ML20008F752

Compliance Determination Procedures for Environ Radiation Protection Stds for U Recovery Facilities:40CFR190

ML20008F752
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Issue date:	12/31/1980
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20008F750	List: ML20008F749 ML20008F751 ML20008F752
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CCMPLIANCE DETERMINATION PROCEDURES FOR ENVIRONMENTAL RADIATION PROTECTION STANDARDS FOR URANIUM RECOVERY FACILITIES 40 CFR 190 U. S. Nuclear Regulatory Ccmission Division of Waste Management Uranium Recovery Licensing Branch December, 1980 1

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Title:

Compliance Determination Procedures for Environmental Radiation Protection Standards for Uranium Recovery Facilities - 40 CFR 190 Backcround Under Title 40 Code of Federal Regulations Part 190 - Subchapter F -

Radiation Protection Programs, the U.S. Environmencal Protection Agency (EPA) promulgated " Environmental Radiation Protection Standards for Nuclear Power Operations" which provides ilmits for the radiation doses received by members of the public in the general environment as the result of operations which are part of the nuclear fuel cycle. Effective December 1, 1980, each uranium ailling facility

• shall conduct its operations in such a manner to assure that the annual radiation dose equivalent of 25 millirems to the whole body, 75 millircas to the thyroid, and 25 millirems to any other organ of any member of the public is not exceeded. However, the dose from radon and its daughters is excluded from these doses. The following discussion briefly describes the Nuclear Regulator;* Cennission's (NRC) program for como11ance determination for uranium recovery facilities.

In April,1980, the NRC published a proposed amendment to 10 CFR Part 20

" Environmental Radiation Protection Standards for Nuclear Power Operations" and will shortly finalize this amendment which requires that a NRC licensee shall comply with 40 CFR 190. This program is also meant to serve as guidance for the Agreement States in their implementation of 40 CFR 190.

As illustrated by radiological assessments performed in the uranium milling generic environmental f= pact statement (GEIS), 40 CFR 190 compliance will be achieved only by strict emission controls at the mill. The most significant sources of emissions are the tailings ponds / piles and the yellcwcake dryer stacks. The NRC has made strict emission control a cpecific license condiMon in its licensing activities over the past several years; and it has been an NRC requirement that exposure limits be met by en.ission controls to the maximum extent reasonably achievable.

Such emission control requirements are contained in the May,1977 NRC staff position on " Tailings Management Perfonnance Objectives" and in the final regulations on uranium milling issued in the Federal Register on October 3,1980. A copy of the criteria in these regulations covering emission controls is attached as Appendix B.

Certainly land use control, e.g., expanding the buffer zone around a mill site, cannot exclusively be used as a substitute for reducing actual emissions from the various milling processes. The primary means of meeting exposure limits must be i

by emission control.

All uranium extraction facilities; to include mills, in-situ operations and heap leach facilities. R&D facilities are not incluced nere since initial assessments indicate that their size and potential radiological impact are insignificant; e.g., R&D in-situ operations in general have no airborne particulate releases.) Mcwever, the Edgemont mill site and the other sites selected for remedial actions for the cleanup of mill tailings (i.e., at abandoned mill sites or off-site areas where tailings have been used) have been excluded from 40 CFR 190 compliance c'uring the remedial action work phase.

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_ There are inherent problems in accurately determining source terms, particularly from large area sources such as the tailings impoundments.

Also, there are significant uncertainties in the atmcspheric transport models used to ccmpute airborne radioactivity concentraticns given a scurce term, particularly where there is irregular terrain. Therefore, the primary means of detennining compliance must be by measurements made at the point of receptor and the procedures outlined below reflect this, j

On the other hand, ccmpliance cannot reasonably be determined and corrective action taken where necessary, by inflexibly and rigidly considering point of receptor data alone. Therefore, environmental measurements at other locations near the mill and at background locations, effluent sampling, meteorologic data, and other similar information must be available to supplement point of receptor data.

Such supplemental information is required most in cases where computed doses approach or exceed the limit. Other monitoring data will be necessary, for examole, to screen out effects of mines that may be nearby and may be contributing tu dose.

By no means will the mere assertion that the mill operations utili::e emission controls suffice to show ccmpliance to 40 CFR 190 exposure limits. The licensee must provide scme succortable dose assessments based on actual environmental monitoring data which are compatible with the procedures discussed below.

Procedure The.1RC staff will implement 40 CFR 190 in a phased fashion as shown in Figure 1.

Eventually a standardi::ed procedure which will be used to assess compliance subsequent to the establishment of each licensee's Environmental Monitoring Program (EMP) will be established.

It will realistically require as much as a year's worth of effluent and environmental menitoring (Phase 1 of Figure 1), however, to firmly establish whether compliance exists at mills which are close to tue limit or where there are significant nearby sources of radioactive emissions such as mines, which are not covered by the standard. Mucn of this time will be spent on the fine tuning of the monitoring and analysis program that is nonnally required in setting up such programs to assure they are operating properly and producing reliable data. It will also take some time to sort out the contributions being made by other sources. This may require some short-tenn, special environmental measurements. Special studies of the effectiveness of selected emission control measures may be required.

These evaluations may be supplemented by computer assessments as needed and appropriata.

I Eventually, under Phase 2,it is anticipated that concentration and/or dose action levels (which may even be higher than 25 millirems accounting for contributions from other sources) will be established, in combination with specific control measures and levels, as the threshold for detennining compliance with the standard. This will reduce costs of implementation, i

eliminate uncertainty on the part of the licensee, regulatory agency and the public (particularly in cases where there are significant extraneous sources), and assure that the need for remedial action is identified most expeditiously if it exists.

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l FIGURE 1 PJIASEILIMI1EMENTAUDN DEC. 1, '80 PilASE 1 VARIAllLE PilASE 2 TIME A

NRC PROSPECTIVE INITIAL ONG0ING ASSESSMENTS ASSESSMENTS ASSESSMENTS f

0 IDEllTIFY LICENSES 0

COMPLETE POTENTIAL 0

INDICATOR POTENTIAL AMENDED !!Y INSTALLATION LICENSE CONCENTRATIONS PROBLEM ORDER -

0F EMP'S AMENDMENT WITil SPECIFIED AREAS 110 CFR 190 0

SORT OuT INSTITUTE IAKES EFFECT EXTRANEOUS SIMPLIFIED 0 ESTABLISH gg SOURCE ASSESSMENT MONITORING g

CONTR ilillT IONS PROCEDURE I

10 CFR 20 0 METE OR0tDGICAL l

INCORPORATES SET COMPLETED 110 CFR 190 0

Sn0RT TERM STUDIES i

AND IESTS 1

0 IDENTIFY NEEDED REMEDIAL CONTROL MEASURES, I F.ANY

- Before environmental monitoring data is available, which is the situation in licensing of new facilities or in authorizing significant modification to existing ones, predictive models must be utilized to evaluate the potential impacts of the prospective new operations. Use of predictive models, in addition to consideration of what limited environmental data exists, is also being used by the staff in the initial 40 CFR 190 implemen-tation efforts in December of 1980. Predictive modeling assessments of radioactivity concentrations to which nearby individuals may be exposed, involve making numerous assumptions and simplifications about important, but frequently uncertain, factors such as mill releases and atmospheric transport; for this reason, as discussed above, actual compliance detennination will be based on environmental monitoring data which indicate directly what such concentrations are. Predictive models, however, are necessary and valuable tools in evale' ting what emission controls are likely necessary, in identifying potential problem areas, and in establishing environmental monitaring requirements.

The fcilowing describes the procedures which shall be followed in (A) determining compliance with 40 CFR 190 based on environmental monitoring data, and (B) assessing proposed operations in term of their ability to meet 40 CFR 190.

A.

Assessment of Actual Environmental Monitorina Data Figure 2 "a0 CFR 190 Comoliance Determination Procedure" shcws a diagram of the various steos to be folicwed to ultimately assure compliance to 40 CFR 190 for all licensing applications.

1.

Each licansee shall establish an Environmental Mcnitoring Program (EMP) consistent with NRC's Regulatory Guide 4.12,

" Radiological Effluent and Environmental Monitoring at Uranium Mills" (April 1980). This document provides specific details for both a pre-operational and the operational moni-toring programs which are considered adequate by the staff to obtain the necessary information to be used by the licensee to estimate the maximum potential annual radiation dose to any member of the general public as a result of actually measured mill effluent releases.

In order to establish such an acceptable EMP, each applicant / licensee shall be required to:

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a.

Develop an EMP and submit a plan to the NRC for review I

and approval. Such a plan shall include specific details l

of the numoer, location, collection method (i.e., equipment),

l sampling frequency and analysis infonnation for all i

sample types (e.g., air particulate, radon /W1., stack

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samples, surface and ground waters, vegetation, food, fish, soil, and direct radiation). For each site (including existing mills), at least one year of site specific metet mlogical data; e.g., wind speed and direction, stability class, etc., shall be collected, sumarized, l

and reported. A site map, including all affected off-l site areas, shcwing each point of sample collection shall l

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FIGURE 2 i

110 CFR 190 COMPLI ANCE IlETERMillATION PROCEDURE (8ASED ON ACTUAL ENVIRONMEllTAL MONITORING DATA)

EMP ESTAllLI Sil REPORTS EMP COMPLIAllCE fl0 CFR 190 ASSESSf1ENT COMPLIANCE g

l}ETERMINATION g

1 E

1r PLAN DEVELOPED DATA NRC PROJECT llY APPLICANT /

(IATilERED llY MANAGER LICENSEE l.ICENSEE REVIEW u.

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A-A APPROVAL ll0SES COMPLIANCE LICENSEE VARIANCES AND l.lCENSE CALCULATED llETERMINED CORRECTIVE REVIEWED /

AMEt>9t1ENT ACTION LICENSE IDENTIFIED AMENDMENT 2 r LICENSE REPORT AMENDMENT EMP SuriMITTED OPERATIONAL s

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IIOCUMENTATION iP IN ANNUAL IRL REPORT INSPECTION

' also be provided. Participation in a Quality Assurance Program (QAP) as described in NRC's Regulatory Guide 4.15, " Quality Assurance Programs for Radiological Monitoring Programs (Normal Operations) -Effluent Streams and the Environment" (February 1979) shall also be discussed in the EMP plan.

b.

Upon NRC's review and approval, the EMP shall be added to the license and any subsequent change or modification of the approved EMP shall require that a specific license amendment be initiated by the licensee.

c.

The EMP plan shall provide a time schedule providing the date when each phase of the EMP will become operational.

For new license applicapts, at least one year of pre-operational monitoring shall be required.

For existing facilities, a realistic time schedule shall be implemented; however, all phases of the EMP shall be operational within 120 days of NRC's approval of the EMP plan.

d.

The NRC's Office of Inspection and Enforcement shall conduct periodic an-site inspections of both the actual environmental monitoring systems / locations, as well as all reports and records of such an EMP to ensure that the actual operations of the EMP are within the approved EMP license condition.

2.

Each licensee shall provide an EMP report every six months, as i

required in 10 CFR 40.65, " Effluent Monitoring Reporting Requirements." The report should contain the specific information as outlined in Section 7 " Recording and Reporting Results" of NRC's Regulatory Guide 4.14, suora.

3.

As a license condition, each license shall be required to submit, in conjunction with its every six months EMP report (EMPR), its own 40 CFR 190 compliance assessment for NRC review and action, as described below.

i a.

Such an assessment shall be based on data gathered by the licensee frem the approved EMP as discussed above. Such use (gathering shall include a semiannual survey of land data i.e., residences, grazing, water wells, etc.) in the I

area within 8 km (5 miles) of the mill. Any difference l

in land use from that previously reported shall be discussed and evaluated with respect to 40 CFR 190 compliance.

In order to minimize records keeping and formal reporting requirements, while still maintaining a reasonable and timely review of the EMP, annual averages based on the l

innediate east two consecutive six month reporting periods shall be used for the compliance assessment ar.d reporting requirements.

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. b.

Dose evaluation using site specific input parameters shall be ccmpleted using the standardi:ed procedures delineated in Attachment A

" Dose Calculational Guidance",

which are based on NRC's draft Regulatory Guide RHp802-4,

" Calculational itdels for Estimating Radiation Coses to Man from Airborne Radioactive Materials Resulting from Uranium Milling Operations". These attached tables are provided to allow the rapid dose calculational assessment of environmental monitoring data. Variations in specific assumptions made in Attachment A will be considered by the staff upon request. Also, it is permissible to subtract out the contribution from background and extraneous sources as determined from measured concen-trations at background locations.

c.

As necessary, a licensee shall indicate in the recort what corrective action is being taken if ncn-comoliance is determined. Each licensee shall comolete its initial 40 CFR 190 compliance assessment and shall submit its EMP report for NRC review and approval prior to July 1,1981; and subsequently within 60 days after January 1 and July 1 of each year thereafter, so long as the license is active.

4 Once eacn year, the NRC shall review and ccmolete its cwn independent determination of each licensee's EMPR and 40 CFR 190 ccepliance assessment. Such a review shall consider the influence of extranecus sources (e.c., mining and transportation activities) and any ancmalous data (e.g., the indication of erroneous data generated during sample collection or sample analysis).

a.

The NRC Project Manager (PM) shall review all subnittals, and shall primarily be responsible for all approvals, license amendments and verification of 40 CFR 190 ccepliance.

1. Upon determination of compliance to 40 CFR 190, the PM will document such findings via a brief Memorancum to File (standardi:ed form memo) for the subject license within 30 days of receipt of reports submitted under3(c).

ii. Upon determination of non-comoliance to 40 CFR 190, the FM shall assure that the licensee take any necessary corrective actions and shall issue specific license amendments as required to accomplish this.

This may require differentiating extraneous sources such as background, mining and transportation activities; obtaining site specific meteorological data, concucting short-tens studies, etc. as shcwn in Phase 1 cf Figure 1 above.

- iii. The PM shall review any variance request per 40 CFR 190.11, and shall initiate appropriate licensing action as required. The EPA shall be notified whenever a variance is granted.

iv. The WUR PM for 40 CFR 190 Compliance assessment shall issue a brief annual report summarizing the results of the individual license compliance reviews.

This report shall also consider the cumulative dose to any member of the population due to exposure frem releases frcm multiple mill facilities in the general area. The EPA shall be provided with a copy of this summary report for their review and coment.

5.

The PM shall periodically review and evaluate the EMP, EMP recorts, and 40 CFR 190 compliance assessments, and shall eliminate any recuirements that experience shcws to be nonessertial or shall require specific actions necessary to shcw compliance.

For example, if the airborne concentration measurements show that there is no need to continue radium-225, or thorium-230 analyses, then such requirements shall be eliminated frcm the EMP. As shewn in Phase 2 of Figure 1, efforts will be made to streamline the periodic compliance assessment effort by prescribing specific concentration levels which, based on experience and in combination with other readily observable parameters related to mill operations and local land use, could be relied upon to detemine compliance.

3.

Predictive Mcdelinc Figure 3 "NRC 40 CFR 190 Assessment of Proscective Milling Operations" shcws a diagram cf the various steps to be followed by the NRC Project Manager in licensing reviews.

1.

All existing data, e.g., source term, environmental monitoring data, land use, population distribution, meteorology, etc.,

shall be gathered and reviewed by the NRC Project Manager (PM).

2.

The NRC PM shall complete an independent radiological assessment to 40 CFR 190 compliance based on predictive modeling using methodology as described in Regulatory Guide RHpS02-4.

3.

These assessments shall be documented in the Environmental Impact Statement (EIS) or environmental appraisal conducted in support of the licensing action. These assessments shall consider the cumulative dose to any member of the pcpulation due to exposure from releases from multiple mill facilities in the general area.

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APPEND 1X A Attachment A Dose Calculational Guidance The est; mated dose received by any member of the general population shall be calculated based on the applicable potential 3xposure of the nearest resident in the off-site area surrcunding the mill site. The total dose shall be the c;? of the external exposure (f.e., due to radiation sources outside the bcdy) and of the internal exposure (i.e., radioactive materials within the bcdy). Doses which are due to background and extraneous scurces should be subtracted from these measured at the nearest receptor. The contribution fran ncn-mill sources (e.g., mining and trsnsportation activities) should also be determined based upon actual measurements at representative background locations.

1.

External Radiation Ex;csure -

The cirect radiation exacsure may be assumed to be ecual to the actual personal c? envircnmental dosimetric data less the aporcpriate background contribution.

2.

Internal Radiation Exposure -

The total dose to crgans (e.g., lung, bone, wnole bcdy, etc.)

shall be evaluated based en sunning all applicable human pathways, sucn as:

a.

Inhalation of Airborne Particulates -

The measurad air:crne concentration multiplied by the dose c:nversicn facters as given in Table A-1.

c.

!ngestian of Ccntaminated Fced and Milk -

The measured ccncentration in the food product multipled by the dose conversion facter as given in Table A-2(a) through (c).

c.

Ingestian of Meat or Milk frcm Livestock Grazing on Contaminated Vegetation -

l ihe measured concentraticn in vegetation (e.g., grasses in gra:ing areas) multiplied by the dose conversien factor as given in Table A-3(a) and (b).

d.

Ingestien of Contaminated Water -

The measured concentratien in potable water multiplied by the dose conversion factor as given in Table A-4 l

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2-e.

Ingestion of Meat or Milk from Livestock Watered on Contaminated Water -

The measured concentration in water used by livestock for watering purposes multiplied by the dose conversion factor as given in Table A-5(a) and (b).

If any of the human exposure pathways as given above are not in evidence at a mill site, then that dose centributien cbvicusly does not need to be considered here. The total dose for each critical organ shall be obtained by sunning the dose due to each radionuclide of the uranium decay chain series (i.e., uranium, radium-225 and thorium-230) and through each pathway, i.e., inhalation plus external exposure plus any applicable ingestien pathways. Since 40 CFR 190 excludes the dose due to radon and its daughters, the dose contribution from lead-210 and polonium-210 have been excluced from these assessments of actual environmental monitoring data.

Mcwever, the dose due to the inhalation pathway shall be of primary concern, with the other pathways providing sucplemental information regarding pcssible expcsure. Additionally, a thercugh evaluatien of background conditiens must be ccmpleted so that any contributica due to the mill coerations (i.e., value measured at point of receptor less applicable backgrcund level) may be acequately assassed.

The point of receptor data must be reviewed in connection with other environmental and effluent acnit ring. data, and other apprcpriate information or assessment tools (such as ccmcuter modelino wnere this may be helpful). in cases wnere extranecus scurces may cause calculated deses to exceed the 40 CFR 190 limits or wnere ancmalous data may be encountered.

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Table A-1 Cose Conversion Factors for the Inhalation of Airborne Particulates I

(Millirem per pCi/m3)*

Whole Radionuclide Body Bone Lung U-238 4.32 79.2 1 58 U-234 4.92 79.5 180 Th-230 166 5950 2220 Ra-225 30.9 309 6610

• The 50-year dose eqmmitment for each year of exposure to 1 pCi/m4 of each radionuclide for an adult breathing rate of 20 m,/ day. Particle si:e of 1.55 um AMAD (i.a., mean diameter of 1 um and 3

density of 2.4 g/cm ) being representative of uranium cre. The Quality Factor for alpha radia-tiens is 10. The tetal dcse per organ is the summat!cn of doses due to each radionuclide.

(Final GEIS, NUREE-0706).

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Table A-2(a)

Case Converson Factors for Ingestien of Contaminated Meat (Millirem per I)*

U Radionucliae

'4 hole Body Bone Liver Kidney U-238 3.55 E-03 6.01 E-02 0.0 1.37 E-02 U-234 4.05 E-03 6.55 E-02 0.0 1.56 E-02 Th-230 4.46 E-03 1.61 E-01 9.16 E-03 4.42 E-02 Ra-225 3.60 E-01 3.60 E+00 4.49 E-04 1.28 E-02

• The 50-year dose ccmiitment for each year of ingestion of centaminated meat. The above factors corres;:end to an adult ingestion rate of 78.3 kg/yr of meat (beef, poultry, pork, mutton). (Regulatory Guide RH#802-4).

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i Table A-2(b)

Dose Conversion Facters for Ingestion of-Contaminated 5dible Vegetation (Millirem per cCf)

Kg Radienuclide Whole Bedy Bone Liver Kidney U-238 2.38 E-03 4.03 E-02 0.0 9.19 E-03 U-234 2.71 E-03 4.39 E-02 0.0 1.04 E-02 Th-230 2.99 E-03 1.C8 E-01 6.14 E-03 2.97 E-02 Ra-225 2.42 E-01 2.42 E+00 3.01 E-44 8.55 E-03

• The 50-year dose c:nnitment for each year of ingestien.cf contaminated ~

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edible vegetaticn.'

A facter of 50% activity reduction through food preparation was assumed, and an adult ingestien rate of IC5 kg/yr :::al vegetable ingestion rate, as well as uniform concentration throughcut all vegetable types. Sheuld data be presented as concentra-icn of edible above ground vegetables, C ; potatees, C ; and c:her below 9

gr:und vegeta les, C ; then the f 110 wing weighted cencentration 3

Cy should be used when multiplying the abcve dose factors:

C./ = 0.38 C1 + 0.58 C2 + 0.05 C,a Table 5 of Regulatory Guide RHiSC2-4 details the breakdown of vegetable censumation.

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Table A-2(c)

Ccse Conversion Facters for Ingestion of Contaminated Milk (Millirem per pCi/1)*

Racianuclice Whcle Socy Sone Liver Kicney U-238 5.90 E-03 9.97 E-02 0.0 2.28 E-02 U-234 6.72 E-03 1.09 E-01 0.0 2.59 E-02 Th-230 7.41 E-03 2.68 E-01 1.52 E-02 7.35 E-02 Ra-226 5.98 E-01 5.98 E+00 7.46 E-04 2.12 E-02

• The 50-year connitment for each year of ingestion of contaminated milk.

These values are based on an adult consu=ption rate of 130 liters / year.

Since children drink greater quantities, the resultant dose is much higher for ycunger pecple.

Ccse conversion fac:crs, as before, are for adults. Prcper dose conversion fac:crs and milk consumption rates for other age groups are presented in Regulatcry Guide RHiS02-4.

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Table A-3 '(a)

Dose Conversion.:acters for Ingestion of Meat frem Cattle Grazing on Centaminated Vegetation aCf (MilliRemper[g)*

Radionuclide

'4 hole Scdy Bone Liver Kidney U-238 5.04 E-05 1.02 E-03 0.0 2.33 E-04 U-234 5.28 E-05 1.11 E-03 0.0 2.55 E-04 Th-220 4.46 E-05 1.51,E-03 9.15 E-C5 4.42 E-C4 Ra-225 9.18 E-03 9.18 E-02 1.15 E-C5 3.25 E-04

'The 50 year dose cc=miteent for each year of ingestien of = eat. The above values are based en the follcwing.

i) Animal uptake of vegetation: 50 kg/ day fi) Enviren= ental transfer cefficients: /:Ci/k;\\

(pci/ cay) 9 U - 3.4 x 10-'

Th - 2.0 x 10

Ra - 5.1 x 10' fii) Adult = eat ingestien rate: 78.3 kg/ year iv) Adult ingestien dose conversten facters (see Regulatory Guide RHiSC2 4) l w

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Table A-3(b)

Cose Conversion Factors for Human Censumption of Milk frem Cairy Ccws Ingesting Centaminated Vegetation (M1111 Rem per cCi),

kg Radionuclide Whole Body Bone Liver Kidney U-238 1.80 E-04 3.03 E-03 0.0 6.94 E-04 U-234 2.05 E-04 3.31 E-03 0.0 7.S9 E-04 Th-230 1.55 E-06 6.70 E-05 3.30 E-06 1.84 E-05 Ra-225 1.76 E-02 1.75 E-01 2.20 E-05 6.25 E-04

• The 50-year dcse ccmmitment fcr each year of ingestion cf milk. The above values are based en the fcil: wing:

i) Animal uptake of vegetation: 50 kg/ day fi) Enviren= ental transfer coefficients:

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0 - 6.1 x 10-4 L

Th - 5.0 x 10-6 Ra - 5.9 x 10-4 iii) Adult censumption of milk: 130 liters / year I

iv) Adult ingestien dose conversion facters (see Regulatory Guide RHiE02 4) i

Table A-4 Ocse Conversion Factors for Human Consumption of Contaminated Water (Millirem per pCi),

1 Radionuclide Whole Body Bone Liver Kidney U-238 1.68 E-02 2.84 E-01 0.0 6.48 E-02 U-234 1.91 E-02 3.09 E-01 0.0 7.36 E-02 Th-230 2.11 E-02 7.62 E-01 4.33 E-02 2.09 E-01 Ra-226 1.70 E'00 1.70 E+01 2.12 E-03 6.03 E-02 The 50-year dese commit =ent for each year of ingestien of centaminated water. The above values are based en an average adult censametien rate of 370 liters / year (Regulatory Guide 1.109) and adult ingestion dese conversten facters (Regulatcry Guide RH#802-4).

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Table A-5 Dose Conversion Factors for Ingestion of Meat frcm Cattle Watered on Contaminated Water (Millirem per PCi).

1 Radionuclide Whole Body Bone Liver Kidney U-238 6.04 E-05 1.02 E-03 0.0 2.33 E-04 U-234 6.88 E-05 1.11 Ee03 0.0 2.65 E-04 Th-230 4.46 E-05 1.61 E-03 9.16 E-05 4.42 E-04 Ra-225 9.18 E-03 9.18 E-02 1.15 E-05 3.25 E-04

• The 50-year dose commitment for each year of ingestion of meat.

The above' values are based en the following:

i) Animal uptake of water: 50 liters / day

11) Environmental transfer coefficients:

f C1/ke I U - 3.4 x 10-4

'pC1/ day)

Th - 2.0 x 10-4 Ra - 5.1 x 10-4 iii) Adult meat ingestion rate of 78.3 kg/ year l

l f v) Adult ingestion dose conversion factors (see Regulatory Guide RHf802-4) t l

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Table A-5(b)

Dese Ccnversion Facters fer Human Censumotion of Milk frcm Cairy Ccws Watered en Centaminated Water (Millirem ;:er pCi),

1 Radionuclide Whole Scdy Bene Liver Kidney U-238 2.16 E-04 3.:5 E-03 0.0 8.33 E-04 U-234 2.46 E-C4 3.98 E-03 0.0 9.47 E-C4 Tn-230 2.22 E-06 8.03 E-05 4.56 E-C5 2.20 E-05 Ra-225 2.12 E-02 2.12 E-01 2.54 E-05 7.50 E-04 "The 50-year dose cemit:ent for each year of ingestien of milk.

The abcVe values are based en the felicwing:

1) Cairy animal intake rate: 50 liters / day

11) /dult ingestion silk rate: 130 liters / year iii) Enviremental transfer ccefficients:

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(;;W ca/

U - 6.1 x 10 *,

Tn - 5.0 x 10-6 Ra - 5.9 x 10-4 iv) Adult ingestien dcse conversion facters (see Reg alatcry Guide RH!EC2-4) w

l i

Accendh 3 Federal Register / Vol. u. No.1s4 / Friday. Oc c*ctr 3.1980 / hies and Regulatiens 65535 b pacts of operatom and to cetset potental Cntenoa SA--Culy 5spetScns dtaili:3s incretses er deceases resulting from tus term effects.

or wasta retencen systems sha3 be inCaten. changes = ergineering plans.

Cn enon 6 4C11eg operations sha3 he conducted by a quahSed eng'.:eer or scientst acuvines performed, and any other ccaductad so that an airborne acuent and documented.De appropnate NRC cendstjens afect=g costa.Regardless of releases are reduced to leveis as low as le regional cSce as indicated = Appendix D of whether reclamadon is phased drough the reasonaoiy ac*uevaele. Se pr. mary meesa of to CD Part 20. or the Cinctor. Cf$ce of his of ce operecen or takes place at de end accomp1.siang mas sha3 be by mes'is of Inspecuan and Esfercament. U.S. Nuc!.at cf pperationa. an appregnate portfon of e=s sion coa:rois. Insututional coat sla. such 'Regulatery Co==asaton. Wa sh=gton. D.C.

sunty 3ar.lity stad be retamed untal!!nal.

as e.xtenc;ng Se site boundary and exclusica "" shal be i==edjata!y sc: Sed ci any ce=;iiase w.th the reclamatica plan i.s.

area. may be employed to ensure that cfsste fadure in a ta4=gs or waste niennon system deter.unam Ihas w.3 y eld a surety that is at exposure ti=uts an met.but ecJy after a3 wbcb ruults is a release of talings or waste Inst suScient at a3 cmas to cover $e costs praedcabIe measures have been taken 'o into u=restncted areas, and/cr of any of decc~-"Ma and reclamacon of 2e control em:asiona at $a source.

unusual condadons (condisons not anu dat are expected'to be distureed Notwthstanc.ng the extaience of 5dividual ccatemplated in te design of te nienden before the next license renewal ne term of dose standards. stnct control of emasacas is systam) which if not corrected could indicate ce sursty tnerw= must be open ended.

necessary to assure cat populanon the potential or lead to fauste ci the system unlese it can be demonstrated that another exposures are reduced to the m*""

and neult in a release of ta2it.ss or wesie

e. angement would rovide an equivalent extest reasonably acsaevabia and to avoid into unrutncied anos.

level of assurance.n:a suurance could be site ccata==atica.no greatest potannal provided mth a surety instr.unent weich !a sources cf of. site radiacon exposure (asde II. T:sancal Cdteria

,ngt, go,,,p ejg p,,.od cf m %

Sm rsdon crpesure) are dus: 3 frem dry Cr: tenon S-Nv'al surety ar-angements Sve years) yet wcich =ust be automaccady sefacas of inn tadings disposal ares set shad be estab!!ssed by ea' h =dl cperator renewed unless the sunty otfies ce c

covered by tadings soluton and,e=ussions peor to ce commencament of operations to bensiicary (the Cc==usson er the State frem paowcake drying and pacans=3 assets $at succca f =da wt3 se avadahie reg datory agency) and te priscpal(me eperacoca-to carry out ce ceconta==adon asd I;censee) some nascnable tme (e.g. 90 days)

Oecxa sha3 be made and logged Wurfy of decc==ussionang of de =3 and ste and for pner to be renewas date of test =tescon a2 parameters (e.g.6fere tial pressures and de raclamauen of asy taul:ss or waste not to renew !n such a situation Se surety s= aboer water Cow rates) whics deter==e dispud mu.De moust of hsh to M nquinmed su3 ex.su ud ce 'huan

=e e5:ency of yeJowcase staca e=2saaco end by such s'n'y a. cace u sha3 % would h grd to sm u maw ccacrea eewoment opers:ca. it saa2 be based on Com=ussion.epproved cost replacement sun *y w:ths a bneipenod cf determ.ned woether er not ccacnons an esumates s a Cm:usen-e; proved pian 'er t=e 'o a3ow at ! asst 50 days for me mc:a a ange prescr:bd to ensure cat de (11 dec=nn-m ason and decc==ussiones of res datcry agency to co' ect, J

equ:pment.s operat=3 cassistantly near p ocl elforietture =ust sot be neessary to

eas e5ceccy

cer ecuve accon saaJ be

=11 budcings and the =11=3 site to le,ve:s g

g,,.g 3

M as wnen performance is outsice of m

de as ud Me hu M m Me u as

rescnbed ges.

.ues. control devices recia=4 tion of'aT p and/cr wasta disposal n;iacement sun *y wt As de requirec =e.

sca.J be opesovo at all Omes cunns crytsg 3

,g g

0*"'""

ce2seeied is Secton 1 of tis Appenc:x.ne

nce to sta expiracon. ne cencauces licassee nr.a3 subt

st tha p as.s c:nsac:cs cescr: bed seove wev:d have to be :!eerfy arr. 3 and paczag=g opersoons seaJ m= as environmental apert dat addresses stated en any sure'y 5s:-:=ent wh2cs ;s :ot te== ate wnen controis are inoperenve.

e open-ended, and mest be ag eed to by s2 de exp2c:ed ecv ron=en:al!=;ac'.s of

'Aten caecis indicate de equipment s not -

eger., =g ye,.m te range preecnbed for ang opersuon cec =*---"-* and partes. T=ancal sure*y arrangements gem 2y accepta' ie to be Cettmissen an:

ta% nciamaden, and palusta o

peak eScency, acsons snail be tamen to alternatives for:utgecs desei=;ects.De (a) Surery bonds:

nston parameters to de pnec= bed racge.

sun *y saa2 slao con ce ;ay=e t of 2e Q) Casa deposits:

Wien thzs cannot be done without scutecwn czarp fw long u surninance and c=nd (c)C4 tScates of droomst nquared by Catenon 10. :s estaeLisa:=g (d) Oeposita of gover==e:ft sec:nne; -

and rpaars dry *=4 and packag=g opersoons s

saan :aue as soon as procucacia.

C;ers=oca may not be re-etarted after spec 5c sunty anangmenta. Se '~n=e,s (e):rrevocaole iet ers orlines of credit and cost recmatn s:a2 tame sto accoust total (f) Comosnacons of me above er sucs ocer canacos due to efmer=al perfor=ance unal c:sta that would be incur ed if an types of arrangements as may be approved se,ded corncen accons have been idenc!!ed and i=piemented..sdl suca indepe cant contne:orwm hzred 'o perform by to Conumanson. However, self insurance.

cesucons, ccrrec=ve accoes and re. starts the a---ianaaicems and reciamaton worr.

or any anass= ment wtuch essencaJy shall be reoorted to de appropeare NRC In ortiar to avoid unnecessary dupucanon consctutes soif insurance (e.g. a contract and===eam ce Com=asaco may accept

, with a state w feceral agency), will s 1 reg:ocal o5ce as inc:cated La C.-tenen SA in "na w-al sunces tar have been sacsfy the surtry require =ent since $2s wr:cng, wit::n 10 days of te suceequent conneddated wtth.*.:ascal er sun'y provides no adcitonal assurance otser tan restar.

o control d.:st.4 Sem tani gs. tat ar angements estabush cat wtuca ainady ex:.sts trougn 'jeense por-ym :ot :aved my o am g ;icuads than. nquiremente of ceer r,ed to =eet ecers] or state rica:re=ects.

be wetted or ese=ucady stabd::ed to preve=t age:ces asd/or local gover==g bocies for Caterten to-A + um charge of og,,;:,.',u::a bloweg aan cusc=g to the sucs coccanussicn=g. =ec=stam=s con.

5 :30.000 (19*3 donars) to cover ce c=sts of max:=um extent nosonaoly ac=sevebie. "'his recamacon. and !ccg term site surved!acce long 'er:3 surv= daw = sha2 be paid by esca requinment may be elaxed :f tadings are and control providec aves arrangemes:s ars

=H 0:erator to the general tnesury of de s:Tec=veiy snestand.'rcts wtad, sucn as may c=tsicered acequate to sacsfy taees U.ited States orto an apprepnate State be ce case woen taey are dieposed of bescw reamrements and that te por:rr. :f de agency pnor to the ter. :sacon of a ura=:um grade ano de tailings surface is not exposed surety wtuch covers the cecctr.=2ssion=4

r cortum cu3 !icense.

to wise. Ca=sicersoca shau be stven :n and reciamanen cf ce =dU. sun tadh:ss site If site survedlance or control requirements pianning tadings ciscosal programs to and assocated areas. and be long term at a partcular site are determmed, on de metsoas wmcs wooid adow paased :overms funcing charge is cearfy ideenflee and basis of a site. spec.c evaluanon, to be a

arid reciamauca of tadings :moounc=ents cetrututted fer m in a us==3 taese signi!!cantly gneter tan dose specf ed in smce is wdl seip :n contreding partculate acavsees. The '.icea.see's sunty mechanism Caterten 17 (e.g.if fencng is determ=ed to anc racon e:russions durms opers= ort To wd! be reviewed annua!!y by the Cam =ussion be necessary) vanance is funcmg

entros dus=::g 5m if*use sources. sucs as to assure cet suSce:t *:ncs would be requan=ents may be specfled by de tadings and are pacs w' en automace avadacie for c motecon sf =e recia= acon Cac:=:ssion. In ar:y case, the total :harge to e

controis as not appiy ope-stors small develes pias J ee wors had to be cerfor=ed my an cover ce :osts of;ong erm surve: Hance shah mr.. en ot, erst:3 ;rocecures s:ec *ving de

r.de:encent ::ct acter. S.a a=cust Of surtry be rues cal wtta and assumed ! pe* cent mecces of::::::1 ms:cs w I e ud4 haesty saould be adjusted to rec g 2:s a=y

'an:uai mal sterest rate. Se :03eced fusca

.s F.eferences 0

U.S. Envircnmental Protecticn Agency - Title 40 Code of Federal Regulations Part 190 - Subchapter F "Envircnmental Radiatien Protection Standards for Nuclear Pcwer 0;eratiens" (40 CFR 190).

O U.S. Nuclear Regulatory Cc=nis'sfen'- Regulatcry Guide 4.14, "Radic1cgical Effleent and Environmental Mcnitcring at Uranium Mills" (April 1980).

O U.S. Nuclear Regulatory Ccamission - Regulatory Guide 4.15. " Quality Assurance ?regrams fer Radic1cgical Monitcring Progra=s (Nor=al Operations) -

Effluent Streams and the Environment",(February 1979).

O U.3. Nuclear Regulatory Ccemissicn - Regulatcry Guide RH!202-4, "Calcula-ticnal Mcdels fer Estimating Radiation Ocses to Man frem Air 5cene Radicactive Materials Resulting frcm Uranium Milling Operations" (draft, May 1979).

0 U.S.* Nuclear Regulatcry Ccamissien - Regulatory Guide 1.109, " Calculation of Annual Ccses to Man frca Rcutine Relesses cf Reac:cr Efiluents fcr the Purpcse of Evaluating Ccepliance with 10 CFR Part 50, Appendix I" (Revision 1, October 1957).

U.S. Envirinmental Frc ecticn Agency - Final Envirencental Statement, o

"'O OFR 190 Environmental Radiation Protec:icn Requiremen.ts for Ncrmal Cperaticns cf Activities in the Urnaiam Fuel Cycle," E?A EE0/4-75-015.

(Ncvemcer1975).

U. S. Envircnmental Protection Agency - Part IV - Supplemental Analysis-1975, c

"Envirenrental Analysis of the Uranium.:uel Cycle," EPA 5EC/4-75-C17.

(July 1975).

~

U. S. Nuclear Regulatcry Ccemission "MILCCS Ccmputer Cece User's c

Manual", By G. N. Gnugnoli and D. E. Martin (May 19801 U. S. Nuclear Regulatory Commissten " Final Generte Environmental Impact c

Statement on Uranium Milling", NUREG-0706 (Septemcer 1980).

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