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' 'MEMO to B. Humphries/J. ~4ens • ' June 11 1996 - EFN's DMO Determinations Page 3 May 19, 1995) to the Division in support of their argument. The DOE report presented a scenario where an individual camps on a mine-rock waste pile for 24 hours a day over a 14-day period. The Total Effective Dose Equivalent (TEDE) resulting from exposure was calculated to be 79 mrem/yr which is less than the NRC standard of 100 mrem/yr. The average value of 0.04 percent U,OH was used in the random dose calculations. This percentage was derived from historic data collected on DOE Lease Tract 13 which is located about 6 miles southwest of the Sunday/West Sunday mines. Without additional data, it is difficult to determine if the DOE scenario would apply to the Sunday/West Sunday mine sites, even though the DOE feels "the exposure value resulting from this scenario on Lease Tract 13 is considered representative of the amount of radiation an individual could be exposed to at any other lease tract, because of the physical similarities of all the mine sites and mine-rock waste piles". If the physical characteristics are the same, will the value of uranium be the same? Is there a direct corollary between the average valve of uranium and the TEDE? Does 0.04 percent, or greater, uranium constitute a quantity of toxic-forming material sufficient to adversely affect human health, property, or the environment, since it appears the TEDE could exceed NRC standards, if an individual is exposed for more than 14 days? Would less than 0.04 percent uranium mean there is not enough radioactivity to adversely affect human health, etc.? The Department of Health, Radiation Control Division, according to Tom Pentecost, has exempted uranium concentration of less than 0.05 percent from their regulations, because the amount is considered non-hazardous and urrregulatable, due to all the naturally-occurring uranium in the State. It appears the biggest problem with waste rock is the potential long-term exposure to ionizing radiation from Radium-226 (a decay product of Uranium 238/235). The DOE has taken the position that normal reclamation techniques/requirements are a practical (and cost effective) approach to clean up the uranium sites and minimize radiation impacts. The DOE recognizes there is a potential to expose the general public to mining-related radioactive materials at these sites, but feel it is often cost-prohibitive, if not entirely impossible, to totally eliminate the radioactive materials from the environment. It is DOE's policy to minimize the potential exposure by requiring the operators to: 1) conduct a cursory radiological scan of the entire mine site, 2) backfill the materials of greatest concern into the existing mine openings and portals, and 3) cover the disturbed areas with any immediately available topsoil. EFN's latest submittal was interesting but did not adequately demonstrate that the waste rock at the two mine sites does not have sufficient quantities of toxic-forming materials to adversely affect human health or the environment. EFN argues that these mine sites do not pose a significant risk and that the existing permit requirements are adequate to protect public health and the environment. However, except for the statement that "the rocks contain low levels of naturally-occurring uranium", the company did not submit any data regarding the types and concentrations of contaminants (toxic-forming materials) that exist at the mine sites. EFN claims that collection and analysis of detailed data concerning concentrations of potential contaminants are not rrquined, since the low levels of uranium do not pose a significant risk to public health, etc.. I suggest the Division notify EFN that they have not demonstrated to the Division's satisfaction that a DMO exemption is warranted for these two mine sites. M: \gaw\osa\SUnday.jd