ML25086A026
| ML25086A026 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/2025 |
| From: | Huda Akhavannik NRC/NMSS/DMSST |
| To: | Adelaide Giantelli NRC/NMSS/DMSST |
| Shared Package | |
| ML25086A021 | List: |
| References | |
| Download: ML25086A026 (1) | |
Text
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MEMORANDUM TO:
Adelaide Giantelli, Branch Chief State Agreements and Liaison Program Branch Division of Materials, Safety, Security, State and Tribal Programs Office of Nuclear Material Safety and Safeguards FROM:
Huda Akhavannik Intergovernmental Liaison Project Manager State Agreements and Liaison Program Branch Division of Materials, Safety, Security, State and Tribal Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF FEBRUARY 27, 2025, MEETING TO DISCUSS ABANDONED URANIUM MINE (AUM) WASTE REMEDIATION GUIDANCE DEVELOPMENT DATE OF MEETING:
February 27, 2025 MEETING LOCATION:
Online PURPOSE:
The purpose of this meeting was to seek feedback on the NRCs implementation plan for SRM-SECY-23-0055, Options for Licensing Emerging Technologies Used for Remediation of Mine Waste, (ML23121A271). NRC staff discussed proposed definitions and considerations for licensing abandoned uranium mine (AUM) waste remediation under 10 CFR Part 40 via a service provider licensing framework.
CONTACT:
Huda Akhavannik, MSST/SALB (301) 415-5253 March 27, 2025 Signed by Akhavannik, Huda on 03/27/25
A. Giantelli 2
SUMMARY
The meeting focused on joint NRC and Agreement State guidance development activities for licensing AUM waste remediation under 10 CFR Part 40 via a service provider license. The NRC staff presented definitions for three terms and initial and demobilization notifications. The working group is drafting updates to RIS 2000-23, Recent Changes to Uranium Recovery Policy, (ML003773008) and an Interim Staff Guidance document for NUREG-1556, Vol. 18, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses, (ML17242A055) to provide the definitions and guidance.
One of the primary challenges discussed was the definition of terms such as ore, abandoned uranium mine, and abandoned uranium mine waste. The NRC defines "ore" though guidance in RIS 2000-23. These proposed definitions aim to differentiate AUM waste from ore while considering state and federal regulations. The working group presented two options for each definition as described in the enclosed presentation.
To ensure safety and environmental compliance, the NRC is considering a notification-based approach for service provider licensees. Initial notifications will require site-specific details such as GPS coordinates, expected remediation duration, uranium and thorium concentrations, environmental impact assessments, and financial assurance documentation. Demobilization notifications will confirm compliance with NRC decommissioning standards, detailing material disposition and final survey data. These notifications will allow the NRC to oversee remediation activities without requiring site-specific licensing upfront. As part of describing these criteria, the NRC staff described that meeting the unrestricted release criteria will minimize complications such as needing to update deed restrictions or putting in place institutional controls for a site where the licensee is not the property owner.
The meeting also addressed Agreement State reciprocity, noting that while the definition of ore is in guidance, Agreement States have flexibility to accept, modify, or reject the NRC license.
Therefore, an NRC licensee working in an Agreement State must comply with state requirements and adhere to a 180-day operation limit before requiring a separate state license.
Separately, the NRC plans to maintain a public list of AUM remediation sites, tracking project progress. Therefore, as part of reciprocity, the licensee should send the initial and demobilization notifications to both the NRC and Agreement States.
The working groups next steps include incorporating feedback from the public, Tribal Nations, and Agreement States before releasing the draft ISG and RIS updates in late fall 2025 for public comment. Additional public and government-to-government meetings will follow to refine the guidance before final implementation. The meeting concluded with a Q&A session, where participants provided questions and comments.
The NRC staff received supportive comments on the remediation technology to cleanup sites and the NRCs efforts to remove this type of activity from the milling framework. Primarily, NRC staff received comments with respect to the definitions, especially the definition of ore. These comments include reciprocity challenges that would be faced by the licensees should an Agreement State choose to not adopt the new definition or guidance and therefore not be able to accept the NRC license as-is for reciprocity. Another licensee described disruptions to their operations and a need for a license amendment to accept AUM waste should the definition of ore change. Another comment described that although the AUM waste would initially not be considered ore, it may fall under the definition after processing and then require another regulatory framework. Other comments surrounded whether these activities should be limited to
A. Giantelli abandoned uranium mines and the significance of whether financial assurance should be considered in the definition of abandoned uranium mine. Finally, the staff received several comments on simplifying the definition of abandoned uranium mine waste to remove various conditions of the definition.
The NRC staff indicated that they would review the meeting recording and transcript and consider these comments as they revise the guidance and definitions.
Enclosures:
- 1. NRC Presentation (ML25055A058)
- 2. Attendance Sheet
A. Giantelli
SUBJECT:
SUMMARY
OF FEBRUARY 27, 2025, MEETING TO DISCUSS ABANDONED URANIUM MINE (AUM) WASTE REMEDIATION GUIDANCE DEVELOPMENT DATED:
DISTRIBUTION:
TBloomer DSilberfeld JMarshall JWhitman BVonTill DuaneWhite PYadav DMandeville ADAMS Accession Number: ML25086A021 (Package), ML25086A026 (Memo)
OFFICE NMSS/MSST NAME HAkhavannik DATE 03/27/2025 OFFICIAL RECORD COPY March 27, 2025