Water Remediation Technology LLC s Process and Licensing A Solution for Radionuclide Water Treatment

Transcription

1 Water Remediation Technology LLC s Process and Licensing A Solution for Radionuclide Water Treatment NMA-NRC Uranium Workshop, 6/5/2018

2 Overview Introduction and Company History WRT s Treatment Technology and Systems WRT s Cradle-to-Grave Approach to Service Radioactive Material Licensing Legal Aspects of WRT Radionuclide Treatment 2

3 Introduction to WRT WRT is a water treatment company Design, manufacture, and service systems treating radioactive and other contaminants in community drinking water supplies (CWS) and groundwater resources; Primary area radionuclides, radium and/or uranium; Other treatments ammonia, arsenic, and recently chromium. Started in 2000, by mining professionals; System development and pilot testing through 2004; Seven full-scale systems by 2005, currently up to about 160. Latest Development, Jan 2018 Acquisition of Loprest Water Treatment Company Filtration processes for iron, manganese, arsenic, and nitrates; Good parallel fit with WRT. 3

4 Why Radium and Uranium Removal Now? Resulted from USEPA s Radionuclide Rule to the SDWA; Adopted Dec 2000; Compliance Monitoring thru Dec 2007; MCLs: Combined Ra 5 pci/l; U 30 mg/l (ppb); WRT s Initial Systems: U 80-gpm sys, Dinwiddie County VA, 2005 (general license); Ra - 5 x ~1,000-gpm systems, Oswego IL, 2005; WRT s Current Installed and Supported DW Systems: ~ 160 systems total, across the U.S., in about 20 states; ~ 2/3 radium systems, 1/3 uranium; Incl. the largest U sys in the U.S., Grand Island NE, 3,500 gpm; and the largest Ra system, San Angelo TX, 3,500 gpm. 4

5 A Different Kind of Animal WRT s Total-Solution Offering Raw Materials Captive zeolite resource (radium media); Treatment Media Production, Golden CO; Z-88 Radium Removal Media; Final process steps for NSF-certified Z-92 Uranium Media; Re-certification of used Z-92 Uranium Media; Treatment System Design & Fabrication, Arvada CO; Radioactive Material Licensing Support incl. providing RSO and Radiation Protection Program; Servicing Treatment Systems incl. all radiologic work; Packaging spent media for transport; Long-term agreements for the final disposal or disposition of spent treatment media. 5

6 Field-Erected (FE) System (Large Wells) All WRT Radionuclide Treatment Systems: Use Ion Exchange; Min. 2 x treatment vessels per train; Can be either upflow or downflow, depending on water quality. FE Sys 500 to ~ 1,750 gpm per train; Multiple trains can be connected in parallel for larger flow rates. 6

7 Modular Component System (MCS) (Medium Wells) For medium-size wells, 50 to 250 gpm; Uses off-the-shelf components, FRP vessels up to 5-ft dia; Can connect multiple trains in parallel for larger flows. 7

8 Portable Exchange System (PES) (Small Wells) Economical solution for small wells from 10 up to ~ 60 gpm; Treatment trains can be added in increments to match a well s flow rate; A treatment vessel is also the transport and disposal container, therefore, no handling radioactive media at site. 8

9 NRC Regulatory Issue Summary (RIS) Water Treatment Resins as Equivalent Feed The Regulatory Breakthrough for WRT s Approach WRT s Preferred Alternative for Spent Uranium Resin: Send the spent resin to a Uranium Producer; recover the U for the fuel cycle; Return the stripped resin to WRT (the beauty it s not a waste); WRT processes resin to re-certify it to NSF Std 61 for DW, then re-uses it. WRT has reached this goal, working with Cameco Resources Prior to the RIS A U Producer needed a license amendment to process water treatment resins Time and Cost Prohibitive; WRT initiated and worked w/ NRC Staff to streamline this regulatory hurdle: NRC established a new term Equivalent Feed recognizing water treatment resin that is similar in composition and function to an ISR s production resin; A U Producer can now accept and process spent water treatment resins w/o the need for a license amendment. A Bonus The RIS also applies to Resin from Satellite ISR Wellfields You re Welcome, ISRs 9

10 Transportation Requirements Spent media typically classified as USDOT Hazardous Material, Class 7 Radioactive Material; One of the two lowest categories of Class 7 mat l UN2910 or UN2912; Shipment is regulated by US DOT, and a Hazmat Carrier is required; WRT is not a Carrier, but does registers w/ DOT as an Offeror of hazmat; Requires training, classification of matl, lab analyses, and manifesting; WRT does, however, have its own resin tankers. Clean water. Clean earth. That s our promise. 10

11 Spent Media Shipments Spent Z-88 Media Shipment WRT performs 25 to 30 spent media exchanges, Ra and U, annually. WRT s Z-92 Resin Tankers 6 to 8 shipments annually Grand Island NE-Cameco Crow Butte-WRT (for re-use) 11

12 Guiding Concepts - Operations and Licensing Once Again, WRT is a Different Animal Operating Philosophy Radioactive material removed in water treatment should not be discharged back to the local environment No Onsite Regeneration; The licensed radioactive material is not used in the customary licensing sense; Terms like Inherent Value of the Source Material have no meaning to WRT. The Uranium is a Contaminant 12

13 Radioactive Material Licensing Licensing Format WRT typ. is the Site Licensee, on behalf of its Client; Multi-site ( Master ) license, performance-based. Streamlined Application Process One-time, comprehensive application, presenting the range of expected systems; New Clients/Systems added to the Master license by a simple registration process. WRT Holds: NRC Uranium Source Material License in renewal; Ten (10) Agreement State Licenses, for Ra and/or U; Authorized to provide service in at least 30 states. 13

14 Radioactive Material Licensing Importance of the NRC License Allows WRT operations in multiple states and Tribal lands; Agreement States look to the NRC for guidance, support, or precedence. Examples have adopted: -- Multi-site, Master License format; -- Alternative Financial Assurance approaches. Expanded Scope w/ Lic. Renewals NRC & Agree. States Initially, drinking water treatment only; Now, with license renewals: -- Service of similar, but non-wrt systems; -- General Groundwater and Surface Water Treatment Aquifer Remediation Pit Lakes Mine Dewatering 14

15 NRC License Financial Assurance IAW concepts presented previously in NUREG-1757, Volume 3, Consolidated Decommissioning Guidance; WRT s Client can provide the FA arrangement, on behalf of WRT, the licensee; A Govt-Entity Client can use a Statement of Intent; As it could if it were the licensee; Saves the Client the cost of a bond, or tying up actual cash (remember, DW Rad. Treatment = An Unfunded Mandate) Most of WRT s Agreement State licenses include some variation of this NRC format for FA. 15

16 Legal Insights Chris Pugsley 16

17 LEGAL ASPECTS OF WRT RADIONUCLIDE TREATMENT For Initial License Issuance in 2007 and License Renewal in 2018, WRT s Radionuclide (Uranium) Water Treatment Process Does Not Qualify as Processing Ores Primarily for Their Source Material Content: Interesting Where This is Water Treatment to Meet a Given Quality Standard, But ISR Groundwater Restoration is Milling? ; Poses Unique Interpretations Given Recent NRC Staff Determination That Processes Such as Ablation (Sophisticated Ore Sorting) is Milling? ; How Do We Reconcile Other Past NRC Interpretations of Mining v. Source Material Processing v. Milling? Clean water. Clean earth. That s our promise.

18 LEGAL ASPECTS OF WRT RADIONUCLIDE TREATMENT NRC and Agreement States Have Shown Flexibility in Its Interpretation of 10 CFR Part 40 (and Equivalent) Regulations: Public Community Water Systems Allowed to Use Statements of Intent for Financial Assurance Guarantees; Recent Commission Decision Offering Extended License Terms for ISRs to Twenty (20) Years Translated to WRT s License Renewal; Expanded Scope of New License Allows Multiple Project Sites to Employ Safe and Proven Water Treatment Technology: CERCLA/Superfund Sites; Private Mining Sites Needing De-Watering; Native American and State Abandoned Mine Reclamation. Clean water. Clean earth. That s our promise.

19 LEGAL ASPECTS OF WRT RADIONUCLIDE TREATMENT Cradle-to-Grave Services Viewed as an Opportunity to Recycle Uranium Into the Nuclear Fuel Cycle: Facilities with Ion-Exchange Processing Capability Are Candidates for Receipt of These Loaded-IX Resins; No Need to Dispose of a Resource That Can Contribute Valuable Benefits to Domestic Electricity Production; Can Be Disposed of at Properly Licensed Facilities If Necessary; IX Resins Can Be Re-Certified and Re-Used. Clean water. Clean earth. That s our promise.

20 LEGAL ASPECTS OF WRT RADIONUCLIDE TREATMENT NRC Flexibility Expands to Properly Address Commission Policy on Performance-Based, Risk-Informed Regulation: Multi-Site License Within Environmental and Technical Bounding Criteria; Conforms with Reciprocity Pending Agreement State License Applications; Agreement States Would Be Well-Served to Adopt Similar Approach: Less Resource Expenditure; Less Painful License Amendment Process; Recognizes Value of a SERP and Their Qualifications. Clean water. Clean earth. That s our promise.

21 LEGAL ASPECTS OF WRT RADIONUCLIDE TREATMENT Other Legal Benefits of WRT Approach to Regulation: Shows Responsible Licensees Can Conduct Low Risk Activities Without Large-Scale Government Regulation; Demonstrates an Unfunded Federal Mandate Can Be Addressed in a Safe Manner; Equivalent Feed RIS Spawned from WRT Licensing; Allows for Proper Regulatory Interpretations; Lays Foundation for Solidification of Mining v. Source Material Processing v. Milling Issue. Clean water. Clean earth. That s our promise.

22 Comments/Questions? Water Remediation Technology LLC Duane Bollig Director Environmental & Regulatory Affairs x108 Thompson & Pugsley PLLC Christopher Pugsley, Esq Clean water. Clean earth. That s our promise. 22