DRC-2006-001321 - 0901a06880aea731

January 10,2006
Mr. Dane Finerfrock
Division of Radiation Control
Department of Environmental Quality
P.O. Box 144850
Salt Lake City, Utah 84114-4850
RE: International Uranium (USA) Corporation, Source Material License No. UT
1900479: Request for Clarification Related to the RCRA Exemptions
Dear Mr. Finerfrock:
On December 23,2005,I made a Utah Government Records Access and
Management Act (GRAMA) Request for "all correspondence, memoranda, phone notes,
electronic mail, reports, or other agency documents related to the Division of Radiation
Control's determination that: "As stated in Section 1.3, the FMRI material is the result of
natural ore processing, therefore no listed Resource Conservation and Recovery Act
(RCRA) material is presented because it is exempt under 40 CFR 261.4(b)(7)."
That determination is set forth in the November 2,2005, Safety Evaluation Report
for the International Uranium (USA) Corporation White Mesa Uranium Mill, San Juan
County, Utah: In Consideration of an Amendment to Radioactive Source Material
License No. UT 1900479 and Ground Water Quality Discharge Permit No. UGW370004
for the Receipt, Storage, and Processing of Fansteel FMRI Alternate Feed Material, page
8. That determination provides no evaluation of the provisions of 40 CFR 261.4(b)(7) or
an explanation of what exactly the FMRI material is exempt from. There is no
explanation of why, because the FMRI material "is the result of natural ore processing,"
it is therefore exempt under 40 C.F.R. 261.4(b)(7). Additionally, the SER does not
provide any discussion of the characteristic hazardous waste component of the FMRI
material and why the FMRI would or would not be a RCRA hazardous waste because of
its characteristic hazardous waste components. The SER does not reference an
exemption from RCRA other than that found in 40 C.F.R.261.4(b)(7).
In response to the December 23, GRAMA, I received a copy of the Technical
Evaluation Report: Request to Receive and Process Alternate Feed Material from FMRI,
Inc. This Technical Evaluation Report (TER) indicates a date of March 7, 2005. It is
unclear if that date serves only as the date of the International Uranium (USA)
Corporation (IUSA) license amendment application or whether the date is the date of the
TER. If it is only the date of the IUSA application, the TER is undated. I do not
understand why I did not receive the TER when I received the SER. The SER was put
out for public comment; the TER was not put out for public comment. For some
inexplicable reason, the SER does not mention or reference the TER as a document
substantiating the SER.
Dane Finerfrock
January 10,2006
Within the TER there is no discussion of any exemption of the FMRI material
under 40 CFR 261.4(b)(7). The TER does not provide any discussion of or basis for the
determination in the SER that the FMRI material is exempt from RCRA under 40 C.F.R.
261.4(b)(1). Because the TER fails to discuss the RCRA exemption that appears in the
SER, it seems that there is no documentation of the basis for the RCRA exemption
determination in the SER. Apparently, the RCRA exemption determination just popped
up in the SER without any previous discussion within the DRC or any substantiating
documentation.
The TER, atz(C) (pages 2-3), does include a "Determination of whether the feed
material contains hazardous waste." This discussion only addresses whether the FMRI
material contains a listed hazardous waste. There is no discussion in that section of the
TER of whether the FMRI material contains RCRA characteristic hazardous waste.
The TER (at the bottom of page 3) contains a discussion of an exemption from
RCRA. The TER states:
Because the Uranium Material is an ore that contains greater than0.057o
source material, the Uranium Material is exempt from RCRA under 40
CFR 261.4(aXa). In addition, based on the site history, the determinations
by FMRI, and the analysis of IUSA's independent expert consultant,
IUSA has also concluded that even if not exempted from RCRA under 40
CFR 261.4(a)(4), on the application of the Listed Hazardous Waste
Protocol, Uranium Material from the Muskogee facility would not be
listed hazardous waste subject to RCRA.
Here, the TER relies on a different section of Title 40 of the Code of Federal
Regulation for the RCRA exemption than that relied upon in the SER. Again, the
applicable section is not quoted nor is the applicability of that section to the FMRI
material substantiated. There is no discussion about whether, "even if not exempted from
RCRA under 40 CFR 2il.a@)@)," the FMRI material would be a characteristic
hazardous waste subject to RCRA.
There appears to be two separate assertions related to the exemption of the FMRI
material from RCRA-one in the SER and one in the TER. There are some significant
differences between the exemption to RCRA claimed in the SER and the exemption
claimed in the TER. The SER claims that the FMRI material is exempt from RCRA
under Section 40 CFR 261.4(b)(7) because "the FMRI material is the result of natural ore
processing"; the TER claims that the FMRI material is exempt from RCRA under Section
261.a@)@) because the FMRI material is "ore greater than0.l5%o source material." In
the SER the assertion is that the FMRI material is a result of natural ore processing, and
in the TER the assertion is that FMRI material is ore itself. The exemption in Section
261.4@)@) allows for an exemption for the definition of solid waste under RCRA. The
exemption in Section 261.4(b)(7) allows for an exemption from the definition of
hazardous waste. For a material to be a hazardous waste it must first meet the definition
of solid waste.
Dane Finerfrock
January 10,2006
There appears to be a contradiction between the assertions in the SER and the
assertion in the TER related to the exemption of the FMRI material from RCRA. It is
hard to understand how the FMRI material can be "ore" for the purposes of an exemption
from the definition of solid waste under Section 2il.a@)@) and also be material from the
processing of "ore" for the purposes of an exemption from the definition of hazardous
waste under Section 261.4(b)(7).
Without going into the merits of either of the two supposed exemptions at this
time, certain questions are obvious:
l. Which proposed exemption from RCRA does the Division of Radiation Control
(DRC) adhere to-the one in the SER or the one in the TER, or both?
2. If the DRC currently adheres to one or the other of the exemption determinations,
why has the DRC found that the other exemption determination is not applicable to
the FMRI material?
3. What, specifically and particularly, is the factual and legal basis for the RCRA
exemption determination that the Division of Radiation Control currently believes is
applicable to the FMRI material?
I request a response to the questions above. I also request that the DRC refrain
from issuing a final determination on the proposed IUSA license amendment until issues
related to the applicability of RCRA to the FMRI material are resolved.
Thank you for your prompt attention to this matter. If you have any questions
related to this request, please feel free to contact me at 435-259-4734 or
sarahmfields @ earthlink.net.
Sincerely,
Sarah M. Fields
P.O. Box 143
Moab, utah84532
From:
lo:
Date:
Subject:
"Sarah M. Fields" <[e-mail]>
Loren Morton <lmorton @ utah.gov>
121812005 12:01:54 AM
IUSA March 8 Application to Process FMRI Material
Dear Loren,
Thank you for your reply to my request for records.
I have a few question regarding the DRC Safety Evaluation Beport (SER)
for the FansteelAlternate Feed Material, lnternational Uranium (USA)
Corporation (IUSA), White Mesa Uranium Mill, March 8,2005, Application.
QUESTIONS:
1. Has the DRC taken the trouble to look at any NRC records pertaining
to the FMRI, lnc. (subsidiary of Fansteel set up after the Fansteel
bankruptcy to carry out decommissioning of the Muskogee site) facility?
2. On page 3 of the SER it states that the Fansteel facility processed natural
ores from 1960 to 1989. According to NRC records, the facility started
processing in 1956. Why the conflicting dates?
3. The FMRlfacility processed tin slag from internationalsources. ls tin
slag from the processing of tin ores considered to be a "natural ore"?
Based on what?
4. On page 4, it states that the material proposed to be sent consists of
ancillary drummed material, pond surrounding soils, and debris.
ln the IUSA application I find no data pertaining to either the
radiological or non-radiological constituents of the drummed material or
the soils surrounding the ponds.
Why is there no information in the Application and the SER
documenting the radiologicaland chemicalconstituents of the soils
and barreled materials.
5. Ponds 2 and 3 are surrounded by contaminated soils. FMRlwill
be required to clean up this material. How much of the soils surrounding
the ponds will go to White Mesa?
What will be the criteria for determining what surrounding material
will go to White Mesa and what will not?
Since the DRC has no authority over the decommissioning and cleanup
of the FMRI facility, how will the DRC assure that any specific criteria
willbe met?
6. How will IUSA "process" the debris for its source materialcontent?
7. On pageT of the SER there are two tables. The first refers to
Ponds 1 and 2. According to the March I IUSA application and the
discussion in the SER, the ponds in question are Ponds 2 and 3. Why are
they referred to as Ponds 1 and2 in the SER?
8. The table the lists the radiological constituents in Pond 2 (actually
Pond 3) under U-234 lists the Min as 1770 pCilg. Then the Max concentration
is supposedly 1000 pCi/g. Here the minimum is more than the maximum. lf you
,-f,ese?"i
add 1770 (Min) and 1 000 (Max) and divide by 2 you get an average 1 350. Most
likely there is an extra 0, and the Min should be 177. This gives an average
pCi/g of 588 (almost 598, but to get the averages FMRI factored in all
the data points). Seems like the IUSA table was copied into the SER,
but not checked for accuracy.
9. The table at the bottom of page 7 ot the SER compares the FMRI
materialwith the WR Grace, Heritage, and Maywood materials. The WR
Grace materialwas never shipped to the IUSA mill, nor was the
Maywood material. What exactly is the rationale behind comparing
the FMRI materialwith materialthat will never (WR Grace) and
probably will never (Mayrvood) be received, processed, and disposed of
at the mill?
10. IUSA has a Standard Operating Procedure (SOP) for high thorium content
material. They supposedly used this procedure for processing the
Heritage material. There is no mention in the application or the
SER of the use of this SOP. Will IUSA be required to use this
procedure? lf not, why not?
12. ln the application IUSA gives a bit of information regarding the
history of Pond 3. However, IUSA and Ms. Tischler failto mention that
the current Pond 3 consists of an old Pond 3 and a Pond 4, which were
reconfigured. There is no information in the application regarding what
Pond 4 was used for, what happened to the Pond 4 materials, or how
much contamination from Pond 4 there will be in the contaminated
soils.
What exactly went into the current Pond 3? Why was this
information about the existence ol Pond 4 and the reconfiguration
of the ponds left out of the application? Will parts of the old
Pond 4 not part of Pond 3 be part of the contaminated soils sent to
the IUSA mill? Where exactly was the old Pond 4 located?
Don't you think that the DRC should have this information?
lnformation re Pond 4:
"The original Pond 3 was smaller and occupied approximately the eastern
half of its current location. No information was available about whether
this pond was lined. The current Pond 3 was expanded in 1979, encompassing
most of Pond 4, and a synthetic liner was laid down. The areas of Pond 4
that were not incorporated into the new Pond 3 were filled in with soil.
It is not clear whether Pond 4 was lined, or what was done with the waste
contained in it."
Considering that the greatest groundwater contamination at the FMRI site
is down gradient from Pond 3, it is reasonable to conclude that it and
Pond 4 were not lined originally.
13. How did the DRC determine that there was sufficient data to
determine the radiological and not radiological constituents of Pond 2
and Pond 3?
14. Does the DRC have any information regarding when and how the
sampling was done? What the sampling methodology was? How many
mlffi'f ifi ffiffi :iffi iiiFffi 6ffi rMHiffi A#iAi
samples were taken?
15. Did the DFIC request a copy of all information referenced by
Ms. Tischler in the March 8,2005, application?
That's enough for now.
Sincerely,
Sarah M. Fields
Dane Finerfrock - Be: Request for Clarification
From:
To:
Date:
Subject:
Laura Lockhart
Finerfrock, Dane
111211200512:53:39 PM
Re: Request for Clarification
Sounds fine, Dane. lf (when) she complains next that she can't make comments unless she has the
answers to these things first, the answer is that her comment, then, is that our decision is premature or
lacks an appropriate basis without those things. Then we'll consider that.
>>> Dane Finerfrock 1112112005 7:49 AM >>>
I received another emailfrom sarah fields. I would like to respond to her using the enclosed. Are you ok
with the following?
Dear Ms. Fields: Thank you for you questions. As you know we are currently in the "public comment
period" for the FMRI- IUC license amendment application. Your comments and questions will be
considered in the final agency decision. Will will respond to your comments and any others as part of the
public participation record, which will be publically available.
>>> "Sarah M. Fields" <sarahmf ields @ earthlink.net> 1 1 11912005 4:24 PM >>>
Dear Mr. Finerfrock,
The November 2, 2005, Salety Evaluation Report for the lnternational
Uranium (USA) Corporation, White Mesa Uranium Mill, states, states that
the materialfrom the FMRI, Inc., site is "alternate feed material."
There is no definition of "alternate feed material" in the Atomic Energy
Act of 1954, as amended, or in any of NRC regulations in 10 CFR Part 40
or EPA regulations in 40 CFR. However, the State of
Utah statute contain a definition of "alternate feed material."
Section 19-3-105, states, in part: Definitions -- Legislative and
gubernatorialapproval required for radioactive waste license --
Application for new, renewed, or amended license.
(1) As used in this section:
(a) 'Alternate feed material' has the same definition as provided
in Section 59-24-102.
The referenced definition of "alternate feed material" in Section
59-24-102, states, in part: "Definitions.
As used in this chapter:
(1) (a) 'Alternate feed material' means a natural or native material:
(i) mined for the extraction of its constituents or other matter
from which source material may be extracted in a licensed uranium or
thorium mill;and
(if) may be reprocessed for its source materialcontent.
(b) 'Alternate feed material'does not include:
(i) material containing hazardous waste listed under 40 C.F.R. Part
261, Subpart D;
(ii) natural or unprocessed ore; or
(iii) naturally occurring radioactive materials containing greater
than 15 picocuries per gram of radium-226."
Questions:
1. The statutory def inition in 59-24-102 says that "alternate feed
material means a natural or native material." ls radioactive waste,
such as the FMRI waste, that has gone through several processing regimes
to extract specific minerals stillconsidered to be a "natural or native
material"? What is the basis for this determination?
2. The statutory definition of "alternate feed material" states that
"alternate feed material" does not include "naturally occurring
radioactive materials containing greater than 15 picocuries per gram of
radium-226."
Since the radium-226 content of the FMRI materials is much greater than
15 picocuries per gram, why is it considered to be "alternate feed material"?
lf the material is not "alternate feed material," because of its
radium-226 content, what type of material is it?
Thank you,
Sarah Fields
-.:-.r:aara{r::li.ll],r:jiill.ll:..lrrrj:lir
Johnathan Cook - Re:
From:
To:
Date:
Subject:
rification Related to the RCRA
Loren Morton
Sarah Fields
1113120061 1:11:54 AM
Re: lnternational Uranium (USA) Corporation (IUSA): Request for Clarification Related
to the RCRA Exemp
Sarah,
Thanks for your Janirary 10, 2006 comments regarding the Fansteel alternate feed proposal at lUC. We
will review them as resources are available.
Loren
>>> "Sarah M. Fields" <[e-mail] 1 110106 1 1 :1 8 AM >>>
Dear Mr. Finerfrock,
Attached please find a letter related to the Division of Radiation
Control's determinations about RCRA exemptions for the FMRI materials
to be received at the IUSA uranium mill.
A paper copy will lollow in the mail.
Sarah Fields
CC:Dane Finerfrock
|..{gtllgt[*!*9g3,lij-B_"' IUSA March 8 Application to Process FMRIo Material
From:
To:
Date:
Subject:
Loren Morton
Sarah Fields
121812005 3:22:21 PM
Re: IUSA March 8 Application to Process FMRI Material
Ms. Fields,
Thanks for your comments. I have passed them on to my engineering and groundwater staff, and we will
form a response to each question / concern as a part of the written Public Participation Summary (PPS)
that will be put together shortly after the January 5 public meeting in Blanding.
I will make sure that we send you a copy of the PPS at that time, so that you can beassured that we
considered and resolved each of your questions / concerns.
Later,
Loren
>>> "Sarah M. Fields" <[e-mail] IAB|OS 12:01 AM >>>
Dear Loren,
Thank you for your reply to my request for records.
I have a few question regarding the DRC Safety Evaluation Report (SER)
for the FansteelAlternate Feed Material, lnternational Uranium (USA)
Corporation (IUSA), White Mesa Uranium Mill, March 8, 2005, Application.
QUESTIONS:
1. Has the DRC taken the trouble to look at any NRC records pertaining
to the FMRI, lnc. (subsidiary of Fansteel set up after the Fansteel
bankruptcy to carry out decommissioning of the Muskogee site) facility?
2. On page 3 of the SEH it states that the Fansteel facility processed natural
ores f rom 1960 to 1989. According to NFIC records, the facility started
processing in 1956. Why the conf licting dates?
3. The FMRI facility processed tin slag from internationalsources. ls tin
slag from the processing of tin ores considered to be a "natural ore"?
Based on what?
4. On page 4, it states that the material proposed to be sent consists of
ancillary drummed material, pond surrounding soils, and debris.
ln the IUSA application I find no data pertaining to either the
radiological or non-radiological constituents of the drummed material or
the soils surrounding the ponds.
Why is there no information in the Application and the SER
documenting the radiologicaland chemicalconstituents of the soils
and barreled materials.
5. Ponds 2 and 3 are surrounded by contaminated soils. FMBI will
be required to clean up this material. How much of the soils surrounding
the ponds willgo to White Mesa?
What will be the criteria for determining what surrounding material
will go to White Mesa and what will not?
".J_g,[ml!fll],.9-9-o-lt:
F", IUSA March 8 AppJication to Processo FMRI Material
Since the DRC has no authority over the decommissioning and cleanup
of the FMRlfacility, how willthe DRC assure that any specific criteria
willbe met?
6. How will IUSA "process" the debris for its source materialcontent?
7. On page 7 of the SEB there are two tables. The first refers to
Ponds 1 and 2. According to the March I IUSA application and the
discussion in the SER, the ponds in question are Ponds 2 and 3. Why are
they referred to as Ponds 1 and 2 in the SER?
8. The table the lists the radiologicalconstituents in Pond 2 (actually
Pond 3) under U-234 lists the Min as 1770 pCilg. Then the Max concentration
is supposedly 1000 pOi/g. Here the minimum is more than the maximum. lf you
add 177O (Min) and 1000 (Max) and divide by 2 you get an average 1350. Most
likely there is an extra 0, and the Min should be 177. This gives an average
pCi/g of 588 (almost 598, but to get the averages FMRIfactored in all
the data points). Seems like the IUSA table was copied into the SER,
but not checked for accuracy.
9. The table at the bottom of page 7 of the SER compares the FMRI
materialwith the WR Grace, Heritage, and Maywood materials. The WR
Grace materialwas never shipped to the IUSA mill, nor was the
Maywood material. What exactly is the rationale behind comparing
the FMRI materialwith materialthat will never (WR Grace) and
probably will never (Maywood) be received, processed, and disposed of
at the mill?
10. IUSA has a Standard Operating Procedure (SOP) lor high thorium content
material. They supposedly used this procedure for processing the
Heritage material. There is no mention in the application or the
SER of the use of this SOP. Will IUSA be required to use this
procedure? lf not, why not?
12. ln the application IUSA gives a bit of information regarding the
history of Pond 3. However, IUSA and Ms. Tischler fail to mention that
the current Pond 3 consists ol an old Pond 3 and a Pond 4, which were
reconfigured. There is no information in the application regarding what
Pond 4 was used for, what happened to the Pond 4 materials, or how
much contamination from Pond 4 there will be in the contaminated
soils.
What exactly went into the current Pond 3? Wl1y was this
information about the existence of Pond 4 and the reconfiguration
of the ponds left out of the application? Will parts of the old
Pond 4 not part of Pond 3 be part of the contaminated soils sent to
the IUSA mill? Where exactly was the old Pond 4 located?
Don't you think that the DRC should have this information?
lnformation re Pond 4:
"The original Pond 3 was smaller and occupied approximately the eastern
half of its current location. No information was available about whether
this pond was lined. The current Pond 3 was expanded in 1979, encompassing
most of Pond 4, and a synthetic liner was laid down. The areas of Pond 4
that were not incorporated into the new Pond 3 were filled in with soil.
?-"9".?.j
r,ege"..-3_l
It is not clear whether Pond 4 was lined, or what was done with the waste
contained in it."
Considering that the greatest groundwater contamination at the FMRI site
is down gradient from Pond 3, it is reasonable to conclude that it and
Pond 4 were not lined originally.
13. How did the DRC determine that there was sufficient data to
determine the radiological and not radiological constituents of Pond 2
and Pond 3?
14. Does the DRC have any information regarding when and how the
sampling was done? What the sampling methodology was? How many
samples were taken?
15. Did the DRC request a copy of all inlormation referenced by
Ms. Tischler in the March 8, 2005, application?
That's enough for now.
Sincerely,
Sarah M. Fields
CC:Dane Finerfrock
roN MirsMAN, rR.
Govcmor
GARY HERBERT
Ucutcnant Govcrnor
State of Utah
Department of
Environmental Quality
Diannc R. Niclson, Ph,D.
Exccutivc Dirccar
DIVISION OF RADIATION
CONTROL
Danc L, Finerfrock
Director
November 18,2005
Ms. Sarah M. Fields
P.O. Box 143
Moab, Utah 84532
Dear Ms. Fields:
In response to your November 9,2005 email,I am writing to advise you that the Division will
hold a public hearing on the International Uranium Corporation's License Amendment
Application for the Fansteel materials. Public Notice will be provided however the date for the
hearing is January 5,2W6. As provided by R313-17-3(3), comments received during the hearing
will be considered in making the final decision.
The decision to hold a public hearing resolves comments two through four of your letter. I have
also considered the first and fifth comments you have made, and have discussed them with
counsel. On the advice of counsel, I have determined that our Notice was legally adequate. I
appreciate your comments, however, and will consider modifying out Notice form in the future.
Please contact Laura Lockhart, Assistant Attorney General, at366-O283 if you have any questions
about this matter.
168Nonh 1950Wcst.POBox 144850.SallLakeCiry.UTE4l14-4850.phonc(801)536-4250.fax[phone]
T.D.D. (801) 5364414 . www.dcq.utah.gov
Sincerely,
IoN MlrsMAN,rR.
Govcmor
GARY HERBERT
Uculcnanl Governor
State of Utah
Department of
Environmental Quality
Diannc R. Niclson, Ph.D.
Executivc Dircctor
DIVISION OF RADIATION
CONTR.OL
Danc L. Finerfrock
Dircctor
November 18,2005
Ms. Sarah M. Fields
P.O. Box 143
Moab, utah84532
Dear Ms. Fields:
In response to your November 9,2005 email, I am writing to advise you that the Division will
hold a public hearing on the International Uranium Corporation's License Amendment
Application for the Fansteel materials. Public Notice will be provided however the date for the
hearing is January 5,2006. As provided by R313-17-3(3), comments received during the hearing
will be considered in making the final decision.
The decision to hold a public hearing resolves comments two through four of your letter. I have
also considered the first and fifth comments you have made, and have discussed them with
counsel. On the advice of counsel, I have determined that our Notice was legally adequate. I
appreciate your comments, however, and will consider modifying out Notice form in the future.
Please contact Laura Lockhart, Assistant Attorney General, at36r6-0283 if you have any questions
about this matter.
l6E North 1950 Wesr . PCI Box I /14850 . Salr Lakc Cily. UT 841 14-4850 . phone [phone] . fax (801 ) 533-4097
T.D.D. (801) 5364414 . www.dcq.utah.gov
Sincerely,
Page I of 1
eI
Notice of Extension and Public Hearing - LS/05/09Craig Jones -
I
From:
To:
Date:
Subject:
[e-mail]
Public Hearing - LS/05/09
la to"^.
Frl=
4i\I
The Utah Department of Environmental Quality is extending the public comment period and scheduling
a public hearing regarding a proposed amendment from International Uranium (USA) Corporation.
Information about this action is posted at the web link: http://www.radiationcontrol.utah.gov/
Initial decisions by the Executive Secretary of the Radiation Control Board (also serves as the Co-
Executive Secretary of the Water Quality Board) have been made to approve a request by the
International Uranium (USA) Corporation to amend Radioactive Source Material License No.
UT1900479 and Ground Water Quality Discharge Permit No. UGW370004 for the receipt, storage, and
processing of Fansteel (FMRI) alternate feed material for its uranium content at the White Mesa
Uranium Mill, San Juan County, Utah.
Thank you.
*{<r<*****8d<****{<******x*.x**********{<**** *{<****xx***x*** r(***{<**r<{.*********
Do not reply to this message. Any replies you send will not be answered because the administrator of
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file://C:\l)ocuments and Settinss\Ciones\I.ocal Settinss\Temn\GW )00004.HTM I I12312005
flLt coPY
SAFETY EVALUATION REPORT
FOR THE
INTERNATIONAL URANIUM (USA) CORPORATION
WHITE MESA URANII.]M MILL
SAN JUAN COI.]NTY, UTAH
IN CONSIDERATION OF AN AMENDMENT TO
RADIOACTIVE SOIJRCE MATERIAL LICENSE NO. UT19OO479 AI\D
GROITND WATER QUALITY DISCHARGE PERMIT NO. UGW370004 FOR
THE
RECEIPT, STORAGE, AND PROCESSING OF FANSTEAL FMRI ALTERNATE
FEED MATBRIAL
PREPARED BY:
THE UTAH DEPARTMENT OF EIWIRONMENTAL QUALITY
DIVISION OF RADIATION CONTROL
November 2,2005
SAFETY EVALUATION REPORT
FOR THE
FANSTEEL FMRI ALTERNATE FEED MATERIAL
TNTERNATIONAL URANTLIM (USA) CORPORATTON
WHITE MESA
URANII]M MILL,
SAN JUAN COTiNTY, UTAH
Table of Contents Page
1.0 Introduction I
1.1 Backsround and Need for Proposed Action I
1.2 Previous Alternate Feed Proposals 2
1.3 FMRI Materials J
I.4 Review Scooe 4
2.0 Site Characteristics of the White Mesa Mill Area 5
3.0 Onerations 6
4.0 Environmental Effects 7
4.1 Radioloeical and Non-Radiolosical Impacts 7
4.2 Surface Water and Groundwater Impacts 9
4.3 Evaluation of Additional Groundwater Monitoring Compliance
Parameters
10
4.4 Alternatives t4
4.5 Lons-Term Impacts t4
4.6 Report Findines 15
5.0 Pronosed License and Permit Chanses L6
5.1 License Amendments Proposed t6
5.2 Permit Modifications Proposed t7
6.0 References 18
7.0 Table 20
Attachment 2t
1.0
SAFETY EVALUATION REPORT
FOR THE
FAN STEEL FMRI ALTERNATE FEED MATERIAL
INTERNATIONAL URANIUM (USA) CORPORATION
WHITE MESA
URANITJM MILL,
SAN JUAN COTJNTY, UTAH
INTRODUCTION
1.1 Background and Need for Proposed Action
This draft Safety Evaluation Report (SER) is being performed to evaluate the
environmental impacts of the proposal for the White Mesa Uranium Mill to receive and
process altemate feed material from the Fansteel Inc. (Fansteel) FMRI facility located near
Muskogee, Okalahoma (the "Muskogee Facility"). The White Mesa mill site is located in
San Juan County, approximately 5 miles south of Blanding. International Uranium (USA)
Corporation (IUSA) submitted a license amendment application by letter dated March 8,
2005 and supplemented by letters dated April l, 2OO5,lune 22,2005, and July 19, 2005, to
amend its State of Utah Radioactive Radioactive Source Materials License No.
UT1900479. The proposed amendment would allow IUSA to receive and process up to
32,000 tons of alternate feed material from the Muskogee Facility.
The Muskogee Facility is being remediated and decommissioned under its Nuclear
Regulatory Commission (NRC) License. The FMRI materials are residues resulting from
processing ores for the extraction of tantalum and niobium.
The FMRI materials are the byproducts of the FMRI processing operations. The materials
consist of finely graded dewatered slurry solids with no free liquid. The materials contain
residual amounts of tantalum, niobium, and uranium.
IUSA is requesting that the material be received and processed for its source material
content. Byproducts from the extraction of source material will be disposed in the mill's
lined tailings cells with a groundwater detection monitoring program. Before the State of
Utah's Agreement State status was formalized, the Nuclear Regulatory Commission (NRC)
approved similar amendment requests in the past for separate alternate feed materials under
this license.
The mill site is licensed by the Utah Department of Environmental Quality, Division of
Radiation Control (DRC) under State of Utah Radioactive Materials License No
UT1900479 to receive and process natural uranium-baring ores including certain specified
alternate feed materials, and to possess byproduct material in the form of uranium waste
tailings and other uranium byproduct waste generated by the licensee's milling operations.
t.2
Groundwater quality at the ruSA facility is also regulated by State Groundwater Permit
Number UGW370004 (hereafter Permit). After review of the proposal, the Executive
Secretary has determined it necessary to also modify the Permit in order to better monitor
and protect local ground water quality from possible effects of disposal of the proposed
alternate feed material.
Previous Alternate Feed Proposals
In the Final Application for Uranium Mills and Mill Tailings made by the State of Utah to
the NRC Office of State and Tribal Affairs, the following commitment was made by the
State of Utah:
"The State of Utah recognizes the importance of and supports the uranium
mining and milling industry. The State recognizes that to remain viable at
this time, uranium mills must be able to engage in activities other than
milling conventional mined uranium such as processing alternate feed
materials for the recovery of uranium alone or together with other minerals."
The State of Utah also agreed to use the current NRC guidance (NRC Regulatory
Issues Summary 2000-23) for review and decision of receipt of alternate feed
materials and that each amendment would be considered a major amendment for the
purposes of licensing. These three criteria for decision making regarding the
acceptance of alternate feed material are:
l. Determination of whether the feed material is an ore.
For the tailings and wastes from the proposed processing to qualify as I1e.(2)
byproduct material, the feed material must qualify as "ore." In determining
whether the feed material is ore, the following definition of ore will be used: Ore is
a natural or native matter that may be mined and treated for the extraction of any
of its constituents or any other matter from which source material is extracted in a
licensed uranium or thorium mill.
The DRC has determined that the FMRI material does meet this criteria.
2. Determination of whether the feed material contains hazardous waste.
If the proposed feed material contains hazardous wastes, listed under subpart D
Sections 261.30-33 of 40 CFR (or comparable Resource Conservation and
Recovery Act (RCRA) authorized State regulations), it would be subject to the U.S.
Environmental Protection Agency (EPA) or State regulation under RCP/^. If the
licensee can show that the proposed feed material does not contain a listed
hazardous waste, this issue is resolved.
Feed material exhibiting only a characteristic of hazardous waste (ignitable,
corrosive, reactive, toxic) would not be regulated as hazardous waste and could
therefore be approved for recycling and extraction of source material. However,
this does not apply to residues from water treatment, so determination that such
residues are not subject to regulation under RCRA will depend on their not
containing any characteristic hazardous waste. Staff may consult with EPA (or the
State) before making a determination of whether the feed material contains
hazardous waste.
If the feed material contains hazardous waste, the licensee can process it only if it
obtains EPA (or State) approval and provides the necessary documentation to that
ffict. Additionally, for feed material containing hazardous waste, the staff will
review documentation from the licensee that provides a commitment from the U.S.
Department of Energy or the State to take title to the tailings impoundment af'ter
closure.
The FMRI material is tailings from the processing of ore. Under 40 CFR
261.4(b)(7), solid wastes from the extraction, beneficiation, and processing of ores
and minerals are not hazardous wastes. Even if this were not the case, in the
application for license amendment made by IUSA on March 8, 2005, ruSA made
the determination that the FMRI material contained no known listed wastes under
subpart D Sections 261.30-33 of 40 CFR. Therefore, this condition is satisfied.
3. Determination of whether the ore is being processed primarilv for its source-
material content.
For the tailings and waste from the proposed processing to qualify as l1e.(2)
byproduct material, the ore must be processed primaily for its source-material
content. If the only product produced in the processing of the alternate feed is
uranium product, this determination is satisfied. If, in addition to uranium product,
another mateial is also produced in the processing of the ore, the licensee must
provide documentation showing that the uranium product is the primary product
produced.
Originally in its March 8, 2005 submittal, ruSA stated that it might consider milling
the FMRI material for tantalum and other metals as well as for uranium. However,
in IUSA's Jtne 22,2005 letter, ruSA stated that the FMRI material would only be
milled for its uranium content. This condition is satisfied.
Currently, IUSA has 13 license amendments authorizing the mill to receive and process
alternate feed materials from various sites, contained in License Conditions 10.6 through
10.18.
FMRI Materials
In IUSA's March 8, 2005 submittal they state that from 1960 to 1989, Fansteel processed
natural ores for recovery of tantalum and niobium at the Muskogee Facility. Tantalum ore
and tin slag were purchased from around the world. This feed material was leached in
concentrated hydrofluoric acid and sulfuric acid. This process dissolved the tantalum and
niobium into solution and the insoluble fluoride compounds, such as thorium, radium, and
uranium, remained behind in the solids. These solids were then filtered and collected in
Ponds 2 and 3. The leached solids sent to Ponds 2 and 3 were highly variable and
1.3
contained on average approximately O.\Vo tantalum (Ta) and 0.L77o U:Os. The solids in
Ponds 2 and 3 contain residual metal impurities in the fluoride form.
The FMRI materials are comprised of the materials stored in on-site Ponds 2 and 3,
ancillary drummed material, pond cover soils, pond surrounding soils, and debris that have
been impacted by the proposed alternate feed material. The FMRI material has a uranium
content of approximately 0.1517o (O.178%o U:Os) and0.35l%o thoium-232.
1.4 Review Scope: Environmental Analvsis
In accordance with UAC R313-22-38 and R313-24-3, this SER serves to:
(1) Assess the radiological and non-radiological impacts to the public health.
(2) Assess any impact on waterways and groundwater.
(3) Consider alternatives, including alternative sites and engineering methods
(4) Consider long-term impacts including decommissioning, decontamination, and
reclamation impacts.
(5) Present information and analysis for determining DRC findings and conclusions
which support the proposed license amendment.
4
2.0 SITE CHARACTERISTICS OF THE WHITE MESA MILL AREA
The area surrounding the White Mesa facility is in an arid climate with an approximate
annual precipitation of l2-inches and a mean temperature of 50o F. Runoff in the project
area is directed by the general surface topography either westward into Westwater Canyon,
eastward into Corral Creek, or to the south into an unnamed branch of Cottonwood Wash.
The San Juan River, a major tributary to the Colorado River, is located approximately 18
miles south of the site.
The population density of San Juan County is approximately 1.7 persons per square mile.
The Town of Blanding is the largest population center near the facility with a population of
3,600. Approximately 3.5 miles southeast of the site is the White Mesa Reservation, a
community of approximately 350 Ute Mountain Ute Indians. The nearest resident to the
mill is located approximately 1.4 miles to the northeast of the mill, which is in the
prevailing wind direction.
Approximately 60%o of San Juan County is federally-owned land administered by the U.S.
Bureau of Land Management (BLM), the U.S. National Park Service (NPS), and the U.S.
Forest Service. Primary land uses include livestock grazing, wildlife range, recreation, and
exploration for minerals, oil, and gas. A quarter of the county is Native American land
owned by either the Navajo Nation or the Ute Mountain Ute Tribe. The land within 5
miles of the site is predominantly owned by residents of Blanding. IUSA owns or has
claims or leases on approximately 5,500 contiguous acres, of which the White Mesa mill
site encompasses approximately 500 acres.
Groundwater beneath the site mainly occurs in two aquifers: a shallow unconfined aquifer
hosted by the Dakota Sandstone and the Burro Canyon formations; and the deep confined
aquifer in the Entrada./Navajo Sandstone. Near the tailings cells the shallow aquifer is
found at a depth of about 80 to 100 feet below ground surface and consists of groundwater
perched over the Brushy Basin Member of the Morrison formation. The deep
Entrada./Navajo Sandstones form one of the most permeable aquifers in the region. It is
found at a depth of over 1,000 feet below ground and is separated from the shallow aquifer
by hundreds of feet of low permeability shales and mudstones (e.g. Brushy Basin and
Recapture Members of the Morrison Formation, the Summerville Formation, etc.).
Recharge to the aquifers occurs by infiltration along the flanks of the Abajo, Henry, and La
Sal Mountains, and along the flanks of the structural folds. Groundwater in the shallow
perched aquifer (Dakota Sandstone and Burro Canyon Formation) is monitored by the mill
in the groundwater detection monitoring program. Water in this zone flows south to
southwest.
Ninety-five groundwater applications, within a 5 mile radius of the site are on file with the
Utah State Engineer's Office. The majority of applications are by private individuals and
for wells drawing small, intermittent quantities of water, less than 8 gpm from the Burro
Canyon formation. For the most part, these wells are located upgradient (north) of the
facility. Stockwatering and irrigation are listed as the primary uses. Two deep water
supply wells are completed in the Entrada/Navajo Sandstone located approximately 4.5
miles southeast of the site on the Ute Mountain Ute Reservation. These deep water supply
wells are completed approximately 1200-feet below the ground surface.
3.0 OPERATIONS
The White Mesa uranium mill was built in the late 1970's by Energy Fuels Nuclear, Inc.
(EFN) as an outlet for the many small mines that are located in the Colorado Plateau. After
about two and one-half years, the mill ceased ore processing and entered a total shutdown
phase. In 1984, a majority ownership interest was acquired by Union Carbide
Corporation's (UCC) Metals Division, which later became Umetco Minerals Corporation
([IMETCO), a wholly-owned subsidiary of UCC. The partnership between UMETCO and
EFN continued until IVIay 26,1994, when EFN reassumed complete ownership of the mill.
In May of 1997 , ruSA purchased the assets of EFN and is the current owner and operator
of the facility. The mill has gone through several operation and shut down periods from
1980 to date.
The current license, License Condition 10.1, specifies a maximum production rate of 4380
tons of yellowcake per year. The maximum mill throughput is limited in part by the annual
freeboard calculations submitted to the UDRC annually, in accordance to License
Condition 10.3.
6
4.0
4.1
ENVIRONMENTAL EFFECTS
Radioloeical and Non-Radiolosical Impacts
Radiological Impacts
According to the March 8, 2005 submittal, the following radionuclides are known to exist
in the FMRI alternate feed materials: Ra-226,Ra-228,Th-228,Th-230,Th-232,U-234,U-
235, andU-238. Concentrations of these radionuclides in FMRI's Tailings Ponds I and 2
are shown below. These radionuclides are commonly associated with the uranium decay
series and natural thorium decay series. The FMRI material is radiologically consistent
with other ores and alternate feeds that have been processed at the White Mesa Mill.
In the June 22,2005 letter, IUSA stated that during storage on the ore pad, the FMRI
materials will be sealed inside a neoprene liner inside a fabric bag. The exposure and dose
rates from the estimated 32,000 tons of FMRI material was found to be approximately the
same as that of an equivalent amount of low-grade Colorado Plateau ore.
The March 8, 2005 submittal has the following comparisons between the FMRI material
and previously licensed natural ores and alternate feed materials.
Material Vo UtOs Th-232
Concentration
FMRI
Material
O.l8%o 0.3587o
Colorado
Plateau Ore
O.l1Vo
toO.3OVo
W.R. Grace 7.27Vo
Heritase l.08Vo
Maywood O.88Vo
Non-Radiological Impacts
According to the March 8, 2005 submittal, the Radioactive Material Profile Record
attached in Appendix 2 to the March 8, 2005, submittal lists the following known and
possible chemical components or hazardous waste characteristics:
Pond
1
Gross
Alpha
Gross
Beta
u-234
(pCi/g)
u-235
(pCi/e)
u-238
(pcile)
Th-228
(pCi/e)
Th-230
(pCi/e)
Th-232
(pCi/g)
Ra-228
(pCi/e)
Ra-226
(pCi/e)
Min 2300 920 170 5.3 t'l0 160 420 160 160 138
Max 6100 3100 550 29 580 560 860 560 560 329
Avs.4478 2091 344 t5.2 357 360 697 360 360 233
Pond
2
Gross
Alpha
Gross
Beta
u-234
(pCi/e)
u-235
(pCi/e)
u-238
(pCi/e)
Th-228
(pCi/e)
Th-230
(pCi/e)
Th-232
(pCi/e)
Ra-228
(pCi/e)
Ra-226
(pCi/e)
Min 840 610 1770 t2 180 94 2r0 94 94 t42
Max 7600 3800 1000 46 ll0 680 1200 680 680 400
Avs.5263 2674 598 30.2 635 437 766 437 437 t44
(Y)N)ff)N)ff)(N)
a.Listed HW x b.Derived-
From HW
x c.Toxic x
d.Cvanides x e.Sulfates x f.Dioxins x
o Pesticides x h.Herbicides x l.PCBs x
J.Explosives X k.Pyrophorics x t.Solvents x
m.Orsanics x n.Phenolics x o.Infectious x
p.Isnitable x q.Corrosive x r.Reactive x
s.Antimony x t.Bervllium x u.Copper x
Y.Nickel x w.Thallium x x.Vanadium x
v.Alcohols x z.Arsenic x aa.Barium x
bb.Cadmium x cc.Chromium x dd.Lead x
ee.Mercury x ff.Selenium x ss.Silver x
hh.Benzene x n.Nitrate x lI.Nitrite x
kk.Fluoride x il.oit x mm.Fuel x
nn.Chelating
Asents
x oo.Residue from Water Treatment x
DD.Other Known of Possible Materials or Chemicals x
For a detailed list of all the non-radiological chemical and their concentrations that are in
the FMRI material, refer to Table 5 and Table 6 of Appendix 2 of the March 8, 2005
submittal.
RCRA Listed Materials Analysis
As stated in Section 1.3, the FMRI material is the result of natural ore processing,
therefore no listed RCRA material is presented because it is exempt under 40 CFR
261.4(b)(7).
RCRA Characteristic Materials Analysis
The following metals and inorganic chemicals can be found in the FMRI material
(ruSA, March 20O5,Appendix 5).
Class Component of FMRI Materials*
Alkali Metals Sodium, potassium
Alkaline Earths Barium, beryllium, calcium, magnesium
Transition and Rare Antimony, cadmium, cerium, chromium, cobalt, hafnium,
Earth Metals Iron, lanthanum, manganese, mercury, molybdenum,
neodymium, nickel, niobium, praseodymium, scandium,
silver, tantalum, thallium, thorium, tin, titanium,
tungsten, vanadium, yttrium, zinc, zirconium
Aluminum,lead
Arsenic, selenium, silicon
Non-Metal Ions Ammonia, chloride, cyanide, fluoride, nitrate, phosphate
sulfate
Volatile Organic Acetone, Methyl isobutyl ketone (MIBK)
Compounds
Semi-Volatile Organics Di-n-butyl phthalate
Compounds
xBold Type = elements or compounds in the FMRI material, that have not been quantified in the
mill's tailings cells to date. Some of these elements, such as tantalum, niobium and scandium are
Other Metals
Metalloids
known to exist in the mill's tailings, from other alternate feed materials, but have never been
quantified. Others, such as cerium, hafnium, lanthanum, praseodymium, tungsten and yttrium are
expected by IUSA to also currently exist in the mill's tailings cells, due to their natural abundance
with other elements found in the tailings cells, but have never been quantified.
There may be some residual methyl isobutyl ketone (MIBK) in the FMRI material.
MIBK was used to remove impurities (iron, zirconium, and uranium) from the
original tantalum processing stream.
In a May 16,2005,letter to ruSA, DRC asked IUSA to specifically evaluate the
chemical compatibility of elements and compounds in the FMRI material that have
not been quantified to date in the tailings ponds. These compounds include:
MIBK, Bis (2-ethylhexyl) Phthalate, Di-n-butyl Phthalate, Cerium, Hafnium,
Lanthanum, Niobium, Neodymium, Praseodymium, Scandium, Sulfides, Tantalum,
Tungsten, Yttrium, and Fluoride.
In a June 22,2005,1etter, IUSA made the following statements:l) Bis (2-ethylhexyl) Phthalate, Di-n-butyl Phthalate and MIBK are in low enough
concentrations to be considered "de minimus," having no impact.o Bis (2-ethylhexyl) Phthalate while reported in the March 8,2005 submittal,
only exists in FMRI's Tailings Pond 5, which is not part of the proposed
alternate feed material.o Di-n-butyl Phthalate in high enough concentrations would actually increase
liner and liner joint plasticity, flexibility, and toughness.
o MIBK and other keytones are compatable with PVC liners and joints to
concentrations up to 107o. The addition of the FMRI material to the tailings
solution will increase the total concentration of keytones to 13 ppm
(o.00l3%o).
Sulfides were incorrectly indicated on the list of constituents in the FMRI
material. The presence of sulfates should have been indicated. Sulfates in any
concentration are compatible with the PVC liner and joints.
Fluorides have been introduced into the Mill's uranium circuit with natural ores
and alternate feeds at levels as high as 460,000 mdkg. The FMRI material has
a concentration of 309,000 mdkg. The addition of fluoride to the tailings
system will increase the overall concentration of fluoride salts in the tailings
cells to approximately O.7Vo The manufacturer's rating for inorganic
hydrofluoric acid compatibility with PVC liners and joints for hydrofluoric acid
is 487o. According to the manufacturer's data, metal fluoric salts in any
concentration are compatible with PVC liners and joints.
The mill tailings system currently contains high levels of metallic salts.
Incremental increases in metallic salt concentrations will not have any effect on
the PVC liners and joints.
4.2 Surface Water and Groundwater Effects
Surface Water Effects
As stated above, during storage on the ore pad, the FMRI material will be sealed in fabric
bags with a 3 mil polyethylene liner. The FMRI material is expected to have a moisture
content of 20Vo to 30%o. There will be no free liquid inside the polyethylene liner.
9
2)
3)
4)
Therefore it is unlikely that material or liquids will penetrate the bag and become exposed
to stormwater. In the event that the FMRI material became exposed to stormwater, IUSA
has an approved spill management plan and stormwater management plan. All storm water
runoff from the ore pad is routed to Cell 1.
Groundwater Effects
As stated above, during storage on the ore pad, the FMRI material will be sealed in fabric
bags with a 3 mil polyethylene liner. The FMRI material is expected to have a moisture
content of 207o to 30Vo. There will be no free liquid inside the polyethylene liner. In
addition, the highly compacted ore pad surface and the limited duration of storage will
further reduce the potential for seepage to occur while the FMRI material is on the ore paid.
Therefore, seepage of the material into the groundwater at the ore pad site is not
anticipated. The FMRI material has similar chemical and radiological properties to natural
uranium ore and materials currently stored in the tailings cells. Therefore, it is not
anticipated that ore pad storage of the FMRI material would pose any additional risk to the
groundwater than conventional ores.
Tailings from the FMRI material processing will be disposed in the lined tailings cells
along with other process tailings. A groundwater detection monitoring program is already
in place, in accordance with the State issued groundwater permit, to determine if any
leakage from the tailings cells has occurred. Additionally, if groundwater contamination
were to occur, the DRC would require that IUSA conduct a corrective action to restore
groundwater to the groundwater standards detailed in the state groundwater permit.
4.3 Evaluation of Additional Groundwater Monitoring Compliance Parameters
With the introduction of the FMRI material into the mill process, each contaminant found
in these materials needs to be considered in order to determine if additional groundwater
monitoring compliance parameters should be added to the Permit.
In Attachment 5, of IUSA's March 8, 2005 submittal Table 2, "Comparison of Uranium
Materials and Alternate Feeds", a surffnary is found of 48 contaminants in the FMRI
material. In determining if additional groundwater compliance monitoring parameters were
needed for the Permit the following criteria were considered for the 48 contaminants:
1) Is the contaminant already included as a groundwater monitoring compliance
parameter in the Permit?
2) Will there be a significant increase in concentration in the tailings inventory?
3) Is the contaminant mobile in the groundwater environment (i.e., low soil-water
partitioning coefficient (Kd)X
4) Does the contaminant represent a known human toxicity hazard?
5) Is there an available and reputable groundwater quality compliance standard?
6) Are there EPA approved analyical methods?
In its review process, DRC observed that many of the 48 contaminants identified in the
FMRI material have never been quantified in the mills tailings cells and, as a result, have
not been considered to date for inclusion in the Permit. Several of these were also of
concern because of proportionately large increases in the projected tailing cell inventory
after the feed stock is processed, although in most cases the overall concentration of these
l0
constituents will not be affected significantly by processing the FMRI material at the Mill
(see Table I Summary of Components in Fansteel Alternate Feed). A total of 26 of the 48
contaminants considered were already required as groundwater monitoring parameters in
the Permit.
Based on the above criteria tin will be added as a groundwater monitoring compliance
parameter to the Permit. Reasons for the selection of tin and omission of the remaining2l
contaminants are found below. Details are also found in Table I in section 7.0 below.
Contaminant Selected for Groundwater Monitoring Parameter
Tin is currently not a required groundwater monitoring parameter in the Permit, and was
omitted from the original Permit due to non-detectable concentrations reported by IUC in
three tailings leachate samples (see l2lll04 DRC Statement of Basis, Table 5). Based on
the proposal in question, tin will experience an estimated increase in the tailing inventory
from 9 to 248 tons (IUSA, March 2005, Attachment 5). With an estimated Kd of 2.5 to 5
(Ohio EPA, 2005) tin is not as mobile in the groundwater environment as other metals;
however, with the high acid conditions in the tailings wastewater, tin could stay in solution
and not partition on aquifer materials. In a memorandum from Mark R. Colsman (Tetra
Tech EM, Inc.) to David C. Frydenlund (IUSA) dated September 26, 2005 (Colsman,
September 26,2005), it was proposed that cadmium and zinc may serve as analogues for
tin because they are associated with lead in mineral deposits and ores. However, the
coincident occurrence of these mineral deposits may be a product of their high temperature
geochemical environment of deposition. In contrast, shallow ground water at the Mill site
is a low temperature geochemical environment. Consequently cadmium and zinc were not
accepted as ground water monitoring analogues for tin.
Toxic levels of tin can pose a human health risk to the kidney and liver (Minnesota
Department of Health, 2005). With the help of EPA Region 8 toxicology staff DRC will
adopt an ad hoc groundwater quality standard for tin of 17,000 ugl[- (See 10127105 FPA
memorandum).
Contaminants Omitted from Groundwater Monitoring Consideration
The following 26 contaminants were not added because they are already required as
groundwater monitoring compliance parameters in the Permit:
Besides tin, the remaining 2l contaminants of concern that are not groundwater monitoring
parameters include the following four groups with their corresponding DRC findings:
Nutrients (2)Ammonia and nitrates
Inorganics and Metals (23)Arsenic, beryllium, calcium, cadmium, chloride,
chromium, cobalt, fluoride, iron, lead, magnesium,
manganese, mercury, molybdenum, nickel, potassium,
selenium, silver, sodium, sulfate, thallium, vanadium, and
zinc
Organics (l)Acetone
1l
Inorganics: cyanide and phosphate
Although there is an expected increase in the concentration in the tailings inventory,
cyanide was omitted because it will off-gas in the high acid environment of the
White Mesa Mill process. Should cyanide be found in future tailings wastewater
sampling under Part 1.H.5, DRC may consider whether it should be added as a
compliance monitoring parameter at a future date.
Phosphate was not a required groundwater monitoring parameters in the Permit,
although, there is a small increase in the inventory of phosphate, because there was
insufficient information to conclude that they pose a human health risk (TOXNET,
2005).
Metals: aluminum, antimony, barium, cerium, hafnium, lanthanum,
neodymium, niobium, praseodymium, scandium, silicon, tantalum, thorium,
titanium, tungsten, yttrium, and zirconium.
Barium, cerium, hafnium, lanthanum, neodymium, niobium, praseodymium,
scandium, tantalum, thorium, tungsten, yttrium, and zirconium were not required as
groundwater monitoring parameter in the Permit. Although, some of these metals
will have only a slight increase in concentration in the tailings inventory, most of
these constituents have not been quantified in the mill's tailings cells to date. All
were eliminated for monitoring consideration because of high Kds ranging from 40
to 1500 Ukg (Colsman September 9, 2005). Other metals are already used as
compliance monitoring parameters that have much lower Kd values, and should be
detected well before the arrival of the above eliminated metals.
Aluminum was also omitted as a groundwater monitoring parameter in the Permit;
although, there is a slight increase in its tailings inventory concentration. This
omission is due to the fact that: 1) Aluminum and iron have similar geochemical
behavior in groundwater environmentsl, 2) the increase in concentration of
aluminum in the tailings will be small (approximately 0.13 7o),3) iron is already a
required groundwater monitoring parameter in the Permit, 4) it is estimated that
there will be similar concentrations of aluminum and iron in the mill's tailings
inventory after processing the FMRI material (IUSA, March 2005), and 5) iron has
an estimated lower Kd than aluminum (iron estimated Kd of 1.4 and aluminum
estimated Kd of 9.9 (Tetra Tech, 2005)). Consequently, iron should be detected at
I In sulfate solution concentrations greater than 10,000 mg/L, as in the wastewater in the tailings cells, iron
and aluminum values greater than 1000 are common. The mobility of these constituents away from the
source of acidity is primarily a function of the total acidity of the solution and the acid-neutralizing capacity
of the material the solution contacts. The acidity of the solution is partly due to the activity of hydrogen;
however, a much greater component is generally due to dissolved iron and aluminum. As the pH of the
solution is raised by reactions with the solid phase iron and aluminum minerals become less soluble and
precipitate producing hydrogen. This reaction produces a much greater acidity provided by the solution
concentration of hydrogen. As a consequence the pH plume and its dissolved constituents will be more
mobile in an acidic solution with high concentrations of iron and aluminum than a plume without these metals
(Deutsch 1997).
t2
the compliance monitoring wells before the arrival of aluminum and therefore an
acceptable analog.
Antimony is also not a required groundwater monitoring parameter in the Permit, in
part because there is no significant increase in the tailings inventory. Further,
antimony and arsenic have similar geochemistry, and arsenic is already a required
groundwater monitoring parameter in the Permit. The estimated mass of antimony
in the mill's tailings after processing the FMRI material will be less than the
estimated mass of arsenic in the mill's tailings (IUSA, March 2005). Antimony has
an estimated Kd of 2.0 (IUSA Permit 2004) and arsenic has a estimated Kd of 1.0
(Tetra Tech, 2005). Consequently, arsenic should be detected at the compliance
monitoring wells before the arrival of antimony.
Titanium is not a required groundwater monitoring parameter in the Permit,
although there is a significant increase in the tailings inventory, and a slight
increase in the concentration in the tailings as a result of processing the FMRI
material, there was no information found in the Hazardous Substance Data Bank
(HSDB) regarding human health risk. Further, no Kd information was found in
available technical literature. Since this information was not available titanium was
eliminated from consideration as a groundwater monitoring parameter. If in the
future, such information should become available, the Executive Secretary may
consider at that time whether titanium should be added as a monitoring parameter,
pursuant to Part IV.N of the Permit.
Volatile Organic Compounds (VOC); methyl isobutyl ketone.
Methyl isobutyl ketone (MIBK) is not a required groundwater monitoring
parameter in the Permit, in part because there is not a significant increase in the
tailings inventory. Also MIBK and Methyl ethyl ketone (I!GK) are members of the
same chemical class (ketones). MEK is already a required groundwater monitoring
parameter in the Permit and can serve as an analog for MIBK, in that: l) The
estimated MEK mass in the tailings will be greater than MIBK (after alternate feed
processing) (IUSA, March 2005), and 2) MEK has a lower estimated Kd than
MIBK G\mK estimated Kd of 0.015 (ruSA Permit, 2004) and MIBK has an
estimated Kd of 0.123 (TOXNET, 2005)) consequently, MEK should be detected at
the compliance monitoring well before the arrival of MIBK and therefore an
acceptable analog.
Semi-Volatile Organic Compounds (SVOC): di-n-butyl phthalate.
Di-n-butyl phthalate is not currently a required groundwater monitoring parameter
in the Permit. However, it was considered for monitoring in the Permit (see
l2lll04, DRC Statement of Basis, p. l9). In order to streamline groundwater
monitoring efforts and for reasons addressed in the Permit all SVOC compounds,
including di-n-butyl phthalate were omitted as groundwater monitoring parameters.
13
Conclusions
The inventory for the FMRI material included 49 contaminants for groundwater monitoring
compliance consideration. Of these 49 contaminants, 26 were already required as
groundwater monitoring compliance parameters in the Permit. Of the remaining 23
contaminants, the Executive Secretary determined that tin should be added as a new
groundwater monitoring compliance parameter in the Permit.
4.4 Alternatives
The action that the DRC is considering is approval of an amendment request to Radioactive
Source Materials License issued pursuant to UAC P.3l3-24 Uranium Mills and Source
Material Mill Tailings Disposal Facility Requirements. Subparagraph UAC R3l3-24-
3(1)(c) requires that alternate sites and engineering methods be considered in the analysis
of the license amendment request.
Based on its review, the DRC staff has concluded that the environmental impacts
associated with the proposed action do not warrant either limiting IUSA's future operations
or denying the license amendment. The DRC staff has concluded that there are no
significant environmental impacts associated with the proposed action. Other alternatives
need not be evaluated.
4.5 Long-Term Impacts
DRC does not anticipate any significant impacts on the reclamation, decommissioning, and
decontamination of the White Mesa facility, if the FMRI material is processed as an
alternate feed. In general, the FMRI material has similar radiological and non-radiological
properties to other alternate feeds and natural ores that have already been processed by
IUSA. One additional ground water monitoring parameter has been required to ensure
added protection of local ground water resources.
In order to evaluate surety issues in the unlikely event that IUSA were to close prior to
processing the FMRI material, DRC sent a letter to IUSA on May 16, 2005, requesting
information as to how much IUSA's financial surety needs to be adjusted. If this scenario
were to happen, the fabric-bagged FMRI material would likely be hauled to the disposal
cell and disposed of directly into Tailings Cell 3. In a letter dated July 19, 2005, ruSA
included an analysis stating that the financial surety would not need to be increased for the
acceptance of the FMRI material, because the mill has already processed other alternate
feeds, which has caused a decrease in the surety greater than that of the surety increase for
the receipt of the FMRI material. Therefore the financial surety amount approved in
License Addendum #l will be sufficient. This amount is $10,950,180.00. To ensure that
the surety amount is always sufficient to cover the amount of alternate feed material stored
at the Mill, changes have been proposed to License Condition 10.1. Refer to Section 5.0
for these proposed changes.
t4
4.6 Report Findines
Based on the foregoing evaluation of the environmental impacts of the ruSA amendment
request, the DRC has determined that there will not be a significant adverse effect on
public health on the environment resulting from the IUSA proposal. The following
statements support and summarize this conclusion:
1. An acceptable environmental and effluent monitoring program is in place to
monitor effluent releases and to detect whether applicable regulatory limits are
exceeded. Radiological and non-radiological effluents from site operations have
been and are expected to continue to remain below the regulatory limits. A
groundwater monitoring program for the shallow perched aquifer is in place to
detect potential seepage of contaminants from the tailings cells. The deep, confined
Entrada./Navajo Sandstone Aquifer is separated by low permeability formations
from the tailings cells further decreasing a potential impact to deep groundwater
resources. The potential for seepage to occur while the material is temporarily
stored on the ore pad is minimal due to triple layer packaging, dry climate and
highly compacted ore pad surface, and the limited duration of storage. Further,
decommissioning and reclamation activities at the storage pad can remove any such
contamination, should it occur, to the tailings cells for long-term control. An
existing dust suppression program will be implemented at the mill to reduce the
potential for airborne contamination.
An approved radiation safety program is in place at the mill. Site perimeter
postings required by License Condition 9.9 are in place at entrances to the mill. In
the past, all worker Total Effective Dose Equivalents (TEDEs) have been found to
be well below the 0.05 Sv (5 rem) annual limit specified in UAC R313-15-201 (10
CFR 20.1201). The licensee has also implemented a bioassay program as
consistent with NRC Regulatory Guide 8.22,"Bioassay at Uranium Mills."
Present and potential environmental impacts from the receipt and processing of the
FMRI material were assessed. No significant impacts have been identified as a
result of this action. Therefore, the staff has determined that any increased risk to
public health and environmental hazards is insignificant.
2.
aJ.
15
5.0 PROPOSED LICENSE AMENDMENTS AND PERMIT MODIFICATIONS
5.1 License Amendments Proposed
The following license condition changes would result from this license amendment. The
changes are presented in redline-and-strikeout format.
l0.l A. The mill production rate shall not exceed 4380 tons of yellowcake per year.
B. Maximum quantities of feed material stored on the mill site. including the
ore pad. in accordance with the submittal to the Executive Secretary clated
July 19. 2005:
(l) Any combination of alle_rnate feed material stockpiled in bulk torm
shall not to exceecl 78.000 tons, without prior approval of the
Executi ve Secretarl-, and
{2) An}'combination of alternate f-eed matedal stored in banels is not to
exceed 33,500 barrels. without prior approval of the Erecutive
Secretar-v. Barrel volume shall not exceed 55 gallons.
C. The licensee shall notify the Executive Secretary prior to recc-iving natural
Ores.
lApplicable DRC Amendment: 2I
10.19 The licensee is authorized to receive ancl process source material from FMRI's
MLrskogee Facility located in Muskogee. Oklahonia. in accordance with statements.
representations. and commitlnents contained in the amendment requests and
submittai$ to the Executil,e Secretary dated March 7. 2005 and June 22. 2005.
lApplicable DRC Amendmerit: 2l
Additionally, the following administrative license amendment will be made. This former
reference to the NRC was not corrected as part of the initial license conversion.
12.2 The licensee shall submit a detailed decommissioning plan to the I*R&-E1eguUJ9
Secretary at least twelve (12) months prior to planned final shutdown of mill
operations that includes a detailed Quality Assurance Plan. The plan will be in
accordance with NRC Regulatory Guide 4.15, "Quality Assurance for Radiological
Monitoring Programs" and NUREG-1575, "Multi-Agency Radiation Survey and
Site Investigation Manual (MARSSIM)" or equivalent most current guidance.
[Applicable NRC Amendment: 13]
lApplicabl_e DRC Amendment: 2l
t6
5.2 Permit Modifications Proposed
Tin is proposed to be added as an additional required groundwater monitoring parameter to
the Permit. Changes that will be added to Table 2 of the Permit, in redline-and-strikeout,
format presented in Attachment 1 below.
t7
6.0 REFERENCES
Colsman Mark R., September 9, 2005, memorandum, Subject: Survey of Reference
Partition Coefficient Values for Trace Heavy Metals in Fransteel Metal, Inc. Uranium
Materials, from Mark R. Colsman, Ph.D. to David C. Frydenlund. Memorandum,
September 9 , 2005, sent by e-mail to the Utah Division of Radiation Control from David C.
Frydenlund to Loren Morton.
Colsman Mark R., September 26, 2005, memorandum, Subject: Geochemical Basis for
Analogues of Proposed Additional Monitoring Parameters, from Mark R. Colsman, Ph.D.
to David C. Frydenlund. Memorandum, September 27,2005, sent by e-mail to the Utah
Division of Radiation Control from David C. Frydenlund to Loren Morton.
International Uranium (USA) Corporation, "Revised Cost Estimate for Reclamation of the
White Mesa Mill and Tailings Management System, Blanding, IJtah," February 2005.
IUSA, "RE: FMRI Alternate Feed License Amendment Application, Department of
Environmental Quality Request for Additional Information, dated May 16, 2005," June 22,
2005
ruSA, "FMRI Alternate Feed License Amendment Application, Revision to Surety
Calculation, White Mesa Mill," July 19, 2005
IUSA, "RE: Application by International Uranium (USA) Corporation for an amendment
to State of Utah Radioactive Materials License No. 1900479 for the White Mesa Uranium
Mill to authorize processing of FMRI, Inc. ("FMRI") alternate feed material," April 1,
2005
IUSA, "RE: Application by International Uranium (USA) Corporation ("IUSA") for an
amendment to State of Utah Radioactive Materials License No. 1900479 for the White
Mesa Uranium Mill to authorize processing of FMRI, Inc. ("FMRI") alternate feed material
(the "Uranium Material")," March 8, 2005
IUSA, "Request to Amend Radioactive Material License White Mesa Mill and
Environmental Report," March 7, 2005
Minnesota Department of Health, Groundwater Health Risk Limits, 2005.
http ://www.health. state.mn.us/di vs/eh/groundwater/hrltable.html
Ohio Environmental Protection Agency, 2005. Vadose Zone Modeling in RCRA Closure.
Department of Hazardous Waste Management. January 7 ,2005
http://www.epa.state.oh. us/dhwm/pdf/VadoseFinal I 22904.pdf
TOXNET, 2005. Hazardous Substances Data Bank,
http ://toxnet.nlm.nih. gov
18
United States Environmental Protection Agency, October 27, 2005, "Relative Source
Contribution for Tin", unpublished agency memorandum from Robert Benson, Ph.D. to
Dean Henderson, Utah Division of Radiation Control
Utah Division of Radiation Control, December 1,2004, Statement of Basis
Utah Department of Environmental Quality, Division of Radiation Control, March 8,2004,
Ground Water Discharge Permit, Permit No. UGW370004.
Utah Department of Environmental Quality, Division of Radiation Control, "Request for
Additional Information Regarding License Amendment Application Radioactive
Materials License UT 1900479," May 16,2005
19
Table 1, Summary of Components in Fansteel Alternate Feed
20
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t
SAFETY EVALUATION REPORT
FOR THE
INTERNATIONAL URANIIJM (USA) CORPO
URANITJM MILL SITE,
WHITE MESA, SAN JUAN COIJNTY
IN CONSIDERATION OF AN
lle.(2) MATERIALS LICENSE UT1900479
DISCHARGE PERMIT NO.
RECEIPT, STORAGE,
FAN STEEL
OI\MENTAL QUALITY
IATION CONTROL
October 14,2005
SAFETY EVALUATION REPORT
FOR THE
FAN STEEL FMRI ALTERNATE FEED
INTERNATIONAL IJRANII'M (USA) CORPORATION'S
URANII]M MILL SITE,
WHITE MESA, SAN JUAN COLINTY, UTAH
Table of Contents
1.0 Introduction
1.1 Bac and Need for Proposed Action
1.2 Previous Altemate Feed
1.3 FMRI Materials
1.4 Review
2.0 Site Characteristics of the White Mesa Mill Area
4.2 Surface Water and Groundwater
4.3 Evaluation of Additional Groundw
4.4 Alternatives
4.6 Report Findin
5.1 License Amendments
5.2 Permit Modi
1.0 INTRODUCTION
1.1 Background and Need for Proposed Action
This draft Safety Evaluation Report (SER) is being perf
environmental impacts of the proposal for the White Mesa
receive and process alternate feed material from Fan Steel'
Muskogee, Okalahoma (the "Muskogee Facility"). The
in San Juan County, approximately 5 miles south of
(USA) Corporation (IUSA) submitted a license
March 8, 2005 and supplemented by letters
L9, 2005, to amend its State of Utah lle.
amendment would allow ruSA to receive
material from the Muskogee Facility.
The Muskogee Facility is being
Regulatory Commission (NRC)
processing ores for the
SAFETY EVALUATION REPORT
FOR THE
FAN STEEL FMRI ALTERNATE FEED
TNTERNATIONAL URANIIJM (USA) CORPORATION'S
URANIUM MILL SITE,
WHITE MESA, SAN JUAN COTINTY, UTAH
ton
The FMRI materials
materials consist of
materials contain resi
IUSA is
content.
the
Mill to
near
located
ranium
r dated
5, and July
79. 'The proposed
tons of alternate feed
ioned under its Nuclear
are residues resulting from
FMRI processing operations.
free liquid.slurry solids with no
niobium, and uranium.
received and processed for its source material
of source material will be disposed in the lined
The
The
(
The
UT]
taili detection monitoring program. Before the State of
was formalized, the Nuclear Regulatory Commission
t requests in the past for separate alternate feed
ma
licensed by the UDRC under the State of Utah lle.(Z) License
byproduct material in the form of uranium waste tailings and
byproduct waste generated by the licensee's milling operations, as well as
material from multiple locations.
Groundwater quality at the IUSA facility is also regulated by State Groundwater Permit
Number UGW370004 (hereafter Permit). After review of the proposal, the Executive
Secretary has determined it necessary to also modify the Permit in order to better monitor
and protect local ground water quality from possible effects of disposal of the proposed
alternate feed material.
1.2 Previous Alternate Feed Proposals
In the Final Application for Uranium Mills and Mill Tailings made by the State of Utah
to the NRC Office of State and Tribal Affairs, the following commitment was made by
the State of Utah:
"The State of Utah recognizes the importance of and supports the uraniu
mining and milling industry The State recognizes that to remain vi
this time, uranium mills must be able to engage in activities
milling conventional mined uranium such as processing
materials for the recovery of uranium alone to together
minerals."
The State of Utah also agreed to use the current NRC
Issues Summary 2000-23) for review and decision of
materials and that each amendment would be considered
the purposes of licensing. These three criteria for {ecisi
acceptance of alternate feed material are:
r the feed
For the tailings and wastes from to qualify as 11e.(2)
byproduct mateial, the feel!"ore." In determining
of ore will be used: Orewhether the feed mate
is a natural or native and treatedfor the extraction of
any of its which source mateial is extracted
in a licensed
The UDRC material does meet this criteria.
ns hazardous
contains hazardous wasted, listed under subpart D
40 CFR (or comparable Resource Conservation and
) authorized State regulations), it would be subject to the
Protection Agency (EAP) or State regulation under RCRA. If
show that the proposed feed material does not contain a listed
e, this issue is resolved.
erial exhibiting only a characteristic of hazardous waste (ignitable,
reactive, toxic) would not be regulated as hazardous waste and could
refore be approved for recycling and extraction of source material. However,
this does not apply to residues from water treatment, so determination that such
residues are not subject to regulation under RCP:/^ will depend on their not
containing any characteristic hazardous waste. Staff may consult with EAP (or
l.
the State) before making a determination of whether the feed mateial contains
hazardous waste.
If the feed material contains hazardous waste, the licensee can process it only if it
obtains EPA (or State) approval and provides the necessary documentation to
that effect. Additionally, for feed material containing hazardous waste, the staff
will review documentation from the licensee that provides a commitment from the
U.S. Department of Energy or the State to take title to the tailings impoundment
after closure.
The FMRI material is tailings from the processing of ore.FR
261.4(b)(7), solid wastes from the extraction, beneficiation, and ing of
ores and minerals are not hazardous wastes. Even if this were , in the
application for license amendment made by IUSA on March made
underthe determination that the FMRI material contained no
subpart D Sections 261.30-33 of 40 CFR.
material content.
For the tailings and waste from the
byproduct material, the ore must be
as 1Ie.(2)
for its Source-material
content. If the only product of the alternate feed is
n addition to uraniumuranium product, this dete
product, another material is ssing of the ore, the
licensee must provide uranium product is the
primary product produc
Originally it its A stated that it might consider
milling the other metals as well as for uranium.
However, in , ruSA stated that the FMRI would only
be milled for i bre this condition is satisfied.
1.3
Currently,
alternate
10.18.
solids.
solids
nse amendments regarding the processing of
10.6 throughsite including License Conditions
submittal they state that from 1960 to 1989, Fansteel, Inc.
natural ores for recovery of tantalum and niobium at its FMRI
Oklahoma. Tantalum ore and tin slag were purchased from around
feed material was leached in concentrated hydrofluoric acid and sulfuric
process dissolved the tantalum and niobium into solution and the insoluble
compounds, such as thorium, radium, and uranium, remained behind in the
These solids were then filtered and collected in Ponds 2 and 3. The leached
faci
the
fl
sent to Ponds 2 and 3 were highly variable and contained on average
approximately 0.87o tantalum (Ta) and O.l7Vo UrOs. The solids in Ponds 2 and 3 contain
residual metal impurities in the fluoride form.
The FMRI materials are comprised of the materials stored in on-site Ponds 2 and 3,
ancillary drummed material, pond cover soils, pond surrounding soils, and debris that
have been impacted by the proposed alternate feed material. The FMRI material has a
uraniumcontentof approximately0.15lTo (O.1787o U:Oa) and0.357Vothoium-232.
1.4 Review Scope: Environmental Analvsis
In accordance with UAC R313-22-38 and R3l3-24-3, this SER serves to:
(1)
(2)
(3)
(4)
(s)
Assess the radiological and non-radiological impacts to the
Assess any impact on waterways and groundwater.
Consider alternatives, including altemative sites and engi
Consider long-term impacts including decommission
reclamation impacts.
Present information and analysis for determini
which support the proposed license amendment.
and
lusions
4
2.0 SITE CHARACTERISTICS OF THE WHITE MESA MILL AREA
The area surrounding the White Mesa facility is in an arid climate with an approximate
annual precipitation of 12-inches and a mean temperature of 50o F. Runoff in the project
area is directed by the general surface topography either westward into Westwater
Canyon, eastward into Corral Creek, or to the south into an unnamed branch of
Cottonwood Wash. The San Juan River, a major tributary to the Colorado River, is
located approximately 18 miles south of the site.
The population density of San Juan County is approximately 1.7 persons per sq le.
The Town of Blanding is the largest population center near the facility with ion
of 3,600. Approximately 3.5 miles southeast of the site is the White Mesa 'ation, a
community of approximately 350 Ute Mountain Ute Indians. The
mill is located approximately 3 miles to the northeast of the m
prevailing wind direction.
Approximately 607o of San Juan County is federally-ow by the
and the
range,
U.S. Bureau of Land Management (BLM), the U.S. Nati
U.S. Forest Service. Primary land uses include li
recreation, and exploration for minerals, oil, and 96. A the is Native
American land owned by either the Navajo Natiqffir t ntain Tribe. The
Iand within 5 miles of the site is predominanffited nts of landing. The
White Mesa mill site encompasses approxi
Groundwater beneath the site mainly a shallow unconfined
aquifer hosted by the Dakota Sandstone formations; and the deep
tailings cells the shallowconfined aquifer in the En
aquifer is found at a depth o(ground surface and consists of
groundwater perched o i of the Morrison formation. The
deep Entrada/Navajo
It is found at a depth
t permeable aquifers in the region.
ground and is separated from the shallow
aquifer by hundreds ty shales and mudstones (e.g. Brushy Basin
and Recapture ormation, the Summerville Formation, etc.).
Recharge to tration along the flanks of the Abajo, Henry, and
La Sal anks of the structural folds. Groundwater in the
shall andstone and Burro Canyon Formation) is monitored
byt detection monitoring program. Water in this zone flows
sou
Ni applications, within a 5 mile radius of the site are on file with
the
and
Bu
the
miles
supply
sup lls are completed in the Entrada./Navajo Sandstone located approximately 4.5
t to the
in the
ineer's Office. The majority of applications are by private individuals
wing small, intermittent quantities of water, less than 8 gpm from the
formation. For the most part, these wells are located upgradient (north) ofI Stockwatering and irrigation are listed as the primary uses. Two deep water
southeast of the site on the Ute Mountain Ute Reservation. These deep water
wells are completed approximately 1200-feet below the ground surface.
3.0 OPERATIONS
The White Mesa uranium mill was developed in the late 1970's by Energy Fuels Nuclear,
Inc. (EFN) as an outlet for the many small mines that are located in the Colorado Plateau.
After about two and one-half years, the mill ceased ore processing and entered a total
shutdown phase. In 1984, u rnuiotity ownership interest was acquired by Union Carbide
Corporation's (UCC) Metals Division, which later became Umetco Minerals Corporation
(Umetco), a wholly-owned subsidiary of UCC. The partnership between UMETCO and
EFN continued until May 26, 1994, when EFN reassumed complete ownership flf the
mill. In May of |997,IUSA purchased the assets of the EFN and is the
and operator of the facility. The mill has gone through several operation
periods through the 1980's and 1990's.
The current license, License Condition 10.1, specifies a max
4380 tons of yellowcake per year. The maximum mill throu
annual freeboard calculations submitted to the UDRC annually
Condition 10.3. This year's maximum allowable
rate of
by the
License
feed.
6
4.0 ENVIRONMENTAL EFFECTS
4.1 RadiolosicalandNon-Radioloeicallmpacts
Radiological Impacts
According to the March 8, 2005 submittal, the following radionuclides are known to exist
in the FMRI alternate feed materials: Ra-22 6, Ra-228, Th-228, Th-230, Th-232, IJ -234,
U-235, and U-238. Concentrations of these radionuclides in FMRI's Tailings Ponds I
and 2 are shown below. These radionuclides are commonly associated with the
decay series and natural thorium decay series. The FMRI material is radi
um
rlly
consistent with other ores and alternate feeds that have been processed at the
Mill.
In the June 22,2005 letter, ruSA the ore pad, the FMRI
materials will be sealed inside a ic bag. The exposure and
dose rates from the esti
approximately the same as
material was found to be
t of low-grade Colorado Plateau
ore.
The March 8,2005 comparisons between the FMRI material
and previous aterials
ng to the March 8, 2005 submittal, the Radioactive Material Profile Record
attached in Appendix 2 to the March 8, 2005, submittal lists the following known and
possible chemical components or hazardous waste characteristics:
u-234
(pCi/e)
Th-232
Concentration
0.15%o
toO.3O7o
(Y)N)(Y)(NI)(Y)0\D
a.Listed IIW x b.Derived-
From [fW
x c.Toxic x
d.Cvanides x e.Sulfates x f.Dioxins x
o Pesticides x h.Herbicides x t.PCBs x
J.Explosives x k Pyrophorics x L Solvents x
m.Orsanics x n.Phenolics x o.Infectious x
D.Isnitable x q.Corrosive x r.Reactive x
s.Antimony x t Beryllium x u.Copper x
v.Nickel x w.Thallium x x.Vanadium J x
v.Alcohols x z.Arsenic x a,A.Barium "rlbb.Cadmium x cc.Chromium x dd.Lead
ee.Mercury x ff.Selenium x oo Silver I
hh.Benzene x ll.Nitrate x il.Nitritr x
kk.Fluoride x lr.oit x mm.Frx x
nn.Chelating
Asents
x oo.Residue fromWater Treatment ,{f x
pp.Other Known of Possible Materials or Chemicals ,JU x
For a detailed list of all the non-radiological chemical ar
the FMRI material, refer to Table 5 and Table 6 of A
submittal. J-
ffiutffi!
RCRA Listed Mater
Wflt':*::,i'titltrT;
RCRA
The following meta
(IUSA, March
Class
Alkali
Alkali
lons
be found in the FMRI material
of FMRI Materials*
um
beryllium, calcium, magnesium
, cadmium, cerium, chromium, cobalt, hafnium,
lanthanum, manganese, mercury, molybdenum,
neodymium, nickel, niobium, praseodymium, scandium,
silver, tantalum, thallium, thorium, tin, titanium,
tungsten, vanadium, yttrium, zinc, zirconium
Aluminum,lead
Arsenic, selenium, silicon
Ammonia, chloride, cyanide, fluoride, nitrate, phosphate
sulfate, sulfide
le Organic Acetone, Methyl isobutyl ketone (MIBK)
-Volatile Organics Di-n-butyl phthalate
*Bold Type = new elements or compounds in the FMRI material, not previously disposed
tailings cells
There may be some residual methyl isobutyl ketone (MIBK) in the FMRI
material. MIBK was used to remove impurities (iron, zirconium, and uranium
from the original tantalum processing stream.
In a May 16,2005,letter to ruSA, UDRC asked IUSA to specifically evaluate the
chemical compatibility of elements and compounds in the FMRI material that do
not currently exist in the tailings ponds. These compounds include: MIBK, Bis
(2-ethylhexyl) Phthalate, Di-n-butyl Phthalate, Cerium, Hafnium, Lan
Niobium, Neodymium, Praseodymium, Scandium, Sulfides, Tantalum,
Yttrium, and Fluoride.
ln a June 22,2005,1etter, ruSA made the following statements:
1) Bis (2-ethylhexyl) Phthalate, Di-n-butyl Phthalate and in low
enough concentrations to be considered "de minimus,"t.o Bis (2-ethylhexyl) Phthalate while reported 2005
of thesubmittal, only exists in FMRI's Tailings
proposed alternate feed material.
Di-n-butyl Phthalate in high enough actually
increase liner and liner joint plasticit touo MIBK and other keytones are cli and joints to
concentrations up to I0Vo.FMRI
ion of
material to the
keytones to 13tailings solution will i
ppm (0.00137o).
2) Sulfides were incorrectly
material. The
any concentration
3) Fluorides have
ores and al
material
tailings s
tailings cel
h
ituents in the FMRI
Sulfates inindicated.
ner and joints.
l's uranium circuit with natural
as 460,000 mdkg. The FMRI
mdkg. The addition of fluoride to the
I concentration of fluoride salts in the
The manufacturer's rating for inorganic
with PVC liners and joints for hydrofluoric
manufacturer's data, metal fluoric salts in any
with PVC liners and joints.
m currently contains high levels of
in metallic salt concentrations will not
metallic salts.
have any effect
and joints.
ter Effects
EVe, during storage on the ore pad, the FMRI material will be sealed in fabric
3 mil polyethylene liner. The FMRI material is expected to have a moisture
of 207o to 307o. There will be no free liquid inside the polyethylene liner.
Therefore it is unlikely that material or liquids will penetrate the bag and become exposed
to stormwater. In the event that the FMRI material became exposed to stormwater, IUSA
has an approved spill management plan and stormwater management plan. All storm
water runoff from the ore pad is routed to Cell l.
Groundwater Effects
As stated above, during storage on the ore pad, the FMRI material will be sealed in fabric
bags with a 3 mil polyethylene liner. The FMRI material is expected to have a moisture
content of 20%o to 307o. There will be no free liquid inside the polyethylene liner.
Therefore, seepage of the material into the groundwater at the ore pad site is not
anticipated. The FMRI material has similar chemical and radiological prope(jps to
natural uranium ore and materials currently stored in the tailings cells.
not anticipated that ore pad storage of the FMRI material would pose any
to the groundwater than conventional ores.
Tailings from the FMRI material processing will be disposed in
along with other process tailings. A groundwater detection
already in place, in accordance with the State issued groundw
any leakage from the tailings cells has occurred.
contamination were to occur, the UDRC would require
it is
risk
cells
IS
ine if
ater
4.3
VE
action to restore groundwater to the groundwater state
groundwater permit.
of Additional Parameters
With the introduction of Fan Steel FMRI l) material to the White
materials needs to beMesa Mill processing, each new con
considered in order to determine if monitoring compliance
parameters are needed IUSA's it (Permit).
In Attachment 5, of IUS March 2005) submittal Table 2,
"Comparison of Urani Feeds", a summary is found of 49
contaminants in the determining if additional groundwater
compliance monitori for the Permit the following criteria were
considered for t
1) Is hcluded as a groundwater monitoring compliance
t increase in concentration in the tailings inventory ?
ile in the groundwater environment (i.e., low soil-water
(Kd)) ?
t represent a known human toxicity hazard,?
vailable and reputable groundwater quality compliance standard ?
A approved analytical methods ?
review process many of the 49 contaminants identified are new to the IUC
a result of the proposed feed stock. Several of these were also of concern
because of large increases in the projected tailing cell inventory after the feed stock is
processed. A total of 26 of the 49 contaminants considered were already required as
groundwater monitoring parameters in the Permit
10
Based on the above criteria tin will be added as a groundwater monitoring compliance
parameter to the Permit. Reasons for the selection of tin and omission of the remaining
22 contaminants are found below. Details are also found in Table I in section 7.0 below.
Contaminant Selected for Groundwater Monitoring Parameter
Tin is currently not a required groundwater monitoring parameter in the Permit, and was
omitted from the original Permit due to non-detectable concentrations reported by IUC in
three tailings leachate samples (see l2lLl04 DRC Statement of Basis, Table 5). B
the proposal in question, tin will experience an estimated increase in the tailing i tory
to5from 9 to248 tons (IUSA, March 2005, Attachment 5). With an estimated
(Ohio EPA, 2005) tin is not as mobile in the groundwater environment als;
however, with the high acid conditions in the tailings wastewater, ti stay in
solution and not partition on aquifer materials. In a memorandum f
(Tetra Tech EM, Inc.) to David C. Frydenlund (IUSA) dated , 2005
(Colsman, September 26, 2005), it was proposed that cadmi as
analogues for tin because they are associated with lead in ores.
However, the coincident occurrence of these mineral of their
groundhigh temperature geochemical environment of depositi
water at the Mill site is a low temperature geochemic uently
cadmium and zinc were not accepted as ground w
Toxic levels of tin can pose a human will adopt an ad hoc
nnesota Department ofgroundwater quality standard for tin
health risk limit for groundwater of 4,000
Contaminants Omitted from G
The following 26 contami se they are already required as
groundwater monitori Permit:
ning 22 contaminants of concern that are not groundwater
include the following four groups with their corresponding DRC
: cyanide, phosphate, and sulfide.
Although there is an expected increase in the concentration in the tailings
inventory, cyanide was omitted because it will was off-gas in the high acid
environment of the White Mesa Mill process. Should cyanide be found in future
Inorganics and llium, calcium, cadmium, chloride,
, cobalt, fluoride, iron, lead, magnesium,
, mercury, molybdenum, nickel, potassium,
ium, silver, sodium, sulfur, thallium, vanadium, and
ll
tailings wastewater sampling under Part 1.H.5, it may be added as a compliance
monitoring parameter at a future date.
Phosphate and sulfide were not required groundwater monitoring parameters in
the Permit, although, there is an increase in inventory, because there was
insufficient information to conclude that they pose a human health risk
(TOXNET,2005).
Metals: aluminum, antimony, barium, cerium, hafnium, Ia
neodymium, niobium, praseodymium, scandium, silicon, tantalum,
m,
UHt
used as
should
titanium, tungsten, yttrium, and zirconium.
Barium, cerium, hafnium, lanthanum, neodymium, niobium ymium,
scandium, tantalum, thorium, tungsten, yttrium, and zirconi ired
as groundwater monitoring parameter in the Permit. AI f these
metals will have an increase in the concentration in t ry. All
were eliminated for monitoring consideration becau g from
40 to 1500 Ukg (Colsman September 9, 2005).
compliance monitoring parameters that have m
be detected well before the arrival of above elimi
Aluminum was also omitted as
Permit; although, there is a predic
This omission is due to the f,
geochemical behavior in groundw
groundwater monitoring parame
be similar concentrati
concentration) in the n
(IUSA, March
estimated Kd o
Consequently,
the arrival of a
Anti
ln
at(
its
ring paiameter in the
inventory concentration.
and iron have similar
ron is already a required
is estimated that there will
with iron having the greater
processing the FMRI material
lower Kd than aluminum (iron
ted Kd of 9.9 (Tetra Tech, 2005)).
are
val
u
'In
and
at the compliance monitoring well before
hn acceptable analog.
groundwater monitoring parameter in the Permit,
ificant increase in the tailings inventory. Further,
similar geochemistry and arsenic is already a required
ng parameter in the Permit. The estimated mass of
Tailings after processing the FMRI material is less than the
arsenic in the Mill Tailings (IUSA, March 2005). Antimony
ons greater than 10,000 mg/L, as in the wastewater in the tailings cells, iron
greater than 1000 are common. The mobility of these constituents away from the
is primarily a function of the total acidity of the solution and the acid-neutralizing capacity
the solution contacts. The acidity of the solution is partly due to the activity of hydrogen;
much greater component is generally due to dissolved iron and aluminum. As the pH of the
solution is raised by reactions with the solid phase iron and aluminum minerals become less soluble and
precipitate producing hydrogen. This reaction produces a much greater acidity provided by the solution
concentration of hydrogen. As a consequence the pH plume and its dissolved constituents will be more
mobile in an acidic solution with high concentrations of iron and aluminum than a plume without these
metals (Deutsch 1997).
l2
has an estimated Kd of 2.0 (ruSA Permit 2004) and arsenic has a estimated Kd of
1.0 (Tetra Tech, 2005). Consequently, arsenic should be detected at the
compliance monitoring before the arrival of antimony.
Titanium is not a required groundwater monitoring parameter in the Permit,
although there is a significant increase in the tailings inventory, there was no
information found the Hazardous Substance Data Bank (HSDB) regarding human
health risk. Further, no Kd information was found in available technical
literature. Since this information was not available titanium was elimi
as a groundwater monitoring parameter. If in the future, such inf ld
come available, the Executive Secretary may require appropriate tr8'
pursuant to Part IV.N of the Permit.
Volatile Organic Compounds (VOC): methyl isobutyl
Methyl isobutyl ketone (MIBK) is not a required itoring
in theparameter in the Permit, in part because there is not
tailings inventory. Also MIBK and Methyl ethyl bers of
the same chemical class (ketones). MEK is ater
monitoring parameter in the Permit and can , in that:
K (afterl) The estimated MEK mass in the tailjl wi
alternate feed processing) (ruSA,has a lower
estimated Kd than MIBK (MEK es A Permit, 20O4) and
MIBK has an estimated Kd of ) consequently, MEK
should be detected at the compli the arrival of MIBK
and therefore an acceptable anal
Semi-Volatile i-n-butyl phthalate.
Di-n-butyl groundwater monitoring parameter
for monitoring in the Permit (seein the Permit.
t2l1lo4, DF':C
monitori
l9). In order to streamline groundwater
addressed in the Permit all semi-VOC
The
for
we
of
yl phthalate were omitted as groundwater
Steel FMRI alternate feed material included 49 contaminants
ing compliance consideration. Of these 49 contaminants, 26
as groundwater monitoring compliance parameters in the Permit.
23 contaminants the Executive Secretary determined that tin should be
groundwater monitoring compliance parameter in the Permit.
4.4
The action that the UDRC is considering is approval of an amendment request to an
lle.(2) material license issued pursuant to UAC R3L3-24 Uranium Mills and Source
t3
Material Mill Tailings Disposal Facility Requirements. Subparagraph UAC R3l3-24-
3(1)(c) requires that alternate sites and engineering methods be considered in the analysis
of the license amendment request.
Based on its review, the UDRC staff has concluded that the environmental impacts
associated with the proposed action do not warrant either the limiting of IUSA's future
operations or the denial of the license amendment. The UDRC staff has concluded that
there are no significant environmental impacts associated with the proposed action.
Other alternatives need not be evaluated.
4.5 Long-Term Impacts
UDRC does not anticipate any significant impacts on the reclamation,
and decontamination of the White Mesa facility, if the FMRI materi
alternate feed. In general, the FMRI material has similar
radiological properties to other alternate feeds and natural
Based
tr8,
as an
non-
been
processed by IUSA. Additional ground water monitoring paflWFs ha ired
to ensure added protection of local ground water
In order to evaluate surety issues in the unlikely prior to
processing the FMRI material, UDRC sent a ay 16,
information as to how much IUSA's financi be adiusted. If this
scenario were to happen, the fabric bagged likely be hauled to the
disposal cell and disposed of directly into dated July 19, 2005,
ruSA included an analysis stating that not need to be increased
already processed otherfor the acceptance of the FMRI materi
alternate feeds, which has than that of the surety
increase for the receipt of t bre the financial surety amount
approved in License This amount is $10,950,180.00.
To ensure that the t to cover the amount of alternate
feed material stored been proposed to License Condition 10.1.
Refer to Section 5.0 fr
of the environmental impacts of the IUSA amendment
ned that there will not be a significant adverse effect on
nt resulting from the IUSA proposal. The following
inmarize this conclusion:
environmental and effluent monitoring program is in place to
releases and to detect whether applicable regulatory limits are
Radiological and non-radiological effluents from site operations have
and are expected to continue to remain below the regulatory limits. A
water monitoring program for the shallow perched aquifer is in place to
detect potential seepage of contaminants from the tailings cells. The deep,
confined Entrada./Navajo Sandstone Aquifer is separated by low permeability
formations from the tailings cells further decreasing a potential impact to deep
4.6
t4
groundwater resources. The potential for seepage to occur while the material is
temporarily stored on the ore pad is minimal due to triple layer packaging, dry
climate, low permeability and highly compacted ore pad surface, and the limited
duration of storage. Further, decommissioning and reclamation activities at the
storage pad can remove and place such any contaminants, should it occur, in the
tailings cell for long-term control. An existing dust suppression progmm will be
implemented at the mill to reduce the potential for airborne contamination.
An approved radiation safety program is in place at the mill. Site
postings required by License Condition 9.9 are in place at entrances to
In the past, all worker Total Effective Dose Equivalents (TEDEs)
found to be well below the 0.05 Sv (5 rem) annual limit specified i
15-201 (10 CFR 20.1201). The licensee has also imple
program as consistent with NRC Regulatory Guide 8.22, "
Mills."
3.Present and potential environmental impacts from
the FMRI material were assessed. No significant j
a result of this action. Therefore, the staff has
R3l3-
oassay
ranlum
ing of
ified as
risk
15
5.0 PROPOSED LICENSE AMENDMENTS AND PERMIT MODIFICATIONS
5.1 License Amendments Proposed
The following license condition changes would result from this license amendment. The
changes are presented in redline-and-strikeout format.
10.1 The mill production rate shall not exceed 4380 tons of yellowcake per IA.
year.
Maximum ouantities of f
the submittal to the
2005:
l) Anv combination of al lk fo
shall not to exceed 78.000 tons, and
ate feed s is not
to exceed 33--500 barrels.55
gallons.
C.The licensee shall rior to receivins
0res.
Iicab
.19 The licensee from ,
with
uests and dated March 7
22.2405.
Additi ive license amendment will be made. This former
refi as part of the initial license conversion.
12.it a detailed decommissioning plan to the NRGErcEgltrg
twelve (12) months prior to planned final shutdown of mill
includes a detailed Quality Assurance Plan. The plan will be in
with NRC Regulatory Guide 4.15, "Quality Assurance for
Monitoring Programs" and NUREG- I 575, "Multi-Agency Radiation
and Site Investigation Manual (MARSSIM)" or equivalent most current
[Applicable NRC Amendment: 13]
IApplicable UDRC Amendment: 2l
16
5.2 Permit Modifications Proposed
Tin is proposed to be added as an additional required groundwater monitoring parameter
to the Permit. Changes that will be added to Table 2 of the Permit, in redline-and-
strikeout, format presented in Attachment I below.
L7
6.0 REFERENCES
Colsman Mark R., September 9, 2005, memorandum, Subject: Survey of Reference
Partition Coefficient Values for Trace Heavy Metals in Fransteel Metal, Inc. ("FMRI")
Uranium Materials, from Mark R. Colsman, Ph.D. to David C. Frydenlund.
Memorandum, September 9, 2005, sent by e-mail to the Utah Division of Radiation
Control from David C. Frydenlund to Loren Morton.
Colsman Mark R., September 26, 2OO5, memorandum, Subject: Geochemical B
Analogues of Proposed Additional Monitoring Parameters, from Mark R. Cols
to David C. Frydenlund. Memorandum, September 27, 2005, sent by e-mail
Division of Radiation Control from David C. Frydenlund to Loren Morton.
International Uranium (USA) Corporation (IUSA), "Revised
Reclamation of the White Mesa Mill and Tailings Management S (Jtah,"
February 2OO5.
IUSA, "RE: FMRI Alternate Feed License A icglion,of
for
.D.
tah
for
Environmental Quality Request for Additional In
22,2005
IUSA, "FMRI Alternate Feed License
Calculation, White Mesa Mill," July 19,
ruSA, "RE: Application by International
to State of Utah Radioactive Materials Li
Mill to authorize processing of
2005
IUSA, "RE: Applicati
amendment to State
Mesa Uranium Mill
," June
to Surety
ion for an amendment
the White Mesa Uranium
feed material," April 1,
(USA) Corporation ("IUSA") for an
ials License No. 1900479 for the White
of FMRI, Inc. ("FMRI") alternate feed
material (the "8,2005
IUSA, K Material License White Mesa Mill and
Envi
Min th, Groundwater Health Risk Limits, 2005.
I Protection Agency, 2005. Vadose Zone Modeling in RCRA Closure.
s Waste Management. January 7,2005
TO ,2005. Hazardous Substances Data Bank,
http ://toxnet.n lm.ni h. gov
Utah Division of Radiation Control, December 1,2004, Statement of Basis
l8
Utah Department of Environmental Quality, Division of Radiation Control, March 8,
2004, Ground Water Discharge Permit, Permit No. UGW3700O4.
Utah Department of Environmental Quality, Division of Radiation Control (UDRC),
"Request for Additional Information Regarding License Amendment Application -
Radioactive Materials License UT 1900479," May 16,2005
t9
7.0 Table 1, Summary of Components in Fan Steel Alternate Feed
20
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JON M, HUNTSMAN, JR.
Govemor
GARY TIBRBERT
Lieutenant Governor
Department of Envlronmental
Quallty
Dlvlslon of Radlatlon Control
168 North 1950 We3t
Sall Lake Clty, Utah 841 16
(801)53C4250 Main Offlcely'oice Mail
(801)533-40e7 FA)(
[phone] TDD
htto:/Arww.deo. utah.oov
htto ://www. radiationcontrol. utah.oov
State of Utatt
Department of
Environmental Quality
Dianne R. Niclso, Ph.D.
Executive Directc
DIVISION OFRADI,ATION
CONTROL
Dane L Frncrtoct
Dircctor
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9.8
DRC-03
Page 6 of 15
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #]JT1900479
Amendment 1
Archeological contractors shall be approved in writing by the Utah SFIPO. The Utah SI{PO
will approve an archeological contractor who meets the minimum standards of the State of
Utah as the principal investigator.
The licensee is hereby authorized to possess byproduct material in the form of uranium waste
tailings and other uranium byproduct waste generated by the licensee's milling operations
authorized by this license. Mill tailings shall not be transferred from the site without specific
prior approval of the Executive Secretary in the form of a license amendment. The licensee
shall maintain a permanent record of all transfers made under the provisions of this
condition.
The licensee is hereby exempted from the requirements of R313- 15-902(5) for areas within
the mill, provided that all entrances to the mill are conspicuously posted in accordance with
R3l3-15-902(5) and with the words, "Any area within this mill may contain radioactive
material".
9.9
9.10 Release of equipment or packages from the restricted area shall be in accordance with the
NRC "Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material," dated May 1987, or suitable alternative procedures approved by the Executive
Secretary prior to any such release.
9. t 1 The final reclamation shall be in accordance with the May 1999, Reclamation Plan Revision
2.0, Attachment A, submitted to the NRC on June 22,1999, and Revision 3.0 submitted to
the NRC on July L7,2000. Prior to the placement of alternate feed material, the licensee
shall determine that adequate cell space is available for that additional material. This
determination shall be made by a SERP-approved procedure.
SBCTION 10: OPERATIONAL CONTROLS, LIMITS, AND RESTRICTIONS
10.1 A. The mill production rate shall not exceed 4380 tons of yellowcake per year.
B. Maximum quantities of feed material stored on the mill site. including the ore pad, in
accordance with the submittal to the UDRC dated July 19. 2005:
(1) Any_combination of alternate feed material stockpiled in bulk form shall not
to exceed 78.000 tons. and
DRC-03
Page 7 of 15
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
ST]PPLEMENTARY SHEET
License #!lf-1900472
Amendment I
(2) Any combination of alternate feed material stored in barrels is not to exceed
33,500 barrels. Banel volume shall not to exceed 55 gallons.
C. The licensee shall notify the Executive Secretarv prior to receiving natural ores.
lApplicable UDRC Amendment: ll
10.2 All liquid effluents from mill process buildings, with the exception of sanitary wastes, shall
be returned to the mill circuit or discharged to the tailings impoundment.
10.3 Freeboard limits for Cells 1-I, 3, and 4A, shall be set periodically in accordance with the
procedures set out in Section 3.0 to Appendix E of the previously approved NRC license
application, including the October 13, 1999 revisions made to the January 10, 1990 Drainage
Report. The freeboard limit for Cell 3 shall be recalculated annually in accordance with the
procedures set in the October 13, 1999 revision to the Drainage Report.
[Applicable NRC Amendment: 16]
10.4 Disposal of material and equipment generated at the mill site shall be conducted as described
in the licensee's submittals to the NRC dated December 12,1994 and May 23,I995,with the
following addition:
A. The maximum lift thickness for materials placed over tailings shall be less than 4-feet
thick. Subsequent lifts shall be less than 2-feet thick. Each lift shall be compacted
by tracking of heavy equipment, such as a Cat D-6, at least 4 times priorto placement
of subsequent lifts.
10.5 In accordance with the licensee's submittal to the NRC dated May 20,1993, the licensee is
hereby authorized to dispose of byproduct material generated at licensed in-situ leach
facilities, subject to the following conditions:
A. Disposal of waste is limited to 5000 cubic yards from a single source.
B. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize
void spaces. Barrels containing waste other than soil or sludges shall be emptied into
the disposal area and the barrels crushed. Barrels containing soil or sludges shall be
verified to be full prior to disposal. Barrels not completely full shall be filled with
tailings or soil.
PAGES: ,fTIME: i :00
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DArE: i/ett of
FROM: Faxed Bv:To: Horo (,
ION M. HUNTSMAN, JR.
Govcnnr
GARYHERBERT
Lieuuna$ Govcrnor
Department of Envlronmenta!
Quallty
Divlslon of Radlatlon Control
168 North 1950 West
Salt Lake Oty, Utah 84116
(801 )536-4250 Main OfffceAy'oica Mall
(80l)533-4097 F$(
(801)53$4414 TDD
http://www.deq. utah.oov
State of Utatr
Department of
Environmental Quality
Diaone R. Niclson, Ph.D.
Executive Direc-tor
DIV$ION OF RADIATION
CONlROL
Dane L Finerfrock
Dfucbr
htto ://www. radiationcontrol. utah.gov
CO../DEPT. T u ,4
_3gcl-V(60
FAX#: 3o9'3t&l- Lll
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COMMENTS
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9.8
DRC-03
Page 6 of15*5
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #III1900479
Amendment 1
Archeological contractors shall be approved in writing by the Utah SF{PO. The Utah SIIPO
will approve an archeological contractor who meets the minimum standards of the State of
Utah as the principal investigator.
The licensee is hereby authorized to possess byproduct material in the form of uranium waste
tailings and other uranium byproduct waste generated by the licensee's milling operations
authorized by this license. Mill tailings shall not be transferred from the site without specific
prior approval of the Executive Secretary in the form of a license amendment. The licensee
shall maintain a permanent record of all transfers made under the provisions of this
condition.
The licensee is hereby exempted from the requirements of R3l3-15-902(5) for areas within
the mill, provided that all entrances to the mill are conspicuously posted in accordance with
R3l3-15-902(5) and with the words, "Any area within this mill may contain radioactive
material".
9.10 Release of equipment or packages from the restricted area shall be in accordance with the
NRC "Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material," dated May 1987, or suitable alternative procedures approved by the Executive
Secretary prior to any such release.
9.11 The final reclamation shall be in accordance with the May 1999, Reclamation Plan Revision
2.0, Attachment A, submitted to the NRC on June 22,1999, and Revision 3.0 submitted to
the NRC on July L7,2000. Prior to the placement of alternate feed material, the licensee
shall determine that adequate cell space is available for that additional material. This
determination shall be made by a SERP-approved procedure.
SECTION 10: OPERATIONAL CONTROLS, LIMITS, AND RESTRICTIONS
10.1 A. The mill production rate shall not exceed 4,380 tons of yellowcake per year.
B. Maximum guantities of feed material stored on the mill site. including the ore pad. in
accordance with the submittal to the IIDRC dated July 19. 2005:
(1) Anv combination of naturalore and alternate feed material stockpiled in bulk
form shall not to exceed 78.000 tons. and
9.9
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
DRC-03
PageT ofl5*5
License #W_1900472
Amendment I
(2) Any combination of natural ore and alternate f'eed material stored in barrels
is not to exceed 33.500 banels.OBarrel volume shall not ter€xceed 55 gallons.
IApplicable uDRC Amenclment: ll aJ,,tJ*)
10.2 All liquid effluents from mill process buildings, with the exception of sanitary wastes, shall
be returned to the mill circuit or discharged to the tailings impoundment.
10.3 Freeboard limits for Cells l-I, 3, and 4A', shall be set periodically in accordance with the
procedures set out in Section 3.0 to Appendix E of the previously approved NRC license
application, including the October 13, 1999 revisions made to the January 10, 1990 Drainage
Report. The freeboard limit for Cell 3 shall be recalculated annually in accordance with the
procedures set in the October 13, 1999 revision to the Drainage Report.
[Applicable NRC Amendment: 16]
10.4 Disposal of material and equipment generated at the mill site shall be conducted as described
in the licensee's submittals to the NRC dated December 12, L994 andMay23,l995,with the
following addition:
A. The maximum lift thickness for materials placed over tailings shall be less than 4-feet
thick. Subsequent lifts shall be less than 2-feet thick. Each lift shall be compacted
by tracking of heavy equipment, such as a Cat D-6, at least 4 times priorto placement
of subsequent lifts.
10.5 In accordance with the licensee's submittal to the NRC dated May 20,1993, the licensee is
hereby authorized to dispose of byproduct material generated at licensed in-situ leach
facilities, subject to the following conditions:
A. Disposal of waste is limited to 5000 cubic yards from a single source.
B. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize
void spaces. Barrels containing waste other than soil or sludges shall be emptied into
the disposal area and the barrels crushed. Barrels containing soil or sludges shall be
verified to be full prior to disposal. Barrels not completely full shall be filled with
tailings or soil.
C. All waste shall be buried in Cell No. 3 unless prior written approval is obtained from
the Executive Secretary for alternate burial locations.
DRC-03
Page 12 of !!45
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
STJPPLEMENTARY SHEET
License #!/f1900472
Amendment I
10.19 The licensee is authorized to rcceive and process source material from FMRI's Muskogee
Facility located in Muskogee. Okalahoma, in accordance with statements. representations.
and commitments contained in the amendment requests and sr:bmittals to the Executive
Secretary dated March 7. 2005 and June 22, 2005.
lApplicable UDRC Amendment: 1l
SECTION 11: MONITORING, RECORDING, AND BOOKKEEPING REQUIREMENTS
1 1.1 The results of sampling, analyses, surveys and monitoring, the results of calibration of
equipment, reports on audits and inspections, all meetings and training courses required by
this license and any subsequent reviews, investigations, and corrective actions, shall be
documented. Unless otherwise specified in the State of Utah regulations all such
documentation shall be maintained for a period of at least five (5) years.
ll.2 The licensee shall implement the effluent and environmental monitoring program specified in
Section 5.5 of the renewal application, as amended by the submittal to the NRC dated June 8,
1995, and as revised with the following modifications or additions:
Stack sampling shall include a determination of flow rate.
Surface water samples shall also be analyzed semiannually for total and dissolved
U-nat, Ra-226, and Th-230, with the exception of the Westwater Creek, which shall
be sampled annually for water or sediments and analyzed as above. A sediment
sample shall not be taken in place of a water sample unless a water sample was not
available.
Groundwater sampling shall be conducted in accordance with the requirements in
License Condition I 1.3.
The licensee shall utilize lower limits of detection in accordance with Section 5 of
the NRC Regulatory Guide 4.14, as amended, for analysis of effluent and
environmental samples.
E. The inspections performed semiannually of the critical orifice assembly committed to
in the submittal to the NRC dated March 15, 1986, shall be documented. The critical
orifice assembly shall be calibrated at least every 2 years against a positive
displacement Roots meter to obtain the required calibration curve.
A.
B.
C.
D.
fb;neFin-ffi
From:
To:
Date:
Subject:
Dane Finerfrock
Frydenlund, David
7112120059:32:27 AM
FMRlAlternate Feed
Dave: I wanted to respond to your questions about the amendment approval for FMRI feed. Here is our
remaining issue. You have requested the approval be granted now. However when we asked that you
provide documentation that the surety was adequate to cover the disposal of the 32000 tons of FMRI ore
in the tailings ponds , the position taken was that a year or so from now when IUC receives the material,
there will be changed conditions over todays circumstances that potentially will allow you to demonstrate
that the surety is adequate.
I am not comfortable granting a license amendment under that circumstance. Furthermore, if I did so, it
would be contrary to established approaches already in place with a number of other Utah licensees that
have surety requirements. Our proposalto resolve this is the following: Please provide a cap by volume,
tonnage , containers, etc. on the feed stock on the ore pad that would, in theory, require reclamation and
demonstrate that there is adequate funding to do so. This information will be used in a license condition. lt
provides a simple determination for inspection purposes by reviewing inventory information. As long as
there is a license condition that has a cap and associated surety funding, all alternate feed issues will be
adequately addressed upon amendment approval and at some point when the feed stock is received.l feel
thats a much stronger position if questioned by the interested parties.
ln your Feb, 2005 reclamation cost estimate document, IUC indicates there was approximately 45000
yards of Linde feed and 55000 drums of Cameco feed currently funded. lt makes sense to us that those
figures could be a starting place for establishing caps.
lf this type of an approach is not acceptable please provide an alternative that meets the stated goals.
Please call me if you have questions.
Page 1
roN M. HUIilAN, JR.
Govemor
GARYHERBERT
Licutetunt Govemor
Q,;
State of Utatt
Department of
Environmental QualitY
Dianne R. Nielson, Ph'D.
Executive Director
DrvrsroNilfi$rArloN May 16,2005
Dane L. Finerfrock
Director
David C. Frydenlund
Vice President and General Counsel
International Uranium (USA) Corporation
Independen ce Plaza, Suite 950
I 050 Seventeenth Street
Denver, CO 80265
Request for Additional Information Regarding License Amendment Application -
Radioactive Materials License UT 1900479
Dear Mr. Frydenlund:
The Division of Radiation Control (DRC) has received the March7,2005 application for a license
amendment to authorize receipt and processing of alternate feed materials by the International
Uranium (USA) Corporation (IUC) at the White Mesa Uranium Mill facility. The proposed 32,000
tons of alternate feed materials are residues resulting from processing ores from 1960 to 1989 for the
extraction of tantalum and niobium at FMRI, a subsidiary of Fansteel lnc.
It is the understanding of the DRC that the licensee is proposing the alternate feed material consisting
of "dewatered sludge" be excluded from RCRA under the provision of Title 42 of the United States
Code (USC) Chapter 82, S 6921, as amended. Upon evaluation of the documentation IUC has
provided, the DRC has no issue with the exclusion. However, the DRC requests additional
information on the following outstanding issues:
l. The FMRI waste profiles indicated that the waste stream included several contaminants that
have not been adequately assessed as to the cumulative effect they may pose to the integrity of
the pond liner, especially where the liner sections are joined. These contaminates include:
- 4 methyl2-pentanone [a.k.a. methyl isobutyl ketone ("MIBK")], Bis (2-ethylhexyl),
Di-n-butyl phthalate, cerium, hafrrium, lanthanum, niobium, neodymium,
Praseodymium, Scandium, Sulfide, Tantalum, Tungsten, Yttrium, and fluoride.
Please evaluate the chemical compatibility of contaminants with the pond liner. seam integrity
and sroundwater quality.
168 North 1950 West. PO Box 1,14850. Salt Irke City, UT 84114-4850. phone [phone]' fax (801) 533a097
T.D.D. (801 ) 5364414. www.deq.utah.gov
{
Page2
2. The waste is described as arriving in "fabric bags". The request also describes the "dewatered
sludge,, as having an average moisture content of 3OVo. The previously submitted report titled,
..Eviluation of pitential foi Seepage of Constituents Present in Altemate Feed Materials into the
ore Storage pad," dated June 28, 2cf]i2, does not evaluate material with a moisture content as
high as 3d7obeingstored on the ore pad. Please evaluate the fabric bags for possible leakase.
3. page l2of the license amendment request states that you may considgr rgcoveri-ng tantalum or
other metals in addition to the uranium product in the alternate feed. In the NRC memorandum
..Redistribution of NRC Regulatory Issue Summary 2W-23 Recent Changes to Uranium
Recovery policy: dated Aprit t9, iOOl',the NRC includes criteria for determine whether or not
u non-natoral oie can be process as an alternate feed. Criteria 3 states:
..... the ore must be processed primarily for its source-material content. If the only product
produced in the processing of the altemate feed is uranium product, this determination is
satisfied. r in aaaition to uranium to uranium product, another material is also produced in
the processing of the ore, the licensee must provide documentation showing that the
uranium product is the primary produced"'
Should the Licensee choose to recover uranium only, no documentation is required. Should the
Licensee choose to recover any material in addition to uranium, the Licensee must notify the
DRC and provide documentation that the uranium product will be the primary product produced.
4. The financial surety for IUSA requires that the current cost estimate be evaluated in regards to
disposal process with each alternate feed and associated costs be itemized. The March 7,2005
,"port did not address any surety costs associated with FMRI material, in the unlikely event that
nise close prior to proclssing the material. Please provide a surety increase estimate.
If you have any questions, please contact Christine Hiaring at (801) 5364OM'
Manager
JIVCMH:ch
Hul
LlWUranium Mills Section
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DIVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
TO:
FROM:
DATE:
State of Utah
Department of
JoN M.0rro*, r*.
Governor
GARY HERBERT
Lieutenant Govemor
Christine Hiaring
MEMORANDUM
Johnathan P. Cook f/Z-%'LI
Apil22,2005
SLJBJECT: Outstanding Engineering Issues Related to the April 1,2005 FMRI Alternate Feed
License Amendment Request
ruSA submitted a report dated April 1, 2005 requesting a license amendment to store and process
alternate feed material from the FMRI, Inc. site located near Muskogee, Okalahoma. This
proposed license amendment would allow for the storage and processing of up to 32,000 dry tons
of "dewatered sludge". There are three outstanding engineering issues that need to be addressed
in a resubmittal from ruSA.
l. The waste is described as arriving in "fabric bags". The report also describes the
"dewatered sludge" as having an average moisture content of 307o. If the fabric bags do
not have a waterproof liner, it seems likely that moisture could leach out of the bag and
into the ore pad. The previously submitted report titled, "Evaluation of Potential for
Seepage of Constituents Present in Alternate Feed Materials into the Ore Storage Pad",
dated June 28, 2002, does not consider ores with a moisture content as high as 307o being
stored on the ore pad. We request that ruSA use fabric bags that have a waterproof
interior liner.
2. On page 12 of the license amendment request, ruSA states that they may consider
recovering tantalum or other metals in addition to the uranium product in the alternate
feed. In the NRC memorandum, "Redistribution of NRC Regulatory Issue Summary
2000-23 Recent Changes to Uranium Recover Policy" dated April 19, 2001, the NRC
includes criteria for determining whether or not a non-natural ore can be processed as an
alternate feed. Criteria 3 states:
"... the ore must be processed primarily for its source-material content. If the only
product produced in the processing of the alternate feed is uranium product, this
168 North 1950 West. PO Box 144850. Salt Lake City, UT 841 14-4850. phone [phone]. fax [phone]
T.D.D. (801) 536-M14. www.deq.utah.gov
lltah!
lNhere ideas connect^
PageZ
determination is satisfied. If, in addition to uranium product, another material is also
produced in the processing of the ore, the licensee must provide documentation
showing that the uranium product is the primary product produced."
ruSA needs to make the determination as to whether they will or will not recover
materials other than the uranium product. If they decided to recover additional materials,
ruSA needs to prove that the uranium product is the primary product being produced.
3. The financial surety for IUSA requires the disposal process and costs associated with each
alternate feed be itemized. The April 1,2005 report did not address any surety costs
associated with disposal of the FMRI material should, in the unlikely event, IUSA close
prior to milling the material. ruSA needs to provide a surety increase estimate.
From:
To:
Date:
Sublect:
John and Chris,
Loren tvlorton
ChristinQ Hiaring; Johnathan Cook
1Of24120O511:36:59 AM
Fwd: Safety Evaluation Report for FMRI Materials
IUG has proposed some cfranges to the SER language for the Fansteel altemate feed material. Some of
Frydentund's email and pr$vid6 me feedback by Wednesday, Oct. 26. Are you OK with their suggestedchanges? i
Thanks,
Loren
I
Dean Hdnderson; John Hultquist
Page I of 2
Johnathan Cook - Fwd: Safety Evaluation Report for FMRI
o
Materials
From:
To:
Date:
Loren Morton
Christine Hiaring; Johnathan Cook
l0l24l2005ll:36 AM
Subject: Fwd: Safety Evaluation Report for FMRI Materials
CC:Dean Henderson; John Hultquist
Loren,
Attached is your draft SER for the FMRI Materials, blacklined to indicate our suggested changes. ln addition to
the blacklined changes, we also propose that the following additional changes be made to the SER and Table 1
thereto:
Table 1 should be amended by adding three columns: one showing the current estimated
concentration of each parameter in the Mill's tailings; one showing the estimated concentration of
each parameter in the Mill's tailings after processing the FMFII Materials; and one showing the
percentage increase or decrease in the concentration as a result of the processing. These columns
can be taken lrom Jo Ann Tischler's Table 2 to Attachment 5 to IUSA's March 8, 2005license
amendment application. We believe it is important to add these columns so that the reader can
obtain a better understanding of the impact of the FMRI materials on the Mill's tailings. By just
showing the changes in mass, the reader is not able to gain this understanding. For example, the
mass of any constituent will always increase because adding the mass of a constituent in the FMRI
materials to the existing mass in the Mill' s tailings will by definition always increase the total mass in
the Mill's tailings, even if the constituent is at a lower concentration in the FMRI materials than it
currently is in the Mill's tailings. Rather than just showing an increase in the mass of all constituents,
as currently set out in Table 1, by adding these three columns, the reader can see that in many cases
the concentrations will actually decrease or stay relatively constant. In addition, the references in
Table 1 should be references to lnternational Uranium (USA) Corporation and not references to
lnternational Uranium Corporation. Also, NQ should refer to "Not Quantified", rather than "Not
Qualified".
IUSA proposes an alternate health-based level ot 22,000 ug/L for tin. This level is consistent with
the risk-based concentrations (RBCs) and preliminary remedial goals (PRGs) for tap water that have
been developed by EPA Regions 3, 6, and g, and that have been used for risk screening by EPA
Region 8 and states within Region 8. These RBCs and PBGs are published at
http://www.epa. gov/reg3hwmdlrisk/h uman/rbc/rbc0405. pdf ,
http;//www.epa, gov_i1egion09/was!e/sf un d/pry/f iles/04p19!able.pdf ,
hllp.l/wurw.epa.gp-v"1_earthlr$l0pdlrqa_clp,+llss!:een.[-tp1. These FIBCs and PFtGs are updated
regularly and calculated in accordance with EPA's Risk Assessment Guidance for Superfund
(http://www.epa.gov/oswer/riskassessmenVrisk superfund.h_t!0 ). Relative to the RBC/PRG of 22,000
ug/L lor tin, the Minnesota health-based limit of 4,000 ug/L proposed by the State uses the same
reference dose of 0.6 mg/kg/day for ingestion of tin. However, the Minnesota value includes
additional conservatism and uncertainty in the form of a fractional exposure lactor (called the Flelative
Source Contribution Factor) that attempts to estimate the amount of tin risk from groundwater
ingestion relative to other unspecified exposure pathways. This fractional exposure factor of 0.2 is a
default value (i.e., it is not site-specific) that may not be applicable to exposure pathways associated
with the Mill. ln other words, the Minnesota standard assumes that an individual receives 80% of the
permissible amount of tin from exposure pathways other than ingestion of groundwater, leaving only
2O"/o of the permissible level (i.e. 4000 ug/L assuming two liters of water ingested per day) available
from ingestion of groundwater. There is no reason to make this assumption for users of groundwater
near the Mill site. We do not believe this approach is universally accepted or that it is the approach
normally taken by the State of Utah. The more standard approach adopted by EPA Regions 3, 6 and
9 would appear to be more appropriate. As a result, we propose that the GWCLs in Table 2 ol the
Groundwater Discharge Permit be based on the 22,AO0 ug/L standard for tin and not the 4,000 ug/L
standard.
1.
2.
file:i/C:\Documents and SettingsUpcook\Local Settings\Temp\GW)00001.HTM to126t2005
Page 2 of 2
lf you have any questions or require any further information, please give me a call. I would suggest that once you
have had a chance to review our proposed changes we have a telephone conference to address any comments
or questions you may have on our suggestions. This will allow us to explain our thinking behind some of our
suggestions. Please let me know what works best for you.
David C. Frydenlund
Vice President and General Counsel
lnternational Uranium (USA) Corporation
1050 17th Street, Suite 950
Denver, CO 80265
Tel: [phone]
Fax: [phone]
www.intluranium.com
file://C:\Documents and SettingsUpcook\Local Settings\Temp\GW)00001.IITM tot26t200s
SAFETY EVALUATION REPORT
FOR THE
TNTERNATTONAL URANTIJM (USA) CO
WHITE MESA URANII.IM
I+I{ITS{4SSA,-SAN JUAN COT JNTY
IN CONSIDERATION OF AN A
H€dARADIOACTIVE -MATERIALS LI
WATER QUALITY DISCHARGE
RECEIPT, STORAGE, AND PRMAL
R THE
EEL +I{E
IRONMENTAL QUALITY
TION CONTROL
October 14,2005
SAFETY EVALUATION REPORT
FOR THE
FANSTEELFAN+FEELFMRI ALTERNATE FEED MA'TERIAL
INTERNATTONAL URANTIJM (USA) CORPORATTONS
WHITE MESA
URANIUM MILT,STFE,
wrrr+E+ms rsAN JUAN coIJNTy, UTAH
Table of Contents
1.0 Introduction
Background and Need for
1.2 Previous Alternate Feed
2.0 Site Characteristics of the White Mesa Mill Area
4.1 Radiolosical and Non-Radiol
4.2 Surface Water and Groundwater
4.3 Evaluation of Additional Grou
Parameters
4.4 Alternatives
4.5 Long-Term Impacts
5.2 Permit Modificati
1.0
SAFETY EVALUATION REPORT
FOR THE
FAN-STEEL FMRI ALTERNATE FEED MAIEBIAL
TNTERNATTONAL URANTUM (USA) CORPORATTON2S
WHITE MESA
URANII.]M MILL€ISE,
wrr+TE+4ESAiSAN JUAN COLINTY, UTAH
INTRODUCTION
1.1 Background and Need for Proposed Action
This draft Safety Evaluation Report (SER) is being
environmental impacts of the proposal for the White Mesa
receive and process alternate feed material from lhC_Fa
facility located near Muskogee, Okalahoma (the
mill site is located in San Juan County, approxi
lnternational Uranium (USA) Corporation
application by letter dated March 8, 2005
2005, Jane 22, 2005, and July 19, 2005,
Materials License No. UT1900479.
receive and process up to 32,000 tons
Facility.
The Muskogee Facility
Regulatory Commission
processing ores for the
The FMRI materials
materials consi
materials
IUSA
con
li
Uta
(
ma license.
the
Mill to
FMRI
Mesa
anding.
amendment
letters'dated April l,
would allow IUSA to
ial from the Muskogee
ssioned under its Nuclear
rials are residues resulting from
obium.
the FMRI processing
slurry solids with no
operations.
free liquid.
The
The
The
Di
um, niobium, and uranium.
be received and processed for its source material
dxtraction of source material will be disposed in the mill's
water detection monitoring program. Before the State of
status was formalized, the Nuclear Regulatory Commission
amendment requests in the past for separate alternate feed
by the Utah Department of Environmental Quality.
UDRC) under the-State of Utah ++e,€)Bae[gaq!iIg
License_Ns. UT19OO479 to receive and process natural uranium-bearing ores
including certain specified alternate feed materials. and to possess byproduct material in
the form of uranium waste tailings and other uranium byproduct waste generated by the
licensee's milling operations. iens.
Groundwater quality at the IUSA facility is also regulated by State Groundwater Permit
Number UGW370004 (hereafter Permit). After review of the proposal, the Executive
Secretary has determined it necessary to also modify the Permit in order to better monitor
and protect local ground water quality from possible effects of disposal of the proposed
alternate feed material.
1.2 Previous Alternate Feed Prooosals
In the Final Application for Uranium Mills and Mill Tailings made by the S
to the NRC Office of State and Tribal Affairs, the following commitment
the State of Utah:
"The State of Utah recognizes the importance of and supportsl
mining and milling industry The State recognizes that to
this time, uranium mills must be able to engage in
milling conventional mined uranium such as
materials for the recovery of uranium alone
minerals."
The State of Utah also agreed to use the current atory
Issues Summary 2O0O-23) for review and
materials and that each amendment would
the purposes of licensing. These three cri
acceptance of alternate feed material are:
For the tailings
byproduct mate
whether the
is a natural
alternhte feed
amendment for
ng regarding the
processing to qualify as 11e.(2)
qualifi as "ore." In determining
owing definition of ore will be used: Ore
be mined and treated for the extraction of
any of i 'matter from which source material is extracted
tna mill.
that the FMRI material does meet this criteria.
'feed mateial contains hazardous wasteCg listed under subpart D
1.30-33 of 40 CFR (or comparable Resource Conservation and
Act (RCRA) authorized State regulations), it would be subject to the
vironmental Protection Agency (EAPfil or State regulation under RCRA.
licensee can show that the proposed feed material does not contain a listed
rdous waste, this issue is resolved.
Feed material exhibiting only a characteristic of hazardous waste (ignitable,
corrosive, reactive, toxic) would not be regulated as hazardous waste and could
Previous Alternate Feed Proposals
therefore be approved for recycling and extraction of source mateial. However,
this does not apply to residues from water treatment, so determination that such
residues are not subject to regulation under RCRA will depend on their not
containing any characteistic hazardous waste. Staff may consult with EAPP_!
(or the State) before making a determination of whether the feed material
contains hazardous w aste.
If the feed mateial contains hazardous waste, the licensee can process it only if it
obtains EPA (or State) approval and provides the necessary documentatign to
that effect. Additionally, for feed material containing hazardous waste,
will review documentation from the licensee that provides a
U.S. Department of Energy or the State to take title to the tailings.
after closure.
The FMRI material is tailings from the processing of CFR
261.4(b)(7), solid wastes from the extraction,ing of
ores and minerals are not hazardous wastes. Even if in the
application for license amendment made by A made
the determination that the FMRI material contai under
subpart D Sections 261.30-33 of 40 CFR
of whether the maril for its
material content.
For the tailings and waste from to qualifu as 1le.(2)
byproduct material, the ore ly for its source-material
content. If the only
uranium product,
product, another
licensee must that the uranium product is the
primary
Origi , ruSA stated that it might consider
mill talum and other metals as well as for uranium.
,2005 letter, ruSA stated that the FMRI materialfor its uranium content. Therefore. no further
Therefure-this condition is satisfied.
has 13 license amendments
l5_@alternate feed materialg from various siteg
in License Conditions 10.6 through 10.18.
's March 8, 2005 submittal they state that from 1960 to 1989, Fansteel;{ne.
the
3.
1.3
In
$ans+eel) processed natural ores for recovery of tantalum and niobium at i+s-€MIll
f€ei+i+fi{+-lhLMuskogee Facility;€klahema. Tantalum ore and tin slag were purchased
from around the world- This feed material was leached in concentrated hydrofluoric acid
and sulfuric acid. This process dissolved the tantalum and niobium into solution and the
insoluble fluoride compounds, such as thorium, radium, and uranium, remained behind in
the solids. These solids were then filtered and collected in Ponds 2 and 3. The Ieached
solids sent to Ponds 2 and 3 were highly variable and contained on average
approximately 0.8Vo tantalum (Ta) and 0.I7Vo U:Os. The solids in Ponds 2 and 3 contain
residual metal impurities in the fluoride form.
The FMRI materials are comprised of the materials stored in on-site Ponds 2 and.3,
ancillary drummed material, pond cover soils, pond surrounding soils, and ie that
have been impacted by the proposed alternate feed material. The FMRI
uranium content of approximately 0.151 Vo (0.178Vo U:Os) and 0.357Vo thoi
Review Scope: Environmental Analvsis
ln accordance with UAC R313-22-38 and R3l3-24-3, this SER
(l) Assess the radiological and non-radiological impacts
(2) Assess any impact on waterways and groundwater
(3) Consider alternatives, including alternative sites
(4) Consider long-term impacts including
reclamation impacts.
on, and
(5) Present information and analysis for
which support -the proposed license
1.4
4
2.0 SITE CHARACTERISTICS OF THE WHITE MESA MILL AREA
The area surrounding the White Mesa facility is in an arid climate with an approximate
annual precipitation of 12-inches and a mean temperature of 50" F. Runoff in the project
area is directed by the general surface topography either westward into Westwater
Canyon, eastward into Corral Creek, or to the south into an unnamed branch of
Cottonwood Wash. The San Juan River, a major tributary to the Colorado River, is
located approximately 18 miles south of the site.
The population density of San Juan County is approximately 1.7 persons per
The Town of Blanding is the largest population center near the facility with
of 3,600. Approximately 3.5 miles southeast of the site is the White Mesa lon, a
community of approximately 350 Ute Mountain Ute Indians. The
mill is located approximately 3U! miles to the northeast of the
prevailing wind direction.
Approximately 6O7o of San Juan County is federally-ow
U.S. Bureau of Land Management (BLM), the U.S. Nati
U.S. Forest Service. Primary land uses include li
recreation, and exploration for minerals, oil, and gqp. A
American land owned by either the Navajo Nati
land within 5 miles of the site is predomi
owns or has clai
White Mesa mill site encompasses approx
Groundwater beneath the site mal4ly
aquifer hosted by the Dakota
confined aquifer in the En
t to the
in the
by the
and the
range,
is Native
n Tribe. The
ts of anding. IUSA
acfes which Tlhe
a shallow unconfined
formations; and the deep
the tailings cells the shallow
ow ground surface and consists ofaquifer is found at a dep
groundwater perched
deep Entrada/Navajo
It is found at a depth
aquifer by hu
and
Recharge
La Sa
shal
bvt
and
B
the
the
of the Morrison formation. The
most permeable aquifers in the region.
ground and is separated from the shallow
ility shales and mudstones (e.g. Brushy Basin
Formation, the Summerville Formation, etc.).
filtration along the flanks of the Abajo, Henry, and
flanks of the structural folds. Groundwater in the
Sandstone and Burro Canyon Formation) is monitored
detection monitoring program. Water in this zone flows
ater applications, within a 5 mile radius of the site are on file with
ineer's Office. The majority of applications are by private individuals
drawing small, intermittent quantities of water, less than 8 gpm from the
formation. For the most part, these wells are located upgradient (north) of
ty. Stockwatering and irrigation are listed as the primary uses. Two deep water
supply wells are completed in the Entrada./Navajo Sandstone located approximately 4.5
miles southeast of the site on the Ute Mountain Ute Reservation. These deep water
supply wells are completed approximately 1200-feet below the ground surface.
3.0 OPERATIONS
The White Mesa uranium mill was del+et€pedbg!!! in the late 1970's by Energy Fuels
Nuclear, Inc. (EFN) as an outlet for the many small mines that are located in the
Colorado Plateau. After about two and one-half years, the mill ceased ore processing and
entered a total shutdown phase. In 1984, a majority ownership interest was acquired by
Union Carbide Corporation's (UCC) Metals Division, which later became Umetco
Minerals Corporation (Umet€oMEIgQ), a wholly-owned subsidiary of UCC. The
partnership between UMETCO and EFN continued until May 26, 1994,
reassumed complete ownership of the mill. In May of 1997, ruSA purchased
of th+EFN and is the current owner and operator of the facility. The mi
through several operation and shut down peri
1980 to date.
The current license, License Condition 10.1, specifies a maximum
4380 tons of yellowcake per year.
4.0 ENVIRONMENTAL EFFECTS
4.1 RadiologicalandNon-Radiolosicallmpacts
Radiological Impacts
According to the March 8, 2005 submittal, the following radionuclides are known to exist
in the FMRI alternate feed materials: Ra-226,Ra-228,Th-228,Th-230,Th-232,U-234,
U-235, and U-238. Concentrations of these radionuclides in FMRI's Tailings Ponds I
and 2 are shown below. These radionuclides are commonly associated with the urgrium
decay series and natural thorium decay series. The FMRI material is radi
consistent with other ores and alternate feeds that have been processed at the
Mill.
In the June 22,2005 letter, IUSA the ore pad, the FMRI
materials will be sealed inside a ic bag. The exposure and
dose rates from the estima material was found to be
approximately the same as of low-grade Colorado Plateau
ore.
The March 8, 2005 comparisons between the FMRI material
and previously li feed materials
cal Imoacts
According to the March 8, 2005 submittal, the Radioactive Material Profile Record
attached in Appendix 2 to the March 8, 2005, submittal lists the following known and
possible chemical components or hazardous waste characteristics:
Th-232
Concentration
0.157o
to 0.307o
W.R. Grace
(Y)(N)(Y)N)(Y)N)
a.Listed HW x b.Derived-
From HW
x c.Toxic x
d.Cvanides x e.Sulfates x f.Dioxins x
s.Pesticides x h.Herbicides x t.PCBs x
J.Explosives x k.Pyrophorics x l.Solvents x
m.Organics x n.Phenolics x o.Infectious x
p.Isnitable x q.Corrosive x r.Reactive x
s.Antimonv x t.Beryllium x u.Copper x
v.Nickel x w.Thallium x x.Vanadium I x
v.Alcohols x Z.Arsenic x aa.Barium J
bb.Cadmium x cc.Chromium x dd.Lead
ee.Mercury x ff.Selenium x gs.Silver I
hh.Benzene x u.Nitrate x It.Nitritr x
kk.Fluoride x IL oil x mm.Fur x
nn.Chelating
Asents
x oo.ResiduefromWaterTreatment ;[F x
DD.Other Known ofr Possible Materials or Chemicals l-x
For a detailed list of all the non-radiological chemicalg
the FMRI material, refer to Table 5 and Table 6 of .submittal. ,,
il:[;:ffit
RCRA Listed Materials Analysis
As stated in Section 1.3, the FMRI
therefore no listed RCRA materi:
cFR 261.4(b)(7). I
natural ore processing,
it is exempt under 40
RCRA
The following metal
(ruSA, March
Alkali
Alkali
be found in the FMRI material
Class of FMRI Materials*
um
beryllium, calcium, magnesium
y, cadmium, cerium, chromium, cobalt, hafnium,
, lanthanum, manganese, mercury, molybdenum,
neodymium, nickel, niobium, praseodymium, scandium,
silver, tantalum, thallium, thorium, tin, titanium,
tungsten, vanadium, yttrium, zinc, zirconium
Aluminum,lead
Arsenic, selenium, silicon
Ions Ammonia, chloride, cyanide, fluoride, nitrate, phosphate
sulfate; $il+ide I
le Organic Acetone, Methyl isobutyl ketone (MIBK)
mi-Volatile Organics Di-n-butyl phthalate
*Bold Type - s#qlgments or compounds in the FMRI material that have not been quantified
in the mill's tailings cells to date.;-no+f+e+i Some of these
elements. such as tantalum. niobium and scandium are known to exist in the Mill's tailings. from
other altemate feed materials. but have never been quantified. Others. such as cerium. hafhium.
lanthanum. praseodymium. tungsten and yttrium are expected by IUSA to also currently exist in
the mill's tailings cells. due to their natural abundance with other elements found in the tailinqs
cells. but have never been quantified.
There may be some residual methyl isobutyl ketone (MIBK) in the FMRI
material. MIBK was used to remove impurities (iron, zirconium, and uranium)
from the original tantalum processing stream.
In a May 16,2005,letter to ruSA, UDRC asked IUSA to specifically ev the
that
dehgyg not in the tailings These
compounds include: MIBK, Bis (2-ethylhexyl) Phthalate, Di-ate,
chemical compatibility of elements and compounds in the FMRI
Cerium, Hafnium, Lanthanum, Niobium, Neodymium,
Sulfides, Tantalum, Tungsten, Yttrium, and Fluoride.
In a June 22,2OO5,letter, ruSA made the following
1) Bis (2-ethylhexyl) Phthalate, Di-n-butyl
enough concentrations to be considered "de
Uffi,
low
lngo Bis (2-ethylhexyl) Phthalate whi 8, 2005
submittal, only exists in FMRI's ffirgt which i part of the
proposed alternate feed materio Di-n-butyl Phthalate ions would actually
increase liner and liner nd toughness.o MIBK and other keyt liners and joints to
concentrations up the FMRI material to the
ntration of keytones to 13tailings solution-
ppm (0.0013
2) Sulfides were;l list of constituents in the FMRI
have been indicated. Sulfates inmaterial.
h the PVC liner and joints.
nto the Mill's uranium circuit with natural
vels as high as 460,000 m/kg. The FMRI
of 309,000 m/kg. The addition of fluoride to the
the overall concentration of fluoride salts in the
imately 0.7Vo The manufacturer's rating for inorganic
patibility with PVC liners and joints for hydrofluoric
g to the manufacturer's data, metal fluoric salts in any
are compatible with PVC liners and joints.
tailings system currently contains high levels of metallic salts.
have any effectI increases in metallic salt concentrations will not
PVC liners and joints.
Effects
Surface Water Effects
As stated above, during storage on the ore pad, the FMRI material will be sealed in fabric
bags with a 3 mil polyethylene liner. The FMRI material is expected to have a moisture
any
Flur3)
4.2
content of 207o to 307o. There will be no free liquid inside the polyethylene liner.
Therefore it is unlikely that material or liquids will penetrate the bag and become exposed
to stormwater. In the event that the FMRI material became exposed to stormwater,IUSA
has an approved spill management plan and stormwater management plan. All storm
water runoff from the ore pad is routed to Cell l.
Groundwater Effects
As stated above, during storage on the ore pad, the FMRI material will be sealed in fabric
bags with a 3 mil polyethylene liner. The FMRI material is expected to have a mqi
content of 207o to 307o. There will be no free liquid inside the polyethylene li -ln
ition. the low surface and
ntial forthe FMRI
material is on the ore pad. Therefore, seepage of the material into the
ore pad site is not anticipated. The FMRI material has similar chemi
properties to natural uranium ore and materials currently
Therefore, it is not anticipated that ore pad storage of the
additional risk to the groundwater than conventional ores.
Tailings from the FMRI material processing will be
along with other process tailings. A groundw
already in place, in accordance with the State i
any leakage from the tailings cells has
at the
cells.
any
gs cells
IS
permit determine if
lly, if
A conduct
detailed
groundwater
a corrective
in the state
4.3
contamination were to occur, the UDRC
action to restore groundwater to the
groundwater permit.
With the introduction of
\:tlhi+e-+ttesa-Mpqi ll
be considered in
parameters should
eeffii0.
In Attach
a
ant found in
I groundwater
,
material into the
these materials needs to
monitoring compliance
the Permit
4)
s)
6)
8, 2005 @submittal Table 2,
and Alternate Feeds", a summary is found of 49
material. In determining if additional groundwater
were needed for the Permit the following criteria were
ant already included as a groundwater monitoring compliance
in the Permit ?
be a significant increase in concentration in the tailings inventory ?
contaminant mobile in the groundwater environment (i.e., low soil-water
itioning coefficient (Kd)) ?
Does the contaminant represent a known human toxicity hazard?
ls there an available and reputable groundwater quality compliance standard ?
Are there EPA approved analytical methods ?
t0
In the$Rcllg review process: DRC observed that many of the 49 contaminants identified
in the FMRI material have never been quantified in the mill's tailings cells and. as a
result. have not been considered to date for inclusion in the Permit.M
Several of these were also of concern
because of proportionately large increases in the projected tailing cell inventory after the
feed stock is processed. although in most cases the overall concentrations of these
constituents will not be affected significantly by processing the FMRI material at the Mill
(see Table I Summary of Components in Fansteel Alternate Feed).. A total of 26 of the
49 contaminants considered were already required as groundwater monitoring para
in the Permit
Based on the above criteria tin will be added as a groundwater monitori pliance
parameter to the Permit. Reasons for the selection of tin and omission lnlng
22 contaminants are found below. Details are also found in Table 1 i below.
Contaminant Selected for Groundwater Monitoring
Tin is currently not a required groundwater monitoring
omitted from the original Permit due to non-detectable re
three tailings leachate samples (see l2lll04 DRC T on
the proposal in question, tin will experience an in the g inventory
from 9 to 248 tons (IUSA, March 2005,esti Kd of 2.5 to 5
(Ohio EPA, 2005) tin is not as mobile in t t as other metals;
however, with the high acid conditions ater, tin could stay in
from Mark R. Colsmansolution and not partition on aquifer
(Tetra Tech EM, Inc.) to David C.September 26, 2005
(Colsman, September 26, 2005)i and zinc may serve as
analogues for tin because in mineral deposits and ores.
However, the coincident its may be a product of their
high temperature ition. In contrast, shallow ground
water at the Mill si ical environment. Consequently
cadmium and zinc water monitoring analogues for tin.
Toxic levels health risk. The DRC will adopt an ad hoc
groundw based on the State of Minnesota Department of
health ri 4,000 ug/l (Minnesota, 2005).lPlease see discussion
Groundwater Monitoring Consideration
minants were not added because they are already required
itoring compliance parameters in the Permit:
nd was
IUC in
and Metals (23)Arsenic, beryllium, calcium, cadmium, chloride,
chromium, cobalt, fluoride, iron, Iead, magnesium,
manganese, mercury, molybdenum, nickel, potassium,
selenium, silver, sodium, sulfur, thallium, vanadium, and
zinc
I Acetone
Besides tin, the remaining 22 contarninants of concern that are not groundwater
monitoring parameters include the following four groups with their corresponding DRC
findings:
Inorganics: cyanide, phosphate, and sulfideale.
Although there is an expected slight increase in the concentration
inventory, cyanide was omitted because it will rv*s*off-gas in
environment of the White Mesa Mill process. Should cyanide be
tailings wastewater sampling under Part 1.H.5, i+DBC may consi
should be added as a compliance monitoring parameter at a fu
Phosphate and sulfirlegle were not required groundwater
the Permit, although; there is an rygal! increase in the
ll decrease in the concentrati
insufficient information to conclude that
(TOXNET,2005).
Metalsr aluminum, antimony,
neodymium, niobium, praseodymiu
the lngs
acid
titanium, tungsten, yttrium, and
Barium, cerium, hafnium,
scandium, tantalum, thoriu
as groundwater monito{
metals will have
high Kds
metals are a
lower
ted
isa
olrussron
behavior
lanthanum,
tantalum, thorium,
obium, praseodymium,
iconium were not required
t. Although, some of these
oncentration in the tailings
monitoring consideration because of
(Colsman September 9,2005). Other
monitoring parameters that have much
ted well before the arrival of the above
as a groundwater monitoring parameter in the
preeie&aSlighl increase in its tailings invenrory
is due to the fact that: l) Aluminum and iron have
in groundwater environmentsl, 2) the increase in
lIn
and
mcentrations greater than 10,000 mgll-, as in the wastewater in the tailings cells, iron
greater than 1000 are common. The mobility of these constituents away from the
is primarily a function of the total acidity of the solution and the acid-neutralizing capacity
the solution contacts. The acidity ofthe solution is partly due to the activity ofhydrogen;
much greater component is generally due to dissolved iron and aluminum. As the pH of the
solution is raised by reactions with the solid phase iron and aluminum minerals become less soluble and
precipitate producing hydrogen. This reaction produces a much greater acidity provided by the solution
concentration of hydrogen. As a consequence the pH plume and its dissolved constituents will be more
mobile in an acidic solution with high concentrations of iron and aluminum than a plume without these
metals (Deutsch 1997).
t2
concentration of aluminum in the tailings will be small (approximately 0.137o).
23) iron is already a required groundwater monitoring parameter in the Permit,
#) it is estimated that there will be similar concentrations of aluminum and iron
in the 4qMill's Tlailings inventory
after processing the FMRI material (ruSA, March 2005), and 54) iron has an
estimated lower Kd than aluminum (iron estimated Kd of 1.4 and aluminum
estimated Kd of 9.9 (Tetra Tech, 2005). Consequently, iron should be detected
at the compliance monitoring wellq before the arrival of aluminum and therefore
an acceptable analog.
Antimony is also not a required groundwater monitoring parameter in
in part because there is no significant increase in the tailings in
uiredantimony and arsenic have similar geochemistry, and arsenic is
groundwater monitoring parameter in the Permit. The esti of
antimony in the pgMill's lTailings after processing the
less than the estimated mass of arsenic in the mMill'
may
Volatile
beis
, March
2005). Antimony has an estimated Kd of 2.0 (ruSA ic has
a estimated Kd of 1.0 (Tetra Tech, 2005). C ld be
detected at the compliance monitoring wells
Titanium is not a
although there is a
required groundwa the Permit,
significant inc inventory-and_Ajlight
increase in the ins the FMRI
material, there was no inf s Substance Data Bank
(HSDB) regarding human health formation was found in
available technical literature. Si not available titanium
was eliminated from co monitoring parameter. If in
the future, such inf ailable, the Executive Secretary
should feqHf€
to Part IV.N of the Permit.
r methyl isobutyl ketone.
) is not a required groundwater monitoring
because there is not a significant increase in the
K and Methyl ethyl ketone (MEK) are members of
(ketones). MEK is already a required groundwater
in the Permit and can serve as an analog for MIBK, in that:
mass in the tailings will be greater than MIBK (after
processing) (IUSA, March 2005), and 2) MEK has a lower
than MIBK (I\{EK estimated Kd of 0.015 (ruSA Permit, 2004) and
an estimated Kd of 0.123 (TOXNET, 2005)) consequently, MEK
be detected at the compliance monitoring well before the arrival of MIBK
therefore an acceptable analog.
Semi-Volatile Organic Compounds (SVOC): di-n-butyl phthalate.
t3
Di-n-butyl phthalate is not currently a required groundwater monitoring parameter
in the Permit. However, it was considered for monitoring in the Permit (see
l2lll04, DRC Statement of Basis, p. 19). In order to streamline groundwater
monitoring efforts and for reasons addressed in the Permit all semi--$VOC
compounds, including di-n-butyl phthalate were omitted as groundwater
monitorin g parameters.
The inventory for the Fan-Steel-FMRI alernate-fee&material included 49
for groundwater monitoring compliance consideration. Of these 49
were already required as groundwater monitoring compliance parameters
Of the remaining 23 contaminants, the Executive Secretary determined
added as a new groundwater monitoring compliance parameter in the
4.4 Alternatives
The action that the UDRC is considering is approval
@aterialg license issued pursuant
and Source Material Mill Tailings Disposal Facilit
R3l3-24-3(1)(c) requires that alternate sites
the analysis of the license amendment request.
Based on its review, the UDRC staff
associated with the proposed action do
operations or the*denialylgg-ef the I
that there are no significant eny
Other alternatives need not
UDRC does not
and decontami
environmental impacts
iting ef*IUSA's future
RC staff has concluded
with the proposed action.
on the reclamation, decommissioning,
ility, if the FMRI material is processed as an
material has similar radiological and
feeds and natural ores that have already
to an
Mills
UAC
1n
4.5
alternate
radi
non-
been
beenground water monitoring parameters haveg
of local ground water resourcses.
issues in the unlikely event that IUSA were to close prior to
ial, UDRC sent a letter to ruSA on May 16,2005, requesting
much IUSA's financial surety needs to be adjusted. If this
the fabric;bagged FMRI material would likely be hauled to the
disposed of directly into Tailings Cell 3. In a letter dated July 19, 2005,
an analysis stating that the financial surety would not need to be increased
ceptance of the FMRI material, because the mill has already processed other
alternate feeds-dunnglhg-ygq, which has caused a decrease in the current reclamation
liability (and hence surety requirements)s*rety€rca+er which more than offsetsthan the
increase in the reclamqtion liability that would result from
t.I fi
how
IUS
for
Conclusions
t4
the receipt of the FMRI material. Therefore the financial surety amount approved in
License Addendum #1 will be sufficient. This amount is $10,950,180.00. To ensure that
the surety amount is always sufficient to cover the amount of alternate feed material
stored at the Mill, changes have been proposed to License Condition 10.1. Refer to
Section 5.0 for these proposed changes.
4.6 Report Findings
Based on the foregoing evaluation of the environmental impacts of the ruSA
request, the UDRC has determined that there will not be a significant adverse
public health on the environment resulting from the ruSA proposal.
statements support and summarize this conclusion:
1. An acceptable environmental and effluent monitoring
monitor effluent releases and to detect whether applica
exceeded. Radiological and non-radiological effluents
been and are expected to continue to remain bel
groundwater monitoring progfilm for the shalloq
detect potential seepage of contaminants from
confined EntradaA.{avajo Sandstone AquifEr is
formations from the tailings cells fu
groundwater resources. The potential
temporarily stored on the ore pad i
climate, low permeability and hi
duration of storage. Further,
storage pad can remove
occur, inlq the tailings
program will be i
contamination.
An approved
postings requi
In the ngrl-2
lace to
rits are
have
its. A
lace to
deep,
ility
to deep
r while the material rs
layer packaging, dry
surface, and the limited
ion activities at the
inan+sgtlen, should it
An existing dust suppression
)
the potential for airborne
is in place at the mill. Site perimeter
9.9 are in place at entrances to the mill.
ive Dose Equivalents (TEDEs) have been
Sv (5 rem) annual limit specified in UAC R313-
The licensee has also implemented a bioassay
NRC Regulatory Guide 8.22, "Bioassay at Uranium
environmental impacts from the receipt and processing of
were assessed. No significant impacts have been identified as
is action. Therefore, the staff has determined that any increased risk
and environmental hazards is insignificant.
15
5.0 PROPOSED LICENSE AMENDMENTS AND PERMIT MODIFICATIONS
5.1 License Amendments Proposed
The following license condition changes would result from this license amendment. The
changes are presented in redline-and-strikeout format.
10.1 The mill production rate shall not exceed 4380 tons of yellowcake per I
Maximum quantities of feed material stored on the mill site, i
ore pad, in accordance with the submittal to the
Secretary dated July 19,2005:
(1) Any combination of alternate feed material lk form
shall not trexceed 78,000 tons, wi
Executive Secretary, and
(2) Any combination of alternate feed
to exceed 33,500 barrels. wi
Secretary. Barel volume
The licensee shall notify
ores.
to receiving natural
[Applicable UDRC A
The licensee is source material from FMRI's
Muskogee F Okalahoma, in accordance with
statements,itments contained in the amendment
A.
year
B.
C.
req))ve Secretary dated March 7,2005 and June
t:21
nistrative license amendment will be made. This former
not corrected as part of the initial license converston.
shall submit a detailed decommissioning plan to the NRGEagqUliJg
at least twelve (12) months prior to planned final shutdown of mill
that includes a detailed Quality Assurance Plan. The plan will be in
with NRC Regulatory Guide 4.15, "Quality Assurance for
ical Monitoring Programs" and NUREG-I575, "Multi-Agency Radiation
Survey and Site Investigation Manual (MARSSIM)" or equivalent most current
guidance.
t6
[Applicable NRC Amendment: 13]
[Applicable UDRC Amendment: 2]
5,2 Permit Modifications Proposed
Tin is proposed to be added as an additional required groundwater monitoring parameter
to the Permit. Changes that will be added to Table 2 of the Permit, in redline-and-
strikeout, format presented in Attachment 1 below.
L7
6.0 REFERENCES
Colsman Mark R., September 9, 2005, memorandum, Subject: Survey of Reference
Partition Coefficient Values for Trace Heavy Metals in Fransteel Metal, Inc. (:94149
Uranium Materials, from Mark R. Colsman, Ph.D. to David C. Frydenlund.
Memorandum, September 9, 2005, sent by e-mail to the Utah Division of Radiation
Control from David C. Frydenlund to Loren Morton.
Colsman Mark R., September 26,2005, memorandum, Subject: Geochemical B
Analogues of Proposed Additional Monitoring Parameters, from Mark R. Col
to David C. Frydenlund. Memorandum, September 27,2005, sent by e-mail
Division of Radiation Control from David C. Frydenlund to Loren Morton.
International Uranium (USA) Corporation ({US$, "Revised for I
Reclamation of the White Mesa Mill and Tailings Management S LJtah,"
February 2OO5.
IUSA, "RE: FMRI Alternate Feed License Amend
Environmental Quality Request for Additional Inf
22,2005
ruSA, "FMRI Alternate Feed License to Surety
Calculation, White Mesa Mill," July 19,
ruSA, "RE: Application by International tion for an amendment
to State of Utah Radioactive Materials Li the White Mesa Uranium
Mill to authorize processing of ate feed material," April 1,
2005
fUSA, "RE: Applicati (USA) Corporation ("IUSA") for an
amendment to State
Mesa Uranium Mill
ials License No. 1900479 for the White
material (the "8,2005
IUSA,ve Materialq License White Mesa Mill and IEnvi
th, Groundwater Health Risk Limits, 2005.
water/hrl
Protection Agency, 2005. Vadose Zone Modeling in RCRA Closure.
Waste Management. January 7,2005
hw f/VadoseFinall2
TO ,2005. Hazardous Substances Data Bank,
http://toxnet. n lm.ni h. gov
Utah Division of Radiation Control, December 1,2004, Statement of Basis
of FMRI, Inc. ("FMRI") alternate feed
Mi
l8
Utah Department of Environmental Quality, Division of Radiation Control, March 8,
2004, Ground Water Discharge Permit, Permit No. UGW37O004.
Utah Department of Environmental Quality, Division of Radiation Control-({JDRG),
"Request for Additional Information Regarding License Amendment Application -
Radioactive Materials License l-ft 1900479," }'.I.ay 16,2005
t9
7.0 Table 1, Summary of Components in FanSqteel Alternate Feed
20
Attachme
Changes to
INIBnNeuoNAL
UneNruvr (use)
ConponATroN
Independence Plaza, Suite 950 . 1050 Seventeenth Street . Denver, CO 80265 . 303 628 7798 (main) . 303 389 a125 (fax)
Ilur:re22,2005
VIA FACSIMILE AND US MAIL
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
Department of Environmental Quality
168 North 1950 West
PO Box 144810
Salt Lake city, Utah 841l4-4810
"\.
Re: FMRI Alternate Feed License Amendment Application, Department of
Environmental Quality Request for Additional Information, dated May I"6,
2005
Dear Mr. Finerfrock:
We are responding to the May 16, 2005 letter from Mr. John Hultquist, Division of
Radiation Control ("DRC") requesting additional information on the March 7,2005
License Amendment Application to receive alternate feed materials from FMRI, Inc.
The DRC questions are repeated below in italics with International Uranium (USA)
Corporation' s ("IU SA' s") responses following each question.
1. The FMRI waste profiles indicated that the waste stream included several
contaminants that have not been adequately assessed as to the cumulative effect they
may pose to the inlegrity of the pond liner, especially where the liner sections are
joined. These conlaminants include :
4 methyl 2-pentanone [a.k.a. methyl isobutyl ketone ("MIBK"), Bis (2-
ethyl hexy I ), D i - n-butyl phthalate, c er ium, hafnium, lanthanum, niobium,
neo dymium, P r as e o dymium, Sc andium, Suffi de, Tantalum, Tungsten, Yttrium,
andfluoride.
Please evaluate the chemical compatibili\t of contaminants with the pond liner. seam
int e gr it:t and gr oundy, at e r qual i4).
Letter to Dane L. Finer
Jtne 22,2005
Page 2
IUSA has retained Jo Ann Tischler, an independent chemical engineer, to evaluate the
chemical compatibility of these constituents with the Mill's tailings cell liners and liner
seam integrity. A copy of Ms. Tischler's memorandum is attached to this letter.
Ms. Tischler concludes generally that all of these constituents are compatible with the
Mill's tailings liners and liner joints in much higher concentrations than found in the
FMRI material. Accordingly, the impact of these constituents on the Mill's tailings
system will be insignificant.
With respect to the specific categories of constituents, Ms. Tischler reaches the following
conclusions:
Phthalates (e.g., bis 2-ethylhexyl and Di-n-butyl phthalate) can have a
positive effect (as a plasticizer) if in high enough concentrations
(approximately 30 percent). At low concentrations (part per million
levels), they are de minimus and will have no impact on the liner
system. The concentration of di-n-butyl phthalate, in the FMRI
Material (approximately 1 ppm) is therefore de minimus and will have
no impact, positive or negative on the Mill's tailings system. Bis 2-
etl-rylhexyl phthalate is not present in the FMRI Material.
There are no sulfides in the FMRI Material. Reference to sulfides in
the Radioactive Material Profile Record submitted with the license
amendment application was a mistake, and should have been a
ref'erence to sulfates. Sulfates at all concentrations are compatible
with the aqueous sulfates already in the tailings system. As a result,
the impact on the Mill's tailings system of any sulfates in the FMRI
Material will be insignificant.
Although there will be an increase in the overall concentration of
fluoride salts in the tailings cells after tailings from processing the
FMRI Material are added to existing tailings, the resulting
concentration of approximately 7,200 ppm (0.7 percent) will be well
below the manufacturer's ratings for compatibility with PVC of 48
percent for inorganic hydrofluoric acid and an unlimited concentration
for metal fluoride salts. Accordingly, the impact of the fluorides in the
FMRI Material on the Mill's tailings system will be insignificant.
As the Mill's tailings cell liners are compatible with high level
metallic salts, and in fact, the majority of the Mill's tailings volume is
comprised of such metallic salts, no compatibility or integrity issues
are expected regardless of incremental changes in the various metallic
salt levels (e.g., cerium, hafnium,lanthanum, niobium, neodymium,
praseodymium, scandium, tantalum, tungsten and yttrium) anticipated
from processing the FMRI Material.
a)
b)
c)
d)
Letter to Dane L. Finer
June 22,2005
Page 3
e) Under even worst-case assumptions, i.e., assumingzero values at half
their detection limit and assuming no reduction in the concentration of
ketones due to volatilization, the concentration of all ketones in the
tailings system after processing the FMRI Material is not expected to
exceed l3 ppm. This level is more than 7,000 times lower then the
U.S. EPA test level for compatibility of ketones with PVC seams and
is clc minimus.
With respect to compatibility of the referenced constituents with groundwater quality, the
constituents will not have an adverse impact on the Mill's tailings system, as discussed
above. Therefore, there is no reason to expect that any of the constituents will ever come
into contact with groundwater. Nevertheless, in the hypothetical situation where the
tailings cells are assumed to be leaking, all of the referenced constituents have either been
measured to be or can reasonably be assumed to be in the existing tailings contained in
the tailings cells. The concentrations of these constituents in the FMRI Material are
relatively low, and, taking into consideration that the total quantity of FMRI Materials is
estimated to be approximately 32,000 tons, compared to total existing tailings in Cell 3 of
approximately one million tons, the impact of these constituents on the makeup of the
tailings will be insignificant. There would therefore be no significant incremental impact
on groundwater quality in the event of a hypothetical leak in the Mill's tailings cells over
and above any impacts from the existing Mill tailings.
2. The waste is described as arriving in 'fabric bags". The request also describes the
"dewatered sludge" as having an average moisture content of 30%. The previously
submitted report titled, "Evaluation of Potential for Seepage of Constituents Present in
Alternate Feed Materials into the Ore Storage Pad", dated June 28, 2002, does not
evaluate material with a moisture content as high as 30o% being stored on the ore pad.
Please evaluate the.fabric bogs for possible leakaqe.
FMRI is designing the drying process to achieve an optimal moisture content of
approximately 20oh. The 30% moisture content was used in the license amendment
application to be conservative. Based on the physical nature of the FMRI Material, it is
not expected that there would be any free liquid at the higher moisture content. Even if
there were some free liquid generated during transport or storage of the material it would
be very small and totally contained by the "fabric bags". The bags are constructed of
polypropylene fabric treated for ultraviolet resistance. Each bag will also have a 3 mil
polyethylene internal liner for additional containment of higher moisture content
materials. A copy of the bag specification is attached.
3. Page l2 of the license amendment request states that you may consider recovering
tantalum or other metals in addition to the uranium product in the alternate feed. In
the NRC memorandum "Redistribution of NRC Regulatory Issue Summary 2000-2j
Recent Changes to Uranium Recovery Policy: datedApril 19, 2001 ", the NRC
Letter to Dane t-. Pin".tt
Jwe22,2005
Page 4
includes criteria.fitr determining whether or not a non-natural ore can be processed as
an alternatefeed. Criteria 3 states:
". . . the ore must be processed primarily for its source material content. If the only
product produced in lhe processing ofthe alternatefeed is uranium product, this
determination is sati.v/ied. If in addition to uranium product, another material is also
produced in the processing of the ore, the licensee must provide documentation showing
that the uranium producl is the primary product produced."
Should the Licensee choose to recover uranium only, no documentation is required.
Should the Licensee choo.se to recover any material in addition to uranium, the Licensee
must notifu the DRC and provide documentation that the uranium product will be the
primary pro duct produce d.
At this time IUSA is planning on processing the FMRI Material for the recovery of
uranium only. Should IUSA choose to recover any other material in addition to uranium,
IUSA will notify the DRC and provide further submissions at that time.
4. The financial surety for IUSA requires that the current cost estimate be evaluated in
regards to disposal process with each alternate feed and associated costs being
itemized. The March 7, 2005 report did not address any surety costs associatedwith
FMRI material, in the unlikely event that IUSA close prior to processing the material.
Please provide a sure\t increase estimate.
In the past, the Mill has not increased or decreased its surety amount during the year as a
result of receiving or processing alternate feed materials or ores throughout the year.
IUSA proposes that, consistent with past practice, the additional surety dollars to account
for the disposal of the FMRI Material will be included in the revised cost estimate that
will be presented to tl're DRC in March 2006. This makes sense for a number of reasons.
Had the projected 32,000 tons of FMRI Material been at the White Mesa Mill at the time
of the February 2005 surety update, the reclamation expense for the material would have
added approximately $43,000 to the current estimate. However, since the material will
not begin arriving at the Mill until later this year, and it is expected to take 12 to 24
months to complete delivery of the material, it would be more timely to evaluate the
added reclamation liability resulting from receipt of this material in the February 2006
surety update. In the interim, IUSA is processing the Cameco alternate feed materials,
which is expected to be complete by early 2006. The processing of this material will
result in a reduction of the reclamation liability by approximately $73,000. IUSA does
not propose that the reclamation surety be reduced in the interim to reflect this reduction
in reclamation liability. Rather, it would be more appropriate to evaluate both of these
activities, receipt of the FMRI Material and processing of the Cameco material, in the
February 2006 surety update.
Letter to Dane L. Fine
Jwrc22,2005
Page 5
I hope this informatign answers your questions, and if you need additional information
please feel free to corftact Harold Roberts or me.
I
John Hultquist, DRC
Jon Jackson, FMRI
Ron F. Hochsfein, IUSA
Harold R. Roberts,IUSA
T. Kenneth Miyoshi, ruSA
MEMORANDUM
International Uranium (USA)
Corporation
David C. Frydenlund
Jo Ann S. Tischler
June 22,2005
FROM:
DATE:
SUBJECT: Response to UDEQ Comment Letter of 05/16/05 on FMRI Amendment
Request
I am supplying the following information in response to the Utah Department of Environmental
Quality ("UDEQ") comment letter of May 16, 2005 regarding International Uranium (USA)
Corporation's ("IUSA's") March 17,2005 application for license amendment for Uranium
Material (the "FMRI Uranium Material") from Fansteel Metals Recovery, Inc. ("FMR["). This
addresses the chemical compatibility of various contaminants in the FMRI Uranium Material
with the Mill's tailings system, in response to UDEQ Comment #1.
Comment #1
The FMRI waste profiles indicated that the waste stream included several contaminants that
have not been adequately assessed as to the cumulative ffict they may pose to the integrity of
the pond liner, especially where the liner sections are joined. These contaminates [sicJ include:- l methyl 2-pentanone [a.k.a. methyl isobutyl ketone ("MIBK")J, Bis (2-ethylhexyl),
Di- n-butyl p h t hal ate, ce r ium, hafnium, I anthanum, niob ium, neodymium,
P r as e o dy miu m, S c andium, Suffi d e, T ant alum, Tun gs t e n, Yt t r ium, and fluo r i de.
Please evaluate the chemical compatibilit.v o_f contaminants with the oond liner, seam integritJ)
and qroundwater inteqri\t.
1. RESPONSE
1.1.Summary
The contaminants identified by UDEQ for further assessment can be categorized by chemical
type as follows:
(i) Phthalates - Bis 2 ethylhexyl phthalate and Di-n-butyl phthalate;(ii) Non-metal inorganic anions - sulfide and fluoride;
Memo re: Response to UDlComments
June 22,2005
Page 2 of 7
(iii) Transition and rare earth metals - cerium, hafnium, lanthanum,
niobium, neodymium, praseodymium, scandium, tantalum, tungsten,
yttrium; and(iv) Ketones - MIBK
As will be discussed in detail below, all of these constituents are compatible with the Mill's
tailings liners and liner joints in much higher concentrations than found in the FMRI material.
Accordingly, the impact of these constituents on the Mill's tailings system will be insignificant.
1.2. Tailings Liner Construction
Currently, only tailings cells I and 3 are in active service. Tailings cell4,A. is out of service and
the Mill does not intend to place any additional materials in this cell unless or until it undergoes
repairs and modification of its liner system.
Cell Liners
The cells were constructed with technology current for the late 1970's and 1980's. Both cells
were constructed of flexible 30 mil polyvinyl chloride ("PVC"). Due to its tight polymeric
structure and the intrinsic electro-negativity and chemical resistance of chlorinated super-
polymers, PVC is generally selected for applications requiring impermeability to a wide range of
free liquids and aqueous solutes including mineral acids, animal fats, petroleum hydrocarbons,
and natural microorganisms (fungi, etc.). It was selected for use at the Mill, in part, because of
its resistance both to strong sulfuric acid, and to kerosene, which are recycled through the tailings
system as part of the Mill 's leaching and extraction processes, respectively.
b) Liner Joint Technology
Historic information regarding the construction of cells 1 and 3 indicates that two different liner-
sealing systems were used in their construction.
The liner sections of one cell were joined by the "solvent-weld" method, and those of the other
by a liner-seam adhesive-bond method. The differences between the two methods are explained
below.
Polymer welding is used extensively to ensure joint or seam impermeability in both rigid and
flexible thermoplastics, including chloro-polymers (vinyls). In polymer welding, the polymer
chains at the edge or surf'ace of one segment or component are brought into contact with those at
the edge of a second component and are made soft or mobile enough to entangle with chain ends
from the second component. In polymer heat welding, mobility is accomplished by heating the
material just above its melting temperature (for crystalline polymers) or its glass transition
temperature (for amorphous polymers). When the material cools, the entangled solid mass of
chains constitutes a weld. Solvent welding exposes the polymer chains to polar organic solvents,
a)
Memo re: Responr",o uilComments
June 22,2005
Page 3 of7
instead of heat, to soften and entangle the strands. When the solvent evaporates, the remaining
entangled solid mass of chains constitutes a weld.
The liner sections of the other cell were joined by a liner seam adhesive system. This method
involves applying a mixture containing strands of one or more polymers dissolved in a volatile
solvent to a pair of PVC (straight, rolled or folded edge) surfaces to be joined. The solvents for
both the weld method and adhesive method are ketones such as MEK, methyl isobutyl ketone
("MIBK") or blends of these and other polar compounds. Historic information for the Mill's
tailings cells indicates that the ketone used both in the solvent welding method and the seam
adhesive method was 2 butanone (also called "methyl ethyl ketone" or "MEK").
U.S. EPA's Hazardous Waste Engineering Research Laboratory(Morrison and Parkhill, 1987)
tested 30 mil PVC seams of various widths joined by solvent adhesive and weld methods (in this
case heat weld). The tests included simulated weathering and exposure to a wide range of
reactive chemicals, including 10 percent methyl ethyl ketone. EPA found that both the weld and
solvent adhesive joints performed satisfactorily under chemical exposure conditions.
1.3. Analysis of Categories of Constituents Found in FMRI Uranium Material
Phthalates
According to the U.S. Army Waterways Experiment Station (see reference 6 below), when PVC
liners are exposed to multiple contaminant mixtures, the key factor in liner life and effectiveness
is not chemical compatibility, but installation technique and preservation of initial plasticizer
content for liner flexibility. According to the Textbook of Polvmer Science (Billmeyer , 197l)
two of the most common types of plasticizers and stabilizers for chlorinated polymers such as
PVC since the 1960's have been di-n-butyl phthalate and multi-substituted phthalates. Polymer
producers BF Goodrich, BASF Corporation, and EI du Pont recommend integration of these
compounds at levels as high as 30 percent by mass into rigid PVC castings and PVC liner
sheeting to improve the lifelong properties of the material. That is, exposure of the cell I and
cell 3 linings to phthalates will not embrittle, dissolve, or degrade the liners. In fact, if present at
high enough concentrations, these types of compounds would actually help maintain liner
integrity by improving its plasticity, flexibility and toughness. However, at low concentrations,
(part per million levels or lower) they are de minimus and will have no impact on the liner
system.
Bis 2 ethylhexyl phthalate is not present in the FMRI Uranium Material. FMRI characterization
studies identified bis 2 ethylhexyl phthalate only in samples from Pond 5. Material from Pond 5
is not included in the malerial to be shipped to the Mill. Bis 2 ethylhexyl phthalate was
mentioned in both the Jo Ann Tischler RCRA memorandum dated March 7,2005 and the Jo Ann
Tischler chemical compatibilty memorandum (the "Tischler Technical Memorandum") also
dated March 7 ,2005, both of which accompanied the license amendment application for the
FMRI Uranium Materials, as an additional example of the types of phthalates that, like di-n-butyl
phthalate, can contaminate samples due to their presence in sampling equipment, containers and
a)
Memo re: Response to Ufr Comments
June 22,2005
Page 4 of 7
personnel protective equipment. FMRI's NRC Site Decommissioning Plan stated that neither
bis 2 ethylhexyl phthalate nor di-n-butyl phthalate were actually present in the FMRI ponds, but
were reported due to their presence in plastic sampling equipment. In any case, as mentioned
above, bis 2 ethylhexyl phthalate was only reported in material from Pond 5, which will not be
shipped to the Mill.
As the concentration of di-n-butyl phthalate in the FMRI Material, if it is actually present, is very
low (approximately I pprn), it ts de minimus and will have no impact, positive or negative, on
the Mill's tailings systenr.
b) Non-metal inorganic anions
(,Suffides
The Radioactive Material Profile Record ("RMPR") submitted with the March 7 ,2005 License
amendment application included a checked box indicating that sulfide was a constituent of the
FMRI Uranium Material. As described in the Tischler Technical Memorandum, despite the
checked box on the RMPR, there is no data in any of the laboratory results indicating the
presence of any sulfides in the FMRI Uranium Material. The laboratory reports do indicate the
presence of sulfates, which are entirely compatible with the aqueous sulfates already in the
tailings system, as addressed in the memorandum. IUSA has confirmed via a June 10, 2005
telephone contact with FMRI that the sulfide box in the RMPR was checked off in error. IUSA
is in the process of obtaining an updated RMPR, corrected to indicate sulfate, not sulfide,
content, and will submit that document to the UDEQ separately from this response.
As sulfates in any concentrations are compatible with the aqueous sulfates already in the tailings
system, the impact of any sulfates in the FMRI Material will be insignificant.
(ii) Fluorides
Information from FMRI indicated that fluoride was present in the FMzu Uranium Material only
in inorganic forms. As described in the Tischler memorandum, the FMRI Uranium Material
consists mainly of residual metal impurities in the fluoride form, that is, metal fluoride salts.
Fluorides have been introduced into the Mill's uranium circuit with natural ores and alternate
feeds at levels as high as 460,000 mg/kg. The FMRI Uranium Material was estimated to have an
order-of-magnitude average concentration of 309,000 mg/kg fluoride salts.
Various manufacturer's literature rate flexible PVC as resistant to inorganic hydrofluoric acid at
concentrations as high as 48 percent by weight, and resistant to metal fluoride salts in all
proportions.
Although there will be an increase in the overall concentration of fluoride salts in the tailings
cells after FMRI tailings are added to existing tailings, the resulting concentration of
Memo re: Response to UDlComments
June22,2005
Page 5 of7
approximately 7,200 ppm (0.7 percent) will be well below the manufacturer's ratings of 48
percent for inorganic hydrofluoric acid and unlimited concentrations for metal fluoride salts.
Accordingly, the impact of-the fluorides in the FMRI Material on the Mill's tailings system will
be insignilicant.
c) Transition and Rare Earth Metals
Various manufacturer's literature rate flexible PVC as resistant to metallic salts, metallic soaps,
metallic cyanides and metallic acetates in nearly all proportions. This resistance includes
compounds of the alkali metals, the alkaline earths, the rare earth metals, the transition metals,
and the metalloids. For this reason, PVC has been used extensively for piping, tubing, bulk
containers and flexible system liners for aqueous solutions of these compounds for nearly three
quarters ofa century.
As the Mill's tailings cel1 liners are compatible with high level metallic salts, and in fact, the
majority of the Mill's tailings volume is comprised of such metallic salts, no compatibility or
integrity issues are expected regardless of incremental changes in metallic salt levels anticipated
from processing the FMRI Uranium Material.
d) Ketones
Methyl isobutyl ketone could be expected to be present in the FMRI Uranium Material as a
residual from FMRI processing steps. Ketones are already present in the current tailings
composition due both to their use in small quantities in the Mill's on-site laboratory and their
presence at low levels in some previously processed alternate feeds.
Manufacturer's guides indicate that ketones may be incompatible with PVC liner systems under
some conditions. These conditions include:
. high concentration solutions of ketones,. non-aqueous solutions of ketones (such as mineral oil or plant oil based solutions),
and
o direct contact of dry liner surfaces with free product ketone.
As described earlier, U.S. EPA obtained satisfactory results from liner and joint testing of PVC
with ketone solutions at concentrations up to 10 percent.
Calculations in Table 2 of the Tischler Technical Memorandum indicate that based on the most
conservative assumptions, the overall average MIBK concentration in the FMRI Uranium
Material might be estimated to be 4.1 ppm, and the total ketone concentration in the Mill tailings
after processing FMRI Uranium Material might be estimated to be 13 ppm. The estimates are
overly conservative for two reasons. First, they assigned a quantity of half the detection limit to
every reported zero value in the FMzu data for any ketone. Second, they assumed that the
concentrations of these highly volatile compounds would not be reduced by evaporation during
Memo re: Response to UII Comments
June 22,2005
Page 6 of 7
FMzu handling, shipping to the Mill, storage, Mill processing or at any time from the tailings
evaporation cells.
In addition, for conservatism, the Mill takes additional measures to minimize the exposure of the
cell liners to potentially degradative conditions. Tailings from alternate feeds and Mill laboratory
wastes containing trace ketones have only been pumped to cells actively in use and already
containing large volumes of aqueous solutions. No oil-based mixtures of ketones have ever been
disposed in the cells. Ketones have no opportunity for direct contact with a dry cell liner or liner
joint surface.
Under even worst-case assumptions, i.e., assumi ng zero values at half their detection limit and
assuming no reduction ir-r the concentration of ketones due to volatilization, the concentration of
all ketones in the tailings system is not expected to exceed 13 ppm. This level is more than 7,000
times lower then the U.S. EPA test level for ketones and is de minimus.
2. SUMMARY OF CONCLUSIONS
2.1. Phthalates can have a positive effect if in high enough concentrations (approximately 30
percent). At low concentrations, (part per million levels) they are de minimus and will have no
impact on the liner system. The concentration of di-n-butyl phthalate in the FMRI Material
(approximately I ppm) is de minimus and will have no impact, positive or negative on the Mill's
tailings system. Bis 2-ethylhexyl phthalate is not present in the FMRI Uranium Material.
2.2. There are no sulfides in the FMRI Uranium Material. Reference to sulfides in the RMPR
was a mistake, and should have been a reference to sulfates. Sulfates at all concentrations are
compatible with the aqueous sulfates already in the tailings system. As a result, the impact on
the Mill's tailings system of any sulfates in the FMRI Uranium Material will be insignificant.
2.3. Although there will be an increase in the overall concentration of fluoride salts in the
tailings cells after tailings from processing the FMRI Uranium Material are added to existing
tailings, the concentrations of approximately 7 ,200 ppm (0.7 percent) will be well below the
manufacturer's ratings o1'48 percent for inorganic hydrofluoric acid and an unlimited
concentration for metal f1uoride salts. Accordingly, the impact of the fluorides in the FMRI
Material on the Mill's tailings system will be insignificant.
2.4. As the Mill's tailings cell liners are compatible with high level metallic salts, and in fact,
the majority of the Mill's tailings volume is comprised of such metallic salts, no compatibility or
integrity issues are expected regardless of incremental changes in metallic salt (e.g., cerium,
hafnium, lanthanum, niobium, neodymium, praseodymium, scandium, tantalum, tungsten and
y.ttrium) levels anticipated from processing the FMRI Uranium Material.
2.5. Under even worst-case assumptions, i.e., assumingzero values at half their detection
limit and assuming no reduction in the concentration of ketones due to volatilization, the
Memo re: Responr. to uoQComments
Jtne 22,2005
Page 7 of 7
concentration of all ketones in the tailings system is not expected to exceed 13 ppm. This level is
more than 7,000 times lower then the U.S. EPA test level for ketones and is de minimus.
3. REFERENCES
1. Billmeyer, Fred. W. Textbook of Polymer Science. Second Edition. New York. John Wiley
& Sons. 1971.
2. Cole-Parmer USA. Chemical Compatibility Database. 2005
3. Copely Products. Chemical Resistance Tables. 2005
4. Morrison, William R. and Parkhill, Linda D. Evaluation of Flexible Membrane Liner Seams
after Chemical Exposure and Simulated Weatherine. U.S. Environmental Protection Agency.
April 1987.
5. Sax, N. Irving, and Lewis, Richard J. Sr. Editors. Hawley's Condensed Chemical Dictionar.y.
Eleventh Edition. New York. Van Nostrand Reinhold Company. 1987
6. Shafer, R.A. Technical Report: New Bedford Harbor Superfund Project. Acushnet River
Estuary. Engineering Feasibility of Dredeing and Dredees Material Disposal Alternatives. U.S.
Army Waterways Experiment Station. May 13,2007
7. Wise, Roger. Solvent Welding of Thermoplastics. TWI, Ltd. 2001
8. Wittliners. Exceline PVC Chemical Resistance Chart http://wittliners.com/chemchart2.html
. Jun.lE OS O4:OOp
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(800) 65s-3002
(847).605-1616
Fa.x: (847) 605-E086
DATE:
CUSfOMER:
PHONE:
FAX:
6-14-0s
A & M.ENGINEERING
t0010 E. 1611,' STREET
TU|SA, OK. 74128
AfiN: DAN BAKER
918{65-5575
918-655-6576
Wesstts: TRe tt.specus e. colrt
REFERENCE;
QUOTE#:
BAG STYLE:
BAG SIZE:
END USE:
MATERIAL:
TYPE:
CI.IARGE SPOUT:
DISCHARGE SPOUT:
FEATURES:
MAX. WEIGHTI
SAFETY FACTOR:
BB 847-1
TPA
42X42\37.
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UV.UNI-AMIMTED
14X18
F[-AT ( CLOSED )
.l-10" UFT LOOPS;
4500 LBS
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4*s*'fuASUBMITTED BY:
GREG HANDRAHAN, SR. l/rCE pR"ESrDEt{T
-Ltti
Irrrnr.rrlor rrf
Unnxruu (usn)-
ConponATroN
Independence Plaza, Suite 950 e 1050 Seventeenth Street .Denver, CO 80265 o 303 628 7798 (main) r 303 389 al25 (fex)
July 19,2005
VIA FACSIMILE AND US MAIL
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
Department of Environmental Quality
168 North 1950 West
PO Box 144850
Salt Lake Ciry, Utah 84114-4850
FMRI Alternate Feed License Amendment Application, Revision to Surety Calculation,
White Mesa Mill
Dear Mr. Finerfrock:
Following your e-mail request and our phone conversation of last week, International Uranium
(USA) Corporation ("ruSA") is providing an update to the surety calculation for reclamation and
decommissioning of the White Mesa Mill and tailings area ("Mill") to address the Division of
Radiation Control's (DRC's") concerns with surety amounts once the FMRI alternate feed
materials begin arriving at the Mill. Following is a description of our recalculation of the existing
surety requirement in order to update the February 2005 Revised Cost Estimate to today's date:
l) The estimated cost, before profit and contingency, for Mill Decommissioning,
Alternate Feed Disposal was increased from $48,572 to $80,957. This increase
reflects the additional cost to dispose of 32,000 tons of FMRI alternate feed material
should the decommissioning begin before the material is processed. For future surety
cost estimate updates, IUSA will include a projected disposal cost for any alternate
feed materials expected to be received on the Mill site during the following l2-month
period. This will ensure that the DRC is protected against additional alternate feed
receipts and potential cost increases during the period covered by the estimate.
2) The estimated Mill Decommissioning, Alternate Feed Disposal cost, before profit
and contingency, was decreased from $57,35 6 to $34,702 to reflect the current
progress made on processing the Cameco alternate feed material. As of July 1, 2005
IUSA has processed over 20,000 barrels of Cameco material. It is expected that all
of the barrels will be processed by March of 2006, well before the majority of the
FMRI material is received, but IUSA will leave the$34,702 amount in the estimate
until the next revision in March of 2006.
3) The estimated cost, before profit and contingency, for Cell 4A Cleanup, was
decreased by $30,636, from $57,247 to $26,611, to reflect the progress made by
ruSA on dewatering and removal of contaminated materials from Cell4A. The work
is projected to be completed by September 30,2005, well before the majority of the
Re:
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Letter to Dane f. ninOct
July 19,2005
Page 2
FMRI material is received, but IUSA will leave the remaining amount in the estimate
until the next revision in March of 2006.
4) The estimated cost, before profit and contingency, for Cell4,A. Cleanup, was
increased by $23,651, from $26,61I to$50,262 to reflect the cost to breach the Cell
4,A. Dike. This cost was included in the estimate in response to a request from
Johnathan Cook during his review of the February 2005 Estimate.
A copy of the summary sheets for Mill Decommissioning and Cell4,A' Cleanup are attached for
your review.
The net effect of the changes detailed above is an increase of $3,489 in the surety amount, from
$10,950,180 to $10,953,669. IUSA does not believe this extremely small increase warrants
modiffing the existing surety documents given the continued reduction in the decommissioning
and reclamation costs from the Cameco processing and the Cell 4,{ cleanout.
ruSA would be agreeable to inserting into the FMRI license amendment a condition to the effect
that IUSA would only be permitted to accept receipt at the Mill of FMRI materials to the extent
that the total amount of alternate feed materials at the site does not exceed 78,000 tons of
alternate feed materials on the ore pad and 33,500 drums of alternate feed materials stored
elsewhere at the Mill site, or, in the event that the surety is revised, does not exceed any revised
amounts contemplated in such revised surety. These are the total amounts of alternate feed
materials contemplated in the above calculations.
We are hopeful this information addresses your concerns and that issuance of the FMRI license
amendment can proceed as soon as possible.
If you have any questions on the attached information, please feel free to contact me.
cc:Ron F. Hochstein, ruSA
Harold R. Roberts,IUSA
T. Kenneth Miyoshi, ruSA
Jon Jackson, FMR[, w/o attachment
& Corporate Council
WHITE Mil MILL RE.LAMATION COGSflMATE
July 2005
Mill Decommissioning
Cell 1
Cell2
Cell 3
Cell4A
Miscellaneous
Subtotal Direct Costs
Profit Allowance
Contingency
Licensing & Bonding
Long Term Care Fund
Total Reclamation
Revised Bond Amount
$1,676,466
$1,417,745
$1,210,306
$1,672,795
$50,262
$2,044,029
10.00%
15.00%
2.000/o
$8,071,603
$807,1 60
$1,210,740
$161,432
$702,733
$10,953,669
$10,953,669
lnternational Uranium (USA) Corp.
White Mesa Mill7 126 l2OO5 - 2:32 PM - WM. RecPlan Est. Feb2005( 1 )
MILL DECOMMISSION!NG
MILL DECOMMISSIONING
Task Cosl
$293,863
$14,856
$258,979
lnternational Uranium (USA) Corp.
White Mesa Mill
Resource Units ask
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 W PC-400 metalShears
65 Ton Crane
30 Ton Crane
Equipment Maintenance (Butler)
Concrete Removal
hrs $17.72 720 s12 751
hrs $14.4C 640 9.219
hrs $10.3e 320 $3,311
nrs $1.3C 960 $1,248
hrs s72.85 640 s46.624
hrs $12.74 640 $8,154
hrs $1U/./L 160 $17,232
hrs 103.8i 160 16.618
hrs $124.21 160 $19,874
hrs $63.2r 16C $10,124
hrs 42.14 80 3.372
hrs $15.87 1,360 $21,580
sf $3.3C 37,500 $123,750
Total Mill Building Demolition
Ore Feed Demolition
Total Ore Feed Demolition
SX Building Demolition
Total SX Building Demolition
Resource Description Units Cosuunit Task Units Task Cosl
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavalor
Cat 330 w/ PC-400 metalShears
30 Ton Crane
Equipment Maintenance (Butler)
hrs $17.72 48,$850
hrs 14.4C 64 s922
hrs $10.35 32 $331
hrs $1.3C 96 $1 25
1rs $72.85 64 $4,662
1rs 12.74 64 $81 5
1rs $107.7C 16 $1,723
hrs $103.87 16 $1,662
1rs 124.21 16 $1,987
1rs s42.14 0
hrs $15.87 112 1.777
Resource Units CosUUnit Task Units Task Cost
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 w/ PC-400 metalShears
65 Ton Crane
30 Ton Crane
Equipment Maintenance (Butler)
Concrete Removal
1rs $17.72 240 $4,252
'lrs $14.4C 320 $4,609
'trs $10.35 160 sl 655
1rs $1.3C 480 $624
1rs $72.85 320 $23,312
1rs $12.74 320 $4.077
'lrs 107.7C 80 8.616
hrs $103.87 80 $8,309
1rs $124.21 80 $9,937
1rs F.2, r9 0
hrs s42.14 0
hrs $15.87 560 $8,886
sf $3.3C 55,97C $184,701
7 12612005 - 2:32 PM-WM.RecPlanEst.Feb2005(1 )
MILL DECOMMISSIONING
Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 w/ PC400 metalShears
65 Ton Crane
30 Ton Crane
Equipment Maintenance (Butler)
Concrete Removal
Total CGD Circuit Removal
Sample Plant Removal
Units Task Units
$81,396
< Cost
$46,709
lnternational Uranium (USA) Corp.
White Mesa Mill
Total Sample Plant Removal
Boiler Demolition
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 W PC-400 metalShears
65 Ton Crane
30 Ton Crane
Equipment Maintenance (Butler)
Concrete Removal
Total Boiler Demolition
$124.21
Resource ask
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 w/ PC-400 metalShears
30 Ton Crane
Equipment Maintenance (Butler)
Concrete Removal
'lrs $17.72 24 $42!
1rs 14.40 32 $461
lrs $10.35 16 s16€
lrs $1.30 48 $62
rrs $72.85 32 $2,331
lrs $12.74 32 $40€
lrs $107.70 I $862
lrs $103.87 I $831
't rs 124.21 8 $994
lrs $42.14 $C
lrs 15.87 56 $88S
sf $3.30 4,200 $13.86C
7 12612005 - 2:32 PM-WM.RecPlanEst.Feb2005(1 )
MILL DECOMMISSIONINGo
ircuit RemovalVanadium Oxidation C
Total Office Building Demolition
Total Vanadium Oxidation Circuit Removal
Main ShopMarehouse Demolition
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 w/ PC-400 metalShears
Equipment Maintenance (Butler)
Concrete Removal
Total Main ShopMlarehouse Demolition
Office Building Demolition
Resource Description Units CosUUnit
$18,816
Task Units Task Cost
$93'401
Task Units Task Cost
$37,408
lnternational Uranium (USA) Corp.
White Mesa Mill
Resource Units CosVUnit Task Units Task Cost
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 w/ PC-400 metalShears
65 Ton Crane
30 Ton Crane
Equipment Maintenance (Butler)
Concrete Removal
hrs $17.72 48 $850
hrs 14 4A 64 $922
hrs $10.35 32 331
hrs $1.30 96 $1 25
hrs t2.6b 64 $4.662
hrs 12.74 64 $81 5
hrs $107.70 16 $1,723
hrs $103.87 16 $1,662
hrs $124.21 16 $1,987
hrs $63.28 $C
hrs $42.14 $o
hrs $15.87 112 $1.777
sf 3.30 1.20C $3.96C
$17.72
$3,975
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 W PC-400 metalShears
Equipment Maintenance (Butler)
Concrete Removal
hrs 17.72 72 1.27e
hrs $14.40 9€$1,383
hrs $10.35 4e s497
hrs $1.30 144 187
hrs s72.85 9€6.994
hrs $12.74 9€1,223
hrs $107.70 24 $2,s85
hrs $103.87 24 2.493
hrs $124.21 24 2.981
hrs $15.87 't6E $2,66€
sf $1.25 12.10C 15 125
7 12612005 - 2:32 PM-WM.RecPlanEst.Feb2005('l)
MILL DECOMMISSIONINGo
Parts RemovalMisc. Tankage & Spare
Total Mill Yard Decontamination
Ore Storage Pad Decontamination
Total Misc. Tankage & Spare Parts Remova!
Mill Yard Decontamination
$7,428
Cost
Cost
lnternational Uranium (USA) Corp.
White Mesa Mill
CosUUnit
Units Task Units
Total Ore Storage Pad Decontamination
Equipment Storage Area Gleanup
Cat 637 Scraper
Cat 988 Loader
Cat D8N Dozer With Ripper
CalDT Dozer
Cat 651 Waterwagon
Cat 14G Motorgrader
Equipment Maintenance (Butler)
Total Equipment Storage Area Cleanup
Resource Units CosUUnit Task Units Task Cost
Equipment Operators
Mechanics
Laborers
Small Tools
Cat 769 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 365 Excavator
Cat 330 w/ PC-400 metalShears
Equipment Maintenance (Butler)
Concrete Removal
hrs $17.72 24 $425
hrs 14.40 32 461
hrs $10.35 1e 166
hrs $1.30 4t $62
hrs $72.85 5z $2,331
hrs s12.74 32 408
hrs $107.70 t $862
hrs $103.87 €$831
hrs $124.21 t 994
hrs $15.87 5e 889
SI 1.25 $o
Resource Units ask Units Task
Equipment Operators
Cat 637 Scraper
Cat 988 Loader
Cat D8N Dozer With Ripper
CatDT Dozer
Cat 651 Watenvagon
Cat 14G Motorgrader
Equipment Maintenance (Butler)
hrs $17.72 582 $10,312
hrs $161.97 257 $41,626
hrs $107.70 6a $7.001
hrs $77.83 65 $5,059
hrs s65.01 65 $4,226
hrs s83.66 65 $5.438
hrs $53.64 65 $3,486
hrs $15.87 582 $9,235
Resource ask
Equipment Operators
Cat 637 Scraper
Cat 988 Loader
Cat D8N Dozer With Ripper
Cat D7 Dozer
Cat 651 Waterwagon
Cat 14G Motorgrader
Equipment Maintenance (Butler)
hrs $17.72 429 $7,601
hrs $161 .97 189 $30,612
hrs $107.70 48 $5.1 70
hrs $77.83 48 $3,736
hrs $65.01 48 $3,1 21
hrs u3.eio 48 $4,016
hrs 53.64 48 $2.575
hrs $15.87 429 $6,807
7 12612005 - 2:32 PM-WM.RecPlanEst.Feb2005(1 )
Revegetate Mi!! Yard & Ore Pad
Resource Description
Total Revegetate Mill Yard & Ore Pad
Total Demolition and Decontamination
CLEANUP OF WIN DBLOWN CONTAMINATION
MILL DECOMMISSIONING
Units CosUUnit Task Units Task Cost
$35,622
Equipment Operators
Cat 637 Scraper
Cat 988 Loader
Cat D8N Dozer With Ripper
Cat D7 Dozer
Cat 651 Watenvagon
Cat 14G Motorgrader
Equipment Maintenance (Butler)
1rs $17.72 231 $4,093
hrs s161 .97 132 $21.380
1rs $107.70 C $o
1rs $77.83 33 $2,568
1rs $65.01 33 $2.145
1rs $83.66 $o
1rs $53.64 33 $1,770
1rs $15.87 231 $3.665
Scoping Survey
$10,425
Resource
Survey Crew
Sample Crew
Tota! Scoping Survey
Characterization Survey
Resource
Sample Crew
Total Gharacterization Survey
Final Status Survey
Resource Description
CosUUnit Task Units Task Cost
Cost/Unit
CosVUnit
$33,613
Task Units Task Cost
$39'349
Task Units Task Cost
Soil Samples
Sample Crew
Total Final Status Survey
Windblown Cleanup
$64,242
Resource Units CosUUnit Task Units Task Cost
Equipment Operators
Cat 637 Scraper
Cat D8N Dozer With Ripper
Cat D7 Dozer
Cat 14H Motorgrader
Soil Samples
Survey Crew
Sample Crew
Equipment Maintenance (Butler)
hrs s17.72 1 .19C $21.084
hrs $161.97 68C $1 10,139
hrs $77.83 17C.$13,231
hrs $65.01 17C $1 1,052
hrs $53.64 17C $9.118
each $50.00 50c $25,000
nrs $13.86 163 $2,260
hrs $13.86 83 $1 15't
hrs $15.87 't,19C $18,883
Total Windblown Cleanup
Quality Control
$211,917
Resource Description Units CosUUnit Task Units Task Cost
Total Quality Control
Total Cleanup Windblown Contamination
$128,960
l-$-A?Ep-BTl
lnternational Uranium (USA) Corp.
White Mesa Mill7 12612005 - 2:32 PM-WM.RecPlanEst.Feb2005( I )
MILL DECOMMISSION!NG
Alternate Feed Disposal
Linde, Cabot, Heritage Material and FMRI
Total Linde, Gabot, Heritage & FMRI Material
Total Quantity
Resource
Flat Bed Trailer and Tractor*
Fork Lift (2)
Total Cameco Barrels
* includes operator
Sub-Total Alternate Feed Disposal
TOTAL MILL DECOMMISSIONING
$80,957
77,943 Cubic Yards (as of 07/01/05, plus FMRI)
196 Cubic Yards per Truck per hour
398 Truck Hours
CosUUnit Task Units Task Cost
$34,702
33,451 Barrels (as of 07/01/05)
40 Barrels per load
0.4 Hours per load
335 Truck Hours
l-5Tis^6-5rl
lnternational Uranium (USA) Corp.
White Mesa Mill
Resource Units CosUUnit Task Units Task Cost
Equipment Operators
Cat 769 Haul Truck (3)
Cat 988 Loader
Cat 651 Waterwagon
Cat 14G Motorgrader
Equipment Maintenance (Butler)
1rs $17.72 713 $12,629
lrs $72.85 398 $28,970
1rs $107.7C 133 sl4.277
1rs $83.6€133 $11,089
1rs $53.64 5C $2,682
'lrs $15.87 713 s'l 1 .310
Cameco Barrels
$12.74
7 l?612005 - 2:32 PM-WM.RecPlanEst.Feb2005(1 )
CELL 4A CLEANUP
CELL 4A CLEANUP
Dewatering of Cell 4A
Resource Description Units CosUUnit Task Units Task Cost
Total Dewatering of Cell 4A - COMPLETE
Remove Fencing
Resource
Equipment Operators
Equipment Maintenance (Butler)
Laborers
Total Remove Fencing
Remove Liner & Contaminated Material to Cell 3
Resource Description Units
CosUUnit
CosUUnit
$0
Task Units Task Cost
$7,307
Task Units Task Cost
Equipment Operators
Cat 769 Truck
Truck Driver
Cat 988 Loader
Equipment Maintenance (Butler)
hrs s17.72 303 $5,368
hrs $72.8r 606 $44.147
!rs s12.74 606 $7.721
hrs $107.70 303 $32,634
hrs $15.87 909 $14.424
Total Remove Liner & Contaminated Material to Cell 3 $104,294
Quality Control
Resource Description Units CosUUnit Task Units Task Cost
Total Quality Gontrol $9,920
Cell 4A Dike Breach
Resource Units CosVunit Task Units Task Cost
637E Scraper
D8R Dozer
14HlRipper Motor Grader
Equipment Maintenance (Butler)
1rs $17.72 180 s3.1 8S
hrs $161 .97 60 $9,718
hrs $77.83 60 $4.67C
1rs $53.64 60 s3.218
hrs $15.87 180 $2,856
Total Cell 4A Dike Breach
Work completed to Date, crystal and liner removal, see detail below
TOTAL CELL 4A CLEANUP REMAINING
$23,651
-$94,910
l-TsdE l
Estimate of Work Completed to Date - March 2004 to July 2005
Remove Liner & Contaminated Material to Cell 3
Resource CosVUnit Task Units Task CostUnits
quipment
Cat 769 Truck
Truck Driver
Cat 988 Loader
Equipment Maintenance (Butler)
Total Work Completed for Removal of Liner & Contaminated Material to Cell 3
lnternational Uranium (USA) Corp.
White Mesa Mill
$12.74
7 12612005 - 2:32 Pl/ - WM.RecPlanEst. Feb2005(1 )
$94,910
I);'J;il',i;:p
ConponATroN
Independetrce Plaza, Suite 950 . 1050 Seventeenth Street . Denve'r, CO 80265 . 303 628 7798 (rnain) r 303 389 4125 (fax)
April 1,2005
VIA FACSIMILE AND US MAIL
Mr. Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
salt Lake city, uT 841 l4-4810
Re: Application by International Uranium (USA) Corporation for an
amendment to State of Utah Radioactive Materials License No. 1900479 for the
White Mesa Uranium Mill to authorize processing of FMRI, Inc. ("FMRI")
alternate feed material
Dear Mr. Finerfiock:
In our letter to you o1'March 8, 2005, we asked that you review the referenced application
on an expedited basis. if possible. You have asked us for a more specific timeframe by
which we would request that this application be reviewed by you.
We understand and appreciate that you must take whatever time is necessary to fully
review our application and all public comments that you may receive, and that it is very
difficult for you to estimate how long this process will take for any particular application.
However, in response to your question and as discussed with you last Friday, a target date
of May 76,2005, or as soon thereafter as possible, for completion of the public comment
period for this licensc amendment application, and completion of your review of public
comments within a f-ew weeks thereafter, if possible, would best suit the commercial and
FMRI site regulatory timetables for this project.
If you have any questions or require any further information, please contact me.
Ron F. Hochstein
Harold R. Roberts
-.4
a'
Yours tru/'l
/,t l; l
David C.
Vice Pres al Counsel
nlund
and Genernt
cc:
Irrrnr.rrrorrl1)
UnaNluu (use)-
ConponATroN
Independence Plaza, Suite 950 r 1050 Seventeenth Street r Denver, CO 80265 r 303 628 7798 (main) r 303 389 4125 (fax)
March 8,2005
VIA FEDEX /f
Dane L. Finerfrock, Executive Secretary /
Utah Radiation Control Board I
Utah Department of Environmental Qualityl
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
r:.
Re: Application by International Uranium (USA) Corporation ("IUSA") for an
amendment to State of Utah Radioactive Materials License No. 1900479 for the
White Mesa Uranium Milt (the "Mill") to authorize processing of FMRI,Inc.
alternate feed material (the "Uranium Material")
Dear Mr. Finerfrock:
We are pleased to enclose with this letter two copies of an application to amend the
Mill's Radioactive Materials License No. 1900479 to authorize receipt and processing of
the Uranium Material as an alternate feed material primarily for the recovery of uranium
and disposal of the resulting tailings in the Mill's tailings impoundments as 11e.(2)
byproduct material.
The Uranium Material must be removed from the FMRI, Inc. facility under a tight
schedule established by the United States Nuclear Regulatory Commission pursuant to
the facility's Site Decommissioning Plan. As a result, we request that you review the
enclosed application on an expedited basis, if possible.
If you have any questions or require any further information, please contact me.
Ron F. Hochstein
Harold R. Roberts
Vice President and General Counsel
roN M. ilrrro", r*.
Governor
GARY HERBERT
Lieutenanl Governor
,@\
QP
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
April I1,2007
Mr. David C. Frydenlund
Vice President and General Counsel
International Uranium Corporation (IUC)
1050 Seventeenth St. Suite 950
Denver, Colorado, 80265
SUBJECT: Authorization to Receive and Process Alternate Feed Material from the FMRI's Muskogee Facility
Revised 1le.(2) Materials License Number UTl900479 Amendment #2 - Approval
Dear Mr. Frydenlund:
The appeal process by the Sierra Club that opposed the IUC proposal to receive and process alternate feed maierial from
Ponds 2 and 3 of the FMRI's Muskogee Facility located in Muskogee, Oklahoma is completed. In a Utah Radiation
Control Board (Board) hearing on March 2,2007 the Board ruled in favor of the Executive Secretary for the Division of
Radiation Control decision to allow IUC to receive and process the FMRI material. The 30 day window for the Sierra
Club to appeal the Board decision is now passed and the Utah Attorney General has verified that no appeal was filled by
the Sierra Club at the Utah Circuit Court. Therefore, the lle.(2) Materials License Number Ll-t1900479 (License)
Amendment #2 of June 13, 2006 is hereby effective.
As a courtesy, enclosed is a copy of the June 13,2006 License Amendment. We request that you carefully read the
License revision to ensure future compliance with its provisions. If you have any questions regarding the License please
contact Dean Henderson at [phone]. Thank you for your cooperation in this matter.
UTAH RADIATION CONTROL BOARD
DLFIDH
Enclosure
144850. Salr LakeCity, UT 841 144850. phone[phone]. fax (E0l) 5334097
T.D.D. (801 ) 53 64414 . wwv).deq.utah.gov
lltnh!
Dane L. Finerflock, Executive Secretary
Utah Radiation Control Board
168 North 1950 West. PO Box
Where ideas conrlecl-
DRC-03
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF RADIATION CONTROL
lle.(2) MATERIALS LI CENSE
pursuant to Utah Code Ann. Title 19, Chapter 3 and the Radiation Control Rules, Utah Administrative
Code R313, and in reliance on statements and representations heretofore made by the licensee
designated below, a license is hereby issued authorizing such licensee to transfer, receive, possess and
,r. th, radioactive material designated below; and to use such radioactive material for the purpose(s)
and at the place(s) designated below. This licensee is subject to all applicable rules, and orders now or
hereafter in effect and to any conditions specified below'
* *r(rF:r**.{(*r.r.*:r:F*r<**{.'$*:l'*x**'F:l'x**
LICENSEE
l. Name International Uranium
(ruSA) Corporation
2. Address 6425 HighwaY l9l
P.O. Box 809
Blanding,I-n 84511
,(:**.r1.:1.:f *:f r.:l.rF****t(*****t<**r(*{<***{€{€r€***(*
3. License Number UT1900479
Amendment # 2
{<rl.** **** rFd. {. * *{.,rrr**** {(rFrr rl.*d(** **<*.**.** *
4. Expiration Date
March 31,2007
*i(**rl.* r.*{<**.!t<rl. * * * ** *,f :** {.:F**rl.{.:N. {<**:i({.r.**
5. License Category 2'b
8. Maximum quantity licensee
may possess at any one time
Unlimited
6. Radioactive material
(element and mass number)
Natural Uranium
7. Chemical and/or
physical form
Any
*<{(rl.{.**rF:1.**:1.*i.**rf *****:li{€*.:1.*:1.:!r<r.***r.*.*:r*.d.i.**{<**{.r.,1.***{<{<*{<:1.****d.**r(*r(******{<***tr:r**
SECTIONS: ADMINISTRATMCONDITIONS
9.1
9.2
The authorized place of use shall be the licensee's White Mesa uranium rnilling facility, located
in San Juan County, Utah.
All written notices and reports to the Executive Secretary required under this license, with the
exception of incident and event notifications under R3l3-15-12O2 and R3l3-19-50 requiring
telephone notification, shall be addressed to the Executive Secretary, Utah Radiation Control
Board, Utah Department of Environmental Quality, 168 North 1950 West, P.O. Box 144850,
Salt I-ake City, UT 841144850.
Incident and event notifications that require telephone notification shall be made to the
Executive Secretary at [phone] during normal business hours or after hours to the DEQ
Duty Officer at [phone].
The licensee shall conduct operations in accordance with statements, representations, and
conditions contained in the license renewal application submitted by letter to the NRC dated
August 23,lggl,as revised by submittals to the NRC dated January 13,1992 and April 7,1992,
9.3
9.4
DRC-03
Page2 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SIIEET -Iic-ense #p[j900479
Amendment 2
November 22,1994,Ju|y27,1995. December l3,l996,andDecember3l, l996,andJanuary
30, lgg7 ,which are hereby incorporated by reference, and for the Standby Trust Agreement, as
amended, except where superseded by license conditions below.
Whenever the word "will" is used in the above referenced documents, itrshall denote a
requirement.
I Applicable NRC Amendment : 2 ]
A. The licensee may, without prior Executive Secretary-approval, and subject to the
conditions specified in Part B of this condition:
(l) Make changes in the facility or process, as presented in the application.
(2) Make changes in the procedures presented in the application.
(3) Conduct tests or experiments not presented in the application.
B. The licensee shall file an application for an amendment to the license, unless the
following conditions are satisfi ed.
(1) The change, test, or experiment does not conflict with any requirement
specifically stated in this license, or impair the licensee's ability to meet all
applicable regulations.
(Z) There is no degradation in the essential safety or environmental commitments in
the Iicense application, or provided by the approved reclamation plan.
(3) The change, test, or experiment is consistent with the conclusions of actions
analyzedand selected in the Environmental Assessment dated February 1997.
C. The licensee's determinations concerning Part B of this condition, shall be made by a
"safety and Environmental Review Panel (SERP)." The SERP shall consist of a
minimum of three individuals. One member of the SERP shall have expertise in
management and shall be responsible for managerial and financial approval changes;
one member shall have expertise in operations and/or construction and shall have
responsibility for implementing any operational changes; and, one member shall be the
corporate radiation safety officer (CRSO) or equivalent, with the responsibility of
assuring changes conform to radiation safety and environmental requirements.
Additional members may be included in the SERP as appropriate, to address technical
aspects such as health physics, groundwater hydrology, surface-water hydrology,
specific earth sciences, and other technical disciplines. Temporary members or
permanent members, other than the three above-specified individuals, may be
consultants.
9.5
DRC-03
Page 3 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SIIEBT
Ucense-#Un900479
Amendment 2
D. The licensee shall maintain records of any changes made pursuant to this condition until
license termination. These records shall include written safety and environmental
evaluations, made by the SERP, that provide the basis for determining that changes are
in compliance with the requirements referred to in Part B of this condition. The licensee
shall furnish, in an annual report to the Executive Secretary, a description of such
changes, tests, or experiments, including a summary of the safety and environmental
evaluation of each. In addition, the licensee shall annually submit to the Executive
Secretary changed pages to the Operations Plan and Reclamation Plan of the approved
license application to reflect changes made under this condition.
The licensee's SERP shall function in accordance with the standard operating
procedures submitted by letter to the NRC dated June 10, 1997.
[Applicable NRC Amendments: 3]
The licensee shall have 30 days from the signatory date of this license to submit financial surety
documents forExerutive Secretary-approved financial surety alTangement, consistent with UAC
R3l3-24 (10 CFR 40, Appendix A, Criteria 9 and 10, as incorporated by reference), adequate to
cover the estimated costs, if accomplished by a third party, for decommissioning and
decontamination of the mill and mill site, reclamation of any tailings or waste disposal areas,
ground-water restoration as warranted and the long-term surveillance fee. Within 3 months of
Executive Secretary approval of a revised reclamation/ decommissioning plan, the licensee shall
submit, forExecutive Secretary review and approval, a proposed revision to the financial surety
arrangement if estimated costs in the newly approved plan exceed the amount covered in the
existing financial surety. The revised surety shall then be in effect within 3 months of written
Executive Secretary aPProval.
Annual updates to the surety amount, required by UAC R3l3-244 (10 CFR 40, Appendix A,
Criteria 9 and 10, as incorporated by reference), shall be submitted to the Executive Secretary by
March 4 of each year. If the Executive Secretary has not approved a proposed revision to the
surety coverage 30 days prior to the expiration date of the existing surety arrangement, the
licensee shall extend the existing surety arrangement for I year. Along with each proposed
revision or annual update, the licensee shall submit supporting documentation showing a
breakdown of the costs and the basis for the cost estimates with adjustments for inflation,
maintenance of aminimum l5 percent contingency fee, changes in engineeringplans, activities
performed and any other conditions affecting estimated costs for site closure. The basis for the
cost estimate is the Executive Secretary-approved reclamation/decommissioning plan or
Executive Secretary-approved revisions to the plan. The previously provided guidance
contained in NUREG -1620, "Standard Review Plan for the Review of a Reclamation Plan for
Mill Tailings Sites under Title II of the Uranium Mill Tailings Radiation Control Act of 1978,"
outlines the minimum considerations used by the Executive Secretary in the review of site
9.6
DRC-o3
Page 4 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
ST]PPLEMENTARY SHEET
-- U c'en ae-#IlT :!-9f,D47 9
Amendment 2
closure estimates. Reclamation/decommissioning plans and annual updates should follow this
outline.
The currently approved surety instrument, a Performance Bond issued by National Union
Fire Insurance Company in favor of the Executive Secretary, and the associated Standby Trust
Agreement, shall be continuously maintained in an amount not less than $10,950,180 for the
purpor" of complying with UAC R313-24-4 (10 CFR 40, Appendix A, Criteria 9 and 10 as
incorporated by reference), until a replacernent is authorized by the Executive Secretary.
IApplicable NRC Amendments: 2, 3, 5, 13' 15, 19,21' 23, 24' 25]
[Applicable UDRC Amendment: I ]
Standard operating procedures shall be established and followed for all operational process
activities involving radioactive materials that are handled, processed, or stored- SOPs for
operational activities shall enumerate pertinent radiation safety practices to be followed.
Additionally, written procedures shall be established fornon-operational activities to include in-
plant and environmental monitoring, bioassay analyses, and instrument calibrations. An up-to-
date copy of each written procedure shall be kept in the mill area to which it applies.
All written procedures for both operational and non-operational activities shall be reviewed and
approved in writing by the radiation safety officer (RSO) before implementation and whenever a
.i,ung" in proceduie is proposed to ensure that proper radiation protection principles are being
apptied. ln addition, the RSO shall perform a documented review of all existing operating
procedures at least annuallY.
As per the Memorandum of Agreement (MOA) negotiated by the Utatr State Historic
presirvation Officer (SI{PO), the Advisory Council on Historic Preservation (ACHP), the NRC
and Energy Fuels Nuclear Inc. (EFN) and ratified on August 20, 1979 and as amended on May
3, 1983 and substantially as implemented in NRC License SUA-1358.
Before engaging in any activity not previously assessed by the Executive Secretary, the licensee
shall administer a cultural resource inventory. AII disturbances associated with the proposed
development will be completed in compliance with theNational Historic Preservation Act (as
amendid; and its implementing regulations, and the Archaeological Resources Protection Act
(as amended) and its implementing regulations.
In order to ensure that no unapproved disturbance of cultural resources occurs, any work
resulting in the discovery of previously unknown cultural artifacts shall cease. The artifacts
shall belnventoried and evaluated in accordance with the National Historic Prcservation Act (as
amended), and no disturbance shall occur until the Iicensee has received authorization from the
Executive Secretary to Proceed.
9.7
DRC.O3
Page 5 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SIIEET
uCense #UI1900479
Amendment 2
The licensee shall avoid by project design, where feasible, the archeological sites designated
"contributing" in the report submitted by Ietterto the NRC dated July 28, 1988. When it is not
feasible to avoid a site designated "contributing" in the report, the licensee shall institute a data
recovery program for that site based on the research design submitted by letter from C. E. Baker
of Energy Fuels Nuclear to Mr. Melvin T. Smith, Utah State Historic Preservation Officer
(SHPO), dated APril 13, 1981.
The licensee shall recoverthrough archeological excavation all "contributing" sites listed in the
report which are located in or within 100 feet of borrow areas, stockpile areas, construction
areas, or the perimeter of the reclaimed tailings impoundment. Data recovery fieldwork ateach
site meeting these criteria shall be completed prior to the start of any project related disturbance
within 100 feet of the site, but analysis and report preparation need not be complete.
Additionally, the licensee shall conduct such testing as is required to enable the Executive
Secretary to determine if those sites designated as "Undetermined" in the report and located
within 100 feet of present or known future construction areas are of such significance to warrant
their redesignation as "contributing." In all cases, such testing shall be completed before any
aspect of the undenaking affects a site.
Archeological contractors shall be approved in writing by the Utah SIIPO. The Utah SHPO will
approve an archeological contractor who meets the minimum standards of the State of Utah as
the princiPal investigator.
9.8 The licensee is hereby authorized to possess byproduct material in the form of uranium waste
tailings and other uranium byproduct waste generated by the licenseets milling operations
authorized by this license. Mill tailings shall not be transferred from the site without specific
prior approval of the Executive Secretary in the form of a license amendment. The licensee
shall maintain a permanent record of all transfers made under the provisions of this condition.
g.g The licensee is hereby exempted from the requirements of R3 13- I 5-902(5) for areas within the
mill, provided that all entrances to the mill are conspicuously posted in accordance with R3l3-
lS-9O2(5) and with the words, "Any area within this mill may contain radioactive material".
9.10 Release of equipment orpackages from the restricted area shall be in accordance with the NRC
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted
Use orTermination of Licenses forByproduct, Source, orSpecial NuclearMaterial," datedMay
1987, or suitable alternative procedures approved by the Executive Secretary prior to any such
release.
DRC.O3
Page 6 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMBNTARY SIMET --trcense fIIfl-90O479
Amendment 2
9.1I The final reclamation shall be in accordance with the May 1999, Reclamation Plan Revision
2.0, Attachment A, submitted to the NRC on June22,l999, and Revision 3.0 submitted to the
NRC on JulY 17,2000.
sEGTION 10: OPERATIONAL CONTROLS, LIMITS, AND RESTRICTIONS
l0.l A. The mill production rate shall not exceed 4380 tons of yellowcake per year.
B. The Iicensee may not dispose of any material on site that is not "blproduct material," as
that term is defined in 42 U.S.C. Section 2Ua@)Q) (Atomic Energy Act of 1953,
Section 1l(eX2)).
C. The licensee may not receive or process any alternate feed material without first
applying for and obtaining approval of a license amendment. For any such proposal, the
licensee shall demonstrate that it will comply with Condition 10.1(8). Any such
demonstration shall include:
l) Demonstration of compliance with the NRC Regulatory Summary 2O0O-23
Recent Changes to Uranium Recovery Policy, November 30, 2000; and
Z) Demonstration of compliance with the November 22, L999 Protocol for
Determining Whether Alternate Feed Materials are Usted Hazardous Wastes, as
approved by the Utah Division of Solid and Hazardous Waste on December 7,
1999.
D. Maximum quantities of feed material stored on the mill site, including alternate feed
materials or other ores, shall not exceed the total material storage quantity found in the
currently approved mill surety pursuant to License Condition 9.5, without prior approval
of the Executive Secretary.
E. The licensee may not receive any alternate feed materials or other ores if those materials
would cause the facility to exceed the tailings cell disposal capacity established by the
currently approved reclamation plan and/or the annual surety report required by License
Conditions 9.11, and 9.5, respectively, without prior approval of the Executive
SecretarY.
I Applicable UDRC Amendment: 2]
DRC.O3
PageT of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
License #tnl9m479
Amendment 2
lo.2 All liquid effluents from mill process buildings, with the exception of sanitary wastes, shall be
returned to the mill circuit or discharged to the tailings impoundment.
10.3 Freeboard limits for Cells l-I, 3, and 4A, shall be set periodically in accordance with the
procedures set out in Section 3.0 to Appendix E of the previously approved NRC license
application, including the October 13,1999 revisions made to the January 10, 1990 Drainage
Report. The freebo-a f-it for Cell 3 shall be recalculated annually in accordance with the
procedures set in the October 13,1999 revision to the Drainage Report.
[Applicable NRC Amendment: 16]
10.4 Disposal of material and equipment generated at the mill site shall be conducted as described in
thelicensee's submittals to the NRC dated December 12, 1994 and May 23, 1995, with the
following addition:
A. The maximum lift thickness for materials placed over tailings shall be less than 4-feet
rhick. Subsequent lifts shall be less thanZ-feetthick. Each lift shall be compacted by
tracking of heavy equipment, such as a Cat D-6, at least 4 times prior to placement of
subsequent lifts.
10.5 In accordance with the licensee's submittal to the NRC dated May 2o,1993, the licensee is
hereby authorized to dispose of byproduct material generated at licensed in-situ leach facilities,
subject to the following conditions:
A. Disposal of waste is limited to 5000 cubic yards from a single source'
B. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the
disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified
to be full prior to disposal. Barrels not completely full shall be filled with tailings or
soil.
c. All waste shall be buried in cell No. 3 unless prior written approval is obtained from the
Executive Secretary for alternate burial locations'
D. All disposal activities shall be documented. The documentation shall include
descripiions of the waste and the disposal locations, as well as all actions required by
this condition. An annual sunrmary of the amounts of waste disposed of from off-site
generators shall be sent to the Executive Secretary'
DRC.O3
Page 8 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
l-icen-se *Uft900479
Amendment 2
10.6 The licensee is authorized to receive and process source materials from the Allied Signal
Corporation's Metropolis, Illinois, facility in accordance with the amendment request to the
NRC dated June 15, 1993.
lO.7 The licensee is authorized to receive and process source material from Allied Signal, Inc. of
Metropolis, Illinois, in accordance with the amendment request to the NRC dated September 20,
lgg1,and amended by letters to the NRC dated October 30,1996 and November 11, 1996.
10.8 The licensee is authorized to receive and process source material, in accordance with the
amendment request to the NRC dated March 5,1997.
[Applicable NRC Amendments: I ]
10.9 The licensee is authorized to receive and process source material from Cabot Performance
Materials' facility near Boyertown, Pennsylvania, in accordance with the amendment request to
the NRC dated April 3, 1997, as amended by submittals to the NRC dated May 19, 1997 and
August 6, 1997.
I Applicable NRC Amendments: 4 ]
10.10 The licensee is authori zedto receive and process source material from the Ashland 2 Formerly
Utilized Sites Remedial Action Program (FUSRAP) site, located nearTonawanda, New York,
in accordance with the amendment request to the NRC dated May 8, 1998, as amended bythe
submittals to the NRC dated May 27, 1998, June 3, 1998, and June 1 l, 1998.
I Applicable NRC Amendments: 6 ]
10.11 The licensee is authorizedto receive and process source material from Cameco Corporation's
Blind River and Port Hope facilities, located in Ontario, Canada, in accordance with the
amendment request to the NRC dated June 4, 1998, and by the submittals to the NRC dated
September 14,lggl,September 16, 1998, September 25,lgg&,October7, 1998, and October 8,
1998.
However, the licensee is not authorized to receive or process from these facilities, the crushed
carbon anodes identified in these submittals, either as a separate material or mixed in with
material already approved for receipt or processing.
1112 The licensee is authorized to receive and process source material from the Ashland I and
SeawayAreaD Formerly Utilized Sites Remedial Action Program (FUSRAP) site,locatednear
Tonowanda, New York, in accordance with statements, representations, and commitments
contained in the amendment request to the NRC dated October 15, 1998, as amended by letters
to the NRC dated November 23,lgg1,November 24,1998, December 23,1998, January 11,
1999, January 27,1999, and February 1,1999.
DRC-03
Page 9 of 14
UTAH DIVISION OF RADIATION CONTROL
RADI OA CTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
trcense #1II190M79
Amendment 2
[Applicable NRC Amendment: 10]
10.13 The licensee is authorizedto receive and process source material from the St.Iouis Formerly
Utilized Sites Remedial Action Program (FIJSRAP) site, in accordance with statements,
representations, and commitments contained in the amendment request to the NRC dated March
Z,1999, and as amended and supplemented by submittals dated June 21, 1999;June29,L999
(2); and July 8, 1999. Prior to the licensee receiving materials from the St. Ipuis FUSRAP site,
the licensee must make a determination that adequate tailings space is available forthe tailings
produced from the processing of this material. This determination shall be made based on a
SERP approved internal procedure.
[Applicable NRC Amendments: I j, 14]
10.14 The licensee is authorized to receive and process source material from the Linde Formerly
Utilized Sites Remedial Action Program (FUSRAP) site, in accordance with statements,
representations, and commitments contained in the NRC amendment request dated March 16,
2000, and as amended and supplemented by submittals dated April 26, 2000, May 15, 2000,
June 16, 20}0,June 19,2000, andJune 23,2000.
Prior to the licensee receiving materials from the Linde FUSRAP site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on a SERP-approved
internal procedure. Design changes to the cells or the reclamation plan require the licensee to
. submit an amendment request for Executive Secretary review and approval.
Prior to the Iicensee receiving materials from the Linde FUSRAP site, the licensee must require
that the generator of the material certify that the material does not contain listed hazardous
waste as defined under the Resource Conservation and Recovery Act (RCRA) per a Radioactive
Material Profi le Record'
[Applicable NRC Amendment: 14]
10.15 The licensee is authorized to receive and process source material from the W.R. Grace site
located in Chattanooga, Tennessee, in accordance with statements, representations, and
commitments contained in the amendment request to the NRC dated April 12, 2000, as
amended and supplemented by submittals dated Apil24,2000, April26,2000, May 5,2000,
November 16,2000, and December 18,2000.
Prior to the licensee receiving materials from the W.R. Grace site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on the SERP-approved
standard operating procedure for determination of tailings capacity. Design changes to the cells
DRC-03
Page 10 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
License #IIf 1900,fl9
Amendment 2
or the reclamation plan require the licensee to submit an amendment request for Executive
Secretary review and aPProval'
prior to the licensee receiving materials from the W.R. Grace site, the licensee must require that
the generator of the material certify that the material does not contain listed hazardous waste as
defined underthe Resource Conservation andRecovery Act (RCRA) per aRadioactive Material
Profile Record.
[Applicable NRC Amendment: 17]
10.16 The licensee is authorizedtoreceive and process source material from the Heritage Minerals
Incorporated site, in accordance with statements, representations, and commitments contained in
the amendment request to the NRC dated July 5, 2000, and as supplemented by submittals dated
November 16, 2000, and December 18,2000'
prior to the licensee receiving materials from the Heritage Minerals Incorporated site, the
licensee must make a determination that adequate tailings space is available for the tailings
produced from the processing of this material. This determination shall be made based on the
sERr-upproved standard operating procedure for determination of tailings capacity. Design
changesio the cells or the reclamation plan require the licensee to submit an amendment request
for Executive Secretary review and approval'
prior to the licensee receiving materials from the Heritage Minerals Incorporated site, the
licensee must require that the generator of the material certify that the material does not contain
listed hazardous waste as defined under the Resource Conservation and Recovery Act (RCRA)
per a Radioactive Material Profile Record'
[Applicable NRC Amendment: 18]
10.17 The licensee is authori zedtoreceive and process source material from the Molycorp site located
in Mountain pass, california, in accordance with statements, representations, andcommitments
contained in the amendment request to the NRC dated December 19, 2000, and supplemental
information in letters dated January 29,2}Ol,February 2,2OOl, March 20,2001, August 15,
2001, October 17,2001, and November 16, 2OOl'
prior to the licensee receiving materials from the Molycorp site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on a SERP-approved
internal procedure. Design changes to the cells or the reclamation plan require the licensee to
submit an amendment request for Executive Secretary review and approval.
I Applicable NRC Amendment: 20 ]
DRC-03
Page ll of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #!If1900479
Amendment 2
l0.l g The licensee is authorized to receive and process source material from the Maywood site located
in Maywood, New Jersey, in accordance with statements, representations, and commitments
contained in the amendment requests to the NRC dated June 15, 2001,June22,2001, August 3,
Zgxl,and supplemented by letters dated November 19, zDl,December 6, z00l,December 10,
zCfl,March ll, 2N2, and JulY l, 2N2.
prior to the licensee receiving materials from the Maywood site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on a SERP-approved
internal procedure. If such determination requires the licensee to make design changes to the
cells or the reclamation plan, the licensee shall submit an amendment request for Executive
Secretary review and aPProval.
prior to the licensee receiving materials from the Maywood site, the licensee must require that
the generator of the material certify that the material does not contain listed hazardous waste as
defined under the Resource Conservation and Recovery Act (RCRA) per a Radioactive Material
Profile Record.
[Applicable NRC Amendment: 22]
10.19 The licensee is authorizedto receive and process source material from Ponds 2 and 3 of the
FMRI's Muskogee Facility ]ocated in Muskogee, Okalahoma, in accordance with statements,
representations, and commitments contained in the amendment requests and submittals to the
Eiecutive Secretary dated March 7,2OO5,Jwe22,2OO5, and April 28,2006.
[Applicable UDRC Amendment: 2]
SECTION 11: MOMTORING, RECORDING, AND BOOKKEEPING REQUIREMENTS
ll.l The results of sampling, analyses, surveys and monitoring, the results of calibration of
equipment, reports on audits and inspections, all meetings and training courses required by this
liiense and any subsequent reviews, investigations, and corrective actions, shall be documented.
Unless otherwise specified in the State of Utah regulations all such documentation shall be
maintained for a period of at least five (5) years.
ll.Z The licensee shall implement the effluent and environmental monitoring program specified in
Section 5.5 of the renewal application, as amended by the submittal to the NRC dated June 8,
lgg5,and as revised with the following modifications or additions:
A. Stack sampling shall include a determination of flow rate'
DRC-03
Page 12 of 14
UTAH DIVISION OF RADIATION CONTROL
RADI OA CTIVE MATERIALS LICENSE
SUPPLEMENTARY SITEET
License #IIII9004Z9
Amendment 2
B. Sudace water samples shall also be analyzed semiannually for total and dissolved U-nat,
Ra-226, and Th-230, with the exception of the Westwater Creek, which shall be
sampled annually for water or sediments and analyzed as above. A sediment sample
shall not be taken in place of a water sample unless a water sample was not available.
C. Groundwater sampling shall be conducted in accordance with the requirements in
License Condition I 1.3.
D. The licensee shall utilize lower limits of detection in accordance with Section 5 of the
NRC Regulatory Guide 4.14, as amended, for analysis of effluent and environmental
samPles.
E. The inspections performed semiannually of the critical orifice assembly committed to in
the submittal to the NRC dated March 15, 1986, shall be documented. The critical
orifice assembly shall be calibrated at least every 2yearsagainst apositive displacement
Roots meter to obtain the required calibration curve'
[Applicable NRC Amendment: 5]
11.3 The licensee shall implement a groundwater detection monitoring program to ensure
compliance to l0 CFR Part 40, Appendix A. The detection monitoring program shall be in
accordance with the report entitled, "Points of Compliance, White Mesa Uranium Mill,"
submitted by letter to the NRC dated October 5,1994, and the following:
A. The licensee shall sample monitoring wells WMMW-5, -l l, -12, -14, -15, and -17, on
a quarterly basis. Samples shall be analyzed for chloride, potassium, nickel, and
uranium, and the results of such sampling shall be included with the environmental
monitoring reports submitted in accordance with l0 CFR 40.65.
In addition, the licensee shall implement a monitoring program of the leak detection systems for
the disposal cells as follows:
B. The licensee shall measure and record the "depth to fluid" in each of the tailings
disposal cell standpipes on a weekly basis. If sufficient fluid is present in the leak
detection system (I-DS) of any cell, the licensee shall pump fluid from the LDS, to the
extent reasonably possible, and record the volume of fluid recovered. Any fluid pumped
from an LDS shall be returned to a disposal cell'
If fluid is pumped from an LDS, the licensee shall calculate the flow rate by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last pumped or
UTAH DIVISION OF RADIATION CONTROL
RADIOA CTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
DRC-03
Page 13 of 14
-LTense #UI'1900,179
Amendment 2
increases in the LDS fluid levels were recorded, whichever is the more recent. The
licensee shall document the results of this calculation.
C. Upon the initial pumping of fluid from an LDS, the licensee shall collect a fluid sample
and analyze the fluii r- pH and the parameters listed in paragraph A of this license
condition. The license" irrAl determine whether the LDS fluid originated from the
disposal cell by ascertaining if the collected fluid contains elevated levels of the
constituents lisied in paragraph A of this license condition or has a pH level less than
5.0. If either elevated constituent levels or a pH less than 5.0 is observed, the licensee
shall assume that the disposal cell is the origin of the fluid.
If the LDS fluid is determined not to have originated from the disposal cell, the licensee
shall continue with weekly measurements of "depth to fluid" in the LDS standpipes.
The Iicensee shall confirm, on an annual basis, that fluid from the disposal cell has not
entered the LDS by collecting (to the extent possible) and anallzing an I-DS fluid
sample for the above stated parameters'
D. Upon indication that the LDS fluids originated from the disposal cell, the licensee shall
determine the flow rate through the liner by the calculation method in paragraph B of
this Iicense condition. If the flow rate is equal to or greater than one gallon per minute,
the licensee shall:
l. Evaluate the cause of the liner distress and take appropriate and timely actions to
mitigatetheleakandanyconsequentpotentialimpacts;
Z. Continue to measure and record LDS "depth to fluid" measurements weekly;
and
3. Notify the Executive Secretary by telephone within 48 hours, in accordance with
License Condition 9.2, andsubmit a written report within 30 days of notifying
the Executive Secretary by telephone, in accordance with License Condition 9.2.
The written report shall include a description of the mitigative action(s) taken
and a discussion of the mitigative action results'
If the calculated flow rate is less than one gallon per minute, the licensee shall continue
with weekly measurements of "depth to fluid" in the LDS standpipes'
E. All sampling, analysis, and evaluation of LDS fluids shall be documented and retained
onsite until iicense termination for Executive Secretary inspection.
lApplicable NRC Amendment: 8]
o
DRC.O3
Page 14 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOA CTIVE MATERIALS LICENSE
SUPPLEMENTARY STIEET
ticense #Irrl9 479
Amendment 2
ll.4 Annually, thelicensee shall collect, during mill operations, a set of air samples covering eight
hours of samplin g, at a high collection flow rate (i.e., greater than or equal to 40 liters per
minute), in routinlly or frequently occupied areas of the mill. These samples shall be analyzed
for gross alpha. In addition, wiih each change in mill feed material or at least annually, the
licensee shall analyze the mill feed or production product for U-nat, Th-230,Ra-226, and Pb-
210 and use the analysis results to assess the fundamental constituentcomposition of airsample
Particulates.
[Applicable NRC Amendment: 7]
11.5 calibration of in-plant air and radiation monitoring equipment shall be performed as specified in
the license renewal application, under Section 3.0 of the "Radiation Protection Procedures
Manual,,, with the exception that in-plant air sampling equipment shall be calibrated at least
quarterly and air sampling equipment checks shall be documented'
ll.6 The licensee shall perform an annual ALARA audit of the radiation safety program in
accordance with the NRC Regulatory Guide 8'31'
SECTION 12: REPORTING REQI'IIREMENTS
12.1 DELETED bY NRC Amendment 13'
[APPlicable NRC Amendment: 13]
12.2 The licensee shall submit a detailed decommissioning plan to the Executive Secretary at least
twelve (12) months prior to planned final shutdown of mill operations that includes a detailed
euality Assurance itan. rtre plan will be in accordance with NRC Regulatory Guide 4.15'
.Qualiiy Assurance for Radiological Monitoring Programs" and NUREG -L575, 'Multi-Agency
Radiation Survey and Site lnvestigation Manual (MARSSM)" or equivalent most current
guidance.
lApPlicable NRC Amendment: 13]
[ApPlicable IJDRC Amendment: I ]
[ApPlicable UDRC Amendment: 2]
UTAH RADIATION CONTROL BOARI)
roN M. rul,o*, r*.
Governor
GARY HERBERT
Lieutenant Governor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson. Ph.D.
Executive Director
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
provlsrons.
536-0046.
June 12,2006
Mr. David C. Frydenlund
Vice President and General Counsel
International Uranium Corporation (IUC)
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Authorization to Receive and Process Alternate Feed Material from the FMRI's Muskogee Facility
Revised Ground Water Quality Discharge Permit UGW370004
Revised 11e.(2) Materials License Number UT190&179 Amendment #2
Public Participation Summary, License Amendment No. 2
Dear Mr. Frydenlund:
We have resolved all public comments received during the public participation period. Therefore, the Utah Division of
Radiation Control authorizes IUC to receive and process alternate feed material from Ponds 2 and 3 of the FMRI's
Muskogee Facility located in Muskogee, Oklahoma.
Minor modifications have been incorporated into the Ground Water Quality Discharge Permit UGW370004 (Pennit) and
the l le.(2) Materials License Number UTL9OO419 (License) Amendment #2 both effective June 13, 2006. Enclosed are
copies of the modified Permit, License Amendment and a copy of the Public Participation Summary (PPS).
We request that you carefully read the final Perrnit and License revision to ensure future compliance with their
If you have any questions regarding the final Permit, License or PPS please contact Dean Henderson at (801)
Thank you for your cooperation in this matter.
UTAH RADIATION CONTROL BOARD
/:.-Ar?
Dane L. Finerfrock, Ex{ghtive Secretary
Co- Executive Secretary, Utah Water Quality Board
DLF/DH
Enclosures
168 North 1950 West. P0 Box 1,14850. Salr Lake City, UT 841 l4-4850. phone [phone]. fax [phone]
T.D.D. (801 ) 536-4414. www.de q.utah. gov
lltah!
lNhere ideas connect"'
DRC-03
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF RADIATION CONTROL
lle.(2) MATERIALS LI CENSE
Pursuant to Utah Code Ann. Title 19, Chapter 3 and the Radiation Control Rules, Utah Administrative
Code R313, and in reliance on statements and representations heretofore made by the licensee
designated below, a license is hereby issued authorizing such licensee to transfer, receive, possess and
use the radioactive material designated below; and to use such radioactive material for the purpose(s)
and at the place(s) designated below. This licensee is subject to all applicable rules, and orders now or
hereafter in effect and to any conditions specified below.
***xx*********************************{<********{<*****{<*******x*r<*d<***d<*d<d<*****x**
1. Name
2. Address
)
6425Highway l9l )
P.O. Box 809 )
Blanding, UT 84511 )
)
LICENSEE
International Uranium
(ruSA) Corporation
) 3. License Number IJT1900479
) Amendment # 2
) xxxxx*{<{<{<*{<**xx*d<d<*****d<***{<**{<{<****
4. Expiration Date
March 31,2007
* * x {< * * * {< * * r< {< * * * * * x * * * * {< * * * * * * * * * d< d< * * *
5. License Category 2-b
*{<*{<*{<**{<****r<**{<*r<{<{<*8******d(*r<d({<r<**********************{<*{<{<{<*****{<********{<{<t<*
6. Radioactive material
(element and mass number)
7. Chemical and/or
physical form
8. Maximumquantitylicensee
may possess at any one time
UnlimitedNatural Uranium Any
x * x * * * * * * * * * {< * * * {< * d< * * {< * {< {< r< {< * {< * * * * * * * * * x * * * * x x * * * * *
SECTION9: ADMINISTRATIYE CONDITIONS
{<{<******
9.1
9.2
The authorized place of use shall be the licensee's White Mesa uranium milling facility, located
in San Juan County, Utah.
All written notices and reports to the Executive Secretary required under this license, with the
exception of incident and event notifications under R313-15-1202 and R313-19-50 requiring
telephone notification, shall be addressed to the Executive Secretary, Utah Radiation Control
Board, Utah Department of Environmental Quality, 168 North 1950 West, P.O. Box 144850,
Salt Lake city, uI 84114-4850.
Incident and event notifications that require telephone notification shall be made to the
Executive Secretary at [phone] during normal business hours or after hours to the DEQ
Duty Officer at [phone].
The licensee shall conduct operations in accordance with statements, representations, and
conditions contained in the license renewal application submitted by letter to the NRC dated
August 23,1991,as revisedby submittals to the NRC datedJanuary 13,1992 andApril7,1992,
9.3
A.9.4
B.
DRC-03
Page2 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #W1900479
Amendment 2
November22,1994,July27,1995. December13,1996,andDecember3l,l996,andJanuary
30,1997 , which are hereby incorporated by reference, and for the Standby Trust Agreement, as
amended, except where superseded by license conditions below.
Whenever the word "will" is used in the above referenced documents, it shall denote a
requirement.
I Applicable NRC Amendment: 2 ]
The licensee may, without prior Executive Secretary-approval, and subject to the
conditions specified in Part B of this condition:
(1) Make changes in the facility or process, as presented in the application.(2) Make changes in the procedures presented in the application.
(3) Conduct tests or experiments not presented in the application.
The licensee shall file an application for an amendment to the license, unless the
following conditions are satisfied.
(l) The change, test, or experiment does not conflict with any requirement
specifically stated in this license, or impair the licensee's ability to meet all
applicable regulations.(2) There is no degradation in the essential safety orenvironmental commitments in
the license application, or provided by the approved reclamation plan.(3) The change, test, or experiment is consistent with the conclusions of actions
analyzed and selected in the Environmental Assessment dated February 1997.
The licensee's determinations concerning Part B of this condition, shall be made by a
"Safety and Environmental Review Panel (SERP)." The SERP shall consist of a
minimum of three individuals. One member of the SERP shall have expertise in
management and shall be responsible for managerial and financial approval changes;
one member shall have expertise in operations and/or construction and shall have
responsibility for implementing any operational changes; and, one member shall be the
corporate radiation safety officer (CRSO) or equivalent, with the responsibility of
assuring changes conform to radiation safety and environmental requirements.
Additional members may be included in the SERP as appropriate, to address technical
aspects such as health physics, groundwater hydrology, surface-water hydrology,
specific earth sciences, and other technical disciplines. Temporary members or
permanent members, other than the three above-specified individuals, may be
consultants.
C.
9.5
DRC-03
Page 3 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #!l!00472
Amendment 2
D. The licensee shall maintain records of any changes made pursuant to this condition until
license termination. These records shall include written safety and environmental
evaluations, made by the SERP, that provide the basis for determining that changes are
in compliance with the requirements referred to in Part B of this condition. The licensee
shall furnish, in an annual report to the Executive Secretary, a description of such
changes, tests, or experiments, including a summary of the safety and environmental
evaluation of each. In addition, the licensee shall annually submit to the Executive
Secretary changed pages to the Operations Plan and Reclamation Plan of the approved
license application to reflect changes made under this condition.
The licensee's SERP shall function in accordance with the standard operating
procedures submitted by letter to the NRC dated June 10, 1997.
[Applicable NRC Amendments: 3]
The licensee shall have 30 days from the signatory date of this license to submit financial surety
documents for Executive Secretary-approved financial surety arrangement, consistent with UAC
R3l3-24 (10 CFR 40, Appendix A, Criteria 9 and 10, as incorporatedbyreference), adequate to
cover the estimated costs, if accomplished by a third party, for decommissioning and
decontamination of the mill and mill site, reclamation of any tailings or waste disposal areas,
ground-water restoration as warranted and the long-term surveillance fee. Within 3 months of
Executive Secretary approval of a revised reclamation/ decommissioning plan, the licensee shall
submit, forExecutive Secretary review and approval, a proposed revision to the financial surety
iurangement if estimated costs in the newly approved plan exceed the amount covered in the
existing financial surety. The revised surety shall then be in effect within 3 months of written
Executive Secretary approval.
Annual updates to the surety amount, required by UAC R3l3-24-4 (10 CFR 40, Appendix A,
Criteria 9 and 10, as incorporated by reference), shall be submitted to the Executive Secretary by
March 4 of each year. If the Executive Secretary has not approved a proposed revision to the
surety coverage 30 days prior to the expiration date of the existing surety arrangement, the
licensee shall extend the existing surety iurangement for I year. Along with each proposed
revision or annual update, the licensee shall submit supporting documentation showing a
breakdown of the costs and the basis for the cost estimates with adjustments for inflation,
maintenance of a minimum 15 percent contingency fee, changes in engineering plans, activities
performed and any other conditions affecting estimated costs for site closure. The basis for the
cost estimate is the Executive Secretary-approved reclamation/decommissioning plan or
Executive Secretary-approved revisions to the plan. The previously provided guidance
contained in NUREG-I620, "Standard Review Plan for the Review of a Reclamation Plan for
Mill Tailings Sites under Title tr of the Uranium Mill Tailings Radiation Control Act of 1978,"
outlines the minimum considerations used by the Executive Secretary in the review of site
9.6
DRC-03
Page 4 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
License #W-1900479
Amendment 2
closure estimates. Reclamation/decommissioning plans and annual updates should follow this
outline.
The currently approved surety instrument, a Performance Bond issued by National Union
Fire Insurance Company in favor of the Executive Secretary, and the associated Standby Trust
Agreement, shall be continuously maintained in an amount not less than $10,950,180 for the
purpose of complying with UAC R313-24-4 (10 CFR 40, Appendix A, Criteria 9 and 10 as
incorporated by reference), until a replacement is authorized by the Executive Secretary.
[Applicable NRC Amendments: 2, 3, 5, 13, 15, 19, 21, 23, 24, 25 ]
[Applicable UDRC Amendment: l]
Standard operating procedures shall be established and followed for all operational process
activities involving radioactive materials that are handled, processed, or stored. SOPs for
operational activities shall enumerate pertinent radiation safety practices to be followed.
Additionally, written procedures shall be established for non-operational activities to include in-
plant and environmental monitoring, bioassay analyses, and instrument calibrations. An up-to-
date copy of each written procedure shall be kept in the mill area to which it applies.
All written procedures for both operational and non-operational activities shall be reviewed and
approved in writing by the radiation safety officer (RSO) before implementation and whenever a
change in procedure is proposed to ensure that proper radiation protection principles are being
applied. In addition, the RSO shall perform a documented review of all existing operating
procedures at least annually.
As per the Memorandum of Agreement (MOA) negotiated by the Utah State Historic
Preservation Officer (SI{PO), the Advisory Council on Historic Preservation (AC}IP), the NRC
and Energy Fuels Nuclear Inc. (EFN) and ratified on August 20, 1979 and as amended on May
3, 1983 and substantially as implemented in NRC License SUA-1358.
Before engaging in any activity not previously assessed by the Executive Secretary, the licensee
shall administer a cultural resource inventory. All disturbances associated with the proposed
development will be completed in compliance with the National Historic Preservation Act (as
amended) and its implementing regulations, and the Archaeological Resources Protection Act
(as amended) and its implementing regulations.
In order to ensure that no unapproved disturbance of cultural resources occurs, any work
resulting in the discovery of previously unknown cultural artifacts shall cease. The artifacts
shall be inventoried and evaluated in accordance with the National Historic Preservation Act (as
amended), and no disturbance shall occur until the licensee has received authorization from the
Executive Secretary to proceed.
9.7
9.8
9.9
DRC-03
Page 5 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #W
Amendment 2
The licensee shall avoid by project design, where feasible, the archeological sites designated
"contributing" in the report submitted by letter to the NRC dated July 28, 1988. When it is not
feasible to avoid a site designated "contributing" in the report, the licensee shall institute a data
recovery program for that site based on the research design submittedby letterfrom C. E. Baker
of Energy Fuels Nuclear to Mr. Melvin T. Smith, Utah State Historic Preservation Officer
(SHPO), dated April 13, 1981.
The licensee shall recover through archeological excavation all "contributing" sites listed in the
report which are located in or within 100 feet of borrow areas, stockpile areas, construction
areas, or the perimeter of the reclaimed tailings impoundment. Data recovery fieldwork at each
site meeting these criteria shall be completed prior to the start of any project related disturbance
within 100 feet of the site, but analysis and report preparation need not be complete.
Additionally, the licensee shall conduct such testing as is required to enable the Executive
Secretary to determine if those sites designated as "IJndetermined" in the report and located
within 100 feet of present or known future construction areas are of such significance to warrant
their redesignation as "contributing." In all cases, such testing shall be completed before any
aspect of the undertaking affects a site.
Archeological contractors shall be approved in writing by the Utah SHPO. The Utah SHPO will
approve an archeological contractor who meets the minimum standards of the State of Utah as
the principal investi gator.
The licensee is hereby authorized to possess byproduct material in the form of uranium waste
tailings and other uranium byproduct waste generated by the licensee's milling operations
authorized by this license. Mill tailings shall not be transferred from the site without specific
prior approval of the Executive Secretary in the form of a license amendment. The licensee
shall maintain a permanent record of all transfers made under the provisions of this condition.
The licensee is hereby exempted from the requirements of R313-15-902(5) for areas within the
mill, provided that all entrances to the mill are conspicuously posted in accordance with R313-
15-902(5) and with the words, "Any area within this mill may contain radioactive material".
Release of equipment orpackages from the restricted area shall be in accordance with the NRC
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted
Use orTermination of Licenses forByproduct, Source, orSpecial NuclearMaterial," datedMay
1987, or suitable alternative procedures approved by the Executive Secretary prior to any such
release.
9.10
DRC-03
Page 6 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
STJPPLEMENTARY SHEET
License #W
Amendment 2
9.11 The final reclamation shall be in accordance with the May 1999, Reclamation Plan Revision
2.0, Attachment A, submitted to the NRC on June 22, 1999, andRevision 3.0 submitted to the
NRC on July 17,2000.
SECTION 10: OPERATIONAL CONTROLS, LIMITS, AND RESTRICTIONS
10.1 A.
B.
The mill production rate shall not exceed 4380 tons of yellowcake per year.
The licensee may not dispose of any material on site that is not "byproduct material," as
that term is defined in 42 U.S.C. Section zUa@)Q) (Atomic Energy Act of 1953,
Section 1l(e)(2)).
The licensee may not receive or process any alternate feed material without first
applying for and obtaining approval of a license amendment. For any such proposal, the
licensee shall demonstrate that it will comply with Conditiern 10.1(B). Any such
demonstration shall include :
Demonstration of compliance with the NRC Regulatory Summary 2000-23
Recent Changes to Uranium Recovery Policy, November 30,2000; and
Demonstration of compliance with the November 22, 1999 Protocol for
Determining Whether Alternate Feed Materials are Listed Hazardous Wastes, as
approved by the Utah Division of Solid and Hazardous Waste on December 7,
1999.
D. Maximum quantities of feed material stored on the mill site, including alternate feed
materials or other ores, shall not exceed the total material storage quantity found in the
currently approved mill surety pursuant to License Condition 9.5, without prior approval
of the Executive Secretary.
E. The licensee may not receive any alternate feed materials or other ores if those materials
would cause the facility to exceed the tailings cell disposal capacity established by the
currently approved reclamation plan and/or the annual surety report required by License
Conditions 9.11, and 9.5, respectively, without prior approval of the Executive
Secretary.
[Applicable UDRC Amendment: 2]
C.
1)
2)
DRC-03
PageT of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SIJPPLEMENTARY SHEET
License #V_1900479
Amendment 2
10.2 All liquid effluents from mill process buildings, with the exception of sanitary wastes, shall be
returned to the mill circuit or discharged to the tailings impoundment.
10.3 Freeboard limits for Cells l-I, 3, and 4A, shall be set periodically in accordance with the
procedures set out in Section 3.0 to Appendix E of the previously approved NRC license
application, including the October 13, 1999 revisions made to the January 10, 1990 Drainage
Report. The freeboard limit for Cell 3 shall be recalculated annually in accordance with the
procedures set in the October 13, 1999 revision to the Drainage Report.
[Applicable NRC Amendment: 16]
I0.4 Disposal of material and equipment generated at the mill site shall be conducted as described in
the licensee's submittals to the NRC dated December 12, 1994 and May 23, 1995, with the
following addition:
A. The maximum lift thickness for materials placed over tailings shall be less than 4-feet
thick. Subsequent lifts shall be less than2-feet thick. Each lift shall be compacted by
tracking of heavy equipment, such as a Cat D-6, at least 4 times prior to placement of
subsequent lifts.
10.5 In accordance with the licensee's submittal to the NRC dated N[.ay 20, 1993, the licensee is
hereby authorized to dispose of byproduct material generated at licensed in-situ leach facilities,
subject to the following conditions:
Disposal of waste is limited to 5000 cubic yards from a single source.
All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the
disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified
to be full prior to disposal. Barrels not completely full shall be filled with tailings or
soil.
All waste shall be buried in Cell No. 3 unless priorwritten approval is obtainedfromthe
Executive Secretary for alternate burial locations.
All disposal activities shall be documented. The documentation shall include
descriptions of the waste and the disposal locations, as well as all actions required by
this condition. An annual summary of the amounts of waste disposed of from off-site
generators shall be sent to the Executive Secretary.
A.
B.
C.
D.
DRC-03
Page 8 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #W.1900479
Amendment 2
10.6 The licensee is authorized to receive and process source materials from the Allied Signal
Corporation's Metropolis, Illinois, facility in accordance with the amendment request to the
NRC dated June 15, 1993.
10.7 The licensee is authorized to receive and process source material from Allied Signal, Inc. of
Metropolis, Illinois, in accordance with the amendment request to the NRC dated September 20,
1996, and amended by letters to the NRC dated October 30,1996 and November 11, 1996.
10.8 The licensee is authorized to receive and process source material, in accordance with the
amendment request to the NRC dated March 5,1997.
[Applicable NRC Amendments: 1]
10.9 The licensee is authorized to receive and process source material from Cabot Performance
Materials' facility near Boyertown, Pennsylvania, in accordance with the amendment request to
the NRC dated April 3, 1997, as amended by submittals to the NRC dated May 19, 1997 and
August 6,1997.
I Applicable NRC Amendments : 4 ]
10.10 The licensee is authorizedto receive and process source material from the Ashland 2 Formerly
Utilized Sites Remedial Action Program (FUSRAP) site, located near Tonawanda, New York,
in accordance with the amendment request to the NRC dated May 8, 1998, as amended by the
submittals to the NRC dated May 27, 1998, June 3, L998, and June 11, 1998.
[Applicable NRC Amendments: 6]
10.11 The licensee is authorizedto receive and process source material from Cameco Corporation's
Blind River and Port Hope facilities, located in Ontario, Canada, in accordance with the
amendment request to the NRC dated June 4, 1998, and by the submittals to the NRC dated
September 14,1998, September 16,1998, September 25,lgg9,October7, 1998, and October 8,
1998.
However, the licensee is not authorized to receive or process from these facilities, the crushed
carbon anodes identified in these submittals, either as a separate material or mixed in with
material already approved for receipt or processing.
10.12 The licensee is authorized to receive and process source material from the Ashland 1 and
Seaway Area D Formerly Utilized Sites Remedial Action Program (FIJSRAP) site, located near
Tonowanda, New York, in accordance with statements, representations, and commitments
contained in the amendment request to the NRC dated October 15, 1998, as amended by letters
to the NRC dated November 23,1998, November 24,1998, December 23,1998, January 11,
1999, January 27,1999, and February 1,1999.
DRC-03
Page 9 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
ST]PPLEMENTARY SHEET
License #lIIl90ElZ9
Amendment 2
[Applicable NRC Amendment: l0]
10.13 The licensee is authorizedto receive and process source material from the St. Louis Formerly
Utilized Sites Remedial Action Program (FUSRAP) site, in accordance with statements,
representations, and commitments contained in the amendment request to the NRC dated March
2, 1999 , and as amended and supplemented by submittals dated June 21 , 1999; June 29, 1999
(2); and July 8, 1999. Prior to the licensee receiving materials from the St. Louis FUSRAP site,
the licensee must make a determination that adequate tailings space is available forthe tailings
produced from the processing of this material. This determination shall be made based on a
SERP approved internal procedure.
[Applicable NRC Amendments: 13, l4]
10.14 The licensee is authorized to receive and process source material from the Linde Formerly
Utilized Sites Remedial Action Program (FUSRAP) site, in accordance with statements,
representations, and commitments contained in the NRC amendment request dated March 16,
2000, and as amended and supplemented by submittals dated April26,2000, May 15,2000,
June 16,2000, June 19,2000, andJune 23,2000.
Prior to the licensee receiving materials from the Linde FUSRAP site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on a SERP-approved
internal procedure. Design changes to the cells or the reclamation plan require the licensee to
submit an amendment request for Executive Secretary review and approval.
Prior to the licensee receiving materials from the Linde FUSRAP site, the licensee must require
that the generator of the material certify that the material does not contain listed hazardous
waste as defined under the Resource Conservation and Recovery Act (RCRA) per a Radioactive
Material Profile Record.
[Applicable NRC Amendment: 14]
10.15 The licensee is authorized to receive and process source material from the W.R. Grace site
located in Chattanooga, Tennessee, in accordance with statements, representations, and
commitments contained in the amendment request to the NRC dated April 12, 2000, as
amended and supplemented by submittals dated Api124,2000, April 26,2000, May 5,2000,
November 16,2000, and December 18, 2000.
Prior to the licensee receiving materials from the W.R. Grace site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on the SERP-approved
standard operating procedure for determination of tailings capacity. Design changes to the cells
DRC-03
Page 10 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
ST]PPLEMENTARY SHEET
License #lII1900,[9
Amendment 2
or the reclamation plan require the licensee to submit an amendment request for Executive
Secretary review and approval.
Prior to the licensee receiving materials from the W.R. Grace site, the licensee must require that
the generator of the material certify that the material does not contain listed hazardous waste as
defined under the Resource Conservation and Recovery Act (RCRA) per a Radioactive Material
Profile Record.
[Applicable NRC Amendment: 17]
10.16 The licensee is authorized to receive and process source material from the Heritage Minerals
Incorporated site, in accordance with statements, representations, and commitments contained in
the amendment request to the NRC dated July 5, 2000, and as supplemented by submittals dated
November 16,2000, and December 18, 2000.
Prior to the licensee receiving materials from the Heritage Minerals Incorporated site, the
licensee must make a determination that adequate tailings space is available for the tailings
produced from the processing of this material. This determination shall be made based on the
SERP-approved standard operating procedure for determination of tailings capacity. Design
changes to the cells or the reclamation plan require the licensee to submit an amendment request
for Executive Secretary review and approval.
Prior to the licensee receiving materials from the Heritage Minerals Incorporated site, the
licensee must require that the generator of the material certify that the material does not contain
listed hazardous waste as defined under the Resource Conservation and Recovery Act (RCRA)
per a Radioactive Material Profile Record.
[Applicable NRC Amendment: 18]
10.17 The licensee is authori zedto receive and process source material from the Molycorp site located
in Mountain Pass, California, in accordance with statements, representations, andcommitments
contained in the amendment request to the NRC dated December 19,2000, and supplemental
information in letters dated January 29,2007, February 2,2007, March 20,2OOl, August 15,
2001, October 17,2001, and November 16, 200I.
Prior to the licensee receiving materials from the Molycorp site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on a SERP-approved
internal procedure. Design changes to the cells or the reclamation plan require the licensee to
submit an amendment request for Executive Secretary review and approval.
I Applicable NRC Amendment: 20 ]
DRC-03
Page 11 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #!l]1900479
Amendment 2
10.18 The licensee is authorizedto receive and process source material from the Maywood site located
in Maywood, New Jersey, in accordance with statements, representations, and commitments
contained in the amendment requests to the NRC dated June 15, 20}l,Jwe22,200l,August 3,
2001, and supplemented by letters dated November 19,200l,December 6,200l,December 10,
2001, March I1,2002, and July 1,2002.
Prior to the licensee receiving materials from the Maywood site, the licensee must make a
determination that adequate tailings space is available for the tailings produced from the
processing of this material. This determination shall be made based on a SERP-approved
internal procedure. If such determination requires the licensee to make design changes to the
cells or the reclamation plan, the licensee shall submit an amendment request for Executive
Secretary review and approval.
Prior to the licensee receiving materials from the Maywood site, the licensee must require that
the generator of the material certify that the material does not contain listed hazardous waste as
defined under the Resource Conservation and Recovery Act (RCRA) per a Radioactive Material
Profile Record.
[Applicable NRC Amendment: 22]
10.19 The licensee is authorizedto receive and process source material from Ponds 2 and 3 of the
FMR['s Muskogee Facility located in Muskogee, Okalahoma, in accordance with statements,
representations, and commitments contained in the amendment requests and submittals to the
Executive Secretary dated March 7 , 2005, Jlurlre 22, 2005, and April 28, 2006.
I Applicable UDRC Amendment : 2 ]
SECTION 11: MONITORING, RECORDING, AND BOOKKEEPING REQI.IIREMENTS
11.1 The results of sampling, analyses, surveys and monitoring, the results of calibration of
equipment, reports on audits and inspections, all meetings and training courses required by this
license and any subsequent reviews, investigations, andcorrective actions, shall be documented.
Unless otherwise specified in the State of Utah regulations all such documentation shall be
maintained for a period of at least five (5) years.
ll.2 The licensee shall implement the effluent and environmental monitoring program specified in
Section 5.5 of the renewal application, as amended by the submittal to the NRC dated June 8,
1995, and as revised with the following modifications or additions:
A. Stack sampling shall include a determination of flow rate.
DRC-03
Page 12 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
License #Ii'I1900,129
Amendment 2
B. Surface water samples shall also be analyzed semiannually for total and dissolved U-nat,
Ra-226, and Th-230, with the exception of the Westwater Creek, which shall be
sampled annually for water or sediments and analyzedas above. A sediment sample
shall not be taken in place of a water sample unless a water sample was not available.
C. Groundwater sampling shall be conducted in accordance with the requirements in
License Condition I 1.3.
D. The licensee shall utilize lower limits of detection in accordance with Section 5 of the
NRC Regulatory Guide 4.14, as amended, for analysis of effluent and environmental
samples.
E. The inspections performed semiannually of the critical orifice assembly committed to in
the submittal to the NRC dated March 15, 1986, shall be documented. The critical
orifice assembly shall be calibrated at least every 2 years against a positive displacement
Roots meter to obtain the required calibration curve.
[Applicable NRC Amendment: 5]
11.3 The licensee shall implement a groundwater detection monitoring program to ensure
compliance to 10 CFR Part40, Appendix A. The detection monitoring program shall be in
accordance with the report entitled, "Points of Compliance, White Mesa Uranium Mill,"
submitted by letter to the NRC dated October 5,1994, and the following:
A. The licensee shall sample monitoring wells WMMW-5, -11, -I2, -14, -15, and -17 , on
a quarterly basis. Samples shall be analyzed for chloride, potassium, nickel, and
uranium, and the results of such sampling shall be included with the environmental
monitoring reports submitted in accordance with l0 CFR 40.65.
In addition, the licensee shall implement a monitoring program of the leak detection systems for
the disposal cells as follows:
B. The licensee shall measure and record the "depth to fluid" in each of the tailings
disposal cell standpipes on a weekly basis. If sufficient fluid is present in the leak
detection system (LDS) of any cell, the licensee shall pump fluid from the LDS, to the
extent reasonably possible, and record the volume of fluid recovered. Any fluid pumped
from an LDS shall be returned to a disposal cell.
If fluid is pumped from an LDS, the licensee shall calculate the flow rate by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last pumped or
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
STJPPLEMBNTARY SHEET
DRC.O3
Page 13 of 14
License #]l!-472
Amendment 2
C.
increases in the LDS fluid levels were recorded, whichever is the more recent. The
licensee shall document the results of this calculation.
Upon the initial pumping of fluid from an LDS, the licensee shall collect a fluid sample
and analyze the fluid for pH and the parameters listed in paragraph A of this license
condition. The licensee shall determine whether the tDS fluid originated from the
disposal cell by ascertaining if the collected fluid contains elevated levels of the
constituents listed in paragraph A of this license condition or has a pH level less than
5.0. If either elevated constituent levels or a pH less than 5.0 is observed, the licensee
shall assume that the disposal cell is the origin of the fluid.
If the LDS fluid is determined not to have originated from the disposal cell, the licensee
shall continue with weekly measurements of "depth to fluid" in the LDS standpipes.
The licensee shall confirm, on an annual basis, that fluid from the disposal cell has not
entered the LDS by collecting (to the extent possible) and analyzing an LDS fluid
sample for the above stated parameters.
Upon indication that the LDS fluids originated from the disposal cell, the licensee shall
determine the flow rate through the liner by the calculation method in paragraph B of
this license condition. If the flow rate is equal to or greater than one gallon per minute,
the licensee shall:
I . Evaluate the cause of the liner distress and take appropriate and timely actions to
mitigate the leak and any consequent potential impacts;
2. Continue to measure and record LDS "depth to fluid" measurements weekly;
and
3. Notify the Executive Secretary by telephone within 48 hours, in accordance with
License Condition 9.2, and submit a written report within 30 days of notifying
the Executive Secretary by telephone, in accordance with License Condition 9.2.
The written report shall include a description of the mitigative action(s) taken
and a discussion of the mitigative action results.
If the calculated flow rate is less than one gallon perminute, the licensee shall continue
with weekly measurements of "depth to fluid" in the LDS standpipes.
E. All sampling, analysis, and evaluation of LDS fluids shall be documented and retained
onsite until license termination for Executive Secretary inspection.
[Applicable NRC Amendment: 8]
D.
DRC-03
Page 14 of 14
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SI.JPPLEMENTARY SHEET
License #lIIl_900,[29
Amendment 2
11.4 Annually, the licensee shall collect, during mill operations, a set of air samples covering eight
hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per
minute), in routinely or frequently occupied areas of the mill. These samples shall be analyzed
for gross alpha. In addition, with each change in mill feed material or at least annually, the
licensee shall analyze the mill feed or production product for U-nat, Th-23O,Ra-226, and Pb-
210 and use the analysis results to assess the fundamental constituent composition of air sample
particulates.
[Applicable NRC Amendment: 7 ]
1 I .5 Calibration of in-plant air and radiation monitoring equipment shall be performed as specified in
the license renewal application, under Section 3.0 of the "Radiation Protection Procedures
Manual," with the exception that in-plant air sampling equipment shall be calibrated at least
quarterly and air sampling equipment checks shall be documented.
11.6 The licensee shall perform an annual ALARA audit of the radiation safety program in
accordance with the NRC Regulatory Guide 8.31.
SECTION 12: REPORTING REQUIREMENTS
l2.L DELETED by NRC Amendment 13.
[Applicable NRC Amendment: l3]
L2.2 The licensee shall submit a detailed decommissioning plan to the Executive Secretary at least
twelve (12) months prior to planned final shutdown of mill operations that includes a detailed
Quality Assurance Plan. The plan will be in accordance with NRC Regulatory Guide 4.15,
"Quality Assurance forRadiological MonitoringPrograms" andNUREG-L575,"Multi-Agency
Radiation Survey and Site Investigation Manual (MARSSM)" or equivalent most current
guidance.
[Applicable NRC Amendment: 13]
[Applicable UDRC Amendment: I ]
[Applicable UDRC Amendment: 2]
UTAH RADIATION CONTROL BOARD
( n; .,
JON M. HI"JNTSMAN, JR.
Governor
GARY HERBERT
Lieutenanl Governor
State of Utah
Department of
Environmental QualitY
Dianne R. Nielson, Ph.D.
Executive Director
DIVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
January 6,2006
Ms. Sarah Fields
P.O. Box 143
Moab, Utah 84532
Dear Ms. Fields:
I have reviewed your comments received as an email on November 2,2005 and December 22,
2005. You are correct that the definition of "alternative feed material" in the Radiation Control
statue, UCAI9-3-105 is the same as in the Tax Code definition at UCA 59-24-102. As you
pointed out, the title of Section, UCA l9-3-105, is "Definitions-Legislative and gubernatorial
ipproval required for radioactive waste license-Applications for new, renewed or amended
license." The International Uranium (USA) Corporation mill is not a radioactive waste disposal
licensee, as that term is defined under that section. Alternative feed materials and conventional
uranium ore is processed through the IUC mill for uranium recovery, whereas a commercial
disposal operation receives and disposes of the waste. The definition of "alternative feed material"
in Utah Code Annotated, 19-3-105(1)(a) is therefore inapplicable to IUC in any way, as the first
Iine of subsection (1) makes clear.
TITAH RADIATION CONTROL BOARD
ck, Executive Secretary
Cc: Laura Lockhart, Attorney, Utah Assistant Attorney General
David Frydenlund, International Uranium (USA) Corporation (IUC)
168 North 1950 west'Po Box I44850'Salt Lake city, UT 841 14-4850'phone (801) 536'4250'fax [phone]
T.D.D. (801) 5164414 . www.deq.utah.gov
JONM.rr*rt*
Govemor
GARY HERBERT
Lieutcnant Govemor
jw)
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Direclor
DTVISION OFRADI,ATION
CONTROL
Dane L. Finerfrock
Director
May 16,2005
David C. Frydenlund
Vice President and General Counsel
International Uranium (USA) Corporation
Independen ce Plaza, Suite 950
I 050 Seventeenth Street
Denver, CO 80265
Subject: Request for Additional Information Regarding License Amendment Application -
Radioactive Materials License UT 1900479
Dear Mr. Frydenlund:
The Division of Radiation Control (DRC) has received the MarchT ,2005 application for a license
amendment to authorize receipt and processing of alternate feed materials by the lnternational
Uranium (USA) Corporation (IUC) at the White Mesa Uranium Mill facility. The proposed 32,000
tons of alternate feed materials are residues resulting from processing ores from 1960 to 1989 for the
extraction of tantalum and niobium at FMRI, a subsidiary of Fansteel Inc.
It is the understanding of the DRC that the licensee is proposing the alternate feed material consisting
of "dewarered sludge" be excluded from RCRA under the provision of Title 42 of the United States
Code (USC) Chapter 82, $ 6921, as amended. Upon evaluation of the documentation IUC has
provided, the DRC has no issue with the exclusion. However, the DRC requests additional
information on the following outstanding issues:
l. The FMRI waste profiles indicated that the waste stream included several contaminants that
have not been adequately assessed as to the cumulative effect they may pose to the integrity of
the pond liner, especially where the liner sections are joined. These contaminates include:
- 4 methyl2-pentanone [a.k.a. methyl isobutyl ketone ("MIBK")], Bis (2-ethylhexyl),
Di-n-butyl phthalate, cerium, hafnium, lanthanum, niobium, neodymium,
Praseodymium, Scandium, Sulfide, Tantalum, Tungsten, Yttrium, and fluoride.
Please evaluate the chemical compatibility of contaminants with the pond liner. seam integritv
and groundwater quality.
168 North 1950 West. PO Box 144850. Salt Lake City, UT 841 14-4850. phone [phone]. fax [phone]
T.D.D. (801 ) 536-441 4 . www.deq.unh. gov
Page2
2. The waste is described as arriving in "fabric bags". The request also describes the "dewatered
sludge,, as having an average moisture content of 3O?o. The previously submitted report titled,
,,Evaluation of p6tential foi Seepage of Constituents Present in Altemate Feed Materials into the
ore Storage pad", dated June 28, 2}O2,does not evaluate material with a mOiStUre COntent as
high as 30Vo beingstored on the ore pad. Please evaluate the fabric bags for possible leakaqe.
3. page l2of the license amendment request states that you may consider recovering tantalum or
oth--er metals in addition to the uranium product in the alternate feed. ln the NRC memorandum
,.Redistribution of NRC Regulatory Issue Summary 2000-23 Recent Changes to Uranium
Recovery policy: dated April 19, 2001", the NRC includes criteria for determine whether or not
a non-natural ore can be process as an alternate feed. Criteria 3 states:
..... the ore must be processed primarily for its source-material content. If the only product
produced in the proCessing of the alternate feed is uranium product, this determination is
iatisfied. U in addition to uranium to uranium product, another material is also produced in
the processing of the ore, the licensee must provide documentation showing that the
uranium product is the primary produced."
Should the Licensee choose to recover uranium only, no documentation is required. Should the
Licensee choose to recover any material in addition to uranium, the Licensee must notify the
DRC and provide documentation that the uranium product will be the primary product produced.
4. The financial surety for IUSA requires that the current cost estimate be evaluated in regards to
disposal process with each alternate feed and associated costs be itemized. The March 7,2005
,"ptrt did not address any surety costs associated with FMRI material, in the unlikely event that
niSe close prior to processing the material. Please provide a surety increase estimate.
If you have any questions, please contact Christine Hiaring at [phone]'
Hul
LlWfuranium Mills Section Manager
JIVCMH:ch
From:
To:
Date:
Subiect:
Loren:
"Harold R. Roberts" <[e-mail]>
"Loren Morton" <LMORTON @ utah.gov>
6/6/06 4:47:51PM
RE: Proposed License Language - Condition 10.1
I think we are OK with the language with the attached modifications. I
think our additions cover what we discussed on the phone call. Call Dave
tomorrow if you have any questions.
Regards,
Harold
----Original Message-----
From: Loren Morton [mailto:LMORTON @ utah.gov]
Sent: Tuesday, June 06,2006 3:19 PM
To: David Frydenlund
Cc: Harold Roberts; Dane Finerfrock; Dean Henderson; Dave Rupp
Subject: IUC: Proposed License Language - Condition 10.1
Dave,
Here's what lcame up with for Condition 10.1 in redline and strikeout
format. Please review and comment by tommorrow morning.
Thanks,
Loren
CC: "Ron Hochstein" <[e-mail]>, "David Frydenlund"
<davef @ intluranium.com>
I
10.1 A.
year.
C.
[Applicable UDRC Amendment: 2]
B.
The mill production rate shall not exceed 4380 tons of yellowcake per
The licensee may not dispose of any material on site that is not "byproduct
material," as that term is defined in 42 U.S.C. Section 20la@)Q) (Atomic
Energy Act of 1953, Section 11(e)(2)).
The licensee may not receive or process any alternate feed material
without first applying for and obtaining approval of a license amendment.
For any such proposal, the licensee shall demonstrate that it will comply
with Condition 10.1(B). Any such demonstration shall include:
1) Demonstration of compliance with the NRC Regulatory Summary
2000-23 Recent Changes to Uranium Recovery Policy, November
30,2000; and
2) Demonstration of compliance with the November 22, 1999
Protocol for Determining Whether Alternate Feed Materials are
Listed Hazardous Wastes, as approved by the Utah Division of
Solid and Hazardous Waste on December 7. 1999.
Maximum quantities of feed material stored on the mill site, including
altemate feed materials or other ores, shall not exceed the total material
storage quantity found in the currently approved mill surety pursuant to
License Condition 9.5, without prior approval of the Executive Secretary
The licensee may not receive any alternate feed materials or other ores if
those materials would cause the facility to exceed the disposal capacity in
the currently approved reclamation plan authorized under License
Condition 9.11, and the currently approved mill surety pursuant to License
Condition 9.5, without prior approval of the Executive Secretary.
D.
E.
License Lanouaoe - Condition 10.1
From:
To:
Date:
Subject:
Dave,
Loren Morton
David Frydenlund
6/6/06 3:19:02 PM
IUC: Proposed License Language - Condition 10.1
Here's what I came up with lor Condition 10.1 in redline and strikeout format. Please review and comment
by tommorrow morning.
Thanks,
Loren
Dane Finerfrock; Dave Rupp; Dean Henderson; Harold Roberts
Loren llorton - 10.1 6-6-06.doc
10.1 A.
year.
B.The licensee may not dispose of any material on site that is not "byproduct
material," as that term is defined in 42 U.S.C. Section 2Ua@)Q) (Atomic
Energy Act of 1953, Section 11(e)(2)).
The licensee may not receive or process any alternate feed material
without first applying for and obtaining approval of a license amendment.
For any such proposal, the licensee shall demonstrate that it will comply
with Condition 10.1(B). Any such demonstration shall include:
1) Demonstration of compliance with the NRC Regulatory Summary
2000-23 Recent Changes to Uranium Recovery Policy, November
30,2000; and
Demonstration of compliance with the November 22, 1999
Protocol for Determining Whether Alternate Feed Materials are
Listed Hazardous Wastes, as approved by the Utah Division of
Solid and Hazardous Waste on December 7, 1999.
(1) D. Maximum quantities of feed material stored on the mill
site, including alternate feed materials or other ores, shall not
exceed the total material storage quantity found in the currently
approved mill surety pursuant to License Condition 9.5.
E. The licensee may not receive any alternate feed materials or other ores if
those materials would cause the facility to exceed the disposal capacity in
the currently approved reclamation plan authorized under License
Condition 9.11.
[Applicable UDRC Amendment: 2]
The mill production rate not exceed 4380 tons of yellowcake per
C.
se to Your
From:
To:
Date:
Subiect:
Dave,
Loren Morton
"davef @ intluranium.com".m ime. M N ET
91271200511:19:17 AM
Re: Additional Monitoring Paramelers -- Response to Your September 21, 2005 email
Thanks for the new information, I willtask Dean to begin review of it immediately. ln the meantime,
please send along official signed copies for the DRC files.
We will be in touch soon.
Thanks,
Loren
>>> "David Frydenlund" <davef @ intluranium.com> 9127105 1 1 :02 AM >>>
Loren,
Further to our telephone conference of September 23, attached is a
memorandum that addresses your September 2l email regarding the possible
addition of MIBK, antimony, tin and aluminum as monitoring parameters to the
White Mesa Mill's Groundwater Discharge Permit.
Also attached is a supporting memorandum from Tetra Tech EM lnc.
Based on the analysis set out in the attached memoranda, we submit that it
is not necessary to add any of these four parameters to the Mill's GWDP, and
that the GWDP need not go to public comment.
Please give me a call if you have any questions or require any further
information.
Thanks,
David C. Frydenlund
Vice President and General Counsel
lnternational Uranium (USA) Corporation
1050 17th Street, Suite 950
Denver, CO 80265
Tel: [phone]
Fax: [phone]
www.intluranium.com
CC:Christine Hiaring; Dane Finerfrock; Dean Henderson; Johnathan Cook
oa
Page I of 1
Johnathan Cook
From: Dean Henderson
To: Frydenlund, David
Date: 101L412005 3:01 PM
CC: Cook, Johnathan; Finefroc( Dane; Hiaring, Christine; Hultquist John; Morton, Loren
Dave,
Here is the Safety Evaluation Report (SER). There are 3 attachments to this email: SER; SER's Section 7.0
Table 1; and SER's Attachment 1, changes that will be made to Table 2 of the Permit.
D.C. is ready for public comment. Please review and have comments to us by this Tuesday (October 18,
2005), Both the Salt Lake news papers (Salt Lake Tribune & Deseret News) and the Blanding News paper, The
Blue Mountain Panorama, need to have the Public Notice (PN) by noon on Friday(s) in order to publish the
following Wednesday(s). The DRC would like to give the News Papers the PN by noon this next Friday (October
21, 2005) so it can be published and the public comment period can start the following Wednesday (October 25,
2005). Call me with questions or concerns (801 536-0046)
Thanks
Dean
file://C:\Documents and SettingsUpcook\Local Settings\Temp\GW)0000l.IIIM tu3t2005
From:
To:
Date:
Subject:
Dane,
Loren Morton
Dane Finerfrock
1011812005 5:20:17 PM
IUC: License Related Actions Since Agreement State Status
Here's a summary of our activities at IUC since 8/16/04.
License Amendments
We have been involved with 3 amendments to the IUC license since Augusl,2004. As follows:
1. Fernald Silo 3 Material (Aborted License Amendment) - chronology is as follows:
111211O4 - IUC holds meeting with DRC to confirm their intentions to compete for the Fernald Silo 3
contract.
1211104 - IUC email (Dave Frydenlund to Dane Finerf rock) outlines 2 proposals lor the Fernald Silo 3
material: 1) lnitial interim storage, and 2) Long-term processing.
1216104 - IUC applies for license amendment for interim storage of Fernald Silo 3 alternate feed, includes
the 2 part approach.
148rc4 - IUC letter withdraws ils 1216104 request for interim storage of Fernald Silo 3 material.
1?16rc4 - DRC letter acknowledges lhe 12/8104lUC withdrawalfor interim storage, documents IUC's
intent to move forward with processing, and notifies IUC of need for 30-day public comment period.
214105 - Fluor Fernald announces award of contract to Envirocare.
218105 - DRC memo acknowledges contract award to Envirocare, and cessation of work by DRC staff (no
written request for withdrawal in file from IUC).
2. FansteelAlternate Feed Proposa! (License Amendment Currently in Process)
3/8/05 - IUC applies for license amendment to process Fansteel alternate feed.
10114105 - DRC sends draft SER to IUC for review for License amendment and GW Permit modification
(so far no comment from IUC)
3. Update of Suretv (8/10/05 License Amendment #1)
3/3/05 - IUC submits annual surety evaluation report
5124105 - IUC submits supplemental information
7125105 - IUC submits supplemental information
8/10/05 - DRC issues License Amendment # 1 to reflect new surety amount.
Ground Water Permit
; Johnathan Cook
11130104 - DRC public notice published, public comment period begins
lnlO5 - Public comment period ends
3/8/05 - DRC resolves public comments and executes final Permit.
DRC lnspections
9124104 - DRC staff visit site for reconnaissance / meet IUC staff (Dean H., John C., Loren M.)
4n-8105 - DRC staff observe installation of new monitoring wells near Cells 1 and 2 (Dean H.)
6123105 - DRC inspection (Dean H. observed part of 2nd Qtr GW sampling event)
<<< John Cook has been down there twice since 9/04 to do engineering inspections, last time was mid-
Sept, 2005 (John C. and John H.). I think there was another John C. visit in the spring. Talk to him for
dates. >>>
Hope this helps. Feel free to call me at home (969-8647) or on my cell phone [phone]) if you have any
questions.
Later,
Loren
CC:Christine Hiaring; Dean Henderson; John Hultquist; Johnathan Cook
PREV EMAIL: IUC's FMRI license
From:
To:
Date:
Subject:
Christine Hiaring
[e-mail]
Thu, Jun 30,2005 7:39 AM
Re: IGNORE PREVIOUS EMAIL: IUC's FMRI license amendment
lf they satisfy that issue, I am sure I will not have a problem.
>>> Johnathan Cook 06128105 3:33 PM >>>
Chris,
The letter came in today. John H. has a copy and I have a copy on my desk. Generally it looks good
except for two items on my end. I'll probably send them one more request for clarification on the surety
(substantiate their claim with numbers) and ask what the saturation limit is on the FMRI material so that I
can compare it to the 20% - 30% range that it will be arriving in. Otheruvise, all my stuff looks fine.
I'll be back in the office on either the 7th or 8th. I haven't decided if I coming in both days.
Thanks,
John C.
>>> Johnathan Cook 612712005 8:33:15 AM >>>
Chris,
Did IUC ever get back to us on the FMRI alternate feed license amendment request? I realized today that
it has been about a month since our RFI to them.
Thanks,
John Cook
Ia
Christine Hiaring
From: Dean Henderson
To: Frydenlund, David
Date: 14 October, 2005 03:01 PM
CC: Cook, Johnathan; Fineffroc( Dane; Hiaring, Christine; Hultquist, John; Morton, Loren
Dave,
Here is the Safety Evaluation Repoft (SER). There are 3 attachments to this email: SER; SER's Section 7.0 Table 1; and SER s
Attachment 1, changes that will be made to Table 2 of the Permit.
D.C. is ready for public comment. Please review and have comments to us by this Tuesday (October 18, 2005). Both the Salt
Lake news papers (Salt Lake Tribune & Deseret News) and the Blanding News paper, The Blue Mountain Panorama, need to
have the Public Notice (PN) by noon on Friday(s) in order to publish the following Wednesday(s). The DRC would like to give
the News Papers the PN by noon this next Friday (October 21,2005) so it can be published and the public comment period
can staft the following Wednesday (October 26,2005). Call me with questions or concerns (801 536-0046)
Thanks
Dean
Christine - Table 1
{r) Components
lncluded as Ground
Water ilonltorlng
Compllanco
Paramelers ln ll.JSA
Ground Welsr
:omoonenl
(r) Componenla
lncludad a8 Ground
Watsr Monitodng
Compllance
Paramoters ln IUSA
Ground Water
nlc^h.rd. Parilh Toxlcltv
Estlmated
MaBs ln Mlll
Tallings aftor
Uranlum
Malerlal
Procssslng lncreasg ln Concentratlon
EPA
Approved
Analytlcal
Kd
ln Mlll
Talllngo
al6n*l
,cetone Yas 340 339.6 No ss 7OO ttd/!.Yes 13)o1) o-oo1lothyl lsobutyl ketono
UIRKI No 2t 23.8 No fea ?lrn n thlt Yoa {1il flD 0.123
,l-n-butyl phthalato
2 1q o (14)n 1ANote: shaded components selected for groundwater monitoring compliance parameters.
components in bold are not included as groundwater monitoring compliance parameters in IUSAs Groundwaler Discharge permit.
Nl = No information in Hazarous substances Data Bank (HSDB), http://sis.nrm.nih.gov.
NQ = Not qualified
NM = No Method lound
1. lnternational uranium corporalion Ground water Discharge permit, permit No. uGw37ooo42 lnventory rrom the Request to Amend Radioactive Material Lic€nse white Mesa Mill And Environmental Fleport, Attachment 5, Table 2, March 7,2005.3. Utah Ground Water Quatity Standards (GWQS), UAC Rg17-6, Tabte 2.4 . EPA drinking water liletime health advisories
5. EPA Drinking water MCL
6. Liretime health advisories EpA Region I Stalf7. EPA Region 3 Risk Based Concentrations Tap Water
8. State of Minnesota Department of Health groundwater health risk limits.9. State ol California Drinking Water Standard.
10. National Environmental Methods lndex (web1 .er.usgs.gov/nemi/reg_search.jsp).
1 1. Test Methods lor Evatuating Solid Waste, EpA SW-846.
12. DOE3004
1 3. standard Methods lor the Examination of water and wastewater, 2oth Edition, 199814' lnternational uranium corporation Groundwater Discharge Permit, Statement of Basis, Attachment T lor inorganic Kds and Attachment g lor organic Kds.15. colsman, september g, 2005, Table I : Literature Kd Values for FMRI-Related Metals16. U.s' EPA, 2005 Superfund Chcemical Data Matrix. http://www.epa.gov/sperfund/sites/nnpt/hrsres/scdm.htm
17. MIBK = Koc (123) x loc (0.001) = 0.12918 ohio Environmental Protection Agency, 2005, vadose zone Modeling in RCBA closure Department of Hazardous waste Management, January 2005.19. Anions generally exhibit very low Kd values. lnternational uranium corporation Ground water Discharge permit, permit No. ucw37ooo4, statement of Basis.
Christine Hiarlng - Tqbte 2,doc
Part I
Permit No. UGW370004
Table2. Groundwater iance Limits
Metals (us/L)
Volatile Or
Groundwater iance Limits
Volatile Or
Christine Hiaring - Tabte 2,doc
Part I
Permit No. UGW370004
Compliance Limits (CL)
Christine Table 5
Part I
PermitNo. UGW370004
Foomts:
l) UhhGrcundWaterQualitySrmdards(GWQS)6defiocdinUACR3lT-6,Tabte2, AdhffcWeSalsoprorrdedhercin,6Doted,ild{allowedbyUACR3l?-6_2.2.2) Ad h@ GWQS fG umo[ia (s N), mol]t detrum, 2"Buh@ (MED, cilmmethee, ild traphthalere bsed oo EPA dri*ing Mu lifetime health advisois.3) Ad hQ CWQS f6 trickel, @ium, od dichlNmelhme (methylene chl6ide, CAS No. 75-09-2) bed otr final EPA &inkitrg wat6 muimum con@trffii@ timib (MCL).
5) Ad hm GWQS fG cobalr md irco bded oo EPA Regton 3 Risk Bas€d Corceotralion lioib fq tap waler.6) Mean conceotlation Md studard deviatim (s.D.) to bc dctomined on a rell-by-wcll md individual pumeE b6is at some futurc dab.?) CrcuodwatercmplimceLimi6(GWCL)based@ooeofrhefollowitrgf@uls: f6ClNtCudwatt,GWCL=0.25*GWQS,ffCtassItGpundw,GWCL=0.5.GweS. AfersubmiBatmdapprvalotthe
two SDdrd deviatios (X+2o) ftr crch mll ud contminmt.8) Fum modbring w[s to be iNalled in e@rdacc wlth Pd LH. I of this petmir.
9) TBD = to b€ determircd affer Exsutlvc S@etary approval of lhe Betgrcurd C@trdffi Quality Re!trr ftr enstitg md new monltoridg wlls rquired by pa( LH.3 ud LH.4, rqlpoctirlyl0) Ad hoc CWQS for iin bosed otr Millwas DcDarltrrrt of HBlth, Greurtvater Health Risk Umit, d000 ug/L
- Table 2.doc
Part IV
PermitNo. UGW370004
I
Christine Hiaring - IUC's FMRI license amendment
From: Johnathan Cook
To: Hiaring, Christine
Date: 27 June,2005 08:33 AM
Subject: IUC's FMRI license amendment
Chris,
Did IUC ever get back to us on the FMRI alternate feed license amendment request? I realized today that it has been about amonth since our RFI to them.
Thanks,
John Cook
/
Christine Hiaring - IGNORE PREVIOUS EMAIL: IUC's FMRI license amendment
From:
To:
Date:
Subject:
Johnathan Cook
Hiaring, Christine
28 June, 2005 03:33 PM
IGNORE PREVIOUS EMAIL: IUC's FMN license amendment
Chris,
The letter came in today. John H. has a copy and I have a copy on my desk. Generally it looks good except for two items on
my end. I'll probably send them one more request for clarification on the surety (substantiate their claim with numbers) and
ask what the saturation limit is on the FMRI material so that I can compare it to the 20olo - 3Oo/o range that it will be arrivingin. Otherwise, all my stuff looks fine.
I'll be back in the office on either the 7th or 8th. I haven't decided if I coming in both days.
Thanks,
John C.
>>> Johnathan Cook 612712005 8:33:15 AM >>>
Chris,
Did IUC ever get back to us on the FMRI alternate feed license amendment request? I realized today that it has been about a
month since our RFI to them.
Thanks,
John Cook
- Re: Please review
From: John HultquistTo: Christine HiaringDate: 12 May,2005 01:55:21 PMSubject: Re: Please review
I have reviewed the letter, here are my redline/strickout revision. lf your ok with the changes go to print
and l'll sign it. Thanks.
>>> Ghristine Hiaring 5112/200511:50 AM >>>
John, I made the requested changes and some other changes to the letter. Please review
.doc
JONM. HUNTSMAN,JR.
Govemor
GARY HERBERT
Ueutemnt Govemor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executiye Dircctor
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
Subject:
Nflf'ay 12,2005
David C. Frydenlund
Vice President and General Counsel
International Uranium (USA) Corporation
lndependenc e Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Request for Additional Information Regarding License Amendment Application -Radioactive Materials License UT 1900479
Dear Mr. Frydenlund:
The Division of Radiation Control (DRC) has received the March 7 ,2005 application for a license
amendment to authorize receipt and processing of alternate feed materials by the International
Uranium (USA) Corporation (IUC) at the White Mesa Uranium Mill facility. The proposed 32,000
tons of alternate feed materials are residues resulting from processing ores from 1960 to 1989 for the
extraction of tantalum and niobium at FMRI, a subsidiary of Fansteel Inc.
It is the understanding of the DRC that the licensee is proposing th*t the alternate feed material
consisting of "dewatered sludge" sh€uld be excluded from RCRA under the provision of Title 42 of
the United States Code (UsC) Chapter 82, S 6921, as amended. Upon evaluation of the
documentation IUC has provided, the DRC has no issue with the exclusion. However, the DRC
requests additional information on the following outstanding issues:
1. Documentation in the application deennrenta+ien presented a comparison between the FMRI
waste stream and current effluent at the White Mesa Mill. The licensee needs to correct the data
tables erroneously presented as samoles of the tailing effluent.
2. The FMRI waste profiles indicated that the waste stream included several contaminants that
have not been adequately assessed as to the cumulative effect they may pose to the integrity of
the pond liner, especially where the liner sections are joined. These contaminates include:- 4 methyl2-pentanone [a.k.a. methyl isobutyl ketone ("MIBK")], acetone, cadmium,
manganese, potassium, sodium, titanium hafnium barium, chromium, nickel,
168 North 1950 West . PO Box 144850. Salt t-ake City, UT 841 14-4850 . phone [phone]. fax [phone]
T.D.D. (801 ) 536-441 4. www.deq.utah. I ov
Page2
antimony, selenium, sulfate, fluoride, Bis (2-ethylhexyl), Di-n-butyl phthalate
Please evaluate the chemical compatibility of contaminants with the pond liner. and seam
i nte grity and groundwater quality.
3. The waste is described as arriving in "fabric bags". The deeumen+-request also describes the
"dewatered sludge" as having an average moisture content of 3OVo. The previously submitted
report titled, "Evaluation of Potential for Seepage of Constituents Present in Alternate Feed
Materials into the Ore Storage Pad", dated June 28, 2002, does not evaluate material with a
moisture content as high as 3OVo being stored on the ore pad. Please evaluate the fabric bags for
possible leakage.
4. Page 12 of the license amendment request states that you rnay consider recovering tantalum or
other metals in addition to the uranium product in the altemate feed. In the NRC memorandum
"Redistribution of NRC Regulatory Issue Summary 2000-23 Recent Changes to Uranium
Recovery Policy: dated April 19 , 2001" , the NRC includes criteria for determine whether or not
a non-natural ore can be process as an alternate feed. criteria 3 states:
"... the ore must be processed primarily for its source-material content. If the only product
produced in the processing of the alternate feed is uranium product, this determination is
satisfied. ff in addition to uranium to uranium product, another material is also produced in
the processing of the ore, the licensee must provide documentation showing that the
uranium product is the primary produced."
Please provide documentation that the uranium product will be the primary product produced.
5' The financial surety for IUSA requires that the current cost estimate be evaluated in regards to
disposal process with each altemate feed and associated costs be itemized. The March 7,2005
report did not address any surety costs associated with FMRI material, in the unlikely event that
IUSA close prior to processing the material. Please provide a surety increase estimate.
If you have any questions, please contact Christine Hairing at [phone].
Sincerely,
John Hultquist
LlWUranium Mills Section Manager
JIVCMH:ch
Christine Hiaring - Cover letter for Fansteel
From:
To:
Date:
Subject:
CC:
Christine Hiaring
Cook, Johnathan
10 May, 2005 02:11 PM
Cover letter for Fansteel
Hultquist John
Please review
JON M. HUNTSMAN, JR.
Govemor
GARY HERBERT
Lieutemnt Govemor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executiye Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Directur
May 10,2005
David C. Frydenlund
Vice President and General Counsel
International Uranium (USA) Corporation
Independenc e Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Subject: Request for Additional Information Regarding License Amendment Application -Radioactive Materials License UT 1900479
Dear Mr. Frydenlund:
The Division of Radiation Control (DRC) has received the March 7 ,2005 application for a license
amendment to authorize receipt and processing of alternate feed materials by the International
Uranium (USA) Corporation (IUC) at the White Mesa Uranium Mill facility. The proposed
32,000 tons of alternate feed materials are residues resulting from processing ores from 1960 to
1989 for the extraction of tantalum and niobium at FMRI, a subsidiary of Fansteel Inc.
It is the understanding of the DRC that the licensee is proposing that the alternate feed material
consisting of "dewatered sludge" should be excluded from RCRA under the provision of Title 42
of the United States Code (USC) Chapter 82, $ 6921, as amended. Upon evaluation of the
documentation IUC has provided, the DRC has no issue with the exclusion. However, the DRC
requests additional information on the following outstanding issues:
1' The application documentation presented a comparison between the FMRI waste stream and
cuffent effluent at the White Mesa Mill. The licensee needs to correct the data tables
erroneouslv presented as samples of the tailing effluent.
2. The FMRI waste profiles indicated that the waste stream has a low pH and also included
several contaminant constituents that have not been adequately assessed as to the cumulative
effect they may pose to the integrity of the pond liner. The Licensee needs to submit an
evaluation of the chansed pH and contaminants to the liner integritv.
168 North 1950 West'PO Box 144850 . Salt take City, UT 841 14-4850. phone [phone]. fax [phone]
T.D.D. [phone] . www.deq.utah.gov
Page2
3. The waste is described as arriving in "fabric bags". The document also describes the
"dewatered sludge" as having an average moisture content of 3OVo. If the fabric bags do not
have a waterproof liners, it seems likely that moisture could leach out the bag and orto th"
ore pad. The previously submitted report titled, "Evaluation of Potential for Seepage of
Constituents Present in Alternate Feed Materials into the Ore Storage Pad", dated June 2g,
2002, and does not evaluate material with a moisture content as high as 30Vo being stored on
the ore pad.
waterproof interior liner.
4.be theproduct produced. Page 12 of the license amendment request states that you rzay "o^id".recovering tantalum or other metals in addition to the uranium product in the alternate feed.
In the NRC memorandum "Redistribution of NRC Regulatory issue Summary 2000-23
Recent Changes to Uranium Recovery Policy: dated April lg,2ool,the NRC includes
criteria for determine whether or not or not a non-natural ore can be process as an alternate
feed. Criteria 3 states:
"... the ore must be processed primarily for its source-material content. If the onlyproduct produced in the processing of the alternate feed is uranium product, this
determination is satisfied. If in addition to uranium to uranium product, another
material is also produced in the processing of the ore, the licensee must provide
documentation showing that the uranium product is the primary produced.,,
The licensee should also be aware that another material is produced with any economic value,
the Licensee must notify the DRC of this changed condition.
5.r ne r.rcensee neetls to orovide a suretv increase estimate. The financial surety for IUSArequires that the current cost estimate be evaluated in regards to disposal process with each
alternate feed and associated costs be itemized. The March 7,200i report ald not address
any surety costs associated with FMRI material, in the unlikely event that IUSA close prior to
processing the material.
oo
Christine H - IUC: Phone
From:
To:
Date:
Subject:
ansteel Proposal and 1st Quarter, 2005
Loren Morton
Dane Finerfrock
10 May, 2005 11:06:27 AM
IUC: Phone CallToday - Fansteel Proposaland 1st Quarter, 2005 lnspection
Dane,
ljust got off the phone with Dave Frydenlund. We talked about a couple of things - as summarized below:
Fansteel Alternative Feed Proposal - I told Dave that John Cook had finished his review and was getting
some peer review on his comments. I also said that Chris was finalizing her review, but that it looked right
now that the radiation safety issues were clear. He asked if we had any groundwater staff evaluate it. I
mentioned that I had asked Chris to look at that. I told Dave that I thought we were a few days away lrom
getting back to him on this.
1st Quarter. 2005 lnspection - I told Dave that John had finished his memo regarding his findings, and
that Chris was about to finish hers, and that at that point John would prepare a transmittal/ summary letter
back to lUC. ltold Dave that we would have something back to him in writing in a few days.
Dave asked if we could make sure to have a formal close-out meeting at the end of our inspections, so as
to clue them in about our preliminary findings. I told Dave that we would do that. I suppose he wants our
staff to talk to him, Harold, or Ken Myoshi (mill manager). I didnt argue with him - in that our staff did talk
to Ron Berg before they left. But from now on, we can closeout with one of the management.
See me if you have questions or concerns about this phone call.
Later,
Loren
CC:Christine Hiaring; John Hultquist; Johnathan Cook
Christine Hiaring - Re: IUC: Phone Call Today - Fansteel Proposal and lst Quafter, 2005
Inspection
From:
To:
Date:
Subject:
CC:
Christine Hiaring
Morton, Loren
10 May, 2005 11:10 AM
Re: IUC: Phone Call Today - Fansteel Proposal and 1st Quafter, 2005 Inspection
Cook, Johnathan; Henderson, Dean; Hultquist, John
Dean reviewed the IUC effluent report and had some comments regarding some exceedances. Perhaps we need to bring
Deans review into the skirmish.
oo
From:
To:
Date:
Subject:
Dane,
Loren Morton
Dane Finedrock
18 October, 2005 05:20:17 PM
IUC: License Related Actions Since Agreement State Status
Here's a summary of our activities at IUC since 8/16/04.
License Amendments
We have been involved with 3 amendments to the IUC license since August,2OO4. As follows:
1. Fernald Silo 3 Material (Aborted License Amendment) - chronology is as follows:
11/21104 - IUC holds meeting with DRC to confirm their intentions to compete for the Fernald Silo 3contract.
1211lo4 - lUC email (Dave Frydenlund to Dane Finedrock) outlines 2 proposals for the Fernald Silo 3material: 1) lnitial interim storage, and 2) Long-term processing.
1.216n4 - IUC applies for license amendment for interim storage of Fernald Silo 3 alternate feed, includesthe 2 part approach.
1218/04 - IUC letter withdraws ils 1216104 request for interim storage of Fernald Silo 3 material.
12116/04 - DRC letter acknowledges lhe 12/8/04lUC withdrawalfor interim storage, documents lUC,sintent to move fonvard with processing, and notifies IUC of need for 30-day puuii comment period.
214/05 - Fluor Fernald announces award of contract to Envirocare.
2l8lo5 - DRC memo acknowledges contract award to Envirocare, and cessation of work by DRC staff (nowritten request for withdrawal in file from IUC).
2. FansteelAlternate Feed Proposal (License Amendment Currently in process)
318105 - IUC applies for license amendment to process Fansteel alternate feed.
1Ol14lO5 - DRC sends draft SER to IUC for review for License amendment and GW Permit modification(so lar no comment from IUC)
3. Update of Suretv (8/10/05 License Amendment #1)
3l3lo5 - IUC submits annual surety evaluation report
5/24105 - IUC submits supplemental information
7/25105 - IUC submits supplemental information
8/10/05 - DRc issues License Amendment # 1 to ref lect new surety amount.
Ground Water Permit
11130104 - DRc public notice published, public comment period begins
1nrcs - Public comment period ends
sl1los - DRc resolves public comments and executes final permit.
DRC lnspections
9l24lo4 - DRC staff visit site for reconnaissance / meet IUC staff (Dean H., John C., Loren M.)
4n-81A5 - DRC staff observe installation of new monitoring wells near Cells 1 and 2 (Dean H.)
6123105 - DRc inspection (Dean H. observed part of 2nd etr GW sampling event)
<<< John Cook has been down there twice since 9/04 to do engineering inspections, last time was mid-Sept, 2005 (John C. and John H.). I think there was another John C. viiit in tne spring. Talk to him fordates. >>>
Hope this helps. Feel free to call me at home (969-8647) or on my cell phone (A42-1zgO) if you have anyquestions.
Later,
Loren
CC:christine Hiaring; Dean Henderson; John Hultquist; Johnathan cook
oo
From:
To:
Date:
Subject:
Dave,
Loren Morton
"davef @ intlu ranium.com".mime.MNET
27 September, 2005 1 1 :1 9: 1 6 AM
Re: Additional Monitoring Parameters -- Response to Your september 21, 2005 email
Thanks for the new information, I will task Dean to begin review of it immediately. ln the meantime,
please send along official signed copies for the DRC files.
We will be in touch soon.
Thanks,
Loren
>>> "David Frydenlund" <davef @intluranium.com> gl27lOS 11:02 AM >>>
Loren,
Further to our telephone conference of September 20, attached is a
memorandum that addresses your september 2l email regarding the possible
addition of MIBK, antimony, tin and aluminum as monitoring parameters to the
White Mesa Mill's Groundwater Discharge Permit.
Also attached is a supporting memorandum from Tetra Tech EM lnc.
Based on the analysis set out in the attached memoranda, we submit that itis not necessary to add any of these four parameters lo the Mill's GWDp, and
that the GWDP need not go to public comment.
Please give me a call if you have any questions or require any further
information.
Thanks,
David C. Frydenlund
Vice President and General Counsel
lnternational Uranium (USA) Corporation
1050 17th Street, Suite 950
Denver, CO 80265
Tel: [phone]
Fax: [phone]
www.intluranium.com
CC:Christine Hiaring; Dane Finerfrock; Dean Henderson; Johnathan Cook
Evaluation Report for FMRI Materials
From: Loren MortonTo: Christine Hiaring; Johnathan CookDate: 24 October, 2005 11:36:59 AMSubject: Fwd: Safety Evaluation Report for FMRI Materials
John and Chris,
IUC has proposed some changes to the SER language for the Fansteel alternate feed material. Some ol
these changes effect sections you wrote. Please review the WORD document attached to Dave
Frydenlund's email and provide me feedback by Wednesday, Oct. 26. Are you OK with their suggested
changes?
Thanks,
Loren
Dean Henderson; John Hultquist
Christine Hiaring - Fwd: Safety Evaluation Report for FMRI Materials
From:
To:
Date:
Subject:
CC:
Loren Morton
Christine Hiaring; Johnathan Cook
24 October,2005 11:36 AM
Fwd: Safety Evaluation Report for FMRI Materials
Dean Henderson; John Hultquist
Loren,
Attached is your draft SER for the FMRI Materials, blacklined to indicate our suggested changes. ln addition to the blacklined
changes, we also propose that the following additional changes be made to the SER and Table 1 thereto:
Table 1 should be amended by adding three columns: one showing the current estimated concentration of each
parameter in the Mill's tailings; one showing the estimated concentration of each parameter in the Mill's tailings afterprocessing the FMRI Materials; and one showing the percentage increase or decrease in the concentration as aresult of the processing. These columns can be taken from Jo Ann Tischler's Table 2to Attachment 5 to IUSA's
March 8, 2005 license amendment application. We believe it is important to add these columns so that the reader
can obtain a better understanding of the impact of the FMRI materials on the Mill's tailings. By just showing the
changes in mass, the reader is not able to gain this understanding. For example, the miss of any constituent will
always increase because adding the mass of a constituent in the FMRI materials to the existing mass in the Mill' stailings will by definition always increase the total mass in the Mill's tailings, even if the constitulnt is at a lowerconcentration in the FMRI materials than it currently is in the Mill's tailings. Rather than just showing an increase inthe mass of all constituents, as currently set out in Table 1, by adding th-ese three columns, the readLr can see that! many cases the concentrations will actually decrease or stay relatively constant. ln addition, the references inTable 1 should be references to lnternational Uranium (USA) Corporation and not references to lnternational
Uranium Corporation. Also, NQ should refer to "Not Quantified", rather than "Not Qualified".
IUSA proposes an alternate health-based level of 22,OOO ug/L lor tin. This level is consistent with the risk-basedconcentrations (RBCs) and preliminary remedial goals (PRGs) for tap water that have been developed by EpA
[egions 3, 6, and 9, and that have been used for risk screening by EPA Region 8 and states within Regi-on 8.
These RBCs and PRGs are published at http://www.epa.gov/reg3hwmd/risk/human/rbc/rbc0405.pdf, -
h!!p;//ww.14,,epa.4tay_lregiaq0g/yvasle../..9lun.d/p-rgl_tlles/-Q4prgtab-!e,pdt, h!Ip_/1,ww-w-.e.pa.g_0y.1_e_a p--d.
n/screen.htm. These RBCs and PRGs are updated regularly and calculated in'acCordance with EPA'a RialiAssessment Guidance for Superfund (http://www.epa.gov/oswer/riskassessmenUrisk superfund.htm ). Relative tothe RBC/PRG of 22,000 ug/L for tin, the Minnesota health-based limit of 4,000 ug/L proposeO Oy tfre State uses thesame reference dose of 0.6 mg/kg lday lor ingestion of tin. However, the Minnesota value includes additional
conservatism and uncertainty in the form of a fractional exposure factor (called the Relative Source ContributionFactor) that attempts to estimate the amount of tin risk from groundwater ingestion relative to other unspecifiedexposure pathways. This fractional exposure factor of 0.2 is a default value (i.e., it is not site-specific) that may notbe applicable to exposure pathways associated with the Mill. ln other words,'the Minnesota standard'assumei thatan individual receives 80% of the permissible amount of tin f rom exposure pathways other than ingestion ofgroundwater, leaving only 2Oo/" of the permissible level (i.e. 4000 ug/L assuming two liters of watei ingested per day)available from ingestion of groundwater. There is no reason to make this assumption for users of gro-undwater nearthe Mill site' We do not believe this approach is universally accepted or that it is the approach norrially taken by theState of Utah. The more standard approach adopted by EPA Flegions B, 6 and g woutb appear to be horeappropriate. As a result, we propose that the GWCLs in Table 2 of the Groundwater Discharge Permit be based onthe 22,000 ug/L standard for tin and not the 4,000 ug/L standard.
lf you have any questions or require any further information, please give me a call. I would suggest that once you have had achance to review our proposed.changes we have a telephone confeience to address any comments or questions you may haveon our suggestions' This will allow us to explain our thinking behind some of our suggestions. Please lei me know what worksbest for you.
1.
2.
David C. Frydenlund
Vice President and General Counsel
lnternational Uranium (USA) Corporation
105017th Street, Suite 950
Denver, CO 80265
Tel: [phone]
Fax: [phone]
www.intluranium.com
From:
IO:
Date:
Subject:
Loren,
"David Frydenlund" <davef @ intluranium.com>
"'Loren Morton"' <lmorton @ utah.gov>
18 October,2005 06:25:57 PM
Safety Evaluation Report for FMRI Materials
Attached is your draft SER for the FMRI Materials, blacklined to indicate
our suggested changes. ln addition to the blacklined changes, we also
propose that the following additional changes be made to the sER and rable 1
thereto:
1. Table 1 should be amended by adding three columns: one
showing the current estimated concentration of each parameter in the Mill's
tailings; one showing the estimated concentration of each parameter in the
Mill's tailings after processing the FMRI Materials; and one showing the
percentage increase or decrease in the concentration as a result of the
processing. These columns can be taken from Jo Ann Tischler's Table 2 to
Attachment 5 to IUSA's March 8, 2005 license amendment application. We
believe it is important to add these columns so that the reader can obtain a
better understanding of the impact of the FMRI materials on the Mill's
tailings. By just showing the changes in mass, the reader is not able to
gain this understanding. For example, the mass of any constituent will
always increase because adding the mass of a constituent in the FMRI
materials to the existing mass in the Mill' s tailings will by definition
always increase the total mass in the Mill's tailings, even if the
constituent is at a lower concentration in the FMRI materials than it
currently is in the Mill's tailings. Rather than just showing an increase
in the mass of all constituents, as currently set out in Table 1, by adding
these three columns, the reader can see that in many cases the
concentrations will actually decrease or stay relatively constant. ln
addition, the references in Table 1 should be references to lnternational
Uranium (usA) corporation and not references to lnternational Uranium
Corporation. Also, NQ should refer to "Not Quantified,,, rather than ,Not
Qualified".
2. IUSA proposes an alternate health-based level of 22,000
ug/L for tin. This level is consistent with the risk-based concentrations
(RBCs) and preliminary remedial goals (PRGs) for tap water that have been
developed by EPA Regions 3, 6, and 9, and that have been used for risk
screening by EPA Region 8 and states within Region 8. These RBCs and pRGs
are published at http://www.epa.gov/reg3hwmd/risk/human/rbc/rbcO4O5.pdf ,http://www. epa. gov/reg ion09/waste/sf u nd/prg/f iles/04prgtable. pdf ,http://www.epa.gov/earthl r6l6pd/rcra_c/pd-n/screen.htm. These RBCs and pRGs
are updated regularly and calculated in accordance with EpA's RiskAssessment Guidance for Superfund
(http://www.epa.gov/oswer/riskassessmenvrisk_superf und.htm ). Relative to
the RBC/PRG of 22,000 ug/L for tin, the Minnesota health-based limit of
4,000 ug/L proposed by the State uses the same reference dose of 0.6
mg/kg/day for ingestion of tin. However, the Minnesota value includes
for Paoe 2
additional conservatism and uncertainty in the form of a fractional exposure
factor (called the Relative Source Contribution Factor) that attempts to
estimate the amount of tin risk from groundwater ingestion relative to other
unspecified exposure pathways. This fractional exposure factor of 0.2 is a
default value (i.e., it is not site-specific) that may not be applicable to
exposure pathways associated with the Mill. ln other words, the Minnesota
standard assumes that an individual receives 80% of the permissible amount
of tin from exposure pathways other than ingestion of groundwater, leaving
only 2Oo/o of the permissible level (i.e. 4000 ug/L assuming two liters of
water ingested per day) available from ingestion of groundwater. There is
no reason to make this assumption for users of groundwater near the Mill
site. we do not believe this approach is universally accepted or that it is
the approach normally taken by the State of Utah. The more standard
approach adopted by EPA Regions 3, 6 and 9 would appear to be more
appropriate. As a result, we propose that the GWCLs in Table 2 of the
Groundwater Discharge Permit be based on the zz,ooo ug/L standard for tin
and not the 4,000 ug/L standard.
lf you have any questions or require any further information, please give me
a call. I would suggest that once you have had a chance to review ourproposed changes we have a telephone conference to address any comments or
questions you may have on our suggestions. This will allow us to explain
our thinking behind some of our suggestions. Please let me know what works
best for you.
David C. Frydenlund
Vice President and GeneralCounsel
lnternational Uranium (USA) Corporation
1050 17th Street, Suite 950
Denver, CO 80265
Tel: [phone]
Fax: [phone]
www.intluranium.com
CC: "'Dane Finerfrock"'<[e-mail], .,Dean Henderson',,<[e-mail]>, <[e-mail]>, <[e-mail]>,
<mark.colsman @ ttemi.com>
hristine - Fwd: KD analysis of FMR|trace meta
From: Loren Morton
To:
Date:
Dean Henderson
09 September, 2005 04:24:03 PMSubject: Fwd: KD analysis of FMRItrace metals
We need to consider this latest information as a part of the IUC Fansteel proposal for Alternate Feed.
Please review and let's discuss.
Christine Hiaring; Dane Finerfrock; John Hultquist; Johnathan Cook
trace metals
From:
To:
Date:
Subiect:
Loren,
"David Frydenlund" <davef @ intluranium.com>
"'Loren Mofion"' <lmorton @ utah.gov>
09 September, 2005 11:23:36 AM
KD analysis ol FMR|trace metals
Attached is a memorandum prepared by Tetratech, with accompanying Table 1,
which provides a Kd analysis of the trace metals in the FMRI materials that
are not included in the Mill's groundwater discharge permit.
Please let me know if you have any questions or require any further
information.
Thanks,
Dave
David C. Frydenlund
Vice President and General Counsel
lnternational Uranium (USA) Corporation
1050 17th Street, Suite 950
Denver, CO 80265
Tel: [phone]
Fax: [phone]
www.intluranium.com
CC:<hroberts @ intluranium.com>, <rhochstein @ intluranium.com>
09 ,doc
MEMORANDT]M
Harold Roberts
International Uranium (USA) Corporation
Mark R. Colsman, Ph.D.
Tetra Tech EM krc.
Date: September 9,2005
Subjecfi Survey of Reference Partition Coeflicient Values for Trace Heavy
Metals in Fansteel Metal,Inc. ('TMRI,,) Uranium Materials
This memorandum describes a review of literature partition coefficient values ("Kd's")
for a group of heavy metals that have been identified in materials from the Fansteel
Metals Muskogee, Oklahoma facility (FMRD that may be processed at the International
uranium (usA) corporation ("rusA") white Mesa Mill (the "Mill") near Blanding,
Utah. Previous characterization studies identified 38 non-radioactive metals in the FMRI
material. Twenty eight of these metals have:
1. already been identified as present in the Mill's existing tailings, and/or
2. already been identified as required analytical parameters in the Mill's Utah
Department of Environmental Quality ("UDEQ") groundwater permit monitoring
list.
The remaining group of 10 metals includes cerium, hafnium, lanthanum, neodymium,
niobium, praseodymium, scandium, tantalum, tungsten, and yttrium. These metals have
historically been of minimal concern as environmental contaminants that pose significant
risks to human or ecological receptors. However, in response to IUSA's license
amendment request for processing of FMRI material (dated March 7, zoos), the Utah
Department of Environmental Quality (UDEQ has required that IUSA consider the
potential groundwater mobility of these metals because they are not currently addressed in
the Mill's groundwater permit. IUSA requested the assistance of Tetra Tech in assessing
the potential mobility of these metals by reviewing available Kd values and
recommending whether or not they should be added as groundwater monitoring
parameters under the Mill's permit.
Tetra Tech's survey of literature Kd values focused on on-line reference materials and
databases of chemical property and environmental fate data, such as those available from
EPA and DOE. Other web-based resources were consulted from the NIH, ATSDR,
Atomic Energy of Canada, and various academic sources (such as the chemical property
databases from CalTech, University of Wisconsin, University of Minnesota, and the
Syracuse Research Corporation). A list of the major resources that were surveyed has
been provided at the end of this memo. These resources served as the starting point for
further investigations of the scientific literature, as possible within the timeframe of the
Christine Hiaring - Metals Kd Memo9 09 05and references fina Paqe 2
survey.
The survey found only limited Kd data for the 10 metals of interest, presented in Table L
In specifying parameters for groundwater monitoring, the Statement of Basis (SB) for the
Mill's discharge permit used the lowest Kd values available in the literature to assess
potential mobility in cases where site-specific Kd information was not available. The SB
found that the minimum Kd values for most of the metals contemplated for monitoring
were below 2 mUg Based on these low Kd's combined with the low pH of the Mill's
tailings ponds, the SB concluded that essentially all the metals evaluated could be mobile
and thus were to be included on the groundwater monitoring list.
In comparison to the Kd's referenced in the SB, the minimum literature Kd's listed in
Table 1 range from 40 mug for cerium to 1,500 mug for hafrrium. These minimum
values are generally 1 to 3 orders of magnitude above the minimum Kd's for the initial
list of metals referenced in the SB. On this basis, the group of metals in Table 1 would be
assessed as less mobile than the list of metals specified in the SB.
For the purposes of this evaluation, 17 major literature and web-based resources listed in
the Reference section below were reviewed for environmental mobility data. References
and links associated with these major resources were also surveyed, and generalized web
searches were performed for each metal. Out of all the resources reviewed, only four
contained any reference to, or data for, any of the 10 metals in the FMRI material. Based
on the scarcity of information that resulted even after the broad environmental literature
search, it can be inferred that these metals are not usually of significant environmental
concern.
In any event, there are a number of cations present in the Mill's tailings, such as arsenic,
calcium, iron, lead, magnesium, manganese, molybdenum, potassium, sodium, vanadium,
and zinc, that:
1. are already present at elevated concentrations in the Mill's tailings system, and in
many cases at higher concentrations than the trace constituents in the FMRI
material,
2. have lower Kd values (higher relative mobility), than the 10 metals associated
with FMRI material, and
3. are already required analytical parameters in the Mill's UDEQ permit monitoring
list.
As a result, there is no need to add these trace constituents as groundwater monitoring
parameters under the Mill's permit.
cc:David C. Frydenlund, ruSA
Jo Ann Tischler, Tetra Tech
Memo9 09 05and Paoe 4 i
REFERENCES
References for Kd's Listcd in Table I
Baes, C. F., [, Sharp, R. D., Sjoreen, A. L., and Shor, R. W., 1984. "A Review and
Analysis of Parameters for Assessing Transport of Environmentally Released
Radionuclides through Agriculture." ORNL-5786. Oak Ridge National Laboratory, Oak
Ridge, Tennessee. (Available at http://homer.ornl.sov/baes/documents. The partition
coefficients presented in this reference have been incorporated in ORNL's Risk
Assessment Information System, Chemical Specific Factors, http://risk.lsd.ornl.gov/cgi-
bin/tox/TOX select?select=csf.)
Hart, Don, and Don Lush. 2004. "The chemical roxicity potential of cANDU Spent
Fuel". Background Paper 4-4 for the Nuclear Waste Management Organization, Canada.
January.(Available
htto://www.nwmo.ca,/Default.aspx?DN=209. I 99.20. l.Documents.)
Thibault, D. H., M. L Sheppard, and P. A. Smith. 1990. A critical compilation and
Review of Default Soil Solid/Liquid Partition Coefficients, Kd, for Use in Environmental
Assessments. AECL- I 0 I 25, Whiteshell Nuclear Research Establishment, Atomic Energy
of Canada Limited, Pinawa, Canada.
TOXNET Toxicology Data Network, Hazardous Substances Data Bank, 2005. National
Library of Medicine, http://sis.nlm.nih. gov.
other References with no Kd Information for the Metars of Interest
Agency for Toxic Substances and Disease Registry, 2005. Toxicological Profiles, PublicHealth Statements, and HazDat Substance Database.
http ://atsdrl . atsdr.cdc. gov: 8O80/atsdrhome.html .
calrech Library System, chemistry, 2005. physical properties Databases and
References. http ://library.caltech. edu/collections/chemistry.htm.
Krupka K.M., R.J. serne, and D.I. Kaplan,2oo4. Geochemical Data package for the
2005 Hanford Integrated Disposal Facility Performance Assessment. PNNL-13037 Rev.2, Pacific Northwest National Laboratory, Richland, WA.
httP://www.pnl.gov/main/publications/externaV-technical reports/PNNl-13037Rev2.pdf
ohio Environmental Protection Agency, 2005. vadose Zone Modeling in RCRAClosure. Department of Hazardous waste Management. January.
http://www.epa. state.oh. us/dhwm/-pdf/VadoseFinal I 22904.pdf.
Pacific Northwest National Laboratory, 2005. Multimedia Environmental Pollutant
Christine H Metals Kd Memo9 09 05and references final.doc
Assessment System (MEPAS). Operated by Ballelle for the U.S. Department of Energy,
http://mepas.pnl. gov/earth/index.html .
Syracuse Research Corporation, 2005. Environmental Fate Database.
http://www.syrres.com/-esc/databases.htm .
University of Minnesota Biocatalysis and Biodegradation Database, supporting referencesand links, 2005.http://umbbd.ahc.umn.edu/resources.html ,
http ://umbbd. ahc.umn.edu/metals.html.
University of Wisconsin, Madison, Chemical Library, 2005. References and Links for
Physical and Chemical Properties.
http://chemistry.library.wisc.edu/properties/properties p.htm-#partition coefficient.
U.S. Environmental Protection Agency (EPA). 1999. "Understanding Variation in
Panition Coefficient, Ka, Values." Document EPA 402-R-99-004A and EPA 402-R-99-
0048. August. (Available at http://www.epa.eov/radiation/docs/kdreport/.)
U.S. EPA, 2005. "Partition Coefficients for Metals in Surface Water, Soil, and Waste."
J. D. Allison, and r. L. Allison, Athens, GA.. Publication No. EPA/600/R-051074, Jily.
http :/iwww.epa. gov/athens/publications/Pub2005.htm I
U.S. EPA, 2005. Soil Screening Guidance website and associated documents (1996,
2002). http : //www. epa. gov/superfu nd/resources/soil/#user.
U.S. EPA, 2005. Superfund Chemical Data Matrix. http://www.epa.eov/superfund/sites-
/npVhrsres/tools/scdm. htm.
Washington State Department of Ecology. Model Toxics Control Act Cleanup Program,cleanup Ipvels and Risk calculations (CLARC) Database
hftps ://fortres s. wa. gov/ecy/cl arcl-CLARCOverview.html
of FMRI Tablel Kdsf9.09.05 final.xls
Literature Kd Values for FMRI
)omDonent
Range in FMRI
Uranium Materlal
Ima/l ar nnmll
Estimated Avorage
)onc. in FMRI Uraniu.r
latarlal Imall ar nnm
Soil-Water Partition
Coeflicient, ORNL
ImlJol2
Soil-Wator Partltion
Coeflicient, NWMO
/ml /al3
ioil-Water Partltlol
Coeftlcient, Othsr
/ml /al
)erium (Ce)1.080-31.600 12.7A5 850 20 000 404
{afnirrm (HI\672-5.720 3.695 1 500 2.400
.anthanum (La)535-9.980 5.557 550 880
leodvmium (Nd)474-10.000 4 351 650
,liobium (Nb)<to-to ooo 7.270 350 3 3rX)
'150-2.040 937 650 s50
icandirrm (Sc\287-4.170 2.409 1.000
'antalum fTa)2.200-51.OOO I t16 650 1.200
'unosten (W)Ar1-l) a 6 3.706 150 150 100 5
/ttrium ffl o I 9-5 720 3.646 500 1,000
Notes to Table 1:
1. The range in the Uranium Material is based on the RMPR and additional characterization data that has been reviewed.
The estimated average concentration was calculated by using the mean values reponed by FMRI for
Ponds 2 and 3.
2. Values lrom Baes, C.F., lll, Sharp, R.D., Sjoreen, A.L. and Shor, R.W., 1984. 'A Review and Analysis of Parameters
for Assessing Transport of Environmentally Released Radionuclides through Agriculture.'
ORNL-5786. Oak Ridge National Laboratory, Oak Ridge, Tennessee.
(Also available at http://risk.lsd.ornl.gov/cgi-birVtox/TOX_select?select=csf .)
3. Values from Nuclear Waste Management Organization (NWMO), Canada, 2004. 'The Chemical Toxicity potential
of CANDU Spent Fuel", NWMO Background Paper 4-4. Ref. 6g't-22904.101.
http://www.nwmo.calDefault.aspx? DN=209, 1 99,20, 1, Documents.
4. Minimum value from Thibault, D. H., M. l. Sheppard, and P. A. Smith. 1990. "A Critical Compilation and Review of
Default Soil Solid/Liquid Partition Coetficients, Kd, for Use in Environmental Assessments." AECL-10125,
Whiteshell Nuclear Research Establishment, Atomic Energy of Canada Limited, Pinawa, Canada.
5. Minimum value from TOXNET Database, 2005, National Library of Medicine, http://sis.nlm.nih.gov/.
oo
From: Loren MortonTo: Johnathan CookDate: Thu, Dec 16,2004 5:55 PMSubject: IUC: DRC Summary of Tailings Wastewater Chemistry
See attached spreadsheet for info on tailings effluent water quality data - look for tabsheet called
NewSum. This is for the water phase contaminants - I didn't look at the solid phase ones. For that you
may have to ask IUC for data.
See me if there's questions.
Later,
Loren
CC:Christine Hiaring; John Hultquist
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From:
To:
Date:
Subject:
"David Frydenlund" <davef @ intluranium.com>
"'Christine Hiaring"' <chiaring@ utah.gov>
18 April, 2005 01:22:24PM
RE: License Amendment Request
Christine,
Attached is an electronic version of the application itself. I will send
you electronic versions of Appendices 4 and 5 once I get them from Jo Ann
Tischler.
Dave
From: Christine Hiaring [mailto:[e-mail]]
Sent: Monday, April 18, 2005 11:31 AM
To: davef @ intluranium.com
Subject: License Amendment Request
Dave, could you email any electronic portions you have of the March 7,zOOs
amendment request? lt would help expedite my review.
Thanks
Chris M Hiaring
State of Utah
Department of Environmental Quality
Division of Radiation Control
Chiaring@ utah.gov
[phone]
lf we knew what it was we were doing,
it would not be called research, would it?
-Einstein-
Christine H - FMRI Amendment Reouest 3.07.05 Final.doc
Request to Amend
Radioactive Material License
White Mesa Mill
And
Environmental Report
March 7,2005
Prepared by:
lnternational Uranium (USA) Corporation
1050 17'h Sfieet, Suite 950
Denver, CO 80265
Contact: David C. Frydenlund
Phone: [phone]
Submitted to:
Executive Secretary
State of Utah
Radiation Control Board
1.
.,
3.
4.
3.07.05 Final.doc
TABLE OF CONTENTS
INTRODUCTION
1.1. WhiteMesaMill
1.2. Proposed Action
1.3. Purpose of Action
L4. Amendment Application and Environmental Report
MATERIAL COMPOSITION AND VOLUME
2.1. General
2.2. Historical Summary of Sources
2.3. Radiochemical Data
2.4. Physical and Chemical Data
2.5. Comparison to Other Ores and Alternate Feed Materials Licensed for Processing at
the Mill
REGULATORY CONSIDERATIONS
3.1. Alternate Feed Guidance
3.2. Uranium Material Qualifies as "Ore"
3.3. Uranium Material Not Subject to RCRA
3.4. Uranium Material is Being Processed Primarily for its Source Material Content
EIWIRONMENT AFFECTED4.I. General
4.2. Transportation Considerations
4.3. Storage
4.4. Process
4.5. Compatibility With ruSA Mill Tailings
4.6. Groundwater
4.7. Surface Water
4.8. Airborne Radiological Impacts
4.9. Radon and Gamma Impacts
4.10. Safety Measures
4.1 l. Long Term Impacts
4. 12. Other Information
4. 1 3. Consideration of Alternatives
CERTIFICATION5.
Attachment I FMRI Site Location Maps
Affachment 2 Radioactive Material Profile Record
Attachment 3 ruSA/LIDEQ Protocol for Determining Whether Alternate Feed Materials
are RCRA Listed Hazardous Wastes
Attachment 4 l$#JJfr|1ilffil [hmentconsurtant
Regarding No RCRA Listed
Attachment 5 Memorandum from Independent Consultant Regarding Chemical
Compatibility of Uranium Material
1.2.
1. INTRODUCTION
White Mesa Mill
International Uranium (USA) Corporation ("ruSA") operates the White Mesa Uranium Mill (the
"Mill") located approximately six miles south of Blanding, Utah. The Mill processes natural
(native, raw) uranium ores and alternate feed materials. Alternate feed materials are uranium-
bearing materials other than natural ores, that meet the criteria specified in the United States
Nuclear Regulatory Commission's ("NRC's\ Interim Position and guidance on the Use of
Uranium Mill feed Material Other than Natural Ores (November 30, 2000) (the "Alternate Feed
Guidance"). Alternate feed materials are processed as "ore" at the Mill primarily for their source
material content. As a result, all waste associated with this processing is 11e.(2) byproduct
material.
Proposed Action
This is a request for an amendment to State of Utah Radioactive Materials License No. UT
1900/.79 to authorize receipt and processing of certain uranium-containing materials" These
materials are residues resulting from processing ores for the extraction oftantalum and niobium
at the FMRI, Inc. ("FMRI") site. For ease of reference, the uranium bearing material, in some
references referred to as Work-in-Process (WP) material, resulting from processing at the FMRI
site, and described further below in Section 2. is referred to herein as the "I]ranium Material".
The Uranium Material is located at the FMRI site located near Muskogee, Okalahoma (the
"Muskogee facility").
1.3. Purpose of Action
The Uranium Material contains greater than 0.057o source material, and accordingly, FMRI holds
a source material license, issued by the United States Nuclear Regulatory Commission (the
"NRC"), for the Muskogee facility. As a condition to the final remediation of the Muskogee
facility and ultimate termination of the source material license, NRC is requiring FMRI to
dispose of the Uranium Material at an off-site location.
IUSA has been requested by FMRI to make this application to process the Uranium Material as
an alternate feed material at the Mill and to dispose of the resulting tailings in the Mill's tailings
impoundments as 11e.(2) byproduct material, in an effort to provide FMRI with an option for
ultimate processing and disposal of the Uranium Material. By providing FMRI with the option
of processing the Uranium Material at the Mill, FMRI will be given the option of recycling the
Uranium Material for the recovery of valuable uranium, a resource that would otherwise be lost
to direct disposal.
1.4. Amendment Application and Environmental Report
This application is intended to fulfill the requirements of an application for an amendment to the
Mill's Radioactive Materials License set out in Utah Administrative Code ("UAC") R3l3-22-38
and includes the Environmental Report required by UAC R3l3-24-3 to be contained in such an
application.
2. MATERIAL COMPOSITION AND VOLTJME
2.1. General
The Uranium Material is currently stored in tailings ponds at the Muskogee facility. The Site
Location Maps in Attachment 1 show the general location of the Muskogee facility and the
specific location of the storage ponds at the facility. The Uranium Material is currently regulated
as source material by the NRC. The Uranium Material will be transported by FMRI, or its
transportation sub-contractor, from the Muskogee facility to the Mill.
2.2. Historical Summary of Sources
From 1960 to 1989, Fansteel, Inc. ("Fansteel") processed natural ores for recovery of tantalum
and niobium, at the Muskogee facility. FMRI is a subsidiary of Fansteel.
Before it was shut down in 1989, the Muskogee facility purchased tantalum ore and tin slag from
around the world. This feed material was leached in concentrated hydrofluoric acid and sulfuric
acid, the tantalum and niobium was dissolved in the solution and the insoluble fluoride
compounds such as thorium, radium and uranium remained behind in the solids. These solids
were filtered and collected in Ponds 2 and 3. The leached solids sent to Ponds 2 and 3 were
highly variable and contained on average approximately O.8Vo tantalum (Ta) and O.I7Vo IJtOs.
The variability was related to the leach efficiency of tantalum at that time as seen by the swings
in tantalum concentration throughout the ponds. The digestion step consisted of concentrated
hydrofluoric acid and some sulfuric acid. The solids in ponds 2 and 3 consist mainly of the
residual metal impurities in the fluoride form.
In the historical process, tantalum and niobium were extracted from the acidic liquid with methyl
isobutyl ketone (MIBK). In the solvent extraction stage, the MIBK organic was used to remove
the impurities such as iron, zirconium and uranium while leaving the tantalum in the "raffinate
stream". After the removal of the impurities, the tantalum was precipitated to form KzTaFz
(potassium heptafluorotantalate) and/or high-grade tantalum oxides and tantalum metals. The
raffinate stream, then containing little or no tantalum but relatively high acid concentrations
(hydrogen fluoride and sulfuric acids), was then neutralized with lime and sent to ponds 8 and 9.
The materials in Ponds 8 and 9 are not intended to be shipped to the Mill.
The Uranium Material is comprised of the materials stored in on-site Ponds 2 and 3, together
with ancillary drummed Uranium Material and pond cover soils, as well as surrounding soils,
;: T-- ffiii:,ilryffiref i* "*i"r ::_]l E3
materials and debris that have been impacted by the Uranium Material. The Uranium Material
has been stored on site at the Muskogee Facility, until an economic process to recover the
elements of interest was developed. The Mill process will recover uranium concentrates from the
solids left over from the previous tantalum processing.
FMRI has requested that IUSA recycle the uranium material and has asked that IUSA submit this
Amendment request. FMRI estimates that the total volume of Uranium Material is expected to
be approximately 16,000 dry tons (of which approximately 457o is expected to be from Pond 2
and surrounding areas and approximately 55Vo is expected to be from Pond 3 and surrounding
areas). According to FMRI personnel, and based on IUSA's past experience with alternate feed
materials in similar situations, this preliminary estimate could increase by up to approximately
1007o during the removal process. Therefore, this request for Amendment is for approval of up
to 32,000 dry tons of Uranium Material, to ensure that all the Uranium Material is covered by
this Amendment.
Attachment I contains Location maps of the Muskogee facility and Ponds 2 and3.
Attachment 2 contains the Radioactive Material Profile Record ("RMPR") completed by FMRI.
The RMPR contains radiological and chemical data summaries ("Solids Analysis") for the
Uranium Material.
2.3.Radiochemical Data
As noted, the process history demonstrates that the Uranium Material results from processing
natural ores and tin slag by leaching and solvent extraction processes for the recovery of tantalum
and niobium.
FMRI has estimated that the Uranium Material has a uranium content of approximately 0.151
weight percent uranium (0.178 weight percent UrOs), and approximately 0.358Vo thorium 232. A
more detailed radiological characterization of the Uranium Materials is contained in the RMPR.
2.4. Physical and Chemical Data
Physically, the Uranium Material is a de-watered slurry with no free liquid, consisting of finely
graded solids containing residual amounts of tantalum, niobium and uranium.
The chemical characterization data for the Uranium Materials is set out in the RMPR.
2.5. Comparison to Other Ores and Alternate Feed Materials Licensed for Processing at
theMill
2.5.t.Ores and Alternate Feed Materials With Similar Radiological Characteristics
With an average uranium content of approximately 0.l8Vo UsOs, the Uranium Material is
comparable to a relatively low-grade Colorado Plateau uranium ore. Colorado Plateau ores
3.07.05 Final.doc
typically average between about 0.157o and 0.307o UrOs.
The concentration of Th-232 of approximately 0.358Vo is also well within the levels of Th-232
that the Mill has been licensed to process in the past. For example the average concentrations of
Th-232 in the W.R. Grace, Heritage and Maywood alternate feed materials are approximately
7 .27 7o, l.08Vo and 0.88Vo respectively.
2.5.2.Ores and Alternate Feed Materials With Similar ChemicaVMetal Characteristics
The Uranium Material is very similar in chemical composition to the Cabot altemate feed
materials that the Mill has processed. Both are residues from previous processing of ores for the
recovery of tantalum and niobium. In fact, as discussed in more detail in Section 4.4 below, all
the constituents in the Uranium Material have either been reported to be, or can be assumed to
be, already present in the Mill's tailings system or were reported in other licensed alternate feeds,
at levels generally comparable to or higher than those reported in the FMRI ponds.
3. REGULATORYCONSIDERATIONS
3.1. Alternate Feed Guidance
The Alternate Feed Guidance provides that if it can be determined, using the criteria specified in
the Alternate Feed Guidance, that a proposed feed material meets the definition of "ore", that it
will not introduce a hazardous waste not otherwise exempted (unless specifically approved by the
EPA (or State) and the long term custodian), and that the primary purpose of its processing is for
its source material content, the request can be approved.
3.2. Uranium Material Qualifies as "Ore"
According to the Alternate Feed Guidance, for the tailings and wastes from the proposed
processing to qualify as l1e.(2) byproduct material, the feed material must qualify as "ore". NRC
has established the following definition of ore:
Ore is a natural or native matter that may be mined and treated for
the extraction of any of its constituents or any other matter from
which source material is extracted in a licensed uranium or thorium
mill.
The Uranium Material is an "other matter" which will be processed primarily for its source
material content in a licensed uranium mill, and therefore qualifies as "ore" under this definition.
3.3. Uranium Material Not Subject to RCRA
3.3.t.General
The Alternate Feed Guidance currently provides that if a proposed feed material contains
t 3.07.05 Final.docIC-h.riqtlr1e Hiaring - FMRI Amendment F
hazardous waste, listed under Section 26I.30-33, Subpart D, of 40 CFR (or comparable Resource
Conservation and Recovery Act ("RCRA") authorized State regulations), it would be subject to
EPA (or State) regulation under RCRA. However, the Guidance provides that if the licensee can
show that the proposed feed material does not consist of a listed hazardous waste, this issue is
resolved. NRC guidance further states that feed material exhibiting only a characteristic of
hazardous waste (ignitable, corrosive, reactive, toxic) that is being recycled, would not be
regulated as hazardous waste and could therefore be approved for extraction of source material.
The Alternate Feed Guidance concludes that if the feed material contains a listed hazardous
waste, the licensee can process it only if it obtains EPA (or State) approval and provides the
necessary documentation to that effect. The Alternate Feed Guidance also states that NRC staff
may consult with EPA (or the State) before making a determination on whether the feed material
contains listed hazardous waste.
Subsequent to the date of publication of the Alternate Feed Guidance, NRC recognized that,
because alternate feed materials that meet the requirements specified in the Alternate Feed
Guidance must be ores, any alternate feed materials that contain greater than 0.05Vo source
material are considered source material under the definition of source material in IOCFR 40.4
and hence exempt from the requirements of RCRA under 40CFR 26l-4(il@). See Technical
Evaluation Report Request to Receive and Process Molycorp Site Material issued by the NRC on
December 3,2001(the "Molycorp TER"). As a result, any such alternate feed ores are exempt
from RCRA, regardless of whether they would otherwise have been considered to contain listed
or characteristic hazardous wastes.
Since the Uranium Material contains greater than 0.O57o source material, it is exempt from
RCRA, regardless of its process history or constituents, and no further RCRA analysis is
required. Nevertheless, because the Alternate Feed Guidance has not yet been revised to reflect
this position recognized by NRC in the Molycorp TER, IUSA will demonstrate below that, even
if the Uranium Material were not considered source material and as such exempt from RCRA,
the Uranium Material would not, in any event, contain any RCRA listed hazardous wastes, as
required under the Alternate Feed Guidance as currently worded.
3.3.2. IUSA/UDEQ Listed Hazardous Waste Protocol
In a February, 1999 decision regarding the Mill, the Atomic Safety and Licensing Board
Presiding Officer suggested there was a general need for more specific protocols for determiningif alternate feed materials contain hazardous components. In a Memorandum and Order of
February 14, 2000, the full Commission of the NRC also concluded that this issue warranted
further staff refinement and standardization.
Cognizant at that time of the need for specific protocols to be used in making determinations as
to whether or not any alternate feeds considered for processing at the Mill contained listed
hazardous wastes, IUSA took a proactive role in the development of such a protocol.
Accordingly, ruSA established a "Protocol for Determining Whether Alternate Feed Materials
are Listed Hazardous Wastes" (November 22, 1999). This Protocol was developed in
conjunction with, and accepted by, the State of Utah Department of Environmental Quality
("UDEQ") (Irtter of December 7, 1999). Copies of the Protocol and UDEQ letter are provided
in Attachment 3. The provisions of the protocol can be summarized as follows:
In all cases, the protocol requires that IUSA perform a source investigation to
collect information regarding the composition and history of the material, and
any existing generator or agency determinations regarding its regulatory status;
The protocol states that if the material is known -- by means of chemical data
or site history -- to contain no listed hazardous waste, IUSA and UDEQ will
agree that the material is not a listed hazardous waste;
If such a direct confirmation is not available, the protocol describes the
additional chemical process and material handling history information that
IUSA will collect and evaluate to assess whether the chemical contaminants in
the material resulted from listed or non-listed sources;
The protocol also specifies the situations in which ongoing
confirmatior/acceptance sampling will be used, in addition to the chemical
process and handling history, to make a listed waste evaluation;
If the results from any of the decision steps indicate that the material or a
constituent of the material did result from a RCRA listed hazardous waste or
RCRA listed process, the material will be rejected; and
The protocol identifies the types of documentation that IUSA will obtain and
maintain on file, to support the assessment for each different decision
scenario.
The above components and conditions of the Protocol are summarized in a decision tree diagram,
or logic flow diagram, included in Attachment 3, and hereinafter referred to as the "Protocol
Diagram".
3.3.3. Application of the Listed Hazardous Waste Protocol
IUSA retained Jo Ann Tischler, an independent chemical engineer and RCRA expert, to conduct
a RCRA evaluation of the Uranium Material and, specifically, to apply the Listed Hazardous
Waste Protocol to the Uranium Material.
Ms. Tischler concluded that, based on the information that is available.
a) The Uranium Material is not a RCRA listed hazardous waste, because it is an
ore that has a natural uranium content of greater than 0.05 weight percent, is
therefore source material, and, as a result, is exempt from regulation under
RCRA;
a)
b)
c)
d)
e)
o
ristine Hiaring - FMRlAmendment Final.doc
Even if the Uranium Material were not source material, it would not be a
RCRA listed hazardous waste for the following additional reasons:
it was generated from a known process under the control of the generator,
who has provided an affidavit declaring that the Uranium Material is not
and does not contain RCRA listed hazardous waste. This determination is
consistent with Boxes I and 2 and Decision Diamonds I and 2 in the
ruSAruDEQ Protocol Diagram;
it is a solid waste that was specifically excluded from definition as a
hazardous waste by the Bevill Amendment;
(iii) The one VOC, MIBK, present in pond samples is not indicative of a
RCRA listed waste. MIBK is present in the material because it was
transferred to the ponds as a contaminant in aqueous tailings after the
liquid-liquid extraction circuit. EPA has determined that aqueous wastes
carrying residual solvents are not RCRA-listed solvent wastes;
(v)
The one SVOC reported in pond samples has been attributed by the
analyst and evaluator as resulting from sampling equipment and is not an
actual contaminant in the pond Uranium Material; and
None of the metals in the pond samples came from RCRA listed
hazardous waste sources. This determination is consistent with Box 8 and
Decision Diamonds 9 through 11 in the ruSA/UDEQ Protocol
Diagram;and
c) The characterization data indicates that, if it were not already exempt from
RCRA as source material, the Uranium Material would possess the RCRA
TCLP toxicity characteristic for chromium.
A copy of Ms. Tischler's analysis is included as Attachment 4.
3.3.4. Radioactive Material Profile Record
Furthermore, in order for IUSA to characterize the Uranium Material, FMRI has completed
IUSA's RMPR form, stating that the material is not RCRA listed waste. The certification section
of the RMPR includes the following text:
I certify that the material described in this profile has been fully
characterized and that hazardous constituents listed in 10 CFR 40
Appendix A Criterion 13 which are applicable to this material have been
indicated on this form. I further certify and warrant to IUSA that the
material represented on this form is not a hazardous waste as identified
by 40 CFR 261 and/or that this material is exempt from RCRA
b)
(i)
(ii)
(iv)
10
regulation under 40 CFR 261.4(a)(4).
3.3.5. Conclusion
Because the Uranium Material is an ore that contains greater than 0.057o source material, the
Uranium Material is exempt from RCRA under 40 CFR 261.4(aXa). In addition, based on the
site history, the determinations by FMR[, and the analysis of IUSA's independent expert
consultant, IUSA has also concluded that, even if not exempted from RCRA under 40 CFR
26I.4($($, on the application of the Listed Hazardous Waste Protocol, Uranium Material from
the Muskogee facility would not be listed hazardous waste subject to RCRA.
3.4. Uranium Material is Being Processed Primarily for its Source Material Content
In its Memorandum and Order, February 14, 2000, In the Matter of International (Jranium
(USA) Corporation (Request for Materials License Amendment), Docket No. 40-8681-MLA-4,
the NRC Commission concluded that an alternate feed material will be considered to be
processed primarily for its source material content if it is reasonable to conclude that uranium can
be recovered from the Uranium Material and that the processing will indeed occur.
The Uranium Material will be processed for the recovery of uranium at the Mill. Based on the
uranium content of the Uranium Material, its physical and chemical characteristics, and IUSA's
success in recovering uranium from a variety of different types of materials, including materials
that were similar to the Uranium Materials, at the Mill, it is reasonable to expect that uranium
can be recovered from the Uranium Material.
As a result, the Uranium Material is an ore that will be processed primarily for the recovery of
source material, and the tailings resulting from processing the Uranium Material will therefore be
lle.(2) byproduct material under the definition set out in 1OCFR 40.4.
4. ENVIRONMENTAFFECTED
4.1. General
The Mill is a licensed uranium processing facility that has processed to date approximately
4,000,000 tons of uranium-bearing conventionally mined ores and alternate feed materials
primarily for the recovery of uranium, with the resulting tailings being permanently disposed of
as 1le.(2) byproduct material in the Mill's tailings impoundments. Environmental impacts
associated with such previously licensed Mill operations have been thoroughly evaluated and
documented in the past (see, for example, the original 1979 Final Environmental Statement
("FES") for the Mill, Environmental Assessments ("EAs") for Mill license renewals dated 1985
and 1997, an EA for the Mill's reclamation plan dated 2000, and EAs for alternate feed materials
dated 2001 and 2002, in each case prepared by the NRC). The Uranium Material will also be
processed as an alternate feed ore at the Mill for the recovery of uranium and the resulting
tailings will be permanently disposed of in the Mill's tailings impoundments as lle.(2)
t1
Christine H ring - FMRlAmendment 3.07.05 Final.doc
byproduct material, in a similar fashion to other conventionally mined ores and alternate feed
materials that have been processed or licensed for processing at the Mill.
Accordingly, this Environmental Report will focus on the various pathways for potential
radiological and non-radiological impacts on public health, safety and the environment and
determine if the receipt and processing of the Uranium Material would result in any potential
significant incremental impacts over and above previously licensed activities.
The pathways that are analyzed are the following:
a) potential impacts from transportation of the Uranium Material to the Mill;
b) potential impacts from radiation released from the Uranium Material while in storage
at the Mill;
c) any chemical reactions that may occur in the Mill's process;
any potential reactions or inconsistencies with the existing tailings or tailings
facilities;
potential impacts on groundwater;
potential impacts on surface water;
potential airborne radiologic impacts;
potential radon and gamma impacts; and
i) worker health and safety issues.
These potential pathways will be discussed in the following sections of this document. The
findings below will demonstrate that, because all the constituents in the Uranium Material have
either been reported to be, or can be assumed to be, already present in the Mill's tailings system
or were reported in other licensed alternate feeds, at levels generally comparable to or higher than
those reported in the FMRI ponds, the resulting tailings will not be significantly different from
existing tailings at the facility. As a result, there will be no incremental public health, safety or
environmental impacts over and above previously licensed activities.
Any environmental impacts associated with removal of the Uranium Material from its place of
storage at the Muskogee facility and its packaging has been considered by NRC under the
Muskogee facility's source material license, and need not be considered here.
4.2. TransportationConsiderations
4.2.1. Packaging and Mode of Transportation
d)
e)
s)
h)
1,2
The Uranium Material excavated from the FMRI site will be dewatered to specified moisture
content (approximately 307o moisture) and placed in three (3) cubic yard fabric bags. The bags
will be placed inside covered exclusive use intermodal or roll-off containers ("IMCs") for rail
shipment to the White Mesa site. Each container will hold approximately 6 three cubic yard
bags.
The rail cars will be transported cross-country to the final rail destination (expected to be either
near Grand Junction, Colorado; Cisco, Utah; Green River, Utah; or East Carbon, Utah), where
they will be transferred to trucks for the final leg of the journey to the Mill. It is expected that
four containers will be shipped per rail car.
The Uranium Material will be shipped as Radioactive LSA tr (low specific activity) Hazardous
Material as defined by DOT regulations. FMRI will arrange with a materials handling contractor
for the proper marking, labeling, placarding, manifesting and transport of each shipment of the
Uranium Material. Shipments will be tracked by the shipping company from the Muskogee
facility until they reach the Mill. Each shipment will be "exclusive use" (i.e., the only material
on each vehicle will be the Uranium Material). FMRI may ship a total of approximately 1,100 to
2,300 IMCs or truckloads over the entire project. Shipments are expected to be completed over a
period of approximately two years.
The trucks involved in transporting the Uranium Material to the Mill site will be surveyed and
decontaminated, as necessary, prior to leaving the Muskogee facility for the Mill and again prior
to leaving the Mill site. If transported in IMCs, the IMCs will also be surveyed before leaving
the Muskogee facility and again upon leaving the Mill.
4.2.2. Transportation Impacts
For the following reasons, it is not expected that transportation impacts associated with the
movement of the Uranium Material by train and truck from the Muskogee facility to the Mill will
be significant:
d Radiological Matters
The transport of radioactive materials is subject to limits on radiation dose rate measured at the
transport vehicle as specified in the US Code of Federal Regulations. The external radiation
standards for these shipments are specified in 10 CFR 7I.47 sections (2) and (3) as less than 200
mrem/tr at any point on the outer surface of the vehicle, and less than 10 mrem/tr at any point 2
meters from the outer lateral surfaces of the vehicle. All transport vehicles and IMCs will be
scanned by FMRI prior to departure from the Muskogee facility to ensure that these limits are
satisfied.
From a radiologic standpoint, the Uranium Material is well within the bounds of other ores and
alternate feed materials licensed for processing at the Mill. The Uranium Material will be
transported in fabric bags within covered IMCs or trailers, in a similar fashion to other alternate
l3
feed materials, and as a result there will be no significant incremental radiological impacts
associated with transportation of Uranium Material to the Mill, over and above other previously
licensed ores and alternate feed materials at the Mill or from licensed activities at other facilities
in the State of Utah.
A Trffic Volume Matters
f) Comparison to Licensed Mill Operations
Section 4.8.5 of the 1979 FES for the Mill noted that during the operations period, when area
mining was at expected peak levels, approximately 68 round trips on local highways would be
made by 30-ton ore trucks to the Mill per day (see the 1978 Dames and Moore Environmental
Report for the Mill, p. 5-34).
In addition, based on a licensed yellowcake capacity of 4,380 tons per year (Mill license
condition 10.1) a maximum of 8,760,000 pounds of yellowcake would require shipment from the
Mill to conversion facilities. This would require approximately 183-275 truck shipments, from
the Mill per year (based on 40-60 drums per truck, 800 lbs per drum), or one truck every one to
two days based on a seven day work week (one truck every day or so, based on a five-day work
week).
In contrast, approximately 1,100 to 2,300IMCs (or truck loads) will be transported from the
Muskogee facility to the Mill during a period of 52 to 104 weeks, under this project. This works
out to approximately 4 to 5 trucks per day assuming a five-day work week or approximately 3
trucks per day assuming a seven-day work week. In addition, the amount of yellowcake to be
produced from processing the Uranium Material is expected to be transported in two to four
truck loads during the life of the project. These volumes are clearly within the volumes of truck
transportation of ores to the Mill under existing licensed capacity. During the period of
transportation of the ISOs to the Mill, IUSA does not expect that ore deliveries from all other
sources would, in total, exceed a small fraction of the truck transportation associated with
licensed capacity.
fij) Comparison to Existing Truck Traffic on Highway 191
On average during 2002, 1,149 trucks traveled south on State Road l9l from Moab across the
Grand County line, and 686 trucks per day traveled the stretch of State Road 191 south of
Monticello, UT toward Blanding, UT (April 9, 2OO3 White Mesa Mill communication with the
State of Utah Department of Transportation ("LDOT")).
Based on the 2002UDOT truck traffic information, an average of 4 or 5 additional trucks per day
traveling this route to the Mill represents an increased traffic load of less than I percent.
For the foregoing reasons, the truck traffic to the Mill from this project is expected to be an
insignificant portion of existing truck traffic in the area, and well within the level of truck traffic
expected from normal Mill operations.
t4
C.-!rlstine Hiaring - FMRI Amendment 3.07.05 Final.doc
4.3.Storage
4.3.1. Manner of Storage
Containers arriving at the Mill site will be received according to existing Mill procedures. The
shipping bags will be unloaded from the IMCs and placed in a designated area for storage until
the material is scheduled for processing. The Uranium Material will not be unloaded from the
shipping bags until just prior to being introduced into the Mill processing circuit. leaving the
material in the shipping bags will eliminate the need for additional dust control measures during
storage.
4.3.2. Environmental Impacts Associated With Storage
Because the Uranium Material will be contained in fabric bags, there will be no pathways for
exposure of Uranium Material to the environment while in storage. Gamma radiation and radon
emanation from the bagged material will be minimal and within the levels associated with other
ores and alternate feed materials handled at the Mill on a routine basis.
Process
The Uranium Material will be added to the Mill circuit in a manner similar to that used for the
normal processing of conventional ore, either alone or in combination with other approved
alternate feed materials. The Uranium Material will be introduced to the process circuit either
through the conventional ore grinding circuit or by use of the existing trommel screen to remove
non-uranium bearing oversize material prior to processing. The material will be processed
through the existing acid leach, CCD and solvent extraction circuits for the recovery ofuranium
values. The leaching process will begin in Pulp Storage with the addition of sulfuric acid. The
solution will be advanced through the remainder of the Mill circuit with no significant
modifications to either the circuit or the recovery process anticipated. Since no significant
physical changes to the Mill circuit will be necessary to process this Uranium Material, no
significant construction impacts beyond those previously assessed will be involved.
Recovery of additional contained metals is not anticipated at this time. Should IUSA decide to
recover tantalum or other metals from the Uranium Materials, such recovery will be
accomplished in a manner similar to the recovery of vanadium, tantalum and other metals at the
Mill in the past.
As mentioned above, the Uranium Material is very similar to the Cabot Materials, which
contained comparable levels of similar metals in their oxide and salt forms. The Cabot Materials
i%dlsl
4.4.
l5
3.07.05 Final.docI Christine Hia
were successfully processed at the Mill during 1997-1998 for the recovery of uranium and
tantalum, under a previous amendment to the Mill's license, without any unforeseen or adverse
process impacts.
The effects of introducing the Uranium Material into the Mill's process and tailings were
reviewed by Jo Ann Tischler, an independent chemical expert. Ms. Tischler's report is included
as Attachment 5. Table 2 to Ms. Tischler's report compares the concentrations of all known
constituents in the Uranium Material to the concentrations of those constituents currently
reported in the Mill's tailings and in other ores and alternate feed materials that have been
licensed for processing at the Mill. Ms. Tischler reached the following conclusions:
a) All the constituents in the Uranium Material have either been reported to be, or
can be assumed to be, already present in the Mill's tailings system or were
reported in other alternate feeds licensed for processing at the Mill, at levels
generally comparable to or higher than those reported in the FMRI ponds. In the
five cases where the concentrations of an analyte were higher in the Uranium
Material than in the Mill's tailings and in other alternate feed materials licensed
for processing at the Mill, the difference in concentration is not significant;
b) All the constituents in the Uranium Material have either been reported to be, or
can be assumed to be, previously introduced into the Mill process, with no
adverse effects to the process, or worker health and safety;
c) The one SVOC reported in pond samples has been attributed by the analyst and
evaluator as resulting from sampling equipment and is not an actual contaminant
in the pond Uranium Material;
d) The Mill has processed alternate feeds with ketones (acetone, methyl ethyl ketone
e.g.) more volatile and mobile than the MIBK reported in FMRI samples. MIBK
is present in the FMRI ponds at concentrations comparable to and lower than the
levels of the lighter, more volatile ketones already processed in other alternate
feeds at the Mill. Acetone may not be present in the Uranium Material. If its
single detection was real, its level is 2,000 times lower than the MIBK;
e) There will be no significant incremental environmental impacts from the
processing of Uranium Material beyond those that are already anticipated in the
Environmental Statement and Environmental Assessments for the Mill; and
Spill response and control measures designed to minimize particulate radionuclide
hazards will be more than sufficient to manage chemical hazards from particulate
metal oxides.
Ms. Tischler also concluded that all of the chemical contaminants in the Uranium Material are
acceptable at the Mill at the levels indicated in the Characterization Data Summary, with no
process impacts. Ms. Tischler notes that, based on the available data, it is reasonable to conclude
16
3.07.05 Final.doc
that the Mill has already processed alternate feeds containing all of the same elemental
constituents, at generally comparable or higher concentrations than are exhibited in the Uranium
Material. Ms. Tischler further concludes that, in the few cases (cadmium, manganese, potassium,
sodium, and titanium) where the concentration of an analyte in the Uranium Material exceeds the
current concentration for that analyte in the Mill's tailings and in other alternate feed materials
that have been licensed for processing at the Mill, the expected impact on the tailings is
insignificant (an increase in concentration of each such analyte in the tailings of 0.10 percent or
less).
Ms. Tischler also concluded that, while the presence of elevated levels of certain constituents
may involve some additional material management requirements during processing, these are
requirements that the Mill has successfully implemented in the processing of previous altemate
feeds. For example, Ms. Tischler notes that the Mill has successfully processed and recovered
uranium from uranium-bearing salts, calcium fluoride precipitates, recycled metals, metal oxides,
and calcined product, all of which posed potential chemical reactivity and material handling
issues comparable to or more significant than those associated with this alternate feed.
Furthermore, the Cabot alternate feed materials were similar residues from tantalum/niobium ore
processing, with similar radiological and chemical characteristics.
4.5.Compatibility With IUSA Mill Tailings
Physical Compatibility.4.5.t.
Generally, the composition of the Uranium Material is very similar to the composition of the
materials currently in the Mill's tailings impoundments, because the Uranium Material resulted
from the processing of metal ores by chemical leaching and solvent extraction, and will not have
an adverse impact on the overall Cell3 tailings composition.
In fact, as mentioned above, the Uranium Materials are very similar to the Cabot altemate feed
materials that were processed at the Mill in 1997-1998 (See License Amendment No. 4). Like
the Uranium Materials, the Cabot alternate feed materials were also residues from ores that had
been previously processed for the recovery of tantalum and niobium using a similar process as
that used at the Muskogee Facility. The Cabot materials were processed successfully and without
incident at the Mill.
Nevertheless, in performing her process review, Ms. Tischler, an independent chemical expert,
also evaluated the impacts of the Uranium Material on the Mill's tailings system and concluded
that all the known impurities in the Uranium Material have either been reported to be, or can be
assumed to be, previously introduced into the Mill tailings impoundments, with no adverse
effects to the tailings system, or human health and safety. Ms. Tischler further concludes that the
constituents in the Uranium Material are expected to produce no incremental additional
environmental, health, or safety impacts in the Mill's tailings system beyond those produced by
the Mill's processing of natural ores or previously approved alternate feed materials. A copy of
Ms. Tischler's report is attached hereto as Attachment 5. Table 2 to Ms. Tischler's report shows
L7
Christine Hiaring - FMRlAmendment 3.07 Final.doc
a comparison of the concentrations of all known constituents in the Uranium Material to reported
concentrations of those constituents in the Mill's tailings and in other alternate feed materials that
have been licensed for processing at the Mill.
4.5.2. Capacity and Throughput
The amount of tailings that would potentially be generated is comparable to the volume that
would be generated from processing an equivalent volume of conventional ore. FMR[, as
described above, may be expected to remove and ship up to 32,000 dry tons of Uranium Material
from the Muskogee facility over a period of one to two years during 2005 to 2007. This volume
is well within the maximum annual throughput rate and tailings generation rate for the Mill of
680,000 tons per year. Additionally, the design of the existing impoundments has previously
been approved by the NRC, and IUSA is required to conduct regular monitoring of the
impoundment leak detection systems and of the groundwater in the vicinity of the impoundments
to detect leakage should it occur.
IUSA proposes that, as has been the case for recent alternate feed license amendments approved
by the NRC, a condition should be added to the license amendment to the effect that the Mill
shall not accept any Uranium Material at the site unless and until the Mill's Safety and
Environmental Review Panel ("SERP") has determined that the Mill has sufficient licensed
tailings capacity to permanently store:
all 1le.(2) byproduct material that would result from processing all the
Uranium Material,
all other ores and altemate feed materials on site; and
c) all other materials required to be disposed of in the Mill's tailings
impoundments pursuant to the Mill's reclamation plan.
Groundwater
In the 1997 EA, NRC staff concluded that, for a number of reasons, groundwater beneath or in
the vicinity of the Mill site will not be adversely impacted by continued operation of the Mill.
Because the Mill's tailings cells are not impacting groundwater, the receipt and processing of
Uranium Material at the Mill will not have any incremental impacts on groundwater over and
above existing licensed operations.
The chemical and radiological make-up of the Uranium Material is similar to other ores and
alternate feed materials processed at the Mill, and their resulting tailings will have the chemical
composition of typical uranium process tailings, for which the Mill's tailings system was
designed. As a result, the existing groundwater monitoring progmm at the Mill will be adequate
to detect any potential future impacts to groundwater.
As a result, there will be no incremental impacts over and above previously licensed activities.
a)
b)
4.6.
18
4.7. Surface Water
There will be no discharge of Mill effluents to local surface waters. All Mill process effluents,
laundry, and analytical laboratory liquid wastes will be discharged to the Mill's tailings
impoundments for disposal by evaporation. Runoff from the Mill and facilities is directed to the
tailings impoundments. Sanitary wastes are discharged to State-approved leach fields. Since
there is no plausible pathway for Uranium Material to impact surface water, and, as indicated in
Semi-Annual Effluent Reports filed by the Mill to date, there is no indication of the Mill
impacting surface waters, then there will be no incremental impact to surface waters from any
airborne particulates associated with processing the Uranium Material.
Uranium Material will be transported to the Mill in closed bags and stored at the Mill in those
bags pending processing. There will therefore be no risk of fugitive dust from the Uranium
Material while in storage at the Mill. Upon introduction into the Mill circuit, the Uranium
Material will be processed in a similar fashion as other ores and alternate feed materials. The
Uranium Material will be relatively moist, with an average moisture content of approximately
3OVo. This will minimize any potential for dusting while the Uranium Material is removed from
the closed bags and introduced into the Mill process. In addition, standard procedures at the Mill
for dust suppression will be employed if necessary. There will therefore be no new or
incremental risk of discharge to surface waters resulting from the receipt and processing of
Uranium Material at the Mill or the disposition of the resulting tailings.
Finally, as the chemical and radiological make-up of the Uranium Material is similar to other
ores and alternate feed materials and the tailings resulting therefrom, the existing surface water
monitoring prognm at the Mill will be adequate to detect any potential impacts to surface water.
As a result, there will be no incremental impacts over and above previously licensed activities.
4.8. AirborneRadiologicallmpacts
The chemical and radiological make-up of the Uranium Material will not be significantly
different from other ores and alternate feed materials that have been processed at the Mill in the
past. The existing air particulate monitoring program is equipped to handle all such ores.
4.9. Radon and Gamma Impacts
As discussed in Section 2.5.2 above, the concentration of uranium in the Uranium Material is
comparable to the concentration of uranium in conventionally mined Colorado Plateau ores.
Furthermore, as is evident from the RMPR, the uranium daughters, such as Ra-226 are in
approximate secular equilibrium with the uranium. ln addition, the concentration of Th-232 in
the Uranium Material is comparable to or lower than the concentration of Th-232 in a number of
other alternate feed materials that have been licensed for processing at the Mill. As a result, the
Uranium Material contains comparable concentrations of radium and other gamma-emitting
radionuclides than other ores and alternate feed materials licensed for processing at the Mill. The
Uranium Material will therefore pose less a gamma and radon hazard than other ores and
l9
alternate feed materials that have been processed or licensed for processing at the Mill.
4.10. Safety Measures
4.10.1. General
During unloading of the Uranium Material onto the ore pad, while the Uranium Material is being
stored on the ore pad pending processing, while feeding Uranium Material into the Mill process
and while processing the Uranium Material and disposing of and managing the resulting tailings,
the Mill will follow its standard operating procedures for occupational and radiological safety.
4.10.2. Radiation Safety
a) Existing Radiation Protection Program at the Mill
The radiation safety program which exists at the Mill, pursuant to the conditions and provisions
of the Mill's Radioactive Materials License, and applicable State Regulations, is adequate to
ensure the maximum protection of the worker and environment, and is consistent with the
principle of maintaining exposures of radiation to individual workers and to the general public to
levels As Low As Reasonably Achievable (ALARA).
Employees will be provided with personal protective equipment including full-face respirators, if
required. In addition, all workers at the Mill are required to wear personal TLD badges or the
equivalent to detect their exposure to gamma radiation.
b) Gamma Radiation
Gamma radiation levels associated with the Uranium Material are within levels of gamma
radiation associated with other ores and alternate feed materials processed or licensed for
processing at the Mill in the past. Gamma exposure to workers will be managed in accordance
with existing Mill standard operating procedures.
c)Radon
Radon levels associated with the Uranium Material are within levels of radon associated with
other ores and alternate feed materials processed or licensed for processing at the Mill in the past.
Radon exposures to workers will be managed in accordance with existing Mill standard
operating procedures.
d) Control of Airborne Contamination
The Uranium Material will be a fine-grained solid with an average moisture content of
approximately 3OVo and particle sizes ranging from less than 0.4 micron to over 30 microns.
Because the Uranium Material will be stored in closed bags while in storage, there will be no
need for dust suppression mechanisms during unloading from the IMCs and storage at the Mill.
20
rffiruiiffiHia;ffi 6:FMHmfr6;dilfii
Dust suppression techniques will be implemented, if required, while the Uranium Material is
being introduced into the Mill process, although this may be unnecessary due to the relatively
high moisture content of the Uranium Material. Once in the Mill process, the Uranium Material
will be in a slurry form, and no special dust suppression procedures will be required.
As is the practice at the Mill for other alternate feed materials, the Derived Air Concentration
("DAC") to be used in any analysis of airborne particulate exposure to workers will be developed
specifically for the Uranium Material, based on applicable regulations and Mill procedures, in
order to take into account the specific radionuclide make-up of the Uranium Material. The White
Mesa Mill has safely received and processed alternate feed materials with higher concentrations
of each of the radionuclides contained in the Uranium Material, under previous license
amendments, and can safely handle the Uranium Material in accordance with existing Mill
standard operating procedures.
4.10.3. Occupational Safety
The primary focus of safety and environmental control measures will be to manage potential
exposures from radionuclide particulates. Response actions and control measures designed to
manage particulate radionuclide hazards will be more than sufficient to manage chemical hazards
from the metal oxides (see the conclusions of Jo Ann Tischler in Attachment 5).
In addition, the Uranium Material contains fluoride, which can pose a hazard to workers.
Workers will be provided with appropriate personal protective equipment in accordance with
Mill standard operating procedures. The Mill has safely handled other alternate feed materials
with similar or higher concentrations of fluoride, and as a result, is experienced in safely
handling such materials.
4.1O.4. Vehicle Scan
As stated in Section 4.2.1 above, the shipments of Uranium Material to and from the Mill will be
dedicated, exclusive loads. Radiation surveys and radiation levels consistent with applicable
DOT regulations will be applied to restricted use vehicles and IMCs. For unrestricted use,
radiation levels will be in accordance with applicable values contained in the NRC Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material, U.S. NRC, May,
1987. If radiation levels indicate values in excess of the above limits, appropriate
decontamination procedures will be implemented.
4.11. Long Term Impacts
The Uranium Material is comprised of similar chemical and radiological components as already
exist in the Mill's tailings cells. Existing monitoring programs are therefore adequate and no
new monitoring procedures are required. As a result, there will be no decommissioning,
decontamination or reclamation impacts associated with processing the Uranium Material, over
2t
cniietin-"''',,t|iem"-:runtAmendment.R.eqllEsts.ol.o5-r-i11at.ooc-22
and above previously licensed Mill operations.
4.12. Otherlnformation
4.12.1. Added Advantase of Recycling
FMRI has expressed its preference for use of recycling and mineral recovery technologies for the
Uranium Material for three reasons: 1) for the environmental benefit of reclaiming valuable
minerals; 2) for the added benefit of reducing radioactive material disposal costs; and 3) for the
added benefit of minimizing or eliminating any long term contingent liability for the waste
materials generated during processing.
FMRI has noted that the Mill has the technology necessary to recycle materials for the extraction
of uranium and other metals and to provide for disposal of the l1e.(2) byproduct material,
resulting from processing primarily for the uranium, in the Mill's existing tailings
impoundments. As a result, FMRI will contractually required IUSA to recycle the Uranium
Material at the Mill primarily for the recovery of uranium.
4.13. Consideration of Alternatives
This application is in response to a request by FMRI for disposaVprocessing options in
connection with the clean up of the Muskogee facility under its NRC source material license.
The Mill is a facility that has been requested to provide these services, because it is licensed to
process materials for the recovery of uranium and is licensed to create, possess and dispose of
byproduct materials that are similar to the Uranium Materials. Options for the remediation of the
Muskogee facility and the disposition of the Uranium Materials have been thoroughly reviewed
as part of the NRC source material license termination process. Given that a decision to dispose
of the Uranium Material at an offsite facility, rather than at the Muskogee facility itself, has been
made, the only options are as to which offsite facility the Uranium Materials will ultimately be
sent to for disposal. There are a limited number of facilities that are licensed to receive, store,
process or dispose of the Uranium Material. Alternatives to processing/disposal at the Mill
would be direct disposal or processing at one of these other facilities. If direct disposal is
utilized, the value of the recoverable uranium in the Uranium Material would not be realized.
5. CBRTIFICATION
This application and Environmental Report has been submitted as of March 7,20O5 by
INTERNATIONAL URANruM (USA) CORPORATION
By:
David C. Frydenlund
22
Vice President and General Counsel
23
Christine Hiarino - FMRI Amendment Reouest 3.07.05 Final.24
ATTACHMENT 1
FMRI Site Location Maps
ATTACHMENT 2
Radioactive Material Profi le Record
25
ATTACHMBNT 3
ruSAruDEQ Protocol
for Determining Whether Alternate feed Materials
are Listed llazardous Wastes
26
ATTACHMENT 4
Memorandum from Independent Consultant
Regarding
No RCRA Listed Hazardous Waste in Uranium Material
27
- FMRI Amendment Reouest 3.07.05 Final.doc
ATTACHMENT 5
Memorandum from Independent Consultant
Regarding
Chemical Compatibility of Uranium Material
28
3.07.05 final.xls
TABLE 1
lncompatibilities and Chemical Hazards for Components of FMR! Uranium Material
)omDonenl Chemical Svmbol
Typical
)omponent Leve
Innmll lncompatibilities
\cetone CHgCOCHe 0-81 )xidizers. strono acids
\luminum AI 2.000-94.000 Is AlzOs - ClF3, hot chlorinated rubber, acids, oxidizers
\mmonia NH4 26-178 itronq oxidizers, haloqens. acids, salts ol silver and zinc
\ntimonv Sb <1 - 2.6 $ SbzOs - none
\rsenic As 0-581
rs AseOs - heat decomposes to trioxides, reacts with BrF3, reducing
rqents, with metals in presence of water
3arium Ba 100-3.000
rc Barium oxides - reacts with water to form hydroxides; reacts with
tJzOa. hvdroxvlamines. SO". HrS
3ervllium Be 8.5-33.8 s BeO - oives off toxic oases in fire
ladmium cd 59.000
rs CdO - reacts with magnesium, decomposes on heating to form
)admium fumes
lalcium Ca r3,000-197,00(rs Ca oxides - react with water
rs Ca hydroxides - react with water
rs CaSO4 - diazomethane, aluminum. phosphorus. water
rs CaSiOa or CaOSiO, - none
lerium Ce 1.080-31.600 10ne
lobalt Co 1.320 lsCoO - none
)hloride ct 74-960 /aries with compound form. As inorqanic salts - none
]hromium Cr 3-2.000 ts CrO, - none
ts CrOs - combustible materials (paper, wood, sulfur, aluminum,
rlastics)
)vanide CN ND-2.200 itronq oxidizers (acids, acid salts. chlorates and nitrates)
)i-n-butyl
ththalate R-COOR 0.35-1.35 tone
Jafnium Hf 672-5,720 rs metal - stronq oxidizers. free chlorine
=luorine F 640-396.000 rs HF - water, steam. corrosive to metals.
ts F2 - water, nitric acid, oxides, orqanics
ron Fe 8,800-54.000 ts FezO: - calcium hvoochlorite. carbon monoxide. hvdrooen oeroxide
ls Fe2(SO4)3 - decomposes at hiqh temoerature
ts AszFeeOo - decomposes on heatinq to yield fumes of arsenic & iron
-anthanum La 535-9.980 tone
-ead Pb <10-2.040
rs PbO - strong oxidants, aluminum powder.sodium; also decomposes
rn heatinq to form lead fumes
Vlaqnesium Mo 14.000 rs MqO - halooens. CLFs
M$(soa)2(oH),
Christine Hiaring - FMRlTablel Compatibil
Ulanoanese Mn 540-3.000.ls Mn(OH)" MnrO.. MnO- none
VlercurV Ho <0.01-4.6 rs HoO - none
rs HqzO - none
ulethyl isobutyl
retone (MIBK)CHgCOC(CHg)s
ND-1,300(avo.4 oom)also called hexone) strono oxidizers. ootassium tert-butoxide
vlolvbdenum Mo 420-9.800 rs Mo - strono oxidixers
{eodvmium Nd 474-10.OOO 10ne
{ickel Ni <5-700 ts NiO - iodine. H,S
rliobium
Columbium)Nb <10-10,000 tone
{itrates Nox 2.4-9.2.rone reported
)hosohate P 12.900 ts PzOo - water. bases. perchloric acid
ls ohosohates - none
)otassitrm K 300-3,400.rs IGO - forms potassium hvdroxide in water
)raseodvmium Pr 150-2,040 lone
icandium Sc 287-4.170 lone
Selenium Se <0.1-4.3 ls SeO - none
iilieon Si 22.OOO rone reported
3ilver Aq 10-52.7 rs AqzO - fire and explosion hazard with orqanic material or ammonia o
iodium Na 740-13,000.rc NaO - srono oxidizer. reacts with water
rs NaOH - stronq oxidizer. reacts with water
ls NaNOg - fire risk near orqanic materials
rs NaSisOz - reacts with aluminum, zinc
iulfate so4 52-10.800.ls SO4 comounds. see other comoounds in this table
iulfide S
rot reported as
Sulfide tone
[antalum Ta 2 200-51 000 rs metal and oxides - strono oxidizers. bromine trifluoiride, fluorine
Ihallium TI 3 rs Tl oxides - none
Ihorium Th 0.01-14.700 10ne
l-in Sn 2.460->10.000 rs SnO - none
itanium Ti 12.200-38.800 ls TiOz - none
Iunqsten W 627-12,300
ls metal, bromine trifluoride, chlorine trifluoride, fluorine gas, iodine
rentafluoride
/ttrium o.19-5.720 rs metal - strono oxidizers
Zirconium Zr 17.500-51.000 rs metal and comoounds - ootassium nitrate. oxidizers
7-inc Zn 420 rs ZnO - none
Notes:
1. Values not otherwise marked are the minimum and maximum from direct pond material analysis.
2. Values marked by "*" were estimated by calculation from TCLP analysis using EPA 20 times rule.
BEFERENCES:
1. NIOSH Pocket Guide to Hazardous Chemicals and Web updates
2. Hawley's Condensed Chemical Dictionary
3. Center for Disease Control/ National lnstitute for Occupational Safety and Health Database
3. Center for Disease Control/ National lnstitute for Occupational Safety and Health Chemical Cards
A
Range in Uranium
Material (mg/L or
A
Range in Uranium
Material (mgy'L or
I
Conc. in Mill
Tailings after
Uranium
Material
Processing
24
I
Conc. in Mill
Tailings after
Uranium
Material
Processing
149
3.07.05 final.xls
Comparison ol
Page 2 !
3.07.05 final.xls
Table 2 Comparison of Uranium Materia ailings and Alternate Feeds
Notes to Table 2:
1. The range in the Uranium Material is based on the RMPR and additional characterization data that has been reviewed. The estimated average concentratic
Uranium Material has been calculated as follows:
a. Mean value reported by FMRI for Ponds 2 and 3.
b. Mean value calculated lrom FMRI data for Ponds 2 and 3. Each ND value was included in the calculation as the midpoint between zerc
and the lower detection limit. This is considered conservative.
c. Based on single reported value if only one value was available. These values are considered conservalive.
d. Calculated midpoint of range. Only range ol data was available. Each "<" value was included in the calculation as the midpoint betwee
and the lower detection limit. These values are considered conservative.
e. Concentration was calculated from TCLP value using EPA 20 times rule.
f. RMPR indicated it was present. Presence and level not confirmed with data.
2. Estimated mass in the Uranium Material is calculated by multiplying column B by an assumed 32,000 dry tons of Uranium Material.
3. Mill tailings range and average concentrations were taken from Mill tailings samples to date, as summarized inTable 5 of the draft Statement of Basis lor the
Groundwater Discharge Permit for the Mill (November 29,2004).
4. Estimated current mass in Mill tailings is calculated by multipling the estimated average concentration in the Mill tailings in Column F by 1,769,000 dry tons
tailings currently in the Mill's active tailings Cell No. 3.
5. Mass in Mill tailings after Uranium Material processing is calculated by adding columns D and G.
6. The increase of component mass in the Mill tailings after Uranium Material processing is calculated as the percentage increase in column H over column G.
7. The concentration in Mill tailings after Uranium Material processing is calculated by dividing column H by 1,800,515, being the existing volume of tailings in
Cell No 3 of 1,769,000 dry tons plus the assumed 32,000 dry tons of Uranium Material.
8. The increase in Mill tailings concentration after Uranium Material processing (ppm) shows the increase (decrease) in concentration of each constituent in th,
Mill's tailings, stated in ppm of the total mass of tailings in Cell No. 3, which is calculated as the difference between column I and column I
9. The increase in Mill tailings concentration after Uranium Material processing (%) is the same number as in column J, except stated as the increase or decre
in the percentage of total Mill tailings mass in tailings Cell No. 3.
10. The concentration in other alternate feeds represents some selected concentrations for constituents found in characterization data lor other altemate feed
materials licensed for processing at the Mill, for comparison purposes.
11. MIBK has not been analyzed in tailings. Levels of MEK, a more volatile and mobile ketone, were used for comparison.
12. Barium, chromium, nickel, antimony, and selenium were not analyzed for in the FMRI Ponds, but were detected in perimeter soils.
13. Hafnium has been identilied in Mill process streams and is therefore in the Mill tailings; however, it has not been analayzed/quantified in the Mill tailings.
Christine Hiaring - March 712005 FMRI Amendment Request
From:
To:
Date:
Subject:
"David Frydenlund" <[e-mail]>
" Christine Hiaring "' <chiaring @ utah. gov>
19 April, 2005 04:40 PM
March 7,2005 FMRI Amendment Request
Chris,
Attached are electronic versions of Jo Ann Tischler's two memoranda and associated schedules, which are Appendices 4 and 5
of the March 7,2005 FMRI license amendment application.
Please let me know if you need anything else?
Dave
To:
From:
Date:
Subject:
MEMORANDT]M
lnternational Uranium (USA) Corporation
Jo Ann Tischler
March 8,2005
Review of Chemical Contaminants in FMRI Inc. ("FMRI") Uranium
Materials to Determine Potential for Worker Safety or Environmental
Hazards, and Compatibility with Mill Tailings
Introduction
This report describes the results of my evaluation of the material (the "Uranium
Material") to be excavated from the Fansteel Metals Muskogee, Oklahoma facility to
determine whether processing the Uranium Material at the International Uranium (USA)
Corporation ("ruSA") White Mesa Mill (the "Mill") may pose any worker safety or
environmental hazards, or may be incompatible with the Mill's existing tailings system.
IUSA has applied for an amendment (the "Request for Amendment") to the Mill's State
of Utah Radioactive Materials License No. UT1900479 to permit the processing of
Uranium Material as an alternate feed material at the Mill.
The following report provides my evaluation of potential safety and environmental
hazards and compatibility with the Mill's tailings system. To perform this evaluation, I
have considered the following questions:
Will any constituents of the Uranium Material volatilize at the known conditions
on the Mill site or in the Mill circuit? If so, will they create any potential
environmental, worker health or safety impacts?
Will the Uranium Material or any of its constituents create a dust or off-gas
hazard at the known conditions on the Mill site or in the Mill circuit? If so, will
they create any potential environmental, worker health or safety impacts?
Will any constituents of the Uranium Material react with other materials in the
Mill circuit?
4. Will any constituents of the Uranium Material create any impacts on the tailings
system?
5. What, if any, limitations on feed acceptance criteria or added operational controls
are recommended in connection with processing the Uranium Material at the Mill
An evaluation of the regulatory status of the Uranium Material relative to RCRA
regulations is provided in a separate report.
l.
2.
3.
-FM 3.07.05 final.doc
1.0 Basis and Limitations of this Evaluation
The chemical component evaluation in this report is based on the following documents:
1. Radioactive Material Profile Record ("RMPR") for the WIP Feed (FMRI, 2005)
and attached Summary of Waste Chemistry Data(2119193)
2. Material Safety Data Sheet Revision 1.1 for Work in Process Sludge from Ponds 2
and 3 Residues (Fansteel, 021 14102)
Site history summary (2 pages) provided to IUSA by FMRI (FMRI 2004).
Material description, history, and location maps in excerpts from "Chapter 4.1
Pond Residues" in the NRC Site Decommissioning Plan.
Analytical data in "Tables 6 and 7: Summary of Waste Chemistry Data for Ponds
2 and3" provided by FMRL
Material description location maps, and analytical data from A Chemical
Comparison of Pond Residues with Estimates of Resources and Suggested Mining
M ethods (Appalachian Resources, September 12, 20A0)
Cover summary, radionuclide data and non-radioactive metals analytical data
from submittal entitled: Fansteel Materials for Processing and Storage (FMRI
2003)
Site History and Background
From 1960 to 1989, Fansteel Metals Recovery, Inc. ("FMRI") processed natural ores and
tin slag for recovery of tantalum and niobium (also called "columbium"), at the
Muskogee facility.
Before the FMRI operation was shut down in 1989, the facility purchased tantalum ore
and tin slag from around the world for recovery of tantalum. The feed material was
leached in concentrated hydrofluoric acid and sulfuric acid. The tantalum and niobium
were dissolved in the leach solution, and the insoluble fluoride compounds such as
thorium, radium, and uranium, remained behind in the solids. These solids were filtered
and collected in Ponds 2 and 3. The composition of the leached solids sent to Ponds 2
and 3 varied with the efficiency of the tantalum leaching process, but they contained an
average of approximately 0.8 weight percent tantalum and 0.15 weight percent uranium
(0.18 weight percent UrOa). The solids in ponds 2 and 3 consist mainly of the residual
metal impurities in the fluoride form.
In the historical process, tantalum and niobium were extracted from the acidic leach
4.
5.
6.
7.
2.0
liquid with methyl isobutyl ketone (MIBK). In the solvent extraction stage, the MIBK
was used to remove the impurities such as iron, zirconium and uranium while leaving the
tantalum in the "raffinate stream". After removal of the impurities, the tantalum was
precipitated to form KzTaFz (potassium heptafluorotantalate) and/or high-grade tantalum
oxides and tantalum metals. The remaining raffinate stream, containing little or no
tantalum but relatively high concentrations of hydrofluoric and sulfuric acids, was
neutralized with lime and sent to ponds 8 and 9. The materials in Ponds 8 and 9 will not
be shipped to the Mill.
The total volume of material to be processed at the Mill has been estimated to be
approximately 16,000 dry tons, but could be as much as 32,000 dry tons. As summarized
in the Radioactive Material Profrle Record, the FMRI Uranium Material can be expected
to have a uranium content of approximately 0.15 weight percent uranium (0.18 weight
percent UrOs) and approximately 0.36 weight percent natural thorium.
The Uranium Material to be processed at the Mill consists of the contents of Ponds 2 and
3, together with ancillary drummed Uranium Material, pond cover soils, as well as
surrounding soils, debris and other materials that have been impacted by the Pond 2 and 3
contents. All of the Uranium Material is currently situated on-site at FMRI. Both ponds
underwent repeated characterization studies during the period from 1989 to 2000. The
chemical contamination profile reported in the FMRI documents listed in Section 1.0
included nearly 300 samples from multiple locations and depths in Ponds 2,3 and 5. The
samples were analyzed for radionuclides, recoverable metal values, and RCRA regulated
organic and inorganic contaminants. These studies provided sufficiently representative
characteization to assess both the regulatory status and chemical and processing
properties of the Uranium Material. It is my understanding that Materials from Pond 5
are not intended to be included in the Uranium Material.
Assumptions Regarding White Mesa MiIl Processing of the Uranium
Material
My evaluation was based on the following process assumptions:
1. The Mill will process the Uranium Material in one campaign.
The Uranium Material will be delivered to the Mill in covered intermodal
containers ("IMCs") via truck, which will be unloaded onto the Mill's ore pad. It
will be temporarily stored on the ore pad, similar to conventional ores, pending
processing.
The Uranium Material will be added to the Mill circuit in a manner similar to that
used for the normal processing of conventional ores and other alternate feed
materials. It will either be dumped into the ore receiving hopper and fed to the
SAG mill, run through an existing trommel before being pumped to Pulp Storage,
or may be fed directly to Pulp Storage.
3.0
2.
4. The Mill does not anticipate any significant modifications to the leaching circuit
or recovery process areas for the processing of the Uranium Material.
5. The Uranium Material may be processed in combination with other approved
alternate feed materials.
4.0 Chemical Composition of the Uranium Material
The characterization data, and the RMPR provided by FMRI, resulted from numerous
sampling events conducted over more than a decade. The chemical contamination profile
included nearly 300 samples from multiple locations and depths in Ponds 2, 3 and 5.
These samples were analyzed for Volatile Organic Compounds ("VOCs"), Semivolatile
Organic Compounds ("SVOCs"), total metals, rare earths, Toxicity Characteristic
lcaching Procedure ("TCLP") metals, and radionuclides. As stated above, material from
Pond 5 will not be included in the Uranium Material to be shipped to IUSA.
While some of the FMRI studies attempted to develop a full chemical characterization,
others were focused on the commercially valuable constituents only. In addition, some of
the studies focused on the contents of the three ponds mentioned above, and some
included characteization of perimeter soils adjacent to the ponds. Hence, the sampling
studies did not involve analysis for, or detection of, all of the same parameters every time.
For conservatism and completeness, the evaluation in this report addresses every
constituent identified in any of the sampling studies, whether the sample was collected
from Pond 2 or 3 contents, or adjacent soils, and whether the constituent was detected
once or was confirmed in multiple analytical results.
Table 1, attached to this report, provides a list of all analytes detected in FMRI Ponds 2
and 3 and a sufirmary of the minimum and maximum concentration reported for each
analye. The classes of compounds in Table 1 are discussed in the remainder of this
section. The process compatibility information for each analyte shown in Table 1, will be
discussed in Section 5.0, below.
Table 2, attached to this report, provides a comparison of the Uranium Material
constituents to the constituents of the Mill's tailings system and to other ores and
previously approved alternate feeds. Column "B" of Table 2, attached to this report, sets
out the estimated average concentration for each analyte. Table 2 will be discussed in
Section 8.0, below.
4.1 Organic Constituents
4.1.1 Volatile Organic Compounds
Approximately 274 samples were analyzed for RCRA Volatile Organic Compounds
("VOCs"). Two polar, oxygenated VOC compounds, 4 methyl 2-pentanone, also called
methyl isobutyl ketone ('MIBK"), and acetone were identified in samples of Pond 2 and
Methyl Isobutyl Ketone
MIBK was used as an extractant in the post-leach steps of FMRI's tantalum circuit.
MIBK was reported in Ponds 2 and 3 at concentrations ranging from non-detectable to
1,300 mg/kg. The estimated average concentration, based on the arithmetic mean of the
reported values, was 4.1 m/kg. However, the actual average concentration in material
delivered to the Mill would be expected to be lower, for two reasons.
First, 207 of the 274 reported values were at or below the reporting level for the analytical
method. They were reported as "less than" a specific concentration value. To obtain a
numerical average, these values were estimated at half the distance between zero and the
reporting limit. For example, a value reported as "< 1600 uglkg (1.6 mg/kg)" was
estimated as 0.8 m/kg). This approach yields a very conservative mean, that is, it
overestimates the average contaminant concentration, and the actual average is likely to
be lower.
Second, the concentrations of MIBK were measured in-situ in ponds 2 and 3. MIBK is a
highly volatile compound that is readily vaporized at room temperature. The highest
concentrations of MIBK in the samples are associated with pockets of liquid in low spots
in the pond structures. As soon as material from these zones in the ponds is exposed to
air, MIBK would begin to volatilize. The MIBK levels would continue to decrease
appreciably during excavation, containerization, shipment, and unloading at the Mill.
Acetone
Acetone is a potential trace impurity in industrial grades of MIBK, and a common
component of mixed ketone formulations used as bulk extractants. Acetone is also a
common laboratory solvent and standard which is highly volatile and water soluble.
Acetone present in laboratory environments can readily contaminate aqueous samples,
and can interfere with gas chromatographic separation and analytical quantitation of other
ketones such as methyl ethyl ketone and methyl isobutyl ketone. As a result, acetone can
produce false positive results in analyses of samples with elevated levels of other ketones.
Acetone was not detected in any samples from Pond 2 and was non-detectable in all but
one anomalous sample from Pond 3, where it was reported as 81,000 ug/kg (81 mdkg).
Based on the known chemical behavior of acetone, and on the single anomalous reported
value, it is likely that acetone may not actually be present in the Uranium Material, but
has been detected as a result of laboratory influences on MIBK samples. For the purpose
of completeness and conservatism in evaluating the Uranium Material, in the analysis
below it was assumed that acetone was present.
In all but the one sample, acetone was reported as "less than" a specific concentration
value. To obtain a numerical average concentration, these "less than" values were
estimated at half the distance between zero and the reporting limit, as was described for
MIBK, above. For example, a value reported as "< 2,400 uglkg (2.4 mg/kg)" was
estimated as 1.2 mg/kg). This approach yields a very conservative mean, that is, it
overestimates the average contaminant concentration and, if acetone is actually present in
the Uranium Material, the actual average concentration is likely to be lower than
calculated by this method.
4.1.2 Semi-Volatile Organic Compounds
Di-n-butyl phthalate
Two RCRA Semivolatile Organic Compounds ("SVOCs") were reported above detection
limits in the 56 samples taken in ponds 2,3 and 5. Di-n-butyl phthalate was reported at
concentrations ranging from non-detectable to 1.35 mg/kg in the samples from all three
ponds, with an estimated arithmetic mean concentration of 1.1 mg/kg. Bis (2-ethylhexyl)
phthalate was reported only in samples from Pond 5. As mentioned above, material from
Pond 5 will not be included in the Uranium Material to be shipped to ruSA.
There is no history of industrial phthalate production or commercial phthalate use at
FMRI. Both bis (2-ethylhexyl) phthalate and di-n-butyl phthalate are common
plasticizers and may contaminate samples due to their presence in vinyl, butyl and other
plastic materials in sampling tools, label inks, packaging, and Personal Protective
Equipment ("PPE"). They are also ubiquitously present in many work environments
because they are known to be components of diesel exhausts from trucks, earthmoving
and excavation vehicles, and construction equipment.
According to the report accompanying the one set of pond characterization data in which
this compound appeared, the presence of phthalates was "believed to be associated with
plastic samples [sic] collection equipment." (NRC Site Decommissioning Plan, Section
4.1-2.3, Page 4-10) The evaluator considered the phthalates not to be actual constituents
of the pond contents. Based on the very low concentrations, which appeared in samples
associated with one sampling event, and on the site history, this conclusion is justified.
This conclusion is also consistent with IUSA's experience with alternate feed materials
from other sites.
Inorganic Constituents
4.2.2 Non-Metal Inorganic Compounds
Eight non-metal ions or compounds were identified in the FMRI Pond materials:
ammonia, chlorides, cyanides, fluorides, nitrates, phosphates, sulfates and sulfides. Two
different types of information from FMRI indicate that all these ions were present only in
inorganic, not organic, compound forms.
First, approximately 274 samples from the FMRI ponds were analyzed for RCRA-
4.2
Christine Hiarino - FMRlCom
regulated Volatile Organic and Semi-volatile Organic compounds, via EPA SW846
methods 8260 and 8270. These method lists include, among others, analysis for organic
compounds of all eight ions listed above. No organic compounds of these eight ions were
detected in any of the 8260 or 8270 VOC or SVOC sampling results.
Second, the analytical data that accompanied the RMPR reported all of these compounds
in one or more of the ASTM method inorganic analysis results.
It can be assumed that no hazardous (or non-hazardous) organic compounds of any of
these eight ions are present in the Uranium Material.
The ions with the highest concentrations in the Uranium Material, predictably, were
fluoride and sulfate, with order-of-magnitude concentrations ranging from 640 to 396,000
mg/kg (ppm), with an estimated average of 309,000 mglkg, and 52 to 10,800 mg/kg, with
an estimated average of 5,400 mglkg, respectively. Phosphate was reported at 12,900
m/kg. All other ions were present at much lower levels with order-of-magnitude
concentrations ranging from non-detectable to 500 mg/kg.
4.2.3 Metals
Nearly 300 samples from FMRI Ponds 2,3, and 5 were analyzed for total metals and rare
earth elements. According to the characterization reports and data, 38 non-radioactive
metals and metalloids were present in the ponds: aluminum, antimony, arsenic, barium,
beryllium, cadmium, calcium, cerium, chromium, cobalt, hafrrium, iron, lanthanum, lead,
magnesium, manganese, mercury, molybdenum, neodymium, nickel, niobium (also called
columbium), potassium, praseodymium, scandium, selenium, silicon, silver, sodium,
tantalum, thallium, thorium, tin, titanium, tungsten, vanadium, yttrium, zinc, and
zirconium. These can be categorized based on their elemental characteristics and
chemical properties as follows:
Class Comnonent of The Uranium Material
Alkal Metals Sodium. potassium
Alkal ne Earths Barium, beryllium, calcium, magnesium
Transition and Rare Earth
Metals
Antimony, cadmium, cerium, chromium,
cobalt, hafirium, iron, lanthanum, manganese,
mercury, molybdenum, neodymium, nickel,
niobium, praseodymium, scandium, silver,
tantalum, thallium, thorium, tin, titanium,
tungsten, vanadium, yttrium, zinc, zirconium
Other Metals Aluminum,lead
Metalloids Arsenic, selenium, silicon
Non-Metal Ions Ammonia, chloride, cyanide, fl uoride, nitrate,
phosphate, sulfate. sulfide
Metal analysis consisted primarily of metal and ionic chemistry. Only a few samples ln
some of the commercial studies involved were analyzed for actual mineral composition.
As a result, for most of the metals and ions, their exact compound form has not been
identified. Assumptions regarding their form, based on process knowledge and prior
experience with leached metal tailings, are discussed below.
For simplicity, in the following discussion, constituents will be addressed by category
wherever possible.
4.2.1 Assumptions Regarding Metals
Six species, aluminum, calcium, iron, niobium (columbium) silicon, and titanium, have
been identified as having at least some fraction of their total concentration present in
mono-, di- and tri-oxide forms. Since the FMRI process residuals were transferred to
Ponds 2 and 3 as aqueous acidic solutions, these cations would also be expected to be
present in the Ponds in hydrated forms such as hydroxides. In any case, all the metals
will be exposed to water sprays and aqueous acids as soon as they are introduced into the
IUSA Mill's leach circuit. Hence, any metals that were in oxide forms in the FMRI pond
materials would be converted to hydroxides and hydrates upon entering the Mill process.
FMRI process history indicates that many of the metal cations would be present in sulfate
or fluoride salts or complexes, as a result of reactions during the aggressive tantalum
leaching with sulfuric and hydrofluoric acid.
In existing tailings analyses for the Mill, as described in the draft Statement of Basis for
the Mill's Groundwater Discharge Permit and in characteization data for other alternate
feed materials licensed for processing at the Mill, all of these metals except hafrrium,
tungsten and scandium have been sampled for and detected in the Mill's tailings, or in
other alternate feed materials.
Samples of an intermediary uranium product have indicated that hafnium has also been
introduced into the Mill process with at least one previously processed alternate feed from
Cabot Corporation. Hafnium is in the same chemical class as zirconium and titanium (all
group V metals), and is often found in nature together with those metals. While Mill
tailings and feed characterization sampling studies to date have never analyzed for
hafrtium, it is expected that, given the existing levels of zirconium in the Mill's tailings
cells, hafnium has also been introduced into the Mill's circuit through other ores and
alternate feed materials in addition to the Cabot materials.
Likewise, Mill tailings and alternate feed characterization sampling studies to date have
not analyzed for tungsten. However, tungsten is in the same chemical class as chromium
and molybdenum (all Group VI metals) and is often found in nature together with those
metals. While Mill tailings and feed characterization sampling studies to date have never
analyzed for tungsten, it is expected that, given the existing levels of chromium and
molybdenum in the Mill's tailings cells, tungsten has also been introduced into the Mill's
circuit through other ores and alternate feed materials.
Mill tailings and alternate feed characterization sampling studies to date have also not
analyzed for scandium. However, scandium is in the same chemical class as yttrium and
lanthanum (all Group Itr metals) and is often found in nature together with those metals.
While Mill tailings and feed characteization sampling studies to date have never
analyzed for scandium, it is expected that, given the existing levels of yttrium and
lanthanum in the Mill's tailings cells, that scandium has also been introduced into the
Mill's circuit through other ores and alternate feed materials. IUSA personnel have also
advised me that the Cabot alternate feed materials also contained scandium, although
characterization data for scandium in the materials was not available at the time of
writing this report.
It is reasonable to say, therefore, that all metals in the Uranium Material have very likely
been introduced into the Mill previously, either in natural ores or in previously licensed
alternate feeds, with no adverse effects to the process.
5.0 Potential Effects in Mill Process
The behavior and chemical compatibilities of the known or expected forms of each of the
constituents in the Uranium Material are listed in detail in the table in Attachment l. The
incompatibilities identified in MSDS and NIOSH guidance, and listed in Table 1, are
applicable to pure products and concentrated mixtures or solutions of the respective
compounds. As discussed above, most of the metal species in the Uranium Material are
present at ppm levels or lower (or at percent levels in the highest case). The
concentrations of these constituents will be further reduced by introduction into the leach
circuit, where they will be present at fractional ppm levels or lower in large volumes of
aqueous acid solution.
The majority of the metal oxides, hydroxides, hydrates, and other mineral salts will be
converted to sulfate salt forms in the leach system. The insoluble forms will be
precipitated with the solids removed from the post-leach thickeners in the counter-current
decantation ("CCD") circuit.
All the known components in their anticipated oxidation or mineral states are compatible
with aqueous sulfuric acid, which will be used for leaching the Uranium Material. All the
known components in their anticipated oxidation or mineral states are compatible with all
other chemicals and materials to which they may be exposed in the Mill.
Since the metals, oxides, hydroxides, hydrates and other salts are expected to be
converted to insoluble sulfates, it can be assumed that the non-uranium constituents that
enter the leach system will leave the leach system, proceed no further than the CCD step,
and be discharged from this circuit to the tailings.
Some of the metal oxides, in the forms in which they will enter the Mill, are known to
decompose at high temperatures, breaking down into volatile lower oxide forms (such as
AszOs decomposing to a trioxide). However, as described above, the metals and metal
10
3.07.05 final.doc 11
oxides will be short-lived in the process, as they will be converted into sulfates in the
leach acid. The metals and their oxides will not be exposed to any conditions that can
produce gaseous byproducts. The sulfate forms are stable and non-reactive and will be
precipitated from the circuit in post-leach steps and discharged to the tailings system.
Reactivity and incompatibility information from Table I and its sources is summarized by
class of contaminant, below.
5.1 Alkali Metals
Although in some circumstances, the introduction of alkali metal oxides in sufficient
quantities into an acid leach circuit has the potential to result in unwanted excess
chemical reactivity, this situation will not result from processing the Uranium Material at
the Mill, for the reasons described below.
Manufacturers' MSDS and NIOSH safety hazard information indicate that the oxides of
the alkali metals, sodium and potassium, are reactive with water. The oxides and
hydroxides dissolve in water with an exotherm (generation of heat energy) if they are
present as pure or high concentration product (percent levels or more).
These constituents will only be present at low levels (less than I percent) in the ore feed
area. As described in Section 3.0, this material will be introduced into the Mill through
the SAG mill or trommel, which have water-based dust control systems, or directly into
aqueous solution ins pulp storage. These low levels will not pose a heat of reaction
hazmd with the water rates in the dust-control system or pulp storage. Moreover, any
water reactivity will also be quenched immediately by the large volume of aqueous
sulfuric acid solution in the leach system.
5.2 Alkaline Earths
Although in some circumstances, the introduction of oxides of alkaline earths in
sufficient quantities into an acid leach circuit has the potential to result in unwanted
excess chemical reactivity, this situation will not result from the processing of Uranium
Material at the Mill, for the reasons described below.
Manufacturers' MSDS and NIOSH safety hazard information indicate that the oxides of
the alkaline earths - magnesium, calcium, barium, and beryllium -- are reactive with
water. Their oxides and hydroxides dissolve in water with an exotherm (generation of
heat energy) if they are present as pure or high concentration product (percent levels or
more).
Magnesium, barium and beryllium will only be present at ppm levels in the ore feed area.
These low levels will not pose a heat of reaction hazard with the water rates in the dust-
control system. Any water reactivity will also be quenched immediately by the large
volume of sulfuric acid solution in the leach system. These oxides also decompose under
n
heat to generate hazardous byproduct gases. However, these materials will not be
exposed to heating conditions during processing at the Mill. As explained in Section 5.0,
above, the metals or metal oxides are expected to be converted to their sulfate salts in the
leach system, and be precipitated with solids removed from the post-leach thickeners in
the counter-current decantation ("CCD") circuit. That is, these metals will proceed no
further than the CCD thickeners before they are discharged to tailings. They will not
proceed with the uranium through its subsequent steps of concentration, precipitation,
dewatering and drying, and so will have no opportunity for exposure to elevated
temperature.
Magnesium oxide is also incompatible, due to strong reactivity, with halogen gases.
However, the Uranium Material will not be in contact with halogen gases at any time
during processing at the Mill.
Calcium will be present at percent levels in the feed. It should be noted that, due to the
high concentrations of hydrofluoric and sulfuric acids used in the FMRI process, calcium
will be present in the form of calcium fluoride and calcium sulfate, not as its oxide.
These calcium salts will also be precipitated with solids removed from the post-leach
thickeners in the CCD circuit. Calcium will proceed no further than the CCD thickeners
before it is discharged to tailings. It will not proceed with the uranium through its
subsequent steps of concentration, precipitation, dewatering and drying, and so will have
no opportunity for exposure to elevated temperature.
Transition Metals and Rare Earths
No incompatibilities have been reported for the lanthanide rare earths lanthanum, cerium,
praseodymium, and neodymium, or the actinide rare earth, thorium. These metals and
their oxides are insoluble in water and slightly soluble in and compatible with acids and
alkalis. They will be converted to sulfates in the leach system, and will be precipitated
and discharged to the tailings.
Chemical behavior and incompatibilities for the transition metals vary, so they are
discussed individually in this sub-section.
Although in some circumstances, the introduction of oxides of the transition metals in
sufficient quantities into an acid leach circuit has the potential to result in unwanted
excess chemical reactivity, this situation will not result from processing the Uranium
Material at the Mill, for the reasons described below.
Antimony oxides are insoluble in water and soluble in and compatible with acids and
alkalis. They will be converted to sulfates in the leach system, and will be precipitated
and discharged to the tailings. They do not pose any incompatibility hazards in the Mill
process.
Oxides of chromium are oxidizers themselves, and are incompatible with combustible
5.3
t2
organic materials, due to the potential for ignition. However, chromium oxides are only
present at trace levels and will be precipitated and discharged from the system before the
aqueous streams are contacted with organic hydrocarbons in subsequent uranium
concentration steps. That is, they will not be in contact with organic materials.
Cadmium oxide is reactive with pure product magnesium. It also decomposes at elevated
temperature to release cadmium fumes. As described above, the metal compounds in the
Uranium Material will be present as oxides, fluorides, sulfates, hydroxides and hydrates,
not as pure products. Cadmium, if it is at all present in the oxide form, will not be in
contact with pure metal magnesium. Cadmium and its oxides are soluble and stable in
acids, will be converted to sulfates in the leach system, will be precipitated and
discharged to the tailings, and will not be exposed to elevated temperature at any time in
the Mill process.
Cobalt, scandium, and their oxides are insoluble in water and slightly soluble in and
compatible with acids and alkalis. They will be converted to sulfates in the leach system,
and will be precipitated and discharged to the tailings. They do not pose any
incompatibility hazards in the Mill process.
Molybdenum and yttrium as pure metals are incompatible with strong oxidizers.
Molybdenum and yttrium are not present as pure metals, but as fluorides, sulfates and
other inorganic complexes at trace levels (less than I ppm to less than 1 percent) in the
Uranium Material.
As metal compounds, molybdenum and yttrium have no reported incompatibilities.
Molybdenum and yttrium will be converted to sulfates, or be precipitated as other
insoluble compounds in the leach system, and will be discharged to the tailings. They do
not pose any incompatibility hazards in the Mill process.
Tunsgten, as a pure metal, reacts with fluorine gas, and other complexed halofluorides,
such as bromine trifluoride, chlorine trifluoride, and iodine pentafluoride. Tungsten in
the Uranium Material will be introduced into the Mill process as a fluoride or sulfate salt,
not as a pure metal. The Uranium Material will not be exposed to fluorine gas or any
halofluorides at any time in the Mill process.
Some zirconium compounds at high concentrations will react with potassium nitrate, and
are incompatible with strong oxidizers. Zirconium is present in the Uranium Material at
levels from 2.4 to 6.6 percent. The Uranium Material will not be in contact with
potassium nitrate atury time in the Mill process.
Zirconium, as well as hafrrium, may be incompatible with strong oxidizers.
The Mill sometimes adds oxidants to the leaching system to improve uranium recovery
from some types of feeds. Sodium chlorate, the typical oxidizing agent used in the Mill's
leach circuit, is a moderately effective oxidizer, but not a strong oxidizer. It will be
t3
3.07.05 final.doc 14
introduced in relatively weak aqueous solution in the leach system, not in concentrate. If
the zirconium, the hafnium or the oxidizer were present at sufficient concentrations to
react, any exothermic heat generated from the reaction would be quenched by the large
volumes of aqueous acids in the leach system.
Hafnium is also known to react with free or gaseous chlorine. Hafnium will not be
exposed to chlorine gas or free chlorine at any time in the Mill process.
Niobium (also called columbium) as pure metal reacts with oxygen and halogens at high
temperatures. It is reactive with hot concentrated hydrochloric, sulfuric or phosphoric
acid, and with most alkaline solutions.
The Uranium Material will not be exposed to high temperature oxygen, halogens,
hydrochloric or phosphoric acid, or alkaline reagents at any time in the Mill process. It
will be leached with sulfuric acid. However, niobium is not present as a pure metal, but
as very low concentration metal salts and complexes that have already been exposed to
sulfuric acid. Niobium salts are soluble and compatible with the materials in the leach
system,
Tantalum metal and its oxides are incompatible with bromine trifluoride, fluorine gas,
and strong oxidizers. The Uranium Material will not be exposed to fluorine gas or
bromine trifluoride at any time in the Mill process.
As explained above, sodium chlorate, the typical oxidizing agent used in the Mill's leach
circuit, is a moderately effective oxidizer, but not a strong oxidizer. It will be introduced
in relatively weak aqueous solution in the leach system, not in concentrate. Tantalum is
present at low levels in the Uranium Material, ranging from 0.2 to 5 percent, and
averaging I percent or less, and is not sufficiently concentrated to react with a weak
solution ofoxidizer.
Oxides of iron are reactive with calcium
hydrogen peroxide. The Uranium Material
materials at any time in the Mill process.
hypochlorite, carbon monoxide gas, and
will not be in contact with any of these
Other compounds of iron, (chlorides, sulfates, etc.) are compatible with the solutions in
the leach circuit. They will be precipitated as sulfates or other insoluble salts, and
discharged to the tailings. They do not pose any incompatibility hazards in the Mill
process.
hon is one of the primary constituents of natural uranium ore rock, other natural mineral
ores, and uranium-bearing contaminated soils processed as alternate feeds at the Mill, as
evidenced by the known concentration of iron of up to 213,000 ppm (21.3 percent)
already in the Mill's tailings solids.
Manganese and its oxides are not soluble in water but are soluble in strong acids. They
t4
will be converted to sulfates in the leach system, and will be precipitated and discharged
to the tailings. They do not pose any incompatibility hazards in the Mill process.
Mercury and its oxides are insoluble in water, alcohol, and ethers, but are soluble in acids.
They will be converted to sulfates in the leach system, and will be precipitated and
discharged to the tailings. They do not pose any incompatibility hazards in the Mill
process.
Nickel and its oxides are reactive and incompatible with gaseous iodine and hydrogen
sulfide. The Uranium Material will not be in contact with either of these materials at any
time in the Mill process.
Silver oxide poses a fire and explosion risk in contact with organic materials and
ammonia. Silver oxides will not be in contact with organic materials or ammonia at any
time in the Mill process. Insoluble salts of silver will be precipitated with solids removed
from the post-leach thickeners in the CCD circuit. That is, these metals will proceed no
further than the CCD thickeners before they are discharged to tailings. They will not
proceed with the uranium through its subsequent steps ofconcentration and precipitation.
Although concentrated uranium acidic brines are precipitated with ammonia at this later
phase, the insoluble silver salts will have been removed to tailings as solids long before
the aqueous uranium stream proceeds to ammonia precipitation. Hence, any silver will
have no opportunity for contact with ammonia.
Because the Mill has produced vanadium pentoxide as a cofirmercial product, vanadium
and its oxides have been handled in all proportions in the Mill in both the leaching and
dryrng circuits.
Thallium oxides are soluble in water and alcohols. They will be converted to sulfates in
the leach system, and will be precipitated and discharged to the tailings. Although
thallium oxides can be reactive with air, thallium oxides in the Uranium Material will not
be directly exposed to air in the Mill process for the following reasons. The Uranium
Material has already been conditioned with aqueous agents, and is no longer a dry
powder. The Uranium Material will be introduced into the Mill circuit through an
unloading system that incorporates water spray dust suppression. It will then be
transferred directly into the leaching circuit where it will be contacted with large volumes
of aqueous sulfuric acid solutions, where the thallium oxide will be converted from oxide
to sulfate form, and will pose no process hazard.
Tin and its oxides are insoluble in water but soluble in strong acids. They will be
converted to sulfates in the leach system, and will be precipitated and discharged to the
tailings. They do not pose any incompatibility hazards in the Mill process.
Titanium and its oxides are stable and insoluble in water, and most acids and bases, at
ambient temperatures. They will be converted to sulfates in the leach system, and will be
precipitated and discharged to the tailings. They do not pose any incompatibility hazards
l5
in the Mill process.
Zinc and its oxides are stable and insoluble in water, but soluble in most acids and bases,
at ambient temperatures. They will be converted to sulfates in the leach system, and will
be precipitated and discharged to the tailings. They do not pose any incompatibility
hazards in the Mill process.
5.4 Other Metals
Although in some circumstances, the introduction of oxides of aluminum and lead in
sufficient quantities into an acid leach circuit has the potential to result in unwanted
excess chemical reactivity, this situation will not result from processing the Uranium
Material at the Mill, for the reasons described below.
Manufacturers' MSDS and NIOSH safety hazard information indicate that the metals
aluminum and lead and their lower oxides, are incompatible with strong oxidizers,
halogen gases, and some acids.
The Mill sometimes adds oxidants to the leaching system to improve uranium recovery
from some types of feeds. Sodium chlorate, the typical oxidizing agent used in the Mill's
leach circuit, is a moderately effective oxidizer, but not a strong oxidizer. It will be
introduced in relatively weak aqueous solution in the leach system, not in concentrate.
Aluminum and lead are also present at very low levels, with concentrations ranging from
nearly non-detectable to 2,000 ppm. Hence, hazards associated with reactions between
lead, aluminum, or their lower oxides with strong oxidizers are not applicable to the
processing of Uranium Material.
As mentioned previously, the Uranium Material will not be in contact with halogen gases
at any time in the Mill process.
The oxides of lead and aluminum react aggressively with strong mineral acids such as
nitric and sulfuric acids. Sulfuric acid used at the Mill is a relatively weak acid and not
an oxidizing acid. Aluminum oxides would be converted to sulfates in the leach step and
removed from the system with other precipitated solids to the tailings system.
5.5 Metalloids
The oxides of silicon do not present any potential chemical incompatibility hazards. They
have been introduced into the Mill circuit and the tailings system, as the inert fraction of
ores, and the soils fraction of alternate feeds, at comparable or higher levels than in the
Uranium Material.
Although in some circumstances, the introduction of oxides of arsenic in sufficient
quantities into an acid leach circuit has the potential to result in unwanted excess
chemical reactivity, this situation will not result from processing the Uranium Material at
t6
Christine Hiaring - FMRI 3.07.05 final.doc Page 17
the Mill, for the reasons described below.
The oxides of the metalloid arsenic are reactive with halogens like bromine trifluoride,
reducing agents, and with some other metals in water. The Uranium Material will not be
in contact with halogen gases or reducing agents at any time in the Mill process.
Higher arsenic oxides (like AszOs) also decompose in heat to evolve gases of lower
oxides. As described above, arsenic compounds will proceed no further than the CCD
thickeners before they are discharged to tailings. They will not proceed with the uranium
through its subsequent steps of concentration, precipitation, dewatering and drying, and
so will have no opportunity for exposure to elevated temperature.
The Uranium Material will not be in contact with reducing agents or halogen gases at any
time in the Mill process.
5.O Non-Metals
Phosphorus has been identified as present in phosphate mineral form. Although in some
circumstances, the introduction of sufficient quantities of phosphate into an acid leach
circuit has the potential to result in unwanted excess chemical reactivity, this situation
will not result from processing the Uranium Material at the Mill, for the reasons
described below.
Phosphates are soluble in water and acidic solutions, and are reactive with bases and
perchloric acid. The Uranium Material will not be in contact with bases or perchloric
acid at any time in the Mill process. Perchloric acid is used in the Mill's analytical
laboratory for uranium assay of ores. However, the laboratory's fume hoods are
sufficient for management of the minimal potential off-gassing from reaction of trace
phosphate with assay reagents.
Cyanides may be present as trace potassium cyanide or sodium cyanide salts. Cyanide
salts are incompatible with strong oxidizers such as chlorates or nitrates. The Mill
sometimes adds oxidants to the leaching system to improve uranium recovery from some
types of feeds. Sodium chlorate, the typical oxidizing agent used in the Mill's leach
circuit, is a moderately effective oxidizer, but not a strong oxidizer. It will be introduced
in relatively weak aqueous solution in the leach system, not in concentrate. Cyanide itself
is also present at very low levels, with concentrations ranging from non-detectable to 160
ppm.
Hence, hazards associated with reactions between cyanides and strong oxidizers are not
applicable to the processing of Uranium Material.
Cyanides have been introduced into the Mill circuit with other alternate feeds at levels
from I to I l0 mglkg, comparable to levels reported in the Uranium Material, and have
been managed with no process, environmental, or safety issues.
t7
li 9! ri*in* [iln r! ns-:. f-M"F 3.07.05 final.doc " .. - , .,."."- ,.-" ,-......".-"Hns,F- -1-p.:l
Nitrates have been introduced into the Mill's uranium circuit with natural ores and
alternate feeds at levels as high as 350,000 mg/kg. The Mill has handled nitrate
compounds in the Mill circuit and tailings system with no process, environmental, or
safety issues.
Chlorides have been introduced into the Mill's uranium circuit with natural ores and
alternate feeds at levels as high as 89,900 m/kg. The Mill has handled chloride
compounds in the Mill circuit and tailings system with no process, environmental, or
safety issues.
Fluorides have been introduced into the Mill's uranium circuit with natural ores and
alternate feeds at levels as high as 460,000 mg/kg. The Mill has processed previous
alternate feeds, such as several of the materials from Cabot, Cameco, and Allied Signal,
with levels of calcium fluoride and other metal fluorides as much as 30 times higher than
those in the Uranium Material. The Mill has handled these fluoride compounds in the
Mill circuit and tailings system with no process, environmental, or safety issues.
Sulfates have been introduced into the Mill's uranium circuit with natural ores and
alternate feeds at levels as high as 300,000 m/kg. Sulfates are also generated by the
reaction of sulfuric acid with other metal cations in the leach circuit. The Mill has
handled sulfate compounds in the Mill circuit and tailings system at all proportions with
no process, environmental, or safety issues.
Ammonia was reported at very low levels, from26 to 178 ppm. Anhydrous ammonia gas
or high concentration ammonium hydroxide solutions are incompatible with strong
oxidizers, halogen gases, acids, and salts of silver and zinc. Ammonia is present as low
concentration aqueous ammonium salts (chlorides and sulfates) and as mineral
complexes, and will not be present as anhydrous ammonia gas or high concentration
ammonium hydroxide.
The ammonium compounds will not contact halogen gases at any time in the Mill
process. They are not present in the reactive form (ammonia or ammonium hydroxide),
and are at concentrations too low to react with the silver and zinc already present in the
Mill tailings, or with the moderate oxidizer that may be added in the Mill leach circuit.
The RMPR indicated that sulfides were present in the Uranium Material. The analytical
data does not indicate what fraction of sulfur in the FMRI ponds composition is present in
the sulfide form. The analytical data accompanying the RMPR itself does not report
sulfide in any of the ion-specific ASTM analyses.
The Mill has previously processed alternate feeds with sulfide levels as high as 11,400
ppm with no process, environmental, or safety issues.
5.7 Organic Compounds
18
-F 3.07.05 final.doc
MIBK is a volatile polar organic compound with a boiling point of Il7'C (242'F) and a
flash point of 64"F. MIBK is highly water-soluble. The arithmetic average of all the
MIBK concentration data reported indicates MIBK may be present at an average of 4
m/kg. At the concentrations detected, MIBK poses no unusual unloading or handling
hazards, and is miscible and compatible with alcohols, aqueous acids, and the kerosene
hydrocarbons utilized in the Mill.
As discussed in Section 3.0 above, the reported MIBK concentrations were from in-situ
samples at FMRI. Due to its volatility, MIBK will vaporize during excavation, loading
shipping and unloading at the Mill, and the resulting concentration of MIBK in the
Uranium Material at the point of introduction in the Mill circuit will be significantly
lower than the values reported in-situ in the FMRI ponds.
Acetone is a volatile polar organic compound with a boiling point of 56.5'C (134"F) and a
flash point of -20"C (-4"F). The single detection of acetone was at 8l mglkg and the
conservative arithmetic average of all the acetone non-detection data with this data point
is 0.012 mglkg. For reasons discussed in Section 4, above, acetone may not be present in
the Uranium Material. Based on its extreme volatility, even if acetone were present in the
Uranium Material, it would be volatilized to non-detectable levels before reaching the
Mill. This conclusion is consistent with situations (such as the Tonwanda FUSRAP site
alternate feed materials) in which acetone was reported as a single detection or at trace
levels in situ at its original site. Confirmatory samples collected on the Mill's ore pad
after unloading did not confirm the presence of any acetone in those alternate feeds at the
Mill site. H acetone were present, at the concentration reported, it poses no unusual
unloading or handling hazards, and like MIBK, is miscible and compatible with the
process chemicals utilized in the leach circuit.
6.0 Potential Worker Safety Issues
According to manufacturers' Material Safety Data Sheets ("MSDSs") and the NIOSH
literature, the primary worker health hazards from the metal oxides are associated with
inhalation of dusts and fines. The oxide dusts of the lower metals are as hazardous as
those of uranium. However, the Uranium Material is expected to have an average
moisture content of approximately 3OVo, which will minimize the potential for dusting. If
required, normal dust controls utilized at the Mill can be implemented to minimize any
worker exposure to dusts from package unloading. In addition, normal operations in this
area require the use of worker personal protective equipment for prevention of dust
inhalation and skin exposure; therefore, normal worker protections already in place will
be sufficient to prevent exposure to any additional metal oxides, sulfates, phosphates,
nitrates or cyanides during processing of the Uranium MateriaL
According to manufacturers' MSDSs and the MOSH literature, the oxides and
l9
Christine 3.07.05 final.doc
hydroxides of the alkali metals (sodium and potassium) are severely corrosive to human
tissue (skin, eyes) and generate corrosive solutions of very high pH when exposed to
water. However, these materials will be introduced into the Mill in the leach system
where acidic solutions (sulfuric acid and tailings) are circulated, at levels which will
counter the alkalinity of any of these materials. In addition, normal operations in this area
require the use of worker personal protective equipment for prevention of exposure to
acidic solutions; therefore, normal worker protection already in place will be sufficient to
prevent eye or skin exposure injuries from caustic sodium or potassium solids or
solutions.
MIBK is hazardous by inhalation, and has an OSHA PEL of 100 ppm in air. At elevated
concentrations, MIBK is flammable, with an LEL in air of 1.2 percent, and a UEL of 8
percent. At elevated temperatures, 860'F or higher, pure MIBK and high concentration
solutions may self-ignite.
MIBK was detected at levels that were several hundred times lower than would be
required to generate either a respiratory hazard and several thousand times lower than
would be required to generate an explosive hazxd in air. At these levels, it requires no
PPE beyond the dust mask and skin protection currently employed at the Mill.
Engineering controls-air circulation fans operating in the acid leach and extraction
circuit areas -- which were designed to manage acid fumes, kerosene vapors and alcohols,
are sufficient for managing the minimal vapors from the low concentration of MIBK
reported in the FMRI data.
Acetone's inhalation and flammability hazard properties are very similar to those ofMIBK. However, if acetone were actually present at the conservative average
concentration estimated in Section 4, above, which is 2,000 times lower than that of
MIBK, its concentration would be too low to generate any detectable level in air.
7.0 Potential Air Emissions Impacts
The introduction of a solid powder like the Uranium Material to any process may produce
two potential forms of air emissions: fugitive dusts, and/or hazardous gases. Discussions
in the previous sections demonstrate that engineering controls already in place at the Mill
will prevent the generation or dispersion of both of these types of emissions. First, the
Uranium Material will be stored in fabric bags while on the ore storage pad at the Mill.
As a result, the dispersion of dust will not be an issue prior to introduction of the
Uranium Material into the Mill process. Second, the Uranium Material will have a
moisture content of approximately 30Vo, which will minimize dusting of finely divided
and powdered altemate feed materials. In addition, if required, normal dust controls
utilized at the Mill can be implemented for further dust control. Third, as described in
Section 5.0, the impurities will almost immediately be converted from volatile oxides to
sulfates or other stable aqueous ionic forms, which are non-volatile and produce no off
20
gases.
Because the metals and ions in the Uranium Material are present at fface levels, they are
not expected to ge,nerate a significant increase in load on the existing bag-house system
and air pollution control devices even if they reach the air control system as solids from
spills in the preJeach area.
21
3.07.05 final.doc
8.0 Potential Effects on Tailings System
Table 2, attached, provides a comparison of every chemical constituent reported in the
Uranium Material with all the reported constituents currently in the Mill's tailings system.
As described above, it is expected that most of the metal and non-metal impurities
entering the leach system with the Uranium Material will be converted to sulfate forms,
precipitated, and eventually discharged to the tailings system.
As shown in Table 2, every metal and non-metal cation and anion component in the
Uranium Material is expected to already exist in the Mill's tailings system. Every
component in the Uranium Material has been:
1,detected in analyses of the tailings cells liquids;
detected in analyses of tailings cells solids;
detected in analyses of alternate feed materials licensed for processing at the Mill;
4. detected in process streams or intermediate products when previous alternate
feeds were processed at the Mill; or
5. in the case of tungsten, scandium, and hafrrium, not sampled for to date, but
assumed to accompany other comparable metals and rare earths which have been
detected in the Mill's tailings,
at concentrations that are generally comparable to or higher than the concentrations in the
Uranium Material In no circumstances does the Uranium Material increase the
concentration of any analyte in the Mill's tailings significantly. The only five analytes
that have higher concentrations in the Uranium Material than in the Mill's tailings or in
other alternate feed materials are cadmium, manganese, potassium, sodium, and titanium,
none of which is expected to increase its concentration in the Mill's tailings by more than
0.10 percent.
The constituents in the Uranium Material are expected to produce no incremental
additional environmental, health, or safety impacts in the Mill's tailings system beyond
those produced by the Mill's processing of natural ores or previously approved alternate
feeds. Since the impacts of all the impurities on the tailings system are already
anticipated for normal Mill operations, and permitted under the Mill's license, they have
not been re-addressed in this evaluation.
9.0 ConclusionsandRecommendations
All of the chemical contaminants in the Uranium Material are acceptable at the Mill at the
levels indicated in the Characterization Data Summary, with no process impacts. Based
on the available data, it is reasonable to conclude that the Mill has already processed
2.
22
1.
alternate feeds containing all of the same elemental constituents, at generally comparable
or higher concentrations than are exhibited in the Uranium Material. In the few cases
(cadmium, manganese, potassium, sodium, and titanium) where the concentration of an
analyte in the Uranium Material exceeds the current concentration for that analyte in the
Mill's tailings and in other alternate feed materials that have been licensed for processing
at the Mill, the expected impact on the tailings is insignificant (an increase in
concentration ofeach such analyte in the tailings of0.10 percent or less).
While the presence of elevated levels of certain constituents may involve some additional
material management requirements during processing, these are requirements that the
Mill has successfully implemented in the processing of previous alternate feeds. For
example, the Mill has successfully processed and recovered uranium from uranium-
bearing salts, calcium fluoride precipitates, recycled metals, metal oxides, and calcined
product, all of which posed potential chemical reactivity and material handling issues
comparable to or more significant than those associated with this altemate feed.
Furthermore, the Cabot alternate feed materials were similar residues from
tantalum/niobium ore processing, with similar radiological and chemical characteristics.
Based on the foregoing information, it can be concluded that:
All the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, already present in the Mill tailings system or were reported in other
alternate feeds processed at the Mill, at levels generally comparable to or higher than
those reported in the FMRI ponds. In the five cases where the concentrations of an
analyte were higher in the Uranium Material than in the Mill's tailings and in other
alternate feed materials licensed for processing at the Mill, the difference in
concentration is not significant.
All the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, previously introduced into the Mill process, with no adverse effects to
the process, or worker health and safety.
All the known impurities in the Uranium Material have either been reported to be, or
can be assumed to be, previously introduced into the Mill tailing impoundments, with
no adverse effects to the tailings system, or human health and safety.
The one SVOC reported in pond samples has been attributed by the analyst and
evaluator as resulting from sampling equipment and is not an actual contaminant in
the pond Uranium Material.
The Mill has processed alternate feeds with ketones (acetone, methyl ethyl ketone
e.g.) more volatile and mobile than the MIBK reported in FMRI samples. MIBK is
present in the FMRI ponds at concentrations comparable to and lower than the levels
of the lighter, more volatile ketones already processed in other alternate feeds at the
Mill. Acetone may not be present in the Uranium Material. If its single detection was
2.
J.
4.
5.
23
real, its level is 2,000 times lower than the MIBK.
6. There will be no significant incremental environmental impacts from the processing
of Uranium Material beyond those that are already anticipated in the Environmental
Impact Statements for the Mill.
7. Spill response and conffol measures designed to minimize particulate radionuclide
hazards will be more than sufficient to manage chemical hazards from particulate
metal oxides.
Jo Ann Tischler
Consulting Chemical Engineer
cc: David C. Frydenlund
24
TABLE I (Rev.0): SUMMARY OF POIENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON.METALS IN FMRI PONDS
CoIlrurcial
Chericals
Acutely Toric
U List
uollrercial
Chemicals
Acut.ly H@rdous
P List
Sourcs
I. Lisa
Soun6
K Lisl
lndEtrial Us and Sow6 of U or P
Lisaed Elerent or Compound
ls This Listlng Applicablc to
FMRI MAieriel?
NONF Not,I
NONE
NONE
NONF No K Listinps
Collmrcial
Chenicals
Acutely Toxic
tl Lisr
Chenicals
Acutaly tl@rdous
P List
NOn-Sp
Sourcc
F List
spocnra
Sourcs
K List
Indctrial Usand SourcE of U or P
Listed Elcmnt or Compou[d
Is Thls Llsting Appli(eblc to
FMRI Material?
Thallium chloridc
Chlorinalion catalyst, sun lamp mnitor No. Thcrc would bc no Eaen for $is compouDd to bc
prcsnt as purc prcduct, bypoduct, or ollspec pDduct on
sib-
Cymogen chloride
Orgmic synthcsis, teareas, waming ag€nt rn
lirmigmt gccs.
No. Thcrc would bc no E*on for this compound to be
psent 6 puE prduct, byproduct, or off-spcc prcduct oo
Calbonic dichloride
(Dh6eenc)
Used in omanic synthesis ,br production of
urcthiles, pldtics dd pcsticidcs. Fomrly
used x chokinp a€ni in mmtlat oas
No P UstiDgs
NONE No FListings
NONE No K hsunss
CYANIDES
Cot1mrclal
Chcdcals
Acutely Toxic
U List
uoltrerclu
Chetrtcals
Acutely Hurdo6
P Lisr
Non-Spccilic
Soum6
F List
SFrlfic
Sourc6
K Llst
lndstrial Us and Sourc6 ol U or P
Listed Elernt or Compound
Is This Listing Applicable to FMRI Pond Material?
u246
Cymogcn bomide
Orgmic synthcsis. rcdenticide.
pdditicide, tumigating ompound, md
No. Therc would bc no rcoon for this compound to bc
prcscnt u Frrc product, blpmduct, or off-spe prcduct on
H)21
Calcium cyoide
Rodcnticide, fumigant for gr@niouses,
flour mills, grain, sed, md cittus tMs,
gold lcaching, and synthesis ofother
No. Thete would bc no reasoD fbr this compound to bc
prcsent 6 purc prduct, byproduct, or off-sp€ pmduct on
P029 Coppcrcyanidc El@tmplaling coppcr onto iM, and as
o orguic synlhBis intcmediatc.
No. Therc would be no rcason lbr this compound to bc
prcscDt as purc prduct, byprcduct, or off-sp@ product on
site-
Page I
Christine Hiaring - FMRlRCHATablel .05 final.doc Page 2
TABLE I (Rev.0): SLIMMARY OF POIENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX YII
ASSOCIATED WITH NON.METALS IN FMRI PONDS
P030
Cymides
GencEl class of compounds containing
cyanide (CN) grcup. Includes other
comp@nds listed by individual names in
this hble.
No. These products my havc b€n uscd in the tmtdum
pMessing circuit, which wu exempt from RCRA during
the tinE pcriod the pond mat.rial wss accumulated. FMRI
he also ontinned that no U listinSs apply, beausc no
spent, aged, or off spec slvent ftom lab or pmess was cvcr
dis'm€d in ti'e mnds.
m3t
Cymogcns
Organic synthesis, welding md cu$ing
gas, fumigant, Mkct pEp€llmt.
No. Therc would be no Edon for this compound lo bc
prcsent as puE prcducl, byprcduct, or off-spec pDducl on
P033
Cyanogen chloride
Orgmic synthesis, tear gas, wming
agcnt in fumigant gas6.
No. lherc would b Do rcilon lbr thts compound to be
prent 6 Brrc product, byproduct, or off-spe prcduct on
PO63
Hydrcyoic acid
Manufacturc of acrylonitrile, acrylaEs,
adipooitrilc, cyanidc salts, dyes, chelatd,
rodenticides, od pcsticidcs.
No. Ihese prcducts may have ben used in the tantalum
pmessing circuit, which wc exempt fmm RCRA during
the rire period the pond material was ammulated. FMRI
h6 also onfimed thal no U listings apply, beause no
spent, aged, or off sp@ solveDt fEm lab or prcess was cverdicm.d in th. mnd<
P074
Nickel cymide
Uscd in rctallurgy m innickel plating No. Thcrc would be no rcason for this compound to b€
prcsent as purc product, byproduct, or off-spec prDduct on
Pos8
Potassium cyanidc
Extmction ofgold dd silvcr from orcs,
rcagent in analyical chcmistry,
No. llErc would be no re6on fbr Ois compound to bc
pEs€nt 6 puE product, byprcduct, or off-sp€c prcduct on
Pos9
Potssium bis (cyanN)
(l) aryentsle Potassium
Silver plating, bactcricidc, antiseplic.No. There would bc no rcdon lbr this compound to be
prcscnt as purc prcduct, byprcduct, or off-spec prcdud on
sitc.
Pl0l
Elhyl cyanidc
Solvent, dielectric fluid, and synthcsis
intemcdiate.
No. lherc would be no rcason fbr this compound to be
prcsent as puE product, byproduct. or off-spe product on
Pl04
Silver cyanidc
Usd in silver F No. Thcre would be no rc6on tbr lhis compound to be
pEseni as purc prcduct, byprcduct. or ofi-spcc prcduct on
Pl06
Sodium Cymide
Milufacorc of dyes, pigments, nylon,
chelatiog compounds, inseticides,
fumiganE. Extradion of gold md sitver
from orcs, el@trcplating, mtal cleaning,
No. Therc would bc no rcason lbr this comfbund lo bc
pEscnt d purc produc(, byprDduc!, or off:spcc prDducl on
site.
Pl2l
Zinc cyanide
Used in nrctal plating, u a chemical
rcagent, and an ins@ticide.
No. I}lerc would be no rc6on for this compound to be
prcsent as purc prcduct, byprcduct, oroff'spcc prcduct on
F006
W6tcwater trcatmnt
sludses frcm eletrcDlatins
No. l'MRl pond mlenals ffi nol ircm rhis indusrry.
F007 No. FMRI pond ruterials aE not frcm this industry.
Page2
ino - FMFIlRCRATablel .07.05 final.doc
TABLE I (Rev.0): SLIMMARY OF FOTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDX VII
ASSOCIATED WITH NON.METALS IN FMRI PIONDS
Page 3
F009
Spcn sripping od
clcming both ftom
No. FMRI poDd matcrials rc not frcm this industry
F0l0
Crl qudch bath Bidu6
fiom rctal hcat trcatine
No. FMRI pond mtcrials @ not from this indusrry.
FOr I
Salt bath pot clcdingplutios ftom mcbl hdt
No. FMRI poDd matcrisls @ not frcm this industry.
F0l2
Quenching wrtewatcr
trcatutrt sludgcs fFm
No. FMRI pond mtcrials @ not fiDm this
F0l9 Wasbwabr
EamDt sfudges from
chemical @nverionmtilg of aluminum
No. l..l\llu pond mbals m nor lNm this industry.
K007
Cymide complexes in
*dtcwatcr sludgc fFm ircD
blue pigrent produdion
No. F-MRI poDd malerials rc nol frcm this indunry.
K0l 3
HydMyeic &id fFm
acrylonitdlc production
No. FMRI pond materials re not fioD this iddusry
K060
Atrmnia still lim sludgc frem
No. lW potrd mEnds rc not trcm tlns
K088
Cyeidc complcxd in spcntpotlild irm piimry
aluminum Eduction
No. I-MRI poDd matcf,als @ hot liom this l
TABLE I (Rev.0): SIIMMARY OF POTENTIAL RCRA LISTINGS
IN ,10 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON.METALS IN FMRI P'ONDS
Page 4
Colrmrclal
Chedcals
Aculely Toxi(
U List
Collmrcial
Chcnlcals
Acut ly H@rdN
P List
Non.Specmc
S@n6
F List
SFclfc
Soun6
K Llsa
Itrd6trial Us and SourcE ot U or P
Listed Elemnt or Compoud
ls Thts lls0ng Appltcablc to
FMRI ltaiertal?
u033
CarboDic difluoridc,
Ca$on ox).fluod&,
U*d io orgmic syutheis for addition of
carbon goup6 to other strumEs.
No. lhcrc vould bc no rcdoD lor this compoutrd b ba
p6ent 6 Frrc product, byprodua, or off-spcc prcdrct on
sitc.
u075
DchlorcdifluoF
mhec
ud ditu coDtd frwiDg. Used in
plstie lmufmrc, dd I $lvat ed
pEcot 6 purc pDduct, byprcduct, or off-spcc prcduct on
siE.
ul34
Hydrogcr fluoride
Cahlyst in Efincry alkylatiotr,
isorciation, @ndcnsation,
dchy&dioD, od polyrcriatioDpeds6. Us€d for oEeic od
inorgmic flourination etions,
production offluorirc gas md aluminum
fluori&, om umium lcachingplrcs, aDd 3 additivc to solid rckd
No. Hydrcgcn fluondc rs plwnt s Bidual aqu@s
hydrcrluoric eid ftom torlum lerching, which wo
.xcmpt ftom RCRA during thc rim pcriod 0rc pond
mtdial w6 mmulatcd. FMRI h6 also onfrfiEd lhat no
U listings apply, beau* no speil, agcd, or off spcc solveDt
ftom lab or precss ws cvcr disposed itr thc poDds-
l:w
DiisoprcplyfluoDphosp
hde
b*cticidc No. Thcrc euld bc no rc6on for this compouod b bcpent 6 Frrc product, byprodud, or off-spe produd oD
P056
Flusim
PDductioo of mhllic fluoridcs aDd
fluomr6oos, fluoridation ompounds
No. ThcE would bc no Eason for this compound to bc
pEscnt 6 Frrc pFduct, bypDduct, or off-sFc pioduct on
P057
2-fluorcrcamidc
Primity s a rodoticidc No. Thcrc would bc no llen for this compound b bc
p@nt I FrE prcdrct, byprodud, d off-spoc preduct oD
m58
Fluorcacetic acid
sodium salt
Primily 6 s rcdchticide No. Thcrc w@ld be no !!en for lhis coDpouDd b bcpcdt 6 Frrc prDdud, byproduct, or off-spe product on
NONE FListiDss
NONF NoKI
To:
final.doc
MEMORANDUM
International Uranium (USA) Corporation
Jo Ann Tischler
March 7,2005
Review of Chemical Contaminants in FMRI lnc. ("FMRI") Uranium
Material to Determine the Potential Presence of RCRA Characteristic or
RCRA Listed Hazardous Waste
From:
Date:
Subject:
Introduction
This report describes the results of my evaluation of the material (the "Uranium
Material") to be excavated from the Fansteel Metals Muskogee, Oklahoma facility
("FMRI") to determine whether or not the Uranium Material is or contains any listed or
characteristic hazardous waste as defined by the Resource Conservation and Recovery
Act ("RCRA"). International Uranium (USA) Corporation ("ruSA") has applied for an
amendment (the "Request for Amendment") to its White Mesa Uranium Mill (the "Mill")
State of Utah Radioactive Materials License No. UT1900479 to permit the processing of
Uranium Material as an alternate feed material at the Mill.
In accordance with the definitions in l0 CFR 40.4 ores with a natural uranium content of
0.05 weight percent or higher uranium are as source material, and are exempt from
regulation under the Resource Conservation and Recovery Act (RCRA). As summarized
in the Radioactive Material Profile Record, the FMRI Uranium Material can be expected
to have an average uranium content of approximately 0.15 weight percent uranium (0.18
weight percent UrOs) and approximately 0.36 weight percent natural thorium, and is
therefore a source material, and categorically exempt from RCRA.
Although the Uranium Material is exempt from regulation under RCRA, ruSA
nonetheless requires a due diligence evaluation of potential materials to be processed, to
assess:
whether the material is, or contains, any hazardous constituents that would be
regulated as RCRA listed hazardous waste, if the Uranium Material were not
categorically exempt from RCRA as a uranium ore or a categorically exempt solid
waste,
Whether the material contains any constituents that could generate a worker safety
or environmental hazard under the conditions under which it will be processed at
the Mill, and
1)
2)
3) Whether the material contains any constituents that would be incompatible with
the Mill's tailings system.
The following report provides my evaluation of the regulatory status of the uranium
material relative to RCRA. Evaluation of potential safety and environmental hazards and
compatibility with the Mill's tailings system are provided in a separate report.
1.0 Site History and Background
From 1960 to 1989, EMRI processed natural tantalum ores, and tin slags, for recovery of
tantalum and niobium (also called "columbium"), at the Muskogee facility.
Before the FMRI operation was shut down in 1989, the facility purchased tantalum ore
and tin slag from around the world for recovery of tantalum. The feed material was
leached in concentrated hydrofluoric acid and sulfuric acid. The tantalum and niobium
were dissolved in the leach solution, and the insoluble fluoride compounds such as
thorium, radium, and uranium, remained behind in the solids. These solids were filtered
and collected in Ponds 2 and 3. The composition of the leached solids sent to Ponds 2
and 3 varied with the efficiency of the tantalum leaching process, but they contained an
average of approximately 0.8 weight percent tantalum and 0.15 weight percent uranium
(0.18 weight percent UrOs). The solids in ponds 2 and 3 consist mainly of the metal
processing impurities in the fluoride form.
In the historical process, tantalum and niobium were extracted from the acidic leach
liquid with methyl isobutyl ketone (MIBK). In the solvent extraction stage, the MIBK
was used to remove the impurities such as iron, zirconium and uranium while leaving the
tantalum in the "raffinate stream". After the removal of the impurities, the tantalum was
precipitated to form KzTaFz (potassium heptafluorotantalate) and/or high-grade tantalum
oxides and tantalum metals. The remaining raffinate stream, containing little or no
tantalum but relatively high concentrations of hydrofluoric and sulfuric acids, was
neutralized with lime and sent to ponds 8 and 9. The materials in Ponds 8 and 9 will not
be shipped to the Mill.
The total volume of material to be processed at the Mill has been estimated to range from
approximately 16,000 to as much as 32,000 dry tons.
Basis and Limitations of this Evaluation
The Uranium Material to be processed at the Mill consists primarily of the contents of
Ponds 2 and 3, all of which is currently situated on-site at FMRI. Both ponds underwent
repeated characterization studies during the period from 1989 to 2000. The chemical
contamination profile reported in the FMRI documents listed below included nearly 300
samples from multiple locations and depths in Ponds 2, 3 and 5. The samples were
analyzed for radionuclides, recoverable metal values, and RCRA regulated organic and
inorganic contaminants. These studies provided sufficiently representative
characteization to assess both the regulatory status and chemical and processing
2.O
Christine - JAT memo on RCRA .07 final.doc
properties of the Uranium Material. It is my understanding that materials from Pond 5 are
not intended to be included in the Uranium Material.
The following contamination evaluation is based on:
1. Radioactive Material Profile Record for the WIP Feed (FMRI, 2005) and attached
Summary of Waste Chemistry Data(2119193)
2. Material Safety Data Sheet Revision l.l for Work in Process Sludge from Ponds 2
and 3 Residues (Fansteel, 021 14102)
Site history summary (2 pages) provided to IUSA by FMRI (FMRI 2004).
Material description, history, and location maps in excerpts from "Chapter 4.1
Pond Residues" in untitled document provided by FMRI (2OO4)
Analytical data in "Tables 6 and 7: Summary of Waste Chemistry Data for Ponds
2 and3" provided by FMRI.
Material description location maps, and analytical data from A Chemical
Comparison of Pond Residues with Estimates of Resources and Suggested Mining
M ethods (Appalachian Resources, September L2, 2000)
Cover sommary, radionuclide data and non-radioactive metals analytical data
from submittal entitled: Fansteel Materials for Processing and Storage (FMRI
2003)
lrtter from E. Jonathan Jackson to Harold Roberts, ruSA, entitled: FMRI Inc.
Determination that WIP Residue is not Regulated as a Solid or Hazardous Waste
(FMRI, October 25, 2004)
IUSA Protocol for Determining Whether Alternate Feeds Are Listed Hazardous
Wastes (ruSA, November 1999).
10. Affrdavit from FMRI (February 2, 2005), a copy of which is attached to this
report.
IUSA has developed a "Protocol for Determining Whether Alternate Feed Materials are
Listed Hazardous Wastes" (November 22, 1999) ("the Protocol"). The Protocol has been
developed in conjunction with, and accepted by, the State of Utah Department of
Environmental Quality ("UDEQ") (Letter of December 7, 1999). Copies of the Protocol
and UDEQ letter are provided in Attachment I of this Report. The RCRA evaluation and
recommendations in this Report were developed in accordance with the Protocol.
3.
4.
5.
6.
7.
B.
9.
memo on RCFIA .07 final.doc Page 4
3.0 Application of Protocol to Uranium Material
3.1 Source Investigation
Several of the information sources enumerated above were used to perform the Source
Investigation indicated in Box I of the flow diagram (the "Protocol Diagram") that forms
part of the Protocol.
The following sections describe the status of the Uranium Material relative to RCRA
Characteristic and RCRA Listed Hazardous Waste regulations, and relative to the specific
parameters identified in the IUSA/UDEQ Hazardous Waste Protocol. Although alternate
feed materials may contain RCRA characteristic wastes, for completeness, this Report
also determines whether or not the Uranium Material contains any characteristic wastes.
3.2 Determination Methods in the IUSAruDEQ Protocol
3.2.1 Regulatory History of the FMRI Uranium Material
As described above, the Uranium Materials to be processed at the Mill were generated
from 1960 to 1989, from the processing of natural ores and tin ore byproducts for the
recovery of tantalum and niobium. Prior to 1989, RCRA specifically excluded "...solid
wastes from the extraction, beneficiation, and processing of ores and minerals..." from
the definition of hazardous waste. This exclusion, known as the Bevill Amendment, 42
USC 6921 (RCRA 3001 (b)(3)(A)(ii), included the residues generated by FMRI's
tantalum process.
The scope of this exclusion has been significantly narrowed by subsequent rulemakings
including the Mining Waste Exclusion (54 FR 36592, September 1989) and the Mining
Waste Exclusion; Section 3010 Notification For Mineral Processing Facilities;
Designated Facility Definition; Standards Applicable to Generators of Hazardous Waste,
(55 FR 2322, January 23, 1990). The Final Rule, which eliminated the exemption for
residues similar to those from the FMRI tantalum process, became effective on March 1,
1990. The Final Rule was not retroactive, that is, it did not eliminate the exemption for
wastes generated before its effective date, unless they were actively managed. All the
Uranium Material from the FMRI facility to be shipped to ruSA was generated before the
active date of the Final Rule, and the material has not been actively managed, as defined
in the Rule. Therefore, the Uranium Material stored on site at FMRI is still exempt from
RCRA under the original provisions of the Bevill Exemption.
An argument could be made that processing the Uranium Material as an alternate feed
material at the Mill could possibly be considered "actively managing" the material as
defined in the Final Rule. If the Uranium Material were not categorically exempt from
RCRA as source material, it could be considered a solid waste at that time. However, as
described in the remainder of this report, even under this interpretation of the
applicability of the Bevill exemption, it would not be a RCRA-listed hazardous waste,
Lc =.!:r.is:ru;i "_,_..;., .:.--! .=.":__r*#si.e._al
and while the Uranium Material would have the RCRA characteristic of toxicity (due to
levels of chromium), it has never been classified or actively managed as a characteristic
waste, and as source material would not be considered a RCRA characteristic waste.
As described in Section 1.0, above, FMRI processed both natural tantalum ores as well as
byproduct (slag) from ores that had been previously processed to recover tin. Hence, the
tin ores, and the tin recovery process, are a potential source of some of the constituents in
the FMRI Uranium Material that are discussed in the following sections. It should be
noted that tin, its processing, and its byproducts, have never been associated with any
specific RCRA hazardous waste listings. Therefore, none of the constituents in the
Uranium Material that may have originated from tin slag are RCRA listed hazardous
wastes.
3.2.2 Evaluation of Potential RCRA Listings Associated with Specific
Contaminants
For potential alternate feeds that are not exempt from RCRA, the Protocol describes
additional steps IUSA will take to assess whether contaminants associated with any
potential RCRA waste listings are present, and the likelihood that they resulted from
RCRA listed hazardous wastes or RCRA listed processes. These steps include tabulation
of all potential listings associated with each known chemical contaminant at the site, and
the review of chemical process and materiaVwaste handling history at the site to assess
whether the known chemical contaminants in the material resulted from listed or non-
listed sources. This evaluation is described in Box 8 and Decision Diamonds 9 through
11 in the Protocol Diagram.
If the results of the above evaluation indicate that the contaminants are not listed waste,
the Protocol specifies an additional assessment of whether the data on which this
determination was made is sufficiently representative, or whether an ongoing acceptance
sampling program should be implemented, and a similar evaluation performed on any
new constituents identified during acceptance sampling.
In the case of the FMRI Uranium Material, Steps 9 through 11 are not required.
However, for the sake of a thorough due diligence evaluation, Steps 9 through I I were
completed, and the results are presented below.
4.0 Chemical Contaminants
The chemical contamination profile reported in the FMRI documents included nearly 300
samples from multiple locations and depths in Ponds 2,3 and 5 (as mentioned above,
material from Pond 5 will not form part of the Uranium Material). These samples were
analyzed for Volatile Organic Compounds ("VOCs"), Semivolatile Organic Compounds
("SVOCs"), total metals, rare earths, Toxicity Characteristic Leaching Procedure
("TCLI)'') metals, and radionuclides.
Christine Hiar - JAT memo on .07 final.doc
A summary of the RCRA evaluation findings for organic and inorganic non-metal
analytes in the FMRI pond samples is provided in Table I of this Report. A summary of
the RCRA evaluation findings for the metal analytes identified in the FMRI pond samples
is provided in Table 2 of this Report.
The characterization data provided to ruSA resulted from numerous sampling events
conducted over more than a decade. While some of the studies attempted to develop a
full chemical characterization, others were focused on the commercially valuable
constituents only. In addition, some of the studies focused on the contents of the three
ponds mentioned above, and some included characteization of perimeter soils adjacent to
the ponds. Hence, the sampling studies did not involve analysis for, or detection of, all of
the same parameters every time. For conservatism and completeness, the evaluation in
this report addresses every constituent identified in Ponds 2 or 3 in any of the sampling
studies, whether the sample was collected from the pond contents or its adjacent soils,
and whether the constituent was detected once or was confirmed in multiple analytical
results.
4.1 Volatile Organic Compounds
Methyl Isobutyl Ketone
FMRI reported that 56 samples from all three ponds were analyzed for RCRA Volatile
Organic Compounds ("VOCs"). One VOC, 4 methyl 2-pentanone, also called methyl
isobutyl ketone ("MIBK") was identified in samples of Pond 2 and Pond 3 contents at
concentrations ranging from non-detectable to 1,300 mglkg.
According to the site characterization report supplied by FMRI, "The most pervasive
constituents (MIBK, ammonia, fluoride, tin and columbium) identified in the ponds and
in the portion of the FMRI site where the ponds are located are consistent with plant
operations and activities historically conducted in this area."
MIBK is a polar oxygenated VOC (a "ketone") used as a solvent for paints, varnishes,
lacquers, and nitrocellulose. It is also used as a reagent in organic chemical synthesis,
and is sometimes added to commercial and industrial shipments of ethanol as a
denaturant. It has also historically been used as an extractant for leached solutions from
uranium and other metal extraction circuits.
MIBK can be associated with two RCRA hazard waste listings. MIBK wastes may carry
RCRA listing U161 if they are directly disposed commercial chemical products, off-spec
commercial chemical products, or manufacturing chemical intermediates. They may
carry RCRA listing F003 if they resulted from direct disposal of solvents or solvent
mixtures containing MIBK, or from still bottoms from recovery of MIBK or MIBK
mixtures. These listings do not apply to MIBK in the FMRI ponds for the reasons below.
MIBK was used as an extractant in the post-leach steps of FMRI's tantalum circuit"
- JAT memo on RCRA 31.07 final.doc
FMRI did not manufacture organic products, so MIBK was never present on the FMRI
site as an off-spec commercial product or manufacturing intermediate. Although it was
present on site as a commercial chemical product (an extractant), the affidavit provided
by FMRI on February 2,2005 confirms that the facility did not directly dispose of plant
or laboratory extractants in the tailings ponds. Hence, the U161 listing does not apply to
MIBK in the FMRI ponds.
MIBK was added to the extraction circuit where it came in contact with water in the
aqueous leachate solutions. MIBK was used to extract tantalum or other metals from the
aqueous leachate stream in a liquid-liquid extraction step, during which the aqueous
leachate stream became contaminated with MIBK. When the spent leachate solution
(tailings solution) was transferred to the WIP ponds, it carried some MIBK contamination
with it.
USEPA has determined that aqueous streams contaminated by contact with solvents or
extractants are not spent solvents and are not subject to the RCRA spent solvent (F001-
F005) listings. In a letter addressing aqueous wastes contaminated with extraction
solvents, Devereaux Barnes, Director of the USEPA Characterization and Assessment
Division, has stated thatr:
"...Process wastes that become contaminated with small amounts of
solvents during processing are not within the scope of the spent solvent
listings. An example of this is an aqueous effluent from a liquid-liquid
extraction step, in which a solvent has been used to extract a product from
water and the water becomes contaminated with small amounts of solvent.
In this example, the solvent is removed with the product and solvent-
contaminated water in not a spent solvent."
As described above, neither the F nor U listing applies to MIBK in the FMRI ponds.
Acetone
One detection of an additional VOC, acetone, was reported in one sample from Pond 3 in
1993. Acetone has not been detected or reported in any other samples from this or any
other sampling event before or since. The acetone detection occurred in a sample that
also had the highest reported levels of MIBK.
Acetone is a polar oxygenated VOC (a "ketone") used as an analytical standard, a
laboratory solvent, a process solvent in chemical synthesis, as lacquer and nail polish
thinner, and as a carrier and solvent in a wide range of household and personal care
products. Acetone may appear as an impurity in commercially distilled MIBK products
and ketone blends.
I Memorandum from Devereaux Barnes, USEPA Characterization and Assessment Division Director, to
Arthur Moretta, UIC Control Program Water Division, Region V, entitled "Regulatory Status of Solvent-
Contaminated Wastestreams from a Pharmaceutical Manufacturer". December 6, 1988.
Christine - JAT memo on RCRA .07 final.doc
Acetone can be associated with two RCRA hazard waste listings. Acetone wastes may
carry RCRA listing U002 if they are directly disposed commercial chemical products, off-
spec commercial chemical products, or manufacturing chemical intermediates. They may
carry RCRA listing F003 if they resulted from direct disposal of solvents or solvent
mixtures containing acetone, or from still bottoms from recovery of acetone or acetone
mixtures. These listings would not apply to acetone, if it were actually present in the
FMRI ponds, for the reasons below.
If it were actually present in the FMRI Ponds, the only plausible reason for its presence
would be as a product impurity in the MIBK extractant, which contacted the aqueous
leachate in the tantalum liquidJiquid extraction step. When aqueous leachate, containing
residual MIBK, was transferred to the tailings system, acetone present in the MIBK
would be transferred to the tailings as well.
As stated above, USEPA has determined that aqueous streams contaminated by contact
with solvents or extractants are not spent solvents and are not subject to the RCRA spent
solvent (F001 -F005) listings.
As described above, if acetone is actually present in the uranium Material, neither the F
nor the U listing applies to it.
4.2 Semi-VolatileOrganicCompounds
Di-n-butyl phthalate
Two RCRA Semivolatile Organic Compounds ("SVOCs") were reported above detection
limits in the 56 samples taken in the three ponds. Di-n-butyl phthalate was reported at
concentrations ranging from non-detectable to 2.8 mg/kg in the samples from all three
ponds, with an arithmetic mean concentration of 1 mg/kg.
There is no history of industrial phthalate production or commercial phthalate use at
FMRI. Both bis (2-ethylhexyl) phthalate and di-n-butyl phthalate are corlmon
plasticizers and may contaminate samples due to their presence in vinyl, butyl and other
plastic materials in sampling tools, label inks, packaging, and Personal Protective
Equipment ("PPE"). They are also ubiquitously present in many work environments
because they are known to be components of diesel exhausts from trucks, earthmoving
and excavation vehicles, and construction equipment.
According to the report accompanying the one set of pond characterization data in which
this compound appeared, the presence of di-n-butyl phthalate was "believed to be
associated with plastic samples [sic] collection equipment." (Untitled, undated FMRI
document, Section 4.I.2.3, Page 4-10) The evaluator considered the phthalate not to be
an actual constituent of the pond contents. Based on the very low concentrations, which
appeared in samples associated with one sampling event, and on the site history, this
4.3
conclusion is justified. This conclusion is also consistent with IUSA's experience with
alternate feed materials from other sites.
Based on the above information, the reported trace phthalates are not be indicative of a
RCRA listed hazardous waste, even if the Uranium Material were not exempt from
RCRA.
Other Non-Metal Inorganic Compounds
Eight non-metal inorganic ions or compounds were identified in the FMRI Pond
materials: ammonia, chlorides, cyanides, fluorides, nitrates, phosphates, sulfates and
sulfides. Ammonia is not associated with any RCRA listings and is not discussed further.
The other six ions are discussed below.
Approximately 274 samples from the FMRI ponds were analyzed for RCRA-regulated
organic compounds, including VOC and SVOC compounds. No organic compounds of
these seven ions were detected in any of the VOC or SVOC sampling results, so they are
not discussed further. This section will address RCRA-regulated inorganic compounds of
these ions.
Two of the inorganic compound types, ammonia and nitrates, are not associated with any
RCRA hazardous waste listings. The remaining six are discussed in this section.
Chlorides
Chlorides may carry RCRA listings U2L6, P033 or P095 if they resulted from the
disposal of thallium chloride, cyanogen chloride or carbonic chloride as commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates.
Thallium chloride is used as a catalyst in chlorination reactions, and as a radiation sensor
in applications such as control on sun lamps. Cyanogen chloride is used in organic
synthesis, as an active agent in tear gas, and as a warning agent (due to odor warning
properties) in fumigation gases. Phosgene is used widely in synthesis for addition of
carbon $oups to larger structures, particularly in manufacture of isocyanate
intermediates, other polymers, and pesticides. It was formerly used in chemical warfare
agents as a choking agent. There is no reason that any of these compounds would be
present as chemical product, off-spec product or manufacturing byproduct on the FMRI
site.
None of the above RCRA listings applies to the chlorides present in the FMRI ponds.
Chlorides are naturally present as trace contaminants in many transition metal and rare
earth ores. This is the most likely source of the chlorides in the Uranium Material.
Chlorides from ore sources are not associated with any RCRA hazardous waste listings.
.o7 10
Cyanides
Cyanides may carry RCRA listings if they resulted from the disposal of any of
following commercial chemical products, off-spec commercial chemical products,
manufacturing chemical intermediates :
the
or
U246 cyanogen bromide
P021 calcium cyanide
P029 copper cyanide
P030 cyanides
P031 cyanogen
P033 cyanogen chloride
P074 nickel cyanide
F019, K088
K007
K013
K060
P063 hydrocyanic acid
P098 potassium cyanide
P099 potassium silver cyanide
Pl01 ethyl cyanide
P104 silver cyanide
P106 sodium cyanide
PI2I zinc cyanide
There is no reason that any of these compounds would be present as chemical product, off-
spec product or manufacturing byproduct on the FMRI site. None of the above RCRA
listings applies to the cyanides present in the FMRI ponds. Cyanides have historically
been used as ore floatation reagents in a variety of primary metal extraction processes.
Although the historic process information available to FMRI does not expressly refer to
cyanides, cyanides most likely resulted from use as a flotation reagent in prior processing
associated with some of the tin slag received by FMRI for reprocessing. There is no other
plausible explanation for their presence, since cyanides were not used at the FMRI
facility. As mentioned above, there are no RCRA listings associated with tin processing,
hence cyanide associated with prior tin processing is not a RCRA listed hazardous waste.
EPA has determi4ed that residual reagents present as contaminants in wastewaters (such
as tailings solutions) are not RCRA listed hazardous wastes.
Cyanide wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
F006, F007, F009 electroplating
F010, F011, F012 metal heat treating
aluminum conversion or reduction
pigment production
acrylonitrile production
coking
None of the above operations or processes was ever conducted at the FMRI facility.
Therefore, none of the F or K listings are applicable to FMRI Uranium Material.
Fluorides
Fluorides may carry RCRA listings if they resulted from the disposal of any of the
following commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates :
10
Christine - JAT memo on RCRA 3-1.07 final.doc
U033 carbonyl fluoride
U075 dichlorodifluoromethane
P043 Diisopropylfluorophosphate
P056 Fluorine
P057 2-fluoroacetamide
P058 fluoracetic acid sodium salt
Carbonyl fluoride is used almost exclusively in organic synthesis to add carbon $oups
onto organic molecular structure. Diisopropylfluorophosphate, 2-fluoracetamide, and
fluoracetic acid sodium salt are used primarily as commercial insecticides and
rodenticides.
Dichlorodifluoromethane is used as a refrigerant for air conditioners, and direct contact
freezing and as a blowing agent in polymer foam blowing.
Fluorine gas is used in the production of metallic fluorides in metal finishing plants, and
commonly for fluoridation of drinking water and toothpaste. Fluorine gas was not used at
the FMRI facility.
There is no reason that any of these compounds would be present as chemical product, off-
spec product or manufacturing byproduct on the FMRI site.
Fluorides may carry RCRA listing UI34, if they resulted from the disposal of hydrogen
fluoride. As described in the FMRI process information, FMRI used hydrofluoric acid
(an aqueous solution ofhydrogen fluoride) fordigestion oftantalum ores. In the tantalum
digestion, it was used as a reactant, which use is not subject to RCRA listings. Insoluble
fluoride compounds formed during the digestion step were filtered out and sent to ponds
2 and 3. Hydrogen fluoride or hydrofluoric acid was not disposed of directly in the
ponds. The fluoride in the ponds resulted from the disposal of insoluble fluoride salt
precipitates, which are not associated with RCRA hazardous waste listings.
Phosphates
Phosphate wastes can ciury RCRA listing U145 if they resulted from the disposal of lead
phosphate commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. kad phosphate is uses as a stabilizing agent in
plastic formulation. There is no reason lead phosphate would be present as chemical
product, off-spec product or manufacturing byproduct on the FMRI site.
Phosphates are natural constituents in soils, in many natural minerals and ores, and in
tantalum and tin ores processed at the FMRI site. They are present in the FMRI ponds as
an impurity precipitated during tantalum recovery processing. The Ul45 listing does not
apply to the FMRI Uranium Material.
1l
Christine Hiaring - JAT memo on RCRA
Sulfates
Sulfates can carry RCRA listing U103 if they resulted from the disposal of dimethyl
sulfate commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Dimethyl sulfate is used in organic synthesis as a
methylating agent for production of amines, phenols, and polyurethanes adhesives.
There is no reason dimethyl sulfate would be present as chemical product, off-spec
product or manufacturing byproduct on the EMRI site.
Sulfates can also carry RCRA listing Pl15 if they result from the disposal of thallium
sulfate commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Thallium sulfate is used as a rodenticide and
pesticide, in the measure of ozone content in gases, and as an indicator in testing for
iodine in the presence of chlorine. There is no reason thallium sulfate would be present
as chemical product, off-spec product or manufacturing byproduct on the FMRI site.
Neither of the above RCRA listings applies to the sulfates present in the FMRI ponds. As
indicated in the historic process information from FMRI, sulfates resulted primarily from
the use of mineral acids in the tantalum leach circuit, which are not associated with any
RCRA hazardous waste listings.
Sulfides
Sulfides can carry RCRA listing U135, U205, or P022 if they resulted (respectively) from
the disposal of hydrogen sulfide, selenium sulfide, or carbon disulfide commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Hydrogen sulfide is used in purification of product hydrochloric and
sulfuric acids, as a laboratory analytical reagent, and as a source of sulfur and hydrogen
atoms in synthesis plants, such as in the preparation of metal sulfides. Selenium sulfide is
used in the preparation of medicines and mediated shampoos for treatment of seborrhea.
Carbon disulfide is used in the manufacture of viscose rayon and cellophane. It is also
used as a solvent in the synthesis ofcarbon tetrachloride and of flotation agents. Carbon
disulfide is a product of the natural degradation of larger organic compounds in the
environment. There is no reason any of these compounds would be present as chemical
products, off-spec products or manufacturing byproducts on the FMRI site.
Sulfides can also carry RCRA listing F005 if they resulted from direct disposal of
solvents or solvent mixtures containing carbon disulfide, or from still bottoms from
recovery of carbon disulfide or carbon disulfide mixtures that originally contained greater
than 10 percent carbon disulfide. There is no reason this compound would be present or
disposed of on site as a solvent, and no carbon disulfide solvent recovery still was ever
present on site. The F005 listing therefore cannot apply to sulfides in the pond materials.
Neither of the above RCRA listings apply to the sulfates present in the FMRI ponds. As
indicated in the historic process information from FMRI, sulfates resulted primarily from
t2
Christine - JAT memo on RA 3J.07 final.doc
the use of mineral acids in the tantalum leach circuit, which are not associated with any
RCRA hazardous waste listings.
4.4 Metals
A summary of the RCRA evaluation findings for the metal analytes identified in the
FMRI pond samples is provided in Table 2 of this Report.
Nearly 300 samples from FMRI Ponds 2,3, and 5 were analyzed for total metals and rare
earth elements. According to the characterization reports and data, five rare earths:
cerium, lanthanum, neodymium, praseodymium, and thorium, and 28 metals: aluminum,
antimony, arsenic, barium, beryllium, cadmium, calcium, chromium, cobalt, haftrium,
iron, lead, magnesium, manganese, mercury, molybdenum, nickel, niobium (also called
columbium), potassium, scandium, selenium, silver, sodium, tantalum, tin, titanium,
tungsten, zinc, and zirconium were present in the ponds.
The rare earth metals, cerium, lanthanum, neodymium, praseodymium, and thorium, and
1l of the above transition metals identified in the pond samples, cobalt, hafrrium,
molybdenum, niobium (columbium) scandium, tantalum, tin, titanium, tungsten, yttrium,
and zirconium, are not associated with any RCRA hazardous waste listings. The
remaining metals are discussed in this section.
Aluminum
Aluminum wastes may be associated with only one RCRA listing, P006, if they resulted
from disposal of aluminum phosphide corlmercial chemical products, off-spec
commercial chemical products, or manufacturing chemical intermediates. Aluminum
phosphide is used as an insecticide and fumigant, and in semiconductor manufacturing.
There is no reason this compound would be present as a chemical product, off-spec
product or manufacturing byproduct on the FMRI site. Aluminum is a natural constituent
in tantalum and tin ores processed at the FMRI site. It is present in the FMRI ponds as an
impurity precipitated during tantalum recovery processing. The P006 listing does not
apply to the FMRI Uranium Material.
Antimony
Antimony wastes may cilrry the following K listings if they resulted from the specific
industries listed here:
K021 fluoromethaneproduction
K161 dithiocarbamate production
Kl77 antimony oxide speculative accumulation
None of the above operations or processes was ever conducted at the FMRI facility.
Antimony is a natural constituent in tantalum and tin ores processed at the FMRI site. It
13
13
is present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. None of the K listings are applicable to FMRI Uranium Material.
Arsenic
Arsenic wastes can carry RCRA listing U136, P011, or P0I2 if they resulted
(respectively) from the disposal of cacodylic acid, arsenic trioxide, or arsenic pentoxide
commercial chemical products, off-spec commercial chemical products, or manufacturing
chemical intermediates. Cacodylic acid is used as an herbicide for grasses and tree
thinning, as a soil sterilizer, and as a chemical warfare agent. Arsenic trioxide is used in
production of pigments, enamels aniline colors, and decolorizing glass. It is also used in
formulation of insecticides, herbicides, rodenticides, sheep dip products and wood and
hide preservatives. Arsenic pentoxide is used in producing arsenates, insecticides and
weed killers, for dyes, printing and glass coloring, and in formulation of metal adhesives.
There is no reason this any of these compounds would be present as chemical products,
off-spec products or manufacturing byproducts on the FMRI site.
Arsenic wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
F032, F034, F035 wood treating
F039 leachates from multi-source landfills
K031 cacodylic acid production
K060 coking
K084, K101, Kl02 veterinary pharmaceuticals
K161 dithiocarbamate production
K171, K172, petroleum refining
Kl77 antimony or antimony oxide production
None of the above operations or processes was ever conducted at the FMRI facility.
Arsenic is a natural constituent in tantalum and tin ores processed at the FMRI site. It is
present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. None of the F or K listings are applicable to FMRI Uranium Material.
Barium
Barium may be associated with one RCRA listing, P013, if it resulted from the disposal
of barium cyanide commercial chemical products, off-spec commercial chemical
products, or manufacturing chemical intermediates. Barium cyanide is used in metal
finishing and electroplating. There is no reason beryllium would be present as chemical
product, off-spec product or manufacturing byproduct on the FMRI site.
Barium is a natural constituent in tantalum and tin ores processed at the FMRI site. It is
present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. The P013 listing does not apply to the FMRI Uranium Material.
t4
- JAT memo on RCRA 31.07 final.doc
15
Christine Hiaring - JAT memo on RCRA .07 final.doc
Beryllium
Beryllium may be associated with one RCRA listing, P015, if it resulted from the
disposal of commercial chemical beryllium powdered products, off-spec commercial
chemical products, or manufacturing chemical intermediates. Beryllium is present as a
commercial pure product in only a few industrial applications such as nuclear reactor
operations, neutron source generators, solid rocket propellants, and inertial guidance
systems. There is no reason beryllium would be present as a chemical product, off-spec
product or manufacturing byproduct on the FMRI site.
Beryllium is a natural constituent in tantalum and tin ores processed at the FMRI site. It
is present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. The P015 listing does not apply to the FMRI Uranium Material.
Cadmium
Cadmium wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
F006 electroplating
F039 leachates from multi-source landfills
K061 steel furnaces
K064 copperproduction
K069 lead smelting
KI77 antimony or antimony oxide production
None of the above operations or processes was ever conducted at the FMRI facility.
Cadmium is a natural constituent in tantalum and tin ores processed at the FMRI site. It
is present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. None of the F or K listings are applicable to FMRI Uranium Material.
Calcium
Calcium wastes can carry RCRA listing U032 or P02l if they resulted (respectively) from
the disposal of calcium chromate or calcium cyanide commercial chemical products, off-
spec commercial chemical products, or manufacturing chemical intermediates. Calcium
chromate is used in the manufacture of pigments, oxidizers, catalysts, medicines, glazes,
colored glass, inks and paints. It is also used in anodizing, engraving, etching, dyeing and
finished metal cleaning. Calcium cyanide is used as a rodenticide/fumigant for grain and
fruit production and storage, in gold leaching operations, and in chemical synthesis of
other cyanides. There is no reason either of these compounds would be present as
chemical products, off-spec products or manufacturing byproducts on the FMRI site.
Calcium is a natural constituent in soils, plant and animal material, and in tantalum and
tin ores processed at the FMRI site. It is present in the FMRI ponds as an impurity
Page 16
16
ristine Hiaring - JAT memo on
F006
F019
F035
F037, F038
F039
K002. K003
electroplating
aluminum coating
wood treating
petroleum refining
leachates from multi-source landfills
chrome pigment production
.07 final.doc
precipitated during tantalum recovery processing. The P015 listing does not apply to the
FMRI Uranium Material.
Chromium
Chromium wastes can carry RCRA listing U032 if they resulted from the disposal of
chromic acid commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Chromic acid is used in the manufacture of
pigments, oxidizers, catalysts, medicines, glazes, colored glass, inks and paints. It is also
used in anodizing, engraving, etching, dyeing and finished metal cleaning. There is no
reason this compound would be present as chemical product, off-spec product or
manufacturing byproduct on the FMRI site.
Chromium wastes may carry the following F or K listings if they resulted from the
specific industries listed here:
None of the above operations or processes was ever conducted at the FMRI facility.
Chromium is a natural constituent in tantalum and tin ores processed at the FMRI site. It
is present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. None of the F or K listings are applicable to FMRI Uranium Material.
Lead
Lead wastes can carry RCRA listings U144,U145, Ul46 or Pl10 if they resulted from
the disposal (respectively) of lead acetate, lead phosphate, lead subacetate, or tetraethyl
lead commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Irad acetate is used in dyeing, pigments, paints,
hair coloring, waterproofing and varnishes. It is also used as a laboratory reagent and in
cyanide gold leaching. Irad phosphate is used as a stabilizing agent in some plastic
resins. Lead subacetate was formerly added to sugar solutions in food products as a
decolorizing agent. Tetraethyl lead is synthesized solely as an anti-knock additive in
gasoline. There is no reason any of these compounds would be present as chemical
product, off-spec product or manufacturing byproduct on the FMRI site.
l-ead wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
wood treating
t7
F035
F039
F037, F038, K048, K049, K051, K052
K002, K003, K005
K046
K061, K062
K064
K069, Kl00
K086
leachates from multi-source landfills
petroleum refining
chrome pigment production
explosive initiator production
iron and steel furnaces
copper production
lead smelting
ink formulation
None of the above operations or processes was ever conducted at the FMRI facility. Icad
is a natural constituent in tantalum and tin ores processed at the FMRI site. It is present
in the FMRI ponds as an impurity precipitated during tantalum recovery processing.
None of the F or K listings are applicable to FMRI Uranium Material.
Manganese
Manganese may be associated with one RCRA listing, P196, if it resulted from the
disposal of manganese dimethyldithiocarbamate commercial chemical products, off-spec
commercial chemical products, or manufacturing chemical intermediates. Manganese
dimethyldithiocarbamate is used almost solely as a pesticide. There is no reason
manganese dimethyldithiocarbamate would be present as chemical product, off-spec
product or manufacturing byproduct on the FMRI site.
Manganese is a natural constituent in tantalum and tin ores processed at the FMRI site. It
is present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. The P196 listing does not apply to the FMRI Uranium Material.
Mercury
Mercury wastes can carry RCRA listings U151, P065 or P0921t they resulted from the
disposal (respectively) of mercury metal, mercury fulminate, or phenyl mercuric acetate
commercial chemical products, off-spec commercial chemical products, or manufacturing
chemical intermediates. Mercury metal product has been used in electrolytic cells, arc
lamps, dental amalgams, mirror coatings. It was formerly used in nuclear power reactors
and as a boiler fluid, and continues to be used in measurement instruments and as a
reaction catalyst. Mercury fulminate is used primarily as an explosive initiator in military
explosives, and is too unstable for most other applications. Phenyl mercuric acetate is a
microbicide used as a fungicide, spermicide, and anti-mildew agent. There is no reason
any of these compounds would be present as chemical product, off-spec product or
manufacturing byproduct on the FMRI site.
Mercury wastes may carry K listings K07l or K106 if they resulted from chorine cell
cathode liquid disposal. No chlorine processing was ever conducted at the FMRI facility.
Mercury is a natural constituent in tantalum and tin ores processed at the FMRI site. It is
present in the FMRI ponds as an impurity precipitated during tantalum recovery
18
Christine Hiaiing - JAi memo on final.doc
processing. None of the K listings are applicable to FMRI Uranium Material.
Nickel
Nickel wastes can carry RCRA listings P073 or PW4 if they resulted from the disposal
(respectively) of nickel carbonyl or nickel cyanide commercial chemical products, off-
spec coflrmercial chemical products, or manufacturing chemical intermediates. Nickel
carbonyl and nickel cyanide are both used in electroplating of nickel coatings. Nickel
carbonyl is also used as a chemical reagent. There is no reason any ofthese compounds
would be present as chemical product, off-spec product or manufacturing byproduct on
the FMRI site.
Nickel wastes may carry RCRA listing F006 if they resulted from disposal of
electroplating sludge. No electroplating was ever conducted at the FMRI facility. Nickel
is a natural constituent in tantalum and tin ores processed at the FMRI site. It is present
in the FMRI ponds as an impurity precipitated during tantalum recovery processing. The
F006 listing is not applicable to FMRI Uranium Material.
Potassium
Potassium wastes can carry RCRA listings P098 or P099 if they resulted from the
disposal (respectively) of potassium cyanide or potassium silver cyanide commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Potassium cyanide is used in gold and silver ore processing,
electroplating, and as an analytical reagent and insecticide. Potassium silver cyanide is
used as an antiseptic and in silver plating. There is no reason either of these compounds
would be present as chemical product, off-spec product or manufacturing byproduct on
the FMRI site.
Potassium wastes may carry RCRA listing K161 if they resulted from dithiocarbamate
production. No organic synthesis was ever conducted at the FMRI facility. Potassium is
a natural constituent in soils, plant and animal tissue, and tantalum and tin ores processed
at the FMRI site. It is present in the FMRI ponds as an impurity precipitated during
tantalum recovery processing. The K161 listing is not applicable to FMRI Uranium
Material.
Selenium
Selenium wastes can carry RCRA listings U204,u205, P103, or Pl14 if they resulted
from the disposal (respectively) of selenious acid, selenium disulfide, selenourea, or
thallium selenide commercial chemical products, off-spec commercial chemical products,
or manufacturing chemical intermediates. Selenious acid and thallium selenide are used
for cold blackening and decorative finishes of metals. Selenium disulfide is used in
medical preparations. Selenourea is methylated to make protective glass coatings. There
is no reason either of these compounds would be present as chemical products, off-spec
19
products or manufacturing byproducts on the FMRI site.
Selenium is a natural constituent in soils and in tantalum and tin ores processed at the
FMRI site. It is present in the FMRI ponds as an impurity precipitated during tantalum
recovery processing. The U and P listings are not applicable to FMRI Uranium Material.
Silver
Silver wastes can carry RCRA listings P099 or Pl04 if they resulted from the disposal
(respectively) of silver potassium cyanide, or silver cyanide commercial chemical
products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Both of these compounds are used in silver plating solutions, and silver
potassium cyanide is also used as an antiseptic. There is no reason either of these
compounds would be present as chemical products, off-spec products or manufacturing
byproducts on the FMRI site.
Silver is known to be a trace constituent in tantalum and tin ores processed at the FMRI
site. It is present in the FMRI ponds as an impurity precipitated during tantalum recovery
processing. The P listings are not applicable to FMRI Uranium Material.
Sodium
Sodium wastes can carry RCRA listing U236 if they resulted from the disposal of
dimethyl biphenyl diyl bis(azo)bis amino hydroxyl tetrasodium salt commercial chemical
products, off-spec commercial chemical products, or manufacturing chemical
intermediates, which are used in research chemistry and biochemistry. They may also
carry RCRA listings P058, Pl05 or P106 if they resulted from the disposal (respectively)
of sodium fluoroacetic acid sodium salt, sodium azide, or sodium cyanide commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Fluoroacetic acid sodium salt is used primarily as a rodenticide. Sodium
azide is used in diagnostic medicine, and as an explosive in air bag inflators. Sodium
cyanide is used in manufacture of dyes, pigments, nylon, insecticides, and chelating
compounds. It is also used in gold and silver extraction, metal treating and cleaning and
ore flotation. There is no reason any of these compounds would be present as chemical
product, off-spec product or manufacturing byproduct on the FMRI site.
Sodium wastes may carry the RCRA listing K161 if they resulted from dithiocarbamate
production. No organic synthesis was ever conducted at the FMRI facility. Sodium is a
natural constituent in tantalum and tin ores processed at the FMRI site. It is present in the
FMRI ponds as an impurity precipitated during tantalum recovery processing. The K161
listing is not applicable to FMRI Uranium Material.
Thallium
Thallium wastes can carry the following RCRA listings if they resulted from the disposal
20
of commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates listed below.
U2l4 thallium (I) acetate
UZls thallium (f) carbonate
UZl6 Thallium chloride
UZIT thallium (I) nitrate
Pl14 selenious acid dithallium salt
Pl15 sulfuric acid dithallium salt
Thallium carbonate is used as an analytical standard, and in production of synthetic
diamonds. Thallium chloride is used as a chlorination catalyst and as a sun lamp
radiation monitor. Thallium nitrate is used to produce green-fire pyrotechnics and as an
analyical laboratory standard. Selenious acid and its salts are used for blackening and
decorative finishing of product metals. Sulfuric acid dithallium salt is used in ant-killer
mixtures. There is no reason any of these compounds would be present as chemical
product, off-spec product or manufacturing byproduct on the FMRI site. Thallium acetate
is used in ore flotation but was not used at the FMRI facility.
Thallium wastes may carry RCRA listing K178 if they resulted from the manufacture of
ferric chloride as a byproduct from titanium dioxide production. No fenic chloride
processing was ever conducted at the FMRI facility. Thallium is a natural constituent in
tantalum and tin ores processed at the FMRI site. It is present in the FMRI ponds as an
impurity precipitated during tantalum recovery processing. The Kl78 listing is not
applicable to FMRI Uranium Material.
Zinc
Zinc wastes can carry RCRA listings U249,PI21,P122, or P205 if they resulted from the
disposal (respectively) of low concentration zinc phosphide, zinc cyanide, high
concentration zinc phosphide, or zinc dimethyl dithiocarbamate ("Ziram") commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Zinc phosphides and Ziram are used solely as rodenticides . Zinc cyanide
is used in metal plating, as an insecticide and as a chemical reagent. There is no reason
any of these compounds would be present as chemical product, off-spec product or
manufacturing byproduct on the FMRI site.
Zinc wastes may carry the RCRA listing K16l if they resulted from Zirarn rodenticide
production. No organic synthesis was ever conducted at the FMRI facility. Zinc is a
natural constituent in soils, plant and animal tissue, and tantalum and tin ores processed at
the FMRI site. It is present in the FMRI ponds as an impurity precipitated during
tantalum recovery processing. The K161 listing is not applicable to FMRI Uranium
Material.
21
4.5 Summary of RCRA Findings
Christine - JAT memo on RCRA .07 final.doc
Based on all of the above information, none of the constituents in the FMRI Uranium
Material would be indicative of RCRA listed hazardous waste, even if the FMRI Uranium
Material were not already exempt from RCRA as source material.
5.0 RCRA Characteristics
Nine samples of material from Pond 2, 15 samples from Pond 3, and 5 samples from
Pond 5 were analyzed for RCRA characteristics and TCLP metals. The FMRI WIP
material and its surrounding soils are not ignitable, corrosive, or reactive per the RCRA
definitions of these characteristics. No organic or inorganic contaminant at these
properties exceeded its respective TCLP threshold for RCRA toxicity characteristic.
One RCRA-regulated metal constituent, chromium, exceeded the RCRA TCLP
characteristic threshold in 13 out of 15 samples in Pond 3, or 13 out of 29 total samples
from all three ponds. The Uranium Material does have the RCRA characteristic of TCLP
toxicity, but has never been classified for shipment or off-site management as a RCRA
characteristic waste.
As discussed in the introduction to this report, the Uranium Material is source material
and exempt from regulation under RCRA. Although it possesses the characteristic of
TCLP toxicity, it would not be classified as a RCRA characteristic hazardous waste.
Furthermore, even if it were not exempt from RCRA and were classified as a
characteristic hazardous waste, alternate feed materials are permitted to contain RCRA
characteristic wastes under NRC's Alternate Feed Guidance.
No other RCRA-regulated constituent exceed RCRA TCLP characteristic thresholds in
any other sample. This result is consistent with the known process history. The Uranium
Material consists primarily of insoluble metal fluorides that did not dissolve even under
the most aggressive leaching conditions in hydrofluoric and sulfuric acid. It is reasonable
that the majority of the fluorides also would not leach under the TCLP conditions, which
are not as aggressive as the tantalum leach process.
6.0 Conclusions
In summary, the following conclusions can be drawn from the FMRI site information
presented above:
1. The Uranium Material is not a RCRA listed hazardous waste because it is an ore that
has a natural uranium content ofgreater than 0.05 weight percent, is therefore source
material, and, as a result, is exempt from regulation under RCRA.
2. Even if the Uranium Material were not source material, it would not be a RCRA
listed hazardous waste for the following additional reasons:
22
Christine - JAT memo on RCRA .07 final.doc
a)It was generated from a known process under the control of the generator, who
has provided an affidavit declaring that the Uranium Material is not and does not
contain RCRA listed hazardous waste. This determination is consistent with
Boxes I and 2 and Decision Diamonds I and 2 in the TSAAIDEQ Protocol
Diagram;
It is a solid waste that was specifically excluded from definition as a hazardous
waste by the Bevill Amendment;
The one VOC, MIBK, present in pond samples is not indicative of a RCRA listed
waste. MIBK is present in the material because it was transferred to the ponds as
a contaminant in aqueous tailings after the liquid-liquid extraction circuit. EPA
has determined that aqueous wastes carrying residual solvents are not RCRA-
listed solvent wastes;
The one SVOC reported in pond samples has been attributed by the analyst and
evaluator as resulting from sampling equipment and is not an actual contaminant
in the pond Uranium Material; and
b)
c)
d)
e) None of the metals in the pond samples came from RCRA listed hazardous waste
sources. This determination is consistent with Box 8 and Decision Diamonds 9
through ll in the ruSAruDEQ Protocol Diagram.
3. The characteization data indicates that, if it were not already exempt from RCRA as
source material, the Uranium Material would possess the RCRA TCLP toxicity
characteristic for chromium.
Jo Ann Tischler
Consulting Chemical Engineer
David C. Frydenlund
23
itine Hiarinq - FMRlRCRATablel nonmetals3.07.05 final.doc 5
TABLE I (Rev.0): SLIMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDD( VII
ASSOCIATED WIIII NON-METALS IN FMRJ PONDS
Page 5
Acutcly Toxic
U List
Acutcly Heardour
P Llst
Sourc6
P Llst
S0rc6
K List
lndNtrial Us and Sow6 of U or P Llstcd tslemnl
or Compoud
Is This Listing Applicable io
FMRI Malerial?
u069 Col]mo plasticizcr iD lacqucB. clastomB, cxplosives,
pDpclluts. Uscd 6 solvcnt dd fixativc ir [Drfum oils.
Used in t@ufrcturc of safcty gl6s, ilsricidB, inks,
paper coatings, adheivc, ing rcpcllet. Abo prcscnt
io diescl exhausts fmm hcavy equiprent on comtruction,
No. Therc wdld be no Mon for this @mpound to cxist 6 purc
product, mufrcruriDg by-produd, or off-spe product on siE. FMRI
indicdB that the appcarmcc ofthis compound in chamctcrization
sampld was due to smplc contmination by platic ontainm od
equiprEnt.
NONE NoPl
NONE No F Listines
NONE K LsUngs
Indu$dal Us and SourcG of U or P Listed
Elerent or Compoud
SolvcDt for painE, vamishes, nitmellulos,
lacquc6. Us.d iD orgeic synthcsis including
rmufrcErc md deDauring of alohols. Used in
exretion of umnium dd otha mals fiom oN.
No. MIBK wre uscd u m exttutmt in the FMRI mtal Eovery
pEess, md entercd the ponds u midual in aquous tailings
slutions. RCRA U listings do nd apply to solvcDt rcsiduals ioplGs aquous frctions aDd dnsaB. FMRI h6 al$ conlidEd
that no U listings apply, bcausc no spcnt, aged, or off spe solvent
F003
Spcnt solvcDts,
mixturcs/blends of
spcbt slYchb or
still booru frcm
thc @vcry of
spcnt slvcnts
originally
@ntainiDS l0
pcrccnt or moE of
spccific non-
halogcoiacd
Christine Hiarino - FMRlRCRATablel .05 final.doc 6
INORGANIC MIRATES]
uolrmrcla(
Acutcly Toric
U List
Colrmrial Chmicals
Acutcly Huardos
P Llst
Nm-SpqificS0rc6
F LIst
SpecincSons
K List
Ind6trial Us and Som6 of, U or P Listcd Elcmnt
or Cmpound
ls This ListlngAppllcablc to
IMRI Materlal?
NONE U hstncs
NONE NoPl
NONE No F Listinss
NONE
TABLE I (Rev.0): SLJMMARY OF P'OTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITII NON-METALS IN FMRI PONDS
Page 6
ComrcielChmiels
Aculely Toxlc
U Llst
Comrcial Chcmicals
Acutcly HmrdN
P List
Non-Speclfc
Sourc6
F List
Spccilic
Soun6
K List
ItrllrEtrial Us and S{rc ol U or P Listed Elemnt
or Compound
Is This Lisdng Appllcable !o
FMRI Mehriel?
ul45 No. Thcrc rculd bc Do EasD for this comlDund b bc prcstrt as pw
Droducr- blmoduct- or off-su oroduct on sitc
NONE No P tistincs
NONE No F Ustings
NONE No K LstDss
Uscd in organic syntheis as a rethylsting ag.nt vould bc Do rcason for tbis compound to cxist as puE
as a deDicrdc, psticialc ud in ozonomtry. Als
used iD analltical laboratoriG for tsting of iodirc in thc
No. Th@ would bc no rca$n for this compouDd b cxist s pw
product, lMufrcfting by-prcdud, or off-spe prcduct or siE.
1 nonmetals3.07.05 f inal.doc
Acut ly Toilc
U Ust
Acua,.ly HurdN
P Ltst
NM.DP
Sourc6
F Lisl
Source
K List
lndEtrlal Us and SourcE ol U or P List€d Elemnt
or Compound
Is This Llsliry Appllcablc to
trMRI Matlrial?
u ll5
Hyd! cosulfidc
Uscd in purifying hyd@hloric and slfuric rcid, and as a@M of hydrcgen dd slfur in sytrIh6is pldb. Uscd
for DMinE ffil sullids- md x an malvtical rcaecni.
No. 'I1crc would bc no Etron for this compound to cxist as purc
prcduct, mufmrihg by-prcducl, or off-spcc product oh siE.
uzo5
Sclcdum sulfidc
U*d itr mdicircs ed mcdicatcd shampoos for trcatiDg No. Thcrc would be Do rcasotr for this cotrlFund b exist as punprodud, mufrcturinr bv-Diodud. or off-sE Droduct on site.
wzz
Carbon disulfid.
Used in mnufrctuE of vise ByoD aod ccllophanc.
Uscd 6 a solvcDt dd in synthcsis of carton tmchlori&
No. Thcre would be no rcosn for this compouDd to exist 6 purc
prcduct, lmufming by-poduct, or off-spcc produd on siE.
F005 SPctrt solv.il mixoFs coDhining BEatcr than lO Frccot
of speific non-haloScnatcd ompoun&, md still bmom
from their mvrru
No. Carbo, disulfide is Dot pBent at lcvels gE.tcr the l0 p.Mnt.
Also, carboD disulfide *6 nd used 6 a $lvcDr d FMRI md rlF& is mlren this mmnd wld bc rcnt iD slvcnt mixorcs on site
NONE NoKl
TABLE I (Rev.0): SIIMMARY OF HOTENTIAL RCRA LISTINCS
IN 40 CFR26I and APPENDIX VU
ASSOCIATED WITH NON-METALS IN FMRI PONDS
NOTES
I, 2. Organic chloride and organo- nitrate compounds assciated with RCRA listings re included in the EPA Volatile Organic Compound (SW-846 8260) and Semi-Volatile
Organic Conpoud (SW-846 8270) analytical srites. FMRI Pond materials underwent multiple analyses for SW -846 8260 and 8270 organic compounds for over a decade, and no
ever been present in the FMRI ponds, only the inorgmic chloride and nitrate compounds were considered in this table.
PageT
TABLE 2 (Rev.0): SUMMARY OF P'OTENTIAL RCRA LISTINGS
IN,l0 CFR 261 and APPENDTX VII
ASSOCIATED WITII FMRI FOND METALS
Page I
Commrclal
Ch€nicals
Acut ly Toric
U LlEt
CotrmNlal
Chcnicals
Acutely
Hazardou
Notr-Sp.clric
Sorc6
F List
Speciflc
Sourc6
K Llst
lndNtrial us ard som6 0f u or P
Ilst d Elmnt or Compourd
ls Thts LlsUnt Appllcable to
FMRI Pond Materlal?
NONE NoUI
m6
Aluminm tmufmring.No. Th@ wH be no rcen for this compound to bc
plwnt 6 purc product, byprodud, or off-spe produd
on site-
NONE No F Ustings
NONE No K Listings
ANIIMOT.ry
CommrciaI
Chedcals
Acutrly Toxlc
u List
Colrercial
C'hcnicals
Acu!elyH@rdrc
P List
Non.Spccfi(
Sourc6
F List
SFcilic
Sourc6
K List
IndEartal Us and Sow6 of U or P
Listcd Elcmnt or Compoud
ls Thls Llsti4 Applioblc !o
FMRI Pond Mer.rial?
NONE No U Listiogs
NONE NoPl
NONE No F Ljstings
K02l
SPcnt catalyst from
fln^mlFrh,ro 6dn.ri^h
No. FMRImderial is nd fromthis iDdustry. Also,etimny is pBcnt primrily 6 m rc@ssory rctal iD
the tunEten oB- which is nd a lisr.d w6<i. sonr.
Purific.tion slid3, baghousc dust
and flor swpingr ftom
No. FMRI mterial is not fFm this industry. Also,
antimny is pE$Dl priMily as m rccssry mtal in
thc tuDgstcn 06, which is td a listed watc ole.
Slag fDm prcdudiotr or
sp€rhtivc @mulation of
No. FMRI maErial is nd fiom this indusry. Als,etimny is prcsnt primdly as m aessory rctal in
the ongsrn oc, *hich is not & listcd wstc sou@.
Christine H FMRIRCRAT final.doc Page.2
TABLE 2 (Rev.0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN ,l() CFR 261 and APPENDIX Vn
ASSOCIATED WITH I'MRI POND METALS
ARSENIC
Commarcial
Chenicals
Acutely Toxic
U List
Colrmrcial
Chetricals
Acutely
Haardo$
P List
Non-Specili{
Sourc6
tr Lisi
Specific
Sourc6
K List
lndNtdal Us and SourcE of U or P
Listed Elemnt or Compound
ls This Listing Applicablc to
F}IRI Pond Malerial?
ul36
Dimthyl menic
rcid
(cacodylic acid)
Used as hcdicide for Johnson grrs on
cotod, iD timberthiming, * a soil
sterilizing agent, and as a chemical
warf@ ageDt.
No. Therc would bc Do Eason fbr this compound to be
prcsent as puE product, byprcducl, or off-spcc product
on site.
Pot I
AEenic trioxidc
Used iD production of pigmnts, aniline
coloE, cermic cnarels, and dccolorizing
g)as, inseticidcs, herbicide,
rodcnticides, wmd md hidc prcscnativd,
No. Therc would be no rcason lb, this compound lo bc
pEscnt as purc prcduct, byprcduct, or off-spe product
Arenic
Pentoxide
Used in production of aecnatcs,
inseticide, dycing od printing, weed
killeE, and coioriation ofglass. Also
-"-, in h-i-I -iL-.:-*
No. 'Iherc would be no rcason lbr this compound to be
prcseDt as purc prcduct, byprDducl, or off-sp@ product
on sitc.
F032
W6tewater lmm wood prcserving
pmesses using cmsote md
*hrrhhh*.n^l
No. FMRI malenal is not trcm this industry. Als
arcnic is prcsent primily s an a@cssory retal in thc
tantalDm orcs, which is not a listcd w6te sourcc.
Wastewatcr frem wood prcscning
prcqses using ctusotc and
rnrrhl6hhh.b^t
No- FMRI material is rct frcm this industry. Also
arcnic is peent primdily d e a@essory mtaliD the
tetalum orcs, which is not s Iisted w6tc s@rce.
WstewatcE fDm w@d
prcsening pmcssa usingi-^.^--:^ --"---,;i--
No. FMRlmatcrial is not fiomthis iDdustry. Also
aEcnic is prcsent pimtrily as an a€dsory mtal in th€
tmtalum oe, which is not a lisled w4tc s@rce.
F039
lrachates fiom land disposal of No. FMRlmaterial is not fmmthis industry. Als
arenic is prcscnt primdily as o accessory mctal in the
lanialum oEr whi.i is nor, liar.d w3rt .-.*.
Spent calalyst liom
fln6r.lmrhrn. nd,rt;^n
No. FMRI matcrial is not from this industry. Also
mcnic is prcsent primily c o rcessory mtal in tbe
tantalnm oB which is nor a li<td ua{e <-,,-.
Byproduct salts from MSMA and
.,.dvli. ,.id 6dil.ri-h
No. FMRI material is not frcm $is industry. Als
menic is prcsent primrily as an acccsory retal in the
tantalum oE< whi.h i< ndr, lisrd w,(r..-.-.
Amnia still limc sludSc trcm
No. FMRI matcrial is not liom ihis industry. Also
ancnic is prcsent primuily s an accessory mtalin the
tantalum orcs. which is not a listed wa<te rorrec
KO84
Wastewrlcrsludge from
veterinary phamrceutical
producrion
No. FMRI material is not frcm this industrJi. Also
aEenic is p6ent primrily as an accessry rctal in tb€
totalum oB, which is not a lislcd wastc source.
Page2
TABLE 2 (Rev.0): SLJMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH FMRI POND METALS
Page 3
K10t
Distillation te Midues ftom
vctcrinary phmotical
production
No. FMRIm{cnd is Ddtiomthis itrdusty. AIso
renic is pmat primily as an acccssory mtll itr the
mtalum om. which is Dot a listcd wsE sNE.
K102
Rcsidu. ftom dccolorization of
.,j-:---, -L-*--.ri^-1.
No. FMR]mderial is not hrmtus industry. AIsoeDic is prcst primily as e rc@s$ry rchl in the
hhlum 06. which is Dot a listcd wsE sE
Pudfication solids, baghousc (fust
od fl@r swccpings fiom
dirhiMAArmar.,.id< lrd,.d6h
No. FMRI mderial is d hom this ihdusry. Als
mcnic is pwnt primily 6 m affiory rchl in tlc
tmhlum 06, which is mt a list d wste sourc.
KlTl SpcDt hydFhating c.talyst
ftom pchlcum EfDing
No. FMR|mdedal is notfromthis indusry. Also
@nic is pucnt primily d m e6sry trud in thc
tanhlum oE which is noi a li$d wrrr. .6nEe
Kt12
Spctrt hydmrcfining celyst from
dhlarh FShih'
No. FMRI material is not fom Oris industry. Also
sEenic is pEsnt priMily 6s e rc6sory mtal ih thc
tantalum oB- which is d a listed w*r. $uFe
Kt77
Slag fiom pDduction or
spedlativc a@mulation of
mtimnv or otimnv oxid6
No. FMRImddialis nd fromlhis iDdusry. Alsoenic is prcsDt primdily as il e@ssory mhl in thc
tdtalum orcs. which is hot a listed wastc source.
Cotrmrcial
Cherlcals
Acutely Toxlc
U Ltst
Ch.rIcals
AculelyHaardc
NOn.)pcc[tc
Sourc6
F List
Sourc6
K List
IndEtrial Us and SourcB of U or P
Listed Elerent or Compourd
Is This Listing Applicablc to
trMRI Pord Matcrial?
NONE Nd II I-isrinrs
ml3
Baium Cymide
Used in rrtallurgy od cletrcplatiDt.No. Therc would bc no Eagn for this compound b bcpBcnt s FrF prcduct, byptoduc!, or off-spe prcduct
NONE No F Listinss
NONE , K LstnEs
Christine Hiaring - FMRIRCFIAT 3.07.05 final.doc
TABLE 2 (Rev.0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN,l0 CFR 261 and APPENDIX VII
ASSOCIATED WITH FMRI POND METALS
BERYLLII]M
ComftrciAl
Chetricals
Acutely Toxic
U List
Chcdcals
A.utely
HaardoN
P Ltst
Non-Sp€cilic
Source
F l-ist
Sp€ciIic
Soum6
K List
Ind6trial Us and SourcE of U or P
Listcd Elemnt or Compound
Is This Listing Applicable to
FMRI Pond Materlal?
NONE No U Listings
Bcryllium POI 5
Bcryllium powder
BerylXum powdet ls uscd tn the rcmspae
industry, c a ncutmn rcflcdor in nuclear
Mctor shielding, solid Eket fuel, and in
X-Ey tubcs. Also used in alloys and pans
in gymcopcs. Suidance systcm
omponenE, inslrumntation dd @ntmls
Therc wdld bc no rc6on tbr powdercd beryllium to bc
prcsen! as purc prcduct, byproduct or off-spcc product
at FMRI.
NONE No F Lstinss
NONE No K Listings
Commercial
Chemicals
Acuiely Toxi(
U List
Comrcial
Chenicals
Acutely
Heardos
Non.Spccilic
Soune
F List
Sourc6
K List
lndutrial Us atrd Sourcs of U or P
Listed Elcmnt or Compourd
ls This Listing Applicable to
FMRI Po.d Material?
NONE No U Listings
NONE No P Listings
Wasbwatcr sludge fiom
No. FMRI material is not from this industry. Also
cadmium is pEscnt pdmtrily as an eccssory rebl in
the ianlalum oEs which i< not c li(d wa<r. <6nr.
trachates from laDd disposal ofwr.t . PO r^ P, ,.d P6 r- PR
No. FMRI material is nd fiom this industry. Also
anenic is prcsent primrily as an accdsory mtal in thc
ranrrhm oEr whi.h i< hoi , li<iJ w.<r. (^.*.
K06l
SEI clectric fumacc cmission
.^hrhl dtr(r/+'do.
No. FMRI material is not ftom this industry. Also
cadmium is present primtrily as an rccessory mal in
the tanlalum orcs, which is not a listed wast€ eurce.
Acid plant blowdown thickencr
slurry/sludge lrcm primary copper
nd',.ri^h hl^wd6uh
No. FMRI material is not from this industry. Also
cadmium is prcsent pimrily as an rccesory metal in
lhe tantalum orcs, which is not a listed wasrc source.
Emission @Dtrcl dust/sludge
No. FMRI material is nol liom this industry. AIso
cadmium is p6ent pimuily r m rccessory rctal in
-,Ll^L l" -^] - r:-'-r -,^-.- -^--^
Page 4
TABLE 2 (Rev.0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN tl{) CFR 261 and APPENDIX VII
ASSOCIATED WITH TMRI P'OND METALS
Comrercial
Che[icals
Acutely Toxic
U List
Colrrercial
Chedcals
Acutely
HazardoE
P List
Non-Spedll.
Sourc6
F List
Specilic
Sourc6
K List
Ind6trial Us and SourcG of U or P
Listad Elemot or Compourd
Is This Listiog Applicable to
trMRl Pond Material?
u032
Calcium
chromate
Usd 6 a pigmnt, comioo inhibitor
oxidizing agent, banery depolili@r,
codin I for light mtal alloys.
No. There would be no rcasoD foa this compound to bc
prcsent as FrE prcduct, byproduct, or off-sPcc pmducl
on sitc.
P02l
Calcium cyanid.
Rodchticidc, fumigmt for gEnhouses,
flour mills, grain, seed, md citrus Es,
gold leaching, and syntiais of other
No. lherc would bc Do rc6on ldr this comlaDd to be
pBcnt as Frrc poduct, bypDduct, oroff-spcc prcduct
on site.
NOM No F Ushnps.
NoKI
Chericals
Acutely Toxic
U List
LOllrerclil
Clhericrls
AcutelyHerdoE
NOn.DpacntcSoun6
F List
Sourcg
K List
lndstrial Us end Som6 ol U or P
Listed Elemnt or CompDurd
ls This Ltstirg Applicabh to
FMRI Pond Material?
u032
Chrcmic acid or
calcium salt of
chromic acid
Usd in lmulrcErc of pigmnE,
oxidiaE, catalysb, mcdicinB, ccrmic
glaEs, colorcd glass, inls, paints, plating,
aoodizilg, cngnving, platic dching, dd
i--ril- r--i--
No. Thcrc would bc no rcason lbr this compound to bc
pEsent as pure product, byproduct, or off-spc product
on site.
NONE No P ListinEs
Wasbwatcr trcatmDt sludgc ftom
No. FMRI maerial is nd from this indusiry. Also
chrcmium is prcsent primarily as o ac@ssory retd in
the tantalum orcs- which is not a listed wartc sure
IUly wasEwarcr reatmnt
sludge frcm ch.mical coating of
No. FMRI malcrial is not froD this induslry. Also
chrcmium is pment primrily as o acessory retal in
thc tantalDm orcs- which is hot a lisbd waste !onr.
Wood trcatin8 wAtcwalcr
No. FMRI matorial is Dot fiom this industry. Also
chmmium is pment primily a m aessory retal in
thc lmtalum orcs- which is not a listcd wste source
Refincry oiYwder sepmtor solids
No. FMRI materiai is nor frcm this industry. Also
chrcmium is prcsent primily a o acessory retal in
rh. tnhraf,rh ^Ec ili.h i. l.r " li.rJ -,".r- .^---
Page 5
Kt17
Slag fom prcduction or
speulativc accumulation of
mtimnv or mtimnv oxidcs
No. FMRI mderial is ndfromthis iDdusry. Also
cadmium is peent primilily as an &cosory ftlal in
thc tdtalum orcs, which is not a listcd waste sourcc.
CALCIIIM
tSt''r't 3.07.05 final.doc
TABLE2 (Rev.0): SIJMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH FMRI POND METALS
Page 6
ruJ6
Rclioery seondary oi Vwater
No. FMRI material is not from ihis ihdustry. Als
chmmiunr is p6ent primilily as an accessory @tal in
rhe tantalum orcs whi..h is noi , li.r.d wa(r. $nF.
lrachates fmm laM disposal of
wdres F20 ro F22 and F26 to F28
No. FMRI materiai is not from this indusrry. AIso
aMnic is prcsent primdly 6 an accessory mtal in the
tantalum orcs, which is not a listcd waste source.
K002
Wastewatcr trcatment sludge frcm
prcduction of chrcm ycllow
No. FMRI material is nor from this indusrry. Also
chrcmium is pr*nt primrily as u acessory metal in
thc lantalum orcs, which is not a listed wastc source.
K003
Wslewater treatuent sludgc fDm
prcduction of chrom mlybdate
No. hMRl matcnal rs rct hom lhis industry. Also
chrcmium is pres€nt primadly 6 m ac@ssory mdd in
thc tmtalum orcs. which is not a Iistcd wasle source-
K004
Wastewater trcamnt sludge frcm
prcduction of zinc yellow
No. tMRl marenal rs not liom this industry. Also
chromium is present primaily 6 m ac@ssory retd in
the tantalum orcs, which is not a listed waste surcc.
K005
Wastewatcr tEatrcnt sludge frcm
productior of chrcm gen
No. FMRI material is not trcm this industry. Also
chmmium is prcsent primarily s m ac@ssory rctal in
ihe tantalum os. which is not a listcd wste sourcc.
K006
Wastewater trcatment sludge ftom
production ofchDre oxidc gr€n
pigmnre
No. hMRl matenal rs not liom this industry. Also
chrcmium is prescnt primarily ro m acessory mtal in
the tantalum orcs. which is not a listed waste sourcc.
K007
Waslewater tEaircnt sludge fmm
production ofircn blue pigmenE.
No. FMRI material is not trcm this industry. Als
chromium is present primily d d ac@ssory retal in
the tetalum orcs. which is nol a listed waste sourcc.
K008
Oven rcsidue fem prcduction of
rLrnru nvida ma* niomantc
No. FMRI mateial is not from this industry- Ale
chrcmiunr is pre*nt primily as e ac@ssory mtal in
the rrntahrm oE. whi.h i< nor, l;.rd w".rp c^"-"
PetDIeum rcfining dissolvcd air
fl^r,ti6h l"DAF \ $1id.
No. FMRI material is Dot liom ihis industry. Also
chrcmium is prcsent priroily as m acessory mal in
lhe ianralum oEr whi.h is n6r i li<td w,.r. $nr.
PetDlcum refining slop oil
No. FMRI nraterial is not from this industry. Also
chrcmium is present primrily 6 u acssory retal inth.ranirhm oEr whi.h is h6i ^ lirtd w,{..^,'h"
Heat cxchdger bundle cleaninS(hdoF fbm Frhl.nh Flinino
No. FMRI material is not ftom this industry. Also
chromium is present primrily as u aessory retd in
thc tantalum orcs. which is not a listed wste source-
Petrcleum rcliDing API sepaEtor
No. FMRI nraterial is nd frcm this indusry. Also
chrcmium is preseDt primaily as il ac@ssory fttd in
-Al^L i" -^r - t:".-, *,^.,- -^..-^
TABLE 2 (Rev.0): SIIMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDD( VII
ASSOCIATED WITH I'MRI POND METALS
PageT
SEI cldric fumacc cmissioD
No. FMRJmdeial is d liomthis iDdrsry. Also
chrcmium is prcsnt pri@ily as m acccssory rctal iD
ihc ttutalum oB- which is d a listed wast sor'e
kDn ud stel mtuufacturing
No. FMRI Mtcrial is M ftom lhis itrdustry. Also
chsmium is prcscnt primily 6 u @ssory mtal inrL- ronrofilh ^8. tti-l i. n^i - [.rJ -,-.'- "-,--
K069
Emission @nml dust/sludgc
iiom s@oodaD, lcjd smltiog
No. FMRJhddial is d &m 0is indusry. Also
chrcmium is pcseot primily c m rcesory maal in
ihc hntalum oEs, which is mt a lisEd *astr $urcc.
K086
SolveDt, @ustic md waEr v6h
sludga fiom inl fomulatioo
l.lo. FMRI mtqid is d from this ihdustry. Also
chrcmium is prcscnt primily o m rcesrcry md it
thc mtalum oB, wtrich is m a listd wastc ffic.
K090
Emision @Dsl dust or sludgc
iom fmhbmium silioh
No. iMRl mdctral ls not liomths tndusty. Als
clmmium is pr6cht prilMily 6 u aesery md iD
dE mtalum oB, which is nd a listcd wastc sourcc.
Chctricals
Acuaely Toxlc
U Llst
ullmrcru
Chenicals
AcutelyHaardc
NOn.DpCC[!C
Sourc6
F LIst
Specific
SouN6
K LIst
IrdGtrial Us and Som6 of U or P
Llstrd Elcmnt or Compourd
ls This Lls(ng Applicablc !o
FMRI Pond Maacrial?
NONE No U Listings.
NONE No P ListiD6.
NONE No FListiDE.NOM NoKl
Christine FMRIRCRAT 3.07.05 final.doc Page 8
TABLE 2 (Rev.0): STIMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX vU
ASSOCIATED WITH FMRI POND METALS
Page 8
Chcnicals
Acutcly Toxic
U List
qllmrcril
Chcricals
Acutely
Hamrdous
NOn-Dp
Sourc6
F Llst
sp€ctrrr
Sourcs
K List
lndEtrlal Us and SourcG of U or P
Listcd Elemnt or Compound
Is Thls Listing Applicable to
FMRI Pond Materlal?
U t44
Iead rcctatc
Textile dyeing, chrcm pigrents, gold
cyilide lcrching, lab rcagcnt, hair dye.
May be prcscnt as antifoulant in paints,
wabDmfins. vmishs.
No. There would bc no reason fbr this compound to be
prcsent as purc prcduct, b)?rcduct, or off-slE product
on sitc.
lead phosphate
Stabilizin8 aSent added to plastic Bins No. Thcrc would bc no rcason for this compound to bc
pBent as purc product, byproduct, or olf-spec pDduct
ul46
lcad subacctate
Dc@lorizing egent added to sugd
solutions ir f@d prcducts.
No. Thcrc would be no rcdoD for this compound to b€
p@nt ss purc prcduct, byprcduct, oroff-spec prcduct
PI IO
Tetmethyl lead
Synlhesized solcly 6 aSdolihc
anti-knck additivc.
No. lXcrc would & no Mson tdr tils compound lo bc
pBent 6 PUE Pmduct, byproduct, or off-spe product
m35
W@d lrcating wstewater
No. FMRI matenal rs nol liom this industry. AIso lc{d
is pment primuily as m accessory metal in the
tantalum orcs. which is not a listd waslc sourc.
F037
Rcfinery oiUwacr *Dmtor solids
No. FMRI matcrial is nol from this industry. Also lcad
is p@nt priMily s s acccssry mctal ih theldtalum oB. which is not a listed waste source.
F038
Refi nery s@ondary oiYwatcr
No. FMRI matcdal is not lrcm Oris industry. Ale lcad
is pBent primdily 6 an ec6ery metal in thc
tiltalum orcs, which is not a listcd waste wrcc.
F039
brchatG fiom land disposal of
wastes F20 io F22 and F26 ro F28
No. FMRI mdenal is not frcm tlus industry. Also lead
is prcsen! primrily as an acccsely metal in the
tantalum om. which is not a listcd waste sourcc.
K002
Wastcwater lrcatrcnt sludgc frcm
production of chrcmc yellow
No. FMRI mdcrial is rot from this industry. Also lead
is prcsent primrily as an acccssory metal in the
tanlalum orcs. which is mt a listed waste sourcc.
K003
Wastcwalct trcatmnt sludge frcm
production of chmrc molybdatc
No. FMRI materi&l is not lrom thrs industry. Also lead
is pBcEt primdily a d accesery mebl in lhc
tantalum om, which is not a listed waste sourcc.
Km5
Watewatcr trcatmnl sludge fiom
production of chrcm gEn
No. lml matenal ls not hom tlus lndustry. Also lead
is pEscnl pdmrily as an affisory rctal in thc
tantalum os. which is not a listcd w6E source.
Wastewalcr trcatrcnt sludge fiom
production of lead bascd
No. FMRI msterial is not fom this industry. Also lead
is pment primoiiy as o accssory metal in thc
tantahm orcs, which is not a listcd waste sourcc.
TABLE 2 (Rev.0): SLMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPEI\DIX VII
ASSOCIATED WITH FMRI POND METALS
Petrcleum rcfiDing dissolYed air
llotation ('DAF') solids
No. FMRI material is not from this industry. Also ledd
is prcsent primarily as m accessory metal in the
tantalum orcs. which is not a listcd waste $urcc.
K049
Pehieum rcfining slop oil
emulsion solids
No. FMRI material is not ftom this industry. AIso lead
is prcscnt primarily u an accessory metal in the
tantalum oB, which is not a listed wastc sourc€.
K05l
P€trcleum rcfinine API sepamtor
solids
No. fMRl matenal rs not lfom this industry. Also lead
is prcsent primdly a o a@ssory metal in thc
tmtalum om. wfuch is nol a listed wasre source.
K052 Petrcleum rcfining leaded No. FMRI material is not from this industry. A.lso lead
is prcsent primily as an accessory mctal in the
tantalum orcs. which is not a listed waste source.K06l
SEI eletric fumacc omission
-^nrtnl *,.r/ctrrr'.
No. FMRI matenal is nol fiDm this industry. Also lead
is pment primdly as m rccessory mdal in the
lanlalum orcs- which is not a listed waste source
K062
Ircn md st€l m6uticruing
^i^Lr- [^-^.
No. FMRI matcrial is not fiom this induslry. Also lcad
is prcsent primaily as an accessory mtal in the
tantalum orcs which is not a listed waste <orme
K064
Acid plant blowdown thickener
slurry/sludge tiom primary coppct
^J!^.i^n Ll^-,r^-,-
No. FMRI matcrial is not fiom this indusrry. Also lcad
is pBent primatily as an accessory metal in the
tMtalum 06. which is not a listed wastc soure-
K069
Emission @ntrcl dust/sludBe
fiom seoodary lcad srelling
No. FMRI material is not lrcm this industry. Also lead
is prcseDt primarily as u accessory mctal in the
tantalum orcs. which is not a listed w6tc source.
K086
Solvent, caustic and water wflsh
sludgG ftom ink tbmulation
No. FMRI mateiial is not frcm this industry. Also lead
is prcrcnr primarily as an accessory metal in the
tantalum orcs, which is not a listed waste sourcc.
Kl00
Waslc sohtion from eid leehing
of cmission contrel dus/sludge
from saondaru lead smlrine
No. FMRI matcrial is not hom this industry. Also lead
is prcsent primarily d m a@essory metal in the
tantalum orcs. which is not a listed wastc source.
MANGANESE
Comrercial
Chericals
Acutely Toxic
U List
Colrmrcial
Chericals
Acutcly
HuardoN
Non-Spccilic
Sourc6
f,'Lisl
Specilic
Sourcs
K List
lndEtrial Us and Sow6 of U or P
Lisled Elemnt or Compound
Is This Listing Appllcable to
FMRI Pond Material?
NONE No U Listinss
Pl96
Mmganese
direthyldithio
ly as a pcsticide.No. There would be no rcason for this compound to be
prcsenl as purc prcduct, byprcducl, or off-spec prcduct
on site.
Page 9
TABLE 2 (Rev.0): SLJMMARY OF PTOTEIYTIAL RCRA LISTINGS
IN rl0 CFR 261 end APPENDX VII
ASSOCIATED WITII FMRI POND METALS
NONE No F U$irys
NONE No K Ultitrs
Page l0
RCRATable2Metals 3.07.05 final.doc
TABLE 2 (Rev.0): SIJMMARY OF FOTENTIAL RCRA LISTINGS
IN40 CFR261 and APPENDIX YII
ASSOCIATED WTTH FMRI POND METALS
Page ll
Cheiricals
Acutely Toxlc
U List
Chenlcals
Acutcly
H@rdoN
Non-SpcclfiC
Sourcs
F Li(
spcclnc
Sours
K List
lndEtrial Us and SourcE of U or P
Listed Elemnt or Compound
Is This Listing Applicablc to
FMRI Pord MAt..id?
u l5l
Mcmry mal
Hg
rnrar mgamr orguc mo tnofg@(
rcaction catalyst, cathodcs for chlorincy'
caustic prDdueion cclls, mimr oting,
vapor ed @ lmp6, nucld po*crMbE, boiler fluids. Ale prcsnt in
insmrcn8 md uscd ih cxErctivc
No, Thcrc euld bc bo E@n for this @mpound to bc
pGctrt 6 FrE product, bypioduct, oi off-spoc produd
on sib.
P065 Mcrcury
hrlrninatc
Duc to elativ€ly high ddon4ioD vclcity,
uscd primri! u o cxplGivc iDitiator in
military cxplosivd. Tm uEtable for lmt
No. Thcrc muld bc ro l@o for this compound to bc
prent 6 Frrc prcduct, byprodud, or off-spe prcduct
on sitc.
P092
Acctato-O-
phcnyl l1mury
of
phenyl muric
Urcd as a fungicidc, aDti-mildcw agcnt.
md as a topical spcmicidc
No. lltcrc wodd k no Ea$o tbr this compouod b bcprelt s FrE produd, bypodud, o, off-spcc pFduct
on siE.
NONE No F ListiDgs
K07l
Btinc purifimtioD muds frm
rcmil @ll chlorirc Droduct
No. tsMRl matend rs Dot trcm tlus industry. Aiso
lrr@ry is pEscbt primarily 6 s a@sory mtal itr rhc
rahtrtrm 6s whi.n i. d i li<rd w {. h.*
KI06
W6Ewatcr tMmnt sludge iom
mrcun cell chlorinc Drodktioh
No- tMRl mdcnal is mt hom this iDdustry. AlsomMry is plsnt primily 6 m amsory mal in theIrntrhrm 68 ehi.h i< Dot. li.r.d w'rr. $.-.
TABLE 2 (Rev.0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN ,10 CFR 261 and APPENDIX VII
ASSOCIATED WTTH TMRIFOND METALS
Cherdcals
Acutcly Toxlc
U Ltst
Chericals
AcutelyHurdN
Sourc6
F Ltst
Dpactrrc
Sourc6
K Llst
!trdElrial Us and Som6 of U or P
Ltstrd Elcmt or Compoud
ls'lnls Listing Appllcalrlc to
F'MRI Pord Materlal?
NONE No U Listitrss
NONE ,io P
NOM No F listinos
ONE No K ListinEs
Chctricals
Aotdy Toxlc
U List
Chcdcals
Acutcly
HeardoE
NOn-DF
Sourc6
F List
Sourc6
K List
lndEtrial Us and Sow6 of U or P
Llsttd Elmnt or CompouDd
ls T'hls LlsalngApplicable toIMRI Polld Material?
No U lf,stinqs
NONE NoPl
NONE NoFl
No K Listings
Commrcir!
Cherdcals
Acutely Toxic
U Llst
ColrIErcial
Chetrlcals
Arutcly
Haard06
P List
Non-Specinc
Sourc6
F List
speclnc
Sourc6
K List
lndEtrtal Us and SourcE ol U or P
Lisled Elemnt or Compouid
ls Thls Listiog Applicablc io
FMRI Pond Matcrtal?
NONE NoUl
NONE l'{o P tjstirs
NONE
NONE NoKl
Colrmrclol
Cherdcals
Acutely Toxlc
U Llsr
Chenicals
Aculely
HaardoN
SoN6
F List
Sour6
K List
Ind6lrial Us atrd SoK6 of U or P
Llst d Elemnt or Compound
ls 'l hls LlstinE Aplrlcable to
t]vlRl Pord Matedal?
Page 12
Ch ristine H iari no - FM R I RC RATable2Metals 3. 07.05
TABLE 2 (Rev.0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN ,10 CFR 261 and APPENDIX V[
ASSOCIATED WITH EMRI P'OND METAIS
Page 13
NONE No U Listings
P073
Nickcl ca6onyl
El@mplatcd nickcl coatings, rcagcil
chemical
No. Thcrc P@ld bc no lten lor thE @mpound to bc
p6ent 6 Fre prdwt, bypreduct, or off-spec prcduct
P074
Nickcl Cyai&Mctallu8y, clcctDplatin g No. Tlrcrc rculd be Do Easn tbr this @mlsnd lo bc
prc*nt o prrc prcduct, byprodud, or off-spec prodrct
on sitc.
F006
Wasicwabr tEatmefr sludgc from
NOM No K Ii<rinrr
- FMR I RCRATable2Metals 3.07.05 f inal.doc
TABLE 2 (Rev.0): SIJMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 251 and APPENDD( VII
ASSOCIATED WITH FMRJ FOND METALS
Page 14
LOllmrct&
Chcnicats
Acutely Toxlc
U Llst
C-hcnicals
AcutelyHaardrc
Sourc6
F List
Somc
K List
IndEtrial Us atd Sorc of U or P
Llst d Elerena or Compound
ls This Llstlng Appllcable !o
FMRI Pond Material?
NONE No U Listings
M6
Pousim
ExIffiioo of gold md silver from oB,
Mgcnt itr 0alytical chcmisry,
No. Therc muld be no Ee! for this compound to bc
pBcDt as purc pEduct, bypDduct, or off-spcc produ
P099
Pmium silvcr
Silvq plating, brcmicide, otisptic.No. Thw wH be no llen for this compound b be
prcscnt 6 puE ptoduct, bypDduct, or off-spe prDduct
NOM NoF
Mcmsodium
Purifiqtion solids, bagh$c du.t
ed sw@pitrg3 fom
Drthiq produdi6 NoK
Commriol
Chcnicals
Acutely Toxic
U LbT
Collmrctal
Chcricals
AcutclyHaardN
P List
Non-SpccllIc
Son6
F List
sFctRc
Sourc6
K List
or
Llsttd Elcmnt or Compound
ls Thls Listing Appliobl. to
FMRI Foid Mra.rtal?
NONE U UstinEs
NOM NoPI
NoFI
NONE No K Listins
TABLE 2 (Rev.0): SUMMARY OF POTTNTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDD( VII
ASSOCHTED WITII FMRI P'OND METALS
SELENII]M
Commr.lal
Cllcrlcsls
Aculely Toxic
U List
Cotrmrcial
Chcidcals
Acuacly
HaardN
P Llst
NoD-Sp.clflc
S0rc6rLls
SFcinc
Sour6
X Llst
IDdEtrial Us and Som6 o[ U or P
Listcd Elerent or Compound
Is This Liilng Applicablc io
FMRI Pond Matcrlal?
u204
Scbnious eid
or
olcnium dioxidc
SclctriNs &id md its salS e uscd for
cold blrckeling of metol pds for modcl
buildirg md dontive fiuishcs.
No. Th€E wH bc Do mon fo this @mpoutrd to bc
p@Dt 6 puE produd orb)'pDdrct on sib.
u205
Sclcnium sulfdc
or slcnium
disulfide
PEp@tioD of todcal dcrrEl and salp
rEdicatiohs-
No. ThcE would bc no Msotr fo this compouDd io be
pEcnt s FrE produd or byproduct oD sib.
Pl03
Sel€mM
Production of dimrhyl scle@M forsfay Slss @ings No. Thcrc muld b€ Do rcasotr for this compound b bcpreDt 6 FrE product or b)?rodud oD sitc.
Pll4
Selenious acid
dithallium salt,
SeleDios eid
dithallium slt,
Thallium
seleDidc,
Thall.ium
slcniE,
Selcdos rcid md its salts @ uscd fbr
@ld bl&kcnitrg of mtal pffi for modcl
building md dmmrivc finishc.
No. Th@ wdH bc m l@D for this cotrtpound b bcprent 6 FrE produd or b)rproduct on sib.
NONE NoF
NUNE NoKI
Page 15
Table2Metals 3.07.05 f inal.doc Paoe 16
SILVER
Commrcial
Chcrdcals
Aculcly Torlc
U Llst
Comnlal
CXEnicals
Acutdy
Hazerdo6
P List
Non-Specilic
Sourc6
F List
Spocinc
Sourc6
K Llst
lnd6ldal Usand Som6 of U or P
Listld Elemot 0 Compound
lE This Listing Applicablc to
FMRI Pord MAteriel?
NONE No U Lislings
P099
Potssium bis(cymH)(l)
argenbb
Silverpotassium
ousepuc No. Th@ woold bc Do @n for this @mIDund to be
prcsnt d Frrc product, byprodud, or off-spcc product
on sitc-
P104
Silvercymid.
Uscd ,tr silvd plating.No. Th@ wH bc no @o for this @mpound to bep@Dt ss Frrc pioduct, bypDdud, ot off-spe produc!
on sirc.
NOM NoF
NONE No K Listibps
TABLE 2 (Rev. 0): SUMMARY OF FOTENTIAL RCRA LISTINGS
IN ,10 CFR 261 and APPEI\'DIX VII
ASSOCIATED WITII FMRI POND METALS
Page 16
Commrci&l
Chmicals
Acutcly Toxlc
U List
LOlrrercril
Chericals
AcutclyHurdo6
P l.l.t
Non-SFcilic
S|)m6
tr'List
Spccilic
Sourc6
K Lisi
lndNtrial Us and Soma ol lJ or P
Llsted Elemnt or Compound
Is This Listint Applicablc to
FMRI Pond Mahrld?
3,jL(3,3,_dimthylu.lr
biphenyll4,41
diyl)bis(@)bis[5-
mino-4-hydrcxyl-
-tetrasodium slt
No. llrcrc rculd bc Do |en ior this compound to bcpreDt B Frrc pFduct, byproduct, or off-spec pmduct
on siE.
P058
FluoFacctic acid
sodium salt
RodcEtrcldc No. There would be no rc6on for this @mpouDd to bc
pMcnt 6 purc produd, byprodud, or ofr-spcc product
on sitc.
Pt05
Sodium uide
Air bag intlatol intcmdiaE in explosivc
l@ufrcturc, prenative in diagnetic
No. Th@ wH bc Do EMn for this compoudd to bc
pGcnl 6 FrE prcduct, byproduct, d off-spe product
on sitc.
Pl06
Sodium Cyeidc MmutrcErc ofdycs, ptgmcnts, nylon,
chelatihg compounds, in*cticides,
luhiguts Exretion of gold and silvcr
from oG, clffiplaring, mhl clcmiDg,
No. Thcrc would bc no @D for t}is @mpouhd to be
p@nt 6 Frrc prcduct, byproduct, or off-sFc product
on sitc,
NONE NoFI
3.07.05 final.doc
Page
TABLE 2 (Rev.0): SUMMARY OF FOTENTIAL RCRA LISTINGS
IN zl0 CFR 261 and APPENDIX VII
ASSOCIATED WITI{ FMRI POND METALS
Kl6l
MctM-sodium
Purification solids, baghouse dust
and sw@pings fm
Dithi@bamatc production No. Therc would be no reason fbr this @mpound to b€
prcsent as purc pDdud, byproduct, or off-spec product
Comrerclal
Chcnicals
Acutely Toxic
U List
Chericrls
Acutely
HazardoN
NOn.Dpe{
Sourc6
F List
Dpecrra
Sourc6
K List
lndNtrial Us and Som6 ot U or P
Lisied Elcmnt or Compourd
ls This LisUnt Applicable !o
FMRI Pond Material?
NONE No tl l-isrinss
NONE NoPI
NNM N^F
NONE NoKI
Comrercial
Chcricals
Acutely Toxic
U Lisl
Lollrerril
Chedcals
AcutelyHaardos
P l.i.t
NOnipecill(
Sourc6
F List
Dp€cilrc
Sourcs
K List
IndNtrial Us and Sourc6 ol U or P
Listed Elcmnt or Compourd
Is Thls Llsaing Applicable to
F'MRI Pond Material?
u2l4
Thallium (I)
HlgI speilic Smvity solutioDs lbrorc
fldation.
No. Thcrc would b€ no rcason ,br this compound to be
present 6 purc pmdud, byprcduct, or ofI-spcc prcduct
on site.
Thallium (I)
libomtory stddard lbr analysis for
carbon disulf'rdc, syntbesis of anifi cial
No. Therc would be no rcason for this compound to be
prcsetrt as purc pDduct, byprcduct, or off:spcc pmduct
on site.
Thallium chloride
L}llonnation catalysl. sun lamp mnitoN.No. Thcrc would be no E6on lbt this @mpound to bc
prcsnt il prrc product, byproducl, or off-sp@ product
on site-
uztT
Thallium (I)
Analytical stmdard, gEn-firc
pyrctehnics.
No. Therc would be no rcasn fbr this compound to be
pEsent as puF prcduct, byprcduct, or off-spe product
on site.
Pl t
Selenious rcid
dithallium salt.
Thallium
sclenide,
Thallium
selcnitc,
Ancimidol
Sclcnious acid and its salts are used tbr
cold blackcning of retal pds for model
building &d drcomtive finishcs-
No. Therc would bc no rc6on fbr this compound to be
prcscnl as prrc product, b)?roduct, or off-spec prcduct
on sitc.
Pu5
Sulturic acid
Pcsticidc, ant-killcr No. Thcrc would bc no rcason for this compound to bc
presen! as purc prcduct, bypmduct, or off-sp@ prcduct
Christine H iari nq - FM H I RC RATable2Merals 3.07.05 f i nal.doc 18
TABLE 2 (Rev.0): SIJMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH TMRI POND METALS
Page 18
NONE No F Listings
Kl78
Residu6 ftom manufacturiog and
storogc of fcnic chloridc frcm
rcids from titmium dioxidc
No. FMRI macrial is mt ftom this industry. Als,
thallium is prsnt priMily 6 an a@ssory ffial iD
the htalum oc, vhich is not a listcd waste sourcc.
THORruM
Comrercial
Chcmicsls
Acutcly Toxic
U Llst
Comrcial
Cherlcals
Acutely
HmrdoE
P LIsr
Non.Specific
Soum6
F List
SFcin(
Sourc6
K List
lndEtrial Us {nd SourcE ol U or P
Listed Elcmnt or Compoutd
ls This Lisaln8 Appll€blc to
FMRI Pord Mal.rlet?
NONE NoUlNOMNoP
NONE NoFIi
NONE No K UstinE
TIN
Commrclrl
Cheftlcals
Acutely Toxlc
U Ltst
Chenicals
Acutdy
HmrdoG
Non-SpcclIic
Sourc6
F List
Sp€cific
Sourc6
K List
Ind6t.ial Us md Som6 of U or P
Llstcd Elcmnt or Compound
ls lhts Listin8 Appltcablc toIMRI Pord Materlal?
NONE
NONE No P IrstinssNOMNoFl
NONE No K Listings
Commrcid
Choicals
Acutcly Toxic
U Llsl
Chtdcals
AcutclyHffirdN
Sourc6
F List
Sourc6
K Llst
Ind6frial Us and 5016 of U or P
Listcd Elcmt or Compound
Is This Listing Applicable to
FMRI Pord Material?
NONE NoUt
NONE No P Listinss
NONE No F Listings
NONE No K hstin6
i qn ri eli n-e." ! "r ie ri ns ;.nMflsg B^T. Q 1e?11"9 3.07.05 final.doc Paqe 19 i-Y,"r
TABLE 2 (Rev.0): SIJMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITII FMRJ POND METALS
Commrcial
Chenicals
Acutely Toxic
U Llst
Comrcial
Chcmicals
Acutely
HaardoN
P Llst
Non-Specifi c
Sourcs
F Llst
Specinc
Sourc6
K List
lndNtrial Us and SourcE of U or P
Listed Elemnt or Compound
ls This Listing Applicat le (o
FMRI Pond Material?
NONE No U Lislinss
NOM No P I-istinps
NONE No F Listings
NONE N6Kl
Commrcial
Chericals
Acutcly Toxic
ll l-isl
Collmrcial
Chcnicals
Acutcly
HaardoN
P List
Non-Spccifi(
Sourc6
F List
Specific
Sourcs
K Lisa
lndEtrial Us and Som6 oI U or P
Llsied Elcmot or Compourd
Is This Listlng Applicable to
FMRI Pond Materiel?
u249
Zinc phophide
f 10 fr. % or l6s)
Rodenticide No. Therc would be no E6oD tbr this compound to bc
PEscnt 4 pDrc product, b1prcduct, or off-spe product
Pt2t
Zinc cyanidc
Metal plating, chemical rcagcnt,
insticide.
No. Therc would bc no rcasoo for this comlEund to b€
pEscnt as puE prcduct, byprcduct, or off-spcc prcduct
Pt22
Zinc phosphide
(grcater than I 0
M. %)
Rodenticide No. There would bc no E4on for this compound to b€
prcscnt 6 Frrc prcduct, byprcduct, or off-s[Ec prcduct
oD sitc.
P205
ZDc dimhyl
dithimarbamtc.
Zirm
fungrcrdc, @lerator in rubbcr synthdis.No. Thcrc would be no rcason ior this compound to be
prcsent as purc pNducl, byproduct, or off-spcc pmduct
on sitc.
NONE No f llslrngs
Kl6l
Zimm pcsticides
Rodenticid.No. FMRI mderial is not fDm rhis industry. Also, zinc
is pEscnt pdmily as il accessory metal in the
tmtalum orcs, which is not a lislcd waste sourcc.
ZTRCONII]M
Commrcial
Chemicals
Acutely Toxic
U Llst
Chcrlcals
Acutcly
HaardN
P I-i.t
Non-Sp€cific
Sourc6
F List
Spe.iflc
Sourcc
K List
IndNtriAl U*s and SourcG of U or P
Listed Elcmnt or Compound
Is'I his Listlng Applicablc to
FMRI Pord Material?
NONE No U Listines
NONE
NOM NoFI
NONE No K Listings
Page 19
- FMRlRCRATable2Metals 3.07.05 final.doc
TABLE 2 (Rev. 0): SIJMMARY OF POTENTIAL RCRA LISTINCS
IN '10 CFR 2lt1 and APPENDU( VII
ASSOCHTED WITH TMRI P1OND METALS
Page20