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' •, • MEMO [o B. Humphries/J. ens • <br />~ ~ ]une I 11996 - EFN's DMO Determinations <br />Page 3 <br />May ] 9, 1995) to the Division in support of their argument. T'he DOE report presentexl a scenario <br />where an individual camps on a mine-rock waste pile for 24 hours a day over a 14-day period. T'he <br />Total Effective Dose Equivalent (TEDE) resulting from exposure was calculated to be 79 mrem/yr <br />which is less than the NRC standard of 100 mremlyr. T'he average value of 0.04 pence;nt U,Og was <br />used in the random dose calculations. This percentage was derived from historic data collected on <br />DOE Lease Tract 13 which is located about 6 miles southwest of the Sunday/West Sunday mines. <br />Without additional data, it is difficult to determine if the DOE scenario would apply to the <br />SundaylWest Sunday mine sites, even though the DOE feels "the exposure value resulting from this <br />scenario on Lease Tract 13 is considered representative of the amount of radiation an individual <br />could be exposed to at any other lease tract, because of the physical similarities of all the mine sites <br />and mine-rock waste piles". If the physical characteristics are the same, will the value of uranium <br />be the same? Is there a direct corollary between the average valve of uranium and the TEDE? <br />Does 0.04 percent, or greater, uranium constitute a quantity of toxic-forming materi;tl sufficient <br />to adversely affect human health, property, or the environment, since it appears the TT:DE could <br />exceed NRC standards, if an individual is exposed for more than 14 days? Would less than 0.04 <br />percent uranium mean there is not enough radioactivity to adversely affect human health, etc.? <br />The Department of Health, Radiation Control Division, according to Tom Pentecost, has exempted <br />uranium concentration of less than 0.05 percent from their regulations, because the amount is <br />considered non-hazardous and unregulatable, due to all the naturally-occurring uranium in the State. <br />It appears the biggest problem with waste rock is the potential long-term exposure to ionizing <br />radiation from Radium-226 (a decay product of Uranium 238/235). The DOE has taken the <br />position that normal reclamation techniques/requirements are a practical (and cost effective) <br />approach to clean up the uranium sites and minimize radiation impacts. The DOE recognizes there <br />is a potential to expose the general public to mining-related radioactive materials at these sites, but <br />feel it is often cost-prohibitive, if not entirely impossible, to totally eliminate the radioactive <br />materials from the environment. It is DOE's policy to minimize the potential exposure b.r requiring <br />the operators to: 1) conduct a cursory radiological scan of the entire mine site, 2) t~ackfill the <br />materials of greatest concern into the existing mine openings and portals, and 3) cover thy; disturbed <br />areas with any immediately available topsoil. <br />EFN's latest submittal was interesting but did not adequately demonstrate that the waste :rock at the <br />two mine sites does not have sufficient quantities of toxic-forming materials to advert>ely affect <br />human health or the environment. EFN argues that these mine sites do not pose a significant risk <br />and that the existing permit requirements are adequate to protect public health and the environment. <br />However, except for the statement that "the rocks contain low levels of naturally occurring <br />uranium", the company did not submit any data regarding the types and concentrations of <br />contaminants (toxic-forming materials) that exist at the mine sites. EFN claims that collection and <br />analysis of detailed data concerning concentrations of potential contaminants are not required, since <br />the low levels of uranium do not pose a significant risk to public health, etc.. <br />I suggest the Division notify EFN that they have not demonstrated to the Division's satisfaction that <br />a DMO exemption is warranted for these two mine sites. <br />M:\gew\ma\Sunday.jd <br />