Decommissioning and

Long-Term Care for Uranium

Production facilities in the U.S.

Daniel M. Gillen

What’s in this session?

• Site Types

• Decommissioning Laws and

Regulations

• Closure Plans and

Processes

• Technical Considerations

• Long-Term Control

• Outcomes

Uranium Recovery Site Types • Legacy Tailings Sites – old, unlicensed,

abandoned mill tailings sites identified and cleaned up by DOE with NRC concurrence

• Regulator licensed sites • Conventional Mills - uranium recovery sites using

conventional ore milling processes

• In Situ Recovery Facilities – uranium recovery through fluid injection into ore body, pumping of resulting uranium–bearing solution, and separation of the uranium in a processing facility

The Law: UMTRCA (The

Uranium Mill Tailings Radiation Control Act)

• The tailings wastes must be transferred to DOE when DOE and NRC determine that remedial action is completed

• The property and minerals must be maintained pursuant to a license issued by the NRC

The Responsible Parties in

the U.S.

EPA

DOE or Licensee

(Operator)

NRC (Regulator)

• The Environmental Protection Agency sets the standards

• The Department of Energy or Licensee designs and constructs to meet standards; DOE is Long-term custodian

• The Nuclear Regulatory Commission Develops Regulations and Guidance and Reviews and Concurs in Design and Construction

UMTRCA (Uranium Mill

Tailings

Radiation

Control Act)

5

Technical Goals for

Remediating a Uranium

Processing Site

• Reduce/Eliminate radiological and non-

radiological impacts

• Stabilize contaminated materials and

remove from contact with public

• Protect/cleanup groundwater

6

Regulations – U.S. standards for

remediation of uranium production sites

General Control

Stability Period

Land and Structure Cleanup

Groundwater Cleanup and Protection

Radon Attenuation

7

General Control • The owner or operator must close the facility in a

manner that:

– Minimizes the need for further maintenance

– Controls, minimizes or eliminates post-closure escape of hazardous materials to the ground or surface waters or to the atmosphere

8

Stability period

• Control of radioactive materials and their listed constituents shall be designed to be effective for up to one thousand years, to the extent reasonably achievable and, in any case, for at least 200 years

9

Land Cleanup

• Remedial actions shall be conducted so that the concentration of radium-226 in land averaged over any area of 100 square meters shall not exceed the background level by more than

– 5 pCi/g, averaged over the first 15 cm of soil below the surface, and

– 15 pCi/g, averaged over 15 cm thick layers of soil more than 15 cm below the surface.

10

Building Cleanup

• In any occupied or habitable building

– Remedial action must achieve, an annual

average radon decay product concentration

(including background) less than 0.02 WL.

One working level is equal to approximately

200 picocuries per liter. 0.02 = 4 pCi/l

11

Groundwater cleanup

and protection • Control of radioactive materials and constituents

shall include a system of disposal designed to ensure that hazardous constituents entering the groundwater from a tailings site will not exceed the established concentration limits in the uppermost aquifer underlying the site beyond the point of compliance.

12

Radon attenuation

• Control of radioactive materials shall provide reasonable assurance that releases of radon-222 to the atmosphere will not exceed an average release rate of 20 picocuries per square meter per second.

13

Additional NRC Regulations

Slopes

Embankment and cover slopes must be relatively flat after final stabilization to minimize erosion potential and to provide conservative factors of safety assuring long-term stability. Slopes should not be steeper than about 5h:1v.

Cover

A full self-sustaining vegetative cover must be established or rock cover employed to reduce wind and water erosion to negligible levels.

Direct Gamma

Direct gamma exposure from the tailings or wastes should be reduced to background levels. 14

Additional NRC Regulations Long-Term Funding

A minimum charge of $250,000 (1978 dollars) for long-term surveillance must be paid by each conventional mill operator.

Variance in funding requirements may be specified by the NRC.

Long-Term Care

Active maintenance should not be necessary to preserve isolation.

DOE annual inspections as a minimum.

Reports to NRC required.

Long-Term Licenses

General License Issued to DOE for multiple sites

Effective when NRC accepts a site Long-Term Surveillance Plan (LTSP)

Specifies general LTSP content 15

Licensed Sites

Timeliness Requirements

• Licenses expire on the date stated in the license unless the licensee has filed an application for renewal

• A licensee must begin the closure process within 60 days if:

– The license has expired

– The licensee has decided to permanently cease principal activities

– No principal activities under the license have been conducted for a period of 24 months

Decommissioning Plan (DP) or

Remedial Action Plan (RAP)

Content

DP/RAP

Environmental

Impact Assessment

Remediation Design based

on the standards

Construction Specifications

Inspection Plan

17

Geotechnical and Hydrologic

Engineering Considerations

Site and material characterization

Slope Stability

Settlement

Liquefaction potential

Cover and Liner Design

Construction considerations

(methods, testing, inspection)

Erosion Protection

Cover Design

• To meet regulatory requirements, cover

designs for uranium mill tailings disposal

cells should:

resist

erosion promote runoff

limit infiltration

minimize radon

emissions

reduce long-term

maintenance

minimize animal and

human intrusions

reduce risk to human health

and the environment

A simple rock cover (radon barrier, bedding,

riprap) is common to many legacy sites in the

western U.S.

Cover Development in the U.S

• There are no standard procedures or “recipes” for

designing covers.

• Cover performance data is indicating that many covers

are not behaving as designed due to changes in the

soil properties, specifically saturated hydraulic

conductivity.

• Nature is altering some cells in the short time they have

been in existence.

Future Considerations

• Cover designs may need to abandon the

barrier control philosophy and move

toward an ecosystem-type approach

• Incorporating plants in combination with

rock materials will create self-sustaining

covers that can approach elimination of

infiltration while providing erosion

resistance.

After Closure Process

Conventional Mills and Legacy Sites

Licensee/DOE submits Completion Report

NRC Reviews; RAIs

Licensee/DOE submits Final

NRC Issues CRR

NRC Terminates specific license

DOE submits LTSP

NRC Reviews/RAIs

DOE submits Final

NRC accepts LTSP and DOE is licensed

Continuing activity under General License and LTSP

Closure Process -

In-Situ Recovery Facilities

• Process similar to Conventional Mills just

described except:

– Licensee performs aquifer restoration

– No tailings waste to turn over to DOE (no LTSP)

– Site released for unrestricted use

Long-Term Surveillance Plan • Legal description of the disposal site

• Detailed description of final site conditions, including groundwater characterization

• Description of the surveillance program – Inspection and reporting frequency

– Frequency and extent of any monitoring

– Constituent limits for groundwater

– Inspection personnel qualifications

– Inspection procedures

– Recordkeeping

• Criteria for follow-up inspections

• Criteria for instituting maintenance

Durango LTSP

DOE Long-Term Care

Inspections Inspection Reports

LTSP Amendments

NRC Oversight

Maintenance as

necessary

Monitoring as required

Ongoing Long-Term Care

Program

Location of Legacy Tailings Sites

. . .

.

. . . .

. . . . . . . . . . . . . .

DOE Long Term Care and

Inspection

• An inspection is conducted at least annually

at each disposal site

• At least two inspectors with appropriate

technical experience comprise an inspection

team

Inspection Considerations

• During an inspection, site inspectors must: – Observe the condition of site (e.g., erosion features

such as gullies or rills, sediment accumulations, vandalism, animal intrusion, plant growth)

– Record observations

– Take and record photographs as necessary, to document conditions at the disposal site and to provide a continuous record for monitoring changing conditions over time

– Collect monitoring data as required by the specific LTSP

Maintenance and Repair

• Examples of maintenance or repair:

– Planned maintenance: grass mowing, road

maintenance, removal of weeds or debris, vegetation

control, or replacement of signs

– Unscheduled maintenance: removal of deep-rooted or

other unwanted vegetation on the disposal cell

– Repair: damage to disposal cell, fence, gate or locks,

surveillance features, wells or roads

Emergency Measures • Examples of disposal site conditions that may

require emergency measures:

– Surface rupture of the disposal cell through subsidence,

cracking, sliding, or slope instability

– Deterioration of the erosion protection rock on the

disposal cell or in the drainage ditches

– Monitored or observed seepage

– Development of gullies on or adjacent to disposal site

property that could affect the integrity of the disposal cell

Closure Outcomes

for Uranium Recovery Sites

• Conventional Mills and Tailings

– Unrestricted Release for sites from which the

tailings were moved to another disposal cell

– DOE Long-Term custodian of tailings under

Part 40 general license

• ISRs

– Unrestricted Release

Salt Lake City, Utah Site before

Salt Lake City Site after

Tuba City, Arizona Site before

Tuba City after

Canonsburg, Pennsylvania

Site before

Canonsburg after

Outcome – In Situ Recovery

Site

25 Tailings Sites under DOE Long-

Term Care (19 Legacy and 6 NRC-

Licensed)

Status

Decommissioning Summary • Regulations set decommissioning requirements for:

– Timeliness of actions

– Soil and structure cleanup

– Groundwater restoration and cleanup

– Design of tailings cells • Siting

• Stability

• Radon reduction

• Groundwater Protection

• NRC review processes and outcomes vary by type of site – Licensing vs Concurrence

– Unrestricted release vs Long-term care

Long-Term Care Summary

UMTRCA requires DOE Long-Term Care under NRC license

NRC regulations include general licenses

NRC regulations require $ for long-term care, set LTSP content, and require annual inspections and reports

LTSP describes site, surveillance program, and criteria for follow-up and maintenance

Process includes simultaneous transfer of responsibility from licensee to DOE

Some Key points of Regulatory Programs

for Uranium Production Activities • Develop a National policy and strategy, essential for effective

execution of licensing and remediation programs for uranium

production activities. The policy expresses the government’s intent;

the strategy sets out the mechanisms for implementing the policy.

• Establish clear laws, with focus on public health and safety and

protection of the environment.

• Define the roles of the regulator, operator, and other involved

agencies/organizations; maintain separation.

Key Points • Clearly commit an adequate financial budget for effective

regulation.

• Define the regulatory process (organizational interaction)

from application to post-closure.

• Develop or adopt clear and comprehensive

regulations/standards that are practicable and can be

readily applied by operators and regulators.

Key Points • Include requirements on timeliness for decommissioning

uranium production facilities.

• Include these important aspects of regulation:

– environmental impact;

– risk assessment;

– stability and control of waste;

– radiological criteria for soil, water and air;

– financial assurance requirements for operators;

– long-term surveillance.

• Develop a strong program of inspection and

enforcement.

•

Key Points

• Consider the entire lifecycle at the beginning of a project.

Develop closure plans at the inception of the project.

• Prioritize remedial action based on risk to health and

safety and the environment.

• Maintain strong programs of stakeholder involvement

throughout the entire lifecycle of facilities.

• Learn from experience; licensing and remediation is an

evolving process.

Not a Mill Site

Questions?