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

2. 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

3. Licensing Process Phases Application/ Licensing Operations Decommissioning Long Term Care Project Manager Technical Reviewers (Geologist, Civil Engineer, Health Physicist, Hydrologist) Environmental reviewers 1-2 years Decades, with renewal Every 10 years Project Manager Technical Reviewers Environmental Reviewers Inspectors ApplicantLicensee Licensee/DOE Project Manager Technical Reviewers Environmental Reviewers Inspectors Up to several years For decom; Long-term care is open ended

4. Regulator issues license Regulator performs full Technical and Environmental Review Regulator performs Acceptance Review Applicant submits Technical and Environmental Report Regulator and applicant hold pre-application discussions Applicant conducts site selection and characterization Phase I: Application Yes

5. 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

6.  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 Environmental Report submittal

7. 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

8. Technical 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

9. Application 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

10. Technical Review Steps Team begins technical review RAI’s issued Revisions to application submitted Remaining open issues addressed in meetings RAI=Request for Additional Information SER=Safety Evaluation Report Review complete; Conclusions in SER

11. Environmental 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

12. 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

13. Public Involvement  NRC Public Website  Freedom of Information Act requests  Specific 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

14. License 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

15. License 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

16. 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

17. Phase II: Operations Licensee performs baseline monitoring and constructs facility Regulator conducts construction inspection and oversight Regulator issues license amendment to operate Licensee operates facility Regulator inspects and renews/amends license Licensee decision to close facility

18. 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

19. Environmental Monitoring Types –Radon –air particulates –biota –soils –direct radiation –Water Locations Frequency of sampling Action levels and corrective action

20. ALARA 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.

21. 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)

22. 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

23. 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

24. Licensing 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

25. Summary LLicensing can be looked at as having 3 main phases; Application, Operation, Closure AApplication process includes: –a–application preparation and submittal –h–hearing process opportunities –t–technical and environmental review –p–public involvement –l–license issuance or denial OOperational actions include monitoring, radiation safety, license amendments and renewal, recordkeeping and reporting, and inspection and enforcement

26. Questions?