ML20209F453
| ML20209F453 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1995 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20209F412 | List: |
| References | |
| 99-950430, NUDOCS 9907160025 | |
| Download: ML20209F453 (16) | |
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Staff Technical Position on Effluent Disposal at Licensed Uranium Recovery Facilities i
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Division of Waste Management U. S. Nuc. lear Regulatory Comission April, 1995 l
-REVISI ON 0 9907160025 990712 PDR ORO NOMA PDR- a
Staff Technical Position on Effluent Disposal at Licensed Uranium Recovery Facilities
Background
NRC-licensed uranium recovery facilities, including milling and in situ leach (ISL) facilities, generate liquid wastes (i.e., effluent) that require proper disposal. At uranium mills, effluent may include contaminated water recovered from ground-water corrective action programs and tailings dewatering activities, and tailings liquor that must be extracted and properly disposed of before surface site reclamation can proceed.
At ISL facilities, effluent 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 streams involving the host aquifer include production bleed and ground-water 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 ground-water inflow into the recovery zone and minimi7e or eliminate the migration of lixiviant and dissolved uranium outside the recovery zone. Ground-water sweep is ground water extracted at the end of a uranium recovery operation primarily to restore ground-water quality in the recovery zone. Liquid waste streams originating at the main uranium recovery plant include wastewater from yellowcake processing and reject brine from reverse osmosis treatment of contaminated water. ,
l Evaporation has generally been used for management of liquid waste at licensed uranium mills and mill tailings disposal sites. This practice involves discharging liquid waste in one or more on-site lined evaporation ponds where l the water is lost to the atmosphere by surface evaporation and other evaporation enhancement systems, and the remaining sludge is placed in a licensed tailings disposal facility. At ISL facilities, management of liquid waste has generally involved such disposal practices as release to surface i waters, on-site land applications including on-site irrigation, and injection in deep wells. ,
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Purpose and Applicability This Staff Technical Position (STP) provides guidance and discusses the technical and regulatory basis for review and evaluation of proposals for disposal of liquid waste at licensed uranium recovery f acilities. The STP is '
primarily intended to guide NRC staff reviews of site-specific proposals for disposal of liquid waste at uranium mills and ISL facilities. The STP can also be used for preparation of proposals for liquid waste disposal by uranium recovery licensees and applicants.
This STP is applicable to both licensed and new facilities. Previously REVISIdN0
approved limits at licensed sites that may not conform to the applicable regulations can be changed by a site-specific license amendment.
Applicable Regulation and Standards In general, applications and proposals for disposal of liquid waste at licensed uranium recovery facilities must comply with the regulations in Appendix A to 10 CFR Part 40, and Subparts K and 0, 10 CFR Part 20, as applicable depending on the proposed disposal procedure. All terms and
-characterizations in this STP 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 construction, maintenance, and operation of surface impoundments that.are used for disposal of liquid waste or waste containing free liquids (Criteria SA(1) through SA(5)); installation of 1.iners (Criterion SE): and seepage control (Criterion SF). Appendix A also includes other generally applicable provisions, including in particular site-specific ground-water protection standards for both radioactive and non-radioactive hazardous constituents (Criteria 5B and SC); corrective action programs (Criterion 50):
ground-water monitoring requirements (Criterica 7); and closure requirements (Criterion 6).
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 EPA regulations in 40 CFR Part 440c " Ore Mining and Dressing Point Source Category: Ef fluent Limitations Guidelines and New Source Performance 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 uranium mining and milling facilities by release in surface' waters.
Byproduct material disposal under Part 20 requires compliance with the applicable regulations in 10 CFR Part 20, Subpart K (620.2001, s20.2002 and ,
620'.2007), and Subpart 0 (520.1301 and %20.1302). Subpart K offers provisions l l
for byproduct material disposal by " release in effluents" (620.2001), or other disposal methods proposed by the licensee (620,2002). Among other requirements, the provisions in $20.2001 and 620.2002 require compliance with the radiation dose limits for individual members of the public in 520.1301, and a demonstration of compliance with these limits as provided in %20.1302.
The dose l'imits in %20.1301 include the total effective dose equivalent to individual members of the public (0.1 rem / year), as well as the dose in any unrestricted area from external sources in any one hour (0.002 rem in any one hour) (520.1301 (a) and (b)). In addition, the regulations allow a licensee to apply for Commission authorization in advance to operate up to an annual dose limit for an individual member of the public (0.5 rem), 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 520.1301 (c) (1), (2), and (3'). The o
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I regulations.also require (in 520.1301 (d)) that licensees who are subject to the provisions of U.S. Environmental Protection Agency's (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 effluents in order to restrict the collective dose at a particular site (620.1301 (e)).
In order to' demonstrate compliance with the dose limits for individual members of the public in 620.1301, licensees and applicants must do so according to the provisions of 520.1302, 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; and, (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 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 B to $20.1001-520.2401 and that the dose from external sources to a continuously exposed individual would not exceed the established standard (0.002 rem / hour and 0.05 rem in a year).
The provisions of $20.1302 also allow licensees, upon approval by the Commission, to adjust the effluent concentration values in Table 2 of Appendix B to $20.1001-520.2401 for members of the public to take account of the actual characteristics of effluent that will be released (520.1302 (c)).
The provisions in.520.2007 require that licensees and applicants must also comply with other applicable federal, state, and local environmental and health protection regulations governing any other toxic or hazardous properties of licenseo materials disposed of under Part 20, Subpart K.
In addition to the above r=quirements, licensees and applicants considering disposal of licensed materials under the provisions of either 520.2001 or 520.2002 are further required to comply with NRC's regulatory provbions for decommissioning of licensed facilities, prior to facility closure od license termination. These provisions include the interim cleanup crited i presently in use, and those specified in the final rule when the final rule is promulgated (the proposed radiological criteria for decomissioning are provided in the proposed rule in 10 CFR Part 20, Subpart E: 520.1401 through
. 520.1405, fE Vol 59, No. 161, page 43228, dated August 22, 1994).
Proposal Review and Evaluation Criteria l In general, licensees of uranium recovery facilities are required to submit proposals for disposal of liquid waste, and obtain NRC's approval of the REVISION O 3
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proposed procedures. Proposals will be approved on a u te-specific basis by NRC staff based on demonstrated compliance with all of the applicable regulations.
Proposal review and evaluation criteria that will be used by the staf f are discussed in the following paragraphs fo_r four disposal procedures that have Deen in practice or proposed at licensed uranium recovery facilities. These include: on-site evaporation; release in surface waters; on-site land applications; and injection in deep wells.
On-Site Evaooration i'
) in accordance with Appendix A, 10 CFR Part 40, proposals ror on-site 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 ground-water protection standards and monit3 ring requirements are adequately established to detect any migration af contaminants to the ground water and to implement corrective action to restore ground-water quality if and when necessary as required by the regulations.
l Evaporation pond systems will be approved if they comply with the regulatory requirements in Appendix A. 10 CFR Part 40. These mainly include the design provisions for surface impoundments (Criteria SA(1) through 5A(5)); In installation of liners (Criterion SE); and secpage control (Criterion 5F).
addition. evaporation ponds must also meet other generally applicable regulatory provisions .in Appendix A, including in particular the site-specific ground-water protection standards (Criteria SB and SC); corrective action programs (Criterion 50); ground-water 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 of 620.2001 and s20.2007, and the provisions of 40 CFR Part 440 as required by Criterion 8 of Appendix A to 10 CFR Part 40. as applicable based on site-specific conditions.
Specifically, release in surface waters must meet the regulatory provisions in
$20.2001 (a)(3), which requires that licensees comply with the dose limits for individual members of the public in 620.1301. In order to demonstrate compliance *with the dose limits:for individual members of the public in
%20.1301, licensees and applicants must do so according to the provisions of
$20.1302 (The provisions of 620.1301 and %20.1302 have already been discussed under Aoplicable Regulations).
Licensees and applicants must also comply with other applicable federal, state, and local environmental and health protection regulations gcVerning any other toxic or hazardous properties of licensed materials disposed of under Part 20 Subpart K, pursuant to the provisions in,620.2007.
4 REVISION _0
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 l regulations' provide technology-based effluent limitations for existing point I sources, in 6440.32 and E440.33) and new source performance standards (NSPS). !
in 5440.34, promulgated by EPA under t*e Clean Water Act. Licensees must demonstrate compliance with these EPA regulations and standards. as applicable, including the obtaining of a National Pollutant Discharge Elimination System (NPDES) permit issued or approved by the EPA.
The regulatory provisions and requirements for release of liquid waste under a NPDES permit are outside the scope of this technical position; however, specific effluent limitations and standards in 40 CFR Part 440 (6440.30 through 9440.34) that are applicable to discharges from mills and ISL uranium recovery facilities are provided and briefly discussed in an appendix to this STP.
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W As indicated in the appendix, 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 include!, production bleed or ground water e" racted from the aquifer during the u-anium recover; operation, and liquid waste generated at the main uranium ;
recovery plant. "Mine wastewater" is wastewater from post-operation ground water sweep, or ground water extracted to restore water quality in the recovery zone after a uranium recovery operation is stopped.
NPDES effluent limitations in 40 CFR 440 that are applicable to NRC licensed facilities are provided in the appendix in Tables Al and A2. The effluent limitations in Table Al are applicable to mills, including " process wastewater" from ISL facilities. The effluent limitations in Table A2 are applicable to mines, including "mine wastewater" from ISL facilities.
Staff notes that NRC's ISL licensees must comply with the NPDES effl.uent 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 Part 20. However, there is no such standard 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 f20.1301 and other requirements to satisfy the provisions in Subpart K). Moreover, the NPDES effluent limitations for certain non-radioactive 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 emand or C00 in Tables Al and Table A2, for example). 4 Therefore, ISL licensees proposing to dispose of byproduct material by release in effluents may need to satisfy different standards, depending on whether the disposal involves releasing a " process wastewater" or a "mine wastewater."
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 released in surface waters have REVISIdN 0 5
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two alternative options to satisfy the regulations. Under the first option a
' licensee would monitor the incoming wastewater by source and meet the corresponding effluent limitations separately for " process wastewater" and "mine wastcwater" at their respective paints of discharge into the interim storage facility. If both input streams were within the appropriate effluent release limits, the licensee would be free to release the wastewater from the storage facility. In the second option. a licensee would not monitor the input st' reams, 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 compiv 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).
i Land Apolications including Proposals for disposal of liqu'id waste by on-site land applications irrigation, will be approved under the provisions of s20,2002. 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 nature and location of other potentially affected facilities; and analyses and procedures to ensure that dose's are maintained As low As Reasonably Achievable (ALARA) '
and within the dose limits in Part 20 (i .e.. (20.1301) .
Proposals must analyze and assess projected concentrations of radioactive i contaminants in the soil; projected impacts on ground-water and surface water quality, and on land uses including particularly crops and vegetation; and projected exposures ar.d health risks that may be associated with radioactive constituents reaching the food chain to verify that the projected doses It is and expected risks conforming to the risk levels permitted under Part 20.
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 that can be implemented in the event that the projected levels are exceeded.
In addition to the radiation dose, it may also be necessary in some cases to l conduct analyses to assess the chemical toxicity of radioactive and non- I radioactive constituents in order to evaluate the health risks associated with land applications involving irrigation at particular sites, in compliance with other applicable Federal, State, and local environmental and healthStaffprotection will work regulations that must also-be satisfied pursuant to s20.2007.
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 6
REVISf0N 0 I
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systems l'ncluding temporary surface storage' facilities, proposals must ;
demonstrate that contaminants will not be returned to the ground water and cause exceedence of any site-specific ground-water protection standards that are established pursuant to Appendix A of 10 CFR Part 40.
Licensees and applicants disposina effluent by on-site land applications are {
further required to comply with NRC's regulatory provisions for j decommi'ssioning, prior to facility closure and license termination 1 I
(decommissioning requirements have already been discussed under Applicable Regulations and Standards).
i Deco-Well Iniection Proposals for disposal of liquid waste by injection in deep wells must treet the regulatory provisions in 920.2002. Specifically, 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 analys. and evaluation of pertinent information on the nature of the environt..ent: information on the nature and location of other potentially affected facilities; and analyses and procedures to ensure that doses are AtARA, and within the osse limits in Part 20 (i.e..
620.1301).
Proposals must also demonstrate that the injection zone is confined, that it is not a drinking water source and that the injected contaminants will not cause exceedence of any established site-specific ground-water 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, proposals may include provisions for periodic ground-water monitoring in the vicinity of the injection well to )
verify that drinking water zones are free from cross contamination, and a remediation plan that can be implerinted in the event that unacceptable levels of contamination are detected.
In addition, pursuant to the provisions of 920.2007, proposals for disposal by injection in deep wells must also meet any other applicable Federal, State, and local government regulations pertaining to deep well injection, and obtain any necessary permits for this purpose. In particular, proposals must satisfy' the EPA's 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 provisions, in general, proposals that satisfy the EPA regulations under the UIC program will be approved by NRC staff. ,
licensees and applicants disposing effluent by injection in deep wells are further required to comply with NRC's regulatory provisions fer j
' decommissioning, prior to facility closure and license termination (decommissioning requirements have already been discussed under Applicable i i
_ Regulations and Standards).
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REVISION 0 I
f Accendix Summary Effluent Limitations and Standards Applicable to NRC Licensed Facilities in 40 CFR Part 440: " Ore Mining and Dressing Point Source Category.
Subpart C. Uranium. Radium and Vanadium Ores Subcategory" Since the NRC does not regulate conventional mining, the effluent 11mit:tions 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 summary.
There is a distinction in 40 CFR Part 440 Subpart C between " process wastewater" and "mine wastewater" with respect to in situ leach (ISL) facilities (see 40 CFR Part 440, Subpart L, and 47 ER 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 operation, and liquid waste generated at-the main uranium recovery plant. "Mine wastewater" is wastewater from post-
. operation ground water sweep, or ground water extracted to restore water quality in the recovery zone after a uranium recovery operation is stopped.
Effluent limitations in 40 CFR 440 that are applicable to NRC licensed facilities are provided in Tables Al and A2. The effluent limitaticns in Table Al are applicable to mills, including " process wastewater" from ISL
[ currently available facilities. Effluents from existing mills, including " process wastewater" from existing ISL facilities, applying the best practicable control technology provided in Table Al.
The effluent limitations in Table A2 are applicable to mines, including "mine wastewater" from ISL facilities. Existing mines, including "mine wastewater" from ISL facilities, applying the best available technology economically achievable (BAT) shall not exce'ed the attainable ef fluent limitations provided in Table A2.
In addition to the above, the new source' performance standards (40 CFR Part 6440.34(b)) stipulate that for new sources there shall be no discharge of process wastewater to navigable waters from mills using the acid leach, alkaline leach or combined acid and alkaline leach process for the extraction I of uranium or from mines and mills using ISL methods. These regulations further stipulate that in the event that the annual precipitation falling on
' Pursuant to the definition of "new sources" in 40 CFR 122.2, "new" uranium j recovery facilities as they pertain to the regulations in 40 CFR Part 440 are those the construction of which commenced after December 3,1982, which is the date when the effluent standards relevant to uranium recovery were first issued.
" Existing' facilities are those the construction of which commenced before December 3, 1982.
REVISION 0 A-1 i
the treatment facility and the drainage area contributing surface runoff to the treatment facility exceeds the annual cvaporation, a volume of water
. equivalent to the difference between there two values may be discharged subject to the limitations set forth abuve.
In that the effluent limitations and standards in 40 CFR Part 440 are based on technology-based treatment requirements, effluent limitations and standards at specific sites will be imposed based on approved treatment technology on a site-specific basis by the EPA. Treatment technology would be approved for specific. site 2 sed on the regulatory provisions in 40 CFR Part 125: Criteria and Standards the National Pollutant Discharge Elimination System; Subpart A: Criteria an ;andards for Imposing Technology Based Treatment Requirements Under Sections J1 (b) and 402 of the Act (i.e. Clean Water Act) (40 CFR Part 125, $125.1- through 5125.3).
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REVISIO(0 A-2
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Table Al Effluent Limitations Representing the Degree of Effluent Reduction Attainable by the Application of BPT Technology (Applicable to existing mills, including " process wastewater" from )
in situ leach facilities)
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(Source: 40 CFR Part 440. s440.32(b))
Effluent Limitations Effluent Characteristic Maximum Average of Daily Values for any One Day for 30 Consecutive Days TSS (mg/l) 30 20 C0D (mg/1) --- 500 As (mg/1) 1.0 0.5 Zn (mg/1) 1.0 0.5 Ra226 (dissolved): pCi/l 10 3 Ra226 (total): pCi/l 30 10 NH 3 (mg/l) --- 100 pH 6.0-9.0 6.0-9.0
' Table A2 Effluent limitations Representing the Degree of Effluent Reduction Attainable by the Application of BAT Technology (Applicable to existing mines, including "mine wastewater" from l in situ leach facilities) i (Source: 40 CFR Part 440, 6440.33(a))
Effluent Limitations ;
Effluent Characteristic e of Daily Values for any One Day for 30 Consecutive Days C0D (mg/1) 200 100 Zn (mg/l) 1.0 0.5 ,
3 Ra226 (dissolved); pCi/1 10 l 10 f Ra226 (total), pCi/l 30 ,
2 U (mg/l) 4 VISION O A-3
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Attachment.D Selected Pages From Power Resources December 1,1997 Letter (Relevant Text Marked)
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- . RESOURCES let 30 .4 :.:0M fn 30~.234.:14-December 1.1997 I l q
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Chief. Rules and Directives U.S. Nuclear Regulatory Commission, g l Washington, D.C.
20555
Dear Sir or Stadam:
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Subject:
Comments On The Draft Standard Review Plan Forin Situ Uranium Extraction )
Applications. NUREG-1569
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Please find attached Power Resources Inc.. (PRD comments on the f Uranium Extraction License Applications. PRJ is a major ISL uranium producer. prod one million pounds L',0, per year for domestic and foreign electrical utilities.
f We Wittrup.
are disappointed that a ninety day extension of the revie l document should be shelved and the process started from the beginning with adequate{
input. The document incorporates none of the previousd input his time.from the industry, al this document finalized, we feel doubtful that any of our comments will be addresse t )
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As an m situ uranium producer. we cannot stress enough the importance i SRP has of an effecj review of this document with input from state and federal agencies, and the ISL industry. lT fi bility and the potential to significantly impact our future expansion plans, and possibly our pro ta /
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viability,if carried forward without the necessary review and input. l l
Sin rely. -
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,NV i NtarkiWittrup. NtSc.. P. Enc. l Director. Ens ironment and Safets l
l Nt. Loomis. WNtA N1. Chalmers l cc:
K. Sweenev. NMA P. Hildenbrand l W. Kearney J. Holonich'NRR Mhmitt 6 I
% M9 Daap 3p , ,g j
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e PRi t. , mmems on WREG lM %nember W
\1 H Nitrup and P R thldenerand The uranium signi6 cant tiaws and inconsistencies that should be addressed by NRC.
mdustry was told at that time that the efDuent disposal document was to be reevaluated December 1996 and that industry's comments would be addressed at that time. Comparing the1995 guidance document with Appendix D of the draft SRP elearly shows that the Jocument has not been reevaluated as pmmised nor hase any of the uranium industr.Cs concems been addressed. Appendix D of the SRP should be res tsed to address industrv's concems. Comments provided to NRC by Power Resources. Inc. in October.1995 can be found as Attachment A to this document.
In Situ Leach Facility
- 39. Appendix E, Recommended Outline for Site-Specific Same as Reclamation and Stabilization Cost Estimates. Pages E-1 through E-5:
Comment 33 above.
Comments to the NRC Regarding Effluent Disposal at Licensed Attachment A:
Uranium Recoverv Facilities i I
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BACKGROD:D )
1.
The STP states that reverse osmosis (RO) reject brine is a liquid waste from the This is not true. RO is used during ground water processing of yellowcake.
restoration as a tool to assist in retuming the affected ground water to its pre-min condition. The RO reject brine is a waste connected with ground water restoratio rather than yellowcake processing.
2.
The STP states that evaporation is used for management ofliquid wastes at li uranium mills and tailings disposal sites. This is not true. Liquid wastes from conventional mills are sent to the tailings disposal facility along wiJ., ta solid wastes. The only time evaporation may be used is during decommissioning w ground water from under the tailings disposal site may be pumped to ponds as part of a Corrective Action Plan to mitigate a ground water c plume.
The STP states that management ofliquid wastes at ISL sites includes relea surface waters. This is generally only true for ground water restoration Gu EP A. SPDES regulations prohibit surface discharge of process waste wal E3.
facilities. However. PRI believes that the in situ mining tiuids are indeed min water, not process waste water and should be eligible for NPDES surfa This opinion is apparently inconsistent with EPNs interpretation which Page 10 of 15 i
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1 m c.-na ..m a n ,. , %, mw v
\114 % dtruti anJ P R ibiderana the mming fluids to be proce3s tluids.
APPIICABl.E RtlES AND REGt'LATIONS i
- 1. The first part of this section t page :) states that disposal ofliquid u aste must comply with 10 CFR 40. Appendix A requirements includine the closureidecommissioningi j
requirements of Criterion 6. The last paragraph of this section t page D 3 tate ; that.
in addition. licensees will also be required to comply w ith NRC regulatory prousions l j
for decommissioning and closure and references the proposed rule at IO CFR j
20.1401 through 20.1405. These two statements are contradictory since the unrestricted re! ease criteria for soil radium concentration in Criterion 6 of 10 CFR l
- 40. Appent is 515 pC: gram while the proposed criteria in 10 CFR 20.1404 ha3 a 15 mrer~ TEDE requirement w hich. for radium. is equivalent 10 0.1 pCi gram.
The lang 'the STP mdicates that Licensees will have to meet both criteria which is possible to accomplish. Additional clarification should be provided.
- 2. Proposed 10 CFR 20.1401 states that as applied to uranium mills, the proposed decommissioning criteria would apply only to decommissioning of the facility and not to the disposal of tailings or soil cleanup which is to be performed in accordance I
with 10 CFR 40. Appendix A. Historically. the SRC has required ISL's to comply with the Appendix A requirements for soil cleanup. Does the term " uranium mills '
of the proposed 10 CFR 20.1401 include ISL facilities in this sense as it does in .
Appendix A of Part 407 I
ON-SITE EV APORATION The 1.
This section appears to confuse tailings cells with evaporation ponds.
requirements of 10 CFR 40. Appendix A apply to impoundments that are designe to dispose of ";.'.i and solid wastes resulting from uranium or thorium milline operations. or mill tailings. Evaporation ponds are designed to contain ground wate or other liquid effluents with relatively small quantities of suspended and dissolved solids. Therefore. the design criteria in Appendix A are not appropriate for i evaporation ponds. 1 2.
This section also states that evaporation ponds must comply with the closure standards of Criterion 6 in 10 CFR 40. Appendix A. Criterion 6 specifies that the waste disposal area must i'e closed by placing an earthen cover over the waste material tie.. buried in place). Historically. the SRC has required that evaporation ponds be excavated and disposed at a taihnes facility or other disposal fac lic~ensed by the NRC to accept by-product material. Does the language in the S '
represent a chance of NRC policy regardine decommissioning of evapora I Pacei)of 15 f
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1 3 s Attachment E 40 CFR 440.34 (Relevant Text Marked)
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f Environmental Protection Agency 5 Am34 mines using in-situ leach methods shall that produce uranium ore, including mines using in-situ leach methods.
not exceed:
shall not exceed:
E w ci m Emuent umweans himum caov var a,,, g. gi Emuent ena actenste him mu wy var lor any i ves im 30 Emuent cnaracionstic oay conseCW" is any 1 was for 30 hvo cays oay consecu-tve says Mis. grams per hte 30 20 TSS ... . . . . .
200 100 200 100 COD .
COD - -. t0 0$ 1 00 5 In...................... In . . .
30 10 3 10 0 Ra226
- tessoaved) .. . 4.... Ra226
- icissohred) .
30 10 30 0 to 0 Ra226 ' (totan .. Ra226 ' (totan
- 'O 20 p ,,' U h"L muse m _s ,,e. .,
w- -so--ca
- wahin the range s.0 to s 0 5440.34 New source performance (b) The concentrations of pollutants standards (NSPS).
discharged from mills using the acid Except et provided in Subpart L of leach, alkaline teach or combined acid this part in v new source subject to this and alkaline leach process for the ex- subpart .m t achieve the following traction of uranium, radium and vana- .N SPS representing the derree of efflu-dium including mill-mine facilities and ent reduction attainable by the appli-mines using in-situ leach methods shall cation of the best available dem-not exceed: onstrated technology (BADT):
Emuene hmdacons (a) The concentration of pollutants discharged in mine drainage from mimum daay var mines, etther open-pit or underground, Emuena charsciensac
'*g'1 Q30 thatmines produce uranium ore, excluding using in situ lea':h methods.
eve oa,s shall not exceed:
EfGuent hmnatiDns 30 20 TsS .
$o0 fa u coo . g 3 Emuent enaracteretc mimum mr lor 30 com y any I saw Zn..e.....,....... ....
1 00 $ seceve cays 10 3 Ra226' toissowed) - . , . _ . . .
30 g,g,,,,,,,,,,,
200 100 coo. 14 0$
Walues m sacocunes ras ever (pCdII. Zn.......... . . . . . .
30 Ra '226 tensosved) 10 0 a mihm the range 6.0 to 9 0- 10 0 Ra ' 226 (tota 0 .. 30 0 a.0 20 6440.33 Emuent limitations represent- upa . F1 (' >
ing the degree of emuent redaction iss . 30 0 20 4 attainable by the application of the best available technology eennomi- +v m picacunesp.i.w mc w
'wam the range 6 0 to o O
' cally achievable (BAT).
Except as provided in Subpart L of (b)(1) Except as provided in para-this part and 40 CTR 125 30 through graph (b) of this section, there shall be 125.32, any existing point source sub- no discharge of process wastewater to lect to this subpart must achieve the navigable waters from mills using the following limitations representing the acid leach, alkaline teach or combined degree of effluent reduction attainable acid and alkaline leach process for the by the application of the best available extraction nd mills using of uranium in situ leach or from mines methods.
technclogy economically achievable The Agency recognizes that the elimi-(BAT):
(a) The concentration of pollutants nation of the discharge of pollutants to discharged in mine dninage from navigable waters may result in an in-mines, either open-pit m underground, crease in discharges of some pollutants 313
, . o (- '.
Differing Professional View Panel Report .
Concerning Handling of Liquid Effluent Releases from In Situ Leach Operations at Licensed Uranium Recovery Facilities ATTACHMENT B {
MYRON FLIEGEL'S DIFFERING PROFESSIONAL VIEW ON COMMISSION PAPER TITLED:
RECOMMENDATIONS ON WAYS TO IMPROVE THE EFFICIENCY OF NRC REGULATION AT IN SITU LEACH URANIUM RECOVERY FACILITIES DATED NOVEMBER 19,1998 i