ML20198G258

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Draft Standard Review Plan for in Situ Leach Uranium Extraction License Applications
ML20198G258
Person / Time
Issue date: 10/31/1997
From:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
References
NUREG-1569, NUREG-1569-DRFT, NUDOCS 9801120284
Download: ML20198G258 (250)


Text

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w NUREG-1569 DRAFT STANDARD REVIEW PLAN forIn Situ Leach Uranium Extraction License Applications l

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AVAILABILITY NOTICE Availability of Refarence Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

1. The NRO Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

-20555-0001

2. The Superintendent of Documents, U.S. Govemment Printing Offico, P. O. Box 37082, Washington, DC 20402-9328
3. The National Technical Information Service, Springfield, VA 22181-0002 Although the listing that follows represents the majority of documents cited in NRC publica-

- tions, it is not intended to be exhaustive.

Referenced documents available for inspection and copying for a foe from the NRC Public Document Room include NRC correspondence and internal NRC memorande; NRC bulletins, circulars, information noticos, inspection and investigation notices; licensee event reports; vendor reports and correspondence; Commission papors; and applicant and licensos docu-

- ments and correspond 0nce.

The following documents in tho NUREG series are available for purchase from the Government Printing Office: formal NRC staf, and contractor reports, NRC-sponsored conference pro-ceedings, international agreement reports, grantee reports, and NRC booklets and bro-chures. Also availabio are regulatory guides, NRC regulations iri the Code of Federal Regula-

. tions, and Nuclear Regulatory Commission issuances.

Documente available from the National Technical information Service include NUREG-s: -ies reports and technical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

Documents available from public and special technical libraries include all open literature items, such as books, journal articles, and transactions. Federal Register noticos. Fodoral and State legislation, and congressional reports can usually be obtained from these libraries.

Documents such as theses, dissertations, foreign reports and translations, and non-NRC con-forence proceedings are available for purchase from the organization sponsoring the publica- ,

tion cited. '

Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration, Distribution and Mall Services Section, U.S. Nuclear Regulatory Commission, Washington DC 20555-00;1.

Copies of industry codes and standards used in a substantivo manner in the NRC regulatory process are maintained at the NRC Library. Two White Flint North 11545 Rockville Pike, Rock-ville, MD 20852-27'18, for use by the public. Codes and standards are usually copyrighted and rnay be purchased from the originating organization or, if they are American National Standards, from the Arnerican National Standards institute,1430 Broadway, New York, NY 10018-3308.

NUREG-1569 DRAFT STANDARD REVIEW PLAN for In Situ Leach Uranium Extraction License Applications Manuscript Completed: September 1997 Date Published: October 1997 I

l Division of Waste Management Office of Nuclear Material Safety and Safeguards l U.S. Nuclear Regulatory Commissien Washington, DC 20555 0001 pa %q ig[/

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COMMENTS ON DRAFT REPORT -

- Any interested party may submit comments on this report for consideration by the NRC staff. ~

Please specify the report number, draft NUREG 1569, in your comments, and send them by the, due date published in the Federrj Register notice to:

Chief, Rules Review and Directives Branch OfTice of Administration Mail Stop T6-DS9 Washington, DC 20555-0001

-.--- - _ _ _ 1_ _ _ _ _ _ _ _

ABSTRACT A Nuclear Regulatory Commission source and byproduct material license is required to recover uranium by in situ leach extraction techniques under the provisions of Title 10 Code of Federal Regulations, Part 40 (10 CFR 40), Domestic Licensing of Source Material. An applicant for a research and development c :ommercial scale license, or for the renewal or amendment of an existing license is required to provide ,

detailed information on the facilities, equipment, and procedures used and an environmental report that discusses the effects of proposed operations on the health and safety of the public and on the environment.

k The Standard Review Plan is prepared for the guidance of staff reviewerz in the Office of Nuclear Material Safety and Safeguards in performing safety and enviromnental reviews of applications to develop and operate uranium in situ leach facilities it provides guidance for new license applications, renewals, and amendments. The principal purpose of the standard rev;cw plan is to assure t1.4 quality and uniformity of staff reviews and to present a well defir,ed base from which to evaluate changes in the scope and requirements of a review.

The standard review plan is written to cover a variety of site conditions and facility designs. Each section is written to provide a description of the areas of review, review procedures, acceptance criteria, and evaluation of findings. Ilowever, for a given application, the staff reviewers may select and e iphasize particular aspects of each standard review plan section as is appropriate for the application.

iii NUREG-1569 n______________--_

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s TCONTENTS 1 q

Pagec l A BSTRACT . . -. . . . . . . . . . '. . , . . . . =. .. : . . . . v.e. . .- . - . .- . . . . . . . . - .

. . . . . s . . . , lii . j

^

FIOU RES . . . . ., . . . ., . . . . . . . . .4.. ........-.....-.......-.........,.,.!vil

- TA B LES . . . . . . . . . . . . . . . . . . . . . . . c . . . . . . . o . . . . : . . . . . . . . . . , . . . . . . . . . . : ix

- _I NT RO D U CTIO N . . . . . . . . , ; . . . , . _. . . . . . . . . . . _ . . . . . . - , . . . . . . . . . . .. . . . . s . xi l'.0 .PROPOS ED ACTIVITIES . - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 2.0 - SITE CH ARACTERIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . < 2 1 .  :

2.1 SITH LOCATION AND LAYOUT , , . . . . . . . . . . . . . . . . . . . . . . . .=. . . 2 '

2.2 USES OF ADJACENT LANDS 'AND WATERS ' . , , . . . . . . . . . . . . . . . . . 2-3'

' 2.3- POPULATION DISTRIBUTION . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . 2-6  :

2.4 = - REGIONAL HISTORIC, ARCHEOLOGICAL, ARCHITECTURAL, SCENIC, '

CULTURAL, AND NATURAL LANDMARKS . . . . . . . . . . . s . . . . . . . . 2-8

. 2.5- M ETEOROLOG Y - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2- 1 1 .

GEOLOGY AND SEISMOLOGY . . . . . . . . . . . . . . . , . . . . , ,- . . . . . 2 ~

2.6'-

2.7 H Y D RO LOG Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 _:

ECO LOG Y - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 27 2.8 2.9 - - BACKGROUND RADIOLOGICAL CHARACTERISTICS . . . . . . . . . . . . . 2-30 2.10 BACKGROUND NONRADIOLOGICAL CH ARACTERISTICS . . . . . . . . . 2 .

2.11 OTHER ENVIRONMENTAL FEATURES . . . . . . . . . . . . . . . . . . . . . . . 2-35

- 3.0 PESCRIPTION OF PROPOSED FACILITY , . . . . . . . . .................. 3-1 -

3.1 SOLUTION MINING PROCESS AND EQUIPMENT . . . . . . . . . . . . . . . 3-1 i 3.2 ' RECOVERY PLANT EQUIPM ENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9 3,3 INSTRUMENTATION . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . 3-10 4.0 EFFLUENT CONTROL SYSTEMS . . . . . . . . . , , , . . . . . . . . . . . . . . . . . . . ' 4-1 4.1 G ASEOUS AND AIRBORNE PARTICULATES . . . . . . . . . . . . . . . . . . . . 4-1 4.2 LIQUIDS AN D SOLIDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . = 4-3 4.3 CONTAMINATED EQUIPMENT 4 .............................-4-8 5.0 OP E RATI O N S . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.1 -. CORPORATE ORGANIZATION AND ADMINISTRATIVE PROCEDURES , . 5 '

- 5.2 M ANAGEMENT CONTROL PROGRAM . . , . . . . . . . . . . . . . . . . . . . . , 5-3 5.3 MANAGEMENT AUDIT, INSPECTION, AND RECORDKEEPING  :

PROGRAM ,..,....................................... 5 '5.3 I' Management Audit, and Internal Inspection Program . . . . . . ............................... 5-4 15.3.2 Recordkeeping and Record Retention ' . . . . . . . . . . . . , , . , . . . 5-7

'54. QU ALIFICATION S . . . . . . . . .. . . . . . . . . . . . . . , , . . . . . . . . . . . . 5 - 5.54 TRAINING ~. . . . . .....................................5-11

- 5.61 SECURITY .......................................... 5-13 1

5.7- .' RADIATION SAFETY CONTROLS AND MONITORING . . . . . . . . . . . 5 14 .

v  ; NUREG-1569

CONTENTS (cont'd)

Page 5.7.1 Effluent Control Techniques . . . ............ .. ... 5-14 5.7.2 External Radiation Exposure Monitoring Program . . . . . . . . . . . 517 5.7.3 Airborne Radiation Monitoring Program . . . . . . .... . . . 5-20 5.7.4 Exposure Calculations ... ............. ........ . 5 23 5.7.5 Bioassay Program . . . . ....... .. . . . . . . . . . . . . . 5-2 6 5.7.6 Contamination Control Program . . ................... 5-28 5.7.7 Airborne Effluent and Environmental Monitoring Program . . . . . 5-33 5.7.8 Groundwater and Surface Water Monitoring Programs . . . . . . . . 5-35 5.7.9 Quality Assurance . . . . . ..... .. ... ........... . 5-45 6.0 GROUNDWATER QUALITY RESTORATION, SURFACE RECLAMATION, AND PLANT DECOMMISSIONING . . . . . . . . . . . . . . . . . . . . . . . . . . . ........ 6-1 6.1 PLANS AND SCllEDULES FOR GROUNDWATER QUALITY RESTORATION ........... ............... . ...... ... 6-1 6.2 PLANS AND SCHEDULES FOR RECLAIMIN "ISTURBED LANDS .... 6-8 6.3 PROCEDURES FOR REMOVING AND DISPO ?:3 OFSTRUCTURES AND EQUIPMENT . . . . . . . . . . . . . . . ................. ...... 6-11 6.4 PROCEDURES FOR CONDUCTING POSTRECLAMATION AND DECOMMISSIONING RADIOLOGICAL SURVEYS . . . . .. ... .... 6-13 6.5 FINANCIAL ASSESSMENT FOR GROUNDWATER RESTORATION, DECOMMISSIONING, RECLAMATION, WASTE DISPOSAL, AND MONITORING . . . ...... .. ...... .................. 6-17 7.0 ENVIRONMENTAL EFFECTS , . . . . .. .... .. .... ......... . 7-1 7.1 SITE PREPARATION AND CONSTRUCTION . ...... .... ... .. 7-1 7.2 EFFECTS OF OPERATIONS . . . ... ....... .. ...... 7-3 7.3 RADIOLOGICAL EFFECTS ... . . . ...... ..... . ... 7-5 7.3.1 Exposure Pathways ... .......... ..... ..... .... 7-5 7.3.1.1 Exposures from Water Pathways . . . . . . . ....., , ..... 7-5 7.3.1.2 Exposures from Air Pathways ........ ... . ..... , 77 7.3.1.3 Exposures from External Radiation . .... .......... . 7-10 7.3.1.4 Total Human Exposures . . . . . . . . . . . .. .... .... . 7-11 7.3.1.5 Exposures to Flora and Fauna .... .... .. . .. ..... 7-13 7.4 NONRADIOLOGICAL EFFECTS . . . . . . . . .... , ,,...... 7-15 7.5 EFFECT.5 OF ACCIDENTS . . ......... ... ... .. . . .. 7-16 7.5.1 Accidents involving Radioactivity . . , . . . ......... . 7-16 7.5.2 Transportation Accidents . .. . . . ... ..... . 7-17 7.5.3 Other Accidents .. . .... ...... . .... . . . . 7-19 7,6 tiCONOMIC AND SOCIAL EFFECTS OF CONSTRUCTION AND OPERATION ....... . . . ... ...... .... . . 7 20 7,6.1 Benefits ... ........ . .. . . ..... ... 7-2i 7.6.2 Costs . . . . ... .... ....... ... . .. . 7-23 NUREG-1569 vi

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.-CONTENTS (cont'd)- a Page-- -3 7.6.3 -l Resources Conunitted .=. . . . .. . . . . . . . . . . . . . . . . . . . , , 7-25 i 8.0  : ALTERN ATIVES TO PROPOS ED ACTION . --. . . . . . . . . . . . . . . -. . . . . . . . . . . 8-1 9.0 BENEFIT COST AN A LYSIS . . . . . . . .. . . -, . . . . . . . . . . . . . . . . . . . . . . . . . ' . 9 >

- 10.0 . ENVIRONMENTAL APPROVALS AND CONSULTATIONS . . . . . . . . . . . . . . . 10-1 APPENDIX A - GUIDANCE REVIEWING - HISTORICAL ASPECTS OF SITE

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FOR PERFORMANCE FOR LICENSE RENEWALS AND AMENDMENTS APPENDIX B - ENVIRONMENTALJUSTICEINNATIONALENVIRONMENTALPOLICY ACT ,

OF 1%9 DOCUMENTS

APPENDIX C - MILDOS-AREA: AN UPDATE WITH INCORPORATION OF IN SITU LEACH '

URANIUM RECOVERY TECHNOLOGY APPENDIX D - EFFLUENT DISPOSAL AT LICENSED URANIUM RECOVERY FACILITIES APPENDIX E - RECOMMENDED OUTLINE FOR SITE SPECIFIC IN SITU LEACH FACILITY RECLAMATION AND STABILIZATION COST ESTIMATES e

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vii NUREG-1569

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m- - - -, - - - -__m_._--_-__ -

. FIGURES !

Page Figure .~-

Licensing process for 10 CFR Part 40 licenses

,...........xiv 1-2: Schematic of Nuclear Regulatory Commission licensing and inspection

- process and applicability to different license documents . . . . . . . . . . . . . . . . . xvi m

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J ix NUREG 1569

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TABLES Table Page 2.7-1 Typical baseline water quality indicators to be determined during preoperational data collection . . . . . ..... .. .... ............ 2-24 2.9.3 1 Standard format for water quality data submittal to the Nuclear Regulatory Commission for uranium recovery facilities . . . . . ... . ........ 2-32 5.7 1 Acceptable strface contamination levcis ... . .. .. ..... . 5-31 l

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1 xi NUREG-1569 l

INTRODUCTION A Nuclear Regulatory Conumssion (NRC) source and byproduct material license is required under the provisions of Title 10 of the Code of Federal Regulations, Part 40(10 CFR Part 40), Domestic Licensing o! Source Material, to recover uranium by it' situ solution mming techniques (in situ leaching or ISL).

The licensing process for 10 CFR Part 40 licenses is pictured in figure 1. An applicant for a new operating license, or for the renewal or amendment of an existing license, is required to provide detailed information on the facilities, equipment, and procedures to be used, and if appropriate, an environmental report (ER) that discusses the effect of proposed operations on public health and safety and the impact on the environment. This information is used by NRC staff to determine whether the proposed activities will be protective of public health and safety and be environmentally acceptable. General provisions for issuance, amendment, transfer, and renewal of licenses are described in 10 CFR Part 2, subpart A.

General guidance for filing an application and for producing an ER is provided in 10 CFR 40.31 Application for Specific Licenses, and in 10 CFR Part 51 Environmental Protection Regulations for Dom:sti: Licensing and Related Regulatory Functions, respectively.

The purpose of this standard review plan (SRP) is to provide the staff in the Office of Nuclear Material Safety and SaleguarA (NMSS) with specific guidance on the review of applications for ISL facilities. The SRP will be used by the NMSS staff in the review of applications for new facilities, renewals. and amendments. Throughout the remainder of this SRP " application" is synonymous with license application, renewal, or amendment. The principal purpose of the SRP is to ensure a consistent quality and uniformity in the NRC s:aff reviews. Each section in this SRP provides guidance on what is to be reviewed, the basis for the review, how the staff review is to be accomplished, what the staff will find acccptable in a demonstration of compliance with the regubtions, and the conclusions that are sought regarding the applicable sections in Title 10 of the Code of Federal Regulations.

This SRP is intended to cover only those aspects of the NRC regulatory mission related to the licensing of an ISL facility. As such, the SRP helps focus the NRC staff review on determining if a facility can be constructed and operated in compliance with the applicable NRC regulations. The SRP is also intended to make information about regulatory matters widely available and to improve conununications and understanding of the staff review process by interested members of the public and the uranium recovery industry.

For amendments, the focus cf the review should t>e on the changes proposed in the amendment (see appendix A for guidance for reviewing historical aspects of site performance). Reviewers should not review other previously accepted actions if they are not nart of the amendment unless the review of the ,

amendment package identifies p oblems with other aspects of facility operation.

l For renewa's, the licensee need only submit information containing changes from the currently accepted  !

license. As for amendments, the staff reviews should focus on those aspects of facility operation that are (

different from what is in the current license. The licensee need not resubmit a complete application l covering all aspects of facility operation. Reviewers should analyze the inspection history and operation of the site to see if any major problems have been identified over the course of the license term, and should review changes to operations from those currently found acceptable (see appendix A). If the changes are found to be acceptable, then the license is acceptable for renewal.

xiii NUREG-1569

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gge g,,g n m Yes Fedemi Regisier Neuce:

(I) Receipt of appliceoon (2)Oppomeuty for Hennns

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(after Nday EPA revww of EIS) l Applicant's Appeal to the g Commassen No Figure 1. Licensing process for 10 CFR Part 40 licenses NUREG 1569 xiy l

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For license amendments and renewals, the operating history of the facility is often a valuable source of-information concerning the adequacy of site characterization, the acceptability of radiation protection and

= monitoring programs, the success of and adherence to operating procedures and training programs, and other data that may influence the staff's determination of compliance. Appendix A to the SRP provides guidance for review of these historical aspects of facility performance; j The products that will be prepared by the NRC staff to document the review will be a technical evaluation report (TER), and an environmental assessment (EA) with a finding of no significant impact (FONSI).

Preparation of an EA is required under the provisions of 10 CFR 51.20 unless (i) the staff finds based on the EA that NRC needs to prepare an environmental impact statement (EIS), (ii) an EIS is needed by r

another federal agency also involved in the action as a cooperating agency (iii) an EIS would be needed because of controversy at the site, or (iv) the action is categorically excluded from the necessity to prepare an EA by 10 CFR 51.22.

It is important to note that the acceptance criteria laid out in this SRP are for the guidance of NMSS staff responsible for the review of applications to operate ISL facilitics. Review pbns are not substitutes for the Commission's regulations, and compliance with a particular SRP is not required. Methods and solutions different from those set out in the SRP will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a license by the NRC.

General Review Procedure -

A licensing review is not intended to be a detailed evaluation of all aspects of facility operations. Specific information about implementation of the program outlined in an application is obtained through the NRC review of procedures and operations done as part of the inspwtion function. A definition of the differences between licensing reviews and inspections is provided in figure 2.

The general licensing process is outlined in the flow diagram provided in figure 1. An ISL source and byproduct material application may be denied or rejected ander specific instances during the review process. Beginning construction of process facilities, well fields, or other substantial a:tions that would adversely affect the environment of the site, before the staff has concluded that the appropriate action is to issue the proposed license, is grounds for denial of the application [10 CFR 40.32(e)]. The applicant's failure io demonstrate compliance with requirements [10 CFR 40.31(h)], or refusal or failure to supply information requested by staff to complete the review (10 CFR 2.108) are also grounds for denial of the application.

Changes to existing licensed activities and conditions require the issuance of an appropriate license amendment. An application for such an amendment should describe the proposed changes in detail, and should discuss the potential environmental and health and safety impacts. Amendment requests should be

-+

reviewed 2 sing the appropriate sections of this document for guidance. Appendix A to this SRP provides guidance for examining the historical aspects of facility operations that may be useful for conducting such amendment reviews.

The steps of the application review are described in the following paragraphs.

1 xv NUREG-1569

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% increasing e I.evel of Detail License application:

Details on how regulations will be snet Licensing Reviews -

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facility will be operated, and basis k 1

for performance-based licenses 'g

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Implementing procedures: Documersing specific steps that should be followed to implement commaments in the license application and operating plan -) f Inspection Individual facility perso. sl: Follow procedures and operate plant Figure 2. Schernatic of Nuclear Regidatory Comenission licensing and i_, _ska process and appucability to efferent license documents

4 Acceptance Review The staff will conduct an acceptance review of the application to determine the completeness of the information submitted. This review requires a comparison of the submitted information to the information identified in the Standard Fo, mat and Content of License Applications, including Environmental Reports, for in Situ Uranium Solution Mining (SFCG)(Nuclear Regulatory Commission,1982). The application will be considered complete for docketing if the information provided is complete, reflects an adequate reconnaissance and physical examination of the regional and site conditions, and provides appropriate analyses and design information to den.onstrate that the applicable acceptance criteria will be met. The staff should complete the acceptance review and transmit the results to the applicant within 30 days of the receipt of the application along with a projected schedule for the remainder of the review as described in section 1.1 of the SRP. In this transmittal, the staff should identify any additional information needed to make the application complete. Detailed technical questions, while not required, can be included if they are identified during the acceptance review.

Detailed Review Following completion of the acceptance review, the staff will conduct a detailed technical review of the application. The results of this review and the basis for acceptance or denial of the requested licensing action are documented by the NRC in an SER and either an EA (10 CFR 5130) if there is a finding of no significant impact, or an EIS (10 CFR 50.31) if the review indicates that the licensed activity would have a significant impact on the health and safety of the public or on the environment. The detailed review should evaluate the environmental, economic, and technical evidence provided by the applicant to support the ability of the proposed facility to meet applicable regulatory requirements.

Ibe Standard Review Plan The SRP is written so as to cover a variety of site conditions and facility designs. Each section provides the complete procedure and acceptance criteria for all of the areas of review pertinent to that section. For any given application, the staff reviewer may select and emphasize particular aspects of each SRP section as appropriate for the application. Because of this, the staff may not carry out in detail all of the review steps listed in each SRP section in the review of every application.

1. Areas of Review This subsection describes the scope of the review (i.e., what is being reviewed). It contains a brief description of the specific technical information and analyseu m the application that must be reviewed by each technical reviewer.

II. Review Procedures This subsection discusses the appropriate review technique, it is generally a step-by-step procedure that the reviewer uses to determine whether the acceptance criteria have been met.

l 111. Acceptance Criteria I

This subsection delineates criteria that can be applied by the reviewer to determine the acceptability of the applicant compliance demonstration. The technical bases for these criteria have been derived from xvii NUREG-1569

10 CFR Parts 40 and 20, NRC regulatory guides, general design criteria, codes and standards, branch technical positions, standard testing methods (e.g,, American Society for Testing and Matenals (ASTM) standards], technical papers, and other similar sources. These sources typically include solutions and approaches previeusly determined to be acceptable by the staff for making compliance determinations for the 1,pecific area of review. These acceptance criteria have been defined so that staff reviewer

  • can use consistent and well documented approaches for review of all applications. Applicants rnay take a; 9 aches to demonstrating compliance that are different from the acceptance criteria in this SRP. However, applicants should recognize that, as is the case for regulatory guides, substantial staff time and effort have gone into the development of these procedures and criteria, and a corresponding amount of time and effort may be required to review and accept new or different solutions and approaches. Thus, applicants proposing solutions and approaches to safety problenv or safety-related design areas other than those described in this SRP may experience longer review tims and NRC requests for more extensive supporting information, The staff is willing to consider proposals for other solutions and approaches on a generic basis, apart from a specific application, to avoid the impact of the additional review time for individual cases.

IV. Evaluation Findings This subsection presents general conchsions and findings of the staff that result from review of each area of the apphcation as well as an identification of the applicable regulatory requirements. Conclusions and findings for a specific application and review area are dependent on the site and type oflicensing action being considered. For each SRP section, a conclusion is included in the SER or the EA/EIS in which results of the review are published. These documents contain a description of the review; the basis for the staff findings, including aspects of the review selected or emphasized; where the facility d sign or the applicant programs deviate from the criteria stated in the SRP; and the evaluation findings.

V. References This subsection lists any applicable references.

SRP UndaLu The SRP will be revised and updated periodically as the need arises to clarify the content or correct errors and to incorporate modifications app oved by NRC management. A revision number and publication date are printed at a lower corner of each page of the SRP. Since individual sections wil! be revised as needed, the revision numbers and dates may not be the same for all sections. Corresponding changes to the SFCG (Nuclear Regulatory Commission,1982) will be made as required.

REFERENCES:

Nuclear Regulatory Commission.1982. Standard Format and Content of License Applications, including Environmental Reports, for in Situ Uranium Solution Mining (SFCG). Regulatory Guide 3.46.

Washington, DC: Nuclear Regulatory Comruissmn, Office of S:andards Development.

NUREG-1569 xy jj l

1.0 -PROPOSED ACTIVITIES 1.1 AREAS OF REVIEW The reviewer will examine the summary of the proposed activities for which a license is requested to gain a basic understanding of those proposed activities and their potential for causing a safety or environmental impact. The staff should revieiv the corporate entities invohed; the location of the proposed activities; land ownership; ote-body locations and estimated U3 0, content; proposed solution mining method and recovery processes; operating plans, design throughput and anticipated annual U3 0, production; estimated schedules for construction, startup, and duration of operations, plans for project waste management and disposal; source and byproduct material transportation plans; plans for ,

groundwater quality restoration, decommissioning, and land reclama; ion; and surety arrangements covering eventual facility decommissioning, groundwater quality restoration, and site reclamation.

Applications for licenses authorizing commercial scale operations should appropriately rely or results from research and development (R&D) operations or other operational experience as a basis for the proposed processes, operating plans (including plans for groundwater quality restoration), and assessment of potential environmental impact.

1.2 REVIEW PROCEDURES The' reviewer should determine whether the application provides a sufficiently comprehensive summary of the nature of the facilities, equipment, and procedures to be used in the propos-d in situ leach (ISL) activity.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

1.3 ACCEI"I'ANCE CRITERIA The proposed activities are acceptable if they meet the following criteria:

(1) The application suinmary of proposed activities includes descriptions of the following items that are sufficient to provide a basic understanding of the proposed activities and their potential health, safety, and environmental impact. The content of the introduction is outlined in the Standard Format and Content of License Applications, including Environmental Reports, for l's Situ Uranium Solution Mining (SFCG), Regulatory Guide 3.46 (Nuclear Regulatory Conunission,1982).

(a) Corporate entities involved (b) The location of the proposed facilities (c) Land ownership (d) Ore-body locations and estimated U3 0, content 11 NUREG-1569 l

Proposed Activities (c) Proposed solution mining method and recovery process (f) Opersting plans, design througtput, and annual U3 0, production (g) Estimated schedules for construction, startup, and duration of operations (h) Plans for project waste management and disposal (1) Plans for groundwater quality restoration, decommissioning, and land reclamation (J) Surety arrangements covering eventual facility decommissioning, groundwater quality restoration, and site reclamation (k) For license renewals; a summary of proposed changes, a record of amendments since the last license issuance, and documentation of inspection results (2) Applications for commercial-scale operations include results from R&D operations or previous operating expericace as a basis for the proposed processes, operating plans, groundwater quality restoration, and assessment of potential environmental impact.

1.4 EVALUATION FINDINGS If the staff's review, as described in this section, results in the accepta. :e of the summary of the proposed activities, the following conclusions may be presented in the technical evaluation report (TER).

The Nuclear Regulatory Conunission (NRC) has completed its review of the summary of the proposed activities at the ISL facility. This review included an evaluation of the methods that will be used to evaluate the proposed activities using the review procedures in SRP section 1.2 and the acceptance criteria outlined in SRP section 1.3.

l The applicant has acceptably described the proposed activities at the ISL l facility including (i) corporate entities involved; (ii) location of the facility; (iii) land ownership; l

(iv) ore-body locations and estimated U2 0, content; (v) proposed solution mining method and recovery l process; (vi) operating plans, design throughput, and annual U2 0, production; (vii) senedules for construction, startup, and duration of operations; (viii) waste management and disposal plans; and (ix) surety arrangements covering facility decommissioning, groundwater quality restoration, and site reclamation. For license renewals, the applicant has provided a summary of proposed changes, a record of amendments since the last license issuance, and documentation of inspection results. Applicants for commercial-scale operations have included results frem R&D operations or previous operating experience.

Based on the information provided in the application and the detailed review conducted of the sununary of the proposed activities at the ,_ ISL facility, the NRC staff has concluded that the summary of the proposed activities is acceptable and is in compliance with 10 CFR 40.32, which describes the general requirements fr . issuance of a specific license.

NUREG-1569 l-2

5 Proposed Activities

1.5 REFERENCES

Nuclear Regulatory Commission.1982. Standard Format and Conteri of License Applications._ Including Environmental Reports, for In Situ Uranium Solution Mining (SFCG) Regulatory Guide 3.46.-

- Washington, DC: Nuclear Regulatory Cummission, Office of Jtandards Development.

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- 13 NUREG-1569 -

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2.0 SITE CHARACTERIZATION  :

2.1 STYE LOCATION AND LAYOUT- .

2.1.1- Anss 07 Review The staff should review geographic maps, topographic maps, and drawings that ' identify the site and its location relative to federal, state, county, and other political sut. divisions. These should include maps provided to show the location and layout of the proposed facilities, well fields, and all principal stmetures such as waste ponds, evaporation ponds, deep injection wells, recovery plant buildings, . 3

- exclusion area boundanes and fences, applicant property and leases, ar.d adjacent properties.

The regional location and site layout for the proposed ISL operations should be reviewed using maps that show the relationship of the site to local water bodies (lakes and streams), geographic features (highlands, forests), geologic features (faults, folds, outcrops), transportation links (roads, rails, airports,

- waterways), political subdivisions (counties, townships) and nonapplicant property (farms, settlements).

A contour map sf the site showing a plan layout of constructions, significant topographic variations of the site environs, and drainage gradients should be evaluated.

2.1.2- Review Procedures The reviewer should establish the validity and completeness of the basic data in order to determine that the site location and layout proposed in the application are complete ed accurate, and the site information is sufficient to evalue.te the location of the proposed facilities relathe to key features and activities. For new applications, the staff should conduct a site visit of the facility, afler becoming famiMar with the submitted materials, in order to develop an acceptable familiarization for the review and to verit) the general aspects of the submitted materials.

The staff should examine maps and drawings provided in the application and associated environmental reports to deiermine whether they provide sufficient detail to lecate the site regionally relative to local political subdivisions and natural features and that the maps allow the staff to determine the proposed layout within the existing topography at the site. On a regional scale, the reviewer should examine the location of the facility and al! federal, state, county, and local political subdivisions that have a bearing on estimating the environmental impact of the proposed operations. The staff should verify that the total acreage that is owned or leased by the applicant and the portion of that real estate or any adjacent properties likely to be affected by s ite actisities have been identified. The reviewer should examine a contour map to determine that the contour intervals had information included on the map are sufficient to show any significant variations in site environs and important drainage gradients. The stafT should also determine that the relationship between the site and surface drainage is readily apparent from the provided F maps. Likewise, it should be possible to ascertain the likely areas of and effects of site activities on local flora and fauna frora the location maps. Staff should detennine that the scale and clarity of the maps are adequate to conduct the necessary environmental and safety reviews. )

- For neense renewals and amendment applications, appendix A to this standard review plan (SRP) pmvides guidance for examinin'g facility operations and the approach that should be used in evaluating amendments and renewal applications. ,

i e

2-1 NUREG-1569

Site Characterization 2.1.3 Acceptance Criteria The characterization of the site location and layout is acceptable ifit meets the following criteria:

(1) Maps are provided that show geologic features, well Gelds, and all planned principal structures such as waste ponds, evaporation ponds, monitoring wells, deep injection wells, and recovery plant buildings.

(2) Maps are provided that show exclusion area boundaries and fences.

(3) Maps are provided that show the applicant property and leases and adjacent properties, including water bodies, forests, and farms and all federal, state, county, and local political subdivisions.

(4) Maps are provided that show nearby population centers and transportation links such as railroads, highways, and watenvays.

(5) A topographic map is provided with elevation comours that show the locations of drainage basins and variations in the drainage gradient in the vicinity of the proposed ISL facility.

(6) The proposed ISL facility is clearly labeled at a scale appropriate to the area being covered (regional and local) and with sufGeient clanty and detail tn allow identificetion and evaluation of the proposed ISL facility. Maps are at an appropriate scale and are clear and readable.

(7) Data sources are documented in reports such as U.S. Geologic Survey (USGS) open files or existing published maps, if data has been generated by the applicant,

. the data documentation should include a description of the investigation and data reduction techniques, j (8) Maps include designation of scale, orientation (e.g., North arrow), and geographic coordinates, in addition to maps, the applicant may provide tabular locations of facilities using univcsal transverse Mercator (UTM) coordinates with appropriate Northing and Easting in meters.

2.1.4 Evaluation Fiatlings if the staft's review as described in this section results in the acceptance of the description of the site location and layout, the following conclusions may be presented in the TER:

The NRC has completed its review of the site characterization information concerned with site location and layou* at the ISL facility. This review included an evaluation using the review procedures in SRP section 2.1.2 and the acceptance criteria outlined in SRP section 2.1.3.

NUREG-1569 22

[

Site Characterization The licensee has acceptably described the site location and layout with appropriately scaled and -

labeled maps showing site layout; regional location; geology; boundaries; exclusion areas, and ibnces; applicant's propeny including leases and adjacent properties; nearby population centers and transportation links; and topography. References are cited acceptably. Any maps previously submitted (e.g maps from -

the original application in the case of renewals) are legible and actual or proposed changes are highlighted.

Based on the informatior provided in the application, and the detailed review conducted of the >

characterization of site location and layout for the ISL facility, the NRC stafT has concluded that the information is acceptable and is in compliance with 10 CFR 51.45 requiring a description of the affected environment containing sulTicient data to aid the Commission in its conduct of an independent analysis.

2.1.5 References None.

- 2.2 USES OF ADJACENT LANDS AND WATERS 2.2.1 Areas of Review The staff shall review descriptions of the nature and extent of present and projected land use (e.g., agriculture, sanctuaries, hunting, mining, grazing, industry, recreation, roads), any recent trends or changes in population or industrial patterns, and any other nuclear fuel cycle facilities located or proposed within an 80 km (50 mi) radius of the site.

The stalT shall also review tables showing, for each of the 22 %-degree sectors centered on each of the 16 compass points (i.e., north, north-northeast, etc.), the distances [to a distance of 3.3 km (2 mi)]

from the center of the site to the nearest resident and to the nearest site boundary.

The staff review shall include the location, nature, and amounts of present and projected surface and groundwater use (e.g., water supplies, irrigation, reservoirs, recreation, and transponation) within 3.3 km (2 mi) of the site boundary [0.8 km t 0.5 mi) for R&D operations] and the p.esent and projected population associated with each use point.

For license renewals and amendment applications appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

2.2.2 Review Procedures The reviewer should detennine whether the application provides sufficient information on the use of the lands and waters within a 3.3 km (2 mi) distance from the site boundary surrounding the proposed facilities {0.8 km (0.5 mi) for R&D operations) to assess the potential impacts ofISL operations on adjacent properties.

1-23 NUREG-1569 r

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Site Charreterization The staff should determine that the application _ contains the location of residence and groundwater supply wells as well as surface water reser"oirs and the estimated use of water in the lands surrounding the site of the proposed facility. Data sources should be referenced. This information should be evaluated to detennine whether it is suf6c.ent to delineate the likely impact (s) of the facility, under both normal operating conditions and accidents, on the groundwater, surface water, and population (both human and animal) near the site. The reviewer should determine that within 3.3 km (2 mi) from the site boundary, the nature and extent of present and projected water and land use and any other trends or changes in population or industrial patterns have been reponed. Any other nuclear fuel cycle facilities located or proposed within an 80 km (50 mi) radius of the site should be identined.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides gaidance for examining facility operations and the approach that should be used in evaluating amendments and rcnewal applications.

2.2.3 Acceptance Criteria The characterization of the uses of adjacent lands and waters is acceptabic if it meets the following criteria:

(1) Information is presented in detail sufTicient for understanding the surrounding land and water uses, such that the risks imposed by ISL operations can be adequately assessed.

Although the speci6c requirements may vary from site to site, the general purpose for detennining land and water use patterns is to provide supporting data for exposure calculations, cost benent analyses, and determinations of air emissions (e.g., dust). The NRC has historically found that a 3.3 km (2 mi) distance from the site boundary is an acceptable ares for which land and water use data should be collected. One acceptable method for presenting this data is for the applicant to provide the information requested in the SFCG (Nuclear Regulatory Commission,1982), section 2.2. The information presented should include (a) Maps slswing the locations of nearest residences, groundwater supply wells, and abandoned wells.

(b) Types of present and projected water use (e.g., municipal, domestic, agriculture, livestock), and descriptions of the methodology and sources used to develop projections.

(c) Present and projected water use estimates by type for both groundwater and surface water, including present and projected withdrawal, and descriptions of the methodology and sources used to develop projections.

(d) For groundwater wells: w ell depth, groundwater elevations, flow rates, drawdown, and a description of the producing aquifer (s).

NUREG 1569 2-1

Site Characterization (e) The locations of abandoned wells and drill holes, including the depth, type of use, condition of closing, plugging procedure used, and date of completion for each well or drill hole within the site area and within 0.4 km (.25 mi) of the well Geld boundary.

(f) Descriptions of the nature and extent of projected land use (e.g., agriculture, recreation, industry, and grazing) and descriptions of the methodology and sources used to develop projections.

(g) For commercial facilities, the location of any other nuclear fuel cycle facilities located or proposed within an 80 km (50 mi) radius of the site.

(2) For each of the 22 %-degree sectors centered on the 16 cardinal compass points, the information identified in section 2.2.3 of the SFCG (Nuclear Regulatory Commission, 1982) concerning human residences, nearest site boundary (ies) to residences, surface and groundwater use, and projected water use is provided. As described in section 2.2 of the SFCG (Nuclear Regulatory Commission,1982), appropriate presentation of the data should include mapped data as appropriate, and a tabular summary fo: each of the 22 %-degree sectors centered on the 16 cardinal compass points, and for each the distance from the center of the site to the site boundary and the nearest residence.

(3) Data sources are documented in reports such as USGS open files or existing published reports or maps. If data has been generated by the applicant, the data documentrtion should include a description of the investigations and data reduction techniques.

(4) Maps ir.clude design:. tion of scale, orientation (e.g., North arrow), and geographic coordinates.

2.2.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the described uses of adjacent lands and waters, the following conclusions may be presented in the TER:

The NRC has completed w. review of the site characterization information concerned with uses of adjacent lands and waters near the _ ISL facility. This review included an evaluation using the review procedures in SRP section 2.2.2 and acceptance criteria outlined in SRP section 2.2.3.

The applicant has acceptably described the present and projected land use including residential, commercial, agricultural, industrial, flora and fauna sanctuaries, arboreal, grazing, recreation (e.g., hunti. j, swimming, skiing), and infrastructure. Appropriate information on the location and extent of each use has been pmvided. In particular, the description and associated tabulated data of the location, nature, amounts and population associated with each use point of present and projected (life of the facility) surface and groundwater use adjacent to the site including water supplies, ir gation, reservoirs, recreation, and transportation within at least 3.3 km (2 mi) of the site boundary [0.o km (0.5 mi) for R&D operations]

is acceptable for determination of likely impacts of the proposed ISL facility. Tabulated data on present 2-5 NUREG-1569

- ~ - . - . . -- -- - ..

Site Characterization and projected water withdrawal rates, return rates, types of water use (e.g., municipal, dom tic, agricuhure, and livestock), source, water use estimates, and abandoned well locations is acceptable. The applicant has identiPed and located (or has noted the absence of) other nuclear fuel cycle facilities located or proposed within an 80 km (50 mi) radius of the site.

Based on the information provided in the application, and the detailed review conducted of the characterization of uses of adjacent lands ai.J waters for the ISL facility, the NRC staff has concluded that the information is acceptable and is in compliance with 10 CFR 51.45 requiring a description of the affected environment containing sufficient data to aid the Commission in its conduct of an independent analysis.

2.2.5 References ,

Nuclear Regulatory Commission 192. Standard Format and Content of License Applications, including Environmental Reports, for in Situ Uranium Solution Mining (SFCG) Regulatory Guide J../6, Washington, DC: Nuclear Regulatory Commission, Office of Standards Development, 2.3 POPULATION DISTRIBUTION 2.3.1 Areas of Review The stafr hall s review population data based on the most recent census, including maps that identify places of significant population grouping such as cities and towns within an 80 km (50 mi) radius

[3.2 km (2 mi) for R&D operations] from the approximate center of projected activities in the format specified in the SFCG (Nuclear Regulatory Commission,1982). The stafT shall review the basis for popuiation projections, in addition, for commercial-scale operations, the staff shall review descriptive material giving significant population and visitor statistics of neighboring schools, plants, hospitals, sports facilities, residential ceas, parks, etc., within 3.3 km (2 mi) of the ISL operations. The review shall include appropriate available food production data in kglyr for vegetables (by type and totals), meat (all types),

and milk and any available future predictions for this production by local governmental, industrial, or institutional organizations within 3. km (2 mi) of the site boundary.

2.3.2 Review Procedures The reviewer shall determine that data has been tabulated and presented in pie segments as described in section 2.3 of the SFCG (Nuclear Regulatory Commission,1982). The basis fbr population projections shall be examined. Recent agricultural production data shall be evaluated for vegetables, meat, milk, and other foodstuffs, in addition to predictions for future production by government, industry, or institutions for land within 3.3 km (2 mi) of the site, it is important to ascertain that the most recent census data has been used and that the data presented will sunport subsequent exposure-dose calculations and risk assessments.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance fcr examining facility operations and the approach that should be used in evalu sting amendments and renewal applications.

NUREG-1569 26

.y , ,. , , - . . . . _ _

Site Characterization 2.3.3 Acceptance Criteria (1) The characterization of the population distribution is acceptable if it meets the fo!!owing criteria:

(a) Populatini data are provided based on generally accepted sources such as the U.S.

Census Bureau, and state and local agencies.

(b) A mup of suitable scale is provided that identifies significant populs.on centers within an 80 km radius (50 mi) [3.2 km (2 mi) for R&D operationsj from the approximate center of the projected activities.

(c) A map of suitable scale is provided centered on the proposed ISL facility marked with concentric circles at 1, 2, 3, 4, 5,10, 20, 30, 40, 50, 60, 70, and 80 km divided into 22 %-degree sectors centered on one of the 16 compass points. A table keyed to this map showing separate and cumulative population totals for each sector and annular ring is provided. The distance to the nearest residence is noted for each sector.

(d) Descriptions of significant population and visitor statistics of neighboring schools, plants, hospitals, sports flicilities, residential areas, parks, and forests within 3.3 km (2 mi) of the proposed ISL facility based on generally accepted sources such as U.S. Census Bureau, and state and local agencies are provided, with identification of data sources.

(c) Projections are included of population, visitor, and food production data over the expected life of the ISL facility (typically tens of years).

(f) Descriptions of the methodology and sources used to develop projections are provided.

(2) The food production data is acceptable if (t.) Data (kglyr) for vegetables, meat, and milk based on generally accepted sources such as U.S. Depanment of Agriculture, Farm Hureau, and state and local agriculture services are provided, with identification of data sources.

2.3.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the population distribution and food production data, the following conclusions may be presented in the TER.

1

! The NRC has completed its revii ,v of the site characterization information concerned with l population distribution and food production near the ISL facility. This review l l

27 NUREG-1569 l

i

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J Site Characterization included an evaluation using the review procedures in SRP section 2.3.2 and acceptance criteri:. outlined in SRP section 2.3.3.

The applicant has acceptably described the population distribution using population data from I generally accepted sources. A raap showing the location of signi6 cant population centers within an 80 km radius (50 mi) of the approxima.e center is provided. A table and accompanying map providing population ir, pie-shaped wedges centered on each of the 16 compass points is included. Nearest residence distances ,

are noted for each sector. The applicant has provided acceptable information on schools, industrial facilities, sports facilities, residential areas, parks and forests within 3.3 km (2 mi) of the proposed ISL facility. Any food production data (e.g vegetables, meat, milk) has been described and keyed u. a map.

Based on a description of the methodology and sources, all the data has been appropriately projected for the proposed life of the ISL facility.

Based on the information proviued in the application, and the detailed review conducted of the characterization of population distribution and food production for the ISL facility, the

- NRC staff has concluded that the information is acceptable and is in compliance with 10 CFR 51.45 requiring a description of the affected environment containing sufHeient data to aid the Commission in its conouct of an independent analysis.

2.3.5 References Nuclear Regulatory Commission.1982. Standard l'ormat and Content of License Applications, including Environmental Reports, for in Situ Uranium Solution Mining (SFCG). Regulatory Guide 3.46, Washington, DC: Nuclear Regulatory Commission, Of6ce of Standards Development.

2.4 REGIONAL IIISTORIC, ARCIIEOLOGICAL, ARCHITECTURAL, SCENIC, CULTURAL, AND NATURAL LANDMARKS 2.4.1 Areas of Review The staff will review discussions of th: historic, scenic, archeological, arch:tectural, cultural, and natural significance, if any, of the proposed site and nearby areas, with specine attention to the site and nearby areas listed in the National Registry of Natural Landmarks and properties included in or eligible for inclusion in the National Register of Ilistoric Places.

The staff will review identi6 cations of those properties includM 1 or eligibic for inclusion in the National Register of Historic Places located within the area of the propcsed project and evidence of contnet with the appropriate state historic preservation officer (SilPO), including a copy of the SHPO comments concerning the effect of the facility on historic, archeological, architectural, and cultural resources.-

Th. review will include information on whether new roads, pipelines, and utilities for the proposed activity will pass through or near any area or location of known historic, scenic, cultural, natural, archeological, or architectural signincance.

NUREG 1569 28

i Site Characterization 2.4.2 Review Procedures The staff shall detennine that the applicant has used the appropriate databases and records to identify historic, archaeologic, scenic, cultural, or natural bndmar\s that are found within the study region.

The stafT shall determine that the locations and descriptions of the features are acceptable to allow an evaluation of any potential impacts of the proposed facilities on the landmarks. Of particular interest are features included in the National Registry of Natural Landmarks and/or the National Register of ifstoric Places. Means to consider and treat such data are discussed in the SFCG (Nuclear Regulatory Commission, 1982). The reviewer should verify that data presented supports the determination of estimates oflong-term costs in terms of potential impainnent of the aesthetic or recreational values of such landmarks. It is important that the application document evidence of contact with knowledgeable sources when no landmarks are identified by the applicant within the study area. The reviewer should examine the likely impact of the presence of new roads, pipelines, or other utilities on areas and locations of known historic, scenic, cultural, natural, archaeologic, or architectural significance. The reviewer shall determine whether the applicant has provided evidence of conferring with the SilPO and that the information provided is in accordance with the National lustoric Preservation Act (NHPA), section 106.

For license renew ils and amendment appiications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and '.he approach that should be used in evaluating amendments and renewal applications.

2.4.3 Acceptance Criteria The characterization of regional historic, archeological, scenic, cultural, and natural landmarks is acceptable if it meets the following criteria:

(1) A listing of all areas included in or eligible to be included in the National Registry of Ilistoric Landmarks is provided.

(2) A listing for all of properties included in or cligible for inclusion in the National Degister of Historic Places is provided.

(3) A map is included showing all identified historic landmarks and historic places with respect to the location of facilities such as buildings, new roads, well fields, pipelines, evaporation ponds, and utilities that might aflect these acas.

(4) Discussions are incorporated of the treatment of areas of historie, archeological, architectural, scenic, cnd cultural significance that follow guidance equivalent to that provided by the National Park Service Preparation of Environrental Statements:

Guidelines for Discussion of Cultural (Ilistoric, Archeological, Architectural) Resources (National Park Service,1973). Where appropriate, tribal authorities hase been consulted for possible impact on Native American cultural resources. For a consideraticn of environmental justice, see Section 7.6.1.3, Acceptance Criterion (3) and appendix B.

29 NUREG-1569

She Characterization (5) Evidence is provided of contact with the appropriate SitPO and tribal authorities. This evidence includes a copy of the SilPO and tribal authority comments conceming the effects of the proposed facility on historic, archeological, architectural, and cultural resources.

(6) The applicant presents a memorandum of agreement between the SIIPO, tribal authorities, and other interested parties regarding their satisfaction with regard to the protection of I

historic, an;heological, architectural, and cultural resources during site construction and operations.

(7) A letter from the ShPO has been obtained that describes if there are :ny issues associated with the state or federal register or any sites eligible for inclusion in the state or federal register.

(8) A letter has been obtained from the SilPO describing archeological sites (cultural resources) that may be affected by the ISL operations.

(9) The aesthetic and scenic quality of the site is rated in accordance with the U.S.11ureau of Land Management (llLM) Visual Resource inventory and Evaluation System (U.S.

Ilurnu of Land Management,1978).

If the rating is below 19 (scale of 0 to 33), no special management is required. if the rating is 19 or abooe, tr, application provides a management plan for minimizing the impact of the proposM facility.

2.4,4 Evaltiation Finditigs if the staffs review as described in this section results in the acceptance of the characterization of the regional historic, archecdogical, architectural, scenic, cultural, and natural landmarks, the following conclusions may be presented in the TER.

The NRC has completed its review of the site characteriration information concerned with regional hhtoric, archeological, architectural, s:enic, cultural, and natural landmarks near the ISL facility. This review included an evaluation using the review procedures in SRP

_,section 2.4.2 and acceptance criteria outlined in SRP section 2.4.3.

The licensee has acceptably described the regional historic, archeological, architectural, scenic, cultural, and natural landmarks. A listing of all nearby areas and propenies included or eligible for inclusion in the National Registrv of Ilistory 1.andmarks is provided. A map showing all historic landmarks and places with respect to ISL facilities is ;ncluded. ,. record of the investigation of places and properties with historic, archeological, architectural, scenic, cultural, and natural landmark significance which follows guidance equivalent to that of the National Park Service is provided. Contact with local tribal authorities is acceptably documented. A letter from the state registrar of historic properties attesting l to the properties that might be affected by the ISL facilities is included. The applicant has acceptably demotetrated that the SitPO and tribal authorities agree with the planned protection from or determination NUREG 1569 2-10

- _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _J

Site Characteritation of lack of conflict with ISL facil; ties and actis ities and with any places of importance to the state, federal, or tribal authorities. 'ihe applicant has acceptably rated the aesthetic and scenic quality of the site in accordance with the llLM Visual Resourte Insentory and thaluation Sptem.

Ilased on the infonnation provided in the application, and the detailed resicw conducted of the .

characteritation of regional historic, archeological, architectural, scenic, cultural, and natural landmarks l near the ISL facility, the NRC stalT has concluded that the infonnation is acceptable and is in compliance with 10 CI'R 51.45 requiring a description of the affec:ed environment containing suflicient data to aid the Commission in its conduct of an independent analpis.

2.4.5 Referenices National Vath Service.1973. Preparation of Environmental Statements: Guidelines for Dhcuuion of Cultural (Hotoric, Archeological, Architectural) Resource.t Washington, DC: National Park Service.

Nuclear Regulatory Commission.1982. Standard 17ormat and Content of License Applications, including Environmental Reports, for in Situ Uranium Solution Mining (Si CG). Regulatorr Guide M6.

Washington, DC: Nuclear Regulatory Conmission, Office of St ndards Development.

U.S. Ilureau of Land Management.1978. Upland Visual Rc30urce /nrentorr and Evaluation llLM Manual Section 8411. Washington, DC: U.S. Department of the Interior.

2.5 METEOROLOGY 2.5.1 Areas of Review The stafT shall review descriptior.s of the atmospherie difTusion characteristics of the site and its surrounding arca based on data collected onsite or at nearby meteorological statior.s. The data to be reviewed include (1) National Weather Service (NWS) station data including locations of all NWS stations within an 80 km (50 mi) radius; and available joint frequency distribution data by wind direction, wind speed, stability class, period of record, and height of data measurement.

, (2) Onsite meteorological data including locations and heights of instrumentation, descriptions of instrumentation, and joint frequency distribution data.

(3) Miscellaneous data including annual aserage mixing layer heights, a description of the regional climatology, and total precipitation and evaporation by month.

The stalT shall also review a discussion of the general climatology including esisting lesels of air pollution, the relationship of the regional meteorological data to the local ds.ta, the meteorological impact of the local terrain and large lakes and other bodies of water, and the occurn nee of ses ere weather in the arn and its effects. This review shall also include data on aserages of temperature and humidity.

2 11 NUREG-1569

Site Characteritation 2.5.2 Review Procedures lhe staff shall detennine whether the application includes suf0cient local and regional scale meteorological information to support estimates of the potential for airbome radionuclide transport frorn the proposed ISL facility to the surrounding area and for determination of airbeme pathway inputs to risk assessment models. This information may include NWS data and onsite monitoring data, or data from local meteorological stations, and any maps or tables that describe meteorological con <litions at the site and surrounding area. Section 2.5 of the SFCG (Nuclear Regulatory Commission,1982) contains a list of acceptable meteorological data requirements.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evalualmg arnendments and renewal applications.

2.5.3 Acceptance Criteria The characteriiation of th( site meteorology is acceptable if it meets the following criteria:

(1) A description of the general climate of the region and local meteorological conditions is provided based on appropriate data from NWS, military, or other stations recogniicd as standard installations.

These data include precipitation; evaporation; and joint frequency distribution data by wind direction, wind speed, stability class, period of record, and height of data measurement. The average inversion height shall also be identi0ed. Data shall also be provided an diumal and monthly aserages of temperature and humidity. The locations of all stations used in the data analysis and the height of the data measurement shall be included. Data periods should be denned by month and year and cover a suf0cient time period to constrain long term trends and support atmospheric dispersion modeling.

(2) Data from local meteorological weather stations supplemented by data from an onsite monitoring program are provided.

The onsite program should be designed in accordance with Regulatory Guide 1.23, Onsite Meteorological Programs (Nuclear Regulatory Commission,1972), and Regulatory l

Guide 3.63. Onsite Meteorological Measurement Program for Uranium Recovery Facilities . Data Acquisition and Reporting (Nuclear Regulatory Commission,1988).

l (3) Consideration of relationships between regional weather patterns and local meteorological conditions based on weather station data and the onsite monitoring program is included.

The im; 7ts of tenain and nearby bodies of water on local meteorology are assessed,and the occurrence of locally ses ere weather is described and its impact considered.

NUREG-1569 2.l2

Site Characterization Infonnation on anticipated air quality impacts from nonradiological sources, such as vehicle emissions and dust from well field activities, is provided for assessing cumulative impacts.

(4) The meteorological data used for assessing impacts are substantiated as being representatise of expected long term conditions at and near the 3 te. 8 (5) The application contains a description of existing levels of air polluthn.

Infonnation on potential for air pollution is based on U.S. Environmental Protection Agency (EPA) studies. AfTected counties within 80 km (50 mi) of the facility are classified according to the National Ambient Air Quality Standards (NA AQS) as being in attainment (below NAAQS) or nonattainment (above NAAQS) status.

(6) A mini.num of one full year ofjoint frequency data presented with ajoint data recovery of 90 percent or more is provided.

(7) The sources of all meteorological and air quality data are documented in open file reports or other published documents. If data has been generated by the applicant the data documentation should include a description of the insestigations and data reduction techriques.

2.5.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the meteorology, the following conclusions may be presented in the TER:

The NP.C has completed its review of the site characterization infonnation concerned with meteorology at the ist. facility. This review included an evaluation using the review procedures in SRP section 2.5.2 and acceptance criteria outlined in SRP section 2.5.3.

The liccusee has acceptably described the site meteorology by providing NWS station data located within 80 km (50 mi) of the site including available joint frequency distribution data on (i) wind direction and speed. (ii) stability class, (iii) period of record, (iv) height of data measurement, and (v) average inversion height. The data covers a sullicient time period to constrain long tenu trends and support atmospheric dispersion modeling. The applicant has provided acceptable onsite meteorological data including (i) descriptions of instiuments,(ii) locations and heights of instruments, and (iii) joint frequency distributions of data. The joint-frequency data presented is for a minimum of I yr with a joint data recovery of 90 percent or more. Additional data on (i) annual average mixing layer heights, (ii) a description of the regional climate, and (iii) total precipitation and evaporation by month hase been provided. The applicant has noted any effect of nearby water bodies or terrain on meteorologie measurements. The applicant has acceptably demonstrated that meteorologic data used for assessing environmental impacts are representative of long-term meteorologic conditions at the site. The applicant's report on the existing lesels of air pollution at the site and nearby is acceptable.

2 13 NUREG-1569

Site Characterization Ilased on the infonnation provided in the application, and the detailed resiew conducted of the characteritation of meteorology at the ISL facility, ti.e NRC staff has concluded that the infonnation is acceptable to allow evaluation of the spread of airbome contamination at the site and desclopment of conceptual and numerical models, and is in compliance with I' Cl R 51.45 requiring a description of the afTected environment containing sufficient data to aid the Commission in its conduct of an independent analysis.

2.5.5 References Nuclear Regulatory Commission.1972. Onsite Meteorological Programs (Safety Guide 23). Rcradatory Guk/c l.23. Washington, DC: Nuclear Regulatory Commission, Ollice of Standards Development.

Nucitar Regulatory Commission.1982. Standard 170nnat and Contert of License Applications, including linvironmental Reports, for in Situ Uranium Solution Mining (SI'CG), June. Rcgsdato>y Guh/c3.46. Washington, DC: Nuclear Regulatory Commission, Ollice of Standards Development.

Nuclear Regulatory Commission.1988. Onsite Meteorological Measurement Program for Uranium Recovery l'acilities Data Acquisition and Reporting. Regulatory Guhle J 63. Washington, DC:

Nuclear Regulatory Commission, Office of Standards Development.

2.6 GEOi,0GY AND SEISh! OLOGY 2.6.1 Aren of Review The reviewer shall examine information on the geologic aspects of the site acquired through standard geologic analyses, including a survey of pertinent literature and field insestigations. This infonnation shall include regional seismicity and scismic history, local stratigraphy, petrology or lithology of rock units, tectonic features (faulting, folding, fracturing), and the continuity of the geologic strata at the site and in nearby regions.

Geologic, structural, and stratigraphic maps and cross sections including representative core and geophysical well log data of the site and its environs shall be resiewed. An isopach map of the intended zone ofinjection or production and arociated confining beds shall be evaluated. All conclusions regarding the lateral continuity and vertical thickness of the ore tone (s), surrounding lithologic units, and confining rones as based on lithologic logs from core and drill cuttings, geophysical data, remote sensing measmements, and the results of other appropriate insestigations shall be reviewed.

. The staff shall review the infonnation presented on any economically imponant minerals and energy related deposits in addition to the uranium ore, including the potential impact of production of such related deposits on the ISL facility.

Data on the peochemistry of the ore tone and the geologic tones immediately surrounding the ore tone that will or could be affected by injected lisisiant shall be evaluated. Infonnation on unique NURiiG 1569 2 14 i

l Site Characterization d rm 'its (including those that might be afi sted by fluid movement associated with the proposed project, s ,.. bentonite) or paleontologic deposits of particular scientific interest shall also be reviewed. 'Ite st.!!shall examine descriptions of any efTects that planned operations at the site might have on the future

/

3 availability of other mineral resources

& 2.6.2 Review Procedures The stafT shall review the application to determine whether a thorough evaluation of the geologic setting for the proposed ISI, activity has been presented along with the basic data supporting all conclusions. In addition to a description of the basic geology, both at the surface and at the depths of interest, the establishment of the continuity of the geologic strata at the site shall be reviewed for applicability, correctness, inclusivity, and likely ability of the aforementioned strata to isolate mining fluids. The reviewer shall focus particular attention on fractures or faults, permeable stratigrarhic units, and lateral facies changes that might preclude the applicant identified geologic barriers to fluid migration from perfonning adequately.

1hc reviewer shall detennine that the application contains viable geologic maps, isopach maps of the ore-bearing strata and of the confining layers, geologic cross sections at places critical to a thorough understanding of the selected site, representative supportive core samples and geophysical and lithologic logs, and other data required for a thorough understanding of the pertinent geology at the site and its environs. The reviewer shall determine that regional stratigraphic and geologic infonnation is discussed in sufficient detail to give clear perspective and orientation to the site specific material presented. The discussion of regional geology and stratigraphy should be assessed to determine if it is adequately referenced and is illustrated by regional surface and subsurface geologic maps, stratigraphic columns, and cross sections.

The staff may also perform an independent analysis of the data provided to assess whether reasonable and conservative alternative interpretations are indicated.

l'or license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

2.6.3 Acceptance Criteria The characterirations of the site geology and seismology are acceptable if they meet the follcwing criteria:

(1) The application includes a description of the local and regional stratigraphy based ca techniques such as (a) Surface sampling and descriptions (b) Cuttings and core logging reports 2 15 NUREG-1569

t Site Characteriration (c) Wircline geophysical logs, such as electrical resistivity, neutron density, and ganuna (d) Geologic interpretations of rurface geology and balanced cross sections These interpretations may be based either on original work submitted by the applicant, or on an appropriate evaluation of previous work in the region performed by state or federal agencies (e.g., USGS, U.S. Bureau of Land Reclamation, U.S. Dureau of Mines), universities, mining companies, or oil and gas exploration companies. The interpretations should be accompanied by (i) Maps such as geologic, topographic, and isopach maps that show surface and subsurface geology and locations for all wells used in defining the stratigraphy (ii) Cross sections through the ore deposit roughly perpendicular and parallel to the principal ore trend (iii) Fence diagrams showing stratigraphic correlations between wells (2) All maps and cmss sections are at sufficient scale and resolution to clearly show the intended geologic information. Maps show ;he locations of all site explorations such as borings, trenches, seismic lines, piezometer readings, and geologic cross sections.

(3) in the local stratigraphic section, all ore horizons, confining units, and other important units such as drinking water aquifers and deep well injection zones are clearly shown with their depths from the surface clearly indicated. Isopach maps are prepared showing the variations in thickness of the minerallied rone and the confining units over the proposed mining area.

(4) A geologic and geochemical description of the ore zone and the geologic units immediately surrounding the ore zone is provided.

(5) An inventory of economically significant mineral and energy related deposits in addition to the uranium ore is provided. Locations of all known wells, surface and underground mine workings, and surface impoundments that may have an effect on the proposed operations are provided.

These items should be located on a map of sufficient scale and clarity to identify their relationship to the proposed facility. For existing wells, the depth should be shown, if possible. To allow evaluation of connections between the ore zone and underground sources of drinking water, plugging and abandonment records provided from state, federal, and local records, as appropriate, should be provided. The applicant should provide evidence that action has been undertaken to properly plug and abandon all wells that cannot be documented in this manner.

NUREG-1569 2 16

1 Site Characterization (6) A description of the local and regional geologic structure, including folds and faults is provided.

Folds and faults can be shown on the geologic maps used to describe the stratigraphy.

Major and minor faults traversing the proposed site should be evaluated for potential future effects of faulting on the uranium production activities and on the ability of the strata to contain lidviant should fault motion occur. Geologic .tructures that are preferential pathways or barriers to fluid flow must be described and the basis for likely ellects on flow given.

(7) A discussion of the seismicity and the seismic history of the region is included.

llistorical seismicity based on data from universities and state and local agencies should be summarized on a regional carthquake epicenter map, including magnitude, location, and date of all known seismic events. Where possible, seismic events should be associated with the tectonic features described in the geologic structures.

(8) A generallied stratigraphic column including the thicknesses of rock units, representation of lithologies, and ore horizon definition is presented.

(9) The sources of all geological and seismological data are documented in USGS open files or other published documents. If data has been generated by the applicant, the documentation should include a description of the investigations and data reduction techniques.

(10) Maps have designation of scale, orientation (e.g., Nonh arrow), and geographic coordinates.

(11) Short-tenn seismic stability has been demonstrated for the ISL facility in accordance with Regulatory Guide 3.11 Design, Construction, and inspection of Embankment Retention Systems for Uranium Mills (Nuclear Regulatory Co nmission,1977).

(12) A general description of the site soils and their propenies has been provided to support an evaluation of the environmental efTects of construction and operation on crosion.

(13) A detailed description of soils and their properties has been provided for any areas where land application of water is anticipated in order to support an assessment of the impacts.

2.6.4 Evaluation Findings if the staff s review as described in this section results in the acceptance of the characteriration of the geology and seismology, the following conclusions may be presented in the TER.

2 17 NUREG 1569

1 Site Characteriration lhe NRC has completed its review of the site characteriration information concemed with geology and seismology at the ISL facility. This resiew included an es aluation using the review procedures in SRP section 2.6.2 and acceptance criteria outlined in SRP section 2.6.3.

The licensee has acceptably de,cribed the geology and seismology by providing (i) a description of the local and regional stratigraphy; (ii) geologic, topographic, and isopach maps at acceptable scales showing surface and subsurface features and locations of all wells and site explorations used in denning stratigraphy; (iii) a geologic and geochemical description of the ore zone and the geologic units adjacent to the ore ione;(iv) an ins entory of nearby economically signi0 cant minerals and energy-related deposits; (v) a description of the local and regional geologic structure; (vi) a discussion of the scismicity and seismic history of the region;(vii) a generatired stratigraphic column that includes thickness of rock units, representation of lithologies, and ore horiron definition; and (viii) a description and map of the soils.

Based on the infmmation provided in the application, and the detailed review conducted of the characteritation of the geology and seismology at the ISL facility, the NRC staff has concluded that the information is acceptable to allow evaluation of the geologic and seismologic characteristics of the site and associated conceptual and numerical models and is in compliance with 10 Cf R 40.31(f) requiring inclusion of an ER in the application, and 10 CFR 51.45 requiring a description of the afTected environment containing sufUclent data to aid the Commission in its conduct of an indel,endent analysis.

2.6.5 References Nuclear Regulatory Commission.1977. Design, Construction, and inspection of Embankment Retention Systems fiw Uranium Mills. Regn/arory Gedde J.//. Washington, DC: Nuclear Regulatory Commission OfUce of Standards Development.

2.7 IlYDROLOGY 2.7.1 Areas of Review

~lhe review shall examine infonnation related to the effects ofISL opentions on adjaecnt surface water and groundwater including (1) The control and monitoring of subsurface process Guids (2) The quantitative physical, chemical, biological, radiological, and hydrological characteristics of the groundwater (3) Typical seasonal ranges and aserages, and the historical extremes for levels of surface water bodies and aquifers (4) Water quality data in and in close proximity to proposed well fields (5) Infonnation on past, current, and anticipated future water use NUREG 1569 2 18

Site Characteriration (6) The relationships of the site to surfaca water features in the site area (7) Flooding mechanisms that may require special design features to be implemented The staff shall review the assessment of the flooding potential, including a determination of the precipitation potential, the precipitation losses, the runoff response characteristics of the watershed, the accumulation of flood runoff through river channels and reservoirs, the magnitude of the probable maximum Good (PMF) or project design flood (if a flood less than the PMF is used) at the site, and the critical water levels, shear stresses, and velocity conditions at the site. The staff also will review (i) the analpes associated with using a Good less than the PMF;(ii) the probable maximum precipitation (PMP) potential, and resulting runoff, for site drainage and for drainage areas adjacent to the site; and (iii) the modeling of physical rainfall and runoff processes to estimate possible flood conditions at the site. For the shyt (usually less than 20 yr) operational period, the staff surgests the use of a single PMF calculated using the 6 hr PMP as an acceptable PMF.

If applicable, assessment of Gooding also may include a review of potential dam failures, if upstream reservoirs exist Peak water levels, flood routing procedures, and velocities will be reviewed in the determination of potential hazards due to failure of upstream water control structures from either seismic or hydrologic causes.

Depending on the type of computational models used, the staff shall review the model, including the determination of flooding depths, channel velocities, and/or shear stresses used to determine the crosion protection design. The staff shall review the various detailed computations for each model and shall review the acceptability of the input parameters to the model.

Design details and analyses pertinent to the following aspects of crosion protection shall be reviewed incleding (i) erosion protection against the effects of Gooding from nearby streams and (ii) erosion protection for drainage and diversion channels.

The review of the local groundwater system shall include (1) Identification of aquifers that may be affected by the proposed ISL operations I

(2) Ore zone aquifer properties including thickness, potentiometric or water table elevations, hydraulic gradients, How velocities, conductivities, transmissivities, storage coeflicients, l and porosities (3) Descriptions of confining beds or other lithologic units separating the ore zone from other aquifers (4) Estimated conductivities, thickness, and lateral extent of aquitards, and other information relative to the control and prevention of excursions (5) Soil types 2 19 NUREG 1569

Site Characterization (6) Conclusions concerning the local groundwater Oow systern based on well borings, cores, pumping tests, laboratory tests, soil suncy s, and other methods (7) Descriptions of local groundwater w cils including locations, uses, amounts used, depths, screened intenals, yield, static water levci, and water quality (8) Descriptions of project related wells including locations, elevations, depths, screened intervals, static water levels, and preopaational water quality (9) The preoperational water quality of all aquifers that might be affected by the proposed operations as weli as the changes expected in quality due to the operations (10) The relationships of the site to surface water features in the site area (11) Flooding mechanisms that may require special design features to be implemented A description of the surface water hydrology shall be reviewed including the size, shape, and hydrologic characteristics and uses of surface water bodies near the site; river control structures; topographic maps of hydrologic features; water quality analysis and now rates from USGS survey stations; site-related drainage water courses; and stream cross sections where necessary to show the vertical and horizontal relationships of channels and pond embankments.

The NRC staff shall review hydrologic information, analyses, and design details in the application to assure the plan provides acceptable erosion protection and capacity. The major areas of review in the erosion protection aspects of the design are (i) the hydrologic description, (ii) Dooding detenninations, (iii) water surface proDies, (iv) channel velocities, (v) shear stresses, and (vi) the erosion protection design, 2.7.2 Review Procedures At a minimum, the reviewer shall evaluate whether the applicant has developed an acceptable conceptual model of the r.ite hydrology, and w hether the conceptual model is adequately supported by the data presented in the site characterization. To this end, the reviewer shall (1) Select a limited number of potentiometric surface elevation measurements from data tabulations and verify that they correspond to elevations shown on maps.

(2) Compare hydrogeologic cross sections with randomly selected wells and borehole logs to serify accuracy and ensure that cross sections are based on an adequate number of wells and boreholes.

(3) Examine both groundwater and surface water baseline water quality data to verify w hether an adequate list of constituents has tren identined, that the number of samples collected is suf0cient to provide meaningful statistics, and that samples are spaced in time i sumciently to capture temporal variations, j NUREG 1569 2 20 i

1 l

Site Characterization ,

(4) Examine pump tests, analyses, and/or other measuement techniques used to determine the hydrologic propenies of the local aquifers and aquitards that affect or may be affected by the proposed ISL activities.  ;

(5). Eumine pump tests that are used to investigate venical confinement or hydraulic iso'ation between the mine tone and upper and lower aquifers.

(6) Review surface water data, including maps that identify nearby lakes, rivers, surface drainage areas, or other surface water bodies; stream flow data, and applicant assessment of the potential for surface water contamination due to ISL operations. l (7) Revicw the modeling results used for the impact analysis, and the conclusior.s drawn from those results.

The infonnation nonnally presented is not amenable to independent verincation, except through cross checks with available publications related to hydrologic characteristics of the site region and through obsersation during site visits. The review procedure consists of evaluating th; completeness of the information and data, by sequential comparison with infonnation available from references. Based on the description of the hydrosphere (e.g., geographic location and regional hydrologic features), potential site flood mechanisms are identified. The description of structures, facilities, and erosion protection designs should be sufuciently complete to allow independent evaluation of the impact of flooding and intense rainfall. Site topographic maps should be of good quality and of sufficient scale to allow independent analysis of postconstruction drainage patterns.

The stafT shall estimate the Good levels, velocities, shear stresses, and magnitudes as described below Staff estimates may be made independertly from basic data, by detailed review and checking of the application analyses, or by comparison with estimates made by others that have been reviewed in detail. The evaluation of the adequacy of the estimates is a matter of engineering judgment, and is based on the confidence in the estimate, the degree of conserwtism in each parameter used in the estimate, and the relative sensitivity of each parameter as it afTects the Dood level or flood velocity.

The evaluation of flooding is separated into two parts: (i) flooding on large adjacent streams, as applicable, and (ii) flooding on local drainage channels and protective features. For large drainage areas, PMF estimates approved by the Chief of Engineers, Corps of Engineers, and contained in published or unpublished reports of that agency, or generallied estimates may be used instead of independent staff-developed estimates. The staff shall utilire flood estimates deseloped by Crippen and Bue (1977) and by the U.S. Bureau of Reclamation (1986) to determine historic regional floods, if the historic maximum i Goods exceed the proposed PMF estimates, the staff shall perfonn a detailed evaluation to determine the l reasons for the discrepancies. The staff will compare basin lag times, rainfall distributions, soil types, and infiltration loss rates to detennine if there is a logical basis for the PMF values being less than historic Goods. Without such estimates, the stafT shall generally use Corps of Engineers runoff, impoundment, and river routing models to independently estimate PMF discharge and water levels at the site. If a computer model such as 'IEC-1 (U.S. Anny Corps of Engineers,1997a) is used, the staff shall review the adequacy of the various input parameters to the model, including but not limited to the following: drainage area, lag times and times of concentration, design rainfall, incremental rainfall amounts, temporal distribution of incremental rainfall, and runoff / infiltration relationships. When detailed independent estimates are 2 21 NUREG 1569 l

Site Characterization necessary, the applicant will be requested to provide all necessary basic data not already included in the supporting documents.

Information peninent to computation of the design flood should be submitted in sufficient detail to enable the staff to perform an independent flood estimate. Acceptance of the analysis is based on; acceptability of model input parameters; general agreement between the staff estimr,tes of Good levels and peak discharges; and the adequacy of the computational methods used for such estimates. In those cases where it is documented that erosion protection features will be damaged but no release of contaminated wastes will occur, the staff shall independently analyre the information provided in the application.

In the detailed review of flooding, the staff shall consider seural factors that are important in determining a local PMP/pMF event. These factors include (i) detennination of design rainfall event: the staff shall ccasult appropriate hydrometeorological reports and detennine that correct values of the l hr and 6 hr PMP events, as applicable, have been determined; (ii) innltration losses: the staff shall check calculations to serify that conservative values of inultration have been selected; (iii) times of concentration the staff shall verify that appropriate methods (depending on the slope, con 0guration, etc.)

has e been selected (the staff shall independently vcrify that the methods selected compare reasonably well with various selocity based methods of design); and (iv) rainfall distributions: the staff shall verify tha; the rainfall distributions (par:icularly the 2 K min,5 min, and 15 min distributions) compare well with the distributions suggested in NRC (1990).

For dam failures, the acceptability and conservatism of the application estimate of flood potential and v ater levels shall be reviewed. In general, depending on the potential for flooding, the stafT shall serify that the application dam failure analyses are either realistic or conserva'.ac by detennining locations and sires of upstream dams assuming an instantaneous failure (complete removal) of the dam embankment and computing the peak outflow rate, if this simplined analysis indicates a potential Dooding problem, the stafT shall may be repeated using more re0ned techniques, and additional infonnation and data may be requested. Detailed failure models, such as those of the Corps of Engineers and NWS are utilized to identify the outuows, failure modes, and resultant water inels at the site.

Using the guidance presented in NRC (1990), the staff shall serify that localiied flood depths, velocities, and shear stresses used in models for rock site determination (such as the Safety Factors Method or the Stephenson Method) are acceptable. For ofTsite flooding efTects, the staff shall verify that computational models such as llEC 2 (U.S. Anny Corps of Engineers,1997b), have been correctly and appropriately used and that the output from the model has been correctly interpreted. The stafT shall verify that acceptable models and input parameters have been used in the dood analyses and that the resulting flood forces has e been acceptably accommodated. Infonnation regarding acceptable models may be found in NRC (1990).

l 2.7.3 Acceptance Criteria The hydrologic characterization should establish a hydrologic .onceptual model for the ISL site and surrounding reg!on. The conceptual model will provide a framework for the applicant to make NUREG-1569 2 22 l

l

Site Characterization decisions on the optimal methods for extracting uranium from the ore zone, and how best to minimize environmental and safety concerns caused by ISL operations. Ilydrologic characterizations that accomplish this objectise are considered acceptable.

The characterization of the site hydrology is acceptable if it meets the following criteria: ,

(1) The applicant has described the local and regional aquifer hydraulic gradients.

Potentiometric surface maps are the recommended means for presenting this data. These i maps should include two levels of detail: regional and local. The regional map should represent the ore zone aquifer and should encompass any potentially affected highly populated areas. The site scale map should encompass the entire license boundary. If overlying and underlying aquifers exist, local scale potentiometric or water surface elevation maps of these aquifers should also be included. These maps should indicate the locations, depths, and screened intervals of the wells used to determine the potentiometric surface elevations. Altematively, this infonnation can be provided in separate maps and/or tables. The appropriate contour interval will vary from site to site; however, contour intervals should be sufficient to make clear the groundwater flow direction in the ore zone and in the overlying and uriderlying aquifers. The number of piezometer elevation

^

measurements t. sed in the construction of each map should be sufficient to detennine the direction of groundwater flow in the ore zone and the overlying aquifer, in order to construct a regional potentiometric map, a rersonable effort should be made to consider as many existing wells as possible.

(2) The applicant has considered hydro-stratigraphy at aa appropriate scale. Ilydrogeologic cross sections are recommended. These cross sections should be constructed fx the area within the license boundary. I'or very large or irregularly shaped mine areas, more than one cross section may be necessary. Cross sections must be based on borehole data from driller's logs collected during well installation or exploratory drilling. All significant borehole data should be included in an appendix. StafT shall verify that, where hydrogeologie units are shown to be continuous, an adequate number of boreholes is used to support this assertion.

(3) Reasonably comprehensise chemical and radiochemical analyses of wate; samples, obtained within the ore body and at locations away from the ore body, have been made to detennine preoperational baseline conditions.11aseline water quality should be determined for the ore zone and surrounding aquifers. This data should include water quality parameters that are expected to increase in concentration as a result of ISL activities and that are of concem to the water use of the aquifer (i.e., drinking water, etc.),

l'or example, ISL operations are not expected to mobilize aluminum, and ualess an ammonia based lisisiant is used, ammonia concentrations in the groundwater should not be increased as a result of ISL operations. Therefore, little is gained by sampling these parameters. Studies have rhown that thorium 230 is mobilized by bicarbonate laden leaching solutions, llowever, studies have also shown that aller restoration, thorium in the groundwater will not remain in solution because the chemistry of thorium causes it to ,

l precipitate and chemically react with the rock matrix (llem,1970). As a result of its low 2 23 NUREG 1569 I l

i Site Characterfration (

solubility in natural waters, thorium is found in only trace concentrations. Additionally, i chemical tests for thorium are expensive, and are not comrnonly included in water  !

analyses at ISL facilities.  !

The applicant should identify the list of constituents to be sampled for baseline concentrations. The list of constituents in table 2.71 has generally been accepted by the '

NRC for ISL facilities. Alternatively, applicants may propose a list of constituents that Table 2.71. Typleal baseline water quality Indleators to be determined during preoperational data collection A. Trace and Minor Elements Arsenic fron Radium 226 and 228 Ilarium Lead Selenium

!!oron Manganese Silver Cadmium Mercury Uranium Chromium Mercury Vanadium Copper Moly bdenum Zine I:luoride Nickel

11. Common Constituents Alkalinity Chloride Sodium Bicarbonate Magnesium Sulfate Calcium Nitrate Carbonate Potassium C. Physical Infleators Specific Conductivit>
  • Total Dissolved Solids #

pil'

- D. Radiologleal Parameters Gross Alphat Gross Beta l '171cid and 1.aboratory detennination.

L

  1. Laboratory only-1 Excluding radon, radium, and uranium

i j

Site Characterization is tailored to a particular loChiion. In such cases, sufScient technical bases must be provided for the selected constituent list.

For determining baseline water quality conditions, at least four sets of samples should be collected and arvlyzal for each listed constituent. Some samples should be split and sent to different laboratories as part of a quality assurance (QA) program. Sets of samples should be taken within a week or two of each other unless natural conditions are such that the water quality of the aquifers changes significantly with time,if natural groundwater How rates and recharge conditions vary considerably (the premise that they do not should .

be documented by the applicant), additional sampling to establish the natural cyclical Ductuations of the water quality is necessary. Where perennial surface water sources are present, surface water quality measurements should be taken on a seasonal basis for a minimum of 1 yr prior to implementation ofISL operations. Surface water samples can be obtained by grab sampling and should be taken at the same location each time.

The average water quality for each aquifer rene and the range of each indicator in the zone has been tabulated and evaluated. If zones of distinct water quality characteristics are identified, they ate delineated and referenced on a topographic map. For example, since uranium roll front deposits are formed at the interface between chernically oxidizing and reducing environments, water quality characteristics may differ signincantly across the roll front.

(4) The applicant should describe all hydraulic parameters used to determine expected operational and restoration performance. Aquifer and aquitard hydraulic properties may be determined using aquifer pump tests for parameters such as hydraulic conductivity, ,

transmissivity, and specific storage. Any of a number of commonly used aquifer pump tests may be used including single well drawdown and recovery tests, drawdown versus time in a single observation well, and drawdown versus distance pump tests using multiple observation wells. The methods or standards used to analyre pump test data should be described and referenced: acceptable methods of analysis include use of curve fitting techniques for draw down or recovery curves that are referenced to peer reviewed journal publications, texts, or American Society for Testing and Materials (ASTM) Standards.

Driscoll (1986) provides examples for conducting and analyzing aquifer pump test data.

It is important for the reviewer to ensure that where fitted curves deviate from measured drawdown, the applicant explains the probable cause of the deviation (e.g., leaky aquitards, delayed yield efTects, boundary efTects, etc.)

For estimates of porosity, the NRC has found it acceptable to use laboratory analysis of core samples, borehole geophysical methods, and analysis of barometric efliciency of the aquifer (e s., Lohman,1979). The applicant should distinguish between total porosity estimated from borehole geephyrical methods and effective porosity that determines transport of chemical constituents.  ;

(S) Surface water characteriration in the mining zone and surrounding areas should bc l addressed. Maps provided in the application should identify the location, size, shape, hydrologic characteristics, and uses of surface water bodies near the proposed site,

{

2 25 NUREG-1569 m- . - - , _ . .

l Site Characterization including potential surface drainage areas near the proposed facilities. An acceptable application should also identify the zones of interchange between surface water and groundwater.

l'or license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendmtnts and renewal applications.

2.7.4 Evaluation Findings if the staffs review as described in 'his section results in the acceptance of the site hydrology, the following conclusions may be presented in the TER.

The NRC has completed its review of the hydrologic site characterization infonnation for the ISL facility.1his review included an evaluation using the review procedures in SRP section 2.7.2 and acceptance criteria outlined in SRP section 2.7.3.

1he licensee has acceptably described the hydrology by providing (i) estimates of the local and regional hydraulle gradients using pctentiometric surface maps with acceptable contour intervals including the ore tone aquifer and other merlying or underlying aquifers and any potentially affected populated area, (ii) hydrologic cross-sections based on an eppropriate number of boreholes (iii) acceptable comprehensive chemical and radiochemical analyses of water amples from in and near the ore body that define the preoperational baseline w er quality conditions,(iv) all hydraulic parameters used to deterrnine expected operational and restoration perfonnance, and (v) characterization of surface water in the ISL facility and nearby areas including presentation of such infonnation on maps. Zones of interchange between surface end groundwater have been identified. The applicant has prmided acceptable erosion protection against the effects of flooding from nearby streams and for drainage and diversion channels.

liased on the information provided in ths opplication, and the detailed review conducted of the characterization of the hydrology at the ISL facility, the NRC staff has concluded that the infonnation is acceptable to allow evaluation of the site and associated conceptual and numerical models and is in compliance with 10 CFR 51.45 requiring a description of the affected environment containing suflicient data to aid the Commission in its conduct of an independent analysis.

2.7.5 References Ctipren, J.R., and C.D. ilue. I977. Matinnan Floodpows in the Conterminom United States. USGS Water Supply Paper No.1887. Denver, CO: U.S. Geological Survey.

Driscoll, F.G.1986. Groonduater and IVells,1hird Edition. St. Paul, MN: Johnson 17iltration Systems, Inc.

1Iem, J.D.1970. Study anJ interpretation ofIhe Chemical Characteristics of Natural Il'ater. USGS Water Supply Paper 1473. Denver, CO: U.S. Geological Survey.

NUREG-1569 2 26 1

Site Characterization Lohman, S.W.1979. Groundwater 1/n/raulics. USGS Professional Paper 708. Reston, VA U.S.

Geological Survey, Nuclear Regulatory Cornmission.1990. Final Staff Technical Position Design of Erosion Protection Coversfor Stabili:ation of Uranium Ahli Tuilings Sutcs. Washington, DC: Nuclear Regulatory Commission.

U.S. Army Corps of Engineers 1997a. Flood //n/rograph fackage. IIEC 1. Washington, DC: U.S. Anny Corps of Engineers, Ilydrologic Engincering Center. Continuously updated.

U.S. Army Corps of Engineers.1997a. li'ater Surface Profiles. IIEC.2. Davis, CA: llydrologic Engineering Center. Continuously updated.

U.S. Uurcau of RecIsmation,1986. Comparison ofEstimated Atatimum FloalPeaks u ith flistoric Floods.

Washington, DC: U.S. Department of the Interior.

2.8 ECOLOGY 2.8.1 Areas of Review The staff shall review descriptions of the Dora and fauna in the vicinity of the site, their habitats, and their distribution. The review should include identincation of imponant species that cre (i) commercially or recreationally valuable,(ii) threatened or endangered, (iii) afTecting the well being of some important species within criterion (i) or (ii), or (iv) critical to tl,c structure and function of the ecological system or are t biological indicator of radionuclides or chemical pollutants in the environment.

The review shall include the inventory of the majority of the terrestrial and aquatic organisms on or near the site and their relative (qualitative) abundance, the quantitatise abundance of the imponant species, and species that migrate through the area or use it for breeding grounda. The staff shall review discussionsof the relative importance of the proposed site envirans to the total regional area for the living resources (potential or exploited).

l'or commercial-scale operations and for R&D operations involving drying of yellowcake, the stafT shall examine data on the count and distribution of important domestic fauna, in particular, cattle, sheep, and other meat animals that may tw invohed in the exposure of man to radionuclides. Imponant game animals should receise similar treatment. A map showing the distribution of the principal plant communities shall be reviewed.

The staff shall also review the discussion of species-ensironment relationships including descriptions of area usage (e g., habitat, breeding) for important species; life histories ofimponant regional animals and aquatic organisms, nonnat seasoilal population Doctuations, and habitat requirements; and identineation of food chains and othei interspecies relationships, particularly when these contribute to prediction or evaluation of the impact of the facility on the regional biota. The statT shall examine any information presented on definable pre-existing emironmental stresses l'om r sources such as pollutants, as well as pertinent ecological conditions suggestise of such stresses, and the status of ecological 2 27 NUREG 1569

Site Characterization succession. As appropriate, the staff shall review a list of pertinent published material dealing with the ecology of the regien and ecological or hielogical studies of the site or its environs currently in progress or planned.

2.8.2 Review Procedttres

'ihe staff shall review the descriptions and inventory of the Dora and fauna in the vicinity of the site including hamt ats and distribution. The review shall include terrestrial and aquatic organisms on or near the site, and their relative (qualita'ive) abundance shall be established. Particular attention sbil be given to species based on their relative importance to the community. The raviewer shall determine that all important species have been identified. Important species include those (i) commercially or recreationally valuable (ii) threatened or endangered, (iii) any species that affects the well being of another important species within (1) or (ii), and (iv) organism (s) that are critial to the structure and fenction of the ecological system or area biological indicators of radionucHdes or chemical pollutants in the environment. Important species should be a part of the larger inventory of species. Ifimportant species are determined to be present, the staff shall evaluate possible detrimental effects on the organism by the proposed facility.

The reviewer shall determine that information on the various species is presented in two separate subsections: terrestrial ecology and aquatic ecology. The reviewer shall also determine that the discussion of the species-environment relationships includes descriptions of area usage (e.g. habitat, breeding) for important species; discussions of life histories of important regional animals and aquatic organisms including nonnal seasonal population fluctuations and their habitat requirements.17ood chains and other interspecies relationships should be examined particularly when these may bear upon predictions or evaluations of the impact of the proposed facility on the stability of regional biota. The reviewer should also examine documentation provided for any preexisting environmental stresses from sources such as pollutants as well as pertinent eco'ogical indicators suggestive of such stresses. A discussion of the status of ecological succession shall be evaluated.

For any operation involving the drying of yellowcake, the staff shall review data on the number and distribution oflocally significant domestic flora and fauna; in particular cattle, sheep, commercial fish, and other meat animals, and commercial crops that may be part of the food chain delivering radiation exposure to man. Important game animals shall be treated similarly. A map showing the distribution and estimates of numbers of commercially significant species shall be examined.

For license renewals and amendment applications, appendix A to this stwdard review p. ,(SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

NUREG-1569 2 28

Site Characterization 2,8.3 Acceptance Criteria

'ihe characterization of the site ecology is acceptable if it meets the following criteria:

4 (1) Inventories of tenestriai and aquatic species are compiled by the applicant based on reports or databases of state or federal 3gencies (e.g, U.S. Fish and Wildlife Service.

EPA).

llistorical sitings of important species as defined in the SFCO (Nuclear Regulatory Commission,1982) should be included in the inventory. If such reports do not exist, inventories should be prepared by the applicant based on a survey of an area surrounding the propor:d facility [80 km radiua (50 mi)). Documentation should be provided that inv(ntories were prepared in consultation with appropriate local, state, and federal

3cncies to confirm the presence or absence of important species (especially threatened or endangered species). Inventories may be based on historical data, but should be updated ta v.;ein two years of the time of application to establish current baselines.

10 !rentories of locally signifkant domestic flora and fauna; in particular cattle, sheep, commercial fish, and other meat producing animals and commercial crops are based on recent f.n:Juction figures from local, state, and federal agencies (e g., U.S. Department of Agriculture).

The statistics should cover at least 3 yr and have been conducted within 2 yr of the date of the application to establish reasonable baselines, important game animals should be treated similarly. A map shewing the distribr* ion and estimates of numbers of commercially significant species should be provided and may be combined with land use

.:.aps discussed in section 2.2 of the SRP.

(3) The important species are discussed in sufTicient detail to estimate both their current and historical abundance.

Tenninology defining endangered or threatened with endangennent can be found in Public Law 93 205, 87 Stat. 884. Any discussion should include non pennanent inhabitants migrating through the area or using it for breeding grounds. The preservation of habitat, particularly for important species, should be a prime consideration. A map of the principal floral and faunal communities has been provided.

(4) The application provides a thorough description of the species environment relationships for each important species identified within 80 km (50 mi) of the facility. If no important species are identified within 80 km of the facility, the application should plainly state so, and no additional review is necessary.

The application should take these relationships into account in providing a discussion of possible detrimental effects that operation of the site will have on the species through changes in habitat, pollution, and aspects of the operations that may place stress on th:

2 29 NUREG-1569

i l

Site Characteritation ]

species environment relationship. Finally, the application should provide information i regarding steps that will be taken to minimite the effect of operating the facility on the species environment relationship.

i (5) All sources of all ecological information are documented in open file reports or other '

published documents. If data has been generated by the applicant, the documentation should provide a description of the investigations and data reduction techniques.

I A list of pertinem published material dealing with the ecology of the region should be included. Any ecological or biological study of the site or its environs either in progress or planned should be described and referenced.

2.N.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the description of the site ecology, the following conclusions may be presented in the TER.

1hc NRC has completed its review of the site characterization information concerned with ecology at the ISL facility. This review included an evaluation using the review procedures in SRP section 2.8.2 and acceptance criteria outlined in SRP section 2.8.3.

The licensee has described the ecology by providing acceptable (i) inventories of terrestrial and aquatic species;(ii) inventories of locally significant domestic flora and fauna (e.g. cattle, sheep, goats); >

(iii) discussions of important species found within 80 k:n (50 ml) of the facility and estimations of their current and h!storical abundance; and (iv) thorough descriptions of the species environment relationships for any important species. ,

llased on the infonnation provided in the application, and the detalled review conducted of the characteriration of the ecology at the ISL facility, the NRC stalT has concluded that the infonnation is acceptable to allow evaluation of the site ecology ar'd associated conceptual and numerical models and is in compliance with 10 CI R $1.45 requiring a description of the alTected environment containing sufficient data to aid the Commission in its conduct of an independent analysis.

2.8.5 References Nuclear Regulatory Commission 1982. Standard Fonnat and Content of License Applications, including Envircnmental Reports, fer in Situ Uranium Solution Mining (SFCG). Regulatory Guide M6, Washington, IX': Nuclear Regulatory Commission, ofice of Standards Development.

4 2.9 IIACKGROUND RADIOLOGICAL CilARACTERISTICS 2.9.1 Areas of Review The reviewer shall examine site specific radiological data provided in the application including ,

the results of measurements of radioactis e materials occurring in important species, soil, air, and in surface  ;

NUREG 1569 2 30 L ._,

Site Characteritation and groundwaters that could be affected by the proposed operations. The reviewer shall examine the design of the preoperational monitoring program, including which radionuclides were analyzed, sampling locations, sample type, sampling frequency, location and density of monitoring stations and the detection limits.

2.9.2 Review Procedures The reviewer shall examine data from the preoperational monitoring program with particular attention paid to the design of the monitoring program, the radionuclides monitored, the results, and the detection limits reported for each radionuclide in each sample medium. The reviewer shall compare and contrast the preoperational monitoring program as implemented against the guidance provided in Regulatory Guide 4.14. Revision I, Radiological Efiluent and Environmental Monitoring at Uranium Mills (Nuclear Regulatory Commission,1980).

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewd applications.

2.9.3 Acceptance Criteria The characteriration of the site ba3 ground radiological characteristics is acceptable if it meets the following criteria:

(1) Monitoring programs to establish background radiological characteristics, including sampling frequency, sampling methods, and sampling location and density are established in accordance with preoperational monitoring guidance provided in Regulatory Guide 4.14, Revision 1 (Nuclear Regulatory Commission,1980). Air monitoring stations are located in a manner consistent with the principle wind directions reviewed in section 2.5 of the SRP.

(2) Soil sampling is conducted at both a 5 cm depth as described in Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980) and 15 cm for background decommissioning data.

(3) Daseline water quality is detennined for the common constituents as well as minor constituents whose concentrations are likely to change s a result of chemical reactions initiated during in siru solution removal of uranium (see Acceptance Criterion 3 in section 2.7.3 for baseline water quality data collection).

Ilecause of the diMculty of predicting efTects of mobilizativa, reprecipitation, and adsorption, comprehensive chemical and radiochemical analyses of water samples obtained within and away from the orebody should be made. Table 2,9.31 shows an acceptable format for the water quality data submitted to NRC for uranium recovery facilities.

2 31 NUREG-1569 i

Site Charactertration Table 2.9.31 Standard format for water quality data submittal to the Nuclear Regulatory Comminston for uranium recovery facilities

1. Water quality sampling techniques and analysis should be in accordance with EPA Guidelines (1 PA,1974)
2. All water quality data submitted to NRC should:
a. Ile submitted in tabular form with the appropriate standards [i.e., EPA national interim primary drinking water regulations, livestock standardt, baseline or excursion levels, or 10 CFR Part 20, Maximum Permissible Concentrations (MPCs)) listed it, the same table, for ease of data comparison. Methods of sampling and preserving, and the laboratory utillred should be indiented in the table. The sampled depths, formation (s) sampled, water lesel clwations and data measured, and dis'ances from the tailings pond or well field foi cach monitor should be noted in the table,
b. Ile submitted graphically to illustrate water quality and water level elevation changes with time with applicable goserning standards, EPA national interim primary drinking water standards and livestock standards, baseline or excursion levels, or MPCs (whateser is appropriate), for the panicular constituent on the Fraph.
c. Include a short summary of the data interpretation, noting any anomalies, with an explanation.
d. Water quality data reports should include a map which shows all water quality sampling points.

U.S. Environmental Protection Agency. I974. Mmualfor Chemical Analysh af Water and Waste.t lipA 625-/6-74 003a. Cincinnati, Oll: U.S. Environmental Protection Agency, Oflice of Research and Desclopment Publications.

2.9.4 Evaltnition Fintilngs if the stan's review as described in thit section results in the acceptance of the description of the site background radiological characteristics, the following conclusions may be presented in the TER.

The NRC has completed its review of the characterization infonnation concerned with the background radiological characteristics at the ISL facility. This review included an evaluation using the resiew procedures in SRP sstion 2.9.2 and acceptance criteria outlined in SRP section 2.9.3.

'Ibe licensee has acceptable established the background radiological characteristics by providing (i) nmnitoring programs to detennine background radiologic characteristics which include radionuclides monitored; sampling frequency; and methods, iocation, and density; (ii) air quality stations located consistent with the prevailing wind directions;(iii) time periods for preoperational monitoring that allow for 12 consecutive months of sampling; and (iv) radiologic analyses of soil samples at 5 cm and 15 cm depths.

Based on the infonnation provided in the application, and the detailed review conducted of the characteritation of the background radiological characteristics at the ISL facility, the NUREG-1569 2 32

.. . _ . . . -_ =-._ _. =- .- --_ . - - . - - _ . - - . - .

Site Characterization NRC stafT has concluded that the infomiation is acceptable to allow evaluation of the radiological background of the site and associated conceptual and numerical models and is in compliance with ,

10 CFR 51.45 requiring a description of the aflected environment containing sumcient data to aid the Commission in its conduct of an independent analysis.

2J.5 References ,

Nuclear Regulatory Commission.1980. Radiological Emuent and Environmental Monitoring at Uranium Mills. Regulato,y Guide 4.14, Rcrision /. Washington, DC: Nuclear Regulatory Commission, Omce of Stand 4 rds Development.

2.10 HACKGROUNP NONRADIOLOGICAL CilARACTERISTICS 2.10.1 Areas of Revit,

'ihe staff shall review information in the application on site specific nonradiological characteristics, particularly those that are related to expected site related emuents. Data to be examined shall include such ind:cators as heavy metals and other potentially toxic substances in surface and groundwaters, atmospheric pollutants, dusts, etc., that could afTect water or air quality. Other regional sourcn of these same materials shall be examined along with any discussion of the possible incremental contribution to the existing levels found.

2.10.2 Review Procedures The reviewer shall examine data from the preoperational monitoring program with particular attention paid to the design of the monitoring program, constituents analyzed, and the results and the detection limits reported for each constituent in each sample medium. Maps shall be examined to determine samplina locations and identify relationships to the proposed facility and the su.munding areas.

Other local and regional potential sources of the same materials shall be identified.

l'or heense renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility cperations and the approach that should be used in evaluating amendments and renewal applications.

2.10.3 Acceptance Criteria The characterization of the site background nonradiological characteristics is acceptable if it meets the following criteria:

(1) A listing of expected site related emuents is provided. This listing should be used to identify those constituents for which preoperational baseline values should be established.

(2) Atmospheric samples are taken to establish baseline conditions for constituents identified in the NAAQS.

l 2 33 NUREG 1569 l

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Special attention should be paid to those constituents that may be produced during l

operation of the ' proposed facility. These data can be gathered . as part of the meteorological information reviewed in section 2.5 of the SRP. l l

(3) When activities such as land applications are involved, background concentrations for soll i constituents are established. ,

i Sampling locations should be clearly sho m, and samples should be collected near areas that are likely to be disturbed during cona,uction and operation of the facility. Soil and 7 sediment sampling should also be conducted near and in drainage areas and surface water -

bodies tha' might be affected in the event of spills. Soll and sediment sampling locations  !

may be the wne for both radiological and nonradiological sampling.

(4) Groundwater and surface water background conditions are established in accordance with  ;

specific acceptance criteria identified in section 2.7.3.

7 (5) Data is gathered from either a preoperational surveillance program or from previous reports from other sources such as local, state, and federal agencies or universities. In all cases, data sources are documented and substantiated, c

2.10.4 Evaluation Findings if the stairs review as described in this section results in the acceptance of the description of the site background nonradiological characteristics, the following conclusions may be presented in the .

TER.  ;

The NRC has completed its review of the infonnation concerned with the background ,

nonradiological characteristics at the _ ISL facility. This review included an evaluation i using the review procedures in SRP section 2.10.2 and acceptance criteria outlined in SRP section 2.10.3.

. The licensee has acceptably established the background nonradiological characteristics by ,

documenting (i) site-related emuents (e.g heavy metals, and other potentially toxic substances),

(ii) baseline atmospheric constituent lesels, (iii) background soil constituent concentrations, (iv) ground ,

and surface water background constituents, and (iv) preoperational data or infonnation from other sources, liased on the intbrmation provided in the application, and the detailed review conducted of the characterization of the background nonradiological characteristics at the ISL facility,

. tne NRC stafY has concluded that the infonnation is acceptable to allow evaluation of the nonradiologic background of the site and associated conceptual and numerical models and is in compliance with 10 CFR L $1,45 requiring a description of the affected environment containing sumcient data to aid the Commission in its conduct of an independent analysis. -

2.10.5 References

- None, i

NUREG 1569 2 34 v l

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t 2.11 OTHER ENVIRONMENTAL FEATURES

. t.11. l Areas of Review .

Th's review shall include environmental site characterization infomiation that does not clearly 1 til into any rf the other subsections in section 2 of the SRP. These will typically be site speel0c, and '

r ay be used by the applicant to mitigate unfavorable conditions, or to provide additional infonnation in s apport of the d tscription of the proposed facility. Information that the applicant believes is important to establish the value of the site and site environs to important segments of the population is appropriately included in this subsection.

t 2.11.2 Review Procedures The staff shall consider environmental information provided in this section as auxiliary infonnation to support an application for a given facility. The information shall be considered in a site.

specine context and should be consistent with the information provided in other sections of the '

application. Depending on the site-speciSc situation, there may be no information in this section of the

  • application.

For license eenewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

2.11.3 Acceptance Criteria The characterization of other site environmental features is acceptable ifit meets the following criteria:

(1) It is consistent with inforruation provided in previous subsectians.

(2) Infonnation is provided in a manner consistent with good scientinc practice, is supported by objective aata to the extent possible, and is relevant to the site under consideration.

~(3) Information supports a detennination that the ISL facility can be operated in a manner that will protect public health and safety and the environment.

2.11.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the description of other environmental features at the site, the following conclusions may be presented in the TER.

The NRC has compkted its review of the characterization information concerned with other environmental features at the ISL facility. This review included an evaluation using the review procedures in SRP section 2.11.2 and acceptance criteria outlined in SRP section 2.11.3.

2 35 NUREG-1569

._ _ . -- _ _ _ . _ . _ . _ _ _ . - ~ _ . _ . _ _. . _ , _ . _ _ , __

___ . . __ _ __ _ _ _ _ _ . _ _ _ . ~ _ _ - . . _ _ . _ _ . - _ . .

- Site Characterir.ation-The licensee has acceptably described any other important environmental features by providing in'tmation that is (i) consistent with other aspects of the site description,(ii) supported by objective data, 1

(iii) relevant to the site under consideration, and (iv) supponive of a determination that the ISL facility i can be operated while protecting public health and safety.

I 1

Based on the infonnation provided in the application, and the detailed review conductwl of the characterir.ation of the other environmental features at the ISL facility, the NRC staff has concluded that the information is acceptable to allow evah..%n of the other environmental features and associated conceptual and numerical models and is in com,niance with 10 CFR 51.45 requiring a

- description of the affected ervironment containing sumcient data to aid the Commission in its conduct of an independent analysis.

2.11.5 References 1

t None.

1 i

1 -

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e i-l

NUREG 1569 2 36 ,

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3.0 DESCRIPTION

OF PROPOSED FACILITY 3.1 SOLUTION MINING PROCESS AND EQUIPMENT 3.1.1 Areas of Review The stMT shall review the in situ leaching process as described in the application. This review '

shall include, but not be limited to (1) A description of the ore bodies and the feasibility of processing the denned well field areas.

(2) Well construction techniques and integrity testhg procedures to ensure well installations ,

will not result in hydraulic communication between production zones and adjeent aquifers.

(3) A process description including injection / production rates and pressures; plant material balances and Cow rates; lixiviant makeup; recovery ef0ciency; and gaseous, liquid, and ,

solid wastes and efuuents that will be generated.

(4) Proposed operating plans and schedules that include timetables and sequences for well Geld operation, surface reclamation, and groundwater restoration.

(5) Evaporation and storage pond construction techniques.

The review shall also include maps showing the faciiities iayout, descriptions of the process and/or circuit, water and material balances, and the chemical recycling system.

3.1.2 Review Predr.res The staff shall determine whether the description of the in situ leaching process provided in the application is suf0cient to permit evaluation of the operations and processes involved in conformance with the acceptance criteria contained in section 3.1.3. StalT shall ensure the following are included in this section: a map or maps showing the proposed sequence and schedules for uranium extraction and ground - :r quality restoration operations; a now diagram of the process and/or circuit; a material balance diagram; a description of any chemical recycle systems; a water balance diagram for the entire system; and a map or mr.ps showirg the proposed sequence and schedules for land reclamation of the well field areas, if wells are not properly completed, lixiviant can now through casing breaks and into overlying aquifers. Casing breaks can occur if the w:ll is damaged during well construction activities. Casing breaks can also occur if water injection pressures exceed the strength of the well materials. Well completion techniques should be reviewed in suf0cient detail to give the reviewer a clear picture of how recovery, injection, and monitor wells are drilled; how their location and spacing are selected; and what materials and methods are used in construction, casing, ani abandonment. The reviewer shall pay particular attention to the technigees employed to prevent hydraulic communication between overlying or underlying aquifers through well boreholes. Additionally, the applicant should describe methods for well abandonment. The 31 NUREG 1569

, -j

Description of Proposed Facility-reviewer shall en3ure that the v. ell casing material used is approoriate for the depths to which the wells are drilled. Where polyvinyl chloride (PVC) is installed at greater than 500 ft, the reviewer shall ensure that the applicant has included the design speciGcations for the casing material used. The reviewer shall examine a description of the procedures used to test well integrity. The reviewer may refer to a well handbook (e.g., Driscoll,1989) to verify the appropriateness and expected perfonnance of well installation and abandonment methods.

The reviewer shall determine that any lined impoundment to contain wastes is acceptably designed, constructed, ard instelled. Materials used to construct the liner shall be reviewed to determine that they I. ave acceptable chem! cal properties and suf6cient strength for the design application. The reviewer shall detennine that the liner will not be overtopped. The reviewer shall determir.- that a proper quality control (QC) program is in place.

For license renewals and cmendment applications, appeadix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

3.1.3 Acceptance Criteria The solution mining process and equipment are acceptable if they meet the following criteria:

(1) The description of the ore body is sufGciently detailed to identify the mineralized zone, its areal distribution, and its approximate thickness, if more than one ore zone is to be leac.hed, each ore zone should be dc6ned separately.

The estimated ore grade should be speciGed.

(2) Well design, testing, and inspection meet ASYM standards (specinc standard numbers must be cited). The following discussion ren-ets practices that NRC has historically found to be acceptable for ISL operations.

(a) Well Design and Construction-Inji.ction and secovery wells should be constructed from materials that are inert to lixiviants and are strong enough to withstand injection pressures. PVC, Oberg! ass, or acrylonitrile butadiene styrene (ABS) plastic casings are generally used in wells less than 500 0 deep. Wells deeper than 500 0, or those subjected to high pressure cementing techniques, are subjtet to collapse. In these instances, steel or fiberglass casing is generally necessary, in all wells (including monitor wells), the annular space between the side of the borehole and the casing should be back-Olled with a scalant from the bottom of the casing to the surface in one continuous operation. Proper back-611ing isolates the screened formation against vertical migration of water from the surface or from other fonnations, and also provides support fo the casing.

Cement or cement-bentonite grout is generally acceptable as a sealant.

NUREG 1569 32

Description of Proposed Facility Material normally used for monitor well. casing is either metal or plastic. The possibility that chemical reactions may take place between the casing and the mineral constituents in the water afTects the choice of casing material used for monitor wells. For example, iron oxide in steel-cased wells will adsorb trace and heavy metals dissolved in the groundwater. Therefore, a baseline water sampling program should be used to detennine concentrations of trace metals.The applicant should use casing that is inert to these metals, such as PVC or fiberglass. When any well is completed, it should be developed until p oduction of essentially sediment free water is assured for the life of the well. One acceptable development method is to use a swab in the well to create a vacuum on the upstroke and positive pressure on the down-stroke.

(b) Well Integrity Testing-Injection and recovery wells should be tested for mechanical integrity. One acceptable method is to pressurize the casing with water to the maximum expected injection pressure, The valve on the line cor.necting the well to the pressurizing packer equipment should be closed, and the pressure inside the well casing monitored for 10 min. If the pressure do:s not drop 10 percent below the maximum pressure that was applied during the test, the casing is deemed acceptable for solution mining. The results of this test, including starting and ending pressures, should be recorded on a form siened by the well Geld engineer and facilities manager, and should be filed at the mine site and included in the application.

In the past, the NRC stafT has found the following well integrity testing procedures acceptable. To inspect for casing leak > after a well has been completed and opened to the aquifer, a packer should te set above the well screen, and each well casing should be filled with water. At the surface, the well should be pressurized with either air or water to 25 percent above the expected operating pressure. A well is satisfactory if a pressure drop of less than 10 percent occurs over I hr. Operating pressure varies with the depth of the well and should be less than formation fracture pressure. Well integrity tests are perfonned on each injection and production well before the wells are utilized and on wells that have been serviced with equipment or procedures that could damage the well casing.

Additionally, each well should be retested at least once each 5 yr if it is in use.

I The NRC staff does not find the sole reliance on single point resistance an acceptable method for determining well mechanical integrity.

(3) The description of the ISL process includes the following information and demonstrations:

(a) Projected downhole injection pressures with the hydrostatic pressure of the fluid column should be demonstrated to be maintained below casing (casing and cement) pressures and formation fracture pressures to avoid hydrofracturing the aquifer and promoting leakage into the overlying units. Piping burst strength should be considered in deep well fields (greater than about 1,000 ft).

3-3 NUREG-1569

Description of Proposed Facility (b) Overall production rates should be higher than injection rates.

(c) Proposed plant material balances and Dow rates should be acceptably described.

(d) Lixiviant makeup should be such that impact on the groundwater quality and the prospects for long-term groundwater restoration will be maintained at levels that ensure acceptable restoration goals can be achieved in a timely manner, Oxidants such as gaseous oxygen and hydrogen peroxide and carbonates such as sodium bicarbonate or carbon dioxide gas have been demonstrated in a number of iSL facilities to be suitable lixiviants.

(c) The description should include an estimate of gaseous, liquid, and solid wastes and effluents that will be generated. Efnuent monitoring and control measures are discussed in section 4.0.

(f) An analysis of the impact that ISL operations are likely to have on surrounding water users has been provided. An acceptable impact analysis should be based on results of numerical or analytical modeling calculations that are used to estimate groundwater travel times frora the proposed extraction areas to the nearby points of groundwater or surface water usage, estimate the amount of process bleed necessary to prever.t migration of lixiviant from the well Gelc', and demonstrate the ability to recover lixiviant excursions. Modciing efforts should be kept simple to the extent possible, favoring conservative assumptions over complicated parameter estimation. An acceptable impact analysis should demonstrate the following:

(i) The ability to control the migration of lixiviant from the ore zones to the surrounding environs (ii) Groundwater and surface water pathways that might transport mining solutions offsite in the event of an uncontrolled excursion or incomplete restoration l

(iii) The impact of ISL operation on groundwater Dow patterns and aquifer levels (iv) The expected post extraction impact on geochemical properties and water

! quality

(4) Proposed operating plans and schedules include timetables for well field operation, surface reclamation, and groundwater restoration. Water balance calculations should be provided that demonstrate that the liquid waste disposal facilities (evaporation ponds, land application, deep well injection) are adequate to process the proposed production and restoration efforts at any time.

NUREG-1569 34

Description of Proposed Facility (5) The design, installation, and operation of evaporation and storage ponds at the site equal or exceed guidance provided in Regulatory Guide 3.11 (Nuclear Regulatory Commission, 1977). The ponds should have sufficient capacity that the entire contents of one pond can be transferred to the other ponds in the event of a leak. (See section 2.7.3 for additional discussion of design and evaluation of retention systems and diversion facilities.)

The stafTshall verify the applicant's analyses or perform independent review analyses of floods and flood velocities, if the design assumptions and calculations are reasonable, accurate, and/or compare favorably with independent staff estimates, the designs are acceptable.

Using the criteria and guidance presented in NRC (1990), the staff shall evaluate the design of diversion channels in several critical areas. For the main channel area, the staff shall verify that appropriate models and input parameters have been used to design the erosion protection. The staff shall assure that flow rates, flow depths, and shear stresses have been correctly computed. The diversion channels snould be sized and protected to pass a PMF with minimal, if any, damage to the diversion channel. No release of contained materials should occur during a PM?. The staff shall determine that the depth of burial of any disposed material is sufTicient to preclude bottom scouring, if an existing or constructed channel is located in or near a pit or impoundment. Where practical, the use of diversion channels at new facilities should be avoided to lessen costs of reclamation and future maintenance.

The stafT shall review the plans, specifications, inspection programs, and QA/QC programs to assure that acceptable measures are being taken to construct the design features according to accepted engineering practices. The staff will compare the information provided with typical programs used in the construction industry.

(6) Results from R&D or other production operations are used to support the description of the ISL process where appropriate.

(7) The design of liners for surface impoundments meets or exceeds the requirements in 10 CFR Part 40, appendix A, criterion 5(A).

The liner for a surface impoundment used to manage uranium and thorium byproduct material must be designed, constructed, and installed to prevent any migration of wastes out of the impoundment to the subsurface soil, ground water, or surface water at anytime during the active life (including the closure period) of the impoundment. The liner r.iay be constructed of materials that allow wastes to migrate into the liner provided that the impoundment closure includes removal or decontamination of all waste residues, contaminated containment system components, contaminated subsoils, and structures and equipment contaminated with waste and leachate. If the impoundment will be closed with liner material left in place, the liner must be constructed of materials that can prevent wastes from migrating into the liner durir.g the active life of the facility.

35 NUREG-1569

Description of Proposed Facility The liner must be constructed of materials that have appropriate chemical properties and sufficient strength and thickness to prevent failure due to pressure gradients, physical contact with the waste or leachate, climatic conditions, and the stresses ofinstallation and daily operation. The subgrade must be sufHcient to prevent failure of the liner due to settlement, compression, or uplift. Liners must be installed to cover all surrounding earth which is likely to be in contact with the wastes or leachate.

The surface impoundment must be designed, constructed, maintained, and operated to .

prevent (i) overtopping resulting from normal or abnormal operations; (ii) overfilling; (iii) wind and wave actions; (iv) rainfall, or run-on; (v) from malfunctions of level controllers, alarms, and other equipment; and (vi) from human error, if dikes are used to form the surface impour.dment, the dikes must be designeu, constructed, and mcintained with sufHeient structural integrity to prevent massive failure of the dikes. In insuring structural integrity, the app'icant mest not assurn that the liner system will function without leakage during the active life of the impoundment.

The design of a clay or synthetic liner and its appurtenant component parts should be presented in the application or related amendment applications for a uranium recovery operation. At a minimum, design details, drawings, and pertinent analyses should be provided. Expected construction methods, testing criteria, and QA programs should be presented. Planned modes of operation, inspection, and maintenance should be discussed in the application. Deviation from these plans should be submitted to and approved by NRC staff prior to implementation.

Tests should show conclusively that the liner will not deteriors when subjected to the waste product and expected atmospheric and temperature condons at the site. Test data and all available manufacturers' test data should be submitted with the application. For clay liners, tests, at a minimum, should consist of falling head permeameter tests performed on columns of liner material obtained during and after liner installation. The expected reaction of the pond liner to any combination of solutions or atmospheric conditions should be known before the liner is exposed to them.

Proper preparation of the subgrade and slopes of a pond is very important to the success of the pond. The strength of the liner is heavily dependent on the stability of the slopes of the subgrade. The subgrade should be treated with a soil sterilant. The subgrade surface fcr a synthetic liner should be graded to a surface tolerance ofless than i in. across a 1-ft straightedge. NRC Regulatory Guide 3.11 (Nuclear Regulatory Commission,1977) outlines acceptable methods for slope stability and settlement analyses, and should be used for design. If an evaporation pond with a synthetic 'iner is located in an area where the water table could rise above the bottom of the liner, underdrains may be required.

A QC program should be established for the following factors: (i) clearing, grubbing, and stripping; (ii) excavation and backfill; (iii) rolling; (iv) compaction and moisture control; (v) Hnishing; (vi) subgrade sterilizathn; and (vii) liner subdrainage and gas venting.

NUREG 1569 36

D.7scription of Proposed Facility Field seams of synthetic liners should be tested along the entire length of the seam.

Representative sampling may be used for factory seams. The testing should use state-of.

the-an test methods recommended by the liner manufacturer. Compatibility tests which document the compatibility of the Geld seam material with the waste product and expected weather conditions should be submitted for NRC staff review and approval. If it is necessary to repair the liner, repiesentatives of the liner manufacturer should be called upon to supervise the repairs.

Daily inspections should be made of the liner, liner slopes, and other earthwork features.

Any damage or defects which could result in leakage should be immediately reported to the NRC staff. Appropriate repairs should be implemented as soon as possible.

To prevent damage to liners, some form of protection should be provided including:

(i) soil covers,(ii) venting systems,(iii) diversion ditches. (iv) side slope protection, or (v) game-proof fences. A program for maintenance of the liner features should be developed and repair techniques should be planned in advance.

Controls should be established over access to the pond, including access during routine maintenance. A procedure should be provided that assures that unnecessary trafGc is not directed to the pond area.

A leak detection system should be installed at all sites utilizing natural or synthetic liners, The system should be designed to perform the following ftmetions: (i) detect accidental leaks from the pond, (ii) identify the location of the leak so that liner repair can be implemented immediately, and (iii) isolate the leakage and control it.

The licensee should monitor the groundwater environment in the vicinity of and downgradient from the lined pond. Monitoring of both the unsaturated zone and saturated zone aquifers should be performed. The applicant should provide analyses documenting that the area of influence of any lysimeters and monitor wells (or other desices) is sufficient to detect any leakage from the pond. Detailed rationale for the placement, locations, type, and number of wells should be provided along with the proposed frequency of sampling. Regulatory Guide 4.14 (Neelear Regulatory Commission,1980) describes programs acceptable to the NRC stalT for groundwater monitoring around tailings and evaporation ponds.

3.1.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the solution mining process ad equipment, the following conclusions may be presented in the TER.

The NRC has completed its review of the solution mining process and equipment proposed for use at the ISL facility. This review included an evaluation using the review procedures in SRP section 3.1.2 and the acceptance criteria in SRP section 3.1.3.

37 NUREG-1569

Description of Proposed Facility The applicant has acceptably described the ore body (ies); demonstrated that w eli installation and testing techniques comply with ASTM standards for materials to withstand lixiviants and injection pressures; demonstrated protection against vertical migration of water; proposed tests for well integrity that assure facility stability; and demonstrated that the ISL process will meet the following criteria:

(i) downhole injection pressures are less than formation fracture pressures;(ii) overall production rates are higher than injection rates; (iii) plant material balances and flow rates are appropriate; (iv) lixiviant makeup is such that restoration goals can be achieved in a timely manner; (v) reccvery efficiency is assessed through mass balance calculations; and (vi) reasonable estimates of gaseous, liquid and solid wastes and efiluents are provided (used in evaluation of efiluent monitoring and contrcl measures in S"P section 4.0). The applicant has used the results from R&D or other production operations to support the evaluation of the solution miniag process. The applicant has provided acceptable operating plans, schedules, and timetables fbr well field operation, smthee reclamation, and groundwater restoration, The applicant has shown that liquid waste disposal facilities are adequate to handle production and restoration efforts and has designed installation and operation of evaporation and storage ponds such that the ponds can contain the entire contents of any other leaking or inoperative pond. The applicant has demonstrated that any dikes used to form a surface impoundment are designed, constructed, and maintained with sullicient structural integrity to prevent massive failure. Additionally, surface impoundments and associated liners are properly designed, llased on the inibrmation provided in the application and the detailed review conducted of the solution mining process and equipment for the ISL facility, the NRC stafT has concluded that the proposed solution mining process and equipment are acceptable and are in compliance with 10 CFR 40.32(c) which requires the applicant's proposed equipment, facilities, and procedures to be adequate to protect health and minimize danger to life or property; 10 CFR 40.32(d) which requires that the issuance of the license will not be inituical to the common defense and security or to the health and safety of the public; 10 CFR 40,41(c) which requires the applicant to confine source or byproduct material to the location and purposes authorized in the license; and 10 CFR Part 40, appendix A, criteria 5(A)(1) and (2) for groundwater protection and surface impoundments. The related reviews of the 10 CFR Part 20 radiological aspects of the solution mining process and equipment in accordance with SRP sections 4.0, Ellluent Control Systems; 5.0, Operations; and 7.0, Environmental EITects; are addressed elsewhere in this TER.

3.1.5 References Driscoll, F.G.1989. Grosmdwater und Wells. St. Paul, MN: Johnson Filtration Systems, Inc.

Nuclear Regulatory Commission.1990. Final StatT Technical Position Design of Erosion Protection Covers for Stabilization of Uranium Mill Tailings Sites, Washington, DC:

Nuclear Regulatory Commission.

Nuclear Regulatory Commission.1977. Design, Construction, and inspection of Embankment Retention Systems for Uranium Mills. Regulatory Guide J.//. Washington, DC; Nuclear Regulatory Commission, Ollice of Standards Development.

NUREG-1569 3-8

l l

Description of Proposed Fa:ility Nuclear Regulatory Commission.1980. Radiological EfTluent and Environmental Monitoring of Uranium Mills. Regulatory Guide 4.N. Washington, DC: Nuclear Regulatory Commission, OfGce of Standards Development.

3.2 RECOVERY PLANT EQUIPMENT 3.2.1 Areas of Review The statT shall review the physical descriptions and reported operating characteristics for the major equipment items of the processing cycle. The staff shall also review descriptions of the proposed process infonnation and control systems relevant to safety, as well as radiation sampling and monitoring equipment. The staff shall review a diagram that indicates the plant layout and locations where dusts, fumes, or gases would be generated; and locations of all ventilation, Hitration, con 0nement, and dust collection systems and radiation safety and radiation monitoring devices.

3.2.2 Review Procedures The staff shall determine whether the physical descriptions and reported operating characteristics for the major equipment items of the processing cycle and the proposed control systems and safety / radiation instrumentation are sufHcient to evaluate the perfonnance of the proposed mining facility.

Staff shall ensure that the application identines all areas where releases of radioactive and hazardous materials (such as radon gas and uranium dust) can occur and that locations of control equipment (e.g.,

ventilation and exhaust systems) and instrumentation are provided.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

3.2.3 .cceptance Criteria The description of the recovery plant equipment is acceptable ifit meets the following criteria:

(1) The application provides a diagram of the proposed (or existing) plant layout.

(2) Areas where dusts, fumes, or gases would be generated are clearly identified along with a description of the source of the emissions (i.e., what is creating the emissions).

(3) All ventilation, Gitration, confinement, and dust collection and the locations of the radiation monitoring equipment described as to type of equipment and their locations identiGed.

3.2.4 Evaluation Findings if the staft's review as described in this section results in the acceptance of the recovery plant equipment,' the following conclusions may be presented in the TER.

39 NUREG-1569

1 Description of Proposed Facility ~  ;

~

The NRC has completed its review of the recovery plant equipment proposed for use at the =

ISL facility. This review included an evaluation using the review procedures in SRP section 3.2.2 and the acceptance criteria outlined in SRP section 3.2.3, The recovery plant equipment has been acceptably diagrammed to show' areas where dusts, e

fumes, or gases would be generated. Ventilation, filtration, confinement and dust collection systems, and ~

the locations of radiation monitoring equipment have been provided.

ilased on the information provided in the application and the detailed review conducted of the recovery plant equipment for the ISL facility, the NRC staff has concluded that the proposed recovery plant equipment is acceptable and is in compliance with 10 CFR 40.32(c) which requires that the applicant's proposed equipment,' facilities, and procedures to be adequate to protect health and minimize danger to life or property; 10 CFR 40.32(d) which requires that the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public; and 10 CFR 40.41(c) which requires the applicant to confine source or byproduct material to the locations and purposes authorized in the license. The related reviews of the 10 CFR Part 20 radiological aspects of the recovery plant equipment in accordance with SRP sections 4.0, Effluent Control Systems; 5.0, Operations; and 7.0, Environmental Effects; are addressed elsewhere in this TER.

3.2.5 References None.

3.3 INSTRUMENTATION 3.3.1 Areas of Review The staff shall review descriptions of the proposed process instrumentation and control systems relevant to safety and radiation safety sampling and monitoring instrumentation, including their minimum specifications and operating characteristics. This review shall include well field process control equipment for monitoring injection pressures, injection rates, and production rates.

3.3.2 Review Prw iures The staff shall review the descriptions of the proposed instrumentation and control systems provided in the application to determine whether they are suflicient to evaluate the interrelationship between the proposed instrumentation systems and the operations or processes to be controlled or monitored. The staff shall also determine whether the proposed instrumentation systems are sufficient to control and monitor operations and processes identified in the description of the proposed facility.

Particular attention should be focussed on whether proposed monitoring and control instrumentation is adequate to quickly identify and remedy ISL and processing problems that can increase exposures to-radiological and chemical hazards, Areas of concern include monitoring and ventilation systems designed to detect and control elevated releases of yellowcake dust from drying and storage operations and radon gas buildup in buildings. Instrumentation to detect and control liquid releases from well field and processing pipe failures, impoundment leaks, and chemical tank valve failures shall also be evaluated in L

NUREG 1569 3 10 o

1

Description of Proposed Facility the stalT review.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

3.3.3 Acceptance Criteria The facility instrumentation is acceptable if it meets the following criteria:

(1) Instrumentation has been described for the various components of the processing facility, including well Gelds, well field houses, trunklines, the production circuit, evaporation ponds, and deep injection disposal wells.

(2) Instrumentation is designed to allow the plant operator to continuously monitor and control a variety of systems and parameters, including total flow into the plant, total waste flow leaving the plant, tank levels, and the yellowcake drier. Instrumentation includes alarms in the event of a failure.

(3) Critical components of the systems are equipped with backup systems that activate in the event of a power failure.

(4) Well Geld operating pressures are kept below casing and formation rupture pressures to prevent vertical excursions. Well Geld operation pressures are to be routinely monitored either at the well head or on the entire system, and are to be measured and recorded daily.

3.3.4 Evaluation Findings if the stairs review as described in this section results in the acceptance of the facility instrumentation, the following conclusions may be presented in the TER.

The NRC has completed its review of the instrumentation proposed for use at the ISL facility. This res iew included an evaluation using the review procedures in SRP section 3.3.2 and the acceptance criteria outlined in SRP section 3.3.3.

The instrumentation has been acceptably described for components including the well Gelds, well field houses, trunklines, production circuit, evaporation ponds, and deep injection disposal wells. The instrumentation allows for continuous monitoring and control of systems including total inflow to the plant, total waste flow exiting the plant, tank levels, and the yellowcake drier. Appropriate alarms are part of the instrumentation systems. Each critical system is equipped with an acceptable backup that automatically activates in the event of a power failure.

Ilased on the infonnation provided in the application and the detailed review conducted of the instrumentation for the ISL facility, the NRC staff has concluded that the proposed instrumentation is acceptable and is in compliance with 10 CFR 40.32(c) which requires the applicant's  ;

3-11 NUREG-1569 l

Description e' Proposed Facility proposed equipment, facilities, and procedures to be adequate to protect health and minimize danger to life or propeny; 10 CFR 40.32(d) which requires that the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public; 10 CFR 40.41(c) which requires the applicant to confine source or byproduct iraterial to the kications and purposes authorized in the license; and 10 Cl R 40, appendix A, criteria 5(A)(1) and (2) for groundwater protection and surface impoundments. The related reviews of the 10 CFR Part 20 radiological aspects of the solution mining process and equipment in accordance with SRP sections 4.0, Efiluent Control Systems; 5.0, Operations; and 7.0, Ensironmental lifTects; are addressed elsewhere in this TER.

3.3.5 References None, NUREG-1569 3-12

4.0 EFFLUENT CONTROL SYSTEMS ^

4.1 GASEOUS AND AIRBORNE PARTICULATES 4.1.1 Areas of Review The staff shall review descriptions of the proposed ventilation. Oltration, and confinement systems that are to be used during operations to control the release of radioactive materials to the atmasphere. The staff shall also review analyses of equipment as designed and operated to prevent radiation exposures and to limit exposures and releases to as low as reasonably achievable (ALARA). A review shall also be conducted of a physical description of discharge stacks, types and estimated composition and flow rates of atmospheric effluents, and proposed methods for controlling such releases.

4.1.2 Review Procedures The staff shall review descriptions, designs, and operational modes to determine whether the proposed ventilation, filtration, and confinement systems and equipraent described in the application are sullicient to control the release of radioactive materials to the atmosphere to meet acceptance criteria identified in section 4.1.3.

4.1.3 Acceptance Criteria The gaseous and airborne paiticulate efiluent control systems are acceptable if they meet the following criteria:

(1) Monitoring and control systems for the facility are located to optimize their intended function. Monitors used to assess worker exposures are placed in locations of maximum concentration based upon determination of airflow patterns.

(2) Monitoring and control systems for the facility are appropriate for the types of ellluents generated. The intended purposes of measurement devices are clearly stated and enteria for monitoring are provided. The acceptance criteria from section 5.7.7.3 of the SRP should be met.

(3) The application provides a demonstration that adequate ventilation systems are planned for process buildings to avoid radon gas buildup. Ventilation systems chould be consistent with the requirements of Regulatory Guide 8.31, Infbrmation Relevant to Ensuring that Occupational Radiatior Exposures at Uranium Mills will be as low as is Reasonably Achievable (Nuclear Regulatory Commission,1983), section 3.3.

The review emphasis should be on (i) radon gas mobilization from recovery solutions entering the plant, (ii) the extraction process (where tanks are vented), and (iii) uranium particulate emissions resulting from drying and packaging operations and spills. For facilities using an open air design for processing (i.e., processing equipment is not enclosed by a building), ventilation will be less of a safety concern. Aspects of design that can significantly limit airborne releases include closed production systems (i.e., no 4-1 NUREG-1569

Emuent Control Systems venting) and the use of vacuum dryers that eliminate airborne uranium particulate releases from drying operations.

(4) The application demonstrates that the emuent control systems will limit exposures under both normal and accident conditions. The application also provides infonnation on the health and safety impacts of system failures and identines contingencies for such occurrences.

4.1.4 Evaluation Findings if the staffs review as described in this section results in the acceptance of the emuent control systems for gaseous and airborne particulates, the following conclusions may be presented in the TER.

The NRC has completed its review of the effluent contml systems for gaseous and airborne paniculates proposed for use at the ISL facility. This review included an evaluation using the review procedures in SRP section 4.1.2 and the acceptance criteria outlined in SRP section 41.3.

The applicant has acceptably described the discharge stacks and the types, estimated composition, and flow rates of cHbents released to the atmosphere. The applicant has designated monitoring and control systems (e.g. ventilation, filtration, and con 6nement) for the types of emuents generated. Also, the applicant has speciGed acceptable monitoring criteria and has located the facility monitoring and contml systems for the required functions (e.g., placement of monitors to optimally assess worker exposure in locations oflikely maximum concentrations detennined by the applicant's analysis of airflow patterns).

The applicant has demonstrated that sentilation systems are acceptable to prevent radon gas build-up where (i) recosery solutions enter the plant, (ii) tanks are vented during the extraction process, and (iii) drying and packaging operations occur By providing information on the health and safety impacts of system failures and identifying contingencies for such occurrences, the applicant has acceptably shown that emuent control systems will limit radiation exposures under both normal and accident conditions. The applicant has committed to occupational radiation doses and doses to the general public that meet dose limits and ALARA goals.

Ilased on the infomiation provided in the application and the detailed review conducted of the emuent control systems fbr gaseous and airborne particulates for the ISL facility, the NRC staff has concluded that the proposed emuent control systems for gaseous and airborne particulates are acceptable and are in compliance with 10 CFR 20.1101 which requires that an acceptable radiation protectim program that achieves ALARA goals is in place; 10 CFR 20.1201, which defines the allowable occupational dose limits for adults; 10 CFR 20.1301, which defines dose limits allowable for individual members of the public; and 10 CFR 20.1302, which requires compliance with dose limits for individual members of the public. The related reviews of the 10 CFR Part 20 radiological aspects of the emuent control systems for gaseous and airborne radionuclides in accordance with SRP sections 5.0, Opcrations; and 7.0, Environmental Effects; are addressed elsewhere in this TER.

4.1.5 References Nuclear Regulatory Commission.1983. Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium ! tills will be as low as is Reasonably Achievable. Regidatory Guide 8.3/

Washington, DC: huclear Regulatory Commission, Office of Standards Development.

NUREG-1569 42

Effluent Control Systems 4.2 LIQUIDS AND SOLIDS 4.2.1 Areas of Review The staff shall review estimates of quantities and compositions of waste residues expected during construction and operation, and the procedures proposed for their management. The staff shall also review design speci6 cations for emuent control systems for liquids and solids. Staff shall review the design speci6 cations of any retention systems such as ponds. If emuents are to be released into surface waters or injected into disposal wells, the staff shall also review the plans to obtain any water quality certifications and discharge permits that may be necessary. Appendix D provides staff guidance on emuent disposal at licensed uranium recovery facilities.

Areas to be reviewed include (1) Information related to lined evaporation pond design, monitoring programs, freeboard requirements, and leak reporting procedures (2) Liquid efiluent disposal plans (3) Contingency plans for dealing with leaks and spills (4) Contaminated solid waste generation and disposal plans (5) Noncontaminated solid waste generation and disposal plans 4.2.2 Review Procedures Staff shall ensure that facility descriptions include a discussion of design features to contain contamination from spills resulting from normal operations and potential accidents (e.g, valve and tank failures, leaks in pond liners). StafT shall perform the following arsessments:

(1) Verify that evaporation ponds rely on standard engineering design to ensure proper containment performance, including appropriate leak detection systems. Staff shall also ensure that appropriate freeboard requirements are established, and that appropriate monitoring programs and reporting procedures are in place.

(2) If liquid effluents are to be released into surface waters, applied to land surfaces, or injected into disposal wells, determine whether the appropriate water quality certifications and discharge permits have been applied for or issued (see SRP section 10.0 for review of these documents).

(3) Ensure that contingency plans are in place for dealing with spills of process fluids from valve, pipe, or tank failures that would rem *: h large spills.

4-3 NUREG-1569

l Emuent Control Systems (4) Ensure that an agreement is in place for disposal of II.e(2) byproduct material in an NRC --

licensed disposal facility or a licensed mill tailings facility.

(5) Ensure that all noncontaminated solid waste will be collected and disposed in accordance with state and local requirements regarding land 611 disposal.

4,2,3 Acceptance Criteria The liquids and solids emuent control systems are acceptable if they meet the following criteria:

(1) Common liquid emuents generated from the process bleed, process solutions (e.g.,

backwash, resin transfer waters), wash-down water, well development water, and restoration waters are properly controlled.

Acceptable control methods include: diversion of liquid wastes to evaporation ponds, deep well injection, and land application / irrigation. Solid emuents can be considered either as contaminated or as noncontaminated Contaminated solid effluent that can be decontaminated and released for unrestricted use is discussed in detail in section 4.3.

In order to dispose of liquid waste by onsite land application the applicant must provide (i) a description of the waste including its physical and chemical propenies that are important to risk, (ii) a description of the proposed manner and conditions of waste disposal, (iii) an analysis and evaluation of pertinent information on the nature of the environment, (iv) information on the nature and location of other potentially afTected facilities, and (v) analyses and procedures to ensure that doses are maintained ALARA and withir. the dose limits in 10 CFR 20.1301.

For land application, the applicant must analyze and assess projected (i) concentrations of radioactive contaminants in the soils;(ii) impacts on groundwater and surface water quality; (iii) impacts on land use, particularly crops and vegetation; and (iv) exposures and health risks that may be associated with radioactive constituents reaching the food chain. ,

All projected doses and risks must conform to the risk levels permitted under 10 CFR Part 20. The applicant should propose periodic soils surveys that include contaminant monitoring to verify that contaminant levels in the soil do not exceed the ,

projected levels. A remediation plan must be in place to be implemented in the event that the projected levels are exceeded.

The applicant must conduct analyses to assess the chemical toxicity of radioactive and nonradioactive constituents to evaluate health risks associated with land application involving irrigation at particular sites. StafT shall determine that the specific toxicity evaluations and any necessary permits are sumcient to conform to the applicable regulations such as 10 CFR 20.2007. In the absence of compliance monitoring wells in the uppermost aquifer in the area used for land application, the applicant must demonstrate that contaminants will not be returned to the groundwater and cause any exceedence of site speci6c groundwater protection standards.

NUREG-1569 44 l

__.____.____.m.. _ . - _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _

Effluent Control Systems Applicants are required to comply with the NkC requirements for decommissioning prior h facility closure tud license termination. (Decommissioning requirements are discussed in section 6 of this SRP.)

(2) Onsite evaporation systems are designed and operated in a manner that prevents migration of waste from the evaporation system to the subsurface.

The following discussion provides guidelines for an acceptable application section dealing with evaporation ponds.

The monitoring and inspection program consists of documented daily checks of pond freeboard and the leak detection synm. Because smal! amounts of condensation can accumulate in leak detection sumps, bemical samples are not commonly collected until water levels greater than a specified amount are detected. The NRC has found 6 in, to be an acceptable level. When signincant water levels are detected, the water in the standpipes must be sampled for indicator parameters to confirm that the water in the detection system is from the pond. The applicant should specify and pro the basis for selecting the indicator parameter (s) used to verify leaks.

Corrective actions should commence upon leak confirmation and should consist of transferring the solution to another pond so that liner repairs can be made. Thus, sufficient freeboard capacity should be maintained in the evaporation pond system that any one pond could be transferred to the remaining ponds in the event of a leak. An additional freeboard requirement is that water levels should be kept far enough below the top of the pond to prevent waves from overtopping during high wind conditions.

Actions to be taken in the event that evaporation pond standpipe water analyses indicate pond leakage include (i) notifying the NRC by telephone within 48 hr of veri 0 cation, (ii) analyzing standpipe water quality samples for leak parameters once every 7 days during the leak period and once every 7 days for at least 14 days following repairs, and (iii) filing a written report with the NRC within 30 days of first notifying the NRC that a leak exists. (This repun would include analvtical data and describe the mitigative action and the results of that action.)

(3) Plans and procedures are provided for addressing contingencies for all reasonably expected system failures and include (a) A listing of potential failures in process or well field equipment that could result in a release of material (b) Identification of appropriate plant and corporate personnel who must be notified in the event of specific types of failures (c) Measures for quickly containing and mitigating the impacts of released materials (d) Provisions for issuing radiation work permits for workers to mitigate impacts l i

I 4-5 NUREG-1569 l l

Ef0uent Control Systems (c) SpeciDe procedures for complying with noti 0 cation requiremen's in the regulations, license, and other permits, as appropriate Processing plants should have sump capacity sufficient to contain the volume of the largest tank in the plant that contains hazardous materiai. Well field flow circuits should be equipped with alarms to notify the operator in the esent ofloss of pressure or excess pressure anywhere within the production circuit. The applicant should maintain a log of all signincant solution spills The NRC should be notified by telephone within 48 hr of any failure that might have a radiological or nonradiological impact on the environment. The noti 0 cation would be followed, within 7 days, by a written report detailing the conditions leading to the failure or potential failure, corrective actions taken, and results achieved. This should be done in addition to the requirements of 10 CFR Pan 20, and 10 CFR 40.60.

(4) The application contains a description of the methods to be used for disposing of contaminated solid wastes that are generated during operation of the facility.

Equipment that can be decontaminated and released for unrestricted use is discussed in section 5.7.6 of this SRP. The storage of byproduct material that either cannot or will not be decontaminated and released for unrestricted use will be managed to ensure compliance with occupational dose limits in 10 CFR Pan 20. subpart C. The detailed review of occupational doses will be completed as described in section 5.7.6 of the SRP. The application should provide an estimate of the amount of contaminated material that will be generated and objective evidence of an agreement for disposal of these materials either in a licensed waste disposal site or at a licensed mill tailings facility.

(5) Noncontaminated solid waste will be gathered periodically and disposed in a sanitary landGil in accordance with state and local regulations. Regulation of this disposal is not part of the NRC licensing responsibility.

(6) Water quality certi0 cation and discharge permits have been obtained, or plans are in place to obtain them (review requirements for the status of these permits are addressed in section 10.0 of the SRP).

(7) Additional details on acceptable methods for efDuent disposal by release to surface water, evaporation from ponds, land application, and deep well injectioii are provided in Appendix D.

4.2.4 Evaluation Findings If the staft's review as described in this section results in the acceptance of the efnuent control r systems for liquids and solids, the following conclusions may be presented in the TER.

l L NUREG-1569 4-6 i

I-

Effluent Control Systems The NRC has completed its review of the efnuent control systems for liquids and solids proposed for use at the ISL facility. This review included an evaluation using the review procedures in SRP secticn 4.2.2 and the acceptance criteria outlined in SRP section 4.2.3. l The applicant has acceptably described the common liquid effluents generated at the fa:ility.

Appropriate control methods including diversion to evaporation ponds, deep well irijection, and land application 4rrigation (select appropriate methods) are identined. Onsite evaporation system designs are prescribed in acceptable detail including engineering plans and drawings. The applicant has proposed daily checks of pond freeboard and leak detection systems. Chemical campling is initiated when leak levels are greater than 6 in. The planned sampling and analysis of contaminants in the leak detection systems are acceptable. An appropriate corrective action plan is described that allows for the contents of a given pond to be transferred to another pond with no release of contamination. The applicant has an acceptable action plan to not:fy NRC, analyze samples, and Ole a written report in the event of leaks. The applicant has ensured that disposal plans are in compliance with applicable directives. Acceptable plans and procedures

-that address contingencies for all reasonably expected system failures are provided. The applicant has demonstrated that sump capacity is sumcient to contain the volume of the largest hazardous material source. The facility has acceptable alarms to notify the operator of loss of or excess pressure within the production circuits.1he applicant's log of signi6 cant solution spills is acceptable. The applicant's plan for spill noti 0 cation is acceptable. The applicant has an acceptable plan for the disposal of contaminated solid wastes that are generated by the facility. The applicant has proposed storage of contaminated material that either cannot or will not be decontaminated and released for unrestricted use. The applicant has demonstrated that the contamination will be managed to insure compliance with occupational dose limits as discussed in section 5.7.6 of this TER. The applicant will dispose of contaminated solid waste periodically in a sanitary land 0ll in accordance with state and local regulations. The applicant has demonstrated possession of the appropriate water quality certi6 cation and discharge permits or has plans in place to obtain them, fly providing infonnation on the health and safety impacts of system failures and identifying contingencies for such occurrences, the applicant has shown that e0luent control systems will limit radiation exposures under both nomial and accident conditions. The applicant has committed to maintaining occupational radiation doses and doses to the general public that meet exposure limits and ALARA goals.

Ilased on the infonnation provided in the application and the detailed review conducted of the enluent control systems for liquids and solids for the ISL facility, the NRC staff has concluded that the proposed enluent control systems for liquids and solids ;re acceptable and are in compliance with 10 CFR 20.1101 which requires that an acceptable radiation protection program that achieves ALAR A goals is in place; 10 CFR 20.1201, which dennes the allowable occupational dose limits for adults; 10 CFR 20.1301, which deOnes dose limits allowable for individual members of the public; 10 CFR 20.1302, which requires compliance with dose limits for individual members of the public; 10 CFR 20.2007 which requires that disposal by injection in deep wells must also meet any other applicable federal, state, and local gosernment regulations pertaining to deep well injection; 10 CFR Part 40, appendix A, criteria SA(1) through SA(5L which deOne design provisions for surface impoundments; criterion SE which dennes installation of liners; criterion SF w hich provides requirements fbr seepage controh criterion 6, which dennes closure requirements; and criteria 8, which requires confonnance to the provisions in 40 CFR Part 440, as applicable. The related reviews of the 10 CFR Part 20 radiological aspects of the effluent control systems for liquids and solid radionuclides in accordance with SRP sections 5.0, Operations; and 7.0, Environmental E0'ects; are addressed elsewhere in this TER 47 NUREG-1569

._~ . . . . ._. -

Effluent Control Systems 4.2.5 References None.

4.3 CONTAMINATED EQUIPMENT The review in this area will be conducted using section 5.7.6 of the SRP.

1 l

NUREG-1569 4-8  ;

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5.0 OPERATIONS 5.1 CORPORATE ORGANIZATION AND ADMINISTRATIVE PROCEDURES 5.1.1 Areas of Review

. The staff shall rev!cw the detailed description of the applicant's proposed orgaaintion and '

administrative procedures, including a description ember chart depicting the key positions in the managcment structure and the responsibilities and fanctions ci ecch with iespect to development, re@w, approval, implementation, and adherence to operating prowdures, radiation safety programs, covironmmtal and groundwater monitoring programs. QA prograras, routine and nonroutine maintenance a:tivities, and changes to any of these. la addition, the reviewer shall examine the plans proposed by the applicant for establishing a Safety and Envhonmental Review Panel (SERP) and the proposed composition and responsibilitics of the SERP.

.5.1.2 Review Procedures The staff shall review areas outlined in the SFCG (Nuclear Regulatory Commission,1982).

Specifically, the reviewer shall determine w hether the proposed organization and administrative procedures are defined in suflicient detail to evaluate the perfonnance of persons in positions responsible for developing, reviewing, approving, implementing, and enforcing the proposed programs related to radiological safety, environmental safety, and groundwater pmtection. In addition, the reviewer shall examine the plans proposed by the applicant for establishing a SERP and the proposed composition and responsibilities of the SERP, For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications, 5.1.3 Acceptance Criteria The corporate organization and administrative procediires are acceptable if they meet the following criteria:

(1) The applicant has provided adequate descriptions of the corporate organization, clearly defining management responsibilities and authority at each lesel.

Specifically, the corporate radiation safety ollicer (CRSO) shall have the responsibilities and authority outlined in Regulatory Guide 831, section 1.2.

(2) The organir.ational structure shows integration among groups that suppon the operation i and maintenance of the facility, if the facility is new, integration between - plant construction and plant management shoWd be detailed.

(3) The applicant has established a SERP that will consist of at least three individuals. One member of the SERP will have expertise in management and will be respondble for implementing managerial and financial changes; one member will have expertise in 5-1 r4UREG-1569

operations and/or construction and will hate responsibility for implementing any operational _ changes; and one member will be the CRSO, or equivalent, with the responsibility for assuring that changes conform to radiation safety and environmental requirements. Additional members may be included in the SERP as appropriate: to address specific technical issues such as health physics, groundwater hydrology, surface water hydrology, and specific carth sciences or other technical disciplines. Temporary members may include consultants.

(4) To the extent possible, proposed administrative procedures confonn with Regulatory Guide 8.2, Guide for Administrative Practices in Radiation Monitoring (Nuclear Regulatory Commission,1973).

5.1.4 Fxaluation Findings if the staffs review, as described in this section, results in the acceptance of the corporate organization and administrative procejures, the following conclusions may be presented in the TER.

The NRC has completed its review of the corporate organization and administrative procedures proposed for use at the ISL facility. This review included an evaluation using the review procedures in ERP section 5.1-2 and the acceptance criteria outlined in SRP section 5.l.3.

The applicana hcs an acceptable corporate organization that defines management responsibilities and authority at each level. The applicant's definition of the responsibilities and procedures with respect to develcpment, review, approval, implementation, and adherence to operating procedures, radiation safety programs (including record keeping and reporting). environmental and groundwater monitoring programs, QA programs, routine /nonroutine maintenance activities, and tha.7ges to any of these is acceptable.

Integration among groups that support operation and maintenance of the facility is demonstrated. In the case of a new facility, integration between facility construction and plant management is acceptably detailed. The applicant has established a SERP with at least three individuals representing expertise in management / financial, operations / construction. and radiction safety (CRSO) matters. The applicant has demonstrated that specific technical issues will be dealt with by the SERP, with suppon fro n other qualified staff members, or consultants as appropriate.

Based on the information provided in the application and the detailed review conducted of the corporate organization and adininireative procedures for the ISL facility, the NRC stafT has concluded that the proposed corporate organization and administrative procedures are acceptable and are in compliance with 10 ti'R 20.1101, which defines radiation protection program requirements; 10 CFR Part 20, subpart 1, sections 2101-2110, which define requirements for record keeping; and 10 CFR Part 20, subpart N, sections 2201-2206, which present the requirements for reporting.

5.1.5 References Nuclear Regulatory Commission.1973. Guide for Administrative Practices in Radiation Monit oring.

l Regulatory Guide 8.2 Washington, DC: Nuclear Regulatory Commission, Office of Standards I Development.

l 5-2 w

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4 Operations

- Nuclear Regulatory Commission.1982. Standard Format'and Content of License Applications,includmg Environmental Reports, for in Situ Uranium Solution Mining (SFCG). Regulatory Guide J..I6.

Washington, DC: Nuclear Regulatory Commission, Office of Standards Development.

Nuclear Regulatory Commission.1983. Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills will be as low as is Reasonably Achievable. Regulatory Guide 8.3/.

Washington, DC: Nuclear Regulatory Commission, Office of Standards Development.

5.2 MANAGEMENT CONTROL PROGRAM -

5.2.1 Areas of Review The staff shall review the management control program and administrative procedures proposed 4

to ensure that activities affecting health, safety, and the environment are conducted in accordance with written standard operating procedures (SOP). The reviewer shall evaluate the management control and decision bases to be used by the SERP in deciding when it is necessary to apply for a license amendment.

Procedures t.oveming nonroutine work or maintenance that is not covered by an SOP stall be reviewed.

5.2.2 Review Procedures The reviewer shall determine that the proposed management control program and administrative procedures are sufHcient to assure that all proposed activities potentially affecting health, safety, and the environment will be conducted in accordance with written operating procedures. The review shall include determining the process for identifying and developing SOPS for routine work, and the review and approval process to be used by the radiation safety staff to modify SOPS when appropriate. Methods for review and approval of nonroutine work or maintenance activity by the radiation safety staff shall be examined, in addition, the reviewer shall examine the plans proposed by the applicant for establishing a SERP and the proposed composition and responsibilities of the SERP.

5.2.3 Acceptance Criteria The management control system is acceptable if (1) The proposed management control program and administrative procedures are sufTicient to assure that all proposed activities can be conducted in accordance with written operating procedures.

(2) The applicant provides a process that will be used to identify and prepare operating procedures for routine work.

There should be a mechanism for the development, approval, and review of all SOPS by the radiation safety staff on an annual basis. Subsr=;uent inspections will ensure that SOPS are adequate and applied correctly.

53 NUREG-1569 i

Operations The process should '_ include procedures covering all aspects of radiation safety,

- maintenance activities (especially in radiation areas), development of wcil Helds, and SERP myiews and activities.

. For SOPS for radiation safety, refer to Regulatory Guide 8.31 (Nuclear Regulatory Commission,1983).

(3) The applicant presents methods for review and approval of _nonroutine work or maintenance activity by the radiation safety staff. The methods should include the preparation and issuance of radiation work permits for activities where SOPS do not apply.

5.2.4 Evaluation Findings if the staff's review, as described in this section, results in the acceptance of the management -

control program, the following conclusions may be presented in the TER.

The NRC has completed its review of the management control program proposed for use at the ISL facility, This review included an evaluation using the review procedures in SRP section 5.2.2 and the acceptance criteria outlined in SRP section 5.2.3.

The applicant has an acceptable management control program that assures that all activities can be conducted according to written operating procedures. The applicant has provided acceptable operating procedures or a process that will be used to develop standard operating procedures. The applicant has acceptably identined radiation protection, maintenance activities (especially in radiation areas),

development of well fie'ds, and SERP reviews as areas where SOPS are acceptable and correctly applied.

The applicant has demonstrated that nonroutine work or maintenance activity will comply with radiation safety requirements and has included, as one means of comparison, the issuance of radiation work permits for activities where SOPS do not apply, llased on the information provided in the application and the detailed review conducted of the.

management control program for the ISL facility, the NRC staff has concluded that the proposed management control program is acceptable and is in compliance with 10 CFR 20,1101, which dennes radiation protection program requirements; 10 CFR Part 20, subpart L, sections 2101-2110, which define requirements for record keeping; and 10 CFR Part 20, subpart M, sections 2201-2206, which present the requirements for reporting.

5.2.5 References Nuclear Regulatory Commission.1983. Infi)rmation Relevant to Ensurhg that Occupational Radiation Exposures at Uranium Mills will be as low as is Reasonably Achievable. Regulatory Guide &31.

Washington, DC: Nuclear Regulatory Commission, OfHee of Standards Development.

5.3 h!ANAGEhlENT AUDIT, INSPECTION, AND RECORD KEEPING PROGRAhl

.5.3.1 hianagement Audit and Internal Inspection Program NUREG-1569 5-4

Operations 5.3.1.1 Areas of Reslew The staff shall review the proposed management audit, internal inspection, and spill notincation progrr ns, including the frequencies, types, and scopes of reviews and inspections; action levels; corrective action measures; and spill notincation procedures; as well as the responsibilities of each participant. The staff shall also review the program for ensuring that employee exposures (to both airborne and extemal radiation) and efnuent releases are ALARA.

5.3.1.2 Review Proecdures The reviewer shall determine whether the proposed management audit, internal inspection, and spill notincation programs are acceptable to ensure the implementation of the proposed management control program and to ensure that employee exposures and ef0uent releases are ALARA.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and th, approach that should be used in evaluating amendments and renewal applications.

5.3,1.3 Acceptance Criteria The management audit, inspection and spill notincation programs are acceptable if : hey meet the following criteria:

(1) The proposed frequencies, types, and scopes of reviews and inspections; action levels; spill notincation procedures; and corrective action measures are determined to be acceptable to implement the proposed controls.

Acceptable programs for quam., inspection of embankment systems are described in Regulatory Guide 3.11 (Nuclear Regalatory Commission,1977).

Acceptable programs for annual ALARA audits are described in Regulatory Guide 8.31 (Nuclear Regulatory Commission,1983).

(2) The applicant has established a commitment to secure and maintain a contractual agreement for the disposal of ISL byproduct material at an NRC or Agreement State licensed facility. Continued yellowede production is contingent upon such an agreement unless such offsite disposal is demonstrated to be impractical or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual surveillance options.

(3) The application contains a commitment to report spills that are either: (1) greater than 10,000 gallons,(2) contains more than 20 kg Uranium, (3) more than 7 millicuries total activity from rads other than uranium, (4) any spill that leaves the site. The spill must be reported to the NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> by phone, and 30 days with a written report detailing the volume of the spill, hazardous constituents present, and correctise action taken to date.

5-5 NUREG-1569

Operations (4) A detailed review of record keeping and retention procedures is conducted using section 5.3.2 of the SRP.

(5) The SERP records will include written safety and environmental evaluatior.s made by the SERP that provide the basis for determining whether changes were mt.de in accordance with the bases described in section 5.2.3.

4 The applicant has made provisions to fumish an annual report to the NRC that includes a description of these changes, tests, or experiments, and a summary of the safety and environmental evaluation for each. In addition, the licensee has made provisions to annually submit change pages to the NRC for the approved application and/or the approveu operations plans and reclamation plan.

The annual SERP report and page changes may be furnished along with reports nomially submitted to satisfy IC CFR 40.65 reporting requirements.

5.3.1.4 Evaluation Findings if the staff's review, as described in this section, results in the acceptance of the management audit, inspection, and spill notification programs, the following conclusions may be presented in the TER.

The NRC has completed its review of the management audit, inspection, and spill noti 6 cation programs proposed for use at the ISL facility. This review included an evaluation using the review procedures in SRP section 5.3.1.2 and the acceptance criteria outlined in SRP section 5.3.1.3.

The applicant has acceptable management audit, inspection, and spill notification programs, that provide frequencies, types, and scopes of reviews and inspections; action levels; and corrective actian measures sufucient to implement the proposed actions. The applicant has established acceptable record control procedures that insure maintenance of all records until license termination. The applicant has acceptably demonstrated that it will record and report spills of hazardous materials at the site in an accurate and timely manner. The applicant will fumish an annual, written report to the NRC that provides the bases for any changes in the approved management audit, inspecJon, and spill noti 0 cation prcgrams along with any appropriate change pages.

Based on the information provided in the application and tl.e detailed review conducted of the management audit, inspection, and spill nctincation programs for the ISL facility, the NRC staff has concluded that the proposed programs are acceptable and are in compliance with 10 CFR 20.1101, which dennes radiation protection program requirements; 10 CFR 20.1501, which contains the general requirements for surveying and monitoring; 10 CFR 20.1204 wMch is the procedures for detemiining individual exposure; 10 CFR 20.1702 which requires the use of process or other engineering measures to control the concentrations of radioactive material in the air; 10 CFR Part 20, subpart L, ,

sections 2101-2110, which define requirements for record keeping; 10 CFR Part 20, subpan M, sections 2201-2206, which present the requirements for reporting; and 10 CFR 40 Appendix A, Criterion 2 (the i applicant should provide an estimate of the amount of contaminated material that will be generated and l NUREG-1569 5-6 i

f Operations

objective lcvidence of an agreement for' disposal of these materials either in a licensed waste disposal site'

? or at a licensed mill tailings facility to demonstrate non proliferation of waste disposal sites).-

5.3.1.5 References ,

Nuclear Regulatory Commission.1977. Design, Construction, and Inspection of Embankment Retention Systems for Uranium Mills. Regulatory Guide 3.11. Washington, DC: Nuclear Regulatory Commission, Office of Standards Development.

Nu. .c Regulatory Commission.1983. Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills will be as hw as is Reasonably Achievable. Regulatory Guide 8.JL

.Washington, DC: Nuclear Regulatory Commission, Office of Standards Development.

5.3.2 Record Keeping and Record Retention 5.3.2.1 Areas of Review The staff shall review the applicant's record keeping plans for the materials control and tracking program; the radiation protection program; the sampling, surveys, and calibrations programs; for planned special exposures; to track doses to workers and members of the public; for the disposal of source, and byproduct materials made under 10 CFR 20.2002,20.2003,20.2004, and 20.2005; and for the records important to decommissioning the facility including records of spills or unusual occurrences involving the spread of contamination, cleanup actions taken, and the locatiu of remaining contamination. The staff shall also review the licensee's plans and arrangements to identify and maint m the records that must be retained for the life of the facility and ultimately transferred to the NRC at the termination of the license.

5.3.2.2 Review Procedures The reviewer shall determine whether the proposed record keeping programs are adequate to ensure that the licensee will be able to track, control, and demonstrate control of, the source and byproduct material produced at the site, such that onsite and ofTsite dose limits will not be exceeded. The reviewer shall determine whether records impoitant to decommissioning and establishing annual surety amounts, such as descriptions of spills and other unusual occurrences will be maintained by the licensee, and are in an identifiable, or pieferably, separate file. The reviewer shall also determine whether the licensee has a plan to maintain the records that will be tumed over to the NRC prior to license termination.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.3.2.3 Acceptance Criteria p _ . The licensee's record keeping and record retention plans shall be acceptable if they meet he following criteria:

5-7 NUREG 1569 i' i 1

l l -

l

Operations (1) The record keeping requirements specified in the Regulatory Guides cited in the other sections of the SRP are met.

(2) The record Leeping plan demonstrates that the licensee will maintain and retain records of the receipt, transfer, and disposal of any source or byproduct material processed or produced at the licensed facility, for the period set out in the licensee's license conditions, or until the Commission terminates the license.

(3) The following will be routinely maintained, and retained for the operating or licensed life of the ISL facility as a permanent site record.

(a) Records of onsite disposal made under section 10 CFR 20.2002, 20.2003, 20.2004, and 20.2005 (b) Records required by section 20.2103(b)(4)

(c) Records containing information important to decommissioning and reclamation of an ISL including:

(i) Descriptions of any spills, excursions, contamination events or unusual occurrences, including the dates, locations, areas or facilities affected, assessments -of hazard, cleanup actions taken, assessment of the efTectiveness of cleanup, and the location of any remaining contamination; nuclides involved, quantities, forms and concentrations, and descriptions of nonradioactive hazardous constituents; and descriptions ofinaccessible areas that can not be cleaned up; sketches, diagrams, or drawings marked to show areas of contamination and places where radionuclide, radiation, and other measurements were made.

(ii) Information related to site characterization, residual soil contamination levels, onsite locations used for burials of radioactive materials, hydrology and geology with panicular emphasis on problem areas that could contribute to groundwater or surface water contamination, locations of

. evaporation ponds, wa te water ponds, lagoons, and well field aquifer anomalies.

(iii) As built drawings or photographs of structures, equipment, rr.stricted areas, well fields, areas where radioactive materials are stored, and any modifications showing the locations of these structures and systems through time.

(iv) Drawings of areas of possible inaccessible contamination including features such as buried y, pes or pipelines.

- NUREG 1569 3.g

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. Operations

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(v) Information on previously used work sites that are inactive at the time of decommissioning, including information on general radioactive materials l and locations. '

1 (vi) The baseline history of background radiation levels at the site. ,

These records will be kept in an identinable, and preferably separate file.

(4) ne licensee demonstrates that those records described in (iv) can be provided to a new owner or new licensee in the event that the property or license is transferred, or to the NRC prior to license termination.

(5) New licensees or owners indicate that any such records received from the previous owner or licensee will be retained along with their own records to be turned over to the NRC prior to license termination.

(6) Records will be maintained as hard copy originals, as copies on microfiche or electronically will be protected, and will be readily retrievable for NRC inspection.

5,3.2.4 Evaluation Findings If the stafrs ieview, as described in this section, results in the acceptance of the record-keeping and record retention program, the following conclusions may be presented in the TER.

The NRC has completed its review of the record-laeping and record retention program nroposed for use at the ISL facility. This review included an evaluation using the review procedures in SRP section 5.3.2.2 and the accep;ance criteria outlined in SRP section 5.3.2.3.

The applicant has proposed an acceptable record keeping and record retention program that shall be adequate to ensure that the licensee is be able to track, control, and demonstrate control over the source and byproduct materials that are processed, produced, or stored at the facility during its operating life, through decommissioning, and to license termination. The record-keeping plans are demonstrated to assist the applicant in ensuring that both onsite and otTsite exposures are kept within regulatory limits, and in documenting compliance with regulations. The applicant has demonstrated and acceptable program to maintain records on spills, potential contamination events, and unusual occurrences for use in calculating annual surety amounts and to ensure complete decommissioning. The applicant has demonstrated an awareness of, and a commitment to the long term need to maintain records on decommissioning, onsite and offsite disposal, and offsite releases of radioactivitv, as a permanent record for the facility that will be transferred to any new owner or licensee, and then ultimately to the NRC prior to license termination.

Based on the infomiation provided in the application and the detailed review conducted of the proposed record-keeping and record retention program for the ISL f >cility, the i NRC stalT has concluded that the proposed record-keeping and record retention plans are acceptable and I' are in compliance with 10 CFR Part 20, subpart L, which defines requirements for record-keeping:

10 CFR Part 40.61(d) and (c) which also define requirements for record-keeping; and 10 CFR 40 (36)(f) which defines the records important t,. commissioning.

l 5-9 NUREG-1569

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i Operations 5.3.2.5 Refmaces None.

5.4 QUALIFICATIONS 5.4.1 Areas of Review The staff shall review descriptions of the minimum qualifications and experienu levels required for personnel who will be assigned the responsibility for developing, conducting, and administering the radiation safety program. The staff shall also review the qualifications of people specifically proposed for these positions.

5.4.2 Review Procedures The reviewer shall detennine w hether the minimum qualifications and experience levels required <

for personnel uho will be assigned the responsibility for developing, conducting, and administering the ,

radiation safety program are sufficient to meet the regulatory requirements. The staff shall also determine ,

that the qualifications of people specifically proposed for these poaltions are consistent with the minimum qua!!fications and experience lesels. i For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.4.3 Acceptance Criteria ,

The qualifications of radiation safety personnel are acceptable if they meet the following criteria:

(1) The personnel meet minimum qualifications and experir nce far radiation safety staff that are consistent with Regulatory Guide 8.31 (Nuckar Regulatory Commission,1983), The emphasis of this guidanco is for uraniun mills; however, the training requirements apply equally to ISL facilities.

5.4.4 Evaluation Findings (J If the staffs review, as described in this section results in the acceptance of the qualifications '

of facility personnel conducting the radiation safety p ogram, the following conclusiors may be presented in the TER.

' The NRC has completed its review ot tbc qualifications of facility personnel conducting the

= radiation safety' program at the ISL facility. This review included an evaluation using the review procedures in SRP section 5.4.2 and the accen snce criteria outlined in SetP section 5.4.3.

NUREG 1569 5 10

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i Operations I i

The qualifications of personnel conducting the radiation safety program at the ISL site are acceptable as they meet the requirements of NRC Regulatory  :

t Guide 8.31.

Ilased on the information provided in the application and the detailed review conducted of the l

quali0 cations of the personnel conducting the radiation safety program for the ISL facility, the NRC staff has concluded that the quallucations of the personnel are acceptable and are in .l'

< compliance with 10 CFR 20.1101, which dennes radiation protection program requirements.

t i

5.4.5 References Nuclear Regulatory Commission.1983. Information Relevant to Ensuring that occupational Radiation Exposures at Uranium Mills will be as low as is Reasonably Achievable. Regadutory Guide 8.J/.

Washington, DC: Nuclear Regulatory Commission, Office of Standards Development,

< t 5.5 TRAINING l 5.5.1 Areas of I;eview ,

t The stalT shall review the proposed employee radiological protection training program, including  ;

the content of the initial training or indoctrination, testing, on the job training, and the extent and t frequency of retraining. This material will most likely be presented as an appendix to the application.1he stafT shall also review the proposed written radiological safety instructions that will be provided to employees to include personal hygiene, contamination surveying prior to cating or leaving the operating area, requirements for personal monitoring devices and respirators, housekeeping requirements, spill cleanup procedures, and emergency actions.

5.5.2 Review Procedures lhe staff shall determine whether the applicant has procedures for an employee radiological protection training program that are adequate to provide radiological safety instructions to the employees. ,

lhe staff shall also determine whether the proposed written radiological safety instructions that will be provided to employees are sufliciently detailed to meet acceptance criteria identified in section 5.53. ,

I or license renewals and amendment applications. appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.5.3 Acceptance Criteria The training program is acceptable if it meets the following criteria:

(1) It is consistent with the approach described in Regulatory Guide 831 (Nuclear Regulatory Commission,1983).

NUREG 1569 l 3.l}

Operations This guide recommends that before hepinning their jobs, all new employees should be instructed by means of an established course in the inherent risks of exposure to radiation and the fundamentals of protection against exposure to uranium and its daughters.

(2) It is consident with Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure (Nuclear Regulatory Commission,1987).

This guide provides guidance for protection of the fetus.

(3) 11 is consistent with Regulatory Guide 8.29, instruction Concerning Risks from Occupational Radiation Exposure (Nucleer Regulatory Commission,1981).

1his guide provides a basis for training en'ployees on the risks from radiation exposure in the work place.

5.5.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the radiological protection training program for personnel, the following conclusions may be presented in the TER.

The NRC has completed its review of the radiological protection training program for personnel conducting the radiation safety program at the ISI, facility. This review included an evaluation using the review procedures in SRP section 5.5.2 and the acceptance criteria outlined in SRP section 5.5.3.

The radiological protection training program for personnel at the ISL site adheres to the guidance and acceptable approaches contained in NRC Regulatory Guides 8.31 (Nuclear Regulatory Commission, 1983), 8.13 (Nuclear Regulatory Commission,1987), and 8.29 (Nuclear Regulatory Commission,1981). The content of the training material, testing, on the job training; and the extent and ficquency of retraining are acceptable. Acceptable wri' ten safety instructions for employees have been produced.

Ilased on the infonnation provided in the application and the detailed review conducted of the radiological protection training program for personnel for the ISL facility, the NRC stafT has concluded that the radiological training program is acceptable and is in compliance with 10 CFR 20.1101, which defines radiation protection program requircraents.

5.5.5 References Nuclear Regulatory Commission.1981. Instruction Concerning Risks from occupational Radiation Exposure. Regulatory Guide &29. Washington, DC: Nuclear Regulatory Commission, Ollice of Standards Development.

NUREG 1569 5 12 1

l r

Operations f

i Nuclear Regulatory Commission.1983. Information Relevant to Ensuring That Occupational Radiation l Exposures at Uranium Mills Will be as low as is Reasonably Achievable. Regulatory Guide & J/.  ;

Washington, DC: Nuclear Regulatory Commission, Of0cc of Standards Development. j Nuclear Regulatory Commission.1987. Instruction Concerning Prenatal Radiation Exposure, Revision 2.  ;

Regn/utoryGuide & /J Washington, DC: Nuclear Regulatory Commission,Omce of Standards t

Des elopment.

5.6 SECURITY  :

5.6.1 Areas of Review The staff shall review the security measures proposed to prevent unauthoriied entry into the f controlled area. j 5.6.2 Review Procedures [

l The staff shall determine whether the proposed security measures are sumcient to prevent unauthorized entry into the controlled area in accordance with regulatory requirements in 10 CFR Part 20, ,

subpan1. <

For license renewals and amendment applications, appendix A to this standard review plan (SRP) ,

provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.6.3 Acceptance Criteria The security program will be acceptable if the anplicant has acceptable passive controls, such l as fencing for well Gelds, and active controls, such as daily inspections and locks for plant buildings.

5.6,4 Evaluation Findings '

If the staffs review, as described in this section, results in the acceptance of the security measures, the following conclusions may be presented in the TER. 1 The NRC has completed its review of the security meuures at the ISL facility. This review included an evaluation using the review procedures in SRP section 5.6.2 and the acceptance criteria outlined in SRP section 5.6.3. >

The security measures at the ISL demonstrate that the applicant has acceptable active and passive constraints on ingress to the licensed and restricted areas. The applicant has identified acceptable reasonable passive controls including barbed wire fencing, locked gates, and warning signage for site control and active security systems for buildings. The applicant will check daily to verify s the integrity of the security system, 5 13 NUREG-1569 I

. , - - - , , , . - - . - , - . - . . . - - - . . - - . . - - . - - . . ~ . ~ . - . - . . - - - - . -

_. _. . __- _ _ _ _ _ _ _ _ . _ _ . - _. . _ _ . _ _ ~ _ _ _

i l

a Operations I ased on the information prosided in the application and the detailed review conducted of the security measures for the ISI, facility, the NRC staff has concluded that the security measures are acceptable and are in compliance with 10 CFR Part 20. subpart I whsch deals with the i

security of stored material and control of material not in storage.

i 5.6.5 References i

None. i 5.7 RADIATION SAFETY CONTROLS AND MONITORING .

5.7.1 Emuent Control Techniques  ;

5.7.1.1 Areas of Review The 61aff shall res lew descriptions of the systems and procedures (e.g.. ventilation, confinement, a filtration) designed to minimite in plan and environrnental emissions at each step of the process where releases might occur. Major airbome radioactive effluents include radioactive particulates (from drying and packaging areas) and radon gas emanating from production solutions. Radon gas mobilization can occur fmm recovery solutions at process locations where systems allow venting, Staff shall evaluate ,

effluent control systems for uranium particulate emissions located in drying and packaging areas and in any other areas where release of significant quantities of uranium particulate is a concern. Closed systems can climinate releases of uranium particulates and radon gas. For example, the use of vacuum packaging equipment has been shown to climinate uranium releases from packaging operations.

Common liquid effluent sources are process bleed, process solutions (e.g., backwash, resin transfer waters), and washdown water, Staff shall review the facility design for containment of  !

contamination from spills resulting from nonnal operations and probable accidents (e.g, tank valve or pipe i i

joint failure), Staff shall also review evaporation pond engineering design to ensure proper containment perfonnance, and evaluate leak detection and monitoring systems for ponds containing contaminated ellluents.

Staff reviews shall include minimum pe formance specifications such as filtration or scrubber efliciency and ventilation airflow at their reasonably expected best performance and the frequency of tests and inspections to ensure that these specifications are being met.

The staff shall review contingency plans and notification requirements to be implemented in the event of equipment failures, spills, or excursions.  ;

5.7.1.2 Reglew Procedures l

The stair shall determine whether the proposed safety controls and monitoring procedures are sufficient to limit radiation exposures and radioactive releases to ALARA and to ensure conformance with regulatory requirements identified in 10 CFR Part 20.

1 L

NUREG-1569 3 1,; ,

i Operations in general, the staff should be familiar with Regulatory Guide 8.10, Operating Philosophy for Maintaining occupational Radiation lixposures as low as is Reasonably Achiesable (Nuclear Regulatory Commission,1977). Additional guidance is found in Regulatory Guide 8.37. ALARA Lesels for IIH1uent from Materials facilities (Nuclear Regulatory Commission,1993), Regulatory Guide 8.31 (Nuclear Regulatory Commission,1983), and Regulatory Guide 3.56 General Guidance for Designing, Testing, Operating, and Maintaining limissionContiof Doices at Uranium Mills (Nuclear Regulatory Commission.  !

1986). The staff shall detennine whether ',he proposed systems and procedures (e.g., sentilation, confinement, filtration) are acceptably described and sullicient to control in plant and ensironmental emissiorts at each Step of the process where releases might occur. Staff shall ensure that minimum performance speci0 cations for sentilatioa, Oltration, and confinement sptems throughout the recovery plant and laboratories are provided and are consistent with assumptions made in exposure estimates for areas of the facility where the splems are operating. Staff should also check that the frequencies of equipment tests and inspections are consistent with manufacturer's recommendations to ensure that these specifications are being met. Contingencies for equipment failures, maintenance shutdowns, and spills shall be reviewed to ensure procedures are in place io maintain exposures ALARA.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance Ibr examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.7.1.3 Acceptance Criteria The radiation safety controls and monitoring program (br cHluents is acceptable if it meets the following criteria:

(1) Radon gas Dom processing tanks within enclosed buildings is properly controlled.

litrectise control of radon gas can be achiesed by use of a pressurized processing tank system that eliminates venting in process buildings or by using appropriate ventilation sptems in buildings where radon gas senting is expected.

(2) Yellowcakn emissions from drying operations are properly controlled.

Acceptable control of yellowerke emissions from the dryer is achieved by meeting the criteria of Regulatory Guide 3.56 (Nuclear Regulatory Commission,1986).

(3) Release of liquids into surface waters must comply with the public dose limits in 10 CFR 20.1301 which may be demonstrated by one of the following methods:

(a) Ihe licensee demonstrates compliance with 10 CFR Part 20, appendis 11 by one of the following methods and shows that if an individual were continuously i present in an unrestricted area, the dose from esternal sources would not exceed 2 mrem /hr or 50 mrem /3 r:

(i) Showing that the discharge of efiluent from any holding pond is within 10 CI'R Part 20, appendis 11 limits at the point of discharge. I or waste 5 15 NURiiG-1569

Operations water where processing and mining water are mingled, the licensee must i

demonstrate compliance with applicable requirements for both was:e water streams.

(ii) Monitoring the incoming process or water to demonstrate compliance with the emuent discharge requirements of 10 CFR Part 20 appendix 11 for process water and 40 CFR Part 440 for mine water, (b) The licensee demonstrates that the total effective dose equivalent to the individual likely to receive the highest dose from the facility does not exceed the annual dose limit for the public.

(4) The applicant describes minimum perfonnance specifications for the operation of the emuent control systems and the frequencies of tests and inspections to ensure proper performance to specifications. Details of acceptable excursion control tech,iques are found in section S.7.8.3 of the SRP.

Acceptable methods for testing, maintenance, and inspection of emuent control systems are given in Regulatory Guide 3.56 (Nuclear Regulatory Commission,1986).

(5) Record keeping for the emuent control system is sumcient to meet requirements in 10 CFR 20.2103(b)(4).

(6) The applicant describes emergency procedures in the event of equiprnent failures or spills, references existing emergency procedures, or commits to the development of emergency pmcedures.

Acceptable emergency procedures are outlined in Regulatory Guide 3.56 (Nuclear Regulatory Commission,1986).

For license renewal applications, the historical emuent control program results are included through the most recent reporting period preceding the submittal of the application.

The effectiveness of the historical program should be discussed with recard to all applicable 10 CFR Part 20 regulatory requirements identified in the preceding paragraphs.

Long-term trends should be discussed,and any short tenu deviations from the long tenn l trend should be explained.

(7) The emuent control techniques are designed to keep exposures to members of the public I

Al. ARA as described in Regulatory Guide 8.37 (Nuclear Regulatory Commission,1993).

5.7.1.4 F. valuation Findings if the stalTs review, as described in this section, results in the acceptance of the radiation safety contmis and monitoring for emuents, the following conclusions may be presented in the TER.

NUREG 1569 3 16

Operations The NRC has completed its review of the radiation safety controls and monitoring program for efUuents at the ISL facility. This review included an evaluation using the resiew procedures in SRP section 5.7.l.2 and the acceptance criteria outlined in SRP section 5.7.l.3.

The applicant has an acceptable radiation safety controls and monitoring program for efUuents at the ISL site and has demonstrated that important effluent streams are controlled and monitored. 'Ihe applicant has used an acceptable pressurized processing tank system and appropriate sentilation systems in buildings where radon gas is sented. Acceptable control of the yellowcake dryer system is evidenced by a vacuum dryer and other appropriate padiculate scrubber equipment on the dryer stack. The applicant has shown that the discharge of process water is within the dose limit of 10 CFR 20.1301 and the discharge of mine water is within 40 CFR Pan 440 limits. The applicant has demonstrated acceptable ellluent control systems and associated test and inspection frequencies to ensure specified performance. Record keeping procedures are acceptabic. Acceptable emergency procedures for handling equipment failures or spills are identined by the applicant.

liased on the infomiation provided in the application and the detailed review conducted of the radiation safety controls and monitoring program for effluents at the ISL facility, the NRC staff has concluded that this program is acceptable and is in compliance with 10 CFR 20.1301, which provides dose limits for members of the public; 10 CFR 20.110'. w hich dennes radiation protection program and ALARA requirements; 10 Cl R 20.1201(a) which provides occupational dose limits; and 10 Cl R Pad 20, subpart M, which tiefines requirements for reports. An evaluation of proposed elDuent control techniques is contained in section 5.7.1.3 of this SRP.

5.7.1.5 References Nuclear Regulatory Commission.1977. Operating Philosophy for Maintaining occupational Radiation Exposures as low as is Reasonably Achievable, Resision 1 R. Regulatory Guide 8 /0.

Washington, DC: Nucicar Regulatory Commission, Of 0ce of Standards Desclopment.

Nuclear Regulatory Commission.1983. Information Relesant to Ensuring that occupational Radiation Exposures at Uran.um Mills will be as low as is Reasonably Achievable. Regulatorr Guide K 3/.

Washington, DC: Nuclear Regulatory Commission OlUce of Standards Deselopment.

Nuclear Regulatory Commission.1986. General Guidance for Designing Testing, Operating, and Maintaining Emission Control Devices at Uranium Mills. Regulatory Guide 3R Washington, DC: Nuclear Regulatory Commission, Of0cc of Standards Desclopment.

Nuclear Regulatory Commissmn.1993. ALARA l es els for Efnuent from Materials Facilities. Regulatory Guide K37 Washington, DC: Nuclear itegulatory Commission.

5.7.2 External Radiation Exposure Monitoring Progratn 5.7.2.1 Areas of Review 5 I7 NUREG-1569

Operations l he staff shall res icw sun e) methods. instrumentation, and equipment for detennining exposures of employees to external radiation during routine and nontoutine operations, maintenance, and cleanup actisities.1his review shall include the types of suneys conducted, criteria for deten aining suncy locations, frequency of sun cys, action les els, management audits, and correctis e action requirements. Staff shall also review the program for personal monitoring (using film badges) including the criteria for including workers in the program, the sensitivity and range of desices used, and calibration frequency and methods.

5.7.2.2 Heview Procedures W The stafT shall determine w hether the safety controls and monitoring procedures proposed by the applicant are sufficient to limit radiation exposures and radioactive releases to ALARA and are in confonnance with regulatory requirements identified in 10 CFR Part 20. The staff shall determine whether proposed monitoring methods, instrumentation, and equipment are sufficient to meet the regulatory requirements for determining the exposures of employees to external radiation (10 Cl R 20.1203). In conducting their review, the staff shall ensure that the applicant has provided one or more charts that identify the facility layout and the location of monitors for external radiation as well as providing acceptable criteria for detennining the sampling locations. StafT shall ensure all monitoring equipment shall be identified by type with additional specification of the range, sensitivity, calibration methods and frequency, availability, and planned use. Staff shall ensure that the proposed monitoring program is sullicient to adeqt.aiely protect workers from haards of beta radiation (skin, extremity, lens of c>e) resulting from the decay products of U 238 when effectise shielding is not present (e g., maintenance operations). The stalf shall also ensure that the monitoring program is acceptable to detect and control gamma radiation from uranium decay products in areas where large volumes of uranium may be present (e g., processing tanks, yellowcake storage areas).

For license renew als and amendment applications, appendix A to this standard review plan (SRp) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.7.2.3 Acceptance Criteria The external radiation exposure monitoring program is acceptable if it meets the following criteria:

(1) The application contains one or more charts that depict the facility layout and the location of monitors for extemal radiation and provide acceptable criteria for detennining the sampling locations which are consistent with Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980).

(2) 'Ihe application pros ides criteria to be used in establishing which employ ees are to receis e external exposure monitoring. These criteria are consistent with Regulatory Guide 8.34 (Nuclear Regulatory Commission,1992).

(3) Monitoring equipment is identified t y type, specification range, sensitisity, calibration methods and frequency, availability, and planned use to protect health and safety and the NUREG 1569 5,ig

Operations environment. 'lhe application also demonstrates that the ranges of sensitivity are those expected from the facility operation.

(4) All monitoring equipment has a lower limit of detection which allows measurement of 10 percent of the applicable limits. Planned suncys of external radiation are consistent with the guidance in Regulatory Guide 830 (Nuclear Regulatory Commission,1983).

(5) Plans for documentation of radiation exposures are consistent with the approach in Regulatory Guide 8.7 (Nuclear Regulatory Commission,1982).

(6) The application presents levels for correctise action that are consistent with the 10 Cl R Pan 20 regulatory requirements.

(7) Radiation doses will be kept ALARA by following Regulatory Guide 8.10, Operating Philosophy for Maintaining occupational Radiation Exposure As Low As Reasonably Achievable (Nuclear Regulatory Commission,1980) and Regulatory Guide 8.31 (Nuclem Regulatory Commission,1983).

(8) The applicant monitoring program is sufficient to adequately protect workers from hazards of beta radiation (skin, extremity, lens of eye) resulting from the decay products of U.238 when effective shielding is not present (e.g., maintenance operations) and is consistent with Regulatory Guide 8.30 (Nucleer Regulatory Commission,1983).

(9) The monitoring program is suflicient to detect and control gamma radiation from uranium decay products in areas where large volumes of uranium may be present (e.g., processing tanks, yellowcale storage areas) and is consistent with Regulatory Guide 830 (Nuclear Regulatory Commission,1983).

(10) The program for external exposure monitoring and detennining doses from external exposure are consistent with Regulatory Guide 8.34.

5,7,2,4 Evaluation Findings if the stalTs review, as described in this section, results in the acceptance of the external radiation exposure monitoring program, the following conclusions may be presented in the TER.

The NRC has completed its review of the external radiation exposure monitoring program at the ISL facility. This review included an evaluation using the review procedures in SRP section 5.7.2.2 and the acceptance criteria outlined in SRP section 5.7.23.

The applicant has an acceptable external radiation exposure monitoring program at the ISL site. The applicant has provided an acceptable chart (s) that depicts the facility layout and the location of eMemal radiation monitors. The external radiation monitors are acceptably placed. 'the applicant has establi4ed appropriate criteria to determine which employees should receive estemal radiation monitoring. The applicant has demonstrated that the range, sensitivity, and calibration of external radiation monitors will support protection of health and safety of employees during the full l

s.19 NUREG 1569 l

Operations range of facility operations. All planned radiation surveys are adequate. Planned documentation of radiation exposures is acceptable:. The applicant's monitoring is acceptable to protect workers from beta and gamma radiation.

liased on the infonnation provided in the application and the detailed review conducted of the external radiation exposure monitoring program at the ISL facihty, the NRC stafT has concluded that the external radiation exposure monitoring program is acceptable and is in compilance with 10 Cl R 20.1101, which defines a radiation protection program and ALARA requirements; 10 CI R 20.1201(a), which dcEnes occupatior.al dose limits; 10 CFR 20.1203, which provides limits for doses from airborne extemal radiation; 10 CI'R 20.1501, which prosides requirements of suncying and radiation monitoring; 10 CFR 20.1502, which defines conditions requiring individual monitoring of external dose; 10 Cl R Part 20, subpan L, which specifies records keeping requirements; and 10 Cl R Part 20, subpan M, which deals defines reponing requirements.

5.7.2.5 References Nuclear Regulatory Comminion.1977. Operating Philosophy for Maintaining Occupational Radiation Exposures As 1.ow As is Reasonably Achievable. Regulatory Guh/c &lo. Washington, DC:

Nuclear Regulatory Commission, Office of Standards Development.

Nuclear Regulatory Commission.1980. Radiological EfHuent and Environmental Monitoring at Uranium Mills. Regulatory Guide 4 /4. Washington, DC: Nuclear Regulatory Commission, Office of Standards Development.

Nuc! car Regulatory Commission.191'2. Instructions for Recording and Reponing Occupational Radiation Exposure Data, Revision 1. Regulatory Guhle &7. Washington, DC: Nuclear Regulatory Commission Ollice of Standards Development.

Nuclear Regulatory Commission.1983. Ilealth Physics Surveys in Uranium Mills. Regulatory Guide &30.

Washington, DC: Nuclear Regulatory Commission, Ollice of Standards Development.

Nuclear Regulatory Commission.1992. Monitoring Criteria and Methods to Calculate Oecupational Radiation Doses. Regulatory Guide &J4. Washington, DC: Nuclear Regulatory Commission.

Ollice of Standards Development.

5.7.3 Airborne Radiation Monitoring Program 5.7.3.1 Areas of Resiew The staff shall review the proposed airborne radiation monitoring program to determine concentrations of airborne radioactive materials (including radon) during routine and nonroutine operations, maintenance, and cleanup. This review shall include criteria for determining sampling locations and sampling frequency with respect to process operations and personnel occupancy, as well as analytical procedores and sensithity and instrument calibration requirements. Action levels, audits, and corrective NUREG 1569 5-20

Operations action requirements shall also be esaluated. This information may be presented in an appendix to the application.

5,7,3.2 Reilew Promiures The stafT shall detennine whether the safety controls and rnonitoring procedures proposed by the applicant are suflicient to limit radiation exposures and radioactive releases to ALARA and are in conformance with regulatory requirements identiDed in 10 CFR Part 20. The staff steall evaluate whether the proposed sampling program to determine concentrations of airborne radioactive materials (including radon) during routine and nontoutine operations, ma:ntenance, and cleanup is in conformance with the regulatory requirements identiDed in 10 CFR 20.1501,10 CFR 20.1502,10 CFR 20.1204 and the other applicable acquirements listed in section 5.7.3.3, For license renewals and amendment applications, appendix A to this standard review plan (SRP) prmides guidance for examining facility operations and the appemch that should be used in evaluating amendments and renewal applications.

5,7.3.3 Acceptance Criteria The airbome radiation monitoring program is acceptable if it meets the following criteria:

(1) The applicant provides one or more charts that depict the facility layout and the location of samplers for airbome radiation. Locations are based, in part, on a determination of air 0ow pattems in areas where monitoring is needed, and determination of monitoring locations is consistent with Regulatory Guide 8.25, Air Sampling in the Workplace (Nuclear Regulatory Commission,1992).

(2) Monitoring equipment by type, speci0 cation range, sensitivity, calibration methods and frequency, availability, and planned use will protect health and safety and the environment. The application also demonstrates that the ranges of sensitivity are those expected from the facility operation.

(3) Planned surveys of airborne radiation are consistent with the guidance in Regulatory Guide 8.25 (Nuclear Regulatory Commissien,1992) and Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983a).

(4) The proposed monitoring program is sulTicient to adequately protect workers from radon gas releaws from venting of processing tanks and from yellowcake dust from drying operations, spills, and maintenance activities and it consistent with Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980). The air sampling program is consistent with Regulatory Guide 8 25 (Nuclear Regulatory Commission, 1992) and Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983a).

(5) Plans for documentation of radiation exposures are consistent with the requirements in 10 CFR 20.2102,10 Ci R 20.2103,10 CFR 20.2106, and 10 CFR 20.2110.

5 21 NUREG 1569

Opuations (6) The applicant demonstrates that respirators will routinely be used for operations within drying and packaging areas and identines the criteria for determining when respirators '

will be required for special job or emergency situations. The respiratory protection program should be consistent with guidance in Regulatory Guide 8.15 Acceptable Programs for Respiratory Protection (Nuclear Regulatory Commission,1976) and Regulatory Guide 8.31 (Nuclear Regulatory Commission,1983b).

(7) For license renew al applications, the historical results of the airborne radiation monitoring program are included through the most recent reporting period preceding the submittal of the application. The effectiveness of the historical program is discussed with regard to all applicable 10 CFR Part 20 regulatory requirements identified in the preceding paragraphs.

Long term trends are discussed, and any short tenu deviations from the long tenn trend are explained.

5,7.3.4 Evaluation findings if the staffs review, as described in this section, results in the acceptance of the airborne radiation monitoring program, the following conclusions may be presented in the TER.

The NRC has completed its review of the airborne radiation monitoring program at the

_lSL facility. Thir review included an evaluation using the review procedures in SRP section 5.7.3.2 and the acceptance criteria outlined in SRP section 5.7.3.3.

The applicant has an acceptable airborne radiation monitoring program at the

_ ISL site. The applicant has provided an acceptable chart (s) that depicts :he facility la)out and the location e rairborne radiation monitors. The airborne radiation monitors are acceptably placed. The applicant demonstrated that the range, sensitivity, and calibration of monitors of airborne rrdiation will support protection of the health and safety of employees during facility operations. The workers are acceptably protected from radon gas releases from venting of processing tanks and from 3cllowcake dust from drying operations, spills, and maintenance activities. Planned radiation surveys are acceptable. Planned documentation of radiation exposures is consistent with the requirements. The applicant'a respiratory protect *on program is acceptable. The applicant's program for monitoring of uranium and sampling of radon or its daughters is acceptable and the results of this monitoring will be used for employee exposure calculations.

Ilased on the infonnation provided in the application and the detailed resiew conducted of the airborne radiation monitoring program at the ISL facility, the NRC staff has concluded that the airborne radiation monitoring program is acceptable and is in compliance with 10 CFR 20.1101, which dennes radiation protection program and ALAR A requirements; 10 CFR 20.1201(a), w hich provides individual occupational dose limits; 10 CFR 20,1201(c), which specines allowed intake of soluble uranium; 10 CFR 20.1202, which uescribes the means of compliance when summing internal and external doses; 10 CFR 20.1203, for detennination of dose from airborne extemal radiation; 10 CFR 20.1208, which speciGes the exposure limits to a fetus during pregnancy; 10 CFR 20,1702, w hich allow s employ ees to limit dose to individuals by controlling access, limiting exposure times, prescribing use of respiratory equipment, or use of other controls; 10 CFR Part 20, subpart L, which speci0es record-keeping requirements, and 10 CFR Part 20, subpart M, which prosides requirements for reports and noti 0 cation.

NUREG 1569 f 22

Operations 5.7.3.5 References Nuclear Regulatory Commission.1975 Acceptable Programs for Respiratory Protection. RegulatoryGuide

  1. li Washington, DC: Nuclear Regulator) Commission.OlDee of Standard 3 Deselopment.

Nuclear Regulatory Commis ion.1980. Radiological EfDuent and 1:nvironmental Monitoring at Uranium Mills. Regulatory Guide 4./4. Washington, DC: Nuclear Regulatory Commission. Office of Standards Desclopment.

Nuclear Regulatory Commission.1983a. Ilealth Physics Suncys in Uranium Mills. Regulatory Guide # 30. Washington, DC: Nuclear Regulatoty Commission OfUv of Standards Des clopment.

Nuclear Regulatory Commission.1983b. Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills will be As Low As Reasonably Achievable. RcgulatoryGuide 8.3/.

Washington. DC: Nuclear Regulatory Commission, Office of Standards Development.

Nuclear Regulatory Commission.1992. Air Sampling in the Workplace, Revision 1. Regulatory Guide #21 Washington. DC: Nuclear Regulatory Commission, Office of Standards Development.

5.7,4 Expostire Calculations 5.7.4.1 Areas of Review The staff shall review the procedures proposed to detennine the intake of radioactive materials by personnel in work areas where airbome radioactise materials could exist. This review shall include procedures for detennining exposures during routine and nonroutine operations, maintenance, and cleanup activities.

5.7.4.2 Review Procedures The stafT shall detennine w hether the safety controls and monitoring procedures proposed by the applicant are sullicient to limit radiation exposures and radioactive releum to ALARA and are in confonnance with regulatory requirements identified in 10 CFR Pan 20. Thc 4 shall evaluate whether the procedures proposed to detennine the intake of radioactive materials by persomwl in work artas u here airborne radioactive materials could exist are in accordance with 10 CFR 20.1204 and 20.1201. The resiew shall also place emphasis on the parameters used in exposure calculations to ensure they are representatise of conditions at the site. Estimation of airborne uranium concentrations shall take into accot.nt the maximum production capacity requested in the application and the anticipated efliciencies of airbome paniculate control systems described in section 5.7.1 of the SRP.

l'or license renewals and amendment applications, appendix A to this standard review plan (SRP) prmides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications, 5 23 NUREG 1569

Owrations ,

5.7.4.3 Acceldarwe Criteria The exposure calculations are acceptable if they meet the following criteria:

(1) The procedures proposed to detennine the intake of radioactive materials by personnel in work areas where airborne radioactive materials could exist are in accordance with 10 CFR 20.1204 and 20.1201.

(2) Exposure calculations for natural uranium are consistent with Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983a) and Regulatory Guide 8.31 (Nuclear Regulatory  :

Commission,1983b).  !

For natural uranium the 10 mg/wk limit for protection against kidney toxicity from 10 CFR 20.120l(e) is more limiting than the DACs provided in 10 CFR Part 20, appendix 11 for solubility classes D and W. The most conservative solubility class (Y) should be used in the absence of site specific solubility characterization results.

(3) For airborne radon daughter exposure, calculations are consistent with Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983a) and Regulatory Guide 8.34, Monitoring Criteria and Methods for Calculating Occupational Radiation Exposure (Nuclear Regulatory Commission,1992a). -

(4) Calculations for prenatal and fetal radiation exposure are consistent with Regulatory Guide 8.36. Radiation Dose to the Embryo / Fetus (Nuclear Regulatory Commission, 1992b).

(5) Exposure calculations are presented for routine operations, nonroutine operations, maintenance, and cleanup activities and are consistent with Regulatory Guide 8,30 (Nuclear Regulatory Commission,1983a) and Regulatory Guide 8.34 (Nuclear Regulatory Commission,1992a).

(6) Parameters used in exposure calculations are representative of conditions at the site and include the time-w eighted exposure that incorporates occupancy time and average airbome concentrations.

For example, the time of exposure may be arbitrarily set at 40 hr per week; however, workers at some facilities may regularly work longer shills. Iloth full-time and part time employees should be considered in these calculations.

(7) Estimation of airborne uranium concentrations takes into account the maximum production capacity requested in the application and the anticipated efliciencies of airbome particulate control systems described in sections 4,1 and 5.7.1 of the SRP.

(8) All reporting and record keeping of worker doses is done in conformance with Regulatory Guide 8,7 (Nuclear Regulatory Commission,1982) and 10 CFR 20.2103.

NUREG 1569 5 24

}

Operations (9) l'or license renewal applications, the historical results of radiation exposure calculations are included through the mal recent reponing period preceding the submittal of the application. The effectiseness of historical radiation exposure calculations is discussed with regard to applicable 10 Cl R Part 20 regulatory requirements.

5.7.4.4 F. valuation Findings if the stall's review, as described in this section, results in the acceptance of the exposure calculations, the following conclusions may be presented in the TER.

~lhe NRC has cornpleted its review of the exposure calculations at the ,. ISL facility. 'this review included an evaluation using the resiew procedures in SRP section 5.7.4.2 and tbc acceptance criteria outlined in SRP section 5.7.4.3.

1he applicant has provided acceptable techniques for exposure calculations at the ISL site. The applicant has provided procedures allowing detennination of intake of radioactive materials by personnel in work areas. The applicant's exposure calculations for natural uranium and airborne radon daughte: cxposure are acceptable and are in confonnance with the guidance in Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983a) and Regulatory Guide 8.34 (Nuclear Regulatory Commission,1992a). The applicant has acceptable procedures for calculating prenatal and fetal radiation exposures consistent with Regulatory Guides 8.13 (Nuclear Regulatory Commission,1987) and 8.36 (Nuclear Regulatory Commission,1992b). All exposure calculation methods for routine operations, nontoutine operations, maintenance, and cleanup activities are acceptable and are corisistent with Regulatory Guide 11.30 (Nuclear Regulatory Commission,1983a) and Regulatory Guide 8.34 (Nuclear Regulatory Commission,1992a). The applicant has used parameters that are representative of the site, such as using both full and part time workers in exposure calculations. The applicant has considered maximum production capacity and aralcipated emeiencies of airborne particulate control systems in providing procedures for exposure calculations. All reporting and record keeping is in conformance with Regulatory Guide 8.7.

liased on the information provided in the applicatio 4 and the detailed review conducted of the exposure calculations at the 15L facility, the NRC staff has concluded tha  : exposure calculations are acceptable and are in compliance with 10 CI R 20.1101, which defines radiati protection program requirements; 10 CI'R 20.120l(a) which specifies individual occupational dose limits; 10 CFR 20.1201(c) which defines allowed intake of soluble uranium; 10 CFR 20.1202 which deuribes the means of compliance when summing intemal and external doses; 10 CFR 20,1203 for determination of dose from airborne extemal radiation; 10 CFR 20.1204 which provides requirements for determination of intemal exposure; and 10 CFR 20.1208 which specifies the exposure limits for a fetus.

5.7.4.5 References Nuclear Regulatory Commission.1982. Instructions for Recording and Reporting Occupational Radiation lixposure Data. Revision 1. Regulatory Guide 8.7. Washington, DC: Nuclear Regulatory Commission, OfEce of Standards Development.

5 25 NUREG 1569

Operations Nuclear Regulatory Commission.1983a. Ilealth Phpics Surveys in Uranium hiills. Regularon-Guldc K 3R Wa ,hington, DC: Nuclear Regulatory Commissica, Office of Standards Des elopment.

Nuclear Regulatory Commission.1983b. Infonnation Relesant to Ensuring that Occupational Radiation Esposmes at Uranium hiills Will lic As 1 ow As is Reasonably Achiesable. Regulaton-Gulde A 3/. Washington, DC: Nuclear Regulatory Commission, Office of Standards Des clopment.

Nuclear Regulatory Commission.1987. Instruction Conctming Prenatal Radiation Exposure. Revision 2.

Regulatory Guide K 13. Washington, DC: Nuclear Regulatory Commission, Ofuce of Standards Des clopment.

Nucleat Regulatory Commission.1992a. hionitoring Criteria and hiethods To Calculate Occupational Radiation Doses. Regulatory Guide &34 Washington, DC: Nuclear Regulatory Commission, Oflice of Standards Desetopment.

Nuclear Regulatory Commission.1992b. Radiation Dose to the Embryo /retus. Regulatory Guide A36.

Washington, DC: Nuclear Regulatory Commission. Office of Standards Development.

5.7.5 liloassay Program 5,7.5.1 Arras of Review The stafT shall resiew descriptions of the bioassay program proposed to confirm results derived from the Airbome Radiation hionitoring Program (SRP Section 5,7.3)and the Exposure Calculations (SRP Section 5.7.4). StalT shall review the criteria for including workers in the bloassay program, the types and frequencies of liioassays perfonned, and action levels applied to the resuhs.

5,7,5,2 Heview Procedures The staff shall deternune whether the bioassay program proposed to confirm results detennined in the Airbome Radiation hionitoring Program (SRP Section 5.7.3) and the Exposure Calculations (SRP Section 5,7.4) is in confonnance with 10 CFR 20.1204,10 CFR 20.1202,10 CFR 20.1201 and 10 CI'R Part 20, appendis 11. Staff shall resiew the bmassay program to ensure that it is consistent with applicable sertions of Regulatory Guide 8.22, liioassay at Uranium Mills (Nuclear Regulatory Commission,1988). The stalT review shall check to ensure that all workers who are routinely exposed to yellowcake dust are included in the bioassay program and that sampling and analysis frequencies are sufficient to detect and take action against high intakes of uranium in the workplace. Primarily, the program should intohe workers stationed in yellowcake drying areas and those who conduct regular maintenance on drying and ventilation! filtration equipment, i

i or license renew als and amendment applications, appendix A to this standard review plan (SRP) prosides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

NUREG 1569 3 26 l

Operaticns 5.7.5.3 Acceptance Criteria The bioanny program is acceptable if it meets the following criteria:

(1) It is consistent with applicable sectiona of Regulatory Guides 8.22, Ilioassay at Uranium Mills (Nuclear Regulatory Commission,1988) and 831 (Nuclear Regulatory Commission, 1983) including ALA'(A requirements. The bioassay program proposed to confirm results determined from the Airborne Radiation Mon! ' ring Program (SRP section $.7.3) and the Exposure Calculations (SRP Section 5.7.4)is in conformance with 10 CFR ?0.1204, and 10 CFR 20.1202.

(2) 1hc detennination of which workers will be monitore.1 in the tioassay program is consistent with Regulatory Guide 8.?2 (Nucl:cr Regulatory Commission,1988).

(3) Sampling and analysis frequencies include bascime urinalyses for all new employees and exit bicassays on Mrmination of empicyment and are consistent with Regul, tory Guide 8.22 (Nuclear Regulatory Commiulon,1988) and Regulatory Guide 8.9, Acceptable Concepts, Equations, and Assumptions for a liioassay Propam (Nuclear Regulatory Commission,1973).

(4) Action levels for bionssay mor.i toring are set in accordance with Regulatory Guide 8.22 (Nuclear Regulatory Commission,1988).

(5) All reporting and record keeping are done in conformance with the requirements of 10 CFR 20.2101, 10 CFR 20.2102, 10 CFR 20.2103, 10 CFR 20.2106, and 10 CFR 20.2110.

(6) for license renewal applications, the historical bioassay program results are included through the most recent reporting period preceding the submittal of the application. The effectiveness of the historical program is discussed with regard to all applicable 10 CFR Part 20 regulatory requirements. Long tenn trends are discussed, and any short tenn deviations from the long tenn trend are explained.

5.7,%8 thaluation Findings lf the stafrs review, as described m this section. results in the acceptance of the bioassay program, the following conclusions may be presented in the TER.

The NRC has completed its review of the bionssay program at the ISL facility. This roiew included an evaluation using the review procedures in SRP section 5.7.5.2 and the acceptance criteria outlined in SRP section 5.7.53.

The applicant has established an acceptable bioassay program at the 13L site that is consistent. An acceptable program for baseline urinalysis and exit bioassay is in place.

Individuals routinely exposed to >cilowcake dust are a part of the bionssay program. An acceptable action 5 21 NUREG 1569

Operations program to curtail uraniurn intake is estabbshed The 9ctions lesels are set. The applicant has established reponing and record Le(ping pintocols in conformance with the requirements of 10 CfR 20, subpart L liased on the information prosided in the application and the detailed review conducted of the bionssay program at the ISL facility, the NRC staff has concluded that the bioassay procam is acceptaHe and is in compibnce with 10 CI R 20.1204, which provides requirements for the detennination of internsi exposure.

5.7.5.5 Re'erences Nuclear Regulatory Commission.1973. Acceptable concepts, Models Equations, and Assumptions for a liioassay program. Regulatory Gu/de # 9. Washington, DC: Nuclear Regulatory Commission, Ofiice of Standards Deselopment.

Nuclear Regulatory Commission.1983. Infonnation Relevant to linsuring that Occupetional Radiation Exposures at Uranium Mills Will be As Low As Reasonably Achievable. Regn/storyGuide 8.3/.

Washington, DC: Nuclear Regulatory Coinmission Office of Standards Development.

Nuclear Regulatory Commission.19'8. liioassay at Uranium Mills Revision 1. Regulatory Guide 8.21 Washington. DC: Nuclear Regulatory Commission. Ollice of Standards Development.

5.7.6 Contamination Control Program 5.7,6.1 Areas of Review 1 he staf f shall review the occupational radiation survey program proposed to prevent employees hom entering clean areas or leasing the site w hile contaminated with radioactive materials. Review areas include proposed housekeeping and cleanup requirements and specifications in process areas to control contamination; frequency of sun ey s of clean areas; survey methods; and minimum sensitivity, range, and calibration frequency of sun ey equipment. proposed contamination criteria or action levels for clean areas and ihr the release of materials, equipment, and work clothes from clean areas or from the site shall be esaluated. Related procedures should be provided as an appendix to the application. The statT shall also resiew the methods proposed to ensure tLat the licensee climinates residual contamination prior to release of equipment Ibr unrestricted use.

5.7.6.2 Reslew l*rocciures The stalT shall detennine whether the proposed safety controls and monitoring procedures proposed by the applicant are sullicient to limit radiation exposures and radioactive releases to ALARA and are in confonnance with regulatory requirements identified in 10 CFR pan 20.

The stafT shall detennine whether the occupational radiation sun ey program proposed to prevent contaminated employees from enteung clean areas or leaving the site is in conformance with regulatory  !

requirements in 10 CFR 20 ! ?o2 and reles ant guidance. Requirements fbr a contamination control program (e g., maintaining change areas and personal alpha radiation monitoring prior to leasing radiation areas)

NUREG-1569 3 2g i

Operations should be incicded in standard operating procedures or discussed in the application. Staff shall confinn that the license applicant has a contamination control prograin consistent uith the guidance on conducting suneys for contamination of skin and personal clothing provided in Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983). Staff shall ensure that the licensee climinates residual contamination on equipment and materials to within acceptable release limits prior to release for unrestricted use (see appendin D).

For license renewals and amendment applications, appendix A to this standant ivview plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5.7.6.3 Acceldance Criteria The contamination control program is acceptable if it meets the following criteria:

(1) The occupational radiation survey progam proposed to preven

  • contaminated employees from entering clean areas or leaving the site is in confonance with regulatory requirements in 10 Cl:R 20.1702 and relevant guidance.

The proposed contamination control program is com,istent with the guidance on conducting surveys for contamination of skin and personal clotidng provided in Reculatory Guide,8.30 (Nuclear Regulatory Coramission,1983).

(2) Requirements for a contamination control prograra (e.g.. maintaining change areas and personal alpha radiation monitoring prior to leaving radiation areas) are included in standard operating procedures or discussed in the application.

These plans should be consis.ent with the guidance on conducting surveys for contamination of skin and personal clothing provided in Regulatory Guide,8.30 (Nuclear Regulatory Commission,1983).

(3) Action levels for surface contamination are set in accordance with Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983).

(4) Monitoring equipment by type, specifications range, sensitivity, calibration methods and frequency, availability, and planned use protect health and safety and the environment.

The application also demonstrates that the ranges of sensitivity are those expected from the facility operation.

(5) All reporting and record keeping is done in conformance with the requirements of 10 CFR 20.2101,20.2102,20.2103,20.2108, and 20.2110.

(6) The licensee will ensure that radioactivity on equipment or surfaces is not covered by paint, plating, or other covering material unless contamination lesels, as determined by a sun ey and documented, ue below the limits specified in table 5.71 prior to application 5 29 NUREG-1569 tr -%s -g-- w -y>- -

m M r qc-- - -

Operations of the coscring. A reasonable effort will be made to minimire the contamination prior to '

the use of any covering.

(7) 'ihe radioactivity of the interior surfaces of pipes, drain lines, or ductwork will be  ;

determined by inaking measurements at all traps, and other appropriate access points, providsd that contemination at these locations is likely to be representatise of contamination on the inte:ior of the pipes, drain lines, or ductwork.

(8) Ihe licensee will make a comprehensive radiation survey in conformance with Regulatory Guide 8.30(Nuclear Regulatory Commission,1983)and NUREG/CR 5849(llerger,1992)

Manual for Cenducting Radiological Suncy in Support of License Termination that established that contamination is within the limits specified in table 5.71 prior to release of premises, equipment, or scrap for unrestricted use.

(9) To relinaulsn possession or control of premises, equipment, or scrap having surfaces contaminated with material in excess of the limits specified (a) The applicent will provide detailed information describing the premises, equiprnent, or scrap; the radioactive contaminants; and the nature, extent, and degree of residual surface contamination.

(b) The applicant has provided a detailed health and safety analysis that reflects that the residual mounts of contaminated nater .ls on surface areas, together with other considerations such as prospectise use of the premises, equipment, or scrap, is unlikely to result in an unreasonable risk to the health and safety of the public.

(c) The applicant includes materials created by special circumstances including, but not limited to, the rating of buildings. trensfer of premises to another organiration continuing work with radioactive eaterials, or c :iversion of facilities to a long term storage facil;ty or to si:Mtsy sta'us.

5,7.6,4 Esaluation Findings if the staffs review, as described in this section, results in the acceptance of the contamination control program, the following conclusions may be presented in the TfR.

The NRC has completed its review of the contamination control progr 1 at the ISL facility. This review included an evaluation using the resiew procedures in SRP section 5,7.6.2 and the acceptance criteria cuttined in SRP section 5.7.6.3.

The applicant has established w acceptable contamination c ontrol program at the ISL site. T he program is consistent w ith Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983). Acceptable controls are in place to prevent contaminated employees from enttiing clean areas or leaving the site. The SOPS will include provisions for cot.tamination control such as maintaining changing areas and personal alpha radiation monitoring prior to leaving radiation areas.

Acceptable action levels have been set in accordance with Regulatory Guide 8.30 (Nuclear Regulatory Commission,1983) and plans for surveys are in place for skin and personal clothing contamination. The NUREG-1569 5 30 l

I Operations Table 5.71 Acceptable surLce contamination levels Nuclides' As trage'd Musimum* 8 ' Rernotable

U-nat, U 235. U 238, 5,000 a dpm/100 15,000 a dpm/100 1,000 a dpm/l(K) cm' 2

and awociated decay cm' cm products Transuranics, lla 226, 100 dpm/100 cm' 300 dpm/100 cm 2 20 dpm/100 cm 2 Ita 228, Th 230, Th llH, Pa-231.

Ac 227,1125,1129 Th nat, Th 232, St 90, 1,000 dpm/100 cm' 3,000 dpm/100 cm' 200 dpm/100 cm' Ra 223, Ra 224, U 232, 1 126,1 131,1 133 Deta gamma emitters 5,000 dpm/100 cm' 15,000 dpm/100 cm' 1,000 dpm/100 cm' (nuclides with decay modes other than alpha emission or spontaneous fission) except SMS, and others noted abose

'Whete surface contamination by both alpha and beta gamma emitting nuclides exists, the limits established for alpha and beta-gamma-emitting nuclides should apply independently.

'As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate factor for badpound, efficiency, and geometric factors anociated with the instrumentation.

' Measurements of average contamination should not be averaged oser more than i square meter. For objects of less surface area, the agerage should be derived for each such object.

  1. lhe maximum contamination level applies to an area of not more than 100 cm'.

'The amount of removable radioactive material per 100 cm' of surface area should le determined by wiping that area with dry filter or soft Asorbent paper, applying moderate pressure, and assessing the a*nount of radioactive material on the wipe with an appropriate instrument of known efficiency.

When removable contamination on objects of less surface area is determined, the pertinent lovels should be teduced ptoportionally and the entire surface should be wiped.

  • ihe ascrage and maximum radiction levels aweiated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad /hr at I cm and 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square untimeter of total absorber.

5 31 NUREG-1569 i

Operations applicant has established that all items remosed from the restricted are suncycJ by the radiation safety staff and meet release limits. All reponing and record keeping is done in confonnance with protocols established in Regulatory Guide 8.7 (Nuclear Regulatory Commission,1982). The applicant has demonstrated that the range, sensitivity, and calibration of monitoring equipment will support protection of the health and safety of employees during the full range at facility operations. The licensee has demonstrated that contaminated surf aces w di not be em ered unless, prior to covering, a sun ey documents that the contamination lesel is below the limits specified in table 5.71. The applicant will determine the radioactivity on the interior surfaces of pipes, drain lines, or ductwork by making measurement at appropriate access pointi that will has e been show n to be representath e ,f the interior contamination. The applicant has committed to establishing that contamination on material, equipment, or serap will be w.. in the limits in table 5.71 prior to unrestricted release, in order to relinquish possession or control of premises, equipment, or scrap with material in excess of the limits specified in table 5.71, the applicant wall provide detailed infonnation on the contaminated material and will provide a detailed health and safety analysis that shows that the release of the contaminated material will not result in an t 1 reasonable risk to the health and safety of the public.

The procedures to ensure that radioactivity on equipment or surfaces is not coscred by paint, plating, or other covering innterials are acceptable, including effons to minimize contamination before the use of any covering. The applicant has acceptably described the means to be used to detennine the existence of radioactivity on interior surfaces of pipes, drain lines, or ductwork by measuring contamination at traps and other appropriate points that provide representative samples of contamination, innsed on the information provided in the application and the detailed review conducted of the contamination control program at the ISL faellity, the NRC staff has concluded that the contamination control program is acceptable and is in compliance with 10 CI'R 20.1101, w hich defines radiation protection program and ALARA requirements; 10 CFR 20.1501, which provides suncy and monitoring requirements and 10 CfR 20.1702, which allows employees to limit dose to individuals by contiolling access. limiting exposure times, prescribing use of respiratory equipment, or other controls.

If the staft's review as described in this section results in the acceptance of the methods Ibr disposal or release of contaminated equipment, the followicg conclusions may be presented in the TER.

The NRC has completed its review of the methods for disposal or release of contaminated equipment proposed for use at the ISL facility. This review included an evaluation using the review procedures in SRP section 4.3.2 and the acceptance criteria outlined in SRP section 4,3.3.

5,7,6,5 References Iterger, J.D. I992. Mmualfor Conducting Radiological Surve.n in Support of1.icense Termination. Draf1 report for comment, NUREG/CR 5849. Washington, DC: Nuclear Regulatory Commission.

Nuclear Regulatory Commission.1982. Instructions for Recording and Reponing Occupational Radiation Exposure Data, Resision 1. Regulatorv Guide U. Washington, DC: Nuclear Regulatory Commission, Office of Standar.h Development.

l NUREG 1569 5 32 l

l l

Operations i

Nuclear Regulatory Commission.1983. licalth Physics Surseys in Uranium Mills.FegulatoryGuide 8 30. l Washington. DC: Nuclear Regulatory Commission.Of0cc of Standards Deselopment.  !

5.7.7 Airborne Effluent and Environmental Monitoring Programs - .

5.7.7.1 Areas of Retlew i The staff shall review the present and future operational rirborne effluent and environmental rnonitoring programs proposed for measuring concentrations and quantities of both radioactive and nonradioactive materials released to and in the environment surrounding the facility. The stafT should review the technical bases proposed for determining environmental concentrations for demonstrating compliance with standards. The stafT review shall fact.s on the frequency of samping and analysis, the typs and sensitivity of analysis, action levels and corrective action requirements, and the minimum number and criteria for loating efuuent and envirumental monitoring stations. The staff shall review the topographic map of the site and the surrounding area showing monitoring locations.

5.7.7.2 Reth.t Procedures The reviewer shall be familiar with the requirements of 10 CFR Part 20 which provides the regulatory standards for protection against radiation. Applicants are required to demonstrate not only that public esposure to radiation is below allowable dose limits as speci0ed in 10 CFR Pari 20, subparts D and F. but also,in accordance with subpan 11, that radiation exposure during ISL operations is ALARA.

The stafT shall detennine whether the poposed airborne ellluent and environmental monitoring programs are suf0cient to limit esposures and releases of radioactive and nonradioactive materials to Al. ARA and are in confonnance with regulatory requirements identi0cd in 10 CFR Part 20.

The stallshall detennine w hether the ef11uent and environmental monitoring programs proposed for measuring concentrations and quantities of both radioactise and nonradioactive materials released to and in the environment around the proposed facility as described in the site characteriration (see section 2.0 of the SRP) are in accordance with the regulatory requirements described in 10 CFR Part 20, subparts D and F (10 CFR 20.1302 and 10 CFR 20.1501, in particular).

StafT shall ensure that the license applicant has adequately considered site specific aspects of climate and topography in determining locations for offsite airborne monitoring stations and environmental sampling areas such that they are capable of detecting masimum offsite concentrations of efnuents in the environment. In conducting their review, staff rhould refer to guidance in Regulatory Guide 4.14 Revision I. Radiological limuent and Environmental Monitoring at Uranium Mills (Nuclear Regulatory Commission,1980) which contains infonnation on determining sampling locations, types, methods, frequencies and analyses which are sumcient to comply with the applicable requirements fbr protection of the public from ofTsite exposures in 10 Cl R part 20, subpans D and F.

For license renew als and amendment applications, appendis A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5 33 NUREG 1569 i

Operations 5.7.7.3 Acceptance Criteria lhe airborne effluent and environmental monitoring programs are acceptable if they meet the following criteria:

(1) 1he proposed airborne efIluent and environmental monitoring program is consistent with Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980) and ALARA requirements as described in Regulatory Guide 8.37 (Nuclear Regulatory Commission,1993).

(2) The proposed locations of the air monitoring stations are consistent with guidance in Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980).

The license applicant adequately considers site specific aspects of climate and topography, as described in the site characterization provided in section 2.0, in determining the number and locations of offsite airborne monitoring stations and environmental sampling areas.

The criteria used in selecting sampling locations should be given. All sampling locations should be clearly shown relative to the proposed facility, nearest residences, and population centers on topographic maps of the appropriate scale.

(3) Ihe proposed airborne ef11uent and environmental munitoring programs should sample radon, air paniculates, surface soils, subsurface soils, vegetation, direct radiation, and sediment in accordance with Regulatory Guide 4.14 (Nuclear Regulatory Commission, 1980).

Preoperational baselines should be established for each of these categories using statistically valid methods prior to stanup of the facility, (4) The proposed sampling methods are consistent with guidance in Regulatory Guide 4.14 (Nuclear hegulatory Commission,1980).

($) All reporting and record keeping are done in confonnance with the requirements of 10 CFR 20.210l,20.2102,20.2103,20.2107,20.2108, and 20.2110.

(6) for license renewal applications, the historical airborne effluent and environmental monitoring program results are included through the most recent reponing period preceding the submittal of the application. The effectiveness of 4he historical program is discussed whh regard to all applicable 10 CFR Pan 20 regulatory requirements identified in the preceding paragraphs. Long term trends are discussed, and any short tenu deviations from the long tenn trend are explained.

5,7.7,4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the airborne efiluent

! and environmental monitoring program, the following conchuions may be presented in the TER.

NUREG 1569 5 34 l

l

Operations the NRC has completed its resiew of the Urtwrne ellluent and ensironmental monitoring program at the ISI facility. This review included an esaluation using the resiew procedures in SRP section 5.7.7.2 and the acceptance criteria outlined in SRP section 5.7.7.3.

The anplicant has established an acceptable airborne effluent and environ. mental monitoring program at ilo ISL rite. The oserall program is consistent with guidance in 1(egulatory Guide 4.14 (Nuclear Regulatory Commission,1980). The applicant will sample radon, air particulates, surface soils, subsurface soils, segetation, direct radiation, and sediment L ~ations of air monitoring stations are consistent with Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980).

Instrumentation is appropriate for the measurement task and is acce9 table. All reponing and secord keeping is done in accordance with the requirements of the 10 CFR Part 20, subpart L.

t liased on the infbrmation provided in the application and 'ie detailed review conducted of the airborne efiluent and environmental monitoring program at the ISL facility, the NRC staff has concluded that the airbome effluent and environmenta: monitoring program is acc, ptable and is in compliance with 10 CFR 20.a02. which requ!res ef1luent monitoring to detennine dose to individual enembers of the public and 10 CFR 20.1501. which specifies survey and monitoring requirements.

5.7.7.5 References Nuclear Regulatory Commiss;on.1980. Radiological Efiluent and Environmental Monitoring at Uranium Mills, Revision 1. Regidatory Guide 4.14, Revhion /. Washington, DC: Nucicar Regulatory Commission, Office of Standards Seselopment.

Nuclear Regulatory Commission.1993. ALARA Lesels for Elliuent from Materials Facilities. Regadatorv Guide #37. Washington, DC: Nuclear Regulatory Commission, Ollice of Standards Des clopment.

5.7.8 Groundwater and Surface Water Monitoring Progrmns 5.7.8,1 Areas of Review There are three distinct phases of groundwater and surface water monitoring: preoperational, operational, and restoration. Preoperational monitoring is conducted as a part of site characterization, and review procedures are covered in section 2 of this SRP. Rectoration monitoring is conducted during the groundwater restoration phase of operations, and review procedures are discussed in section 6. This SRP section deals specitically with monitoring of groundwater and surface water quality during the production or operational phase of ISL activities.

The staff shall review the technical bases and procedures fbr the iblioning components of an elTectise groundwater and surface water operational monitoring program:

(1) Well field baseline water quality monitoring programs (groundwater and surface water)

(2) Selection of escursion indicators and their respectise upper control limits (UCLs) 5 35 NUREG-1569

Operations (3) 1he placement of excursion monitoring wells (4) Well field testing to verify horizontal continuity between the ore zone and perimeter wells, and vertical isolation tetween the ore zone and vertical excursion monitor wells (5) 1he excursion monitoring program, including well sampling schedules, criteria for placing well fields on excursion status, and corrective actions to be taken in the event of an excursion (6) 1hc surface water rnonitoring program Procedures for sample collection and analysis should be presented in an appendix.

5.7.8.2 Retlew Procedures Prior to ISL operations, wc!! field hydraulic and vater chemistry data are collected. The water quality data is used to set the concentrations of parameters that will be used to determine if the well field is being operated safely. Water quality data is also used to set the water quality to which the aquifer will be restored after ISL operations. From an environmental standpoint, hydraulle data or ;afonnation that is used to describc the flow of groundwater, is used to (i) evaluate whether the well field can be operated safely, (ii) confinn monitor wells have been located correctly, (iii) design aquifer restoration activities, and (iv) predict postrestorat;on impacts. The reviewer shail determine that the objectives of the operational mon i toring program have been established. To this end, the reviewer shall:

(1) Verify that procc-dures for collecting all water quality data will be developed to include sets of samples that are acceptable to evaluate natural spatial and temporal variations in water quality.

(2) linsure that the applicant uses an appropriate technical basis for detennining monitor well spacing.

(3) Evaluate whether well field testing is suflicient to establish horirontal connectivity between the ore zone and outer monitor wells, and sertical isolation between the ore zone and venical excursion monitor wells-(4) livalaate whether the excursion monitoriny program will result in timsly detection and rnoning oflixiviant migration from the ore ione.

(5) thaluate whether a surface water monitoring program is necessary at the site and, if so, w hether the monitoring program will be efTective to detect migration of contaminants into surface water bodies.

(6) Esaluate whether actions to be taken in the event no excursion is detected are consistent with the acceptance criteria.

P NURi?G-1569 5 36

Operations

]

(7) Ensure that the approaches for new well fields and establishment of UC1/s hase the basic components outlined in the SRP. The reviewer is not expected to resiew the specified parameters or UCl.s for individual well fields. This will be donc during routine ,

inspections of operations.

l'or license renewals and amendment applications, appendix A to this standard review plan (SRf'?

provides guidance for examining facility operations and the approach that <hould be used in evaluating amendments and renewal applications.

5.7.8.3 Acceptance Criterim

+

The groundwater monitoring program should ensure that an excursion is detected long before ISL solutions could seriously degrade the water quality of groundwater outside the well field area. Early detection of excursions by a monitor well is influenced by the thickness of the aquifer monitored, the distance that monitor wells are placed from the well field and each other, the frequency that the monitor wells are sampled, the water quality parameters that are sampled, and the concentrations of parameters that w ul tw used to declare that an excursion has been detected.

The groundwater and surface water monitoring purams are acceptable if they are sufficient to ensurs that .fMng day to day operations, groundwater and surt. ce water will be mo4ored such that early detectic i l' tii.. : restoration of excursions will be achieved. The following criteria must be met by ISL operational monitoring programs:

(1) For each new well field, the applicant's approach for establishing baseline water quality data sufficient tv (i) define the primary restoration goal of returning each well Geld to its preoperational water quality conditions, and (ii) provide a standard ihr detennining when an excursion has occurred.

llaseline sampling programs should provide enough data to adequately evaluate natural spatial and temporal variations in preoperational water quality. At least four independent sets of samples should be collected. There should be adequate time between sets to detect preoperational temporal viations (2 wk recommended; longer if scuonal variations occur). A set of samples is defined to be a group of at least one sample fbr each of the designated baseline monitor wells within the unit being characterited, taken to represent the water quality conditions of the sampled aquifer at a specific point in time. An acceptable set ci .amples should include all well Geld perimeter monitor wells, all upper and lower aquifer monitor wells, and at least one prmluction/ injection well per acre in each well Geld. For large well fields, it may not be practical to sample one production / injection well per acre; if fewer than one per acre are sampled, enough productiordinjection wells to provide an adequate statistical population must be sampled.

As a general! ;uideline, for nonnally and log normally distributed populations, at leu six samples are required to achiese 90 percent confidence that any random sample will lie within two standard deviations from the sample mean in no case should the baseline sampling density for pmduction! injection wells be less than one per 4 acres.

547 NUREG-1569 i

Operations The. applicant should identify the list of constituents to be sampled for baseline ,

concentrations. The list of constituents in table 2.71 has generally been accepted by the NRC for ISL- operations. A'tematively, applicants may propose a list of constituents that is tailored to a particular location. In such cases, sufficient technical bases must be provided for the selected constituent list. For example, many licensees have deci6d not-to sample for thorium 230; thorium 230 is a daughter product from the decay of

> uranium 238, and studies have shown that it is mobilized by bicarbonate-laden leaching solutions. Ilowever, studies have also shown that after restoration, thorium in the

! groundwater will not remain in solution, because the chemierv of thorium causes it to precipitate an I chemically react with the rock matrix (Hem, i " 5). As a result of its low solubility in natural waters, thorium is found in only trace co,sentrations. Additionally, chemical tests for thorium are expensive, and are not commonly included in water analyses M ISL mines. This example concerning thorium 230 has been found to be an acceptab.e technical basis for excluding thorium 230 from the list of sampled constituents.

For all constituents that are sampled, copies d latoratory reports documenting the measurements should be maintained by the applicant.

An outlier is a single nonrepeating value that lies far above or below the rest of the sample values for a single well Removal of outliers from sample sets should be done using proper statistical methods. The outlier may represent a sampling, analytical, or other unknown source of error or unidentified randomness in the data, its inclusion within the sample could significantly change the baseline data, since the outlier is not typical of the bulk of the samples. All calculations, assumptions, and condusions made by the applicant in evaluating outliers should be fully explained. When an outlier has been discarded, it may be necessa'y to take another sample to replace the one discarded. A conservative metnod for dealing with suspected outliers is to accept any questionable data that cannot te positively linked to sampling or analytical error. Another acc:ptable method is to accept any value within three standard deviations of the mean. For a nonnally distributed set of values, three standard deviations encompass 99.7 percent of the variation in the population. It is often necessary to perfonn log-transfonnations on data in order to better approximate a normal distribution. The standard deviation should be calculated without using the v sted outliers. Care should be taken not to exclude suspected outliers that ultimately ne rmresent bimodal distributions. Methods in NUREG/CR-4604 (Nuclear Regulatory Commission,1988) and NUREG-1475 (Nuclear Regulatory Commission, 1994) are acceptable methods to the NRC staff for outlier calculation. Other documented and technicallyjustified methods used by applicants will be considered in the evaluation

<' a (e.g., U.S. Environmental Protection Agency,1989).

(2) The cplicant selects excursion indicator sets and UCLs. UCLs are intended to provide early warning that leaching solutions are moving away from the well fields so that groundwater outside the monitor well ring is not significantly threatened. This is accomplished by choosing parameters that are strong indicators of the ISL leaching process and that do not greatly attenuate because of geochemical reactions in the aquifers.

'If possible, the parameters chosen should be easy to analy7e, allowing timely data report ig. The concentration of the chosen indicator parameters should be set high enough that / sse positives (false alarms due to natural llactuations in water chemistry) are not a NUREG 1569 5 38 l

l:

Operations frequent problem, but not so high that significant groundwater quality degradation occurs by the time an excursion is identified. A minimum of three excursion indicators must be proposed. The choice of excursion indicators must be based on lixiviant content and host rock geochemistry. StalT must ensure that selected excursion indicators are measurable parameters that are found in significantly higher concmt:ations during ISL operations than in the natural waters. At most uranium ISL operatWs, cloride is an excell nt excursion indicator because it acts as a conservative tracer, it is usily measured, and chloride concentrations are significantly increased during ISL lea-idng. Conductivity, which is correlated to TDS, is also considered to be a go / < aursioc indicator (Staub,1986; Deutsch,1985). Total alkalinity (carbonate plus sicarbonate i.lus hydroxik) is an excellent indicator in well fields where sodium bicaraonate or carbon dioxide are used in the lixiviant. If conductivity is used to estimate IDS, it must be clerily stated that mearurements will be normalized to a reference temperature, usually 25 *C, due to the temperature dependence of conductivity.

Calcium, sodium, and sulfate are projected to be found at significantly higher levels in 2

ISL leachate than in natural groundwater concentrations. The use of cations (e.g., Ca *,

Na') as excursion indicators is generally not appropriate, because they are subject to ion s

exchange processes in the presence of clay miacrals. The use of sulfate may give false alarms because ofinduced oxidation around a monitor well(Staub,1986; Deutsch,1985).

Ilowever, this should only be a problem if UCL values are set too conservatively.

Uranium is not considered a good indicator, because while it is mobilized by ISL leaching, it may be retarded by reducing conditions in the aquifer. Water level measurements are very useful for any excursion monitoring program, since in artesian aquifers water level changes are quickly transmitted through the aquifer, llowever, water levels are not considered to be good indicators, because water level data would identify too many false excursions (fals? positives). The applicant may choose to add a nonreactise, conservative tracer to ISL solutions to act as an excursion indicator. The applicant is required to provide the technical bases for the selection of all excursion indicators.

UCLs must be calculated such that the presence of two or more excursion indicators in a monitering weli at concentrations greater than the UCL for the respective indicator will be an indication that a lixiviant excursion has occurred. The value of the UCL for ech excursion indicator must be less than the lowest concentration at which the indicator could reasonably be expected to occur in the lisiviant while the well field is in operation. Each UCL must also be greater than the baseline concentration for its respective excursion indicator. Applicant site specific experience is ollen valuable in determining appropriate UCLs that provide timely detection and avoid false alarms.

Upper control limits for a specific excursion parameter should be determined on a statistical basis in order to account for potential spatial and temporal variations for the parameter concentrations within the ore zone. Nuclear Regulatory Commission staff have

- found the use of statistical techniques such as the student "T" distribution an acceptable method for setting UCLs. In some cases, the use of a simple percentage increase abose baseline values ( a 20 percent increase above the established baseline is suggested) has 5 39 NUREG-1569

1 1

Operations been found acceptable by staff. The staff has decided that in areas with good water quality ( a TDS less than 500 mg/L), setting the UCL at a value of 5 standard deviations above the mean of the measured concentrations is an acceptable approach. However, in so:nc aquifers of good water quality, low chloride concentrations have been founo to have such a narrow statistical distribution that a specified oncentration (15 mg/L) above the mean or the mean plus 5 standard deviatim epproach, which ever is greater, has been used 10 establish the chloride UCL.

The same UCLs may be assigned to all monitor wells within a particular hydrogeologic unit in a given well field if baseline dats indicate little chemical heterogeneity.

Alternative;y, if individual monitor wells in a given unit exhibit unique baseline water quality, UCLs may be assigned on a well by well basis. If UCLs vary from well to web, a table should be included listing all monitor wells and their respective UCLs.

(3) The applicant establishes criteria for determining monitor well locations. Orc zone perimeter monitor wells are used to <letect horizontal excursions outside the well field boundary. They generally surround the entire well field and are screened over the entire ore ione hydrogeologic unit. Local groundwater gradients, velocity, and dispersion of the excursion indicators should be considered when choosing the location and spacing for these wells. A horizontal excursion may be more likely to occur downgradient from the well field due to the background gradient of the groundwater. As an excursion migrates away from the well field, it will tend to spread laterally due to dispersive processes.

Excursions may also occur upgradient or crossgradicnt from the natural flow direction if the flow balance between production and injection w :lls is incorrect, or if flow velocities away from the well field are low enough that dispersion is the dominant transport process.

The criteria should ensure that perimeter monitor wells will be placed close enough to the well field to provide timely detection, yet they should be far enough away from the well field to avoid numerous false alarms. They must also be spaced close enough to one another so that, by the time an excursion reaches them, the expected width of the excursion plume is likely to encounter at least one monitor well. In previous reviews, the NRC staff has commonly found the location of horizontal monitor wells to be acceptable if the wells were located 140 m (400 ft) from the edge of the production or injection wells with 140 m (400 ft) between each monitor well so that the angle formed by lines drawn from any production well to the two nearest monitor wells would not be greater than 75 degrees. The NRC staff has also approved horizontal monitor well locations uased L on a modeling demonstration that a theoretical excursion can be controlled at the monitor l well locations within 60 days of excursion detection at a monitor well.

Upper and lower aquifer monitor wells should lie within the well field and be completed in the appropriate hydrogeologic unit. Their location within the well field should not be arbitrary, and the technical basis for their selection should be discussed in the application.

~

The appropriate number of these monitor wells may vary from site to site. It may be appropriate to exclude the requirement to menitor water quality in the underlying aquifer if(i) the underlying aquifer is a poor producer of water, (ii) the underlying aquifer is of poor water quality,(iii) there is a large aquitard between the ore zone and the underlying aquifer and few boreholes have penetrated the aquitard, or (iv) deep monitor wells would NUREG 1569 5-40

Or -' ions significantly increase the risk of a vertical excursion into the underlying aquifer. Monitor '

wells completed in aquifers above the first overlying aquifer may not be required when (i) the aquifers are separated from the production zone by thick aquitards, (ii) a high quality mechanical integrity weli testing crogram will be implemented, or (iii) the aquifers are unsubstantial producers of water or of poor water quality. In well fields where the ore zone confining layers are particularly thin, or of questionable continuity, a greater number of monitor wells is appropriate. In general, when the direction of groundwater flow in an upper or lower aquifer is well known consideration by the epplicant should be given to locating (Nse wells on the hydraulically downgradient side of a well field, in areas where ore zone confining layers may be thin or incompetent, and in areas where injection pressure may be highest (i.e., closer to injection wells than to production wells).

The process for detennining the screened interval of the monitor wells should be described. Fully screened monitor wells sample the entire thickness of the aquifer.

Therefore, excursions could not pass above or below the well screens. Ilowever, the concentration of the indicator parameters might be diluted and therefore may not provide the earliest possible warning that an excursion is occurring. Partially screened monitor wells only sample the zone of ore extraction within an aquifer. These wells might miss some excursions, but would suffer less from dilution efTects than fully screened wells. For most situations the NRC staff favors fully screened monitor wells. Fully screened monitor wells would assure that excursions will eventually be detected, have the advantage of more accurately representing the water quality that a groundwater user is likely to experience, and do not suffer from the uncertainty of predicting the completion intervals of injection and production wells that have not yet been drilled.

The NRC staff has approved a vertical monitor well density for the first overlying aquifer of one monitor well per 1.6 ha (4 acres), one monitor well per 3.2 ha (8 acres) of well Geld unit in each higher aquifer, and one monitor well per 1.7 to 3.2 ha (4 to 8 acres) in the underlying aquifer.

(4) The applicant establishes well field test procedures. Once a well field is installed, it should be tested to establish that the ore zone production and injection wells are hydraulically connected to the perimeter horizontal excursion monitor wells, and hydraulically isolated from the vertical excursion monitor wells. Such testing will serve to confinn the perfbrmance of the monitoring system, and verify the validity of the site conceptual model reviewed in section 2 of the SRP. The reviewer should verify that well field test approaches have sound technical bases. Test approaches typically consist of a pump test that subjects the well field to a sustained maximum withdrawal rate while monitoring the perimeter and vertical excursion wells for drawdown. The test should continue until the effects of pumping can be cleuly seen via drawdown in the perimeter monitor wells. Typically about I fl of drawdown in the perimeter monitor wells will verify hydraulic connection, but the amount may vary due to distance from the pumping weUs, pumping rates, and hydraulic conductivity. To investigate vertical confinement or hydraulic isolation between the mine zone and upper and lower aquifm it is acceptable  ;

to perform pump tests that in addition to the mine zone, also monitor wMer levels in )

upper or lower aquifers.  !

l 5-41 NUREG-1569 l l

i 1

I l

Operations (5) The applicant dennes operational approaches for the monitoring program. The monitoring program must indicate which wells will be monitored for excursion indicators, the monitoring frequency, and the criteria for deter nining when an excursion has occurred.

The NRC has determined that an acceptable excursion monitoring program should indicate that all monitor wells will be sampled for excursion indicators at least every 2 wk during mining operations.

An excursion is deemed to have occurred if any two excursion indicators in any monitor well exceed their respective UCLs, or a single excursion indicator exceeds its UCL by 20 percent. A veri 0 cation sample must be taken within 48 hr after results of the Orst analyses were received. If the second sample does not indicate that UCLs were exceeded, a third sample must be taken within 48 hr after the second set of sampling data was acquired, if neither the second nor the third sample indicate that UCLs are exceeded, the Orst sample is considered in error and the well is removed from excursion status. If either the second or third sample contain indicators above UCLs, an excursion is confirmed, the well is placed in excursion status, and corrective action must be initiated.

Generally, the risk of contamination to surface water bodies from ISL operations is low w hen proper operational procedures are followed. Any surface water body that lies within the proposed license boundary should be sampled at upstream and downstream locations, both prior to and during operations. The reviewer should ensure that preoperational water quality sampling locations for applicable surface waters are indicated in the application.

The preoperational data should be collected on a seasonal basis for a minimum of 1 yr prior to ISL operations. Proecdures for monitoring surface water quality during operations should be discussed in the applicatior.: this discussion must include a monitoring schedule, monitor locations, and a list of sampled constituents. The applicant may be exempted from monitoring during operations if the site characterization demonstrates that no signi0 cant How of groundwater to surface water occurs near the site (e.g., if surface water bodies are perched and ephemenil).

(6) The application includes corrective action and noti 0 cation plans in the event of an excursion. The NRC must be notined within 24 hr by telephone and within 7 days in writing from the time an excursion is verified. A written report describing the excursion event, corrective actions, and the corrective action results must be submitted to NRC within 60 days of the excursion con 0rmation. If wells are still on excursion when the report is submitted, the report must also contain a schedule for submittal of future reports to the NRC describing the excursion event, corrective actions taken, and results obtained.

In the case of a vertical excursion, the report muse contain a projected date when characterization of the extent of the vertical excursion would be completed.

Corrective action to retrieve horizontal excursions within the ore-zone aquifer is generally accomplished by adjusting the How rates of the pumping / injection wells to increase process bleed in the area of the excursion Vertical excursions have proven more dif0 cult to retrieve: at some ISL facilities, vertical excursions have persisted for years. In the event that an excursion is not corrected within 60 days of confirmation, applicants must either NUREG-l%4 5-42 l

Operations terminate injection of lixiviant into the well field until the excursion is retrieved, or provide an increase to the reclamation surety in an amount that is agreeable to the NRC and that would cover the expected full cost of correcting and cleaning up the excursion.

The surety increase must remain in force until the excursion is corrected. The written 60 day excursion report should state and justify which course of action will be followed.

If wells are still on excursion status at the time the 60-day report is submitted to the NRC, and the surety option is chosen the well field restoration surety will be adjusted upward.

To calculate the increase in surety for horizontal excursions, it is assumed that the entire thickness of the aquifer between the well field and the monitor wells on excursion has been contaminated with lixiviant. It is also assumed that the width of the excursion is the distance between the monitor wells on excursion status plus one monitor well spacing distance on either side of the excursion. When the excursion is corrected, the additional surety requirements resulting from the excursion will be removed.

To calculate the increase in surety for vertical excursions, an initial estimate of the area contaminated above background is made. All estimates assume that the entire thickness of the upper aquifer is contaminated. As characterization of the extent of contamination proceeds, the surety may be increased or decreased as appropriate. Once the extent of contamination is determined, the area contaminated above background is used to calculate the level of surety. When the vertical excursion is cleaned up, the additional surety requirements resulting from the excursion are remosed, in calculating the increase in surety bonding for horizontal and vertical excursions, the same fonnula used to calculate the number of pore volumes reouired to restore a well field is applied to the assumed areas of contamination. This approach is consistent with 10 CFR Part 40, appendix A, criterion 9. Increased surety provides assurance that cleanup will be accomplished in the event of licensee default, and surety can be adjusted l downward once cleanup is complete. In calculating the area affected by an excursion and the volume of water required to effect restoration, a conservative estimate is taken to ensure that adequate funds are available to clean up the groundwater should the licensee fail to do so.

Corrective action for verthal and horizontal excursions can be detennined complete when all excursion indicators are below their respective UCLs, or no more than one excursion indicator exceeds its respective UCL by less than 20 percent. Stability in the excursion indicator concentrations must be demonstrated by measurements over a suitable time period before the corrective action measures can be discontinued.

An excursion is deemed to have been corrected when all control parameters are reduced to their UCLs or lower.

S.7.8.4 Evaluation Findings if the staft's review, as described in this section, results in the acceptance of the groundwater and surface water monitoring programs, the following conclusions may be presented in the TER.

5-43 NUREG 1569

1 Operations The NRC has completed its review of the groundwater and surface water monitoring programs at the ISL facility. This review included an evaluation using the review procedures in SRP section 5.7.8.2 and the acceptance criteria outlined in SRP section 5.7.8.3.

The applicant has established acceptable groundwater and surface water monitoring programs at the ISL site. The applicant has established acceptable baseline sampling programs including the number and timing of samples, constituents sampled, and appropriate statistical methods to remove outliers. The applicant has selected acceptable excursion indicator parameters and the approach for establishing UCLs. Appropriate criteria are used to establish monitor well locations for all potentially affected aquifers. Appropriate well Geld test procedures are established. The applicant has de0ned acceptable operational approaches for the groundwater and surface water monitoring programs including identifying appropriate wells for monitoring for excursion indicators, monitoring frequency, and criteria for determining the presence of an excursion. The applicant has de0ned an acceptable sampling program for any surface water body that lies within the facility boundary including downstream sampling locations, appropriate preoperational seasonal data collestion, standard approaches for monitoring including a schedule and a list of analy7ed constituents. The applicant has prepared an acceptable corrective action plan including noti 6 cation of the NRC and subsequent reporting in the event of an excursion.

Based on the infonnation provided in the application and the detailed review conducted of the groundwater and surface water monitoring programs at the ISL facility, the NRC staff has concluded that the groundwater and surface water monitoring programs are acceptable and are in compliance with 10 CFR 40.32(c), which requires the applicant's proposed equipment, facilities, and procedures to be adequate to protect health and minimize danger to life or property; 10 CFR 40.32(d),

which requires that the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public; and 10 CFR 40.41(c), which requires the applicant to confine source or byproduct material to the locations and purposes authorized in the license; and 10 CFR 40.31.

Preoperational monitoring is conducted as part of site characterization and is addressed in section 2 of this TER while restoration monitoring is conducted during groundwater restoration and is addressed in section 6 of this TER.

S.7.8,5 References Deutsch, WJ., et al.1985. Alethod of Alinimi:ing Growid-Water Contamination From in Situ Leach Uranium Alining. NUREG/CR-3709. Washington, DC: Nuclear Regulatory Commission.

Ilem, J.D. I985. Study and Interpretation of the Chemical Characteristics ofNa: ural Water. USGS Water Supply Paper 2254, third edition. Roton, VA: U.S. Geological Survey.

Nuclear Regulatory Commission. 1988. Statistical Alethods for Nuclear Afaterial Afanagement.

NUREG'CR 4604. Washington, DC: Nuclear Regulatory Commission.

Nuclear Regulatory Commission.1994. Applying Statistics. NUREG-1475. Washington, DC: Nuclear Regulatory Commission.

NUREG-1569 5-44

Operations Staub, W.P. et al.1986. An Analysis of Escursions at Selected in Situ Uranium Afines in Il)vming and Texas. NUREG/CR 3967. Washington, DC: Nuclear Regulatory Commission.

U.S. Environmental Protection Agency.1989. Statistical Analysis of Ground ll'ater Afonitoring Data at RCRA (Resource Conservation and Recovery Act) Facilities, Interim Final Guidance.

ggy EPA /530-SW-89-026. Washington, DC: U.S. Environmer.tal Protection Agency.

ECbb; 5.7.9 Quality Assurance .,ANS ESTOI 5.7.9.1 Areas of Retlew The staff should review the QA programs proposed for all radiological, emuent, and environmental (including groundwater) monitoring programs. fhe stait; 5.7.9.2 Review Procedures g) E-The stafishall detennine whether the safety controls and monitoring proc edures proposed by the applicant are sumcient to limit radiation exposures and radioactive releases to ALARA and are in confonnance with regulatory requirements identified in 10 CFR Part 20. The staff shall detennine if the g QA programs proposed for all radiological, effluent, and environmental (including groundwater) monitoring are in accordance with Regulatory Guides 4.15, Quality Assurance for Radiological Monitoring Programs (Nonnal Operations)- Emuent Streams and the Environment (Nuclear Regulatory Commission, 1979).

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the apprcach that should be used in evaluating (3) amendments and renewal applications.

5.7.9.3 Acceptance Criteria The QA program is a.ceptable if it meets the following criteria:

(1) The QA plan has been established and applied to all radiological, emuent, and environmental programs. The proposed QA plan should be consistent with guidance provided in Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980) and q Regulatory Guide 4.15 (Nuclear Regulatory Commission,1977).

(2) All reporting and record keeping will be done in confonnance with the review described in Section 5.3.2 of this SRP.

Note that under the existing 10 CFR Part 20 requirements, a licensee must retain survey and calibration records for 3 yr instead of the 2 yr mentioned in Regulatory Guide 4.15 (Nuclear Regulatory Commission,1979). Furthermore, existing 10 CFR Part 20 requirements have been updated to include a requirement that all licensees maintain 6.1.3<

fo\\ot 5 45 NUREG-1569

sw. cations rec the affected pore volume ar  : en (2) site upon which restoration estimatese consistent with theYometh arebased.

Compare descriptions of restoratio at the R&D site or other th eg at R&D rock sites for otherISL facilitie (3) host and lixiviant .

n methods

s. chemistry Ensure to methods that methods selected that arehave a se successfu been 10 sht u

ppropriate for the Assess whether the applicant has p rainati restoration by comparing standards restored ISL facilities, success and a realistic to previou e essment of the expected postreclamati etermination assrovided

  • the sta a

of (4) s restoration work at the o R&D site or thon 'ng water con qu Evaluate the ability of the post er previously successful restoration. The NR (5) reclamation stability monitoring m includx

( Consider whether the proposed r program to verify "

(

field and monitorectedwells spread o of thecleanup due to well TheSPPL field f I

(6) pumped during restoration will adver lproduction zone),fextraction so ' program Eulatory Assess whether plansse foryplugging alTect offsite groundwater s.

r useand whether

$sion,1919' consistent with generally n ques. accepted tech iand abandoning etain reco ge NRC te wells provides guidance for examining fa iliForlicenserenewals c

e tennination are andam g3ased on amendments and renewal applicatio ns. ty operations and the approent applications, regram append at ths 6.1.3 Acceptance Criteria ach that should bengused in evaluatis -

stabic and is an

,' tion Pf E'"

'yg part 20, decommissioning and acceptabl ifThe plans and schedules for gr e

(1) they meet the following crite ioundwater qua!ity restorat The application includes estimat r a: , surface reclamation, and plant need to be cleaned up during groundes of the volume icicarRCB"I"9" andOpem quality o Washin 4 water restoration.

raction solutions that investigationsock. in similar host re based on experience in ISL rGenerally, thesewc)estimates ear Regulato (2) 16115. E' operations or R&D The applicant describes o the meth d Commis A pore volume is an indirect used m for estimating well field pore volume.

processed o to restore the groundwateasure of the volume of water th a certain v lume ofer.

to represent howof water rock or sedim It represents that must the be water that fillstothat processed ff must be pumped or ent. Restoration costs are closely li ke soid space inside n

e ect restoration. The pore volum ed to the amount the levelmany times of etTort the contaminated required volum tdisplaced or processed e parameter is used guREG-1569 to resto o restore groundwater regardlesse groundwater q of the scale of the test. Ins a means 6-2

Operations-Staub; W.P. et al, I986. An Analysis of Escursions at Selected in Situ Uranium Mines in Wyoming and

-Texas. NUREG/CR 3967. Washington, DC: Nuclear Regulatory Commission.

U.S. Environmental Protection Agency. I989. Statistical Analysis of Ground Water Monitoring Data at RCRA (Resource Conservation and Recovery Act) Facilities, Interim Final Guidance.

EPA /530 SW-89 026. Washington, DC: U.S. Environmental Protection Agency,

=5.7.9 Quality Assurance 5,7.9.1 Areas of Review The staff should review the' QA programs proposed for all radiological.. effluent, and environmental (including groundwater) monitoring programs.

'5.7.9.2 Review Procedures The staff shall detennine whether the safety controls and monitoring nrocedures proposed by the applicant are sufficient to limit radiation exposures and radioactive releases to ALARA and are in conformance with regulatory requirements identified in 10 CFR Part 20, The staff shall determine if the QA programs proposed for all radiological, efnuent, and environmental (including groundwater) monitoring are in accordance with Regulatory Guides 4.15, Quality Assurance for Radiological Monitoring Programs (Nonnal Operations)- E01uent Streams and the Environment (Nuclear Regulatory Commission, 1979).

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

5,7.9.3 Acceptance Criteria The QA program is acceptable if it meets the following criteria:

(1) The QA plan has been established and applied to all radiological, effluent, and environmental programs. The proposed QA plan should be consistent with guidance

, provided in Regulatory Guide 4.14 (Nuclear Regulatory Commission,1980) and Regulatory Guide 4,15 (Nuclear Regulatory Commission,1977).

(2) All reporting and record keeping will be done in conformance with the review described in Section 5.3.2 of this SRP, Note that under the existing 10 CFR Part 20 requirements, a licensee must retain survey and calibration records for 3 yr instead of the 2 yr mentioned in Regulatory Guide 4.15 (Nuclear Regulatory Commission,1979). Furthermore, existing 10 CFR Part 20 requirements have been updated to include a requirement that all licensees maintain 5-45 NUREG-1569

., _ _ _ _ _ . _ -. . _ . ._ . _ . - ._ ..____O

a. ..u-e. . -_ _ , 44-a h-+ 4----- . , _M_.4 __~ - - + < - A8 A.4 d-ne.- 4 E-_FmJ Operations - I records used to demonstrate compliance and evaluate dose, intake, and releases to the f environment until the NRC terminates the license.

-(3) = For license renewal applications, the historical QA program results are included through .

. the most recent reporting period preceding-the submittal of the application. The effectiveness of the historical program are discussed with regard lto all applicable '

10 CFR Part 20 regulatory requirements. Long term trends are discussed, and any short term deviations from the long-term trend' arc explained. ,

J 5.7.9.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the QA program, the following conclusions may be presented in the TER.

The NRC has completed its review of the QA program at the _ ISL facility.

This review included an evaluation using the review procedures in SRP section 5.7.9.2 and the acceptance criteria outlined in SRP section 5,7.9.3.

The applicant has established an acceptable QA program at the ISL site, The QA program has been applied to all radiological, emuent, and environmental programs consistent with Regulatory Guides 4.14 (Nuclear Regulatory Commissioni 1980) and 4.15 (Nuclear Regulatory l- Commission,1979). The applicant has agreed to retain survey and instrument calibration records for 3 yr and to retain records to demonstrate compliance and evaluate dose, intake, and releases to the environment until the NRC tenninates the license.

Based on the information provided in the application and the detailed review conducted of the l QA program at the - ISL facility, the NRC staff has concluded that the QA program is

- acceptable and is in compliance with 10 CFR 20,1101, which provides requirements for radiation protection programs; 10 CFR Part 20 subpart L, which specifies record keeping requirements; and 10 CFR Part 20, subpart M, which defines reporting and notification requirements.

5.7.9.5 References l

Nuclear Regulatory Commission.1979. Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Emuent Streams and the Environment, Revision 1, Regulatory Guide ./.11 Washington, DC: Nuclear Regulatory Commission, Omce of Standards Development.

Nuclear Regulatory Commission.1980. Radiological Emuent and Environmental Monitoring at Uranium Mills, Revision 1. Regulatory Guide 4./4 Revision 1. Washington, DC: Nuclear Regulatory Commission, Omcc of Standards Development.

L NUREG-1569 5-46

6.0 GROUNDWATER-QUALITY RESTORATION, SURFACE RECLAMATION, AND PLANT DECOMMISSIONING 6.1 PLANS AND SCilEDULES FOR GROUNDWATER QUALITY RESTORATION 6.1.1 Areas of Review The staff shall review the following aspects of the groundwater quality restoration program:

(1) Estimates of the concentrations, and lateral and vertical extent of those chemicals that may persist in leached-out well field production zones afler termination of in situ operations and prior to restoration activities.

(2) Descriptions of proposed methods and techniques to be used to achieve groundwater quality restoration, including identification of in situ chemical reactions that may hinder or enhance restoration. The staff should also review descriptions of Guids to be used during restoration and the hydraulic and geochemical properties of the receiving stratum.

For commercial-scale operations, the staff shall evaluate results obtained from R&D operations.

(3) A schedule for sequential restoration of well fields.

(4) Descriptions of the expected postreclamation conditions and quality of restored groundwaters, compared with the preoperational land and water quality characteristics if there is prior experience in restoring groundwater at the site.

(5) Assessments of the proposed water quality restoration operations with respect to their adverse effects on groundwaters outside production zones.

(6) Procedures to be used for plugging, sealing, capping, and abandoning wells associated with the ISL operations.

(7) Methods of efnuent disposal, such as deep well injection, surface discharge, and land application are generally strictly regulated by the EPA and state agencies, and the applicant is responsible for ensuring such disposal methods are in compliance with applicable directives.

6.1.2 Review Procedures The statT shall review plans and schedules for groundwater quality restoration, and perform the following actions:

(1) Evaluate estimates of postextraction groundwater quality by comparison to descriptions of lixiviant composition and host rock geochemistry. Ensure that methods far estimating I

6-1 NUREG-1569 l

the affected pore volume are consistent with the methods used at the R&D site or other site upon which restoration estimates are based.

(2) Compare descriptions of restoration methods to methods that have been used successfully at R&D sites for other ISL facilities. Ensure that methods selected are appropriate for the host rock and lixiviant chemistry.

(3) Assess whether the applicant has provided a reasonable standard for the determination of restoration success and a realistic assessment of the expected postreclamation water quality by comparing standards to previous restoration work at the R&D site or other previously rpred ISL facilities.

(4) Evaluate the ability of the postreclamation stability monitoring program to verify successful restoration.

(5) Consider whether the proposed restoration program adequately addresses water quality cleanup due to well ficid Dare (undetected spread of extraction solutions between the well Geld and monitor wells of the production zone), and whether the quantity of water pumped during restoration will adversely alTect offsite groundwater uses.

(6) Assess whether plans for plugging and abandoning wells prior to license termination are consistent with generally accepted techniques.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

6.1.3 Acceptance Criteria The plans and schedules for groundwater quality restoration, surface reclamation, and plant decommissioning and acceptable if they meet the following criteria:

(1) The application includes estimates of the volume and quality of extraction solutions that need to be cleaned up during groundwater restoration.

Generally, these estimates are based on experience in ISL operations or R&D insestigations in similar host rock.

(2) The applicant describes the method used for estimating well Celd pore volume.

A pore volume is an ir. direct measure of the volume of water that must be pumped or processed to restore the groundwater. It represents the water that Olis the void space inside a certain volume of rock or sediment. Restoration costs are closely linked to the amount of water that must be processed to effect restoration. The pore volume parameter is used to represent how many times the contaminated volume of water in the rock must be displaced or processed to restore groundwater quality, it provides a means of comparing the level of etTort required to restore groundwater regardless of the scale of the test. In 6-2

general, the more pore volumes of water it takes to restore groundwater quality, the more effort it will cost to_ achieve restoration; Estimates of groundwater restoration pore volumes should take into account the effective porosity of the contaminated region and the lateral and vertical extent of contamination.

(3) The application includes well field restoration plans.

Restoration plans contain descriptions of the process to be used for well Geld restoration and projected completion schedules based on well Geld ore depletion. This description-should include restoration flow circui:s, treatment methods, methods for disposal or treatment of wastes and effluents, monitoring sche lales, a discussion of chemical additives used in the restoration process, anticipated efTects of chemical additives, and alternate techniques that may be employed in the event that primary plans are not effective.

Typleally, restoratiott is divided into distinct phases in which different techniques are employed. Groundwater sweep is used to purnp water from the ore zone without reinjecting in order to recall lixiviant from the aquifer and draw in surrounding uncontaminated water. Res erse osmosis / permeate injection circulates water from the well Geld through a reverse osmosis (RO) treatment process and reinjects the permeate into the well Geld, typically at rates similar to those used during production. Groundwater recirculation is used to evenly distribute water throughout the restored well field in order to dilute any pockets of remaining contamination. An additional acceptable restoration method is the injection of chemical reductants (usually hydrogen suindc) into the well field. These reductants are used to immobilize metals that may have been dissolved by the oxidizing lixiviant; however, some general water quality parameters, such as TDS, may be adversely affected by reductants. When chemical reductants are added, the applicant should address any additional treatment necessary to remove the reductant from the aquifer after it has served its intended purpose. Typically, this will require additional RO/ permeate injection.

The NRC promotes Dexibility and innovation in approaches to restoration. Therefore, applicants should not be limited to one restoration method for all wcll Selds. Rather they should describe the phases of restoration that may be used and the most likely restoration scenario, based on R&D results and restoration experience.

Restoration plans should also include a list of monitored constituents, a monitoring interval, and the sampling denshy (wells / acre). An acceptable constituent list should be based on production ard Nstoration solutions used and on the host rock geochemistry, in the interest of minimizing expense, 'he applicant may propose a lin,ited set of indicator constituents to monitor restoration progress and a sampling density that does not include all production and injection wells. The applicant may also propose monitoring composite samples from the restoration stream, liowever, prior to detennination of restoration success, all welk that were sampled for basel;ne conditions should be sampled for the full list of monitored constituents.

The applicant should specify the criteria that _will be used to detemiine restoration success.

Generally, the acceptance criteria for restoration success are based on the ab;lity to meet the goals of the restoration program and the absence of c signincant increasing trend during the stability monitoring period.

63 NUREG-1569

i Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning For purposes of surety bonding, restoration plans must include estimates of the level of effon, in terms of pore volume displacements, necessary to achieve primary restoration targets. These estirnations must be based on historical result; : Ained from the R&D site or experience in other well ficids having - similar hydrologic and geochemical characteristics.

(4) Restoration goals are established in the application for each of the monitorec constituents.

The applicant has the option of detennining restoration goals for each constituent on a well by well basis, or on a well field average basis. Restoration goals should be established for the ore zone and for any overlying or underlying aquifer that remains affected by ISL solutions.

(a) Primary Restoration Standards-The priraary goal for a restoration program is to return the water quality of the ore zone and affected aquifers to preoperational (baseline) water quality or better, it is unlikely that after restoration activities the groundwater quality will be returned to the exact water quality that existed at every location in the aquifer prior to ISL operations. Therefore, it is acceptable to use standard statistical methods _to set the primary restoration goal and to detennine compliance with it. At many sites, average parameters have been used to set primary restoration goals. It is also acceptable for the applicant to propose that the baseline conditions for each chemical species be represented by a range of concentrations. For example, a confidence interval of 99 percent has been found acceptable in past licensing actions (i.e., there is only a one percent probability that the true baseline falls outside of the proposed restored water quality range). The reviewer will ensure that statistical methods used to determine such confidence intervals are properly applied. The baseline average plus three standard deviations is another method for establishing primary restoration targets that has been found acceptable by the NRC.

(b) Secondary Restoration Standards-Because the ISL process requires changing the chemistry of the ore zone, it is reasonable to expect that ISI, may cause permanent changes in water quality. For this reason. it is acceptable for the applicant to propose, as a secondary restoradon standard, returning the water quality to its ISL class of use (e.g., drinking water, livestock, agricultural, or limited use). Applicatmns should state that secondary standards will not be applied so long as restoration continues to result in signilicant improvement in groundwater quality.

It is acceptable to NRC staff if, on a constituent-by constituent basis, secondary goals are determined by applying the lower of the state or EPA secondary and primary drinking water standards. For example, if preoperational water quality is not suitable for drinking water only because of high radium concentrations, then restoration must return all constituents except for radium to drinking water standards. Some uranium ISL operators have assened that if preoperational use NUREG 1569 6-4 L

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Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning is not suitable for drinking water because of one or more constituents, then it is not reasont.ble to require restoration to drinking water standards for all cther constituents. Ilowever, the NRC has maintained that if only a few constituents are above drinking water standards, then the water could reasonably be treated for use as drinking water. Thus, class of use should be considered on a constituent-by-constituent basis. For radionuclides without drinking water standards, it is acceptable to NRC staff, on a constituent-by-constituent basis, to -

determine secondary standards from the concentrations for unrestricted release to the public in water, rrom table 2, of 10 CFR Part 20, appendix B.

(c) If a groundwater parameter could not be restored to its secondary goal, an applicant would have to make a demonstration to the NRC that leaving the parameter at the higher concentration would not be a threat to public health and safety or the environment and that, on a parameter-by-parameter basis, water use would not be significantly degraded. This situation might arise with respect to the TDS parameter. TDS is a measure of the sum of all dissolved constituents, but it is most alTected by the major constituents (sulfate, chloride, calcium bicarbonate, carbonate, fiuoride, sodium, and potassium). Ilowever, not all of the major constituents have a secondary or primary drinking water standard (e.g.,

bicarbonate, carbonate, calcium, magnesium, and potassium). Consequently, it is possible that after groundwater restoration, the 1DS secondary goal might be achieved, but the secondary goal (br individual major ions that contribute to TDS might not be achieved. If such a situation occurred, the applicant would have to make a demonstration to the NRC that leaving a parameter at higher than secondary goal concentrations would not be a threat to public heahh and safety or the environment and that water use would not be significantly degraded. Such proposed alternatives must be evaluated as a license amendment request only after restoration to the primary or secondary standard is shown not to be practical.

(5) The postrestoration stability monitoring program is described in the application.

The purpose of a stability monitoring program is to ensure that chemical species of concem do not increase in concentration subsequent to restoration. The applicant should specify the length of time that stability monitoring will be conducted, the number of wells to be monito:ed, the chemical mdicatora to be monitored, and the monitoring frequency.

The NRC has previously approved stability monitoring periods as short as 9 mo with samples taken from designated monitor wells every 3 mo. These requirements will vary based on site-sp:cific postextraction water quality and geohydrologic and geochemical characteristics. Prior to fmal well field decommissioning, all designated monitor wells must be sampled for all monitored constituents. Well fields may be decommissioned when all constituent concentrations meet approsed standards and _how no strong treads in groundwater quality deterioration as a result of ISt. activities.

The application includes a discussion of the poter.tial e.stemal efTects of groundwater (6) restoration.

65 NUREG-1569

Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning Groundwater restoration operations, and the expected postreclamation groundwater quality, must not adversely affect groundwater use outside the well fields. Water users from

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nearby municipal or domestic wells that were in use prior to ISL operations should be provided reasonable assurance that their water quality will not be degraded. Degraded water quality includes changes in color, odor, and taste of water, in addition to changes in concentrations of chemical constituents in cases where such threats exist, the use of secondary restoration targets may not be appropriate. In one such case the NRC has found it acceptable to allow the ISL operator to' move municipal wells used by a nearby town to a location that would eliminate potential for degraded water quality due to ISL operations (Nuclear Regulatory Commission,1997). In this situation, it was decided that the water quality of the town well could be degraded as long as the water quality at each individual well head would not exceed EPA primary and secondary drinking water standards or a concentration of 0.44 mg/L uranium as a result of future ISL operations.

(7) Methods for abandoning wells are included in the application.

The basic purpose for sealing abandoned wells and bore holes is to restore the well field to preoperational hydrogeologic conditions. Any well or bore hole to be permanently  ;

abandoned should be completely filled in such a manner that vertical movement of water along the borehole is prevented. ISL operators usually rely on a drilling contractor to perform well abandonment. The application should specify the methods and materials to be used to plug holes, and that records documenting the well abandonment will be maintained by the licensee. Abandonment procedures that conform to ASTM Standard D 5299 (American Society for Testing and Materials,1992) or procedures from the State Engineer's Oflice are considered acceptable by the NRC. An applicant may propose other generally accepte( !andards for abandoning wells and boreholes.

References for these standards shout oc specified in the application, and copies should be kept on file by the applicant. h . . pas that are not considered to be generally accepted abandonmcnt practices should be described in detail and may require additional time for review.

(8) Descriptions of water consumption impacts.  ;

J During ISL operations, water quality impacts usually are more of a concern than water consumption impacts. This is because water consumption during ISL operations is relatively small. Ilowever, when restoration activities begin, water consumption will significantly increase. The amount of increase will depend on the restoration techniques applied. Techniques that clean up the aquifer by pumping water from the aquifer, cleaning the water, and reinjecting the clean wrter consume the least amount of water. Water consumption impacts will result in water loss from the aquifer and water level declines.

The impacts of water consumption on local wells and water users should be evaluated.

Water level declines can result in increased pumping costs or inability to obtain water from the aquifer in local wells. Water loss from the aquifer may mean that less water could be available to downgradient groundwater and surface water users.

NUREG-1569 6-6

Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning 6.1.4 Evaluation Findings If the staff s review, as described in this section, results in the acceptance of the plans and schedules for groundwater quality restoration, the following conclusions may be presented in the TER.

The NRC has completed its review of the plans and schedules for groundwater quality restoration proposed for use at the ISL facility. This review included an evaluation of the methods that will be used to develop the groundwater restoration program and schedules using the review procedures in SRP section 6.1.2 and the acceptance criteria outlined in SRP section 6.1.3.

The applicant has acceptably demonstrated that well field groundwater restoration standards will be representative of the preoperational baseline groundwater conditions. As a secondary restoration goal, the applicant has identified and committed to use the fedeial primary and secondary drinking water standards.

The applicant's method for estimating well field pore volume is acceptable taking into account the estimated elTective porosity of the contaminated region and the lateral and vertical extent of contamination. With respect to the methodology for undenaking restoration, the applicant provided an acceptable mix of groundwater sweep, reverse osmosis, and groundwater recirculation. The well-field-specific mix of these approaches will be determined as part of the groundwater restoration plan for each individual well field. In addition, the applicant has demonstrated an acceptable method for determining the extent of well field flare and for ensuring acceptable restoration of the Care. The applicant has committed to complete restoration for any well field within a 3 yr period after ore extraction ceases.

The applicant has presented an acceptable list of constituents to be monitored and has specified acceptable criteria to determine the success of restoration either on a well by-well or well field average basis. The number of pore volume replacements necessary to achieve the primary restoration targets has been provided and is acceptable. The applicant has demonstrated that the primary restoration program will return the water quality of the ore zone and alTected aquifers to pre-extraction (baseline) water quality or better, that any secondary restoration standards proposed by the appiicant are acceptable, or that final water quality will protect public health and safety and the environment in compliance with ALARA principles. The applicant's postrestoration stability monitoring program is acceptable. Any potential adverse offsite effects of groundwater restoration are acceptable.

The methods proposed for abandoning wells and sealing them to restore the well field to pre-extraction hydrologic conditions are acceptable. The applicant has evaluated the consumptive water impacts of the ISL facility using acceptable methods.

Ilased on the information provided in the application and the detailed review conducted of the plans and schedules for groundwater quality restoration for the ISL facility, the NRC staff has concluded that the proposed plans and schedules for groundwater quality restoration are acceptable and are in compliance with 10 CFR 40.32(c), requiring the applicant's proposed equipment, facilities, and procedures to be adequate to piotect health and minimize danger to life or property; 10 CFR 40.32(d), requiring that the issuance of the license will not be inimical to the common defense 6-7 NUREG-1569 i

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Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning and security or to the health and safety of the public and 10 CFR 51.45(c), which requires the applicant to provide sufficient data for the Commission to conduct an independent analysis.The related reviews of thd 10 CFR Part 51 environmental protection regulations for domestic licensing and related regulatory functions for plans and schedules for groundwater restoration in accordance with SRP sections 5.0, Operations; and 7.0, Environmental EfTects; are addressed elsewhere in this TER.

6.1.5 References American Society for Te-ting and Materials.1992. Stamfard Guidefor Decommissioning of Ground Water Wells, l'adase Zone Mmitoring Devices, and Other Devices for Environmental ActicMes, De.signation: D J299. Philadelphia, PA: American Society for Testing and Materials.

Nuclear Regulatory Commission. I997 Final Environmental h.. pact Statement to Construct and Operate the Crownpoint Uranium Solution Mining Project Crownpoint New Mexico. NUREG 1508.

Washington, DC: Nuclear Regulatory Commission.

6.2 PLANS AND SCHEDULES FOR RECLAIMING DISTURBED LANDS 6.2.1 Areas of Review

'the staff sball review all maps provided in the application showing the postreclamation conditions of afTected lands and immediate surrounding areas. The staff shall also review nocedures for (i) reclaiming temporary diversion ditches and impoundments,(ii) re-establishmg surface drainage patterns disrupted by the proposed activities, (iii) mitigating or controlling the effects of subsidence, and (iv) preparing the ground surface for postoperational use in accordance with the criteria in section 5.2 of the SRP.

NRC staff shall review preremediation the radiological survey program that will identify areas of the site that need to be cleaned up to comply with NRC concentration limits. Staff shall evaluate measurement techniques and sampling procedures proposed for detennining the radionuclide concentrations and the extent of contamination of buildings, structures, and soils. In addition, the review shall confirm that the licensee will have an approved radiation prctection program in place prior to the start of reclamation and cleanup work.

6.2.2 Review Procedtires The staff shall determine whether the described procedures for reclaiming temporary diversion ditches and impoundments, re establishing surface drainage patterns disrupted by the proposed activities, mitigating or controlling the elTects of subsidence, and preparing the ground surface for postoperational 7use are consistent with regulatory guidance and suflicient to verify that requirements equivalent to 10 CFR Part 40, appendix A, criterion 6, and 10 CFR 40.42 have been met Staff shall ensure that the ,

licensee intends to restore topography and vegetation to a state that is similar to preoperational conditions.

Staff shall resiew the prereclamation sampling plan to ensure that it provides adequate coverage to designate contaminated areas for cleanup. Particular attention shall be focussed on sampling temporary NUREG-1569 6-8 d

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Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning diversion ditches and impoundments (evaporation ponds), well field surfaces, process and storage areas, transportation routes, and operational air monitoring locations. These areas am expected to have higher levels of contamination than surrounding areas. Staff shall also ensure that plans exist for the disposal of contaminated soils at an existing licensed byproduct material disposal facility, consistent with 10 CFR Part 40, appendix A, criterion 2. StafT shall confirm that the licensee has an approved radiological protection program to ensure worker safety during decommissioning, reclamation, and cleanup activities and shall detennine whether any changes have been proposed for this program. The program for radiation protection is addressed in section 5.7 of the SRP. Staff should review the compliance history for the radiation safety program to identify any deficient areas that may require special consideration prior to the start of work.

For license renew als and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

6.2.3 Acceptance Criteria The plans and schedules for reclaiming disturbed land are acceptable if they meet the following criteria:

(1) Appropriate cleanup criteria have been considered in developing the prereclamation surveys and planned cleanup activities. Acceptable cleanup criteria are discussed in SRP sections 6.3 (for buildings and structures) and 6.4 (for soils).

(2) The prereclamation survey pro; ram for buildings, structures, and soils identifies instruments and techniques similar to the preoperational survey program to determine baseline site conditions (e.g., background radioactivity) but also takes into account results from operational monitoring and other inr crmation that provide insight to areas of expected contamination.

Survey areas should include diversion ditches, evaporation ponds, well field surfaces, buildings and structures in process and storage areas, onsite transportation routes for contaminated material and equipment, and other potentially contaminated areas. A sampling grid should be used and a statistical basis for sample size should be provided.

Acceptable methods for sampling are provided in NUREG/CR 5849, Manual for Conducting Radiological Surveys in Support of License Termination (Berger,1992). In particular, the following sections of NUREG/CR-5849 (Berger,1992) are applicable to prereclamation surveys: 2.3.2, Scoping Survey; 2.3.3, Characterization Survey; 2.3.4, Remediation Control Survey; 3, Assessing the Radiological Status of the Site; 5, Radiological Instrumentation: 6, Survey Techniques; 7, Sample Analysis; and 8, ,

Interpretation of Survey Results. l (3) The licensee provides the procedures for interpretation of the prereclamation survey results and describes how they will be used to identify candidate areas for cleanup l

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Groundwater Quality Restoration, Su*ce Reclamation, and Plant Decommissioning operations. Acceptable sursey methods are discussed in SRP Section 6.4, Procedures for Conducting Postreclamation and Decommissioning Radiological Surveys.

(4) The postreclamation survey procedure provides the survey methods and approach for complying with the requirements equivalent to 10 CM Part 40, appendix A, criterion 6 limits.

(5) The discussion of surface restoration includes a prefacility surface contour map, a description of any significant disruptions to surface features during facility construction and operation, and a description of planned activities for surface restoration that identifies any important features that cannot be estored to the pre ISL condition.

(6) Any changes to the existing NRC-approved 10 CFR Part 20-based radiation safety program that are needed to ensure safety to workers and the public are identified with appropriate justification prior to the start of decommissioning and reclamation work.

Acceptable approaches for the radiation safety program are evaluated in accordance with Section 5.7 of the SRP, Radiation Safety Controls and Monitoring.

6.2.4 Evaluation Findings If the staffs review, as described in this section, results in the acceptance of the plans and schedules for groundwater quality restoration, the following conclusions may be presented in the TER.

The NRC has completed its review of the plans and schedules for reclaiming disturbed lands proposed for use at the ISL facility. This review included an evaluation of the methods that will be used to develop the reclamation of disturbed lands program and schedules using the review procedures in SRP section 6.2.2 and the acceptance criteria outlined in SRP section 6.2.3.

The applicant has acceptable plans for a prereclamation soil survey that uses instrumentation and techniques similar to the preoperational survey used to establish baseline site conditions. The applicant has acceptably considered results from operational monitoring and other information relative to areas of expected contamination in its reclamation plans. Areas to be evaluated are acceptable and include diversion ditches, evaporation ponds, well field surfaces, buildings and structures in process and storage areas, onsite transportation routes, and other potentially contaminated areas. The applicant has proposed acceptable methodology to determine areas to be resampled or sampled with higher than normal densities. The applicant has defined appropriate procedures for the prereclamation survey and the means used to identify candidate areas for cleanup using the acquired data. An acceptable prefacility construction contour map is provided along with a description of any significant disruptions to surface features during facility construction, operation, and shut-down. An acceptable plan of activities for surface restoration including identification of any irreversible changes has been provided. The applicant has assured the NRC that any changes to the radiation safety program identified as a result of the decommissioning and reclamation uork will be identified prior to commencing the work.

NUREG-1569 6-10

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j Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning flased on the information provided in the application and the detailed review conducted of the plans and t.chedules for reclaiming disturbed lands for the ISL fadlity, the NRC staff has concluded that the proposed plans and schedules are acceptable and are in compliance with 10 CFR 4032(c), which requires the applicant's proposed equipment, facilities, and procedures to be adequate to protect health and minimize danger to life or property; 10 CFR 40.41(c), which requires the applicant to con 0ne source or byproduct material to the locations and purposes authorized in the license; '

and 10 CFR Si,45(c), which requires the applicant to provide suf0cient data for the Coramission to conduct an independent analysis. The related reviews of the 10 CFR Pan Si environmental protection regulations for domestic licensing and related regulatory functions for plans and schedules for groundwater restoration in accordance with SRP Sections 5.0, Operations; and 7.0, Environmental EITects, are addressed elsewhere in this TER.

6.2.5 References Derger, J.D. t992. Mcumalfor Conducting Radiological Surveys in Support ofLicense Termination. Draft report for comment, NUREG/CR 5849. Washington, DC: Nuclear Regulatory Commission.

6.3 PROCEDURES FOR REMOVING AND DISPOSING OF STRUCTURES AND EQUIPMENT 6.3.1 Areas of Review The staff shall review procedures for removing and disposing of contaminated structures and equipment used during ISL operations, as well as procedures for managing toxic and radioactive waste materials and for removal and disposal of structures. The reviewers shall also evaluate procedures that identify radiological hazards prior to initiating dismantlement of structures and for detection and cleanup of removable contamination from structures and equipment. Procedures and plans for ensuring that all contaminate' facilities and equipment are addressed and are either planned to be disposed in a licensed facility, will acet the contamination levels for unrestricted use, or are designated for re-use at another ISL facility shall be examined. The staff shall also review provisions made for the removal and disposal of byproduct material to an existing uranium mill or licensed disposal site.

6.3.2 Review Procetitires -

The >talT shall determine whether the procedures for removing and disposing of structures used during ISI, operations and all procedures for managing toxic and radioactive waste materials are consistent with regulatory guidance and sulTicient to meet the applicable regulatory requirements in 10 CFR 40.42.

Plans for structures and equipment to be released for unrestricted use should be reviewed in SRP Section 5.7.6, Contamination Control Program. StafT shall confirm that plans for dismantlement of structures and equipment include a preliminary assessment of anticipated hazards that should be considered prior to dismantlement. This shall include the use of appropiiate suney methods to determine the extent of contamination of equipment and structures before starting decommissioning and reclamation work.

Particular attention shall be focussed on those parts of the processing system that are likely to have accumulated contamination over long time periods such as pipes, sentilation equipment, efnuent control 6-11 NUREG-1569 1

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Groundwater Quality Restoration, Surface Reclamation.

- and Plant Decommissioning systems, and facilities and equipment used in or near the yellowcake dryer area. The staff shall also review provisions made for the removal and disposal of by product mater,al to an existing uranium mill or licensed disposal site to ensure that they meet requirements of 10 CFR Part 40, appendix A, criteria.

l'or license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

6.3.3 Acceptance Criteria The procedures ror removing and disposing of structures and equipment are acceptable if they meet the following criteria:

(1) A program is in place to control residual contamination on structures and equipment.

(2) Measurements of radioactivity on the interior surfaces of pipes, drain lines, and ductwork will be determined by makir.g measurements at all traps and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, and ductwork.

(3) Surfaces of premises, equipment, or scrap that are likely to be contaminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement are presumed to be contaminated in excess of the limits.

(4) Prior to release of premises for unrestricted use, the licensee will make a comprehensive radiation suncy to es:ablish that contamination is within the limits specified in SRP Section 5.7.6, Contamination Control Program.

(5) A contract between the licensee and a waste disposal operator should be in existence to dispose of Ile.2 byproduct material.

6.3.4 Evaluation Findings if the stalTs review, as described in this section, results in the acceptance of the procedures for removing and disposing of structures and equipment, the following conclusions may be presented in the TER.

The NRC has completed its review of the procedures for removing and disposing of structures and equipment proposed for use at the ISL facility. This review included an evaluation of the methods that will be used to develop the procedures for removing and disposing of structures and equipment using the review procedures in SRP section 6.3.2 and the acceptance criteria outlined in SRP section 6]J.

NUREG-1569 6-12 i

Groundwater Quality Restoration, Surface Reclamation,

' and Plant Decommissioning The applicant has established an acceptable program for the elimination of residual contamination on structures and equipment. The applicant has made acceptable plans for measurements of radioactivity on the interior surfaces of pipes, drain lines, and ductwork by making appropriate measurements at all traps, and other access points where contamination is likely to be representative of system wide contamination. All premises, equipment, or scrap likely to be contaminated but which cannot be measured, have been assumed by the applicant to be contaminated in excess oflimits and will be treated accordingly.

For all premises, equipment, or scrap contaminated in excess of specified limits, the applicant has provided detailc<!, specine infermation describing the premises, equipment or scrap in terms of extent and degree of radiological contamination. The applicant has provided an acceptable detailed health and safety analysis that reDects that the contamination and any use of the premises, equipment, or scrap will not result in an unreasonable risk to the health and safety of the public or the environment. The applicant plans to conduct a comprehensive radiation survey to establish that any contamination is within limits specified prier to the release of the premises, equipment, or scrap. The applicant will file a copy of the sucvey report with the NRC OITice of Nuclear Material Safety and Safeguards (NMSS), Uranium Recovery Branch. The report will include identification of the premises, documentation that a reasonable effort has been made to eliminate residual contamination, and a description of the scope of the survey and the general procedures that were utilized, llased on the information provided in the application and the detailed review conducted cDhe procedures for removing and disposing of structures and equipment for the ISL facdhy, the NRC staff has concluded that the procedures are acceptable and are in compliance with 10 CFR 40.32(c), which requires the applicant's proposed equipment, facilities, and procedures to be adequate to protect health and minimize danger to life or property; 10 CFR 40,41(c), which requires the applicant to con 0ne source or byproduct material to the locations and purposes authorized in the license; and 10 CFR 40.31(f), which requires inclusion of an ER in the application. The related reviews of the 10 CFR Part 51 environmental protection regulations for domestic licensing and related regulatoiy functions for plans and schedules for groundwater restoration in accordance with SRP sections 5.0, Operations, and 7.0, Environmental Effects; are addressed elsewhere in this TER.

6.3.5 References None.

6.4 PROCEDURES FOR CONDUCTING POSTRECLAMATION AND DECOMMISSIONING RADIOLOGICAL SURVEYS 6.4.1 Areas of Review The staff shall review procedures for conducting postreclamation and decommissioning radiological surveys, including postoperational groundwater monitoring for decontamination and removal of structures and equipment. The NRC staff should review the radiological verification survey program that will serve as a basis for detemiining compliance with NRC concentration limits. Staff should evaluate measurement techniques and sampling procedures proposed.

6-13 NUREG 1569

Groundwater Quality Restoration, Surface Reclamation, ard Plant Decommissioning 6.4.2 Review Procedures The stafT shall determine whether the procedures for conducting postreclamation and decommissioning radiological suneys are acceptable to verify that concentration limits similar to those in 10 CFR Pad 40, appendix A, criterion 6 cre met. StafT shan ensure that sampling fregt.encies and locations are acceptable and representative of conditions at the site. Staff shall consider the survey methods provided in NUREG/CR 5849 (Ilerger,1992) s.long with the applicable site conditions to determine the acceptability of the licensee's proposed samplirg program. Staff shall con 6rm that the determination of background concentrations of radium 226 and other radionuclides is based upon sampling in uncontaminated areas near the r.ite. Other radionuclides that should be sampled for if suspected to be present included thorium 230, thorium 232, uranium; and lead 210 should also be determined if suspected to be present.

If elevated levels of radionuclides other than radium are expected to remain after the radium 226 criteria have been met, the reviewer will determine whether an appropriate approach for cleanup and scrification is presented in the reclamation plan.

6.4.3 Acceptance Criteria The procedures for conducting postreclamation and decommisst aing radiological surveys are acceptable if they meet the following criteria:

(1) The cleanup criteria for radium in soils are met as provided in 10 CFR Part 40, appendix A, criterion 6-(6).

This criterion states that the design requirements for longevity and control of radon releases apply to any portion of : ensed and/or disposal site unless such portion contains a concentration of radium in land, averaged over areas of 100 square meters, which as a result of byproduct material, does not exceed the background level by more than (i) 5 picocuries per gram (pCi/g) of radium-226. or, in the case of thorium byproduct material, radium-228, averaged over the Grst 15 cm below the surface, and (ii) 15 pCilg of radium-226, or, in the case of thorium byproduct material, radium 228, averaged over 15-cm thick layers more than 15 cm below the surface.

(2) Ilackground radionuclide concentrations are determined using appropriate methods as described in Section 2.9 of the SRP.

(3) Acceptable cleanup criteria for uranium in soil are as follows:

NUREG-1569 6-14

Groundwater Quality Restoration, Surface Reclamation,  ;

and Plant Decommissioning (a) - 10 pCi/g total uranium, with (or without) decay products in secubr equilibrium, with no restriction on burial method.

(b) 30 pCi/g total uranium, with no decay products present, with no restriction on burial method.

(c) liigher concentrations are acceptable if the materials are buried at least 4 ft below the surface and if it can be demonstrated that the buried materials will be stabilized in place and not be transported away from the site. An NRC Branch Technical Position on disposal of thorium or uranium (NRC,1981) describes acceptable concentrations and criteria that must be met for this option to be

.pplied.

(4) For areas that already mest the radium cleanup criteria, but that still have elevated thorium levels, an acceptable cleanup criterion for thorium 230 is that concentration which, combined with the residual concentration of radium 226, would result in the radium concentration (residual and from thorium decay) that ^ould be present in 1,000 yr me-ting the radium cleanup standard.

An acceptable altemate criteria for a deeply buried thorium deposit would be to determine, for a 1,000 year period, that the amount of radon that could exit into a 100 m' structure built over that deposit would meet the EPA radon progeny standard for habitable structures (0.02 WL).

(5) The survey method for veri 6 cation of soit cleanup is designed to provide 95 percent con 6dence that the survey units meet the cleanup guidelines. Appropriate statistical tests for analysis of survey data are described in sections 8.5.4 and 8.5.5 of NUREG/CR-5849 2

(Berger,1992). For verification of radium 226 in soil, each survey unit is a 100 m (or smaller) area, based on the r quirements of the cleanup criterion.

(a) For veri 6 cation of radiv:n 226 in soil, the following sampling program is acceptable. In each 100 m' area, one 9-plug composite soil sample is collected.

If this sampling method is used, the sampling error / uncertainty would haw to be considered in performing the statistical comparison.

(b) For veri 6 cation of radium 226 in soil, an acceptable alternative sampling and measurement program is the following. Regressions can be developed between gamma scan measurements and concentrations of radium 226 in soil. The gamma scans can be used as the primary veri 6 cation techniqee, with a percentage of the 100 m' areas being sampled as above. Typically,5 to 10 percent of the 100 m' areas should be sampled, although lower percentages ce acceptable if the statistical comparison test is still met. For performing the statistical comparison, the uncertainty in predicted concentrations from the regression must be considered.

6-15 NUREG-1569 j 1

l

Oroundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning (c) For veriDeation of other radionuclMes in soil, methods similar to the above may be used, as long as the sampling or measurement technique is determined to be appropriate fer the radionuclide being measured.

(6) Acceptable surface contamination levels for equipment and structures are provided in table 5.7-1.

6.4.4 Evaiuation Findings if the staffs review, as described in this section, re 'ilts in the acceptance of the procedures for conducting postreclamation and decommissioning radiological surveys, the following conclusions may be presented in the TER.

The NRC has completed its review of the postreclamation and decommissioning radiological surveys proposed for use at the _ ISL facility. This review included an evaluation of the metheds that will be used for the postreclamation and decommissioning radiological surveys using the review procedures in SRP section 6.4.2 and the acceptance criteria outlined in SRP section 6.4.3.

The applicant has developed an acceptable program for cleanup of radium that demonstrates that the rudium concentration is the upper 15 cm of soil will not exceed 5 pCilg and in subsequent 15 cm i

layers will not exceed 5 pCilg. The applicant has established an acceptable program for c eanup of total uranium at 10 pCilg or less with decay products in secular equilibrium; 30 pCi!g or less with no decay products present; or higher concentrations if buried at least 4 n beneath the surface, and it has been demonstrated that the uranium will be stabilized in place. The applicant has an acceptable plan for cleaning up areas with elevated thorium levels by continuing reclamation until the radium activity (residual and from thorium decay) that would be present in 1,000 yr will be 5 pCi/g or less in the top 15 cm of soil and 15 pCilg or less in subsequent 15 cm layers standards, or the applicant has demonstrated that for a 2

deeply-buried thorium deposit, the amount of radon that could exit into a 100 m structure built over that deposit would meet the EPA radon progeny standard for habitable structures. The applicant has acceptably sampled for thorium and has ensured that habitable buildings to remain onsite will be evaluated against the EPA radon progeny standard and that interior gan.ma levels are demonstratcd to meet the EPA standard. The applicant has acceptably demonstrated that the survey methods employed to determine contamination on facilities and equipment are suf6cient to show compliance with the NRC limits on decontamination of facilities and equipment destined for unrestricted use.

Ih sed on the infonnation provided in the application and the detailed review conducted of the procedures for conducting postreclamation and decommissioning radiological surveys for the ISL facility, the NRC staff has concluded that the procedures are acceptable and are in compliance with 10 CFR 40.32(c), which requires the applicant's proposed equipment, facilities, and procedures to be adequate to protect health and minimize danger to life or propeny; 10 CFR 40.32(d),

which requires that the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public; 10 CFR 40.41(c) which requires the applicant to con 0ne source or byproduct material to the h> cations and purposes authorized in the license; 10 CFR Part 40, appendix A, criteria 6 and 7, which provide groundwater standards and groundwater monitoring requirements NUREG-1569 6-16

l l

Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning necessary to comply with these standards; and 10 CFR S t.45(c), which requires the applicant to provide sullicient data for the Commission to conduct an independent analysis, The related reviews of the 10 CFR Part 51 environmental protection regulations for domestic licensing and related regulatory functions for plans and schedules for groundwater restoration in accordance with SRP sections 5.0, Operations; and 7.0, Environmental Effects; are addressed elsewhere in this TER, 6.4.5 References Berger, J.D.1992. Mnwalfor Conducting Radiological Surveys in Support of License Termination. Drafi report for comment. NUREG/CR 5849 Washington, DC: Nuclear Regulatory Commission.

Nuclear Regulatory Commissior,,1981, Disposal or On-site Storage of Thorium or Uranium Wastes From Past Operatis s, Federal Register, vol. 46, p. 52061, October 23,1981, 6.5 FINANCIAL ASSESSMENT FOR GROUNDWATER RESTORATION, 3 DECOhlh11SSIONING, RECLAh!ATION, WASTE DISPOSAL, AND A10NITORING 6.5.1 Areas of Review The stafT shall revbw financial essessments provided by the applicant for the costs of groundwater restoration (section 6.1); reclamation (section 6.2); and decommissionine waste disposal, and monitoring (section 6.4). These assessments may be provided in the form of a narrative or as an appendix The staff shall review provisions for a financial surety similar to those contained in criterion 9 of 10 CFF. Part 40, appendix A.

6.5.2 Review Procedures The staff shall review the financial surety assessment provided by the applicant to verify that the activities incorporated in the financial assessment are consistent with the activities proposed in the application. In addition, the reviewer shall verify that the activities proposed in the application are included in the financial assessments. The purpose of the financial surety is to provide sufficient resources for completion of reclamation of the facility including building decommissioning and well-field restoration and soil decommissioning by an independent contractor if necessary.

The reviewer shall determine whether the assumptions for the financial surety analysis are consistent with what is known about the site (SRP section 2.0) and the design and operations of the facility and its efiluent control system (SRP sections 3.0, 4.0, and 5.0). To the extent possible, the applicant shouki base these assumptions on experience from generally accepted industry practices, from R&D activities at the site, or from previous operating experience in the 2,e of a license renewal. The values used in the analysis should be based on current dollars (or adjustui for inflation) and reasonable values for the costs of various activities. The reviewer shall also examine the type of financial instrument proposed fi)r the surety to ensure that it is in accordance with the requirements of 10 CFR Part 40, appendix A, criterion 9.

6-17 NUREG-1569

Groundwater Quality Restoration, Surface Reclamation, and Plant Decornmissioning for license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

6.5.3 Acceptance Criteria The Gnancial assessment for groundwater rt-, oration, decommissioning, reclamation, waste disposal, and monitoring is acceptable if it meets the following criteria:

(1) The bases for establishing a financial surety are provided in accordance with those found in 10 CFR Part 40, appendix A, criterion 9. Surety for well Gelds is usually established as they go into ptoducti>>n. Once accepted, the surety will be teviewed annually by NRC la assure that sufficient funds would be available for completion of the reclamation plan by an independent contractor. Detailed guidance ca reviewing financial assessments for 151, operations is found in appendix E of this SRr ,

(2) All activities included in the financial analysis are activities that are included either in the reclamation plan or in sections 6.1 through 6.4, (3) All activities included either in the reclamation plan or in sections 6.1 through 6.4 are

,acluded in the financial analysis.

(4) 1he assumptions used for the financial surety analysis are consistent with what is known about the site (SRP section 2.0) and the design and operations of the facility and its ellinent control system (SRP sections 3 0, 4.0 and 5.0). To the extent ponible, the applicant has based these assumptions on experience from generally accepted industry practices, R&D at the site, or previous operating experience in the case of a license renewal.

t (5) The appfi, ant commits to funding the approved unancial surety through one of the mechanisms described in Regulatory Guide 3.66 (Nuclear Regulatory Commmission, 1990).

6.5.4 Evaluation Findings if the stafi's review, as described in this section, results in the acceptance of the financial assessment for groundwater restoration, decommissioning, reclamation, waste disposal, and monitoring, the following conclusions may be presented in the TER.

i The NRC has completed its review of the procedures for conducting Snancial assessment for i groundwater restoration, decommissioning, reclamation, waste disposal, and monitoring proposed for use l

at the ISL facility. This review included an evaluation of the methods that will be used 1 develop the procedures using the review procedures in SRP section 6.5.2 and the acceptance criteria outlined in SRF section 6.5.3.

NUREG 1569 6-18 i

i

,_.7., ..., .,

Groundwater Quality Restoration, Surface Reclamation, and Plant Decommissioning The applicant has established an acceptable financial surety based on the requirerm ,ts in 10 CFR Part 40, appendix A, criterien 9. The applicant has assured that sufficient funds v -euld be available for completion of the reclarnailon plan by an independent contractor. The applicant has included in the financial analyses all the activities in the reclamatioa pina or in sections 6.1 through 6.4 of the SRP.

The applicant has based the assumptions for financial surety analpis on site conditions including experiences with generally accepted industry practices, Re D at the site, and previous operating experience (in the case of a license renewal). The values used in the fiancial surety analysis are based on current dollars (or adjusted for inflation) and reasonable costs for the required reclamation activities are defined.

1he financial instrument proposed is a (i) surety bond, (ii) eash deposit, (iii) certificate of deposit, (iv) deposit of a govemment security (v) irrevocable letters or lines of credit, or (vi) combinations of the above that meet the total surety requirements (select appropriate descr.ption) and is acceptable.

Ilased on the information provided in the application and the detailed review conducted of the procedures for conducting the financial assessment for groundwater restoration, decommissioning, reclamation, waste disposal, and monitoring for the _ , _

ISI. facility, the NRC stalT has concluded that the procedures are acceptable and are ;n compliance with 10 CFR Part 40, criterion 9, which requires financial surety arrangements be establishca by each operator, t he related reviews of the l') CFP Part 51 environmental protection regulations for domestic licensing and related regulatory functions for plans and schedules for groundwater restoration in accordance with SRP sections 5.0, Operations, and 7.0, Environmental Effects; are addressed elsewhere in this TER.

6.5.5 References Nuclear Regulatory Commission,1990, Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72.

Regulatory Guide 3,66, Washington DC: Nuclear Regulatory comrnisolon, Of fice of Nuclear Regulatory Research, 6-19 NUREG-1569

l 7.0 ENVIRONMENTAL EFFECTS  !

i 7.1 SITE PREPARATION AND CONSTRUCTION 7.1.1 Areas of Review The staff shall review how construction activities may disturb the existing terrain and wildlife habitats, including the effects of such activities as building temporary or permanent roads, bridges, or service lines; disposing of trash; excavating; and land filling. The staff shall also review infonnation on how much land will be disturbed and for how long and whether there will be dust or smoke problems.

The staff shall review data indicating the proximity of human populations and identifying undesirable impacts on their environment arising from noise, disruption of stock grazing patterns, and inconvenience due to the moecment of men, material, or machines, including activities associated with any provision of housing, transportation, and educational facilities for workers and their families. Descriptions of any eyected changes in accessibility to historic and archeological sites in the region shall be assessed.

Discussions of measures designed to mitigate or reverse undesirable clTects such as crosion control, dust

- stabiliation, landscape restoration, control of truck traflic, and restoration of afrected habitats shall be reviewed. The staff shall also evaluate any discussion on the beneficial effects of site preparation ,

constn.ttion activitles.

The staff shall review the impact of site preparation and construction activities on area water

- roources and the effects of these activities on fish and wildlife resources, water q ality, water supply, aesthetics, etc., as applicable. Reviewers shall evaluate measures such as pollution control and other l procedures for habitat improvement to mitigate undesirable effects. ,

J 7.1.2 Review Procedures The staff shall determine if the application adequately addresses how site preparation and construction activities may disturb the existing terrain, wildlife habitats, and area water sources. The consequences of these activities to both human and wildlife populations shall be considered. The descriptions should be adequately supported by site-specific data, well documented calculations, and accepted modeling studies. The discussion should include those impacts that are unavoidable as well as those that are irreversible. Staff shall ensure that the applicant provides infonnation pertaining to how much land will be disturbed and for how long. StalT shall conGrm that the efTects of the following activities and circumstances, where applicable, are addressed: the building of temporary or pennanent roads, bridges, or service lines; disposing of tash; e3.cavating and land filling; and the potential for dust '

and smoke problems. The proximity of site activities to nearby human populations shall be addressed as well as anticipated impacts on their environment including noise; disruption of grning patterns; inconvenience due to movement of material and machines; cfTects arising from additional housing, transportation, and educational facilities for workers and families; and any disruption in access to historic or archeological sites. Staff shall ensure that mitigation measures that are adequate to alleviate or significantly reduce environmental impacts are discussed. Examples of mitigation measures include erosion control, dust stabilintion, landscape restoration, control of truck traflic, and res' oration of affected habitats.

The staff shall also evaluate any discussion of potential beneficial clTects from site prepration and construction to the extent that such might counteract detrimental effects.

71 NUREG-1569

-,-r --gww,e -e- ,.m- ~ w a v w wp- w m.,w-m --w, ,+e, we 4 ,e-e- --~~- +- e ,.e--..r-y u-a~--,se-~ws + ,w-m e, ee o e--~-v --w--,wa

for license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7.1.3 Acceptance Criteria 1 The environmental impacts of site preparation and construction are acceptable if they meet the following criteria:

(1) All envirornnental impacts from construction activities are adequately described and supported with site specine data and, where applicable, modeling studies and calculations.

A thorough discussion of all construction activities should be provided with assoelated impacts including the generation and control of wastes; dusts; smoke; noise; trame congestion; disruption of local public services, routines, and property; and aesthetic impacts.

(2) The applicant adequately describes all unavoidable and irreversible impacts to both the natural environment and nearby human populations.

(3) The applicant adequately describes the amount of land to be disturbed and the amount of time it will be disturbed.

(4) The applicant recommends reasonable mitigation measures for all significant impacts.

(5) The applicant demonstrates that land can be restored to original characteristics.

7.1.4 Evaluadon Findings If the staffs review, as described in this section, results in the acceptance of the site preparation and construction plans, the following conclusions may be presented in the TER.

The NRC has completed its review of the plans for site preparation and construction proposed for use at the ISL facility. This review included an evaluation of the methods that w;ll be used to conduct the site preparation and construction using the review procedures in SRP section , l.2 and the acceptance criteria outlined in SRP section 7.1.3.

The applicant has acceptably identified all environmental impacts from construction activities including waste generation, dusts; smoke; noise; trame congestion; disruption of public services, routines, and propeny; and aesthetic impacts. The applicants's plans are supponed with site specific data and modeling studies or calculations w here applicable. The effects of all unavoidable and irreversible impacts on the natural environment and humans are acceptable. Disturbance of land and the length and nature of the disturbance are acceptably described. The applicant has recommended appropriate mitigation measures for all signi0 cant impacts. The applicant has determined that the land can be retumed to its original use aller cessation of ISL operations.

l 72 l

l

1 Environmental Effects linsed on the information provided in the application and the detailed review conducted of the site preparation and construction plans for the ISL facility, the NRC staff has concluded that the proposed site preparation and construction are acceptable and are in compliance with 10 CFR 40.32(c), which requires the applicant's proposed equipmeat, facilities, and procedures to be adequate to protect health and minimire danger to life or property; 10 CFR 40.32(d), which requires that the issuance of the license wol not be inimical to the common defense and security or to the health and safety of the public; 10 CFR 40.41(c), requiring the applicant to confine source or byproduct material to the location and purposes authorized in the license; appendix A, criteria 5 and 7. hich provide groundw.ter standards and groundwater monitoring requirements necessary to comply with these standards; and to CFR $1.45(c), which tequires the applicant to provide sufficient data for the Commission to conduct an independent analysis.

7.1.5 References None.

7.2 EFFECTS OF OPERATIONS 7.2.1 Areas of Review The staff shall review dircussions in the application that address the impact of facility operations on the environment, including surfaca water bodies, groundwater, sir, land, land use, ecological systems, and h iportant plants and animals as discussed in section 2.0 of the SRP, 7.2.2 Review Procedures The staff shall determine whether the application addresses the environmental impact of facility operations on the environment, including surface water bodies, groundwater, air, land, land use, ecological systems, and important plants and animals. The staff s, hall detennine whether the supporting evidence is based on and supported by theoretical, laboratory, onsite, or field studies undertaken for this or for previous operations.

The stafT shall determine whether the proposed facility provides for the protection of groundwater from the environmental effects of operations, in conducting the review, the staff shall focus on the (i) characteristics of the hydrological system, (ii) effluent control systems, (iii) groundwater monitoring and surface water monitoring programs, and (iv) the groundwater restoration program pmvided in the application. This information should provide a strong basis for determining the overall effects of potential impacts to the groundwater system, such as lixiviant excursions, infiltration from spills, or ruptures of wells.

StafT shall ensure that, if surface water exists onsite or is connected to offsite surface water systems, impacts of operations on surface water are assessed and mitigation measures are provided if a significant potential for impacts is identified. Potential impacts might include siltation from disruption of surface ground cover or changes to surface drainage patterns. Staff shall also detennine whether the applicant has assessed the potential for decreased air quality resulting from dust loading due to truck 73 NUREO 1569

Environmental Effects traf 0c on dirt roads and exposure of disturbed surface soils to wind. Radiological impacts to air from operations are discussed in the following sections.

In conducting the review, the staff shall consider the applicant's ecological information as reviewed in ser, tion 3.0 of the SRP to detennine if any endangered or sensitive species of plants and i animals exist on she. The level of concern for ecological impacts of operations will be afTected by ti,e presente of any sr.h sensitive or endangered species. For most facilities, the ecological impacts are espected to be minimal during this period due to the lach of surface disruption during operations. The staff review shall ensure that measures have been taken to restrict tenestrial animals from entering facility grounda by use of fencing and other means. In areas used by migrating waterfowl, additional measures may need to be taken to ensure that any evaporation ponds are not used by waterfowl. Local ecological conditions may be such that the facility grounds provide favorable habitat for local wildlife, and efforts to minimlic contact between wildlife and contaminated areas should be considered. These efforts will serve to tr'tigate immediate impacts on kical species, but will also serve to limit introduction of contamination into the food chain.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applicat6.

7.2.3 Acceptarice Criterh 1he environmental impacts from operations are acceptable if they meet the following criteria:

(1) All anticipated signincant environmental impacts from facility operations are identined and the applicant provides (i) mitigation measures for these impacts,(ii) Justincation for why impacts cannot be mitigated, or (iii)Justi0 cation for why it is not necessary to mitigate these impacts to protect the local environment.

(2) At a rninimum, the applicant demonstrates that the anticipated impacts to tenestrial ecology, air quality, surface and groundwater systems, and land use are environmentally acceptable.

7.2.4 Evaluatiori Findings if the staffs review, as described in this section, results in the acceptance of the effects of operations, the following conclusions may be presented in the TER.

The NRC has completed its review of the effects of operations proposed at the ISL facility.1his resiew included an evaluation of the methods that will be used to evaluate elTects of operations using the review procedures in SRP section 7.2.2 and the acceptance criteria outlined in SRP section 7.2.3.

The applicant has acceptably described all anticipated signi0 cant environmental impacts from facility operations. The applicant has provided acceptable (i) mitigation of such impacts,(ii) justi0 cation NUREG-1569 74

Environmental Effects of why impacts cannot be mitigated, or (iii) Justification of why it is not necessary to mitigate the impacts '

to protect the local environment. The applicant has demonstrated that anticipated impacts to terrestrial ecology, air quality, surface and gioundwater systems, and land use are environmentally acceptable. j i

liased on the infonnation provided in the application and the detailed review conducted of the effects of operations on the ISL facility, the NRC staff has concluded that the anticipated efTects of operations are acceptable and are in compliance with 10 CFR 40.41(c), which i

requires the applicant to confine source or byproduct material to the location and purposes authorized in the license; and 10 CrR St.45(c), which requires the applicant to provide sufficient data for the Commission to conduct an independent analysis.

7.2.5 References None.

7.3 RADIOLOGICAL EFITCTS 7.3.1 Exposure Pathways .

The staff shall review infonnation on the radiological effects of operations on humans, including estimates of the radiological impacts from all exposure pathways. The staff shall evaluate descriptions of the plant operations with special attention to potential pathways for radiation exposure of humans. Staff shall review infonnation on accumulation of radioactive material in specific compartments and should ensure that both internal and external doses are included in the analysis. This infonnation can be tabulated using the outline provided in appendix A of the SfCG (Nuclear Regulatory Commission,1982).

7.3.1.1 Exposures from Water Pathways 7.3.1.1.1 Areas of Review The stafT shall review the estimates of annual average concentrations of radioactive nuclides in receiving water at the site boundary and at locations where water is consumed or is otherwise used by humans or where it is inhabited by biota of significance to human food chains. The review shall include the data presented in support of these estimates, intluding details of models and assumptions used in supporting calculations of total annual whole body and organ doses to individuals m the offsite population from all receiving water exposure pathways as well as any dilution factors used in these calculations.

Additionally, staff shall review estimates of radionuclide concentration in aquatic and terrestrial food chains and associated bioaccumulation factors. Stafr shall evaluate calculations of internal and external doses. If there are no waterbome efiluents from the facility, then these analyses are not needed. Details of models and assumptions used in calculations may be provided in an appendix to the application.

7.3.1.1.2 Review Procedures The staff shall determine whether the concentration estimates at the site boundary meet the regulatory requirements in 10 CFR 20.1302(bX2)(i) with regard to annual average concentrations of 7-5 NUREG 1569

. , , , - - ,,,-- -- - . . ,,-,,,n_, - ,

Environtnental Effects radioactive nuclides in liquid emnrts. Staff shall also check to ensure that calculations of concentrations base been done for receiving water at locations where water is consumed or is otherwise used by humans or where it is inhabited by biota of significance to human food chains to meet public dose limits in 10 Cl R 20.1301, which incorporates the requirements of 40 CFR Part 190. if the liquid emuent dose is calculated separately from the air pathway dose, it is important that the staff ensures that the results can be summed with the air pathway dose for the total dose comparison to the limit in 10 CFR 20.1301. The staff shall also determine whether these estimates are supported by properly interpreted data, calculations, and model results using reasonable assumptions. Staff shall review the parameter selections including the Justifications provided for important parameters used in the dose calculation. Staff shall check the input data for all modeling results to ensure the parameters discussed in the application are the same as those used in the modeling. Code outputs shall be spot checked to ensure that the results are correctly reported in the application. For simple hand calculations, spot calculations can be used to verify that they were donc correctly.

I or license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7.3.1.l.3 Acceptance Criteria The exposures from water pathways are acceptable if they meet the following criteria:

(I) The estirnates of individual exposure to radionuclides at the site boundary meet the regulatory requirements in 10 CFR 20.1302(bX2Xi) with regard to annual average concentrations of radioactive nuclides in liquid emuents, or the dose limit in 10 CFR 20.1301.

(2) Calculations of concentrations of radionuclides in receiving water at locations w here water is consumed or is otherwise used by humans or where it is inhabited by blota of significance to human food chains are included in the compliance demonstration for public dose limits in 10 CFR 20.1301.

(3) For facilities that generate liquid emuents, the relevant exposure pathways are included in a pathway diagram provided by the applicant.

(4) The conceptual model(scenarios and exposure pathways)is similar to and consistent with the methodology for liquid emuent exposure pathways in Regulatory Guide 1.109 (Nuclear Regulatory Commission,1977).

(5) The conceptual model used for calculating the source term and individual exposures (and/or concentrations of radionuclides) from liquid emuents at the facility boundary is representative of conditions described at the site as reviewed in section 2.0 of the SRP.

(6) The parameters used to estimate the source tenn, environmerital concentrations, and l exposures are applicable to conditions at the site as reviewed in section 2.0 of the SRP.

l NUREG 1569 76

Environmental Effects 7.3.1.l A Evaluation Findings 1

If the staffs review, as described in this section, results in the acceptance of the exposures from i water pathways, the following conclusions may be presented in the TER. (

1

'lhe NRC has completed its review of the radiological effects of exposure from water pathways at the ISL facility. This review included an evaluation of the methods that will be used to evaluate radiologi'al effects using the review procedures in SRP section 7.3.1.1.2 and the acceptance criteria outlined in SRP section 7.3.1.1.3.

The applicant's estimates of individual exposure to radionuclides from water pathways at the site boundary are acceptable since they are less than the requirements in 10 CFR 20.132 (bX2Xi) with regard to annual average concentrations in liquid ellluents, or they are less than the dose limit in l 10 CFR 20.1301. The applicant has dernonstrated that the concentrations of radionuclides in receiving l water wheie it is consumed or otherwise used by humans, or where it is inhabited by biota significant to )

the human food chain are ;n compliance with the public dose limits in 10 CFR 20.1301. The applicant ,

has included the relevant pathway ding ams in the application. The applicant has used an acceptable representation of the conditions at the site in the detennination of the source tenn for the model calculations. The applicant has acceptable values for parameters used to estimate the source tenn, environmental concentrations, and exposures and the parameters are representative of the site.

7.3.1.1.5 References Nuclear Regulatory Commission,1977, Calculation of Annual Doses to Man From Roetine Releases of Reactor Efiluents for the Purpose of Evaluating Compliance With 10 CFR Part 50, Appendix 1, Revision, Regulatory guide 1.109, Washington, D.C., Nuclear Regulatory Commission, Office of Standards Development.

Nuclear Regulatory Commission.1982. Standard Fonnat and Content of License Applications, including Environmental Reports, for /n Situ Uranium Solution Mining (SFCG), June. Regulatory Guide M6. Washington, DC: Nuclear Regulatory Commission, Office of Standards Develooment.

7.3.1.2 Exposures from Air Pathways 7.3.1.2.1 Areas of Review The staff shall review estimated release rates of airbome radioactivity considering applicable meteorological data as reviewed in section 2.0 of the SRP. The staff shall then review the estimates of annual total body and organ doses to individuals including (i) at the point of maximum ground level concentration offsite, (ii) at the site boundary in the direction of the prevailing wind, (iii) at the site boundary nearest the emission source, and (iv) at the nearest residence in the direction of the prevailing wind. The applicant can choose to show compliance with a concentration limit or w"h individual dose limits. Therefore, the staff shall initially detennine the method of compliance chan by the applicant and focus the review accordingly. Regardless of which compliance method is chosen. the reviewer shall also 77 NUREG 1569

Environmental Effects need to evaluate an individual dose to the public to comply with the requirements in 10 CFR 20.1301. The staff shall resiew data, models, calculations, and assumptions used in support of these estimates. The review shall consider both the source tenn and exposure pathway components of the calculation and shall include deposition of radioactive material on food crops and pasture grass.

7.3.1.2.2 Resiew Procedures lhe staff sh 11 detennine whether the estimates of annual total body and organ doses to individuals at the point of maximum ground level concentrations off site, individuals exposed at the site boundary in the direction of prevailing wind, individuals exposed at the site boundary nearest to the sources of emissions, and individuals expnsed at the nearest residence in the direction of the prevailing wind meet the regulatory requirements in 10 CFR 20.1301 and 40 CFR 190.10. The staff shall also determine whether these estimates are supported by properly interpreted data, calculations, and model results using reasonable assumptions.

An acceptable computer code that calculates offsite doses to individuals from airborne emissions from ISL facilities in MILDOS AREA (Yuan et al,1989). This code does not calculate the source term.

Therefore, the applicant must provide documentation of the source tenn calculation that is used as input to MILDOS AREA, if this code is used. StafT shall review the source term equation to ensure that it !s an accurate estimation of all significant airborne releases from the facility including, where applicable, yellowcake dust from the dryer stack and radon emissions from processing tank venting and well field releases. If a closed processing loop is used, then radon release from processing is expected to be negligible. If a vacuum dryer is used for yellowcake, then dust emissions from drying will also be assumed to be negligible. StalT shall focus attention on the values used for the production flow and the fraction of this flow that is expected to be released during operations. A reasonable estimate of well field radon release is about 25 percent. Staff shall also ensure that the source term calculation accounts for all material released during start up, production, and restoration activities. t The review of the MILDOS-AREA calculation shall focus on the code input provided by the applicant. The applicant should have provided a list of the relevant parameter information that was used.

The infonnation from this list shall be compared with the input from the code nm to ensure that the correct values have been used. Dose results from the code output should be checked against the tabulated results in the application to ensure that the values have been correctly reported. Staff shall also evaluate warning messages that the code provides in the output to identify anomalies in the input data or problems with the run. If reported results appear anomalous, staff may conduct confirmatory analyses using MILIX)S AREA.

For license renew als and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

NUREG-1569 73

, - - - . ~ , . . . ,_

Enviromnental Effects 7.3.1.2.3 Acceptance Criteria The exposures from air pathways are acceptable if they meet the following criteria:

(1) The estimates of individual exposure to radionuclides at the site boundary meet the regulatory requirements in 10 CFR 20.1302(bX2Xi) with regard to annual average concentrations of radionuclides 'n airborne efiluents or the dose limit in 10 CFR 20.1301.

(2) Calculations of concentrations of radionuclides in air at locations downwind where residents live or where biota of significance to human food chains ex;st are included in the compliance demonstration for public dose limits in 40 CFR Part 190 and 10 CFR 20.1301.

(3) Relevant airbome exposure pathways are included in the pathway diagram provided by the applicant.

(4) 1he conceptual model used for calculating the source tenn and individual exposures (and/or concentrations of radionuclides) from airborne elliuents at the facility boundasy is representative of conditions described at the site as reviewed in section 2.0 of the SRP.

The conceptual model is consistent w ith the methodologies described in Regulatory Guide 3.51 (NRC,1982). The conceptual model for the MILDOS AREA code (Yuan, et al, 1989) is acceptable for these exposure calculations.

($) The parameters used to estimate the source term, environmental concentrations, and exposures are applicable to conditions at the site as reviewed in section 2.0 of the SRp.

Guidance on source term calculations is available in Regulatory Guide 3.59, Methods for Estimating Radioactive and Toxic Airbome Source Tenns for Uranium Milling Operations (Nuclear Regulatory Commission,1987). Additionally, an example source term calculation specifically applicable to ISL facilities is described in Appendix C.

7.3.1.2.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the radiological cliects from air pathways, the following conclusions may be presented in the TER.

The NRC has completed its review of the radiological effects of exposure from air pathwi.ys at the _ ISL facility, This review included an evaluation of the me; hods that will be used to evaluate radiological clTects using the review procedures in SRP section 7.3.1.2.2 and the acceptance criteria outlined in SRP section 7.3.1.2.3.

The applicant's demonstrations of individual exposure to radionuclides from air pathways are acceptable since they are less than the limits in 10 CFR 20.132 (bX2Xi) with regard to annual average concentrations in airborne efliuents or they are less than the dose limit in 10 CFR 20.1301. The applicant has acceptably demonstrated that the concentrations of radionuclides in air at locations where residents live or where biota of significance to human food chains exist are in compliance with the public dose limits in 10 CFR 20.1301. The applicant has included the relevant airbome exposure pathway diagrams 79 NUREG 1569

Environmental Effects in the application. The applicant has used an acceptable representation of the atmospheric conditions at the site in the determination of the source tenn and individual exposures for their model calculations. The applicant has used acceptable values for parameters used to estimate the source tenn, environmental concentrations, and exposures; and the parameters are representative of the site.

7.3.1.2.5 References Nuclear Regulatary Commission,1982, Calculational Models for Estimating Radiation Doses to Man l' rom Airbome Radioactive Materials Resulting Frorn Uranium Milling Operations, Regulatory Guide 3.51, Washington, D.C.: Nuclear Regul tory Commission, Omce of Standards Development.

Nuclear Regulatory Commission,1987. Methods for Estimating Radioactive and Toxic Airborne Source Terms for Uranium Milling Operations. Regulatory Guide J.59. Washington, DC: Nuclear Regulatory Commission, Omcc of Standards Development.

Yuan, Y.C., Wang, J.II.C., Zielern, A.,1989, MEDOS AREA: An Enhanced Version of MILDOS for large Area Sources, Repon ANL/ES 161, Argonne, IL: Argonne National Laboratory, Energy and Environmental Systems Division.

7.3.1.3 Exposures from External Radiation 7.3.1.3.1 Areas of Review 1he staff shall review estimates of maximum annual external dose that would be received by an individual from direct radia, ion at the nearest site boundary and in offsite populations. The sinff shall also review data, models, calculations, and assumptions used in suppon of these estimates.

7.3.l.3.2 Review Procedures The staff shall determine whether the estimates of maximum annual external dose that would be received by an individual from direct radiation at the nearest site boundary meet the ilmits specified in 10 CFR 20.130l(a)(2). The stafTshall also detemiine whether these stimates are supported by properly interpreted data, calculations, and model results using reasonable assumptions. Staff shall confinn that the input parameters t. sed for the extemal dose calculation are consistent with the information provided in the application. The staff shall also confinn that the selected pr.an eter values are representative of conditions at the site as reviewed in section 2.0 of the SRP. StalT shall check the source tenn conceptual model and selected parameter values to ensure that they are appropriate for the site conditions described in the application.

j NUREG-1569 7 10 l

Environmental Effects 7.3.1.3.3 Acceptance Criteria lhe exposures from external radiation are acceptable if they meet the following criteria:

1 (1) The estis,ates of external radiation exposure at the site boundary meet the regulatory limits in 10 Cl R 20.130l(a)(2).

(2) The applicant provides an exposure pathway diagram that includes the relevant external exposure pathways.

(3) The model(s) used for calculating the source term, environmental concentrations, and ,

extemal exposures at the facility boundary are representative of site conditions reviewed in section 2.0 of the SRP.

(4) The parameters used to estimate the source tenn, environmental concentrations, and extemal exposure are applicable to site conditions as reviewed in section 2.0 of the SRP.

7.3.1.3.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the radiological effects of exposures from external radinilon, the following conclusions may be presented in the TER.

The NRC has completed its review of the indiological efTects of exposure from external radiation at the ISL facility. This review included an evaluation of the methods that will be used to evaluate radiological effects using the review procedures in sri > section 7.3.1.3.2 and the acceptance criteria outlined in SRP section 7.3.1.3.3.

The applicant's demonstration of individual exposure to radionuclides from extemal radiation is acceptable and meets the requirements of 10 CFR 20.132 (b). The applicant has provided an acceptable exposure pathway diagram that includes all relevant external pathways. The applicant has used an acceptable representation of the external exposures at the site in the detennination of the source tenn, environmental concentrations, and individual exposures for the model calculations. The applicant has acceptable values for parameters used to estimate the source tenu, environmental concentra* ions, and exposures; and the parameters are representative of the site.

7.3.1.3.5 References None.

7.3.1.4 Total Iluman Exposures 7.3.1.4.1 Areas of Review The staff shall review estimates of the maximum annual dose that could be received via all pathways der.cribed above by :_n individual at the site boundary and at the nearest residence For commercial scale operations, the staff shall also review estimates of radiation dose from all pathways to 7 11 NUREG-1569

Environmental Effects the regional population within 80 km (50 mi) of the facility including the total annual 100 yr environmental dose commitment to the population from all pathways. The staff shall also review data, models, calcuistions, and assumptions used in support of these estimates. Much of this review will already have been completed for the pathway specific calculations and the total dose will be the sum of these results.

7.3.1.4.2 Review Procedures The staff shall determine whether estimates of the maximum annual dose that could be received via all pathways described above by an individual at the site boundary and at the nearest residence meet regulatory requirements in 10 CFR 20.1301 and 40 CFR 190.10. For commercial scale opemtions, the staff shall also review estimates of radiation dose from all pathways to the regional population within 80 km (50 mi) of the facility. These calculations can be effectively executed by the MILDOS AREA code (Yuan, et al,1989). The staff shall also determine whether these estimates are supported by properly interpreted data, calculations, and model results using rcasonable assumptions. Afler the pathway specific calculations have been reviewed, staff shall check to ensure that the doses have been correctly summed to determine the total dose. Also, staff shall ensure the population dose is compared with a meaningful reference dose, such as that which is expected for the exposure to the same population from background radiation sources.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7.3.1.4.3 Acceptance Criteria lhe total human exposure is acceptable if it meets the following criteria:

(1) The estimates of individual exposure to radionuclides at the site boundary meet the regulatory requirements in 10 CFR 20.1302(b)(2)(i) with regard to annual average concentrations of radioactive nuclides in airbome and liquid efiluents or the dose limit in 10 CFR 20.1301.

(2) Calculations of the maximum individual whole body and organ doses at ihe site boundary and for the nearest downwind resident and where biota of significance to human food chains exist are included in the compliance demonstration for public dose limits in 10 CFR 20.1301.

(3) The exposure pathway diagram provided by the applicant includes pathways relevant to all eflluents expected from facility operations.

(4) The models used for calculating the source tenns and individual exposures (and/or i concentrations of radionuclides) from all effluents at the facility boundary are I representative of conditions described at the site as ieviewed in t ction 2.0 of the SRP.

The conceptual models are acceptable as described in Sections 7.3.1.1,7.3.1.2, and 7.3.1.3 if this SRP.

NUREG 1569 7 12 l l

I Environmental Effects (5) The parameters used to estimate source terms, concentrations, and exposures are representatise of conditions described at the site as reviewed in section 2.0 of the SRP.

7.3.1.4.4 Evaluation iindings if the staffs review, as described in this section, results in th acceptance of the radiological effects from total human exposures, the followin;, conclusions may be presented in the TER.

The NRC has completed its review of the radiological efTects of total human exposures at the ISL facility. This review included an evaluation of the methods that will be used to evaluate radiological effects using the review procedures in SRP section 7.3.1.4.2 and the acceptance criteria outlined in SRP section 7.3.1.4.3.

1he applicant's detennination of total human exposure to radionuclides at the site boundary is acceptable since meets the requirements in 10 CFR 20.1301 The applicant has provided an exposure pathway diagrarn that includes all relevant extemal pathways. The applicant has used an acceptable representation of the external exposures at the site in the determination of the source term, environmental concentrations, and individual exposures for the model calculations. 'ihe applicant has acceptable values for parameters used to estimate the source term, environmental concentrations, and exposures; and the parameters are representatise of the site.

7.3.1.4.5 References Yuan, Y.C., Wang, J.ll.C., Zielem, A.,1989, MILDOS AREA An Enhanced Version of MILIX)S for large Area Sources, Report ANUES 161, Argonne, IL: Argonne National Laboratory, Energy and Environmental Systems Division.

7.3.1.5 Exposures to llora and Fauna 7.3.1.5.1 Areas of Review

'the stalT shall review estimates of maximum radionuclide concentrations that may be present in important local flora and local and migratory fauna. 'the staff shall also review data, bioaccumulation factors, models, calculations, and assumptions used in support of these estimates.

7.3.1.5.2 Review Procedures The statishall detennine whether estimates of maximum radionuclide concentrations that may be present in important local flora and local and migratory fauna are calculated such that environmentTI impacts from facility operations can be assessed to address the requirements of 10 CFR Part S t. The staff shall also determine whether these estimates are supported by properly interpreted data, reasonable bioaccumulation factors, approved calculations, and model results using reasonable assumptions. Detailed biosphere modeling is not necessary for these calculations. Output from MILDOS AREA (Yuan, et al, 1989) provides ground level concentrations of radionuclides that can be then converted to plant and animal concentrations by use of simple conscrsion equations that include deposition, uptake factors, plant 7 13 NUREG 1569

Environmental Effects l inMrception fractions, and animal consumption rates obtained from the literature. Staff shall spot check parameter values against known sources to ensure that they are within expected ranges. The tabulation of bioaccumulation factors and their sources can be presented in an appendix to the application. Provided these concentrations are protective of human health, they would not be expected to adversely affect native plants and animals (llamthouse,1995).

For license renewals and arnendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7.3.1.5.3 Acceptance Criteria i

The exposures to Dora and fauna are acceptable if they meet the following criterion:

(1) The model and parameter values used for calculation of concentrations of radionuclides in important local dora and fauna are consistent with generally accepted health physics practice and are applicable to the species identined at the site as reviewed in section 2.0 of the SRP.

7.3.1.5.4 Evaluation Findings if the staf1's review, as described in this section, results in the acceptance of the radiological effects from exposures to Cora and fauna, the following conclusions may be presented in the TER.

The NRC has completed its review of the radiological effects of exposures to Dora and fauna at the ISL facility. This review included an evaluation of the methods that will be used to evaluate radiological effects using the review procedures in SRP section 7.3.1.5.2 and the acceptance criteria outlined in SRP section 7.3.1.5.3.

The applicant has demonstrated that the offsite impacts of operation would be minimal. Flora and fauna in the areas surrounding the project site are similar to those onsite and are common in the region. The applicant has taken acceptable steps to minimite erosion and sedimentation both on and offsite by (i) not placing wells, roads, or other facilities on steep, or currently eroding slopes;(ii) vegetating and stabilizing topsoil stored for subsequent use; and (iii) constructing drainage diversions where needed to limit Hooding potential. Under nonnal operation, the only routine release would be of concentrations of radon and particulate radionuchdes to the airshed. Provided that these concentrations are protective of human health, they would not be expected to adversely affect the native plants and animals, and as such, are acceptable, 7.3.1.5.5 References Itamthouse, L.W.1995. Efects ofloni:ing Radiation on TerrestrialPlants and Animals. A workshop report-ORN1/IN 13141. Oak Ridge, TN: Oak Ridge National Laboratory.

Yuan, Y.C., Wang, J.ll.C., Zielern, A.,1989, Mll. DOS AREA: An Enhanced Versio, of MILDOS for NUREG 1569 7 14

Environmental Effects large Area Sources, Report ANilES 161, Argonne, IL: Argonne National Laboratory, Energy and Environmental Systems Division. >

7.4 NONRADIOLOGICAL EFFECTS 7.4.1 Areas of Review lhe staff shall review estimates of concentrations of nonradioactive wastes in emuents at the points of discharge as compared with natural ambient concentrations without the discharge and with applicable standards. The review shall include the projected effects of the emuents for both acute and chronic exposure of the biota (including any long term buildup in sollt ad sediments and in the biota).

The staff shall evaluate discussions of dilution and mixing of discharge into the receiving environs, and  ;

estimates of concentrations at various distances from the point of discharge. The effects on terrestrial and aquatic environments from chemical wastes that contaminate groundwater shall also be examined.

The staff shall also review discussionsof any potential effects of the proposed operation that do i

not clearly fall under any specine topic previously addressed. These may include changes in land and 4

water use at the project site; sanitary and other recovery plant waste systems; interaction of the facility with other existing or projected neighboring facilities; effects of groundwater withdrawal on groundwater resources in the vicinity of the well field (s) and recovery plant (s); cfrects of construction and operation of roads, transmission corridors, railroads, etc.; efTects of changes in surface water rvailability on blotic populations; and disposal of other solid and liquid wastes. i 7.4.2 Review Procedures 1he stafTshall determine whether the specine estimated concentrations of nonradioactive wastes in emuents s' the point of discharge and the projected effects for both acute and chronic exposure of the j biota are a' ,tely quantined in accordance with the NEPA requirements in 10 CFR 51.45. Where applicable, 4 di shall determine whether these estimates are supported by properly interpreted data, reasonable b; 6cumulation factors, calculations, and model results using reasonable asst.mptions.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7.4.3 Acceptance Criteria The nonradiological effects are acceptable if they meet the following criteria:

(1) . The estimated concentrations of norradioactive wastes in ef0uents at the point of discharge and the projxted effects for both acute and chronic exposure of the biota are -

adequately quantined in x ordance with the NEPA requirements in 10 CFR 51.45, 7 15 NUREG 1569

_ _ _-_. . _ _ _ _ _ . __ , _ . . _. _ . _ _ . _ _ _ ... _ . _ - _ - . _ u_

_ . _- _. . _ _ . - _ _ . _ _ - - - - _ . - - - = ~ _ - - . - _

?

Environmental Elfects 7.4.4 Evaluation Findings if the staff s review, as described in this section, results in the acceptance of the nonradiological effects, the following conclusions may be presented in the TER.

He NRC has completed its review of the nonradiological efrects at the ISL facility. This review included an evaluation of the methods that will be used to evaluate nonradiological effects using the review procedures in SRP section 7.4.2 and the acceptance criteria outlined in SRP section 7.4.3. ,

The applicant has acceptably described all anticipated significant nonradiological environmental .

impacts from facility operations. He estimated effects of nonradioactive wastes in elliuents at the point of discharge and the projected effects for both acute and chronic exposure of biota are acceptable.

7.4.5 References None.

7.5 EFFECTS OF ACCIDENTS in this section of the application, the applicant should discuss the environmental effects of possible accidents that may occur, whether or not those accidents may produce an impact on the site or its environs. Analyses should be based on relevant experience and accident statistics from similar operating facilities. Accidents due both to human causes and natural phenomena should be addressed. See 10 CFR 20.403 and 20.405 regarding reporting requirements.

7.5.1 Accidents involving Radioactivity 7.5.1.1 Areas of Review The statishall review analyses of accidents involving radioactivity for a spectrum of accidents that might occur ranging in severity from trivial (essentially no release of radioactivity to the environment) to large releases, including characterization of occurrence rate or probability and potential consequences.

Examples of accidents resulting in large releases would be an undetected lixiviant excursion or the failure of a waste retention system resulting from an act of nature, faulty design, or misoperation. Examples of accidents resulting in small releases would be failure of a pumping circuit with ground surface lixiviant release or failure of the ventilation system serving the chemical makeup area. The staff shall review measures to be taken to prevent accidents, and discussions of proposed contingency plans to be implemented in the event that accidents occur.

7.5.1.2 Review Procedures The stafT shall detennine whether accident scenarios desuibed in the application are reatonable based upon analysis of descripdons of the facility and operations re ' awed in sections 3.0,4.0, aid 5.0 of the SRP and are sufliciently complete to determine environmente mpacts of operations pursuant to the NEPA requirements. The staff shall determine whether these scenarios and estimates are suppcrted by properly interpreted date, calculations, and model results using reasonable assumptions. If conecquences NUREG 1569 7 16

Environmental Effects cannot be quantified, then a qualitative d(scriptien of impacts may be acceptable. Staff shall ensure the applicant has procedures in place to detect and respond to all postulated accident conditions and to mitigate consequences.

7.5.1.3 Acceptance Criteria The consequences of accidents involving radioactivity are acceptable if they meet the following criteria:

(1) The applicant has provided analyses of probable accident consequences that are consistent with the facility design and planned operations and are sufficient to identify possible environmental impacts from operations.

t (2) Analyses of accident consequences include mitigation measures for postulated accidents.

(3) Analyses of accidents include results of operating experience at similar facilities.

(4) The applicant's response program provides for notification to the NRC in compliance with the requirements of 10 CFR 20.2202 and 20.2203.

7.5.1.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the effects of accidents involving radioactivity, the following conclusions may be presented in the TER.

'the NRC has completed its review of the efTects of accid:nts involving radioactivity proposed at the ISL facility. This review included an evaluation of the methods that will be used to evaluate effects of accidents involving radioactivity using the review procedures in SRP section 7.5.1.2 and the acceptance criteria outlined in SRP section 7.5.1.3.

'the applicant has acceptably described all anticipated significant efTects of accidents from facility operations involving radioactivity. The applicant has provided an acceptable analysis of probable accidents involving radioactivity and their consequences consistent with the facility design and planned operations.

The applicant has identified possible environmental impacts from such accidents and has included mitigation measures. The applicant has considered the analyses of accidents involving radioactivity resulting from past operating experience at similar facilities. The applicant's response program will comply with the notification requirements of 10 cfr 20.2202 and 20.2203.

7.5.1.5 References None.

7.5.2 Transportatlan Accidents 7.5.2.1 Areas of Review 7 17 NUREG-1569

Environmental Effects lhe staff shall review accident scenarios and estimated releases of radioactivity and nonradiological wastes as a result of transportation accidents. ISL facilities must address the potential for

>cilowcake and processing chemical shipment accidents. Yellowcake is classified by the NRC in 10 CTR Part 71 as low. specific activity material.1he radiological health impacts of accidents are small and most spills can be remediated by a cleanup crew. Additional transportation activities can include shipments of wet >ellowcake slurry and offsite waste disposal shipments. The staff shall review data, models, calculations, and assumptions used in support of these estimates. Emergency response plans, mitigation measures, and experience from other similar facilities shall also be reviewed to ensure the appropriate procedures are in place.

7.5.2.2 Review Procedures lhe staff shall detennine whether transportation accident scenarios described in the application are reasonable and complete and that the analyses are sufficient to assess the environmental impacts from transportatioa activities onsite and offsite pursuant to the NEPA requirements of 10 CFR Part $1. The review shall consider the discussion of plant operations in rection 5.0 of the SRP and shall confirm that all significant transportation activities are included in the accioent analyses. The staff shall use its understanding of the past industry experience with transponation accidents to assess whether the analyses are complete in addressing possibb accident conditions and consequences. Staff do not need to review all of the operational aspects of transportation activities as thne will be addressed through inspections relevant to the general transportation license requirements. The staff shall detennine w hether the scenarios and estimates are supported by properly interpreted data, calculations, and model results using reasonable assumptions.

For license renewals and amendment applications, appendix A to this standard itview plan (SRP) provides guidance for examining facility operations and the approach that should be used in esaluating amendments and renewal applications.

7.5.2.3 Acceptance Criteria lhe consequences of transponation accidents are acceptable if they meet the following criteria:

(1) The transportation accident analyses postulated scenarios cover the full extent of significant transportation activities reviewed in section 5.0 of the SRP.

(2) The accident scenarios and result s are consistent with industry transportation experience and are considered reasonably likely to occur during the life of the facility.

(3) Procedures to respond to and mitigate or remediate the impacts of all fonns of potential transportation accidems are refcrenced in the at plication.

(4) Assessment of transponation impacts considers the local routing options and accident rates for these routes, and how these rates will be affected by the additional shipments.

7.5.2.4 Evaluation Findings NUREG-1569 7-18

s l Environmental Effects If 'he staffs review, as described in this ution, results in the sceptance of the effects of ,

transportatiot. accidents, the following conclusions may be presented in the TER. l The NRC has completed its review of the effects of transportation xcidents proposed at the ISL facility. This review included an evaluation of the methods that will be used to evaluate effects of transportation accidents using the review procedures in SRP section 7.5.2.2 and the xceptance criteria o 'ned in SRP section 7.5.2.3. l The applicant has sceptably described all anticipated significant effects of transportation  !

i accidenta from facility operations covering ~ the full extent of transportation activities reviewed in section 5.0 of the SRP. The applicant has provided an acceptable analysis of probable transportation accident scenarios and consequences consistent with the facility design and industry transportation experience. The applicant has identified possible environmental impacts from such transportation accidents and has included mitigation and remediation measures for the possible transportation accidents. The .

. applicant has considered the analyses of transportation accidents resulting from past operating experience at similar facilities. The assessment of transpiration accidents considers local routing options and accident rates for those routes, including the change in rates resulting from the additional shipments required by facility operation.  ;

7.5.2.5 References None.

7.5.3 Other Accidents 7.5.3.1 Arena of Review The staff shall review information on other accidents that, although radioactive materials would not be involved, would have consequences that could affect the environment. Such accidents as chemical explosions or fires, steam toiler failures, and leakage or rupture of vessels containing toxic materials could have significant environmental impacts. The possible effects of these accidents shall be evaluated.

7.5.3.2 Reslew Procedures lhe staff shall determine whether accident scenarios described in the application and their estimated consequences are reasonable and consistent with past industry experience. The review shall emphasire the plant design and specific components that are prone to failure or known to have failed at other facilitics. The staff shall determine whether the scenarios and estimates are supported by properly interpreted data, calculations, and model results using tensonable assumptions. If consequences cannot be quantified, then a qualitative description of impacts may be acceptable. Staff shall ensure the applicant has procedures in place to detect and respond to all postulated accident conditions and to mitigate consequences.

7 19 NUREG 1569 1

. , - _ - , _ , , - _ , _ - ~ . . . _ - _ . - - , , , - . . - . - _ , . . . . - _ . _ . . . . _ . - - - _ . - - . . . . . , - - . - . . ~ . -

I i

Environmental Effects l For license renewals and amendment applications appendix A to this standard review plan (SRP)  ;

provides guidance for examining facility operations and the approach that should be used in evaluating  !

amendments and renewal applications. L 7.5.3.3 Acceptance C heda

{

ne consequences of other accidents are acceptable if they meet the following criteria:

(1) Analyses of accidents provide definition of probable accident consequences that are consistent with the facility design, industry experience, and plannal operations, and are sufficient to identify possible environmental impacts from operations.

(2) ne analyses of accident consequences include mitigation measures for postulated accidentc.

7.5.3.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the elTects of other accidents, the following conclusions may be presented in the TER.

The NRC has completed its review of the effects of other accidents (those not involving radioactive materials) proposed at the ISL facility. His review included an evaluation of the methods that will be used to evaluate effects of other accidents using the review procedures in SRP section 7.5.3.2 and the acceptance criteria outlined in SRp section 7.5.3.3.

De applicant has acceptably described all anticipated significant effects of other accidents from facility operations covering the full extent of activities discussed in sections 3.0,4.0, and 5.0 of the SRP.

De applicant has provided an acceptable analysis of probable accidents and consequences consistent with ,

the facility design ar.d industrywide experience. The applicant has acceptably identified possible environmental impacts from such other accidents and has included mitigation and remediation measures F for the possible other accidents. The applicant has considered the analyses of other accidents resulting from past operating experience at similar facilities.

7.5.3.5 References None.

7.6 ECONOMIC AND SOCIAL EFFECTS OF CONSTRUCTION AND OPERATION The staff shall review descriptions in the application related to the potential economic and social efTects of construction and operation of the proposed facility. These impacts should be discussed in separate sections covering benefits, costs, and resources committed.

NUREG 1569 7 20 l

l L . . . - -- - .- . -. -

Environmental Effects 7.6.1 Benefits 7.6.1.1 Areas of Review The staff shall review social and economic benefits from the proposed ISL operations that affect various politicaljurisdictions or public and private interests. Some of these reflect transfer payments or other values that may partially, if not fully, cornpensate for certain services as well as extemal or environmental costs, and this fact should be reflected in the designation of the berent. Some examples of benefits to be reviewed include (1) Tax revenues to be received by local, state, and federal govemments (2) Temporary and permanent new jobs created and payroll (value-added concept)

(3) Incremental increases in regional productivity (4) Enhancement of recreational values (5) Environmental enhancement in support of the propagation or protection of wildlife and the improvement of wildlife habitats (6) Creation and irnprovement of local roads, waterways, or other transportation facilities (7) Increased knowledge of the environment as a consequence of ecological research and environmental monitoring activities associated with plant operation and technological improvements from the applicant research prograrns The staff shall also review discussions of sigt'ficant benefits that may be realized from construction and operation of the proposed facility including expressions in monetary terms, discounted to present worth, of who is likelv to be alTected and for how long. In the case of aesthetic impacts that are difTicult to quantify, the staff shall review pictorial drawings of structures or environmental modifications visible to the public.

7.6.1.2 Re el-w Procedures The staff shall detennine whether sullicient detail is presented to evaluate significant economic and social benefits that may be realized from construction, operation, restoration, reclamation, and decommissioning of the proposed facility. The staff shall determine whether the likely benefits are reasonable and supported by properly interpreted data, calculations, and model results using reasonable assumptions. The staff shall determine to what extent likely benefits can serve to offset adverse effects and costs of construction and operation of the facility. The SFCO (Nuclear Regulatory Commission,1982) provides a list of the types of benefits to be included in the application.

7 21 NUREG 1569

Environmental Effects For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7.6.1.3 Acceptance Cdteda The economic and social effects of construction and operation are acceptable if they meet the following criteria:

(1) 1he applicant's analysis of economic and social benents that may be realized from construction, operation, restoration, reclamation, and decommissioning of the proposed facility are supported by properly interpreted data, calculations, and model results to comply with the requirements of 10 CFR SI A$(c).

(2) For each benefit identiDed, the applicant identifice who is affected and the duration of the irnpact.

(3) for special case EAs (e.g., those that have substantial public inteiest, decommissioning /

decontamination cases that allow radioactivity in excess of release criteria, or cases where environmental justice issues have been previously raised) the applicant has provided sufficient data to assess environmentaljustice issues in accordance with appendix E to this SRP.

7.6.1.4 Evaluation Findings if the staffs review, as descrited in this section, results in the acceptance of the effects of the economic and social benefits of construction and operation, the following conclusions may be presen:cd in the TER.

The NRC has completed its review of the economic and social beneSts of construction and operation proposed at the ISL facility. This review included an evaluation of the methods that will be used to evaluate effects of economic and social benefits of construction and operation using the review pmcedures in SRP section 7.6.1.2 and the acceptance criteria outlined in SRP section 7.6.l.3.

The applicant has acceptably described all anticipated economic and social benefits of construction and operation of the facility covering the full extent of activities discussed in sections 3.0, 4.0, and 5.0 of the SRP The applicant has provided an acceptable analysis of probable benents consistent with the facility design and industrywide experience. The applicant has included analyses of (i) tax revenues; (ii) creation of temporary and permanent jobs and accrued payroll; (iii) incremental increases in regional productivity; (iv) enhanecment of recreational salues; (v) environmental enhancement and increased knowledge of the environment through ecological research and environmental monitoring programs; and (vi) creation and improvement of infrastructure (e.g. roads, waterways, water and power supply, and other transportation facilities). The applicant has acceptably identined for each benefit who is affected and the expected duration of the beneficial effect. Overall, the applicant has demonstrated that the analysis of the economic and social benefits from the construction, operation, restoration, reclamation, NUREG 1569 7 23

Environmental Effects and decommissioning of the proposed ISL facility are supported by properly interpreted data, calculations, and model results.

7.6.1.5 References 8

Nuclear Regulatory Commission.1982. Standard Format and Content of License Applicat 9ns,Inchding Environmental Reports, for /n Situ Uranium Solution Mining (SFCG). June. Regulatory ,

Guide J.46. Washington, DC: Nuclear Regulatory Commission, Ofuce of Standards  !

Development. l 7.6.2 Costs 7.6.2.1 Areas of Review

'ihe staff shall review infortnation presented concerning the primary corporate intemal costs helu&g (i) the capital msts of land acquisition and irnprovement; (ii) the capital costs of facility construction;(iii) other operating and maintenance costs. including license fees and taxes:(iv) groundwater quality restoration, surface reclamation, and plant decommissioning costs; and (v) R&D costs, including postoperational monitoring requirements. 'ihe applicant should discount these costs to present worth.

The staff shall also review information on extemal costs including the probable number and location of the population group adversely affected, the estimated economic and social impact, and any special measures taken to alleviate the impact.

Temporary extemal costs shall also be evaluated including housing shortages; inflationary rentals or prices; congestion of local streets and highways; noise and temporary aesthet ci disturbances; overloading of water supply and sewage treatment facilities; crowding oflocal schools, hospitals, or other public facilities; overtaxing of community services; and disruption of people's lives or of the local community caused by acquisition of land for the proposed site.

Finally, the stafT shall review information regarding long term external costs including impairment of recreational values (e.g., reduced availability of desired species of wildlife ond sport animals, or restrictions on access to land or water areas preferred for recreational use); deterioration of aesthetic and scenic )alues; restrictions on access to areas of scenic, historic, or cultural interest; degradation of areas having historic, cultural, natural, or archeological value; removal ofland from present or contemplated alternative uses; reduction in quantities of regional products because of displacement of persons from the land proposed for the site; lost income from recreation or tourism that may be impaired by environmental disturbances; lost income attributable to environmental degradation; decrease in real estate values in areas adjacent to the proposed facility; and increased costs to local govemments for the services required by the permanently employed workers and their families, in discussing these costs, the applicant should indicate, to the extent practical, who is likely to be affected, to what degree, and for how long.

7.6.2) Review Procedures 7 23 NUREG-1569

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linvironmental Elfects lhe stalf shall determine whether sufficient detail is presented to evaluate significant economic and social internal and external costs that may be incurred during construction, operation, restoration, reclamation, and decommissioning of the proposed facility, The assessment of costs shall be reviewed in the context of the :nfonnation prosided in other chapters of the application to ensure consistency and completeness. lhe staf f shall resiew any data, models, calculations, and assumptions used in support of these projections. 'lhe staff shall ensure the applicant has identified who it is that will bear the cost, the number of such people, the duration of the impacts, and what measures will be taken to mitigate the impacts. Costs should be discounted to present worth.

l'or license renewals and amendment applications, appendix A to this standard review plan (SRP) prmides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

7,6,2,3 Acceptance Criteria lhe costs of the ISI, operations are acceptable if they meet the following criteria:

(1) 1he analyses of economic and social costs that may be realized from construction, operation, restoration, reclamation, and decommissioning of the proposed facility are supported by properly interpreted data, calculations, and model results to comply with the requirements in 10 CFR SI.45(c).

(2) For each cost identified, the applicant identifies who is affected, the duration ofimpacts, and any mitigation measures necessary to alleviate or reduce impacts.

(3) Costs are discounted to present worth.

7,6.2.4 Evalnation firxdings if the stafri re.m e. as described in this sectirn, results in the acceptance of the efTects of the economic and social emte of construction and operation, the following conclusions may be presented in the 1 ER.

The NRC has completed its review of the efTects of economic and social costs of construction and operation proposed at the ISL facility. This review included an evaluation of the methods that will be used to evaluate efTects of economic and social costs of construction and operation using the review procedures in SRP section 7.6.2.2 and the acceptance criteria outlined in SRP section 7.6.2.3.

The applicant has acceptably described all anticipated economic and social costs of construction and operation of the facility covering the full extent of activities discussed in sections 3.0,4.0, and 5.0 of the SRp.The applicant has provided an acceptable analysis of probable coes consistent with the facility design and industryw ide experience. The applicant has included analyses of(i) impairment of recreational values;(ii) restriction on access to water or land for recreational use;(iii) restriction on access to areas of scenie, historic, or cultural interest; (iv) deterintation of aesthetic and scenic values;(v) degradation of areas having historie, cultural, natural, or archeological values; (vi) remosal of land from present or NUREG-1569 7 24

Environmental Effects contemplated alternative uses;(vii) reductions in quantities of regional products;(viii) lost income from recreation or tourism that may be impaired by environmental disturbances;(ix) lost income attributable to environmental degradation; (x) decrease in real estate values adjacent to the proposed facility; and (xi) increased costs to local govemments for increased services and infrastructure. The applicant has identified for each cost who is alTected, to what extent, and the expected duration of the effect. Overall, the applicant has demonstrated that the analysis of the economic and social costs from the constmetion, operation, restoration, reclamation, and decommissioning of the proposed ISL facility is supported by acceptably interpreted data, calculations, and model results.

7.6.2.5 References None.

7.6.3 Resources Committed 7.6.3.1 Areas of Review The staff shall review irreversible and irretrievable commitments of resources due to the construction, operation, restoration, reclamation, and decommissioning of the proposed facility. This review shall include both relative impacts and long term net effects. Such resources should include permanent land withdrawal, irreversible or irretrievable commitments of mineral resources, water resource needs and groundwater consumption, pennanent vegetation and wildlife losses (e.g., unique habitat, species), and consumption of material resources such as processing chemicals and power or energy needs.

The staff shall review infonnation presented concerning the percentage terms in which the expected resource loss is related to the total resource in the immediate region and in which the immediate region is related to the surrounding regions in terms of afTected areas and distances from the site.

7.6.3.2 Review Procedures The staff shall detennine whether sufficient detail is presented to evaluate irreversible and irretrievable commitments of resources due to the construction, operation, restoration, reclamation, and decommissioning of the proposed facility. These commitments shall be reviewed considering the facility description and operations discussed in earlier chapters to ensure cor.sistency and completeness. Resource needs previously identified in existing ERs for similar facilities that are currently operating can be used in the staffs review for comparison. )

7.6.3.3 Acceptance Criteria The resources committed to ISL operations are acceptable if they meet the following criteria:

(1) The irreversible and irretrievable commitments of resources for the construction, operation, restoration, reclamation, and decommissioning of the proposed facility are appropriate considering the following:

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l Environmental Effects i (a) Permanent land withdrawal (b) Permanent commitment of mineral resources (c) Pennanent commitment of water resources Postgroundwater restoration impacts at public water supply wells are acceptable if the water quality at town wells is consistent with EPA primary and secondary drinking water standards and the NRC standard of 0.44 mg/L for uranium (d) Irreversible loss of surface vegetation (e) Irreversible loss of wildlife (f) Irreversible commitments of material resources including processing chemicals and energy needs 7.6,3.4 Evaluation Findings if the staffs review, as described in this section, results in the acceptance of the economic and social effects of resources committed, the following conclusions may be presented in the TER.

The NRC has completed its review of the effects of economic and social effects of resources committed at the ISL facility. This review included an evaluation of the methods that will be used to evaluate economic and social effects of resources committed using the review procedures in SRP section 7.6.3.2 and the acceptance criteria outlined in SRP section 7.6.3.3.

The applicant has acceptably described all anticipated economic and social effects of resources committed at the facility covering the full extent of activities discussed in sections 3.0,4.0, and 5.0 of the SRP. The applicant has provided an acceptable analysis of probable effects consistent with the facility design and industrywide experience. The applicant has included analyses of(i) permanent land withdrawal, (ii) permanent commitment of mineral resources, (iii) permanent commitment of water resources, (iv) irreversible loss of surface vegetation, (v) irreversible loss of wildlife, and (vi) irreversible commitments of material resources including processing chemicals and energy needs. The applicant has acceptably identified, for each resource committed, who is affected, to what extent, and the expected duration of the effect. Overall, the applicant has demonstrated that its analysis of resources committed as a result of the construction, operation, restoration, reclamation, and decommissioning of the proposed ISL facility is supported by properly interpreted data, calculations, and model results.

7.6.3.5 References None.

NUREG 1569 7 26

,i 8.0 ALTERNATIVES TO PROPOSED ACTION 8.1 AREAS OF REVIEW The staff will review comparative evaluations of available alternatives to the selected ISL process incluaing realistic alternatives for the various processing stages. The reviews shall include descrip' ions of the groundwater quality restoration programs to be applied for each alternative. The staff shall evaluate alternatives that may reduce or avoid significant adverse environmental, social, and economic effects expected to result from construction and operation of the proposed facility. The staff shall also review the bases and rationales for the choices in regard to number, availability, suitability, and factors limiting the range of alternatives that might avoid some or all of the environmental effects identified in section 7.0 of the SRP For commercial-scale operations, the review shall include the comparative evaluation of available alternatives using results obtained from R&D operations.

The staff shall also review wasic management alternatives considering siting, design, and operational performance objectives developed by the NRC staff in addition to the plans for final disposal discussed in section 6.0 of the SRP.

The review shall include discussions regarding locating the liquid impoundment areas at sites where disruption and dispersion by natural forces are eliminated or reduced to the maximum extent reasonably achievable, and designing the impoundment areas so that seepage of toxic materials into the g groundwater system would be eliminated or reduced to the maximum extent resonably achievable.

8.2 REVIEW PROCEDURES The staff shall determine that the applicant has justified the choice of particular recovery processes for the ore body by considering and choosing among echniques and processes that affect the environment in minimal ways. The justification sho'ild include a comparative evaluatian of the av.tilable, practicable alternatives. Strengths and weaknesses associated with the likely effects of the use of each technique or process, including the groundwater quality restoration program, should be presented. The staff shall determine that the applicant has considered and chosen those alternatives that may reduce or avoid significant adverse environmental, social, and economic effects expected to result from the construction and operation of the proposed facility. The staff shall evaluate the bases and rationales the applicant used for the consideration and rating of the alternatives. The staff shall determine that, for commercial scale operations, the comparative evaluation of available alternatives includes results from R&D operations or similar pnxtuction scale sites.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

8.3 ACCEP FANCE CRITERIA The evaluation of alternatives to the proposed action is acceptable if it meets the following criteria:

8-1 NUREG-1569

i (1) TheLapplicantionsiders process _ alternatives to the proposed action. The applicant  !

identifies alternatives to the operation of the proposed facility in the manner reviewed in ,

sections 3.0,4.0,5.0, and 6.0 of the SRP that may mitigate adverse environmental,

- social, and economic effects reviewed in section 7.0 of the SRP. These alternatives may -

include, but are not limited to-(a) Alternative ore extraction processes such as iraditional open-pit and underground mining ,

(b)- Alternative lixiviant chemistry

'(c) Alternative groundwater restoration techniques (d) Alternative waste management practices (e). Uranium recovery process alternatives (2) The alternatives are compared to the proposed actions pertaining to the site as reviewed in section 2.0 of the SRP and are consistent with existing mining standards and practices.

The rationale for selecting the proposed method should be provided, and the proposed action should be shown to be at least as effective as the considered diernatives in meeting all regulatory requirements, if the application is for a new cemmercial scale license, the consideration should be based on the results of the R&D site.

(3) _ Tiw applicant considers the environmental, social, and economic effects of a no-licensing alternative. Presumably, the applicant will provide information to demonstrate that the proposed action will provide social L and economic benefits that outweigh the environmental impact of operating the facility.

8.4 EVALUATION FINDINGS If the staff's review, as described in this section, results in the acceptance of the alternatives to the proposed action, the following conclusions may be presented in the TER.

The. NRC. has. completed its review of the alternatives to the proposed action at the '

ISL facility This review included an evaluation of the methods that will be used to develop the alternatives to the proposed action using the review procedures in SRP section 8.2 and the

= ,=== criteria outlined in SRP section 8.3.

The applicant has considered other alternatives to its proposed ISL facility such as open-pit or underground mining. Alternatives to the proposed facility operations that might mitigate environmental, social, and economic effects identified in SRP tection 7.0 are presented in a form similar to that required in sections 3.0,4.0, 5,0, and 6.0, of the SM. Alternatives were acceptably considered for lixlviant chemistry, groundwater restoration techniques, waste management practices, and uranium recovery processes. The applicant has demonstrated that the choice of alternative is effective in meeting all

_ regulatory requirements. Data from past operations or considerations based on results of an R&D site 84 a

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Alternatives to Proposed Action were included in the evaluation of the alternatives. The applicant has considered a no licensing alternative and has demonstrated that the social and economic benefits of the proposed ISL facility

. outweigh any adverse environmental impact of the facility.

8.5 - - REFERENCES None.

8-3 NUREG 1569 ii

9.0 BENEFIT-COST ANALYSIS 9.1 AREAS OF REVIEW The benefit-cost analysis proposed in this section is intended to be a summary of the benefits and costs of the proposed facility. The staff shall review the discussion provided and any accompanying illustrations and tables that exolain the important benefits and costs of the proposed facility and operations to determine that the issuance of a license isjustified. It is impcrtant that both quantitative and qualitative justifications be supported with acceptable data and appropriate rationale.

> The review shall include criteria for assessing and comparing benefits and costs where these are expressed in nonmonetary or qualitative terms and rationales for the selection of process alternatives as well as subsystem alternatives. The staff shall also evaluate descriptions of the potential cumulative effecte, and the rationale for omitting apparent benefits or costs.

9.2 REVIEW PROCEDURES The reviewer shall determine that the benefit-cost statement has t.ren summarized in the form of a narrative and accompanying tables and char:s. The important benefits and costs should be contrasted and discussed appropriately to justify the issuance of the license.

The reviewer shall determine that the applicant has developed criteria for assessing and comparing benefits and costs where they are expressed in nonmonetary or qualitative terms. Among the criteria that should be considered are: (i) groundwater quality or quantity effects, (ii) radiological impact, and (iii) disturbance of the land. The applicant shall present the rationales for the selection of process alternatives as well as subsystem alternatives. The reviewer shall ascertain that potential cumulative and symbiotic effects have been detailed along with appropriate rationales for such tradeoffs. If any apparent benefits or costs have been omitted by the applicant, the reviewer shall determine that the applicant has presented the rationale for such omis-. ions. The staff shall determine that the applicant has related all the terms used in the benefit-cost analysis to the relevant sections of the application. Overall, the benefit-cost section should demonstrate to the reviewer's satisfaction that the proposed project is a positive economic and social activity.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

9.3 ACCEPTANCE CRITERIA The benefit-cost analysis is acceptable if it meets the following criteria:

(1) The economic benefits of the construction and operation of the proposed facility are acceptably summarized. These may include, but are not limited to (a) Tax revenues to be received by federal, state, and local governmeats (b) Temporary and permanent jobs 9-1 NUREG-1569

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(c)- ; incremental increases in regional product l

_(d)L Enhancement of recreational values

- (e) -- ~ Environmental enhancement in support'of the propagation or protection of

- wildlife and the improvement of wildlife habitats ' y  ;

(f) . Creation and improvement of local roads, waterways, or 'other transportation

- facilities j, t

-(g)'  ; Increased knowledge of the environment ss a consequence of ecologicai5esearch and environmental monitoring activities associated with plant' operation and

= technological improvements from the applicant's research program

- (2)- Economic benefits are estimated based on realistic assumptions and objecti_ve sources such

- as census data, tax information, and other site characteristics reviewed in section 2.0 of -  :

the SRP.

'(3) - The applicant provides a summary of internal costs, including capital costs or land acquisition and improvementi capital costs of facility construction, other operating and Jmaintenance costs, plant decommissioning and site reclamation costs, and the costs of _

future improvements in the proposed facility; The costs .cf groundwater restoration, decommissioning, and reclamation are considered as presented in the financial assessment for surety reviewed in section 6.5 of the SRP, (4) The ap;licant summarizes short ter.n external costs as they affect the interests of people '

1 outsido of the owners and operators of the proposed facility, These may include, but are not lim ted to (a) Housino, shortages ,

(b) Local inflation (c) Noise and congestion (d) Overloading of the water supply, water treatment facilities, and disposal landfills (c) Crowding of schools, hospitals, recreational facilities, or other public facilities i

(f) Disruption of people's lives'(e.g., ranching, farming) through the acquisition of land (5) The applicant suntnarizes long-term external costs as they affec: the irderests of people outside of the owners and operators of the proposed facility. These may include, but are not lit-ited to -

(a) - Impairment of recreational values through reduction in wildlife and sport animals e

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Benefit-Cost An.tlysis (b) Restrictions on access to land or water (c) Aesthetic impacts (d) Degradation or limited access to areas of historical, scenic, or cultural interests (e) Lost income related to limitations on access to land and facilities (f) Decreased real estate values (g) Increased cost to provide government services for increased populations (6) The applicant identifies who is most likely to be affected by the construction and operation of the proposed facility, and to the extent possible, identifies how long the disturbance is expected. This information should be consistent with the population information reviewed in section 2.3 of the SRP.

(7) If the application is for a renewal, the applicant provides a summary of the actual economic benefits and costs of the facility since the last licensing action.

(8) A comparison of the be*nefits and costs is presented that acceptably justifies proceeding with the ISL operations.

(9) For special case EAs (e.g., those that have substantial public interest, decommissioning / decontamination cases that allow radioactivity in excess of release criteria, or cases where environmental justice issoes have been previously raised) the applicant has provided sufficient data to assess environmental justice issues in accordance with appendix E. T'ils assessment may be made in section 7.6.1.3 of this SRP.

9.4 EVALUATION FINDINGS If the staff's review, as described in this section, results in the acceptance of the benefit-cost analysis, the following conclusions may be presented in the TER.

The NRC has completed its review of the benefit-cost analysis for the ISL facility. This review included an evaluation of the methods that will be used to conduct the benefit-cost analysis and th results using the review procedures in SRP section 9.2 and the acceptance criteria outlined in SRP section 9.3.

The applicant has acceptably summarized the economic benefits of the construction and operation of the proposed ISL facility including (i) additional tax revenues, (ii) temporary and permanent jobs, (iii) incremental increases in regional product, (iv) enhancement of recreational values (v) environmental enhancement including protection or propagation of wildlife, (vi) creation and improvements in local infrastructure, and (vii) increased awareness of the environment resulting from ecological research and monitoring and any technological improvements resulting from the 9-3 NUREG-1569

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Benefit-Cost Analysis applicant's program. The applicant has determined economic benefits from objective sources including (i) census data, (ii) tax information, and (iii) other data as evaluated in section 2.0 of the SRP. The applicant has acceptably summarized costs including (1) internal, (ii) capital, (iii) other operating and maintenance, (iv) plant decommissioning and site reclamation, and (v) future improvements. The cos:s for groundwater restoration, decommissioning, and reclamation, as considered in the financial assessment for surety reviewed in section 6.5 of the SRP, are acceptable. The applicant has identified all short-term 4

ISL facility-driven external costs including (i) housing shortages; (ii) local inflation; (iii) noise and congestion; (iv) overloading of infrastructure (e.g. schools, water supply, transportation links); and (v) disruption of people's lives as a result of land acquisition. The applicant has acceptably determined all facility-driven long term external costs including (i) impacts on recreation through reduction in wildlife or sport animals; (ii) restrictions to access to land or water; (iii) aesthetic impacts; (iv) degradation or limited access to historic, scenic, or cultural interests; (v) lost income related to limitations on access to land or recreational facilities; (vi) decreased real estate values; and (vii) increased costs to provide government services for any additional population. The applicant has acceptably identified and considered the extent and longevity of effect of construction and operation on individuals. The applicant has presented a comparison of the benefits and costs that acceptably justifies the proposed ISL facility and operations.

9.5 REFERENCES

None.

I NUREG-1569 94

10.0 ENVIRONMENTAL APPROVALS AND CONSULTATIONS 10.1 AREAS OF REVIEW The staff shall review all licenses, permits, and other approvals of construction and c- c w required by federal, state, local, and regional authorities for the protection of the environment inuuu...g a list of those federal and state approvals that have already been receiver md the status of those pending approvals. The staff shall also review similar information regarding appn Js, licenses, and contacts with tribal authorities. The staff will examine previously submitted environmental assessments or environmental impact statements, if appropriate.

The staff shall evaluate discussions of the status of efforts to obtain a water quality certification under section 401 and discharge permits under section 402 of the Federal Water Pollution Control Act, as amended, if required including the rationale if certification is not required. The staff shall also note the state, local, and regional planning authorities that have been contacted or consulted.

Finally, the staff shall review descriptions of meetings held with environmental and other citizen groups with reference to specific instances of the compliance with citizen group recommendations.

10,2 REVIEW PROCEDURES The reviewer shall determine that the applicant has satisfied all license, permit, and other approvals of construction and operations that are required by federal, state, local, and regioral authorities for the protection of the environment. Types of licenses or permits may include but are not limited to (i) source materials, (ii) underground injection, (iii) pond construction, (iv) surface discharge, (v) industrial groundwater, (vi) aquifer exemption, (vii) air quality, and (viii) disposal well. The federal and state approvals that have already been received should be listed, and those pending approval should be appropriately identified. The reviewer should determine that the applicant has presented the appropriate environmental assessment or full environmental impact assessment for the proposed ISL site and surrounding area regardless of whether the assessments are pre-existing or prepared especially for this application. This section is intended to cover licensing and permitting of the process as a whole or parts of the process, and does not require a listing of certifications that may be required for equipment or personnel. Copies of associated documentation may be provided as an appendit to the application.

For license renewals and amendment applications, appendix A to this standard review plan (SRP) provides guidance for examining facility operations and the approach that should be used in evaluating amendments and renewal applications.

10.3 ACCEI"I'ANCE CRITERIA The status of environmental approvals and consultations is acceptab.e if it meets the following criteria:

(1) The applicant provides a summary of all permits or licenses obtained for the proposed facility. These should clearly identify (a) The type of permit or license 10-1 NUREG-1569

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.(b) _.The granting authority (local, state, regional, tribal authorities, or federal);

(c) The permit or license number (if appropriate) ,

(d) The current status,' with expiration date, if appropriate .

~

(2) For permits not yet granted, the applicant provides a discussion of the current status of the application and objective evidence that the applicant has applied for, but has not yet received, the permit from the gnnting authority. Such evidence may include copies of documents such as letters from the graming authority or the permit application.

(3) For permits and licenses not yet granted, the applicant indicates when approval is expected. Consultat!ons with the granting authority can be summarized.

(4) The granting authority is clearly defined and appropriate to the area being permitted or licensed if p,11ts are granted under agreement state status, this should be identified in the application.

(5) The applicant summarizes meetings held with environmental and other citizens groups since the lest licensing application, and responses to the concerns expressed at these meetings.

10.4 - EVALUATION FINDINGS If the staff's review, as described in this section, results in the acceptance of the environmental .

approvals and consultations, the following conclusions may be presented in the TER.

The NRC has completed its review of the environmental approvals and consultations for the ISL facility. This review included an evaluation of the methods that will be used to acquire the environmental approvals and consultations using the review procedures in SRP section 10.2 and the acceptance criteria outlined in SRP section 10.3.

The applicant has acce;' ably identified the environmental approvals and consultations obtained or required for the proposed ISL facility. The applicant has provided a summary of all pennits and licenses obtained for the proposed facility that identifies the type of permit (license),

the granting authority, the assigned number, and the current status with expiration date (if appropriate).

For permits not yet received, the applicant has provided a discussion of the status of the application and evidence that the applicant has requested the appropriate permits, and an indication of when the approval is expected. The applicant has identified all permits issued under agreement state status and demonstrated that the granting authority is appropriate for all pennits. Any meetings held with environmental and citizen's groups are acceptably documented.

10.5 REFERENCES

- None.

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APPENDIX A  :

GUIDANCE FOR REVIEWING HISTORICAL ASPECTS OF SITE i PERFORMANCE FOR LICENSE RENEWALS AND l AMENDMENTS  !

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APPENDIX A GUIDANCE FOR REVIEWING HISTORICAL ASPECTS OF SITE PERFORMANCE FOR LICENSE RENEWALS AND AMENDMENTS For license renewals and amendments, the historical record of site operations provides valuable information for evaluating the licensing actions. Following are specific areas where a compliance history or record of site operations and changes should be provided for review:

  • Amendments and changes to operating practices or procedures
  • License violations identified during Nuclear Regulatory Commission (NRC) or agreement state site inspections
  • Excursions and resultant cleanup histories or status
  • Exceedences of any radiation exposure, contamination, or release limits
  • Exceedences of any nonradiation contaminant exposure or release limits
  • Changes to any site characterization information important to the evaluation of exposure pathways and doses including site location and 1&yout, uses of adjacent lands and waters, population distributions, meteorology, the geologic or hydrologic setting, ecology, background radiological or nonradiological characteristics, and other environmental features.
  • Effects of site operations including data on radiological and nonradiological effects, accidents, and the economic and social effects of operations.
  • Changes to factors that may cause reconsideration of alternatives to the pro, ased action
  • Changes to the economic costs and benefits for the facility since the last application if after a review of these historical aspects of site operations, the staff concludes that the site has been operated so as to protect health and safety and the environment, and that no unreviewed safety related concerns have been identified, only those changes proposed by the license renewal or amendment or application should be reviewed using the appropriate sections of this standais review plan. Aspects of the facility and its operations that have not changed since the last license renewal or amendment should not be reexamined.

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APPENDIX B i l

ENVIRONMENTAL JUSTICE IN NATIONAL ENVIRONMENTAL POLICY ACT OF 1%9 DOCUMENTS NUREG-1569

APPENDIX B ENVIRONMENTAL JUSTICE IN NATIONAL ENVIRONMENTAL POLICY ACT OF 1%9 DOCUMENTS Backaround On February 11, 1984, the President signed Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low income Populations, which divets all federal agencies to develop strategies for considering environmental justice in their programs, policies, and activities. Environmental justice is described in the Executive Order as " identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations." The Nuclear Regulatory Commission (NRC) will consider the Cwncil on Environmental Quality (CEQ) guidelines on how to take environmental justice into account when preparing documents under the National Environmental Policy Act (NEPA). This procedure provides interim guidance on where and how environmental justice is to be handled in NEPA documents. When the CEQ guidelines are available, this interim procedure will be revised, as required. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards policy is presented below.

Policy It is the policy of the Office of Nuclear Material Safety and Safeguards (NMSS) to address environmental justice in every environmental impact statement (EIS) and every supplement to an EIS that is issued by NMSS. Except in special cases, environmental justice need not be addressed for environmental assessments (EAs) in which a finding of no significant impact (FONSI) is made.

For EAs with a FONSI determination, the staff concludes as part of its analysis that there will be no significant impacts from the action. Therefore, there would be no disproportionately high and adverse effects or impacts on members of the public, including minority or low income populat. ' Generally, no environmental justice evaluation need be performed. However, there will be special cases where environmental justice reviews will be required for actions in which an EA/FONSI is prepared. These cases may include regulatory actions that have substantial public interest, decommissioning cases involving onsite dispesal in accordance with 10 CFR 20.2002, decommissioning / decontamination cases which allow residual radioactivity in excess of release criteria, or cases where environmental justice issues have been previously raised. Management (division director / branch chief) will decide on a case-by-case basis when special circumstances exist that require the staff to perfonn an environmental justice review for an EA.

The level of discussion on environmental justice will vary based on the circumstances of each action. The actual determina ion of impacts. will not change; the evaluation and analysis will be expanded.

Environmental ju:tice is a different manner of characterizing the impacts; it does not identify new impacts te analyze, although it does involve the collection of additional data. Each EIS or special case EA should contain a section that fully describes the environmental justice review process; the length of the section depends on the circumstances. Guidance is provided below.

B-1 NUREG-1569

1 I

Proce49In (1) The first step in evaluating environmental justice potential is to obtain demographic data (census data) for the immediate site area and surrounding communities. Data for the state, county, and town will also be necessary. The demographic data should consist of income levels and minority breakdown. For the purpose of this procedure, minority is defined as individuals classified by the U.S. Bureau of the Census as Negro / Black / African American, Hispanic, Asian and Pacific Islander, American Indian, Eskimo, Aleut, and other non-White persons. Low-income is defined as being below the poverty level as defmed by the U.S. Census Bureau.

d Guidelines for .etermining the area for assessment are provided in the following discussion. If the facility is located within the city limits, a 0.56 mi radius ( l square mi) from the center of the site is probably sufficient for evaluation purposes; however, if the facility itself covers this much area, use a radius that would be equivalent to 0.5 mi from the site. If the facility is located outside the city limits or in a rural are'a, a 4 mi radius (50 square mi) should be used.

[The U S. Environmental Protection Agency (EPA) is currently using i square mi and 50 square mi for their environmental justice profiles; they use both for each site.] These are guidelines, the geographic scale should be commensurate with the potential impact area (i.e.,

if impacts are predicted out to 5 mi, a 5 mi radius should be used). The goal is to evaluate the

" communities," neighborhoods, or areas that may be disproportionately impacted. The reviewer should consider an incremental radius (e.g., if a 4 mi radius is chosen, also obtain data for the 1,2, and 3 mi radii). The specific census data may be difficult to obtain; one possible source is the Geographic Information System. Other sources include the applicant, local governments, state agencies, or local universities, it is recommended that the U.S. Bureau of the Census 10-yr census for data on minorities and income level be used. The U.S. Bureau of the Census 10-yr census data has poverty thresholds that should be used for determining the number of economically stressed households. Use the best available information.

The next step is to compare the area's percentage of minority population to the state and county percentage of minority population and to compare the area's percentage economically stressed households to the state percentage of economically stressed households. Note that the jurisdiction that the area percentage is compared to is dependent on the geographic area used in describing the demographics.1; is possible that the geographic area could cross county and state lines and this should be considered when making comparisons. If the area percentage exceeds that of the state or county percentage (or the comparison base used) for either minority population or economically stressed households by 20 percent, the site does have an environmental justice potential and environmental justice will have to be considered in greater detail. Additionally, if either the minority or low-income population percentage exceeds 50 percent, environmentaljustice will have to be considered in greater detail, if neither criterion is met, the site does not have an environmentaljustice potential and no further evaluation is necessary. Document the conclusion in the environmental justice section.

(2) Once it is determined that a site does have a potential for an environmental justice concern, it is then necessary to determine if there is a " disproportionately high and adverse" impact (human health or environmental effect) to the minority or low-income population surrounding the site.

This does not involve determining if there are any new impacts; impacts of the proposed action are to be determined in the usual manner. The impacts should be evaluated to determine those that affect these populations. In considering the impacts to the populations, differential patterns NUREG 1569 ~ B-2

of consumption of natural resources should be considered (i.e., differences in rates and/or patterns of fish, vegetable, water and/or wildlife consumption among groups defined by demographic factors such as socioeconomic status, race, ethnicity, and/or cultural attributes.)

The impacts to the local area surrounding the site should be summarized in the environmental justice section. It is not necessary to discuss the impacts at the same level of detail as in the impact sections, it is acceptable to briefly mention the impact and reference the section where it is discussed in greater detail.

The next step is to determine if the impacts disproportionately impact the minority or low-income population. Are the impacts greater for these populations? Are there any impacts experienced by these populations that are not experienced by others? In cases where the population is located next to the site, the impacts or potential for impact will likely be disproportionate for these populations. For instance, potential exposure to effluents may be greater for those living closest to the facility, or noise and traffic may disrupt nearby residents to a greater extent than those hving far from the site, and the potential risk due to accidents may be greater for nearby residents. If there are no disproportionate impacts, environmental justice is not an issue, and no further analysis would be needed. Document the findings in the environmental justice section.

Next, it is necessary to determine if the impacts are high and adverse. Another way of stating this is: are the impacts significant, unacceptable or above generally accepted norms such as regulatory limits or sate and local statues and ordinances. Each impact should be reviewed for significance. If the statement can be made that none of the impacts is significant, then there are no disproportionate adverse and high impacts on the minority or low-income populations.

Document the conclusion in the environmental justice section.

(3) If there are significant impacts to the minority or low-income populations, it is then necessary to look at mitigative measures and benefits. Determine if there are any mitigative measures that could be taken to reduce the impact. Discuss the measures. Discuss the benefits of the project to surrounding communities. Benefits to a specific group may be difficult to determine; particularly economic benefits. The conclusion at this point is project specific. The conclusion may be that there are disproportionately high and adverse impacts to minority and low-income populations; however, the mitigative measures and/or the benefits of a project outweigh the disproportionate impacts, if this is not the case, the facts should be presented so that the ultimate decision maker can weigh all aspects in making the agency decision. The Executive Order does not prohibit taking an action where there are disproportionate high and adverse impacts to minority and low-income populations.

(4) The results of an environmental justice evaluation should be documented in the EIS or special case EA. The document should contain a distinct section on environmental justice even if the demographics do not indicate a potential for an envirotunental justice concern. If a site has already received an environmental justice evaluation, it is acceptable to reference the previous evaluation and provide a summary of the findings and then add any new information that results from the proposed action. For instance, if environmentai justice is included in a license renewal, it would not need to be completely readdressed for a license amendment.

Staff shall look at the demographics of a site early in the review process. This will enable the staff to identify affected populations and include the affected population in the process. If public meetings are B3 NUREG-1569

L held concerning a specific site, an attempt should be made to include any-minority cr low income community in the meetings, Extra measures should be taken to ensure that minority and low income i populations are given the opponunity to panicipate. These may include holding public meetings in the evenings or weekends or translating notices (and other documents) into a larquage other than English.

If a representative (s) of the affected population has been identified, such as an officer of an organized local group or a community leader, the individual (s) should receive notices of meetings and copies of

' Federal Register notices. During scoping meetings for an EIS, NMSS. staff shall solicit input on

- enviionmental justice issues, NUREG-1569 B-4

l i

e i

1 APPENDIX C MILDOS-AREA: AN UPDATE WITH INCORPORATION OF IN SITU LEACH URANIUM RECOVERY TECHNOLOGY

.l s

NUREG-1569

. - . . . = . -. - . . . . .. . _ . . - . .. . . . . .

APPENDIX C MILDOS-AREA: AN UPDATE WITH-INCORPORATION OF IN SITU LEACH URANIUM RECOVERY TECHNOLOGY Letter Report MILDOS-AREA: An Update with Incorporation ofIn Situ Leach Uranium Recovery Technology

  • EJt. Falancs, DJ.12Poire, S. Y. Chen, and Y. Yuan" Environmental Assessment Division Argonne Nationallaboratory 9700 South Cass Avenue Argonne,IL 60439
  • Wed: supponed by te U.S Nuclear Regulasary Commission and the U.S. Department of Energy. Assistant Sacrosary for Environmental!" ;- .under Contract W 31 109-Eng 38. l

! " Yuan is affiliased with Square Y Consultanta, Orchard Park, NY t l

l C-1 NUREG-1569 i

i

- - . - . - . . = . - - -. .-. -- -- .

l May 1995 ~

Contents

1. LVTRODUCrlON- .I
2. PROJECTOllJECTIVE . _. 2
3. MODIHCATIONS TO THE MILDOS. AREA CODE 2
4. SOURCE TERM ESTIMATION FOR A SAMPLE ISL FACILITY 3 4.1 New W d <V -4 4.2 Prakwelan Wd Held -4 4.3 Dying and Packaging of Yellow Cake 7 4.4 Remoration Wed Held - 8 4.5 Releases from Land Appiimilon Anas 9
5. EXAMPLE OF SOURCE TERM CALCULATION FOR SAMPLE ISL FACILITY 10 5.1 Summary of Pdndpal Operating Charactedstics of the Single ISL Facility . 13 5.2 New Wd Held Ikilling/Constadion Area: We5 Meid 13 5.3 Production Well Meid 2 14 5.4 Production Well Meid 3 15 53 Restoration Was Held 16 5.6 Imd Appilmelan (Inisation) Ama 17 5.7 Main Pmesedag Facility- - 18
6. DESCRII'rION OF PATCH PROGRAM -19 lii NURiiG.1569 C-2 I

1

7. REFERENCES- - 19 Attachment 1: MILDOS. AREA Data input File for Sample ISL Site _ 21 Attachment 2: MILDOS AREA Output Hie for Sample ISL Site- . 25 Tables 11 Anowable Concentndlons Used in MILDOS-AREA :3 51 Soum and Receptor Coordinates _ 12 M8WT 51 Map of Sample ISL Facility 11 1

iv C3 NUREG 1569 i

w-i

i
1 Dfl'RODUCTION.

De MILDOS AREA conputer code was devehped at Argonne Nadonal 1.aboratory in 1989 (Yuan et at 1989) for evaluating radiobsical inpacts of uranium pmcessmg facilities. De code was nvvwi o from the original MIIJY"i code (Strenge and Bander 1984) to include large area sources and to incorporate changes in methods for dommetry c=F%ns. MIIDOS AREA estimates the-radiok,sicalinpacts of airbome emissions of radioisotopes of the uranium-238 series. Two ddierent measures are calculated: dose conmitments to hurmn receptors and annual average air concentrations.  !

MHDOS-AREA incorpornsed dose conversion factors derived by the International Commission on-Radiological Proescuo- (ICRP) recommendatins of 1978. De annti ' average air concentrations were conpared with the noxinaim permissible concentrations (MPCs) in the U.S. Nuclear Regulatory Convriission's Ssandandsfor Prosecnon agalart Radiation (10 CFR Part 20). On January 1,1994, s revision to 10 CFR Part 20 (revised Part 20) went into effect. De' revised Part 20 updated its

~

dosimsey to the ICRP 1978 recommendanons De dose limit to the general public also changed. De changes led to a revison of the calcuinted aDowable concentranons for w.ww.;iod areas, with MPC behag repinced by the term " effluent concentratkms." nerefore, the cakulations perfomed by

< MILDOS-AREA were r.ot consistent with the current terminology and data conauned in the revised Part 20.

la addition, a new trathod of ncovenng uramum g.uned populariry in the late 1980s, and now the nusonty of operating licensees use the in . situ leach (ISL) method. In a typical ISL naning site (Hunter 1996), a hconsee uses a series of injection wens that introduce dissolved oxygen and sodium carbonnen/bacarbonate into the ore sone. De uranium is mobihand and is v.au.cied through a series of punging wedis.- De uranium rich weser is routed through a processing building, where the uranium is - l removed from the water by lon-exchange (IX) colurms. 'The loaded IX resin is then prncened to

, remove the uranium (elution). - De eluted uranium is further processed into a concentrated uranium l sluny, De slurry is then dried into yellow cake (UA). De dried U303 is pa+=d and slupped for further pmcassing into ennched uranium and reactor fuel j i

NUREG-lM9 C-4

- .- - _.=.- -.-- .- -

... - . , . - - . . . - = - _ - . - - . ,

Some ISL facihs have smaller processing plants renote from the main processing plant. These plants, called satellite facilides, generally will couect the uraniurn in resin tanks and then ship the loaded resin to the main processing plant for elutbn drying, and packaging. The satellite facilities allow the licensee to econorisally mine uranium a distance away from the rmin processing plant.

2 PROJECTOBJECTIVES 1he overall objecove of this project is o a update the MIIDOS AREA code data structures and tenrunology to te cormstent with revised 10 CFR Past 20. Anoder objective is the creation of an exanple problem for ISL facilides. FmaDy, the above objecuves resuk in the creation of a patch program that will update current versions of MIIDOS AREA to the new version.

This report consists of three components: (1) modfration of the data structure of the MILDOS-AREA code, (2) source term derivation for the ISL nining technology, and (3) applicauon of this rnethodology in the sanple problem Fmally, a conputer patch program containing this updated informanon is described. This patch program is to be attached to MILDOS AREA as an update for the parucular applicanon.

3 MODIFICATIONS TO THE MILDOS AREA CODE Two sets of nuventhns are rmde to the MILDOS AREA code. These changes resect both the semar. tic and the dosim-nic revisions implenented in thr. revised 10 CFR Part 20.

The fast mrviifw-athn consists of replacing all occunences of MPC with aBowable concentration (ALC). 'these chmges a5ect the last page(s) of output for each time step (see Attachment II), where the concentrations of radionuclides in air at each receptor locauon oc reported. These pages are now refened to as the "Resuks of the ALC Check at this 1.ocation."

2 C-5 NUREG-1569

}

The second untirnrian consists of replacing the oki MPC values in de MIIDOS AREA database with the numbers currendy 'MiM under EfDuent Concentrations (Air Column 1) in Table 2 of Appendix B to the revised 10 CFR Fart 20. An exception is radon-222 (Rn-222), where de ALC is expressed in units of working level (WL). The value for Rn 222 is derived as specifed in du text of Appendix B: to revised Part 20; the occupadonal derived air concentratbn of 1/3 WL has been divided by 300. Table 3 1 lists the radionuclides and the ALCs used in MILDOS-AREA.

TABLE 31 ADowable Concentradons Used in MILDOS. AREA Radbnuclide AC Defauk (Inhalation Class) Inhalation Class (pCVm')

Uranunw238 3(D),1(W),0.06(Y) Y Uraniunv234 3(D),1(W),0.05(Y) Y Thoriunv230 0.02(W),0.03(Y) W Radituw226 0.9 (W) W Radon-222 1/900 (*) (*)

lead-210 0.6 (D) D Bismuth 210 500(D),40(W) W Pobniurw210 0.9 (D),0.9 (W) W

(*) Radon 222 is gaseous; the AC is reported in WLs.

4 SOURCE TERM ESITMATION FOR A SAMPLE ISL FACILITY

'Ihe sources of radioactive effluent from an operatmg ISL uranium recovery facshty include (1)the drilling operanon at new wen Gelds, (2) uranntm extraction operanons at production well fickis, (3) drying and packaging of yelbw cake, (4)testoration operations at ok! well felds, and (5) land application areas. 'the following sections describe a methodology for source term derivation for ISL sites that may be used instead of the methodobgy presented in NUREGER-4088 (Hartley et al 1985). Other methodologies may be more wiupriatefor a particular operating site.

3 NUREG-1569 C-6

4.1 New Wd Held Convenuonal rotary rigs are conwnonly enployed for d dnlling activines at an ISL facility. Because all exploranon driR holes are driBed by using and a sealed with high-viscosity benton* nud to naintain aquifer isolation, no partculates are expected to be released during drilhng operauons. The

- only source of radcacts release is the Ra 222 from radamcontaining ore cuttings wiver.rDy stored in the mud pit. Dunng the period when the ore cuttings are awaiting disposal while stored in a nud pit, radianceive decay of radiurw226 (Ra 226) is producing redon condnuously. The amount of Rn-222 availabis for release, or the noxinum release rate, in a year as a resuk of Ra-226 decay from ore cuttings ki storage is assumud to be given by the following expression:

Rn = 10'" EL(Ral l'M N , (1) where Rs = Rn 226 release rate from new wel fiek! (CVyr),

10-'8 = unit conversion factor (CVpC1),

/Ra/ = conamration of Ra-226 in ore (pGg),

i E = amenatirn6 Power (Cimensionless),

L = decay constant of Rn-222 (0.181/d),

T = storage time in ned pit (c'),

M = average rnass of ore matennl in the pit (g), and N = nunter of mud pits generased per 3 ear.

4.2 Penductics Wd Reid No particulate masennis are expected to be rekased from the production wen fieki hecane its process streams, from production and injection weds to IX columns in the antethre facihty, are an in a closed-loop cirt:uit. 'The pnmary radcactive emssion from the process streams of the production well ficki is 4

C-7 NUREG-1569 4

m R.1222 gas. In the natural environment, radon enwates continuously in the ground and nigrates through the rock or soil by both diffusion and convection. The novement of radon in groundwater in nest cases is gc.emed by water transpon, rade. than by diffusion (Hess et al.1985; Mueller Associates, Ire.1986). In an ISL production well field, the radon relerd from the ore body is readdy rernowd by the process ..aer ("hxiviant") moving through the well field by injection and production weas. 'Ihe 3.8 day half life of Rn-222 allows k to circulate along whh the process water in the well field over a long time before k decays.

The poneral equation describing the change in Rn-222 concentration over time in the process water of e web field can be expressed as:

dCa.

V , yg , gg , yy y (,, , (p, , y,y (,, , g 3y dT where V = volume of water in circulation (L),

C,. = Rn 222 concentranon in process water (pCVL),

f = fraction of radon source carried by cixulaung water (dimensionless),

S = radonsource(pCVd).

L = decay constant of Ra 222 (0.181/d),

y = rase of radon vendng from piping and valves during circuladon (1/d),

F, = " purge" rate of treated water (Ud), and F, = water discharge rate from resin unloading ofIX columns (1/d).

The balarre of the fraction of radon source camed by cin:ulating water accounts for any radon in the mined area that is not swept into the iniection-production wellloop and remains trapped in the ore zone. The " purge" or " bleed" in the production well fieki is necessary to maintain a hydrauhc cone of dep6ession around each well field to prevent leakage of nuning solutions cud the production zone.

S l

NUREG 1569 C-8 l

1 l

1he redon soun= isrm, s, can be exposeed as I

s = 10' x L E /Ra/ A D P , (3) where .

10' = unit conversion factor (en/h/),

E = emanating power of active ore zone (dimensionless),

[Ra) = Ra 226 concentration in ore sone (pCVg),

A = active area of ore none (m'),

D = average IM*naan of are mone (n0, and F = buk density of ore material (g/cmD.

The waser dacharge rate from nesin unloadmig, Fu can be :alculated by F, = N, V, P, , (4) where V, = vohmeconsentofIXcolurm(L),

N, = nurmber ofIX cobim unloadmgs per day, and 74 = possityofresicinnenrial Under senady s:ase corahtions, the Rn 222 concentration in the pocess wassr, Cm, can be written u o

( 5) -

Ca. =L +(10' v) V +(Rai Fr + F. A D P E L f_

When passwo is seduced during purging or when water is asneed dunng irrigation, radon is readily released to the ------,' ; 'Ps amount of Rn-222 available for release from the " purge" is dapawinne on the weser vokame purge taan, F,, and on the Ra-222 concentradon in the peged liquid, Cn. By p conservatively assummg that at available redon in the purge water is relop4 tie annual Rn 222 emissionis:

1 b Rn,, = 3.65 x 10* Ca. F, , ,

(6) 6 C-9 , NUREG-1569 o

,, - . - , , , - . - - - . - --.,,-m. , , . --

P where 1 3.65 x 10 = unit conversion factor (QpMWyr), and An. = Rn-222 release rate from purge water (CVyr).

The anni al Rn-222 releases from occasional venting from wellheads and leaking transport piping are Rn, = 3.63 x10* v Co. V , ( 7) where Rn. is the annual Rn-222 selease from venting (CVyr).

The annual redon 222 discharge from the unloading of the IX column contents is Rn, = 3.63 x10*Co.Fo , (8) where Rn, annual Rn-222 release from unloading ofIX coluna content (Ci/yr).

The total annual Rn-222 release from the production weH field is the rum of An., An., and Rn,.

The occunence of radon in warer is controDed by the chemkal concentradon of radium in ths hec * -oil or mck and the enussivity of radon into water. Radon enters air filled pores in the soil mainly hacanaa of the receu of redon atoms on the decay of Ra-226. The fraction of radon formed in the son which enters the pores is caDed the emanating power, reponed values range from about 1% to 80%, with in average of 20%, depending on soa type, pore space, and water content (MueBer Anancimaan Inc.

1986). Varying environmental condaions have been found to affect the rate (.t radon emanation. In particular, moisture has been found to have signi6 cant efliscts on the radon emanadon rate. For purposes of conservadvely esdnating the redon release from ISL wet fields, the enanating power is asumed to be 0.25.

4.3 Drying and Packaging of Youow Cake For facihdes using rotary vacuum dryen for prucsiig yeBow cake, no particulate enusions are expected under nomal operating condaions. For facilities using themmi drying, stack releases nay be 7

NUREG-1569 C-10

estimated on the basis of infornsbn provided by a nun &r of operating ISL uranium recovery facDhies. Ahhough note data are needed, the stack release of yellow cake has been estimated to M about 0.05% of the amount produced; however, because the day-to-day variations of particulate release rates can vary by several times, the assuription is that 0.1% of the uranium produced escapes as p:r*.ic.httes into the atmosphete, as suggested in the Final Gencric EnvironmentalImpa. ..atement on Uranium Milling (NRC 1980).

The particulate release of nuclides other than uranium isotopes is estimated by grab sanples reported by ISL facGiries (e.g., Semiannual Reports for Highlana Uranium Project, Irigary and Christensen Ranch Projects, Crownpoint, and others). On the basis of the field measurements, the cornervative assunption is that the acuvaties of thornim (0.15-0.4% of measured values), radium (0.2-0.3%), lead, polonium, arxl ks decay progeny are 0.5% of the U 238 activuy in the yellow cake. Furthermore, k may be assumed that the fraction of this activity that is relemmi is the same as the fracuon of uranium (0.1%) that is released.

4.4 Restoration We5 Held The basic operaung } .a of the restoration weH field are sumuar to those of the prodxtion weH fiekt. Groundwater a5ected by neaching pr==*e in the production web fieldt is restored to its prensning levels (1) 'oy the " pun, and Leat" (groundwater sweep) method and by Dustung whh fresh water injection, and (2) by using the permeauve stream from reverse-osmosis treatment units. ljke the production we# fieki, no particulate matenals are expected to be released from the restoration wen ficki operanons. The pnmary source of radioacuve release is the Rn-222 gas in the process water circulating within and discharged from the resto:stion operations. 'Ihe annual Rn 222 releases from the restoration wen field therefore can be r=wle~i by Equations 6 and 7.

8 C-11 NUREG-1569 l

4.5 Ph Aronalmd Appikatha Artes Rationuclite<:nntaining waw, ekher frem purge wr* r from productbn wcB fekis or from restoration wastewater trom restoration web fekis, is treated to unre.tricted release nevels ard dhposed of by irrigation. Reinae onto ^e sou surface wiu contaminate the soil at the tard applicauon areas. 'De radorm:5 des adsorted by the sou wiu become a source term fet radioact,v; release through wind erosion proceanos. To estimase this wind generased source term by urine MILDOS. AREA, the radionuclide concentratbm in the sou reeds to be estimated frst. 'De radion- lide coroentration in the contaminated surface soR region of the land application area. C,, is calculated by C, = #' . ( 9)

.\, So P, where C, = radionuclide concentratbn in the surtaae sou (pCVg),

/6' = unk conversion factor (1/cm'),

V, a total volume of waner released onto the land calication area (m'),

C. = radionuclide concentration h tressed water (pCE).

A, = area ofland application (rd),

Se = aneumed depdi of contaminated assa (m),

r, = buk densityof surface sol (shd), and A, = taction nf radionuclide in irrigation water retained in the soa partienes (dmensknless).

The Asetion of redbnuclides in irrigation water retained ki de sou partienes, R., can be calculated with the fokiwing domada:

R = (1 1). (10)

Ro

'De resaniation factor, As. can be calculated with the foBowing fomm'.a:

R,=1+ , (11)

W 9

NUREG 1$69 C 12

I i

i wiese Ks = radionucide diaribution coetfernt (cm'/g), and w = soit volune water content (dinembnness).

1 1

The volunrtric water content of de soil, w, is the fraction of the total porosity of the soil naterial occupind by water. lie radionuclue distribution coefficient is de ratio of de radionuclide uguihhium j corcentradon of the adsorbed radionuc!de in sou to tM desorbed radioauclide in water, Represordadve distributbn coeffkents can be found in the report by Yu et at (1993).

5.0 EXAMPLE OF SOURCE TERM CALCULATION FOR SAMPLE ISL FAPILrrY 11e followin- exarmio illustrates some typkal cekulations that rney be uri to derive tie source term at a hypodetical operstmg ISL uranium rocovery facihty The exanple covers the potential operations dat may resuk in radionucide teleases to de air from a typical facilty. An mput file for use by the M11 DOS AREA code is provided for sis exartpne (Attachnert I), as weH as the doses to hypothetical receptors calculated by the code (Attachment II). Note dat reasonable assunptions for input paraneters have teen used for this hypodetical site, but these imut data are not intended so rerve as subsrinstesfor data collected at actual operatingfacilities.

'Ihe is>out of de hypodedcal siis is shown in Figure 51, it consias of a main processing facility, a satenite facility, one won fiek! under devebpment (actim wou feki 1, two production won fields (active wen fends 2 and 3), a restorttion won fend, two radium setthng poruls (P1 and P2), a holding pond, arut an irrigation pbt. Only straD portions of the wen fiekts are assumed to be active over any one > ear period of operations. Eight receptor locarbns are idenufied. Of these,locarbn 5 is included within a cattle grazing area to estimato the dose from consunption of livestock product.s that tray become contaanrated fmm site releases. Sourte and receptor locations are reported in kibmeters east (r coortbnate) and north (y coordnate) of t'w dryer stack in t's man pic4g facDay, Negative values of x and y coordinates indcate west and south drections, resrectiwh Table 5-! 1:sts the coordnates 10 C.13 NUREG 1569

Figwe 5-1. Layoun of Hyg&M ISL FaciSty z

C h ~

9 c:

+8 Grazing Area (4 333. 1378) k I;$f\ !8 (f#$$8ti6'h'c..

i I'

s g

4 s <-us4. im) wgML,,

000000000c '

om 2 22e N'39 > (1 *$$$$7 3 i

gy\ *2 : 2

([o'( -' s s M, +

d M +

g s[3 bx x i . ,,.,.,,

9 \ am M (j-(-2.274. 4.oso) 7-- g \ l h/ o on

\

~

\ [ / P1 (4 34 . a) 092)

A  % 19 j s/ E s*Y' S 7 /. t SF (4.629, 4377) ( 4 434. -1.464)

  1. Et

~ ~ ~.' ~.y o azz. -s m, P2 (-6.708. -0.595) '

imgation Plot 0.5 0 #

' 0.5 Kilometers

M (0.182. -2.607}

Receptor Location Site Boundary M Radium-Se:thng Pond St - Satellite Facility MPF - Main Prnressing Facility

l  !

j TABIE5-1 Searceand ReceptorCoordneces i

I Source East (km) horik (km) - :: .1 Fast (km) Nonh (km) l 1.Yeaow CJe Dryer Seack 0.000 S.000 Recepeer 1 pnent.ilf* g.gge 1.33s i

. 2.timin Procesang FacmayIX Cohsens 0.On6 0.000 Roonpter2 padmem4 1.4(,7 8.114 3.SeWacey 4.6 ) 4 377 Recepter3 pnendset 1.812 -120B

!- 4. Rasum.Segeng Pond 1 -031 4ARE Recepeer4(Inesteset 0.142 -2 807 l 5.Radum Seedng Pond 2 4.708 4.505 Recepeer 5 % -3.104 1.2ee

s. Acsswo Wes Field 1 (Area Sonance) -7.383 1.142 Recepter a pnessess4 -2274 4.08
-7.300 1.313 Roospear7 pneulese4 -4_434 -1.464 [

j -7.145 1.464 Recepter3 % 4.333 1.373 j 4.803 1.300  ;

7. Acsere was Field 2(Area Source) -5.440 -1.488 l

-4A79 -1.053

[*

-5.380

-52e2

-1.438

-1.5 tis j um

8. Acteve Wes Field 3 (Anse Source) -1.423 OJ07 I

! -1.305 0325

) -1.104 0.575

-0.886 0.441 j l 9. Ressorahon Wet Fioed (Area Source) -0.248 0.407 O.054 OA27 i j 0.137 0.575 1 -0.014 0.374

10. Imgamon Plot (Area Source) -0.889 -1.839 4 -0.830 -1.825

-0.952 -1.704

-0.911 -1.448

, Z

! C N

O. .

1 emm I

} D i

i i

r used in the input data file for each w,urce ard receptor. The meteorology for the site is assumrd to te the pertic Sie proviled with the code.

5.1 Summary of Prindpal Operating Charnderistiu of the Sample ISL Facility The following parameten apply to the entire facilay:

Yellow cake production rate = $20 metne ton (Miyyr Average ore aethiry. U.238 and each progeny in secular equilibrium = 280 pCVs Oro poroairy = 0.28 Oro density = 1.8 gbd .

5.2 New Was Pleid Drbs/ Construction Arve (Wes Fleid 1):

A portion of wou field I, located north of the satellite facility, is under development, as foBows:

Number of new weus per peak year = 600 Number of new wells per mud pit = 12 Number of nand pits = 60(V12 = 50 Ore none thickness = 5 m Driu hole dameter e 8 in.

Aserage ore materiel per weH (g)= 3,14 x (8 in/2 x 2.54 cadn)* x 500 cm x 1.8 g/cm'= 2.9 x 10' 5

Total ore material in nand pie per year (g) = 3.5 x 10 Average stonge time of ore grade materialin mud pits = 12 d Radon emanating power = 0.25 For this location, on the basis of an average Ra 226 concentration of 280 pCyg, the annual Rn-222 enassion from the mud pit can be estimated by using Equation 1:

An = 10 '8 CVpC1 x 0.25 x 0.181/d x 280pCVs x 12 d x 3.5 x 10'F x 50fyr

= 0.027 Che 13 NUREG-1569 C-16

I

'The radon Dux can then be estimated by dniding the total etnission rate by the area under devebpnent as follows:

Area of active dnihng per 3 ear = 60,000 m' Average Rn 222 fktx rate = (10 pCW3 x 0.027 CWT)/(60,000 m8 x (3.15 x 10'4r))

8

= 0.0143 pCVm /s i

5J Production Wsu Flead 2 The following assunptions are used for the production well flekt located just to the east of the sateEse facihty:

Operating days per 3 ear = 365 Dimensions of the active ore to:ly:

Peak area per 3 ear to be nsed = 50,000 m' Averap thickness of ore bodies = 3 m Total flow volume in circulation in weR field = 50,000 x 3 x 0.28 = 42,000 m' = 4.2 x 10' L 1he following assunptions are made for the sateHite facility:

Demonsions or capacity of resin colurm = 3,500 gal Resin porosity = 0.4 Number ofloaded resin unloadings per day = 3 Wear dacharp rate from unbadmg ofIX cohmi

= 3,500 gal x 0.4 x 3.7851/ gal x 3/d = 1.6 x 10'[jd Total wastewater " purge" rate = 100 gallons per rdnute (gpn$

= 100 gpm x 3.785 t/ gal x 60 mird X 24 Nd = 5.5 x 10'l/d

. Praction of redon source camed by circulating water = 0.8 Rate of radon venting during circulation = 0.01/d The radon correntration in circulating water is derived by using Equation 5' :

Ca.= [(10' x 280 x 50,000 x 3 x 1.g x 0.25 x 0.181) x 0.8]/

'To reduce the lengh of this and other calculations, most of the units have been omined. The reader is referred back to the equations in C"sapter 4 for details on parameter descriptions and units.

14 C 17 NUREG-1569

I i

l 5

([0.191 x (4.2 x 10')) + 1(5.5 x 10 ) + (1.6 x 10'))) i

= [(3.4 x 10i3) x 0.8)/(8.6 x 10') = 3.2 x 10' pCVL  !

The radon rete.ve rue from purse waier into setiling pond P2 is derived by using Equxion 6:  ;

. An, =(3.65 x 10*) x (3.2 x 10') x (5.5 x 10')

= 64 CV)5 h radon release rate from gat vendng and leandng during circuladon is derived by using Equation 7:

5 An. =(3.65 x 10 8$ x 0.01 x (3.2 x 10) x (4.2 x 10')

= 49 CVyr  !

W radon release ra:e 60m IX unloading is derived by using Equation 8:

5 An, = (3.65 x 10*) x (3.2 x 10) x (1.6 x 10 8)  :

= 1.9 CVyr W total radon release from productier. well field 2 = 115 CVy .

5.4 Productka Weg F1eed 3 Tie following assumptions are used for the production wen 6eu located just to the mest of the main proonsaing kility:

0;ersig days per year = 365 Dimensions of the active ore body.

Peak area per year to be naned = 55,000 m' Average thickness of ore bodies = 5 m Total Gow volume in circulation in wet field

= 55,000 x 5 x 0.28 = 77,000 m' = 7.7 x 10' L The same parameters used for the sateBite facility servidng wen sew 2 apply to the IX fn:ility used for well Geld 3. *lhe following source tems have been derived by using Equadons 5 to 8.

W radon corwentration in circuladng water for weu Seki 3 is given by Cu o[(10' x 280 x 53,000 x 5 x 1.8 x 0.25 x 0.181)x0.8)/

{[0.191 x (7,7 x 10')] + ((5.5 x 10') + (l.5 x 10')))

= [(6.3 x 1082) x 0.8] /(1.53 x 10') = 3.3 x 10' pCi/L +

15 r

NUREG 1569 C-18 .

f 4- - --

--y w+, y- , , -w-, -, + < -,-v.., , .-.,-.w-w-. .,.---.u - --y .m.%- -- --- - . mm__- ----.__ -- -,-=

-. -__ __ - . _-. - . - . _ . ~ .--.-----.- .-

i l

'The radon relene rate from purge water into settling pond Pi is given by .

5 Rn. = (3.63 x 10 '*) x (3,3 x 10') x (5.5 x 10 )

= (4 Cyyy The radon release rate trom gas venting and leaking during circulation is given by  ;

Rn, = (3.65 x 10) x 0.01 x (3,3 x 10') x (7.7 x 10')

= 93 CVyr l

The radon relene rate from IX unloading is giver. by Rn = (3.65 x 10) x (31 x 10') x (1.6 x 10')

= 1.9 CVyr

'De total redon release from productbn weH feld 3 = 161 CVyr.

53 Radoration Well Field The fotbwing a.uurrptions were used for the restoration weu fend north of the main processing facuity.

Er.pected restoration operation time = 7 >t Operating days pec year = 240 Dimensions of restoration ore body:

Area per "o be restored = 100,000 m' Averge thickness of ore bodes = 5 m Total flow vol.;me in circulation ir well ficki

= 100 000 x 5 x 0.28 = 140,000 nf = 1.4 x 10'1 Total treated water " purge" rate = 200 gpm

= 200 gpm x 3.7851/ gal x 60 mi Vh x 24 Wd = 1.1 x 10'IJd Fraction of radon source camed by circulating w3ter = 0.8 Rate of radon venting during circulation = 0.01/d j

'Ihe following source terms have been derived by using Equations 5 to 7.

'Ihe radon concentration in circulating water for the restoration well ficki is given by Ca.=[(10' x 280 x 100,000 x 5 x 1,8 x 0.25 x 0.181) x 0.8}/

16 C 19 NUREG 1569

([0.191 x (1.4 x 10")] + (1.lmx 10')} }

= [(1.1 x 10'8) x 0.8]/(2.g x 10') = ?.3 x 10' pCVL The radon release rate from pury watz:into ser'H1 pond P1 is given by An., = r24365) x (3.65 x 10 ) x (3.3 x 10') x (1.1 x 10 8)

= 67 CVyr The redon relanse rate from gas vendng and lealdng during circulation h giwa by An, = (24365) x (3.65 x 10r *) x 0,01 x (3.3 x 10') X (1,4 x 10')

8 all0CVp The total radon relmane from the restoradon woe held = 197 CVyr.

5.6 Land Appikatior ' Irrigation) Asia The following assunptions are made for the irrigolon plot:

Radionuchde concentradons in the holding pord:

U 238 = 1,200 pCE 1h 230 = 5 pCE Ra 226 ard au progeny = 30 pCE land irription operation weer now rue = 400 spm

= 400 spm x 3.785 t/ gal X 60mirdi X 24 Wd = 2.2 x 10'IJd 1.and irrigation operadon = 122 Wyr Land irrigadon operation liiodne = 7 yr Total mlume waser released over operadon lifetirre

= (2.2 x 10'!)d) x 122 Wyr x 7 yr x 10~8 m'/L =1.9 x 10' m' Total are of clean wa. unser land appi;. don = 185,000 m' Assumed depth of contaminated area = 0.15 m Density of soil = 1.6 g/cm' sod volume water content = 0.25 Distribution coef5cient of soil (cm'/g):

Uranium = 50 17 NUREG 1569 C 20

Thonum = 60,000 Radarn = 70 te.ad = 100 The retaniation factors of surface soil, cakulated by using Equation !I, are Uranium = 320

'Ihorium = 380,000 Radium = 450 Iml = 640 The fraction of radionuclides in irrigation wakr that is retained in the surface soil, calculated by using Equation 10,is Uranium = 1 1horium = 1 Radium = 1 Imd=1 The land appbcation area peak surface soil radenuclide concentrations, calculased by using Equasion 9, are U 238 =(108 x 1,200 x 1,9 x 10' x !)/(185,000 x 0.15 x 1.6)

= 0.043 x 1,200 = 51 pCVg Th 230 = 0.043 x 5 = 0.21 pCVs Ra 226 = 0.043 x 30 = 1,3 pcyg pb 210 = 0043 x 30 = 1.3 pCVs Radon Dux = 1.3 pCVs x 1.0(pCVm'AV(pCVg)a 1.3(pCVm'/s) 5 7 Main Proesonna Fachky The following assurgeons appy to the main processing facility.

Yellow cake (U,CA) production = 520 MT/yr Stack release rate:

U 238 4

= 520 MT/yr x 0.001 x 10' gyr x 0.85 g U ns /g U3Ch x (3.3 x 10 0 U 238/g U nat) 18 C-21 NUREG 1569 I

= 0.146 CYyr Th.230

= 0.14 x 0.005 = 0.00073 CVyr Ra.226. Pb-210, and Po 210

= 0.146 x 0.005 = 0.00073 CVyr 6.0 I)ESCRil'r10N OF PATCH PROGRAM

  • Ihe revisions to de MILDOS AREA code are ircorporated in de following files:
  • MILMAIN.EXE. 'This Sie is the IORTRAN executable fue containing the revisions discussed in Ompter 3. It rephres the oki hDLMAIN.EXE.
  • SAMPISLDAT. This (de is the input data file for de exartple ISL facility described in Chapter 5.

It is listed in Attachment 1.

  • MILDOS.UPD. This data fue contains the updated allowable c' antration leveis for de radionucliles listed in Table 3-1.
  • README.TXT. This text fine contains instructions to MILDOS AREA on how to replace the ok! MILMAIN.EXE with the rew version and how to copy the other :wo files to de user's M11. DOS directory.

7.0 REITRENCES 1lattley, ).N. et al, I985, Methodsfor Estimating Radioactive and Tatic Airborne Source Termsfor Uranium Milling Operadont, NUREGER 4088, PNL 5338, prepared by Pacirc Northwest Laboratory, Richknd, Wash., for the U.S. Nuclear Regubtory Cormassion, Warhington. D.C., June.

l 19 NUREG 1569- C-22

-c., - - - - ,.. , , - - , ,y-,,-,- , - - - - , , ,,,y-. - - - - - --

f Hen, CT., et al,1985, 'The Ocrunence of Radioactivity in Public Water Supplies in the United Stues," Health Physics, vol. 48, No. 5, May.

Huruer, J.,1996, " Making a Success of in Situ teactung at the liighland Uranium Project," presented at the annual treeting of the Society for Mining, Metallurgy, and Exploration, Phoenix, A" , March 11 14.

Muenar Associsses, Inc.,1986, Indoor Air Quality Environmental fr{ormation Handbook: Radon, DOE /PE/120132 2, prepared by Mueller Anociates Inc., Baltimore, Md., for U.S. Department of Energy, Washington, D.C NRC: see U.S. Nuclear Regulatory Commission.

Strongs, D.L, and TJ, Bander,1984, MilDOS - A Conputer Program for Calculating Enstronmensal Raiuuhus Dosesfrom Uranium Recovery Operations, NUREGICR 2011, PNL 3167, Pacdc Northwest Laboratory, Richland, Wash , for the U.S. Nucliar Regulatory Conmssion, Washington, D.C U.S. Nuclear Regulatory Conssission,1980, Final Generic Environmental inpact Statement on Urantwn Milling NUREG-0760 Wast'ngton, D.C. Sept.

Yu, C, et nL,1993, Manualfor inplementing Residual Radioactive Material Guidelines Using RESRAD, Wrsion 5.0, ANIJEAD/tD2, Argonne NationalLaboratory, Argonne,11 Sept.

l l Yuan, Y.C, J.H.C Wang, and AJ. Zitten,1989, MilDOS AREA: An Enhanced Version ofMilDOS forlarge. Arm Sources ANL/ES 161, Argonne NarknalLaboratory, Argonne,Ill, June.

i' I

20-C-23 NUREG 1569

l Attachment I:

MILDOS. AREA Data Inpu' File for Sample ISL Site 21 NUREG-1569 C-24

1 l

)

1 l

61HOATA l I TTODO= 2

  • 1, 8
  • 0, IRTYPE=8*0,40*-1, JC=1,0,1,2'0,2*1,0,1,0, l

IRADON=0.86,0.06,0.04,0.04, IPACT=9*0,1, NSORCE 10, PACT = 51.,2*0, 0.21,2'0, 1. 3,2 ' 0, 1.3,2'0, QAJUST= 1,9*0, 1,9*0, 1,9*0, 1,9*0, ' 9*0, 1,9*0, 1,9*0, 1,9*0, 1,9*0, 1, 9

  • 0, 1,9*0, 1,9*0, .,9*0, 1,9*0, 1,9*0, 1,9*0, 1,9*0, 1,9*0, '. 0
  • 1, 10+1, SOROE=

0 . 0, 0.0, 20.0, 0.0,1.46E-1,3*7.3E-4,0,0,1101,1,17.0, 0.0, 0.0, 0.0, 0.0, 4*0.0, 1. 9, 1102, 1, 0.0,

-0.341,-0.092, 0. 0, 0.0, 4*0.0, 153., 1203, 1, 0.0,

-6.629,-0.377, 0.0, 0.0, 4*0.0, 1. 9, 1304, 1, 0.0,

-6.708,-0.595, 0. 0, 0.0, 4*0.0, 64., 1305, 1, 0.0,

-7.0, 1.2, 0. 0, 0.06, 4*0.0, 0.027, 2001, 3, 0.0,

-5.3, -1.3, 0.0, 0.050, 4*0.0, 49.0, 2002, 3, 0.0,

-1.2, C.3, 0.0, 0.055, 4*0.0, 93.0, 2003, 3, 0.0,

-0.23, 0.5, 0.0, 0.10 4

  • 0. 0, 110.0, 2004, 3, 0.0,

-0.776,-1.354, 0.0, 1, 4+1.0, 1.0, 6001, 3, 0.0, FAS= 3*-1.,

SRNS=1.3,1,1, HDP=50.0, FREQ =

.00038, .00011, .00021, .00009, .00018, 2*.00013,

.00006, .00027, 2*.00006, .00009, .00006, .0001,

.00006, .0001, .00021, 2*.00027, 2*.00021, 2*.00007,

.00014, .00041, 2*.00014, .00021, .00014, 0,

.00014, 65*0, .00181, .00115, .0014, .001$8,

.00168, .0006, .00128, .00095, .00361, .00176,

.00008, .00096, .00093, .00058, .00107, .00056,

.00199, .00103, .00151, .00116, .00082, .00062,

.00082, .00123, .00253, .00123, .0011, .00082,

.00158, .00055, .00103, .00089, 2*.00082, 2*.00055,

.00021, .00007, .00034, .00075, .00199, .00041,

,00062, .00041, .00048, .00069, .00055, .00027, 48*0, .00068, .00053, .00067, .00052, .0006,

.00032, .00062, .00074, ,0017*, .00068, .00056,

.00034, .00028, .00029, .00059, .00028, .00329,

.00219, .00206, 2*.00096, .00062, .0011, .00009,

.00514, .00212, .00039, .00075, .00151, .00103, 2*.00009, .00404, .00253, .00233, .00137, .00048,

.00007, .00055, .00201, .01062, .00288, .00103,

.00116, .00411, .00377, .00315, .00185, 2*.00027,

.00034, .00027, 3

  • 0, .00069, .00226, .00014, 2*.00021, .00116, .00158, .00075, .00021, 12*0,

.00007, .00021, .00007, 17*0, .00709, .00308,

.00332, .00296, .0026, .00169, .0022, .00229,

.0073, ,00197, .0051, .00129, .00175. .00136,

.0018, .00166, .04028, .00849, .00692, .00377,

.00233, .00199, .00397, .00514, .02124, .00617,

.00377, .00356, .00466, .00411, .005, .00507,

.02041, .01103, .00527, .0026, .0013, .00103,

.00349, .01048, .05747, .01178, .00432, .00486,

.01671, .0163, .91075, .00692, .00836, .00889,

.0063, .00158, 00027, .00041, .00151, .0007,

.05439, .01212, .00185, .00322, .03213, .05556,

.02466, .00425, .00075, .00062, .00041, ,00007, 0, .00007, 0, .00055, .00459, .00123,

.00014, .00027, .00699, .01932. .00521, .00062, 2

  • 0, ,00007, 5*0, .00044, 2

I 00178, .00384, .00069, .00021, .01075, .00438,

.00503, .0052, .00552, .00354, .00582, .00553,

.J23'1, .00944, .?0799, .00475, .00635, .00556,

.00604, .00493, .01226, .00329, .00356, .00308,

.70145, .00176, .00267, .00521, .0204!, .00856,

.00541, .00527, .00644, .0063, .00562, .00377,

.0061, .00178, 0011, .00048. .00014, 2' 00007,

.00:3, 2016?, .00116, .00096, .00158, .00788,

.00795, .00349, .00151, 144*0, DMM 150, DMA=1550, froR =0.5, FTORP=0.5, THAYl=0.5, THAYP*0.5, FPR=320,1400,230, IPOP =

$72, 266, 401, $15, 221, 3178, 6078, 4842, 7011, 7959, 9705, 9708, 1145, 266, 1603, 1288, 221, 4073, 6789, 9505, 12220, 14591, 15101, 15552, 1145, 1288, 1402, 258, 779, 4073, 6789, 9505. ;2220, 13210, 12551, 14482, 1145, 1431, 1202, 1545, 221, 883, 1472, 3921, 8870, 14092, 15611, 16542, 572, 1431, 2003, 258, 221, 883, 1472, 2060, 2649, 3238, 5900, 8403, 572, 1431, 2003, 773. 221, 883, 1472, 2060, 2649, 3238, 3826, 4415, 572, 143, 21, 26, 221, 883, 1472, 2060, 2707, 3677, 4761, 6404, 916, 215, 21, 26, 221, 883, 1472, 2060, 3296, 4995, $904, 6812, 286, 143, 200, 26, 221, 883, 1472, 2060, 2721, 4995, 5904, 6812, 12, 15, 21, 26, 221, 883, 2068, 3670, 3656, 4995, 5904, 6812, 12, 15, 21, 26, 221, 1360, 3460, 4844, 6143, 63e4, 6368, 6812, 12, 15, 21, 26, 370, 2076, 3460, 4844, 4789, 4665, 4838, 5162, 114, 15, 21, 26, 519, 2076, 3460, 4844, 2809, 3214, 3798, 4382, 114, 15, 21, 26, 519, 2009, 2904, 3677, 4427, 4092, 3798, 4382, 229, 15, 21, 44, 519, 1476, 2348, 3287, 4226, $166, 5841, 6384, 206, 15, 21, 26, 260, 1409, 2348, 3287, 4226, 6121, 7718, 7256, PAJUST-10*1, IADD=8, XRECEP=

0.989, 1.338, 0, 1.467, 0.114, 0, 1.012.-l.269, 0, 0.182,-2.607, 0,

-3.184, 1.269, 0,

-2,274,-0.08, 0,

-4.434,-1.464, 0,

-6.333, 1.978, 0, NSTEP=2,TSTART=1997,TSTEP=10,10,8*0, ACTRAT=2.5, IPSOL-3'3,4*2, PTSZ-1.5,3.0,7.7,54.0.0.3, PTS t rC = 0. 0,1,0, 2

  • 0. 0,1,0, 5

-_ ~

SAMPLE ISL FACILITY GENERIC tiET STATION Yellowaaka Dryer Plant IX- Racon Settlin7 Pond P1 3atellite fac111t','

Settlan; For.3 P2 New Welitteld 1 Prod. Wellfield 2 Frod. We11fteld 3 Rest. Wellfield 4

  • t.igatica flot Pesident 1 Resident 2 Resident 3 Pesident 4 Grating Area 5 P.esident 6 Resident 7 Resident 8 10-Year Action Period 10* Year Restoration 6NWAREA NEX*0, NAS = 3, NNODE = 8, NODE. 8,3,1,2, 7,4,8,3, 6,5,7,4, XS = -0.776E3, -0.547E3, -0.466E3, -0.520E3,

-3.669E3, -0. 8 30E3, -0. 95 2E3, -0. 911E3, YS = -1.354E3, -1,360E3, -1.556E3, -1.772E3,

-1.839E3, -1.825E3, -1.704E3, -1.446E3, 4END I

s 1

j C-27 NUREG 1569 1

Attahn::nt II:

F "ILDOS AREA Output Mie for Sample ISL Site NUREG 1569 C-28

~. v-,~m- o -. -- . -~, - , - - w - - -- m -- , r--------e------t-

eau. lush ##dH te, Ist. D AC3 L377 ColK: CILDOS-AREA qu2/97) '

Ppt,et

  • METSET: CDsERIC "ET STATION - sata: 'sampiel.oet 03/11/97 TA31X. OF CONTDfTS pattnant nc I CAL DATA . . . . . . . . . . . . . . . . . . . . . . . - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 II8DIVIDUAL REC 1PTORS & MI SCELIAssE005 INFUT fATA . . . . . . . . . . . . . . . . . . . . . . . . . . . - 3 poyUIATIDst DI STRIBUTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

" FINITE.E12 MENT DATA FOR SOURCE 6001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 SOURCE PRfUWETERS . . . . . . . . . 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . = . . . . . . . . . . . . . . 6 DOSE CUurvERSIoss FACTORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . T TIpsE STEP 1, 10-Year Action Perio COIICENTRATIOut DATA FOR SPATI AL 1tfTERV ALS . . . . . . . . . . . . . . . . . . . . . . . . . . , , , , - 12 AsseeUAL F0FU1ATIOgl DOSE COP 981TWGDITS, PERSOI6-REM PER YEAR FOPU1ATION DOSE SUpsthatY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 -

INDIVI DUAL RECEPTOR PARTICULATE COFJCEIr MT10 BIS . . . . . . . . . . .. . . . . . . . . . . . . . . 17 y

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a E NUREG 1569 C 34

EEGICet: SAMP11.1*;L FACILITY CCOI: MILC33-AREA (02/97) FAGE 7 METSET: GEME81C MET STATION DATA: 1.aspist.dat 03/14/97 ItattALATION DOSE CONVERSION ' ACTORS, MPEM/YR PER PC1/M3 FOR ACE G4UP OF INFANT AMAO= 1.5 psa U-238 U-234 Th-230 Ra-226 Pty-210 BL-210 Po-21u Er1T.CTiv 3.42E+03 3.85E+0? 4.68E+03 6.49E+02 1.74E+02 4.10E+00 e.svE+02 acne 4.P1E+01 5.41E+01 2.17E+04 5.92E+02 5.47E*02 1.03E-02 2.10E+01 AVG. ! Anac 2.69E+04 3.saCE+04 3.10E+04 4.17E+03 5.07E+01 5.96E+01 3. hE + 01 L1 yen 3.51E-01 3.23E-01 1.1 f.E+ 02 4.422+01 2.83E+03 1.3 E400 2.54E+02 MIDNEY 4.67E+01 5.23E+01 1.21E+01 1.68E+01 1.08E+03 3.48E*01 1. 37E+0 3 AMAD. 3.0 p. U-238 U-234 Th-230 Ra-226 1% 210 8i-210 Pu-210 ETTECTTv 2.0eE+03 2.33E+03 l.05E+03 4.63E+02 1.90E+02 3.25E+00 7.2eE+c2 BONE 3.56E+01 3.95E+01 1.57E+04 6.64E*02 5.94E+02 8.98E-02 2 37E+04 AVG.LONG 1.70E+04 1.94E+04 1.96E+04 2.63E+03 5.51F*01 3.77E+01 2.12E+03 liver 2.4BE-01 2.38E-01 8.41E+01 4.95E+01 3.08E+03 1.6%E*00 2.88E*02 -

K10NEy 3.481+01 3.86E+01 8.73E+00 1.88E*01 1.16t+03 4.13E+01 1. 4 W + 0 5 page. 7.7 um U-238 U-234 Th-230 Ra-226 Pty-210 Bi-210 Po-JIU

_ --------.--...~.------- - ---------- .-~~--------------- --

EFFECT1v 1.11E+03 1.25E+03 1.85E+03 3.08E+02 2.28E+02 2.91E*00 7.61E*02 gong 3.60E+01 4.02E+01 1.18E+04 8.37E+02 7.46E+02 1.27E-01 3.00E+o?

AVG. LUNG 7.50E+03 8.38E+03 8.46E*03 1.14E+03 6.67E*01 1.78E+01 9.1th+02 L1vER 2.30E-01 2.47E-01 7.57E*01 6.37E*01 3.71E*03 2.30E*00 3.52E+0?

O x1ppEy 3.71E+01 4.20E+01 7.71E+00 2.51E+01 1.39E+03 5.34E*01 1.85F*03 ta

-.---.-........'Iv..-

ErfECTIV 2.49E+00 2.74E+00 5.25E+02 1.45E+02 2.17E+02 1.82E+00 4.90E+0e BONE 2.04E*01 2.2SE+G1 6.11E+03 7.79E+02 7.13E*02 1.40F-01 2.ssk+e2 ,

Avt, .1,0NG 0.00E+00 0.00E+00 0.00E+00 0.00E*00 6.38E+01 0.00E+00 0.00E+00 5 LIVER 1.09E-01 1.40E-01 3.92E*01 5.93E+01 3.55E+03 2.53E+00 3.12E+o2 )

KIDNEY 2.10E+01 2.38E+01 3.99E+00 2.34E+01 1.32E*03 4.75E+01 1.64E+u)

AMAD- 0.3 pm U-238 U-234 Th-230 pa-226 Pb-210 Bi-210 b>- 21 s EFFECT1v 6.97E*03 7.81E+03 9.06E+03 1.18E+03 1.75E+02 6.52E*00 1. WE +tr l '

pone s.37E+01 9.35E*01 4.21E*04 5.42E+02 5.39E+02 4.04E-02 1.7SE*U2 AVG. LUNG 5.84E+04 6.67E+04 6.73E+04 9.03E+03 5.00E*01 1.21E+02 7.29E+0) liver 6.15E-01 5.35E-01 2.06E+02 3.64E+01 2.80E+03 7.62E-01 1.98t+02 r KloNEY 7.63E+01 8.55E+01 2.12E+01 1.43E+01 1.09E+03 2.51E+01 1.10E*Cl  ;

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CODE: CIL105- ARFA (02/973 FAGF. $

RECIGe8: As*F11 I5L f ACILITY sEET!dT: GE W IC MET STATION CATA: sampisi.dat 03/14/97 t 130HA1ATION DOSE C0wvtRSION FACTORS. MBEM/YR PER PC1/M3, FOR AGE Gm0U1' 04" TEENACE pose @= 1.5 ssen U-238 U-234 n-230 R4-226 Pb-210 86-210 Pu-210 EFFECT1** 8.55E+02 9.62E*02 1.77E+03 9.20E+61 9.06E+01 2.13E+00 9.3eE*01 -

t sone 4.15E+01 4.63E+01 1.97E+04 7.02E+02 9.58E+02 1.23'.-01 1.4st+05 AVG.IbMG 6.88E+03 7.69E+03 7.7 6E+03 5.21E+02 9.51E*00 1.12E*01 4.20E+02 EgvER 8.43E-02 7.30E-02 3.16E+01 5.30E+00 5.07E+02 2.37E-01 2.73E+01 -

4 RIDuSEY 1.17E+01 1.312+01 4.2SE+00 5.89E+00 2.39E+02 7.74E+00 1.dE+b2 apino. 3.0 pen U-238 s U-234 n-230 Ra-226 Pb-210 si-280 Pv.210 ,

EFFECT1v 5.20E+02 5.83E+02 1.16E+03 6.56E+01 9.87t+01 1.69E*" 7.74E+01 ,

, goest 3.06E+01 3.41E+01 1.43E+04 7.87E+02 1.04E+03 1.57E ,1 1. ME

  • 481 L 4 AVG.1MeeG 4.34E+03 4.85E+03 4.90E+03 3.29E+02 1.0 3E+01 7.06E+00 2.65E+02  !

ErvEm 5.95E-02 5.38E-02 2.72E+01 5.94E+00 5.51E+02 3.03E.01 3.08E+01 l

. K1DesEY 8.61E+00 9.64E+00 3.10E+00 6.60E+00 2.58E+02 9.18E+00 1.87E+02 r l

anno. 7.7 pse U-238 U-234 n-230 Ra-226 Ptr-210 81-210 Po-210 '

_, . _ - - . - _ - = - - .-... .. ..........-

I

! EFFECT1v 2.78E*02  ?.12E+02 6.62E+02 5.88E+01 1.10E+02- 1.40E+00 7.18r+01 nowE 2.47E+01 2.77E+01 9.08E*03 9.49E+02 1.22E+03 2.08E-01 2.0 E+01 1.87E+03 2.09E+03 2.11E+03 1.42E+02 1.24E+01 3.30E+00 1.15E+02 AVG.InwG ' 3.75E*01 g ElvtR 3.89E-02 3.86E-02 1.73E+01 7.11E+00 6.61E*02 4.10E-01 g KIDesEY . 6.18t+00 6.92E*00 1.97E+00 8.61E+00 3.07t+02 1.18t+01 2.27E*02 ,

]

J M f mMpm.54.0 pm U-238 U-234 n-230 Ra-226 Pb-210 31-210 Po-210 ,

--- --................a .

.Erft.CT!v 6.22E-01 6.85E-01 1.88E+02 2.76E+01 1.04E+02 8.77E-01 4.70E*01 ,

ecest 1.40E+01 1.57E+01 4.70E*03 8.83E+t2 1.17E+03 2.29E-01 1.80E+01 0.0CE+00 0.00E+00 0.00E+00 0.00E+00 1.18E+01 0.00E+00 0.00E+00, AvC.LUesG LIVER 1.83E-02 2.19E-02 8.98E+00 6.62E+00 6.32E+02 4.50E-01 3.33E+01 ,

x10esEY - 3.50E+00 3.92E+00 1.02E+00 8.02E+00 2.91E+02 1.0 =,E + 01 2.02E*02  !

apepe. 0.3 pin U-238 U-234 n-230 Ra-226 Ptr-210 31-210 Po-21u

= -- . -- - ... ....... -

EFFECTIV 1.74E+03 1.95E+03 3.44E+G3 1.58E+02 8.76E*01 3.26E*00 1.4WL+G2 g0est 7.49E+01 8.37E+01 3.83E+04 6.46t+02 1.01E+03 1.54E-02 1.27E+ct AVG.LtMcG 1.49E+04 1.67E+04 1.68E+04 1.13E+03 9.99E+00 2.42E*01 9. lie *u2 E3vER 1.54E-01 1.2SE-01 6.64E+01 4.16E+00 5.33E+02 1.45E-01 2.48E+01 j RIre;EY 2.0$E+01 2.29E+01 7.56E+00 4.76E+00 2.56E*02 5.91E+00 1.50E+02  ;

I i  ;

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REGIOf83.3/etP1.E ISL FACILITY . COME: MI14US-APEA 402/94 PAGE- 10 PETSETi CE3sERIC MEr STATION ' DATA: saa s1.dat 03/14/97 2

.C 1 .' N LlanAt.ation Dose CasvERStow rACTnes, nREn/vR PER PCr/n), rom ace cRocP or Acol.T m

    • As44D.1.5 la U-239 U-234- Th-230 .Ra-226 Pb-210 .as-210 tw-2to,

'EFFECTIV- 7.13E+02 _ _........ .........

'* 8.02E602 1.61E+03 5.41E+01 sowE. 2.30E+01 2.57E+C1 6.97E+01 1.64E+00 5.87E*01 1.97E+04 2.19E+02 5.64E+02 AVG.1sts 5.73E+C3 6.41E+03 6.47E+03 7.24E-02 '5.d2E*ec LIVER 3.47E+02 7.92E*00 9.32E+00 2.sut+02

'7.03E-02 6.09E-02 3.42E+01 2.94E+00 Rroesty . 9.73E*00 1.09E+01 4.23E*02 1.97E-01 1.82E*dt 3.99E+00 2.94E+00. I 99:"+02 6'45E+00

. 1.1cE*02 anAp. 3.0 pm. U-239 U-234 Th-230 Ra-226- It-210 sh-210

. . . . _ . _ . _ - - - - -~ Iv 210 LTTECTIV 4.34E+02 4.85E+02 1.05E+03 sowE-3.96E+01 1.59E+01 1.30E+00 1.70E+01 1.90E+01 1.43E+04 2.46E+02

4. 8 4 E+ 01 -

AVG.IJJteG 3.62E+03 4.05E+03 6.12E*02 9.26E-02 6.5eE*00 4.09E+03 2.19E+02 0.61E+00 5.99E+00 LivtR '

4.96E-02 4.4eE-02 2.47E+01 1.77E+02 3.30E*00 4.59E+02 2.52E-01 2.05E+01 RIDesEY 7.17E+00 8.03E+00 2.81E+00 J.30E+00 2.15E+02- 7.65E+00 4.25t*02 AMAp. 7.7 pm U-238 U-234 Th-230 Ra-226 Pt>-210 81-210 tv- 2 W

'EFitCTIV. 2.32E+02 2.60E*02 6.62E+02 2.80E+01' BONE 1.12E+01 8.45E+01 1.osE*00 4.23 ten

  • 1.26E+01 9.0SE+03 2.79E+02 4.79E+02 avg.1Anac 1.56E+03 1."P S E + 03 1.76E+03 1.16E-01 7.51L+0w 9.46E+01 9.53E+00 2.54E+00

~O LIVER 2.99E-02 2.97E-02 1.5BE+01 3.14E+00 Ta36*ul G KIDNEY ' 4.75E+00 5.00E+02 3.16E-01 2.84L*01 on 5.32E+00 1.79E+00 3.74E+00 2.36E+02 9.04E+09 1.421*tte ApeAp.54.0 po : 0-238 U-2 '4 4 Th-230 Ra-226 Pb-210 - In .19 P. N EFFECTIV 5.18E-01 5.71E-01 1.88E*02 1. 31 F.+ 01 6.03E*01 6.75E-0!

BONE 6.37E+00 7.12E+00 4.70E+03 2.60E+02 2.70 4 AVG.LipsG 0.00E*00 0.00E+00 6.49E+02. 1.27E-01  % 6t t +vu-0.00E+00 0.0CE+C0 9.11E+00 0.00E*00 1

LIVER 1.41E-02 1.68E-02 8.16E+00 *.9uE*ec 1

3. 4 9E+00 4.96E+02 3.46E-01 1-Etouty 2.6*E+00 3.01E+00 9.29E-01 3.49E*00 . . Wt* 3 t

! 2.24C+02 si.05E*00 f. -+.e . t

AMAo. 0.3 pm U-239 U-234 Th-230 Ra-226 k 210 81-210

_____.._-__--- - = - - - - - - - - - -- -- -

5 -ets l

EFFECTIV __.........n.........

1.45E+03 1.63E+0? 3.12E+03 9.86E+01 sone, 4.41E+01 4.92E*01 7.30E+01 2.72E+00 7 13L 03-3.83E+04 2.09E*02 5.92E+02 Av61mNG 1.24E+04 1.39E*04 1.40E+04 4.44E-02  % 2 W ow l LIVER 7.53E+02 9.33E+00 2.02E+08 6.9 f E + u 1.40E-01 1.16E-01 6.64E+01 2.90E+00

- KIDNEY 1.96E*01 2.09E+01 4.44E+02 1.21E-01 1.65E+vi

, 7.56E+00 2.80E*00 2.13E*02 4.93E+GO 1.out+o

( EXTERNAL Int 01.E BODY DOSE CE*8 VERSION FA,h.

U-238 Th-230 Ra-226 Pb-210

.._ . ..._... . ..___~._.-_. - - =.- - - -

lui-222 Po-218 Ph-214 h -/14 I

CPOUMD, NR/YR itR PCI/M2 3.70E-06 6.12E-07 - . .. ...._.................-... ......

9.47E-07 2.27E-06 5.03E-08 1.10E-08 CLOUD, MR/YR PER PCI/M3 1.23E-04 3.59E-06 3.16E-O*. I.e5E-04 4.90t-05 1.43E-05 2.83E 06 ~ 6.34E-07 1.67E-9)

WORKING LEVEL CONCENTP4710N FACTORS,18L PER PC1/n3 ........

3 .1 s E . U.*

........ ........ 1.03E-06 S.G7E-06 3.79E-Ob I

l

. . _ .- ,, , - , m, ,- . -- - . . .-._ - -- , , ~ . . . . - _ . , . - - - _ _ _ . _ _ . _ _ _ __ _ ____ _

ETAl us4; SAMPLE ISL FAC1LsTY COOO MILEOS-EREA 102/975 FACE 11 METSET: GElfr*1C MET STATaON DAT A: Sampis1.dat 03/14/97 IrsGESTION DOSE CONVERSION FACTOp$, MPEM FER PCI INCE.STED ACE GROUP TISSUE U-239 U. 4 Th-234 Th-230 R4-226 P+O-210 3a-210 Po-219


_--_---------------------.----~~--- -

INFANT EFE CTIV 1.61E-02 1.79E-02 8.57E-04 2.51E-02 2.11E-02 3.11 E-02 3.8et-05 7.95E-92 INFANT BONE 4 . 4 'E-02 5.43E-42 9.24E-07 4.39E-02 1.09E-01 1.8tt 'll 4.00E-07 3.29E-02 1

INFANT liver 2.72E-04 3.15E-04 4.93E-07 3.74E-03 8.48E-C3 3.62E-01 7.52E-06 4.4WE-02 INFANT KIDNEY 4.93E-02 5.71E-02 4.3BE-07 3.53E-04 3.32E-03 1.35E-01 2.86E-04 L 23E-01

--- ---- -.---.-- ----- --- ------=

CHILD EFECTIV 9.95E-04 1.14E-03 5.30E-05 1.53E-43 2.3?E-03 8.67E-03 1.09E-b5 9.12F-03 CHILD emE 4.86E-03 5.43E-03 1.00E-07 3.32E-03 2.50E-02 7.86E-02 2.53E-01 t.076-U3 CHILD LIVER 3.74E-05 4.2CE-05 6.78E-08 1.45E-04 1.32E-03 8.81E-02 1.83E-et e.eet-03 CHILD F10NEf 6.01E-03 6.75E-01 5.34E-08 1.54E-05 6.44E-04 3.54E.02 7.asE-05 3.44E-02

-_--._--_--.-----------------~-- - - - - - - - - - - - - ~ ~ - - - - - - - - - - - - - - - - - - - --------------... . ..--- --

TEENAGE EFFECTIV 7.90E-04 8.80E-04 4. JE-05 1.20E-03 4.22E-03 1.12E-02 1.40E-05 4. 85E - 0 3 TEENAGE BONE 1.83E-02 2.0$E-02 3.87E-07 3.32E-03 1.C9E-01 2.35E-01 1.51E-03 1 et-0)

TEENAf'E LIVER 2.13E-05 2.3?E-05 3.wSE-08 5.94E-05 8.14E-04 4.75E-02 9.8FE-07 3.4eE-03 TEENAGE RIDNEY 3.8$E-03 4.33E-03 3.43E-08 6.80E-06 1.02E-03 2.18E-02 4.62E-05 f.utE.-92

--__------_--~-----------------------------~~----------------- --- -.-- _.-------------.-------

ADULT EFFECTIV 2.55E-04 2.84E-04 1.36E-05 5.46E-04 1.32E-03 5.10E-03 6.36E-06 1. 44 E 4 )

ADU1.T BONE 3.74E-03 4.18E-03 7.70E-08 1.33E-03 2.53E-02 8.10E-02 2.61r-07 4.IJE44 ADULT LIVER 8.51E-06 9.55E-06 1.54E-C8 2.20E-05 3.39E-04 2.26E-02 4.7"E-07 . 1. 60E-0 3 ADUI.T KIDNEY 1.54E-03 1.73E-0i 1.37E-08 2.52E-06 3.39E-04 1.04E-02 2.20E-05 9 . 2 %E - D )

ENVIRONMENTAL CONCENTRATION FACTORS CONCENTRATION FACTOR FOOD TYPE U-238 Th-230 Ra-226 Pb-210 g* SIV, DIMENS*0NIESS ED. AM. 2.50E-03 4.20E-03 1.40E-02 4.00E-03 B1V, DIMENSIONLESS POTATO 2.50E-03 4.20E 03 3.00E-03 4.00E-04 c BIV, DIMENSIONLESS BE!.DW G. 2.50E-03 4.20E-03 1.40E-02 4.0CE-o n 1:1V, DIMENSION 1133 TVRAGE 2.50E-03 4.20E-03 1.80E-02 2.40E-02 BIV, DIMENSIONLESS ST. FEED 2.50E-03 4.20E-03 8.20E-02 3.%E-02 FBI, PCI/ItG PER PCI/ DAY MEAT 3.4CE-04 2.0cE-04 5.10E-04 7 *0t 04 fMI, PCI/L PER PCI/CAf MI1JC 6.10E-04  %.GoE-06 5.90E-04 a.zoE-04 FR?.CTION IN ED PORTION ED.ABG. 1.00E+00 1.00E+00 1.00E+00 1.00E*00 FRACTION IN ED PORTION POTATO 1.00E-01 1.00E-01 1.00E-01 1.00E-01 FRACTION IN ED PORTION BELOW G. 1.00E-01 1.00E-01 1.00E-01 1 00E-01 FRACTION IN ED PORTIC:' FORACE 1.00E+00 1.00E+00 1.00E+00 1.00E+00 FRACTION IN ED PORTION ST. FEED 1.00E*GO 1.00E+00 1.00E*00 1.00E*00 TIME STEP DEPENDENT VARIABLES NO. TIME STEP NAME FAJUST CTACT GFACT GFACT GFACT TFACT TFACT TFACT TFAr7 U-238 Th-230 Ra-226 Pb-210 U-238 Th-230 Da-226 f%-210 1 10-Year Act on Perio 1.000E+00 2.947E+0d 2.947E+08 2.941EIO4 2.542E+08 1.624E+C0 1.624E*00 1.624E+00 1.620E-DV 2 10-Year Restoration 1.000E+00 2.947E+08 2.947E+0B 2.941E+08 2.542E+08 1.624E+00 1.624E+00 1.624 +09 1. 420E

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TIME STEP NuneER 1, 10-Year Actios Peric. CURA 11oM IN TRs 13... 10.0 . ,

CONCENTRATION DATA IVR THE E DIRECTION, THETA EQUALS $4.0 DEGREES' TOTAL AIR CONCENTRATIONS, PCI/M3, AMD NL XRHO, EM U-23d Th-230 Ra-226 Pb-210 - Rn-222 Po-218 Pb-214 Bi-214 tb-210- WL 1,5 4.257E-03 .2.128E-05 2.133E-05 4.128E-05 8.309E+00 7.386E+00 3.171E+0c 1.625E+00 ~2.639E-06 2. 6 8'l-o'.

2,5 2.266E-03 14133E-05 1.1'7E-05 1.134E-05 4.365E*00 4.125E+00 2.190E+00 1.398E+00 3.325E-06 J.v56L-v5 3,5 1. 4 00t>0 3 . 7.000E-06 7.062E-06 7.044E-06 2.829E+00 2.748E+00 1.652E+00 1.175E*00 3. 811E-% 1.559E-05 4.5 9.516E-04 4.154E-06 4.843E-06 4.bJ0E-06 2.032E+06 2.001E+00 1.300E+00 19.862E-01 4.123E-06 1.237E-05 7.5 4.085E-04 2.03*E-06 2.116E-06 2.111E-06 1.025E+00 7.768E-01 6.288E-01 4.484E-06 7.J40E-fis 1.166E-04 5.816E-07 6.169E-07 6.154E-07 ; 1.020E+00 3.985E-01 3.987E-01 3.527E-01 3.084E-01 4.297E-06 3.349E-06 15.0 25.0 4.356E-05 2.171E-07 2.334E-01 2.328E-07 1.948F-01 1.949E-01 1.856E-01 1,729E-01 3.864E-06 1.787E-Oo ,

35.0 2.259E-05 1.125E-01 1.220E-07 1.217E-07 1.212Ewl 1.213E-01 1.198E-01 1.144E-01 ~3.535E-06 1.154E-06.  ;

45.0 1.383E-05 6.891E-08 7.514E-08 7.495E-08 8.461E-02 9.466E-02 8.397E-C2

. 3.274E-06 d 201E-07 55.0 9.352E-06 4.657E-08 5.110E-08 5.057E-08 6.336E-02 6.339E-02 6.326E-02 6.265E-02 3.064E-06 O l%7E-07 65.0 6.142E-06 3.357E-08 3.696E-08 3.686E-08 4.960E-02 (,963E-02 4.968E-02 4.947E-02 2.s96E-06 4.8 75E -

75.0 5.088E-06 2.533E-08 2.797E-08 2.190E-08 t.010E-02 4.012E-02 .C.023E-02 4.019E-02 2.733E-06 3.952E-07~

GROUND SUFFACE CONCENTRATIONS, PCI/M2 XpHO. . EM U-238 Th-230 Ra-226 Pb-210 Rn-222 Po-218 Pb-214 81-214 Pt>-lld

. . . . . . . _ _ _ _ _ - _ . - - - ...- - == =.. . .--

1.5 1.737E+03 3.867E+01 3.892E+01 3.892E*01 0.000E+00 4.477E+01 4.477E*01 4.477E*01 2.013E**0 2.5 4.121E+03 2.059E*01 2.081Et61 2.081E+01 0.000E+00 2.407E+01 2.407E601 2.407E+01 2.55tE*oV 3.5 2.556E+03 1.276E+J1 1.317E+01 1.317E*01 0.000E+00 1.535E+01 1.535E+0) 1.535E+01 2.906E 00 4.5 1.748E+03 8.114E+00 9.302E+00 9.302E+00 0.000E+00 1.089E+01 1.08 9E+0. 1.089E+01 3.144E+00 0 1.5 1.577E+02 3.7 68E+00 4.248E+00 4.24BE+00 0.000E+00 5.060E+00. 5.060E+00' 5.060E+0 3.419E*00 b

~ 15.0 2.177E+02 1.080E*00 1.272E+00 1.272E+00 0.000E+00 1 588E+00 1.588E+00 1. 58 9t + 0s 3.277E+60 25.0 8.127E+01 4.031E-01 4.790E-01 4.790E-01' O.000E+00 f.'34E-01 6.331E-01 6.334E -2.947E+00. l 35.0 4.205E+01 2.086E-01 2.47!E-01 2 479E-01 0.000E+00 3.439E-01 3.439E-01 3.439E-01 2.696E+00-45.0 2.569E+01 1.275E-01 1.511E-01' 1.511E-01 0.000E+00 2.181E-01 2.191E-01 -2.181E-01 2.497E:00 55.0 1.734E+01 9.605E-02 1.020E-01 1.020E-01 0.000E+00 522E-01' 1.522E-01 1.522E-01 2.337E*C0 65.0 1.248E+01 6.192E-02 7.309E-02 7.309E-02 0.000E+00 1.124E-01 1.124E-01 1.124E-01 2.201E*00 15.0 9.399E+0G 4.665E-02 5.487E-o2 5.487E-02 0.000E*00 8.664E-02 8.664E-02 8.664E-02 2.084E+00.

TOTAL DEPOSITION kATES, PCI/M2-SEC XRHO, FM U-238 .Th-230 Ra-226 Pb-210 1.5 4.263E 05 2.131E-07 2.149E-07 2.223E-07 2.5 2.271E-05 1.135E-37 1.149E-07 1.246E-07 i 3.5 1.409E-05 1.034E-08 7.273E-06 8.390E-08 4.5 9.631E-06' 4.802E-08 5.137E-08 6.361E-08 7.5 4.175E-06 2.076E-08 2.346E-Ou 3.685E-08 L 15.0 1.200E-06 5.954E-09 7.023E-09 1.990E-08 25.0 4.478E-07 2.222E-09 2.645E-09 1.423E-08 35.0 2.317E-07 1.149E-09 1.369E-09 1.197E-08 -a i

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METSET6 CE**"IC MET STATION . DATA: Gampis1.dat' . 03/14/97 TIME' STEP NUMBER 1, 10-Year ac tion Perio DURATION IN YRS 13.. 10.0 T1 CvHCENTRATION ATA FOR THE N DIRECTION, THETA EQUALS 270.0 DECMEES 4

'- . TOTAL' AIR CONCENTRATIONS, PC1/M3, AFD WL .

lXRHO[RM U-238 Th-230 Ra-226 '?b-210 Rn-222 Po-218, Pb-214 81-214 .Pb-210 WL

..... .. -- .--....----....--.- - ~ ------.... ..------ --- - ---- --- -- - - - -

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1.5 1.501E-03 "1.495E-06 7.806E-06 7.786E-06 2.339t+01 2.257E*01 5.583E+00 .1.116E+00 1.647E-Oe' 5.snE-05L 2.5 9.0R9E-0 4 - 4.543E 06 4.570E-36 't.558E-06' 5.684E+00 S.5T2I+44 3.204E+00 1.143E+00 2.343E-Ota ' i nt e t'E- 05 3.5 5.762E-04 ~2.881E 2.889E-Ot 2.882E-06 3.617E+00 3.572E*00 . a . 4*.** + 00 't.630E+00 2.918E ut,- 2.21PE-0) 4.5- 3.890E-04 1.945E-06 1.949E-06 1.944E-06 3.913E*00 3.77BE+00 2.326E+00 2.+=0$E+00 3.22 3EiO6 J.13eE 1.5 1. 562 E-tie .7.810E-07 7.822E-07 7.802E-07 3.520E+00~ 3.365E+00 1.656E+00 9.386E-C* L605E-Oo 1.536E-05 '

15.0 3.621E-05'. 1.810E-07 1.813E-07 1 e0BC-Of 3.32CE 3.329E-01 <3.254E-01' 3.154F-01 4.* 10E 1.1*9E-06 25.0 1.052E-05 :5.261E-08 5.270E-08 5.256E-0 1.356E-01 1.357E-01 1.355E-01 1.347E-01 3. 635E-6 : fl.329E-os-35.0 4.541E-06 2.273E-00 2.218E-06 2.272E-Ot 7.849E-02 7.854E-02 7.879E-02 1.884E-02; '

3.2 4 9E-06 ' t 344E-07 i-- 45.0 2.488E-06 1.244E-08 1.247E-08 1.244E-06 5.273E-02 5.276E-02 5.299E-02 5.312E-02! 2. 966E- 06 5.21/E-07

} 55.0 1.518E-06 7.888E-09 7.907E-09 7.887E-09 3.848E-02 3.850E-02 3.868E-02 3.88CE-02 2.748E-06 3.bo5E-07 4

65.0 1.101E-06 5.503E-09 5.516E-09 5.502E-09 2.952E-02 2.954E-02 2.968E-02' 2.978E 2.569E-06 2.920E-07 75.C 8.152E-01 '4.016E-09 4.086E-09 4.016E-09 2.347E-02 2.349E-02 2.360E-02 2.368E-02 2.418E-06 2.322E-07 CROUND SURFACE CONCENTRATIONS, PC1/M2 NRHO, FM .U-238 Th-230 Ra-226 Pb-210 Rn-222 Po-218 Pb-214 Bi-214 . fW '10 j; ... ........ ......----= - ---

1.5 2.805E*03 1.393E+01 1.616E+01 1.616E+01 0.000E+00 3.404E+01 3.404E+01 3.404E+01 1. 2 %E + 04 2.5 1.655E+03 8.270E+00 9.427E+n0 8.427E*00 0.000E+00 1.284E+01 1.284E+01 1.284E+01 1.197E*0u 3.5 1.048E+03 5.235E+00 5.281E+00 5.281E*00 0.000E+00 9.110E+00 8.110E*00 8.110E*00 . 2.226E*ou

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) 25.0 1.910E+01 7.550E-02 9.560E-02 9.%60E-02 0.000E+00 2.031r-01 2.031E-01 2.031E-01 z! 772E* m 35.0 8.255E+00 4.12 n-02 4.132E-02 4.132E-02 0.000E+00  ?.035E-01 1.035E-01 1.03tE 2.477E+0p j 45.0 4.517E+00 2.258E-02 2.261E-02 2.261E-02 0.000E+00 6.440E-02 6.440E-02 6.440E-02 2.?62E*Oo 55.0 2.864E*00 1.432E-02 3.434E-02 1.434E-02 0.000E+00 4.483E-02 4.483E-02 4.483E-04 2.096E+00:

65.0- 1.998E+00 9.987E-03 5.004E-02 1.000E-02 0.000E+00 3.340E-02 3.340E-02 3.340E-02 1.959E+00-15.0 1.480E*00 7.391E-03 1.401E-03 1.407E-03 0.000E+00 2.601E-02 2.601E-02 2.601E-02 12844E UOJ s

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EEGION: SAMP11 ISL FACILITY CODE: H11 IDS-AREA (02/07) PAGE 19 METSET: CENERIC MF" STATION DATA: ses .sl.dat 03/14/97 TIME STEP NUwSER ., i.e-Year Action Perto 00' ATION '1M 1RS 15. . . 10.0 2

INDIVIDUAL RECEPTOR KADON AND RADON DAUCHTER CONCENTRAT10!!S AIRBORNE CONCENTRATIfWS, PC1/M3 CM)UNO CONCENTRATION $. 4%*I / M1~

No Pn-222 Po-218 tb-214 B1-214 rb-210 B1-210 Po-210 WL Po-218 Pb-2*4 84-214 W-llO "

o ___ _________.-_____ _.--.---- -

/

1 6. 58 9E *00 6. 37M+00 3.415E +00 1.77 9E+00 2.628E-06 7.112E-09 9.661E-13 3.052E-05 5.047E+00 5.047E+00 5.04 7r.00 J.tru4E *ow 2 8.187E+00 7.286E+00 3.137E*00 1.595E+00 2.569E-06 8.451E-09 1.142E-12 2.937E-05 5.771E+00 5.771E+00 5.771L*00 1.**%9E*cw b 3 6.889E+00 6.294E*00 2 379E+00 1.595E400 2.684E-06 8.414E-09 '1.041E-12 2.754E-05 4.985E+00 4. 985E*00 4.985E+00 2.041E*uG 4 5.437E*00 5.294E+00 3.139E+00 1.98DE+00 3.949E-06 1.069E-08 9.973E-13 *.875E-05 4.193E+00 4.193E*00 4.193E 00 J.O!!E+00 5 2.731E+00 2.712E+00 1.920E+00 1.315E+00 2.520E-06 5.462E-09 3.347E-13 1.7 47E-05 2.148E*00 2.14eE+00 2.148E*00 1.922E+00 6 7.579E+00 7.326E*00 3.755E+00 1.853E+00 2.271E-O' 4.011E-09 2.411E-13 3.349E-05 5.002E+00 5'.902E+00 5.802E+00 1.732E*00 7 6.152E+00 5.504E+00 2.335E+00 1. 367E+00 3.204E-0 9.216E-09 7.482E-13 2.261E-05 4.350E+00 4. 360E+00 4. 360D00 2. 441E+00 8 3.601E+C0 3.5cf E+00 2.233E+00 1.539E+00 4.11"E-06 1.466E-08 1.600E-12 2.067E-05 2.177E+00 2.777E+00 2.777E+00 3.138E+00 k

Ltc10:4 - 3 AMP 1.E ISL FACILITY COC7.- CILDOS-AREA (02/97) PAGE 19

_ . METSET: CE' 'IC MET STATION DATA: 'sampici.dat 03/14/91 TIME STEP NUMBER 1, .10-Yur Action Pori. tupATION 13 YRS IS. . 10.0

. HUMBER 1 NAME= Resident 1 h= 1. F"'M, Y= 1.3EM, Z= 0.0M, c:ST= 1.7 m , IRTTPE= 0 FESULTS CF ALC CHECK AT THIS LOCATION

.......-.-..-....-.....----.-.--.---- - - - - - - - - . . . - . - . . ~ ~ - - - - . - - - -

__.........--............--2.

U-239 U-234 Th-230 Ra-226 Rn-222fvt) Fb-210 Bi-210 Po-210

. . . . . . . . . - - . ~ . . . . . . . . - - - . - ~ . . . - = - - - - - . - - - - - - - . . ~ - - - - ~ . - - -

CONC., PCI/M3 2.50E 03 2.50E-03 1.25E-05 1.26E-05 3.05E-05 1.52E-05 1.25E-05 1. 2 *>E- 0 5 AIL PCI/M3 6.00E-02 5.00E-02 3.00E-02 9.00E.01 1.10E-03 6.00E-01 4.00E+01 9.00E-01 FRACTION OF A1.C 4.16E-02 4.99E-02 4.16E-04 1.4CE-05 2.77E-02 2.53E-05 3.14E-07 1.3*E-05

............ ..------.~ ..-.--.----. ..-- -

SUM OF FRACTIONS EQUALS 1.20E-01 NUMBER 2 NAME= Resident 2 X= 1.52, Y= 0.12, Z= 0.0M, DIST= 1.5m, I'RTTPE= 0 RESULTS OF Alf CHECK AT THIS LOCATION

.......---.-..... ... ~.----...-.-- -

U.238 U-234 Th.230 Ra-226 Rrs.222 (WL) Ph.210 Bi-210 Po-210

. _._ ....... ---..-...~ --..--------

- - - ....--- .......-.- -..--...----- --- ...-- - .~-----..-----. .........

CONC., PC1/M3 3.84E-03 3.84E-03 1.92E.05 1.92E-05 2.94E-05 2.18E-05 1.92E-05 1 M2E-05 g AIC, PC1/M3 6.0CE-02 5.00E.02 3.00E-02 9.00E-01 1.10E-03 6.00E-01 4.00E*01 9.00E-ol h rpACTION OF ALC 6.40E-02 7.f8E-02 6.40E-04 2.14E-05 2.67E-02 3.63E-05 4.80F-07 2.13E 05

-...---..-----... -... ........-......=-- - ....--.--....-- _....--- = . - - - - - . . - . - . . . - . . . . . - - - . . . - - -

SUM OF FRACTIONS EQUALS 1.68E-01 Z

C b

O, W

D CB C

i

.REGIow: SAptP11 'ISL' FACIL1TV C00Ci CIIAOS-APEA (01/9'*3 PAGE .23  :-I pee

  • SET: GENERIC MET STATION DATA: sampiel. cat . .

03/14/97 i TIME, STEP WUMBER 1, 10-Year Action Perio -DURATIOle IN YRS 35..c 10.0- ,

NUpqSER 3.-stAME= Resident 3 X=- ' 1. Olet, Ya -1.31Gt, Z= 0.04, DIST= 1.68e0."1RT7PE= 0~

w RESULTS OF Alf CHECK AT TR13 ".DCATICIS i

. O, _ _______ _- --

[

.  : U-238 U-234 Th-230 Ra-226' Rn-2"2 (trL) Pb-210 .81-210 Po-210 'I t' .. _ ....__ _ -.--- - --

Cosec., PCI/M3 2.83E-03 1.41E-05

, 2.83E-03 1.54E-05 2.75E-05 1.80E-05 1.53E-05. :1.53E-05 e ALC, PC1/M3 6.00E-02 5.00E-C2 3.00E-02 S.00E-01 1.10E-03 6.00E-01 4.00E+bt 9[0CE-01 FRACT1088 OF ALC 4.71E 5.65E-02 4.69E-04 1.71E-05 2.50E-02 3.00E-05 3. 8 3E-0 7 ' . 1.70E-05'

__.------ -- -_= -

SUM or FRACTIONS EQUALS 1.29E -*

j ' NUMBER 4 NAME=Pesident 4 X* 0 .2106, Y= -2.6MM, Z= 0.0M, DIST= 2. 64G4, ' IRTYPE= 0 3- RESULTS Or AIR CHECK AT THIS LOCAT10e4

, __ ...................---------- - =--- - - - --


.----~-

U-238 U-234' Th-230 Ra-226 Rn-222 (WL) -Pb-210 81-210- t o-21U ' '

......__ __._-.__~_.--= - - - - - - - ~ ~ - - - - - - ----

(") Coe5C., PCI/M3 3.01E-03 3.01E-03 1.49E-05 1.73E-05 2.87E-05 2.12E-05 't.73E-05 '1.12E M .

00 Air, PCI /M) ' 6.00E-02 5.00E-02 3.COE-02 9.00E-01 .1.1CE-03 6.00E-01 4.00E+01- 9.001-01 '[

FRACTI0rt OF Atc' *s . 01 E-02 6.02E-02 4.98E-04 1.92E-05 '2.61E-02 3.53E 4.31E-o' l'.92E-u , -i

=- -------------------------

SUM Or FRACTIONS EQUALS 1.37E-01

-)

I i i p

4 4

-i

(

,w ave.: se raz ass,encta.str' 'DDE: CILDOS-AREA (D2/97) PAE 21 METSET: CEN'41C MET STAYION' .3AT3: sampi&1.clat .

@3/14/97 TIME STEP WUMBER 1, 13. Year Action Peri DURAs 10N l'.3 TRS IS. . . 10.9 MusqeER L5 suweE= Grazing Area 5 X= -3.21st, Y. 1.3m , la 0.0M, DIST= 3.4pse, IRTYPE= 0 RESULTS OF ALC CHECK AT TMIS LOCATI0tt U-239- U-234 Tta-230 Ra-226 An-222(WL1 Pts-210 81-210. Po-21u 00sec., pct /M3 3.93E-04 3.93E-04 1.96E-06 1.99E-06 '1.75E-05 4.50E-06 1.99E-06 1.98E-06 A12. PCI/M3- 6.00E-02 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.007:-01 4.00E+01~ 9.00E-01 51ACT1088 OF Air 6.55E-03 7.86E-03 6.55E-05 2.21E-06 1.59E-02 7.50E-06 4.97E-00 2.20E-06 "

-- . __- ==-.............

Supt OF e M IOt43 EQUALS 3.04E-02 NUMBER 6 MAME= Resident 6 X- -2.3Rpt, Y= -0.110t, 1= 0.0M, DIST= 2.3RM, IRTYPE= 0 RESULTS OF Air CHECK AT THIS IECATICII U-238 U-234 Th-230 Ra-226 Rn-222(WL) - Ptr-210 BL-210 Po-210 CostC. , PCI/M3 9.90E-04 9.90E-04 4.95E-06 4.99E-06 3.35E-05 7.25E-C6 4.90E-06 4.97E 06 Air, PCI/M3 6.00E-02 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.00E-05 4.00E+01 9.00E-01 O

M f1ACTIces OF ALC 1.65E-02 1.9rt-02 1.65E-04 5.54E-06 3.*nt-02 1.21'.-95 '1.24E-07 5.53E-06 .

. . . . . . . . - . = _ - _ = - - - --

SUM Of f1 ACTIONS EQUALS 6.69E-02 e

Ie

<5

R EGICad : SAMPLE ISL PACILITY CODE MIM-AREA 102/97) PAGE 22 METSET: CENERIC NE7 STATION DATAf samr 1.dat 03/14/97 TIME STEP NUMSER 1, 10-Year Action Perio DURATtCN IN YRS 15... 10.0 Z

NUMBER 7 HAME= Resider.t 7 X= -4.4KM, Y= - 1. 5KM, Z* 0.0M, DIST= 4.7KM, IRTYPE= 0 m RESULTS OF Alf CHECK AT THIS 14CATIC:4 Q ......__........-_...._.... - - _ - . . . . - - --- ----

G U-238 0-234 Th-230 Ra-226 Rn.222(WLI Pb-210 81-210 Po-210 m .___...._......... _._-. _._ .--- - --......----- -

c CONC., PC1/M3 4.13E-04 4.13E-04 2.07E-06 2.07E-06 2.26E-05 5.27E-06 2.07E-06 2.06E-Oc ALC, PC1/M1 6.00E-02 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.00E-01 4.00E+01 9.00E-01 FPACTION OF ALC 6.89E-0) 8.26E-03 6. ts 9E-05 2.30E-06 2.06E-02 8.79E-06 5.18E-08 2.29E-06

.........__._. ....._ __. - - - - _ . - - - - _ = . . . . . . . . _ - _ . . . _ _ . . . _ - _ _ _- - ....____ ..._._.__._..____.

SUM OF FRACTIONS EQUALS 3.58E-02 NUMBER 8 NAME= Resident 8 X= -6.3EM, Y= 2.0KM, Z= 0.OM, DIST= 6. 6P38, IRTYPE= 0 RESULTS OF ALC CHECK AT THIS 1DCA710N U-238 U-234 Th-230 Ra-226 Rn.222(WL) Pb-210 Bi-210 Po-210 g CONC., PCI/M3 1.50E-04 1.50E-04 7.48E-07 7.50E-07 2.07E-05 4.86E-06 7.63E-07. 7.49E-07 O ALC, PC1/M3 6.00E-02 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.00E-01 4.00E+01 9.00E-01 rRACTION OF AI.C 2.49E-03 2.99E-03 2.49E-05 8.34E-07 1.881.-02 8.11E-06 1.914-08 ts . 32E $7 SUM OF FRACTIONS EQUALS 2.4 3E-02

. m .. sm.444aa suur. : m aw:2- AM.A (u/ / *s il PAGE 23 METSET: CENERIC KET STAT!ow CATA: tampis1.dat 03/14/97 TIME STEP NUMBER 2, 10-Year pastoration C3KATION 13 Y25 13... 10.0 CONCENTRATION sTA FOR THE N DIREC*10N, TMETA EQUALS 0.= DEGREES TOTAL AIR CONCENTRATIONS, PC1/M3, AND WL ypso, KM U-238 Th-230 Pa-226 Pb-210 Rn-222 Po-218 Pb-214 Bi-214 Pb-210 WL 1.5 3.678E-05 1.681E-u7 5.502E-07 5.491C-07 1.636E-01 1.597E-01 9.970E-02 6.662E-02 '.318E-07 9.tu4E-of 2.5 2.333E-05 1.052E-o? 3.817E-07 3.808E-07 1.212E-01 1.197E-01 8.290E-02 6.188E-02 1.749E-07 7, 7 4 4 E- 07 3.5 1.609E-05 7.196E-08 2.778E-07 2.772E-07 9.32=E-02 9.272E-02 6.869E-02 5.452E-02 1.049E-07 6.471E-07 4.5 1.180E-05 5.245E-Oe 2.112E-07 2.107E-07 7.437E-02 7.414E-02 5.762E-02 4.741E-02 /.2500-01 $.451 -07 7.5 5.830E-06 2.563E-08 1.109E-07 1.106E-07 4.368E-02 4.367E-02 3.707E-02 3.208E-02 /.512E-Of ).52eE-01 15.0 2.034E-06 8.813E-09 4.167E-08 4.157E-08 1.954E-02 1.955E-02 1.81?E-02 1.665E-02 z.492E-07 1.743E-u7 25.0 9.420E-07 3.621E-09 1.788E-08 1. 7 8 3E-01 9.738E-03 9.744E-03 9.501E-03 9.122E-03 2.216E-07 9.22 3E-Os 35.0 4.67)E-07 2.003E-09 1.013E-08 1.011E-08 6.081E-03 6.085E-03 6.034E-03 5.921E-03 2.085E-07 5.W94E-08 45.0 3.009E-07 1.285E-09 6.601E-09 6.585E-09 4.245E-03 4.247E-03 4.241E-03 4.206E-03 1.930E-07 4.157E-08 55.0 2.139E-07 9.115E-10 4.741E-09 4.730E-09 3.203E-03 3.20$E-03 3.210E-03 3.199E-03 + 80."-07 3.151E-08 65.0' 1.587E-07 6.754E-10 3.536E-09 3.528E-09 2.492E-03 2 494E-03 2.502E-03 2.501E-03 a.o9 07 2.45bE-08 75.0 1.229E-07 5.223E-10 2.750E-09 2.743E-09 2.00$E-03 2.006E-03 2.014E-03 2.017E-03 1.60.=-07 1.9moE-u8 CROUND SURFACE CONCENTRATIONS, PC1/M2 XpHO, FM U-238 Th-230 Ra-226 Pb-210 Rn-222 Po-210 Pb-214 Bi-214 Pb-J10 1.5 1.910E+04 9.527E*01 9.946E+01 9.946E+01 0.000E*00 9.958E+01 9.958E*01 9.958E*01 1,810E*00 2.5 1.053E+04 5.253E*01 5.549E+01 5.549E*01 0.000E+00 5.558E+01 5.558E+01 5.558E+01 3.091Eeu0 3.5 6.562E*03 3.271E+01 3.484E+01 3.484E+01 0.000E+00 3.491E+01 3.491E+01 3.491E+01 4.329E*UO 4.5 4.451E+03 2.218E*01 2.377E+01 2.377E+01 0.000E+00 2.383E*01 2.383E*01 2.383E+01 5.244E*uu 7.5 1.877E+03 9.350E+00 1.013E+01 1.013E*01 0.000E+00 1.017E+01 1.017E+01 1.017E+01 e.568E*00

( 1*.0 5.089E*02 2.533E+00 2.790E+00 2.790E+00 0.000E+00 2.006E+00 2.dO6E+00 2.006E+00 h.862E+00

[$ 25.0 1.194E+02 8.926E-01 9.866E-01 9.866E-01 0.000E+00 9.944E-01 9.944E-01 9.944E-01 6.608E .-0 35.0 8.949E4*J1 4.453E-01 4.920E-01 4.928E-01 0.000E*00 4.976E-01 4.976E-01 4.976?.-01 t.207E*UG 45.0 5.352E+61 2.663E-01 2.946E-01 2.946E-01 0.000E+00 2.990E-01 2.980E-01 2.9804-01 5.819E+0o 55.0 3.565E*G 1.774E-01 1.965E-01 1.965E-01 0.000E+00 1.991E-01 1.991E-01 1.991E-01 5. 4 7 4 8.* Jo 65.0 2.547E+01 1.267E-01 1.402E-01 1.402E-01 0.000E+00 1.422E-01 1.422E-01 1.422E-01 5.171E Ou 75.0 1.910E+01 9.504E-02 1.051E-01 1.051E-01 0.000E+00 1.066E-01 1.066E-01 1.066E-01 4.905E*00 TOTAL DEPOSITION RATES, PC1/M2-SEC XPHO, KM U ~s8 Th-230 Ra-226 Pb-210 1.5 8 . '.8 5E- 0 7 3.702E-09 1.801E-08 1.836E-08 2.5 5.i36E-07 2.413E-09 1.224E-08 1.274E-08 3.5 3.9?0E-07 1.671E-09 8.668E-09 9.262E-09 4.5 2.86'E-07 1.217E-09 6.399E-09 1.059E-09 7.5 1.362E-07 5.768E-10 3.093E-09 3.839E-09 15.0 4.318E-08 1.822E-10 9.988E-10 1.744E-09 25.0 1.565E-08 6.597E-11 3.630E-10 1.045E-09 35.0 7.882E-09 3.322E-11 1.830E-10 8.081E-10 45.0 4.703E-09 1.982E-11 1.092E-10 6.878E-10

g $5.0 3.168E-09 1.335E-11 7.363E-11 6.144E-10 C
65.0 2.236E-09 9.424E-12 5.190E-11 5.601E-10 75.0 1.662E-09 7.009E-12 3.855E-11 5.188E-10 O

b a

k 4

)_ " EEGIONi .P AftE 15L FAC11.17Y 'COC3- M11. DOS-AIEA (02/97) PAGE 24 N .METSET: CENERIC MET STATION. DATA: sampis!.uat. 03/14/97 i

. TIME STEP NUMBER 2, 10-Year Restoration- .00 RAT 10N IN YRS 13.'.. 10.0 2E .

j

) CONCENTRATION DATA FOR THE E DIRECTION,. THETA EQU4'S 90.0 OECREE3 '

TOTAL AIR CONCD47 RATIONS, PCI/M3, AND NL xRMO, KM. -U Th-230 Ra-226 Pb-210 Rn-222 Po-210 Pb-214 Ri-214L Pb-210- WL

'g.....'.'.........-238 .... ....- =- -- ----

= - - -

@ '1.5 '8.963E-06 4.283E-ne 9.052E-08 9.038E-08 7.750E-02 7.626E-02 4.866E-02 3.0'eE-02 4.981E-08 4.sviE-o?. '

2.5 5.339E-06 2.514E-o8 6.267E-08 6.225E-08 4.215E-02 4.177E 2.931E-02 2.094E-02 4.848E .t.svel-01 . i

~3.5~ 5.153E-06 2.316E-08 8.603E-08 8.584E-00 2.900E-02 2.888E-02 2.120E-02' 1.629E-02 5.089L-08. 1 va0E-o1 4.5 5.672E-06 2.467E-08 1.139E-07' 1.136E-07 2.375E-02 '2.362E-02 1.772E-02 1.417E-02 5.088E-08 1.670E-47 1.5 4.256E-06 1.809E-08 9.534E-08 9.511E-08 1.436E-02 1.434E-02 1.149E-02 9.609E-03 6.615E-08 1.vevE-07 15.0 1.844E-06 1.154E-09 4.328E-08 -4.317E-08 6.316E-03 6.319E-03 5.630E-03 .4.963*.-03 6.695E-08 5.357E-b8 25.0 8.336E-07 3.492E-09 1.986E-08 1.981E-08 3.150E-03 3.152E 3.003E-03l 2.801E-03 6.147E-08 2.894t-oe 35.0 4.196E-07 2.006E-09 1.151E-08 1.148E-08 1.965E-03 1.966E-03 -3 925T-03' 1.054E-03 . 650E-08 1.61ut-ce 45.0 3.142E-07 1.313E-09 7.570E-09' 7.551E .1.371E-03 1.372E-03 1.360+ 133 1.334E-03 .241E-08 li328E-08 55.0 '2.269E-07 9.469E-10 5.486E-09 5.472E-09 1.037E-03 1.038E-03 1.035C-03 1.024E-03 4.908E-09 .1.014E-Os 65.0 1.6)3E-07 7.061E-10 4.101E-09 4.091E-09 8.075E-04 8.079E-04 8.085E-04 8.046E-04.. 4.619E-08 7.932E 75.0 1.316E-01 5.489E-10 3.194E-09 3.186E-09 6.502E-04 6.506E-04 6.522E-04 6.513E-04 4.370E-08 .6.40tE-09 CROUND SURFACE CONCENTRATIONS, PCI/N2 t

U-238  ; Ra-226

! XRHO, kM. 'Th-230 Pb-210 Rn-222- Po-218 Pb-214 Bi-214 PS-210 .

1.5 6.751E+03 3.373E*01- 3.414E+01 3.414E+01 0.000E+00 3.420E+01 ,3.420E*01 3.420E*01 1.122E+00

' 2.5 3.600E+03 1.79dE+01 1.834E+01 1.834E*01 0.000E*00 1.837E+01 1.837E+01 1.837E+01. 't.655E*ou j

3.5 2.246E*03 1.119E+01 1.194E+01 1.194E+01 0.000E+00 1.196E+01 1.196E*01; 1.196E+01 I.893E*00L 1.550E+03 7.102E+00 .!

(1 4,5 8.787E+00 8.787E+00 0.000E+00 8.8CSE+v0 La 7.5 6.825E+02 3.374E*00 4.264E+00 4.764E+00 0.000E+00 8.005E+00'.8.R05E*00 .2,449E*04-b# 4.275E+00 4.275E+no 4.275E+00- 2.732E+JO, i 20.0 1.986E+02 9.779E-01 1.333E+00 1.333E+00 0.000E+00 1.330r+00 1.330E*00: 1.330E+00

~

25.0 1.434E+C1 - 3.657E-01 5.067E 01- 5.067E-01 0.000E+00 .5.092E-01

2. 42E*00 'j
5. 0 92E-01 5.09?E-01 1.927E*ue 35.0 3.847E+01 1.892E-01 2.622E-01 '2.622E-01 0.000E+00' 2.636E-01 2.630E-01 2.618E-08 1.763E*0u' 45.0 2.349E+01 1.156E-01 1.594E-01 1.594E-01 'O.000E+00 1.605E-01' 1.605E-01 '1.60$E 1.633E+uo 55.0 1.586E*01 7.802E-02 1.077E-01 1.077E-01 0.000E+00 1.085E-01 1.085E-01 1.065E-01 ~1.520E+00 65.0 1.139E+01 5.608E-02 7.682E-02 7.682E-02 0.000E+00 1.746E-02 7.746E-02' 7.746E-0? i.439E+00 75.0 8.572E+00 4.221E-02 5.748E-02 5.748E-02 0.000E+00 5.199E-02 5.799E-02 5.799E-02 '1.363E+00 5

TOTAL DEPOSITION RATES, PC1/M2-SEC XRHO, KM U-238 Th-230 .;

Ra-226 Pb-210 e

~~" ' "~~ ~~~ ~ ~

i5 1.54E-Ii? I.Y67E-iE~~

6 2.567E-09 2.710E-09 2.5 1.028E-07 4.548E-10 1.886E-09 2.027E-09 3.5 1.356E-07 5.779E-10 3.004E-09 3.149E-09 4.5 1.736E-07 7.279E-10 4.117E-09 .4.277E-09 7.5 1.338E-07 5.567E-10 3.280E-09 3.470E-09 15.0 5.240E-09 2.174E-10 1.298E-09 1.496E-09 25.0 2.070E-08 8.582E-11 5.136E-10 6.968E-10 3>

35.0 :1.071E-08 4.440E-11 2.657E-10 4.346E-10 45.0 6.431E-09 2.667E-11 1.595E-10 3.164E-10 "i 55.0 4.350E-09 1.804E-11 1.079E-10 2.549E-10 65.0 3.045E-09 1.263E-11 7.549E-11 2.139E-10 i 75.0 2.243E-09 9.304E-12 5.556E-11 1.865E-10 4

3 4

, , .- y , ,- m

- - i . - _ _. . .

PEG 10N;? iW4PLE ISL FACILITY rDDE: MILDOS-AREA' 102/981 -FAGF' 2S METSET: CEMFalc MET STATION JATA* Sampisl. cat 03/14/97

  • TIME STEP MUMBER 2, 10-Yost postoration CURAT.04 13 7RS 13... 10.0 CONCENTRATION DATA FUR THE S DIRECTION, THETA EQdA1.5 180.0' DEGREES TOTAL AIR CONCENTRATIONS, PC1/M3, AND WL XEMO, NM U-238 :Th-230 Ra-226 Pb-210 Rn-222l Po-218 Pb-214 Bi-214 Ptr-210 = WL

] -=----------- --~~-----u - ~ ~-

1.5 5.169E-04 2.137E-06 1.297E-05 1.293E-05 1.023E+00- 7.202E-01 1.371E-01 2.818E-02 ;' 9.674E-09 .1. 5CE - o+.

1 303E-04' 5.413E 3.207E-06 3.199E-06 3.505E-01 2.971E-01 9.619E-02 3.169E-02 1.805E-06 %119E-07 2.5 3.5 1.641E-05 ~7.082E-08' 3.495E-07 3.486E-07 1.368E-01 1.306E-01 6.602E-02 3.39eE-02 3.170E-Oe k n0E-u7 1.468E-07 1.464E-07 9.492E-02. 9.312E-02 5.715E-02 3.6(7E-02 6.656E-08 5,N5E-07 4.5 1.618E-06' '3.341E 3.uveE 7,5 2.543E-06 1.132E-08 4.501E-08 4.4 91E 4.153E-02 4.147E 3.288E-02 2.681E-02 1.199E-U7 6.674E 2.975E-09' 1.172E-08 1.169E-08 1.452E-02 1.453E-02 1.334E-02 1.207E-02 1.360E-o? 1.276E-07'

'15.0 25.0  ?.328E 1.038E-09 4.097E-09 4.087E-09 6.230E-03 6.242E-03. 6.111E-03 5.890E-03 1.251E-07 .$.938E-Od 1.189E-07 5.282E-10 2.132' ;9 2.127E-09 3.614E-03 3.616E-03 3.659E-03 3.611E-03 1.138E-07 3.581E-C8

-35.0 2.485E-03 2.486E-03 2.488E-03 2.479E-03 1.046E-07 L 2. 4 4 2E-Ot*

- 45.0 7.255E-08 3.213E-10 1.324E-09 1.321E-09

'55.0 4.949E-08 2.185E-10 9.193E-10 9.172E-10 1.83EZ-03 1.837E-03 1.843E-03 1.842E-03 9.116E-08' 't.811E-08 6.692E-10 1.410E-03 1.416E-03 1.418E-03 9.087E-08 :1.392E-08 65.0 3.570E-08 1.573E-10 6.708E-10 1.409E-03 2.102E-08 1.188E-10 5.128E-10 5.116E-10 1.122E-03 1.123E-03 1.128E-03 1.131E-03 3.554E-08 1.109E-08 75.0 GR % D SURFACE CONCENTRATIONS, PC1/M2 xago, RM u-238 Th-230 Ra-224 Pb-210 Rn-222 Po-218 Pb-214 Bi-214 026-110

---~ - -- --~ -- ~-

1.5 1.850E*04 8.508E+01 2.632E+02 2.632E+02 0.000E+00 2.630E+02 2.638E*02' 2.638E+C2 1.349E*Cu j 2.5 7.4'3E+03 3.565E*01 7.665E+01 7.665E+01 0.000E*00 7. 68 9E+ 01 7.689E*01 7.689E+01 7.057E*ud 3.5 3.610E+03 1.788E+01 2.115E+01 2.175E+01 0.000E+00 2.185E+01 2.185E+01 2.185E+01 2.597E+ou 4.5 2.380E+03 1.183E+01. 1.325E+01 1.325E*01 0.000E+00 1.333E+01 1.333E+01 1.333E*01 3.054E*00

, 1.5 9.821E+02 4.894E+00 5.237E+C0 5.237E+00 0.000E*00 5.270E+00 5.270E+00 5.270E+0C 3.686E+00 9 15.0 2.615E+02 1.304E+00 4.518E-01 1.374E+00 4.109E-01 1.374E+00 0.000E+00 0.000E+00 1.385E+00 4 ~;s9E-01 1.385t*00 4.759E-01 1.385E+00 4.759E-01 3.651E+00 3.510E*Ou

$ 25.0 9.056E+01 .4.709E-01 _

35.0 4.425E+01 2.208E-01 2.2940-01 2.294E-01 0.000E+00 2.323E-ul 2.323E-01' 2.3232 3.293E+uo.  !

3.019E+00  ;

45.0 2.587E*01 1.291E-01 1.339E-01 1.339E-01 0.000E+00' 1.359E-01 1.359E-01 1.359E-01

'55.0 1.684E*01 8.406E-02 8.721E-02 8.721E-02 0.000E+00 8 866E-02 8.866E 8.866E-02 2.888E+00 l' 65.0 1.178E+01 5.877E-02 6.093E-02 6.093E-02 0.000E+00- 6.20$E-02 6.205E-02 6.205E-02 2.722E*00 -

75.0 8.656E+00 4.320E-02 4.478E-04 4.478E-02 0.000E+00 4.567E-02 4.567E-02 4.567E-02 2.576E+00 TOTAL DEPOSITION RATES, PCI/M2-SEC XRHO, RM U-238 Th-230 Ra-226 Pb-210 1.5 2.513E-05 1.036E-07 6.384E-07 6.368E-07  ;

2.5 5.829E-06 2. 405E -08 1.414E-07 1.471E-07

, 3.5 5.908E-07 2.463E-09 1.436E-08 1.443E-08 4.5 2.320E-07 9.758E-10 5.940E-09 5.626E-09 6.192E-08 2.635E-10 7.5 1.380E-09 1.737E-09 .

' 15.0 1.346E-08 5.769E-11 2.301E-10 6.975E-10

! 25.0 3.957E-09 1.108E-11 e' . 2 4 98- 11 4.576E-10 t 35.0 1.832E-09 7.93GE- G 3.772E-11 3.7 8 9E-10 45.0 1.044E-09 4.524E-12 2.135E-11 3.350E-10 y 55.0 6.791E-10 2.943E-12 1.389E-11 3.053E-10 65.0 4.696E-10 2.036E-12 9.578E-12 2.822E-10 C 3.436E-10 1.491E-12 7.000E-12 2.636E-10 g 15.0 o

a g

1

?

  • * ~ ~ c e .e 4y , -, .

,U

I CODE: M11IM- AREA (02/97) PAGE 26 REGICes: SAMFLE'ISL FACILITY 03/14/97 METSET: GENERIC MET STATION DATA: Samt al . rta t 55 TIME STEP NUMBER 2, 10-Year pesturation DUFATIOh IN 'fRL 15... 10.0 C

CO*4CENTRATICf4 DATA FOR THE W 01RECTION, THETA EQUALS 270.0 DEGPEES O* TOTAL AIR COr4CENTRATIONS, PC1/M3, AND WL an-222 Po-218 Pb-214 Bi-214 l'b-210 WL E U-238 Th-230 Ra-226 Pb-210 xpgo, gM-- ----_---- -------------- ----------------------------------------------------.-----

QQ ------------------~~---------------~~~~01 7.218E-08 3.858E-07 3.848E-07 1.739E- 1.636E-01 7.841E-02 3.753E-02 3.591E-06 L otuf-07 1.5 1.703E-05 4.916E-02 2.835E-02 3.937E-08 4.t*tE-Gi 2.670E-06 1.226E-08 3.862E-08 3.854E-08 7.817E-02 7.697E-02 2.5 6,238E-09 1.490E-08 1.496E-08 3.646E-02 3.530E-02 2.716E-02 1.940E-02 3.979E-Od . 434E"07 3.5 1.320E-06 1.758E-02 1.410E-02 4.056E-OH 1.tstE-u) 8.162E-07 3.902E-09 8.199E-09 8.186E-09 2.129E-02 2.126E-02 4.5 9.980E-03 9.236E-01 5.5etE-op wootE-ud 7,5 3.036E-07 1.46BE-09 2.617E-09 2.674E-09 1.068E-02 1.068E-02 6.011E-10 4.153E-03 4.155E-03 4.092E-03 3.997E-03 b.06fE-08 *.994E-06 15.0 6.962E-08 3.371E-10 6.003E-10 1.891E-08 1.002E-10 1.885E-10 1.892E-10 1.925E-03 1.927E-03 1.927E-03 1.918E-03 5.537E 25.0 2.077E-08 1.171E-03 5.033E-00 1.tSCE-08 9.299E-09 4.462E-11 8.967E-11 8.953E-11 1.165E-03 1.165E-03 1.169E-03 35.0 5.264E-11 7.977E-C4 8.017E-04 0.037E-04 4.629E-OH 1,e64E-09 5.232E-09 2.501E-11 5.212E-11 7.981E-04 45.0 1.618E-11 3.543E-11 3.537E-11 5.951E-04 5.955E-04 5.982E-04 6.003E-04 4.308E-08 5.e85E-09 55.0 3.396E-09 4.033E-08 4.$2eE-09 2.395E-09 1.139E-11 2.538E-11 2.534E-11 4.578E-04 4.581E-04 4.603E-04 4.619E-04 65.0 8.499E-12 1.917E-11 1.914E-11 3.648E-04 3.650E-04 3.668E-04 3.681E-04 3.800E-08 3.6 tee-09 15.0 1.188E-09 GROUNC SURFACE CONCENTRATIONS, PC1/M2 Th-230 Ra-226 Pb-210 Rn-222 Po-218 Pb-214 8i-214 Ftr 21 u XPHO, FM U-238

- - - - - - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 1.684E+01

- - - - - - - - - - 8.2MbE-ul 2.548E+03 1.25' +01 1.671E+01 1.671E+01 0.000E+00 1.684E+01 1.684E*01 1.5 1.170E+00 1.449E*03 7.21..+00 7.513E+00 7.513E+00 0.000E+00 7.574E+00 7.574E*00 7.574E+00 2.5 4.673E+00 1.4SOE+cv fl 3.5 9.146E+02 4.5L3E+00 4.644E+00 4.644E+00 0.000E+00 4.673E+00 4.673E*00 3.081E+00 3.113E+00 3.113E+00 0.000E+00 3.130E+00 3.130E*00 3.130E*00 t . 5 996. uv da 4.5 6.167E+02 4' 2.473E+02 1.236E+C0 1.241E+00 1.241E+00 0.000E+00 1.249E+00 1.249E*00 1.249E+00 1. 7 9tE + n**

7.5 1, 6 4 cE

  • m >

5.728E+01 2.863E-01 2.866E-01 2.866E-01 0.000E+00 2.no9E-ci 2,gg9E-01 2.899E-01 15.0 0.000E+00 8.476E-02 i . 3116 .tw 25.0 1.664E*01 8.31*E-02 8.32E-02 8.323E-02 8.4?6E-02 8.476E-02 3.595E-02 3.597E-u2 3.'.97E-02 0.000E+00 3.690E-02 3.690E-02 3.690E-02 1.6tvE*uo 35.0 7.192E+00 3.936E+00 1.967E-02 1.969E-02 1.969E-02 0.000E+00 2.032E-02 2.032E-02 2.032E-02 1.478E*vu 45.0 1.296E-02 2.195E+00 1.247E-02 1.249E-02 1.249E-02 0.000E+00 1.296E-02 1.296E-02 t.37cE co 55.0 8.709E-03 0.000E+00 9.072E-03 9.072E-03 9.072E-03 1.281E+0u 65.0 1.741E+00 8.700E-03 8.709E-03 1.289E+00 6.444E-03 6.45CE-03 6.450E-03 0.000E+00 6.739E-03 6.739E-03 6.739E-03 1.205E*uo 75.0 TOTAL DEPOSITION RATES, PC1/M2-SEC XRHO, EM U-238 Th-230 Pa-226 Pb-210 1.5 6.156E-07 2.555E-09 1.521E-08 1.528E-08 2.5 5.999E-08 2.597E-10 1.235E-09 1.350E-09 3.5 2.381E-08 1.061E-10 4.202E-10 5.386E-10 4.5 1.334E-08 6.b35E-11 2,140E-10 3.352E-10 7.5 4.232E-09 1.960E-11 5.724E-11 2.247E-10 15.0 8.717E-10 4.094E-12 1.048E-11 1.924E-10 25.0 2.458E-10 1.159E-12 2.855E-12 1.689E-10 35.0 1.070E-10 5.041E-13 1.255E-12 1.522E-10 45.0 5.900E-11 2.776E-13 6.975E-13 1.396E-10 55.0 3.778E-11 1.i?5E-13 4.516E-13 1.297E-10 65.0 2.626E-11 1.234E-13 3.127E-13 1.213E-10 75.0 1.9395-11 9.1181-14 2.300E-13 1.142E-10

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E RE410N: $ AMP 3.E I.,L 1ACALITY CODE: M LCOS- AREA '02/971 PAGE 2ss MET $ET: CENERIC MET STATIOs4 DATA: sampisi.dat 03/14/97 TigeE $TE*> FattBER 2, 10-Year Restoration DURATION'IN TRS IS... 10.0 7

c Ile0IVIDUAL RECE.' TOR PARTICULATE CONCENTRATIONS AIRBORNE "OseCENTRATIONS, PC1/H3 CROUse0 CONCENTRATIONS, PC1/Hf NO. NAME PTSI. . U 238 Th-2N Ra-226 Pb-210 0-238 Th -230 Ra-226  % .116

.-----.----~~...----o---..--------

"* 1 Resident 1 1 0.000E*00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E*00 .u uuut.Go 1 Resident 1 2 3.935E '16 1. 961E-08 1.955E-08 1.955E-08 3.935E+03 2.967E+01 1.955E+01 1.%5E*68 1 Resident 1 3 '.076E-06 1.267E ni 7.840E-08 7.820E-08 1.043E+01 4.292E-02 2.646E-01 e.64a,E-ul 1 Resident 1 4 1.643E-06 6.766E-U9 4.198E-08 4.177E-08 4.813E+01 1.982E-01 1.222E+00 1. 22.* E

  • uu COpeCENTRATION TOTALS 8.654E-06 3.910E-08 1. Met-01 1.395E-01 3.994E+03 1.99tE+01 2.104E+ut 2.1u46+01

.--.--_ .. ..------=- -

- - - - - . - - - - - = - - -------- -

=------- ---

2 Resident 2 1 0.000E+00 0.000E:0C 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 v.cooE*do

, 2 Resident 2 2 6.064E-06 3.031E-08 a . 012E-Q 3.012E-08 6.064E+03 3.031E*01 3.012E*01 3.912E+ul 2 Resident 2 3 1.257E-06 5.177E-09 L205C-09 3.197E-08 4.261E+00 1.755E-02 1.002E-01 1.08tt-01 2 Resident 2 4 7.392E-07 3.044E-09 1.984E-08 1.879E-08 2. 65E+01 8.915E-02 5.497E-01 5.497E-01 COseCENTRAT2 0ee TOTALS 8.060E-06 3.854E-08 U.101E-08 8.089E-04 6.090E+03 3.042E+01 e.078E+01 J.018E+bt 3 Resident 3 1 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 4.372E-06 0.000E*00 v.000E+0v 3 Resident 3 2 2.185E-08 2.172E-08 2.172E-08 4.372E+03 2.185E+01 2.172E*01 2.172E+01 3 Resident 3 3 3.316E-05 1.365E-07 8.451E-07 8.430E-07 1.124E+02 4.627E-01 2.853E*00 2.45?E+oo 3 Resident 3 4 2.696E-05 1.110E-07 6.871E-07 6.854E-07 7.896Ee02 3.251E+00 2.005E+01 2.005E+01 CONCENTRATIOtt TOTALS 6.449E-05 2.694E-07 1.554E-06 1.550E-06 5.274E+03 2.55'E+01 4.462E*0' 4.4 2E+01

= _ - - - - =- =- -- --

4 Resident 4 1 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 4.579E-06 0.000E*00 0.060E*0u 4 Resident 4 2 2.289E-08 2.275E-08 2.275E-08 4.579E+03 2.289E+01 2.275E*01 2.275E+01 q's 4 Resident 4 3 5.969E-05 2.458E-07 1.521E-06 1.518E-06 2.623E+02 8.329E-01 5.135E+00 %135E+0a 5.069E-05 2.087E-07 1.292E-06

$e_ ..---_-.-.'.---..-....-- -

Resident 4 CONCENTRAT ON TOTALS 4

1.150E-04 4.174E-07  ?.836E-06 1.289E-06 2.829E-06 1.e85E+03 6.266E+03 6.114E+00 2.984E*01 3.769E*bt 6.558Eml s . 7 e.vE + 01 m %tE*01 5 Grazing area 5 1 0.000E+00 0.000E+00 0.000E+00 0.600E*00 0.000E+00 6.192E-01 t M0E+00 0.no0E*00 0.000E+vo 5 Crazing Area 5 2 3.096E-09 3.076E-09 3.076E-09 6.192E+02 . 3.0%E*00 3.u76E+00 Lo f tE*00 1

5 Gra Ing Area 5 3 7.076E-07 2.914E-05 1.804E-C8 1.799E-08 2.398E+00 ,9.874E-03 6.00aE-02 e.desE-O

  • 5 Grazing Area 5 4 3.285E-07 1.353E-09 8.373E-09 8.353E-09 9.623E+00 3.962E-02 1.655E-06 7.362E-09 2.443E-01 2.443r.01 COe4 CENTRATION TOTALS 2.949E-08 2.942E-08 6.313E+02 3.145E*00 3 381E*00 L381E+90

-........_.---......-------- ----------- ---- -=- -- i 6 Resident 6 1 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E*00 1.562E-06 0.000E*00 0.0uut*Db 6 Resident 6 2 7.808E-09 7.758E-09 7.758E-09 1.562E+03 7.800E+00 7.158E*00 7.15eE+00 6 Resident 6 3 1.141E-06 4.697E-09 2.908E-00 2.900E-08 3.'66E+00 1.592E-02 6 Resident 6 6.324E-07 2.604E-09 9.815E-02 E 615E-u4 4 1.612E-08 1.608E-08 1. 52E+01 7.627E-02 4.702E-01 4.792E-01 CONCENTRATIOt* TUTALS 3.335E-06 1.511E-08 5. 295E-08 5.284E-08 1.584E+03'

_-._ _-....---..-------- - - - - - = - - - -

1.900E*00 8.327E*00 W.32tE*ud

==_----- -.- --....- -----------. '

7 Resident 7 1 0.000E+00 0.000E+00 0.000e.+00 0.000E+00 0.000E+00 6.525E-07 0.000E*00 n.006E+00 u.ovbt+ou 7 Resident 7 2 3.262E-09 3.242E-09 3.242E-09 6.525E+02 3.262E+00 3.242E400 8.397E-08 3.242E+vu 7 Resident 1 3 3.458E-10 2.140E-09 2.135E-09 2.846E-01 1.172E-03 7.224E-03 7.2/4E-Os 7 Resident 1 4 3.531E-08 1.454E-10 8.999E-10 8.977E-10 1.034E+00 7.118E-07 4.258E-03 2.62 % -02 2.625E-u:

COteCENT R ION TOTALS 3.153E-09 6.282E-09 6.274E-09 6.538E+02 3.268E+00 3.275E+00

3. t r tE *ut.

- - - - - - - - - - ~ ~ - - - - - - - ~ ~ - - - - . - - - - - - - -

8 kesident 8 1 0.000E+00 0.000E*00 0.000E+00 0.000E*00 0.000E+00 2.362E-07 0.000E*00 0.000E+00 0.uouE*6o 8 Resident 8 2 1.181E-09 1.173E-09 1.173E-09 2.362E+02 1.181E*00 1.173E*00 1. I '. 3 E

  • 00 8 Resident 8 3 d.173E-08 3.612E-10 2.236E-09 2.230E-09 2.973E-01 1.224E-03 8 Resident 8 3.031E-08 1.248E-10 7.548E-03 f.54WE-Os 4 7.724E-10 7.705E-10 8.877E-01 3.655E-03 2.253E-02 2.253E.02 COtaCENTRATION TOTALS 3.542E-07 1.667E-09 4.102E-Oe 4.174E-09 2.374E+02 1.186E+00 1.2036,00 I.eutE*ou

- - - - . - - - - ~ ~ - - - - - - - - - - - - - - . - - - - . - - - - -

. ww. ,,,, 4. ' 4is. r,% a s.s s s . t Uut.: C11205-AREA (02/971 PAGE 129-'

pitTSET: GEN"fC MET STATION . .1CTA:.. sampic1.dat ,03/14/97

' TIME STEP NUNDER 2,.10-Yasr Restort. tion DURA 1'ON 13 YRS 15... 10.01

- , 17 INDIVIDUAL RECEPTCR RADON AND RADON DAUGHTER CUNCIh04T10NS

., AIRBORNE CONCENTRAT10NS..FC1/M)." .

CactJB40 CONCENTRATION $, PC1/Mt s yo; .Rn-222_ -Po-218 Pb-211 Bi-214 3Pb-210. Bi-210- Po-210. ' N1. ' Po-218 .Pb-214 :81-214 Ft,-Ilu

. . . . - ............ -. - - ----===- ----= ---------.- - --

= . . . . . . . - . . . . - - . - . . . . . . . . . .

L1- .1.431E-02 1.335E-02_5.050E-02 3.549E-02 7.676E-09 1.848E-10 1.244E-14 4.639E-07 5.909E-02 SiSO9E-02 5.009E-02 1. H7E+vo 12' 1.717E-02 7.666E-02. 4.981E-02 3.170E-02 5.200E-08 1.006E-10 5.391E-15 4. 497E-01' 6.071E-G2 6.071E-02 6.071E-02 1 ;2WE*ots ; 4 i 3 J?.720E-01 1.553E-01-6.606E-02 3.033E-02 2.826E-08 3.119E-11 9.992E-16 6.001E-07 1.230E-01 1&230E-01 1.230E.cl't.321E+ou T4. 2.7 65E-01 2.391E-01 8.661E-02 3.263E-02 2.230E-08 1.851E-11 4.478E-16 8.071E-07.1.994E-01.1.894E-01 1.894E+01 1 338E*0d

.^ s5 .3.979E-02 J.956E-02 3.012E-02 2.283E-02 5.814E-04 1.592E-10 1.194E-14 2.796E-07 3.134E-02 3.134E-02'3.134E-02 1.271E 00 6' 9.259E-02 9.082E-02 5.426E-02 .3.020E-42 3.721E-08 5.414E-11 2.307E-15 4.816E-07 .7.193E-02 ?.193E-02 7.1'.i3E-02 1J 133E+0e i 1- 3.415E-02 3.470E-02~2 833E-02 2.201E-92 5.561E-06 1.500E-10 1.109E-14 2.615E-07 2.74eE-02 2.749E-02'2.740E-02 1.601E+00L .i '

8 1.222E-02 1.222Ea02 1.113E-02 1.009E-02 5.650E-OS. 3.079E-10 4.398E-14 1.067E-07 9.600E-03 9.680E-03 ' 9.6e0E-03 2.045E+00 4

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  • METSET:-CENERIC MET STATION , DATAr saar al.dat 03/14/97',. . 'e .

TIMt_ STEP NUMBER 2 1C -Year Restoration

' .j (41FPTION s IM TR3 I3... 10.0 : ~

b. . .

MUpgBER 1 .: NAME= Resident 1 X= 1.0MM. Y= 1.3FM, E= 0.04, Dist- l1.1ee, IRTYPE. O ^!

! " RESULTS OF A14 CMECK AT THIS LOCATION

__- - _-_=... __ .---. -_ - - - - - - -  !

____ _ . h ___. ..,_..:

l:

U-238 U-234 Th-230 .Ra-226 . Rn-222 (Itt.) .Pb-210 i

81-210 " ~

Pct-210 . '

_. - ._..- . i ;

H CONC., pct /M3 8.65E-06 8.65E-06 3.91E-08 1.40E-07 '4.64E-07 ' 2.16E-07'  !.40E-07. 1.40E-07 ALC, PCI/M3 6.00E-02 5.00E-02 3.00E-02 '9.00E-01 1.10E-03 6.00E-01 4.00E+01 9.OuE-01)

F14ACT10N OF AI.C .1.44E 1.73E-04 1.30E-06 1.55E-07 4.22E-04 3.605-07 3.49E-09 1.SSE-07 SUM OF FRACTIONS EQUALS 7.41E-04 q

NUMBEA 2. NAME= Resident 2 X= 1.5MM. Y=' O.1EM, z. 0.0M, 013T= g,$an, IRTYPE= 0 RESULTS OF Att CHECK AT THIS IDCATION U-238 U-234 Th-230 Ra-226 Rn-222(WL3 .Fb-210 SE-2'O 'tw-110' i 9

CONC., PC1/M3 8.06E-06 8.06E-06 3.85E-08 8.10E-08. 4.50E-07 1.34E-07 8.10E-08 e . %E-Od

$' Alf,-PC1/M3 6.00E-02 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.00E-01'

.t L

4.00E+01 9.00E-Ot, FRACTION OF Atr 1.34E-04 1.61".-04 1.28E-06 9.00E-08 4. bye-04 2.23E-07 2.014-09 S.94E-4e

- - - - - - - - - - - - - - - - - - . - ~ ~ ~ - - - - -

SUN OF FRACTIONS EQUALS 7.06E-04 '

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cau s ges t. amror. A sa, e na.: a.s tr CODE: MILDOS- AKEA 402/979  : PACE 31 -

- peET5ET: CD'MIC MET STATION DATA: sampisl.dat'- 03/14/91' TIME STEP 98UMEIR 2. 10-Year Restoratix DURAT10st IN TRS-IS..i 10.0-yupgBER 3"#8AME* Resident 3 X= 1.0 % Y= -1.3FM, Zw .0.0M. O!sT. 1. 64WI. 1RTTPE= 0 PESULTS OF ALC CWCK AT TitIS IDCAT10st

~ COB 8C. , PC1/M3, 6.45E 05 6.45E-05 2.69E-07 1 55E-06. 6.08E-07 1.58E-06 . -

1.55E ' 1.SSE-co'- }

Alf..PC1/M3 6.00E '2 5.00E-02. 3.00E-02 9.00E-01 1.10E-03 6.00E-01 1.00E+01 - 9. 0t:t '

FRACTIOes OF ALC 1.07E-03 1.29E-03 8.98E-06 ,1.73E-06 5.53E-04 2.63E-06 ' 3.BBE-08 t.72E-06.

=- ....- -

= --- - - ....,.............  ;

,. SUM OF FRACTIcetS EQUALS 2.93E-03 s peUMBER 4 NAf8E* Resident 4 X= 'O.250t, Y= - 2 . 6108, Z= 0.0M, DIST= ' 2.6MM,.IRTYPE='O RESULTS OF Alf CHECK AT THIS IDCATIODE ,

+

U-238 U-234 Th-230 Ra-226 :Rn-222teft) Pb-210. B1-210 .Po-21U [

(op0C. , PC1/M3 1.15E-04 1.15E-04 4.77E-07 2.84E-06 8.07E-07 ~ 2.85E-06 ~ 2.83E-06 2.83E-06 I

ALC, PCI/M3 6.00E-02 5.00E-02 3.00E-02 .9.00E-01 1.10E-03' 6.00E-01 4.00E+01 9.00E-01 h.

u FPACTION OF ALC 1.92E-03 2.30E-03 1.59E-05 3.15E-06 7.34E-04 4.75E-06' 7.07E-Os 3.14E-06 p i

SUM OF FRACTIONS EQUAa3 4.99E-03 i v i

t r

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I

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REGION: S M PLE 13L FACgE,ITY CODE: MILDOS-AREA (02ht) ;PAGE' 3? >

~METSET: CENF.RIC MET STATION DATA: sampisl.dat 03/14/97' TIME STEP MUMBEA 2, 10-Year Restoration DURATaON IM YRS IS... 10.0 ' ,

Z~

NUMeER 5 . seAME Grazing Area 5 x- -3.2MM, Y=. 1.3FM, Z= 0.0M, DIST= 3.4MM, IRTYPE= 0

'{

RESf7LTS OF ALC CHECK' AT THIS 14 CATION - *

.-- U-238 U-234 Th-230 Ra-226 Rn-222*WLI PL 210' Bi-710 Pu-2nd

=

CONC., PC1/M3 1.66E-06 1.66E-06' 7.36E-09 2.95E-08 2.79E-07, 8.76E-08 2.96E-08 7.94E-06, ALC,'.PCI/M3 6.00E-02. 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.00E-01 4.00E*01 9.00E-01 FRACTION OF AIx*; 2. MR-05 3.M E-05 2.45E-07 3.28E-08 2.53E-04 1.46E-07 '7.39E-10 '3.27E-08

. _ . - - - -- -=_. . .............

i SUN OF FRACTICNS EQUALS 3.14E-04 NUMBER 6..NAME= Resident 6' ' X= -2.3MM, Y= -0.1EM, 1= 0.0M, DIST=j 2.3FM, IRTYPE= 0

  • RESULTS OF Alf CHECK AT THIS IDCATION

[-

...........--......e-U-238 U-234 Th-230 Ra-226 Rn-222(WL) Pb-210 81-210' Po-210.

........._. .......... - . = - - .... ...-- __ -- _.....-- -

g CONC., PCI/M3 3.33E-06 3.33E-06 1.51E-08 5.30E-08 4.82E 07 9.01E-08 5.29E-08 5.2WE-05 ALC,.PCI*M1 6.00E-02 5.00E-02 1.OJE 02 9.00E-01 1.1CE-03 6.00E-08 4.00E*01 -4. 0ct.. E L '

FRACTION Or.ALC 5.56E-05 6.67E-05 5.04E-07 5.88E-08 4.38E-04 1.50E-07 1.32E-0* ~ 5.87E-do SUM OF FRACTIONS EQUALS 5.61E-04 i

W n

f

t 1

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+ 4,...n.. . + . ,-q,

. .+ , ,, . . . . . . . . . - . _ . . . . . - - .

.. - *e awe, s e e FAGE '33 ,

. PIETSE*; CEg8E1lt!C MET ' STATIDet LATA: saapist.dat; . ,. 03/14/*7 TIME. STEP isUMBER 2,~10-Ysar Pestoration i DUpA1 2M.12.T23 15.. 10.0 1#

yUMgEn 7 sWtMEamesident 7 X= ' ' -4. 4 99t, Y= -1. 5100, ' 2 - 0.0N, ,DIST= '4.7199, . ' I RTY PE= 0 RESULTS OF AIC ClfECK AT THIS IDCATICId

. . . - - - - - -l '

U-238 U-214 Th-230 Ra-226 Rn-222twL) Pb-210
86-210 Fu-210: -

=- - = . . - ---- --

COI8C . , PC1/M3 ' 7.72E-07 7.72E-07 3.75E-09 6.20E-09 2.61E 6.19E-09 6.42E-09 6.N E-es d- l-c AIC, PCI/M3 6.00E 5.00E-02 3.00E-02 '9.00E-01. '1.10E-03 6.00E-01 4.00E+01 L9.00E-On

' FRACTIOes OF ALC 1.29E-05 1.54E-05 1.25E-07 6.99E-09 2.30E-04 1.03E-07 1.61E-10 : '

6.97E-09

.... ...= M -- -. - - - -i- - - - - - - -

=.._..-_ .__-_ __..;.......

s SUM OF f RACTIONS EQUALS 2.66E-04 t# UMBER 8 MAME= Resident 9 X= - 6 . 3109, Y= 2.0FM, Z= 0.0M, DIST= 6.6EP, IRTYPE- 0 1'

RESULTS OF Air CHECK AT THIS IDCATION

... ...............= - - --


........---- -a---"

U-238 U-234 Th-230 3a-226 Ra-222 (WL) Pb-210 B1-210 Pu-250 e

....... - - - - ~ = -

. . + .

Cosec., PC1/H3 3.54E-07 3.54E-07 1.67E-09 4.18E-09 1.07E-07 6.07E-08 '. 4. 4 9E-0 9 4.1 ?E- 09

'9 o

ALC, PCI/M): 6.00E-02 5.00E-02 3.00E-02 9.00E-01 1.10E-03 6.00E-01 4.00E+01 9.00E-01 ,

'. rRACTION OF Air 5.90E-06 7.0e1-06 5.5CE-08 4.65E-09 9.70E-05 1.01E-07 1.1?E-10 4.64E-u9 t 1 SUM or FRACTIONS EQUALS 1.10E-04

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APPENDIX D EFFLUENT DISPOSAL AT LICENSED URANIUM RECOVERY FACILITIES -

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APPENDIX D EFFLUENT DISPOSAL AT LICENSED URANIUM RECOVERY FACILITIES

[hckground NRC-licensed uranium recovery facilities, including milling and in situ leach (ISL) facilities, generate liquid wastes (i.e., effluent) that requi;e proper disposal. At ISL facilities, efnuent is generated from four liquid waste streams: two involving the host aquifer and the other two originating at the main uranium recovery plant. Liquid waste stres ms involving the host aquifer include production bleed and groundwater sweep. Production bleed is ground water extracted from the aquifer during the uranium recovery operation, in excess of injected water, in order to maintain a net groundwater inflow into the recovery zone and minimize or eliminate the migration of lixiviant and dissolved uranium outside the recovery zone Groundwater sweep is ground water extracted at the end of a uranium recovery operation primarily to restore groundwater quality in the recovery zone. Liqid waste streams originating at the uranium recovery plant include wastewater from yellowcake processing and reject brine from reverse asmosis treatment of contaminated water.

At ISL facilities, management af liquid waste has generally involved such disposal practices as release to surface waters, evaporation from lined ponds, onsite land applications including onsite irrigation, and injection in deep wells. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards policy is presented below.

Purpose and Annlicability This appendix provides guidance and discusses the technical and regulatory basis for review and evaluation of applications for disposal of liquid waste at ISL facilities. It is primarily intended to guide NRC staff reviews of site-specific applications for disposal of liquid waste at facilities. It can also be used for preparation of proposals for liquid waste disposal by ISL licensees and applicants. This appendix is applicable to both licensed and new facilities.

6policable Regulatior. and Standards in general, applications and proposals for disposal of liquid waste at ISL facilities must comply with the regulations in appendix A to 10 CFR Part 40, and subparts K and D,10 CFR Part 20, as applicable cepending on the proposed disposal procedure. All terms and characterir.ations in this appendix are to be used consistent with their definitions in the applicable regulations.

Applicable regulations in appendix A to 10 CFR Part 40 mainly include design standards for conatruction, maintenance, and operation of surface impoundments that are used for disposal of liquid waste or waste containing free liquids [ criteria 5A(1) through 5A(5)]; installation of liners (criterion SE); and seepage control (criterion 5F). Appendix A also includes other generally applicable provisions; including in particular site-specific groundwater protection standards for both radioactive and nonradioactive hazardous cor:stituents (criteria 5B and SC); corrective action programs (criterion 5D); groundwater monitoring requirements (criterion 7); and closure requirements (criterion 6).

p.1 NUREG-1569

Furthermore, criterion 8 of appendix A to 10 CFR Part 40 requires that byproduct materials must be managed so as to conform to the applicable U.S. Environmental Protection Agency (EPA) regulations in 40 CFR Part 440 Ore Mining and Dressing Point Source Category: Ef0uent Limitations Guidelines and Mine Source Perfc,rmance Standards, Subpart C, Uranium, Radium, and Vanadium Ores Subcategory, as codified on January 1,1983. These regulations provide technology-based limitations for disposal of wastewater from ISL facilities by release in surface waters.

Byproduct material disposal under 10 CFR Part 20 requires compliaru. with the applicable regulations in 10 CFR Part 20, subpart K (20.2001,20,2002, and 20.2007), and subpart D (20.1301 and 20.1302),

Subpart K offers provisions for byproduct material disposal by " release in ef0uents" (20,2001), or other disposal methods proposed by the licensee (10 CFR 20.2002). Among other requirements, the provisions in 10 CFR 20.2001 and 20.202 require compliance with the radiation dose limits for individual members of the public in 10 CFR 20.1301, and a demonstration of compliance with these limits as provided in 10 CFR 20.1302.

The dose limits in 10 CFR 20.1301 include the total t:ffective dose equivalent to individual members of the public (0.1 rm/ year), as well as the dose in any unrestricted area from external sources in any I hr (0.002 rem in any I hr) [10 CFR 20.1301(a) and (b)]. In addition, the regulations allow a licensee to apply for Commission authorization in advance to opeiate up to an annual dose limit for an individual member of the public (0.6 wm), which the Commission may generally authorize on a temporary basis or under special circumstances involving existing facilities (those designed prior to January 1994), subject to the requirements in 10 CFR 20.1301(c)(1), (2), and (3). The regulations also require [in 10 CFR 20.1301(d)] that licensees who are subject to the provisions of EPA generally applicable environmental standards in 40 CFR Part 190 shall comply with these standards. In some cases, the Commission may impose additional restrictions on radiation levels and on the total quantity of radionuclides that may be released in efnuents in order to restrict the collective dose at a particu,ar site [10 CFR 20.1301(e)].

In order to demonstrate compliance with the dose limits for individual members of the public in 10 CFR 20.1301, licensees and applicants must do so according to the provisions of 10 CFR 20.1302 which require that licensees (a) Demonstrate compliance with the dose limits for individual members of the public by conducting surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas (b) Show compliance with the annual dose limit by demonstrating, by measurement or calculation, that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or, by I demonstrating that the annual average concentrations of released radioactive materials do not exceed the effluent concentration values (for water) provided in table 2 of appendix 8 to 10 CFR 20.1001-20.2401 and that the dose from external sources to a continuously

. exposed individual would not exceed the established standard (0.002 rem!hr and 0.05 rem l in a year).

The provisions of 10 CFR 20.1302 also allow licensees, upon approval by the Commission, to adjust the effluent concentration values in table 2 of appendix B to L 10 CFR 20.1001-20.2401 for members of the public to take account of the actual characteristics of efduent that will be released [10 CFR 20.1302(c)].

NUREG-1569 p.2

The provisions in 10 CFR 20.2007 require that licensees and applicants must also comply with other applicable federal, state, and local environmental and health protection regalations governing any other toxic or hazardous properties of licensed materials disposed under 10 CFR Part 20, subpart K.

In addition to the above requ;tements, licensees and applicants considering disposal of I; censed materials under the provisions of either 10 CFR 20.2001 or 20.2002 are further required to comply with NRC's regulatory provisions for decommissioning of licensed facilities, prior to facility closure and license termination. These provisions include the interim cleanup criteria presently in use, and those specified in the final rule when the final rule is promulgated (the proposed radiological criteria for decommissioning are provided in the proposed rule in 10 CFR Part 20, subpart E:

10 CFR 201401-20.1405, FR volume 59, no.161, p. 43228, dated August 22,1994),

pronosal Review and Evaluation Criteria in general, licensees of ISL facilities are required to submit applications for disposal of liquid waste, and obtain NRC's approval of the proposed procedures. Applications will be approved on a site-specific basis by NRC staff based on demonstrated compliance with all of the applicable regulations.

Application review and evaluation criteria that will be used by the staff are discussed in the following paragraphs for disposal procedures that have been in practice or proposed at ISL facilities. These include:

onsite evaporation, release in surface waters, onsite land applications, and injection in deep wells.

Onsite Evanoration in accordance with 10 CFR Part 40, appendix A, applications for onsite evaporation systems must demonstrate that the proposed disposal facility is designed, operated, and closed in a manner that prevents migration of waste from the evaporation systems to a subsurface soil, ground water, or surface water.

In addition, applicants must demonstrate that site-specific groundwater protection standards and monitoring requirements are adequately established to detect any migration of contaminants to the ground water and to implement corrective action to restore groundwater quality if and when necessary as required by the regulations.

Evaporation pond systems will be approved if they comply with the regulatory requirements in 10 CFR Part 40, appendix A. These mainly include the design provisions for surface impoundments

[ criteria SA(1) through SA(5)); installation of liners (criterion SE); and seepage control (criterion SF).

In addition, evaporation ponds must also meet other generally applicable regulatory provisions in appendix A, including in particular the site-specific groundwater protection standards (criteria SB and SC); corrective action programs (criterion SD); groundwater monitoring requirements (criterion 7); and closure requirements (criterion 6).

Release in Surface Waters

( Proposals for release of liquid waste in surface waters must demonstrate compliance with the provisions l of 10 CFR 20.2001 and 20.2007, and the provisions of 40 CFR Part 440 as required by criterion 8 of l 10 CFR Part 40, appendix A as applicable based on site-specific conditions.

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Specifically. release in surface waters must meet tne regulatory provisions in 10 CFR 20.2001(a)(3).

which requires that licensees comply with the dose limits for individual members of the public in 10 CFR 20.1301. In order to demonstrate compliance with the dose limits for individual members of the public in 10 CFR 20.1301 licensees and applicants must do so according to the provisions of 10 CFR 20.1302 (The provisicas of 10 CFR 20.1301 and 20.1302 have already been discussed under Applicable Regulations.)

Licensees and applicants must also comply with other applicable federal, state, and local environmental ary* health protection regulations governing any other toxic or hazardous properties of licensed materials disposed of under 10 CFR Part 20, subpart K, pursuant to the provisions in 10 CFR 20.2007.

Compliance with criterion 8 of appendix A to 10 CFR Part 40 requires conformance to the provisions in 40 CFR Part 440, as applicable. These regulations provide technology-based effluent limitations for existing point sources, in 40 CFR 440.32 and 440.33 and new source performance standards (NSPS), in 40 CFR 440.34, promulgated by the EPA under the Clean Water Act. Licensees must demonstrate compliance with these EPA regulatiom and standards, as applicable, including th: obtaining of a National Pollutant Discharge Elirnination System (NPDES) permit issued or approved by the EPA.

The regulatory provisions and requirements for release ofliquid waste under a NPDES permit are outside the scope oi' this appendix; however, specific effluent limitations and standards in 40 CFR 440.30-440.34) that are applicable to discharges from ISL facilities are provided and briefly discussed in a sununary to this appendix.

As indicated in the summary, there is a distinction in 40 CFR Part 440, subpart C (i.e., NPDES standards) between " process wastewater" and ' mine wastewater" with respect to ISL facilities. " Process wastewater" is wastewater and liquid waste generated from uranium recovery operations; it includes production bleed or groundwater extracted from the aquifer during the uranium recovery operation, and liquid waste generated at the main uranium recovery plant. "Mine wastewater" is wastewater from post-operation groundwater sweep, or groundwater extracted to restore water quality in the recovery zone after a uranium recovery operation is stopped.

WPDES ef0uent limitations in 40 CFR 440 that are applicable to NRC licensed facilities are provided in the summary in tables Al and A2. The effluent limitations in table Al are applicable to milia, including

" process wastewater" from ISL facilities. The effluent limitations in table A2 are applicable to mines, including "mine wastewater" from ISL facilities.

NRC staff notes that ISL licensees must comply with the NPDES effluent limitations for uranium in table A2, which applies to existing mines. including "mine wastewater" from ISL facilities; this is because mines and "mine wastewater" are not covered by NRC regulations in 10 CFR Part 20. However, there is no such stand.ird for uranium in table Al, which applies to existing mills, including " process wastewater" from ISL facilities. Licensees must in this case comply with the provisions in 10 CFR Part 20, subpart K (i.e., meet the dose limits for individual members of the public pursuant to 10 CFR 20.1301 and other requirements to satisfy the provisions in subpart K). Moreover, the NPDES effluent limitations for certain nonradioactive constituents for release of " process wastewater" may be different from those for release of "mine wastewater" [e.g., the effluent limitations for the chemical oxygen demand (or COD) in tables Al and table A2, for example].

NUREG-1569 04

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Therefore ISL licensees proposing to dispose of bypNJuct nuuerial by release in effluents may need to satisfy different standards, depending on whether the disposal involves releasing a " process wastewater" or a "mine wastewaer." Consequently, licensed ISL facilities that involve commingling of " process wastewater" and "mine wastewater" in an interim common storage facility (i.e., storage reservoir) before the wastewater is teleased in surface waters have two alternative options to satisfy the regulations. Under the first option, a licensee would monitor the incoming wastewater by source and meet tne corresponding affluent limitations separately for " process wastewater" and "mine wastewater" at their respective paints vf discharge into the interim storage facility, if both input streams were within the appropriate effluent release limits, the licen ce would be free to release the wastewater from the storage facility.in the second option, a licensee would not monitor the input streams, and would need to meet the applicable standard in 10 CFR part 20 before releasing the commingled wastewater in surface waters.

Licensees and applicants disposing effluent by release in surface waters are further required to comply with NRC regulatory provisions for decommissioning prior :o facility closure and license termination (det vnmissioning requirements have already been discussed under Applicable Regulations and Standards).

Land Acelications Proposals for disposal of liquid waste by onsite land applications, including ;trigation, will be approved under the provisions of 10 CFR 20.2002. Licensees must in this case provide a description of the waste, including its physical and chemical properties that are important to risk evaluation; the proposed manner and conditions of waste disposal; an analysis and evaluation of pertinent information on the nature of the environment; information on the natutt and location of other potentially affected facilities; and analyses and procedures to ensure that doses are maintained As Low As Reasonably Achievable (ALARA) and within the dose limits in 10 CFR Part 20 (i.e.,10 CFR 20.1301).

Applications must analyze and assess projected concentrations of rabactive contaminants in the soil; projected impacts on groundwater and surface water quality, and on lar J uses including particularly crops and vegetation; and projected exposures and health risks that may be associated with radioactive constituents reaching the food chain to verify that the projected doses and risks conform to the risk !evels permitted under 10 CFR Part 20. It is expected that proposals include provisions for periodic soil surveys that include contaminant monitoring to verify that the contaminant levels in the soil do not exceed those projected, and a remediation plan thM can be implemented in the event that the projected levels are exceeded.

In addition to the radiation dose, it may ako be necessary in some cases to conduct analyses to assess the chemical toxicity of radioactive and nonndioretive wnstituents in order to evaluate the health risks associated with land applications involving irri Eation at particular sites in compilance with other applicable federal, state, and local environmental and health protection regulations that must also be satisfied a pursuant to 10 CFR 20.2007. Staff will work with appropriate state and federal agencies if necessary to review site specific chemical toxicity evaluations, and to verify that any necessary permits for this purpose are secured as warranted by the applicable regulations.

In the absence of compliance monitoring wells in the uppermost aquifer in the area used for effluent disposal or for installation of land application systems including temporary surface mrage facilities, proposals must demonstrate that contaminants will not be returned to the grour water and cause exceedence of any site-specific groundwater protection standards that are established pursuant to appendix A of 10 CFR Part 40.

D5 NUREG-1569

Licemees and applicants disposing efnuent by onsite lan:1 applications are further required to comply with

)

NRC regulatory provisions for deconunissioning, prior to facility closure and license termination (deconunissioning requirements have already been disetused under Applicable Regulations and Standards).

Dren Well Iniectica Proposals for disporsi of liquid waste by injection in deep wells must meet the regulatory provisions in 10 CFR 20.2002 Speci0cally, proposals must in this case include a description of the waste, including its physical and chemical properties that are important to risk evaluation; the proposed manner and conditions of waste disposal; an analysis and evaluation of pertinent information on the nature of the environment; infonnation on the nature and location of other potentially affected facilities; and analyses nnd procedures to ensure that doses are ALARA, and v*hin the dose limits in 10 CFR Part 20 (i.e.,

10 CFR 20.1301).

Applications must also demonstrate that the injection zone is confined, that it is not a drinking water source, and that the injec:ed contaminants will not cause exceedence of any established site specinc groundwater protection standards in the uppermost aquifer or result in any cross contamination that would adversely impact another zone that is a source of drinking water. If necessary and warranted by site conditions, applications may include provisions for periodic gioundwater monitoring in the vicinity of the injection well to verify that drinking water zones are free from cross contamination, and a remediation rian that can be implanted in the event that unacceptable levels of contamination are detected.

In addition, pursuant to the provisions of 10 CFR 20.2007, proposals for disposal by injection in deep wells must clso meet any other applicable federal, state, end local government regulations pertaining to deep well injection, and obtain any necessary permits for this purpose. in particu'ai. proposals must satisfy the EPA regulatory provisions in 40 CFR Part 146: Underground injection Control (UlC)

Program: Criteria and Standards, and obtain necessary permits from the EPA and/or States authorized by EPA to enforce these p9 visions. In g:neral, applications that satisfy the EPA regulations under the UIC program will be approved by NRC staff.

Licensees and applicants disposing efnuer,t by injection in deep wells are further requiral to comply with NRC's regulatory provisions for decommissioning, prior to facility closure and license termination (decommissioning requirements have already been discussed under Applicable Regulations and Standards).

Summar.y Ef0uent Linitations and Standards Applicable to NRC Licensed Facilities in 40 CFR Part 440; Ore Mining and Dressing Point Source Ca'egory, Subpart C, Uranium, Radium and Vanadium Ores Subcategory.

Since the NRC does not regulate conventionil mining, the efnuent limitations in 40 CFR Part 440 pertaining exclusively to conventional mines are not applicable to NRC licensed facilities and will not be provided or discussed in this sununary.

There is a distinction in 40 CFR Part 440, subpart C between " process wastewater" and "mine wastewater" with respect to in situ ISL facilities (see 40 CFR Part 440, subpart L, and 47 FR 54604).

" Process wastewater" is wastewater and liquid waste generated from uranium recovery operations; it includes production bleed or ground water extracted from the aquifer during the uranium recovery NUREG 1569 D6 l

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operation, and liquid waste generated at the n,ain uranium recovery plant. "Mine wastewater" is wastewater from postoperation ground water sweep, or groundwater extracted to tesfore water quality in the recovery zone after a uranium recovery operat ion is stopped.

Effluent limitations in 40 CFR 440 that are applicable to NRC licensed facilities are provided in tables Al and A2. The effluent limitalians in table Al are applicable to mills, including " process wastewater" from ISL facilities. Efnuents from existing mills, including " process wastewater" from existing ISL facilities, applying the best practicable control technology currently available (BPT) shall not exceed the attainable effluent limitations provided in table Al. >

The effluent limitations in table A2 are applicable to mines, including "mine wastewaters" from ISL facilities. Existing mines, including "mine wastewater" from ISL facilities, applying the best available technology economically achievabt (BAT) shall not exceed the attainable efnuent limitations provided in table A2.

4 in addition to the above, the new source' performance standards [40 CFR 4440.34(b)] stipulate that for new sources there shall be no discharge of process wastewater to navigable waters from mills using the acid teach, alkaline teach or combined acid and alkaline leach process for the extraction of uranium or from mines and raills using ISL methods. These regulations further stipulate that in the event that the annual precipitation falling on the treatment facility and the drainage area contributing surface runoff to the treatment facility exceeds the annual evaporation, a volume of water valent to the difference between these two values may be discharged subject to the limitations set forth above.

in that the ef0uent limitations and standards in 40 CFR Part 440 are based on technology based treatment requirements, ef0uent limitations and standards at specific sites will be imposer ' ased on approved treatment technology on a site specific basis by the EPA. Treatment technology v approved for specific sites based on the regulatory provisions in 40 CFR Part 125: Criteria a ..t Standards for the National Pollutant Discharge Elimination System: Subpart A; Criteria and Standards for imposing Technology Dased Treatment Requirements Under Sections 301 (b) and 402 of the Act (i.e., Clean Water Act)(40 CFR Part 125, 125.1-125.3).

'Punuant to the dennition of *new sourm" in 40 CFR 122.2. *new' uranium recmery facihties as the) pertain to the regulations in 40 CFR Part 440 are those the construction of whkh commenced after December 3, IW2, which is the date when the emuent standards relevant to uranium recovery were nrst issued. "Esisting' facihties are those the construction of which commenced before Decemtwr 3.1992.

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_ . . . _ _ _ ~ - _ - _ _ _ - - _ - - - _ _ . _ . . . _ .

Table Al. Emuent limitatiorm representing the degree of emuent reduction attainable by the I application of best practicabls control technology currently available. (Applicable to existing mills, l including " process wastewatar" from la situ leach facilities.) [ Source: 40 CFR Part 440.32(b)]

Emuent Limitations Maximum Average of Daily Values for Emuent Characteristic for any One Day 30 Consecutive Days TSS (mg/l) 30 20 ,

COD (mg/l) - 500 AS (mg/l) 1.0 0.5 Zn (mg/l) 1.0 0.5 Ra226 (dissolved): pCi!! 10 3 Ra226 (total): pCi/l 30 10 Nil' (mg/l) -

100 pli 6.0-9.0 6.0-9.0 Table A2. Emuent limitations representing the degree of emuent reduction attainable by the application of best practicable control technology currently evallable. (Applicable to existing mines, including "mine wastewater" from in situ leach facilities.) [ Source: 40 CFR Part 440.33(a)]

Emuent Limitations Average of Daily Values for Emuent Characteristic Maximum for any One Day 30 Consecutin1Days COD (mg/l) 200 100 Zn (mg/l) 1.0 0.5 Ra226 (dissolved); pCill 10 3 Ra226 (total); pCill 30 10 g U (mg/l) 4 2 NURfiG 1569 D-8

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APPENDIX E  !

l RECOMMENDED OUTLINE FOR SITE-SPECIFIC IN SITU LEACH FACILITY RECLAMATION AND STABILIZATION COST ESTIMATES l I

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1 APPENDIX E RECOMMENDED OUTLINE FOR SITE-SPECIFIC IN SITU LEACII FACILITY RECLAMATION AND STABIl.IZATION COST ESTIMATES As required under Criteria 9 and 10 of 10 CFR Part 40, appendix A, the licensee shall supply sufficient information for the Nuclear Regulatory Commission (NRC) to verify that the amount of coverage provided by the financial assurance accounts for all necessary activities required under the license to allow the license to be terminated. Cost estimates for the following activities (where applicable) should be submitted to NRC with the initial license application or reclamation plan and should be updated annually as specified in the license. Cost estimates must be calculated an the basis of completion of all activities by a third party. Unit costs, calculations, references, assumptions and equipment and operator efficiencies, etc., must be provided.

The detailed cost information necessary to verify the cost estimates for a above categories of closure work is descritxi in the following recommended outline.

(I) FACILITY DECOMMISSIONING This includes dismantling, decontamination nd disposal of all structures and equipment. This may be accomplished in two phases, in the first phase, only the equipment not used for groundwater restoration (including the stability monitoring period) is removed. Well plugging and removal of the remaining equipment would be performed in a second phase, after the approved completion of groundwater restoration. The buildings used for the in situ operations may be decontaminated and released for unrestricted use.

(A) Salvageable building and equipment decontamination (list). For each building or piece of equipment listed, the following data should be provided:

(1) Labor for dismantling and decontamination (a) Person-hours and categories of labor (b) Average hourly vage for each category (c) Total labor cost (benefits, insurance, etc., and all labor overhead must be included here or calculated on the basis of total project labor)

(2) Equipment and material for dismantling and decontamination:

(a) Itemization of equipment and material to be used for decontamination (b) Itemized cost for material and equipment cost per hour listed in (a) above (equipment costs must include hourly operating, ownership, and overhead expenses)

E1 NUREG 1569

(c) Operating hours for each piece of equipment (d) Total equ! pre.;nt and material cost.

(13) Nonsalverable building and equipment disposal (1) List of major categories of building and equipment to be disposed of and their corresponding quantities:

(a) Structures (list each major) (tons of material and building volume cubic feet)

(b) Foundation concrete (cubic yards)

(c) Process equipment (tons)  !

(d) Piping and insulation (lump sum)

(e) Electrical and instrumentation (lump sum)

(2) Unit cost of disposal for each item above (include equipment, labor, material, transportation, and disposal costs)

(3) List and state how each chemical solution within the mill area will be disposed of along with the associated cost of disposal (4) Total cost (C) Restoration of contaminated areas (ore storage pad, access roads, process area, affected groundwater, evaporation pond residues, etc.)

Removal and Disposal of 11(c)2 byproduct material-In 10 CFR 40, appendix A, criterion it required that these materials are to be transported and disposed at a licensed tailings area or licensed disposal site. The quantity of material to be removed and the distance to the disposal site and the fees charged by the receiving facility are important considerations in determining the costs of disposal.

Reclanution-This entails recon. touring the well fields and evaporation ponds and placing top soil or other materials acceptable to the NRC. This may also include revegetation.

(1) Removal:

(a) Area, depth, and quantity of material to be removed (area, feet, and cubic yard-or size of liner if appropriate)

(b) Unit cost (include excavation, loading, transportation, and deposition)

(c) Total cost (equipment and labor)

NUREG 1569 E.2

t (2) Revegetation: i i

(a) Area to be revegetated (acre)

(b) Unit cost (include fill material replacing topsoll, and revegetation cost) >

t (c) Total cost (equipment, labor, and materials)

(II) GROUNDWATER RESTORATION AND WELL PLUGGING l In most cases, groundwater restoration consists of groundwater sweeping and water treatment with partial reirdection. The water treatment equipment used during the uranium recovery phase l of the operation is generally suitable for the restoration phase. The capital cost of this  !

equipment is usually absorbed during the initial stages of the operation leaving only the costs i

> of operation, malrnenance, and replecement filters for the restoration phase. However, if additional equipment will be requirrJ for restoration, associated costs should be detailed here.

Replacement costs of some water treatment equipment may need to be included in the surety ,

if the equipment used for restoration is near the end of it's serviceable life.

r4) Method of restoration (B) Volume of aquifer required to be restored, area and thickness of aquifer, number of required pumping cycles, and cycling time (C) Equipment associated with aquifer restoration (e.g., reverse osmosis unit)

(D) Verification sample analysis >

(1) Number of samples (2) Unit cost for sample collection and analysis (per sample)

(3) Total cost for verification sample analysis (E) Well plugging (1) Number of drill holes to be plugged (2) Depth and size of each drill hole (3). Material to he used for plugging including acquisition, transportation, and plugging .

(4) Total cost for well plugging t (F) Total cost for groundwater restoration E3 NUREG IS69 >

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(Ill) RADIOLOGICAL SURVEY AND ENVIRONMENTAL MONITORING Radiological Survey-Suneys and soll samples for radium in areas to be released for restricted use. Soils around the well fields, evaporation ponds, and process buildings should be analynd for radium content. A gamma survey of all areas should be made prior to release for unrestricted use. All equipment released for unrestricted use should be surveyed and records maintained.

(A) Soll samples for radium (B) Decommissioning equipment and building smear semples t

(C) Gamma survey (D) Environmental monitoring Costs of labor, materials, and analysis for continuation of environmenta! monitoring ,

program throughout reclamation.

(E) Total cost (1) Number of each kind sample listed above ,

(2) Unit cost for sample and analysis (price per sample)

(3) Total cost for radiological survey (IV) - PROJECT MANAGEMENT COSTS AND MISCELLANEOUS 3 Itemin estimated costs associated with project management, engineering changes, mobilization costs, legal expenses, power costs during reclamation, quality control, radiological safety costs, etc.

(V) LABOR AND EQUIPMENT OVERHEAD, CONTRACTOR PROFIT Overhead costs for labor and equipment and contractor profit may be calculated as separate items or loaded into hourly rates. If included in hourly rates, the unit costs must identify the percentages applied for each area.

(VI) CONTINGENCY The licerece should include a contingency amount to the total cost estimate for the final site -

. closure. The staff currently considers a 15 percent contingency to be an acceptable minimum

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(Vill) ADJUS1MENTS TO SURETY AMOUNTS The licensee is required by 10 CFR Part 40, apperfix A, criteria 9 to adjust cost estimates annually to account for innation and changes in reclamation plans. The submission should be in the form of a request for amendment to the license.

(A) Adjustments for in0ation The licensee should submit a revised surety incorporating adjustinents to the cost estimates for infiation 90 days prior to each anniversary of the date on which the first teclamation plan and cost estimate was approved. The adjustment should be made using the innation rule indicated by the change in the Urban Consumer Price Index published by the U.S. Department of Labor, Bureau of Labor Statistics.

(B) Changes in Plans (1) Changes in the process such as size or method of operation.

(2) Licensee initiated changes in reclamation plans or reclamation / decommissioning activities performed.

(3) Adjustments to reclamation plans required by the NRC.

(4) Proposed revisions to reclamation plans must be thoroughly documented and cost estimates and the basis for cost estimates detailed for NRC review and approval. Where a licensee is authorized by the NRC to secure a surety arrangement with the state, no reduction to the surety amount shall be initiated wl:hout prior NRC approval. Copies of all correspondence relathig to the surety between the licensee and the state shall be provided to the NRC. If authorized by the NRC to maintain a surety with the state as the beneficiary, it is the responsibilitv of the licensee to provide the NRC with verification of same; ensure that the agreement with the state specifically identifies the financial surety's appil7 ation, in siru leach (ISL) facility, and decommissioning / reclamation requirements; and transfer the long-term surveillance and control fee to the U.S. Department of ihe Treasury prior to li .ense termination.

All costs (unit and total) are to be estimated on the basis of independent contractor costs (include overhead and profit in unit costs or as 3 percentage of total). Equipment owr.ed by the licensee and the availability of licensee staff should not be considered in the estimate to reduce cost calculations. All costs should be based on current year dollars. Credit for salvage value is generally not acceptable on the estimated costs.

The NRC staff teview may include a comparison of unit cost estimates with standard construction cost guides (e.g., Dodge Guide, Data Quest) and discussions with appropriate r. tate or local authorities (highway cost construction). The licensee should provide supporting information or the basis for selection of the unit cost figures used in estimates.

E5 NUREG-1569

f*fec f OW 336 u s NucLt.A4 Rt GuLAlotY Costletsb40N 1. REPOR1 NUMBER Mimi ,*'C7fn*1^."2$,*,,7

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    • BIBLIOGRAPHIC DATA SHEET

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NUREG 1569 2 tilLE ANYbuhtlitt Draft Draft Standard Review Plan for in Situ Leach Uranium Extraction License Apphcations 3 DATE REPOR1 PUBusHEo WoNTH YEAR ^

l

_. _ October . ... _ 19g7 __

4 FIN OR GRANT NUMBER s Au1WsR($1 s 1YPE of REPORT Draft F. PERico COVERED (#atus,,e W1 s PL Rf OAMING ORGANilAllON e NAME AND ADoREss (# NRC. pro.uss Desen oaks a Repen, U s N.smer Rep eeery com eneca sw meag emees aow*est.

om.wenemenee,oseens Division of Waste Management Office of Nuclear Materials Safety and Safeguards U S. Nudear Regulatory Commission Washington, D C. 20555-0001 s 66*ONSORING ORGANilAliON . NAME AND ADDRE ss (# NRc. rype 'seme es e60.e'. # owcocsor. p,ovute NRC Dween onke or Regen. U s Nuter Reputefry comnessen.

ew aweap emese J Carne as 8. above.

10 bvPPLEME NIA4f NO!s b 11 Abs 1KAci (puo so,tse or assi A Nuclear Regulatory Commission source and byproduct material license is required to recover uranium by in situ leach crtraction techniques under the provisions of Title 10 Code of Federal Regulations, Part 40 (10 CFR 40), Domestic Licensing of Source Material. An applatant for a research and development or commercial-scale hcense, or for the renewal or cmendment of an existing hcense is required to provide detailed information on the facihties, equipment, and procedures used cnd an environmental report that discusses the effects of proposed operations on the health and safety of the pubhc and on the environment.

The Standard Review Plan is prepared for the guidance of staff reviewers in the Office of Nuclear Material Safety and Safeguards in performing safety and environtmntal reviews of applications to develop and operatc uranium in situ leach facihties. It providus guidance for new license apphcations, renewals, and amendments. The principal purpose of the standard review plan is to assure the quakty and uniformity of staff reviews and to present a well-defined base from which to evaluate changes in ttw scope and requirements of a review.

The standard review plan is wntten to cover a variety of site conditions and f64llity designs. Each section is written to provide o description of the areas of review, review procedures, acceptance critena, and evalual on of findings. However, for a given cpr'scatiori, the staff reviewers may select and emphasize particular aspects of each standard review plan section as is appropriate for the apphcahon.

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