ML20040A736
| ML20040A736 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1981 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20040A735 | List: |
| References | |
| REF-WM-34 NUDOCS 8201220022 | |
| Download: ML20040A736 (62) | |
Text
a' sl G
RADIOLOGICAL ASSESSMENT FOR THE UNI 0tl CARBIDE URAVAN URANIUM MILL
.a URANIUM REC 0VERY LICENSING BRANCH DIVISION OF WASTE MANAGEMENT UNITED STATES NUCLEAR REGULATORY COMMISSION
~
December 1981
',,:u.
i 8201220022 811230
-?
PDR WASTE
~7~~
a-HM-30 PDR i
RADIOLOGICAL ASSESSMENT FOR THE UNION CARBIDE URAVAN URANIUM MILL 1.1 Introduction The purecse of this report is to present the NRC Staff's assessment and methodo' logy which were used to describe the incremental radiological impacts which would result from continued operation of.the Uravan Mill at its present location.
This assessment contains estimates of the annual releases of radio-active materials from the mill and tailings management system the resulting concentrationsattherestrictedareaboundariesfromthemiliandtailings management system, and the dose commitments to nearby individuals and the general population (as defined by NRC, Reference 1) within 80 km (50 miles).
The calculated concentrations and doses are compared to regulatory standards and measured background radiation.
All potential pathways that were con-sidered to contribute a ;ignificant fraction of the dose commitments have been examined.
The results of this radiological assessment are dependent on and sensitive to many input design parameters.
In particular, Grand Junction meteorology was used in the absence of detailed, site specific, meteorology which was not available to NRC at the time this assessment was performed.
However, it is believed that the Grand Junction, Colorado meteorology is reasonable and a comaarison of Grand Junction and San Miguel river valley data indicates that staaility conditions would be similar at both sites (Reference 2). Where actual values have been obtained from environmental monitoring data (Reference 2) these values have been used.
Changes in parameter values used in the estimation of radioactive releases (Table 1.1) would result in different calculated dose commitments.
Therefore, future significant modifications to the facility's design or operation which would affect the assumptions made here concerning effluent releases would require a revised analysis.
1.1.2 Estimated releases The assumptions and data used and the estimates of overall releases of radio-active material froa the mill and the tailings management system are presented in Tables 1.1 and 1.2.
More detailed descriptions of release estimates are provided in Appendices A and B.
A schedule of operation based on 20 years' production of tailings was used in estimating the parameters and releases for the tailings management system.
1.1.3 Exposure pathways 1.1.3.1 Airborne pathways Potential airborne environmental pathways by which people can be ex1osed to radioactivematerialsfromthisprojectareshowninFigure1.1.
T1ese pathways include exposure from inhalation of radioactive materials in the air, from
~
,b r,
- 17.^.
$j m-
p
/
Table 1.1 Principal parameter values used
.4 theg adiological assessment of the Union Carbide Corporation Uravan mill Value*
Parameter f
Average ore grade, % V 038 0.17 Ore concentration of U-238 562.5 Th-230 542.0 pCi/g Ra-226 595.0 Pb-210 617.0 Ore processing rate, MT/ year 432,000 Operaticn schedule, days / year 360 Ore storage pile Actual Area, ha 1.42 2
Annual average dust loss rate, g/m year 269.2 Dust-to-ore activity ratio 2.5 Release rate for truck dumping and other 5.5 x 10 3 ore pad activities, %
Specific radon flux from ore piles, 1.0 2
pCi/m -sec per pCi/g Ra-226 Tailings impoundment system General parameters i
Tailings area activities, pCi/g U-238 83.0
)
Th-230 485.0 Ra-226 573.0 Pb-210 666.0 Annual average dust loss rate, 2692.45 i
g/m year 2
Dust-to-tails activity ratio 2.5 Dusting reduction factor for water cover, moisture, and chemical agents,%
80.0 Specific radon flux from exposed 2
beach, pCi/m -sec per pCi/g Ra-226
- 1. 0, Tsilings areas Pile 1 & 2, ha 23.0 Pile 3, ha
- 9. 3 lj
.4 21??r-
= -2:::U.'J_..
.. _ A rtT M sd rd E w '.mus ~
~4 h3M
x 3
l l
i Table 1.1(continued) i 47-Parameter Value*
i Evaporat' ion ponds and spray areas TOS, g/L 140 Concentrations in discharge to ponds, pCi/L U-238 3459-
.~ Th-230 148300 Ra-226 1004 Pb-210 1004 Concentrations in solids in ponds, pCi/g U-238 24.7 Th-230 1057.4 Ra-226 7.2 Pb-210
- 7. 2 Evaporation pond and spray areas, ha Club Ranch ponds 13.0 Club Mesa spray area 13.0 Emergency ponds 0.5
" Parameter values presented here are those selected by NRC staff after careful review of the applicants submittals.
In instances where available data have been insufficient and/or not specific, reasonably conservative estimates have been made.
l 1
1 9
.%4,
.,J n
on
i-4 1
Table 1.2 Estimated annual releases of radioactivity resulting from the Uravan uranium mill during operations i
'g i
Annual releases of radioactivity (Cur'as/ year)*
Release Source U-238 Th-230 Ra-226 Pb-210 Rn-222**
Ore storage 4.38E-2t 4.22E-2 4.64E-2 4.81E 2.67E+2 Yellowcake stack #
5.36E-1 8.51E-3 3.54E-4 4.00E-3 0.0 Aerofall crushing stacks #
- 4. 93E-2 7.58E-2 3.07E-2 6.42E-2 1.08E+2 AK leach #
4.79E-2 1.94E-1 7.09E-2 3.23E-1 0.0 Leach #
6.26E-4 6.39E-4 2.39E-3 1.56E-3 0.0 l
Fir.; ore storage area #
5.33E-3 8.45E-3 1.64E-2 1.27E-2 0.0 Tailings area pile 1 & 25 2.57E-2 1.51E-1 1.78E-1 2.06E-1 8.34E+2 Tailings area pile 35 1.04E-2 6.06E-2 7.16E-2 8.32E-2_ 3.36E+2 Club Ranch Evaporation Ponds 1.08E-3 4.62E-2 3.14E-4 3.14E-4 5.92E+0 Club Mesa Spray Area 2.16E-2 9.23E-1 6.29E-3 6.29E-3 2.95E+1 Emergency PondsS 4.15E-5 1.78E-3 1.21E-5 1.21E-5 2.20E-1,
" Releases of all other isotopes in'the U-238 decay series are also included in the radiological im)act analysis.
These releases are assumed to be identical to those presented lere for parent isotopes.
For instance, the release rate 1
of U-234 is assumed identical to that for U-238.
Release rates of Pb-210 and Po-210 are assumed equal to that for Ra-226.
- Rn-222 emissions are estimated using the Ra-226 content in the ore or taili.ngs.
i tread as 4.38 x 10 2 or 0.0438.
J
- Particulate emissions of U-238, Th-230, Ra-226 and Pb-210 were measured by the NUS Corporation and reported in NUS-3582 in 1980.
STailings ponds presently reflect an 80% reduction due to water. cover and 2
water or chemical spraying.
Evaporation ponds reflect a 95% reduction, since very little, if any, beach areas are exposed during operation.
During post-operation drying, the reduction factors are assumed to be 0.
8 4
l I
i-
- .2
.w Sn O
L
' In J.J ha
~
?
~
'e ORE FROM MINES 2
y
\\ f H
ORE PAD, FEED o7 $
AND GRINDING
$5 bS 4
h 3, 9
y
% s, g
LEACHING AND INHALATION MAN g
f EXTRACTION RADON AND PARTICULATES S
e AIRDORNE DIRECT EXTERNAL RADIOACTIVITY Z
EXPOSURE MAN ES o
c 0'
] (
V' 9
ON TAILINGS pO g
g p
W STORAG E y
a 0
2 r+
4 O
RADIOACTIVITY 7
d E
IN SOIL q
)f in c:
2 2
/
w gsn.
MILK YELLOWCAKE DRYING Q
I f
_)f CATTLE AND PACKAGING 3
y RADIOACTIVITY INGESTION MAN <
- h. I 'l,]lb,N} ' [
)f VEGETATIO I'.
- 4 IN I I PRODUCT TO 4
BEEF i
MARKET CATTLE x
E C
i 5
,. '0 ' ~ ::l q
g c
i i
~
6 radioactive materials deposited on the ground, and from ingestion of contaminated l
food (i.e., vegetables, meat, and milk).
l l
1.1.3.2 Liquid pathways 1
The potential for contamination of groundwater used as drinking water at the t
Uravan site was not considered to be significant due to the relatively large depth to useable groundwater and the presence of intervening strata.
Domestic water for the town of Uravan is obtained from a well 2 miles East-Southeast of the site and tops an aquifer 150-200 feet below the level of the canyon floor.
l Geologic formations below the tailings disposal site and above the San Miguel River are aquifers of poor quality due to their relatively 1rw permeability' and their topographically high position.
The primary aquifer in the area is the Windgate Sandstone which is located 800 feet below the site.
Impacts associated with contamination of surface water, however, were investi-gated due to the proximity of the Uravan Mill (and associated Club Ranch Ponds) to the San Miguel River.
Results of this investigation, however, indicate that the liquid pathway is not significant compared to other pathways shown on Figure 1.1.
1.1.4 Radiation dose commitments to individuals The nearest known resident is located about 0.18 km (0.1 mile) southeast of the raill.
The nearest known residence in the prevailing wind direction is located about 0.5 km (0.3 miles) northwest of the mill.
The nearest population center is Uravan, Colorado which is located about 0.2 km (0.1 mile) directly east of the mill.
Table 1.3 presents a summary of the individual dose commitments calculated for the most critical locations.
It was assumed that locally produced milk, meat, and vegetables were consumed by the local residents.
The meat was assumed to originate from cattle gra:ing 1.03 km WNW of the mill.
1.1.5 Radiation dose commitments to populations Table 1.4 shows the predicted annual environmental population dose commitments which were calculatrd within 80 km (50 miles) of the site using the Mildos Code (Reference 1).
The estimated annual population dose commitments to the same population from natural background radiation sources is presented in Table 1.4.
Population distribution data (Table 1.5) projected for the year 2000 were used to do the estimation.
This population is projected for what is estimated to be the last year of operation and is based on a density of 3 persons per square mile, except for known population centers.
Population dose commitments resulting from the operation of the Uravan uranium mill represent a fraction of the doses from natural background sources.
Releases of radoh gas yield radiological impacts ranging thousands of miles from a release source.
Impacts of radon releases from the facility which occur within 80 km (50 miles) of the site have been included in the tabulation i
@(*?.
l
~'
m,
~ ~ - -.
w A~
b
7 Table 1.3 Annual dose commitments to individuals in the vicinity of the Uravan uranium mill Dose commitments
- to body organs (mremperyearofexposure)
Exposure Whole Bronchial pathway body Bone Lung epithelium Nearest residence, BLOCK D, 0.18 km SE Inhalation **
11.1 324.0 615.0 82.9 External ground 24.6 24.6 24.6 24.6 External cloud 0.108 0.108 0.108 0.108 Vegetable ingestion 10.3 141.0 10.3 10.3 Meat ingestion #
4.00 57.1 4.00 4.00 Milk ingestion 2.17 24.4 2.17 2.17 Total 52.3 571.0 656.0 124.0 Nearest residence in prevailing wind direction, BLOCK C, 0.50 km NW Inhalation **
9.17 266.0' 512.0 59.3 External ground 21.8 21.8 21.8 21.8 External cloud 0.058 0.058 0.058 0.058 Vegetable ingestion 9.12 124.0 9.12 9.12 Meat ingestion #
4.C3 57.1 4.00 4.00 Milk ingestion 1.92 21.5 1.92 1.92 Total 46.1 490.0 549.0 96.2 Mining camp #2, 1.74 km WSW Inhalation **
4.97 159.0 190.0 94.7 External ground 17.5 17.5 17.5 17.5 External cloud 0.255 0.255 0.255 0.255 Vegetable ingestion 7.23 98.4 7.23 7.23 Meat ingestion #
4.00 57.1 4.00 4.00 Milk ingestion 1.51 16.4 1.51 1.51 Total 35.5 349.0 220.0 125.0
^Uoses are integrated over a 50 year period from one year of exposure
Doses to the bronchial epi those resulting from the inhalation of radon daughters.
l
- Ingestion doses result from the consumption of the meat of.
cattle grazing 1.03 km WNW of the mill.
.sg
],-
l w
<. M -
..a.
n g
8 1
-l 4
Table 1.4 Annual environmental dose commitments (EDCs) to regional population
- within 50-mile radius resulting from the operation of the Uravan uranium mill 100 year EDC (' person rem per year of exposure)**
Exposure Whole Bronchial pathway body Bone Lung epithelium #
Inhalation 2.13 65.4 93.3 36.3 External ground 16.3 16.3 16.3 16.3 External cloud 0.399 0.399 0.399 0.399 Vegetable ingestion 3.34 41.6 3.34 3.34 Meat ingestion 0.112 1.49 0.112 0.112 Milk injestion 0.250 2.62 0.250 0.250 Tota 1 22.5 128.0 114.0 56.7 Estimated population dose 3881.0 4858.0 3908.0 14786.0 from natural backgroundt Ratio of total annual 0.006 0.026 0.029 0.004 regional population dose to that from natural background
- Population is estimated to the last year of operation (2000) based on an approximate density of 3 persons per square mile, (ER p.'2-8)-(Reference 3),
except for known population centers.
- Inhalation doses to the bronchial epithelium are those resulting from the inhalation of radon daughters.
t tBackground doses are based on the regional population size of 26,'404; and Reference 4.
.P
\\
i s
J E;.
s r>
, i.
n;;k
'T' Nhf
'f7' 1
qng a!
p
. sad A y^ ;,.E l
-w I
E,~
4 9
a~
_ Table 1.5 ' Population distribution projected for.the final year of the Uravan uranium mill's operati
)
DEGREES N
NNE NE ENE E
WNb 2/'
KILOMETERS 0.0
?2.5 45.0 67.5 90.0 112.5 135.0 157.5 180.0 202.5 225.0 247.5 270.0 292 1.0- 2.0 1
1 1
1 1
1 1
1 1
1 1
1 1
2.0- 3.0 1
1 1
1 1
1 1
1 1
1 1
1 1
3.0- 4.0 2
2,
.2 2-2 2
2 2
2 2
2 2
2 4.0- 5.0 2
2 2
2 2
2 2
2 2
2 2
2 2
5.0-10.0 li 17 17 17 17 17 17 17 17 17 17 17 17 1
10.0-20.0 69 1050 1025 69 69 69 69 69 69 69 69 69 69 6
I 20.0-30.0 115 115 115 115 115 115 115 115 115 115 115 115 115 11 30.0-40.0 160 160 370 160 160 160 160 160 160 160 160 160 160 16 40.0-50.0 208 208 370 208C' 208 '
208 208 208 208 208 208 208 208 20 fc 50.0-60.0 253 253 253 253 253 253 253 253 253 253 253 253 253 25 60.0-70.0 299 299 299 299 299 299 299 299 299 299 299 299 299 29 4
70.0-80.0 344 344 344 344 344 344 344 344 344 344 344 344 344 34 TOTALS 1471 2452 2799 1471 1471 1471 1471 1471 1471 1471 1471 1471 1471 147 TOTAL 1-80 KM POPULATION IS 26404 PERSONS 1
I
. ~ -...
e.
j i
\\
i-o 5
0 1 2 2 7 9 5 0 8 3 9 4 0 N7 6
1 3
5 J1 6 0 5 9 4 3 t
1 1 2 2 2 3 0 N3 2
0 1 1 2 2 7 9 5 0 8 3 9 4 1 5
1 6 1 6 0 5 9 4 7 M1 1
1 2 2 2 3 4 F 3 1
sn 5
I
- lllllll1 l
1I
10 of the regional ponilation dose commitments (Table 1.4).
Transcontinental radon-222 impacts lave also been evaluated.
Table 1.6 includes total environ-mental dose commitments received by both regional and extraregional popula-tions, as well as a grand total of 100 year environmental dose commitments received by the continental population.
1.1.6 Evaluation of radiological impacts on the public Examination of the estimated doses from milling operations at the Uravan Uranium Project indicate that annual environmental doses to the regional population from this site are a fraction of those from natural background radiation (Table 1.4).
However, a comparison of the dose commitments to individuals at the nearest locations and the nearest location in the pre-vailing wind direction (noted in Section 1.1.4) with the limits specified in the Environmental Protection Agency's 40 CFR 190 (" Radiation Protection Standards for Normal Operations of the Uranium Fuel Cycle" effective December 1980) regulations indicates that both of these locations receive doses which significantly exceed the standard of 25 millirems total dose to any organ of an offsite individual (18 to 25 times the allowable dose).
Table 1.7 compares the 40 CFR Part 190 limits with calculated dose commitments to individuals.
Doses in this table are actually lower than total doses (Table 1.3) because it does not include doses from radon and its daughters.
As indicated in Table 1.7, the estimated radiation dose commitments to the bones and lungs of individuals living at the nearest residence are respectively 21.9 and 25.4 times the EPA limits.
The calculated bone doses result primarily from the inhalation of particulates, and closer examination of releases appears to indicate that these doses are due to isotopes of uranium.
The close proximity (0.2 km) of this residence to mill operations appears to have significantly influenced the cr.lculated doses.
Radiolo Corporation in the vicinity of the mill (gical monitoring performed by the NUS Reference 2) seems to confirm the estimated high doses calculated for the site vicinity.
e l
4 ow SQr.
~
.M
^
':1;.y
.~
skw A
11 I
Table 1.6 Total environmental dose commitments resulting from theUravanuraniummilloperations*(person-rem)
(
h Bronchial
.l.ocation of population Whole body Bone Lung epithelium Within 80 km of the mill 7.354E+02** 3.727E+03 2.704E+03 2.086E+03 Beyond 80 km of the mill 8.737E+02 1.079E+04 8.737E+02 8.737E+02 Total 1.609E+03 1.451E+04 3.578E+03 2'. 959E+03' Fraction of background #
1.932E-06 1.742E-05 4.296E-06 7.106E-07
^Laiculated for the operational and postoperational periods totaling 20 years.
- Read as 7.354 x 102 or 735.4.
- Ratio of total environmental dose commitments resulting from Uravan mill operations to doses from natural background sources which are estimated onthebasisofaNorthAmericancontinentalpopulationprojectedforthe year 2000 at 416 4 million persons, each receiving 100 millrems per year to the whole body, bone, and lung an'd 500 millirems per year to the bronchial epithelium.
B e
ll T[4..
fQ w..-
O*
12 Table 1.7 Annual dose commitments to individuals compared with EPA radiation protection standards 40 CFR 190 Dose commitments (mrem per year of exposure) pathway Whnle body Bone Lung EPA 40 CFR 190 limits
- 25 25 25 Nearest residence, BLOCK D, 0.18 km SE Inhalation 11.1 324.0 615.0 External 2.09 2.09 2.09 Vegetable ingestion 10.3 141.0 10.3 Meat ingestion **
4.00 57.0 4.00 Milk ingestion 2.17 24.4 2.17 Total 29.7 548.0 634.0 fraction of limit 1.19 21.9 25.4 Nearest residence in prevailing wind, BLOCK C, 0.50 km NW Inhalation 9.17 266.0 512.0 External 1.75 1.75 1.75 Vegetable ingestion 9.12 124.0 9.12 Meat ingestion **
4.00 57.0 4.00 Mi'k ingestion 1.92 21.5 1.92 Total 26.0 470.0 529.0 Fraction of limit 1.04 18.8 21.2 Mining camp #2,1.74 km WSW Inhalation 4.97 159.0 190.0 External 0.777 0.777 0.777 Vegetable ingestion 7.23 98.4
~ 7.23 Meat ingestion **
4.00 57.0 4.00 i
Milk ingestion 1.51 16.4 1.51 Total 18.5 332.0 204.0 Fraction of limit 0.74 13.3 8.16 which specifically
^ values trom 40 CFR Part 190,itments arising from excludes doses and dose comm releases of radon and daughters.
- Meat ingestion doses result from the consumption of the meat of cattle grazed 1.03 km WNW of the mill.
u T
j sm Gi; v f
n.
- pt
=p 7
.~
....u
- . e
- ..s a
,s
6 13 l
References
/
1.
U.S. NRC Final Generic Environmental Impact Statement on Uranium Milling.
September 1980.
9 s'
2.
40 CFR 190 Related Radiological Doses due to the Operation of the Uravan Uranium Mill.
NUS-3582.
May 30, 1980 i
3.
EnvironmentalReport,UravanUraniumProject;PreparedbyDamesandMoore for the Union Carbide Corporation.
August'31, 1978.
4.
Descriptions of the United States Uranium Resource Areas.
June 1979.
4
{
1 E
t 1
4 l
i l
6
..j ep y.h
+
ST41,e OM F%
W 4
Ma 4
i
./
9 Appendix A The radiological assessment using the MILDOS computer code does not include impacts from liquid p'athways.
Generally, the liquid pathways to humans are not significant in milling regions; however, the proximity of the San Miguel River to the Uravan mill raises the question of possible seepage into the river and to water wells.
The specific pathways that will be discussed are:
1.
Humans drinking contaminated water.
~
2.
Humans consuming meat from cattle drinking contaminated water.
3.
Humans drinking milk from dairy animals consuming contaminated water.
The concentration levels which are to be considered correspond to three points of interest along the San Miguel River:
upstream, between the mill and the Club Ranch evaporation ponds, and downstream of the mill.
Monitored concentrations Data was collected during 1979 and reported in "The 1979 Annual Summary, Environmental and Health Physics Monitoring, Uravan, Colorado", published by the Union Carbide Corporation Metals Division.
This data is summarized in Table 1.
Dose commitments to individuals by the three liquid pathways above will be based on radionuclide levels listed in Table 1.
Impacts to humans from direct consumption Table 2 presents the dose conversion factors for human consumption of-contaminated water.
Using the concentration levels in Table 1 and the dose conversion factors in Table 2, the human impacts from water consumption at the'various points of the San Miguel River are displayed in Table 3.
Imoact to Humans from Consumption of Meat The calculational model for this pathway is taken from References 1 and 2.
The computation consists of two steps:
1.
The meat concentration is the product of the following:
Animal uptake of liquid (liters /d'ay).
Environmental transfer coefficients _
pCi/kg pC1/ cay Water concentration of the nuclide of interest (pCi/ liter).
A-2' t
Table 1 1979 annual average concentrations of radionu'clides in the San Miguel River (pCi/L) 1 Locat. ion U-Nat Th-230 Ra-226 Upstream 7.0 1 19.0*
3.0 1.0 0.62 1 0.92 Below mill and above 3.0 2.0 0.64 1 0.39 Club Ranch Ponds 8.0 1 10.0,,
Downstream 9.0 1 12.0 8.0 1 15.0 0.65 1 0.20
- The numbers following are the annual sample standard deviations for the monthly samples.
Table 2 Dose conversion factors for human consumption of contaminated water (mrem per pCi/L)*
Radionuclide Whole body Bone Liver Kidney U-Nat**
3.59E-Et 5.93E-1 0.0 1.38E-1 Th-230 2.11E-2 7.62E-1 4.33E-2 2.09E-1 Ra-226 1.70E+0 1.70E+1 2.12E-3 6.03E-2
^The 50 year dose commitment for each 3 ear of ingestion of contaminated water.
The above values are based on an average adult consumption rate of 370 liters / year (Regulatory Guide 1.109) and adult ingestion dose conversion factors (Regulatory Guide RH 802-4).
- 0ose conversion factors for U-238 and U-234 were summed to obtain U-Nat dose factors.
tread as 3.59 x 10 2 or.0359.
S s
b
^
j A-3' f.
1 Table 3 Dose (ommitments to humans from consumption i
i of contaminated water.
(mrem /yearof ingestion) i Location
. Whole body Bone.
Liver Kidney j
Upstream 1.37 17.0 0.131 1.63 Between mill and
{
Club Ranch Ponds 1.44
- 17.9 0.143-1.77 i
Downstream
. 1.60-22.5 0.348 2.95 i
I 2
l 4
l Table 4 Pertinent environmental parameters l
Description Value Reference.
a i
Uptake rate of water 50(cattle)
Ref. 1 j
(liters / day) l Transfer coefficients
!y gested V 3.4 x 10 4 (cattle)
Ref. 1, 2, 3
/
i j
Th 2.0 x 10 4 (cattle)
Ref. 1, 2, 3
).
Ra 5.1 x 10 4 (cattle) huf. 3 i
Pb 7.1 x 10 4 (cattle)
Ref. 3 j.
Adult' Meat Ingestion Rate 78.-3(meat)
Ref. 3 j
kg/yr I
r 1
m.%,
..ww.,
4" e
-p
,-ge
,--~.--,., ~,---
p--
-4,.y e
m y
p
+.
A-4 l
2.
The dose commitment to a given organ is computed as a product of the following:
a Annual rate of meat consumption (kg/yr).
Meat concentration of the nuclide (pCi/kg).
This was computed in D
1 above.
The. dose conversion factor for tile particular nuclide and organ mrem /yr pC) Ingested To permit flexibility, the parameters in Tables 4 and 5 are utilized so as to leave the initial water concentration variable.
Table 6 lists factors which convert water concentration directly to dose.
Using Table 6 and the concen-trations in Table 1, doses to the various organs are computed and listed in Table 7.
Impacts to humans from ingestion of milk from dairy animals consuming contaminated water Table 8 presents the dose conversion factors used to determine the human impacts from the milk ingestion liquid pathway.
The values in the table are prepared so that only the concentrations in the water of the radionuclides need to.be known.
Generic u)take values are used, in lieu of more specific informa-2 tion. The values in Taale 8 are in reality multipliers which take into account the dose conversion factors in Table 6, the assumed annual ingestion rates of the animals and humans and ths environmental transfer coefficients.
Dose commitments to humans are presented in Table 9 for the milk pathways.
Again the impacts are computed for the 3 different points along the San Miguel River.
Summary The total im)act from the l'iquid pathways is presented in Table 10.
These values are tie sum of the dose impacts from Tables 3, 7 and 9.
The impacts of humans drinking water directly are the largest, but it should be noted that the potability of the water from the river may be questionable.
Likewise, the concentrations from wells may not correspond to the concentrations reported for the river.
If the upstream concentrations are taken to represent the background radionuclide content of the San Miguel River, the downstream concentrations contribute no more than 6 mrem to the total impact of the liquid pathway.
o O
A-5' I
f
' I
' Table 5 Adult dose convp!rsion factors for ingestion (Ref. 3) mrem /pCi ingested U-238 U-234 Ra-226 Th-230
'Pb-210 Whole Body 4.54x10 5 5.17x10 5 4.60x10 3 5.70x10 5 5.44x10 4 Bone 7.67x10 4 8.36x10 4 4.60x10 2 2.06x10 3 1.53x10 2 Liver 0.0 0.0 5.74x10 8 1.17x10 4 4.37x10 3 Kidney 1.75x10 4 1.99x10 4 1.63x10 4 5.65x10 4 1.23x10 2 Table 6 Adult dose factor multipliers
"[{*{'
f r ingestion of meat te from cattle consuming contaminated water Beef U-Nat*
Th-230 Ra-226 Whole Body 1.29x10 4 4.46x10 5 9.18x10 3 Bone 2.13x10 3 1.61x10 8 9.18x10 2 Liver 0.0
'9.16x10 s 1.15x10 5 Kidney 4.98x10 4 4.42x10 4 3.25x10 4
- Factors for U-238 and U-234 were summed to obtain the U-Nat multiplier.
o O
W b
n "v'>
-O'-
b S
l A-6' j'
l
(
l Table 7 Annual theinghandosetoadultsresultinion of meat from cattle dr n from contaminated water.
(mremperyearof ingestion).
R Location Whole body Bone Liver Kidney Upstream 0.007
-0.077 0.0003 0.005 Between mill and Club Ranch Ponds 0.007
.0.081 0.0003 0.006 Downstream 0.007 0.092 0.001 0.008 Table 8 Dose conversion factors for human consumption of milk from dairy cows watered on contaminated water mrem
~
pTi7L*
Radionuclide Whole Body Bone Liver Kidney U-Nat 4.62E-04 7.63E-03 0.0 1.78E-03 Th-230 2.22E-06 8.03E-05 4.56E-06 2.20E-05 Ra-226 2.12E-02 2.12E-01 2.64E-05 7.50E-04
^lhe bu year aose ccmmitment for each year of ingestion of j.
milk.
The above values are based on the following:
i) Dairy animal intake rate:
60 liters / day ii) Adult ingestion milk rate:
130 liters / year iii) Environmental transfer coefficients:
P P
U - 6.1 x 10 4 Th - 5.0 x 10 6 Ra - 5. 9. x 10 4
~
iv) Adult ingestion dose conversion factors from Table 5 i
A-7'
/
Table 9 Dose commitments to individuals from the ingestibn of milk from animals drinking water from the San Miguel River.
(mrem / year of ingestion)
Location Whole body Bone Liver Kidney Upstream 0.016 0.185 0.00003 0.013 Between mill and Club Ranch Ponds 0.017
~0.197 0.00003 0.015 Downstream 0.018 0.207 0.0001 0.017 Table 10 Dose commitments from the liquid pathway to humans.
(mrem /yr of ingestion)
Location Whole Body Bone Liver Kidney Upstream 1.39 17.3 0.131 1.65 Between mill and Club Ranch Ponds 1.46 18.2 0.143 1.79 Downstream 1.63 22.8 0.349 2.98 O
II
l l
A-8' l
-j APPENDIX A REFERENCES l
N 1.
U.S. Nuclear Regulatory' Commission Regulatory Guide 1.109, " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for-x the Purpose of Evaluating Compliance with 10 CFR 50", Appendix I, March 1976.
2.
Reference 1, Revision 1, October 1977.
3.
U.S. Nuclear Regulatory Commission Draft Regulatory Guide, " Calculational Models for Estimating Radiation Doses to Man from Airborne Radioactive Materials Resulting from Uranium Milling Operations", Division 3, Task RH-802-4, May 1979.
I e
a b
i l
9
+
4 4-s.,
y A
p---
,,se-i-U
. _,_ _,. -- -., -_____--,- -.- -..~ - - --__ _.--,.,...,--.- _ __,,,
~ ~
o I
&I Appendix B DETAILED RADIOLOGICAL ASSESSMENT e
W 4
M TIM W-g; Rg g]g; g.
^'
a 7/
Appendix B RADIOLOGICAL ASSESSMENT DETAILED,4 This assessment describes the models, data, and assumptions used by the staff to perform its radiological impact assessment of the Union Carbide Corporation's h
Uravan uranium mill.
The primary calculational tool' employed is MILD 05,1 an NRC-modified version of the UDAD (Uranium Dispersion and Dosimetry) computer code originated at Argonne National Laboratory.2 B.1 ANNUAL RADI0 ACTIVE MATERIAL RELEASES Table 1.2 lists estimated annual activity r'eleases for the Uravan Mill.
All data except for the annual average dusting rate for exposed tailings sands are based on the data and assumptions given in Table 1.1 and described elsewhere in Section.1.
This dusting rate is calculated in accordance with the following equation:
7 M = 3.156 10)[)RF (B-1) ss, s
where F = annual average frequency of occurrence of wind speed group s
s, dimensionless; R = dusting rate for tailings sands at the average wind speed for 8
2 wind speed group s for particles <20 pm diam, g/m.s; 2
M = annual dust loss per unit area, g/m. year; 3.156 x 107 = number of seconds per year; 0.5 = fraction of total dust loss constituted by particles <20 pm diam, dimensionless.1 The v'alues of R and F used by the staff are as given in Table B.l.
s s
B-1 s
x
O I
B-2
/
/
/
~
Table B.1 Parameter values for calculation of annual dudtsyg rate for exposed tailings sands
- Wind speed group. Average wind speed Dusting rate Annual frequency of (g/m.s)'
occurrence 2
(knots)
(mph) 0-3 1.5 0
0 4-6 5.5 0-0 7-10 10.0 3.92E-7**
0.14338 11-16 15.5 9.68E-6 0.02179 17-21 21.5 5.71E-5 0.00551
>21 28.0 2.08E-4 0.20228
- Dusting rate as a function of wind speed is computed by the MILD 05 code.1 Wind speed frequencies obtained from annual joint frequency data presented in Table B.2.
- Read as 3.92 x 10'7, or.000000392.
2 The calculated value of the annual dusting rate, M, is 2692.5 g/m. year.
Annual curie releases from the tailings piles are then given by the following relationship:
S = MA(1 - f ) t(C) (2.5 x 10 12),
(g. 2) c where 2
A = assumed beach area of the pile, m ;
f = fraction of dusting rate controlled by mitigating actions, c
dimensionless; f = fraction of ore content of particular nuclide present in the t
tails; S = annual release for the particular beach area, Ci/ year; C = assumed raw ore activity, pCi/g; 2.5 = dust-to-tails activity ratio; 10 12 = Ci/pCi.
There are two main tailings disposal areas at the Uravan site.
The largest one is approximately 23 hectares and is composed of the old tailings piles and an active tailings disposal area.
The smaller impoundment is 9.3 hectares of tailings and is actively being used for disposal of tailings.
The NRC staff has assumed a dusting loss reduction factor of 80% or better for water cover, moisture and other mitigation procedures.
Should the moisture levels in the solids not be sufficient
B-3
~
l r
DE s
a stu 6 set mC tsC g
-s C sgt 2
35 Sv vgv w
wav p
use 7;taL?
$7ASILTif Cb&SS 1.6
.CSee 039e 0890 037C
.C3SC
.06AC 0790.334c 143C 093t
.1095
.33th.3070 3530 093C 0360 1.3390 5.S
.C23e.elet 034C 0360 0336.025C 0430 091t
.07tC 069e 0f0C 0640 0920.326C.tS9C
.0230
.536C 10.0 0.000t C 0Poe C.0000 C.ecet C.C000 0.0000 C.006C C.0000 C.0000 C.000C C.0000 C.9000 C.00PO C.000e 3.0090 C.De00 0.0000 15.! t.e000 C.00ne C.000C t. 0000 C.0000 0.000C C.000C t.0000 C.0000 C.0000 C.000C C.000? 9.0000 0.000C C.e000 C.etDe 0.0000 11.5 C.t000 0.0000 C.0000 t.0cet C.0000 C.0000 C.000C 9.000C 0.000t C.0000 C.000C C.000C C.0000-C.Or00 C.e000 C.De00 C.9002-18.* C.0009 C.80ne.C.0000 C.0000 0.0000 C.pn00 C.0cte t.0000
.2330 1410.3410
.3350
.3640 3430 3790 419e 2.C310 4;,
.C13t
.t330 063t.cS3t
.e860 0390.2270 7050 4500 3eit
.330t
.3500
.3530 6S00.5330.576t 4.391t
$7a91L7?? Clasp 7 2.5
.52*f 3Cie.3500 3400 3000 6950 4290.772c
.112C.Delt.tS00
.0322 0690 2240.3970 45a0 4.6890 S.5 4410
.3690
.3940
.211e 7900.523e.3240 3640
.C210 014C 4034C
.0110 0130 0900.3t50.21SC 2.9970
,SC.C
.1620 0**C
.3030
.176C
.2330 4250.2n3C 064C C,0000 0,000t C.9000 C.0000 C.0000 C.0000 0.000t C.epec 1.382e 15.5 C.e000 0.cner C.000C t.000e C.000C C.0000 C.eceC C.0000 C.0000 C.0000 C.0000 C.000C C.0000 C.000t 0.00tc C.0000 0.00cc 21.5 0.0000 C.000C C.00CC C.coet C.fD?C C.0?00 t.00C0 C.0000 C.0000 C.0000 C.0f 0C C.0000 C.0000 C.000C t.000e t.0000 0.0000 15.0
.113P 073e 049C.e930
.3390
.3t2C.22SC
.196C
.St?C 0600 679C
.C?to.3450 3ett 2030.323C 2.744c ALL 1.245e 634t 715e 7tte 1.C290 1.t350 1.1910 6tst 3730.1230
.343C
.122C.2750 6310 7tSD 1920 11.213e 3789187?? C1433 3 1.5
.1190 0690 04aC.C21e.01Sc 4000 611e.stot.3060.1300 1250.1560.2900.616c 4430.2740 4.314e S.S
.176%
.t13e
.0620 066t 0490
.S990 1.7040 902t 4140.12tt 9960
.1510 4060 1.c3ac 653C.2560 4.2 ESC St.t 0130.eeSe C.000C
.c0tt
.CC70
.039C.tT3C 066C
.CS9C 0t90 0730.0430 0C70.233c.326C
.e#60
.e30s 1S.S C.eMSc.et?t 0C7f C.0000 C.00ne C.0PeC 005e 0050
.tl60 0340.t230 9.0000
.0090
,C23e. Clot
.tM1C
.1200 11.S t.0000 C.Dene C.De00 C.09te 0.000C C.0006 005t t.0000 9098 016C.t110 C.0000 C.0000 C.000e 002C C.0000 0430 16.0
.3100
.079C
.1190
.3450
.1950
.264C
.1950.3410 3530 094c.3030 0990.3130.3040 2230
.3430 2.5340 ALL
.3140
.20*C
.2330
.2400
.3250 1.2920 2.a930 1.7000 1.0570 4340 4390 446C 96aC 1.710t 1.463 0.6160 34.206c S7891LITY CLASS 4 1.5 2**C
.iten
-1230
.2000 215C
.St?C 5530.36te 1490 07Se
.3000
.1300 2810 7380 6660.3n6e 4.tStr S.S
.S?'t.
.3a?C
.2770.26te
.314C 2.47Se 1.7540 7950 463C
.169C 41970.3350.2850 1.1290 1.C2Pe '.473 0 3C.715e 3C.0
.39?*
.703?
.274C.771t
.2650 3.1650 1.69ec
- 400 5000.2t90 3400 2300 4106 1.128e
- 960
.5590 12.0250 16.5 043e.C30c 0670.e460
.C2SC
.3066
.2110.3670
.3ame.132e 41370 0490
.3430
.2330 3640.0370 2.0590 21.5.0130
. C3 ' ?
.t*90
.Cete.022C 0360 0340 0320 0670
.S830
.tS00 0210 043e 0660.c660.0300
.Sete 26.C t,000t C.00et C.Dee0 t.00tt C.000C C.0000 0.000e C.00PO 0.0000 C.cn00 0.'teet t.0000 C.9000 C.000e C.000e 0.0000 C. cept ALL 1.764C 4030.tS3e 1440 49tle 1.1520 4.7400 2.09%D 1.5370 7C50 vt14C.665C 2.1730 3.3740 2.C200 1.4530 3C.22+e
- 17A91L17f Cb438 $
1.5 3490 2150 3200.St?C 5530 1.3200.6930 v3130
.3 t10 010e v3C30.1260.1670 4270 4130.3150 4.3460 S.S 319e.203C
.2640
.2stt 413t 3.9320 1.0170
."359e
.3360 0790 4460
.0390 0190. 2tSC 4360.34Se 6.343r 3C.0 C.tcen C.00nD C.e000 C.000C C.000; C.0000 0.000C t.9000 0.000C C.000t C.c000 -0.0000 %0000 C,0000 C.0000 0.0n00 0.0000 15.S t.00e# t.Op00 C.DePC C.000e C.0000 C.0000 0.e000 C.0000 C.000e C.0000 0.9000'C.0000 C.000C t.0000 C.0000 C.0000 0.0000 73.3 c.0*?C t.000C C.0a00 C.00er C 0000 C.000* C.eeft t.T000 C.000e C.000e C.0000 C.0000 C.0000 C.000f t 000e C.0000 9.000t 25.t
.e33C 47%e.473 0 1.6750 1.+st e 2.287e 1.S660
.+tSO 5640 7610 1930.7eSO.4120 9760 6470 4100 13.433e ALL 1.3610 9930 1.3*SO 2.4 560 2.6See 1.5 34C 4.7610 1.2560
.s660
.3180 4420 4500 651C 1.5330 1.4 560 1.070h 24.772C
'57&2ILT*7 C3.1SS 4 1.5
.aste.30ac 46aC 1.3 59 a 1.13 0 0 2.973C 2.171C 57h0
.'2?to 090e.5000
.c700.tist 460C-4300.3900 11.39:0 4.5 C.000t t.0000 0.0e00 C.000e C.0000 C.000t C.0000 C.0000 t.000C C.0000 C.0000 C.0000 C.0000 C.0000 0.0000 -0.0000 0.0000 n.Da00 0.000e C.0APO 0.0000 C.0000 0.0000 C.0000 0.0e00 0.0na0 0.0000 C.0000 t.0000 t.0000 0.0000 C.0000,C.0000 0.0000 10.C 0.0000 35.5 t.000t C.Dono C.e000 0.000e C.0000 0.0000 c.0000 C.Once C.teet C.00po C.0000 0.0000 0.ee02 C.0000 0.0000 C.0000 11.5 t.0000 t.ve00 C. Opec 0.000^ C. ceco C.0ece C.e000 e.e000 0.0000 0.000a t.0000 0.000e 0.000e 0.0000 0.0000 0.0000 t,00cc
'24.0 C.0000 C.0000 0.0e00 0.00eo 0.0000 0.0000 C.e000 f.0000 0.0000 t.000t C.000C C.000t C.000C C.0000 t.0000 0.000C C,0cet 4LL 4990. 3 04 C 4 6J O 1. 3 S M 1.13 00 2 9730.2.123t
.57't
.27tc 080e.3000
.ttte,1140 4500 4t00 3e00 31.39 e 100.0060 S.. m 4.06SC20.t n C a.0 m. 420e
.c o 2. m e 2.2600 2.03 0 3.S4,75.9500,. m e S. m 0 c.
4... 0 2.45,C 2.51 0 Table B.2 Joint relative wind frequency data from Grand Junction, Colorado J
B,
l to reduce dusting to this level, then the estimates presented in the dose assessment portion of this docuyent could be significantly higher.
The activities of U-238, Th-230, Pb-210 and Ra-226 in_the tailings solids were measured and documented by the NUS Corporation for the Uravan mill.3 These activities are 83 pCi/g, 485.0 pCi/g, 573.0 pCi/g and 666.0 pCi/g for U-238, Th-230, Ra-226 and Pb-210, respectively.
These activities were assumed to be representative of all solid tailings disposal areas.
~
In addition to the tailings impoundments, the Uravan mill site has approximately 30 hectares of evaporation ponds or spray areas.
These areas are designed to accelerate the evaporation of the liquid waste from the mill.
Activities of the solids which are suspended in the liquids are estimated to be:
24.7 pCi/g, 1057.4 pCi/g, 7.2 pCi/g, and 7.2 pCi/g for U-238, Th-230, Ra-226 and Pb-210.
The reduction factor for the evaporation ponds is assumed to be approximately 95%, since no more than 5% of beach would be exposed during operation.
How-ever, the spray areas are assumed to have 0% reduction of dusting, since the solids would " plate.out" upon shallow evaporation.
Dust losses from the ore storage piles were estimated by assuming that they would be about 10% of those from an equivalent area of tailings beach.
B.2 ATMOSPHERIC TRANSPORT The staff analysis of offsite air concentrations of radioactive materials has been based on four years of meteorological data collected at the Grand Junction, Colorado, site during the period 1960 through 1964.3 The collected meteoro-logical data are entered into the MILDOS code as input in the form of a joint frequency distribution by stability class, wind speed group, and direction.
The joint frequency data employed by the staff for this analysis are presented in Table B.2.
The dispersion model employed by the MILD 05 code is the basic straight-line Gaussian plume model. Ground-level, sector-average concentrations are computed using this model and are corrected for decay and ingrowth in transit (for radon-222 and daughters) and for depletion caused by deposition losses (for particulate matter).
Area sources are treated using a virtual point source technique.
Resuspension into the air of particulate material initially deposited on ground surfaces is computed using a resuspension factor that depends on the age of the deposited material and its particle size.1 For the isotopes of concern here, the total air concentration including resuspension is about 1.6 times the ordinary air concentration.
The assumed particle size distribution, particle density, and deposition velocities for each source are presented in Table B.3.
9 6
o O
A
~
J e
d B-5_
/
Table B.3 Physical chavatteristics assumed for particulate material releases Deposition 1
Diameter Density Velocity AMAD*
Activity source (pm)
(g/cm )
(cm/s)
(pm) 3 Crusher dusts 1.0 2.4 1.0 1.55 Yellow cake dusts 1.0 8.9 1.0 2.98 Tailings, ore pile dusts 30%
5.0 2.4 1.0 7.75 70%
35.0
~ 2.4 8.8 54.2 Ingrown radon daughters 0.3 1.0 0.3 0.3
- Aerodynamic equivalent diameter, used in calculating inhalation doses.1 B.3 CONCENTRATION IN ENVIRONMENTAL MEDIA Information provided below describes the methods and data used by the staff to determine the concentrations of radioactive materials in the environmental media of concern in the vicinity of the site.
These include concentrations in the air (for inhalation and direct external exposure), on the ground (for direct external exposure), and in meat and vegetables (for ingestion exposure).
Concentration values are computed explicitly by the MILDOS code for U-238, 4
3 Th-230, Ra-226, Rn-222 (air only), and Pb-210.
Concentrations of Th-234, Pa-234, and U-234 are assumed to equal that of U-238.
Concentrations of Bi-213 and Po-210 are assumed to equal that of Pb-210.
i B.3.1 Air concentrations 7
Ordinary, direct air concen,trations are computed by the MILDOS code for each receptor location from each activity source by particle size (for particulates).
Direct air concentrations computed by MILDOS include depletion by deposition (particulates) or the effects of ingrowth and decay in transit (radon and daughters).
To compute inhalation doses, the total air concentration of each isotope at each location, as a function of particle size, is computed as the sum of the direct air concentration and the resuspended air concentration:
C,9p(t) = Caipd + Caip r,(t),
(B-3) where C. (t) =. total air concentration of isotope i, particle size p, at. time alp 3
t, pCi/m ;
C
= direct air concentration of isotope i, particle size p, for aipd 3
the time constant, pCi/m ;
9
B-6 j
Caipr(t) = resuspended air concentration of isotope i, particle size p, 3
at time t, pCi/m.
The resuspended air concentration is computed using a time-dependent resuspen--
sion factor, R (t), defined by p
R (t) = (1/V )l0~5
~A t e R for t 5 1.82 year.
p p
~
= (1/V )l0 9 for t > 1.83 year,
(B-4) p where R (t) = ratio of the resuspended air concentration to the ground concen-P tration, for a ground concentration of age t years, of particle size p, m 2; V = deposition velocity of particle size p, cm/s; p
I A = assumed decay constant of the resuspension factor (equivalent to R
a 50-d half-life), 5.06 years;
~
10 5 = initial value of the resuspension_ factor (for particles with a deposition velocity of 1 cm/s), m 1;
~
'10 8 = terminal value of the resuspension factor (for particles with a deposition velocit9 of I cm/s), m 1; 1.82 = time required to reach the terminal resuspension factor, years.
The basic formulation of the above expression for the resuspension factor, the l
initial and final values, and the assigned decay constant derive from experi-mental observations.4 The inverse relationship to deposition velocity eliminates mass balance problems involving resuspension.of more than 100% of the initial ground deposition for the 35 pm particle size (see Table B.3).
Based on this formulation; the resuspended. air concentration is given by i l - exp[-(A * + A ) (t - a)]
g R
0.01 C x 10 5 aip(t) =
aipd (3,*A)
C 5
R exp[-A*(t-a)]-exp(-A*t))
g
+ 10 46(t)
(3.1.56 x 107),
(B-5) 3,,
I where x = (t - 1.82) if t i 1.82, years; 6(t) = 0 if t < l.82 and is unity otherwise, dimensionless; 4
a
B-7
.- a i
Ay=effectivedecaycons'tantforisotopeionsoil, year 1;
~
0.01 = deposition velocity for the particle size for which the initial resufpension factor value is 10 5 per meter, m/s; 3.156 x 107 = s/ year.
3 s
Total air concentrations are computed using Eqs. B-3 and B-5 for all particulate effluents.
Radon daughters that grow in from released radon are not depleted
~
because of deposition losses and are therefore not assumed to resuspend.
B.3.2 Ground concentrations Radionuclide ground concentration:; are computed from the calculated airborne particulate concentrations arising directly from onsite sources (not including air concentrations resulting from resuspension).
Resuspended particulate concentrations are not considered for evaluating ground concentrations.
The direct deposition rate of radionuclide i is calculated, using the following relationship:
D.=bC
.V (B-6) di p adip p, where C
= direct' air concentration of radionuclide i, particle size p,
~
adip 3
pCi/m ;
2 di = resulting direct deposition rate of radionuclide i, pCi/m.s; D
V = deposition velocity of particle size p, m/s (see ref. 4).
p The concentration of radionuclide i on a ground surface resulting from constant deposition at the rate D ver time interval t is obtained from di 1 - exp[-Ai + Ae)t)
(B-7)
C ;(t) = Ddi g
g,.
g 1
e where 1
2 g (t)'= ground surft.ce concentration 'of radionuclide i at time t, pCi/m ;
C g
t = time interval over which deposition has occurred, s; I
-1; A, = assumed rate constant for environmental loss, s
~
i A. = radicartive decay constant 5 for radionuclide i, s 1 1
il N
1
. l
B-8 o
i
/
The environmental loss constant Ae corresponds to an assumed half-time for loss of environmental availability of 50 years.4 This parameter accounts for downward migration in soil and loss of availability caused by chemical binding.
It is assumed to apply to all rf3ionuclides deposited on the ground, s
Ground concentrations are explicitly computed only for U-238, Th-230, Ra-226, and Pb-210.
For all other radionuclides, the ground concentration is assumed equal to that.of the first parent radionuclide for which the ground concentration is explicitly calculated.
For lead-210, ingrowth from deposited radium-226 can be significant.
The concentration of lead-210 on the ground caused by radium-226 deposition is calculated by the staff, using the standard Bateman formulation and assuming that radium-226 decays directly to lead-210.
If.
i = 6 for radium-226 and i = 12 for lead-210 (ref. 1), the following equation is obtained:
1-expFAj2)+exp(-Agt)-exp(-A$2)
D t
t 2 d6 g12(Pb:
Ra) =
(B-8)
C A
A$2 A - $2 6
6 where 9 2(Pb:
Ra) = incremental lead-210 ground concentration resulting from C
1 2
radium-226 deposition, pCi/m ;
A* = effective rate constant for loss by radioactive decay and
' migration of a ground-deposited radionuclide and is equal to A
- A,s(
n e
B.3.3 Veoetation concentrations Vegetation concentrations are derived from ground concentrations and total deposition rates.
Total deposition rates are given by the following summation:
D;=[CgV, (B-9) a p
p where D is the total deposition rate, including deposition of resuspended 4
2 activity, of radionuclide i, pCi/m.s.
Concentrations of released particulate materials can be environmentally transferred to the edible portions of vegetables or to hay or pasture grass consumed by animals by two mechanisms - direct foliar retention and root uptake.
Five categories of vegetation are treated by the staff:
edible aboveground vegetables, potatoes, other edible belowground vegetables, pasture grass, and hay.
Vegetation concentrations are computed using the following equation:
1 - exp(-A t )
~
Cyg=DEE$ry g$(Byg/P),
(B-10)
+C YA yg
'b g
a b
9
~
B-9 where W
B soil-to plant transfer factor for isotope i, vegetation type v, yg = dimensionless; S.
C
=
yj resulting concentration of isotope i, in vegetation v, pCi/kg; E = fraction of foliar deposition reaching edible portions of y
vegetation v, dimensionless; F = fraction of total deposition retained on plant surfaces, 0.2, r
dimensionless; P = assumed areal soil density for surface mixing, 240 kg/m ;
2 t = assumed duration of exposure while growing for vegetation v, s; y
Y = assumed yield density of vegetation v, kg/m ;
2 y
A = decay constant accounting for weathering losses (equivalent to a 14-d half-life), 5.73 x 10 7 per second.
The value of Ev is assumed to be 1.0 for all aboveground vegetation and 0.1 for all below ground vegetables.8 The value of t is taken to be 60 days, exceptforpasturegrass,whereavalueof30daylisassumed. The yield den-2 sity, Y is taken to be 2.0 kg/m, except for pasture grass, where a value of 0.75kg/m,2 is applied.
Values of the soil to plant transfer coefficients, B".,
are provided in Table B.4.
l Table B.4 Environmental transfer coefficients i
Material U
Th Ra Pb Plant / soil, B EdibleabovEhound 2.5E-3*
- 4. 2E-3 1.4E-2 4.0E-3 Potatoes 2.5E-3 4.2E-3 3.0E-3 4.0E-3 Other belowground 2.5E-3
- 4. 2 E-3 1.4E-2 4.0E-3 Pasture grass 2.5E-3 4.2E-3 1.8E-2 2.8E-2 Stored feed (hay)
?.5E-3 4.2E-3 8.2E-2 3.6E-2 Beef / feed, F 3.4E-4 2.0E-4 5.lE-4 7.lE-4 pCi/kgperhCi/ day b,
Milk / feed, Fmi, 6.1E-4 5.0E-6 5.9E-4 1.2E-4
- Read as 2.5 x 10 3, or.0025 Source:
U.S. Nuclear Regulatory Commission, Calculational Models for i
Estirhating Radiation Doses to Man from Airborne Radioactive Materials Resulting from Uranium Operations, Report Task RH 802-4, Washington, D.C., May 1979.
'l
~
/
o B-10 i
B.3.4 Meat and milk concentrations C
Radioactive materials can be deposited on grasses, hay, or silage, which is eaten by meat animals, which are, in turn, eaten by man.
It has been assumed that meat animals obtain their entire feed requirement by grazing nine months per year and consuming non-local stored hay for the remaining feed requirement.
The equation used to estimate. neat concentrations is Cbi = QFbi(0.75 Cpg $ + 0.0 Chi),
( -11) where Cpg$ = concentration of isotope i in pasture grass, pCi/kg; Chi = concentration of isotope i in hay (or other stored feed), pCi/kg; Cbi = resulting concentration of isotope i in meat, pCi/kg; Fbi = (feed-to-meat transfer factor for isotope i, pCi/kg per pCi/d see Table B.4);
Q = assumed feed ingestion rate, 50 kg/d; 0.75 = fraction of total annual feed requirement assumed to be satisfied-by pasture grass; 0.0 = fraction of the total annual feed requirement assumed to be satisfied by locally grown stored feed (hay).
The above grazing assumptions are also reflected in the following equation for milk -concentrations:
C,$ = QF,$(0.75 Cpg $ + 0.00 Chi),
(B-12) where C,$ = average concentration of isotope i in milk, pCi/L; F,g = feed-to milk activity transfer factor for isotope i, pCi/L per pCi/ day ingested (see Table B.4).
B.4 DOSES T'O INDIVIDUALS Doses to individuals have been calculated for inhalation; external exposure to air and ground concentrations; and ingestion of vegetables, meat, and milk.
Internal doses are calculated by the staff, using dose conversion factors that yield the 50 year dose commitment, that is, the entire dose insult received over a period of 50 years following either inhalation or ingestion.
Annual doses given are the 50 year dose commitments resulting from the one year exposure period when environmental concentrations resulting from plant operations are expected tc be near their highest level.
o s,
.+
B-11 b
E B.4.1 Inhalation doses
,/
/
Inhalation doses have been computed using air concentrations obtained by Eq. B-3 (resuspended air concentrations are included) for particulate materials and the dose conversitn factors presented in Table B.5.2 7 Dose to the bronchial epithelium from radon-222 and short-lived daughters were N.
computed based on the assumption of indoor exposure at 100% occupancy.
The dose conversion factor for bronchial epithelium exposure from radon-222 derives as follows:
1.
1 pCi/m3 radon-222 = 5 x 10 8 working levels (WL).*
2.
Continuous exposure to 1 WL = 25 cumulative working level months (WLM) per year.
3.
1 WLM = 5000 mrem.8 Therefore, E
radon-222) x 5 x 10 8 x
25 x 5000 millirems,
~
(1 pCi/m3 I
pCi/m3 WL Wili
~
0.625 millirems,
~
and the radon-222 bronchial epithelium dose conversion factor is taken to be 0.625 millirems per year per pCi/m.
3 1.4.2 External doses j
External doses from air and ground concentrations are computed using.tfie dose conversion factors provided in Table B. 6.
Doses are computed based on 100%
occupancy at the particular location.
Indoor exposure is assumed to occur 14 -
hours / day at a dose rate of 70% of the outdoor dose rate.
B.4.3 Inoestion doses Ingestion doses are computed for vegetab'les and meat (beef and lamb) on the basis of concentrations obtained using Eqs. B-9-B-12, ingestion ~ rates given in Table B.7, and dose conversion factors 8 given in Table B.8.
Vegetable ingestion doses were computed assuming an average 50% activity reduction caused by food preparation.1 Ingestion doses to children and teenagers were computed but were found to be equal to or less t.han doses to adults.
"One WL concentration is defined as any combination of short-lived radioactive decay products on radon-222 in 1 L of air that will release 1.3 x 105 MeV of alpha particle energy during radioactive decay to lead-210.
= #e
B-12
/
Table B.5 Inhalatiop dose conversion factors.
Values are given 'in millirems per year per pCi/m3 Organ U-238
.U-234 U-230 Ra-226 Pb-210 Po-210 Particle size = 0.3 pm a
Whole body 7.46E+0 1.29E+0 8one 2.32E+2 5.24E+0 Kidney 1.93E+2 3.87E+1 Liver 5.91E+1 1.15E+1 Mass average lung 6.27E+1 2.66E+2 j
Particle size = 1.0 pm Whole body 9.82E+0 1.12E+1 1.37E+2 3.58E+1 4.66E+0 5.95E-1 i
Bone 1.66E+2 1.81E+2 4.90E+3 3.58E+2 1.45E+2 2.43E+0 Kidney 3.78E+1 4.30E+1 1.37E+3 1.26E+0 1.21E+2 1.79E+1 Liver 0.
O.
2.82E+2 4.47E-2 3.69E+1 5.34E+0 Mass average lung 1.07E+3 1.21E+3 2.37E+3 4.88E+3 5.69E+2 3.13E+2 Particle size = 1.0 pm Whole body 4.32E+0 4.92E+0 1.66E+2 3.09E+1 4.36E+0 4.71E-1 Bone 7.92E+1 7.95E+1 5.95E+3 3.09E+2 1.35E+2 1.92E+0 Kidney 1.66E+1 1.89E+1 1.67E+3 1.09E+0 1.13E+2 1.42E+1 Liver 0.
O.
3.43E+2 3.87E-2 3.45E+1 4.22E+0 Mass average lung 1.58E+2 1.80E+2 3.22E+3 6.61E+3 7.72E+3 4.20E+2 Particle size = 5.0 pm Whole body 1.16E+0 1.32E+0 1.01E+2 4.00E+1 4.84E+0 7.10E-1 Bone 1.96E+1 2.14E+1 3.60E+3 4.00E+2 1.50E+2 2.89E+0 Kidney 4.47E+0 5.10E+0 1.00E+3 1.41E+0 1.25E+2 2.13E+1 Liver 0.
O.
2.07E+2 4.97E-2 3.83E+1 6.36E+0 Mass average lung 1.24E+3 1.42E+3 1.38E+3 2.84E+3 3.30E+2 1.88E+2 Particle size = 35.0 pm Whole body 7.92E-1 9.02E-1 5.77E+1 3.90E+1 4.43E+0 7.28E-1 Bone 1.34E+1 1.46E+1 2.07E+3 3.90E+2 1.38E+2 2.96E+0 Kidney 3.05E+0 3.47E+0 5.73E+2 1.38E+0 1.15E+2 2.19E+1 Liver 0.
O.
1;19E+2 4.85E-2 3.51E+1 6.52E+0 Mass average lung 3.33E+2 3.80E+2 3.71E+2 7.64E+2 8.70E+1 5.75E+1 a
Read as 7.46 x 10, or 7.46.
Sources:
M. Momeni et al., Uranium Dispersion and Dosimetry (UDAD) Code, Report ANL/ES-72, NUREG/CR-0553, Argonne National Laboratory, Chicago, May 1979 and D. R. Kalkwarf, Solubility Classification of Airborne Products from Uranium Ores and Tailings Piles, Report PNL-2830, NUREG/CR-0530, Pacific Northwest Laboratory, Richland, Wash., January 1979.
t
. o,
B-13
?,
1 3
Table B.6 Dose conversion factors'for external exposure 3
FQ Whole b'ody Isotope Skin
~
s
(
For air concentration doses, 3
millirems per year per pCi/m U-238 1.05E-5*
1.'57E-6 Th-234 6.63E-5 5.24E-5 Pa(m)-234 8.57E-5 6.64E-5 U-234 1.36E-5
'2.49E-6 Th-230 1.29E-9 3.59E-6 Ra-226 6.00E-5 4.90E-5 Rn-222 3.46E-0 2.83E-6 Po-218 8.18E-7 6.34E-7 Pb-214 2.06E-3 1.67E-3 Bi-214 1.36E-2 1.16E-2 Po-214 9.89E-7
~7.66E-7 Pb-210 4.17E-5 1.43E-3 s
For around concentration doses, 2
millirems per year pe,r pCi/m U-238 2.13E-6 3.17E-7 Th-234 2.10E-6 1.66E-6 Pa(m)-234 1.60E-6 1.24E-6 U-234 2.60E-6 4.78E-7 Th-230 2.20E-6 6.12E-7 i
Ra-226 17.16E-6 9.47E-7 Rn-222 6.15E-8 5.03E-8 Po-218 1.42E-8 1.10E-8 Pb-214 3.89E-5 3.16E-5 Bi-214 2.18E-4 1.85E-4 Po-214
- 1. 72E-8 1.33E-8 Pb-210 6.65E-6 2.27E-6
- Read as 1.05 x 10 6, or.0000105.
Source:
U.S. Nuclear Regulatory Commission, Calculational Models for Estimating Radiation Doses to Man from Airborne Radioactive Materials Resulting from Uranium Milling Operations, Report Task RH 802-4, Washington, D.C., May 1979.
+
Av
'f.,.
- 2$
'~-1C mm
,. ?
N/
f r$;,. b E:
i s- --
as'
-. 4 w.
., s,;
~
s j\\
..i e y
B-14 s
Table B.7 Assumed food ingestion rates *
).
(
Infant Child Teen Adult Vegetables, kg/ year 48 76 105
, I Edible aboveground 17-29 40 Potatoes 27 42 60 0'
lowground 3.4 5.0 5.0
^
Meat (beef, fresh pork, 28 45 78 and lamb)', kg/ year Milk, L/ year 208 208 246 130
- Ingestion rates are averages for typical rural farm households.
No allowance is credited for portions of year when locally or homegrown food may not be available.
J.F.FletcherandW.L.Dotson, HERMES-ADigitAl Source:
Computer Code for Estimating Regional Radiological Effects from the Nuclear Power Industry, Report i
HEDL-TME-71-168, Hanford Engineering Development i
Laboratory, Hanford, Wash., December 1971.
i i
1 4
i I
1 I
l I *
?
lYh.
'}l ii
'A; t
k,
- h J
- r, "'
)
..;i -,
w,.
.w
B-15
~ ~ ~ ~
~
Table B.8 Ingestion dose conversion factors.
Values are in millirem /pCi ingested.
Isotope Age group Organ' U-238 U-234 Th-234 Th-230 Ra-226 Pb-210 Infant Whole body 3.33E-4 3.80E-4 2.00E-8.
1.06E-4 1.07E-2 2.38E-3 Bone 4.47E-3 4.88E-3 6.92E-7.
3.80E-3 9.44E-2 5.28E-2 Liver 0.
0.
3.77E-8 1.90E-4 4.76E-5 1.42E-2 Kidney 9.28E-4 1.06E-3 1.39E-7 9.12E-4 8.72E-4 4.33E-2 Child Whole body 1.94E-4 2.21E-4 9.88E-9 9.91E-5 9.87E-3 2.09E-3 Bone 3.27E-3 3.57E-3 3.42E-7 3.55E-3 8.76E-2 4.75E-2 Liver 0.
0.
1.51E-8 1.78E-4 1.84E-5 1.22E-2 Kidney 5.24E-4
'5.98E-4 8.01E-8 8.67E-8 4.88E-4 3.67E-2 Teenager Whoie body 6.49E-5 7.39E-5 3.31E-9 6.00E-5 5.00E-3 7.01E-4 Bone 1.09E-3 1.19E-3 1.14E-7 2.16E-3 4.09E-2 1.81E-2 Liver 0.
6' O.
6.68E-9 1.23E-4 8.13E-6 5.44E-3 Kidney 2.50E-4 2.85E-4 3.81E-8 S.99E-4 2.32E-4 1.72E-2 Adult Whole body 4.54E-5 5.17E-5 2.13E-9 5.70E-5 4.60E-3 5.44E-4 Bone 7.67E-4 8.36E-4 8.01E-8 2.06E-3 4.60E-2 1.53E-2 Liver 0.
O.
4.71E-9 1.17E-4 5.74E-6 4.37E-3 Kidney 1.75E-4 1.99E-4 2.67E-8 5.65E-4 1.63E-4 1.23E-2 Sources:
U.S. Nuclear Regulatory Commission, Calculational Models for Estimating Radiation Doses to Man from Airborni Materials Resulting from Uranium Milling Operations, Report Task RH 802-4, Washington, D.C., May 1979 and G. R. Hoene:
Age-Specific Radiation Dose Conversion Factors for a One-Year Chronic Intake, Report NUREG-0172, Battelle Pacific Nor.
Richland, Wash., November 1977.
e i
h--
um g
.e_
e%,
131 4
- k,
ErY t*
3i-210 Po-210 3.58E-7 7.41E-4 4.16E 3.10E-2 2.68E-5 5.93E-3 2.08E-4 1.26E-2 1.69E-7 3.67E-4
.97E-6 1.52E-3 1.02E-5 2.43E-3 1.15E-4 7.36E-3 i.66E-8 1.23E-4 i.59E-7 5.09E-4 6.51E-6 1.07E-3
.48E-5 3.60E-3
).96E-8 8.59E-5 1.61E-7 3.56E-4
- .18E-6 7.56E-4
.83E-5 2.52E-3 Radioactive and J. K. Soldat, I
kwest Laboratories, i
= ~ ~.
r
i B-16 REFERENCES FOR APPENDIX B i
l 1.
U.S. Nuclear Regulatory Commission, Calculational Models for Estimating Radiation Doses to Man from Airborne Radioactive Materials Resulting from c<
Uranium Milling Operations, Report Task RH 802-4, Washington, D.C.,
May 1979.
2.
M. Momeni et al., Uranium Dispersion and Dosimetry (UDAD) Code, Report AHL/FS-72, NUREG/ CR-0553, Argonne National Laboratory, Chicago, May 1979.
3.
"40 CFR 190 Related Radiological Doses Due to the Operation of the Uravan Uranium Mill." NUS-3582 May 30, 1980.
~
4.
U.S. Nuclear Regulatory Commission, Final Generic Environmental Impact Statement on Uranium Milling, Report NUREG-0706, Washington, D.C.,
September 1980.
5.
D. C. Kocher, Nuclear Decay Data for Radionuclides Occurring in Routine Releases from Nuclear Fuel Cycle Facilities, Report ORNL/NUREG/TM-102, Oak Ridge National Laboratcry, Oak Ridge, Tenn., August 1977.
6.
J. F. Fletcher and W. L. Dotson, HERMES - A Digital Computer Code for Estimating Regional Radiological Effects from the Nuclear Power Industry, Report HEDL-TME-71-168, Hanford Engineering Development Laboratory, Hanford, Wash., December 1971.
7.
D. R. Kalkwarf, " Solubility Classification of Airborne Products from Uranium Ores and Tailings Piles," Report NUREG/CR-0530; PNL-2830, Pacific Northwest Laboratory, January 1979.
8.
National Academy of Sciences - National Research Council, The Effects on Populations of Exposure to Low Levels of Ionizing Radiation, Report on the Advisory Committee on Biological Effects of Ionizing Radiation, U.S.
Government Printing Office, Washington, D.C.,1972.
9.
G. R. Hoenes and J. K. Soldat, " Age-Specific Radiation Dose Conversion Factors for a One-Year Chronic Intake," Battelle Pacific Northwest Laboratories, U.S. Nuclear Regulatory Commission Report NUREG-0172, November 1977.
e R
f y
l w
(
q
.7 w.
t
~..
r
. s.
p
/
I COMPLIAfiCE DETERMINATION PROCEDURES FOR ENVIR0tiMENTN.RADIATIONPROTECTION STANDARDS FOR URANIUM RECOVERY FACILITIES
'40 CFR 190 U. S. Nuclear Regulatory Commission Division of Waste Management Uranium Recovery Licensing Branch December, 1980 0
O O
4
+we<
w.-+-
-e,_,
Title:
Compliance Detemination Procedures for Environmental Radiation Protection Standards for Uranium Recovery Facilities - 40 CFR 190
/
Background
i Under Title 40 Code of Federal Regulations Part 190 - Subchapter F -
Radiation Protection Programs, the U.S. Environmental Protection Agency (EPA) promulgated " Environmental Radiation Protection Standards for Nuclear Power Operations" which provides limits 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 milling facility
- shall conduct its operations in such a manner to assure that the annual radiation dose equivalent of 25 millirems to the whole bcdy, 75 millirems 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 Regulatory Commission's (NRC) program for compliance detemination 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 CFRc190.
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 impact 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 yellowcake dryer stacks. The NRC has made strict emission control a specific license condition in its licensing activities over the past
- several years; and it has been an NRC requirement that exposure limits be met by emission controls to the maximum extent reasonably achievable.
Such emission control requirements are contained in the May,1977 NRC staff position on " Tailings Management Performance 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 cont'rols 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 by emission control.
All uranium extraction facilities; to include mills, in-situ operations and heap leach facilities. R&D facilities are not included here 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.) However, 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 during the remedial action work phase.
5 e
s.W.hA
. D
- f 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 atmospheric transport models used to compute airborne radioactivity concentrations given a source term, particularly wherdthere is irregular terrain. Therefore, the primary means of determining compliance must be by measurements made s
at the point of receptor and the procedures outlined below reflect this.
't On the other hand, compliance cannot reasonably be determined and corrective action taken where necessary, bf 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 example, to screen out effects of mines that may be nearby and may be contributing to dose.
By no means will the mere assertion that the mill operations utilize emission controls suffice to show compliance to 40 CFR 190 exposure limits. The licensee must provide some supportable dose assessments based on actual environmental monitoring data which are compatible with the procedures discussed below.
Procedure The NRC staff will implement 40 CFR 190 in a phased fashion as shown in Figure 1.
Eventually a standardized 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 monitoring (Phase 1 of Figure 1), however, to firmly establish whether compliance exists at mills which are close to the limit or where there are significant nearby sources of radioactive emissions such as mines, which are not covered by the standard. Much of this time will be spent on the fine tuning of the monitoring and analysis program that is r.ormally 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-term, 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 appropriate.
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 measure's and levels, as the threshold for determining compliance with the standard. This will reduce costs of implementation, 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.
O e
m
,.%r aM E
FIGURE 1 PjlASED IMPLEMEHIATION DEC. 1, '80 PilASE 1 VARIABLE PilASE 2 TIME flRC PROSPECTIVE INITIAL ONG0ING ASSESSME.1TS ASSESSMENTS e ASSESSMENTS O
IDENTIFY LICENSES O
COMPLETE POTENTIAL 0
INDICATOR w
POTENTIAL AMENDED BY INSTALLATION LICENSE CONCENTRATIONS PROBLEM ORDER -
0F EMP'S AMENDMENT WITil SPECIFIED AREAS,
110 CFR 190 ERATING 0
SORT Our INSTITUTE IAKES EFFECT EXTRANEOUS SIMPLIFIED ONDITIONS -
SOURCE ASSESSMENT DEN M IED AS O
ESTABLISit M NIT RING TION EEVELS CONTRInuTIONS PROCEDURE REQUIREMENTS 10 CFR 20 O'
METEOROLOGICAL INCORPORATES SET COMPLETED i
L 40 CFR 190 0
SNORT TERM STUDIES
~
AND TESTS 4
0 IDENTIFY NEEDED
)
REMEDIAL CONTROL MEASURES, IF AOY N
r.1
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 considera, tion 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 determination will be based on environmental monitoring data which indicate directly what such concentrations are.
Predictive models, however, are necessary and valuable tools in evaluating what emission controls are likely necessary, in identifying potential problem ~ areas, and in establishing environmental monitoring requirements.
The following describes the procedures which shall be followed in (A) detemining compliance with 40 CFR 190 based on environmental monitoring data, and (B) assessing proposed operations in tem of their ability to meet 40 CFR 190.
A.
Assessment of Actual Environmental Monitorina Data Figure 2 "40 CFR 190 Compliance Detemination Procedure" shows a diagram of the various steps to be followed to ultimately assure compliance to 40 CFR 190 for all licensing applications.
1.
Each licensee shall establish an Environmental Monitoring
~
Program (EMP) consistent with NRC's Regulatory Guide 4.14,
" 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 infomation 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:
Develop an EMP and submit a plan to the NRC for review a.
and approval.
Such a plan shall include specific details of the number, location, collection method (i.e., equipment),
sampling frequency and analysis infomation for all sample types (e.g., air particulate, radon /WL, stack Lamples, surface and ground wa'ters, vegetation, food, fish, soil, and direct radiation).
For each site (including existing mills), at least one year of site specific meteorological data; e.g., wind speed and direction, stability class, etc., shall be collected, summarized, an.d reported. A site map, including all affected off-site areas, showing each point of sample collection shall 4
e s
4 a
4e
%"'A
FIGURE 2 110 CFR 190 COMPLIANCE DETERMINATI0rt PROCEDURE (8ASED ON ACTUAL ENVIRONMENTAL MONITORING DATA)
EMP D@E E
ESTABLISH REPORTS EMP COMPLIANCE 110 CFR 190 ASSESSMENT COMPLIANCE g
DETERMINATION g
I f
II PLAN DEVELOPED DATA NRC PROJECT BY APPLICANT /
GATHERED BY MANAGER' LICENSEE LICENSEE REVIEW i
x 7
3r ir i
APPROVAL.
DOSES COMPLIANCE LICENSEE VARIANCES AND LICENSE CALCULATED DETERMINED CORRECTIVE REVIEWED /
AMENDMENT ACTION LICENSE IDENTIFIED AMENDMENT LICENSE
<r REPORT AMENDMENT EMP suBniTTED OPERATIONAL u
DOCUMENTATION iP IN ANNUAL IRE REPORT INSPECTION s
also be provided. Participation i 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" (Fetffuary 1979) shall also be discussed in the EMP plan.
1 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.
The EMP plan shall provide a time schedule providing the c.
date when each phase of the EMP will become operational.
For new license applicants, 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 on-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 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, supra.
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.
a.
Such an assessment shall be based on data gathered by the licensee from the approved EMP as discussed above.
Such data use (gathering shall include a semiannual survey of land i.e., residences, grazing, water wells, etc.) in the area within 8 km (5 miles) of th' mill.
Any difference e
in land use from that previously reported shall be discussed and evaluated with respect to 40 CFR 190 compliance.
In order to minimize records keep.ing and formal reporting requirements, while still maintaining a reasonable and timely review df the EMP, annual a erages based on the immediate past two consecutive six month reporting periods shall be used for the compliance assessment and reporting requirements.
e me-ehw p -'
'%*gg 4+
sM
b.
Dose evaluation using site specific input parameters chall be completed using the standardized procedures delineated in Attachment A
" Dose Calculational Guidance",
which are bas 9d on NRC's draft Regulatory Guide RH!802-4,
" Calculational'Models for Estimating Radiation Doses 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 a::sumptions made in Attachment A will be considered by the staff upon request. Also, it is pemissible to subtract out the contribution from background and extraneous sources as determined from measured concen-trations at background locations.
As necessary, a licensee shall indicate in the report c.
what corrective action is being taken if non-compliance is determined. Each licensee shall complete 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 each year, the NRC shall review and complete its own independent determination of each licensee's EMPR and 40 CFR 190 compliance assessment. Such a rev j
influence of extraneous sources (e.g.iew shall consider the
, mining and transportation activities) and any anomalous data (e.g., the indication of erroneous data generated during sample collection or sample analysis),
The NRC Project Manager (PM) shall review all submittals, a.
and shall primarily be responsible for all approvals, license amendments and verification of 40 CFR 190 compliance.
- 1. Upon determination of compliance to 40 CFR 190, the PM will document such findings via a brief Memorandum to File (standardized fom memo) for the subject license within 30 days of receipt of reports submitted under3(c).
ii. Upon determination of non-compliance to 40 CFR 190, the PM shall assure that the licensee take any necessary corrective actions and shall issue specific license amendments as rdquired to accomplish this.
This may require differentiating extraneous sources such as background, mining a,nd transportation activities; obtaining site specific meteorological data, conducting short-term studies, etc. as shown in Phase 1 of Figure 1 above.
m,
n. n.a
I 111. The PM shall reviett'any variance request per 40 'CFR 190.11, and shall initiate appropriate licensing action as required. The EPA shall be notified whenever a varianceisgranted.
iv. The WMUR PM for 40 CFR 190 Compliance assessment x
shall issue a brief annual report summarizing the i
results of the individual license compliance reviews.
This report shall also consider the cumulative dose to any member of the population due to exposure from releases from multiple mill facilities in the general
~
area. The EPA shall be provided with a copy of this sumary report for their review and coment.
5.
The PM shall periodically review a'nd evaluate the EMP, EMP reports, and 40 CFR 190 compliance assessments, and shall
~
eliminate any requirements that experience shows to be nonessential or shall require specific actions necessary to show compliance.
For example, if the airborne concentration measurements show that there is no need to continue radium-226, or thorium-230 analyses, then such requirements shall be eliminated from the EMP. As shown 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.
B.
Predictive Modeling Figure 3 "NRC 40 CFR 190 Assessment of Prospective Milling Operations" shows a diagram of 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 RH#802-4.
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 population due to exposure from releases from multiple mill facilities in the general area;
--n---
a'--
FIGifE 3_.
flRC 10 CFil.190 ASEES90lf 0F PROSfECTI\\E F11LLifG OfIMT10flS (MSED C(l PEDICTIVE WDEllfG EXISTIfE ilRC CCfPLINI EfNIR0fIETTAL MTA M
iflITBIEfff ASSESSTUlf IFFACTSTATEPFJff GAllERED RADIOLOGICAL OR NPMIS/L BY LICBLTE ASSESFtElf IIBfflFY fEEED V-CQfill0L fD\\ SUES OR IUIDITIAL PROBIDI MTA NEAS REVIDED 9
, BUIR0frBffAL l
fullTORiflG i
l sf E DUllU B fTS
. SOURE TEIH ESTimTE
. BNIRDfPUffAL TfWISIVRT
. C0f!CBfTMT10fl PROJECT 10fl
. DOSE CALCILATIQi
APPENDIX A Attachment A Dosa Calculational Guidance
/
The estimated dose received by any member of tne general population shall be calculated based on the applicable potential exposure of the nearest resident in the off-site area surrounding the mill site.
The total dose shall be the sum of the external exposure (i.e., due to radiation sources outside the body? and of the internal exposure (i.e., radioactive materials
~
within the body).
Doses which are due to background and extraneous sources should be subtracted from these measured at the nearest' receptor.
The contribution from non-mill sources -(e.g., mining and trsnsportation activities) should also be determined based upon actual measurements at representative background locations.
1.
External Radiation Exposure -
The direct radiation exposure may be assumed to be equal to the actual personal or environmental dosimetric data less the aporopriate background contribution.
2.
Internal Radiation Exposure -
)
The total dose to organs (e.g., lung, bone, whole body, etc.)
shall be evaluated based on summing all applicable human pathways,
{
such as:
a.
Inhalation cf Airborne Particulates -
The measured airborne concentration multiplied by the dose conversion factors as given in Table A-1.
b.
Ingestion of Contaminated Food and Milk -
The measured concentration in the food product multipled i
(
by the dose conversion factor as given in Table A-2(a)
I through (c).
Ingestion of Meat or Milk from Livestock Grazing on c.
Contaminated Vegetation -
i The measured concentration in vegetation (e.g., grasses in grazino areas) multiplied by the dose conversion factor as given ic Table A-3(a) and (b).
d.
Ingestion of Contaminated Water -
The measured concentration in potable water multiplied by the dose conversion factor as given in Table A-4.
e O
,,%')
- M gpv*"'"'
l
,2-i, Ingestion of Meat or Milk from Livestock Watered en e.
Contaminated Water -
The measuredYconcentration in water used by livestock for watering purposes multiplied by the dose conversion j
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 tnat dose contribution obviously does not need to be considered here. The total dose for each critical organ shall be obtained by summing the dose due to each radionuclide of the uranium decay chain series (i.e., uranium, radium-226 and thorium-230) and through each pathway, i.e., inhalation plus external exposure plus any applicable ingestion 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 excluded from these assessments of actual environmental menitoring data.
However, the dose due to the inhalation pathway shall be of primary concern, with the other pathways providing supplemental information regarding possible exposure. Additionally, a thorough evaluation of background conditions must be completed so that any contribution due to the mill operations (i.e., value d
measured at point of receptor less applicable background level) may be
.}
adequately assessed.
n
$ue t m n st be reviewed in connection with other environmental a
e o in9.,d ta, and other appropriate information or assessment tools 1
(such as computer modelina where this may be helpful)
-4 i
here s r ancma ou data m y be en o nte ed a
b 4
6 4
O 9
e e
k I
I o.
~
4 Table A-1 Dose Conversion Factors for the Inhalatiog)of Airborne Particulates (MilliRer per pCi/m gs a
Whole Radionuclide Body Bone Lung U-238 4.32 79.2 158 U-234 4.92 79.5 180 Th-230 166 5950.
3220
,e i
Ra-226 30.9 309 6610
- The 50-year dose cqmnitment for each year of exposure to 1 pCi/m3'of each radionuclide for an 3
adult breathing rate of 20 m / day.
Particle size of1.55umAMAD(i.g.,meandiameterof1umand density of 2.4 g/cm ) teing representative of j
uranium ore. The Quality Factor for alpha radia-tions is 10. The total dose per organ is the summation of doses due to each radionuclide.
~
~
i (Final GEIS, NUREG-0706).
i l
1 1
e A
..w.
.o Table A-?.(a)
Dose Converson Factors for Ingestion of Contaminated Meat (MilliRemperlCi)+
g Radionutlide Whole 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-226 3.60 E-01 3.60 E+00 4.49 E-04 1.28 E-02
- The 50-year dose commitment for each year of ingestion of contaminated meat. The above factors correspond to an adult ingestion rate of 78.3 kg/yr of meat (beef, poultry, pork, mutton).
(Regulatory Guide RH#802-4).
t 9
e Ts w r
.[
~)
.a,.
.e.
Table A-2(b)
Dose Conversion Factors for Ingestion of Contaminated Edible Vegetation (MilliRemperjCi) g Radionuclide Whole Body Bone Liver Xidney 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 1.08 E-01 6.14 E-03 2.97 E-02 Ra-226 2.42 E-01 2.42 E+00 3.'01 E-04 8.56 E-03 l
- The 50-year dose commitment for each year of ingestion of contaminated ~
~
. edible vegetation.'
A factor of 50% activity reduction through food preparation was assumed, and an adult ingestion rate of 105 kg/yr total vegetable ingestion rate, as well as uniform concentration throughout all vegetable types. Should data be presented as concentration of edible above ground vegetables, C ; potatoes, C ; and other below ground vegetables, C ; then the fbliowing weighked concentration 3
y Cy should be used when multiplying the above dose factors:,
C = 0.38 Cj + 0.58 C2 + 0.05 C3 y
Table 5 of Regulatory Guide RH#802-4 details the breakdown 'of vegetable consumption.
P r
l k
= A, 'i +
7p".
+
"*I i
Cyr.g
.. ~4~
,.j%
2,+
2;an di?@
- ~: - -
n ::.
m;;;x,
_ A _ _.
.E M Ce Wdes
.. ~ -
I l
Table A-2(c).
Dose Conversion Factors for Ingestion of Contaminated Milk (Millirem per pCi/l)*
Radionuclide Whole Body Bone Liver Kidney 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 i
- The 50-year commitment for each year of ingestion of contaminated milk.
These values are based'on an adult consumption rate of 130 liters / year.
Since children drink greater quantities, the resultant dose is much higher for younger people.
Dose conversion factors, as before, are for adults.
Proper dose conversion factors and milk consumption rates 4
for other age groups are presented in Regulatory Guide RHi802-4.
a>
'Il l
t e
Y Y q
, ll.Y J.,+
as, J
- ~ ~ "
'l Table A-3 '(a)
Dose Conversion Factors for Ingestion of Meat from Cattle l
. Grazing on Contaminated Vegetation ci (MilliDemper[g),
i s
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 E-03 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-226 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 on the following.
i) Animal uptake of vegetation: 50 kg/ day
- 11) Environmental transfer coefficients: [pci/kgi
~
(pCi/dayj U - 3.4 x 10~4 Th - 2.0 x 10-4 Ra - 5.1 x.10-4 I
iii) Adult meat ingestion rate: 78.3kg/ year iv) Adult ingestion dose conversion factors (see Regulatory Guide RH#802-4) 4-
' ^
NTN MT M'
3 er m-t i
- d
Table A-3(b)
Dose Conversion Factors for Human Consumption of Milk from Dairy Cows Ingesting Contaminated Vegetation (MilliRemper PCf),
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 7.89 E-04 Th-230 1.85 E-06 6.70 E-05 3.80 E-06 1.84 E-05' Ra-226 1.76 E-02 1.76 E-01 2.20 E-05 6.25 E-04
- The 50-year dose commitnent for each year of ingestion of milk. The above values are based on the following:
i) Animal uptake of vegetation:
50 kg/ day ii) Environmental transfer coefficients:
IpCi/kg s
pCi/dayj U - 6.1 x 10-4 L
Th - 5.0 x 10-6 Ra - 5.9 x 10-4 iii) Adult consumption of milk:
130 liters / year iv) Adult ingestion dose conversion factors (see Regulatory Guide RHi802-4) 4
=
4 r
a3 lut l5l.N..
na.
2
Tablo A-4 Dose Conversion Factors for Human Consumption of Contaminated Water (Millirem per pCi)*
1 1
^
Radionuclide Whole Body Bone Liver Kidney U-238 1.68 E-0.s 2.84 E-01 0.0 6.48 E-02 T-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 dose comitment for each year of ingestion of contaminated wa ter. The above values are based on an average adult consumption rate of 370 liters / year (Regulatory Guide 1.109) and adult ingestion ~
dose conversion factors (Regulatory Guide RH!802-4).
o P"
' [e. c.
-1,
' Q#i '
.I
..a.
Table.A-5 Dose Conversion Factors for Ingestion of Meat from Cattle Watered on Contaminated Water (Millirem per PCi)*
1 i
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 E-03 0.0 2.65 E-04 Th-230 4.46 E-05 1.61 E-03 9.16 E-05 4.41 E-04 Ra-226 9.18'E-03 9.18 E-02 1.15 E-05 3.25 E-04
- The 50-year dose commitnent for each year of ingestion of meat.
The above ' values are based on the following:
- 1) Animal uptake of water: 50 liters / day ii) Environmental transfer coefficients:
fpCf/ko I U - 3.4 x 10-4
'pCi/ day /
f l
Th - 2.0 x 10-4 i
Ra - 5.1 x 10-4 iii) Adult meat ingestion rate of 78.3 kg/ year
- iv) Adult ingest.on dose conversion factors (see Regulatory Guide RH!802-4)
J
.h e
e y>
.$?ll g.
3;$.3 m:
}l R
l!
.a a3+-
Jl
Table A-5(b)
Dose Conycrsion Factors for Human Consumption of Milk from Dairy Cows Watered on Contaminated Water (Millirem per PCf)*
1
)
Radionuclide Whole Body Bone Liver Kidney 49 l
U-238 2.16 E-04 3.65 E-03 0.0 8.33 E-04 U-234 2.46 E-04 3.98 E-03 0.0 9.47 E-04
~
Th-230 2.22 E-06 8.03 E-05 4.56 E-06 2.20 E-05 Ra-226 2.12 E-02 2.12 E-01 2.64 E-05 7.50 E-04
- The 50-year dose commitment for each year of ingestion of milk.
The above values are based on the following:
I i) Dairy animal intake rate: 60 liters / day ii) Adult ingestion milk rate:
130 liters / year iii) Environmental transfer coefficients:
- pci/ liter I (pci/ cay j
U - 6.1 x 10-4 Th - 5.0 x 10-6 4
Ra - 5.9 x 10-4 iv) Adult ingestion dose conversion factors (see Regul'atory Guide RHf802-4) 4 4
I e
i I
4 9
J y-1.
i1
??!E -
,s x.,.
.. ~
...: a
. w..
.n
'Appen' dix B Federal Register / V'ol. 45. No.194 / Friday. October 3.1980 / Rules and Rzgulations 65535 l. pacts cf operaurn; arid to detect potential
' Criterion A--D:llyinspecGons sf tau.ngs increasts or decesses resulting from '
Icrg tem silicts.
cr weste rsttntion syste=s shaU be inf11 bon. ching:s in enginnrms plans..
Cr;terien th-.MiUing operatiens shaU be conducted by a quahSed eng:neer or scientist acuvities performed. and any other conducted so that au airt.orne e!Swent and doeurnented.The apptc;nate NRC cen6tions affecung costs. Regardless of nleases are redaced to levels as low as is regional c5ce as in6cated in Appendia D of whether reclamation is phased through the reasonably achievabla.ne primary means of to CTR part 20. or the Director. Office of life of the operation or takes place at the end accomphs10ng this shaU be by means of Inspecues and ErJercement. U.S. Nudear of operauons, an appropnate portion of e=ission coctrols. Institutenal controls. suth 'Regslatory Co=mussion. Washington. D.C.
sunty liability shall be retained until rmal.
as exten6Ag the nie boundary and endusion
- Ou5. shan be i=me6ately notied of any compliance with the reclamaton plan is..
area, may be employed to ensure that of! cite f ailure in a tallings or waste retemn system determined.nis wiu yield a surety that is at' i
exposure li=its are met but only after all -
which results in a release of talhr.~ or waste least suficient at au times to coser the costs of decc==issioning and redamation of the pracucable measures have been taken to into unrestncted anas. and/or cf any '
areas that are expected'io be d sturbed controle=issions at the sourca.
unusual con 6tions (con 6tions not Notwithstanding the existence ofin6vidual contemplated in the design of the retentica before the next beense renewal.ne term of dose standare.s. stnet control of emnsions in system) which if not corrected could in6cate the seety mechanism must be open ended.
nec.essary to assure that populanon the potential or lead to faDure of the system unless it can be demonstrated that another exposuns an reduced to the maxanum and nsult in a release ei tailings or waste arrangement would provide an equivalent extent reasonably achievable and to avoid into unresmeted anas.
level of assuanet.nis assuranca could be site contammucn. The greatest potennal provided with a surety instrument which is sources of casite r 6auon exposure (aside U.Enancial Criteria wntten for a specified period of time (e g.
fr:m redon exposure) are dustna frem dry Cntenon s-Finsacial s=ety arrangements five years) yet w;uch must be automaticaUy surfaces of the tailings 6sposal ana not shaU be estahbsbed by ea'ch c:in operator renewed unless the surety notifies the covered by u Ws solution and emissione prior to the ec=mencement of eperations to beneSoary (the Cec =ission or the State
! om yeDowcake drymg and packag=3 assure that suf5cient funds win be available regulatory etency) and the principal (the ope raton' to carry out the deconta=ination and Ucensee) some reasonable time (e.g. 90 days)
Checis shaU be made and leved bouly of prier to the renewal date of theirintenton' au parameters (e_g.65erecual pressures and decommissioning of the mal and site and for the reda=auon of any tailings or waste not to renew.in such a situation the surery
- ubber water Cow rates) which detede disposal areas.ne amount of f.md4 to be requirement still exists and the licensee t:e e!Eciency of yeDowene staci e=isoon ensured by such sunty arrangementa shaU be would be required to submit an acceptable esetrol eswpment operstar. !: shan be based on Co==ission. approved cost replacement surety within a brief penod o,f determined whether or r.ot cen6 mons are u 6 a Connen. approved plan for ti=e to aUow at least ec days for the n
widm a range presenbed to ensue that the (1) decentaminsuon and decc==issicning cf regulatory agency to coUect, equi; ment is operstmg consistentfy near cuu buil6ngs and the =iting site tolevels Proof of forfeiture must not be neessary to peak eBoency correcove acton sbau be Wh 4 aUp msM use cf due coUect 6e g so 6at b h w h h taken when performance is outside of anos upon dece==issioning and I:) the beensee could not provide an acceptable presc-ibed runes. ci!!uent control devices redamation of tailings and/or waste dsposal replacement surety wiiin the required me, sha3 be opersove at all t:mes dunna dry =3 g
ggg g
gg g
dehneated in Secton I of this Appendix.The
.pnor to its expiration.The con 6 tons e a t.
tb y U ca e ta bcenset sha3 sub=11 this plan in conjuncucn cescibed above would have to be dearly
~ ~ '
Drp. and puh. ages operabens abau with an envron= ental report 6at adnresses stated en any surery instrument which is not te = mate when controls are inoperanve.
the expected envuonmentali= pact.: ef the opesnded, and must be agreed to by all When checks in6cate the equipment is not parms.Finano ! surety anangements millms operauor. dece==issioning sad a
cperat=3 within the range prescibed for tailmss redamauor. and evaluates generaDy acceptable to the Commission are:
peak emorney, accons shah be tnen to ahemativo for =itigating tbne != pacta.ne (a) Sunty bonds restore parameters to the prescibed ranse.
When this cannot be done without shuteown surety shad also cover the pay =ent of the (b) Cash deposits:
end repairs. dry =g and packag=a operanons charge for long term surniHanes and contml (c) CertiScates el deposit f
shall cene as soon as pracocabie.
requ: red by Critenom 10.1m estabbsn=3 (d) Deposits of governme:*. secunties:
Opersuons may not be re-started after spec:Sc surety arrangementa. the licensee's (e) Irrevouble letters or lines of cre6t: and cost utimatu shaU take into ac:ount total (f) Combmanons of the above or such cther cenaton due to oH.nor=al performance until costs that would be incurred if an types of arrangements as may be approved needed correcove actorts have been identSed and 2nplemented. AD such independent contractor were hired to perform by the Com:mssion. However. self insurance, cessabona. correctve actons. and re.etarts the decommissioning and redsmatien work.
or any arrangement which essentiaDy she.U be reoorted to the appropnste NRC
. In order to avoid unnecessary 6rpbcanon consututes self insurance (e.g. a contract regnonal of5ce a s in6cated in Cr:tenen aA. in and expe=sa. the Commission may accept
. wi6 a state or federal agency). will not financial sureties that have been satufy the surety requirement since this wnt:ryt. withm 10 days of the subsequent consobdated wi6 financ:al or surety provides no ad6tional assurance other than res tan.
To coctml dustmg !:cm taihngs. that anangements estabbshed to meet that which already exists through beense porten not covered by stan6sg hauida shan. requirements of other Federal or state recuirementa.
be wetted or che=icaUy stabutzed to prevent agencies and/or local governing bo6es for Cnterion WA minimum charge of or *"a bloweg and dustmg to the such decom= ssionmg. cecontamination.
3250.000 (19 8 dollars) to cover the costs of maxtnu:a extent reasonably acnaevable.nis redemauon. andlong term site su-veillance. Icng term surveillance shan be paid by each requirement may be relaxed if tailms: are and control provided such arrangements are miu operator to the general treasury of the effecovelv sheltered from wind. such as may considered adequate to satisfy thne Ucated States or to an apprepnate State be the case =bere they are 6sposed of below requirements and that the portion of the agency prior to the ter==ation of a uranium grade and the tailmss surf ace is not exposed surrrv which covers the deco =tmissioning or thorium miH !icense.
to wind Consideranon shau be given in and.eclamation of the c:iU. miu tailings site If site surveillance or centrol requirements planruns tadings 6sposal pregrams to and associated areas. and the long term at a particular site are determined on the methods which wculd adow phased covering fundmg charge is dearly identfied and basis of a site. specific evaluation.to be and redarnauen cf tauings impound:nents comrutted for use in ac:omphshing these sigmficantly greater than those speciSed in stnce this wiu help in con:relhng particulate actmties.The licensee's surety mechanism Cnterien 11(e.g. if fenc:ng is dete.=ined to and radon emissions dur.ng cperanon.To wiU be reviewed annually by the Cont =assion be necessary) variance in funding control dustmg f em 6f8use sources, such as to assure that sufficient funds would be requirements may be speciSed by the taihngs and ore pads where automatic available for completion of the redamation Commission. In any case. the total charge to controls do nc4 apply, cperators shall develop plan if the work had to be perfor=ed by as cover the costs oflong term surveiUance shaU wntien operatmg procedcres specifving the independent contract:r.The amount ci surety be such that, w;th and assumed 1 percent rnethods cf can:rcl wr.ich will be utilized.
babity should be adjusted to rec 0gni:e any
' annual realinterest rate. the collected funds
'Ir 1
i
- Ag l1w a.w ?
Roferences 0
U.S. Environmental Protection Agency - Title 40 Code of Federal Regulations l
Part 190 - Subchapter F, " Environmental Radiation Protection Standards for Nuclear Power Operations" (40 CFR 190).
l 0
U.S. Nuclear Regulatery Cc=nis'sion"- Regulatory Guide 4.14, " Radiological Effluent and Environmental Monitoring at Uranium Mills" (April 1980).
O U.S. Nuclear Regulatory Commission - Regulatory Guide 4.15. " Quality Assurance Programs for Radiological Monitoring Programs (Normal Operations) -
-s Effluent Streams and the Environment" (February 1979).
O U.S. Nuclear Regulatory Commission - Regulatory Guide RH!802-4, "Calcula-tional Models for Estimating P.adiation Doses to Man from Airborne Radioactive Materials Resulting from Uranium Milling Operations" (draft, May1979).
O U.S. Nuclear Regulatory Cctaission - Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I" (Revision 1, October 1957).
U.S. Environmental Frotection Agency - Final Environmental Statement, o
"40 CFR 190 Environmental Radiation Protection Recuirements for Normal Operations of Activities in the Urnaium Fuel Cycle," EPA 520/4-76-016.
(November 1976).
U. S. Environmental Protection Agency-- Part IV - Supplemental Analysis-1976, o
" Environmental Analysis of the Uranium Fuel Cycle," EPA 520/4-76-017.
(July 1976).
o' U. S. Nuclear Regulatory Commission "MILDOS Computer Code User's Manual", By G. N. Gnugnoli and D. E. Martin (May 1980).
U. S. Nuclear Regulatory Commission " Final Generic Environmental Impact o
Statement on Uranium Milling", NUREG-0706 (September 1980).
g s.
'4e S
4
,., t l
'.~ 5 L 4
AL M
316-'
-w.
- ~. -
n
+
v.-