riverton, wyoming 82501 wyoming uranium mill tailings … · riverton, wyoming 82501 subject:...

JUL 1 8 1994Mr. P.J.L. LyonsGeneral SuperintendentUmetco Minerals CorporationP.O. Box 151Riverton, Wyoming 82501

SUBJECT: AMENDMENT 27 OF LICENSE NUMBER SUA-648 FOR THE UMETCO GAS HILLS,WYOMING URANIUM MILL TAILINGS SITE

Dear Mr. Lyons:The U.S. Nuclear Regulatory Commission has completed a review of your annualsurety update for the Umetco Gas Hills mill tailings site, as submitted inyour letter dated June 14, 1994. The revised cost estimate accounts for workcompleted and includes the appropriate adjustment to account for the effectsof inflation. Therefore, the proposed surety amount of $8,566,324 isacceptable. We understand that the surety bond held by the State of Wyomingremains in the amount of $11,104,900, which exceeds the required suretyamount.

The enclosed Technical Evaluation Report contains NRC's assessment of thelicensing action and the recommended license change. The license is beingreissued to incorporate this change exactly as requested.

An environmental assessment for this action is not. required since thisaction is categorically excluded under 10 CFR 51.22 (c)(11), and anenvironmental report from the licensee is not required by 110 CFR 51.60(b)(2).

Any questions should be addressed to Allan Mullins at (301) 415-6693.

Sincerely,

Joseph J. Holonich, ChiefHigh-Level Waste and

Uranium Recovery Projects BranchDivision of Waste ManagementOffice of Nuclear Material

Safety and Safeguards

Enclosures:

1. Technical Evaluation ReportL 2. Source Material License SUA-648

cc: J. Hough, RCPD, WY, WDEQ

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TECHNICAL EVALUATION REPORT

DATE: 81994

,DOCKET NO. 40-0299 LICENSE NO. SUA-648

LICENSEE: Umetco Minerals Corporation

FACILITY: Gas Hills uranium mill

PROJECT MANAGER:

Allan Mullins

TECHNICAL REVIEWER:

Richard Turtil

SUMMARY AND CONCLUSIONS:

The Licensee provided the annual surety update required by LicenseCondition (LC) 55 by letter dated June 14, 1994. The revised costestimate of $8,566,324 accounts for work remaining to be done andincludes the appropriate adjustment for inflation. The proposed suretyamount of $11,104,900 is in excess of requirements and is therefore

,acceptable.

DESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:

The licensee submitted the annual surety update in their letter of June14, 1994, and requested that the surety bond, which is held by the Stateof Wyoming, be maintained at the current amount of $11,104,900.

TECHNICAL EVALUATION:

The Licensee revised the reclamation cost estimate to reflect completedtasks and current dollar amounts for remaining work. The revised costestimate of $8,566,324 for completion of reclamation activities isreasonable. The total surety amount includes $1,511,100 for a bondrequired by the Wyoming Department of Environmental Quality. The suretybond is sufficient to more than cover both required sureties.

RECOMMENDED LICENSE CHANGE:

The staff recommends that a minor change to Source Material License SUA-648, LC55, be made to confirm the adequacy of the current surety held bythe State of Wyoming. The revised license condition will read asfollows:

55. The licensee shall maintain an NRC-approved financial suretyarrangement, consistent with 10 CFR 40, Appendix A, Criteria 9 and 10,adequate to cover the estimated costs, if accomplished by a third party,for decommissioning and decontamination of the mill and mill site,

reclamation of any tailings or waste disposal areas, ground waterrestoration as warranted and the long-term surveillance fee. Withinthree (3) months of NRC approval of a revisedreclamation/decommissioning plan, the licensee shall submit, for NRCreview and approval, a proposed revision to the financial suretyarrangement if estimated costs in the newly approved plan exceed theamount covered in the existing financial surety. The revised suretyshall then be in effect within 3 months of written NRC approval.

Annual updates to the surety amount, required by 10 CFR 40, Appendix A,Criteria 9 and 10, shall be submitted to the NRC at least 3 months priorto the anniversary date which is designated as September 13 of eachyear. If the NRC has not approved a proposed revision to the suretycoverage 30 days prior to the expiration date of the existing suretyarrangement, the licensee shall extend the existing surety arrangementfor one year. Along with each proposed revision or annual update, thelicensee shall submit supporting documentation showing a breakdown ofthe costs and the basis for the cost estimates with adjustments forinflation, maintenance of a 15 percent contingency fee, changes inengineering plans, activities performed and any other conditionsaffecting estimated costs for site closure. The licensee shall alsoprovide the NRC with all surety related correspondence submitted to theState of Wyoming, a copy of the State's surety review and the finalapproved surety arrangement. The licensee shall also ensure that thesurety, where authorized to be held by the State, expressly identifiesthe NRC portion of the surety and covers the decommissioning anddecontamination of the mill and mill site, reclamation of the tailingsand waste disposal areas, ground water restoration as warranted and thetransfer of the long-term surveillance fee to the U.S. General Treasury.The basis for the cost estimate is the NRC approvedreclamation/decommissioning plan or NRC approved revisions to the plan.The minimum considerations used by the NRC in the review ofdecommissioning and reclamation estimates are shown in the attachment toSUA-648 entitled, "Recommended Outline for Site Specific Reclamation andStabilization Cost Estimates." Licensee submittals of reclamation/decommissioning plans and annual updates should follow this guidance.

Umetco Gas Hills' currently approved surety instrument, a surety bondwith Seaboard Surety Company (No. 861822) held by the State of Wyoming,shall be continuously maintained in an amount no less than $8,566,324for the purpose of complying with 10 CFR 40, Appendix A, Criteria-9 and10 until a replacement is authorized by both the State and NRC.

[Applicable Amendments: 1, 2, 13, 19, 20, 26, 27]

ENVIRONMENTAL IMPACT EVALUATION:

The staff has determined under exclusions contained in 10 CFR 51.22(c)(11) that further environmental documentation is not required furthis amendment. The amendment is administrative, recognizing theadequacy of the existing bond held by the State of Wyoming. Therefore,an environmental assessment by this office for the proposed action is

2

categorically excluded under 10 CFR 51.22 (c)(11), and is not requiredby 10 CFR 51.60 (b)(2).

REFERENCE:

Letter from P.J.L. Lyons to Joseph J. Holonich, June 14, 1994, "Request toAmend License Condition No. 55."

3

NRC FORM 374(10-89) PAGE 1 -_OF 14 PAGESU.S. NUCLEAR REGULATORY COMMISSION

MATERIALS LICENSE

1ý

Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10,Code of Federal Regulations, Chapter I. Parts 30, 31, 32, 33, 34, 35, 39, 40 and 70, and in reliance on statements and representations heretoforemade by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, source, and special-nuclear material designated below; to use such material for the purpose(s) and at the place(s) designated below; to deliver or transfer such materialto persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conditionsspecified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations and orders of the NuclearRegulatory Commission now or hereafter in effect and to any conditions specified below.

Licensee

Umetco Minerals CorporationI. 3. License number

SUA-648, Amendment No. 27A" P. 0. Box 151

Riverton, Wyoming

6. Byproduct, source, and/orspecial nuclear material

82501 4. :Expiration date Until terminatedUni terminate

5. Docket orReference No.

[APPICaDle Amendments: ZCZJ40-0299

7. Chemical and/or physicalform

8. Maximum amount that licenseemay possess at any one timeunder this license

Natural Uranium Any Unl imited

9. Authorized place of use: The licensee's uranium milling and heap leachfacilities located in Natrona County, Wyoming.

10. For use in accordance with statements, representations and conditions containedin Sections 4.1,"4.2, 4.3, 4.4, 4.5, and 4.6 of the submittal dated May 28, 1992,except where superseded by license conditions listed below.

Whenever the word "will" is:used in the-above.referenced sections, it shalldenote a requirement.

[Applicable Amendments: 22]

11. DELETED by Amendment No. 22.


13. The licensee is hereby exempted from the requirements of Section 20.203(e)(2) of10 CFR 20 for areas within the mill, provided that all entrances to the mill areconspicuously posted in accordance with Section 20.203(e)(2) and with the words,"Any area within this mill may contain radioactive material."

14. The RSO shall meet the minimum qualifications specified in Section 2.4.1 ofRegulatory Guide 8.31 dated May 1983.

15. Written procedures shall be established for nonoperational activities to includeenvironmental monitoring, bioassay analysis, and instrument calibrations. An up-to-date copy of each written procedure shall be kept in the area to which itapplies.

-• ..,

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NRC Form 374A U.S. N EAR REGULATORY COMMISSION(5-84)

MATERIALS LICENSESUPPLEMENTARY SHEET

PAGE 2 OF 14 PAGESLicense number

SUA-648, Amendment No. 27Docket or Reference number

40-0299

All written procedures shall be revised and approved in writing by the RSO beforeimplementation and whenever a change in procedure is proposed to ensure thatproper radiation protection principles are being applied. In addition, the RSOshall perform a documented review of all existing procedures at least annually.


16. The RSO shall prepare and submit a quarterly radiation safety report to theGeneral Superintendent. This report shall summarize personnel exposures,bioassay results, RWPs, inspections, monitoring and survey results. In addition,the quarterly report shall include a review 'of any trends in personnel exposuresor area radiation exposure rate'levels and shall' specifically address anyunresolved safety problems:'and provide proposed corrective action.[Applicable Amendments: 22]

17. The licensee shall conduct the annual ALARA audit program as proposed in theirrenewal application dated December 30, 1985. A copy of the ALARA audit reportshall be sent to the Uranium Recovery Field Office within 30 days of completionof the audit.


19. Occupational exposure calculations shall be documented within I week of the endof each regulatory compliance period-,as specified in 10 CFR 20.103(a)(2) and10 CFR 20.103(b)(2). [Applicable Amendments: 22]

20. Calibration of all equipment utilized for, area radiation surveys and for internalexposure determinations shall be performed in accordance with Section 7 ofRegulatory Guide 8.30 dated June 1983.

21. In addition to the bioass~ay program described in Section 4.4.2.4 of the licenserenewal application dated May 28, 1992, the licensee shall comply with thefollowing:

A. Anytime an action level of 15 g/l uranium for urinalysis or 9 nCi ofnatural uranium for in vivo measurement is reached or exceeded, the licenseeshall document the corrective actions which have been performed inaccordance with Revision 1 of Regulatory Guide 8.22, dated January 1987.This documentation shall be submitted to the NRC, Uranium Recovery FieldOffice, as part of the semiannual report required by 10 CFR 40.65.

B. Anytime an action level of 35 g/l for two consecutive specimens or 130 g/luranium for one specimen for urinalysis or 16 nCi uranium for an in vivomeasurement is reached or exceeded, the licensee shall document thecorrective actions which have been performed in accordance with Revision Iof Regulatory Guide 8.22. This documentation shall be submitted to the NRC,Uranium Recovery Field Office, within 30 days of exceeding the action level.


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NRC Form 374A15-84)

U.S. NUý.. ..JAR REGULATORY COMMISSION PAGE 3 OF 14 PAGES

License number'•IIA-RdR Amc~ndrmrntn Nn •7


Docket or Reference number

40-0299

22. Release of equipment or packages from the restricted area shall be in accordancewith, "Guidelines for Decontamination of Facilities and Equipment Prior toRelease for Unrestricted Use or Termination of Licenses for Byproduct Materials"dated September 1984. [Applicable Amendments: 22]

23. Mill tailings other than samples for research shall not be transferred from thesite without specific prior approval of the NRC in the form of a licenseamendment. The licensee shall maintain a permanent record of all transfers madeunder the provisions of this condition.


25. The licensee is hereby authorized to possess byproduct material in the form ofuranium waste tailings. generated by the licensee's uranium recovery operationsauthorized under SUA-648.


27. The results of sampling, analyses, surveys and monitoring, the results ofcalibration of equipment, reports on audits and inspections, and all meetings andtraining courses required by this license and any subsequent reviews,investigations, and corrective actions, shall be documented. Unless otherwisespecified in NRC regulations, all such documentation shall be maintained for aperiod of at least 5 years.

28. The licensee shall immediately notify the NRC, Uranium Recovery Field Office, bytelephone and telegraph, of any failure to-.the tailings dam which results in arelease of radioactive material and/or:any unusual conditions which if notcorrected could lead to such a failure. This-requirement is in addition to therequirements of 10 CFRVPart 20. [Applicable Amendments: 22]


30. The licensee shall decommission the UmetcoGas Hills Uranium Mill in accordancewith their submittals dated May 2 and June 18, 1990, except for onsite disposalof materials and equipment. Notwithstanding any statements to the contraryabove, the licensee shall:

A. DELETED by Amendment No. 24.

B. For windblown tailings cleanup, the licensee shall follow the procedure assubmitted by letter dated December 21, 1990, with the following additions:

1) Umetco will conduct, as a minimum, additional micro-R-meter surveys at50-meter intervals along lines encircling the inactive tailings pile at100, 200, and 300 meters.

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NRC Form 374A U.S. NUt AR REGULATORY COMMISSION PAGE 4 OF 14 PAGES

(5-84) License number

SUA-648, Amendment No. 27Docket or Reference numberSUPPLEMENTARY SHEET4029

2) A minimum of 24 verification soil samples will be collected from thesurvey area after normal surveys are complete and analyzed forU-natural and Radium-226 ratios.

3) The results of all surveys and soil samples must be submitted in reportform to the NRC Uranium Recovery Field Office no later than 60 daysafter receipt of soil verification results.

C. All mill debris shall be disposed of in accordance with the January 10,1991, submittal. Additionally, all debris shall be placed in a manner thatavoids nesting and minimizes --voids,,. 1-Fill material must be placed in andaround each lift of debris.in sufficient volume to form a coherent mass.

All debris not specifically addressed in the May..2', 1990, submittal shallhave a maximum dimension of 30 feet and a maximum volume of 30 cubic feet.Debris not meeting these requirements shall be reduced in size. Emptydrums, tanks, or other objects with hollow volumes greater than 5 cubic feetshall be reduced in volume by at least 70 percent.

[Applicable Amendments: 14, 16, 17, 22, 24].

31. Before engaging in any activity not previously, evaluated by the NRC, the licenseeshall ,prepare and record an environmental evaluation of such activity. When theevaluation indicates that such activity may-result in a significant adverseenvironmental impact that'was not assessed or that is-greater than assessed, thelicensee shall provide a written evaluation of such.activities and obtain priorapproval from the NRC in the form.of a -li.cense amendment..

32. The licensee shall conduct an annual survey of."land use (private residences,grazing areas, private and public potable water and agricultural wells, andnon-residential structures and uses) in the area within five (5) miles (8 km) ofany portion of the restricted area boundary and submit a report of this survey Luthe NRC, Uranium Recovery Field Office. This report shall indicate anydifferences in land use from that described in the last report.

33. In order to ensure that no disturbance of cultural resources occurs in thefuture, the licensee shall have an archeological and historical artifact surveyof areas of its property, not previously surveyed, performed prior to theirdisturbance, including borrow areas to be used for reclamation cover. Thesesurveys must be submitted to the NRC and no such disturbance shall occur untilthe licensee has received authorization from the NRC to proceed.

In addition, all work in the immediate vicinity of any buried cultural depositsunearthed during the disturbance of land shall cease until approval to proceedhas been granted by the NRC.

34. The licensee shall conduct the environmental monitoring program as summarized inTable 6.9 of the FES (NUREG-0702) and Section 4.5 of the license renewalapplication dated May 28, 1992 with the following modifications:

NRC Form 374A U.S. N, EAR REGULATORY COMMISSION PAGE 5 OF 14 PAGES(.5-84) License number

MATERIALS LICENSE SUA-648, Amendment No. 27Docket or Reference number

SUPPLEMENTARY SHEET 40-0299

Air particulate and integrated radon progeny monitoring is not required at theformer bunk house area.

Air particulate monitoring is not required at the former yellowcake area effluentstack.

TLDs located at the air particulate monitoring stations shall be exchanged

quarterly.

Soil sampling at the air particulate monitoring stations is not required.

Notwithstanding the above, al:l ground-water "monitoring requirements will be asspecified in License Condition No. 35.

[Applicable Amendments: 8, 22]

35. The licensee shall implement a ground-water compliance monitoring programcontaining the following:

A. Sample Lower Wind River wells MW-i, 2, 4, 6, 7, 10, 16, 17, 18, 19, 20, 23,24, 25, 26, .27, 30; DW-2, 3; and Upper Wind River wells EW-1, 2, 3; GW-1, 2,3, 4, 5, 6, 7, 8; HW-2, 3, 4; PW-1, 2, 3, 4, 5, 6; and RW-2 on a semiannualfrequency for arsenic, beryllium, nickel, selenium, natural uranium,combined radium-226 and 228, thorium-230, lead-210, gross alpha, field pH,total dissolved solids, field conductivity, sulfate, iron, nitrate andchloride.

B. Comply with the following ground-water protection standards in mg/l (exceptwhere otherwise specified):

At Lower Wind River point of compliance wells MW-I and MW-21A withbackground being recognized in well MW-2: arsenic = 0.05, beryllium = 0.05,nickel = 0.06, selenium = 0.01, natural uranium = 89.0 pCi/l, combinedradium-226 and 228 = 31.5 pCi/l, thorium-230 = 6.6 pCi/l, lead-210 =5.0 pCi/l, and gross alpha = 146.0 pCi/l.

At Upper Wind River point of compliance Wells GW-7 and GW-8 with backgroundbeing recognized in well LA-2: arsenic = 0.05, beryllium = 0.01, nickel =0.04, selenium = 0.01, natural uranium = 199 pCi/l, combined radium-226 and228 = 24.9 pCi/l, thorium-230 = 4.8 pCi/l, lead-210 = 4.6 pCi/l, and grossalpha = 17.8 pCi/l.

C. Implement the Lower Wind River corrective action program described in theDecember 4, 1989, submittal and the Upper Wind River Corrective ActionProgram described in the August 28, 1989, submittal due to exceeding ground-water protection standards with the objective of returning theconcentrations of hazardous constituents to the ground-water protectionstandards specified in Subsection (B). Additionally, a leak detectionsystem shall be installed in the proposed Lower Wind River evaporation pond.

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NRC Form 374A U.S. NU.. _AR REGULATOR Y COMMISION I - PAGE 6 OF 14 PAGES(5-84) License number

SUA-648, Amendment No. 27MATERIALS LICENSReferencenumrSUPPLEMENTARY SHEET

40-0299

40-0299

The corrective action program shall be fully operational as soon aspracticable, but in no event later than December 15, 1990. Additionally,the licensee shall on a semiannual frequency, submit a ground-watermonitoring report as well as submit a corrective action program review bySeptember 30 of each year that describes the progress towards attainingground-water protection standards.

D. The licensee shall use, at a minimum, the following lower limits ofdetection for water quality analysis in mg/l, unless otherwise noted:

arsenic = 0.01, beryllium !- 0..01,.nickel= 0.01, selenium = 0.005, totaldissolved solids = 1.0, :sulfate = 0.1, chloride = 0.1, iron = 0.1, pH = 0.1(standard units), natural uranium = 1.0 pCi/i, 'combined radium-226 and 228 =1.0 pCi/l, thorium-230 = 1.0 pCi/l, lead-210 = 1.0 pCi/l and gross alpha =5.0 pCi/l.

[Applicable Amendments: 6, 8, 11, 15, 21]

36. The licensee shall minimize, to the maximum extent practicable, ponding of waterin the A-9 pit through decanting and the use of spray evaporation systems.Approval of spray evaporation techniques for any areas, except the A-9 pit andthe adjacent evaporation ponds, shall require approval from the NRC in the formof a license amendment.

Additionally, the licensee shall prevent precipitation runoff from entering theA-9 pit, to the maximum extent practicable in accordance with their plansubmitted by letter dated March 16, 1987.. The system shall be inspected as partof the inspection program required for-the evaporation ponds in order to assurethat the runoff diversion system is maintained and functions as designed.



38. The licensee shall follow the lower limits of detection contained in theattachment to SUA-648 entitled, "Lower Limits of Detection for Sample Analysis"for the analysis of samples collected in conjunction with the environmentalmonitoring program.

39. The results of all effluent and environmental monitoring required by this licenseshall be reported in accordance with 10 CFR 40, Section 40.65, with copies of thereport sent directly to the NRC, Uranium Recovery Field Office. Monitoring Datashall be reported in the format shown in the attachment to SUA-648 entitled,"Sample Format for Reporting Monitoring Data."

40. The leak detection system associated with the buried solution return line fromthe South evaporation pond to the mill shall be inspected as follows during milloperation:

NRC Form 374A U.S. K LEAR REGULATORY COMMISSION PAGE 7 OF 14 PAGES(5..84) License number

MATERIALS LICENSE SUA-648, Amendment No. 27MATERALS LCENSEDocket or Reference number


A. The location of standpipes shall be as shown on Map No. A12-81-27B submittedby letter dated July 9, 1984. All standpipes with the exception ofstandpipes 11, 12, 14 and 15, shall be checked monthly for the presence ofseepage during operations. All such checks shall be documented.

B. The electrical leak detection system shall be checked weekly duringoperations to assure it is functioning as designed and the checksdocumented.

C. A surface line shall be maintained between standpipes No. 10 and 16. Thesurface line shall be inspected twice per.shift during operations and theinspections documented. E.-Future plans for 'burial of the line betweenstandpipes No. 10 and 16 shall be submitted to-the Uranium Recovery FieldOffice, NRC, for review and approval prior to implementation.

41. DELETED by Amendment-No. 22.

42. The licensee shall not dispose of solid or liquid wastes in the abovegradetailings impoundment. In addition:

A. Eight piezometer wells shall be maintained to monitor the phreatic waterline in the tailings dikes. The piezometer measurements shall be madesemiannually. Piezometer measurements can be discontinued for wells afterthere have been at.least.two (2) consecutive dry readings from that well.

B. The licensee shall maintain an.automatic high liquid level alarm in the westberm sump.

C. The licensee shall operate the inactive tail~ings impoundment surface waterseepage collection system and perform monitoring-in accordance with the plandescribed in Union.Carbide Corporation's letter dated April 23, 1981, withthe exception that collection of water from.the sumps shall be in accordancewith the submittal dated December 5, 1983."1 The licensee shall document the

results of the monitoring of the .seepage collection system. The licenseeshall also perform a daily documented inspection of the sumps and shallrecord the water levels daily.

D. The licensee shall implement the berm sump monitoring program as specifiedin their submittal dated December 5, 1983, with the following exceptions:

1) The action level for Sump No. 4 shall be 4.0 feet.

2) Collection of water from the sumps shall be documented.

3) Sampling will not be required.


I

43. Maintenance of the below-grade tailings disposal system in the A-9 pit shall bein accordance with the following documents and conditions:

NRC Form 374A U.S. LEAR REGULATORY COMMISSION PAGE 8 OF 14 PAGES(5-84) License number

MATERIALS LICENSE SUA-648, Amendment No. 27MATPERINTALS LICEE Docket or Reference number

-SUPPLEMENTARY SHEET 40-0299

A. Sections 3-9 and 11 of "Alternative VII - Inplace Dewatered Uranium TailingsDisposal System," September 28, 1979, submitted by letter datedSeptember 18, 1979.

B. The licensee shall maintain three additional piezometers at each of twolocations in the tailings in the below-grade impoundment; at a stationapproximately halfway between the north and south ends of the center linedrainage blanket, and at a station near the south end of this drainageblanket. These piezometers shall be placed at distances of 50, 100, and 200feet from the drainage pipe. At one station, the piezometers should beplaced to the west of the drai&n and Iat.'the other station they should beplaced to the east of theddrain. Piezometer readings shall be taken atquarterly intervals-and submitted at least semiannually as part of theenvironmental monitoring report required by 10 CER .40.65.



45. The licensee shall maintain cumulative flow meters on all lines leaving the A-9pit and shall document weekly the total flow of liquid pumped or decanted fromthe A-9 pit.


47. DELETED by Amendment No.1.

48. Maintenance and operation of the evaporation ponds shall -be conducted inaccordance with Section 6 and Exhibit 2 of "AlternativeVIl - Inplace DewateredUranium Tailings Disposal System," dated September 28, 1979.

Additionally, the exposed clay liner of the evaporation ponds at and below themaximum operating level of the pond shall be kept moist at all times to preventdesiccation and cracking.

49. The licensee shall maintain at least five (5) feet of freeboard between theembankment crest of the evaporation ponds and the maximum operating level of theponded liquid.

50. As a precaution against settlement, the top of the clay liner of the embankmentof the evaporation ponds shall be maintained at two feet above the maximumoperating level in the south evaporation pond and one foot above the maximumoperating level in the north evaporation pond.

51. The licensee shall maintain erosion controls at liquid inflow points into bothevaporation ponds and at the culvert outlet into the north pond.[Applicable Amendments: 22]

52. The licensee shall implement the inspection and monitoring program for thetailings disposal system (including the evaporation ponds) as specified inRegulatory Guide 3.11.1. A copy of the technical evaluation specified in

NRC Form 374A U.S. NL .EAR REGULATORY COMMISSION PAGE 9 OF 14 PAGES(5-84) License number


OUP IO miiiiu"tt i u L "U. LI


40-0299

Section C of Regulatory Guide 3.11.1 covering the evaporation ponds shall besubmitted to the NRC within one month of completion of the evaluation.[Applicable Amendments: 1]


54. The final reclamation of the inactive, above-grade tailings areas and heap leachsite shall be in accordance with the December 18, 1980, letter enclosing theD'Appolonia Consulting Engineers report entitled, "Reclamation Plan - InactiveTailings Areas and Heap Leach Site," and the April 19, 1979, and May 13, 1982,letters.

Notwithstanding, the following modifications shall-be required in lieu ofstatements made in the-above referenced documents:

A. The alternate reclamation plan which provides for IOH:IV embankment slopesas presented in Section 4.1 of the D'Appolonia report shall be required.

B. The entire reclaimed tailings and heap leach areas shall be covered with aminimum of 10 feet of cover material which meets the followingrequirements:

1) A clay cap of a minimum of I foot thickness.

2) A suitable filter material of a mi.nimum I foot thickness to be placeddirectly over the-clay-cap. The licensee shall document and submit tothe NRC the soils :testing.data- for .the.filter materials whichdemonstrates a permeability differenti.al of at least two orders ofmagnitudeý"greater than the clay cap~materials. "

3) A minimum of 7.5 feet of additional overburden and spoils materials.The licensee may use a thickness of 6.5 feet over areas specified to becovered by cobble rock ri.prap.

4) A minimum of 0.5 feet of topsoil.

5) A minimum of 1.5 feet of cobble rock riprap on slopes greater thanIOH:IV over reclaimed areas. The rock riprap shall have the followinggradation as a minimum.

% Passing by Weight Rock Size (inches)

100 8 - 1250 6 - 815 3 - 4

C. The licensee shall not rip the topsoil into the spoils materials as proposedin the reclamation plan.

.. ..... ....

NRC Form 374A U.S. NUL-EAR REGULATORY COMMISSION PAGE 10 OF 14 PAGES(5-84) License number

MATERIALS LICENSE SUA-648, Amendment No. 27MATERALS LCENSEDoket or Reference number


D. Prior to completion of reclama-ion, the licensee shall assure that the waterretention structure adjacent to the spoils area, lying east of the aboveground impoundment, has been removed and drainage re-established.

E. The schedule and sequence of reclamation activities for the inactivetailings areas shall be as specified in the licensee's submittals datedMay 21, 1986, and February 17, 1988, with the exception that the licenseeshall not place the 1 foot clay cap (Phase 7) during the 1988 constructionseason.

Instrumentation to be monitpred shal:l be as specified in Section 5.4 andFigure 5.5. of Volume Il.o•fthe report-ent!itled, "Stabilization andReclamation of an Inactive Tailings Impoundment::.ý" The frequency of readinginstrumentation shall be as follows:

1) Weekly during construction.

2) Weekly for the next month.

3) Monthly for next 6 months.

4) Quarterly thereafter.

F. Construction of the..reclamation-cover. shall be as specified in thelicensee's submittal dated June 16,.1983, with the-following exceptions:

1) The clay cap materi~al shal-l. .be ..compacted to at 'least 90 percent of itsstandard:Proctor-maximum density (ASTM D698) at a moisture contentbetween optimum and two -(2),percent hiigher. If-a lower degree ofcompaction is desired, permeability tests on samples of the claymaterial compacted to the desired density..,shall be performed todocument that the permeability would not exceed 1 foot/year and theresults submitted to the':,NRC, Uran-ium 'Recovery Field Office, for reviewand approval prior to construction.

2) An Atterberg Limits and laboratory moisture-density test shall beperformed on a composite sample from each clay borrow area to be usedduring a particular construction phase prior to initiation of work. Inaddition, four field density and four field moisture content testsshall be performed for each layer of clay placed. These tests shall beperformed prior to placing cover material over the clay. The resultsof the field tests shall be correlated using the results of thelaboratory tests.

3) The cover material shall be compacted to between 85 and 90 percent ofits standard Proctor maximum density (ASTM D698). The soil cover shallbe placed and compacted in two approximately equal lifts. Four fielddensity tests shall be performed for each lift of soil cover materialplaced.

NRC Form 374A U.S. NUt-. AR REGULATORY COMMISSION PAGE 11 oF 14 PAGES

(5-84) License number

Q1JIA - AAQ Amn•eimnn+ Nn 97MATERIALS LICENSESUPPLEMENTARY SHEET


40-0299

4) A report summarizing construction activities for each phase ofreclamation work and containing the results of all quality assurancetesting shall be submitted to the NRC, Uranium Recovery Field Office,within 60 days of completion of the activities.

5) Following completion of the interim stabilization cover, the licenseeshall thereafter perform documented inspections of the cover. Thelicensee shall, within 30 days of these inspections, weatherpermitting, provide for the repair of any area which could result inponding of surface water due to settlement or exposure of tailings dueto erosion. a

[Applicable Amendments: '4, .-6 7]

55. The licensee shall maintain an NRC-approved financial surety arrangement,consistent with 10 CFR 40, Appendix A, Criteria 9 and 10, ,adequate to cover theestimated costs, if accomplished by a third party, for decommissioning anddecontamination of the mill and mill site, reclamation of any tailings or wastedisposal areas, ground water restoration as warranted and the long-termsurveillance fee. Within three (3) months of NRC approval of a revisedreclamation/decommissioning plan, the licensee shall submit, for NRC review andapproval, a proposed revision to the financial surety arrangement if estimatedcosts in the newly approved-plan exceed the amount covered in the existingfinancial surety'. The revised surety sha1l then be in effect within3 months of written NRC approval.

Annual updates to the suretyI.amount, .,required.by 10 CFR 40, Appendix A,Criteria 9 and 10,.shall be submitted.to the NRC...at least 3 months prior to theanniversary date which is designated as September 13 of-each year. If the NRChas not approved a proposed revision to"the surety coverage 30 days prior to theexpiration date of the exi.sting surety arrangement,. .the licensee shall extend theexisting surety arrangement for one year. Along with each proposed revision orannual update, the licensee shall-.submit supporting documentation showing abreakdown of the costs and the basis for the cost estimates with adjustments forinflation, maintenance of a 15 percent contingency fee, changes in engineeringplans, activities performed and any other conditions affecting estimated costsfor site closure. The licensee shall also provide the NRC with all suretyrelated correspondence submitted to the State of Wyoming, a copy of the State'ssurety review and the final approved surety arrangement. The licensee shall alsoensure that the surety, where authorized to be held by the State, expresslyidentifies the NRC portion of the surety and covers the decommissioning anddecontamination of the mill and mill site, reclamation of the tailings and wastedisposal areas, ground water restoration as warranted and the transfer of thelong-term surveillance fee to the U.S. General Treasury. The basis for the costestimate is the NRC approved reclamation/decommissioning plan or NRC approvedrevisions to the plan. The minimum considerations used by the NRC in the reviewof decommissioning and reclamation estimates are shown in the attachment toSUA-648 entitled, "Recommended Outline for Site Specific Reclamation andStabilization Cost Estimates." Licensee submittals of reclamation/decommissioning plans and annual updates should follow this guidance.

*YieýýIhel*N*14N ý&YY&Iillý6ýli&ilýraý,ý&iýlte;ýlisilýrel3ýrstwyi _WS

NRC Form 374A U.S. NU _AR REGULATORY COMMISSION PAGEC5.84)

12 OF 14 pAOFS


SUA-648, Amendment No. 27IDocket or Reference number

40-0299

Umetco Gas Hills' currently approved surety instrument, a surety bond withSeaboard Surety Company (No. 861822) held by the State of Wyoming, shall becontinuously maintained in an amount no less than $8,566,324 for the purpose ofcomplying with 10 CFR 40, Appendix A, Criteria 9 and 10 until a replacement isauthorized by both the State and NRC.

[Applicable Amendments: 1, 2, 13, 19, 20, 26, 27]

56. Prior to termination of this license, the licensee shall provide for transfer oftitle to byproduct material and land, including any interests therein (other thanland owned by the United States..7or' the .State.of Wyoming) which is used for thedisposal of such byproduct.material-or is essential to ensure the long termstability of such disposal site to the United States or State of Wyoming, at theState's option.

57. The NRC will not terminate the license until final reclamation has been completedand meets all applicable NRC regulations.

58. The licensee is authorized *to receive and dispose of a quantity of wastes in theA-9 pit and reclaim in accordance with the submittals dated September 10 and 16,1987; and August 29 and September 24, 1988. Wastes which may be disposed of inthe A-9 pit may be from onsite sources, e...g., evaporation pond materials,licensed in situ facilities, and up to 10,000 cubic yards per year of otherbyproduct material provided NRC approves the characteristics and disposalprocedures for this other material. Additionally, the licensee shall:

A. Prior to placement of the final cover, verify that the interim cover iscompacted to 95.percent of Proctor:maximum density.

B. Place the final cover clay and filter layers in compacted lift thicknesses

not exceeding 6 inches.

C. Place the spoil layer in a loose-lift. thickness not to exceed 18 inches.

D. Assure that the riprap layer thickness is greater than 1.5 times the upper-limit D50 size, or the maximum D100 size, whichever is larger.

E. Assure that the filter bed and riprap gradation requirements described intheir submittal dated December 6, 1988, are met. The December 6, 1988,gradations are dependent on a durability rating of 65 percent or better.Minimum riprap specifications and durability test results fromrepresentative samples must be submitted for NRC review and approval.Minimum riprap specifications and durability tests shall include L.A.abrasion, absorption, soundness, and specific gravity, and the durabilityrating shall be determined in accordance with the Final Staff TechnicalPosition, Design of Erosion Protection Covers for Stabilization of UraniumMill Tailings Sites, Division of Low-Level Waste Management andDecommissioning, August 1990. The durability rating must be determined tobe 65 or greater before placement and again when one-third and two-thirds ofthe materials have been placed.

NRC Form 374A U.S. NL. -EAR REGULATORY COMMISSION PAGE 13 OF 14 PAGES*-4~ )License number

MATERIALS LICENSE SUA-648, Amendment No. 27MATERALS LCENSEDocket or Reference number


F. The maximum dimension of scrap material shall be limited to 30 feet asstated in your submittal dated May 16, 1988. The one exception shall be thesteel tank described in the licensee's November 9, 1989, submittal. Thistank shall be filled to eliminate the void and buried intact.

G. Upon receipt and disposal of the in situ wastes and other byproductmaterial, the activity, location, and elevations of the waste shall bemapped and the potential impact on the required radon cover thicknessevaluated. A report containing this information shall be submitted for NRCreview and approval 3 months prior to placement of the radon cover.

[Applicable Amendments: 1, 5,j 9,9c :10, 18, 22-i' 25].

59. The licensee shall complete site reclamation in accordance with the approvedreclamation plan and ground-water corrective action plan,ý.as authorized byLicense Condition Nos. 54 and 58, respectively, in accordance with the followingschedules.

A. To ensure timely compliance with target completion dates established in theMemorandum of Understanding with the Environmental Protection Agency(56 FR 55432, October25, 1991), the licensee shall complete reclamation tocontrol radon emissions as expeditiously as practicable, consideringtechnological feasibility, ,in accordance with the following schedule:

(1) Windblown taililngs retrieval and placement on the pile:

For the 'Inactive -Impoundment .-. complete.'For the-A29 Impoundment -,December 31, 1993.For the Heap Leach Impoundment - December 31, 1993.

(2) Placement of'the interim cover to decrease....the potential for tailingsdispersal and erosion:

For the Inactive Impoundment -- complete.For the A-9 Impoundment - complete.For the Heap Leach Impoundment - complete.

(3) Placement of final radon barrier designed and constructed to limitradon emissions to an average flux of no more than 20 pCi/m 2/s abovebackground:

For the Inactive Impoundment - December 31, 1995.For the A-9 Impoundment - December 31, 1995.For the Heap Leach Impoundment - December 31, 1995.

B. Reclamation, to ensure required longevity of the covered tailings andground-water protection, shall be completed as expeditiously as isreasonably achievable, in accordance with the following target dates forcompletion:

US. REG, LT C OMMSSO',=41

,NRC Form 374A(5-84)

U.S. NU%,-EAR REGULATORY COMMISSIONPAC' F 14 , 14 PAGES


License number

SUA-648, Amendment No. 27Docket or Reference number

40-0299

I

(1) Placement of erosion protection as part of reclamation to comply withCriterion 6 of Appendix A of 10 CFR Part 40:

For the Inactive Impoundment - December 31, 1996.For the A-9 Impoundment - December 31, 1996.For the Heap Leach Impoundment - December 31, 1996.

(2) Projected completion of ground-water corrective actions to meetperformance objectives specified in the ground-water corrective actionplan - December 31, 1996.

C. Any license amendment request to revise-thewcompletion dates specified inSection A must demonstrate that compliance was.-not technologically feasible(including inclement:weather, litigation which compels delay to reclamation,or other factors *beyond the control of the licensee).

D. Any license amendment request to change the target dates in Section B abovemust address added risk to the public health and safety and the environment,with due consideration to the economic costs involved and other factorsjustifying the request such as delays caused by inclement weather,regulatory delays, litigation, and other factors beyond the control of thelicensee.

FOR THE NUCLEAR REGULATORY COMMISSION

Dated: "71 i'ý l - Joseph J. Hol -onich, Chief;,High-Level,'Wiste and

Uranium Recovery Projects BranchDivision of Waste'ManagementOffice of Nuclear Material Safety

and Safeguards

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