1. Update on EPA Regulatory and Guidance Activities
April 24, Presented by: Tom Peake U.S. Environmental Protection Agency Office of Radiation and Indoor Air Radiation Protection Division
Presented to: Low-Level Radioactive Waste Forum
Spring 2017 Meeting
Denver, CO

2. Presentation Outline Uranium Recovery Rulemakings
40 CFR part 192
40 CFR part 61, subpart W
Protective Action Guides (PAG) Manual
Waste Isolation Pilot Plant (WIPP)
Federal Guidance Reports

3. 40 CFR Part 192
Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings.
Issued pursuant to the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA).
January 2015 proposal to address groundwater protection at uranium in-situ recovery (ISR) facilities.
ISR injects a solution to mobilize uranium in groundwater.
Aquifer restoration to prevent migration of constituents.
Standards to address monitoring and post-restoration stability.
Significant comment on monitoring timeframe and costs.
Re-proposal published January 19, 2017.
Request comment on significant changes (180 days).
Long-term monitoring reduced from 30 to minimum 3 years.

4. 40 CFR Part 61, Subpart W Clean Air Act NESHAP.
Limits radon emissions from operating tailings.
Revision of 1989 rule published January 17, 2017.
Review mandated by Clean Air Act Amendments of 1990.
Utilizes Generally Available Control Technology.
Retains requirements applicable to conventional impoundments.
Radon flux standard and monitoring for older impoundments.
Size and number limitations for newer impoundments.
Specifies applicability to ISR, heap leach facilities.
Maintain liquids in “non-conventional” impoundments (ponds).
Limits on heap leach piles after processing is completed.

5. Protective Action Guides (PAG) Manual (1 of 2)
Guidance for state and local officials during radiological emergencies.
Evacuation/relocation, shelter-in-place.
Safety of food and drinking water.
Based on projected (avoided) dose.
Not establishing safe dose to allow.
1992 PAG Manual applicable to nuclear only.
Early and intermediate phases only.
Late phase and drinking water PAGs promised.

6. PAG Manual (2 of 2) Revision proposed 2013, final December 2016.
Extends to all radiological incidents.
Adopts FDA food PAG and thyroid dose for KI.
KI based on 5 rem projected thyroid dose to child.
Eliminates 50-year PAG (5 rem over 50 years).
Re-entry matrix based on DOE operational guidelines.
Late-phase cleanup/waste management guidance.
Drinking water PAG issued January 2017.
Two tiers based on projected first-year dose.
500 mrem general population (> 15 years old).
100 mrem sensitive populations (e.g., infants).
Health-based levels for providing alternative sources.

7. Waste Isolation Pilot Plant (WIPP)
Waste emplacement suspended after February 2014 radiation release.
Limited emplacement resumed January 2017.
EPA and New Mexico inspections in late 2016.
EPA certifies WIPP long-term performance.
10,000-year standards in 40 CFR part 191.
DOE required to apply for recertification every five years – third application submitted March 2014.
EPA declared application complete in January 2017.
Review delayed by February 2014 radiation release.
Recertification decision required within six months of completeness determination.

8. Federal Guidance Reports
AEA provides EPA authority to establish radiation protection guidance for federal agencies.
Policy recommendations and technical reports.
Two key technical documents under revision.
Work by ORNL, with support from EPA and NRC.
Incorporates age-specific dosimetry (ICRP categories).
FGR 15 – External Dose Coefficients.
Update to FGR 12 (1993).
Review of draft document nearing completion.
FGR 16 – Internal Dose and Risk Coefficients.
Updates FGR 11 (1988) and 13 (1998).
Preliminary draft (100 radionuclides) February 2016.
Complete draft for review expected Spring 2017.

9. Immediate Issue Being Considered
Age-specificity and “Reference Man/Individual”.
Considers capability to evaluate different age cohorts.
EPA is evaluating how it protects sensitive individuals, especially children.
Children may (or may not) have a higher risk per dose than adults depending on the radionuclide or exposure scenario.
One does not stay a child for a lifetime, so how should an annual dose limit factor in the different risks per dose over a lifetime? Is an annual dose limit the best approach?
This issue is important to 40 CFR Part 190 and its protection of “any member of the public” language, but the issue is broader than one regulation.
EPA is reviewing the science to inform the policy.

10. Questions? Tom Peake (202) 343-9765 peake.tom@epa.gov
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