DRC-2007-001822 - 0901a06880afdb70

WHITE MESA URANIUM MILL
LICENSE RENEWAL APPLICATION
STATE OF UTAH RADIOACTIVE MATERIALS LICENSE NO. UT19OO479
February 2Er?.007
Prepared By:
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver,Co 80265
Volume 4 of 5
@nvironmental Report)
WHITE MESA IJRANIUM MILL
Environmental Report
In Support of the License Renewal Application
STATE OF UTAH RADIOACTIVE
MATERIALS LICENSE No. UT1900479
February 28r 2007
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
TABLE OF CONTBNTS
1. INTRODUCTION
1.1. The Proposed Action ......... 11.2. Purpose and Need for the Proposed Action....... .................... I1.3. Benefits of the Proposed Action....... ..................... 11.4. Applicable Regulatory Requirements, Permits and Required Consultations.........21.4.1 Applicable Standards for Review and Approval of the License RenewalApplication ...............21.4.2 Components of the Application ......................41.4.3 Applicable Regulatory Standards for Mill Operations ........................71.4.4 Licenses and Permits ...................... 81.4.5 Consultations............... ...................91.5 Alternate Feed Program............. ...........92. ALTERNATIVES ................ 102.1 Consideration of Alternatives................ ............. l02.1.1 Renewal of the License...... ......... l02.1.2 No Action Altemative .................. 102.1.3 Alternatives Considered But Eliminated ......... ................ l l2.1.4 Consideration of Altemative Engineering Methods ....... 122.2 Cumulative Effects.... .....122.3 Comparison of the Predicted Environmental Impacts............... .......... 122.4 Updates & Changes to Factors That May Cause Reconsideration of Alternatives ......... 123. DESCRIPTION AND ASSESSMENT OF THE AFFECTED ENVIRONMENT....... 133.1 Introduction................ ..... 133.2 Site and/or Facility Description and Location.............. ...... 133.3 Climate, Meteorology and Non-Radiological Air Quatity....................................... 163.3.1 Climate and Meteorology.......... .................. 163.3.2 Baseline Air Quality .................... L73.4 Geolog5r..... .......................223.4.1 Regional Geology .....223.4.2 Local Geology..... ......243.4.3 Seismicity.. ...............243.4.4 Mineral Resources .......................243.5 Soi1s.......... .....263.6 Bedrock .........263.7 Water Resources ............293.7.l Surface Water......... ...................... 283.7.2 Groundwater Characteristics.......... ............... 36
3.7 .3 Groundwater Quality ........._._......443.7.4 Springs and Seeps .....523.8 Topography ................ ...................... 543.9 Demography and Socioeconomic Profile ..........543.9.I Demography of the Area.......... ......................543.9.2 Socioeconomic Profiles ................ .................563.10 Land Use............ .............. 56
Denison Mines (USA) corp., white Mesa Mill, Environmental Report, February zB,2oo7
i
4.
t.
6.
7.
3.lL Transportation ........... ......................573.12 Ecological Resources and Biota ......593.12.1 Terrestrial. ................593.12.2 Aquatic and Wetlands Biota ......623.13 Baseline Radiological Environment......... .........633.13.1 Background Radiation ................633.13.2 Radiological Impacts of Currently Licensed Operations. .................. 653.13.3 Mill's Alternate Feed Program............. .....l}g
COSTS AND BENEFITS.......
CONSIDERATION OF LONG TERM IMPACTS .................. 133MITIGATION OF IMPACTS ................. 134
Denison Mines (usA) corp., white Mesa Mill, Environmental Report, February 2g,2ao7
ii
INDEX TO FIGURES
Fisure No. Description Page
Figure 3.2-1
Figure3.2-2
Figure 3.3-1
Figure 3.3-2
Figure 3.4-1
Figure 3.4-2
Figure 3.7-1
Figure 3.7-2
Figure 3.7-3
Figure 3.7-4
Figure 3.7-5
Figure 3.7-6
Figtre3.7-7
Figure 3.7-8
Figure 3.9-l
Figure 3.13-l
Figure 3.13-2
Figure 3.13-3
Figure 3.13-4
Figure 3.13-5
Figure 3.13-6
Figure 3.13-7
Figure 3.13-8
Figure 3.L3-9
Figure 3.13-10
Figure 3.13-11
Figure 3.13-12
Figure 3.13-13
Figure 3.13-14
Figure 3.13-15
Figure 3.13-16
Figure 3.13-17
Mill Location Map
Mill Land Map
Wind Frequency Distribution for all Hours
High Volume Air Monitoring Stations
Colorado Plateau Geologic Map
Generalized Stratigraphy of White Mesa Mill
Drainages Map of the Vicinity of the Mill
Streamflow Summary, Blanding, Utah Vicinity
Surface Water Quality Sampling Stations in the White Mesa
Vicinity
Approximate Elevation of Top of Brushy Basin
Perched Water Levels
Approximate Location of Ruin Spring
Depth to Perched Water September 2002
Groundwater Sampling Stations in the Mill Vicinity
Population in the Project Vicinity - 2000 Census
Sources of Airbome Radioactive Effluents from the Mill and
Exposure Pathways to Man
BHV- I Radionuclide Concentrations (trrCi/ml)
BHV- 1 Uranium-Nat. Concentrations (pCi/ml)
BHV-I Thorium-23O Concentrations (prCi/ml)
BHV- I Radium-226 Concentrations (pCi/ml)
BHV- 1 Lead-210 Concentrations (p Ci/ml)
BHV-2 Radionuclide Concentrations (pCiiml)
BHV-2 Uranium Nat. Concentrations
BHV-2 Thorium 230 Concentration (frCi/ml)
BHV-2 Radium-226 Concentrations (pCi/ml)
BHV-2 Lead,-210 Concentrations (pCi/ml)
BHV-3 Radionuclide Concentrations (prCi/ml)
BHV-3 Uranium Nat. Concentrations (pCi/ml)
BHV-3 Thorium-230 Concentrations (pCilml)
BHV-3 Radium-226 Concentrations (pCi/ml)
BHV-3 Lead-210 Concentrations (pr Cilml)
BHV-4 Radionuclide Concentrations (pCi/ml)
l4
15
18
2t
23
25
29
32
33
38
40
42
43
45
55
67
79
80
81
82
83
84
85
86
87
88
89
90
9t
92
93
94
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
iii
Figure No.Description Pase
Figure 3.13-18
Figure 3.13-19
Figure 3.13-20
Figure 3.13-2I
Figure 3.13-22
Figure 3.13-23
Figure 3.13-24
Figure 3.13-25
Figure 3.13-26
Figure 3.13-27
Figure 3.13-28
Figure 3.13-29
Figure 3.13-30
Figure 3.13-31
Figure 3-13-32
Figure 3-13-33
Figure 3.13-34
Figure 3.13-35
Figure 3.13-36
BHV-4 Uranium-Nat.Concentrations (UCi/ml)
BHV-4 Thorium-23O Concentrations (pCi/ml)
BHV-4 Radium-226 Concentrations (pCilml)
BHV-4 Lead-210 Concentrations (p Ci/ml)
BHV-5 Radionuclide Concentrations (trrCilml)
BHV-5 Uranium-Nat. Concentrations (pCi/ml)
BHV-5 Thorium-23O Concentrations (trrCilml)
BHV-5 Radium-226 Concentrations (pCilml)
BHV-5 Lead-210 Concentrations (trr Cilml)
BHV-6 Radionuclide Concentrations (pCilml)
BHV-6 Uranium-Nat. Concentrations (pCi/ml)
BHV-6 Thorium-230 Concentrations (pCi/ml)
BHV-6 Radium-226 Concentrations (pCi/ml)
BHV-6 Lead-210 Concentrations (trrCi/ml)
Background Subtracted and Background Environmental TLD
Measurements (mrem/Qtr)
Ra-226 Concentrations In Vegetation (pcl/Kg)
Pb-210 Concentrations In Vegetation (pCilKg)
Occupational Airborne Activity Monitoring Locations
(Particulate & Radon) at the White Mesa Mill
Site Map of the White Mesa Mill Showing Location of
Buildings and Tankage
Figure 3.13-38 Period Average Radon WL
9s
96
97
98
99
100
101
102
103
t04
105
106
t07
108
111
tL2
113
119
120
126
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,200i
iv
INDEX TO TABLES
Table No.Description Paee
Table 3.3-1
Table 3.5-1
Table3.7-I
Table 3.7 -2
Table 3.7-4
Table 3.7-9
Table 3.9-1
Table 3.11-1
Table 3.ll-2
Table 3.12-l
Table 3.12-2
Table 3.13-l
Air Emission Inventory for Key Criteria Emissions (tons/yr)
Results of Soil Analyses at Mill Site
Drainage Areas of Mill Vicinity and Region
Summary of FES and Subsequent Sampling Results For
Cottonwood Wash and Westwater Creek
Water Quality of Groundwater in the Mill Vicinity
Results of Quarterly Sampling Ruin Spring (2003-2004)
Population Centers Within 50 Miles of the Mill Site
Production and Transportation Summary
Estimated 2002Dally Car and Truck Traffic on Route 191
Endangered, Threatened And Candidate Species In The Mill
Area
Species Managed Under Conservation Agreements/Strategies at
the Mill Area
Mill Site Average Dose From Natural Background Radiation
(Excluding Dose From Radon)
Table 3.13-2 FES Estimated Annual Releases Of Radioactive Materials
Resulting From The Mill (Annual releases (Ci))
Table 3.13-3 Comparison of FES Modeled Dose Commitments to Then
Applicable Radiation Protection Standards at The Nearest Actual
Residence at the time of The FES (2.8 Miles) North-Northeasr)
Table 3.134 Comparison Of Annual Dose Commitments To Nearest Potential
(Actual Current) Residence (1.2 Miles North) At Time Of FES
As Modeled In The FES With Applicable Radiation Protection
Standards
Table 3.13-5 FES Annual Population Dose Commitments Within 50 Miles of
the Mill
Table 3.13-6 MILDOS AREA Calculations (Excluding Radon) (40 CFR 190)
Annual Dose Commitments Adult, mrem/yr) Update of l99l
EnecoTech Run
Table 3.13-7 2007 Arizona Strip Ore TEDE (mrem/ry) (100 mrem limit to
any member of the Public, lncluding Radon)
Table 3.13-8 2007 Colorado Plateau Ore TEDE (mrem/ry) (100 mrem limit to
any member of the Public, Including Radon)
Table 3.13-9 2007 Arizona Strip Ore TEDE (mrem/ry) (10 mrem Constraint
Limit to any member of the Public, Excluding Radon)
Table 3.13-10 2007 Colorado Plateau Ore TEDE (mrem/ry) (10 mrem
Constraint Limit to any member of the Public, Excluding Radon)
20
27
30
34
46
53
56
58
59
6t
6t
65
66
69
69
7t
74
75
75
75
75
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
v
Table No.Description Pase
Table 3.13-Il
Table 3.13-12
Table 3.13-13
Table 3.13-14
Table 3.13-15
Table 3.13-16
Table 3.13-17
Table 3.13-18
Table 3.13-19
Table 3.13-20
Table 3.13-21
Table 3.13-22
Table 3.13-23
Table 3.13-24
Environmental Media Monitoring (Locations and Frequency
NCRP Report 94-Global Lead-210 Concentration Example
1999 TLD (Environmental) Gamma Dose (After Background
Subtraction)
1995/1996 Mill Stack Sampling Results
Soil Sample Concentrations
Annual Radon Emanation Testing Tailings Cells 2 & 3
Mill Airborne Activity Monitoring Locations
Grouped Workplace Locations for Airborne Particulate and
Radon Monitoring
Solubility Class, Chemical Form and Abundance of Feed
Material at the Mill
Particulate Concentrations (Gross Alpha) in Workplace
Locations for 1999 Mill Run
Average Radon Decay Progeny and Gamma (Measured During
the 1999 Mill Run)
Mill Workforce TEDE Dose (Rem) (Annual Dose Limit Of 5
Rem)
Occupational Doses-1997 Through 2005 (Rem)
Alternate Feed Materials Licensed to Date for Processing at the
Mill
INDEX TO APPENDICES
76
109
111
tt4
115
tt6
t2t
r22
123
t24
125
127
127
130
Appendix Description
C
Site Hydrogeology and Estimation of Groundwater
Travel Times in the PerchedZone
Background Groundwater Quality Report: Existing
Wells
Dose Assessment
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,zWj
vi
1. INTRODUCTION
Denison Mines (USA) Corp. ("Denison") operates the White Mesa Uranium Mill (the "Mill"),
located approximately six miles south of Blanding Utah, under State of Utah Radioactive
Materials License No. UT1900479 (the "License"). This Environmental Report ("ER") has been
prepared to accompany and support Denison's License Renewal Application (the "Application")
for renewal of the License under Utah Administrative Code R3l3 -22-37 .
This ER describes the environment in which the Mill operates, the environmental and radiation
monitoring results to date, and the potential for future impacts to public health, safety and the
environment. This ER demonstrates that the Mill has been operating in compliance with all
applicable regulatory standards and ALARA (as low as reasonably achievable) goals, and that
continued operation of the Mill in accordance with the existing terms and conditions of its
License will not be inimical to public health, safety or the environment.
1.1. The Proposed Action
The proposed action is the renewal of the License on the same terms and conditions as set forth
in the existing License. Denison plans to continue operating the Mill on these same terms and
conditions. Accordingly, the Application and this supporting ER serve to supplement, and
update as necessary, already existing and accepted analyses of the facility.
1.2. Purpose and Need for the Proposed Action
The Mill is licensed to process natural uranium ore and certain alternate feed materials. The
purpose of the Mill's process is to extract contained uranium and co-product metals, such as
vanadium, from such ores. The current License is up for renewal on March 31, 2007. It is the
purpose of this ER to support Denison's Application to renew the License on the same terms and
conditions as the existing License. This ER provides the necessary technical information and
data to demonstrate that the Mill's operations continue to be compliant with regulatory standards
and that potential environmental impacts and/or radiation exposure to the public and workers are
as low as reasonably achievable.
1.3. Benefits of the Proposed Action
The Mill is currently one of only two operating conventional uranium mills in the United States.
With the notably high worldwide demand for uranium weighing heavily against limited uranium
supplies and domestic processing capabilities, the benefit of the Mill's processing capability is
both demonstrable and undeniable. Currently, about 20Vo of the electric power generated within
the United States is derived from nuclear power plants, with a major thrust underway to build
additional nuclear power stations both in the United States and abroad. Given that the Mill is
centrally located within the Colorado Plateau mining district (a major source of domestic
uranium) and that it is one of only two operating uranium mills within the United States (and the
only operating uranium mill on the western slope of the Rocky Mountains), the continued
operation of the Mill is vital to the uranium mining industry in the region and to the United
States nuclear industry as a whole. In addition to this larger energy benefit, the operation of the
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
I
t.4.
Mill provides significant local benefits by supporting the tax base for San Juan County and by
providing jobs to local citizens. The Mill is a major employer in San Juan County, which has
one of the highest unemployment rates in the state, and depends on the well paying jobs provided
by the Mill.
Applicable Regulatory Requirements, Permits and Required Consultations
1.4.1 Applicable Standards for Review and Approval of the License Renewal Application
R3l3-22-39 (Executive Secretary Action on Applications to Renew or Amend) provides that in
considering an application by a licensee to renew or amend a license, the Executive Secretary of
the Utah Radiation Control Board (the "Executive Secretary") will use the criteria set forth in
Sections R3l3-22-33 (General Requirements for the Issuance of Specific Licenses) and R313-24
(Uranium Mills and Source Material Mill Tailings Disposal Facility Requirements) as
applicabler.
In addition, Form DRC-01, 02194 requires that the application include responses to the
"respective item and,/or sub item of the licensing guide," which the State of Utah Division of
Radiation Control ("DRC") has advised is the applicable U.S. Nuclear Regulatory Commission
("NRC") Standard Review Plan for the type of activity being licensed. For the renewal of
uranium mill licenses, Denison has been advised by NRC that the applicable Standard Review
Plan is the Standard Review Plan for In Situ Leach Uranium Extraction License Applications,
NUREG-1 569, June 2003 ("NUREG-1 569").2
Accordingly, the Application must demonstrate that the following criteria enumerated in R313-
22-33, as applicable, are satisfied:
a) The applicant and all personnel who will be handling radioactive material are qualified
by reason of training and experience to use the material in question for the purpose
requested in accordance with the applicable rules in a manner as to minimize danger to
public health and safety or the environment;
b) The applicant's proposed equipment, facilities, and procedures are adequate to minimize
danger to public health and safety or the environment;
facilities are permanently located in Utah;
I plt3-22-39 also requires the Executive Secretary to use the applicable criteria in R3l3-22-50 (Special Requirements for
Specific Licenses of Broad Scope), and R3l3-22-75 (Special Requirements for a Specific License to Manufacture, Assemble,
Repair, or Distribute Commodities, Products, or Devices Which Contain Radioactive Material) and in Rules R3l3-25 (License
Requirements for Land Disposal of Radioactive Waste-General Provisions), R3 l3-32 (Medical Use of Radioactive Material),
R3 l3-34 (Requirements for Irradiators), R3 l3-36 (Special Requirements for lndustrial Radiographic Operations), or R3 l3-38
(Licenses and Radiation Safety Requirements for Well Logging). However, none of these criteria are applicable to uranium
mills.
' NRC ttuff udvised that they did not prepare a similar Standard Review Plan for uranium mills at that time because they did not
anticipate any new uranium mills being constructed, and they concluded that, because both uranium mills and ISL uranium
recovery facilities are subject to l0 CFR Part 40, NUREG- 1569 could be applied universally to both types of facilities.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,20A1
2
c)
d) The issuance of the license will not be inimical to the health and safety of the public;
The applicant satisfies applicable special requirements in sectionsR3l3-22-50 and R3l3-
22-75, and Rules R3l3-24, R313-25, R313-32, R313-34, R3l3-36, or R313-38; and
To the extent the original siting of the Mill has resulted in any environmental costs, the
Executive Secretary will be able to conclude, after weighing the environmental,
economic, technical and other benefits against such environmental costs and considering
available altematives, that the action called for is the issuance of the proposed license
renewal.
R3l3-22-33 provides that a license application shall be approved by the Executive Secretary if
the Executive Secretary determines that the forgoing criteria are satisfied.
Similarly, this Application must also demonstrate that the Mill continues to comply with the
applicable provisions of 10 CFR Part 40 Appendix A, as required by R313-24-3 and must
contain an environmental report describing the proposed action, a statement of its purposes, and
the environment affected as required by R313 -24-3 and NUREG-1569.
It is important to note that since the Application is for renewal of an existing licensed facility, the
Application will focus on any changes to currently licensed activities and on demonstrating how
existing licensed facilities continue to meet applicable regulatory criteria. As stated in the
introduction to NUREG - 1569 :
For renewals, the licensee need only submit information containing changes from
the currently accepted license. The licensee need not resubmit a complete
application covering all aspects of facility operation. Reviewers should analyze
the inspection history and operation of the site to see if any major problems have
been identified over the course of the license term and should review changes to
operations from those currently found acceptable (see Appendix A). If the
changes are found to be acceptable, then the license is acceptable for renewal.
For license amendments and renewals, the operating history of the facility is often
a valuable source of information concerning the adequacy of site characterization,
the acceptability of radiation protection and monitoring programs, the success of
and adherence to operating procedures and training programs, and other data that
may influence the staff's determination of compliance. Appendix A to the
standard review plan^provides guidance for review of these historical aspects of
facil ity performance.'
As indicated in the excerpts quoted above and elsewhere in NUREG-1569, Appendix A to
NUREG-1569 lists the documentation required and the criteria to be applied in connection with
license renewal applications for uranium mills. Appendix A provides that for license renewals,
the historical record of site operations, including air and groundwater quality monitoring,
3 NUREG-t569, page xvii.
e)
0
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
J
provides valuable information for evaluating the licensing actions. The Appendix then lists a
number of specific areas where a compliance history or record of site operations and changes
should be provided in the application for review. The Appendix then provides that if, after a
review of these historical aspects of site operations, the staff concludes that the site has been
operated so as to protect health and safety and the environment and that no un-reviewed safety-
related concerns have been identified, then only those changes proposed by the license renewal
application should be reviewed using the appropriate sections of NUREG-1569. The Appendix
concludes by specifically stating that aspects of the facility and its operations that have not
changed since the last license renewal should not be re-examined.
I.4.2 Components of the Application
In order to satisfy the requirements of R3l3-22-39, and applicable criteria set out inR3l3-22-33,
R3l3-24-3 in accordance with the provisions of NUREG-1569, the Application is comprised of
the following:
a) ApplicationDocument
The Application document describes the Mill's process and equipment; waste systems;
administration, including qualifications of personnel, management controls, inspection and audit
programs, training program, radiation protection program, and environmental surveillance
program; a review and analysis of potential accidents and the Mill's emergency response
programs; the Mill's reclamation plan; and a listing and description of violations, incident
investigations, excursions and regulatory exceedances. Attached to or incorporated by reference
in the Application are the Mill procedures and programs that are relevant to those matters.
While NUREG-1569 provides that aspects of the facility and its operations that have not changed
since the last license renewal should not be re-examined, it is intended that the Application and
the documents appended thereto and incorporated by reference therein, together with the
accompanying ER, will.
demonstrate that Denison and all Mill personnel are qualified by reason of training
and experience to perform their respective functions in accordance with applicable
rules in a manner as to minimize danger to public health and safety or the
environment;
describe the Mill's existing equipment, facilities, and procedures and demonstrate that
they continue to be adequate to minimize danger to public health, safety or the
environment; and
iii) confirm that the Mill facilities are located in Utah,
as required under R3l3-22-33, and that the Mill continues to satisfy the applicable special
requirements of R3 l3-24.
Denison Mines (USA) corp., white Mesa Mill, Environmental Report, February zB,2007
4
i)
ii)
No changes to the Mill's existing equipment, facilities, and procedures are requested as part of
this license renewal process. Some changes to the Mill's equipment, facilities and procedures
have been made with the approval of the NRC or in accordance with existing license conditions
since the last license renewal in March 1997. These changes are reflected in the descriptions set
out in the Application and in the documents incorporated by reference therein. However, since
the changes are comprised in the existing License, Executive Secretary approval of these changes
is neither sought nor requested by the Application.
b) Environmental Report
This ER accompanies and is incorporated by reference into the Application. This ER
incorporates by reference, updates or supplements the information previously submitted in
previous environmental analyses performed at the Mill to reflect any significant environmental
change, including any significant environmental change resulting from operational experience or
a change in operations or proposed decommissioning activities since the last License renewal on
March 31,1997.4
A Final Environmental Statement (the "FES") was prepared by NRC for the original Mill
License application in May 1979, which is incorporated by reference into, updated or
supplemented by this ER. The basis for the FES was the Environmental Report, White Mesa
Uranium Project San Juan County, Utah, dated January 1978, prepared by Dames & Moore (the
"1978 ER"). ln addition, the following environmental evaluations have also been performed for
the Mill and are incorporated by reference into, updated or supplemented by this ER:
. an EA was prepared by NRC in September 1985 for the Mill License renewal (the "1985
EA");
. ar EA was prepared by NRC in February 1997 for the Mill License renewal (the "1997
EA'');
. arl EA was prepared for Denison's reclamation plan (the "Reclamation Plan") in February
2000 (the "2000 EA");
a Page xvi of NUREG-1569 provides that an applicant for a new operating license, or for the renewal or amendment of an
existing license, is required to provide detailed information on the facilities, equipment, and procedures to be used and to submit
an environmental report that discusses the effect of proposed operations on public health and safety and the impact on the
environment as required by l0 CFR 51.45, 51.60, and 51.66. l0 CFR 51.60 provides that in the case ofan applicarion to renew a
license issued under l0 CFR Part 40 for which the applicant has previously submitted an environmental report, the applicant may
submit a supplement to the applicant's previous environmental report, which may be limited to incorporating by reference,
updating or supplementing the information previously submitted to reflect any significant environmental change, including any
significant environmental change resulting from operational experience or a change in operations or proposed decommissioning
activities. Although the regulations in l0 CFR 51.45, 51.60 and 51.66, which implemenr Secrion 102(2) of the National
Environmental Policy Act, do not apply to State licensing activities, the State of Utah has its own requirements to prepare an
Environmental Report in R3l3-24-3. It should also be noted that R3 l3-22-32 states that the Application may incorporate by
reference information contained in previous applications. By including changes since the last application and incorporating by
reference those aspects of previous applications that have not changed, the Executive Secretary will be able to focus his review
on those aspects oflicensed operations that have changed since the previous license grant.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
5
an EA was prepared in December, 2001 (the "2001EA") in connection with a license
amendment issued by NRC authorizing the receipt and processing at the Mill of certain
altemate feed materials from Molycorp Inc.'s Mountain Pass Facility;
an EA was prepared in August, 2002 (the "2002 EA") in connection with a license
amendment issued by NRC authorizing receipt and processing at the Mill of certain
alternate feed materials from the Maywood Formerly Utilized Sites Remedial Action
Program ("FUSRAP") site in Maywood, New Jersey;
a Statement of Basis was prepared in December 2004 by DRC in connection with the
issuance of the Mill's Groundwater Discharge Permit (the "GWDP Statement of Basis");
and
a Safety Evaluation Report was prepared by DRC in November 2005 in connection witha license amendment issued by the Executive Secretary authorizing receipt and
processing at the Mill of certain alternate feed materials from the FMRI facility in
Muskogee Oklahoma (the "FMRI SER").
Accordingly, this ER includes the following matters as contemplated by Appendix A to
NUREG-1569:
i) Updates and changes to any site characterization information important to the
evaluation of exposure pathways and doses including site location and layout; uses of
adjacent lands and waters; population distributions; meteorology; the geologic or
hydrologic setting; ecology; background radiological or non-radiological
characteristics ; and other environmental features ;
ii) Environmental effects of site operations including data on radiological and non-
radiological effects, accidents, and the economic and social effects of operations;
iii) Updates and changes to factors that may cause reconsideration of altematives to the
proposed action;
iv) Updates and changes to the economic costs and benefits for the facility since the last
application; and
v) The results and effectiveness of any mitigation proposed and implemented in the
original license.
With respect to the assessment of any impact on groundwater resulting from the activities
conducted pursuant to the License, this ER incorporates by reference certain reports, or portions
thereof, filed with the Co-Executive Secretary of the Utah Water Quality Board pursuant to the
Mill's Groundwater Discharge Permit ("GWDP")(see Section 1.4.3.2 below).
The result of the foregoing is that, as required by R313-24-3, this ER, together with the previous
environmental analyses and reports incorporated by reference herein, or updated or
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
6
supplemented by this ER, describes the proposed action, a statement of its purposes, and the
environment affected, and presents a discussion of the following:
. An assessment of the radiological and non-radiological impacts to the public health from
the continuation of the activities to be conducted pursuant to the License;
. An assessment of any impact on waterways and groundwater resulting from the
continuation of the activities conducted pursuant to the License;
. Consideration of alternatives, including alternative sites and engineering methods, to the
continuation of the activities to be conducted pursuant to the License; and
. Consideration of the long-term impacts including decommissioning, decontamination,
and reclamation impacts, associated with the continuation of the activities to be
conducted pursuant to the License.
Table 1-1 was prepared as a means of identifying the location in the ER of each of the subjects
listed above.
Table 1-1
Location of Components in the Environmental Report
ER Report Subiect Location In:Environmental Roport
Site Location and Layout Section 3.1
Use of adiacent Lands & Water Sections 3.10 & 3.7.3.2
Population Distribution Section 3.9
Meteorology Section 3.3
Geolosic Settins Sections 3.4 & 3.1 .2.1
Hvdroloeic Settine Sections 3.7.2.2, 3.7 .2.3 & 3.7.2.4
Ecology Section 3.12
Background Radiological & Non-
Radiolosical Characteristics
Environmental effects of site ooerations Sections 3.3.2.3, 3.1 .1.3, 3.7 .3, 3.7.4 & 3.13
Accidents Section 4
Economic and Social Effects Sections 3.9.2 & 5
Updates and Changes to factors that that may
cause reconsideration of alternatives
Section 2
Cost and Benefit Analysis Section 5
Mitieation of Imoacts Section 7
1.4.3 Applicable Regulatory Standards for Mill Operations
The Mill is subject to numerous regulatory standards, many of which are addressed in various
sections of this ER. The main regulatory standards are the following:
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2Cf7
7
i) Utah Regulations Applicable Specifically to Uranium Mills
The Mill must comply with the applicable provisions of l0 CFR Part 40 Appendix A, as required
byR3l3-24-3.
ii) Utah Radiation Protection Standards
The primary radiation protection standards applicable to the Mill are found in R3l3-15.
iii) Utah Groundwater Protection Regulations
The Mill must comply with the Utah Water Quality Act (Utah Code Annotated 19-5) and the
Utah Ground Water Quality Protection Regulations (Utah Administrative Code R317-6).
iv) Clean Air Act
The Mill must also comply with Clean Air Act national emission standards for hazardous
pollutants ("NESHAPs"). The requirements for operating (i.e., active) uranium mills are
forth in 40 CFR Part 61, Subpart W.
I.4.4 Licenses and Permits
The Mill has the following License and permits in place which provide the regulatory framework
for Mill Operations and the environmental, health & safety procedures.
i) Mill Radioactive Materials License
As mentioned above, the Mill holds the License, which was issued pursuant to the provisions of
R3l3-22 and R313-24.
ii) Groundwater Discharge Permit
The State groundwater protection rules described in Section 1.4.2.5 above are implemented at the
Mill through State of Utah Groundwarer Discharge Permit No. UGW370004.
iii) State of Utah Air Quality Permit
The State of Utah Department of Environmental Quality ("UDEQ") administers and implements
the State's rules and regulations for air quality.
Denison holds Division of Air Quality Approval Order No. DAQE-AN 1205005-06 (the "Air
Quality Permit"), issued by UDEQ, for the Mill. The Air Quality Permit describes the approved
air pollution control equipment required to be operated at the Mill, and sets limitations and test
procedures for emissions to the atmosphere from the indicated emission points, as well as
general procedures for controlling dust from roads and fugitive sources.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
8
air
set
1.4.5 Consultations
No consultations of other agencies were made by Denison in connection with this Application.
This is because the Mill is an existing licensed facility that is operating in accordance with its
License and in compliance with applicable regulatory standards, and Denison seeks a renewal of
its License to continue its existing operations on the same terms and conditions. However, the
Executive Secretary may make any such consultations he deems appropriate.
1.5 Alternate Feed Program
Under the License, the Mill is authorized to process conventionally mined ores and certain
alternate feed materials. Alternate feed materials are acceptable for processing at the Mill if they
meet the criteria set out in NRC's Altemate Feed Guideline and a specific License amendment
authorizing receipt and processing of the Alternate Feed Material at the Mill is issued by the
Executive Secretary. In reviewing a proposed Altemate Feed Material, the Mill and the
Executive Secretary must determine on a case-by-case basis whether the proposed feed material
can be processed at the Mill in a manner that does not give rise to any significant public health,
safety or environmental impacts, over and above the previously licensed activities. The Mill
intends to continue to pursue its alternate feed program set out in Section 3.13.2 of this ER.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,zOO1.
9
.,
2.1
ALTERNATIYES
Consideration of Alternatives
The action under consideration is the renewal of the License for continued operation of the Mill.
The alternatives available to the Executive Secretary are to:
a) Renew the License with its existing terms and conditions;
b) Renew the License with such additional conditions as are considered necessary or
appropriate to protect public health, safety and the environment; or
c) Deny renewal of the License.
As demonstrated in this ER, the environmental impacts associated with renewal of the License
do not warrant either limiting the Mill's future operations or denying the License renewal. As
there are no significant public health, safety or environmental impacts associated with renewal of
the License on its existing terms and conditions, Denison asserts that alternatives with equal or
greater impacts need not be evaluated, and alternative a) is the appropriate alternative for
selection.
2.1.1 Renewal of the License
The Mill is one of only two operating uranium mills in the Unites States and the only uranium
mill on the western slope of the Rocky Mountains. As a result, the Mill is the only currently
available opportunity for production of uranium from conventionally mined ore in San Juan
County and in the four corners area of the United States. The Mill therefore provides a benefit to
the regional community and to the uranium industry as a whole in the United States. Renewal of
the License would allow the Mill to continue to provide these benefits.
As will be demonstrated in Section 3 of this ER, the Mill's equipment, facilities and procedures
are adequate to minimize impacts to public health, safety and the environment. The Mill has
operated since its inception in compliance with all applicable regulatory standards and ALARA
goals and is capable of continuing to operate in compliance with such standards and goals.
In addition to the License, the Mill has been issued a Groundwater Discharge Permit, which
provides additional protection for public health and the environment. The Mill has demonstrated
that it is capable of continuing to operate in a manner that satisfies all regulatory standards and
ALARA goals under the existing terms and conditions of the License and GWDP, there is no
need to add any additional conditions to the License in order to protect public health, safety or
the environment.
2.1.2 No Action Altemative
A "no action" alternative would result in the License renewal application being denied and the
immediately available processing opportunities for mined uranium ore being lost in the short
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
l0
term, severely impacting independent uranium miners in the area and lessening the United
States' capability to respond to the need for uranium for nuclear power generation.
Denying renewal of the License would eliminate utilization of the Mill during a time when
commodity prices for uranium are favorable, and the demand for uranium milling capacity is
unprecedented. Permitting the Mill to continue processing conventionally mined ore for the
recovery of uranium will provide the opportunity for regular employment in an economically
depressed area of the United States. A large percentage of the workers at the Mill are Native
American, and this employment opportunity has significant direct impact in the local Native
American community. In addition to the direct hiring of employees at the Mill, local miners and
other western United States mining companies require access to an operating uranium mill. The
inability of these mining entities to gain access to local milling services will prevent the mining
industry from responding to the cument uranium supply shortage. Thus, secondary local
economies will not enjoy the benefit of renewed mining income, and national demand for
uranium will continue to be reliant primarily on foreign supplies of uranium for nuclear fuel. In
order to respond to the current uranium market, conventional mining companies will be forced to
license and construct new uranium milling facilities to engage in conventional ore processing,
directly in opposition to the objective of non-proliferation of new uranium mill tailings disposal
facilities embodied by l0 CFR Part 40 Appendix A, Criterion 2.
As will be demonstrated in Section 3 of this ER, the impacts associated with renewal of the
License and continued operations thereunder will be within the realm of impacts anticipated in
the FES, the 1985 EA and the 1997 EA, and the continued licensing of the Mill will satisfy
applicable criteria inR3l3-22-33 and P.3l3-24. As a result, Denison asserts that the Executive
Secretary should have no basis for denying the proposed action.
2.1.3 Alternatives Considered But Eliminated
i. Consideration of Alternative Sites
The Mill is already sited and in existence and has been operating for over 25 years. It is not
feasible to consider moving the Mill to an altemative site. Even if that were possible, as will be
demonstrated in Section 3 of this ER, the Mill is sited in a good hydrogeologic setting and is
otherwise well sited for its operations. This is evident from the fact that the Mill has operated
since its inception in compliance with applicable regulatory standards and ALARA goals.
If the License is not renewed, there can be no assurance that, as an alternative, an equally well-
suited site, that complies with the applicable siting requirements of 10 CFR Part 40 Appendix A,
can be identified and obtained. Even if a suitable alternative site were to be identified and
obtained, licensing and construction of a new mill could not be accomplished in a time frame
that would ensure production could commence in a period of suitable market conditions.
Furthermore, as the existing Mill tailings would have to be decommissioned in place, creation of
a new mill site would result in unnecessary proliferation of mill tailings disposal facilities in
contravention of 10 CFR Part 40 Appendix A, Criterion 2.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
ll
,,,
2.1.4 Consideration of Altemative Engineering Methods
As will be demonstrated in Section 3, the existing Mill facilities, equipment, procedures and
training of personnel have resulted in the Mill operating since inception in compliance with all
applicable regulatory standards and ALARA goals. Current modeling demonstrates that the Mill
is capable of continuing to operate under the existing terms and conditions of the License in a
manner that will continue to comply with such standards and goals. Furthermore, the Mill's
GWDP institutes additional protections and engineering controls, including the requirement that
any new construction of tailings cells must meet current best available technology standards.
Therefore, there is no need to consider altemative engineering methods. The existing equipment
and facilities, together with the existing terms and conditions of the License and the GWDP are
sufficient to ensure that all applicable requirements will continue to be satisfied.
Cumulative Effects
There are no past, present, or reasonably foreseeable future actions which could result in
cumulative impacts that have not been contemplated and previously approved under the existing
Mill License.
As stated throughout this ER, License renewal will result in no activity with potential,
significant, incremental impacts to public health, safety or the environment over and above the
actions contemplated in the FES, the 1985 EA and the 1997 EA. The activities contemplated
with regard to ore processing remain unchanged from those previously authorized under the
License.
2.3 Comparison of the Predicted Environmental Impacts
There have been no observed significant impacts which were not previously quantified and
addressed to public health, safety or the environment resulting from existing activities conducted
under the License. As there will be no significant changes in Mill operations if the License is
renewed under its existing terms and conditions, possible impacts to public health, safety or the
environment will not exceed those predicted in the original License application and periodic
renewals.
2.4 Updates & Changes to Factors That May Cause Reconsideration of Alternatives
As discussed in Section 5, Costs and Benefits, there have been no changes to factors that may
cause reconsideration of alternatives. There have been no significant changes in the costs
associated with operation of the Mill, and the benefits associated with continued operation of the
Mill have become more evident over time as the number of uranium mills has dwindled and the
demand for uranium milling services from local miners and the industry as a whole has increased
in recent years. Furthermore, no new alternatives to the services provided by the Mill have been
identified since the last License renewal in 1997 .
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
t2
3.
3.1
DESCRIPIION AND ASSESSMENT OF TIIE AFFECTED ENVIRONMENT
Introduction
This Chapter of the ER provides a description and an assessment of the environment surrounding
the already licensed and existing White Mesa Uranium Mill ("the Mill"). The environmental and
radiation monitoring results to date demonstrate that the Mill has been operating in compliance
with applicable regulatory standards and ALARA goals, and that continued operation of the Mill
can be accomplished in accordance with such standards and goals.
3.2 Site and/or Facility Description and Location
The Mill is regionally located in central San Juan County, Utah, approximately 6 miles (9.5 km)
south of the city of Blanding. The Mill can be reached by taking a private road for
approximately 0.5 miles west of Utah State Highway 191. See Figure 3.2-1.
Within San Juan County, the Mill is located on fee land and mill site claims, covering
approximately 5,415 acres , encompassing all or part of Sections 21,22,27,28,29,32, and 33 of
T37S, R228, and Sections 4, 5, 6, 8, 9, and 16 of T38S, F.228, Salt Lake Base and Meridian.
See Figure 3.2-2.
All operations authorized by the License are conducted within the confines of the existing site
boundary. The milling facility currently occupies approximately 50 acres and the tailings
disposal cells encompass another 250 acres. See Figure 3.2-2.
The resident currently nearest to the milling facility is located approximately 1.2 miles (1.9 km)
to the north of the Mill site, just north of air sampling station BHV-I. See Figure 3.3-2.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
t3
E
I
p
I
B
I
tr
p
,9
E
E
P't
ni
=i,
la
ig
I 22 livL ,Al_ _1Ili lAii"* o ;
I ). *T'* *
t;l-
|
| \ zt
'1., L.. c;
l.a ! i t
$ l;^\sfi' . '::l
\ i'1,\.\ - -',}t-
a t;-",.
tat
dIaI
a'tta\i
2
IE'
)
,l\
21
t-
,,it
-ilr , 1.1'"
24 3 1g i lzo)-i1 niii tL-; i, \.. j'u ;,''\ 2s \. 30 ! t ('z"' ltjld$I -i-*d-f-W,
}.* / ,'*.,*rVYy;
rtl,
-l
I
I
l,-F Ii.-
I::!t1"
tlli
{n
i
f'*,.1trf
/
, "\..*
7
-ta
- '18
J
toIE
z,I-l ag
I /l/
I
I
T-
I
I
-l-
i
\,,,,
\
I,iiU
.{.
.'l
\3
-i:t
I
i.rEi{i
III.ta
cLA[t S
7+
1s tl.tprr , r'
..i-" I i*5 ilri
Property Boundary
Reservation Boundary
Canyon Rim
-
ITIIIII
Denison Mines (USA) Corp.
Figure 3.2-2
White Mesa Mill
Land Map
c
h
ab
.iq
BI
$
cg
E
B
Fi
$
I
E
P
E
E
E
I!s
Es
OB
iH
=i
3.3 Climate, Meteorology and Non-Radiological Air Quality
3.3.1 Climate and Meteorology
3.3.1.1 Resional
The climate of southeastem Utah is classified as dry to arid continental. Although varying
somewhat with elevation and terrain, the climate in the vicinity of the Mill can be considered as
semi-arid with normal annual precipitation of about 13.4 inches. Most precipitation is in the
form of rain with snowfall accounting for about 29Vo of the annual total precipitation. There are
two separate rainfall seasons in the region, the first in late summer and early autumn (August to
October) and the second during the winter months (December to March). The mean annual
relative humidity is about 44 percent and is normally highest in January and lowest in July. The
average annual Class A pan evaporation rate is 68 inches (National Oceanic and Atmospheric
Administration and U.S. Department of Commerce, 1977), with the largest evaporation rate
typically occurring in July. This evaporation rate is not appropriate for determining water
balance requirements for the tailings management system and must be reduced by the Class A
pan coefficient to determine the later evaporation rate. Values of pan coefficients range from
60Vo to 8lVo. Denison assumes for a water balance calculations an average value of 7O7o to
obtain an annual lake evaporation rate for the Mill area of 47 .6 inches. Given the annual average
precipitation rate of 13.4 inches, the net evaporation rate is 34.2 inches per year.
The weather in the Blanding area is typified by warm summers and cold winters. The mean
annual temperature in Blanding is about 50oF. January is usually the coldest month and July is
usually the warmest month.
Winds are usually light to moderate in the area during all seasons, although occasional stronger
winds may occur in the late winter and spring. The predominant winds are from the north
through north-east (approximately 30 percent of the time) and from the south through south-west
(about 25 percent of the time). Winds are generally less than 15 mph, with wind speeds faster
than 25 mph occurring less than one percent of the time. The National Weather Service Stationin Blanding, Utah is located about 6.25 miles north of the Mill. Data from the station is
considered representative of the local weather conditions (1978 ER, Section 2.7.2). However, as
an element of the pre-construction baseline study and ongoing monitoring programs, the Mill
operates an onsite meteorological station, described in greater detail below. Further details about
weather and climate conditions are provided in the 1978 ER (Section 2.7) and, in the FES
(Section 2.1).
3.3.1.2 On Site
On-site meteorological monitoring at the Mill was initiated in early 1977 and continues today.
The original purpose of the meteorological monitoring program was to document the regional
atmospheric baseline and to provide data to assist in assessing potential air quality and
radiological impacts arising from operation of the Mill.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,20Oj
l6
After the Mill construction was completed, the monitoring programs were modified to facilitate
the assessment of Mill operations. The current meteorological monitoring program includes data
collection for wind speed, wind direction, atmospheric stability according to the standard
Pasquill scheme (via measurements of deviations in wind direction, referred to as sigma-theta),
and precipitation as either rain or snow. The recorded on-site meteorological conditions are
reported to Denison on a semi-annual basis and are described in semi-annual reports prepared for
Denison and maintained at the Mill. Figure 3.3-1 shows the windrose for the Mill site for the
period of January * December 2006, the most recent full year of compiled meteorological data.
3.3.2 Baseline Air Ouality
3.3.2.1 FES Evaluation
At the time of the 1978 ER and FES, the Four Comers Air Quality Control Region which
encompasses parts of Colorado, Arizona, New Mexico and Utah and within which the Mill site is
located had a priority IA rating, signifying a violation of federal air standards. The rating was
for particulate matter and sulfur dioxide due to emissions from fossil-fueled power plants located
within the region (1978 ER, Sect. 2.7 .4.2). This was an important consideration at the time since
the original proposal was to use coal and oil as the source of process and building heat at the
Mill. Thus, much of the discussion of potential air quality effects of the Mill arose from
consideration of the potential effects of wind-blown dust from coal storage stockpiles and from
air emissions of sulfur dioxides, particulate matter, carbon monoxide, and nitrogen oxides arising
from the combustion of coal at the Mill. However these concerns are moot since the last time
coal was used to fire boilers at the Mill was 1990. By the time the Mill commenced the
199411995 mill run, propane was chosen to fire all process and heating boilers, and this remains
the fuel of choice as the operation continues.
The FES, based on data collected for one year prior to construction of the Mill at four sampling
locations, reported various background air quality data for the project site and compared them to
then existing criteria. The FES reported dustfall to average 33 gtm2 per month with the highest
monthly average of 102 g/m2 occurring in August. The FES also ieported a geometric mean
total suspended particulate (TSP) level of 18 pg/m3, based on monitoring from October 1977
through February 1978 (See FES Section2.2). This value is well below the Federal and State air
quality standard.
3.3.2.2 Effects on Air Oualiry Projected for Mill Operations
The FES (Section 4.L.2) concluded that, while air quality during operation of the Mill could be
affected by atmospheric releases (principally from the building and processing boilers,
yellowcake and vanadium dryers, tailings disposal system, and ore stockpiles), the operation of
the Mill facility should not have any significant impact on air quality. See Section 3.3.2.3
below.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2A07
t7
IUldtG f..rm[
Blrldng, Ltfi Whtl Spod
Dl,tc0on (bbilngf .ur)
INORIH ---
t
III
I t--
M,
tlltllttt-----,--fF---iW6Tl ii
atl(Ittlttlt
i"Dr I rrlrllllrt- -- -L -- -- - -- & -. - - - - - - /- - - - - -- r {- -- - - - - - -.1ttl: : I i EAsri
-r-.--_t_-----
I
I
IIII
"------l------'II
IIIlsounl
"-.-,:-l--.---'
WiDSPEED
0du)
f >=rr.l
! e.c-lt.r
! c.z- c.e
! c-0. c.r
[-_l z.r- sr
! os- zr
ffil3:0r!ia
ilTIPBDI
axl6Jil I -D.cAt
0G00 - 8:00
oomaf,Yilft
Dcdrn Hncc
,ffi,n!
ilcfrCrll.t{omct
Arroddcr FIGURE 3.3-1Ctl,TUNDE
028*
MI-@Ufr;
0ttE htr.
AtG.ElDS@r
3.5Ents
ROtrtlo;
20tE{rB
mPlotVh- [a-EthmaI kr
3. 3.2. 3 Operat ional Environmental Air M onitoine D ata ( non - rad iol o pic al I
This Section discusses only the non-radiological air monitoring programs, whereas the
radiological air monitoring programs are discussed in Section 3.13.1.7. In this regard, the non-
radiological air emissions from the Mill are regulated by the State of Utah in accordance with theMill's Air Quality Permit (Approval Order No. DAQE-AN1205005-06). Amongst other
features, the Air Quality Permit sets out annual emissions limits for the yellowcake dryers and
the vanadium circuit scrubber. The Air Quality Permit also describes emissions controls for
sources in the Mill and general procedures for controlling dust from roads and fugitive sources.
Also, the Permit specifies that the Mill must comply with various Federal requirements including
those of 40 CFR Part 61 concerning emissions of radon from the Mill tailings.
Specifically, the Air Quality Permit requires that particulate (PM-10) emissions to the
atmosphere shall not exceed 0.40 lbs per hour for each yellowcake dryer and 2.50 lbs per hour
for the vanadium circuit scrubber. The Air Quality Permit requires that initial compliance testing
of the scrubber and dryers must be performed within 180 days of the start up of a new emission
point or the inclusion of an emission point in the Permit, and thereafter, if and when directed by
the Utah Department of Environmental Quality (UDEO. The yellowcake dryers were initially
tested under the Air Quality Permit when the second yellowcake dryer was installed in
connection with the 199511996 mill run and again in June, 2006 in cormection with restart of
yellowcake drying operations. The yellowcake dryers were not operated for sufficient duration
during the intervening years to prompt testing. The June, 2006 testing showed that the
yellowcake dryer was operating within this compliance limit.
With regard to the vanadium circuit scrubber, the 199511996 mill run, as well as the subsequent
altemate feed processing campaigns, did not involve vanadium production, and the vanadium
circuit was not operated. For the 1999 Mill run, while some vanadium was produced, product
finishing (where the vanadium scrubber is employed) was not of a sufficient duration to prompt
the compliance testing program. However, vanadium production is anticipated early in this
licensing cycle, and vanadium circuit scrubber emissions will be tested at that time.
In order to ensure compliance with applicable air quality standards and the requirements of the
Air Quality Permit, the Permit recognizes the specifications of emission generating equipment
and emission control equipment at the Mill, and places restrictions on the use of such equipment
as an emission control mechanism. For example, the Permit provides that no more than 720,720
tons of ore may be processed in any 12 month period and that the total amount of propane gas
consumption for the boiler facilities shall not exceed 2,960,880 gallons per 12 month period, in
each case without the prior approval of UDEQ. In this way, the Permit ensures compliance with
applicable standards by:
. Recognizing the nature of the Mill's operations and emission control systems
. Controlling the throughput rate and propane consumption to maintain compliance with
the emission standards, and
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2OO7
t9
. Placing other restrictions on air emission-generating activities at the Mill in a manner that
is calculated in the Permit, ensuring compliance with applicable air quality standards.
In addition to the operational controls established by the Air Quality Permit, the Mill is required
to submit to UDEQ an Armual Air Emission Inventory. Table 3.3-l sets out the Annual Air
Emission Inventory for the key criteria emissions for the last eight years. The key criteria
emissions are: PM-10 (particulate measuring 10 microns or less); sulfur oxides (SOX); nitrogen
oxides (NOX); volatile organic compounds (VOC); and carbon monoxide (CO).
Table 3.3-1
Air Emission Inventory for Key Criteria Emissions (tons/yr)
Year PM.lO sox NOX voc CO
1991 o.775 0.25s 3.8s9 2.120 7.257
1998',
I 999 2.51 l.l5 l8.l I 2.16 t4.t4
2000 1.9 1.47 14.61 2.76 I 1.78
2001'
2002 0.68 0.98 9.04 l.80 n.49
2003'
2004'
2005 0.18 0.20 2.11 0.31 3.69
2006
INot required to file an Air Emission lnventory for the year because it was determined thal the Mill <tid not realize a change of 57o or more in
emissions for any criteria pollutant reported in the previous year.
In addition, and as part of the Mill's License-driven environmental air monitoring program for
radionuclides (See Section 3.I3.1.7), non-radiological total particulate matter is collected and
measured at the facility's environmental air monitoring stations. The environmental air
monitoring program utilizes four high volume continuous air sampling stations, which have been
placed at the locations indicated in Figure 3.3-2 (Stations BHV-I, BHV-2, BHV-4, BHV-5). In
addition, in 1999 a fifth sampler (BHV-6) was located south of the facility and between the Mill
and the White Mesa Ute community. The filters collected from these samplers are weighed for
total particulate loading and analyzed for principal radionuclide parameters. The data derived
from this monitoring effort are reported in the Semi-Annual Effluent Monitoring Reports that are
filed with the Executive Secretary, examples of which are provided with the Application. A
more detailed discussion of the environmental air monitoring regimen and airborne radionuclide
particulate measurement program is provided at Section 3.13.1.7 .I below.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February ZB,2O0j
20
Z:\wt!trlciil\[e-mail]\Eftrulttltrf Rlgott'F Evt.ln3}2ni!FtE:I!'-1@/2{f'07{:l7:29Fl'
ldd.ff.C.9Utl,
Il-- i-- --*i' *t!)!ai ?, l=
lr. 'd Itri\i-+t- irJ--i,-i'f 'r,i
4-'L^ ti
ir,.r::,,I ?,
--$i+
{-{._._ \
A '-"! r
IIt
1
lo
: BHV-2
lir--J
i' rt i: j
1i)l1 ._i\_.t-.
-Jai, .tDlt\ti .f*,Li ,rt ,,''i!',li-i--Iit--J-l -+-L.t, ii,tti ir \'f:1
i I i,.-o-':;:'.lttrr- t,,.
"A"--,4
\" .-/' j11 I
'- i/\ a
) " \,,\
.'1__
t-
I
\
to\E
-e_'.2,t "E
"* ---\
1
irrarrr.itrrr?
Ithl.i'ri!ltr
-\'-- -_
.,-=-l,-,=---
I\la.'/' I I\ :-
t I
I
.-a--.a,l
O2J
ii
tlltIt-t)taI
t1\
7t'*-
-
Property Boundary o Air Monitor
Stations
-
Reservation Boundary
rrrrrrr Canyon Rim
Denison Mines (USA) Corp.
Figure 3.&2
High Volume
Air Monitoring Stations
During the 1999 natural uranium ore mill run, from April through October, 1999 (including the
period of highest winds), the average total particulate suspended matter collected from all
environmental sample locations was 20 pg/m3.This value appears to be within the measurement
error of the local background concentration of (18 pg/m3) reported in the original FES
Evaluation. The maximum value from any location for seven consecutive days was 401tglm3.
With regard to temporal maximum site information, during a period of April-October, 2001,
when San Juan County was also experiencing a local drought and including the annual windy
period, Denison's site-wide average total suspended particulate measurement was only 2611g/m3.
More importantly, the maximum individual measurement was 44 lt1lm3, well below the
regulatory limitation and principally due to general dusting, absent any influence by the Mill. In
addition, because this climatic environment would represent the local "worst case" for dusting, it
would be highly unlikely that the Mill's influence would ever exceed the total suspended
particulate standard.
By means of these comparisons, it can be concluded that total suspended particulate
measurements during Mill operations have been observed to be similar to those experienced
under natural local conditions and that particulate impact from the Mill is low.
3.4 Geology
3.4.1 Regional Geoloev
The Mill site lies within a region designated as the Canyon Lands section of the Colorado
Plateau physiographic province (Figure 3.4-l). Elevations in the region range from
approximately 3,000 feet in the bottom of canyons to over 11,000 feet among the peaks of the
Henry, Abajo and La Sal Mountains. The average elevation for the area, excluding deeper
canyons and isolated mountain peaks, is about 5,000 feet.
The sedimentary rocks exposed in southeastern Utah have a total thickness of approximately
6,000 to 7,000 feet. These sedimentary units range in age from Pennsylvanian to Late
Cretaceous; older rock units which underlie those of Pennsylvanian age are not exposed in the
Mill site area.
Structural features in the Mill site area have been divided into three main categories on the basis
of origin or mechanism of the stress that created the structure. These categories are: (1) structures
related to large-scale regional uplifting or downwarping directly related to movements in the
basement complex (the Monument Uplift and the Blanding Basin); (2) structures due to diapiric
deformation of thick sequences of evaporate deposits, salt plugs and salt anticlines (the Paradox
Fold and Fault Belt); and (3) structures formed due to magmatic intrusions (the Abajo
Mountains).
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February ZB,2001.
22
I
'l \'T#j;..@,,=
ilK#
-
Ff
#w'#
ry\._. _w,*
ftt', \l ;" M-x**Lol iorn
'wj ffi
-.^;.;rnao'c -?l -y,^ ='W
_\t{'[:,j
,_r.*Ei
il
/t -,.I RED\trE
-_l o)F'
S"P*
I.EGEND
-Tf-+
--F-
BOUNDARY OF TECTONIC DIVISION
MONOCLINE SHOWNG TRACE OF N(IS
AND DIRECTION OF DIP
ANTICLINE SHOWING TMCE OF N(IS
AND DIRECTION OF PLUNGE
SYNCLINE SHOWING TRACE OFN(IS
AND OIRECTION OF PLUNGE
PmJeCt wHlTE MESA MILL
Figure 3.4-1
Colorad Plateau Geologic Map
Ig
+I
ta
jt
c
F
gt
EnI
E!
E
E
EI
ExEeEi
E5
Eg:".
IB
iE?0it
A generalized stratigraphic column for the region is provided as Figure 3.4-2. The Summerville
Formation, Entrada Sandstone, and Navajo Sandstone are the deepest units of concem
encountered at the site.
3.4.2 Local Geology
The Mill site is located on the western edge of the Blanding Basin, sometimes referred to as the
Great Sage Plain, lying east of the north/south-trending Monument Uplift, south of the Abajo
Mountains and adjacent to the northwest-trending Paradox Fold and Fault Belt. The Abajo
Mountains are the most prominent topographic feature in the region, rising over 4,000 ft above
the surface of the plain. The lithology of the immediate area is composed of thousands of feet of
multi-colored pre-Tertiary age marine and non-marine sedimentary rocks. Erosion on the
regionally-uplifted sedimentary strata has produced an affay of eroded canyons and mesas.
The Mill is more specifically located on White Mesa and rests on alluvial windblown silt and
sand which covers sandstones and shales of Jurassic and Cretaceous age. The surface of the mesa
is nearly flat, with a surface relief of 98 ft. The maximum relief between White Mesa and the
adjacent Cottonwood Canyon is about 750 ft.
3.4.3 Seismicity
The historical record of seismicity for the region is about 150 years old. Between 1853 and
1986, approximately 1,200 seismic events were recorded within 200 miles of the Mill site. The
nearest of these events occurred in the Glen Canyon Recreation Area, 63 miles away, and at a
location approximately 53 miles to the northeast of the site. An intensity V (Modified Mercalli
Scale) event occurred on August29,I94l,just east of Durango, Colorado, 99 miles away. In the
FES (Section 2.7.3) NRC staff concluded that, based on the region's seismic history, the
probability of a major damaging earthquake occurring at or near the site is remote.
3.4.4 Mineral Resources
There are no known mineral resources of any significance at the Mill site. However, there has
been some exploration for oil and gas in the nearby vicinity.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
24
-T-
I
II srnr-E. GRAv, GRAv-cREEN, At{o puRplE,I SILTY IN PART WTH SOME SANDS-ToNE
I unses
_tz.tol
EI>tr.lI I sANDsroNE. ARxosrc. yELLow ro cREENTsH* I GRAY, RNE To coARsE GRANED, INTERBEDDEO
6l !ffircneensx-GMY ro REDDTSH-BRoWN
al
M.l
X I sHAr.E. REDDT'H-.RA' srLTy ro sANDy
= I rmn6eooeo wrTH sAt{osToNE. ARKostc,- I REDDISH-GRAY. TO YEI.I-OW-BROWN, FINE-
_l _ro MEoruM-cRANEo
I
II smosroNE. euARrz. YELLowsH-roI neoosx BRourlr. FrNE-To coARSE-I GRAINED INIERBEDDED wm| REDDISH-I cmv srrurI
AIIUVIUM.
COLLWUM AND TALUS
-.:.. ^..= -AND Ar{D S|LT, REDDTSH BROWN \ERYEOLIAN SAND RNE-GRAINEO
= - = = = = {NCOS_SEAIB -:=I{ALE, LrGHr cR y, soFT
DAKOTA SANDSTONE
SANDSTONE. QUARTZ. UGHT YTLLOV{ BROTYN,
POORLY SORITEO, IRON CONCREAIIONS.
Y{ELL INDURAIEO
BURRO CANYON FORMATION
SANDSTONE, QUARIZ. LIGHT GRAY TO UGHT
BROWN. CROSS-BEDDED. CONGLOMERAIIC.
POORLY SORTED INIERBEDDED W[}I
GRAY-GREEN SHATE
BRUSHY BASIN MEMBER
WESTWATER CANYON MEMBER
RECAPTURE MEMBER
SALT WASH MEMBER
SUMMERVILLE FORMATION
SAI{DSTONE, RED-BROV'N, THIN-8EDDED, WMI
RIPPIT MARKS. ARGILITCEOUS WTH S}IAI.E
INTERBEDS
SqNDSTONE, QUARTZ WH]IE TO GRAYISH
BROIYN. MASSTVE. CROSS-BEODED, FINE-rO MEDIUM-GMINEDENTRADA SANDSTONE
NAVAJO SANDSTONE
SANDSTONE, QUARTZ, UGHT YEUOUSH-
BROIVN TO UGHT-GRAY AND WHIIE, ilASSTVE,
CROSS-BEDDED, FRIAELE. FINE- TO
MEDIUM-GRAINED
Scction neor lYoter Wcllfokcn from
\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\
trttttltt,JlI,tttttlrtttrtt
aa
t-'.JzYO
IF
LdF
xoE
o_
o_
Denison Mines (USA) Corp.
Figure 3.4-2
Generalized Stratigraphy of
White Mesa Mill
c
ri
+
a
N
^t+
F
Er.lt
i,I
F
EcI
E
e5I
E
tl
Ei
I
=trHl<a
=-i$B
!n
=$
3.5 Soils
The majority (99Vo) of the soil at the Mill site consists of the Blanding soil series (1978 ER, Sect.
2.10.1.1). The remaining l%o of the site is in the Mellenthin soil series. Because the Mellenthin
soil occurs only on the eastern-central edge of the site (1978 ER, Plate 2.10-l), the FES (Section
2.8) concluded that it should not be affected by Mill construction and operation.
The Mill and associated tailings cells are located on Blanding silt loam, a deep soil formed from
wind-blown deposits of fine sands and silts. Although soil textures are predominantly silt loam,
silty-clay-loam textures are found at some point in most profiles (Table 3.5-1). This soil
generally has a 4 to 5 inches reddish-brown, silt-loam A horizon and a reddish-brown, silt-loam
to silty-clay-loam B horizon. The B horizon extends downward about 12 to 16 inches where the
soil then becomes calcareous silt-loam or silty-clay-loam, signifying the C horizon. The C
horizon and the underlying parent material are also reddish-brown in color.
The A and B horizon both are non-calcareous with an average pH of about 8.0, whereas the C
horizon is calcareous with an average pH of about 8.5. Subsoil sodium levels range up to I2Vo in
some areas, which is close to the upper limit of acceptability for use in reclamation work (1978
ER, Sect. 2.10.1.D. Other elements, such as boron and selenium, are well below potentially
hazardous levels. Potassium and phosphorus values are high in this soil (1978 ER, Table 2.10-2)
and are generally adequate for plant growth. Nitrogen, however, is low (1978 ER, Sect. 2.10.1.1)
and may have to be provided for successful revegetation during final reclamation.
With well-drained soils, relatively flat topography (see Section 3.8), and limited annual
precipitation (see Section 3.3.1), the site generally has a low potential for water erosion.
However, the flows resulting from thunderstorm activity are nearly instantaneous and, without
the Mill's design controls, could result in substantial erosion. When these soils are barren, they
are considered to have a high potential for wind erosion. Although the soil is suitable for crops,
the low percentage of available moisture (6 to 97o) is a limiting factor for plant growth;
therefore, light inigation may be required to establish native vegetation during reclamation.
3.6 Bedrock
Subsurface conditions at the Mill site area were investigated as part of the 1978 ER by drilling,
sampling, and logging a total of 28 borings which ranged in depth from 6.5 to 132.4 ft. Of these
borings, 23 were augured to bedrock to enable soil sampling and estimation of the thickness of
the soil cover. The remaining 5 borings were drilled through bedrock to below the perched water
table, with continuous in situ permeability testing where possible and selective coring in
bedrock. The soils encountered in the borings were classified and a complete log for each boring
was maintained. See Appendix A of Appendix H of the 1978 ER.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
26
q)
0
ti2
f8,ri 9.eri ?otrE<Gl-FO(n
o
(r)
u)q)/
(8ng17barg)
JSC
(urdd)
trlnlssElod
(udd)
eluqdsoql
(ob)
uoqrEJ
r;ue8rg
(ob)
unsd,(g
I:I
(o/o)
uoBBrnlss lB rslEAl
(%)
arn$!ol^l
eqBllB v
reJnlxetr
'oN algord
(loqu,ts)
saFes llos
eb)
dss
(D uru)
ecg
(ob)
aut!.I
s3I
(u!)
qrdac
q$
aN
\o
\o€
\oN
.+
ql5l3
Nt€jld
ololocildl6i
qlq
rl6
tl\qrlr
qlqEIO6lS
Flll=
rldldql'61|U
YISol+
c.l@
n
€
o\
F-
\€
Or€
o\
@
rao
-q
qo
@
9
J(n
N
.lo\
o\
e{
F-dlo
6
qo\
q
\@
J
<,,
j
@
q
c.l
o
a
\o
(-.1o
096
gor
q
@
,.1Uta
(\
c..i
.1.
c,.i
C)
-ofitFil_rI1E
oo -9rr-O\=
-lltsJt?.NEoxo.:
ri<3..=oagrl3 -.1bUu)6
Borings in the footprint of the existing tailings cells reported calcareous, red-brown sands and
silts from the surface to a depth of 15 ft, averaging over 7 ft. Borings in the general area of the
Mill site and the tailings cells reported calcareous, red-brown sands and silts from the surface to
a depth of 14 ft, averaging over 9 ft. Downgradient of the tailings cells, calcareous sands and
silts extend to a depth of 17 ft of the surface. The calcareous silts and sands of the near-surface
soils grade to weathered claystones or weathered sandstones, inter-layered with weathered
claystone and iron staining. At depth, the weathered claystone or weathered clayey sandstone
grade into sandstone with inter-layered bands of claystone, gravel, and conglomerate. Some
conglomerates are cemented with calcareous matrix.
3.7 Water Resources
3.7.1 Surface Water
3.7. 1.1 Surface Water Characteristics
The Mill was designed and constructed to prevent runon or runoff of storm water by a) diverting
runoff from precipitation on the Mill site to the tailings cells; and b) diverting runoff from
surrounding areas away from the Mill site. In addition to these designed control features, the
facility has developed a "Stormwater Best Management Practices Control Plan" which includes a
description of the site drainage features and the best management practices employed to assure
appropriate control and routing of stormwater. A copy of the Mill's Stormwater Best
Management Practices Plan is included as Appendix C to the Application.
As discussed above, the Mill site is located on White Mesa, a gently sloping (17o SSW) plateau
that is physically defined by the adjacent drainages which have cut deeply into regional
sandstone formations. There is a small drainage area of approximately 62 acres (25 ha) above
the site that could yield surface runoff to the site. Runoff from the mesa is conveyed by the
general surface topography to either Westwater Creek, Corral Creek, or to the south into an
ururamed branch of Cottonwood Wash. Local porous soil conditions, topography and low
average annual rainfall of 13.4 inches cause these streams to be intermittently active, responding
to spring snowmelt and local rainstorms (particularly thunderstorms). Surface runoff from
approximately 624 acres of the Mill drains westward and is collected by Westwater Creek, and
runoff from another 384 acres drains east into Corral Creek. The remaining 4,500 acres of the
southern and southwestern portions of the site drain indirectly into Cottonwood Wash (1978 ER,
p.2-la3). The site and vicinity drainages carry water only on an intermittent basis. The major
drainages in the vicinity of the Mill are depicted in Figure 3.7-1 tabulated in Table 3.7-1. Total
runoff from the mesa (total yield per watershed area) is estimated to be less than 0.5 inch
annually (1978 ER, p. 2-143).
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
28
o
o
o
.1
.2
.3
USGS GAUGE NO. 09376900
USGS GAUGE NO.09378630
USGS GAUGE NO. O93787OO
International Uranium (USA) Corporation
Figure 3.7 - 1
Drainage Map of the Vicinity
of the White Mesa Mill
Table 3.7-1
Drainage Areas of Mill Vicinity and Region
Basin Description Drainase Area
so- miles km2
Corral Creek at confluence with Recapture Creek 5.8 15.0
Westwater Creek at confluence with Cottonwood Wash 26.6 68.8
Cottonwood Wash at USGS Gauge west of project site = 205 <53 I
Cottonwood Wash at confluence with San Juan River = 332 <860
Recapture Creek at USGS gauge 3.8 9.8
Recapture Creek at confluence with San Juan River =200 <518
San Juan River at USGS gauge downstream at Bluff, Utah = 23,000 <60,000
Source: Adapted from 1978 ER, Table 2.6-3
There are no perennial surface waters on or in the vicinity of the Mill site. This is due to the
gentle slope of the mesa on which the site is located, the low average annual rainfall of 13.4
inches per year at Blanding, local soil characteristics and the porous nature of local stream
channels. Prior to construction, three small ephemeral catch basins were present on the site to
the northwest and northeast of the Mill site.
Corral Creek is an intermittent tributary to Recapture Creek. The drainage area of that portion of
Corral Creek above and including drainage from the eastern portion of the site is about 5 square
miles. Westwater Creek is also an intermittent tributary of Cottonwood Wash. The Westwater
Creek drainage basin covers nearly 27 square miles at its confluence with Cottonwood Wash 1.5
miles west of the Mill site. Both Recapture Creek and Cottonwood Wash are similarly
intermittently active, although they carry water more often and for longer periods of time due to
their larger watershed areas. They both drain to the south and are tributaries of the San Juan
River. The confluences of Recapture Creek and Cottonwood Wash with the San Juan River are
approximately 18 miles south of the Mill site. The San Juan River, a major tributary for the
upper Colorado River, has a drainage of 23,000 square miles measured at the USGS gauge to the
wesr of Blufl utah (1978 ER, p. 2-130).
Storm runoff in these streams is characterized by a rapid rise in flow rates, followed by rapid
recession primarily due to the small storage capacity of the surface soils in the area. For
example, on August 1, 1968, a flow of 20,500 cubic feet per second was recorded in Cottonwood
Wash near Blanding. The average flow for that day, however, was only 4,340 cfs. By August 4,
the flow had retumed to 16 cfs (1978 ER, p. 2-135). Monthly streamflow summaries as updated
from Figure 2.4 of the FES are presented in Figure 3.7-2 for Cottonwood Wash, Recapture Creek
and Spring Creek. Flow data are not available for the two smaller water courses closest to the
Mill site, Conal Creek and Westwater Creek, because these streams carry water infrequently and
only in response to local heavy rainfall and snowmelt, which occurs primarily in the months of
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February Zg,2OO7
30
April, August, and October. Flow typically ceases in Corral Creek and Westwater Creek within
6 to 48 hours after precipitation or snowmelt ends.
3.7. I .2 Surface Water Backeround Oualitv as of the Date of the FES
Sampling of surface water quality in the Mill vicinity began in July 1977 and continued through
March 1978. Baseline data describe and evaluate existing conditions at the Mill site and vicinity
at that time. Sampling of the temporary on-site surface waters (two catch basins) was attempted
at that time but without success because of the lack of naturally occurring water in these basins.
Sampling of ephemeral surface waters in the vicinity was possible only during major
precipitation events, as these streams are normally dry at other times. See FES Section 2.6-I.2.
The locations of the surface water sample sites used prior to Mill operations are presented in
Figure 3.7-3.
As noted in the FES, natural surface water quality in the vicinity of the Mill is generally poor, as
shown by the data in Table 2.22 of the FES and Table 3.7-2. Waters in Westwater Creek (SlR
and 59) were characterized at the time of the FES by high total dissolved solids (TDS) (mean of
674 mglliter) and sulfate levels (mean of 117 mg of SO4 per liter). The waters were typically
hard (total hardness measured as CaCO3; mean 223 mg/liter) and had an average pH of 8.25.
Estimated water velocities for Westwater Creek averaged 0.3 fps at the time of sampling.
Samples from Cottonwood Wash (S8R) at the time of the FES were generally similar in quality
to Westwater Creek water samples, although the TDS and sulfate levels were lower (TDS
averaged 264 mglliter; SOa averaged 40 mg/liter) during heavy spring flow conditions (80 fps
water velocity). During heavy runoff, the concentration of total suspended solids in these
streams increased sharply to values in excess of 1,500 mg/liter (Table 3.7-2). High
concentrations of certain trace elements were measured in some sampling areas. Levels of
mercury (total) were reported as high as 0.002 mg/liter (S3R, 7125/77: SBF'7l25l77). Total iron
measured in the pond (S5R, Illl0l77) was 9.4 mg/liter. The FES concluded (Section 2.6.1.2 of
the FES) that these values appear to reflect groundwater quality in the vicinity and are probably
due to evaporative concentration and not due to human perturbation of the environment. Corral
Creek was also sampled at the time of the FES, but it has not been included in subsequent
operational monitoring at the Mill. See Table 2.22 of the FES for sampling results for Corral
Creek.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
3l
Denison Mines (USA) Corp.
Pmject wHrE MESA MILL
Figure 3.7-2
Streamflow Summary
Blanding, UT Vicinity
E.
,ii9
-
CI
PId€.i*
3
B
e
iI
3
e
.e
.EE'a-3
Qu
OE
EE
=oB€ftx
z;\wtriE it6 llluo7 usE Rffil Appllc.dor\ENkilmnt l RGPort - thuln brc 3.7.3nti,9, HsE 3.7-3, Qn6lut, gfii',
't4.ldob.PoFfi3,Url,
, - l-J./f
i I .7'-o II r zl
II r ta
,rl([".It ,
I
I
I
Ir
I
Ir
{,!
T
aIt ,$
i!:r
aa\f
It
i
at
:
l..
iH\ " i,,-\\-f' I--,T:i', A I
ll /'lro* o zoool
--,'-ll I scArE lN FEETF-- ''-
|nlit,tr ,
1;i:tdlf,1:*l'ir I rs '/ j++ l-s,l'i\ .'4 I I
t{L*i {
_r'{: \\ t"i.I., \
)" {.1"1.
-\,\r\ .\.,
\\
I
t_
Il,$
loo ' :lt, );r :l-
IY?'i-'=- tIt.
i'c, i 1ii iti.{ "'daat_
Ir
I
/
Tr--t'1
t-.'at,' )al, .,. I.lr)1,!--tta
/l
4Rll
ll..
rl\
\. '\
*l -')- - T
"1 fr5
,= -',!t'
,tt'"'7"'tr rt-a ' t-. I ' -r /rJ,. , t -r,_i_r.- f- -lot ,. ,
j, ri-j i I\ fi)+!'
. to- - cr"6__-4
\ , -*#,/ ^J -
\..
Arrl
r(I'iI ssR
;cE-
Ii..f''
Itri
E l,'
,*li "\"I'f
I
I,t t'l
l.'It-*t,\.'4
T l'.r* .Zt
-
r{-t-{.ir o*tr\,.r.\ |
| | -''i
1-i, l
I
\ta
\
Lr
a
\rtl
ta
i
\t)_a
,/"'
I
:;iJi
-l
aIIaa
I
r-,Y)=',oy-tArI
-
PROPERTYBOUNDARY
-
RESERVATIONBOUNDARY
r!IIITI CANYONRIM
SI SURFACEWATERSAMPLINGLOCATION
Denison Mines (USA) Corp.
Figure 3.7-3
Surface Water Quality Sampling
Stations Prior to Mill Operations
3.7.1.3 Surface Water Backsround Oualitv
Surface water samples are collected for Cottonwood Wash and Westwater Creek as part of the
Mill's operational monitoring program. Samples were also taken prior to Mill construction and
summarized in the FES as well as at various times and for various parameters since then. A
comparison of the FES results and subsequent sampling results during Mill operation is set out in
Table 3.1-2. Surface water values over time for both Cottonwood Wash and Westwater Creek
are included in the Semi-Annual Effluent Reports.
Table3.7-2
Summary of FES and Subsequent Sampling Results For
Cottonwood Wash and Westwater Creek
Parameter
:
Cottonwood Wash
On6t$aoo6\
FES .:.
WeslwaterQrebkl
lutun7arz3nEt'
Field Specific Conductivity (umhoVcm)240-550 32U620
Field pH 6.6 to 8.1 7.6-8.3
Dissolved Oxvsen
Temoerature ("C)6.0 to 35 3-14
Estimated Flow m/hr 0.4 to 80 0.28 to 39.9
pH 7.5 to 8.21 8.2 to 8.35
TDS (@r80"C)253 ro944 l0 to 803 496 ro 969 93-9W
Redox Potential 210 to 260 186 to220
Alkalinity (as CaCOS.)134 to 195 76 ro 257 147 ro 229 230
Hardness, total (as CaCO.)148 to 195 l17 to289
Carbonate (as CO,)0.0 0.0 to 2.3
Aluminum, dissolved 0- l6 to 3.0 0.1 to 4.0
Ammonia (as N)<0.1 to 0.16 <0.1 to 0.75
Arsenic, total 0.02 to 0.041 0.007 to 0.037
Barium, total 0.2 to 1.2 <0.2 to 0.81
Boron, total <0.1 to 0.2 <0. I to 0.1
Cadmium, total <0.002 to 0-01 <0.002 to 0.006
Calcium, dissolved 54 to 178 76 to 172
Calcium 37 to7l 94.5
Chlorine
Chloride 6to24 5 to 33.3 17 to 125 76
Sodium l8 to t04 160.5
Sodium. dissolved 2l to 66 3l to 60
Silver, dissolved 0.002 to <0.005 <0.005 to 0.006
Sulfate. dissolved (as SO,)39.7 to 564 57 to 245 85 to 163 408
Vanadium. dissolved <0.005 to <0.01 <0.001 to 0.008
Maqenese. dissolved 0.02 to 0.84 0.03 to 0.60
Chromium. total <0.01 to 0.14 <0.01 to 0.60
Coooer. total 0.005 to 0.09 <0.005 to 0.05
Fluoride. dissolved 0.2 to 0.36 0.2 to 0.4
Iron. total 5.9 ro 150 0.28 to 44
Iron. dissolved 0.1 I to I.9 0.17 to2.5
lrad, total 0.05 to 0.14 <0.05 to 0.1
Masnesium 10.5 to 38.1 23.5
Magnesium, dissolved 17 to28 13 to26
Mercury, total 0.00006 to 0.002 <0-00ffi3 to
<0.0005
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2C[J|.
34
Parameter
FES
Cottonwood Wash(7t2\n7-ADAn*\Cottonwood Wash
oltfitSt-2006\
FES
Westwater Creek
lufin7-3D3n8r
Westwater Creek
(u22182-2M)
Molvbdenum. dissolved 0.002 to 0. l0 0.002 to 0.006
Nitrate (as N)0.l2to 1.77 <0.05 to 0.05 0.05
Phosohorus. total (as P)0.05 ro 3.2 0.05 to 0.88
Potassium 1.77 to 4
Potassium. dissolved 1.2 ro 6.9 2.0 to 3.2 4.05
Selenium. dissolved <0.005 to 0.08 <0.005 to 0.003
Silica, dissolved (as SiO,)8tol8 Ttoll
Strontium, total 0.34 to 0.64 0.44 to 0.76
Uranium, total 0.004 to 0.27 0.006 to 0.0O1
Dissolved Uranium 0.004 to 0.015 0.002 to 0.015
Zinc, dissolved 0.008 to 0.06 0.M to 0.12
Total Orsanic Carbon 1to12 6to16
Chemical Oxvsen Demand 6t to t63 23 ro 66
Oil and Grease 2 I
Total Susoended Solids 146to2,025 0 to 16.400 12 to 1940 <4 ro I,190
Total Dissolve Solids 215 to 679 274
Deieiihination (uCilml)
Gross Aloha <1.0E-9 to l.0E-9 lE-10 to 4.5E-9 <1.0E-9
Gross Beta 0 to 8E-9
Dissolved Uranium'1.02E-9 to2.79E-9 2.238-9 to 6.84E-6 1.038-9 to 1.35E-9 8.8E-7
Uranium, total'21.838-7 to2.79E-9 2.798-9 to 4.068-9
Susnended Uranium <2.08-10 to 6.09E-10 6.WE-7 6.WE-7
Th-230, dissolved <2.0E-10 to 4.148-6 0 to lE-9 <2.0E-10
Th-230, suspended <2.0E-l0to <2.0E-7 3.0E-r0
Ra-226 2E-tO
Ra-226, disolved <2.0E-10 ro2.0E-9 2.0E-10
Ra-226, suspended <2.0E-10 to <2.0E-7 <2.0E-10
Pb-210 7E-10 to LIE-9
Po-210 0 to lE-10
Source: FES Table 2.22 and Mill Sample Data
5 Calculated by Denison for activity comparison using the Specific Activity for U-nat (6.77E-7 Ci U-nat/g U-nat)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
35
3.7.2 GroundwaterCharacteristics
This Section is excerpted from the Report entitled: Sile Hydrogeology and Estimation of
Groundwater Travel Times In Perched Zone White Mesa (Jranium Mill Site Near Blanding,
utah,February,2007, prepared by Hydro Geo chem, Inc. ("HGC"), a copy of which is attached
to this ER as Appendix A.
3.7.2.1 Geoloeic Settine
The Mill is located within the Blanding Basin of the Colorado Plateau physiographic province.
Typical of large portions of the Colorado Plateau province, the rocks underlying the site are
relatively underformed. The average elevation of the site is approximately 5,600 ft (1,707 m)
above mean sea level (amsl).
The site is underlain by unconsolidated alluvium and indurated sedimentary rocks consisting
primarily of sandstone and shale. The indurated rocks are relatively flat lying with dips
generally less than 3". The alluvial materials consist mostly of aeolian silts and fine-grained
aeolian sands with a thickness varying from a few feet to as much as 25 to 30 ft (7.6 to 9.1 m)
across the site. The alluvium is underlain by the Dakota Sandstone and Burro Canyon
Formation, which are sandstones having a total thickness ranging from approximately 100 to 140
ft (31 to 43 m)- Beneath the Burro Canyon Formation lies the Morrison Formation, consisting,in descending order, of the Brushy Basin Member, the Westwater Canyon Member, the
Recapture Member, and the Salt Wash Member. The Brushy Basin and Recapture Members of
the Morrison Formation, classified as shales, are very fine-grained and have a very low
permeability. The Westwater Canyon and Salt Wash Members also have a low average vertical
permeability due to the presence of interbedded shales. See Figure 3.4-2 for a generalized
stratigraphic column for the region.
Beneath the Morrison Formation lies the Summerville Formation, an argillaceous sandstone with
interbedded shales, and the Entrada Sandstone. Beneath the Entrada lies the Navajo Sandstone.
The Navajo and Entrada Sandstones constitute the primary aquifer in the area of the site. The
Entrada and Navajo Sandstones are separated from the Burro Canyon Formation by
approximately 1,000 to 1,100 ft (305 to 335 m) of materials having a low average vertical
permeability. Groundwater within this system is under artesian pressure in the vicinity of the
site, and is used only as a secondary source of water at the site.
3.7.2.2 Hvdroqeolosic Settins
The site is located within a region that has a dry to arid continental climate, with average annual
precipitation of approximately 13.4 in. Recharge to aquifers occurs primarily along the mountain
fronts (for example, the Henry, Abajo, and La Sal Mountains), and along the flanks of folds such
as Comb Ridge Monocline.
Although the water quality and productivity of the Navajo/Entrada aquifer are generally good,
the depth of the aquifer (approximately 1,200 ft below land surface (bls)) makes access difficult.
International Uranium (USA) Corporation, Environmental Report, June 20, 2003
36
The Navajo/Entrada aquifer is capable of yielding significant quantities of water to wells
(hundreds of gallons per minute (gpm)). Water in wells completed across these units at the site
rises approximately 800 ft above the base of the overlying Summerville Formation.
3.7.2.3 Perched Zone Hvdropeolosy
Perched groundwater beneath the site occurs primarily within the Burro Canyon Formation.
Perched groundwater at the site has a generally low quality due to high total dissolved solids
(TDS) in the range of 1,200 to 5,000 milligrams per liter (mg/L), and is used primarily for stock
watering and irrigation in the areas upgradient (north) of the site, The saturated thickness of the
perched water zone generally increases to the north of the site, increasing the yield of the
perched zone to wells installed north of the site. Perched water is supported within the Burro
Canyon Formation by the underlying, fine-grained Brushy Basin Member. Figure 3.7-4 is a
contour map showing the approximate elevation of the contact of the Burro Canyon Formation
with the Brushy Basin Member, which essentially forms the base of the perched water zone at
the site. Contact elevations are based on monitoring well drilling and geophysical logs and
surveyed land surface elevations. As indicated, the contact generally dips to the south,/southwest
beneath the site.
The permeability of the Dakota Sandstone and Burro Canyon Formation at the site is generally
low. No significant joints or fractures within the Dakota Sandstone or Burro Canyon Formation
have been documented in any wells or borings installed across the site (t<night Pi6sold, 1998).
Any fractures observed in cores collected from site borings are typically cemented, showing no
open space.
Based on samples collected during installation of wells MW-16 and MW-17 (the locations of the
various monitoring wells are indicated on Figure 3.1-4),located immediately downgradient of
the tailings cells at the site, porosities of the Dakota Sandstone range from l3.4%o to 26Vo,
averaging \OVo, and water saturations range from3.7Vo to 27.2Vo, averaging I3.5Vo. The average
volumetric water content is approximalely 3Vo. The permeability of the Dakota Sandstone based
on packer tests in borings installed at the site ranges fuom2.7lE-06centimeters per second
(cm/s) to 9.12E-04 cm/s, with a geometric average of 3.89E-05 cm/s.
The average porosity of the Burro Canyon Formation is similar to that of the Dakota Sandstone.
Based on samples collected from the Burro Canyon Formation at MW-16, located immediately
downgradient of the tailings cells at the site, porosity ranges fuom ZVo to 29.l%o, averaging
18.37o, and water saturations of unsaturated materials range from O.6Vo to 77.2Vo, averaging
23.4Vo. Titan, 1994, reported that the hydraulic conductivity of the Burro Canyon Formation
ranges from 1.9E-07 to l.6E-03 cm/s, with a geometric mean of 1.1E-05 cm/s, based on the
results of 12 pump/recovery tests performed in monitoring wells and 30 packer tests performed
in borings prior to that time.
Denison Mines (USA) corp., white Mesa Mill, Environmental Report, February zg,z\oj
37
Insert 3.7-4
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
Hydraulic testing of wells MW-l, MW-3, MW-5, MW-17, MW-18, MW-19, MW-20, and MW-
22 during the week of July 8,2002, yielded average perched zone perneabilities ranging from
approximately 4.0E-07 cm/s to 5.0E-04 cm/s, similar to the range reported by previous
investigators at the site (HGC, 2002). Downgradient (south to southwest) of the tailings cells,
average perched zone permeabilities based on tests at MW-3, MW-5, MW-17, MW-20, and
MW-22 ranged from approximately 4.08-07 to 4.0E-05 cm/s. Permeability estimates were based
on pump/recovery and slug tests analyzed using several different methodologies.
A number of temporary monitoring wells have been installed at the site to investigate elevated
concentrations of chloroform initially discovered at well MW-4 in 1999. Some of the
conglomeratic zones encountered within the perched zone during installation of these wells are
believed to be partly continuous or at least associated with a relatively continuous zone of higher
permeability (IUSA and HGC, 2001). The higher permeability zone defined by these wells is
generally located east to northeast of the tailings cells at the site, and is hydraulically cross-
gradient to upgradient of the tailings cells with respect to perched groundwater flow. Relatively
high permeabilities measured at MW-l l, located on the southeastem margin of the downgradient
edge of tailings Cell 3, and at MW-14, located on the downgradient edge of tailings Cell 4, of
1.4E-03 cm/s and 7.5E-04 cm/s, respectively (UMETCO,1993), may indicate that this zone
extends beneath the southeastem margin of the cells. This zone of higher permeability within the
perched water zone does not appear to exist downgradient (south-southwest) of the tailings cells,
however. At depths beneath the perched watff table, the zone is not evident in lithologic logs of
the southemmost temporary wells TW4-4 and TW4-6 (located east (cross-gradient) of Cell 3),
nor is it evident in wells MW-3, MW-5, MW-12, MW-15, MW-16, MW-17, MW-20, MW-21,
or MW-22, located south to southwest (downgradient) of the tailings cells, based on the
lithologic logs or hydraulic testing of the wells.
Because of the generally low permeability of the perched zone beneath the site, well yields are
typically low (less than 0.5 gpm), although yields of about 2 gpm may be possible in wells
intercepting the higher permeability zones on the east side of the site. Sufficient productivity
can, in general, only be obtained in areas where the saturated thickness is greater, which is the
primary reason that the perched zone has been used on a limited basis as a water supply to the
north (upgradient) of the site.
3.7.2.4 Perched Groundwater Flow
Perched groundwater flow at the site is generally to the south/southwest. Figure 3.7-5 displays
the local perched groundwater elevation contours at the Mill. As indicated, the perched
groundwater gradient changes from generally southwesterly in the western portion of the site to
generally southerly in the eastem portion of the site.
Denison Mines (USA) Cory., White Mesa Mill, Environmental Report, February 28,2OO7
39
_tZr \Whlt! lile ill[\2007
A.rob.Pof.pc3,urU
ADpll@tion\Ervtmrotal Rrport - FiqrGugrc 3.7'5nqg,Fg'n3.7$, 02i?5,tzfi, l1:04:X Pt'i,
Denison Mines (USA) Corp.
Pmjec't WHTTE MESA MILL
Figure 3.7-5
KRIGED PERCHED WATER LEVELS
4TH QUARTER 2006
Perched water discharges in springs and seeps along Westwater Creek Canyon and Cottonwood
Canyon to the west-southwest of the site, and along Corral Canyon to the east of the site, where
the Burro Canyon Formation outcrops. Perched water flowing beneath the tailings cells
eventually discharges in springs and seeps located in Westwater Canyon, to the south-southwest
of the cells. The primary discharge point for perched water flowing beneath the tailings cells is
believed to be Ruin Spring, located approximately 10,000 ft south-southwest of the Mill site, as
shown in Figure 3.7-6.
3.7.2.5 Perched Zone Hvdroqeolosv Beneath And Downsradient O.f The Tailinqs Cells
As of the 4th Quarter, 20066, perched water has been encountered at depths of approximately 50
to 115 ft bls in the vicinity of the tailings cells at the site (Figure 3.7-7). Beneath tailings Cell 3,
depths to water ranged from approximately 72 ft below top of casing (btoc) east of the cell (at
MW-31), to approximately 115 ft btoc at the southwest margin of the cell (at MW-23).
Assuming an average depth of the base of tailings Cell 3 of 25 ft below grade, this corresponds
to perched water depths of approximately 47 to 90 ft below the base of the cell, or an average
depth of approximately 70 feet beneath the base of the cell.
The saturated thickness of the perched zone as of the 4th Quarter, 2006 ranged from
approximately 94 ft in the northeast portion of the site to less than 5 ft in the southwest portion of
the site. Beneath tailings Cell 3, the saturated thickness varies from approximately 49 ft in the
eastemmost corner of the cell to approximately 6 ft in the westernmost corner of the cell. South-
southwest of the tailings cells, the saturated thickness ranges from less than 1 ft at MW-21 to
approximately 25 ft at MW-17. The average saturated thickness south-southwest of the tailings
cells, based on measurements at MW-3, MW-5, MW-12, MW-14, MW-15, MW-17, and MW-
20, is approximately 14 ft. The average saturated thickness based on measurements at MW-5,
MW-15, MW-3, and MW-20, which lay close to a line between the center of tailings Cell 3 and
Ruin Spring, is approximately 12 ft. By projecting conditions at these wells, the average
saturated thickness is estimated to be approximately l0 to 15 ft between MW-20 and Ruin
Spring.
Perched zone hydraulic gradients currently range from a maximum of approximately 0.04 feet
per foot (fUft) immediately northeast of tailings Cell 3 to less than 0.01 ftlft downgradient of Cell
3, between Cell 3 and MW-20. The average hydraulic gradient between the downgradient edge
of tailings Cell 3 and Ruin Spring was approximated by HGC to be approximately 0.012 fttft.
HGC also estimated a hypothetical worst case average perched zone hydraulic gradient,
assuming the perched water elevation to be coincident with the base of tailings Cell 3, to be
approximately 0.019 ftlft. See Section 3.2 of Appendix A.
6 Current groundwater elevations are reported to UDEQ in the Quarterly Groundwater Reports appended to the
Application. In general, sub-surface water contour conditions remain the same as those discussed above.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,200].
4t
Z:\White l{ee pllll\2007 LieM Rensal Ap9lication\Envircnmnbl RePt ' FiguG\ligre 3 76 drq , Flq@ 3 74. 0A24POO7 3134:ll l+1'
Adobe PDF, 11 x 17
o
Z:$iirbiiaig\2007tffiRgmlrppforbtr\EnrmrtrrlilFt'f,rcvl0t!f'7'7fi'fi'a3'7'l'0,4}q7&,Stl9tlS$LAd& ?DF.9cl, 11 x l,
Figure 3.7-7
Depth to Perched Water
September 2002
HGC also estimated the average permeability of the perched zone downgradient of tailings Cell
3, based on pump/recovery test and slug test data obtained from perched zone wells located
along the downgradient edge of and south of Cell 3, to be between 2.39E-05 cm/s and 4.3E-05
cm/s. See Section 3.3 of Appendix A.
3.7.3 GroundwaterQuality
3.7.3. 1 Entrada/Navaio Aquifer
The Entrada and Navajo Sandstones are prolific aquifers beneath and in the vicinity of the site.
Water wells at the site are screened in both of these units, and therefore, for the purposes of this
discussion, they will be treated as a single aquifer. Water in the Entrada/Navajo Aquifer is under
artesian pressure, rising 800 to 900 ft above the top of the Entrada's contact with the overlying
Summervillle Formation; static water levels are 390 to 500 ft below ground surface.
Within the region, this aquifer is capable of yielding domestic quality water at rates of 150 to 225
gpm, and for that reason, it serves as a secondary source of water for the Mill. Additionally, two
domestic water supply wells drawing from the Entrada./Navajo Aquifer are located 4.5 miles
southeast of the Mill site on the Ute Mountain Ute Reservation. Although the water quality and
productivity of the Navajo/Entrada aquifer are generally good, the depth of the aquifer (>1,000 ft
bls) makes access difficult.
Table 3.7-4 is a tabulation of groundwater quality of the Navajo Sandstone aquifer as reported in
the FES and subsequent sampling. The total dissolved solids (TDS) range from 244 to I,Il0
mg/liter in three samples taken over a period from January 27, 1977, to May 4,1977. High iron
(0.057 mglliter) concentrations are found in the Navajo Sandstone. Because the Navajo
Sandstone aquifer is isolated from the perched groundwater zone by approximately 1,000 to
1,100 ft of materials having a low average vertical permeability, sampling of the Navajo
Sandstone is not required under the Mill's previous NRC Point of Compliance monitoring
program or under the state's GWDP. However, samples were taken at two other deep aquifer
wells (#2 and #5) on site (See Figure 3.7-8 for the locations of these wells), on June 1, 1999 and
June 8, 1999, respectively, and the results are included in Table 3.7-4.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,200't
44
zfffi rg rrUmz uG Rffil Ap9lGei\E wlffi*J Rrrolt' FlT|ruo'G t'?'srt4'fin''7''at2,/7fil ll:l9l'' |ft
& rDG.o.g, 1l r 17
#'-t-r-
-(>i A i 'l-]
il /t'i 2ooo o 2o."; ilc-r--,. ft
[r*]--s!*FEE'[
a{
f'-- - ,-i' II;l,': ?: ! i!!"' t:.ii jli
++ --,. '
Tr 4- rv"r
.1$-trT-'--iSt+ t--
A i"\ .--_;1 t
\ I '\', \-
t-i- -117'1 T-
'- I- I ! rr t\ I i.f I t}.r, r;t
ii h !/ii
\irrl
t\aa
\ l- "'1
'[. it ;tii
li 1t i(- 1 \.';""2,)r ,l-\- t --t71;P$i{i
( v\ .'t \ tl-/ I
_ \..
['', ac{R Ii(
'--r1-H-
'l.-t.-3,,fr
, I .;' be,hs Lt i"*"-\ r\ i '\ ii"[]* -L - i- --i-=!-"t[rl \, i/| .' , Qi \ ir,\lni \ rr. i ----' )' I\\--3
.r ,,,.,:r, i:,i:it'i\
/l"
1 (. tfs"
!.i I
-t-- -
i
-'+ti\r
lu
I
I
I
III
i,t
I
7,.Yr
E
!ra_E_t3
rrt
1 6ae GROUNDWATER (WELL OR SPRING)
SAMPLING LOCATION
J waren SUPPLYwELL
-
-
IIIIIII
PROPERTY BOUNDARY
RESERVATION BOUNDARY
CANYON RIM
Denison Mines (USA) Corp.
Figure 3.7€
Groundwater (Wel! or Spring) Sampling
Stations in the White Mesa Mcinity
Table 3.7-4
Water Quality of Groundwater in the Mill Vicinity
Parameter
FES, Test Well
(G2R)
0tnn7 -3n3n8t)
WeIl #2
6t0tt99l
Well #5
6toSDgl
Field Specific Conductivity
(umhos/cm)3 l0 to 400
Field pH 6.9 to 7.6
Temperature (t)ll to 22
Estimated Flow m/tu (epm)109(20)
DH 7.9 to 8.16
Determination, mg/liter
TDS (@180"C)216tolll0
Redox Potential 2ll to 220
Alkalinity (as CaCOST)180 to 224
Hardness, total (as CaCOr)177 to2O8
Bicarbonate 226 214
Carbonate (as CO.)0.0 <1.0 <1.0
Aluminum 0.003 0.058
Aluminum, dissolved <0. I
Ammonia (as N)0.0 to 0. 16 <0.05 <0.05
Antimonv <0.001 <0.001
Arsenic, total .007 to 0.014 0.0t 8 <0.00t
Barium, total 0.0 to 0.15 0.1 l9 0.005
Beryllium <0.001 <0.001
Boron, total <0.1to 0.ll
Cadmium, total <0.005 to 0.0 <0_001 0.018
Calcium 50.6 39.8
Calcium, dissolved 5l to l12
Chloride 0.0 ro 50 <l.0 2.3
Sodium 7.3 9.8
Sodium, dissolved 5.3 to 23
Silver <0.001 <0.001
Silver, dissolved <0.fi)2 to 0.0
Sulfate 28.8 23.6
Sulfate, dissolved (as SO,)17 to 83
Vanadium 0.003 0.003
Vanadium. dissolved <.002 to 0.16
Manganese 0.01r 0.032
Manganese, dissolved 0.03 to 0.020
Chromium, total 0.02 to 0.0 0.005 0.005
Copper, total 0.005 to 0.0 0.002 0.086
Fluoride 0.18 0.18
Fluoride. dissolved O.l to O.22
Iron, total 0.35 to 2.1 0.43 0.20
Iron, dissolved 0.30 to 2.3
I Zero ralues (0.0) are below detection limits.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
46
Parameter
FES, Test Well
(G2R)
0t27n7 -323n8t)
Well #2
6tltD91
Well#5
6t089gl
Lead, total 0.02 - 0.0 <0.00t 0.018
Masnesium 20.4 21.3
Magnesium, dissolved l5 to 2l
Mercury, total <-00002 to 0.0 <0.001 <0.001
Molybdenum 0.001 <0.001
Molybdenum, dissolved 0.004 to 0.010
Nickel <0.001 0.004
Nitrate + Nitrate as N <0.10 <0. l0
Nitrate (as N)<.05 to 0.12
Phosphorus, total (as P)<0.01 to 0.03
Potassium 3.1 J.J
Potassium, dissolved 2.4 to 3.2
Selenium <0.001 <0.001
Selenium, dissolved <.005 to 0.0
Silica. dissolved (as SiOr)5.8 to l2
Strontium, total (as U)0.5 to 0.67
Thallium <0.001 <0.001
Uranium, total (as U)<.002 to 0.16 0.0007 o.oo42
Uranium, dissolved (as U)<,002 to 0.031
Zinc 0.010 o.126
Zinc, dissolved 0.007 to 0.39
Total Oreanic Carbon l.l to 16
Chemical Oxvsen Demand <l to 66
Oil and Grease
Total Suspended Solids 6 to 1940 <1.0 10.4
Turbidity 5.56 I9.l
Determination (pCifl itbr)
Gross Aloha <1.0
Gross Aloha + orecision 1.6+l.3 to 10.2+2.6
Gross Beta <2.0
Gross Beta + precision 8+8 to 73+19
Radium 226 + precision 0.3+0.2
Radium 228 <1.0
Ra-226 + orecision 0.1+.3 to 0.6+0.4
Th-230 + precision 0.1+0.4 toO.l+2.1
Pb-2 l0 + Drecision 0.0+4.0 to 1.0+2.0
Po-210 + precision 0.0+0.3 to 0.0+0.8
Source: Adapted from FES Table2.25 with additional Mill sampling data
3.7.3.2 Perched Groundwater Zone
Perched groundwater in the Dakota/Burro Canyon Formation is used on a limited basis to the
north (upgradient) of the site because it is more easily accessible. The quality of the Burro
Canyon perched water beneath and downgradient from the site is poor and extremely variable.
The concentrations of total dissolved solids (TDS) measured in water sampled from upgradient
and downgradient wells range between approximately 1,200 and 5,000 mg/l. Sulfate
concentrations measured in three upgradient wells varied between 670 and 1,740 mgll (Titan,
1994), The perched groundwater therefore is used primarily for stock watering and irrigation.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
41
The saturated thickness of the perched water zone generally increases to the north of the site.
See the Background Groundwater Quality Report: Existing Wells For Denison Mines (USA)
Corp.'s White Mesa Mill Site, San Juan County, Utah dated December 2006 prepared by Intera,
Inc., Appendix B.
At the time of renewal of the Mill license by the NRC in March, 1997 and up until issuance of
the Mill's Groundwater Discharge Permit ("GWDP") in March 2005, the Mill implemented a
groundwater detection monitoring program to ensure compliance to l0 CFR Part 40, Appendix
A, in accordance with the provisions of Mill License condition 11.3A. The detection monitoring
program was in accordance with the report entitled, "Points of Compliance, White Mesa
Uranium Mill," submitted by letter to the NRC dated October 5,1994. Under that program, the
Mill sampled monitoring wells MW-5, MW-I1, MW-12, MW-14, MW-15 and MW-17, on a
quarterly basis. Samples were analyzed for chloride, potassium, nickel and uranium, and the
results of such sampling were included in the Mill's Semi-Annual Effluent Monitoring Reports
that were filed with the NRC up until August 2004 andwith the DRC subsequent thereto.
Prior to 1997 , commencing h 1979, the Mill monitored up to 20 constituents in up to 13 wells.
That program was changed to the Points of Compliance Program in 1997 because:
. The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer; and
. The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
(a)Groundwater Discharge Permit
On March 8, 2005, the Co-Executive Secretary of the Utah Water Quality Board issued the
Mill's GWDP, which includes a groundwater monitoring program that supersedes and replaces
the groundwater monitoring requirements set out in Mill License Condition 11.3A. Groundwater
monitoring under the GWDP commenced in March 2005, the results of which are included in the
Mill's Quarterly Groundwater and DMT Perfornance Standard Monitoring Reports that are filed
with the Co-Executive Secretary of the Utah Water Quality Board. A copy of each such Report
since March 2005 is included in this Application.
(b) Groundwater Sampling Locations and Frequency
Currently, the Mill monitors ground water for radionuclide content and other parameters required
by the GWDP. Accordingly, groundwater quality is sampled for 47 constituents at the locations
depicted on Figure 3.7.-5 and at the frequencies listed below:
Quarterly Groundwater Compliance Monitoring Locations. MW-l1. MW-14. MW-26. MW-32
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W1
48
Semi-annual Groundwater Compliance Monitorine. MW-l. MW-18. MW-19. MW-2. MW-3. MW-5. MW-12. MW-15. MW-17
New Wells
The following new monitoring wells were added under the Permit.
. MW-3A. MW-23. MW-24. MW-27. MW-28. MW-29. MW-30. MW-31
These wells are being sampled quarterly to determine background. Once
background is established, a determination will be made under the Permit as to
which of these wells will be monitored on a semi-annual basis.
Accelerated Groundwater Monitoring
In addition to the routine quarterly and semi-annual monitoring referred to above,
Denison collects accelerated samplings at varying locations in accordance with
the Permit, as reported in the Quarterly Groundwater and DMT Performance
Standard Monitoring Reports.
Background Study
On August 28,2006, Denison received a Notice of Violation from the Co- Executive Secretary
of the Utah Water Quality Board (the "Co-Executive Secretary") which lists three violations of
the GWDP. Specifically, the NOV cited a number of constituents that had been detected in
groundwater monitoring wells in excess of the compliance limits set out in the GWDP. This
NOV was not unexpected, because the interim groundwater protection limits set out in the
GWDP were set prior to the establishment by the Co-Executive Secretary of background
groundwater quality at the site. Both Denison and the Co-Executive Secretary recognized at the
time of issuance of the GWDP that because background groundwater quality at the Mill had not
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2C[1
49
(c)
yet been approved at that time, the Co-Executive Secretary could not determine if any
constituent in groundwater is naturally occurring and therefore detectable or undetectable for
purposes of selecting groundwater protection limits in each monitoring well at the site.
Consequently, the Co-Executive Secretary initially assigned the groundwater protection limits as
if all constituents were "undetectable". However, in the Statement of Basis for the GWDP, the
Co-Executive Secretary acknowledged that after submittal and Co-Executive Secretary approval
of the existing well Background GWDP, pursuant to Part I.H.3 of the GWDP, the permit can be
reopened and the groundwater protection limits in the permit modified to reflect natural
background. The Co-Executive Secretary also acknowledged in the Statement of Basis that this
approach to set the initial limits in the GWDP does not account for natural variations in
groundwater quality and that false positives in the groundwater monitoring data may occur until
the Background Groundwater Quality Report is submitted, approved by the Co-Executive
Secretary and the GWDP limits re-established. Recognizing that it is not possible to determine
whether or not an exceedance of any of the current GWDP limits is due to natural causes prior to
review and acceptance by the Co-Executive Secretary of the Background Groundwater Quality
Report, the Executive Secretary and Denison agreed, in response to the NOV, on a revised date
of January 2,2007 to complete and submit the Background Groundwater Quality Report. The
Background Groundwater Quality Report had not been submitted at the time of the NOV
because it had taken much longer than originally anticipated by Denison to complete. This was
primarily due to the massive effort required by Denison's consultants in assembling, performing
quality assurance evaluations on and analyzing some 19,000 data entries that had been
accumulated over the history of the Mill, but which had never been assembled into one data base.
The Background Groundwater Quality Report was prepared for Denison by Intera, Inc., and
submitted to the Co-Executive Secretary on January 2, 2007, as agreed. Intera concluded in the
Report that "after extensive analysis of the data, we have concluded that there have been no
impacts to groundwater from Mill activities." lntera based this conclusion on a number of
factors, including the following:
There are a number of exceedances of permit limits in upgradient and far downgradient
wells at the site, which cannot be considered to have been impacted by Mill operations to
date. Exceedances of permit limits in monitoring wells nearer to the site itself are
therefore consistent with natural background in the area. In situations where the
constituent that exceeds the permit limit is not trending upward, the proper conclusion is
that it is representative of natural background.
There are numerous cases of both increasing and decreasing trends in constituents in
upgradient, far downgradient, and Mill site wells, which provide evidence that there are
natural forces at work that are impacting groundwater quality across the entire site.
In almost all cases where there are increasing trends in constituents in wells at the site,
there are more pronounced increasing trends in those constituents in upgradient wells.
Furthermore, and more importantly, in no case is there any evidence in the wells in
question of increasing trends in indicator parameters, such as chloride or fluoride, which
are considered the most mobile and best indicators of potential tailings cell leakage at the
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
50
site. Intera considered the combination of these factors to be conclusive evidence that all
increasing trends at the site are caused by natural forces and not by Mill activities.
The Background Groundwater Quality Report (Appendix B) supports Denison's position that the
exceedances of GWDP limits referred to in the NOV are due to natural background forces and
that the permit limits must be adjusted accordingly, as contemplated by the GWDP.
Chloroform Investieation
In May, 1999, excess chloroform concentrations were discovered in monitoring well MW-4, in
the shallow perched aquifer along the eastern margin of the Mill site. Because these
concentrations were above the State Ground Water Quality Standard ("GWQS") for chloroform,
the Executive Secretary of the Utah Water Quality Board initiated enforcement action against the
Mill on August 23, 1999 through the issuance of a Groundwater Corrective Action Order, which
required completion of: l) a contaminant investigation report to define and bound the
contaminant plume, and 2) a groundwater corrective action plan to clean it up. Repeated
groundwater sampling by both the Mill and DRC have confirmed the presence of chloroform in
concentrations that exceed the GWQS along the eastem margin of the site in wells that are
upgradient or cross gradient from the tailings cells. Other VOC contaminants have also been
detected in these samples. After installation of 23 new monitoring wells at the site, groundwater
studies appear to have defined the eastem and southern boundaries of the chloroform plume.
The Mill is currently in the process of installing additional wells in order to define the western
and northern bounds of the plume.
Based on the location of the plume and characterization studies completed to date, the
contamination appears to have resulted from the operation of temporary laboratory facilities that
were located at the site prior to and during construction of the Mill facility, and septic drainfields
that were used for laboratory and sanitary wastes prior to construction of the Mill's tailings cells.
Interim measures have been instituted in order to contain the contamination and to pump
contaminated groundwater into the Mill's tailings cells. A final corrective action plan has not yet
been developed.
In the Statement of Basis for the GWDP, the DRC noted that7, while the contaminant
investigation and groundwater remediation plan are not yet complete, the DRC believes that
additional time is available to resolve these requirements based on the following factors: 1)
hydraulic isolation found between the shallow perched aquifer in which the contamination has
been detected and the deep confined aquifers which are a source of drinking water in the area,2)
the large horizontal distance and the long groundwater travel times between the existing
groundwater contamination on site and the seeps and springs where the shallow aquifer
discharges at the edge of White Mesa, and 3) lack of human exposure for these shallow aquifer
contaminants along this travel path.
' See page 3 of the Statement of Basis, dated Decemb er 1,2Cxi,4.
(d)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W7
5l
Denison and DRC have agreed on a schedule for drilling of the additional wells necessary to
define the boundaries of this plume and for completion of the contaminant investigation report
and preparation of a groundwater corrective action plan.
(e) THF Study
Detectable concentrations of tetrahydrofuran ("THF") have been found in four wells at the Mill,
including upgradient well MW-I, and far downgradient well MW-3, as well as wells MW-2 and
MW-12 which are close to the Mill's tailings cells. Two of these wells, upgradient well MW-l
and far downgradient well MW-3 have THF concentrations that exceed the State GWQS. The
two other wells, MW-2 and MW-12 that are closest to the tailings cells exhibited detectable THF
concentrations that did not exceed the GWQS. Denison believes that the THF was most likely
derived from PVC glues and solvents used during installation of the PVC well casings found in
several monitoring wells at the facility, including each of the four wells described above. This
position is consistent with the occurrence of THF in both up and far downgradient wells at the
site. However, the Co-Executive Secretary has determined that further evaluation is required to
determine why three other wells installed at the same time do not exhibit detectable THF
concentrations. As a result, Part I.H.19 of the GWDP requires that Denison submit a work plan
to examine this matter further. Such work plan was submitted to the Co-Executive Secretary and
further evaluations are ongoing at this time.
3.7 .4 Springs and Seeps
As discussed in Section 3.7.2.4, perched groundwater at the Mill site discharges in springs and
seeps along Westwater Creek Canyon and Cottonwood Canyon to the west-southwest of the site,
and along Corral Canyon to the east of the site, where the Burro Canyon Formation outcrops.
Water samples have been collected and analyzed from springs and seeps in the Mill vicinity as
part of the baseline field investigations reported in the 1978 ER (See Table 2.6-6 in the 1978
ER).
During the period 2003-2004, Denison implemented a sampling program for seeps and springs in
the vicinity of the Mill which had been sampled in 1978, prior to the Mill's construction. Four
locations were designated for sampling, are shown on Figure 3.7-8. During the 2-year study
period only two of the four locations were able to be sampled, Ruin Spring and Cottonwood
Canyon. The other two locations, Corral Creek and a location west of Westwater Creek were not
flowing (seeping) and samples could not be collected. With regard to the Cottonwood seep,
while water was present, the volume was not sufficient to complete all determinations, and only
organic analyses were conducted. The results of the organic analysis did not detect any
detectable organics.
Samples at Ruin Spring were analyzed for major ions, physical properties, metals, radionuclides,
volatile and semi-volatile organic compounds, herbicides and pesticides, and synthetic organic
compounds. With the exception of one chloromethane detection, all organic determinations were
at less than detectable concentrations. The detection of chloromethane is not uncommon in
groundwater and can be due to natural sources. [n fact, chloromethane has been observed by
Denison at detectable concentrations in field blank samples during routine groundwater sampling
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
52
events. The results of sampling for the other parameters tested are shown in Table 3.7-9. Tbe
results of the 200312004 sampling did not indicate the presence of mill derived groundwater
constituents and are representative of background conditions.
Tatrle 3.7-9
Results of Quarterly Sampling
Ruin SprineQ0O3-200a)
Parameter Ruin Sprine
01-03 o2-03 03-03 04-3 o1-04 O2'04 03-04 04-04
Maior Ions (ms/L)
Alkalinity 196 r98 193 191 195 183
Carbon Dioxide ND ND ND ND t2 ND
Carbonate ND ND ND ND ND ND
Bicarbonate 239 241 235 232 238 223
Hydroxide ND ND ND ND ND ND
Calcium 153 156 t49 r58 158 162 t76 r86
Chloride 28.1 2t.5 21.4 28.0 29.3 28.5 26 25
Fluoride ND 0.5 0.5 0.6 0.6 0.6
Magnesium 34.8 34.2 31.1 34.2 35.8 35. I 37.1 38.6
Nitrosen. Ammonia As N ND ND ND ND ND 0.06 ND 0.06
Nitrosen- Nitrate+Nitrite as N 1.6 t.5 1.4 1.4 1.73 r.85 1.34 1.1
Phosphorous 0.10 ND ND ND ND ND ND
Potassium 2.6 J.J 3.9 3.4 3.6 4.0 3.7
Sodium lr0 105 103 Il3 104 ll0 l13 il6
Sulfate 503 501 495 s06 539 468 544 6t3
Physical Properties
Conductivitv (umhos/cm)t440 l4l0 1390 t4r']0 1320 1570
nH t.9t 7.98
TDS (mell-)1040 1000 1050 lll0 1050 1070
TSS (mell-)t 3.5 ND ND ND ND ND
Turbidity (NTU)0.16 0. l3 ND 0.12
Metals-Dissolved (ms/L),
Aluminum ND ND 0.40 ND ND ND ND ND
Antimony ND ND ND ND ND ND ND ND
Arsenic 0.001 ND ND 0.00r ND ND ND ND
Barium ND ND ND ND ND ND ND ND
Bervllium ND ND ND ND ND ND ND ND
Cadmium ND ND ND ND ND ND ND ND
Chromium ND ND ND ND ND ND ND ND
Copper ND ND 0.082 ND ND ND ND ND
Iron ND ND ND ND ND ND ND ND
Lead ND ND ND ND ND ND ND ND
Manganese ND ND ND ND ND ND ND ND
Mercury ND ND ND ND ND ND ND ND
Molvbdenum ND ND ND ND ND ND ND ND
Nickel ND ND ND ND ND ND ND ND
Selenium 0.013 0.012 0.012 0.012 0.o12 o.ot2 0.0t2 0.012
Silver ND ND ND ND ND ND ND ND
Thallium ND ND ND ND ND ND ND ND
Uranium 0.009 0.01I 0.010 0.010 0.01I 0.011 0.009 0.0t0
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
53
Parameter Ruin SDrine
01-03 ()2-03 ()3-03 ()4-3 or-04 o,2-o4 03-04 o4-04
Maiorlons (me/L)
Vanadium ND ND ND ND ND ND ND ND
Zinc 0.0r4 ND ND ND ND ND ND ND
Radionuclides (pCi/L)
Gross Alpha Minus Rn & U ND ND 1.4 ND
Lead 210 42 ND ND ND ND ND ND ND
Radium 226 0.3 ND 0.3 ND ND ND t.3 ND
Thorium 230 0.3 o.2 0.5 ND ND ND 0.4 ND
Thorium 232 ND ND ND ND ND
Thorium 228 ND ND ND ND
3.8
As required by Part I.H.9 of the Groundwater Discharge Permit, the Mill submitted to the Co-
Executive Secretary of the Utah Water Quality Board for approval a plan for groundwater
sampling and analysis of all seeps and springs found downgradient or lateral gradient from the
tailings cells at the Mill. This Plan is currently under review by the Co-Executive Secretary.
Topography
The Mill site is located on a gently sloping mesa that, from the air, appears similar to a
peninsula, as it is surrounded by steep canyons and washes and is connected to the Abajo
Mountains to the north by a narrow neck of land. On the mesa, the topography is relatively flat,
sloping at less than one (1) percent to the south and nearly horizontal from east to west. See also
Section 3.4.1 and Figure 3.7-6.
3.9 Demography and Socioeconomic Profile
3.9.1 Demosraphy of the Area
Demographic information is generally derived from information obtained by the U.S. Census
Bureau. These records are updated on a five year frequency for population centers which exceed
65,000 people and on a ten year frequency for lesser populations. As such, the local population
update for the area of interest was last recorded in the year 2000, and it is that data base which
was utilized to formulate the demographic information provided in this report. According to the
2000 census, the population density of San Juan County, in which the Mill is located, is 1.8
individuals per square mile. By comparison, the statewide density is greater tban 27.2 persons
per square mile. The town of Blanding, Utah, approximately 6 miles north of the Mill, is the
largest population center near the Mill site, with3,162 persons. Approximately 5 miles southeast
of the Mill site is the White Mesa community of approximately 277 Ute Mountain Ute tribal
members. See Figure 3.9-1. The Navajo Reservation is located approximately 19 miles
southeast of the Mill. The nearest community on the Navajo Reservation is Montezuma Creek, a
community of approximately 507 individuals in Utah. The nearest resident to the Mill is located
approximately 1.5 miles to the north of the Mill, near air monitoring station BHV-1 Table 3.9-1
provides population centers located within 50 miles of the Mill site.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
54
{I
E
Etg
g
F
g
*
c
E
Tii
!
E
p:
E
ETi
TI
T
E*
=-.IB
iH5rII
SCALE012
-==-MILES
PROPERW BOUNDARY
RESERVATION BOUNDARY
CANYON RIM
Figure 3.9-1
Population in The
Prcject Vicinity - 2000 Census
Table 3.9-1
Population Centers Within 50 Miles of the Mill Siter
Population Center 20fi) Population Distance From Site"
(miles)
Blandine. UT 3.162 6
White Mesa, UT 271 4
Bluff, UT 320 l5
Montezuma Creek, UT 507 20
Aneth, UT 598 27
Mexican Hat, UT 88 30
Monticello. UT I,958 2',7
Eastland/Ucolo, UT 249'32
Dove Creek, CO 698 37
Towaoc, CO 1,097 50
Source: http://factfi nder.census.gov
r2000 Census
2 Approproximate distance from Mill site by air
3 Based on 1978 population estimate
3.9.2 Socioeconomic Profiles
San Juan County, Utah, is the largest and poorest county in Utah. As of December 2006, the
unemployment rate in San Juan County was 4.9Vo, compared to 2.6Vo for Utah as a whole, and
4.5Vo for the nation as a whole. When operating, the Mill is one of the largest private employers
in San Juan County, employing up to 60-140 full time employees. As such, the Mills employees
represent a significant economic base for the city of Blanding and rural residents of San Juan
County. In addition, the Company pays local taxes to San Juan County, further supporting the
development of the local economic base. The Mill also provides income to local minorities,
typically employing a high percentage of minority workers ranging from 45-757o Native
Americans.
Since its inception in 1980, the Mill has run on a campaign basis, in each case remaining on
standby pending accumulation of sufficient ore stockpiles to justify a milling campaign.
Currently, Mill employees are predominantly residents of San Juan County, or residents of
neighboring counties who commute to the Mill on a daily basis. Historically, the Mill has drawn
upon such residents of San Juan County and neighboring counties for each milling campaign,
rather than relying upon an influx of workers to the area. As a result, Mill campaigns have not
given rise to any unusual demands on public services or resulted in any cultural or
socioeconomic issues for the surrounding areas.
3.10 Land Use
Approximately 65.8Vo of San Juan County is federally owned land administered by the U.S.
Bureau of Land Management, the National Park Service, and the U.S. Forest Service. Primary
land uses include livestock grazing, wildlife range, recreation, and exploration for minerals, oil,
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
56
and gas. Approximately 22Vo of the county is Native American land owned either by the Navajo
Nation or the Ute Mountain Ute Tribe. The area within 5 miles of the Mill site is predominantly
range land owned by residents of Blanding. The Mill site itself, including tailings cells,
encompasses approximately 300 acres.
A more detailed discussion of land use at the Mill site, in surrounding areas, and in southeastern
Utah, is presented in the FES (Section 2.5). Results of archeological studies conducted at the site
and in the surrounding areas as part of the 1978 ER are also documented in the FES (Section
2.s.2.3).
3.11 Transportation
The FES (Section 4.8.5) contemplated that during full-scale operations, about 85 hourly Mill
employees plus 20 salaried staff would travel to the Mill daily along U.S. Highway 1918. The
FES (Section 4.8.5) also noted that heavy truck traffic would also increase substantially in the
Mill area. Specifically, Section 4.8.5 of the FES noted that during the operations period, when
area mining was at expected peak levels, approximately 68 round trips on local highways would
be made by 30-ton ore trucks to the Mill per day (1978 ER, p. 5-34).
These calculations are consistent with an annual avera9e Mill capacity of 2,000 tons of ore per
day, which, based on typical Mill availabilities, would be expected to result in the processing of
approximately 680,000 tons of ore per year. On the basis of 25 tons of ore in each truck, 27,200
round trips per year, or approximately 78 round trips per day, based on a 7-day work week (109
per day, based on a five-day week) would be transported along local highways to the Mill. For
purposes of comparison to the FES, 78 roundtrips per day based on 25 tons of ore per truck is
equivalent to 65 round trips per day based on 30 tons of ore per truck. The FES also
contemplated that if the Mill is operating at a capacity of 680,000 tons of conventional ore per
year, approximately 17 shipments of anhydrous ammonia would be made annually to the Mill in
2O ton loads; sulfuric acid shipments to the Mill would amount to about eight truck loads per
day; and that amine shipments would be made at the rate of about one truck load every 45 days
(FES Section 5.3.3).
Finally, the FES (Section 5.3.1) noted that refined yellowcake product is generally packaged in
55-gal, l8-gauge drums holding an average of 800 lb and classified as Transport group III Type
A packaging (49 CFR Parts 170-189 and 10 CFR PartTl). Yellowcake is shipped by truck an
average of 1,300 to 1,441 miles to a conversion plant, which transforms the yellowcake to
uranium hexafluoride. An average yellowcake shipment contains approximately 45 drums, or
17.5 tons of yellowcake.
Based on a licensed yellowcake capacity of 4,380 tons per year (Mill License condition 10.1) a
maximum of 8,760,000 pounds of yellowcake would require shipment from the Mill to
conversion facilities. This would require approximately 183-275 truck shipments from the Mill
per year (based on 40-60 drums per truck), or one truck every one to two days based on a seven-
day week (one truck everyday or so, based on a five-day week).
8 At the time of the FES, Highway l9l was Highway 163.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
57
The following Table 3.11-1 illustrates the various materials shipped to and from the Mill for
various periods of operation over the Mill's history (Note: shipments are indicated on Table
3.11-1 based on the assumption that the ore shipments were made during the year that the ore
was processed. However, for some years actual shipments of ore took place during previous
years of Mill standby, such as 1984 and 200012001, while the Mill was stockpiling ore in
preparation for a future Mill run).
Table 3.11-1
Production and Transportation Summary
tMill on Standby
2 Uranium produced in 2002 and 2003 was not shipped until 2005
From this table it is evident that a total of over 28 million pounds of U:Oa and over 33 million
pounds of vanadium have been recovered at the Mill since its inception from over 4 million tons
of conventional ores and alternate feed materials, ranging from no production in some years, to
production at full capacity in other years. Average production per year in the peak years of
production of 1980-1983 and 1985-1989, has been approximately 1.5 million and3.75 million
pounds of U:Os, respectively. The peak years of production for the Mill were 1986, 1987, and
1988 during which the Mill produced and shipped approximately 4.98, 4.8 and 4.97 million
pounds of yellowcake, respectively. It can also be observed from this table that when the Mill is
in full operation, as for example during the five full years of operations included in the period
1985-1990, an average of approximately 68 ore, reagent and other supply trucks arrived at the
Mill each week day, and approximately one truckload of uranium and one truckload of vanadium
was shipped from the Mill every three week days.
In 2003, the Utah Department of Transportation ("UDOT") provided Denison with2002 traffic
pattems. This information is set out in Table 3.ll-2 relating to vehicular traffic at various
locations along the route to the Mill. Because local traffic conditions remain essentially
unchanged since the period of that data collection effort, the data are again used here for the
purposes of this Application.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
58
Year(s)
Received
Oi"e'(Toiis)'
::h6ductiorr Numberof Trucks
lbsV,O.0rd
UrOr
Product
V:Os
Produc't H,Sr}.llactO.Fuels & Oils
Itgrosene
Amine,
nupprresMisc.
. Reeoenlc '
1978- 1983
I 984
1985-1990
199 I -1994'
I 995
1996
1997
l 998
1999
2000-2001'
2002
2003
2004
2005
2006
I,5 I l,5rM
0
2,037,209
0
163,M6
43,553
1,995
63,296
90,308
0
t35,724
36,469
7,594
2,399
3,t85
6,(N5,]Zt
0
I 8,759,338
0
1,472,6t4
661,'722
619, r 93
3,000
652, I 00
0
0
0
0
46,092
230,959
I 3,008, l 55
0
t8,943,167
0
0
0
0
0
I,5 r2,80r
0
0
0
0
0
0
60,462
0
8 t,488
0
6,522
I,742
r00
3,1 65
3,612
0
6,786
I,823
436
t44
202
150
0
469
0
37
l7
l5
0
l6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
l2
Jt)
474
38
12,092
0
16,298
0
2,283
610
t6
t27
676
0
20
1
0
216
354
90'7
0
1,222
0
98
26
0
0
59
0
0
0
0
2
0
t,5t2
24
2,037
96
272
73
3
t27
90
48
271
73ll
24
66
t6
0
102
0
8
2
2
0
0
0
0
0
0
4
6
2,267
260
3,056
I040
408
109
60
r90
27t
520
4U
r09
t0
35
l8l
Total 4,096322 28,4s0;739 33,46/,,123 166,482 "7M 849 32,699 zr3l4 4Jn zw EB23
Listed below are points on the north and south boundaries of each of the cities of Moab,
Monticello and Blanding in order to allow for an estimation of the average truck traffic through
those cities, as well as north and south of the Mill, and points representing the northem most
point on Highway 191 (Crescent Junction) and the midpoint on the route (La Sal Junction).
Table 3.ll-2
Estimated 2002Daily Car and Truck Traffic on Route 191 in Yicinity of the Mill
Location
Northbound Southbound
Number of
Cars
,Number of
.,:Trrrcks
7o Trucks of
Total Traffic
Number
of Cars
Number of
Trucks
.% Trucks of
Total Traffic
Ict SR 262 to Aneth (South of the Mill)1,292 259 177o 1,242 218 lSVo
Ict SR 95 South of Blanding (South of
Blandins and North of the Mill)1.131 365 llTo I,661 410 20Vo
Verdure (North of Blanding)936 301 24Vo 902 342 28Vo
South of Monticello l,609 609 27Vo I,551 686 3lVo
North of Monticello 862 1t6 45Vo 862 7t6 45Vo
Ict SR 46 La Sal Jct 1,217 382 247o 1.262 48r 287o
San Juan Grand County Line (South of
Moab)3.213 1.023 24Vo 3,380 1,149 257o
Jct SR 128 Colorado River (North of
Moab)2,152 705 25Vo ) 7)q 6ll 2t?o
Jct SR3 I 3-Jct I70 Crescent Jct l.l l5 366 25Vo 1.207 3t7 217o
3.12
3.t2.1
Estimate provided by IJDOT to Denison on April 9,20[3.
Eeological Resources and Biota
Terrestrial
3.12.t.1 Flora
The natural vegetation presently occurring within a 25-mlle (40-km) radius of the Mill site is
very similar to that of the region, being characterized by pinyon-juniper woodland intergrading
with big sagebrush (Artemisia tridentata) communities. The pinyon-juniper community is
dominated by Utah juniper (Juniperus osteosperma) with occurrences of pinyon pine (Pinus
edulis) as a codominant or subdominant tree species. The understory of this community, which
is usually quite open, is composed of grasses, forbs, and shrubs that are also found in the big
sagebrush communities. Common associates include galleta grass (Hilaria jamesii), green
ephedra (Ephedra viridis), and broom snakewood (Gutierrezia sarothrae). The big sagebrush
communities occur in deep, well-drained soils on flat terrain, whereas the pinyon-juniper
woodland is usually found on shallow rocky soil of exposed canyon ridges and slopes. See
Section 2.9 of the 1978 ER.
Based on the work completed by Dames & Moore in the 1978 ER, no designated or proposed
endangered plant species occur on or near the project site (1978 ER, Section 2.8.2.1). Of the 65
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
59
proposed endangered species in Utah at that time, six have documented distributions in San Juan
County. A careful review of the habitat requirements and known distributions of these species
by Dames & Moore in the 1978 ER indicated that, because of the disturbed environment, these
species would probably not occur on the project site. The Navajo Sedge has been added to the
list as a threatened species since the Dames & Moore study.
In completing the 2002EA, NRC staff contacted wildlife biologists from the BLM and the Utah
Wildlife Service to gather local information on the occurrences of additional species surrounding
the Mill. In the 20028A, NRC staff concluded that the Navajo Sedge has not been observed in
the area surrounding Blanding, and is typically found in areas of moisture (2002 EA at 4).
3.12.1 .2 Fauna
Wildlife data were collected by Dames & Moore through four seasons at several locations on the
Mill site, prior to construction of the Mill. The presence of a species was based on direct
observations, trappings and signs such as the occurrence of scat, tracks, or burrows. A total of
174 vertebrate species potentially occur within the vicinity of the Mill (1978 ER, Appendix D),
78 of which were confirmed (1978 ER, Section 2.8.2.2).
Although seven species of amphibians are thought to occur in the area, the scarcity of surface
water limits the use of the site by amphibians. Eleven species of lizards and five snakes
potentially occur in the area (1978 ER, Section 2.8.2.2).
Fifty-six species of birds were observed in the vicinity of the Mill site (1978 ER, Section
2.8.2.2).
The food habits of eagles vary depending on the season and the region in which they live. Fish,
carrion and waterfowl such as mallard, are consumed by eagles when available to them. The
FES indicates that mallards are both common and permanent in the vicinity of the Mill (FES,
Table 2.28).
Raptors are prominent in the western United States. Five species were observed in the vicinity
of the site. Although no nests of these species were located at the time of the FES, all (except the
golden eagle, Aquila chrysaetos) have suitable nesting habitat in the vicinity of the site. The nest
of a prairie falcon (Falco mexicanus) was found about 314 mile (1.2 km) east of the site.
Although no sightings were made of this species, members tend to retum to the same nests for
several years if undisturbed (1978 ER, Section 2.8.2.2).
Of several mammals that occupy the site, mule deer (Odocoileus hemionus) is the largest
species. The deer inhabit the project vicinity and adjacent canyons during winter to feed on the
sagebrush and have been observed migrating through the site to Murphy Point (1978 ER, Section
2.8.2.2). Winter deer use of the project vicinity, as measured by browse utilization, is among the
heaviest in southeastem Utah at 25 days of use per acre in the pinyon-juniper-sagebrush habitats
in the vicinity of the project site. In addition, this area is heavily used as a migration route by
deer traveling to Murphy Point to winter. Daily movement during winter periods by deer
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
60
inhabiting the area has also been observed between Westwater Creek and Murphy Point. The
present size of the local deer herd is not known.
Other mammals present at the site include the coyote (Canis latrans), red fox (Vulpes vulpes),
gray fox (Urocyon cineroargenteus), striped skunk (Mephitis mephitis), badger (taxidea taxus),
longtail weasel (Mustela frenata), and bobcat (Lynx rufus). Nine species of rodents were trapped
or observed on the site, the deer mouse (Peromyscus maniculatus) having the greatest
distribution and abundance. Although desert cottontails (Sylvilagus auduboni) were uncommon
in 1977, black-tailed jackrabbits (Lepus califomicus) were seen during all seasons.
In the 2002 EA, NRC staff noted that, in the vicinity of the site, the U.S. Fish and Wildlife
Service had provided the list set out in Table 3.12-1, of the endangered, threatened, and
candidate species that may occur in the area around the site.
Table 3.12-l
Endangered, Threatened and Candidate Species in the Mill Area
The2002 EA also noted that, in addition, the species listed on Table 3.12-2 may occur within the
Mill area that are managed under Conservation Agreements/Strategies.
Table 3.12-2
Species Managed Under Conservation Agreements/Strategies at the Mill Area
For the 2002 EA, NRC staff contacted wildlife biologists from the BLM and the Utah Wildlife
Service to gather local information on the occurrences of these additional species surrounding
the Mill. NRC staff made the following conclusions (2002 EA p.4):
Denison Mines (uSA) corp., white Mesa Mill, Environmental Report, February 28,2007
6l
Common Name Scientific Name Status
Navaio Sedee Carex specuicola Threatened
Bonvtail Chub Gila elesans Endangered
Colorado Pikeminnow Ptvchocheilus lucius Endansered
Humpback Chub Gila cvoha Endansered
Razorback Sucker Xyrauchen texanus Endansered
Bald Eaele Haliaeetus leucocephalus Threatened
California Condor Gymnogyps californianus Endangered
Gunnison Sase Grouse Centrocercus minimus Candidate
Mexican Sootted Owl Strix occidentalis lucida Threatened
Southwestern Willow Flycatcher Empidonax traillii extimus Endangered
Western Yellow-billed Cuckoo Coccyzus americanus occidentalis Candidate
Black-footed Ferret Mustela nisrioes Endangered
Source: 2002EA
CommonName Scientific Name
Colorado River Cutthroat Trout Oncorhynchus clarki oleuriticus
Gunnison Sage Grouse Centrocercus minimus
Source: 2002EA
While the ranges of the bald eagle, peregrine falcon, and willow flycatcher
encompass the project area, their likelihood of utilizing the site is extremely low.
The black-footed ferret has not been seen in Utah since 1952, and is not expected to
occur any longer in the area. The Califomia Condor has only rarely been spotted in
the area of Moab, Utah, (70 miles north) and around Lake Powell (approximately
50 miles south). The Mexican Spotted Owl is only found in the mountains in Utah,
and is not expected to be on the Mesa. The Southwestern Willow Flycatcher,
Westem Yellow-billed Cuckoo, and Gunnison Sage Grouse are also not expected to
be found in the immediate area around the Mill site.
3.12.2 Aguatic and Wetlands Biota
Aquatic habitat at the Mill site ranges temporally from extremely limited to nonexistent due to
the aridity, topography and soil characteristics of the region and consequent dearth of perennial
surface water. Two small stockwatering ponds are located on the Mill site a few hundred yards
from the ore pad area (See Figure 3.7-7). One additional small "wildlife pond", east of Cell 44,
was completed in 1994 to serve as a diversionary feature for migrating waterfowl. Although
more properly considered features of the terrestrial environment, these ponds essentially
represent the total aquatic habitat on the Mill site. These ponds probably harbor algae, insects,
other invertebrate forms, and amphibians. They also provide a water source for small mammals
and birds. Similar ephemeral catch and seepage basins are typical and numerous to the northeast
of the Mill site and south of Blanding.
Aquatic habitat in the Mill vicinity is similarly limited. The three adjacent streams (Corral
Creek, Westwater Creek, and an unnamed arm of Cottonwood Wash) are only intermittently
active, carrying water primarily in the spring during increased rainfall and snowmelt runoff, in
the autumn, and briefly during localized but intense electrical storms. Intermittent water flow
most typically occurs in April, August, and October in those streams. Again, due to the
temporary nature of these steams, their contribution to the aquatic habitat of the region is
probably limited to providing a water source for wildlife and a temporary habitat for insect and
amphibian species.
In the 2002F,A, NRC staff concluded that (p. 4) no populations of fish are present on the project
site, nor are any known to exist in the immediate area of the site. Four species of fish designated
as endangered or threatened (the Bonytail Chub, Colorado Pikeminnow, Humpback Chub and
Razorback Sucker) occur in the San Juan River 18 miles south of the site, which Dames &
Moore noted in the 1978 ER (Section 2.8.2) is the closest habitat suitable for these species. NRC
staff further concluded that there are no discharges of mill effluents to surface waters, and
therefore, no impacts are expected for the San Juan River due to operations of the Mill.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
62
3.13 BaselineRadiologicalEnvironment
3. 13. I Background Radiation
All living things are continuously exposed to ionizing radiation from a variety of sources
including cosmic and cosmogenic radiation from space and external radiation from terrestrial
radionuclides such as uranium, thorium and potassium-40 that occur in the earth's crust, in
building materials, in the air we breathe, the food we eat, the water we drink and in our bodies.
Some exposures, such as that from potassium-40, are controlled by our body's metabolism and
are relatively constant throughout the world, but exposures from sources such as uranium and
thorium in soils and especially from radon in homes can vary greatly, by more than a factor of
ten, depending on location.
In order to provide a context for exposures potentially attributable to radioactive emissions from
processing ores and altemate feed materials at the Mill, this section provides some general
background information on exposures to natural background radiation worldwide, in the United
States and in the Colorado Plateau region where the Mill is located.
3.1 3.1.1 The World
In general terms, the worldwide breakdown of natural background radiation sources can be
summarized as follows (UNSCEAR, 2000):
Cosmic and Cosmogenic
Terrestrial
Inhaled (Radon)
Ingested
Total (Average)
39 mrernlyr
48 mrem/yr
126 mrem/yr
29 mrem lyr
242mremlyr (116 mrem/yr excluding radon)
According to the United Nations Scientific Committee on the Effects of Atomic Radiation
("UNSCEAR"), the actual doses can vary considerably from the nominal values listed above,
and around the world vary from this value by more than a factor of 10. For example, the dose
from cosmic and cosmogenic radiation varies with altitude. The higher the altitude, the less is
the protection offered by the earth's atmosphere. The dose from external gamma radiation can
vary greatly depending on the levels of uranium and thorium series radionuclides in the local
soil. One example is the elevated gamma fields seen on natural sands containing heavy minerals
as for example in regions around the Indian Ocean, in Brazil, and New Jersey. The high
variability in indoor radon concentrations is a major source of the variation in natural
background dose. The variability in the dose from radon arises from many factors, including:
variability in soil radium concentrations from place to place; variation both over time and
location in housing stock, heating and ventilating systems; and variations in individual habits.
The worldwide average ambient (i.e. outdoor) radon concentration is about 10 Bq/m3
(UNSCEAR, 2000) and the world average concentration of U-238 and Th-232 in soils is about
0.7 pCr/g(25 Bqikg) (NRC, 1994\.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
63
The definition of "background radiation" in 10 CFR 20.1003 specifically includes global fallout
as it exists in the environment from the testing of nuclear explosive devices or from past nuclear
accidents such as Chernobyl that contribute to background radiation and are not under the control
of the licensee. The calculation of background radiation in this Section 3.13.1 is conservative
because it does not include such fallout in background radiation for the Mill site.
3.13.1.2 United States
In the United States, nominal average levels of natural background radiation are as follows
(National Council of Radiation Protection and Measurements ("NCRP"), 1987):
Cosmic and Cosmogenic
Terrestrial
Inhaled (Radon)
Ingested
Total (Average)
28 mrem/yr
28 mrem/yr
200 mrem/yr
40 mrem /yr
296mremlyr (96 mrem/yr excluding radon)
As shown above, in the United States, the average annual dose from natural background
radiation is about 296 mremlyr (including radon). The actual armual dose from natural
background varies by region within the United States. For example, the average dose from
external terrestrial radiation for a person living on the Colorado Plateau is in the order of 63
mrem,/yr, which is considerably higher than the average dose from terrestrial radiation for a
person living in Florida, where the average annual dose from external terrestrial radiation is only
about 16 mrem/yr. (NRC, 1994; NCRP, 1987). No comparison made. In the United States,
outdoor radon levels vary widely from about 0.1 pCifl in New York City to about 1.2 pCitL in
Colorado Springs (NCRP, 1987), generally consistent with nominal worldwide values noted in
the previous section.
3.13.1.3 Mill Site
At the Mill site, the average dose equivalent from natural background radiation was measured in
1977 to be about 142 mrem/yr. Of this 142 mrem/yr, 68 mrem/yr came from cosmic radiation,
while about 74 mremlyr came from terrestrial radiation (1978 ER).
Ingested radionuclides would contribute (about) a further 18 mrem/yr (NRC, 1979). This brings
the total natural background dose from extemal radiation and ingested radioactivity, but
exclusive of the dose from Rn-222, to about 161 mrem/yr (Table 3.13-1).
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
64
Table 3.13-1
Mill Site Average Dose From Natural Background Radiation
(Excluding Dose From Radon)
Location
Cosmic and
Cosmogenic
(mrem/vr)
External
Terrestrial
(rnrerr/vr)
Ingested-
(mrem/yr)
Average Total
Dose
(rnrem/vr)
Blanding,
Utah,/White Mesa 68 74 l8 160
United States 28 28 40 96
Worldwide 39 48 29 l16
Source: Appendix C
Based on pre-operational measurements of ambient outdoor radon levels in the vicinity of the
Mill (1978 ER), the dose from Rn-222 was estimated using generally accepted procedures to
contribute an additional 250 mrem/yr. When the contribution from radon was added to other
sources of natural background radiation dose, the total annual dose from natural background
radiation and radioactivity to a person living in the vicinity of the Mill was estimated to be about
400 mrem/yr, considerably higher than the national average of 296 mrem/yr but not without
precedent for Western U.S. locations. The increase over U.S. average background radiation
exposure in the vicinity of the Mill is principally due to greater cosmic radiation exposure at
higher elevations and from greater terrestrial sources (e.g. higher soil concentrations of
radionuclides) common in the Western United States.
3.13.2 Radiological Impacts of Currently Licensed Operations
3.13.2.1 Introduction
The FES, in part relying on information in the 1978 ER and Supplement to the 1978 ER,
provides a detailed assessment of the potential radiological impacts from the then proposed Mill
(Section 4.7). As noted in the FES, there is no plan to release radioactive effluents to the surface
water environment (Section 4.7.2). In addition, the FES notes (Section 4.7.2) that the possibility
of seepage from the tailings impoundment to groundwater is remote and therefore, no potentially
significant contribution to dose from water pathways was anticipated. As described elsewhere in
this ER (Section 3.7.3.2), the groundwater monitoring program is designed to ensure early
detection of any un-anticipated seepage and implementation of any necessary mitigative
measures. In addition, the Background Groundwater Quality Report (Intera, 2007), together with
the data collected from local surface water drainages, and data collected from seeps and springs
supports the conclusion that groundwater impact from Mill sources is not evident. The
environmental pathways of potential concern considered in the FES are therefore for airborne
emissions.
This Section briefly discusses the radiological impacts considered in the FES potentially
attributable to airbome radioactive emissions from the Mill to both nearby individuals and the
entire population within 50 miles of the Mill. Consideration has also been given to the
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
65
occupational exposure
human.
Finally, the foregoing
operating results based
received by Mill employees and radiation exposure of biota other than
analysis is then followed in each category by a brief discussion of actual
on historic monitoring data.
3.13.2.2 Exposure Pathways for Humans
Potential environmental exposure pathways by which humans could be exposed to airborne
radioactive emissions from the Mill are presented schematically in Figure 3.13-1. As noted in
the previous Section, there are no realistic surface water or groundwater pathways of exposure.
The doses to humans estimated in the FES are based on the proposed Mill design, the actual
characteristics of the site environs, and the models and assumptions described in Section 4.7 and
Appendix D of the FES.
Environmental exposure pathways of potential concem for airborne effluents from the Mill are
inhalation of radioactive materials in the air, external exposure to radioactive materials in the air
or deposited on ground surfaces, and ingestion of contaminated food products (vegetables and
meat). The FES assessment was based on the projected air emissions shown in Table 3-13-2.
Table 3.13-2
FES Estimated Annual Releases of Radioactive
Materials Resulting from the Mill
(Annual releases (Ci)r)
Source u-238 Th;230.Ra:?i26 R:n-222
Blanding ore
crusher2
2.68-04 2.68-04 2.68-04 2.6F+N
Ore storase oiles t.1E-04 t.7E-04 t.7E-O4 2.48+02
Secondary crusher'6.5E-04 6.5E-04 6.5E-0.1 5.2E+00
Yellowcake
scrubber
2.98-02 l.6E-03 6.28-05 0.0
Tailines svstem 1.38-02 2.0E-01 2.tE-Ot 8. lE+03
Source: FES Table 3.3
' Releases of other isotopes on the U-238 decay chain are included in the radiological impact analysis. [n the front-end of the Mill,
these releases are assumed to be identical to those presented here for parent isotopes. For instance, the release rate of U-234 is
taken to be equal to that for U-238. The Mill process separates uranium from the tailings. Thus, the product stream (i.e., the
yellowcake stream) contains most of the uranium, while the tailings contain relatively little uranium but most of the other
radionuclides in the U-238 decay chain
' The Blanding Ore Crusher was utilized in corurection with the ore buying station which was located on what became the Mill's ore
pad. This ore crusher ceased operations in 1982, and is no longer in operation.3 The Secondary Crusher is the Mill's semi-autogenOus grinding (SAC) mill, which is used for cnrshing conventional ores.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
66
t
I
ni
c
j
cId3
j
ri
P
p
g
t
E
E
P5
3
i;
oF.
bu
Es.L
aJ
g3*fHa<lu5
=fi-uJ9;rLiLkwzttoutFJ
Denison Mines (USA) Corp.
Figure 3.13-1 Source of airbome
radioactive effluents from the Milland
exposure pathways to humans
3.13.2.3 Radiation Doses to Individual Members of the Public
At the time of the FES, the nearest resident lived approximately 2.8 miles north-northeast of the
Mill building, near the location of air monitoring station BHV-2 (See Figure 3.3-2). A mobile
home about 2.0 miles north of the Mill was occupied until just prior to the time of the FES.
Currently, the nearest resident is approximately 1.6 miles north of the Mill, just north the
location of air monitoring station BHV-1 (See Figure 3.3-2). BHV-1, which is located 1.2 miles
north of the Mill, is the location of the "nearest potential residence" identified by NRC staff at
the time of the FES and was included in the FES radiological assessment. BHV-I remains the
location of the nearest potential resident (Note that, in this ER, the people who live at the nearest
residence are sometimes referred to as the nearest receptor(s).)
The nearest potential residence evaluated in the FES, and the actual current nearest residence, is
along the northern border of the site, about 1.2 miles and 1.6 miles respectively, from the Mill
building. All other lands abutting the Mill site to the east, south, and west are the property of the
licensee, or the U.S. Bureau of Land Management. The area immediately to the north of the Mill
site, the current location of the nearest residence, is used for the grazing of meat animals (beef.)
It is assumed that meat animals could be grazed along the northern site boundary and eaten by
the nearest actual residents. The calculated ingestion doses for consumption of beef grazed at
this location are comparable to those calculated for other locations around the site at which
grazing could be expected to occur (FES, Section 4.7.3).
Tables 3.13-3 and 3.13-4 present a summary of the individual dose commitments reported in the
FES for the nearest actual residence at the time of the FES and the nearest potential residence,
respectively. These calculations were performed by NRC staff at the time of the FES assuming
the Mill was operating at 2,000 tons of conventionally mined ore per day. For details of the
radiological assessment methods used by NRC see Appendix D to the FES. In brief, NRC used
an NRC-modified version of the UDAD Code, the predecessor to the MILDOS Code.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
68
Table 3.13-3
Comparison of FES Modeled Dose Commitments to Then Applicable Radiation Protection
Standards at the Nearest Actual Residence at the Time of the FES
(2.8 Miles North-Northeast)
NRC reeulation at Time of FES (10CFR Part 20)
Organ Estimated Dose
(mrem/vr)
Applicable Limit
(mrem/yr)
Fraction of Limit
Total bodv 2.4 500 0.005
Bone r6 3000 0.005
Lung 3.2 ls00 0.002
Bronchial eoithelium 0.00015 wL'0.033 wL'0.005
Then Proposed EPA standard (40 CFR Part 190)2 '
Organ Estimated Dose
(mrem/yr)
Applicable Limit
(mrem/yr)
Fraction of Limit
Total bodv 1.4 25 0.06
Bone l5 25 0.60
Lung 2.2 25 0.09
Bronchial epithelium l9 Not Limited
Source: FES Table 4
I Radiation standards for exposure to Rn-222 and its short-lived daughters are expressed in terms of working level (WL)
concentrations. OneWListheamountof anycombinationof short-livedradioactivedaughters of Rn-222 in I literof airthatwill
release I .38+05 MeV of alpha energy during their decay to Pb-2 I 0.2 Doses computed for evaluation ofcompliance with 40 CFR Part 190 are less than total doses because dose contribution fromRn*222
released from the site, and any radioactive daughters that grow in from released Rn-222 have been eliminated. Limits in 40 CFR Part
190 do not apply to Rn-222 or its radioactive daughters.
Table 3.134
Comparison of Annual Dose Commitments to Nearest Potential (Actual Current)
Residence (1.2 Miles North) at time of FES as Modeled in the FES
With Applicable Radiation Protection Standards
Source: FES Table 4.8
Radiation standards for exposure to Rn*222 and its short-lived daughters are expressed in terms of working level (WL)
concentrations. One WL is the amount of any combination of short-lived radioactive daughters of Rn-222 in I liter of air that will
release I .3E+05 MeV of alpha energy during their decay to Pb-210.
Doses computed for evaluation of compliance with 40 CFR Part 190 are less than total doses because dose contribution from Rn-222
released from the site, and any radioactive daughters that grow in from released Rn-222 have been eliminated. Limits in 40 CFR Part
I 90 do not apply to Rn-222 or its radioactive daughters.
Denison Mines (USA) Cory., White Mesa Mill, Environmental Report, February 28,2001
NRC resulation at Time of FES (10CER Part 20)
Organ Estimated Dose,,: r-.bili.)Applicable l,imit. r
(mrern/vrl ..-.'-
Total bodv 5.8 500 0_01
Bone 32 3,000 0.01
Lung 9.8 I,500 0.007
Bronchial epithelium 0.00036 wL'0.0033wL'0.01
Then Fronosed EPA standard (40 CER Part 19Dz
Orgail . Estiniated Dose
fmrem/vr)
Applicable timit:.(l6psirlva) ;
Fractlonof Limit
Total bodv 2.5 25 0.1
Bone 29 25 1.2
Lung 6.5 25 0.30
Bronchial eoithelium '78 Not Limited
69
The doses to individuals, predicted by NRC staff, as set out in Tables 3.13-3 and 3.13-4 were
calculated for inhalation, extemal exposure to air and ground concentrations, and the ingestion of
vegetables and meat. The dose conversion factors, used to convert intake of radioactivity taken
into the body by inhalation or ingestion, to dose, actually represent the entire dose received by
that individual over the fifty years following the actual intake. This dose is referred to as
committed dose, or fifty-year dose commitment. The extemal dose conversion factors used by
NRC staff assumed that the residents spent 1007o of their time at the residence and were indoors
14 hours per day exposed to an external dose rate of 70Vo of the outdoor dose rate. This factor is
intended to correct for the shielding from external gamma radiation provided by the residence.
It should be noted that the radiation dose limits for members of the public have changed since the
time the FES was proposed. Since that time, NRC, in l0 CFR Part 20, has adopted an annual
dose limit of 100 ruem total effective dose equivalent (TEDE) for members of the public which
takes into account the radiation dose from both internal and external sources for doses
attributable to licensed operations. Doses from natural background or medical radiation are
excluded. This standard has been adopted by the State in R313-15-301(1)(a).
NRC concluded that all of the radiation doses estimated to the public from future operations at
the Mill would be a small fraction of the then existing NRC limits.
In addition, NRC staff also compared their predicted doses to then proposed revised EPA's 40
CFR Part 190 limits, which became effective in December 1980 (and now required under 10
CFR 20.1301 (d)) and which included an annual dose equivalent limit of 25 mrem (exclusive of
radon), which applies today. NRC staff concluded that the predicted annual dose equivalent
dose to a receptor at either the then existing nearest residence or the potential nearest residence,
would still have been a small fraction of the EPA's then proposed 25 mrem/yr dose limit. For a
Mill operator, the FES indicated that the predicted dose commitment to the bone could exceed
EPA's current standard of 25 mrem/yr, and recommended monitoring and if necessary, dust
control programs for the Mill operator to ensure that this standard was satisfied in practice. This
monitoring and procedures are in place.
In addition to these regulatory requirements, the Mill uses, to the extent practicable, procedures
and engineering controls, based upon sound radiation protection principles, to achieve
occupational doses and doses to members of the public as low as reasonably achievable
("ALARA"). The ALARA goals set by the Mill are intended to result in lower occupational
doses and doses to members of the public than permitted under applicable regulatory standards.
3.I3.2.4 Radiation dose commitments to populations
In estimating the potential dose to the population living within a 50 mile radius of the Mill, NRC
staff considered the nearby population groups, including the community of White Mesa and the
city of Blanding.
The FES also estimated annual doses to the projected population living within 50 miles of the
Mill, as shown in Table 3-13-5, along with estimated annual doses to the same population from
natural background radiation sources.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
70
Table 3.13-5
FES Annual Population Dose Commitments Within 50 Miles of the Mill
Pooulation doses (oerson-rerns/vear')
Orsan MillOperations Natural Backsroundo
Total body 3.4 7,500
Bone 6.4 7,500
Luns 7.1 7^500
Bronchial eoithelium t32 23,000
Source: FES Table 4.7I Based on a projected year-2000 population of46,500.2 The natural background dose rate to the whole body was estimated in the FES to be 16l mrem/yr. The bronchial epithelium dose from
naturally occurring Rn-222 was assumed in the FES to be 500 mrem/yr. See FES Section 2.10. This methodology is somewhat
different than the more current methodology for calculating background radiation, as discussed in Section 3. I 3. I .
In reality, this population dose is likely to be over-estimated as the population within the 50 mile
radius has not in fact achieved the levels forecasted in the FES. For example, the FES reports the
1977 population of San Juan County to be about 13,000 and projects a 2000 population ofabout
33,000 (Section 2.4.1) while the actual population of San Juan County in 2000 is about 14,400
(Source: www.factfinder.census.qov). Similarly, the current population within 50 miles (80 km)
of the Mill is about 24,544, about half that assumed by NRC for its assessment of population
dose commitments in the FES. In any event, NRC staff indicated in the FES that the population
dose resulting from the operation of the Mill represents less than l%o of the doses from natural
background sources.
3.1 3.2.s Radiation Dose From Ore and Uranium Concentrate Transportation
Ore is transported from the mines in tarp-covered dump trucks of 25-ton capacity. The
shipments are in accordance with the requirements of the Department of Transportation (49
CFR). The ore is not heaped in the truck beds but is evenly distributed to prevent load shifting
and ore spillage during transportation. The use of a canvas cover secured over the truck bed
minimizes dust loss during haulage (1978 ER, p 3-30).
The uranium concentrate (yellowcake) is transported by truck in 55-gal drums. Each uranium
shipment was estimated by NRC to result in an extemal radiation dose to an individual of 2
mRftrr at any edge of the truckbed (FES Section 3.2.4.8), which is considered to be insignificant.
The FES concluded that, under normal operating conditions, no significant release of radioactive
particulates would occur. Therefore, there would be no significant dose to the public from
transportation of ore to the Mill or the transportation of yellowcake from the Mill, under normal
operations.
3.13.2.6 Evaluations of Radiological Impacts From the Licensed Mill Operations
As noted in Section 4.7.5 of the FES, all radiation doses calculated for nearby residents from
uranium milling operations at the Mill site are small fractions of those arising from naturally
occurring background radiation. They are also small when compared to the average medical and
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
7t
dental x-ray exposures currently being received by the public for diagnostic purposes. Further,
as noted in Section 3.13.1.3, NRC concluded in the FES that all of the radiation doses to the
public from future operations at the Mill would be a small fraction of the then existing NRC
limits.
In the period after the FES, NRC carried out a detailed evaluation of a generic mill (GEIS 1981)
using dose calculation methods that had been updated since the FES was prepared. One outcome
of the GEIS, was the development of the MILDOS code for estimating environmental radiation
doses from uranium recovery operations (Strenge and Bender 1981). Since that time, the
MILDOS code has continued to evolve as the science of dose estimation evolved. The most
recent version of MILDOS is MILDOS AREA (Argonne 1998), which is routinely used for NRC
regulatory purposes and has also been used in this assessment. tn looking at the results for
subsequent MILDOS runs carried out with the MILDOS and MILDOS AREA codes, it should
be remembered that the dose calculation methodology has evolved between 1979 and the various
versions of the MILDOS and MILDOS AREA codes that have evolved since then, and
consequently the results of MILDOS runs with the various models will be different even for the
same model inputs.
Subsequent dose modeling using NRC's MILDOS code was performed in 1991 for Umetco, a
previous operator of the Mill, in support of the Mill's 1997 license renewal (Enecotech 1991).
The modeling performed for Umetco assumed the maximal conditions shown below:
. 730,000 tons of ore per year (average of 2,147 tons per day),r ilversge grade of 0.537o U:Os,o &ver&Be uranium recovery of 94Vo,. operating24hrlday for 340 days per year,. 15 years ofproject life, and,. a yellowcake production of 4,380 tons of U3Os per year (8.8 million lb/yr).
By comparison, the dose calculations reported in the FES were for an average ore grade of
O.lSVo U3Os and an annual yellowcake production of about 863 tons of U3Os. See FES, Table
3.2.
The 1991 EnecoTech MILDOS analysis was updatedin2OOT using MILDOS AREA for this ER
and using similar but updated input parameters. More specifically, and separate from the
differing model codes, for the purposes of this ER full-capacity production at the Mill was
considered under two ore processing scenarios, Arizona Strip ores (Upper Bound) and Colorado
Plateau ores (Lower Bound). (Appendix C, Dose Assessment for License Renewal Application &
Environmental Report, SENES, 2007). While the Mill is capable of operating at these
maximized rates, it should be noted that the Mill has never operated at these levels (See Table
3.11-1, page 3-31 of this ER). Accordingly, actual production may be less than that modeled
under these assumptions, resulting in a conservative review of potential dose to members of the
public for this ER.
From the analysis described in the FES, assuming a total population of 46,500 within a 50 mile
radius of the Mill, NRC staff predicted an annual population dose of about 3.4 person-rem. In
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
72
the l99l re-analysis performed by Enecotech using an updated model (MILDOS) developed by
NRC for this specific type of application, and assuming a much higher ore grade and quantity of
yellowcake produced, a population dose of about 2.4 person-rems per year was estimated for a
population of about 9,000 assumed to live within 50 miles (80 km) of the Mill.
In addition to the population dose, the MILDOS code also calculates the concentrations of
radioactive dust and radon at individual receptor locations around the Mill. The MILDOS code
then compares these predicted concentrations to reference concentrations (referred to as
maximum permissible concentrations; MPC's.) For the then nearest residence (located 2.8 miles
north-northeast of the Mill), the l99I EnecoTech MILDOS analysis concluded that the
combined ratios of predicted air concentrations (that is concentrations of U-238,U-234,Th-230,
Ra-226, Pb-210 and Rn-222 and decay products to the corresponding NRC MPC, and the
estimated whole body dose was 8.2E-02 mrem, is more than 100 times smaller than the
allowable total.
The MILDOS Code also calculated the 40 CFR.190 total body dose (which excludes radon).
The FES reported 40 CFR 190 total body doses for people living at both the then nearest actual
residence (2.8 miles north-northeast of the Mill) and for the nearest potential residence about 1.2
miles north of the Mill. These results, as well as the 1991 EnecoTech MILDOS and 2007
MILDOS AREA results are summarized in Table 3.13-6. Not surprisingly, the highest doses are
predicted for the potential nearest resident with other, further away, receptors receiving lower
doses. It is important to note however, that all of the doses are below regulatory levels of 25
rnrem per year and small compared to the dose from natural background radiation (See Section
3.13.1). For reasons given earlier, as a result of the numerous changes to the dose calculation
methodology in the intervening period, the direct comparison of the doses is of limited use.
Nonetheless, it is worth noting that the 2007 MILDOS AREA modeling predicted that, except
for the nearest resident estimated by the FES, doses are larger than those reported in the FES and
by EnecoTech and should be considered as the current bound on potential doses arising from the
processing of conventionally mined ores.
The production scenarios formulating the basis of this 2007 ER update included the following
production considerations :
Arizona Strip Ore. 730,000 tons of ore per year (average of 2,000 tons per day),o &versge grade of 0.64 Vo U:Os,r oversg€ uranium recovery of94Vo,. operating24hrlday for 365 days per year, ando yellowcake production of 4,380 tons of U3Os per year (8.8 million lb/yr).
Colorado Plateau Ore. 730,000 tons of ore per year (average of 2,000 tons per day),o BvefoS€ grade of 0.25Vo U:Os, l.50%o YzOso over&Be uranium recovery of94Vo,. operating24hr/day for 365 days per year, ando yellowcake production of 1,731 tons of U3Os per year (3.5 million lb/yr).
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
't3
Based on these production rates, the 2007 MILDOS AREA modeling projected dose to varying
locations, including the nearest resident and the nearest potential resident. The results of the
modeled doses, compared to earlier assessments are provided in Table 3.13-6:
Table 3.13-6
MILDOS AREA Total Effective Dose Equivalent Calculations (Excluding Radon)
(40CFR190 Annual Dose Commitments Adult, mrem/yr)
Update of l99l EnecoTech Run
Source: Appendix CI Dose calculation methods changed between 1979 and l99l and therefore, the results from the FES and the l99l EnecoTech analyses
may not be directly comparable.2 The FES provides 40 CFR 190 dose estimates only for the nearest and potential nearest (now actual nearest) receptors.' The updated analyses were done using the MILDOS AREA Code which was updated from the earlier MILDOS Code used by
EnecoTech. Thus, the results of the two Codes are presented for historical context and doses estimated with the two Codes are not
directly comparable.
The results of the 2007 MILDOS AREA modeling (See Appendix C, Dose Assessment in
Support of the License Renewal Application & Environmental Report for the White Mesa Mill,
SENES Consultants Limited,2007) demonstrate that the Mill will remain in compliance with the
dose limitations to members of the public under either of the conventional ore processing
scenarios. As mentioned above, the Mill must comply with three separate standards with respect
to public dose. First, the dose to any member of the public (UDEQ-R313-15-301(1)(a)) must not
exceed 100 mrem/yr (including radon). Next, the dose to the nearest resident (EPA-40 Cm 190)
must not exceed 25 mrern/yr to any organ (including the whole body as an organ). Finally, the
Total Effective Dose Equivalent (TEDE), excluding radon to any member of the public cannot
exceed 10 mrem/yr as an ALARA constraint limitation (UDEQ-R313-15-101(4)). In this regard,
the Milling of either Arizona Strip or Colorado Plateau ores, at the rates and grades specified
above, were well within these limits. The results of the 2007 MILDOS AREA TEDE dose
estimations including and excluding radon for the nearest resident, the nearest potential resident
(BHV-1), the City of Blanding, and the White Mesa Ute Community are present in Tables 3.13-7
through 3.13-10 below. With respect to the limit for individual organs to members of the public,
the largest dose projected was at the BHV-I location whereby the bone dose to the teenager is
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
74
Receptor Location FES Doses
Dose (mrem/yr)I'
1991 EnecoTech
Doses
Dose (mrem/yr)
2007 Updated,
Doses
Dose (mrem/yr)3
Arizbna
Strip
Colorado
Plateau
Nearest Potential Resident
GHV-1, 1.2 mi N of Mill)2.5 0.42 0.16 0.15
Current Actual Resident
(1.6 Mi N of Mill)0.09 0.09
FES Nearest Resident
(2.8 miNNE of Mill)1.4 0.08
Blanding
(6 mi NNE of Mill)NA 0.02 0.01 0.01
White Mesa Community
(5 mi SE of Mill)NA 0.05 0.01 0.0r
estimated 1.17 mrem/yr (4.77o of the limit) for the Arizona Strip ore scenario. The largest dose
to the bronchi, across all age categories, is estimated at 1.05 mrem/yr (4.2Vo of the limit) for the
Colorado Plateau scenario.
Table 3.13-7
2007 Arizona Strip Ore TEDE (mrem/yr)
(100 mrem Limit to any member of the Public, Including Radon)
Table 3.13-8
2007 Colorado Plateau Ore TEDE (mrem/yr)
(100 mrem Limit to any member of the Public,Including Radon)
Table 3.13-9
2OO7 Arizona Strip Ore TEDE (mrem/yr)
(10 mrem Constraint Limit to any member of the Public, Excluding Radon)
Table 3.13-10
2007 Colorado Plateau Ore TEDE (mrem/yr)
(10 mrem Constraint Limit to any member of the Public, Excluding Radon)
Receptor Location Estimated Dose (mrem/vr) bv Ase Catesorv
Infant Child Teenager Adult
Nearest Potential Resident (BHV- I )2.94 2.15 2.25 1.97
Nearest Actual Resident r.83 l,31 1.43 1.27
Blandine 0.19 0. r6 0.16 0.15
White Mesa Ute Community 0.39 0.34 0.35 0_33
Estimated Dose (mrenr/vr) bV Ape Catesorv
Infant Child 'TeenCser Adult
Nearest Potential Resident ( BHV- I 1.20 0.89 0.93 o.20
Nearest Actual Resident 0.15 0.58 0.60 0.54
Blanding 0.08 0.07 o.o7 0.07
White Mesa Ute Communitv 0.18 0.16 0.16 0.r5
Receptor Location Estimated Dose (mrem/vr) bv Ase Catesorv
Infant child Teeriaser Adult
Nearest Potential Resident (BHV-l 1.37 0.57 0.61 0.39
Nearest Actual Resident 0.79 0.33 0.39 o.23
Blandins 0.05 0.02 0.02 0.01
White Mesa Ute Communitv 0.08 0.03 0.03 0.02
Receptor Location Bstimated Dose (mrem/vr) bi Aie Cateeory
Infant chitd Teeriaser Adult
Nearest Potential Resident GHV-l 0.54 0.22 0.26 0.16
Nearest Actual Resident 0.31 0.13 0.15 0.09
Blandine o.02 0.01 0.01 0.01
White Mesa Ute Communitv 0.03 0.0r 0.01 0.01
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
15
The
and
3.13.2.7 Operational Environmental Monitoring Data
has established monitoring programs to evaluate compliance with effluent limitations
to assess the potential for release of radioactive material into the local environment. These
monitoring programs were developed and implemented at the time of Mill construction, operated
with appropriate adaptation over time, and remain consistent with the Mill's Radioactive
Materials License and guidelines developed by the NRC (U.S.N.R.C. Regulatory Guide 4.14,
Radiological Effiuent and Environmental Monitoring at Uranium Mills-Rev.1, 1980). Standard
Operating Procedures (SOP's) for these monitoring activities are discussed in Section 6.5 of the
Application, and the Environmental Protection Manual containing the SOP's has been attached
as Appendix A to the Application.
In accordance with its environmental monitoring program, the Mill monitors various
environmental media and conditions near the facility. For the purposes of this ER, the data
obtained over time from each of these measurement programs can be utilized to assess
compliance with regulatory requirements, and as a resource to evaluate overall impact resulting
from the operation. In this regard, the routine monitoring programs and locations listed in Table
13.13-8 below are employed by the Mill in accordance with its Environmental Protection Manual
(See Appendix A to the Application). For specific details as to Standard Operating Procedures
for sample collection activities, please refer to the Mill's Environmental Protection Manual
(attached as Appendix A to the Application).
Table 13.13-11
Environmental Media Monitoring
(Location and Frequency)
Frequency [,ocation
Airborne Particulate
8.
Radionuclide Concentrations
Continuous
Air Monitoring Stations:
-Sentinel Air Monitoring Stations North, East and South of the Mill
IBHV-l & BHV-2 (north), BHV-5 (east), and BHV-4 (south)I
-A background location distant to and west of the Mill (BHV-3)
-A station specifically requested by the White Mesa Ute
Community
south of the Mill Site (BHV-6)
External Gamma Radiation
Continuous
Measurements
Analyzed
Ouarterlv
Air Monitorins Stations:
-BHV-1, BHV-2, BHV-3, BHV-4, BHV-5 and BIIV-6
Vegetation Spring & Fall Three site periphery locations:
(NE, NW & SW of the Mill Site)
Stack Release Rates
&
Emission Radionuclide
Content
Quarterly
When
Operating
Point Emission Sources:
-Two Yellowcake Scrubbers
-One Yellowcake Baghouse
-One Vanadium Scrubber
Surface Water Quarterly
Surface Drainages:
-Cottonwood Creek
-Westwater Creek
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,200i
76
Media Monitored Frequency lncation
Groundwater Per GWDP
Requirements
Ouarterlv
-N{W-l I, MW-14, MW-26 and MW-32
Semi-annual
-vrw-1, Mw-18, Mw-19, Mw-2, Mw-3, Mw-5, MW-12 and
N[W-17
NewWells
-MW-3A, MW23, NN\r-24, MW-25, NNv-27, MW-28, NN{-29,
MW-30 and MW-31
Accelerated
-In addition to the routine quarterly and semi-annual monitoring
referred to above, Denison collects accelerated monthly and
quarterly
samplings at varying locations triggered for accelerated monitoring
under the conditions of the GWDE .
Soils l* & 3'u
Ouarters
Air Monitoring Stations:
-BHV-1, BHV-2, BHV-3, BHV-4, and BHV-5
Radon Emanation from
Tailins Cells Annually Tailings Beaches and Soil Cover over Tailings Beaches
a) AirborneRadionuclide Monitoring
Due to the nature of the uranium processing mill functions, dust generation and offsite transport
of particulate nuclides represents the exposure pathway which poses the greatest potential risk to
members of the public. ln order to assure compliance with the Effluent Concentration Limits
listed at l0 CFR 20, Appendix B (incorporated by reference into R313-15-302) requires that
uranium mills analyze particulate samples collected from the air monitoring stations for
suspended radionuclide content. Accordingly, the particulate monitoring program at the Mill
currently employs five high-volume continuous air monitoring stations. Four of the stations
(BHV-1, BHV-2, BHV-4, and BHV-5) are required by the Mill's Radioactive Materials License.
At the request of the White Mesa Ute Community, Denison also installed and operates a sixth
station (BHV-6). These sampling stations serve as sentinels for airborne particulate which could
potentially emanate from the Mill site. It should be noted that in addition to its general site
monitoring function, location BHV-I also serves as a conservative surrogate for concentrations
at the nearest resident. While not actually located at the residence (i.e. ll2 mile South) the
sampler provides a conservative estimate for the residence because it is located between the Mill
and that residence.
In addition to these monitoring stations the Mill has sampled and established an airbome
particulate nuclide background for the site. More specifically, the Mill previously operated an
additional sampling station (BHV-3) which was for background monitoring and was located
approximately 3.5 miles west of the Mill site. With the approval of the NRC and effective
November, 1995, this station (BHV-3) was removed from the active air monitoring program. At
that time, Denison proposed (and the NRC determined) that a sufficient air monitoring data base
had been compiled at station BHV-3, determining that the data were representative of
background radionuclide concentrations. It should be noted, however, that while air sampling
was discontinued at this location, gamma measurements and soil samples continue to be
collected at BHV-3.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
71
Airbome particulate monitors are operated continuously at each of the high-volume air sampling
stations referenced above. Particulate sample collection filters are gathered by site technicians
weekly in accordance with the Mill's environmental air sampling procedures and are composited
on a quarterly basis for laboratory analyses. The analytical parameters applied to the collected
filters are: Uranium-Natural activity, Thorium-230 activity, Radium-226 activity, and Lead-210
activity. In addition to the requisite nuclide determinations, particulate loading is determined for
each filter and composited as a quarterly mass-loading estimate for review purposes only (See
Section 3.3.2.3 above). The specific locations of the Mill's airborne particulate monitoring
stations are depicted on Figure 3.3-2.
In order to evaluate the concentrations and impact of radionuclides observed at the Mill's air
monitoring stations, a series of graphical illustrations was prepared. The graphs display reported
data over time since the 1981 inception of the Mill's environmental air monitoring program. It
should be noted that for graphical illustration purposes, values reported at zero, that is values
reported at less than the prescribed detection limit and missing values were plotted as I x 1016
prCi/ml concentrations, the general detection limit expressed by the data set. Where other "less
than" values were indicated (e.g. data where detection limits varied from 1 x 1016 pCi/ml) this
detection limit concentration was utilized for plotting the data point. The intent of this data
treatment convention was to provide a conservative viewable depiction of site airborne nuclide
information. The conservative nature of this format is founded on the fact that the actual
concentration below the detection limit cannot be determined and, as such, the plotted point is at
a higher concentration than the actual (unmeasured) activity concentration of the collected
sample. The graphs of air station radionuclide observations follow as figures 3.13-2 through
3.13-31.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
78
I<;
x
o
x
i.
L
f,
in
t]-1
Ii<
le<
a
sF\.-i<t*-
)>s-lH!tt trl
ii-g
L,
:-r-
E
iliiil
l1+i+i
H,i ,iffifif,r
zul
i5i r+4'frtiiii$i;$tt,
-r
I
I
I
I
lo<
I
Ia<
I
!
L
I
I
lo<
i!E',i)-;1fiHTF
It,ti
I
ll
lt
I
fii{iltt
It
#i-i
(}
ffi
ffir,*
hi
H
tsri-,
iii+ilrr t
Itl
JrrrltttLltllI tt
ltlt
lrrr r
s
)
a
l(
|##ilrtrY I*+i.i. i
ffiT
p,
,'ii{rrl!.Il) rlttttt,,,,,lr,,Itrrrtlll
1,,,,,iltttt
ltltrl
,?:t
,E ffiy-!{t,
rts-altt
llrFd-
H
=
1ilii li.+r Htrl.\L*
wtr
=Eo
oE,.9
G<rEdro
-()dEE()
=o.o1plrE
EoE(!E,
I
Eo
@
UJoq
t\
u.loq
(o
UJoq
s
IUoq
ir)
uloq
(etecS 6ot)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
79
:E
C'
=oE.o
GI(r)€-.i, o
c?6E()
E' (Etr.4
E
.E
(!
I
-o
E-o!=L:T EcnLU =--o'=(2uJ.95SilE5H;sfrEEKEo
=<ri==8 rPt
E 3=iOCD+*EtrEEE{ o o,
LrJ < O- O-
-f Lal
ul uloooo--(atecS 6ot)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W7
80
=E
C)
otr.9
(g
TE(r:, oF(,c|t!E6e8Eqr
E
=otF
I
o
_E()==T E()llJ :> =N O*r =F.=F:[lE S,,', ot
=QH ttE; rr IEi.EO
Err,J*I ilPt
5 8=dO(5.a+
E#EEE{orc,gJLLru<Lo-
sl lnii
==(elecg 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2A07
8l
-E-\()3
otr.9
tEurts..i 5-(,G:tEE6
.g)xll. cy
E
EtsE,
a
o
_E()
T -EOLll ,= =oEYco=3sl5;*3sflEE&E<cEoi=*8 rPt
53=do(r<s
5#pEdl e eUJ<(L(L
!+ rr)
'it Lirooqq
(e;ecg 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
82
=E
q)
=otro
(oFco=-ts(l)()E5=o.9olL-6tI!l(E
G,J
I
@
Eo==
T -EOLrJ ,= =@_Y<uI E^,7,_=>-ul.E\<lx-J;$ [E{JEt6HE(,E-:<ElpE5 3={O(5s<-
E#EEE{ or o!JL![rJ<(LL
90-dos
90-das
t0-dos
80-d0s
z0-d0s
t0-dos
00-das
66-daS
86-daS
/6-dos
96-doS
96-daS
,6-dos
e6-dos
z6-dos
t6-das
06-dos
68-daS
88-doS
/8-d0s
98-deS
98-doS
,8-dos
88-doS
z8-das
t 8-das
utoq
(\l
UJoq
lr)
lUoo
*
t!oo
C')
uloo-
(o
UJoq
o
uJoo
t-
UJoqr
(etecS 6ot)
I
l
l
l
)c
t
x
x
,t
L
,h
i14T.
i<ra<
(
(}
.f
sBx|-
I(
trf,Sq
', trl
i.t-ff\-r
"*
E
iii i
iiiilttt
l.H
ffi(Fi
ih!"
'b+Ii
l$+),
IHrrr{w
mkirt
TH
ilttl+1ni
#iilrtrlt
m+
tii
l(
I
L-
.iI l-l
iltlll
I
il
rl
lr
ii
?,ItIt
tlt
tll
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2Q07
83
|r,
t!oo'.(e1ecA 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
84
o
Y"""
"#"
"l'"*
'#"
:a
:;a
ju,
'l''"o
,t
ia
fi
"", r""
oo"
oE.9
(E
Eo(,@Ecb,Q
cd-esAeET E
!J- .=E(E
=6la
o
SE=o.if- =T Ec.rtll >-o, E (2 [.uJ5dfrEiHI
E,jr J I
- 6'= rfi(ENEV
=c.i==8 "9t5 8=do(9<sE#PEP{oo+JLLru<o-o-
o
-l ro
I'J TI.J8E
(atecS 6ot)
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
85
Iilit
illl
I
r
l.
rx
a
x
:
:
d)
,
l
\
\
't/
>a
,t
It]
i+lJl r
iiil
lI tt?ttal
ill}*i
ilt,iiiT
l.g
ffi
tltlD'
il
\
If
I
5
Lr
'
Ll-{
a
iior
I
)<
llltr)aq
l.*rlll
N
I
t4L
ilr,er'-
#7ir-r,,tt t
ir,*-|.-i+<iii*,r(
'r', ))11H..
arltll
ii;i; i i\i->
rttt t t illftttt vJfr{ft r
!L!L, I L
:E(,
=E.9
(E
CDEc,l, e
cooq'C'
EE*E
'=osF
C\Ia
-@
o
o sO==$ _ST EOLUI>f<\I O+r =-.= F; LlJE< ' N!9H.ttb.o " 3EI E<c
=6=S8 rPt53=?(J(5++
E#EEE5 e e[!<Lr
@
uloq
t\
u.loq
(o
uloq
st rr,
ul rrJooqq
(etecS 6ot)
cf)
L!o6-
<\!
[!oquloq
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
86
:E
c)
=oco
6
Eo(,Go(J
(0GI(\t
aE.=
=tTEE,6ta
-@
sO=Eo -!f s.lOrEYc'rJEstE;*T
e.lld€Ht8Ec.i=3;8 il9i58=dO(5+*
E#PE€5 e euJ<oL
TTUJ UJEE
(etecS 6ot)
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
87
a
il
lt
iis
I
ltililtl
!
o
I
I
p
I>
I
Et'a
1,<
a
.f]IBl}-i<Et>-t,,(,#
lieft/'tfi\
llt r
iiili+(
Hi,:fr
,Hi
H F
illtlt*1f
a
I
lt
I
4
I -
ii
il
il
tl
l
rut,\_9
rlr tl
ltilt
?r(fr
i,ilt
milllt
)rl
l!
tl
U
il
lt
trtt
tlli
rttltt
L
I
-a
*frl{lrf1
:Eo
oE.9
F(E
CDE
-Oartq,c)
=().EP OrrE
aE'TEo
(\a
a
m
Ea
6 --ET --EOttlr-=@_Yc.r
'tcE-rHi =9 rr-:(rJ'-L - ll (O'.Y Lu = ,9!6ir)Ev
=.-: ]<ErpE3 3=iC)(5s*5#EEEi e etl.l<a-(L
o
C'
tiJoq
t\
UJ
E
(o
UJoq
-t tr,
r! uJoooo-;(elecg 6o1)
cr)
UJ
E
N
r.!oq]'Joo-
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
88
c6,..,%
ua.,%
eOZOn
6..,h
% trlt-crtIrLloa. It I'% l;l
oezo,-
lt I
% lEl(p. l+I'% ltl14l
%El
*..,4r,
%
:E()
=oE.9
6c.r E+E
cDo6;O
Er.=lt !l
c,.9E6Ec2a
-o
*..,%
J
"07%
n
t.ue
(agecg 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
89
96,..,h
%
eolo?
%
tOZOr.
oa.,%
%rn7
oa.?
%
%
*..,h
'a.?
*rn
%
tOZOr.
-E=o
=
artc,.9r!oats
-E6iE
(r)0oO
6; .trtr=E
.E
(lt
=CDa
-@
E()€=tJ<f-=T EcvLU>f-o'=9ul
," =.d R.=v-5iH,'
Es+.qEc\I .EYEc!J=8 ilPt
5 3=iO(9+<E#EEE{ or o.l+JLLut<o-o-
@
UJoq
F
LrJoq
trr,
LU LUooqq
(agecg 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
90
96'.-
63:
"r?,;31
or:?
qi!"
*a?,,?
/a?
ooi!,
,;:a
,"::"
,i!r
""?
";:a{/6(O.-?
<e.?
""?gc.?
*f:
9o.?
toi.e,',?
eoin,
6::."?
ce.?,"?,%
:E=C'
oEo
6qtsFC6bg'. c6aooO
.E,e*e
'=oEF
GEa
E
_€O=ET EC)Llt :> =6I !2 -tll +r
-E:LUE -<,.,, NJ\16 llE'i "EEI EoEroJS8 rPiE8=iO(5++E#EEEJ E EuJ<o-tL
@
TUoq
t\
rUoq
(O
[!oq
$rr)
UJ UJooqq
(elecg 6o1)
(f,
uloq
6r
LtJoquJoo;
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
9l
8'.-
^ '/l"a-
"r?
'an,,:?
h '/1"d..
*
-s 'r.'d..,,?//,1o-?
,,?
/Aoa?
%::-//,
%-"
"r?
";::{/6(A',
a;::
*ca?
*f:s:
"t?,an
,n:%
6!:
*ca,
ar?,%
=E.\(J
=o
=o
6r{,E
6Do
-Oci5
EC)
=(0C'I NiE$
E
E(EE
c:'I
-o
Eo==(o-..-LT -EoUJ;==orEYc"trr \i-.=olOE =,.,, rr)
=<oH rr
SLtr rr IER'E<c
=c.i =S8 "Pt6 B><O(5ss5#EpEiEEuJ<(L(L
@
[rJoc
t.
trloqTUoq
(o
UJoq
$ro
uJ uroo<?q
FF
(e1ecg 6o1)
(t,
LrJoq
AI
UJoq
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
92
9O,yOr.
%
oozo..
+..t2r-
(a.
'%
%
%zo.-,
oa.
*rn
%
s..t4/,
%
%yo..
zeyot
%
=E.\c)
oE
.9oE
(aE
-O.''Eoo
=()C" C'iEp
I!tGa,J
e:)I
@
_EO=E(o -+5 €OLU:i=<o-Yc.tII E:T.=-\-ulEt2,r,-rJ+ ',b:I8pU'=.i(uro Ev
=;=<ElpE5 8=iO(5.+<
E#PE#i e eI.U<CL
@
UJ
E
t*
u,!JI-
(o
u,
e
tlr,
LU r.rJEE
FF
(elecg 6o1)
(f)
UJaI-
6lF
uJ
E
uJoo-
il
a-il
itlt
I
I
lt
itltlllt
l
lt
IrI
tl
tiIl
,t
b
I
I
I
I
,rr
,fi\
,(,P
P'-*
$.-i'1
iLilff,I\'.1
]\,iitt'r t'r-
iLilir
'<"/H
"{Iit'
t-
ti{lilllittt
Itt
Irt
iiN
DL
lxL
r
,ll
ll
ll
It
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
93
,a
aI
ii\.f|\,\ii<
rr(
ii'
+d-r tli<-rra.*
€
)4
]:*Gl?*Th
ir<i.i<.#itsfr
t+iiili
!iiii ili-*{
)|,ttttl I'il+r r
Eg,i
i1?.i++..1ffi-l
t't*i
ttit t
i+f ll Itfil ll,,ai!:
il'ii| i ir'{,r'fr,)
<F
ai<r
tr<
I
I<r---
I
I
I+--
E,IrtlrrrHftHH
t
I
I
+
a
a
rat
*il
g-!t---
tr
li (
a<
I.<
lry
l4illtfi
,FiGt!t<
ii*z#*:/f-?E-'_-1*l
#h"
H*
Hiru
.i
I
I
I
I
I
I
I
lar:l $!I L
ffiffi
l]!k rs-
'ri#B F 7
o
E=C'
=oE.9
(EL
ciE
cDoo()!oE'.!iiEE
JE.9!,.oE<fI
-E
o
@
LUoo-
t.
[!oo-
(o
t!oo-
=t
uJoq
(Y)
uloq
(\I
LlJoq
r,)
IIJoq
(a1ecg 6o1)
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
94
%
"#"
"o:",
il
il
lr
l
c
i.<a<.
e
<}
N}i\tlt,e(rlt
iiit i ir
illtt t
l'i'it i
.,--4ftff,"b\
il;lil
Hr
).I\i\tl
ri
lt
{a.>J-
{\t\
I
I
I
I
I
I+-
ll
il
il
lt
lr
l
tl
I
il
lllr
)l
#a
)F{{
lil rt
tilii I
*r1
a
il
I
ltl
tl
I
I
lttl
ll
lllt
llI
lr
ltillllt
LI
rfr
!)!u
r ill
ltttttItt
t,lJ.I
;_
ii!Ilt
tltlIL
tl
C<ttllE1tfrlt
tt
Ilt+a
/
3I
I
lt
il
l
il
I
I
I
Ilil
lt
illt
1l
>r+ffi#'a
Hi
),, tffi'
ilr !FtiliF'WH
ffitr*a r
liltl t liTiiTr-atttl,11
=E
-\C)
=oEo
.EoE.i8
c,oEq
6t -E'tr i.E
=E(U
=tfI
o
E-=o€=os_=T Ecvl.IJ l>FO,EQLu
', ;.i R.=v-
!sfr tt
SLti rr I-EKE(,
=cri =*8 ilPt58=iO(9ss
E#pp€1eeIJJ<(LO-
@
uloqIUoq
t-
trJoq
(o
t!oq
sro
ul uJooqe
FF
(elecg 6o1)
(t,
u,oq
ot
[!oq
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
95
*"
fi
jo,
;q
E.\o
otro
(EorEr.Ecr, 9l
caoo()L^
.i,F*E
'trogFaI
o
_€o)cs\i _Eg(\r Orrr=Fr,-+.= F: LUE S,,', c!l(26 ttE;iE'EF'=rF
EH5;8 ilPi
5 8=iO(5ss
5#EEE{ o or!JLL[!<(L(L
$loFFtu ulooqq
(agecg 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W7
96
?o,,
:;a
rfi
#
fih'h
=E.\o
otr
.9
tERE6aO
-9r', 5Eo
=@Er (\l
iE qt
E
.=t,Etr,
T
o
E*\o
T -Ei5Ul ;i=orEYc'>IS:Y
=olruE r,.', ro
=coft tr5ri8EE'E<c
ENJ=8 r9t
5 8=iO(9sr
=zo)6br9P3{ o q)!JLLUJ<(L(L
o
@
UJoq
i-
uJoq
(O
UJoe
N
UJoq
str)F-tIJ TUoocqF
(e;ecg 6o1)
(Y)
uloq
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2N'7
97
;.
i
a
'
i\=r-\i<
a
{a?>Ba.-jl
\r:r-T-1
K
o<-),/E
I
lirl--iw#,
Hri
iffilffiIil
&"tt.Jt
*it I
,b, Irl
'r
r
,.h iHiiliir'lsL-JE+
ail
.trIr
ll
U
TT]slt
ral rrtkflnI
+i+iiltl
iltlilt!
Utllttiltt
rlJ.l J-r a
a
=E.\oa
at,E.9FE(,:IE
-OaiEgro
=c).91 oLF
a!,(Eo
-la
o
sOJco -S.; .EC'Ulli=o-Hcvil E:'i.= -\ - t.UE (2.r, -: -= il
E- ll (U!2.J.- O6H'E<c
=-J<(E ilgt58=d(J(5s*
E#EP€5 e ellJ < o- o-
o
@
r!oq
F.
UJoq
(o
trJoq
$lr)
rir r.irooqq
(elecg 6o1)
(f)
Llloq
C\T
lnoquJoq
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W7
98
,#
ia
=E.\()
oE
.9
(uorENE.iE
c)oo()IoE).:,iEE
=E
.oE(EEtoI
-E
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
99
#
ia
=E.\o
otro
(E(D.tsrE,*G)-c)crbEo
Et(ga?
E
=E(E
=lt:)I
o
S=O€f,5s_=T EoroEc2ur
+ESfr5:H;sf:E.EREo
=cri =S8 ilPt
5 8=?OOss
E#EEEJeer..lJ < o o-
o
o
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
100
o
=Eo
=oE.9
6*ENE9E'. Earoo()
3G'
.E, S*e
=oEF
ljoI
-E
E
O
st -Si seN O+
=E:UJE -<,,', (\r
=!2H IE;iEEIE<c
=6=*8 rPtEs=dOOssE#EEE{ o o+JLLUJ<L(L
o
stlr)
uJ uloooo--(a1ecg 6o1)
o
Denison Mines (USA) Corp., White Mesa Mill, EnvironmentalReport, February 28,2007
l0l
#"
.#,
.:.""
qho"
*1"'
*o"
s
*o"
ffi
.:.""
*o"
*1"'
*os
*1"
$
u1',
'"e
=E.\o)
otro
(EotsotEAO=(,'. ce:rooc)5ro.pN*e
EoE
toI
-@
-Eo
-; €<.>LU;==o,= Y cols
=O-:[!F=,rr)5o:H rrsTIEERroEii:g8 "Pt68=dO(5ss
E#EEE{0.,o+J!Lr.Ij<o-(L
gagec5 6o1)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W7
t02
0a
i:*
":."t
dr,
":",;-t,
.l:r
*ot,
":.'".r%
*o$
*o",
":."
*o',
ao',
d:r
.:.'"
*1'"
*ot,
.":,"
*ot,
*1",
":.""
*1',
+l',
,J:T
or,
A
ii{
ir
li
I
I
3
lA++
ii<
G
a
FBF
Dr
p
|ir4-
"r>\|,tal"H-
+.=*I_
?iiii'+qrlijtrFr
tsis
tii lt??Itl#,
H
It lr
lTt
s {
f IrFI
Ilt
tlI
=E
(5
oEo
FE(!:t ErOatE
e,C,
=oEDOiE6
IE'
TE3
ui)t
E
ELJ; -Er €ou_q.iI c --
EEiT!co$ "L- il 69"r=,'?trtoEv
=,jr<a il()*EE==O(5s.+
E#EP#5egL!<(LtL
@
IIJoo;
r.-
LlJoo-
(o
LUoc
s|r)
I.IJ tUoooo--gelecg 6o1)
(?,
UJ
E
(\l
UJ
E
rljoo-
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
103
=Eo
oEo
6
hrE6i8
ai, osO!oEr.=lL9
E.9!,(EE(l'
a
@
lr)
UJoo-(alecS 6ot)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2W7
104
%""
9"r,
%""
%""
%,,
%""
%""
qh"r,
Eo
=oE
.9
EotsAIEci8
(DOs(J
6.8E,AE
E6
=(l)I
-E
E>Ev=os_=T EororE!2r-ur5d85=HI
5dr il I.ER E(5
=c.i=;!I ilPt68=dO(5+r
EtrPEi5 e er.JJ < o- o-
@
[!oq
F
UJoq
@
tuoq
s()-uJ uJoooo--(atecS 6ot)
(')
uJoq
N
uJoquloq
il
I
il
ratt\
II
I
lrlt
iilt
)rll
tl),
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
105
tt
It
llII
il
l
ltltll
I
Iililil
il
1tti
it
I
I
I
jr
I
I
I
ll
lr
ll
I
il
ii
iitl
tl
lt
t,,
lir
lr
i
I
I
i
I
I
I
ii
%"*
9"r,
%,"
%"r,
%,,
%r"
%,,
%""
=E.\()2
oco
(EortsNEc!, 9l-EG'OoO
.e,Rt!!E
=oEFI
o
so
T EOTIJ >=C\r ()slr -=T=tr;tuE _<..,, N
=!6 tt5-.rrBEi.E(JEroJS8 rgt58=dO (5.+ s6#sEE{ o o+J L !IU<(LO
@
IJJoq
F*
UJoq
@
UJoq
tloFF
IJJ I.JJooqq
FF
(alecg 6o1)
(?)
u,oq
N
UJoqu,oq
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
106
ga
o$
%.o",
1""
lt
o",
I"o.o$
-E.\o
=oE
.9
GBEdro-(,atEEo
=(oC'I NEql
E
.=!,EE
@!
@
-EoJC6 -S= saotEYc"rtt ._-ti5.=o-llJ5;HT
5 '-ir
rr IER'EO
=..i=*8 rPi53=iO(l++
E#EEE{ o o+JLLrU<(L(L
%'"
oo*r,
%.o$@
trJoo-
Ir
ulq
(O
IIJ
E
sro FlndEE
(etecS 6ot)
(O
[!
E
N
uloo-
uJ
e
I
t )1 'ffi,
Ilttt Itlrll t
i|ihd
ll
I2l
I
I
I
I
I
jr
J
lt
lr
il
liiiii
F
il
il
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
l07
il
il
ll
il
(
(
$*i
H'
tr
ll
ll
i,,
H\
/
iiili
t
tr
ii[l
{',rlt r rr\r
lfl
\
,,
t
+
ltlt
l
il
U
il
ll
tl
l %""
%""
t"r,
%'"
%,,
%""
%""
%,,
=E.\o3
oE
.95SG:tErOatPoo
=c).9' orr&tE(EoJ
@I
.r-o
€
Oa=
r €OU}=J@-\ioril E^1 7E=-TULgur:!=T*€ ru .=,?gu?.EY
=-J<U "Y<5 8=dO(9+r
E#SEJ{oqr+JLLLU<'L(L
o
LUoq
i.-
uJoq
N
tuoq
(o
UJoq
-f lJ)Fri,t dooqq
F
(atecS 6ot)
(o
UJoq
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
108
A review of the foregoing figures supports the conclusion that airbome particulate is well
controlled at the Mill. The results of these analyses demonstrate that the facility has been
consistent in its compliance with the Effluent Concentration Limits (ECL's) required by
regulation (10 CFR 20, Appendix B, also incorporated by reference in R313-15-302).
The data obtained since program inception in 1981 indicates that only one individual quarterly
measurement (Th-230 at BHV-5 for the 2nd qtr, 1996) has ever exceeded the ECL at the Mill.
With regard to this particular single measurement, while it is important to consider and evaluate
an individual measurement exceeding the ECL, for public dose estimation purposes it is the
annualized data that are of primary significance. In this instance, the annuali zed Th-230 data for
BHV-5 in 1996 is well below the ECL for the annual period.
It is noteworthy, and expected, that while Pb-210 concentrations are ALARA. They are elevated
in comparison to the other radionuclides tested (i.e. U-nat, Th-230 andRa-226). This condition
is experienced world-wide and is resulting from the ubiquitous presence of radon in the
atmosphere. Accordingly, observed Pb-210 disequilibria cannot be attributed to the operation of
the Mill.
Radon-222 emanates as a decay-chain progeny of the Radium-226 contained in the soil of the
earths crust and is dispersed generally throughout the earth's atmosphere. The electrically
charged short and long-lived decay products of Radon-222 attach to ambient dust particles found
naturally in the atmosphere and are carried long distances. Lead-210 is the longest lived of these
decay products and is the decay product of the shorter-lived radon progeny. As such, it
accumulates as an electrical attachment on the natural ambient dust in the atmosphere and is
generally measured at elevated activity when compared to local decay-chain parent nuclide
activity, regardless of uranium milling activity. At the Mill's BHV air monitoring stations, all
dust (ambient natural and Mill derived) is collected by the sample filter. Because of the natural
elevation of Pb-210 accumulated as an attachment to the naturally occurring ambient dust
particles collected by the air sampling equipment, Pb-210 is commonly elevated and in
disequibrium when compared to parent nuclide activity, regardless of the Mill's presence. By
way of illustration, average groundJevel concentrations have been reported for selected States
(NCRP Report 94, 1992) and are summarized in Table 3-13-7 below, demonstrating elevated Pb-
210 activity where no uranium milling operations are located nearby. Lead-ZIO activity
concentrations can be expected to be even higher for locations in the western U.S. where
uranium ore bodies are commonly located.
Table 3.13-12
NCRP Report 94-Global Lead-210 Concentration Example
State
California
Illinois
Ohio
Massachusetts
600
1500
300
700
t.6E-
4.tE.
8.lE-
l.9E-
4
4
5
4
Source: January-June, 2006 Semi-Annual Effluent Report (Denison)
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
109
Evaluation of the data by comparison to the Mill's ALARA goals reveals that, with very few
exceptions, the gross (background inclusive) measurements do not exceed the Mill's ALARA
objectives which are 25Vo of the ECL. (In only 9 of the 1,984 gross radionuclide determinations
did the measurement exceed the Mill's self-imposed ALARA threshold).
b) Radon
Due to the unavailability of monitoring equipment to detect the new 10 CRF standard of 0.1
pci/I, with the approval of NRC, Radon 222 monitoring at BHV stations was discontinued in
1995. lnstead, Denison demonstrated compliance with these limits and the requirements of
R313-15-301 by calculation, authorized by the NRC and as contemplated by R313-15-302 (2)
(a).
This calculation was performed by use of the MILDOS code for estimating environmental
radiation doses for uranium recovery operations (Strenge and Bender 1981) and more recently in
2003 by use of the updated MILDOS AREA code (Argonne 1998). The analysis under both the
MILDOS and MILDOS AREA codes assumed the Mill to be processing high grade Arizona
Strip ores at full capacity, and calculated the concentrations of radioactive dust and radon at
individual receptor locations around the Mill.
The MILDOS and MILDOS AREA codes calculated the combined Total Effective Dose
Equivalent (TEDE) from both air particulate and radon at the nearest potential residence,
approximately 1.2 miles north of the Mill, the public, as well as at all other receptor locations.
These calculations revealed projected doses to be below the ALARA goal of 10 mrem/yr for air
particulate as set out in R313-15-101(4). Radon has also been calculated to be within regulatory
limits.
While confident that past modeling was sufficiently accurate, detection equipment hass improved
since 1995. The Mill has decided to implement Alpha Track monitoring for radon at its
environmental air monitoring stations commencing with the l't Quarter of 2OO7 .
c) Extemal (Direct) Gamma
TLDs are co-located with the high volume air samplers at the BHV stations shown on Figure
3.3-2. In addition, TLDs continue to be installed at BHV-3. The quarterly results of the TLD
measurements for 1999 (after subtracting the background measurements from BHV-3) are
summarized in Table 3.13-8. 1999 was chosen as a reference year, because it is the year in
which the last Mill run occurred. In some cases the BHV-3 background was higher than the
measurements at the other sites. These values are in brackets indicating a negative value after
subtracting the BHV-3 value.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
il0
Table 3.13-13
1999 TLD (Environmental) Gamma Dose (After Background Subtraction)
Location
Gamma dose (mrem/vr)
Jan 1/99-
Anr 13D9
Apr 1199-
Julv 15D9
July 1D9-
Octl2lD
Oct 1D9-
Jan 10/fi)Maximum Average
BIIV-I 1.00 (0.60)3.80 0.00 3.80 1.05 (0.60)
BHV-2 5.20 0.00 (0.20)6.40 6.40 2.85 (0.20)
BHV-4 6.00 0.00 3.00 0.80 6.00 2.45 0.00
BHV-5 2.80 '7.60 4.60 6.60 7.60 5.40 2.80
Brry-6 2.40 0.60 3.40 2.00 3.40 2.t0 0.60
Source: Mill monitoring data.
The measured levels at BHV-5 were the highest, reflecting proximity to the Mill's ore storage
area. The gamma levels at BHV-1 were the lowest. Since BHV-2 is further from the Mill than
BHV-l and showed a higher annual gamma dose, it is likely that the gamma radiation levels at
BHV-2 were in fact natural and un-impacted by activities at the Mill. Variations in naturally
occurring radiation in soils and the use of phosphate fertilizer could readily explain such
variations in natural background.
In addition to the 1999 measurements, gamma exposure rates have been measured at air stations
BHV-1, BHV-2, BHV-3, BHV-4 and BHV-5 since the beginning of Mill operations in 1981.
Figure 3.13-32 below depicts the measurements of record since that time, and further illusffates
that incremental dose above background at BHV-3 remains low, regardless of the state of
operations.
Figure 3.13-32
Background Subtracted and Background
Envi ronmental TLD Measurements (mrem/Qtr)
d. / f f f f / f f d* du,/* dn do d* do / ao a* f f f f f f f
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
llt
(d) Veeetation
Vegetation samples are collected at three locations around the Mill periphery. The sampling
locations are: 1) Northeast, 2) Northwest and 3) Southwest of the Mill facility. The samples are
collected during early spring, late spring and fall (e.g. the growing seasons). A graphical log-
scale presentation of the radionuclide uptake in vegetation as observed over time since 1998,
prior to and after the most recent natural ore mill run, is provided in Figures 3.L3-33 and 3.13-34.
For these graphs the "less than" values and zeros have not been plotted as the results are not
comparable to any regulatory limit (i.e. the vegetation sampling data is utilized for dose
modeling purposes only, when appropriate). The 2006 data compared to the results of previous
years indicate no increase in uptake of Ra-226 or Pb-210 in the vegetative growth collected and
are within the variation of previous sampling episodes. It should be noted that vegetation
samples in recent years were collected during a period of severe drought in San Juan County.
For this reason sampling was dramatically affected due to the scarcity of available vegetative
species at the respective sampling locations.
Figure 3.13-33
Ra.226 Concentrations ln Vegelation (uCi/Kg)
gEooooJ
o-"$.".[.".[.$.$"$."]."$."$-$.$-$.$
FNE -{_NW -_r_sw-l
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2001
l2
Figure 3.13-34
Pb-210 Concentrataons ln Vegetation (uCi/Kg)
o6ou, t.00E-05g}o
1.00E-06
1.00E-02
1.00E-03
1.00E-04
1.00E-07
1.00E-08
o.$.$.""[.$.""[-1$""$-$."$.$-$.$.$
I--.-NE {-NW --*-sw-l
(e) Stack Releases
The Mill has three stacks associated with yellowcake production: the north yellowcake dryer; the
south yellowcake dryer and the yellowcake baghouse. Denison measures uranium in stack
emissions from these stacks when the Mill is operating. In addition, when the Mill is producing
yellowcake for more than one consecutive quarter, the stack testing program also includes
measurements of Ra-226, Th-230, and Pb-210 in the particulate. The yellowcake dryers were
operated during the 1995/1996 and 1999 Mill runs. Table 3.13-9 sets out the stack sampling
results for the Mill run when the high-grade Arizona Strip ores were processed. As stated
previously, the Arizona strip ores are representative of the upper bound for natural ore
processing. During the 1995/1996 processing campaign both the north and south yellowcake
dryers were operating, and representing the most conservative case for yellowcake scrubber
emission.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
I t3
Table 3.13-14
1995t1996 Mill Stack Sampling Resultsl
Source: Mill Semi Annual Effluent Reports.I The annualized release rate for uranium was estimated by summing the quarterly release rates reported in the Table and multiplying the
sum by four.
From this data, the uranium release rate stated as Cilquarter on an annualized basis, can be
calculated for the processing of high grade Arizona Strip ores to be 1.49E-02 Cilyr from the
yellowcake scrubber, which is less than the emissions modeled in the FES of 2.98-02 Cilyr U-
238 (see Table 3.13-2). Similarly, the annualized release rates for Th-230 andRa-226 can be
calculated to be 1.38E-05 and 2.48-06 Crlyre, which are less than the levels modeled in the FES
of 1.6E-03 and 6.2E-05 Cilyr.
The stack sampling results for the 1999 Mill run, in which a smaller quantity of lower grade ores
was processed and only the north yellowcake dryer was used, indicated lower emission levels for
all measured radionuclides as compared to the 199511996 Mill run. The annualized release rates
for Unat, Th-23O and Ra-226 can be calculated to be 5.14E-03, l.219-06 and 6.94E-06.
Similarly, yellowcake scrubber stack tests conducted during product drying campaigns for the
2006 alternate feed processing have been lower than those exhibited during the 199511996 Mill
run.
For the purposes of the 2007 MILDOS assessment the more conservative (larger) EnechoTech
release rates were utilized for dose estimation purposes in both ore processing scenarios.
(f) Surface Water
See Section 3.7.1 above.
(g) Groundwater
See Section 3.7.2 above.
(h) Soils
Soil samples are collected annually at each of the BHV-1, BHV-2, BHV-3, BHV-4 and BHV-5
locations and analyzed for Unnl and Ra-226. Soil sampling data, Iaboratory analyses and
graphical representations, since the Mill's inception of this program, are provided in the Semi-
e The annualized release rate for Ra-226 and Th-230 were scaled from the annualized uranium release rate on the basis of the
relative quarterly concentrations reported in Table 3. I 3-7.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2Cf7
tt4
Parameter Detirction
Limit
North Yellowcake
Stack
South Yellowcake
Stack
Yellowcake Baghouse
Stack
U-", uCi/ml 9E 4 4.178-lO 3.72E-10 6.38E-l I
Ra-226 uCi/ml 2E 4 2.47E-4 + 2.24E-14 1.878-14+ 1368- 14 9.438-14 + 1.858 -14
Th-230 uCi/ml 2E 5 t.498-3 +7.M8-14 2.358-13+4.718-14 4.078-13 + 8.278 -t4
Pb-210 uCi/ml 2E 5 3.288-3 + 1.05E-14 1.438-12 +6.18E- l3 9.62E-13 + 5.238 -13
U.,, Release Rate (Ks/Otr)NA 2.9 2.1 0.4
U-", Release Rate (CilOtr)NA 1.998-03 1.45E-03 2.768-4
Annual Effluent Reports. No obvious trend is evident in any of the sample location data sets.
Sample results obtained since the previous licensure demonstrate that soil nuclide concentrations
are low (less than unrestricted release requirements). These data are presented in Table 3.13-10.
Table 3.13-15
Soil Sample Concentrations
(Values x 1.0E-3 pCi/Kg)
Date BIIV.I BIIV.2 BHY.3 Brrv-4 BHV.5
Ra-ZXi U-Nat Ra-226 U-Nat Ra-226 U-Nat Rr-226 U-Nat Ra-226 U-Nat
r997 0.54 0.3 r 0.56 0.16 0.27 0.27 0.26 0.26 1.50 L50
1998 r.60 3.05 0.70 0.58 0.s0 0.45 1.00 l.l9 3.00 2.16
t999 2.27 1.74 0.78 0.84 0.53 o.42 0.84 0.77 3.2'.7 3. l5
2000 1.55 L2t 0.8r 0.53 {.,(0.83 1.22 3.81 3.25
2001 L00 1.00 0.60 0.30 0.04 0.30 0.90 1.00 1.20 LlI
2002 1.30 1.35 0.90 0.52 0.50 0.30 1.20 1.49 2.40 2.8t
2003 0.80 0.99 0.60 o.79 0.50 0.33 0.60 0.43 2.80 4.20
2004 0.60 0.61 0.40 0.25 0.40 0.22 0.60 0.51 1.00 r.40
2005 0.90 0.96 0.70 0.34 0.60 0.27 0.60 0.38 0.70 0.41
2006 0.70 0.16 o.44 0.25 0.4t 0.25 0.52 0.48 1.40 1.30* Data not available
(i) Radon Emanation from Tailings
Clean Air Act (CAA) NESHAPs requires that the Mill demonstrate on an annual basis that, on
average, the radon flux from existing uranium mill tailings piles not exceed 2O pCi/m2ls. In
order to satisfy this requirement, the radon flux from tailings surfaces at the Mill are measured
and reported to the State of Utah on an annual basis. These data consistently demonstrate that
the radon flux from the surfaces of tailings at the Mill are below the NESHAP's criteria, which,
according to EPA, protects public health and safety with an ample margin of safety. Table 3.13-
13 shows the radon emanation rates from the Mill's tailings cells over the most recent five year
record. It should be noted that at the time of this writing the report for the 2006 tests had not yet
been received by Denison from its radon test contractor, and as a result the 2006 data could not
be included.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
l15
Table 3.13-16
Annual Radon Emanation Testing
Tailings Cells 2 & 3 (pCi/m2-sec) 10
Year Rn 222 Emanation-Cell2 Rn-222 Emanation-Cell 3
1997 t2.l 16.8
1998 14.3 14.9
t999 13.3 2.2
2000 9.3 l0. t
200t 9.4 0.7
2002 9.3 6.3
2003 4.9 3.6
2m,4 3.9 0.8
200s 7.1 6.2
Source: Mill NESHAPS Reports.
The values reported for 2001 and2002 were elevated when compared to prior years testing. It is
Denison's belief that these emanation rates were largely due to the drought conditions in those
years, which reduced the moisture content in the interim cover placed over the inactive portions
of tailings Cells 2 and 3. In addition, the commencement of the 20}2Mlll run, which resulted in
increased activities on the tailings cells, may have contributed as well. As a result of the higher
radon emanation rates experienced in 2001 and2O02, additional interim cover was placed on the
inactive portions of Cells 2 and 3 in order to reduce radon flux to the levels measured in previous
years. While this effort was successful, additional cover was again applied to the tailings in 2005,
further reducing radon emanation to well below the NESHAPS standard of 20 pCi/m2-sec.
3.13.2.8 Occupational Doses
The FES notes that uranium mills are designed and built to minimize the exposure of mill
workers, that occupational exposures for workers are monitored and kept below regulatory
limits, and that workplace radiation protection measures are periodically reviewed and updated
as appropriate. NRC staff also comment in the FES that based on staff review of mill exposure
data, uranium mill workers were unlikely to be exposed to more than25Vo of NRC's permissible
limits. See FES Section 4.7.6. The actual doses to workers at the Mill have in fact been low, as
illustrated in the following discussion.
Denison has implemented a comprehensive radiological workplace and worker monitoring
program at the Mill. Radiological monitoring of the Mill workplace includes area measurements
of external gamma radiation, radon decay progeny and long-lived alpha activity in airborne dust.
(a) Dose Limits
In order to provide a context for the workplace and worker monitoring data given below, it is
necessary to briefly comment on the current NRC dose limits for workers which are given in l0
l0 Radon flux measurements are made on the cover area and beach area of tailings Cell 2 and tailings Cell 3. The
mean area weighted radon flux for the total tailings area is then calculated with the results as shown in the table.
Denison Mines (USA) Corp., White Mesa Mill, EnvironmenralReport, February 28,2007
il6
CFR Part 20 (R313-15-201). The fundamental dose limit is given in terms of a TEDE which, in
effect, is the sum of the deep dose equivalent for external gamma exposures and the committed
effective dose equivalent for internal exposures from radionuclides taken into the body, through,
for example, inhalation of radioactive dust and radon. The term "committed" simply means that
all of the dose attributable to the intake of a radionuclide during the 50 year period after intake is
taken into account and assigned to the year of intake. Both doses are reported in "rems".
The deep dose equivalent is the standard measure of the "whole body" dose from external
gamma radiation. The committed effective dose equivalent is the standard measure of the whole
body dose from radioactivity in internal organs and tissues (summed over all organs using
appropriate weighting factors for radiation quality and radio-sensitivity of the various organs).
While the basic dose limit set out in 10 CFR Panlt 20 (R313-15-201) is a TEDE dose of 5 rem
(5,000 mrem) per year, in practice the dose from intemally deposited radioactivity is determined
through the use of derived limits. The Derived Air Concentrations "DAC's" are the
concentrations of airborne radioactivity which, if inhaled by a worker for an entire working year
(assumed to be 2,000 hours), would result in a committed effective dose equivalent of 5 rem.
These DAC's are commonly used to control occupational exposures.
10 CFR Part 20 (Appendix B, Table 1) which is incorporated by reference into R313-15-201,
also provides a DAC for Rn-222 of 0.33 ("Work Levels") WL. A full year of exposure to radon
decay progeny of 0.33 WL is assumed to cary the same risk as exposure to 5 rem. Thus, the
workers TEDE doses can be assessed using a sum of fractions rule as follows:
Annual TEDE = (gamma/5) + V2,000{(CA/DACA +Cs/DACs + Cg/DAC6...) + (WU0.33)}
Where:r gaffima is the annual workplace gamma dose in rems. Ca is the average workplace air concentration of radionuclide A, in pCi/ml. DACI is the derived concentration for radionuclide A, in prCilml. WL is the average workplace exposure to radon decay progeny (WL). t is the time of exposure (hours). 2000 is the normal number of working hours per year
(b) ALARA Program
The Mill uses, to the extent practicable, procedures and engineering controls, based upon sound
radiation protection principles, to achieve occupational doses and doses to members of the public
that are ALARA. Under the Mill's ALARA Program, the mill has set a goal of maintaining
occupational exposures to levels that are no more than 257o of regulatory standards, to the extent
reasonably achievable. In addition to engineering controls, the Mill requires mandatory use of
respirators in areas of higher airborne particulate. and manages worker time in higher garnma
radiation areas as two measures to keep exposures within regulatory limits and ALARA.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2OO7
fi7
(c) Use of Respirators
10 CFR Part 20, Appendix A sets out protection factors for respirators to be used where the
contaminants have been identified and the concentrations (or possible concentrations) are known.
The protection factor is a measure of the degree of protection afforded by a respirator, defined as
the ratio of the concentration of airborne radioactive material outside the respiratory protective
equipment to that inside the equipment (usually inside the facepiece) under conditions of use. It
is applied to the ambient airbome concentration to estimate the concentrations inhaled by the
wearer according to the following formula:
Concentration inhaled = (Ambient airborne concentration)(Protection Factor)
The concentration inhaled, as determined by use of this formula, is then compared to the
applicable DAC to determine regulatory compliance. Likewise, for administering the Mill's
ALARA Program, an ambient airbome concentration that is expressed as a percentage of DAC
can be divided by the specific respirator protection factor to arrive at the percentage of DAC if a
respirator is used.
Typically, depending on the circumstances, the Mill employs the use of full or half-mask
negative pressure (i.e., negative phase during inhalation) respirators, with a protection factor of
50. ln certain circumstances the Mill also uses powered air purifying respirators (PAPR) with
radiological dust cartridges, that have a protection factor of 1,000. Other respiratory equipment
is used at the Mill as required in special circumstances.
(d) Workplace Airborne Activity Monitoring Locations
Figure 3.13-35 shows the occupational airborne activity monitoring locations at the Mill. The
corresponding identification codes for each monitoring location are provided in Table 3.13-12.
Airborne dust and gamma radiation levels are routinely collected in areas at the Mill with
potential for worker exposure. The general site is shown in Figure 3.13-36.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
I l8
Figure 3.13-35
OCCU PATIONAL AIRBORN E ACTIVTTY MON ITORI NG LOCATIONS
(PARTICULATE & RADON) AT THE WHTTE MESA MILL
rETl
ORE STORAGE
rEA-.i]
SCALEHOUSE
fEffiol
toAI o-l
i*.5:i,
Ir*a
/-lrnza
Denison Mines (USA) Corp., White Mesa Mill, Environmental Reporr, February 28,200'1.
ll9
\
)
1t
100 0 100 200 300
ORE
PAD
Icw'
-
SCALE 1'.250'
co* 8tl-fiE
\t
rtumEa
a-
d
arb
--a
frlt4
E
ril
Denison Mines (USA) Corp.
P'ojec't WHIE MESA MILL
Figure 3.13-36
Site Map of The White Mesa Mill
Showing Location of Buildings and Tankage
i
n
a
I
9'
ric
II
$
d
sa1!.9
t
8.
3
I
.e
Ia&
;
!
T
:--
0q-EjH
r€liI
Table 3.13-17
Mill Airborne Activity Monitoring Locations
Identification Code
BA-I
BA-2
BA-6
BA-7
BA-7A
BA-8
BA-9
BA-IO
BA-I I
BA-12
BA-12A
BA-I28
BA-I3
BA-I3A
BA-I4
BA-I5
BA-I6
BA-I7
BA-I8
BA-I9
BA-20
BA-21
BA-22
BA-22A
BA-23
BA-24
BA-25
BA-26
BA-27
BA-28
BA-29
BA-30
Location
Ore Scalehouse
Ore Storage
Sample Plant
Sag Mill Area
Sag Mill Control Room
Leach Tank Area
CCD Circuit Thickeners
SX Building North Area
SX Building South Area
YC Precipitation & Wet Storage Area
North YC Dryer Enclosure
South YC Dryer Enclosure
YC Precipitation & Wet Storage Area
YC Packaging Enclosure
Packaged YC Staging Area
Metallurgical Lab Sample Prep Room
Lunch Room Area (New Training Room)
Change Room
Administration Building
Warehouse
Maintenance Shop
Boiler
Vanadium Panel
Vanadium Dryer
Filter Belt/Rotary Dryer
Tails
Control Room
Shifters Office
Operators Lunch Room
Dump Station
Filter Press
Truck
Source: Radiation Protection Manual
To facilitate the discussion of occupational exposures, the individual workplace monitoring
locations shown in Figure 3.13-35 and listed in Table 3.13-12 were grouped according to factors
such as proximity to Mill processes, type of exposure and similarity of DACs. For example, the
monitoring locations at the SAG mill and at the SAG mill control are grouped together due to
Denison Mines (USA) Corp., White Mesa Mill, Environmenral Report, February 28,2007
t2t
their proximity and similarity of activities. Other groupings were assembled in a similar manner.
These groupings are shown in Table 3.13-13. Each grouped location indicated in the first
column of Table 3.13-13 is assigned its own DAC; similarly, each workplace location indicated
in the fourth column uses the DAC for the respective grouped location
Grouped workplace Locations #tfn3o'f;farticutate and Radon Monitoring
(e) Airborne Dust
The routine airborne particulate radioactivity levels are reported in terms of gross alpha activity.
These measurements can be compared to DAC's developed by Denison for each stage of the
process and approved by NRC. The relevant DAC is defined according to the source of airborne
dust (e.g. from ore, tailings or yellowcake), the lung solubility class according to the chemical
II DAC's for vanadium workplace locations are not included in this analysis
Grouped Locationll Secondary Grouping ID Code Workplace Location
Ore-Crind Southeast of Mill BA-I
BA-2
BA-20
BA-I9
BA-I6
BA.I7
BA-I8
Ore Scalehouse
Ore Storage
Maintenance Shop
Warehouse
Lunch Room
Change Room
Administration Building
Outside of Mill BA-28 Dump Station
Inside the Mill BA-7
BA-7A
BA-26
BA-27
BA-29
SAG MiII
SAG Mill Control
Shifter's Office
Operations Lunch Room
Filter Press
Inside the Mill, Just Outside YC Areas BA-25 Control Room
Leach BA.8 kach Tank Area
CCD BA-9 CCD Circuit Thickeners
SX SX BA-I I SX Buildine South
(Outside SX)BA-2I Boiler
Yellowcake Precipitation BA-12 Yellowcake Precipitation and Wet Storage Area
Yellowcake Packaging:Yellowcake Enclosure BA
BA
BA
2A
28
3A
North Yellowcake Dryer Enclosure
South Yellowcake Dryer Enclosure
Yellowcake Packasins Enclosure
Yellowcake Packaging BA-I3 Yellowcake Drying and Packaging Area
Yellowcake Staging (Storage)BA-14 Packaged Yellowcake Staging Area
Tailings BA-30
BA-24
Truck Shop
Tailings
Radiation Protection
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,Z0O7
122
form of the radionuclides and the relative abundance of the radionuclides. The basis for the
current NRC approved DAC's is summarized in Table 3.13-14.
Table 3.13-19
Solubility Class, Chemical Form and Abundance of Feed Material at the Mill
Source : Radiation Protection Manual
t l0 CFR Parr 20, Appendix B
'] NUREG/CR-0530, PNL2870, D.R. Kalkwarf, 1979, "solubility Classifications of Airbome Products from Uranium Ores and Tailings piles',
The actual results of the airborne dust monitoring for 1999, the most recent year in which
conventional ores (Colorado Plateau) was processed, corresponding to the grouped locations are
shown in the following Table 3.13-15 along with the percentage of the DAC that the measured
concentrations represent. These data demonstrate that the airborne radioactive particulate
concentrations for typical Mill operations are well below the corresponding DACs. Data for the
2006 Mill run in not available as of the date of this report. However, the 1999 conventional ore
Mill run is considered to be representative of typical full scale Mill operations.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
123
Location U*t Th-230 Ra-226.Pb-210
Ore-Grind DAC is specified in l0 CFR Part 20
Leach lz Ore, % Precipitation lz Ore, lz Pr ecipitation lzOre, % Precipitation Yz Or e, lz Precipitation
CCD Class D
Sulfate
257o
Class W I
Sulfate
25Vo
Class Wr
Sulfate
25Vo
Class D I
Sulfate
257o
SX Class D
Sulfate
25Vo
Class W I
Sulfate
257o
Class WI
Sulfate
25Vo
Class D I
Sulfate
257o
Precipitation Class D 2
Diuranate
lO0%io
NA NA NA
Yellowcake
Packaging
Class Y: 90 7o arrd
Class W: l0 7o
Oxide
ljOVo
NA NA NA
Tailings Class Y
Oxide
4Vo
Class Y 2
Oxide
32Vo
Class Wt
Oxide
32Vo
Class W I
Oxide
32?o
Table 3.13-20
Particulate Concentrations (Gross Alpha) in Workplace Locations for 1999 Mill Run
Grouped
Location
DAC
(pCi/ml)
Individual
Location
Production
Period
Concentration
0rCi/nrl)
Production
Concentration
(Vo ofDAC)
Non-
Production
Period
Concentration
(uCi/ml)
Non-
Production
Concentration
(Vo af DAC\
Southeast of
Miil
6.008-r r Ore Scalehouse
Ore Storage
Maintenance
Shop
Warehouse
Lunch Room
Change Room
Administration
Blds
1.468-12
2.418-12
2.068-12
1.268-12
7.338-t3
3.19E-12
l.4tE-12
2.43
4.01
3.44
2.ll
1.22
s.32
2.35
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Average NA NA
Outside of
Miil 6.00E-l I Dump Station 2.06E-ll 34.26 3_72E-13 0.62
Inside the
MiII 6.00E-l I SAGMiII
SAG MiII
Control
Shifter's Office
Operations
Lunch Rm
Filter Press
r.34E-l I
1.90E-12
r.568-t2
1.498-13
5.7tF-12
22.27
i.t I
2.59
1.25
9.51
3.37E-12
3.49F-12
4.968-13
1.80E-13
N/D
5.62
5.81
0.83
0.30
ND
Average 4.668-12 7.76 1.888-12 3.14
Leach 5.00E-10 Leach Tank
Area I .588- t 2 0.32 8.40E- 13 0.17
CCD 1.20E-l l CCD Circuit
Thickeners 1.258-12 10.41 2.59E-12 21.58
sx 1.20E-l I SX Building
South 1.628-12 13.50 2.48E-13 2.O7
Boiler 3.05e- I 3 2.54 N/D N/D
Inside Mill,
outside YC 6.00E-l I Control Room 1.468-t2 2.43 5. l5E- I 3 0.86
Yellowcake
Precipitation 5.00E-10
YC
Precipitation
&Wet Storase
1.598-t2 0.32 6.40E-13 0. l3
Yellowcake
Enclosure 2.208-ll North YC
Dryer Enc
South YC
Dryer Enc
YC Pkg
Enclosure
1.20E-l I
5.24F-12
3.688-t2
54.57
23.8 r
16.71
2.538-12
1.348-12
6.O48-t3
I 1.48
6.1 I
2.75
Averase 6.978-12 31.10 t.49E-12 6.78
Yellowcake
Packagine
YC Drying &
Packasing Area 2.738-12 12.40 5.68E- l3 2.58
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
124
Grouped
Location
DAC
(pCi/ml)
Individual
Location
Production
Period
Concentration' fuCi/ml)
Production
Concentration
(7o of DAC)
Non-
Production
Period
Concentration(uCi/ml)
Non-
Production
Concentration
(Vo oIDAC)
Yellowcake
Staging
(Storase)
Packaged YC
Staging Area 2.22E-12 10.08 6.228-13 2.83
Tailings 1.708-l I Truck Shop
Tailinps
8.51E-13
6.95E-13
5.01
4.09
NA
NA
NA
NA
Average 7.738-13 4.55 NA NA
Source: Mill Monitoring Data
It should be noted that several of these locations (e.g. yellowcake enclosures) are areas where
mandatory respiratory protection is required, and thus potential exposures to workers in these
areas would be lower than suggested by the simple application of data in Table 3.13-15. See
Section 3.13.1.8.c.
0 External Gamma
Gamma radiation is continuously monitored by TLD measurements at numerous fixed locations
within the Mill and at nearby locations on the property where workers may be exposed. Figure
13.13-37 shows the individual gamma dose rates at individual workplace locations for both the
production and the non-production periods in 1999. The average gamma levels for key work
areas are summarized in Table 3.13-16.
Table 3.13-Zl
Average Radon Decay Progency and Gamma
(Measured During the 1999 Mill Run)
Area RDP (WD Gamma {mrem/h),
Leach 0.005 0.05
CCD 0.01l 0.01
SX 0.0t2 0.0r
YC Precipitation 0.010 0.06
YC Enclosure 0.015 NA
YC Packaeins 0.010 0.r3
YC Storaee 0.007 0.04
Tailines 0.004 0.04
Source: Mill Monitoring Data
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
125
'Not Grouped Spatially
E EEEEE E E i $ l E gsr6BBE i$ E gfis 18 EE q E e " €,3:'E E"EEEIIIsEEE i
E sFo
EsgBgEEhd8E .Hx Hp-EoE
Figure 13.13-37
Period Average Radon WL in Workplace Locations
Production and Non-Production Periods (1999)
Workplace Locatlon
g) Radon
Conventional ores and some of the altemate feed materials that have been processed at the Mill
contain Ra-226 and therefore are a source of Rn-222. The results of monthly measurements at
the fixed monitoring locations are shown in Figure 3.13-7 and summarized for key work areas in
Table 3.13-16. The regulatory limit (DAC) for radon in the work place is 0.33 WL. The
measured values are a factor of ten smaller than the DAC.
Figure 3.13-38 illustrates the average radon working levels in the various workplace locations in
1999 for production and non-production periods.
h) Worker Dose
Worker doses from external gamma radiation are monitored continuously at the Mill by personal
TLD badges. The doses from intemal radionuclides and radon are determined from workplace
airborne radioactivity measurements and analysis of how much time each worker spends in each
workplace.
From the data for all workers who were present throughout the full duration of one or both of the
recent full Mill runs (1999 and 1995/1996), the average and maximum Mill workforce TEDE
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
t26
doses were calculated as summarized in Table 3.13-17. The TEDE doses are well below NRC's
dose limit of 5 rem per year, and the ALARA goal of 1.25 remper year.
Table 3.13-22
Mill Workforce TEDE Dose (Rem)
(Annual Dose Limit Of 5 Rem)
Production Period Average Dose Maximum Individual Dose,
1999 0.17 0.68
1995/96 0.3s l.l
Source: Mill monitoring data
In addition to these data, the doses computed for workers at the plant from 1997 ta 2005 (the
most current year for completed dose computation) were evaluated. The results of that
evaluation are provided in Table 3.13-18.
Table 3.13-23
Occupational Doses-1997 Through 2005 (Rem)
Year .,TEDE CEDE Mill Production
(Y/N)Ore,Feed ProcessedMax,'iAve;,Max Ave
1997 0.91 0.27 0.83 o.23 Y Alternate Feeds
1998 1.41 0.35 1.27 o.29 Y Alternate Feeds
1999 0.45 o.t7 0.29 0.12 Y Alternate Feeds & Colorado Plateau Ore
2000 0.23 o.l2 0.r0 0.07 N
200r o.29 0.16 0.03 0.02 N
2002 0. l9 0.09 0.08 0.04 Y Alternate Feeds
2003 0.29 0.10 0.0s 0.03 Y Alternate Feeds
2004 0.10 0.06 0.04 0.03 N
200s 0. l5 0.06 0.05 0.03 Y Alternate Feeds
The data presented in Table 3.13-18 demonstrate that, with the exception of the year 1998, doses
were consistent with that experienced during the 1995196 and 1999 milling campaigns. Upon
further review with Mill staff, it is apparent that the 1998 dose maximum was elevated for
workers in the unloading (^dump station) area during the processing of alternate feed material. In
this instance the CEDEI2 (Committed Effective Dosi Equivalent the dose due to internal
deposition) was the greatest contributor for the maximum case indicating that the inhalation
pathway had the greatest influence. While the maximum dose for the 1998 1.41 rem was slightly
above the ALARA objective (25Vo of the dose limit or 1.25 rem), all doses were well below the 5
rem maximum worker exposure limit, and the average was well below the ALARA goal. It is
also important to note that processing of altemate feeds during the years 1997, 1999,2002,2003
and were well below that ALARA 25Vo objective, including 1999 when Colorado Plateau ores
were also processed.
12 Committed Effective Dose Equivalent (H850) is the sum of the products of the weighting factors applicable to each of the body
organs or tissues that are irradiated and the committed dose equivalent to each of these organ tissues (HE50=S x W, x H, ,50).
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 2g,2001-
127
i) Area Contamination Monitoring
Denison carries out alpha surveys on a routine basis at various locations around the Mill. The
results of these surveys are compared to the unrestricted release criterion of 5,000 dpm/lO0cm2
total and 1,000 dpm/100 cm2 removable alpha as set out in NRC Reg Guide l-86, G;idelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted (Jse or
Termination of Licenses for Byproduct, Source and Special Nuclear Material. To date, there has
never been any indication of a trend suggesting any increase in contamination. Where elevated
levels of contamination have been identified, they have been determined to be the result of
inadvertent cross contamination from clothing. In such situations the Mill has taken corrective
actions, including reminding the employees to observe good hygiene work practices. It is
believed that good operational contamination controls supported by area contamination
monitoring contributes to the low doses to workers seen at the Mill.
3.13.2.9 Radiological Impact on Biota Other Than Man
The 1978 ER (Section 5.1.3) considered the potential radiological impacts of radioactivity on
"biota other than man" (non-human biota) and concluded that because of the low levels of
airborne radioactivity that would be deposited on the ground arising from the operation of the
Mill, no detrimental effect on non human biota would be expected.
The FES (Section 4.7 .7) concluded that because the effluents from the Mill would be maintained
within radiological protection limits for humans, there would be no adverse radiological impact
on non-human biota such as birds and mammals.
This view was consistent with the generally held view of the time as expressed in the 1977
Recommendations of the International Commission on Radiological Protection (ICRP 1977)
which indicated that "...the level of safety required for the protection of all human individuals is
thought likely to be adequate to protect other species..."
It was only in the early 1990's that attempts were made to look in general at the effects of
radiation on plants and animals at levels implied by the radiation protection standards for humans
(e.g. IAEA 1992). More recently, The International Atomic Energy Agency (IAEA), amongst
many other activities world-wide, made a start towards developing a protection methodology
with a discussion document (IAEA 1999).
Recently, DOE has reviewed the available literature and evaluated dose benchmarks (actually
dose-rate benchmarks) for non-human biota. (DOE 2002)
Given that there are no discharges to surface or groundwater from Mill operations and that
neither the soil nor vegetation monitoring programs show any increasing trend, no impacts to
non-human biota is expected from these sources.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,zOOj
t28
3.13.3 Mill's Alternate Feed Program
In addition to allowing for the processing of conventionally mined ores for the recovery of
uranium and vanadium, the Mill License gives the Mill the right to process other uranium-
bearing materials known as "alternate feed materials," pursuant to the Alternate Feed Guidance
referenced in Section 4 of the Application. Alternate feed materials are uranium-bearing
materials other than conventionally mined uranium ores, such as residues from other processing
facilities, which usually are classified as waste products to the generators of the materials. An
amendment to the Mill License is required for each different alternate feed material. The Mill
can process these uranium-bearing materials and recover uranium, alone or together with other
valuable metals such as niobium, tantalum and zirconium.
Since the exact nature of future altemate feed material is unknown at the time of this writing, this
ER's focus is appropriately directed at the upper bound and range of known natural ore mill
feeds. Once a proposed altemate feed material is identified and properly characterized (and the
milling processes to be applied to the feed are determined) the materials are evaluated carefully
by Denison.
Alternate feed materials are acceptable for processing at the Mill if they meet the criteria set out
in NRC's Alternate Feed Guideline and a specific license amendment authorizing receipt and
processing of the Alternate Feed Material at the Mill is issued by the Executive Secretary. In
reviewing a proposed Alternate Feed Material, the Mill and the Executive Secretary must
determine on a case-by-case basis whether the proposed feed material can be processed at the
Mill in a manner that does not give rise to any significant public health, safety, or environmental
impacts, over and above the previously licensed activities.
As of February 28, 2007, the Mill has received fourteen license amendments, authorizing the
Mill to process eighteen different alternate feed materials. As of February 28,2007, the Mill has
processed over 360,000 tons of altemate feed materials, recovering over 1.6 million pounds of
U3Os from these materials.
Table 3.13-19 sets out the sources of alternate feed materials and their source material content
that have been licensed to date for processing at the Mill.
Denison Mines (USA) Corp., White Mesa Mill, Environmental Report, February 28,2007
129
Table 3.13-24
Alternate Feed Materials Licensed to Date for Processing at the Mill
Source: Denison
' These FUSRAP materials are derived from uranium mill tailings. Therefore, they contain the U-238 series in
disequilibrium
Material that the Mill is licensed to process, but which the Mill has not received to date.
Contains U-238 series in equilibrium andTh-232 series in disequilibrium.
Contains U-238, Iow levels of Ra-226 and high levels ofTh-230
Contains U-238 series in disequilibrium
Contains U-238 series in equilibrium as well as Th-232 series in equilibrium.
Contains U-238 series in equilibrium with high levels of Th-232 andTh-228.
Contains U-238 series in equilibrium, as well as elevated levels of Th-232 series in equilibrium.
2
3
4
5
6
'1
8
Alternate Feed Description;,
Volume Average Uranium
Content
(Wt Vo Ul
Linde'Soils contaminated with uranlum
and other radionuclides
100,000 tons 0.M7o
Ashland 'Soils contaminated with uranium
and other radionuclides^
172,600 tons O.06Vo
Ashland'Soils contaminated with uranrum
and other radionuclides.
43,980 tons 0.N9Vo
St. Louis Soils contaminated with uranium
and other radionuclides.
t,029,000 cY 0.@7o
Maywood'Soils contaminated with Th-232,
uranium and other radionuclides.
250,000 Tons 0.0l%o.
Nevada Test Site Cotter
Concentrate4
Drummed slurry 363 tons l0.l%o
Honeywell'Calcium Fluoride waste stream -
licensed source material
5,2143 tons 2.lVo
Cabot"Ore residues from tantalum
production Licensed source
material
16,830 tons 0.341Vo
Allied Signal'Aqueous potassium hydroxide
(KOH) slurry and solids
Licensed source material
1,595 tons 17.O7o
Rhone-Poulenc'Uranyl nitrate hexahydrate liquid
concentrate
17 tons 5O.O7o
Cameco'Potassium fl uoride product 1,966 tons 4.67o
Cameco'Uranium tetrafluoride with filter
ash Powdered solid
l0 tons 657o
Cameco'Calcined raffinate 2.197 tons 5.5Vo
Cameco'Mono- and dibutyl phosphate
reseneration Droduct
557 tons 8.0%
W.R. Grace Monazite sands and soils 203,000 tons 0.747o
Heritase'Monazite sands 2,910 tons 0.057o
Molycorp"Lead sulfide pond solids.
Licensable source material
I 1.500 tons 0.l5Vo
FMRI6 Ore residues from tantalum
production
Licensed source material
32,000 tons 0.157a
Denison Mines (USA) Corp., White Mesa Mill, Environmental Reporr, February 28,2007
130
4.ACCIDENTS
The occurrence of accidents related to operation of the Mill is minimized through proper design,
construction, and operation of the process components and through a quality assurance program
designed to establish and maintain safe operations. ln accordance with applicable regulations,
the facility design, the organization of the operation, and the quality assurance program, together
with the 1978 ER and supplements were reviewed by various agencies to ensure that there is a
basis for safe operations at the site. This review resulted in the FES. Additional evaluation of
the environmental impacts of accidents was performed in the 1997 EA, with the benefit of
information and data from many years of Mill operations. Moreover, several agencies maintain
surveillance over the plant and its individual safety systems by conducting periodic inspections
of the facility and its records and by requiring reports of effluent releases and deviations from
normal operations.
Despite the above precautions, accidents involving the release of radioactive materials or
harmful chemicals have occurred at other facilities in operations similar to those at the Mill.
These potential accidents, as they relate to Mill operations generally, have been evaluated in the
FES and in the 1.997 EA. Because the proposed Mill operations will not change upon renewal of
the License from those already accepted under the License, there will be no new situations
involving potential accidents that have not been analyzed and adequately addressed in Mill
design, in Mill procedures and in the training of Mill personnel and contractors. In accordance
with Appendix A to NUREG 1569, an assessment of impacts from previously analyzed accidents
is not required where the circumstances associated with such accidents have not changed.
The potential accidents previously assessed and accepted under the License include leakage of
pipes or tanks, fires and explosions, tornadoes, tailings dam failure and failure of chemical
storage tanks and transportation accidents. All of those types of accidents are discussed in more
detail in the Application. There are no changes to applicable circumstances that would require a
re-evaluation of those types of accidents in connection with this License renewal.
Furthermore, the GWDP has added a number of additional precautions and controls. These
additional protections, together with the protections under the License are considered to be
adequate to handle any accidents that may occur.
International Uranium (USA) Corporation, Environmental Report, June 20, 2003
l3r
5. COSTS AND BENEFITS
Appendix A to NUREG 1569 requires that the applicant for a license renewal describe any
updates and changes to the economic costs and benefits for the facility since the last application.
There have been no significant changes to the costs associated with the Mill since the last
License renewal in 1997. There will be no change to the disturbed area or facilities or operations
at the Mill as a result of the License renewal. As indicated in Section 3 of this ER, the Mill has
operated in accordance with applicable regulatory standards and ALARA goals since its
inception, and updated MILDOS AREA modeling indicates that the Mill is capable of continuing
to operate well within those standards and goals. There have been no significant demographic
changes that have impacted the ability of the Mill to operate in a manner that will result in no
significant impacts to public health, safety or the environment. It is expected that continued Mill
operations will continue to draw primarily upon the existing work force in the area with little
impact on social services.
The Mill is one of only two operating uranium mills in the United States and is one of the largest
private employers in San Juan County. The benefits of the Mill will continue to be the provision
of well-paying jobs to workers in San Juan County and the support of the tax base in that
County. Moreover, as the only operating uranium mill on the western slope of the Rocky
Mountains, the Mill is relied upon by the large number of independent uranium miners in San
Juan County and the Colorado Plateau as the only feasible uranium mill for their uranium ores.
With the recent gap between the supply and demand for uranium and the increases in the price of
uranium, the need for continued licensing of the Mill is crucial for such miners and for the
uranium industry in the United States as a whole.
ln sum, the costs associated with the operation of the Mill have not changed significantly, but the
benefits have become more evident over time as the number of uranium mills has dwindled and
the demand for uranium milling services from local miners and the industry as a whole has
increased.
Denison Mines (USA) Corp., White Mesa Mill Environmental Report, February 28,2007
132
6. CONSIDERATION OF LONG TERM IMPACTS
The long term impacts, including decommissioning, decontamination, and reclamation impacts
associated with activities to be conducted pursuant to the License have been considered in detail
in the FES, the Mill's Reclamation Plan and the 2000 EA prepared by the NRC in connection
with the Reclamation Plan.
The Mill's Reclamation Plan and financial surety arangements, as well as the provisions in the
Mill's GWDP that relate to final reclamation of the site are described in detail in Section 8 of the
Application. The renewal of the License will not result in any changes to operations at the Mill
that would impact decommissioning, decontamination or reclamation aspects associated with
Mill activities, or the previous analyses of such aspects.
In other words, there will be no long term impacts associated with renewal of the License over
and above those contemplated in connection with the existing License at the time it was last
renewed in 1997.
Denison Mines (USA) Corp., White Mesa Mill Environmental Report, February 28,ZW7
133
7. MITIGATION OF IMPACTS
NUREG 1569 requires that the ER provide the "results of effectiveness of any mitigation
proposed and implemented in the original license". ln the case of the White Mesa Mill, there
have not been any mitigations proposed or implemented under the License.
Denison Mines (USA) Corp., White Mesa Mill Environmental Report, February 28,2007
134