ML20151V061

for Comment Issue of Rev 1 to Reg Guide 3.5, Std Format & Content of License Applications for U Mills

ML20151V061
Person / Time
Issue date:	11/30/1977
From:	NRC OFFICE OF STANDARDS DEVELOPMENT
To:
References
REGGD-03.005, REGGD-3.005, NUDOCS 8808220084
Download: ML20151V061 (7)

Text

, _ _ _ _ _ _ _ _ _ _ _ _ _

Revision 1

1. co November 1977 U.S. NUCLEAR REGULATORY COMMISSION O g/ g'o ) OFFICE OF STANDARDS DE

,, g DEVEL REGULATORY GUIDE 3.5 STANDARD FORMAT AND CONTENT OF LICENSE APPLICATIONS FOR URANIUM MILLS A. INTf10 DUCTION Paragraph what information the licant wishes to

,. reference and how such info is pertinent.

In order to process or refine ores containing by weight 0.05% or mere of uranium, after removal Changes to existing (lic p ms require the from their place of deposit in nature, an NRC Source issuance of an approp ' t nse endment. An Material License is requirn'. An applicant for a new application for such # nt should describe license or renewal of an uisting license to receive, the proposed cha ir possess, and use source materials is required to pro-vide detailed information oc his proposed facilities, . APPLICATION equipment, experience, and procedures. This infor-mation is used by the Commission in deterinining

, An app a uranium milling license l shou ing Form NRC-2 in cecordance whether the applicant s proposed activities will, .h ments specified in i 40.31 of 10 CFR among other things, result in undue risk to the health uired by A 40.31(f) of 10 CFR Dart 40, and safety of the public. General guidance for tiling l' an applicat,on i is approved in 6 40.31 of 10 CFR Part ic on for a new licens/ should be filed at .

e m nths prior to comfnencing construction 40, "Applications for Specific Licenses." The pur

, pose of this guide is to provide specific guidan e pr p sed mill. An application for renewal of the format and content of an application for existing license should be filed at least thirty days N

Source Material License authorizing uranium lling - r to k expkanon of the existing license. Appli cati ns raay be filed with the Director Office of Nu;-

activities. The information in this guide ge - o I clear Matetlats Safety and Safeguards, U.S. Nuclear provide instructive guidance and sho not Regulatory Commission, Washington, D.C. 20555.

sidered a substitute for a careful ev ation f the proposed program by the applicant o uring App atlons may also be filed in person at the Com- ,

that the application clearly and adequate escribes missi n,s ffices at 1717 11 Street NW, Washing- j the radiation safety proced es that will be followed. t n, D.C. or 7915 Eastern Avenue, Silver Spring, Maryland.

Information not spe a scussed in this guide should be included in th n if it is an impor. The National L.vironmental Policy Act of 1969 tant part of an t i (83 Stat, 852), implemented by Executive Order

,diat,on protection pro- 11514 and the Council on Environmental Quality's gram. An inco lete li non will result in Jelay of issuanc ense! nd may result in dental of a Guidelines of August 1,1973 (38 FR 20550), re-license quires that all agencies of the Federal Govemment prepare detailed environmental statements on propos-Informa submitted to the Commission may be als for legislation and other major Federal actions incorporated the application by reference. linw- ugnificantly affecting the quality of the human envi.

ever, each reference should be clear and specific, ronment. The principal objective of the National En.

i.e., the reference should indicate by date, page, and vironmental Policy Act of 1969 is to build into the U com. ews w .a. e. ~ swn .. * ~ ce a. u s,m a.g ., o. ..SNRC.RE.Q.ULATORY

w. ..w w a. GU. IDES

.i.~.~. i** c-=e. a..m. o c en 4"- . o**a a .,

5--aa.o

,. .~ .cm.e.+.-.,un u ,..~c- . **

,.g. . i.

. i=a.w. .w m .. o

. ~ m.,a

. w.. *. . - n .w,,, o,,

T/,,'7 T%.,7 '"if.U,.Y.l .* C '

• J!**f I I.*.*.*.".*%*,' a.. .

• 7,"Z,,

.yjg , m, . .. ~ -. . .,, ,a jI g.g g.g=;

g gg.

. - . ~.

co . .%

....w..,...>,.-.

.,. . . ,. ,,. w c

..,",,,,",,,'",,,',,,,,,,,",,",.,,,,,,,,,,,,_,'",,,,,,,,,,,,,,,,,,,y,,

,'*.U.7,'.",7,' ". 70'.. ' OC' "[,'I.05 I

s,. ., w ..

."*7

a. w.a.". '.'O~Mi*',.*".',,*"4.*.',!*,.*'n.'.:7.*'.f o e ana o. . o-. 'b. ,,.-

7,*c.'c *.'".,'.O i

8800220004 771130 er 00bY PDR L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -  ;

l I

agency decisionmaking process an appropriate end 2.1 Geography and Demography careful consideration of environmental aspects of proposed actions. Title 10 CFR Part $1, "Licensii.g J3./ Geography and Regulatory Policy and Procedures for Environ- A geographic description of the area in which the L mental Protection," sets forth the NRC policy and mill is located should be provided, including (1) procedures for the preparation and processing of en- maps showing the location of the site with respect to {

vironmental impact statements and related documents State, county, and local subdivisions, plus nearby in-pursuant to section 102(2)(C) of the National En- habited areas and (2) maps (topographic, if available) vironmental Policy Act of 1969 in connection with showing the mill, mill perimeter, Wlings location, the Commission's licensing and regulatory activities. exclusion area bo'mdary, company property, abutting The provisions of 10 CFR Part 51 and i 40.31(f) of and adjacent properties, nearby water bodies, and in- )

10 CFR Part 40, "Licensing of Source Material,,, habited areas, plus other relevant details.

require the submittal of environmental reports by ap- 2./.2 Demography -

plicants for NRC permits and licenses for certain facilities, includ,ngi uranium mills. Thus, an applica- A description of the potentially affected population tion for a uranium milling license must be accom- within a 5 mile radius of the mill snould be provided, panied by an environmental report. Current resident population information, based on most recent census data, should be provided as well C. CONTENTS OF AH APPLICATION as the projected population for the anticipated life of the mill. Significant transient or seasonal population The application should contain the information variations shculd be identified and discussed, incNd-specified in items 1 through 8 of Form NRC-2. The ing bases for assumptions and projections.

information required in items 9 through 14 of Iorm NRC-2 should be incorporated into the various items identified below. Each subject should be treated in 2.2 Meteorology sufficient depth to permit the Commission independ- This section should provide a meteorological de-ently to determine whether the applicant's proposed scription of the site and surrounding area. Sufficient activities will be conducted in accordance with NRC information should be included to permit an inde.

rules and regulations. All pages of the application pendent evaluation by the NRC staff of att1ospheric snould be numbered and dated- '

diffusion characteristics of the local area. The sources of information and data supplied should be

1. PROPOSED ACTIVITIES stated and should include (1) diurnal and monthly av.

This section should briefly discuss the overall mill- etages and extremes of ternperature and humidity;(2) ing proposal for which a license is requested, includ- m nthly wind characteristics including speeds and db ing the following: a brief description of the proposed recu n, annual joint frequency of wind speed, and mill and its location; the corporate entities involved; direction by stability category; (3) data on precipita-the maximum design thmughput of the mill; U Os ti n; and (4) frequency of occurrence and effects of content of the ore to be processed; concentrate yield; storms.

milling pro.ess; tailings management; estimated time schedules for construction and startup; and antici- 2.3 Ilydrology  ;

pated lifetime of the mill.

Sufficient information should be provided to allow

2. SITE CilARACTERISTICS an independent review to be made of all hy.

drologically related design bases, performance re-This section should provide information on the lo- quirements, monitoring specifications, and operating cation of the mill and a description of the geograph- procedures important to safety. Identify the sources ical demographic, meteorological, hydrological, of the hydrologicalinformation, the types of data col-seismological, and geological characteristics of the lected, and the methods and frequency of collection, site and surrounding vicinity. Sufficient information 23./ Groundwater should be provided to permit an independent evalua- 4 tion of site characteristics from a safety viewpoint. Describe the regional and local groundwater aquif.

Applicatiens may reference the pertinent section in ers, formations, sources, ar.1 sinks. Describe the re-the accompanying environmental report, prepared in charge potential of the immediate plant area, includ-conformance with r4RC Regulatory Guide 3.8. ing vertical and horizontal permeabilities of the natu-ral and modified terrain, as well as that of tailing areas. Describe the present and projected regional

' NRC Regulatory Guide 3 8, "Preparation of Environmental 3 ** E "

Repons for t'f anium Mills," pro *iden specific gaidance en the fluenced by the proposed actisities and all local and conienti of an arrlicant's en*ironrnentai repon. regional pubhc users (amounts, water lesels, loca-3.5 2

)

tions, and drawdown); indicate gradients and sea- equipment. Include a disgram of the mill layout indi-sonal variations in groundwater levels beneath the cating areas and points where dusts, fumes, and gases site, are genersted. The diagram should also show the to-cation of the ventilation, filtration, confinement, and 2.3.2 Surface Water dust collection systeins referenced in item 4.1 and the Describe the location, size, shape, and other hy- location of radiation monitoring equipment refer-drologic characteristics of streams, rivers, lakes, enced in items 5.5(1) and 5.5(2),

marshes, estuaries, etc., of the environs. Include a desetiption of any upstream and downstream river contrcl structures and downstream water supply users 3.3 Instrumentation (including location, annount, and purpose, e.g.,

Provide a description of all process instrumentatior domestic, agricultural), and provide a map (topo- and control systems relevant to safety and all radia-graphie, if available) showing major hydrolog,c i fea-tion safety sampling and monitoring instrumentation, tures of the area. including their minimum specifications and operating characteristics. Also, describe and identify by make, 2.4 Geology and Seismology model number, purpose, and location each radioac.

Provide the geologic and seismic characteristics of tive source and/or gauging device used throughout the area and site, the nature of the investigations per- the mill for which a license is required under the pro-formed, the results of investigations, conclesions, visions of 10 CFR Part 30, "Rules of General and identification of information sources. Supple. Applicability to Licensing of Byproduct Material."'

ment the written description with tables and legNe The instrumentation associated with leak testing such graphics as appropriate. sources and/or devices should be identified in this section.

2.4.1 Geology Describe the geologic aspects of the site. The dis.

cussion should note the broad features and general characteristics of the site and environs including 4. WASTE MANAGEMENT SYSTEM p) stratigraphy and structural geology Describe charac-teristics of the subsurface soil or rock including the 4.1 Gaseous (V identification and evaluation of zones of deformation that might act as cotiduits for contaminants, Provide a description of all ventilation, filtration, confinement, and dust collection systems that are used during mill operations to control gaseous 2.4.2 Seismology radioactive materials. Include the type. specifica.

Discuss the seismicity rincluding history) of the tions, and locations of such systems, e.g., ore trans.

regiott. Where possible, associate seismic events with fer points, crushing, grinding, etc. Include an analy-tectonic features identified in the geology discussion, sis of the efficiency of the equipment as designed and Furnish a regional earthquake epicenter map showing operated to prevent radiation exposures to employees site location. and to limit such exposures to as low as is reasonably achievable. Also, include a description of mill dis-charge stacks, including stack heights, types and 3, MILL PROCESS AND EQUIPMENT C neentration of effluents discharged, and methods (i.e., scrubbers, filters, etc.) for contro!!ing releases Provide sufficient information in this section on the of radioactise materials and for limiting such releases mill process and operating equipment to permit the to as low as is reasonably achievable.

independent assessment of the radiological protec-tion factors associated with the proposed milling operations. 4.2 Liquids and Soilds

1. Where retention systems such as levees, dikes, 3,y ggg p ponds, etc., are used to prevent the release of liquid Provide a quantitative flow diagram of the npll or solid westes containing radioactive material to process showing the maximum mill throughput per offsite areas, provide the information specified in unit time including the anticipated moisture content the regulatory position of Regulatory Guide 3.11, of the ore and the composition of all flow streams for "Design, Construction, and Inspection of Embank-each rasjor step in the process. ment Retention Systems for Uranium Mills" (appli-cable information concerning this subject p:ovided in 3.2 Mill Equipment section 2 above need not be repeated here).

\j Provide a physical description and the operating

• These sources will be authorized in the mitt operating license characteristics for all major items of m,ll i process rather than separate NRC byproduct materiallicenses.

3.5 3 l

2. If effluents are to be released into waters of the 4. Provide a detailed description of the program for United States, provide a discussion of the status of ensuring that employee exposures (both airbome and efforts to obtain a water quality certification under external radiation) and effluent releases are "as low Section 401 and discharge permits under Section 402 as is reasonably achievable."

of the Federal Water Pollution Control Act, as amended, or submit copies of these items if already issued. 5,2 Qualifications Provide a description of the minimum qualifica-4,3 Contaminated Equipment tions and experience required of personnel to hold Provide a description of the methods for disposing positions in the applicant's organization assigned the of contaminated waste salids (such as filters, filter responsibility for developing, conducting, and ad-presses, obsolete or worn out equipment) that are ministering the radiation safety program for the mill, generated in the milling process. Also, provide as an appendix the qualifications of the individuals currently holding these positions.

5. OPERATIONS 5,3 Training Compliance with the statements, representations, Provide a description of the employee radiological and procedures provided in this section will normally Protection training program addressing the following:

be made a specific condition of the NRC operating content of the ,nitial i training or inJoctrination, test-license. Thus, the fellowbg should be considered as ing, n.the job training, and extent and frequency of specific commitments en the part of the applicant for I'Ifaining. As an appendix, provide a copy of the conducting mill operations and radiological protec- written radiological safety instructions provided em- ,

tion programs. In order to facilitate administration of Pl oyees. These instructions should include provisions the license by the licensee and NRC, this section I r Persona 1 hygiene including washing, contamina-d.ould be complete in itself, insofar as possible, tion surveying prior to eating or leaving the mill, in-without references to other submittals. Also, the structions for v, caring personnel monitoring devices bases for all programs addressed in this section, as and respirators, and instructions for good housekeep-well as demonstration of their adequacy, should be mg equirements and for cleaning up dust and spills w thin the m,ll.

provided. i 5.1 Corporate Organization and 5.4 Security Administrative Procedures Provide a description of the method for preventing l

1. Provide a detailed description of the applicant's unauthorized entry to both the mill and the tailings organization, including authority and responsibility systems.

of each lesel of management and'er supervision in regard to development, review, approval, implemen-tation, and adhe,ence to operating procedures, radia- 5,5 Radiation Safety tion safety programs, routine and nonroutine mainte. . , ,

nance activities, and changes in any of the above. Provide a description of the radiation safety pro-gram that has been developed for determirung that

2. Describe the management control program and occupational radiation exposures and effluent releases administrative procedures to ensure that all activities will be as low as is reasonably achievable. Include are conducted in acrordance with written operating the following:

procedures that are approved and reviewed at speci. .

fled frequencies by radiation safety staff. This pro- 1. A description of the methods, instrumentation, )

gram should provide a method for ensuring that any and equipment for determining exposures of employ. '

nnnroutine work or maintenance activity, not covered "St . external radiation during normal and non-by an effectise operating procedure, is conducted in r utine operations, maintenance, and cleanup ac-accordance with a special work permit reviewed and tivities. Prov,de i the type of surveys conducted, approved by the radiation safety staff. criteria for determining survey locations, frequency of surveys, action levels, management audits, and

3. Describe the management audit and internal in- corrective action requirements. For personnel spection program, including types and scopes of re- monitoring devices such as film badges, indicate the views and inspections, frequencies, action levels, and number and category of personnel involved in the <

corrective action measuus in regard to the foregoing program and the sensitivity and range of the devices.

activities. Also identify by management position the For survey instruments, provide instrument sen-individual responsible for ea-h phase of the audit and sitivities, ranges, and calibration methods (in an ap-inspection program, pendix) and frequencies.

l 3.5 4 l

fl h }2. A description of the sampling For program thatandiseftluent monitoring, both enviremental Q followed to determine concentrations of airborne radioactive materials (including radon) within the the frequency of sampling and analysis, the types and sensitivity of analysis, action levels and corrective mill during routine and nontoutine operations, action requirements, and the minimum number and maintenance, and cleanup activities. In the descrip- criteria for locating environmental and effluent tion of the sampling program include monitoring stations should be provided. Proposed lo-

. cations should be indicated on a figure of the mill and

a. The en.tena for determining sampling loca- surrounding area in an appendix.

tions with respect to process operation and personnel occupancy and 7.* A description of the liquid effluent survey pro-

. gram to determine if process effluents are reaching

b. The frequency of sampling, type of analysis, subterranean or surface water supplies. This should sensitivity of overall sampling and analysis, actwn include the technical basis therefor, the minimum levels, nanagement audits, corrective action re- number of monitoring locations, the criteria for locat-quirements, and instrumentation calibration fre-

, ing sampling stations, the frequency of sampling, and quency. Procedures for sample analysis and instru- action levels and corrective action requirements. Pro-1 ment calibration should be included as an appendix. vide the step by step procedure for sample analysis of

3. A description of the procedure followed in de- natural uranium, radium 226, and thorium 230 as an termining the intake of radioactive materials, in con. appendix. Also, the proposed monitoring locations formance with 6 20.103 of 10 CFR Part 20, for each should be shown on a figure of the mill and surround employee who occupies areas where airborne radioac- ing area in an appendix.

tive materials exist. Include exposures incurred dur- 8. A description of the radiation safety program mg nonroutine operations, maintenance, and cleanup associated with the radioactive sources and gauges activities as well as routine activities. identified in section 3.3 above. Include methods and

4. A description of the bioassay program to be frequencies for leak testing the radioactive source.

conducted to confirm the results derived from the 9. A description of the interim stabilization procc-programs identified in items 2 and 3 above. Indicate dures (during milling operations) to eliminate the n the number and category of personnel involved in the blowing of tailings from the tailings retention system

/ program, the types and frequencies of bioassays per- to unrestricted areas and the ore dust from the ore

\ formed, and action level critena to be applied t piles should be provided, including the demonstration bioassay results, of the adequacy of these procedures under potential

5. A description of the survey program to deter- wind and weather conditions at the site location, mine that employees (plus their workelothes or .

coveralls, etc.) entering clean areas (lunchrooms, of. 10. Provide the minimum performance specifica- ,

fices, etc.) of the mill or leaving the mill site are not tions, such as filtration or scrubber efficiency and air )

coctaminated with radioactive materials. Include (1 w, f r perating the mill ventilation, filtration, good housekeeping and cleanup requirements and canfinement, and dust collection systems throughout specifications in mill process areas to control con- the mill and associated laboratories at their ren- l tamination, frequency of surveys of clean areas, sur- s nably expected best performance and the frequensy vey methods, and minimum sensitivity, range, and f tests and inspections to ensure that these specifica-calibration frequency of survey equipment. Provide tions are being met, contamination criteria or action levels for clean areas 11. Provide a decommissioning program that in, and for the release of materials, equipment, and cludes reclamation of the mill site at the termination ,

workelothes to clean areas or from the site. Proce- of milling activities and the surety arrangements to l l dures for instrument calibration should be included as ensure that sufficient funds are available to complete I an appendix. this decommissioning program.

6.* A description of the survey program, methods, 12. Provide a tailings management and reclama-and procedures for determining concentrations and tion program addressing the following performance quantities of airborne radioactive materials released objectives to the environs and a description of the environmental monitoring program to be conducted plus the techni- a. Reduce direct gamma radiation from the im-  !'

l cal basis therefor (i.e., a correlation of stack heights, poundment area to essentially background.

meteorological characteristics, etc.) to determine en- b. Reduce the tsdon emanation rate from the vironmental concentrations. impoundment area to about twice the emanation rate g 40 CIR Chapter 1. Pan 190. and Regulatory Guide 4.14, in the surrounding environs.  !

"Measurias. E*aluatins, and Reporting Radioactiuty in Re. g g go g

) leases oi Madioactive Matenals in Liquid and Airborne Eftluents g g v

frorn l'raniurn Mills." should be reuemed it connection eith and maintenance program following successful ]

this section. reclamation.

3.5 5 l l

- ___________________________a

. . 1

d. Provide surety arrangements to ensure tha: suf- up and operation, and the radiation safety program i ficient funds are available to complete the full recla- (including the in plant, effluent, and environmental l mstion plan, monitoring programs)* should be defined and dis-cussed. Also discuss the corrective action measures

6. ACCIDENTS established to ensure that conditions adverse to qual.

ity are identified and corrected and that the cause of A spectrum of potential mill accidents ranging from trivial to serious should be estaolished by significant conditions adverse to quality is deter-classes of occurrence, and each class of accidents mined and corrective action taken to preclude repeti-gion, should be appropriately evaluated. The evaluation should include a discussion of measures that have been implemented to prevent accidents and a demon-stration of the adequacy of the methods. Emergency plans and training for coping with accidents should 8. EVALUATION OF ALTERNATIVES also be described. For example, potential accidental Where the proposed course of action was based on fires should be discussed in terms of occurrence, pre- the consideration of various alternatives, the vention, detection and suppression mechanisms (both benefit cost analysis used in arriving at the "as low manual and au'.omatic), and emergency plans for cop- as is reasonably achievable" concept shouM be pre-ing therewith. The adequacy of the program should sented, and the rationale for the recommeaded course also be discussed. of action should be included.

7. QUALITY ASSURANCE

• The NRC staff is preparing a regulatory guide on quality an.

surance for radiological effluent and environmental monitoring The quality assurance program for all phases of the programs that is scheduled to be published for comment in De-milling project including design, construction, start. cember 1977.

O 9

3.5-6 e

UNITEO STATES { -]

NUCLE AR REGULATORY COMMISSION WASHINGTON. D. C. 20555 POST ACE AND FEES PAIO v=it t o state s =vc t s ae OFFICI AL SUSINESS 4 M '

.)

e s cus a t o s , toww.wn=

PEN ALTY FOR PMIV ATE USE. 5300 k.

I f

I i

i l

l O

1 l

l l

l l

l l

i I

i O 1 l