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~~ INTEROFFICE MEMORANDUM DMSlON OF MINERALS AND GEOLOGY TO: H. Bruce Humphri(~es, James Stevens FROM: James Dillit: ~..lc' I. DATE: November 15. 1996 ~ III IIIIIIIIIIIIIIII RE: Recommendation for an Exemption of DMO Status, West Sunday Mine, Permit No. M-81-021 and Sunday Mine, Permit No. M-77-285 After reviewing the attached Einergy Fuels Nucleaz, Inc. report involving test results of the waste dumps at the referenced mine sites it is my recommendation that the Division exempt these sites from DMO status pursuant to Rule 7.2.6. As defined in Rule 1.1(14), a designated mine operation means a mining operation at which: (a) designated chemicals used in metallurgical processing aze present on-site; or (b) toxic or acid- forming materials will be exposed or disturbed as a result of mining operations; or (c) acid mine drainage occurs or has the potential to occur due to mining or reclamation activities. The referenced mines do not use designated chemicals, have not disturbed or exposed acid-forming materials, and do not have acid mine drainage. The Division determined that ilte referenced mines had a reasonable potential to be a Designated Mining Operations since then: was a possibility that toxic-forming materials were exposed or disturbed as a result of minim; operations. The operator disputed the designation and proposed to demonstrate to the satisfaction of the Division that toxic-forming materials have not been exposed or disturbed in quantities sufficient to adversely affect human health, property or the environment. The operator and Division agreed that the only possible problem at these sites was the potential for long-term exposure to ionizing radiation from Radium-226 (a decay product of Uranium 238/235). The Division decided that a .OS% concentration of U308, or greater, would be considered toxic. The decision to use .OS% U308 as a standard of toxicity was based on the following; 1) the Department of Health, Radiation Control Division, exempts uranium concentrations of less than .OS % from their regulations b~~cause the amount is considered non-hazardous and unregulatable due to all the naturally-occurring uranium in the State, 2) the Department of Energy has determined that if an individual camped on one of the waste dumps for 24 hours a day for 14 days the Total Effective Dose ]Equivalent (TEDE) resulting from the exposure would be less than the NRC standard of 100 mrem/yr: which is considered the maximum allowed exposure to radiation and 3) the Bureau of Land Management has determined that uranium concentrations less than .OS % are non-hazazdous. However, in order to minimize the potential exposure to ionizing radiation, both the I)OE and BLM require the operators to: A) conduct a cursory radiological scan of the entire mine site at closure, B) bacld"ill the materials of greatest concern