40 CFR Part 192,  Subpart D
Standards for Management of Uranium
Byproduct Materials
EPA 402-R-93-085
                  TECHNICAL SUPPORT FOR
                AMENDING STANDARDS FOR
                 MANAGEMENT OF URANIUM
                  BYPRODUCT MATERIALS
          BACKGROUND INFORMATION DOCUMENT
                         Prepared for

              U.S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Radiation and Indoor Air
                      401 M Street, S.W.
                    Washington, B.C. 20460

                         October 1993

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                            DISCLAIMER
     Mention of any specific product or trade name in this report
does not imply an endorsement or guarantee on the part of the
Environmental Protection Agency.
                        LIST OF PREPARERS
     Various staff members from EPA's Office of Radiation and
Indoor Air contributed to the development and preparation of the
Background Information Document (BID).
Albert Colli
Chief, Air Standards and
Economics Branch
Reviewer
Byron Bunger
Economist
Writer/Reviewer
Fran Jonesi
Chief, NESHAPs Section
Reviewer
Gale Bonanno
Attorney Advisor
Reviewer
     An EPA contractor, S. Cohen & Associates, Inc. in McLean,
Va, provided significant technical support in preparation of the
BID.
                                11

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                             PREFACE


     The Environmental Protection Agency (EPA) is amending 40 CFR
192, Subpart D, dealing with disposal of uranium mill tailings at
non-operational sites licensed by the Nuclear Regulatory
Commission (NRC) or an Agreement State pursuant to the Uranium
Mill Tailings Radiation Control Act (UMTRCA) of 1978 (42 U.S.C.
2022, 7901-7942).

     This Background Information Document (BID) has been prepared
in support of the rulemaking proceedings for EPA's action.  This
BID only considers long-term disposal of tailings at facilities
licensed by the NRC or an Agreement State,  and designated as
Title II facilities in the UMTRCA.  Currently, the tailings at
these facilities are subject to the disposal and long-term
stabilization regulations developed under the UMTRCA by the EPA
and the NRC and set forth in 40 CFR 192, Subpart D.  In addition,
the standards at 40 CFR Part 61, Subpart T  (National Emission
Standard for Hazardous Air Pollutants) which would otherwise
apply to these sites, are currently stayed until EPA takes final
action on its proposal to rescind Subpart T or until June 30,
1994, whichever occurs first.

     Copies of this BID, in whole or in part, are available to
all interested persons.  An announcement of the availability
appears in the Federal Register.  For additional information,
contact Eleanor Thornton at (202) 233-9773  or write to:

     Director, Criteria & Standards Division
     Office of Radiation and Indoor Air (6602J)
     Environmental Protection Agency
     401 M Street, SW
     Washington, DC  20460
                               111

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                         TABLE OF CONTENTS
Disclaimer	
List of Preparers	
Preface	
List of Tables	    v
List of Figures	    ix


CHAPTER  1    BACKGROUND INFORMATION   	   1-1

         1.1  STATEMENT OF PURPOSE	1-1
         1.2  REGULATION OF URANIUM MILL TAILINGS	1-3
         1.3  THE 1989 CAA NESHAP STANDARDS AND THE
              CLEAN AIR ACT AMENDMENTS OF  1990	1-8

CHAPTER  2    INDUSTRY PROFILE   	   2-1

         2.1  DEMAND AND USES	2-1
         2.2  SUPPLY	2-7
         2.3  INDUSTRY STRUCTURE AND  PERFORMANCE   	   2-12
         2.4  ECONOMIC AND FINANCIAL  CHARACTERISTICS   ....   2-14
         2.5  INDUSTRY FORECAST  AND OUTLOOK  	   2-15
         2.6  EVALUATION OF FORECASTS AND  URANIUM
              MARKET DEMAND 	  .....   2-17

CHAPTER  3    BACKGROUND INFORMATION  FOR LICENSED  NON-
              OPERATING URANIUM  MILL  TAILINGS  IMPOUNDMENTS.  .   3-1

         3.1  OVERVIEW	3-1
         3.2  FACILITY-SPECIFIC  CHARACTERISTICS  	   3-3

CHAPTER  4    RADON-222 SOURCES, ENVIRONMENTAL TRANSPORT,
              and RISK COEFFICIENTS	4-1

         4.1  MILL TAILINGS:   ENVIRONMENTAL  SOURCE TERMS
              FOR RADON-222	4-1
         4.2  RADON-222 EXPOSURE PATHWAYS  AND  RISK TO
              HUMAN HEALTH	4-10

CHAPTER  5    70-YEAR RADON EMISSIONS FROM NON-OPERATIONAL
              TAILINGS IMPOUNDMENTS  AND HEALTH RISKS  TO
              NEARBY POPULATIONS  	   5-1

         5.1  THE 70-YEAR ASSESSMENT PERIOD  	   5-1
         5.2  PROTOCOL FOR ESTIMATING RADON  EMISSIONS ....   5-4
         5.3  RADON EMISSIONS  FROM NON-OPERATIONAL
              TAILINGS IMPOUNDMENTS  	   5-10
         5.4  POPULATION EXPOSURES AND HEALTH  RISKS  	   5-12
         5.5  MEASURED RADON EMISSION LEVELS	5-17
                                 IV

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                   TABLE OF CONTENTS (Continued)

CHAPTER  6    RADON-222 CONTROL TECHNIQUES  	   6-1

         6.1  INTERIM RADON CONTROL TECHNIQUES   	   6-1
         6.2  DEWATERING OF TAILINGS PILES IN PREPARATION
              FOR PERMANENT COVER	6-2
         6.3  LONG-TERM RADON CONTROL TECHNIQUES   	   6-3
         6.4  COMPARISON OF EARTH COVERS TO OTHER
              CONTROL TECHNIQUES  	   6-6

CHAPTER  7    COSTS AND BENEFITS	7-1

         7.1  THE COSTS AND BENEFITS OF RADON COVER IN
              PERSPECTIVE	7-1
         7.2  COSTS OF COVERING THE PILES	7-2
         7.3  COST OF VERIFYING RADON EMISSIONS	7-4
         7.4  COST SAVINGS DUE TO POSTPONING THE TIME
              OF COVER.	7-6
         7.5  COST SAVINGS AND RISK INCREASES COMPARED.  ...   7-6
         7.6  FINANCIAL BURDEN ON INDUSTRY	7-7
         7.7  REGULATORY FLEXIBILITY ANALYSIS 	   7-8

APPENDIX A.   CAP88-PC INFORMATION SHEETS  	   A-l

APPENDIX B.   SYNOPSIS REPORT FOR LUCKY Me MILL	B-l

REFERENCES	R"1

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                          LIST OF TABLES
CHAPTER 2:
        2-1  Status of U.S. Nuclear Power Plants as of
             December 31, 1990	  2-3

        2-2  Commitments for Delivery of Uranium From
             Domestic Suppliers to U.S. Utilities:
             1990-2000 and Later	2-4
        2-3  Origin of Uranium Committed for Delivery
             to U.S. Utilities from Domestic Suppliers:
             1990-2000 and Later, as of Dec. 31, 1990
 2-5
        2-4  Exports of Uranium by Utilities and
             Domestic Suppliers: 1967-2000 and Later, as
             of Dec. 31, 1990	2-6
        2-5  Production of Uranium Concentrate by
             Conventional Mills and Other Sources:
             1953 through 1990 (Tons U3O8  ....
        2-6  Uranium Mill Capacity (Tons of Ore Per Day)
2-8

 2-9
        2-7  Imports of Uranium for Commercial Uses:
             1975-1990	2-10
        2-8  U.S.  Commercially-Owned Uranium Inventories
             as of December 31,  1988, 1989 and 1990  .  .
 2-12
        2-9  Capital Expenditures,  Employment,  and
             Active Mills:  Conventional Uranium Milling
             Industry	2-13

        2-10 Comparison of  Uranium Projections: U.S.  Uranium
             Requirements,  Domestic Production, and Net
             Imports (Million Pounds U3O8)	    2-17

        2-11 Employment in  the U.S. Uranium Industry
             Under Current  Market Conditions:  1975-2005
             (Person-Years)   	 .....  2-18
        2-12  Projected U.S.  Nuclear Power Capacity and
             Uranium Requirements (Million Pounds U3O8)
 2-20
        2-13  U.S.  Reasonably Assured Resources (RAR)  by
             State and by Mining Method,  as of
             December 31,  1990	2-22
                               VI

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                    LIST  OF  TABLES  (Continued)
CHAPTER 3:
        3-1  1992 Status of Non-Operational Tailings
             Impoundments Identified in the Memorandum of
             Understanding (MOU) 	  3-2


CHAPTER 4:

        4-1  Radon-222 Decay Product Equilibrium Fraction
             at Selected Distances from the Center of a
             Hectare Tailings Impoundment  	  4-9

        4-2  Past Risk Estimates for Exposure to
             Radon Progeny	4-15

        4-3  BEIR IV Risk Model - Lifetime Exposure and
             Lifetime Risk	4-20

        4-4  Estimated Lung Cancer Risk from Radon
             Progeny Exposure for Three Miner Cohorts  ...  4-20

        4-5  Lifetime Risks of Lung Cancer Death from
             Radon Daughter Exposure (per 106 WLM)	   4-24

        4-6  Lifetime Risk from Excess Radon Daughter
             Exposure (Adjusted for a Background Exposure
             of 0.25 WLM/yr)	4-26

        4-7  Summary of K Factors for Bronchial Dose
             Calculated for Normal People in the General
             Environment Relative to Healthy Underground
             Miners	4-28


CHAPTER 5:

        5-1  Assessment Period for Non-Operational
             Tailings Impoundments 	  5-3

        5-2  1992 Status of Non-Operational Tailings
             Impoundments  	  5-5

        5-3  Coefficient b Values for Select Soil Types
             and Moisture Content  	  5-6

        5-4  Summary of Emissions for the Pathfinder-
             Lucky Me Facility	5-10
                               Vll

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                   LIST OF TABLES  (Continued)

        5-5  Radon Emissions for Non-Operational
             Impoundments  	  5-11

        5-6  Radon-222 Exposures and Associated Risks
             for MOU Disposal Schedule	5-16

        5-7  Radon-222 Exposures and Associated Risks
             for Baseline Emissions  	  5-18
CHAPTER 7:
        7-1  Facility-Specific Release Rates, Cover Depths,
             and Areas	-	7~3

        7-2  Costs of Achieving the Regulatory Emission
             Standards (1991 $, Million)	7-5

        7-3  Present Value Costs to Cover by MOU Target
             Dates (Millions of 1991 Dollars)	7-6
                               viii

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                         LIST OF FIGURES
CHAPTER 4:
        4-1  Uranium-238 Decay Chain and Half-Lives of
             Principal Radionuclides 	
4-2
        4-2  Radon Emanation Process 	  4-3

        4-3  Effect of Pile Depth on Hyperbolic Tangent
             Term in Radon-222 Flux Equation	4-5
CHAPTER 5:
        5-1  Changes in Radon-222 Penetration With Earth
             Cover Thickness . . 	
5-7
                                IX

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                             CHAPTER 1

                       BACKGROUND  INFORMATION
1.1  STATEMENT OF PURPOSE

     Uranium mill tailings refer to the wastes that result from the
processing of ores to recover uranium.  Since commercially-
processed uranium ores in the United States typically contain 0.05
to 0.2 percent uranium, virtually the entire ore throughput of
milling becomes tailings waste.  Historically, uranium mill tail-
ings have been stored in large surface impoundments, or piles, in
quantities ranging from less than one million tons to over 30
million tons.  These impoundments cover areas from seven to over
three hundred acres.

     Tailings emit radon gas, a radioactive decay product of
uranium.  Since tailings impoundments often have large unprotected
surface areas, the exposure to radon-222 is a health concern.
Under the authority of the Uranium Mill Tailings Radiation Control
Act (UMTRCA) and the Clean Air Act (CAA), the U.S. Environmental
Protection Agency (EPA), the Department of Energy (DOE), and the
Nuclear Regulatory Commission (NRC) have devised and implemented
controls to limit risks from the milling of uranium ores during
both the active period of operations and the closure/disposal
phase, when active milling of ore has ceased.

     This Background Information Document (BID) only considers
long-term disposal of tailings at facilities licensed by the NRC or
an Agreement State, and designated as Title II facilities in the
UMTRCA.  Currently, the tailings at these facilities are subject to
the disposal and long-term stabilization regulations developed
under the UMTRCA by the EPA and the NRC and set forth in 40 CFR
192, Subpart D and 10 CFR 40, Appendix A.

     As discussed in the sections that follow, the EPA initially
promulgated regulations in 1983 under the UMTRCA that established
generally applicable environmental standards for both radiological
and non-radiological contaminants.  The NRC subsequently developed
specific licensing and design criteria to implement the EPA's
standards for Title II sites.  In 1989, under the authority of the
CAA, the EPA promulgated National Emission Standards for Hazardous
Air Pollutants (NESHAPs), 40 CFR 61, Subpart T, which address only
the emission of radon-222 from the disposal of tailings.  Subpart T
requires that a radon barrier capable of limiting emissions to an
average of 20 pCi/m2-s  be  installed within two years of the promul-
gation date of the NESHAPs or two years from cessation of opera-
tions, which ever is later.  Subpart T also requires that a one-
time emission test be performed to assure that the design objective
                                1-1

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of 20 pCi/m2-s  for the radon barrier  has  been  achieved.   In promul-
gating Subpart T, the EPA found that the regulations established
under UMTRCA did not set specific deadlines for disposal; therefore
a NESHAPs was required to achieve radon-222 emissions at levels
consistent with protection of the public's health with an ample
margin of safety.

     In its review of the EPA's Subpart T NESHAPs, the NRC ex-
pressed concerns regarding the duplication of the UMTRCA require-
ments.  In response to the concerns regarding duplication. Congress
amended the CAA prior to its reauthorization in 1990.  This amend-
ment gives the EPA the authority to amend the CAA to avoid duplica-
tive regulation while still protecting public health with an ample
margin of safety.  Under the authority of this amendment, and after
consultations with the NRC and affected Agreement States, the
Administrator has undertaken the following actions:

     •    Stayed the NESHAPs (40 CFR 61, Subpart T) as it applies
          to the Title II uranium mill tailings (NRC- or Agreement
          State-licensed) until the date on which the rulemakings
          discussed below have been completed (or June 30, 1994,
          whichever occurs first)

     •    Proposed to rescind 40 CFR 61 Subpart T as it applies
          to Title II facilities

     •    Published an Advanced Notice of Proposed Rulemaking to
          amend its UMTRCA regulations (40 CFR 192, Subpart D) to
          require emplacement of radon control barriers at cur-
          rently non-operational impoundments by specified dates
          and at operational impoundments within seven years of
          cessation of operations, and to require one-time test-
          ing of the radon barriers to assure that the design
          flux has been attained.

     This Background Information Document provides information in
support of these rulemakings.  This chapter provides a historical
summary of mill tailings regulations under the UMTRCA and CAA,
details of the possible rescission of 40 CFR 61, Subpart T, and
the amendment of 40 CFR 192, Subpart D.  Chapter 2 of this BID
provides a profile of the uranium milling industry and an assess-
ment of its economic status.  Past operational information and
the current status of the non-operational impoundments are
presented in Chapter 3.  Radon sources, environmental transport,
and risk coefficients are developed in Chapter 4.  Chapter 5
summarizes the exposures and health risks to nearby populations
from non-operational tailings impoundments.  Chapters 6 and 7
discuss radon control techniques and provide cost estimates for
the emplacement of an earthen cover that will reduce radon emis-
sions to regulatory standards.
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1.2  REGULATION OF URANIUM MILL TAILINGS

1.2.1  UMTRCA Authorities

     The Atomic Energy Act of 1954 gave the Atomic Energy Commis-
sion (AEC) authority to license and regulate source material
(uranium and thorium) processed at uranium mills.  However, once
a mill stopped operating, the AEC had no authority to regulate
the tailings piles that remained.  One result was that some
tailings were used in the 1960s as fill around foundations of
houses, causing high indoor radon concentrations.  The 1976
Resource Conservation and Recovery Act (RCRA) gave EPA the
authority to place controls on mill tailings, if EPA considered
them hazardous.  However, in 1978 Congress passed UMTRCA (P.L.
95-604, 42 USC 2022, 7901-7942), which gave the EPA the authority
to regulate mill tailings for the purpose of protecting the
public from radon and other exposure pathways.

     UMTRCA set up two programs to protect public health and the
environment from mill tailings hazards.  Both programs required
EPA to set standards for disposal of tailings; the other agencies
involved were required to implement those standards.  The "Title
I" program directed the Department of Energy  (DOE) to remediate
the tailings at inactive (generally abandoned) uranium mill sites
that did not have an effective AEC or NRC license as of January
1, 1978.  The "Title II" program was for "active" sites licensed
by the NRC or an Agreement State.  EPA standards for these sites
were to cover final disposal of the tailings, including radon
control after the mill closed, and to be consistent with stan-
dards for wastes promulgated under the RCRA.  UMTRCA directed EPA
to set standards for Title I sites within one year and standards
for Title II sites within 18 months of enactment.

1.2.2  EPA's UMTRCA Rulemakings

     On April 22, 1980, EPA proposed cleanup  standards for Title
I sites, covering open lands and buildings contaminated with
residual radioactive materials from uranium processing (to be
codified in 40 CFR 192, Subpart A).  These were made immediately
effective as interim standards pending public review and promul-
gation of final standards (45 FR 27370 and 27366).  On January 9,
1981, EPA proposed disposal standards for Title I sites (46 FR
2556), and on January 5, 1983, EPA promulgated final rules for
the disposal and cleanup of the Title I sites (48 FR 605).

     About this time Congress amended UMTRCA.  PL 97-415, passed
in January 1983, included a provision that would strip EPA of its
standard-setting authority if EPA did not set standards for Title
II sites by September 30 of that year.  In response, EPA proposed
general environmental standards for Title II  uranium and thorium

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mill tailings sites on April 29, 1983 (48 FR 19584) and promul-
gated final rules on September 30 (48 FR 45926, codified in 40
CFR 192, Subparts D and E).

     Both the UMTRCA Title I and Title II standards were chal-
lenged in the Tenth Circuit Court of Appeals by several parties
in thirteen separate suits filed in 1983 and 1984  (56 FR 67570
lists the case numbers of these suits).  In September of 1985,
the court upheld all provisions of the standards, as promulgated,
except those dealing with groundwater protection at Title I
sites.  The court directed EPA to promulgate groundwater stan-
dards for Title I sites similar to those for Title II sites.  EPA
proposed new ground water regulations to replace those set aside
on September 24, 1987 (52 FR 36000).  Promulgation of the final
standards is awaiting the Office of Management and Budget's
review.  Groundwater protection standards are not the focus of
these proposed rulemakings.

     For Title II sites, the EPA's UMTRCA standards reguire, in
part, that management of byproduct materials (tailings) during
operations and prior to the end of the closure period be consis-
tent with the standards set forth in 40 CFR 190.  However, 40 CFR
190 does not address the doses caused by radon and its decay
products, nor does it establish a numerical limit for radon
emissions from the tailings piles.  Instead, it reguires that
radon emissions be kept as far below Federal Radiation Protection
Guides as is practicable.

     EPA's UMTRCA standards established a design standard limit-
ing radon emissions from the tailings piles that have been closed
to an average not exceeding 20 pCi/m2-s.  These standards  also
provided for the long term stability of the piles, reguiring that
the radon barrier be effective for 1000 years to the extent
reasonably achievable, but in any event for at least 200 years.

1.2.3  NRC's UMTRCA Rulemakinqs

     UMTRCA placed reguirements on NRC as well as on EPA.   NRG
proposed rules implementing the AEA, as amended by UMTRCA, for
uranium mill tailings and for construction of major plants on
August 24, 1979 (44 FR 50015).  On the same date, NRC also
promulgated final regulations (with reguest for public comments)
for uranium mill tailings licensing (44 FR 50012).  On October 3,
1980, NRC promulgated final rules that specified licensing
reguirements for uranium and thorium milling (45 FR 65521).

     The January 1983 Congressional amendments to UMTRCA that
reguired EPA to issue regulations for Title II sites, in turn,
caused the NRC to suspend, on May 26, 1983, portions of their
rules (48 FR 23649).  NRC licensees could have incurred signifi-
cant costs to implement the NRC standards,  had the NRC not
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modified  its standards to conform with those issued by EPA, as
UMTRCA required.  On November 26, 1984, NRC proposed rules that
would conform  its requirements to EPA's standards  (49 FR 46418).
Since these proposed rules excluded EPA groundwater protection
standards, the NRC also issued, on the same date,  a notice of
proposed  rulemaking to incorporate the groundwater and other
provisions of  EPA's 40 CFR 192, Subpart D standards into NRC
standards (49  FR 46425).  In various other actions in 1985, 1986,
and 1987, NRC  proposed and promulgated rules that  incorporated
all EPA standards for UMTRCA Title II mill tailings sites  (50 FR
41852, 51 FR 24679, and 52 FR 43562).  Thus, by November of 1987,
the NRC's standards under UMTRCA were fully compatible with those
promulgated by the EPA.

1.2.4  Clean Air Act Rulemakings

     When Congress amended the Clean Air Act in 1977, it specifi-
cally addressed emissions of radioactive materials.  Before that
time, emissions of radionuclides either were regulated under the
Atomic Energy  Act or were not regulated at all.  Section 112 of
the Clean Air  Act required the EPA Administrator to determine,
after public notice and opportunity for public hearings (44 FR
21704, April 11, 1979), whether emissions of radionuclides cause
or contribute  to air pollution that may reasonably be expected to
endanger  public health.  In December of 1979, the  EPA published a
notice in the  Federal Register listing radionuclides as hazardous
air pollutants under Section 112 of the Clean Air  Act (44 FR
76738, December 27, 1979).  This determination was supported by a
technical report issued by the EPA detailing emission levels,
applicable effluent controls, and the radiological impacts caused
by airborne radioactive effluents released by various source
categories of  facilities (EPA79).

     In June of 1981, the Sierra Club filed a suit alleging that
the Clean Air Act required the EPA to propose standards for
radionuclides within 180 days of listing them as hazardous
pollutants under Section 112.  The court agreed with the Sierra
Club and  in September of 1982 ordered the EPA to publish proposed
emissions standards for radionuclides,  with notice of public
hearing within 180 days of that order.

     In April of 1983, the EPA proposed radionuclides emission
standards for four source categories:  DOE facilities; NRC-
licensed and non-DOE Federal facilities; underground uranium
mines; and elemental phosphorus plants.   The Agency also deter-
mined that emissions from several other source categories did not
require regulations:   coal-fired boilers;  the phosphate industry;
other mineral extraction industries;  uranium fuel cycle facili-
ties; uranium mill tailings;  high-level radioactive waste facili-
ties; and low energy accelerators (48 FR 15077, April 6,  1983).
The Agency prepared a draft background information document in
support of these decisions (EPA83).

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     After several extended comment periods and two public
hearings, the Sierra Club again filed suit in February of 1984 to
compel the EPA either to make the standards final or to determine
that radionuclides are not hazardous air pollutants and "delist"
them.  In August of that year, the court ordered the Agency to
take final action by October 23, 1984.  In response to that
order, the EPA withdrew the proposed standards for elemental
phosphorus plants, DOE facilities, and NRC licensees, finding the
control practices used for these source categories already
protective of public health.  The proposed standard for under-
ground uranium mines was also withdrawn, but with the intent to
set a different standard.  The Agency also announced its inten-
tion to regulate radon-222 emissions from licensed uranium mills
and reaffirmed its decision not to regulate emissions from
coal-fired boilers, the phosphate industry, other extraction
industries, uranium fuel cycle facilities, and high-level radio-
active waste.  Phosphogypsum stacks would be studied to determine
whether a standard was needed.

     In December 1984, the court ordered the EPA either to issue
final standards for the original four source categories or delist
radionuclides.  The Agency then promulgated NESHAPs for elemental
phosphorus plants, DOE facilities, and NRC-licensed facilities
(50 FR 7280, February 6, 1985).  Two other NESHAPs established
work practice standards to control radon emissions from under-
ground uranium mines  (50 FR 15385, April 17, 1985) and licensed
uranium mill tailings  (51 FR 34056, September 24, 1986). These
standards were again challenged in court.

     While these suits were being adjudicated, the U.S. Court of
Appeals for the D.C. Circuit found that the EPA's NESHAPs for
vinyl chloride was defective because the Agency had considered
costs and technological feasibility without first making a
determination based only on health risk.  The court proposed a
two-step process as one means  for the Administrator to establish
NESHAPs that met the Congressional intent of safe with an ample
margin of safety.  As a first  step, a level that would be deemed
acceptable is established based solely  on consideration of the
health risks imposed by that  level.   Once an acceptable level of
emissions is determined, the  ample margin of safety  is addressed
by evaluating all  relevant  factors including technical feasibili-
ty of controls, cost of controls, etc.

     The court  also ordered the EPA to  examine the effect of the
vinyl chloride  decision on  other  standards.  Concluding that
costs had been  considered in  many of  the  radionuclide rule-
makings, the Agency asked the court to  let  those NESHAPs remain
in place while  it reconsidered them and all other  issues raised
in the  lawsuits.
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     In early December 1987, the court accepted the EPA's propos-
al to reconsider all the NESHAPs using this two-step approach and
established a time schedule requiring the Agency to propose
decisions for all radionuclide source categories within 180 days
and make final decisions within 360 days.  This schedule was
later modified to require proposed regulatory decisions by
February 28, 1989, and final action by August 31, 1989.

     On March 7, 1989, the EPA published proposed NESHAPs that
described four possible policy approaches for regulating emis-
sions of radionuclides (54 FR 9612).   Public hearings were held
in April.  On July 14, 1989, the court extended the deadline for
final action until October 31, 1989.   The NESHAPs were made final
on that date and most, including Subpart T, became effective on
December 15, 1989, when they were published in the Federal
Register (54 FR 51654).

     In establishing the final radionuclide NESHAPs for each
source category, the EPA adopted three risk criteria as central
to the determination of acceptable levels of emissions and in its
determination of the ample margin of safety:

     •    Maximum Individual Risk  (MIR) - the maximum additional
          risk of any individual member of the public contracting
          fatal cancer from exposure to radioactive materials
          released to the air from any facility that is part of
          the source category.  In evaluating the MIR, the EPA
          calculates a 70-year lifetime risk to an individual
          assuming that the level of emissions is constant
          throughout the persons entire life.  The EPA considers
          that a risk to the maximum exposed individual of ap-
          proximately one in ten thousand (1E-4) is presumptively
          acceptable.

     •    Risk Distribution - an estimate of how many persons
          exposed to the airborne effluents from the facilities
          that comprise a given source category are at a given
          level of individual risk.  In evaluating the risk
          distribution, the EPA assesses the doses to all indi-
          viduals within 80 kilometers of any facility in the
          source category.  The Agency's goal is to assure that
          as many persons as possible are at a lifetime risk of
          less than one in one million (1E-6).

     •    Incidence - an estimate of the health impact on the
          entire population within a given area from exposure to
          a facility's emissions.  The EPA considers no more than
          approximately 1 fatal cancer per year caused by all
          facilities in the source category to be acceptable.
                               1-7

-------
     These criteria are not absolute, but serve as guidelines
that the EPA considers along with other factors which may be
unique to each source category.

     In establishing the NESHAPs for disposal of uranium mill
tailings (40 CFR 61, Subpart T), the Administrator found that
emissions of radon-222 which meet the UMTRCA design criterion of
20 pCi/m2-s  averaged over  the  entire disposal  area represents  a
level that is safe with an ample margin of safety.  By promulgat-
ing the NESHAP, the Administrator assured that final disposal
would be achieved as expeditiously as possible.  The monitoring
of emissions after construction of the radon barrier, but prior
to final stabilization, was to assure that the design objective
of 20 pCi/m2-s  was  indeed  achieved.

1.3  THE 1989 CAA NESHAP STANDARDS AND THE CLEAN AIR ACT
     AMENDMENTS OF 1990

     On December 15, 1989, the Environmental Protection Agency
(EPA) promulgated National Emission Standards for Hazardous Air
Pollutants  (NESHAPs) under Section 112 of the Clean Air Act
(CAA).  These standards regulated radionuclide emissions to the
ambient air from several source categories, inclusive of non-
operational uranium mill tailings sites.  These sites are also
regulated under the Uranium Mill Tailings Radiation Control Act
(UMTRCA).  The UMTRCA separated these sites into  (1) inactive and
abandoned sites controlled by the DOE (Title I sites) and (2)
tailings sites licensed and regulated by the Nuclear Regulatory
Commission  (NRC) or an Agreement State  (Title II sites).

     The NESHAPs for licensed, but non-operational uranium mill
tailings sites, Subpart T of 40 CFR 61, specifies that once a
uranium mill tailings pile or impoundment ceases to be operation-
al, it must be disposed of and brought into compliance with the
radon emission standard (not greater than 20 Pci/m2-s)  within two
years.  For impoundments that were non-operational at the time of
rulemaking, this meant emplacement of an earthen cover had to be
completed by December 15, 1991 to meet the standard.  In addition
to specifying a time for closure and emission limits, Subpart T
also requires specific monitoring and record keeping.

     The UMTRCA regulations, as implemented by the NRC, specify a
design flux that must be met for 1000 years.  This flux is
identical to the emission standard in Subpart T, but UMTRCA cur-
rently establishes no time limits for disposal of the piles.  The
UMTRCA standards also do not require monitoring to confirm that
the design flux limits have been achieved.

     Although the NESHAPs and UMTRCA complement each other, they
create dual regulatory oversight, including independent procedur-
al requirements seeking to ensure compliance with the common 20
                               1-8

-------
pCi/m2-s flux standard.  Concern over the duplication and compli-
cation  created by the  two regulations resulted  in petitions  by
the NRC and the American Mining Congress, which urged the  EPA to
reconsider its position.

     Congress, in response to  its own concerns  over the dual
authority established  by the UMTRCA and  CAA regulations, substan-
tially  amended the CAA in 1990.  As part of that enactment,
section 112(d)(9) was  added to the statute.  It states the
following:

     "No standard for  radionuclide emissions from any cate-
     gory or subcategory of facilities licensed by the
     Nuclear Regulatory Commission (or an Agreement State)
     is required to be promulgated under this section if the
     Administrator determines, by rule,  and after consulta-
     tion with the Nuclear Regulatory Commission, that the
     regulatory program established by the Nuclear Regulato-
     ry Commission pursuant to the Atomic Energy Act for
     such category or  subcategory provides an ample margin
     of safety to protect the  public health."

     This provision strives to eliminate duplicative regulations
by the  EPA and the NRC and preserve governmental resources.

     Moreover, Congress expressed sensitivity to the special
compliance problems of uranium mill tailings sites through new
section 112(i)(3).  This section provides an additional three-
year extension to mining waste operations (e.g., uranium mill
tailings)  if the four  years allowed (including  a one-year  exten-
sion) for compliance with standards promulgated under the  amended
section 112 is insufficient to dry and cover the mining waste.

     The result is that the EPA, NRC, and affected Agreement
States  have consulted  and drafted a Memorandum of Understanding
(MOU).  The primary purpose of the MOU is to ensure that the
nineteen non-operational uranium mill tailings piles licensed by
the NRC or the affected Agreement States achieve compliance
through an effective installation of an  earthen cover that limits
radon emissions to the  20 pCi/m2-s flux standard as defined in 40
CFR 192.32(b)(1).  A second objective of the MOU was to ensure
that compliance proceeds as expeditiously as practicable consid-
ering technological feasibility.  Target dates for the nineteen
non-operational uranium mill tailings piles were established for
meeting the radon emission standard;  the target dates are based
on a guiding objective that disposal occur by the end of 1997 or
within seven years of when the existing  operating and standby
sites enter disposal status.
                               1-9

-------

-------
                             CHAPTER 2

                          INDUSTRY  PROFILE

     The U.S. uranium milling industry is an integral part of a
domestic uranium production industry that includes companies
engaged in uranium exploration, mining, milling, and downstream
activities leading to the production of fuel for nuclear power
plants.  The product of uranium milling is uranium concentrate,
also referred to as uranium oxide,  yellowcake, or U3O8.

2.1  DEMAND AND USES

     Domestic producers of uranium concentrate have two markets:
the U.S. nuclear power industry and exports.  The nuclear power
industry is by far the more important of the two.  Military uses,
once the only source of demand for uranium, have been supplied
solely by government stockpiles since 1970  (DOESVa).

     Demand for domestically produced uranium reached its highest
level in 1979 when utilities delivered 30.9 million pounds of U3O8
to DOE for enrichment, but has fallen since then.  By 1990 less
than 15 million pounds of domestic U3O8 were sent to DOE for enrich-
ment.  Domestic production reached its highest level in 1980 and
has steadily declined since then.  Exports also have declined
substantially.  Exports of uranium by domestic suppliers in 1990
totaled 2.0 million pounds, slightly less than the 2.1 million
pounds in 1989 and less than one-third of total exports in 1978,
the year of highest exports (DOE91b).

     A number of negative forces have combined to cause the current
depressed state of the industry.  The boom of the 1970's along with
high expectations for the 1980's, encouraged large scale domestic
and foreign exploration.  The discovery of low cost foreign re-
serves, coupled with relaxed restrictions on imports effectively
priced the domestic sources out of the market.  Expectations are
that a growing portion of utility requirements will be supplied by
foreign-origin uranium during the second half of this decade.
Further exacerbating the downturn in domestic production is the
slow growth in overall demand for electrical power and the slower
than anticipated expansion of nuclear energy as power source for
generating electricity.  Growth also has been hindered by delays in
completing construction of new plants and by the cancellation of
projected construction  (DOE91a).

     Also contributing to the depressed state in the domestic
uranium industry are the large inventories of yellowcake, enriched
uranium and fabricated fuel being held by both producers and
utilities.  These inventories accumulated because utilities,
anticipating a growing need for uranium a decade or more ago,
entered into long-term contracts to purchase large amounts of
                                2-1

-------
domestically produced uranium.  As actual needs fell short of
expected needs due to nuclear power plant construction delays and
cancellations, large inventories accumulated.  These inventory
supplies were once estimated to cover four to five years of utility
requirements, and they adversely affected suppliers in two ways:
Primarily, they served to extend the downturn in uranium demand for
a number of years by decreasing the need for utilities to enter
into new contracts.  In addition, high interest rates in the 1980s
increased inventory holding costs, leading some utilities to
contribute to the excess supply by offering inventory stocks for
sale on the spot market (EPA86).  By 1990, utilities had reduced
their inventories to three years of forward coverage (DOE91a).

     Provided below is a brief description of the historical uses
and demand for uranium in the United States.

2.1.1  Military Applications

     In the early 1950's,  the U.S. government's need for uranium
for defense uses far exceeded the world's production capability.  A
Federally funded production incentives program was then instituted.
The incentives program was so effective that the government phased
it out in the 1960's and terminated its purchase program in 1970.
The government still has sufficient stockpiles to meet military
requirements well into the future.

2.1.2  Nuclear Power Plants

     Since 1971, utilities, which use uranium as fuel for nuclear
power plants, have been virtually the only source of demand for
uranium production.  Commercial generation of nuclear powered
electricity began in 1957 with the operation of the first central
station reactor at Shippingport, Pennsylvania.  By the end of 1990,
111 nuclear reactors were licensed to operate in the United States,
with 99.6 gigawatts of net generating capacity (DOE91c).

     Demand for uranium by utilities may be directly linked to the
fuel requirements of currently operating or planned nuclear power
plants.  The status of U.S. nuclear power plants as of December 31,
1990 is shown in Table 2-1.  Because of the long lead times associ-
ated with the ordering, construction and permitting of nuclear
power plants, it is extremely unlikely that any additional orders
for new nuclear plants will result in operable capacity before 1998
(DOE87c).  Historical consumption data for utilities are not
available.  However, information on contract commitments between
suppliers and utilities, which constitutes a share of total utility
uranium consumption, is available.  Commitments for deliveries from
1990 to 2000 are listed in Table 2-2.  In 1990, utilities signed 49
uranium procurement contracts with domestic suppliers equal to 27
million pounds of uranium.  Thirty-eight contracts were based on
spot-market purchases and 11 were long-term contracts.  Although
these contracts are with domestic suppliers, not all of the uranium

                                2-2

-------
delivered will be  domestic in origin.   Domestic suppliers  import a
significant share  of uranium which they deliver to utilities.   The
origin of committed uranium for the years 1990  through 2000  are
given in Table 2-3.   In 1990, domestic suppliers delivered a total
of  20.5 million pounds of uranium to utilities,  30 percent of these
deliveries were foreign in origin.   Utilities and suppliers  ac-
counted for roughly equal shares  of 1990 imports.   The quantity of
deliveries from domestic suppliers is projected to decline markedly
by  2000.   By the end of 1990, market commitments for delivery in
1991  and beyond from domestic suppliers totaled 87.9 million
pounds.   Just more than 50 percent of that uranium has been  speci-
fied  as being of domestic origin  (DOE91b).  Over the same  period,
commitments from foreign suppliers for the same period totaled
137.3 million pounds.   For years  beyond 1990, the data show  that
utility commitments account for 84% of the total quantity  under
contract as of December 31, 1990.
 Table 2-1.  Status of U.S. Nuclear Power Plants as of December 31, 1990


 Status                         Number of Reactors
               Net Summer
            Capability  (GWe)
 Operable*

 In Commercial Operation**

   In Power Ascension

     Total

 In Construction

   In Low-Power Testing

   Under Construction

   Indefinitely Deferred***

     Total

 Total
111

 0

111



 0

 3

 5

 8

119
99.6

  0

99.6



  0

 3.4

 6.1

 9.6

109.2
Notes:
     Operable units or reactors are those that have been issued a full power
     license by the Nuclear Regulatory Commission.  Retired units are not
     included.  Shoreham received a possession-only license in June,  1991.
     Since the unit is not currently scheduled to operate,  it is not  included
     in the total for units in the construction pipeline or operable  units.

 **   Three Mile Island 2, Hanford-N, Fort St. Vrain, and Rancho Seco  are not
     included.

***    Includes Bellafonte 1 and 2, Perry 2, WNP1 and WNP3.


Source:  (DOE91c)
                                 2-3

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                                     2-4

-------
Table 2-3.  Origin of Uranium Committed for Delivery to U.S. Utilities From
           Domestic Suppliers:  1990 to 2000 and Later, as of Dec. 31, 1990
                          (Million Pounds U3O8)
Year of Delivery
1990*
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000 & Later
TOTAL
Origin
Domestic
14.3
6.7
6.4
6.4
6.4
6.3
5.3
3.5
2.4
1.7
1.8
61.3
of Committed
Unspecified
0.0
12.4
6.0
6.8
3.1
4.0
2.2
1.4
0.8
0.6
0.4
37.7
Uranium
Foreign
6.2
0.8
0.6
0.6
0.6
0.6
0.0
0.0
0.0
0.0
0.0
9.4
Total
20.5
19.9
13.0
13.8
10.1
10.9
7.5
4.9
3.2
2.3
2.2
108.4
 Notes:

   *  Actual deliveries



 Source:  (DOE91b) 	
2.1.3  Exports

     Exports  of  uranium by producers have  generally declined
since 1979.   In  1987,  they were at their lowest level since 1975,
but have grown slightly since 1987.  For 1990,  exports of-uranium
concentrate totaled 2  million pounds.  As  of December 31, 1990,
contracts were in place for exports of an  additional 17.5 million
pounds for 1991-2000 (DOE91b).  Exports of uranium by utilities
and domestic  suppliers for 1977-1990, as well as commitments  for
1991 through  2000 are shown in Table 2-4.   Since 1967, U.S.
companies have exported a total of 69.4 million pounds of uranium
concentrate equivalent.
                                2-5

-------
Table 2-4. Exports
1967 to
Year of Delivery
Actual Deliveries:
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
Subtotal
Commitments:
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Subtotal
TOTAL
of Uranium by Utilities and Domestic Suppliers
2000 and Later, as of December 31, 1990
(Million Pounds U3Og)
Annual Cumulative

1.4
1.6
1.0
4.2
0.4
0.2
1.2
3.0
1.0
1.2
4.0
6.8
6.2
5.8
4.4
6.2
3.3
2.2
5.3
1.6
1.0
3.3
2.1
2.0
69.4

2.0
2.5
2.6
2.6
2.3
2.0
1.3
1.1
1.1
0.0
17.5
86.9

1.4
3.0
4.0
8.2
8.6
8.8
10.0
13.0
14.0
15.2
19.2
26.0
32.2
38.0
42.4
48.6
51.9
54.1
59.4
61.0
62.0
65.3
67.4
69.4
—

71.4
73.9
76.5
79.1
81.4
83.4
84.7
85.8
86.9
86.9
—
—
Notes:
Figures for 1967-1981 represent exports by uranium producers only.
Source; (DOE91b)
                               2-6

-------
 2.2   SUPPLY

 2.2.1 Sources of Supply

      The uranium used to fuel nuclear reactors is supplied by
 domestic and foreign producers and inventories held by utilities.
 The role of each is described in the following sections.

 Domestic Production

      Table 2-5 shows trends in domestic production of uranium
 concentrate from 1953 to 1990, by state.  Total production was
 relatively constant at 10,500 to 12,500 tons per year until 1977,
 when  it began an increase that peaked in 1980 at 21,852 tons.
 Production has declined almost every year since, reaching only
 5,657 tons in 1985 and falling to 4,443 tons in 1990 (DOE91b).

      Coinciding with the overall decline in the domestic produc-
 tion  industry is a decline in the share of production represented
 by conventional mills.  Historically, conventional milling
 accounted for approximately 70 percent of U.S. production.
 However, by 1985, the conventional share of production had fallen
 to 54 percent.  It rose to 66 percent in 1986, but then declined
 again (DOE87b).  By 1990 conventional milling accounted for 52
 percent of total production (DOE91b).

     Although non-conventional methods of production are limited
 in the quantity of uranium concentrate they can produce, they
 produce it cheaply.  DOE has estimated that by the middle of
 1991, nearly two-thirds of domestic uranium was produced from two
 non-conventional methods, in-situ leaching and by-product recov-
 ery.  This shift has occurred because these non-conventional
 methods can produce low quantities of uranium cheaply.   The trend
 towards non-conventional methods is expected to continue in the
 near term, and is expected to account for nearly all production
 by 1993.

     The decline in domestic production by conventional methods
 has resulted in severe over capacity and mill shutdowns.  Milling
 capacity, which almost doubled between 1975 and 1980 when the
 price of uranium was high and optimistic demand forecasts stimu-
 lated investment in milling facilities,  once enjoyed a utiliza-
tion rate of 94 percent (EPA86).   In December 1986,  capacity
utilization was about 32 percent at operating mills,  and only 9
percent of the total .industry potential.   By December of 1990
 conventional mills were operating at a mere 7 percent of total
 available industry capacity.   The number of operating mills has
 also declined dramatically,  from 20 in 1981 to a low of two in
June 1985.  NUEXCO indicates that six mills operated in 1987,  but
the number was only two by the end of December 1990  (DOE91b).   In
terms of nonconventional milling,  at the end of 1990 there
                               2-7

-------
  Table  2-5.   Production  of  Uranium Concentrate by Conventional Mills  and  Other
                           Sources:  1953 Through 1990  (Tons U3O8)
  Year
New Mexico     Wyoming
                                           Texas
Utah     Colorado    Others	Total
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
—
847
2,891
2,534
3,604
6,772
7,760
7,750
7,293
5,512
4,747
4,591
5,076
5,933
6,192
5,993
5,771
5,305
5,464
4,634
4,951
5,191
6,059
6,779
8,539
7,423
7,751
6,206
3,906
2,550
1,458
692
926
1,166
1,130
1,152
306
—
—
—
—
1,247
1,675
2,770
2,823
3,055
2,566
2,216
2,097
2,248
2,667
2,873
3,063
3,654
3,487
4,216
5,159
3,767
3,447
4,046
4,990
5,329
5,452
6,036
4,355
2,521
2,630
1,560
1,214
317
284
1,004
804
684
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
*
*
*
*
2,651
3,408
3,141
2,131
1,650
1,310
1,084
1,293
1,358
1,403
1,470
916
214
180
454
1,222
3,291
3,822
3,535
3,034
2,954
3,188
3,080
2,063
1,510
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
940
1,239
1,483
1,726
1,966
2,917
3,278
3,117
2,951
2,652
2,134
1,800
1,290
1,423
1,340
1,614
1,678
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
—
—
9
181
—
119
691
847
979
956
870
820
925
1,020
954
1,842
1,313
1,689
925
3,480
3,481
3,220
3,442
2,810
2,962
2,642
3,170
4,618
3,210
4,657
5,535
4,876
3,750
3,113
2,667
4,768
4,504
4,159
3,343
2,537
1,163
1,600
2,784
5,958
8,482
12,437
16,239
17,637
17,348
17,008
14,217
11,846
10,442
10,589
11,253
12,368
11,659
12,905
12,273
12,900
13,235
11,528
11,600
12,747
14,939
18,486
18,736
21,852
19,237
13,434
10,580
7,441
5,657
7,304
7,312
7,696
6,769
4,443
Notes:
--  No production
*   Individual  state production aggregated with "others".
Source: Personal Conmunication, Mining and Mineral Division, New Mexico Energy, Mineral and Natural Resources
Department.
     U.S. and comparative New Mexico data from U.S. Department of Energy,  1979-1982;
     New Mexico data from Mining and Minerals Division, New Mexico Energy, Minerals
     and Natural Resource Department for 1983-1990;
     Non-New Mexico data from Energy Information Administration for 1983-1990;
     Texas recovery for 1986-1987 included unspecified quantity of U308 milled from
     New Mexico ore.
                                              2-8

-------
were 3 phosphate and 2 in-situ mills in operation.  They produced
4.2 million pounds of uranium concentrate, 1.4 million pounds
less than in 1989.  Uranium mill capacities and utilization
levels are listed in Table 2-6.


                Table 2-6.  Uranium Mill Capacity
                            (Tons of Ore per Day)
Year
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
Total
Capacity
54,050
55,050
51,650
48,450
47,250
42,650
34,650
30,600
30,600
30,600
Operating
Capacity
49,800
33,650
29,250
19,250
6,550
11,650
13,250
7,900
7,900
4,300
Operating
Capacity
Utilization
Rate
83%
74%
58%
64%
78%
32%
31%
44%
45%
48%
Total
Capacity
Utilization
Rate
77%
45%
33%
25%
11%
9%
12%
11%
12%
7%
 Source: (DOE91a).
Imports

     A second source of uranium is the import market.  Until
1975, foreign uranium was effectively banned from U.S. markets by
a Federal law prohibiting the enrichment of imports for domestic
use.  This restriction was lifted gradually after 1975, and was
eliminated completely in 1984.  From 1975 through 1977, imports
amounted to a small portion of total domestic requirements, and
U.S. exports actually exceeded imports in each year from  1978
through 1980.  By  1986, however, imports supplied 44 percent of
U.S. requirements.  Total imports in 1990 have grown 54 percent
since 1986 to a total of 23.7 million pounds of uranium concen-
trate, surpassing  domestic supply.  This is a marked increase
from the 13.1 million in imports reported in 1989. Table  2-7
lists U.S. imports from 1975 through 1990, as well as  import
commitments through the year 2000  (DOE87a, DOE91b).
                                2-9

-------
Table  2-7.   Imports of Uranium for Commercial Uses:  1975 - 1990
                          (Million of Pounds U3O8)
Year of Delivery
Actual Deliveries:
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
Subtotal
Commitments :
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Subtotal
TOTAL
Annual

1.4
3.6
5.6
5.2
3.0
3.6
6.6
17.1
8.2
12.5
11.7
13.5
15.1
15.8
13.1
23.7
159.7

20.2
16.2
18.7
15.6
15.6
14.1
13.2
7.5
8.3
14.7
144.1
303.8
Cumulative

1.4
5.0
10.6
15.8
18.8
22.4
29.0
46.1
54.3
66.8
78.5
92.0
107.1
122.9
136.0
159.7
—

179.9
196.1
214.8
230.4
246.0
260.1
273.3
280.8
289.1
303.8
—
—
Source: (DOE91b)
                               2-10

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      Utilities  and suppliers purchased roughly  equal  shares  of
 1990  imports.   For delivery commitments beyond  1990,  utilities
 account  for  84% of the  total quantity of  imports under  contract
 as  of December  31,  1990 (DOE91b).

      The primary sources  of U.S. uranium  imports have been
 Canada,  South Africa  and  Australia. In 1990, 43 percent of U.S.
 uranium  imports were  from Canada,  32 percent were  from  Australia,
 and 25 percent  were from  various other countries.  The  United
 States has not  imported uranium from South Africa  since the  1986
 ban which was called  for  in the Comprehensive Anti-Apartheid Act.
 However, on  July 11,  1991 the U.S. eliminated restrictions
 against  South Africa, and uranium  imports have been permitted to
 resume.

      Forecasts  of import  penetration call for the  import share to
 grow  through the 1990's.  The Department of Energy  projects that
 without  government  intervention, imports will rise from 52
 percent  in 1991 to  83 percent by the year 2003.  Many factors
 will  affect  the amount  of uranium  imported in the  near  future,
 including: the  extent to  which the U.S. resumes trade with
 Namibia  and  South Africa, whether Germany sells its unwanted
 inventories, whether Australia lifts regulations restricting
 certain  drilling and whether the former Soviet Republics are able
 to  produce and  sell uranium on a large scale (DOE91a).

 Inventories

      Utilities  hold uranium inventories in order to meet changes
 in  the scheduling of various stages of the fuel cycle,  such  as
 minor delays in deliveries of uranium feed.  Uranium  inventories
 also  protect the  utilities against disruption of nuclear fuel
 supplies.

      Table 2-8  lists inventories of commercially owned  natural
 and enriched uranium held in the United States as  of December 31,
 1988,  1989, and 1990.   DOE-owned inventories are not  included in
 this  table.  The  uranium  inventory owned by utilities alone  at
 the end of 1984 represented almost four years of forward cover-
 age.  Forward coverage dropped to 3 years by the end of 1990.  In
 1990  total commercial inventories decreased by 5.9 million pounds
 from  138.1 million pounds in December of 1989 to 132.2 million
pounds in December of 1990.   Utility inventories decreased from
 115.8 million pounds in 1989 to 102 million pounds in 1990 - a
reduction of 13.8 million pounds.  Government held inventories of
uranium concentrate decreased from 77.5 million pounds  in 1989 to
59.8 million pounds in 1990.   Finally,  in 1990,  the amount of
enriched uranium held in inventory by the Government increased
from  24.7 million pounds to 32.8 million pounds (DOE91b).
                               2-11

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      Table 2-8.  U.S. Commercially-Owned Uranium Inventories as of
                      December 31, 1988, 1989 and 1990
                      (Million Pounds,  U3O8 Equivalent)

Owner Category
Utilities
Suppliers
TOTAL
1988
Natural
80.2
18.2
98.4
Enriched
45.3*
1.1
46.4
1989
Natural
R67.3
R21.2
R88.6
Enriched
R48.5*
1.0
R49.5
1990
Natural
61.4
25.8
87.2
Enriche
40.6*
4.4
45.0
 Notes:
   * Includes fabricated fuels (23.7 million pounds U3O8 in 1988,
    22.8 million pounds in 1989 and 19.5 million pounds in 1990)

 R = Revised from data published DOE90a

 Source: (DOE91a)                                 	
2.3  INDUSTRY  STRUCTURE AND PERFORMANCE

     The number of firms participating in the domestic uranium
milling industry declined between 1977 and 1983, and again after
1987.  In  1977,  26 companies owned active uranium mills.   By June
1985, there were only two (DOE87b).   In 1987, six companies
operated six mills (industry sources).  However, by 1990  only two
mills were operational.  The contraction of the industry  can also
be seen in trends in employment and capital expenditures  (Table
2-9).  Capital expenditures in 1986 were only $1 million,  com-
pared to $72 million in 1981 (1986 dollars)  (DOE87a, DOE87b).  By
1990 capitol expenditures for conventional milling were so small
that the DOE no longer published the figure independently of
other processing methods.  Employment in 1984 was 513 person-
years, compared to 2,367 person-years in 1981.  In 1990,  employ-
ment had dropped to 304 person years (DOE87a, DOE91a, DOE91b).
The overall level of employment in the raw materials industry
reported in 1990, 1,335 person-years, was approximately 6% of the
level of 21,251 person-years reported in the peak year 1979
(DOE91b).

     A wide variety of companies have been represented within the
uranium industry.  In the industry's early years, holdings were
dominated  by  independent mining and exploration companies.  Since
then, mergers, acquisitions, and the entry of conglomerates have
considerably  altered industry structure.  During the 1970's, the
oil  embargo and optimistic forecasts of future nuclear power-
capacity made  entry into the uranium market attractive to oil
                                2-12

-------
companies and utilities.   However,  by 1990 depressed market
conditions prompted multinational domestic oil companies to leave
the  uranium industry.


        Table 2-9.  Capital Expenditures, Employment, and Active Mills:
                         Conventional Uranium Milling Industry
 Year
  Capital Expenditures*
(Million Constant  1990 $)
 Employment
(Person-years)
Number of Active
Mills At Year-End
1987
1988
1989
1990
1991**
0.3
7.3
4.6
0.6
0.5
432
572
367
304
—
6
6
3
2
—
 Notes:
     * Capital Expenditures figures include processing activities/unconventional
      mines.  Expenditures for conventional mines fall every year.  They
      constitute a negligible percentage of the figures given above.

    ** Capital Expenditures for 1991 are projected.  Other data for the
      same year are not available.


 Source; (DOE91a, DOE91b)
     Recently,  uranium milling  and mining has experienced an
increased  level of industry concentration.  Nine firms  account
for almost all  domestic uranium output,  both conventional and
non-conventional.   Four firms account for almost 80 percent of
all domestic production.  The DOE  projects that the industry will
become even more concentrated in the near term.  The sale and
production of uranium is only a small segment of the firms'
principal  activities for nearly all of the firms remaining in the
industry.   Among the four largest  uranium firms in 1990;  two were
foreign-based energy firms, one was controlled by a foreign-based
uranium  firm, and one was a wholly owned subsidiary of  a  domestic
utility  (DOE91a).

     These ownership characteristics influence the financial
viability  of the industry.  The desire of the parent companies to
weather  a  downturn in the uranium  market and to retain  an inter-
est in producing properties is  a function of how necessary their
involvement is  to their main business activity.  Most firms are
continuing to withdraw from an  extremely soft market.   Foreign
owned firms appear to have adopted a longer term viewpoint than
have some  of their domestic counterparts.   It is certain  that the
industry will continue to undergo  structural change.  This change
                                2-13

-------
will depend on the regulatory environment, domestic and foreign
demand, costs of production, and the industry's ability to
compete with lower-priced imports (DOE87a, DOE91a).

2.4  ECONOMIC AND FINANCIAL CHARACTERISTICS

     In March 1992, the departments of mining or natural resourc-
es in the states with uranium mills were contacted to provide
their assessments of the status of the uranium industry.  This
assessment disclosed that due to protracted low prices only two
mills were then operational, and both planed to shut down, one
was expected to begin decommissioning.

     In New Mexico, the two milling facilities together employ 61
people, although neither facility is operational.  The laborers
at those mills are engaged in reclamation work and the leaching
of small quantities of uranium.  The State estimates that a total
of 87 workers are employed in both the milling and mining indus-
try, down from 318 the year before.  Grants, New Mexico, the
location of the two remaining licensed facilities in the state,
has been in steady economic decline.  The Rio Algom Mill in
Grants, which once employed between 1,300 and 1,600 people,
employed only 37 by March 1992.  Most of their former employees
have left the state, some work for a new prison facility and a
few others are employed by a local coal mine (NM92).

     Wyoming still has one mill in operation, the Pathfinder Mill
in Shirley Basin.  The Pathfinder Mill is operating significantly
below capacity, and planned to close in spring 1992.  However, it
planned to remain on standby status.  State figures on employment
in the industry remain unchanged since 1984, at 454 people.
Employment is expected to drop after the mill closes  (WY92).

     The uranium industry in the state of Washington has been
inactive since 1985, and no indication has been shown that this
will change.  No new industries have entered the regions where
mining took place.  The workers who were not part of the Indian
community have left the area (WA92).

     Texas, like Wyoming, had one mill which was still operating.
This mill was scheduled to shut down and begin decommissioning in
April of 1992.  The mill, recently bought from Chevron by General
Atoms, employed 60 people at that time.  Most of the workers were
engaged in dismantling the mill.  The area around the mill is
economically depressed, however, the nearby economy of San
Antonio offers employment opportunities.  All other mills in
Texas have been permanently closed, although the former Conquista
Project, once owned by Conoco, now by DuPont, still employs
several people  (TX92).
                               2-14

-------
      Colorado  and Utah experienced  some  activity  in  the  late
 1980's,  but more  recently have  had  no milling production.   Both
 states have a  skeletal labor  force  in the uranium industry.   The
 Cotter Mill in Canon  City,  Colorado is in danger  of  decommission-
 ing,  causing a permanent  loss of between 100 and  150 jobs.  These
 jobs  translate into a $5  to $7.5 million per year pay-roll  loss
 to  the local economy.   The situation in  Utah is similar.  The
 Umetco Minerals Mill  in Blanding opened  recently,  and is on
 stand-by status (CO92,  UT92).

 2.5  INDUSTRY  FORECAST AND OUTLOOK

      This section presents projections of total U.S.  utility
 market requirements,  domestic uranium production  and net imports.
 Developed for  a fifteen year  period (1991-2005),  these projec-
 tions are considered  "near term."   A basic assumption of the  near
 term  projections  is that  current conditions, as defined by  the
 Department  of  Energy's  Energy Information Administration (DOE,
 EIA), will  continue unchanged through the end of  this century.
 This  section is based on  the  reference case projections in  EIA's
 Domestic Uranium  Mining and Milling Industry: 1990 Viability
 Assessment  (DOE91a).

 2.5.1 Projections of Domestic  Production

      The EIA's  Reference  case1 forecasts  for  1991-2005 in five
 year  intervals  are based  on the output of two EIA economic
 models;  the Uranium Market  Model (UMM)  which projects demand, and
 the Uranium Supply Analysis System  which projects supply.  The
 methodology of  these  models is  beyond the scope of this study; it
 is  fully described in Appendix  D of  the 1990 Viability Assess-
 ment.  The  EIA  examines future  developments in the domestic
 uranium  industry  and  in the domestic and international uranium
 markets  under current market  conditions and under certain hypo-
 thetical  supply disruption  scenarios.2  The current market condi-
 tions are generally the same  as those presented in Sections 2.1 -
 2.4 of this study and are based on historical trends  in the
 domestic uranium  industry as  outlined by the Viability Assessment
 and the  EIA's Uranium Industry Annual 1990.   In addition to the
     1 The EIA publishes three projection cases, an upper, lower and
no  new  order  case.    However,  in the  near term  no significant
difference exists among any of these cases.

     2   These scenarios, the "current disruption status" scenario
and the "projected disruption  status"  scenario,  are used  to test
the viability of the  U.S.  uranium  industry, to examine the ability
of this industry to respond to an abrogation of various fractions
of contracts  for  uranium imports intended for  domestic end use.
Both of these bear only tangentially  to this study and will not be
discussed further here.
                               2-15

-------
uranium prices, production and imports, exploration expenditures,
capital expenditures, and employment data developed for inclusion
as "current market conditions," the EIA identifies several
international political uncertainties which could affect the
uranium industry.  Also taken into account by DOE are assumptions
on future electricity generation, fuel burnup levels, enrichment
in tails assay, and inventory drawdowns.

2.5.2  Near-Term Projections

     The reference case projections for uranium concentrate re-
quirements, domestic production and net imports through the year
2005 is shown in tabular form in Table 2-10, along with compari-
sons to previous DOE and independent projections.  Aggregate
domestic production from 1991 though the year 2000 is projected
to be 82.8 million pounds, about the same as total domestic
production in the years 1980 and 1981.  Production is expected to
remain low through 2005 (DOE91a).

     Using the same models, the Department of Energy has forecast
industry-wide employment through the year 2005.  The DOE projects
that employment will remain steady at approximately 1,200 person-
years per year in mining, milling, and processing past the turn
of the century.  However, the DOE does not predict how that labor
will be dispersed throughout the industry (DOE91a).  Both histor-
ical and projected employment are presented in tabular form in
Table 2-11.

     In the immediate future, very little of the domestic produc-
tion of uranium can be expected to come from conventional milling
methods.  As of the winter of 1992 many mills have filed for
decommissioning status.  The remaining mills will remain on
standby status for a short period to evaluate changing market
conditions.  If conditions remain unchanged, the last facilities
will likely shut down as well.

     Whereas low prices have forced conventional domestic milling
out of the market, they have less of an affect on processing
methods such as by-product recovery and in-situ leaching.
Thesenon-conventional methods of production have a lower marginal
cost of production than do conventional producers, and therefore
are less affected by the fluctuations in uranium market prices.
However, the non-conventional methods have a relatively low
capacity and will not be able to respond to large increases in
demand  (DOE92).
                               2-16

-------
  Table 2-10.  Comparison of Uranium Projections: U.S.  Uranium Requirements,
                        Domestic Production, and Net Imports
                               (Million Pounds U3Og)

                                         Projection Period
Source
1991-1995
1996-2000 2001-2005
Total,
1991-2000
Total,
1991-20
Uranium Requirements
1990
1989
1988
1987
Viability Assessment
Viability Assessment
Viability Assessment
Viability Assessment
Nuexco, Reference Case
Energy Resources International,
Inc . , Low Case
209
195
189
168
218
196
.2
.1
.6
.8
.3
.1
213
198
181
173
208
188
.1
.2
.8
.2
.5
.4
203
193
176
—
205
182
.3
.8
.0
-
.0
.6
422
393
371
342
426
384
.3
.5
.4
.0
.8
.5
625
587
547
-
631
569
.6
.3
.4
-
.8
.1
Domestic Production
1990
1989
1988
1987
Viability Assessment
Viability Assessment
Viability Assessment
Viability Assessment
Nuexco, Reference Case
44.
45.
47.
41.
35.
3
8
1
3
8
38.
46.
49.
69.
65.
5
4
9
3
3
31.
68.
74.
—
72.
6
5
7

3
82.
92.
97.
110
88.
8
2
0
.6
4
114
160
171
-
127
.4
.7
.7
-
.0
Net Imports
1990
1989
1988
1987
Viability Assessment
Viability Assessment
Viability Assessment
Viability Assessment
129
117
113
106
.7
.8
.2
.1
156
128
112
92.
.7
.6
.8
1
161
110
92.
—
.4
.5
6

286
246
226
198
.4
.4
.0
.2
447
356
318
-
.8
.9
.6
—
Source: (DOE91a)
     The Reference case EIA projections  of  domestic U3O8 produc-
tion through the year 2000 are based on  a unit by unit review of
nuclear power plants that are new, operating,  under construction,
or units for which orders have been placed  and for which licenses
are currently being processed.  Under  EIA's Reference case,
nuclear generating capacity is expected  to  increase from 99.6 GWe
in 1991 to  106.5 GWe in 2005  (Table 2-12).

2.6  EVALUATION OF FORECASTS AND URANIUM MARKET DEMAND

     This section compares our scenario, as developed from DOE
forecasts,  for total domestic production of U3O8 to total domestic
uranium resources.
                                2-17

-------
Table 2—11.  Employment in the U.S. Uranium Industry Under Current
                Market Conditions:  1975 to 2005 (Person-Years)
                                   Mining, Milling
Year
Exploration and
Processing**
Total
Historical:
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
2,049
2,793
4,140
4,449
4,066
3,370
2,300
769
374
235
163
162
183
144
86
73
7,623
10,330
13,901
16,391
17,455 R
16,549
11,376
8,338 *
5,241
3,362
2,283
1,957
1,819
1,997
1,497
1,262
9,672
13,123
18,041
20,840
21,521 R
19,919
13,676
9,107
5,615
3,597
2,446
2,119
2,002
2,141
1,583
1,335
Projected:
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
Notes:
*
**
R
Source
60
60
60
60
60
60
60
60
70
70
70
70
60
60
60
Includes 140 contract truckers
Includes employment in byproduct
1,200
1,300
1,300
1,300
1,300
1,200
1,200
1,200
1,100
1,000
800
800
800
1,000
1,100
1,260
1,360
1,360
1,360
1,360
1,260
1,260
1,260
1,170
1,070
870
870
860
1,060
1,160
and in-situ processing.
Revised from data published in the 1989 viability
report (DOE89a) .
: (DOE91a)

assessment

                               2-18

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 2.6.1 Domestic Uranium Resources

      The most recent projections of domestic U3Og production shown
 in Table 2-10 indicate that slightly over 114 million pounds of
 U3O8 will be produced domestically between the years 1991 and
 2005.  By-product recovery and in-situ leaching are expected to
 account for much of this production.   Historically, these methods
 have processed between 3.7 and 6.5 million pounds of uranium per
 year. Moreover,  non-conventional production at this level is not
 greatly impacted by market forces.  The marginal cost of process-
 ing small quantities of uranium from by-product recovery of
 minerals such as copper and phosphate is negligible.   In-situ
 leaching also can produce small quantities of uranium at low
 costs.   However,  the capacity for production from these two
 methods at costs below current market prices is limited.

      If these methods produce at their historical maximum capaci-
 ty and process 6.5 million pounds of  uranium each year between
 the years 1991 and 2005,  97.5 million pounds of U3O8 will  be
 generated by non-conventional methods.   On the other hand,  if the
 non-conventional  methods  operate at a minimal capacity and
 process only 3.7  million  pounds,  then over the fifteen years only
 55.5 million pounds will  be generated.   Therefore,  non-conven-
 tional  methods can be expected to produce  somewhere between 55.5
 million pounds and 97.5 million pounds accounting for between 48
 and SS^percent of total projected domestic production.   Since
 domestic production is expected to decline over the projected
 years,  while domestic non-conventional production could remain
 steady,  non-conventional  production could  easily account  for all
 of  the  31.6  million pounds  projected  between  the year 2000  and
 2005.   Thus,  conventional milling should account for  the  remain-
 ing 16.9  million  pounds to  58.9  million pounds  of  the 114.4
 million forecast  for this period.  Most of  this  production  should
 be  expected  in the  earlier  projection  years.

 2.6.2   Conventional  Milling Domestic Resources

     DOE  also estimates the total  "endowment" of domestic U3O8 re-
 sources.  The  "endowment" is defined as all U3O8  in deposits
 containing at least  0.01  percent  (100 ppm)  of U3O8.  Resources are
 grouped according to resource categories, as defined  below.  The
 three resource categories used by DOE are also those  used by the
 International Atomic Energy Commission and the OECD Nuclear Power
Agency:

     •    Reasonably Assured Resources  (RAR) refers to uranium in
          known mineral deposits which could be recovered within
          given cost ranges, and using currently proven technol-
          ogy.  This corresponds to DOE's Reserves Category7
                              2-19

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  Table 2-12.
Projected U.S. Nuclear Power Capacity and Uranium
            Requirements
        (Million Pounds U3Og)
Year
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
Net
Design
Capaci-
ty*
(GWe)
99.6
100.8
101.9
101.9
103.1
103.1
103.1
104.3
104.3
105.4
105.4
105.4
106.6
106.6
106.5
Uranium
Require-
ments**
(Million
Pounds, U3O8)
41.8
41.8
40.8
42.4
42.4
43.5
43.5
42.4
42.4
41.3
41.3
42.7
39.9
39.9
39.5
Opti-
mal
Vari-
able
Tails
Assay-
s***
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.29
0.28
0.27
0.26
0.25
Utility Con-
tract
Commitments
(Million
Pounds, U3Og)
33.5
26.5
28.8
23.8
24.6
19.9
16.2
9.3
9.2
6.2
3.6
NA
NA
NA
NA
Utility Un-
filled
Requirements
and Inventory
Drawdowns****
(Million
Pounds, U3Og)
8.2
15.3
12.1
18.6
17.9
23.6
27.3
33.1
33.2
35.1
37.7
NA
NA
NA
NA
Notes:
*     Capacity in operation at the end of the year

**    These projections have been smoothed to reduce the magnitude
of yearly variations due to reactor fueling schedules; smoothing,
however, does not affect the overall trend of the projections.

***   Percent U-235 transaction enrichment tails assay.

****  uranium requirements minus contact commitments equals
unfilled requirements and inventory drawdowns.

Source:  (DOE91a)	
                              2-20

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     •    Estimated Additional Resources (EAR) refers to uranium
          in addition to RAR that is expected to occur, mostly on
          the basis of direct geological evidence in extension of
          well explored deposits, little explored deposits, and
          undiscovered deposits believed to exist along well
          defined geological trends with known deposits, such
          that the uranium can be recovered within the given cost
          estimates.  This corresponds to DOE's Provable Poten-
          tial Category;

     •    Speculative Resources  (SR) refers to uranium in addi-
          tion to EAR and RAR which is thought to exist, mostly
          on the basis of indirect evidence and geological ex-
          trapolations.  This corresponds to DOE's Possible
          Potential Resource Category.

     The "forward cost of recovery" of uranium resources repre-
sents estimates of most future costs of mining, processing, and
marketing U3O8, exclusive of return to capital.  These estimates
include the costs of transportation, environment and waste
management, construction of new operating units and maintenance
of all operating units, and future exploration and development
costs.  Also, appropriate indirect costs such as those for office
overhead, taxes and royalties are included.  Table 2-15 presents
estimates of all reasonably assured U3O8 resources having a
"forward cost of recovery" of no more than $50/lb (DOE91a).  In
addition to the reasonably assured resources, the DOE expects
2,200 million pounds of estimated available resources as well as
1,300 million pounds of speculative resources, both at a forward
cost of recovery of less than $30 per pound.  At a forward cost
of recovery of up to $50 per pound, expectations rise to 3,400
million pounds and 2,200 million pounds, respectively.

     Using only Reasonably Assured Resources, Table 2-13 suggests
that the United States currently has about 265 million pounds of
U3O8 with a forward cost of recovery of no more than $30 per pound
(DOE91a).  Assuming an average U3O8 recovery rate of about 90
percent, domestic mills have enough resources in this category to
cover all of the projected domestic production through 2005 even
without the expected contribution of non-conventional methods.

     The determination of conventional milling output over the
fifteen year period is not only  dependent on the accuracy of the
DOE forecasts, but also on the assumption that no technology is
introduced to expand the capabilities of non-conventional pro-
cessing.  Although the introduction of such technology is not
anticipated under current market conditions, some possibilities
remain open.  These possibilities include: increased by-product
recovery in the processing of bauxite and beryllium ores, and by
extraction of uranium from copper waste dumps  (DOE80).  Studies
are also being conducted to remove uranium from seawater.  Scien-
                               2-21

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tists are capable of accessing the large quantities of uranium
found in seawater but the economical viability of such technology
is questionable (Ca79, Ro79).
  Table 2-13.
U.S. Reasonably Assured Resources (RAR) by State
  and  by Mining Method,  as  of  December  31,  1990
              (Million Pounds  U3O8)
                               Forward-Cost Category (Nominal $)
                                  $30 Per           $50 Per
Origin
State
New Mexico
Wyoming
Texas
Arizona, Colorado, & Utah
Other*
Total**
Pound U3O8

85
71
23
43
43
265
Pound U3O8

351
330
47
125
73
926
Mining Method
  Underground
  Open Pit
  In Situ
  Other***
    Total**
                     141
                     39
                     84
                      1
                     265
468
277
163
18
926
Notes:
 *  Includes California, Idaho, Nebraska, Nevada, North
    Dakota, Oregon, South Dakota and Washington
**  Uranium resources that could be recovered as a byproduct
    of phosphate and copper mining are not included, but may
    amount to 37 million pounds U3O8.
*** Includes heap leaching, mine water and low grade stockpile.
Reasonably Assured Resources  (RAR) in forward-cost categories
are cumulative; i.e. the quantity listed at $50/lb U3O8 includes
all RAR at $30/lb.
Source; (DOE91a)
                              2-22

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                             CHAPTER 3

         BACKGROUND INFORMATION FOR LICENSED NON-OPERATING
                 URANIUM MILL  TAILINGS  IMPOUNDMENTS
3.1  OVERVIEW

     Uranium mills process ore for the purpose of recovering and
concentrating uranium to an intermediate, semi-refined product
called yellowcake.  There are two basic conventional processes for
extracting uranium from the ore:  the acid-leach process and the
alkaline-leach process.  The leaching process removes the uranium
from the crushed ore, with sulfuric acid as the leaching agent in
the acid-leach process; a mixed sodium carbonate sodium bicarbonate
solution is the leaching agent in the alkaline-leach process
(NRC80).

     Both milling processes involve a series of operations, includ-
ing ore handling and preparation (crushing and grinding), extrac-
tion, concentration and precipitation, product preparation, and
tailings disposal (EPA86).  Although each of these milling activi-
ties has the potential to release radon, essentially all the radon-
222 emissions associated with the uranium mill process come from
the tailings disposal area.  Previous evaluations have shown that
radon releases from other milling operations are insignificant
(NRC80; EPA83b; EPA85).  Therefore, the reduction of radon-222
emissions at licensed uranium mill sites is accomplished most
effectively by reducing the emission from the tailings disposal
area.

     The tailings represent the bulk of the wastes originating from
the uranium mill and contain (1) all the contaminants present in
the original ore, (2) about 10 percent of the uranium not recovered
in the milling process, and (3) a variety of chemicals and addi-
tives, inclusive of water, used in the extraction processes.   Both
the acid—leach and alkaline-leach extraction processes create waste
with concentrated levels of thorium and radium.  In the acid-leach
process, approximately 95 percent of the thorium in the original
ore remains in the solid tailings waste.  Less than one percent of
the radium is dissolved in the liquids.  Even greater amounts of
thorium and radium remain in the solid waste from the alkaline-
leach process (EPA83b).  These concentrated levels of thorium and
radium in the tailings waste are the source of radon-222 emissions.

     This Section provides a historical overview of the licensed
non-operating uranium mills identified in the Memorandum of Under-
standing (MOU) between the EPA and the NRC and the current status
of the associated tailings impoundments.  Impoundment characteris-
tics and surface area status are summarized in Table 3-1.  It
should be noted that seven of the twenty tailings impoundments
listed in Table 3-1 contain evaporation ponds within the tailings

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disposal area.  Evaporation ponds are used for dewatering of the
piles and for long-term maintenance of ground water.  Since the use
of the evaporation ponds is an integral part of the remediation
process, it is not the EPA's intent to require the final radon
cover to include these ponds, even when located on the tailings
pile, by the target dates specified in the MOU.  Therefore, the
acreage associated with the evaporation ponds has not been included
in the total surface areas of the tailings impoundments.

     Data were compiled using NRC dockets and EPA documents written
in support of previous rulemakings associated with the UMTRCA and
the CAA.  An updated status of the tailings surface configuration,
obtained from mill facility licensees, was provided by the NRC's
Uranium Recovery Field Office and cognizant individuals from
affected Agreement States.
Table 3-1.
1992 Status of Non-operational Tailing Impoundments
Identified in the Memorandum of Understanding
TAILINGS SURFACE
FACILITY
ANC, Gas Hill, WY
ARCO Coal, Bluewater, NM
Atlas, Moab, UT
Conoco, Conguista, TX-
Ford-Dawn Mining, Ford, WA
Hecla Mining, Durita, CO
Homes-take, NM (large impoundment)
Homestake, NM (small impoundment)
Pathfinder-Lucky Me, GH, WY
Petrotomics, Shirley Basin, WY
Quivera, Ambrosia Lake, NM
Rio Algom, Lisbon, UT
Sohio-L-Bar, NM
UMETCO, Gas Hills, WY
UMETCO, Maybell, CO
UMETCO, Uravan, CO
UNC, Church Rock, NM
Union Pacific, Bear Creek, WY
WNI, Sherwood, WA
WNI, Split Rock, WY
Total
110
270
128
250
123
35
170
13
203
114
368
100
80
192
50
70
103
178
94
223
Ponded
0
0
0
0
0
0
0
0
9
0
0
0
0
0
0
0
0
0
0
0
Wet
0
0
10
100
28
0
18
0
6
0
0
0
0
0
0
0
0
0
44
0
AREA (Acres)
Dry
0
120
118
0
0
0
152
7
0
0
36
0
0
0
15
0
0
0
50
0
Interim
Cover
110
150
0
150
95
35
0
6
188
114
332
100
80
192
35
70
103
178
0
223
MOU
Target
Date
1995
1995
1996
1996
2010
1997
1996
1997
1998
1995
1997
1996
1992
1995
1997
1997
1997
1996
1996
1995
                                3-2

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3.2  FACILITY-SPECIFIC CHARACTERISTICS

3.2.1  ANC. Gas Hills (also known as FAP)

     In 1959, Federal-American Partners  (FAP) began operation of a
uranium mill located in the Gas Hills Mining District of Wyoming.
FAP was originally a partnership consisting of two corporations,
Federal Resources Corporation and American Nuclear Corporation
(ANC).  Tennessee Valley Authority (TVA) was the leaseholder.

     The ANC Gas Hills mill was licensed to process 860 metric tons
per day.  The mill used acid leach-solvent extraction process to
recover uranium oxide from the ore.  Waste tailings were deposited
in a dam impoundment (Tailings Pond No. 2) as a slurry and the
liquid was decanted into Tailings Pond No.l, which served as a
solar evaporation pond.   The total tailings area encompasses
approximately 110 acres.

     During the operation period of 1959 through 1981, approxi-
mately 5.4 million metric tons of tailings waste was generated.  In
February 1981, TVA instructed FAP to suspend their mining opera-
tion.  Milling of stockpiled ores continued until October 1981,
when the mill was shutdown.

     Currently, reclamation activities at the site include decom-
missioning of the mill and reshaping and regrading of both tailings
impoundments.  A six-inch interim soil cover has been placed over
the 110-acre tailings area.  The MOU target date for completion of
a final earthen cover over the tailings impoundments to reduce
radon levels to the UMTRCA standard is 1995.

3.2.2  ARCO Coal. Bluewater Mill

     The Bluewater Uranium Mill is owned by the Anaconda Minerals
Company, a unit of ARCO Coal Company, a Division of Atlantic
Richfield Company.  The mill is located about ten miles northwest
of Grants, New Mexico.   The mill operated between 1953 and February
1982.

     Originally, Bluewater Mill was designed to process 300 tons of
ore per day using a carbonate leaching operation to extract urani-
um.  In 1959, the mill was upgraded to handle 6000 to 7000 tons of
sandstone ore, and the carbonate process was replaced by an acid
leach method.

     The mill site has three tailings impoundments.  Tailings from
the carbonate leach process were initially stored in an above-
ground area covering about 47 acres (Impoundment No. 2) north of
the mill.  After the process changed to acid leach, slurring of the
materials began, and the tailings were deposited in the main
tailings impoundment (No. 1), which is a natural basin enhanced and
enlarged through earthen dikes and embankment to encompass roughly

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230 acres.  A third tailings impoundment, the north area acid pile,
is situated immediately northwest of the main pile and covers 23
acres.

     From 1982 until 1985, ARCO dewatered the main tailings im-
poundment and removed the dissolved uranium from the liquid by
solvent extraction.  The waste from this recycling process, or
barren raffinate, was pumped to the tailings pile until the end of
1983.  Thereafter, the barren raffinate was pumped directly to the
evaporation ponds.   Approximately 25 million tons of tailings
materials, generated during operating and recycling activities,
have been deposited in the main tailings impoundment.

     Reclamation activities are currently underway at the site.
These activities include removal of tailings material in four
evaporation ponds to the tailings slime area, regrading of tailings
embankments, and pickup of windblown tailings and placement into
impoundment.  Approximately 150 acres of the 270-acre tailings area
has been covered with an average of 2.5 feet of native soil.
According to the Memorandum of Understanding, it is projected that
the radon cover will be in place by 1995.

3.2.3  Atlas. Moab Mill

     The Moab uranium recovery facility, located in Moab, Utah, is
owned by Atlas Minerals Corporation.  Milling operations began in
October 1956.  The ore processing circuits underwent several design
changes over the years.  The mill's initial design consisted of two
alkaline leach circuits.  A copper circuit was added in 1965 and
operated until December 1970.  In 1965, one of the alkaline leach
circuits was converted to an acid leach and a uranium and vanadium
solvent extraction unit was installed.  A fire in 1968 temporarily
suspended operations.  The alkaline leach circuit was restarted in
1969 and ran until January 1982. The acid leach and solvent extrac-
tion circuits operated until the mill was put on a standby status
in March 1984.

     Waste tailings were disposed in a single tailings impoundment
consisting of five embankments formed by sand tailings dikes.
Approximately 10.6 million tons of waste were deposited as a slurry
in the tailings impoundment.  The tailings disposal area covers
approximately 128 acres.

     Presently, site reclamation activities are proceeding.  The
tailings pile is currently being dewatered, with 118 acres dry and
the remaining 10 acres wet.  The MOU target date for completion of
an earthen cover, which meets the UMTRCA emission standards, is
1996.
                                3-4

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 3.2.4   Conoco.  Concmista  Mill

     The  Conquista  Mill is  located  in  Falls  City,  Texas,  an Agree-
 ment State.   The  owner, Conoco,  Inc.,  operated  the mill between
 1972 through  the  early 1980's.   The mill was licensed  to  process  a
 maximum of  3100 metric tons of ore  per day.

     Approximately  8 million metric tons of  tailings waste  was pro-
 duced during  the  mill's operating life.  The tailings  were  deposit-
 ed  in an  above-grade tailings impoundment constructed  of  natural
 clay.   This single  impoundment encompasses approximately  250 acres.

     Currently, reclamation of the  Conquista site  is underway.
 Mill decommissioning has  been completed.  A  permanent  radon cover,
 which meets the UMTRCA emission  standard of  20  pCi/m2-s,  has been
 placed  over approximately 150 acres of the tailings impoundment.
 The remaining tailings area (100 acres) is wet.  In accordance with
 the MOU,  the  entire tailings disposal  area will have a final radon
 cover by  1996.

 3.2.5   Ford-Dawn  Mill

     The  Dawn Mill  is located in Ford, Washington, an  Agreement
 State.  Dawn  Mining Company operated the mill from 1957 until 1964
 under government  contract.   The mill was shut down and rehabilitat-
 ed  between 1965 to  1969.  The mill  resumed operations  in  1969
 processing uranium  ore under commercial contracts  until 1982, when
 it  was  placed in  a  standby  mode for economic reasons.
     During operations, production  capacity  of  the mill was 600
 tons of ore per day resulting in the generation of approximately
 2.9 million tons  of tailings waste.   These tailings were  deposited
 in  three  unlined, above-grade impoundments,  constructed behind
 earthen dams, and one lined, below-grade disposal  area.   The three
 above-grade impoundments  encompass an  area of 95 acres.   The below-
 grade disposal area covers  28 acres.

     Presently, the three above-grade  impoundments have been
 blanketed with a  five-foot  interim earthen cover.  There  have been
 no  reclamation activities performed on the lined,  below-grade
 disposal  area.  A target date of 1996 has been  established for
 completion of a final radon  cover over the entire  impoundment
 areas,  as stated  in the Memorandum of Understanding.

 3.2.6  Hecla Mining, Durita Prelect

     The Durita site was constructed and operated  as a secondary-
 extraction heap leach facility that recovered uranium and vanadium
 from mill tailings  originally processed through the Naturita Mill.
The Durita Site occupies 160 acres in Montrose County,  Colorado,
 (an Agreement State),  about three miles southwest of the town of
Naturita.   The operation is managed by Hecla Mining Company.
                                3-5

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     The site contains an ore preparation facility, a plant for
leachate recovery, three leach tanks (piles),  and six evaporation
ponds.  The three small heap leach piles encompass approximately 35
acres and contain 600,000 tons of tailings.  The leach areas were
constructed of earthen dikes, underlain by a clay liner.

     The Durita site is in the process of reclamation.  An interim
soil cover of approximately 2 feet of compacted sandy clay soil has
been placed over the three heap leach piles.  Based on the MOU, a
final radon cover, which satisfies the emissions standard of 20
pCi/m2-s, will  be  in place  by 1997.

3.2.7  Homestake Mill

     The Homestake Uranium Mill is located in Grants, New Mexico.
Homestake's milling facilities were constructed and originally
operated as two distinct partnerships, with Homestake Mining
Company acting as the managing partner for both.

     The smaller of the two mills was organized as Homestake-New
Mexico Partners.  The mill operated between February 1958 and
January 1962 at a nominal capacity of 750 tons per day.  An alka-
line leach-caustic precipitation extraction process was used to
recover uranium.

     The larger mill, organized under Homestake-Sapin Partners,
began operations in May 1958 at a capacity of 1750 tons of ore per
day.  The mill was designed as an alkaline leach extraction facili-
ty.  In April 1968, through a change in the distribution of owner-
ship, Homestake-Sapin Partners became United Nuclear-
Homestake Partners.  In March 1981, Homestake purchased United
Nuclear Corporation's interest and operated the mill as Homestake
Mining Company-Grants until February 1990.

     A separate tailings impoundment area was constructed for each
of the two mills.  The first and smaller tailings impoundment
(associated with the Homestake-New Mexico Partners facility) was
constructed of earthen embankments.  Approximately 1.22 million
tons of tailings were deposited in the approximately 13-acre
impoundment area.  This impoundment is designated as
Homestake1s "small impoundment" in Table 3-1.

     The second tailings disposal area, associated with
Homestake-Sapin Partners, was constructed of compacted coarse
tailings embankments and is divided into two cells.  The impound-
ment encompasses approximately 170 acres and contains over 22
million tons of tailings.  This impoundment area is designated as
Homestake's "large impoundment" in Table 3-1.

     Reclamation activities have commenced at the sites which
include mill decommissioning and tailings impoundment dewatering.
                                3-6

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 A lined evaporation pond has  been constructed to  aid  in the
 dewatering process.   Currently,  the  configuration of  the large
 tailings pile consists  of 152 acres  that  are  dry,  with  no soil
 coyer,  and 18 acres wet.   Seven  acres  of  the  total 13-acre small
 tailings pile currently exists in a  dry,  uncovered state.   The
 remaining 7 acres  have  been blanketed  with  an interim soil cover.

     The EPA and NRC have decided to treat  the reclamation of  the
 two Homestake tailings  disposal  areas  separately.   Therefore,  in
 accordance with the Memorandum of Understanding,  a 1997 target date
 for completion of  a final earthen cover has been  set  for the large
 tailings impoundment; and a date of  2001  has  been established  for
 the small impoundment.

 3.2.8   Pathfinder-Lucky Me Mill

     The Lucky Me  Mill,  located  in Gas Hills,  Wyoming,  is  owned by
 Pathfinder Mines Corporation.  The mill commenced operations in
 1958 with an ore-processing capacity of 935 tons  per  day.   Subse-
 quently,  the capacity was expanded to  about 2800  tons of ore per
 day.  An acid leach process is used  to recover uranium  from the
 ore.

     The tailings  retention system consists of four unlined,
 earthen dam impoundments  having  a  surface area of  roughly  87,  63,
 38, and 15  acres.  Approximately 10.7  million  tons of tailings have
 been disposed of in  the 203-acre impoundment areas.

     Currently, an interim soil  cover  has been placed over  188
 acres of the tailings disposal areas.  The  remaining  impoundment
 areas consist of 9 acres  which are covered  with free  standing water
 (ponded)  and 6 acres that are  wet.  As specified by the  MOU, an
 earthen cover reducing radon emanation to 20 pCi/nr-s  will be  in
 place by 1998.

 3.2.9   Petrotomics.  Shirley Basin Mill

     The Shirley Basin Mill is owned by Petrotomics Company, a
 subsidiary  of Texaco.  The mill  is located  in  Shirley Basin,
Wyoming.  Petrotomics operated the mill from 1962 until  1985.   An
 acid leach-solvent extraction  process was used to extract uranium
 oxide from  ore.  The mill operated at a maximum ore processing
 capacity of  1400 tons per day.

     During operations,  about  6.4 million tons of tailings waste
was generated and deposited in a single above-grade,  earthen dam
constructed  impoundment.  The tailings impoundment area  encompasses
approximately 114 acres.

     Petrotomics is proceeding with reclamation activities at the
site.   To date, these activities include completion of the mill
                                3-7

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decommission, drying of the tailings area, and placement of an
interim stabilization soil cover over the entire tailings pile.
Based on the MOU, a target date of 1995 has been set for completion
of a final radon attenuation cover over the impoundment area.

3.2.10  Ouivera. Ambrosia Lake

     The Ambrosia Lake Mill, located in Ambrosia Lake, New Mexico,
is owned by Quivera Mining Company.  Milling operations began in
1958 under the ownership of Kerr-McGee at a design capacity of 3630
tons of sandstone ore per day.  The capacity was subsequently
expanded to 7000 tons per day.  In 1985, the mines and mill were
placed in standby status.  The mill utilized a conventional sulfu-
ric acid leach and solvent extraction recovery process.  Ion
exchange units were also used to extract uranium from mine water
discharged during dewatering of the Quivera mines.

     Approximately 33 million tons of process solids were deposited
on-site in two main tailings impoundments (Nos. 1 and 2a) and two
ancillary impoundments (No. 2b and 2c).  The disposal areas are
enclosed by dams (embankments) constructed with sand tailings.
Impoundment No. 1 encompasses approximately 229 acres and was used
almost exclusively during operations; Impoundment No. 2a, 2b, and
2c covers approximately 139 acres.  Liquid tails were decanted as
clear solutions and pumped to lined ponds for evaporation.  Solids
from the evaporation ponds will be returned to the tailings pile.

     Interim site reclamation activities are currently underway.
Tailings pile No. 1 has been regraded and recontoured to convey
precipitation off the top and covered with an interim cover con-
sisting of one-foot of alluvium material.  Approximately 85 acres
of Impoundment No. 2a, 2b, and 2c have also been dried and blanket-
ed with a one-foot interim soil cover.  In accordance with the
Memorandum of Understanding between the EPA and NRC, the target
date for completing emplacement of a final earthen cover to limit
radon emissions to a flux of 20 pCi/m2/s or less is  1997.

3.2.11  Rio Algom Mill

     The Rio Algom Mill owned by Rio Algom Mining Corporation is
located in Lisbon, Utah.  Rio Algom operated the mill from May 1972
until October 1988, when it was shut down due to declining ore
reserves.

     The mill's designed throughput was 750 tons of ore per day.
The ore was processed by alkaline  leaching and  ion exchange.
During operations, tailings were deposited in two above-grade,
earthen dam constructed impoundments.  The impoundments are unlined
but dug into natural clay.  The total tailings  disposal area
encompasses an  estimated 100 acres with approximately 3.3 million
tons of tailings.
                                 3-8

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      Reclamation activities, to date, include completion of a
 three-foot interim radon attenuating cover of clay and clay silt
 over both tailings impoundments.  Based on the MOU, a final radon
 cover will be in place over the entire impoundment area by 1996.

 3.2.12  Sohio-L-Bar Mill

      The L-Bar Uranium Mill is located in Seboyeta, New Mexico.
 Mining and milling operations were managed by Kennecott Corpora-
 tion,  a subsidiary of BP America,  from 1977 until cessation of
 operations in May 1981.  The source materials license was trans-
 ferred to Sohio Western Mining Company in 1990.

      The L-Bar mill utilized an acid leach process for extracting
 uranium from the ore.   An estimated 1.6 million  tons of tailings
 waste,  consisting of about 38 percent solids mixed with water,
 acid,  and a variety of spent process chemicals,  was generated
 during the operating period.   These tailings were pumped into an
 above-grade tailings impoundment.   The impoundment dam was con-
 structed from a starter dam of weathered Mancos  Shale,  with a
 bottom lining of salt-treated shale (to promote  clay swelling).
 The  tailings disposal  area encompasses approximately 80 acres.

     Reclamation activities at the site are nearing completion.   A
 final^earthen cover, which meets the radon emission limit of 20
 pCi/m-s, has been placed over the entire impoundment area.  Rock
 erosion protection  is  in place over the embankment slopes and
 spillways,  and vegetation is  beginning to grow on the pile top.
 The  MOU target date for the L-Bar  site has been  set for 1992.

 3.2.13   UMETCO.  Gas Hills Mill

     Umetco Minerals Corporation,  a wholly owned  subsidiary of
 Union Carbide  Corporation,  began operations  of the Gas  Hill Mill,
 located in East  Gas Hills,  Wyoming,  in  1960.  The  mill's  initial
 throughput capacity of  1100 tons of  ore per  day was  increased to
 1400 tons per  day in 1980.  An acid  leach  process  was used  to
 extract the uranium from  the  start  of operations  in  1960  until late
 1984.   Heap leach operations  at  the mill were introduced  in March
 1980.   The heap was extended  in November  1982 and  leaching  opera-
 tions continued until shut down  in December  1984.  The  facility
 remained in a  standby status  from 1985 until 1987  awaiting  improved
market  conditions.  Operations resumed in May 1987 and  shut down
permanently on January 1, 1988.


     The mill site encompasses a total of 235 acres which includes
the uranium mill, two tailings impoundments  (one above-grade
tailings area and the A-9 below-grade tailings pit), heap leach
operations, and evaporation ponds.   The 147-acre above-grade tail-
ings disposal area was used between 1960 and 1980 and contains
                                3-9

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approximately 5.8 million tons of tailings.  The 24-acre A-9 pit (a
clay-lined, depleted open pit mine) received approximately 1.4
million tons of tailings between 1980 and 1984.  In addition, the
A-9 pit has received 2.3 million tons of tailings from the Riverton
site (Title I).  The total tailings area (two impoundments and the
heap leach pile) encompasses approximately 192 acres.

     Reclamation activities have begun at the Umetco Gas Hill site.
Currently, a four-foot interim soil cover has been placed over the
192-acre tailings impoundment area.  According to the MOU, all
tailings areas will have a final cover, which meets the UMTRCA
emission standards, by 1995.

3.2.14  UMETCO. Mavbell Site

     The Maybell, located northeast of Maybell Colorado  (an Agree-
ment State) is a heap leach facility.  Umetco Minerals Corporation
operated the facility between 1975 and 1982.

     At the Maybell site, low grade uranium ore was placed on a
clay liner in piles (heaps) from 35 to 50  foot high.  The heap
leach process consisted of ponding a dilute solution of  sulfuric
acid in cells on top of heaps of low grade uranium ore.  The acid
percolated through the ore producing uranium-laden fluids  (leach-
ate) .  The leachate was collected by a drain system, constructed
above the clay  liner, and piped to an adjacent plant for concen-
tration .

     The heaps  cover an area of approximately  50 acres.  A thick
containment berm constructed of mine overburden surrounds the
perimeter of the leach piles.

     Reclamation activities, to date,  include  dewatering of  the
heaps and placement of a six-inch  interim  soil cover over approx-
imately 35 acres.  The remaining 15 acres  are  currently  dry  and
uncovered.  In  accordance with the MOU,  a  target date of 1997 has
been set for  completion of  an earthen  cover, which meets the radon
emanation  limit of 20 pci/m2-s.

3.2.15  UMETCO. Uravan Mill

     The Uravan Mill  is  located  in Uravan,  Colorado  (an  Agreement
State).  Umetco Mineral  Corporation, a subsidiary  of Union  Carbide
Corporation,  owns  the mill.  The mill  began processing uranium,
vanadium,  and radium  in  1915 using a two-stage acid  leach operation
to recover uranium and vanadium.   The  mill operated  at a maximum
licensed  capacity  of  1400  tons  of  ore  per  day.   In November 1984,
the mill was  placed  on  standby.   In  1987,  the  license was  amended
to maintain the mill  on  standby and to permit  reclamation of the
existing  tailings.
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     An estimated 12 million tons of tailings was produced during
operations.  This waste was disposed of in three tailings impound-
ments situated on mesas.  Impoundments 1 and 2 are adjacent and
overlapping and actually constitute one impoundment, which combined
cover approximately 39 acres.  The outward face of the impoundment
is constructed behind dikes of coarse tailings and the inward side
is contained by the native terrain.  Impoundment 3 is also con-
structed behind embankments of course tailings and encompasses
about 19 acres.  In addition, the site contains a 12-acre sludge
pile.

     Reclamation activities, to date, include placement of a ten-
foot soil cover over approximately 90% of the .impoundment area.
The remaining 10% (about 7 acres) contains a one-foot interim soil
cover.  The MOU specifies a target date of 2002.  However, a CERCLA
Consent Decree requires final cover over the tailings by 1997 with
the exception of a small portion of the impoundment (roughly 1%),
which may remain open to receive residues from groundwater restora-
tion activities.  For the purposes of this analysis, 1997 will be
used as the target date.

3.2.16  UNC. Church Rock Mill

     United Nuclear Corporation's (UNC) Church Rock Uranium Mill
facility is located about 17 miles northeast of Gallup, New Mexico.
The mill operated from 1977 until May 1982, when activities were
stopped due to the poor uranium market.

     The mill normally processed approximately 3500 tons of ore per
day using an acid leaching process to extract the uranium.  The
resulting acid solution and tailings were stored in a series of
three unlined tailings impoundments, each of earthen dam construc-
tion. In July 1979,  there was a breach in the earthen retaining dam
of one of the ponds spilling approximately 94 million gallons of
acidified effluent and about 1100 tons of tailings slurry.  Follow-
ing the dam failure, UNC dug two pits (Borrow Pits 1 and 2) for
disposal of mill solutions and tailings.  The total tailings
disposal area covers about 103 acres.

     Currently, the Church Rock Mill is in the process of being
decommissioned.  Other reclamation activities are in progress at
the site including the completion of a one-foot interim soil cover
over the entire tailings impoundment.  A final earthen cover, which
meets the UMTRCA emission standards, will be in place by 1997.
                                3-11

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3.2.17  Union Pacific, Bear Creek Mill

     Bear Creek Uranium Company, owned by Rocky Mountain Energy (a
subsidiary of Union Pacific Corporation) operated the Bear Creek
Mill located in Powder River Basin, Wyoming.  The mill was operated
from September 1977 through January 1986, when it was shut down due
to unfavorable uranium market conditions.

     The mill utilized a conventional sulfuric acid leach-solvent
extraction process for extracting uranium oxide.  The original mill
throughput capacity of 1000 tons per day was expanded to 2000 tons
per day in 1979.  Tailings were disposed in an earth-filled dam
constructed from mine overburden.  With the increased mill through-
put, it was recognized that the original design capacity of the
tailings area would be inadequate.  Therefore, the mined out B-3
pit was used as a second tailings disposal impoundment.  The
coarse, dewatered solids (sands) were deposited in the B-3 pit and
the fine tailings solids (slimes) and solution were disposed in the
originally designed tailings impoundment area.  The total tailings
disposal surface area occupies approximately 178 acres.

     Bear Creek Uranium Company has begun reclamation activities at
the site.  Mill decommissioning has been completed.  Currently, the
tailings surface is protected with an average one-foot thick
interim cover of clay soil.  The projected target date for comple-
tion of the final earthen cover is 1996 in accordance with the
Memorandum of Understanding.

3.2.18  WNI. Sherwood Mill

     The Sherwood Mill is located on the Spokane Indian Reservation
in Washington, an agreement state.  Western Nuclear, Inc. (WNI)
operated the mill from 1978 through 1984.  In 1984 the mill was
maintained in a "hot" standby mode between 1984 and 1988.  In 1988,
the boilers were shut down and the mill was considered to be in
"cold" standby.

     A conventional acid leach-solvent extraction circuit was used
for the recovery of uranium oxide from ore.  The mill was designed
to process 2000 tons of ore per day.  Resultant tailings waste
(approximately 2.3 million tons) was disposed in a single above-
grade tailings impoundment constructed with earthen embankments.
This tailings area encompasses about 94 acres and at the cessation
of operations was filled to approximately 70% of full capacity.

     Decommissioning of the mill commenced in January 1990.
Western Nuclear, Inc. is currently in the process of dewatering the
tailings impoundment area.    To date, approximately 50 acres are
dry and 44 acres are wet.  In accordance with the MOU, the
target date of 1996 has been set for completion of a radon attenua-
tion cover over the tailings area.
                                3-12

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3.2.19  WNI. Split Rock Mill

     Between the years of 1957 and 1981, Western Nuclear Inc.  (WNI)
operated the Split Rock Uranium Mill and adjacent tailings disposal
areas, located in Jeffery City, Wyoming.  The mill was placed on
standby status during the period of 1981 through 1986.  In 1986,
the license was amended to terminate use of the tailings pond for
tailings disposal.  During operations, the mill was licensed to
process 1700 tons of ore per day using an acid leach-solvent
extraction method.

     The original tailings disposal area, constructed with an
earthen starter dike and a tailings sand embankment, was utilized
from 1958 to 1977.  In 1977, the tailings liquid breached the
extreme northern section of the embankment.  Following the breach,
the embankment was repaired and the impoundment area was enlarged
by constructing a new compacted tailings dam upstream of the
existing embankment.  The entire 223 acre disposal area contains
approximately 7.7 million tons of tailings waste.

     To date, WNI has completed decommissioning activities at the
site.   Reclamation operations, inclusive of an interim cover over
the entire impoundment area, are underway.   As specified in the
MOU, a target date of 1995 has been set for completion of an
earthen cover which reduces radon levels to 20 pCi/m2-s or less.
                               3-13

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                             CHAPTER 4

 RADON-222 SOURCES, ENVIRONMENTAL TRANSPORT, AND RISK COEFFICIENTS
     This chapter presents the physical and chemical properties of
radon-222, where and how it is emitted from the uranium tailings,
and the mechanism by which it is transported through the environ-
ment.  Also presented are the methods used to model the atmospheric
dispersion of the radon-222 and a description of how the health
risks associated with these emissions are estimated.

     Uranium ore contains both uranium and its decay products,
including significant concentrations of radium-226.  Radon-222 is a
naturally occurring radioactive gaseous element that is formed by
the radioactive decay of radium-226.  Radium-226 is a long-lived
(1620 year half-life) decay product of the uranium-238 series.  In
nature, uranium is about 99.3 percent uranium-238; thus, it is the
decay products of uranium-238 (Figure 4-1) that govern the radioac-
tive content of the ore.

4.1  MILL TAILINGS:  ENVIRONMENTAL SOURCE TERMS FOR RADON-222

     Uranium ore that is processed in mills to concentrate uranium
to an intermediate semi-refined product called yellowcake, yields a
waste material with significant concentrations of radium.  About
ten percent of the starting concentrations of the uranium—238 and
virtually all of the decay products in the ore inclusive of radium-
226 are contained in the tailings.  Radium-226 undergoes further
radioactive decay to produce radon-222 gas.  The half-life of
radon-222 is 3.8 days.  Therefore, when radon is released to the
atmosphere, the released atoms can travel large distances before
they decay.  Tailings represent the largest and longest lasting
source of radon-222 emissions from licensed uranium mills because
of the large exposed area and the residual concentrations of
radium.

     Radon-220, a decay product of thorium-232, is also contained
in tailings.  Because of its short half-life of only 55 seconds, it
has a limited time to be released into the atmosphere and reach a
potential target population.  Radon-220 is regarded to have an
insignificant impact on human health when released from uranium
mill tailings piles and will, therefore, not be considered in this
report.

     Radon, as an inert gas, is chemically unreactive with most
materials and is free to travel through the small spaces between
particles which constitute a tailings pile.  The fine slime fraction
contains the majority of radium-226 in the tailings (NRC80).  The
sand fraction contains radium-226 in concentrations ranging from 26
to 100 pCi per gram  (NRC80), and the tailings liquid (raffinate)
contains 1.7 to 35,000 pCi per liter of radium-226  (EPA83b).

                                 4-1

-------
   TJ-238
          a,7

      4.5 x 109 y
Th-234
                                           0,7
                                         24.1 d
Pa-234
                                                          1.17 m
   Ra-226
             7.7 x 104 y
                     Th-230
               a,7

          2.44 x 10s y
U-234
 a,7
1.6 x 103 y
   Rn-222
          a,7

        3.82 d
Po-218
                                            a
                                         3.05 m
Pb-214
                                                    0,7
                                                   26.8 m
   Pb-210
                 a,7
             1.64 x icr4 s
                     Po-214
                                    18,7
                         Bi-214
                                 19.8  x m
 0/7
22.3 y
   Bi-210
                     Po-210
               5.01 d
                                           a,7
                                 138.4  d
                         Pb-206
   y
   d
   m
   s
years
days
minutes
seconds
Figure 4-1.
      Uranium-238 Decay Chain  and  Half-Lives of Principal
      Radionuclides
                               4-2

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     Not all the  radon produced within the pile will be released to
the pore spaces between particles.   Some of radon produced will
remain trapped within the physical  structure of the particles or
through recoil become "impacted" in adjoining particles and will,
therefore, be unable  to enta^  the pc    spaces ^ 'igure 4-2} . Because;
radon is moderately soluble in water,  the single most important
variable is moisture  content of the piles.  However, a limited
amount of water is  thought to   enhance the apparent emission of
radon because it  reduces the radon  atom's recoil range and may
prevent radon atoms from lodging in adjacent grains.  The radon atom
can then diffuse  into the pore air  space where it is available to
migrate through the pile.   If  the pore spaces are totally saturated,
as is the case when piles are  wetted or in ponded areas, the radon
atom has a low probability of  emanating from the pile.  This is due
to the fact that  water hinders radon's migration by lowering the
diffusion coefficient and by absorbing radon atoms (Ta86).  Radon
solubility depends  on the water temperature; the colder the water,
the greater the radon's solubility.  A measure of gas solubility is
given by the solubility coefficient.   The radon solubility coeffi-
cient is defined  as the ratio  of the radon concentration in water to
that in air (Co86).   The warmer the water temperature, the more
radon is released;  and,  therefore,  the lower the solubility coeffi-
cient. -The maximum solubility coefficient of radon is about 0.5 at
water temperatures  approaching 0°C.  Solubility decreases  exponen-
tially with a rise  in temperature and  is reduced to about  0.25 at
20°C and 0.1 at 90°C.
                                       •  Rodium-226

                                    ^ ^  Rodon-222

                                    "';; Q  Alpha Panicle

                                    :? R Recoil Range - The distance thot o
                                         radon-222 atom  travels when the
                                         rodium-226 atom disintegrates
                Figure 4-2.  Radon Emanation Process

                                 4-3

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4.1.1  Estimating Radon Emissions from Tailings Impoundments

     In addition to moisture content, the amount of radon-222
emitted from tailings impoundments depends on a number of highly
variable factors, such as ore grade, grain size, porosity, tempera-
ture, and barometric pressure.  These factors, in turn, vary between
sites, between locations on the same site, and with time  (PEI85).
For these reasons, mathematical models typically have been used to
estimate average radon-222 emissions on a theoretical basis.
Considerable research has been conducted to develop and refine ways
of calculating average radon-222 flux from infinitely thick or deep
sources (i.e., at least 1 meter deep).  This work has largely been
carried out in support of the Uranium Mill Tailings Remedial Action
Program (UMTRAP) and pertains to inactive mill tailings piles.
Empirical measurements have been made of radon-222 emissions from
licensed uranium mills and tailings piles, and studies have demon-
strated good agreement between actual measurements and estimates
based on mathematical models  (EPA83b).

     A one-dimensional, steady-state, radon-222 diffusion equation
has been developed for sources (e.g., ore piles and tailings) that
are more than several meters thick  (Ni84, Fr84).  Equation 4-1
defines the radon flux at the surface as follows:
                          Jt = 104 RpE (7.0)
                                         1/2
                                                            (Eq. 4-1)
                                                                  IS
where Jt is the radon-222  flux at the  surface of the  source
(pCi/m2-s) ; R is  the specific activity of radium-226  in ore  or
tailings equal to 2812 x  (uranium ore grade in percent), pCi/g; p
the bulk dry density of the source  (g/cm3) ;  E  is the  radon-222
emanating fraction of source, dimensionless; 7 is the radon-222
decay constant (2.1 x I(r6/s) ; D is the effective diffusion coeffi-
cient for radon-222, equal to bulk radon diffusion coefficient/
porosity De/p (cm2/s) ;  and p is  the porosity,  equal to l-(bulk
density/ specific gravity).

     For piles that are less than a few meters thick, Equation 4-1
should be multiplied by a hyperbolic tangent function that varies
with depth or thickness (T), as shown in Figure 4-3.  With the
exception of the radon-222 decay constant, these parameters can vary
significantly from location to location within the source, both
horizontally and with depth, in a given ore pile or  tailings  im-
poundment.  Except for the decay constant and bulk density, these
parameters are difficult to measure.  They are based on the physical
characteristics of the source materials, which vary  (1) over  time
(e.g., radium-226 content may decrease over the life of the mill as
ore grade declines), (2) seasonally, and  (3) with changing mill
operation.  Given the complexity and variability of  parameters
affecting radon emission and the scarcity of site-specific measure-
ments, the EPA has adopted the following generic correlation  between
radon emissions and radium concentration  (EPA83b):
                                 4-4

-------
Radon emanation estimates used in this report are based  on  the
average radium concentration in each pile using the  simplified
relationship of 1 pCi Ra-222/m2-s per pCi Ra-226 per gram of
tailings.  The emanation rate varies according to tailings
characteristics, grain structure, grain  size and moisture
content, and according to meteorological conditions  such as
temperature and barometric pressure.  These rates can be
expected to vary across individual piles and from pile to pile.
The rate chosen here is believed to be generally representative
of all uranium mill tailings piles and is used for all areas  of
a pile that are free of significant moisture.  Wetted or ponded
areas of a pile are assumed to emit no significant levels of
radon.
                                D = BULK DIFFUSION COEFFICIENT
   0.0 I
     0   40
 Figure  4-3.
 120     200     280     360
                DEPTH, cm
440
520
                                                            600
Effect of Pile Depth on Hyperbolic Tangent Term  in
Radon-222 Flux Equation (Ha85).
                                4-5

-------
 4.1.2   Ingrowth of  Radon-222  Decay Products

     At the  point where  radon-222  diffuses out  of  the  tailings pile
 surface, the concentrations of  associated radon-222 decay products
 are  zero, because those  decay products  generated prior to diffusion
 from the surface are  retained in the  tailings.  As soon as radon-222
 is airborne,  ingrowth of decay  products commences.  The quantitative
 relationship between  radon and  radon  decay products depends  on the
 extent  to which radioactive equilibrium is reached.  If the  rate of
 formation and disintegration  of the decay products suspended in air
 is exactly equal, a condition of secular equilibrium is reached.
 Although secular equilibrium  is a  theoretical upper limit, in
 reality it is not achievable  due to plume depletion of radon daugh-
 ters by dry  and wet deposition  and precipitation scavenging.

     Human exposure to radon-222 progeny from tailings piles is
 based on an  indoor/outdoor exposure model.  The model  assumes that
 the  average  individual spends about 75  percent  of  the  time indoors
 and  25  percent  outdoors  (Mo76;  Oa72).   Radon-222 and its decay
 products may enter  a  structure  that is  downwind and enhance  the
 normal  indoor air concentration.

     The specific activity of radon or  individual  decay product
 isotopes is  commonly  quantified in picocuries per  liter (pCi/1).
 However, the  specific activity  of  short-lived radon decay products
 collectively  is also  measured in units  called working  levels (WL).
 One  working  level is  any concentration  of short-life radon-222
 progeny having  1.3  x  10? MeV per liter of potential alpha energy
 (FRC67).  The relationship between the  working  level concentration
 of decay products and the picocurie per liter concentration  of radon
 depends on the  degree of equilibrium  between radon and radon daugh-
 ters.   At secular equilibrium,  one WL is equal  to  100  pCi/1  of
 radon-222.

     Equation 4-2 defines the relationship between WL  and pCi/1 in
 terms of the  equilibrium fraction:
                  Equilibrium Fraction = [^3  x 100
                                          [pCi/1]
                                         (Eq. 4-2)
     The exposure to radon-222 progeny at a site of interest is
based on the calculated radon-222 concentration and the calculated
radon-222 progeny equilibrium fraction:
Radon progeny
concentration
   (WL)
    Radon
concentration
   (PCi/1)
    Radon progeny
x  equil. fraction
       (feeff)
   (Eq. 4-3)

1.0 x ID'2
(WL/pCi/1)
                                 4-6

-------
     Calculations  of  radon-222  progeny equilibrium fractions are
based on distance  from  a  source and  the time required to reach the
exposure site.  By using  the  ingrowth  model  of Evans (Ev69)  and the
potential alpha energy  data of  United  Nations Scientific Committee
on the  Effects of Atomic Radiation  (UNSCEAR77),  the outdoor equi-
librium  fraction  can be  calculated  by the expression:
 fC00t = 1.0 - 0.0479e-t/4-39
         - 2.1963e
                  -t/38.6
       + 1.2442e
                               -t/28.4
(Eq.  4-4)
where t is the travel time  in minutes  (distance/transport
velocity).
     The indoor equilibrium  fraction presumes  that  those decay
products associated with the radon-222 release also enter the
building and that a ventilation rate of  1 hour'1  (one air change per
hour) in combination with  indoor removal processes  (e.g.,  deposition
onto room surfaces) produces an indoor equilibrium   fraction of  0.35
when there are no decay products in the  ventilation air  and 0.70
when the decay products are  in equilibrium with the radon-222 in  the
ventilation air (EPA83b).  A simple linear interpolation is used  to
obtain the indoor equilibrium fraction:
                           =  0.35 (1
                                            out\
                                             (Eq.  4-5)
     If one further assumes that a person spends 75 percent  of  his
or her time indoors and the remaining 25 percent outdoors  at the
same location, the effective equilibrium fraction  is given by:
  f,eff  =  0.75
f em
0.25 f.
=  0.2625 + 0.5125
(Eq.  4-5)
     To calculate air exposure concentrations for specific members
of the public and regional populations, EPA uses the computer model
CAP-88 EPA 1991  (EPA 520/6-91/022, December 1991, "User's Guide  for
CAPS8-PC").  CAP-88, which stands for Clean Air Act Assessment
Package - 1988,  is a set of computer programs, databases, and
associated utility programs for estimating dose and risk from a
variety of radionuclide emissions to air inclusive of radon  from
large area sources.  Large area sources are modeled in CAP88-PC
using a method described by Mills and Reeves, as modified by Chris-
topher Nelson, EPA, and implemented by Culkowski and Patterson
(Mo79).  The method transforms the original area source into an
annular segment with the same area.  The transformation is dependent
on the distance between the centroid of the area source and  the
receptor.  At large distances (where the distance/diameter ratio is
2.5), the area source is modeled as a point source; at close dis-
tances it becomes a circular source centered at the receptor.  A
point source model is also used if the area source is 10 meters  in
diameter or less.
                                 4-7

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     CAP-88 uses a modified Gaussian plume equation along with
proximal meteorological data.  Annual average meteorological data
sets include frequencies for several windspeed categories for each
wind direction and Pasquill atmospheric stability category.  CAP-88
uses reciprocal-averaged wind speeds in the atmospheric dispersion
equations, which permit a single calculation for each wind speed
category.

     The principle of reciprocity is used to calculate the effective
chi/Q.  The problem is equivalent to interchanging source and
receptor and calculating the mean chi/Q from a point source to one
or more sector segments according to the angular width of the
transformed source.  The mean value of chi/Q for each sector segment
is estimated by determining chi/Q at the distance which would
provide the exact value of the mean if the variation in chi/Q were
proportional to r'15 for distances from the point source to location
within the sector segment.  The chi/Q for the entire transformed
source is the sum of the chi/Q values for each sector weighted by
the portion of the total annular source contained in that sector.

     Table 4-1 provides a sample set of values for a 3.5 m/s wind-
speed and various distances from an 80 hectare source.  Removal
processes outdoors were assumed to limit the equilibrium fraction to
0.85, which corresponds to an indoor equilibrium fraction of 0.65
and an effective fraction of 0.70.  Table 4-1 shows that this limit
is reached at a distance of 19,550 meters.
                                 4-8

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Table 4-1.
Radon-222 Decay Product Equilibrium Fraction at
Selected Distances From the Center of a 80 Hectare
Tailings Impoundment1
Distance
(m)








1
1
2
2
3
4
5
6
8
10
15
19
150
200
250
300
400
500
600
800
,000
,500
,000
,500
,000
,000
,000
,000
,000
,000
,000
,551
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
f OUt
.013
.020
.026
.031
.041
.051
.060
.078
.094
.133
.168
.201
.234
.295
.353
.407
.507
.593
.755
.850
j
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
E6m
355
357
359
361
364
368
371
377
383
397
409
421
435
453
473
493
527
558
614
648
i
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
; eff
•e
267
273
276
278
284
289
293
302
311
331
349
366
382
414
443
471
522
566
650
698
       Calculations (tabulated to 3 decimal places to
       facilitate comparisons) presume:  a 3.5 m/s
       windspeed for the outdoor equilibrium fraction;
       an indoor equilibrium fraction of 0.35 for no
       radon-222 decay products in the ventilation air
       and 0.70 for ventilation air with 100 percent
       equilibrium between radon-222 and its decay
       products; and an effective equilibrium fraction
       based on 75 percent of time indoors and 25 per-
       cent of time outdoors.
                              4-9

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4.2  RADON-222 EXPOSURE PATHWAYS AND RISKS TO HUMAN HEALTH

     Radon-222 has a half-life of 3.8 days and follows a decay
process that involves seven principal decay products* before  ending
as stable non-radioactive lead (see Figure 4-1).   The dominant decay
products are those with very short half-lives and include polonium-
218, lead-214, bismuth-214, and polonium-214.  It is generally
believed that it is radon decay products, rather than radon itself,
that may induce lung cancer among exposed individuals.  The quanti-
tative relationship between radon and radon decay products depends
on the extent to which radioactive equilibrium is reached.  Poloni-
um-218, the first decay product, has a half-life of just over three
minutes.  This, however, is long enough for most of these electri-
cally charged and chemically reactive atoms to attach themselves to
microscopic airborne dust particles.  The total radon daughter
products (attached and unattached) that remain suspended in air is
reduced by several processes so that secular equilibrium is never
reached.  Removal processes are affected by the concentration of
airborne dust particles, the size of dust particles, surface to
volume ratio, surface texture, air flow, etc.  Based on simultaneous
measurements of radon and radon decay products, it has been found
that the indoor equilibrium fraction ranges from 0.3 to 0.7 with an
average of about 0.5 (Ge85).

     When inhaled, attached radon decay products with particle sizes
in the micron range are deposited on the moist epithelial lining of
the larger bronchi of the lung.  Unattached radon decay products
when inhaled penetrate smaller regions of the lung where they may be
deposited.  Although most particles are eventually removed from the
larger bronchi and upper respiratory tract by natural mechanisms,
radioactive decay occurs in time to expose lung cells to ionizing
radiation.  Two of the short-lived decay products, polonium-218 and
polonium-214, emit alpha particles during the decay process, which
exposes proximal cells to radiation with high linear energy transfer
(high-LET).

     High-LET radiations have a larger biological effect per unit
dose (rad) than low-LET radiations.  How much greater depends on the
particular biological endpoint under consideration.  For cell
killing and other readily discernable endpoints,  the relative
biological effectiveness (RBE) of high-LET alpha radiation may be 10
or even 20 times greater than low-LET radiation.   The RBE value is
also influenced by the dose level; for example, if linear and
linear-quadratic dose response functions are demonstrated for high-
and low-LET irradiations, respectively, the RBE must be assumed to
decrease with increasing dose for the high-LET radiation.

     For purposes of calculating dose equivalent, each type of
radiation emission is assigned a quality factor (Q) to account for
     * Radon decay products are also referred to as radon daughters.

                                4-10

-------
 its relative  efficiency  in producing biological damage.  The dose
 equivalent  (in rems)  is  the absorbed dose  (in rad) times the appro-
 priate quality factor (Q) for a specified kind of radiation.  Unlike
 an RBE value, which  is usually defined  in terms of a specific target
 cell, biological  endpoint, and dose-level, a quality factor repre-
 sents a generic assessment by radiation experts of the potential
 harm of a given radiation relative to X- or gamma-rays.  In 1977,
 the International Commission on Radiological Protection  (ICRP)
 assigned a quality factor of 20 to alpha particle irradiation from
 internal emitters (ICRP77).  The ICRP also found evidence that for
 very low dose rates  such as in occupational settings, the biological
 risks were lower  by  a factor of 2.5 than the same exposure received
 over a short period  of time.  Implicit  in ICRP's risk estimates for
 low dose/low dose rate is a dose reduction factor (DREF) of about
 2.5.  The EPA risk model does not employ DREF; therefore, in order
 to avoid an artificial inflation in high-LET risk estimates, EPA has
 assumed a RBE of  8 (i.e., 20/2.5 = 8) for calculating the risks from
 internal alpha particles.

     In the case  of  alpha irradiation of the lung by radon decay
 products, an assessment  of risk is not  only limited by uncertainties
 regarding RBE values  but also by the non-uniformity of radionuclide
 distribution and  dose distribution among and within individual
 target cells.  Adequate  characterization cannot be made of the exact
 doses delivered to cells that eventually become cancerous.  In
 uranium miners, and the  general population, the majority of lung
 cancers arise from the epithelium of bronchial airways.  In this
 tissue, both secretory and basal cells  are considered to be targets
 for lung cancer development (NRC91). Knowledge of the deposition
 pattern of the radioactive particles and non-attached decay products
 and the geometric spacing of decay progeny to cells that are suscep-
 tible can only be ascertained by theoretical models.  (Ha82, Ja80,
 Ja81, Mc78, Mc83).  Fortunately, there  are human epidemiological
 data that allow direct estimates of risks per unit of exposure that
 do not use a dosimetric  approach.  The Agency's estimates of risk of
 lung cancer due to inhaled radon progeny is based on the epidemio-
 logical approach  adopted by the National Academy of Science, in
which risk estimates  are based on observed excess lung cancers among
 groups exposed to varying time-integrated air concentrations of
 radon progeny.  In effect, EPA's estimates of lung cancer risks are
 based on the amount of inhaled radon-222 decay products to which
people are exposed rather than on the dose absorbed by specific
target cells of the lung.


 4.2.1  Characterizing Exposures and Risks to the General Population
       Vis-a-Vis  Underground Miners

     Epidemiological  investigations of uranium and other underground
miners have provided valuable data on the quantitative risks of lung
cancer associated with exposure to radon progeny in underground
mines.   The principal occupational groups that constitute the

                                4-11

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epidemiological database for the risk estimates include:  (1) U.S.
uranium miners, (2) Czechoslovakian uranium miners, (3) Ontario
uranium miners, (4) Malmberget iron miners, and (5)
Eldorado uranium miners.

     As discussed above, exposure to radon-222 decay products under
working conditions is commonly reported in the unit of working level
(WL).  The WL unit was developed because the concentration of
specific radon progeny depends on ventilation rates and other
factors.  A working level month (WLM) is the unit used to charac-
terize a miner's exposure to one working level of radon progeny for
a working month of about 170 hours.  Because the results of epide-
miological studies are expressed in units of WL and WLM, the follow-
ing outlines how they can be interpreted for members of the general
population exposed to radon progeny.

     The EPA assumes that a mine worker inhales 30 liters per minute
(averaged over a work day).  This average corresponds to about 4
hours of light activity and 4 hours of moderately heavy work per day
(ICRP75).  The new ICRP radon-222 model, however, assumes an inhala-
tion rate of 20 liters per minute for mine workers, which corre-
sponds to 8 hours of light activity per day
(ICRP81).  This may be appropriate for nuclear workers; however,
studies of the metabolic rate of mine workers clearly show that they
are not engaged in light activity only  (Sp56; ICRP75; NASA73).
Therefore, 30 liters appears to be a more realistic estimate of the
average per minute volume for this group.  Based on this per minute
volume, a mine worker inhales 3.6 x 103 cubic meters  in a working
year of 2000 hours (ICRP79).  One working level of radon-222 progeny
is equivalent to 2.08 x 10'5 joules per cubic meter (1.3 x 105 MeV
per liter); therefore, in a working year, the potential alpha energy
inhaled by a mine worker exposed to one working level is 7.5 x 10"2
joules.

     There are age- and sex-specific respiratory rate and volume
differences, as well as differences in duration of exposure, in a
general population as compared to a mining population.  According to
the ICRP Task Group Report on Reference Man  (ICRP75), an inhaled air
volume of 2.3 x 104 liters per day is assumed for adult males,  2.1 x
104 liters per day for adult females of the general population.
Reduced volumes of air are respired by children.  However, the
smaller bronchial area of children, as compared with that of adults,
more than offsets their lower per minute volume.

     For a given concentration of radon-222  progeny, the amount of
potential alpha energy a member of the general population inhales in
a month is more than the amount a mine worker receives  in a working
month.  Although members of the general population are  exposed
longer  (up to 24 hours per day, 7 days a week), the average  amount
of air inhaled per minute  (minute volume)  is less  in this group than
that for a mine worker when periods of  sleeping and resting  are
                                 4-12

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taken into account (EPA79; Th82).  The radon-222 progeny exposure of
a mine worker can be compared with that of a member of the general
population by considering the amount of potential alpha energy each
inhales per year (Ev69).  That radon daughter deposition (and dose)
in the conducting airways of the lung is proportional to ventilation
rate (quantity inhaled) has also been recommended by other investi-
gators (Ra 85; Ho 82).

     In earlier reports, EPA used an "exposure equivalent," a
modified WLM in which adjustments were made for age-specific differ-
ences in airway dimensions and surface area, respiratory frequency,
and minute volume.  These factors were expected to influence aerosol
deposition and, therefore, radiation dose from radon daughters.
This approach to quantifying exposure, correcting for differences in
these factors, was recommended by Evans (Ev69) and is consistent
with the original derivation of the working level (Ho57).

     The BEIR IV Committee, however, concluded that the tracheo-
bronchial "dose per WLM in homes, as compared to that in mines,
differs by less than a factor of 2," and,  at the time the BEIR IV
Report was issued, advised that the dose and risk per WLM exposure
in residences and in mines should be considered to be identical
until better dosimetric estimates are developed (NAS88).  The BEIR
IV Report, however, also stated the need for further research and
analysis on uncertainties in applying lung cancer risks character-
ized for underground miners to people in their homes.  Because of
the importance to the public of the risks of radon exposure in homes
and schools, the EPA asked the National Research Council to initiate
a study of the dosimetric considerations affecting the applications
of risk estimates, based on studies of miners to the general popula-
tion.  The EPA asked that a panel be assembled to investigate the
differences between underground miners and members of the general
public in the doses they receive per unit exposure due to inhaled
radon progeny.  In 1991, the NRC published a companion report to the
BEIR IV Report entitled "Comparative Dosimetry of Radon in Mines and
Homes," (NRC91).
 On the basis of this publication and review of other current
 information, the EPA, in 1992, with approval of its Science
 Advisory Board, adopted a risk coefficient of 2.24 x 10"* lung
 cancer deaths per person-WLM.   	
     This risk coefficient applies to residential radon exposure
received by the general public and is based on a modified BEIR IV
model using a standard life table calculation with 1980 U.S. vital
statistics.  Modifications to the BEIR IV model include the K factor
value of 0.7 and an adjustment to account for background radon
exposure.  The K factor is defined and discussed in Section 4.2.4
below.
                                4-13

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     The following provides a historical account of the EPA risk
model and derives the current risk coefficient of 2.24 x 10"* lung
cancer deaths per person-WLM.

4.2.2  The History and Derivation of EPA's Radon Risk Coefficients

     The Early EPA Model.  The initial EPA method for calculating
radon risks has been described in detail (EPA79, E179).  As new data
were reported, the EPA revised its model to reflect changes, as
contained in consecutive reports (EPA79, EPA82, EPA83a, EPA83b,
EPA84, EPA85, and EPA86). The Agency initially projected radon lung
cancer deaths for both absolute and relative risk models, but since
1978, EPA has based risk estimates due to inhaled radon-222 progeny
on a linear dose response function, a relative risk projection
model, and a minimum cancer induction period of 10 years.  A life
table analysis has been used to project this risk over a full life
span.  Lifetime risks were initially projected on the assumption
that an effective exposure of 1 WLM increased the age-specific risk
of lung cancer by 3 percent over the age-specific rate in the U.S.
population as a whole (EPA79).  In the most recent documents,
lifetime risks were calculated for a range of risk coefficients from
1 percent to 4 percent per WLM (EPA86).

     Comparison of Earlier Risk Estimates.  Several estimates of the
risk due to radon progeny have been published since the original EPA
model was developed.  These risk estimates were reviewed in a number
Of EPA reports (EPA84, EPA85, and EPA86).

     Previous EPA risk estimates for lifetime exposure to a general
population, along with Atomic Energy Control Board (AECB), National
Academy of Sciences (NAS), UNSCEAR, ICRP, and National Council on
Radiation Protection and Measurements (NCRP) estimates of the risk
of lung cancer resulting from inhaled radon progeny, are listed in
Table 4-2.  The AECB estimate for lifetime exposure to Canadian
males is 830 fatalities per million person-WLM  (Th82).  In Table 4-
2, this estimate has been adjusted for the U.S. 1970 male and female
population.
                                4-14

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Table 4-2.  Past Risk Estimate for Exposures to Radon Progeny
Fatalities per
Organization Model 106 person-WLM
EPA
NAS*
AECBb
ICRP
UNSCEAR
NCRPC
Rel.
A-S Abs.
Rel.
	
	
Dec.
760 (460)a
730 (440)a
600 (300)"
150-450
200-450
130
Exposure
Period
Lifetime
Lifetime
Lifetime
Working
Lifetime
Lifetime
Lifetime
Expression
Period
Lifetime
Lifetime
Lifetime
30 years
40 years
Lifetime
                   Abs.
   BEIR III

   *  EPA and AECB based their estimates of risk for the general
     population on an exposure equivalent, corrected for breathing
     rate (and other factors).  For comparison purposes, the values in
     parentheses express the risk in more customary units,  in which a
     continuous annual exposure to 1 WL corresponds to 51.6 WLM.

   b  Adjusted for U.S. General Population:  see text.

   c  NCRP84:   Table 10.2; assumes risk diminishes exponentially with a
     20-year halftime, and no lung cancer risk is expressed before age
     40.
   Sources:
   Models:
EPA83b; NAS80; Th82; ICRP81; EPA86; UNSCEAR77; NCRP84;
USRPC80.

Rel. - Relative Risk Projection
A-S Abs. - Age-Specific Absolute Risk Projection
Dec. Abs. - Decaying Absolute Risk Projection
                                 4-15

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     The National Institute for Occupational Safety and Health
reviewed published data on miner studies used as a basis for
estimated risk coefficients and pointed out some of the strengths
and limitations of selected studies (NIOSH87).

     The occupational exposure groups that constitute the epide-
miological database for the risk estimates are as follows:

1.   U.S. Uranium Miners (NIOSH87)

     (a)  Strengths:  A large, clearly defined, well-traced
          cohort with some smoking histories and exposure records
          on the same persons.  Standard sampling techniques were
          used to make measurements.

     (b)  Limitations:  There were few measurements in small
          mines, work histories were self-reported, exposures
          were high, and potential error due to excursions in
          exposure levels is high.

     (c)  Follow-up:  19 years in 1977.

2.   Czechoslovakian Uranium Miners (NIOSH87)

     (a)  Strengths:  Extensive exposure data with a large number
          of low level exposures and limited exposure to other
          underground mining.  Many possible confounding factors
          have been investigated and eliminated.

     (b)  Limitations:  Exposure estimates prior to 1960 based on
          radon gas measurements.  Person years at risk not
          determined in standard manner.  Smoking effect neglect-
          ed.  Elevated levels of arsenic in ore.

     (c)  Follow-up:  26 years in 1975.

3.   Ontario Uranium Miners  (NIOSH87)

     (a)  Strengths:  Miners received low mean cumulative expo-
          sures.  Prior mining experience was carefully traced.
          Exposures prior to 1967 may be disputed.

     (b)  Limitations:  Median age of the cohort was 39 years in
          1977.  Thoron and gamma exposures may have been high
          but not accounted for.  Smoking history is limited.

     (c)  Follow-up:  18 years in 1977.

4.   Malmberget Iron Miners  (NIOSH87)

     (a)  Strengths:  Low exposure levels, long follow-up and
          stability of work force.  Complete ascertainment of

                               4-16

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          vital status and confirmation of diagnosis.
          confounders was examined and ruled out.
                           Risk from
     (b)   Limitations:  Relatively small cohort with limited
          exposure data and an unclear cohort definition.

     (c)   Follow-up:  44 years in 1976

5.   Eldorado - Uranium Miners (NAS88)

     (a)   Strengths:  Very low exposure rates, miners screened
          for prior mining experience, roughly equal groups
          of surface only and underground only miners, Silica
          and diesel exhaust exposures low.  Potential
          confounders investigated.

     (b)   Limitations:  Exposure estimates are disputed.  Sixteen
          percent of the miners excluded for incorrect or missing
          data.  Average age in 1980 was 43 years.

     (c)   Follow-up:  14 years in 1980.


     BEIR IV Risk Estimates..  In early 1988, the National Academy
of Sciences  released the BEIR IV Committee report, which compre-
hensively examined information on the risks from radon and other
alpha-emitting radionuclides (NAS88).  With the cooperation of
the principal investigators, BEIR IV reviewed in detail the
mortality experience of four cohorts of underground miners (the
U.S., Ontario, and Eldorado uranium miners and the Malmberget
iron miners) and how the mortality related to radon daughter
exposure.  The Committee calculated the relationship of age-
specific relative risk to exposure level and time-since-exposure
(TSE) in two analyses.  The first used internal cohort compari-
sons and was a grouped-data analog of a Cox relative-risk regres-
sion (NAS88).  The second analysis compared the cohorts with
external rates and was a generalization of common standard
mortality ratio (SMR) methods.  Separate parallel analyses were
carried out to establish a single combined value for each parame-
ter.

     The mathematical form of the Committee's preferred TSE model
for the radon related age-specific mortality rate at age (a) is
r(a)  = r0(a)
0.025 y(a)
                                           0.5W2)]
(4-7)
  where:
     r(a) is the lung cancer mortality at attained age  (a) due to
     all causes,
                               4-17

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     r0(a) is the age-specific baseline rate of lung cancer death
     in  the  absence of  any excess  radon exposure  over  low back-
     ground  levels,

     7(a)  is the  age-specific adjustment to the relative risk
     coefficient  for radon with

           7(a)  =  1.2 when a  < 55  years
                =  1.0 when a  is  55-64  years
                =  0.4 when a  > 65  years

     The 7(a) adjustment  decreases the radon-induced lung cancer
     risk with  age.   This incorporates the  Committee's finding
     that excess  relative risk in  the  miners decreased with  age
     at  risk.

     (Wi + 0.5W2)  represents cumulative lifetime exposure up  to
     age (a)  modified as  follows:

           Wr = cumulative exposure occurring from 5-15 years
           before  age (a) ,  and

           W2 = cumulative exposure up to age a-15 years.

     Since W2 is reduced by 50 percent, the model gives less
weight to exposures  more  distant in time since exposure.   This
reflects the Committee's  conclusion that risk decreases with time
since exposure  as modeled for the  four cohort studies  of miners.
Hence, the relative  risk  coefficient  (6 = 0.025)  effectively
varies from  0.5 percent per WLM  to 3.0 percent per WLM,  depending
upon age at  risk  and time since  exposure (Pu89).  Therefore,
r0(a) (0.025)  (7a) (Wx + 0.5W2)  represents  the rate of excess  lung
cancer due to radon.

     The Committee model  is,  therefore,  an  age-specific,  rela-
tive-risk projection model  with  a  5-year latent period prior to
expression of risk.

     In  its  analysis, the BEIR IV  Committee identified two major
areas of  uncertainty affecting its conclusions: (1) uncertainty
related  to the Committee's  analysis of cohort data and (2) uncer-
tainty related to projection  of  the risk to other groups.  The
Committee's  TSE model uses  risk  coefficients derived from analy-
sis of data  from four miner cohorts.   Random or systematic
errors, particularly systematic  errors,  could bias the conclu-
sions.    Sources of error  in addition to  basic sampling variation
include:  (1) errors  in exposure  estimates,  particularly since the
magnitude  of error may differ among the  studies;  (2) errors  of
misclassification of cause  of death; (3)  errors in smoking status
                               4-18

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of individual miners, and (4) modeling uncertainty—i.e., does
the model properly address all parameters that are determinants
of risk?

     Having developed the TSE model for miners, the Committee
anticipated the following sources of uncertainty in projecting
the model across other groups: (1) effect of gender (miner data
are for males); (2) effect of age (miner data contain no informa-
tion on exposures before about age 20); (3) effect of smoking
(miner data contain poor information on smoking status); (4)
temporal expression of risk  (not enough miners have died to
establish accurately the pattern of lifetime risk from radon
exposure), and (5) extrapolation from mining to indoor environ-
ments (what are significant differences in the air in mines
compared to air indoors?).  After reviewing the various sources
of uncertainty, the BEIR IV Committee concluded [p42], " ...The
imprecision that results from sampling variation can be readily
guantified, but other sources of variation cannot be estimated in
a quantitative fashion."  Therefore, the Committee chose not to
combine the various uncertainties into a single numerical value"
(NAS88).

     The question of errors in exposure estimates is particularly
interesting since the modeling is strongly influenced by the U.S.
uranium miner data.  In fact, the model risk estimates would be
33 percent higher if the U.S. cohort was removed.  Exposure in
the U.S. cohort is poorly known:   cumulative WLM (CWLM) are
calculated from measured radon levels for only 10.3 percent of
the miners, estimates are used for about 36.1 percent of the
miners,  and "guesstimates" are employed for about 53.6 percent of
the miners (NAS88, Lu71).  Only 26.1 percent of the U.S. uranium
miner exposure data are based on measured values (Lu71).

     The Ontario cohort exposure estimates also are not well
founded.  Upper and lower estimates were developed:  the lower
from measured values, the upper based on engineering judgment
(NAS88).  Eldorado cohort estimates of CWLM were based almost
entirely on measured values, while Malmberget cohort estimates
were based on a reconstruction of past ventilation conditions
(NAS88).  Of the four cohorts, the United States has one of the
poorest bases for CWLM estimates.  One serious problem is the
potential error due to large excursions in radon daughter concen-
trations (NIOSH87).  The uncertainties in exposure estimates are
particularly significant in view of the rather large impact the
U.S. cohort has on the form of the model.

     When the BEIR IV model is run with the 1980 lifetable and
vital statistics at an exposure level of 0.001 WLM per year, the
reference risk can be calculated  (Table 4-3).
                               4-19

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Table 4-3.  BEIR IV Risk Model - Lifetime Exposure and Lifetime
            Risk
                  Group
                            Risk (KrVWLM)
                  Male
                  Female
                  Combined
                                 530
                                 185
                                 350
     ICRP 50.  The International Commission on Radiological
Protection, in its Publication 50, addressed the question of lung
cancer risk from indoor radon daughter exposures.  The ICRP Task
Group took a direction quite different from the BEIR Committee.
The Task Group reviewed published data on three miner cohorts:
U.S., Ontario, and Czech uranium miners.  The estimated risk
coefficients by cohort are presented in Table 4-4.
Table 4-4.  Estimated lung cancer risk coefficients from radon
            progeny exposure for three miner cohorts
   Cohort
    Follow-up
Relative model
Absolute model
U.S.
Czech
Ontario
Average
Source: ICRP87
1950-1977
1948-1975
1958-1981
0.
1.
0.
0%-2
1%
.0%
.0%
.3%
2-8
10-25
3-7
10
cases/10
cases/10
cases/ 10
cases/10
6
6
6
6
PWLMY
PWLMY
PWLMY
PWLMY
The relative risk model then developed for a constant exposure
rate is:
                       t-r
     X(t) = X0(t)[l +  j   r(te) E(te)  dtj
                      0
                                                   (4-8)
  where:

     X0(t)

     r(tc)

     E(tc)
= the mortality rate at age t



     = the age-specific lung cancer rate at age t

     = risk coefficient at age of exposure te

     = age-dependent exposure rate
                               4-20

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     T    = time lag  (minimal latency) = 10 years

     In the case of a constant exposure rate or constant annual
exposure, the equation collapses to:
     X(t) = X0(t)[l + r E(t - T)]

  where:
 (4-9)
      r   = age-averaged relative risk coefficient

     E(t - r) = E [t - T]

          = cumulative exposure to radon daughters to age t-r

     Since ICRP recommends the use of the relative risk model,
the ICRP 50 absolute risk model will not be addressed further in
this document.

     To adapt the relative risk model derived from studies of
underground miners for the general population, the ICRP Task
Group introduced several adjustments.  The first was to correct
for co-carcinogenic influences in mines. To account for unidenti-
fied, unproven carcinogens that might be present in mine environ-
ments but not elsewhere, only 80 percent of the risk was attrib-
uted to radon.  The second adjustment was for dosimetric correc-
tions.  The dose to bronchial epithelium used by the Task Group
for persons indoors was estimated to be only 80 percent as large
as that for persons in mines; therefore, the risk to the public
from radon was considered to be 80 percent of the risk of miners.

     Adjusting the average relative risk coefficient of 1 percent
per WLM by these two factors gives a risk coefficient of 0.64
percent per WLM:
               1.0% x 0.8 x 0.8 = 0.64%.
(4-10)
     The third adjustment made by the Task Group is related to
age.  Since reports of Japanese A-bomb survivors and some other
radiation-exposed groups support an elevated estimate of risk in
children compared to adults, the Task Group increased the risk
coefficient of persons between birth and age 20 by a factor of 3.

     The final relative risk coefficients in the ICRP 50 model
are:  1.9 percent per WLM if the age at time of exposure is
between birth and 20 years, and 0.64 percent per WLM if age at
time of exposure exceeds 20 years.
                               4-21

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     When the ICRP 50 relative risk model is run with 1980 U.S.
lifetable and vital statistics at an exposure level of 0.001 WLM
per year, the reference risk calculated is:
               Group

               Male
               Female
               Combined
Risk
      610
      205
      420
     EPA's Selection of Risk Coefficients in Earlier Documents.
To estimate the range of reasonable risks from exposure to radon-
222 progeny for use in the Background Information Document for
Underground Uranium Mines (EPA85), EPA averaged the estimates of
BEIR III, the EPA model, and the AECB to establish an upper bound
of the range.  The lower bound of the range was established by
averaging the UNSCEAR and ICRP estimates.  The Agency chose not
to include the NCRP estimate in its determination of the lower
bound because this estimate was believed to be outside the lower
bound.  With this procedure, the EPA arrived at relative risk
coefficients of 1.2 percent to 2.8 percent per WLM exposure
equivalent (300 to 700 fatalities per million person-WLM exposure
equivalent) as estimates of the possible range of effects from
inhaling radon-222 progeny for a full lifetime.  Although these
risk estimates did not encompass the full range of uncertainty,
they seemed to illustrate the breadth of much of scientific
opinion at that time.

     The lower limit of the range of 1985 EPA relative risk
coefficients, 1.2 percent per effective WLM, was similar to that
derived by the Ad Hoc Working Group to Develop Radioepidemio-
logical Tables, which also used 1.2 percent per WLM (NIH85).
However, some other estimates based only on U.S. and Czech miner
data averaged 1 percent per WLM  (Ja85) or 1.1 percent per WLM
(St85).  On the other hand, three studies - two on miners  (Ra84,
Ho87) and one on residential exposure (Ed83; Ed84) - indicated a
relative risk coefficient greater than 3 percent per WLM, perhaps
as large as 3.6 percent.

     The EPA, therefore, increased the upper limit of its esti-
mated range of relative risk coefficients.  To estimate the risk
due to radon-222 progeny, the EPA used the range of relative risk
coefficients of 1 to 4 percent per WLM.   (See EPA86 for a more
detailed discussion.)  Based on 1980 vital statistics, this
yielded, for members of the general public, a range of lifetime
risks from 380 to 1,520 fatal cases per 106 WLM (expressed in
exposure equivalents).  In standard exposure units, uncorrected
for breathing rate and age, this corresponds to 230 to 920 cases
per 106 WLM.   Coincidentally,  the geometric mean estimate ob-
tained in this way with 1980 vital statistics, 4.6xlO'4/WLM in
standard units of exposure, is numerically the same as that
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 obtained  using  a  3  percent  relative risk  coefficient  and  1970
 vital  statistics.

     In response  to the  consensus-based reports, BEIR IV  and ICRP
 50, and a recent  report  on  the Czech miner groups  (Se88), the
 Agency subsequently reviewed  its basis for radon risk estimation.
 Comparable relative risk coefficients for miners (age-constant
 relative  risk)  yielded a coefficient of around 1 percent  in ICRP
 50, 1.34  percent  in BEIR IV,  and 1.5 percent in the Czechs.  This
 suggested that  the  range, 1 percent to 4  percent, previously used
 by EPA, may have  been too wide.

     The  BEIR IV  Committee  noted and modeled a drop in relative
 risk with increasing time of  exposure and a decreasing relative
 risk with increasing age after exposure (NAS88).  The Czech
 miners show a similar response pattern (Se88).  Though the
 Committee did note  a dose rate effect in  the U.S. uranium miner
 cohort, i.e., a decrease in risk per unit exposure at high dose
 rates, it was not included  in the model (NAS88).  The possibility
 of a similar dose-rate effect was found recently in a study on
 Port Radium uranium miners  (Ho87).

     The  ICRP 50 Task Group worked from a different database and
 developed a simpler model with fewer age- and time-dependent
 parameters.  The Task Group provided a 3  times higher risk for
 exposure  between birth and  20 years of age than after 20 years of
 age (ICRP87).   The  finding  in the recent  Czech report that risk
 prior  to  age 30 is  2 to  2.5 times greater than after  age 30 lends
 some support to the ICRP conclusions (Se88).

     Both BEIR  IV and ICRP  50 models treat radon and  smoking
 risks  as  multiplicative.  This conclusion is based primarily on
 data from the U.S.  uranium  miner cohort.   Although apparently
 based  on  weaker evidence, the report on Malmberget miners and the
 recent report on Czech miners both concluded that the  interaction
 of smoking and radon exposure is small (Ra84, Se88).  The attrib-
 utable risk per unit exposure in smokers  and non-smokers was
 essentially the same (Se88).  The true interaction of radon and
 cigarette smoking is controversial.  Both antagonistic (Lu79)  and
 multiplicative  (Lu69,  Wh83)  interactions have been reported in
man,  and  animal studies can be found to justify either position
 (Ch81,  Ch85).  In prior calculations,  EPA has always treated the
 interaction between radon daughters and cigarette smoke as
multiplicative.   EPA continues to treat the radon daughter-smoke
 interaction as multiplicative at this time.

     At the advice of the Radiation Advisory Committee of EPA's
 Science Advisory Board,  EPA continued to use relative risk models
but included both BEIR IV and ICRP 50 model calculations to
 illustrate the difference in results from the two models.   The
 ICRP 50 model was slightly modified.   To compensate for differ-
ences in dosimetry,  the risk reduction factor of 0.8 was elimi-

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nated to place the ICRP 50 model and BEIR IV model on a compara-
tive basis.  Calculations in the ICRP 50 model were made using
risk coefficients of 2.4 percent per WLM from birth to age 20 and
0.8 percent per WLM for ages greater than 20 years, yielding
estimates listed in Table 4-5.

     Table 4-5 also summarizes previous risk estimates based on
the BEIR IV and the ICRP 50 model, modified as described above.
Both models were adjusted for the effect of background radon
exposure (see section below).
Table 4-5.  Lifetime Risks of Lung Cancer Death From Radon
            Daughter Exposure  (per 106 WLM)
                                              Model
     Group
                                  BEIR IV
                   ICRP 50
     Men
     Women

     Combined Population
     (Range)
530
185

350
   760
   255

   500
(170-840)
     The ICRP Task Group concluded that, all things considered,
the range of variation of the mean relative risk coefficient  is
from about  0.3 up to  2 times the value stated  (ICRP87).  The
range of risk cited in Table 4-5 for the ICRP model reflects  this
uncertainty in the risk coefficient.  Since the BEIR  IV  Committee
did not provide  a numerical range of uncertainty, no  range  is
given for that model.

4.2.3  Correction of  Radon Risk Estimates  for the Effect of
       Background Exposure

     A relative  risk  model for radon-induced lung cancer general-
ly assumes  the excess risk, Xr,  from a given exposure, is propor-
tional to the observed baseline risk of  lung cancer in the
population, X0.   Thus, for a constant exposure rate,  w, the
excess risk at age, a, attributable to previous exposure can  be
written:
           Xr(w,a) = X0(a)  j8(a)f(w/a).
                        (4-11)
                               4-24

-------
     For example,  in the case of an age-constant relative risk
model with a  10-yr minimum latency:
          j8(a) = j8 =  constant

          f(w,a) =  (a-10)w
(4-12)

(4-13)
     Although Xr is commonly assumed to be proportional to X0,  a
more consistent  (and biologically plausible)  way to formulate a
relative risk model is to  assume that  the radon risk,  Xr, is
proportional to  X0', the lung cancer rate  that would prevail  in
the absence of any radon exposure  (Pu88):
          Xr(w,a)  = X0 (a)|8(a)f(w,a)
(4-14)
Presuming that the risk model can be used to  relate X0(a) to
X0'(a), then
          X0(a)  = X0'  (a)  [1 + |8(a)f(w,a)]
(4-15)
where w is the average exposure rate  in the population.   It
follows from the previous equation that

          X»(a) =  X0(a)/[l  + j3(a)f(w,a)]                    (4-16)


     The inferred baseline  rate without radon exposure depends,
of course, on both the risk model and the presumed average
background exposure rate.   The excess risk associated with an
arbitrary.exposure situation  can be calculated using standard
life-table methodology.

     The ICRP 50 committee  did correct the baseline rate  in this
way in calculating lifetime population risks, assuming an average
exposure rate of 0.2 WLM/yr.  The BEIR IV Committee did not
incorporate the correction, noting that it would be small (see
NAS88, p. 53).  In arriving at a final estimate based on  the  ICRP
50 and BEIR IV models (Table  4-6), EPA has incorporated a model-
specific baseline correction, calculated on the assumption of a
0.25 WLM/yr average radon exposure rate (Pu88).  As seen  from
Table 4-5, this correction  results in roughly a 15 percent
reduction in each of the estimates of lifetime risk for the
general population.
                               4-25

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Table 4-6.  Lifetime Risk from Excess Radon Daughter Exposure
            (Adjusted for a Background Exposure of 0.25 WLM/yr)

                Risk of Excess Lung Cancer Deaths per 106 WLM

   Group	BEIR IV	ICRP 50	Average
    Men
    Women
    Population
    Combined
    (Range)
460
160
305
   640
   215
   420

(140-720)
   550
   190
   360

(140-720)
     Consistent with the recommendations of the Agency's  Radia-
tion Advisory Committee, EPA averaged the risk estimates derived
from the BEIR IV and ICRP 50 models.  These estimates are based
on 1980 U.S. vital statistics and are adjusted for an assumed
background exposure of 0.25 WLM/yr.  Thus, as shown in Table 4-6,
the excess lifetime risk in the general population due to a
constant, low-level, lifetime exposure was estimated by the EPA
to be 360 excess lung cancer deaths per 106 WLM, with  a  range  of
140 to 720 excess lung cancer deaths per 106 WLM.   The EPA used
the risk coefficient of 3.6 x 10"* fatal lung cancer per WLM in
its risk assessment involving NESHAPs radionuclides (EPA89).

4.2.4  EPA's Current Risk Projection Approach - Adjusted BEIR IV
       Model

     In 1991, the Office of Radiation Programs requested that
the SAB review proposed revisions to EPA's radon risk assessment
methodology.  The SAB recommended that the Agency use only the
BEIR IV model for assessment of risk from residential exposure to
radon.  The recommendation to use only the BEIR IV model and
discontinue use of the ICRP 50 model was based on several new
pieces of information.  The first was evidence from epidemiologi-
cal studies of a decrease in lung cancer risk with time since
exposure, which had been incorporated into the BEIR IV model, but
not the ICRP 50 model.  The second was the publication of the
BEIR V report (NAS90) and a study of Chinese miners exposed to
radon gas (Lu90).  These publications found no evidence of
dependence on age at exposure for lung cancer.  This was not
consistent with the increased risk to children assumed in the
ICRP 50 model.  Finally, the BEIR IV model was based on the most
updated information, was well documented, and represented the
consensus of a body of established and qualified scientists
(EPA92).

     EPA has made two adjustments to the BEIR IV model  in esti-
mating radon risks.  The first modification, previously de-
scribed, was an adjustment of the age-specific baseline rate of
                               4-26

-------
lung cancer from all causes by eliminating death due to average
background exposure.  This reduced the lifetime risk estimates by
about 15 percent.

     The second modification was based on findings cited  by the
National Research Council in a report completed under a grant
from EPA (Comparative Dosimetrv of Radon in Mines and Homes,
NRC91).  In this publication, a companion to its earlier  BEIR IV
report, the National Research Council compared radon exposures in
mines to those of typical homes.  This comparative study  identi-
fied physical and biological parameters which uniquely apply to
miners in a mining environment and the general population in a
home environment.  Parameter values considered to be significant-
ly different include age- and sex-dependent respiration rate and
volume, breathing route, age at exposure, aerosol size distribu-
tion, unattached fraction, cigarette smoking, and effects of
environmental contaminants other than radon.  The committee also
explored the consequences of various underlying model assumptions
for the efficiency of nasal deposition, the efficiency of bron-
chial deposition, the solubility of progeny in mucus, and the
growth of aerosols in the respiratory tract.  Using the terminol-
ogy of the BEIR IV report (NAS88), if exposure is expressed in
the commonly used unit working level month (WLM), the risk per
unit exposure in the home, (Risk) h/(WLM) h, can be related  to that
in mines, (Risk)m/(WLM)m,  by  a  dimensionless  factor K.
         where:
                          = (Risk) h/ (WLM) h
                            (Risk) J (WLM) m
(Eq.  4-17)
     Thus, if the K factor exceeds unity, the risk per unit of
exposure is greater in the home; if it is less than unity, the
risk per unit of exposure is less in the home.

     Across a wide range of exposure scenarios considered by the
Committee, most values of K were less than unity.  Because
uncertainty remained after the committee's review concerning the
cells of origin of lung cancer, the Committee performed the
calculation separately for basal and secretory cells in the
respiratory epithelium.  The K factors for normal people without
respiratory illness are summarized in Table 4-7.  The Committee
concluded that the risk per unit exposure to target cells in the
respiratory tract tends to be lower for the home environment by
about 30 percent for adults and by 20 percent or less for infants
and children.  Thus, when exposure is chronic (i.e., lifetime),
direct extrapolation of risk estimates from the mining to the
home environment is likely to overestimate the number of radon-
caused lung cancer by about 30 percent.
                               4-27

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Table 4-7.
Summary of K Factors for Bronchial Dose Calculated
for Normal People in the General Environment
Relative to Healthy Underground Miners

               K Factor for the Following
                      Target Cells:
Subject Category
Infant ,
Child,
Child,
Female
Male
age 1 mo
age 1 yr
age 5-10 yr


Secretory
0.74
1.00
0.83
0.72
0.76
Basal
0.64
0.87
0.72
0.62
0.69
     Using the K value of 0.7 for both sexes and all ages, the
adjusted BEIR IV model can be written as:
r(a) = r0(a)
0.0175 T(a)
                              0.5W2)]
                                                        (Eq. 4-18)
where, the parameters are those described previously in equation
4-7 with the difference that & = 0.0175 as a result of the
adjustment for the factor K = 0.7.

     The modified BEIR IV model, when used in a standard  life
table calculation in conjunction with U.S. 1980 vital statistics,
yields a risk factor of 2.24 x 10"4 lung cancer deaths per person
WLM.
 The assessment of radon risk from uranium mill tailings im-
 poundments in this report uses the current EPA risk value of
 2.24 x 10"4 lung cancer deaths per person-WLM.	
                               4-28

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                             CHAPTER 5

       70-YEAR RADON EMISSIONS FROM NON-OPERATIONAL TAILINGS
        IMPOUNDMENTS AND HEALTH RISKS TO NEARBY POPULATIONS
     This chapter provides a quantitative assessment of radon
emissions and risks to nearby populations for the nineteen non-
operational tailings impoundments scheduled for covering as defined
in the Memorandum of Understanding between the EPA and the NRC.
Emission and risk estimates are based on a lifetime exposure of 70
years, beginning December 15, 1991 and ending December 15, 2061.

5.1  THE 70-YEAR ASSESSMENT PERIOD

     The NESHAP 40 CFR 61, Subpart T, specifies that once a uranium
mill tailings pile or impoundment ceases to be operational, it must
be disposed of and brought into compliance, with an emission rate
not to exceed 20 pCi/m2-s, within  two years.   For  the  nineteen
impoundments which were non-operational at the time of rulemaking,
enforcement of Subpart T of 40 CFR 61 would have meant emplacement
of an earthen cover to meet compliance with the UMTRCA emission
standard as by December 15,  1991.   This objective, however, was not
met.  This led the EPA to seek a revised closure date as defined in
the Memorandum of Understanding.  The selection of December 15,
1991 as a start date for the 70-year assessment period provides a
basis for comparing radon emissions and risks for tailings impound-
ments under the MOU disposal dates and the original date specified
by 40 CFR 61, Subpart T.  Emissions' and risk estimates correspond-
ing to the original December 15, 1991 disposal date represent
"baseline values."

     A 70-year assessment period of projected radon emissions
corresponds to the total number of years to which an average
individual may be at risk from uranium mill tailings emissions.
Radon emissions for the 70-year period may involve three discrete
time intervals:

 (1) The first interval corresponds to the standby phase which
     reflects the current configuration of the tailings impound-
     ment.

 (2) The second interval encompasses the time needed to dewater,
     dry, and cover tailings piles.

 (3) The third and final interval is the post-disposal portion of
     the 70-year period, when all tailings piles for a given
     impoundment have been covered and all tailings piles meet
     regulatory emission standards.
                                5-1

-------
     The duration of the three phases is partly linked to the MOU
target date and the need to dewater and dry currently ponded and
wetted tailings before heavy equipment can be used to emplace a
final earthen cover.  Previous estimates assumed a five-year period
for the disposal phase (EPA86).

     In estimating the duration for each of these three phases
within the 70-year time span starting December 15, 1991 and ending
December 15, 2061 for the nineteen non-operational impoundments,
the following protocol was used:

 (1) Disposal period is defined by the five-year period which pre-
     cedes the MOU target date.  For impoundments with MOU target
     dates prior to January 31, 1996, the disposal period is
     obviously less than five years and is defined by the time
     interval between December 15, 1991 and the MOU target date.

 (2) Standby period is defined by that period between December 15,
     1991 and the MOU target date minus five years.  In order for a
     standby period to exist, the MOU target date must be later
     than 1996.

 (3) The post-disposal period is the balance of time remaining and
     is equal to 70 years minus the disposal and standby periods.


     Table 5-1 identifies the nineteen facilities, their MOU target
disposal dates, and the corresponding time periods for standby,
disposal, and post-disposal.  It is assumed that the MOU target
dates are met, and that no extensions of time are needed for
factors beyond the control of the licensees.
                                5-2

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Table 5-1.  Assessment Period for Non-Operational Tailings Impoundments




                                               70 Year Assessment Period
Facility Name/Location
ANC (FAP)/Gas Hills, WY
ARCO Coal, Bluewater, NM
Atlas, Moab, UT
Conoco, Conquista, TX
Ford-Dawn Mining, Ford, WA
Helca Mining, Durita, CO
Homestake, NM: large impound.
Homestake, NM: small impound.
Pathfinder-Lucky Me, GH, WY
Petrotomics, Shirley Basin, WY
Quivera, Ambrosia Lake, NM
Rio Algom, Lisbon, UT
Sohio-L-Bar, Cebolleta, NM
UMETCO, Gas Hills, WY
UMETCO, Maybell, CO
UMETCO, Uravan, CO
UNC, Church Rock, NM
Union Pacific, Bear Creek, WY
WNI, Sherwood, WA
WNI, Split Rock, WY
MOU
Target
Date
1995
1995
1996
1996
2010
1997
1996
2001
1998
1995
1997
1996
1992
1995
1997
1997
1997
1996
1996
1995
(12/15/1991 - 12/15/2061)
Standby
(Yrs)
none
none
none
none
14
1
none
5
2
none
1
none
none
none
1
1
1
none
none
none
Disposal
(Yrs)
4
4
5
5
5
5
5
5
5
4
5
5
none
4
5
5
5
5
5
4
Post-Disposal
66
66
65
65
51
64
65
60
63
66
64
65
70
66
64
64
64
65
65
66
                                      5-3

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5.2  PROTOCOL FOR ESTIMATING RADON EMISSIONS
                                                         >
     Radon emission rates for each of the nineteen non-operational
tailings facilities are estimated on the basis of (1) the tailings
status, (2) areas of the tailings, (3) radium-226 concentrations,
and (4) the duration, in years, for the three phases which make up
the 70-year assessment period.

     The current status of the nineteen facilities was obtained
from the NRC's Uranium Recovery Field Office and cognizant offi-
cials representing Agreement States.  Information included tailings
surface areas, interim cover data, and average radium-226 concen-
trations.  The data are summarized in Table 5-2.

     Estimated radon emissions from dry tailings are based on the
generic emission relationship of 1 pCi Radon-222/m2-s per pCi
Radium-226/g of tailings.  Emissions from tailings with a permanent
cover are either assessed at the design flux levels or the UMTRCA
limit of 20 pCi/m2-s.   Emissions  from tailings  that  are  currently
wet or ponded (i.e., sprayed to mitigate dust and radon emissions)
are assumed to emit no significant levels of radon.

5.2.1  Emissions From Wet and Ponded Areas During Disposal Period

     During the five-year disposal phase, however, wet and ponded
areas undergo a thorough drying before heavy equipment can be used
to install a permanent  earthen cover.  For the five-year disposal
phase, a drying period of four years is assumed with a one-year
period for the installation of a permanent cover.  During the four-
year drying-out period, emissions are assumed to linearly increase
from zero to a maximum value defined by the generic relationship of
1 pCi Radon-222/m2-s per 1 pCi Radium-226/g  of  tailings.   In the
fifth and final year of the disposal phase,  covering of all dried
areas  (i.e., recently dried and previously dried areas)  commences
and progresses throughout the year at a constant rate.  During the
fifth and final year of disposal, radon emissions are assumed to
linearly decrease from the maximum dry level to 20 pCi/m2-s, the
final emission rate assumed for all impoundments that do not now
have a permanent cover.

     For impoundments whose MOU target dates do not allow for a
full five-year disposal period, the start date for drying out of
wet or ponded areas is assumed to have begun prior to December 15,
1991 so that a five-year disposal period is achieved.  For example,
an impoundment with a MOU target date of 1995 will be assumed to
have started the dewatering and drying process in 1990,  or one year
prior to the start of the 70- year assessment period.  Starting
emission rates from tailings areas, which have had one year of
drying as of December 15, 1991, are assumed to be 25 percent of
their maximum dry state  (i.e., (0.25) x  (1 pci Radon-222/m2-s  per 1
pCi Radium-226/g)).
                                5-4

-------
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                                                            5-5

-------
5.2.2  Interim Covered Areas

     Tailings with an interim cover are assumed to remain status
quo during the standby phase and the first four years of the
disposal phase.  The installment of a permanent cover is assumed to
coincide with those of recently and previously dried tailings in
the fifth and final year of disposal.

     Of the twenty impoundments, all but three have interim covers
over portions of their tailings.  An interim cover significantly
reduces radon as well as particulate emission.  Its effectiveness
depends mainly on moisture content, porosity, and cover depth
(EPA86).  The relationship between the flux from an interim covered
surface to the flux from a bare dry tailings surface is described
by equation 5-1:
              =  FDT e
                                       ,-bx
                                                           (Eq. 5-1)
            where:
                •1C
                •DT
   is the flux through interim cover (pCi/m2-s)

   is the flux through dry tailings (pCi/m2-s)

b  is a coefficient dependent upon the moisture
   content, bulk density, specific gravity and
   porosity of the soil used

x  is the cover thickness in cm
Table 5-3 provides representative values for b for specific earth
types and moisture content.


Table 5-3.  Coefficient b Values for Select Soil Types
                       and Moisture Content1
         Earth Type
             %  Moisture
Coefficient b
A Sandy Soil
B Soil
C Soil
D Compacted Moist
3.4
7.5
12.6
17.0
0.00699
0.00937
0.01350
0.01850
         Soil

         E-Clay

          1  Reference:   EPA89
                21.5
   0.02553
                                5-6

-------
     The approximate effectiveness of these various types  of earth
covers in reducing radon-222 emissions is graphically depicted in
Figure 5-1.  The  application of almost any type of earth will
initially affect  a rapid decrease in radon emission.  For  example,
an interim cover  of 0.5 meter (1.6 feet) or 1 meter  (3.3 feet),
which consists  of type B soil with a moisture content of 7.5%,
would result in reductions of radon-222 emissions of 37 and 60
percent, respectively.   Installed interim covers commonly  consist
of local native soil,  which can be assumed to represent B  soil with
a 7.5 percent moisture content.   When the depth of the interim
cover is known, radon-222 emission rates are calculated using
equation 5-1 with the appropriate b coefficient value.  When earth
type is not known,  the interim cover is assumed to consist of B-
soil with 7.5 percent moisture content having a b-coefficient value
of 0.00937.
               100
                  BADON PENETRATION {%)
        CIS
        LJ
                                  EARTH- TYPE - •

                                     A S4NBY--SOIL--

                                     B SOIL

                                     C SOIL

                                     D COMPACT MOIST SOIL

                                     E CLiY- - -
        t"c¥
12345

 EARTH COVER THICKNESS (meters)
          Figure 5-1.
 Changes in Radon-222 Penetration with Earth
 Cover Thickness  (adapted  from EPA89).
                                 5-7

-------
     For impoundments with tailings where the thickness of the
interim cover was not available, emanation rates are assumed to be
50 percent of their maximum value  (i.e., FIC/FDT  =  0.5).

5.2.4  Sample Calculation

     A sample calculation, which estimates radon emissions, is
provided below and serves to illustrate the methodology used to
calculate radon emissions for the nineteen non-operational tailings
facilities:

 Problem; Calculate the radon-222 emissions for Pathfinder-Lucky Me
          for (1) the 70-year assessment period (12/15/1991 -
          12/15/2061) under the revised UMTRCA regulations/MOU
          target date and (2) 70-year baseline emissions.
 Given;
          MOU target date 1998

          Current tailings, characteristics
                 Wet
                 Ponded
                 Dry
                 Interim Cover

                      Total:  =
    24,000 m2
    36,000 m2
         Om2
=  761.000 m2

   821,000 m2
          No information was available about the interim
          cover with regard to earth type and depth of
          cover.

          Average radium-226 concentration in tailings is
          220 pCi/g.
Solution: Emissions must be calculated separately for wet, ponded,
          and covered areas and for each of the three time periods.


  1. Standby Period;  During the standby period of two years, the
     wet and ponded areas are assumed to be non-fluxing.  The
     interim covered area of 761,000 m2 can be assessed by the
     equation:
                            •ic
                               =  F
                                   DT
                                      ,-bx
                 (see equation 5-1)
     Since no information about earth type and cover depth was
     available, it will be assumed that FIC/FDT =  0.5.   This  implies
     that the radon flux from the interim covered tailings will be

                                5-8

-------
   one-half  of the maximum flux for dry uncovered tailings of 220
   pCi/m2-s.

   Radon emissions for the two-year standby period for interim
   covered tailings are:

     Rn-222 Emissions,,^ = (220 pCi/m2-s) (0.5) (3. 1536 x 107s/y) (761,000 m2) (2y)

     Rn-222 Emissions,,,,, = 5280 Ci
2. Disposal  Period;  During the five-year disposal  period, wet
   and ponded areas will be dewatered and dried  for the first
   four years.   In the fifth and final year, a permanent earthen
   cover  is  installed that meets the UMTRCA emission standard of
   20 pCi/m2-s.

   During the first four years,  emissions are assumed to linearly
   increase  from 0 to a maximum of 220 pCi/m2-s with an  average
   value  of  110 pCi/m2-s.   During the  final  (fifth)  year,  emis
   sions  are assumed to decrease from 220 pCi/m2-s to 20 pCi/m2-s
   with an average value of 120 pCi/m2-s.

   During the disposal period,  tailings with interim cover are
   conservatively assumed to remain unchanged for the first four
   years.  A permanent cover is assumed to be installed during
   the fifth and final year of  the disposal period  and coincides
   with the  permanent cover installation of the  previously wet
   and ponded areas.

     a.   Radon emissions from interim covered tailings  (i.e.,
          FIC/FDT = 0.5) :
                                        L) (3.1536xl07s/y) (ly)]  761,000m2
     Rn-222IC = [(220 pCi/m2-s) (0. 5 ) (3. 1536xl07 s/y) (4y) +

                110 pCi/m2-s+20 pCi/m2-s.

                          2

     Rn-222IC =  12,120 Ci

b.  Radon  emissions from wet and  ponded tailings:

     Rn-222w/P = [(110 pCi/m2-s) (3.1536xl07s/y) (4y) +

                (120 pCi/m2-s) (3.1536xl07s/y) (ly)] 60,000m2

     Rh-222w/P =  1059 Ci

c.  Radon  emission for the  five-year disposal period from
    all tailings:
          Rn-222Di3p08aI
               =  Rn-222,,
+  Rn-222v
          Rn-222
               Disposal
               =  12,120 Ci  +  1059 Ci
          Rn-222Disposlll  =  13,179 Ci
                                5-9

-------
 3.  Post-Disposal  Period;   During the post-disposal period of  63
     years, all permanently covered tailings are assumed to be
     fluxing at the UMTRCA emission limit of 20 pCi/m2-s.

     Radon emissions for the post-disposal period:

       Rn-222PD  =   (20 pCi/m2-s) (3.1536 x 107s/y) (63y) (821,000 m2)

       Rn-222PD  =   32,634 Ci

     Table 5-4 summarizes emissions for the Pathfinder-Lucky Me
Facility.
    Table 5-4,
 Period
Summary of Emissions for the  Pathfinder-Lucky Me
              Facility

  Covered      Wet      Ponded    Dry      Total
 (761,000m2) (24,000m2) (36,000m2)   (Om1)   (821,000m2)
Standby
(2 years)
Disposal
(5 years)
Post— Disposal
(63 years)
5280 Ci
12,120 Ci
30,249 Ci
0
424
954
0
Ci 635 Ci
Ci 1431 Ci
Total Emission,
0
0
0
Ov
5280 Ci
13,179 Ci
32.634 Ci
= 51,093 Ci
     Emissions  for  the baseline condition involves estimating radon
releases for the  70-year period (i.e., 12/15/1991 - 12/15/2061)  if
the tailings had  been covered as of 12/15/1991, as required  in 40
CFR 61, Subpart T.   For baseline conditions, radon emission  is
estimated at a  constant rate of 20 pCi/m2-s  for the full duration
of 70 years.

       Rn-222BajcIi]10 =  (20 pCi/mz-s) (3.1536xl07s/y) (70y) (821,000 m2)

       Rn-222BM<:1jno =  36,260 Ci
5.3  RADON EMISSIONS FROM NON-OPERATIONAL TAILINGS IMPOUNDMENTS

     Estimates  of radon emissions for each of the non-operational
impoundments  cited in the MOU are provided in Table  5-5.   Emissions
are provided  where applicable for the standby period,  disposal
period, and post-disposal period.  Emissions, when summed,  provide
an estimate of  the cumulative radon that is released over the 70-
year assessment period.
                                 5-10

-------
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     Table 5-5 also provides 70-year baseline emissions, which
represent the hypothetical releases that would have been expected
if impoundment facilities had been able to meet the original target
date of December 15, 1991 for permanent disposal, as defined by
Subpart T of 40 CFR 61.

     An assessment of these two disposal schedules reveals that the
collective 70-year emissions corresponding to the MOU disposal
schedule of about 810,000 Ci exceeds the collective 70-year base-
line emissions of about 520,000 Ci by 290,000 Ci.  Correspondingly,
this difference in cumulative emissions yields annual average
facility emission rates that differ by a factor of about 1.6 (i.e.,
average annual facility emissions of 610 Ci/y versus 390 Ci/y).

     Based on radium-226 concentrations, the emplacement of a
permanent cover is expected to reduce radon emissions by one to two
orders of magnitude from the maximum emission rate of dry tailings.
Nevertheless, post-disposal releases appear relatively significant.
In fact, for eleven impoundments, the largest cumulative release
occurs during the post-disposal period when a permanent cover has
been installed.  This seeming paradox, however, is resolved by
noting that the average post-disposal period represents 64.7 years
or 92.4 percent of the 70-year assessment period.  For the same
reason, the average annual emission rate for the 70-year assessment
period is low since this value is also dominated by the lengthy
post-disposal period.

     Variations in emission rates over the 70-year assessment
period are quantitatively and graphically depicted in the illustra-
tion provided below for Pathfinder's Lucky Me facility.  During the
two-year standby phase, emissions are estimated at 2640 Ci/y.
Emission rates increase linearly during the first four years of the
disposal phase, reaching a maximum value of 3056 Ci/y.  During the
fifth and final year of the disposal phase, the emplacement of the
permanent earthen cover steadily reduces emissions to the final
level of 518 Ci/y.  The emission rate of 518 Ci/y meets the UMTRCA
standard and is assumed to remain constant for the full duration of
the 63 year post-disposal phase ending in the year 2061.

5.4  POPULATION EXPOSURES AND HEALTH RISKS

     The previously described CAP88-PC model was used to estimate
the down-wind radon exposures from tailings emissions  (see Appendix
A).  When public exposure is assessed, the two parameters of
concern are:   (1) the lifetime fatal cancer risk to the individu-
al (s) experiencing the maximum risk (MIR) and  (2) the annual
collective risk to near-field residents.  Exposure estimates are
based on historical site-specific meteorological conditions and
empirical population data which identify residents by distance and
sector.
                                5-12

-------
            ILLUSTRATION:   70-YEAR EMISSION PROFILE FOR LUCKY MC
Data Elements:
  1.  MOU target disposal  date 1998
  2.  Average Radium-226 Concentration:  220 pCi/g
  3.  70-year Assessment Period:
      Standby = 2 yrs;  Disposal  = 5 yrs;  Post-Disposal = 63 yrs
  4.  Current Tailing Surface Area (m2  x  103) :
      Ponded = 36;  Wet =  24;  Dry = 0;  Interim Cover = 761;  Total  =  821

Emission Rates:
  E[  = Current/Standby Emission  Rate
      = (Interim Covered Area)(Flux)
      = (7.61E+5 m2) (110 pCi/m2-s)   =  2640 Ci/v

  E2  = Maximum Emission Rate - (Maximum emission rate is the combined
        emission of areas  with interim cover and those from dried areas
 .       (i.e., currently wet and  ponded).
      = (7.61E+5 m2) (110 pCi/m2-s)  + (6.00E+4 m2) (220  pCi/m2-s)
      =  2640 Ci/y + 416 Ci/y  =   3056 Ci/v

  E3  = Post-Disposal Emission Rate
      = (Total Area)(UMTRCA Emission Flux)
      = (8.21E+5 m2) (20  pCi/m2-s)   =  518 Ci/v
     Total

   where:
                                  t2(.
            = 2 yrs;  t2 = 4 yrs;  t3 = 1 yr;
   2

63 yrs
Total Emissio^  =  2x2640-^(4) ( 2640+3056 )-^ (1) ( 3056+518 )

  Total  Emission,,™,..™^  = 51,093 Ci
                                          2      '  *~' "      2

                                        Averags Emission Rate = 730 Ci/y
          4000


          3500


          3000


          2500


          2000


          1500


          1000


           500


            0
              Emission Rate (Ci/yr)
             '90 '91 '92 '93 '94 '95  '96  '97  '98  '99 2000

                                      Year
                                                '58  '59  '60  '61  '62  '63
                                     5-13

-------
     Due to the prevailing winds, which favor some sectors over
others, the maximum individual risks are not necessarily experi-
enced by the residents closest to the sites.  Prevailing winds also
influence the dose distribution and affect the cumulative popula-
tion exposures to individuals residing within the 0-80 km radii of
the impoundment facilities.  All exposures conservatively assume
that individuals spend 100 percent of their time at their residen-
tial location (i.e., 75 percent indoors and 25 percent outdoors).

     Table 5-6 provides summary data for each facility based on the
MOU disposal schedule.  The values are derived as follows and are
illustrated by using the Pathfinder-Lucky Me facility as an exam-
ple:

   • Average Radon Emission (Column #1).  This value represents the
     yearly average radon emissions (Ci/y) for the 70-year assess-
     ment period starting December 15, 1991 and ending in 2061.

     For the Lucky-Mc facility, the 70-year assessment period
     includes a 2-year standby, a 5-year disposal, and a 63-year
     post-disposal period  (see Table 5-1).  For the 70-year peri-
     ods, it was estimated that a total of 51,093 Ci would be
     released yielding an average annual value of 730 Ci (see Table
     5-5) .

   • MIR Radon Concentration  (Column #2).  The tailings enhanced
     average radon-222 concentrations for the MIR is a site-specif-
     ic value which is defined by meteorologic and population data.

     Appendix B provides a computer generated Synopsis Report for
     the Lucky-Mc facility.  Based on prevailing wind and air
     dispersion, the maximally exposed individual is located 25,000
     meters north of the tailings where the radon concentration is
     8.77E-4 pCi/1 above prevailing background.

   • MIR Decay Product Concentration  (Column #3).  Radon concentra-
     tions in Column #2 are converted to concentration levels of
     radon-222 progeny by means of an appropriate equilibrium
     fraction.  Values for the indoor/ outdoor equilibrium fraction
     vary with radon plume travel time and, therefore, distance
     from tailings.


     To determine the decay product concentration for the Lucky
     He's MIR, which is to an individual that is located at 25,000
     meters, the effective equilibrium fraction of 0.698 is used
     (see Table 4-1):

     Decay Prod. Cone.(WL) =  (Radon Cone.)(Equil. Fraction)
                           =  (8.77E-4 pCi/1)(0.698)(1WL/100 pCi/1)
                           =  6.12E-6 WL
                                5-14

-------
     MIR Lifetime Fatal Cancer risk (Column #4) .  Risk values  are
     derived by:   (1)  integrating the exposure to radon progeny
     over the 70-year exposure duration, which yields exposure in
     the conventional time- integrated unit of WLM, and (2) multi-
     plying the derived WLM value times the EPA risk coefficient.

     For the Lucky Me MIR,  the lifetime fatal risk of cancer is
     derived as follows:
                =  (70 y exposure) (Cancer Risk Coefficient)
       Riskcmoer
 = (6.12E-6 WL)(24h/d x 365d/v x 70vl(2.24E-4 cancer/WLM)
                  170 hr/m

= 4.95E-06  (lifetime)
   • Population  Decay Product Concentration (Column #5).  This
     value represents the collective air concentrations of radon
     progeny  for all  residents residing within 80 km of the
     facility.

     The computer-generated collective exposure of 2.29E-2 WL for
     the Lucky Me population is not readily derived manually, and
     represents  the sum of population weighted air-concentrations
     at residential locations defined by sector and distance (see
     Table 1  of  Appendix B).

  •  Population  Annual Fatal Cancer Risk (Column #6).  The annual
     risk to  the 0-8O km population is derived by integrating
     population  exposures to radon progeny over a one year period
     and multiplying  the derived person-WLM/y times the EPA's risk
     coefficient.

     The annual  fatal cancer risk to the 0-80 km population for the
     Lucky-Mc facility is derived as follows:

       Risk,,,,,,.,.,   =  (2.29E-2 person-WL) (24 h/d x 365 d/vl(2.24E-4 cancer/WLM)
                                      170 h/m

       Risk^^.   = 2.64E-04 cancers/

     Variations  in exposures  and risks among facilities differ by
two to three  orders of magnitude.  For lifetime fatal risks to
the maximally exposed individuals,  values range from a low
probability of 3.79E-6 (ANC,  Gas Hills)  to a high of 2.70E-4
(Hecla Mining) among  the nineteen facilities under the MOU
disposal schedule (see Table  5-6).   Variations in the risks to
the MIR primarily reflect radon emission rates and distances from
the impoundment  facilities.   The collective annual fatal cancer
risks to the  0-80 km  population show a similar variation.   The
low annual population cancer  risk of 1.19E-4 (Hecla Mining,
Durita) is two orders of magnitude lower than the highest value
of 1.20E-2 cancer death per year corresponding to Conoco's
                               5-15

-------
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Conquista facility.  In addition to radon emission rates, the
principal factors affecting variations in population risks are
population size and distribution within the 80 km radii.

     The annual population fatal cancer risks for all nineteen
facilities combined are 3.48E-2 deaths per year with an average
value of 1.8E-3 deaths/year.  Based on these probabilities, a
single fatal cancer is estimated for the cumulative exposures
from all facilities over a 29 year period.  For a single facili-
ty, the average probability of one fatal cancer over the 70-year
assessment period is about 0.13.

     For comparison, baseline radon-222 exposures and associated
risks are provided in Table 5-7.  Fatal cancer deaths for all
nineteen facilities is 2.26E-2, with an average of 1.19E-3 deaths
per year.  The reduced radon emissions and risks representing
baseline values are those that would have been expected had all
nineteen non-operational facilities been able to meet the origi-
nal CAA disposal date of December 15, 1991.  A comparison of
values from Table 5-6 and 5-7 show that the baseline emissions
and risks are nearly a factor of two lower than those correspond-
ing to the MOU disposal schedule.

     Any extentions in the times for covering the piles beyond
the MOU target dates would increase total emissions and total
risk from the piles.  There would be no changes in baseline
emissions or risk.

5.5  MEASURED RADON EMISSION LEVELS

     There has been relatively little experience with measure-
ments determining the effectiveness actually achieved by the
radon covers placed on uranium mill tailings piles.  This is
because few Title II piles have been covered under Subpart T and
because testing the effectiveness of covers was not required for
Title II piles under UMTRCA.  The available evidence, some of it
from Title I piles that are being reclaimed by the Department of
Energy, indicates that the actual level of emissions through the
radon covers is considerably lower than the 20 pCi/m2-s  flux
standards in Subpart T and UMTRCA, generally lower by a factor of
two to ten.  The probable reason is that clay andsoilwith high
clay content have proven to be more readily available at the mill
tailings sites than was assumed in the cost analyses performed
for the UMTRCA and the 1989 Subpart T rulemakings.  The superior-
ity of clay as a cover material can be seen in Figure 5-1; it is
considerably more effective for a given depth of cover than are
other cover materials.
                               5-17

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                              CHAPTER  6

                    RADON-222 CONTROL TECHNIQUES


     This chapter provides a  brief discussion of specific tech-
niques employed for  interim and  long-term control of radon emis-
sions from the tailings piles.   Also discussed are methods used to
dewater and dry the  tailings  impoundment areas before a permanent
cover can be installed.

6.1  INTERIM RADON CONTROL TECHNIQUES

6.1.1  Water Spraying

     Saturating tailings with a water sprinkling system effectively
reduces radon-222 emissions to nominal levels.  The degree of
radon-222 control increases slightly  with the depth of the water.
Factors affecting the effectiveness of this practice include the
mill water recirculation rate (if any), evaporation and precipita-
tion rates, impoundment construction  and slope, phreatic levels,
ground water contamination potential, and dike or dam stability.
Some above-grade tailings impoundments minimize the depth of the
water to reduce seepage and possible  ground water contamination
through the use of overflow pipes, which direct water to separate
evaporation ponds.   (Strict ground water contamination standards,
as specified in 40 CFR Subpart D 192.32, will frequently determine
the degree of water  cover maintained  in an active area.)

6.1.2  Interim Soil  Cover

     An application  of an interim earthen cover on dry portions of
a tailings impoundment reduces radon-222 emissions prior to final
reclamation.  The effectiveness of the interim cover in reducing
radon emissions is determined by the  earth-type used and the thick-
ness of the cover (see Chapter 5, Figure 5-2).  For example, a 0.3
meter (1 foot)  or a  1 meter (3.3 foot) thick soil cover having 8
percent moisture content would theoretically reduce radon-222
emissions by about 25 and 62 percent, respectively.

     Site characteristics that control or prohibit the applica-
bility of interim cover include impoundment design and construc-
tion; dam height; stability; phreatic level; permeability; site
water balance;  evaporation rates; presence and availability of
suitable earth cover material.  Operating factors such as expected
uranium production rate, length and number of standby periods,
impoundment capacity, and expected mill life must also be consid-
ered in determining applicability of  interim covers.
                                6-1

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6.2  DEWATERING OF TAILINGS PILES IN PREPARATION FOR PERMANENT
     COVER

     During operational and standby phases of uranium milling, a
water cover over the tailings piles is commonly used as a radon
reduction technique.  Prior to final reclamation, the tailings
disposal area, however, must be dewatered and dried in order to
permit the use of heavy equipment for permanent cover installation.
Past and current uranium tailings disposal methods have relied
exclusively upon exposure of the surface of the impounded tailings
to sunlight and winds for drying.  Rates of evaporation vary
considerably with climate, but are generally very high in those
states which produce most of the uranium.

     The time required to dewater a tailings pile can vary consid-
erably, based on many factors such as size of the tailings disposal
area, the uranium recovery process utilized, the disposal manage-
ment system employed, the method used for dewatering, etc.  As
mentioned above, the most commonly used method for dewatering the
tailings piles is natural evaporation.  Although evaporation rates
are greatly dependent on climate, the majority of uranium mill
sites are located in semi-arid, dry areas of the country.

     In order to expedite site reclamation and consolidation of the
tailings pile, it is common for the owners of the mill to employ
the use of an enhanced evaporation system.  The evaporation process
is greatly enhanced through the use of a pumping and spraying
distribution system.

     In addition, tailings embankments are generally recontoured
and surface water diversion systems are constructed for the purpose
of directing rain and snow runoff away from the tailings area.

     Based on the above consideration and iridustry/DOE experience
to date, the NRC, in the Final Generic Environmental Impact State-
ment On Uranium Milling (NRC80), utilized a five-year disposal
period for the tailings pile in their assessment of the "model"
mill, which was considered to be representative of the milling
industry.  This five-year disposal period has been commonly adopted
in other uranium mill environmental assessments  (NRC80).

     Processes that reduce the liquid content of impounded tailings
also reduce the potential for seepage problems, by reducing the
source of and driving head for seepage.  In addition, tailings with
a low moisture content will consolidate more rapidly and add to the
stability of the tailings mass, thus reducing problems associated
with final impoundment drying and reclamation.

     The most common engineered method of reducing the water
content in the tailings is in-situ dewatering.  This is accom-
plished by permitting gravity draining of liquids to a tailing low
point  (sump pit) from which clear decanted liquid is withdrawn and

                                6-2

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recycled and/or transported to an evaporation pond.  An underdrain
system, generally consisting of a network of slotted PVC piping
covered by a blanket of sand and/or gravel and supported by the
low-permeability impoundment bottom, is used to withdraw free
liquid from the tailings.  Water, which collects in the sump pit,
can then be pumped back to the mill for reuse or directed to an
evaporation pond.  This not only reduces the phreatic surface of
the liquids in the tailings (the driving force for seepage), but
also increases the stability of the tailings mass.


6.3  LONG-TERM RADON CONTROL TECHNIQUES

6.3.1  Earth Cover

     Covering the dried tailings with soil is a proven effective
method for reducing radon-222 emissions (Ro84).  The depth of soil
required for a given amount of control varies with the type of
earth and radon-222 exhalation rate.

     Earth covers decrease radon-222 emissions by retaining the
radon-222 released from the tailings long enough so that a major
portion will decay in the cover.  A large decrease in radon-222
emissions is achieved by applying almost any type of earth.  Radon-
222 diffusion through earth is a complex phenomenon affected by
processes such as molecular diffusion, described mathematically by
Pick's law.  These complex parameters have been evaluated by Rogers
and Nielson (Ro81) and were described in Chapter 4.  Diffusion
depends greatly on the porosity and moisture content of the medium
through which it occurs. Therefore, high-moisture content soils,
such as clay, provide greater radon-222 emission reduction because
of their smaller diffusion coefficients.

     In practice, earthen cover designs must take into account
uncertainties in the measured values of the specific cover mater-
ials used, the tailings to be covered, and predicted long-term
values of equilibrium moisture content for the specific location.
The uncertainty in predicting reductions in radon-222 flux in-
creases rapidly as the radon-222 emission limit is reduced.

6.3.2  Asphalt Covers

     Asphalt cover systems have been proposed as a radon-222
control technique because such systems exhibit very low radon-222
diffusion coefficients.  The Pacific Northwest Laboratory  (PNL) has
investigated controlling the release of radon-222 through use of
asphalt emulsion covers for DOE's Uranium Mill Tailings Remedial
Action Project (UMTRAP).  Results have shown asphalt emulsion cover
systems to be effective at substantially reducing radon-222 emis-
sions, and field tests  indicate that such systems have the proper-
ties necessary for long-term effectiveness and stability.  Of the
various types of asphalt cover systems that were researched, an

                                6-3

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 asphalt emulsion admix seal  was  found  to  be  the most  effective
 (Ha84;  Ba84).

      Based on  cost estimates for application of a  full-scale
 asphalt cover  (Ba84),  asphalt cover  systems  could  prove to be
 economically competitive with earthen  covers at some  existing
 sites.   These  cost estimates are applicable  to relatively flat
 sites,  which may require regrading before these techniques could
 be applied.  Long-term cover protection,  in  the form  of gravel or
 vegetation above an earthen  cover applied over the asphalt radon-
 222 barrier, may also  have to be considered.

 6.3.3   Soil  Cement Covers

     A  mixture of soil and Portland  cement,  called soil cement, is
 widely  used  for  stabilizing  and  conditioning soils (Pc79).  The
 aggregate  sizes  of tailings  appear suitable  for soil  cement, which
 is relatively  tough, withstands  freeze/thaw  cycles, and has a
 compressive  strength of 300  to 800 psi.   When combined in a dispos-
 al system  with a 1-meter earth cover,  soil (tailings) cement would
 likely  provide reasonable resistance to erosion and intrusion,
 substantially  reduce radon releases, and  shield against penetrating
 radiation.  A  previous study (EPA82) has  estimated that soil cement
 covers  would control emissions to approximately the same levels as
 a 2-meter  earth  cover.  Costs are expected to be comparable to
 those of thick earth covers.   The long-term  performance of soil
 cement  is  unknown,  especially as tailings piles shift or subside
 with age.  When  placed over  large surface areas, soil cement
 typically  cracks at various  intervals.    The importance of this
 cracking on the  effectiveness of soil  cement has not been evalu-
 ated, but  is expected  to be  small.

 6.3.4   Other Radon Control Techniques

     A  number  of other radon control techniques have been proposed
 and subjected  to preliminary evaluations  for applicability.
 Several of these techniques  are  summarized below.

     Synthetic Covers  and Chemical Sprays.   Synthetic material such
 as a polyethylene sheet can  reduce radon-222  emissions if carefully
 placed  and sealed on dry tailings.   The overall effectiveness of
 synthetic  covers  is not known since  leaks occur around the edges
 and at  seams and breaks.  Synthetic  covers also have a limited
 life, especially in dry, sunny,  windy  areas,   and will not provide a
 long-term  barrier to radon-222.   Such  a barrier would aid,  at least
 temporarily, in  the control  of radon-222  if  a soil cover material
were subsequently applied.

     Chemical  stabilization  sprays that form coatings on the dry
 tailings are effective  for controlling dust,  but are not effective
 in controlling radon-222 since an impermeable cover is not ob-
 tained.
                                6-4

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     The  lack of  long-term stability of synthetic covers and the
 ineffectiveness of chemical sprays make these options unsuitable
 for  long-term passive control.

     Thermal Stabilization.  Thermal stabilization is a process in
 which tailings are sintered at high temperatures.  The Los Alamos
 National  Laboratory has conducted a series of tests on tailings
 from four different inactive mill sites (Dr81).  The results show
 that thermal stabilization is effective in preventing the release
 (emanation) of radon from tailings.  However, before thermal
 stabilization can be considered as a practical disposal method,
 information is needed on the following: (1) the long-term stability
 of the sintered material; (2) the interactions of the tailings and
 the  refractory materials lining the kiln; (3) the gaseous and
 particulate emissions produced during sintering of tailings; and
 (4)  revised engineering and economic analysis as more information
 is developed.

     Since gamma  radiation is still present, protection against the
 misuse of sintered tailings is required.  While the potential
 health risk from  external gamma radiation is not as great as that
 from the  radon decay products, it can produce unacceptably high
 exposure  levels in and around occupied buildings.  Also, the
 potential for groundwater contamination may reguire the use of
 liners in a -disposal area.

     Chemical Processing.  The Los Alamos National Laboratory has
 also studied various chemical processes such as nitric acid leach-
 ing  to extract thorium-230 and radium-226 from the tailings, along
 with other materials (Wm81).  After removal from the tailings, the
 thorium and radium can be concentrated and fixed in a matrix such
 as asphalt or concrete.  This greatly reduces the volume of these
 hazardous materials and allows disposal with a higher degree of
 isolation than economically achievable with unextracted tailings.

     The  major question regarding chemical extraction is whether it
 reduces the thorium and radium values in the stripped tailings to
 safe levels.  If processing efficiencies of 80 to 90 percent were
 attained, radium concentrations in tailings would still be in the
 30 to 60  pCi/g range.  Thus, careful disposal of the stripped
 tailings  would still be required to prevent misuse.   Another
 disadvantage of chemical processing is the cost, although some of
 the  costs might be recovered from the sale of other minerals
 recovered in the processing (Th81).

     Deep-Mine Disposal.  Disposal of tailings in worked-out deep
mines offers several advantages to surface disposal options.  The
probability of intrusion into and misuse of tailings in a deep mine
 is much less than in the case of surface disposal.   Radon releases
to the atmosphere would be eliminated,  for practical purposes, as
would erosion and external radiation.   The major disadvantage of
deep mine disposal is the potential contamination of groundwater

                                6-5

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resulting from leaching of radionuclides and other toxic chemicals
from the tailings.  Overall, while this method can provide a
relatively high level of protection against exposure to radon and
misuse of tailings, it has a high potential for causing serious
groundwater contamination which is very costly to control.

     Caliche Cover.  Caliche (calcium deposits that form within or
on top of soil in arid or semi-arid regions) cover material for
mill tailings piles has been suggested as a control method (Br81).
This material may be effective in precluding excessive mobilization
of certain radionuclides and toxic elements.  However, the effec-
tiveness and long-term performance of such covers have not been
adequately assessed.


6.4  COMPARISON OF EARTH COVERS TO OTHER CONTROL TECHNIQUES

     In comparison to other control technologies, earth covers have
been shown to be the most cost effective (NRC80).  Apart from cost
considerations, earth covers as a method to control radon-222
emissions also offer several other benefits.  For example, syn-
thetic covers, such as plastic sheets, do not reduce gamma radia-
tions.  However, earth covers that are thick enough to reduce
radon-222 emissions will reduce gammp. radiation to insignificant
levels.  Further, chemical and physical stresses over a substantial
period of time destabilize synthetic covers; earth covers are
stable over the long term, provided the erosion caused by rain and
wind is contained with vegetation or rock covers, and appropriate
precautions are taken against natural catastrophes, e.g., floods
and earthquakes.

     Earth covers also reduce the likelihood of groundwater contam-
ination resulting from either storing radioactive materials in
underground mines  (typically located under the water table) or from
using the leaching process to extract radioactive and nonradioac-
tive contaminants from mill tailings.  Moreover, although under-
ground mine disposal is an effective method to protect against
degradation and intrusion by man, it nevertheless incurs a social
cost.  For example, storing tailings in underground mines elimi-
nates the future development of the mines' residual resources.
Again, earth covers with proper vegetation and rock covers can
protect against human intrusion, without incurring such social
costs.

     Finally, earth covers provide more effective long-term stab-
ilization than either water or soil cement covers.  Inasmuch as
soil cement covers are comparable to earth covers in terms of cost
effectiveness, their long-term performance is as yet unknown.
Water covers, on the other hand, depend upon long term institution-
al oversight.  Institutional controls cannot be relied upon over
time periods as long as 1000 years or more.  Moreover, earth covers
are more practical than water covers in arid regions.

                                6-6

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     The standards established for long-term control of residual
radioactive materials from inactive uranium processing sites under
UMTRCA (40 CFR 192, Subpart A) require the following:


     "... Control shall be designed to:  (a) Be effective
     for up to one thousand years, to the extent reasonably
     achievable, and, in any case, for at least 200 years,
     and,  (b) Provide reasonable assurance that releases of
     radon-222 from residual radioactive material to the
     atmosphere will not:  (1) Exceed an average release rate
     of 20 picocuries per square meter per second, or (2)
     Increase the annual average concentration of radon-222 in
     air at or above any location outside the disposal site by
     more than one-half picocurie per liter."


     It has been decided that the earth cover will serve as the
radon control technique  (specified by 10 CFR 40, Appendix A) which
currently provides the most cost effective means of satisfying the
UMTRCA control standards.
                                6-7

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                             CHAPTER 7

                         COSTS AND BENEFITS

     The perspective from which the costs and benefits of this
rulemaking are assessed is addressed in the first section of this
chapter.  The costs of covering the piles and the financial burden
this imposes on the mill tailings industry are discussed in Sec-
tions 7.2 through 7.4, and in Section 7.6.  Costs and benefits are
compared in Section 7.5.  The regulatory flexibility analysis is in
the last section of this chapter.

7.1  THE COSTS AND BENEFITS OF RADON COVER IN PERSPECTIVE

     The 20 pCi/m2-s radon emissions  limit used throughout  this
analysis was established in the 1983 UMTRCA rulemaking.  That
rulemaking found that the costs of achieving a 20 pCi/m2-s  limit
were justified by the reduction in radon induced fatal cancers.
The 1989 CAA rulemaking reaffirmed the 20 pCi/m2-s  limit, finding
that it was safe with an ample margin of safety.  The rulemaking
discussed in this BID does not alter those decisions, nor does it
reconsider the results of those rulemakings.  The costs and bene-
fits of covering the uranium mill tailings piles in order to
control radon emissions are not changed.

     However, there are other costs and benefits specifically
associated with the rulemaking addressed in this BID.  They are
separate from the costs and benefits discussed in the paragraph
above and are dealt with separately.   These costs and benefits are
evaluated from the perspective of the situation as it existed at
the end of 1991, after the MOU between EPA, NRC and the Agreement
States on Subpart T had been signed.   The mill tailings piles
subject to the MOU did not have completed radon covers at that
time.  Under provisions of Subpart T as enacted, they were to have
had permanent radon covers by December, 1991.  The MOU postponed
the time for achieving final cover; effectively reducing the costs
to the mill operators of meeting the cover requirements because it
delays the time when the expenditures were to have been made.  The
MOU also allowed an increase in the overall fatal cancers caused by
emissions from the piles by allowing emissions to continue past the
end of 1991.  From this perspective,  the cost to society of this
rulemaking becomes the increased fatal cancers caused by the
extended period of radon emissions and the benefit to society
becomes the reduction in costs due to the delay in covering the
piles.

     The increased fatal cancers resulting from this rulemaking are
presented in Chapter 5 and the cost savings are presented in the
next three sections of this chapter.
                                7-1

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7.2  COSTS OF COVERING THE PILES

     The costs of covering the piles subject to the MOU are devel-
oped in this section.  Earthen covers placed on the tops and sides
of uranium mill tailings piles have been demonstrated to be a cost-
effective means of providing long-term control of radon emissions.
This chapter presents cost estimates for the placement of earthen
covers which meet the 20 pCi/m2-s  emissions  limit  for  the  currently
non-operational tailings impoundments.

     The cost of earthen cover varies with the geographic location
of the tailings impoundment, its layout, the topography of the
disposal site and its surroundings, and the thickness of the cover
required to achieve the emission standard.  The cost also varies
with the availability of cover material, the distance it must be
hauled, and the ease of its excavation.  If the necessary materi-
als, such as gravel, dirt, and clay, are not available locally,
they must be purchased and/or hauled, thereby significantly in-
creasing costs.  In general, the more difficult the excavation the
more elaborate and expensive the equipment needed will be, and the
higher the cost will be.

     The date of covering the piles affects the present valuation
of the cost of cover.  Therefore,  the length of the delay, as well
as site specific characteristics of the piles themselves,  must be
taken into account in determining the costs of the covers.

     Table 7-1 provides estimates of the radon emissions release
rates and cover thickness required on each pile to meet the 20
pCi/m2-s  emissions  limit.   It  also gives the pile  areas  and infor-
mation on any interim cover that may be on the pile.  Estimates of
the total volume of earth needed for permanently covering each pile
can be calculated from the information in this table by subtracting
the volume of the interim cover from the volume needed to cover the
entire pile.

     The installation of the permanent cover is assumed to take one
year, as is also assumed for calculating estimated radon emissions
in Chapter 5.  The permanent cover is assumed to be completed at
the end of the year of the MOU target disposal date.

     Cost estimates are generated using the same methods as were
used in estimating the costs for covering the tailings at licensed
mill tailings facilities for the NESHAPs promulgated in 1989.  The
methodology is described in detail in Appendix B of the Risk
Assessments Appendixes  (Appendix to Volume 2), and the costs are
summarized in Chapter 4 of the Economic Assessment  (Volume 3), of
the Background Information Document for those NESHAPs (EPA89c,
EPA89d).  The unit costs for individual cover activities were
updated to 1991 dollars for this analysis.  The revised costs were
                                7-2

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      Table 7-1.  Facility-Specific Release Rates, Cover Depths,  and Areas


Release
Rate
Facility (pCi/m2-s)
ANC, Gas Hill, WY
ARCO Coal, Bluewater, NM
Atlas, Moab, UT
Conoco, Conquista, TX
Ford-Dawn Mining, Ford, WA
Hecla Mining, Durita, CO
Homestake, NM (large impoundment)
Homestake, NM (small impoundment)
Pathfinder-Lucky Me, GH, WY
Petrotomics, Shirley Basin, WY
Quivera, Ambrosia Lake, NM
Rio Algom, Lisbon, UT
Sohio-L-Bar, NM
UMETCO, Gas Hills, WY
UMETCO, Maybell, CO
UMETCO, Uravan, CO
UNC, Church Rock, NM
Union Pacific, Bear Creek, WY
WNI, Sherwood, WA
WNI, Split Rock, WY
TOTALS
420
620
540
224
240
428
300
300
220
170
237
420
500
310
128
480
290
420
200
430

Cover

Area
Depth Current Covered
Required Interim by
to Meet Cover Interim
Standard Depth Cover
i (m) (m) (m2)
3.25
3.66
3.52
2.58
2.65
3.27
2.89
2.89
2.56
3.58
2.64
3.25
3.43
2.92
1.98
3.39
2.85
3.25
2.46
3.27

0.15
0.75
N/A
2.58
1.50
0.60
N/A
0.75
0.75
0.60
0.30
0.90
3.43
1.20
2.73
2.73
0.30
0.30
N/A
3.00

445,000
607,000
0
607,000
384,000
142,000
0
24,000
761,000
461,000
1,344,000
405,000
324,000
777,000
141,000
283,000
417,000
720,000
0
902,000
8,744,000

Total Area
to be
Covered
(m2)
445,000
1,093,000
518,000
1,012,000
497,000
142,000
688,000
52,000
821,000
461,000
1,490,000
405,000
324,000
777,000
202,000
283,000
417,000
720,000
380,000
902,000
11,777,000
taken from recent versions  of  the same sources used for the unit
costs in Appendix B  (ME91a, ME91b).   The updated unit costs are:

     •    Hauling —  $3.88 per  cubic  meter,
     •    Excavating — $1.23 per cubic meter,
     •    Grading —  $2.04 per  cubic  meter,
     •    Compacting — $1.63 per cubic meter.

     The total cost  of covering  each tailings  pile is estimated
based on these unit  costs and  the volumes of earth cover calculated
from information in  Table 7-1.   Excavating and grading costs are
applied for regrading  of slopes  of each pile and for the reclama-
tion of the borrow pits.  Table  7-2  presents the costs for each
                                 7-3

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pile for the specific activities required to construct earth
covers.  A standard overhead cost is applied to arrive at the total
1991 cost to cover each pile to achieve a radon emission rate of 20
pCi/m2-s.

     Table 7-2 also shows the present value, or discounted, costs
of covering these piles on the MOU target dates.  The present value
costs shown are based on discount rates of 2, 5 and 7 percent.

7.3  COST OF VERIFYING RADON EMISSIONS

     Testing the covered piles for radon emissions is a relatively
minor cost.  After completing construction of the radon cover, the
owner or operator of each uranium mill tailings pile is required to
measure the radon flux through the permanent radon barrier to
verify the effectiveness of the design of the barrier in ensuring
that the 20 pCi/m2-s  standard is  not exceeded.   The  flux is to be
determined after the radon barrier is in place, but before the
placement of gravel and riprap, which are measures for achieving
long-term stabilization of the pile.  The necessary measurements
are to be performed in accordance with the procedures described in
40 CFR part 61, Appendix B, Method 115 or any other method proposed
by a licensee and approved by NRC or an affected Agreement State as
being at least as effective as EPA method 115 in demonstrating the
effectiveness of the permanent barrier in achieving compliance with
the standard (EPA85a).  Method 115 specifies that the flux be
determined from the mean of a minimum of 100 radon flux measure-
ments made from the adsorption of radon on activated charcoal in
large-area collectors placed at regularly spaced intervals on the
surface of the pile.  Radon is to be collected for a 24-hour
period.  The radon collected is measured by gamma-ray spectroscopy.

     The typical cost of verifying that a covered pile meets the 20
pCi/m2-s  limit  is in  the range of $5,000  to  $6,000,  but it may be
as high as $10,000.  This is the cost to the pile owner or operator
if the task is performed by a firm specializing in this type of
measurement.  It covers transportation to and from the pile site,
all labor associated with placing and recovering the large-area
collectors and measuring the radon adsorbed on the charcoal, the
cost of the activated charcoal used in the collectors, and the
capital cost of the canisters and instruments used.

     Assuming that it costs $10,000 to test each pile, the total
cost of verifying the emissions for the approximately 34 piles at
the 19 sites is expected to be about $340,000 disregarding
discounting.  These costs would be added to the costs shown in
Table 7-2, but they increase overall costs insignificantly.
                                7-4

-------
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                                                               7-5

-------
7.4  COST SAVINGS DUE TO POSTPONING THE TIME OF COVER

     Under provisions of the CAA, 40 CFR 61, Subpart T, all non-
operational piles were to have been permanently covered by December
15, 1991.  The MOU agreement between the EPA, the NRC, and the
affected Agreement States postponed the dates for requiring final
cover; providing specific dates for covering each pile.  The dates
were deferred from one to nineteen years.  This delay is a savings
to the uranium milling industry and to society as a whole.  The
savings, shown in the last column of Table 7-3, are the differences
between the 1991 cost of covering the piles and the discounted
costs of covering the piles on the dates specified in the MOU.  The
1991 cost of increasing the cover to the required depth for all
impoundments would have been somewhat less than $300 million.
Postponing covering the piles reduces this cost by about $29, $65,
or $85 million, at 2, 5, or 7 percent discount rates, respectively.
This savings would be increased if the time for covering any of the
piles were delayed beyond the MOU cover dates.  The savings would
be reduced if any of the final covers were completed before the
dates established by the MOU, or if additional interim covers were
placed on the piles before the MOU dates.


    Table 7-3.   Present  Value Costs  to Cover by MOU Target Dates
                          (Millions of 1991 Dollars)
Baseline
Cost to
Cover in
1991
0%
2%
5%
7%
Real
Real
Real
Real
Interest
Interest
Interest
Interest
Rate
Rate
Rate
Rate
265
265
265
265
.4
.4
.4
.4
Present
Value Cost
to Cover
by MOU
Target
265
238
203
184
Date
.4
.0
.6
.6
Cost
Savings
From 1991
Baseline
0.
27.
61.
80.
0
4
7
8
7.5  COST SAVINGS AND RISK INCREASES COMPARED

     Table 5-7 shows that 2.26E-2 fatal cancers were expected to
have occurred over the 70 year assessment period used for evaluat-
ing risk, had all the piles listed in the MOU been covered by the
end of 1991.  The expected number of fatal cancers increases to
3.48E-2 as a result of delaying placement of radon covers until the
dates agreed to in the MOU.  The increased number of fatal cancers
resulting from this rulemaking is 1.22E-2 over the 70 year assess-
ment period.  This increase in fatal cancers can be compared to the
reduced costs shown in Table 7-3.
                                7-6

-------
 7.6  FINANCIAL BURDEN ON INDUSTRY

     A variety of costs are borne by the uranium milling industry
 in keeping piles on standby or inactive status rather than taking
 them to final closure.  They  include the costs of keeping personnel
 at the pile sites to carry out the variety of duties associated
 with the maintenance, upkeep  and guarding of the piles, and the
 costs associated with management oversight.  In addition, there are
 various fees associated with  maintaining NRC or Agreement State
 licenses as long as the piles are on standby or inactive status.
 The licensees are also financially liable for the piles as long as
 they retain title to them.

     All of these costs cease when the piles have been covered and
 stabilized in accordance with the provisions of UMTRCA, so that
 permanent responsibility for  their care passes to the Federal
 Government.  The cessation of these costs is an incentive for the
 licensees to close the piles.

     There are, however, substantial costs associated with covering
 these piles, as shown in Tables 7-2 and 7-3.  Further expenditures
 are necessary to meet the ground water and stability provisions of
 UMTRCA in order to finally close these piles.  The costs of these
 other provisions are not addressed in this rulemaking because they
 do not contribute to the reduction in radon emissions.

     EPA has assumed in its previous rulemakings that the piles
 could be closed five years after milling operations ended.  Five
 years is the approximate time it takes to dry out a thoroughly wet
 pile and to complete construction of the radon cover.  The MOU
 between NRC, the affected Agreement States, and EPA was negotiated
 in Oct. 1991, before this rulemaking was undertaken.  The target
 dates in the MOU were established expressly so that the licensees
 would achieve control of radon emissions as expeditiously as
 practicable considering technological feasibility.

     The postponement in the dates for requiring cover, past the
 December 1991 deadline established by Subpart T,  represents a
 reduction in the costs of covering the piles.  This, in itself,
 reduces the cost burden to the pile owners.

     The NRC and the affected Agreement States agreed to ensure
 that the schedules and conditions for affecting final closure are
 flexible enough to consider technological feasibility.  A number of
 licensees were allowed more than five years from the signing of the
MOU to complete construction of radon covers.  Therefore,  it is
 reasonable to assume that the licensees will be able to meet the
MOU dates without incurring unreasonable costs.
                                7-7

-------
7.7  REGULATORY FLEXIBILITY ANALYSIS

     The Regulatory Flexibility Act (RFA)  requires regulators to
determine whether proposed regulations would have significant
economic impact on a substantial number of small businesses or
other small entities.  If so, regulators are required to consider
specific regulatory alternatives that minimize the impacts on these
small entities without compromising the objective of the statute
under which the rule is enacted.  Alternatives for consideration by
the RFA are tiering regulations, performance rather than design
standards, and small firm exemptions.

     Most firms that own uranium mills are divisions or subsidiar-
ies of major U.S. and international corporations.  Many of these
uranium milling operations are a part of larger diversified mining
firms which are engaged in a number of raw materials industries;
uranium milling represents only a small portion of their overall
operations.  Others are owned by major oil companies and electric
utilities which were engaged in horizontal and vertical integra-
tion, respectively, during the industry's growth phase in the 1960s
and 1970s.  In 1977 there were 26 companies operating uranium mills
in the U.S.  Presently there are approximately three, and these
operate only part time.  Future projections for the industry are
bleak; it is unlikely that more than a very few mills will operate
at any one time in the future.  The high financial risk and the
large capital requirement needed to enter or to remain viable in
the industry means that the industry will be restricted to large
diversified firms and large electric utilities.

     This rulemaking reduces the economic cost to the mill owners
for covering the uranium mill tailings piles subject to the Subpart
T regulation promulgated in 1989 because it effectively postpones
the required expenditures to later dates.  It was found in the 1989
rulemaking that there was no significant impact on small business
entities.  There has been no change in this, no new tailings piles
have been constructed since 1989.

     The result is that no significant impact on small business
entities is expected if this rulemaking is promulgated.
                                 7-8

-------
        APPENDIX A
CAP88-PC INFORMATION SHEETS

-------

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:  Baseline Emissions	  Page

Facility:  Federal American	  Location:  Riverton, Wyoming
                                                                     of
 _X	Population Run  Input File Name: FED AMER BASE
     _Array Attached  Pop. File Name: FEDAMERI
                                                Output File Prefix:   AAO
Latitude:
42 '
47
59
Longi tude:   107
38
                                                                   00
Distances:   500   1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.000  60.000
 (meters) 80,000  	  	  	  	  	  	  	  	  	
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	       X
    Vegetables:     	              	            	
      _Individual Run  Input File Name:
                                                Output File Prefix:_
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  LANDER           WBAN: 24021
                       Array Attached  STAR File Name:  LND1100
                                HDR:   1100
                                      CODE:  LN LND   SET//:
                                                      STAR05
Temperature:  6.0 °C  Lid Height:  608 m  Rainfall: 25.4 cm/yr

      Stack Source:     1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2):  445,000
 Plume Rise:
 	Buoyant  (cal/s):
 	Momentum (m/s):
 	Entered  (m):
   Pasquill  Stability
                        B
Nuclide  Class AMAD   Release  Rates  (Ci/yr)

Rn-222                  281       	
       Additional Source Term Attached
 Comments:
                                           A-l

-------
                               CAP88PC INFORMATION SHEET

 Date:  April 1992  Source Category:  Baseline Emissions	  Page

 Facility:  Anaconda (ARCO Coal)	  Location:   Bluewater.  N.M.
                                               of
  _X	Population Run  Input File Name:  ANACONDA BASE
      _Array Attached  Pop. File Name: BLUEWATE	
 Latitude:    35 "     16       12 "  Longitude:  107 "
                          Output File Prefix:
                         AAB
                        56
        44
 Distances:    500   1.000   2.000   3,000   4,000   5,000  10,000  20,000  40,000   60,OOP
  (meters) 80,000

 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:                                                                      X
     Vegetables:
      _Individual Run  Input File Name:
                          Output  File  Prefix:.
 Distances:
  (meters)

 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:      	              	            	     Productivity
          Milk:
    Vegetables:
Meteorological  (STAR)  Data:   	
Location:  AMBROSIA LAKE    WBAN:
_Array Attached   STAR  File  Name:   STARANHM
          HDR:
CODE:
SET#:
Temperature:  13.4  "C   Lid Height:   767 m  Rainfall:  20.6  cm/yr

	Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2):  1.214.000
Plume Rise:
	Buoyant  (cal/s):
	Momentum  (m/s):
	Entered  (m):
   Pasquill Stability
B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                  766
      Additional Source Term Attached
Comments:
                                          A-2

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:   Baseline Emissions	

Facility:  Moab	  Location:  Moab, Utah
                                 Page
              of
  X   Population Run  Input File Name:  MOAB BASELINE
	Array Attached  Pop. File Name: MOABATLA	
Latitude:   38 °     35       59 "  Longitude:  109 "
                        Output File  Prefix:     AAC
                       35
44
Distances:   500   1,000   2,000   3.000   4.000   5.000  10,000  20.000  40.000  60.000
 (meters) 80,000
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat-                         	            	     Productivity
                    	                                                           x
          Milk:
    Vegetables:
      Individual Run  Input File Name:
                         Output File Prefix:
Distances:
  (meters)
 Food Fractions:  Fl-Grown  at Home   F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:                         	            	      Productivity
          Milk:     ZUZZ             	            	         	     	
    Vegetables:     	             	            	
 Meteorological  (STAR)  Data:   	
 Location:   GRAND  JUNCTION   WBAN:  23066
Array Attached  STAR File Name:  GJT0476
         HDR:  0476     CODE:  GJT
         SET#:  STAR03
 Temperature:  13.7  °C  Lid Height:   538  m  Rainfall:  20.3  cm/yr
      _Stack Source:

         Height (m):
       Diameter (m):
   X   Area Source:
 Circular Area (m2):   518.000
 Plume Rise:
 	Buoyant (cal/s):,	
 	Momentum (m/s):   	
 	Entered (m):
    Pasquill Stability
 B
 Nuclide Class AMAD  Release Rates (Ci/yr)

 Rn-222        	     327      	
       Additional Source Term Attached
 Comments:
                                           A-3

-------
                               CAPS8PC INFORMATION SHEET

 Date;  April 1992  Source Category:  Baseline Emissions	  Page

 Facility:  Conquista	  Location:  Falls City, Texas
                                                                                 of
  _X	Population Run  Input File Name: CONQUISTA BASE
      _Array Attached  Pop. File Name: CONQUIST
 Latitude:   28 °     54       03 "  Longitude:_
                                                            Output File Prefix:
                                                                AAD
                                                 98
                                       05
40
              500
Distances:	
 (meters) 80,000
1,000   2.000   3,000   4,000   5,000  10.000  20,000  40,000  60.000
 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:     	              	            	     Productivity
           Milk:     	              	            	        	       x
     Vegetables:     	
      _Individual Run  Input File Name:
                                                            Output File Prefix:,
 Distances:
  (meters)

 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:      	              	            	     Productivity
          Milk:      	              	            	        	     	
     Vegetables:      	              	            	
 Meteorological  (STAR)  Data:   	
 Location:   SAN  ANTONIO      WBAN:  12921
                                   Array Attached  STAR File  Name:   SAT0064
                                            HDR:   0064	 CODE:   SAT
                                                        SET//:  STAR01
Temperature:  20.4  °C  Lid Height:   873 m  Rainfall:  68.6  cm/yr

      Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2):  1,012.000
Plume Rise:
	Buoyant  (cal/s):
   Momentum  (m/s):
	Entered  (m):
   Pasquill Stability
                                   B
                                 D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 638
      Additional Source Term Attached
Comments:
                                          A-4

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:  Baseline Emissions	  Page

Facility:  Dawn	  Location:  Ford, Washington
                                                                     of
 _X	Population Run  Input File Name:  DAWN BASELINE
     _Array Attached  Pop. File Name:  DAWNMILL
                                                Output File Prefix:    AAE
Latitude:
47
54
06
Longitude:   117 °
49
58
Distances:   500   1,000   2,000   3,000   4,000   5,000  10,000  20,000  40,000  60,000
 (meters) 80,000  	  	  	  	  	  	  	  	  	
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat^     	              	            	     Productivity
          MilkT     	              	            	        	
    Vegetables:     	              	            	
                                                                         X
     _Individual Run  Input File Name:_
                                                Output File Prefix:_
Distances:_
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  SPOKANE          WBAN: 24157
                       Array Attached  STAR File Name:  GEG0.360
                                HDR:  0360     CODE:  GEG
                                                      SET#: STAR03
Temperature:  8.4 "C  Lid Height:  640 m  Rainfall: 42.4 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):   497,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222                 313
      Additional Source Term Attached
Comments:
                                          A-5

-------
                               CAP88PC INFORMATION SHEET


 Date: April 1992   Source Category:  Baseline Emissions	  Page

 Facility:   Naturita	  Location:  Naturita. CO	
                                                                     of
  _X	Population Run  Input File Name:  NATURITA BASE
   X	Array Attached  Pop. File Name: NATURITA
   lt-T t-lirlo •    ^R °     TJ       f\f\ "  T m-irr-l «-,,^£> •
                                                Output File Prefix^    AAF
 Latitude:
38
12
00
Longitude:   108
37
00
 Distances:    500   1.000   2.000   3.000   4,000   5,000  10,000  20.000  30,000  40.000
  (meters) 50.000  60.000  80.000

 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:      	              	            	     Productivity
          Milk:      	              	            	        	     _X
     Vegetables:      	
      _Individual Run  Input File Name:
                                                Output File Prefix:.
 Distances:
  (meters)
Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:      	              	            	     Productivity
          Milk:      	              	            	        	     	
    Vegetables:      	              	            	
Meteorological  (STAR)  Data:   	
Location:  Grand Junction   WBAN:   23066
                       Array Attached  STAR File Name:   GJT0476
                                HDR:   0476     CODE:   GJT
                                                      SET//:   STAR03
Temperature: 11.5  °C   Lid Height:   538 m  Rainfall:  20.3 cm/yr

      Stack Source:      1234
        Height  (m):
      Diameter  (m):
   X  Area Source:•
Circular Area  (m2):    142,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                    9
      Additional Source Term Attached
Comments:
                                          A-6

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:  Baseline Emissions	  Page

Facility:  Homestake (large impoundment)    Location:  Grants, N.M.	
                                                                     of
 _X	Population Run  Input File Name: LHOMESTAKE BASE
     _Array Attached  Pop. File Name: HOMESTAK
                                                Output File Prefix:   AAI
Latitude:
35
14
31    Longi tude:   107
51 '
46
Distances:   500   1.000   2.000   3.000   4.000   5.000  10,000  20.000  40.OOP  60.000
 (meters) 80,000  	  	  	  	  	  	  	  	  	

Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	       X
    Vegetables:     	              	            	
     JEndividual Run  Input File Name:_
                                                Output File Prefix:
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  AMBROSIA LAKE    WBAN:
                       Array Attached  STAR File Name:   STARANHM
                                HDR:
                                      CODE:
                                             SET#:
Temperature: 13.4 °C  Lid Height:  767 m  Rainfall: 20.6 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area  (m2):  688,000
Plume Rise:
	Buoyant  (cal/s):
	Momentum (m/s):
	Entered  (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 4.34            	
      Additional  Source  Term Attached
 Comments:
                                           A-7

-------
                               CAP88PC INFORMATION SHEET

 Date;  April 1992  Source Category:  Baseline Emissions	  Page

 Facility:  Homestake (small impoundment)    Location:  Grants, N.M.	
                                                                     of
  _X	Population Run  Input File Name: SHOMESTAKE BASE
 Latitude:
       .Array Attached  Pop. File Name: HOMESTAK
       irfo-   75 °     I/,       11 "  T n-nrr-i-t-n^a-
                                                Output File Prefix:    AAJ
35
14
31    Longitude:   107
51
46
 Distances:   500   1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.OOP  60.000
  (meters) 80,000  	  	  	  	  	  	  	  	  	

 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:     	              	            	     Productivity
           Milk:     	              	            	        	     _X
     Vegetables:     	              	            	
      _Individual Run  Input File Name:
                                                Output File Prefix:
 Distances:_
  (meters)
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk:      	              	            	        	     	
     Vegetables:      	              	            	
Meteorological  (STAR)  Data:   	
Location:  AMBROSIA.LAKE    WBAN:
                      _Array Attached  STAR File Name:   STARANHM
                                HDR:
                                      CODE :
                                             SET#:
Temperature:  13.4 .."C  Lid Height:   767 m  Rainfall:  20.6 cm/yr

      Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m^):    52,OOP
Plume Rise:
	Buoyant  (cal/s):
   Momentum  (m/s):
   Entered  (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222	33       	
      Additional Source Term Attached
Comments:
                                          A-8

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:  Baseline Emissions	  Page

Facility:   Lucky Me	  Location:  Riverton, Wyoming
                                                                     of
 _X	Population Run  Input File Name:  LUCKY MN BASE
     ^Array Attached  Pop. File Name:  GASLUCKY
                                                Output File Prefix:
                                                              AAK
Latitude:
42
49
55    Longitude:   107
37
00
Distances:   500   1.000   2,000   3.000   4.000   5.000  10,000  20.000  40,000  60,000
 (meters) 80,000  	  	  	  	  	  	  	  	  	
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  FS-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	
    Vegetables:     	              	            	
                                                                         X
     _Individual Run  Input File Name:
                                                Output File Prefix:
Distances:_
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  LANDER           WBAN: 24021
                       Array Attached  STAR File Name:  LND1100
                                HDR:  1100     CODE:  LND
                                                      SET#: STAR05
Temperature:  6.0 °C  Lid Height:  608 m  Rainfall: 22.9 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  821,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 518
      Additional Source Term Attached
Comments:
                                          A-9

-------
                               CAP88PC INFORMATION  SHEET

 Date:   April  1992   Source Category:   Baseline  Emissions	  Page 	3

 Facility:   Petrotomics	  Location:  Medicine  Bow.  Wyoming
                                                                     of
  _X	Population Run  Input File Name:  PETROTOMICS  BASE
      _Array Attached  Pop.  File Name:  PETROTOM
                                                Output File Prefix:,
                                                              AAL
 Latitude:
42
20
Longitude:   106 °
11
49
 Distances:    500    1.000    2,000   3.000   4.000    5.000   10,000   20.000  40.000   60.OOP
  (meters) 80,000  	  	  	  	  	   	   	  	   	

 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	               	             	     Productivity
          Milk:     	               	             	        	       X
    Vegetables:     	               	             	
      JEndividual Run   Input  File  Name:
                                                Output File Prefix:
Distances:
  (meters)
Food Fractions:  Fl-Grown at Home   F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:     	              	            	      Productivitvity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological  (STAR) Data:  	
Location:  CAS PER           WBAN:  24089
                       Array Attached  STAR File Name:  CPR1564
                                HDR:   1564     CODE:  CPR
                                                      SET#:  STAR07
Temperature:  5.3 °C  Lid Height:   533 m  Rainfall:  30.5 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  461,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 291      	
      Additional Source Term Attached
Comments:
                                          A-10

-------
                              CAP88PC  INFORMATION  SHEET

 Date:  April  1992   Source  Category:  Baseline  Emissions	  Page 	1_

 Facility:  Kerr-McGee  (Quivera)	   Location:   Ambrosia  Lake.  N.M.
                                                                                 of
  _X	Population Run   Input  File Name: KERR-MCGEE  BASE
	Array Attached   Pop.  File Name: AMBROSIA	
Latitude:   35  °      23        39  "  Longitude:   107
                                                            Output File Prefix:
                                                               AAM
                                                          49
                                                47
             500
Distances:	
 (meters) 80,000
1,000   2,000   3.000   4.000   5.000  10.000  20.000  40.000  60.000
Food Fractions:  Fl-Grown  at Home  F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:     	             	            	     Productivity
          Milk:--    	             	            	        	       X
    Vegetables:     	             	            	
      _Individual Run   Input File Name:
                                                            Output File Prefix:
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     _              _            _     Productivity
          Milk:     _              _            _        _     _
    Vegetables:     _              _
Meteorological (STAR) Data:  	
Location:  AMBROSIA LAKE    WBAN:
                                  _Array Attached  STAR File Name:   STARANHM
                                  	 HDR:	 CODE:	 SET#:
Temperature: 13.4 °C  Lid Height:  767 m  Rainfall: 20.6 cm/yr

      Stack Source:     1           23           4
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  1,490,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                                   B
                                  D
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222                 940
      Additional Source Term Attached
Comments:
                                          A-ll

-------
                               CAP88PC  INFORMATION SHEET

Date:  April  1992   Source  Category:  Baseline Emissions	  Page

Facility:  Rio Algora	  Location:  La Sal, Utah	
                                              of
  _X	Population Run   Input  File Name:  RIO ALGOM BASE
                         Output File Prefix:
                AAN
	Array Attached   Pop.  File Name: LASALRIO	
Latitude;   38  °      15       00  "  Longitude:  109
                       16
30
Distances:   500    1,000    2.000    3.000   4.000   5.000  10.OOP  20.000  40.OOP  60.0PP
  (meters) 8P.PPO  	  	  	  	  	  	  	  	  	
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            ^	        	       X
    Vegetables:     	              	            	
      _Individual Run  Input File Name:
                         Output File Prefix:
Distances:_
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological  (STAR) Data:  	
Location:  GRAND JUNCTION   WBAN: 23066
Array Attached  STAR File Name:   GJT0476
         HDR:  0476     CODE:   GJT
        SET#:  STAR03
Temperature: 13.7 °C  Lid Height:  538 m  Rainfall: 20.3 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2);  4P5.000
Plume Rise:
   Buoyant (cal/s):
	Momentum (m/s):
   Entered (m):
   Pasquill Stability
B
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222                 255            	
      Additional Source Term Attached
Comments:	^____	
area changed per comments: 0-5 km demography updated.
                                          A-12

-------
                               CAP88PC INFORMATION SHEET

 Date:   April 1992  Source Category:  Baseline Emissions	  Page

 Facility:   L-Bar	  Location:   Seyboyeta, N.M.
                                                                     of
  _X	Population Run  Input File Name:  L BAR BASELINE
       Array Attached  Pop.  File Name:  LBARSOHI
   _ • ..	a _ -    irro      11*      f\f\**
                                                Output File Prefix:
                                                              AAV
 Latitude:
35
11
09
Longitude:   107 °
20
09
 Distances:    500   1.000   2.000   3,000   4,000   5,000  10.OOP  20,000  40.000  60.000
  (meters)  80,000  	  	  	  	  	  	  	  	  	
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	       X
     Vegetables:     	              	            	
      _Individual Run   Input  File Name:
                                                Output File Prefix:
Distances:
  (meters)
Food Fractions:  Fl-Grown  at  Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	             .          Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological  (STAR) Data:  	
Location:  ALBUQUERQUE      UBAN:  230-50
                       Array Attached  STAR File Name:  ABQ0282
                                HDR:   0282     CODE:   ABQ
                                                      SET//: STAR03
Temperature: 13.4 "C  Lid Height:   767  m  Rainfall:  20.6  cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  324,000
Plume Rise:
   Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
                                D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 204
      Additional Source Term Attached
Comments:
                                          A-13

-------
                               CAPS8PC  INFORMATION SHEET

Date;  April 1992   Source Category:  Baseline  Emissions	   Page

Facility:  Umetco Gas  Hills	  Location:  River ton, Wyoming
                                                                    of
  _X	Population Run  Input File  Name:  GAS  HILLS  BASE
      _Array Attached  Pop.  File  Name: UCCGASHI	
Latitude:   42  °      49        45 "  Longitude:   107  "
                                               Output File Prefix:
                                                                 AAA
                                             29
                                                34
Distances:
500
1.000   2.000   3.000   4.000   5,000  10.000  20.000  40.OOP  60.000
  (meters) 80,000
Food Fractions:  Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
__        Meat:     	             	           	      Productivity
          Milk:     	             	           	        	       X
    Vegetables:     	             	           	
      _Individual Run   Input  File Name:
                                               Output .File Prefix:,
Distances:,
 (meters)
Food Fractions:  Fl-Grown  at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	           	     Productivity
          Milk:     	             	           	        	     	
    Vegetables:     	             	           	
Meteorological (STAR) Data:
Location:  LANDER
                	Array Attached  STAR File Name:  LND1100	
               WBAN: 24021     HDR:  1100     CODE:  LND      SET#: STAR05
Temperature:  6.0 -°C  Lid Height:  608 m  Rainfall:  25.4 cm/yr
     _Stack Source:

        Height (m):
      Diameter (m):
         . 1
  X   Area Source:
Circular Area (m2):  777.000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                      B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 490          	
      Additional Source Term Attached
Comments:
                                          A-14

-------
                              CAP88PC INFORMATION SHEET


Date: April 1992   Source Category:  Baseline Emissions	

Facility:  Maybe 11	  Location:  Maybe 11, CO
                                               Page
              of
 _X	Population Run  Input File Name:  MAYBELL BASELINE    Output File Prefix:   AAP
	Array Attached  Pop. File Name: MAYBELL	
Latitude:   40 °     32       36 "  Longitude:  107
                                    59
36
Distances:   500   1,000   2.000   3.000   4.000   5.000  10.OOP  20.OOP  30.000  40.OOP
 (meters) 50.000  60,000  80.000  	  	  	  	  	  	  	

Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	       X
    Vegetables:     	              	
      _Individual Run  Input File Name:
                                      Output File Prefix:,
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  Eagle County	 WBAN:
             Array Attached  STAR File Name:   EEE1420
                      HDR:  1420     CODE:  EEE
        SETf:
Temperature:  5.8 °C  Lid Height:  538 m  Rainfall: 33.8 cm/yr

      Stack Source:     1234
        Height (m) :
      Diameter (m) :

   X  Area Source :
Circular Area (m):

Plume Rise:
_ Buoyant (cal/s): _
_ Momentum (m/s) :   _
_, _ Entered (m) :
   Pasquill Stability
202.000
             B
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222                  13         	
      Additional Source Term Attached
Comments:
                                          A-15

-------
                               CAP88PC INFORMATION SHEET

 Date:  April 1992  Source Category:  Baseline Emissions	  Page

 Fac 111 ty;  Uravan	  Location:  Uravan, Colorado
                                                                                 of
  _X	Population Run  Input File Name:  URAVAN BASELINE     Output File Prefix:.
                                                                                   AAQ
      _Array Attached  Pop. File Name: URAVANUN	
 Latitude:   38 °     22       00 "  Longitude:  108
                                                          45
                                                00
              500
Distances:	
 (meters) 80,000
1.000   2,000   3,000   4.000   5,000  10,000  20,000  40.OOP  60.000
 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  FS-Imported   Urban/Low    Rural
           Meat:     	              	            	     Productivity
           Milk:     	              	            	        	       x
     Vegetables:     	              	            	
      _Individual Run  Input File Name:
                                                            Output File Prefix:
 Distances:
  (meters)
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk:      	              	            	         	     	
     Vegetables:      	              	
 Meteorological  (STAR)  Data:
                                   Array Attached  STAR File Name:   GJT0476
                                            HDR:   0476      CODE:   GJT
 Location:   GRAND JUNCTION   WBAN:  23066
 Temperature:   9.4  °C  Lid Height:   538 m  Rainfall:  29.4 cm/yr

 	  Stack Source:      1234
                                                        SET//:  STAR03
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2):   283,000
Plume Rise:
	Buoyant  (cal/s):
	Momentum  (m/s):
   Entered  (m):
   Pasquill Stability
                                   B
                                                                                G'
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                  18
      Additional Source Term Attached
Comments:
                                          A-16

-------
                               CAPS8PC INFORMATION SHEET

 Date:   April  1992  Source Category:  Baseline Emissions	  Page

 Facility:   Church Rock	  Location:   Church  Rock.  N.M.
                                                                                 of
  _X	Population Run  Input File Name:   CHURCH ROCK BASE     Output  File Prefix:    AAR
   	Array  Attached  Pop.  File Name:  CHURCHRO
 Latitude:    35  °      38       47 "   Longitude:   108  °
                                                          30
                                                08
              500
Distances:	
 (meters) 80,000
1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.000  60.000
 Food  Fractions:   Fl-Grown at  Home   F2-Grown Regionally   F3-Imported    Urban/Low    Rural
          Meat:     	             	           	      Productivity
          Milk:     	             	           	        	
    Vegetables:     	             	           	
                                                                                     X
      _Individual Run   Input  File  Name:
                                                            Output File Prefix:
Distances:
  (meters)
Food Fractions:  Fl-Grown  at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	            	     Productivity
          Milk:     	             	            	        	     	
    Vegetables:     	             	            	
Meteorological  (STAR) Data:  	
Location:  GALLUP/SEN	 WBAN: 23081
                                   Array Attached  STAR File Name:   GUP1167
                                            HDR:   1167     CODE:   GUP
                                                        SET#:  STAR03
Temperature: 10.3 °C  Lid Height:   767 m  Rainfall: 30.3 cm/yr

      Stack Source:      1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  417,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                                   B
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222                 263
      Additional Source Term Attached
Comments:
                                          A-17

-------
                               CAPS8PC INFORMATION SHEET

 Date:  April 1992  Source Category:  Baseline Emissions	  Page

 Facility;  Bear Creek	  Location:  Douglas. Wyoming
                                                                                 of
  _X	Population Run  Input File Name:BEAR CREEK BASE
    	Array Attached  Pop. File Name:  BEARCREK
    . » *_	i _ _    / *? o     «i .*- *      • » H  —    ...
                                                            Output File Prefix:.
                                                                 AAS
 Latitude:
            43
  16
11
Longitude:   105 "
37 '
                                                                    46
              500
Distances:	
 (meters) 80,000
1,000   2,000   3,000   4,000   5,000  10,000  20,000  40,000  60.000
 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:     	              	            	     Productivity
           Milk:     	              	            	        	       .X
     Vegetables:     	              	            	
      _Individual Run  Input File Name:.
                                                            Output File Prefix:.
 Distances:
  (meters)
 Food  Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk:      	              	            	        	     	
    Vegetables:      	              	            	
Meteorological  (STAR)  Data:   	
Location:  CASPER           WBAN:  24089
                                   Array Attached  STAR File Name:  CPR1564
                                            HDR:  1564     CODE:  CPR
                                                        SET//:  STAR07
Temperature:   7.3  "C   Lid Height:   533 m  Rainfall:  30.5 cm/yr

	Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2)':   720,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                                   B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 454
      Additional Source Term Attached
Comments:
                                          A-18

-------
                               CAPS8PC  INFORMATION  SHEET

Date:  April  1992   Source  Category:  Baseline  Emissions	   Page 	1

Facility:  Sherwood	  Location:  Uellpinit, Washington
                                                                                 of
  _X	Population Run   Input  File  Name:   SHERWOOD  BASE
                                                            Output File Prefix:   AAT
	Array Attached   Pop.  File  Name: WELLPINI	
Latitude:   47  "      52        27 "   Longitude:   118  °
                                                          07
                                                00
             500
Distances:	
 (meters) 80,000
1,000   2.000   3,000   4.000   5.000  10.OOP  20.000  40.OOP  60.000
Food Fractions:  Fl-Grown  at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	            	     Productivity
          Milk:     	             	            	        	       X
    Vegetables:     	             	            	
      _Individual Run   Input  File Name:
                                                            Output File Prefix:
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home   F2-Grown Regionally  FS-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  SPOKANE          WBAN: 24157
                                   Array Attached  STAR File Name:  GEG036P
                                            HDR:   0360     CODE:   GEG
                                                        SET#:  STAR03
Temperature:  8.4 "C  Lid Height:  640 m  Rainfall: 31.7 cm/yr

      Stack Source:     1234
        Height (m): 	
      Diameter (m): 	

  X   Area Source:
Circular Area (m2):   380,000

Plume Rise:
	Buoyant (cal/s): 	
	Momentum (m/s):  	
	Entered (m):        	
   Pasquill Stability     A
                                   B
                                  D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 240
      Additional Source Term Attached
Comments:
                                          A-19

-------
                               CAP88PC INFORMATION SHEET

 Date:   April 1992  Source Category:  Baseline Emissions	  Page 	1_

 Facility:   Split Rock	  Location:   Jeffrey City,  Wyoming

   X   Population Run  Input File Name:  SPLIT ROCK BASE      Output File Prefix:
 	Array Attached  Pop.  File Name: JEFFREYC	'_
 Latitude:    42 °     30       32 "  Longitude:  107 °
                                                                                 of
                                                                                  AAU
                                                           47
              14
 Distances:    500   1.000   2,000   3,000   4,000   5,000  10,000   20,000   40,000   60,OOP
  (meters)  80,000

 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low   Rural
           Meat:      	              	            	      Productivity
           Milk:      	              	            	        	      X
     Vegetables:      	              	            	
      _Individual  Run  Input File Name:
                                                            Output File Prefix:
Distances:
  (meters)
Food Fractions:   Fl-Grown at  Home   F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:     	             	           	      Productivity
          Milk:     	             	           	        	     	
    Vegetables:     	             	           	
Meteorological  (STAR)  Data:  	
Location:  LANDER           WBAN:  24021
                                   Array Attached  STAR File Name:  LND1100
                                            HDR:  1100     CODE:  LND
Temperature:  6.9  °C  Lid Height:   608 m  Rainfall:  25.4 cm/yr

      Stack Source:      1234
                      SET#: STAR05
                                                                                    6
        Height  (m):
      Diameter  (m):
  X
	Area Source:
Circular Area (m2):  902.000
Plume Rise:
   Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill'Stability
                                   B
D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222	569
      Additional Source Term Attached
Comments:
                                          A-20

-------
                               CAP88PC INFORMATION SHEET

 Date:  April 1992  Source Category:  Revised UMTRCA Regulations      Page

 Facility:  Federal American	  Location:  Riverton. Wyoming
                                                                                  of
  _X	Population Run  Input File Name: FEDERAL AMERICA
 	Array Attached  Pop. File Name: FEDAMERI	
 Latitude:   42 °     47       59 "  Longitude:  107 "
                                                             Output File Prefix;    AG
                                                           38
        00
 Distances:    500   1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.000  60.000
  (meters) 80.000  	  	  	  	  	  	

 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            HZH        	       x
     Vegetables:     	              	
      _Individual Run  Input File Name:
                                                             Output File Prefix:_
 Distances:
  (meters)
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk:      		            ^^        	
     Vegetables:      	              	
 Meteorological  (STAR)  Data:   	
 Location:   LANDER           WBAN:  24021
                                    Array Attached   STAR  File Name:   LND1100
                                             HDR:   1100
CODE:  LN LND   SET#:
                                                                                     STAR05
 Temperature:   6.0  °C  Lid Height:   608  m  Rainfall:  25.4  cm/yr

 	Stack Source:      1234
        Height  (m):
      Diameter  (m):

      Area Source:
Circular Area (m^;

Plume Rise:
	Buoyant (cal/s): 	
	Momentum (m/s):  	
	Entered (m):
   Pasquill Stability
                     445.000
                                   B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222	          523
      Additional Source Term Attached
Comments:
                                          A-21

-------
                               CAP88PC  INFORMATION  SHEET

Date:  April 1992   Source  Category:  Revised UMTRCA Regulations      Page

Facility;  Anaconda (ARCO  Coal)	  Location:  Bluewater. N.M.
                                                                                 of
  _X	Population Run   Input  File Name: ANACONDA
                                                            Output File Prefix:
                                                                AS
      Array Attached   Pop.  File Name: BLUEUATE	
Latitude;   35 °      16        12  "  Longitude:   107
                                                          56
                                                44
             500
Distances:	
 (meters) 80,000
1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.OOP  60.000
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	            	     Productivity
          Milk:     	             	            	                     X
    Vegetables:     	             	            	
      _Individual Run  Input  File Name:
                                                            Output File Prefix:.
Distances:
 (meters)

Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  AMBROSIA LAKE    WBAN:
                                   Array Attached  STAR File Name:   STARANHM
                                            HDR:
                                        CODE:
SET#:_
Temperature: 13.4 °C  Lid Height:  767 m  Rainfall: 20.6 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2): 1.214.000
Plume Rise:
	Buoyant (cal/s):
   Momentum (m/s):
	Entered (m):
   Pasquill Stability
                                   B
                                  D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222	1.615     	
      Additional Source Term Attached
Comments:
                                          A-22

-------
                               CAPS8PC INFORMATION SHEET

 Date:   April  1992   Source Category:  Revised UMTRCA Regulations

 Facility:   Moab	  Location:   Moab,  Utah

   X   Population Run  Input File Name:   MOAB	
                                  Page
              of
 	Array Attached  Pop.  File Name:  MOABATLA	
 Latitude:   38  "      35        59 "   Longitude:   109
                         Output File Prefix:    AP
                       35  '
44 "
 Distances:    500    1.000    2.000    3,000    4.000    5.000   10.OOP   20.000   40.OOP   60.000
  (meters)  80,000  	  	   	  	   	                   	   	
 Food  Fractions:   Fl-Grown at  Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	           	      Productivity
          Milk:1"    	             	           _____        	      X
    Vegetables:     	             	           	
      _Individual Run   Input  File Name:
                         Output File Prefix:_
Distances:
  (meters)
Food Fractions:  Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low   Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	    	
    Vegetables:     	              	            	
Meteorological  (STAR) Data:  	
Location:  GRAND JUNCTION   WBAN: 23066
Array Attached  STAR File Name:   GJT0476
         HDR:  0476     CODE:  GJT
        SET#: STAR03
Temperature: 13.7 °C  Lid Height:   538 m  Rainfall:  20.3 cm/yr

      Stack.Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  518.000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
B
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222	854
      Additional Source Term Attached
Comments:
                                          A-23

-------
                               CAP88PC INFORMATION  SHEET

Date:  April  1992   Source  Category:   Revised UMTRCA Regulations       Page

Facility;  Conqulsta	  Location:  Falls  City,  Texas
                                                                                 of
  _X	Population Run   Input  File  Name:  CONQUISTA
                                                            Output File Prefix:    AF
	Array Attached   Pop.  File  Name:  CONQUIST
Latitude:   28  "      54        03 "   Longitude:_
                                                 98
40 "
Distances;   500   1.000    2,000    3.000    4.000    5.000   10.000   20.000  40.000   60.000
  (meters) 80,000  	  	  	  	  	   	   	  	   	

Food Fractions:  Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	             	      Productivity
          Milk:     	              	             	        	       X
    Vegetables:     	              	             	
      JEndividual Run  Input File Name:
                                                            Output.File Prefix:,
Distances:,
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	      Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  SAN ANTONIO      WBAN: 12921
                                   Array Attached  STAR File Name:  SAT0064
                                            HDR:  0064     CODE:  SAT
        SET#: STAR01
Temperature: 20.4>°C  Lid Height:  873 m  Rainfall: 68.6 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X
	Area Source:
Circular Area (m2): 1.012.000
Flume Rise:
	Buoyant (cal/s):
   Momentum (m/s):
   Entered (m):
   Pasquill Stability
                                   B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 724      	
      Additional Source Term Attached
Comments:
                                          A-24

-------
                                CAP88PC INFORMATION SHEET

  Date:  April  1992   Source Category:   Revised UMTRCA Regulations       Page

  Facility:	Dawn	  Location:   Ford.  Washington
                                               of
   _X	Population Run   Input File  Name:  DAWN
                          Output File Prefix:    AT
                                                           49
                                 58
     _Array Attached  Pop. File Name: DAWNMILL	
Latitude:   47 °     54       06 "  Longitude:  117 °

Distances:   500   1.000   2.000   3.000   4.000   5.000  10.OOP  20.000  40.000  60 000
 (meters) 80,000  	  	                                  —	  —	  —'	

Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            HHZ                     X
    Vegetables:     	
      _Individual Run  Input File Name:
                          Output File Prefix:
 Distances:
  (meters)
 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:     	              	            	     Productivity
           Milk:     	                                	
     Vegetables:     	
 Meteorological (STAR) Data:  	
 Location:   SPOKANE          WBAN: 24157
_Array Attached   STAR File Name:   GEG0360
         HDR:   0360     CODE:  GEG
                                                                            SET#: STAR03
 Temperature:   8.4 "C  Lid Height:  640 m  Rainfall: 42.4 cm/yr
       Stack Source:
         Height  (m):
       Diameter  (m):
  X   Area  Source:
 Circular Area  (m2):   497.000
Plume Rise:
	Buoyant  (cal/s): 	
	Momentum (m/s):  	
	Entered  (m):
   Pasquill  Stability
B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 450
      .Additional Source Term Attached
Comments:
                                          A-25

-------
                              CAPS8PC INFORMATION SHEET
Date; April 1992   Source Catesorv:  Revised UMTRCA Regulations      Page

Facility:  Naturita	  Location:  Naturita,  CO	
                                                                                 of
 _X	Population Run  Input File Name: NATURITA
                                                            Output File Prefix:     AD
  X   Array Attached  Pop. File Name: NATURITA
Latitude;   38 °     12       00 "  Longitude:  108
                                                          37
                                                                   00
             500   1,000   2.000   3.000   4.000   5.000  10.000  20.000  30.000  40.000
 (meters) 50.000  60.000  80.000
Distances:
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
                                                                                     X
          Milk:
    Vegetables:
      Individual Run  Input File Name:
                                                            Output File Prefix:.
Distances:_
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            ____        	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  Grand Junction   WBAN:  23066
                                   Array Attached  STAR File Name:  GJT0476
                                            HDR:  0476
                                                           CODE:   GJT

Temperature: 11.5 "C  Lid Height:  538 m  Rainfall: 20.3 cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
SET#:  STAR03
   X  Area Source:
Circular Area (m2):   142,000

Plume Rise:
	Buoyant (cal/s): 	
   Momentum (m/s):  	
	Entered (m):        	
   Pasquill Stability     A
                                   B
                                                     D
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222	41      	
      Additional Source Term Attached
Comments:	____
                                          A-26

-------
                               CAP88PC INFORMATION SHEET

 Date;   April 1992  Source Category:  Revised UMTRCA Regulations      Page

 Facility:   Homestake (large impoundment)    Location:  Grants, N.M.	
                                                                                 of
  _X	Population Run  Input File Name: HOMESTAKE LARGE
    	Array Attached  Pop. File Name: HOMESTAK
    it-ii^Q-    71; °     I/.       it "  T »«_•; *-..j~ .
                                                            Output  File  Prefix:,
                                                                AAG
 Latitude:
            35
  14
31    Longitude:   107
                                                           51
46
              500
Distances:	
 (meters) 80,000
1.000   2.000   3,000   4.000   5.000  10.OOP  20.OOP  40.000  60.OOP
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk;.     	              	            	        	       x
     Vegetables:      	              	
      _Individual  Run  Input File Name:.
                                                            Output File Prefix:,
Distances:
  (meters)
Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            .	        	     	
    Vegetables:     	              	            	
Meteorological  (STAR)  Data:   	
Location:  AMBROSIA  LAKE     WBAN:
                                   Array Attached  STAR File Name:  STARANHM
                                            HDR:
                                        CODE:
                                             SET#:_
Temperature: 13.4  °C   Lid Height:   767  m  Rainfall:  20.6  cm/yr

	Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area (m2):  688.000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
   Entered (m):
   Pasquill Stability
                                   B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222	918
     _Additional Source Term Attached
Comments:
                                          A-27

-------
                               CAP88PC INFORMATION SHEET

 Date:  April  1992  Source Category:   Revised UMTRCA Regulations       Page

 Facility:   Homestake (small impoundment)     Location:   Grants, N.M.	
                                               of
  _X	Population Run  Input File Name:  HOMESTAKE  SMALL
      Array Attached  Pop.  File Name:  HOMESTAK
 Latitude:   35  "      14       31 "   Longitude:   107  °
                          Output File Prefix:    AAH
                        51
46
 Distances;    500    1,000    2,000    3,000    4,000    5.000   10.000  20.000  40.000   60.000
  (meters) 80,000  	   	  	  	  	   	  	  	   	
 Food Fractions:   Fl-Grown at Home   F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:     	             	            	     Productivity
          Milk:     	             		        	
    Vegetables:     	             	            	
                                                  .X
      JEndividual Run  Input  File Name:_
                          Output File Prefix:,
Distances:.
  (meters)
Food Fractions:  Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     _^___              	            	
Meteorological  (STAR) Data:  	
Location:  AMBROSIA LAKE    WBAN:
 Array Attached  STAR File Name:   STARANHM
~	 HDR:	 CODE:	 SET#:
Temperature: 13.4 °C  Lid Height:  767 m  Rainfall: 20.6 cm/yr

 	 Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2)':   52,000
Plume Rise:
   Buoyant (cal/s):
   Momentum (m/s):
   Entered (m):
   Pasquill Stability
 B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                  94           	
      Additional Source Term Attached
Comments:
                                          A-28

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:  Revised UMTRCA Regulations      Page

Facility:  Lucky Me	  Location:.  Rlverton. Wyoming

  X   Population Run  Input File Name: LUCKY MC	
                                                                     of
   	Array Attached  Pop. File Name: GASLUCKY
   •it-llHo-   L.O °     AQ       «;=; "  T ^^.rr-1 1-1,^0 •
                                                Output File Prefix:
                                                     AU
Latitude:
42
55    Long i tude:   107
37
00
Distances:   500   1.OOP   2.000   3,000   4.000   5.000  10,000  20.000  40,OOP  60.000
 (meters) 80,000  	  	  	  	  	  		  	  	

Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	       x
    Vegetables:     	              	            	
     _Individual Run  Input File Name:
                                                Output File Prefix:
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  LANDER	  WBAN: 24021
                       Array Attached  STAR File Name:  LND1100
                                HDR:  1100     CODE:  LND
                                             SET#: STAR05
Temperature:  6.0 °C  Lid Height:  608 m  Rainfall: 22.9 cm/vr

	Stack Source:     1234

        Height (m) : 	  	  	  	
      Diameter (m) : 	  	  	  	
  X   Area Source:
Circular Area (m2):  821,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
                       D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222	730      	
      Additional Source Term Attached
Comments:
                                          A-29

-------
                               CAP88PC INFORMATION SHEET

 Date:  April  1992   Source Category:   Revised UMTRCA Regulations       Page 	1_

 Facility:   Petrotomics	  Location:   Medicine  Bow.  Wyoming

   X   Population Run Input File Name:  PETROTOMICS	  Output File Prefix:
 	Array Attached Pop.  File Name:  PETROTOM
 Latitude;   42  °      20       04    Longitude:   106 °
                                              of
                                                AH
                       11
49 "
 Distances;    500    1,000    2,000   3.000   4.000   5.000   10.000   20.000  40.000   60.000
  (meters) 80.000  	   	  	 	  	   	   	  	   	

 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally F3-Imported   Urban/Low    Rural
          Meat:     	              	            	      Productivity
          Milk:     	              	            _____         	      X
     Vegetables:     	              	            	
      JEndividual Run   Input  File  Name:
                         Output File Prefix:,
Distances:_
  (meters)

Food Fractions:  Fl-Grown at  Home   F2-Grown Regionally   FS-Imported   Urban/Low    Rural
          Meat:     	             	           	     Productivity!ty
          Milk:     	             	           	        	     	
    Vegetables:     	             	           	
Meteorological  (STAR) Data:  	
Location:  CASPER	 WBAN:  24089
Array Attached  STAR File Name:  CPR1564
         HDR:  1564     CODE:  CPR
        SET#: STAR07
Temperature:  5.3 "C  Lid Height:   533  m  Rainfall:  30.5  cm/yr

      Stack Source:     1234
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  461.000
Plume Rise:
   Buoyant (cal/s):
	Momentum (m/s):
   Entered (m):
   Pasquill Stability
B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 484
      Additional Source Term Attached
Comments:
                                          A-30

-------
                              CAP88PC INFORMATION SHEET

Dace:  April 1992  Source Category:  Revised UMTRCA Regulations      Page 	1_

Facility:  Kerr-McGee (Quivera)	  Location:  Ambrosia Lake. N.M.
                                              of
 _X	Population Run  Input File Name:  KERR-MCGEE
                         Output File Prefix:
                 AJ
	Array Attached  Pop. File Name: AMBROSIA	
Latitude:   35 "     23       39 "  Longitude:  107
                       49
47
Distances:   500   1.000   2.000   3,000   4.000
 (meters) 80.000
                 5.000  10.OOP  20.000  40.OOP   60.000


                                                 Rural
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low
          Meat:     	              	            	     Productivity
          Milk:     	              	            	            .
    Vegetables:     	              	            	
      _Individual Run  Input File Name:
                         Output  File  Prefix:
Di-stances:
 (meters)
Food Fractions:  Fl-Grown  at Home   F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:     	             	            	     Productivity
          Milk:     	             	            	        	    	
    Vegetables:     	             	            	
Meteorological  (STAR) Data:  	
Location:  AMBROSIA LAKE     WBAN:
 Array Attached  STAR File Name:   STARANHM
~_	 HDR:	 CODE:	 SET#:
Temperature:  13.4  "C   Lid  Height:   767  m  Rainfall:  20.6  cm/yr

       Stack  Source:      1234
         Height  (m):
       Diameter  (m):
  X   Area Source:
 Circular  Area  (m2):   1,490,000
 Plume  Rise:
 	Buoyant  (cal/s):
 	Momentum (m/s):
 	Entered  (m):
    Pasquill  Stability
 B
 Nuclicle  Class  AMAD  Release Rates (Ci/yr)

 Rn-222	.1.548     	
       Additional Source Term Attached
 Comments:
                                           A-31

-------
                              CAP88PC INFORMATION SHEET

Date:  April 1992  Source Category:  Revised UMTRCA Regulations      Page

Facility:  Rio Algoin	  Location:  La Sal, Utah	
                                                                                 of
 _X	Population Run  Input File Name: RIO ALGOM
                                                            Output File Prefix:
                                                                 AN
	Array Attached  Pop. File Name: LASALRIO	
Latitude;   38 "     15       00 "  Longitude:  109 "
                                                          16
                                                30
             500
Distances:	
 (meters) 80,000
1,000   2.000   3.000   4,000   5.000  10.000  20.000  40.OOP  60.000
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          MiTSC:     	              		        	       X
    Vegetables:     	              	            	
      _Individual Run  Input File Name:
                                                            Output File Prefix:
Distances:,
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological  (STAR) Data:
Location:  GRAND JUNCTION   WBAN:  23066
                                   Array Attached  STAR File Name:  GJT-0476
                                            HDR:  0476     CODE:  GJT
                                                        SET#: STAR03
Temperature: 13.7 °C  Lid Height:   538  m  Rainfall:  20.3 cm/yr

      Stack Source:      1234
        Height  (m):
      Diameter  (m) :
  X   Area Source:
Circular Area  (m2):  405,000
Plume Rise:
	Buoyant  (cal/s):
	Momentum (m/s):
	Entered  (m):
   Pasquill Stability
                                    B
Nuclide Class AMAD   Release Rates  (Ci/yr)

Rn-222                    274        	
      Additional  Source Terra Attached
Comments:
                                           A-32

-------
                               CAPS8PC INFORMATION SHEET

 Date:   April 1992  Source Category:  Revised UMTRCA Regulations      Page

 Facility:   L-Bar	  Location:  Seyboyeta.  N.M.
                                               of
  _X	Population Run  Input File Name: L BAR
      _Array Attached  Pop.  File Name: LBARSOHI	
 Latitude:    35 °     11       09 "  Longitude:  107
                          Output  File  Prefix:.
                                AM
                        20
               09  "
 Distances;    500   1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.OOP  60.OOP
  (meters) 80,000  	
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk:      	                                                           X
     Vegetables:      	
      _Individual Run  Input File Name:
                         Output File  Prefix:.
 Distances:
  (meters)
 Food  Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	     	
    Vegetables:     	              	            	
Meteorological  (STAR)  Data:  	
Location:  ALBUQUERQUE     WBAN:  23050
Array Attached  STAR File Name:  ABQ0282
       _ HDR:  0282     CODE:  ABQ
                      SET#:  STAR03
Temperature:  13.4  "C   Lid Height:   767 m Rainfall:  20.6  cm/yr

      Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2)-:  324.000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
   _Entered (m):
   "Pasquill Stability
B
D
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 204
      Additional Source Term Attached
Comments:
                                          A-33

-------
                               CAPS8PC INFORMATION SHEET

 Date:  April 1992  Source Category:  Revised UMTRCA Regulations      Page

 Facility:  Umetco Gas Hills	  Location:   Riverton.  Wyoming
                                                                     of
  _X	Population Run  Input File Name:  UMETCO GAS HILLS     Output File Prefix:     AI
Latitude:
      .Array Attached  Pop.  File Name:  UCCGASHI
      'trio'   A 9  °      /iQ       /. «; "   T s^rr41-.,/4» •
42
49
45    Longitude:   107
29 '
34
Distances:    500   1.000   2.000   3,000   4.000   5,000  10.000  20.000^  40.OOP  60.000
  (meters) 80.000  	  	  	  	  	  	  	  	  	

Food Fractions:   Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:      	              	            	     Productivity
          Milk:      	              	            	        	       X
    Vegetables:      	              	            	
      JIndividual Run  Input File  Name:
                                                Output File Prefix:
Distances:
  (meters)
Food Fractions:   Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	           	     Productivity
          Milk:     	             	           	        	     	
    Vegetables:     	             	           	
Meteorological  (STAR)  Data:  	
Location:  LANDER	 WBAN:  24021
                       Array Attached  STAR File Name:   LND1100
                                HDR:  1100     CODE:  LND
                                                      SET//: STAR05
Temperature:  6.0  °C  Lid Height:   608  m  Rainfall:  25.4  cm/yr

      Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area (m2):  777.000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
	Entered (m):
   Pasquill Stability
                       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 589
      Additional Source Term Attached
Comments:
                                          A-34

-------
                               CAPS8PC INFORMATION SHEET


 Date: April 1992   Source Category:  Revised UMTRCA Regulations

 Facility:  Maybell	  Location:  Maybell, CO
                                                                 Page
                                                              of
  _X	Population Run  Input File Name: MAYBELL
      _Array Attached  Pop. File Name: MAYBELL	
 Latitude:   40 °     32       36 "  Longitude:  107 °
                                                        Output File Prefix:    AC
                                                      59
                                                36
 Distances:
         500
1.000   2.000   3.000   4.000   5.000  10.000  20.000  30.000  40.000
  (meters) 50,000  60.000  80.000

 Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:     	              	            	     Productivity
                     	              	            	                       X
      Milk:
Vegetables:
      _Individual Run  Input File Name:
                                                        Output File Prefix:,
 Distances:
  (meters)
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      	              	            	     Productivity
           Milk:      	              	            mH        	     	
     Vegetables:      	              	
Meteorological  (STAR)  Data:   	
Location:   Eagle  County     WBAN:
                              _Array Attached  STAR File Name:   EEE1420
                              	 HDR:   1420     CODE:   EEE      SET#:
Temperature:   5.8* °C   Lid Height:   538  m  Rainfall:  33.8  cm/yr
       Stack  Source
        Height  (m)
      Diameter  (m)

   X  Area Source:
Circular Area (m^)

Plume Rise:
	Buoyant (cal/s)
	Momentum  (m/s):
   _Entered (m):
                  202.000
   Pasquill Stability
                               B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                  70
      Additional Source Term Attached
Comments:
                                          A-35

-------
                               CAP88PC INFORMATION SHEET

 Date:  April 1992  Source Category:  Revised UMTRCA Regulations      Page

 Facility;   Uravan	  Location:   Uravan,  Colorado
                                              of
  _X	Population Run  Input File Name:  URAVAN
   	Array Attached  Pop.  File Name:  URAVANUN	
 Latitude;    38 °      22       00 "  Longitude:   108
                         Output File Prefix:,
                 AL
                       45
00
 Distances:    500   1,000   2.000   3.000   4.000   5,000  10,000  20.000  40,000  60,000
  (meters)  80.000

 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:      	              	            	     Productivity
          Milk:      	              	            	        	      X
     Vegetables:      	              	            	
      _Individual  Run  Input File Name:
                         Output File Prefix:
 Distances:,
  (meters)

 Food  Fractions:   Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	             	           	     Productivity
          Milk:     	             	           	       	     	
    Vegetables:     	             	           	

 Meteorological  (STAR) Data:   	Array Attached   STAR  File Name:  GJT0476	
 Location:  GRAND  JUNCTION   WBAN:  23066      HDR:   0476     CODE:  GJT     SET#:  STAR03
Temperature:  9.4  "C  Lid Height:   538  m  Rainfall:  29.4  cm/yr

	Stack Source:      1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area  (m2):  283,000
Plume Rise:
	Buoyant (cal/s):
   Momentum (m/s):
	Entered (m):
   Pasquill Stability
B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                  60
      Additional Source Term Attached
Comments:
                                          A-36

-------
                                CAP88PC INFORMATION SHEET

  Date:  April 1992  Source Category:  Revised UMTRCA Regulations      Page

  Facility:  Church Rock	  Location:  Church Rock. N.M.
                                                                                  of
    X	Population Run  Input File Name: CHURCH ROCK
     	Array Attached  Pop.  File Name:  CHURCHRO
     itude:    35 °     38       L.1 "  T nr,
-------
                              CAP88PC INFORMATION SHEET

Date;  April 1992  Source Category:  Revised UMTRCA Regulations      Page   1

Facility:  Bear Creek	  Location:  Douglas. Wyoming	

  X   Population Run  Input File Name: BEAR CREEK	  Output File Prefix:.
	Array Attached  Pop. File Name: BEARCREK	
Latitude:   43 °     16       11 "  Longitude:  105 "
                                                     of
                                                       AO
                              37
46
Distances:   500   1.000   2.000   3.000   4.000   5.000  10.000  20.000  40.000  60.000
 (meters) 80.000  	  	  	  	  	  	  	  	  	
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:    ' 	              	            	     Productivity
              - '^    m*^Mim*^ti^^*^~              ^^^^^^lt^ftml^f                                       ^^
          Milkf     	
    Vegetables:     	
      Individual Run  Input File Name:.
                                Output File Prefix:.
Distances:
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat •                         	            	     Productivity
          Milk:     ^m              	            	
    Vegetables:     	              	            	
Meteorological (STAR) Data:
Location:  CASPER	
 	Array Attached  STAR File Name:   CPR1564	
WBAN: 24089	 HDR:  1564     CODE:  CPR      SET#: STAR07
Temperature:  7.3 °C  Lid Height:   533 m  Rainfall:_30_._5_cm/yr

	Stack Source:     1234

        Height  (m): 	  	  		
      Diameter  (m): 		  	  	
  X   Area Source:
Circular Area  (m2):  720.000
Plume Rise:
	Buoyant  (cal/s):
	Momentum (m/s):
   Entered  (m):
   Pasquill Stability
       B
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222        	      713      	
      Additional  Source  Term Attached
Comments:
                                           A-38

-------
                               CAP88PC INFORMATION SHEET

 Date:   April 1992  Source Category:  Revised UMTRCA Regulations      Page 	]

 Facility:   Sherwood	  Location:   Wellpinit.  Washington
                                               of
  _X	Population Run  Input File Name:  SHERWOOD
 	Array Attached  Pop.  File Name:  WELLPINI	
 Latitude:    47 °      52       27 "  Longitude:   118
                         Output  File  Prefix:,
                               AQ
                       07
               00
 Distances:    500   1.000   2,000   3.000   4,000   5.000  10,OOP  20,000  40.OOP  60.000
  (meters) 80,000  	
 Food Fractions:   Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
           Meat:      _              _            _     Productivity
           Milk:
     Vegetables:
      _Individual Run  Input File  Name:
                         Output File Prefix:.
 Distances:
  (meters)
 Food Fractions:  Fl-Grown at  Home   F2-Grown Regionally   F3-Imported   Urban/Low    Rural
          Meat:     	              	           	     Productivity
          Milk:
    Vegetables:
Meteorological  (STAR) Data:  	
Location:  SPOKANE   	 WBAN:  24157
Array Attached  STAR File Name: __GjG0360
         HDR:  0360     CODE:  GEG
                      SET#: STAR03
Temperature:  8.4  "C  Lid Height:   640 m  Rainfall:  31.7 cm/yr

	Stack Source:     1234
        Height  (m):
      Diameter  (m):
  X   Area Source:
Circular Area (m2>:   380,000

Plume Rise:
	Buoyant (cal/s): 	
   Momentum (m/s):  	
	Entered (m):        	
   Pasquill Stability     A
B
D
Nuclide Class AMAD  Release Rates (Ci/yr)

Rn-222	347
      Additional Source Term Attached
Comments:
                                          A-39

-------
                               CAP88PC  INFORMATION SHEET

Date:  April 1992   Source Category:  Revised UMTRCA Regulations      Page 	1

Facility:  Split Rock	  Location:  Jeffrey City. Wyoming
                                              of
  _X	Population Run   Input  File Name:  SPLIT ROCK
                         Output File Prefix:
                 AK
	Array Attached  Pop.  File Name: JEFFREYC
Latitude:   42  "      30        32  "   Longitude:  107  °
                       47
14
Distances:   500   1,000    2.000    3,000   4,000   5,000  10,000  20,OOP  40.OOP  60,OOP
  (meters) 80,000  	  	  	  	  	  	  	  	  	

Food Fractions:  Fl-Grown at Home   F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	                     X
    Vegetables:     	              	            	
      _Individual Run  Input File Name:_
                         Output File Prefix:^
Distances:_
 (meters)
Food Fractions:  Fl-Grown at Home  F2-Grown Regionally  F3-Imported   Urban/Low    Rural
          Meat:     	              	            	     Productivity
          Milk:     	              	            	        	
    Vegetables:     	              	            	
Meteorological (STAR) Data:  	
Location:  LANDER           WBAN: 24021
Array Attached  STAR File Name:   LND1100
         HDR:  1100	 CODE:  LND
Temperature:  6.9 "C  Lid Height:  608 m  Rainfall: 25.4 cm/yr

      Stack Source:     1234
        SET#: STAR05
                                                 6
        Height (m):
      Diameter (m):
  X   Area Source:
Circular Area (m2):  902,000
Plume Rise:
	Buoyant (cal/s):
	Momentum (m/s):
   Entered (m):
   Pasquill Stability
fi
Nuclide Class AMAD  Release Rates  (Ci/yr)

Rn-222                 690	  	
      Additional Source Term Attached
Comments:
                                          A-40

-------
              Appendix B
            CAP88-PC

              Version 1.00

Clean Air Act Assessment Package - 1988
     SYNOPSIS   REPORT

      Radon Population Assessment
          Facility:   LUCKY MC
              City:   RIVERTON
             State:   WY
                  B-l

-------
        LUCKY MC  SYNOPSIS
       Effective  Dose Equivalent
             (mrem/year)
               2.49E-02
 At This  Location:
  Source  Category:
      Source Type:
    Emission Year:
25000 Meters North
INACTIVE TAILINGS
Area
730 Ci/y
     Dataset Name:
     Dataset Date:
        Wind File:
  Population File:
LUCKY MC
Mar 30, 1992  10:00 pm
WNDFILES\LND1100.WND
POPFILES\GASLUCKY.POP
         SITE INFORMATION
      Temperature:
    Precipitation:
    Mixing Height:
  6 degrees C
 2 3 cm/y
608 m
        SOURCE INFORMATION

    Source Number:       1
Source Height (m)
      Area (sq m)

Plume Rise
 Bouyancy (cal/s)
  (Release Rate)
    1.00
8.21E+05
 O.OOE+00
                    B-2

-------
                     LUCKY MC SYNOPSIS
             RN-222  MAXIMALLY EXPOSED INDIVIDUAL
        Location  Of  The Individual:
       Radon Concentration (pCi/1):
 Decay Product Concentration  (WL):
        Lifetime  Fatal Cancer  Risk:
                     25000 Meters North
                     8.77E-04
                     6.12E-06
                     4.95E-06
                            TABLE 1
    FREQUENCY  DISTRIBUTION OF  LIFETIME FATAL  CANCER RISKS
   Risk Range
Number of
 People
Number of People
  In This Risk
 Range Or Higher
Deaths/Year
  In This
 Risk Range
Deaths/Year
In This Risk
Range Or Higher
l.OE+00 TO l.OE-01          0
l.OE-01 TO l.OE-02          0
l.OE-02 TO l.OE-03          0
l.OE-03 TO l.OE-04          0
l.OE-04 TO l.OE-05         37
l.OE-05 TO l.OE-06      21420
 LESS THAN l.OE-06        402
                   0
                   0
                   0
                   0
                   37
                21457
                21859
                   O.OOE+00
                   O.OOE+00
                   O.OOE+00
                   O.OOE+00
                   5.70E-06
                   5.67E-04
                   4.60E-06
                O.OOE+00
                O.OOE+00
                O.OOE+00
                O.OOE+00
                5.70E-06
                5.72E-04
                5.77E-04
  Collective Exposure  (Person Working  Levels):  2.29E-02
         RADIONUCLIDE  EMISSIONS DURING THE YEAR
        Nuclide  Class   Size
              Source
                #1
               Ci/y
                TOTAL
                 Ci/y
        RN-222
       0.00   7.3E+02   7.3E+02
                              B-3

-------
LUCKY MC SYNOPSIS

     TABLE 2
  POPULATION DATA
Distance (m)
Direction
N
NNW
NW
WNW
W
WSW
SW
SSW
S
SSE
SE
ESE
E
ENE
NE
NNE
250
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Distance (m)
Direction
N
NNW
NW
WNW
W
WSW
SW
SSW
S
SSE
SE
ESE
E
ENE
NE
NNE
15000
0
0
0
0
0
451
0
0
0
0
0
0
0
0
0
0
25000
13
0
0
0
0
0
0
0
82
0
11
0
0
0
0
0
35000
0
0
1
34
0
0
0
0
0
0
0
0
0
24
0
0
45000
0
92
0
0
0
0
50
1882
0
0
0
40
0
0
66
0
55000
112
0
0
0
0
355
22
0
489
0
0
0
59
0
0
0
70000
0
140
1364
14704
1362
36
9
11
215
51
35
0
36
100
0
13

















      B-4

-------
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                               R-2

-------
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                               R-3

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                               R-4

-------
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                               R-5

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