ML20209F428
| ML20209F428 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1998 |
| From: | Schmidt D, Surmeier J, Treby S NRC |
| To: | |
| Shared Package | |
| ML20209F412 | List: |
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| NUDOCS 9907160020 | |
| Download: ML20209F428 (10) | |
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Differing Professional View Panel Report l
Concerning Handling of ]
Liquid Effluent Releases From in Situ Leach <
dperations at Licensed Uranium Recovery Facilities )
' _ ;_ - > /EltJl98
%ohn J. Surmeier, Chairman
/ Y ' It/ /2/zi/ff "
Stuart A. Treby, Pa 1 Merribef i *h iz./u /38 Duane W. Schmidt, Panel Mbm6er i
Ta%' 8" "J'*
ru tv i E M)W cit) J
I DIFFERING P.ROFESSIONAL VIEW PANEL REPORT CONCERNING HANDLING OF LIQUID EFFLUENT RELEASES FROM IN SITU LEACH OPERATIONS AT LICENSED URANIUM RECOVERY FACILITIES
- 1. INTRODUCTION This report discusses the review of the Differing Professional Views (DPVs) from.two individuals on a related issue concerning the handling of liquid effluent releases from in situ leach (ISL) uranium extraction operations at licensed facilities. The two DPVs were submitted by:
- William H. Ford to Carl J. Paperiello, Director, Office of Nuclear Material Safety and Safeguards (NMSS) on October 20,1998 ( Attachment A). Mr. Ford, in his DPV, objects not only to the current Division of Waste Management's (DWM's) policy towards regulating liquid effluent at ISL facilities but also to Option 3 in the proposed Commission Paper entitled " Recommendations on Ways to improve the Efficiency of NRC Regulations at In Situ Leach Uranium Recovery Faci!ities"(hereafter referred as the proposed Commission Paper). Mr. Ford believes that all of the liquid effluent releases should be considered as "11e.(2) byproduct material," as practiced by NRC staff prior to 1995. Furthermore, his view would be the same whether or not the NRC relied on the Environmental Protection Agency (EPA) Underground inject Control (UlC) Program.
Mr. Ford submitted several supporting documents with his DPV: (1) Selected pages from the National Mining Association White Paper presented before the Commission on June 17,1998; (2) a letter to Ms. Ruth E. McBurney, Director Division of Licensing, Registration, and Standards, Bureau of Radiation Control, Texas Department of Health from Joseph J. Holonich, dated May 5,1998; (3) the April 1995, DWM " Staff Technical Position on Effluent Disposal at Licensed Uranium Recovery Facilities; and (4) Selected pages from Power Resources December 1,1997 Letter. These documents are included as part of Attachment A. Mr. Ford later provided additional supporting documents for Panel consideration that will be referenced separately.
e Flvron Filenel to Joseph J. Holonich, Chief, Uranium Recovery Branch, DWM/NMSS on November 19,1998 (Attachment B). Dr. Fliegel disagrees with some of the conclusions and recommendations in the addressed the proposed Commission Paper. He concluded that Option 3 of the proposed Commission Paper did not conform with a plain English reading of the definition of 11e.(2) byproduct material and should be rejected.
Following receipt of the first DPV from Mr. Ford, a Panel was established to review it in accordance with NRC Management Directive 10.159," Differing Professional Views and Opinions." The Panel members ware John J. Surmeier, Chairman; Stuart A. Treby; and Duane W. Schmidt. The second DPV was assigned to the existing Panel after agreement by Dr.
Fliegel, and was confirmed in a memorandum from Carl J. Paperiello, Director, Office of Nuclear Material Safety and Safeguards, dated November 27,1998. (Attachment C.)
DPV REPORT 12/21/98 1 l
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II. BACKGROUND Both Mr. Ford's and Dr. Fliegel's DPVs raise a number of complex issues that required considerable research. Attachment D contains a list of the documents reviewed by the Panel, with a synopsis of pertinent information. The following discuenion provides the reader with )
background information relating to the DPVs discussion that follows.
A. In Situ Leach Uranium Extraction-The Effluent Streams At ISL facilities, we often think of two phases of activity -- the production phase and the restoration of groundwater, in the production phase, ISL facilities produce uranium by using injection and production wells to circulate civiant (water containing chemicals), which mobilizes I and transports uranium and other cheraical constituents, through an aquifer. When the water is l pumped to the surf ace, the uranium recovery plant removes the uranium prior to returning the water to the aquifer. When uranium extraction activities in a well field are no longer economically viable, the groundwater quality in the aquifer is restored (restoration phase). The reason for this restoration is that in the process of extracting uranium, the lixiviant dissolves other constituents that remain in the groundwater such as radium, selenium and arsenic.
During the production phase, at ISL facilities, the liquid waste streams originate from (1) the production bleed from the well field, and (2) other aspects of uranium recovery in the plant. The ,
production bleed consists of groundwater extracted from the aquifer during the uranium !
recovery operations in excess of injected water and is used to maintain a net groundwater inflow into the uranium extraction zone. The other liquid waste streams are from such aspects as elution of the urahium from the ion-exchange resins, washing and production of yellowcake, and other miscellaneous sources.
During the restoration phase, the ISL facility may continue to extract and concentrate uranium j through the ion exchange process as long as it remains economical. As a result, some of the l restoration phase effluent wastes may be very similar to those in the production phase. On the i other hand, there are other waste streams unique to restoration techniques such as from f groundwater sweep (in which no water is reinjected into the aquifer) and reverse osmosis. I i
At ISL facilities, management of liquid waste has involved such disposal practices as release to surf ace waters, evaporation from lined impoundments, land application, and deep well injection. l B.11e.(2) Byproduct Material l a
The Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) amended Section lie. of the Atomic Energy Act (AEA) to include specifically as byproduct material" . . the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed 'primarily for its source material content." For purposes of this paper, these tailings or ,
wastes, as defined in Section 11e.(2) of the AEA, will be designated as "11e.(2) byproduct material." l DPV REPORT 12/21/98 2 u
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C. The Effluent Wacte Stream Problem - Where in the Process is 11.e(2) Byproduct Materlai Created?
This questfon of where 11e.(2) byproduct material is created has been a highly controversial issue since at least 1980. This issue has been the concern of industry and the NRC staff. A root cause relates to ditfering interpretations of where in the ISL process extraction or concentration takes place and therefore 11e.(2) byproduct materialis created. There has never been a." definitive" determination that has resolved the controversy. In trying to resolve this issue, NRC staff has modified its guidance practice over the past several years. .in each case, industry has strenuously objected. Staff now is proposing another change in its guidance that is contained in a proposed Commission Paper. The two DPVs express concerns over the direction and recommendations in the Commission Paper. Additional details on this problem are presented in Section D and Attached D of this Report.
D. Historical Perspective The groundwater and effluent release controversy over NRC licensed ISL f acilities goes back to at least 1980 when the Governor of the State of Wyoming questioned NRC's regulatory authority over gruundwater at ISL facilities. The concern by the Governor may have been as a result of: (1) UMTRCA not explicitly mentioning in situ operations; (2) the definition in 10 CFR 40.4 of " byproduct material" that excludes underground ore bodies depleted by solution extraction; and (3) the 1980 "Bevill Amendment" to EPA's Resource Conservation and Recovery Act (RCRA) in which high volume, low-level wastes fre m mining or mineral processing are excluded from the definition of hazardous waste (40 CFR 261.4(b)(7)).
In an April 28,1980 memorandum to Chairman Ahearne from Howa'rd K. Shapar, Executive Legal Director, the Office of the Executive Legal Director (OELD) concluded that under the licensing and regulatory authority found in the AEA, as amended by UMTRCA, the NRC had the authority to protect groundwater at ISL facilities through the imposition of groundwater protection conditions in ISL licenses. (See Attachment E-2.) .
During the next eighteen years, the industry and the affected States--both Agreement and non-Agreements States-have raised concems on this issue. NRC staff first provided policy guidance on effluent release at ISL facilities in 1987 which was reissued in 1993 in the Uranium Recovery Policy and Guidance Directive System, as LLWM-87-01. This NRC staff policy .
reaffirmed the conclusions reached in the 1980 OELD Legal Opinion and stated that the staff may elect, as a matter of regulatory policy, to discharge its responsibility by deferring to a State for regulatory control.
In 1994, Shaw, Pittman, Potts & Trowbridge, on behalf of six companies engaged in ISL uranium operations, requested a review and reversal of NRC's 1980 OELD Legal Opinion that provided the basis for NRC' legal authority to impose license conditions to protect groundwater from contaminants which result from licensed operations connected with ISL extraction of source material. NRC staff responded by stating that the "[p]otential contaminants of groundwater resulting from in situ operations are clearly within the scope of NRC's regulatory control under the Atomic Energy Act, as amended, by UMTRCA." While not included in the DWM response to Shaw, Pittman, Potts & Trowbridge, the OGC staff memorandum used as a basis for the above response made a very cogent observation by noting that "[i)f NRC has no DPV REPORT 12/21/98 3
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' jurisdiction it has no authority to exempt "' The OGC staff memorandum also indicated that the
- submitted legal arguments were not convincing enough to alter the conclusions reached in the 1980 OELD Legal opinion.
In 1995, DWM issued a Staff Technical Position (STP)," Effluent Disposal at Licensed Uranium Recovery Facilities." Among other things the STP differentiated for the first time between how process and restoration effluent wastes at ISL facilities vyere to be regulated. Process wastes ,
were considered those wastes associated with the production phase of operations (with primary purpose being extraction of uranium) in a given wellfield and therefore 11e.(2) byproduct material, while restoration wastes were considered those associated with the restoration phase (with primary purpose being ground water quality restoration) and therefore implicitly not considered 11e.(2) byproduct material. Based on the material the Panel has reviewed, the industry response was that this change in staff position was not helpful. Specifically, it resulted in an increased uncertainty as to how to dispose of waste which now could be commingled process waste (11e.(2) byproduct material) and restoration waste (not 11e.(2) byproduct material).
In 1997, NRC published a Draft Standard Review Plan for in Situ Uranium Extraction License 1
Applications, NUREG-1569, that incorporates an effluent release concept modified from the 1995 STP. Again, it appears as if the ISL industry comments were negative. Power Resources Inc. (PRI), an NRC ISL licensee, stressed in its response the need for an effective and thorough review of this document with input from state and federal agencies, and the ISL industry. PRI further stated that "[t]his SRP has the potential to significantly impact our future expansion plans, and possibly our profitability and viability, if carried forward without the necessary review and input."
In 1998, the National Mining Association (NMA) submitted a White Paper, prepared by Shaw, Pittman, Potts & Trowbridge and the Associate General Counsel of NMA, to the NRC in April 1998. Among other issues, the White Paper devoted over thirty pages to discussing NRC's jurisdiction over ISL f acilities. The White Paper raised questions concerning NRC's current liquid effluent guidance policy (Option 1 in the proposed Commission Paper). The NMA stated that it believed "[a]s a practical matter, NRC staff's misapplication and misuse of the AEA jurisdictional definitions has put ISL licensecs in an awkward position. This is particularly troublesome in the context of handling ISL liquid effluents." The White Paper suggested two other approaches:
(1)"Under one such approach, if NRC continues to assert that ISL mining really is a type of process, then the underground ore body is like the mill at a conventional facility. This means that like a conventional mill, the underground ore body is 11e.(2) byproduct material.
Accordingly, all wastewaterfor the ISL wellfields would be 11e.(2) byproduct material."
(Option 2 in the proposed Commission Paper.)
(2) "However, another approach, and the better reasoned one, is for NRC to agree that it does not have jurisdiction over ISL wellfields until the pregnant lixiviant at a minimum l
' Memorandum from Robert L. Fonner to Joseph J Holonich," Jurisdiction Over Wel! fields at in Situ Uranium Recovery Operations, dated March 30,1994, p. 2. (Reproduced in Attachment E.)
DPV REPORT 12/21/98 4
l reaches the IX but rnore appropriately when it reaches the elution stage at the mill. This would mean that production bleed would be a mining waste, not a processing waste, and would allow this material to be disposed of pursuant to an NPDES permit. Any sludges resulting from these effluent streams would qualify for RCRA's Bevill exclusion. The only 11e.(2) byproduct material under this alternative would be discrete surface wastes from the production of yellowcake after the IX." (Note: This approach may be considered similar to Option 3 in the proposed Commission Paper; however, the White Paper implies that the NRC agree that it does not have jurisdiction. The Commission Paper states that NRC can defer its authority to others (EPA or EPA's Primacy States), thus affirming that NRC does have jurisdiction over all groundwater at ISL sites.)
lli. DPV SUMMARIES A. William Ford's DPV ( ttachment A)
Mr. Ford's DPV discussed the reasons why all liquid effluent from in situ leach uranium extraction facilities should be considered as 11e.(2) byproduct material as was done by the NRC staff from at least the early 1980's up until this policy was changed by the Division of Waste Management (DWM) in its April,1995 " Staff Technical Position on Effluent Disposal at Licensed Uranium Recovery Facilities"(hereafter referred to as the 1995 STP). Second, Mr.
Ford presents arguments to support the reasons he is opposed to the current staff practice (using the 1995 STP) whereby some liquid effluent releases are regulated by the NRC while some are not. Finally, the DPV argues against the proposed staff alternative policy (Option 3 in j
the proposed Commission Paper) in which NRC would relinquish all regulatory authority over liquid effluent releases including both " production bleed" and ground water restoration waste waters. ,
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Mr. Ford believes that the current staff practice (1995 STP) and the proposed altemative (Option 3 in the proposed Commission Paper) create great uncen tinty for all parties. These options open up potential litigation and would require licensees and the NRC to spend increased resources caused by disagreements over regulatory authority and locating acceptable waste disposal sites. He further argues that these two alternatives also (1) weaken NRC authority over the regulation of 11e.(2) byproduct material sites in general including conventional uranium mills and (2) sncourage State govemments to extend their regulatory control to 11e.(2) byproduct disposal sites.
Mr. Ford, in his cover memorandum to the DPV, indicated that he was aware that the staff was preparing a Commission Paper recommending that NRC remove itself from the review of groundwater protection at in situ leach facility by relying on the Environmental Protection Agency's Underground injection Control (UlC) Program. He does not object to this proposed action; however, his professional view on liquid effluents would be the same whether or not the NRC relied'on EPA's UIC Program.
B. Myron Fliegel's DPV (Attachment B)
Dr. Fliegel's DPV addresses Option 3 in the proposed Commission Paper entitled:
" Recommendations on Ways to improve the Efficiency of NRC Regulations at In Situ Leach Uranium Recovery Facilities". Among other things, Option 3 proposes to treat " production DPV REPORT 12/21/98 5
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bleed" at in situ leacn facilities as non 11e.2 byproduct material. (in order to maintain a net inward pressure in the aquifer that is being worked, more water is extracted than is reinjected back into the aquifer. The excess water that is not reinjected is waste water called " production bleed.") Dr. Fliegel believes that the third option is inconsistent with a plain English reading of the definition of 11e.(2) byproduct material. He believes that it is clear that there is concentration of uranium at the ion exchange stage and that tne production bleed is, therefore, 11e.(2) byproduct material. He further believes that one cannot make a distinction between the waste stream resulting after the elution stage (washing and production of the yellowcake) and the waste stream consisting of the production bleed produced at the ion exchange stage.
IV.
SUMMARY
OF ISSUES REVIEWED BY THE DPV PANEL l I
The Panel reviewed the material discussed cited above as well as the documents listed in j Attachment D. The Panel held discussions with Mr. Ford, Dr. Fliegel, and Mr. Joseph Holonich,
' Acting Deputy Director, NMSS/DWM. A summary of the key issues reviewed and the Panel's ;
findings are presented below.
A. Definition of 11e.(2) Byproduct Materials As noted above, section 11.e(2) of the AEA, defined " byproduct material" to include " . . . the !
tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content." In developing the implementing regulations of 10 CFR 40, the Commission modified the definition slightly, to specifically include ,
surface wastes from ISL facilities while excluding the depleted underground ore body: " . . . the !
tailings or wastes produced by the extraction of uranium or thorium from any ore processed primarily for its source material content, including discrete surface wastes resulting from uranium solution extraction processes. Underground ore bodies depleted by such solution extraction operations do not constitute ' byproduct material' within this definition." For uranium ;
ISL facilities, important aspects of the definition of 11e.(2) byproduct material are that (1) the l' material must be a waste, (2) the waste is produced during the process of extraction or concentration of uranium, and (3) the extraction or concentration is from ore that is processed primarily for its source material (uranium) content.
In contrast to " source material," the Commission has not established through rulemaking any lower (bounding) limit or de minimis concentration for 11.e(2) byproduct material, below which the material would no longer be considered 11e.(2) byproduct material. Thus, the dilution of 11e.(2) byproduct material with water or other liquids would not in and by itself make it non-11e.(2) byproduct material.
B. Classification of the Waste Streams Cetermination of where in the ISL process " extraction or concentration of uranium" occurs, and the resulting waste stream, is central to the issues raised in the DPVs.
DPV REPORT 12/21/98 6
Production Bleed Waste Stream Both Mr. Ford and Dr. Fliegel argue in their DPV's that the " production bleN" waste stream is integral to the process for the extraction of uranium. In Options 1 and 2 of the proposed Commission Paper, the staff classifies the " production bleed" as 11e.(2) byproduct material.
This is consistent with a determination that the production bleed is a waste water stream that is diverted after the ion exchange columns. Uranium is clearly concentrated (and could be considered extracted) in the ion exchange resin, so production bleed is a waste resulting from the concentration of uranium.
However, in the recommended Option 3, staff proposes the NRC should no longer classify the ,
production bleed as 11.e(2) byproduct material
. . . since it is a waste that is generated as part of ensuring protection of ground water and not as a result of extracting uranium. Production bleed, instead, would be reclassified as a 'mine wastewater.'"(See page 6 of the 12/16/98.)
No information is provided in the proposed Commission Paper for concluding that the activity of
" concentration or extraction of uranium" is moved from the ion exchange columns to the elution stage. In addition, industry information (not included in the proposed Commission Paper) indicates that the production bleed also serves a production purpose, and is useful toward the '
extraction of uranium, in the Power Resources, Inc. amendment application for its Gas Hill Project (Chapter 3, page 3-50, dated June 1998) the following statement is made concerning the production or "wellfield" bleed. l "The ISL process is operated as a closed system, with the total injection rate to the wellfield maintained below the total production rate from the wellfield. The water which is removed is referred to as bleed or purge. The bleed performs two functions in the well field operation:
"1. Prevents an unwanted build-up of anions which compete with uranium for ion exchange sites and must be removed during ground water restoration; and "2. Creates a hydrologic cone of depression within the mined zone which prevents the unwanted migration of fixiviant away from the mining area.
"The bleed will be removed from the closed system after the lixiviant passes through the ion exchange system for uranium removal." (Bold face added for emphasis.]
The NMA in its White Paper also indicates that this bleed " brings fresh water into the mining zone to inhibit the build up of contaminants'that could reduce the efficiency of the mining operation. 2 2 " Recommendations for a Coordinated Approach to Regulating the Uranium Recovery industry: A White Paper" presented by the National Mining Association, dated April 22,1988, p.102._
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l While Mr. Ford in his DPV did not address Dr. Fliegel's concerns, he raised a number of issues {
concerning the potential adverse impact that excluding the production bleed from NRC regulation (Option 3 of the proposed Commission Paper) could have on NRC, the industry and States.
FINDING: In the proposed Commission Paper, the staff asserts that the production bleed only !
serves the purpose of protecting groundwater and therefore can be classified as mine waste water. Contrary to this view, the. additional industry information indicates that the production bleed also aids in the concentration of the uranium at the ion exchange columns. Dr. Fliegel shares this view that concentration of uranium occurs at the ion exchange columns. Since these points are not directly addressed, additional justification for classifying this waste stream as non-11e.(2) byproduct material appears to be warranted in the Commission Paper. .
l In addition, Mr. Ford has raised arguments pointing out the disadvantages of the i staff's recommended approach in Option 3. His DPV raises reasonable arguments for consideration by senior management and should be addressed in any rulemaking to clarify regulation of ISL uranium extraction activities. ,
t Groundwater Restoration Waste Stream The DPVs (particularly Mr. Ford) raise arguments that the groundwater restoration waste ;
streams should be 11e(2) byproduct materials contrary to the DWM Staff Technical Position. j One argument, discussed by Dr. Fliegel as reasonable, is that ground water restoration wastes {
are 11e.(2) byproduct material if one considers the ICL facility as an entity with the sole purpose !
of producing uranium from ore. As such, any waste produced from that facility, at any time in the life cycle of the facility, can be viewed as waste produced by the extraction or concentration ,
of uranium, since there was no other purpose for the facility. Using this argument, ground l water restoration is a necessary step in the process to extract uranium from ore and wastes l produced in this step therefore meet the definition of 110.(2) byproduct material.
The ISL operation is almost a closed-loop process. After teaching with the lixiviant the underground ore body is processed ore. The pregnant lixiviant (containing uranium) is brought to the surface, where it is passed through an ion-exchange system to remove the uranium; then I the barren lixiviant is reinjected (possibly with additional fresh lixiviant) into the ore body where {
the uranium is again dissolved. It can be argued that the lixiviant reinjected last contains wastes produced from the extraction in the ion-exchange system and thus would be by definition 11e.(2) byproduct material. As result, after the process circuit ceases operation, the l contaminated ground water would be 11e.(2) byproduct material. It could then be argued that :
I all wastes from ground water restoration from that point on would also be 11e.(2) byproduct material, and would be under the jurisdiction of UMTRCA, EPA standards, and NRC regulations, j Another argument that ground water restoration wastes are 11e.(2) byproduct material is that running lixiviant through an ore body is processing which extracts uranium from the ore body into the process water (lixiviant). Thus, any waste produced, including the contaminated ground water, would be considered 11e.(2) byproduct material.
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I l A fourth argument, that ground water restoration wastes are 11e.(2) byproduct material, is that l only the depleted ore body is specifically excluded from the definition of byproduct materialin the regulation (10 CFR 40.4). The contaminated ground water is not excluded from the definition of byproduct material, and so should be considered to be included as byproduct l material.
Mr. Ford in his DPV identifies a series of arguments against the current DWM Technical Position (Option 1 in the proposed Commission Paper). Some of the principal ones are:
- 1) Defining groundwater undergoing restoration as non-11e(2) byproduct material, has the potential to weaken NRC regulatory authority over liquid, air, and solid emissions from 11e.(2) facilities and the decommissioning and cleanup of those facilities; 2) Current staff practice will create disagreements between licensees, the NRC, and the public, over what the NRC regulates; 3) State governments may be encouraged to regulate 11e.(2) disposal facility since the material would be commingled radioactive and chemical waste; 4) Health, safety, and environmental risks will be increased by encouraging onsite disposal and the creation of many small disposal sites of radioactive material; and 5) Current staff practice will make it very difficult for some licensecs to locate disposal sites that will accept contaminated material. In his
.DPV, Mr. Ford identifies a series of arguments in favor of returning to the pre-1995 NRC staff policy of treating all waste streams as 110.(2) byproduct material (Option 2 of the proposed Commission Paper).
FINDING: The DPVs raise reasonable arguments for consideration by senior management and should be addressed in any future rulemaking to clarify regulation of ISL uranium extraction activities.
V. PANEL RECOMMENDATIONS Pursuant to Management Directive 10.159, the Panet has restricted its recommendations to only those concerns raised either in the DPVs or follow up discussions with Mr. Ford and Dr.
Fliegel.'
- 1. The proposed Commission Paper needs to be reviewed and potentially revised to address the findings made above.
- 2. Senior management needs to give consideration to the arguments made in the DPVs in any future rulemaking to clarify NRC's regulation of ISL uranium extraction activities.
- 3. Senior management needs to reevaluate whether the current practice (Option 1 in the Commission Paper) should be continued upon consideration of the arguments in Mr.
Ford's DPV.
8 Given the 18-year history and the Panel's review of this complex issue, the Panel suggests that consideration be given to developing legislation to clarify how ISL uranium extraction activities and the resulting waste should be regulated.
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..y..;
Differing Professional View Panel Report Concerning Handling of {
Liquid Effluent Releases from In Situ Leach {
l Operations at Licensed Uranium. Recovery Facilities !
l ATTACHMENT A WILLIAM H. FORD'S DIFFERING PROFESSIONAL VIEW CONCERNING NUCLEAR REGULATORY COMMISSION '
REGULATION OF LIQUID EFFLUENTS FROM IN SITU LEACH URANIUM EXTRACTION FACILITIES DATED' OCTOBER 20,1998 s\t y.