Steven H Brown, CHP 

SENES Consultants Limited 

Centennial, Colorado USA

NRC/NMA Uranium Workshop 

July 1 – 2, 2009 

Denver, Colorado 
Premise 

 We (U industry, scientists) have believed since the beginning

 of commercial nuclear industry that the science provides the

 obvious answers to addressing concerns of citizens and

 public officials 

 If they don’t “get it”, its their problem, not ours 

 WRONG!! - its our problem since without public acceptance

 we cannot move forward without a great deal of pain, if at all 

 It is in America’s best interest for us to figure this out 

 We must move beyond our “professional arrogance” and

 figure out how to make the science – that in fact does provide

 the answers Understandable 
A Humble Attempt At Making The Science

 Understandable 
In Q/A Format, A Citizens Guide Answers

 the Following Questions 

 What is uranium and where does it come from? 

 How much uranium and associated elements (“decay

 products”) are in the food we eat, water we drink and in

 soil under are feet? 

 How radioactive is uranium and uranium ore compared to

 consumer products we use everyday that contain

 radioactive substances? 

 Are existing regulations for uranium recovery facilities

 adequate to protect the public from additional radiation

 exposure above our natural background exposure? 
In Q/A Format, A Citizens Guide Answers

 the Following Questions (continued) 

 What are the potential health effects from exposure to

 uranium? 

 What about the known health impacts (e.g., lung cancer)

 to many uranium miners who worked underground in the

 1950’s and 1960’s? 

 How is uranium extracted from the earth? 

 What is uranium used for and why is it important? 

 Don’t scientists disagree on many of the health and safety

 concerns associated with uranium and radiation exposure

 in general? 
 Some Common and Critical 

 Misconceptions: Examples 

 Uranium becomes radioactive when mined 

 Environment is “radiation free” w/o nuclear industry 

 No “safe” level of radiation exposure - any amount is

 potentially harmful 

 Health impacts to early U miners in 1950’s and 1960’s

 translate directly to workers and public today 

 Scientists disagree on basic principles of radiation safety 

 Almost anyone with an advanced degree (including

 lawyers) can be an expert in anything 
What is Uranium and 

Where Does it Come From ? 
Uranium in the Natural Environment

 “Primordial” element part of Earth’s formation 4.5 billion 

years ago (originated in supernovas) 

 Deposited on land by volcanic action over geologic time 

 Dissolved by rainfall and carried into underground formations 

 Chemical conditions in some locations resulted in 

concentration into “ore bodies” 

 Fairly common element in Earth’s crust (soil, rock) and in 

groundwater and seawater, typically 2-4 ppm - as common 

as tin, tungsten, molybdenum, etc. 

 A square mile of earth, one foot deep, will typically contain 

over a ton of uranium; one acre of land, one foot deep, 

typically has 3 - 4 lbs
Our Radioactive Natural Environment –

 Everyday Sources of Radiation 

Exposure to Humans 
We Live in a Radioactive Environment – 

It’s Always Been This Way 

 We are continuously 

bombarded with radiation from 

space and earth’s surface 

 Uranium is a common element 

in rock and soil 

 Uranium is in the food and 

water we consume everyday 

 Background radiation in Rocky 

Mtn. States can be several 

times higher than other parts 

of the U.S. – Elevation and 

Mineralization! 
Sources of Radiation Exposure to Humans 

50% (NCRP 160) 

48% (NCRP 160) 

Update from NCRP Report 160, National Council on Radiation Protection and Measurements 

Ionizing Radiation Exposure of the Population of the United States, 2006 
Cosmic Ray and Terrestrial Background Varies

 Considerably Across US 

National Council on Radiation Protection and Measurements; NCRP Report No. 160, 

Ionizing Radiation Exposure of the Population of the United States. 2006 
Variability of Natural Background from 

Place to Place – Example: Colorado

Stone, JM, Whicker, RD et al, Spatial Variations in Natural Background Radiation: 

Absorbed Dose Rates in Air in Colorado. 

Health Physics, Vol. 9(5), May 1999 
Natural Background Levels and Regulatory 

Limits for Protection of the Public 

Table of Natural Background Radiation* 

Source U.S. 

Average1

Colorado 

Average2

Leadville2

Cosmic radiation 

(from space) 

34 50 85 

Terrestrial radiation 

(from the ground) 

22 49 97 

Internal: Ingested from food 

and water and inhaled naturally 

occurring radon and its decay 

products 

254 301 344 

TOTAL 310 400 526 

* In units of mrem/year- mrem (millirem) is a unit of effective radiation dose. One rem is 1,000 mrem. 

1 National Council on Radiation Protection and Measurements. Ionizing radiation exposure of the population of the

 United States. NCRP Report No. 160; 2006. 

2 Moeller D, Sun LSC. Comparison of natural background dose rates for residents of the Amargosa Valley, NV, to those

 in Leadville, CO, and the states of Colorado and Nevada. Health Phys 91:338-353; 2006. 
 Background Levels (from previous slide) 

> Colorado average = 400 mrem 

> Leadville, Colorado = 526 mrem 

> U.S. average = 310 mrem 

 Regulatory Limits 

> EPA drinking water standard = 4 mrem1

> EPA limit for all exposure pathways = 25 mrem2 

> NRC Limit with radon = 100 mrem; excluding radon = 25 mrem3 

Annual Background Radiation Exposure vs. 

Annual Public Exposure Limits: 

U Mines and Mills 

1 U.S. Environmental Protection Agency. Radionuclides in drinking water. Available at:

http://www.epa.gov/safewater/radionuclides/index.html. 

2 U.S. Environmental Protection Agency. Environmental radiation protection for nuclear power operations, 40 CFR 190.10; 2006. 

3 U.S. Nuclear Regulatory Commission; Domestic Licensing of Source Material ; 10 CFR 40 
Radiation Background in Kerala India 

 Unusually high natural radiation background has been

 known for many years due to natural thorium in the

 monazite sands of the region 

 Annual outdoor exposure levels as high as 7000 mrem

 have been measured where people live 

 Recent epidemiological studies have concluded no excess

 cancers in over 69,000 residents studied for 10 years1 

1 R Naire, B Rajan, et al; Background radiation and cancer incidence in Kerala,India—Karunagappally cohort

 study; Health Physics, 96,1, January, 2008 
How Much Natural Radioactive Uranium 

is in the Food We Eat, Water We Drink and 

in the Soil Under Our Feet? 
How Common are Uranium and its Daughter 

Products1 in Nature?2 

 Typical concentration in soil and rocks (pCi*/gram): 

 > Uranium = 0.6 – 3.0 

 > Uranium in phosphate rock used for fertilizers = 40 – 80 

 > Radium = 0.4 – 3.6 

 > Thorium = 0.2 – 2.2 

1 Daughter products = those chemical elements that uranium decays into as a result of its radioactive properties.

 Thorium and radium are also radioactive. 

2 Sources: (1) National Council on Radiation Protection and Measurements. Natural background radiation in the United

 States. Washington, DC: National Council on Radiation Protection and Measurements; NCRP Report No. 45; 1975.

 (2) National Council on Radiation Protection and Measurements. Exposure of the population in the United States and

 Canada from natural background radiation. Bethesda, MD: National Council on Radiation Protection and

 Measurements; NCRP Report No. 94; 1992 (updates and supersedes NCRP Report No. 45). 

*

pCi = picocurie, one-trillionth of a curie, the amount of radioactivity where approximately two atoms decay per minute.

 Picocurie is a measure of the amount of radioactivity. 
How Much Uranium is in the Food and Water 

We Eat and Drink? 

 Typical annual uranium intake in example foods: 

> Whole-grain products: 10 pCi 

> Meat: 50-70 pCi 

> Fresh fruit: 30-51 pCi 

> Potatoes: 67-74 pCi 

 > Bakery products: 39-44 pCi 

Sources: (1) National Council on Radiation Protection and Measurements. Exposures from the uranium series with

 emphasis on radon and its daughters. Bethesda, MD: National Council on Radiation Protection and Measurements;

 NCRP Report No. 77; 1987. (2) Welford GA, Baird R. Uranium levels in human diet and biological materials. Health

 Phys 13(12):1,321-1,324, 1967 (values for three U.S. cities—New York City, Chicago, San Francisco). 
Natural Uranium in Groundwater 

 Can vary considerably from place to place depending

 on local mineralization, hydrology and geochemistry 

 Although typically a few micrograms / liter ( a few pCi /

 liter), U has been measured in public drinking water

 sources 10 -100 + greater than this 

 No permanent health effects have been observed in

 populations drinking water for generations with these

 high natural levels 

Sources:(1) Assessing Potential Risks from Exposure to Natural Uranium in Well Water. Hakonson-Hayes A.C, P.R.

Fresqueza,, F.W. Whicker, Journal of Environmental Radioactivity, 59 (2002) 

(2) Public Health Goal for Uranium in Drinking Water. Office of Environmental Health Hazard Assessment California

 Environmental Protection Agency, 1997 (3) U.S. Dept. of Health and Human Services, Public Health Service,

 Agency for Toxic Substances and Disease Registry. Toxicological Profile for Uranium. 1999.
U Levels in Groundwater > EPA Drinking Water

 Standard (30 micro grams per liter) Are Common 

Data from USGS open

 file report 97-492,

 2006; reformatted

 1975 – 1980 data

 from U.S. NURE

 HSSR program 
Radioactivity of Uranium Ore 

 and Some Consumer Products 
Exposure From Consumer Products 

Used Every Day 

National Council on Radiation Protection and Measurements; NCRP Report No. 160, 

 “Ionizing Radiation Exposure of the Population of the United States”, 2006 
Radioactivity of Uranium Ore 

 Typical uranium ore contains 

670 pCi/gram of uranium 

(assuming 1,000 ppm of 

uranium in the ore) 

 A handful ( about 10 grams) 

= about 7,000 pCi 

 Considering the numerous 

daughter products, the 

handful of ore = about 70,000 

total pCi 
Radioactivity of Some 

Consumer Products 1 

 Household smoke detector (americium) = average of 

50,000,000 pCi 

 Household smoke detector (radium) = 50,000 pCi1 

 Typical older (pre-1970) luminous wrist watch dials 

(radium) = up to 4,500,000 pCi 

 Typical modern luminous wrist watch dials: radioactive 

hydrogen (tritium) average of 1,300,000,000 and 

promethium average of 45,000,000 pCi

1 National Council on Radiation Protection and Measurements. Radiation exposure from consumer 

products and miscellaneous sources. NCRP Report No. 56; 1977 
Radioactivity of Some 

Consumer Products (continued) 

 Coal fly ash = 6 - 20 pCi/gram uranium1 

 Coal fly ash in TVA Kingston spill, Dec. 2008 ( > billion 

gallons) = 6 - 8 pCi / gram radium > 1,000,000,000,000 pCi 

total in spill 2 

 Additional consumer products containing naturally 

occurring radioactivity include fertilizers (uranium, thorium, 

potassium), gas lantern mantles (thorium), glass and 

ceramics (uranium as coloring agent)3

1 U.S. Geological Survey, Fact Sheet FS-163-9, October, 1997. Values actually stated as 10 - 30 ppm 

2 Duke University, Nichols School of Environment, January 2008. 

 See http://www.nicholas.duke.edu/index.html

3 Health Physics Society. Consumer products containing radioactive materials. Health Physics Society Fact Sheet. 

 Available at: www.hps.org/hpspublications/radiationfactsheets.html. 
Radiation Exposure in Perspective - 

 Cigarette Smoking

 A cigarette smoker gets about 1000 mrem / year effective

 dose above background from Polonium 210 in tobacco smoke 

 So a smoker’s effective dose = 10 X annual public exposure

 limit (100 mrem – U.S.NRC) 

 Chest X ray = 8 mrem so for smoker = 125 chest X rays /

 year !! 

 Assuming 15 % of population smokes, their total dose / year =

 30 X more than the total annual dose to all workers at the 104

 nuclear power plants in U.S. + all workers at U.S.DOE

 nuclear installations + all crews on U.S. Navy nuclear ships 

 See Moeller DW and Sun C, Thinking Outside the Box: Polonium 210 in Cigarettes – A Needless 

 Source of Radiation Exposure, Health Physics News,37,4,April 2009 
What are the Potential Health Effects from 

Exposure to Uranium?1

 Uranium is a heavy metal and acts similar to lead 

(another heavy metal) in the body. 

 Accordingly, for natural uranium, national and 

international human exposure standards are based on 

the possible chemical toxicity of uranium (e.g., effect on 

kidney—nephrotoxicity), not on radiation and possible 

“cancer effects” (radiotoxicity) 

1Sources: (1) U.S. Nuclear Regulatory Commission. Standards for protection against radiation. 10 CFR 

 Part 20; 1992. (2) International Commission on Radiological Protection. Limits for intakes of radionuclides

 by workers. ICRP Publication 30, Part 1.1979. (3) Agency for Toxic Substances and Disease Registry.

 Toxicological profile for uranium. Department of Health and Human Services, Public Health Service; 1999.

 Available at: http://www.atsdr.cdc.gov/toxprofiles/tp150.html. 
29 

Health Effects of Ionizing Radiation 

are Well Understood 

 International and National Authorities rely on the work of

 scientific committees such as: 

> United Nations Scientific Committee on the Effects of Ionizing 

Radiation (UNSCEAR); 

 National Academy of Science, Biological Effects of Ionizing 

 Radiation (BEIR) Committees; 

> National Council on Radiation Protection (NCRP), and others 

 for their evaluation of the scientific information on 

 health effects of exposure to ionizing radiation 
Dose Response Model Generally Accepted by

 International and National Scientific Bodies

 (UNSCEAR, BEIR, NCRP) 
Despite Public Confusion and 

Misunderstanding, Health Effects In 

Populations Living Near Uranium Facilities 

Have Been Well Studied 

According to1: 

 U.S. Department of Public and Human Services, Agency for 

Toxic Substances and Disease Registry 

 National Cancer Institute 

 Journal of Radiation Research 

 Journal of Radiation Protection 

Based on studies and data collected over 50 years, there is No scientific 

evidence that uranium exploration, mining, or milling activities result 

in additional cancers in populations living nearby 

1 Specific references can be provided on request 
Example Conclusions from Studies on

 Health Impacts on Populations Living Near 

Uranium Mines and Mills 

“ The absence of elevated mortality rates of cancer in

 Montrose County over a period of 51 years suggests that

 the historical milling and mining operations did not

 adversely affect the health of Montrose County residents.”1 

“No unusual patterns of cancer mortality could be seen in

 Karnes County over a period of 50 years suggesting that

 the uranium mining and milling operation had not increased

 cancer rates among residents.”2 

1 Cancer and Noncancer Mortality in Populations Living Near Uranium and Vanadium Mining and Milling

 Operations in Montrose County, Colorado, 1950 -2000. Boice, JD, Mumma, MT et al. Journal of Radiation

 Research, 167:711-726; 2007 

2 Mortality in a Texas County with Prior Uranium Mining and Milling Activities, 1950 – 2001. Boice, JD,

Mumma, M et al. Journal of Radiological Protection, 23:247 – 262; 2003 
 Underground Uranium Miners 

in the 1950’s and 60’s 

 Miners were exposed to very high levels of uranium decay

 products ( “radon daughters”) in poorly ventilated

 underground mines and some were severe smokers which

 increased dose 

 Follow up of 68,000 former miners indicated 2700 lung

 cancers – much higher than expected incidence* 

 These working conditions existed before Federal agencies

 (OSHA, MSHA, NRC) and laws to protect workers

 throughout American industry ( manufacturing, construction,

 mining, etc.) 

 Levels of exposure 10 – 100 X current worker standards 

•Dr. John Boice, International Epidemiology Institute, Vanderbilt University – personal communication; summary 

 of numerous references which can be provided upon request 
How is Uranium Extracted 

from the Earth ? 
The Uranium Fuel Cycle - What is Uranium 

Used For and Why is it Important? 

Courtesy of Australian Uranium Association at www.aua.org.au 
What is Uranium Used For? 

 Number one use = Electricity generation via nuclear fission. 

Approximately 20 percent of U.S. electricity is generated by 

uranium fuel in nuclear power plants (over 400 plants currently 

world wide and many more planned) 

 Uranium fission in nuclear reactors makes isotopes used in 

medicine (e.g., 99Mo, which produces 99mTc for diagnostic 

imaging studies – used in over 70% of all nuclear medicine 

procedures) 

Nuclear fission—each “fission” of

 a 235U atom by a neutron results

 in release of radiation (heat, light,

 gamma and x rays), more

 neutrons, and other particles 
What is Uranium Used For?: 

Commercial Uranium Fuel Cycle 
What is Uranium Used For? 

 One pound of yellowcake has energy equivalence of 35 

barrels of oil1 and one 7-gram (1/4-ounce) uranium fuel 

pellet has an energy-to-electricity equivalent 17,000 cubic 

feet of natural gas or 1,780 pounds of coal 2 

 Other uses include coloring agent in ceramics and 

glass, military armor and armament, counterweights on 

ships and aircraft, radiation shielding (extremely dense 

and heavy metal but relatively flexible) 

1 David Bradish, Mgr. Energy information, Nuclear Energy Institute

2 U.S. Department of Energy, Energy Information Administration 
Why is Domestic Uranium Recovery

 Important: America’s Energy Needs 

 Currently, U.S. fleet of 104 nuclear power plants provide

 20% of the U.S.’ base load electricity 

 These plants consume about 60 million pounds of

 uranium fuel per year, and new plants expected to come

 on line in next 10 - 20 years 

 The U.S. currently produces about 5 million pounds of

 uranium fuel per year 
Why is Domestic Recovery Important:

 America’s Energy Needs 

 As is our current situation with oil, we are highly reliant on

 foreign sources 

 Some of these regimes (now and/or in future) may not be

 friendly to the U.S. 

 “Exploding” economies like China and India plan on

 building large numbers of new nuclear plants in next 2

 decades and will compete for world wide uranium

 supplies 
Why is Domestic Uranium Recovery Important:

 Basic Reality of Supply and Demand 

Uranium Producers of America 

http://www.uraniumproducersamerica.com/supply.html 
World-Wide Uranium Production 

Uranium Producers of America @ http://www.uraniumproducersamerica.com 
Don’t Scientists Disagree on 

Radiation Effects? 

 Vast majority really do not 

 Human health effects from radiation have been

 extensively studied and are well understood 

 Much info presented here = “consensus science” –

 generally agreed upon position of national and

 international bodies of experts 

 As a society, we have to do better job in “weighing the

 evidence” including expertise and experience of the

 ”speaker” specific to the subject matter 

 Upon objective evaluation, we will often find relative

 weight of claims are not equal at all 
Apply the Challenge of 

Dr. Carl Sagan 

“ Remarkable claims demand 

remarkable evidence” 
Some Final Thoughts # 1

The daily advance of science will enable

 us and future generations to administer

 the Commonwealth with wisdom 

 - Thomas Jefferson 

- Thomas Jefferson to Lafayette, 1823: In The Writings of Thomas Jefferson;

 Lipscomb and Bergh, editors, 20 volumes , 1903-1904 
The goal of science is the gradual 

 removal of prejudices; which is

 belief in the absence of evidence 

 - Niels Bohr 

 - Atomic physics and human knowledge. John Wiley 1958 p 31 

Some Final Thoughts # 2 
Questions? 

Steve Brown, CHP 

SENES 

Englewood, Colorado USA 

sbrown@senes.ca 
License vs. Amendment in

In-Situ Recovery Licensing

Stephen J. Cohen

Team Leader

Uranium Recovery Licensing Branch

U.S. Nuclear Regulatory Commission
The Issue• Increased number and variety of IS

applications for new facilities, restarts, and expansions

• Need to establish procedures 

regarding separate licenses vs. amendment of existing licenses for variety of application scenarios
Background/Past Practice• NRC process generally requiring separate 

licenses for individual fuel cycle facilities; Typically, new facility=new license

• Changes to facilities approved by amending 

licenses

– New tailings cell at a conventional mill – New evaporation pond at an ISR– Process changes; monitoring changes

• Some proposed licensing actions raise 

question of amendment or new license 
Related Definitions• Wellfield – An area within a mine unit from w

source material is extracted by ISR operationwhich includes injection, production, and monwells

• Ion Exchange (IX) Plant – A process building 

ISR Facility in which lixiviant from the productwells is run through ion exchange columns whresin beads selectively remove the uranium frsolution 

• Central Processing Plant (CPP) – A process 

building at an ISR Facility in which the end proyellowcake, produced as a slurry or a dried po
Definitions (continued)• ISR Facility – An operation that includes o

more wellfields, and either an IX Plant or a 

– ISR/resin - An operation with one or mo

wellfields and only an IX Plant

– ISR/yellowcake - An operation with one 

more wellfields and a CPP

• ISR Satellite – An ISR/resin that transport

loaded resin to a CPP operated by the samcompany/licensee; The ISR/resin is a “satethe CPP.
Background/Past Practice (continued)• Unique nature of ISR uranium operations • Example-licensing ISR/resin satellite facilities

– Historically, NRC amended the associated 

existing ISR/yellowcake license 

– Most cases, satellite facility near the existin

licensed facility, thus considered an extensexisting operation 

– Case where proposed satellite remote from 

licensed ISR/yellowcake has raised amendvs. new license question 
Other Scenarios

• NRC received inquiries from compan

considering other ISR facilities deviatfrom typical ISR/yellowcake 

– Stand-alone ISR/resin facilities – CPPs without wellfields– Additional CPP at satellite ISRs

• Other scenarios possible

– Add second CPP– ?
Proposed Process – Primary-Site Amendments• All additions or enhancements to a licensed uranium 

facility at the primary site of the facility can be approthrough an amendment to the license 

– Creation of multiple uranium recovery licenses a

uranium recovery site not an efficient use of NRC resources 

– Allows amendment to the existing license for a re

an additional CPP at a facility that already has a 

– Allows typical more minor amendments (add eva

pond, modify process or monitoring program, etcpast
Proposed Process – Multiple-Site Amendments• Certain facility additions not located at the p

licensed site can be approved through ame

– Need to show a “strong connection” to 

primary facility 

– Facilities being of same type and owners

sufficient reason to meet strong connectirequirement 

– Therefore, cannot use a single license (a

annual fee) to cover operationally or hydrgeologically separate facilities
Strong Connection

• Strong Connection requirement can be met in two 

– Operational Connection – Proposed addition o

ISR/resin facility that will ship resin to same enexisting licensed CPP for further processing (sfacility)

– Hydro-Geologic Connection – Proposed additio

ISR/resin facility and wellfields having ore zone stratigraphy, hydro-geologic containment, and influencing factors similar to the existing facility

• Meeting either of these conditions allows multiple 

operations at separate locations under a single lic

• Applies only to facilities totally in Non-Agreement 
Hydro-Geologic Connection • Compare the degree of similarity or difference between the 

new site/wellfield(s) and the site/wellfield(s) under the existiusing eight factors significant to wellfield performance chara

– Natural system factors

• Regional structural setting• Regional stratigraphy and hydrogeology• Ore zone stratigraphy and lithology• Confining unit stratigraphy, continuity, permeability• Faults and structures that could affect groundwater f

– Human disruptive factors

• Impacts from uranium mining on hydrogeology• Impacts from other natural resources extraction (coa

methane withdrawal) on hydrogeology

• Impacts from abandoned drill holes 

• For a “strong hydro-geologic connection,” none of the evalu

should be identified as different 
Proposed Process – Separate Licenses• If none of conditions allowing license amendment

met, proposed action would require separate licen

• Therefore, a separate license would be needed fo

– Constructing an unattached ISR/resin facility w

loaded resin is taken to another company’s facCPP for processing 

– Constructing a stand-alone CPP without wellfie

receives and processes resin from off-site ISR

– Creating a stand-alone facility by adding a CPP 

satellite ISR/resin
Table of ISR licensing action scenarios and corresponding process r

Amendment EA

Existing ISR licensee proposes additions, 

modifications, or enhancements to its licensed facility

Amendment EA Existing licensee proposes restart of a facility in standby or decommissioningAmendment EA Existing licensee proposes an additional CPP at its existing ISR/yellowcake

License Complex EA* Existing ISR/yellowcake licensee proposes a CPP at its existing satellite ISR/resin

Existing licensee proposes a CPP at its ISR/resin Amendment EA

License Complex EA* New applicant or existing licensee proposes a stand- alone CPP at new site

Amendment EA

Existing Licensee proposes satellite, i.e., remote 

ISR/resin w/ resin shipped to its licensed existing CPP (strong business connection)

Amendment EA

Existing ISR/resin licensee proposes an additional 

ISR/resin close by with strong hydro/geo connection

License Complex EA* Existing ISR/resin licensee proposes an additional ISR/resin w/ no strong connectionLicense Complex EA* New applicant proposes a new ISR/resin, resin shipped to separate business entity’s CPPLicense Complex EA* New applicant or existing licensee proposes a new ISR/yellowcake 

ENVIRON 

PROCESS

LICENSING 

PROCESS

ISR-RELATED APPLICATION

•New licenses would require complex EAs that are tiered off of the GEIS issued in draft (7/28/08); If EA 

result in F

O

N

SI, an EI

S would be required
Fee Issues• Recognize potential for fee inequitie• Will consider potential changes to fe

categories based on potential applicexpectations
Summary• Number and variety of ISR applications = ne

position on approach to licensing actions

• Additions or enhancements to a licensed ur

recovery facility at the primary site of the facapproved through a license amendment

• “Strong connection” facility additions not loc

the primary licensed site approved through amendment

• Strong connection = operational or hydro-ge• If neither of conditions allowing license 

amendments met, proposed action requires separate license
Path Forward• Issue RIS on licensing process befo

NRC/NMA Workshop

• Address any fee structure proposals 

during the annual fee rule process; fee rule for comment Feb 2009; 30 comment period
Lessons Learned – New Facili

Applications

Stephen J. Cohen

Team Leader

Uranium Recovery Licensing Bra

U.S. Nuclear Regulatory Commis
Lessons Learned – Applicants• Application Completeness• Unusual Site Conditions• Health Physics Program• Operations• Radiation Protection• Decommission Plans/Surety• Groundwater Reclamation
Lessons Learned – NRC• Guidance Document Errors• Review Process/Schedule Managem• Applicant Interaction• Coordination of Reviews• Acceptance Reviews
NRC Actions• Guidance Revisions• Coordination or ER and UR Schedu• One Point of Contact• Clarity of Milestones
George Pangburn

Deputy Director

Office of Federal and State Materia

Environmental Management Prog

Events – Operating and New Fa• Commission Briefing – December 11, 2008• Received 8 applications for new facilities since 

– 2 Actions Completed for Operating Facilities– Accepted 5 applications for detailed review– 1 Application Not Accepted– Issued RAIs for 4 Applications– Supporting 3 Hearings – Crow Butte (2), Cogema

• ISR GEIS• Consultations – Gov’t. – Gov’t. and Mutli-Agenc• 24 – month review schedule intact
Current Issues - New Licensing

• Budget and Staffing• Stakeholder Outreach• Programmatic Uncertainty - Beyond 

FY2012

• Guidance Development• Hearings• Application Quality