U.S Regulatory Process for Uranium Production Facility Licensing and Operation Daniel M. Gillen.

U.S Regulatory Process for Uranium Production Facility Licensing and Operation

Daniel M. Gillen

What’s in this Session

What’s in this Session

• Discussion of what comprises the initial licensing and operational phases of the facility lifecycle– Phase 1: License application and issuance

process– Phase 2: Regulator/Licensee interactions

during operations

• Phase 3: Closure/License Termination will be discussed in a separate presentation

Licensing Process PhasesLicensing Process Phases

Application/Licensing

Operations

Decommissioning Long Term Care

Project ManagerTechnical Reviewers(Geologist, Civil Engineer, Health Physicist, Hydrologist)Environmental reviewers

1-2 yearsDecades, with renewalEvery 10 years

Project ManagerTechnical ReviewersEnvironmental ReviewersInspectors

Applicant Licensee Licensee/DOE

Project ManagerTechnical ReviewersEnvironmental ReviewersInspectors

Up to several yearsFor decom; Long-term care is open ended

Phase I: ApplicationPhase I: Application

Yes

Yes

• Applicant selects best site considering:– Distance from mines– Waste storage (groundwater, below grade cells, surface

water hydrology)– Transportation routes

• Pre-application area and site characterization– Use of adjacent lands and waters– Population distribution– Historic, scenic, and cultural resources– Meteorology– Geology/seismology– Hydrology (surface and groundwater)– Ecology– Background radiological characteristics

Site Selection, Characterization

License Application general content– Proposed activities– Site Characteristics– Mill process and equipment and Waste management system– Operations (Organization, Security, Radiation Safety)– Decommissioning Plans– Financial Assurance– Accident Analysis

Environmental Report general content– Description of the Proposed Action– Description of the Affected Environment– Identification of Adverse Impacts that cannot be avoided– Alternatives to the Proposed Action

Application and EnvironmentalReport submittal

Technical and Environmental Review

Technical and Environmental Review

• Goal is protection of public health and safety and environment

• A review team is assigned to the project

• Acceptance Review first• Application review schedule set• Reviews use applicable

standard review plans

Technical Review TeamTechnical Review Team

• The team is led by the Project Manager

• Uranium recovery application review teams– Health Physicists– Hydro-geologists– Geotechnical Engineers– Surface water hydrology and

erosion experts– Financial Specialists

Application GuidanceApplication Guidance

• Standard Format and Content Guides for Applicants (What needs to be submitted)

• Standard Review Plans for review staff– Ensure reviews are of consistent quality and

uniformity– What is to be reviewed– Basis for the review– How the review is to be accomplished– What the staff will find acceptable– Conclusions that need to be made

Technical Review StepsTechnical Review Steps

Team beginstechnicalreview

RAI’sissued

Revisions toapplicationsubmitted Remaining

open issuesaddressed inmeetings

RAI=Request for Additional Information

SER=Safety Evaluation Report

Review complete;Conclusions inSER

Environmental ReviewEnvironmental Review

Safety and environmental reviews conducted in parallel

Law requires Federal agencies to consider the environmental impacts of their actions

Initiated by application for a new license, or a change to an existing license

Focus is on the environmental impacts of the proposed action

Financial Assurance

• Licensees must provide:– Certification of

financial assurance to guarantee that funds will be available for decommissioning

– Breakdown of estimated costs for site closure

– Commitments for annual update and updates for any planned expansions or operational changes

Public InvolvementPublic Involvement

NRC Public WebsiteFreedom of Information Act requestsSpecific hearing opportunities provided:

Individuals, citizen groups, private businesses, and governmental bodies have received hearing status

Input in the environmental evaluation process (scoping and comment)

Meetings with licensees/applicants open to public

License IssuanceLicense Issuance

• If the finding is that the application/proposal for a uranium recovery facility complies with laws and regulations:– Issue letter to applicant– Attach Safety Evaluation Report, reference to

the Environmental Assessment document (with FONSI), and a License with certain license conditions as appropriate

License DenialLicense Denial

If the finding is that an application does not comply with the laws and regulations:– Issue a notice of proposed denial or a notice

of denial of the application– Inform the applicant in writing of:

The nature of any deficiencies or the reason for the proposed denial or the denial, and

The right of the applicant to demand a hearing

Key Areas Addressed in Licenses (License Conditions)

Key Areas Addressed in Licenses (License Conditions)

• Authorized place of use and production limitations• Tie to commitments in Application• Financial Assurance • SOP development• Radiation Program: Training, Bioassay, HP surveys,

ALARA, Inspections, Release of equipment and materials

• Effluent and Environmental Monitoring• Waste Management• Record Keeping and Reporting

Phase II: OperationsPhase II: Operations

Facility Operation

• During facility operation, the licensee:– Meets all license conditions– Gathers environmental and

effluent monitoring data– Monitors workers– Keeps required records– Reports to Regulator as

required by regulations and license

– Requests amendment and renewal of license as necessary

Environmental MonitoringEnvironmental Monitoring

• Types– Radon– air particulates– biota– soils– direct radiation– Water

• Locations• Frequency of sampling• Action levels and corrective

action

ALARA PrincipleALARA Principle

• ALARA = As Low As (is) Reasonably Achievable

• Licensees must use procedures and engineering controls to achieve occupational doses and doses to members of the public that are ALARA.

Recordkeeping and Reporting

Recordkeeping and Reporting

Records need to be kept related to:– Implementation of the radiation protection program– Radiation surveys and instrument calibration– Occupational doses and planned special exposures– Doses to members of the public– Waste disposal– Receipt and transfer of source or byproduct material – Spills– As built drawings– Environmental monitoring (biota, air, groundwater,

surface water)

Recordkeeping and Reporting(Continued)

Recordkeeping and Reporting(Continued)

Reports need to be sent to Regulator on:– Theft or loss of material– Incidents where doses are exceeded– Exposures, radiation levels, and

concentrations of radioactive material exceeding the constraints or limits

– Unplanned contamination events– Results of effluent monitoring

Inspection and Enforcement

• Regulator inspectors must pass qualification• Inspection Manual Chapter 2801 addresses how uranium mill

inspected• Frequency generally 1/yr, but depends on operating history• May be announced or unannounced• Team: Lead inspector (HP); hydro-geologist, geotechnical engineer

as needed• Inspect records, interview staff, perform confirmatory surveys,

observe activities• Enforcement action may follow: NOV’s, Civil Penalties, Orders

Licensing ActionsLicensing Actions

• License Amendments– Licensee requests for changes to existing licensed

activities and conditions require the issuance of license amendments

• License Renewals– Currently, uranium recovery facilities are required to

renew every 10 years

• Licenses may be revoked, suspended, or modified by Regulator

Summary

Licensing can be looked at as having 3 main phases; Application, Operation, Closure

Application process includes:– application preparation and submittal– hearing process opportunities– technical and environmental review– public involvement– license issuance or denial

Operational actions include monitoring, radiation safety, license amendments and renewal, recordkeeping and reporting, and inspection and enforcement

Questions?