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CD: 

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8) 102RQ-RN-1-7 

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40><lj52RQ-RN-5-2~r> 

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Internal SFUND Box Number 35 OF 283 

Initials/Date: LDS / 3-8-2007 
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:r 

ICF INCORPORATED International Square, 1850 K Street, Northwest, Washington, D.C. 20006 (202) 862-1100 

February 26, 1986 

MEMORANDUM 

TO: Barbara Hostage 

Emergency Response Division 

Office of Solid Waste and Emergency Response 

FROM: Harvey Cohen and Steve Wyngarden 

ICF Incorporated 

SUBJECT: Potential Hazards Posed by Releases of 

Uranium Ore During Transportation 

In response to your request, we have performed a brief review of the 

environmental and safety concerns associated with releases of uranium ore from 

uranium mines. Our preliminary findings are reported below. A brief 

description of the existing regulatory program covering uranium mines is also 

given to demonstrate how releases from mines are currently controlled. If 

necessary, additional investigation of this issue will be performed. 

Regulation of Uranium Mines 

According to a survey by the American Mining Congress, only six uranium 

mines in the United States are producing ore at the present time. There are 

reported to be at least 15 other active uranium mines in the country, but 

production from these is on temporary standby. Most of the uranium mines are 

located in western states including Colorado, Texas, New Mexico, and Arizona. 

Although not uranium ores, phosphate ores with significant concentrations of 

uranium are also mined in the state of Florida [1]. 

Regulation of uranium mines is primarily the responsibility of the 

states. State control of uranium mining operations varies from state to state 

and may include permitting of mine operators, field inspections, monitoring of 

reclaimed land for radon (Rn) emissions, and investigations of releases into 

the environment. None of the state agencies that we talked with (Colorado, 

Texas, and Florida) currently has regulations or reporting requirements 

specifically governing releases of radioactive ores. However, Colorado's and 

Texas' State Health Departments both indicated that in the event of a large 

release (a truckload, for example), they would expect a release report and 

cleanup. The Texas representative stated that a cleanup of any 

uranium-containing material would be required in order to allay public 

concerns [2]. The Colorado representative also said that any substantial 

release would be promptly cleaned up because it would be both economically and 

environmentally prudent [3]. 
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Other regulatory programs covering uranium mines include EPA's National 

Emission Standards for Hazardous Air Pollutants, or NESHAPS (40 CFR 61). In 

these standards, EPA has established limits for Rn-222 emissions from 

underground uranium mines. The Office of Mine Safety and Health of the U.S. 

Department of Labor also performs periodic inspections of producing mines --

primarily for protecting employee safety [4]. The Nuclear Regulatory 

Commission (NRC) does not license or otherwise regulate uranium mines. 

Hazards of Uranium Mine Releases 

All of the uranium ores now being mined in the U.S. are low grade, 

containing about 0.1 to 0.2 percent UO., This is equivalent to about 

J o 

250-510 picocuries (pCi) of uranium in equilibrium with its daughters, per 

gram of ore [5]. Based on a review of relevant literature and conversations 

with state regulators (all sources are cited in the reference list to this 

memorandum), small releases of these ores and associated mining wastes are not 

considered to pose a public health or environmental threat. 

The major hazard posed by mining of uranium ores is through inhalation of 

Rn-222 released during mining operations. Radon is a uranium daughter product 

which occurs in the form of a gas. EPA has found that the cancer risks posed 

by model uranium mines is dominated by lung cancer due to Rn-222 daughter 

exposure [6]. Currently, underground uranium mines utilize high volume 

ventilation systems to reduce Rn concentrations in the mine atmosphere, and 

EPA limits the radon emissions from mining activities through the NESHAPS. 

The references cited in the attached list indicate that the risk posed by 

Rn-222 released from small amounts (up to, and including truckloads) of 

uranium ore is minimal unless the gas is released into a restricted 

environment where the radon and its daughter products could potentially 

accumulate. EPA found that solid uranium mining wastes (ores, sub-ores, and 

waste rock) "are potentially hazardous when used as building materials or when 

buildings are constructed on land containing such waste. The hazard arises 

principally from increased lung cancer risk due to Rn-222" [6]. However, this 

is a problem associated with disposal of large quantities of mining ores and 

tailings rather than with small releases of ore occurring during 

transportation or other activities. 

Inhalation of uranium and thorium dust from an ore spill is also a 

potential concern associated with releases from mines. However, U.S. uranium 

ores (generally from sands and sandstones) tend to contain from 6 to 14 

percent moisture and only about 1.0 percent respirable dust by weight [7]. 

EPA has estimated that the health risk posed by particulate uranium and 

thorium resulting from erosion of ore piles and loading/unloading operations 

is smaller (by a factor of 100) than the risk from radon [5]. Using 

worst-case assumptions, the maximum dose to an individual exposed to all the 

dust that could be released from a truckload of ore was modeled to be 0.13 rem 

at 500 meters [7]. More realistic doses resulting from releases of small 

quantities are expected to be much lower. 
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-3-

Another radiological consideration associated with uranium mining spills 

is the potential for health and environmental damage caused by direct 

radiation. Representatives of the Colorado and Texas Departments of Health 

felt that the risk posed by direct contact with a piece of low grade uranium 

ore was very small to non-existent. The Texas Department of Health 

representative even stated that the radionuclide contents of uranium ores in 

his state are low enough that those ores are not considered radioactive 

material by the state Department of Transportation. 

Both the NRC and EPA have established guidelines and regulations 

restricting the disposal of materials containing low levels of uranium. 

However, these guidelines are intended to restrict the use and disposal only 

of large volumes of these materials -- in particular, to assure acceptable 

health risks to persons occupying homes built on large areas of contaminated 

land. For example, the NRC's uranium concentration guideline for radioactive 

wastes which may be disposed of in an unrestricted manner is 10 pCi/g [8]. 

The EPA cleanup level for inactive uranium milling sites is 5 pCi/g of 

radium-226. These guidelines were developed to mitigate any potential hazards 

to persons living in close association with radioactive materials for an 

extended period of time (years). Neither guideline is considered applicable 

to a release of small volumes of uranium ore into the environment. In 1983, 

when EPA studied uranium mine solid wastes as a separate class of materials, 

the agency concluded that regulation of these wastes was unwarranted because 

of their low levels of radioactivity and undesirability as building materials. 

One final area of potential concern should be addressed -- the hazards of 

nonradiological contaminants associated with uranium ore. Uranium ores and 

solid mining wastes frequently contain nonradioactive metals such as 

molybdenum, selenium, arsenic, manganese, vanadium, copper, zinc, and lead; 

mercury and cadmium are present only rarely. When associated with uranium ore 

in elevated levels, these metals may be present in the waterborne effluent 

from mines and could cause deleterious environmental and health effects. 

However, EPA has concluded that airborne emissions of nonradioactive metals 

from mining activities cause an insignificant health risk [6]. Consequently, 

airborne releases of these metals in conjunction with a spill of uranium ore 

or waste rock are not expected to be a cause for concern. In addition, 

because releases of ore or waste rock during transit are expected to be small, 

any release of nonradiological contaminants to water sources would also be 

small. The State Health Department representatives we spoke with did not feel 

that a truckload of ore accidently dumped into a river would pose a serious 

health threat [2]. 

Conclusion 

Although we have not collected data on the exact size and frequency of 

releases of uranium ore and mining wastes, such releases undoubtedly occur 

during routine uranium mining activities. Like other mining and mineral 

operations where earthen materials are handled in bulk quantities, small 

releases surely occur while in transport by truck to uranium mills. Releases 

are also expected at the mine site from loading operations, from above-ground 
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• 4 -

piles of mining waste (due to wind and water erosion of sub-ores and waste 

rock), and from other activities. The principal health concern associated 

with mining activities is the release of radon, and it is important to manage 

large quantities of uranium mine wastes in a manner that prevents their use as 

construction material or as fill around buildings where radon may accumulate 

indoors. However, based on the reference materials we reviewed and our 

conversations with state regulators, small releases of uranium ore and mining 

wastes during transportation should not be a concern because: 

• Radon poses a serious problem only when large 

quantities of uranium ore or mining wastes are 

involved, such as at the mine itself or when bulk 

quantities of waste are used in and around 

construction sites. Occasional road spills are not 

expected to be in large enough quantities to present 

a radon hazard and are unlikely to cause any radon to 

accumulate in a restricted environment. 

• The release of uranium and thorium dust and 

resulting health concerns at active mine sites is 

small compared to the release and risks of radon. 

Because radon is not expected to be a problem 

associated with spills in transit, neither is the 

airborne release of uranium and/or thorium 

particulates. 

• The direct radiation hazard association with 

uranium ore is small. 

• Nonradioactive contaminants are generally present 

in uranium ores in low concentrations and any 

chemical (as opposed to radiological) hazards 

associated with the release of ores or waste rock in 

transit are expected to be small. 
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-5-

References 

1. Economic Profile of the Uranium Mining Industry, Jack Faucett Associates, 

April 1985. JACKFAU-85-311-13-A. 

2. Telephone Communication. Harvey Cohen, ICF, and Riff Meyer, Texas 

Department of Health, Radiological Control Division, February 13, 1986. 

3. Telephone Communication. Harvey Cohen, ICF, and Ed Cray, Colorado 

Department of Health, Radiation Division, February 13, 1986. 

4. Telephone Communication. Steve Wyngarden, ICF and Richard L. Smith, U.S. 

Department of Labor, Office of Mine Safety and Health, February 13, 1986. 

5. Draft Background Information Document: Proposed Standards of 

Radionuclides, EPA 1983, EPA 520/1-83-001. 

6. Potential Health and Environmental Effects of Uranium Mine Wastes, EPA 

1983, EPA 520/1-83-007. 

7. Generic Environmental Impact Study on Uranium Milling, Nuclear Regulatory 

Commission, 1979. 

8. Disposal or On-Site Storage of Thorium or Uranium Wastes from Past 

Operations, U.S. Nuclear Regulatory Commission, Branch Technical 

Position, Federal Register, October 23, 1981.