EPA Uranium Program UpdateLoren W. Setlow andReid J. RosnickEnvironmental Protection AgencyOffice of Radiation and Indoor Air (6608J)Washington, DC 20460NMA/NRC Uranium Recovery WorkshopApril 30, 20082OverviewEPA Radiation protection programUranium reports and abandoned minelands programCoordination with NRC rulemakingEPA regulatory requirements foruranium operations3EPA Radiation Protection Program•Specific Atomic Energy Act radiation protectionauthorities and responsibilities assigned to EPA underReorganization Plan No. 3 in 1970;•and•Environmental statute authorities; examples applicableto uranium extraction include•Uranium Mill Tailings Radiation Control Act•Clean Air Act•Clean Water Act•Safe Drinking Water Act•Comprehensive Environmental Response,Compensation and Liability Act4Uranium Reports andAbandoned Mine Lands Program•Technologically Enhanced Naturally OccurringRadioactive Materials from Uranium Mining, VolumeI: Mining and Reclamation Background(Revised June 2007)•Volume II: Investigation of Potential Health,Geographic and Environmental Issues FromAbandoned Uranium Mines (Final released April2008)•Uranium Location Database(August 2006)•Compilation of Federal and State sources,~15,000 records•Digital GIS database product5Uranium Reports andAbandoned Mine Lands Program•Uranium AML Program:•Continued to partner with Federal MiningDialogue agencies; uranium location databaseincorporated into combined AML spatialdatabase•Agency testimony for House Hearing on Navajouranium AML-Oct. 2007, Senate Hearing on AMLand uranium mining-March 2008•EPA assistance to Navajo Nation—Five yearplan to address uranium contamination6EPA Coordination with NRC Rulemaking•EPA policy on ISL groundwater protection:•EPA regulations generated in accordance withUMTRCA (40 CFR 192) provide the appropriatestandards to be used by NRC for groundwaterprotection•EPA’s UIC regulations promulgated under theSafe Drinking Water Act (40 CFR 146) providestandards which must be followed by ISLinjection well applicants, but are supplementaland independent of the requirements developedunder UMTRCA7EPA Coordination with NRC Rulemaking•During 2007 and 2008, EPA participated onNRC Working Group to develop draftproposed uranium ISL groundwaterprotection rule•EPA participation is to ensure that NRCincorporates EPA regulatory requirementsdeveloped under UMTRCA and that areconsistent with EPA UIC injection wellregulations•Under UMTRCA, NRC must obtain EPAconcurrence on the rule8EPA Regulatory RequirementsFor Uranium Operations (UMTRCA)•40 CFR 192 regulations implementing UMTRCA forenvironmental and radiation protection at uraniummills and uranium extraction facilities, adopted byNRC in 10 CFR Part 40•Under UMTRCA (and RCRA), restoration ofgroundwater must be to•(1) background; or•(2) Maximum Concentration Limits (MCL’s) forparticular constituents, whichever is higher; or•(3) Alternate Concentration Limits (ACLs), ifestablished9EPA Regulatory RequirementsFor Uranium Operations (UMTRCA)•ACLs must be determined on a case-by-casebasis and meet ALARA.•Class of use is not an approved provisionunder UMTRCA/RCRA for meeting ACL’s andALARA•Class of use could be considered as oneinput in determining final ACLs•Radiation and environmental protectionstandards for surface facilities andimpoundments also established in40 CFR 19210EPA Regulatory RequirementsFor Uranium Operations (SDWA-UIC; CWA)•EPA’s UIC regulations promulgated underthe Safe Drinking Water Act (40 CFR 144 and146) provide standards which must befollowed by ISL injection well applicants•UIC Class III injection wells•UIC Class V disposal wells•40 CFR 440 Subpart C implementing theClean Water Act with requirements forenvironmental limitations on dischargesfrom uranium, vanadium and radium mines,mills and ISL facilities11EPA Regulatory Requirements forUranium Operations (Clean Air Act)•40 CFR 61, Subpart B regulations limiting radonemissions from underground uranium minesinclude:•Applies to 10,000 tons/yr ore production, or100,000 tons/mine lifetime•Ambient air radon standard not to exceed 10mrem/yr to any member of the public-compliancedetermined with COMPLY-R, or equivalent,approved code•Annual reporting requirements – by 3/31 eachyear, emissions calculations for the year,monthly if not in compliance•Record keeping requirements: Five years12EPA Regulatory Requirements forUranium Operations (Clean Air Act)•40 CFR 61 Subpart W Requirements apply to facilitieslicensed to manage uranium byproduct materials(after 12/15/89) during and following the processing ofuranium ores•Preconstruction approval, 40 CFR 61.07•Impoundment construction and operationrequirements in 40 CFR 192 cross referenced inSubpart W•Limit on number/size of impoundments•Phased Disposal – lined impoundments nomore than 40 acres, no more than two inoperation at any time•Continuous Disposal – tailings are dewateredand immediately disposed, no more than 10acres uncovered at any time13EPA Regulatory Requirements forUranium Operations (Clean Air Act)Subpart W Requirements (continued)•What is an impoundment (per 40 CFR 192.32, whichcross references 40 CFR 260.10)?•“...a facility or part of a facility which is a naturaltopographic depression, man-made excavation ordiked area formed primarily of earthen materials(although it may be lined with man-madematerials) which is designed to hold anaccumulation of liquid wastes, or wastescontaining free liquids, and which is not aninjection well. Examples of impoundments areholding, storage, settling, and aeration pits,ponds and lagoons.”14EPA Regulatory Requirements forUranium Operations (Clean Air Act)Subpart W Requirements (continued)•Radon emission standard of 20 pCi/m2/sec --annual reporting requirements, notification inadvance of testing•The radon emission standard is for existingsources only (existing before 12/15/89)•All operators must comply with 40 CFR192.32(a), Application standards for processingoperations, and prior to end of the closureperiod.•Seehttp://www.epa.gov/radiation/neshaps/subpartw/index.htmlfor more information15Questions?