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WHITE MESA URANIUM PROJECT
ENERGY FUELS NUCLEAR,INC.
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FINAL ENVIRONMENTAL STATEMENT
related to the
Energy Fuels Nuclear,Inc.,
WHITE MESA URANIUM PROJECT
(San Juan County,Utah)
Docket No.40-8681
M.ay 1979
prepared by the
U.S.Nuclear Regulatory Commission
Washington,D.C.20555
NUREG-0556
SUMMARY AND CONCLUSIONS
This Final Environmental Statement was prepared by the staff of the U.S.Nuclear Regulatory
Corranission and issued by the Commission.'s Office of Nuclear Material Safety and Safeguards.
1.This action is administrative.
2.The proposed action is the issuance of a Source Material License to Energy Fuels Nuclear,
Inc.,for the construction and operation of the proposed White Mesa Uranium Project with a
product (U 30a)production limited to 7.3 x 105 kg (1.6 X 106 lb)per year.
3.The following is a summary of environmental impacts and adverse effects.
a.Impacts to the area from the operation of the White Mesa Uranium Project will include
the fo 11 owi ng:
•Alterations of up to 195 ha (484 acres)that will be occupied by the mill,mill
facilities,tailings area,and roads.Approximately 135 ha (333 acres)will be per-manently committed to tailings disposal.
•An increase in the eXisting background radiation levels of the mill area as a
result of continuous but small releases of uranium,radium,radon,and other
radioactive materials during operation.
•Socioeconomic effects on the towns of Blanding and Monticello,Utah,where the
majority of mill workers will be housed during mill construction and operation.
•Production of waste material (tailings)from the mill,which will be produced
at a rate of about 1.8 x 106 kg (2000 tons)per day for 15 years and will be
deposited onsite in subsurface pits.
b.Surface water will not be affected by normal milling operations.Mill process
water will be taken from the Navajo aquifer,and process water will be discharged
to the tailings impoundment at about 1.18 m3 (310 gal)per minute.Approximately
5.9 x 105 m3 (480 acre-ft)of water per year will be utilized by the mill,and this
is not expected to have an effect on the Navajo aquifer.
c.There will be no discharge of liquid or solid effluents from the mill and tailings
site.The discharge of pollutants to the air will be small and the effects negli-
gible.The estimated total annual whole-body and organ dose commitments to the
population within 80 km (50 miles)of the proposed mill site are presented below.
Natural background doses are also presented for comparison.These dose estimates were
based on the projected population in the year 2000.The dose commitments from normal
operations of the proposed White Mesa mill will represent only very small increases
from those due to current background radiation sources.Radiation dose commitments to
individuals living in nearby residences will not be permitted to exceed the 25-
millirems-per-year EPA limit (40 CFR Part 190).
Annual population dose commitments
to the population within an 80-km
(50-mi1e)radius of the plant site in the year 2000
Dose (man-rems/yr)
Receptor organ Plant effluents Natural background
Total body
Lung
Bone
Bronchial
epithelium
3.4
7.1
6.4
13.2
i ; ;
7,500
7,500
7,500
23,000
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6.Th)s Final Environmental Statement was made available to the public and to the specified
agencies in May 1979.
7.On the basis of the analysis and evaluation set forth in this Environmental Statement,it is
proposed that any 1icense issued for the White Mesa mill should be subject to the following
conditions for the protection of the environment.
a.The applicant shall construct the tailings disposal facility to incorporate the features
described in Alternative 1 of Sect.10.3 and in Sect.3.2.4.7 and to meet the safety
triteriaspecified in NRC Regulatory Guide 3.11.
b.The applicant shall implement an interim stabilization program that minimizes to the
maximum extent reasonably achievable dispersal of blowing tailings.This program shall
include the use of written operating procedure~that specify the use of specific control
methods for all conditions.The effectiveness of the control methods used shall be
evaluated weekly by means of a documented tailings area inspection.
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Construction and operation of the White Mesa mill will require the commitment of small
amounts of chemicals and fossil fuels,relative to their abundance.
Construction and operation of the White Mesa mill will provide employment and induced
economic benefits for the region,but may also result in some socioeconomic stress.
Department of Commerce
Department of the Interior
Department of Health,Education,and Welfare
Federal Energy Regulatory Commission
Department of Energy
Department of Transportation
Environmental Protection Agency
Department of Agriculture
Advisory Council on Historic Preservation
Department of Housing and Urban Development
Utah Board of HealthUtahStatePlanningCoordinator
Utah Division of Oil,Gas,and Mining
g.
e.
d.
f.
a.alternative sites for the mill,
b.alternative mill processes,
c.alternative of using an existing mill,
d.alternative methods for tailings management,
e.alternative energy sources,and
f.alternative of no licensing action on the mill.
5.The following Federal,State,and local agencies were asked to comment on the Draft
Environmental Statement:
The area devoted to the milling operations will be reclaimed after operations cease,
but the approximately 135 ha (333 acres)tailings area may be unavailable for further
productive use.However,when reclamation is completed and testing shows that radiation
levels have been reduced to acceptable levels,it may be possible to return the tailings
area to its former use as grazing land.
Historical and archeological surveys have identified archeol09ical and historic sites
within the proposed project area.Pursuant to 36 CFR Part 63.3,the NRC requested a
determination from the Secretary of the Interior that the area on which the archeolog-
ical sites are locatee is eligible for inclusion in the National Register of Historic
Places (flational Register)as an Archeological District.The resultin'g determination
was that the White Mesa Archeological District is eligible for inclusion in the
National Register.Although a similar request was made for determinations of eligi-
bility for the historic sites,these determinations await supplementary documentation.
It is anticipated that the NRC will enter into a Memorandum of Agreement under
36 CFR Part 800,"Procedures for the Protection of Historic and Cultural Properties,"
to ensure adequate mitigation of impacts to cultural resources.
4.Principal alternatives considered are as follows:
c.The applicant shall implement the environmental monitoring program summarized in
Table 6.2 of this document.The applicant shall establish a control program that
shall include written procedures and instructions to control all environmental
monitorins prescribed herein and shall provide for periodic management audits to
determine the adequacy of implementation of these environmental controls.The
applicant shall maintain sufficient records to furnish evidence of compliance with
these environmental controls.In addition,the applicant shall conduct and document
an annual survey of land use (grazing,residences,etc.)in the area surrounding the
proposed project.
d.Before engaging in any activity not assessed by the NRC,the applicant shall prepare
and record an environmental evaluation of such activity.When the evaluation indi-
cates that such activity may result in a significant adverse environmental impact
that was not assessed,or that is greater than that assessed in this Environmental
Statement,the applicant shall provide a written evaluation of such activities and
obtain prior approval of the NRC for the activity.
e.If unexpected harmful effects or evidence of irreversible damage not otherwise
identified in this Environmental Statement are detected during construction and
operation,the applicant shall provide to the NRC an acceptable analysis of the
problem and a plan of action to eliminate or reduce the harmful effects·or damage.
f.The applicant shall conduct a meteorological monitoring program as specified in
Section 6.1 of this document.The data obtained from this program shall be tabulated
and made available for NRC inspection.
g.The applicant shall provide for stabilization and reclamation of the mill site and
taili~gs disposal areas and mill decommissioning as described in Alternative 1 of
Section 10.3 and in Section 3.3 of this document.
h.The applicant shall provide surety arrangements to ensure completion of the mill site
and tailings area stabilization,reclamation,and decommissioning plans.
i.The applicant shall consult and coordinate with the Utah Division of Wildlife Resources
regarding the extent of fencing and other ways to mitigate any adverse impacts that
may occur to deer.
j.The applicant shall routinely monitor the tailings discharge system at 4-hr intervals
and document the results.The applicant shall monitor the use of the impoundment by
wildlife in conjunction with the program to monitor the tailings discharge system.
8.On the basis of the analysis and evaluation set forth in this Environmental Statement,it
is proposed that any license issued for the White Mesa mill should be subject to conditions
for the protection of historic,archeological,architectural,and cultural resources.The
conditions should be similar to those outlined in the proposed Memorandum of Agreement in
Appendix E.
9.The position of the NRC is that,after weighing the environmental,economic,technical,
and other benefits of the operation of the White Mesa Uranium Project against
environmental and other costs and after considering available alternatives,the action
called for under the National Environmental Policy Act of 1969 and 10 CFR Part 51 is the
issuance of a Source Material License subject to conditions 7a through 7j and in 8.above.
As announced in a FederaZ Register notice dated 3 June 1976 (4l FR 22430),the NRC is
preparing a generic environmental statement on uranium milling.Although it is the
NRC's position that the tailings impoundment method discussed in this Statement represents
the most environmentally sound and reasonable alternative now available at this site,any
NRC licensing action will be subject to express conditions that approved waste-generating
processes and uranium mill tailings management practices may be subject to revision in
accordance with the conclusions of the final generic environmental impact statementandanyrelatedrulemaking.
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CONTENTS
SUMMARY AND CONCLUSIONS
CONTENTS ....
LIST OF FIGURES
LIST OF TABLES
FOREWORD ...
1.INTRODUCTION . . . . . . . .1.1 THE APPLICANT'S PROPOSAL
1.2 BACKGROUND INFORMATION . . . . . . . ......
1.3 FEDERAL AND STATE AUTHORITIES AND RESPONSIBILITIES ....
1.4 STATUS OF REVIEWS AND ACTIONS BY FEDERAL AND STATE AGENCIES
1.5 NRC MILL LICENSING ACTIONSREFERENCESFORSECTION1
2.THE EXISTING ENVIRONMENT '"
2.1 CLIMATE . . . . . . . . .
2.1.1 General influences
2.1.2 Precipitation
2.1.3 Winds..
2.1.4 Stonns .
2.2 AIR QUALITY .2.3 TOPOGRAPHY.. . . . . " . .
2.4 DEMOGRAPHY AND SOCIOECONOMIC PROFILE
2.4.1 Demography of the area ..
2.4.2 Socioeconomic profiles " •2.5 LAND USE ...•.••........
2.5.1 Land resources ......•....
2.5.2 Historical,scenic,and archeological resources
2.6 WATER ..•..•.•...•......
2.6.1 Surface water .•....•....
2.6.2 Groundwater ...•....•.•.
2.7 GEOLOGY,MINERAL RESOURCES,AND SEISMICITY
2.7.1 Geology •••••
2.7.2 Mineral resources2.7.3 Seismicity
2.8 SOILS . . . . . . .
2.9 BIOTA ...•...
2.9.1 Terrestrial.
2.9.2 Aquatic biota .•..
2.10 NATURAL RADIATION ENVIRONMENT
REFERENCES FOR SECTION 2
3.OPERATIONS ..•••..3.1 MINING OPERATIONS •
3.2 THE MILL ..•..•••....•..
3.2.1 External appearance of the mill
3.2.2 The mill circuit .....•...
3.2.3 Nonradioactive wastes and effluents
3.2.4 Radioactive wastes and effluents .
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6.MONITORING PROGRAMS ••..••••
6.1 AIR QUALITY ..••..•..
6.2 LAND RESOURCES AND RECLAMATION
6.2.1 Land resources
6.2.2 Reclamation.
6.3 WATER . . . ....
6.3.1 Surface water
6.3.2 Groundwater
6.4 SOILS .•••...
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5.
3.3 INTERIM STABILIZATION,RECLAMATION AND DECOMMISSIONING
3.3.1 Interim stabilization of the tailings area
3.3.2 Reclamation of the mill tailings area
3.3.3 Decommissioning
REFERENCES FOR SECTION 3
4.ENVIRONMENTAL IMPACTS ..
4.1 AIR QUALITY ....
4.1.1 Construction
4.1.2 Operation ..
4.2 LAND USE .
4.2.1 Land resources .
4.2.2 Historical and archeological resources
4.3 WATER .
4.3.1 Surface waters
4.3.2 Groundwater
4.4 MINERAL RESOURCES
4.5 SOILS .
4.6 BIOTA .
4.6.1 Terrestrial
4.6.2 Aquatic ...
4.7 RADIOLOGICAL IMPACTS
4.7.1 Introduction
4.7.2 Exposure pathways.. .........
4.7.3 Radiation dose commitments to individuals
4.7.4 Radiation dose commitments to populations ...
4.7.5 Evaluation of radiological impacts on the public
4.7.6 Occupational dose .
4.7.7 Radiological impact on biota other than man
4.8 SOCIOECONOMIC IMPACTS . . . . .....
4.8.1 Demography and settlement pattern
4.8.2 Social organization ..
4.8.3 Political organization
4.8.4 Economic organization
4.8.5 Transportation .
4.8.6 Impact mitigation ..
4.8.7 Conclusions .....
REFERENCES FOR SECTION 4 • • . •
ENVIRONMENTAL EFFECTS OF ACCIDENTS ..••
5.1 MILL ACCIDENTS INVOLVING RADIOACTIVITY
5.1.1 Trivial incidents.
5.1.2 Small releases ••••.
5.1.3 Large releases ..•..
5.2 NONRADIOLOGICAL ACCIDENTS .••
5.3 TRANSPORTATION ACCIDENTS •.••
5.3.1 Shipments of yellow cake .
5.3.2 Shipments of ore to the mill ••
5.3.3 Shipments of chemicals to the mill
REFERENCES FOR SECTION 5
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1.INTRODUCTION
1.1 THE APPLICANT'S PROPOSAL
Pursuant to Title 10,Code of FederaL Regu~tions (CFR),Part 40.31 and to,10 CFR Part 51,
Energy Fuels Nuclear,Inc:(the applicant),on February 6,1978,applied to the Nuclear
Regulatory Commission (NRC)for an NRC Source Material License to construct and operate a
uranium processing mill.This mill,hereafter referred to as the White Mesa Uranium,Project,
will process ores from independent and company-owned mines.There will be no uranium mining
at the project site.
The pr9ject will consist of construction and operation of a mill with a nominal processing
capacity of 1800 metric tons (HT;2000 tons)per day with provision for recovery of vanadium
as well as uranium.
The applicant presently controls by ownership,lease,or contract,are reserves of approximately
8600 MT (9500 tons)of U30e with an average are grade of 0.125~.The proposed operating
schedule is 24 hr/day,340 days per year.At this schedule,there are about 11 years of ore
supply.The applicant has designed for a 15-year project lifetime with the expectation that
other ore sources will be discovered later.Based on these figures and a 94%recovery,the
mill will produce approximately 730 MT (800 tons)of U30e per year.
Waste materials (tailings)from the mill will be produced at abOut 1800 HT (2000 tons)of
solids per day and stored onsite.Sequential preparation,filling!and reclamation of tailings
impoundment cells are planned (Sect.3.2.4.7).This will decrease the amount of tailings exposed
(and radon exhaled)during operation of the mill.
In accordance with NRC Guides 3.5 and 3.8.the applicant has submitted a Source MaterialLicenseApplication(Form AEC-2),1 an Environmental Report (ER),2 and supplements to the ER
in response to questions by the NRC staff.
1.2 BACKGROUND INFORMATION
The proposed Energy'Fue1s Nuclear,Inc.,mill will be located in San Juan County,Utah.about
8 Ian (5 miles)south of Blanding.Utah (Fig.1.1).Ore for the mill feed will be prOVidedthroughtwoexistingorebuyingstations,one near Hanksville in Wayne County,Utah.and the
other adjacent to the planned mill on the same site (Fig.2.1).These buying stations,ownedbyEnergyFuels,purchase ore from independent mines and will also receive ore from company-owned mines.
The surface area of the project site is owned by Energy Fuels Nuclear,Inc.•or controlled by
mill site claims.The mill will occupy about 20 ha (50 acres)of the site,including 6 ha
(16 acres)presently occupied by the existing ore buying station.At the end of the proposed
15-year project lifetime,the tailings disposal cells will occupy approximately another 135 ha
(333 acres).
The purpose of this Environmental Statement is to discuss in detail the environmental effectsofprojectconstructionaswellasmonitoringandmitigatingmeasuresproposedtominimizethe
effects of the project on the immediate area and surrounding environs.
1.3 FEDERAL AND STATE AUTHORITIES AND RESPONSIBILITIES
Under 10 CFR,Part 40,an NRC license is required in order to "receive title to,receive,
possess.use.transfer.deliver ..•import ••.or export ...source material "(i.e.,
1-1
ES-4607
Fig.1.1.Location of the site of the White Mesa Uranium Project rOBS =ore buying
station].Source:Plateau Resources,Ltd.~Application for a Source MateriaZ License
for the 8~ing Ore Buying Station.Grand Junction,Colo.,Apr.3.1978,Fig.2.1-2.
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. m and/or thorium in any form or ores containing 0.05%or.more of uranium,thorium,or~~~g~~ations thereof).10 CFR Part 51 provides for the preparation of a detailed Environmental
Statement pursuant to the National Environmental Policy Act of 1969 (NEPA)prior to the
issuance of an NRC license to authorize uranium milling.
The NEPA became effective on January 1,1970.Pursuant to Section 102(2)(C),in every major
Federal action significantly affecting the quality of the human environment,Federal agencies
must include a detailed statement by the responsible official on
1.the environmental impact of the proposed action,
2.any adverse environmental effects that cannot be avoided should the proposal be
implemented,
3.alternatives to the proposed action,
4.the relationship between local short~term uses of man's environment and the maintenance
and enhancement of long-term productivity,and
5.any irreversible and irretrievable commitments of resources that would be involved in
the proposed action should it be implemented.
This detailed Environmental Statement has been prepared in response to the above requirements.
The State of Utah implements other rules and regulations affecting the project through
necessary permits and approvals provided by State agencies.The Utah Division of Oil,Gas,
and Mining is the responsible agency for all mine and mill sites within the State under the
"Utah Mined Land Reclamation Act of 1975."Title II of the "Uranium Mill Tailings Radiation
Control Act of 1978"gives the NRC direct licensing authority over uranium mill tailings.Bonding arrangements will be required to assure funding for reclamation of the tailings
impoundment and mill site grounds and for decommissioning of the facility.
1.4 STATUS OF REVIEWS AND ACTIONS BY FEDERAL AND STATE AGENCIES
The only regulatory action required from the NRC is the issuance of a Source Material License.
In addition,before construction and operation of the White Mesa Uranium Project can be
completely implemented,the State of Utah requires that permits or licenses be obtained prior
to the initiation of various stages of construction and operation of the mill.The current
status of these regulatory approvals and permits is given in Table 1.1.
1.5 NRC MILL LICENSING ACTION>
In June 1976 [Fed.Regist.41(108):22430-22431 (June 3,1976)],the NRC specified that
applicants requesting a Source Material License prior to the NRC's issuance of its generic
environmental impact statement on uranium milling (scheduled for release in 1979)shouldaddressfivecriteriathatwillbeweighedbytheCommissioninlicensingandrelicensingactions.These criteria are considered below as they apply to the White Mesa Uranium Project.
1.It is LikeLy that each individuaL Licensing action of this type wouLd have a utiLity
that is independent of the utiUty of other'Licensing actions of this type.
This statement is manifestly true for uranium mills in general and for the White Mesa
mill in particular.This mill is located near multiple mining operations producing
low-grade ore (=0.13%).The costs of hauling this ore over longer distances·make thisprojectVirtuallyindependentofothermillingoperations.This milling project can
be considered on its own merits,licensing·actions with respect to other mills areindependentofthismill,and a separate cost-benefit analysis can be performed.
1-4
3-12·79
Nonerequired
Inreview
10-17·77
4-27·77
3-12·79
4-2().77
In revi_
None required
11·16-78
3-7-77
12-10-76
11·22·78.11-7-78
2·23-77
11-22·78
11·22-78
Continui"l
2-6-78
USEO
UBWa.UWPCC
UBWa.IJWPCC
UBAa.UACC
UBSWM
BlM
USNRC
UBS
USEPA
w_~.-mita
..1943-109-6881
47331-(09-6721 .w_~lity Construction Pemllt
Public drinking ....syItefl'I
Air0u8I1tv Construction Pwmit
Mill U1ili,..disposal
Recording of mill siUl c1.ims
Sou/'CII MaUIri.1 Uetllle
SaniUltion fac:iliti.
~onofsillllificant dlUlrioration
PwrnitOI'ioin-
.Exp/anation ofacronyms and initialisms:Utah SUUI E"IinemOffiCI.USEO;UtItt BInMIof WllUIf Quality.
UBWQ;Utah Water Pollution Control CommitUII.UWPCC;Utah BurNU of Air OUIllty.UBAO:UtahAireor-.
vation Committ8e.UACC;UU1h BurNU ofSolidWaste Managtment.UBSWM;U.s.BurNU of Land ~gIIYleIlt.
BlM;U.s.Nuet_R~latoryCommiaion.USNRC;UU1h Bureau ofSani1ation.UBS:and U.s.EnvironmlOUll·
ProtectionAgency.USEPA.
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2.It is not ZikeZy that the taking of any particuZalo Zicenaing acticm of this type during
the time frame under considePation ruouZd constituu a CO/I'I7Iitment of NSOlQ'CeS that llJOUZd
tend to significantZy forBcZose the aZternatives fIlJaitobZe with respect to any other
individuaZ Zicensing action of this type.
The proposed action involves the construction and operation of a mill to produce yellow
cake from local uranium ore bodies.As pointed out in the response to the first criterion,
uranium mills are normally located close to economically exploitable ore bodies.The ore
would not likely be exploited-to provide feed for a more distant mill.As to the commit-
ment of resources,none of the materials involved in the construction and operation of the
mill are unique or in short supply;hence,licensing this mill would not effect any
licensing action with respect to other mills.Air,land,and water resources would be
used locally but not to an extent to preclude the erection and operation of another mill.
3.It is ZikeZy that any envizeonmentaZ impacts associated lJith any individuaZ Zicensing
action of this type hlOUZd btl such that they couZd adequatliZy be add:rsssed lJithin the
contert of the indi1JiduaZ ZicensB appZication lJ.'i.thout ovezokJoking any aumuZative
envi1'01111lentaZ impact.
This Environmental Statement contains an assessment of the environmental impacts associated
with the proposed licensing action and their severity,and includes proposed monitoring
programs and actions to mitigate the impacts.Cumulative impacts have been addressed
within the context of the individual license.The relative isolation of the proposedsitevirtuallyensuresthatallappropriateenvironmentalimpactscanbeadequately
addressed in this site-specific Environmental Statement.Adverse effects characteristic
of all uranium mills will be evaluated in a forthcoming generic environmental statement.
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The major objective of the generic statement is the generation of proposals to mitigate
such effects.
4.It is Ukel,y that any technical,issues that may arise in the course of a review of an
individual,Ucense appUcation can be resol,ved within that context.
The applicant has co~sidered alternative mill processes,tailings,disposal methods,and
other technical issues in its license application and Environmental Report.The staff
has reviewed the applicant's evaluations and,in addition,has evaluated other technical
issues.All of these evaluations and,presumably,any further technical issues that
may arise during review are resolvable within the content of the individual licensing
action,inasmuch as this mill is independent of other mills.In addition,the licensewillbeconditionedasrequiredbytheFederal,Register notice of June 3,1976,to permit
revision of waste generation,waste management,and other practices.
5.A deferral,on Ucensing actions of this type wouUl resu"Lt in substantial,ham to the
pubUc interest as indicated above because of uraniwn fuel,requirements of operating
reactors and reactors now under construction.
As previously stated by the NRC~"the full capacity of the existing mills will be
required to support presently operating nuclear power reactors and those expected to
to begi n operation in 1977."The Wlli te Mesa mi 11 is one of a small number of new mi 11 s .
that have been proposed in the last several years and a deferral of its operation could
decrease the supply of uranium and extend the time required for the delivery of fuel toreactorsnowoperatingorunderconstruction.This could adversely affect the abilityofreactorstodeliverneededelectricalpower.Such a short-fall of electrical energyisgenerallyconstruedtobeharmfultothepublicinterest•.(See also Sects.10.5 and10.6 and Appendix B.)
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REFERENCES FOR SECTION 1
1.Energy Fuels Nuclear.Inc.,"Application for Source Material License (NRC-2)".
February 6.1978,revised September 26.1978.
2.Energy Fuels Nuclear.Inc••"Environmental Report.White Mesa Uranium Project.
San Juan County.Utah",January 30.1978,revised May 15.1978.
3.Energy Fuels Nuclear.Inc.,letter to NRC.November 8.1978.
4."UranilJlll Milling.Intent to Prepare a Generic Environmental Impact Statement."Federal
Register (41 FR 22430).June 3,1976.
2.THE EXISTING ENVIRONMENT
2.1 CLIMATE
2.1.1 General influences
Although varying somewhat with elevation and terrain in the vicinity of the site.the climate
can generally be described as semiarid.Skies are usually clear with abundant sunshine.
precipitation is light.humidity is low.and evaporation is high.Daily ranges in temperature
are relatively large.and winds are normally light to moderate.Influences that would result
in synoptic meteorological conditions are relatively weak;as a result.topography and local
micrometeorologica1 effects play an important role in determining climate in the region.
Seasons are well defined in the region.Winters are cold but usually not severe.and summers
are warm.The normal mean annual temperature reported for Blanding.Utah.is about lOoe (SO°F),as shown in Table 2.1.January is usually the coldest month in the region.with a normal mean
monthly temperature of about _3°C (27°F).Temperatures of -18°C (OOF)or below may occur inabouttwoofeverythreeyears.but temperatures below~26°c (-15°F)are rare.July is gener-
ally the warmest month.having a normal mean monthly temperature of about 23°C (73°F).Temper-
atures above 32°C (gO°F)are not uncommon in the summer and are reported to occur about 34 days
a year;however,temperatures above 38°C (100°F)occur rarely.
2.1.2 Precipitation
Precipitation in the vicinity of the White Mesa Uranium Project is light (Table 2.2).Normal
annual precipitation is about 30 cm (12 in.).Most precipitation in the area is rainfall,withabout25%of the annual total in the form of snowfall.
There are two separate rainfall seasons in the region.The first occurs in late summer and
early autumn when moisture-laden air masses occasiona11y.move in fran the Gulf of Mexico.
resulting in showers and thunderstorms.The second rainfall period occurs during the winter
when Pacific storms frequent the region.
2.1.3 Winds
Wind speeds are generally light to moderate at the site during all seasons.with occasional
strong winds during late winter and spring frontal activity and during thunderstorms in the
summer.Southerly wind directions are reported to prevail throughout the year.Summaries of
wind direction and wind speed distributions are given in Tables 0.1 and 0.2 of Appendix D.
2.1.4 Storms
Thunderstorms are frequent·during the summer and early fall when moist air moves into the area
from the Gulf of Mexico.Related precipitation is usually light.but a heavy local storm can
produce over an inch of rain in one day.The maximum 24-hr precipitation reported.to havefallenduringa30-year period at Blanding was 5.02 em (1.98 in.).Hailstorms are uncommon in
this area.Although winter storms may occasionally deposit comparable amounts of moisture,
maximum short-term precipitation is usually associated with summer thunderstorms.
Tornadoes have been observed in the general region.but they occur infrequently (see
Sect.5.1.3.1 for estimate of probability).Strong winds can occur in the area along with
thunderstorm activity in the spring and summer.The White Mesa site is susceptible to occa-
sional duststorms.which vary greatly in intensity.duration,and time of occurrence.The
basic conditions for blowing dust in the region are created by wide areas of exposed dry top-
soil and strong,turbulent winds.Duststorms usually occur following frontal passages during
the warmer months and are occasionally associated with thunderstorm activities.
2-1
..~
Table 2.2.Precipitation m.nlandlllltr_at Blanding,U....
Total
Month Mean monthly Maximum monthly Greatest daily Vearemin.em in.em in.
January 3.04 1.20 10.31 4.06 2.64 1.04 1952
February 2.95 1.16 4.39 1.73 2.62 1.03 1937
March.2.38 0.94 5.00 1.97 2.54 1.00 1937
April 2.18 0.86 5.41 2.13 2.69 1.06 1957
May 1.63 0.64 5.11 2.01 2.39 0.94 1947
June 1.39 0.55 5.51 2.17 3.56 1.40 1938
July 2.13 0.64 7.79 3.07 3.35 1.32 1930
Au~1t 3.02 1.19 12.59 4.98 5.03 1.98 1951
September 3.02 1.19 9.60 3.78 3.07 1.21 1933
October 3.51 1.38 16.79 6.61 3.94 1.55 1940
November 1.88 0.74 5.21 2.05 2.41 0.95 1946
December 3.20 1.26 9.29 3.68 3.56 1.40 1931
-Period of record:1931-1980130 .,.anl.
Source:Plateau Resources,Limited,Appliution for ~~n.ILi_,Tabl.2.2·2,p.2·8,Apr.
3,1978.
-
2-3
2.2 AIR QUALITY
,j._';
The proposed mill site lies within the jurisdiction of the Four Corners Interstate Air Quality
control Region No.14,which encompasses parts of Colorado,Arizona,New Mexico,and Utah.The
air quality of the region is evaluated according to a classification system that was established
in 1971 for all Air Quality Control Regions (AQCR)in the United States (ER,Sect.2.7.4.2).
The classification system rates the five major air pollutants (particulate matter,sulfur
dioxide,nitrogen oxides,carbon monoxide,and photochemical oxidants)as having a priority
of I,II,or III.A priority I rating means that a portion of the region is significantly
violating Federal standards for a particular pollutant and special emission controls are needed.
If the emissions are predominately from a single-point source,then it is further classified as
IA.A priority rating of II indicates a better quality of air in the region;a priori~y III
rating classifies the highest quality.The concentrations that define the classificatlon are
outlined in Table 2.3.
Table 2.3.Federal regional priority classifications based
onambient air quality
Air quality for each priority groupS
Average time II III
Annual >100pg/m3 60-100/lg/m3 <60pg/m3
24 hr >455/lg/m3 260-455/lg/m3 <260/lgfm3
3 hr 1300 /lg/m3 <1300/lg/m3
Annual >95/lg/m3 60-95/lg/m3 <60/lg/m3
24 hr >325pg/m3 150-325/lg/m3 <150/lg/m3
8 hr >14 mg/m3 <14 mg/m3
1 hr >55mg/m3 <55 mg/m3
Annual >110/lg/m3 <110pg/m3
1 hr >195/lg/m3 <195pg/m3
Pollutant
Nitrogen
dioxide
Photochemical
oxidants
Carbon
monoxide
Particulate
matter
Sulfur oxides
a In the absence of measured data to the contrary,any region containing an area
whose 1970 "urban place"population exceeds 200.000 will be classified priority I.All
others will be classified priority III.Hydrocarbon classifications will be same as for
photochemical oxidants.
Source:ER,Table 2.7-20.
The priority classifications for the Four Corners Interstate AQCR,which includes the proposed
mill site,are presented below:
Sulfur
dioxides
Particulate
matter
Nitrogen
oxides
Carbon
monoxide
Photochemical
oxidants (Hc)
Priority
classification IA IA III III III
The priority IA ratings for particulate matter and sulfur dioxide for the AQCR are due to emis-
sions from fossil-fueled power plants located within the region (ER,Sect.2.7.4.2).However,
none of the power plants lie within 50 km (31 miles)of the mill site,which suggests that the
air quality in the vicinity of the site may be better than the priority IA classification
indicates.
The Utah Division of Health monitors total suspended particulates and sulfur dioxide at a
station located 105 km (66 miles)west-southwest of the site at Bull Frog Marina.Except for
the short-term (24-hr)particulate measurement,all reported values (ER,Table 2.7-21)were
2-4
well below the Federal and State of Utah air quality standards.The 24-hr particulate
violations are believed to have been caused by dust blown by high winds.
Based on data collected from four sampling locations on the project site for one year,dust-fall averaged 33 g/m2 per month;the highest monthly average was 102 g/m2 occurring in August.l
Total suspended particulate monitoring from October 1977 through February 1978 revealed a geo-
metric mean of 18 ~g/m3.l Dustfall for this same time period averaged 23 g/m2 per month.If
a linear relationship between total suspended particulate matter and dustfall is assumed,the
annual geometric mean for total suspended particulates is expected to be 26 ~g/m3.This value
is well below the Federal and State air quality standard of 60 ~g/m3.The maximum 24-hr con-
centration was 79 ~g/m3,or approximately one-half of the Federal and State standard of
150 ~g/m3.Sulfation-rate monitoring for one year at four locations on the site indicate
that sulfur dioxide concentrations at the site vicinity are less than 0.005 ppm.1 The Federal
and State standard for the annual average of sulfur dioxide is 0.03 ppm.
2.3 TOPOGRAPHY
The site is located on a "peninsula"platform tilted slightly to the south-southeast and sur-
rounded on almost all sides by deep canyons,washes,or river valleys.Only a narrow neck of
land connects this platform with high country to the north,forming the foothills of the Abajo
Mountains.Even along this neck relatively deepstream courses intercept overland flow from the
higher country.Consequently,this platform (White Mesa)is well protected from runoff flood-
ing,except for that caused by incidental rainfall directly on the mesa itself.The land on
the mesa immediately surrounding the White Mesa site is relatively flat.
2.4 DEMOGRAPHY AND SOCIOECONOMIC PROFILE
The site of the proposed White Mesa Uranium Mill is in San Juan County in southeastern Utah
(Fig.2.1),approximately 8 km{5 miles)south of the city of Blanding.Energy Fuels Nuclear,
Inc.,currently operates an ore buying station on this property.Energy Fuels also operates anorebuyingstation'near Hanksville,Utah.It is intended that ore will be transported from
the Hanksville facility to the proposed mill on Utah Route 95,passing through portions of
Wayne,Garfield,and San Juan counties (ER,pp.2-4 to 2-7).It should be noted that Plateau
Resources Limited currently operates a uranium ore buying station in Blanding at a site located
approximately 3 km (1.9 miles)north of the Energy Fuels'White Mesa site.
Because of its close proximity to the proposed mill site,the city of Blanding is likely to
receive the largest share of this project's socioeconomic impacts.The communities of
Monticello and Bluff also are likely to share the effects of mill-induced population increases
and ensuing social impacts.These three communities and Hanksville have been studied for socio-
economic impacts.The counties of San Juan,Wayne,and Garfield have been examined where effectsarelikelytobegeneralizedoveralarger area.
2.4.1 Demography of the area
2.4.1.1 Current population and distribution
Compared to most eastern states,Utah is rather sparsely populated with a 1977 population of1,271,300 - a 20%increase since 1970.This population represents an overall density of
39.9 persons per square kilometer (15.4 per square mile),but nearly 70%of Utah's population
lives in the counties of Salt Lake,Utah,and Weber where Salt Lake City,Provo,and Ogden,
respectively,are located.
San Juan County,where the proposed White Mesa mill would be constructed,has a population of
13,000 (an increase of 35.3%from 1970).Wayne County,the site of the Hanksville ore buying
station,has a population of 1800 (a 21.4%increase since 1970).Garfield County has a total
population of 3600 (an increase of 14%from 1970).The data in Table 2.4 illustrate that whilethesethreecountieshaveexperiencedgrowthinrecentyears,their overall density has remained
low.
The closest city to the proposed mill site is Blanding (Table 2.5),which had a 1977 population
of 3075,up 37%from 1970.Monticello,the county seat,has 2208 residents,54%more than in
1970.Between them,these two communities account for nearly 40%of San Juan County's popu-
lation (ER,p.2-18).Another 46%of the total is made up of Navajo Indians living on or near
r
ttI
•
2-5
Es-.~e7
F1StotLAI(E
....,.,.ATIONAL FOREST
AESE"VATION
20 40
:s
Fig.2.1.Regional map of the White Mesa Uranium Project site.Source:Plateau
Resources,Ltd.,AppZiaation for a Sota'ae Material Liaense for the Blanding Ore Buying
Station,Grand Junction,Colo.,Apr.3,1978.
Table 2.4.Area and populationfor Uteh and Wayne.Garfield.
and san Juan counties.1970 and 1977
Population per square kilometer
State or
county
Land area
km2 sq miles
Total population
1970 1977"Change
l%l
1970
SQ.mile
1977"
sq.mile
Utah.total
Wayne
Garfield
San Juan
213.190
6.444
13.507
20,412
82.340
2.489
5.217
7.884
1.059.273
1,483
3.157
9.606
1.271.300
1.800
3.600
13.000
20.0
21.4
14.0
35.3
5.0
0.2
0.2
0.5
12.9
0.6
0.6
1.2
5.9
0.3
0.3
0.5
15.4
0.7
0.7
1.6
'Preliminary data.
Source:U.S.Bureau of Census.1970;Utah Population Work Committee.1977.
2-6
Table 2.5.Population centers near the
White Mesa Uranium Project
Approximate distance from
the project sites
Blanding site Hanksville site
km miles km miles
Colorado
GrandJunction"290 180 260 160
Cortez"140 85 346 215
Durango"210 130 420 260
Utah
Blanding 8 5 209 130Monticello4830225140Bluff3220225140
Hanksville 225 140 16 10
Moab"130 80 193 120
New Mexico
Farmington"260 160 750 290
"Population greater than 4500 according to 1975 Census
records.
Source:Adapted from ER,Table 2.2-1.
the Nav~jo Reservation in southern San Juan County (ER,p.2-15).The town of Bluff has apopu1atlonof280,more than double its population in 1970 (ER,p.2-18).
With~n a 290-km (~80-mile)radius of the proposed mill there are several larger cities that
are lmportant reglona1 centers (See Table 2.5 for distance relationships to the project sites).Moab,Utah,the closest and also the smallest,has a population of approximately 4500 according
to 1976 census recor.ds (ER,Table 2.2-1).Cortez,Colorado,has a population slightly under
6800 and Durango,Colorado,has nearly 12,000 residents.Both Grand Junction,Colorado and
Farmington,New Mexico,have populations approaching 28,000.'
Approximately 16 km (10 miles)from the Hanksville ore buying station is the town of Hanksville,which had a 1975 population of 160.
The area within an 8-km (5-mile)radius of the proposed mill is sparsely populated and primarily
agricultural.It is estimated that about 70 to 80 people currently reside here.The closest
currently inhabitated dwelling unit is approximately 5 km (3 miles)north of the site (Appli-
cant's responses to ER questions,Enclosure 2,p.2),but most area residents live to the
south in the Ute Mountain community of White Mesa.The Blanding airport also lies within this8-km (5-mile)zone,and approximately 30 to 40 people use that facility daily.
2.4.1.2 Projected population and distribution
Between now and the year 2000.Utah's population is expected to rise steadily according to
projections prepared by the Utah Agricultural Experiment Station (Table 2.6).Both high and
low projections assume a gradual decline in mortality and constant fertility.The difference
between them is that the high figures also assume a positive net migration while the low
figures are based on no net migration at all.Projections for San Juan County indicate a
much greater growth rate than for the State as a whole (Table 2.6).
According to the city manager of Blanding.a population increase of almost 1500 is ex~ected
within the next three years.bringing the number of city residents to 4540 by 1981 .(C1ty Manager
of Blanding.Utah.personal communication,July 10.1978).This estimate represents ~n increaseof47.6%over the 1977 population and is based on the assumption that the proposed Wh,te Mesa
uranium mill will be built.Monticello's city manager is also predicting growth.but at a
lesser rate than for Blanding.Between now and 1983.an increase of approximately 600 (or
27%)is expected (City Manager of Monticello.Utah.personal communication.July 30.1978).
IIr
•
2-7
Table 2.6.Population projections"San Juan,Wayne,and Garfield
counties,compared to the State-----_.----------.
1975b 1980 1990 2000 Percent increase
(1975-2000)
Utah
High 1,216,843 1.420,553 1,803,985 2,163,927 78
Low 1,206,584 1,302,815 1.484,231 1,655,528 37
San Juan County
High 12,816 17,373 26,002 33,300 160
Low 12,716 13,954 16,917 19,753 55
Wayne County
CII~High 1,960 2,660 3,770 4,530 131.1
\L.l Low 1,950 2,060 2,310 2,510 28.7
Garfield County
High 3.480 3,940 4,670 5,960 71.3
Low 3,470 3,760 4.460 5,120 47.6
•High projections assume a gradual decline in mortality,constant fertility,and positive net
migration.Low projections assume a gradual decline in mortality,constant fertility,and no net
migration,
b U.S.Census estimation for 1975 indicates that actual population for the State and all three
counties was below the "low"projection presented in this table.
Source:EA,Table 2,2-22,
The Blanding airport.about 5.6 km (3.5 miles)north of the prospective mill site.has plans
to expand its existing runway and storage areas by summer of 1979.An increase in flights
to and from the facility may accompany these improvements (Manager of Blanding City Airport.
personal communication.Aug.2.1978).The Ute Mountain Indian community of White Mesa is
currently considering requesting the use of the idle Blanding Launch Site.part of the White
Sands Missile Range.from the U.S.Army.This property.which is approximately 6 km (4 miles)
south of the mill site,would be used for a community center and would not have permanent .
residents.
2.4.1.3 Transient population
Although the permanent population in southeastern Utah is relatively low.this area receives
a substantial number of tourists each year (Table 2.7).Capital Reef National Park alone had
nearly 0.5 million visitors in 1976.The exact numbers fluctuate from year to year,but the
overall trend appears to be toward increasing visitation.Manti~La Sal Forest,which is six
miles north of 81anding.is the nearest recreation area.
2.4.2 Socioeconomic profiles
2.4.2.1 Social profile
Housing
Blanding.From 1972 to 1975.approximately 12 new units were added each year.but in 1976 that
figure rose to 37.2•3 In 1977.43 new dwelling units were added,and this accelerated rate of
construction appears to be continuing (City Manager of Blanding.Utah.personal communication.
July 10.1978).Mobile homes in this area are often found on individual lots in single-family
neighborhoods as well as in mobile home parks.
At present.the supply of new housing is keeping up with the number of residences.and the
vacancy rate is very low.Approximately 200 lots are available for single-family houses in
Blanding to accommodate future growth.There are also around 25 current vacancies in a local
mobile home park (ER.p.4-18).The supply of rental units in Blanding.as in many small
cities,is low (ER.p.2-50).
Visitors (thousandsl
Table 2.7.Visitor statistics,recreation areas in southeastern Utah"
1977 (January-September)197619751974
59.0 71.8 80.0 67.3
88.7 76.4 NAc
234.0 292.1 469.6 364.2
(through August)
11.0 13.2 19.4 16.2
40.3 48.4 71.9 67.1
12.0
42.7
1973
62.6
100.9
311.2
12.1
58.5
1972
272.0
60.8
60.8
105.3
Hovenweep National Monumenrt
Natural 8ridges National Monument
Area
Glen Canyon National Recreation Area
Canyonlands National Park
Manti-La Sal National Forest
(visitor days)b
Capital Reef National Park
"Data refer to actual visitations for each area except Manti-La Sal National Forest.Here,data indicate recreation visitor
days.A visitor day is the equivalent of one person entering an area for 12 hr.
b Data refer to the Monticello Ranger Districtonly.
clndicates data not available.
d Data refer to the Square Tower Ruin Unit,near 8landing.
Source:ER,Table 2.2-5.
2 ~-0
Public services
Monticello.During the five years of 1972 through 1976,the supply of housing in Monticellowaslncreasingatapproximatelysixunitsperyear.4,5 In 1977 this figure jumped to around
60 units per year,and between 60 and 80 new units are expected to be constructed in 1978;
however,the demand for housing has not yet exceeded the supply (City Manager of Monticello,
Utah,private communication,July 20,1978).An expected annexation will double the size of
the city and provide room for at least 150 more single-family homes.Approximately 35 vacancies
now exist in local mobile home parks (ER,p.4-18).As in Blanding,rental housing is scarce.
A 23~unit apartment is currently being constructed to accommodate some of the demand for this
kind of housing (City Manager of Monticello,Utah,private communication,July 20.1978).
Bluff.Over the last five years.the supply of new housing in Bluff has increased at a rate
or-TTve or six new housing units annually and the demand has not exceeded the supply.The
existence of approximately 70 vacant lots with water connections and available spaces in two
mobile parks within the city limits indicate that Bluff is capable of accommodating future
growth (ER.p.2-56).
Blanding.Water is obtained from surface runoff and underground wells,and an 0.11-m3/sec
(1800-gpm)sewage treatment plant is operated by the city.Water consumption in 1976 averaged
0.023 m3/sec (547,000 gpd).The current system is adequate to handle moderate population
increases,and improvements are being planned to handle the influx of new residents expected by
1981 (City Manager of Blanding.Utah.personal communication,July 10.1978).Sewage treatment
is provided through a lagoon system.and improvements are planned for the near future.Elec-
tricity is provided through a city-owned distribution system;the city also provides solid
waste collection and disposal.Propane gas is available through two private distributors.but
there is no natural gas service (ER.p.2-46).Local streets are maintained jointly by the
city and county (Treasurer of San Juan County,Utah.personal communication.July 25.1978).
Hanksville.Hanksville currently has no excess housing supply,arid the majority of families
live in mobile homes.Hanksville is presently installing a new water system to service the
existing community and to provide service for 24 new building sites for permanent housing.
--..,as e
2-9
Blanding has a full-time police force of three officers and an auxiliary force of eight,and
a volunteer fire department provides fire protection.Health care is available through the
36-bed San Juan County Hospital in Monticello,a 31-bed nursing home in Blanding,and two local
doctors,one public healt~nurse,and one dentist.There is a mental health"clinic in town
with one full-time therapist (ER,p.2-47).
Two elementary schools and one high school serve Blanding.The combined capacity of the
elementary schools is 750 students;630 are current11 enrolled.With 874 students,however,
the high school has 174 students more than the planned capacity.The opening of two new high
schools,scheduled for the near future (one in 1978 and one in 1979/1980),should ease the
current overcrowding (ER,p.2-48).
Blanding's recreational resources consist of one swimming pool,one lighted ball field,one
nine-hole golf course,three parks,and a school softball field and gymnasium that are also
available for public use.6 Local residents also have access to several National parks,forests,
monuments,and recreation areas (Table 2.7).The San Juan County Library is located just north
of Blanding (Treasurer of San Juan County,Utah,personal communication,July 25,1978).In
addition,the applicant has recently provided support for certain recreational endeavors in the
local area through the sponsorship of athletic teams and related activities.To accommodate
anticipated future growth,the city has set apart an area for an additional ball field and
park.6
Monticello.Water is supplied by surface runoff and groundwater,and,as in Blanding,there
is a city-operated water treatment plant.Improvements to the water supply system are being
undertaken to raise its overall capacity (City Manager of Monticello,Utah,personal communi-
cation,July 20,1978).Primary and secondary sewage treatment is provided by a local digestor
plant,and future improvements are planned (ER,p.2-51).The City of Monticello distributes
electricity supplied by Utah Power and Light to city residents.The transmission system is now
at capacity,but Monticello's city manager has said that the city is currently considering
w~ys to expand its service area.Natural gas is available through the Utah Gas Service (ER,
p.2-53).Monticello currently operates a waste disposal service,and street maintenance is.a
joint responsibility of city and county.
Police and fire protection is provided by the three full-time police employees and one part-
time police employee.They are aided by the County Sheriff's Department and a volunteer fire
department with three trucks (ER,pp.2-53 and 2-54).The 36-bed San Juan County Hospital and
a small mental health clinic with one therapist and one outreach worker are in Monticello."
There is also a public health nurse in town.
There are an elementary school and a high school in town,both of which are currently operating
at about two-thirds of their peak capacity.The elementary school,which can handle S50
students,now has 365 enrolled.The high school,designed for 500,serves 370 students
(ER,p.2-54).
Three public parks,one swimming pool,one golf course,a local ski resort,and the National
areas listed in Table 2.7 provide recreational opportunities for area residents.One of the
city parks is currently being expanded,and it is the judgment of the city manager that
these facilities are adequate to handle future mill-induced population increases.6
Bluff.The water system for Bluff consists of three artesian wellS and a 760-m3 (2 x lOS-gal)
storage tank capable of servicing a population almost double the present one.Sewage treatment
is currently provided through individual septic tanks although construction of a community
treatment facility has been proposed (ER,p.2-56).
Two sheriff's deputies are responsible for local police protection,and fire protection is the
responsibility of an eight-person volunteer fire department.Bluff residents have access to
county health services in neighboring cities,and outreach workers for the Four Corners Mental
Health Agency are available.
One elementary school,with a capacity of 200,provides education for the 104 students.A pro-
posal for expansion of recreational facilities was recently defeated by community voters,
leaving one park,one ball field.and the recreational areas shown in Table 2.7.6
Table 2.8.Selected demographic characteristics.San Juan County.compared to Utah 119701
Culture
I
1II1,
,I
L ~,:...,..,
2.0
12.5
23.0
10.6
29.6
52.5
7.3
14.0
Utah
1.059.273
1.033.880
2.4
3.157
Garfield County
12.1 12.2
1.2 0.3
8.9 8.7
27.3 26.4
7.4 8.2
35.4 32.6
49.3 49.4
7.9 9.8
1.638
Wayne County
27.0
8.8
10.7
18.0
13.9
36.0
45.6
4.5
9.606
5.153
46.4
San Juan County
Source:ER.Tables 2.2-4 and 2.2-21.
Total population
Race
White
Other (%1
Education
Median school years
completed (population
25years and over)
Percent of population with
less than 5 years
Percent of population with
4 years ofcollege or more
Age
Median age
Percent under 5 years
Percent 5-17
Percent 18~
Percent 65+
2-10
Law enforcement is provided by one part-time sheriff and road maintenance is also provided
by the county.Ambulance and emergency medical services are available in town;however,the
nearest medical clinic is in Green River,97 km (60 miles)to the north.The nearest hospital
is over 160 km (100 miles)away in Moab (ER,p.2-72).
2.4.2.2 Economic profile
Between 1970 and April 1978,the number of nonagricultural payroll jobs in San Juan Ceunty
increased by over 1000 -from 1786 to 2452.The relative importance of the various economic
sectors also shifted in that period.Services stayed nearly the same;the relative importance
of trade,transportation,construction,and manufacturing declined slightly;and the signifi-
cance of finance,insurance,and real estate rose a little.The importance of mining and
Hanksville's 50 elementary students attend a local school with an enrollment capacity of 60.
Middle and high schoolers are bused to Bicknell,105 km (65 miles)away.The middle school
has a current enrollment of 105 and a capacity of 120;the high school has 155 students and
the ability to take 200 (ER,p.2-74)..
Navajo and Ute Indian populations concentrated in southern San Juan County have their own
cultural heritage.As shown in Table 2.8,almost half of the county's residents are nonwhite
(46.4%),and most of these are Navajos.Religion is another significant influence in south-
eastern Utah.The predominant Church of Jesus Christ of Latter Day Saints stresses within itsb~liefs the values of family life,education,and marriage and provides a focus for community
11fe.Table 2.8 also compares the age and educational attainment of the three counties and theStateasawhole.
Hanksville.A single privately owned well supplies water to Hanksville residents and is
operating at peak capacity although installation of a new water storage and distribution
system is under way.No community sewage is provided.A county dump is available for city
waste disposal (ER,p.2-72j.The Gar-Kane Power Company supplies electricity in this area
(ER,p.2-74).
~s
2-11
government changed dramatically,however.Employment in government services declined
from 31.6 to 24.5%,while mining climbed from 21.3 to 31.7%of the total.7
Because total employment increased so greatly,the absolute number of jobs rose in all cate-
gories.The largest increase by far,however,was in mining,which grew from 381 jobs in 1970
to 935 in April 1978.In the one-year period ending April 1978,the largest numerical increases
were experienced in const~uction,mining,trade,and services (Table 2.9).
Table 2.9.Nonagricultural payroll jobs in San Juan.Wayne.and Garfield
counties from April 1977 to April 1978
April Percent of April Percent of Percent change1977total1978total
San Juan County
Manufacturing 185 6.6 197 6.7 6.5
Mining 890 31.5 935 31.7 5.1
Construction 142 5.0 155 5.2 9.2
Transportation.commerce.utilities 157 5.6 168 5.7 7.0
Trade 400 14.2 424 14.4 6.0
Finance.insurance.real estate 25 0.9 27 0.9 8.0
Services 303 10.7 322 10.9 6.3
Government 718 25.5 724 24.5 0.8
Total 2820 100.0 2452 100.0 4.7
Wayne County
Manufacturing 28 6.5 24 6.5 3.6
Mining 48 11.1 50 11.2 4.2
Construction 63 14.6 64 15.4 9.5
Transportation.commerce.utilities 2 0.5 2 0.4
Trade 44 11.4 52 11.6 6.1
Finance.insurance.real estate 7 1.6 7 1.6
Services 23 5.3 24 5.4 4.3
Government 211 49.0 214 47.9 1.4
Total 431 100.0 447 100.0 3.7
Garfield County
Manufacturing 237 19.1 252 19.4 6.3
Mining 46 3.7 48 3.7 4.3
Construction 57 4.6 62 4.8 8.8
Transportation.commerce.utilities 66 5.3 71 5.4 7.6
~~Trade 184 14.9 195 15.0 6.0~.j Finance.insurance.real estate 14 1.1 15 1.2 7.1i~,j Services 288 23.3 306 23.6 6.2
Government 347 28.0 350 26.9 0.9
Total 1234 100.0 1244 100.0 4.8
Source:Utah Department of Employment Security.Research and Analysis Section.adapted from
QuanerlyEmploym.,t NtlwsJtlmrof Southtlastem DistrictofUtah,January-April 1978.
The mineral industry is extremely important to San Juan County,and uranium production is a
substantial component of this sector.In fact,San ·Juan County is the largest producer of
uranium in Utah,and this activity has increased dramatically since 1975 (Utah Geological
and Mineral Survey,private communication,July 17,1978).Natural gas and crude oil are
the other important materials being produced here (ER,p.2-32).
Tourism is also an important part of San Juan County's economy,a part that has been increasing
steadily in recent years.Between 1975 and 1977,tourist room rentals increased by 32.5%.
2-12
Total nonagricultural payroll employment in Wayne County was 447 in April 1978 (Table 2.9).
The government employed almost 50%of those workers,and construction,trade,and mining
activities accounted for nearly 40%.
In Garfield County,nonagricultural employment for April 1978 totaled 1244 (Table 2.9).The
.government accounted for slightly over 25%of this employment,services for slightly under 25%,
manufacturing for almost 20%,and trade for another 15%.
Between 1973 and 1977,per capita income for the State of Utah rose by 44%,from $4100 to
$5900.Increases in per capita income for San Juan County did not keep pace with raises else-
where.Income in 1973 was $2400,58.5%of the State average,and 1977 income was $3400 or
57.6%of the State figure (Table 2.10).
Between 1970 and 1977,unemployment fell for the State as a whole and for Wayne,Garfield,and
San Juan counties.The State figure went from 6.1 to 5.3%;Wayne County,from 8.5 to 7.2%;
Garfield,from 19.2 to 7.9%;and San Juan.from 10.7 to 8.1%(Table 2.11).
The characteristics of job applicants in San Juan County.where the White Mesa mill is to be
located,are listed in Table 2.12.Most jobs in mining are classified in the "miscellaneous·
section.
The number of retail and wholesale establishments and their sales are shown in Table 2.13 for
San Juan County and the cities of Blanding and Monticello.Since 1967.county wholesale and
retail sales have both nearly tripled.8 Retail sales are almost evenly divided between Blanding
and Monticello,together accounting for 94.3%of the county's total retail activity.
In 1977,San Juan County levied an ad valorem tax of 16 mills on the assessed value of all
property in the county for the general fund.An additional 40 mills was collected for the
county school district and a final 2 mills for the countywide water conservation district.The
communities of Monticello.Blanding.and Bluff also levied an extra 15,21.and 10 mills.
respectively.on the assessed value of all property within their corporate limits.Finally,
the Monticello and Blanding Cemetery Districts each collected 2 mills on all property within
those district boundaries.Mines and mills are subject to the above taxes as is all other real
property.The total amount collected from all these funds combined was $5.126.748 (Treasurer
of San Juan County.Utah.personal communication.July 25,1978).two-thirds of which went to
the County School District.In addition to the property tax.San Juan County also received
$87.496 in sales taxes.
San Juan County handles its financial affairs through a number of separate funds.th~largest
of which is the general fund (Appendix C).Within this fund.the property tax comprlses the
largest single source of revenue,accounting for slightly over 33%of the 1977 total.Shared
revenues from the State of Utah contributed another 20.1%,and Federal shared revenues and
in-lieu-of-tax payments added another 15.3%.
The largest expenditure for San Juan County in 1977 was for road maintenance ($1.176.000)
amounting to slightly over one-half of total county funds.Other large outlays were 11.2%
for health services and 6.4%for the Sheriff's Department.
In the fiscal year ending in June 1977.the largest source of reve~ue ~or the ci~y of
Blanding's general fund (Appendix C)was th~sa~e of a general o~11gJtlon e1ectrlc-.
water-and sewer-improvement bond issue.yle1dlng $225.000.ThlS was followed by
sli9ht;y over $55.000 from sales and use taxes and a little more than $44.000 from prope~ty
taxes.Federal revenue sharing and waste collection and disposal f~e~were the.other maJor
sources of funds.each contributing about $18.000 to the total.Utlllty operatlons were
financed through a separate fund.
Blanding's major expenditures in the same year were for public utility capital improvements a~d
police expenses.each of which cost less than $50.000.Street maintenanc~cost abo~t half thlS
amount,and waste collection and airport funds made up the last of the maJor expendltures.
;
f
----,.3
2-'j 3
Table 2.10.Per capita incomes for Utah and Wayne.Garfield.and
San Juan counties.1973-1977
State or cou nty 1973 1974 1975 1976"1977'
Utah $4,100 $4,500 $4,800 $5,300 $5,900
Wayne 3,100 3,400 3,800 4,100 6,100
Garfield 3,400 3.300 3,500 4.200 5,000
San Juan 2,400 2.700 2,900 2.900 3,400
aRevised.
bpreliminaryestimate.
Source:Utah Department of Employment Security,Research and
Analysis Section.adapted from Quanerly Employment Newsletter of
Southeastern Districtof Urah.January-March 1978.
Table 2,11.Total civilian labor and unemployment for Utah and Wayne.
Garfield.and San Juan counties.1970and 1977
State or labor force Unemployment Unemployment rate
county 1970 1977"1970 1977"1970 1977"
Utah 414.248 551.900 25.214 29.500 6.1 5.3
Wayne 664 880 57 63 8.5 7.2
Garfield 1,483 1.773 285 140 19.2 7.9
San Juan 3.015 4.198 322 341 10.7 8.1
·Preliminary.
Source:Utah Department of Employment Security.Research and Analysis Section.
adapted from Quarterly Employment Newslerrer of Southeastern District of Ural/,
January-March 1978.
Includes persons actively seeking employment.
some of whom were employed at the time
Table 2.12.Occupational char_risties of
job applicants in the Blanding area.
January-March 1978
Source:Utah Department of EmploymentSecurity.
Research and Analysis Section.adapted from QUllr·
ttlrly Emp/oym",t NtlwsIMttlr of SouthelJsrem Di6-
tricrofur8h,January-March 1978.
44
59
76
39
5
27
56
156
51
513
Professional.technical.managerial
Clerical.sales
Service
Farm.fisheries.forestry
Processing
Machine trades
Bench work
Structural
Miscellaneous
Total
2-14
Table 2.13.Retail and wholesale activity in San Juan County,
Blanding,and ~onticello (1976)
San Juan County Blanding Monticello
Number of retail 101 35 40
establishments
Retail sales $15,300,000 $7,150,000 $7,280,000
Number of wholesale 9 3 3
establishments
Wholesale sales $5,600,000 NAa NA
aNA:Information is not available.
Source:Utah Industrial Development Information System,Economic Facts
forSan Juan County,Blanding,and Monticello,1977.
As in Blanding,Monticello has a separate fund for operating public utilities.Over $350,000wasspentduringfiscalyear1977-1978.Slightly over half of the city's nearly $150,000 in
general fund revenues for the fiscal year ending June 1978 came from sales and use taxes,while
property taxes contributed another 25%.Unlike the county,both Monticello and Blanding receive
more of their general funds from sales taxes than from property taxes.The largest expenditure
in 1978 was the $54,800 spent on administration.This figure was followed by the $49,400 spentforpoliceprotection.
2.4.2.3 Transportation
A system of two-lane paved highways and unimproved roads accounts for virtually all transport
of peopl e and products in and out of San Juan County.Although Bl andi ng,Bluff,Monti cell0,
.and Canyonlands National Park have small municipal airports,there is no rail,bus,or com-
mercial air service (ER,p.2-30).
U.S.Route 163 receives a greater amount of traffic than any other road in the county.This
highway runs between 1-70 on the north [approximately 161 km (100 miles)from the proposed
mill]and U.S.Route 160 in Arizona to the south;the highway passes through Monticello,Blanding,and Bluff.The heaviest traffic in the county is on this artery just north of
Monticello,where the average daily vehicles were about 2685 in 1975.More recent figures
indicate a 43%increase in traffic in this area between 1975 and 1977 (ER,p.2-30).
Traffic volumes on Utah "Route 95 from the Blanding area to Hanksville are much lighter but
have been increasing in recent years (Table 2.14).From 1975 to ]977,an increase of 33%was
observed on Highway 95 south of Hanksville (ER,p.2-30).U.S.Route 666 from Monticello to
Cortez,Colorado,also carries a significant amount of traffic.9 All of the roads in this area
carry a substantial amount of out-of-state traffic (Table 2.14).
2.5 LAND USE
2.5.1 Land resources
Southeastern Utah is known as the Canyonlands area;an arid climate and rugged terrain have
limited permanent settlement of this region.Large rock formations and dee~narrow canyons
are characteristic of the area.and these.combined with the Indian ruins found here.are
attracting increasing numbers of tourists (ER.p.2-23).Much of this area is isolated.how-
ever.and the population density is low (Sect.2.4.1.1).
The site of the proposed White Mesa Uranium Mill consists of 600 ha (1480 acres).approximately
8 km (5 miles)south of the city of Blanding off U.S.Route 163.About one-third of the total
site is scheduled to be actually used for mill operations and tailings disposal.The immediate
area is bordered by both privately owned and Federal land.
2-15
Tabl.2.14.Traffic volumes in 1975for So"Juan County and Blanding·Hanksvili.route
Highway Segment
Approximate
Averagedaily percentageof
traffic count:!out-of·state
passenger tr~ffic
1;:.__
Utah Route 95 Blanding to Natural Bridges
Nat!.Monument
Natural Bridges to Hite
Hire to Hanksville
U.S.Route 163 Monticello to La Sal Junction
Monticelloto Blanding
Blanding to Utah Route 262 turnoff
Utah Route 262 to Bluff
Bluff to Mexican Hat
Utah Route 263 Route 95 to Halls Crossing at
Glen Canyon
Utah Route 261 Route 95 to Moxican Hat
310
95
95-290
1490-26B5
860-1985
740-925
530
560
25-35
130
20
10
10-20
20-35
10-25
20-30
40
40
20
50
"Two figures in this column represent values given for different points along the route.One
figure indicates that a traffic,countwas taken at only one location.
Source:ER.Table 2.2·9.
Much of the land in San Juan County is Federally owned (see Table 2.15).Approximately
two-thirds of this land is administered by the U.S.Bureau of Land Management for multiple
uses such as grazing,mineral extraction,timber production,and wildlife management.Another
one-fifth of the Federal land is managed by the National Park Service and slightly less than
one-sixth is under the control of the U.S.Forest Service (ER,p.2-25).One-fourth of the
total area is Indian land.Nearly all of this territory is part of the Navajo Indian Reser-
vation,but a small portion belongs to the Ute Mountain tribe (ER,pp.2-23 to 2-26).TheStateowns6.5%of San Juan County,leaving only 8.3%in private hands (Table 2.15).
Table 2.15.Land ownership.Wayne,Garfield.and San Juan counties,1967
Wayne County Garfield County San Juan County
ha acres Percentage ha aeres Percentage ha acres Percentage
Federal 542.055 1.338.875 84.2 1.195.842 2.953.729 89.0 1,208,247 2.985.630 59.8
State 59.373 146.651 9.2 90.167 222.712 6.7 131.707 325,317 6.5
Indian 0 0 0 0 0 0 505.086 1.247.563 25.0
Private 40,472 99.965 6.3 53.578 132.337 4.0 168.664 416.600 8.3
Urban and 2.193 5,416 0.3 3.507 8.662 0.3 6,177 15.253 0.3
transportation
Small water"54 133 b 389 960 b 404 997 b
Total area 644.146 1.591.040 100.0 1.343.481 3,318.400 100.0 2,019,940 4.991.360 100.0
"Includes water areas of0.8 to 16 ha (2 to40 acresl and streams less than0.20 km (0.125 milel in length
b Less than O.1%..
Source:ER.Table 2.2·23.
In Wayne County,much of the land is Federally owned (Table 2.15).As in San Juan County,
administration is split between the U.S.Bureau of Land Management,the U.S.Forest Service,
and the National Park Service.The State controls 9.2%of the land in Wayne County,and 6.3%is in private hands.There is no Indian land.
2-16
Garfield County exhibits almost the same ownership pattern as neighboring Wayne County.Federal
land control is exercised by the U.S.Bureau of Land Management,the U.S.Forest Service,and
the National Park Service (ER,p.2-63).State land accounts for 6.7%of the total,and privatelandcomprisesanother4%.There is no Indian land (Table 2.15).
Because of the arid nature of this area,the primary agricultural use of the non-Federal prop-
erty in all three counties is rangeland (Table 2.16).The land within 8 km (5 miles)of the
proposed mill is primarily used for grazing.In addition to the uranium ore buying station
currently operated at the site by Energy Fuels Nuclear,Inc.,nonagricultural land uses in
this area include the Blanding airport,a small commercial establishment,a part of the Ute
Mountain Indian community of White Mesa,several structures connected with the U.S.Army's
Blanding Launch Site,and another ore-buying station,operated by Plateau Resources,Inc.
(ER,p.2-29).
Table 2.16.Land use in Wayne.Garfield.and San Juan counties exduding Federal land.1967'"
Wayne County Garfield County San JuanCounty
ha acres Percentage ha acres Percentage ha acres Percentage
Cropland 8.829 21.815 8.6 13.651 33.732 9.2 59.093 146.016 7.3
Irrigated 8.829 21.815 8.6 12.897 31.869 8.7 2.878 7.111 0.4
Nonirrigated 0 0 0 754 1.863 0.5 56.215 138.905 6.9
Pasture 0 0 0 1.481 3.660 1.0 24,497 60.531 3.0
Rangeland 69,465 171.645 68.0 91.923 227.139 62.3 511.139 1.263.007 63.0
Forest 4.235 10,464 4.2 24.331 60.120 16.5 187.100 462.318 23.0
Otherb 17.277 42.691 16.9 12.302 30.398 8.3 23.314 57.608 2.9
Urban and 2.192 5,416 2.1 3.506 8.662 2.4 6.173 15.253 0.8
transportation
Small water 54 133 389 960 0.3 403 997
Total non-Federal 10.205 252.165 100.0 147.582 364.671 100.0 811.719 2.005.730 100.0
Federal 541.843 1.338.875 1.195.374 2.953.729 1.208.284 2.985.630
Total countY acreage 643.894 1.591.040 1.342.956 3.318,400 2.020.003 4.991.360
·Water areas of mae than 16 km (40 acres)and rivers wider than 0.20 km (0.125 mile)are excluded.
b "Otr.er"includes strip mine areas.salt flats.mud flats.marshes,rock outcrops.feed lOts.farm roads.ditch banks.and miscellaneous
agricultural land.
clncludes water areas of 0.8 to 16 ha (2 to40 acres)and streams less than 0.20 km (0.125 mile)in length.
Source:ER.Tables 2.2·8and 2.2-24.
2.5.1.1 Mill ownership
The surface area of the entire 600-ha (1480-acre)project site is currently owned by EnergyFuelsNuclear,Inc.(ER,p.2-4).
2.5.1.2 Farmlands
Because the rugged terrain and arid climate of the White Mesa region have restricted development
of cultivated croplands,grazing is the predominant agricultural land use (Table 2.16).Dry
farming produces primarily wheat and beans.No unique or prime farmlands exist on the mill
site or in the surrounding area.6
The Federal government owns and administers,through the U.S.Bureau of Land Management,
approximately 60%of the total land area of San Juan County (ER,Sect.2.2.1.3).This land,
classified as multiple use,is leased for grazing,oil and gas exploration,and mining claims,
and is managed for wildlife and recreation.The majority (63%)of the private land in San Juan
County is rangeland (Table 2.16).
I
~.-.
2-17
The site for the proposed uranium mill (Fig.2.2)was previously used for grazing.Also,poten-
tial grazing land lies on all sides of the applicant's property (Fig.2.2).Based upon primary
production for rangeland in fair condition,and assuming 50%of the primary production will be
grazed,grazing capacity of rangeland in the vicinity of the site is conservatively estimated at
about 0.69 to 1.24 animal units months (AU/Is)per hectare (0.28 to 0.5 AUMs per acre);tO that is.
about 0.8 to 1.4 ha (2 to 3.6 acres)of rangeland are required to support one cow or five sheep
for one month per year.The nearest cultivated cropland (alfalfa)occurs 2.4 km (1.5 miles)
north of the site boundary,and the nearest garden plot lies approximately 1.6 km (l mile)
north.tO
2.5.1.3 Urban areas
The communities of Blanding,Monticello,and Bluff,all within 48 km (30 ~i1es)of the proposed
White Mesa mill site,and the town of Hanksville,16 km (10 miles)from the Hanksville are
buying station,have been discussed in detail in Sects.2.4.1.1,2.4.1.2,and 2.4.2.1.The two
largest of these,Blanding and Monticello,have a number of regulations governing land use,
including zoning,subdivision regulations,and building codes (City Manager of Blanding,Utah,
and City Manager of Monticello,Utah,personal communications,July 10,1978,and July 20,1978,
respectively).
2.5.2 Historical,scenic,and archeological resources
2.5.2.1 Historical sites
Although there are no cultural sites on or adjacent to the proposed mill site which are presently
included in the National Register of Historic Places (National Register),the White Mesa
Archeological District has been determined eligible for inclusion in the National Register.
Landmarks of southeastern Urah currently included in the National Register are summarized in
Table 2.17.Closest to the proposed mill site is the Edge of Cedars Indian Ruin,located inBlanding(approximately six miles north of the proposed mill site).
A historical survey was conducted on the proposed mill site,and six historical sites were
identified.Five of the six historical sites are curren~ly under review to determine eligibilityfortheNationalRegister.
2.5.2.2 Scenic areas
Southeastern Utah is known for its unusual scenic qualities,in particular the abundance of
massive stone arches and other outstanding rock formations.The general area features a uniquely
rugged terrain with wide vistas,badlands,and steep canyons.
Canyonlands National Park is an area of unusual,interesting geological formations,and the Glen
Canyon National Recreation Area on Lake Powell is a man-made lake on the Colorado River.
Capitol Reef National Park contains numerous colorful stone formations.At Natural Bridges
Monument,rock arches span deep canyons,forming the largest natural bridges in the world.
These and other natural and scenic landmarks draw visitors to southeastern Utah every year.In
addition,the area contains an abundance of Indian ruins and petroglyphs.Newspaper Rock State
Park,Edge of the Cedars State Park,and Hovenweep National Monument are noted areas of scenic
and archeological interest (Fig.2.1).Closest to the proposed mill site is Edge of The Cedars
State Park (historicia monument),located in Blanding (approximately three miles north of the
proposed mill site).
2.5.2.3 Archeological sites
Archeological surveys of portions of the entire project site were conducted between the fall
of 1977 and the sprin[of 1979.The total area surveyed contained parts of Sections 21, 22,
27,28,32,and 33 of137S,R22E.and encompassed 809 ha (2000 acres).of which 81 ha (200 acres)
are administered by the U.S.Bureau of Land Management and 130 ha (320 acres)are owned by the
State of Utah.The remaining acreage is privately owned.During the surveys,121 sites were
recorded and all were determined to have an affiliation with the San Juan Anasazi who occupied
this area of Utah from about 0 A.D.to 1300 A.D.All but 22 of the sites were within the
2-18
ES-4S8t
T37S
R22E
Fig.2.2.Land Ownership in the vicinity of the project site (085 =ore-buying station).
Source:ER,Plate 2.1-3 and Sect.2.1.
Note:Energy Fuels Nuclear currently owns T37S R22E Section 33,SE\,but this quarter section
is not part of the proposed project.
project boundaries.Table 2.18 summarizes the recorded sites according to their probable
temporal positions.The dates of occupation are the best estimates available,based on pro-
fessional experience and expertise in the interpretation of archeological evidence•.Available
evidence suggests that settlement on White Mesa reached a peak in perhaps 800 A.D •.Occupation
remained at approximately that level until some time near the end of Pueblo II or in the
Pueblo II/Pueblo III transition period.After this period,the population density declined
sharply,and it may be assumed that the White Mesa was,for the most part,abandoned by about1250A.D.
2-19
Table 2.17.Historic sites in southe_rn Utah
induded in the "N.tion.1 Register of
Historic Places"
Location
SanJu.n County
Site
Blanding
35 miles southeast of Blanding
Southeast of Mexican Hat
25 miles southeastof Monticello
30miles west of Monticello
Glen Canyon National Recreation Area
14 miles north of Monticello
W.yne County
Capital Reef National Park on Utah
Route 24
3 miles southeast of Bicknell
60 miles south of Green River.in
Canyonlands National Park
Green River vicinity
Capital Reef National Park
Capital Reef National Park
Capital Reef National Park
Edge of Cedars Indian Ruin
Hovenweep National Monument
Poncho House
Alkali Ridge
Salt Creek Archaeological
District
Defiance House·
Indian Creek State Park"
Fruita School House
Hans Peter Nielson Gristmill
Harvest Scene Pictograph
Horseshoe (Barrier)Canyon
Pictograph Panel
Gifford Barn·
Lime Kiln·
Oyler Tunne"
Garfield County
46 miles south of H.nksville
South of Hanksville
Near Panquitch
Starr Ranch
Susan's Shelter
Bryce Canyon Airport Hangar
•Pending nominations to the "National Register of Historic Places."
Sources:U.S.Departmel'lt of the Interior."Nation.I Register of
Historic Places."FrKI.Rtlflm.41(28).Feb.10.1976.and subsequent
issues through 43(225).Nov.21.1978.
Archaeological test excavations were conducted by the Antiquities Section,Division of State
History,in the spring of 1978,11 on 20 sites located in the area to be occupied by tailings
cells 2,3 and 4.Of these sites,twelve were deemed by the State Archaeologist to have sig-
nificant National Register potential and four possible significance.The primary determinant
of significance in this study was the presence of structures,though storage features and
pottery artifacts "were also common.
In the fall of 1978.a surface survey was conducted on much of the previously unsurveyed portions
of the proposed mill site.Approximately 45 archaeological sites were located during this sur-
vey,some of which are believed to be of equal or greater significance than the more significant
sites from the earlier study.Determination of the actual significance of all untested siteswillrequireadditionalfieldinvestigation.
2-20
Table 2.18.Distribution of recorded sites
according to temporal position
Approximate Number ofTemporalpositiondates·sitesIA.D.1
Basket Maker III 575-750 2
Basket Maker 111/575-850 27
Pueblo I
Pueblo I 750-850 12
Pueblo I/Pueblo II 850-950 13
Pueblo II 950-1100 14
Pueblo II/Pueblo III 1100-1150 12
Pueblo III 1150-1250 8
Pueblo 11+b 5
Multicomponent c 3
Unidentified d 14
·'ncludes transitional periods.
bAlthough collections at these locations were lack·
ing in diagnostic material.available evidence indicates
that the site would have been used or occupied no
earlier than 900 A.D.and possibly later.
CCeramic collections from each of these sites
indicate an occupation extending from Pueblo I
throuQh Pueblo II and into Pueblo III.
dThese sites did not produce evidence strong
enough to justify any identification.
Source:Adapted from ER,Table 2.3·2.and from
supplementary reportson project archeology.
Note:These sites are shown in Fig.3.4.
Pursuant to 10 CFR Part 63.3,the NRC submitted on March 28,1979,a request to the Keeper oftheNationalRegisterforadeterminationofeligibilityfortheareawhichhadbeensurveyed
and tested.(The area contained 112 archeological sites and six historical sites.)The
determination by the Keeper of the National Register on April 6,1979,was that the White MesaArcheologicalDistrictiseligibleforinclusionintheNationalRegister.Requirements for
further action to be taken are discussed in Sect.4.2.2 and in Appendix E.
2.6 WATER
2.6.1 Surface water
2.6.1.1 Surface-water description
The proposed mill site is located on White Mesa,a gently sloping (1%SSW)plateau that is
physically defined by the adjacent drainages which have cut deeply into regional sandstoneformations(Sect.2.7.1 and Fig.2.8).There is a small drainage area of approximately 25 ha
(62 acres)above the proposed site that could yield surface runoff to the site.Runoff from the
project area is conducted by the general surface topography to either Westwater Creek,Corral
Creek,or to the south into an unnamed branch of Cottonwood Wash.Local porous soil conditions,topography,and low average annual rainfall [30 cm (11.8 in.)]cause these streams to be inter-
mittently active,responding to spring snowmelt and local rainstorms (particularly thunderstorms).
Surface runoff from approximately 155 ha (384 acres)of the project site drains westward and is
collected by Westwater Creek,and runoff from another 155 ha (384 acres)drains east into Corral
Creek.The remaining 289 ha (713 acres)of the southern and southwestern portions of the site
drain indirectly into Cottonwood Wash (ER,p.2-143).The site and vicinity drainages carry
water only on an intermittent basis.The major drainages in the project vicinity are depicted
in Fig.2.3 and their drainages tabulated in Table 2.19.Total runoff from the site (total yield
per watershed area)is estimated to be less than 1.3 cm (0.5 in.)annually (ER.p.2-143).
2-21
ES-4590
.'USGS GAUGE NO.09376900.2 USGS GAUGE NO.09378630.3 USGS GAUGE NO.09378700
Fig.2.3.Drainage map of the vicinity of the White Mesa Uranium Project.
Source:ER,Plate 2.6-5.
Source:ER,Table 2.6·3.
Table 2.19.Drainage areas of project vicinity and region
I.tI
Drainage area
km2 sq miles
15.0 5.8
68:8 26.6
<0;531 <0;205
<;;B60 <Q32
9.8 3.8
<0;518 <0;200
.;;sO,OOO <0;23,000
Corral Creek at confluence
with Recapture Creek
Westwater Creek at confluence
with Cottonwood Wash
CottonwoodWash at USGS
gage west of project site
Cottonwood Wash at confluence
with San Juan River
Recapture Creek at USGS gage
Recapture Creek at confluence
with San Juan River
San Juan River at USGS gage
downstream of Bluff,Utah
2-22
Basin description
There are no perennial surface waters on or in the vicinity of the project site.This is due tothegentleslopeofthemesaonwhichthesiteislocated,the low average annual rainfall of
29.7 cm (11.8 in.)per year at Blanding (ER,p.2-168),local soil characteristics (Sect.2.8),
and the porous nature of local stream channels.Two small ephemeral catch basins are present
on the site to the northwest and northeast of the present buying station (Sect.2.9.2).
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
13 km2 (5 sq miles).Westwater Creek is also an intermittent tributary of Cottonwood Wash.
The Westwater Creek drainage basin covers nearly 70 km2 (27 sq miles)at its confluence with
Cottonwood Wash 2.5 km (1.5 miles)west of the project site.Both Recapture Creek and Cotton-
wood 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 29 km (18 miles)south of the project site.The
San Juan River,a major tributary for the upper Colorado River,has a drainage of 60,000 km2
(23,000 sq miles)measured at the USGS gage to the west of Bluff,Utah (ER,p.2-130).
Storm runoff in these streams is characterized by a rapid rise in the flow rates.followed by
rapid recession primarily due to the small storage capacity of the surface soils in the area
(Sect.2.8).For example.on August 1,1968.a flow of 581 m3/sec (20.500 cfs)was recorded
in Cottonwood Wash near Blanding.The average flow for that day.however.was only 123 m3/sec
(4340 cfs).By August 4.the flow had returned to 0.5 m3/sec (16 cfs)(ER.p.2-135).Monthly
streamflow summaries are presented in Fig.2.4 for Cottonwood Wash and Recapture Creek.Flow
data are not available for the two smaller watercourses closest to the projec~site.Corral
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 April,August.
and October.According to the applicant,flow typically ceases in Corral and Westwater creeks
within 6 to 48 hr after precipitation or snoW!!H!ltends.
~2
2-23
ES-4594
50
400
...350
<oJ
<oJ...
.:.300
co:u..
Z502'o-'...ZOO
>--':z:~150o:E
~100..co:~..
AVERAGE ANNUAL FLOW=800AF-(1965-1974)ORAINAGE AREA-3.77 SQ.MI.
AVERAGE ANNUAL YIELD=ZIZ.Z AF/SQ.MI.
VI ELD-AF/SQ.
MIN.AVE.----Z6 ZIZ
(1970)
(0)
OCT NOV DEC JAN FEB .....APR ....yJUNEJlJl.y AUG SEPT
MONTH
MI
MAX.
86Z
(197Z)
AVERAGE ANNUAL FLOW=6300 AF (1964-1974)
1600 DRAINAGE AREA-Z05 SQ.MI.
AVERAGE ANNUAL YIELD =31 AF/SQ.MI.
1400...
<oJ~1Z00...co:u
":.10002o
-'
...800
>--':z:
~600o:E
~400..co:...
:ZOO
OCT POI DEC JAN FEB ....-.....y.AH:..u.y AUG SEPT
MONTH
VlELD-AF/SQ.
MIN.AVE.----6.7 31
(1969)
MI.
MAX.
100
(197Z)
Fig.2.4.Streamflow summary in the Blanding,Utah,vicinity.(a)Upper portion of
the watershed near the headwaters of Recapture Creek near Blanding at 7200 ft MSL;USGS
gage 09378630.(b)Cottonwood Wash about 11 km (7 miles)southwest of Blanding at 5138 ftMSL;USGS gage 09378700.Source:Adapted from the ER,Plate 2.6-6.
2-24
2.6.1.2 Surface-water guality
The applicant began sampling surface~water quality-in the project vicinity in July 1977 and
continued through March 1978.Baseline data describe and evaluate existing conditions at the
project site and vicinity.Sampling of the temporary onsite surface waters (two catch basins)
has been attempted but without success because of the lack of naturally occurring water in
these basins.The basin to the northeast of the proposed mill site has been filled with well
water by the applicant to serve as a nonpotable water source during planned construction of
office and laboratory buildings in conjunction with the proposed mill (approximately six months).
This water has not been sampled by the applicant but presumably reflects the poor quality
associated with local groundwater (Sect.2.6.2).Sampling of ephemeral surface waters in the
vicinity has necessitated correlation with major precipitation events as these watercourses are
normally dry at other times.
The chemical and physical water quality parameters measured by the applicant are listed in
Table 2.20.The locations of the surface-water sample sites are presented in Table 2;21 and
Fig.2.5,and the water quality values obtained for these sample sites are given in Table 2.22.
Water quality samples were collected during the spring at several intermittently active streams
(Fig.2.5)that drain the project area.These streams include Westwater Creek,(SlR,59),
Corral Creek below the small irrigation pond (S3R),the junction of Corral Creek and Recapture
Creek (S4R),and Cottonwood Cre.ek (S8R).Samples were also taken from a surface pond southeast
of the proposed mill (S5R).No samples were taken at S2R on Corral Creek or at the small wash
(S6R)located south of the site.
Surface-water quality in the vicinity of the proposed mill is generally poor.Waters in
Westwater Creek (SlR and S9)were characterized by high total dissolved soli.ds (TDS;mean of674mg/liter)and sulfate levels (mean 117 mg of S04 per liter).The waters were typically hard
(total hardness measured as CaC0 3 ;mean 223 mg/liter)and had an average pH of 8.25.Estimated
flow rates for Westwater Creek averaged <0.08 m/sec «0.3 fps)at the time of sampling.
Samples from Cottonwood Creek (SaR)were similar in quality to Westwater Creek water samples,
although the TDS and sulfate levels were lower (TDS averaged 264 mg/liter;SO~averaged
40 mg/liter during heavy spring flow conditions [24 m/sec (80 fps)streamflowJ.
The concentrations of TDS increased downstream in Corral Creek,averaging 3180 mg/liter at S3R
and 6660 mg/liter (one sample)at S4R.Total hardness averaged in excess of 2000 mg/liter,and
pH values were slightly alkaline.Estimated flows in Corral Creek were typically less than
_0.03 m/sec (0.1 fps)during sampling.
The spring sample collected at the surface pond south of the project site (S5R)indicated a
TDS concentration of less than 300 mg/liter.The water was slightly alkaline with moderate
dissolved sulfate levels averaging 42 mg/liter•
.During heavy runoff,the concentration of total suspended solids in these streams .increased
sharply to values in excess of 1500 mg/liter (Table 2.22).
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,7/25/77;S8R,7/25/77).
This level is 40 times the EPA recommended limit for the protection of freshwater aquatic life
(0.05 ~g/liter).12 Total iron measured in the pond (S5R,11/10/77)was 9.4 mg/1iter,over nine
times the EPA recommended limit of 1 mg/1iter for the protection of aquatic life.These values
appear to reflect groundwater quality in the vicinity (Sect.2.6.2)and are probably due to
evaporative concentration and not due to human perturbation of the environment.
2.6.1.3 Surface-water utilization
Regional surface water is primarily used for agricultural irrigation and stock-watering
purposes.Water usage from the San Juan River in Utah alone amounts to approximately12.2 x 103 m3 (9900 acre-ft)per year.Table 2.23 lists the existing surface-water appro-
priations within the project vicinity.Water uses in San Juan County are presented in
Table 2.24;
,
2-25
Table 2.20.Physical and chemical water quality parameters
Specific conductance (fieldl.mlcromhos/cm
Total suspended solids
Temperature (fieldl
pH (lab.field)
Redox potential
Total dissolved solids
Dissolved oxygen (field)
Oil and grease
Total hardness as CaC03
Total alkalinity as Cac03
Carbonate as C03
Chloride
Cyanide
Filloride
Nitrateas N
Sulfate as SO4
Calcium
Iron.total and dissolved
Magnesium
Ammonia as N
Phosphorus,total as P
Potassium
Silica
Sodium
Chemical oxygen demand (COD)
Source:ER,Table6.1·1.
Manganese
Aluminum
Arsenic
Barium
Boron
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Strontium
Vanadium
Zinc
Silver
Po-210
Pb-210
Th·230
Uranium (natural)
Ra-226
Gross Ct
Gross 13
Station no.
Table 2.21.Surface water samplingstations
Location
l
S5R
SSR
S7R
SlR
S2R
S3R
S4R
Westwater Creek at downstream (south)side of Highway 95 bridge
Corral Creek at downstream (south)side of small bridge
Corral Creek at spiIIway of small earthen dam
Corral Creek at junction with Recapture Creek 0.40 km (0.25mile)
from end of jeep road
Surface pond south of mill site,0.20 km (0.125 milB)west of
Highway 47
Small washsouth of mill site,1.6 km (1.0 mile)west of Highway 47
East side of Cononwood Creek,at jeep trail intersection south·
southwest of mill site
SSR East side of Cononwood Creek,at jeep trail intersection west·
southwest of mill site
S9 East side of Westwater Creek,at jeep trail intersection
Source:ER,p.6-1.
Table 2.22.Water quality of surface watersin project vicinity,Blanding,Utah
Zero values (0.0)are below detection limits.
2-26 ,
3/23/78
b
b
b
11/10177
b
b
b
Corral Creek.S2RC
7/25/773/23178'
Sampling for dates·as given
7/25/77 11/10177 3/23/78
Westwater Creek,Sl RC
490 620
7.6 8.3
3 14
21.910.02)39.910.031
Determination,mg/liter
8.2 8.35
496 559
220 186
206 229
262 289
0.0 2.3
0.2 0.10
<0.1 0.18
0.007
<0.2 0.22
0.1 <0.1
<0.002 <0.005
76 140
17 38
31 60
<0.005
103 163
<0.01 <0.005
0.030 0.04
<0.01 0.01
<0.005 0.01
0.3 0.4
0.28 1.5
0.17 0.21
<0.05 <0.05
17.0 26
<0.0005 <0.ססOO3
0.002
<0.05 <0.05
0.05 0.06
2.8 2.0
0.003
7 9
0.44 0.76
0.006 0.004
0.002 0.003
0.09 0.04
6 7
23 48
1 1
12 47
Detarmination.pCi/litar
0.1 ±1.1 4.5 ±2.0 b
0±9 8 ±11
0.2 ±0.3 0.2 ±0.3
0.0 ±0.4 0.1 ±0.4
0.7 ±2.3 1.1 ±3.8
0.1 ±0.5 0.0±0.7
b
b
b
Field specific conductivity.J,Jmhos/cm
F,eld pH
Dissolved oxygen
Temperature,OC
Estimated flow,mlhr (fps)
Gross alpha ±precision
Gross beta ±precision
Ra·226 ±precision
Th-230 ±precision
Pb-210 ±precision
Po·210 ±precision
pH
TDS (at 18()"C)
Redox potential
Alkalinity (as CaCOa)
Hardness,total las CaCOa)
Carbonate (as COa)
Aluminum,dissolved
Ammonia (as N)
Arsenic,total
Barium,total
Boron,total
Cadmium,total
Calcium.dissolved
Chloride
Sodium.dissolved
Silver,dissolved
Sulfate,dissolved (as SO_)
Vanadium.dissolved
Manganese.dissolved
Chromium.total
Copper,total
Fluoride,dissolved
Iron,total
Iron.dissolved
Lead.total
Magnesium,dissolved
Mercury.total
Molybdenum,dissolved
Nitrate (as N)
Phosphorus.total (as P)
Potassium.dissolved
Selenium.dissolved
Silica dissolved (as Si02)
Strontium,dissolved
Uranium,totai (as U)
Par~meter
Uranium,dissolved (as U)
Zinc,dissolved
Total organic carbon
Chemical oxygen demand°II and grease
Total suspended solids
l'2-27
Table 2.22.(ContinuedI
Parameter Sampling for dates as given
7/25/77 11/10/77 3/23/78 3/23/7fi'7/25/77 11/10/77 3/23/78
Corral Creek.S3FF Junction of Corral and
Recapture creeks.S4RC
Field specific conductivitY•.umhos/cm 2000 2400 3500 3500 d d 6000
Field pH 6.8 7.9 7.8 7.9
Dissolved oxygen
Temperature °c 27.7 8 13 13 14
Estimated flow,m/hr Ifpsl 98.710.091 21.9 (0.021 65.8 (0.061 65.8 (0.06)10.9 (0.011
Determination,mgtliter
pH 6.7 8.0 8.23 8.15 d d 8.11
TDS (at 180°C)1350 3160 4095 4130 6660
Redox potential 260 240 190 193 195
Alkalinity (as CaC031 70 172 236 236 274
Hardness,total (as CaC031 853 1910 2200 2200 2100
Carbonate (as C03I 0.0 0.0 0.0 0.0 0.0
Aluminum.dissolved 0.04 <0.1 <0.1 <0.1 <0.1
Ammonia (as N)0.15 <0.1 <0.1 0.13 <0.1
Arsenic,total <0.01 0.011 0.013 0.010
Barium,total 0.36 0.4 0.18 0.22 0.29
Boron,total 0.1 0.2 0.2 0.2 0.2
Cadmium,total 0.004 0.006 0.01 0.01 0.02
Calcium,dissolved 150 78 546 571 649
Chloride 54 152 214 189 556
Sodium,dissolved 115 160 312 315 1205
Silver,dissolved 0.004 0.02 0.01 0.02
Sulfate,dissolved (as SO.)803 2000 2596 2854 3760
Vanadium,dissolved 0.004 <0.01 0.005 <0.005 <0.005
Manganese,dissolved 0.20 0.030 0.05 0.04 0.32
Chromium.total 0.02 0.01 0.02 0.04 0.04
Copper,total 0.01 0.010 0.02 0.03
Fluoride,dissolved 0.32 0.6 0.8 0.8
Iron,total 0.08 0.09 0.09 0.12 0.30
Iron,dissolved 0.12 0.07 0.09 0.04 0.10
Lead,total 0.04 0.15 0.10 0.08 0.14
Magnesium,dissolved 120 20 359 376 353
Mercury,total 0.002 <0.0005 0.00003 0.ססOO9 0.ססOO2
Molybdenum,dissolved <0.01 0.004 0.003 0.004
Nitrate (as N)0.21 0.11 0.81 0.81 <0.05
Phosphorus,total (as PI 0.21 0.06 <0.02 <0.02 0.06
Potassium,dissolved 13 4.8 6.9 6.8 6.8
Selenium,dissolved 0.16 0.032 0.027·0.005
Silica,dissolved (as Si02 1 10 2 3 3 11
Strontium,dissolved 1.9 2.2 5.0 5.1 12
Uranium,total (as Ul 0.005 0.028 0.046 0.038 0.085
Uranium,dissolved (as Ul 0.002 0.028 0.046 0.036 0.082
Zinc,dissolved 0.06 0.02 0.02 0.01 0.02
Total organiccarbon 11 17 18 22
Chemical oxygen demand 79 234 155 61
Oil and grease 1 2 <1 1
Total suspended solids 9 6 9 24
Determination,pCiI1itar
Gross alpha:!:precision 15:!:2 19:!:6 13.4:!: 6.6 O:!:11 d d 7.0:!:2.9
Gross beta ±precision 180 ±20 0:!:29 95:!:50 37 ± 4 25±18
Ra-226 ±precision 0.0 ±0.3 0.3 ±0.3 0.4±0.4 0.0~±0.03 0.2 ±0.3
Th·230:!:precision 3.1 ±0.5 0.1:!:0.5 1.3±0.6 O±0.1 1.5 ±0.7
Pb-210 ±precision 1.4 :!:2.1 2.4:!:2.6 1.4 ±3.6 O:!:1 1.4 ±3.7
Po-210 ±precision 0.0:!:0.3 0.6:!:0.7 0.5 ±0.9 '1.4 ±1.1
2-28
,
•
Table 2.22.(ContinuedI i
•Parameter Sampling for dates as given t7/25/77 11/10/77 3/23/78 3/2317~7/25/77 11/10177 3/23/78 rSurlacepond.S5R c:Unnamed Wash.s6RC Cottonwood Creek.S7C
tFieldspeCificconductivity.~mhos/cm e 100 250 d d 320FieldpH6.8 8.4 8.2 tDissolvedoxygenITemperature.oC 20 12EstimatedIlow.m/hr lIps)1097 (10)
Determination,mg!lile'
pH e 6.9 7.94 d d 8.36TDS(at lSO·C)264 291 295Redoxpotential280130172Alkalinity(as CaC03 )218 138 149Hardness.total (as CaC03 )67 129 154 !Carbonate (as C03 )0.0 0.0 2.3 iAluminum,diss«;»lved 2.0 1.0 2.4 !Ammonia (as N)<0.1 0.19 0.15 fArsenic.total 0.008 0.027Barium.total <0.2 0.33 0.66 tBoron.total 0.2 0.1 <0.1Cadmium.total <0.002 <0.005 0.006Calcium.dissolved 22 72 134Chloride8107Sodium.dissolved 0.6 5.4 20Silver,dissolved <0.005 <0.005Sullate.dissolved (as SO.)64 20.3 52.6Vanadium.dissolved <0.01 0.012 0.012Manganese,dissolved 0.095 0.15 0.69Chronium,total 0.04 0.04 0.03COPPl!'.total 0.005 0.02 0.04Fluoride.dissolved <0.1 0.1 0.2Iron,total 9.4 11 3.9"on,dissolved 1.2 1.0 1.7Lead,total <0.05 <0.05 0.08Magnesium,dissolved 3.2 8.8 25Mercury.total <0.0005 0.00005 0.ססOO7Molybdenum.dissolved 0.002 0.004Nitrate(as N)4.26 0.05 0.14Phosphorus.total (as P)0.04 0.37 0.85
Potassium,dissolved 14 13 2.3Selenium.dissolved <0.005 <0.005Silica.dissolved (as Si02 )2 7 10Strontium,dissolved 0.10 0.34 0.49Uranium,total 0.004 0.002 0.011Uranium,dissolved (as U)0.003 <0.002 0.007Zinc,dissolved 0.02 0.10 0.050Totalorganiccarbon152010Chemicaloxygendemand715860Oilandgrease211Totalsuspendedsolids2682101600
Determination.pCillitar
Gross alpha t precision 1.1 t 1.1 1.2t 1.1 d d 3.2 t 1.8Grossbetatprecision15t1027t832tIlRa·226 t precision 0.2 t 0.3 0.1 to.9 0.6 t 1.5Th·230 t precision 0.0 t 0.4 0.9t0.6 0.2 t 0.4PI>-210 t precision 2.6 t 2.2 0.0 t 3.8 4.3 t 3.7Po·21 at precision 0.2 t 0.5 0.0 to.6 0.0t 0.7
2-29
Table 2.22.(ContinuedI
Sampling for dates as given
Parameter 7/25/77 11/10/77 3/23/78 3/23/7~7/25/77 11110/77 3/23178
Cottonwood Creek.S8Re Westwater Creek.srF
Field specific conductivity.,umhos/cm
Field pH
Dissolved oxygen
Temperature.0 C
Estimated flow.mlhr (fps)
550
6.6
35
0.4
445
6.9
6.0
0.7
240
8.1
7
80
240
7.9
7
80
d d 320
8.0
9
0.28
Determination,mg/liter
DeUlrminltion.pCi"i..
pH
TDS (at 180°C)
Redox potential
Alkalinity (as CaC03)
Hardness.total (as CaC03)
Carbonate (as C03)
Aluminum,dissolved
Ammonia (ao N)
Arsenic.total
Barium,total
80ron.total
Cadmium.total
Calcium.dissolved
O1loride
Sodium,dissolved
Silver,dissolved
Sulfate.dissolved (as SO.)
Vanadium.dissolved
Manganese.dissolved
Ouonium.total
Copper.total
Fluoride.dissolved
Iron,total
Iron,dissolved
Lead.total
Magnesium,dissolved
Mercury.total
Molybdenum,dissolved
Nitrate (as N)
Phosphorus,total (as PI
Potassium,dissolved
Selenium,dissolved
Silica,dissolved (as Si02)
Strontium,dissolved
Uranium,total
Uranium,dissolved(as.UI
Zinc,dissolved
Total organic carbon
O1emical oxygen demlnd
Oil andgrease
Total suspended solids
Gross alpho ±precision
Gross beta ±precision
Ra-226 ±precision
Th·230t precision
Pb·210 t precision
Po-210 t precision
7.5
944
220
134
195
0.0
3.0
0.12
0.02
1.2
0.1
0.004
79
13
36
0.002
564
0.003
0.84
0.14
0.09
0.36
150
1.4
0.14
24
0.002
<0.01
1.77
0.05
6.9
0.08
10
0.64
0.027
0.015
0.06
16 t3
72 ±17
0.6±1.3
0.9 t 0.6
0.8±1.9
0.0±0.3
8.2
504
260
195
193
0.0
0.7
<0.1
0.2
0.2
<0.002
54
24
66
132
<0.01
0.065
<:0.01
0.005
0.2
5.9
0.62
0.05
17
.<0.0005
0.10
0.14
3.2
3.2
8
0.60
0.004
0.004
0.05
7
61
2
146
2.9 t 1.5a±10
1.1 ±0.5
O,Ot 0.4
0.0 t 2.2
0.6 t 0.7
8.21
275
210
155
148
0.0
2.4
0.13
0.041
0.85
0.1
<0.005
178
7
23
<0.005
39.7
<0.005
0.78
0.04
0.05
0.2
50
1.9
0.10
28
0.00006
0.002
0.13
0.96
2.5
<0.005
11
0.56
0.014
0.008
0.06
12
163
2
2025
7.3 ±2.4
28 ±11
1.9±1.7
0.0±0,3
2.5t 4.3
0.0t 0.6
8.09
253
224
155
154
0.0
0.16
0.16
0.032
1.1
<0.1
0.01
72
6
21
<0.005
39.7
<0.005
0.02
0.05
0.05
0.2
53
0.11
0.10
17
0.0012
0.002
0.12
0.84
1.2
<0.005
18
0.34
0.014
0.006
0.008
11
111
2
1850
23 ±3
110±6
2.0t 0.1
0.2 to.l
0±1
d
d
d
d
8.20
969
190
147
117
0.0
4.0
0.75
0.037
0.81
0.1
0.006
172
18
125
0.006
85
0.008
.0.60
0.60
0.05
0.2
44
2.5
0.10
13
0.00012
0.006
0.05
0.88
3.2
<0.005
11
0.65
0.004
0.002
0.12
16
66
1
1940 It.
•Replicate sample analyzed for quality assurance on radioactivity.
bNotenouqh water in strllm to sample adequltely,
C See Tlbl.2.21 for 10000loniof IIIIIpling ItlItionl.
dNa Wlter in strelmto sample.
•Not sampled.
Source:Adapted from ER,Table 2.6-7.
2-30
ES-4589
MILES
Fig.2.5.Preoperational water quality sampling stations in the White Mesa.project
vicinity.~:ER,Plate 2.6-10.
,
2-31
!.I
Table 2.23.Current surface water users in project vicinity
Address Application Application Quantity
Name date number cfs m3!sec
Corral Creek
Fred Halliday Blanding,Utah August 12.1971 40839 0.5 0.014
Cottonwood Creek or Wash
William Keller Moab,Utah November 12,1907 1647 1.0 0.028
Hyrum Perkins Bluff,Utah June 22,1910 3322 5.49 0.156
U.S.Indian Ignacia,Colorado March 12,1924 9486 1.18 0.033
Service
U.S.Indian Service Ignacia,Colorado March 24,1924 9491 0.738 0.021
U.S.Indian Service Ignacia,Colorado March 24,1924 9492 0.298 0.008
Kloyd Perkins Blanding,Utah April 13,1928 10320 1.455 0.041
W.R.Young Blanding,Utah October 22,1928 104935 0.0015 0.00004
W.R.Young Blanding,Utah October 23,1928 10496 0.0022 0.0006
W.R.Young Blanding,Utah October 22,1928 10497 0.002·0.00005
San Juan Monticello.Utah October 10,1962 34666 12,000 1500
County water (acre·lt)(ha-m)
Conservation district
Earl Perkins Blanding,Utah April 16,1965 36924 5.0 0.142
Seth Shumway
H.E.Shumway
Preston Nielson
Parley Redd
Kenneth McDonald
Blanding,Utah
Blanding.Utah
Blanding.Utah
Blanding,Utah
Blanding,Utah
Westwa1llr Creek
January 7,1929
Segregation date:February 28.1970
Segregation date:October 22,1970
Claim date:October 16.1970
Change of Appropriation:
June 12,1974
10576
37101a
37601a
Claim 2373
42302
0.005
0.7623
0.2377
0.015
1.0
0.002
0.022
0.007
0.0004
0.028
rl
L.
Source:ER,Table 2.6-4.
Table 2.24.Water use of San Juan County,1965
"Incidental use of irrigation water by phreatophytes and
other miscellaneous.vegetation.
b Includes evaporation losses applicable to these sources of
depletion.
Source:ER,Table 2.6-5.
Consumption
5,500
100
1,300
1.800
1,100
100
9,900
6,785
123
1.603
2,220
1,357
123
12.211
m3 X loJ Acre-ftUse
Irrigated crops (5000 acres)
Reservoir evaporation
Incidental use"
Municipal and industrialb
Mineral~
Augmented fish and wildlifeb
Total
------------------'~I .
I
I
I
I
I
I
I
I
I
I
I
II
I
I
I"
l'
I
,I''r
I
2-32
2.6.2 Groundwater
A generalized section of the stratig,aphic and water-bearing units in southeastern Utah is
shown in Fig.2.6.Recharge of these aquifers occurs from seasonally variable rainfall infil-
trating along the flanks of the Abajo,Henry,and La Sal mountains and along the flanks of
folds.Recharge water also originates from precipitation on the flat-lying beds where it
percolates into the groundwater region along joints.
In the White Mesa area,39 groundwater appropriations (applications for water wells)are on file
with the Utah State Engineers Office for wells lying within an 8-km (5-mile)radius of the
project site.All but one of these wells produce from the Dakota and Morrison formations.
Thirty-five of these are for wells which are actually constructed (ER,Table 2.6-1).Most of
these wells produce less than 55 m3/day (10 gpm)and are used for domestic,irrigation,and
stock-watering purposes.The remaining well,which was drilled to a depth of 548 m (1800 ftl
by Energy Fuel s Nuclear,withdraws water from the Navajo Sandstone.The majority (31)are
hydrologically upgradient or cross gradient with respect to the project site.The remaining
four wells (three onsite and one offsite,south)are on land owned by the applicant.Two of
the onsite wells are located in the area of the proposed tailings impoundment and will be
completely plugged with bentonite and/or another suitable clay.9,6 The well which is offsite
and south will be capped or used for monitoring purposes.
As is the case throughout most of the Four Corners region,the Blanding area depends largely
on groundwater for its water supply.A porous soil,underlain by the Dakota Sandstone on top
of a regional aquiclude (the Brushy Basin Member of the Morrison Formation),provides the
Blanding area with a near-surface source of groundwater.This situation is somewhat uncommon
in the highly dissected south-central portion of the Colorado Plateau.
The Dakota sandstone on White Mesa has been completely isolated by erosion;consequently,
all recharge to this formation comes from precipitation and irrigation on the mesa.No irriga-
tion occurs close to the mill site,and normal precipitation is only 30 cm (12 in~)per year,
most of which reenters the'atmosphere as evapotranspiration (i.e.,it does not penetrate the
soils over the Dakota).The Dakota is the underlying bedrock under the proposed tai1i ngs
impoundment and has a permeability coefficient from 1.5 to 3 m (5 to 10 ft)per year (ER,
Sect.4.2.4.1 and Appendix H).Jointing occurs in the formation but is probably not fully
penetrating.An aquiclude,the Brushy Basin member of the Morrison Formation,underlies the
Dakota sandstone,which accounts for the groundwater retained in the lower portion of the
Dakota.
In the immediate vicinity,only the Dakota Sandstone and the Salt Wash Member (including the
Westwater Member)are significant aquifers.The Entrada and Navajo formations contain larger
quantities of water,but their depth prohibits common exploitation,in use for domestic water
supplies.
Comb Ridge and the Abajo Mountains are significant areas of recharge of the Salt Wash and
deeper aquifers.General gradients of groundwater movement in these aquifers follow the
regional structure,and the water discharges ultimately in the vicinity of the San Juan River.
Because the Brushy Basin Member acts as an aquiclude to the Salt Wash Member in the uplands,
the primary recharge areas for this aquifer are Brushy Basin Wash to the northwest of Blanding,
Cottonwood Creek to the west and southwest of the town,and the upper reaches of Montezuma
Creek,especially along Dodge and Long canyons.
Several permeability tests were conducted at the mill and tailings retention sites.The
results of these tests show a hydraulic conductivity of 1.5 to 3 m (5 to 10 ft)per year (see
Fig.2.7).The shallow groundwater movement at the mill site is estimated to be about 0.3 to
0.6 cm (0.01 to 0.02 ft)per year toward the south-southwest and the shallow groundwater move-
ment at the tailings site is about 0.08 to 0.3 cm (0.0025 to 0.01 ft)per year in the same
direction.The values were derived using the following formula based on Darcy's Law:
V ~Ki/0 ,
where
,,
2-33
GEOLOGIC
AGE ES -4582
SHINARUMP Memberof Chinle
Formation;DeCHELLY Sandstone of
Cutler Group.Locally provide good
water where they are near surface.as
in vicinity of 8luft.
\
I
Cutler
Group
Navajo Sandstone
Chinle Formation
Wingate Sandstone
Kayenta Formation
Hermosa Formation
Halgaito Formation
Rico Formation
IALLUVIUM.Provides small quantities of water
~from .hallow wells.Such wells are subject:i--------_to great seasonal variation in amount of yield.
MancpS Sh The water is generally of poor Quality __
Dakota S5 \probably owing to the sulfate salts in the
\
Mancos shale.Burro Canyon Fm ~
Morrison \~IDAKOTA Sandstone and upper part of MORRISON
Formation l Formation.Water of fair to poor quality
~available by pumping.
Bluff Sandstone \\,BLUFF Sandstone.Artesian aquifer,potable
Summerville fm water.Supplies a spring ean of Bluff
and weIIs SOUth of Hatch.
NTRAOA Sandstone.Artesian aquifer,
potable water,CropS out in western
and southern parts of area but tJase
reaches dept!"!of nearly 1500 ft in
central part of area (near Aneth field
in Blanding basin!.
~NAVAJO Sandstone.Artesian aquifer
\
yielding good quality water.Crops
out in western and southern parts of~area and reaches depths of 1850 ItShinarumpMember
I-:-:M-oen-:"""kO-P':""1""Fo-rma-t':""io-n-----1\\near Aneth oil field.
r,W~h..,.'tc..e_R-'m.."...;;.5o:........J..I\1 ,WINGATE Sandstone.Artesian aquifer
DeChelly 50 '\prOViding good quality water for wells
Organ Rock Shale \in vicinity of 8luff.
~---4\Cedar Meso
Sandstone
uenV>«0:;;
z«
i0:wQ.
I
0:>Wo:'""«:32a
e
Z2WQ.
Fig.2.6.Generalized stratigraphic section showing freShwater-bearing units in
southeastern Utah.Source:ER,Plate 2.6-1.
v =the rate of movement of groundwater through the formation,
K the hydraulic conductivity of formation 1.5 to 3 m/year (5 to 10 ft/year),
i gradient (calculated as 0.03 at mill site and 0.01 at tailings site),
o porosity of formation (assumed as 20%).
Table'2.25 is a tabulation of groundwater qual ity of the Navajo Sandstone aquifer.The TOS
range from 244 to 1110 mg/liter in three samples taken over a period from January 27,1977,to
May 4,1977.High iron (0.57 mg/liter)concentrations are found in the Navajo Sandstone.The
U.S.Environmental Protection Agency recommends 0.3 mg of dissolved iron per liter for drinking
water.13 Feltis14 noted that the total dissolved solids in the alluvium and at shallow depths
in the Dakota Sandstone,the Burro Canyon Formation,and the Morrison Formation range from
300 to 2000 mg/1iter.
The applicant has sampled groundwater from local springs and wells at locations shown in
Fig.2.5.Total dissolved solids ranged from about 700 to 3300 mg/1iter.Standards for
public drinking water were frequently exceeded for sulfate,selenium,iron,and arsenic.The
waters are suitable for stock and wildlife use.
"JI
l>'Po
.";;:;./t:i;..H·-~
1
.It!
~
24o
.",
II .'"\1---~--'--';o'-'\'-~'SlE]
,0 '"0 II.",G'.\''.,./"~\''''1'r,.'""0.,
.l,I
ES-4~eb
l-'-'l \
12 '90
o I 2.,9 I,I,.__J ?J
I g I '-'-'
I
,06 ?i
?...........7 /•
,"0 0 /I
!.~./i
I \~,
,:;MILL SITE I
I.~i.1\0 3 ','.J .'\~G'~2~0
25 I, •1-==...:....:=-=-~6'.s-o.--?.
I 130,140 11'0.I
,~6'/~.
I I~,/SW "'''''0,r5 I
,"',0 17 0 '".I'19 I ",,07 SE •TAILING SITE
o °0'~0 'r-~2~O~'",~,:_:_=--1-.J8 Ii2~?....../i ---i;----------J
i ~6 I s:o:o~;>
,I ~"I ~7 J'
,28L~
0:wI-
0:<{
W ~
I-...<{0~z
0 0I-~:z:I->...wW..J0w
56.6'6677.9
56.0'6578.4
66.5'5677.9
56.8'5577.6
100.0'5579.3
99.8'5579.5
75.0'5573.1
81.3'5566.8
110.0'5490.3
110.0'6490.3
75.0'5472.6
76.0'6471.6
75.7'5471.9
34.7'5637.3
93.0'5560.0
93.5'5559.5
94.0'5569.0
94.0'5559.0
96.0'5499.0
B4.0'5511.0
B4.5'5510.5
84.5'5510.5
91.0'5504.0
90.0'5505.0
90.5'5504.5
90.0'5505.0
90.7'5504.3
oo/JIJ/77 5679.3
11/04/77
oo/JIJ/77 5648.1
11/04/77
00/27/77 5600.3
11/04/77
00/22/77 5647.6
00/27177
11/04/77
11/04/77 6472
00116/77 5663
00/22/77
00/27177
00/00/77
00/00177 6696
00/16/77
00/22/77
00/27/77
00/00/77 6596
00/16/77
00/22/77
00/27177
11/04177
z01=<{>W..JgW
WUw<{
..J ...0 0::z:::>
..J (I)
..J W 0;;;I-Z<{500
3 00/19/77 5634.4
00/22/77
00/27177
11/04/77
Fig.2.7.Groundwater-level map of the White Mesa site.
Source:ER,Plate 2.6-2.
9
28
N
19
12
N.E.
S.E.
S.W.
KEY
-5~20'-ELEVATION OF WATER TABLE (FEET ABOVE MSU
•DIRECTION OF SHALLOW GROUND WATER MOVEMENT
028 BOREHOLE LocATION AND NUMBER ENCOUNTERING WATER
11 •••- •L I I J a .'••5 AIUlllatl..F I._, ,~-""..""".',.,~
·The spring in CorTII Creek,Station No.GIR.WlS testedon July 25,1977,Indegoin on November 10,
1977.8eCIUse of the low flow,the springcould not be 1000ted.
bUUh StlteDivision of HellmAnllysis,lJIb No,770111.
·Penilllnllysisby Huen Resewch,Inc.,SImple No.HRI·l1503,
Source:Adept8d from EA,Tabl.2.....8nd ''Supplemental FtepO".8"'1"8Weter Quality
Environmental Aepo".White M..Uranium PrOject:'June28.117•.
2-36
2.7 GEOLOGY,MINERAL RESOURCES,AND SEISMICITY
2.7.1 Geology
2.7,1.1 Regional geology
The proposed project site is near the western margin of the Blanding Basin in southeastern
Utah.Thousands of feet of marine and nonmarine sedimentary rocks have been uplifted,moder-
ately deformed,and subsequently eroded.North of the site is the Paradox fold and fault belt;
to the west,the Monument uplift;to the south is the San Juan River and the Tyende Saddle;and
to the east is the Four Corners platform (the Canyonlands section merges with the Southern
Rocky Mountain province;see Fig.2.8).The area is characterized by deeply eroded canyons,
mesas,and buttes formed from sedimentary rocks of pre-Tertiary age.Regionally,elevations
range from about 900 m (3000 ft)to more than 3350 m (11,000 ft).With the exception of the
deeper canyons and isolated mountain peaks,the average elevation is approximately 1500 m
(5000 ft).
Exposed sedimentary rocks in southeastern Utah have an aggregate thickness of about 1800 to
2100 m(6000 to 7000 ft)and range in age from Pennsylvanian to Late Cretaceous.
Shoemaker noted three origins of the structural features seen in the project area:
(1)structures related to large-scale regional epeirogenic deformation (Monument Uplift and
Blanding Basin),(2)structures formed due to diapiric deformation of thick evaporities,and
(3)structures formed due to magmatic intrusions (Abajo Mountains).15,16
2.7.1.2 Blanding site geology
The proposed site is located near the center of White Mesa.The nearly flat surface of the
mesa has a thin veneer of loess and is underlain by resistant sandstone caprock.Surface
elevations across the site range from 1690 to 1720 m (5550 to 5650 ft).The maximum relief
between White Mesa and the adjacent Cottonwood Canyon is about 230 m (750 ft).
White Mesa is drained to the west by Cottonwood Wash and Westwater Creek and to the east by
Recapture Creek.There streams are intermittent and flow into the San Juan River.In the
project area,exposed rocks are of Jurassic,Cretaceous,and Pleistocene-Recent age (see Fig.
2.9).The Jurassic to Upper Cretaceous rocks are represented,in ascending order,by the San
Rafael Group,the Morrison Formation,the Burro Canyon Formation,the Dakota Sandstone,and the
Mancos Shale.The rocks are primarily cross-bedded sandstones,conglomeratic sandstones,claystones,mudstones with some sandy shales,and limestones.Cenozoic rocks include eolian
loess,stream-born alluvium,colluvium,and talus.
The structure of White Mesa is simple.The Dakota Sandstone and Burro Canyon Formation are
essentially flat with gentle undulations and are commonly jointed.Two joint directions are
found usually perpendicular to each other.
2.7.2 Mineral resources
2.7.2.1 Uranium deposits
Two types of uranium mineralization exist in the region:(l)tabular deposits nearly parallel
to the bedding of fine-grained to conglomeritic sandstone lenses and (2)fracture-controlled
deposits.None of the fracture-controlled deposits have yielded large production.17 The
tabular deposits occur in the Chinle,Morrison,and Cutler formations.Vanadium is a common
byproduct of most uranium produced from the Morrison Formation.Principal uranium minerals
are uraninite and coffinite.
2.7.2.2 Other mineral resources
Seven wildcat oil wells were drilled about 6 km (4 miles)west of the proposed site.All were
dry and were abandoned.
,
it;
Ind
he
...'.......
...."'"\'....\-\r ..,.I;.,.4 I
I ~, II.,\...,\\,\
...."',:"~...I,.\,....I,,/1
V
2-37
•....'
ES-4537
EXPLANATION 25 0 25 50 7lI
...._-----lCA~1 '""'~IIIOU..OAllty 0"TECTO.'C DIY.
L,.o
MONOCLINE,SMOWI.,TJlACI:
0'AX"."0 D••aCTIOII M
0'1'
-f---
ANTICLUII,SHOW.'"T_ACIO~alii _OIIllCTIOIl O~
I'LUII.~
.T.CLI.I,SHOW''''TIIACr
f7 ..,.......0 OIl'ICT'OIl CW'
....UII.I
Fig.2.8.Tectonic index map.Source:ER,Plate 2.4-1.
2-38
ES -4588
ERA SYSTEI1 SERIES STRATIGRAPHIC THICKNESS·LITHOLOGY(Age)UNIT (ft)
Alluviu.2-2~Silt.sand and grave::'in arrtlyol and stream
valleys.
Slope ",~.h.talul and rocK rubble ranglr.g
::Holocene Colluvium and Talus 0-15+from cobbles and bou1ders to massive blocks
c QUATERNARY tc>fallen frOID cliffs and outcrops of resist&n:~Pleistocene :'ock.0::'":.;Reddish-brC'WTl to light-oro"",,.uncon30!ida-
tOe'I.(--22+ted.well-sorted silt to ",ediUlll-grained
sand;putially cemenud with cal1c~e ir.
some area:reworked putIy'by water.
Unconiorllity
Cra~'to dark-grayt fiss11e.thin-beJJed
Hanco.Shale 0-11 (1)marine shale with fo••1Itle-rou;.and)·lime-
,tone in lower Itrata.
Upper Light Y4l!.ilowllh-brown to light gray-~rovnt
Cretaceous thick bedded to crels-bedded .andstoneI
Dakota Sandsto1'!t!:conglomeratic .andltone;interbedded thin30-75 len:lcular gray carDon.c.eCUI elaYltoneCRETACEOUSandimpureeoal;lccal courle b••al con-
glomerate.1--------Unconformity -------1.1ght-eray And l1eht-bro,,"'"n.massive and
cro••-bed~ed conglo_.ratic ••ndstoneJand
l.over Burro Canyon Fonution 50 -ISO interbedded Ireen and gray-gre,:n lDudlton~;
Cretaceoul locally cont.i~thin dilc:ontinuou.bed.
of !!It11cif1ed land.tone and ~i_.tone
near tcp.'------Unconfon:ity(?
Var1egatec!gray,pale-greer.,reddi.h-brClwn,
Brushy a..1n Member 200-450 and purple bentonitic:mudstone and silt-
atone conta1n1ng thin discontlnuo\lli I.nel-
Itone and con,lo_rate lenael.
e~InterbeddlOd yellowi.h-and greenish-gray
~~Weltwater Canyon to ::"lnk.llh-cray,fine-to courle-grained•0-250Q•MeQber aric.ol1c landltone and greeniah-gra)·to..N 0:>re~di.~,-brown .and}'.hale and IIUdltone,'"..
'"e%a Interbedded redd1ah-cuy to l1g~t bro·wn.:Recapture HeMer::0-200 flne-to medium-grained land.t.one and
a reddi.l:-sray silty and eand)'claystone.%
Upper Int-!t'oeacied yellowiah-brown.to pale
Jur••aic S.lt Walh Meaber 0-350 redJish-brown f ine-srained ttl con~lo~
er1etc la:TIdltcnel and areecish-andJUMSSICreddish-sray _stan.,
~-Uncanfonity
WIlito ta grayish-brown•...11ve,erol.-
Bluff Sandstone 0-15l>'-bedded,fine-to .edium-srain.d ealian
I.adstone....~S_rv111e Thin-bedded.ripple-..rked reddish-brown025-125..Foraatlon _ddr sandaton.and aandy .hal••'"i:Reddi.h-brown to srayish-vhiu...aaive,~Entrada•SandatoDt 150-110 cTos.-bedded,Une-ta .edi_srain.d•a.adatoM.e~Irre~ulary bedced reddi.h-brawn muddy
Car..l For.ation 20-100+.andltoae and .andy audatone w1th local
MidU.thin b.d.of brown to gray Ii.utone and
Juraaai"reddish-ta sr••nish-sray .hal••
Unconforctcy
*To convert f.et ta _t.n,..lriply feet by 0.3041,
Fig.2.9.Generalized stratigraphic section of exposed rocks in the project vicinity.Source:ER,Table 2.4-2.
C .'4588
~aDl
I:""'C-;\
I ,c,:
:ki~~·.':':
:ant
r 2-39
Thin,discontinuous beds of impure lignite and coal up to 0.6 m (2 ft)thick occur throughout
the Dakota Sandstone.Although several of these coal beds have been mined on a limited scale
in the Blanding area,most of the coals are too impure for commercial use.IS
Copper deposits are associated with the fracture-controlled uranium-vanadium deposits in the
Abajo Mountains and with some sedimentary deposits.The copper content may be as high as 3%.Sand and gravel deposits are mined on the east and south slopes of the Abajo Mountains for
pavement construction material.
Although water is produced from wells drilled to the Burro Canyon Formation and the Dakota
Sandstone,this water is corrrnonly mineralized and in some localities unfit for human con-
sumption.IS Deep wells drilled to the Entrada and Navajo sandstones yield potable water.17 ,lS
Several springs in the project vicinity discharge groundwater from the Burro Canyon Formation.
2.7.3 Seismicity
Within a 320-km (200-mile)radius of the site,450 seismic events occurred between 1853 and
1978.Of these,at least 45 had an intensity of VI or greater on the Modified Mercalli Scale.
Within a l60-km (lOO-mile)radius of the project area,15 earthquakes have been recorded.Of
these,only one had an intensity of V,and the rest were IV or less.The nearest event occurred
in Glen Canyon National Recreation Area,about 70 km (43.5 miles)northwest of the proposed
site.The next closest event occurred about 94 km (58.5 miles)to the northeast.The event of
intensity Voccurred on August 29,1941,just east of Durango,Colorado.2o It is doubtful that
any of these events would have been felt in the vicinity of Blanding.
Based on the region's seismic history,the probability of a major damaging earthquake occurring
at or near the proposed site is remote.Algermissen and Perkins2I indicate that there is a 90%
probability that horizontal acceleration of 40%gravity (0.4 g)would not be exceeded within
50 years.
2.8 SOILS
The majority (99%)of the soil on the project site consists of the Blanding soil series (ER,
Sect.2.10.1.1).The remaining 1%of the site is in the Me11enthin soil serles.Because the
Me11enthin ~oi1 occurs only on the eastern-central edge of the site (ER,Plate 2.10-1),it
should not be affected by construction and operation of the mill.
The mill and associated tailings disposal ponds will be 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,si1ty-c1ay-10am textures are found at some point in most profiles (ER,
Table 2.10-2).This soil generally has a 10-to 13-cm (4-to 5-in.)reddish-brown,silt-loam A
horizon and a reddish-brown,silt-loam to si1ty-c1ay-loam B horizon.The B horizon extends
downward about 30 to 40 cm (12 'to 16 in.)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 have an average pH of about 8.0,whereas the average pH at the Chorizonisabout8.5.Subsoil sodium levels range up to 12%in some areas,which is close to
the upper limit of acceptability for use in reclamation work (ER,Sect.2.10.1.1).Other
elements,such as boron and selenium,are well below potentially hazardous levels.Potassium
and phosphorus values are high in this soil (ER,Table 2.10-2)and are generally adequate for
plant growth.Nitrogen,however.is low (ER.Sect.2.10.1.1)and fuay have to be provided for
reclamation.
With the well-drained soils,relatively flat topography (Sect.2.3),and low precipitation
(Sect.3.2.1),the site generally has a low potential for water erosion.However,the flows
resulting from thunderstorm activity are nearly instanteous and,if uncontrolled,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 ofavailablemoisture(6 to 9%)is a 1imiting factor for plant growth;therefore,1ight irrigation
may be required to establish native vegetation during reclamation.
2-40
2.9.1 Terrestrial
I
f
I
Jc.J
f
I
I
55.6
49.9
61.0
79.7
67.9
67.4
80.0
15.6
16.9
24.2
9.5
20.1
.15.3
7.0
25.9
33.3
15.2
10.7
12.0
17.3
13.2
Vegetative cover Litter Bare ground
Community type
Percentage of each type of cover
Table 2.27.Ground cover for each community wi1hin the
project site boundary
•Rock covered 4.4%of the ground.
Pinyon-juniper woodland"
Big sagebrush
Reseeded grassland I
Reseeded grassland II
Tamarisk·salix
Controlled big sagebrush
Disturbed
ha acres
Pinyon-juniper woodland 5 13
Big sagebrush 113 278
Reseeded grassland I 177 438
Reseeded grassland II 121 299
Tamarisk'salix 3 7
Controlled big sagebrush 230 569
Disturbed 17 41
Expanse
Community type
Table 2.26 Community types and expan.wi1hin the
project site boundary
2.9.1.1 Flora
2.9 BIOTA
Based upon dry weight composition,most communities on the site were in poor range condition in
1977 (ER,Tables 2.8-3 and 2.8-4).Pinyon-juniper,big sagebrush,and controlled big sagebrush
communities were in fair condition.However,precipitation for 1977 at the project site was
classed as drought conditions (ER,Sect.2.8.2.1).Until July,no production was evident onthesite.
The natural vegetation presently occurring within a 40-km (25-mi1e)radius of the site is very
similar to that of the potential ,22 being characterized by pinyon-juniper woodland intergrading
with big sagebrush (Artemesia tridentata)communities.The pinyon-juniper community is domi-
nated by Utah juniper (Juniperus osteosperma)with occurrences of pinyon pine (Pinus eduZis)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 ga11eta grass (HiZaria jamesii),green ephedra (Ephedr~
viridis),and broom snakeweed (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.
Seven community types are present on the project site (Table 2.26 and Fig.2.10).Except for
the small portions of pinyon-juniper woodland and the big sagebrush community types,the majority
of the plant communities within the site boundary have been disturbed by past grazing and/or
treatments designed to improve the site for rangeland.These past treatments include chaining,
plowing,and reseeding with crested wheatgrass (Agropyron desertorum).Controlled big sage-
brush communities are those lands containing big sagebrush that have been chained to stimulate
grass production.In addition,these areas have been seeded with crested wheatgrass.BothgrasslandcommunitiesIandIIaretheresultofchainingand/or plowing and seeding with
crested wheatgrass.The reseeded grassland II community is in an earlier stage of recovery
from disturbance than the reseeded grassland I community.The relative frequency,relative
cover,relative density,and importance values of species sampled in each community are pre-sented in the ER,Table 2.8-2.The percentage of vegetative cover in 1977 was lowest on the
reseeded grassland II community (10.7%)and highest on the big sagebrush community (33%)(Table
2.27).
No designated or proposed endangered plant species23 occur on or near the project site
(ER,Sect.2.8.2.1).Of the 65 proposed endangered species in Utah,six have documented
distributions in San Juan County.2~Acareful review of the habitat requirements and known
distributions of these species indicates that,because of the disturbed environment,these
species would probably not occur on the project site.
2-41
ES-4580
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CONTROLtED
BIG SAGEBRUSH
TAMARIX-SALIX
DISTURBED
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e RESEEDED.e GRASSLAND I
I /.J ('._:\,~<<.I n RESEEDED,).(':~/-(·.----V-.-r;-;...M \I::£;J GRASSLAND II)-,.)1 -..-.!...,.,1'"-~/_\_'-,_/~r+\~\,~sa BIG SAGEBRUSH
[
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ty
Fig.2.10.Community types on the White Mesa project site.Source:Energy Fuels
Nuclear,Inc.,"Responses to COllII1ents Telecopied from NRC to EnergY"T'UeTs Nuclear,Sept.25,1978,"Oct.4,1978,Plate 2.8-2.
2-42
2.9.1.2 Fauna
The applicant has collected wildlife data through four seasons at several locations on the
site (Fig.6.1).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 proposed mill (ER,Appendix D),78 of which were
confirmed (ER,Sect.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.The tiger salamander (Ambystoma tigrinum)was
the only species observed.It appeared in the pinyon-juniper woodland west of the project site(ER,Sect.2.8.2.2).
Eleven species of lizards and five snakes potentially occur in the area.Three species of
lizards were observed:the sagebrush lizard (SaeZoparas graaiosus),western whiptail
(Cnemidophorus tigris),and the short-horned lizard (Phrynosoma dougZassi)(ER,Sect.2.8.2.2).
The sagebrush and western whiptail lizard were found in sagebrush habitat,and the short-horned
lizard was observed in the grassland.No snakes were observed during the field work.
Fifty-six species of birds were observed in the vicinity of the project site (Table 2.28).The
abundance of each species was estimated by using modified Emlen transects and roadside bird
counts in various habitats and seasons.Only four species were observed during the February
sampling.The most abundant species was the horned lark (EremophiZa aepestis)followed by the
common raven (Corvus aorax),which were both concentrated in the grassland.Avian counts
increased drastically in May.Based on extrapolation of the Emlen transect data,the avian
density on grassland of the project site during spring was about 305 per square kilometer (123
per 100 acres).Of these individuals,94%were horned larks and western meadowlarks (SturneZZa
negZeata).This density and species composition are typical of rangeland habitats.2s In late
June the species diversity declined somewhat in grassland but peaked in all other habitats.By
October the overall diversity decreased but again remained the highest in grassland.
Raptors are prominent in the western United States.Five species were observed in the vicinity
of the site (Table 2.28).Although no nests of these species were located,all (except thegoldeneagle,AquiZa ahrysaetos)have suitable nesting habitat in the vicinity of the site.
The nest of a prairie falcon (PaZao mexiaanus)was found about 1.2 km (3/4 mile)east of the
site.Although no sightings were made of this species,members tend to return to the same
nests for several years if undisturbed (ER,Sect.2.8.2.2).
Of several mammals that occupy the site,.mule deer (OdoaoiZeus hemionus)is the largest species.
The deer inhabit the project vicinity and adjacent canyons during winter to feed on the sage-
brush and have been observed migrating through the site to Murphy Point (ER,Sect.2.8.2.2).
Winter deer use of the project vicinity,as measured by browse utilization,is among the
heaviest in southeastern Utah [61 days of use per hectare (25 days of use per acre)in the
pinyon-juniper-sagebrush habitats in the vicinity of the project site].26 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 inhabiting the area has also been observed between
Westwater Creek and Murphy Point.26 The present size of the local deer herd is not known.
Other malllllals present at the site include the coyote (Canis Zatrans),red fox (VuZpes vuZpes),
gray fox (Uroayon aineroargenteus),striped skunk (Mephitis mephitis),badger (Taxidea taxus),
longtail weasel (MusteZa frenata),and bobcat (Lynx rufus).Nine species of rodents were
trapped or observed on the site,the deer mouse (PeromysauB manicuZatus)having the greatest
distribution and abundance.Although desert cottontails (SyZviZagus auduboni)were uncommon
in 1977,black-tailed jackrabbits (Lepus aaZ~fornicus)were seen during all seasons.
Three currently recognized endangered species of animals27 could occur in the project vicinity.
However,the probability of these animals occurring near the site is extremely low.The project
site is within the range of the bald eagle (HaUaeetus ZeuaoaephaZus)and the American peregrine
falcon (FaZao peregrinus anatum),but the lack of aquatic habitat indicates a low probability
of these species occurring On the site.Although the black-footed ferret (MusteZa ni~pes)
once ranged in the vicinity of the site,it has not been sighted in Utah since 1952,2 and the
Utah Division of Wildlife feels it is highly unlikely that this animal is present (ER,Sect.
2.8.2.2).
I~...
I
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2-43
Table 2.28.Birds observed in the vicinity of the proposed WhiteMesa Uranium Project
Statewide Statewide
relative Species relativeSpeciesabundanceabundance
and status'and status'
Mallard CP Pinyon jay CP
Pintail CP Busl'ltit CP
Turkey vulture US Bewick's wren CP
Red-tai led I'lawk CP Mockingbird US
Golden eagle CP Mountain bluebird CS
Marsl'l hawk CP Black·tailed gnatcatcher H
Merlin UW Ruby-crowned kinglet CP
American kestrel (;P Loggerl'lead sl'lrike CS
Sage grouse UP Starling CP
Scaled quail Not listed Yellow-rumped warbler CS
American coot CS Western meadowlark CP
Killdeer CP Red-winged blackbird CP
Spotted sandpiper CS Brewer's blackbird CP
Mourning dove CS Brown·l'leaded cowbird CS
Common nigl'ltl'lawk CS Blue grosbeak CS
White·tl'lroated swift CS House finch CP
Yellow-bellied sapsucker CP American goldfinch CP
Western kingbird CS Green-tailed towl'lee CS
Ash-throated flycatcher CS Rufous·sided towhee CP
Say's phoebe CS .Lark sparrow CS
Horned lark CP Black·throated sparrow CS
Violet-green swallow CS Sage sparrClw US
Barn swallow CS Dark-eyed junco CW
Cliff swallow CS Chipping sparrow CS
Scrub jay CP Brewer's sparrow CS
Black·billed magpie CP White·crowned sparrow CS
Common raven CP Song sparrow CP
Common crow CW Vesper sparrow CS
·W.H.Behle and M.L.Perry,Utah Birds,Utah Museum of Natural History,
University of Utah,Salt Lake City,1975.
2.9.2 Aquatic biota
Aquatic habitat at the project 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 catch basins (Sect.2.6.1.1),approximately 20 m in diameter,
are located on the project site,but these only fill naturally during periods of heavy rainfall
(spring and fall)and have not held rainwater during the year-long baseline water quality
monitoring program.Although more properly considered features of the terrestrial environment,
they essentially represent the total aquatic habitat on the project site.When containing
water,these catch basins probably harbor algae,insects,other invertebrate forms,and
amphibians.They may 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 project
site and south of Blanding.The basin to the northeast of the present ore buying station has
been filled with well water to be used during construction of the adjacent office and labora-
tory facilities.Present plans are for it to contain water for approximately six months.This
basin has not been sampled for aquati~biota since filling.
Relative abundance
C =common
U =uncommon
H =hypothetical
Source:EA,Table 2.8-5.
Status
P =permanent
S =summer resident
W =winter visitant
2-44
Aquatic habitat in the project 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 these streams.Again,due to the
temporary nature of these streams,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.
No populations of fish are present ?n the pr?ject ~ite,nor are any know~to exist,in its imme-
diate vicinity.The closest perennlal aquat1c hab1tat to the proposed m1ll,appears to be a small
irrigation basin (approximately 50 m in diameter)about 6 km (3.8 miles)upgrade to the no~th­
east.This habitat was not sampled for biota b~the ap~licant,who reports that the pond 1S
intermittent and probably does not harbor any f1sh spec1es.
The closest perennial aquatic habitat known to support fiGh populations is the San Juan River
29 km (18 miles)south of the project site.Five species of fish Federally designated (or
proposed)as endangered or threatened occur in Utah (Table 2.29).One of the five species,the
woundfin (PZegopterus argentissimus),does not occur in southeastern Utah where the proposed
mill site is located.29 The Colorado squawfish (PtychocheiZus Zucius)and humpback chub (GiZa
cypha),however,are reported as inhabiting large river systems in southeastern Utah.The
bonytail chub (GiZa eZegans),classified as threatened by the State and proposed as endangered
by Federal authorities is also 1imited in its distribution to main channels of large rivers'.
The humpback sucker (razorback sucker;Xyrauchen texanus),protected by the State and proposed
as threatened by the Federal authorities,is found in southeastern Utah inhabiting backwater
pools and quiet areas of mainstream rivers.The closest habitat suitable for the Colorado
squawfish,humpback chub,bonytail chub,and humpback sucker is the San Juan River,29 km
(18 miles)south of the proposed site.
Table 2.29.Threatened and endangered aquatic species occurring in UUh
Occurrence
Species Habitat Listing in
southeastern Utah
Woundfin Silty streams;muddy,swift-current Federal -endangeredb No
Plegoprerus argentissimus areas:Virgin River critical habita~State -threatened
Humpback chub Large river systems,eddies.and Federal -endangeredb Yes
Gilacypha backwater State -endangered
Colorado River squawfish Main channels of large river systems Federal -endangeredb Yes
Prychocheilus lucius in Colorado drainage State -endangered
Bonytail chUb Main channels of large river systems Federal -proposed Yes
Gila elegans in Colorado drainage endangeredC
State -threatened
Humpback sucker Backwater pools and quiet-water Federal -proposed Yes(razorback sucker)areas of main rivers threatenedc
Xyrauchen rexanus State -threatened
·"Endangered and Threatened Wildlife and Plants,"Fed.Regist 42(211):57329 (1977).
b"Endangered and Threatened Wildlife and Plants,"Fed.Regist 42(135):36419-39431 (1977).
c"Endangered and Threatened Wildlife and Plants,"Fed.Regist 43(79):17375-17377 (197B).
I
I
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I
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I
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I
I
I
I
I
10 NATURAL RADIATION ENVIRONMENT2.
diation exposure in the natural environment is due to cosmic and terrestrial radiation and
Ra the inhalation of radon and its daughters.Measurements of the background environmental
tOdioactivity were made at the proposed mill site using thermoluminescent dosimeters (TLDs).~~results indicate an average total-body dose of 142 millirems per year,of which 68 millirems
.eattributable to cosmic radiation and 74 millirems to terrestrial sources.The cosmogenic
lSdiatiOn dose is estimated to be about 1 millirem per year.3D Terrestrial radiation originates~aom the radionuclides potassium-40,rubidium-87,and daughter isotopes from the decay of~anium-238,tho~ium-232,and,to a lesser extent,uranium-235.The dose from ingested radio-~uclides is estimated at 18 millirems per year to the total body.3D The dose to the total body
from all sources of environmental radioactivity is estimated to be about 161 millirems per
year.
The concentration of radon in the area is estimated to be in the range of 500 to 1000 pCi/m3 ,
based on the concentration of radium-226 in the local soil.3o ,31.Exposure to this concentra-
tion on a continuous basis would result in a dose of up to 625 millirems per year to the bron-
hial epithelium.32 As ventilation decreases,the dose increases;for example,in unventi-
lated enclosures,the comparable dose might reach 1200 millirems per year.
The medical total-body dose for Utah is about 75 millirems per year per person.33 The total
dose in the area of the proposed mill from natural background and medical exposure is esti-
mated to be 236 millirems per year.
2-46
REFERENCES FOR SECTION 2
1.Energy Fue 1s Nuc1ea r,Inc.,"Suppl ementa 1 Report,Meteoro logy and Air Qua1ity,
Environmental Report,White Mesa Uranium Project,San Juan County,Utah,"Sept.6,1978.
2.The Bureau of Economic and Business Research,Co~~nity Economic Facts:Blanding,Utah -
1975,prepared for Utah Industrial Development Information Service,Salt Lake City,Utah.
3.The Bureau of Economic and Business Research,Community Economic Facts:Blanding,Utah -
197?,prepared for Utah Industrial Development Information Service,Salt Lake City,Utah.
4.The Bureau of Economic and Business Research,Community Economic Facts:Monticello,Utah -
1975,prepared for Utah Industrial Development Information Service,Salt Lake City,Utah.
5.The Bureau of Economic and Business Research,Community Economic Facts:Monticello,Utah -
1977,prepared for Utah Industrial Development Information Service,Salt Lake City,Utah.
6.Energy Fuels Nuclear,Inc.,"Responses to Convnents on White Mesa Project DES,"
~larch 6,1979.
7.Utah Department of Employment Security,Research and Analysis Section,adapted from
Quarterly Employment Ne~sletter of Southeastern District of Utah,January-March 1978.
8.Utah Industrial Development Information Service,County Economic Facts:San Juan
County -1977.
9.Utah Department of Transportation,State of Utah,Major Hig~ys Map,Salt Lake City,
Utah,1976.
10.Energy Fuels Nuclear,Inc.,"Response to Comments from the U.S.Nuclear Regulatory
Commission,June 7,1978,White Mesa Uranium Project Environmental Report,"Denver,
June 28,1978.
11.State of Utah,Division of State History,"Archeological Test Excavations on White ~1esa,
San Juan County,Southeast Utah,"prepared for Energy Fuel s Nucl ear,Inc.,Denver,
Colorado,May 1978;also "Additional Archeological Test Excavations on White Mesa,
San Juan County,Southeast Utah,"January 1979.
12.Environmental Protection Agency,Quality Criteria for Water,Report EPA-440/9-76-023,
Washington,D.C.,1976.
13.U.S.Envi ronmenta1 Protection Agency,"Water Quality Criteria 1972,"Committee on Water
Quality Criteria,1972.
14.R.D.Feltis,Water from Bedrock in the Colorado Plateau of Utah,Utah State Engineer
Technical Publication No.15.1966.
15.E.M.Shoemaker,StructUX'al FeatUX'es of Southeastern Utah and Adjacent Parts of Colorado,
New Mexico,and Arizona,Utah Geological Society Guidebook to the Geology of Utah No.9,
1954,pp.48-69.
16.E.M.Shoemaker,StruatUX'al FeatUX'es of the Colorado Plateau and Their Relation to Uranium
Deposits,U.S.Geological Survey Professional Paper 300,1956,pp.155-168.
17.H.S.Johnson,Jr.,and W.Thordarson,Uranium Deposits of the Moab,Monticello,White
Canyon,and Monument Valley Districts,Utah and Arizona,U.S.Geological Survey Bulletin
1222-H,1966.
18.L.C.Huff and F.G.Lesure,Geology and Uranium Deposits of Montezuma Canyon Area,San
Juan County,Utah,U.S.Geological Survey Bulletin 1190,1965.
2-47
19.I J Witkind,GeoZocu o~~he Abajc Mcun~~~ns A~e~,San Juan County,Ytah,U.S.Geologicals~rv~y Professional Paper 453,1964.
F.A.Hadsell,Sisto Earthquake Act.CoZorado 63(1):57-72 (1968).
S.T.Algermissen and D.M.Perkins,A PrcbabiZis~ic Estimate of Ma:imum Acceleration in
21.Rock in the Con~i~uous United States,U.S.Geologlca1 Survey Open Flle Report 76-416,
1976.
R.L.Linder and C.N.Hillman,Proceedings of the Black-Footed Ferret and Prairie Dog
Workshop,September 4-6,1973,South Dakota State University,Brookings,1973.
L.B.Dalton et al.,Species List of Invertebrate wildlife that Inhabit Southeastern Utah,
Utah State Division of Wildlife Resources,1977.
J.A.Wiens and M.1.Dyer,"Rangeland Avifaunas:Their Composition,Energetics,and Role
in the Ecosystem,"in Proceedings of the Symposium on Management of Forest and Range
Habitats for Nongame Birds,U.S.Forest Service General Technical Report WO-l,1975.
State of Utah,Division of Wildlife Resources,letter to Jim Chadwick,Dames and Moore,
July 27,1977.
"Endangered and Threatened Wildlife and Plants,"Fed.Regist.42(135):36419-36431 (1977).
22.A.W.Kuchler,Potential NaturaZ Vegetation of the Conteminous United States,Special
publication 36,American Geographical Socjety,New York,1964.
23."Endangered and Threatened Wildlife and Plants,"Fed.Regist.41(117):24524-24572 (1976).
S.L.Welsh,N.D.Atwood,and J.L.Reveal,"Endangered,Threatened,Extinct,Endemic,
and Rare or Restricted Utah Vascular Plants,"Great Basin Nat.35(4):327-376 (1975).
National Council on Radiation Protection and Measurements,Natural Background Radiation
in the United St~tes,Report No.45,1975.
K.J.Schaiger,"Analysis of Radiation Exposure On or Near Uranium Mill Tailings Piles,"
Radiation Data Rep.14:41 (1974).
National Academy of Sciences-National Research Council,The Effects on Populations of
Exposure to Low Levels of Ionizing Radiation,Report of the Advisory Committee on the
Biological Effects of Ionizing Radiation (BEIR Report),NAS-NRC,Washington,D.C.,1972.
33.U.S.Department·of Health,Education,and Welfare,Population Exposure to X-rays,U.S.
1970,Report DHEW-73-8047,November 1973.
24.
25.
c·26.
V
27.
28.
29.
30.
31.
r::r.,'~,
32.
t"f.,''~
3.OPERATIONS
3.1 MINING OPERATIONS
The White Mesa Uranium Project will process ores originating in independent and company-owned
mines.Mines within 160 km (100 miles)of Energy Fuels ore buying stations (in Blanding or
Hanksville)are expected to supply virtually all of the ore processed by the facility.Energy
Fuels controls reserves of approximately 8600 metric tons (MT)(9500 tons)of U30S with an
average ore grade of 0.125%U30S (ER,p.l-n.Additional ore will be purchased from independent
mines.There will be no onsite mining activity.The environmental effects of the Blanding
ore buying station (on the project site)are included in this assessment.
3.2 THE MILL
The proposed mill will utilize an acid leach-solvent extraction process for uranium recovery.
Provisions for vanadium byproduct recovery are included in the design.The nominal processing
capacity of the mill is 1800 MT (2000 tons)per day.The expected average ore grade is 0.125%
U30S'The process will recover approximately 94%of the uranium in the are.The proposed mill
would operate on a 24 hr/day,340 days per year schedule.Based on the above design para-
meters,the annual U30S production of the proposed White Mesa mill will be approximately
730 MT (800 tons).The estimated annual vanadium (V20S)production is 1480 MT (1630 tons).
3.2.1 External appearance of the mill
The plant buildings will be mainly of prefabricated construction.Although the facility will
resemble the artist's rendition (Fig.3.1),the final layout may vary,depending on final
equipment selection.
As viewed from U.S.Highway 163,the mill will consist of a series of long buildings.Portions
of the mill will stand above the natural skyline.The ore buying station,ore stockpiles,and
the natural terrain will obscure the view of portions of the mill.The proposed tailings
impoundment should not significantly alter the landscape as seen from the highway,except
around soil stock piles and borrow areas.
3.2.2 The mill circuit
3.2.2.1 Uranium circuit
The flow sheet for the uranium circuit of the proposed mill is shown in Fig.3.2.The ore
would undergo a sequence of crushing,grinding,leaching,counter-current decantation,and
solvent-extraction steps.The extracted uranium would be precipitated,dried,and packaged for
shi pment.
Most ores would be fed to the mill via the ore buying stations.Because the ores will originate
from many different mines,blending will be necessary to ensure optimal processing amendability.
This blending will occur as the ore is fed to the mill.
Ore received at the ore buying stations is crushed to less than 3.8 cm (1.5 in.)during the
sampling process.As the ore is fed to the mill,a semi autogenous grinding (SAG)mill will
reduce the feed size to smaller than a 28-mesh (0.589 mm or 0.0232 in.)screen.The ore slurry
produced by the SAG mill will be leached in two stages with sulfuric acid,manganese dioxide
(or an equivalent oxidant),and steam in amounts that will produce an acid solution with a
temperature of 71°C (160°F).Acid consumption will be reduced by neutralizing the alkaline
.3-1
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View of the proposed White Mesa Uranium Project.~o~rce:ER,Plate 3.1-1.
12
Fig.3.1.
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8
ORE STOCKPILES FROM
BUYING STATION
ATMOSPHERE
H2O
ORGANIC
PREGNANT LEACH
SOLUTION
BARREN PREGNANT
ORGANIC ORGANIC
NaCI
BARREN PREGNANT BARRENLEACHSTRIPSTRIPI
I•OPTIONAL
TAILING TO
VANADIUM
RECOVERY
YELLOW CAKE
PRODUCT
Fig.3.2.Generalized flowchart for the uranium milling process.Source:ER,Plate 3.2-1.
components of the ore with excess acid in the pregnant leach solution in a preleach stage
(Fig.3.2).It is anticipated that approximately 95%of the uranium contained in the crude ore
will be dissolved over a leaching period of up to 24 hr.The uranium-bearing solution will be
separated from the barren waste by counter-current decantation using thickeners.Polymeric
flocculants will be used to enhance the settling characteristics of the suspended solids.The
decanted pregna~t leach solution is expected to have a pH of approximately 1.5 and contain less
than 1 g of U30a per liter.The barren waste will be pumped to the tailings retention area.
Solvent extraction will be used to concentrate and purify the uranium contained in the decanted
leach solution.In a series of mixing and settling vessels,the solvent extraction process
will use an amine-type compound carried in kerosene (organic)which will selectively absorb the
dissolved uranyl ions from the aqueous leach solution.The organic and aqueous solutions will
be agitated by mechanical means and then allowed to separate into organic and aqueous phases in
the settling tank.This procedure will be performed in four stages using a counter-flow
principle in which the organic flow is introduced to the preceding stage and the aqueous flow
(drawn from the bottom)feeds the followi ng stage.It is estimated that,after four stages,
the organic phase will contaift about 2 g of U30a per liter and the depleted aqueous phase
(raffinate)about 5 mg per liter.The raffinate will be recycled to the counter-current
decantation step previously described or further processed for the recovery of vanadium (Sect.
3.2.2.2).The organic phase will be washed with acidified water and then stripped of uranium
by contact with an acidified sodium chloride solution.The barren organic solution will be
returned to the solvent extraction circuit,and the enriched stripping solution containing
-,
!
/
ATMOSPHERE
SODA
ASH
r.:~~---l--PREGNANT
ORGANIC
r-------------------------------!PRECIPITATIONAND
THICKENING
1+----(OFimjG)._-------------I ANDFILTERING
DRIED OR
FUSED
VANADIUM
PRODUCT
ES 4~B~
3-4
Fig.3.3.Generalized flowchart showing recovery of vanadium.Source:ER.Plate 3.2-3.
3.2.2.2 By-product vanadium recovery
Vanadium,which is present in some of the ores,will be partially solubilized during leaching.
The dissolved vanadium will be present in the uranium raffinate.Dependinq on its vanadium
:ontent,the uranium raffinate will either be recycled to the counter-current decantation step
(Sect.3.2.2.1)or further processed for recovery of the vanadium before recycling.
The vanadium recovery process will consist of a separate solvent extraction step to treat theuraniumraffinateandprecipitatethevanadiumfromthestrippingsolution.The flowchart
shown in Fig.3.3 illustrates the process.
about 20 g of U30S per liter will be neutralized with ammonia to precipitate ammonium diuranate
(yellow cake).The yellow cake will be settled in two thickeners in series,and the overflow
solution from the first will be filtered,conditioned,and returned to the stripping stage.
The thickened yellow cake slurry will be dewatered further in centrifuges to ~educe its water
content to about 40%.This slurry will then be pumped to an oil-fired multiple-hearth dryer
(calciner)at 650°C (1200e F).The dried uranium concentrate (about 90%U30S )will be passed
through a hammer mill to produce a product of less than 0.6 cm (1/4 in.)size.The crushed
concentrate,which is the final product of the plant,will then be packaged in 55-gal drums for
shipment.
I-
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3-5
ium raffinate will be pumped to a series of agitators where the electromotive forceThe.ur~~on potential)will be adjusted to -700 mV with ~~_~te and the pH raised to(OX1~aO The solution may possess some turbidity after this step and will be filtered prior to
1.8-.·'to a five-stage solvent extraction circuit.Except for the one additional stage of
passlniion the solvent extraction section will be essentially the same as utilized for thee;<tr~Cm An amine-type compound carried in kerosene (Sect.3.2.2.1)will selectively absorb~ranlun~dium ions from the uranium raffinate solution.The organic solution will then be
the.vaed of vanadium by contact with a soda ash solution.The barren organic solution will bestrlP~ed to the solvent extraction circuit,and vanadium will be precipitated from the enrichedret~rp"ng solution on a batch basis as ammonium metavanadate.strlp .
anadium precipitate will be thickened and filtered prior to drying in an oil-fired dryer.
The ~ried precipitate will be subjected to a fusion step at approximately 800°C (1500°F)to
Thed ce V 05 (black flake);packaging will be in 55-gal drums.Less than 0.005 percent U30a willb~oc~ntai~ed in the vanadium product.39
3.2.3 Nonradioactive wastes and effluents
3.2.3.1 Gaseous effluents
Milling operations will result in the release of nonradioactive vapors to the atmosphere.
Leachi!!.9..
The leaching of ores in the uranium and circuit will produce carbon dioxide gas,sulfur dioxide
gas water vapor,and some sulfuric acid mist.Based on the projected calcite concentration in
the'ore and process conditions,the applicant estimates emissions of carbon dioxide to be 2200
kg/hr (4800 lb/hr)and emissions of sulfur dioxide and sulfuric acid mist to be 0.023 kg/hr
(0.05 lb/hr)from leaching (ER,p.3-10).The staff agrees with these estimates.
Solvent extraction
The solvent extraction processes used in uranium and vanadium recovery will release organic
vapors consisting of kerosene (95%)and small quantities of amine and alcohol compounds used in
the extraction.The applicant estimates the organic losses to be approximately 0.046 kg/hr
(0.1 lb/hr)(ER,p.3-10).There are no Federal or State emissions standards applicable to
the release of this mixture.However,Federal and State ambient air quality standards have
been set at 160 ~g/m3,averaged over 3 hr.The applicant states that operation of the pro-
posed mill will not result in hydrocarbon concentrations exceeding this level (ER,p.3-10).
Product dryers
The yellow cake and vanadium black flake dryers will burn approximately 11 liters/hr (3 gph)
of No.2 fuel oil «1%sulfur),producing gaseous effluents containing nitrogen,carbon
dioxide,water vapor,sulfur dioxide,and nitrogen OXides,as well as some ammonia from decom-
position of the concentrate product.Radioactive effluent from this source is discussed in
Sect.3.2.4.6.The applicant estimates that dryer off-gas concentrations of sulfur dioxide
and nitrogen oxides will be 0.91 kg/hr (2 lb/hr)and 0.23 kg/hr (0.5 lb/hr)respectively (ER,
p.3-11).
Because the heat input to the yellow cake and vanadium black flake dryers will be only 4.7 x
lOa J/hr (4.5 x 105 Btu/hr),no Federal or State emission standards apply to this source.
However,Federal and State ambient air quality standards will apply to nitrogen oxides,sulfur
dioxide,and particulate concentrations due to dryer operation.
BUilding and process heating
Steam necessary for building and process heating will be generated from coal-fired boilers.
Approximately 55 MT (60 tons)of coal per day will be required at a heat input of approximately
5:3 x 1010 J/hr (5 x 106 Btu/hr).As a result of the boiler combustion,various stack gasesw~ll be released to the atmosphere,including carbon dioxide,water vapor,sulfur dioxide,and
nltrogen oxides.
I .I
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3-6
State and Federal emission standards are not applicable to a steam generating boiler of this
small size.However,Federal and State ambient air quality standards will apply to tne
resulting ambient concentrations.The combustion of 55 MT (60 tons)per day of 0.3%sulfur
coal would generate approximately 33 kg (720 lb)of sulfur dioxide per day (ER,p.3-21).Based
on an industrial NOx emrnission factor of 10 kg/MT (20 lb/ton)of coal burned,the staff
estimates nitrogen oxide emissions to be 545 kg/day (1200 lb/day).Fly ash emissions from this
proposed boiler are discussed in Sect.3.2.3.3.
Analytical laboratory
The mill facility will be complemented with an analytical laboratory that will routinely assay
products of ore,process streams,and final products to assure adequate quality control and
plant operating efficiency.The laboratory fume hoods will collect air and mixed chemical
fumes for dilution and venting to the atmosphere.These gases will contain nonradioactive
chemicals,such as CO2,HC1,and N02'The volume of gaseous fumes emitted from the laboratory
operations will be small and,considering the dilution in the collection stack and air
eductors,should be inconsequential (ER,p.3-22).
3.2.3.2 Liquid effluents
All mill process,mill laundry,and analytical laboratory liquid wastes will be discharged to
the tailings impoundment for disposal by evaporation (Sect.3.2.4).Sanitary wastes will b~
disposed of by a septic tank and leach field designed and operated in accordance with appli-
cable State of Utah,Division of Health,and U.S.Public Health Service standards and regula-
tions.
Storm runoff from above the mill,ore storage piles,ore buying station,and the initial tail-
ings impoundment (cell 1 -initial)will be diverted to offsite drainages (Figs.3.4 and 3.6).
The runoff from the mill and facilities area will be impounded in a sedimentation pond
located at the southwest corner of the mill and facilities area bounded by cells 1 and 2.
3.2.3.3 Solid effluents
Nonradioactive solid wastes will be generated by the coal-fired boiler,the ore buying stations,
and by maintenance and administrative activities at the mill.Dusts will be emitted from ore
crushing and handling operations,ore storage piles,unstabilized tailings,and from the
uranium yellow cake and vanadium black flake dryer stacks.With the exception of the black
flake dryer,the dusts from these sources are contaminated with low levels of radioactivity.
Radioactive solid effluents are discussed in Sect.3.2.4.
Building and process heating
The combustion of coal will produce two ash products,fly ash and bottom ash.With a coal
usage rate of 55 MT (60 tons)per day,the total ash production would be less than 5.5 MT
(6 tons)per day,which will be sent to the tailings retention system.These ash products
would settle with the tailings solids and present no additional waste problems.
Stack emissions from the coal-fired boilers will pass through multiclones to remove fly ash,
and less than 86 kg (190 lb)per day of particulate matter will be released to th!atmosphere.
Fly ash deposits from the precipitator will also be sent to the tailings impoundment(ER,p.3-21)..
Ore processing,maintenance,and administration
Scrap iron,wood,and other mine trash removed from the ore during crushing operations will be
only slightly contaminated such that it may be disposep of as nonradioactive waste.Trash,
rags,wood scrap,and other uncontaminated solid debris will result from maintenance and
administrative activities.These materials will be disposed of in land fill areas approved by
the State Division of Health and the appropriate local authorities.
(,J•......
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GENERAL NOTES
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• ,..,'I.•-'l~'.'._,'.'"'"t,...I,':I •I •I .1..";ik"i·L,~.f,'''l ..',.
;--
Fig.3.4.Overall plot plan as proposed for the six-cell tailings disposal system including possible future cell additions,
Source:Energy Fuels Nuclear,Inc.,"Transmittal of Conceptual Review Construction Drawing Set and Synopsis,Tailings ManagementSystem,White Mesa Uranium Project,Blanding,Utah,"Apr.2,1979.
~I:
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3-8
Vanadium product dryer
When ore characteristics permit,the vanadium recovery circuit will extract the vanadium from
the uranium circuit effluent (Sect.3.2.2.2).The precipitated vanadium product will be dried
in an oil-fired dryer to give vanadium pentoxide (black flake).Vanadium pentoxide is toxic.
Therefore,drying and packaging will occur in an isolated building,and emissions will be
controlled by a wet fan scrubber operating at an equivalent venturi scubber pressure of 51 cm
(20 in.)of water and an efficiency of 99%.The applicant estimates the particulate release
.rate from this source to be 0.23 kg/hr (0.5 lb/hr).l
3.2.4 Radioactive wastes and effluents
r1ining and milling of natural uranium releases some radioactivity to the environment.Uranium-
238 and its daughter products in the ore are the most significant sources of radiation.The ore
processed by the proposed White Mesa mill is expected to have an average grade of 0.125%uranium
(as U30a).Ore of this grade has an activity of about 320 uCi of uranium-238 per ton of ore.
The activity from uranium-235 and its daughters is only 5%of that of the uranium-238 series and
may be ignored as it is radiologically insignificant.
Ore buying,shipping,and mi11i.ng processes offer several pathways for release of radioactive
effluents to the environment (Fig.3.5).The applicant's existing Hanksville and Blanding ore
buying stations and the proposed mill are designed to minimize the releases through these
pathways.The ore buying stations are the subject of NRC licensing actions independent from
the mill source material license,which is the subject of this document.Effluents from the
operation of these stations will be considered only as they impact the environment around the
site.In the following sections each potential effluent source is discussed,and estimates of
effluent releases based on operating data from other similar facilities will be presented.
3.2.4.1 Ore crushing and sampling
Run-of-mine ore will be received at the applicant's ore buying stations at Hanksville and
Bl andi ng.Ore from di fferent mi nes wi 11 be segregated into "l otsII to fad 1Hate samp 1ing and
payment.The raw ore will pass through a primary crusher and be reduced to less than 3.8 cm
(1.5 in.).A fraction of the ore will be subjected to a crushing and sampling process that will
produce a representative sample of the entire ore lot being processed.During the sampling
process,radon gas and low-level radioactive ore dust will be released.
The Blanding ore buying station is expected to process 114 tiT (l25 tons)of ore per hour,opera-
ting on one 8-hr shift per day.All feeders,crushers,screens,chutes,and transfer points are
enclosed in hoods connected via ducts to the three baghouse dust filters used in the plant.The
filters are cleaned by a reverse jet of air,which knocks the dust into a bin at the bottom of
the baghouse.The collected dust is recombined with the ore at appropriate points,so the ore
grade is not altered (ER,p.3-32).
The bag filters have a dust removal efficiency of around 99.5%(ref.2).Assuming the ore to be
fairly dry «6%moisture)and the dust load to the collector to be 0.008%by we1~ht,3 the dust
loss from the total crushing and sampling process would be approximately 4 x 10 %.Conserva-
tively assuming that the entire mill ore demand of 1800 MT per day is processed by the Blanding
station primary crusher,the annual dust emission would be 0.245 MT per year.At an average
grade of 0.15%U30a,slightly higher than expected,the concentration of uranium-238 in ore
would be about 423 pCi/g.Also,the uranium concentration of fine crusher dusts is reported to
be about 2.5 times the concentration in the gross ore.3 Based on these data,and the assumption
of secular equilibrium,approximately 2.6 x 10-*Ci per year of uranium-238 and each radioactive
daughter would.be released.
Radon-222 gas would be released as a result of disturbance of the ore during processing.Roughly
10%of the equilibrium amount of radon is released during crushing and grinding operations.*
Use of this value for the Blanding ore buying station is conservative because secondary crushing
and grinding do not occur.Based on a 10%radon loss,an ore process rate of 1800 MT per day,
and an equilibrium ore concentration of 423 pCi/g,approximately 26 Ci of radon-222 would be
released each year.
3.2.4.2 Transportation of ore to the mill
Crushed ore will be transported from the Hanksville buying station to the proposed mill in
canvas-covered dump trucks of 30-ton capacity.The ore will ndt be heaped in the truck beds but
will be evenly distributed to prevent ore spillage during transportation.The use of a canvas
cover tied over the truck bed will minimize dust loss during haulage (ER,p.3-30).
3-9
-I
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ium
and
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f
(AIR (YELLOW CAKE))
ES-4S93
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ill
'a-
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be
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.0
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ve
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-ng
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Fig.3.5.Radionuclide dispersion pathways relevant to the White Mesa Uranium Project.
3.2.4.3 Ore pads
Quantities of ore will be stored in stockpiles at the applicant's ore buying stations at Hanks-
ville and Blanding.These ore buying stations are the subject of two additional licensing
actions separate from the mill application.The effluents from the ore pad at the Blanding ore
buying station.however.would act in synergism with the effluents from the proposed-mill;
therefore,the Blanding ore pad operations and effluents are discussed.
Because of present ore buying operations.the applicant is accumulating ore in a 2.4-ha (6-acre)
area north of the existing Blanding ore buying station.The applicant estimates that a maximum
of 2.3 x 105 NT (2.5 x 105 tons)of ore will be stockpiled at the Blanding site at the time of
mill startup.This quantity of ore would create a pile 6.7 m {22 ft}tall covering the 2.4-ha
(6-acre)stockpile area.During operations.the stockpile would be reduced to under 9.1 x 104
MT {l x 105 tons).
Particulates and radon-222 will be the main atmospheric emissions associated with the ore piles.
Based on the meteorological data and the dusting rates for tailings sands (as a function of wind
speed)presented in Appendix D.and assuming that ore pile dust emissions will 'be 1%of those
from an equivalent area of fine-grained tailings.the annual average ore pile dusting rate is
estimated to be about 1.8 x 10-7 g/m2-sec.For a surface area -of 6 acres (2.4 ha).accounting
for side areas and surface roughness.the annual ore,pile dust release is estimated to be 162.
kg.At a gross ore concentration of 423 pCi/g and a fine concentration of 2.5 times that figure.
the annual uranium-238 release from this source would be about 1.7 x 10-4 Ci/yr.The release of
each particulate daughter in secular equilibrium would also be 1.7 x 10-4 Ci/yr.
3-10
The applicant 'intends to moisten pile surfaces after ore is added or removed and this will act
to reduce these releases~As the release estimates presented here are basically proportional to
the area of the ore storage piles,they would not be significantly affected by changes in the
volume of stored material as long as it is distributed over the same surface area.
Radon-222 will be produced in the pile from decay of radium-226.Most of the radon decays in
place with only a small fraction of the radon escaping the piles via diffusion.The staff
estimates the annual radon release for the maximum stockpile case to be approximately 240
Ci/year (see Appendix F).As mill operations progress and the size of the pile decreases to an
equilibrium value under 9.1 x 104 MT,the radon release from this smaller pile will depend on
pile geometry.The radon flux from the pile surface is virtually independent of thickness for
thicknesses greater than J m (10 ft).Therefore,if the same area [2.4 ha (6 acres)]is main-
tained for the equilibrium pile,the annual radon release would be the same as for the maximum
stockpile,that is,240 Ci/year (Appendix F).
Dust control measures such as moistening the surface of the stockpiled ore will also reduce
radon releases because the moisture will decrease the diffusion coefficient.This effect is
expected to be small.
3.2.4.4 Secondary crushing and grinding
The applicant proposes to use a semi autogenous mill to perform secondary crushing and grinding
of the ore.The semiautogenous mill will also function as a primary crusher for ores received
directly from mines (and not through ore buying stations).This process uses larger pieces of
ore to crush and grind smaller pieces;thus the ore essentially grinds itself.Steel balls may
be added as necessary to aid in grinding.
Because 'the semi autogenous mill is a wet process,particulate releases will be smail.Assuming
a release fraction of 1 x 10-4%,a gross ore concentration of 423 pCi/g,a fine concentration
2.5 times higher,and a processing rate of 1800 MT/day,the annual release of uranium-238 and
each daughter in secular equilibrium from secondary crushing and grinding is estimated to be 6.5
x 10-4 Ci.Based on a release fraction of 20%the annual release of radon-222 gas from thissourceisestimatedtobe52Ci.
3.2.4.5 Leaching and extraction
Leaching and extraction are wet processes and should not make any significant contribution to
the release of particulates.Because the residence time of ore in the leaching circuit will be
short (12 to 24 hr),radon-222 will not build up to concentrations high enough to give a signifi-
cant gaseous release.
3.2.4.6 Yellow cake drying and packaging
Normally,the uranium concentrate (precipitated ammonium diuranate)will be dried at 650°C.
The product (yellow cake)will be about 90%U30a and will contain about 94%of the uranium in
the ore.In addition.yellow cake will contain about 5%of the thorium-230 and 0.2%of the
radium-226 and daughters originally in the ore.The uranium product dryer and product crusher
will be isolated from other mill areas.Emissions will be controlled by wet fan scrubbers
operating at an equivalent venturi scrubber pressure of 0.5 m (20 in.)of water with an
efficiency of about 99%.The solution and particulates collected from the scrubbers will be
recycled to the No.1 yellow cake thickener in the mill (ER,p.3-19).Data presented in
Table 9.13 of Reference 3 indicate that about 1.2%of the annual yellow cake production may be
expected to reach-the wet fan scrubbers.At a gross ore grade of 0.15%U30a and a recovery rate
of 94%,the annual production of pure yellow cake (U30a)would be about 863 Mr.With a
scrubbing efficiency of 99%.the annual yellow cake release would be about 115 kg of which
about 104 kg would be U30a.The uranium-238 release rate is then calculated to be about
0.029 Ci/~r.Releases of other isotopes would be abou~1.6 x 10-3 Ci/yr of thorium-230 and
6.2 x 10-Ci/year each of radium-226 and lead-210.Releases of radon gas from this source
are negligible.
ct
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3-11
3.2.4.7 Tailings retention area
The tailings discharged from the counter-current decantation unit of the mill is a slurry
consisting of 897 kg (1977 lb)of solids and 0.9 m3 (237 gal)of liquid per ton of dry ore fed
to the mill.The tailings liquid contains residual acid from the leaching step and dissolved
solids placed in solution by the leaching and solvent extraction steps.The estimated com-
position of the waste solution is given in Table.3.1.
Both the liquid and solid portions of the tailings will be a source of low-level radiation due
to the uranium and daughter products left in the wastes.Approximately 6%of the original
uranium,95%of the thorium,and 99.8%of the radium remain with the tailings.The radio-
active components of the waste show generally low solubility and remain mostly in the solids.
The applicant conducted assays of synthetic tailings generated under conditions expected to be
found in the mill and measured the thorium-230 and radium-226 contents at 1.5 x 102 pCi and
3.7 x 102 pCi per gram of solids (ER,p.3-12).The actual concentrations found in the mill
tailings will depend on the actual grade of the ore fed to the mill.The soluble radioisotope
concentrations are listed in Table 3.1.
Because of the adverse radiological and chemical nature of uranium mill tailings,permanent
environmental isolation is required.The tail ings management plan should prevent excessive
release of solids by wind erosion and of liquids by seepage,leakage,or overflow during
operation of the mill.Following the cessation of milling operations,the tailings management
plan should also provide for adequate stabilization of the tailings against long-term erosion
and minimize the leaching of radioactive solids,the diffusion of radon-222 £as,and the
I
I
Tabla 3.1.Com~1ionof liquid in....nt toili..
•Iurry bMod on lobcwoUlrytOtt _k:ing
1
I
6.5
be
lifi-
Pet:ameter
Compooi1ion (Wli....1
v
U
Na
NH3
CI
504
Cu
Co
Mg
AI
Mn
Zn
Mo
Organics
pH
As
ea
Cd
Cr
PI>
Hg
S-
Ag
F
Si
Gross .Iphl.missions
Gross baUomissions
Th·230
R.226
Pb-210
Amount
0.24
0.0025
4.90
0.065
3.05
82.2
1.62
0.48
4.06
4.26
4.58
O.O!!
0.007
0.2"
1.8-2.0
0.052
0.0003
0.0017
0.0060
0.001
0.000001
0.00056
0.00006
0.0014
0.30
2.5 X 10"
2.3 X 101
1.3 X 10"
2.3 X 10'
2.8 X 10'
i,
L
°Meauradin gallon._1000gal.
Source:ER,p.3-12,Energy Fuels Nuclear,Inc.,
"Respanses to Comments on White Me..Project OES:'
Mar.6,1979.
I,
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I
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I
3-12
direct gamma radiation dose from the tailings.The tailings management plan proposed by the
applicant is discussed in the remainder of this section.The merits of the proposed impound-
ment and alternative methods are discussed in Sect.10.3.
The applicant proposes to build a six-cell impoundment system immediately to the west and south
of the proposed mill (Fig."3.4).The design storage volume of this system is 15 years.The
impoundment would be constructed in a swale,a shallow natural basin.A cell would be con-
structed by excavating the bottom of the swale and placing an embankment across the swale to
form the downstream side of the cell.
Each retention embankment will have a final embankment elevation matching the level of the
adjacent natural ground that creates the ridges along the edges of the swale.Therefore,the
embankments will only be as high as the undisturbed ground adjacent to the tailings cell.The
maximum embankment heights will vary from 7.6 to 13.0 m (25 to 42 ft),depending upon the
individual cell.
Each tailings cell will be filled to a level 1.5 m (5 ft)below the top of the embankment and
the adjacent ground and will be covered with a sufficient amount of cover to reduce the radon
emanation to twice background.This cover will create a slight rise where the swale formerly,
existed to gently drain waters away from the reclaimed tailings area while minimizing erosion
of the cover material.
Seepage will be controlled in the first three cells [evaporation cells 1 -initial (1-1)and
1 -enlargement (l-E)and tailings cell 2J by state-of-the-art synthetic liners placed over
and overla,in by layers of packed silt-sand materials available onsite (see Sect.10.3.2 for
description).No seepage problems with .this liner system are anticipated.The applicant
proposes to line the remaining cells with a 2-ft layer of compacted clay (permeability of about
3 x 10-8 cm/sec)to control seepage.Cells 1-1 and l-E will be used only as evaporation ponds.
As the tailings slurry in cells 2 through 5 drains,excess liquid will be pumped to these ponds
for evaporation.Cell 1-1,cell 2,and the cell 2 "safety dike"will compose the first stage
of construction (see flg.3.6.'.
The embankments which dam tne cells will be 'constructed of compacted soil available on the
site.The embankments would vary in height from a meter or more near the ridges of the
swale to as much 13 m (42 ft)for dikes at the lowest point in the swale.All dikes would
be 6 m (20 ft)thick at the crest (allowing for an access road on the dike)and would have
slopes no steeper than 3:1 (horizontal to vertical;Fig.3.7).The final exterior slope of
the last embankment on the perimeter of the impoundment will have a slope of 6:1 and will be
constructed of excavated rock (Fig.-3.8).Because the dikes will not saturate during the brief
period a given cell is in operation,engineered embankments are not utilized.Geotechnical
studies performed for the applicant indicate that the proposed slopes would withstand an
earthquake with a magnitude of VI on the Modified Mercalli Scale.
The proposed tailings system features simultaneous construction,operation,closure,and
reclamation activities.The first two cells (cell 1-1 and cell 2)and the cell 2 "safety
dike"(which will ultimately be part of the cell 3 embankment)would be constructed before
commencement of mill operation (Fig.3.6),with tail ings being initially deposited in the
second cell and the liquids decanted and pumped back to the first cell (cell 1-1)for
evaporation.The "safety dike"of the second cell would form a downstream catchment area
for any release of tailings material in the event of failure of cell 1-1 or cell 2 embankments.
(Note that this failure is considered highly unlikely as the cell 2 embankment will be
designed and constructed to meet Regulatory Guide 3.11.)During the filling of cell 2,
ce 11 3 woul d be excavated and 1ined,and the "safety di ken for cell 3 woul d be constructed.
After cell 2 is filled to its final grade,the tailings disposal pipeline would be moved
to cell 3.While cell 3 is being filled,reclamation of cell 2 would commence after the tail-
ings had dried,and excavation of cell 4 would begin.Except for a small channel,which
would be maintained through the cover of the first cell (and each subsequent cell)for
placement of the tailings slurry pipeline and tailings liquids return line (to evaporation
ponds),the cells will be completely reclaimed.The slurry discharge pipe will also be
contained in a second pipe (emergency containment pipe)where it passes through embankment
sections to prevent embankment erosion in the event of slurry pipe failure.This pattern of
operation would continue until the last cell is constructed.As with previous tailings cells,
closure and reclamation of the last cell (cell 5)would be completed as soon as the tailings
surface is sufficiently dry for movement of heavy equipment over the pile.Cells 1-1 and
l-E will be allowed to dry,construction materials from cell l-E will be placed in cell 1-1,
and cells 1-1 and l-E areas will be reclaimed.
',:<~'!;;;.::.
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Fig.3.6.Initial construction phase--detailed plan.Source:Energy Fuels Nuclear,Inc.,"Transmittal of Conceptual Review
Construction Drawing Set and Synopsis,Tailings Management System,White Mesa Uranium Project,Blanding,Utah,"~pr.2,1979.
...'---------
3-14
ES·462'
Fig.3.7.Typical dike section.Source:Energy Fuels Nuclear,Inc.,Source Material
License Application,White Mesa Uranium Mill,Blanding,Utah,Energy Fuels Nuclear,Inc.,
Denver,Sept.26,1978,Appendix AA.
ES·4626
GROUND
2'THICK CELL LINER
Fig.3.8.Final dike section.Source:Energy Fuels Nuclear,Inc.,Source Material
License Application,White Mesa Uranium Mill,Blanding,Utah,Energy Fuels Nuclear,Inc.,
Denver,Sept.26,1978,Appendix AA.
The staff has examined the water balance for the system and concluded that the 40 ha (98 acres)
of available free water surface (cells 1-1 and l-E;Fig.3.4)plus evaporation from the slimes
area and evaporation from the moist sand fraction in the tailings cells will enable theapplicanttodisposeofexcesswater.If difficulties are encountered,the applicant can
recycle some of the ponded water for further mill use.
Effluents from the proposed impoundment will consist of wind-blown particulates,and radon-222.
During tailings cell fill operations,wind erosion of the tailings will be minimized by keeping
the entire tailings surface moist by regularly shifting the location of the slurry discharge
spigot.However,as the final layer of sands is deposited in a cell,the tailings discharge
line will .be moved toward the downstream dike,allowing the upper end of the cell to dry out.
Additional drying will be·necessary to allow operation of heavy equipment during reclamation of
the cell.The staff will require the use of crusting agents,water spray,or similar means to
minimize the erosion of the tailings by wind.If no successful mitigating measures were taken
(conservative calculatiQn),the annual average dry tailings pile dusting rate,on the basis of
data presented in Appendix D,would be about 1.8 x 10-5 g/m2-sec which is equivalent to
about 2.2 MT/acre-yr.Corresponding estimated radioactivity release rates are 1.4 x 10-4
Ci/acre-yr for U-238,2.2 x 10-3 Ci/acre-yr for Th-230,and 2.3 x 10-3 Ci/acre-yr for Ra-226
and Pb-210 (each).
Due to uncertainties concerning the period of time necessary for drying prior to cell reclama-
tion,the staff has Conservatively assumed (for purposes of radiological impact analysis)that
each cell would have an area of 40 ha (100 acres)and that there could be 2 cells drying out
while a third was being filled.If the cell being filled is 50%beach,there could be a
total of approximately 100 ha (250 acres)of tailings area available for dusting.The staff
has assumed that control measures to be implemented by the applicant will reduce dust emissions
from nonoperational cells by 80%.Under these conditions total annual radioactive particulate'
releases are estimated to be 0.013 Ci of U-238,0.20 Ci of Th-230,and 0.21 Ci of Ra-226 and
Pb-210 (each).
3-15
don-222 gas is expected to be released in significant quantities from dry tailings areas.
Raleases from saturated tailings,or tailings that are under water,are severely limited due to
Re low diffusivity of radon gas in water.The staff assumes that two 40-ha (lOO-acre)cells
the be drying prior to reclamation while a third cell .is being !illed.Radon :eleases fr?m the~a~est cell (8%moisture content),the other cell drylng out pnor to reclamatl0n (15%mOl sturer~tent).and the beach area of the filling cell (50%beach,37%moisture content)are estimated~~be 5550 Ci/yr,2480 Ci/yr,and 30 Ci/yr,respectively (see Appendix F for details).The
otal annual radon-222 release is estimated to be 8060 Ci/yr.Radon releases from underwater~aiJings materials or reclaimed tailings cells are insignificant in comparison and have been
ignored.
3.2.4.8 Uranium concentrate transportation
uranium concentrate will be transported in 55-gal drums by truck because no rail .trans-
Thetation is available at the site.Uranium shipment,about 2000 drums each year,wl11 result~oran external radiation doses to an individual of 2 mR/hr at any edge of the truckbed.Under
ln mal operating conditions,no significant release of radioactive particulates would occur.~~:ever,release could occur during transportation accidents as discussed in Sect.5.3.1.
3.2.4.9 Source terms
Sections 3.2.4.1 through 3.2.4.8 describe the nature and quantity of radioactive effluents
conservatively estimated to be generated by milling operations at the White Mesa Uranium Project.
Estimates employed in the above discussions were derived from project design parameters and data
from similar mills.6-37 The estimates reflect operation of the fully developed mill and
tailings area.Initial releases from the tailings area will be lower than the estimated values
for several years after startup.Therefore,the use of full-scale operation as the basis for
estimates adds some additional conservatism to the analysis.Table 3.2 gives the design param-
eters used in estimates of radioactive release rates.The source terms for the milling opera-
tions and areas are presented in Table 3.3.
3.3 IilTERIM STABILIZATION,RECLAf·1ATION AND DEC0I1fUSSIONING
3.3.1 Interim stabilization of the tailings area
Interim stabiZization is defined as measures to prevent the dispersion of tailings particles by
wind and water outside the immediate tailings retention area.Such measures will be required
at the White Mesa mill during the 15 years of operation (for in-use ~nd drying cells)and the
years required to dry the final tailings cell and evaporation cells after operation (see
Sects.3.2.4.7 and 10.3.2,Alternative 1)prior to reclamation.
As a license condition,the staff will require that the applicant implement an interim stabiliza-
tion program which minimizes dispersal (via airborne particu1atesJ of blowing tailings to the
maximum extent reaso~ab1y achievable.The program shall include the use of written operatlng
procedures that speclfy the use of specific control methods for all conditions.The effective-
ness of this control measure shall be checked at least weekly by means of a documented site
inspection.
3.3.2 Reclamation of the mill tailings area
In accordance with the Utah MineJ Land Reclamation Act of 1975 and the requirements of the NRC,
the applicant has prepared a stabilization plan for the tailings area.The goal of the appli-
cant's plan is to meet the performance objectives for tailings management (Sect.10.3.1).
The proposed reclamation program calls for a 0.6-m (2.0-ft)layer of compacted clay,a 1.2-m
(4-ft)layer of silt-sand overburden material,and a 1.8-m (6-ft)layer of rock overburden
material over the tailings area.The proposed cover is considered sufficient to reduce
The cover would also be graded and sloped at a grade of 2%or less to prevent impoundment of
surface runoff.Slopes on the perimeter of the cover would be no steeper than 6:1 (horizontal
to vertical)and would be constructed of riprap.A layer of topsoil 0.15 m (0.5 ft)thick
will be placed over the cover.The area would be fertilized and revegetated with a suitable
mixture of grasses,forbs,and shrubs.Grasses and shrubs whose root structures would penetrate
the cover will not be planted.The approximate volumes of material required would be 7.38 x
10 5 m3 (9.65 x 105 yd3)of clay,1.76 x 10 6 m3 (2.30 x 106 yd 3)of overburden,2.2 x 106 m3
,,
iL
3-16
(2.89 X 106 yd 3 )of rock,and 2.2 x lOS m3 (2.88 yd 3)of topsoil.Staged constructed,operation,and reclamation will minimize stockpiling and handling requirements.
The reclamation plans have been developed from recommendations from the U.S.Department of
Agriculture (USDA)Soil Conservation Service and Forest Service (ER,Sect.9.4).These plans
are also in accordance with the regulations of the State of Utah Division of Oil,Gas.andtHning.38,39
Value"
1800
4 X 10-7
0.1
2.5
1800
1 X 10-6
0.2
2.5
2.4 (6)
3.0 (7.3)
1.8 X 10-7
2.5
0.94
0.05
0.002
863
959
0.012
0.01
0,06
0.95
0.998
40(100)
100 (250)
1.8 X10-5
2.5
Parameter
Table 3.2.Principal parameter values used in the
radiological assessment of the White Mesa Uranium Project
General data
Average are grade,%U3as 0.15
Ore-concentratlon,pCi of U·238 and daughters per gram 423
are processing rate.MT/day 1800
Days of operation per year 340
Blanding are crusher
are processing rate.MT/day
Fraction released as particulates
Fraction of radon released
Dust:oreconcentration ratio
SemiautogenOlls grinder
are processing rate,MT/day
Fraction released as particulates
Fraction of radon released
Dust:ore concentration ratio
Ore storage pilesb
Yellow cakedrying and packaging
Fraction Uto yellow cake
Fraction Th to yellow cake
Fraction Ra and Pb to yellow cake
Annual U30S production,MT
Annual yellow cake production,MT
Fraction of yellowcake to scrubber
Scrubber release fraction
Tailings impoundmentsystemb•C
Fraction U to tailings
Fraction Th to tailings
Fraction Ra and Pb to tailings
Area,ha (acres)per cell
Actual area,ha (acres)
Effective dustingarea,ha (acres)
Annual average dust loss rate,g/m2•sec
Dust:ore concentration ratio
Area subject to dusting,ha (acres)
Annual average dust loss rate,g/m2 •sec
Dust:tails concentration ratio
•Parameter values presented here are those selected by the staff for use in
its radiological impact assessment of the White Mesa Uranium Project.These
values,which include emissions from the Blanding are buying station,
represent conservative selections from ranges of potential values in instances
where insufficient data has been available to be more specific.
b Appendix F provides additional information regarding thecalculation of
radon releases.
cEffective dusting area is 36 ha (90 acres);20%of two 4O-ha (loo-acre)
cells drying prior to reclamation and 50%of a 4()'ha (10().acre)operational
cell.
il _
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3-17
Table 3.3.Estimated annual releases of radioactive matllrials
resulting from the White Mesa Uranium Project
Annual.releases (Ci)"Source U-238 Th·230 Ra·226 Rn·222
Blanding ore crusher 2.6 X 10-4 2.6 X 10-4 2.6 X 10-4 2.6 X 10
Ore storage piles 1.7 X 10-4 1.7Xl0-4 1.7 X 10-4 2.4 X 102
Secondary crusher 6.5 X 10-4 6.5 X 10-4 6.5 X 10-4 -5.2 X 10
Yellow cake scrubber 2.9 X 10-2 1.6 X 10-3 6.2 X 10-5 0.0
Tailings system 1.3 X 10-2 2.0 X 10-1 2.1 X 10-1 8.1 X lei!
"Releases of other isotopes in the U-238 decay chain are included in the radiological
impact analysis.These releases are assumed to be identical to those presented here for
par.ent isotopes.For instance.the release rate of U-234 is taken to be equal to that for
U·238.
The project site will be revegetated to return it to the original uses of grazing and wildlife
habitation.The soils are relatively uniform and adequate for these reclamation procedures
(ER Sect.9.1.1).The reclamation schedule for the tailings impoundment site is depicted in
Fig:3.9.The tailings ce11s will be reclaimed sequentially as each cell is filled,beginning
after about the fourth year of operation and every four years thereafter until termination of
project operations.A clay cap (0.6 m (2 ft)],and onsite clayey-silt soil (1.2 m (4 ft)],and
rock overburden (1.8 m (6 ft)],will be placed over the dried tailings.Except for the rock-
lined drainage ditches,rock-filled slopes along the edges of the soil-covered tailings cells,
and the rock-filled southernmost dike of cellS,about 0.15 m (0.5 ft)of topsoil will be placed
on the surface of all disturbed areas and seeded with a mixture of grasses,forbs,and shrubs
(Table 3.4).Any excess rock will be disposed of at the 14.6-ha (36-acre)borrow area prior to
its recl ama tion.
The applicant's selection of seeds is representative of the vegetation on the site prior to
construction and will suffice in reclaiming the site to the preconstruction land condition.The
stlged reclamation plan will permit optimizing the seed mixture for a maintenance-free vegetative
cover which will maximize soil stability.In the long term native vegetation is expected to
return to the area.The seed should be obtained from those areas that have soil characteristics
anj climate similar to the project site.4o
The mixture of seed will be planted in November with a rangeland drill.Because soil nitrogen
is low (ER,Sect.2.10.1),it may be necessary to apply an appropriate fertilizer prior to
seeding.The applicant claims that the topsoil will contain sufficient debris so that mulching
will not be required.However,by the time reclamation begins,much of the debris will be
decomposed.Mulches increase infiltration and reduce erosion and ~vaporation,thereby encour-
aging seed germination and plant growth.Therefore,it may be necessary to crimp mulch into the
soil of all disturbed areas prior to seeding.Revegetated areas will be monitored (Sect.6.2.2).
The staff notes that the information developed in the Generic Environmental Jmpact Statement on
Uranium Milling being prepared by NRC could be used to modify or change the procedures proposed
herein.The generic statement will contain the results of ongoing research to assess the envi-
ronmental impacts of uranium mill tailings ponds and piles,and will'suggest means for mitigating
any adverse impacts.The current NRC licensing action regarding the White Mesa mill will be
subject to revisions based on the conclusions of the Final Generic Environmental Impact State-
ment on Uranium Milling Operations and any relat~d rule making.
The applicant will be required to make financial surety arrangements to cover the costs of
reclaiming the tailings disposal area and of decommissioning the mill.
"
Fig.3.9.System schedule.Source:Energy Fuels Nuclear,Inc.,"Transmittal of Conceptual Review Construction Drawing Set
and Synopsis,Tailings Management System,White Mesa Uranium Project,Blanding,Utah,"Apr.2,1979.
WI
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3-19
Table 3.4.Species._ding rates.and planting depths of tentative
seed mixture to be used in reclamation of the project site
Species Seeding rate Depth
kg/ha Iblacre cm in.
Grasses
"Luna"pubescent wheatgrass 6.16 5.5 0-0.64 0-0.25
Fairway (crested)wheatgrass 1.68 1.5 0-0.64 0-0.25
Forbs
Yellow sweetclover 1.12 1.0 1.27-2.54 0.5-1.0
Palmer penstemon 0.112 0.1 0-0.64 0-0.25
Alfalfa 1.12 1.0 1.27-2.54 0.5-1.0
Shrubs
Fourwing saltbush 0.56 0.5 0.64-1.27 0.5-1,0
Common winterfat 0.56 0.5 0.64-1.27 0.5-1.0
Big sagebrush 0.112 0.1 0.64-1.27 0.5-1.0
Total 11.424 10.2
Source:Energy Fuels Nuclear.Inc.•Source Materials License Application,White
Mesa Uranium Mill,Blanding,Utah,Denver.SePt.26.1978.
Prior to the termination of the license the NRC will require'that the reclaimed tailings
impoundment area be deeded to the Federal government.
In addition.although revegetation is an effective erosion control method under normal climatic
and edaphic conditions.it is not known whether continued growth of vegetation can be assured
at this site without irrigation or other supportive measures.Therefore.to assure that a
stable cover will be established.the staff recommends that riprap (or gravel cover)over the
entire basin be planned as an optional erosion control method.The final choice ~etween gravel
and vegetation can be made based on some years of 'testing and research currently 1n progress.
and on the performance of various reclamation schemes which are completed in the interim.
3.3.3 Decommissioning
Near the end of the useful life of this project and prior to the termination of the license the
NRC will require a detailed decommissioning plan for the White Mesa mill.which will contain
plans for decontamination.dismantling.and removing or burying all buildings.machinery.
process vessels.and other structures and cleanup,regrading and revegetation of the site.This
detailed plan will include data from radiation surveys taken at the site and plans for anymitigatingmeasuresthatmayberequiredasaresultofthesesurveysandNRCinspections.
Before release of the premises or removal of the buildings and foundations.the licensee must
demonstrate that levels of radioactive contamination are within limits prescribed by NRC and the
then-current regulations.Depending on the circumstances.the liRe may require that the appli-
cant submit an Environmental Report on decommissioning operations prior to termination of the
license.
3-20
REFERENCES FOR SECTION 3
1.Engery Fuels Nuclear,Inc.,Source Material License Application,White Mesa Uranium Mili,
Blanding,Utah,Energy Fuels Nuclear,Inc.,Denver,Sept.26,1978.
2.National Air Pollution Control Administration,Compilation of Air Pollutant Emission
Factors,Publication No.AP-42,U.S~Environmental Protection Agency,Washington,D.C.,
1968.
3.R.C.Dahlman,G.S.Hill,and J.P.Witherspoon,Correlation of Radioactive Waste Treat-
ment Costs and the Envirorunental Impact of Waste EffZuents in the Nuclear Fuel CycZe,
vol..1,ORNL/TM-4903,Oak Ridge National Laboratory,Oak Ridge.Tenn.,July 1975,
Table 9.12.
4.Ref.3,p.151.
5.U.S.Nuclear Regulatory Corrmission,Final Envirorunental Statement ReZated to Operation of
Bear Creek Project,Docket No.40-8452,June 1977.
6.K.J.Schiager,"Analysis of Radiation Exposures on or Near Uranium Mill Tailings Piles,"
Radiol.Data Rep.12:17-28 (1971).
7.U.S.Environmental Protection Agency,Envirorunental Analysis of the Uranium Fuel cycle,
Report EPA-520/9-73-003,Washington,D.C.,1973.
8.U.S.Atomic Energy Corrmission,Envirorunental Survey of the Uranium Fuel cycle,Report
WASH-1248,April 1974.
9.U.S.Energy Research and Development Administration,U.S.NUclear P~er Export Activities,
Report ERDA-1542,April 1974.
10.R..C.Merritt,"The Extractive Metallurgy of Uranium,"Colo.Sch.of Mines Res.Inst.,
Golden,Colo.,1971.
11.D.A.Nussbaumer and D.F.Hannon,"The United States AtQmic Energy Corrmission's Regulatory
Control Prograllllle for Uranium Milling,"reprint from Radiological HeaZth and Safety in
Mining of Nuclear Materials,vol.II,International Atomic Energy Agency,Vienna,1964,
pp.519-533.
12.E.C.Tsivoglow and R.L.O'Connell,Waste Guids for the Uranium MilZing Industry,U.S.
Department of Health,Education,and Welfare,Technical Report W62-12,Robert A.Taft
Sanitary Engineering Center,Cincinnati.Ohio,1962,78 pp.
13.R.G.Beverly,"Unique Disposal Methods are Required for Uranium Mill Waste."Min.Eng.20:52-56 (1968)..
14.Winchester Laboratory,Topical.Report,Janua:I'1J 1960 SurrrnaPy Report on I;The Control of
Radium and Thorium in the Uranium MiZZing Industry.II.Radium-226 Analysis Principles,
Interference and Practice.III.Current Winchester Laborator-y Projects,U.S.Atomic Energy
Corrmission Report WIN-1l2.National Lead Col.,Inc••Feb.1.1960.97 pp.
15.U.S.Department of Health.Education.and Welfare.Process and Waste Characteristics at
Selected Uranium Mills,Public Health Service.Technical Report W62-17.Robert A.Taft
Sanitary Engineering Center.Cincinnati.Ohio,1962.94 pp..
16.K.E.Tame et al..Disposal-of Liquid Waste in the Durango-Type Uranium Mil-Zing PZot.1sheet,
U.S.Bureau of Mines.Report of Investigation 5874.1961,12 pp.
17.K.E.Tame et al..Disposal-of Radioactive Waste in the Vitro-Type Uranium MiZZing F"Low-
sheet,U.S.Bureau of Mines.Report of Investigation 6011,1962.10 pp.
18.
19.
20.
3-21
K.E.Tame et al.,Radi~aooive was~e Jisposal in the Shiprook-Tyve Urani~~MilZin~FZow-
sheet,U.S.Bureau of M1nes,Report of Investigation 6045,1962,'9 pp.~
K.E.Tame and J.B.Rosenbaum,Disposal of Liquid Waste in the Resin-in-Pump ~~pe Uranium
MiZZing Fl~wsheet,U.S.Bureau of Mines,Report of Investi9ation 6114,1962:li~pp..
K.E.Tam:,R~ioaotivity in Alkaline Leaoh Milling Prooess,U.S.Bureau of Mines,ReportofInvest1gat10n6346,1964,8 pp.
21.
24.
"gy
t.
R.G.Beverly,"Radium and Thorium Behavior in Uranium Mill ing Circuits -Statement of Air
and,Water ~oncentration ~imits ~resc,:"ib:d in Part 20,"presented at the Symposium on
Rad10-chemlcal Problems 1n Uran1um Mlll1ng,Grand Junction,Colorado,Oct.5 and 6,1960.
22.W.B.Harris et al.,Envi~onmental Haz~ds.Associatedwith the Milling of Uranium Ore-A
summary Report.U.S.Atom1C Energy Comm1ss10n Report HASl-40 (REV),New York Operations
Office,Health and Safety laboratory,Revised Nov.14,1958.
23.American Standard Radiation Protection in Uraniwn Mines and Mins (Concentrators).
sponsored by Atomic Industrial Forum,Inc.,and National Safety Council,American Standards
Association Inc.,New York,approved Oct.3,1960.
A.Whitman and E.S.Porter,Chemical Stream Pollution from Uranil~Mills,U.S.Atomic
Energy Commission Report WIN-99,National lead Co.,Inc.,June 13,1958,43 pp.
25.R.D.lynn and Z.E.Arlin,"Deep Well Construction for the Disposal of Uranium Mill
Tailing l4ater by the Anaconda Co.at Grants,New Mexico,"Trans.Min.AIME 223:230-237,
1962.
26.G.R.Yourt,"Radiological Control of Uranium Mine and Mill Wastes,"in Ontario IndustriaZ
Waste conference Preceedings.No.13,pp.107-120,1966.
27.D.F.little et al.,"Two Years'Milling at Bicroft Uranium Mines ltd.,"Trans.Min•.4.n1E
220:458-468,1961.
28.W.L.lennemann and F.E.McGinley,"Advances in Uranium Ore Processing,"Min.Congr.J.
45(7):59-63,1959.
29.W.D.Arnold and D.J.Crouse,"Radium Removal from Uranium Mill Effluents with Inorganic
Ion Exchangers,"Ind.Eng.Chem.Process Des.Dev.4(3):333-337,1965.
30.U.S.Department of Health,Education,and Welfare,"Disposition and Control of Uranium
Mill Tailings Piles in the Colorado River Basin,"Federal Water Pollution Control Adminis-
tration,Region VIII,Denver,Colorado River Basin Water Quality Control Project,March
1966,36 pp.
31.R.H.Kennedy,"Comparison of Foreign and Domestic Uranium Ore Milling Practices,"
presented at the Tenth Annual Minerals Symposium,sponsored by the Colorado Plateau
Section AIME,Grand Junction,Colorado,May 8,1965.
32."Radiation Regulation No.2,"Regulation of the Colorado'State Department of Public
Health Requiring Stabilization of Uranium and Thorium Mill Tailing Piles.
33.Erosion Control Uraniwn Mill Tailing Project.Monticello.Utah.U.S.Atomi~Energy
Commission Report RHO-3005,Grand Junction Office,Dec.20,1963,26 pp.
34.Supplement to the Report of the MonticeZZo MiZZ Tailing Erosion Control Project.Monti-
cello.Utah.U.S.Atomic Energy Commission Report Supplement to RHO-3005,r.rand Junction
Office,Apr.20,1966,8 pp.
35.H.J.Paas,Jr.,Radiological Appraisal of the Monticello Project San Juan County.Monti-
cello,Utah.U.S.Atomic Energy Commission Report 100 12049,Idaho Operations Office,
February 1966,20 pp.
36.R.Havens and K.C.Dean,Chemical Stabilization of the Uraniwn Tailings at Tuba City.
APiapna.U.S.Bureau of Mines,Report of Investigation 7288,1969,12 pp.
37."EnVironmental Survey of Uranium Hill Tailings Pile,Tuba City,Arizona,"RadioZ.HeaZth
Data Rep.9(11):475-487,1968.
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38.Dames and Moore,"Response to Corrrnents Telecopied from the NRC to Energy Fuels Nuclear,
25 September 1978,"Denver,Oct.4,1978.
39.State of Utah,Division at OiZ,cas,and Mining,Changes and Adoptions to the General
Rules and Regulations,"adopted by the Board of Oil,Gas,and Mininq on Mar.22,1978,
effective June 1,1978.
40.A.P.Plummer,D.R.Christensen,and S.B.Monsen,Reotoring Big-Game Range in Utah,
Utah Division of Fish and Game,Publication.No.68-3,Salt Lake City,1968.
4.ENVIRONMENTAL IMPACTS
4.1 AIR QUALITY
4.1.1 Construction
The major nonradiologica1 air pollutants associated with construction of the mill facility will
be gaseous emissions from internal combustion engines and fugitive dust generated from moving
vehicles and wind erosion.In general,these emissions will not produce significant impacts to
air quality.
The maximum expected emission rate for any of the major pollutants (NOz'SCz,CO,and hydro-
carbons)from each piece of construction equipment is less than 0.2 g/sec.1 Using conservative
x/Q (sec/m3 )values (Appendix H,Table H.1),the staff calculated the annual atmospheric con-
centration of each ~011utant per vehicle to be less than 1 ~g/m3 at the property boundary in the
direction of the prevailing wind.
Fugitive dust associated with construction of the facility will average about 0.4 to 0.7 MT/ha
(1 to 2 tons/acre)per month.z Based on a total of about 142 ha (344 acres)disturbed at any
one time (Sect~4.2.1),about 121 to 241 g/sec of particulates will be emitted.Annual average
atmospheric concentrations of particulates were calculated by the staff using the x/Q values(Appendix H,Table H.1)for the 16 compass directions at a distance of 2.4 km (1.5 miles).The
average of these 16 concentrations indicates that particulate loading due to construction will
range from 26 to 53 ~g/m3 (Table 4.1).These are conservative calculations because the x/Q val~es
assume a point source;the construction activities actually will be widespread,creating
many scattered,diffuse sources.Furthermore,the larger dust particles would deposit rapidly,
another condition not accounted for in the calculation.Although dust could cause occasional
localized degradation of air quality at the site,the duration will be only during the
construction phase.To minimize fugitive dust,the applicant will frequently water exposed
areas and heavily traveled areas,and all vehicles will be operated at a reduced speed.3
4.1.2'Operation
Air quality during operation of the facility could be affected by atmospheric releases princi-
pally from the building and processing boiler,yellow cake and vanadium dryers,tailings dis-
posal system,and ore stockpiles.The applicant's consultant's estimates of emissions from each
primary source and their release heights are listed in Table 4.2.The staff estimates (Sect.3)
are somewhat different,but the conclusions drawn (below)remain the same.In addition,
insignificant quantities will be released from other sources including the coal stockpiles,ore
transport systems,and acid leach system.Atmospheric dispersion coefficients (x/Q)for each
release height are listed in Appendix H,Tables H.l through H.4.Assuming all processes are
operating simultaneously,annual atmospheric concentrations of particulates,SOz'and NOx at
the property boundary in the direction of the prevailing wind were calculated by the staff to
be approximately 13.9,and 4 ~g/m3 respectively.These concentrations are well below appli-
cable Federal and State air quality standards (Table 4.1).For reasQns stated earlier,the
particulate concentrations are quite conservative.The applicant calculated the atmospheric
concentrations of the major pOllutants using the CRSTER program.a program used by the U.S.Environmental Protecti~n Agency.4 Calculations were for five distances:2,4,6,8,and 10 km
(3.2,6.4,9.7,12.9,and 16.1 miles).Concentrations were the largest at the 2-km (3.2-mile)
distance and are as follows:particulates,annual average =0.26 ~g/m3.24-hr average =
3.7 ~g/m3;SOz.annual average a 1.1 ~g/m3.24-hr average =15.4 ~g/m3.3-hr average =
66.6 ~g/m3;NOx'annual average =0.51 ~g/m3.
Although operation of the mill facility should not have any significant impact on air quality.
Utah's Air Conservation Regulations S require that air pollution control equipment and processes
be selected and operated to provide the highest efficiencies and the lowest discharge rates
that are reasonable and practical.While the degree of control is subject to approval by the
State Air Conservation Committee.the control must be a minimum of 85%.Utah regulations also
restrict the sulfur content of coal and oil.used as fuels,to no greater than 1.0 and 1.5%
respectively.
4-1
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4-2
Table 4.1.Federal and State of Utah air quality standards
Table4.2.Emission rates,sources,and release heights of
major air pollutants associated with operation
of the White Mesa mill
Averaging time"Primary standard Secondary standard
Annual 0.05 ppm 0.05 ppm
'(100 j.lg/mJ )(100 j.lgimJ )
Annual 0.03 ppm
(80j.lg/mJ I
24 hr 0.14 ppm
(365 j.lg/mJ I
3 hr 0.5 ppm
(1300j.lg/mJ I
Annual geometric 75j.lg/mJ 60 j.lg/mJ
mean
\260 j.lg/mJ 150 j.lg/mJ24hr
3 hr 0.24 ppmc 0.24 ppm
6to 9 AM (160 j.lg/mJ )(160j.lg/mJ )
1 hr 0.08 ppm 0.08 ppm
(160j.lg/mJ )(160 j.lg/mJ )
8 hr 9 ppm 9ppm
(10 mg/mJ )(10 mg/mJ )
1 hr 35 ppm 35 ppm
(40 mg/mJ )(40 mg/mJ )
Air pollutant Emission rate Release height
and source (g/see)(m)
Suspended particulate
Boiler 1.0 27.4
Yellow cakedryer 0.05 13.7
Vanadium dryer 0.06 13.7
Tailings 1.01 1.0
Ore stockpiles 1.08 3.0~.0
S02
Boiler 4.0 27.4
Yellow cake dryer 0.25 13.7
Vanadium dryer 0.25 13.7
NO"
Boiler 2.0 27.4
Yellow cake dryer 0.06 13.7
Vanadium dryer 0.06 13.7
Pollutant
Sources:Dames and Moore."Responses to Comments from the ,
U.S.Nuclear Regulatory Commission.June 7,1978.White Mesa
Uranium Project Environmental Report."Denver,June 28.1978:
Dames and Moore."Supplemental Report,Meteorology and Air
Quality.Environmental Report.White Mesa Uranium Project,San Juan
County,Utah.for Energy Fuels Nuclear,Inc....Denver,Sept.6.1978;
Dames and Moore."Responses to Comments Telecopied from NRC to
Energy Fuels Nuclear,25 September 1978."Denver.Oct.4.1978.
"All standards exceptannual average are not to be exceeded more than once a year.
b Nitrogen dioxide is the only one of the nitrogen oxides considered in the ambient standards.
cMaximum 3 hr concentration between 6 and 9 AM.
Source:ER,Table 2.7-19.
Nitrogen dioxideb
Sulfur diox Ide
Suspended particulates
Hydrocarbons (corrected
for methane)
Photochemical oxidants
Carbon monoxide
4-3
4.2.2 Historical and archeological resources
As discussed in Sect.2.5.2.1,a historical survey was conducted.Of the six historical sites
identified during that survey,five were considered to be eligible for inclusion in the National
Register of Historic Places (National Register).Pursuant to 36 CFR Part 63.3,a request on
March 28,1979,for determinations of eligibility for the historic sites was submitted and is
currently under review.Of the five sites considered eligible,only one ("Earthen Dam")will
be adversely affected by the mill project,and mitigation will be specified if the site is
in fact eligible.(See the proposal for a Memorandum of Agreement in Appendix E.)
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4.2.1 Land resources
4.2.1.1 Nonagricultural
The proposed White Mesa Uranium Project is not expected to alter the basic pattern of land
ownership in the area (Table 2.15).Area land uses will change,however,as a result of the
proposed mill.About 600 ha (1480 acres)are owned by Ener~y Fuels Nuclear,Inc.;roughly
195 ha (484 acres)will be directly used during operations (Sect.2.5.1)for milling,ore buying,
and tailings disposal.Increased residential and commercial land use is expected in neighboring
communities to serve mill-prOduced population growth (Sects.4.8.1 and 4.8.2).The volume of
traffic using the highways in this area is also expected to grow substantially (Sect.4.8.5),
and mineral extraction is expected to increase in the project area in response to the mill's
demand for uranium ore (Sect.4.8.1.2).
Regulations promulgated by the U.S.Environmental Protection Agency6 require any major source of
ir pollutants to comply with the Prevention of Significant Deterioration (PSD)-regulations.~he White Mesa Uranium Project is currently being evaluated by the appropriate regulatory authori-
ties to ascertain if the project is defined as a major source.If the project is deemed to be a
major source,then the applicant will be required to file for the appropriate PSD permit and to
comply with all regulations therein.Initial indications are that the atmospheric concentrations
of pollutants associated with mill operation will be well within the PSD allowable increments.
southeastern Utah,known for its scenic qualities (Sect.2.5.2.2),attracts many visitors.
Stack emissions (primarily steam)wi:1 be visible to the public traveling Highway 163 east of
the site.However,they.are ~ot ex~ect~d to be ~isible fr?m major ~ecreation~l ar~as in the
vicinity.The closest hlstorlca1 slte lnc1uded 1n the Nat10na1 Reglster of HlstorlC Places
(National Register)is located a~out 10 km (6 miles)north of the prpposed mill site
(Table 2.17).
4.2 LAND USE
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4.2.1.2 Agricultural
Construction and operation of the facility will disturb about 20 ha (50 acres)directly
(Table 4.3).In addition,the tailings will cover a total of about 135 ha (333 acres),and
39 ha (98 acres)will be used for stockpile and borrow areas.Because the tailings disposal
system will be constructed as six separate cells (two cells for evaporation and four for
tail ings disposal),with a full tail ings cell being reclaimed as a new cell is opened,a total
maximum surface area Gf about 89 ha (~22 acres)will be disturbed at anyone time by the
tailings system.Also,a maximum of about 15 ha (36 acres)of borrow area will be exposed
at any given time.Therefore,total land area disturbed at anyone time by construction
and operation of the mill facilities will be about 141 ha (343 acres).However,until all
operations have terminated,at least 195 ha (484 acres)will be unavailable for grazing.Basedr.•.•..~.i·on the capacity of the tailings cells,the mill has a potential to operate 15 years.The dura-t~tion of the impact will be somewhat longer than this depending on the time required for con-
~~~._-~~._-~~s-t-Y'ueHon,-t-he-+en~t-hof-timebetween-d isturbance-and-rec-lamation,and-the--len-gth-of-time it----
takes for a suitable vegetative cover to become established on each reclaimed area.Therefore,
a realistic estimate of the amount of time the land will be disturbed is about 20 years.
Upon termination of the mill operations,all remaining disturbed areas will be reclaimed to
ultimately restore the land to its original grazing use (Sect.3.3.l).Loss of nearly 1~5 ha
(484 acres)of grazing land each year the land is disturbed represents less than 0.1%of the
private rangeland in San Joan County (Table 2.16).With successful reclamation (Sect.3.3.2),
this land could be returned to its original grazing capacity..
4-4
4.3 WATER
4.3.1 Surface waters
3.2
4.6
3.8
3.5
15.1
Tailings capacity
(years)
Area to be
Area disturbed
ha acres
Mill"20 50
Evaporation cells I and E 40 98
Tailings cell 2 25 61
Tailings cell 3 25 63
Tailings cell 4 23 58
Tailings cell 5 21 53
Safety dike 1 3
Topsoil stockpiles 4 10
Overburden stockpile 6 16
Rock stockpile 15 36
Borrow area 15 36--Total 195 484
"Includes 6 ha /16 acres)occupied by an ore buyin9 station.
Source:Energy Fuels Nuclear.Inc.,"Transmittal of Conceptual
Review Construction Drawin9 Set and Synopsis,Tailings Management
System,White Mesa Uranium Project,Blanding,Utah,"Apr.2,1979.
The construction and operation of the uranium mill should have minimal impact on the surface
waters of the project site and vicinity.During construction of the mill,the ground surface
will be disturbed by grading.excavation.road access.spoil and topsoil storage,and other
construction-related activities.The soils of the project vicinity are normally subject to
erosion due to lack of consolidation and poor vegetative cover (Sects.2.8 and 2.9.1).During
periods of flow in local intermittent streams.this natural erosion is ref1ected.in values of
total suspended solids which reach levels of >1500/mg/1iter (Table 2.22).Storm runoff from
above the mill.ore storage piles,and ore buying station will be diverted to offsite
drainages.Runoff from the mill and facilities area will be impounded onsite in a sedimentation
pond.
Sediment carrying runoff that can enter local streams will originate primarily from the steep
sides of the temporary overburden stockpiles.Table 4.4 lists the effects of early con-
struction (mill facilities,two evaporation cells.and'the first two retention cells).The
net change in tons of s~diment transferred to local streams is about -2450 MT (-2700 tons).
or a reduction in total sediment transfer.
Table 4.3.Land disturbed bv construction and
operation of the White Mesa Uranium Project
As discussed in Sect.2.5.2.3,archeological surveys and testinq have been .conducted on the
site since the fall ·of 1977,and although additional field work will be required to determine
the significance of all identified archeological sites,the NRC,after consultation with the
Utah State Hist~ric Preservation Officer (SHPO),determined that this area of White Mesa contains
numerous sites which are likely to yield information important in the prehistory of the region.
The NRC accordingly requested a determination from the Secretary of the Interior that the area
on which the properties are located is eligible for inclusion in the National Register as an
Archeological District.The resulting determination was that the White Mesa Archeological
District is eligible for inclusion in the National Re~ister.It is anticipated that the NRC
will enter into a Memorandum of Agreement under 36 CFR 800,Procedures for the Protection of
Historic and Cultural Properties.The proposed plan for mitigatory action is outlined in the
proposal for a Memorandum of Agreement in Appendix E.
nsni:::'~_B
4-5
Table 4.4.Effects of initial construction S!llgeS
Yearly sediment
Area production to local Yearly net change Yearly changeLocationstreamshaacresMT/ha tons/acre MT tons
MT/ha tons/acre
Borrow area 15 36 0 0 -22 -10 -330 -360 n
1098 +490 245 I :Topsoil stockpile slopes 0.2 0.5 1120 500 220 LJ
Overburden stockpile slopes 0.4 1 1120 500 1098 [phone]
Topsoil central stockpile 3.6 9 0 0 -22 -10 -79 -90
Overburden central stockpile 6 15 0 0 -22 -10 -132 -150
Evaporation cells Iand E 40 98 0 0 -22 -10 -880 -980
Tailing cells 2 and 3 50 124 0 0 -22 -10 -1100 -1240
Mill site drainage 24 60 0 0 -22 -10 -528 -600
Net -2390 -2685
Source:Energy Fuels Nuclear.Inc.,"Transmittal of Conceptual Review Construction Drawing Set and Synopsis.Tailings
Management System.White Mesa Uranium Project,Blanding,Utah,"Apr.2.1979.
There will be no discharge of mill effluents to local surface waters.In addition,sanitary
wastes generated by mill operation will be retained in a sanitary drainage field (Sect.3.2.3.2)
and should not affect surface-water quality.
The construction and operation of the proposed uranium mill should not affect local surface
waters to any significant extent.
4.3.2 Groundwater
4.3,2.1 Water usage
The applicant has obtained a permit to utilize up to 1.0 X 106 m3 (811 acre-ft)although the
mill will only use about 5.9 x 105 m3 (480 acre-ft)of water per year,which will be withdrawn
from the Navajo sandstone aquifer.All other wells within 8 km (5 miles)produce from other
formations.This usage will have no effect on other users.
4.3.2.2 Potential degradation of groundwater
The mill will discharge about 1.12 m3/min ~310 gpm)of liquid to the proposed tailings impound-
ment (Fig.3.4).The chemical and radiological composition of this waste liquid is given in
Table 3.1.
The applicant has proposed to line the evaporation cells (1-1 and 1-E)and tailings cell 2 with
a multicomponent liner (of synthetic and onsite clayey-silt materials)and to line the remaining
"tailings cells with a 2 foot layer of compacted clay (permeability approximately 3xlO-8 cm/sec)to
essentially eliminate seepage into the underlying Dakota formation;therefore,the possibility
of groundwater degradation caused by seepage of tailings liquids is considered to be remote.After
reclamation,when deterioration of the liner may have occurred,the staff expects essentially no
seepage into the Dakota formation because of the high net evaporation rate in the area.Pre-
operational and operational monitoring of the groundwater is required (Sect.6.3),and mitigating
measures will be taken if unexpected groundwater contamination is observed.
4-6
4.4 MINERAL RESOURCES
Only uranium,vanadium,and copper are present in sufficient quantities to warrant processing.
At present copper extraction is uneconomic.If this copper,or any other mineral in the ore,
becomes more valuable in the future,the overburden could be removed from the tailings and these
minerals extracted;therefore,this project is not expected to have any impact on the avail-
ability of other minerals.
4.5 SOILS
construction of the mill and tailings disposal system will disturb about 195 ha (484 acres)
(Table 4.3).The top 15 cm (6 in.)of soil,removed from the mill site,tailings cells,and
borrow area,will be stockpiled at two locations totaling 4 ha (10 acres)(Fig.3.4).The
remaining overburden and rock will be stockpiled at four areas,totaling 21 ha (52 acres).
Removal of topsoil will disrupt existing physical,chemical,and biotic soil processes.
Although topsoil will be replaced upon termination of the project operations,a temporary
decrease in natural soil productivity is probable.7
Removal of topsoil and natural vegetation on the site will accelerate wind and water erosion.
Generally,the duration of these impacts will be only during the construction phase.which is
expected to take one year.To minimize fugitive dust resulting from construction activity,the
applicant will frequently water exposed areas and heavily traveled areas,and all vehicles will
be operated at a reduced speed.3 The tailings impoundment will be constructed as six separate
cells (Fig.3.4),only four of which will be active at any given time.As a tai1~ngs cell i~
being reclaimed,another cell is being constructed.This construction sequence w111 result 1n a
minimum disturbance of land at any given time.The material excavated from one cell can be hauled
directly to a filled cell and placed over the tailings as part of the required cover,thus
reducing handling of materials.
All mill facilities will be located upstream of the tailings cells.Evaporation cell 1-1 and
tailings cell 2,which will be constructed simultaneously with the mill facilities and a
sedimentation pond,will capture mill site runoff (Fig.3.6).Although sediment transfer will
be increased within the site,the location of the mill facilities and tailings cells should
minimize sediment transfer from the site,as discussed in Section 4.3.1.To minimize erosion,
the overburden and topsoil stockpiles will be stabilized by seeding with cereal rye and yellow
sweet clover.s Sunflowers,Russian thistle,and other annual plants will also become established
and will aid in preventing erosion of the stockpiles.
Impacts to soils during operation of the mill include wind and water erosion.Soil over mucho~the site will be stabilized by gravel and the presence of structures.The topography of the
sl~e concentrates some of the surface water at two points directly north of the proposed mill
(F1g.3.4).During operations,diversion ditches will be constructed in this area to collect
surface runo~f from ~he drainage above the mill site [25 ha (62'acres)],and the discharge
from these d1tches w111 be directed to the east into Cottonwood Wash.Rock from excavation of
the tailings cells will be placed as riprap in the drainage channels to help prevent severe
erosion.Rock will also be used to construct the downstream slope of dike 5 and areas on the
perimeter of the reclamation cover.Mill and facilities area runoff will be contained by asedimentpond(Fig.3.4).
upon termination of the mill operations,.a11 remaining disturbed areas will be reclaimed to
restore the land to preconstruction land uses (Sect.3.3.2).Reclamation laws require successful
establishment of a soil medium that is capable of sustaining vegetation without irrigation or
continuing soil amendments.Assuming reclamation efforts will be successful,long-term impacts
to the soil are not expected to be significant.
4.6 BIOTA
4.6.1 Terrestrial
The primary ecological impact of construction and operation of the mill and tailings disposal
system will result from the loss of habitat.However,the majority (85%)of the vegetation
that will be removed has been previously disturbed to varying degrees by either chaining,
plowing,or reseeding (Figs.2.10 and 3.4;Tables 2.26 and 4.5).Winter deer use of the project
vicinity,primarily pinyon-juniper-sagebrush habitats,is among the heaviest in southeastern
Utah.9 However,because similar rangeland is very common throughout the region (Sect.2.5),it
is expected that loss of this relatively small parcel of land (less than 0.1%of the private
rangeland in San Juan County)should not significantly reduce the amount of habitat for these
animals.
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4-7
Table 4.5.Community types and approximate
expanse to be disturbed by construction and
operation of the White Mesa mill
Area to be
Community type disturbed
ha acres
Pinyon-juniper woodland
Big sagebrush
Reseeded grassland I
Reseeded grassland II
Tamarisk'salix
Controlled big sagebrush
Disturbed"
"Includes ore buying station.
2
27
29
45
1
89
11
6
68
73
115
2
225
28
!f"~;a ,-,
len
ed
Land clearing,operation of heavy equipment,and other construction activities will .destroy
small animals that move too slowly to escape or that retrea~to bu~rows for protec~1?n.Other
animals will be displaced and may be lost because of predatlon or lncreased competltlon for
food,territory,and other habitat requir~ments.Although ma~y ?f.these.species are important
members of the food chain,their destructlon would not be.a slgnlflcan~lmpact b~cause thes~
animals comprise a very small percentage of the total reglonal populatlons.Habltat that wlll
be disturbed as a result of construction and operation of the mill ~epresents less than.0.05%of
similar habitat in the county.
Suspended particulate matter will be emitted into the air by construction activities (Sect.4.1).
These particulates will eventually be deposited in part on the surrounding vegetation therebyreducingplantvigororcausingtheplantstobelesspalatabletoconsumers.Although the
magnitude of these potential impacts is not known.it is expected to be negligible.No signif-
icant deleterious effects have been demonstrated at other construction projects ·of similar orgreatermagnitude.Furthermore.if any impacts do occur from fugitive dust and/or gaseous
emissions,they should be minor and short term.
Few data are available to demonstrate the effects of noise on Wildlife,and much of what is
available lacks specific information concerning noise intensity,frequency,and duration of
exposure.10 Probably,the noisiest period of construction will be during the excavation of thetailingscells.The applicant estimates the average sound level during the excavation
phase to be about 66 dB(A)at 300 m (1000 ft)from the center of activity.Such noise is not
expected to seriously affect the area wildlife.The noise initially may cause migration by some
wildlife away from the immediate site vicinity,but those that remain or return will generally
become habituated to construction noises and activities.IO
To balance yearly water inputs with yearly net evaporation,the evaporation cell design will
require a surface area of about 40 ha (98 acres)of tailings water.11 These liquids will be
unsuitable for use by wildlife due to radionuclides and other contaminants.However,the fencing
around the tailings impoundment will exclude large animals.and the acidic nature of the pond
(pH of about 1.8 to 2.0),and the high salinity will make it unsuitable for most aquatic
organisms and subsequently an unattractive feeding place for waterfowl.However,a few waterfowl
or other birds may rest on the impoundment for a short time during migration.Following ter-
mination of the mill operations,the tailings disposal area would remain fenced until releasedfromitsstatusasarestrictedareaandwillnotbeusedforanypurposeotherthantailings-stabilization and reclamation.
Increased human population associated with construction and operation of the mill wi'll adversely
affect most wildlife in the area.Greater human population will cause an expansion of munici-
palities for commercial.residential.and recreational purposes.Although some species may
benefit from large human populations.most of the larger mammals and predators will abandon
habitats in close proximity to intense human activity.Additional stress will be placed on the
terrestrial biota as a result of greater hunting pressure (both legally and illegally)and
destruction of habitat by off-road recreational vehicles.Increased wildlife losses are
expected to occur as a result of greater vehicular travel on highways.
lJ
[
The operation of the uranium mill will not entail direct discharge into any surface waters.As
':he construction and operation of the proposed uranium mill should not affect local surface I
waters to any significant extent,the staff does not predict any adverse impacts on aquatic '~iota.:
4-8
None of the proposed endangered plant species12 that have documented distributions in San Juan
County13 are expected to occur on the facility site or immediate vicinity.Although the
endangered 14 American peregrine falcon (FaZao peregrinus anatum)and bald eagle (HaZiaeetus
ZeuaoaephaZus)range in the vicinity of the site,lack of suitable habitat indicates a low
probability of these species utilizing the project site for feeding or nesting.Th~b1ack~
footed ferret (MUsteZa nigripes),which once ranged in the vicinity of the site,has not been
sighted in Utah since 1952,l~and the Utah Division of Wildlife Resources feels that the
presence of this species is highly unlikely (ER,Sect.2.8.2.2).Therefore,construction and
operation of the proposed mill is not expected to impact any endangered species.
4.6.2 Aquatic
4.7 RADIOLOGICAL IMPACTS
4.7.1 Introduction
Th~primary sou~ces of.radio10gica1 impact to the environment in the vicinity of the proposed
Whlte ~esa Uranlum ProJect are naturally occurring cosmic and terrestrial radiation,and naturally~ccurr~ng radon-222.The average who1e-bod~d?se rate ~o the population in the site vicinity,
lncludlng doses from natural background radlatlon and dlagnostic medical procedures is estimated
to be about 236 millirems per year (see Sect.2.1C),'
This 'section describes the results of the staff's analysis of the mil1~contributed incremental
radiological impacts to the environment and the population in the vicinity of the White Mesa
mill site.This analysis is primarily based on the estimated annual releases of radioactive
materials given in Table 3.3 and the models,data,and assumptions discussed in Appendix D.
Detailed analyses of the radiological impacts of mill operations to nearby individuals and the
entire population within 50 miles have been performed.All potential exposure pathways likely
to result in significant fractions of the mill's total radiological impact have been included
(see Fig.4.1).Consideration has also been given to the occupational exposure received by mill
employees and radiation exposure of biota other than man.
4.7.2 Exposure pathways
Potential environmental exposure pathways by which people could be exposed to radioactive mill
effluents are presented schematically in Fig.4.1.Estimates of dose commitments to man have
been based on the proposed plant design,and actual characteristics of the site environs.The
staff's analysis has included considerations of radioactive particulate and gaseous releases totheatmosphere.'
There will be no p1anned'or routine releases of radioactive waste materials directly into
surface waters.While there is a possibility of some seepage of radioactive liquids from the
tailings impoundments into the groundwater system,tni·s possibility is considered remote and no
significant contribution to dose via liquid pathways is expected.Furthermore,the applicant
will be required to perform ,environmental and other monitoring programs to provide early
detection of any seepage that might occur and to take appropriate mitigating measures.
Environmental exposure pathways of concern for airborne effluents from the White Mesa mill
include 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 (vegeta-
bles and meat).
4.7.3 Radiation dose commitments to individuals
The nearest known resident lives approximately 4.5 km (2.8 miles)north-northeast of the
proposed location of the mill building (ER,Plate 2:2-1).A mobile home about 3.2 km (2.0 miles)
north of the mill was occupied until recently but has since been moved.The nearest residence
in the direction of the prevailing winds is located about 6.4 km (4.0 miles)to the south.
Nearby population groups include the community of White Mesa.about 8.0 km (5.0 miles)to the
southwest with a population of about 300,and the city of Blanding.9.6 km ~6.0 miles)to the
north-northeast with a population of about 3300 (ER.Plate 2.2-1).
I
'II
I
.....I.0
'~'--:11
RAD IOAC TIVlTV
IN SOIL
~-~,
L ~__:
zo
I-
m .....a.-'F'"",,~'<!,!",g-"'I\t-,I:,'.,·-~iI K:,:~~·,:.",.-·~\9
E5-4699
VIol1.
IUo
RADIOACTIVITY INGESTION QHAN
IN ~.r..VEGETATION -.lL
AIRBORNE
RAD IOACT,IVITY
INHALATION QIRADONANDPARTICULATES"HAN
"''I
Q'"..I I~.,#7 ii-VIzIUl1.VI::>VI
IU'"
W"""'l'l~~~~~1L;'''/~
YELLOWCAKE DRYING
AND PACKAGING
PRODUCT TO
MARKET
LEACHING AND
EXTRACTION
Fig.4.1.Sources of radioactive effluents from the mill and exposure pathways to man.
ORE FROH HINES
r.--··I
-'
ez~::::~VI[_:~:_:;1
._.....~..._._.-
--~
-
4-1G
The nearest potential residence locations are along the northern border of the site,about
1.9 km (1.2 miles)from the mill building.Substantial tracts of privately held acreage
exist in this area.All other lands abutting the mill site to the east,south,and west are
the property of Energy Fuels Nuclear,Inc.,or the U.S.Bureau of Land Management.The area
immediately to the north of the mill site,although suitable for residential structures,
presently is believed to be used only 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 caiculated for other locations around the site at which grazing could
be expected to occur.
Table 4.6 presents a summary of the individual dose commitments calculated for the nearest
actual residence,the nearest actual residence in the prevailing wind direction,and the nearest
potential residence.At each of these three locations,it is assumed that individuals ingest
meat grown at thelocatiori of the nearest potential residence,along the northern site
boundary.Table 4.6 also presents the inhalation and external doses calculated for the
community of White Mesa and the city of Blanding.
Table 4.6.Annual dose commitments to individuals from radioactive
relea!ll!s due to operation of the White Mesa Uranium Mill
Annual dose commitment (millirems)
Location Exposure pathwav BronchialTotalbodyBoneLungepithelium"
Nearest residence,Inhalation 0.039 1.0 0.89 19
4.5 km (2.8 miles)north·northeast External from cloud 0.12 0.12 0.12
External from ground 0.87 0.87 0.87
Vegetable ingestion 0.34 4.0 0.34
Meat ingestion 1.0 10 1.0
Total 2.4 16 3.2 19
Nearest residence in Inhalation 0.013 0.34 0.55 25
prevailing wind External from cloud 0.22 0.22 0.22
direction,6.4 km External from ground 0.24 0.24 0.24
(4.0 miles)south Vegetable ingestion 0.094 1.1 0.094
Meat ingestion 1.0 10 1.0
Total 1.6 12 2.1 25
Nearest potential Inhalation 0.13 3.5 4.1 78
residence,1.9 km External from cloud 0.20 0.20 0.20
(1.2 miles)north External from ground 3.2 3.2 3.2
Vegetable ingestion 1.3 15 1.3
Meat ingestion 1.0 10 1.0
Total 5.8 32 9.8 78
Community of Inhalation 0.023 0.60 0.60 20
White Mesa,ao km External from cloud 0.19 0.19 0.19
(5.0 miles)southwest External from ground 0.16 0.46 0.46
Total 0.37 1.3 1.3 20
City of Blanding Inhalation 0.0074 0.2 0.24 8.1
9.6 km (6.0 miles)north·northeast External from cloud 0.090 0.09 0.09
External from ground 0.13 0.13 0.13
Total 0.23 0.42 0.46 8.1
-Doses tothe bronchial epithelium result from the inhalation of the Short·lived daughters of Rn·222.
4.7.4 Radiation dose commitments to populations
The annual doses to the population estimated to exist within 80 km (50 miles)of the site in
the year 2000 are presented in Table 4.7 along with estimated annual doses to the same population
from natural background radiation sources.Population dose commitments resulting from the
operation of the White Mesa uranium mill represent less than 1%of the doses from natural
background sources.
Table 4.7.Annual population dose commitments
within 80 km (50 miles)
Organ
(.,<.0__J--
4-11
Population doses,
man·rems/yearB
r!
aBased on a projected year·2000 population of 46,500.
b The estimated natural background dose rate to the whole body is
161 millirems per year.The bronchial epithelium dose from naturally
occurring Rn-222 is assumed to be 500 millirems per year (Sect.2.10).
Plant effluents Natural backgroundb
Total body
Bone
Lung
Bronchial epithelium
3.4
6.4
7.1
132
7,500
7.500
7.500
23.000
rILi-_,
riI
f:L
c
or"~L..
4.7.5 Evaluation of radiological impacts on the public
All radiation doses calculated to result to the surrounding population from uranium milling
operations at the White Mesa site are small fractions of those arising from naturally occurring
background radiation (see Table 4.7).They are also small when compared to the average
medical and dental x-ray exposures currently being received by the public for diagnostic
purposes.
calculated annual individual dose commitments are only small fractions of present NRC limits
for radiation exposure in unrestricted areas.as specified in 10 CFR Part 20,"Standards for
Protection Against Radiation."Dose commitments to actual receptors are also well belowlimitsspecifiedintheEPA's "Radiation Protection Standards for Normal Operations of the
Uranium Fuel Cycle"(40 CFR Part 190),which is to become effective for uranium milling
operations in December 1980.Table 4.8 provides a comparison of maximum calculated annual
dose commitments with the radiation exposure limits of 10 CFR Part 20 and 40 CFR Part 190.
As indicated in Table 4.8,radiation dose commitments to the bone of an individual living atthenearestpotentia1residencecauldexceedthe25-mi 11 i rem per year EPA 1imit by about 2V~.
The staff has a1so determi ned that bone doses from the ingestion of r,leat "F"OIll anima is grazed
to the south of the present site would be in excess of 40 CFR Part 190 limits;however,the
applicant is currently negotiating to obtain this land and would be able to restrict access by
grazing catt1e.8 Meat and/or vegetable ingestion doses could exceed 40 CFR Part 190 limits
at locations to the east if dusting of tailings sands is not controlled adequately.Therefore.the staff would require the applicant to
1.implement the environmental monitoring program outlined in Table 6.2;
2.perform and document an annual land use survey to determine changes in land use (e.g.,for
grazing,residence,and well locations);and
3.implement an interim stabilization program for all exposed tailings areas to minimize the
blowing of tailings.The program would include a weekly,documented inspection to assess
the effectiveness of the control methods being used.
4.7.6 Occupational Dose
Uranium mills are designed and built to minimize exposure of both the mill workers and the
general public to radiation.Occupational exposures for workers are required to be monitored
and kept below NRC limits.In addition,protection measures to reduce occupational exposures
are periodically reviewed and revised in accordance with the requirement to make such exposuresaslowasisreasonablyachievable..
Special studies lG at selected mills have shown that the exposures of mill workers to airborne
radioactivity are normally below 25%of the maximum permissible concentrations given in
Appendix Bof 10 CFR Part 20 and that external exposures are normally less than 25%of .~O ~FR Part 20 1imits.lG ,17 A recent review18 of mill exposure data by the NRC staff has
1ndlcated that only a few uranium mill employees may have exceeded,over a one-year period,
15 to 20%of the permissible exposure to ore dust,25%of the permissible exposure to~e1~o~cake,or 10%of the permissible exposure to radon concentrations.Except for a few
1nd1vldua1s,the combined exposure of an average worker to these radioactive components over ,
a one-year period probably does not exceed 25%of the total permissible exposure.
[
I
4-12
4.8 SOCIOECONOMIC IMPACTS
Table 4.8.Comparison of annual dose commitments to individuals
with applicable radiation protection standards
0.005
0.005
0.002
0.005
0.06
0.6
0.09
Fraction
of limit
25
25
25
500
3000
1500
0.033WL
c
Applicable
limit,mrem/yr
2.4
16
3.2
0.00015WLa
1.4
15
2.2
19
Estimated
dose,mrem/yr
Nearestacrua/residence,4.5 km 12.8 miles)nonh-nonheast
Present NRC regulation (10 CFR Part 201
Future EPA standard (40 CFR Part 19O)b
Organ
Total body
Bone
Lung
Bronchial epithelium
Total body
Bone
Lung
Bronchial epithelium
Nearest potential residence,1.9 km (1.2 miles)north
Present NRC regulation (10 CFR Part 20)
Total body 5.B 500 0.01
Bone 32 3000 0.01
Lung 9.B 1500 0.007
Bronchial epithelium 0.00036 WL 0.033WL 0.01
Future EPA standard (40CFR Part 190)b
Total body 2.5 25 0.1
Bone 29 25 1.2
Lung 6.5 25 0.3
Bronchial epithelium 7B c
a Radiation standards for exposure to Rn-222 and its short-lived daughters
are expressed in terms of working level (WLI concentrations.One WL is the
amount of any combination of short-lived radioactive daughters of Rn-222 in 1
liter of air that will release 1.3 X 105 MeV of alpha energy during their dec'ay to
Pb-210.
bDoses computed for evaluation of compliance with 40 CFR Part 190 are
less than total doses because dose contributions from Rn-222 released from the
site,and any radioactive daughters that grow in from released Rn-222 have been
eliminated.!-imits in 40 CFR Part 190 do not apply to Rn-222 or its radioactive
daughters.
eNotlimited.
4.7.7 Radiological impact on biota other than man
Although no guidelines concerning acceptable limits of radiation exposure have been established
for the protection of species other than man.it is generally agreed that the limits for humans
are also conservative for those species.19-26 'Doses from gaseous effluents to terrestrial biota
(such as birds and mammals)are quite similar to those calculated for man and arise from the same
dispersion ~athways and considerations.Because the effluents of the mill will be monitored andmaintainedwithinsaferadiologicalprotectionlimitsfor,man.no adverse radiological impact is
expected for resident animals.,
4.8.1 Demography and settlement pattern
4.8.1.1 Population increase from direct employment
A peak employment of 250 construction workers will be reached in August 1979 and maintained for
three months.Over a 12-month period.there will be an average.of 175 employees.Mill opera-
tions are expected to employ 85 workers (Table 4.9).If 60%of the construction workers re-locate from outside the project area,27 an average of 105 workers and a peak of 150 workers willmoveintotheregion.If construction workers are accompanied by 0.9 nonworking dependents,28
the population increase attributable to construction will be as shown in Table 4.10.
Table 4.9.Employment,White Mesa Uranium Project-Construction
Operations
Table 4.10.Population influx associated with
the White Mesa Uranium Project
Construction
:'
Average Peak Operations
Direct employment
Average Peak
Salaried staff 2sa·b
Construction workers 175 250
Mill workers 85b
Total direct 175 250 110b
aRepresents increases over OJrrent employment.
b Full capacity.
Sources:ER,p.4·13;Energy Fuels Nuclear,Schedule of
Projecmd Manpower RtlqUiremenrs;Muril D.Vincelette,Vice
President for Operations.Energy Fuels Nuclear,Inc.,personal
communication with Martin Schweitzer,Oak Ridge National
Laboratory,July 12,1978.and August 15,1978;and Erik J.
Stenehjem and James E.Metzger,A Framework for Projecting
Employtrl6flt and Population Changes Accompanying Energy
Development,Argonne National Laboratory.Argonne,III.,
1976.
Indirect employment
Salaried staff
Mining
8uYing station
Service (nonbasic)
Total indirectl
Total employment
100
100
275
100
100
350
2aa
220-2soasa
578-62aa
829-907"
939-1017
Direct employment
In-moving workers 105 150 57"
Nonworking dependentsb 95 135 120
Total direct 200 285 177
Indirect employment
In'moving workers 47 47 432-587
Nonworking dependentsC 99 99 907-1233
Total indirect 146 146 1339-1820
Total in·moving workers 152 197 489 644
Total influx 346 431 1517-1997
aFull capacity.
bTo find the total number of nonworking dependents.multiply the
number of construction workers and operations personnel by 0.9 and
2.1 respectively.
cTo find the total number of nonworking dependents,multiply the
number of workers by 2.1.
Sources:ER,p.4·13;Energy Fuels Nuclear,Schedule ofProjected
Manpower Rtlquiff1ments;Muril D.Vincelette.Vice President for
Operations.Energy Fuels Nuclear.Inc.•personal communication with
Martin Schweitzer,Oak Ridge National Laboratory.July 12,1978,and
Erik J.Stenehjem and James E.Metzger.A Framework for Projecting
Employment and PoPt/larion OIanges AccompanYing Energy Develop·
ment,Argonne National Laboratory,Argonne,III..August H176;and
Mountain West Research,Inc..Construction Worker Profile,Old West
Regional Commission,December 1975.
ed
ns
ota
same
and
:is
ill
I
During operations,75%of the jobs available could be filled from the "local"labor pool.Up to
30%of these workers may relocate closer to their new place of employment (Vice-President for
Jperations,Energy Fuels Nuclear,Inc.,personal communication,July 12,1978).In San Juan
:ounty,there are 2.1 nonworking dependents for every worker.28 If this relationship holds for
relocations,the population may grow by 177 individuals.
4.8.1.2 Population increase from indirect emplOyment
Indirect employment is the total of new jobs created in industries that supply factors ofproductionandthatproducethegoodsandservicesdemandedbyprojectworkers.28 Between
0.3 and 0.9 indirect employees are generally needed for each construction worker during the
construction phase of an energy project.29 Because there is normally a lag between the crea-
tion of direct jobs and the indirect jobs they induce,it is likely that during the relatively
short construction period in question indirect employment will stay at the low end of the scale
and not rise above 100 (Table 4.9).
Because there are many clerical,sales,and service workers seeking employment in the Blanding
area (Sect.2.4.2.2),many of the indirect jobs created by mill construction may be filled from
the local area.At most,the same proportion of workers will move in as is expected in the
case of mill operators (47 employees or less).Including nonworking dependents,146 persons
will move into the area (Table 4.10).
During mill operation,the proportion of indirect to direct employment will increase.To
operate at capacity,the White Mesa uranium mill requires 1800 MT (2000 tons)of are daily,
Which will be supplied by area mines.According to the applicant,the ore buying stations
(one located at the proposed mill site and the other in Hanksville)are currently buying
slightly over one-fourth of the ore the mill will consume at peak operations.This fraction
means that only one-fourth of the miners that will eventually be needed to supply the mill
are already employed.An increase of 220 to 250 miners over current.employment levels is expected
(Table 4.9).If between one-half and two-thirds of these future jobs are filled by personsmovingintothearea,then about 110 to 16~miners will migrate in for a total population gain
of 340 to 510,based on 2.1 nonworking dependents for every worker.
Currently,the Energy Fuels ore buying stations employ ten people.Five additional jobs at the
Blanding station when mill operations start will mean an increase of five in area population.
The 21 workers employed by Energy Fuels in ore exploration is not expected to change.
In San Juan County's economy,there are 1.6 nonbasic jobs for each basic job.The basic sector
brings in revenues from outside the immediate area.The nonbasic sector provides goods and
services in response to local demand.Because the White Mesa project is expected to add 361 to
·391 new basic jobs to the area economy,it can be predicted that 578 to 626 new jobs will be
created in the nonbasic sector.If the proportion of in-migrants taking nonbasic jobs is approxi.
mate1y the same as described earlier,roughly 300 to 400 jobs in the nonbasic sector will be
taken by persons moving into the area,causing a population increase of 930 to 1240.
4.8.1.3 Total population increase
About 120 hourly workers and staff will be involved in mill operations.Nearly 60 of these
employees should be new to the area.Indirect jobs stimulated by the mill are expected to be in
the range of 830 to 910.The total population increase would range from approximately 1500 to
2000 (Table 4.l0).
4.8.1.4 Distribution of new residents
The 431 new residents expected as a result of construction of the White Mesa Uranium Project
represents 3.3%of the San Juan County population.Their settlement pattern will be determined
by a number of factors including the availability of housing,public services,and amenities in
the surrounding communities and the proximity of those communities to the mill site.Blanding,
Monticello,and Bluff are all within 48 km (30 miles)of the proposed mill and are capable of
absorbing the projected population growth.
Because it is closest to the site,Blanding is likely to experience more in-migration than the
other two communities.
The population influx during the operations period will be much greater than that associated with
construction.The 1500-2000 new residents expected represents 11.5 to 15.4%of San Juan County's
current population.
The majority of mill-related personnel are expected to reside in the three above-named communi-
ties;however,since the mining operations selling ore to the applicant are geographically
dispersed,some in-migrating miners will locate in the outlying rural areas.
4.8.2 Social organization
Studies of other areas impacted by energy projects indicate that rapid population growth can lead
to inadequacies in the provision of housing and essential public services,such as water andsewagetreatment,education,and health care.An annual growth rate of 15%is often cited as
the point where.these problems become severe.30 ~ssuming that Blanding gets 70%of the popula-
tion growth induced by the White Mesa uranium mill,Monticello gets 25%,and Bluff receives 5%,
none of these communities will experience even a 10%population increase in 'the one-year
construction period.However,during the three-year period from early 1980,when ml11 operations
are scheduled to begin,through the end of 1982,when most of the direct and indirect population
increases should have occurred,the number of in-migrants will be much greater (Table 4.11).If
the total population influx reaches 2000,Blanding's rate of growth will average nearly 15%
annually over.thethree years in question.While Monticello and Bluff will not grow at this
rate,their increases will be substantial (see Sect.2.4.1.2).
Balanced against this rapid growth are plans for providing additional housing and public services
in the impacted communities.Action from both the public and private sector is anticipated,.
which will help reduce the adverse effects that can result from unmanaged growth (Sects.4.8.2.1
and 4.8.2.2).
4.8.2.1 Housing
During the construction period,197 workers are expected to relocate in the project area.It is
likely that a number of these workers will share accommOdations;therefore,between 145 and 197
new housing units will be demanded during this time.
J-is
Table 4.11.MiII·induced population influx for the communities of Blanding,Monticello,
and Bluff,assuming a 70-25·5%split of the in-moving population
,0
:'oxi-
Population In 1977
Peak construction·period influx'
Peak construction·period influx
as a percentage of 1977 population
Operations·period influxb
Operations·period influx as
a percentage of 1977 population
Blanding
3075
302
9.8%
1050-1400
34.1-45.5%
Monticello
2208
108
4.9%
375-500
17.0-22.6%
Bluff
280
22
7.7%
75-100
26.8-35.7%
:-li:,
I •I I!I
in
!d
n
I,
lith
.y's
•Peak construction·period influx is projected to be 431.
bOperations.period influx is projected to be approximately 1500-2000.
In the operations period,489 to 644 new jobs are expected to be filled by in-migrants.Because
these workers are much more likely to become permanent members of the community and to relocate
with their families,it will be assumed that one housing unit is required for each of 'them.
Table 4.11 projects the future growth of each of these communities using previous assumptions
(Sect.4.8.2).If this distribution is used as a guide,roughly 100 to 140 housing units will be
needed in Blanding,35 to 50 in Monticello,and 7 to 10 in Bluff during the construction period.
During operations,Blanding will need 340 to 450 units,Monticello 120 to 160,and Bluff 25 to 30
(Table 4.12).Although no new workers are anticipated at the Hanksville ore buying station,
mining activity in the area may create some demand for additional housing in the town of
Hanksville.Under current conditions this would not be easily accommodated although future
improvements in the local water system (ER,p.2-74)may make residential expansion possible.
Blanding
In August 1978,plans for a l17-space mobile home park,scheduled to be ready for occupancy by
February 1979 were approved in a newly annexed portion of the city.At the same time,a 242-
unit subdivision was approved in another newly annexed section;construction is scheduled to
begin in January 1979.
Table 4.12.Housing demand and supply in Blanding.Monticello.and Bluffcaused by the White Me..lhnium Project
ead Construction period Operations period
Supply Supply"
City Demancf Dema~
Existingb In process Possible Total Existingb In process Poss,ible Total
Blanding 100-140 25 149 174 340-450 25 391 200 616onsMonticello35-40 35 23 58 120-160 35 23 200 258onBluff7-10 20 20 25-30If 20 0-70 20-90
Total 142-200 80 172 252 485-Q40 80 414 400-470 844-964
ces
.1
is
7
•Assumes a 70-25-5%split of the in-moving population between Blanding,Monticello.and Bluff.
bAs of August 1.1978.
"Operations-period supply includes those units developed during the construction period.
Sour,ces:ER.pp.4-18 and 2·58;and Philip D.Taylor.President,Taylor &Associates,August 17,1978;Terry Palmer,
Palmer Builders.July 13,1978;Richard Terry,Monticello City Manager.August 4.1978,private communications with
Martin Schweitzer,Oak Ridge National Laboratory.
-,.-------------_.-_.
.1-15
The 117 mobile home spaces,combined with 25 existing spaces in Blanding (ER,p.4-18),are
sufficient to satisfy the maximum demand projected for the construction period.In addition,a
32-unit apartment complex is now in the financing stages and local builders estimate that 50 to
60 new single-family houses could be constructed annually for at least the next three years on
the 200 vacant lots estimated to be available within the city limits (Palmer Builders representa-
tive,personal communication,July 13,1978).The total number of potential additional housing
units is around 600,nearly enough to absorb all mill-related growth.Counting only those units
now existing or having city approval,the number is still nearly 400,mid-way between the high
and low projections of Blanding's share of expected growth (Table 4.12).
Monticello
There are 35 vacancies in a local mobile home park (ER,p.4-18),and a 23-unit apartment
building is being constructed.In addition to these 58 units (more than the 35-50 needed duringconstruction),200 single family homes are expected to be built by 1981 (Monticello City Manager,
personal communication,July 20,1978).This quantity will be more than enough to accommodate
Monticello's expected share of mill-induced growth during the operations period and indicates
that this city has the potential of absorbing additional growth (Table 4.12).
Bluff
The 20 mobile home park spaces now available in Bluff (ER,p.4-18)can accommodate twice the
projected growth for the construction period and two-thirds of that expected during operations.
Because the town also has 70 empty lots (ER,p.2-56)suitable for development,it is possible
that more growth than was postulated may occur here (Table 4.12).
4.8.2.2 Public services
Blanding
Population increases should not strain the existing electricity distribution or solid waste
disposal systems.Streets and recreation facilities are also adequate.Water and sewage systems
are adequate for the 300 new residents expected during -the construction period (Blanding CityManager,personal communication,June 21,1978),but they are not sufficient for the mill-induced
newcomers.However,expansions in both water and sewer facilities,which are planned for
completion by 1981,should be adequate to provide acceptable services to these in-migrants.
Additional public safety and health care services are likely to be necessitated by the operationsperiodpopulationinflux.Blanding has plans to add a new full-time member to the police force
in fiscal year 1979 (ER,p.2-47).
Approximately 120 new school age children are expected during the construction period.27,31
During the operations period,384 to 504 new students will be entering Blanding's schoo1s.31 In
the fall of 1978,a new high school in southeastern San Juan County will relieve current over-
crOWding in San Juan High School and leave it approximately 100 students below capacity.The
opening of a second new high school in fall 1979 in southwestern San Juan County will leave
roughly 300 vacancies in San Juan High School.Blanding's two elementary schools are currently
120 students below capacity;therefore,the influx of additional students during the construction
period should not present a problem.However,the influx of 200 to 300 new elementary students
during the operations period will necessitate operating at 80 to 180 students over capacity.The
school district is prepared to provide new facilities as the need arises (San Juan County School
District,personal communication,August 18,1978).
Monticello
Existing solid waste disposal and recreation facilities appear adequate to accommodate the
projected population influx,as does the local system of streets.Improvements in public safety
and health care facilities are likely to be required.To supply future needs,the community is
currently attempting to expand the city-run electricity transmission system.
The existing sewage treatment plant is currently operating at its design capacity;the growth
associated with mill construction and operations would cause-overloading.Improvements are being
planned to allow service for 3000 residents,but completion is not anticipat~until at least
mid-1980.The city's share of the associated expenses will amount to roughly one-quarter million
:\
~I
:a-
I.s
ms
ed
ns
4-17
d 11ars and is likely to be financed through general obligation bonds.The remainder of the
o uired funds will come from the Federal government.Monticello's water supply system isre~rentlY operating near capacity.However,improvements to the existing system are scheduled to~u completed by August 1979.Until that time,lack of water is a limitation to growth.After-
erd the system will be able to accommodate nearly 800 new people.The city's share of projectwape~ditures will be approximately $600,000,financed by general obligation and revenue bonds(~ontiCello City Manager,.personal communication,July 11,1978).
Because both the elementary and the high school are operating at approximately two-thirds
apacity,with room for over 300 students between them,the addition of 140 to 180 new students~uring the operations period should not present a prob1em.3l
~
Most existing public services in the town of Bluff are currently adequate to handle the limited
rowth anticipated.The local water system is capable of accommodating a 79%increase in usage.~ewage disposal is currently handled by individual septic tanks.Public safety,recreation,and
health facilities may all require incremental improvements to keep up with rising population.
Educational facilities are also more than adequate for the expected in-migration.Growth beyond
that shown in Table 4.11,however,may strain existing public services and call for improvements
not considered here.
4.8.2.3 Culture
Nearly 45%of San Juan County residents are native Americans (predominantly Navajo),and
another 35%are members of the Mormon Church.32 Changes in the relative numbers of these twogroupScouldalterthesocialclimateintheareaoftheproposedmill.
In addition to potentially changing the racial and re1 igious composition of the community,a
substantial population influx could also create tensions between established "old-timers"and
"newcomers."As area population grows,long-time residents may feel a loss of intimacy,and
value conflicts may arise between those who favor a more "urban"lifestyle and those who wish to
preserve a small town atmosphere.33 However,because the greatest growth will occur during the
operations period,when in-migrants are much more likely to settle permanently than during
construction,it is expected that eventually a mutual accommodation of "old"and "new"values
will occur.
4.8.3 Political organization
Changes in the political as well as the cultural characteristics of an area frequently accompany
rapid growth.Expansion and "professionalization"of local government often occur in response to
the changing size and characteristics of the population.This trend'is evident in the area of
the proposed White Mesa mill where the city of Blanding has recently hired a full-time city
engineer in response to the accelerating growth rate (Blanding City Manager,personal communi-
cation,August 14,1978),and Monticello anticipates the eventual need for more public employees
to handle future in-migration (Monticello City Manager,personal communication,July 11,1978).
The local power structure can also be altered by the growth associated with a project such as the
White ~lesa Uranium t1ill.Political control may pass from the hands of established residents to
those of newcomers associated directly and indirectly with mill operations.33 As in the cultural
arena,a balance is likely to be reached over time between divergent political interests.
.4.8.4 Economic organization
4.8.4.1 Employment
Peak employment during the construction of the White Mesa mill is expected to be about 350;of
these workers,approximately'150 are expected to come from the immediate area.During opera-
tions,between 939 and 1017 new jobs are expected to be created directly and indirectly by the
mill.Roughly 300 to 500 of these jobs should be filled by area residents.At 8.1%,the
[
rI
~1-1a
unemployment rate in San Juan County is significantly higher than the state average of 5.3~
(Sect.2.4.2.2),and it is highly probable that mill-induced employment will result in a lowering
of this figure.
4.8.4.2 Income
Of the additional 350 needed during construction,250 will be construction workers whose wages
are substantially higher than the local mean.The remaining 100 will be employed in lower-paying
jobs in the nonbasic sector.During operations,nearly 40%of all new workers will be highly
paid miners or mill personnel.According to the Utah State Department of Employment Security,
the avera~e monthly salary for a miner in this state is $1500 to $1833 and for a miller,$1000
to $1500.3 .
These high-paying new jobs will elevate average per capita income in San Juan County and increase
the amount of money spent in the local communities.These increased expenditures may lead to the
availability of a wider range of goods and services.Competition from the new,high-wage
industries may also have the effect of raising salaries for other jobs.33
4.8.4.3 Tax revenues
During the construction period,San Juan County will continue to collect property taxes on the
unimproved value of the White Mesa·site (Sect.2.4.2.2).Sales tax will also be paid on mate-
rials purchased in connection with this project.The communities of Blanding,Monticello,and
Bluff each have the local option tax;outside of their boundaries the local tax goes to the
county (Utah State Tax Commission representative,personal communication,August 23,1978).
The applicant estimates that of the $18 million to be spent on equipment and supplies during
construction,$432,000 in sales tax will accrue to the State,and $81,000 to the locales in which
purchases are made.Of the local share,$13,500 will end up in the southeastern counties.The
ore buying stations operated by Energy Fuels Nuclear,Inc.,will also pay property taxes during
this period.
Area mines selling ore to the applicant's ore buying stations will be subject to as many as four
different taxes.Property tax will be levied at the normal county rate on twice the value of
average net proceeds plus the value of the land,if patented,and the personal property and
improvements onsite (Utah State Tax Commission representative,personal communication,July 14,
1978).A 1%mine occupation tax is levied on the gross value of all ore sold,less a standard
exemption.These revenues go to the State general fund.Sales tax will be paid on all purchases,
and a State corporate franchise tax of 4%on net taxable income will supply monies to the State's
Uniform School Fund.
Workers will be subject to Federal and State income taxes;the applicant estimates ~hat roughly
$1.3 million will go to the Federal and State governments from construction worker lncomes
(ER,p.4-23).Taxes on the salaries of nonbasic employees will contribute additional income tax
revenues.Workers will also pay sales tax on all purchases and ad valorem taxes on any property
owned in the area.Assuming nationwide expenditure patterns,38.3%of family income (ER,
p.5-31),$2.82 million for construction workers alone (ER,p.4-24),will be spent locally on
personal consumption expenditures.33 Sales tax on this will amount to $112,800 for the State and
$21,150 for the jurisdictions in which the purchases are made.
During operations,the mill will pay property taxes of approximately $456,000 to San Juan County
(ER,p.5-28).Two-thirds of this amount goes to the school district.Sales tax will be paid on
most equipment and materials purchased but not on the raw ore to be processed (Utah State Tax·
Commission representative,personal communication,August 23,1978).Finally,the Federal and
State governments will levy corporate franchise and income taxes.
If mining activity increases in the area the tax base of San Juan and neighboring counties will
increase,as will the revenues received by the State.Corporate-owned property would be subject
to the State franchise and Federal income taxes •.The ore buying stations and independently owned
mining operations would continue to pay taxes as outlined above.
San Juan County and the communities of Blanding,Monticello,and Bluff are also expected to
benefit from increased property taxes due to the construction of new commercial and residential
buildings and rising property values.Sales tax will be paid on roughly $4.5 million in personal
consumption expenditures in the area.33 Around $180,000 will go into the State treasury and
$35,000 will be returned to the county or municipality where purchases are made.
ring
.1-19
During both construction and operations,the State of Utah receives a substantial portion of t~e
ax revenues generated by the White Mesa mill and related activites.The State receives the
\ti re mine occupation and corporate franchi se taxes and spl its personal income taxes with the~ederal government.Sales tax revenues are split with local governments,with the majority of
the funds being routed to the State government (Table 4.13).
Table 4.13.Taxes related to theWhite M_Uranium Projects
ying
~.:~J ,~IO
.'ease
I the
'hich'he
.ng
'our
4,;d
lases,
Ite 's
Tax
PropertY tax
Sales tax
Mine occupation tax
Corporate franchise tax
Personal income tax
Construction period Operations period
Entity taxed Recipient of tax Entity taxed Recipient of tax
Unimproved San Juan County White Mesa San Juan County
mill site Mill
Ore buying San Juan and Ore buying San Juan and Wayne
stations Wayne counties stations counties
Uranium mines San Juan and neighboring Uranium mines San Juan and neighboring
counties counties
Property-owning San Juan County,Blanding,Property-owning San Juan County,
workers Monticello,and Bluff workers Blanding,Monticello,and
Bluff
Mill materials Utah,San Juan County.Mill supplies Utah,San Juan County,
Blanding,and Monticello Blanding,and Monticello
Mine supplies Utah,San Juan County,Mine supplies U~ah,SanJuan County,
Blanding,and Monticello Blanding,and Monticello
Worker purchases Utah,San Juan County,Worker purchases Utah,San Juan County,
Blanding,and Monticello Blanding,and Monticello
Uranium mines Utah Uranium mines Utah
Sqme uranium Utah Some uranium Utah
mines mines and
White Mesa mill
All workers Utah,United States All workers Utah,United States r"1I •I ~L...J
Ily
!tax
!rty
Inty
d on
11
ect
Iwned
al
;onal
Both San Juan County and its municipalities will receive property and sales tax revenues from the
mill and related activities (Table 4.13).Most purchases are likely to take place in Blanding
and Monticello,which will receive the local option sales tax.During the operations period,
these two communities may share as much as $35,000 annually from personal expenditures,which is
relatively minor compared to the $456,000 in property taxes which San Juan County will receive
from the mill itself.The ad valorem taxes paid to the county by area mines could also be
substantial when mining activity is at its peak.Increased property tax revenues will accrue
to the cities of Blanding,Monticello,and Bluff from new houses and businesses,but these added
revenues will be significantly less than the amounts received by San Juan County.
4.8.4.4 Public expenditures
Financing improvements in public services needed as a result of rapid population growth can place
a strain on local governments.Estimates of the required capital investment range from $1000
(ER,p.5-27)to $5000 for each additional resident.3~For the 1500 to 2000 in-movers expected
as a result of operating the White Mesa mill,this amount would be approximately $1.5 to$10 million.As much as another $1000 per person should be expected for operating costs,3~
adding an extra $1.5 to $2 million annually to the expenditures of local governments in the
Vicinity of the proposed mill.The capital and operating expenses listed above would be shared
by San Juan County and the communities of Blanding,Monticello,and B1ufi'.
Blanding and Monticello are expected to need improvements in their water and sewage systems as
well as in their health and public safety services.Blanding will probably require additionaled~ca~ion.faci1ities,and Monticello will need an expanded electricity distribution system.The
~JOrlty of the costs associated with these services will be borne by the impacted municipalities~hemselves.
~-2Q
Although the largest share of the new tax revenues generated by the White Mesa project will
accrue to San Juan County,the communities of Blanding,Monticello,and Bluff will receive some
of these monies.In addition,other sources are expected to provide funds for needed public
service improvements.Capital outlays for water and sewage system expansion are expected to
include Federal and State funds (Sect.4.8.2.2),and tap fees will aid in repaying local water
and sewer improvement bonds.35 It is the judgment of the staff that,given all the revenue
sources available,the impacted communities will be able to provide services for the expectedpopulationinfluxwithoutlong-range fiscal difficulties.
4.8.5 Transportation
Both heavy truck and automobile traffic will increase in the area as a result of the proposed
White Mesa Uranium Project;therefore,traffic congestion,road wear,road noise,and trafficaccidentswillalsoincrease.
During the peak construction period,250 workers are expected to drive to and from the mill site
each day.Because most workers are expected to live north of the site in the cities of Blanding
and Monticello,traffic will increase substantially on U.S.Route 163.The 100 additional
nonbasic workers expected during this time will also add to traffic on area roads,although a
large portion of these employees are likely to live and work in the same community.Nonwork
trips will also increase on area roads,as will traffic within the communities of Blanding,
Monticello,and Bluff.
During the operations period,the number of automobile trips between Blanding and the mill site
will decrease,but auto traffic in the surrounding area will rise.About 85 hourly mill
employees plus 20 salaried staff and 10 buying station employees will travel to the White Mesa
mill daily along U.S.Highway 163.In addition,approximately 220-250 new miners will be
employed in the area and their trips between home and work will considerably increase traffic
volumes.Finally,about 600 new workers in the nonbasic sector will add to local traffic,even
though many will reside in their community of employment.
Heavy truck traffic will also increase substantially in the project area.During the operations
period,when area mining is at expected peak levels,approximately 53 round trips per day will be
made between area mines and the Blanding buying statioQ.Another 17 roun~trips between other
mines and the Hanksville station and an additional 15 round trips between the Hanksville and
Blanding stations will occur each day (ER,p.5-34).
The heaviest truck traffic will take place on U.S.Route 163 and Utah Route 95,but U.S.
Route 666 and Utah routes 262, 276,263,and 24 will also be affected.In addition to these
paved roads,secondary roads are also expected to handle up to 15%of total truck traffic (ER,
p.5-34).
4.8.6 Impact mitigation
Energy Fuels Nuclear,Inc.,has expressed concern about maintaining a stable work force and
has instituted programs to mitigate potential negative impacts on the project area.The appli-
cant has cooperated with a Denver-based developer to provide additional housing for expected in-
migrants in Blanding.Preliminary plan approval was received in August 1978 for a 117-space
mobile home park and a 242-unit single-family subdivision (Sect.4.8.2.1)on land that was
purchased by Energy Fuels Nuclear for resale to the developer (Vice-President for Operations,
Energy Fuels Nuclear,Inc.,personal communication,June 27,1978).These dwelling units will
satisfy a large portion of the total mill-induced housing need.Company benefits,such as an
annual cash bonus and profit-sharing plan,encourage job stability.
Public action is also being planned to mitigate prospective social impacts at the area of the
proposed mill.Section 4.8.2.2 details the steps being taken by local governments to provide
additional public services to meet expected population increases.
Additional actions can be taken to further mitigate potential mill-induced impacts.Hiring
unemployed area residents can keep the total population influx down and simultaneously reduce
local unemployment.Negative impacts can be diminf~hed by ensuring that planned improvements to
public services are made before anticipated growth occurs.Early solicitation of Federal and
State aid and early issuance of local bonds can provide funds for needed expansions before
existing services become inadequate.
Jme
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,
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The ore trucks passing between the Hanksville and Blanding stations,and possibly additional
mill-bound trucks originating at area mines,will travel along Utah Highway 95,which also
provides access to the Natural Bridges National Monument.According to the Utah Department
of Transportation,this increased activity could affect traffic movement during the summer
monthS,but the extent of the impact is not currently quantifiable.The applicant will attempt
to reduce possible negative impacts on area traffic flow by providinw acceleration lanes
and turnouts where the traffic will enter and exit the project site.2
Both San Juan County and its municipalities have the fiscal responsibility of providing needed
services for new residents.Neither these costs nor the tax revenues generated by the White Mesa
mill and related activities,however,are evenly distributed.The communities of Blanding and
Monticello face substantial capital and operating costs for providing for new residents.A
fraction of the additional taxes accruing to San Juan County and the State of Utah could be
distributed by means of a revenue-sharing arrangement based on the distribution of the costs of
new required services.
Although it is certain that residential and commercial growth will occur in the communities of
Blanding,Monticello,and Bluff,the form of this growth is difficult to predict.Advance land-
use planning should ensure that the spatial structure of eventual growth is compatible with
cOlTll1unity goal s.
4.8.7 Conclusions
Both positive and negative socioeconomic impacts are probable as a result of the proposed White
Mesa Uranium Project.The reduced unemployment,higher per capita income,increased tax base,
and greater availability of goods and services,all of which are likely to accompany the mill and
its related activities,could be considered benefits for the project area.On the negative side,
public service expenditures will rise,existing cultural and political balances may be changed,
and road traffic and associated impacts will increase as a result of increased road use.Although
most project-related socioeconomic impacts can be mitigated,the distribution of impacts and
responsibility for mitigation of the impacts may not coincide.The importance of a coordinated,
joint planning effort by incoming industrial developers and local and state governments should be
emphasized in order to mitigate some of the adverse impacts of the rapid population change
expected in the Blanding area.The staff has concluded that the potential benefits of the pro-
posed project outweigh the asscciated costs.
-t-22
REFERENCES FOR SECTION 4
1.U.S.Environmental Protection Agency,Compilation of Air Pollutant Emission Factors.2r.d
ed.,Office of Air Quality Planning and Standards,Research Triangle Park,N.C.,1976.
2.U.S.Environmental Protection Agency,Fugit~ve Dust -Sources,Emissions.and Control.
Office of Air Quality.P1anning and Standards,Research Triangle Park,N.C.,1973.
3.Dames and Moore,"Response to Coments from the U.S.Nuclear Regulatory Commission,
June 7,1978,White Mesa Uranium Project Envi ronmenta1 Report,"Denver,June 28,1978.
4.Dames and Moore,"Supplemental Report,Meteorology and Air Qual ity,Environmental Report,
White Mesa Uranium Project,San Juan County,Utah,for Energy Fuels Nuclear,Inc.,"Denver,Sept.6,1978.
5.State of Utah,Division of Health,Ai~Conservation Regulations.Salt Lake City,May 22,1977 .
6.Fed.Regist.•June 19,1978...7.U.S.Environmental Protection Agency,Assessment of Environmental Aspects of Uranium
Mining and Milling.Report EPA-600/7-76-036,Washington,D.C.,1976.
8.Dames and Moore,"Responses to Comments Te1ecopied from NRC to Energy Fuels Nuclear,
25 September 1978,"Denver,Oct.4,1978.
9.State of Utah,Division of Wildlife Resources,letter to Jim Chadwick,Dames and Moore,July 27,1977;
10.U.S.Environmental Protection Agency,Effects of Noise on Wildlife and Other Animals.
Report NT1D300.5,Office of Noise Abatement and Control,Washington,D.C.,1971.
11.Energy Fuel s Nuclear,Inc.,"Source Material License Appl ication,White Mesa Uranium
Mill,Blanding,Utah,"Energy Fuels Nuclear,Inc.,Denver,Sept.26,1978.
12."Endangered and Threatened Wildlife and Plants,"Fed.Regist.41(117):24524-24572 (l976).
13.S.L.Welsh,N.D.Atwood,and J.L.Reveal,"Endangered,Threatened,Extinct,Endemic,
and Rare or Restricted Utah Vascular Plants,"Great Basin Nat.35(4):327-376 (1975).
14."Endangered and Threatened Wildlife and Plants,"Fed.Regist.42(135):36419-36431 (1977).
15.R.L.Linder and C.N.Hillman,Proceedings of the Black-Footed Ferret and Prairie.Dog
Worksh~p.September 4-8.1973.South Dakota State University,Brookings,1973.
16.B.R.Metzger,"Nuclear Regulatory Corrmission Occupational Exposure Experience at Uranium
P1 ants,"Conference on Occupational Health E:r:perienae with Uranium.Report ERDA-93,
Washington,D.C.,1975.
17.International Atomic Energy Agency,Safety Series No.43.Manual on Radiation Safety in
Uranium and Thorium Mines and MiZls.IAEA,Vi enna,1976.
18.Presentation to the Environmental Subcorrmittee of the Advisory Subcommittee on Reactor
Safeguards,Occupational Radiation Exposure Control at Fuel Cycle Facilities,26 January
1978,by the Chief,Fuel Processing &Fabrication Branch,U.S.Nuclear Regulatory
Commission.
19.S.I.Auerbach."Ecological Considerations in Siting Nuclear Plants.The Long-Tenn Biota
Effects Problem,"Nual.Saf.12:25-35 (1971).
20.Proceedings of the Enviranmental Plutonium Symposium.Report LA-4756,Los Alamos
Scientific Laboratory,Los Alamos,N.Hex.,1971,and A Proposed Interim Standard for
Plutonium.Report LA-5483-MS,Los Alamos Scientific·Laboratory,Los Alamos,N.Hex.,1974.
21.Enewetak Radiological Survey.USAEC Report NVO-140,Nevada Operations Office.~as Vegas,
Nev.•1973.
22.N.A.Frigerio.K.F.Eckennan,and R.S.Stowe,"Background Radiation as a Carcinogenic
Hazard."Rad.Res.62:599 (1975).
4-23
23.A.H.Sparrow et al.,"Chromosomes and Cellular Radiosensitivity,".=;ad.i=es.32:915(1967).
24.Radioaativity in the Marine Environment,Report of the Committee on Oceanography,National
Academy of Sciences-Nationa1 Research Council,Washington,D.C.,1971.
25.R.J.Garner,"Transfer of Radioactive Materials from the Terrestrial Environment to
Animals and Man,"Environ.Contro~2:337-385,1971.
26.S.E.Thompson,Co~~entration Faators of Chemiaa~EZements in Edib~e Aquatia Organisms,USAEC Report UCRL-50564,rev.1,October 1972.
27.Mountain West Research,Inc.,Construation Worker Profi~e,Old West Regional Commission,
December 1975.
28.Erik J.Stenehjem and James E.Metzger,A Framework for Projeating Emp~oyment and PopuZa-
tion Changes Aaaompanying EnQrgy Development,Argonne National Laborato~y,ArQonne.Ill .•
August 1976.
29.Rapid Growth from Energy Projeats:Ideas for State and Loaal Aation,Department of Housing
and Urean Development,Office of Community Planning and Development,1976.
30.John S.Gilmore and Mary K.Duff,Boom Town Growth Management:A Case Study of Roak
Springs-Green River,Wyoming,Westview Press,Boulder,Colo.,1975.
31.The County Year Book,1977,National Association of Counties and International City Manage-
ment Association,Washington,D.C.,1977.
32.Energy Fuels Nuclear,Inc.,"Responses to Comments on White Mesa Project DES,"March 6,
1979.
33.Keith D.Moore,Diane M.Hanmond,and John S.Gilmore,"Socioeconomic Considerations,"
Chap.5 in Administrator's Guide for Siting and Operation of Uranium Mining and MilZing
Faailities,Stone and Webster Engineering Corp.,May 1978.[Prepared for Western Inter-
state Energy Board under Contract No.68-01-4490 to U.S.Environmental Protection Agency.][
34.Keith D.Moore,Finanaing Options for Cormrunities Near Large Energy Development.s,1978.
35.Housing Program for Energy Fuels Nualear,Ina.:B~anding,Utah,Taylor &Associates,
Denver,Colo.,no date.
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5.ENVIRONMENTAL EFFECTS OF ACCIDENTS
The occurrence of accidents related to operation of the White Mesa mill will be minimized
through the proper design,manufacture,and operation of the process components and through
a quality assurance program designed to establish and maintain safe operations.In accordance
with the procedures set forth in the appropriate regulations,Energy Fuels Nuclear,Inc.,has
submitted applications containing descriptions of the facility design,the organization of
the operation,and the quality assurance program.These documents,together with the
Environmental Report and supplements,have been reviewed by various agencies to ensure that
there is a basis for safe operations at the site.Moreover,those agencies will 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 in operations similar to those proposed by the applicant.In
this assessment,therefore,accidents that might occur during milling operations have been
postulated and their potential environmental impacts evaluated.Section 5.1 deals with
postulated accidents involving radioactive materials and Sect.5.2 deals with those not
involving radioactive materials.The probabilities of occurrence and the nominal consequences
are assessed,using the best available estimates of probabilities and realistic assumptions
regarding release and transport of radioactive materials.Where information adequate to a
real istic evaluation was unavailable,conservative assumptions were used to compute environmental
impacts.Thus,the actual environmental impacts of the postulated accidents would be less,
in some cases,than the effects predicted by this assessment.
Exposure pathways considered in estimating dose commitments resulting from accidental releases
were inhalation and immersion in contaminated air.It was assumed that exposure through the
ingestion and surface pathways could be controlled if necessary.
5.1 MILL ACCIDENTS INVOLVING RADIOACTIVITY
The specific activities of the radioactive materials handled at the mill are extremely low:
=10-9 Ci/g for the ore and tailings and ~10-6 Ci/g for the refined yellow cake products.*The
quantities of materials handled,on the other hand,are relatively large:773 metric tons
(MT)of yellow cake per year,representing ~472 Ci of radioactivity.To be of concern,these
very low specific activities require the release of exceedingly large quantities of materials;
driving forces for such releases will not exist at the proposed White Mesa mill.
Guidelines have not been published for the consideration of accidents at uranium mills;there-
fore,the postulated plant accidents involving radioactivity are considered here in the follow-
ing three categories:j'
1.trivial incidents (i.e.,those not resulting in a release to the environment),
2.small releases to the environment (relative to the annual release from normal operation),
and
3.large releases to the environment (relative to the annual release from normal operations).
*In contrast to the relatively high specific activities of a number of prominent radio-
nuclides (i.e.,~10-1 Ci/g for p1utonium-239 and ~lO-3 Ci/g for coba1t-60).
5-1
5-2
Trivial incidents include spills,ruptures in tanks or plant piping containing solutions or
slurries,and rupture of a tailings disposal system pipe in which the tailings slurry is
released into the tailings pond.Small releases include failure of the air cleaning system
serving the concentrate drying and packaging area,a fire or explosion in the solvent extraction
circuit,and an explosion in the yellow cake dryer.Large releases include a major tornado.
For most of the postulated cases resulting in a release to the environment,the analysis gives
the estimated magnitude of the release,the corresponding maximum individual dose at various
distances from the mill.and the estimated annual likelihood of occurrence.The latter
estimates are based ona diversity of sources,including incidents on record,chemical industry
statistics,and failure prediction methodologies.Data and models for the behavior of radiation
in accident situations were taken from AIRDOS-II computer code 1 and from the International
Commission on Radiological Protection (ICRP)2 and were updated by dose conversion factors
based on the lung model of the ICRP Task Group on Lung Dynamics.3
During the three decades of nuclear facility operation,the frequency and severity of accidents
have been markedly lower than in related industrial operations.The experience gained from
the few accidents that have occurred has resulted in improved engineering safety features and
operating procedures,and the probability of the occurrence of similar accidents in the future
is very low.Based on analysis,it is believed that even if major accidents did occur there
would probably not be a significant offsite release of contamination and that radiological
exposures would be too small to cause any observable effect on the environment or any deleter-
ious effect on the health of the human population.
5.1.1 Trivial incidents
The following accidents.due to human error or equipment failure.would not result in the
release of radioactive materials to the environment.
5.1.1.1 Minor leakage of tanks or piping
Uranium-bearing slurries and solutions will be contained in several tanks comprising the
leach.washing,precipitation and filtration,and solvent extraction stages of the mill cir-
cuit.Human error during the filling or emptying of tanks or the failures of valves or piping
in the circuit would result in spills that might involve the release of several hundred pounds
of contained uranium to the room;however,the overflow will be collected in sumps designed
for this type of spill,and sump pumps will be used to return the materials to the circuit.
Therefore,a rupture in a process tank or a leaking pipe would not affect the environment.
5.1.1.2 Major pipe or tank rupture
All mill drainage.including that from chemical storage tanks,will flow into a catchment
basin upstream from the tailings impoundment site.The mill will deliver approximately
75.3 MT (83.3 tons)of solids per hour and approximately 76.1 m3 [75.95 MT (84.02 tons)]of
solution per hour to the tailings cell.Should the rupture ofa pipe in the tailings distribu-
tion system occur,the liquid would flow into the catchment basin where it could be pumped to
the tailings cell.Chemicals could be recovered,transferred to the tailings cell,or neu-
tralized in the catchment basin.Residue from a slurry loss would be cleaned up and the con-
taminated soil removed to the tailing retention area.
5.1.2 Small releases
The following accidents,due to human or equipment failure,would release small quantities of
radioactive materials to the environment.The estimated releases.however,are expected to be
small in comparison with the annual release from normal operations.
.--r-"
j
;~.~
:~..)1[",1
ion
iJ
e
5-3
5.1.2.1 Failure of the air cleaning system serving the yellow cake drying area
Because of system designs,this type of accident is unlikely to occur or go undetected.A
losS of water pressure to the scrubber or the failure of the fan drive would sound an alarm.In
the event of electrical or mechanical failure,however,it was estimated that approximately
14.83 kg (27.97 1b)of U309 would be lost from the stack over an 8-hr shift.All of this
insoluble uranium was assumed to be in the respirable size range:
Because the meteorological data at the time of the postulated accident is unpredictable,it
was assumed that for this stack release the conservative meteorological conditions of 1 m/sec
wind speed and a Pasquill type-B stability would exist.It was also assumed that all the
material was distributed over a single 22.5°sector.The maximum dose commitments to the
nearest resident [4.8 km (3 miles)from the point of·release]were as follows:total-body,
0.0009 mil1irem;bone,0.026 millirem;lung,0.32 millirem;and kidney,0.008 millirem.The
maximum dose commitments to the potential nearest resident [1.6 km (1 mile)from point of
release]were as follows:total-body,0.009 millirem;bone,0.25 millirem;lung,3.0 millirems;
and kidney,0.072 millirem.
5.1.2.2 Fire in the solvent extraction circuit
The solvent extraction circuit will be located in a separate bUilding that is isolated from other
areas due to the large quantities of kerosene present.From chemical industry data,the
probability of a major fire per plant-year4 is estimated to be 4 x 10-4.However,at least two
major solvent extraction circuit fires are documented in the literature,one of which destroyed
the original solvent extraction circuit at one mill in 1968.4 There have been approximately
540 plant-years of mill operation in the United States,equivalent to about 320 plant-years
handling 390,000 metric tons of ore per year.Thus,judging from historical incidents,the
likelihood of a major solvent extraction fire at the proposed mill is assumed to fall in the
range of 4 x 10-4 to 6 X 10-3 per year.
In the event of a major fire,it is conservatively assumed from previous estimates that
1%of the maximum uranium inventory,or approximately 4.5 kg (10 lb),would be released into
the environment.s,6 It was assumed that the conservative meteorological conditions of 1 m/sec
wind speed and a Pasquill type-D stability would exist for the ground-level release.It was
also assumed that all the material was distributed over a single 22.5°sector.The maximum
dose commitments to the nearest resident [4.8 km (3 miles)from point of release]were total-
body,0.0004 mil1irem;bone,0.01 millirem;lung,0.122 millirem;and kidney,0.003 millirem.
The maximum dose commitments to the potential nearest resident [1.6 km (1 mile)from point of
release]were total-body,0.005 millirem;bone,0.15 millirem;lung,1.8 mi1lirem;and kidney,
0.04 millirem.
5.1.3 Large releases
Incidents that might release large quantities of radioactive materials to the environment com-
pared with annual releases from normal operations are considered in this section.By virtue of
complex and highly variable dispersion characteristics,however,the individual impacts will not
necessarily be proportional to the total amount of radioactivity released to the environment.
5.1.3.1 Tornado
,<L
The probability of occurrence of a tornado in the 1°square in which the White Mesa mill is
located is negligible.Using closest available data,the probability is approximately 8 x 10-5
per year.7 The area is categorized as region 3 in relative tornado intensity8 [i.e.,for a
"typical"tornado,the wind speed is 385 km/hr (239 mph/hr)of which 305 km/hr (190 mph/hr)is
rotational and 79 km/hr (49 mph/hr)is translational].None of the mill structures are designed
to withstand a tornado of this intensity.
The nature of the milling operation is such that little more could be done to secure the facility
with advance warning than could be done without it.Accordingly,a "no-warning"tornado was
postulated.Moreover,because it is not possible to accurately predict the total amount of
material dispersed by the tornado,a highly conservative approach was adopted.Because the
5-4
yellow cake product has the highest specific activity of any material handled at the mill and as
much as 45 MT of product may be accumulated prior to shipment,it is assumed that the tornado
lifts 4550 kg (10,031 1b)of yellow cake.
A conservative model,which assumes that all of the yellow cake is in respirable form,was used
for the dispersion ana1ysis.9 The model assumes that all of the material is entrained in the
tornado as the vortex passes over the site.Upon reaching the site boundary,the vortex
dissipates,leaving a volume source to be dispersed by the trailing winds of the storm.The
material is assumed to exist as a volume source representative of the velocities of the tornado,
and it disperses through an arc of 45°.Due to the small particle sizes postulated,the
settling velocity is assumed to be negligible.
The model predicts a maximum exposure at a distance of approximately 4 km (2.5 miles)from the
mill,where the 50-year dose commitment to the lungs of an individual is estimated to be
approximately 1.1 x 10-7 rem.The 50-year lung dose commitment as a function of distance is
plotted in Fig.5.1.
10-7
!...'"0C
'0-8
10.t03 402
DISTANCE (m.ttn)
Fig.5.1.Tornado damage:50-year dose commitment to lungs.
5.1.3.2 Tailings dam failure
Because of the multiple cell design (Sect.3.2.4.7;Fig.3.4),the tailings retention embankment
design (in accordance with Regulatory Guide 3.11),the short period of cell.use,and the
low head [<9 m (30 ft)],a large release of tailings and tailings fluid is not credible.Small
releases would be retained by downstream catchment ponds.
5.2 NONRADIOLOGICAL ACCIDENTS
The potential for environmental effects from accidents involving nonradioactive materials at
the White Mesa mill is small.Failure of a boiler supplying process steam could release
low-pressure steam to the room,possibly causing minor injuries to workers,but would not
involve the release of chemicals or radioactive materials to the environment.Forced-air
ventilation systems are provided in several stages of the process to dilute the chemicalvaporsemittedandprotecttheworkersfromthehazardousfumes.Failure of these ventilation
systems might result in the interim collection of these vapors in the building air.Such a
failure might affect individual plant employees but would have no persistent effect on the
environment.
~;'-:
!d L
loL;
5-5
mber of chemical reagents used in the process will be stored in relatively large 'quantities
An~he site.Minor leaks and spillage of reagents will be captured in sumps and returned to
on mill circuit.Major spills could flow across the mill site and enter the drainaget~eersion ditch protecting the tailings impoundment.The staff recommends either the~l\truction of'dikes around storage tanks or the construction of a catchment basin below~?~mill for any major spills.Spillage in the mill will be washed down and pumped back~~to the mill circuit.
he only chemical that might seriously affect the environment is ammonia.A break in the
T ternal piping of the anhydrous ammonia tank would not result in a release,because,upon a~~op in pressure,an excess flow valve would automatically close,thus preventing any loss.
The line carrying ammonia to the storage tank from the tank truck possibly could be ruptured,
'n which case the release rate would be limited to 100 g/sec of the vapor.10 Beyond a dis-~ance of 10 km (6 miles),the resulting concentration would be below the 600 ~g/m3 short-term
air quality standard derived from State of Colorado regulations,the most restrictive current
re ulation.11 Beyond a distance of 700 m (2300 ft)from the mill,concentrations of ammoniafr~m the accident would be less than the 40,000 ~g/m3 needed to produce a detectable odor and
would not be noticeable by offsite residents;these concentrations would pose no health risk
because they would be less than the 69,000-ug/m3 limit for prolonged human exposure.12
Thus,the relea~ed ammonia would not be noticed by offsite residents and would pose no health
risk to the envlronment.
The solvent extraction and dryer units in the vanadium circuit will be similar to the
corresponding units in the uranium circuit with respect to fire and explosion potential
(Sect.5.1).Vanadium pentoxide (V20S)and/or organic complexes of vanadium would be
released as would very minor amounts of thorium-230 and uranium,which may also be present
in the organic solvent.Thorough washing of contaminated areas would minimize the risk
to mill employees.The general public should receive no significant health effects from
accidents in the vanadium circuit.
5.3 TRANSPORTATION ACCIDENTS
Transportation of materials to and from the mill can be broken down into three categories:
(1)shipments of ore from the mine to the mill,(2)shipments of refined yellow cake from the
mill to the uranium hexafluoride conversion facility,and (3)shipments of process chemicals
from suppliers to the mill.An accident for each of these categories has been postulated
and analyzed.The results are given in the following discussion.
5.3.1 Shipments of yellow cake
Refined yellow cake product is generally packaged in 55-gal,18-gage·drums holding an average
of 364 kg (800 lb)and classified as Transport group III Type A packaging (49 CFR Parts 170-189
and 10 CFR Part 71).It .is shipped by truck an average of 2100 km (1300 miles)to a conversion
plant,which transforms the yellow cake to uranium hexafluoride for the enrichment step of the
light-water-reactor fuel cycle.An average truck shipment contains approximately 45 drums,
or 16 MT (17.5 tons),of yellow cake.Based upon the White Mesa mill capacity of 618,200 MT
(680,000 tons)of ore annually and a yellow cake Yield of 773 MT (850 tons),an average of
approximately 48 such shipments are required annually.
From published accident statistics,13,14 the probability of a truck accident is in the range of
1.0 x 10-6 to 1.6 X 10-6 per kilometer (1.6 x 10-6 to 2.6 X 10-6 per mile).Truck accident
statistics include three categories of traffic accidents:collision,noncollision,and other
event.Collisions involve interactions of the transport vehicle with other objects,whether
moving vehicles or fixed objects.Nonco11isions are accidents in which the transport vehicle
leaves the transport path or deviates from normal operation in some way,such as by rolling
over on its top or side.Accidents classified as other events include personal injuries
suffered on the vehicle,records of persons falling from or being thrown against a standing
vehicle,cases of stolen vehicles,and fires occurring on a standing vehicle.The likelihood
5-6
of a truck ~hipment of yellow cake from the mill being involved in an accident of any type
during a one-year period is approximately 0.13.
The ability of the materials and structures in the shipping package to resist the combined
physical forces arising from impact,puncture,crushing,vibration,and fire depends on the
magnitude of the forces.These magnitudes vary with the severity of the accident,as does
the frequency with which they occur.A generalized evaluation of accident risks by NRC
classified accidents into eight categories,depending upon the combined stresses of impact,
puncture,crushing,and fire.1S On the basis of"this classification scheme,conditional
probabilities (i.e.,given an accident,the probabilities that the accident is of a certain
magnitude)of the occurrence of the eight accident severities were developed.These
fractional probabilities of occurrence for truck accidents are given in Column 2 of Table 5.1.
To assess the risk of a transportation accident,the fraction of radioactive material released
in an accident of a given severity must be known.Two models are postulated for this
analysis,and the fractional releases for each model are shown in Columns 3 and 4 of Table 5.1.
Model I assumes complete loss of the drum contents;Model II,based upon actual tests,assumes
partial loss of the drum contents.The packaging is assumed to be type A drums containing
low specific activity (LSA)radioactive materials.Considering the fractional "occurrence and
the release fractions (loss)for Model I and Model II,the expected fractional release in
any given accident is approximately 0.45 and 0.03 respectively.
Tabla 5.1.FractiOMI probabilitia.at
occurrence and corresponding package rele_
fractions for each at the reta_modal.for LSA
-ml tyPll A containen involvacl
in truck eccidentl
Accident Fractional
severity occurrence Model I Model II
category of accident
I 0.55 0 0
II 0.36 1.0 0.01
III 0.07 1.0 0.1
IV 0.016 1.0 1.0
V 0.0028 1.0 1.0
VI 0.0011 1.0 1.0
VII 8.SE·S 1.0 1.0
VIII 1.SE-S 1.0 1.0
Source:U.S.Nuclear ReQulatory Commis-
sion,Final Environmmtal Statemmt "on the
Transportation of RadioactiVtl Materials by Air
and Other Models,Report NUREG-0170,Of-
fice of Standards Development,February 1977
(draft).
Model I and Model II estimate the quantity of yellow cake released to the atmosphere in the
event of a truck accident to be about 7400 kg (16,200 1b)and 500 kg (1100 1b)respectively.
Most of the yellow cake released from the container would be deposited directly on the ground
in the immediate vicinity of the accident.Some fraction of the released material,however,
would be dispersed to the atmosphere.Expressions for the dispersal of similar material to
the environment based on several years of actual laboratory and field measurements have been
developed.14 The following empirical expression was derived for the dispersal of the material
to the environment via the air following an accident involving a release from the sontainer:
f =0.001 +{4.6 x 10-4 )[1 -exp{-0.15ut)]u1•78 ,
I
I !
I
I
I,I
!
i ""I"I
I!
5-7
the fractional airborne release,
:<=
t =
the wind speed at 15.2 m (50 ft)expressed in mlsec,
the duration of the release,in hours.
l p.-;-~
ec"C~
.l.
esr'
d L~
d
I this expression,the first term represents the initial "puff"immediately airborne when
ne container is in an accident.Assuming that the wind speed is 5 mlsec (10 mph)and that~~hr are available for the release,the environmental release fraction is estimated to be
x 10-3•If insoluble uranium (all particles of which are in th~respirable size range)~assumed and a population density of 160 people per square mile (which is characteristic of~~e eastern United States)is supposed,16 the consequences of a truck accident involving a
hi ment of yellow cake from the mill would be a 50-year dose commitment*to the general~op~lation of approximately 13 and 0.9 man-rems to the lungs for Models I and II respectively.
In a recent accident (September 1977),a commercial truck carrying 50 steel drums of uranium
oncentrate overturned and spilled an estimated 6800 kg (15,000 lb)of concentrate on the
cround and in the truck trailer.Approximately 3 hr after the accident,the material was~overed with plastic to prevent further release to the atmosphere.Using the above formula
and values of wind speed for a fractional airborne release for this 3-hr duration of release,
approximately 56 kg (123 lb)of U30S would have been released to the atmosphere.The
consequence of this accident would be a 50-year dose commitment to the general population
of 11 man-rems for a population density of 160 people per square mile.The consequence for
the accident area,where the population density is estimated to be 2.13 people per square
mile,would be a 50-year dose commitment of 0.146 man-rem,which can be compared to a 50-year
integrated lung dose of 19 man-rems from the natural background.
The applicant will submit to the NRC an emergency-action plan for yellow cake transportation
accidents.This emergency-action plan is intended to ensure that personnel,equipment,and
materials are available to contain and decontaminate the accident area.
5.3.2 Shipments of ore to the mill
Hanksville and Blanding are ore buying stations servicing small-and intermediate-sized mines
throughout southeastern Utah and southwestern Colorado.Because of the small sizes of the
mines,shipments of ore will be sporadic;therefore,the average shipping distance for the
ore will vary throughout the 1ife of the project.The app1i cant estimates the radi i of the
Hanksville and Blanding buying station service areas to be 160 km (100 miles)and 201 km
1125 miles)respectively.Ore collected at the Hanksville station will be shipped an additional
193 km (120 miles)to the mill at Blanding.Based on projected capacities of the two ore
buying stations,approximately 25%of the total ore requirements would be supplied by the
Hanksville station.On this basis the ore will be shipped an average of 258 km (160 miles).
This value is an upper limit because most of the mines will be well within the service areas.
To deliver 618,200 MT (680,000 tons)of ore in trucks with a 30-ton capacity would require
22,670 trips per year,or a total of 5.84 x 106 vehicle-km (3.63 x 106 vehicle-miles).For
the accident probability cited in the previous section,1.0 x 10-6 to 1.6 X 10-6 accidents per
kilometer (1.6 x 10-6 to 2.6 x 10-6 per mile),accidents involving ore trucks would bccur at
the rate of 7.6 per year.However,because of the low specific activity of the ore and the
ease with which the contaminant can be removed,the radiological impact is considered to beinsignificant.
5.3.3 Shipments of chemicals to the mill
Truck shipments of anhydrous ammonia to the mill,if involved in a severe accident,could
conceivably result in a significant environmental impact.Approximateiy 17 shipments of
anhydrous ammonia will be made annually in 18 MT (20-ton)loads from a supplier located
approximately 320 km (200 miles)from the mill.
*Doses integrated over a 50-year commitment following exposure.
5-2
The annual U.S.production of anhydrous ammonia shipped in that form is approximately
6.9 x 106 MT (7.6 x 106 tons).About 26%of the shipments are made by truck (the remainder by
rail,pipeline,and barge).If the average truck shipment is 19 MT (21 tons),the approximately
93,000 truck shipments of anhydrous ammonia are made annually.According to accident data
collected by the Department of Transportation,there are about 140 accidents per year
involving truck shipments of anhydrous ammonia.For an estimated average shipping distance
of 560 km (350 miles),the resulting accident frequency is roughly 2.7 x 10-6 per kilometer
(4.3 x 10-6 per mile).Data from the Department of Transportation also reveal that a
release of ammonia [an average of 770 kg (1700 lb)],occurred in approximately 80%of the
reported incidents and that an injury to the general public occurred in roughly 15%of the
reported incidents that involved a release (most of the injuries were sustained by the driver).
Utilizing these data,the probability of an injury to the general public resulting from an
average shipment of anhydrous ammonia is roughly 3 x 10-7 per kilometer (4.8 x 10-7 per mile).
This estimate i-s probably too high for shipments near the White Mesa mill because of the
relatively low population density.Nevertheless,if this estimate is used,the likelihood of
an injury to the general public resulting from shipments of ammonia to the mill is predicted toberoughly1.6 x 10-3 per year.
Sulfuric acid shipments to the White Mesa mill will amount to about eight truck loads per day.
Tentative plans are to ship acid into Moab or Thompson,Utah,by rail;the acid will then be
loaded into specifically designed tank trucks for transportation to the White Mesa mill.Moab
is about 130 km (80 miles)from the site.Using statistical data from Sect.5.3.2,less than
0.1 accident per year should be observed.Because sulfuric acid is not volatile,the risk to
the general public is no greater than that from other collisions.
Amine shipments will be made by truck into the White Mesa mill.Only one truck load about
every 45 days will be required,and the risk of injury to the general public should be no greater
than 8 x 10-4 per year.Transport of all such commodities will be in accordance with all
applicable State and Federal rules and regulations.
wj}l
r~bY
m~~,e1yI:'
~ver).
ofecr::o
~,,;
day.
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5-9
REFERENCES FOR SECTION 5
1.R.E.Moore,The AIRDOS-II Computer'Code fo:r Estimating Radiation Dose to Man for'
Air'Dorne Radionuclides in Ar'eas SUr':rounding Nuclear'Facilities,Report ORNL-5245,
Oak Ridge National Laboratory,Oak Ridge,Tenn.,1977.
2."Recommendations of the International Commission on Radiological Protection,Report of
Committee II on Permissible Dose for Internal Radiation,"Health Phys.3:1-380 (1960).
3.ICRP Task Group on Lung Dynamics,"Deposition and Retention Models for Internal Dosimetry
of the Human Respiratory Tract,"Health Phys.12:181 (1966).
4.Directorate of Regulatory Standards,U.S.Atomic Energy Commission,Envir'onmental Su:rvey
of the U:ranium Fuel Cycle,Report WASH-1248,April 1974.
5.Battelle Northwest Laboratories,Conside:rations in the Assessment of the Consequences of
Effluents f:rom Mixed Oxide Fuel Fab:rication Plants,Report BNWL-1697,Richland,
Washington,June 1973.
6.Directorate of Licensing,U.S.Atomic Energy Commission,Pr'oposed Final Envi:ronmental
statement,Liquid Metal Fast B:reede:r Reacto:r P:rog:ram,Report WASH-1535,December 1974.
7.H.C.S.Thom,"Tornado Probabilities,"Mon.Weathe:r Rev.91:730-737 (1963).
8.E.H.Markee,Jr.,and J.G.Becker1ey,Technical Basis fo:r Inte:rim Regional To:rnado
C:rite:ria,Report WASH-1300,U.S.Atomic Energy Commission,May 1970.
9.F.C.Kornegay,Ed.,Condensed Pr'oceedings of the Symposium on the Dispe:rsion of
Par'ticulate Matte:r by Natu:ral Vo:rtices,held at A:rgonne National Labo:rato:ry,A:rgonne,
Illinois,August 1976 (in preparation).
10.U.S.Nuclear Regulatory Commission,Final Envi:ronmental Statement Related to Ope:ration of
Beal'C:reek Project,Docket No.40-8452,June 1977.
11.Colorado Air Pollution Control Commission,"Regulation to Control the Emissions of
Chemical Substances and Physical Agents,"Regulation No.8,effective May 1,1974.
12.F.A.Patty,Indust:rial Hygiene and Toxicology,2d ed.,rev.,vol.II,Toxicology,
David W.Fassett and Dan Irish,Eds.,Interscience,New York,1963.
13.Directorate of Regulatory Standards,U.S.Atomic Energy Commission,Envi:ronmental Su:rvey
of T:ranspo:rtation of Radioactive Mate:rials to and f:rom NucZea:r Plants,Report WASH-1238,
December 1972.
14.Battelle Northwest Laboratories,An Assessment of the Risk of T:ranspo:rting Plutonium
Oxide and Liquid Plutonium Nit:rate by T:ruak,Report BNWL-1846,Richland,Washington,
August 1975.
15.U.S.Nuclear Regulatory Commission,Final Environmental Statement on T:ransportation of
Radioactive Mate:rials by Ail'and Other Modes,Report NUREG-0170,February 1977 (draft).
16.U.S.Bureau of the Census,Statistical Abstract of the United States:1976,97th ed.,
1976.
----------------------------
6.MONITORING PROGRAMS
6.1 AIR QUJlLITY
particulate matter,measured by dustfall samplers,and sulfation rates,measured by lead
dioxide plates,~er~mo~itored at four locations on the proj~ct site for one year beginning in
March 1977.Beg1nn~ng 1n October 1977,t~tal suspended partlcula~es were measured for five
months at one 10cat10n by a high-volume a1r sampler.The ore bUY1ng station located on the
project site (Fig.2.10)began operation in May 1977.
An estimate of S02 concentrations (ppm)was obtained by multiplying sulfation plate data
(milligrams per 100 cm2 per day)by 0.03.2 In addition to the onsite monitoring,the Utah
Bureau of Air Quality operates a monitoring station for suspended particulates and sulfur
dioxide approximately 106 km (66 miles)to the southwest,at Bull Frog Marina.The applicant
will be required to conduct a monitoring program to collect onsite meteorological data,e.g.,
wind speed and direction at one hour interval s,the results of which will aid in the determina-
tion of compliance with 40 CFR Part 190.
The applicant did not present an operational monitoring program for nonradiological air
quality.Because no significant impacts to air quality due to operation of the facility are
expected (sect.4.1),the staff does not recommend an operational monitoring program for air
qual ity.
6.2 LAND RESOURCES AND RECLAMATION
6.2.1 Land Resources
6.2.1.1 La nd
The applicant acquired land-use data from published reports (ER,Sect.13),discussions with
personnel of various Federal,State,and local offices,and onsite visits.The staff wouldconditionthelicensetorequirethelicenseetoconductanddocumentalandusesurveyon an
annual basis.
6.2.1.2 Historical,Scenic and Archeological Resources
The existing condition of the site was determined as described in Sect.2.5.2.Additional
monitoring,will be performed as described in Sect.4.2.2.
6.2.2 Reclamation
Reclamation plans are in accordance with the regulations of the Utah Division of Oil,Gas andmining.1 '2 The vegetation on reclaimed areas will be monitored and maintained until stand estab-
lishment and perpetuation is assured.2 In accordance with the State of Utah Division of Oil,
Gas,and Mining (Reclamation Regulation,Rule M-10),the revegetation will be deemed accomplished
and successful when the species
1.have achieved a surface cover of at least 70%of the representative vegetative communities
surrounding the operation (vegetation cover levels shall be determined b~the operator
using professionally accepted inventory methods approved by the Division),
2.have survived for at 1east three growi ng seasons,
3.are evenly distributed.and
4.are not supported by irrigation or continuing soil amendments.3
In addition,the applicant states that aerial photographs will be taken every third year to
monitor the progress of reclamation efforts.2
6-1
6-2
The staff feels that the applicant's revegetation procedures and monitoring programs are
adequate to ensure successful reclamation.Sufficient records must be maintained by the
applicant to furnish evidence of compliance with all monitoring.The applicant will file a
performance bond with the State of Utah to ensure performance of land reclamation.4
6.3 WATER
6.3.1 Surface water
Quarterly monitoring of surface-water quality will continue throughout the life of the project.
Sample locations are described in Table 2.21 and Fig.2.5,and the chemical and physical
parameters to be measured are given in Table 2.20.Because of the temporary nature of many of
the watercourses in the site vicinity,it is recommended that the applicant take advantage of
seasonal rainfall and snOl'mlelt in schedul ing the collection of water samples.
6.3.2 Groundwater
The applicant has supplied chemical constituent data for samples from each of two abandoned
stock wells on the project site.Water from these wells (G6R and G7R on Fig.2.5),completed
in the Dakota Sandstone,is of poor quality.Total dissolved solids are in excess of 2000 ppm,
which would have adverse effects on many crops.Total sulfate is in excess of 1300 ppm compared
with an acceptable value of 250 ppm;dissolved iron is in excess of 3 ppm compared with an
acceptable value of 0.05 ppm;and lead is in excess of 0.12 ppm compared with an acceptable
value of 0.05 ppm.s Data from local springs indicate that the water is suitable for stock and
wildlife use only.
Additional sampling in accordance with Table 6.1 will be required.During operation,the applicant
will be required to monitor the groundwater from wells installed and located as specified in
the Source Material License to detect potential groundwater contamination (as discussed in
Sect.4.3.2.2)until reclamation is completed.The applicant is also required to submit a plan
to mitigate such contamination if observed.
6.4 SOILS
During September 1977,an existing soil survey of the site was field-verified by a retired
USDA Soil Conservation Service scientist,and a soil scientist for the applicant's consultant
(ER,Sect.6.1.4.1).At least one soil profile for each mapping unit was located and sampled.
Soil analyses for potential uses in reclamation operations included contents and characteristics
such as texture,water-holding capacity,saturation percentage,pH,lime percentage,gypsum,
electrical conductivity,exchangeable sodium percentage,sodium adsorption ratio,organic
carbon,cation exchange capacity,boron,selenium and available phosphates,potassium,and
nitrate/nitrogen (ER,Sect.6.1.4.1).
6.5 BIOTA
6.5.1 Terrestrial
Plant communities at the project site were mapped by aerial photographs and field verification
(ER,Sect.6.1.4.3).Vegetation on the site was surveyed during the spring and summer of 1977
(Fig.6.1).Five 1.0-m2 quadrats were placed every 10 m along 100-m transects.The number
of transects varied depending upon the size and homogeneity of the community.The larger and
more diverse communities had the greatest number of transects.Species collected were ten-
tatively identified in the field and later verified at the Rocky Mountain Herbarium of the
University of Wyoming.The density of each species was determined by counting the number of
individual plants in each quadrat.The percentage of cover for each community was estimated
visually within each quadrat,and all quadrats were then summed and divided by the total
number of quadrats to reach a mPan percentage of cover for the entire community.Production
studies were also conducted during the 1977 growing season (April through September)and
expressed as kilograms per hectare (pounds per acre).The number of 1.0-m2 samples taken in
each community on the site to measure production varied from 5 to 40,depending upon the size
and homogeneity of the community.
'"It,",
Natural uranium,Ra-226,Th·230,
Pb-210,and Po·210
Natural uranium,Ra·226,Th-230,
Pb-210,and Po·210
Suspended and dissolved
Pb·210 and Po·210
Natural uranium,Ra-226,Th·230,
Pb-210,and Po-210
Dissolved natural uranium,Ra·226,
Th·230,andchemicals·
Dissolved Pb·210 and Po·210
Total and dissolved natural uralllum,
Ra·226,Th-230,and chemicals'
Total and dissolved Pb·210and
Po-21O
Dissolved and natural uranium,Ra·226,
Th·230,and chemicals·
Dissolved Pb·210 and Po·210
Suspended and dissolved nalural
uranium,Ra·226,Th·230
NalUraluranium,Ra·226,Th·nO,
and PlJ·21O
NalUraluranium,Ra·226,Th·230,
and Pb·210
Natural uranium,Ra·226,1h·230,
and Pb·210
Rn·222
Sample measurement-------_._---~_.
Test frequency Type of meaSurement
•::J<1>.a.
Each 48·hr sample
Quarterly composites of samples'
Quarterly composites of samples
Quarterly composites of samples
~--­,''----_..__!
....n'";:,<+
;:,
Type and frequency
Continuous (one week
per month;same
period each month):
samples collected for
48·hrintervals
Continuous:weekly
Continuous:weekly
Continuous:weekly
Table 6.1.Preoperational monitoring program
'"
Location
Samplecollection
Locations onsite at or near site
boundaries
Locations offsite including
nearest residences
Background location remote from
site
At same locations where particulates
are sampled
5
3
Number------.------
Type
of
sample
Radon gas
Particulate
Particulate
Air
Particulate
Water
Groundwater 3 IIells located around tallings Grab;quarterly Quarterly
disposal area (one downgradient SemiannuallyIndtwocrossgradient;deep)
1 Wells within 2 km of tailings disposal Grab:quarterly Quarterly
(from each weill areas (could be used for potable
water or irrigation)Semiannually
Well located up gradient from disposal Grab:quarterly Quarterly
area for background
Semiannually
Surface water 1 Onsite or offsite streams (Westwater Grab:quarterly Quarterly
(from each body Creek,Corral Creek,Cottonwood
of waterI Wash,etc.}which may be potentially
contaminated by direct surface drain·Grab;semiannually Semiannually
age or tailings impoundment failure
Vegetation (forage)3 GraZing areas near the mill site in Grab;three times Three times
different sectors having the during grazing
highest predicted particulate season
concentrationsduring milling
operations
Food (crops,livestock)3 Within 5 km of mill site Grab:three timeS One time
(ofeach typel duringharvest or
slaughter
Fish Each bodyof Collection ofgame fish (if anyl Grab;semiannually Two times
water from streams in the site environs
which may be contaminated by
surface runoff or tailinll5 im·
poundmentfailure
mI.j:>
Rn-222 flux
All samples for Ra-226;one sample for
natural uranium,Th-2JO.and
Pb-210
Natural uranium.Ra-226.Th-2JO,
and Pb-210
All samples for Ra-226;oneset of
samples for natural urantum.Th·2JO.
and Pb-210
Pressurized ionization chamber or
properly calibrated portable •
survey instrument
Natural uranium.Ra·226,Th-2JO,
and Pb-210
Natural uranium.Ra-226.Th·2JO.
and Pb·210
All samples for Ra-226;10%of
samples for natural uranium.
Th-2JO,and Pb-21O
Pressurized ionization chamber
or properly calibrated portable
survey instrument
Pressurized ionization chamber or
properly calibrated portable
survey instrument
Test frequency Type of measurement
Sample measurement
Each sample
Twotimes
One time
One time
One time
One time
Quarterly
One time
One time
One time
Grab;once following
site preparation
Grab;once following
spring runoff and
once in latesummer
following period of
extended low flow
Two-to three-day
period;one sample
during each ofthree
months (normal
weather)
Type and frequency
Grab;once following
site preparation
Gamma dose rate;
once prior to
construction
Grab;once prior
to site construction
Gamma dose rate;
once following
preparation of
milling site
Gamma dose rate;
quarterly
.Grab;once prior to
site construction
Grab;once prior to
site construction
location
150-m intervals to a distance of
1500 m in each of eight directions
from a point equidistance between
the milling area and tailings pond
150-m intervals in both horizontal
andvertical transverses across the
milling areas
Upstream and downstream of waters
that may receive surface water run-
off from potentially contaminated
areas or thatcould be affected by
tailings impoundment failure
At center of mill site and at 750and
1500 m in each offour directions
from the site
Sampl e callection
At same locations as used for col-
lection of particulate samples
JOD-m intervals to a distance of
1500 m in each of eight directions
from a point equidistance from
mill and tailings pondsites
JOD-m intervals in both a horizontal
and vertical transverse across the
milling area
AI same locations as usedfor col-
lection ofair particulate samples
750-m intervals in each of four
directions from a pointequi-
distance from the mill and tailings
pond sites
Atcenterof mill building area
5
5
6
5
10
80
10
40
Number
2
/from each stream)
Table 6.1.(continuedI
Type
of
sample
Radon-222 flux
Sediment
Subsurfacesoil profile
Surface soil
•Nonradiological chemical parameterslisted in Table 2.25.
Source:"Branch Position for Preoperational Radiological Environmental Monitoring Program for Uranium Mills,"U.S.Nuclear Regulatory Commission,Memorandum from l.C.Rouse.ChIef
of Fuel Processingand Fabrication Branch.Jan.9,1978.
Site survey
Gamma dose rate
--------------------------_.
6-5
A ensus of birds was taken in February,May,late June,and October by roadside counts (ER,P1~te 2.8-3)and a walked-transect count (Fig.6.1).For the roadside count,all birds were
11ied within a 0.4-km (1/4-mi1e)radius every 0.8 km (1/2 mile)along the transect.The
taadside count is an adequate method for determining the composition and abundance of birds.~~e walked-transect counts,described by Em1en,6 are useful for estimating densities in specific
habitats.Raptor nests were investigated by visiting possible nesting sites.
Data on big game were based on signs (scat,tracks,etc),direct observation,and information
supplied by the Utah Division of Wildlife Resources (ER,Sect.6.1.4.3).Livestock information
was obtained from the U.S.Bureau of Land Management.Rabbits and hares were counted along two
roadside transects on two consecutive evenings each season (ER,Plate 2.8-3).A census of small
mammals was taken at three trap grids placed on the site for each of three consecutive nights
in August and October 1977.Each grid consisted of 12 rows and 12 columns of traps spaced 15 m
(49 ft)apart for a total of 144 traps.Sherman live traps were used in the study and all
traps were checked each morning and night.The captured animals were eartagged and released to
estimate the population through a standard capture/recapture method.7 However,not enough
animals were captured to make a meaningful population estimate (ER,Sect.6.1.4.3).In addition
to the grids,two traps lines consisting of 20 to 26 traps each were placed in pinyon-juniper
and tamarisk-salix habitats to determine relative abundance,diversity and distribution of
small mammals (Fig.6.1).
Although potentially harmful amounts of radionuclides and other contaminants in the tailings
impoundment are not expected to result in any significant impacts to wildlife,the actual
extent of this impact cannot be quantified (Sect.4.6.1).Therefore,the staff will require
that the applicant monitor the use of the impoundment by wildlife in conjunction with the
program to monitor the tailings discharge system (Sect.3.2.4.7).The monitoring plan should
be submitted to the Utah Division of Wildlife Resources for their evaluation and approval.
Because surface water is limited in the area,daily monitoring would be especially important
during the fall and spring migration periods of waterfowl and shorebirds.The data should
be submitted to the Utah Division of Wildlife Resources and the NRC on a yearly basis for
evaluation to determine if there is a need for additional monitoring.
6.5.2 Aquatic
Because of the lack of aquatic habitat (Sect.2.6.1.1),subsequent paucity of aquatic biota
(Sect.2.9.2),and the low probability that the aquatic habitat could be significantly
impacted by mill construction and/or operation (Sect.4.6.2),an extensive,long-term aquatic
biota monitoring program is not considered necessary by the staff.However,because the local,
ephemeral streams (Corral Creek,Westwater Creek,and Cottonwood Wash)have not been sampled
for aquatic biota during times of water flow,the staff will require the applicant to undertake
a biotic survey of these environments under appropriate conditions to characterize any temporal
aquatic biota,if the groundwater monitoring program indicates levels of potential contaminants
are increasing.
6.6 RADIOLOGICAL
6.6.1 Preoperational program
A preoperational,radiological monitoring program is being developed at the proposed White
Mesa mill site to establish the baseline radiation levels and concentrations of radioactive
materials occurring in air,biota,and soil,as well as in regional surface water and local
groundwater.The sampling program,begun in July 1977,is ongoing,and results are incomplete.
The preoperational monitoring program will conform to that recommended by the NRC and shown in
Table 6.1.
6.6.2 Operational effluent and environmental monitoring program
The objectives of the effluent monitoring program are to ensure that the proposed mill discharges
are as ·low as reasonably achievable,to develop criteria that can be used in the design of
new operational procedures,and to aid in the interpretation of the results of such other studies
as the environmental monitoring program.The procedures for controlling effluent release and
performing monitoring and surveys will conform to applicable U.S.Government regulations.The
program that will be implemented (Table 6.2)will consist of measurements of radioactivity in
the air,surface water and groundwater,soil,and biota.
j
~,I~,.,l_
i .
-
,
..0.;.•
...,-:."
\....~~.
-.:'~,.,":./
'..\:::-....~-'~~.-.;,'f
._',~.~.1
'j'='I.
t'.',1;".-''.0+.'~./
~..
.;
I.
I/.
,"
RG 2 -R.MeCIId GrOUlOnd ][Communityo-O,sturtled Community
T-S "Tomono-Sob Community
'-,
IIGraaIand Grid (R••••d.d Gra••land I)
IIBiv SogeIlrulh/Gr_Grid (Controll.d 81,So,.lIrusll)
SCALE I:156250
oritin-0 directIon of trav._
/
/
~I
V;
w-
-'--............;..-----~-......'"'l!t_.,
-"-:-;'''
_."-.~
:
VEGETATION
Transect Locations
p"J -f'inJon "Juniper CommurVty
BS -Big Soveorusll CClIMlIftty
CBS -Controlled Bit S~ComrnUllly
RG I "Raeeded Grosaloncl I Convnunil)o
WILDLIFE
Srnoll Mornmot Live-Tropp,",TronSKI
l Pin1O""JuniPll'Tron••ct
f Tomorilll-Grosa Tron••ct(Tarnarllk-Soll.)
IDBi;Sotetrush Grid
Modifi.d Emlen Bird TronHet
EmIen I •GrOlllond
EmIen2 -Big SCI9IIWUIIl
",'.
-r/
.,
'/1
~...."""~
_:---oJ
,,.
--"'.,-,..-~...':;".'~~.
-.,;.,,".
-.
.""'...........;....
6-6
ES-4599
.=""--
'.,.-'o..~J'.."-..'-.:~.
~,:
'.."
Fig.G.l.Sampling locations for terrestrial ecological characteristics in the vicinityoftheWhiteMesaproject.~:ER,Plate 2.8-1.
·:";"0iiJI,;J'i!.;'-i.J;..·~cci.."'JI>.~·
.._--1
;-
tJ\
I~J
Rn-222
Natural uranium,flow ralll
Natural uranium,Ra-226,Th-230.
and Pb·210
Ra-226,Th-230,Pb·210
Natural uranium,Ra-226,Th-230,
and Pb·210
Natural uranium,flow ralll
(11 Ra-226 and Th·230 or
(2)natural uranium,
Ra-226,and Th·230
Pb·210
Natur~1 uranium,Ra-226,Th-230,
and Pb·210
Sample measurement
Test frequency Type of measurement
Semiannual for
first year,1 or 2
Each 48-hr sample
Semiannual
Semiannual for
first year
Ouarterly
Semiannual,1 or~
Quarterly composite
Ouarterly composite
Quarterly oomposite
Isokinetic and repre-
sentative-semiannual
stack sample
Isokinetic and repre·
sentative-monthly
stack sample and
either (11 semiannual
stack sample or
(21 semiannual product
(yellow cake)sample
Method and frequency
Continuous;weekly or
more frequently as
required bydust
loading
Continuous;weekly or
more frequently if
required by loading
Continuous;weekly
or more frequently
if required by dust
loading
Continuous;at least
one week per month
at approximately the
same period each
month,samples
collected for 48-hr
inlllrvais
Sample collection
Table 6.2.Operational radiological environmental monitoring program
Yellowcake dryer and packaging
stack
Ore crusher stack
Location
At site boundaries and in different
sactors having the highest pre'
dictedconcentrations
At nearest residence
Same as for air particulates
Control location-more than 15km
from mill site in least prevalent
wind direction
5
3
Number
Particulallls
Radon gas
Type of sample
_.__L.-..._::_..-=.:.~~~.:::._L~i~~::.=J,,~~-~".,.
Air
Particulates
------------------_._-------------------'-------------------
8To be taken during operation of the stack ventilation system and the respective processsystem.Minimum sampling time,3 hr per stack.
bChemical parameters tobe analyzed will be determined from an analysis ofsamples taken from the tailings pond once mill operations have begun.
eTOSz total dissolved solids.
dlf a large number ofwells are located within 2 km,only those ""ells nearest tailings impoundmentor the mine need be sampled.
m
I
OJ
Total natural uranium,Ra-226,
Th-230,Pb-210,and Po-210;
suspended solids
Natural uranium and Ra-226
Ra-226 and Pb-210
Measurement of x-ray andgamma-
exposure rates
Dissolved natural uranium,Ra-226,
Th·230,Pb-210,and Po·210;
chemicalsb and TDSe
Dissolved natural uranium.Ra-226,
Th-230,Pb-210,and Po-210;
chemicals and TDS
Total natural uranium,Ra-226,
Th-230.Ph-210,and Po-210;
chemicals and TDS
Sample measurement-------Type of measurementTestfrequency
Annually
Each sample
Quarterly
Quarterly when
flowing or follow-
ing precipitation
event
Monthly;quarterly
after first year
Quarterly
Quarterly
Pressurized ionization
chamber,properly
calibrated portable
survey instrument or
thermoluminescent
dosimeters with two or
more phosphors each
Grab;annually
Grab;three times
duringgrazing
season {i.e.,April,
July,andOctober!
Grab;quarterly when
flowing or following
precipitation event
Grab;monthly
(quarterly after
first year!
Grab;quarterly
Grab;quarterly
Method and frequency
Table 6.2 {continuedI
Location
Sample collection
Same as for air particulate samples
From animal grazing areas near mill
site which have the highest pre,
dicted concentration (including
nearest ranchesl
Two deep downgrad1ent.two
deep crossgradient.and five
shallow well s west &south.
tnfttally.
Controllocation-hydrologically up
gradie.lt {not influenced by tailings
seepageI
Each well used for drinking water or
watering livestock or crops within
2 kmof tailings pond or mined
Surface waters passing through or
close to the mill;one sample
upstream and onedownstream
of location of potential influence
Same as for air particulate samples5
5
3
9
Number
2
{from each streamI
1
{from each weill
Type of sample
Surface water
Soil
Vegetationor forage
OilllCt radiation
Water
Groundwater
6-9
REFERENCES FOR SECTION 6
1.A.P.Plummer,D.R.Christensen,and S.B.Monsen,Restoring Big-carne Range in Utah,
Utah Division of Fish and Game,Publication No.68-3,Salt Lake City,1968.
2.Energy Fuels Nuclear,Inc.,"Responses to Comments from the U.S.Nuclear Regulatory
Commission,June 7,1978,White Mesa Uranium Project Environmental Report,"Denver,
Jw'!e 28,1978.
3.State of Utah,Division of Oil,Gas,and Mining,"Changes and Adoptions to the General
Rules and Regulations,"adopted by the Board of Oil,Gas,and Mining on March 22,1978;
effective June 1,1978.
4.Energy Fuels Nuclear,Inc.,"Responses to Comments Te1ecopied from NRC to Energy Fuels
Nuclear,Sept.25,1978,"Oct.4,1978.
5.Office of Water and Hazardous Materials,USEPA,Quality Criteria for Water,Washington,D.C.,1976.
6.J.T.Em1en,"Population Densities of Birds Derived from Transects Counts,"Auk 88:
323-342 (1971)..
7.R.L.Smith,Ecology and Field Biology,2d ed~,Harper and Row,New York,1974.
t'·.,;,:.'..1
U
7.UNAVOIDABLE ENVIRONMENTAL IMPACTS
7.1 AIR QUALITY
An unavoidable impact of construction and operation of the mill facility would be a slight
'ncrease in particulate matter and ambient concentrations of gaseous emissions.Because the
loncentration of these pollutants would be below the Federal and State air quality standards,~he staff feels that they will not significantly contribute to the decline of the regional air
quality.
7.2 LAND USE
7.2.1 Land resources
7.2.1.1 Nonagricultural
Area land uses will change as a result of the population growth that would be induced by the
proposed mill and any related mining activities.Possible adverse impacts are those which
would result from increased traffic on the highways.
7.2.1.2 Agricultural
Construction and operation of the mill would result in an unavoidable loss of nearly 195 ha
(484 acres)of potential qrazing land.Following project termination,about 70%of this total
area [approximately 135 ha (333 acres)]would be occupied by the reclaimed tailings impoundment
area and would be considered 'permanently committed to tailings disposal.This area might be
available for grazing after it has been released from its status as a restricted area.The
remaining land would be reclaimed to permit unrestricted use.
7.2.2 Historical and archaeological resources
If the program of mitigation outlined in Sect.4.2.2 is followed (avoidance of sites when possible,
full excavation of those which cannot be avoided,and protection of potential or currently
unidentified sites),adverse impacts should be minimized.
7.3 WATER
7.3.1 Surface water
Erosion of disturbed soils during construction and operation would minimally impact the local
streams and only during heavy,erosion-producing rainfall.No adverse impacts due to mill-site
runoff are expected,because this runoff will be impounded on the mill site during operations.
No adverse impacts on surface water caused by groundwater transport of tailings material are
expected.Overall,no adverse impacts to surface water~are expected.
7.3.2 Groundwater
Operation of the proposed mill should result in the use of about 5.9 x 10 5 m3 (480 acre-ft)of
water (drawn from the Navajo aquifer)per 4ear.The usage of water by the applicant should have
~o adverse effect on other users.Preoperational and operational monitoring of the groundwater
15 required (Sect.6.3.2),and mitigating measures will be taken if unexpected groundwater
contamination is observed.
7-1
7-2
7.4 SOILS
Construction and operation of the mill facility would disturb about 1~5 ha (484 acres).Topsoil
will be removed from the construction areas and stockpiled for replacement upon termination of
operations.However,a temporary decrease in natural soil productivity is probable (Sect.4.5).
Some soil will be unavoidably lost,primarily from wind erosion,but proper mitigating measures
(Sect.4.5)would minimize this impact.Reclamation laws require successful establishment of a
soil medium that would be capable of sustaining vegetation without irrigation or continuing soil
amendments (Sect.3.3.2).Long-term impacts to the soil are not expected to be significant.
7.5 BIOTA
7.5.1 Terrestrial
The proposed project would result in a temporary unavoidable loss of about 195 ha (484 acres)
of vegetation and a concomitant loss of wildlife (Sect.4.6.1).Although some vegetation and
wildlife loss would be unavoidable,such loss should not result in any long-term adverse
impacts.
7.5.2 Aquatic
The impact on limited available aquatic habitat due to mill construction or operation is
projected as insignificant (Sect.4.6.2 and 7.3.1).No adverse impacts on aquatic biota'are
expected.
7.6 RADIOLOGICAL
Radioactive emissions from transportation,storage,and milling of the ore would increase the
level of radioactivity in the surface environment.
7.7 SOCIOECONOMIC
The infusion of people into the local area would strain certain public services and the housing
market,unless these areas are expanded rapidly.Both old and new residents would be affected.
The present consumer prices for goods and services in the area of the site would be stimulated
by the project.A rising cost of living primarily affects original residents who have not
increased their income at the same rate as energy-development workers..
The general inconvenience caused by expansion to meet the needs of the new residents -such
as construction c.ctivities,temporary buildings,and decline in services -can rarely be
avoided in large projects such as uranium mill construction;The staff expects that such
inconveniences will affect many in the area of the White Mesa Uranium Project but that these
effects cannot be avoided.
nl
p~"u
:efl
U
8.RELATIONSHIP BETWEEN SHORT-TERM USES OF THE ENVIRONMENT
AND LONG-TERM PRODUCTIVITY
8.1 THE ENVIRONMENT
8.1.1 Air quality
The short-term increases in suspended particulates during plant construction and the increases
"n suspended particulates and chemical emissions associated with mill operation are expected~ohave no impact on the long-term quality of the atmosphere in the region.
8.1.2 Land use
The land on which the mill is located could be returned to its present state and capacity by
reclamation activities.The tailings area,however,under present regulations may be unavail-
able for further productive use.
While uranium milling is a short-term activity,a mill tailings disposal site will constitute a
ermanent disturbance of the land surface,rendering it unsuitable for future archaeological~nvestigation.Therefore,any such investigation must be conducted prior to the initial surface
disturbance.
8.1.3 ~
Because water for mill ing operations will be drawn from a deep and 1ightly used aquifer,no
changes in the water-use patterns of the area are expected to occur as a result of mill operation.
8.1.4 Minera 1 resources
No mineral resources are known to exist on the site.Reworking of tailings for extraction of
other minerals could occur if economics warrant.
8.1.5 ~
The applicant's reclamation program is designed to return the soils to a condition of
productivity that is consistent with their present and historic usage -that is,the
production of forage and habitat for 1i vestock and wil d1 i fe.The program wi11 begi n as soon
as practicable and will continue throughout the life of the project.As a result,about
half the disturbed soils should be back in production by the time mill operation ceases.
8.1.6 Biota
8.1.6.1 Vegetation
Revegetation of disturbed areas will begin as soon as practicable and will continue throughout
the life of the project.A satisfactory vegetative cover is expected to be established in two
or three years.About half the disturbed area will be revegetated by the time mill operations
cease,and the remainder will be revegetated shortly thereafter.
8.1.6.2 Wildlife
n,I ",l"'.:.~
Terrestrial vertebrates now inhabiting the project site will either perish or will escape to
undisturbed areas surrounding the mill,where populations will be controlled by natural means.
After reclamation,the more adaptable individuals and species will repopulate the area as
favorable stages in the vegetative succession are reached.
8.1.7 Radiological
The tailings will be impounded in lined cells.Such enclosures would be overlain with cover
m~terial to meet radon release standards,and then reclaimed.The reclaimed tailings area
Wl11 constitute a source of radon emission of about twice the natural background flux.
8-1
8-2
8.2 SOCIETY
No significant long-term impacts on the socioeconomic character of local communities can
presently be attributed to the project with certainty.The nature of such impacts will depend
on the prevailing community conditions when operations of this mill cease:
1.If the local economy and population continues to grow when the operation terminates
and project personnel migrate from the area,the additional housing and public facilities
built to accommodate project-related personnel will help to accommodate needs of theexpandingeconomy.
2.If,at project termination,the economic activity and populations of communities are
declining and surpluses of facilities and housing exist,some of the resources initially
invested to accommodate needs of the White.Mesa mill employees will not have been
amortized.This situation could be aggravated if bonds used to finance public facilities
directly attributable to this development have not been amortized during the operating(or ether taxpaying)life of the project.
A loss of long-term productivity may result from disturbance of archeological sites.However,
the mitigating actions that would be taken should result in preservation of archeological
materials that might otherwise have been destroyed.This is consistent with the opinion of the
Utah State Historic Preservation Officer who has advised as follows 1:
The work to identify significant sites and sites that will be adversely effected
is nearly complete and while certain sites within the property may be significant
under the federal criteria,as more fully explained in the State Archaeologist's
report,you should be aware that the significance of these sites lies not with
their becoming public attractions or monuments,but rather with the information
they have yielded about certain prehistoric cultures.Sites of this nature are
plentiful throughout the southeastern part of Utah,but have not been tested.
It is only the opportunity presented by the desire of Energy Fuels to build a
uranium mill in this area that permitted us to devote the time and energy
to a thorough study of such sites.In essence,Energy Fuels project will permit
the recovery of archaeological data that without the project probably never .
would have been recovered.
REFERENCES FOR SECTION 8
1.Utah State Historic Preservation Officer,letter to NRC.dated December 5,1978.
[.
..•...'.;
,;;!3
Iyn
.i~;les
9.IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
9.1 LAND AND MINERAL
9.1.1 Land
The land occupied by the reclaimed tailings cells may not be available for further productive
use.This would be considered an irreversible commitment of resources..
work to reclaim archaeological sites may result in an incomplete recovery of archaeological data
or resources.or in an inadvertent destruction of a portion of those resources.
9.1.2 Mineral
No major irreversible or irretrievable commitments of mineral resources are anticipated other
than (1)the uranium and vanadium that will be recovered;(2)the 23,000 MT (25,000 tons)of
coal that will be burned each year;and (3)the yearly consumption of 6.6 MT (7.3 tons)of
kerosene and 95 m3 (25,000 gal)of fuel oil in processing operations.
9.2 WATER AND AIR
9.2.1 Water
Ground and surface waters are not expected to be impacted by the proposed project.Because of
the large volume of groundwater available,use of that water during mill operations is not
considered an irreversible or irretrievable commitment of resources.
9.2.2 Air
Air is not depleted as a result of construction and operation of the mill facility but there
is a potential for the air quality to be impaired primarily as a result of an increase in
total,suspended particulate matter.However,because the atmosphere is self-cleaning of
the pollutants at the anticipated low concentrations,no irreversible ~r irretrievable
commitments of air resources are expected.
9.3 BIOTA
9.3.1 Terrestrial
Although a total of about 195 ha (484 acres)of soils and associated vegetation will be
temporarily disturbed or lost for the life of the project,the land and wildlife habitat can
be restored in time to acceptable levels as a result of approved reclamation efforts
(Sect.3.3.2).Current regulations,however,require the tailings disposal area [about 135 ha
(333 acres)]to remain fenced until it is released from its status as a restricted area.
Wildlife will undoubtedly use this area after it is fully reclaimed.This restriction is not
considered an irreversible commitment of resources.
9.3.2 Aquatic
The staff does not expect any irreversible or irretrievable commitments of aquatic biota or
habitat from project operation.
9-1
9-2
9.4 MATERIAL RESOURCES
Major irretrievable and irreversible commitments of material resources*incurred per year of
White Mesa mill operation are 6.04 X 104 MT (6.66 x 104 tons)of sulfuric acid;4.8 x 10 3 MT
(5.3 x 10 3 tons)of manganese dioxide,2.47 x 103 MT (2.72 x 103 tons)of sodium chlorate;
1.92 x 10 3 MT (2.12 x 103 tons)of soda ash;4.39 x 102 MT (4.84 x 102 tons)of ammonium
sulfate;2.93 x 102 MT (3.23 x 102 tons)of anhydrous ammonia;and 0.91 x 10 2 MT (1.0 x 102 tons)
of flocculent.In addition small amounts of Isodecanol,Amine,and various laboratory chemicals
will be consumed.
These materials are not in short supply and are common to many industrial processes.
*Assuming 25%of the ore is processed for vanadium.
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10.ALTERNATIVES
10.1 ALTERNATIVE SITES
The following factors were among those considered in selecting and evaluating mill and
tailings disposal sites:
1.availability of suitable land;accessibility,but with limited public exposure
(population doses);
2.proximity to producing mines and known ore bodies for reducing haulage costs and
decreasing the impacts associated with ore transport;
3.geotechnical,meteorological,and hydrological factors:(l)direction and intensity
of prevailing winds,(2)presence of mineral resources,(3)subsurface structural
stability,(4)availability of natural tailings impoundment liner materials (5)ade-
quate quantity and quality of materials available for reclaiming the tailings dis-posal area and other disturbed surface areas,and (6)suitable drainage and-flood
characteristics;
4.topographical factors such as (1)surface suitability for construction of facilities
with minimum alteration of terrain,and (2)minimal drainage area above the tailings
impoundment;
5.proximity to natural and man-made areas that could be adversely affected by the
construction,operation,and reclamation activities related to the project;
6.existence of unique habitats that might support protected,threatened,or endangered
species;
7.availability of industrially important services such as transportation,power,and
communications.
The staff has determined that the most important factors to be considered during the site
selection process are those which ensure an acceptable tailings management program.The NRC
tailings management performance objectives for siting and design are listed in Section 10.3.1.
10.1.1 Alternative Mill and Tailings Disposal Sites
The applicant's Hanksville and Blanding ore-buying stations were located to collect uranium
are from small producing mines in southeast Utah.The majority of the ore for the mill will
not be coming from company-owned mines located in close proximity in a specific geographical
area but will be collected thru ore-buying from widely scattered mining operations in the Four
Corners region.There are,theoretically,a multitude of potential sites in the Blanding -
Hanksville region.
As was the case with the existing ore-buying stations,alternate sites for the mill would be
optimally located with respect to the ore to be processed to minimize hauling distances,i.e.,
transportation impacts.
In addition to the alternative sites discussed below,the following alternatives were evaluated:
The alternative of storing the mill wastes in the mines from which the ore was extracted.
This alternative is not feasible for a central milling operation that will be processing
are from approximately 100 small,widely distributed mines with diver~e ownerships.
Adequate control of the transportation,handling,and storage of the tailings would be
difficult,and accessing and monitoring the effects of the tailings on the scattered,site-specific environments would be both difficult and expensive.
2.The alternative of milling the ore purchased at the buying stations at existing uranium
mills (see Section 10.4 for discussion).
The applicant evaluated two basic siting options:(1)locating the mill and tailings impound-
ment in the Hanksville area,and (2)siting the processing and waste disposal facilities in
the vicinity of Blanding.
10-1
,
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10-2
1.
The option of locating the mill and tailings dis~osal facilities in the Hanksville area was
considered unacceptable by the staff for the following reasons:
1.Socioeconomic limitations (Section 2.4.2).These limitations include (1)limited ~apac_ity of Hanksville to absorb growth (excess housing is nonexistent);and (2)limited
availability of power,communications,and transportation (air and rail)services.
Hanksville (population 160)could not support the population increase that would be
necessary to implement this project.The population change would be similar to that
projected for Blanding (Section 4.8.1);h0wever,the impacts would be significantly
greater.
Increased ore haulage distances.Approximately 75%of the known uranium ore depositsavailableforprocessingarelocatednearBlanding(ER.p.10-2).
2.
IThesesiteswereevaluatedprimarilywithrespecttotheavailabilityofsuitableland,hydro-i
logical and topographical considerations,and accessibility of services:1Availabilit~of Suitable Land.A drawback for the Calvin Black property is that it is Ii
3.2.km (2 mlles~from B'and~ngand th~re are private.residences within a.O.4-km (0~25-milel ,
radlus of the slte.The Whlte Mesa slte,10 km (6 mlles)south of BJandlng.on t e other I
hand,is bounded on east,west,and south sides by publicly-owned land and the ne rest 1
potential residence is 1.6 km (1 mile)north (the nearest current resident is aoonpxi-
mately 3 miles north).}
Hydrological and Toeographical Considerations.Cottonwood Wash drains through the middle
01 the Zekes Hole slte and the drainage at this location is greater than 500 km2 (193
square miles).The Calvin Black property lies directly in the Westwater Creek drainage.
The Mesa and White Mesa sites are both located on gently sloping lands and are not crossed
by major drainages.
2.
Based on a consideration of socioeconomic and transportation impacts,the staff has concluded
that other potential "alternative sites in the southeastern Utah region would be no better than
those located in the vicinity of Blanding,Utah.Four alternative mill and waste disposal
sites in the Blanding area were evaluated by the applicant (Fig.10.1):(1)Zekes Hole
(Area I),(2)Mesa (Area II),(3)Calvin Black property (Area III),and (4)White Mesa
(Area IV).Zekes Hole is pUblicly-owned land located approximately 8 km (5 miles)southwest ofBlanding,adjacent to and on the south side of State Highway 95.The Mesa site alternative is
located approximately 6.4 km (4 miles)southwest of Blanding,adjacent to and on the south
side of State Highway 95 and consists of two sections of pUblic land.The Calvin Black property
encompasses approximately 290 ha (720 acres)of privately owned land and is located approxi-"
mately 3.2 km (2 miles)south of Blanding along the north side of State Highway 95.The White
Mesa site is composed of 600 ha (1480 acres)of privately owned land and is located approxi-
mately 10 km (6 miles)south of Blanding on the west side of Highway 163 and is crossed by the
Black Mesa Road and an existing power line.(The site is owned by Energy Fuels Nuclear).
3.Accessibility of Services.There is limited accessibility to commercial power at the
Zekes Hole and Mesa sltes;power is available at the Calvin Black property and White Mesa
sites.The applicant claims that the water supplies at the Mesa site and at the Calvin
Black property might be inadequate to support the proposed mill.Access to roads is not
a problem at any of these sites.
Based on a comparison of the four areas with respect to the characteristics listed above thestaffconcludedthatthemillsiteareachosenbytheapplicant(White Mesa)was asenvironmentallysuitable(or was better)than any of the other three.
10.1.2 Alternative Tailings Disposal Sites in the White Mesa Area
The applicant evaluated four potential sites for mill tailings disposal in the White Mesa area
(see Fig.10.2).At two of the sites (East and West),the tailings would be stored in
canyons;and dams of considerable height would be required as part of the impoundments.AttheNorthandSouthsites,tailings impoundments would cover larger surface areas and would be
shallow,requiring the construction of dikes of low height.
The West site is located in Westwater Creek Canyon.The terrain in the area is steep,and a
15-year impoundment would require a dam approximately 70.1 m (230 ft)high.A single-cell,
above-grade impoundment,sized to hold 15 years of tailings,would cover a small area
[approximately 28 ha (68 acres)],and the drainage area would be about 340 ha (850 acres).
The applicant rejected this tailings disposal site alternative for the following reasons (ER,IAppendixH,p.5):"
10-3
Fig.10.1.Alternative areas near Blanding studied by applicant for the White Mesa Uranium
Project.Source:ER.Plate 10.2-1.
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II -MESA AREA
III-CALVIN BLACK PROPERTY
IV-WHITE MESA
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1.
2.
10-5
Because the dam would have to be quite high to provide the required storage capacity and
the toe of the dam would be in the flood plain of Westwater Creek,the long-term stabil-
ity of the impoundment would be questionable.
Prevention of excessive seepage into the nearby vertical sandstone canyon walls would be
difficult.
1.
The East site is located in Corral Creek Canyon.A conventional,above-grade tailings impound-
ment,designed to hold 15 ~ears of mill tailings,w?uld cover approximately ~9 ha (120 acres),
would require a dam approxlmately 36.6 m (120 ft)hlgh,and would have a dralnage area of
about 1400 ha (3400 acre~).This tailings disp?sal site alternative was rejected by the
applicant for the followlng reasons (ER,Appendlx H,p.6):
1.Although the reservoir surface area would be small,~ch is beneficial for reclamation
purposes,the drainage area is large;and water erosion over the long term is potentially
severe.
2.Prevention of excessive seepage into the steep,mostly sandstone canyon walls would be
difficult.
The South site,which was picked by the applicant as the optimum site,is downgradient from
the proposed mill site.The area is gently sloping,disturbed rangeland containing a slight
swale in the general area where the tailings impoundment would be placed.A single-cell,
above grade,15-year impoundment at the South site would cover approximately 100 ha (250 acres),
would require a dam approximately 19.8 m (65 ft)high,and would have a drainage area of
about 240 ha (590 acres).The impoundment that is part of the tailings management systemproposedbytheapplicantistobelocatedattheSouthsiteandisdiscussedindetailin
Sects.3.2.4.7 and 10.3.2 (Alternative 1).
The North site is located on gently sloping land upgradient from the proposed mill site.If a
conventional,above-.grade,dam/pond disposal facility,sized to hold 15 years of mill wastes,
were to be constructed in the area,the applicant estimates that the impoundment would cover
87 ha (215 acres),would require a dam approximately 24.4 m (80 ft)high,and would have a
drainage area of approximately 170 ha (420 acres).With the exception that the tailings would
have to be pumped uphill for a slightly greater distance,there are no significant differences
between this site and the South site.
Assuming that the mill would be located at White Mesa and utilizing the following criteria to
screen feasible site alternatives from a multitude of potential sites in the Blanding area,the staff located and evaluated three additional alternative tailings disposal sites:
To minimize long-term wind and water erosion problems,the areas chosen for further study
contained naturally excavated basins which 1)are almost completely enclosed by substan-
tial rock barriers (such as cliffs)and would require a dam.with a small length,and 2)
which would have minimal drainage areas above the tailings impoundment.
2.Only basins that could be impounded to contain at least 15 years of mill tailings andwhichcouldbereadilyaccessedbyroadorbyslurrypipelinewereconsidered.
The three additional alternative tailings disposal sites evaluated by the staff were 1)Recap-
ture Creek,2)Brown Canyon,and 3)Alkali Canyon.The Recapture Creek site is located in
Section 26,T375,R22E,east of the Corral Canyon tailings disposal site ("East site")investi-
gated by the applicant,and east of the White Mesa site boundary.The Brown Canyon site is
located northeast of the White Mesa mill site in sections 13, 14,and 23,T37S,R22E (themajorityofthetailingsimpoundmentwouldbeinsection14).The Alkali Canyon site is
located east-northeast of the White Mesa mill site in sections 10, 11,14 and 15,R23E,T37S.
A tailings impoundment at the Recapture Creek site would cover approximately 37 ha (90 acres)
and would require a dam approximately 48.8m (160 ft)high.At the Brown Canyon site an impound-
ment would cover approximately 84 ha (205 acres)and would require a dam approximately 30.5m(100 ft)high.A tailings retention area at the Alkali Canyon site would cover approximately
66 ha (161 acres);the dam required would be about 54.9m (180 ft)high.All sites are acces-
sible by road;the haulage distances would be approximately 5.3 km (3.3 mi)to Recapture
Creek,8.5 km (5.3 mi)to Brown Canyon,and 19.5 km.(12.2 mi)to Alkali Canyon.
10-6
The tailings retention areas at these sites would be smaller than the proposed impoundment at
Wh-ite Mesa,and the local topographies offer excellent protection from wind and water erosion.
However,the dam heights would be greater,and the canyon walls are steep and consist of highly
permeable and fractured sandstone;the prevention of seepage from the tailings retention areas
would be difficul~and the long-term stability of the dams would be questionable.The staff
concluded that no appreciable additional environmental benefits could be gained by storing
the tailings at these sites.
10.1.3 Evaluation of Alternative Mill and Tailings Disposal Sites
The staff has concluded that no net environmental advantages would accrue if the mill and
tailings disposal facilities were to be located at sites other than the site proposed by theapplicant(White Mesa);i.e.,the site proposed for the projected facilities is better,from a
environmental standpoint,or at least as suitable as other potential locations.It must be
emphasized that this conclusion is only possible because a similar conclusion can be made
concerning the acceptability of the proposed tailings management system (Section 10.3.2,
Alternative 1),which enhances the environmental suitability of the chosen site.
10.2 ALTERNATIVE MILL PROCESSES
10.2.1 Conventional Uranium Milling Processes
The milling processes proposed by the applicant are conventional and conform with those
commonly used by the domestic uranium milling industry.In general,yellow cake is produced
by the milling of uranium ore via the following procedure:(1)ore preparation (involving
primarily the crushing and grinding of the ore),(2)leaching,(3)separation of pregnant
leach liquids from waste solids (tailings),(4)concentration and purification of the uraniumbyextractionfromthepregnantsolution,(5)precipitation of the uranium from the extract
solution,and (6)drying and packaging.The specific manner in which each of these steps,
singly or in combination,is accomplished varies from mill to mill,depending on differing ore
characteristics.Normally,process decisions are based on overall economic considerations,
including costs of controlling chemical and radiological effluents to air,water,and land.
Crushlng and grinding of ore are needed to reduce overall particle size to ensure efficient
contact with the uranium-dissolving reagent.Normally,the ore is moved from stockpiles to
the crusher by trucks,bulldozers,or by front-end loaders.1 Conventional crushing equipment
usually reduces the size of the ore particles to approximately minus 1.9 cm (3/4 in.).Control
of the moisture level in the feed ore is crucial in.the crushing process and generally should
be less than 10%to prevent crusher malfunctions.In most mills the crushed ore is stored
temporarily in bins before further processing.Grinding is usually accomplished by rod or
ball mill,with the ore being ground to approximately 28 mesh for acid leaching and to approx-
imately 200 mesh for alkaline leaching.1 At the White Mesa mill the ore [which has alreadybeencrushedtolessthan3.8-cm (1.5-in.)size at the ore buying stations]will be fed by a
front-end loader through a primary grizzly to a secondary grizzly and then fed by conveyor
belt to a semi autogenous wet grinding mill.The mill will operate in closed circuit with
screens,with the minus 28 mesh output (underflow from the screens)being pumped to three
mechanically agitated,wet-slurry storage tanks.
The leaching method chosen for removal of the uranium from the ground ore is heavily dependent
on the chemical prope~ties of the ore.Ores containing low levels of basic materials (primar-
ily lime)are usually leached with sulfuric acid.An alkaline leach reagent (normally sodium
carbonate-bicarbonate solution)is usually used when the lime content of the ore is high and
uneconomical quantities of acid wouid be required,significantly increasing processing costs.
Some processes add acid in "stages"to minimize excessive initial frothing and to monitor acid
content (pH control).The applicant evaluated the effectiveness of acid and alkaline leaching
processes on ores purchased ~y the ore buying stations (ER,p.10-6).Although some of the
ore could be successfully treated by alkaline leaching,acid leaching usually resulted in
higher recovery rates;therefore,a conventional sulfuric acid leach process was chosen by the
applicant.The leaching circuit at the White Mesa mill will be designed for the extraction of
vanadium as well as uranium.The ore will be leached in two stages utilizing sulfuric acid,
manganese dioxide (depending on availability and delivery,an equivalent oxidant such as
sodium chlorate might be used),and steam.The overall uranium recovery rate is expected to
be about 95%.
The separation of the pregnant leach solution from waste solids is usually accomplished by
thickening or by filtration.The majority of the acid leaching mills in the United States use
counter-current decantation in thickeners for liquid-solid separation.2 The applicant has
also chosen to achieve liquid-solid separation by counter-current decantation washing and
thickening methods.(The belt filtration alternative is described in Sect.10.2.2.)Either
conventional,multistage,counter-current thickeners or Enviro-Clear type thickeners will be
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10-7
employed.To reduce freshwater requirements,barren raffinate will be added to the final
thickner for washing the leached residue.Polymeric flocculants will be used to increase
separation efficiency,and the waste solids (underflow slurry from the last thickener
containing 50%water)will be pumped to the tailings impoundment area.
concentration and purification of the uranium from the pregnant leach solution is necessary
for the production of a high-grade uranium product.This is usually performed by either a
solvent extraction or an io~exchange process.The applicant has decided to utilize a
solvent extraction method where the decanted,aqueous uranium-bearing leach solution will be
contacted with an organic solution consisting of an amine-type compound dissolved in a
kerosene diluent.The dissolved uranyl ions are more solUble in (and transfer into)the
organic solution.Resin-based processes,such as resin-in-pulp and resin ion exchange in
clarified solution,were evaluated by the applicant and rejected for economic reasons,pri-
marily because of relatively higher operating costs.The solvent extraction process will be
carried out in a series of mixer and settling vessels,with the organic and aqueous solutions
being mechanically agitated and separated into organic and aqueous phases in the settling
tanks.This separation operation would be performed in four stages using a counter-flow
principle where the organic flow is introduced to the preceding stage and the aqueous flow
feeds the following stage.The depleted aqueous phase (raffinate)will be recycled to thecounter-current decantation stage or processed for the recovery of vanadium (Sect.3.2).The
uranium-loaded extract (organic solution)will be washed and stripped of uranium by contact
with an acidified sodium chloride solution;the resulting barren organic solution will be
returned to the solvent extraction circuit.
The milling process generally concludes with the recovery of the uranium from solution by
chemical precipitation.When acid leach methods are utilized,the uranium is precipitated by
neutralization with a base such as ammonia,lime, magnesia,or hydrogen peroxide.2 The precip-itate is then dewatered,dried,and packaged.At the White Mesa milT,the uranium-rich
solution from the stripping operation will be treated with ammonia to neutralize the solution,
precipitating ammonium diuranate,or yellow cake.The precipitate will then be thickened,
dewatered by centrifuge,dried in a multiple-hearth,oil-fired dryer (calciner),crushed to
minus O.G-cm (0.2S-in.)size in a hammer mill,and then packaged in 55-gal drums for shipment.
The drying,crushing,and packaging operations will be isolated and enclosed in an area that
is maintained at a negative air pressure to contain and collect (by wet scrubbing)airborne
U30S particles.As an alternative to the drying,crushing,and packaging operations,yellow
cake slurry can now be shipped directly to a UFs conversion facility.The applicant investi-
gated this alternative processing option but rejected it because of uncertainties concerning
the long-range availability of sufficient capacity at this type of conversion facility.
10.2.2 Uranium Milling Processes which Produce Low-moisture Tailings
There are several alternative uranium milling processes currently in u~e in other countries
which produce low-moisture tailings,which might be amenable to direct burial in unlined
disposal retention areas,such as depleted open-pit mines or specially prepared pits.
For example,a dewatering method developed by Burns and Roe/Pechiney/Ugine Kuhlmann utilizes
a belt-filtration process instead of conventional vacuum drum filters and thickeners to
separate the pregnant leach solution from waste solids.The liquid-solid separation method
proposed by the applicant will produce tailings that will be approximately 50%water by
weight;the rate of discharge will be approximately 1800 MT (2000 tons)of tailings and
1800 MT (2000 tons)of water per day.If the Pechiney milling technique,which uses a belt
filter,were to be implemented,the "cake"would be counter-currently washed in two stages,
with the barren tailings being dewatered to a moisture content of approximately 22%.The
tailings can be neutralized before or on the belt filter.The tailings would then be
belt-conveyor or truck transported to the tailings disposal site.Because the tailings are
essentially "dry,"the area required for tailings storage might be reduced;and the problems
associated with the control and monitoring of seepage from a disposal site might also be
decreased.The possibility of using this type of belt filtration process is dependent on
consistent physical characteristics in the ore processed,as this is the basis for the design
of the filter.The or~to be processed at the White Mesa mill will have a wide range of
physical and chemical characteristics.
The applicant evaluated the effectiveness of utilizing a belt filter or disk filter system to
reduce the moisture content of the mill tailings.The filtration circuit evaluated,however,
would not replace the proposed "thickener"liquid-solid separation process but would accept
the tailings from the thickener circuit and segregate the slimes and sands for separate dispos-
al.This alternative tailings disposal method is discussed in greater detail in Sect.10.3.2
(Alternative 3).
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10.3.1 Introduction
Post reclamation
Provide surety arrangements to ensure that sufficient funds are available to complete the
full reclamation plan.
10.3 ALTERNATIVE METHODS FOR TAILINGS MANAGEMENT
Each alternative tailings management plan has been evaluated against the following set of
performance objectives developed by the staff:
3.Design the isolation area so that seepage of toxic materials into the groundwater system
will be eliminated or reduced to the maximum extent reasonably achievable.
During operations
Siting and design
1.Locate .the tailings isolation area remote from people so that population exposures willbereducedtothemaximumextentreasonablyachievable.
2.Locate the tailings isolation area so that disruption and dispersion by natural forces is
eliminated or reduced to the maximum extent reasonably achievable.
10.3.2 Feasible alternatives for tailings management
Alternative 1:Tailings disposal in impoundment cells built,filled,and reclaimedinstages
This alternative involves the construction of a six-cell impoundment system with a safety dike
in a swa1e (shallow natural basin)immediately to the west and south of the proposed mill site.
Two of the cells will be used as evaporation ponds.As proposed by the applicant,the total
5.Reduce direct gamma radiation from the impoundment area to essentially background.
6.Reduce the radon emanation rate from the impoundment area to about twice the emanation
rate in the surrounding environs.
7.Eliminate the need for an ongoing monitoring and maintenance program following successful
reclamation.
4.Eliminate the blowing of tailings to unrestricted areas during normal operating
conditions.
8.
10.2.3 Evaluation of Proposed Millina Process
The milling processes proposed by the applicant are conventional,state-of-the-art techniques
utilized in the domestic uranium milling industry and are as environmentally sound as other
commonly used processing combinations.Further unforeseen developments,such as increased
processing costs due to changes in the characteristics of the ore or changes in the relative
costs of reagents,may result in the applicant proposing changes in the mill circuit.When
such changes are suggested,the environmental impacts associated with their implementationwillbeassessed.
For the purposes of this section,tailings management is defined as the control of the
tailings and waste solutions following removal of the uranium values.Engineering techniques
to control pollutants from tailings,both during operational and post-operational stagesofamillingproject,have been proposed.The unique characteristics of each facility.must
be identified,and then appropriate environmental controls must be applied.The staff has
examined alternatives considered by the applicant,3-S as well as alternatives considered
for other mills in preparing this section.6-10 Alternatives presently available or feasible
(i.e.,potentially available with existing technology and at a reasonable cost)are described
in Sect.10.3.2 and evaluated in Sect.10.3.3.A list of additional alternatives for tailings
management that the staff has concluded are not feasible with existing technology is presented
in Sect.10.3.4.
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tailings disposal area would be sized to contain 1800 metric tons (MT;2000 tons)per day of
tailings produced during 15 years of mill operation (see Fig.3.4).The proposed tailings
System involves simultaneous construction,operation,and reclamation of individual cells.As
one cell is being used for tail ings disposal,the previous used cen will be drying and the
next cell downgradient will serve as an emergency catchment basin (Sect.3.2.4.7).An
individual cell would be sized to hold approximately four years production of tailings and would
cover approximately 24 ha (60 acres)of surface area.Cells would be constructed by excavating
the bottom of the impoundment and by building successive embankments across the open (southern)
end of the swa1e to contain the tailings.The excavation of a limited amount of bedrock material
[1.5 to 1.8 m (5 to 6 ft)deep],in addition to overburden soil,would be necessary.Because a
high degree of weathering is anticipated at these depths,excavation would be accomplished by
ripping;no blasting would be used for excavation of the rock (exce t for localized lenses of
unweathered rock.Excavation slopes no steeper than 3:1 horizontal to vertica are specified
for slope and lining system stability.The dikes would be homogeneous,compacted,earth-filled
embankments constructed from soils present in the overburden at the tailings disposal site.Theembankmentswouldvaryinheightfromapproximately7.6 m (25 ft)for cell l-E to 13 m (42 ft)
for cell 5,where the dikes cross the lowest part of the swale.Each dike would be 6.1 m (20 ft)
thick at the crest to allow for an access road and would have side slopes no steeper than 3:1
(horizontal to vertical)(Fig.3.7).When passing between individual cells,the tailings
discharge pipe would b2 contained in an outer "emergency containment"pipe.The "emergency con-
tainment"pipe would be secured in a pipe trench lined with a double layer of synthetic liningwhichwouldbebuiltintothecrestsofembankments.The downstream slope of the final,
southernmost dike (cell 5)is the only dike that would ultimately have an exposed face (afterfinalreclamation);therefore,to reduce the potential for excessive erosion of this embankment
after cessation of mill operations,a 6:1 sloped layer of rock fill would be used in the con-
struction of the downstream segment of this dike (Fig.3.8).Additionally,to minimize water
and wind erosion during operations,excavated rock would be used to protect drainage channels
and to cover the exterior slopes on the perimeter of the impoundment.The entire tailings
retention system (including the cell 5 safety dike)would cover approximately 135 ha (333 acres)
of surface area if the mill were to operate at 1800 MT per day for 15 years;the total affected
acreage (includes land needed for stockpiling and borrow areas)would be approximately 195 ha
(484 acres).(See Table 4.3.),
To prevent seepage of liquid wastes from the impoundment facilities,the applicant initially
will line all interior surfaces of each cell with a state-of-the-art synthetic liner such as
PVC reinforced with a nylon scrim (the final liner and liner system specifications and the
program for installation,maintenance and inspection of the liner system will be reviewed
and approved by the NRC staff prior to use).To prevent puncturing of the synthetic
liner,a smooth (projection free)subliner of locally obtained cla,ye,y-silt soil would be
placed over the excavated rock surfaces of each cell floor.The entire synthetic liner
surface (including the liner on the upstream portion of the dikes)would be overlain with
30.5 em (12 in.)of clayey-silt soil to minimize liner deterioration caused by winds,sunlight,
and the tailings materials and also for protection from operating equipment.No slurry discharge
will be permitted directly onto the cell lining cover.Because (1)the cell floors would be flat
(2%slopes or less)for other than excavation slopes (no steeper than 3H:1V),(2)the cells would
be shallow impoundments,and (3)dense,relatively incompressible materials (Dakota Sandstone)
would underlay the liner,differential settlement should not be of sufficient severity to
compromise the liner integrity.
The expected net evaportion rate at the site is 0.9 m (3 ft)per year,and the total liquid
transported with the tailings would be 5.9 x 105 m3 (480 acre-ft)per year.On the slightly
sloping impoundment surfaces,the staff expects the tailings to drain and settle to a void
fraction approaching 0.34,which would contain pore water at 50%of saturation.This quantity
would be effectively bound by capillary forces at 0.17 m3 (0.17 ft3)of water for each cubic
meter of settled tailings or about 7.0 x 104 m3 (57 acre-ft)per year.With no'seepage,
equilibrium between input and evaporation would be achieved with about 56 ha (139 acres)of
ponded liquid.Because the surface areas of the evaporation cells would be only 40 ha,(98 acres),
the staff ha~concluded that corrective measures,such as recycling tailings solutions to the
mill,may have to be instituted to satisfy water balance requirements.However,this should
not be required because the moist tailings surface and the ponded slimes will provide at least
an additional 24 ha (60 acres)of evaporation surface in addition to the 40 ha (98 acres)of
evaporation pond.
10-10
During operations,a freeboard of 1.5-m (5 ft)minimum would be maintained in the evaporation and
tailings cells.In addition,interceptor ditches would be constructed to divert surface drainage
away from the operations and impoundment areas.These ditches,sized to pass the probable maximum
flood,would be constructed north,east,and west of the tailings and operating areas.Riprap
consisting of excavated rock,would be placed in the ditches to aid in preventing erosion.Ov~r
the long term,the interceptor ditches would fill with silt and become revegetated.The small
drainage area upgradient from the reclaimed tailings impoundment [upgradient drainage area is
0.065 km2 (0.025 sq mile)]obviates concerns over·dispersion of the cover from flooding.
Reclamation would be implemented sequentially for the tailings cells as each cell is inactivated
and as soon as an individual cell has dried sufficiently to allow the movement of equipment
over the pile.To reduce radon gas emanation and gamma radiation from the tailings to
acceptable levels,the applicant proposes to cover the tailings with a 0.6-m (2-ft)layer
of compacted clay obtained from offsite deposits,1.2 m (4 ft)of onsite clayey-silt materia~,
1.8 m (6 ft)of rock,and 15 cm (6 in.)of topsoil.Slopes on the perimeter of the cover would
be no steeper than 6H:1V and would be constructed of riprap.The compacted clay would be
designed and constructed to prevent damage by differential settlement.To revegetate the
tailings area,the applicant has proposed to seed the tailings cover with a mixture of grasses,
forbs,and shrubs.
Because the cap would be almost 4 m (13 ft)thick,the staff has concluded that root penetra-
tion into the tailings is not likely,reducing the possiblity of adverse impacts associated
with the upward migration of radionuclides and toxic elements through plant root systems.
Although the disposal area would be located in a relatively arid region,the proposed cover
is not expected to develop significant shrinkage cracks because the clay content of the soils
to be utilized is low (except for the imported,remolded clay).
The reduction of the gamma radiation that results from capping a tailings pile is dependent on
the degree of compaction and mass stopping power of the cover material.As shown in Appendix G,
similar cover was calculated by the staff to reduce the gamma radiation from the tailings to
approximately 1 x 10-7 mi11iroentgens per year,thus meeting the performance objective for
reduction of gamma radiation.
The radon flux at the surface of uncovered tailings was calculated by the staff to be approxi-
mately 439 pCi/m2 ·sec.The covering scheme proposed by the applicant [0.6 m (2 ft)of
clay overlain with 1.2 m (4 ft)of clayey-silt material,1.8 m (6 ft)of rock,and 15 cm
(6 in.)of topsoil]was estimated by the staff to reduce the radon emanation rate from the
reclaimed tailings area to approximately 1.16 pCi/m2 sec and meets the intent of the performance
objective for reduction of radon exhalation.These calculations will be experimentally
confirmed.
Discounting and deflating the expected costs to 1978 dollars (10%discount rate and 8%rate of
inflation per annum),the total estimated costs for this alternative is approximately
$20.7 million.(The costs for a synthetic liner for the entire impoundment and for the clay
comoonent of the cover are estimated at $5.5 and $2.0 million.respectively.)
The major benefits that could accrue with implementation of this tailings disposal alternative
are the following:
1.The tailings would be stored in the head end of a natural basin and below the ridges bounding
that basin on all but the southern(open)end.Although the tailings cover is only partially
below these ridges [at least 1.5 m (5 ft)],the slight grade «·2%overall)on the cover and
small upgradient drainage area [0.065 km2 (0.025 mi 2)]should provide a high degree of pro-
tection from wind and water erosion.Slopes on the perimenter of the impoundment cover
would be no steeper than 6H:1V and would be constructed of riprap.The entire area would be
revegetated;and a layer of riprap would be placed on all exposed slopes around the impound-
ment,further minimizing potential erosion problems.Although the downstream side of the
last dike (on cell 5)has an exposed face.it will have a 6:1 slope and will be constructed
of rock overburden.
2.The cellular design allows staged reclamation.minimizing the quantity of tailings exposed
at anyone time.Ove~burden storage and handling requirements are also reduced,that is,
overburden removed during excavation of later cells can be transported directly to cells
being reclaimed.
3.The low dikes and the shallow depth of the cells increase dike stability.
10-11
Alternative 2:Be1ow-rade burial in a s it
.alternative involves the excavation of a basin of sufficient size and depth to store allThl~he tailings and tailings cover completely below grade.The impoundment would be linedo~h a synthetic liner to minimize seepage from the disposal area.After completion of fill
w1t ations and as the tailings reach sufficient dryness to allow the movement of equipmentope~the pile,the tailings would be covered with compacted clay,locally obtained rock andoV~l and topsoil in the same configuration as proposed for Alternative 1.Therefore,the~~~o~gas and gamma attenuation estimates would be the same as for Alternative 1.
I the version of this alternative proposed by the applicant,the tailings would be stored
bnl OW grade;but the tailings cover would protrude above grade.However,a true below-grade~s osal system would have to include the cover below grade,which would require modifica-~~o~s in the applicant's proposed plan.Further excavation downward would significantly increase
\ts and would require extensive blasting to remove unweathered Dakota Sandstone.Implement-~~g either version of this alternative would be advantageous as no retention embankment would be~equired;thus the probability of release and dispersion of tailings would be minimized.
The estimated cost of Alternative 2 is $32.6 million (discounted to 1978 dollars).This does
not include the cost of the additional excavation of bedrock that would be required to make the
system "below grade".The benefits that this alternative might have over Alternative 1 do not
justify the additional costs.
Alternative 3:Filtered tailings disposal
This alternative features partially below-grade burial of dewatered tailings in unlined basins
or trenches.Dewatering would be accomplished by either horizontal belt-type or disc-type
vacuum filters.The filtration circuits would not replace the proposed "thickener"liquid-
solid separation process but would accept the tailings from the thickener circuit and segre-
gate the liquids and solids for separate disposal (see Fig.10.3).The dewatered tailings
would be transported to the disposal area either by truck or by a portable conveyor system.
The liquid filtrate would be discharged to three 28-ha (70-acre)lined evaporation ponds.
After completion of milling operations,the ponds would dry out.Soluble residue and con-
taminated clays and underlying materials would be removed from the pond areas and buried in
the tailings disposal area.The evaporation ponds would be constructed above grade,would vary
from 1.8 m (6 ft)to 2.4 m (8 ft)in depth,and would be lined with a clayey-silt material
available onsite.
The major disadvantages associated with the implementation of this alternative are as follows:
1.The tailings would be partially above grade,and the long-term stability of the
reclaimed tailings impoundment would be questionable.
2.The absence of an impermeable liner under the evaporation pond increases the possibility
of long-term leaching of toxic elements from the tailin9s.(The impermeability of
the compacted clayey-silt material has not been proven.)
The total volume of tailings produced over the 15 years of project operation woul d approach
6.88 x 10 6 m3 •This volume would cover an area of 160 ha (400 acres),4.6 m (15 ft)deep.To
balance excavation quantity (4.74 x 106 m3)and cover requirements,the applicant proposes to
construct a 160-ha (400-acre)impoundment,3 m (10 ft)deep.This design would result in a
tailings projecting 1.5 m (5 ft)above grade and the tailings cover completely above grade .
The same cover scheme proposed in Alternative 1 would be utilized.
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The reliability of the filter system would be questionable due to the wide variety of
ores to be processed by the proposed mill.
The total cost of this alternative is a function of the dewatering system and tail ings transport
system chosen.With haulage of dewatered tailings by truck or by conveyor belt and filtration
by horizontal belt or disc filters,the costs range from approxi~ately $24.7 to $25.0 million.
(The cost of the clay cap would be approximately $2.4 million.)
Fig.10.3.Filtered tailings disposal belt extractor flow diagram.Source:Energy Fuels Nuclear,Inc.,adopted from
Fig.3-14 in "Investigations of Alternative Tailings Disposal Systems,White Mesa Uranium Project,Blandin9,Utah,"April 1978.
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10-13
lternative 4:Solidification of tailings utilizing cement,asphalt,or other chemical fixants~
this option,~i1l tailings would be fixed with cement,asphalt,or other chemicals to form
I"solid,less leachable product for disposal.The solidified tailings could then be stored tn
a impoundment.The disposal area would be reclaimed by covering the material with layers of~~erburden and topsoil and revegetating it to minimize water and wind erosion.
rt1and cement could be utilized to fix either the entire tailings solids or the slimes only.i~either case,the tailings would be neutralized (probably by the addition of lime),and the
as te slurry would be dewatered to a minimum of 60%solids before being mixed with the cement.~minimum of 1 part cement to 20 parts tailings would be required for solidification;strength,
leaching resistance,and cost increase as the ratio of cement to tailings increases (ref.11,
p 43).The 1:20 cement to tailings mixture could be pumped,if necessary,via a slurry pipe-
line to a disposal site.
Neutralized,dewatered (dried)slimes and waste solutions could be fixed with asphalt,and the
final product would contain approximately 60%slimes solids (ref.11,p.42).When first
mixed,the product would be fluid and could be shipped via a pipeline to a disposal site.The
major advantages of solidifying tailings in asphalt are (1)leaching resistance is high and
(2)radon exhalation is reduced because asphalt is an effective radon diffusion barrier.
Commercially available chemical fixantscou1d also be used to solidify the tailings.If this
waste stabilization method were to be implemented,the chemicals would be blended into the
tailings slurry and the resultant mixture pumped to an impoundment where solidification would
occur within a few days to a few weeks.The waste material would either be entirely entrapped
or the pollutants (primarily heavy metals)would be chemically bound in insoluble complexes.4
Although theoretically feasible and environmentally desirable,solidification of tailings is
expensive.The applicant investigated the costs of utilizing chemical fixants to solidify the
tailings,finding the costs to range from $7 to $36 per ton of treated tailings.4 If a nominal
cost of $10 per ton of tailings is assumed,chemically fixing the waste material produced by
15 years of mill operation would cost approximately $91.3 million (discounted to 1978 dollars).
The staff estimates that the costs of asphalt or cement fixation would range from $90 million
to $105 million..
Alternative 5:Conventional above-grade tailings disposal using an engineered embankment
to retain the tailings
This alternative consists of creating a tailings impoundment by constructing a dike to enclose
the lower end of the natural basin south of the proposed mill site (Fig.10.4).A full-height
engineered embankment constructed of borrow material would be used to retain 15 years of mill
tailings.Because the basin created by the embankment would be filled with tailings by distri-
bution from the top of the dam,construction of the embankment would have to be completed
before the system could be used.The downstream segment of the embankment would be construc-
ted of permeable sand.To minimize seepage,the upstream section would be constructed of
compacted clayey-silt and silty-sand and would be tied into the soil liner on the bottom of
the impoundment.The dam would be approximately 20.7 m (68 ft)high,with a freeboard allow-
ance of about 1.5 m (5 ft)for wave protection.The tailings reservoir would cover approxi-
mately 103 ha (250 acres).To prevent erosion of the downstream dam slope,15 cm (6 in)of
gravel,overlain with 30.4 cm (1 ft)of riprap or a 10 em-thick (4 in-thick)concrete cap
reinforced with wire mesh,would be placed over the downstream segment.The floor of the
impoundment would be lined with 0.6 m (2 ft)of compacted.locally obtained clayey-silt material
to 1imi t seepage from the impoundment.
After the completion of mill operations and as the ta'ilings reach sufficient dryness to allow
the movement of equipment over the pile,the tailings would be covered with layers of compacted
clay,clayey-silt material,and topsoil of the same configuration as proposed for
Alternative 1,and the area would be revegetated with appropriate plant species.
The total estimated cost for this alternative is $9.0 million (discounted to 1978 dollars)if
riprap is used for slope protection.The cost of the clay cap is roughly $1.5 million.
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10-14
ES-4827
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Fig.10.4.Conventional disposal,engineered embankment -full height.Source:Energy
Fuels Nuclear,Inc.,Fig.3-3 in "Investigations of Alternative Tailings Disposal Systems,
White Mesa Uranium Project,Blanding,Utah,"April 1978.
10-15
Alternative 7:Segregated disposal
In this alternative,tailings sands would be separated from slimes and liquids.The dewatered
sands would be placed in unlined trenches,and the slimes and liquids would be discharged to
clay-or synthetic-lined evaporation ponds (Figure 10.6).
The sands disposal area would cover approximately 126 ha (310 acres)and would consist of a
series of parallel,unlined trenches.The total excavation requirements for the area would approach4.18 x 106 m3 .Sands would be placed in the trenches by a "Mobile Disposal Unit,"which would
(1)receive the total slurry,(2)remove the sands from the slurry by means of either standard
hydrometallurgical cyclones (hydrocyclones)with or without a dewatering screen,and
(3)would deposit the moist sands (20 to 25%moisture)in the unlined trenches.The deposited
sands would drain to 15 to 20%moisture,and all drainage would be recycled to the mill.Use
of the hydrocyclone-dewatering screen option would result in drier sands being deposited,thus
minimizing the seepage from the trenches.Each individual trench would be reclaimed after it
is filled.The sands would be leveled to the natural grade and a 2.7-~(9-ft)layer of com-
pacted clayey-silt material would be placed over the sands to limit radon emanation and to
protect the sands against erosion.
Slimes and liquids would be directed to a 36-ha (90-acre)evaporation pond.The applicant has
examined four alternate pond configurations:two above grade (lined with onsfte soils),one
partially below grade (synthetic-lined),and one below grade (synthetic-lined).Engineered
embankments would be constructed for the above-grade and partially above-grade options,and the
below-grade option would not require embankments.
The major differences in the costs of the alternative configurations are related to the amount
of excavation necessary in construction of the ponds.Dike construction for the above-grade
option would require 1.13 x 106 m3 of fill materials from onsite borrow areas.The partially
above-grade option would result in the excavation of 1.53 x 106 m3 ,with 305,800 m3 being used
in embankment construction.The below-grade option would result in the excavation of
5.35 x 106 m3 of material,of which 2.78 x 106 m3 would be solid rock.
Reclamation would be achieved by covering the area with a suitable radon diffusion barrier
over the dry slimes.Given the high radium content of the slimes,the staff feels that theCOverconfigurationproposedinAlternative1couldbeinadequatefortheslimesarea.
The applicant also.investigate~the con~t~uction of ~n engineered ~mbankment.in sta~es,with
ch stage being slzed to retaln the talllngs from flve years of mlll operatlon.Wlth the
eaception that the dam would be exposed to er?sion durinQ the operational p~riod (because noe~prap could be adequately placed until the flnal stage ~s completed~,the l~pacts of staged
r mconstruction would be about thp same as would occur lf a fulJ-helght englneered embankmentd:re to be used.The cost would be approximately $9.4 million (discounted to 1978 dollars).~hiS estimate does not include the cost described above for the clay cap.
Alternative 6:Conventional above-grade tailings disposal utilizing an evaporation pond for
~rage of llquid wastes
This alternative consists of discharging the tailings slurry into a segmented settling pond,
with liquid wastes bein9 decanted into an evaporation pond.The settling basin and the evapora-
tion pond would be enclosed by engineered embankments (Fig.10.5).The evaporation pond would
be 1200 m (4000 ft)by 165 m (540 ft),or 20.3 ha (49.5 acres).The main basin would cover
approximately 103.7 ha (253 acres).The maximum height of the settling pond embankments would
be 12 m (40 ft);the dam around the ev~poration pond would be about 9 m (30 ft)high.Small
embankments constructed of tailings sands would be constructed in the main basin to create five
segments.Tailings would be delivered to the tops of these dikes,with the excess liquids being
decanted into the pond area outside the tail~ngs impoundment.As each divided segment is filled
to design capacity,it would be allowed to dry and then covered with a layer of compacted clay,
soil material,and topsoil of the same configuration as proposed for Alternative 1.The
main basin and the evaporation ponds would be lined to limit seepage with a 0.6 m (2 ft)linerofclayey-silt materials.The lengths of the embankments required to surround the impoundments
would be approximately 4180 m (13,700 ft)for the settling basin and approximately 1550 m
(5080 ft)for the evaporation pond.The total cost of this alternative would be approximately
$10.7 million (discounted to 1978 dollars).The cost of the clay cap is $1.8 million.
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Fig.10.5.Conventional disposal,segmented settling pond and evaporation pond.Source:
Energy Fuels Nuclear,Inc.,Fig.3-6 in "Investigations of Alternative Tailings Disposal systems.
White Mesa Uranium Project,Blanding,Utah,"April 1978.
Fig.10.6.Segregated <lisposal area -general layout..Source:Energy Fuels Nuclear,Inc.,Fig.3-8 in "Investigations of
Alternative Tailings Disposal Systems,White Mesa Uranium Project.Blanding,Utah,"April 1978.
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Above-grade slimes
Partially below-grade
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Below-grade slimes
Above-grade disposal
with several small ponds
$16,924,000
$25,350,000
$31,571,000
$16,924,000
$16,720,000
$25,147,000
$31,368,000
$16,720,000
Hydrocyclones only
The cost of this alternative as estimated by the applicant is a function of the slime-sand
separation method and of the slime pond configuration chosen (the increase in costs due to
increases in cover material thickness over the dried sl imes is not inc'luded):
Hydrocyclones and
dewatering screens
10-18
Alternative 8:Neutralization of tailings
This alternative consists of treating the acidic tailings with various bases to yield a
neutral solution.According to ref.11,pp.132 and 133,neutralization II •••causes the
precipitation of 90%of the radium,almost all the thorium,and much of the iron,copper;
cobalt,arsenic,uranium,vanadium,and other heavy metal ions as insoluble oxides or hydrox-
ides ..,Seepag~from neturalized,compacted tailings covered by a pond,or runoff from
neutralized tailings,carries very little radium,in contrast to seepage or runoff from unneu-
tralized tailings which may carry dissolved radium.1I
In Canada,liquid wastes from acid-leach uranium mills are routinely neutralized prior to
discharge to natural waterways.Neutralization reportedly requires about 7.3 kg (16 lb)of
limestone (CaC03 )and 4.5 to 22 kg (10 to 48 lb)of lime (Ca[OH]2)per ton of ore.12 A theo-
retical value of 15.6 MT (34.4 tons)per day of lime for an 1800 MT (2000 tons)per day millhasbeenreported.11 The White Mesa Uranium Project would be processing approximately 1800 MT
(2000 tons)of ore per day for 340 days per year;therefore,neutralization could require
approximately 11,000 MT (12,000 tons)per year of lime [assuming 32 MT (35 tons)per day].
The applicant investigated the possibility of introducing milk of lime into the tailings
stream to neutralize the tailings effluent.Neutralization could be applied to any of the
tailings disposal alternatives discussed in this section.For alternatives 1,2,and 6,the
applicant estimated that neutralization of the tailings would precipitate about 91 kg (200 lb)
of salts (including water of hydration)per ton of tailings.The precipitate would be gelati-
nous and of low density,and the total volume of tailings would increase slightly.The total
capital and operating costs for neutralizing 15 years of mill tailings was estimated to be
approximately $18.55 million (discounted to 1978 dollars)for these alternatives.
The applicant also evaluated the consequences of neutralizing the slimes portion of the tailings
produced by segregating the slimes and sands (see Alternative 7).The applicant estimated that
approximately 82 kg (180 lb)of salts would be precipitated per ton of tailings,increasing the
weight of the slimes and reducing the resulting mixture to approximately 40%solids.The
applicant also estimated that to maintain an adequate evaporative rate,the evaporation pond
would have to be doubled in size to approximately 73 ha (180 acres).(About 36 ha (90 acres)
would be needed for unneutralized slimes.)The total capital and operating costs for neutrali-
zation of only the slimes portion of the tailings were estimated to be $16.34 million,assuming
15 years of mill operation and discounted to 1978 dollars.
10-19
Is
10.3.3 Evaluation of alternatives
lternative 1 is the preferred alternative of the applicant and the staff.The tailings would
A stored in the head end of a natural basin and below the ridges bounding that basin on all
bet the southern (open)end.Although the cover is only partially below these ridges (approxi-
bU te1y 5 of the 12.5 ft of cover),the final grade on the reclaimed impoundment is slight «2%),
mad the slopes on the perimeter of the cover would be no greater than 6H:1V and would be
anstructed of riprap..Revegetation of the area and the placement of containment material (riprap
con concrete)on all downstream slopes would minimize wind and w~ter erosi~n.In addition,the0~11 drainage area above the reclaimed tailings area [0.065 km (0.025 mi )]obviates concerns
s er dispersion of cover from flooding which can be a severe problem over the long term.There-~vre the proposed cover meets the performance objectives for reduction of radon exhalationa~d gamma radiation and should eliminat~the n~ed for an ongoing monitoring ~nd maintena~c~.
ogram.The segmented impoundment deslgn,WhlCh allows for staged reclamatlon,would mlnlmlze~~ilingS exposure during operations.Theliners.on cell interiors would essentially eliminate
seepage.
Storing the tailings below grade (Alternative 2)in a specially dug pit would mlnlmlze 10ng-
term wind and water erosion of the reclaimed tailings impoundment.In addition,the proposed
cover (same as for Alternative 1)would meet the radon exhalation and gamma radiation criteria.
However,to provide sufficient pit capacity to contain both the tailings and cover completely
below grade,significant amounts of bedrock would have to be excavated by blasting,which could
fracture the bedrock increasing its permeability substantially.Because the water table is only
15 to 23 m (50 to 75 ftl below the surface and the pit would be deep (7.6 to 9.2 m (25 to 30 ft)),
any failure of a liner could result in liquid wastes reaching the water table through these
fractures.In addition,the cost of this excavation could be prohibitive.
Alternative 3 involves dewatering the tailings.The ~ajor disadvantages for this dewatering
alternative as proposed by the applicant are that the tailings themselves would be partially
above grade and susceptible to long-term wind and water erosion following reclamation and that
the success of filtration,which depends greatly upon the amenability of the ores to the method
chosen for filtration,would be questionable because of the variability of the ores.Also,the
clayey-silt 1iner proposed for the evaporation pond has not been shown to be capable of reducing
seepage to the maximum extent reasonably achievable.
Alternative 4 involves solidification of tailings.Although this could be environmentally
attractive,the technology is not well established,and at present,the costs far outweigh any
benefits that might accrue.
Alternative 5 consists of conventional above-grade dam and pond systems.The reclaimed impound-
ment area would be highly susceptible to wind and water erosion and would not eliminate the need
for ongoing monitoring and maintenance over the long term.In addition,the proposed clayey-silt
liner has not been shown to be capable of reducing seepage to the maximum extent reasonably
achievable.
Alternative 6 consists of discharging the tailings slurry into a segmented,above-grade settling
pond and transferring the tailings liquids to an enclosed,above-grade evaporation pond.The
reclaimed impoundment would be susceptible to erosion over the long term.Also the proposed
liner has not been shown to be capable of reducing seepage to the maximum extent reasonably
achievable.
Alternative 7 involves the segregation of tailings sands from the slimes and liquids and
disposal of the sands in unlined trenches and storage of the slimes/liquids in clay-or synthetic-
lined impoundments.The slimes ponds would be either above grade,partially below grade,or
below grade.The proposed alternative would result in above-grade systems that would be highlysusceptibletoerosion.Also,the,cover over the slimes might not reduce radon eXhalation to two
times background.
Table 10.1.Alternatives considered and rejected
10-20
Reason for rejection
Technology is not developed (would
require a selectively permeable
bottom 1iner)
Technology is not available to allow
seepage water treatment sufficient
to attain water that is environ-
mentally and legally acceptable
for release
Control of transportation,unloading,
storage,and placement of the
wastes in the many small mines as
well as monitoring and control of
radon gas emissions,particulate
emissions,groundwater contamination,
and other detrimental impacts would
be very djfficult (Sect.10.1.1)
Additiona1 overburden and topsoil
would be required to reduce gamBI
radiation to the natural background
level.to prevent plant root
penetration into the tailings,and
to minimize erosion problems.The
cost of the cap would be excessive,
campared to cost of the soiI the
liner would replace.The integrity
of the liner could not be guaranteed
over the long-term due to the effects
of freezing and thawing cycles,settle-
ment of the tailings,and possible
chemical attack by the tailings
The envirol1lN!ntal hazards and the costsofmitigatingtheadverseimpacts
associated with tailings disposal
would only be Shifted fl'Olll the
Blanding area to another location.
The closest active disposal areas are
located in Moab and LaSal.Neither
impoundment is capable of holding
the design output of the proposed .ill.
Additionally,transport of tail1ngs
would incur risks of accidents.dis-
persal of tailings,and exposure to
workers and others along the transport
route
Transport of tailings to currently active
tailings impouncnents
Alternative
Covering of the tailings with a synthetic
liner material such as concrete,asphalt,
or PVC plastic to reduce radon emanation
Precipitate radioactive and toxic elementstobottomofthetailingspond3ndconsidertopoftailingsascover
Install drains below pond to collect and
discharge to a local waterway
Offsite disposal in mines
10.3.4 Alternatives considered-and rejected
Table 10.1 lists some of the additional alternatives considered and rejected.
N~utrali~ati~n of the entire tailings (Alternative 8)might partially eliminate the need.for a
llner WhlCh lS needed to prevent seepage,however,it has not been shown capable of retarding th
movement of anions in the tailings.Neutralization of the slimes produced after segregation Ofe
sands from slimes (Alternative 7)or neutralization of dewatered·tailings (Alternatives 3 or 6)
would appear to be the most effective programs.However,the supplemental costs for neutraliza_
tion would be high,and are not considered to be justified at the present time by the benefits
gained at the White Mesa site.
For all of the alternatives considered,the applicant would be required to implement an interim
stabilization program to minimize the blowing of tailings to the maximum extent reasonably
achievable.
Based on the above d.iscussion and evaluation of alternatives,the staff believes that the
tailings management plan described under Alternative 1 is the best plan for the White Mesa
site when considered in terms of both the staff's performance objectives (Sect.10.3.1)and
economic factors.This alternative represents the most environmentally sound,reliable,and
reasonable method of tailings management for the proposed White Mesa site using existing
commercial technology.It should be noted that the choice of the preferred alternative isoaseoonpresentstanoarosandexistingtecnnologies.However,if the final Generic Environ-
mental Impact Statement on Uranium Milling and associated regulations show that modification
0;=~:le chosen alternative is necessary,the plan will be changed accordingly.
10-21
1.
2.
a
the
of
6)
iza-
ts
rim
I-
I
10.4 ALTERNATIVE OF USING AN EXISTING MIll
The option of utilizing existing ore processing mills requires the evaluation of numerous
factors,including (1)the method and distance of mine-to-mil1 transport,(2)variations in
ore grade,("3)qual ity of haul roads,(4)total tonnage to be transported,(5)haul age sched-
ules,(6)traffic and weather conditions,(7)possible interim transfer and storage costs,
(8)handling and milling costs,and (9)environmental costs and benefits.
The nearest currently operating uranium ore processing facilities (in relationship to the
app1icant 's Hanksv ill e and B1andi ng ore buyi ng stations)are located in Moab,Utah;la Sal,
Utah;and Uravan,Colorado.The approximate highway dist~nces of these mills from the Hanks-
ville and Blanding stations are,respectively,Moab,189 km (118 miles)and 134 km (84 miles);
La Sal,243 km (152 miles)and 74 km (46 miles);and Uravan,339 km (212 miles)and 170 km
(106 miles).
Although the mill located in.la Sal (Humeca)is reasonably close to the Blanding ore buying
station,it would have drawbacks as an ore processing alternative for the following reasons:
The Humeca mill utilizes an alkaline leach process.Although tests conducted by the
applicant indicated that some of the ores bought by its ore buying stations could be
successfully treated by alkaline leaching,higher recovery rates could be obtained with
acid for the majority of the ores.Because most of the ores are low grade (about
0.125%),any significant lowering of recovery rates would decrease the economic feasibil-ity of ore shipment from the scattered,small mining operations.
Currently,only ore from a company-owned and company-operated mine is being processed;
therefore,it is questionable whether the mill has the capacity,processing capability orthewillingnesstoacceptadditionalore..
The mills at Moab and Uravan utilize acid leaching (the Moab mill also has an alkaline leach
circuit);therefore,with process adjustments,acceptable recovery rates could be obtained.
However,primarily because of high haulage costs and the limited capabilities of the mills to
process additional ore,the staff has concluded that processing the ores at either or at both
of these mills is not feasible.Assuming that (J)transportation costs are lOt per ton-mile6
and (2)the average grade of the ore bought at the applicant's Hanksville and Blanding ore-
buying stations will be 0.125%,the staff estimates that,if the ore is shipped to these
currently operating mills,costs of producing each pound of U30a would increase by the following
amounts for additional transportation costs alone (i.e.,does not include incremental cost
for toll milling):
1.Moab mill -$3.20 per pound.
2.Humeca mi 11 (la Sal)-$3.04 per pound.
3.Uravan mill -$7.84 per pound.
Transporting the ores to existing mills could reduce the total land requirements for processing
the ores.However,the environmental costs associated with uranium ore processing and tailings
disposal would not be decreased and would only be shifted away from the Blanding area to theareaof the mill receiving the ore.If the proposed mill is not constructed,there is a high
probability that other mills (or expansions in capacity of existing mills)will be proposed in
the area to process the ore now programmed for the applicant's mill.If no mills (or expan-
sions)are constructed,a substantial economic base for the Hanksville-Blanding area will be
removed because many of the small independent mines would not be economically viable.
Table 10.2.Relel'Ves and currentconsumption of energy lOurces
Source:U.S.8ureau of Mines,United States Energy through the YNr2000.December 1975.
18
46
28
3
5
Percentage of total U.S.energy
consumption contributed by
each energy resource
90
3
4
3
o
Percentage of proven U.S.energy
reserves economically recoverable
with existing (1975)technology
Coal
Oil
Gas
Nuclear
Other
Table 10.3-Forecast of groD energy consumption for 1980, 1985,and 2000
1980 1985 2000
Fuel Percentage Percentage Percentage10'2 Stu of gross 10'2 Btu of gross 10'2 Btu of gross
Coal 17,150 19.7 21,250 20.6 34,750 21.3
Petroleum 41,040 47.1 45.630 44.1 51.200 31.3
Natural gas 20,600 23.6 20,100 19.4 19,600 12.0
Oil shale 870 0.8 5,730 3.5
Nuclear power 4,550 5.2 11,840 11.4 46.080 28.2
Hydropower and
geothermal 3.800 4.4 3.850 3.7 6,070 3.7
Totals 87,140 100.0 103,540 100.0 163,430 100.0
10-22
10.5 ALTERNATIVE ENERGY SOURCES
10.5.1.1 Introduction
Source:Tetra Tech.Inc.,Energy Fact Book -1977.prepared under the direction of
the Director,Navy Energy and National Resources Research and Development Office,
April 1977.
Despite concentrated efforts to slow down our consumption of-oil and natural gas,increase the
usage of coal-burning facilities,and further-the utilization of nonconventiona1 energy sources,
energy demand forecasts indicate that by the year 2000,approximately 43%of our energy will
still be supplied by oil and gas,21%by coal,and only a small percentage (7%)by solar,geo-
thermal,and oil shale (Table 10.3).15
The use of uranium to fuel reactors for generating electric power is relatively new histori-
cally.Coal was the first fuel used in quantity for electrical power generation.Coal use
was reduced because of the ready availability and low price of oil and natural gas,which are
cleaner burning than coal and easier to use.Uranium fuel is even cleaner (chemically)than
oil or gas and at present is less expensive,on a thermal basis,than any other fuel used to
generate electric power.The following discussion concerns the relative availability of fuels
for power generation over the next 10 to 15 years and a comparison of the health effects of
utilizing coal and/or nuclear fuels as energy sources.
10.5.1 Fossil and nuclear fuels
10.5.1.2 Overview of U.S.energy usage and availability
According to the NationaZ Energy PZan,published by the Carter Administration in April 1977,
the United States uses more energy to produce goods and services than any other nation and
consumes twice as much energy per capita as does West Germany,which has a similar standard
of living.13 In 1975,the United States consumed approximately 71 quadrillion Btu's
(71 x 1015),or 71 quads (q),of energy,with about 93%of this energy being supp1 i ed by three
fossil fuels:oil.natural gas,and coal.14 Approximately 75%of our energy needs are
suppled by natural gas and oil;however,because domestic supplies of these valuable resources
are limited (about 7%of proved reserves are oil and gas),the amount of oil imported from
foreign sources has increased,undermining our military and economic security.14 Table 10.2
illustrates the disparity between availability and usage of energy sources in the United States.
10-23
-,
Of the 71 q of energy consumed in the United States in 1975,20 q consisted of electric energy.
An estimated 8.6%of t~is electric en:rgy was generated using nuclear fuels,bu~within ten
ears this percentage lS expected to lncrease to 26%.Coal was used for produclng 59%of the~lectric energy generated by combustion of fossil fuels in 1975-;oil and gas produced 20 and
21~respectively.Use of oil and gas to generate electric power has decreased about 10%over
_th;last three years,a reflection of high oil prices and gas unavailability.IE
current and projected regu~rements for electric energy (1970-1985)and relative changes in
resources used for generatlon,as estimated in the Project Independence report,l7 are shown in
Table 10.4.The evidence ayailable at this time indicates that,of the resources currently
used in electric-power $eneration (coal,uranium,oil,gas,and hydro),coal and uranium must
be used to generate an lncreasing share of U.S.en~rgy needs.The supplies of oil and gas
available for electric power generation are decreasing,and the United States dces not have
sufficient oil and gas reserves to ensure a long-run supply.
Table 10.4.Estimated relative changes in resources to be used
for generation of projected electric energy requirements
Thermal energy required by years,%
Fuel resource used
1970"1974b 19sd'1985"
Coal 45 45 45 46"
Oil and gas 38 34 25 16
Nuclear 2 4d 17 26
Hydro,waste,etc.15 17 13 12
Total qUads ofenergy
required 15.6 20 25.5 34
•Actual.
b Estimated from Federal Energy Administration,National
Energy Outlook.U.S.Government Printing Office,Washing·
ton,D.C.,February 1976.
ceoal usage must increase 77%by 1985 to attain this level.
dUranium.fueled reactors furnished 9.9%of the total U.S.
production in January 1976.
Source:Federal Energy Administration,Proiect tndeptNld·
enea,U.S.Government Printing Office,Washington,D.C.,
November 1974.
With increasing energy demands,both foreign and domestic,expectations are that in the next
few decades the prices of oil and and gas will increase rapidly as reserves of these two
resources become severely depleted.Because of the time lag between initial extraction and
consumption of the rasource for energy production (three to five years from mine to generation
plant for uranium and coal,five to seven years for construction of a coal generating plant,and
seven to ten years for construction of a nuclear generating plant),the exploitation of both
coal and uranium resources must be integrated with contemporary energy needs.Although coal
and uranium resources are adequate for foreseeable energy needs,major expansion of both
uranium-and coal-producing industries will be required,as neither of these industries is con-
sidered capable of singly supplying future energy requirements.
The determination of availability of uranium in large enough quantities to fuel the projected
nuclear generating capacity (for 1985 and beyond)is currently a matter of study.lS Results
of those studies are given in Appendix B,which includes an estimate of reactor installation
through the year 2000 and the relative percentage of total electricity-generating capacity
these new installations would represent.
10.5.1.3 Coal production
Congress and the Carter administration have stressed,via passed and proposed legislation,
the necessity of future decreases in oil and gas demand to alleviate our dependence on foreign
energy sources and to reorient our energy consumption patterns.The Projeat Independence
report of November 1974 and the NationaZ Ene~gy OutZook of February 1976 both proposed that
Table 10.5.Uranium requirements
Source:Federal Energy Administration.National Energy
Outlook.U.S.Government Printing Office.Washington.D.C.•
February 1976.
•Each costcategory includesall lowercost reserves andresources.
bReserves are in known deposits.
cProbable resources have not been drilled and sampled as extensively as
reserves.
dPossillle and speculative resources have been estimated by inference from
geologicevidence and limited sampling.
Source:Department of Energy.Smistical D.r.of tIM U"",ium Industry,
Report GJO·l00(78).Jan.1.1978.
165.000
415.000
565.000
0.6
704.000
490.000
1.135.000
1.515.000
0.8
960,000
Lifetime U30a requirements (tons)
for specified plant factor
Potential resources ltons)
Probablec Possibled Speculatived
540,000
1.015.000
1.395.000
370,000
690.000
890.000
ReserveI'
(tonsl
Table10.8.U.S.uranium IU30e1 _rees
MWe operating
by 1985
142.000
15
30
50
Costcategor'"
($/Ib)
10-24
coal production be increased from present levels (approximately 650 million tons per year)to
approximately 1.2 billion tons by 1985.16 ,17 The major expansion of coal production will likely
be in the west (from ~pproximately 92 million tons in 1974 to about 380 million tons in 1985),
because of·the low sulfur (low air pollutant)content of most western coals.The potential for
environmental damage (due tc disturbance of generally fragile ecosystems)in the western
United States will be increased.Because the major markets for the coal produced will be located
hundreds of miles from the western mines,transportation costs will be high,as w~ll the envi.
ronmental impacts associated with transportation systems.Currently,transportiltion costs for
bringing western coal to the eastern United States account for the major portion of the market
price.Also,for a given thermal content,transport facilities for U30S per year are minimal
compared to those for coal because of the much higher energy content of uranium fuel.Approxi-
mately 250 tons of U30S per year are required for a 1000-MW nuclear plant operating at a plant
factor of 0.8.Annual western coal requirements for an equivalent 1000-MW coal p1ant would be
more than 3 x .106 tons,or the load capacity of at least one unit-train (100 cars of 100 tons
each),per day of plant operation.
10.5.1.4 Uranium fuel production
Estimates presented in the NationaZ Energy OutZook 16 indicate that 140,000 to 150,000 MWe of
nuclear generating capacity will be needed to supply 26%of the total electrical energy used in
1985.The first Project Independence report17 indicated that nuclear capacity could increase
to more than 200,000 MWe by 1985.A more recent and lower estimate resulted from lower projec-
tions of electricity demand,financial problems experienced by utilities,uncertainty about
government policy,and continued siting and licensing problems.The more recent projections
of uranium requirements are given in Table 10.5.
Table 10.6 presents estimates of quantities of uranium available at different recovery cost
levels.Assuming reserves recoverable at a forward cost of production up to $30/lb of U30S,
the Department of Energy (DOE)estimated that in January 1978 the total of all variously known
categories of uranium resources was approximately 3.48 x 106 tons.19 An estimated 6.9 x 10 5 tons
of these resources consisted of known reserves;that is,drilling and sampling have established
the existence of these deposits beyond.reasonable doubt.19 Approximately 5.2 x 105 tons of
U30s could be recovered from very low grade are and Chattanooga shale for about $100/lb and
approximately 4 x 109 tons of U30S from seawater for an estimated cost of between $300/1b and$750/lb.20 ,21
I ...::
I
I
..J.•..
-,..-...
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ly
10-25
Historically,resources of uncertain potential have become established at an average rate of
7%per year since 1955.17 If this rate were to persist over the next decade,total reserves
would exceed requirements (1,340,000 tons of reserves vs a maximum 960,000 tons required for
lifetime nuclear generating capacity rated at 142,000 MWe)by about 380,000 tons.Assuming
nO transfer of possible resources into the "probable"category,probable resources would still
contain 430,000 tons.'
Mill capacity in the United States as of January 1978 was 39,210 tons of are per day.These
mills operated at 79%of capacity in 1977.Uranium oxide output was approximately 14,946 tons,
equivalent to about 2.5 lb of U30S per ton of ore.
A survey of U.S.uranium marketing activity completed by ERDA in May 1977 22 indicated that
annual contracted deliveries of U30S for nuclear-powered electric generation plants (assuming
no recycle of plutonium and uranium and 0.20%uranium-235 enrichment plant tails assay until
October 1,1980,0.25%thereafter)will exceed annual requirements until 1979 (see Fig.10.8).
contracted imports of U30S will exceed contracted exports by a considerable margin over the.
next few years.Through 1990,cumulative contracted imports of U30S are 47,200 tonS (approxl-
mate1y 50%of future contracted imports will come from Canadian sources),compared to 13,500 tons
to be exported.Figure 10.7 illustrates total U30S requirements,domestic deliveries,imports,
and exports through 1990.
:-1
I'l :
ES-4634
r :U
DOMESTIC DELIVERY
COMMITMENTS
"....~--...-------'"--'"/- - -REQUIREMENTS
/10.20 TAILS UNTIL
/1011/80,0.25 THEREAFTER
",""- -NO RECYCLE)
./208 GWe
".",.,.
/
./
./
EXPORTS I'/
40
10
50
=e..,
::I
~30e,
l-
ezcen::Ie1=20
ns
76 n 78 79 III 81 B2 B3 84
YEAR
85 86 87 88 B9 90
Fig.10.7.Summary of uranium requirements and delivery commitments as of January 1,1977.
~:Energy Research and Development Administration,Survey of United States Uranium Market-
ing Activity,Division of Uranium Resources and Enrichment,Office of Assistant Director of
Raw Materials,May 1977.
Cumulative U.S.supplies of U30e (including domestic and foreign inventories and contract
commitments)will exceed DOE enrichment feed requirements until 1983.The gap between
cumulative supply and cumulative requirements is expected to be approximately 58,000 tons by
1985 and widen to approximately 233,000 tons by 1990 (see Fig.10.8).
"
,~
1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
CUMULATIVE DOMESTIC &FOREIGN
URANIUM DELIVERY COMMITMENTS
PLUS BUYERS·INVENTORIES
'"'"'"'"'"'"'"'"'"'"'"'"REQUIREMENTS
",'"10.20 TAILS UNTIL
'"10 1 80.0.25 THEREAFTER.
",'"NO RECYCLE,208 GWe
'"'"'"'"'"'"'"'"'"'"'"'"'"'"
500
450
400
350
<Xl0.,300:l
'"Zel-e 250Z<t'":le:I:200I-
150
100
50
ES-4632
10-26
10.5.1.5 Comparison of health effects of the uranium fuel cycle and the coal fuel cycle
Research conducted by the U.S.Nuclear Regulatory Commission 23 comparing the health effects
associated with the coal fuel cycle (mining,processing,fuel transportation,power generation,
and waste disposal)and the uranium fuel cycle (mining,milling,uranium enrichment,fuel
preparation,fuel transportation,power generation,irradiated fuel transportation,and waste
disposal)indicated that increases in the use of coal for power generation may cause the adverse
health impacts related to electric energy production to increase.As defined by the study,
health effects are stated in terms of "excess"mortality,morbidity (disease and illness),
and injury among occupati ona1 workers and the general publ ie,where "excess"impl ies illness
and injury rate$higher than normal and premature deaths.The estimated excess deaths per
0.8 gigawatt-year electric [GWyr(e)](i.e.,per 1000 MWe power plant operating at 80%of
capacity for one year)were 0.47 for an all-nuclear economy (assumes that all of the elec-
tricity used within the nuclear fuel cycle is generated by nuclear power)and 1.1 to 5.4 if all
the electricity used in the uranium fuel cycle (primarily for uranium enrichment and reactoroperation)came from coal-fired plants.Excess deaths for the entire coal cycle varied from
15 to 120 per 0.8 GWyr(e).Mortality estimates are shown in Table 10.7.
Excess morbidity and injury rates for workers and the general public resulting from normal
operations and accidents in an all-nuclear cycle were estimated to be about 14 per 0.8 GWyr(e),
with injuries to miners from accidents (falls,cave-ins,and explosions)accounting.for ten of
these occurrences.If all the electrical power used in the uranium fuel cycle originated from
coal-fired plants,these rates would increase to approximately 17-24 per 0.8 GWyr(e).The
estimated excess disease and injury rate for the coal cycle was 57-210 per 0.8 GWyr(e).Coal-
related illnesses among coal miners and the general public and injuries to miners account for
the majority of nonfatal cases.Table 10.8 illustrates these comparative illness and injuryrates.
Fig.10.8.Comparison of U30e requirements and contracted deliveries plus inventories.
Source:Energy Research and Development Administration,Survey of United States Uranium Market-
ing Aetivity,Division of Uranium Resources and Enrichment,Office of Assistant Director of
Raw Materials,May 1977.
10-27
Table 10.7.Current energy source excess mortality summary per year pe.0.8·GWyrle)power plant
riI
General public Totals
Accident Disease
0.05"0.06b 0.47
0.10"·9 0.64-4.6h 1.1-5.4
Disease
0.14b
0.14-0.4sb-'
Occupational
Accident
Nuclear fuel cycle
0.22"
0.24-0.25"'"With 100%of the electricity used in the
fuel cycle produced by coal powerd
All nuclear
Although the adverse health effects related to either the uranium fuel cycle or the coal fuel
cycle represent small additional risks to the general public,the study concluded that "...
the coal fuel cycle may be more harmful to man by factors of 4 to 260 depending on the effect
being considered,for an all-nuclear economy,or factors of 3 to 22 with the assumption that
all of the electricity used by the uranium fuel cycle comes from coa1~powered plants ..."
(ref.23,p.13).Additionally,"..•the impact of transportation of coal is based on firm
statistics;this impact alone is greater than the conservative estimates of health effects for
the entire uranium fuel cycle (all nuclear economy)and can reasonably be expected to worsenasmorecoalisshippedovergreaterdistance.II (ref.23,p.13).
"Primarily fatal nonradiological accidents,such as falls,explosions,etc.
bprimarily fatal radiogenic cancers and leukemias from normal operations at mines,mills,power plants and
reprocessing plants.
<Primarily fatal transportation accidents (Table S·4,10 CFR Part 51)and serious nuclear accidents.
dU.S.population for nuclear effects;regional population for coal effects.
'Primarily fatal mining accidents,such as cave-ins.fires,explosions,etc.
'Primarily coal workers pneumoconiosis and related respiratory diseases leading to respiratory failure.
9Primarily members of the general public killed at rail crossings by coal trains.
h Primarily respiratory failure among the sick and elderly from combustion products from power plants but
includes deaths from waste coal bank fires.
;100%of all electricity consumed by the nuclear fuel cycle produced by coal power;amounts to 45 MWe per 0.8
GWyr(e)..
Source:R.L.Gotchy,Health Effects Attributable to Coal and Nuclear Fuel Cycle Alternatives,Report
NUREG-0332,Division of Site Safety and Environmental Analysis.Office of Nuclear Reactor Regulation,U.S.
Nuclear Regulatory Commission,September 1977.
10.5.2 Solar,geothermal,and synthetic fuels
Estimates reported in the NationaZ Energy OutZook 16 indicate that solar and geothermal sources
will each supply about 1%of'U.S.energy requirements by 1985 and about 2%by 1990.Supplies
of synthetic gas and.oi1 derived from coal will probably not exceed 1%of U.S.energy reQuire-
ments as of the year 1990.These projections are based on many considerations.The technologyexistsinallcasesbutnotinaproven,commercially viable manner.The potential for proving
these technologies on a commercial scale is great,but timely development will require a favor-
able market as well as governmental incentives.Amaximum of 6%of projected 1990 energy
requirements is expected to be derived from solar,geothermal,and synthetic fuel resources
combined.
The NationaZ Energy PZan13 does not set specific goals for increased use of synthetic fuels or
geothermal energy,but does state that,as a possible goal,solar energy will be used in
2.5 million homes by 1985.
15-12013-11oh1.29
Coal fuel cycle
0.35-0.65"0_7'
Ratio of coal to nuclear:32:260 fall nuclear);14:22 (withcoal powed
Regional population
Table 10.8.Current energy source summary of excess morbidity and injury per 0.8 GWyr(e)power plant
'Primarily nonfatal cancers and thyroid nodules.
bprimarily nonfatal injuries associated with accidents in uranium mines,such as rock falls,explosions,etc.
cPrimarily nonfatal cancers,thyroid nodules,genetically related diseases,and nonfatal illnesses following high
radiation doses,such as radiation thyroiditis,prodromal vomiting,and temporary sterility.
dTransportation-related injuries from Table S4,10CFR Part 51.
eU.S.population for nuclear effects:regional population forcoal effects.
'Primarily nonfatal diseases associated with coal mining,such as coal workers pneumoconiosis,bronchitis,
emphysema,etc.
gPrimarily respiratory diseases among adults and children from sulfur emissions from coal·fired power plants but
-includes waste coal bank fires.
h Primarily injuries to coal miners from cave·ins,fires,explosions,etc.
;PrimarilY nonfatal injuries among members of the general public from colHsions with coal trains at railroad
crossings.
j 100%of all electricity consumed by the nuclear fuel cycle produced by coal power;amounts to 45MWe per 0.8
GWyr(e).
Source:R.L.Gotchy,Health Effects Attributable to Coal and Nuclear Fuel Cycle Alternatives.Report
NUREG·0332,Division of Site Safety and Environmental Analysis,Office of Nuclear Reactor Regulation,U.S.
Nuclear Regulatory Commission,September 19,77.
Totals
14
17-24
57-210
General public
10-10lf
0.7~
1.3-5.39
Morbidity Injury
Occupational
Nuclear fuel cycle
Coal fuel cycle
20-70'17-34;
O.84a
1.7-4.1'
Morbidity Injury
All nuclear
Regional population
With 100%of electricity used by the
fuel cycle produced by coal power"
Ratio of coal to nuclear:4.1:15 (all nuclear);3.4:8.8 (with coal power);
10-28
10.5.3 By-product uranium
Uranium recoverable as a by-product of phosphate fertilizer and copper production is estimated
to be 140,000 tons through the year 2000,19 These reserves are in addition to tre 690,000 tons
of $30 uranium available from conventional mining and milling sources.
The following is noted in a report by the National Academy of Sciences:2q
Like all by-product commodities,by-prOduct uranium is entirely dependent upon
production of the primary commodity,is limited in amount by the level of production
of the primary commodity,and is unresponsive to the demand for uranium.By-product
uranium could be obtained from the mining of phosphate,copper,and lignite.
Much phosphate is treated with sulfuric acid to produce fertilizer and goes through
a phosphoric acid step.Uranium in the phosphate can be recovered from the
phosphoric acid..••It has been estimated that about 2500 ST U30e per year
could be recovered from Florida phosphate mined for fertilizer.
The Bureau of Mines studied the sulfuric acid leaching of low-grade dumps at 14 porphyry
copper mines and concluded that about 750 ST U30e per year could be recovered.Thiswouldberecoveredfromrockswhoseuraniumcontentrangesfrom1to12ppm.
The Bureau of Mines thought that other porphyry copper deposits might also be possible sources
of by-product uraniu~.
The staff has studied available data on the potential of uranium production from phosphate
fertilizer production25 and from copper dump leaching,and estimates that production could
reach 3000 to 5000 MT (4000-6000 tons)per year from phosphoric acid extraction and 400 to
900 MT (500-1000 tons)per year from copper dump leaching.25 ,26 Much effort has been expended
to determine the amounts of uranium that might be recovered from coal and lignite.Some uranium
10-29
waS recovered from lignite ash in the early 1960s;but the lignite itself was not a suitable
fuel for the process;supplementary fuel was needed for the necessary conversion to ash.No
uranium has been recovered as a by-product from the ash of coal-or lignite-fired power plants.
Ash samples continue to be analyzed for uranium,but to date no ash containing more than 20 ppm
U30S has been found,and most ash samples contain from 1 to 10 ppm U30S.2 6
10.5.4 Energy conservation
The cornerstone of the ~ational Energy Plan is conservation,the cleanest and cheapest source
of new energy supply.
If vigorous conservation measures are not undertaken and present trends continue,energy
demand is projected to increase by more than 30%between now [1977]and 1985.13
The National Energy Plan lists the following consuming segments as being prime targets for
energy conservation:
1.transportation,
2.buildings,including residences,
3.appliances,
4.industrial fuel use,and
5.industries and utilities using cogeneration of electricity and low-grade heat.
Part of the National Energy Plan will be the utilization of all possible governmental means
(tax reduction,incentives,direct subsidy,and legislation and regulation)to change the past
relationship between energy production and use of energy requirements in the United States
where energy usage is two times higher per capita than in other industrial countries for
energy consumption and production and energy use.
The National Energy Plan clearly states that both coal and nuclear electrical generation
facilities will be needed to meet estimates of U.S.energy requirements through the year
2000,even if the conservation goals of the Plan are met.The relative amounts of each
energy source used will depend on economic and regional environmental considerations.
10.6 ALTERNATIVE OF NO LICENSING ACTION
Among the alternative actions available to the NRC is the denial of a Source Material License
to the applicant.Classifications of source materials are discussed in 10 CFR Part 40.13(b);
these classifications are based on Section 62 of the Atomic Energy Act of 1954,which specifi-
cally exempts "unbeneficiated ore"from control.Under these regulations Energy Fuels could
mine the ore but could not process it,should the NRC deny the Source Material License.
Exercise by the NRC of this option would thus leave the applicant with three possible courses
of action:(a)mine the ore and have it processed at an existing mill possessing a Source
Material License;(b)postpone the project while attempting to remove the objections.ihat led.to the denial of the license;or (c)abandon the project.Alternative (a)nas Deen 01scusseo 1n
Sect.10.4.Alternative (b)is essentially the applicant's proposal (merely shifted in time),
which is the subject of this Statement.Alternative (c),therefore,is the only alternativediscussedherein.
If the applicant were not awarded a Source Material License,the uranium concentrate it intends
to produce would not become available for use as fuel in nuclear reactors in as timely a
manner.The relationship of electrical energy produced by nuclear reactors to the total U.S.
energy requirements has been discussed in Sect.10.5.
The yellow cake produced by the White Mesa mill will contribute to the worldwide supply of
uranium which will be used as fuel in nuclear reactors that are either ooeratina or undpr
construction in the United States or abroad.As was stated in Section 10.5.1.4.contracted
imports of U30a will exceed contracted exports over the next few years.Lack of fuel would
require those reactors short of fuel to reduce their output and could conceivably result in
the shutdown of some of them.
r'I .
!
10-30
The applicant has indicated the effects of losses of local and reQional economic benefits thatwouldoccuriftheWhiteMesamillwerenotlicensedandhasalsopointedouttheenviron-
mental costs that would not be incurred should no license be issued.Overall,the benefitsaccruingfromthemilloutweighthecosts.
10-31
REFERENCES FOR SECTION 10
11
2.
3.
4.
5.
:i
/6.
-":j.~~
,
7.
8.
9.
10.
11
D.A.Clark,State-of-the-Art:Uranium Mining,Millina,and Refining Industry,Report
EPA-660/2-74-038,National Environmental Research Center,Office of Research and Development,U.S.Environmental Protection Agency,June 1974.
R.C.Merritt,rne'Extractive Metallurgy of Vranium,Colorado School of Mines ResearchInstitute,Golden,Colo.,1971.
Energy Fuels Nuclear,Inc.,"Proposed Tailings Disposal System,White Mesa Uranium Project,Blanding,Utah",Sept.20,1978.
Energy Fuels Nuclear,Inc.,"Investigation of Alternative Tailings Disposal Systems,WhiteMesaUraniumProject,Blanding,Utah,"April 1978.
Energy Fuels Nuclear,Inc.,"Report of Evaluation of Long-Term Stability of Uranium Mill
Tailings Disposal Alternatives,White Mesa Uranium Project,Near Blanding,Utah,"Aug.11,
1978.
U.S.Nuclear Regulatory Commission,Draft Environmental Statement Related to the Minerals
Exploration Company's Sweetwate~Uranium Project,Sweetwater County,Wyoming,Docket
No.40-8584,December 1977.
U.S.Nuclear Regulatory Commission,Final Environmental Statement Related to the utah
Internati~~l,Inc.Lucky Mc Gas Hills Uranium Mill,Docket No.40-2259,November 1977.
U.S.Nuclear Regulatory Commission,Draft Environmental Statement Related to the Operation
of Moab Uranium MiZZ,Atlas Minera7-s Division,Atlas Corp.,Grand County,Utah,Docket
No.40-3453,November 1977.
U.S.Nuclear Regulatory Commission,Draft Environmental Statement Related to the EXxon
Minerals Company,U.S.A.,Highland Uranium solution Mining Project,Converse County,
Wyoming,Docket No.40-8102,May 1978.
U.S.Department of Agriculture,Forest Service,Draft Environmental Statement for the
liomestake Mining Company's Pitch Project,Saguache County,Colorado,July 14,1978.
M.B.Sears et al.,COIVLe1a.:t<.on 06 RacU.oa.c:Uve Wcu..te Tltea..tmen.t CO-6-U and -the tnv-Vton-
mental Impact of Waste Effluents in the Nuclear Fuel·CyoZe for Use in Establishing
'~s Low as Practicable"Guides -Milling of Uranium Ores,Report ORNL/TM-4903,vol.1,
Oak Ridge National Laboratory,Oak Ridge,Tenn.,1975.
I'i ,l j
11
i :lei
12.D.Moffett,"Uranium Waste Researchers Consider Alternate Means of Tail ings Disposal,"
Can.Min.J.,January 1977.
13.Executive Office of the President,The National Energy PZan,Energy Policy and Planning,
Apri 1 1977.
14.Tetra Tech.,Inc.,Energy Faat Book -1977,prepared under the direction of the Director,
Navy Energy and National Resources Research and Development Office,April 1977.
15.U.S.Bureau of Mines,United States Energy through the Year 2000,December 1975.
16.Federal Energy Administration,National Energy Outlook,U.S.Government Printing Office,
Washington,D.C.,February 1976.
17.Federal Energy Administration,Project Independence,U.S.Government Printing Office,
Washington,D.C.,November 1974.
18.Department of Energy,Latest Estimate of u.s.Uranium Resouraes,April 1978.
19.Department of Energy,StatisticaZ Data of the Uranium Industry,Report GJO-10O(78),
January 1,1978.
20.Nuclear News,July 1975,p.37 [reprinted in Energy Faatbook -1977].
21.U.S.Bureau of Mi nes,Recovery of Uranium from LoW-Grade Resouraes,December 7,1977
(unpublished).
i ~
I 1
I
10-3<:
22.Energy Research and Development Administration,Survey of United States U~anium
Ma~keting Activity,Division of Uranium Resources and Enrichment,Office of Assistant
Director of Raw Materials,May 1977.
23.R.L.Gotchy,5eal~h Effects Att~ibuta~le to Coal xnd Nuclear Fuel Cycle Alternatives,
Report NUREG-0332,Division of Site Safety and Environmental Analysis,Office of Nuclear
Reactor Regulation,U.S.Nuclear Regulatory Commission,September 1977.
24.National Academy of Sciences,Mine~al Resources and the Envi~onment.SuppZementa~d
Re?ort:Reserves and Resources of Uranium in the U.S.,Washington,D.C.,1975,p.106.
25.J.K1emenic and D.Blanchfield,"Production Capability and Supply (of Uranium),"paper
presented at Grand Junction,Colo.,ERDA Uranium Conference,October 1977.
26.J.F.Pacer,Jr.,"Production Statistics,"paper presented at Grand Junction,Colo.,
ERDA Uranium Conference,October 1977.
11.NRC BENEFIT-COST SUMMARY FOR THE WHITE MESA URANIUM PROJECT
11 .1 GENERAL
Implicit in the decision of a utility to construct a nuclear power plant is that the uranium
needed to fuel the reactor is available (Appendix B).For each application to the NRC for a
permit to construct a nuclear power plant,an Environmental Statement is prepared which includes
a review of the availability of uranium resources.The uranium to be produced by the White Mesa
mill is among the total U.S.resources considered to be available to the commercial market for
reactor fuel;thus,the uranium from this mill is needed to meet the demands of the nuclear
power industry.In the Environmental Statement,the benefits (the electrical energy produced)
of the nuclear plant are weighed against the economic end environmental costs,including a
prorated share of the environmental costs of the uranium fuel cycle.These incremental impacts
in the fuel cycle are justified in terms of the benefits of energy generation.However,
because these costs and benefits are not localized,it is appropriate to review the specific
site-related benefits and costs for an individual fuel cycle facility such as the White Mesa
mi 11.
11.2 QUANTIFIABLE ECONOMIC IMPACTS
Section 4 of this Environmental Statement treats the quantifiable economic impacts for the
White Mesa Uranium Project.On the one hand,many monetary benefits accrue to the community
from the ~resence of the mill -for example,local expenditures of construction and operating
funds and payments of State and local taxes.Against these monetary benefits are the monetary
costs to the different communities involved -for example,costs for new or expanded
schools and other community services.It is not possible to arrive at an exact numerical
balance between the benefits and costs for anyone community unit or for the mill because
the distribution of revenues to support services may not be timely or completely consistent
with those geographical locations where impacts occur.
11.3 THE BENEFIT-COST SUMMARY
As stated in Sect.11.1,the benefit-cost summary for a fuel cycle facil ity such as the White
Mesa Uranium Project rests on a comparison between the societal benefit of an assured U30Ssupply(ultimately providing electrical energy)and local environmental costs for which there
are no directly related compensations.For the White Mesa mill,these uncompensated environ-
mental costs are basically two:radiological impact and disturbance of the land.As showninSect.4.7,the radiological impact of the White Mesa mill is acceptable by current standards.
The disturbance cf the land,as shown in Sect.4.2,is a long-term impact that is judged to
be small in comparison to alternative uses the land may support in the future.
11.4 STAFF ASSESSMENT
The staff has concluded that the adverse environmental impacts and costs are such that use of
the mitigative measures suggested ry the applicant and the regulatory agencies involved would
reduce to acceptable levels the short-and long-term adverse environmental impacts and costsassociatedwiththeproject.
The White Mesa Uranium Project,along with other energy-related projects in the area,will
create a short-term stress on the political and social systems (including housing and schools)
of the area.The quantity of total tax money appears to the staff to be adequate but the
distribution may not be (see Sect.11.2).This aspect of the project is currently receiving
attention by the institutions directly concerned,and ~itigation appears possible.
11-1
11-2
As was shown in section 10.5.1.4,U.S.requirements for U30S will exceed production capability
for the next few years.Although the applicant may export the uranium derived from the U30S
produced at the White Mesa Mill,the United States is a net importer of uranium and failure to
license the proposed project would only result in the foreign demand being filled by other
domestic/foreign mills that could be producing uranium for consumption in the United States.
In considering the energy value of the U30S produced,minimal radiological impacts,minimal
long-term disturbance of land,and mitigable nature of the impacts of growth on the local com-
munities,the staff has concluded that the overall benefit-cost balance for the White Mesa
Uranium Project is favorable,and the indicated action is that of licensing.
,I
Appendix·A
COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT
AND NRC STAFF RESPONSES
""".....'..'.g:;':~
U
[
r;l....~.L
Appendix A
COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT
AND NRC STAFF RESPONSES
In this appendix,the letters of comment on the Draft Environmental Statement pertaining to
the White Mesa Uranium Project are reproduced in full.The staff responses are printed con-
veniently close to each comment.Specific comments and responses are keyed by numbers in the
margins of the letters and at the beginnings of the corresponding responses.In addition,
changes in the text have been made where needed.
Letters of comment were received from the following:
U.S.Department of the Interior
U.S.Environmental Protection Agency,Region VIII
Advisory Council on Historic Preservation
U.S.Department of Health,Education,and WelfareDepartmentoftheArmy,Corps of Engineers '
U.S.Department of Agriculture,Soil Conservation Service
Federal Energy Regulatory Commission
U.S.Department of Agriculture,Science and Education Administration
U.S.Department of Transportation,U.S.Coast Guard
State of Utah,Department of Social Services
State of Utah,Department of Development ServicesUtahDepartmentofEmploymentSecurity
William A.Lochstet
R.W.Berg
City of Blanding
City of Monticello
San Juan School District
San Juan Center for Higher Education
College of Eastern Utah
Church of Jesus Christ of Latter Day Saints
Jim Dandy,Navajo Indian Tribe
Councilman,White Mesa Ute Tribe
Chamber of Commerce of Monticello,UtahA.W.Egbert
John Mitchell,Wasatch Financial Corp.
Tom Redd,Wasatch Financial Corp.
E.A.Bl ack
Zelma Acton
Calisbee Black
Earl E.Stevens
Phil B.Acton
E.Brent Redd,Abajo Petroleum,Inc.
Jim H.Acton
City Council of Monticello,Utah
Kay R.Johnson,JTN Insurance,Inc.
Robert E.and Joan Hosler,Thin Bear Indian Arts,Inc.
A-3
..,...
RESPONSES
A.Sections 2.5.2 and 4.2.2 have been revised and Appendix E has been Included
concerning the currently Identified cultural resources and the mitigatoryactionsthatwillbetaken.
FEB 1 4 1979
Sen't'Enrrgy ami Yo"Srrw"AmericiI!
United States Department of the Interior
OFFICE OF TilE SECRETARY
W"'SJ~INP.:fO:-l,DC 20240
Mr.Ross A.Scarano
Uranium Mill Licensing Section
Division of Fuel Cycle andMaterialSafety
Nuclear Regulatory Commission
Washington,D.C.20555
In Reply Refer To:
EGS-ER-78/1222
Mail Stop 760
Dear Hr.Scarano:
This is in response to your letter of December 15 requestingtheDepartmentoftheInterior's comments on the draft
environmental statement f"r or-eration of the W:',ite Mesa
Uranium Project,San Juan County,Utah.
We find that the draft statement is incomplete in its treat-ment of 'cultural and recreational rpsources,and that a
fuller discussion of the infrastructure of the loc~l CJm-munities together with the potential impacts,includingfinancialburdens,on these communities is warranted.Further discussion of the impact of the project on recov-erability of mineral resources other than uranium is alsodesirable.
The statement should deal more adequately with the avail-ability of ground water and with potential contamination of
water resources,especially with regard to the long-t~
stability of .mill tailings.
GENERAL COMMENTS
The draft statement does .not adequately discuss project
impacts to archeological resources,and the compliance with
historic preservation laws and regulations is incomplete.
ru
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p,
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RESPONSES
r,;,~~~~r-"~~
The $1.5 to $2 million annual operating costs cited earlier will be met by a
variety of sources;the combination of property and sales taxes with the utility'soperatingincomeandotherrevenuesisexpectedtobaIanceneededexpenditures,supporting the staff's original contention that the provision of services shouldnotentaillong-range financial difficulties.
Regarding the provision of other public services and their associated costs,
Sect.4.8.2.2 discusses the capability of present and planned facilities to
acconmodate anticipated growth in the communities surrounding the propo~.ed
White Mesa mill.As stated there,8landing is planning to expand water and
sewer facilities to accommodate expected plant-induced population growth,and
Monticello is working on improvements to their water supply,sewage treatment,
and electricity distribution systems.an effort also aimed at acconmodatinggrowth.The capital for these improvements is expected to come from a varietyofsources,with Federal and State funds significantly bolstering the local
contribution.
C.A detailed listing of present and proposed recreational facilities in the com-munities of Blanding,Monticello,and Bluff has been added to Sect.2.4.2.1.In
Iight of the planned expansion of local faci Iities in Blanding and Monticello,
where the bulk of plant-induced in-migration is expected,and the abundance ofnearbyFederalandStaterecreationareas(Table 2.7),the staff judgment that
current and projected populations can be adequately served appears to be
justified.
8.Modifications to the applicant's proposed tailings impoundment plan (Sect.3.2.4.7)
will result in impacts to a smaller land area.The staff also agrees with the
Utah State Historic Preservation Officer (SHPO),Appendix A,p.A-35,that
archaeological resources would not result in the choice of another of thealternativesitesinthiscase.
[J~CV'
2
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ir'."'-_."'.,.<3~;~2;l[;1:."]!:.:~~7.~J
';,f;;;";,.:••.
r rr JI nor.,.73mTT.·-Fifii",-~!·_·.
C::~::'.3l
Although at least 78 archeological sites have been iden-tified in the project area by field survey and preliminary
testing,there is no indication that the eligib.ility of thesitesfortheNationalRegisterofHistoricPlaces,eitherindividuallyorasadistrict,has been determined pursuantto36CFR63,nor that consultation with the Advisory Council
on Historic Preservation required by 36 CFR 800 has taken place.These steps should be completed prior to preparation of thefinalenvironmentalstatement.As the statement recognizes(p.4-4),"a precise statement of impacts is not possible,"
since further consultations are needed to prepare an appro-
priate avoidance/mitigation plan and conclude the MemorandumofAgreement.When this is done,the statement should berevisedtodiscussboththespecificmitigationmeasuresthathavebeenagreedtoandtheextentandseverityof.
remaining unavoidable adverse impscts to archeological
resources.
~The discussion of alternative mill sites concludes that on
the basis of socioeconomic and transportation impacts there
are "no better"alternative sitea in southeastern Utah
(p.10-2,par.2).It appears,however,that alternative
sites have not been evaluated on the basis of impacts to
environmental and cultural resources.In view of the den-
sity of archeological sites on and in the vicinity of the
project area,as well as the amount of land disturbance
required to construct the mill and tailings ponds,we rec-
ommend further study to identify alternative locations withlowerdensitiesofarcheologicalsitesandthuslesser
impacts to these resources.Any analysis of such sites
should be included in the final statement.
~we are concerned that.the statement does not adequately
recognize the effect of population increases on recreationresourcesandfacilitiesintheprojectarea,particularlyinthecommunityofBlanding.There is no discussion of the
facilities in or capacity of the four public parks in Blanding,
but simply the statement that the facilities are "adequate"
(p.4-7).Although these may be adequate for the present
population,it is not clear whether the facilities couldaccommodateapopulationincreaseofnearly50percent.Moreover,in view of the projected $1.5 to $2 million in-crease in local government costs and the apparent shortfall
in tax revenues (pp.4-19 and 20),the conclusion that "the
impacted communities will be able to provide services for
the expected population influx without long-range fiscal
difficulties"appears unwarranted.
r~.-_~::d
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3
~The final statement should analyze the capacity of existingfacilitiestoaccommodateprojectedpopulationincreases,
recognize the adverse effects resulting from any inadequacy
of capacity,and discuss what action will be taken by the
Nuclear Regulatory Commission and the project sponsor to
assure the provision of adequate recreation facilities.In
particular,we urge that the project sponsor explore withlocalofficialsandtheUtahOutdoorRecreationAgencyvariousmeansofprovidingaidforthedevelopmentof'neededrecreationfacilities.
~Known mineral resources tn the millsite vicinity includeuranium-vanadium,coal,copper,and sand and gravel.TheseresourcesarediscussedingeneralanditispOintedout
that seven petroleum test wells drilled about 4 miles westofthesiteweredry.We believe,however,that more mightbesaidaboutthepossiblecommitmentofmineralresourcesunderthetailingsareabecausecommitmentofthe450orsoacresrequiredforthisuseisvirtuallypermanent.Thus,
in addition to the general statement in section 2.7.2.1(p.2-36),something should be said as to whether or'not anyexplorationorevaluationhasbeendonetodeterminethe
possible loss of resources under the proposed tailings areas.
A map showing proposed or existing mining operations that
would supply this mill would be helpful in identifying
the need for the project.
SPECIFIC COMMENTS
(2)Page 2-5,fig,2.1:The map indicates that the highway that
would receive much of the heavy truck traffic providesacceastotheNaturalBridgetrationalMonument.The impactonaccesstotheMonumentshouldbeassessedinsection4.8.5
(p.4-21).
~p.ges 2-7 to 14,sec.2.4.2:Under social economic profileitisdifficulttograspthecurrentsituation.Existing
capacities for water.sewer,and other components of the
infrastructure should be described.'
RESPONSES
D.The response to the previous.conment outlined the capacity of existing and
planned recreational facilities to acconmodate projected local population growth.
Continuin~company cooperation with local conmunities as evidenced by housing
planning (Sect.4.8.6)is expected in the future.
E.Potentially CORlllercial coal occurs locally only in the Dakota Formation.No
coal is evident in the local [0.8 to 2.4 km (0.5 to 1.5 miles)]outcrops or
has been observed during well driHing on the site.Uranium-vanadium depos its
could occur in the Morrison Formation at depths of 70 to 280 m (230 to 920 It)
at the site.If deposits are present.underground mining would be required and
the tailings area would not preclude this.Oil exploration and possible production
would not be affected because top casing would be set below the tailings or offset
drilling techniques could be used.
1.A discussion of the impact of heavy truck traffic along Utah Highway 95 on
the Natural Bridges National Monument has been added to Sect.4.8.6.
2.Section 2.4.2 provides a profile of the social.economic.and transportation
systems of the mill impact area,including a description of the various publ ic
services provided in the conmunities of Blanding,Monticello.and Oluff.
It is the staff's judgment that the treatment given therein to water,sewer,
power.waste disposal,public safety.health.and educational systems provides
a clear and accurate picture of the local infrastructure.
~>
m
,J
·~:;~cl:','~,:·;::::,,:,;;i,.~:;:,:'
~pages 2-16 to 17,sec.2.5.1.2:The discussion of farmlands
should indicate that no unique or prime farmlands exist inthearea.
~age 2-17,sec.2.5.2.2:In the discussion of scenic areasVisualResourceManagementratingsshouldbeincluded.
~page 2-32,sec.2.6.2:Two of the onsite wells are located
in the area of the proposed tailings impoundment and it is
stated that these wells would be capped.We suggest that to
protect the aquiferes)properly and to avoid the possibility
of future problems in monitoring and contamination control,
the wells in the tailings impoundment area should be thoroughly
plugged both in and .below the uppermost impermeable layer
below the base of the tailings and above the aquiferes).
Otherwise,deterioration of the abandoned wells surrounded
by tailings could furnish ready avenues for the movement of
pollutants into the aquiferes).If,on the other hand,
plans include future use of the wells--for example,for
monitoring--the statement should describe precautions to
ensure the continued integrity of the casings.
~Page 3-12,par.2:Despite the assertion that the "tailings
would be stored completely below grade"(p.10-19,par.I),this is not clear from the description of the dike construc-
tion in chapter 3.Embankment height at the lowest point in
the swale is given as 30 feet and from the description and
figure 3.7 it appears that this would be 30 feet above the
natural ground.A better description of the tailings grade
in relation to natural grade and the dike farthest downstream
would be helpful.
~page 3-14,sec.3.3.2:The source of cover material for the
tailings area should be described.As this area will prob-
ably need extensive reclamation,we recommend a discussion
of this topic.
~page 4-1:The project area is close to major recreation
areas where visual impacts are of great concern.A dis-
cussion of impacts on Visibility from emissions would be
appropriate.
(!)page 4-3,sec.4.2.1.1:How long will the 1,480 acres be
disturbed?
~page 4-5,sec.4.3.2.2:What is the permeability or esti-
..ted life of the liner for the tailings ponds?
F~"'~2":-'
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11:11
12-18
/1 or L"ss
Fin~.Rotin
r:::~;;?':_"·jf
Sc"nic QualityC1ossificotion
Closs A
Closs B
~lnS5 C
~u
ty
RESPONSES
F~~C'J~~;.~:~
Subtotal +__+_0_.10to/-:O'-_
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A.B.or C
5.The section has been revised to state that the two wells will be completelyplugged.
4.The U.S.Bureau of Land Management -s Visua1 Resource Inventory eva Iuates
an area's scenic quality based on land form.vegetation.water.color,
influence,scarcity,and cultural modification.According to these criteria,
the proposed mill site itself does not rank as an outstanding scenic area,receiving a "Class C"rating,as shown below.
Score (Circle Appropriote L"Y"I)
3.A discussion of this issue has been added to Sect.2.5.1.2.
rC"~:::jJ
High Medium Low '::lotionole orExplonation
I Londform 5 3 ifh>
2 Vegetation 5 3 little diversiJWoter5.3 none
4 Color 5 3 relatively uni
5 Influence 5 3 unaffected
6 Scorcity 6 2 common7CulturolModificotion201(-'il modified for g
6.Sections 3.2.4.7 and 10.3 (Alternatlve·1)have been revised to clarify the
description of the proposed system.The tailings area will be constructed
in a natural swale with each cell being excavated to provide additioMIdept~.Each retention embankment .-111 be constructed across the excavated"
cell with the final embankment matching the level of the adjacent natural
ground that creates the ridges along the edges of the swale.Therefore,
the embankments will only be as high as the undisturbed ground adjacenttothetailingscell.The maximum embankment heights will vary from 7.6 to
13.0 m (25 to 42 ft).depending on the individual cell.The last
embankment will be constructed with a 6:1 downstream slope and will beconstructedofriprapforlong-tenn stability.
Each tailings cell will be filled to a level 1.5 m (5 ft)below the top oftheembankmentandthe.adjacent ground and will be covered with a sufficient
amount of cover to reduce the radon emanation to twice background.This
cover will create a slight rise where the swale fonnerly existed to gently
drain waters away fro,"the reclaimed tailings area while minimizing erosion
of the cover rnateria1.
7.The silt-sand,rock,and topsoil are available from cell excavation and the
onsite borrow ar.ea shown In Fig.3.4.Clay for cell linings and cover will
probably be removed from Brushy Basin outcrops on Westwater Creek Canyon.
These barren.heavily dissected outcrops will lose no potential use fromclayremoval.No reclamation is required because they presently support
no vegetation.
8.A discussion of impacts of visibility from emissions has been added to the
text.
g.The total project site [599 ha (1480 acres)]will not be disturbed by
project activities.As stated in Sects.4.2.1.1 and 4.2.1.2,about 196 ha
(484 acres)will be disturbed by const"uction and operation of the millfacility.A realistic estimate of the minimum amount of time the land will
be disturbed is about 20 years.Note that the reclaimed tailings areawillnotbeavailableforunrestricteduse.
4
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~page 4-6.sec.4.6.1:Which deer herd is affected?
~page 4-7,par.3:This paragraph does not adequately de-
scribe the impacts of the project on mule deer use of the
project site as discussed on page 2-42 (par.6).Deer use
of the area will be influenced by factors other than just
noise.Approximately 358 ha occupied by the mill,millfacilities,tailings area,and roads will not be availableforusebydeer.How much of the total project site,orspecificfacilitieswithinthesite.will be fenced and whatarethepatternsofhumanuseofthefacilitiesthatwill
influence the daily movement and use of the area by deer?
We recommend that the applicant fence as little of the tocal
area as possible by limiting fencing to areas where requiredforspecificsafetyorotheroperationalrequirements.We
also recommend that the applicant,during construction and
operation of the project,coordinate with the Utah Division
of Wildlife Resources concerning ways to mitigate any impacts
to deer that may develop during this time.
~page 4-7,par.4:The discussion concerning the quantity oftailingswater(28 ha)that may impact wildlife'is in conflictwiththediscussionsoftheproposedtailingssystemonpage3-13.There,figures concerning the surface acreage of
tailings water that may be present at one time range from33.2 ha to 100 ha.What is the maximum surface acreage oftailingsliquidthatwouldbepresentatanyonetimethat
might serve as an attraction to waterfowl or shorebirds?
@page 4-13,sec,4.7.6:The paragraphs on occupational
health are somewhat limited.Discussion of followup onemployeehealthmightbeincluded,both here and in section 6.6.
~page 4-17.sec.4.8.2.2,par.1:It is mentioned that the
town of Blanding has adequate water and sewer facilities for
300 new residents.However,even in a good year,water must
be watched very carefully.During a drought season their
water supply has been down to less than'a two-week supply.
Monticello has similar problems.'
@page 4-18.sec.4.8.2.3:What is meant by "a large portion,of the population"?Figures are available to determine the
percentage of various groups.
RESPONSES
10.No long-tenn data on service IHe is available.No deterioration during
the mill operating IHetime is expected,and because final reclamation is
under drained conditions.no long-tenn ~roblems should occur.If properlyinstalled,penneabilities less that 10-em per second are expected.
II.The deer herd under consideration is part of Utah's Division of Wildlife
Resources herd unit 31-A (San Juan-Blue Mountain).As discussed in
Sect.2.9.1.2,deer migrate through the vicinity of the site to Murphy Point
(Fig.2.5)to winter.Daily movement during winter periods by deer
inhabiting the area has also been observed between Westwate'r Creek andMurphyPoint(Fig.2.5).
12.Although about 154 ha (383 acres)for the mill facility and tailings impound-
ment will be fenced,an additional 40 ha (98 acres)will be disturbed as a
result of stockpiles and borrow areas.As stated in Sect.4.2.1.2,a total
of about 195 ha (484 acres)would be disturbed.In addition to these direct
impacts as a result of habitat disturbance and human activities at the site,
the deer may be further impacted as discussed in paragraph 5,page 4-7.
Greater human population associated with construction and operation of the
mill can result in greater hunting pressure (both legally and illegally)
and destruction of habitat by off-road recreational vehicles.Although
the staff does not expect the movements of deer across Highway 163 to be
influenced,increased wildlife losses are expected to occur as a result of
greater vehicular travel.Thl'applicant wjll be required by license
condition to consult and coordinate with the Utah Division of Wildlife
Resources regarding extent of fencing and other ways to mitigate any
adverse impacts to deer that may occur.
13.The staff estimates that the 4D-ha (g8-acre)area of the evaporation cells
may be required.Because the moist tailings also provide evaporation surface,
the total area of the evaporation ponds may not be required.
14.The section has been modified slightly to clarify that maximum radiation
exposures for both mine and mill workers have been set by regulatory
agencies to protect the workers from undue risks and that protection
measures to reduce occupational dose are reviewed and revised to keep
radiation exposures as low as reasonably achievable.
Because doses to occupational workers are measured and maintained belowoccupationaldoseIimits,nO increase in discussion is warranted in the FES.
15.Although water scarcity is indeed a reality in southeastern Utah,infonnation
supplied by the Blanding city manager indicates the ability of existing
facilities to accOlllllOdate 300 additional residents.Growth of a greater
magnitude,however,is contingent upon planned improvements in the watersupplysystem(Sect.4.8.2.2).
16.Aquantification of Mormon and Native American populations in San Juan County
has been added to Sect.4.8.2.3.
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Coefficient of transmissivity (gpd/ft2)
Coefficient of storage
Specific capacity (gpm/ft drawdown)
No potential effects on human health are expected because no sustained
ingestion of the saline water by birds is credible.See response to
comment 18.
The city of Blanding has completed one well in the Navajo about 11 km
(7 miles)north of the site.Static water level was 152 m (500 ft);
the well produces 200 gpm (309 acre-ft per year)with 122 m (400 ft)of
drawdown.Other Blanding wells are completed in the Entrada.
The staff estimates that,at the site,both the Entrada and Navajo aquifers
contain about 25.000 acre-ft/sq mile (formation thickness times 0.25
effective porosity).Most usage in the area is from the Entrada.Even
without recharge,the staff considers the impacts minimal in the low
population density region.
Al though no data exist on the use of uranium mill tai1 Ings ponds by
migratory waterfowl.the staff does not anticipate that contact with the
tailings will result in increased mortality.The salinity of the tailings
liquid (mostly sulfate)is in excess of 100,000 ppm,which makes it
unpalatable for drinking by any species.The effective acid concentration(0.016 molar)is too low to cause physical damage but is expected to result
in sufficient irritation to the skin of the feet and legs of waterfowl that
they will not spend extensive periods of time on the tailings pond.
Consequently,exposure time is not expected to be sufficient for waterfowl
to contract high body burdens of radionuclides and toxic chemicals from the
tailings.In addition,the acidic nature of the tailings will preclude thegrowthofaquaticplantsandinvertebratesusedasfoodbymostwaterfowl,
making it unlikely that other consumer organisms (including man)will be
exposed to significant levels of radionucl ides through the ingestion of
waterfowl exposed to tailings.The staff is unaware of data that document
the impacts to waterfowl from exposure to uranium mill tailings.The staff
does not expect that anything but an occasional landing wi 11 be observed
but requires that the applicant observe any use by waterfowl and maintain
a record of such observations to confirm that this is true.
The staff contacted the USGS,Water Resources Division,Utah District.For
the Four Corners area.the range of Navajo characteristics were as follow:
RESPONSES
Sections 4.8.2.1 and 4.8.2.2 describe planned expansions of the housing
,stock and various public services designed to acconmodate projected growth
in the impact area.This apparent readiness for mill-Induced population
growth indicates a likelihood that the adverse impacts experienced in Emery
and Carbon counties will be avoided here.As stated in Sect.4.8.6,a
strong defense against such impacts lies in making sure that plannedimprovementsaremadebeforegrowthoccurs.An explanat ion of how needed
expenditures are expec.ted to be balanced by future revenues.thus avoiding
long-range financial difficulties.is found in the response to general
cooment "e"above.
t:""o~.o.,
20.
18.
19.
17.
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6
~page 4-21.par.1:It is concluded that the project can beaccomplished"without long-range financial difficulties"for
the local communities.Actual experience in similar situa-
tions,particularly Carbon and Emery Count'ies,indicates
that there have been substantial lags between needed tax
revenues and demand for housing and public services.Since
these lags have resulted in significant impacts on the
affe~ted communities,we suggest further analysis of this
issue.
~psge 6-3,par.3:Further explanation should·be provided in
this paragraph as to how "potentially harmful amounts of
radionuclides and other contaminants in the tailings im-
poundment"amount to insignificant impacts to wildlife(waterfowl and shorebirds).We fully support the need for amonitoringprogramtodetectanyadverseimpactsofthetailingsimpoundmentonwaterfowlandshorebirds.Of par-
ticular importance would be to note the behavior of the
birds using the impoundment.Is there any indication of
sluggish flight or difficulty in taking off Once birds have
landed on the pond(s)?Does there seem to be an increase in
preening activity?We reo ommend that at the first sign of
any problems (behavioral changes or m~rtalitie3)the appli-
cant should immediately notify the Utah Divisin.l of Wildlife
and the Fish and Wildlife Service so appropriate mitigative
measures can be pursued.
~AlSO,the possibility of any impact to publ~c health as aresultofradionuclidesorothercontaminatesenteringthe
human food chain (waterfowl)should be discussed in this
paragraph.This would be a function of the length of use of
the ponds by the birds,the mechanism of their contamination,
and the probability of their being hsrvested.These itemsshouldbediscussedinthisparagraphsndinsection4.6.1
(p.4-6)..
~psge 9-1:The statement should give a better concept of the
chsracteristics and water-bearing properties of the Navajo
Sandstone aquifer.Yield and drawdown or specific capacity
information for the Blanding site well in the Navajo
Sandstone aquifer should be given,if no aquifer test has
been made;such information would permit at least quantita-
tive assessment of ground-water impacts.The basis for the
assertion in section 9.2.1 concerninK the large amount of
water available in the Navajo Sandstone aquifer of the
project area should be indicated.The environmental report
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7
for the project asserts (p.2-120)that in 1977 development
of the deeper aquifers of the Entrada Sandstone and the
Navajo Sandstone was progressing near Blanding and 110nticello,
Utah.Because of the proximity of the town of Blanding,the
aquiferes)utilized by the municipal wells should bl!identi-fied.The statement should also indicate whether wI!lla ontheUteIndianReaervationtaptheNavajoSandatoneaquifer.The following references may be useful in conaidering thepropertieaoftheaquiferinthegeneralarea.
(1)Irwin,James H.,1966,Geology and availability ofgroundwaterontheUteMountainIndianReservation,Colorado and New Mexico:U.S.Geological Survey Water-
Supply Paper 1576-G.
(2)Cooley,M.E.,Harshbarger,J.W.,Akers,J.P.,and
Hardt,W.F.1969,Regional geohydrology of the Navajo and
Hopi Indian Reservations,Arizona,New Mexico and Utah:
U.S.Geological Survey Professional Paper 529-A.
Thank you for the opportunity to comment.
,.,
1:ce~
''-l-'~_"__......~.Hei~oSECRETARYDeput,A:lsut8ftt
We have completed reviewing your Agency's recently-issued Draft
Envirollllental Statement (DES)on the White Mesa Uranium Project
(NUREG-0494).The enclosed final c_ts do not differ from thosepreviouslysubmittedtoyouIndraftform.
In general,there are no major problems with this document.
Overall,EPA's reviewing staff found the DES to be a well-prepared
statement which supports the construction and operation of a uranium
111111 at the proposed location.We are pleased to note that this DES
incorporates many of Our cOlllllents on previous DES's developed by theCllIIIIIlsslonforotheruranlllllmillingprojects.
The most positive feature of the proposed project is the planforthedisposalandlong-term stabilization of the radioactive
residuals.By disposing of these tailings in below ground and lined
cells which are to be filled and reclaimed sequentially,any
environlllental impacts should be minimized.
We are concerned with the proposed sizing of the tailings
impoundment cells.This may create situations where insufficient
storage volume is available for total evaporation,or there is a lack
of reserve volume in the event that a rupture of one cell's dike wouldbreachthenextcell's dike.This concern is compounded by our doubt
that the filled 'cells will dryas quickly as indicated due to the
lIIinlmized seepage through the proposed impoundment lining.Expansion
of the tailings disposal area with shallower cells appears more
desirable than Increasing the individual cell volumes'through raiseddlllllheightincrements.
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UNITED STATES ENVIRONMENTAL ~ROTECTIONAGENCY
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leland C.Rouse,Chief
Fuel Processing"Fabrication Branch
Division of Fuel Cycle and Material Safety
U.S.Nuclear Regulatory COIIIIission
Washington,D.C.20555
Dear Mr.Rouse:
MAIl 16 1979
REF:8AIl-1ll
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We concur with your Agency's pollcy of evaluating the
justification for licensing uranilJl milling projects,in part,with
the need for uranillll to fuel nuclear power plants that will produce
electric power for sale to U.S.conSllllers.In this regard,we were
surprised to learn that the NRC llcensed Bear Creek Uranium Hi 11,
owned by the Rocky Mountain Energy Co.,has negotiated a large sale of
uranillll to a Swedish utility.The NRC FES for Bear Creek did not
acknowledge such an eventuality nor does the DES for the White Mesa
Project describe any foreign sales of Its product.To maintainfederalcredibilitywefeelthattheNRCshouldstrivetogivea more
accurate account of the .arketing of uranilJl by its licensees.This
is particularly illportant when the question of environmental costs
versus the gain of certain benefits are used to justify a givenproject.
According to the procedures EPA has adopted to rate
environmental statl!llents,NIJREG·D494 will be listed in the Federal
Register as ER-2.This lIH!ans that EPA has reservations concerning the
envirOflll!ntal effects of certain aspects of the proposed action and
needs Idditlonal data as indicated by the enclosed comments.
We will be glad to discuss these commments if you need furtherclarificationordesireadditionalguidanceonhowthesecanbedealt
with in the Final Environmental Statement.
Ql:~
Alan Herls~~inlstratorRegiona ..,
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1.Page 1-3.Section 1.5:The DES does not appear to reference NRC's
responsibility under the recently enacted "Uranium Hill Tailln9s
Radiation Control Act of 1978".What additional requirements'will be
stipulated?What changes,if any,in tailings manal/ement \,/111 result?
l.Page l-17,Section 2.5.l.3:The Final Environmental Statment
(FES)should contain more detailed Infol"matlon on the significance and
location of all archaelogfcal sites.The staff lllentions (p.2-19)that
I surface survey was conducted In the Fall,1978,yet the results of
the survey are not presented.Further field Investigations and
analysis (as suggested by the staff)are needed In order to determine
the potential inlportance of the sites as well as any adverse impacts
~hich may occur from the proposed mill.These results should be
presented in the FES.
3.Pages 2-26 thru 29,Table l.ll:The radiological analyses look
someloihat suspect.Results for the two replicate samples are not in
good agreelllent.Gross alpha results seem to generally be less than the
uranhn activity.At location SIR,it is difficult to see how the
creek could have enough water fo.r one sample but not enough for the
replicate sample.Some of the samples also seem high for background
samples.
4.Page l-30.Figure 2.5:This figure Is too cluttered for ease of
interpretation.It should only be a schematic shOWing the Intermittent
drainages,project boundaries,and s~n:pllng locations.The contour
lines and other marki"gs should be eliminated.
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RESPONSES
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I.The last paragraph in Sect.1.3 has been revised to include a statement that
Title"of that act gives the NRC direct Iicensing authority over uranium
mill tailings.(Sect.1.5 does not appear to be affected.)The proposedtailingsmanagementplanforthisprojectiscurrentlyconsideredstate
of the art,and the act itself should not result in the stipulation of
additional technical requirements.The act does reqUire that "reclaimed"
land used for tailings storage be deeded to the Federal government and
this requirement sha11 be complied with.The proposed tafI ings impound-
ment would be located on lands owned by Energy Fuels Nuclear,Inc.,except
for small portions which are federally owned.
4.The staff considers the level of detail in this figure to be appropriate.
It is true that the gross alpha results are generally less than the
uranium activity.However.this is evidently not unique to this work alone.
An EPA publication (EPA 906/9-75-oo2)entitled Wate,-Quality Impacts of Uroni"m
Mining and Milli"fJ Activiti,?8 in the GJ"ants Mineml Belt~NeLJ Mexico.September1975,stated the following as two of its study results:
•The uranium isotopes (uranium-234,-235,and -238)are the main cdntribution
to the gross alpha result;however,in several determinations,gross alpha
underestimated the activity present from natural uranium.
•It is doubtful that the gross alpha determination can even be used as an
indicator of the presence of other alpha emitters (e.g.,uranium-natural
and polonium-210),and because the gross alpha results generally have such
large error terms,no meaningful determination of percentage of radionucl ide
to 'gross alpha can be implied.
The adequacy of SIR's sample size to permit a replicate is not known,butbecausealloftheothersamplesarewithoutrepIicate,at least one sample
waS analyzed (although an index of reproducfbility was possible).
Sorne of the activities do seem high for background values (e.9.,radium-Z26
averages equal 0.03 pCf/liter in North American streams -less than stated
values).but statistical fluctuations and local environmental conditions mustbeconsidered.
2.The results of the survey conducted in the fall of 1978 were not reported until
January 1979.Additional information has been included in this FES.
3.Admittedly,the replicate samples do not show good a9reement,but this Is
understandable as the samples are replicates with respect to location
and not with respect to time.Activity levels and other parameters can
vary widely as a function of flow conditions.
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!;PA REGION VI II
SPECIFIC COM-:ENTS ON
WHITE MESA URANIUH PROJECT
DRAFT ENVIRON~IENTAl STATHIENT (DES)
(NUREG -0494)
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See 001 coament E regarding the I1orrison Formation.
B.Ore samples from the Itanksville and Blanding area were obtained by the appl icant
from approximately 50 mines that will be shipping ore to the White Mesa mill.
Samples from each of the mines were composited on a weighted basis (percentage of
mine production)for laboratory testing,which included alkaline and acid-leach
studies for comparisons.These studies showed that ur,lIIium recoveries were
higher by approximately 2%and vanadium recoveries by approximately 50%when
acid-leach was used compared to alkaline leaching.This discovery was the basis
for the applicant'S choice.The staff considers both acid and alkaline milling
acceptable.(See Sect.10.2.1.)
7.Some formations showo in Fig.2.6 are not shown in Fig.2.9 because the fonner
is a generalized stratigraphic section showing the freshwater-bearing units of
southeast Utah,and Fig.2.9 is a stratigraphic section showing the rocks exposed
in the project vicinity.The oldest unit shown io Fig.2.9 is the Cannel Formation
because this is the oldest rock exposed in the vicinity.The Chinle Formation
occurs at an estimated depth of 51B m (1700 ft)and the Cutler Fonnation at over
975 m (3200 tt)at the project site.If uranium is present in these fonnations,
underground mining would be required.
5.The Dakota sandstone on White Mesa has been completely isolated by erosion;
consequently.all recharge to this formation comes from precipitation and
irrigation on the mesa.No irrigation occurs close to the mill site,and normal
annual precipitation is only 30 em {12 in.}per year.most of which reenters
the atmosphere as evapotranspiration (i.e.,does not penetrate the soils over
the Dakota).The Dakota is the underlying bedrock under the proposed tailings
impoundment and has a penneability coeffic,ient from 1.5 to 3 m (5 to 10 ftl pee
year (ER,Sect.2.4.2.1 and Appendix It).Jointing occurs in the tonnation but
is probably not fully penetrating.An aquiclude,the Brushy Basin member of the
I1orrison Formation,underlies the Dakota sandstone,which accounts for the
groundwater retained in the lower portion of the Dakota.
6.Thicknesses of stratigraphic units in the vicinity are shown in Fig.2.g.
RESPONSES
g.All surface runoff from the mill and ore storage sites be im,pounded
onsile in a sedimentation pond.
10.The NRC staff recoqnizes that operation of the White Mesa Uranium Mill and its
tailings impoundment system may result in some offsite low-level contamination
of ground surfaces.The levels and impacts of such contamination have been
considered in detail in the preparation of the radiological impact evaluation
of the proposed project.The results of this evaluation are presented in
Sect.4 7 and include an assessment of compl iance with relevant Federal
regulations governing offsite contalOination.Staff analysis indicates that
the project will,if operated in accordance with planned license conditions,
fully comply with these regulations.The monitoring program outlined in
Section 6 is designed to provide the data necessary to confinn this conclusion.
II.The concentration of ten minor constituents,including arsenic and seleniu""
have been added to Table 3.1.
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S.Page 2-32,Sectlon 2.6.2:This Section is not very specHic on
the recharge characteristics of the aquifer underlying the s ite (Oa~ota
SS).
There should be more detail on possible recharge in the iamediate
vicinity of the mi11.Tlits should include some detail as to the
prevalence of fractures and points which would provide avenues of
recharge.It would be helpful to also have site specific InfiltrationdataforthesoilsandunderlyingbedrockInthevicinityofthe
proposed tailings ponds.A discussion on the possibility that joints
lIay be open enough to provide a dIrect path to the ground water would
be appropriate.
6.Page 2-33,Figure '2.6:A vertical scale range would be helpful Infindingthedepthtovarlousunits.
7.Page 2-38,Figure 2.9:Since the DES states that uranium deposits
are also found In the Chinle,and Cutler formations and they are sho~m
in the stratigraphic sectlon In Figure 2-6,why aren't they represented
in Figure 2-9?In addition to describing the lithography of the Chinle
and Cutler formations In Figure 2.9,It should show which members of
the Morrison formation are potentially uranium bearing.
8.Page 3-1,'Section 3.2.2.1:Since the ore "Ill be purchased from
diverse sources and will consist of a mixture of differing
chararterlstics,It ts difficult to determine if the proposed mllllng
lllethod is the most envIronmentally acceptable without additlonal
Information about the ore.It ts not clear that the sulfuric acid
leach circuit Is the most acceptable due to the apparent alkalinity of
some llf the ore.
g.Page 3-6,Section 3.2.3.2.:We cor-cur "ith the staff that the
draInage design should be altered to Isolate mill site runoff into a
retentIon pond.
10.Page 3-7,Figure 3.4:The proposed land acquisition sho.n InFigure3.4.,appears to be much too small.Even with the precautlons
taken that are described in the text,~eposition of airborne
contaminants from stacks or.resuspension will probably contaminate land
beyond the~boundarles sho.m.The size of the buffer zone should be
increased.
11.Page 3-11,Section 3.2.4.7:This Section presents data on the
composition of the tailings that will be going Into the ponds,but
there Is no estimate on the amount of selenium or arsenic that might be
In the material.It Is hard to envision that the ore being r.;illed willnotcontainthesetwoelements.Data on these elements s~ould be
Included.
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12.Page 3-12,Section 3.2.4.7:The thinness of the cover over the
synthetic liner raises concern about assurfng the integrity of the
liner over the life of the project.There is no data as to whether the
inflow structures will be designed .to insure that the liner is not
damaged by the inflow of tailings.Also there is no information on the
long term effect of the chemical In ·the tailings on the liner.There
should be some discuss.Ion as to the feasibility of imp1aclng a natural
clay liner with a permeability of less than 10-6 cm/sec.This ,,'Ould
be vastly superior to a synthetic liner because It would have Integrity
for a longer period of time.Aclay liner should be required,but if a
synthetic liner Is used,there should be a thicker cover over the liner
(4-6 inches of silt)In the areas where Inflow will be occurlng.
13.Page 3-12,Section 3.2.4.7:Even If it is believed that the dikes
will not saturate,good practice calls for installation of piezometersorsoilmoisturetubestoIlIOnltordikemoisture.
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RESPONSES
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"A.P.Plurrmer,O.R.Christensen,and S.B.Monsen,Reetorina liig-I;ame Ra"lle i..
Utah.Publication 68-3,Utah Division of Fish and Game,Salt lake City,1968.
The applicant recognizes that complete success should not be expected in
nonirrigated plantings.Therefore,light irrigation may be required in the
initial establishment stages.Further,the applicant is committed to monitoring
and maintaining the reclaimed areas until stand establishment and perpetuation
is assured in accordance with the State of Utah Division of Oil,Gas,and Hlning,
Reclamation Regulation Rule H-IO (Sect.6.2.2).
16.The revegetation plan for reclamation of the mill tailings area is necessary for
long-term stabll ity for several reasons.The roots of the plants help stabllizethesoiltoreducewinderosion,and the cover helps break the ground-level w·lnd
to reduce wind erosion,reduces raindrop splash and downslope movement of runoff.
and adds a yearly Increment of organic matter to aid in rebuilding the soil
profile.
12.With the procedures and controls proposed for the illstallatiun of the liner in
cells 1-1,l-E,and 2.the staff believes that the impermeable synthetic liner
will Iimit seepage to a very minor quantity,if any.
This statement has not attempted to detail the procedures by which the impoundment
will be constructed or the liner placed.However,the applicant has proposed
installing a smooth,rut-free surface without protrusions as a liner base to
offer protection to the membrane during placement and subsequent use.Following
the installation of the liner,a protective soil cover would be placed over the
liner,and a maintenance and inspection program for the liner system will be
a condition of the license.Note that discharge of tailings directly onto the linercoverwillnotbepermitted.A 2-ft 1iner of compacted clay has been proposed for
cells 3,4,and 5.A review of tests results for the proposed clay material wll1
be completed prior to system approval to ensure that a permeability of 1 x 10-
em/sec can be achieved under the conditions anticipated.
13.Piezometers will be required In the dikes.
14.Section 3.2.4.7 has been revised and should eliminate these concerns.In addition,
the slurry and decant 1ines will pass through a safety containment pipe in the
dikes between cells.No failure by erosion is credible under these conditions.
Finally,the tailings impoundment system will be monitored at 4-hr intervals.
15.Plurrmer,Christensen.and Monsen·(1968)have stated that stand establishment
in areas with less than 23 cm (g in.)annual precipitation will not generally
succeed without irrigation.The 81andlng site,however,receives an average
annual precipitation of about 29.7 cm (11.7 in.).In addition,crested wheatgrass
pastures already established in this area without irrigation are good evidence
that the species suggested for reclamation can be establ ished in the reclaimed
areas without irrigation.The statement "1 ight irrigation may be required to
establish native vegetation"refers to the germination and initial establishment
of the plants.Areas that are irrigated for several years following seedingwillundoubtedlyproduceanexcellentplantcover,but it is likely that these
plants would be far less able to survive an interruption or cessation of
Irrigation than those whose growth characteristics reflect the arid character-
istics of the site.
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14.Page 3-13,Section 3.2.4.7.:The asslMl1ption is made that If a
pipeline failure OCCurS in one cell any tailings loss ·would be
contained.It loIOu1d seem that this would depend on the scenario
selected.A pipeline break such as the United Nuclear-Homestake
Partners break,..hlch took out the dike,could conceivably breach all
of the completed dikes for the White Mesa system if It occurred on an
upstream dike.This presUAles that at least one pond is full,that the
next pond Is partially full,and that the break occurs In the first
dike.Since the IIRC staff analysis concludes that water evaporation
may not proceed as rapidly as the appl icant proposes,this problem
should be carefully considered in pipeline routing.
15.Page 3-14,Section 3.3.2.:The San Juan River area is a "ater
short area.The arid climate will make revegetation of mill tailings
areas difficult,without frequent use of Irrigation during the growing
season.On page 2-39,the last paragraph,the staff states..."light
Irrigation may be required to establish native vegetation during
reclamation."We do not believe this statement adequately reflects the
reclamation effort that ..auld be needed in this area.
16.Page 3-14 Section 3.3.2.:Is the revegetation plan for
reclamation 01 the mill tailings area necessary for long term
stability?If so,have revegetation tests been performed that
demonstrate successfUl ro?vegetation?
17.~4-3,Section 4.2.2.:The first paragraph is misleading to the
reader .:hen considering other Information presented in Section
2.5.2.2.The results of the historical survey and recOlr",endations of
the Council on HistoriC Preservalion and the State Historic
Presenation Officer should be included in the FES.
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-4-
18.Page 4-5 Section 4.3.2.2:With regard to seepage Into ground
water after liner deterioration.the recently published ORP/lV·78-8
(Water Movement In Uranlun Mll1 Tailings Profiles)suggests that
seepage may continue for the lifetime of the pile.ORP/lV-78-5 (Study
of Engineering and Water Management Practices that wll1 Minimize the
Inflltration of Precipitation into Trenches Containing Radioactive
Waste)also notes that clay liners (and caps)are extremely susceptible
to biological damage and should be protect.ed from freezing.Native
clay contains substantial portions of non-clay material which
diminishes its sealant value.
19.Page 4-5.Section 4.3.2.2:Although the amount of ground water in
the White Mesa area (5 IIlle radius frOl1l project site)that is used for
domestic.livestock.or agricultural purposes is small.and careful
monitoring of this ground water supply will be required (during
construction and operation).I~e believe that NRC should consider
additional monitoring requirements of the runoff "ater from retention
ponds.Since·the ground water supply is located very close to the
surface.there ts a potential for ground water contamination in this
area.Cultivated crops are located as close as 1 mile north of the
project site..
20.pa~e 4-5,Section 4.3.2.2.:The description of the retention
ponds and catchment basIn for potentia1 ruptures of piped tailings)ts
not adequate as presented In the DES.HentIon is made of rock being
placed along the dikes of the retention ponds,but what kind of soli or
liner will be placed underneath the rock?
21.Page 4-9,Figure 4.1:The ingestion path~!ay should include
wildlife,such as deer.
22.Page 4-12.Table 4.8:The NRC regulation (10 CFR 20)applicable
dose limit for the bronchial epithelium is reported In working levels
(Ill)In this table,but was reported in cumulative ~lOrking level months
(ClIlH)in Table 4.6 of Io:oab DES.Thts inccnststency is confusing to
the reader and make comparisons difficult.The estimated radiation
doses to the bronchial epithellun as reported in mrem/yr In this table
appear to be too low..
23.Page 4-'13.Section 4.7.7.:While probably not of great
significance.it seems unlikely that there "ould be no adverseradiologicalimpactonresidentburrowinganimalsinthetailings areas.
RESPONSES
Revegetation can occur in the project.area as evidenced by the past treatments
of the land to improve range condition.These treatments have included chaining
of sagebrush,plowing the surface,and reseeding with crested wheatgrass
(Sect.2.9.1.1).Covering the disturbed areas with previously stockpiled topsoil
and reseeding with "luna"pubescent wheatgrass.crested wheatgrass,forbs,and
shrubs (Table 3.4)will closely replicate these past treatments of ne land and
should result in successful revegetation,assuming that proper planting time,
the addition of appropriate soil amendments (such as nitrogen and possibly
irrigation for initial stand establishment),and protection from grazing and
other disturbances are provided.
Please note that the staged reclamation plan should provide an opportunity to
verify the viability of the proposed cover.
17.Sections 2.5.2 and 4.2.2 have been revised and Appendix E has been included
concerning the currently identified cultural·resources and the mitigatory actions
that wi11 be taken.
18.ORP/lV-78-8 clearly states "under 1imited rainfall conditions ...any
significant vegetation cover on the tailings pile would use all availableprecipitation.leaving little or no water to flow below the root zone to
greater depths."Because revegetation will occur and because a 3.2-01 (lO.5-ft)
cover (minimum)is proposed over the clay cap to protect it from bioloqical damage
and freezing,the staff does not expect significant seepage from the tailings
impoundment.
19.Please refer to Fig.3.4 and Sect.3.2.3.2.Runoff from the mill .site will be
impounded on the site.No monitoring of runoff water appears necessary under
these conditions.
20.See responses to comments 14 and 19.Tailings impoundment construction and
operation are discussed in revised Sects.3.2.4.7 and 10.3 Alternative 1.
Dike.construction is shown in Figs.3.7 and 3.8.
2!.The meat ingestion pathway considered as part of the overall radiological impact
evaluation Implicitly accounts for Ingestion of wildlife,although the models
and parameter values used are specifically applicable for beef c,lttle.This
Is accomplished through the use of conservatlve occupancy factors,envi ronmenta1
transfer factors,and ingestion rates.With specific regard to the Inclusion of
deer as part of the Ingestion pathway for meat,numerical values In all three
of these categories would be reduced.causing a net decrease In the estimated
doses from the meat Ingestion pathway.
22.The noted change was made to more accurately represent the actual limitation on
radon-222 daughter concentrations expressed in 10 CFR Part 20.Similarly,the
presentation made In this Statement will continue to be made In future Statementsuntilrefinementsareconsideredjustifiable.The estimated bronchial
epithelium doses were calculated using the models and data provided in
Appendix 0 and have been found to be numerically accurate.
23.The staff agrees that during project operation such animals could receive doses
in rems per year,but not sufficient to cause observable effects.After
reclamation,considering the cover to be placed over the tailings,the staff
considers potentia1 exposures to be ex tremely small.
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26.8eslde the fact that there is no regulatory basis upon which transfers of orebetweencompetingoperatorscouldberequired.there is no overwhelming reason
from an environmental standpoint why this would be advantageous.
27.This information has been added to the text.
RESPONSES
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28.For the initial groundwater monitoring program,the appl icant plans to install
five deep wells completed in and cased down to the Dakota Sandstone aquifer,
as well as five Shallow wells with monitoring zones in (al the soil and
residuum and (b)fresh rock above the saturated zone.Of these wells,one
will be upgradient and four generally downgradient;the remainder will be
cross-gradient.The two deep downgradient wells will be operated as pumpingwells.The monitoring program will be expanded with the construction of
additional tailings cells.The downgradient pumping wells are planned to draw
flow from along the edges of the cells to the wells and to decrease flow and
contaminant detection times by increasing the hydraulic gradient.A program of
mitigation will be initiated if leakage Is detected.The monitoring program
appears adequate as proposed.
With respect to radiotoxicity.the critical organ and impact for yellow-cake-
uranium inhalation is dependent on the solubility category assumed.If yellow-
cake-uranium solubility in human lung fluid is assumed to be Class Y (years),
then radiation exposure to lung tissue is critical.That assumption has been
made for this analysis following ICRP recommendations.However,recentcontractordataindicatevaryingsolubilitiesforuraniuminyellowcake
depending on the specific chemical compounds constituting the yellow cake and
the calcining temperature.This issue is presently under NRC staff review.
25.The population density used by the staff is considered conservative.Denver has
a population density of 5418 people per square mile,and a potential similar
accident would calculate to 440 man-remS and 30 man-rems for Models I and IIrespectively.Effects on exposed individuals would not be more severe than
the accident discussed in Sect.5.3.1.
24.The staff recognizes that inhalation of yellow cake dust can cause health
effects due to the chemical toxicity of uranium.However,no clinical effectswereobservedamongtheindividualswhowereinvolvedinarecent(September
1977)yellow cake truck accident or in the subsequent clean-up.Also,uranium
bioassays of 27 persons who were in the vicinity of the'spill (including the
law-enforcement and rescue personnel)indicated that physically damaging uranium
intake did not occur.The highest reported bioassay being 18.1 "g of uranium/
1iter of urine.
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27,Page 5-8,S5ctlon 5.3.3.:Truck shipments of a",lnes and sulfuric
acid should be Iscussed,
28.Page 6-2,Section 6.3.2.:This Section Indicates that monitoring
wells will be Installed near the tailings ponds to detect contaminants
If they reach the ground water.8y the time any contaminants reach the
ground ..ater In a detectable level there would be a fairly large amount
of material moving through the unsaturated zone.If the applfcant
Installed one vaculin lyslmeters belo"each pond in the unsaturated zone
(5-15 feet below the bottom of the pond),It ~.ould be possible to
detect leachate movement well before it reached the g,·ound h·ater,If
such a device was Installed,It ~lOuld not endanger the integrity of the
liner and would allow the applicant to use fewer monitoring ~Iells.The
best monitoring well scheme "ould have one to three wells on the up
gradient side of the pond area and three to five wells on·the down
gradient side.The ~Il!lls should not penetrate more than 15-30 feet of
the fOl'1llatlon to minimize the dilution effect caused by sampling a
large perforated Interval.
24.Page 5-5,Section 5.3.1.:The major toxicity of yellow cake
appears to be heavy metal poisoning to the kidney.not radi~tion
damage.A chemical toxicity evaluation of accidental dispersal to thepublicshouldbemade.
25.~e 5-6.Section 5.3.1.:Yellow cake shipments in congested
urban areas appear to be neglected in the accident models.A
population density of 160 people per square mile is not an accurate
representation of an urban area,where larger traffic volumes and busy
Intersectlons Increase the likelihood of an accident with a higher
population dose potential.An accident model,utilfzlng specific data
for a metropolitan area such as Denver,would be useful in evaluatlng
the IIDst severe accident consequences.
26.Page 5-7,Section 5.3.2.:When ccnslderfng the likelihood of 7.6
ore truck aceldents per year fran the Hanksville ore buying station and
the econllOllcs of haUling low grade ore 163 miles to the IIhite ~IesaProjectsite,It seems appropriate to consider the alternative of
hauling the Hanksville ore to the proposed Shooting Canyon Project to
be located south of Hanksville,
,.,
I
RESPONSES
30.(a)As in the above response to 29(a).analyses of fi Iter samples for
polonium-210.particulates (weight on filters),and trace metals are not con-
sidered necessary.The monitoring of the Interim stabil ization program wi 11 becloselycontrolledinaccordancewithwrittenoperationproceduresandisconsideredadequate.
(a)&(b)Monitoring at the periphery of the tailings disposal area is not
considered necessary and the use of site boundary air sampling stations should
permit the assessment of the radiological effluents to the general populatinn,
This Is expecially true since the saqJling locations will be chosen usingthefollowingfactors:
•average meteorological conditions (windspeed,wind direction.atmosphericstabiltty);
•prevail ing wind direction;
•site boundaries nearest to the mill.ore piles•.and tailings piles;
•direction of nearest residence;and
•location of estimated maximum concentration of radioactive material.
29.(a)Because of the quarterly compositing of air filters.the value of analyzing
for polonium-210 is essentially el iminated because of the relatively high decay
of collected polonium over several months.Any polonium-2l0 present would be
due to decay of lead-210.Trace metals are not expected to be transported in
significant or accurately measurable amounts In the small quantities of
particulates anticipated.
(b)See above response to 26 for a description of the proposed ground water
monitoring program.Table 6.1 has been changed appropriately.
(e)and (d)Using reasoning similar to that presented in (a),neither polonium-21O
nor trace metals should be sampled in surface soil or sediment.
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29.Page 6-5,Table 6.1:The following'additions to the proposed
preoperat iona'monitoring program are recorr",ended:a)Air Particulate
Expaiidanalytical proto~ol to include polonium -210,
particulates ("eight on filterl,and significant
trace metals present In the ore (e.g.,arsenic and molybdenum).
b)Ground water
The monitoring requirements set forth on page 6-2 implies a
greater number of wells for monitoring the tail ings disposal
area than the six Indicated In Table 6.1.This apparent
Inconsistency should be explained.Due to the confusing
parenthetic remark-"from each "ell",It Is not clear how many
wells are within 2 kilometers of the 'tailings disposal area
and what the sampling frequency Is.
c)Surface Soil
Samples analyzed for lead-210 should also be analyzed for
polonlum-210 and significant trace metals found In the ore.
d)Stream Sediment
Same comment as for surface soil samples.
-6-
a)Air Particulate
Consistent witli the recommendation for the preoperational
monitoring program,analysis of filter samples for polonium
-210 (at least semi-annually),particulates (weight on filters),
and significant trace metals.Air particulate samplers shouldbe'located on the periphery of the active tailings disposal
area (one upwind and several dOhntllnd)monitor the effectiveness
of the interim stabilization prog,"am.Sampling should be
continuous with filters replaced ~,eekly.Each sample should bl!
analyzed weekly for gross alpha and monthly composition for
radlum-226.
b)Radon Gas
Samplers should be located on the periphery of the tailings
disposal area to quantify emissions from this source.These
statinns will have to be operated In the post-recl,mation
period to ensure the effect iVE'ness of the reclamation program.
30.Pave 6-7.Table 6.2:The following additions to the proposed
operat onal monitoring program are recoo.mended:
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RESPONSES
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(c)See above response to 27(b).Table 6.2 has becn changcd appropriately.
(d)This is not considered necessary as comparison of pre-and operational total
concentrations is as informative.
(e)The staff does not require sediment sampling in the operational monitoring
program.Surface-water ana lysisis as informa t i ve.
(f)Soil sampling at the periphery of the ore piles or the tailings piles is
not considered necessary.With an annual collection frequency and consideringtheintegrativecollectingfunctionofsoil,the results would probably be
inconclusive as to the origin of a radionuclide (e.g.,whether or not the
radium-226 in a sample from the ore pile periphery includes contributions from
the grinding and crushing staCk,tailings pile,etc.).
(g)The staff does not feel these suggested changes are necessary.
32.As was shown in section 10.5.1.4,U.S.requirements for UJOa will exceed
production capability for the next few years.Although the applicant may
export the uranium derived from the U30a produced at the White Mesa Mill,the
United States is a net importer of uraniurn and failure to 1icense the proposed
project would only result in the foreign demand being fi lled by other domesticl
foreign mills that could be producing uranium for consumption in the United
States.Sectlons 10.5,10.6 and 11.4 and Appendix B have been modified to better
reflect this current situatlon.
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31.Modifications in the tailings management program proposed by the appl icant shouldobviatetheseconcerns.Tailings deposited in lined cells will be gravity-drained,
and the liquids will be pumped back to the evaporation cells (cell.I,Initial and
cell I,Enlargement).The probability of a sequential failure of embankments
becomes very small after cell 2 has been filled and reclaimed.In addition,theembankmentthatformsthefinalbarrierforcontainmentoftailings(at any point
in the operating sequence)will be constructed only after review and approval in
accordance with Regulatory Guide 3.11..
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c)Ground water
The monitoring requirement set forth on page 6-2 impl ies a much
larger number of "ells for monitoring the potential impact of
seepage frOlll the tailings disposal area than the four indicatedIntabIe6-2.
d)Surface Water
fOprovlde a lIleanlngful comparison with pre-operational data,
analysIs for total and dissolved concentarations of specific
radlonuclldes should be conducted,not only totalconcentratIons.
32.Page 10-24,Sectlon 10.6:This Section states (as In previous
DES's)that the uranl...prOduction Is needed to fuel reactors that
produce electric power to U.S.consumers.If this is an important
consideration in IIRC licensing action,and we feel It should be,it
deserves further evaluation.We are becoming Increasingly aware of
foreign sale of yellow cake that the NRC stated In the specific FES lolas
destined for U.S.energy needs.Since much criticism Is being
generited by the general public concerning the hazards associated with
nucll.r power .nd the unpopular radioactive waste disposal Issues
(inclUding tailings),.Isstatements such as the above will further
erode public confidence in Federal actions related to nuclear energy.
e)Stream Sediment
Consistent In the preoperational monitoring program,annual or
sl!lll-annual sampling of sediment at the surface water stations
should be continued during the operatlonal period.
f)Surface Soil
In addition to the proposed 5 stations,soil collection stations
should be established on the periphery of the ore storage pad
and the tailings disposal area.Collection should be annually
with routine analyses for radlum-226 and uranium.Selected
samples (10 to 20%)should be analyzed for lead-210,polonium-210,and significant trace metals.
g)Vcgetation
for a totally comprehensive monitoring program,on site as well
as off site,vegetation should be monitored for radionuclides
concentrations.Perhaps,three to flYe on-site stations with
analyses for radlum-226 and uranium on all samples,and lead
-210,polonlum-210,and significant trace metals on selected
samples.
31.Page 10-9,Section 10.3.2.:lie concur with the staff that
Alternative 1 Is the IlOSt environmentally sound long term tailings
.anagement plan.~:e are however,concerned with the potential of asequentialcelldikefailurecausinganuncontrolledtailingsrelease
(Indicated in earlier cOlllllent)and the likelihood of the predicted
tailings drying time due to the synthetic liner.The recent EPA
publication "Water Movement In Uranium Mill Tailings Profiles"
(ORP/lV-78-8)Indicates that the tailings n:ay never dry adequately for
final stabilization and reclamation action without cOl1siderable
additional materials and efforLlle suggest that a tailings dewatering
plan be added to this alternative.
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33.P.ge 0-6,Section 0.4.1.:In the first p.r.gr.ph,the reference
should be task Group lung Hodel.
This section Is IlIUch to abbreviated for proper ev.lu.tion .nd needs
exp.nsion,The r.tlonale for .ssuming that Indoor radon daughter
concentration would be 50%of the outdoor radon cloud concentration,
should be explained,Since a WLM Is based on 170 hours exposure,it
should be E'xplalned-how continuous exposure to 1 III Is equal to 25 WlH
per year.We feel that the bronchial eplthelium dose convers ion factor
of 0.625 /IIrem/yr Is not .ppropl·l.te,A /IIore conserv.tive estimatebet..een this value and the 4 ...rem/yr per pel/m3 estimate in
EPA-520/1-16-001 "auld be more appropriate for ~RC licensIng actIon.
34.P.ge F-2,Section F.2.:Again,the r.:lon emission flux estimates
should be more conservative.~lore conservative (higher)estimates for
dry.IIOlst.and satur'ated tails seems appropriate for IIRC licensingaction.
35.No specific page:We .re Incre.slngly becoming a....re of reports
of stolen quantities of uranlUlll yellow cake.One such report describes
1.000 lbs.of yellow cake valued at S280,OOO which was stolen from a
New Mexico mill.Previously it \·,as felt th.t 55 g.llon drums weighing
800 lbs.and valued at S8/lb.(but for .;hlch there .,ere no un.uthorlzed
buyers)would not be readily stolen.HO"lever,in light of the dr.matic
rise in the price of uraniUII .nd .v.i1.billty of further processing
plants .round the world.It Is time to consider incre.sed pl.ntsecuritymeaSUI·es.
RESPONSES
33.This typographic.l error h.s been corrected.
The b.sis for the st.ff's dose conversion f.ctor for bronchial epithelium
exposure due to inhalation of short-Iived radon-222 daughters is now detailedinAppendIxI.
34.The staff considers the treatment of r.don exhal.tion sufficiently conservative
in Appendix F.The conclusion is the result of the following consider.tlons:
•The estim.tes for r.don emissions were b.sed on 100 h.(250 .cres!of
tailings exposed to r.don exh.l.tion.The maximum .re.of the impoundment
(oper.tion.1 t.illngs .nd ev.por.tion cells)subject to r.don exhalation
at any point in the mill lifetime should be no more th.n 90 ha (222 acres).However,cells 1-1 and 1·E are evaporation ponds (p.3-12)and hence
contribute an insignificant amount of radon eXhalation.Thus,there would
only be a maximum of 50 ha (124 .cres)of tailings subject to radon
exhalation at any point during the lifetime of the mill.The consider-
ation of the area subject to radon exhalation introduces conservativism
Into the final radon emission estimates of 5500 Ci/year.2480 Ci/year,
and 30 Cilyear for dry,moist,and saturated tailings respectively.
•The parameter values for the calcul.tion of the radon flux are considered tobereasonablechoicesintheliterature.*,t
•The staff h.s stipul.ted .dditlon.1 controls to dusting such .s w.ter spray or
simil.r me.ns,which would in turn reduce r.don exhal.tion by incre.sing themoisturecontentofthet.i1ings surf.ce.
.15.The .pplic.nt has provided a description of security measures to prevent theftasfollows:
E.ch barrel of yellow c.ke produced will be weighed and an identification numberstenciledonthesideandtopofthedrum.These weights and numbers will be
recorded and filed.Lids will be bolted onto the drum .nd "sealed."The .se.1
number will .Iso be recorded and filed.The yellow cake packaging room will belockedunlessauthorizedshipmentsarebeingm.de from the room.
Yellow c.ke th.t is stored inside the plant .re.will be in •fenced .re.
(6-ft ch.in link)th.t will be within the mill .re.6-ft fence with the g.te
locked unless .uthorlzed deliveries or shipments .re being m.de.
The entire mi II are.will be fenced with •6-ft chain-Iink-type fence .s
indic.ted .bove.All g.tes .nd entr.nces to the mill will be kept locked with
the exception of the m.ln g.te by the .dministr.tive office.This l.tter g.tewillbeundersurveill.nce or locked .t .11 times.Employees will be required
to p.rk outside the fence .nd p.ss through the main gate on foot.
"A.B.Tdnner."Radon Migration in the Ground:A Review,'"in The NatuP(4l
Radiatiun t'nvi1'Onment,J.A.S.Ad.ms .nd W.H.lowder,Eds.,University of ChicagoPress,Chic.go,1965.
tH.B.Sears et al.•('ol'r'elation of HadioQdtivt'!Wadtt:!Tt'eatment ('OlltH Iw.1 tht..:~'nlJil'unmental [",('fWt of Wuste fo.'j'fluents in the NuaZt!(ll'1-'ut!Z CyaZe [0/'/Joe it!
establishing "as [,flu)'U;/'l'lwticable"1,·ui.ietJ -Mill'-'l:1 oj"lIr'fmillnt (}l'el1~Report
ORNl/TM-4903,vol.I,Oak Ridqe N.tion.l labordtorv,O.k Ridqe,Tenn.,Hay 1975.
,-
"
':.:·.-,:~t;;-b'..b·~~_:,:.·'::-,;·;:,:5",,~:i;:m,',.(,.~',~-::·X:c;',-;N.~&:~'1ii~'~·'
r::'
Advisory
CouncilOn
Historic
Preservation
1522K_NW.
WoahlalloDnCo
2llOO5
Jaauary 17,1979
Hr.Ro••A.Scarano,Section Leader
Uraai...lUll Lic....iDa section
Pual Procaaaial ,Pabricatioa Branch
Div1a1oa of Pual Cycla ,IIaterial Safety
U.S.Nuclear 'eaulatory C....18a1oa
Waeh1aatoa,D.C.20555
Dear Kr.Scaraao:
Thia 18 10 reapoaaa to your requeat of Decaaher 15,1978,for
co_nta on th.draft eoviro......tal .tat_nt (liES)for the
Whit.Heea Urani...Projact,Utah.We hav.reviewed the DES
aad note that the undertaltinl will affect n..-roua archeololical
propertie.that may b.elilible for incluaioa in the National
Relister of Historic Place••
Pursuant to Section 106 of the National Historic Preservation
Act of 1966 (16 U.S.C.470f,eo amended,90 Stat.1320)Federal
agenciaa ...t,prior to the approval of the expenditure of any
Pederal fund.or prior to the IranUng of any license,permit,
or other .pproval for an undertaking,afford the Council an
opportunity to co...nt on the effect of the undertakiDg upon
propertie.included in or eligible for ioclusion in the
National Register.
r;;)While we note that the Nuclear Regulatory Co_iuion appearsPtobei.plementing stepa which will result in compliance with
,Section 106,until the requir....nts "f Section 106 are met,
the Councll .ust consider the DES incomplete in its treatment
of historical,archeololical,architectural and cultural
resourceS.To remedy this deficieDcy,the Council will
provide,in accordance with its "Procedures for the Protection
of Historic and Cultural Propertie."(36 CFR Part 800),
Bubstantive co-.eDte on the effect of the undertaking on
these properties.
R£SPONSES
A.Sections 2.5.2 and 4.2.2 have been revised and Appendix E has been included concern-
ing the currently identified cultural resources and the mitiqdtory actions that will
be taken.
,.,.,
Dear Sir:
Attachaent
Sincerely yours.
..,'·oJ,.
,,:o;':'i~/'::'
,JanUAJ"Y 19.1919
DEPARTMENTOF HEALTH.EDUCATION.ANDWELFARE
PUBLICHEALTHSERVICE HFV-2
FOODAND DRUG ADMlfflSTAATION
ROCKVILLE.U."YL""'D 2oe51
u.S.Nuclear Reaulatory CoIImiaaion
Waahinaton,D.C.20SSS
~C'·~kKennethE.Taylot.D.V.M.
FDA Eovironee,ntal Coordinator
Attached are ccmmente on DEIS (NlIREG-0494)related to the operation
of White Heaa UraDi....Project.Th•••COIIIDeDts pertain to·sections
not covared by the review of FDA'e Bureau of Radiological Health.
who auI.itted their co_enta io a letter dated January 10,1979.
Aa the coordioatiog offica,I noruUy would heve ulted the Bureau
of Radiological Health to tncorporate aubstantlve COlIJDBnte of other
PHS egenciea 84d/or HEW regional offices ioto a eingle set of co_ents.
Havina received the Center for Diseaee Control co_ents after the
Bureau of Radiological Health forwarded their co_ents,l.am
attachina CDC'a aeparately for ·your Department'a conaideration in
dealing with co_enta received by February S.1979,the DEIS co....entdeadline.
Attention:Director,Diviaion of Fuel Cycle and Material Safety
_:~""::"~"'\",~.,-;.............
-t.l?~{}<.,;;,.t,;,-.,
0S.CtiOll 3.2.3.2 .t.t..:"Stono run-off frOll tha ..Ul.ore .torasa pUea.
•nd or.buyinS .tationa will ba diracted to tha bterceptor drainsse
• •..•t.-n-......_,.......0'0""0 ..
'Co",,~,n
,---"":---'
RESPONSES
1.Section 3.2.3.2 has been revised and should clarify that this runoff will be
impounded.Sections 4.3.1 and 7.3.1 have also been appropriately modified.
Sections
c7'~g~
'rank S.Liaella.Ph.D•
DUE January 15.1979
DEPARTMEI\;T OF HEALTH.EDUCATION.AND WELFARE
PU81.1C HEALorH SER.\'ICE
CE~T..a foa I)lSlASI CO~TaOL
L...~__.~
ditch 810llS tha a..t.m ..arsin of tba taUinaa impoundlllant.The .taff
rec_de that the drainasa duiao ba alt.red to leolate mill site
Dr.Kennath E.Taylor
'ood ,DruS Adain1etratiOD
USIlRC.DES Related to Oper.tiOll of Whita Me..Urani....Projact (San Juan
Gounty.Utah),
runoff into a retention pond."We asr••with the st.ff r.c.....sndstion;
Chief.BovirOllllent81 Affaire Group
Bovironaent81 Be81th Servica.DiviaiOD/BSS
4.3.1 and 7.3.1 .hould incorporata thle idaa.
.Ul aite runoff .hould ba pond.d and evaporated if feaaible.
MEMORANDUM
ro
fROM
,uaJICT:
Page 2
Hr.Ros8 A.Scarano
White ...Urani..ProjectJanuary17,1979
Pleaee call Brit Allan Storey at (30J)2J4-4946.an FTS
nUllber.to aee1et you in compleUng this proceaa.
Sincerely.~~-Waatern OfUce
levi...anel eo.pl1ance
,.,,,,
,:,!,d.i-~i;·.;,.'.;;';"'~'i·.-
Deer Sir,RESPONSES TO HEW CO"'ENTS
.,,
,.,
~__.'E~J
1.Staff analysis indicates that ingestion of ""'at grazed in the area ill'l1lediately
south of the site would result in doses in excess of those allowable under
40 CFR Part 190,which becomes enforceable for uranium mills as of December 1980.
Should the subject area remain available for grazing as of that date and should
further NRC evaluation continue to result in dose estimates above compl iance
levels,the mill operator would be required to undertake mitigating actions thatcouldconceivablyincludemillshutdown.However,the primary sources of
potentially excessive meat ingestion doses are radium-226 and lead-21O transported
in airborne tailings dusts.Due to the progressive nature of the tailings cell
construction-fill-reclamation scheme,the.available dusting area of dry tailings
would be minimal.ThUS,actual releases during this time would not be expected
to amount to the quantities assumed for this licensing evaluation,and noncom-
pliance with 40 CFR Part IgO would not be anticipated.The NRC staff intends to
remain fully cognizant of this particular situation and to fully enforce the
limitations on offsite exposure embodied in 40 CFR Part Ig0.
2.No attempt has been made to quantify the potential occupational doses under
accidential conditIons because there is no evidence that this infonnation would
add to that already provided in Section 4.7.6.That section includes a brief
sUlllllary of mill exposure data which are required to be reported to the NRC and
notes that the combined exposure of an average worker to the radioactive component~
present (under all conditions)does not exceed 25%of that pennitted.That
section also notes that protection measures to reduce occupational exposures
are periodically reviewed and revised in accordance with the requirement to make
such exposures as low as is reasonably achievable.
For ingestion pathways,bone doses are critical.However,following an accident
situation,food ingestion exposure would be controlled through monitoring and
condemnation procedures.if necessary.Therefore,only inha1ation exposures
are routinely evaluated for accidents.
3.
'----~--~-~
January 10,1979
RESPONSES
DEPARTMENT OF HEALTH.EDUCATION.AND WELFARE
PUl!ILIC HEA'TH SERVICE
FOOD A,NDDRUG ADMINISTRATION
ROCKVILLE,MARV.LAND ~0I57
s£:e~~~
;~,
Bernard Shleien,Pham.D.
halstant D1Tector for Scientific
Affe1ra
Bureeu of lediologieel Health
2.Occupational dose••re dlscu••ed for normal operating conditions
(p.4-13).There 10 no dloeuee1on of potenUel neeupetionel
do•••under .ccidental conditions.
3.FrOll eeleuledonB io eee.4,bone eppeera to be the eriUeel
orl.D.However,in di8culsing the t...pact of .ccidenta,dose
co_it.entl .re c.lculated for the luna,rather than for bone.
Vbil.It ia recoanlzed th.t bone do•••are IIOst likely to
occur throuah the 108••tloD pathway.I believe that dose.to
thi.organ aerltl dilcu.aion under accidental clrcuutancea.
.1.Pele 4-10 indieetee thet bone doee (Teble 4.8)from ingeBUon
of ..et would ""eeed 40 CPR 190.aeferenee in doe..ent to
negott.tlonl to reltrict acce••by grazing c.ttle would not.
in IIY opinion,constitute.definitive action to allay concern.
concerning this potential i.pact.
Attention:Director,Divi.ion of Fuel Cycle and Material Safety
Following ere e~enU on the DEIS (1IUIlEG-0494)releted to the operation
of White M•••Ur.nt....Project.The.e c~ent.are rel.ted only to the
rediololieel apeete 'lIeeeribed in the doe..eot.
U.S.Nuclear aeluletory eo.ieaion
W.ehinltOn.D.C.20SSS
SiDe.rely your••
,.,
or.
RESPONSES
No response 1s requlred,
11 January 1979
Hr.Ro..A.Scarano
Urani..KUl LicaDll1Da Saction
8uclaar Ilepalatory ee-taaion
VUb1Jlltoa.D.C.20555
Dear Hr.Scarano:
Corp.of !nain.ers intereat in tbe project 18 prillarlly the effect the
project would have On flnocl probl_in the ar...the relationship of the
project to Corp.project.aDd .tudi....nd COTlpl18DCe with Corps regula-
tory pamit prolr_.We have DO c.-ent••iDc.tb.project do.s DOt
.ppaar to contribut.to.or .ffset.flnocl probl....iD tbe aree.doee not
conflict with Corp.flnocl control projecte or plans.and it spp.ara that
th.project would DOt require •S.ction 404 p&l1a1t uoder tb.Clun Veterkt(33 USC 1344).
Tbf.a 18 in raply to your letter of 15 Dece.ber 1978 reque.Ung review of
tb.draft eDV1ro_nul .tat....t for the llhite llua UraniUla Project naar
Ilaodilla.Utah.'lbe propoud projact is within the area under jurisdic-
tion of Seer_to Di.trict.Corpa of Engineers.aDd accordingly.Los
.&qalaa District referred the corre.pond.nce to out'offic.for reply.
IiIJuJ 1h &;;L
.f"J;WRI;!C.WEDDELL
Cbief.Enlin.erfol Dlvlaioo
!baDIt you for tb.opportunity to review aod COllllBDt on tb.propnsedproject.
~!1 DEPARTMENT OF THE 'RMYe"CIIAW.N'YO DISTRICT,COR~Oil'ENGINIEER.
~~J e80 CAP'lTOL MALL~aACII"".NTO.CAUII'OllHIA 8S8."
R."LY 1'Q
&1'1'_N1'IONO~
SPUD-V
-~,-,-,
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RESPONSES
No response is requi red.
_'...I
-~,~,'::,?tJ:;.";:':'·:.;':;;~;"I~ili:r!:·,:,:"!,:.-
4012 Federal Building125SouthStateStreetSaltlakeCity.UT 84138
Janijary 19.1979
SOli
Conservation
Service
Dear Sir:
We have reviewed the December 1978,Draft Environmental Statement,
related to the operation of White Mesa Uranium Project by Energy Fuels
Nuclear,Inc.This docullent WIS Identified as Docket No.40-8681 and
was trtnSllltted to us by your Decl!llber 15,1978 letter.
The points of conslderltlon where the SCS has Interest or expertise have
been adquately addressed.We have no specific cOIIIIIents.
Director
Division of Fuel Cycle and Material Safety
U.S.Nuclear Regulatory COIIIIllssion
Washington,D.C.20555
14wrJlJA~'tr:~eD.McMl11an --;;
State Conservatlonlst
~
f~~Unired 5t.lesfW)l .Dep.ortment 01.~Apiculture
~~~:{------
FEDERAL ENERGY REGULATORY COMMISSION
W......NGTOH.D.C.20426
INft.P'LVft......TOI
February 22,1979
Mr.Ross A.Scarano
Section Leader,UraniUII Mill
Licensing SectionDivisionofFuelCycle and
Material SafetyNuclearRegulatory COII1Ilssionwashington,D.C.20555
Dear Mr.Scarano:
I am replyin9 to your request of December IS,1978 to the FederalEnergyRegulatoryCommissionforcomnentsontheDraftEnvironmentalImpactStatementfortheWhiteMesaUraniumProject.This Draft
EIS has been reviewed by appropriate FERC Staff components upon whose
independent evaluation this response is based.
The staff concentrates its review of other agencies'environmental
impact statements basically on those areas of the electric power,
natural gas,and 011 pipeline industries for which the COM1ission has
jurisdiction by law,or where staff has special expertise in evaluatln9
environmental impacts involved with the proposed action.It does not
appear that there would be any significant impacts in these areas of
concern nor serious conflicts with this agency's responsibilities shouldthisictionbeundertaken.
Thank yO!!for the opportunity to review this statement.
Sincerely,
~'I,,~..J'.~~<-
ad M.Heinemann
Advisor on Environmental Quality
RESPONSES
No response is required...
,,'
::(:~1~";:';:"'.'""';:"'"i~"-"
-~==]
';-
,~,n
RESPONSE:
Section 3.5.1 has been changed.,
.,',\::,
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rr:-:'"C
""!'A.'"I~~,
.;':-)••,!'
"~)..."/.
~.O:~I,,~~:~:,~lt,I"~;:I:«(;-h'~~/7'JJ
\'",...,N':'I"N f)(;:roo-'"
,'o<oa"(202)42f,..22('2
.12 April 19/9
DEPAiHIJ1::m OF TIlMlSPOllTA-rJON
Ui'JITED STATES COAST GUARD
D2ar !'II'.Scarano:
Sinct.:rt:!y,
TIlisis in respons"e to your letter of 15 December 1978 fOrl-larding the
drilft environmental impact statement on the Uhitc Mesa Uranium Projec:t
for coriunent.
The opportunity to review this draft state":ent is appn·ci<1t~(I.
DOT Coordinator for ,.,rater
HE"SOllTces
f{(~1
"Section 5.3.1"-First sentence:The Del'urr::me"t of Transportntion
does not classify containers as Type A.This is done by the shIpper."
Hr.Ross A.Scarano
Fuel Processing &Fabrication Branch
Division of Fuel Cycle and Material Safety
u.S.Nuclear Regulatory Commission
Hashington.D.C.20~55
The concerned operating administrations and st,Jff of the OCI)artTlIent of
Transportation have reviewed the material,8Hd the Offi(:e of Hazardous
}olatcrials Regulation has the fol101dng comr.ent:
GP,0'\/55
If••14W "".c.\nIlyewi:h.
li6T,'.::J.;~;.,J!~'!''''''-'''",,,,-'-_...._-
Gentlemen:
I...o
{'
1~'Wt"\1N'Ulh I..."ph,!~"'ll'01/,;PO lJu..l~)I.'J.~;"lt ld~CClly Uldhl"lllll(l
8UI!dJtil.'l
January 31,1979
Sca1t M.M'lhhon.GOVIIf"nof.Stele ofUWl
Anthony W.Milcheli.Ph.D..hecull...01'-':10'
-'<·~·;",.'!.:>;,:~::,;-~·.:..-;--,..",.,}~-~:jri"....'t1'f.i-i:-::,::-:,,~;;..
."""'1',dl'IUI",IIUU""""'uIL,-,."
''':,~;51:18ii~i:::'_
Social Services
u.s.Nuclear Regulatory Conmission
Washington,D.C.20555
We will appreciate receiving clarification of these matters.
Sincerely,
9~~"""\G~'C_~
Richard C.Hansen
Associate Deputy Director of Health
Envi ronmentaI Health Services Branch
Re:White Mesa Uranium Project
Environmental Impact Statement
A review of the above referenced report reveals that questionsremainconcerningairpollution..
This is explained by the enclosed copies of memoranda from ourBureauofAirQuality.
RCH:mkh
Diwil.onofH••11b
En..",lnmt'lll.1fte.1lI1~'''ICt''1j''''lChJ.mciD ClowOttJ.lul~UlflfClu'ul He.1Il1
Enclosure
Subject:White Mesa Uranium ~lill -Energy Fuels Nuclear,Inc.
-·:·i.....
.\'
;';,";;:£'~:~.;~'{".,~f.~it.,~'i~:i -·_,f,,~~_'_'.~""',-(';'-~';'.;~..'",,:'-:""~;-i~.•:.-
,•:...J
The White Mesa Project is currently being evaluated by the appropriate regulatory
authorities to ascertain if PSD regulations apply.The appl icant must comply
with all applicable regulations under the PSD rules,including any required
sampl ing methods to demonstrate performance.
Memorandum
Dill:December 7,1978
533-6108
It
An EQu.1 O~o'tunIIY Employ.,
From:Casper A.NeIson
To:File
Social Services
Yellow cake (ammonium diurante)is precipitated from the strip solution
with ammonia.Yellow cake slurry is to be dewatered in a centrifuge and pumped
to.a 6'diameter oil fired multiple-hearth dryer (alciner).The dried con-
centrate is reduced to minus 1/4"si.e through a hamer mill and packaged in
55 gallon drums for shipment.It is proposed to conduct the drying,crushing
and packaging of yellow cake in an isolated,enclosed building with negat.ive·
pressure to contain and collect (by wet scrubbing)all air borne particles.
An amine-type compound carried in kerosene (organic)is used to absorb
the dissolved uranyl ions from the aqueous leach solution.Kerosene (hydrocarbon)
vapoT is emitted to 8 limited extent during this solvent extraction and strip-
ping process.It is proposed to vent this vapor to the atmosphere by forced
air building ventilation at 6 changes per hour.
Ores are being blended and will continue to be blended according to
chemical and metallurgical characteristics.Crushed are will be wet-grolUld
(SAG _semiantogenous grinding)prior to the H2S04 leach.Acid leaching will
produce S02 and acid mist in sufficient quantity to Tequire covered tanks and
demister exhaust fans venting directly to the atmosphere.The leach·solution
containing t.he uTanium (and vanadiwn)will go to the solvent extraction section.
The barren waste will be pumped to the tailings rejection cells.
The project site is adjacent to an existing buying station which includes
a stockpiling area and sampling mil I.It is estimated that 250,000 tons of
ore will be stockpiled prior to start·-up of the ..ill .
The mill will have a design capacity of 2000 TPU.Operations would be
continuous.340 days per year.Conventional milling methods will be practiced,,~hich includes grinding.two stage leaching,solvent extraction;precip.itation
and thickening,dr)'ing and packaging.Because vanadium is not present in all
are receipts.the vanadium circuit will operate approximately 120 days per year.
Vanadium precipitate wi II be dried and fu.ed before packaging.
EFN,Inc.proposes to construct and operate an acid leach uranium mill
and associated facilities for producing yellow cake uranium concentrate and a
more limited quantity of vanadium concentrate in San Juan County approximatel)'
six miles south of Blanding.'San Juan County is classified as Class II area.
ass-XI 12117
page 2
Memo -Energy FueIs
12/7/78
By-product vanadium,when present,will report with the aqueous phase
of the solvent extraction process.An amine-type compoWld carried in kerosene
will be used t.o selectively absorb the vanadium ions from this equeous (raffinate)
solution.The organic will be stripped of vanadium with soda ash as an am-
monium metavandate precipi-tate.The slurry is to be filtered,dried in a
mUltiple-hearth furnace,and fuzed to produce black flake (V20s),which is also
to be packaged in SS gallon drums.This operation is to be conducted under
conditions like that for preparing yellow cake for market,including ·wet scrub-
bing for collection of particulate matter.
Coal will be used as the major fuel for both process steam and space
heating,with oil-fired boiln as standby for 30 days Eer year.It is estimated
that the maximum heat input requirement will be 33 X 108m's per hour (40 tons
coal per day).Fly ash and bottom ash will be sent to the tailings pond.It
is proposed that the coal fired boilers be equipped with a cyclone fly ash col-
lector of 90S control efficiency.Due to the small size of the proposed oil-
fired boile.r (lO X 106 8m/hr)and limited operating time (30 days/year),there
is no intent to apply particulate emissions control to this source.EFN,Inc.
environmental report indicates that the sulfur content of the coal to be used
will be 0.3S,which is about one-half the average sulfur content of Utah coals.
The White Mesa Uranium project includes constnlction and use of a laboratory.
Gaseous fUMs emitted from laboratory operations will be small and considering
the dilution in the collection suck should be inconsequential.
There will be fugitive particulat'e emissions resulting from construction
actiVities;wind erosion of stockpiled are and coal;front end loader handling
of ore and coal;wind erosion of a portion of the tailings area;vehicular
traffic on unpaved roads.
See notes and calculations on Appendix A sheets and Table 4.1-1 -Gas-
FUIIll-Dust Generation Areas;Table 4.1-2 -Stack Heights 'and Emission Data.
See pages 6-13 -Environmental Report.Dames and Moore fOWld that
aaxillUll ground level concentrations frOID the dryer and boiler stack were
obt.ained from stable conditions and low wind speeds.Therefore.diffusion
calculations should include use of a stable atmosphere (F Stability)and wind
speed of 2 ..ters per second.Terrain fluctuations are slight within 2000
meters of the proposed mi11;therefore.terr3in probably need not be considered
in diffusion Calculations.
David "arkley,Environmental Coordinator,was contacted by telephone
December 6,1978,relative to need for additional information and clarifica-
tion of some statements and data in the Permit Application of November 21,1978.
He will confir..'replies by letter.
i1
_.~__.__~tNt t m M ft..n·w.7"'.5 'rs n?nmetedvlgn,.,'4tdih rik..*w..-er,a5C_r "·2 7 ••7'7
~
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Subject:White Mesa Uranium Project
.~-----.
f
~~
~----..,,- Jil~....lL__~_~~~CJ
1979
Memorandum
An EQUeI~tuntty (Il'1O'0""
Associate Deputy Olte:January 25,
Oi rector of Health ,1
Director,Bureau of Air Quality (,Pr
Richard C.Hansen.
Alvin E.Rickers,
To:
From:
11
While both statements address air quality In a very general way,
there Is concern about both documents.The background ambient air quality
data from the proposed plant site which are referenced In both documents
were obtained by static sampling.This method Is not equivalent to the EPA
reference IIN!thod and therefore.the data are subject to question.It Is
doubtful that such data would be acce,table particularly if it were proposed
for use to fulfill the requirements of the Federal Prevention of Significant
Deterioration of Air Quality criteria.
The environmental Impact.statements for the White Mesa Uranium
Project prepared by both Dames &More and the Nuclear Regulatory Com-
missions have been reviewed.
Social·Services
DSS-~12/n
Ve appreciate having the opportunity to review this document.
p
';;'
RESPONSES
No response is required.
Draft Environmental S['.teaeDt-Whit.·~es8Uraniull Project
ROBS A.Scarano.Sect10n Leader
u.S.Nuclear Regulatory ea-lssion
Div.of Fuel Cycle'Haterial Safety
Vuhinaton.D.C.20555
UNITEDSTATES DEPARTMENT OF AGr.ICULTURE
SCIENCE AND EDUCATION ADMINISTRATION
OFFICE OF THE DEPUTY DIRECTOR FOR
AQRICULruRALRESEARCH
WASHINQTON.O.C.20250
Subject:
To:
We have reviewed the draft environmental iJlpact stateaent related to
operation of the propoaed White HeA Uraniua Project located in
San .Juan County.Utah;
We have DO co_eats ~o add to tbe .taff evalu.~loD and recOllllendatlons.
7~
H.L.BARRlll/S
Acting Deputy Assistant Adllinistrator
;_'.b-ili-.s~·,,i-.':\(o"O.<;",
Scoll M.Malhelon,Govttnor
.,'~~
t
.~en
L .::JC~l-----'lL:.~;r-',
2.This opinion was revisad by the Utah State Historic Preservation Officer.
The White Mesa Archeological Oistrict has since been determined to be eligible
for inclusion in the National Register of Historic Places.
I .The staff agrees with the co","ent.
RESPONSES
NM"/!~)",;:/1
Deer 1Ir.lIBrtin:
lIE:lbite 1IBsa.SaD Juan Cbmty
January 12,1979
1Ir.Jack llartin
Assistant Director
}\)els Cycle Safety aDd Liceusing
!hUed State NuclearIIeilUlatoryQmn1ssion
7915 Eastern AWDUe
Silver ~1Dp.IIIIryland 20901
In smmary;the alternative sites,even if there \IOIld have been no hydro-
logical pr:oblBllS,would probably have presented a larger probl"'"in the
mitigation of cultural resources and that the nanination of the sectionsotlandaroundtheprocessingplant\lOJUld probably be unacceptable as an
archeological district.
:--~"
Ilt:l'.\R1'~If.X I OF
IlI:W:1.0I'\I[:\T SERVICrS
:tCi~;:~~}:'(~:~~:~;
STATE OF UTAH
'Ibe purpoee of this letter is to address sane additional concerns that
the Nuclear Regulatory O:mnission aDd too Advis>ry Cbmcil may have
coocerning the mitigation of cultural resources that are being :fnllacted
by the developDBl1t of a processing plant on Ilhite Mesa by Energy fuels
Nuclear.
(0O:1e issue is alternate site location for tbe mill and tailings.It is
our undBrstan~that alternate sites l'el"e oot considered because of
hydrology probl81J3 and that because of this,archeological studies were
DOt done of these areaS.It is too opinion of our staff that if studies
would have been done of tbe four alternative sites"that a higher or
equal degree of density or archeological sites 1OOU1d have been located
and mrs OCIIPl1cated mitigatioo lIllY have been required.o A eecond issue C£lI\C8ms the possibility that this area could be considered
as a possible llallination to the National Register of Historic Places as an
archeological district.It is our opinion that this intonnation by itself
would be insufficient for naninatioo as a district,it is felt that the
total area of White Mesa \IOIld have to 'be looked at to 'be naninated.'!be
boundaries of this project \IOIld be considered artifical and woold not
take into consideratioo too natural barriers that ,""uld be necessary for
a IICIlIinatial.
:\,ISI()S 0.';INDUSTRIAL PROMOTION TRA\'t:l.Ilf.\·rUW'\lfXI.f.XPOSln()~s .511\1'[IIIS1(JR\'.U;-.,t:.\K"fS
1Ir.Jack llartin
January 12,1979Page2
Should you need assistance or clarification,please call or write Wilson G.
Martin,Preservatioo 1leIIe1opneot <bordinator,Utah State Historical Society,
307 \fest 200 Soutb,Salt Lake City,utah 84101,553-6017.
Sincerely,~~Bxecutiw Director
IDd
State Historic Preservation Officer
JlD:jr:B746:SA:J-l
'l"
~'"
_·_·::i;lJ.h;~,_,
o'IVISIO~0.':INous·rRI."I.PROMO.,.,ON .l°R;\\'EI.UI'.\·f.I.IW~1I'I.C\.I'OSITIU:"S -51\'1 •.I1ISHHn'....:-.1 o\RI~
STATI::OF UTAH
~....i
';"
~"
RESPONSES
=.i
3.Appendix E has been included and should resolve this cOl1lTIent.The actual
IIIOnitoring plan will be developed in consultation with the Utah State Historic
Preservation Officer.
2.Table 2.18 has been updated and a footnote added that affected sites are show.
in Fig.3.4.
1.The text has been changed to the correct number of sites.
l _
r----,.-;~_,--J
IlEl'ARDIE:'\T 01'
1ll:\'ELOI'\IEIo:r St:R\'ICF.S
J,Phillip KeeneIII
[ll:cculiwDirector
104 SCltc ~pitol
Sale LakcCity,Ur~h84114
Tclephonc:(801).555-S961
SconM.~bthelOn.GDlIcrnor
January IS,1979
1Ir.Il:>ss A.Scarano
:fuels Cycle Safety and Licensing
Utited Btates Nuclear lIegulatol1'
CamI1BBioo
7915 Eastern .Avenue
811_SprillllS,Maryland 20901
lIE:OmDents OIl Draft EIB Stateneot,Illite ~lesa UranillD Project
Dear 1Ir.Scarano:
In response to your request for review of the draft envirorrrental
1JqJact statenent on the White Mesa Uranilml Project,the staff has
one general caunent and three specific canrents concem,ing the
eultural resoorces and the potential inpact on tho!!!,resources,
In general,perhaps DOra space could have been allotted for a
discussion of the hackground of archeological impacts and proposed
mitigations of those 1JqJacts.
Spec1fic ccmnents about the statBllSllt are:
(1)2.5.2.3,Illl.2-19 -The last paragraph should read 45 archeo-
logical sites instead of 25 archeological sites.
(2)2.5.2.3,pg.2-20 -<hart 2.18 should reflect all 112 sites
located.It is realized that the infonnatioD 011 all sites was
probably not available at the time of the draft,but the new infor-
mation slnu1d be reflected in the final statanent.
(3)4.2.2,Illl.4-4 -Qmceming paragraph 3.it is suggested that
there slrJuld be nrJDitoring of activities at the Mill Sites for
subsequent developnent activities,which we agree lwith;ho\\ever.
the use of the tenn Mill Q:Jeration suggests that an archeologist
be IXJt on the staff to DDDitor all Mill ~rations for the life of
the Mill,and oe feel this is unnecessary.
J~~J!:~\'.~'(75:~.:~'·';~t."r•.~;~~~,::~y
1Ir.Boss A.Scarano
January 15,,1979
Page 2
It you have any questions or concerns,please contact Wilson G.Martin,
(BOl)533-6017,or James L.Dylansn,(BOl)533-6000,Utah State HistoricalSociety,3fY1 West 200 South,Salt lake City,Utah 84101.
~i)~
J.Phillip Kseoe III
Executive Director
and
State IIistar1c Preservation Officer
JID:Jr:B746/SA:J_l
f'
~,
If you have any questions or concerns.please contact Wilson G.
Martin.Preservation Development Coordinator.Utah StateHistoricalSociety.307 West .200 South.Salt Lake City.Utah
84101 •.[phone].
•~i;(e~.~l.y\:J\\.~\r,.A1·........\I",~)JIJ"~".;,
J,j Phillip Keene III
Executive Director
andStateHistoric Pr~servation Officer
;-..,<D
==~]~~.~=:Jc---,::....J
RESPONSES
B.Pursuant to 36 CFR Part 63.3,the White Mesa Archeological Oistrict hasbeendetenninedtobeeligibleforinclusionintheNationalRegister
of Historic Places.
A.The staff agrees that.a consideration of archeological resources would not
result in the choice of another of the alternative sites in this case,
-..,~.;~.~.:
Uiubtlh'h.ont'~lIe ·lIuwudC.P.kr,Jr.
ni/~boolhI~rilhlh •'1..11...1J.Uhu'r
On.....11 ni ;)l;lh!lIi;IUI'~
MfhinT.Sll1ilh.Dj~clor
Crllne Bulldi....Suite 1000307l"clt2nd Sc.tulhS.1I L.keClI)',l!tah84101Td.phon.(8011SJ3.S7SS
~(~~'~~i·7'!~·:i~)f·
S('oll \..M.the-IOtI,GoVf'r1lDf
IlEI'.\RT~IENTm'
Dn EJ,OP~IENTSERVICES
SHTE OF UTAII
oUr."fed J.""mel'
~Il••ill~,\I"nto,n
;/'.,
f"~.:";~::,{J
\~/~~y'J'.":--;-;~.,y''':''':~~
WGM:jr/B746SJ
L
Mr.Jack Martin
Assistant Director
Fuels Cycle Safety and Licensing
United States Regulatory Co.-ission7915EasternAvenueSilverSprings.NO 20901
January 23.1975
~-nlt.II£,~hRY ~~~£~¥)r.f.~,~lcA~~~l~..~fn.1II ..Thn-ultII-.I.u....
IJr.Utl'"(;.1_.,1011 •Dr.WlI)'MIi..lhllton •lIelrnl.I·,,~n...l..a
Dear Mr.Martin:
Several issues have arisen during our discussion of the White
Mesa Mill and Tailings Development.We would like to go over
those concerns one at a time.
~First.the selection of sites for the location of the mill andtailings.We understand that alternate sites were notconsideredbecauseofhydrologyproblems.However.it is theopinionofourstaffthatifthefouralternativesiteshad
been researched for archeological resources.that areas of anequalorhigherdegreeofdensitywouldbefoundsincethesealternativesiteshavesimilarcharacteristicsandtheproblemofhigharcheologicaldensitieswouldremain.
(!)second.we did not consider .nomination of the site as a
district at this time.The portion of the property beingdevelopedbyEnergyFuelsNuclearwouldofneccessityhave tobetheboundariesofthedistrict.since sufficient researchhasnotbeendoneforthewholeWhiteMesaarea.Under ourrules.this would be considered an artifical boundary and wouldnotbeanacceptableperimeterforahistoricarea.Therefore.we have considered the individual sites on an individual basis
of eligibility.This criteria would apply regardless of
whether it were a district or not.since the sites they have
found not eligible would also not be eligible within a historic
district.
'.;,'".'/'..,........!I".,.,.I'U •
Dear Sir:
February 2,1979
{"..C)
_.:c:.;:.~i7::=..:,..
RESPONSES
No response is required.
...'.u'·.••,:J.•,.
.j ./
./.'.,
jJt.Jh D~{IJ'rJnlnt\01 EmploymentSecurity
U.S.Nuclear Regulatory Commission
Office of Nuclear Material
Slfe~and Safeguards
IIashington,D.C.20555
..:.JOBQf~
SERVICE,.
The staff of the Blanding Job Service Office has been rather deeply
involved with the Energy Fuels Nuclear operation from the time it
first started in San Juan County.The past,current and,we believe,
the future impact of the Energy Fuels program,has been and w1l1continuetobeverypositive.
Our business is jobs and this is what Energy Fuels is providing,in
an area which needs jobs very badly.H.e draft envtronmenta 1 state-
ment which was issued in December 1978,does not address some socio-
economic conditions which relate to the need for jobs.For instaoce,
the Novelltler 1978 report frOlll the Utah Department of Social Services
lists 555 famllies containing 2,084 individuals "ho are receiving
publtc assistance in San Juan County.This does not include indivi-duals who are on medical assistance only.This means that 14.781 of
the total coun~population Is receiving public assistance under AFOC
or GA categories.This Is by far the hi ~hest welfare percentage in
the entire State of Utah.It Is our feeling.that the only way to
reduce this finanelal burden and break the dependency cycle is toprovidehighqualityjobs.
A review of the draft statement indicates that Energy Fuels is pre-
pared to do an excellent .job with environmental and other community
concerns.On the basis of these and other facts,we support the con-struction and operation of the White !':esa uranium mi11 and urge you
to issue appropriate licenses as soon as possible.
Very truly yours.
Harold J.lyman,M,,'nager
.:Qrrlt',.MIt!'rr,on.
OOlhl,ntN
A,BMCI.IyeMIl".,.Admin/,,,.,,,,
104 navey l.aboratory
Penn.State University
University Park,Pa
16802
5 February 1979
Director,Division of
Fuel Cycle and Vaterial Safety
U.S.Nuclear Regulatory Commission
~lashington,D.C.
20555
Gentlemen:
Enclosed is my analysis of the White Mesa Uranium Project.
Please note that the information is my own and not necessarily
the opinion of The Pennsylvania State University,which
affiliation is given for ident.1fication purposes only.
The analysis in the draft does not seem to satisfy NEPA.
I would hope that bhese mattprs are addressed in the final ES.
Sincerely,
y..;i.l.:.....a.~
':!m.A.Lochstet
~,--,L-~__¥J
p
'"
An Analysis of the Pro~osed
"~ite ~lesa UraniuT,Project
by
William A.Lochstet
The Pennsylvania State University*
February 1979
The Nuclear Regulatory Commission has attempted to evaluate
the environmental impact of the proposed ~~ite Mesa Uranium
Project (Ref.1).The long term radiological effects are
dismisaed by eatimating that the radon emissions from the mill
tailings ,dll be twice background.Erosion of the abandoned
tailings ia to be minimieed.These effor's will be examined
here.
In 1976,Pohl (Ref.2)pointed out that the thorium-2JO
in mill t~ilings decays to radium-226,which in turn decays to
radon-222 with a time scale determined by the 8 x 104 year half
life of thorium-2JO.Recently,Kepford (aef.J)has sr.own
that the uranium-2J8 in the mill tailings and in the uranium
enrichment tailings,of the gaseous diffusion olants,decays
by several steps thru thorium-2JO to radon-222,and should
be considered.This process operates on a ti~e scale dete~ined
by the 4.5 x 109 year half life of urani·~-2J8.These matters
*The opinions and calculations oresentedhere are m~o\~.and
not necessarily those of The Penns';lva:lla SMte l'niv~rsitl'.
1·:y affiliation is given here for :.~e"t1ficiltion ,-urposes only.
,-/-:~~:~>~;
RESPONSES
The staff has chosen to Iimit its radiological assessment to an evaluation of the dose
to the population within an BO-km radius of the plant integrated over a 50-year period
from one year of exposure for the following reasons:
1.The radon dose cOl\1llitment becomes a very small fraction of the natural background
dose beyond BO km.Table 4.7 of this document shows that the bronchial epithelium
population dose within BO km (132 man-remS per year)is only ",0.25%of the
bronchial epithelium population dose from natural background (23,000 man-rems per
year).
2.The calculation of the maximum annual dose from one year of exposure integrated
over 50 years provide a realistic estimate than can easily be compared to
applicable standards and regulations.The staff does not feel that it is
realistic or meaningful to consider effects on a time scale of 4.5 x 109 years
as proposed by the commentor.It should be noted that the 3.2 x lOB deaths
estimated by the commentor over 4.5 billion years is only 0.026 statistical
premature deaths per year.
Also,because the depleted uranium tails from the enrichment process are not
necessarily waste and it is a NEPA goal to attain maximum use of depletable
resources,we would consider the enrichment tails as a resource.If,however,
they are to be considered as waste,the staff believes the reduction factor
for radon of 200 to be unrealistic.In fact,we would assign a zero increase
of radon above that naturally occurring if the depleted enrichment tails were
buried at a depth and erosional enviroMlent similar to that of their fonner
place of natural deposit.Without the enrichment tails,the 5.3 x 107 deaths
estimated by the cOlllllentor over 4.5 billion years is only O.OIll statistical
premature deaths per year.
The Dakota Sandstone underlying the tail ings impoundments is about 70 million
years old.The staff considers it unlikely that it will erode away in the
foreseeable future.
Recent public hearings before the Atomic Safety and licensing Board to consider
the question of the proper assessment of the impact of radon releases from the
nuclear fuel cycle and health effects that can reasonably be assumed associated
therewith have supported the staff's position.
We believe that to attempt to fix absolute figures for health impacts
over hundereds of thousands of years,as Dr.Pohl did,represents
pure speculation ..•Our "rule of reason"then,would be to look at
absolute figures only for those periods for which reasonable estimates
can be made ...and to accept the notion that effects beyond that
time can be adequately quantified by noting that they are "immeasurably
small"compared to natural backgrounds.
IiThe July 24.197B,Partial Initial Decision of the Atomic Safety and Licensing
Board Authorizing Limited Work Authorization,Black Fox Station,Units 1 and 2.
p,..N
~&;'~~..,
·..,-;."c.::J,'t.,:~..,:~,,_.
'T'he act.ual calculat.ion (,!p.f.1,P.~'-)i"~~lllts ~n ~.I!'I Il]:nifision
rat.e of 1.1,rGi/,,:~::;ec in 'n .~:"ea .,,:~....~~-.>.~b,:lck~rr"oun'!rat.e i~
have been addressed by Dr.R.I..Gotchy of \.h"NJC Staff (Ref.4).
These arguements will be considered in the case of the
"'hite Mesa Uranium Project.
The ~~ite Mesa mill is expedted ~o oroduce 7.3 x l05kg of
U30S per year which for 15 years of operation would ymeld
a total of 1.1 x l07kg (Ref.I,p.3-1).Of this total,
9.3 x l06kg would be uranium metal.This is the material shipped
away from the mill for isotopic enrichment.The millis
expected to operate at a 94~recovery rate for uranium (Ref.l,
P.)-1).In this case a total of 9.9 x lO~g of uranium will
be contained in the ore supplied to the mil~.Of this,
5.9 x l05kg of uranium will remain in the mill tailin~s.
With an extraction efficiency of 95%for thorium,(Ref.I,p.3-11)
these mill tailings will also contain 161 kg of thoriurn-230,
which remains from the total that WaS in secular equilibrium
~~th the uranium-23S in the ore.Of the uranium shioped a.my,
7.4 x lO~g will remain as tailings (depleted uranium)from the
enrichment process.
The ultimate decay of the 5.9 x lo5kg of uranh,,"in the
!lIill tails will produce a total of 13.5 X l013c'JrieS of
radon-222.The decay of the 161 kg o!thorium-210 .dll yield
2.4 x 1010 curies of ~radon-222.The decay of th~7.4 x lo6kg
of depleted uranium from the enrichment rroccss will result in
1.1 x l015cnries of radon-222.
The tlRC ~oal i'l t.o reduce radom ~:ni~5ions to t.·.ice back~roun,l.
fI>~
RESPONSES
"__---'-------J ~~~:=J
.•.we believe that we have an obligation to assess the effects of
today's actions on future generations.We certainly must consider
any known effects on our immediate successors as of importance com-
parable to effects on those now living.When it comes to balancing
adverse impacts to those descendants who may follow a mi 11 ion years
from now against the benefits to the present gener·ation.we would
weight benefits to the present population.The benefits are
certain -the impacts hypothetical.The action presently proposed
is not one that presents a serious risk to any future generation.*
This evaluation is supported by the draft Generic Environmental Impact Statement
on Uranium Milling.NUREG-05ll.April 1979.Specifically,refer to Table 5 in
the Summary of that document.entitled "Comparison of Continuous Releases of
Radon from Uranium Mill Tailings with Other Continuous Radon Releases."
---~;~~ulJ 14.1978.Partial Initial Decision of the Atomic Safety and Licensing
Board.Perkins Nuclear Station.Units 1.2.and 3.
L ~
2;·.:hite Mesa
will it before the entire mE'''''erod""a:':ay.To n'/prage OVpr
~..""
'''''~i~:M~t,~..~..."~~''C'",,",,·,,
'-'"""!,:.'~a.:-r..;;'!"':':'~'-".'.'.1.'•.••-
..·:"".l~"=f=.~...
t"o-c;1J
.;:,~~;!_~:!-,>:~~"·:·-,~·~n~.i).:)·
~::J3[:':~t::::J
•'hite I~esa 3
0.64 pCi/m2sec.The difference of 0.76 pCl/m2sec is the excess
expected due to the tailings.The area is taken as that of
6 cells of 28 ha each (Ref.I,p.10-9)I,~th a t~tal area of
1.68 x 106m2•This results in an emission rate of 1.3 x 10-6Ci/sec,
or 40 Ci/year.Considering the ratio of thorium to thorium in
the tailings and the half livea involved,this reaults in a total
of 1.6 x 1010Ci of radon released to the air,primarily from
the decay aT uranium-238.This of course assumes that'the
eoil cover remains intact for a period of time longer than
the 4.5 x 109 year halt life of uranium-238.This is not likely.
At present,some recent dry mill tailings piles have two
feet of dirt covering.In this case the EPA estimate is that
1/20 of the radon escapes to the air (Ref.5).The proposed
stabilization will have more than this covering.The downseream
slope of the ~final,southernmost eike is proposed to be
6:1(Ref.I,p.10-9).This will not sto~erosion.The only
ouestion is how long it will be before erosion cuts into the
tailings volume.The effects of erosion must be considered
over a time span measured by the half life of uranium-238.
On this geologic time a scale it is clFar thAt tm entire mesa
will erode away.The proposed site is bounded on the west by
westwater creek where the surfsce droDs away as much as
240 feet in 1/4 mile.Directly east of tr.~site,.tm surface
drape away into corral creek as much as 120 feet in 1/4 to 1/8
of s mile.The difference in releif ~~~r.Gott?nWDOc Canyon
is un to 750 feet (lief.'I,r.2-36).'["e oU<!!Jtion is ho"long
··--"kd
'.~~i'!V..1'-~;';·,.t-;;'..:.i.~!,,~~~.!~};b·~-_'";~~ti·.,~v,
is necessar;to determine tha I'opulatio'l ;,t risk.The nOllulat.ion
:r
t;;
..----,~~---1 ~---':"'77"l;-:';:~~--'~.....-.~.J:.::..::-:.~r.:'.'--:"'::':':.:~~.':~~''-':-:-''-~.~;';'/:::!::::t:.c:::-e.m-.
4
..~r_"'.-".'c'_~'''M,.."",>t.-:',:o-.7l.~~_~".:
At present there is no clear DIan for the disposal of
the depleted uranium from the isotopic enrichment process.
considered here ia that of the ""t.tr':'.!.3.,.alan!1;\'li~h sa:ne of
To estimate the health consequences of these releases,it
piles is recognized by the NRC staff (Ret.4,P.4),bu.t not
discussed in the EIS (Ref.1).It should be noted that thia
At present such material is located in the eaatern part of
the country.It is assumed that it Will be buried near its
present location at some shallow depth.A reduction factor of
1/200 is used here to account for the wetter condition of
the at soil.ThUS,of the 1.1 x 1015Ci of an produced by
the decay of the enrichmant tails,it is astimated that
5.3 x 1012Ci escape to the atmosphere.
situation could be mitisated it the mill extracted more at the
uranium and thorium,or it the tailinss were located elsewhere.
It should be noted that trucks will be returning from the ,
mill or ore bUying station to the mines in an empty state.
These trucks could carry tailings with little additional
effort.
the effects of erosion over long periods of time and possible
re-burial it will be assumed that 1/20 of the radon produced
in the mill tailings escapes to the atmosphere.It should be
noted that this figure represents an average over time and
locations.Deteriorilation ot the stabilization of mill tails
!"hite Mesa
the rest of the northern hemisphere.Since it is not possi'le
to predict the U.S.population thousands of years into t~
future,the present population with its present .spatial
distribution will be used as a Cirst estimate.The NRC Staff
haa already done thia,asauming a U.S.population of
)00 million (Ref.~.P.)),with th.re.ult that the release
at one curte at radon-222 trom a typical pile z will reault
in a total ot 0.56 person-r..to the bronchial epithelium,
tor the total population.The total dOle.which result are
shown in Ta~le 1.It should be noted that 10 CPR Part 50,
Appendix I presente a guideline ot •1000 p~r total body
peraon-rem.If this were applied to tie bronchial epithelium,
the NRC estimate of 1.6 x 1010Ci released would result in
6.7 xl09 p~raon-rem tor A cash estimate of $6700 billion.
The NRC eatimate of cancer .risk ia 22.2 deaths per
million peraon-rem to the bronchial epithelium (Ref.4,P.?),
and is taken from ~ASH-1400 and Gesmo.Even though this
estiaate is too low,it will be used here.The reSUlts,
shown in TAble I,are that the thorium in the mill tails will
cause.about 15,000 deaths,while the uranium therein will
result in 5)million [e-mail] depleted uranium .fill result
in 66 million dead.Even the NRC estimate of radon releases
will result in 19~.000 dead.
These deaths will be accumulated over a very longtime
period.The estimate is probauly incorrect due tn an
unri"r"9timation of pO'llul'tion.Thora c£'rt:':nly ,·,il 1 be hc:\l~:,
"'hite ~'esa 5
{"..
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'l"~
".'.,k.;.•..;,.:.::,--!:.*1'ii);;"~':c,·,-'>.;;ci:d:i.\~-K-·~'··.'t>·'-':l·~,~
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6
._-...:-_,·..·--"v".c-.,.._·',;·,..,..,:.-~',::.::·."-'~1.-.:ct.1""..;·,.':"'....:.·
Ths comparison of these health impacts to background is
We conclude,then that Section 102 of NEPA mandates a
particular sort of careful and informerl decision -making
Drocess and crestes .1uoicis11v ,,~.forcable out.ies •••••
But if tl)e deciAi"n was reachpil r.roc~dur'l11y "ithout
individll'lJ iz.,.;c.m'!i<!'!Nltlon and oalc.lIcinR of pn';ironmentJl
facl":orF···Conrluct.erl fully "nrl in ',:",rl f":'th__ir is "he
r~:~non'ibility of t~c court'l~:~~verse.
~'hite Mesa
time period used here is required by footnote
USNRC,547 F.2nd 6))(D.C.Cir.1976),which states in part:
We note at the outset that this standard is misleading
because the toxic life of the wastes under discussion
tar exceeds the life of the plant being licensed.The
environmental effects to be considered are those flowing
from reprocessing and passive storage for the full
detoxification period.
consequences for many years into the future.There is no basis
for an arbitrary cutoff at any point in time.In fact the long
totally irrelevant,and contrary to the National Environmental
Policy Act of k 1969 (NEPA).To carry out a proper cost -benefit
analysis,the tptal costs must be considered,regardless of
whether or ~ot ~t might be possible to ststistically detect
or measure,thellll.NEPA does not require an environmental
asseasment of background.It does require an assessment of
the activity in question.In this trcy a proper cost -benefit
snalysis will be performed.In particular,in Calvert Cliffs
Coordinating Committee v.USAEC,449 F.2nd 1109 (D.C.Cir.,
1971)the court state.:
It is felt that this statement takes precident over statments
ot the Atomic Safety and Licensinr,Boards in the Perkins
and Black Fox cases.
It is hoped that these iseues are addressed in the final
envirOnMental statement.
without ruling out coets procedurally.There ie no b8sis tor
an arbitrary cutoff in time or in distance from the facility.
t..0>
7
the analysis be conducted honestly
l:hite 'le68
Thue it is reouired that
_.__Je2~t~!'f>:,::~:~;;•.___.r~·.;1 ~'~.;;..•;..-,~.,~·.t._
~~~~~F~7.~"ft-:.:~~=-::··.··~·­
..::.!r~""~....:_'.:':'::::::.~.~."y':';.·~7..::..:;.:.=..=:.;::~=..:.:.~=•..=..·~~=:':..
·!life I.'esa 8
Dose Commitments to Humans due to ~hite ~esa Mill
Table 1
origin of Radon Reduction Population
Radon generated Factor DO,se DeathllCuriesBronchial
Epithelium
Perllon-rem
Thorium in 2.4 x 1010 6.7 x 10820 15,000muTails
Urani\DI in 8.5 x 1013 20 2.4 x 1012 5.3 x 107
Mill Tails
'\"..
UraniUIII in
..,
Enriclullent 1.1 x 1015 200 3.0 x 1012 6.6 x 107
Ta11s
'~ill Tailll
NRC 1.6 x 1010 none 8.7 x 109 1.9 x 105
Estimate
~_h ••••••_n IIJ~:=;_~_.!!.:7:.2"L?,"',..,:,'1st j=;C--:;~~Ji";::(::;:~-·~i--l:.~J----l
2 R.O.Pohl,"Health EfCedtll 01'Radon-222 from UranillDl
Hining",Search,l (5),345 -350 (August 1976)
5 "Environmental Analysis ot the UranillDl Fuel Cycle.Part I _
Fuel Supply"BPA-520/9-73-003-B,U.S.Enviroa~ental
Protection Agency,(October 1973).
1 Draft Environmental Statement rela"ed to operation of
\l.'hite Mella UranillDl Project,Energy Fuels Iluclear.Inc.,
HURBG-0494,Docket No.40-8681,u.s.Nuclear Regulatory
Commieeion,December 1978
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9
ReCerences
ACCidavit 01'R.L.Gotchy,NRC Staft,"Ippendix",
"Radiological Impact 01'Radon-222 Releases",U.S.NRC,
in the matter ot Three Mile Island Unit 2 ( Docket
I 50 -320),(January 20,1978).
"'hite Mesa
3 Tellti~ony ot Dr.Chauncey R.KerCord,"Health Effects
Comparison tor Coal and Nuclear Power"in the matter of
Three Mile Island Unit 2 (Docket I 50 -320)operating
license hearings end portions.of trens~ript related.
in which the NRC start supports Kepford's numbers.
4
·=:~e.-:;!'-,'.~..".,:-~'c.\~_~,~,.;:;){'\-:1:t'!".,~.
;,'!i::~,~~.~.r~,·,,~::';r~
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OJ ~ItIS()..~~~(~
~<-r.£rt1'4Ovg'21 u
{'
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L~r~---'L J
The issues of nuclear power plant waste disposal and alternative er,ergy sources
are beyond the scope of this document.
RESPONSES
An ongoing radiological environmental monitoring program will be conducted to
assure compliance with EPA "5 "Radiation Protection Standards for Norma1
Operations of the Uranium Fuel Cycle"(40 CFR Part 190).Those standards
limit radiation dose commitments to individuals to no more than 25 millirems
per year,which is approximately 161 of natural background radiation (161 milli-
rems per year;see Sect.2.10).
1.The.radiological impact evaluation has fully addressed the radioactivity sources
constituted by airborne transport of ore.yellow cake.and tailings dusts.These
sources are addressed and quantified in Sect.3.2.4 (see Table 3.3),and their
impacts are evaluated in Sect.4.7.The staff evaluation indicates that the
White Mesa Uranium Mill and its tailings impoundment system will not result in
offsHe radioactivity concentrations or radiation exposures in excess of Federal
limitations.Resulting exposures at the city of Blanding have been estimated and
are provided in Table 4.6.
,..--L__.~
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~frMn.r-0..~tfjr:l.'W/..u-20~.
so.r:~!t{j~SUJ;:;L ~-~,!a.~sr/~1 a.-.~fh ff ro.JJ.oadr'udJi ~*wn VXJf-~tU-..uJ ??(/
,-..J JIo.hw.t ~Al(,bY '/4 "~~"~~J;..w4J".CJt;t()~tVe k .~~:Iv -'f.~?.;M ~,~rL,a.--.-vL
.~tV ;mrrniJcA 0-~~<;(.r:.mtotM cd~CAst""(8UPtt.~hfl;'It.
Sjffi dJ ~).&-.1/It-tr.iJ.Lu.-Cf/'11c;.r.ll1 ;s /J'UJ 14Fhdlt7;tiL mm r-d,rftnI>d r-~
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"':C"~1T\;i~"S:~__.~.....
Responses were not necessary for the following letters from cities,schools,andotherorganizedgroups..
...,
'"~,
Ill••c'_ l ...l ..et ....IIt..._ret II,ebe ,1..t ......tructi.n•
••-.c._l....'_......ctl••",n l t ..n ......1I,••eh.Cn,
--
:-
F·~F~'-"-"":.'"-,,jF~"""lI~~.~;;
;'~~~:1:Y.\~'::~;~':
f.bruary ).1.91Q
rP-"~'r1~~8:"""'1
-2-
rTI
Slneerel,.
fDN:..Jn
cc:Covernor of Utah
Con.r•••lonal I.pre••ntltI v••
/'/.'I.",,~......4 •."~..,......~c::
DeL";.,.Cl bbon••".U.
".yor
culinary water ....ppl,end dlatrlbuUon ayuem.However,the cloa.
relatlon.hlp with [nera'fuel•••n....lent ha.enabled u.to plan and
prepare adequa.el,for that l.-paet.It I.our und.,.uMndlua th••the
plant conetruelion ltNlable I.00'1 larlel,In the lland.01 the "uel.ar
Ite.ul'lor,CO_••••on.w.re.p_ctfuU,ur8_pro.pl and flvur.ble Ilttlon
on the _II I lIean••eo that the '-stl...nllna 01 our pllnl may be expedlted
can".tellli w.th antlc'pated econoe'c arovth.
Unlt.d Stat••fhlc..r Iteaul.tory Co_l••lon
F"--"'l
~.,;I
(:'.
~L ..__."Jjr"-'''''~..:"1d-;_':·.··:i~tY
•,.,~c.'"i~-<:"'~~-~;_.;,;-,:~~fu.~.t.;:-:.
r~~'<"'1
City at Blanding
110WEST 1ST SOUltlSllIUT
POST0FF1C£BOX 1I8
IILANDIHG.UTAt<Nan
''''.7.-27111
,......,1.tt19
r_"'~J
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~-?-~
....I.ct'".........t.U.....1 tb.eltla•••,tb.Cll,.,lI_l Ut....ebe CU,eo..acH _ ,...._tb ..t '.nh __u
nl.U ta e'"Dnll ....l••_tel leet_llt ••tbe ...ll U••l...
.....J e _..-I••4_l....t .......,'_l._1•••lac•
Un.ted Stetee .cl....
a.lulatory eo-t••'0.1915 laat.ra .._.
11l.........l ...._,l_
Au_tl......10..Ic._
Cletltl_.
....l eh.,1 ,"'H , , 1 n,.d...l..~Ii_••l _ell1 .tII4l••_pr l..tbe .
_lic.U.......prl_,l4••tl..........t'"l..oct t'".HI.,...tl••_lac _c._I._.e _ ,cU•••HI ......
•••_l _lcl,.l lce..III ......4....1 _,.••U _.11-
l•••l."l'..ell ClNp ,_._e."'lc"_I ..l "'''t".e'Ile l..ecU _....-Clle Cle,_le._.lc...Ha .e 4l..
•""lwe..
.l••tM 4 _,.1 U••l_V l.....l•••••l.the
....l.elle 1••It l ,1.,l••UlcMe 1.l.eh.l.eel .....,.t __••1 •_ht 10.....l.
er••1M --..e ..ec_t '••1'•.Me"•'.pre••lo•...e.....ua .,,Ie n.Ii...._II.,lIC,,,,n,tell""'l...
...,l '.U•••11&I'_l.._I_l"••Ut.....l.c.t".'tl _,.,_dU_.....,...........cU _"-,.,,.Jell.4 I.'l.._.....••••1Ia.Clle "ne U_._,.1 our _,1 w ••
pr••_.I,Ie.ceol te I ,be •••I••••l.'lICta.,.,l._.t .....
Clle .".rc..n,te _ "...Je'".n..l.ta t"'''e.'_te.
1P"""'""""'1k.:,
,,'~,:.:<.:'
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.''':'~~£~.i·~'Y_~_··"di:;_::~'~-
A'ter .t ln'the anvlr_tal Uat_1 and ellendlng a Fubllc ..etlng
..Id by (rIY Fuels lucl..,.Inc••_the City 0'Monticello,_Id like
to 10 on record ,Ivlng e.."ovel for tile above .....d project.
,...t1.....
I-I
:-
_..-ca...,.....
FebrUilry 7.1919
PO\lOt"{r801l"!19
MonllleUO.Ulah Soh);
S;HI JULlII School Djj!~icl
Our Air.Scera_:
U.S.Nuelear Regul.lory Co_Inion
7915 E..lern Av..ue
SlIveraprlngs,Meryl.nd 20910
ATTENTION:Air.Ross SClIra_
RDL:cc
The San Juan Board of Educallon Is wrillng In supporl of Ihe applic.lion
of Energy Fuels Nuel..r.Inc.for a source ",",Ierl..ls license wllh respecl
to Its proposed utanl....11 10 be located .pproxl....lely six miles soulh of
Blanding.Uleh.
The S.n Juan School Dislrlcl Is concerned aboul lhe socio"economlc impecls
of _rgy develo~tin our counlY.The proposed energy developmenl
progr•••111 add slgnlflcanlly 10 our counly lax b.se and will creale an
eUrKtlve Job _rket for our high school and college graduales.
The benefll.of the propoSed ..ergy program are signlflcanl.
For the ebove reasons .e respectfully urge lhel this license be I..ued in
lhe shorlesl 11_possible.
Sincerely.I!u~~~
San Juan Board of Educallon
---
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~:.\\oIl;.ll.,..:'0.II,,;,'111'1.""".-l:,1
j ,\.,h II~E.LLv,I,.T.\"U:tJ;.
February 5.1'1'
•.,,..~u.,·~:.J..'
",.:",'~..-':l:.!.~~<I;'_""',..t;~'-::--':';"'c,'.~'~·~'~;:·,~;;,
C!lTY OF 1tIO~'j'ICJ::LLD»
•~~~'.?'~ICE~LO,.._~'---'
oYKer i:~'"',.••L'o("
lIIIyo,
····10
ae,WIIlte .....Uranl..Project -Dodcal '.0-8681
Sincere'y.
Director
IlvhlOll of Fuel Cycle .""IIIIle,lel Ia'ely
U.S.lucie..".ulalo,y (_hal..
......lll.tOll.I.C.20555
,.;Iv.(.'_\
.,\11IoM....,.
,.~i....I nULf.,
.',:.\11::,;-
•I."~••1 .;.r.li.
.\I\'PU
.....1'..U R~JrJ
......j"~...:.'.
j'U'j
•.loJl·.'.:L~.It..'
~~8m oJ.-canter foe ~Mucatial
~~tt~Vocational &paci.Uat
8m .llYn Qult:y ..10catad in a -._at tt.IlcutI-r.emUl1tad sute..
..~ly ~_11M .-y ,.,~trt..'ftw IIQIl:hun third of u..
0lU\ty,tHdl-u.....ly balf tt.~,11M an en-ly high d'I8II'Wy-
.-It _~nte (52\1 with ~15&of tt.~W-boa -.iv-1IIlI a Mluy of '5,GOO Cl&'_.
'ftw ..~of a ...ani..~_11 at NUta __on u..wry
..at --um land,~ua potaItlal fix ...,~t.tW:b haa ~
.u..ly .....-liable.IlhaI1JY PlaLa IlIclaar haa lant ita ~and 11M....inwlwd in the ~tat bllll9Ja1 t.rain1ng __Uola Wlidl ..ill
enIbla billl9Ja1 ...,.jo IIIlIlta to cpoUfy b ...,~t intt.II1ninlJ ~try.Ia ..........75&at tt.15 WlldroKa mqu1rad to .,.....ta tt.10111
~_CIa.tt.I.oaal jail adoat ....u ..a aua.t.IIItW ~at -...bM1c _:Id-.tt......tiaI af the 10111 np-.a ai'Jl'1fl-*Cll:IIIUibt-
tJaa tD tt.-.11 -awof tt.ClIUIq.
.........,eUota tt.CIllIll:ribut1o a-w Plaia 11M .u-ty to our QCBUt-
~t¥--IlIIPR tt.1&"effmta 111 ~tt.lllita Unn10a Nl.11.
...
.n
L~
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[;~::~::Jc,:~::;]
'~n·~~~,_~-:
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February S.1979
m:.::m
DE:.AN M McDONAUJ "Ht.~Ul16.
ClII............1IU
i;::.~~,lij,_;.<:~':~:l~":r'.
C:~jc::::]
lleer Sir:
Itha.baan brouaht tt>.y att.ntloo that you are currently recetvtnl
pUblic:C~Dta on theaovlron"Olal draft for the White He••Ur.ntua Project
p...po....II,....r.''"111.luci.er.I..e .
The uraalua .111 propo."by Itneray ru.l.Nucla.l'.In .0UI'optoton•
caD IDd..d ....v••_rkeel favol'.b•••ffact 00 the r••ldente of Sao Juan County.
lu-.d•••eM a....aa at p.......t virtually d.void of _Jar Induatl'y.the
uc.ltl1a-..ot of auclt a alii would be ab'a to atiaalat.the acoo.-y tn a poalr:.lva
__...I ,...a.a11,uri.JOur favorabla con.aderatloa of thatr draft at.teMnt ..
-~-Sloe.raly your••~'~-'~'~.lJuJ7t1 ?t1IlJ~~«/f -...~-1>'lie ",I!cDoneid.-p'.r,;-.-0'~W...._:.~~f"\~~'::.0 ..,,....."\~.-...,.....,.
COLLEGE OF EASTERN UTAH.PRICE.UTAH I~MlI.(101;631-2'20
b:lo.rlY ruel.Nucl.ar
lith.lie..ProJ.e•
Dock••110.408681
!be ColI.,.of E.at.rn Uteh haa been involved In the Ilandini.San
Juan Couaty.Uta"••1'•••toea 1916..Althoulh .-oat of our eUort.have b~.n In
eM prof•••toaal pr.,arattoa of blUaaual/btcultur.l t.acher.aad t.achllr aid•••
...........a c....c.eo ab••na tbe davalo,..at of ....r.y-r.l.t.d Induatr,In
tbe a.....
Director.Dlvl.loo of Fuel Cycl.aDd Kat.r.al Safety
U.S.IIICLIll lIcUUTOU CINIISSIOll
....bi....oa.DC 20~~~
r.-::J
.Lt::..
f:~:J
'/',::i.,'\....'-1 .:.:;.~\·ft -_...';'!J':~'..r t •.::'.••"J V'I,_lo:.~·-,\~'.:~"~:':!1EJ~~
~~
1'GuKy~,U79
;"~:::'<;.;";'cf;~.~'::i.'t":~':-':*~i!:f1['_~;i~·'"'.'-';-'<-':,'A
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._~:.:_·c .'~":\.;:::WiA:";~
~':]
PO.BOX 383 •BlANDING.UTAH-.511 •(8011878-2370
AfFlLlATEOf'COLLEGEOf'EASTERNUTAH •DEANY,McOONAlD.PRESIDENT
Uo'.JJVftt
D1nct«,Dlvt.laI at PIal ~_1IItMiala.'-ty
U.II ~~C)wN_'m
.....•,D.C.~
DIu'a1z.
I '--u.d a dl'att CXlW of tt.~tal5u_t ~Latad to tt.
!rEtialat Illite .....u~~~la....~Inc••aid dl~dii PI\iliiI*II iID tiltlira.aa..-r iiIIt m.to ~t.
SAN JUAN CENTEI fOR
HIGHE.EDUCATION
LlI""lM,OIr_
IX
~
,-~,~".ii.';~:""
[8I::17;;"]
"Sf~-E.",
'!U CHUKCI :,'1
Ir'~:.'c cl·n~~\'::­l'UllW-'.
S/\I~:r :.
llANOIHuutAH IIAM........"'"".....r•.7,1979
United Stat..a&claar ....toI7 ea-t..SDII7915"t_l_
Il1wwepri1lp.1laq1allll »PIO
itia........-..-
Dear"'.
le lIIIt.aU_01 tile QIurda 01 .._llbriat ot taU.....lIq 8e1Dt.a,
_...-tUill 1D 8UIJIIiu't 01 Ule ...,uceUoa 01 1lIoor..lIaBla a&claarI
IDa.tor a 8auI'ee ...t......U_lllUl ....,.et.to ita propoaed
.....w.8U1 to 1lIl located ~t"eb aUM _UI ot Banl11JlI,UI.ah.
Quo dalP'cb 1a a pr1aIaq 1Dtlu_e 1A Ule eoc1et,r ot t.he _th..etem
pen or Ut.aIa Uleret '1a ~abaut.Ule BOcioe_c bipect.e
or -..~t.or our ..-en ....lIIp1qreel,either dlreclJ,
or 1iad1.nat.~.1D tile _'e ..uSDI ~tq.ae inllaell7 i.ca.pr1eeel
or __h'.to'......llIIoH ..cc...1e dependenl upoa bard IIDrl<
MIl •~Mi'II&tor II1a ore.~..fIaela IIu proYldad ~cb a .......t
~Ule ....t.t.lID ,.......lIIe propo....JlI'OII'-wUl r-rov1de eUraclhe
joIl ....t.tor our bi.ecboo1 and oo11..e araduatea.
lie nepaoU\a1J,J v ..tile,Wa 11ce"aa be ie..eel 1A the aharleet
u..poae1bla.
11DcareJ,r...1..-jJ"J/.l;.'I...~C.-¥.,.Y':...-4."fJ
PneSdant Prect 1le111_·.;I
I
Peb.ua.y 7.1979
DirectorDivi.ion of Puel Cycleand"aterial SafetyU.B.Nuclea.Regulatory Co..i••ion
...hington,D.C.20555
...Ine'9Y Puel.White "esa U.aniu.Mill
7IIe under.igned a.a repre.entattve of the Navaho Indtan
~rtbe in Southeaatern Utah wi.he.to advise you that we .uppo.t
the Inergy Puel.White Me.a U.antue Mill project.This projectw111p.ovtde needed job.to the Nevaho Indiens and should have
e beneficial econo.ic iepact on the Tribe as e whole.A nu-oe.of ou.Trtbe are already e.ployed tn the Ener9Y Puels Buyin9Btetionand.ine.in the area of the Mtll.Approval of lhis
projact at the ea.lteat poa.tble ti.e will no doubt open
job.during the con.truction and operation phases of thts
project•
~_&L._-~tf'-~-------aho Ind~iibe
f Reservation eha ler P.esident
~
._):'r.~:X:y~-j/;
Re:Energy Fuels White Mesa Uranium Hill
.6 ~\'f'~I ~.Lfj~-r;..:ul'--"-_Coun~n .~
White " a Ute Tribe
.~~
::-U>....
:_:~:::~;~
l;;lY'f~
Monticello Chamber of CODlDerce
Jim Camberlango.Pres.
Brent Redd,Vice Pres.
~tf4
The Monticello Chamber of COl1llJerce would like to go on
record as g1ving unanimous support for the above named
project.We pledge our co-operation,support and en-
couragement to Energy Fuels Nuclear,Inc.1n their venture.
Re:White Mesa Uranium Project -Docket #40-8681
February 5.1919
Director
Division of Fuel Cycle and Material
U.S.Nuclear Regulatory Corunission
Washington.D.C.20555
Gentlemen:
cr:z:~]
MOy..,nweep
·_.:.~al
."Ii1o,",r,laJns
:'Aonum.ttnl
'J1;lIfty
l.oCJklngGla••
;tock
Vall.yo'
Iheooda
;,I-\Iural
:;,iQl)u~
,\It..lOIi-Wsat.cor...
,::anvonfanda
,.\batDIBlue'
~"ounlalns
Trallot
the Ancient.
.lainL'ow
.)rrd~lit
Navajo
.~o:t"tfrv.~tIIOfi
Goosenecksof
~he Soan ..Juan
Post G;tice Box 1105
~,'onticello.Utah 84525
:4:~.,:.H':11 '~C2flic
.:.?II !uan County,
J.<O"-O·11luar'l-,nlllt
.;om"ot••....
1._!·fap·;lWUU
·DeaaHa...
Pninl
r::._-,~'":~J[~~~:Jttd~
•'_:::""..~-':'.:-\.:·~~.~'_:_,·~~,~_i~·_,"~~..:!,:.~,':'5_6
[~:~:2]
February 7.1979
~;.:::~
_.-.:-"-.~--"~~F.!"'_""!!!!IS¥..._.:=:'''''''';C''''';'":'''''~''
.::;<'\;:.Q.g~;J.'.,.,:;;;"'''_'.
L_-";:;J
The White Mesa Ute Indian Tribe supports the construction
and operation of the proposed Energy Fuels Uranium Hill to be
located on White Mesa approximately five (5)miles north of the
Ute Reservation.The White Mesa project should be a benefit totheUteTribeinsofarastribememberswillbenefitfromthe
jobs created in the immediate area.The Tribe urges your
favorable consideration of the issuance of the source materiallicensefortheEnergyFuelsMill.Your earliest possible
action on the issuance of this license will permit the opening
of a substantial number of job opportunities to the Ute tribe
members.
Director
Division of Fuel Cycle
and Material Safety
u.S.Nuclear RegUlatory Commission
Washington.D.C.20555
[~~.~~~~~.~~~
'_.~__~·i··,'.l •
on';;;"."
>j
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j
of
on..i&
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._~"'M~'~'fI'''''.''«,:",=~1':1·••_r 7 TS.....aaa···:;..,"""".,."....,---.
l1li
.J
'l"'"..,
r:1,,3~./:~._-~./::~..r~.~~''''''"ll!'-!",,",~~",:,.;:,>jM k",:"":o~,,j,;;..41
.,'.SCE RiVERS'.'"H.JH ·~\r·~·::~.·._v.\l 5 lOll .FAt:~PHOIIIE NUMSEAS
~""1!\Il~_:i':":"<'~W
~-"'V 11\Mh
r=i::;~
MGMCU~P "G"
TOM REDO
18'0)EST
DIRECTOR OF THE DIVISION FUEL CYCLE
AND HATERIAL SAFETV
U.I.NUCLEAR REGULATORV COMMISSION
~ASHINGTON DC i0555
q-0~9a8ZEO)1 OZ/OZ/79 ICS IPMRNCZ CSP HSHB
101~7IZI)'HGH TORN BLANDING UT 100 02-02 0~03P EST
REFERENCE ENERGY FUELS WHITE MEIA URANIUM PROJECT SAN JUAN COUNTY UTAH
DOCKET NUMBER .0-1611
ENERGY FUELS HAl OPERATED A URANIUM ORE BUVING IT4TION 4ND HAS DON~EXTENSIVE EXPLORATION NEAR BLANDING UTAH FOR SOHE TI"~.THIS FIRM AND
THEIR EMPLOVEES HAVE BEEN VERY BENEFIC~4L TO OUN 4RE4 AND OUR ECONOHJ.NOW,THEV NEED TO BUILD AN ORE PROCESSING MILL TO UTILIZE THE ORE THEV
HAVE LOCATED IN THE GROUND.AND ALID TO PROCESS THE ORE THEY HAVE
PURCHAIED.I URGE yoU TO GRANT ENERGY FUELS THIS 4UTHORITV ON FEIiRUARY
5TH.
THE CITIZENS OF BLANDING UTAH ARE VERY CONCERNED ABOUT THE SAFE TV ANDTHEENVIRONMENTALIMPACTOFTHISMILL,SO HE ARE PLEASED TO KNO~THAT
THEIR DEalGN II MOAE THAN AOEQUATE TO CONTAIN T~E WASTE TAILINGS.A~DTHEPRODUCTIONE"MISSIONS•
OUA NATION NEEDS TO OEVELOP THESE SAFE USES OF URANIUM AS A MATTER OF
SURVIVAL,SO WE ARE FREEO 'RO"THE CRUSHl~G 8UROENS OF BUYING MOST OFOUAOILOVERSEAS.AND FROM THE LACK OF THE ENERGY wE NEED.HITH THISNUCLEARDEVELOPMENTAMERICACANOVERCOHE60THoUAINFLATIONANDSTAGNATIONPROBLEMS.
OUR LOCAL IAN JUAN COUNTY ECONOHV OESPARATELY NEEDS A LONG TERMEMPLOVERTOHELPSOLVEOURCRONICUNEMPLOVHENT.~HICH IS ONE OF THEWORaTINTHENATION.
PLEASE LET YOUR INTELLIGENCE ANO YOUR GOOD SE~SE OVERCOME THE"ANTI-NUCLEAR"AND "ANTI-DEVELOPMENT'RADICAL GROUPS AND APPROVE THIS
HILL.
YOURS TRULY,
H4S4~CH fIN4NCIAL CORP TR
Ii~.sl~~4NDING UT 8q511
t::-:::Jr:::~~~~;:J!F"'""'1~~;.,--,,;.~
./
C:;;]~~_..~.~~t'::;:;ZJ
hbr\lar7 a.1919
WASATCH
FINANCIAL COAl'
BOX 651 .IlLANOING,UTAH 84511
PHONE (101)671·_
I::~;~~t~::;]
JWJI/jj
001 Did.1an of ~1oal Jntorat1.aa &!loclaMz>t Controlo.s.Jua1eal'lap1&tlll7 e-.Wa.lIlnIt....D.C.20SSS
DIal'IJ1loI
I ..W'1tjq --.dDll tbe ~.ul at B1an4inI.Ot.ah.(.-0'
1M1a'll1t.••lIrud»a PI'OjNt....",...CDuDt7.IlllaDt 140-8681.)
I .....,.,.1IlIGb-in ~a"or of th18 JII'OjNt.I think it ~be a ".17.-s thinl ~or the ~of ~-'the people of SuI Juan CouDt7.
1Wr _1Mntlal 11111 be AllF"lated.
D1Notor
Di,,18la1 ~~&.taia1.W~o.S.IIIIa1Mr .,.ea..
~~.-D.C'-20SSS
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"'bruar1 4.1979
Director
D1viaion or ruela C1cla &Materiala S.ret1u.s.Nuclear Regulatory Comaia.ioll
"".hinlltoll.D.C.20555
Dear Sire,
Tbi.letter 15 in reference to Enero Fuels Nuclear Incorporated's
\/bite M...Project in San Juan Count1.Utab.It ia Docket Duabar40-8681.
I all var1 ,,",cb ill r...or or tbi.project .nd would like to Ne
it receiva your approval.I b....livad ill thi.are.aoat or .,
ur..I aa raiaillll a'1 ruil,bare.and aa operatinll a bunneaa•
I bave bad occa.aioll to a...ociate witb tba principala or EDero
Fuel.Nuclear Oil both a parao...l and businaaa lsvel.I bave.nj01ed tbia usociatioe.
I raal the .\/bita lie....Project will re.ult in a .ubstantial
acoeoaic iaprove_nt is th1a area.It will creata joba ror
local peopla and will·inject aone1 iDto tba local ecooOllY.ItwillieprovetbalocaltaxbaN.
I aleo raal tbe White He..Iroject i.nacauer1 on a nati.....l
leval .lao..It will do a...thiDII tovard reUavinll the preNnt
anarO .bort..a.
Allain.I urlle 10ur approval or thia project.Thank 10U ror',our Cooper.tion.
"garda.
Karl E.StueDs
BlandiJlg.Utab
r'"N
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1"'"..
Box117
MONTICELLO,UTAH84535
February 5,1979
ABAJO PETROLEUM,INC.
Hapf:J~MotOW1CJ9J,"<·.""'';;''·'"'.'.·j{j~~~~.l
Director
Division of Fuel Cycle and Material Safety
U.S.Nuclear RellUlatory COlIllIIission
Washillllton.D.C.20555
Re:White Mesa Ureni...Project _Docket '40-8681
Gentlemen:
It.8rent Redd
After studying the environmental statement and attending a public meet1ng
held by Energy Fuels Nuclear.Inc.,I.in my personal and business
capacity.would like to go on record glving approval for the above namedproject.
SK~<~
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fEB \0\\919 ~.}.
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Salt Lake CIty.Utah 84115
February 8,1979
t"';,."•.~
bi.....;t'"-J-.:r;/~
P.o.Box 15585
~""'..''lt~~.:.....:...d1Jb;:C:~:~
cc:Division of Technical Information Bnd Document Control
u..S.Nuclear Regulatory Commission
Waehington,D.C.20555
mj
We would like to voice our interest and deep concern that your commission
speedily passes the project for Energy Fuels so that San Juan County may
get on with the very intricate part of the development of energy for our
nation 8S well as economic development for the people of San Juan County.
'Ie feel this would be very instrumental in not only the economic
development in Sen Juan County but of the State of Utah and also in the
interest of ener81 development for our nation.
Please give every consideration to the passing of this and try not to
listen 80 intently to the chattering of BOIDe ot the special interest
people who try to destroy the economic developlent of our country.
Dear Sir:
~or~;lllps/~Pn/
B.JO~
ice-President
We have recently established a branch office at Blanding Utah and we
are very enthused about the prospects at economical development in San
Juan County.One of the highlights of this economical devalopment is
the uranium processing plant referred'to above which Energy Fuels
proposes to build at White Hesa.south of Blanding Utah.
We appreciate your consideration of tbis and any assistance you can give
to the eerly pessing of this project es it is our understanding that
Ellargy Fuele ie ready to begin construction in May llIId have went to a
great deal of expenee to line up ore and eetsblish a program to begin this
project in eerly !lily of this year•
Director
Division ruel Cycle and Materiel Sefety
U.S.Nuclear Regulatory Commission
Washington,D.C.20555
[::2:]
3445 South Main.Suite 112
JTN Insurance,Inc.
t.:.;.;]~~-:'..~LD;~~:~
February 7,1979
[;;~~~J
~""-::;~J-'~~/~:··d':-.,(-1'/(,,__<.;..-~~!~.~ucfl of Honticello,Utahrr'"i,./.~e;;p~
.;)ll)(i..:-0.£(~~i~.'"..~:/'{/.('-~.,.:tf.-;"V7'''~;,~~--.II
The Monticello City Council endorses and supports the
proposed Energy Puels Uranium Mill located approximately
five (5)miles south of Blanding,Utah.The impact of the
Mill construction and operation to Honticello as well as
San Juan County should be quite beneficial.Jobs will be
provided to a number of individuals many of which will no
doubt live in Honticello.A number of current employees
of Energy Fuels already reside in Honticello.
Although an increase in population of the City ofMonticelloasprojectedfromtheconstructionandoperation of
the proposed uranium mill,the City is planning expansions to
the utility systems and feels that it will be well able to take
care of the impact of any additional residents that m.y locateintheCity.we look forward to Energy Fuels'early commence-
ment of conatruction and ask that you favorably consider the
application for the source material license.
Re:Energy Puels White Mesa Uranium Mill
Gentlemen.
DirectorDivision of Fuel Cycle
and Material Safety
U.S.Nuclear Regulatory Co..issionWashington,D.C.20555
A-68
",~
,.
Appendix B
BASIS FOR NRC EVALUATION OF THE WHITE MESA MILL PROPOSAL
..,
j.:
B-3
Appendix B
BASIS FOR NRC EVALUATION OF THE WHITE MESA MILL PROPOSAL
B.1 THE NUCLEAR FUEL CYCLE
The nuclear fuel cycle comprises all the processes involved in the utilization of uranium as
a source of energy for the generation of electrical power.
The nuclear fuel cycle consists of several steps:
1.extraction -removing uranium ore from the ground.separating the uranium content from
the waste,and converting the uranium to a chemically stable oxide (nominally U30e);
2.cogversion or fluorination -changing the U30e to a fluoride (UF s)'which is a solid at
room temperature but becomes a gas at slightly elevated temperatures,prior to enrichment;
3.enrichment -concentrating the fissionable isotope (uranium-235)content of the uranium
from the 0.7%occurring in nature to the 2 to 4%required for use in reactors for power
generation;
4.fabrication -converting the enriched uranium fluoride to uranium dioxide (U02 ),forming
it into pellets,and encasing the pellets in tubes (rods)that are assembled into fuel
bundles for use in power generating reactors;
5.nuclear power generation -using the heat resulting from uranium and plutonium fission
to generate steam for use in the reactor turbines;
6.spent fuel reprocessing -chemical separation of fissionable and fertile values
(uranium-235,uranium-238,plutonium)from fission products (waste),with concurrent
separation of uranium from plutonium;and
7.waste management -storage of fission products,spent fuel,and low-level wastes in a
manner that is safe and of no threat to human health or the environment.
Step 6 (reprocessing,involving the recycling of plutonium),which had traditionally been
considered as an essential part of the nuclear fuel cycle,was recently deferred by the
National Energy Plan {NEP)l as a necessary part of the cycle.The U.S.commitment to advanced
nuclear technologies based on the use of plutonium recovered by the reproc~ssing of spent1ight-water-reactor (LWR)fuel has also been deferred.These policy statements enter into the
staff's evaluation of the need for licensing the White Mesa mill,because without repro-
cessing,all LWR fuel must be derived from the mining and milling of new U30e from projects
such as the White Mesa mill and the related uranium mines.
This cycle,as defined by current policy,is portrayed in Fig.B.l.
Nuclear reactor operation converts about 75~of the fissionable isotope (uranium-235)into
fission products.thereby liberating thermal energy and creating plutonium.another fissionable
element.in the process.Some plutonium is retained in the spent fuel.
The spent fuel removed from the reactor is stored at the reactor site (and later at the repro-
cessing plant.if policy changes)to "cool."The radioactivity of the fuel is reduced by a
factor of about 10 after 150 days storage.Without reprocessing.this spent fuel is considered
waste.Policies and methods regarding its storage and/or disposal are currently under study by
the DOE and NRC.
REA CTOft SITE
SPENT FUEL STORAGE
NUCLEAR
POWER
GENERATIONo
F"SHCO"~
///I
//SPENT
,,/CORE
//./././././
FUEL PREPARATION
AND
FABRICATION
/
/
/
/
///
//
/
/
ES-4694
WASTE STORAGE
OR
BURIAL
\\
\
\
\
\
\\
\\\\\
Fig.B.1.The LWR fuel cycle.
•AFR •Away From Reactor
--Steps InvolvillCj Uranium
Fuel (Fresh or Spent)
---Steps InvolvillCj Intermediate-level
arid Low-level RadiOlclive Wastes
Two types of reactors are currently used to generate essentially all of the nuclear energy sold
in the United States:the boiling-water reactor (BWR)and the pressurized-water reactor (PWR).
Each reactor type is operated with a fuel-management scheme designed to meet the requirementsoftheutilityoperator.Different fuel-management schemes result in different fuel burnuprateswhich.along with other design parameters.affect the quantity of residual fissionablematerials.the type and amount of radioactive wastes in the spent fuel.and the quantities of
nuclear fuel consumed.
B-4
B.2 USE OF NUCLEAR FUEL IN REACTORS
The need for uranium fuel.as dictated by the installation of 380 GWe of nuclear capacity
anticipated by the year 2000.is shown in Table B.1.A 1000-MWe reactor will require =30 MT
of uranium fuel per year at a plant-factor of 0.6-and =30 MT of uranium fuel for a plant factor
of 0.8.The tenn "plant factor"indicates the ratio of the average power load of an electric
power plant to its rated capacity.For a 3S enriched fuel and 0.25S enrichment tails assay.
7.9 times the metric tons of fuel replaced equals the standard tons of U308 required for a
1000-MWe power plant.The percentage of total e1ectr1.ca1 generating capacity over the same
time period that this schedule represents is shown in Table B.2.On the basis of recent state-
ments by the industry and the DOE.the staff believes that this schedule represents a maximum
for nuclear reactor installations between 1990 and 2000 but is reasonably accurate through 1990.2
Cumulative requirements through the year 2000 would be 883.000 MT of uranium as U308 (Table B.1).
Table B.3 compares this requirement with available uranium (reserves and probable resources)
for the year 2000 and the 30-year plant lifetimes of the 380 GWe projected for installation by
the year 2000.Requirements and resources are in reasonable ba1ance;3 that is.the sum of
reserves and probable resources is approximately equal to the lifetime requirements of the
380 GWe installed by 2000.
In 1977.23 mills produced about 12.000 MT of U308 while handling 32.000 MT of ore per day.
These mills operated at 80 to 85S of capacity.The U308 content of the ore was less than
1.5 kg/MT (3 1b/ton;<0.15S).4 Ores processed by the White-Mesa mill will have a U308 content
approximating this national average.
Table 8.2.Comperison of total and nucle.generati",capacity,operating in yean ~977-2000
Total generating Nuclear generating capacity (GWel
Year capacity (GWe'-Planned or under Nuclear,Nuclear,
Minimum Maximum Actual construction Estimated minimumc_maximumc_
(%1 (%1
1978 507 507 49 12 12 .,.
I
1980 544 627 84 16 14 •1985 624 840 127 20 15.
1990 734 1131 195 26 17 i:,t;
1996 869 1525 280 32 18
2000 1039 2092 380 36 18
·From "Electric Utilities Study"by TRW for ERDA,Contract E(49-1l.3885,pp.1-19,et seq.
Maximum case is 7.0%compounded annual growth through 1985,then 6.4%to 2000.Minimum c_is
3.9%through 1985,then 3.5%to 2000.
B-6
REFERENCES FOR APPENDIX B
808,000
1.180.000
2,000,000
At $50/1b"
Resource availability
626,000
921,000
1,550,000
At $301lb"
883,000
2,051,000
Reactor demandTimeperiod
Through year 2000
For 30·year lifetime of 380 GWe
Reservesd
Probable resources
Sum of reserves and probable resources
'To convert to short tons multiply by 1.1.
bBased on information presented by U.S.Energy Research and Development Administration (now U.S.
Department of Energy)at the Uranium Industry Seminar,Grand Junction.Colorado.October 1977.and in
"ERDA Makes Estimate of Higher Cost Uranium Resources,"U.S.Energy Research and Development
Administration,June 1978.
CCosts include all those incurred in property exploitation and production except costs of money and
taxes.
dDoes not include 126.000 MT of U30S which could be produced as a by-product of phosphate
fertmzer and copper production.
Table B.3.Comparison of U.S.reactor requirements and domestic r_availability
(in metric tons of U30 S as ofJanuery 1978~.b
3."ERDA Makes Preliminary Estimate of Higher Cost Uranium Resources."U.S.Energy ResearchandDevelopmentAdministrationNotice.June 1977.
1.Office of the President.NationaZ Enepgy Ptan~Washington.D.C••April 1977.
2.Brown and Williamson.U.S.Department of Energy."Domestic Uranium Requirements.Policy
and Evaluation."paper presented at the Uranium Seminar.Grand Junction.Colo.•October
1977.
4.J.F.Pacer.Jr.,"Seminar on Uranil.lIl Resources."paper presented at the Uranium Seminar.
Grand Junction.Colo••October 1977.
As can be seen in Table B.1.the annual requirement for U30e in 1981 (17.500 MT)exceeds the
output of existing uranium mills (12,000 MT).In 1980.·the White Mesa Uranium Project
would produce 6%of the national capacity for tons of ore per day.and its total production of
U30e through the next 15 years of operation would be about 3%of the national requirements.
Although this production is not currently planned for use to meet National requirementsdirectly.it will increase the overall U30e supply available.The project will contribute to
meeting the demand forecast for the nuclear power industry.
Appendix C
STATEMENTS OF GENERAL FUND REVENUES AND EXPENDITURES
FOR SAN JUAN COUNTY.
BLANDING AND MONTICELLO
•
.;):'~;';''';'''ifi~··''·
SAN JUAH COUNTY
GENERAL FUND
&1ATENENT OF REVENUES,EIPENDITURIS.AND COMPARISON WITlI BUDGET
1'01 TIll YlAil ENDED DECEHaI!R 31.1977
HIGIIWAY AND PUILIC IHPIOVINENT:
n,
(",
San Juan County Audit for 1911.
SAH JUAH COUNTY
GEKlRAL FUND
STATEMENT OF REVENUES,EXPENDITURES,AHD COMPARISON WITH 8UDGET
FOIl THE YEAR ENDED DECEMBER 31,1977
Source:
1911 OVER 1916
TOTAL (UNDER)ACTUAL
EXPENDITURES !!!Jg!~~PRIOR YEAR
PARKS,RECREATION AND PUBLIC PIl.OPEIlTY:
Parka and I'ecreation $71,293 $71,602 $309 $63,823
Televiaion ---2..600 11,436 1.836 18,102
Total park..recreation and
public property §80,893 §89,038 §8,145 §82.525
CONSERVATION AND ECONONIC DEVELOPIlENT:
Aariculture and extenaion .ervice l __11.815 $16,013 $2,198 $1l,346
Total conaervltioD and
econ..ic developlMtnt t 1l,815 $16r013 §2,198 ,1l,346
TOTAL EXPENDITURES -GENERAL FUND 13,045,563 '2,240,945 $(804,618)ll.lll.239
EXCE8S UVENUE8 (EIPENDITUlES),(531.42S)·'--444.917 •982,405 §310.166
161,410
328,004
203.713
11,939
145,648
4,213
Ji,Oll
11,212
$192,214
,
1976
ACTUAL
PRIOR YEAll
OVER
(UNDER)
!!!!!ill
$91,396
(239,008)
(483,411)
(101,901)
,(II,500)
(48)
56-.ill!.)
$(12,213)
150,896
310,992
96.583
I1r899.
1977
TOTAL
~
,198r122
,144;320
5,181
36,156
ll,859
'''903'309 'Ir116,310 ($126.930)$1,311,016
$653,500
550,000
580,000
119,800
$326,315 ,250,151 $06,158)$155,538
~
,155,820
5,835
36,100
12,600
,210,355
;.;......0.:-:.
$31,950 $31,434 $(516)$28,785
3,150 2,994 (156)3,252
15,000 22,364 7,364 15,818
6,500 1.901 (4,593)922
40,250 34,284 (5,966)35,005
36,980 39,817 2,891 34,648
24.100 l2,914'(l,126)21,781
16,380 15,094 (l,l86)13,918
23,825 26.336 2.511 ~6,086
39.910 37,106 (2,264)40,340
1,000 121 (213)
185,500 222,525 37,025 19l,005
18,150 21,143 2,993 18,258
68.010 31.820 (36,250)31,662
$510,825 ,_51I.l85 !...-...lli $468.540
"":'.,,;ru~
ll'Ilh".,.CI road.e.lIe.tor road.
N,.c~llen.ouo
'rotol hipwo,end
public i.prov_nt
Hb.ltb ••Ivic.a
C.uamilililon
Di'tri~t COU1't
elly ..nd pfecinct court.
Oth..judicial
'..·rk end euditor
Il~,ol'du
Ac tc.tney
Tre.....r.r
A'lc"'ol'
S"r"f:)'\ll
PI.nuln,ca.-i••ion
N.n·d~~rt_nrel
Buildin.o
AdJcrl i..in,aDd c.,...Dity pro.otion
Toul .enerel .over......nt
fUBLIt KlALTH:
PUBLIC HAfETY:
t;huilf
For"d~pe.t...nt
(,lu.~'Liona'(jail)
Othea pr"t.~tioQ
Tutel publie .ofocy
EXPENDITURE'
CENE:tAL GOVERIOlEIIT:
lliEIl .':Piil5'!i
n
I.p.
I 9».)91
I 866.129
U.716
76,376
5.176
1976
ACTUAL
.UlIIl YIAI
OVER
(UIlDII)
!!!!!!!!
•.91.0151.91'
17.6"
8,020
!!!!!!2!!
79.60'•61,116
38,909 119.276
73.172 63.012
I 100.000 •.,1.690 •91.690 f 263,602
12.'08,135 12,685.'22 I 117.787 12.536.005
•61.000'9a,697 I 30.697 •72.202
I 3.150 I 3.250
116 663
I '"•3.968 I 3.966 L.-!t.713
• •
11.655 •11.655 •11.892
"'.029 119.029 116.671
465.000 292.902 Cl52.09S>
16,000 36.392 22,392 9,653
550,000 53',83'(10,162)525,572
~116.712 (19.288)92.331
fI,IU,OOO fI,114,528 .S 2'.672>L..!!l&919
•119,850 •'1,055 I(38.795)•76.936
7,500 5,U6 (1,686)10,591
162,000 155.146 13.146 305.882
3.120 3.120 4.160
26,000 12,755 (11.265)26.283
--!Ll92 32.136 13.136 29,528•313,050 •290,722 .(22.32S>•469.37.
I .9\.015 I 9n.m I 102.41\
!!!!!!!!!!.
IAIl JUAN CllUIITY
CZ.UL,\IIlD
ITA~IIT 0'UVENIJII.IUIIlDITlIUI.AllD COWAll8Oll 111ft lUIIG8T
fOI TIl 1IAI 1_llICIIIIU U,.971
1917
TOTAL
!e!!!!:
TOrAL UVlIIIIII -GI.UL JI/III
'1.1 AIIl roua11WlI,
ra•••
NIIClUAllIOUI UVI_I,
lot.r..t ••nlol.loot....eooe••al .••1.of ..t.d.h ur,U••
Tot.l .l.e.ll_r."._.
LIClUII AlII ITlI
au.lao••H ...tt.
..............Ue t.
Tot.l He oed .....tt.
lIIftllOOVl ftAL UVI_I:
' 1 Ir t.' a r"...,,_.' a ..,...t.I.HIN of C.....
It.t.Irut.
It.t."r••r.vonu••
Grata h_otller wit.
Tot.l lot........._t.l r."_.
CIIAIGII fOI IUVlClI:
Goo...al lo"•..-tPuIlHe.ar.t,
Itr••t ....pullUe l..ro,,_t.
I..ltll
Pork.oed pubUe ,ro..rt,
lIi.coll_........"le••
Tot.l ourl"for ..."le••
TADI:c.••ral ,ro..rt,t .
DaH"UHC ,dor ,t .aa.....l •••••~U••t .
,..ltl.....l.t.....t C.....
,.t..t.....(lot.a)
n•(T,
,~..:'~',;-";.:!~'
~.-.-1
(87.73)
$404,416.05
$21,220.54
$404,38~.32
$425,608.~6
1.522.94
180,00
J..n.30.1917
$44,393.96
1,691.72
55.313,55
450,00
1,387.60
6,00
245,00
170.00
18,227.00
4.248.20
14.278.44
5,626.70
1,351.81
280,00
6,718,50
18,462,50
102,61
480,26
160,33
98.19
225,000.00
3,389.71
1.193.31
9,672.01
9,845.59
1,110,05
(134,65)
$150,383,63
$158,019,03
$111,891,59
$19,872.56
8.219,98
11,525,33
127.25
J..aa 30,1916
$i7,959.5)
3,488.70
43,336,72
489.00
645,80
1.00
85.00
5,931.30
14,087.00
4,248.20
6,940.83
2.,056,46
1,782,33
700.00
7,879.00
11,451,31
80,61
901,56
1,335,16
10,12
517,42
318.52
Ad':.,a-c••h I•••RU••:
S....lc.P•••(U••t.CoII.ctlo...nd DI.po••I,.
,lepr.....t.tl••of U..coll.ctlbl.Account.Ch."led
II.ctrlc,V.t nd 5.....Utility ,..nd.
I AccOllDt Cu nt C..acliU
"'10".'.JTOII T•••••I.tl.....nt ,..ad•••nd
I.......nc.'....I....Wlthh.l.'
~I.ctacl Offlcl.l••nd 'I.......leploy.......'It.
Allo"';I.......nc.h ..I_.
Tot.''.ftDU.A'Ju.t_nt.
TOTAl.CItOSg:IF-YIIllr:S
Tot.1 I,calpt.
STATItlEIII'0'CEIlUAL fUND IEYEIIIES .nd U'ENDITURiS -FISCAL YEAlS ENDED JUNE 30,1916 -1911
SCHEDUlE:"E"
CITY or BLANDING
Il.adlna City,Utah
1.I.ac••C.,h I.c.lpt.
,,i·.;'~~7~t'1..r.~":'r.-
C••h Acco....t.bllity A'J...t_nt.-
Add'.C~.h Cont..lbutio..-Ilect..lc,w.t....nd 5.....,..ad,Acc~u..t C......ent
Dachlct:
DI.co..nt.Allowed -W••t.CoII.ctlo...nd DI.po••l
.IYIJUE .ECEIPTS,
Coon.ftt Y.ar 'rop...ty T .
.....,tlo..-...10..,T••••
5.1...nd U••T••••
...1....Lie......
..11.1",.nd Co••tructlo..'....It.
Ilcycl.'n.
Oth.r llc nd 'It.c t.'ro-'ad l Oo _..t
, 1 ••••na.Sh...I...
Stat.LlqaD",.ad A110t t
Cl•••"e".oad '"nd Allot_nt
Oth Oo nt.l C".Dt.
AI t .
C t y Lot 5.1••
Cou..t Pi.....nd Itl••
W••t.~llectio ad DI.po••1 ,•••
W••t.CoII.ctlon .nd DI.po••l '•••Itl••
1 Red I..t t -Cl..."eN load 'und
1 Red I..t t • I...RU.Sh...I",'und
E Red IDt t -AI..po..t Co••tructlo..'undrroc....,5.1.of C.O...ad.
I ...na'I..t n •C.o...nd ,.ad.
·"I.c.II I...RU••
CIT\'or ....111;
11...t..CU"OUIl
n
I'"$136.147.77
11.396.36
10.686.07
48.344.32
10S.34
$5.606.53
3.536.93
1.086.75
589.50
46.929.58
4.744.42
60.00
26.960.59
1.075.00
1.498.50
6.275.00
18.i88.40
14,6toto.88
4.824.35
CONrIM1ATION • • • • • • • • • • • • • •---------------
$123.857.98
170.147.2)70.427.80
--
$294.005.21 $206.575.57
($116.11).62)$219,0)).29
(11.72)0.032.76)21.)8 28.37123.78 142.98135.034.98 38.672.31--
$19.054.80 $256.844.19
$6,044.01
2,742.42
388.14
~89.50
47,288.56
2,396.21
60.00
17,969.27
1,105.00
1.532.20
6.522.50
18.887.50
12.725.04
3.352.04
2.180.0.-
75.13
7.480.113
8.332.04
154.310.36
4.00
-.-.--------.-.---...--.-----.-----
Othar 1.,..,lt.r••1
1...,1..I t..I.rl...A•••t.
I..ftt.ac.-10'••••Vltllhald T•••••l1li I.aur.nc.'r...I...Co.trl"tlo.-II.etrle.V.t.r .l1li S...r.Account Curr.nt1.,.l1li.-~••t.CoII.etlo....DI.po••1
T~t.1 nt".r 1.....ltur••
Toul OPftoU,.1.....Uure.
urP:llltTU1l CIIAIcrsl
o,.r.tl..'......tt.r••l'''I.t.tr.tt...
Mnlcl,..CoRt
II-etlo.I ....u I.,...
roUc ~.t I .
rlr.....r~.t r .
I....ctlo.....rt t I .
Itr..t Dep.re-e.t I .
..Itt.I.nfe UO 1
V.tft -Serf••11-1-47
S...r -Serf••12-1-54
Ltlht -Sert••5-1-57
V.t.r - I t••5-1-74
V••t.CoII.etfo DI.po••1 I......Airport I ......
Ct..."C"10"r••I ...n••
'.r.....••er••tlo.I.,.•••
TOr41 qprllllTUllS
Adju.~.t.l
lacr....t.1 I.cr••••In U..pproprl.t.d Surplu._
...10,...·I••ur.ne.'r..I...Ad••ne.d.laer••••
V••t.CoII.etlon ...DI.po••1 Aecou.t.a.e.I••bl••Iner••••
'.yroll T.~.,.,.bl••laer••••
II.ctrlc,V.t.r .l1li Sewer -Aeeount Curr.nt.Iner••••
Not laer••••I.U••pproprl.ted Surpl••
SCIlnULII "I"IfATDllIII'or CIIlIIAL PUIIl II"IIIIS AIID urlllllTUll1 _rlSCAL YUlS EIIIED JU.30,1976 _1977 ••
IICISI (DEFICIT)1 .......'.e.lpt.Ow.r 1...lIIIltur••
.r----:..,:.._:..~~------_"J.i-.....L __~..__,_..L':~'.~
MONTICEllO
GENERAL FUND
levenue.
Property taxes
Sal..tax
Court fines
Cia.."c"load Fund
State Liquor Allotment
Bu.ines.licenses
Other 1icenae.and permits
Other revenue.
Total Revenues
Dilburlements
Mminiltration
Court
PoUce
Fire
Streetl
Parke
Total Disbursements
Tranlfer to Bond Redemption &Intere.t Fund
Exces.of Revenues over Disbursements and
Tran.fer.
r-~,;....._--_.__..1
1977-1978
Adjusted
Budget
$37,536
79,908
16,422
4,950
2,702
1,602
2,066
2,450
$147,636
$54,800
3,700
49,400
1,700
10,200
2,000
$111,800
19.500
$141,300
$6.336
.-(,~~}~:;'~~~.-~.~)ii-i.,~·~:,
nI
"
~..
E'.,
11 :l'
Appendix D
DETAILED RADIOLOGICAL ASSESSMENT
!,
·1'.P~f
D-3
APPENDIX D.DETAILED RADIOLOGICAL ASSESSMENT
Supplemental information is provided below which describes the models,data,and assumptions
utilized by the staff in performing its radiological impact assessment of the White Mesa Uranium
Project.The primary calculational tool employed by the staff in performing this assessment
is an NRC-modified version of the UDAD (Uranium Dispersion and Dosimetry)computer code,
originated at Argonne National Laboratory (Ref.1).
0.1 ANNUAL RADIOACTIVE MATERIAL RELEASES
Estimated annual activity releases for the White Mesa site are provided in Table 3.3.They
are based on the data and assumptions given in Table 3.2 and described elsewhere in Section 3andinAppendixF,with the exception of the annual average dusting rate for exposed tailings
sands.This dusting rate is calculated in accordance with the following equation:
M=3.156 X 107 L;Rls (0-1)0.5 s
where Fs is the annual average frequency of occurrence of wind speed group s,
dimensionless;
Rs is the dusting rate for tailings sands at the average wind speed for wind speed
group s,for.particles ~20 ~m diameter,g/m2-sec;
M is the annual dust loss per unit area.g/m2-yr;
3.156 x 107 is the number of seconds per'year;and
0.5 is the fraction of the total dust loss constituted by particles <20 ~diameter,
dimensionless (Ref.1).-
The values of Rand F utilized by the staff are as g~ven in Table 0.1.The calculated
value of the an~ual du~ting rate,M,is 555 g/m2·yr.Annual curie releases from the
tailings piles are then given by the following relationship:
(0-2)
where A is the assumed beach area of the pile,m2 ;
fc is the fraction of the dusting rate controlled by mitigating acti~ns,dimensionless;
ft is the fraction of the are content of the particular nuclide present in the tails;
S is the annual release for the particular beach area,Ci/yr;
423 is the assumed raw ore activity,pCi/g;
2.5 is the dust to tails activity ratio;and
lxlO-12 is Ci/pCi.
Table 0.1 Parameter Values for Calculation of Annual Dusting
Rate for Exposed Tailings Sands
Wind Speed
Group,knots
0-3
4-6
7-10
11-16
17-21>21
Average Wind
Speed.mph
1.5
5.5
10.0
15.5
21.5
28.0
Dusting Rate )
(Rs)'9/m2 -secla
oo3.92xl0-7
9.68xlO·6
5.71xl0·s
2.08xl0-4
Frequency af()
OCcurrence(F5)b
0.2836
0.1736
0.0395
0.0229
(a)
(b)
Dusting rate as a function of wind speed is computed by the UDAD code
(Ref.1).
Wind speed frequencies obtained from annual joint frequency data
presented in Table 0.2.
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0-4
---------------------
0-5
Fo~the W~ite ~sa site,it wa~assumed ~hat two.100:acre c~lls would be available for dusting
Whlle drylng prlor to reclamatlon.Requlred mitlgatlng actlons to reduce dusting were assumed
to reduce dust losses by 80 percent for these cells.It was also assumed that half of a
third 100-acre cell being filled would be beach area and available for dusting.No control
was assumed for the exposed beach area of the operational cell.
Dust losses from the six-acre ore storage pile were estimated by assuming they would be about
one percent of those fram an equivalent area of tailings beach.
0.2 ATMOSPHERIC TRANSPORT
The staff analysis of off site air concentrations of radioactive materials released at the
White Mesa mill site has been based on a full year of meteorological data collected on site
over the period 3/1/77 through 2/28/78 (Ref.2).The collected meteorological data is entered
into the UDAD code as input,after assemblage and reduction,in the form of a joint frequency
distribution by stability class,wind speed group,and direction.The joint frequency dataemployedbythestaffforthisanalysisarepresentedinTable0.2.
The dispersion model employed by the UDAD code is the basic straight-line Gaussian plume model(Ref.1).Ground level,sector-average concentrations are computed using this model and are
corrected for decay and ingrowth in transit (for Rn-222 and daughters)and for depletion due
to deposition losses (for particulate material).Area sources are treated using a virtual
point source technique.Resuspension into the air of particulate material initially depositedongroundsurfacesistreatedusingaresuspensionfactorwhichdependsontheageofthe
deposited material and its particle size (Ref.1).For the isotopes of concern here,the total
air concentration including resuspension is about 1.6 times the ordinary air concentration.
The assumed particle size distribution,particle density,and deposition velocities for each
source are presented in Table 0.3.
Table 0.3 Physical Characteristics Assumed for Particulate Material Releases
Deposition
AMADa,Diameter,Densit~,Velocity,Activity Source \.1m 9/cm em/sec ~
Crusher Dusts 1.0 2.4 1.0 1.55
Yellowcake Dusts 1.0 8.9 1.0 2.98
Tailings,Ore Pile 5.0 (30%)2.4 1.0 7.75
Dusts 35.0 (70%)2.4 8.8 54.2In-grown Rn Daughters 1.0 0.3 0.3
aAerodynamic equivalent diameter,used in calculating inhalation
dos!!s (Ref.1).
0.3 CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Information provided below 'describes ·the methods and data used by the staff to determine the
concentrations of radioactive materials in the environmental media of concern in the vicinity
of the White Mesa site.These include concentrations in the air (for inhalation and direct
external exposure),on the ground (for direct external exposure),and in meat and vegetables
(for ingestion exposure).Concentration values are computed explicitly by the UOAO code for
U-238.Th-230.Ra-226,Rn-222 (air only),and Pb-210.Concentrations of,Th-234.Pa-234,andU-234 are assumed to be equal to that of U-238.Concentrations of 8i-210 and Po-2l0 are assumed
to be equal to that of Pb-210.
0.3.1 Air Concentrations
Ordinary,direct air concentrations are computed by the UDAO code for each receptor location,
from each activity source.by particle size (for particulates).Direct air concentrations
computed by UDAO include depletion by deposition (particulates)or the effects of ingrowth
and decay in transit (radon and daughters).In order to compute inhalation doses,the total
air concentration of each isotope at each location,as a function of particle size,is computed
as the sum of the direct air concentration and the resu$pended air concentration:
,;
(0-3)
D-6
(0-6)]
10-9 {_ex_p_(-_1_.8_2_A_i*_)_-_ex_p_(-_A_i_*t_)}rO-SJ
Ai*
+
Concentrations of particulate materials in and on soil are computed from direct air concentra-
tions.Resuspension of deposited activity is not treated as a loss mechanism and redeposition
is ignored.Ground concentrations are given by
CgiP(t)=0.01 Caipd Vp [1 -exp (-Ai*t)
Ai*
where Cgip(t)is the ground concentration of isotope i,particle size p,at time t,pCi/m2;and
A'*is the effective decay constant for isotope i on or in soil,yr-1;1
and where Ai*=Ai +A*(D-7)
where Ai is the radiological decay constant,yr-1;and
A*is the assumed environmental loss constant for activity in s011 (equivalent to a
50-yr halflife),1.39 x 10-2/yr•
where CaiP(t)is the total air concentration of isotope i,particle size p,at time t,pCi/m 3 ;
Caipd is.the direct air concentration of isotope i,particle size p,(constant)
pCl/m3;and
Caipr(t)is the resuspended ~ir concentration of isotope i,particle size p,attimet,pCi/m3•
The resuspended air concentration is computed using a time dependent resuspension factor,
R(t),defined by
()(1 )-5 e-ARt (Rp t /Vp 10 for t ~1.82yrs)(O-4a)
Rp(t)(1/Vp)10-9 (for t >1.82 yrs)(O-4b)
where Rp(t)is the ratio of the resuspended air concentration to the ground concentration,for a ground concentration of age t Yrs,of particle size p,m-1;
Vp is the deposition velocity of particle size p,em/sec;
AR is the assumed decay constant of the resuspension factor (equivalent to
a 50-day ha1f1ife),5.06 yr;
10-5 is the initial value of the resuspension factor (for particles with a depositionvelocityof1em/sec),m-1;
10-9 is the terminal value of the resuspension factor (for particles with a deposition
velocity of 1 em/sec),m-1;and
1.82 is the time required to reach the terminal resuspension factor,yrs.
The basic formulation of the above expression for the resuspension factor,the initial and
final values,and the assigned decay constant derive from experimental observations (Ref.3).
The inverse relationship to deposition velocity eliminates mass balance problems involving
resuspension of more than 100%of the initial ground deposition for the 35 ~particle size
(see Table 0.3).Based on this formulation,the resuspended air concentration is given by
where Ai*is the effective decay constant for isotope i on soil (see Equation 0-7),yr-1 ;and
0.01 ism/em.
Total air concentrations are computed using Equations 0-5 and 0-3 for all particulate effluents.Radon daughters which grow in from released radon are not depleted due to deposition losses
and are therefore not assumed to resuspend.
0.3.2 Ground Concentrations
In general,the half-lives of the pertinent isotopes are such that it is appropriate to assume
either complete ingrowth or no ingrowth.However,ingrowth of Pb-210 from Ra-226 is treatedexplicitlyusingthestandardBatemanformulation.
0.3.3 Vegetation Concentrations
(0-8)
0-7
concentrations of released particulate materials can be environmentally transferred to the edible
portions of vegetables,or to hay or pasture grass consumed by animals,by two mechanisms _
direct foliar retention and root intake.Five categories of vegetation are treated by the staff
modified version of the UOAo code.They are edible above ground vegetables,potatoes,other
edible below ground vegetables,pasture grass,and hay.Vegetation concentrations are computedusingthefollowingequation
[
1 -exp (-AW t)] BviCvip=0.01 Vp Caip Fr Ev --~Y~V~AW--~~-+Cgip -P-
where Bvi is the soil to plant transfer factor for isotope i,vegetation type v,dimensionless;
Cvip is the resulting concentration of isotope i,particle size p,in vegetation v,pCi/kg;
Ev is the fraction of the foliar deposition reaching edible portions of vegetation v,
dimensionless;
is the fraction of the total deposition retained on plant surfaces,0.2,dimensionless;
is the assumed areal soil density for surface mixing,240 kg/m2 ;
is the assumed duration of exposure while growing for vegetation v,sec;
is the a~sumed yield density of vegetation v,kg/m2;
is the decay constant accounting for weathering losses (equivalent to a 14-day half-
life),6.73 x 10-7/sec;and
0.01 is m/cm.
The value of E is assumed to be 1.0 for all above grounnd vegetation,and 0.1 for all below
ground vegetabYes (Ref.4).The value of t is taken to be 60 days,except for pasture grass
where a value of 30 days is assumed.The yVeld density,Y ,is taken to be 2.0 kg/m2 except for
pasture grass,where a value of 0.75 kg/m2 is applied.VaYues of the soil to plant transfer
coefficients,Bvi 'are provided in Table 0.4.
Table 0.4 Environmental Transfer Coefficients
u Th Ra Pb
I.Plant/Soil (Bvi's)
a)Edible Above·Ground:b)Potatoes:
c)Other Below Ground:
d)Pasture Grass:
e)Stored Feed (Hay):
II.Beef/Feed (Fbi's)
pCi/kg per pCi/day:
0.3.4 Meat Concentrations
Radioactive materials can be deposited on grasses,hay,or silage which are eaten by meat
animals,which are in turn eaten by man.For the White Mesa site,it has been assumed that meat
animals obtain their entire feed requirement by grazing,6 months per year,and by eating locally
grown stored feed th~remainder of the year.The equation used to estimate meat concentrations
is
0.4 DOSES TO INDIVIDUALS
*One WL concentration is defined as any combination of short-lived radioactive decay products of
Rn-222 in one liter of air that will release 1.3 x 105 MeV of alpha particle energy during theirradioactivedecaytoPb-210.
(0-9)
0-8
in pasture grass,pCi/kg;
in hay (or other stored feed),pCi/kg
Fbi (0.5 Cpgi +0.5 Chi)
is the concentration of isotope
is the concentration of isotope
is the assumed feed ingestion rate,50 kg/day;and
is the fraction of the total annual feed requirem~nt assumed to be satisfied by
pasture grass or locally grown stored feed.
is the resulting concentration of isotope i in meat,pCi/kg;
is the feed to meat transfer factor for isotope i,pCi/kg per pCi/day (see
Table 0.4);
Q
0.5
Cmi =Q
where Cpgi
Chi
Inhalation doses have been computed using air concentrations obtained by Equation 0-3 (resus-
pended air concentrations are included)for particulate materials,and the dose conversion
factors presented in Table 0.5.These dose conversion factors have been computed by Argonne
National Laboratory's UOAO code (Ref.1)in accordance with the Task Ground Lung Model of the
International Commission on Radiological Protection (Ref.5).
Doses'to the bronchial epithelium from Rn-222 and short-lived daughters were computed based on
the assumption of indoor exposure at 100%occupancy.The dose conversion factor for bronchial
epithelium exposure from Rn-222 is derived as follows (see Appendix I for additional details):
Doses to individuals have been calculated for inhalation,external exposure to air and ground
concentrations,and ingestion of vegetables and meat.Internal doses are calculated by the staffusingdoseconversionfactorswhichyieldthe50-yr dose commitment,i.e.,the entire dose
insult received over a period of 50 years following either inhalation or ingestion.Annual doses
given are the 50-yr dose commitments resulting from a one-year exposure period.The one-year
exposure period was taken to be the final year of mill operation when environmental concentra-
tions resulting from plant operations are expected to be at their highest level.
0.4.1 Inhalation Doses
1)1 pCi/m3 Rn-222 =5 x 10-6 Working level (Wl).*
2)Continuous exposure to 1 WL =25 cumulative working level months (WLM)per year.
3)1 WLM =5000 mrem (Ref.6)
External doses from air and ground concentrations are computed using the dose conversion factors
provided in Table 0.6 (Ref.1).Doses were computed based on 10~occupany at the particular
location.Indoor exposure was assumed to occur 14 hrs/day at a dose.rate of 70%of the outdoor
dose rate.
Therefore:
1 pCi/m 3 Rn-222 x (5 x 10-6 pc~m3)x (25 w~r)x (5000 ~)=0.625 mrem
and the Rn-222 bronchial epithelium dose conversion factor is taken to be 0.625 mrem/yr per
pCi/m3•
0.4.2 External Doses
0.4.3 Ingestion Doses
Ingestion doses have been computed for vegetables and meat (beef and lamb).Ingestion doses
reported are based on concentrations obtained using Equations 0-8 and 0-9.ingestion rates given
0-9
Table 0.5 Inhalation Dose Conversion Factors (mrem/year/pCi/m 3)
Particle Size =0.3 Microns PB210 P02l0
Whole Body 7.46E+00 1.29E+00
Bone 2.32E+02 5.24E+00
Kidney 1.93E+02 3.87E+Ol
Liver 5.91 E+Ol 1.15E+0l
Mass Average Lung 6.27E+Ol 2.66E+02
Particle Size =1.0 Microns U238 U234 TH230 RA226 PB210 P0210
Density =8.9 g/cm3
Wliole Body 1.44E+00 1.64E+00 1.37E+02 3.97E+Ol 9.42E+00 1.77E+OO
Bone 2.42E+Ol 2.64E+Ol 4.90E+03 3.97E+02 2.87E+02 7.22E+00
Kidney 5.53E+00 6.30E+00 1.37E+03 1.40E+00 2.39E+02 5.33E+Ol
.Liver O.O.2.82E+02 4.94E-02 7.32E+Ol 1.59E+Ol
Mass Average Lung 2.13E+03 2.42E+03 2.37E+03 3.04E+02 2.49E+Ol 1.12E+02
Particle Size =1.0 Microns U238 U234 TH230 RA226 PB2l0 P02l0
Density =2.4 g/cm3
Whole Body 1.65E+00 1.87E+00 1.66E+02 3.40E+Ol 8.24E+00 1.54E+90
Bone 2.78E+Ol 3.03E+Ol 5.95E+03 3.40E+02 2.56E+02 6.29E+00
Kidney 6.33E+00 7.22E+00 1.67E+03 1.20E+OO 2.13E+02 4.64E+0l
Liver O.O.3.43E+02 4.22E-02 6.53E+01 1.38E+Ol
Mass Average Lung 2.88E+03 3.28E+03 3.22E+03 4.04E+02 3.38E+Ol 1.48E+02
Particle Size =5.0 Microns U238 U234 TH230 RA226 PB2l0 P0210
Whole Body 1.16E+00 1.32E+00 1.01E+02 4.47E+Ol 1.00E+Ol 1.96E+OO
Bone 1.96E+Ol 2.14E+Ol 3.60E+03 4.47E+02 3.11E+02 7.99E+00
Kidney 4.47E+00 5.10E+00 1.ooE+03 1.57E+00 2.59E+02 5.89E+01
Liver O.O.2.07E+02 5.55E-02 7.93E+Ol 1.76E+Ol
Mass Average Lung 1.24E+03 1.42E+03 1.38E+03 1.87E+02 1.45E+Ol 7.01E+Ol
Particle Size =35.0 Microns U238 U234 TH230 RA226 PB210 P0210
Whole Body 7.92E-01 9.02E-01 5.77E+01 4.40E+01 9.66E+00 1.93E+00
Bone 1.34E+01 1.46E+01 2.07E+03 4.40E+02 3.00E+02 7.84E+00
Kidney 3.05E+00 3.47E+00 5.73E+02 1.55E+OO 2.50E+02 5.79E+01
Liver O.O.1.19E+02 5.47E-02 7.65E+0l 1.73E+Ol
Mass Average Lung 3.33E+02 3.80E+02 3.71 E+02 6.38E+01 3.91 E+OO 2.58E+Ol
Table 0.6 Dose Conversion Factors for External Exposure
Dose Factors for Doses from Air Concentrations,mrem/yr per pCi/m3
ISOTOPE SKIN WHOLE BODY
U238 1.05E-05 1.57E-06
TH234 6.63E-05 5.24E-05
PAH234 8.57E-05 6.64E-05
U234 1.36E-05 2.49E-06
TH230 1.29E-09 3.59E-06
RA226 6.00E-05 4.90E-05
RN222 3.46E-l0 2.83E-06 .,
P0218 8.18E-07 6.34E-07
PB214 2.06E-03 1.67E-03 ·nB12141.36E-02 1.16E-02
P0214 9.89E-07 7.66E-07 ".
PB210 4.17E-05 1.43E-05
II
.Ii
,"-
m!j
D-10
Table 0.6 Cont'd
Dose Factors for Doses from Ground Concentrations.mrem/yr per pCi/m2
ISOTOPE SJe'IN WHOLE BODY
U238 2.13E-06 3.l7E-07TH2342.10E-06 1.66E-06PAM2341.60E-06 1.24E-06U2342.60E-06 4.78E-07TH2302.20E-06 6.l2E-07RA2261.16E-06 9.47E:07RN2226.15E-08 5.03E-08P02l81.42E-08 1.10E-08PB2143-.89E-05 3.l6E-05B12142.18E-04 1.85E-04P02141.72E-OB 1.33E-08PB2l06.65E-06 2.27E-06
in Table 0-7.and dose conversion factors given in Table 0-8 (Ref.1 and Ref.7).Vegetable
ingestion doses were computed assuming an average 50%activity reduction due to food preparation(Ref.4).Ingestion doses to children and teenagers were computed but found to be equivalenttoorlessthandosestoadults.
Table 0.7 Assumed Food Ingestion Rates.a kg/yr
Child Teen Adult
1.Vegetables (Total):48 76 105
a)Edible Above Ground:16 29 42b)Potatoes 27 42 60c)Other Below Ground:5 5 3
II.Meat (Beef and Lamb):28 45 78
a All data taken from Reference 4.Ingestion rates are averages for typical rural farm house-
holds.No allowance is credited for portions of year when locally or home grown food may notbeavailable.
Table 0.8 Ingestion Dose Conversion Factors (mrem/pCi ingested)
Age Group Organ 238U 234U 234TH 230TH 226RA 210PB 210BI 210PO
Infant Who Bod 3.33E-04 3.80E-04 2.00E-08 1.06E-04 1.07E-02 2.38E-03 3.58E-07 7.41E-04
Bone 4.47E-03 4.88E-03 6.92E-07 3.80E-03 9.44E-02 5.28E-02 4.16E-06 3.lOE-03
Liver O.O.3.77E-08 1.90E-04 4.76E-05 1.42E-02 2.68E-05 5.93E-03
Kidney 9.28E-04 1.06E-03 1.39E-07 9.12E-04 8.71E-04 4.33E-02 2.08E-04 1.26E-02
Child Who Bod 1.94E-04 2.21E-04 9.88E-09 9.91E-05 9.87E-03 2.09E-03 1.69E-07 3.67E-04
Bone 3.27E-03 3.57E-03 3.42E-07 3.55E-03 8.76E-02 4.75E-02 1.97E-06 1.52E-03
Liver O.O.1.51 E-08 1.78E-04 1.84E-05 1.22E-02 1.02E-05 2.43E-03
Kidney 5.24E-04 5.98E-04 8.01E-08 8.67E-04 4.88E-04 3.67E-02 1.15E-04 7.56E-03
Teenager Who Bod 6.49E-05 7.39E-05 3.31E-09 6.00E-05 5.00E-03 7.01E-04 5.66E-08 1.23E-04
Bone 1.09E-03 1.19E-03 1.14E-07 2.16E-03 4.09E-02 1.81E-02 6.59E-07 5.09E-04
Liver O.O.6.68E-09 1.23E-04 8.13E-06 5.44E-03 4.51E-06 1.07E-03
Kidney 2.50E-04 2.85E-04 3.81E-08 5.99E-04 2.32E-04 1.72E-02 5.48E-05 3.60E-03
CJ
"4.54E-05
I
Adult Who Bod 5.17E-05 2.13E-09 5.70E-05 4.60E-03 5.44E-04 3.96E-08 8.59E-05 ~
~
Bone 7.67E-04 8.36E-04 8.01E-08 2.06E-03 4.60E-02 1.53E-02 4.61E-07 3.56E-04
Liver O.O.4.71E-09 1.17E-04 5.74E-06 4.37E-03 3.18E-06 7.56E-04
Kidney 1.75E-04 1.99E-04 2.67E-08 5.65E-04 1.63E-04 1.23E-02 3.83E-05 2.52E-03
...~~..-:'-,.7::,~~,;;_,c-=L__
_-~.".-.-.-.._~_~~,:..;;".:·.:r:.:~:,:~~",~~.i.'~·~l-<.~·,.~"...,.~-~,.-
·:.-..-:··:....:.~'-iti;··i·.·
D-12
REFERENCES FOR APPENDIX D
1.M.Momeni et al.,"Uranium Dispersion and Dosimetry (UDAD)Code",Argonne National Laboratory
Report,in preparation.
2.Personal communication (letter),Environmental Coordinator,Energy Fuels
Nuclear,Inc.,to U.S.NRC,November 8,1978.
3.Generic Environmental Impact Statement on Uranium Milling,NUREG-0511,
April 1979.
4.J.F.Fletcher and W.L.Dotson (compilers),"HERMES - A Digital Computer Code for Esti-
mating Regional Radiological Effects from the Nuclear Power Industry",Hanford Engineering
Development Laboratory,HE~L-TME-71-168,December 1971.
5.ICRP Task Group on Lung Dynamics,"Deposition and Retention Model s for Internal Dosimetry of
the Human Respiratory Tract",Health Physics 12:181,1966.
6.National Academy of Sciences -National Research Council,"The Effects on Populations of
Exposure to Low Levels of Ionizing Radiation,"Report of the Advisory Committee on the
Biological Effects of Ionizing Radiation (BEIR),U.S.Government Printing Office,1972.
7.G.R.Hoenes and J.K.Soldat,"Age -Specific Radiation Dose Conversion Factors for a One-
Year Chronic Intake,"Battelle Pacific Northwest Laboratories,U.S.NRC Report NUREG-0172,
November 1977.
"io>
Appendix E
LETTER TO THE ADVISORY COUNCIL ON HISTORIC'PRESERVATION r 1L.,
---;~.~....;.-..,:.......~~..,.:..-~....
'-••'~':O,;"'..'"-,:-,~.~~:~1~~}1..'"--:~i~ji~1:7:~-~J __:'~,,--i,~~'~~;:.'
PRELIMINARY CASE REPORT
Concerning The Lands to be Impacted by the Proposed
White Mesa Uranium Mill
In response to a request by Energy Fuels Nuclear,Inc.,the U.S.Nuclear
Regulatory Commission proposes to issue a Source Material License to possess
and use source material at a uranium mill to be located on the White Mesa
approximately flve (5)miles south of Blanding,Utah.Under the provisions
of the Atomic Energy Act of 1954.as amended,and the regulations in Title la,
Code of Federal Regulations.Part 40,the activity is subject to statutory
licensing provisions administered by the U.S.Nuclear Regulatory Commission.Energy Fuels Nuclear,Inc.submitted its application for a Source MaterialLicenseonFebruary6.1978.The application is being considered for
approval under the applicable laws and regulations.
Adraft environmental statement (DES),copy attached.relating to the
proposed issuance of the Source Material License was issued in December
of 1978.The DES provides a description of the proposed project and an
assessment of the environmental impacts.Comments were requested and
received from various agencies of the federal government,agencies of the
state and local governments.and interested individuals.The target date
for issuance of the final environmental statement (FES)is May 15.1979.The area of the proposed mill lies within an archaeological district whichhasbeendeterminedtobeeligibleforinclusion1ntheNationalRegister
of Historic Places.Adescription of specific sites which will be
affected by the project is set forth in reports issued by the DivisionofStateHistory.State of Utah.The reports are attached hereto as
Exhibits B. C.and D.
The opinion of the Utah State Historic Preservation Officer (SHPO)con-
cerning the affected sites is stated in letters to the Nuclear RegulatoryCommissiondatedDecember5,1978 and January 4.1979.copies of which are
attached hereto as Exhibits E and .F.
Alternative locations for the proposed project have been considered bytheNuclearRegulatoryCommission.the Utah SHPO and Energy Fuels.The
Utah SHPO.in a letter to the Commission dated January 12,1979.a copyofwhichisattachedheretoasExhibitG.stated that the project site
selected by Energy Fuels will have the least adverse effect onarcheologicalresourcesofanyofthealternativesitesconsidered in the
area.
Aproposal for the contents of a Memorandum of Agreement has been devel-
oped by the Commission ~nd is being forwarded.Sites which can be feasiblyandprudentlyavoidedwillbeavoided.
E-3
er::E:nl
UNITEDSTATES
NUCLEAR REGULATORY COMMISSION
WASHINGTlIN.D.C._
~C;L'J
Enclosures:As Stated
cc:Hr.J.Phillip Keene III
Utah State Historic Preservation Officer
(w/o enclosures)
Advisory Council on
Historic Preservation
Western Office
Review &ComplianceATTN:Hr.Louis S.Wall,ChiefP.O.Box 25085
Denver,Colorado 90203
Gentlemen:
SinCerelY,.//
/~~'d>'C--
Ross A.Scarano.Section Leader
Uranium Recovery Licensing BranchDivisionofWasteManage~nt
Pursuant to 36 CFR 63.3 the U.S.Nuclear Regulatory Commission
Submitted to the Keeper of the National Register a request for adetenninationofeligibilityfortheareaincludedwithinthesite
of the proposed Energy Fuels Nuclear,Inc.,White Mesa UraniumHill,with the exception of the NEl/4 of Section 33.T37S.R22E.(The NEl/4 of Section 33,T37S.R22E has been surveyed but the
significance of the sites has not been determined.)The attachedPreliminaryCaseReportandaproposalforthecontentsofa
Memorandum of Agreement have been prepared and are being submi~ted
pursuant to 36 CFR BOO.Also attached is a.letter from the Utah
State Historic Preservation Officer which contains his concurrenceontheproposal.
[:,,:.~~.[.::2.:)]
(.\.",,"11110(/.....¥~>o.:.~n~0•R~~
'l';..tt"
"..0It••••
__.':A'i,;C:i_h-·
- 3 -
PRELIMINARY CASE REPORT
ENCLOSURES
1.U.S.Nuclear Regulatory Convnission,"Draft Statement Related to theOperationofWhiteMesaUraniumProject,Energy Fuels Nuclear,Inc.,"Docket No.40-8681,December 1978.
2.Exhibit A -Map of the area south of Blanding,Utah.This map
shows the entire White Mesa and surrounding areas.The area surveyedforarchaeologicalsitesisdelineatedbythechecked,heavy line,
This area covers all of the mill site with the exception of the NE~
of Section 33 as well as additional area in Section 32,T375,R22E.This map identifies by legal subdivision (sections)the Districtboundaries.
"__.b'f··...._/~...
,.~'...~...
3.ExhibitB -"Archeological Test Excavations on White Mesa,SanJuanCounty,Southeastern Utah,"by laMar lindsay,May 197B.
Note:The Plot Plan for the White Mesa Uranium Mill is included.
The boundary of the mill site is delineated by the dark'blue lineandtheareafordesignationasanArcheologfcalDistrictis
delineated in pink.The pink line on the Plot Plan corresponds to
the checked line on the map referred to in the description of
Exhibit "A"above.The Plot Plan shows the individual archeo.logical sites.
4.Exhibit C -"Additional Archeological Test Excavations and Inven-
tory on the White Mesa,San Juan County,Southeastern Utah,"by
Asa S.Nielson,January 1979.Photographs are glossy black-and-white,
5.Exhibit D -Report prepared by David Merrill of the Utah StateHistoricalSociety.This report sUlllllarizes the findings of thehistoricsurveyoftheWhiteMesaArea.
6.Exhibit E -Ltr fra.Utah SHPO to NRC,dated December 5,197B.
7.Exhibit F -Ltr from Utah SHPO to NRC,dated January 4,1979.
8.Exhibit G -Ltr from Utah SHPO to NRC,dated January 12,1979.
...
- 2 -
E-4......'.t·....~~."..,~_i;!l\'#.,tjAt./',"ll.\·..".....'
~
Energy Fuels has agreed to pay the full cost of the data recovery program.
The cost of construction of the project from its inception to t.he date of
the cOl1lll1encement of the operation is to borne solely by the I ""gy Fuels
Nuclear,Inc.The federal government will not contribute to any part oftheestimatedcostoftheproject.
The U.S.Nuclear Regulatory Commission proposes to issue a Source Materiallicense,pursuant to the Atomic Energy Act of 1954,(42 U.S.C.2011ff.,asamended,68 Stat.919),to Energy Fuels Nuclear Inc.in connection with
its White Mesa Uranium Mfll (hereinafter referred to as the "project")
located approximately five (5)miles south of Blanding,Utah.
Energy Fuels Nuclear,Inc.has requested technical assistance from the
Division of State History,State of Utah,in the identification,protec-
tion and management of cultural resources.This assistance has beenprovidedintheformofculturalsurveysandexcavationsonthelands
involved in the project (project site).Those activities revealednuneroussitesofculturalsignificance.(See Exhibits B,Cand D.)
Accordingly,the Secretary of the Interior was requested to make adeterminationofeligibility.The resulting determination,as set forth in
Exhibit E,is that the area delineated in Exhibit A constitutes a district
which is part of sane as yet undefined larger Archeological Oistrict
eligible for inclusion in the Nationll Register of Historic Places.
The U.S.Nuclear Regulatory Commission in consultation with the Utah
State Historic Preservation Officer,has determined that the land-
modifying operations associated with the licensed activities (hereinafterreferredtoas"undertaking")could have an adverse effect upon the
property and pursuant to Section 106 of the National Historic Preserva-tion Act of 1966 (16 U.S.C.470F,as amended,90 Stat.1320),theU.S.Nuclear Regulatory Commission has requested the comments of the
Advisory touncil on Historic Preservation (hereinafter referred to as the
"Councfl")•
Pursuant to the regulations for the"Protection of Historic and Cultural
Properties"(36 CFR Part 800),the Utah State Historic Preservation
Officer and representatives of the Advisory Council on Historic Pre-
servation,and the U.S.Nuclear Regulatory Commission have consulted andreviewedtheundertakingtoconsiderfeasible.and prudent alternatives to
avoid,satisfactorily mitigate,or minimize the adverse effect.EnergyFuelsNuclear,Inc.was invited to participate in the consultation.
In the light of such consultation,the Commission agrees that it will
take the following actions:
f.When it is not feasible to avoid a site designated "Eligible"
in Table A,the licensee shall institute a data n"overy
program with respect to the site which the CommiSSion determines
will satisfactorily mitigate any adverse effect.
d.Condition c,above,will apply to lands associated with theundertaking,but which have not currently been identified.e.g.,
to borrow areas outside the current project boundaries,with
the exception that the results of surveys and testing may be
reported to the Commission after December 31,1979.
e.The licensee shall avoid any site designated "Undetermined"
in Table A.
2
.,-;.i-i"~':':',i·
1.If the Commission issues a license for the undertaking,it will
include conditions similar to the following therein:
a.The licensee shall avoid by project design where feasiblethesitesdesignated"Eligible"in the attached Table A.
Sites that will ultimately be located within 100 feet of
the perimeter of the reclaimed tailings impoundment area are
considered unavoidable and shall be recovered through
archeological excavation.
b.The licensee shall conduct testing as required to enable theCommissiontodetermineifthosesitesdesignated"Undetermined"
in Table A are of significance warranting their redesignation as
"Eligible."This action by the licensee will be completed byJanuary1,1981.In all cases such testing will be completed before
any aspect of the undertaking affects a site.
c.The licensee shall conduct archeoloQjc~1 and historic
surveys and testing on the NEI/4 of'Seclion 33,T37S,R22E toidentifysuchadditionalsitesasmaybelocatedthereandto
enable the Commission to evaluate their significance.The
results of surveys and testing shall be reported to the
Commission no later than Dec~nber 31,1979.The licenseeshallavoidanysitewithinthisareauntiltheCommission
has reviewed the licensee's report and has advised the
licensee of its determinations.If the Commission,uponreview,amends Table A to include additional sites,the
licensee shall take such action with respect to such additionalsitesasmayberequiredforthesitesthathaveinitially
been designated.
E-5
05/01/79
/t~Li.."<i\,-",,ik.(;riI
.!.;:i<,:~·"j-d,,";-./;«;{,,,~i::f~L.~'
PROPOSAL FOR THE CONTENTS OF A
MEMORANDUM OF AGREEMENT
.-,;c{l-:Ui>:;;'.-··
Concerning the Mitigation of Adverse Effect at the
White Mesa Project Millsite
<••,-;_,~....,..r".
I I r--
a
....
'"
'"...o~-
'"po,.-
'"...o....
'"...
m~~NM~~~M~oo~mON~m_M~OO~oooooommmmmOOONNMMMM~~qm~MMMMMMMM~~~~~~~~~~~~~~w~~~~~~~~~~~~w~~~~w~~
O'lmOMUl\O.......~mO_~C:OUlq~~O_~~O~M~~~~~~~~~~~~rooooommm~o~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
\O ......C:OONUl\O .....NM ......NM~O'lO_NM'¢\OmO_N~~~~:::ffi~~~~~~~~~~~~~~~ffi~~~\O'Ot.O'O\Ot.O'O\Ot.Ot.O\O ~......
~~~~g~~~~~(W"')(Y)MC"'1<1l:;ttO'O ......t,Q\O\0\0 \0\0\0\0\0 to..............
LO \0cc C\I '¢lIllD0\0 _C\J M qo U1\0mCOOOOlO'lo,\mmLnUllOI.llUl............,o\O\O\Ot.O\O\C,o..............................C:OC:O...........................................................................................
\O-NMmo_CX)mO_N\O......mO_NM'¢U1\OC:O_M~'Oc:oooc:ommmO'lO'lOOOaO_NNNNNNNNMC"'lM~~~~~~~~~~~~~~~~~~~~~~~~~~
'"'"N...
~N...
0>
w,c::oz:
0>
..
:0
i:j I ."'"N...
CIl.....;n..
:0
CIl~.~'"'"..c:'E
~..'"c::::>
CIl.....;n
...u..'r')eQ.
'"VI;l.....
.c::>:...c:...
il 0...
'".....'"Q;""CIl.....
.~'"';u'0,
0
'0...c:u~..:
E-6
g.The Commission may amend Table A,with the consent of thelicensee.without amendment to this license.The licensee's
failure to object within 10 days after the Commission amends
Table A in writing shall be deemed to constitute itsconsent.
h.The licensee shall cooperate with the Commission in the develop-
ment and implementation of a monitoring program with respect to
the preservation of cultural resources.The licensee shall have
obtained the approval of the Commission with respect to this programbeforeinitiationofground-disturbing activities.The planshall,alllOng other thIngs.include provision for (1)the presence
during specified operations of an archeological contractor satis-
factory to the C~ission and (2)appropriate action.including notice
to the Comuission and the SHPO Ind suspension of ground disturbing
activities.upon discovery of preViously unidentified cultural resources.
An archeological contractor acceptable to the SHPO and meeting the
minimum standards for a principal investigator as specified by the
Secretary of the·lnterior will be considered satisfactory to theCommission.
3
i.Thelicensee shall recover through archeological excavation all
"Eligible"sites listed in Table Awhich are located in borrow
areas.stockpile storage areas and construction areas.Recovery
of all sites will be completed no later than December 31,1982,
with sites in the area of the first three tailings impoundmentcells(the two evaporation cells and the first tailings cell)
being recovered first.
j.The licensee shall have the.archeological contractor specify
the layout of haul raods.i.e••to best avoid sites.andshallobtaintheapprovaloftheCommissionforthislayoutpriortoearthmovingactivities.
k.The licensee shall provide the additional documentation requiredtoobtainadeterminationofeligibilityforthe"Earth Oam".
"Range War Site","Kunen Jones Home"."Posey War Si tes".and"White Mesa COIII11Unity"cultural sites prior to October I,1979.
If the Earthen Dam is determined to be "Eligible".the licenseeshallensurethattheEarthenDamisrecordedpriortoits
demolition or alternation so that there will be a permanentrecordofitsexistence.Energy Fuels Nuclear.Inc.,for
the NRC.will first contact the Historic American EngineeringRecord(HAER).Heritage Conservation and Recreation Service
(Department of the Interior.Washington,D.C.20243;telephone[phone])to determine the level of documentation
required.All documentation must be accepted by the HAERpriortodemolitionorexcavation.
·,:·jdI>,::Y~~:.,··,~::~";,Y,t'),:,:,,,,·~·-
It~~.~~](~~_~~~-::]rc:~~:~]r~=.:~~~,[f_'~~_:j r'''-~~~~f~~--~~~~rrr;~~~'r-'~'~~;~'l ~~C·,I.c_~'~r~~'~--~'~4 :-:~~:~~~
-.~
2.The Commission will review all determinations of the StateHistoricPreservationOfficerwithrespecttositeswhosestatus(eligibility)has to date been found to be "undetermined"or whicharesubsequentlyreportedtotheCommissionasar~sult of surveys
or discovery during the conduct of the undertaking.If theCommissionconcurswiththedeterminationsoftheSHPO.the
Commission will take the indicated administrative action (i.e.•amend TableA.as referred to in the license conditions).If the
Commission does not concur with the determinations of the SHPO.
it will request the comments of the Council before any adverse
effects upon such sites are permitted.
3.The Commission will consult with the SHPO with respect to any
data recovery program to be undertaken by the licensee to mitigate
adverse effects and with respect to the monitoring program which the
licensee will be required to implement.If the Commission concurs
with the recommendations of the SHPO.it will require the licensee to
institute programs in accordance therewith.Otherwise.the
Commission will request the comments of the Council before any
adverse effects upon the affected sites are permitted.
4.The Commission will consult with the SHPO with respect to the layout
of haul roads prior to giving its approval to any request of thelicenseewithrespectthereto.
5.The Commission will exercise its inspection and enforcement
authority in good faith to assure that the activities of the
licensee are carried out in accordance with its license and the
provisions of this Agreement.
6.The Commission will submit to the Keeper of the National Register
a request to expand the area of the Archeological District toincludetheNEI/4 of Sectlon-33.T37S.R22E.when initial deter-
minations have been made concerning the significance of individual
sites within that area.
[-__-.:.J It:~--:J
5
E-7
PROPOSAL FOR THE CONTElITS OF A
MEMORANDUM OF AGREEMENT-
ENCLOSURES
1.Exhibit A -Map of the area south of Blanding,Utah.This map
shows the entire White Mesa and surroundtng areas.The area surveyed
for archaeological sites is delineated by the checked,heavy line.
This area covers all of the mill site with the exception of the N[~
of Section 33 as well as additional area in Section 32,T37S,R22E.
This map identifies by legal subdivision (sections)the Districtboundaries.
2.Exhibit B -"Archeological Test Excavations on White Mesa.San
Juan County,Southeastern Utah,"by LaMar Li ndsay,~lay 197B.
Note:The Plot Plan for the White Mesa Uranium Mill is included.
The boundary of the mill site is delineated by the dark blue lineandtheareafordesignationasanArcheologicalDistrictis
delineated in pink.The pink line on the Plot Plan corresponds to
the checked line on the map referred to in the description ofExhibit"A"above.The Plot Plan shows the individual archeo-
logical sites.
3.Exhibit C -"Additional Archeological Test Excavations and Inven-
tory on the White Mesa,San Juan County,Southeastern Utah,"by
Asa S.Nielson,January 1979.'Photographs are glossy black-and-white.
4.Exhibit D -Report prepared by David Herrill of the Utah State
Historical Society.This report summarizes the findings of thehistoricsurveyoftheWhiteMesaArea.
5.Exhibit E -Ltr f"om Keeper of the National Ilegister.National
Park Service.001 to IIRC.dated April 26.1979.
NOTE:Exhibits A.B.C and Dare common to both the Preliminary CaseReportandtheproposalforaMemorandumofAgreement.
STATE Of l'TAH
~.
DEP.-\RT:\IEXT Of
DEVELOP:\IEXT SERVICES
J.Phillip Keene 1\1
Executive Director
104 State Capitol
Salt Lake City,Utah 84114
Telephone:[phone]
Scott ~.1.~Iatheson,Governor
May 3,1979
Mr.Ross A.Scarano,Section Leader
UranitllJ Mill Licensing Section
Fuel Processing and Fabrication Branch
Division of Fuel Cycle and
Material Safety
U.S.Nuclear Regulatory Ccmnission
Washington,D.C.20555
HE:Proposal for the Contents of a HaJDrandum of Agreanent
White Mesa,San Juan County
Dear Mr.Scarano:
If you have any questions,please contact Wilson G.Martin,
801-533-6017,or Jim Dykman,801-533-6000.
Sincerely,
~~~'Ph~li;Keene III
Executive Director
and
State Historic Preservation Officer
The staff has revi~the proposed meJDrandtlll of agreanent.
The meJDrandum of agreanent will ~atisfy the necessary
mitigation under the requiranents of 106 review procedures.
However,the a.grearent does call for scme unnecessary miti-
gation by the developer.We would like to review these
items individually at a later date.
E-8
cc:Energy FUels Nuclear,Suite 900,'Ibree Park Central,
1515 Arapahoe Drive,Denver,CO 80202
WGf:jr:B74ffiJ
PS:Table A soould be amended to list sites 6391, 6436,6437,
6445,6686,6697,6757,7696 in Eligible colum,instead
of Undetennined.The table is correct to the best of our
knowledge except for the above change.
DIVISION Of:INDUSTRIAL PROMOTION .'TRA\'EL OEVELOP~1ENT.EXPOSITIONS·STATE HISTORY.FINE ARTS
Appendix F
RADON RELEASE DURING MILLING OPERATIONS
F-3
APPENDIX F.RADON RELEASE DURING MILLING OPERATIONS
F.1 ORE PADS
The radon-222 release from the ore pad can be estimated by the following data and assumptions:
Area of the ore pads (A)2.43 X 108 cm2 (6 acres)
Thickness of ore piles (t).670 cm (22 ft)-maximum case;and 305 cm
(10 ft)-equilibrium case
Radium-226 concentration (eRa)423 pCi per gram of ore
Density of ore (p)1.6 g/cm3
Decay constant of radon-222 (A)2.1 x 10-6 sec-1
D Iv (diffusion coefficient/void 2.5 x 10-2 cm2/sec
efraction)
Radon emanation coefficient (generic 0.2
value given.actual ore from numerous
mines may vary widely)(E).
The radon-222 flux (J)at the surface of an area with a finite depth of uniform material may
be estimated:
where the symbols are as defined above.
The hyperbolic tangent factor corrects the infinite thickness radon 'flux for the thickness
of the pile.Substituting into this correction factor for a 670-cm (22-ft)pile and a
305-cm (10-ft)pile reveal that the radon release is reduced by 9 x 10-~and 0.75%respectively.This reduction is negligible so the piles may be considered infinitely
thick.
The radon flux (J)for an infinitely thick pile is given by
Substitution of the above values gives
J =(423 pCi/g)(1.6 g/cm3)(O.2)"(2.1 x 10-6 sec-1)(2.5 x 10-2 cmz/sec)=0.031 pCi/w·sec •
F-4
F.2 TAILINGS IMPOUNDMENT
423 pCi/g
1.6 g/cm 3
0.2
5 x 10-2 cm2/sec (ref.1.Table 9.29)
1 x 10-2 cm2/sec (ref.1.
Table 9.29)
5.7 x 10-6 cm2/sec
(ref.1.Table 9.29)
Radium concentration (eRa)of solids
Density
Emanation factor
D /v for dry tailings (8%moisture)e
De/V for moist tailings
(15%moisture)
De/V for saturated tailings
(37%moisture)
This value applied to botn the maximum and equilibrium stockpiles.as the flux is a function ofarearatherthanthickness.
JA =(0.031 pCi/cm2 ·sec)(2.43 x 108 cm2)=7.54 x 106 pCi/sec =7.54 ~Ci/sec =240 Ci/year
For fill operations and prereclamation conditions the impoundment is assumed to have areas of
saturated tailings.areas of moist tailings.and areas of relatively dry tailings.The
following data and assumptions were used to determine radon-222 release rates from thedifferentareas.
Multiplication by the area gives the release rate:
J =J exp [-~YJ../(D /v).:J:.],P ~e 'Z.'Z.i=l
The "infinite thickness"flux is calculated by the expression
J..=CRapE "Y.>.(D/V)
Substitution of the above values gives
J...dry tails =439 pCi/m2-sec.
J...moist tails =196 pCi/m2-sec.and
J...saturated tails =4.7 pCi/m2-sec.
Based on the conservative assumptions of 40 ha (100 acres)dry tails,40 ha (100 acres)moist
tails.and 20 ha (50 acres)saturated tails,the annual radon-222 release from the tailings
impoundment system is calculated to be 8064 Ci.Radon releases from ponded areas are
negligible.Radon-222 releases from dry,moist,and saturated tails are 5552 Ci/yr,
2482 Ci/yr,and 30 Ci/yr,respectively.
F.3 TAILINGS COVER REQUIREMENTS
The folloWing formula was used in calculating the reduction in radon flux produced by theproposedcoversystem:
F-5
where
i the ith layer of a multicomponent cover (n is the number of components)•
A decay constant for radon-222 (2.1 x 10-6 sec-1) •
x =thickness of cover layer (cm)•
J =resulting radon flux after attenuation through cover (pCi/m2 'sec)
J =radon flux at the surface of the tailings (pCi/m2·sec).p
The cover proposed by the applicant consists of 61 cm (2 ft)of compacted clay overlain
by 1.2 m (4 ft)of silt-sand soil,a 1.8-m (6-ft)layer of rock overburden material,and
15 cm (0.5 ft)of topsoil.The estimated D~V for these materials are 1.2 x 10-3 cm2/sec
for the clay and 2.2 x 10-2 cm2/sec for the rest of the cover.2 The dry tailings
(8%moisture)infinite thickness flux of 439 pCi/m2 ·sec is assumed to model the 10ng-
term conditions for the system.Substitution of these values into the equation yields
J =(439 pCi/m2 ·sec)exp {-/(2.1 x 10-6 )/(2.2 x 10-2)(320)-1(2.1 x 10-6)/(1.2 x 10-3)(61)}
(439 pCi/m2 ·sec)(3.42 x 10-3)
1.5 pCi/m2'sec •
As reported in the Supplemental Environmental Report 3 the average background flux is
0.64 pCi/m2 ·sec.Because of its thickness,the silt-sand material is expected to contribute
background f1ux,so the total radon flux would be essentially twice background.The proposed
cover is adequate for areas where there is no significant accumulation of slimes.The
applicant's proposed operating plan should prevent excessive sand-slimes segregation.
nI ILJ
['
[--
I
iII
~~
F-6
REFERENCES FOR APPENDIX F
1.R.E.Blanco et a1.,Correlation of Radioaative Waste Treatment Costs and the Environ-
mental Impaat of Waste Efj1uents,vol.1,Report ORNL/TM-4903,Oak Ridge National Labora-
tory,Oak Ridge,Tenn.,May 1975,Table 9.29.
2,Energy Fuels Nuclear,Inc.,Supplement to the Proposed Tailings Disposal System,White
Mesa Uranium Projeat,Oct.16,1978.
3.Energy Fuels Nuclear,Inc.,Supplemental Report,Baseline Radiology Environmental Report,
White Mesa Uranium Projeat,San Juan County,Utah,Sept.26,1978,p.15.
Appendix G
.CALCULATIONS OF TAILINGS PILE GAMMA RADIATION ATTENTUATION
[J
fi
.r-l
lJ
G-3
APPENDIX G
CALCULATIONS OF TAILINGS PILE GAMMA RADIATION ATTENUATION
Assuming soil to be composed mainly of SiO z,the mass attenuation coefficient for 1-2 MeV
gamma ray is 0.0518 cmZlg.1 (Most of the dose rate from a typical natural emitter is in
this range.Z)Assuming the gamma radiation from the uncovered tailings pile to be approxi-
mately 12 R/year (same as for Bear Creek project)and the bulk density of the soil to be
1.5 g/cm 3 ,the effect of the 3.28 m (10.75 ft)of soil materials proposed (excluding the
shale layer)would reduce the gamma radiation to approximately 10.3 pR year.
III =exp[-(~en/p)px]=exp[-(0.0518 cmZlg)(1.5 g/cm 3)(328 cm)]=8.5 x 10-lZ ;o
I =(8.5 x 10-lZ)(12 R/year)=10.3 pR/year .
The background radiation dose as measured by the applicant3 is 77.7 mR/year.The'gamma
radiation from the deposited tailings would be insignificant compared to the natural
gamma background.
REFERENCES FOR APPENDIX G
c
1
2
3
>.,.
;~E"~;
U.S.Department of Health,Education,and Welfare,Radiological Health Handbook.U.S.
Government Printing Office,Washington,D.C.,January 1970,p.139.
H.May and L.D.Marinelli,"Cosmic Ray Contribution to the Background of Low Level
Scintillation Spectrometry,"Chap.29 in The Natural Radiation Environment.J.A.S.Adams
and W.M.Lowder,Eds.,University of Chicago Press,Chicago,1964.
Energy Fuel s Nucl ear,Inc.,Supplemental Report.Baseline Radiology Envir0l111Uintal.Report.
White Mesa Uranium Project.Sept.26,1978,p.27.
Appendix H
ATMOSPHERIC DISPERSION COEFFICIENTS
H-3
APPENDIX H
ATMOSPHERIC DISPERSION COEFFICIENTS
Tables H.l through H.4 list x/Q (sec/m 3 )values calculated by the staff using AIRDOS-II,
a FORTRAN computer code,l and onsite meteorological data supplied by the applicant.2
L
L
to:
~t.2~'ll.:'-o ~
tot...!.,,
"
L
2400
1 79E-7
1.33E-7
7.67£-8
2 74E-7
1.ooE-7
6 64E-8
7.50£-7
1.69E-7
1.66E-7
6.57E-7
2.59£-7
2.19E-7
1.37E:§
2.56E-7
3.28E-7
1.61E-7
1.39E-7
)33E-7
7 99E-8
1.05E-7
2400
4.91E-8
5.58E-8
4.72E-7
1 19E-7
1 85E-7
4.11E-7
8 36E-7
1.68E-7
2.47E-7
1.49E-7
2,01E-7
1.18E-7
1720
3.23E-7
!8E-7
27E-7
3;43E-7
2.53E-7
2.69£-6
3.ZlE-7
5.28E-7
1.91E-7
3.07E-7
1.46E-6
4.22E-7
4.97E-7
1.28E-6
4.94£-7
6.27E-7
1720
2 66E-7
2.g0E-7
2 54E-7
1.52E-7
9.38E-8
1.07E-7
7 27E-7
3.57E-7
9.28E-7
3'.27E-7
1.66E-6
7 69E-7
8.09E-7
2.25E-7
4.71E-7
3 87E-7
1400
1400
3.74E-7
4.77E-7
5.10E-7
2.82E-7
2.21E-7
4.78E-7
2.17E-6
4.02E-6
1.87E-7
7.85E-7
7.41E-7
1.92E-6
7.30E-7
6.28E-7
9.30E-7
2.25E-7
2.96E-7
3.76E-7
3 38E-7
1.60E-7
1.39E-7
5.34E-7
2,51E-6
1.40E-6
4 91E-7
1.22E-6
4 32E-7
3.34E-7
5 65E-7
6.99E-7
'3.96E-7
1095
2.95E-7
7.60E-7
4.48E-7
7.60E-7
5.93E-7
1095
8.13E-7
3.06E-6
3.53E-7
3.45E-6
6.42E-6
9.97E-7
1.24E-6
1.18E-6
1.16E-6
7.17E-7
1.47E-6
6,glE-7
3.59E-7
4.72E-7
2.58E-7
6.35E-7
2.23E-7
5.42E-7
4.09E-6
8.59E-7
2.27E-6
7.93E-7
1.98E-6
6.96E-7
5.33E-7
1.12E-6
9.01E-7
Distance from effluent (m)
Oistance from effluent (m)
940
940
7.93E-7
1.09E-6
3.95E-7
4.75E-7
5.99E-7
1.02E-6
4.11E-6
4.63E-6
8.63E-6
1.67E-6
1.02E-6
9.58E-7
1.34E-6
1.58E-6
1.54£-6
1.9ZE-6
6.34E-7
8.55E-7
6 09E-7
3.49E-7
4.82E-7
3.01E-7
7.33E-7
5.62E-6
1.17E-6
2.72E-6
3.11E-6
1.08E-6
7,20E-7
9.46E-7
1.51E-6
1.21E-6
1.54E-6
1.43E-6
1.11E-6
790
2.34E-6
8.42E-7
5.53E-7
6.70E-7
2.22E-6
5.78E-6
1.22E-5
1.44E-6
6.49E-6
2.17E-6
1.88E-6
2.77E-6
1.34E-6
6.88E-7
9.05E-7
1.23E-6
5.03E-7
790
1 16E-6
4.32E-7
1.06E-6
4.54E-6
1.69E-6
8.24E-6
3,98E-6
1.57E-6
1.37E-6
2.16E-6
1.03E-6
1.73E-6
2.34E-6
3.91E-6
6.61E",
335
2.94E-6
5.10E-6
7.10E-6
2.42E-5
4.59E-5
2.18E-5
9.24E-6
6.05E-6
7.52E-6
8.61E-6
5.57E-6
9.58E-6
1.20E-5
6.65E-6
2.54E-6
335
5.19E-6
3.94E-6
7.13E-6
3.00E-6
6.34E-6
5.31E-5
2.54E-5
H-4
1.04E-5
2.88E-5
9.82E-6
8.40E-6
6.09E-6
1.27E-5
1.00E-5
Table H.2.Annual average x/Q (sec/1l3)at various distances for the 16 CClllpaSS
directions.release height 6 III
Table H.1.Annual average x/Q (sec/m3)at various distances for the 16 compass
directions.release hei9ht 1 m
W
Sli
S
N
NW
SE
ESE
E
WNW
SW
NE
NNE
NE
N
NNW
WNW
NIl
ENE
E
WSW
W
ESE
SSW
S
SSE
SE
NNW
WSW
ENE
SSE
Toward
Wind
NNE
ssw
Toward
Wind
r
i
Wind
H-5
Table H.3.Annual average x/Q (sec/m3)at various distances for the 16 compass
directions,release height 13.7 m
Oistance from effluent (m)
Toward
N
NNW
NW
WNW
w
WSW
SW
SSW
S
SSE
S£
ESE
£
£NE
NE
NNE
335
3.92£-6
2.81£-6
3.67£-6
2.22£-6
1.29£-6
9.58£-7
.2.15£-6
2.21£-6
5.82£-6
3.11£-6
3.25£-6
1.76£-6
2.10£-6
2.04E-6
5.30E-6
4.74E-6
790
1.19£-6
8.78£-7
1.13£-6
4.76£-7
3.83£-7
9.47£-7
1.37£-6
6.28£-6
3.36£-6
3.02£-6
1.25£-6
1.12£-6
8.95E-7
1.94E-6
1.60E-6
940
9.31£-7
6.84i-7
8.80£-7
5.25£-7
3.84£-7
3.11£-7
7.85E-7
1.18£-6
5.70£-6
3.05£-6
2.73£-6
1.10£-6
9.61E-7
7.38E-7
1.57E-6
1.27E-6
1095
7.43£-7
5.45E-7
7.01£-7
4.16£-7
3.13£-7
2.55£-7
6.51£-7
1.00E-6
4.95E-6
2.65E-6
2.37£-6
9.36£-7
8.11£-7
6.09E-7
1.28E-6
1.02E-6
1400
5.06£-7
3.71E-7
4.77£-7
2.82£-7
2.18£-7
1.79£-7
4.63£-7
7.32£-7
3.70£-6
1.97£-6
1.76£-6
6.88£_7
5.88£-7
4.32E-7
8.96£-7
7.09E-7
1720
3.61E-7
2.64E-7
3.39E-7
2.00E-7
1 58E-7
1.30£-7
3.39£-7
5.43E-7
2.78£-6
J.,48£-6
1.32E-6
5.12£-7
4.35£-7
3.16E-7
6.50E-7
5.10E-7
2400
2.02£-7
1.48£-7
1.90£-7
1.12£-7
8 m-8
7 m-8
1.94£-7
3 16E-7
1.63£-6
8.73£-7
7.75£-7
2.99£-7
2.52£-7
1.82£-7
3.70E-7
2.89E-7
Wind
Table H.4.Annual average x/Q (sec/m3)at various distances for the 16 compass
directions,release height 27.4 m
Distance from effluent (m)
Toward
N
NNW
NW
WNW
W
WSW
SW
ssw
S
SSE
SE
ESE
E
ENE
NE
NNE
335
2.0~-6
1.35E-6
1.82E-6
1.07£-6
5.68£-7
3.95E-7
7.43E-7
5.82E-7
1.02E-6
5.01£-7
7.49E-7
4.85E-7
7.67E-7
7.59E-7
2.45E-6
2.28£-6
790
8.07E-7
5.88£-7
7.62E-7
4.63E-7
2.76E-7
2.07E-7
4.74E-7
5.13E-7
1.50£-6
7.99E-7
7.94E-7
4.12E-7
4.69E-7
4.47E-7
1.12E-6
9.86E-7
940
6.38E-7
4.69i-7
6.06E-7
3.69E-7
2.27E-7
1.73E-7
4.05E-7
1.57E-6
8.43E-7
.8.01E-7
3.9OE-7
4.15E-7
3.82E-7
9.15E-7
7.96E-7
1095
5.20£-7
3.84E-7
4.95E-7
3.01E-7
1.91E-7
1.48E-7
3.53E-7
4.38E-7
1.61E-6
8.64E-7
8.03£-7
3.71E-7
3.74E-7
3.32E-7
7.72E-7
6.62E-7
1400
3.72E-7
2.76E-7
3.55E-7
2.15E-7
1.44E-7
1.14E-7
2.79E-7
3.75E-7
1.56E-6
8.33E-7
7.58E-7
3.29E-7
3.11E-7
2.62E-7
5.83E-7
4.88E-7
1720
2.81E-7
2.09E-7
2.68E-7
1.61E-7
1.13E-7
2.27E-7
3.23E-7
1.44E-6
7.72E-7
6.97E-7
2.90£-7
2.64E-7
2.12E-7
4.60E-7
3.78£-7
2400
1.75E-7
1.30E-7
1.67E-7
9.93E-8
7.43E-8
6.04E-8
1.56£-7
2·37E-7
1.15E-6
6.12E-7
5·48E-7
2.19E-7
1.91E-7
1.45E-7
3.04E-7
2.44E-7
H-6
REFERENCES FOR·APPENDIX H
1.R.E.Moore,The AIRDOS-II Corrrputer Code for Esti~ting Radiation Dose to Man from
Airborne RadionucZides in Areas SU1'1'ounding NucZear FaciZities,Report ORNL-5425,Oak Ridge National Laboratory,Oak Ridge,Tenn.,1977.
2.Dames and Moore,"Supplemental Report,Meteorology and Air Quality,Environmental Report,
White Mesa Uranium Project,San Juan County,Utah,for Energy Fuels Nuclear,Inc."Denver,Sept.6,1978.
I
I
I
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r
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r'
L
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r
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r'~.L
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11"L
APPENDIX I
RADON DOSE CONVERSION FACTORS
1-3
APPEIlDIX I.RADON DOSE CONVERSION FACTORS
The basis upon which the NRC staff has relied for its radon daughter inhalation dose conversion
factor consists of the following major ccrnponent carts:
1.The indoor working level (ilL)concentration resultini from an outdoor radon-222concentrationof1pCi/m3 is approximately 5.0 x 10·ilL;
2.The number of cumulative working level months (IILM)exposure per year for an
average individual at a constant concentration of one ilL is 25 WLM/yr;and
3.The cOl1ltlitted dose equivalent to the bronchial epithel1l111 (basal cell nucleiofsegmentedbronchi)per unit IILM exposure is 5000 mrem (5 rem).
These component parts enter into the following equation which yields the radon-222 inhalation
dose conversi on factor used by the staff:
5.0 X 10-6 ilL 25 WLM/yr 5000 mrem 0.625 mrem/yrx x1pCi/m3 ilL IILM 1 pCi/m3
Each of the three ccrnponents identified above derive fran sources and data identified below:
t.5 x 10-6 WL per pCi/m3 of radon-222 is established by the assuNd indoor air
concentration ratios for radon-222,polonium-21S,lead-214,and bisRlUth-214
of 1.0/0.90/0.51/and 0.35.These concentration ratios and the derived conversion
factor are representative of conditions in a reasonably well ventilated stnlcture
(Refs.1 and 2).
2.25 IILM/yr per ilL concentration derives from the assUllption that an average
individual's average breathing rate will be about 50 percent of that of a
working miner.A IILM is defined,in terms of exposure to a working miner,
as one month's occupational exposure to a one-ilL concentration.This assUlled
breathing rate would result in an average individual receiving about 0.5 IILM
as a result of the same 1ength of exposure to air at a one-ilL concentration.
The following relationship applies:
(S760 hrs/yr)x 12 IILM/yr-IIL x 0.5 •25 IILM/yr-llL40hrs/wk x 52 wks/yr
3.Five rem/IILM is the value derived fran applying a quality factor (QF)of 10
for alpha radiation,to convert fran rad to n!II (Refs.I,2,and 3),to the
figure of 0.5 rad/IILM as reported in the SEIR Report (Ref.3,page 148).
The staff considers the above basis for its radon-222 inhalation dose conversion factor to be
both sound and reasonable.The staff acknowledges that radon dosillltl'y is extretRly cOllPlex
and strongly influenced by ass~environnental and biological conditionil.In view of thelargevariationsinducedbyratherslllilllchangesintheasslllM!d free-ion fraction,relativeequilibrillll,thickness of the intervening tissue and mucous layers,etc.,the staff"asendeavoredtousephysical,envirol1llental,and other data reasonably representative of averageconditions.
IllfelWlCes for Appendix I
1."Potential Radiological IIIIPKt of Airborne Releases and Direct G.-Radiation to Individua15
Living Hear Inactive Uranillll Mill Tailings Piles,"U.S.EPA,EPA-520/1-76-OO1,January 1976.
2."Environmental Analysis of the UraniUlll Fuel Cycle,Part I--Fuel Supply,"U.S.EPA,
EPA-520/9·73-003·B,OCtober 1973.
3."The Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"Report of the
Advisory CoaIIlittee on the Biological Effects of Ionizing Radiations (BEIR),National ~
of Sciences -National Research Council,November 1972.
"-
.::\'",,-,'
NRC FORM 335 1.REPORT NUMBER IAwgnea by DOC)
U.S.NUCLEAR REGULATORY COMMISSION(7·77)NUREG-0556BIBLIOGRAPHICDATASHEET
4.TITLE AND SUBTITLE (Add VOlume No.,ifl/PPrOf'riac.)2.(Leave blank)
Final Envi ronmental Statement related to operation of
White Mesa Uranium Project,Docket No.40-8681 3.RECIPIENT'S ACCESSION NO.
7.AUTHOR IS)5.DATE REPORT COMPLETED
MONTH I YEAR
9.PERFORMING ORGANIZATION NAME AND MAILING ADDRESS (Include Zip Code)DATE REPORT ISSUED
U.S.Nuclear Regulatory Commission MONTH I YEAR
Mil V lQ7QOfficeofNuclearMaterialSafety&Safeguards 6.(LewB blank)Washington,D.C.20555
8.(Lealie blank)
12.SPONSORING ORGANIZATION NAME AND MAILING ADDRESS (Include Zip Code)
10.PROJECT/TASK/WORK UNIT NO.
11.CONTRACT NO.
Same as above.
13.TYPE OF REPORT IPERIOO cove Reo (lnclusill'dllr.s)
Final Environmental Statement
15.SUPPLEMENTARY NOTES 14.(LB_blllflk)
16.ABSTRACT (200 words or Itlss)
A Final Environmental Statement for Energy Fuels Nuclear,Inc.related to issuance
of a source material license for the White Mesa Uranium Project to be located in
San Juan County,Utah (Docket No.40-8681)has been prepared by the Office of
Nuclear t~terial Safety and Safeguards.This statement provides (1)a summary
of environmental impacts and adverse effects of the proposed action,and (2)a
consideration of principal alternatives.Also included are comments of governmental
agencies and other organizations on the Draft Environmental Statement for this project
and staff responses to these comments.The NRC has concluded that,after weighing
the environmental,economic,technical,and other benefits of the White Mesa Uranium
Project against environmental and other costs and considering available alternatives,
the action called for is issuance of a source material license,subject to stipulated
conditions.
17.KEY WORDS AND DOCUMENT ANALYSIS 17..DESCRIPTORS
,
17b.IDENTIFIERS/OPEN·ENDED TERMS
18.•AVAILABILITY STATEMENT 19.SECURITY CLASS (This repon)21.NO.OF PAGES
Release unlimited.20.SECURITY CLASS (Thisp.".J 22.PRICE
S
NRC FORM 335 (7.77)