Revision 1 

tilN REQ1 ,4 November 1977 

S& 1 U.S. NUCLEAR REGULATORY COMMISSION 

C REGULATORY S) GUIDE ,e 

OFFICE OF STANDARDS DEVELOPMENT 

REGULATORY GUIDE 3.5 

STANDARD FORMAT AND CONTENT OF LICENSE 

APPLICATIONS FOR URANIUM MILLS 

A. INTRODUCTION paragraph what information the 'plicant wishes to reference and hwsuch info n sprtinent. 

In order to process or refine ores containing by 

weight 0.05% or more of uranium, after removal Changes to existing (lic e) pr s require the 

from their place of deposit in nature, an NRC Source issuance of an approp 'ate ense hendment. An 

Material License is required. An applicant for a new application for such nt should describe 

license or renewal of an existing license to receive, the proposed cha 

possess, and use source materials is required to pro- I 

vide detailed information on his proposed facilities, G PPLICATION 

equipment, experience, and procedures. This infor- An app n a uranium milling license 

mation is used by the Commission in determining shout •ing Form NRC-2 in accordance whether the applicant's proposed activities will, wj4th , ments specified in § 40.31 of 10 CFR 

among other things, result in undue risk to the health re uired by § 40.31(t() of 10 CFR Part 40, 

and safety of the public. General guidance for filing m~lic on for a new license should be filed at 

an application is approved in § for 40.31 peciic of 10 CFR Part e_ __n for to cense ou ction icenes."Thee months prior to commencing construction 40, "Applications for Specific Licenses." The pur-'•i proposed mill. An application for renewal of 

pose of this guide is to provide specific guidan n existing license should be filed at least thirty days 

the format and content of an application for oir to the expiration of the existing license. Appli

Source activities. Material The information License authorizing in this guide uranium BecainmybefldwtthDrcoOfcefNu cations may be filed with the Director, Office of NU

aveTi his gclear Materials Safety and Safeguards, U.S. Nuclear 

provide instructive guidance and sho not• - Regulatory Commission, Washington, D.C. 20555. 

sidered a substitute for a careful ev ation Applications may also be filed in person at the Com

proposed program by the mission's offices at 1717 H Street NW, Washing that the application clearly and s adequate escribes ton, D.C. or 7915 Eastern Avenue, Silver Spring, the radiation safety procedes that will be followed. Maryland. 

Information not spe cal .scussed in this guide The National Environmental Policy Act of 1969 

should be included int I n if it is an impor- (83 Stat. 852), implemented by Executive Order 

tant part of an t'l diation protection pro- 11514 and the Council on Environmental Quality's 

gram. An inco lete nliction will result in delay Guidelines of August 1, 1973 (38 FR 20550), re

of issuance ens nd may result in denial of a quires that all agencies of the Federal Government 

license ic 0 prepare detailed environmental statements on propos

Informa submitted to the Commission may be als for legislation and other major Federal actions 

incorporated the application by reference. How- significantly affecting the quality of the human envi

ever, each reference should be clear and specific, ronment. The principal objective of the National En

i.e., the reference should indicate by date, page, and vironmental Policy Act of 1969 is to build into the

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission, US. Nuclear Regu

Regulatory Guides are issued to describe and make available to the public methods latory Commission. Washington. D.C. 20555. Attention: Docketing and Service 

acceptable to the NRC staff of implementing specific parts of the Commission's Branch. 

regulations, to delineate techniques used by the staff in evaluating specific problems The guides are issued in the following'ten broad divisions: 

or postulated accidents, or to provide guidance to applicants. Regulatory Guides 

are not substitutes for regulations, and compliance with them is not required. 1. Power Reactors 6. Products 

Methods and solutions different from those set out in the guides will be accept- 2. Research and Test Reactors 7. Transportation 

able if they provide a basis for the findings requisite to the issuance or continuance 3. Fuels and Materials Facilities 8. Occupational Health 

of a permit or license by the Commission. 4. Environmental and Siting 9. Antitrust Review 

5. Materials and Plant Protection 10. General 

Comments and suggestions for improvements in thest guides are encouraged at all 

times, and guides will be revised, as appropriate, to accommodate comments and Requests for single copies of issued guides (which may be reproduced) or for place

to reflect new information or experience. However, comments on this guideif ment on an automatic distribution list for single copies of future guides in specific 

received within about two months after its issuance, will be particularly useful in divisions should be made in writing to the US. Nuclear Regulatory Commission. 

evaluating the need for an early revision. Washington, D.C. 20555, Attention: Director. Division of Document Control.
agency decisionmaking process an appropriate and 

careful consideration of environmental aspects of 

proposed actions, Title 10 CFR Part 51, "Licensing 

and Regulatory Policy and Procedures for Environ

mental Protection," sets forth the NRC policy and 

procedures for the preparation and processing of en

vironmental impact statements and related documents 

pursuant to section 102(2)(C) of the National En

vironmental Policy Act of 1969 in connection with 

the Commission's licensing and regulatory activities. 

The provisions of 10 CFR Part 51 and § 40.31(f) of 

10 CFR Part 40, "Licensing of Source Material," 

require the submittal of environmental reports by ap plicants for NRC permits and licenses for certain 

facilities, including uranium mills. Thus, an applica

tion for a uranium milling license must be accom

panied by an environmental report.* 

C. CONTENTS OF AN APPLICATION 

The application should contain the information 

specified in items I through 8 of Form NRC-2. The 

information required in items 9 through 14 of Form 

NRC-2 should be incorporated into the various items 

identified below. Each subject should be treated in 

sufficient depth to permit the Commission independ ently to determine whether the applicant's proposed activities will be conducted in accordance with NRC 

rules and regulations. All pages of the application 

should be numbered and dated. 

1. PROPOSED ACTIVITIES 

This section should briefly discuss the overall mill

ing proposal for which a license is requested, includ

ing the following: a brief description of the proposed 

mill and its location; the corporate entities involved; 

the maximum design throughput of the mill; U3Os 

content of the ore to be processed; concentrate yield; milling process; tailings management; estimated time 

schedules for construction and startup; and antici

pated lifetime of the mill. 

2. SITE CHARACTERISTICS 

This section should provide information on the lo

cation of the mill and a description of the geograph ical, demographic, meteorological, hydrological, 

seismological, and geological characteristics of the 

site and surrounding vicinity. Sufficient information 

should be provided to permit an independent evalua

tion of site characteristics from a safety viewpoint. Applications may reference the pertinent section in 

the accompanying environmental report, prepared in 

conformance with NRC Regulatory Guide 3.8.' 

* NRC Regulatory Guide 3.8, "Preparation of Environmental 

Reports for Uranium Mills," provides specific guidance on the 

contents of art applicant's environmental report.

2.1 Geography and Demography 

2.1.1 Geography 

A geographic description of the area in which the 

mill is located should be provided, including (1) 

maps showing the location of the site with respect to 

State, county, and local subdivisions, plus nearby in

habited areas and (2) maps (topographic, if available) 

showing the mill, mill perimeter, tailings location, 

exclusion area boundary, company property, abutting 

and adjacent properties, nearby water bodies, and in

habited areas, plus other relevant details. 

2.1.2 Demography 

A description of the potentially affected population 

within a 5-mile radius of the mill should be provided. 

Current resident population information, based on 

most recent census data, should be provided as well 

as the projected population for the anticipated life of 

the mill. Significant transient or seasonal population 

variations should be identified and discussed, includ

ing bases for assumptions and projections. 

2.2 Meteorology 

This section should provide a meteorological de

scription of the site and surrounding area. Sufficient 

information should be included to permit an inde

pendent evaluation by the NRC staff of atmospheric 

diffusion characteristics of the local area. The 

sources of information and data supplied should be 

stated and should include (1) diurnal and monthly av

erages and extremes of temperature and humidity; (2) monthly wind characteristics including speeds and di

rection, annual joint frequency of wind speed, and 

direction by stability category; (3) data on precipita

tion; and (4) frequency of occurrence and effects of 

storms. 

2.3 Hydrology 

Sufficient information should be provided to allow 

an independent review to be made of all hy

drologically related design bases, performance re

quirements, monitoring specifications, and operating 

procedures important to safety. Identify the sources 

of the hydrological information, the types of data col

lected, and the methods and frequency of collection. 

2.3.1 Groundwater 

Describe the regional and local groundwater aquif

ers, formations, sources, and sinks. Describe the re

charge potential of the immediate plant area, includ

ing vertical and horizontal permeabilities of the natu

ral and modified terrain, as well as that of tailing 

areas. Describe the present and projected regional 

use; tabulate existing private users within the area in

fluenced by the proposed activities and all local and 

regional public users (amounts, water levels, loca3.5-2
tions, and drawdown); indicate gradients and sea

sonal variations in groundwater levels beneath the 

site. 

2.3.2 Surface Water 

Describe the location, size, shape, and other hy

drologic characteristics of streams, rivers, lakes, 

marshes, estuaries, etc., of the environs. Include a 

description of any upstream and downstream river 

control structures and downstream water supply users 

(including location, amount, and purpose, e.g., 

domestic, agricultural), and provide a map (topo

graphic, if available) showing major hydrologic fea

tures of the area. 

2.4 Geology and Seismology 

Provide the geologic and seismic characteristics of 

the area and site, the nature of the investigations per formed, the results of investigations, conclusions, 

and identification of information sources. Supple

ment the written description with tables and legible 

graphics as appropriate. 

2.4.1 Geology 

Describe the geologic aspects of the site. The dis

cussion should note the broad features and general 

characteristics ot the site and environs including 

stratigraphy and structural geology. Describe charac

teristics of the subsurface soil or rock including the 

identification and evaluation of zones of deformation 

that might act as conduits for contaminants. 

2.4.2 Seismology 

Discuss the seismicity (including history) of the 

region. Where possible, associate seismic events with 

tectonic features identified in the geology discussion. 

Furnish a regional earthquake epicenter map showing 

site location. 

3. MILL PROCESS AND EQUIPMENT 

Provide sufficient information in this section on the 

mill process and operating equipment to permit the 

independent assessment of the radiological protec

tion factors associated with the proposed milling 

operations. 

3.1 Mill Process 

Provide a quantitative flow diagram of the mill 

process showing the maximum mill throughput per 

unit time including the anticipated moisture content 

of the ore and the composition of all flow streams for 

each major step in the process. 

3.2 Mill Equipment 

Provide a physical description and the operating 

characteristics for all major items of mill process

equipment. Include a diagram of the mill layout indi

cating areas and points where dusts, fumes, and gases 

are generated. The diagram should also show the lo

cation of the ventilation, filtration, confinement, and 

dust collection systems referenced in item 4.1 and the 

location of radiation monitoring equipment refer

enced in items 5.5(1) and 5.5(2). 

3.3 Instrumentation 

Provide a description of all process instrumentatiot. 

and control systems relevant to safety and all radia

tion safety sampling and monitoring instrumentation, 

including their minimum specifications and operating 

characteristics. Also, describe and identify by make, 

model number, purpose, and location each radioac

tive source and/or gauging device used throughout 

the mill for which a license is required under the pro

visions of 10 CFR Part 30, "Rules of General 

Applicability to Licensing of Byproduct Material." * 

The instrumentation associated with leak testing such 

sources and/or devices should be identified in this 

section. 

4. WASTE MANAGEMENT SYSTEM 

4.1 Gaseous 

Provide a description of all ventilation, filtration, 

confinement, and dust collection systems that are 

used during mill operations to control gaseous 

radioactive materials. Include the type, specifica

tions, and locations of such systems, e.g., ore trans

fer points, crushing, grinding, etc. Include an analy

sis of the efficiency of the equipment as designed and 

operated to prevent radiation exposures to employees 

and to limit such exposures to as low as is reasonably 

achievable. Also, include a description of mill dis

charge stacks, including stack heights, types and 

concentration of effluents discharged, and methods 

(i.e., scrubbers, filters, etc.) for controlling releases 

of radioactive materials and for limiting such releases 

to as low as is reasonably achievable. 

4.2 Liquids and Solids 

1. Where retention systems such as levees, dikes, 

ponds, etc., are used to prevent the release of liquid 

or solid wastes containing radioactive material to 

offsite areas, provide the information specified in 

the regulatory position of Regulatory Guide 3.11, 

"Design, Construction, and Inspection of Embank

ment Retention Systems for Uranium Mills" (appli

cable information concerning this subject provided in 

section 2 above need not be repeated here). 

• These sources will be authorized in the mill operating license 

rather than separate NRC byproduct material licenses.

3.5-3
2. If effluents are to be released into waters of the 

United States, provide a discussion of the status of 

efforts to obtain a water quality certification under 

Section 401 and discharge permits under Section 402 

of the Federal Water Pollution Control Act, as 

amended, or submit copies of these items if already 

issued. 

4.3 Contaminated Equipment 

Provide a description of the methods for disposing 

of contaminated waste solids (such as filters, filter 

presses, obsolete or worn-out equipment) that are 

generated in the milling process. 

5. OPERATIONS 

Compliance with the statements, representations, 

and procedures provided in this section will normally 

be made a specific condition of the NRC operating 

license. Thus, the following should be considered as 

specific commitments on the part of the applicant for 

conducting mill operations and radiological protec

tion programs. In order to facilitate administration of 

the license by the licensee and NRC, this section 

should be complete in itself, insofar as possible, 

without references to other submittals. Also, the 

bases for all programs addressed in this section, as 

well as demonstration of their adequacy, should be 

provided. 

5.1 Corporate Organization and 

Administrative Procedures 

1. Provide a detailed description of the applicant's 

organization, including authority and responsibility 

of each level of management and/or supervision in 

regard to development, review, approval, implemen

tation, and adherence to operating procedures, radia

tion safety programs, routine and nonroutine mainte

nance activities, and changes in any of the above. 

2. Describe the management control program and 

administrative procedures to ensure that all activities 

are conducted in accordance with written operating 

procedures that are approved and reviewed at speci

fied frequencies by radiation safety staff. This pro

gram should provide a method for ensuring that any 

nonroutine work or maintenance activity, not covered 

by an effective operating procedure, is conducted in 

accordance with a special work permit reviewed and 

approved by the radiation safety staff. 

3. Describe the management audit and internal in

spection program, including types and scopes of re

views and inspections, frequencies, action leyels, and 

corrective action measures in regard to the foregoing 

activities. Also identify by management position the 

individual responsible for each phase of the audit and 

inspection program.

4. Provide a detailed description of the program for 

ensuring that employee exposures (both airborne and 

external radiation) and effluent releases are "as low 

as is reasonably achievable." 

5.2 Qualifications 

Provide a description of the minimum qualifica

tions and experience required of personnel to hold 

positions in the applicant's organization assigned the 

responsibility for developing, conducting, and ad

ministering the radiation safety program for the mill. 

Also, provide as an appendix the qualifications of the 

individuals currently holding these positions. 

5.3 Training 

Provide a description of the employee radiological 

protection training program addressing the following: 

content of the initial training or indoctrination, test

ing, on-the-job training, and extent and frequency of 

retraining. As an appendix, provide a copy of the 

written radiological safety instructions provided em

ployees. These instructions should include provisions 

for personal hygiene including washing, contamina

tion surveying prior to eating or leaving the mill, in

structions for wearing personnel monitoring devices 

and respirators, and instructions for good housekeep

ing requirements and for cleaning up dust and spills 

within the mill. 

5.4 Security 

Provide a description of the method for preventing 

unauthorized entry to both the mill and the tailings 

systems. 

5.5 Radiation Safety 

Provide a description of the radiation safety pro

gram that has been developed for determining that 

occupational radiation exposures and effluent releases 

will be as low as is reasonably achievable. Include 

the following: 

1. A description of the methods, instrumentation, 

and equipment for determining exposures of employ

ees to external radiation during normal and non

routine operations, maintenance, and cleanup ac

tivities. Provide the type of surveys conducted, 

criteria for determining survey locations, frequency 

of surveys, action levels, management audits, and 

corrective action requirements. For personnel 

monitoring devices such as film badges, indicate the 

number and category of personnel involved in the 

program and the sensitivity and range of the devices. 

For survey instruments, provide instrument sen

sitivities, ranges, and calibration methods (in an ap

pendix) and frequencies.

3.5-4
2. A description of the sampling program that is 

followed to determine concentrations of airborne 

radioactive materials (including radon) within the 

mill during routine and nonroutine operations, 

maintenance, and cleanup activities. In the descrip

tion of the sampling program include 

a. The criteria for determining sampling loca

tions with respect to process operation: and personnel 

occupancy and 

b. The frequency of sampling, type of analysis, 

sensitivity of overall sampling and analysis, action 

levels, management audits, corrective action re

quirements, and instrumentation calibration fre

quency. Procedures for sample analysis and instru

ment calibration should be included as an appendix. 

3. A description of the procedure followed in de

termining the intake of radioactive materials, in con

formance with § 20.103 of 10 CFR Part 20, for each 

employee who occupies areas where airborne radioac

tive materials exist. Include exposures incurred dur

ing nonroutine operations, maintenance, and cleanup 

activities as well as routine activities. 

4. A description of the bioassay program to be 

conducted to confirm the results derived from the 

programs identified in items 2 and 3 above. Indicate 

the number and category of personnel involved in the 

program, the types and frequencies of bioassays per

formed, and action level criteria to be applied to 

bioassay results. 

5. A description of the survey program to deter

mine that employees (plus their workclothes or 

coveralls, etc.) entering clean areas (lunchrooms, of

fices, etc.) of the mill or leaving the mill site are not 

contaminated with radioactive materials. Include 

good housekeeping and cleanup requirements and 

specifications in mill process areas to control con

tamination, frequency of surveys of clean areas, sur

vey methods, and minimum sensitivity, range, and 

calibration frequency of survey equipment. Provide 

contamination criteria or action levels for clean areas 

and for the release of materials, equipment, and 

workclothes to clean areas or from the site. Proce

dures for instrument calibration should be included as 

an appendix. 

6.* A description of the survey program, methods, 

and procedures for determining concentrations and 

quantities of airborne radioactive materials released 

to the environs and a description of the environmental 

monitoring program to be conducted plus the techni

cal basis therefor (i.e., a correlation of stack heights, 

meteorological characteristics, etc.) to determine en

vironmental concentrations. 

* 40 CFR Chapter 1, Part 190, and Regulatory Guide 4.14, 

"Measuring, Evaluating, and Reporting Radioactivity in Re

leases of Radioactive Materials in Liquid and Airborne Effluents 

from Uranium Mills," should be reviewed in connection with 

this section.

For both environmental and effluent monitoring, 

the frequency of sampling and analysis, the types and 

sensitivity of analysis, action levels and corrective 

action requirements, and the minimum number and 

criteria for locating environmental and effluent 

monitoring stations should be provided. Proposed lo

cations should be indicated on a figure of the mill and 

surrounding area in an appendix. 

7.* A description of the liquid effluent survey pro

gram to determine if process effluents are reaching 

subterranean or surface water supplies. This should 

include the technical basis therefor, the minimum 

number of monitoring locations, the criteria for locat

ing sampling stations, the frequency of sampling, and 

action levels and corrective action requirements. Pro

vide the step-by-step procedure for sample analysis of 

natural uranium, radium-226, and thorium-230 as an 

appendix. Also, the proposed monitoring locations 

should be shown on a figure of the mill and surround

ing area in an appendix. 

8. A description of the radiation safety program 

associated with the radioactive sources and. gauges 

identified in section 3.3 above. Include methods and 

frequencies for leak testing the radioactive source. 

9. A description of the interim stabilization proce

dures (during milling operations) to eliminate the 

blowing of tailings from the tailings retention system 

to unrestricted areas and the ore dust from the ore 

piles should be provided, including the demonstration 

of the adequacy of these procedures under potential 

wind and weather conditions at the site location. 

10. Provide the minimum performance specifica

tions, such as filtration or scrubber efficiency and air 

flow, for operating the mill ventilation, filtration, 

confinement, and dust collection systems throughout 

the mill and associated laboratories at their rea

sonably expected best performance and the frequency 

of tests and inspections to ensure that these specifica

tions are being met. 

11. Provide a decommissioning program that in

cludes reclamation of the mill site at the termination 

of milling activities and the surety arrangements to 

ensure that sufficient funds are available to complete 

this decommissioning program. 

12. Provide a tailings management and reclama

tion program addressing the following performance 

objectives: 

a. Reduce direct gamma radiation from the im

poundment area to essentially background. 

b. Reduce the radon emanation rate from the 

impoundment area to about twice the emanation rate 

in the surrounding environs. 

c. Eliminate the need for on ongoing monitoring 

and maintenance program following successful 

reclamation.

3.5-5
d. Provide surety arrangements to ensure that suf

ficient funds are available to complete the full recla

mation plan. 

6. ACCIDENTS 

A spectrum of potential mill accidents ranging 

from trivial to serious should be established by classes of occurrence, and each class of accidents 

should be appropriately evaluated. The evaluation 

should include a discussion of measures that have 

been implemented to prevent accidents and a demon

stration of the adequacy of the methods. Emergency 

plans and training for coping with accidents should 

also be described. For example, potential accidental 

fires should be discussed in terms of occurrence, pre vention, detection and suppression mechanisms (both 

manual and automatic), and emergency plans for cop ing therewith. The adequacy of the program should 

also be discussed. 

7. QUALITY ASSURANCE 

The quality assurance program for all. phases of the 

milling project including design, construction, startup and operation, and the radiation safety program (including the in-plant, effluent, and environmental 

monitoring programs)* should be defined and dis

cussed. Also discuss the corrective action measures 

established to ensure that conditions adverse to qual ity are identified and corrected and that the cause of 

significant conditions adverse to quality is deter

mined and corrective action taken to preclude repeti tion. 

8. EVALUATION OF ALTERNATIVES 

Where the proposed course of action was based on 

the consideration of various alternatives, the 

benefit-cost analysis used in arriving at the "as low 

as is reasonably achievable" concept should be pre sented, and the rationale for the recommended course 

of action should be included. 

* The NRC staff is preparing a regulatory guide on quality as surance for radiological effluent and environmental monitoring 

programs that is scheduled to be published for comment in De

cember 1977.

3.5-6
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