ML20236M800
| ML20236M800 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/1987 |
| From: | Pangburn 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 8708110240 | |
| Download: ML20236M800 (7) | |
Text
WM Record file WM Project _ I i
DccLet No. __
IDRW
[
Distribyun JUL. 3 1987 LPDR WM-60/GCP/86/-6/11 Z ~~'l'~~
._ __. ; ~ ~ - - - - -
Eejum in_ _._Wy g g i
t MEMORANDUM FOR:
Paul H. Lohaus, Acting. Chief Operations Branch Division of Low-Level Waste Management l
and Decommissioning l
l THRU:
Myron Fliegel, Section Leader l
Uranium Recovery Section Operations Branch, LLWM l
FROM:
George C. Pangburn, Project Manager Uranium Recovery Section l
Operations Branch, LLWM
SUBJECT:
MEETING BETWEEN NRC, DOE AND THE STATE OF WY0 MING REGARDING THE RIVERTON TITLE I SITE i
On June 10, 1987, representatives of the NRC, DOE and the State of Wyoming met at NRC's offices in Bethesda, MD, to discuss institutional issues related to the remedial action planned for the Title I UMTRAP site in Riverton, WY. The I
meeting was a follow-up to a meeting held in Denver on June 3 (see Trip Report I
of G. Gnugnoli dated June 11,1987) and focused on issues which DOE identified l
in an attached " white paper." The list of attendees is also attached.
i R. Marquez of DOE Albuquerque opened the meeting by stating DOE's interest in moving forward to relocate the Riverton tailings to an NRC-licensed uranium mill tailings pile in the Gas Hills area of Wyoming and noting the State of 1
Wyoming's high level of interest and support for this project. He then stated l
several operational DOE assumptions regarding this remedial action.
j 1)
The action consists of excavation and transport of tailings from the processing site and stops at the gate of the licensed Title II opera tor.
i 2)
The operator would stabilize and reclaim the tailings once inside the gate in accordance with the requirements of the NRC license.
3)
Title I standards would be applied at the remediated processing site while Title II standards would apply at the Title II disposal site.
Mr. Marquez went on to note that they hoped this meeting would resolve whatever institutional barriers might exist in performance of the remedial action so that the limited window of time which they believed to exist would not be closed.
N. Freudenthal of the State of Wyoming affirmed the State's support and emphasized the need to begin the remedial action as planned on July 15, while State funds to support were still available.
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t WM-60/GCP/86/-6/11 R. Fonner of NRC addressed the NRC's role in concurrence on completion of remedial actions and noted two dilemmas which DOE's proposed action would pose:
1)
If the licensee at the Title II site is responsible for stabilization and reclamation of the tailings, NRC through its responsibilities to concur in remedial action as well as regulate to assure public health and safety, would be placed in the conflicting roles of regulating completion of the reclamation and then concurring on it as well.
2)
What financial assurance exists that the licensee will complete the reclamation? Sureties at Title II sites cover the reclamation of the tailings present at those sites, but would those sureties be adequate to reclaim both the existing Title II material and that
)
material coming from the Riverton site?
)
1 Mr. Fonner indicated that the NRC was not particularly concerned about the details of land acquisition at the Title II site, but rather with how the aforementioned issues might be resolved in a satisfactory manner. Mr. Fonner reiterated that NRC cannot concur in completion of the remedial action until the tailings are stabilized and reclaimed in accordance with ap(plicable standards at tb Title 11 site. He stated that Section 108(a) 1) of UMTRCA appeared to provide a mechanism toward resolution of the first issue; i.e., it l
allows DOE to designate someone else to carry cut remedial actions. The l
l attendees discussed this concept as well as the need for an adequate surety at some length. Although DOE requires a performance bond on behalf of their contractor, under the anticipated contract this bond would not cover stabilization and reclamation of tailings at the Gas Hills disposal site.
The participants l
discussed possible mechanisms to provide the necessary financial assurance in i
a fonn that would be administered solely for the reclamation of the Title 1 material. Mr. Fonner also noted that if the approach of identifying a designee were taken and funds were obligated to said designee, the statutory i
completion date for DOE's remedial actions might not impact this site. DOE then requested a break to caucus among themselves.
l At the conclusion of the break, DOE proferred several items which the participants discussed and agreed upon. The items in the agreement are listed below and a copy of the agreement as signed by R. Fonner, 0GC; R. D. Smith, URF0; J. Anderson, DOE; and N. Freudenthal, State of Wyoming, is attached.
1)
Section 108(a)gnate the selected contract bidder as designee under DOE would desi (1) for completion of remedial action, i.e.,
stabilizing at the Gas Hills site.
2)
A separate bid item may be identified for each bidder to identify incremental costs of stabilization and disposal.
0 t
4 '
WM-60/GCP/86/-6/11 3)
DOE would require the successful bidder to have NRC-approved reclamation plan and adequate surety. DOE will assist UP.F0 in cost evaluation.
4)
Designee / contractor will. be responsible for obtaining NRC concurrence on completion of RAP.
5)
Remedial action plan submitted by DOE will address excavation.
l restoration of processing site, transportation.to Gas Hills site and-l the undertaking of. the designee to complete the stabilization of-the removed tailings.
6)
NRC requirements for licensees will be applied at the dispot,al site.
1 7)
NRC assumes that site acquisition will be carried 'out by DOE and the State in accordance with applicable requirements.
NRC agreed to provide DOE with copies of the revised reclamation plans l
supplied by the potential bidders for DOE's use in preparation of independent cost estimates. DOE would identify to NRC the low bidder upon review of the proposals. DOE indicated that the agreements would probably. result in a delay in the issuance of the final RAP for concurrence, but the length of that delay.
could not be estimated at this time. NRC agreed to prepare minutes of this meeting which would incorporate the agreements reached therein.
M George C. Pangburn, Project Manager Uranium Recovery Section Operations Branch, LLWM
Enclosures:
1.
White Paper 2.
List of Attendees 3.
Signed Agreement cc: w/ encl.
J. Turi, DOE /HQ S. Miller, DOE /HQ J. Anderson, DOE /AL R. Marquez, DOE /AL D. Mann, DOE /AL r
N. Freudenthal, State of Wyoming i
)
j
_-______-_----p
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7
,Rif 09 '87 10:21 P.9Bi t M PROGECT RIVERTODI RF. LOCATION '
l PROPOSITIONS,
)
e Relocate Title I rat tings et Rivartom: mill bite to Titf a II site in Cas Ht11slarea.4 i
i l
l k
i INM7ITUTIONAL 18sIE4, 1.
NRC responsibility to concur:with resedial. action and any relocation decision.
9 2.
MRC licensing of 3ong-tets maintenance end surveillknca.
1 I
l 3.
State acquisition of dispossi sites 6 I
I 4
Application of Titlet t or Ttrie 11 standards..
JSSUER RM50LUTION:
1.
If ?rmandtal action';1s characterized;ma decontendnation of Riv>rton.
mill sitci and transport to a Titla 'II site..WRC than, caneers with a remedial actinn plan. describing remedA41.actioh me such.
2.
Title 1 of the Act, requires thats.long -term estatenstace and surveillance be conduttei ander an NRC liconwe. At a Title II tits..
A
M4.09 '87 10:22 P.002 t
'such a liccniec is provide # t'or try the Act.: Ultimately, a federal agane'y (lf kaly DOE).will assues custody:of the disposal site.
)
- 3..The Act dJew not ircquire acquisition of fee edela by the State. That ie, an " interest" 16 the land may ibe appropriate, such as an ease.nent.
Moreover, in thfa case, the Cas' 111114 disposal sicca are on BLN-administered. federal land. This issue.any be academic because 512t' has indtrared ie will Head the land to thct Title II owner / operator.
4.
Title I wtandards would be applied to the eteen-up of the Title I mill.
site.r The Titln 1 railings wouldibe commingled with the tailings cxtant at a Title 11 disposal site; final raclamattun would bc j
perfurned in accordance with's rc clamationi plan approved'hy MRC mtder
, g, Titiet11 requittments of HRC and RPAJ The; environmental. sod health her.ards ar the Titl6 I mill is addressed and the tallings are disposed of f n a marmer that inddrwapen the long-tcra control requinment ne the Act.
PRECEDE)'T At the TVA Title 11 disposal site in Edgesunt. SD. DOE lis transporting vicinity property estoriais for commingled disposal eith T.itle 11 tmittngs.- 'lhe dispessi;in doce pursuant to a license amesidment:1seced by -
NRCland in accordance with*sn agrapannt b=Lween DOE und TVA which is concurredt with by the State and NRC. The rationa,la van that the vicinity property materials were derived from the TVA mill'.
A escendary rat.ionale was to ministre the numbert of disposal mitva.
W W
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Mtg. June 10, 1987, Riverton RAP Robert L. Fonner NRC-0GC
(
Myron Fliegel NRC-NMSS
(
Harry Pettengill NRC-URF0
(
George Pangburn NRC-NMSS
(
Giorgio Gnugnoli NRC-NMSS
(
Rich Marquez DOE-AL
-(
Nancy Freudenthal State of WY
(
Steve Miller DOE-GC
(
John F. Kendig NRC-SLITP James Turi NRC-URF0 Will Maez DOE-AL James R. Anderson DOE-AL 1
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