ML20214N198
| ML20214N198 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/1985 |
| From: | Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Dragonette K NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20210Q655 | List: |
| References | |
| FRN-49FR46425, FRN-51FR24697, RULE-PR-40 AB56-1-36, NUDOCS 8609160156 | |
| Download: ML20214N198 (14) | |
Text
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'l ABsw e n PPK ISTRIBUTION 213/MFW/85/10/17
_j- /WMFile213 NMSS r/f WMGT r/f REBrowning MEMORANDUM FOR: Kitty S. Dragonette, WMLU MJBell Division of Waste Management MRKnapp MFliegel FROM: Malcolm R. Knapp, Chief, WMGT MWeber & r/f rt Division of Waste Management l
SUBJECT:
DRAFT FEDERAL REGISTER NOTICE ON NRC'S AMENDED JGreeves URANIUM RECOVERY REGULATIONS JBunting As re' quested in your TAR dated September 13, 1985, Michael Weber has prepared several portions of a draft Federal Register Notice to accompany NRC's amended regulations for uranium recovery. Succinct descriptions of the impacts of amendments to 10 CFR Part 40, Appendix A are provided in the enclosure along with a list of references as requested in an attachment to the September.13 TAR. The description of closure requirement impacts provides space for a paraphrase of this requirement once.it is developed. Although we evaluated technical aspects of, the proposed amendments. to Appendix A in r.esponding.~to
~ this TAR, our resp'onse should n'ot be construed to imply that we necessarily endorse the technic.al justifications for the EPA standards in 40 CFR Part 192, Subparts D and E. As you discussed with Mr. Weber, we have postponed planning regulatory guidance to accompany the groundwater revisions to Appendix A until after we meet with you, Mark Haisfield, and URF0 staff to identify the needs for such guidance. Please. contact Mr. Weber at telephone extension x74746 if you have any questions about the enclosed descriptions or list of references.
le/
Malcolm R. Knapp, Chief Geotechnical Branch Division of Waste Management
Enclosure:
Draft Impact Descriptions t
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4.a.(1) Synthetic Liners As provided in Criterion 5(A)l, liners for tailings surface impoundments must be designed, constructed, and installed to prevent any migration of wastes out of the impoundments during the active life of the facility. This provision requires installation of synthetic liners to mitigate migration of hazardous .
constituents from the tailings,. unless an applicant or licensee can demonstrate t' hat these constituents will not migrate into groundwater or surface water. In 1980, the NRC staff concluded that seepage control is the
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most effective approach for reducing potential groundwater contamination.
Seepage control actions relevant to Criterion 5(A)l. include installation of synthetic liners such as flexible polymeric membrane, plastic, and rubber. -
liners. .
Synthetic liners constitute state-of-the-art components of uranium tailings impoundments to minimize groundwater contamination caused by leakage from tailings impoundments. Although they do not prevent leakage, synthetic liners that are properly designed and installed are more effective than other types of liners in. minimizing leakage rates from active tailings impoundments, .thus protecting groundwater quality. Persons living near uranium processing sites may benefit directly from the preservation of the quality of groundwater and l surface water. The benefits of groundwater protection cannot be generically L assessed, however, because these benefits are determined by highly site-specific factors.
The requirement to install synthetic liners in new or existing tailings impoundments will significantly increase the cost of tailings disposal compared with costs incurred at uranium mills constructed before 1978. Since 1978, NRC has required licensees to construct new uranium tailings impoundments using either synthetic or engineered clay liners. Accuracies of cost estimates 'for liners at future sites are inherently limited by site-specific factors that affect liner costs, including liner type and characteristics, inpoundment design, impoundment size, time of installation,
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205/PFW/85/10/08 and location of the processing facility. Based on cost evaluations described-in NRC's Generic Environmental Impact Statement on Uranium Milligig (GEIS) and updated analyses, installation of synthetic liners is expected to account for 1 to 2 percent ~of the value of uranium produced at a typical uranium mill.
The value of uranium was estimated by assuming a 15-year life cycle for the mill, an annual yellowcake production of 580 metric tonnes (MT), and a fixed market price for yellowcake of $44100 per MT.
The average size of existing uranium tailings impoundments or groups of impoundments in the United States is approximately 70 hectares (175 acres).
Based on unit costs of synthetic liners installed at other waste dispo. sal sites irr the United States, the cost of synthetic liner installation' in an average-size -impoundment would be expected to range from $4.2 to 10.4 million (1985). Unit costs for previous years were escalated to 1985 costs in proportion to increases in construction price indexes for appropriate years.
Table 1 compares estimated costs for synthetic liner installation with costs
.of other groundwater protection measures based on a simplified site model.
These cost estimates may differ from actual costs based on site-specific factors discussed above, as well as hydrogeologic characteristics ani the need for corrective action to protect groundwater quality. For example, at processing sites where contamination would jeopardize beneficial use of aquifers, a licensee may need to construct a tailings impoundment using a composite synthetic and clay liner. The incremental costs of composite liner installation are not included in the table.
4.a.(2) Alternatives to Synthetic Liners As an alternative to synthetic liner installation, Criterion SA(1) provides licensees and applicants' with flexibility to construct storage impoundments for uranium tailings, provided that tailings constituents do not migrate into subsurface soils, geologic media, . groundwater, or s'urface water during the
f 205/MFW/85/10/08 active life of the facility. The licensee or applicant would be required during closure of the facility to remove or decontaminate all waste residues (e.g., tailings), contaminated impoundment components (e.g., liners, embankments), contaminated soils and geologic media, and contaminated structures and equipment. Relocation of the tailings would generally not be required for disposal impoundments constructed with synthetic liners.
NRC staff considers that the use of tailing impoundments for storage rather than disposal generally will not be economically viable because of the high costs of removing, decontaminating, and disposing large volumes of tailings and contaminated wastes. This alternative also involves costs for developing 'and constructing chemically-treated or admixed. liners.that will -
prevent waste migration into soils, geologic media, groundwater, and surface water. As seen in Table 1, the estimated cost for excavation and hauling tailings to a disposal site alone significantly exceeds the cost of synthetic liner installation. Use of impoundments for tailings storage appears even less likely considering additional costs for the alternative including disposal site preparation costs; design, testing, and installation costs for liners; and costs for dewatering the tailings so they can be relocated to a disposal site.
Criterion SA(3) provides the applicant or licensee with an opportunity for another exemption from the synthetic liner requirement if the applicant or licensee can demonstrate to the Commission that a combination of design, operation, and site characteristics prevents migration of hazardous constituents into groundwater or surface water at any future time. This demonstration should consider such factors as the nature and quantity of wastes, alternate design features and operation practices, hydrogeologic site characteristics, and other factors that could influence the quality of leachate and mobility of hazardous constituents relevant to their migration to groundwater and surface water.
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r 205/MFW/85/10/08 Costs incurred in successfully demonstrating the exemption will vary based on the relative importance and type of site characteristics, design features, and operation practices. For example, a successful demonstration based primarily on site characteristics may only require additional collection of site characterization infor.aation to supplement information contained in environmental assessments and licensing evaluations pursuant to Criterion 5H(2). The incremental cost in this case would be limited to the additional costs of collecting more-detailed hydrogeologic information (e.g., aquifer tests analyses, groundwater monitoring results, stratigraphic data). In contrast, a demonstration may be based primarily on appropriate operational
. practices such as drying the tailings with cyclones or belt filters. The cost of ,this alternative .would equal the capitaT co~sts of necessary equipment and - - -
structures, as well as the mainten'ance and operational costs associated with the equipment and structures. Because of the diversity of potential alternatives to synthetic liner installation, the costs of the alternatives is expected to vary from less than to greater than the costs of synthetic liners as described in Table 1.
The potential benefits gained from the exemption are essentially equivalent to potential benefits associated with synthetic liner installation, namely protection of groundwater and surface water quality. This benefit may be realized by humans living near uranium processing facilities and the surrounding environment. As a potential secondary benefit of the liner exemption, Criterion 5A(3) may stimulate effective application of new control and operation technologies for environmental protection at uranium processing facilities. Successful applications could benefit other programs for radiological and non-radiological waste management.
O a
205/MFW/85/10/08 )
4.a.(3) Groundwater Monitoring Criterion 7A requires implementation of groundwater monitorin,g programs and analysis of groundwater monitoring data. These programs directly support the secondary groundwater protection standard of phased monitoring and corrective actions based on monitoring results. Most existing monitoring programs at uranium processing sites will need to be upgraded to comply with the requirement for groundwater monitoring programs for detection of hazardous constituents, compliance with site-specific groundwater protection standards, and demonstration of the effectiveness of corrective actions. For example, licensees may need to install new wells at sites where existing monitoring
. wells are inadequate to characterize the. effects of uranium tailings disposal on groundwater quality or where background groundwater quality has .not been established. At other sites with adequate monitoring facilities, licansees may need to expand monitoring programs to sample for more constituents or at an increased frequency.
The costs of upgrading existing grcundwater monitoring programs at uranium processing sites will be affected by site-specific factors such as the adequacy of existing monitoring wells, extent of groundwater contamination, and hydrogeologic site characteristics. These costs will be incremental to costs for groundwater monitoring at existing sites for compliance with licensing conditions and preparation of environmental assessments.
Groundwater monitoring costs may also be affected by site-specific decisions such as pursuing an exemption to the synthetic liner requirement, requesting Alternate Concentration Limits (ACL's), or selecting corrective actions for groundwater contamination. Based on unit costs for monitoring wells in the United States, the costs for installing and monitoring 30 shallow (50 foot depth) wells at a site and analyzing the samples for major and minor ions, inorganic hazardous constituents, and organic indicator parameters would be expected to range from $ 35,000 to 225,000 per year (1985).
205/MFW/85/10/08 In comparison with the costs of other groundwater protection measures, the total cost of groundwater monitoring is relatively small during the active life of the facility. If- these costs are extrapolated for decades after closure of the tailings impoundments, however, total groundwater monitoring
, costs may account for a signifi' cant proportion of the total value of yellowcake produced by a uranium .rgill.~ Using the example described above, the total cost of groundwater moni,toringsfor 50 years would account for 0.3 to 1.1
. percent of the total yellowcake Yalue at a uranium mill with a 15-year life cycle, a production capacity of 580 MT per year, and yellowcake value of
$44100 per MT.
4.a.(4) Alternate. Concentration Limits > .
Today's proposed ame[1dments provide licensees with flexibility in developing site-specific groundwater protection standards that incorporate Alternate Concentration Limits (ACL's) in lieu of background concentrations limits or the limits listed in Criterion SC. Based on a licensee's demonstration, the Commission may establish ACL's provided that a hazardous constituent does not pose any present or potential hazard to humans or the environment as long as its concentration does not exceed this alternate limit at the point of compliance. The Commission will consider justifications of alternate concentration limits using generic guidance developed jointly by NRC and EPA based on factors listed in Criterion 5B(6).
The costs of demonstrating alternate concentration limits will vary based on site-specific factors that determine information needs for the demonstration.
Information collected for the demonstration should be used in conjunction with information contained in environmental reports and license applications.
Because detailed site information is required in Criterion 5H, justifications for ACL's should only need to be supplemented with information about adverse W
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205/MFW/85/10/08 effects of hazardous constituents on humans and the environment based on reputable literature. The cost of assembling this information is expected to be minimal compared with costs for other groundwater protection actions such as liner and cover installation or groundwater monitoring.
4.a.(5) Closure As provided in Criterion , surface impoundments at uranium processing facilities must be . . . (insert paraphrased criterion for stabilizing
) tailings prior to closure) . . . prior to construction of a final cover.
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The environmental characteristics of most processing sites in combination with effective earthen covers for radon control and erosion protection should
< generally be sufficient to minimize .long-term infiltration into stabilized impoundments. However, some tailings disposal impoundments with synthetic liners.may require more complicated cover designs and installations to prevent i detrimental accumulation of water in the stabilized impoundment after closure (i.e., bathtub effect). For example, a site may require a composite cover consisting of compacted silt to control radon diffusion and a bituminous
, concrete surface seal to minimize infiltration.
The cost of a bituminous concrete seal for an average-size impoundment would be expected to range from $1.3 to 1.7 million (1985). As with other large-scale construction projects, the costs of seals and other closure measures may vary considerably based on site-specific factors such as type and characteristics of the seal, cover design, size of cover, location of the processing site, and the effectiveness of tailings stabilization and dewatering prior to impoundment closure. The cost of synthetic, admixed, or concrete cover seals would be expected to be less than or equal to the cost of synthetic liners beneath tailings impoundments. Thus, cover seals may account i
4 205/MFW/85/10/08 for 0.2 to 3 percent of the value of yellowcake produced by a uranium mill with a 15-year life cycle, production rate of 580 MT per year, and yellowcake market price of $44100 per MT.
4.a.(6) Corrective Actions for Groundwater Contamination l In recognition of potential failures of impoundment liners an'd covers, today's proposed amendments provide for a secondary groundwater protection standard involving a phased approach for groundwater monitoring and corrective action.
Corrective actions may be required to restore groundwater to its background quality to avoid adverse effects on humans and the environment. The objective of corrective action programs is to prevent ' hazardous constituents in the' -
uppermost aquifer from exceeding their respective concentration limits at the point of compliance. This objective is to be accomplishea by eliminating the source of groundwater contamination by either relocating the tailings to a suitable disposal site or treating them in place to limit the mobility and release of hazardous constituents. In addition, the corrective action program must also remove or treat in place any hazardous constituents that exceed their concentration limits in groundwater between the point of compliance and the site boundary.
Corrective action programs may also be required for groundwater contamination from waste disposal impoundments at uranium in-situ leach and heap-leach facilities. Actions taken at these facilities would be expected to be similar in purpose and design to those implemented at uranium mills, although the l
scale of action would probably be larger at uranium mills.
Licensees have been operating programs to mitigate groundwater contamination at uranium mills for several years. The corrective action programs required in today's amendments may substantially increase the costs associated with
( groundwater protection at uranium processing facilities by requiring i
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205/MFW/85/10/08 expansion of existing mitigation programs or development of new corrective action programs. Accuracies of cost estimates for corrective action programs are inherently limited by site-specific factors such as the extent and type of contamination, volume of tailings, hydraulic and geochemical properties of the.
hydrogeologic system, impoundment design, and other factors that affect the technical feasibility, practicality, timing, and extent of corrective actions for groundwater contamination.
Table 1 compares relative costs of groundwater protection actions, including components of corrective action programs such as slurry trench installation, grouting, drain and well installation and operation, relocation of tailings,
, and aquifer restoration. The costs of component actions, would be sumed. to
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j develop cost estimates of integrat'ed corrective action programs. An examp1e of an ' integrated corrective action program would include dewatering. tailings to reduce seepage into an aquifer, installation of a bentonite slurry wall upgradient of a contaminated groundwater plume, installation and operation of injection and withdrawal wells for aquifer restoration, and construction and operation of a water treatment facility to improve the quality of water removed from the contaminated aquifer. In addition to activities directly related to design and implementation of the corrective action programs, the program also incurs costs for detailed groundwater monitoring and evaluation of monitoring data to evaluate the effectiveness of corrective action programs.
The costs of corrective actions may account for a significant proportion (e.g., 20%) of the value of yellowcake produced at a uranium processing facility depending on the type and extent of corrective actions.
TABLE 1. COST COMPARISON FOR GROUNDWATER PROTECTION ACTIONS Cost Range Percentage of Type of Action (millions 1985 dollars,) Product Value Synthetic. Liners 4.2 to 10.4 1.1 to 2.7 Clay, Admixed, and 1.4 to 8.0 0.4 to 2.1 Asphalt Liners Slurry Trench 4.2 to 7.2 1.1 to 1.9 Grout Curtain 16.6 to 33.3 4.3 to 8.7 Bituminous Concrete 1.3 to 1.7 0.3 to 0.4
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Groundwater Drains ' 1.8 to 2.2
- 0.5 t'o 0.6
-(w/o treatment)
Withdrawal Wells 0.5 to 0.7 0.1 to 0.2 (w/o treatment)
Withdrawal Wells 7.3 to 33.0 1.9 to 8.6 (with. treatment)
Relocation of. 24.5 to 53.1 6.4 to 13.8 Tailings Assumes the following site model: 70 hectare tailings impoundment in which tailings have been deposited to a thickness of 9 m; contaminated groundwater plume extends from the upgradient side of impoundment to 500 m laterally downgradient of the downgradient edge of the impoundment; unidirectional groundwater flow field; aquifer is 15 m thick, composed of silty sand, and has a porosity of 20%; uranium mill produces yellowcake for 15 years with an annual production rate of 580 MT at a fixed market price of
$44100 per MT; tailings are relocated to a disposal site (uncosted) within 9 km of the original impoundment.
t LIST OF REFERENCES Barcelona, M. J., Gibb, J. P., and Miller, R. A. 1983. A Guide to the Selection of Materials for Monitoring Well Construction and Ground-Water
- ' Sampling. Illinois State Water Survey, ISWS Contract Report 327.
Buelt, J. L., and Barnes, S. M. 1981. A Comparative Evaluation of Liner Materials for Inactive Uranium Mill Tailings Piles. Proceedings of the Symposium on Uranium Mill Tailings Management, Colorado State University, October 26-27, 1981.
Buelt, J. L., Hale, V. Q., Barnes, S. M., and Silviera, D. J. 1981. An Evaluation of Liners for a Uranium-Mill Tailings Disposal Site - A Status Report. U. S. Department of Energy, DOE /UMT-0200.
Deutsch, W.'J., Bell, N. E., Serne, R. J., Shade, J. W., and Tweeton, D. R. ~'
1984. Aqirifer Re's'toration Techniques for In-situ Leach Uranium Mines. .
U. S. Nuclear Re,gulatory Comission, NUREG/CR-3104.
Dewolf, G., Murin, P., Jarvis, J., and Kelly, M. 1984. The Control Cost Digest: Cost Summaries of Selected Environmental Control Technologies.
U. S. Environmental Protection Agency, EPA-600/8-84-010.
Engineering News Record, Volume 214, Number 12. March 21, 1985, p. 101.
Ertec Atlantic, Incorporated. 1983. Draft Final Liner /Locational Analysis Project. Prepared for the U. S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.
Forseth, J. M., and Kmet, P. 1983. Flexible Membrane Liners for Solid and Hazardous Waste Landfills - A State of the Art Review. Presented at the Sixth Annual Madison Conference of Applied Research and Practice on Municipal and Industrial Waste, University of Wisconsin Extension, September 14 and 15, 1983.
Gates T. E. 1982. Consolidation Theory and Its Applicability to the Dewatering and Covering of Uranium Hill Tailings. U. S. Nuclear Regulatory Commission, NUREG/CR-2894.
Ghassemi, M., Haro, M., and Fargo, L. 1984. Assessment of Hazardous Waste Surface Impoundment Technology: Case Studies and Perspectives of Experts.
U. S. Environmental Protection Agency, Contract Number 68-02-3174.
f Ghassemi, M., Haro, M., Metzger, J., Powers, M., Quinlivan, S., Scinto, L., and White, H. 1983. Assessment of Technology for Constructing and Installing Cover and Bottom Liner Systems for Hazardous Waste Facilities.
Prepared for the U. S. Environmental Protection Agency, Contract Number 68-02-3174.
Gutknecht, P. J., and Gates, T. E. 1982. Review of Design Approaches Applicable to Dewatering Uranium Mill Tailings Disposal Pits. U. S.
Nuclear Regulatory Commission, NUREG/CR-2608.
Mitchell, D. H. 1984. Technology for Uranium Mill Ponds Using Geomembranes.
V. S. Nuclear Regulatory Commission, NUREG/CR-3890.
Mitchell, D. H., and Spanner, G. E. 1984. Field Performance Assessment of Synthetic Liners for Uranium Tailings Ponds: A Status Report. Pacific
. Northwest Laboratory, PNL-5005. .
Opitz, B.' E., Dodson, M. E., an'd Serne, R. J. 1984. ~ Laboratory Evaluation of' l
Limestone and Lime Neutralization of Acidic. Uranium Mill Tailings
- Solution. U. S. Nuclear Regulatory Commission, NUREG/CR-3449.
Rishel, H. L., Boston, T. M., and Schmidt, C. J. 1982. Ccats of Remedial Response Actions at Uncontrolled Hazardous Waste Sites. U. S.
Environmental Protection Agency, EPA-600/2-82-035.
Rogoshewski, P., Bryson, H., and Wagner, K. 1983. Remedial Action Technology for Waste Disposal Sites. Park Ridge, New Jersey: Noyes Data Corporation.
Serne, R. J., Peterson, S. R., and Gee, G. W. 1983. Laboratory Measurement of Contaminant Attenuation of Uranium Mill Tailings Leachates by Sediments and Clay Liners. U. S. Nuclear Regulatory Commission, NUREG/CR-2938.
Shafer, J. M., Oberlander, P. L., and Skaggs, R. L. 1984. Mitigative Techniques and Analysis of Site Conditions for Ground-Water Contamination Associated with Severe Accidents (Draft Report). U. S. Nuclear Regulatory Comraission, NUREG/CR-3681.
Sherwood, D. R., and Serne, R. J. 1983. Tailings Treatment Techniques for Uranium Mill Waste: A Review of Existing Information. U. S. Nuclear Regulatory Commission, NDREG/CR-2938.
4 U. S. Environmental Protection Agency. 1982. C1Jsure of Hazardous Waste Surface Impoundments. Office of Solid Waste and Emergency Response, SW-873.
U. S. Environmental Protection Agency. 1983. Lining of Waste Impoundment and Disposal Facilities. Office of Solid Waste and Emergency Response, SW-870.
U. S. Environmental Protection Agency. 1984. Case Studies 1-23: Remedial Response at Hazardous Waste Sites. Office of Emergency and Remedial Response and Office of Research and Development, EPA-540/2-84-002b.
U. S. Environmental Protection Agency. 1984. Review of In-place Treatment Techniques for Contaminated Surface Soils: Technical Evaluation (Volume 1). Office of Solid Waste and Emergency Response and Office of Research and Development, EPA-540/2-84-003a.
U. S. Environmental Protection Agency. 1984. Slurry Trench Construction f'or' Pollution Migration Control. Office of Emergency and Remedial Response and Office of Research and Development, EPA-540/2-84-001.
U. S. Environmental Protection Agency. 1985. RCRA Ground-Water Monitoring Technical Enforcement Guidance Document. Office of Solid Waste and Emergency Response.
U. S. Nuclear Regulatory Commission. 1980. Final Generic Environmental Impact Statement on Uranium Milling. Office of Nuclear Material Safety and Safeguards, NUREG-0706.
U. S. Nuclear Regulatory Commission. 1984. Regulatory Analysis Guidelines of the U. S. Nuclear Regulatory Consnission. NUREG/BR-0058, Revision 1.
Ware, S. A., and Jackson, G. S. 1978. Liners for Sanitary Landfills and Chemical and Hazardous Waste Disposal Sites. U. S. Environmental Protection Agency, EPA-600/9-78-005.
White, W. S. 1984. Directory and Profile of Licensed Uranium-Recovery Facilities. U. S. Nuclear Regulatory Commission, NUREG/CR-2869, Revision 1.
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