ML20211C407
| ML20211C407 | |
| Person / Time | |
|---|---|
| Issue date: | 09/19/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20211C406 | List: |
| References | |
| REF-WM-41 NUDOCS 9709260189 | |
| Download: ML20211C407 (13) | |
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COMPLETION REVIEW REPORT FOR THE REMEDIAL ACTION AT THE SALT LAKE CITY, UTAH VITRO PROCESSING SITE URANIUM MILL TAILINGS REMEDIAL ACTION PROJECT SITE September 1997 DIVISION OF WASTE MANAGEMENT U.S. NUCLEAR REGULATORY COMMISS!ON T'2 g92 By970919 WM-41 PDR -
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TABLE OF CONTENTS StEll9n East
- INTRODUCTlON.....................................................................................................................1
1.0 BACKGROUND
..............................................................................................................1 1.1 UMTRCA........................................................................................................................1 1.2 CONCURRENCE PROCESS FOR THE SELECTION OF DOE'S REMEDIAL ACTIONS......................................................................................................................1 1.3 CONCURRENCE PROCESS FOR THE PERFORMANCE OF DOE'S REMEDIAL ACTlONS........................................................................................................................2 1.4 S ALT LAKE CITY VITRO PROCE S SING SITE............................................................ 2 1.5 COM PLETlON REVIEW RE PORT ORG ANIZATION....................................................... 2 2.0 ANALYSIS OF DOE REMEDIAL ACTlON PERFORM ANCE........................................... 2 2.1 P R E VI O U S A C Tl O N S....................................................................................................
2.2 REVIEW OF RE M EDI AL ACTION PERFORM ANCE....................................................... 4
- 2. 3 RADI ATlON P ROT ECTlON REVIEW.............................................................................. 4 3,0
SUMMARY
......................................................................................................................7
4.0 REFERENCES
...............................................................................................................7 APPENDlX A NRC SITE VISITS TO THE UMTRA PROJECT VITRO SITE........................... A 1 APPENDIX B - UMTRCA, THE EPA STANDARDS, AND THE PHASED U.'.* T RA P R O J E C 1..........................................................................................
LIST OF FIGURES Elama East 1.1 Vitro Processing Site Before Remediation..................................................................... 3 2.1 Location of Resid ual Radioa ctive Material..................................................................... 6
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SALT LAKE CITY, UTAH, VITRO PROCESSING SITE COMPLETION REVIEW REPORT INTRODUCTION The Salt Lake City site is one of the 24 abandoned uraniurn mill tailings sites to be remediated by the U.S. Department of Energy (DOE) under the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA). UMTRCA requires, pursuant to Section 104(f)(1), that the U.S. Nuclear Regulatory Commission concur with the DOE's determination that the remedial action has been properly completed. This Completion Review Report (CRR) documents the NRC staff's basis for its concurrence decision with respeci to DOE's Certification Summary for the completion of surface remediation at the Salt Lake City (Vitro) former processing site. The NRC staff prepared a separate CRR for the Salt Lake City disposal site located at Clive, Utah.
1.0 BACKGROUND
1,1 UMTRCA Title I of UMTRCA provides for remedial action at abandoned uranium mill tailings sites and associated vicinity properties. The purpose of this legislation is to protect the public health and safety and the environment from radiological and non-radiological hazards asociated with the process related materials at these sites.
UMTRCA directs DOE to select and perform remedial actions at 24 abandoned uranium mill tailings sites to ensure compliance with the general environmental standards promulgated by the U.S.
Environmental Protection Agency (EPA) under Section 275(a) of the Atomic Energy Act of 1954, as amended by UMTRCA. UMTRCA also requires DOE to obtain NRC's concurrence with DOE's selection and performance of the remedial actions. Following completion of the remedial actions, UMTRCA authorizes NRC to license the long-term custody, maintenance, and monitoring of the disposal sites to ensure continued protection of the public health and safety and the environment.
Appendix B includes a more detailed discussion of this legislation.
1.2 CONCURRENCE PROCESS FOR THE SELECTION OF DOE'S REMEDIAL ACTIONS To document its selection of the remedial action to be implemented at a particular site, DOE develops and issues a Remedial Action Plan (RAP) underits Uranium Mill Tailings Remedial Action (UMTRA) Project. The RAP descnbes the series of activities and presents the design proposed by DOE to provide for the ;0ng term protection of the $ lblic and the environment. Usually this involves cleanup of the processing site and adjacent windblown areas, in addition to stabilization of the residual radioactive materials. DOE also issues a Remedial Action Inspection Plan (RAIP), which establishes the quality control program of testing and inspection that will be employed for the remedial action. In accordance with UMTRCA Section 108(a)(1), the NRC staff reviews and concurs with the RAP and the RAIP, and any subsequent modifications. By its concurrence in the remedial action selection, the NRC staff concludes that the planned remedial actions will comply with EPA's applicable standards in 40 CFR 192, Subparts A, B, and C. The basis for the concurrence in DOE's selection of remedial action is documented in a Technical Evaluation Report (TER).
1
1.3 CONCURRENCE PROCESS FOR THE PERFORMANCE OF DOE'S REMEDIAL ACTIONS
' The remedial actior. work is performed by DOE contractors under Federal procurement regulations.
During construction, DOE inspects and documents activities in accordance with the UMTRA Project Quality Assurance Plan, the RAIP, and the RAP. In addition, the NRC staff conducts independent inspections during construction, as determined necessary.
Upon completion of the remedial action, DOE compiles construction records and prepares a comp letion report to document that remedial actions were performed in accordance with the RAP or RAP modifications, and the RAIP. Based on this information, DOE certifies that all provisions of the RAP have been satisfied and, therefore, that the remedial actions comply with the applicable EPA standards in 40 CFR 192.
Based on its review of DOE's documentation, and on its site visits and observations, NRC makes a concurrence decision with regard to DOE's remedial action completion determination for each site, and then documents the basis for this concurrence decision in the CRR. By its concurrence in the remedial action performance, the NRC staff concludes that the remedial action has been completed in accordance with the NRC aoproved design NRC's concurrence with DOE's compleWn determination fulfills the Commission's responsibility under UMTRCA Section 104(f)(1).
1.4 SALT LAKE CITY VITRO PROCESSING SITS, The Salt Lake City uranium mill tailings site, also known as the Vitro site, is located about four miles southwest of the Salt Lake City dosentown area. The Vitro plant processed uranium ores from 1951 to 1964. In 1965, the mill was converted to the production of vanadium. Vanadium production ceased in 1968 and the plant was dismantled in 1970. Prior to remediation, the tailings piles were largely uncovered.
The State of Utah was the DOE contractor at the site. Tailings and debris from the Vitro site in Salt Lake City (Figure 1.1) were transported by rail,1985 through 1987, for disposal at the Clive site, which is located about 65 miles west of Salt Lake City, in Tooele County, Utah. The former Vitro processing site is now owned by the Central Valley Water Reclamation Facility Board.
1.5 C_OMPLETION REVIEW REP _ ORT ORGANIZATION The purpose of this CRR is to document the NRC staff review of DOE's Salt Lake City, Vitro Processing Site Completion Report (CR)(DOE,1997). Section 2 of this report presents the analysis of remedial action and ridresses radiation protection aspects of the remedial action. Appendix A provides a listing of NRJ dlalf visits to the Vitro site and Appendix B provides a detailed description of the requirements of UMTRCA and the resulting phased process of the UMTRA project.
2.0 ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE 2.1 PREVIOUS ACTIONS NRC staff, based on its review of the RAP (DOE,1984), and the RAIP (MK-F,1985) concurred that the remedial action, as designed, would meet the applicable EPA standards. This concurrence was based on technical findings that there is reasonable assurance that the selection of the remedial action would meet the standards for long term stability, radon attenuation, water resources protection, and cleanup of contaminated land.
2
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Staff reviews included assessments in the areas of erosion protection, water quality, geology, geotechnical stability, and radon attenuation. The NRC concurred on the final RAP and the RAIP on
' November 7,1985. The basis for the NRC staffs concurrence in DOE's selection of remedial action at the Salt Lake City site is documented in a Technical Evaluation Memoranda (TEM) issued in March 1985 (NRC,1985).
2.2 REVIEW OF REMEDIAL ACTION PERFORMANCE The NRC staffs primary objective in reviewing DOE's certification of remedial action completion is to determine whether the remedial actions have been performed in a manner consistent with specifications provided in the RAP, RAP modifications, and the RAIP, and if not, that deviations to these specifications still resu:t in compliance with the EPA standards. In support of this action, the NRC staff participated in site reviews (see Appendix A), field observations, assessnient of on site data and records, and review of DOE Site Audit Reports. The following section presents the results of the NRC review of remedial action performed at the Vitro site.
2.3 RADIATION PROT ECTION REVIEW The EPA cnterion for soil radium (Ra 226) (40 CFR 192.12) requires cleanup at the processing site 2
such that the average Ra-226 levels above background in each 100-m area do not exceed either 5 pCilg in the top 15 cm of soil, or 15 pCilg in any underlying 15-cm layer. If radionuclides other than radiurn and its decay products are present in sufficient quantity and concentration to constitute a significant radiation hazard, a supplemental standard needs to be applied in accordance with the EPA requirement in 40 CFR 192.21(h). If such a standard is applied,192.22 (b) requires that remedial action reduce other residual radioactivity to levels that are as low as is reasonably achievable (ALARA).
The NRC staff reviewed the radiation protection aspects of remedial actions at the Salt Lake City Vitro processing site to ensure that cleanup of residual radioactive materials was performed in accordance with the NRC-approved specifications in the RAP, RAIP, and the final design. Areas of review included contaminated material excavation, verification of cleanup, laboratory and field testing, and quality assurance audits. The NRC staff reviewed the venfication results presented in the DOE Completion Report for the Vitro Processing Site and the information in the DOE Final Audit Report of Remedial Action Construction (DOE,1996).
During review of the radiation protection aspects of the remedial action completion documentation for the processing site, the NRC staff noted the following:
1.
The techniques, which DOE states were used for verifying radiological cleanup at the processing site (CR Section 4), comply with standard DOE practices. The DOE audit report indicates that although several audit observations were made at the Vitro site, none affected the ability of the contractor to ensure compliance with EPA standards.
2.
The radiological survey records support general compliance with the Ra-226 soil cleanup standards in Subpart 8 of 40 CFR Part 192. However, sample results indicate that the Ra-226 tubsurface standard was exceeded in six isolated grids. The elevated Ra-226 grid 2
(100m ) values are 42.0,28.1,19.2,17.9,17.6, and 16.0 pCilg. DOE indicated (in response to NRC comments) that the six Ra-226 values are bookkeeping anomalies reflecting a failure to update records to include the final venfication sample analysis. However, a conservative assumption is that the grids remain as reported in the CR. On page 7-6 of the CR, DOE
. Indicates that the grid with 42 pCi/g Ra 226 would produce 0.02 WL (radon progeny 4
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concentration) in a house built over that area, if the radon flux was calculated assuming that the existing 4.7 feet of backfill would remain in place. This levelis equivalent to the Uranium Mill Tailings Remedial Action (UMTRA) Project limit for existing buildings which is 0.02 WL
_ (40 CFR 192.12(b)). This small amount of buried material would only be hazardous if a house were built directly over the deposit such that radon could accumulate in the structure.
Therefore, the NRC staff concludes that of the six venfication grids that may not meet the 15 pCi/g plus background radium standard, only the one with the highest reported concentration could potentially produce an unacceptabie health risk, and then, only under highly unlikely conditions (considering future land use).
3.
Because thorium (Th 230) was identified at the Vitro site, a supplemental standard for Th 230 is presented in Section 6.2 of the CR, however, the supplemental standard application was not submitted to NRC for concurrence during remediation of the site. Also, site remediation was performed before the UMTRA Project Th-230 generic policy (December 1993) and the 35 pCi/g Th 230 guideline were under discussion. DOE estimates in the CR that at least 1480 cubic meters (24 grids exceed 35 pCilg) of Th-230 contaminated soil remain on the Vitro site. The analyzed samples from the 24 grids average 234 pCilg. However, the exact extent of the remaining ekvated Th-230 is r;ot known, since the deposit edges were estimated and the analytical results for 100 grids only indicate that the Th 230 < 50 pCilg so some of these grids may exceed 35 pCl/g (see Figure 2.1). In addition, DOE did not include a discussion in the final CR indicating that the Th 230 cleanup achieved the ALARA level.
The NRC staff, as part of its review, considered whether the residual Th 230 was a significant hazerd, in order to determine if a supplemental standard was required. Because Th 230 is an alpha emitter, it can be hazardous to humans / animals if a sufficient quantity is inhaled with dust particles or ingested because of uptake into food (vegetables, milk) or water. The staff evaluated the likelihood that this residual material could create a health hazard, even though it is covered by 0.5 to 8.5 feet of soil. The proposed future land use for this property does not include residential occupation, consequently, DOE evaluated potential dose.mpacts due to non-resident exposures. DOE's dose modeling demonstrated that a construction worker on the site for 3 months, exposed to the highest Th-230 concentration, mighi receive a dose of 71 mrem, which is below the 100 mrem /yr public dose limit applicable to NRC licensed sites.
Exposure to the Th-230 via the food pathway is not likely as the site is in an industrial area.
Ingestion of Th-230 via the water pathway is unlikely because DOE indicated that the Th-230 is in an insoluble form adheririg to soil particles, Th 230 is not elevated in the groundwater, and the site groundwater is not drinking water quality. Based on this information, NRC staff determined that under current site use (open land, driving range) and anticipated site use (golf course, expansion of waste water treatment facility), there is not a significant hazard due to the remaining Th 230 on the Vitro site in the foreseeable future. Therefore, a supplemental standard for Th 230 is not required.
4.
Although the EPA regulations do not require assessment of hazards far in the future, due to the presence of Th 230, the NRC staf* considered that when Th 230 decays (half life 77,000 years)it produces Ra-226. Under certain land uses (long-term exposure scenarios), the Ra-226 and its decay products could be hazardous within a few centuries, but most important is its daughter radon (Rn-222), which has the same activity as the Ra-226 within a month of the Ra 226 formation. The radon gas, if allowed to build-up inside a habitable structure, creates an inhalation hazard due to radon progeny. After 100 years, some of the grids with high Th 230 content could present a health hazard due to radon progeny (greater than 0.02 WL), if a habitable structure were built over the deposit without a radon venting / barrier system. The staff concluded that given the high cost of excavation, testing, transport, and disposal of the Th-230 contaminated material, and the fact that any future health risk from the i
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Th-230 could be controllod by land (deed) annotation (see following discussion), the uncertainty of site use (potential radiation dose) in future centuries does not warrant addit.onal remediation of Th 250 at the Vitro site.
5.
Land annotation is required by Section 104(d) of UMTRCA, which states that the DOE shall issue appropriate rules and regulations to require notice in the localland records of the residual radioactive materials which were located at any processing site. It also indicates that the State shall take action to notify any person, prior to purchase of the site, of the condition of such site after remedial action. The proposed land annotation document for the Vitro site entitled," Notice of Residual Radioactive Contamination,"was reviewed by the staff. The document notifies potential buyers of the presence of the residual radioactivity on the site, and of ways to avoid ootential health risks due to the material. Exhibit 2 from that document (see Figure 2.1) indicates the locations of the residual contamination. Note that the area of contam' nation along 3300 South Street shown on this figure is the supplemental standards area for Ra426 material remaining around the gas and water lines.
3.0
SUMMARY
The purpose of this review was to determine whether DOE had performed remedial actions at the site in accordance with specifications in the RAP, RAP modifications, and other supporting project documents, and thus with the EPA standards in 40 CFR Part 192, Subparts A-C. Based on its review of the Final CR and associated documents, and on observations made during periodic site visits, the NRC staff concludes that DOE performed remedial action at the Vitro site in accordance with the EPA standards. Therefore, NRC concurs with DOE's certification of completion of the Salt Lake City remedial action at the former Vitro processing site.
4,0 REFERENCES U.S. Department of Energy (DOE), Washington, D C.
, Remedial Action Plan and Site Conceptual Design for Stabilization of the inactive Uranium Mill Tailing Site at Salt Lake City, Utah, UMTRA-DOE /AL 0141.0000. December 1984.
, Final Completion Report, Salt Lake City, Utah, Vitto Proct:1;,ing Site, June 1997.
Final Audit Report of Remedial Action Construction at the UMTRA Project Salt Lake City, Utah, Site, April 1996.
U.S. Nuclear Reguiatory Commission, Washington, D.C., Final Technical Evaluation Memoranda for the Remedial Action of the South Salt Lake City, Utah (Vitro) Uranium Mill Tailings Site, March 1985.
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APPENDIX A-l ti:'C SITE VISITS TO THE SALT 1.AKE CITY UMTRA PROJECT VITRO SITE i
4 Date Staff / Discipline Purpose Sept. 28,1983 T. Verma site tour and review aspects M. Weber / hydrology of site hydrology March 30,1984 D. Martin / management site visit G. Gnugnoli/ health physics July 25,1985 D. Gillen/geotechnical engineering '
on site construction review May 5,1986 D. Gillen/geotechnical engineering review excavation of E. Hawkins/ management contaminated material and T. Olson/ groundwater hydrology verification of soll cleanup i
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APPENDIX B UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT Title I of the Uranium Mill Tailings Radiation CorWol Act (UMTRCA) defines the statutory authority and roles of the DOE, the NRC, and the EPA with regard to tne remedial action program for inactive uranium mill tailings sites.
The Standards UMTRCA charged the EPA with the responsibility for promulgating remedial action standards for inactive uranium nll sites. The purpose of these standards is to protect the public health and safety and the environment from radiological and non-radiological harards associated with radioactive materials at the sites. UMTRCA required that EPA promulgate these standards by no later than October 1,1982. After October 1,1982, if the EPA had not promulgated standards in final form, DOE was to comply with the star aards proposed by EPA under Title I of UMTRCA until cuch time as the EPA had promulgated its standards in final form.
The final EPA standards were promulgated with an effective date of March 7,1983 (48 fB 602; January 5,1983); see 40 CFR Part 192 - Standards for Remedial Actions at inactive Uranium Processing Sites, Subparts A, B, and C. These regulations may be summarized as follows:
1.
The disposal site shall be designed to control the tailings and other residual radioactive materials for up to 1000 years, to the extent reasonably achievable, and, in any case, for at least 200 years (40 CFR 192.02(a)).
2.
The disposal site design shall provide reasonab!a assurance that radon-222 from residual radioactive material to the atmosphere will not exceed an average release rate of 20 picoeuries per square meter per second, or will not increase the annual average concentration of redon-222 in air, at or above any location outside the disposal site, by more than one-half picocurie per liter (40 CFR 192.02(b)).
3.
The remedial action shall be conducted so as to provide reasonable assurance that, as a result of residual radioactive materials from any designated processing site, the concentrations of radium-226 in land averaged over any area of 100 square meters shall not exceed the backgro ind level by more than 5 pMocuries/ gram averaged over the first 15 centimeters of soil below the surface and 15 picoeuries/ gram averaged over 15 centimeter thick layers of soil more than 15 centimeters below the surface (40 CFR 192.12(a)).
4.
The objective of remedial action involving buildings shall be, and reasonable effort shall be made to achieve, an annual average (or equivalent) radon decay product concentration (including background) not to exceed 0.02 WL, and the level of gamma radiation shall not exceed the background level by more than 20 microroentgens per hour [40 CFR 192.12(b)).
5.
The portion of the EPA standards dealing with groundwater requirements,40 CFR 192.20(a)(2)-
(3) were remanded by the Tenth Circuit Court of Appea% on September 3,1985. Based on this court decision, EPA was directed to promulgate new groundwater standards. EPA proposed these standards in the form of revisions to Subparts A C of 40 CFR Pari 192 in September 1987, and the final groundwater standards were promulgated January 11,1995.
B-1
Before the groundwater standards were final, as mandated by Section 108(a)(3) of UMTRCA, the remedial action at the inactive uranium processing sites were to comply with EPA's proposed standards untd such time as the final standards are promulgated. DOE performed remedial action at the inactive processing sites in accordance with NRC's concurrence with the remedial action approach based on the proposed EPA groundwater standards (52 8 36000; September 24,1987). Delaying implementation of the remedial action program would be inconsistent with Congress' intent of timely completion of the program. Modifications of disposal i
sites after completion of the remedial action to comply with EPA's final groundwater protection standards may be unnecessarily complicated and expensive and may not yield commensurate benefits in terms of human and environmental protection. Therefore, tne Commission believes that sites where remedial action has been essentially completed prior to EPA's promulgation of final groundwater standards will not be impacted by the final groundwater standards promulgated January 11,1995. Although additional effort may be appropriate to assess and clean up contaminated groundwater at these sites, the existing designs of the disposal sites should be considered sufficant to provide long-term protection against future groundwater contamination. NRC does not view UMTRCA as requiring the reopening of those sites that have been substantially completed when NRC concurred with the selection of remedial action in accordance with applicable EPA standards, proposed or otherwise in place at the time such NRC concurrence was given.
DOE Selection (Desian) Phase For each site, UMTRCA requires that DOE select a olan of remedial action that will satisfy the EPA standards and other applicable laws and regulations, and with which the NRC will concur. For each site, this phase includes preparation by DOE of an Environmental Assessment or an Environmental Impact Statement, and a Remedial Action Plan (RAP). The RAP is structured to provide a comprehensive understanding of the remedial actions proposed at that site and contains specific design and construction requirements. To complete the first phase, NRC and the appropriate State or indian tribe will review the RAP and then concur that the RAP will meet the EPA standards.
The Performance (Construction) Phase 2
in this phase the actual remedial action (which includes decontamination, decommissioning, and reclamation) at the site is done in accordance with the RAP. The NRC and the Statelindian tribe, as applicable, must concur in any changes to the concurred-in plan that arise during construction. At the completion of remedial action activities at the site, NRC concurs in DOE's determination that the activities at the site have been completed in accordance with the approved plan. Prior to licensing (the next phase), title to 'he disposed tailings and contaminated materials must be transferred to the United States end the la.u von which they are dispused of must be in Federal custody to provide for long-term Federal control. Disposal sites on indian land will remain in the beneficial ownership of the Indian inbc.
NRC concurrence in the DOE determination that remedial action at a processing site has been accomplished in accordance with the approved plan may be accomplished in two steps where residual radioactive materialis not being moved from the processing site to a different disposal site.
The Uranium Mill Tailings Remedial Action Amendments Act of 1988 allows for a two-step approach for Title I disposal sites. The Amendments Act will allow DOE to do all remedial actions, other than
- groundwater iestoration, for the first step of closure and licensing. The second step, which can go on for many years, will deal with existing groundwater restoration. When groundwater restoration is completed, the Long-Term Surveillance Plan required under the licensing phase will be appropriately amended. - For sites that are being moved, licensing will occur in one step. There is no groundwater B-2
e restoration at the disposal site and the processing site will not be licensed after completion of
, remepial action.
The Licensina Phase Title i of UMTRCA further requires that, upon completion of the remedial action program by DOE, the permanent disposal sites be cared for by the DOE or other Federal agency designated by the President, under a license issued by the Commission. DOE will receive a generallicense under 10 CFR Part 40.27 following: (1) NRC concurrence in the DOE determination that the disposal site has been properly reclaimed, and (2) the formal receipt by NRC of an acceptable Long Term Surveillance Plan (LTSP). NRC concurrence with DOE's performance of the remedial action indicates that DOE has demoostrated that the remedial action complies with the provisions of the EPA standards in 40 CFR palt 192, Subparts A, B, and C. This NRC concurrence may be completed in two steps as discussed above. There is no termination date for the generallicense.
Public involvement has been and will continue to be provided through DOE's overall remedial action program for Titt0 i sites. The local public will have an opportunity to comment on the remedial action or closure plans poposed and implemented by DOE and to raise concems regarding final stabilization and the degree of protection achieved. NRC fully endorses State / Indian tribe and public input in all stages of the program. /,t the time the LTSP is submitted, the NRC will consider the need for a public meeting in response to requests and public concerns.
The Surveillance _and Monitorina Phase In this phase, DOE and NRC periodically inspect the disposal site to ensure its integrity. The LTSP will require the DOE to make repairs, if needed.
One of the reauirements in the EPA standards is that control of the tailings should be designed to be effective for up to 1000 years without active maintenance. Although the design of the stabilized pile is such that reliance on active maintenance should be minimized or eliminated, the NRC license will require emergency repairs as necessary. In the event that significant repairs are necessary, a determination will be made on a site specific basis regarding the need for additional National Environmental Policy Act actions, and health and safety considerations based on 10 CFR Parts 19, 20, and 21.
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