ML19305C009
| ML19305C009 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/1980 |
| From: | Krug M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Stricklan K AFFILIATION NOT ASSIGNED |
| References | |
| REF-WM-22, REF-WM-24 NUDOCS 8003250467 | |
| Download: ML19305C009 (2) | |
Text
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FEB 2 81980
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Ms. Kay Stricklan
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P. O. Box 1228 Canon City, Colorado 81212
Dear Ms. Stricklan:
We received a copy of your letter to Mr. Douglas Costle of the U. S.
Environmental Protection Agency (EPA), dated January 22, 1980, and would like to address your c~ncerns. The EPA's regulation, 40 CFR Part 190, o
" Radiation Protection Standards for Nuclear Power Operations," which will be effective for uranium milling operations in December 1980, limits the annual doses to any member of the public as a result of exposures to planned discharges of radioactive materials to the general environment to 25 mi.llirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ.
(The regulation excludes the dose contribution from radon and its radioactive daughters.) Thus, to determine compliance with the limits of 40 CFR Part 190, the doses to each. organ are not added, but calculated separately.
.The U. S. Nuclear Regulatory Commission's (NRC) staff will independently L
calculate the estimated dose commitments to individuals and populations as part of the staff's evaluation of the proposed Hansen Project.
The E
report analysis will compare the predicted doses with applicable regulations and recommend license conditions to the State of Colorado to assure appropriate Federal standards are met and exposures are monitored during operation of the facility.
For the review of the Cotter Corporation's uranium mill near Canon City, the NRC staff conservatively estimated that the maximum individual dose commitment could exceed the 40 CFR Part 190 limits (e.g., the bone dose was calculated as 25.72 millirem / year).
However, a comprehensive radiological monitoring program has been recommended and instituted to determine if additional measures are needed to assure off-site doses meet the EPA standards.
The NRC staff did not estimate any radiation exposure of 64 millirem /vear resultino from the Cotter facility.
It'is assumed that the quoted number was calculated by adding the estimated maximum individual dose commitments for the total body, bone, lung, and bronchial epithelium, which were included in the NRC staff's environmental assessment report (copyenclosed). As discussed previously, it is incorrect to add these doses to determine compliance with the limits of 40 CFR Part 190.
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Ms. Kay Stricklan ',
The NRC staff has recently developed perf6rmance objectives for an acceptable ' uranium mill tailings management program, based upon the most
- up-to-date technology.: These performance objectives are outlined in the enclosed staff technical position paper.
One of these objectives is to
" locate the tailings isolation area remote from people such that population exposures would be reduced to the maximum extent reasonably achievable."
.This performance objective must be satisfied in tailings management system proposals for new facilities. However, during the review of existing tailings management systems, e.g., during license renewals, locations are reviewed to determine if sufficient cause exists to require an alternate disposal location for tailings generated as a result of milling operations. In any case, as noted earlier, Cotter will
- have to meet the EPA standard. Regarding the location of new facilities, there is no specific distance limit to meet the remoteness objective.
The_ acceptability of a ta'. lings management proposal is based upon a complete evaluation of the proposal with respect to the tailings management /
performance objectives, in addition' to compliance with applicable Federal regulations such as 40 CFR Part 190.
It is hoped that this'information sufficiently addresses your concerns.
Please contact me at (301) 427-4103 if you require any further information.
Sincerely,
$q)ArwnR
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r Madonna E. Krug Project Manager Uranium Recovery Licensing Branch Division of Waste Management
Enclosures:
1.
' U. S. Nuclear Regulatory Commission, " Environmental Assessments of the Tailings Management Program and Radiological Effluents for the Proposed Expansion of the Cotter Corporation Uranium Mill at' Canon City, Colorado," Revision 1, April 1979.
.2.
U. S. Nuclear Regulatory Commission, " Branch Position -Uranium Mill Tailings Management," May 13,.1977.
cc: James L. Montgomery W
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