Status of the Uranium Recovery Program

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1 Status of the Uranium Recovery Program John Tappert, Director Bill von Till, Branch Chief Division of Decommissioning, Uranium Recovery, and Waste Programs June

2 Presentation Outline Programmatic Accomplishments Adapting to Change Wyoming Agreement State Application Transition of Wyoming to an Agreement State What s Next 2

3 Programmatic Accomplishments Implementing recommendation of UR licensing program assessment Increased communication with applicants and licensees Progress on major licensing actions Review of Wyoming Agreement State application 3

4 Adapting to Change NRC wide Transformation Initiative Energy Market (dynamic workload) Budget Preparing for potential of Wyoming becoming an Agreement State Fees 4

5 Wyoming Agreement State Application NRC staff prepares Commission Paper that includes draft analysis, draft Agreement and Federal Register notice requesting comments Commission approves publication in the Federal Register for public review and comment June 2018 (projected) Draft Agreement and staff analysis published in Federal Register once a week for four consecutive weeks June July 2018 (projected) NRC staff analyzes public comments July August 2018 (projected) 5

6 Wyoming Agreement State Application (cont d) NRC staff prepares Commission Paper that includes final analysis, Agreement and resolution to public comments August 2018 (projected) NRC staff delivers Agreement to Commission for review and approval September 2018 (projected) Chairman and Governor sign Agreement September 2018 (projected) State assumes regulation authority September 30, 2018 (projected) Final Agreement published in Federal Register October 2018 (projected) Orderly transfer of records Early October 2018 (projected) 6

7 Transition of Wyoming to an Agreement State We are committed to close coordination with Wyoming Implementing strategies to manage transition and right size the UR program based on assumed work Limited work on guidance after the transition 7

8 What s Next Limited guidance updates Licensing process improvements Knowledge management ISR Rulemaking 8

9 von Till Presentation Outline Adapting to change Operational Priorities Operational Accomplishments Operating/Licensed Sites Hearings (Schedules Only) Status of Major Licensing Actions Status of Radiation Protection Issues Alternate concentration limits at ISR sites 9

10 Adapting to Change Adapting to a changing workload and Wyoming as a potential Agreement State Combining uranium recovery functions Budget commensurate with work Rightsizing staffing Cameco s decision to curtail U.S. operations Decrease in major applications like North Trend expansion to Crow Butte Focus on groundwater restoration reviews with alternate concentration limits 10

11 Operational Priorities Priorities safety, security, protection of environment 1. Licensed sites and hearings 2. New facility/expansion reviews 3. Guidance Perform safety and environmental reviews in parallel, depending on staff availability and available resources New applications and expansions performed in order of acceptance License renewals same priority as licensed site actions Plan to work on guidance revisions starting in FY19 as resources permit 11

12 Major Operational Accomplishments Crow Butte Marsland expansion Draft EA on December 15, 2017 SER completed on January 29, 2018 Final EA on April 30, 2018 License amendment completed on May 23, 2018 Kennecott Sweetwater license renewal SER completed on February 28, 2018 Draft EA completed on March 26, 2018 Uranium One Ludeman major expansion Draft EA completed on February 27, 2018 SER completed on March 1,

13 Minor Operational Accomplishments Completed 12 inspections and 8 site visits 7 operating UR site inspections 5 decommissioning UR site inspections 7 DOE observational site visits 1 UR site visit (ANC-Gas Hills) Completed 15 license amendments/verifications Financial surety updates Removal of satisfied license conditions Verification of radiation protection actions Verification of groundwater actions 13

14 Operating/Licensed Sites 1. Cameco Smith Ranch ISR WY decision to curtail 2. Cameco Crow Butte ISR NE - decision to curtail 3. Uranium One Willow Creek ISR WY 4. Ur Energy/Lost Creek Lost Creek ISR WY 5. Uranerz Nichols Ranch ISR WY 6. Strata Energy Ross ISR WY 7. Kennecott Sweetwater Standby Conventional Mill WY 8. Uranium One Moore Ranch (not constructed) ISR WY 9. Powertech Dewey Burdock (not constructed) ISR SD 10. Hydro Resources Inc. Crownpoint (not constructed) ISR NM 11. AUC Reno Creek (licensed on 2/17/17) (not constructed) ISR WY 14

15 Status of Major Licensing Actions Review Safety Status Environmental Status Licensing Decision Cameco Crow Butte Marsland Complete 1/29/18 Complete 4/30/18 Complete 5/23/18 Uranium One Ludeman Complete 3/1/18 On track for 8/3/18 (sch) On track for 8/31/18 (sch) Kennecott Sweetwater Complete 2/28/18 On track for 7/20/18 (sch) On track for 8/31/18 (sch) Lost Creek East/KM Horizon On track for 8/7/18 (sch) BLM Lead Potentially WY Cameco Smith Ranch Renewal Scheduled for 9/25/18 (at risk) Scheduled for 9/20/18 Scheduled for 9/27/2018 (at risk) 15

16 Hearings (schedules only) 1. Powertech Dewey Burdock On October 19, 2017, ASLB granted summary disposition of NHPA consultation contention. NEPA cultural resources contention is the sole remaining contention. Licensee petition for review submitted to the Commission on November 20, On April 12, 2018, ASLB suspended evidentiary hearing dates pending developments in Staff s approach to resolve remaining contention. 2. Cameco Crow Butte License Renewal ASLB issued partial initial decision for Contention 1 (Consultation & Tribal Cultural Properties) on May 26, Licensee petition for review submitted to the Commission on June 20, ASLB issued second partial initial decision on other contentions on December 6, Licensee and Consolidated Intervenors petitions for review submitted to the Commission. 3. Cameco Crow Butte Marsland Evidentiary Hearing is currently scheduled for October 30 November 1, Cameco Crow Butte North Trend On hold per applicant. ASLB will set schedule once actions complete. 16

17 Status of Radiation Protection Issues September 14, 2017 NRC webinar on Radiation Protection issues (ML17262A496). 33 participants, including NRC, NMA, operating UR facilities, Wyoming DEQ, and public Five topics, including examples of acceptable methods for: radiation surveys meteorological data effluent quantities public dose calculations NRC/DOT transportation requirements No new issues identified since September 2017 NRC staff is available to answer questions NRC staff intends to complete the Radon ISG Register at the NRC RAMP website to download MILDOS-AREA version

18 ACLs at ISR facilities Genesis of ACLs in EPA RCRA and CERCLA CERCLA Section 121(d)(2)(B)(ii) RCRA 40 CFR Part UMTRCA 40 CFR Part (a)(2)(iv) NRC Regulations: 10 CFR Part 40, Appendix A, Criterion 5B(5) contains ground water restoration standards, ACLs allowed under 5B(5)(c) 18

19 ACLs at ISR facilities Guidance for ACLs at conventional uranium mill sites NUREG 1620, Appendix K ACLs at ISR sites - case by case, based on regulations Will incorporate into a revised NUREG 1569, hold workshops with interested stakeholders, send draft out for public comment One ACL application for Wellfield at ISR facility under review Note that ACLs at ISRs have been discussed in evidentiary hearings for Crow Butte and Strata Ross 19

20 ACLs at ISR facilities (cont d) 10 CFR Part 40, Appendix A, Criterion 5B(6) contains specific criteria for ACLs Present no significant hazard Will not pose a substantial present or potential hazard to human health or the environment Consideration of practicable corrective actions Limits are as low as reasonably achievable Potential adverse effects on ground-water quality Potential adverse effects on hydraulically-connected surface water quality 20

21 ACLs at ISR facilities Specific Factors (a) Potential adverse effects on ground-water quality, considering (i) The physical and chemical characteristics of the waste in the licensed site including its potential for migration; (ii) The hydrogeological characteristics of the facility and surrounding land; (iii) The quantity of ground water and the direction of ground-water flow; (iv) The proximity and withdrawal rates of ground-water users; 21

22 ACLs at ISR facilities Specific Factors (cont d) (v) The current and future uses of ground water in the area; (vi) The existing quality of ground water, including other sources of contamination and their cumulative impact on the ground-water quality; (vii) The potential for health risks caused by human exposure to waste constituents; (viii) The potential damage to wildlife, crops, vegetation, and physical structures caused by exposure to waste constituents; (ix) The persistence and permanence of the potential adverse effects. 22

23 ACLs at ISR facilities Specific Factors (cont d) (b) Potential adverse effects on hydraulically-connected surface water quality, considering (i) The volume and physical and chemical characteristics of the waste in the licensed site; (ii) The hydrogeological characteristics of the facility and surrounding land; (iii) The quantity and quality of ground water, and the direction of ground-water flow; (iv) The patterns of rainfall in the region; (v) The proximity of the licensed site to surface waters; 23

24 ACLs at ISR facilities Specific Factors (cont d) (vi) The current and future uses of surface waters in the area and any water quality standards established for those surface waters; (vii) The existing quality of surface water including other sources of contamination and the cumulative impact on surface water quality; (viii) The potential for health risks caused by human exposure to waste constituents; (ix) The potential damage to wildlife, crops, vegetation, and physical structures caused by exposure to waste constituents; and (x) The persistence and permanence of the potential adverse effects.10 CFR Part 40, Appendix A, Criterion 5B(6) contain specific criteria for ACLs 24

25 Illustration of ISR ACL Example POC POC Point of compliance well (where ACL is approved) POE USDW Exemp t Aquife r Exempt Aquifer GW Flow Direction Original Perimeter Ring Excursion Monitoring Well ( 400 ft from well field boundary) POE/POC Point of Exposure (POE) Well at edge of exempt aquifer zone : Location approved by NRC for long term monitoring compliance of approved ACL 25

26 Questions? Picture taken near Jeffrey City/Split Rock, WY 26