ML20214E899
| ML20214E899 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1987 |
| From: | Gnugnoli G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-60 NUDOCS 8705220307 | |
| Download: ML20214E899 (5) | |
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MEMORANDUM'FOR:- Paul H'. Lohaus.; Acting Chief *
< Operations Branch Division- of-Low-level Waste Management .
._and Decommissioning a -
FROM: Giorgio N.' Gnugnoli, Project Manager
< ^ Operations Branch '
-Division of Low-Level Waste Management
'and Decommissioning
SUBJECT:
' MEETING.0N DISPOSAL OF RIVERTON TAILINGS AT THE r
' AMERICAN NUCLEAR CORPORATION'S.(ANC'S) GAS. HILLS,. '
E WYOMING LICENSED FACILITY.
Lodistics:= March 17,.1987.
NRC Uranium. Recovery Field Office' Denver,~ CO -
- NRC- , DOE WYOMING >
Attendees: .-
s.
L. Askew L G. Gnugnoli J. D'_Antcnio E.!Hawkins W. Arthur R. Shaffner D. Martin J. Gatrell 'R. Wood "
H. Pettengill "O.
R. Smith ~ ,
, Discussion: The' participants discussed several topics regard'ing' the subjhet- .
co-disp'osal option, which are sumarized asf follows:-
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f, - Impacts of UMTRAP Deadline
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b NRC ' staff pointed out that UMTRCA Title I requires that NRC have DOE under; y license for the inactive tailings by-September 1993. This assumes ~ that DOE' ,
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- iwill obtain the proposed.3-year extension. In order to co-dispose and.. .
J' comingle Title I .and II tailings, the co-disposal area would need to be put .
~. under,such a' license to DOE by September 1993, assuming the Title'I remedial action is completed.. Participants agreed that some Title II licensees would
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possibly not elect to pursue'such options, if the imposition of such deadlines-
.would interfere with their operational planning, ,
. Proposed DOE Contracting Strategy Participants discussed the feasibility of DOE pre-qualifying contractors to perfom the remedial action, in the case of co-disposal of Title I and II
- ~ tailings. Other uranium milling facility licensees have shown some interest and willingness to consider such co-disposal. The DOE participants indicated that the DOE would establish criteria to provide the highest level of f ' confidence that the remedial action would be completed. In order to minimize L DOE liability in the. case of insolvency on the part of the licensee, DOE is e
considering the inclusion of pre-qualification criteria requiring the
'. contractor to obtain a= surety mechanism for remedial action activities at the site of commingling. (A pre-solicitation of interest for potential disposal 7
9705220307 870506 PDR WASTE
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siteshas$beenreleasedbyM-KFergusononApriljl4,1987). This mechanism-iwould be separate from1the existing'NRC- and State-approved sureties held by .
/the State: and from' perfomance bonds for. Title I activities outside of.the' site
_ 'of conmiingling; e.g.. restoration of the.Riverton processing site. (The DOE's
- Office of: the Chief Counsel is perfoming =a . review of UMTRCA and NRC regulations relating.to financial assurance. The intent is to determine whether the NRC's overall bonding mechanism is adequate for,the needs of both
...m ' NRC and ; DOE, in order to avoid _ unnecessary duplication). The contract an'd the
- financial surety mechanisms would extend to the end of. remedial action; 1.e.,
sthe placement.of the final cover. All- participants' agreed that any bonds
, "should not be. held by the NRC, because the sums would be absorbed into the U.S.
Treasury and would be difficult to recover. The DEQ remarked that overlapping financial sureties could make commingling less attractive to potential bidders.
The DOE would plan _to incorporate into_the contract the necessary milestones to comply with the mandatory completion >date. Thus, even if the reclamation continues beyond the time mandated for program completion; there;would continue to be a binding contractual obligation to complete the remedial action. NRC-
. staff pointed out that such explicit provisions may be difficult to stipulate. l because the NRC-approved reclamation plans may not be finalized until after the sc licensee requests the' amendment to separate the commingling reclamation from
. any other ongoing Title II operations. DOE and DEQ participants agreed to
+ implement mutual DOE and Wyoming. accords in a Cooperative Agreement !
' modification subject to NRC r'eview and concurrence.
Land Acquisition The American Nuclear Corporation's (ANC's) site in the Gas Hills is a leading -
. candidate for the co-disposal. The Pond.1-areacis on BLM land, which is leased by ANC.- NRC staff indicated-that BLM, as Lan organization in DOI, needed to c make the land available to DOE for co-disposal, as required by UMTRCA. Title I.
The DEQ staff indicated that BLM officials had infomally discussed this issue -
with them and that BLM'did not intend to hold things up. BLM has written to DOE regarding a potential request for. land withdrawal for portions of the ANC site (Enclosed). The DEQ indicated that they would contact ANC and other Gas Hills facilities to determine what BLM lease restrictions might exist. ' Aside from having to allow such disposal by license amendment, the NRC would also have.to ' concur in-the designation and disposition of inactive site tailings at such locations. NRC staff further indicated that the DOE needs to have a precise description of the land affected by the co-disposal and which is to be
= transferred, either in the Cooperative Agreement or in the Remedial Action Plan
- (RAP) .'
Surveillance and Maintenance NRC staff indicated to the DOE participants that the licensee will not be released from its responsibility after construction completion. Under nomal
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circumstances the Title II licensee is kept under license for a period of time following the completion of reclamation construction. This post construction period would be on the order of five years, so as to demonstrate that the
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Ireclamationpl.an'hadachievedtheNRCclosurerequirements.1Duringthisperiod -
.the licensee would perfom surveillance and monitoring activities as= required under the license, which would be equivalent to the kinds of activities DOE. '
would; perform underaits custodialtresponsibilities at. Title'I sites. s
+ DOE Correspondence I The DOE staffJindicated that it would redraft a'. letter discussing its approval a of co-disposal which would reflect the discussions of this meeting.1 The letter '
', would be~provided to the U.S. Congress to infom them of this co-disposal g ; option-and of DOE's intention to pursue it. 1
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Remedial Action Plans
-The participants agreed that the most flexible approach for ~ documenting:the' .
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. c remedial' action would be-to reference the NRC~ docket and independent assessment
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regarding reclamation activities at the Title II' site. The remainder-of the, ,,,
u RAP would be generated by DOE and would. cover excavation and restoration of, the f . , l processing site and the transport and delivery of residual radioactive material
, to the Title II site.
J' Giorgio N. Gnugnoli, Proje'ct Manager "
u Operations Branch .
Division of Low-Level Waste Management'
- and Decomissioning Enclosurei _As stated
.cc: w/ enclosure J. Anderson, DOE /AL. J. Gorn, NRC/0CA W. Arthur, DOE /AL R. Shaffer, WY/DEQ L.' Askew,-WY/DEQ R. Smith, NRC/URF0-
"J.-D' Antonio, DOE /AL >
J. Turi DOE /HQ NE-22
'J. Gatrell,' 00E/HQ NE .R. Wood, WY/DEQ s
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ENCLOSURE
, 3009 4
Phono: (307) 332-7822 .
lurch 13, 1987
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' ' U.S. D:p3rt:cnt of Dicrgy Uranium 11111 Tailing Project Office 5301 Central Avenue 1;E 10hurg:erque !M 87108 D ar l'r. 7.nderson:
'Ihrough the news nadia in Wyming and particularly Premont County, EU4 has h::.rned that the Susquchanna uranita mill tailings near Riverton will be re;:oved and taken to the Gas Hills uranitm mining area,for disposal and stabilization. I further understand that the tailings are to be disposed of .
cm Imrican Nuclear Cbrpany's (NC) properties in the Gas Hills which are covered by tailings fra the inactive Federal Am.arican Partners mills since scre of the taillngs frcm this mill are on unpatented mill site clairas covering public lands under the jurisdiction of the Bud, I would appreciate hearing frm yatt cmoerning any infomatim you scay have that would identify exactly where the tailings will be deposited and what acticns the DOE will be tah.ing to acquire the proposed diamaal lands for future management responsibilities. If the DOE or the Nuclear Regulatory Cannic=icn will be required to have the publ.ic lands protected under a withdrawal, a request for such a withdrawal should be made as soon as possible. . . . . . .
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'Jhank you for your cooperation. .4.\:.m 4, g5 4 -
Sincerely, ,@'
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0(e. L~. y Manager D. // .
I A k.1 cj/f0f6(@c' cc: Richard Bastin, Rawlins District Ed Hawkins, U.S. Nuclear Regulatory Agency, Uranitro Recovery Field Office, Regicn IV, P.O. Box 25325, Denver CD 80225 e
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' Jbny Pettengill, U.S.. ::1 car Ib3ulatory Agency, Urcnita Recovery Field Offico, Regica IV, P.O. .ox 25325, Denver 00 80225 Robert Paolo, Jacobs En< is cering Group, 5301 Centml. Avenue 1:8., .9aite 1700, Albugierquo !!! 87. %
, s, - Pat !',ontoya, U.S. Ibpt. ti Ihcrgy (FCtD), Ibx 5400, Albuquerquo !ct 87115 EG:orgccon: pin
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