ideas, the groups

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that Congress very specifically or- *

'g WASHINGTON - Serj.' ' Ali say. .

  • iginally assigned to the Nuclear . i .,

Simpson wants the Environmental , But a proposal which will make Regulatory Commission,' 1; ,(, ?

Protection Agency (EPA) to back it harder to force clean-up' of Simpson said. ' - -

cff in its attempts 'to deal ,with . contaminated g aundwater near e n w i r o n m e n t a l p r o b l e m s , uranium mills is " Irresponsible,"

Dy law, the EPA'can only issue

" general performance standards,"

,? ,g associated with uranium! mill the .ccnservationists say. Such' he said, but has .instead become f { 4,y , i trilings. i , contamination, which is a problem involved in detailed regulation of ] .

i Responsibility for regulating ' in Wyoming, calls for stronger, uranium mills. .

mill tailings lies with the Nuclear not weaker measures, they said. "This usurps the jurisdiction of . t i  ;%,j i Regulatory Commission (NRC), .

' the NRC," Simpson said. "If the  ?

Simpson said in a statement issued ' SIMPSON SAID proposed EPA . uranium mill tallings program is .

Monday. The EPA is restricted to ever to become effective, there .

regulations issued last fall overstep '

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formulating only general '.stan- bcundaries set forth by Congress must be a mutual recognition by !P 8 dards for the NRC to, apply, he in 1978 when ,it passed a law both the EPA and the NRC that.

said. . . ,

.g outlining how mill tailings are to each agency is charged with a 3 Aides to the , Wyoming, Re- be regulated. , . certain responsibility."

  • publican said Simpson is stu'dying "The.' standards promulgated by The EPA rules are "duplicative N ways to ensure the responsibility is . the Environmental' Protection and overlapping," he said. Unless .

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i properly divided. . -

Agency for protecting the public the basic approach outlined by the i' i Those measures have met with a health and safety from the risks of statute is maintained. Simpson ALAN SIMPSON g j mixed response from environ- uranium mill tailings involve the Please see TAILINGS, A14 Warrte El% to back off a

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Continued from Al LESI EY DAbi of the National '

sa d Simpson's aide said the measure is -

e regulatory program will Audubon Society also said "there intended to ensure continuity in the o '

is no need to fix the law." The tailings regulation program.

I Environmental groups say that EPA and NRC should be allowed attitude represents a considerable to work out the details of policy "There are problems with that "

the Sierra Club's Yeager said. "It l7 -

improvement over 'a n earlier . and enforcement. he said.

( amendment, circulated by But conservation groups were ought to be open to improve-ment." ,

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i Simpson's office, which would . Melody Enceks of the Powder have largely removed the mill less pleased with a remaining .

Simpson amendment which would River Basin Resource Council said ig-taih,nas frr m any EPA review, the amendment would exclude groundwater contami- "ir- et

[h "That would make us feel more ' nated .by uranium tailings from responsibly" weaken the ability of comfortable " the Sierra Club's regulation under revised hazardous the EPA to force the clean.up of con minated groundwater in Brooks Yeager said of the ad-ministrative approach. "It was waste laws now before Congress.

The amendment would make it w

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/)/G "We are disappointed Sen I i hke swatting a gnat w(th a sledge-hammer to go after it with the harder to force clean-up of Simpson does not appear to be tailing-contaminated groundwater serious about protecting peorw. legislation. beyond miIi boundaries. groundwater "'she said.

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STATUS OF NRC-LICENSED URANIUM MILLS CURRENT OPERATING STATUS OPERATING MILLS, NO SHUT DOWN PLANS 6 MILLS SHUT DOWN, ANTICIPATING RESTART 6 j

MILLS SHUT DOWN, PLANNING DECOMMISSIONING 1 1

MILLS IN PROCESS OF DECOMMISSIONING 0

NEW MILLS ANTICIPATED IN NEXT FIVE YEARS URF0/RIV 4/19/84

2. .

STATUS OF NRC-LICENSED MILLS EPA REQUIREMENT: SURFACE IMPOUNDMENT (EXCEPT FOR EXISTING PORTION) MUST HAVE A LINER THAT IS DESIGNED, CONSTRUCTED, AND INSTALLED TO PREVENT ANY MIGRATION OF WASTES OUT OF THE IMPOUNDMENT TO THE ADJACENT SUBSURFACE S0ll OR GROUND WATER OR SURFACE WATER AT ANY TIME DURING THE ACTIVE LIFE (INCLUDING THE (40 CFR 192.32(A),

CLOSURE PERIOD) 0F THE IMPOUNDMENT.

40 CFR 264.221(A)).

OPERATING SHUT DOWN NUMBER OF MILLS WHOSE ENTIRE LICENSED 2 3 CAPACITY COMPLIES WITH REQUIREMENT NUMBER OF MILLS THAT WOULD NEED A LINER 3 1 FOR CURRENTLY LICEN5ED CAPACITY TO COMPLY NUMBER OF MILLS THAT NEED ADDITIONAL CAPACITY [ g JT /3' TO OPERATE AND WOULD NEED A LINER TO COMPLY NUMBER OF MILLS WHERE EXEMPTION FROM REQUIRE-MENT MIGHT BE FEASIBLE FOR USE OF AVAILABLE 0 0 CAPACITY OR CONSTRUCTION OF FUTURE CAPACITY URF0/RIV h /10 /Qh

3 -

STATUS OF NRC-LICENSED URANIUM MILLS EPA REQUIREMENT: DETECTION MONITORING PROGRAMS REQUIRED UNDER 5264.98 TO ESTABLISH THE STANDARDS REQUIRED UNDER 5264.92 SHALL BE COMPLETED WITHIN ONE (1) YEAR OF PROMULGATION. (40 CFR 192.32(A)(2)(III)).

NUMBER OF IIILLS THAT HAVE A MONITORING PROGRAM THAT APPEARS TO COMPLY WITH 5264.98 REQUIREMENTS FOR:

OPERATING SHUT DOWN 6 7 MONITORING FOR INDICATOR SPECIES 3 4 MONITORING AT " COMPLIANCE POINT" 4 6 ESTABLISHING BACKGROUND LEVELS 6 7 SEMI-ANNUAL MONITORING FREQUENCY (OTHER REQUIREMENTS NOT EVALUATED)

URF0/RIV 4/19/84 .

b -

STATUS OF NRC-LICENSED URANIUM MILLS .

BASED ON CURRENT MONITORING PROGRAMS, THE NUMBER OF MILLS WHERE:

OPERATING SHUT DOWN NO INDICATION OF GROUND WATER 0 2 CONTAMINATION EXISTS INDICATOR SPECIES INDICATE GROUND WATER 6 5 CONTAMINATION EXISTS ONE OR MORE HAZARDOUS CONSTITUENTS HAVE 6 5 BEEN~ IDENTIFIED IN GROUND WATER 5 3 MITIGATIVE ACTION PROGRAMS ARE IN PLACE URF0/RIV 4/19/84

5 STATUS OF NRC-LICENSED URANIUM MIi_LS CONFORM TO '40 CFR 190, " ENVIRONMENTAL RADI ATION EPA REQUIREMENT:

PROTECTION STANDARDS FOR NUCLEAR POWER OPERATIONS" (l40 CFR 192.32(A)(3)). 2 fe, m. ,,mvar orn M PENDING FINAL EVALUATION, ALL MILLS-NUMBER OF MILLS IN COMPLIANCE:

APPEAR TO BE IN COMPLIANCE.

URF0/RIV 14/19/8f4 ,

6 STATUS OF NRC-LICENSED URANIUM MILLS .

EPA REQUIREMENTS: CONFORM To 40 CFR 440, "0RE MINING AND DRESSING POINT SOURCE..." (40 CFR 192.32(A)(3)).

p toget een NUMBER OF MILLS IN COMPLIANCE:

ALL MILLS l

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URF0/RIV l 4/19/84 -

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STATUS OF NRC-LICENSED URANIUM MILLS .

EPA REQUIREMENT: DISPOSAL AREAS COMPLY WITH 5264.111 AND BE DESIGNED TO PROVIDE REASONABLE ASSURANCE OF CONTROL OF RADIOLOGICAL HAZARDS TO:

BE EFFECTIVE FOR ONE THOUSAND YEARS TO THE .

EXTENT REASONABLY ACHIEVABLE AND, IN ANY CASE, FOR AT LEAST 200 YEARS, AND LIMIT RELEASES OF RADON-222 TO 20 PIC0 CURIES PER SQUARE METER PER SECOND. (40 CFR 192.32(B)(1)).

ALL MILLS NUMBER OF MILLS WHOSE PRELIMINARY RECLAMATION PLANS APPEAR TO MEET THESE REQUIREMENTS URF0/RIV 4/19/84

8 -

STATUS OF NRC-LICENSED URANIUM MILLS .

EPA REQUIREMENT: -THE REQUIREMENTS OF S192.32(B)(1) SHALL NOT APPLY TO ANY P,0RTION OF A. SITE WHICH CONTAINS RA-226

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' ' CONCENTRATIONS, AVERAGED OVER 100 SQUARE-METER $

s LESS THAN: , .

5 eCI/G OVER FIRST 15 CM -

15 PCI/G OVER SUCCEEDING 15 CM LAYERS (40 CFR 192.32'(s)(2)) .

ALL MILLS NUMBER OF MILLS WHOSE PRELIMINARY RECLAMATION PLANS APPEAR TO MEET THIS REQUIREMENT 4

mm k

URF0/RIV 4/19/84 .

STATUS OF NRC-LICENSED URANIUM MILLS 1 .

CURRENT OPERATING STATUS OPERATING MILLS, NO SHUT DOWN PLANS 6 MILLS SHUT DOWN, ANTICIPATING RESTART .6 MILLS SHUT DOWN, PLANNING DECOMMISSIONING 1 1

MILLS IN PROCESS OF DECOMMISSIONING 0

NEW MILLS ANTICIPATED IN NEXT FIVE YEARS t

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R .R,7 URF0/RIV l 21 / 1 9 / 8 l1

STATUS OF NRC-LICENSED MILLS

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EPA REQUIREMENT: SURFACE IMPOUNDMENT (EXCEPT FOR EXISTING PORTION) MUST HAVE A LINER THAT IS DESIGNED, CONSTRUCTED, AND INSTALLED TO PREVENT ANY MIGRATION OF WASTES OUT OF THE IMPOUNDMENT g '\ - TO THE ADJACENT SUBSURFACE S0ll OR GROUND WATER OR SURFACE I WATER AT ANY TIME DURING THE ACTIVE LIFE (INCLUDING THE CLOSURE PERIOD) 0F THE IMPOUNDMENT.

(40 CFR 192.32(A),

40 CFR 264.221(A)).

OPERATING SHUT DOWN NUMBER OF MILLS WHOSE ENTIRE LICENSED CAPACITY COMPLIES WITH REQUIREMENT 2 3 I NUMBER OF MILLS THAT WOULD NEED A LINER FOR CURRENTLY LICENSED CAPACITY TO COMPLY 3 1 1 NUMBER OF MILLS THAT NEED ADDITIONAL CAPACITY ( 3 TO OPERATE AND WOULD NEED A LINER TO COMPLY M / ^

NUMBER OF MILLS WHERE EXEMPTION FROM REQUIRE-MENT MIGHT BE FEASIBLE FOR USE OF AVAILABLE 0 0 CAPACITY OR CONSTRUCTION OF FUTURE CAPACITY

3 STATUS OF NRC-LICENSED URANIUM MILLS EPA REQUIREMENT: DETECTION MONITORING PROGRAMS REQUIRED UNDER 5264.98 p,

/( TO ESTABLISH THE STANDARDS REQUIRED UNDER 5264.92 SHALL BE COMPLETED WITHIN ONE (1) YEAR OF PROMULGATION. (40 CFR 192.32(A)(2)(III)).

p NUMBER OF MILLS THAT HAVE A MONITORING PROGRAM THAT APPEARS TO COMPLY p ,.

WITH 9264.98 REQUIREMENTS FOR

/0PERATING SHUT DOWN g

,7 ,

7 MONITORING FOR INDICATOR SPECIES (('6 3 4 MONITORING AT COMPLIANCE POIIT"> 4 Y

4 6 ESTABLISHING BACKGROUND LEVELS SEMI-ANNUAL MONITORING FREQUENCY \6 7

\

(OTHER REQUIREMENTS NOT EVALUATED) )

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URF0/RIV 4/19/84

b STATUS OF NRC-LICENSED URANIUM MILLS BASED ON CURRENT MONITORING PROGRAMS, THE NUMBER OF MILLS WHERE:

OPERATING SHUT DOWN NO INDICATION OF GROUND WATER 0 2 CONTAMINATION EXISTS INDICATOR SPECIES INDICATE GROUND WATER CONTAMINATION EXISTS 6 5 r ,

ONE OR MORE HAZARDOUS CONSTITUENTS HAVE BEENIdENTIFIEDINGROUNDWATER 6 5 g t &

5 3 MITIGATIVE ACTION PROGRAMS ARE IN PLACE

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>gf+ -g&s 4ggggL%,y w 9 7:n: es an siku.so"~ T u% m% m g eyF y RIy

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n f STATUS OF NRC-LICENSED UPANIUM MILLS EPA REQUIREMENT: CONFORM To 40 CFR 190, " ENVIRONMENTAL RADIATION

.t 8 PROTECTION STANDARDS FOR NUCLEAR POWER OPERATIONS" r.

(40 CFR 192,32(A)(3)),

i NUMBER OF MILLS IN COMPLIANCE: PENDING FINAL EVALUATION, ALL MILLS APPEAR TO BE IN COMPLIANCE.

9 URF0/RIV 4/19/84 -

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STATUS OF NRC-LICENSED URANIUM MILLS EPA REQUIREMENTS: CONFORM To 40 CFR 440,."0RE MINING AND DRESSING POINT SOURCE..." (40 CFR 192.32(A)(3)).

NUMBER OF MILLS IN COMPLIANCE: ALL MILLS l

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I URF0/RIV 4/19/84

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STATUS OF NRC-LICENSED URANIUM MILLS EPA REQUIREMENT: DISPOSAL AREAS COMPLY WITH s264.111 AND BE DESIGNED TO PROVIDE REASONABLE ASSURANCE OF CONTROL OF RADIOLOGICAL HAZARDS TO:

BE EFFECTIVE FOR ONE THOUSAND YEARS TO THE EXTENT REASONABLY ACHIEVABLE AND, IN ANY CASE, FOR AT LEAST 200 YEARS, AND LIMIT RELEASES OF RADON-222 TO 20 PIC0 CURIES PER SQUARE METER PER SECOND. (40 CFR 192.32(B)(1)).

' ALL MILLS NUMBER OF MILLS WHOSE PRELIMINARY RECLAMATION PLANS APPEAR TO MEET THESE REQUIREMENTS I

i URF0/RIV 4/19/84 ,

(;; 3 .t ie g STATUS OF NRC-LICENSED URANLUM MILLS EPA REQUIREMENT: THE REQUIREMENTS OF 5192.32(a)(1) SHALL NOT APPLY TO ANY PORTION OF A SITE WHICH:CONTAINS RA-226 CONCENTRATIONS, AVERAGED OVER 100 SQUARE METERS, i

LESS THAN:

5 PCI/G OVER FIRST 15 CM i;

15 PCI/G 0VER SUCCEEDING 15 CM LAYERS (40 CFR 192.32(s)(2))

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ALL MILLS NUMBER OF MILLS WHOSE PRELIMINARY RECLAMATION l PLANS APPEAR TO MEET THIS REQUIREMENT i

i URF0/RIV 4/19/84 .

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sy URANIUM MILL TAILINGS MEETING APRIL 19, 1984 INDEX

1) MEM0 TO COMM FM CHAIRMAN 4/12/84 RE URANIUM MILI.

TAILINGS

2) MEM0 TO COMM FM DIRCKS 12/22/83 RE STAFF PLANS FOR REVISING URANIUM MILL TAILINGS REGULATIONS
3) MEMO TO CHAIRMAN FM DIRCKS 12/21/83 RE URANIUM MILL TAILINGS TASK FORCE
4) MEM0 TO COMM FM DIRCKS 1/31/84 RE INPUT FROM AFFECTED STATES ON PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS AND ADVANCE NOTICE OF PROPOSED RULEMAKING

( JSECY-83-523)

5) LTR TO CANNON FM DIRCKS 3/9/84 RE DIFFERENCES WITH EPA
6) GRAPHS RE NRC LICENSED CONVENTIONAL MILLS
7) LTR TO DIRCKS FM CANNON 3/21/84 RE RESPONSE TO LTR OF 3/9/84
8) FEDERAL REGISTER 10/7/83 PART IV EPA ENVIRONMENTAL STANDARDS FOR URANIUM AND THORIUM MILL TAILINGS AT LICENSED COMMERCIAL PROCESSING SITES; FINAL RULE

- EPA MILL TAILING STANDARDS WITH CROSS-REFERENCED RCRA STANDARDS j (?

(Ig) MILL TAILING LICENSE FOR PLATEAU RESOURCES LIMITED -

SUA-1371 9/30/84

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11) SECY-83-523 FM DIRCKS 12/28/83 RE PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS AND ADVANCE NOTICE OF PROPOSED RULEMAKING
  1. 12) MEMO TO TECHNICAL ASSISTANTS FM TRUBATCH 1/13/84 RE PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS (SECY-83-523) vP 13) SECY-83-523A FM MALSCH 2/3/84 RE PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS (SECY-83-523)
14) MEM0 TO COMM FM DIRCKS 3/2/84 RE PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS (SECY-83-523 8 523A)

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vH 15) MEMO ~TO COMM FM MALSCH 3/14/84 RE PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS (SECY-83-523 8 523A)

16) MEM0 TO COMM FM DIRCKS 3/6/84 RE URANIUM MILL TAILINGS

.dj'> STAR-TRIBUNE, CASPER, WYO 3/27/84 SIMPSON COMMENTS RE NRC REGULATION OF MILL TAILINGS

18) LTR TO CHAIRMAN FM SIMPSON 3/12/84 RE ENFORCEMENT OF THE URANIUM MILL TAILINGS RADIATION CONTROL ACT OF 1978 (UMTRCA)
19) LTR TO CHAIRMAN FM UDALL 3/23/84 RE NRC/ EPA DIFFERENCES r'

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20) TRANSCRIPT - EXCERPT FM COMMITTEE'S MARKUP 0F UMTRCA IN 1978 WHICH INCLUDES REFERENCES TO THE QUESTION OF EPA'S AUTHORITY TO PROMULGATE GENERAL ENVIRONMENTAL STANDARDS. PROVIDED BY JIM CURTIS d 21) MEMOTOTECHNICkLASSISTANTSFMTRUBATCH4/6/84RE URANIUM MILL TAILINGS (SECY-83-540) uh 22) DRAFT BRIEF FOR PETITIONER AMERICAN MINING CONGRESS IN SUPPORT OF ITS MOTION FOR

SUMMARY

DISPOSITION 4/10/84 10 CFR PART 40 APPENDIX A WITH SUSPENDED RULES 8

. - _. _. _.

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