A Comparison Of Mine Exposures With Regulatory Standards And Radon Daughter Concentrations

INTRODUCTION Standards limiting the annual exposure of United States uranium miners to radon daughters were established in 1967 at 12 Working-Level-Months (WLM). The standard was reduced by a factor of three, to 4 WLM, in 1971. Currently, the standard is again being examined to determine if it should be changed. Since 1967, Union Carbide has calculated individual monthly exposures in company and contract-operated mines located on the Colorado Plateau. Although it has been possible, by extensive ventilation control measures and accurate routine sampling, to meet the current exposure standard, there are many miners whose exposures closely approach the 4 WLM standard for any given year. However, it was noted that for miners who work for any extended period of years the [average] exposure was much less than the standard. The primary purpose of this paper is to show that, in effect, any annual exposure standard to radon daughters results in a long-term exposure considerably below that standard. Further, most miners, due to their job assignments and/or employment habits, only receive a small fraction of the standard. HISTORY OF EXPOSURE STANDARDS Prior to 1967, radiation protection in uranium mines was fundamentally based on a radon daughter concentration guide. In 1960, the American Standards Association published mine and mill radiation protection standards (ASA-1960). The Colorado Department of Mines, in 1961, adoped a standard which followed the ASA Standard and provided that if concentrations exceeded 10 Working Levels (WL), the area was to be shut down until corrective action was taken; if between 3 and 10 WL, corrective action was to be initiated; between 1 and 3, additional samples were to be taken and individual exposures evaluated; and if below 1 WL, conditions were considered to be controlled. In 1967, the U.S. Department of Labor issued the first exposure standard which called originally for limiting annual exposures to 3.6 WLM but which was later changed to 12 WLM. The complicated regulatory developments leading to this standard have been described elsewhere (Beverly-1969, Rock & Walker-1970). Effective July 1, 1971, this exposure standard was lowered to 4 WLM per year, which is the current standard. Over the past year, there has been speculation about the potential risk to uranium miners working at the present standard. A recent NIOSH Study Group Report (NIOSH-1980) concluded: "There is also strong evidence that a substantial risk extends to and below 120 WLM of exposure." The 120 WLM corresponds to a miner working in uranium mines for 30 years, a rare occurrence, at an exposure rate of 4 WLM per year, an even rarer occurrence. On the other hand, the General Accounting Office, in a recent Report to the Congress (GAO-1981), was very critical of reports by NIOSH on general low-level radiation risks. The GAO recognized that”...important questions remain unanswered about the cancer risks of low-level ionizing radiation exposure;" and recommended that Congress enact legislation giving statutory authority to an interagency committee to coordinate Federal research on health effects of ionizing radiation exposure. The International Commission on Radiation Protection at its March, 1980 meeting recommended limiting the inhalation of radon daughters to 0.02 J per year, equivalent to 0.4 WL, which on an annual basis would be 4.8 WLM and noted it is common to reduce this figure by 20% for allowance in the case of uranium miners for external and/or dust exposure(Sowby-1980). This is essentially equal to the present standard of 4 WLM. As earlier uranium miner exposure studies are reevaluated, and as new studies are conducted, it is important that the relationship between regulatory standards and the resulting actual exposures be recognized. UNION CARBIDE URANIUM MINING EXPERIENCE Union Carbide started mining Colorado Plateau uranium-vanadium ores in the late 1920s for the contained vanadium values. In the early 1950s, the Atomic Energy Commission contracted Union Carbide to produce uranium at mills located in Uravan and Rifle, Colorado. The company now has over fifty years of mining experience in the area. Some mines are operated as company mines and others are operated by private mining companies under a contractual arrangement. Ventilation, sampling, and exposure calculations are carried out the same in contract mines as in company-operated mines. Data presented in this report do not differentiate between company or contract employees and include all employees who worked underground any portion of a year in Union Carbide mines from 1967 through 1980. At the peak of uranium mining activities in 1970, there were 577 miners employed at year end (285 company employees and 292 contract) and 52 mines in operation (8 company-operated and 44 contract mines). Contract mines varied from two-man operations up to 15 employees. Company mines were generally the larger operations and employed from 20 to 100 miners.