1. NRC LICENSE APPLICATION PROCESS
STEPHEN J. COHEN
HYDROGEOLOGIST/PROJECT MANAGER
URANIUM RECOVERY BRANCH

2. NRC Detailed Technical
Consult
SF & C
NRC LICENSING PROCESS
Submit Application
to NRC
Pre-Licensing
Meeting w/NRC
NRC Acceptance
Review
EIS From
NEPA Review
Applicant
Resubmit
Adequate
Inadequate
NRC Detailed Technical
Review
Opportunity
for
Hearing
NRC Issues License
Issue RAIs to
Applicant
If open issues
remaining
NRC Prepares SER
Applicant Response/
Provides Add’l Info.
All Open Issues
Resolved
NRC Final Review

3. PRE-LICENSING ACTIVITIES
OBJECTIVE – NOTIFY NRC OF PROJECT AND
GET ON NRC BUDGET
PRE-LICENSING MEETINGS
SCHEDULES AND PROGRESS UPDATES
Schedules and progress updates are important aspect of pre-licensing.
Needed to help NRC budget and plan for work
No Charge for first pre-licensing; subsequent meetings are charged
Letters of Commitment
Pre-Licensing activities could last for years

4. PRE-LICENSING ACTIVITIES (cont’d.)
SITE INVESTIGATION - EXAMPLES
GEOLOGY
GEOTECHNICAL
HYDROGEOLOGY
HYDROLOGY
ENVIRONMENTAL INVESTIGATION - EXAMPLES
ARCHAEOLOGY
BACKGROUND
CULTURAL RESOURCES
HEALTH PHYSICS
CROSS-OVER AREAS

5. LICENSE APPLICATION SUBMITTAL
NO AMOUNT OF PRE-LICENSING COORDINATION
CAN SUBSTITUTE FOR A POORLY PREPARED
APPLICATION.
WHAT IS A GOOD APPLICATION?
AN APPLICATION THAT PROVIDES THE NECESSARY INFORMATION TO ALLOW NRC’S ASSESSMENT OF TECHNICAL, SAFETY AND ENVIRONMENTAL ASPECTS OF A PROJECT.
Need to provide sufficient detail, but be as concise as possible.

6. LICENSE APPLICATION SUBMITTAL (cont’d.)
WHAT DOCUMENTATION IS REQUIRED FOR A LICENSE
APPLICATION?
TRANSMITTAL LETTER
FORM 313 – 10 CFR 40.5 AND 40.31
TECHNICAL REPORT
ENVIRONMENTAL REPORT
NRC’S RESPONSE WHEN APPLICATION IS RECEIVED
FED. REG. NOTICE – OPPORTUNITY FOR HEARING
DOCKET NUMBERS
ALL DOCUMENTS ARE PUBLIC UNLESS WITHOLDING IS APPROVED UNDER 10 CFR 2.390
Technical and environmental reports should be separate – different reviewers and review paths
If this is done, some sort of table or checklist is required to allow reviews to identify those parts meant to fulfill the ER guidance recommendations.

7. LICENSE APPLICATION SUBMITTAL (cont’d.)
REVIEW PLANS AND GUIDANCE – BASIC LIST
NUREG-1569 – IN-SITU LEACH MINES
NUREG-1620 – CONVENTIONAL MILL REC PLANS
NUREG-1757 – DECOMMISSIONING
NUREG-1748 – ENVIRONMENTAL REVIEWS
10 CFR PART 40, APPENDIX A
REG. GUIDE 3.5, REV. 1
VARIOUS REG GUIDES

8. LICENSE APPLICATION SUBMITTAL (cont’d.)
FORMAT AND CONTENT GUIDANCE
CONVENTIONAL MILL – REG GUIDE 3.5 & NUREG-1620
ISL FACILITIES – NUREG-1569
ENVIRONMENTAL REPORT – NUREG-1748
10 CFR PART 40, APPENDIX A
Other guidance documents are available and have been provided on the CDs handed out at registration.
Ground water restoration, monitoring can either be safety or environmental issue depending on the proximity of site to supply wells.

9. CONVENTIONAL MILL APPLICATION CONTENT
PROPOSED ACTIVITIES
SITE CHARACTERISTICS
MILL PROCESS AND EQUIPMENT
WASTE MANAGEMENT SYSTEM
OPERATIONS
ACCIDENTS
QUALITY ASSURANCE
Guidance states the evaluation of alternatives.
This is generally a NEPA issued and should be addressed in the environmental report.

10. CONVENTIONAL MILL APPLICATION CONTENT
10 CFR PART 40, APPENDIX A, NUREG-1620
RECLAMATION PLAN
SURETY
IMPOUNDMENT DESIGN STANDARDS
ALSO 40 CFR – IMPOUNDMENT LIMIT
Pre-UMTRCA applications did not include the need for a Reclamation Plan.
Required by Appendix A
Demonstrates knowledge of reclamation process and it’s used to calculate initial surety.
EPA has a 40-acre limit for impoundments under 40 CFR

11. ISL APPLICATION CONTENT
PROPOSED ACTIVITIES
SITE CHARACTERIZATION
DESCRIPTION OF PROPOSED FACILITY
EFFLUENT CONTROL SYSTEMS
GROUND WATER RESTORATION, SURFACE
RECLAMATION, AND DECOMMISSIONING
ACCIDENTS
QUALITY ASSURANCE
SURETY ESTIMATE
GROUND WATER RESTORATION IS A CROSS-OVER TOPIC.

12. NRC ACCEPTANCE REVIEW 90-DAY INITIAL REVIEW
BASIS OF REVIEW: NUREGS, REG GUIDES, OTHER
GUIDANCE.
ACTIONS FOR INCOMPLETE APPLICATIONS:
CAN BE RETURNED TO APPLICANT FOR
RESUBMITTAL.
ACCEPTED WITH REQUEST FOR ADDITIONAL
INFORMATION.
IF APPLICATION IS COMPLETE, ACCEPTANCE LETTER ISSUED.

13. NRC ACCEPTANCE REVIEW (cont’d.)
ORDER OF REVIEW
APPLICATIONS WILL BE REVIEWED IN THE ORDER THEY ARE ACCEPTED.
SUBMITTING PARTIAL OR HASTILY PREPARED APPLICATIONS TO GET INTO THE QUEUE IS NOT ACCEPTABLE.

14. TECHNICAL REVIEW OF APPLICATION
BASIS OF REVIEW – REGULATIONS, NUREGS, REG. GUIDES
REQUEST FOR ADDITIONAL INFORMATION –
GOAL IS ONE REQUEST
ENVIRONMENTAL REVIEW – CONCURRENT WITH
TECHNICAL REVIEW

15. TECHNICAL REVIEW OF APPLICATION (cont’d.)
SOME ADDITIONAL THOUGHTS ON THE FOLLOWING AREAS:
GEOLOGY AND HYDROGEOLOGY
HEALTH PHYSICS
SURFACE WATER HYDROLOGY
BACKGROUND RADIATION AND WATER QUALITY INVESTIGATION
RECLAMATION PLAN AND SURETY
ACCIDENT SCENARIOS

16. GEOLOGY AND HYDROGEOLOGY
APPLICABLE FOR BOTH ISL AND CONVENTIONAL FACILITIES.
THOROUGH DESCRIPTION OF GEOLOGY AND HYDROGEOLOGY.
DETAILED TESTING AND ANALYSIS INFORMATION
STATISTICAL ANALYSIS METHODS
THOROUGH HYDROGEOLOGIC DESCRIPTION
AQUIFER TESTS
MONITORING

17. HEALTH PHYSICS ISSUES 10 CFR 40, APPENDIX A CRITERION 7 THROUGH 10
COMPLETE BASELINE DATA
PRE/POST OPERATIONAL MONITORING PROGRAM
NUREG 1569
BACKGROUND RADIOLOGICAL CHARACTERISTICS
DECOMMISSIONING GUIDANCE
Bullet 1: 10 CFR 40 criterion 7 states that a licensee is to provide complete baseline data and establish a pre/post operational monitoring program. A major issue is what level of complexity exists for these tasks. What level of detail is required? How many samples? What frequency? What type of samples? Etc..
Bullet 2: NUREG 1569 provide some guidance on the above questions but is purposely vague to allow licensees to establish programs that conform to their specific facility. However, the NUREG does reference decommissioning guidance. What it takes to decommission a facility should be evaluated as part of the pre operational monitoring program.

18. GEOTECHNICAL ENGINEERING
DESIGN
OPERATIONS
DECOMMISSIONING/RECLAMATION
DESIGN
Site Characterization
Tailings Impoundments/Evaporation Ponds (Stability, Settlement, Seepage, Construction Quality Control)
Reg Guide 3.11; Reg Guide 1.138;; STP (79-01)
Operations
Impoundment Inspection and Maintenance
Seepage/Leak Detection Monitoring
Reg Guide ; Draft Reg Guide MS-146-4
Decommissioning/Reclamation
Long-term stability
Cover Design (infiltration, radon emanation)
NUREG-1620 (section 2.0)

19. SURFACE WATER HYDROLOGY/EROSION PROTECTION – ISL FACILITIES
SITED TO AVOID FLOODING/EROSION
EROSION PROTECTION NEAR STREAMS
IMPOUNDMENTS TO CONTAIN LARGE EVENTS
DAM SAFETY
RECLAMATION PLAN
IN-SITU FACILITIES
1. FACILITIES SHOULD BE SITED TO AVOID FLOODING AND EROSION
2. EROSION PROTECTION MAY BE NEEDED IF SITED NEAR STREAM OR ARROYO, OR IF DIVERSION CHANNELS ARE CONSTRUCTED
3. IMPOUNDMENTS MAY NEED TO CONTAIN LARGE FLOODS, RAINFALL EVENTS, AND WAVE ACTION
4. OPERATIONAL DESIGN CRITERIA ARE BASED ON NEED TO PREVENT RELEASE OF CONTAMINATED MATERIAL (OR FLUIDS) FROM FLOODING AND EROSION
5. POSSIBLE DAM SAFETY CONSIDERATIONS, DEPENDING ON SIZE OF IMPOUNDMENT
6. SITE CONSIDERATIONS APPLY TO OPERATIONAL PERIOD - USUAL PRACTICE IS TO COMPLETELY CLEAN UP SURFACE AREAS - RECLAMATION PLAN FOR LONG-TERM STABILITY AND EROSION PROTECTION IS USUALLY NOT NEEDED

20. SURFACE WATER HYDROLOGY/EROSION PROTECTION – CONVENTIONAL MILLS
RECLAMATION PLAN WITH APPLICATION
EROSION PROTECTION DESIGNS NEEDED FOR CHANNELS, EMBANKMENT SLOPES, AND APRONS.
NUREGS-1620 AND PROVIDE ACCEPTABLE METHODS FOR EROSION PROTECTION
OPERATIONAL IMPOUNDMENT CAPACITY/FREEBOARD MAY BE AFFECTED BY LARGE EVENTS
DAM SAFETY CONSIDERATIONS
B. CONVENTIONAL FACILITIES
1. RECLAMATION PLAN FOR LONG-TERM STABILIZATION OF TAILINGS MUST BE PROVIDED WITH APPLICATION
2. EROSION PROTECTION DESIGNS ARE ALMOST ALWAYS NEEDED FOR CHANNELS, EMBANKMENT SLOPES, AND APRONS
3. NUREG-1623 AND NUREG-1620 PROVIDE ACCEPTABLE METHODS FOR DESIGN OF EROSION PROTECTION FOR RECLAMATION
4. OPERATIONAL IMPOUNDMENT CAPACITY AND FREEBOARD MAY BE AFFECTED BY LARGE FLOODS, RAINFALL EVENTS, AND RESERVOIR WAVE ACTION
5. POSSIBLE DAM SAFETY CONSIDERATIONS DEPENDING ON SIZE

21. BACKGROUND INVESTIGATIONS
BACKGROUND GROUND WATER QUALITY INVESTIGATION – 10 CFR 40, APPENDIX A, CRITERION.
1 YEAR OF SAMPLING
BACKGROUND CONCENTRATIONS APPROVED BY NRC.
SOILS BACKGROUND INVESTIGATION SUFFICIENT TO IDENTIFY HETEROGENEITIES IN RADIONUCLIDE CONCENTRATIONS.
BACKGROUND CONCENTRATIONS AT DEPTH COULD BE A CONCERN.

22. ACCIDENT SCENARIOS – A BRIEF DISCUSSION
SPECTRUM OF POTENTIAL ACCIDENTS
MEASURES TO PREVENT ACCIDENTS
EMERGENCY PLANS AND TRAINING
SPECTRUM SHOULD INCLUDE TRIVIAL TO SERIOUS
CLASS OF OCCURRENCE
FIRES ENGULFING THE PROCESSING PLANT, POTENTIAL EXPLOSIONS, AND URANIUM DISPERSAL.

23. REQUESTS FOR ADDITIONAL INFORMATION ISSUED TO
RAIs AND RESPONSES
REQUESTS FOR ADDITIONAL INFORMATION ISSUED TO
COMPLETE REVIEW.
RAI LETTER ISSUED WITH RESPONSE REQUESTED
WITHIN 30 TO 45 DAYS.
GOAL: ONCE RESPONSES ACCEPTED – TECHNICAL REVIEW PROCEEDS.

24. COMPLETE ENVIRONMENTAL REVIEW PROCESS - EIS
FINAL REVIEW STEPS
COMPLETE ENVIRONMENTAL REVIEW PROCESS - EIS
COMPLETE THE SAFETY EVALUATION REPORT
PUBLISH RECORD OF DECISION
ISSUE LICENSE AND SAFETY EVALUATION REPORT
ADJUDICATION

25. Thank you!
Any Questions?