# EPA’S **NESHAP Subpart W Activities** Reid J. Rosnick Environmental Protection Agency Office of Radiation and Indoor Air Radiation Protection Division (6608J) Washington, DC 20460 rosnick.reid@epa.gov May 27, 2010 Uranium Recovery Workshop 20102 

## Overview
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## EPA regulatory requirements for operating

uranium mill tailings (Subpart W)
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## General requirements applicable to Subpart W
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## Status Update on Subpart W Activities
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## Communications3 

### EPA Regulatory Requirements for Operating Uranium Mill Tailings (Clean Air Act)
• 40 CFR 61 Subpart W requirements apply to facilities licensed to manage uranium byproduct materials during and following the processing of uranium ores • Preconstruction approval, 40 CFR 61.07 • Impoundment construction and operation requirements in 40 CFR 192 cross referenced in Subpart W • Limit on number/size of impoundments • Phased Disposal – lined impoundments no more than 40 acres, no more than two in operation at any time • Continuous Disposal – tailings are dewatered and immediately disposed, no more than 10 acres uncovered at any time4 

## EPA Regulatory Requirements for Uranium Operations (Clean Air Act) Subpart W Requirements (continued) • 

### Radon emission standard of 20 pCi/m 2

### /sec -- annual reporting requirements, notification in advance of testing • 

### The radon emission standard is for existing sources only (existing before 12/15/89) • 

### All operators must comply with 40 CFR 192.32(a) See http://www.epa.gov/radiation/neshaps/subpartw/rule making -activity.html for more information5 

## EPA Regulatory Requirements for Underground Uranium Mining (Clean Air Act)

• 40 CFR 61.20, Subpart B regulations limiting radon emissions from underground uranium mines include: • Applies to 10,000 tons/yr ore production, or 100,000 tons/mine lifetime • Ambient air radon standard not to exceed 10 mrem/yr to any member of the public- compliance determined with COMPLY- R, or equivalent, approved code • Annual reporting requirements – by 3/31 each year, emissions calculations for the year, monthly if not in compliance • Record keeping requirements: Five years6 

## General Requirements Applicable to Subpart W

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### Subpart W and B facilities are subject to the general requirements of 40 CFR 61 . 01 - . 19 • Application for construction and modification • Notification of startup • Compliance with monitoring/maintenance requirements
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### Subpart W facilities are subject to the design and ground -water requirements of 40 CFR 192 . 32 (a) • Ground -water protection standards • Impoundment design requirements similar to hazardous waste facilities7 

### • 

## Status Update on Subpart W Activities8 

## Status of Subpart W Review Activities

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### Major emphasis on risk assessments • 

### Purpose is to update risk numbers used in 1989 rulemaking to reflect state of the science • Evaluate impacts to the public • Also focus on Tribes, EJ communities, children’s health • 

### All operating tailings piles and ISL’s • 

### Stylized scenarios will also be developed for representative future sites • 

### Scenarios would include varied climate, heap leach9 

## Status of Subpart W Review Activities Choosing a Risk Assessment Model
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### 1989 rule used AIRDOS to calculate dose and risk • 

### Determination which model is appropriate • 

### Candidate models include CAP88, GENII, RESRAD, MILDOS -AREA, MEPAS, GASPAR • 

### We welcome any other candidates you may know about10 

## Status of Subpart W Review Activities

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### Preliminary screening of candidate codes • 

### Once defined, the code will be used to determine individual and population dose and risk • 

### Some evaluation criteria include: • Exposure pathways modeled • Dose factors used • Risk factors used • Source term calculation • Input parameter sensitivity analysis • Verification/validation/documentation • Ease of use/user friendly11 

## Status of Subpart W Activities

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### Risk estimates will be developed for each Subpart W facility • 

### Estimates will be presented on a facility- by-facility basis, the same format used in the 1989 rulemaking • Source category, radionuclides released, existing controls • Bases for the risk estimate • Results of the dose and risk calculations • Description of supplementary emissions controls and cost effectiveness in reducing dose and risk12 

## Communications13 

## Communications

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### We have developed a website dedicated to Subpart W which provides internet access to background information already compiled by EPA • 

### Provides public access to all non - privileged records, especially technical documents, as well as useful links to sites relevant to Subpart W • 

### http://www.epa.gov/radiation/neshaps/subpartw/rule making -activity.html14 

## Communications

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### We are conducting quarterly conference calls to brief stakeholders on the review of Subpart W
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### Next Call is scheduled for Tuesday, July 6, 2010 at 11:00 AM EDT
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### Phone - in number – 1 - 866-299 -3188 • 

### Conference Code 202343956315 

## Communications

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### In addition to in - person regional presentations such as this, we are also holding an internet seminar (webinar)
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### Thursday, June 17 , 2010 at 11 : 00 AM, EDT
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### Please see the Subpart W website for details on how to access the webinar16 

## Questions?