DRC-1999-001061 - 0901a06880859322

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IrrBnxauoNAL
UneNtuvt (use)
ConroneuoN
Independence Plaza, Suite 950'. 1050 Seventeenth Street o Denver, CO 80265 '
, APril 16, 1999
303 628 7798 (main) e 303 389 {125 (tir-t)
h;
/r" i.\,:._ ,u_ >i gglgF * IVIA FACSIMILE:' [phone]
VIA FIRST CLASS MAIL
Mr. Don Ostler, Director
Division of Water Quality
State of Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144850 '
Salt Lake City, UT 8,4114-4850
White Mesa Mill
As contemplated in,our letter to you of March 19, 1999, this letter summarizes information
previously submined by International Uranium (USA) Corporation (*IUSA") to the Utah
Department of Environmental Quality (*UDEQ"), which is the type of information that is
normally provided in an application for a Groundwater Discharge Permit (*GWDP").
For your ease of reference. the italicized sections below are ordered to correspond to pelected
sections in the Utah Ground Water Discharge Permit Application lnformation format, with
each item followed by IUSA's description of the information which has been submitted
pertinent to the section.
3. DISCHARGE VOLUMES
Part B(3.) This section requires thatfor each type of discharge checked in #2 above,
the applicant is to list the volumes of wastewater discharged to the ground or ground
waten,"Yolumes'if wastewater should be rtai&d t cztealatedfun wdterwage.
As d*flneff fui.this secti6h, IUSil woukil cheik':none of thc discharges in #2, and' would
respond tfirii'tU$a has no discha{os bf fluias to the'$round or gioundwffi, ,.
P OT ENnU L D ISC HA RG E t/O LU MEg
Pqgg BH) Thiis section' requests that for each'tlry'of potentic{ discharge checked in
#2-sbbve, the appticant. is,.to list the maximum yolume of lluid,tltqt.could be
disct Wgpd tb ,he 'grbund cdnsideting such factors as: liner httdraufrc conductivity
and ofiiirtitlrig hbad'condittin:5, lCak'ddlection,rysteh sensitlbity, leathate collection
system efiitti*cy, atC: Catcuhitons.otlil iaw data used 1o'determine'qt{ potentifil
d i s c har !e' $ba{'d be' at t a c h e d.'"'
iUr. Don Ostler
April 16. 1999
Page 2 of4
The letter report from Knight-Pi6sold (Evaluation of Potential for Tailinss Cell Discharee-
White Mesa Mill, November 23, 1998) ("Knight-Pi6sold Report") evaluated the potential for
discharge of tailings fluid to the ground, considering the above factors, as well as Iiner
installation quality control. Calculations and data used to evaluate the potential for discharge
from the tailings impoundments were detailed in the section entitled Modelins of Potential
Volumetric Flux in the Knight-Pidsold Report and February 12, 1999 responses to UDEQ
questions.
HYDROGEOLOGIC REPORT
This section calls for a geologic description, with references used, that includes as
appropriate: Siructural Geologt 0.e., regiqnal and local, particularly faults.
fractures, joints and bedding plane joints; Stratigraphlt (i.e., geologic formations and
thickness. soil types and thickness, depth to bedrock; Topography (i.e., a map which
identifies facility boundaries, the |00 year flood plain area and applicable flood
control or drainage barriers, and surrounding land uses.
Section 1.0 of the Hydroeeologic Evaluation of White Mesa Mill (Titan, l994xthe "Titan
Repon"), contains discriptions of structura! geology, local geologic structure, hydrogeologic
setting, stratigraphy, and topography.
The section requests a Hydrologic Description, with references used, that includes:
Ground water depths, flow directions and gradients. Well logs should be included if
available. Aqufer name and characteristics, including saturated thickness, flow directions,
porosity, hydraulic conductivity, hydraulic communication with or isolation from other
aquifers or surface sources, recharge information, water in storage, usage, and the proiected
aerial extent of the aquifer.
The Titan reporq Points of Compliance. White Mesa Uranium Mill (Titan, l994Xthe "Point
of Compliance report"); H)rdrogeoloqy of White Mesa Mill (Umetco, 1992); and Semi-
Annual Effluent Report(s), which have been provided to UDEQ, contain details including
groundwater depths, flow directions and gradients; well logs; flow characteristics including
aquifer name and saturated thickness, flow directions, porosity, hydraulic conductivity;
confining units preventing communication of the perched zone of groundwater with the
aquifer; rccharge information; water usage; and aerial extent of the aquifer. These reports
demonstrate that no groundwater has been affected by potential discharge from the tailings
cetls. Water elevations and piezometric surfaces for both the unconfined perched zone used
for groundwater monitoring and the confined Entrada/l.,lavajo aquifer, respectively,
presented in these reports. In particular, Section 1.0 of the Titan Report describes
geologic, hydrogeologic, and climatological sening of the Mill. Section 2.0 of the Titan
report evaluates groundwater occurrence in the uppermost sandstone units, which hosts a
thin, discontinuous zone of poor-quality water used for monitoring; the aquitard properties of
the underlying thick sequence of shales, mudstones, and claystones; and the aquifer
properries of the deep EntradaA.lavajo aquifer, located more than 1,200 feet below the Mill.
The quality of the perched groundwater is described in Section 2.2 of the Titan Report and in
Section 2.2 of the Point of Compliance Report. Water quality data are contained in
Appendices of each report. The reports contain groundwater monitoring data collected since
are
the
\lr. Don Ostler
April 16. 1999
Page 3 of4
as far back as 1979. from collection points located both hydraulically upgradient and
downgradient, and within a one-mile radius of the tailings cells. These historic data should
meet the requirements of Section 8.
Note on Protection Level.s;
This note states that after the applicant has defined the quality of the Jluid to be discharged
(Ground ,yater Discharge Permit Application, Part B), characterized the local
hydrogeologic conditions and determined background ground water quality (Hydrogeologic
Report), the Executive Secretary will determine the applicable ground water class, based on:
t ) the location of the discharge point within an area of formally classified ground v'ater, the
background value of total dissolved solids. Accordingly, the Executive Secretary will
determine applicable protection levels for each pollutant of concern. based on background
concentrations and in accordance with URC R3l7-6-1 and R3l7-6-6.1A(l).
As stated in Section 2.2 of the Point of Compliance Report:
"The average total dissolved solids (TDS) concentrations for site wells in the perched
zone range froml,27l to 5,052 milligrams per liter (mg/L) and average sulfate
concentrations range from 656 to 2,956 mgtL. These ranges of concentrations also
have been documented in sandstone and shale units in other semi-arid regions with
natural poor water quality. According to Utah Administrative Code R448-6, ground
water with TDS of 3,000 to 10,000 mg/L is classified as Class III - Limited Use. A
number of upgradient, transgradient and downgradient wells, including wells
WMMW-3. WMMW-44, WMMW-I2, WMMW-I4, WMMW-I5, WMMW-I7 and
WMMW-19, would fall
perched water."
this classification, indicating the poor quality of the
GROUND WATER DISCHARGE CONTROL PI^AN
This section asks the applicant to select a compliance monitoring method to
demonstrate an adequate discharge control system. Among the discharge conffol
options is "no discharge," meaning that the system prevents any discharge of fluids
to ground or ground water by lining discharge pint with multiple synthetic and clay
liners; an earthen liner, which controls the volume and rate of efrluent seepage by
lining the discharge point with a low permeability earthen liner (e.g. clay), and
demonsffation that the receiving ground water, at a point as close as practical to the
discharge point, does not or will not exceed the protection levels. This demonstration
should be based on numerical or analytical saturated or unsaturated ground water
flow and contaminant transport simulations.
The Knight-Pidsold report and supfilemental responses to UDEQ, described above, address
the Mill's liner system and conclude that the liner system will serve to prevent discharge of
tailings fluids to groundwater and will prevent an exceedance of protection levels. This
demonstration was based on numerical saturated and unsaturated groundwater flow
simulations.
Mr. Don Ostler
April 16. 1999
Page 4 of4
10. Compliance fuIonitoring Plan
The applicont is asked to demonstrate that the method of compliance monitoring
meets spectJied criteria for groundwater monitoring, including v'ell location,
.. consffuction, operation; sampling and analysis procedures: and background woter
Section 3.0 of the Point of Compliance report details the detection monitoring program
approved by rhe U.S. NRC for the Mill. The report contains details regarding well location.
construction, and operation, and development of baseline water quality levels. Baseline is set
in accordance with methods recommended by the U.S. Environmental Protection agency, and
are detailed in Section 3.3, Statistical Analysis of Monitoring Data, in the Point of
Compliance report. Sample collection and preservation conforms with EPA methods, and is
discussed in the White Mesa Mill Quality Assurance Project Plan, submitted to the UDEQ in
I 998.
This concludes this summary of information that IUC has submitted to the UDEQ, which
constitutes facts to be used to assess what, if any, meaningful differences exist between the
current groundwater regime applicable to the White Mesa Mill under NRC regulations and
the State of Utah's Groundwater Discharge Permit ("GWDP") program. On or before May
30, 1999, IUSA will submit a second package of additional information not previously
submined, based upon the data and needs described in Appendix A, Permit Application
tnformation, of the Groundwater Water Quality Protection Permit lnformation Document
(UDEQ, Division of Water Quality, January 1996).
MRR:smc
. Sincerelv.
Michelle R. Rehmann
Environmental Manager
Dianne Nielson, UDEQ
"William Sinclair, UDEQ
N. King Stablein, NRC
Mike Fliegel, NRC
Paul Lohaus, NRC
Charles Hackney, NRC
Fred Nelson, Utah Attorney General's Office
David Bird, Parson, Behle, and Latimer
Tony Thompson, Shaw, Pittman, Potts, and Trowbridge
Milt Lammering, EPA Region VIII
Earl H. Hoellen, IUSA
David Frydenlund, IUSA
Page i
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
TABLE OF CONTENTS
page No.
Lrsr oF TA8LES............... ......................ii
Lrsr oF FIGUR8S............... .....................iii
LIST OF ATTACHMENTS. .....................iv
REFERENCES.......... ............v
HGCUTIVE SUMMARY .........I
PART A GENERAL FACILITY INFORMATION . .....4.I
PART B GENERAL DISCHARGE INFORMATION ....B.I
PART C ACCOMPA}.IY-ING REPORTS A}.ID PLANIS ....C.I
e
Table A-l
Table A-2
Table A-3
Table A-4
Table A-5
Table B-l
Table C-t
Table C-2
Table C-3
Table C-4
Table C-5
Table C-6
Page ii
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
LIST OF TABLES
Page No.
Projected Chemical Usage. ............A-8
Estimated Chemical Composition ..... ......4-9
ofLiquid in Tailing Slurry
Estimated Radiochemical Composition. ........A-10
of Tailing Liquid and Solids
Wells Located Within a S-Mile Radius. ...........A-16
of The White Mesa Uranium Mill
Drainage Areas of Project Vicinity and Region .L-26
of Tailing Liquid and Solids
Monitoring Well and Ground Water Elevation Data.. .....8-4
Generalized Stratigraphic Section of... .........C-8
of Subsurface Rocks Based on Oil-Well Logs
Generalized Stratigraphic Section of..... ................C-9
Exposed Rocks in the Project Vicinity
Properties of the Dakota/Burro Canyon Formation. .........C-3 I
Summary of Hydraulic Properties... .. . .C-32
Summary of Borehole Tests, 1994 Drilling Project. ...........C42
White Mesa Project, San Juan County, Utah
Results of Laboratory Tests. . ..............C43
e
Figure A-l
Figure A-2:
Figure A-3
Page iii
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
LIST OF FIGURES
Pase No.
Regional Location Map.. . .. .... -2
White Mesa Mill - Regional Map . .......A-3
Showing Land Position
Groundwater Appropriations within a...... ..A-19
5-Mile Radius of the White Mesa Mill
Figure A-4 Drainage Map ofthe Vicinity of..... .............4-24
the White Mesa Uranium Mill
FigureB-l WhiteMesaMill-SitePlanMap.. ...8-6
Showing Monitor Wells and Borings
Figure B-2 BlockFlowsheet. ..........B-19
FigureB-3 FlowBalance..... ..........8'20
Figure C-l Colorado Plateau Geologic Map.. .......C-6
Figure C-2 Generalized Stratigraphy of White Mesa. ..C-25
FigureC-3SitePIanMapShowingMonitorWellsandBorings......
Figure C-4 White Mesa Mill Seaion A-A'... ..C-28
FigureC-5 WhiteMesaMill SectionB-B'... ...-C'29
Figure C-6 Perched Ground Water Levels. ..........C-36
Figure C-7 Saturated Thickness ofPerched Water. .......C-37
Figure C-8 Preoperational Water Quality Sampling. .........C45
Stations in the White Mesa Vicinity
Attachment I
Attachment 2
Attachment 3
Attachment 4
Attachment 5
Attachment 6
Attachment 7
Attachment 8
Page iv
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
LIST OF ATTACIIMENTS
Pages 6-9 of the Titan Report
White Mesa Drinking Water Source Protection Plan
ruSA Letter to William J. Sinclair, UDEQ, October 31, 1998.
ruSA Letterto Don Ostler, UDEQ, March 19, 1999.
Knight Pidsold Report and Correspondence
Slimes Drain Data
Dames & Moore Table 2.6-6
NRC Renewal of Source MaterialLicense SUA-1358
Page v
International uranium At #3li:'ffi:
White Mesa Uranium Mill
Groundwater Information Report
REFERENCES
y,/ Dames and Moore, 1978. Environmental Reporg White Mesa Uranium Project, San Juan
County, Utah. Prepared for Energy Fuels Nuclear, Inc., January.
Energy Fuels Nuclear, Inc, 1996. Semi-annual Effluent Report, July - December, 1995.
Report Submitted by William Deal on February 26, 1996, to U.S. Nuclear
Regulatory Commission.
Environmental Protection Agency, 1984. Lining of Waste [mpoundments and Disposal
Grose, L.T., 1972. Tectonics, in Geologic Atlas of the Rocky Mountain Region. Rocky
Mountain Association Geologists, Denver, Colorado, pp. 35-44'
Haynes, DD., Vogel, J.D., and Wyant, D.G., 1972. Galogy, Structure and Uranium
Deposits of the Cortez Quadrangle, Colorado and Utah. U.S. Geological Survey,
Miscellaneous Investigation Series, Map, I-629, May.
Hufi, L.D., and Lesure, F.G., 1965. Geology and Uranium Deposits of Monteanma
Canyon Areq San Juan County, Utah. U.S. Geotogical Survey Bulletin 1190, 102
p.
International Uranium (USA) Corporation (IUSA), 1998. White Mesa Mill Quality -
Assurance Project Plan.
-,tnternational Uranium (USA) Corporation (IUSA), 1999. White Mesa Mill Drinking-f'" l'''"'
Water Source Protection Plan.
Johnson, H.S., Jr., and Thordarson, W., 1966. Uranium Deposits of the Moab,
Monticello, White Canyon, and Monument Valley Districts, Utah and Arizona.
U..S. Geological Survey Bulletin 1222-H,53 p.
Kelley, V.C., 1955. Regional Tectonics of the Colorado Plateau and Relationship to the
Origin and Distribution of Uranium. New Mexico University Publication Geology
No. 5, 120 p.
TKnight Piesold LLC, 1998. Evaluation of Potential for Tailings Cell Discharge - White- z1i? r- Mesa Mill. :o
o
Page vi
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
REFERENCES
(continued)
Shoemaker, E. M., 1954. Structural Features of Southeastern Utah and Adjacent Parts of
Colorado, New Mexico, and Arizona. Utah Geological Society Guidebook to the
Geology of Utah, No. 9.
Shoemaker, E. M. 1956. Structural Features of the Colorado Plateau and Their Relation
to Uranium Deposits. U.S. Geological Survey Professional Paper 300, pp. 155-
168.
Stokes, W.L., 1967. Asurvey of Southeastern Utah Uranium Districts, Utah Geological
Society Guidebook to the Geology of Utatu No. 21, pp. l-l l.
Thompson, K.C., 1967. Structural Features of Southeastern Utah and Their Relations to
Uranium Deposits, Utah Geological Society Guidebook to the Geology of UtdL
No. 21, pp. 23-31.
-.{*an Environmental Corporation, 1994. Hydrogeologic Evatuation of White Mesa
Uranium Mill.
. zTitan Environmental Corporation, 1994. Points of Compliance, White Mesa Uranium l* ):"
w Mi[. ,'r'\
r-'Umetco Minerals Corporation, 1992. Hydrogeology of White Mesa Mill.
U.S. Nuclear Regulatory Commission, 1979. Final Environmental Statement - White
Mesa Uranium Project, NUREG-0556.
U.S. Nuclear Regulatory Commission, 1997. Environmental Assessment for Renewal of
Source Material License No. SUA-1358.
Witkind, 1.1., 1964. Geology of the Abajo Mountains Are4 San fuan County, Utah. U.S.
Creological Survey, Professional Paper 453.
o
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May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
EXECUTIVE STIMMARY
This Groundwater Information Report (*GR") contains groundwater information
regarding the White Mesa Uranium Mill (the *Mill") from which is the type of information
that is normally provided in an application for a Groundwater Discharge Permit
('GWDP"). For the past several years, International Uranium (USA) Corporation
(*ruSA") has provided the Utah Department of Environmental Quality ("UDEQ") with
groundwater reports including a hydrogeologic evaluation; point of compliance reports;
groundwater modeling reports; and semiannual monitoring reports, which are submitted
under the terms of the Mill's license issued by the U.S. Nuclear Regulatory Commission
('NRC").
UDEQ has questioned whether or not the NRC's regulatory regime protects the
groundwater at the Mill to the extent the State believes is required. Although ruSA
maintains its position that it is not legally required to have a GWDP, and this GIR should
not be considered to be an application for a GWDP, ruSA is voluntarily providing this GIR
as part of its ongoing commitment to working with UDEQ to determine what, if any,
meaningful differences exist between the current groundwater regime appticable to the Mill
under NRC regulations and the State's GWDP program. IJDEQ has advised ruSA that it
will use this information to draft a suggested form of a GWDP that would satis$ UDEQ's
requirements but that would also address IUSA's concerns that have been discussed with
UDEQ. ruSA and UDEQ will then evaluate whether any meaningful differences exist
between the two groundwater regimes and, if so, whether they are more appropriately
resolved through the issuance of a GWDP, by adding additional conditions to IUSA's NRC
license (which is the approach suggested by IUSA), or by some other alternative.
For ease of reference, the italicized sections in the GIR are ordered to correspond to
sections in Appendix A Permit Application Information Section, of the Ground Water
&STAFF/MRI/TEXT99'GlR599GlRamitl
PageZ
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Quality Protection Permit Information Document (UDEQ, Division of Water Quality,
January 1996). Each item is followed by IUSA's description of the information which has
either previously been submitted, or is being submitted pertinent to the section. These
sections include the following:
Part A begins with general facility information, including addresses, contact names and
telephone numbers, and facility classification. Part A also describes principal processes
and raw materials used, and products produced. Projected chemical usage, projected
estimated composition of I le.(2) byproduct tailings slurry and liquid, management of
sanitary wastes, and management of laboratory byproducts from the uranium production
process are described. A listing of all permits held by the Mill is provided. Part A
concludes with a description of known or potential water use, including: wells and
appropriations, the lack of wellhead protection areas, and topography as it relates to surface
water drainages.
Part B, a section for "General Discharge Information", begins with an explanation of
IUSA's position that there is no probable cause to believe that the tailings cells at the White
Mesa Mill will discharge to groundwater. Statutory and technical bases for this position
are detailed, and include extensive monitoring history which has demonstrated no releases
to groundwater. Locations of tailings cells, volumes and types of materials contained in the
cells, and discharge potential are described.
For Part C, UDEQ requests reports and plans, including a Hydrogeologic Report a
Groundwater Discharge Control Plan, a Compliance Monitoring Plan, a Closure and Post-
Closure Plan, a Contingency Plan, and a Corrective Action Plan, all to be prepared by or
under the direction of a professional engineer or other groundwater professional prior to
construction of the facility. As the Mill and tailings cells are existing facilities, IUSA has
described equivalent reports and plans meeting the requirements of each of these requested
S:STAFF/MRI/TEXT99/GlRJ99rGlRcxmhl
Page 3
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
documents, and confirms that all of these were prepared by or under the direction of
professional engineers or other groundwater professionals. The reports referenced in Part
C, with the exception of letters specifically addressed to the UDEQ and one reporl have
been submitted as documents in support of the Mill's NRC license. All of these were
reviewed in pre-design meetings and post-construction reviews by the NRC.
Part C also provides an analysis of the composition of I le.(2) mill tailings managed at the
Mill resulting from processing of mined ores as compared to the composition of lle.(2)
mill tailings resulting from the processing of "alternate feed" ores. This analysis
demonstrates that there is no significant difference in chemical composition between the
two.
S:STAFF/MR.R./TEXT99G tR99/GlR accmfi I
Page A- l
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
PART A: GENERAL FACILITY INFORMATION
l. Facility Name:
Mail Address:
Contact Name:
Title:
Phone No.:
White Mesa Uranium Mill
6425 So. Highway l9l
P.O. Box 809
Blanding, UT 8451I
Michelle R. Rehmann
Environmental Manager
[phone]
The White Mesa Mill (the *Milf') is located in southeastern Utah, approximately six
miles south of Blanding, Utah (see Figure A-l).
The Mill is defined as the total area owned by lnternational Uranium (USA) Corporation
("IUSA") and its affiliates near Blanding, Utah, including the sites for the Mill, tailings
retention system, and associated facilities. The project site includes all of Section 28 and
portions of Sections 21,22,27,32and 33 of T37S R22E (Figure A-2). [t comprises t,480 . , '"1\
acres. The nri*&tit5lnrd*shown on Figure A-2
rF Thus. project site and restricted area are one and the same as defined here. As
projected in the Environmental Report, White Mesa Uranium Project - San Juan County
Utah (Dames and Moore, 1978) (the "Environmental Report), only a small portion of the
Mill site was disturbed by constnrction and operation. A total of about 77 acres in the
southern one-fourth of Section 28 was disturbed at the Mill site. The rrif,agrrrarrhr
$nl*wasprojectedtooccupyatotalofrffiintheNE%ofSection32and
the NW % of Section 33. IUSA and
its affiliates own the surface of the entire project site.
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FIGURE; A-1
REGIONAL LOCATION IvIAI
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Page A--l
ivlay 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
The following adjoining properties are fee land:
T37S R22E
T37S R22E
T37S R22E
T37S R22E
Section 33,
Section 21,
Section 21,
Section 22,
SEI/4
NEI/4SWl/4
N1/2SEl/4
N1/2SW1/4
The surface of all other contiguous land is federally owned and administered by the U.S.
Bureau of Land Management.
2. Owner/Operatorlnformation
Owner Name: IUC White Mesa LLC, an affrliate of IUSA
Mail Address: Independence Plaza, Suite 950
1050 lTth Street
Denver, CO 80265
Phone No.: [phone]
Operator Name: International Uranium (USA) Corporation
Mail Address: lndependencePlaza" Suite 950
1050 lTth Street
Denver, CO 80265
[phone]
Oficial Representative: David C. Frydenlund
Title: Yice President and General Counsel
Phone No: (303) 3894130
3. Facility Classification; Existing Facility
Phone No.:
S : STAf F/MRX/TEXT99/G!RJ9o/G!R9IA I fnl
4.
5.
6.
Page A-5
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundn'ater Information Report
Type of Facility: NRC-Licensed Uranium Mill
SIC Codes: 1094-Uranium, Radium, Vanadium Ores
Projected Facility Life: License renewed to 2007.
7. UDEO asl<s for identification of principal processes used, or services provided by
the facility, including principal products produced and raw materials used by the
facility:
RAW MATERIALS USED, AND PRINCIPAL PRODUCTS PRODUCED
The following subsections provide an overview of mill operations and operating periods,
and of the operations of the mill circuit and tailings management facilities. The
tbllowing discussion is summarized from the Environmental Report. The following
process steps are utilized for processing of mined ore or for processing of alternate feed
ores. with no significant modifications from the process described below required for
alternate feed ores.
Conventional milling methods for uranium ore processing are used. The ore is typically
crushed and ground to a size suitable for sulfuric acid leaching to ex&act the uranium.
The uranium-bearing solution is then separated from the ore residue, purified and
concentrated by solvent extraction, and the uranium precipitated as ammonium diuranate,
also known as "yellowcake." The yellowcake precipitate is de-watered, calcined,
crushed, and placed in drums for shipment.
When economically feasible, as determined by market conditions and ore characteristics,
by-prodrrcts of copper and/or vanadium may be recovered. The L,S*:.& dceigrrsd ,to"
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zfu fiCi
1/v\{
\+.- t 1Jo\lr.+u-/u. 1
(c4
* rn ,r\
7l?,bttz p ci -r.i
{ t"t o lle
o,o5 = 35,601\ PCia
!n ot*'
l,l ,
Page A-6
May 28, 1999
lntemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Theffias estimated by
Moore, at the time of the initial resource assessment, to be about$@arudqr
/ -t-*/ .77-r: L
P""l-<
Since the ores were projected to, and in practice have, originated from many different
mines, it is often a practice to blend them according to their chemical and metallurgical
characteristics. The crushed ore is wet-ground in a semi-autogeneous grind (SAG) mill
to pass a 28-mesh (O.Oz3zinch) screen. The ore slurry produced by the wet grinding step {*,
isleachedintwoStageswithsulfuricacid,sodiumchlorate,andsteaminamountsthatl4'i,>
first stage leach is to utilize the residual acidity of the pregnant leach liquor by reacting it
with the alkaline constituents of the freshly ground ore, thereby achieving chemical
economies.ItisanticipatedthatIn*ffifrrrnnftrpcontainedi'.:.,,"{
the *hdiqp ,2*/", +
The uranium bearing solution is separated from the barren waste by recr*
dEnnn**p(CCD) using thickeners. Polymeric flocculents are used to enhance the
settling characteristics of the undissolved solids. The decanted pregnant leach solution
has a pH of approximately 1.5 and contains less than one gram per liter of U3O6. The
barren waste is pumped to the tailing retention area.
\ llcl'., t, , 'r? tlzob
Solvent extraction is used to concentrate and puriry the uranium .contained in the
decanted leach solution. The solvent extraction (SX) process is cari'iecl out in a series of f-y
mixer and settling vessels, using an amine-type compound carried in kerosene(organic) i*', ^i.uL{Coo{
which selectively absorbs the dissolved uranyl ions from the aqueous leach solution. The i -
organic and aqueous solutions are agitated by mechanical means and then allowed to
separate into organic and aqueous phases in the settling tank. This procedure is
performed in four stages using a counter-flow principle wherein the organic flow is
introduced to the preceding stage and the aqueous flow (drawn from the bottom) feeds
ostoo'lY+
Dames &
I3f*h
t^
1
S. STAFF/MRVTEXTeeIGIRSeq'clRp&,\ I fnl
l*rk+\ \\
..-PL4t -/
[r\ {'a,*-iu'-
'r* n^J4'*'h z {t4,ofi{t)
61a, o?z> Uzoe
,(-- o P ?'lP'oa=
l,bI 6 ao3 ,n-L\ loo!.
2 - oF
= l,bqG.oorg . bl
(-oP
= l)1,/B)/r+,ogl pc;
(-op
1,e'l 6 1+ Pc; '4
A/-L
=p, Haf , U 't;t'!
+t'/.oo
E*,lrl')I ( un^+<(
- . A4D,/Bsz*1"
'J:u4?
M
oCi.t
-q
2
r
lYtA
24
'- pC)- 9p /.'/,
( / - va*
.1.,) rO) fto !.?f\
Page A-7
lvlay 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
iJ , )-, Groundwater lnformation Report
the following stage. It is estimated that, after four stages, the organic phase will contain
about two grams of U:Os per liter and the depleted aqueous phase (raffinate) about 5 mg
per liter. The raffinate is recycled to the counter-current decantation step previously
described or further processed for the recovery of vanadium. The organic phase is
washed with acidified water and then stripped of uranium by contact with an acidified
sodium chloride solution. The banen organic solution is retumed to the solvent
extraction circuit and the q*i**ntdfm*r ntaining about@
li*ris rxffidieod".wi*h am*,*o-praohrianc@im"di@(yellowcake). The
yellowcake is seuled in two thickeners in series and the overflow solution from the first
filtered, conditioned and retumed to the stripping stage.
The thickened yellowcake slurry is de-watered further in a centrifuge to reduce its water
content to about 40 percent. This slurry is then pumped to an oil or gas fired multiple-
hearth dryer (calciner). The concentrate, which is the final product of the plant, is then
packaged in 55-gallon drums for shipment.
The uranium concentrate drying, crushing and packaging operation is conducted in an
isolated, enclosed building with a negative ventilation pressure to contain and collect (by
wet scrubbing) all airborne U3Os particles. This system not only enhances the recovery
of uranium but also decreases the exposure of employees to potential radiation. In
addition, the design of the Mill is such that any leaks or spills in the plant are collected
and recycled to the appropriate part of the process, thus minimizing potential
contamination of the surrounding areas.
-. '5
)o/oc o /*c f
Uzct,
- It;l " ;':|I
jl,t 5r.i:,,t
S: STAf FMRUTEXTg9/GlR5996lR9tA I fol
-rrk\ ,,,* ptoc-rl+f,-- 3,8t5/5xa=,-t = [l)o
(wrA-'") =
lt r'(uLr k&J
=( /b)
tl\o,4r-+r*'*= tL
(
@i tP^J'f ilsz ( ''11*)
Page A-8
Ivlay 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
During processing of the ore, approximately the following chemical quantities were
projected by Dames and Moore to be consumed per day of operation for the recovery of
the uranium:
TABLE A.I
PROJECTED CHEMICAL USAGE
Chemical/Rate of Usaqe Dailv Use
Sulturic acid (196 lb/ton) 392,000
Sodium chlorate (5 lb/ton) 6,000
.{ locculents (0.3 lb/ton) 600
Sodium chloride (3.0 lbnb U:Os) 15,000
Soda ash (2.0lbnb UrOs) 10,000
Ammonia (0.4 lbnb UrOe) 2,000
Organic (95 percent tceg5gne). 1,680
LIQUID EFFLUENTS
, : t)
P n )^;t 1ra',: 'rLA '
+ib_: - l1*^
Ju14,gs3,ooi:.- 313,'
14,o,+4,gg5 ? 152'
t , Litl ,^4?, 5aeit 't u
The major liquid effluent discharged from the Mill to the cells is water contained in the
plant tailing slurry. The discharge rate of water present in the tailing slurry was expected
S:STAf F&fi R/TEXI99G|R599&lRptA I fnl
L\ ^ fa",lv*y, L^rlntr =0,oo "
5 JA
{
= 2,s yL d{+
(
= l) bq2,5 j:L
j.t
%
pci.4 ----.. t7''L{
u -r^1/r? -',
4?5d
/f ly-'
,)0,rl/,
t,
l6t
a:,^: "hr
tv\ tf
J"4
,\(-]\ '"'cltttt ' '-o,, Iv
to average 335 gallons
1B?, |ao Ut'-J,
\
Page A-a
May'28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
per minute and, based on laboratory test work reported by Dames
and Moore, would have an analysis approximately as follows:
t
fi9..1,,"t ['t
t-
'..'2jlJ-'i''t-
O,'L'
a --tt LJ -+2j 7 v'A,u | '
->5,o
I,Z
11,o tl
5,o
,.o'l
G,5 -B,q
TABLE A.2
ESTIMATED CHEMICAL COMPOSITION
oF TIQUID IN TAILINGS SLURRY /'/'/
i'(
{
i :" -v)'l .,' '
',d c t,'
-.\ t.
D
Constituent
vJ
Na
NHr
CI
SOr
Cu
Ca
Mg
AI
Mn
Zn
Mo
Organics
pH
t"
Grams/Liter !?, '-_
0.24 '' 4c'@
0.0025 t,! r,' '
4.900.065 ["5'a
3.05
82.21.62 ,i;1r.:,o
0.48
4.06
4.264.5g 4,59o'o
0.09 " ). o
0.007 j .2
See discussion below
1.8-2.0
Ii
The above liquid effluents were projected to contain a portion of the organic phase from
the uranium (and vanadium) solvent extraction steps. The organic residue is entrained
with the tailings solids. The amount of organic (mostly kerosene) released was projected
to be about 0.2 gallon per 1,000 gallons of raffinate, or 70 lb./hr. All liquid effluents
exiting from the Mill are confined in the tailings impoundment area. No liquid effluents
cross the property boundary of the Mill site.
S : STAFF/MRR/TEXT99r'Gn 599/GtRp$ I fnl
Page A-10
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Radiochemical analyses of the above tailings water and solids are as follows:
TABLE A.3
ESTIMATED RADIOCHEMICAL COMPOSITION OF
ffitr]ffi8rcWfrtffiF,{rem,ffiG'urr,;-o;'t;,
Assay, pCi/Liter - ily.< ! aD<
Radioactivity
Gross Alpha
Liquid 2.5 x l0 5
Solids
Assay, pCi/grams -PrF ){tlblt-\e* 4- '
-- -- --
Gross Beta 15230 p"226 p62to
2.3 x 105 1.3 x 105 2.3 x 102 2.8 x 102
Th230 Ra226
1.5 x 102 3.7 x 102
The Mill processed 1,511,544 tons of ore and other materials from May 6, 1980 to
Febnrary 4, 19t3. During the@
Acecru5,e*-ST'440fl, L,023,393 tons were processed. During the @
from , 1,015,032 tons were processed. Dtring the
203,317 tons were
processed. The &fth@**am,ol*y.$S96 fuwh.SGtrGdcs,""[Sr6,
processed 3,868 tons of calciurn fluoride material. Since ear:ly 1997, the Mill has
processed 58,403 tons from several additional feed stocks. Inception to date material 4'
processed through April 1999 totals 3,815,577 tons. This total is for all processing
periods combined.
MANAGEMENT OF I IE.(2) TAILINGS AND TAILINGS SOLUTIONS
The design of the lle.(2) tailings system features simultaneous constnrction, operation,
closure, and reclamation activities. Initid design, as approved in the Final Environmental
. ) rtrt' il
S:STAfFMRf,/TEXT996IR599G|R9i{ I fnl
o,,
,{
Page A-11
May 28, 1999
Intemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Statement Related to Operation of White Mesa Uranium Project, Energy Fuels Nuclear,
Inc. (U.S. NRC, Docket. NO. 40-8681, May 1979) (the "Environmental Statement"),
anticipated construction of six 100-acre tailings cells. In fact, tailings and process
solutions produced by the Mill operation are being impounded in a series of cells, each
having a total area of less than 70 acres. The design for each cell provides for total i .
containment of solids and liquids ,6t p,,', {"+- v:n 't b,lio
t"i' t -4 ], &*{<wW (n^-'
Construction on the tailings area began on August l, 1978 yith the nlovement of earth
from the area of Cell 2. Cell2 was completed on May 4, 19d0, Cen fron June 29,lgill,
and ln {. /untu .mpfutud and peod 'fo'r o *hort pcriod of time solely fgr sqlution storagq and )
evaporation. Cell 4 is not in use presently.
r!P' The design of the Mill is such that any leaks or spills are collected and recycled to the r&'!-"i:\" ',
.-': *-- ,,-.1'1.r,qr,', "|lappropriatepartoftheproceSs'thuseliminatinganyproductlossorcontaminationofthe
surrounding area.
TailingsproducedbytheMilltypicallycontain,havean
in-place dry density of 86.3 pounds per cubic foot (Cell 2), have a size distribution with a
predominant -325 mesh size fraction, and have a-hig[agidandloceUlgq! content.
'--(.'*:!r,,
-="-
i
In summary, the tailings facilities at the Mill currently consist of four cells as follows:
F^1
Ja-."r"
t
. Cell l, constnrcted with a 30 mil PVC earthen-covered liner, is used for the
fl ,c.po6aCffi o6ereoesdmion.
o Cell 2, constmcted with a 30 mil PVC earttren-covered liner, is used for the
-7
S. STAf F/MRPTEXf99G|R599G!Rp|A I fnl
ok
l'l'p'tt, \n [*
(\'r, 1 ltq = 3,Dt5, 5++(..1n
G,,,*,, f J;/ v" i."--e }, l,J. (c**c^} Vrln * ,tr.)
.rl
A-t
,\' LJ Ius?r- ^ )+*e^,4
{
Orl
= 3t?*ttofiyJz
= 0,15qL
, ttf lyJ ./g6,7,8 ?+ +r
l - o,51SB
=6 -z- /5"/ a,oo;,17 l-+t
{\ '''
i, v
*,
/t Iwtr
'l
<_.:, i 4(.
c''
lai
: r\o{
Page A-12
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater lnformation Report
Cell 3, constructed with a 30 mil PVC earthen-covered liner, is used for the
sblags of barm t*ilillgs.oulds &nd soluti@s.t!7
constructed with a lkiffinaUn is euren&u*rrd . / *)9 '
lP, t' ', '
, 'n'Total estimated design capacity of Cells 2,3, and 4A is approximately six million cubic
yards.
Tailinss Management
Constructed in shallow valleys or swale areas, the lined tailings facilities provide storage
below the existing grade and reduce potential exposure. Because the cells are separate
and distinct, individual tailings cells may be reclaimed as they are filled to capacity. This
k-2"{L"
phased reclamationladon exposure to a minimum.
The perimeter discharge method involves setting up discharge points around the east,
north, and west boundaries of the cell. This results in low cost disposal at first, followed
by higher disposal costs toward the end of the cell's life. The disadvantage to this
method is that reclamation activities cannot take place until near the end of the cell's life.
This disadvantage was recognized and led to the development of the finat gnde method.
':.: :'l :r '- 'l ::- :
Slurry disposal has taken place in both Cells 2 and 3. Tails placement accomplished in
Cell 2 was by means of the above described perimeter discharge method, while in Cell 3
the final grade method, described below, has been employed.
The final grade method used in Cell 3 calls for the slurry to be discharged turtil the
tailings surface.comes up to final grade. The discharge points are set up in the east end of
the cell and the final grade surface is advanced to the slimes pool area. When the slimes
ivt."l!I
>- "t -- --",
44-t f ;F
S:STAFF/Mn&TEXT99/GIR599,GnBA I fol
Page A- 13
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
I:
l-!,
pool is reached, the discharge points are then moved to the west end of the cell and
worked back to the middle. An advantage to using the final grade method is that
maximum beach stability is achieved by (l) allowing water to drain from the sands to the
maximum extent, and (2) allowing coarse sand deposition to help provide stable beaches.
Another advantage is that radon release and dust prevention measures (through the
placement of the initial layer of the final cover) are applied as expeditiously as possible.
Liquid Manaeement
As a zero-discharge facility, the White Mesa Mill must evaporate all of the liquids
utilized during processing. This evaporation takes place in two areas:
o Cell 1, which is used for solutions only
. €ell3, in which taitingsd solutionsexist.
-ti,L{,. , r
The original engineering design indicated a net water gain into the cells would occur
during mill operations. As anticipated, this has been proven to be the case. In addition to
natural evaporation, spray systems have been used at various times to enhance
evaporative rates and for dust control. To minimize the net water gain, solutions are
recycled from the active tailings cells to the ma:<imum extent possible. Solutions from
Cells I and 3 are brought back to the CCD circuit where metalh:rgical benefit can be
realized. Eanlth +^ ^tnfiaret tf'rt- 'm':trai- Iilr-^ -r ' fil'b't 't'lr lhnrri', ff+t'L
of the solution.
A visual inspection is made daily by supervisory personnel of all process tanks and .,:
discharge lines in the mill and of the tailings management area. In the event of a failure ':",, (i '
in one of the normal process streams, corrective actions are taken to ensure that there are ..1, j,
no discharges to the environment.
S : STAr FMRR/TEXT99/G!Rseg/'ClRptA I ftrl
Page A-1.{
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Most process liquids are recycled in the Mill; however, Dames and Moore projected that
about one ton of liquid (water) for every one ton of barren tailing solids will be
discharged to the tailings retention area. The water (expected analysis given above) will
be required to transport the solids to the tailings retention area. In addition, the
elimination of some process water in this manner avoids a build-up in chemical ions that
could be harmful to the process. As stated above, no liquid effluents cross the property
boundary. The tailings retention system consists of a series of lined, below-grade tailings
cells. The cells are lined with an impervious membrane to provide total containment of
solids and liquids. The cell area is calculated to be sufficient to achieve evaporation of
the total liquid effluent.
SANITARY WASTES
All applicable State of Utatr, Division of Health standards are met in the design and
operation of the sanitary facility associated with the Mill complex. Sanitary wastes are
disposed of by a*np&a*nak-.and,&oqrehffi designed and operated in accordance with the
U.S. Public Health Service standards and all applicable regulations.
Coveralls used in yellowcake product areas are laundered at the Mill. Furthermore, Mill
personnel are provided with a change room and trrrffigfuielto allow them to leave
their work clothes at the Mill. All liquid fufrom the laundry are mrM
trf,@
ANALYTICAL LABORATORY
The Mill facility has an analytical laboratory which routinely assays products of ore,
process streams and final products to assure adequate quallty control and plant operating
Ik;l-aL; r
^t(:a ]( <
*J t-
S: STAFF/Ir{RR,TEXT99/G!R599/'GIRFA I fnl
Page A-15
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater lnformation Report
effrciency. Under the terms of the NRC license, liquid laboratory wastes are discharged
as I le.(2) byproduct material to the tailings retention system.
8. UDEQ asks for a list of all existing or pending Federal, State, and Local
government e nvironmental permits :
Permits held by the White Mesa Mill include:
*b-3
9. UDEQ asks for names, locations, and descriptioins of: each well/spring (existing,
abandoned, or proposed), water usage (past,/present, or future); water bodies;
drainages; well-head protection areas: topigraphy; and man-maderstructures
within one mile radius of the point(s) of discharge site. UDEQ reque\s existing
U.S. NRC Source Material License No. SUA-1358
Utah Air Quality PermitNo. DAQE-687-95
Utah Water System No. 19025
well logs (include total depth and variations in water deptls).
WELLS AND APPROPRIATIONS
a
a
o
A-L-/
\ti'* d lP^'-, ., {,,-- S '
i
I
i
a-r, }/+'-'-QtY --'Seventy-six groundwater appropriation applications, within a five-mile radius of the Mill
site, are on file with the Utah State Engineer's office. A summary of the applications is
presented in Table A-4 and shown on Figure A-3. The majority of the applications are by
private individuals and for wells drawing small, intermittent quantities of water, less than
eight gpm, from the Burro Canyon formation. For the most part, these wells are located
upgradient (north) of the White Mesa Uranium Mill site. Stecla.idoGing and irdg*ha*
are listed as primary uses of the majority of the wells. It is important to note thatndl1
completed i*lre perched groundwater of the'hnfutr formation rrhHt
s:sl^f F/MRn/TEXT94yGIR59S/GtRFA I fnt
Table A-4
Wells Located within a $Mile Radius of
The White Mesa Uranium Mill
Map
No
Water Right
I Nielsot Norman and Richard C.
2 Guynon, Willard M.
3 Nielson, J. Rex
4 Nielsoru I. Rex
5 Lymaq Fred S.
6 Plateau Resources
7 Plateau Resources
8 Nielson, Norman and Richard C.
9 Lyman, George F.
l0 Holt, N.E., Mc[:ws. W.
I I Perkins, Dorothy
12 Enerry Fuels Nuclear, Inc.
13 Encrgt Fuels Nuclear, Inc.
14 Utah Iaunch Complex
15 Enerry Fuels Nuclear, Inc.
16 Enerry Fuels Nuclear, Inc.
l7 Enerry Fuels Nuclear, Inc.
lE Enerry Fuels Nuclear, lnc.
19 Iom. Alm*U:' , '
20 Energy Fuels Nuclear, lnc.
2I BLM
22 llaltiday, Fred L.
23 PerkingPaul
24 Red4 James D.
25 Brown, Aroe G.
26 Brow\ Creorge
sEc
ll
l0
l0
l0
l0
l5
l5
l4
l5
l5
2t
2L
22
27
28
2t
2t
2E
33
33
E
ll
2
2
I
I
TWP
37S
37S
3?S
375
37S
37S
37S
37S
37S
37S
37S
37S
375
37S
375
375
37S
37S
375
37S
375
37S
375
375
37S
37S
RNG
22E
22E
22E
228
228
22E,
22E
228
22E
22E
22E
228
22E
22E
22E,
228
22E
228
228
228
22E
22E
22E
22E
228
22E
cFs
0.015
0.015
0.015
0.013
0.022
0.015
0.015
0.015
0.015
0.007
0.015
0.6
l.l I
0.015
l.u
l.l I
0.015
0.6
0.oti
0.6
0.01
0.015
0.015
0.1
0.015
0.015
USE
IDS
S
IDS
s
TDS
o
o
IS
S
s
s
o
o
D
o
o
DSO
o
s
o
s
IS
ID
TD
IS
IDS
Depth
(fr)
150-200
82
160
165
120
740
135
150-200
135
195
150
1600
1820
650
1885
1850
1800
1600
200
1600
170
It0
180
200
2t0
140
Table A-4
Wells Located within a S-Mile Radius of
The White Mesa Uranium Mill
(continued)
Map
No.
Weter Right Depth
(fr)
l4l
180
142
100-200
160
190
196
160
t60
0
160
t40
132
150
60
1600
o lE60
s tts
D 226
ID IEO
s 164
IDS
D 100-300
IDS t00-300
ID 75
IDS 100-300
sEc
I
I
2
2
I
3
I
I
I
I
I
I
I
I
l5
2l
2E
I
3
3
2
2
2
2
2
2
TWP
37S
375
37S
37S
37S
37S
37S
37S
37S
37S
37S
37S
37S
375
37S
375
37S
375
375
37S
37S
37S
37S
37S
375
37S
RNG
228
228
22E
22E
22E,
228
22E
22E
22E
22E
22E,
22E
22E
22E
22E
228
22E
22E,
22E
228
22E
22E
228
228
22E
22E
crs
0.004
0.015
0.015
0.015
0.015
0.015
0.1
0.015
0.015
0.015
0.015
0.015
0.015
0.015
0.015
0.600
1.100
0.200
0.015
0.030
0.030
0.012
0.015
0.015
0.0t5
0.015
USE
IDS
ID
s
s
IDS
IDO
IDS
ID
TDS
IDS
s
TDS
Is
IS
IS
o
27 Brown, Llo M.
28 Renta Alyce M.
29 Rogers, Clarence
30 Perkirs, Dorothy
3l Brandt J.R & C.J.
32 Montella Frank A.
33 Snyder, Bertha
34 Martineau, Stanley D.
35 Kirh Ronald D. & Catherine A.
36 Palmer, Ned J. and Marilyn
37 Grover, Jess M.
38 Monson, Larry
39 NielsorL Norman and Richard
40 Wa&ins. Henry Clyde
4l Shumnray, Glen & Eve
42 Energt Fuels Nuclear, Inc.
(not drilled)
43 Energy Fuels Nuclear, Inc. (#t)
44 Watkins, Ivan R
45 Waukesha of Uah
46 Simpson, William
47 Guymon, WillardM.
48 Harrison, Lynda
49 Hurst, Reed
50 I(aer, Alvin
5l Heiner, Gerald B.
52 Laws, James A.
Table A-4
Wells Located within a $Mile Radius of
The White Mesa Uranium Mill
(continued)
sEcMap
No
\Yeter Right
53 Laws, J. Parley
54 AndersorL Dennis & Blith
55 Guymon, Eugene
55 Guymor\ Eugene
57 Guymon, Dennis & Doris
5t Guymo& Eugene
59 GuymouEugene
60 Perkins, Dorothy
6t Wa&ins,Ivan R
62 Roper, Lloyd
63 Smitl\ I.ee & N{arylynn
il McDonal( Kenneth P.
65 Brake, John
66 Brake, John
67 Red( Parley V. & Reva V.
6t C&CConsruction
69 Guymon, Dean W.
70 Phillips, Elizabeth Ann Hurst
7l HowE, I-conard R
72 Shumnay, lvIark Eugene
73 Shum*ay, lvfart Eugene
14 Lyman, Henry lv{.
75 Uta Mountain Ute
76 Ute Mountain Ute
TWP
37S
37S
37S
375
37S
37S
375
375
375
365
36S
36S
36S
36S
36S
26S
37S
365
37S
37S
375
crs
0.015
0.015
0.r00
0.015
0.030
0.1 15
0.1r5
0.015
0.015
0.015
0.060
0.015
0.015
0.015
0.015
0.015
0.015
0.015
0.015
0.015
0.015
0.100
0.535
0.t606
USE Deptb
(fi)
TDS
IDS 160
IDS t30
s 130
IDS 2rO
IDS 100-200
IDS 100-200
IDS 140
IDS 145
ID I8O
IDS I7O
TDS 734
ID 250
IS 150
IS 200
IS 190
IDS IEO
I 165
o 160
ID
IDS 150
IDS 200
2
2
2
2
2
2
2
2
t
34
34
34
34
34
34
34
3
22E,
22E,
22E
22E
22E
22E
22E
22E
22E
22E
22E
22F
22E
22E
22E
22E
22E,
22E34
3
3
3
3
23
23
D
D
22E
228
228
22E,
22E
228
37S
385
385 15l5
Notes:
D -Domestic
I - Irrigation
S - Stoclruatering
O - tndustrial
SEC - Section
TWP -Tovmship
RNG -Range
CFS - Cubic Feet Per Second
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Page A-10
lv'tar' 28. 1999
International Uranium (USA) Corporation
White Mesa Llranium Mill
Groundwater Information Report
riowngradient of the site within the five-mile radius. Trvo water *"tt, fni.{available
data'itrdica@ are completed in the Entrada,/Navajo sandstone (Clow, ielZ;, ,*irtI _--'
opp.oxiilately 4.5 miles southeast of the site on the Ute Mountain Ute Reserv'ation.
These wells supply domestic water for the Ute Mountain Ute White Mesa Community,
situated on the mesa along Highway 191 (see Figure A-3). Data supplied by the Tribal
Environmental Programs Office indicate that both ',vells are completed in the
Entrada,/Navajo sandstone, which is approximately 1,200 feet below the ground surface.
Insufficient data are available to define the groundwater flow direction in the
Entrada./Navajo sandstone in the vicinity of the Mill.
The well yield from wells completed in the Burro Canyon formation within the White
lvlesa site is generally lower than that obtained from wells in this formation upgradient of
the site. For the most part, the documented pumping rates from on-site wells completed
in the Burro Canyon formation are less than 0.5 gpm. Even at this low rate, the on-site
"vells compieted in the Burro Canyon formation are typically pumped dry w'ithin a couple
of hours.
This low' productivity suggests that the White Mesa Uranium Mill is located over a
peripheral fringe of perched water; with saturated thickness in the perched zone
discontinuous and generally decreasing beneath the site, and with conductivity of the
formation being very low. These observations have been verified by studies performed
tbr the U.S. Department of Energy's disposal site at Slick Rock, rvhich noted that the
Dakota Sandstone, Burro Canyon formation, and upper claystone of the Brushy Basin
Member are not considered aquifers due to the low permeability, discontinuous nature,
and limited thickness of these units (U.S. DOE, 1993).
In addition, Attachment 1, which contains pages 6-9 of the Hvdrogeolosic Evaluation of
white Mesa uranium Mill (Titan, 1994) (the "Titan Report") provides maps,
S STAfFA.{RRJTEXT99/CIR599/GIefr{ I fnl
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Page A-11
May 28, 1999
Intemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
descriptions, and a list of groundwater appropriations, within a S-mile radius of the Mill
site. which are on file with the Utah State Engineer's office. The Titan Report also lists
monitoring wells completed at the Mill and details of monitoring well construction.
NO WELLHEAD PROTECTION AREAS
Attachment 2, the
particular, Water Well No. 2 (WW-2) provides water to the White Mesa Mill from the
Entrada/Navajo Aquifer. The well was constructed in 1980 incorporating the following
features:
{'{,'--,
-.f
i.'
l)
2)
3)
4)
The well was drilled to a depth of 1,885 feet.
The borehole diameter of the r+'ell is l5 inches.
The well casing was set to a depth of 1,250 feet.
The well casing diameter is l0 inches with a nominal wall thickness of 0.250
inches gauge.
The well was packed from 100 feet to 1,250 feet with gravel.
The well was sealed to 100 feet with concrete.
A submersible pump was placed in the well casing at a depth of
approximately 1,000 feet.
The Entrada/1.{avajo Aquifer is separated from the Burro Canyon Formation, which hosts
the perched zone used for monitoring, by an aquitard composed of approximately 1,100
feet of unsaturated shales, clays, siltstone, and sandstones interbedded with significant
shales. The Brushy Basin member (200450 feet thick) is the first section of the aquitard
and is composed of variegated bentonitic mudstone and claystone that prevents the
downward percolation of groundwater. Beneath the Brushy Basin member, the
s)
6)
7\
("DWSPP") describes why there are no wellhead tion areas at the Site. In
S : STAf F[!'RR/TEXT99/G|R599/GlRprA I fnl
Page A-21
iv{ay 28. 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
remaining units of the Morrison and Summerville Formations, which also overlie the
Entrada./Navajo Aquifer, are unsaturated, low-permeability layers, which contain
numerous clay zones, including one 300-foot section consisting of 80 percent clay.
Recharge to the Entrada./Navajo Aquifer occurs many miles from the Mill by infiltration
of precipitation along the flanks of the Abajo, Henry and La Sal Mountains and the flanks
of folds, such as the Comb Ridge Monocline and the San Rafael Swell, where the
permeable formations are exposed at the surface. Recharge does not occur from
infiltration of precipitation falling on the surface of White Mesa.
Subsection 1428(e) of the Safe Drinking Water Act Amendments of 1986 identiff a
"Wellhead Protection Area" or WHPA as:
"the surface and subsurface area surrounding a well or well field,
supplying a public water system, through which contaminants are
reasonably likely to move toward and reach such water well or well field."
ti-
jr:li. Based on the conditions described in this 1999 DWSPP report, contaminants potentially
. ! { Lr,:y--; .---' introduced at the surface would not reach the well or well field of WW-2. Therefore,
there are no potential contamination sources within the protection zones of the wellhead.
According to Dames and Moore, the movement of groundwater occurring at shallow
depths in the Dakota sandstone and Burro Canyon formation at the Mill site is believed to
be confined to isolated zones within White Mesa. These formations are exposed and crop
out in the canyon walls of the surface drainages both east and west of the site. Due to the
location of the site on the northern margin of the northwest-southeast trending Blanding
basin, the near surface formations dip one or two degrees to the south. Beneath the
shallow perched groundwater zone, the Brushy Basin Member of the Morrison formation
is generally impermeable and there are locally impermeable lenses in the base of the
S: STAfF/MR!i/TEXT99/GlRJ99lclRpr{ I fnl
.N
" l'1,,1,{ tL '
Loo ln'"" ,'- '(5,7'u'
br&'r "',|,h)
Pa_ee A-13
Ma,"- 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Burro Canyon formation. Groundwater levels may be highest in the center of the mesa,
coincident with the highest land elevations, and lower to the east and west where
groundwater can drain from the mesa through springs and seeps in the canyons of
Westwater, Cottonwood and Corral Creeks. This is partially substantiated by water
levels measured in drill holes and wells in the project vicinity. As discussed below,
several small, ephemeral springs exist along the canyon walls adjacent to the project site.
SURFACE WATER DRAINAGES
Figure A-4 shows drainages in the vicinity of the Mill. No percanid srrf€so ,$er
drainagea exist on &€ Mill eie. The Mill site is located on White Mesa, a gently sloping
(l% SSW) plateau that is physically defined by the adjacent drainages which have cut
deeply into regional sandstone formations. The lack of perennial surface waters on or in
the vicinity of the Mill site is due to the gentle slope of the mesa on which the Mill is
located, the low averdge annual rainfall of ll.8 inches (29.7 cm) per year at Blanding
(Dames & Moore, 1978), local soil characteristics, and the porous nature of local stream
channels.
The San Juan River is a major tributary of the Upper Colorado River and drains
approximately 23,000 square miles (60,000 sq km) above Bluff, Utah, which is located at
the mouth of Coftonwood Wash. The San Juan River flows in a westerly direction
toward its confluence with the Colorado River at Lake Powell, which is about I 14 river
miles (183 km) west of Bluff.
The entire (860 sq km) with the
southern half being relatively narrow and the northern half being wider. The creek's
headwaters are in the Manti-La Sal National Forest. Elevations within the basin range
from nearly I1,000 feet (3,333 m) mean sea level (msl) at Mt. Linnaeus Peak, to a low of
S STAf F/MRR/TEXT99/G|R590/GlR.A lfnl
i --iL:ja --' ''^;---Y-. /-rr -r,A)&,
f ifrq-:r
r"-.ia')u
RECAPTURE
WATERSHED
CREEK
,
WESTWATER R
WATERSHED
C K
\I
8""*'0"-r#,"ffi Yifl,corPorat
FIGURE 4.4
DraiDsgc lv{ap of thc Vicinity
of the Whitc Mesa Mill
-'l--il'1,=a4
I
SPRING CREEK WATERSHEO
COTTONWOOD WASH WATERSHE
v!.
IEE K
D
l+\jl -iar1
OI USGS GAUGE
.2 USGS GAUGE
03 USGS GAUGE
NO. O9376900
NO. O9378630
NO. O9378700
,I n\<-Jt{=
PROJECT SITE I
OATE: MAY.1999
Page A-l-i
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
about 4,300 feet (1,303 m) msl at the confluence of Cottonwood Wash and the San Juan
River. The creek bottom is at elevation 5,100 feet (1,545 m) msl directly west of the Mill
site. The or nearly 3
percent.
The Recapture Creek drainage zuea encompasses 200 square miles (518 sq km) and
extends for nearly 38 miles (61 km) from its headwaters in the Abajo Mountains on the
north to its confluence with the San Juan River to the south. The basin is very narrow,
measuring less than 7 miles (ll km) wide at its broadest point. Elevations range from
1 1,360 feet (3,442 m) msl at its headwaters on Abajo Peak, to 5,200 feet (1,576 m) msl
directly east of the Mill site, to a low of 4,400 feet (1,333 m) msl at its confluence with
the San Juan River. The overall basin slope is about 163 feet (a9m) per mile, or a little
over 3 percent.
The West'water Creek drainage basin covers nearly 27 square miles (70 sq km) at its
confluence with Cottonwood Wash, about 1.5 miles (2.5 km) west of the Mill site. The
west and northwest portions of the Mill site lie within the Westwater Creek watershed.
The divide between Westwater Creek's drainage area and that of Recapture Creek passes
through the City of Blanding. Runoff originating from within Blanding is collected by
both of these watercourses.
€aa*€peFis a small intermittent tributary of Recapture Creek and collects runofffrom
the eastern half of the project site. The thrinage,araaeof that portion of Corral Creek
aboveandincludingthesiteis@(l3sqkm).Theareaoftheentire_
Corral Creek basin measured at its confluence with Recapture Creek is 6 square miles (15
sq km).
S:STAFFA/IRR/TEXT99/CIRS9olclRpr { I fnl
Page A-26
lvlay 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
The following table summarizes the drainage areas in the general vicinity of the Mill site:
TABLE A-5
DRAINAGE AREAS OF MTLL VICINITY AND REGION
Basin Description
Corral Creek adjacent to Mill site
Corral Creek at confluence with
Recapture Creek
Westwater Creek at confluence with
Coftonwood Wash
Cottonwood Wash at USGS gauge
west of Mill site
Cotton Wash at confluence with
San Juan River
Recapture Creek at USGS gauge
Recapture Creek at Confluence with
San Juan River
San Juan River at USGS gauge
downstream of Bluff, Utah
Drainage Area
Square SquareMiles Kilometers
5.3 t3.7
5.8 15.0
26.6
205
332
3.8
200
23,000
68.8
531
860
9.8
518
60,000
Storm runoff in these streams is characterized by a rapid rise in the flow rates, followed
by rapid recession primarily due to the small storage capacity of the surface soils in the
area. For example, on August l, 1978, a flow of 20,500 cubic feet per second (cfs) (581
m3/sec) was recorded in Cottonwood Wash near Blanding. The average flow for that
day, however, wErs only 16 cfs (0.5 m3/sec)(Dames & Moore, 1978). Flow data are not
available for the two smaller water courses closest to the Mill site, Conal Creek and
S r STATFA{Rn"ITEXT99/G!R5e9/GIRFA I fnl
Page A-37
May'28, 1999
Intemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Westwater Creek, because these streams carry water infrequently and only in response to
local heavy rainfall and snowmelt, which occurs primarily in the months of April,
August, and October. Flow typically ceases in Corral and Westwater Creeks within 6 to
48 hours after precipitation or snowrnelt ends.
S STA.F FAlRi,/TEXt94/GlR599/GtRtrA I fnl
Page B-i
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
PART B: GENERAL DISCHARGE INFORMATION
INTRODUCTION
The GWDP Application Information form (Appendix A of the Ground IAarcr Qualiry
Protection Permitting Information Document, UDEQ, January 1996) aslcs _fa,
informationfor"eachpointofdischargetogroundwater.". \ o,1,, , , , -.t t"t \
lp .,.rt'.,' ?'eso'") 9'' '; :' n St*J*'; Jt t'^'il:' *-,,a'l
The Mill is a zero disc(arge facility. In 20 years of monitoring, there have been no \
detections of releases to groundwater. Moreover, there is no probable caulie to believeT] L, )
that the tailings cells at the White Mesa Mill will ever discharge to groundwater (see
Attachment 3, letter from IUSA to UDEQ dated October 31, 1998 and Attachment 4,
letter from IUSA to UDEQ dated March 19, 1999).
As described in the letter of October 31, 1998, -L- ua:' l llrrnli
FAt rli.J-t dt
rEfl'r;'-*--t|. tf i'' Ui
Statutorv Provisions
The October 31 letter explains that the statutory authority for the State to promulgate the
groundwater discharge regulations is the Utah Water Quality Act, which provides that:
it is unlawful for any person to discharge a pollutant into waters of the
state or to cause pollution which constitutes a menace to public health and
welfare, or is harmful to wildlife, fish or aquatic life, or impairs domestic,
agricultual, industrial, recreational, or other beneficial uses of water, or to
place or cause to be placed any wastes in a location where there is
d l" 71't
"64,
s sTAf F/r,rRR/TEXTee/Gn5e9/Gt?{ Bfnr
Pagc'B-l
NIay 28, 1999
Intemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater I nformation Report
probable cause to believe it will cause pollution, unless authorized under
the Act or regulations.
Utah Code Ann. Section l9-5-107(l). "Waters of the State":
a) means all streams, lakes, ponds...and all other bodies or accumulations of
water, surface and underground, natural or artificial, public or private, which
are contained within, flow through, or border upon the state or any portion of
the state; and
b) does not include bodies of water confined to and retained within the limits of
private property, and which do not develop into or constitute a nuisance, a
public health hazard, or a menace to fish or wildlife.
As is evident from previous correspondence between IUSA and UDEQ, it is IUSA's
position that it is not required to obtain a groundwater discharge permit, for several
reasons. including the following:
I
I
r.. b"1 /'" t , a)\)r-rt r I Ir r"t i'r Li..'i Irrtsr'-'y''
1\ ,
^r' a
i..1.
The Mill should be permitted bv rule. IUSA and its predecessors have conducted
groundwater monitoring at the Mill for a number of years, and there is no
evidence that the tailings impoundments are impacting groundwater. The existing
n,ilgroundwater data demonstrate that the Mill will have, at most, a de minimrtz'. -lr r
potential effect on groundwater quality, so IUSA should be entitled to a permit by
-
There is no potential for discharge to waters of the State. The State requires a
groundwater discharge permit for facilities which discharge or would probably
result in a discharge of pollutants that may move directly or indirectly into
b)
s STAf FA{RR/TExT99/crR5e9/clRpr8fnl
*'",11:iB;;
lnternational Uranium (USA) Ctrporation
White Mesa Uranium Mill
Groundwater Information Report
-.1 ;,\,;---P,r,,n:,-?^J.i,."1 , i;x)iio,;., '"'' ,e'
groundrvater. There have been no discharges to groundwater from the Mill, nor
is there probable cause to believe that the activities at the Mill will result in such a
discharge.
Data Demonstrate No Discharse to Groundwater
Monitoring from 1979 to 1997
The Mill has collected over 20 years of groundwater monitoring data, which show that no
tailings constituents have been released to groundwater.
o Pre-operational groundwater sampling of surface water, groundwater seeps,
perched zone wells, and deep wells, began in 1977 and continued until the Mill
started up in June 1980. These analyses were confirmed by the Utah state
Division of Environmental Health Laboratorv.
r d l98l background study reviewed water quality data before and after startup
to confirm that the Mill introduced no new impacts to groundwater.
. The Mill has collected and reported quarterly water quality data to the NRC
continuously for 20 years since startup. Twenty years of data have never
shown a statistically significant increase in any of the constituents from the
-, perched zone orthe deep aquifer.)'
Groundwater monitoring of the Burro Canyon formation perched zone has been
conducted at the White Mesa facility since 1979. Table B-1 (Titan Report Table 2.3)
provides a list of wells that have been constructed for the purpose of the facility. Figure
'q' 4r, Ilo
or_., ., "/')
t Al*L\P1)-/
gsc t a't-:
,.'.,,:
-'/'
l-,i'''rts.i'
- fL'
"-,i :T
- "''ri
,.. ci Iu-
l\
't1 i'
S.STAf Ft1l{R R/TEXT9rycln599/ctR1nBfnl
Table B-1
Monitoring Well and Ground Water Elevation Data
White Mesa Uranium Mill
Well Name Date Total Per{orations
Installed Denth
Water Levcl Measuring Point
Depth Elevrtion
Date (ft) (ft-MSL)
Above Elevrtion
LDS (fr) (fL-MSL)
2.0 561E.22
1.8 5613.49
2.0 5555.32
t.6 5622.57
5609.33
WI\,!MW-l
WMlvfW-2
WMIvfW-3
\"rrN,II\rIW4
wtv{Mw-5
WMlvfW6
WMlvfW-7
rlMtutw-8
wMMW-ll
WMlvfW-12
wlvIMW-13
Sep79
Sep79
Sep79
Sep-79
lvlay-80
lvIay-80
May-80
May-80
Oct-82
Oct'82
Oct-82
tL7'.
128.8',
98',
t23.6',
136',
135'
130.3'
I18.5'
129. l'
138'
33.5',
62.7'
33.5',
62.z'.
92'-ll2'
g5'-125'
67',-87',
92'.-12'
g0'-120'
99L129'
l0'-30'
39.7'.-59.7"
I1.3L31.3'
39.z',-59.2'
rvt9t92
tUt9l92
nlL9t92
LUt9l92
tvt9l92
tvt9l92
7lLU92
tv30t92
ttB0l92
10fiu92
3l4t9t
3t4t9l
314l9t
3l4t9t
95.5'-133.5', llll9l92 108.32 0.6
This well was desuoyed during construction of Cell 3.
This well was destroyed during construction of Cell 3.
This well was destroyed during construction of Cell 3.
75.45 5572.77
I10.06 5503.'t3
83.74 5471.58
92.42 5s30.15
r05.34 5491.05
108.28 5490.34
Dry
87.56
92.1 1
85.00
Dry
Dry
Dry
Dry
5596.39
5598.62
1.5
1.5
1.5
t.5
l.E 5622.83
2 5622.58
2 5633.58
2.t s633.39
90.7'-130.4' tllt9l92 102.53 5508.55
84'-124' LUt9t92 109.68 5499.77
2.{
0.9
5611.08
5609.45
This well uas destroyed during construction of Cell 4A.
WMlvfW-I4 SepE9
WMN{W-IS Sep89
0.0
0.8
!!i\4MW-16
WMI\,ftV-17
wMNflv-18
WMMW-19
#9-l
#9-2
#10-2
#t0-2
Dec-92
Dec-92
Dec-92
Dec-92
tvlay-8O
tvlay-80
tvlay{0
May-80
g l.5' 78.5'-88.5'
I l0' 90'-100'
148.5' 103.5L133.5'
149' l0l'-l3l'
Notes:l. Well locations provided on Figure 1.5.3-1.2. LDS = leak detection sJstem.
ft.-MSL = feet - mean sea level.
Adapted from: Table 2.3,Hydrogeologic Evaluation
\\ _f,r,,
C\ o r'a ,l
i.l ' ',)'-- lr\1 ] - fr-' Iqlu' :
Page B--i
lvlay 28, 1999
Intemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
B-l indicates the locations of these wells. The water quality data obtained from these
rvells are provided both in tabular and graphical form in Appendix B of the Titan Report.
Examination of the spatial distribution and temporal trends (or lack thereof) in
concentrations of analyzed constituents provides three significant conclusions:
l) The quality of perched water throughout the site shows no discernible pauem
in variation,
2) The water quality is generally of poor quality [moderately high values of
chloride, sulfate, and totally dissolved solids (TDS)1, and
-,. 3) Analytical results shows that operations at the White Mesa Uranium Mill have
,, ', _) not impacted the quality of the perched zone.
To arrive at these conclusions, comparisons of the water chemistries from the various
wells were analyzed by graphical techniques (seg Titan Report, Section 2.2.1). The
purpose of the comparisons was to determine if trends in chloride, which would be
associated with water from the tailings ponds, were increasing in the perched zone.
S : STAr FA{RPTEXTg9/GlR599/GlR$aftrl
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ta
FIGURE 8.1
rl.hi|,e Vesa Mill
giLe Plon Ya? shoning
VoniLor Aells and Borings
SCALErc
2OOO O 2OOO QOO leeL
Po.
^r:' DAMES AND MooRE t97B BoRlNGs
ci'"' wATER suppLy wELLs o'APPoLoNtA (tgEt)
,.''o-t ExlsrrNc MoNrroRrNG wELLs
#- ExrsTrNc wATER suPPLY wELLS
E STOCK WELLS
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Page B-7
NIay 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Point of Compliance Proeram Instituted in 1997
The Mill's Point of Compliance ("PoC") proposal (Titan, 1994) (the "poC report"),
which has been accepted by NRC as the basis for the Mill's ongoing detection monitoring
program, was developed based on a reevaluation of all of the existing groundwater data
reviewed as of the Spring of 1995, and incorporated NRC's comments from a meeting of
August 11, 1994, and site visit of September 20, 1994. The PoC proposal package
included copies of two EPA guidance documents which, in addition to NRC guidance,
were used to develop the monitoring and statistical approaches presented in the POC
report.
The Mill switched to Point of Compliance Monitoring in 1997, after reviewing 14 years
of quarterly data on up to 20 chemical and radiological constituents in up to 13 wells
rvhich indicated that:
The Mill and tailings system have produced no impacts to perched zone or deep
aquifer.
The most dependable indicators of water quality and potential cell failure would
be chloride, nickel, potassium and natural uranium.
Statistical Analysis
Because of the variable groundwater chemistry indicated in the Burro Canyon formation
baseline data, comparison of individual well groundwater chemistries to a single
background groundwater well is not an appropriate method of monitoring potential
disposal cell leakage or groundwater impacts. Water quality baseline and comparisons to
s. sTAf F/IViRR./TEXTee/GlR599/clRprBftrt
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-...-..-.
Page B-8
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
that baseline established on a well-by-well basis was approved for the POC, as this
method best provides a meaningful representation of changes in groundwater chemistry.
Based on a review of water quality data gathered from 1979 through 1992, which are
presented in the Titan Report, and considering the apparent variability of chemical
composition of perched water and the absence of any impact from operations, IUC
applies an intra-well approach for assessing water quality trends. This approach,
described in POC report (Titan, 1994), involves determination of background
concentrations for a number of selected wells, using a methodology recommended by the
U.S. Environmental Protection Agency (EPA).
Location and Rationale of POCs
The POCs for the White Mesa Uranium Mill are the existing monitoring wells WMMW-
5, WMMW-I1, WMMW-I2, WMMW-l4, WMMW-IS, and WMMW-I7. The locations
of the POC wells are shown in Figure B-1.
The POC locations were chosen based on the guidance set forth in the document entitled
"RCRA Ground-Water Monitoring: Draft Technical Guidance" (EPA, 1992)! The POC
monitoring wells are located hydraulically downgradient of and adjacent to tailings
disposal cells No. 3 and No. 4A', and are screened in the perched groundwater zone.
These wells are monitored quarterly for the indicator constituents chloride, potassium,
nickel, and uranium. As stated above, statistical methods recorlmended by the EPA are
employed to evaluate whether the perched groundwater zone has been affected by cell
leakage.
The purpose of groundwater monitoring is to provide timely detection of potential
releases to the uppermost aquifer. The uppermost usable aquifer beneath the Mill is the
S : STAFF/MRI /TEXT99/GIR 599/GlRpafd
-"1.
)r)
Page B-9
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Entrada./Navajo sandstone. The Burro Canyon formation is approximately 1,200 feet
above the aquifer, at depths of 9l to l4l feet below land surface, and hosts small volumes
of poor-quality perched water. The POC monitoring wells are completed in the perched
groundwater zone of the Burro Canyon formation. In terms of detection monitoring, the
perched groundwater zone provides the earliest horizon for detection of tailings cell
leakage relative to the Entrada./Navajo aquifer.
As summarized in the POC report and in Section 1.3 of the Titan Report, this uppermost,
discontinuous zone of water encountered beneath the tailings disposal areas at the Mill
does not constitute an aquifer, due to poor water quality and minimal to zero yield.
Although the perched zone transmits insufficient water to be an aquifer, this zone is
usable for very early detection of any potential releases from the tailings disposal cells at
the Mill. Indeed, any release detected in this zone would be identified in an area
separated from the Entrada./l.,lavajo aquifer by approximately 1,200 feet of very low-
permeabi I ity, bentbnitic mudstones and c laystones.
Downgradient of the Mill, (i.e., between the Mill and dissecting canyons), the
groundrvater in the perched zone cannot be used for irrigation or domestic consumption
because of the natural poor quality of the water and low yield rates. Documented
pumping rates from monitoring wells completed in the Burro Canyon Formation are less
than 0.5 gallons per minute (gpm); even at this low rate, the wells are typically pumped
dry in a period of minutes to less than nvo hours.
At the Mill site, the tailings cells are located within the unsaturated Dakota Sandstone,
which overlies the Buno Canyon Formation. If leakage were to occur from the tailings
cells, tailings-related constituents would have to migrate vertically through approximately
I l0 feet of unsaturated material before reaching the perched groundwater zone.
S STAFF/MR"I"/TEXr90/ClR599/GlRdBfnl
Page B-10
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
The findings of the Titan Report were that the tailings located in the existing disposal
cells are not impacting groundwater at the site. In addition, it did not appear that future
impacts to groundwater would be expected as a result of continuing operations. These
conclusions were based on chemical and hydrologic data which showed that:
a) The chemistry of perched groundwater encountered below the site does not show
concentrations or increasing trends in concentrations of constituents that would
indicate seepage from the existing disposal cells;
b) The usable aquifer at the site is separated from the facility by approximately 1,200
feet of unsaturated, low-permeability rock;
c) The usable aquifer is under artesian pressure and, therefore, has an upward
pressure gradient which would inhibit downward migration of constituents into
the aquifer; and
d) At the time of the analysis in 1994, the facility had operated for a period of 15
years and had caused no impacts to groundwater during this period.
0c
L,'t t '
L-/Y
Continued POC monitoring at the site is performed to verifr that past, current and future
operations will not impact gloundwater. At this time, twenty years of operation and
monitoring of the perched water zone (located some 1,200 feet above the Entrada/l{avajo
Aquifer) have given no indications that the tailings cells in use at the Mill have ever
released tailings liquid to the perched zone. The likelihood of impact to the
Entrada/l'{avajo Aquifer, some 1,300 feet below the site, which is separated from the
tailings impoundments by up to 1,200 feet of very low permeability shales, claystones,
and mudstones, is extremely remote.
S : STAFFnttRn /TEXT99/GlR599/GlR/Ahl
Page B-l I
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
No Probable Cause to Believe the White Mesa Mill Will Discharge Pollutants to
Groundwater
During September and October, 1998, a team of licensed professional engineers and
experienced groundwater professionals from Ifuight Pidsold performed an independent
review of cell construction for cells l, 2 and 3, as well as an updated analysis of
performance of those cells. The Ifuight Pi6sold report (the "Knight Pidsold Report"),
has been previously submitted to UDEQ, but is also included herewith as Attachment 5
for ease of reference. Cell 4 was not reviewed in detail by Knight Pi6sold, because it is
not in use. A thorough evaluation of that cell will be completed prior to its being put into
use.
With respect to the construction of those cells currently in use, Knight Pi€sold found that:
Cells l, 2 and 3 were designed and constructed with emphasis on
containment of liquid. The constnrction of each component of the cell
structrues and lining systems was well documented,,with a lwel of detail ,
in Qc of the liner that weo exeaptioaal at.tlrs tirre the cells were
constructed. There are no defects evident in the records of design or
constructio& as evidenced by both [Knight Pi6sold's] review and the
inspections made by the NRC at the time of construction. Therefore, there
is no support for any claim that design or constnrction of the cells was in
any way substandard.
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S : Sf Af F/MRRITEXT9/GIRS9ryGlRprafnl
Page B-12
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
.-' I 6r
,A- ,-,q ll2'
^1(={" ,4 {t,K"ight Piesold also reviewed the perfonnance of the Leak Detection System ("LDS"),
4'Y. \fu1"'*d concluded that there arc "no indieations that taitings cells are discharging tailings
^ \oe,i('i \ I^ L
; $\4, ^ ' liquid to either the LDS or the underlying formation".t-Z
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Following the review of cell construction, Knight Pi6sold conducted a detailed review of t r / j
the performance of the cells, including modeling of cell 3. The cell 3 modeling results -'-ff,,
werc extrapolated to cells I and 2. The following is a sunmary of lfuight Pidsold's _ J;.Ao* .
conclusions:i,r-n, ! 'r
a) Since the cells were constructed in the early 80's there has been no indications
that tailings cells were or are discharging tailings liquid to either the LDS or the
underlying formation;
b)has been thoroughly analyzed and
- url^}'' g {h'-t Sa-^n'c'e- ? tr/o C t''
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\r . Y"u'f)r -
lnro ol' | .'r- ."6
r- l. \.{i {'^.Mjl?tt ' ',0 r '".;,.'V: ci.l&' '
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.! fi"i ---"^|./.
Recent modifiTlig.ll lo the operating permit are based on sound engineering
principles and are more likely to detect leakage through a damaged liner than
@occurring irr
during the period suggested that if
ffio.zs gpm). This rate is considere d, de minimis and intrerent for PVC liners
by the EPA. Based on Iftright Pidsold's modeling, the total volumetric flux since -
beginning of cell use would represent only 4 percent of the specific rctention
(i.e., permanent pore storage) in the trnderlying sandstone. Hence, 96 percent of
the permanent pore storage would be available for future moisture, if any, which
d)
S:STAFF/MRX/TEXT99,E|R'9orcIRFBfril
I
', .. .,i6',u, ",
Page B-13
May 28, 1999
lntemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
may migrate below the cell's liner.
e) Cessation of the discharge of any liquids upon termination of cell operating life
and reclamation of tailings will result in a gradually diminishing rate of any
volumetric flux that may occur during the post-operation period.
+'{ed| If the status quo were to continue, any volumetric flux through the Cell 3 liner
that were to occur, based on Knight Pi€sold's modeling, might require at least 400
years after closure to fill the remaining sandstone pores such that unsaturated flow
downward toward the perched water zone could commence
g) Unsaturated flow, if it were to exist, based on Ifuight Pi6sold's modeling, would
require an additional 299:qars*to travel the I l0 vertical feet to the nerc$d y,ater-
bearing zone after sandstone moisture is raised to a degree facilitatiri-g dotvriward
movement of moisture. In other words, a total of 1,300 years would be required
before any potential volumetric flux from a reclaimed cell could reach the perched
water zone below the site.
h) Dissolved metals in tailings water are unlikely to be transported through the I l0-
ft vadose zone due to significant attenuation from a number of potential processes
documented to exist when moisture moves at a very slow rate through a very low .jt
permeability media. These processes include a combination of microfiltatiod ' . t .
tluough the PVC liner, 4dgqIplLi-on to soil particles, c.atigl %ghal1ge, lp!.g!t"l - o;-;"" ::rcaC =6{
15f _veaiqal di,spersion due to heterogeneities of rock, and oxidatisn--reduclfon -9:
A !-t- -l\lilr_,,,Processes' [ , ;oi.,,.,- str{*,lf,
1?6u'-' llru, \n,b .[n. r.- [),, ". -,
(ut;'tt{ t r
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S :STAFF/MRUTEXI99/'GIRS9{GlRgrBfnl
Page B-l.t
May 28, 1999
Intemational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
i) Since Cells Nos. I and 2 are smaller and the hydraulic heads of liquids present in
those cells are also lower, estimated potential flux rates from Cells I and 2 will be
correspondingly lower than those which may occur for Cell 3.
In summary, as is evidenced by the volumes of groundwater data provided to the State of
Utah Division of Radiation Control (DRC) by IUSA and its predecessor licensees at the
Mill, and reinforced by a review by independent registered professional engineers and
experienced groundwater professionals, there is absolutely no evidence that the Mill hai
ever caused a discharge of pollutants to groundwater, nor that there is probable cause to
believe that the Mill will discharge pollutants to the waters of the State. The groundwater
conditions at the Mill are monitored closely under NRC regulations. (
^,
. ,= 71i7 lt tt: -
t \, t ,-1 ,
C.o-, 1-(-a,tt , r" a i,, 9
{n^. }\
Although IUSA has 20 years of data to show no impacts to groundwater, IUSA
voluntarily agreed to a recent request by UDEQ to allow the State to perform split
sampling of groundwater at 17 wells on or around the White Mesa Mill property. The
program was proposed to involve the following sampling:
o Six monitoring wells in the perched zone at the Mill, that IUSA currently
monitors quarterly for water quality reporting to the NRC;
. Eight additional monitoring wells in the perched zone at the Mill, that ruSA
does not currently sample;
o Two supply wells in the deep Entada/l.Iavajo Aquifer at the Mill; and
l
Ct'+i'
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.z: frr"of,,)l-a lcn"n'
Cooperative Studies with UDEO
S : STA! FMR&TEXT9o/G!R59e/GIRpBfnl
Page B-15
May 28, 1999
International Uranium (US A) Corporation
White Mesa Uranium Mill
Groundwater Information Report
o Two supply wells in the deep Entrada.0.lavajo Aquifer at the White Mesa,Ute
community. *f [i'. ,\,/{r--' i" - " i"'li:]'"
IUSA and UDEQ developed an agreement to analyze the well samples for volatile
organic compounds, semi-volatile organic compounds, pesticides, herbicides, radio-
nuclides, ions, heavy metals, and other parameters. With the exception of sampling the
deep wells at the White Mesa Ute Community, for which UDEQ had not yet obtained
Tribal approval, the initial sampling event took place in mid-May 1999.
l. Location
The location of the White Mesa Mill and the tailings cells is described above in Part
A(l). The locations of the partially below-grade, lined tailings cells, which are
nondischarging cells, and which are monitored under a Point of Compliance Monitoring
Plan, described in the POC report, as well as being subject to a Reclamation Plan, are
indicated on Figure A-3 in Part A.
2. Type of Fluid to be Discharged or Potentiolly Discharged
The only potential discharge from the tailings cells at the White Mesa Mill.would be
tailings water from NRC-regulated I le.(2) tailings disposal cells. There is no discharge
or potential discharge from materials meeting the definitions of sanitary wastewater,
cooling water, process water, mine water, solid waste leachates, mining leachates, storage
pile leachates, or potential underground storage tank leakage.
The lfuight Pi6sold Report is an independent review of tailings cell performance at the
White Mesa Mill. This evaluation included modeling of hypothetical discharge of tailings
water from Cell 3, and extrapolated Cell 3 modeling results to Cells I and 2. Based on
S : STAr F/MR.R/TEXT9e/GIR599/GIR6afnl
Page B-16
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
this report and other data, IUSA has concluded that there is no probable cause to believe
that the tailings cells will discharge pollutants to the groundwater.
3. Discharge Volumes
I
,'r.;fi 4 ae'vn't n .
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; b, 1,..^ [6t&I{ t
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'l.i
This section requires thatfor each type of discharge checked in #2 above, the applicant is
to list the volumes of wastewater discharged to the ground or groundwater. Volumes of
wastewater should be measured or calculatedfrom water usage.
)/+
As defined in this section, IUSA would check none of the discharges in #2, and would II
respond that IUSA hasrhad and will have no discharges of fluids to the ground *_)
groundwater. :
4. Potential Discharge Volumes
UDEQ aslro that for each We of discharge checked in #2 above, the owner list the
volumes of wastewater discharged to the ground or groundwater. This section also
requests that for each type of potential discharge checked in #2 above, the applicant is to
list the muimum volume offluid that could be discharged to the ground corcidering such
foctors as: liner lrydraulic conductivity and operating head conditions, leak detection
system sensitivity, leachate collection system eficienqt, etc. Calculations and rau, data
used to determine said potential discharge should be attached.
Volumes of wastewater should be measured from water usage. If it is necessary to
estimate volumes, the owner is asked to enclose the number in parentheses. Average
daily volume means the arcrage per operating day; ex. For a discharge of 1,000,000
gallons per year from a facility operating 200 days, the average daily volume is 5,000
gallons.
S : STAf F/MRn/TEXT99/GlR59AGlRprEfnl
Page B-17
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
In addition, UDEQ asl<s that for each type of potential discharge checked in #2 above,
the owner list the maximum volume of fluid that could be discharged to the ground
considering suchfactors as: liner hydraulic conductivity and operating head conditions,
leak detection system sensitivity, leachate collection system eficiency, etc. Attach
calculation and raw data used to determine said potential discharge.
DISCHARGE POTENTIAL
i
The Ifuight Pi6sold Report evaluated the potential for discharge of tailings fluid to the ?'
*^ - n:
ground, considering the above factors, as well as liner installation quality control. l^'''"i--,,rt;,'' Rip61 '; L'..
Calculationsanddatausedtoevaluatethepotentialfordischargefromthetailings,.l..
impoundments were detailed in the section entitled Modeline of Potential Volunetric z-:.; i,',,, '
Flux in the lfuight Pidsold Report and February 12, lggg responses to UDEQ questions. '' i * " t '
,
These are included with the Knight Pidsold Report in Attachment 5.
I. ts*d/
\-\_-.-"__
The Knight Pi€sold evaluation included modeling of hypothetical discharge of tailings
water from Cell 3, and extrapolated Cell 3 modeling results to Cells I and 2. Modeling
of potential volumetric flux is provided on pages 7-10 of the evaluation. The reader is
referred to those calculations. UDEQ has previously sent questions to IUC regarding
selected aspects of the Knight Pidsold Report. Copies of the relevant correspondence are
included as {{39'b4ent 6 to this report. This evaluation indicated that there is no
probable calrse to believe that discharge of tailings water to the underlying perched water
zone in the Burro Canyon Sandstone will occur during the operational life of the cell.
Future reclamation of tailings will eliminate the potential for future discharge. Should
the cells be reclaimed with water retained in the cells, the modeling indicates that
discharge to the perched mrre, if it were to occur, would not be possible for
approximately 1,300 years after clostue. Even then, discharge of any chemical
S STAFF/MRn /TEXT,lD/GlR599/GlRerBfol
Page B-l 8
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
constituents is not likely due
attenuation in the vadose zone.
to microfiltration by
I->= r-q , ?.- f,
the low permeability liner
,'. !,.,.;,, |.,: fl ,." :l
and
-' , l< (!-'.- "
5. Means of Discharge or Potential Discharge
As discussed above, three lined, monitored surface impoundments have been constructed
and used for operations at the Mill. A fourth impoundment, Cell 4A,, was constructed in
1989, but has not been used for Mill onerrations to date. Any potential discharge would
have to come from these sources,
Report.
whibh have been analyzed in the lftright Pidsold
j""
6. Flows, Sources of Pollution, and Treatment Technologies
For Jlows, UDEO requests a line drawing showing: l) water flow through the facility to
the groundwater discharge point. UDEQ asl<s for sources of intake materials or water,
operations contributing wastes or wastewater to the effluent, and wastewater treatment
units. A water balance on the line drawing is to be constructed by showing a,verage /lows
between intalces, operations, treatment units, and wastewater outfalls. UDEQ states that
if a water balance cannot be determined, a pictorial description of the nature and amount
of any sources of water and arry collection or treatment measures should be provided.
Mill operations, processes, and materials used in the process were described previously in
Part A(7). A water balance is depicted in Figures B-2 and B-3, Block Flowsheet and
Flow Balance. The Block Flowsheet and Flow Balance represent the design approved for
construction, assuming a 2,000 ton per day operation. The Mill has typically operated
well below this capacity. It should be noted that minor modifications have been made to
this design, weh as minor equiprnent changoe, but none of these have significantly
altered the flows depicted.
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Page B-11
Ivlay 28. 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
7. Discharge EflluentCharacteristics
Established and Proposed Ground lV'ater Quality Standards
t-JDEQ asl<s the owner to identifi wastewater or leachate characteristics by providing the
ry\pe, source, chemical, physical, radiological, and toxic characteristics of wastewater or
leachate to be discharged or potentially discharged to groundwater (with lab analytical
data if possible). UDEQ states that this should include the discharge rate or
combination of discharges, and the expected concentrations of any pollutant.
I le.(2) Tailinss Water Characteristics
The type, source, chemical, and radiological characteristics of the byproduct materials
and tailings solution to be stored in the Mill tailing cells is described above in Section
A.(7). Lab analytical data were produced in September of 1991, based on samples
obtained from the Cell 2 Slimes Drain. These datq which are the only analytical data
available directly reflecting the composition of the I le.(2) byproduct tailings sands and
solution stored in the Mill tailing cells, are included in Appendix B of the Titan Report.
A copy of the data page, taken from Appendix B of the Titan Report, is included for ,
convenienceherewithasAttachment6. -J*^*rc^'yuL1,t-obl - t*'l nj !'"6"'+ Qb5*^'pl
,,- J,/Jn, ri 5'!olc,'l l^'irr't r' -' J)rl:r"ll
1,lj f.,,....
Hazardous Substances
UDEQ requests that hazardous substances found in the Clean Water Act which are either
found or believed to be found in the discharge or potential discharge be identifieQ
.,- *:!,';," ,',)'''-" ;'o),i*', tu,./'The parameters shown as detected in the Slime6 Drain were compared with Tables
I16.4A-List of Hazardous Substances and 116.4-8, found in Title 40, Code of Federal
!
)* i
I
t j.1 ar/l
f e. .I
{}'l
crl I
S STAf FA,iRR./TEXT99/G1R.599/CIn Fgfnt
,"ilil ?;;;
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Regulations, Section 116.4, Designation of Hazardous Substances. The parameters
analyzed and dgtected in the tailings slimes which are listed in these tables *. gro.r- ?
a I p ha, ac eto ne J Ih br of o#,to tuen{ain-butyl phthaht(p h"K ^anaphthal er6,
il\wu *c',L,W- Tlql r'd-*- *-)7 r',, kl n7 14 -a U^* n'epi
- o ls, ^* J t /*/ € 4^- ffJ,L '+-"-J;- nt ll
a rfu'N\:ttY{.
,/ - (T lAri c r'c iJ
,?l
Q,\^,- r' !-+., ///
S : STMF/MR&TEXTrr9/O|R599/GnDrBfot
O
Page C-l
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
PART C: ACCOMPANYING REPORTS AND PLANS
UDEQ states that reports and plans describing the items listed in Part C should be
prepared by or under the direction of a professional engineer or other ground water
professional. UDEQ commenls that since groundwater permits cover "a large variety of
discharges (sic) activities, the appropriate details and requirements of the /ollowing
reports and plans will be covered in the pre4esign meeting(s)".
IUC notes that the reports referenced n this or other sections of this information package
were prepared by a number of professional engineers and/or other groundwater
professionals, using established methodologies, incorporating reasonable levels of
conservatism. The reports referenced in this and previous sections, with the exception of
Ietters specifically to Utah DEQ, and the Knight Pidsold Report, have been submitted as
permitting documents to the NRC. The NRC technical experts have conducted detailed
reviews of these documents. In addition, as described in the Knight Pidsold Repor!
designs, specifications, and quality control plans were reviewed in pre-design meetings
and post-construction reviews by the NRC.
8. Hydrogeologic Report
UDEQ asks tor geologic description, with references used, that includes as appropriate:
Structural geologt (i.e., regional and local, particularly faults, fractures, joints and
bedding plane joints; Stratigraphy (i.e., geologic formatiotts and thickness, soil types and
thiclorcss, depth to bedrock); Topography (i.e., a map which identifies /acility
boundaries, the 100 year flood plain area and applicable flod control or drainage
barriers, and strrounding land uses. lVell logs should be included if available, and
UDEQ aslrs /or aquifer name and characteristics, inchding saturated thickness, flal
directions, porosity, hydraulic condactivity, hydraulic communication with or isolation
STSTAFFAIRn /TEXT99/GlR599/GlRtrCl
Page C-2
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
from other aquifers or sarface sources, recharge information, water in storage, usage,
and the projected aerial extent of the aquifer.
HYDROGEOLOGIC REPORTS PREVIOUSLY SUBMITTED TO UDEQ
Hydrogeologic reports previously submitted to UDEQ contain many of the categories of
information requested.
Section 1.0 of the Titan Report presents a description and definition of the site
hydrostratigraphy, and occurrence of groundwater as it relates to the natural and
manmade safeguards which protect groundwater resources from any potential discharge
from the tailings cells at the Mill. Geologic setting and structural geology is described in
Section 1.2 and shown on Figure l.l of the Titan Report. Local geologic structure is
described in Section 1.2.2. Stratigraphy is detailed in Section 1.2.1, and shown on Figure
1.2. Copies of Figure Ll and 1.2 from the Titan Report are included herewith as
AttachmentT.-- ltA'L x Lr' = l>diytrrl{',-- Ain)6<
,' , r .. -' /! ..- r r..,. LLIi /"j''t"t t/''
,"/ P*"'
-and Semi-Annual Eftluent Report(s), all of which have been provided to UDEQ, contain
details including groundwater depths, flow directions and gradients; well logs; flow
characteristics including aquifer name and saturated thickness, flow directions, porosity,
hydraulic conductivity; confining units preventing communication of the perched zone of
groundwater with the aquifer; recharge information; water usage; and aerial elitent of the
aquifer. Water elevations and piezometric surfaces for both the unconfined perched zone
used for groundwater monitoring and the confined EntradaA.lavajo aquifer, respectively,
are presented in these reports. These reports demonstrate that no groundwater has been
affected by potential discharge from the tailings cetls.
The Titan Report; the POC report; Hydrogeology of White Mesa #ill (Umetco, L99Z);
/-!
I
S:STAFFATRR /TEXT99iclR99ClRplC I
Page C-3
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
In particular, Section 1.0 of the Titan Report describes the geologic, hydrogeologic, and
climatological setting of the Mill. Section 2.0 of the Titan report evaluates groundwater
occurrence in the uppermost sandstone units, which hosts a thin, discontinuous zone of
poor-quality water used for monitoring; the aquitard properties of the underlying thick
sequence of shales, mudstones, and claystones; and the aquifer properties of the deep
Entrada./1.{avajo aquifer, located more than 1,200 feet below the Mill. The quality of the
perched groundwater is described in Section 2.2 of the Titan Report and in Section 2.2 of
the POC report. Water quality data are contained in Appendices of each report. The
reports contain groundwater monitoring data collected since as far back as 1979, from
collection points located both hydraulically upgradient and downgradient, and within a
one-mile radius of the tailings cells. These historic data should meet the requirements of
Section 8.
I 978 ENVIRON},{ENTAL REPORT
The 1978 Environmental Report prepared in support of the Environmental Assessment
reported extensively on regional and local geology and stratigraphy. For ease of
reference, geologic discussions from the Environmental Report are contained below.
Geoloey
The following text is copied, with minor revisions, from the Environmental Report
(Dames and Moore, 1978) (ER). The text has been duplicated herein for ease of
reference and to provide background information concerning the site geology. ER
Subsections used in the following text are shown in parentheses immediately following
the subsection titles.
S:STAFF4TIRR,/TEXT99/GIR599/GIR,PIC I
Page C-4
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
The site is near the western margin of the Blanding Basin in southeastern Utah and within
the Monticello uranium-mining district. Thousands of feet of multi-colored marine and
non-marine sedimentary rocks have been uplifted and warped, and subsequent erosion
has carved a spectacular landscape for which the region is famous. Another unique
feature of the region is the wide-spread presence of unusually large accumulations of
uranium-bearing minerals.
Regional Geology
The following descriptions of regional physiography; rock units, and structure and
tectonics are reproduced from the ER for ease of reference and as a review of regional
geology.
Physiography (ER Section 2.4.1.1)
The Mill site is within the Canyon Lands section of the Colorado Ptateau physiographic
province. To the north, this section is distinctly bounded by the Book Cliffs and Grand
Mesa of the Uinta Basin; western margins are defined by the tectonically controlled High
Plateaus section, and the southern boundary is arbitrarily defined along the San Juan
River. The eastern boundary is less distinct where the elevated surface of the Canyon
Lands section merges with the Southern Rocky Mountain province.
Canyon Lands has undergone epeirogenic uplift and subsequent major erosion has
produced the region's characteristic angular topography reflected by high plateaus, mesas,
buttes, structural benches, and deep canyons incised into flat-taying sedimentary rocks oi
pre-Tertiary age. Elevations range from approximately 3,000 feet (914 meters) in the
bottom of the deeper canyons along the southwestern margins of the section to more than
I1,000 feet (3,353 meters) in the topographically anomalous laccolithic Henry, Abajo and
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May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
La Sal Mountains to the northeast. Except for the deeper canyons and isolated mountain
peaks, an average elevation in excess of 500 feet (1,524 meters) persists over most of the
Canyon Lands section.
On a more localized regional basis, the Mill site is located near the western edge of the
Blanding Basin, sometimes referred to as the Great Sage Plain (Eardly, 1958), lying east
of the north-south trending Monument Uplift, south of the Abajo Mountains and adjacent
to the northwesterly+rending Paradox Fold and Fault Belt (Figure C-l).
Topographically, the Abajo Mountains are the most prominent feature in the region,
rising more than 4,000 feet (1,219 meters) above the broad, gently rolling surface of the
Great Sage Plain.
The Great Sage Plain is a structural slope, capped by the resistant Burro Canyon
formation and the Dakota Sandstone, almost horizontal in an east-west direction but
descends to the south with a regional slope of about 2,000 feet (610 meters) over a
distance of nearly 50 miles (80 kilometers). Though not as deeply or intricately dissected
as other parts of the Canyon Lands, the plain is cut by numerous narow and vertical-
walled south-trending valleys 100 to more than 500 feet (30 to 152+ meters) deep. Water
from the intermittent streams that drain the plain flow southward to the San Juan Riveq
eventually joining the Colorado Nver and exiting the Canyon Lands section tkough the
Grand Canyon.
Rock Units @R Section 2.4.1.1)
The sedimentary rocks exposed in southeastern Utah have an aggregate thickness of
about 6,000 to 7,000. feet (1,829 to 2,134 meters) and range in age from Pennsylvanian to
Late Cretaceous. Older unexposed rocks are known mainly from oil well drilling in the
Blanding Basin and Monument Uplift. These wells have encountered correlative
S: STAFF/MR.R/TEXT99/ClR599/GlR.plc I
&
\.t.
t>
'f,.
-L
?s
/ eo'Jn€lRf d IEaTONTC 9rvrglot{
-- r{oNaoLtNE 3HAffN6 TRAaE OF AXISI I AND DIRIC?|ON OF OtP
ANflCLI{E 9{Or{tr{6 IF,ACE Or AxtS
t - AnD D|REOnOX OF FLUN6E
----l-- sn€Lo.E 3ror0ir9 TRAcE oF A)<rgI ANo DtRECnoN of FLUNGE
FIGURE C.l
Colorado ?laleav Oeologic Vo?
$
Yr)
"t.
Page C-7
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Cambrian to Permian rock units of markedly differing thicknesses but averaging over
5,000 feet (1,524 meters) in total thickness (Witkind, 1964). Mosr of the wells drilled in
the region have bottomed in the Pennsylvanian P{adox Me]|]lb-er of the Hermosa
formation. A generalized stratigraphic section of rock units ranging in age from
Cambrian through Jurassic and Triassic (?), as determined from oit-well logs, is shown in
Table C-1. Descriptions of the younger rocks, Jurassic through Cretaceous, are based on
field mapping by various investigators and are shown in Table C-2.
Paleozoic rocks of Cambrian, Devonian and Mississippian ages are not exposed in the
southeastern Utah region. Most of the geologic knowledge regarding these rocks was
Iearned from the deeper oil wells drilled in the region, and from exposures in the Grand
Canyon to the southwest and in the Uinta and Wasatch Mountains to the north. A few
patches of Devonian rocks are exposed in the San Juan Mountains in southwestern
Colorado. These Paleozoic rocks are the result of periodic transgressions and regressions
of epicontinental seas and their lithologies reflect a variety of depositional environments.
In general, the coarse-grained feldspathic rocks overlying the Precambrian basement
rocks grade upward into shales, limestones and dolomites that dominate the upper part of
the Cambrian. Devonian and Mississippian dolomites, limestones and interbedded shales
unconformably overlay the Cambrian strata. The complete absence of Ordovician and
Silurian rocks in the Grand Canyon, Uinta Mountains, southwest Utah region and
adjacent portions of Colorado, New Mexico and Arizona indicate that the region was
probably epeirogenically positive during these times.
The oldest stratigraphic unit that crops out in the region is the Hermos formation of
Middle and Late Pennsylvanian age. Only the uppermost strata of this formation are
exposed, the best exposure being in the canyon of the San Juan River at the
"Goosenecks" where the river traverses the crest of the Monument uplift. Other
,' ,';l.-, .\ '-tl
/'-t:'4,- ,. ^:
I
S:STAFFII(RR 1TEXT9/GlR ryctRprCl
TABLE C.l
GTTTRITIZTD STRATIGRAPHIC SECTI(}II (lT SUBSURTACE
R0cr(s B[st0 0ll 0lt-tlEtt t0GS
(A!ter Stokes, 195{; i{ltkied, 196,t; tlulf a:rd L.!u!a. 1965; Johnson and Thordarson, 1965)
I
I
I
I
I
3
I
It
Aqc
Jurasric andtriarsic ( ? )
frias!ic(?)
triasric
?enn!ylvani.nand P.r&.i.an(?)
Pcnnrylvanirn
I{lr.lrtlpptrn
Drvonlao
Str.tigrrphictinl' r
Glan crnyon Group!
NrvrJo S.ndttone
xlyGnta lolErtion
wlngats S.nd!tonc
Chinl.e Forration:
Undield.d
Itost Back !{ct!bar
Shinaru.urp l{cdcr
L.d?ltla tlaastona
Ou^Ery Lharton.
Elb.rE, loriErtion
Thicknrsr.
( (r)
300-a00
100- 150
2 50- 350
600- 700
0-t0o
0- 20
0-500
ll00-1r00
{50
l20o
200
500
lo0
2C0
----- uncontolEtty
rtCdl,c (?) and Ho.nkopt ?ota.t'iotl 50-100tasar Triaslic
----- Unconfenaity
?Grtaian Cutl,ar PorE tloD:
Organ Ro€k !{cEbe!
Ca&r HGlr
S.ndaton. lt€d.r
Rico Porir.tLon
BatEar ?orution:
Upp.s t{.ibar
Parador NaEbcr
Lortr f.Dbar
1000-1200 Gray, lerrivc llrutonr: sor rhalcatrd rrndttoa.
Erllt., ulr:/d.4l!a, !rfzp.u!, rhrlr,rnd rlltrton.
Ll!! .ton., rilrrton., and ahrk
Oa!cri,ption
Bu!! to llqht gray, E .ltvc, cro!!-bodded, lriablc r.ndston.
Raddlrh-brorn randttone .nd qudlton6
and occarioaal conglooerace Ienses
Rrddlrh-brosnr rastive r croer-bcdded,
f !,nc-greined randatonc
v.riagetad cleystonc vi,tJr lo4 thinbcdc o! slltrton. and liertcnc
Light color.d, conglorratic aand-rton. rnd conglocrita
Ycllwirh-gray, !in. to coars€-graincd r.ndrton., conglorcratic
..::::::::::_:::::::::.. _---_--..
Rcddlsh-broun Eudatonc and !ine-
..::::::. :::::::::-.-.
icddirh-brorn, tandl, audltonc
Rcddirh-broga, nelrtvc, tln. tomdiu.fr- g reinad raadlton.
Rcd and gray calcercour, randy rhale;gr.y lir!.ttonc end randttona
ihl,t to t a .ucrot. to cryrg.llln.lir!ton.
Llght gray atrd trn, thln-bcddrdIl,Drton. and dolocltr
Grey rad brosn dolooit. rnd U.irtor,cvlUr thla br& grera rh.l. rld ..nd-ttona
Gny and brovn lhrton. .rd doloaltc,trl&pathic ..nd.ton. rnd .rkor.
3oqli -- Uncoalotzlty ---------
---- UncontorEi,ty
CrEbEirn Ophlr totr! tlon aad 600liDtlc Qu.attito
i ?o conv.rt l..t !o Ec.rt, Bultj,ply by 0.3048. Av.r.g. thicknerr 91na l! nngr l,t notthoYn.
ANII'C T(D(oII
TABLE C-2
GTTENI[IZTD STRATICRIPflIC SECTI(lT (lr EIP(lSED
R0ct(s tr TltE PR0trcT ytctxtTl
(Att.r Horn.r r, ot.t t962i WifiIrd,l9G4; Hutf qr.t L.rr., lgCS)
LIT80l-061
Sllt. aed tBd tt.val 1n assorot rnd atr.evrllcyr.
Lddr,.b-br6rB ro lltht-brm. mcoErolld.-t.d, xll-3orttd rtlt to EdlEt".j,o.duod: p.rthll, c.rar.d ctrh c.ltch. ln!c .ru; rcvotl.d Pcclt b, e.r.s.
Slopc nrh, r.lu rEd rock rubbl. ruglotfrm eobblrr rDd bould.rr !o r.rrtvr bloal.fellra fror clllfr rad outcrop. of r.al.tratr*L..QT,ATERMRI
Eolocme
coPlar,rtocrEa
Collwlu rad felu
Looe
Uocoofonltt
clgtrcEqrS
.rtr$IC
UDP.TCntrcro
larr
Caatacaoga
0-l l (?)CrrT to d.rl,-tr.t, tlr.U.r ttr1tsb.dd.drrlm rhrh rlth fort:,tt.rour rudy ltr-rtil 1a l,o{s atrala.
D.lrt. S.!dtro!.
- - oscorforrls, -
lsrlo Caaron Forr.s1o6
Uoc6!onlt, (?
Itu.h, L.lB ll.$.!
Ltgbt yrllovtrh-btan to tlthr jttl-brora,chlcl b.dd.d to cro.t-b.dd.d a.ttdrtao..cootl6.rr!1c ..adrtor; la!.rb.dd.d thl'!katlculrr t a, calbolacaoEt chtttooarod hpus. corl; Locrl corrtt brrrl eoa-tlil.C..
Lltht-Eil, .nd llght-bror!, rrerlrc radcro..-b.dd.d ca3l*rtle .edrroo. rndltrtarbadd.d traa! ald lrrr-lr..a .rrdaroa.;locelly c6r.1r EhlD dl.cilB1ttuou brdrof ailrclfl.d a.8drlotr. .l!d llrrtoaaE.aa to9.
OprrJraa..ic
g
Io
!o!
t
V.st.t.s.d tr.rr p.l3-ts.ra. rrddhb-brm..ad pqrpl. b.!roo1tr,c rdtrmr rsd rllt-rtoB cmtrla.aEt tll! dlaeoatlauou rrad-atoil ald eajtorrrtr l.a8r.
Irt.rb.dd.d r.lloyl.lF .!d fr..olth-taryto tl*,futstr.rr llI. !o coutrGtr.lE.d.slo.lc erodrsoor .ad ts..llb-t'ry tos.ddi.rb-bso! a{td, ab.t. rqd rd.roo..
I!!.rHd.d s.ddl.h-at., ro tltbr brcI!t1F to rdtrD-tstllad ..!datoa. .!dr.ddl.Ftri, al1!, .ad oodT cleyrtotc.
lhlt llrrh t$rr
Uacorlor! tT
fhft Seodrtm
llt rb.ad.d r.rlouLhlb!!i! !o D.l.r.ddlrhpbra! ltr-jrtlnrd to cootloF.sltlr ..!datar of 3troleb eds.ddLb-ffr, .rd.ror.
lAlt. to 3rry'tb.trorur r..ty.. cro..-brddrd, llr- tc rrdtrrlrrlrd rolLoaaldaCa.
litFb.dd.d r rlplht*ld Bdalrb-btorrrrdd, a.!d.ta. .!d a6d, ab.la.
Lddl.t'ban! to ts.rl,aHl!.. rr.lv..cso..-b.dd.dr flr. tc rdlE-tl.frdaa!d.!or.
rlo corr.at t..t ro rt,aa.. tlttlpl, fot !y O.!Oaf.
&nfufrrf brddrd rrddtrb.bron rrddy..!da!or. .sd aa!d, rdrtooa yltb loc-!tbl! b.da of bsa! !o ts., tr'r,toa. .ads.ddl.lF to tra.o1.b.trr7 rhrh.
Page C-10
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Grou ndwater Information Report
exposures are in the breached centers of the Lisbon Valley, Moab and Castte Valley
anticlines. The Paradox Member of the Hermosa formation is sandwiched between a
relatively thin lower unnamed member consisting of dark-gray shale siltstone, dolomite,
anhydrite, and limestone, and an upper unnamed member of similar lithology but having
a much greater thickness. Composition of the Paradox Member is dominantly a thick
sequence of interbedded slate (halite), anhydrite, gypsum, and black shate. Surface
exposures of the Paradox in the Moab and Castle Valley anticlines are timited to
contorted residues of gypsum and black shale.
Conformably overlying the Hermosa is the Pennsylvanian and Permian (?) Rico
formation, composed of interbedded reddish-brown arkosic sandstone and gray marine
limestone. The Rico represents a transition zone between the predominantly marine
Hermosa and the overlying continental cutler formation of permian age.
Two members of the Cutler probably underlying the region south of Blanding are, in
ascending order, the Cedar Mesa Sandstone and the Organ Rock Tongue. The Cedar
h"lesa is a white to pale reddish-brown, massive, cross-bedded, fine-to medium-grained
eolian sandstone. An irregular fluvial sequence of reddish-brown fine-grained
sandstones, shaly siltstones and sandy shales comprise the organ Rock Tongue.
The Moenkopi formation, of Middle (?) and Lower Triassic age, unconformably overlies
the Cutler strata. It is composed of thin, evenly-bedded, reddish to chocotate-brown,
ripple-marked, cross-laminated siltstone and sandy shales with irregular beds of massive
medium-grained sandstone.
A thick sequence of complex continental sediments known as the Chinle formation
unconformably overlies the Moenkopi. For the purpose of making lithology correlations
in oil wells this formation is divided into three units: The basal Shinarump Membeq the
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Page C- l I
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater [nformation Report
Moss Back Member and an upper undivided thick sequence of variegated reddish-brown,
to greenish-gray, yellowish-brown to light-brown bentonitic claystones,
mudstones, sandy siltstone, fine-grained sandstone, and limestones. The basal Shinarump
is dominantly a yellowish-grey, fine- to coarse-grained sandstone, conglomeratic
sandstone and conglomerate characteristically filling ancient stream channel scours
eroded into the Moenkopi surface. Numerous uranium deposits have been located in this
member in the White Canyon mining district to the west of Comb Ridge. The Moss Back
is typically composed of yellowish- to greenish-grey, fine- to medium-grained sandstone,
conglomeratic sandstone and conglomerate. It commonly comprises the basal unit of the
Chinle where the Shinarump was not deposited, and in a like manner, frlls ancient stream
channels scoured into the underlying unit.
In the Blanding Basin the Glen Canyon Group consists of three formations which are, in
ascending ordeq the Wingate Sandstone, the Kayenta and the Navajo Sandstone. All are
conformable and their contacts are gradational. Commonly cropping out in sheer cliffs,
the Late Triassic Wingate Sandstone is typically composed of buff to reddish-brown,
massive, cross-bedded, well-sorted, fine-grained quartzose sandstone of eolian origin.
Late Triassic (?) Kayenta is fluvial in origin and consists of reddish-brown, irregularly to
cross-bedded sandstone, shaly sandstone and, locally, thin beds of limestone and
conglomerate. Light yellowish-brown to light-gray and white, massive, cross-bedded,
friable, fine- to medium-grained quartzose sandstone typifies the predominantly eolian
Jurassic and Triassic (?) Navajo Sandstone.
Four formations of the Middle to Late Jurassic San Rafael Group unconformably overly
the Navajo Sandstone. These strata are composed of alternating marine and non-marine
sandstones, shales and mudstones. [n ascending order, the formations are the Carmel
fbtmalion, Entrada Sandstone, Summerville formation, and_g1g_E$n4s!one., The Carmel
usually crops out as a bench between the Navajo and Entrada Sandstones. Typically
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May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater lnformation Report
reddish-brown muddy sandstone and sandy mudstone, the Carmel locally contains thin
beds of brown to gray limestone and reddish- to greenish-gray shale. predominantly
eolian in origin, the Entrada is a massive cross-bedded fine- to medium-grained
sandstone ranging in color from reddish-brown to grayish-white that crops out in cliffs or
hummocky slopes. The Summerville is composed of regular thin-bedded, ripple-marked,
reddish-brown muddy sandstone and sandy shale of marine origin and forms steep to
gentle slopes above the Entrada. Cliff-forming Bluff Sandstone is present only in the
southern part of the Monticello district thinning northward and pinching out near
Blanding. It is a white to grayish-brown, massive, cross-bedded eolian sandstone.
ln the southeastern Utah region the Late Jurassic Morrison formation has been divided in
ascending order into the Satt Wash, Recapture, Westwater Canyon, and Brushy Basin
Members. In general, these strata are dominantty fluvial in origin but do contain
lacustrine sediments. Both the Salt Wash and Recapture consist of alternating mudstone
and sandstone; the Westwater Canyon is chiefly sandstone with some sandy mudstone
and claystone lenses, and the heterogenous Brushy Basin consists of variegated bentonitic
mudstone and siltstone containing scattered thin limestone, sandstone, and conglomerate
Ienses. As strata of the Morrison formation are the oldest rocks exposed in the project
area vicinity and are one of the two principal uranium-bearing formations in southeast
Utah, the Morrison, as well as younger rocks, are described in more detail below.
The Early Cretaceous Burro Canyon formation rests unconformably (?) on the underlying
Brushy Basin Member of the Morrison formation. Most of the Burro Canyon consists of
light-colored, massive, cross-bedded fluvial conglomeratg congtomerate sandstone and
sandstone. Most of the conglomerates are nsar the base. Thin, even-bedded, light-green
mudstones are included in the formation and light-grey thin-bedded limestones are
sometimes locally interbedded with the mudstones near the top of the formation.
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Overlying the Burro Canyon is the Dakota Sandstone of Upper Cretaceous age. Typical
Dakota is dominantly yellowish-brown to light-gray, thick-bedded, quartzitic sandstono
and conglomeratic sandstone with subordinate thirr-. lenticular beds of mudstone, gray
carbonaceous shalo and, locally, thin seams of impure coal. The contact with the
underlying Burro Canyon is unconformable whereas the contact with the overlying
Mancos Shale is gradational from the light-colored sandstones to dark-grey to black shaly
siltstone and shale.
Upper Cretaceous Mancos Shale is exposed in the region surrounding the Mill vicinity
but not within it. Where exposed and weathered, the shale is light-gray or yellowish-
gray, but is dark, to olive-gray where fresh. Bedding is thin and well developed; much of
it is laminated.
Quaternary alluvium within the Mill vicinity is of three types: alluviat sitt, sand and
gravels deposited in the stream channels; colluvium deposits of slope wash, talus, rock
rubble and large displaced blocks on slopes below cliff faces and outcrops of resistant
rock; and alluvial and windblown deposits of silt and sand, partially reworked by water,
on benches and broad upland surfaces.
Structure and Tectonics (ER Section 2.4.1.3)
According to Shoemaker (1954 and 1956), structural features within the Canyon Lands of
southeastern Utah may be classified into three main categories on the basis of origin or
mechanism of the stress that created the structure. These three categories are: (l)
structures related to large-scale regional uplifting or downwarping (epeirogenic
deformation) directly related to movements in the basement complex (Monument Uplift
and the Blanding Basin); (2) structures resulting from the plastic deformation of thick
sequences of evaporite deposits, salt plugs and salt anticlines, where the structural
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expression at the surface is not reflected in the basement complex (Paradox Fold and
Fault Belt); and (3) structures that are formed in direct response to stresses induced by
magmatic intrusion including local laccolithic domes, dikes and stocks (Abajo
Mountains).
Each of the basins and uplifts within the Mill area region is an asymmetric fold usually
separated by a steeply dipping sinuous monocline. Dips of the sedimentary beds in the
basins and uplifts rarely exceed a few degrees except atong the monocline (Shoemaker,
1956) where, in some instances, the beds are nearly vertical. Along the Comb Ndge
monocline, the boundary between the Monument Uplift and the Blanding Basin,
approximately eight miles (12.9 kilometers) west of the Mill area, dips in the Upper
Triassic Wingate sandstone and in the Chinle formation are more than 40 degrees to the
east-
Structures in the crystalline basement complex in the central Colorado plateau are
relatively unknown but where monoclines can be followed in Precambrian rocks they
pass into steeply dipping faults. It is probable that the large monoclines in the Canyon
Lands section are related to flexure of the layered sedimentary rocks under tangential
compression over nearly vertical normal or high-angte reverse faults in the more rigid
Precambrian basement rocks (Kelley, 1955; Shoemaker, 1956; Johnson and Thordarsoq
1966).
The Monument Uplift is a north-trending, elongated, upwarped structure approximately
90 miles (145 kilometers) long and nearly 35 miles (56 kilometers) wide. Structural
relief is about 3,000 feet (914 meters) (Kelley, 1955). Its broad crest is slightly convex to
the east where the Comb Ridge monocline defines the eastern boundary. The uniform
and gently descending western flank of the uplift crosses the White Canyon slope and
merges into the Henry Basin (Figure C-l).
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East of the Monument Uplift, the relatively equidimensional Blanding Basin merges
almost imperceptibly with the Paradox Fold and Fault Belt to the north, the Four Corners
Platform to the southeast and the Defiance uplift to the south. The basin is a shallow
feature with approximately 700 feet (213 meters) of structural relief as estimated on top
of the Upper Triassic Chinle formation by Kelley (1955), and is roughly 40 to 50 mites
(64 to 80 kilometers) across. Gentle folds within the basin trend westerly to
northwesterly in contrast to the distinct noftherly orientation of the Monument Uplift.
Situated to the north of the Monument Uplift and Blanding Basin is the most unique
structural feature of the Canyon Lands section, the Paradox Fold and Fautt Belt. This
tectonic unit is dominated by northwest trending anticlinal folds and associated normal
faults covering an area about 150 miles (241 kilometers) long and 65 miles (104
kilometers) wide. These anticlinal structures are associated with salt flowage from the
Pennsylvanian Paradox Member of the Hermosa formation and some show piercement of
the overlying younger sedimentary beds by plug-like salt intrusions (Johnson and
Thordarson, 1966). Prominent vatleys have been eroded along the crests of the anticlines
where salt piercements have occurred or collapses of the central parts have resulted in
intricate systems of step-faults and grabens along the anticlinal crests and flanks.
The Abajo Mountains are located approximately 20 miles (32 kilometers) north of the
project area on the more-or-less arbitrary border of the Blanding Basin and the paradox
Fold and Fault Belt. These mountains are laccolithic domes that have been intruded into
and through the sedimentary rocks by several stocks (Witkind, 1964). At least 3l
laccotiths have been identified. The youngest sedimentary rocks that have been intruded
are those of Mancos Shale of Late Cretaceous age. Based on this and other vague and
inconclusive evidence, Witkind (1964), has assigned the age of these intrusions to the
Late Cretaceous or early Eocene.
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Nearly all known faults in the region of the Mill area are high-angle normal faults with
displacements on the order of 300 feet (91 meters) or less (Johnson and Thordarson,
1966). The largest known faults within a 40-mile (64 kilometer) radius around Blanding
are associated with the Shay graben on the north side of the Abajo Mountains and the
Verdure graben on the south side. Respectively, these faults trend northeasterly and
easterly and can be traced for approximate distances ranging from 2l to 34 miles (34 to
55 kilometers) according to Witkind (1964). Maximum displacements reported by
Witkind on any of the faults is 320 feet (98 meters). Because of the extensions of Shay
and Verdure fault systems beyond the Abajo Mountains and other geologic evidence, the
age of these faults is Late Cretaceous or post-Cretaceous and antedate the laccolithic
intrusions (Witkind, 1964).
A prominent group of faults is associated with the salt anticlines in the paradox Fold and
Fault Belt. These faults trend northwesterly parallel to the anticlines and are related to
the salt emplacement. Quite likely, these faults are relief features due to salt intrusion or
salt removal by solution (Thompson, 1967). Two faults in this region, the Lisbon Valley
fault associated with the Lisbon Valley salt anticline and the Moab fault at the southeast
end of the Moab anticline have maximum vertical displacements of at least 5,000 feet
(1,524 meters) and 2,000 feet (609 meters), respectively, and are probably associated
with breaks in the Precambrian basement crystalline complex. It is possible that zones of
weakness in the basement rocks represented by faults of this magnitude may be
responsible for the beginning of salt flowage in the salt antictines, and subsequent
solution and removal of the salt by groundwater caused collapse within the salt anticlines
resulting in the formation of grabens and local complex block faults (Johnson and
Thordarson, 1966).
The longest faults in the Colorado Plateau are located some 155 to 210 miles (249 to 33g
kilometers) west of the Mill area along the western margin of the High plateau section.
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These faults have a north to northeast echelon trend, are nearly vertical and downthrown
on the west in most places. Major faults included in this group are the
Hurrican,Toroweap-Sevier, Paunsaugunt, and Paradise faults. The longest fault, the
Toroweap-Sevier, can be traced for about 240 miles (386 kilometers) and may have as
much as 3,000 feet (914 meters) of displacement (Kelley, 1955).
From the later part of the Precambrian until the middle Paleozoic the Colorado Plateau
was a relatively stable tectonic unit undergoing gentle epeirogenic uplifting and
downwaqping during which seas transgressed and regressed, depositing and then partially
removing layers of sedimentary materials. This period of stability was intemrpted by
northeast-southwest tangential compression that began sometime during late
Mississippian or early Pennsylvanian and continued intermittently into the Triassic.
Buckling along the northeast margins of the shelf produced northwest-trending uplifts,
the most prominent of which are the Uncompahgre and San Juan Uplifts, sometimes
referred to as the Ancestral Rocky Mountains. Clearly, these positive features are the
earliest marked tectonic controls that may have guided many of the later Laramide
struclures (Kelley, 1955).
Subsidence of the area southwest of the Uncompahgre Uplift throughout most of the
Pennsylvanian led to the filling of the newly formed basin with an extremely thick
sequence of evaporites and associated interbeds which comprise the Paradox Member of
the Hermosa formation (Kelley, 1956). Following Paradox deposition, continental and
marine sediments buried the evaporite sequence as epeirogenic movements shifted
shallow seas across the region during the Jurassic, Triassic and much of the Cretaceous.
The area underlain by the Paradox Member in eastern Utah and western Colorado is
commonly referred to as the Paradox Basin (Figure C-1). Renewed compression during
the Permian initiated the salt anticlines and piercements, and salt flowage continued
through the Triassic.
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The Laramide orogeny, lasting from Late Cretaceous through Eocene time, consisted of
deep-seated compressional and local vertical stresses. The orogeny is responsible for a
north-south to northwest trend in the tectonic fabric of the region and created most of the
principal basins and uplifts in the eastern-half of the Colorado plateau (Grose, l97Z;
Kelley, 1955).
Post-Laramide epeirogenic deformation has occurred throughout the Tertiary; Eocene
strata are flexed sharply in the Grand Hogback monocline, fine-grained Pliocene deposits
are tilted on the flanks of the Defiance Uplift, and Pleistocene deposits in Fisher Valley
contain three angular unconformaties (Shoemaker, 1956).
Blanding Site Geology
The following descriptions of physiography and topography; rock units; srructure;
relationship of earthquakes to tectonic structure; and potential earthquake hazards to the
project area are reproduced from the ER for ease of reference and as a review of the Mill
site geology (see Figure C-l).
Physiography and Topography (ER Section 2.4.2.t1
The Mill site is located near the center of White Mesa, one of the many fingerJike north-
south trending mesas that make up the Great Sage Plain. The nearly flat upland surface
of White Mesa is underlain by resistant sandstone caprock which forms steep prominent
cliffs separating the upland from deeply entrenched intermittent stream courses on the
east, south and west.
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Surface elevations across the Mill site range from about 5,550 to 5,650 feet (1,692 to
.i 1,722 meters) and the gently rolling surface slopes to the south at a rate of approximately
_A/60 feet per mile (18 meters per 1.6 kilometer).
Maximum relief between the mesa's surface and Cononwood Canyon on the west is
about 750 feet (229 meters) where Westwater Creek joins Cottonwood Wash. These two
streams and their tributaries drain the west and south sides of White Mesa. Drainage on
the east is provided by Recapture Creek and its tributaries. Both Cottonwood Wash and
Recapture Creeks are normally ephemeral streams and flow south to the San Juan fuver.
Rock Units (ER Section 2.4.2.2)
Only rocks of Jurassic and Cretaceous ages are exposed in the vicinity of the Mill site.
These include, in ascending order, the Upper Jurassic Satt Wash, Recapture, Westwater
Canyon, and Brushy Basin Members of the Morrison formation; the Lower Cretaceous
Burro Canyon formation; and the Upper Cretaceous Dakota Sandstone. The Upper
Cretaceous Mancos Shale is exposed as isolated remnants along the rim of Recapture
Creek valley several miles southeast of the project site and on the eastern flanks of the
Abajo Mountains some 20 miles (32 kilometers) north but is not exposed at the Mill site.
Howeveq patches of Mancos Shale may be present within the Mill site boundaries as
isolated buried remnants that are obscured by a mantle of alluvial windbtown silt and
sand.
The Morrison formation is of particular economic importance in southeast Utah since
several hundred uranium deposits have been discovered in the basal Salt Wash Member
(Stokes, 1967).
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In most of eastern Utah, the Salt Wash Member underlies the Brushy Basin. However,
just south of Blanding in the Mill vicinity the Recapture Member replaces an upper
portion of the Salt Wash and the Westwater Canyon Member replaces a lower part of the
Brushy Basin. A southern limit of Salt Wash deposition and a northern limit of
Westwater Canyon deposition has been recognized by Haynes et al. (1972) in Westwater
Canyon approximately three to six miles (4.8 to 9.7 kilometers), respectively, northwest
of the Mill site. However, good exposures of Salt Wash are found throughout the
Montezuma Canyon area 13 miles (21 kilometers) to the east.
The Salt Wash Member is composed dominantly of fluvial fine-grained to conglomeratic
sandstones, and interbedded mudstones. Sandstone intervals are usually yellowish-brown
to pale reddish-brown while the mudstones are greenish- and reddish-gray.
Carbonaceous materials ("trash") vary from sparse to abundant. Cliff-forming massive
sandstone and conglomeratic sandstone in discontinuous beds make up to 50 percent or
more of the member. According to Craig et al. (1955), the Salt Wash was deposited by a
system of braided streams flowing generally east and northeast. Most of the uranium-
vanadium deposits are located in the basal sandstones and conglomeratic sandstones that
fill stream-cut scour channels in the underlying Bluff Sandstone, or where the Bluff
Sandstone has been removed by pre-Morrison erosion, in similar channels cut in the
Summerville formation. Mapped thicknesses of this member range from zero to
approximately 350 feet (0-107 meters) in southeast Utah. Because the Salt Wash pinches
out in a southerly direction in Recapture Creek three miles (4.8 kilometers) northwest of
the Mill site and does not reappear until exposed in Montezuma Canyon, it is not known
for certain that the Salt Wash actually underlies the site.
The Recapture Member is typically composed of interbedded reddish-gray, white, and
light-brown fine- to medium-grained sandstone and reddish-gray, silty and sandy
claystone. Bedding is gently to sharply lenticular. Just north of the Mill site, the
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Recapture intertongues with and grades into.the Salt Wash and the contact between the
two cannot be easily recognized. A few spotty occurrences of uriniferous mineralization
are found in sandstone lenses in the southern part of the Monticello district and larger
deposits are known in a conglomeratic sandstone facies some 75 to IOO miles (l2l to l6l
kilometers) southeast of the Monticello district. Since significant ore deposits have not
been found in extensive outcrops in more favorable areas, the Recapture is believed not
to contain potential resources in the project site (Johnson and Thordarson, 1966).
Just north of the Mill site, the Westwater Canyon Member intertongues with and grades
into the lower part of the overlying Brushy Basin Member. Exposures of the Westwater
Canyon in Cottonwood Wash are typically composed of interbedded yellowish- and
greenish-gray to pinkish-gray, lenticular, fine- to coarse-grained arkosic sandstone and
minor amounts of greenish-gray to reddish-brown sandy shate and mudstone. Like the
Salt Wash, the Westwater Canyon Member is fluvial in origin, having been deposited by
streams flowing north and northwest, coalescing with streams from the southwest
depositing the upper part of the Salt Wash and the lower part of the Brushy Basin (Hutr
and Lesure, 1965). Several small and scattered uranium deposits in the Westwater
Canyon are located in the e)iitreme southern end of the Monticello district. Both the
Recapture Member and the Westwater Canyon contain only traces of carbonaceous
materials, are believed to be less favorable host rocks for uranium deposition (Iohnson
and Thordarson, 1966) and have very little potential for producing uranium reserves.
The lower part of the Brushy Basin is replaced by the Westwater Canyon Member in the
Blanding area but the upper part of the Brushy Basin overlies this member. Composition
of the Brushy Basin is dominantly variegated bentonitic mudstone and siltstone. Bedding
is thin and regular and usually distinguished by color variations of gray, pale-green,
reddish-brown, pale purple, and maroon Scattered lenticular thin beds of distinctive
green and red chert-pebble conglomeratic sandstone are found near the base of the
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member, some of which contain uranium-vanadium mineralization in the southernmost
part of the Monticello district (Haynes et al., 1972). Thin discontinuous beds of
limestone and beds of grayish-red to greenish-black siltstone of local extent suggest that
much ofthe Brushy Basin is probably lacustrine in origin.
For the most part, the Great Sage Plain owes its edstence to the erosion of resistant
sandstones and conglomerates of the Lower Cretaceous This
formation and the contact is concealed over
most of the Mill area by talus blocks and slope wash. Massive, light-gray to light
yellowish-brown sandstone, conglomeratic sandstone and conglomerate comprise more
than two-thirds of the formation's thickness. The conglomerate and sandstone are
interbedded and usually grade from one to the other. However, most of the conglomerat e.4*
is near the base. These rocks are massive cross-bedded units formed by a series of
interbedded lenses, each lens representing a scour filled with stream-deposited sediments.
In places the formation contains greenish-gray tenticular beds of mudstone and claystone.
Most of the Burro Canyon is exposed in the vertical cliffs separating the relatively flat
surface of White Mesa from the canyons to the west and east. In some places the
resistant basal sandstone beds of the overlying Dakota Sandstone are exposed at the top
Iofthecliffs,butentirecliffsofBurroCanyonaremostcommon.%f.
a
bll-"la r* !-' : ' -' r'r' t r : ' -.:t- and most investigators map the two
formations as a single unit. At best, the contact can be defined as the top of a silicified
zone in the upper part of the Burro Canyon that appears to be remnants of an ancient soil
that formed during a long period of weathering prior to Dakota deposition (Huff and
Lesure,1965).
The Upper Cretaceous Dakota Sandstone disconformably overlies the Burro Canyon
formation. Locally, the disconformity is marked by shallow depressions in the top of the
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Burro Canyon filled with Dakota sediments containing angutar to sub-rounded rock
fragments probably derived from Burro Canyon strata (Witkind, 1964) but the contact is
concealed at the Mill site. The Dakota is composed predominantly of pale yellowish-
brown to light gray, massive, intricately cross-bedded, fine- to coarse-grained quartzose
sandstone locally well-cemented with silica and calcite; elsewhere it is weakly cemented
and friable. Scattered throughout the sandstone are lm,of,oo*rOilsmffiee, dark-gray
c{rM#oand,insomeinstances,[e-mail],the
lower part of the Dakota is more conglomeratic and contains more cross-bedded
sandstone than the upper part which in normally more thinly bedded and marine-like in
appearance. The basal sandstones and conglomerates are fluvial in origiq whereas the
carbonaceous mudstones and shales were probably deposited in back water areas behind
beach ridges in front of the advancing Late Cretac@us sea (Huffand Lesure, 1965). The
upper sandstones probably represent littoral marine deposits since they grade upward into
the dark-gray siltstones and marine shales ofthe Mancos Share.
ThelHsnotexposedintheprojectvicinity.Thenearestexposuresaresmall
isolated along the western rim above
Recapture Creek 4.3 to 5.5 miles (6.9 to 8.9 kilometers) southeast of the Mill site.
Additional exposures are found on the eastern and southern flanks of the Abajo
Mountains approximately 16 to 20 miles (26 to 32 kilometers) to the north. It is possible
tha but are obscured by the mantle
of alluvial windblown silt and sand covering the upland surface. The Upper Cretaceous
fif*fnr Bedding in the Mancos is thin and well developed, and much of
the shale is laminated. Where fresh, the shale is brittle and fissile and weathers to chips
that are light- to yellowish-gray. Topographic features formed by the Mancos are usually
subdued and commonly displayed by low rounded hills and gentte slopes.
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A layer of Quaternary to Recent reddish-brown eolian silt and fine sand is spread over the
surface of the Mill site. Most of the loess consists of subangular to rounded frosted
quartz grains that are coated with iron oxide. Basically, the loess is massive and
homogeneous, ranges in thickness from a dust coating on the rocks that form the rim
cliffs to moro than 20 fu (6 meters), and is partially cemented with calcium carbonate
(caliche) in light-colored mottled and veined accumulations which probably represent
ancient immature soil horizons.
Structure (E.R. Section 2.4.2.3)
The geologic structure at the Mill site is comparativety simple. Strata of the underlying
Mesozoic sedimentary rocks are nearly horizontal; only slight undulations atong the
caprock rims of the upland are perceptible and faulting is absent. In much of the area
surrounding the Mill site the dips are less than one degree. The prevailing regional dip is
about one degree to the south. The low dips and simple structure are in sharp contrast to
the pronounced structural features of the Comb Ridge Monocline to the west and the
Abajo Mountains to the north.
The Mill area is within a relatively tectonically stable portion of the Colorado plateau
noted for its scarcity of historical seismic events.
Site Hydrostretigraphy
The site stratigraphy is described above. This section describes Mill site
hydrostratigraphy, which is also described in the Titan Report. The detailed Mill site
stratigraphic column with descriptions of each geologic unit is provided on Figure C-2.
The following discussion, adapted from the Titan Report. focuses on those geologic units
at or in the vicinity of the Mill site which have or may have groundwater present.
S:SIAFF/MR R/TEXT9ryclR99/ClRplcI
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CO\GRED BY UNCONSOUOATED ALLIMUM.
COLLWUU AT.IO IALUS
lI ,.., ...,- eoirnrl snruo - ----
- - - _- - -ilP$l?-:$'' RED'rsH BRor,N IERY
**ee<sei# = = = = = = =flNCOS:S-HAE- - -sHALE.
LtcHT Gnry, soFT
DAKOTA SANDSTONE
SAI.IOSTONE. OUARTZ. UGHT YELLOW BROWN.
POORLY SORTEO, IRON CONCRTATIONS.
WEI,I INDURATEO
SAT.IOSTONE, OI,ARTZ. LIGHT GRAY TO UCHT
BROWN, CROSS-BEDDEO. CONGLOMERATIC.
POORLY SORTEO INTEREEOOEO wlTH
GRAY-GREEN SH^LE
BURRO CANYON FORMATION
\r.r...\\\
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BRUSHY BASIN MEMBER
WESTWATER CANYON MEMBER
RECAPTURE MEMBER
SALT WASH MEMBER
SUMMERVILLE FORMAIION
ENTRADA SANDSTONE
NAVA.JO SANDSTONE
FIGURE C-2
-T-
I
I
I tnoar, cRAy. cRAy-cREEN. AtD puRpLE,I srrv tN PART um soME sAr{osroNE
I r-eNses
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-I wm| GREENISH-GRAY TO REDOSH-8ROWN
6l SHALEalEl
X I ',*LE.
REDDTsH-.R^' srlry ro sAr.oy< I rNrERBEooEo wrH s,rNosroNE, ARKosrc,: I REoolsH-cRAy. To yELLow-BRowN. RNE-I ro ueoruu-cRAINED
I_t_
II SAT.IOSTONE. OUARZ. YELLOWSH-TOI REoorsx BRowN. FINE-To coARsE-I GRAINED INTERBEDOEO wm| REDDISH-I cRev smr-gI
SAI.IOSTONE. REO-BROIYN. THIN-BEDOEO. WITTI
RIPPLE TARKS, ARGILI.ACEOUS I$TH SHALE
INIERBEOS
S^I.IOSTONE. OIJARTZ TYHIIE TO GRAI1SH
BROWN. M Sstvt, CROSS-BEDOEo. RNE-IO MEOIUM-GRAINEO
SANOSTONE. OUARTZ. UGHI YELLOMSH-
BROWN TO UGHT-GRAY ANo WHIrE MASS|VE
CROSS-BEOOEO. FRIABLE, RNE- TO
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Page C-26
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White Mesa Uranium Mill
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The presence of groundwater within and in proximity to the site has been documented in
three strata: the Dakota Sandstone, the Burro Canyon formation, and the Entrada/l.,tavajo
Sandstone. The Burro Canyon formation hosts perched groundwater over the Brushy
Basin Member of the Morrison formation at the site.
The Entrada/l'Iavajo Sandstones form one of the most permeable aquifers in the region.
This aquifer is separated from the Burro Canyon formation by the Morrison formation
and Summerville formation. Water in this aquifer is under artesian pressure and is used
at the Mill for industrial needs and showering. The artesian conditions present in this
aquifer are discussed below and in the Titan Report.
Geologic cross sections which illustrate the stratigraphic position of the EntradaA{avajo
Sandstone aquifer and intervening strata are shown on Figures C-3, C4, and C-5 (from
Titan Report Figures 2.1, 2.2, and 2.3, respectively). The summary of the borehole
information supporting the site's stratigraphy, description of the drilling information, and
boring logs are presented in Appendix A of the Titan Report. With the exception of six
deep water supply wells installed at various locations around the site and completed in
Entrada./l''tavajo Sandstone, all of the boring data are from wells drilled through the
Dakota/Burro Canyon Sandstones and terminated in the Brushy Basin Member. The
drilling and logging data indicate that the physical characteristics of the bedrock ,ary
considerably, both vertically and laterally. The following sections discuss the relevance
of those strata and their physical characteristics to the site's hydrogeology.
Dakota Sandstone
The Dakota Sandstone is a low- to moderately permeable formation that produces
acceptable quality water at low production rates. Water from this formation is typically
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^'- DAMES AND MooRE 1978 BoRINGS
ci""o WATER SUppLy WELLS O'APPOLONIA (1961)
,.""-t ExlsrlNc MoNlroRlNG WELLS
+' ExtslNG IvATER suppLy wELLS
! STOCK WELLS
FIGURE C.3
VlihiLe Vesa Mill
SiLe Plan Vo? shoning
VoniLor Aells and Sorings
SCALErc
2OOO O 2OOO QOO teeL
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y\hiLa Vega MillSecLion A-A'
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FIGURE C.5y\hi|e Vesa Mill
SecLion B-3'
a
Page C-30
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
used for stock water and/or irrigation. The Dakota Sandstone is the uppermost stratum, in
which the tailings disposal cells are sited.
At the ground surface, the Dakota Sandstone is overlain by a veneer of reddish-brown
clayey or sandy silts with a thickness of up to I0 feet and extends to depths of 43 to 66
feet below the surface @'Appolonia, 1982). The Dakota Sandstone at the site is
typically composed of moderately hard to hard sandstones with random discontinuous
shale (claystone) and siltstone layers. The sandstones are moderately cemented (upper
part of formation) to well cemented with kaolinitic clays. The claystones and siltstones
are typically 2 to 3 feet thick, although boring WMIvfW-19 encountered a siltstone layer
having a thickness of 8 feet at 33 to 4l feet betow the ground surface.
Porosity of the Dakota Sandstone is predominately intergranular. Laboratory tests
performed (rc T.QbLe.-G3, from lilu.nepg#*hl.snAD show the totat porosity of the
sandstone varies from 13.4 to 26.0 percent with an average value of 19.9 percent. The
formation is very dry to dry with volumetric water contents varying from 0.6 to Z.l
percent with an average value of 3.0 percent. Saturation values for the Dakota Sandstone
vary from 3.7 to 27.2 percent. The hydraulic conductivity values as determined from
packer tests range from 9.12E-04 centimeters per second (cm/sec) to 2.718-06 cm/sec
with a geometric mean of 3.89E-05 cm/sec @ames & Moore, l97g; umetco, l9g2). A
summary of hydraulic properties of the Dakota Sandstone is presented in Table C-4
q111R"p-ort Table 2.2). _==-
Burro Canyon Sandstone
Directly below the Dakota Sandstone, the borings encountered sandstones and random
discontinuous shale layers of the Burro Canyon formation to depths of 9l to l4l feet
below the site. The importance of this stratum to the site's hydrogeology is that it hosts
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Table C-4
Summary of Eydraulic Properties
White Mesa Mill
BoringMell
[,ocation
Soils
6
Dakota
Sandsone
No.3
No.3
No. 12
No. 12
No. 19
No. 19
Burro Canyon
Formation
No.3
No.3
No.3
No.3
Laboratory Test
Laboratory Test
Laboratory Te*
Laboratory Test
Laboratory Test
[:boratory TeS
Iaboratory Test
Iaboratory Test
Injection Test
Injecrion Test
lnjection Test
Injection Test
Injection Test
Injection Test
Injection Test
Injection Test
Injection Test
Injection Test
9
4.5
4
28-33
3342.5
t6-22.5
22.s-37.5
26-37.5
37.5-52.5
42.5-52.5
52.5{3
63-72.5
72.5-92.s
D&M
D&lv{
D&M
D&M
D&M
D&M
D&M
D&M
Geometric
Mean
D&M (l)
D&M
D&I\,I
D&M
D&tvl
D&i\,t
Geometric
Mean
5.68E+02
2.808+00
5.108{{0
7.928+0l
7.008m0
9.4/.E)42
9
4.5
4.5
4
4
7
l0
t2
l6
17
l9
22
Document
Refercnced
D&M
D&I,I
D&I!(
D&I\,7
Eydreulic
Conductivity
Eydreulic
Conductivity
l.2E+01
l.0E+01
l.2E{l
l.4E+02
2.2E+At
9.38+01
7.0E{l
3.9E{O0
l.2E{5
l.0E{5
l.2E{s
l.4E{4
2.lE4s
9.08{5
6.8E{5
3.8E{6
2.458{{l 2.3TE45
5.498{4
2.7rE{6
4.93846
7.66'E45
6.77E46
9.12844
4.038+01 3.89E{s
5.80E{O0
1.628{l
5.308flm
3.208+00
5.61E{6
1.578{s
5.r38{6
3.09E{6
Table C-4
Summary of Hydraulic Properties
White Mesa Mill
(continued)
BoringAilell
Location
Intend Document
Hydraulic
Conductivity
Eydrrulic
Conductivity
(cm./sec")Test Type (ft - ft") Refercnced (ftlyr.)
No.3
No.3
No.9
No.9
No.9
No.9
No.9
No. 12
No. 12
No. 12
No.28
No.28
No.28
WMMWI
WMlvfW3
WMMW5
WMMW5
WMlvfWl I
wMMWll
WMMW12
WMMWl2
WMMWt4
WMtvfW14
WMMWt5
WMlvtWl5
wMNrw16
WMMWl6
Injection Test
Injection Test
Injection Test
Injection Test
Injection Test
Injection Tes
Injection Test
Injection Test
Injection Tes
Injection Test
Injection Test
Injection Tes
Injection Test
92.5-107.5
t22.5-t42
27.542.5
42.5-59
59-82.5
82.5-t07.5
107.5-132
37.5-57.5
57.5-82.5
82.5-102.5
76-87.5
t7.5-107.5
107.5-132.5
90-120
90-120
99-129
99-129
28.5-31.5
45.5-51.5
4.90E{0
6.008+0l
2.708+{0
2.00E+oo
7.008+0l
l.t0E{o0
3.00E+01
9.018{{l
1.40E{0
1.07E+ol
4.30E{{0
3.008+01
2.008-ml
3.00E{o0
2.9TEt+0
l.3lE{{l
2.108{{l
1.23E+O3
1.638{03
6.848+0l
6.84Eml
l.2lE+03
4.02E+{2
3.6SE{Ol
2.588{Ol
9.428+{2
5.288{l
4.74E46
5.80E{7
2.618{6
1.93E{6
6.7TE47
1.06846
2.90E47
t.70E{7
1.35E{6
1.03E45
4.16E46
2.90E47
1.93847
2.90E.46
2.87E46
1.27E45
2.038{5
l.l9E43
t.58843
6.61845
6.618{5
l.l6E{3
3.88E44
3.53E{5
2.49E45
9.10E{4
5.r0E{5
(7) Recovery 92-ll2
(A Recovery 67-E7
(7) Recovery 95.5-t33.5
(7) Recovery 95.5-133.5
(7) Recovery 90.7-130.4
(7) Single well dranrdown 90.7-130.4
(7) Rccorrcry 84-124
O Recovery 84-124
D&M
D&M
D&M
D&I,I
D&I,I
D&T,T
D&M
D&M
D&M
D&M
D&M
D&lvl
D&M
Peel
Peel
H.E
Peel
H.E
Peel
H-E
Peel
H-E
H.E
H-E
Peel
(2)
(3)
Single rvell drawdown
Single well drawdown
Single well drawdown
A Recovery
Injection Test
Injecrion Test
(s)
(6)
Peel
Peel
Table C-4
Summary of Hydraulic Properties
White Mesa Mill
(continued)
Interval Document
Eydreulic Eydraulic
Conductivity ConductivityBoringAilell
Location Ti:st Type (ft - ft) Referenqed (ft/yr.) (cm./sec.)
WMlvtW16
WMlvtWl6
WMMWtT
WMMWlT
wMMWlT
WMMWlS
WMMWtS
WMMWIE
WMMW19
WMMWl9
Entrada/Navajo
Sandstones
ww-l
ww-l
ww-1,2,3
Injection Test
Injection Test
Injection Test
Injection Test
Injection Test
Injection Test
Injection Tes
Injection Test
Injection Test
Injection Test
Recovery
Multi-well drawdown
Multi-well drawdown
65.5-7t.5
85.5-91.5
45-50
90-95
100-105
27-32
85-90
120-t25
5560
95-100
Jl'u!
Kua
Peel
Peel
Peel
Peel
Peel
Peel
Peel
Peel
Peel
Peel
, kll
8.07E+0t
3.008{l
3.10E{o0
3.628{0
5.69E{O0
l.l4E{2
2.69E+Ot
4.66E+00
8.69E+O0
1.45E+00
7.80E{5
2.90E45
3.00E46
3.50E{6
5.50E.06
l.l0E44
2.60E{5
4.508{6
8.408{6
1.40E46
Crcometric
Mean
D'Appolonia
D'Appolonia
D'Appolonia
Geometric
Mean
3.80E{2
4.668+02
4.24E142
3.67E{4
4.50E{4
4.108{4
1.058{t l.0lE{s
(4)
4.22E+42 4.088{4
Notes:
(l)
(2)
(3)
(4)
(s)
(6)
D&lvI = Dames & Moore, Envircnmenul Report, White Mesa Uranium Project January, 1978.
Peel = Peel Envimnmentat Services, T METCO Minerals Corp., Gmund Water Study, White Mesa Facility, Iune 1994.
H-E= Hydro-Engineering; Gmund-Water Hydrologr at the White Mesa Tailings Facility, July, 1991.
D'Appolonia, Assessment of the Water Supply Systerq White Mesa Project, Feb. 1981.
Eady test data.
kte test data.
Test data reana TEC.
O
Adapted from: Table2.2, Titan Report
I
Page C-35
Internationat Urani u m rus #3fi:.li::
White Mesa Uranium Mill
Groundwater Information Report
perched water beneath the site. Beneath the Burro Canyon formation, the Brushy Basin
Member is composed of variegated bentonitic mudstone and siltstone; its permeability is
lower than the overlying Burro Canyon formation and prevents downward percolation of
groundwater (Haynes, et al, 1972). Observed plasticity of claystones (Umetc o, 1992)
forming the Brushy Basin Member indicates low potential for open fractures which could
increase permeability. A summary of a drilling program carried out in 1994 to obtain
additional hydrogeologic data and assess fracture potential follows this section regarding
hydrostratigraphy.
l Previous investigators have seldom made a distinction between the Dakota and Burro-{
fCanyon Sandstones. However, examination of borehole cuttings, cores and geophysical
logging methods has atlowed separation of the two formations. Although simitar to the y,,,"1 ,*y^"
oy
Dakotq the Burro Canyon formation varies from a very fine- to coarse-grained
sandstone. The sand grains are generally poorly sorted. The coarse-grained tayers also
tend to be conglomeratic. The grains are cemented with both silica and kaolin, but sitica-
cemented sandstones are dominant. The formation becomes argillaceous near the contact
with the Brushy Basin Member.
The saturated thickness in the Burro Canyon formation varies across the project area
from 55 feet in the northern section to less than 5 feet in the southern area. Some wells "
are dry, which suggests that the zone of saturation is not continuous. Saturation ceases or
is marginal along the western and southern section of the Mill site. The extent toward the
east is not defined, but its maximum extent is certainly not beyond the walls of
Westwater Creek and Conal Canyons where the Burro Canyon formation crops out.
Perched groundwater elevations and saturated thickness of this formation are shown on
Figures c-6 and c-7, respectively (from Titan Report Figures 2.4 and 2.s).
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SCALE
2000 0 2000 4ooo
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FIGURE C-6 Perehed Oround VlaLer Levele
IIIIt
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a,
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SaLvraLed Thicknoes - Fail gn2
2000 4000 FEET
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International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Hydraulic properties of this stratum have been determined from 12 single, well-
pumping/recovery tests and from 30 packer tests. A summary of the hydraulic properties
is given in Table C-3 l$,.Report fablg__?,2)- These tests indicate the hydraulic
conductivity geometric mean to be l.0E-05 cm/sec. The physical properties of the Burro
Canyon Sandstone are summarized in Table C-4. Based on the core samples tested, the
sandstones of the Burro Canyon formation vary in total porosity from 1.7 to 27.6 percent,
the average being 16.0 percent. Volumetric water content in these sandstones ranges
from0.l to 7.1percent, averaging 2.2percent, with the fine-grained materials havingthe
higher moisture content. Porosities in the claystone layers vary fronl 16.4 to 29.1 percent
with saturation values ranging from 33.8 to 77 .2 percent.
Brushy Basin l!{ember
&
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c/t,
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,114',..
The Brushy Basin Member of the Morrison formation is the first aquitard isolating
perched water in the Burro Canyon formation from the productive Entrada./Navajo
Sandstones The Brushy Basin Member, in contrast to the overlying Dakota Sandstone,
is composed of bentonitic mudstone and claystone. Limited site-specific hydraulic
property data are available for the Brushy Basin Member.
The thickness of the Brushy Basin Member in this region reportedly varies from 200-450
feet (Dames & Moore, 1978). This stratum was penetrated by six water supply well: (g
_ Nn hFigure (Titan Report Figure 2.1) and Appendix A of the Titan Report) and itsthickness/fta t-"1^t-
was estimated at 275 fee/.. Borings which terminate in the Brushy Basin Member
encounter moderately plastic dark green to dark reddish-brown mudstones. Plastic
bentonitic mudstone is not prone to develop fracturing. Hence, competency of this
stratum, as an aquitard, is considered by Titan to be "very likely".
t"^_,! i
S:STAFF&IRR"ITEXT99/GlR599/clRp€ |
Page C-39
lv{ay 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
E n trad a/l{avaj o A q u ifer
Within and in proximity to the Mill site, the Entrada.rNavajo Sandstones are both prolific
aquifers. Since Mill site deep water wells are screened in both aquifers, they are, from a
hydrogeologic standpoint, treated as a single aquifer. The Entrada./Navajo Sandstone is
the first useable aquifer of significance documented within the project area. This aquifer
is present at depths between 1,200 and 1,800 feet below the surface and is capable of
delivering from 150 to 225 gpm of water per weil (D'Appolonia, l9g I ).
Water is present under artesian pressure and is documented to rise by about g00 to 900
feet above the top of Entrada/Navajo Sandstone contact with the overlying Summerville
formation. The static water level is about 400 to 500 feet below the surface (Figures C-4
and C-5).
The combined thickness of the strata separating this aquifer from water present in the
Burro Canyon formation is about 1,200 feet. This confining layer is competent enough to
maintain pressure of 900 feet of water or 390 pounds per square inch (psi) within the
Entrada./Navajo Aquifer. The positioning of this aquifer and its hydraulic head versus
other strata is shown on Figures C-4 and C-5. In-situ hydraulic pressure of groundwater
in the Entrada.&'Iavajo Aquifer is strong evidence of the confining (i.e., ..aquitard")
properties of the overlying sedimentary section. Titan noted that "Due to the presence of
significant artesian pressure in this aquifer, any future hydraulic communication between
perched water in the Burro Canyon formation and the Entrada.tlavajo Aquifer is
unlikely".
S:STAFF/Ir{RR/TEXT99/GtR599/ClRflC I
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Page C-40
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater lnformation Report
DATA COLLECTED IN 1994
This subsection contains a summary of a 1994 drilling program carried out in response to
a request by the NRC and the U. S. Environmental Protection Agency (EpA) to further
investigate the competence of the Brushy Basin member of the Morrison formation and
to provide additional hydrogeologic data. Three vertical and four angle core holes were-#--- u_drilled.
The three vertical holes (wMlv[\il-20, wMMw-2I, and wMMw-22) were drilled
downgradient of the existing monitoring wells. Constant head packer tests were
conducted over intervals within the Brushy Basin member to gain information about the
horizontal hydraulic conductivity of this unit. Setected w#lrqdco of the Brushy
Basinmemberwereanalyzediniiag.Thethreevertical
holes were drilled to sufficient depth to penetrat e 20" feet of Brushy Basin Member.
ffirveredrlted ;;;;, A,rl L
were examined l.rhfi1p r".r. n/---lffra*, and where noted, they were packer tests were
conducted during the drilling of the holes to gain further information about the hydraulic
conductivity of the rocks.
Upon completion of drilling, all the geotechnical holes were logged using wireline
geophysical methods. A video camera survcy was performed in three of the four core
holes. T - lltfi^1
/(
Selected cores of the Brushy Basin from att the holes were sent for @qt_;- t -1o -1
ry$ryry9$ of the. vertical permeabitity. The results of these tests are presented in :::z1'-.,:
.--+Table C-5. The hy$raulic conductivities calculated from these tests vary from 7.l0E-06 11 ,! [ . (t;,,i"rj 'l ' ,,,cm/sec to d".qUE-04 cm/sec in the Dakota formation, from 9-88Er07cm/sec to 7.70E-04'' l( \,L)E 'q d,tbl- (
SSfAFFAiRWTEXT9g/CtRjg9lctRprc I
. iV?Y
.:L,
-n au'tp"?\ . k\2" a,(ool'4u*i&(
/6-r''
a.!'ri ;t,'\r
o'
Page C-41
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
oli l,4t-,1 .-*' 6 A-','l,l 'ro
cm/sec in the Burro Canyon formation and from 2.30E-A7"cm/sec toJ-9tE;Ud cm/sec in
the Brushy Basin member. Three packer tests run within the Brushy Basin member
yielded "No Take." Due to the low hydraulic conductivities, measurements could not be
made with the equipment available. The hydraulic conductivities of these zones can be
expected to be lower than the zones in which actual measurements were made. It can,
therefore, be assumed that the hydraulic conductivities of these zones are less than 2.30E-
07 cm/sec. Packer tests tend to reflect horizontal hydraulic conductivities which can be
expected to be greater than vertical hydraulic conductivities of the same zone.
Slug tests were conducted in wells WMV[W-2O and WMMW-zz. The test results are
shown in Table G5. A hydraulic conductivity of 3.148-06 cm/sec was catculated for
wMlvrw-20 and g)Ewrirnlsec (essentially l.0E-06 cm/sec) for wMMW-22.'e o,o(tAFJrt.= 2 QZE- 0r,. lp',
Cores from the Brushy Basin were sent to Western Engineers of Grand Junction,
Colorado for horizontal and vertical permeability determination. The results of these tests
are shown,on Table C-6. The vertical hydraulic conductivities of the cores vary from
,a!L
5.gsE-o{ to 7.28E-lf cnltec. The geometric mean of the vertical permeabilities is
1.238-08 cm/sec.
tl i"l t
For the few analyses conducted for horizontal permeabilities, the results ranged fromyt'[,.-t.0gE-oz to 6.t+E-tO"iiir/sec and the geometric mean of these values was calcutated to
be 6.72E-09 cm/sec.
Packer tests were conducted over zones within the Dakota, Burro Canyon and Brushy
Basin units. The mss and vidbo survGys of tho &ill ho,lca showod $rat.ths.fe.w olood
&airline &aoturos. Fr€rs{r& in the Burro Canyon and Dakota Formations 'do. ,no0
substs,ntiatly afftct thc hyfuio conductivity "of.the f,ornations.
,/ olL
S:STAFF/MRUTEXT99GIRJ99/GlRptC I
Table C-5
Summary of Borehole Tests, 1994 Dritling Program
White Mesa Project, San Juan County, Utah
Hydraulic
Conductivity
Hydraulic
Conductivity
cm/sec
WIVIMW.2O 7l10.5-l14.5 Constant Head
of Test Formation
Brushy Basin 0.005
Well No.
WMMW-21
wMprw-22
Interval
r' 87.0-90.0
/t09.5-1t7.0
-130.0-140.0
Slug Burro Canyon 0.015
Constant Head Brushy Basin 0.17
Constant Head Bnshy Basin
5.29E46 5--'.b-=L,xF- j
c^i/c
8.tsE{6 /
2.30E47 r'
GH-e4-l&
-/76-t20
.-34.040.0
--40.0-50.0
Slug
Constant Head
Constant Head
Burro Canyon
Dakota
Dakota
0.06 4.,a. t 3.14E{6"_? / \rx \a| -t "- '
'n ,-^r
0.16
l.l8
olt
7.10E{6
5.60845
t/
l/'
/10.0-80.0
,.- 92.0-100
-, 103.0-l10.0
Constant Head
Consunt Head
Constant Hand
Burro C:nyon
Burro Canyon
Burro Canyon
o.0lo ,.,-, - g.ggE{7+-
- t.)de- + til /r1Lr3.r 6.20E44/
,l
15.84e' 1:' 1 [',ti 1,.7.70'.44 r'
GH-s4-2Ar
_,.130.0-140.0
- 163.0-t65.0
2.34.0-{0.0
,32.540.0
--50.0-56.0
Constant Head Brushy Basin
Constant Head Brushy Basin
t.7oB{'4 t "
-No Take- //
//
3.toE45'/
t.go}44-'
t.toE44--
Constant Head
Constant Head
Constant Head
Dakota
Dakota
Dakota
3.6
0.66
t8.72
2.30
.- 60.0:70.0
-. 70.0-80.0
- 80.0-90.0
Constant Head
Constant Head
Constant Head
Burro Canyon
Burro Canyon
Burro Canyon
4.goB45 ""
2.WE44 "-
t.50E41t,-'
1.04
4.18
3.02
YGH-94-3 /
._ 13E.0-144.0
155.0-161.0
138.0-144.0
Constant Head Bnshy Basin
Congant Head Brushy Basin
Constant Head Brushy Basin
-No Take- 1..-
.,/
3.26E#t/
2.70E#y'
0.07
0.06
rlrJ -)pru?'j
t iL,
t ll *\!-
h'. ''
*ft \*1,
Well No.
Table C-6
Results of LaboratorT Tests
Interval Tested (ft)Formation Tested
Vertical
Permeabilities
cm/sec
WMIvflV-20
WMMW-21
wMNfw-22
..92.0-92.5
/95.4-96.0
(104.0-104.4
,-105.0-105.5
Z, 109.5-l10.0
,,,94.8-95.3
/- t06.5-t07.0
/14.s-lls.0
A22.2-122.7
( t26.3-t27.2
- 133.3-133.7
- 137.3-137.8
.163.0-163.5
-- t65.0-t65.5
.__ 161.0-161.5
--1,57.0-t57.5
-_ 158.0-158.5
Brushy Basin
Brushy Basin
Brushy Basin
Brushy Basin
Brushy Basin
Bnshy Basin
Bnshy Basin
Brushy Basin
Bnshy Basin
Bnshy Basin
Bnshy Basin
Bnrshy Basin
Brushy Basin
Bnshy Basin
Brushy Basin
Brushy Basin
Brushy Basin
7.g6E41r''
2.g6E4g "'
2.43E4g tu/
7.288-n/
r.ozE$g/
5.78F.{5 /
6.38E-rO/
t.46F47v'
l.0g}46r'/
6.s1lF.-r|/
z.trE4s y'
5.95E44 -'
1.68r.48/
6.76E47 /
6.73F.4s /
9.4LE-LO /
2.r7E4s /
cH-t *
GH.2A
CH.3
cH{
r
*
v-
Well No.Interval Tested (ft)Formation Tested
Horizontal
Permcabilities
cm/sec
WMIvtlV-20
WMMW-21
WMMW-22
f es.4-e6.0
_ 105.0-105.5(
I 94.8-95.3
Bnshy Basin
Brushy Basin
Brushy Basin
Brushy Basin
t.ogE0l /
6.t4E-tO /
8.3IE-lO'--
3.67F.48'/'437.3-137.8
Page C-44
Internationar Uran iu m rus #8li:rff :
White Mesa Uranium Mill
Groundwater [nformation Report
UDEQ asks for an agricaltural description, that includes a descriprion of agricultural
crops grown within the facility boundaries, types of crops produces, amount of water
appliedfor irrigation, and any confinemerfi areasfor livestock.
No agricultural crops are grown, and no livestock confinement areas exist, within the
Mill facility boundaries, as defined by the restricted area. There are some livestock
grazing areas adjacent to the Mill site.
Note on Protection Levels:
This note states that a/ter the applicattt has defined the quality of the fluid to be
discharged (Groundwaler Informatiotr, Part B), characterized the local hydrogeologic
conditions and determined background groundwater quality (Hydrogeologic Report), the
Executive Secretary will determine the applicable groundwater class, based on: I) the
Iocation of the discharge point within an area o/ /ormatty classified groundwater, the
background value of lotal dissolved solids. Accordingly, the keative Secretary will
delermine applicable protection levels for each pollutont of concern, based on
background concentrations and in accordance with URC R3l7-Gl and R3l Z-G6.4A(I).
PRE.OPERATIONAL B ACKGROUND SAMPLES
This section summarizes pre-operational background sampting of groundwater and
surface water, and describes the EPA-recommended approach that was proposed by the
Mill, and approved by the NRC, for determination of background for the POC wells.
Pre-operational water quality sampling stations are shown in Figure c-g.
S:STAFFA{RR,ITEXT99/CIR9,GIR9iC I
55R =5f t i*1f
I @*ffii*lcorPot
FIGURE C-S
Preopcruiorl Wtcr Qrulity Saopli
Strtimr iDtG WhiE Mcsa Viciuit5
S7R('...+'29r \(,2 ,':
ir i q\-.\:'
ftt;Jr n, il[[, HIY'h.dfrii, g
STilPTITO STTTI(ITS IX PN(I'TCT UICIXITT
I A ,,/
GROUNOWA
SAMPLING
SURFACE
RADIOLOGI
?jie)
TER (WELL OR SPRING)
LoCATtoN 2A " _l.Al ,
WATER SAMPLING LOCATION
CAL SAMPLING LOCATION i1.
a
a
rft
'*sI l\ ^;^ )f(d,-,,.
ar..4..
...t
a
\\ I.rlq) ir3 (Isan
.;ssR'
,l;t#, '
\ I '\ro}
k\\s [4sr,,{n-=-'] ?-<-YY1=r \
Page C-46
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Baseline Groundwater Ouality
Pre-operational groundwater sampling began in July 1977. Analysis was performed by
the Utah State Division of Environmental Health Analysis Lab No. 77061. One sample
was split for duplicate analysis by Hazen Research for selected water quality parameters.
One replicate was analyzed for QA on radioactivity. Results available at the time of
publication of the 1978 Environmental Report (Dames & Moore, 1978) ("ER") were
published in the ER on Table 2.6-6, and are provided in Attachment 7. It should be noted
that the EPA laboratory certification was not in effect at that time. Detection limits were
not reported with the analytical results.
Supplemental discussion of the pre-operational groundwater quality was published in the
Final Environmental Statement ("ES") for the White Mesa Uranium Project (USNRC,
May 1979). As described in the ES, groundwater data collected from January 1977 to
May 1977, prior to gperation, indicated that:r "rg1*\;.,'{' Jt'^ ik,\rl+\\-. Samples Gl, G3, G4, and G5'were taken from springs within Cottonwood
Creek, originating in the perched water zone. G2 was collected from a wellJ
compteted in the Navajo Sandstone, and exceeded public drinking water \)
standards for selenium, sulfate, iron and arsenic.
I
fytt *m'
- ft\qt [q
l>or*.ttn
4l /."t: fi!.1
\
Other wells completed in the Navajo Sandstone exceeded USEPA
recommendations for iron. 1.bb P- L e+LZ
, r 1 t
/qb^u.[;t*h*{i"nZ ^ X tr!?*h$!
Wetls Eq.-E? completed in the Dakota Sandstone .i""#"i puUtit drlnking -l
water stfidards for iron, sulfate, lead and arsenic.
l\^l^* duc*d,'h Qn{1*l<2,l,iri-* Atl^rl, 1
S:STAFFAIRi/TEXT99/GlRJ99GlRSC I
- f"lA h {14rt- 5415 D O r* r.'^{ g^."lrk.[, sn*/ h- * I ,
Page C-47
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
BACKGROUND APPROACH FOR GROT.JNDWATER DEFINED IN TI{E TITAN
POINT OF COMPLIA}ICE REPORT
The POC report, which was accepted by the NRC for ongoing groundwater monitoring as
part of the license renewal in 1997 (See Renewal of NRC License No. SUA-1358, March
14,199'1, Attachment 8), implemented use of existing monitoring wells 5, I I, 12, 14 and
17, for ongoing monitoring. The locations were selected in accordance with EPA's
RCRA Ground-Water Monitoring: Draft Technical Guidance (EPA 1992). '€hloride
potassium and nickel were chosen as indicator parameters. Trace metals such as sodium,
magnesium, calcium and arsenic were not selected as indicator parameters, because the
presence of calcareous stringers and zones beneath the site would retard the movement of
these metals making them an unreliable indicator of water quality. The same calcareous
materials would also react with low pH solutions from potential tailings cell liner leaks,
making pH an unreliable indicator.
ThePoCreportintroduceduseofthecombinedmethod
for evaluating the quarterly groundwater data. The Shewhart-CUSUM method involves
plotting standardized constituent concentration data versus time, and comparison of the
data for each parameter against a predefined upper bound (based on standard deviations)
rather than against a static background mean concentration. All of the charts presented in
the POC report were so they
would cover the same time period. The
*i*allwaterqualityhollectedforthesewellffiThedata
pointsusedincludedtheearliestsamplesffiandquarterlysamples-
every period thereafterffi
^-AA-.-l*1
!r{".* i
.?,
S:STAFFrtrlRI/TEXT9/ClnrrclRpiC I
\i
\,1,,r,Ju'"
r.,' -
-Io' b* ru &.'
,
"
r-l
r{ llnv. lJr et '\r' "
It Erztt
Page C-48
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Baseline Surface Water Ouality
Sampling of surface water quality in the Mill vicinity began in July 1977 and continued
through March 1978. Baseline data describe and evaluate existing conditions at the Mill
site and vicinity. Sampling of ephemeral surface waters in the vicinity was possible only
during major precipitation events, as these streams are normally dry at other times.
The locations of the surface water sample sites are presented in Figure C-8. The water
quality values obtained for these sample sites are given in Dames & Moore (1978) Table
2.6-7, and NRC (1979)Table 2.22. Water quality samples were collected during the
spring at several ephemeral streams that drain the project area. These streams include
Westwater Creek (SlR, 59) Corral Creek below the small irrigation pond (S3R), the
junction of Conal Creek and Recapture Creek (S4R), and Cottonwood Creek (S8R)
Samples were also taken from a surface pond southeast of the mill (S5R). No samples
were taken at S2R on Corral Creek or at the small wash (S6R) Iocated south of the site.
Surface water quality in the vicinity of the Mill is generally poor. Waters in Westwater
Creek (S lR and 59) were characterized by high total dissolved solids (TDS; mean of 674
mg/liter) and sulfate levels (mean I 17 mg of SOr per liter). The waters were typically
hard (total hardness measured as CaCOI; meao 223 mg/liter) and had an average pH of
8.25. Estimated water velocities for Westwater Creek averaged 0.3 fps (0.08 m/sec) at
the time of sampling.
Samples from Cottonwood Creek (S8R) were similar in quality to Westwater Creek water
samples, although the TDS and sulfate levels were lower (TDS averaged 264 m{liter;
SOa averaged 40 mg/liter) during heavy spring flow conditions [9hS (24 m/sec) water
At /.,, /.^ qib
velocityl.
S:STAFFAIR-R/TEXT99GlR5eYclRD€ I
{' --D5b 11
AJT,AU v
+Wql*e' ^
Page C-49
May 28, 1999
International Uranium (USA) Corporation
White lv{esa Uranium Mill
Groundwater Information Report
rc\ *'
The concentrations of TDS increased downstream in Corral Creek, averaging 3,180
mg/liter at S3R and 6,660 mg/liter (one sample) at S4R. Total hardness averaged in
excess of 2,000 mg/liter, and pH values were slightly alkaline. Estimated water velocities
in Corral Creek were typically less than 0.1 fps (0.03 m/sec) during sampling.
NN,/
The springfsample collected at the surface pond south of the project site (S5R) indicated a
TDS concentration of less than 300 mg/liter. The water was slightly alkaline with
moderate dissolved sulfate levels averaging 42 mgfliter.
During heavy runoff,, the concentration of total suspended solids in these streams
increased sharply to values in excess of 1,500 mg/liter (see U.S. NRC I979, Table 2.22).
High concentrations of certain trace elements were measured in some sampling areas.
Levels of mercury (total) were reported as high as 0.002 mg/liter (S3R, 7125177; SBR"
7125177). Total iron measured in the pond (S5& llll0l77) was 9.4 mg/liter. As stated
by Dames & Moore, these values appear to reflect groundwater quality in the vicinity and
are probably due to evaporative concentration and not due to human perturbation of the
environment.
1997 EA AND LICENSE RENEWAL
The Mill license was renewed in 1997. Copies of the renewal license and EA were
provided directly to UDEQ by the NRC, but a copy is included in Attachment 8 for ease
of reference. The NRC specified groundwater monitoring in accordance with the POC
approach in the 1994 POC Report.
As stated in Section 2.2 of the POC Report:
"The uwage total dissolved soli ds tFE6) concentrations &.'cite' ud&*in
\.
. ,1 * ftolti'"['t- /
the perched zone rangcfr€mf
C l,,ra T- ._
S:STAFf/f,{R.tuTEXTeerclRJee/GlReicl Cl Nq fl
itior (mg/L) and
,,{t,\QS
",, i, , '; (a.)pr,
, Auxl
fD:
.'-tf tr -
\r
3,0'ro
I
?. ii.r r) i il1
0 l?- n't ;,t Q 0.,I
t,1.,441,1, i,
I
'7, rr o v1Jt I
Page C-50
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
average sulfate coneentrations range from 656 to 2,956 mgil. These
ranges of concentrations also have been documented in sandstone and
shale units in other semi-arid regions with natural poor water quality.
According to Utah Administrative Code R448-6, ground water with TDS
of 3,000 to 10,000 mg/L is classified as Class III - Limited Use. A
number of upgradient, transgradient and downgradient wells, including
wells WMMW-3, WMMW-44, WMMW-I2, WMMW-I4, WMMW-I5,
WMMW-I7 and WMMW-19, would fall into this classification,
indicating the poor quality of the perched water."
Groundwater Discharge Control P lan
ll-lll:." "Fr'a(
.n Z', f '\
d i<-r. '.>L
-"r r l-""-..(()." .-r/
-F#**-'-''
This sectiotr asks the applicattt to select a compliarrce monitoring method to demonstrate
an adequate discharge conlrol system. Among the discharge control options is "no
discharge," meaning that the system prevents any discharge of fluids to ground or
groundvaler by lining discharge point with multiple rynthetic and clay liners; an earthen
liner, v'hich controls the volume and rale of eflluent seepage by lining the discharge
poitrt t+,ith a low permeability earthen liner (e.g. clay), and demonslraliotr that the
receivitrg ground waler, al a point as close as practical to the discharge point, does nol
or will not exceed the protection levels. This demotrstration should be based on
numerical or analytical saturaled or unsaturated groundwater flow and contaminant
I ranspor I si mu lat ions.
S:STAFF,lrlRR./TEXT99/GlR99/GlRptC I
Page C-51
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater In formation Report
CELL DESIGN AND CONSTRUCTION
The White Mesa Mill has constructed four below-grade tailings disposal cells for
containment and storage of tailings generated during the uranium milling process, ns
follows:
l) Cell I is constructed with a$ffiffiHHffiiner covered with earthen material.
This cell was completed in l98l and is
@
2) Cell 2 is constructed with a;ffiHffiiner covered with earthen material.
This cell was completed in 1980 and is used for the storage of barren tailings
sands. This cell has received an interim cover and prescntly receives no
liquid effluent from the Mill.
3)Cell3isconstructedwitham[inercoveredwithearthenmaterial.
This cell was completed in 1982 and is used for the
ColCell4isconstructedwithaffiner.Thiscellwasconstructedin
II 1990 and presentlyL-
S:STAfF/Mi,WTEXT99relR gryclRe.C I
Page C-52
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
OzuGINAL DESIGN STANDARDS
The White Mesa Mill's original license required that the tailings system be constructed in
accordance with the design criteria in 40 CFR 192. These criteria required that the
system be designed to protect groundwater from:
Radionuclides
The full suite of RCRA characteristic wastes
The full suite of RCRA listed wastes.
This means that, because organic and inorganic chemicals are added in the Mill process,
the tailings system liners had to be designed to be as protective as both a hazardous waste
disposal system and a radioactive waste containment system.
The tailings cells were designed and constructed in accordance with standards and
requirements of the NRC which approved both the design and the construction of the
cells. Construction requirements were incorporated into detailed plans and specifications
that were reviewed and approved by the NRC. These specifications called for Registered
Professional Engineers and NRC inspectors to oversee and approve the construction.
These inspections were documented by as-built records submitted to the NRC, as
required by law. These records document that the tailings cells were constructed to a
very high standard. In accordance with license requirements, performance of the cells
has been monitored since their construction by annual reports certified by Registered
Professional Engineers and on file with the NRC.
a
a
o
7
I tr1l -) r'q '
r 'l rlf
S:STMF/MRR /TEXTg9rclR,99/clRprC I
Page C-53
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
COMPOSITION OF THE TAILINGS
The Mill's tailings cells contain chemical and radionuclide constituents from three
sources:
Components of theccefed to the Mill
Residuals of chemicals that were added to the ores during processing in the Mill
o Materials which NRC requires that IUSA collect and dispose of in the tailings,
including:
- soils contaminated by windblown dust from the Mill ore pad
- {ff:fromthetlllG!
- crfrr*r from tholffnd
- ndiacothodobds which$RGre+riffisfo.p
The primary components in the tailings, prior to the introduction of alternate feeds, have
included:
a
a
a
a
a
a
a
a
a
Mineral sands (residual minerals from ores)
Acids
Bases
Organic hydrocarbons from kerosene
Inorganic and
rJ ')
organic chemicals from bench-scale proces(iasting..) -koJ ;"i 1.
S:STAFF/MRR/TEXT99J'CIR g9/GlRplC I
"\&{twl -rpDl*''| . r'fu*l'o ,\'1"" I
" *--
Page C-54
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
The liner system was designed for compatibility with the full suite of Criteria 13 organic,
metallic, and radionuclide compounds
. f,very contaminant present in conventional ores was anticipated in the design
standards for the liner
. Every chemical introduced in the Mill processing circuit was anticipated in the
design standards for the liner
. Every compound introduced in alternate feeds was anticipated in the design
standardsfortheliner. L"rL-* ,-- t'^,'i,;'i I
COMPATTBILITY OF THE LTNER WITH OzuGINAL AND ADDITIONAL
COMPOLINDS
The material selected forthe design and construction of the synthetic liner in Cell 1,2,
and3,wasl&miW.
,, r t. + 4 *- ^.t,o, I I (. a^,po*,!o (*f*vtvlr/
I \ -^-s[ar;'lO*t'd?oPi':ri"'rai nzg'"b^q4€ n*o: I tl 'c*^ff*'-'*llftorT
p.lc .: L1 ,.+ri '-" pvC is commonty use , t 'b,n/ft)---
o'991i c"t='" '':.:1,_ g,tb D hazardous waste landfills, and
KonP*' [:'ff*\-I P ' ' 2) solid waste landfills which contain a combination of domestic and
commercial sanitary wastes, municipal trash, and ha"ardous chemicals.
EPA has expended significant effort in recent years to assess what impact, if any,
industrial wastes may have on the performance and longevity on various types of liners.
These studies have found that PVC liners are compatible with dilute concentrations of
S:STAFF/MRIyTEXT99rclRt99/GlR9rc I
\
)
)
Page C-55
May 28, 1999t\enationar''iili,T,t'.:lir:.:r#ffi
i
\ ,,"\- o"- Groundwater Information Reportl)v
{organic materials including industrial solvents. Research conducted by the EPA has
concluded that PVC liner overall performance is unaffected by exposure to a wide range--)t/tt, \ 4,.t','' '
r$.\ 7'"
^
\*{,#5,^
>dT;nJ{td1
- -9--"--'
,! \
fl' r 14, ''o "'
*r' ioLt*r'
%"[f*t.r'
184). EPA studies found that PVC liners are fully compatible with most industrial waste
solutions including all those potentially applicable 1o the White Mesa Mill operations. [*",)r"-t'\ -;*,"i,rk)U f<o.e*a-r''*p. t-;
MODELING
of solutions (EPA" Lini ilities. 1984. oaee
The Knight Piesold Report and supplemental responses to UDEQ, described above
Section B.(8), address the Mill's liner system and conclude that the liner system wl
serve to prevent discharge of tailings fluids to groundwater and will prevent an
exceedance of protection levels. This demonstration was based on numerical cr*uwdr
ir eentanqi*eo,tM-
because the hydrogeologic setting, the integrity of the liners, and other factors described
i n the IGeigfu'Fi6sold' @rt" *erd,th,tlse"ia no probeblo,s*reo b c!$w, di#ge
l-
of uitings f,uids togrotrrdlretm '' \'-'o *lt 50?44 '
10. Compliance Monitoring Plan
UDEQ aslrs for a demonstration that the methd of compliance monitoring meels
specified criteria lor groundwater monitorittg, including well location. constrttction,
operation; sampling and analysis procedures: and backgroundwater quality.
Section 3.0 of the POC report details the detection monitoring program approved by the-
U.S. NRC for the Mill. The report contains details regarding well location, construction,
and operation, and development of baseline water quality levels. Baseline is set in
accordance with methods recommended by the U.S. Environmental Protection agency,
and are detailed in Section 3.3, Statistical Analysis of Monitoring Datq in POC report.
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Page C-57
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
c) Plan and cross-sectional views of a &r*l*odcmtfu*",m which Ccrcills the
location and elevation of tailings. The plan includes details on cover thickness,
physical characteristics of cover materials, proposed testing of cover materials
(specifications and quality assurance), the estimated volumes of cover materials
and their availability and location.
d) Detailed plans for placement of rock or vegetative cover on the final reclaimed
tailings pile and Mill site area.
e) A proposed irnplementation schedule for items A through D above which defines
the sequence of events and expected time ranges.
0 An fffl15i*$ show that the proposed type and thickness of soil cover is adequate
toprovideffiandisadequatetoassurelong.termstability,as
well as an analysis and proposal on methodology and time required to restore
groundwater in conformance to regulatory requirements.
g) A detailed lo*,,mspi! of each phase of the reclamation plan to include
contractor costs, projected costs of inflation based upon the schedule proposed in
item E, a proposed contingency cost, and the costs of long-term maintenance and
monitoring.
ruSA has prepared the reclamation plan in accordance with NRC requirements for
stabilization of mill tailings. It should be noted that many of the technical approaches
and requirements imposed by the NRC on development of the reclamation plan are
unique to long-term management and stability of uranium mill tailings, and require
conformance with these established approaches. It is IUSA's understanding that the
NRC review of the reclamation plan is near completion.
S:STAff /MRVTDO9rcnrelrGlR!.C I
Page C-58
May 28, 1999
lnternational Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
12. Contingency and Corrective Action Plans
The UDEQ states that the purpose of a Contitgency Plan is to outline definitive actions
to bring a discharge or potenlial discharge facility into compliatrce with the regulations
or the permit, should a violation ocah This applies to both new and exisling facilities.
UDEQfurther states thatlor existingfacilities that may have caused any violalions of the
Ground Water Quality Standards or class TDS limits as a reslt of discharges prior to
the issuance of the permit, a plan lo correcl or remedy any contaminated groundwater
must be included.
Contingency Plan
UDEO states that this plan should address: cessation of discharge until the cause of the
violation can be repaired or corrected; /acility remediatiott to correct the discharge or
violaliotr.
Section 3.3.1 of the POC report details the use of EPA-approved statistical methods for
evaluation of monitoring data, involving the preparation of control charts. The control
charts presented in Appendix B of the POC report show that based on water quality data
taken after March 24, 1994, the POC monitoring wells do not show impact from Mill
operations. As future quarterly water quality data are collected, the control charts are
updated and compliance evaluated. If sampling of a POC monitoring well indicates
exceedance of the control chart upper bounds, a confirmatory sampling program will be
initiated. The confirmatory sampling program will consist of monthly sampling of the
affected well for a minimum period of six months. The minimum sampling period of six
months has been chosen, and committed to as a condition of the NRC license, to provide
a statistically significant population for evaluating possible outliers and seasonality.
After the confirmatory sampling program is complete, the POC groundwater quality data
S:STAff/MR.R./TEXT91I/GlR599/GlR.r.C I
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Page C-59
May 28, 1999
lnternational Uranium (US A) Corporation
White Mesa Uranium Mill
Groundwater Information Report
will be analyzed using an Analysis of Variance (AIIIOVA) as per EPA (1989) guidance.
The AIr{OVA would be used to determine if the water quality data collected during the
confirmatory sampling program are statistically different from the water quality data
collected before the confirmatory sampling program. If the data are significantly
different, a corrective action plan will be prepared.
Corrective Action Plan
UDEQ states thatfor existingtacilities that hary already violated Ground Water Quality
Standards, this plan should ittclude: a characterizalion of contaminants groundwater;
facility remediation proposed or ongoing including timetable for work completion;
ground wate r remedi ati on.
As stated previously in this submittal, Mitl operations have not, to date, produced any
detectable contamination of groundwater. The POC report presents the rationale for
locations and compliance criteria for groundwater points of compliance for the Mill. The
purpose of the POCs is to continue to provide timely detection of potential leakage from
the tailings disposal cells at the Mill, and to assure protection of the Entrada/tlavajo
Aquifer. Groundwater modeling described in the Knight Pi6sold report has indicated that
there is no probable cause to believe that even the perched zone used for groundwater
monitoring could be impacted by tailings constituents. And, as stated above, the POC
report provides that, in the unlikely event that these constituents are deteded and
confirmed to be elevated in the POC wells, a coffective action plan will be prepared and
submitted to the NRC.
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S:STAFF/UI [/TEXT99/GlR599GlRptC I
Page C-60
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
Uranium Mill Tailings Radiation Control Act Requirements
The I le.(2) tailings and tailings liquid generated by the Mill process are contained in
I le.(2) byproduct material impoundments that are subject to stringent regulatory criteria
set forth in l0 CFR Part 40, Appendix d which conform to EPA's active mill tailings
site regulations set forth at 40 CFR Part 192. The Appendix A Criteria impose soil and
groundwater protection standards for radioactive and nonradioactive (hazardous) waste
constituents that provide protection equivalent to that provided by RCRA. In addition,
the site closure requirements under UMTRCA require measures suffrcient to provide
reasonable assurance of stability without active ongoing maintenance for up to at least
200 years and to the extent reasonably practicable 1,000 years, far beyond the regulatory
horizon of RCRA. Moreover, upon closure, custody to the I le.(2) byproduct material
impoundments would be transferred to the DOE or the State which, in turn, becomes a
NRC licensee with the primary responsibility for perpetual maintenance and surveillance
of such sites.
CERTIFICATION
I certi$ under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
beliet, true, accurate, and complete. I am aware that there are significant
-
S:STAFF/MRL/TEXT99'GtR.JlrgrclnDrc I
Page C-61
May 28, 1999
International Uranium (USA) Corporation
White Mesa Uranium Mill
Groundwater Information Report
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations:
David C. Frydenlund
Vice President and General Counsel $031628-7798
PHONE NO.
May 28. 1999
DATE
SSTAfr/URI/TEXT9/qm,YG|ngicl
Pages 6-9
of the
Titan Report
o Revision 0
luly 27, 1994
page 6
Member of the chinle Formation of Triassic age; and the DeChelle Member of the cutlerFormation of Permian age.
Recharge to aquifers in the region occurs by infiltration of precipitation into the aquifers along
the flanks of the Abajo, Henry and La Sal Mountains and along the flanks of folds, such as Comb
Ridge Monocline and the San Rafael Swell, where the permeable formations are exposed at the
surface (Figure l.l).
Seventy'four ground water appropriation applications, within a five-mile radius of the Mill site,
are on file with the Utah State Engineer's office. A summary of the applications is presented in
Table l'l and shown on Figure 1.3. The majority of the applications is by private individuals
and for wells drawing small, intermittent quantities of water, less than 8 gailons per minute
(gpm), from the Burro Canyon Formation. For the most part, these wells are located upgradient
(north) of the White Mesa Uranium Mill site. Stockwatering and irrigation are listed as primary
uses of the majority of the wells. It is important to note that no wells exist downgradient of the
site within the 5-mile radius.
The productivity of the Burro Canyon Formation within the White Mesa site is substantially
different from the productivity of this formation upgradient of the site. For the most part, the
documented pumping rates from on-site wells completed in the Buno Canyon Formation are less
than 0.5 gpm. Even at this low rate, the on-site wells are typically purnped dry within a couple
of hours. This low productivity stems from the fact that the White Mesa Uranium Mill is located
over a peripheral fringe of perched water; saturated thickness decreases under the site and
permeability of the forrration is very low.
These observations have been verified by snrdies performed for the U.S. Deparunent of Energj,s
disposal site at Slick Rock which noted that the Dakota Sandstone, Burro Canyon Formation and
upper claystone of the Brushy Basin Member are not considered aquifers due to the low
permeability, discontinuous nature and limited thickness of these units (DOE, 1993).
cRT\St BDAECIORY\TILENAMEREV r?a7l9.1 OTlfAilEnvironrnen tal
o Table l.l
Wells Located Within A S-Mile Radius ofThe White Mesa Uranium Milt
Map Numbers Water Right
Nielson, Norman and Richard C.
Guymon, Willard M.
Nielson, J. Rex
Nielson, J. Rex
Lyman, Fred S.
Plateau Resources
Plateau Resources
Nielson, Norman and Richard C.
Lyman, George F.
Holt, N.E., Mclaws, W.
Perkins, Dorothy
Energy Fuels Nuclear, Inc.
Energy Fuels Nuclear, Inc.
Uah Launch Comptex
Energy Fuels Nuclear, [nc.
Energy Fuels Nuclear, [nc.
Energy Fuels Nuclear, [nc.
Energy Fuels Nuclear, [nc.
Jones, AIma U.
Energy Fuels Nuclear, Inc.
BLM
Halliday, Fred L.
Perking, Paul
Redd, James D.
Brown, Aroe G.
Brown, George
Brown, Llo M.
Rentz, Alyce M.
Rogers, Clarencc
Perkins, Dorothy
Brandt J.R. & C.J.
Montellq Frank A.
Snyder, Bertha
Martineau, Sanley D.
Kidq Ronald D. & Catherine A.
Patmer, Ned J. and Marilyn
Grover, Jess M.
Monson, Larr;l
Neilson, Norman and Richard
Watkins, Henry Clyde
Shumway, Glen & Eve
Energy Fuels Nuclear, Inc.
(not drilled)
SEC TWP RNC CFS
I I 37S 228 0.015l0 37S 22E 0.015l0 37S 228 0.01sl0 37S 228 0.013l0 37S 22E 0.02215 37S 22E 0.015ls 37S 22E 0.01st4 37S 22E 0.01515 37S 22E 0.01515 37S 22E 0.0072t 37S 22E 0.0152t 37S 22E 0.622 37S 228 l.n27 37S 228 0.01528 37S 22E l.lt2E 37S 22E l.lt28 37S 22E 0.01528 37S 22E 0.633 37S 228 0.01s33 37S 228 0.68 37S 22E 0.01
l I 37S 22E 0.0152 375 228 0.0t52 37S 228 0.1r 37S 22E 0.015I 37S 22E 0.015l 37S 22E 0.004t 37S 22E 0.0152 375 22E 0.01s2 37S 22E 0.015l 37S 22E 0.0153 37S 22E 0.015I 37S 22E 0.1I 37S 22E 0.015I 37S 228 0.015I 37S 22E 0.0t5r 37S 22E 0.015l 37S 22E 0.015I 37S 22E 0.015I 37S 22E 0.01515 37S 228 0.01s2t 37S 228 0.600
USE Depth (ft.)
IDS t50_200s82IDS 160s 165IDS I2Oo 740o t35IS ls0-200s 135s 195s 150o t600o 1820D 650o 1885o l8s0DSO 1800o 1500s 200o t600s t70IS 180ID I8OTD 2OOIS 2IOtDS 140IDS l4lTD I8Os t42s 100-200IDS 160IDO 190IDS 196TD 160IDS 160IDS Os 160TDS I4OIS t32IS I5OIS 60o 1600
o
l
2
3
4
5
6
7
8
9
l0il
l2
l3
l4
l5
l6
L7
t8
l9
20
2t
22
23
24
,<
26
27
28
29
30
3l
32
33
34
35
36
37
38
39
40
4t
42
OTITAilEnvirorunental
Table l.l
Wells Located Within A S-Mite Radius of
The White Mesa Uranium Mill
(Continued)
Map Numbers
45
46
47
48
49
50
5l
52
53
54
55
56
57
58
59
60
6l
62
63
64
65
66
67
68
69
70
7t
72
73
74
Notes:
D - Domestic
I - Irriguion
S- Stockwatering
O - Industrial
Depth (ft.)
I 860
185
226
180
164
100-300
100-300
75
100-300
160
130
130
2t0
100-200
100-200
140
145
180
t70
734
250
150
200
190
180
165
160
43
44
Water Right
Energy Fuels Nuclear, Inc. (#l)
Watkins, Ivan R.
Waukesha of Utatr
Simpson, William
Guyman, Willard M.
Harrieson, Lynda
Hurst, Reed
Kaer, Alvin
Heiner, Gerald B.
Laws, James A.
Laws, J. Parley
Anderson, Dennis & Edith
Guymon, Eugene
Guymon, Eugene
Guymorl Dennis & Doris
Guymon, Eugene
Guymon, Eugene
Perkins, Dorothy
Wa&ins, Ivan R.
Roper, Lloyd
Smith, Lee & Marylynn
McDonald, Kenneth P.
Brake, John
Brake, John
Red4 Parley V. & Reva V.
C & C Construction
Guymon, Dean W.
Phillips, Elizabeth Ann Hurst
Howe, Leonard R
Shumway, Mark Eugene
Shurnway, Mark Eugene
Lyman, Henry M.
SEC TWP RNG CFS USE
28 37S 22E 1.100 0I 37S 22E 0.200 s3 37S 228 0.015 D3 37S 228 0.030 ID2 37S 22E. 0.030 s2 375 22E 0.012 IDS2 375 228 0.015 D2 37S 22E 0.015 IDS2 375 228 0.015 tD2 37S 22E 0.015 IDS2 37S 22E 0.015 IDS2 37S 22E 0.015 tDS2 37S 22E 0.100 IDS2 37S 22E 0.015 s2 37S 228 0.030 IDS2 37S 22E 0.115 IDS2 37S 228 0.115 IDS2 37S 228 0.015 IDSr 37S 22E 0.015 IDS34 365 22E 0.015 ID34 365 228 0.060 IDS34 365 22E 0.015 tDS34 365 22E 0.015 ID34 365 22F. 0.01s Is34 365 228 0.015 IS34 265 22F 0.015 ts3 37S 228 0.015 IDS34 365 22E 0.015 I3 37S 22E 0.015 03 37S 22E 0.015 ID3 37S 228 0.01s IDS3 37S 22E 0.100 IDS
o
o
150
200
SEC - Seaion
TWP - Township
RNG - Range
CFS - Cubic Fea Per Second
O T I TAf ! E nviro nrne ntat
o
I
I
a
SCALE
GROUND WATER APPROPRIAT]ON
APPLICATIONS WITHIN A FME MILE
RADIUS OF THE WHITE MESA MILL
PREPARED FOR
ENERGY FUELS NUCLF3R
DEiIVER, COLORADO
OflTAfIEnviron,,,entat
2000 FEFr
FIGURE 1.3 ORAWING NUMBER
11 11 -tA7
o Revision 0
luly 27, 1994
page 9
Two water wells exist approximately 4.5 miles southeast of the site on the ute IndianReservation' These wells supply domestic water for the village on the mesa along Highway l9l.Both wells are completed in the Entrada sandstone which is 1,200 feet below the ground surface.
Climatological Setting
The climate of southeastern Utah is classified as dry to arid continental. The region is generallytypified by warm surrmer and cold winter temperatures, with precipitation averaging less thanll'8 inches annually and evapotranspiration in the range of 61.5 inches annually (Dames andMoore, l97S).
Precipitation in southeastern utah is characterized by wide variations in seasonal and annualrainfall and by long periods of no rainfall. Short duration sunmer stonns furnish rain in smallareas of a few square miles and this is frequently the total rainfall for an entire month within agiven area The average annual precipitation in the region ranges from less than g inches at Bluffto more than 16 inches on the ea^stern flank of the Abajo Mountains, as recorded at Monticello.The mountain peaks in the Henry, La Sal and Abajo Motrntains may receive more than 30 inchesof precipitation, but these areas are very small in comparison to the vi*t area of much lowerprecipitation in the region.
1.4
CRTISUBDnECIOR.I1FTLEIIA.METEV [?arl9{t O T I EfrfE E nvironrnentat
White Mesa
Drinking Water Source
Protection plan
WHITE MESA MILL
DRINKING WATER SOURCE PROTECTION PLAN
March 30, 1999
Revision 1.0
Contact Ronald Berg
lnternational Uranium (USA) Corporation
White Mesa Mill
il25 South HighwaY 191
Blanding, UT 84511
Phone: (435) 678'2221
\[rr;n ]il. .gaa
WHITE }IESA }IILL
DzuI\'KIi{G IVATER SOIRCE PROTECTIO)i PLAI{
TABLE OF CONTENTS
Page
E,IGCUTnTE StMMARY..... """"'l
I.O INTRODUCTTON. ".......J
Ll System lnformation """'3
1.2 Slurce Information """'3
1.3 Designated Person... "" "'l
DELINEATION REPORT. .........4
2.1 Geologic Data.. """"""4
2.2 Well Constnrction Dau. " "" ' 14
2.3 Aquifer Data. """"""16
2.4 HydrogeologicMettrodsandCalculations. """""17
2.5 Map Showing Boundaries of the DWSP Zones' """""'18
2.6 ProiectedequiferClassification..'' ""'""18
T\-\,ENTORY OF POTENTI.AL C ONTAMINATION S OURCE S . . . . . ... . . ..20
A S S E S SMENT OF POTENTI.AL C ONTA]V{INATION S OURCE
HAZARDS "" "" "21
TvIANAGEMENT PROGRAIVI FOR E)fl STING POTENTTAL
CONTAIVIINATIONSOLjRCES """" ""27
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
TvIANAGEMENT PROGRAM FOR FUT[.TRE POTENTI,AL
CONTATVIINATION SOLjRCE S
IMPLEMENTAfiON SCHEDULE. . .. .
RESOURCE EVALUATION.
RECORDKEEPING.26
23
24
?s
CONTINGENCY PLA}IS .27
LIST OF FIGT,RES
:"
\[.tr,:;t -:r). ';oc
WrilTE IIIESA }IILL
DRI\KING WATER SOLIRCE PROTECTION plAti
LIST OF TABLES AND FIGLRES
2.1 Site Plan Map
l.l Cross-Section A-A'..
1.3 Cross Section B-B.
2.4 Elevation of Top of Brushy Basin
2.5 Report of Well Driller, Water Well2
LIST OF TABLES
Table 2'r"" ....r5
Table 2.2.,.. ....t6
....t2
. ,:.--
-l ,'
\l.rrch -:r,,.
E.}GCUTT!'E SLA,[\{ARY
*:Tl:,i,X.n.Yl.:i,iH:-,::from the Enuada,Narajo.{,quifer, which is separated
#,T.:::': -T-I":r"g1Navaiq Aq:if:: is present "t a.ptns t.;;;i.i,,ili ffil.::;below'the surface and is."p.-bl. oid.lir.ring from rso a::s gpm of water.
Water well No. 2 (WW-2) provides water toEntradaAiavajo Aquifer. Ttre wlll was constructed
fearures:
The well was drilled to a depth of l,gg5 feer.
The borehole diameter of the well is l5 inches.
The well casing was set to a depth of 1,250 feet.
The well casing diameter is l0 inches with a nominal wall thickness of 0.150inches gauge.
The well was packed from 100 feet to r,250 feet with graver.The well was sealed to 100 feet with concrete.A submersible pum-p wils placed in the wefl casing at a depth ofapproximately 1,000 feet.
the White IVIesa lvlill from thein 1980 incorporating the follorvine
r)
2)
3)
4)
s)
6)
7)
t- - i *t
{'b\.'\ ;?t 7'
,a: \. r, .' ,' -r 'n
'rl "
Drirking water Source Protection (DwsP) plans are the primary means for the publicwater system to Protect their sources of drinking water &om contaminatioa. fne OWSpplan for the white Mesa Mill shows that there ir. no potential contamination souces inthe vicinity of the well or wellfield from which *atei is obtained for toe at the whiteiv{esa iVill.
The Entadaalavajo Aquifer is a protected aquifer. The hydrogeologic data provided inthis report verifr
-protected aquifei conditions. A protected aquifer is an aquifer which isa producing aquifer with a naturally protective layer of clay ai r...ilo r..t in thickness,located above the aquifer. Because the EntradaiNavajo Aquifer can bc classified as aprotected aquifer, no drinking water protection zooes exist foi ww-2.
The Eatrada/l'{avajo sandstones form one of the most permeable aquifers in the region.( ': A perchd water zone exists h ei Burro Canyon Formatioa above trre rnt "a"nrii";-o"':i rr r Aquifer. $9.Elre,nod'€prm*im and monitoring of the perched water zone dm--PgirmF4ts"ilNfeliliGdffi.''tnqr0a*liryEstG*h'in use at &e Mill were or n*dbehryirgtaiIingsliquid@-Verticalmigrationtoanysignificarrtdepthishighlv-l.,.
unlikely due to the low permeability ana sigrincant thickiess of the underlying ,;iunsarurated aquitard.
It},
The Enrada't'Iavajo Aquifer is separated from the Burro Canyon Formation, which hosts . .i.r,the perched zone used for monitoring, by an aquitard composeo of approximately 1,100
R.e'. ..,-t
\larch -;0. iqco
:::::t Ht:,J:T:|.:lr]:r. cta1s, sil,rllone-. and sandstones interbedded with sisniricantsha.les. The Brushy Basin member (:00--t50 tbet thickl is rhe tjrst secti* -: .-t l"*j ;i;;;i$fi?il:,1i.' ff:#::, :::':X;il::,,ffi[* #*il:that prel'ents thedo*nward percloration of groundrvarer. Beneath the B;fi;-";";
fT.Tiq units of the Vlorrison and Summerville Formations, rwhich also overlie the
in member. rhe
numerous clay zones, including one i00-foot s--'tion consisting of g0 percent clay..
Recharge to the Entrada.a'lavajo Aquifer. occurs many miles from the Mill by infilrrationof precipitation along the flanks of the.]bajo, HenryhJi, s.iffiffi Jno *. flanksof folds, such as the Comb Ridge Monocline ana te San Rafael Sw.ell, where rhepermeable formations iue exposed at the surface. Recharge does not occur frominfiltration of precipitation failing on the surface of white Mesa.
subsection la28(e) of the safe Drinking water Act Amendments of 19g6 identif,.a'Wellhead Protection Area'or WHpA as:
'the surface and subsurface :uea surrounding a well or well field, supplyin-e apublic water system' through which contaminane arl reasonably likely to move towardand reach such water well or well field.,'
Based on the conditions described in this report, contaminants potentially introduced atthe surface would not reach the well or *"il field of ww-2. 'Ttrerefore,Gr.
are nopotential contamination souces within the protection zones of the wellhead.
(
"1 f,-n@:
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l'1,, "l /I ! tl tt:
t/'f
hITRODUCTION
l.l System Information
l.l.l Water system
system.
The Water System Name is
The Water System Number
The Water System Address
845 I l.
name, number and address. and type of water
Intemational Uranium (USA) Corporation.
is 19025.
is 6425 South Highrvay l9l, Blanding, UT.
isa
t.2
The system is an existing water svstem.nontransient/noncomrnunity water system.
Source Inforuration
L.2.1 Source narne, type, and description of location.
The sor:rce name is water weil No. 2 (ww-2). It is gn existing weil, andis an individ,al source. The welr, which is arready coustructed, is located2'100 feet north' and,2,200 feet west, &om the soutlr..rt corncr of Section28, T37s, R22E, SL!M, -9n properry ormed by International uranium(USA) Corporation at the Whiti lviesa Uranir* t iitt.
Designated Person
The Designated Person, l?. yh* correspondence regarding this report andfutrue correspondence will be directed, is:
Mr. Rouald Berg
Intemational Uranium (USA) Corporation
White Mesa Mill
6425 South Highway l9l
Blanding, UT 8451I
Phone: (435) 678-ZZ2t
r.3
dz1 [ erl:r-'nr-
i.-r:
\ Ilr;lr -ir-).
DELI-\EATION REPORT
Geologic Data
2.1.1 Regional Ceologic Sening
Rock of upper Jurassic and cretaceous age are exposed in the canyonwalls in the vicinity of the White Mesa Uranium Mill site. These rockunits include, in descending order, the following: Eolian sand ofQuaternary Age and varying thickness overlies the Dikou sandstone andMancos shale on the mesa. A thin deposit of tarr.rs derived from rock failsof Dakota sandstone and Buno canyon Forrration mantres the rowervalley flanlc. underlying these units are the cretaceous Age erosionalrer,nants of Mancos shale, Dakoa sandstone, and Buno canyonForuration. Erosional remnants of Mancos share are only found north ofthe Mill site. The Bnshy Basin, westwater canyon, Recaprue and saltwash Members of the upper Jtuassic Age Monison Formation areencountered bclow the Burro canyon Formation. The Summerville
Formation, EaEnda sandstone, and Navajo sandstone are the deepest unitsofcoacern encountered at the site.
In general, the rock fomrations of the region are flat-lying with dips of I to3 degrees. The rock formations are inCised by strearmsihat hare formedcanyour between intervening areas of broad mesas and bunes. Anintricate system of deep canyons along and across hogbacks and cuestashas rcsulted from faulting, upwarping and dislocation Jf rocks around theintnsive rock masses, such as the Abajo Moutains. Thu the region isdivided up into numerous hydrorogical areas controlled by stnrcuralfeatures.
/" The white N{esa uranium lv{ill is located near rhe western edge of theBlanding Basin within the Canvonlands section of the colorado plateau
physiographic province. The fanyonlands rru". *J.rgone broad. fair5.horizontal uplift and subsequent erosio.n w-hich t ur. p.ir..a ,ir. ,.gr":,characteristic topography represented by higtr plateaur. ,.r"r. bunes anddeep canyons in_cised.into relatively flat lylg'sedimentary rocks of pre-Tertiar.v age. Erevations range &om approiimatery 3,000 feet in thebonoms of the d::g 9-yons arong the southwestern m"rgins of the ,.gionto more than I1,000 feet in the Henry, Abajo and LaSal mor:ntains locatedto the northwest and northeast of the faciiity. with the exception of thedeep canyons and isorated mountain peaks, an average elevation slightllin excess of 5,000 feet persists over most of the canyonlands. Theaverage elevation at the white Mesa uranium Mill is 5,600 feet mean sealevel (MSL).
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/, .1 The strara underly'ing white Nlesa ha'e 3 regionai dip of i: to I degree rothe south: howe','er. local dips of _i de_erees hi'e been ;.;:;;.Approximarely :-i miles to the north. rhe Abajo Mountains, formed brigneous intrusions. have caused rocal faulting. ,**t*.--.;idisplacement of the sedimentary section. However.-no faults'hanre beenmapped in the immediare vicinit-v- of White Nlesa.
on a regional basis, the formations that are recogrized as aquifers are:cretaceous-age Dakota sandstone and the upper part of the lvlorrisonFormation of late Jurassic age; the Entrada'sandstone and the Navajosandstone of Jurassic age: the wingate sandstone and the ShinarumpMember of the Chinlf" Formation of Triassic agei and the DeChelleMember of the Cutler Formation of permian aee.
The presence of groundwater wirhin and in pr-o*i-i,y to the site has beendocumented in three strata: the Dakota sandstone, the Burro Canyon
.. Formation, and the Entrada,o-iavajo sandstone. a.> r,,", *:J,; , )-. i.-,'-"r'. I'ic2.1.2 Geologic Featurres and Aquifer characteristics observed in theWell and Area of the potential protection Zones
This section details- the stratigraphic name(s), lithology of the aquifer andconfining units, and a discussion regarding the lack #fr..t*., and faultsin or near the well.
As discr:ssed above in section z.l.l, Groundwater occurreuce within theproximity of the white Mesa uranium Mill has been documented in rfueestrata: the Dakota sandstone, the Burro canyon Formation, and theEntrad^aNavajo sandstones. The Burro canyon iormation hosts perchedgroundwater over the Brushy Basin Member of the Morrison Formation atthe site.
The Entradaalavajo sandstones form one of the most pemreable aquifersin the region. This aquifer is separated from the Buno'canyon Formationby the combioed shales, and sandstones interbedded with significantshales, constihrting the Morrison and summerville Formations. Theuppennost unit in these formations is the Brushy Basin member, a silryshale in excess of 200 feet thick at the site. water in the EntradarNavajois und91 artesian pressure and is rsed at the Mill primarily for showering
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Geologic cross sections which ilhstrate the stratigraphic position of theEntradaAlavajo sandstone aquifer and intervening stmta'are shown onFigures 2.1,2.2, and 2.3. Even though cross-sections A-A' and B-B' in
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are represenrarive of the general stratigraphl in the immediare vicinitr ,_rt\\'\t'-:.
Dakota Sandstone and Burro Canyon Formation
The groundr!'ater occurrence within Dakota sandstone and Burro CanlonFormation in proximity' of the Mill site is in the form of a sin-ele perc-hed
groundwater zone. The -qroundwater is perched above the Brushy. Basinivlember of the Morrison Formation. w.hich consists of bcnronitic
mudstones and claystones. The saturated thickness of the percherl
groundwater zone varies from 5-i feet north of the site and thins ro less
than 5 feet to the south where it seeps into the adjacent can!,ons as
evidenced by springs and productive vegetation panems.
Downgradient of the Mill (i.e., between the lv{ill and dissecting canl.ons)
the groundwater in the perched zone cannot be used for irrigation or
domestic consumption because of the naflral poor qualiry of the water and
low yield rates of the perched zone. Documented purnping rates from on-
site wells completed in the Burro canyon Formation are less than 0._i
gallons per minute (gpm). Even at these low rares, the wells are typically
pumped dry within a couple of hours.
At the Mill site, the tailings disposal cells are sited within the unsarurared tDakota sandstone. tf cell leakage were to occur from the tailings cells.
tailings-related constiruents would have to migrate tfuough approximatelv
I l0 feet of unsaturated material before reaching the perched groundw.aterzone. This perched zone, while yielding insuffrcient water to be
considered a tsable resource, is the zone used by the Mill for groundwater
monitoring purposes.
The Dakota sandstone at the site is tvpically composed of moderatel-v- hardto hard sandstones with random discontinuors shale (claystone) and
siltstone layers. The sandstones {ue moderately well cemented (upper part
of formation) to well cemented with kaolinitic clays. The claystones and
siltstones are tlpically 2 to 3 feet thich although borings have encountered
a siltstone layer having a thickness of 8 feet, at 33 to 4l feet below the
groturd surface. The hydraulic conductivity values as determined from
packer tests range from 9.12E-04 centimeters per second (cm/sec) to 2.71
E-06 cm/sec, with a geometric mean of 3.898-05 cm/sec.
The composition of the Brushy Basin Member, which hosts the perched
groundwater beneath the site, is of variegated bentonitic mudstone and
siltstone. Hydraulic properties of this strarum determined from 12 single,
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well-pumping/recover.v- tesrs and tiom i0 packer tesrs. indicare rhe
hydraulic conductiv'itl' geometric mean to be l.0E-0-s cm sec.
confining units (including the Brushy Basin) and Aquitard
Properties
The Brushy Basin member of the fvlonison Formation is the first unit ofan aquitard wirh a total thickness of approximately 1.100 feet. isolatineperched water in the Burro cany'on Formation from the productir.!
EntradartJavajo sandstones. The elevation of the top of the Brushy Basin
is shown in Figure 2.-1. The Brushy Basin rv'fember, in contrast to the
overlying Dakota sandstone. is composed of bentonitic mudsrone and
claystone. During the initial site investigation, borings which terminated
in the Brushy Basin member encountered moderately plastic dark green ro
dark reddish-brown mudstones.
The next la,ver encountered is the westwater canyon member of the
Morrison Formation, which is composed of fine to coarse grained arkosic
sandstone interbedded with sandy shale and mudstone. The Recapture
member is the next layer encountered and it is typically composed of
interbedded fne to medium grained sandstone and silty and sandy
claystone. The fual layer of the Morrison Formation, the Salt wash
member is composed of fine-grained sandstone interbedded with
mudstone. The drillers log of ww-2 shown in Figure 2-5 shows a g0%
clay layer from 900 to 1,200 feet, which would be representative of the
Morrison Formation.
The final confining layer encountered, which lies directly above the
Entrada/tfavajo Aquifer, is the summerville Formation. The summerville
Formation is composed of sandstone interbedded with shale. The drillers
log for WW-2 reports this layer to be 50% clay.
E ntradaAlavaj o Sa ndstonc Aquifer
within and in proximity to the site, the Entrada/Navajo sandstones are
both prolific aquifers. Since the Mill site water well is screened in both
aquifers, they are, from a hydrogeologic standpoint, treated as a single
aquifer. The Entrada/f.lavajo sandstone is the first useable aquifer of
significance documented within the Mill area. This aquifer is present at
depths benveen 1,200 and 1,800 feet belowthe surface and is capable_of
delivering from 150 to 225 gpm (D'Appolonia 198 I ).
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The -eroundwater present w'ithin the Entrada;Navajo Sandstones is rhe tlrstusable aquifer of signiticance documented rvithin ih. ,r., of rhe \till. TheEntrada'Navajo sandstone aquifer (Entrada.,Nar.ajo Aquifer) is an anesi.rrraquifer and is used regionairy' tbr irrigation and domesric consumprion.
At the iv{ill site. the EnrradaNa'ajo Aquirer is separated from the perchedgroundwater zone (w'hich. again. is *ithin the Dakota Sandstone andBurro Canyon Formation) b.,- more than i.100 teet of unsaturared. lo*permeability formations. The combinarion of low permeability.. thickunsarurated strata and the.artesian pressure within the aquifer provlaes apositive natural ph,vsical and hydraulic barrier ttrat protecrs theEntrada,Navajo aquifer from being impacted by potential'tailings cellleakage.
As stated above, the combined thickness of the strata separating thisaquifer from water present in the Burro canyon Ftrmatio'n isapproximately 1,100 feet. This confining layer is competent enough tomaintain pressure of 900 feet of water, or 390 pounds per square inch-Gsi)within the Enrada.&.{avajo aquifer. water is p..i.nt under artesianpressure and is documented to rise about g00 to goo feet above the top ofEntrada.&'Iavajo sandstone in contact with the overlying sumrnerv,illeFormation. The static water level is about 400 to sbo -re.t below thesurface.
tYnl{;'t' t
The position of this aquifer and its hydraulic head versus other strata isshown in Figures 2.2 and 2.3. In-siru hydraulic pressure of groundwater inthe Entrada/l{avajo Aquifer is strong evidence oith. aquitar-d prop.ni., oithe overlying sedimentar,v section. Due to the presence oi significantartesian pressure in this aquifer, any futue hydraulic communication
benveen perched water in the Burro canyon Formation and theEntrada/l'Iavajo Aquifer is unlikely. In order foi consritucots to enser rhe--- aqldfcr, tho preeeaue.of the aquifer would beye to be excecded. Ttrerefore,
aquifer in the presence of artesian\- c.^. ,iro[ J^., ,. , o ,.)'i ,. ', o,,,-, J.. ,i' 1r+{ ru',-'* '\
migration of constituents into the
conditions is turlikely.Cr}l.l
;1 4'''\I Eighteen years of operation and monitori,g oi ,rr. ;.*ri.d"*;;;; ,Ln! ii
(located some 1,100 feet above the Entradarhavajo Aquifer) have givenno indication that the tailings cells in use at the mill were or aredischargrng tailings liquid to the perched zone. The likelihood of impact tothe Entrada/Navajo Aquifer, some 1,300 feet below the site, *lri.h i,
separated from the uilings impoundments by up to 1,100 feet of very lowpermeability shales, claystones, and mudstones, is extremely remote.
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:.: Well Construction Data
2.2.1 Well drillers los
The drillers log for ; , is attached as Figure 2.5. Well construction
and performance details for WW-2 and the other deep w'ells which are not
in use, are shovm in Table 2.1. WW-2 is cased from 0 t'eet (ft.) to 1.150 ft.
and is grouted to 100 feet w'ith concrete. The well log describes multiple
zones containing clay fractions, with one 300-ft. thick zone. in the inten'al
from 900 to 1,200 feet, containing 80 percent clay. This claye!'zone
immediatel y overl ies the Entradalrlavaj o aqui fer'
2.2.2 Elevation of wellhead
The wellhead elevation is 5,610 ft. (MSL)
2.2.3 Borehole diameter
The borehole diameter is l5 inches (in.)
2.2.4 Casing diameter
The casing diameter is 10 in.
2.2.5 Total depth of well
The total depth of the well is 1,885 ft. The well is cased from 0 ft. to
1,250 ft. The well is completed as an open hole from 1,250 ft. to 1,885 ft.
2.2.6 Depth and tength of the screened or perforated intervals.
There iue no screeffi or perforated intervds in the well. The well is
completed as an oPen hole bclow 1,250 ft-
2.2.7 Well scrcen or perforation type
No well screens were tsed in this well.
2.2.7 Casing tYPe
The casing is reported on the driller's log as new 250 gage'
2.2.9 Method of well construction
The driller's log reports the method of constnrction as rotary drilling.
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2.:.10 Type of pump
A submersible pump is installed in the w.etl.
2.2.1 I Location of pump in well
The pump is set at 1,000 ft.
2.2.12 Maximum projected pumping rate
No pump test was conducted at the time of well installation andcompletion. The well has been used at a ma.ximum pumping rare of ll-i
gpm.
Pump test results for four other wells completed in the same zone and
depth at the Mill, with similar completion, but which are not currently in
use, yielded the results presented in Table 2.2:
TABLE 2.2
PUMP TEST RESIILTS FOR FOI-rR WELLS COMPLETED
TN THE ENTRADAAIAVAJO AQUIFER AT WHITE MESA MILL
ww-l
ww-3
ww-4
ww-5
223
245
?38
t20
353
3r5
890
377
1.6
')
48
t.5
Therefore, it appears reasonable to expect, particularly based on the results
of the pump test on well ww-4, that well ww-2, completed in the same
Entrada/l'{avajo aquifer, could potentially srstain a yield on the order of 225
gpm.
2.3 Aquifer Data
2.3.1 Hydraulic Conductivity
A purnping test was performed in the Navajo/Entrada Aquifer in
September, 1980 by D'Appolonia consulting Engineers, tna. The
hydraulic conductivity was estimated at 4.24E+02 ftJyr, based on a multi
well drawdown test. The permeability assuming an aquifer thickness of
500 ft is 8.0 gaUday per square foot (D'Appolonia, February lggl).
l6
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2.3.4
I.r. >l
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Ilarch -i(J. :qoo
Transmissivity
Transmissiviry' is estimared at approximatel."- -1.000 gal day' per square tbot(D'Appolonia. February 198 I ).
Hydraulic gradient
The hydraulic gradient is not known. due to insufficient data for the area.
Direction of groundwater flow
The direction of groundwater flow in the deeper aquifers in the Blandine
Basin is related to the deeper stru*ures of the Branding Basin. onl
recharge area of the Enrrada and Navajo sandstones is along comb fudge
Monocline about 8 miles directly west of the site area. The ground*rt.,
movement in these units is described in the Environmental Report for thewhite Mesa Mill (Dames & Moore, 1978) as being thought to proceed
from the recharge area eastward and southeastward dowudip toward the
center of the Blanding basin, approximately 18 miles south-southeast of
the project. At present, there are no data to substantiate this hypothesis as
there are neither maps of potentiometric surfaces in the Navajo or Entradanor long-term records of water levels in the site vicinity for wells
penetrating the Navajo or Enrada.
Estimated effective porosity
The effective porosity is not known, due to insufficient &ta for the area
Satr"rated thickness of producing aquifer
Beneath the Mill site, the thickness of the combined Entradaalavajo
formations, from which water is drawn through open-hole completions, is
approximately 600 to 550 ft. At well tvw-2, the open lrolo,intorvatis6Bi
&.
Hydrogeologic Methods and Calculations
No hydrogeologic methods were wed to delineate the protection zones
becausc the hydrogeologic and geologic data suted above in Section 2.1.2
and below in Section 2.6, demonstrate that recharge to the Entrada/Navajo
Aquifer does not occur in the vicinity of rhe wellhead.
fl\p ot " "'"r'
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2.3.5
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2.4
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Map Shorving the Boundaries of rhe DWSP Zones
A DwsP zone is an area rvithin a certain time period (up to l-i years) ot
groundwater time of rravel ro the wellhead or margin of the collecrion
area, the boundary of the aquife(s) which supplies warer to thegroundwater source, or the groundwater divide, whichever is closer.
There are no DwsP zones at the site, because there are no surface orsubsurface areas surrounding the wel.l through which contaminants are
reasonably likely to move toward and reach the groundwater source.
The hydrogeologic data provided in his report verifu protected aquifer
conditions. A protected aquifer is an aquifer which is a producing aquiter
with a naturally protective layer of clay, at least 30 feet in thickness, above
the aquifer. Because the Entrada/|,Iavajo Aquifer can be classified as a
protected aquifer, no drinking water protections zones exist for ww-2.
As detailed below in Section 2.6, the hydrogeologic and stratigraphic
feattres which provide protected status to the EntradaAiavajo Aquifer
include multiple zones of very low permeability rock, including clay uniawell in excess of the 30-ft. thickness described in the Dwsp Standard
Report Format (october 1998); indeed, these clay zones iue iui much as
300 ft. thich in a confining unit that is approximately 1,100 feet thick. In
addition, although the presence of the protective features described in this
report, which provide assurance that no contaminants are reasonably likely
to move toward and/or reach the Entrada/|.lavajo aquifer, the location offMilf*&'ioftp*adioe*9, . These
factors combine to demonstrate thatfturrorurding &e groundwater source of drinking *at.t
Protected Aquifer C lassifi cation
The Eutrada/tlavajo Aquifer is a protected aquifer. A protected aquifer is
a producing aquifer wi& a naturally protective layer of clay, at least 30
feet in thickness above the aquifer. The Eotradaalavajo Aquifer is
protectcd by 1,200 feet of unsaturated, Iow-permeability rock. The
Bnshy Basin Member of the Morrison Formation is the first unit of the
aquitard isolating perched water in the Burro Curyon formation from the
Entrada/tlavajo Aquifer. The thickness of the Bnshy Basin Member
varies from 200-450 feet and is composed of bcntonitic mudstone and
claystone. The Bnshy Basin is located approximately 100 - 150 feer
below the gror.rnd surface and approximately 1,100 feet above the
Entrada./t lavaj o Aquifer.
_i- -1, .l I s*t,[
fa1t';o.JA flaa'")-'+
t t-;
'1, ,- o,l; - cD*" L*r't',,* "'^f,*lt :
J"f,,-'' \r\
r*' I ii
2.6
supplyrng the PWS,
l8
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The remaining la.vers of the lvlorrison Formation are composed of tine tocoarse grained sandstone interbedded w.ith sandy. shaies and mudstones.The drillers log of w'\\'-2 shown in Figure l-5 ihows a g0 percenr cla,layer from 900 to 1.200 feet. rvhich w.ould be representative of rheMorrison Formation.
response to a request b,r_ theu. s. Nuclear Reguratory comnfsiion (l\Rc) and the u. s
wl,+
rw|:
Ja l-Environmental Prorecrion_ Agency (EpA) to nrnrrer investigare thecompetence of the Brushy Basin rirember of the lVlonison formation and toprovide additional hydrogeologic data.
and the U. S.
I *\ioi.,ll'"nn
"\? €
Packer tests were conducted over zones within the Dakota, Burro canvonand Brushy Basin units. The cores and video surveys "; #ffii'#: #showed few closed, hairline fractures present in tho g,-o i;;; ;_Dakota Formation that do not substanriaily ,r..t tt. l'yil.ffi:conductivity of the formations.
At the Mill site, the Entrada/l.Iavajo Aquifer is separated from the perchedgroundwater zone by more than i,100 feei of unsatuated, rowpermeability formations. The combination of low penneability, thickunsaturated skata Td g" artesian pressurc within the aquifer priuiar, .positive natural physical and hydraulic barrier ttrat protects theEntrada/i.{avajo aquifer &om being impacted by potential'tailings cellleakage.
Eighteen years of operation and monitoring of the perched water zone,which is located I l0 feet below the site havi given no indication that thetailings cells in usc at the mill were or are discharging tailings liquid to theperched zone. The likelihood of impact to the aeep *aro.li.quif.r, so*.1,200 fcet below the sit-e, and sepaiated from thetailings irio*irn.nt,by up to [,100 feet .of very row permeability shares] chystones, andmudstones, is extremely remote.
l9
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t.i.0 rNl'ENTORy oF porENTrAL CONTAMTNATTON SOLRCES T.l' "' .,
!'
o _ There are no potential contamination sources within the four protection zones or theent[e management area.
Rechar-qe to the Entrada,Navajo Aquifer does not occur from infiltration from rhe
overl.'-ing strata. [nstead it occurs by infiltration of precipitation into the aquiferalong the flanks of the Abajo, Henry and La Sal Mountains and along the flanks offolds, such as Comb Ridge lvlonocline and the San Rafael Swell. where thepermeable formations are exposed at the surface. There are no potential
contamination sources located near these recharge areas.
The presence of low permeability, unsaturated strata between the Buno Can."-on
Formation and the EnEada.t',Iavajo Aquifer provides a positive natural physical
barrier that will Protect the quality of the Entrada.tlavajo Aquifer.
-artesian pressures in the EntradaAlavajo Aquifer indicate
from the facility to the aquifer is extremely remote.
This, combined with the
migration of constituents
O*\
J. PPt ro--
20
! .\ )i
R.a', , ,-j
\larch -it]. llc.l
.I.O ASSESSMENT OF POTENTLq,L CO}{TAIVINATION SOLR.CE TT{ZARDS
There are four types of hazard controls: R, L4 -, I here are tbur types o[ hazard controls: Regulatory, best managemenr'pollution
+ l'4- Prevention. ph;rsical, and negligible quantity controls. PWSs are not required to olanity controls. PWSs are not required to planr lr\*Lr*
/, \JD
and implement land management strategies for potential contamination sourcehazardsthatareassessedasadequatelycontrollea.. l ._ ,, .. euarterly monitorin,s ofthe perched water zone is conducted which is more ihan 1,100 feet above the
Entrada.triavajo Aquifer. The perched water zone is monitored for NRC point ofcompliance sampling parameters (nickel, potassium, chloride, and uranium). There
have \en no detections of releases. tf the tailings ponds or any other contamination
was erftering the subsurface environment, it would be first detected in the perched
water tone.
I
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2t
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5.0 TFIE MANAGEMENT PROGRAM FOR EXISTI}iG POTENTLA,L
CONTATVINATION S OURC E S
This section is intended to be a plan to be implemented by the PWS to control pCS
hazards. Since there are no existing potential contamination sources to manasew'ithin the rvellhead protection. no management program is required nor submined
herein.
22
:)',i j ?
Rer ...r-)
\larch -il). igqo
6.0 TI{E NIANAGEMENT PROGRA.IU FOR FUTURE POTENTIAL
CONTAMINATION SOURCES
Since the EntradatNavajo Aquifer is a protected aquifer, there are no future potential
contamination sources to manage within the wellhead protection.
23
-
l,,i s?
R'er t '''1
I[arch -]0. loqq
7.0 THE TMPLEMENTATION SCHEDULE
The implemenhtion schedule is a list of the land managemenr srrategies w.hich har e
been identified b.v the PWS for both existing and future PCSs with a beginning darefor each one. Since there are no PCSs, no land management strategies- need to beimplemented.
24
f,"i i?
Rer , ,.,
\larch i0. .,)qq
8.0 THE RESOLts.CE EVALUATION
No financial or other resources are needed to implemenr the DWSp plan.
25
l\i i:
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llarch i0. 199.)
9.0 THE RECORDKEEPTNG SECTION
Any changes to the DWSP Plan will be documenred.
26
f,'.i s3
R.* ..0
\larch i0. i999
IO.O CONTINGENCY PLAN
Contingency plans focus on the identification and possible solutions of problems
that may arise if the DWSP plan fails. Additionally, the contingency' plan
addresses problems PWSs need to solve in the event of water shortages or
contamination incidents that may impact their ability to supply safe drinking
water to the public.
The DWSP plan for the White Mesa Mill will not fail because the Entrada/1.{avajo
Aquifer is a protected aquifer and there are no PCSs. Water from WW-2 is not
used for drinking water and is used mainly for showering and toilet facilities.
The White Mesa Mill cunently supplies bonled water to be used as drinking
water.
Due to the size and capacity of the Entrada/l.Iavajo Aquifer it is highly unlikely
for a water shortage to occur. On the stight chancc the WW-2 became
contarninated, the well would be shut down and WW-4 or W'W-5 would be
utilized. W'W-4 and WW-5 are existing water supply sources that can be utilized
if needed. WW4 is located upgradient of WW-2 and WW-5 is located
dowugradient at a depth of 2,200 feet in the Wingate sandstone aquifer located
beneath the Navajo/Enftda Aquifer. Water can also bc tnrcked in from a potable
water source in Blanding, Utah if needed. A water fratment facility is tsed to
chlorinate the groundwater before it is ued. The drinking water is also sampled
in accordance with the State of Utah Rules for Public Drioking Water Systems.
27
REFERENCES
Dames and Moore, 1978. Environmental Report. \y'{hite Mesa Uranium Proiect.
San Juan Countv Utah. Prepared for Energy Fuels Nuctear, tnc., January.
D'Appolonia consulting Engineers, tnc., 1981, Letter Report, Assessment of the
Water Suoolv Svstem. \Mite Mesa Proiect. Btandino. Utah. erepareO for
Energy Fuels Nuclear, lnc., February.
D'Appolonia consulting Engineers, lnc., 1982. Letter Reoort - Groundwater
Monitorino Prooram - \rltrite Mesa Uranium Proiect. Blandinq. Utilt.
Energy Fuels Nuclear, lnc., 1997. Reclamation Plan Wtrite Mesa Mitl. Blandino. /
Utah, Februarv 1997.
Hydro-Engineering, 1991, Ground Water Hvdroloqv at the \Mite Mesa Tailinqs \./'
Facilitv. Prepared for Umetco Minerals Corporation, Blanding, Utah, July.
Titan Environmental Corporation, 1994. Hvdrooeolooic Evaluation of \Mite
Mesa Uranium Mill. Julv 1994.
Titan Environmental Corporation, 1994. Points of Comoliance, Wtrite Mesa
Uranium Mill. Seotember 1994.
Umetco Minerals Corporation, 1993, Ground Water Studv. \Mite Mesa Mill. t/./'
Blandino. Utah. License SUA 1358, Docket No.40€681, February.
IUSA Letter to
William J. Sinclair, UDEe
October 31, 1998
Irre Rrrrro\.{r
Unrxrurr (L;Si.
Conponrrros
OI ndependence Plaza. Suite g50 . 1050 Seventeenth Street r Denv'er. CO 30265 . 303 6!3 77gg (main r . :10.3 :lg9 { l!5 , fu
October 31, 1998
William J. Sinclair, Director
Division of Radiation Control
State of Utah Department of Environmental euality
168 North 1950 West
P.O. Box 144850
Salt Lake Ciry, UT 84114-4850
Dear Mr. Sinclair:
}:.li::::.tp"":d:'-,i_l?1 to your letter. to International uranium (usA) corporation (..IUSA,)of August 4, 1998, in which you request that rusA submit an applicatiication for a State groundwaterdischarge permit for the White Mesa Mill (the.,Mill").
In this letter, rusA,sserts that it is not required to obtain a Groundwater Discharge permit&ccarse:
[':j||,:t?1ff:1,:,1]f ]r:'h.,.y"er euatity .A:: ,: a united states Nucrear ReguratoryCommission ('NRC") Iicensed facility, such as the Mill, is pre-empted by Heral legislatiorl-assertion c'DoE")andrd; inanyeven!ry --(
therefore the Mill does not fallwithin the requirements of the Utah water Quality Aa. we also address your request for access tothe Mill for purposes of groundwater sampling.
FEDERAL PREEMPfiON
The requirements ofthe Utah Water Quality Act regarding groundwater discharge permits do notaPply to the Mll because they are preempted by feJeral liw. In addition, ttre apptication of Stategroundwater regulatiors would threaten to delay the closure of the Mill's tailings irnpoundments andpreclude or impede their transfer to DoE for perpetual care and custody.
The issue offederal preanption is addressed in detail in the NIvIA White p"p"q .T.ecommendations
for a Coordinated Approach to Regulating the Uranium Recovery Industrlfi pages sz-g6. Thefollowing summarizes r{Y !h. federal preemption argument applies to the state;s ruqu.rt that IUCobtain a groundwater discharge permit for non-radioactive-discharges from lfe.(21 byproductmaterial.
\TAEORSYSIUSERS\EGCIDAVRLETTERS\StEtr t.doc
Wiiliam J. Sinclair 'October i l, 1998
In the past, the State sought to require IUC to zubmit a -eroundwater discharge permit application fornon-radioactive discharges but not for radioactive discharges. The State re[ed on section Z7a$) ofthe Atomic Energy Act (the "AEA") and cases construing-this section for its assertion ofjurisdictionover non-radioactive discharges from I le.(2) materials.t Section 274(k) provides:
Nothing in this section shall be construed to affea the authority of any
state or local agency to regulate activities for purposes other than
protection against radiation hazards.
42 U.S.C. $ 2021(k). Several cases have construed this section in the context of federal versus stareauthority over 1le.(2) material, but none has addressed the issue of whether a state may assertjurisdiction over non-radioactive dischar-ses to groundwater. Moreover, the line of cases ihat theState appears to have relied upon in the past to support its assertion ofjurisdiction is equivocal onthe issue of preemption. Indeed, more recent case law suggests that a fundamental premiseunderlfng that earlier line of cases was incorrect. When one looks at the relevant statuies andIegtslative history it is plain that state regulation of I le.(2) blproduct material is preempted by federalIaw. This is true for all components of l le.(2) mati;al wherever they appear - including
components found in groundwater. Thus, it is IUSA's position that state regulatiomof *y A*forgu]of l le'(2) blproduct material, radioactive or non-raditactive, is precmpti Uy the AEA.
The line of cases the State has relied upon to support its assertion of jurisdiction arises from theplanned disposal of I le.(2) material at the Ken-Mtbee Chemical Corporation's Rare Eanh Facility,located partly within the corporate timits of the City of West Chicaio. There are three pertineniqrses:
r Illinois v. Kerr-McGee Chern. Corp,677 E2d 571 (76 Cir.
regulate public nuisances unrelated to the NRC-regulated
to the legislative history of section 27a$):
1982), addresses whether the City can
tailings impoundment. The court cited
It is not intended to leave any room for the exercise of dual or
concurrent jurisdiction by states to control radiation hazards by
regulating byproduct, source, or special nuclear materials. The intJnt
I For cxample, thc Stetcnrent of Basis for Envirocstr's groundweta dischargc pcrmit inctudcs thc following strtsmcnt
Bccausc drc ShE hrs not rcccivcd dctcgrtion of authority for I lc.(2) wrstc from trc NRC, Uteh hrs no direct authority ovctthc ndlxctivc eontrminants in t lc.(2) wrste mstcrids.-Howcvcr, i.d.ol .orrt dccisbns havc dtourcd the st{cll to rcgulatctttc aga-Edbbgic portim of I lc{2) mercrials. so long as s.rci rcgulation ds not frusrarc rhc undcrlying purposc ofth fuJlcgislation.
Similarly, drc SbE hrs rsscrlcd in thc Privetc Fuct Storrgc licanring mattet rhat thc NRC's authority urd€r thc AEA docc not p*qrnpt
:tllc lEgulstbn of grurndrrntcr.citing to 42 u.s.c. S 20-21(L),K.n-Mcc* crron. com. , citr r sri rli ilolFli,1990), urd P".lIi" G"s & Et ctic ,. Encr"', Rc.orno Cormi t manrorium law hcld notto-!'e-efoq!@ by trc AEA bccrur (atcs rctrin *,"it trt mtu o rrguhtc thc ccononric rspcts of clccric gcnenticr). Scc In thc Mrttcrqf Priratc Fqcl Stonrc. LLC, NRC Dockct No. 72'22-IsFsL "statJof Utah'r contcntions on thc consriction 'rd opcrating LicmrApplication by Privarc Fucl stongc, LLC for an Indcpcndcnt Spcnt Fuel Stongc Facility."
\TA8OR\SYS\I'SER,S\DGC\DAVRLETTERS\SLEK I.dOC
William I. Sinclair -J-October 3 l, 1998
is to have the material regulated and licensed either by the
Commission, or by the state and local governments, but not by both.
&E coua"efo o'reee@noA*ena*noryeoa@mefur&{r,auttreefrU*qrrylhe,nnormdisi*
- the City has the authority to regulate dangerous conditions
constituting a public nuisance, such as open pits eUia wittr refuse andchemicals in a factory area and insufficient fencing and lightin!; and
_ * the City has the authority to require Kerr-McGee to clean upofsite contaminarion.
' In Brown v. Kerr-McGee Chem. Corp. ,767 F 2d 1234,124 Cir. l9g5), the court held that theAEA preempted a request for a state-law injunction to move non-radioactive wastes to anotherlocation when the non-radioactive and radioactive wastes were intermixed and inseparable. Thecourt's rationale was that a state injunction requiring Ken-McGee to remove the byproductmaterial would restrict NRC's authority to regulate thi ndiologicd h;Js associated with thematerial.
o [n ren-l,tccee cneq corp. r gl4F.zdg2o (7'h cir, 1990), the courtheld that the AEA did not preemPt a city ordinance concerning erosion and sedimentationrequirements because the requirements did not conflict with l.iRglegut",ion..
sections 27 @) and 27aft)
feaerat sovernmen, T,l ll;material and states retaining a,thority overrhe ,.non-radiological,' *p*tr."iBi*fdidd*rf t te.(zi.
.111.::li","tI,:Pg,cal and non-radiological components lor ju;taioion"ffisesirirrir
J":'h "r,itrtil
r When Congress enacted IIMTRCA in 1978 it created a new class ofAEA-regulated muerial. This new class of material - I I e.(2) blproduct material - was (and runains)unique under the AEA because it was expressly defined uy congr.tr tolnru de alt waste -encompassing all radiological and non-radiological components - prodr.ed as a result of uraniumercraction operations. This fitndamental aspect of t t..1zj blprodua material, which was emphasizedin the legislative history ofIJMTRCA2, cannot be ignored byartificially Ariang pe.(2) material into"radiological" and "non-radiotogical" aspeds for furposer of .pportioningiriuaiaion between thestates and the federal government.
2 Sec, e'9" 124 Cong. R*,.29,776 (daily ed. Scpt 18, 1978) (statement of Scn. Dornenici). SenatorDomcniciexplained:
A basic principlc of thc amendment is thc crcation of a unificd rcgimc formi[ tailings so that variors distinct marcrials rvhich makc ry o,iiifi rifftailings pile nccd not bc subject to fragmcntd duplicativc *a poti i.ffyconllicting rcgulatory activities by differcnt Government agancics.
\TAAOR\SYS\I SERSIDcC\DAALETTERS\Sinctrr.doc
l\',
u-,l-
William J. Sinclair October 31, 1998
3 Copics of thc circuit court and district court opinions are attached as Attachmentsl and 2.
4 District court opinion at 12.s , 496 U.S.. 72.78-19(1990)
6 tlR Rcp. No. 95-t4t0, Prt I !t 12 (1978) (cmphrsis addcd). Thc tcgishrivc hisrry is rcplctc wih stetcrncag indi:ering rhlt CongrcsintcndcdtocEateauniformrutionalqruanrofrcgulationtbrlle.(2)mucrial. sccId.parttrat45;HcaringonH&l33g2,ILRl2g3g,HR' 12535' ud ttR 130a9 Bcforc thc Subcomm. orr Energy and thc Environment of rhc Housc Corr. o;, tncriaand InsrhrAlBirs,95e Cong. 95-30 u 130 (t97t[sbrancnt of Joscptr tU. rcii;c. CtrlrmanJ.
\TABOR\SYS\USER.S\DGCIDAVRLETTER.IilSinc|r t. doc
4-
The fallacy of attempting to divide jurisdiction over I le.(2) material along radiological versus non-radiological lines was driven home recently by the U.S. Court of Appeals fir the Ninth Circuit, in thecase of Waste Action Project v. Dawn Mining Corp . I37 F.3d i)a p" Cir. l99g)., In thai case,the Ninth Circuit Court ruled that the EPA lacked authority to r.gri.t. the discharge of I le.(2)byproduct material under the Clean Water Act, because I le.(2j byproduct material is not a"pollutant" for purposes ofthat Act. Since Utah's groundwater programis independent of the Cleanwater Aa and is not an EPA delegatd prograrn" the courr's primaraholding in waste Action projea
is not direaly applicable to Utah's ass€rtion of regulatory authority. The mor. p.n-*nt urpilfthe Waste Action Project case is the distria court's recognition thai the radiologi'cal componlnts ofI le.(2) blprodua materid cannot be segegated from the non-radiological components foi purposesof asserting regulatoryjurisdiction. Specifically, the plaintiffin the caie had alleged that dischargesof certain non-radiological constituents from a uranium mill tailings facility 1e.g., silicq heavy metils,zulfates, phosphates, chlorides and other chemicals) required an NPDEi p.*it The district courr
disagreed, noting that uranium mill tailings " are regutated solely by the I.;RC pur*ant to the AEA
as amended by UMTRCA.'d Accordingly, the distria coun rejecteA tne plaintiffs assertion that thenon-radiological discharges were subject to the clean water Acr.
Finally, the courts have made clear that in circumstances where the operation of state law wouldft:str1e the purposes and objectives of Congress, or where state law and federal law conflict, state
l-aw will be preempted.' Congress, when fu enacted LJMTRCA created a coordinated federal ,Lgir.for the comprehensive regulation of I le.(2) byproduct material. Under this regime, three fejeral
agencies share responsibility for regulating all aspects of I le.(2) material. It is evident from thelegislative history, and from the statute itselfi that Congress' purpose in creating this comprehensiveand pervasive federal scheme of regulation was twofold: n6t, Congress wLted to ensure thaturanium mill tailings (and I le.(2) byproduct material generally) would be regutated according touniform national standards. Thus, as Congress explained when it enacted UltfnCe:
without the authorities included in H.R. 13650 [which would
eventually be enacted into law as UMTRCA], the conditions
addressed by the remedial program would be left without
remedy, otd the authority of the commission to establish
uniform national standards for waste disposal from uranium
millswould not be clear.6
Congress' second PurPose in enacting uI\,{TRCA was to ensure that uranium mill tailings would be
o
William J. Sinclair October 31, 1998
Xl*:l,_I:tlf oe. and controlled in a_safe, timely, and environmentally sound manner., State
:*.i:l?.:fj::-::T:y:,*,ponents or ue (2) bfproduct ,.;.;.i ili,G;;;;;.,; ,;
::.1?:,bltJ".d:" material components in groundwater, undermines the qyo;;f rrd;;"il";r ii,lJv,ffi;;;;ffiffi;;li#Fo'o-r t^- ^-J :- -ll:^:- ^ .t5r tr5s rntenqes ro creare unoer uM I KCA. similarly, by imposidifferent frorn, and in addition to, those imposed by NRC, state reguration of r I.r. sssr,vrr L.,, Lrurtr rrrpusris Dy r\t(L, $ate regulatton of I le.(2) byproductmaterial in groundwater threatens to delay the closuie of tailings ri,.-r -J irp.a" tr,ei, transfer toDOE for long term custody. This is a very important point for both IUSA and the State. Underu L..v VLslW. Vllut a
mc}.jll._Yly,1_o:^,1T*'ed to DoE:'t1.. st19 ro1 p.'p.,u.r;;" ;r"*ever, it is tiketythat DoE will not take long term care and custody of the Mill siti ifihe site is also subisubjea to a Statepermits
-5-
The conflict created by the State's assertion of authority to regulate I le.(2) byproduct material ingroundwater is evident here, in Utah's .Pn to require . ground*ater discharge permit. The NRCregulates both radioactive and non-radioactive disctrarg;s to groundw;i NRC has definedbyproduct material to include all wastes--{oth radioactivl and nJn-radioactive-produced from themilling process. 57 Fed.Reg. 20,525, 20,525 (lgg2). The State and NRC have both acknowledgedthe potential conflicts if both the State and NRC iegulate groundwater discharges from the IUCtailings impoundment. For example, the.state acknoiledg.i in its letter dated August 2g,1996 tofUC's predecessor (Attachment 4) as follows:
upon our earlier reviewofyour proposar for compriance monitoringto be done under your NRC licensg we concluded' thar the proposed
monitoring program wgul-d be adequate for compliance ronitoring;under a groundwater discharge permit. Howevir, in the event thatcompliance monitoring reveated a release of contaminants from thetailings cells, there would be discrepancies between state and NRCregulatory programs. These include differences in which bodies ofunderground wuer are protectd, which parameters are regulated, andcleanup procedures and standards.
7 Sce. c.r..42 U.S. C. ! 790t(r).
t For cxamplc' un&r thc rccarts complacd Lic.nsc Tcrminaiion/Sitc Trensfcr Prorocol bct\rrccn DoE and NRC (Athdrmcnt 3I DoEwilt not t& titlc o a triting! ditPocd ria' ena I{Rc will not tqminatc rh. ri..n.. for r sirc, if thqc are any ou6hnding ..isucr- withr6Pcct !o ttlts rcguhbr arthoriti6' simihdy, in situltionr wherc trcrc ir cven a pocsibirity thrt. i. Jgirt,*t to impoc rdditionelrctncdi'tion tEquitcmcntr on op of thosc rcquircd ry-yRc. ooe right ioi compcllcd nor to .ccEpt titlc, sincc to do to r*rld bcfurqrsi*crrt wih rtr strtrrory dirrtivc in AEA sccrion E3 that srch tnru-fcrs a mE_.r" ,o bc aecnlbhcd .. m cd b lhc g*rrncrtrhis rsluctarrcc on thc prrr ofDoE would likcly bc compoundcd by rhc conccms nisod by thc FedcJ ro-iri,io, co.pliancc Acl whichrcquire th.t lidc'"l frilitia cornply wilh rll ittt t quir.t.ntt i"opo,iil-ric conrd rnd rbetcmcnr of rcrid *nns ditposrr .,,dmarugarant " 42 U.S.C. I 59(il(a).
9 UMTRCA rcquired EPA to promulgetc cnvimnmcnul stendrrds for rrdblogicat urd mnndiologi:rl 6rzr& ,,reirtd wift byprcd*tmrtcrial' 42 u's'c' ! 2022(b)' EPA promulgated such standards. whict inctudc gmund*rrcr protccrion ,r.,,d&dr. 40 c-F-R-$ 19032(aX2)' thc NRc (or rgrecnrnt strtcl is chaaca wirh thc r*rdulif oi -6crnarting md cnfordng ttrc shdar& 42 us.c.$ 2022(d).
\TAEORISYS\USERS\E GCIDATE1LETTERS\Sinc| I.doc
Williarn J. Sinclair October 31, 1998
A letter dated December 13, 1996 from the NRC to the Stare (Attachment 5) also acknowledges rhedifferences between the State groundwater discharge program and the hlRC program.
In summary, utah's efforts to regulate I le.(2) byproduct material in groundwater threatens to
::f:=:.-*_::::l^:l-:.1tu:, nati1nar r1?"*,9; established under rnrrnc,r.' and to impedetailings impoundment closure and transfer to the federal government. In additioru the iimposition of:':::,'1"::i::l',:::9*:Yl:1::jtT,::qi.'i*itnea.;;.d;;;;c#*effi ;:
:,T,**:T:Il.:.:jpreemption established by the supreme court, utah's d;;;" "f d;.,.;authoriry is preempted.
2. TEE WEITE MESA MILL DOES NOT EAVE TEE POTENTTAL TO DISCEARGE TOWATERS OF TEE STATE AND EENCE DOES NOT FALL WITEIN TEEREQUIREMENTS OF TEE UTAE IVATER QUALITY ACT.
2.1 Statutory Provisions
I
^{
The statutory authorityfor the State to promulgate the groundwater discharge regulations is the utahWater Qudity Act, which provides that:
it is unlaurful for any person to discharge a pollutant into waters of the stateor to cause pollution which constitutes a menace to public health andwelfare, or is harffil to wildlife, fish or aquatic life, or impairs domestic,agricultural, industrial, recreational, or othei beneficial uses of wa,.r, or,oplace or cause to- be placed any wastes in a location where there is probable
cause to believe it will cause pollution,
unless authorized under the Act or regulations. utah code furn. Section lg-5-107(1). ..waters ofthe State":
mearN all streams, lakes, ponds...and all other bodies or accumutations ofwater, surfaceand underground" natural or artificiat, public or private, which are contained withiq flowthrougfi or border upon the state or any ponion ofthe state; and
does not include bodies of water confined to and retained within the limits of privateproperty, and which do ryt develop into or constitute a nuisance, a public health hazard,or a menace to fish or wildlife.
a)
b)
Utah Code Ann. Section l9-5-102(lg).
rusA is not required to obtain a groundwater discharge permit, for the following reasons:
i'a) . ruSA and its predecessors have conductedgrolndwater monitoring at the Mill for a number of years, and there is no evidence that thetailings impoundments are impacting groundwater. The oristing groundwater data
O\','
\\TABOR\SYS:\LSERI|\EIGODAVBLETTERS\Sinck t.doc
:
.'\
/
't i
William J. Sinclair
activities at the Mill will result in such a discharge.
2.2 Data Demonstrate No Discharge to Groundwater
-7-October 31, 1998
demonstrate that the Mill will have, at most, a.i., nirrimr,rs potential effect on groundwaterquality, so IUSA should be entitled to a permit by rule. See UeC zu l7-6-6.2.A.1 and 25.
. The State requires a groundwater
::i::.Tj.: TT: p.' l:llti es_ which a i r. i,.,g. o, *our o ;," b.t r; ;ff;' in I iir.r,arge ofrrJvrr(u 59 utpollutants that may move directly or indireitly into groundwater. There have been nodischarges to groundwater from the Mil, nor is tt.rJ p.u.bre cause to beriieve that the
/1
iData on groundwater quality and occurrence at the Mill have been collected from up to 23 wettsdrilled since 1979.
The Mll's Point of Compliance ("PoC") proposal, which has been accepted by NRC as the basis forthe Mill's ongoing detection monitoring progranL was developed based on a ,eeratuation (the"Hydrogeologic Evaluation") of all of thi lxisting groundwater data reviewed as of the Spring of1995, and incorporated NRC's comments from -a -meeting of August I l, 1994, and site visit ofseptember 20, 1r,4. The proposal package included copies'of two EpAguidance documents whictq '
in addition to NRC guidance, t".i. ,rcd to devetop tt, ,nonitoring LJ ,Ltistical approachespresented in the pOC proposal.
The purpose of groundwater monitoring is to provide timely detection of potential releases to thelll"fl: f::r; $:tftojt usab.le aeflr u91eath the Mill is the Eniradaaravajo sandsone.
IT ?111,.11. 1r.T:*,111! .og'oximately.l,2o0 ree;.bou. the aquireq ., i.oinr'Jr!ii]'i'i1.syur! ur 7r tu l.ttfeet below land surface, and hosts small volumes of poor-qrality perched water. The poC
T:l:":J:Ijf_tTl91i the perched groundwaier zone of the Buno canyon Formation.,s.rvtr r-t.,r la&tltgll.
3:]}: ll^dtj:"tn y3nilorins, the perched lroundwater zone provides the earliest horizon fordetection oftailings cell leakage relative to the Entradaalavayo aquifer.ft. j
* g*:,*-:9_cf"q"*l and in section. 1.3 of the Hydrogeorogic Evaluatioq this:lf T: 1 *:ltylr_r :: * :f wat er encou nt ered b eneath,h.,fi ; A;;il ;;; r"# Mi; #'"t;; #5-*r. Arthough the
' ::T*1^,:1iffi:::gi:i ^yte' to
.
b e an .a;uirer;, r,r' ;; k,ffi d,,ffi #ffi?"1,;;vY, e.rrI ggfgr,atull
:j}t^":tlll ftf::,I"m the tailings disposal cetts at ihe Miu. Indeed, ury rete"se detected in
iHff",*^"I*::*i'y^T#j,f-::f*,ed frgm ir," i*..a.^,"G&;ii, uy approximatery1,200 feet of very low-permeability, bentonitic mudstones and claystonis.
, '^;
l.l nr,( "'
Downgradient of the Mill, (i.e., between the Mill and dissecting canyons), the groundwater in theperched zone catrnot be used for irrigation or domestic consumption uecause of the natural poorqualrty of the water and tow leld rates. Documented pumping rates from monitoring wellscompleted in the Burro canyon Formation are less than 0.5 gallons per rninute (gpm); even at thislow rate, the wells are tlpically pumped dry in . p*oJ oiminutes to tess than two hours.
\TAEORISYS\I SOO**nmLETTERS\SirEtrl.doc
William J. Sinclair -8-October 31, 1998
to"" YuttheMill sitg the, !i', )nt r0o At the Mill site the tailings cells are located within the unsaturated Dakota Sandstone, which overties
ho\ )",gJ)\,r,- the B.urro 6anY!1-Formation. If teakage were to occur from the tailings cells, tailings-related
-'iubefore reaching the perched groundwater zone.
The findings ofthe Hydrogeologic Evaluation were that the tailings located in the odsting disposal
cells are not impacting groundwater at the site. In addition, it did nor appear that future irp".tt to
groundwater would be expeaed as a result of continuing operations. These conclusions weie based
on chemical and hydrologic data which showed that:
L./- r'oo'
6hrt''c
fteHtlofperchedgroundwaterencounteredbelowthesite*hL
concentrationsoGIlsinconcentrationsofconstituentsthatwouldindicate-
seepage from the existing disposal cells;
The usable aquifer at the site is separated from the facility by approximately 1,200 feet of
unsaturated, low-permeability rock;
The uc*lcq$ifuie€oe.ffiGehfr.,p!ffirc and, therefore, has an upward pressure
gradient which would inhibit downward migration of constituents into the aquifer; and
d) At the time of the analysis in 1994 the facility had operated for a period of 15 years and had
caused no impacts to groundwater during this period. - -hi oL..-i a/\D r c. :i r I,c.a!.vu .. :,
Continued POC monitoring at the site is performed to verify that past, current and future operations
will not impact groundwater.
2.3 No probable cause to betieve the White Mcsa Mill will discharge poflutants to
groundwrter
During the last two monthq a tGam of licerued professional engineers from Knight Piesold performed
an independent review of cell constnrction for cells l, 2 and 3, as well as an updated analysis of
performance ofthose cells. Ccll4 was not reviewed in detail by Knight Piesold, lecause it iinot in
use. A thorough arduation of that cell wilt be completed prior to itJ being put into use.
With respect to the construction ofthose celts currently in use, Knight pi6sold found that:
Cells l, 2 and 3 were designed and constructed with emphasis
on containment of liquid. TheCfEl*rCeach component
ofthe cell structures and lining systems%
a)
*---v
b)
c)
,,lh.li5the cclls were constructd. There are no dcfeas
evident in the records of design or constructio[ as addenced by
both [Knight Pi6sold's] review and the inspections made by the
\TABORISYS\USEnSDcC\DAttSUlrfE**imtrl.doc
William J. Sinclair October 31, 1998
- L.\.-.*-lr- for any.claim that design or construction of the cells was in any_ ^ l;'(:," waysubstandard.
)'^' jrY' ^ 7' '"|'
1l ^ ^Art ^ ",1, Knight Piisold also reviewed the performince of the Leak Deteaion System (,,LDs-), and concluded1L'^.- ,u \ ,^ ir that there are "no indications that tailincs cells are dicnhar'i,r, roitinoo t:^.,:J +^ ^irl^-.L- ' hd - ^,++"i- r'"tr L*r,that there are "no indications that tailings cells are discharging tailings liquid io eitier the LDS or rheAJy " u_.Vunderlying formation,,
Following the review of cell construction, Knight Pidsold conducted a detailed review of the loerformanec nftha nallc inalrr.lino -^.loli-a ^f ^^tt t .FL- ^-tr . r i. vL |t'w ,Po:,..v- .vrrvw vl faav
f*,fiT,""f*Sl}:,hduding modeling of T_l]1. ft. cell3 modeting rezutts were extrapo tatedlto cells I and 2. The following is a summary of Knight pidsold,s concluiions:
rl(tt"!
-9-
*
Since the cells were constructed in the early 80's there has been no indications that tailingcells were or are discharging tailings liquid to either the LDS or the underlying formation;
Water observed in the cdlzLDS sump has been thorougtrly analyad @
a)
b)
j, r'
.t t..
tt li
-{*u i
1Utcr"
c) Recent modifications to the operating permit are based on sound engineering principles andare more likely to detect leakage through a damaged liner than consideration of chemicalanalysis alone;
d) Modeling ofprmrhlly occurring er during theperiod benveen January I983 and October l99gOtl*eflflFir This rate is considere d "de minimd urd inherent for pVC linen by the EpA -/,"kBased on our modeling, the total volumaric flux since beginning of cell use would rcpre*nt 1^ Loiqu,Q,'. ''?j.,f
:I1_1 po.,:* of the specific retention (i.e., permanent pore storage) in the underllng
U*+ |.q t, '' *^.'j ' t sandstone. Ilence, 96 percent of the permanent pore storage would be available for firLrir,,,* a ''r *' {}r6-lrloisture, if any, of which may migrate below the celt's liner.Q,'" f t ,- -'
- t ,rt p^ r 'r;-lar-' - -- --- -' -- -'J l
( y 6 1r' - I (a
-.-'
-<,e)CessationofthedischargeofarryliquidsuponterminationofceIIoperuinglifeand.^ { l,- "' ,'ry, t
^: .__, : ,e !o.ub reclamation oftailings will resrlt in the gradually diminishing rate of volumetric flu during
, .i i r .,r' r r r" the post-operation period.
0 lfthe status quo were to continue, the volumetric flux through the Cell 3 liner, based on ourmodeling might require at least 400 yers after closure to fill the remaining sandstone pores
such that unsaturated flow downward toward the perched water zone could commence.
\TAEORISY$I SER$DGCIDAVEILETTERS\SiEIrI.de
William J. Sinclair -10-October 31, 1998
trgr) e''e
h) Dissolved metals in tailings water are unlikely to be transported tkough the I lo-ft vadosezone due to significant attenuation from a number of potential pror.rr.r-documented to existwhen moisture moves at a very slow rate throlgf'1-a,,yery low permeability media. Theseprocesses include a combination of microfiltratid{ tfuotgh the pvc liner, .en*&-Llgiri-yparticles, cation exchangg horizontal and vertical disperiion due to heterogeneities of rock, kand oxidation-reductiqn processes. ::,,t ". *...7? :r :lr,rrr, r-a- [dr^o{-{ (1,fa,,. ., . .i,
& j
D Since Cells Nos. I and 2 are smalter and the hydraulic heads of liquids present in thosecells are also lower, estimated flux rates from-Cells I and 2 wifl b; ,orr.rponJingly lowerthan those which may occur for Cell 3.
Conclusion
lrr _'l) \1,' '
2.4
As is evidenced by rhe volumes of groundwater data provided to the State of Utah Division of3Y::,:::::jgi:l:f^ly!1:{its predecessor licensees at the Mn, and reinforced by af:::flit?._r*"t regstered professional Lngineers, there is absotutety no;"ti""* il*il ffiH:::t:ll*,",91t:!tl" ofpollutantt to grou-ndwater, nor that there is p-u.ut. cause to believe t3:j:TY1,:ljT!*i. poltutants to theLters of the s,"..ii. gr*#;;;fi;ffi;:Mill are monitored closely under NRC regulations. \_ t t,," ,..t'
ACCESS TO TEE WEITE MESA MILL TO CONDUCT GROT'hIDWATER SAIVIPLING
The DRC has asked that it have access to the Mill to conduct groundwater sampting. In a letter toDianne Melson dated oaober 30, 1998, IUSA indicated that it-encourg., or"ussion benveen DRCand IUSA on a broad range ofmatterq includingthis request. rusA toJks forward to disanssing thisissue with DRC in due courset as part of its broader discissions with DRC. iorr.*r, we would tiketo take this oppornrnity to briefly state a few points on this particular request.
fu the DRC is a$'arg all groundwater data collected for th_e Mill monitoring program are publiclyavailable; and" to facilitate DRC's access to these data, IUSA and its ;;;;*r ficensees haveroutinely provided cgnies-9fryrorts containing groundwater data to the tiiuirion. In additioq withinthe past few ycarx the Mll licensee providedilie state with tt" opponuJty to sampte IUSA,s deepwells, which are completed in the Entrada./1.{avajo sandstone, the'rcgioJ"qrifo, at the sarne timethat the state sampled the welts in the same .quif.r, located at the riNt. prela ute community. Itis our understanding that the results ofthis partianlar sampling event inaicatJlnat the operation ofthe Mill has had no effect on water quality in the regionataquifer.
Al{'9ugr'ru,sA is pleased to provi'l-e the state with access to our groundwater monitoring dat4which are collected under the terms of a detailed-sampling progranL and include sampling procedures,gualltr controuqudity assurance, and data quality ou;Jtires, we would need to know more aboutthe state's proposed sampling progfim before r"i.orr.nton the appropriateness ofthe proposedsampling. As explained in the State,s brief request, the objecr:ves sgthjprip"*a additional sampling
\TASORTSYS\I SERS\EG0DAVAETTERS\SiIE|rI.dc
William J. Sinclair
DCF/tay
Enclosures
cc (dencls.):
October 31, 1998
Yours truly,
Vice President and General Counsel
-l l-
are not clear- Although the State indicates that-the purposes of this additional groundwater samplingwould be "to ensure that alternate feed materials have not resulted in an enviroimental impact to .1,.groundwater and to gather data to be used in formulation of a groundwater discharge permit for thewhite Mesa facility", rusA believes that our existing database-ampty aemonsirates that operationsat the Mill, including alternate feed processing, haveiesulted in no impact to groundwater. Indeed,the construction of our tailings celts, coupled with site hydrogeologic inditions, and otherconsiderations consistent with lo cFR P* 40, Appendix d combini to ripport the posiiion that ouroperations are extremely protective of groundwiter, and that the sit. ios.t virnrally no risk togroundwater resources in the area In additiorq the existing monitoring prog* has been daerminedby the NRC to be adequate to detect any potential reteasJs to groundwater, should they occur.
In view of these considerations, IUSA would ask that the State please provide a more detaileddescription of the proposed data quality objectives, sampling and .natysis plan, and qualitycontroUquality assurance measures associated with the proposeaLmpling progr.rr,, to enable us tofully evaluate your request.
4. St Mtr{ARY
In sumrnary, ruSA would be pleased to meet with UDEQ to discuss the remaining issues raised inyour letter of August 4, as well as a possible means of providing t DEe with any data that mayfurther confirm that the cells at the Milldo not discharge io groundwater. Howwer, forthe reasonscited above we feel it is not appropriate for IUSA to .plty foi a Utah groundwater dischargu p..*i .
Dianne Melsorq Executive Directoq IJDEe
Don Ostleq Director, tIDEe Division ofWater eualityJoseph Holonictu Chiefi, NRC Uranium Recovery Uranch
Jim Parh NRC Uranium Recovery Branch
Richard Bangart, NRC Office of State programs
Charles llackney, NRC Region tV
Fred Nelson" Utah Attorney Generals Office
David Bird, Parsons, Behle, and Latimer
Tony Thompsorl Shaw, pittmarl potts, and Trowbridge
avid C. Frydenlund
\TABORSY$I SERIilEGGDAELETTERIiSi,E| l.doc
IUSA Letter to
Don Ostler, UDEQ
March 19, I ggg
Isrrn.r.ruo\ AL
Ururxrulr (USA)
ConroneuoN
Independence Plaza, suite g50 r l0s0 seventeenth street . Denver. co g0265 .303 628 TT9g lmainr . 303;169 {t!5 tir_r
March 19, 1999
Via Facsimile: 801-533-4097
Vin Federal Exoress
Don Ostler, Director, Division of Water eualityState of Utah
Department of Environmental euality
168 North 1950 West
P.O. Box 144850
Salt Lake City, UT 841l4-4850
Re: White Mesa Mill
Dear Mr. Ostler:
we appreciate the opportunity to meet with you and other members of the Utah Department ofEnvironmental Quality ("tIDEQ") on March 12, lggg, to discuss the potenii"t appii."bllily ;ithe State of Utah Groundwater Discharge Permit q'dwDp"; requirements to ruSA,s WhiteMesa Mill (the *Mill").
As we stated at the meeting, protection of the environment and public heatth is, has been andalways will be of paramount importance to IUSA in operating thc Mill. it. ttriti is suuleci to acomprehe.nsive regrrlatory regime administered by the United States Nuclear RegutatoryCommission ("NRC")' which includes monitoring and other measures to protect groundwater.we believe that these regulations are as protectiveif the environment, including groundwater, asany State regulations. Indeed, the URC regulations incorporate Environmental protection
Agency ('EPA") Resource Conservation Recovery Act ("RCRA') hazardous waste controlrequirements to address the non-radioto gicalthazaidous constitr.nti in uranium mill taii;;;;which is why RCRA permits are not required for this facility. Furthermore, continuous datacollected on groundwater quality at the Mill over the last 20 yearssupport this belief since theMill began operations in 1979, there have been no discharges to groundwater from the Mill,,norjs.there any data to suggest that there is probable causc to b"liuru thst the aoivities at the Millwil[ resnlt in such adischarge in the futuri. - r-u.
^
ty ,- r, ,,r I- [, ,," - ;,
- :,--
5r -i..' 1i. . .. l{,,. :,As you are aware, ruSA believes that the application ortr," ut"rr Wi ., ar"lity Act to an NRClicensed facility, such-as the Mill, is preempted by federal legislatioq ind assertion of Stateintervention could wetl result in the tinited States Department of Energy (*DoE-) not taking
!.t)bs
\lr. Don Ostler
IUarch 19. 1999
Pa*ee 2 of 3
long-term care and custody of the Mill. For this reason, IUSA believes that it is not required to
obtain a GWDP. Irrespective of this fact, IUSA believes that it also would not be required to rt11
obtain a GWDP under the Utah Water Quality Act because, as noted above, there is no probable r'{ t4
cause to believe that the Mill will result in a discharge of pollutanrs to groundwater. e b,
Nevertheless, IUSA does understand that TIDEQ has a concern that the NRC's regulatory regime
may not protect the groundwater at the Mill to the extent the State believes is required. We are
committed to working with UDEQ to determine what, if any, meaningful differences exist
between the current groundwater regime applicable to the Mill under NRC regulations and the
State's GWDP program. We hereby reaffrrm that commitment, and intend to continue to work
with UDEQ with a view to satisfying UDEQ's concern in a manner that is compatible with the
federal regulatory regime applicable to the Mill.
To this end, during our meeting on March 12, IiDEQ proposed that IUSA informally submit
information typically required for a GWDP. After receiving this information, TIDEQ would then
draft a suggested form of GWDP that would satisff UDEQ's requirements but that would also
address IUSA's concerns that were thoroughly discussed at the meeting, including the DOE
transfer issue. tiDEQ expressed the opinion that they believed this could be accomplished.
ruSA and UDEQ will then evaluate whether any meaningful differences exist between the two
groundwater regimes and, if so, whether they are more appropriately resolved through the
issuance of a GWDP, by adding additional conditions to IUSA's NRC license (which ]vas the
approach suggested Uy fi.lSe,;, oi by ro*. other atternative. - -G
Nftc "-.J+ o,A,tco, -l:h.
As we discussed, any acceptable method of dealing with these issues will have to address our
concern that the State will attempt to use the GWDP as a means to regulate and control IUSA's
operations at the Mill. You and Fred Nelson attemptd to assure us that the State's only
objectives in terms of a GWDP were the protection of groundwater and enforcement of Utah's
laws. While we believe your thoughts were sincere, you can imagine how dismayed we were
when we received a copy of the attached letter from Bill Sinclair to the Secretary of the fumy. I
hope you now understand our concern about the State's motives in requiring ruSA to submit to a
GWDP. This interference with tUSA's commercial activities suggests hostile State motives
which could be interpreted as tortious attempts by a non-Agreement State to indirectty and
illegally regulate our facility.
Irrespective of this unfortunate event, which we will address separately, ruSA intends to honor
its commitment to continue to explore ways to work with t DEQ to resolve our differences in a
mutually satisfactory manner. Therefore, we would like to proceed with the next step in
UDEQ's proposal and provide UDEQ with the information normally required in an application
for a GWDP. This information should allow t DEQ to understand the carefully chosen physical
setting of the Mill and the regulatory regime applicable to it, and to determine from UDEQ's
point of view what, if any, meaningful differences there may be between NRC's groundwater
protection program and the State's GWDP program.
the information required, and5hs reviewed
In addition, EIIre
iJinctuaeinformationinthefollowingareas]facility
location, type of nrii'.i ,i."itt' 'otuie' oi nuia 1 th-t"*ll,o"i":i::1i.ff::ttill":".'irTii:
ff:::"#ffi.rll}li discharge, water n"*r, discharge of fluid characteristics' hvdrogeologv,
groundwater discharle conirorr, .o.rpii"n.L monito-ring, closure and post closure plans' and
contingency and .oi'"Lir. action pr",ir.
-ii
itris scrreaull is not acceptable to UDEQ, please let
us know as soon.r p"ttiUf. so thaiwe can discuss possible alternatives'
\lr. Don Ostler
lvlarch 19, 1999
Page 3 of3
After you have had a chance to. review.this informi!:1P:S i:i^Y,*^:i:'::
position to discuss anY meanlingful differences between..tle two groundwater
il#;r:;"i'ii.i"r, appropriatJ*.y to address any such differences.
President and Chief Executive Ofticer
rusA continues to berieve that the comprehensive reguralo.ry requirements of the NRc have and
will continue to assure protection orpuiii, health anl safety, inctuding groundwater issues' we
recognize the Stateis airr.ring view on this issue, but continue to berieve that resolution of the
differences between rusA and uDEe ttrorgt constructive negotiation is preferable to litigation'
Therefore, we are willing to proceed with u6gQ,s suggested approach as.a demonstration of our
good faith ,o "rrur.'fro',.Oion.of
the ,iuiron"nt to-UOgQis satisfaction' ruSA appreciates
UDEe,s willingness'to consider all ;;ttii[ options. avaiLble to ensure protection of the
environment in a ,";;; that is ,onrirtJJ*th the regulatory regime applicable to the Mill'
in a better
regulatory
cc: Dianne NielsorL Executive Director' ['DEQ
william sin"r"ir, oitaot, LDEQ Division of Radiation control
ii"g it.Ufein' Chief, NRC Uranium Recovery Branch
frfit-" Hi.gel, NRC Uranium Recovery Branch
Paul Lohaus, NRC Offrce of State Programs
Charles HackneY, NRC Region IV
ired NelsorL Utah Attorney General's Office
David Bird, Parsons' Bihle' and Latimer
Tony Thompson, Shaw' Pittman" Potts' and Trowbridge
Mililammering, EPA Region VIII
David FrYdenlund, ruSA
Michelle Rehmann' ruSA
(LDEQ, Division
CordiallY.
ATTACHMENT 5
Knight Pi6sold Report
Correspondence
November 23, l99g
Anthony J. Thompson
!!l*, Pirtman, potts, & Trowbridge
2300 N Street, N.W.
Washingtorq D.C. ZOO37 _L2g
{*!sht Piesotd LLC
coNSULTtNG ercrre
1050 Seventeenth Street, Suite 500
D e nve 4 Co lo rado g026 S _0 500
Te Ie phone ( 3 0t ) 629 -8288Telelax (30j) 629-8789
YOUR REFERENCE
1626C
OUR REFERENCE
EVALUAT3
{*ight Pi4soW
GROUP
't-1-..<--Yf
Popielak, P {
Evaluation ofpotentiar for Taitings cefi Discharge - white Mesa Miil
Dear IVlr.
In response to your request, we have conducted an evaluation of tailings cell perforrnance at the\vhite Mesa MII of your client, Intemational Uranium oa;J'c",po^.ul19n (ruc). This independenttTX.ffil'::H T:,::liTJHt -#o tentiar rb; l ;.;"se o r ta i r i ngs *"*, no m this r;r il;
Review of tailings cell construction,
Review of Iiner leakage monitoring,.
Modeling of hypothetical dischargl'of taitings warer from Cell 3, andExtrapolarion of Cell 3 modelingio Cells I and 2.
I
.)
J.
4.
ffi:*t:#:'ff::yj::ff:f:ie of tailings water to the underrying perched water zone inlli : lil:X iTfi :i *i :::x :*:t,' : : "":' o *** ;i. ", illl:::i ilil'f'fi :"[,1 H:tilff i:
: i j:::q:,:::,l 1,
*'",":: the potentiar ilil;iil;,.:' il"ft, lTthe cells be reclaimed withlilH*,x,:li'i![[i1lig:f:::::';911J1r';l*.ff ,;,]#L,li::[iJJ"TlilI''fl Jil::::1"ffi::*,1;iglfi i#i:*::*".^,::1,*:^::.#i;ilff :*[,HI',,T:ff"];due to microfiltration uy tt" to* p".m*u,r-rir"l ##ffir:"J:fl[:t":::*J:;H'
we hope that this review proves beneficial in evalua_ting your clie_nt,s standing with regard to thepotential for discharge of tailings water. Please call if wJ can ue of further assistance.
Sincerely,
KMGHT PIESOLD LLC
P.E.
Roman S.
"ff'"t$tJpAIVIERICAN CONSULTING
ENGINEERS COUNCIL
.1),_ rcte1., ,?,Jh,
^ll--('fuv n n',.^lr ,
I It*p* C*" ir^.,n1 tl- l<4
(&
X*q!,/ I,iitrL!
Anthony J. Thompson
Shaw, Pittman, potts, & Trowbridge
Tailings Cell Construction
Facility Summary
The white Mesa Mill has constructed four below-grade tailing disposal cells. These cells aresummarized by the following:
I cell I is constructed with a 30-mil PVC liner covered with earthen material. This cell wascompleted in l98l and is used for the evaporation and storage of process solution.Cell 2 is constructed with a 30-mil PVC liner covered with earthen material. This cell wascompleted in 1980 and is used for the storage of barren tailing sands. This cell has receivedan interim cover and presently receives no liquid effluent from the mill.Cell 3 is constructed with a 30-mil PVC linercovered with earthen material. This cell wascompleted in 1982 and is used for the storage of barren tailing sands and associated solution.Cell 4 is constructed with a 40-mil HDPE liner. This celi was consrructed in 1990 andpresently receives no tailings from the mill. Tailing solution was initially stored in this cellbut was later remov:d. A detailed analysis of lineiperformance will be conducted prior toany process use of this cell.
Foundation Conditions and Excavation'f he cells have similar foundation conditions, namely, variable thickness of cohesive clay (ML to CL)overlying sandstone and claystone bedrock. cells were excavated into the bedrock, but cell dikesincorporated in-situ soils unless they were found to be calcareous. some calcareous soils in the
'icinity of Cells I and 2 were excavated for this reason and replaced with non-calcareous soil. Thesoil excavated to form the cell bases was generally used in dike construction.
In general, bedrock was excavated by ripping and dozing to design grade, although some hard zoneswere encountered in all cells. The rock was excavated to a final surface that slopes toward themidpoint of the downslope (south) dike in each cell- After the last bedrock lift was excavated, largerock fragments and claystone were removed from the underlying surface; other fragments down tocoarse sand were left in place for construction of the liner bedding layer.
Dike Construction
Dikes were constructed of cohesive (ML, CL) soils. D'Appolonia (l9s2a) reports that the soil wasplaced and compacted in lifts to at least 90vo Modittied-Proctor dry density, or ar least I l5 pcf.Cohesive soils compacted to this dry density have substantial strength, li* permeability, andessentially no liquefaction or settlement potential. Test results in D'Aplolonia l issza) show I .97omaximum volume change in consolidation tests with acid pore liquid, demonstrating that these soilsa're not susceptible to weakening and collapse in the event of lin.il.uk.g.. Harrison and Abt ( l9g0)state that QC field density testing was performed frequently, averaging- on". per I ,000 cubic yards(cy)' This frequency exceeds NRC requirements as stated in rhe construction siecifications. Fill thatfailed testing was reworked and retested until it passed. This observaiion is confirmed by
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
November 23, 1998
D'Appolonia (1982a, Appendix B) for dikes for cells 1,2, and 3. AII inspections by Abr
( 1980)reported no deficiencies in construction or QC practices or resulrs. The records provide highconfidence that these dikes were well constructed and should remain intact under any failure or
leakage scenario likely to be encountered at rhe white Mesa Mill site.
Ilasc Preparation and Bedding
The cell bottoms were prepared for liner installation by crushing, rhen compacting, the last lift of
ripped rock, less claystone and large sandstone blocks. The final excavated rock surface, on both
the cell bottom and the slopes excavated in rock, was picked free of loose +6-inch rock fragments
so that no rock protruded more than four inches above the general level of excavation. The small
broken rock was ripped, then crushed to a consistency of sand using compactors. This material was
placed on top of the remaining rock and rolled by a smoothdrum compactor until the surface was
l'rec of fragments protruding above the rolled surface, as documented by visual inspections by all
p.rnies (D'Appolonia, Energy Fuels Nuclear, and Goodrich or Warersaver) and photographs recorded
inD'Appolonia(1982a)andEnergyFuelsNuclear(1983). Thefinishedbedding,whichcoversrock
surf aces on both the cell bottoms and side slopes, has a maximum size of 1.0 inch, less than 2O Vo
clav, and gradations (D'Appolonia, 1982a; Fig. l3) consistenr with a well graded medium ro coarsesrtnd. The bedding material conforms to the specifications for this material in the design
iD'Appolonia, l98l). Cell4,constructedofHPDEin lgg0,wasfurnishedwitha l-footlayerofcliy
iindcrlying the I{DPE.
Underdrain System'['[rtunderdrainsristemconsistsof a t2-inchsanddrainontheinslopeof thesouthdikeofeachcell,rliilt a 3-inch diameter slotted PVC pipe buried in the downslope end of the sand drain connected
t,) i1 Drisct)pipe riser that connects to the top of the inslope. During consrruction some modifications
r'"ere ntade in the pipe connections to facilitate construction. The underdrain system was designed
to intercept and bleed off any moisture that might penetrare the liner on rhe downsrream (south) dike
oi c:ach cell.
Although this system was originally intended to ensure that the dikes would not become saturated
rr,'ith acidic solution that would compromise their structural integrity, the underdrain is also
hydraulically connected to the liner bedding, which is in direct conracr with (directly underlies) the
l2-inch thick sand drain of the underdrain system along the south inslope of each cell. Therefore,
there is also direct hydraulic connection between the liner bedding layer and the 3-inch pVC pipe
in the underdrain system, making the underdrain system also a leak detection system for the entire
Iiner. A more extensive underdrain was incorporated into Cell4 construction. However, Cell4 is
not in use and will not be modeled in this review.
Liner
The liner for cells t, 2 and 3 is 30 mil
2 and Watersaver Company for cell 3.
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PVC supplied and installed by B.F. Goodrich for cells I and
D'Appolonia ( 1982a) and Energy Fuels Nuclear ( 1983) have
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Anthony J. Thompson
Sharv, Pittman, Potts, & Trowbridge
November 23,1998
documented that liner materials supplied by these companies met or exceeded specifications. Thesereports also contain descriptions of ground preparation and daily inspections of ifre bedding surfacesprior to installation, pointing out that the liner installation contracror had to be satisfied with the
surface before liner was installed.
D'Appolonia (1982a, Appendices C and D) and Energy Fuels Nuclear (1983, Appendices B and C)document the seaming procedures used to join liner panels as well as the results of field and
laboratory tests performed on the liner seams. Additional documentation on liner installation and
te st results is contained in Harrison and Abt ( 1980), Goodrich General Products Division ( l9g0), andD'Appolonia, (1980). The records contained in these documenrs demonstrare rhar eC protocols for
LSSurance of Iiner material quality and installation were followed rigorously. This record establishes
the basis for high confidence that the liner was installed correctly and would, therefore, be expected
to function as designed.
l,iner Cover and Slimes Pool Drain System
The liner was covered with l2 to l8 inches of qualifying (non*alcareous) soil in rvhich a slimes pooldrain system was installed in cells 2 and 3. The original design called for the liner cover to consist
oi' coarse tailings; however, insufficient volume of coarse tailing was available early enough toconstruct the liner cover entirely of this material, so other qualifying soil rvas used in liner cover
locations where no slimes pool drain pipes were installed. A graded sand rvas used to fill over and
around the slimes pool drain pipes in Cell 2. Coarse tailings were used as pipe bedding material forallothercells. Thisdrainsystem,intendedtofacilitatedewateringoffinetailings(slimes),consisted
of a rectangular grid of slotted PVC pipe wrapped in Mirafi 140 filter cloth and connecred ro a
Driscopipe riser at the middle of the south dike of each tailing cell, the lorv poinr in the cell bottorn.'f he design is documented in D'Appolonia ( 198 I ). The actual grid pattern of pipes installed in Cell
-)lEnergyFuelsNuclear, l983,Figure4)differedfromthedesign(D'Appolonia, t98l,Sheet3)to
better ensure gravity flow to the riser location.
i\Ionitoring PIan
The monitoring plan (D'Appolonia, 1982b) covers inspection of operations, training of personnel,
supervision, Iines of communication and responsibility, and documentation relating io design,
construction and operations of the tailings cells. It was prepared in recognition of the fact thatdiligence should not end at the end of construction but continue during operations. It calls for
inspections to be performed at regular intervals, ranging from daily to yearly.
Daily Inspections are to be made of each active tailing disposal area, rhe slurry pipeline (including
slurry flow and line pressure) and slurry discharge location, the evaporation pond (Cell I ), and thi
sump and drain systems. Three levels of response are defined, classified according to the urgency
of the required response.
Weekly inspectiotts include pond surface elevations, flow in sump and drain lines, and liquid levels
in underdrain risers.
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Anthony J. Thompson
Shaw, Pittman, Potrs, & Trowbridge
November 23, 1998
lv'lonthly inspections are conducted of the surface water diversion and retention structures, and thepipeline is surveyed for wear (erosion of wall thickness) using ultrasonic methods.
Quarterly inspections are made of emergency spillways and post-construction changes outside thedisposal area. A review of operating and maintenance procedures is also conducted.
l'early inspections include surveys of the dike crests and slopes, technical evaluation of inspection
reports, and a summary of inspection observations.
This monitoring plan provides regular, timely examination of the key indicators of cell and linerfunction assuring that leaks substantial enough to saturate the bedding layer wi1 be detected under
this program during the daily or weekly inspections.
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
November 23, 1998
Leak Detection System Monitoring
History
The uranium tailings cells (numbers l, 2 and 3) were built in the early 1980's. Since the inception
of their operation, there has been no indication that cells were or are discharging tailings liquid to
the leak detection system or underlying aquifer. Also site records indicate that operators of the
White Mesa Mill have followed inspection protocols requiring inspections of all tailings cell leak
detection risers. Data reviewed by Knight Pidsold indicate that there has been no detection of warer
in either of the LDS sumps from Cells I or 3. However, water was encountered during the
construction of the Cell 2 LDS sump. Additional water was later detected in a previously dry Well
7-2,in June of 1980. This well was located between the Cell 2 Dike and the Cell 3 Safety Dike in
an area which would later become the floor of Cell 3.
An October 1980 monthly report indicated that the water quality of Well 7 -2 was similar to that of
the Fly Ash Pond. [n December 1981 water was detected in the Cell 2 LDS sump. After laboratory
analysis this water was once again determined to be unrelated to tailings liquids. Subsequent
analyses throughout the 1980s continued to corroborate that the LDS for Cell 2 was intercepring
ponded waters in the Fly Ash Pond. Therefore, although some waters are being collected by the Cell
2 LDS, several years of analyses and evaluations support the conclusion that no tailings cell leakage
has been detected in any of the LDS sumps for Cells l, 2, or 3.
In August 1989, Umetco proposed a Detection Monitoring Program which rvas incorporated into the
pre-1997 license conditions. These conditions originated from the desire to detect any statistically
significant trends rvhich would indicate that tailings liquids are present in the Cell 2 LDS sump.
Although this procedure is applicable to all cells, at no time has water been detected in the LDS
sump of either Cell I or 3. This program is summarized as the following:
t.lrak Detection Systems are to be checked weekly for presence of liquids. Any liquids found
are to be removed.
Determination of "significant leakage" will trigger increased sampling frequency from
selected compliance rnonitoring wells. Significant leakage was defined as flow greater than
one gallon per minute. Should flows exceed one gallon per minute, an automatic pumping
system would be installed.
[rakage would be analyzed and evaluated for statistically significant trends. Should this
evaluation indicate that water removed from the LDS was originating from the lined facility,
Umetco would characterize the extent and degree of contamination and report to the NRC.
However, should water removed from the LDS originate from other sources (i.e., Mill Area
Sedimentation Pond) no additional work would be required.
2.
J.
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Shaw, Pirtman, Potts, & Trowbridge
6
November 23, 1998
Present Condition
The 1997 license renewal modified the detection monitoring program to evaluate the chemicalcltaracteristics of any water found in the LDS, thus focusing the program on chemical analytes.lnternational Uranium Corporation requested (January 9 and February26, 1998) that the projru*
be restored to the pre-1997 permit conditions which included an evaluation of flow rare as well asanalytes- Such a program is more likely to detect leakage through a damaged Iiner than consideration
of chemical analysis alone. The NRC concurred (1998) and issued an amended materials licensein 1998 restoring the intent of the pre-1997 conditions. Although the amended materials license
varies slightly from conditions proposed by Umetco in 1989, these variations are minor and do notchange the overall monitoring program as outlined in the previous section.
(l \ I (r0Os\ I 616c\wp\E VALUAT.I.rvJrd
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
November 23, 1998
Modeling of Potential Volumetric Flux
Purpose
This section assesses the hypothetical volumetric flux from tailings Cell 3 at White Mesa Mill.Modeling of Cell 3 was determined to be the most conservative case to model as its saturated depth
and area are much greater than those of Cells I or 2, hence, the liner in the Cell 3 is under g."it",
stress than in the remaining cells. This modeling assesses the quantity oF potenrial volumetric fluxthrough the liner of Cell 3 as well as the effect such flux might cause upon underlying strata. Resultsof these analyses for Cell 3 were extrapolated to Cells I and 2.
Background and Scope'failings Cell 3 was constructed in 1982 in accordance with the standards and requirements of the
U.S. Nuclear Regulatory Commission (NRC), which approved both the design and construction. As-built records of the Cell3 facility indicate that it is lined with 30-mil-thick poly"inytchloride (pVC)
plastic underlain by a 6-inch (in) compacted soil layer, except along the south embankment wherethe PVC liner is underlain by a l2-in layer of sand drain material containing a 3-in diameter
perforated plastic pipe. A generalized schematic of Cell 3 is shown on Figure I . Monitoring of thet{rain material since construction of Cell 3 has indicated no detectable water in this embankment
underdrain system. Cell 3 will be used for an additional two to three years and then will bereclaimed.
in tlte absence of any evidence of leakage occurring from Cell 3, hy,pothetical modeling to evaluate
potential environmental effects if the leakage rvere to occur frgm this cell was performed. This
scction presents results of the following:
l.modeling of volumetric flux through the PVC liner of Cell 3 based on hisrorical measured
water levels in the cell provided by IUC;
modeling of water retention within the unsaturated zone between Cell 3 and a perched water
zone approximately 110 feet beneath the cell; and
modeling of the rate of water movement in the unsaturated zone beneath Cell 3 and the time
it would take for water to reach the perched water table under assumed future operating and
closure conditions in Cell 3.
Volumetric FIux through Cell 3 PVC Liner Under Historical Operation
Unlike water flow through a porous soil, water transmission through a PVC liner can only occur
because of vapor diffusion and density discontinuities (EPA 1988). The discontinuities may be
present as pinholes and installation defects. Vapor diffusion involves the transmission of water
vapor through the liner on a molecular scale and is controlled by the permeability of the liner, its
thickness, and the pressure head on the fluid. Pinholes and installation defects could serve as
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
November 23, 1998
passageways for liquids. The combined flow through the discontinuiries and vapor diffusion is
hencefo(h termed volumetric flux.
The passage of water through a liner also is dependent upon the thickness and hydraulic conductivity
of the materials immediately above and below the liner. Giroud and Bonaparte (1989) provide
procedures for calculating flux rates through liners, taking into account the characteristics of the
materials above and below the liner, potential installation defects, as well as the available hydraulic
head on the liner. The total volumetric flux across the liner calculated in this review includes
potential flux from vapor diffusion across the intact liner, flux through pinholes, and flux through
the installation defects. Giroud and Bonaparte (1989) indicate that typical geomembrane liners have
about 0.5 to 1.0 pinholes per acre from manufacturing defecs. Additionally, good to excellent liner
installation results in less than I defect per acre. To be conservative, lhe flux rate analyses in this
review assume I pinhole and 2 defects per acre. Review of model resulrs indicates that pinhole and
det'ect flux rates are a minor factor in the calculation of total volumerric flux through the liner.
Volumetric flux through the Cell 3 liner was calculated in three parts due to the geometry and the
underlying compacted soil/drainage layers; I ) flux through the south dike liner, 2) flux through the
tiiree remaining dike liners, and 3) flux through the cell bottom liner. The flux rares for these three
were multiplied by their respective liner areas to give a total volumetric flux through the Cell 3 liner.
The Cell 3 PVC liner equivalent hydraulic conductivity was taken lrom liner data published by the
U.S. Environmental Protection Agency (EPA, 1988).
Tire total flux rate and the associated volumetric flux, based upon effective liner areas, were used
to calculate the volume of water which would enter and be retained by the underlying unsaturated
zone. as rvell as the time for the unsaturated zone to reach a water content which rvould begin to
initiate unsaturated florv downward toward the perched water table. Figure 2 presents a time series
of the historic Cell 3 water-surface elevations and also shows the calculated volumetric flux rates
through the liner for those water-surface elevations.
Average Cell 3 water-surface elevation during the 190-month periods of record was 5,595.57 ft
above mean sea level (famsl), with a minimum and maximum elevation, respecrively of 5,580.23
and 5,605.41 famsl- These watersurface elevations were used to calculated the hydraulic heads
acting on the liner.
Based upon the calculated flux rates shown on Figure 2 and the liner areas over which they apply,
the total volumetric flux across the Cell 3 liner is estimated to have averaged 50 ftr/d over the 190-
months. Figure 3 shows the cumulative volumetric flux of water that could have passed across the
Cell 3 liner since January 1983. This volume is approximately 290,000 ft]. Of this volunre,
approximately 79 percent is from vapor diffusion across intact liner surflaces, less than I percent is
from hypothetical pinholes, and approximately 20 percent is from potential installation defects.
Clearly, a majority of the seepage across the Cell 3 liner is from vapor ditfusion across the intact
liner surfaces.
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Sha,,v, pitrman, ports, &Trowbridge EP| /6a)t ' *'November23,
1998
<{I
This hypothetical flux is very low and equates to less than 5 gallons per acre of liner per day (gpad).Acknowledging that vapor diffusion through PVC liners occurs, the Environmental protection
Agency (EPA) recommends that liner seepage be limited to de minimrs quantities. This term refersto the insignificant quantity of water vapor that may permeate a pvC liner. Although this rate iscalculated for site-specific conditions, EPA has proposed that 5 to 20 gpad is representative of a linerinstalled with a high level of quality ursurun.. 6Re, 1988). our eitimated flux rate, includingpotential installation defects, is less than 5 gpad and is indicative oIa well-constructed, functional[,VC liner.
Water Retention in the Unsaturated Zone Beneath Cell 3 Under Historical0peration
In unsaturated materials the pores are only partially fllled with water, with the remaining pore spaceusuallyoccupiedbyair. Additionally,unsaturatedflowcanoccuronlyifenoughofthe foreuotum"has water in excess of moisture retained in storage by the forces oF attraction. This thresholdvolumetric water content is called "specific retention" and is the water content at which essentialyno rvater moves downward under gravity flow.
In the Dakota Sandstone and Burro Canyon formations underlying Cell 3, the rocks are unsaturatedibr a depth of I l0 ft, until a perched water-bearing zone in the Burro Canyon Formation iscncountered- Data published by Titan Environmental (lgg4) indicate that within this I l0-ftunsaturated zone the average water content of the rocks is less than the moisture retention. Thismeans that some volume of water can be stored in the unsaturated zone before initiation ofun'saturated florv by gravity. This ability to perrnanently store additional water and the configurationof the srrarra underlying Cell I are shown on Figure 4.
The documented volumetric water content of the I l0-ft unsaturated zone in the Dakota and BurroCanyon formations is 3.4 percent. Because the specific retention for this same thickness is 5.5percent, 2.1 percent by volume is available for water storage prior to downward unsaturated watermovement (litan Environmental, 1994). Applying this potential storage volume to the footprint ofcell 3 (an area of 3,375,913 ft2', approximately 77.5 acres) results in a residual storage voiume ofabour 7.8 million cubic feet for the I l0-ft thick unsaturated zone.
Assuming that 2.1 percent residual water storage volume was available in January 19g3, and theseepage from Cell 3 between January 1983 and presenr was approximately290,000 f;3, indicates thatapproximately 4 percent of the residual pore volume in the unsaturated ione could have been filledsince Cell 3 began operation in January 1983. This means that an additional 7.5 million cubic feetof water would have to discharge from Cell 3 just to bring the average warer content of theunderlying Dakota and Burro Canyon formations to moisture levels adequite to initiate unsaturateddorvnward flow.
Cell 3 will be used for an additional2 to 3 years, at which time it will be capped and reclaimed. WeIlave estimated the volumetric flux for the remaining years of operation by cons..ratively assuming
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
November 23, 1998
that the water-surface elevation in Cell 3 would be at a constant maximum level of 5,603 famsl. Atthis elevation the volumetric flux rate from the entire Cell 3 would be approximately g0 ftr/a o, o qgallons per minute Gp*). After that timq Cell 3 would be capped and reclaimed. Hence, volumetricfiux of tailings water from Cetl 3 would have resulted in nL discharge of tailings solution to theunderlying perched water zone during its operation life.
The time to bring the Dakota and Burro Canyon sandstones to a volumetric moisture content of 5.5percent would occur far into the future after Cell 3 closure and reclamation if drainable fiquidsremained in the cell- Model results indicate that an additional 7.5 million ft3 of residual ,to..g"rvould still be available to store future fluxes across the Cell 3 liner after closure and reclamation.Conservatively assuming that water remains in the cell and an effective cell cap eliminates the additionof water to the cell, the amount of liquids available for seepage would be limited to that which wasin the Cell 3 tailings at the time of closure. we estimate that ihetaitings within the cell have a specificretention of 75Yo (Hoftnan and Cellaq 1998 and Vick, 1990). Using this relationship we havemodeled a decreasing saturated level within the tails after capping. irojections of future watersurface levels and liner flux rates are shown on Figures 5 and 6. These data indicate that the residualstorage in the underlying Dakota and Burro Canyon formation would be filled to a volumetricmoisture content of J 5 percent in approximately coO years after Cell 3 closure and reclamation.Atier that time, additional votumetric flux from Cell 3 iould begin to move dorvnward toward thepcrcired water table at a very slow rate determined by the unsaturated hydraulic conductivity of theunderlfing formation. At the inception of unsaturated flow, volumetric flux from the cell would be31 ft3/d (Figure 6), a1d would ."qrir" approximately 900 additional years ro reach the perched warertable I l0 ft beneath Cell3. In summ&ry, a total of 1,300 years would be needed for volumetric fluxlronr cell 3 to reach the perched water tabre after closurl of the cell
\\'ater-Quality Implications of Liner SeepageA majority of the potential flux from the cell wouldiezult from vapor diffi:sion through the intactliner' PVC liners do not appear to be permeable by ions with the possible exception-of hydrogen(EPA 1988). Because of this, a majority of the seepage would have a water chemistry much lowerin dissolved solids (virtually absent) than the *"i"i seeping through the liner via pinholes andinsta[lation defects.
Transmission of water tkough soil or rock does not necessarily include the transmission of potentialpouutants contained within the fluid. Several physical and chemical processes result in the attenuationof many chemical constituents. These processes include mechanical dispersioq adsorption to soilparticles, cation exchangg and oxidation-reduction reactions. As a result oithese processes, not onlyrvould it take approximately 1,300 years for volumetric flux to potentially..""h the perched waterzone, but such volumetric flux could be expected to be relativety free of most contaminants.
Extrapolation of Cell 3 Modeling to Cells I and 2
Modeling of Cell 3 was determined to be the most conservative case to model as its saturated depthand area are much greater that those of Cells I or 2. All three cells were lined with the same
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
November 23, L998
materials in the same fashion. Our review of construction reports indicates that all cells were
constructed to the same general level of quality control - excellent. As flux through the liner is
directly proportional to the head above the liner, estimated flux rates from Cells I and 2 will be
consistently lower than for Cell 3. Therefore, modeling of Cell 3 results in the most conservative
estimates of potential impacts to the perched water zone.
u
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Shaw, Pittman, Potts, & Trowbridge
t2
November 23.1998
1
Summary of Conclusions
From the above review of cell construction and analyses of Cell 3 liner seepage during and after
operation, we offer the following conclusions:
l.Since the cells were constructed in the early 1980's there have been no indications that tailing
cells were or are discharging tailings liquid to either the leak detection systems or the
underlying formation;
Water observed in the Cell2 LDS sump has been thoroughly analyzed and determined not
to be a component of the tailings water;
Recent modifications to the operating permit are based on sound engineering principles and
are more likely to detect leakage through a damaged liner than consideration of chemical
analysis alone;
Modeling of potentially occurring volumetric flux through the Cell 3 PVC liner during the
period between January 1983 and October 1998 may have reached an average rare of 50 fC/d
(0.25 gpm). This rate is considered "de minimis" and inherenr for PVC liners by the EPA.
Based on our modeling, the total volumetric flux since beginning of cell use would represenr
only 4 percent of the specific retention (i.e., permanent pore storage) in the underlying
sandstone. Hence, 96 percent of the permanent pore storage would be available for future
moisture if any were to migrate below the cell's liner;
Cessation of the discharge of any liquids upon terminarion of cetl operaring life and
reclamation of tailings will result in the gradually diminishing rare of volumetric flux during
the post-operation period;
If the status quo were to continue, the volumetric flux through the Cell 3 liner, based on our
modeling would require at least 400 years after closure to fill remaining sandstone pores such
that unsaturated flow downward toward the perched water zone could commence;
Unsaturated flow, if it were to exist, based on our modeling, would require an additional 900
years to travel the 110 vertical feet to the perched water-bearing zone after sandstone
moisture is raised to a degree facilitating downward movement of moisture. In other words,
a total of 1,300 years would be required before any potential volumetric flux from a
reclaimed cell could reach the perched water zone below the site;
8. Dissolved metals in tailings water are unlikely to be transported through the I t0-ft vadose
zone due to significant attenuation from a number of potential processes documenred to exist
when moisture moves at a very slow rate through a very [ow permeability rnedia. These
processes include a combination of microfiltration through the PVC liner, adsorption to soil
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6
7.
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Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
t3
November 23, 1998
particles, cation exchange, horizontal and vertical dispersion due to heterogeneities of rock,
and oxidation-reduction processes.
9 - Since Cell I and 2 are smaller and the hydraulic heads of liquids presenr in those cells are
also lower, estimated flux rates from Cells I and2 will be correspondingly lower than thosewhich may occur for Cell 3.
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Anthony J. Thompson
Sharv, Pittman, Potts, & Trowbridge
November 23,l99B
References
We have reviewed and"/or cited the following documents in preparation of this review:
Abt, S.R., 1980, Trip Report of Inspection of Embanlcrnent #3 on 4n4/80.
Rrooks, R.H. and A.T. Corey,1964,Hydraulic Properties of Porous Media, Hydrology Papers No.3,
Fort Collins, Colorado State University, March,ZT p.
D'Appolonia, 1980, l,etter Report on PVC Liner and Underdrain Installation dated 8/8/80.
D'Appolonia, 198 l, Engineer's Report, Second Phase Design - Celt 3 Taiting Managentent System,
White Mesa Uranium Project.
D'Appolonia, 1981, Lrtter Report, I"eak Detection Systent Evaluation White Mesa Uranium project.
D'Appolonia, 1982a, ConstructionReport,lnitialPhase-Tailinglvlanagementsystent,WhiteMesa-
Urattiurtt Project.
D'Appolonia, 1982b, Monitoring Plan, Initial Phase - Tailing Management System, Wip Mesa
Uranium Project..
Encrgy Fuels Nuclear, 1983, Construction report, Second Phase - Tailing Managentent System,
White lv'lesa Uraniurn Project.
Environmental Protection Agency, 1988, Lining of Waste Contairunent and other Intpoundnrcnt
Facilities.
Giroud, J.P. and R. Bonaparte, 1989, Lealcage through Liners Constructed with Geomembrane
Liners Parts I and II andTechnical Note, Geotextiles and Geomembranes, vol. 8, no. l, ppZT-
67, vol. 8, no. 2,pp7l-l I l, and vol. 8, no. 4, pp. 337-340.
Goodrich General Products Division, 1980, t.aboratory Test Report of 3/6/80 on PVC Liner
Material.
Harrison, H.C., and Abt, S. R., 1980, IE Inspection Report No. 40/8681/80-01 of 6/6/80 on 4/t 5/80
Inspection of Dike #4 and Cell #2 Liner Placement.
Hoffman, G.L. and R.R. Cellan, 1998, Slime Dewatering at the Homestake Grants Projcct,ln:
Tailines and Mine Waste'98, Proceedings of the Fifth InternationalConference on Tailings and
Mine Waste '98, Fort Collins, Colorado, USA, 26-29 January, 1998, Brookfield, VT, USA: A.A.
Balkema Publishers, 965 p.
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h'rtiglrt I'itisoltl
Anthony J. Thompson
Shaw, Pittman, Potts, & Trowbridge
l5
November 23. 1998
Mcwhorter' D.B. and J.D. Nelson, 1980, Seepage in rhe Partially Saturated bne Beneath TailingsImpoundmenrs, Mining Engineering, April, pp. 432_439.
McWhorter, D.B and J.D. Nelson, 19:79, Unsaturated Flow BeneathTailings Impoundments. Journalof the Geotechnical Division, ASCE, vol. 105, no. GTI l, pp. l3 fl-trq.'
Tindall, J.A. and J.R. Kunkel, 1999, IJnsaturated Zane Hydrotogy for Scienrists and Engitrcers,Upper Saddle River, NJ: prentice Hall, Inc., 602 p.
Titan Environmental Corporation,lgg4, Hydrogeologic Evaluation of White Mesa Uranium Mill,Report Prepared for Energy Fuels Nuclear, Inc., July,5l p.,5 tables, l9 figures, reflerences,Appendices A through G.
Urnetco Minerals Corporation, 1989, I*tterfront D.K. Sparling and J.S. Hantrick regarding tlteproposed Detection Monitoring programfor Ceil 3.
U'S. Environmental Protection Agency, (EPA), 1988, Lining of lVaste Cottainnrcttt artd Otlrcr{mpoundntent Facilities, EPA/600/2-88tO52,Risk Reduction Engineering l-aborarory, Cincinnati,oH.
U'S' Nuclear Regulatory Commission (USNRC), 1980, lzue r fronr G.D. Browrt to Ertergy FuelsNuclear regarding inspectiorts by Abt and Harrisort.
Ll.S.NuclearRegulatoryCommission(USNRC), 1998, MaterialsLicense,sUA-t35B,Amendtrttettt
l/o.8.
Vick' S.G., 1990, Planning, Design, and Analysis of Tailings Dams, Vancouver, 8.C., Canada:
Bitech Publishers, Ltd.,34Z p.
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DEPARTMENT OF ENVIRONIVIENTAL QUALITY
DIVISION OF RADIATION CONTROL
l5t North 1950 Wcst
P.O. Bor l44t5o
sdr l-rlie city. ur.h t4 I l4-4tJ0
(t0l) 515-{250 voicc
(t0l) tl3a097 Fu
(t0 r ) ,16-44 r1 T.D.D.
.etl ; t :SSt .,,
1
N{ichrcl O. LcrvittGotcm
Diannc R. Niclson. Ph.D.Erco'c Drm
William J. SinclrirOlw
January 21,1999
lv{ichelle R. Rehmann
Environmental Manager
I nternational Uranium (USA) Corporation
Independence Plaza, Suite 950
1050 Seventeenth Steet
Denver, CO 80265
Methodology Assurnptions used for Calculation of Flux Through The Cell 3 Liner
White Mesa Uranium Mill
Dear Ms. Rehmann:
The Uuh Department of Environmental Q,rality, Division of Radiation Control (DRC) has
received the subject report prepared by lhight Piisold LLC and dated Deccmbcr 3 I, 1998. A
review of this reporr by DRC staffindicates that a numhr of assumptidns were madc without
appropriate supporting documentation. Thesc assumptions have critical implications associated
rr irh the analytical model inputs and corresponding output liner leakage predictions. Without thc
supporting documentation, these assumptions and the model predictions cannot be conJirmed.
To enable rhe DRC to proceed wirh a rcview of the modeling effort and veriff the predictions
rendered, please provide the following information.
The geomembrane defect frcquencics and sizes rscd in the modeling effort assumed
intensive quality sssurancdquality control (QA/QC) monitoring during liner corutnrction.
To validate this assumption, extensive documentation of construction QA/QC is nceded.
?lease provide the DRC withthe conshrction QA/QC documentation to ensure the
following:
Quality control was provided by the geomembranc installer following a rigorous
construction qualitycontrol manual;,
Quality assurance was provided continuously by an third party independent firm;
All geomcrnbrane panel scams were tested after installation to find and rcpair all
seam defects;
Description and documentation of steps werc taken in preparation of thc soil
subgrade below the 30-mil synthetic PVC liner. In particular, pleasc provide:
ivlichelle R. Rehmann
Jarruary 21, 1999
Page 2
Ma,timum and average particle size allowed on the soil subgrade prior to
installation of the 30-mil synthetic liner. Please provide gradation testing
results to support said claims.
Description of equipment and methods used to remove over-sizcd
matcrials (e.g. rock clasts, soil clods) from the soil subgrade prior to
placcment of the 30-mil synthetic liner.
monitoring of moisture, ambient temperature, seaming temPerature, seam
contamination by dust or dirt, and remedial activitics were conducted and
documented; and
all conncctions between geomembrancs and appurtcnances were testcd to find and
repair defective connections.
As stated in the Summary of Model Assumptions on page I of the subject report, "Ifie
soil layer underlying thc geomembrane has a saturated hydraulic conductivity ronging
from lxltt (for sandl to txtF cnds (for reworked bedrock materials)." Because the soil
'layer beneath the geomembrane is the controlling soil layer, there needs to be some
quanritative justification for using thesc values, particularly for the reworked bedrock
materials ofitre Dakota Sandstone. Please providc the DRC with documentation for
quanrirative results of permeability urd compaction tests to justiff the hydnulic
lonductivity values uscd in the analytical modcling effort-
I
As indicated above, the DRC qucstions the validity of the hydraulic conductivity used for
thc soil layers underlying the geomembranc. Conscquently, thc DRC questions whether
the appropriate Geomembrane liner Design Casc and corrcsponding equations of
Sctgoeaei and others (1994) was applied in the modeling effort. Please jutify the Design
Case that was used in the leakage analytical modeling effort.
Accelerated travel times of tailings pond leakage via secondary permeability from joints
and fracturcs was not addressed in either the Novernber 23, 1998 or the December 31,
1998 Knight Pidsold rcporu. However, site-specific well test data from a previous
groundwaier Sudy of the \Ttrite Mesa mill indicated the presence ofjoinS and fractures .
il..r. justify why the poteilial effects ofjoint and fracturc flow werc not incorporated in
the seepage analytical modeling effort.
l)
2)
iv{ichelle R. Rehntann
January 21,1999
Page 3
We appreciate the oppornrnity to review the Knight Piisold report and look forward to working with
you in'the futgre. Iiiou have any questions about this lener, please call me or Rob Herbert at (801)
536-4250.
ffi;F
Division of Radiation Control
WJS:RFH:rh
cc: Don Ostler, P.E., Dircctor, DEQ-DWQ
F rj{rrraril}?lwrm xca^\trcsolr.LTr
lrrER\ rTIt.i\ rr
UR.r.rtt'rr
CoRpoR.rrros
IndependencePlaza.Suiteg.50. 10.50SeventeenthStreet. Denrer.CO5():6;.:i();l 6237i9Srriliun .,jt,.i i\9ati) i.ir
February 12, 1999
VIA FEDERAL EXPRESS
William J. Sinclair, Director
Division of Radiation Control
State of Utah Department of Environmentd Qudity
168 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: Response to your lener of January 21,1999 Regarding Methodology Assumptions for
Calculation of Flux Tkough the Cell 3 Liner, White Mesa Uranium Mill
Dear lv{r. Sinclair:
This letter responds to your letter of Jan uary 21,1999 regarding methodolory assumptions for
calculation of flux through the Cell 3 liner, White Mesa Uranium Mill, which we received by
fa.x on February 3, 1999. We appreciated your sending us a fa:red copy of the letter.
As we indicated we would do during our telephone call of February 2, 1999, we hereby
transmit responses to the questions in your letter of Ianuary 2L, 1999. We hope that this
provides your engiraering staffwith all necessary information to complete their review ofthe
tailings cell performance review and modeling performed by Ifuight Pi6sold, LLC, as reported
on November 23, 1998. I can be reached at [phone].
Sincerely,-Y4,,u.qM
Michelle R. Rehmann,
Environmentd Mutager
MRR/dm
Attachment
\lr \\ iilirm J Sinclei
February i:, 1999
Page 2 of2
cc: Ron E. Berg
Sam Billen (Knight Pi6sold)
Dave Bird
William N. Deal
David C. Frydenlund
EarlE. Hoellen
Harold R. Roberts
Tony Thompson
cF: LELEAilhite Mesa MilvGroundwater Discharge Permit
CF: LELElKnight Pi€sold RePort
FTUSERS\STAFF\I{RN\LETTER9SISINCU I I.DOC
X nis A P i6 s ?,!4, 14r,9=.En-uurucercrneensANoENvlRoiltExrALsclExTlsrs
February'tl. 1999
1050 Seventeenth Street, Suite -i00
Denve r Colorado 80265 -0500
Telephone ( 303 ) 629'8788
Tetefu (303) 629'8789
YouB REFERENcE ll0lC
oun REFERENcE LDEQ3.*gl
Ivlichelle Rehmann
International Uranium (USA)' Corporation
1050 Seventeenth Street, Suite 950
Denver. CO 80265
Re: Response ro UDEQ Comments on Methodology Assumptions
Dear Michelle:
Ar your requesr, we have reviewed the letter tiom the umh Depailment of Environmental Quality
(UDEQ) dared January 21, t999. This leuer conrained four commens regarding the UDEQ's review
ol modeting *. ,...nily completed tbr rhe whire vlesa uranium Mill. The purpose of our modeling
ettort was to esrimate in. *it.r tlu.r, rhar could reasonably be expected to pass tfuough Cell 3' a
pVC-lined impoundmenr ar your taciliry. Previous cell modeting by others utilized hypothetical
cases involving unreatistic aslumptions of massive liner failure. Eighrcen years of operation have
indicared that these hypothetical assumptions are unwarranted. Our obiective has been to review
available dara and approximare actual site conditions. we have used engineering judgement to
quanrity rhe hydrautit conductivity of the soils beneath the PVC tiner. We infer that UDEQ
generally agrees with the modeling but is questioning specilic input values used in the model.
iooi,ionuui. uogq seems ro purporr rhar unsarurated tlorv in the underlying Dakota Sandstone is
ti'cture controlled. we have summarized the uDEQ commenr and our responses iLs tbllows:
Comment t: UDEe quesrions the conclusion that the tiner was installed under intensive quality
.rtur*..lquality control (QA/QC) and, therefore, our assumptions regarding liner
defect frequencies are invalid'
Response l: Our review and analysis of cell construction activities as reported in our letter to
furrhony Thompson, dated November 23, t998 concluded that the [iner was, in tact,
instaUei in accoidurce wirh inrensive QA/QC procedures. This report cites numerous
specifications, construction reports, Nuclear Regulatory Commission (NRC)
inspections, and third party reviews used to arrive at this conclusion. Should UDEQ
quistion our engineering review of the QA/QC documentation, these documents are
pan of the pubfc recorJ and can be reviewed by UDEQ as required- These reports
conuin the iactory seam tests, quality control tests, field seam tests, bedding gradation
tes6, and liner repair reports requested by UDEQ'
MEMBER OF
AMEB]CAN CONSULTING
ENGINEEBS COUNCIL
XniStu PiAsok
GROUI
Knisht Piisold
-9-
lvlichelle Rehntann
lnternationul Uranium t USA) Corporltion
Comment 2:
Response
Comment
Februarv ll. 1999
As we srated in our lerter report titled Methotlolo*- lor Calculation of Flu.r Through
the Cell 3 Liner. dated December 31. 1998:
"sensiriviry analyses were conducted to determine the ettect of det'ect
assumptions. [ncreising the frequency of pinholes and installation
det'ects by an order of magnitude (i.e., l0 timei resulted in only a30%
increase in the estimates tbr average tlux through the liner. These
analyses indicare that pinhole and det'ect tlu.r trequencies are a minor
tactor in the estimation of total volumetric tlu.x through lhe liner-"
Based on our review of consrruction documentation, we jud-ee it improbable that there
could be l0 times the insrallation det'ects we assumed. Thus, although UDEQ
quesrions rhe QA/QC assumprions. these parameters do not si-enilicantly change our
conclusions.
UDEe quesrions the assumed hydraulic conductivity of the regraded materials beneath
the liner.
No documenrarion is available for the saturated hydraulic conductivities of dike or
bottom materials underlying the -geomembrane. [n our etlbrts to approximate actual
seepage we used engineering judgement to estimate the hydraulic properties of the
tinei UeOOin_e marerial. We assumed that the saturated hydraulic conductivity of the
l2-in sand layer behind rhe liner on the south dike of Cell 3 was lxl0I cm/s because
this is a typical value for the clean sand that was used tbr the underdrain material. The
value of-ixl06 cm/s was used for the compacted soils behind the other tluee sides
(dikes) of Cell3. This same value also was used for the compacted, reworked Dakota
formation beneath the bottom of Cell 3. However, as shown by our response to
Commenr 3, these assumptions are not critical to the estimated flux values calculated.
UDEe comments that a change in assumed hydraulic conductivity would require
modeling the slatem under a different Design Case-
The model we applied provides for six Design Cases as defluied by Schroeder and
orhers (1994). Ttres" Design Cases vary depending on the arrangement of the
composite liner and the hydraulic conductivity of its constituents. Our model
conslrvatively ignored rhe low conductivity tailings overlying the geomembrang. The
appropriate d.rign Case for rhis arrangement is Design Case 3a. This case is formed
giu 6O0Su 626.irP\UOE@..t 6
Knight Piisold
-v-
lvlichelle Rehmann
International Uranium (USA) Corporation
Comment 4.
Response 4:
February 12. 1999
by a hi-eh conductivity material (pure rvater) overlying the geomembrane wirh a low
conductivity layer (reworked Dakota bedrock) underlying the _geomembrane. tn rhis
case, the tiner beddin-e material acts as the controlling soil.
The UDEQ is correct that changing the assumed hydraulic conductivity tbr the Liner
bedding material would change the applicable Design Case. However, as the UDEQ
points out, the appropriate desi-en case is determined by the controlling soil. If the
UDEQ t'eels that the hydraulic conductivity of the highly compacted liner beddin,e is
greater than 105 cm/s, the low conductivity tailing overlying the liner would become
the controlling soil.
Our engineerin-e experience and the observed perform4nce of the existin,e tailin-e
underdrain indicate that this tailing is trnely -sround with resulting hydraulic
conductivities most likely well below t0'6 cm/s. This case is most appropriately
modeled by Design Case 4a. Design Case -[a is a mirror image of our modeled case
rvith a low conductivity layer (tailing) overlying the geomembrane and a high
conductivity layer (reworked Dakota bedrock) underlying the -eeomembrane. The flux
equations tbr both Design Cases 3a and 4a are identical, as are the heads on the
-geomembrane used in the tlux model. Theretbre, the Design Case used for the tlux
model is correct no matter which assumptions are used tbr the saturated hydraulic
conductivity of the tailing/bedrocUgeomembrane layers.
Derivation of the tlux model requires ftat one of the soils (ie., upper or lower) be rhe
controllin-s soil. In this case, the tlux is controlled by either the tailin-e above or the
beddin-e material beneath. Regardless of tlre assumption, the model indicates the same
tlux rate and travel time tbr both Design Cases. As such, proracted discussions with
respect to proper hydraulic conductivity estimate do not change the conclusions of our
study.
UDEQ asks for justilication as to why fracture tlow was not incorporated into the
travel time modeling.
Fracture flow was not incorporated into the tlow modeling because our review of
boring logs, pumping tests, and previous hydrogeologic repors gave no indication that
any significant fractures exist. We are aware that questions regarding bedrock
tractures have been raised in the past. Our review of available data concurs with the
conclusion reached in Titan Environmental's 1994 report titled Hydrogeologic
Evaluation of Wite Mesa Uranium Mill:
Gl! 300SiU 1526c\rp\UO€O:l.rDd
Knisht Piisold
-v-r
ivlichelle Rehmann
lnternational Urlnium (USA) Corporation
Februarv ll. t999
"lt could be postulared thar a hypothetical tracture beneath rhe wet
tailings cell rvould reduce the tirne of intrltrarion through the vadose
zone. However, no signilicant tiacture/ioinrs have been documented in
the subsurtace in the approximately 45 welrs and borings at the site. In
addition, Disposal cell No. 2 has been in operarion tbr over 14 years
with no evidence of constituents mi,grating ttrough the vadose zone."
(Titan, Page:t0)
Our intent has been to model actual conditions and not elevare the hypothetical toreality. Fracture tlow was not considered in our model because we found no basis to
believe that it exists. The UDEQ comment ret'ers ro 'sire-specitic well test data". If
UDEQ is aware of well testing that indicates tracture tlow, it would be benetjcial tbr
them to cite their reference.
It is important to reelize that minor adjustments to model assumptions do nor signilicandy change
the estimated 1.300 years required betbre any tlux tkou-eh the liner could reach the percnlO *ur-.,
zone. Changin-e model results by even a few hundred years does not negate rhe conclusion that Cell
3 overlies several layers of extremely low conductivity bedrock that severely limit the potential tbr
tailings solution to reach the perched water zone or impact the deep regional aquifer.
lve are pleased to assist you in responding to UDEQ questions reguding our modelin_e et'forrs. fu
ahva.v-s. tbel tiee to call il'you should need turther assistance.
ld,",fuL
Senior Engineer
Glt 600S1 I 6il6c\sp\UOE@.rpd
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ATTACIIMENT 8
NRC Renewal of
Source Material License
suA-1358
1+ttr
UNITED STATES
NUCLEAR REGULATORY COMMISSION
VTASH|NGTON, D.C. 2ossffi t
Ilarch 14, 1997
Hr. Harold Roberts, President
Energy Fuels Nuclear, Inc.
1515 Arapahoe Street, Suite 900
Denver, Colorado 80202
SUBJECT: RENET{AL 0F S0URCE I,IATERIAL LICENSE SUA-1358, ENERGY FUELS
NUCLEAR, INC.'S I{HITE I{ESA UM}IIUi{ I,IILL, SAN JUAI{ COUNTY, UTAH
Dear Hr. Roberts:
The U.S. Nuclear Regulatory Cormission staff has completed its review of
Energy Fuels Nuclear, Inc.'s (EFl{) license renewal appfication for Sourcel{aterial License SUA-1358, as submitted by letter dated August 23, 1991.
Additional supplements and revisions to the renewal application were provided
by letters dated Oecember 13 and 17, l99l; January 13 and April 7,1992;
July 28, October 5, and November 22, 1994; December 13, 1995; and January 30,
1997.
The liRC staff determined, in accordance with l0 CFR 51.25, that preparation of
an environmental assessment (EA) was necessary to document its review. The
l{RC staff issued an EA (Enclosure l) to the public document file on February?7,1997. Based on its analysis, the NRC staff concluded that the
environmental impacts associated with the proposed 'license action (i.e.,
renewal of SUA-1358) were not significant and that the proposed action h,as
acceptable. A final finding of no significant impact (FOI{SI) was prepared in
accordance with l0 CFR 51.32, and, on l,larch 5, 1997, published in the Federal
Reqister (Enclosure 2), providing notice of (l) the NRC's intent to issue the
proposed license amendment, (2) the availability of the EA to the public, and(3) an opportunity for hearing for affected individuals.
The NRCwith the
Parts 20
rev i ew.
staff also rev'iewed EFN's license renewal application for compliance
requirements under Tltle l0 of the Code of Federal Regulations (CFR),
and 40, and prepared a Safety Evaluation Report (SER) to document its
A copy of the SER is provided as Enclosure 3.
Therefore, pursuant to l0 CFR Part 40, Source ltlaterial License SUA-1358 is
hereby issued for the continued operation of the t{hite ilesa uranium mill.
The renewal license is provided as Enclosure 4.
l{ith this licensing action, the NRC staff will be authorizing continued mill
operations under the Performance-Based License Condition (PBLC) format.
However, EFt{ is required, under License Condition 9.4 of the renewal license,to submit its standard operating procedures (S0Ps) for implementing the Safety
and Environmental Review Panel (SERP) by Apri'l 30, 1997. EFt{ shall not
implement any provision of the PBLC until the NRC has found the proposed S0Psfor the SERP acceptable.
H. Roberts -2-
The issuance of this renewal license was discussed'in a telephone conversationon Harch 10, 1997, between l{s. l{ichelle Rehmann of your organ'ization andHr. James Park, the NRC Project l{anager for the l{hite Hesa site. In thatconversation, l,lr. Park agreed to provide EFN with a copy of revised NRCguidelines for decontamination of facilities and equipment prior tounrestricted release or license termination, wh'ich are referenced in LicenseCondition 9.10. A copy of these guidelines are provided as Enclosure 5.
If you have any questions regarding this letter or the enclosures, please
contact ilr. Park at [phone].
Si ncerely,
-J-/tz4,aJoseph d. Holonich, Chief
Uranium Recovery Branch
Divi sion of l{aste l{anagement
Off ice of Nuclear l{aterial
Safety and Safeguards
Docket No. 40-8681
License Ho. SUA-1358
Cases Closed: X60577, X5ll00
Inclosures: As stated (5)
cc u/o enclosures: l{. Sinclair, UT
Itl. Rehmann, EFH
Encl osure I
Environmental Assessmentfor Renewa'l of
Source l,lateri al Li cense No. SUA- l3SB
Energy FueIs Nuclear, Inc.llhite ilesa Uranium ilil l
San Juan County, Utah
E}IWR ONIVTENTAL ASSESSMEI\T
FOR RENEWAL OF
SOI]RCE MATERIAL LICENSE NO. SUA.135E
ENERGY FIJEI^S NUCLEAR, INC.
WIIITE MESA TJRAMTJM N{ILL
SAT{ JUAIY COI'NTY, IJTAII
FEBRUARY 1997
DOCKET NO. 40-8681
U.S. Nuclcer Rquhtory Cornmission
Oflica of Nrrleer Mrterid Sefety
and Sefeguerds
Division of lYaste Menagenrent
TABLE OF CONTENTS
Location
Climate and Weather
Geology
2.3.1 Regional Geology2.3.2 Local Geology
2.3.3 Seismicity
Water Resources
2.4.1 Surface Water
2.4.2 Groundwater
Topography
Demography
Land Use
3.0 PROCESS DESCRIPTION
Paoe
1.0 INTRODUCTION
1.1 Background lnformation1.2 Proposed Action1.3 Review Scope1.3.1 Federal and State Authorities1.3.2 Basis of NRC Review
2.O SITE DESCRIPTION
)
4
4
4
5
2.1
2.2
2.3
5
5
6
6
6I
8
8I
r0
2.4
2.5
2.6
2.7 10
10
11
11
13
4.0 EVALUATION OF ENVIRONMENTAL IMPACTS 14
3.1
3.2
4.1
4.2
4.3
4.4
4.5
4.6
4.7
Mill Circuit
Mill Waste Disposal
lntroduction
Air Ouality lmpacts
Historical and Cultural Resources
lmpacts to Water Resources
4.4.1 Surface Water lmpacts4.4.2 Groundwater lmpacts
lmpacts on Ecological Systems . . .4.5.1 Endangered Species4.5.2 Wetlands
Badiological lmpacts4.6.1 Operating Data4.6.2 Radiological Assessment
14
14
14
15
15
15
16
16
16
17
17
19
21ln-Plant Safety
1.0 INTRODUCTION
By application dated August 23, 1991, and supplements and revisions transmitted byletters dated December 13 and 17, 1991, January I3 and April 7, 1g92, Umetco MineralsCorporation (Umetco) requested renewal of Source Material License SUA-135g, forcontinuod authorization of milling activities at ths White Mesa Uranium Mill, which islocated in San Juan County, Utah. By tetter dated March 29, l gg4, Umetco requestedtransfer of the license and a change in ownership of the mill to Energy Fuels Nuctear, lnc.(EFN). On May 25, 1994, the license was am€nded to change designation of the ticenseeto EFN. ln the acquisition agreem€nt between EFN and Urn€tco, EFN agreed to abide by
all commitm€nts and repres€ntations made to tne U.S. Nuctear Regulatory Comrnission by
Umetco.
with this licanse renewal, NRC wilt be authorizing continued mill op€rations under the
Performance-Based License Condition (PBLC) format. Under performance-Based Licensing,the licensee has the burden of ensuring the proper implementation of the pBLC. Thelicensee may:
Make changes in the facility or process, as presented in the application,
Make changes in the procedures presented in the application, or
Conduct tests or experiments not presented in the application. without prior
NRC approval, if the licensee ensures that the following conditions are met:
The chang€, test, or experiment does not conflict with any
requirement specifically stated in the license {excluding material
referenced in the Performance-Based License condition), or impair the
licens€e's ability to meet all applicable NRC regulations.
TherE is no degradation in the ess€ntial safety or environmental
commitments in the license application, or provided by the approved
reclamation plan.
The chang€, t6st, or experiment is consistent with NRC's conclusions
regarding actions analyzed and selected in the EA.
otherwise, the licensee is required to submit an application for a license
amendment from NRC. The licensee's determinations whether the above conditions
are sstisfied will by made by a Safety and Environmsntal Review Panel (SERP).
The SERP shall consist of a minimum of three individuals. One member of the
SERP shall have exportaso in management and shall be responsible for managerial
and financial approval changes; one member shall have expertisa in operations
and/or construction and shall have exp€rtise in implernentation of any changes; and
one member shall be the corporate radiation safety officer or equivatent. Additional
members may be included in the SERP as appropriate, to address technical aspects
in several areas, such as health physics, surface water hydrology, specific earth
(1)
(2)
(3)
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Figure 1.1 Location of the White Mesa Uranium Mill
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1.3.2 Barb of NRC Review
The NRC, Division of Waste Management, staff has assessed the environrnental and safetyimpacts associated with the renewal of EFN's commercial ticense for the White Mesa milt,and documented th€ rssults of the assessment in this report. Tr'a staff performed thisappraisal in accordance with the requiremonts of 10 cFR part 51.
ln conducting its assessment, the staff considered the following:
lnforrnation contained in the previous €n'r'ronmontal evatuations of the White Mesaproject (i.e., the 1979 FES and the 198S EA);
lnformation contained in EFN's August 23, 1ggl, ronewal application, and
supplernentary information submitted by letters dat€d December .t3, lggl; July 29,
October 5, and November 22, 1994: and December .t3, ,l996;
lnformation contained in EFN amendment requests, NRc approvals of such
requests, and land use and environmental monitoring reports.transmitted
subsequent to August 23, 1 99 1;
Personal communications with EFN and UDEO; and
lnformation derived from NRC staff site visits and inspections of the White Mesamill site.
2.O SITE DESCRIPTION
Location
The proiect site is located in central San Juan County, Utah, approximately 9.5 km(6 miles) south of the city of Elanding. The mill can be reached by taking a private road
for approximately 0.5 miles west of Utah State Highway 19.l.
All operations to be authorized by the ren€wed license will be conducted within the
confines of the existing site boundary. The proiect site consists of 1971 hectares (ha)
.4871 acres) of private land together with mill site claims. The mill site itself occupies
approximat€ly 20 ha (50 acres) and the tailings disposal cells another 182 ha (45O acres).
2.2 Climate and Weather
Southeastsrn Utah's climate is classified as arid, with an average annual precipitation of
3O centimetsrs (cm) (12 inches), 75 percent of which falls as rain. Two separate rainfall
seasons can be distinguished in the area, with the first occurring during late summer and
early fall, and the second between the months of December and March. Ternperatures in
summ€r normally rang€ from 4'C (4O'F) to 32'C (9O'F), while winter tsmp€ratures range
between -9'C (15'Fl and 13'C (55'fl. The yearly normal moan temp€rature is 9'C(so'F).
2.1
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ERUSHY EASIN MEMEER
MEMEER
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RECAPTURE MEMEER
SALI WASH MEMEER
SUMMERVILLE FORMAIION
ENTRAOA SANDSTONE
T{AVA'O SANOSTONE
NOTE:
I IHIS DRAffNG IS NOT TO SCALE.
2. ALL IHICKNESSES ARE APPROXIM^TE
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(after Titan, 1994b)
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The underlying Burro Canyon Formation L simitar to the Dakota Sandstone. Composed ofvery fine- to coarse-grained sandstones, with discontinuous random shales, the BurroCanyon becomes argillaceous near its lower contact with the bentonitic mudstones andclaystones of the Brushy Basin Member (Morrison Formation). Beneath the site,groundwater is first encountered at this contact as a zone of perched water. This zoneoccurs at depths of 22 to 33 m (73 to 109 feet) below the surface, and its thicknessvaries across the project area, trom l7 m (55 feet) in the northern section to less than1.5 m (5 feet) in the southern area. Potentiometric maps suggest that the predominantdirection of groundwater flow in the saturatsd portion of the Burro Canyon Formationbeneath the site is to the south-southwest (Titan. 1gg4b).
The Eurro Canyon outcrops along the walls of Westwater Creek Canyon and CorralCanyon, and groundwater from the perched zone discharges into these canyons, asevidencsd by the occurrance of springs and productive vegetation patterns. Based on theresults of 12 pumping/recovery tests and 30 packar t€sts, tha hydraulic conductivity ofthe saturated portion of the Burro Canyon Formation ranges from I.4E-06 to l.2E-O3cm/sec, with a geometric mean of 1.0E-05 cm/sec (Titan, l gg4b). Water yields at thetest wells were very low, typically less than 0.5 gallons per minute (gpm), althoughslightly higher yields {on the order of 2 gpm) may be possible in locatized zon€s oi trigr'erpermeability, resulting from lenses of coarser material or localized fracturing.
The quality of the Burro Canyon perched water beneath and downgradient from the site ispoor and extremely variable. The conuentrations of total dissolved solids (TDS) measuredin water sampled from upgradient and downgradient wells rang€ between approximately1000 and 5ooo milligrams per liter (mg/l). Sulfate concentrations measured in threeupgradient wells varied between 670 and 1740 mg/.
As stated above. the Brushy Basin Member of the Morrison Forrnation is composed ofbentonitic mudstones and claystones. ln the region, the thickness of this unit ranges from60 to 135 m (200 to 450 feet). A total of approximately 365 m (1200 feet) ofunsaturated, low permeability shales and poorly sorted sands of the Morrison andSummerville Formations separate the Brushy Basin from the underlying Entrada and NavajoSandstones.
The Entrada and Navaio Sandstones are prolific aquifers beneath and in the vicinity of thesite. Water wells at ths site are screened in both of these units, and therefore, for thepurposss of this discussion, they will b6 treated as a single aquifer. Water in theEntrada/Navaio Aquifer is under artesian pressur€, rising 24S to 275 m (8OO to 9O0 feet)above th€ top of the Entrada's contact with the overlying Summerville Formation; staticwat€r levels are l2O to 150 m (4OO to 5OO feet) below ground surface. Within the region,the aquifer is capable of yielding domestic quality wat€r at rates of 150 to 225 gpm, ai-ldfor that reason, it serves as the source of water for the mill. Additionally, two domesticwater supply wells drawing from the Entrada/Navajo Aquifer arg located 4.5 milessouth€ast of the mill site on th€ Ute lndian Reservation.
I
Table 2.1
Population centers within 60 Kilometers of the white Mesa Mill Site(modified from Umetco, t99l)
Distance from Distance fromTown 1gg0 popuration site (km)' site (mires)
Whito Mesa, UT
{unincorporated}
320?6.4 4
Blanding, UT 31 62 9.5 6
Bluff, UT 847 25 15
Montezuma Creek, UT 1223 32 20
Monticello, UT 1 806 43 27
Anath, UT 991 43 27
Mexican Hat, UT 495 48 30
Eastland/Ucolo, UT 249 51 32
Dove Creek, CO 623 59 37
Approximetc dirt.nc. lrom nrill ritc by ir
Approximata population
3.0 PBOCESS DESCRIPTION
A simplified flow diagram of the White Mesa mill circuit is provided as Figure 3.1.
3.1 Mill Circuit
Ore and other feed material is delivered to the site by truck. Once at the site, followingweighing of the truck, an ore load is dumped at a specific location on th€ ore pad.
Preliminary analyses 8re th€n conduct€d, and the moisturo contsnt of the or€ d€termin€d.Loaders or trucks then haul stockpiled ors to the ore grizzly.
A semi-autog€nous grinding (SAG) mill is used to grind the or€, and the resultant slurry ispumped to two mechanically-agitated storage tanks. Materiat from thesa tanks is pumpedto a two'stage acid leach process, in which sulfuric acid, an oxidant, and steam are usedto l€ach the ore slurry.
Next, a multi-staged counter-current decantation (CCD) washing circuit is employed tos€parat€ the strong acid liquor and wash the teached residue. During each CdO staga,solid particles settle to the bottom of the thickener tank, leaving a clirified uranium-6earingsolution at th€ top. This solution is transferred "up-stage," whire the same process ofdecantation takes place. Overftow from the top (i.e., the first) CCD thickener tank is sentto the two-stags leach process mentioned above, the overflow of which is clarified prior to
t1
solvsnt extraction. The slurry at th€ bottom of the tank is progressively transferred"down" the circuit. From the final thickener tank, it is sampled and then pumped to thetailings rot€ntion area.
Meanwhile, the uranium-bearing liquid is transferred to a solvent extraction process whichis carried out in a series of mixing and settling vessels. Amine-typ€ compounds andkerosene are added to dissolve the uranyl ioni from the leach soh.rtion. The sotution isthen stripped of uranium by acidification and pumped to a precipitation tank.
lVithin the precipitation tank, th€ pregnant solution is neutralized and yellowcake is settled.The yellowcake is n€xt transferred to a csntrifuge wher€ it is further concentrated. The
thickened yellowcake slurry is transfsrred to either of two propan€ gas/diesel-fired
multiple-hearth dry€rs. Both dryers feed to 8 common packaging hopper and drum fillingstation, where the dried yellowcake is powdered and packaged in Ss-gallon drums.
These drying, powdering, and packaging operations are perforrned within an enclosureunder negative pressure, with wet scrubbers used to collect airborne particulates. Duringthe entire route of production, concrete curbing and sumps are designed to intercept anyspillage and return it to the appropriate process crrcuit.
3.2 Mill Waste Disoosal
Mill tailings are deposited within tailings cells located at the facility. The tailings, alongwith liquid wast€, are slurried by pipeline to th€ impoundment system, which consists of aseries of synthetically-lined cells that are designed for phased construction andreclamation. Cells are presently designated 1-1,2,3, and 44 (th€ higher the number rafersto the more recently constructed cell).
The four tailings cells are designed to accepr the quantity of waste to be produced duringa 1 S-year op€rating period, at an ore processing rate of 2OOO tons per day. The tailings
and evaporation cells are designed and constructed as partially below-grade disposalfacilities. Any change in the maximum op€rational freeboard and tonnage limits for the
cells, as specified in the renewal application, will continu€ to require NRC approval due to
the safety and environmental conc€rns involved. EFN also implements procedures to
minimize dispersal of blowing tailings.
Each cell has a leak detection system designed to provide an early warning of catastrophicliner failure. These syst€ms are checked daily as part of the tailings disposal systemmonitoring program, which also includes checks oo slurry pipeline connections and wear,
cell fluid levels, liner integrity, and the effectiv€n€ss of dust minimization mothods. Each
tailings cell embankment is also regularly monitored for stability and the results r€port€d toNRC. Tailings Cell 4A was designed, constructed, and placed into operation in 1ggO,
according to an NRC-approved plan and in accordance with U.S. Environmental Protection
Agency (EPA) regulations.
As stated.above, alt production spillag€ or wastes, such as tailings and process water, areeither returned to th€ mill circuit or s€nt by pipeline to the appropriate tailings
impoundment, while sanitary wastes are disposed of separately in a State-approved
13
The requir€ments were incorporated into SUA-1358 when initially issued. Therequirem€nts have been modified following subsequ€nt amendments to th€ MOA. Themost recent modifications wsre incorporated into SUA-13S8 through the issuance of alicense amendment on May 1 1, 1983. These requirements will be included in the renewedlicense.
The licensee will also be required to conduct, as a minimum, an archaeological andhistorical artifact survey of areas not previously surveyed prior to their disturbance.
4.4 lmoacts to Water Resources
4.4.1 Surfaco Wrtcr lmpactt
Continued operation of the mill should have negligible impacts on surface waters on and inthe vicinity of the project site, because (1) mitlLfiluents are not discharged to local surfacewatsrs; (2) sanitary wastos are discharged to State-approved leach fieldl; and (3) tailingsfrom mill op€rations are discharged by pipeline to partially below-grade, linedimpoundments. ln addition. rs noted above, EFN has committed io regular inspections ofthe tailings disposal syst€m, including disposal c€rl embankments.
4.4.2 Groundwater lmpacts
For the following reasons, the NRC staff does not believe that groundwater beneath or inthe vicinity of the site will be adversely impacted by continued operation of the mill:
1. Four tailings cell have been constructod to accept tailings slurry and solutions andother approved wastos. Each of the cells has been designed and constructed tominimize seepage of tailings fluids into the subsurface. tells 1i,2, and 3 have a6-inch compacted sandstone bedding layer, an overlying synthotic liner, and a leakdetection syst€m consisting of: (11a 12-inch thick compacted sand layer on theupstrearn face of the downstr€am retention dike, (2) a 3-inch diameter perforatedpipe installed at th€ to€ of the sand layer, and connecting to (3) a l2-inch diameteraccess riser pipe.
Cell 4A is constructed with a 12-inch thick clay base layer overlain by a syntheticliner covering both the bottom and side slopes of the cell. A leak detection systemis located beneath the synthetic liner. This system is composed of 4-inchperforated pip€s embedded in granular materials in synthetically-lined trenchesexcavtted into the clay base. These pipes ar€ connected in turn to a l2-inchdiameter access pipe.
As patt of EFN's inspection procedures for the tailings manag€m€nt syst€m, dailymeasuroments aro taken of liquid levels in the leak detection system for each cell.lf specific changes in these levels are recorded, site manag€m€nt is notifiedimmediately. Quarterly sampling of a number of monitor wells completed in theBwro Canyon perched water zone and located around and among the tailings cells,is also required by EFN's inspection procedures. Fufther discussion of thelicensee's groundwater detection monitoring program is provided in Section 4.6..l.
15
a.
4.6 Badiolooicallmoacts
4.6.1 Opcrating Data
Sampling results discussed in this ssction w€re provided by the licensee in accordance
with the requirements of 10 CFR 40.65, as modified by license conditions currently in
SUA-1358. The renewal license will retain these sam6 license conditions, which address:
(1) stack sampling, (2) surface water sampling, (3) groundwater sampling, (4) lower limits
of detection, and (5) inspections and calibrations of the critical orifice assembly.
Air Particulate Sampling
EFN's air particulate monitoring program consists of continuous environmental
sampling stations at four locations, three of which are located at tho site boundary,
and one at th€ n€ar€st residence, which is 5 km (3 miles) northeast of the site.
Samples are collected quarterly and analyzed for U-nat. Th-23O, Ra-226, and
Pb-210.
Data collected during continuous mill operations in 1989-90. and again in 1995-96,
indicatad that measured concentrations of U-nat, Th-230, Ra-226, and Pb-210
were small fractions (i.e., lessthan ten p€rc€nt) cf the appropriate 1O CFR Part20
limits for unrastricted areas. C,.)ncentrations of these.radionuclides measured at the
BHV-S sampling station tended to be elevated during mill operations due to
increased dust from the ore stockpile and the increased traffic around the ore
stockpile and mill areas. .
Stack Effluent Sampling
During operations, stack sampling is performed quarterly on the yellowcako stacks
(i.e., the dryer and baghouse stacksl and semi-annually on th€ grizzly and demister
stacks. Stack samples are analyzed for U-nat, Th-23O, Ra-226, and Pb-210.
Measurements performed in 1989 and 1995-96 indicate that emissions of these
radionuclides have been consistently low. ln addition, m€asur€rnents of product
loss through the yellowcake stacks have been well below levels originally predicted
in the FES for the facility (NRC, 19791.
Radon Gas Monitoring
Environmental monitoring for radon gas using thermoluminescent dosimeters ffLDs)
was discontinrrd with NRC approval in September 1995. The licensse will
demonstrate compliance with the 1O CFH Part 2O annual dose limit of 1OO mrem
through MILDOS-AREA modeling calculations..
The licensee will still b€ required to keep rcdon-222 emissions from an existing mill
taalings pile from exceeding 2O pCi/m2-s of radon-222, in accordance with the
requirements of 40 CFR 61.252.
17
sampling program. lf the data are significantly different, then a corrective actronplan will be developed.
The NRC staff found the proposed groundwater detection monitoring program to beacceptable, with modifications as follows: (1) that well wMMw-17 be included inthe sampling program; and Ql that uranium be added as an indicator parameter tobe analyzed for. EFN agreed to these modifications in a telephone conversation onDecember 1 1, 1996. EFN will be required, by ticense condition, to conduct itsgroundwater detection monitoring in accordance with the proposed program, asmodified.
Finally, the licensee will continu€ to be required to {l ) analyze liquid found in theleak detection system during weekty inspections for specified constituents;(2) conduct statistical analyses to d€termine if significant linear trends exist, and(3) propos€ corr€ctivs action for NRC review and approval if such trends do exist.
4.6.2 Radiological Assessment
a. Offsite lmpacts
The radiological impacts from milling operations at the white Mesa site have beenassessed previously and documented in the FES (NRc, 1g79) and ihe l ggs EA(NRC' 1985a)' ln the previous EA, tne staff analyzed impacts associated withmilling at a nominal rate of 2o0o tons of ote ger day, and an average ore grade of0.50 percent, for a yeilowcake production rate of 43go tons per year, anddetermined that both site boundary radionuclide concentrations and individual dosecommitments were smart fractions of the appricabre standards.
As part of its November 22, 1994, amendment request for authorization to install asecond dryer, EFN provided updated MlLDos-AREA calculations and results. lnapproving EFN's r€quest, the NRC staff determined, based on its review of theMlLDos-AREA results, that releases from the mill would not result in a member ofthe public receiving a radiation dose in excess of the 1o cFR part 20 limit (i.e.,I OO mrem per year).
It should be noted that actual radiation doses to the public will likety be less thanmodeled, because EFN normally processes lower grade ores, at a iate less than2000 tons of ore per day.
b. Badiological lmpact on Biota Other than Humans
Although no guidelines concerning acceptable limits of radiation exposure havebeen established for the protection of species other than man, it is generally agreedthat the limits for humans are also conservative for oth€r species. Doses fromgas€ous effluents to terrestrial biota (such as birds and mammals) are quite similarto those calculated for man and arise from the same dispersion pathways andconsiderations. Eecause the ef{luents of the facility will be monitored and
19
4.7
maintained within safe radiological protection limits for rnan, no adverse radiological
impact is expected for resident animals.
ln-Plant Safetv
The licensee has established and conducts an in-plant safety and radiation safety program'
EFN stated that the in-plant safety program meets the requirements of the Mine Safety and
Health Administration (MSHA), as well as those p€rtin€nt requiremants of the Occupational
Safety and Health Administration (OSHA). The licensoe's op€ration is based on good
safe;y practices and procedures. During mill ofrrations, EFN has a full-time safety official
on staff to me€t all safety requirements established by Federal regulations. During routine
radiation safety inspections, NRC, to th€ best of its ability, observes in-plant industrial
safety for deficiencies and brings any identified deficiencies to the attention of plant
managem€nt.
NRC, throtigh 1O CFR Part 20 and license conditions, requires a radiological safety
program that contains the basic elements needed to assure that exposures are kept low or,
in any event, as low as is reasonably achievable (ALARA). Therefore, an in'plant radiation
safety program including the following is required:
Oualified management of the radiation safety proEram and appropriate t, rrning of
personnel;
Written radiation procedures;
Airborne and surface contamination sampling and monitoring;
lnternal and external radiation monitoring programs;
An approved respiratory protection program; and
An annual ALARA audit and frequent in-house inspections.
NRC considers the program of in-plant safety, as required by Federal regulations, and the
radiation safety program as defined by 1O CFR Part 2O to be sulficient to protect the
worker during normat op€rations. The NRC evaluation of the licensee's radiation safety
program is discussed more fully in the SER.
5.O ENVIRONMENTAL EFFECTS OF ACCIDENTS
5.1 Failure of Chemical Storaoe Tanks
At th€ mill, tanks are used to storo a variety of industrial chemicals, process fluids, and
slurries, as well as flammable liquids. Various systems have been implemented to contain
or direct routine or unplanned spillage. Tanks which are most likely to overflow are
equipped with high-level atarms to reduco the possibility of spillage due to tank overflow.
Spills'resulting from the failure of any chemical holding tank would first be contained by
engineered dikes or curbs. lf th€ volume was too great, such as that from a rupture in one
21
6.0 RECTAMATIOT{ AND DECOMMISSIONING
Following financial difficulties in February 1995, EFN agreed to voluntarily revise its surety
amount to cov€r reclamation and decommissioning costs for the site in its current state.
EFN is pursuing this action in two phases, with the first having been completed in June
1995 with NRC's approval of a revised surety amount of approximately $10.5 million. ln
this initial phaso, EFN reviewed all major reclamation cost centers, considering the then
current level of development and disturbanco at the sit€. ln the second phase, EFN is
reviewing all elements of the site reclamation plan and will, if necessary, revise the earlier
cost €stimate.
The licens€e is exp€cted to submit the revised site reclamation plan in early t 997 for NRC
revi€w and approval.. NRC will review th€ plan in accordance with the requirements of
1O CFR Part 40, Appendix A, and applicable staff guidance documents. Because NRC has
yot to receive the reclamation plan, EFN will be required by license condition to provide
the plan to NBC by June 30, 1997, for its review and approval in the form of a license
amendment.
Site decommissioning will be conducted under a plan approved by NRC. EFN will be
required by license condition to submit a detailed decommissioning plan to NRC for
approval at least 12 months prior to.the planned final shutdown of mill operations.
7.O ALTERHATIVES
The action under consideration is the renewal of Source Material License SUA-1358, for
continued op€ration of the White Mesa mill, as requested by EFN. The alternativ€s
available to NRC are to:
(1) Renew the license with such conditions as are considered n€cessary or
appropriato to protsct public health and safety and the environment; or
(2) Deny renewal of the license.
Based on its review of the information identified in Section 1.3.2, the NRC staff has
concluded that th€ environmental impacts associated with tho proposed action do not
warrant denial of the license rsn€wal. lt is th€ staff's conclusion that th€ impacts
associated with the license renewal are within the realm of impacts anticipsted in the FES
(NRC, 19791 and the previous EA (NRC, 1985). Additionally, in the SER prepared for this
action, the staff har reviewed the licensee's proposed action with respect to tho criteria
for license issuance specilied in 10 CFR Part 4O, Section 40.32, and has no basis for
denial of the propolr€d action.
8.0 FI]IIANCIAL SURETY
Under 1O CFR part aO, Appendix A, Criterion 9, licenso€s ars required to establish a
financial sur€ty ad€quat€ to covor the estimated costs for (1) decommissioning and
decontamination of the mill and mill site, (2) reclamation of any tailings or waste disposal
ar68s, (3) ground wator restoration, as warranted, and (4) the long-term surveillance fee.
23
1O.O FIilDING OF NO SIGNIFICANT IMPACT
EFN has applied to NRC to rsnew Source Material License SUA-1358 to authorize
continu€d op€rations Et th€ White Mesa uranium mill. located in San Juan County, Utah.
NFC has reexamined actual and potential environmental impacts associated with
yellowcake production at ths rnill site, and has determined that renewal of the source
material license (1) will be consistent with requirements of t0 CFR Part40, (2) will not be
inimical to the public health and safety, and (3) will not hava long-term detrimental impacts
on the environment.
Therefore, based on an evaluation of EFN's renewal request, the NRC staff has determined
that ths prop€r action is to issue a FONSI in the Federal Register. The following
statements support the FONSI and summarize the conclusions r€sulting from the staff's
environmental ass€ssmont:
An acceptable environmental sampling program is in place to monitor effluent
releasas and to datect exceedances of appropriate limits;
. The licensee has implemented an intensive, routin€ inspection program of the mill
process building, associated facilities, and tailings retentlon impoundments, and
conducts an annual ALARA audit program;
. Standard op€rating procedures are in place for all operational process activities
involving radioactive materials that ar6 handled, processed, or stored;
. Mill tailings and process liquid effluents from the mill circuit are discharged to
partially below-grade, lined tailings impoundments, with leak detection systems;
. The licensee will implem€nt an acceptable groundwater detection monitoring
program to €nsur€ compliance with the requirements of 10 CFR Part 4O,
Appendix A;
. The licensee will conduct sita decommissioning and reclamation activities in
accordance with NRC-approved plans; and
. Becaus€ tho staff has determined that there will be no significant impacts
associated with approval of ths licenso r€n€wal, there can be no disproportionately
high and adverse effects or impacts on minority and low-incorne populations.
Conseqtrently, lurther svaluation of 'Environmental Justice' concerns, as outlined in
Executive Order 12898 and NRC's Ollice of Nuclear Material Safety and
Safeguards Policy and Procedures Letter 1-50, Rev.1, is not warranted.
Based on th€se findings, the NRC staff recommends that EFN's license for yellowcake
production at the White Mesa uranium mill bs renewed. The source material license shall
be based upon the licensee's renewal application, this EA, th€ SER, and the license
conditions which address environmental issues (see Section 1 1). License conditions
addressing radiation safety concerns can be found in the SER.
25
disciplines. Temporary members or p€rmanent members, other than the
thr€€ above-specified individuals, rnay be consultants'
D. The licensee shall maintain records ^f any changes made pursuant to this
condition until license termination. These records shall include written
safety and environmental evaluations, mad€ by the SERP, that provide the
basis for determining changes are in compliance with the requirements
referred to in Part B of this condition. The licensee shall furnish, in an
annual report to NRC, a description of such changes, tests, or experiments,
including a summary of the safetv and environmental evaluation of each. ln
addition, the ticensee shall annually submit to the NRC changed pages to the
Operations Plan and Reclamation Plan of the approved license application to
reflect changes made under this condition.
The licensee shall submit to NRC by March 31, 1997, for review, the standard
operating procedures (SOPs) needed to impl€m€nt this license condition. The
licensee shall not implement any provision of this license condition until NRC has
found the proposed SOPs acceptable.
Standard operating procedures (SOPs) shall be established and followed for all
op€rational process activities involving radioactive matarials that are handled,
processed, or stored. SOPs for operational activities shall enumerate pertinent
iadiation safety practices to be followed. Additionally, written procedures shall be
established for non-op€rational 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 RSO before implementation and whenever
a change in procedure is proposed to €nsuro that proper radiation prot€ction
principles are being applied. ln addition, the RSO shall perform a documented
revi€w of all existing operating procedures at least annually.
Before engaging in any activitY not previously assessed by the NRC, the licensee
shalt administer a cultural resourco inventory. All disturbanc€s associat€d with the
proposed development will be completsd in compliance with the National Historic
preservation Act (as amended) and its implementing regulations (36 CFR 800), and
the Archaeological Resources Protection Act (as amended) and its implementing
regulations (43 CFR 7).
ln order to €nsuro that no unapprov€d disturbance of cultural r€Sourcos occurs, anY
work resulting in the discovery of previously unknown cultural artifacts shall cease'
The artifacts stratt be inventoried and evaluated in accordance with
36 CFR part 8OO, and no disturbance shatl occur until th€ licensee has received
authorization from the NRC to proceed.
The licensee shall avoid by proiect design, where feasible, the archeological sites
designated 'contributing' in the report, "Archeological Sites Related to tho White
27
11.
surety. The revised surety shall then be in effect within 3 months of written NRC
approval.
Annual updates to th6 surety amount, required by 10 CFR 40, Appendix A, Criteria
9 and 1O, shall be submitted to NRC at least 3 months prior to the anniversary date
which is designated as June 4 of each year. lf NBC has not approved a proposed
revision to the surety coverage 30 days prior to the expiration data of the existing
surety arrangem€nt, th6 licensee shall extend the existing surety arrangement for
1 year. Along with each proposed revision or annual update, the licensee shall
sttbmit supporting documentation showing a breakdown of the costs and the basis
for the cost estimates with adiustmonts for inflation, maintenance of a minimum
15 percent contingency fee, changes in engineering plans, activiti€s performed and
any oth€r conditions affecting estimated costs for site closure. The basis for the
cost estimate is the NRc-approved reclamation/decornmissioning plan or NRC-
approved revisions to the plan. The previously provided guidance entitled
'Recommended Outline for Site Specific Reclamation and Stabilization Cost
Estimatss' outlines the minimum considerations used by NRC in the review of site
closure estimates. Reclamation/decommissioning plans and annual updates should
follow this outline
The currently approved surety instrument, lrr€vocable Letter of Credit No.
SOOO17O12, issued byThe Bank of New York in favor of ttFC, as amended, May
1O, 1994, to include a Standby Trust Agreement, shall be continuously maintained
by UMETCO in an amount not less than S10,915,467 for the purpose of complying
with 1O CFR 40, Appendix A, Criteria 9 and 10, until a replacement is authorized
by NRC.
Disposal of material and equipment generated at the mill site shall be conducted as
described in the licensee's submittals dated December 12, 1994 and May 23,
1995, with the following addirion:
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 equiprnent, such as a Cat D-6, at
least 4 times praor to placement of subsequ€nt lifts.
The licensee shatl subrnit a detailed decommissi6ning plan to th€ NRC at l€ast
twelve ( 1 2) months prior to planned final shutdown of mill operations.
The license€ shall submit to NRC for review. by June 30, 1997, a detailed
reclamation plan for the authorized tailings disposal area which includes the
following:
A post-operations interim stabilization plan which details rn€thods to prevent
wind and wat€r erosion and recharge of the tailings area.
A plan to determine the best methodology to dewater andlor consolidate the
tailings cells prior to placement of the final reclamation cover.
A.
29
Uranium Mill," submitted by letter dated October 5, '1994, as modified by the
following:
The leak detection system for all oonds will be checked weekly. lf liquid is
present, it shall be analyzed for chloride, sulfate, selenium, and pH. The
samples will be statistically analyzed to determine if significant linear trends
exist, and the results will be submrtted to NRC for review.
lf a significant lin€ar trend is indicated, tha licensee will submit a proposed
corrective action for review snd aoproval to NRC. The corrective action shall
include a discussion on delineation of the areal ext€nt and concentration of
hazardous constituents.
The licensee shall sample monitoring wells WMMW-S , -11 , -12, '14, '15,
and -17, on a quartsrly 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 1O CFR 40.65.
REFERENCES
Titan Environmental Corporation [Titanl, '1994a, "Points of Compliance, White Mesa
Uranium Mill," prepared f or Energy Fuels Nuclear, lnc., September 1994.
Titan, 19946, "Hydrogeologic Evaluation of White Mesa Uranium Mill," prepared for
Energy Fuels Nuclear, lnc., July 1994.
Umetco Minerals Corporation, 1991,'1991 White Mesa Mill License Renewal," 4 vols.,
August 1991.
U.S. Nuclear Regulatory Commission INRCI, 1988,'Bioassays at Uranium Mills," NRC
Regulatory Guide 8.22, Rev. 1, August 1988.
NRC, 1985a, 'United States Nuclear Rogulatory Commission Environmental Assessment
Prepared by the Uranium Recovery Field Office in Consideration of the Renewal of Source
Material Licensa SUA-1358 for the Umetco Minerals Corporation White Mesa Uranium
Mill," issued September 26,1985.
NRC, 1985b, 'safety Evaluation Report for Umetco Minerals Corporation White Mesa
Uranium Mill, License SUA-1358, Docket No.40-8681," issued September 26, 1985.
NRC, 1983,'Hydrologic Design Criteria For Tailings Retention System," NRC Staff
Technical Position WM-82O1, January 1983.
NRC, 1980a, "Operational lnspection and Surveillance of Embankment Retention Systems
for Uranium Mill Tailings,' NRC Regulatory Guide 3.11.1, October 1980.
A.
B.
31
Encl osure 2
Federal Reqister Notice:
Finding of No Significant Impact
Notice of Opportunity for Hearing
(62 FR 10091; l,larch 5, 1997)
Federal Re :r Vol. 62. No. -tl t,f'.<jr.,-'Sdav. \t i 1Qq- \(ltlces 100,
Burldr.rq. 3ll0 L Streer. N\V . must provide sufficrent informatron lo comment of rts proposed frndrng of nt
1y65h,^groa. DC, aod at the local public sbow'rhat a Beourne disoute ex-tsts-wrt-h srgnrEcant hazards coosidemtroo in
Cocume"nt room located at t-he Osterhout the apolicani on a matenal issue of law accordance *'ith l0 CFR 50.91 and
Free Ubrar.v. Reference Department. 71 or fa&. Contentions shall be licrited to 50.92.
Souuh Frarrirlin Street. lVrlkes-Barre, mart;;;tfi lbe scope of the For fu,rthet details witb respect to tJ
iemsylvania. lf a request for a beaiing amendmeot ulder coosrderatioo. The actioo. see the.app.li-cation for
-or petitioo for leave tb intervene is file-d contention must be one'vhich. if amendments dated Februar-v 11, 1997
by'}e above date, the Commission or an proven, wouid entitle t-he petitioner to whicb is available folpublic-iospeai
Aiomic Safetv and Licensing Board, LU"f. A petitioner who fails to file sucb at the Commission's Public Documen
clesipated b1: :he Commissiio oiUy tU" a suppiefuent which satisEes these Room' the G"h|! BuildinS. 2120 L
Chdlman of Ge Atomic Safety and' ."q,r'ii"-"ot" with respect to at leost oae Street. NW" lVashingtoo. DC. and at t
Liceosing Board Pa.oel, wlll rule on t-he contention wiir not be'permittcd to local public danrncnt rooo lantod r
rqu€c.id/or petition: and thc participate a! r party. - thc Osterhout fry" Hblty..fgfcrcnceS"*"t ry o. thddoigo"ted ,l,tooic ' Thoir poraitiod to i.aterreno becooe DaPartEoot. 71 South Fnallia Street
S.Isty a;d Ucenring"Boad *iU i"""" a pertiec to rhe prrcading. aubiect-to aly hlilb.B.rr. hnrylvaaie-
noticc of hcrring c-ra rppropdete [i-i66ss3 ia-tbo ordor grantiag lcavc to ILrd u RocHllr, llryhrd. thir 2sthordr. intervene, and bave the opponuaity to of F.b$rry 1997.
As required by 10 CFR 2.774, s participate fully in the conduct of the Fo' thc Nuclcgr Rcguletory Coromirrioa
petition for leeve to intorvo!€ rhell set hearing iacludiag tho opportunity to I.b l. s-t&
lorth with particulrrity the iatcroet of Prtsaut svidsacs and cross+xa.mine 'Dir-,-tot, pt',*it Di.tomtc tr-2. Divbion o
tha pdtioner in ths procaeding, and wilaeccca Aaalr Ar,iic,g--.t/E, Afia ol Nuclear
bow tbet i.utrElt oai, te rffctid by the A ruquecl for a herinS or. a petition . -iian Arjnt"U"".r nlt! of tie proceeding. The petition for leave to intewene must be Eled.with tFR Doc 97-5399 Frlcd t-<-gz: S:,tS arnl
elrould rpcaE:crlly explrl' tbs- rqroo.r the Secretary of the Coogueeion" U.S. ..r-- o- ,D.r,why iatcivotioa itorild bc pormittcd Nudan Regule_ tory Comnisdon
with prrdctrlar *e."oo' i;,fl*'* *'Ju"*t;;. eqi6rsss+oor. a1i""uo
followiag hctor:: (1) Tbe uature of the [locleting and Servlces Bralch,.or tDoc*rt 1lo. 'lo-Strl
ihc pm&edia$ aod (3) the possible duriag th1 lrrt 1O dayrof ths oodcal sJrAfi: Tbo U.S. Nudcu.Rrguletor
of,ta of aay order which Ety bo period, it it l6qu6.tcd th.t trrt Pltruo.ocr Conmtdo (NRC) propc to ttEor
ffiH"ffill?ffi#!:',"" miffirf':?ffi;i" ffi[ ffi*t ffiIffi,H *'uatnre ald ixteot ofthe petitiineis 2720Lstreet, l{W., Washington, Dl
proPoIty, finrnciat. or ot[er intorest in tl'e abovc d€to. Whfr€ Fqtition^a arc ol OpportliltY lor ]trrlng
duriog thc lut 1o daya of tho r
p€riod, it is rrquo.tcd tbrt thc
oromotlv rc inlqa th. C@rmtsmd in ibo proodin3 oo tUc -propply rc-iafSrm thc.,99T*i*m by FIRC Sar.". *ein L[6E SUA-1
pcddoodr h&!d" Tha-poddo rhould I tollta tc-bPh@ c+l^P Y"$a to *rthslzr thr ltcou. ED*ST tu
iUo ia-trv tbr rpctnc irpa(r) of tba Uulou .r l{Un) 241{1m (ll },flml }hrclrr. ln EfN}, hr qttnrod
arbirt E lir of tL pruittng rr to f-(am) 3{247m). Thr lYodrn Uuloo {Gdo of thr lllbltc Ir
*hrch pddor wf.sr to toti'vuo. opcrtrrbouldb.-d"* g1!9.P. qrufunutll'bcltcd rr Blrdlng
Anl gdrrou who h- ilad r pcddou fc liladncrdm ltunbr Nlorr -4.b_ utrb- Al ht|ronorrl Aretai'j to btcvqr or wbo U.. Uo, foUowing E .tlt! rddread to loha F' wrr prbrord by tb NRC ilrtr ttr
6rlni316{ .r r party uury a.uond thc StoE: pcBfioode nrnc rad q!-.p.U*. " - .c."i{.n"" with-thc rcqutrcrnontr o
pctitiou withdut rlN;dry lavc of the nuobcr: drtc pcdtion wrr mailcd: pLent Cff, p"rt 31. Tho coucluriou of the
iloard up to 15 dayi prior i'o ths Erst uane; end putlica-dou.deto.aad pagc Envimomcotel AsrGrsl[Gnt is a Finrp-irilrirt contraria& Eb.dul.d iD rb urub.rr e[ ihir Fcdar. f"4TT noticc- of No Slpiicrat f'opGr (FONSI) fc'p.o*dra but ruch en ruodad A copy of thraodEou rhould drc b. p-po..f, llcaniq aaioo-
lctitioa m-nn retirfy thc rpaafr*y t.ot io &. OGc! of tbr Gcrnl iil'fffrer Fil .rU COIT Cnffi ',.i*ffi L',iffi_offi Er*'m*,m*'sm----;9"
pnhrriag coutracr'rbrdufa u Ac q,ol. .Dd to lry silh3 -Equin.-s}:, ;iit-e'i--:;:;tOO"l U r.tffi*;t'ffiHflnl,- Iffi;Sffi " Hmffi#ieffi:rr[iLh nur trchr& r ltrt of thr ruorrv h rb. ltcan ril __ L w-t6Aoi O.C. iosss. Tclqhccootmdorrfirclrnroghttob. - NmdmclyiltDttofpcUUor-S lliiirs.or}e.UdSlt d tu tbr nrttc. Eri cmfradou liv. to intrwcm. JrGEd(r. PcutroDl.;E"..dd"hrp"d!"ratonrof . mpploatrlpcdttootrnd/c el??1.gfAf,fltmAlE':
the irsur of trrw or'hd to bc rrirrd or for h::11t--t!,11I_T*T.d Boc5roundcoutrovcrtcd. h edddon. thc pctidoncr abcsnt a daaoination-bv thc
shall providc a briet explanetloa of thc C.-;;i;;;tf" t1t-iaiig-"tE*r or the -..-t:.t* Materid Licensc SUA-1
Htritff*rtrrHft ffils*"#ilffi- riffiqs6ptnrm whtch -ppd,.t tr, comoiio th""ld b" g."th b.-d;P""; ' rcaonl naultour (1o cR)' Pn
ard o whlch th. pd6ou ioroar to ti.iEfr ifiltcr-t-.fra14 p ro HF.d" Ucadue of Sourca Mr
16ryi"gr-rr"gth"-"mt".uo.rtt" ffiriiXr-Xrl6."[azra(a]-- Thbltorqulattyruthcizar
LCri"d-n Eauo*Euadrc -n-;'"d;iiilti6"'i"si"'"5ii"a. ltl]t#EffiH;ffi#,*;rovtt;H;; rh-" rp..{n" thc Cooioilon'r nrtr uiv i.ar tb. urrE
sourrccr end doc1rncutr o[ whlch the emcndmmtr ettc it .o-pia"l itt roi\ (2) Dfl.a PyPrducl Eato
po6donr b rwrrc rnd on whlch thc t*f"i".f -"i." ena p'riit to iha tUf icii of unnirio wrctc trili!
'p;nn;; L6n& io ."fi t" *t UUih co'r,Flerlon of an- y rcqutrcd bcrria- --s iI it othcr unaium byprodrct waste
rhua hctr or oxp€rt opinlou. pctitroucr ;fifi;b-; uttli,i"itioi* p"Uu-" gposntod by opcntionr at the u
!ederal Keqster Y Ot. oi. .\r) iJ
Ll .:ilo:!tor: .u ffie€tlo! o(!er
apnlrcable requirements of 10 CFR Part
2 o[ the Commrssioo s regulauous. a
request for a hearing filed bv I Person
other tban an applicant must describe in
detail:(llThe interest of the requestor in the
proceeding;' (2) How-that ioterest may be affected
by the results of the proceeding,
including the reasons why the requestor
shn"ld bc permitted a hearing, witb
particular referencu to the factors set --.in 5 2.1205(g);
(3) the requestor's eMs of concem
about the licensing activity that is the
nrbirrct Ernor of thc procccding: aad
({) Thc ckcu.Estanca esublishing
tbrt tha rrqucct for r berring ir timcly
ia sccordanc€ with 5 2.f 205(c).
Aay beariq that is requested aad
6nnted will bo held ia accordancc with
&e Coo.oissiou's [nformd Heariag
Prodrrre. for Adiudications ia
Meterials Licensing Proceediogs in 10
CF? Pan 2, Subpsrt L
tltod rr Ralrill,r. llrryLrd, thir i$1f, fiy
o{ Fabnrary 1997.
Fcr the Nuclcu Rrguhtory Commirsioa.
Ircph I. Holoaich.
Ch ie f. U an ium Raowy Fm nch. Diyision
ol Waste M. nagemcn& Olfice of Nuclcor
Hotenal fulety ond fufeguards.
tfR Doc. 97-53tt Fllad Fl47: E:{5 16l
Ir.r€(E rDat-t
IUaE S-170 rd er}.l.Sll-DocliaG{Iif rrld {O.{i4
tb*Lrtrl* hc-CqtcodtfEurrttrc hnrrd ol Sourcrl-add Ucmq Flndtg d Xo
Slgntllcrrt lmp.ct rnd tlo{c. ot
Opporurntty tor ! tlG.tlng (XUBE@CR-
1618)
Tbc U.S. Nuclar R.guhtory
C-oo.uirrion ir cooridcriag thc rencrrl
of Sourca Matcri.l LicensSMFtT9
and S[.JB-1152 forth! cotlnudop-rda qf Nuclrr !.lal+ rr. (NMI).
locrtrd h Coocod l,tpcttm.
SurydtlrHudlItret
- Idantifaabn of tb Pto@ tlrlcrqt
Thc pmpccddmt th. rwrl of
NM'c Sorrrc! l'{drrtdUoora Sfu{B-
179 end SUB-1{52 for at lort 5 yeen.
With thcro rancwrl$lhr NMI hdlitY
[iar'irur-il netai. rilor.. ''t,rltie. .l"-iiel i:r]se'siinilgtl rnng3l tloses were
uranluin mut.ri. :,ior. , \ldc. or 'l 'rride. r:cr::pdred to NRC requlremeots ar.d
natural t-bonum metal, allov. or ortde. EPA standards to gauge impacts to
and depleted uranium slab. The public bealt-h aod safetv.
liceased uranium mav be an element of nmbieot air concentrations (at or
any compound except uraniu-st beyond the site boundary) resulting
hexafluoride (UFo). The proposed action from the primary sources of
would also pennit NMI to possess, nonradiological air emissions were
under Ucense SUB-1452. deplete:l estimated using the Industrial Sourc"
uranium as contarnination in sand; Complex-Version 2 (lSC2) air
depleted uranium as co.ltamination on dispersion model (EPA 1992a). Total
metallic components. packaging predicted concentrations wene
materials or equipmeni. or as waste compared to theNatiood Ambient Ai
solids; and natural thorium as Quality Sta.odards (NAAQS! in onder
couto'ninatiou on metallic courpogogts, gaugO impactt oD &ir quelity.
paclagin-g materials or equipment, or 8s b*t Frcm Routfur Aitbrne Relasewarte solids.
Prior to September 1985, liquid and Small a.sroua! sf qpairrm 6p
sludgo wastel hom the prdror wero eoittcd hoo 33 Jtt& at NMI. Tbe
stabilized and eopued into an unlined towa of Coocord peraits deplered-.
holding basin and adiaceot bog located u+trlqn enissions of up to 280 pci pr
on sitelropertf. The'holtli.8 L.in wcr calonder quartcr-for oPontloas
corered'bya sf,ecial membriae i-o 1986 associated with License Nos. sMB-tz
to reduce infiliration of rain water and and SUB-1{52. NRC's regulations (10
discharge of contaminants to surface CFR 20.130f ).rsquim licensees to limi
and groirnd wateF. Remediatiou of tbe doses to EGEhr! of tha Public to
holding besin aad conta.uriaated IOOP*T per year..Eraission rates of
groundirater is being planned as a deplated uranium in 199{ were less
Lp"t"t, rlecommissi-oling action: tl1a T peroat o.{th3 zlo ttpi per
thireforc, this actioo and iubsequeot caleader quertcr limit- For tho
enrrironmoutal impaar srs outlido tho modelilg, aoauel eo,issions'.vere
scope of this EA. ' 6s5r"n6d tn bc rt Ela.,(iElrrm permitted
rhc Need for the koposed Ac6on :1',*"ghi +i: ffilrull}lj"*
Tho rtion is to determinc if thc . coorarvadvc ln that thcy ruult in biBJ
Iicaora rhould b6 rncwrd c daicd- prcdlaad dc. tb[ rn cxpacd to
NMI m..ulactqrcc producttcoopord *s..ff,1 milrun ranrnl commitl
of dcplctcd ruudun and oetunl cfiacflvl doo tqutvrlant prcdlaed w
ursli-un that hava Ellitlry, csFca 2.5 mlq- Thtr dorc rrr cdndd tc
industdd, and ucdtcrl applcetiour. cur to r ltdu luud 15o m ({92
Ihpletcd unuium mctal iJpruad to hsa t!9 EildbuildDq. Thir ls ab<
fort aroor poootrdore, rinrrlt ootbrlf thr ddrDc. to iha urea
countarwcifitr rud radiadon r[i6lrllng ttridat- Thanilul, 15{t lD ({92 tt) is
devicss. Deiial of the liceqs€ renewala- conridcrcd a r"fHcicntly coElowativ
will cmttnuo to coAd ogolry
opandmr tncludlry thr dadoPoot
and mrnuicturc of crci4t,6usioa .
sq6ahlnod partr. ead oarl powdcr
coopriod of dcplctrd nrolun rad
oanu'el unnium -trl. Thc propood
stion would pcruit NIIB to ltacsrundcr Licanro SMB-179. nrtrrnl
for NMl is an dtemative avaihble to di8t Dco to fou aD uPPcr bound of
NRC. but sinca rpproxiruatoly helf of du thrt could bc ncat!,td bY th"
th€ U.S. d6-.^{1ij 6ecc pr6du"t i" publlc ranurlly. Thl prrdictod ennt
baing ua by opcretionr at'NM itq= !.2.5 PGG.EI of thr.NRC linit'
hcih]ties, dinyrng lbe licgossc woutd Thc -primrry rourcal.ot.
"ot U" i" tt ieUia'r Uca tntaat- nourdlologbl dreolrdou et NU
&rvironaranral l,,,"ro, "t tb r,,,4 Xfr$s;ffiffi'A.,llon Po,lhnEtt: Sq.l{o|. pl.-to. rad (
Bah redlotogtcel end oonndlolodc"t Shct-tro abdo ntr. cdcrrLtl
atmocphcrlc cibdoos ocsur and wctc "rln3 thc merdmum-aotthly fucl u!!s.ril duilg uoroal (iucidcut-freo1 reta, wrrr urcd fD [llC2 for-pgiodr
rt iIIt{L Th. r.dio}ogfcrl 2{ hr q ld" t oBS'tcE @It i@ niip"* of thc conttuucd opcnidon of crtcutrt d uttrytb. ErxiEuE snt!
ttrdNf,g facility wero assessed using fuel usrgc ntcr' werc rlad in lSC2
atmospheric dispersion modeling to the ennu.el tlme P.tid Both site
sstimdtc ambioni qaarrel dorc to-thc lpcd8c drtr 1ad conrrnadvc
oublic rcaildDr Aom olrltcn' d tbc rrarmgUor ruc urd la thc mod
ina nciUty. T6 uu th. inprt of rndyia Tarlprrdtard-Gouqlntr
unniumc;tldonr onrtrnapbrlc rur copcrd to tha NAAQS h-(
tracounoar, ths @MPLY coalutcr codc to trst tnarar oa etr-qurllty. Tt
wec uscd to dacrafnc thc mi:dmum rqrltr-of tli srtydl show tblt
aolual dcc cqutvdcnt tedvcd iou Errdrlua &br end 2't-hr evcngg
utanirrn couciotatioor ia thc embieot coucaotrdoor uc ebqrt twico thl
air (at or bcyood the rite boundary). rlspccdvQ NA/l\qS. For rII otLer r
Encl osure 3
SafetY Evaluation RePortfor Renewal of
Source.ilaterial License No. SUA-1358
Energy Fuels Nuclear, LtLc.
tthi [e l{esa Urani um I'li I I
San Juan County, Utah
SATETY EVALUATION REFORT
FOR REI\TEWAL OF
SOT'RCE MATERIAL LICENSE NO. SUA.135t
ENERGY TUEI^S NUCLEAR, INC.
WIIITE MESA TJRAI{TT'M MILL
SAN JUAI{ COT'NIY, IJTAH
MARCH LW|
DOCKET NO. 4{FE681
U.S. Nud.rr R{uhtort gorrmiedoo
Offrcc of Ndc.r ilIetcrirl S.fttY
end $fcaurrfi
Dividm of Wtrt. l{rrgtmcnt
1.0 INTRODUCTION
1.1 Description of Proposed Action
1.2 Backgroundlnformation1.3 Review Scope
TABLE OF CONTENTS
Paoe
3
3
2.O
2
2
2
3AUTHORIZED ACT!VITIES
2.1 Facility Description2.2 Operations
3.0 FACILITY ORGANIZATIONANDADMINISTRATIVE PROCEDURES . .. ... 3
3.1 Organization
3.2 Radiation Safety Staff and Responsibilities
3.3 Minimum Technical Oualifications for the Radiation Safety Staff
3.3.1 Mill Manager
3.3.2 Radiation Safety Officer
3.3.3 Radiation Technician
Administrative and Operating Procedures
lnspections and Audits
3.5.1 lnspections...
3.5.2 ALARA Audit
Radiation Safety Training
4.1
4.2
4.3
4.4
4.5
4.6
4.7
3.4
3.5
3.6
3
bI
8III
9
9
10
11
4.O RADIATION SAFETY CONTROLS AND MONITORING . . 12
Ventilation and Effluent Control 12
ln-Plant MonitorirE Data . 13
Personnel Monitoring Data 13
Externat Radiation Control Program 14
4.4.1 Occupotional Exposure 14
4.4.2 External Radiation Surveys 14
tnternal Radiation Control Program 14
4.5.1 Airborne Radioactivity Surveys . . 14
4.5.2 lnternol Exposure to Radioactivity 15
4.5.3 Respiratory Protection Program 16
Bioassay 17
Contamination Coirtrol 17
4.7.1 Personnel Contamination . - 17
4.7.2 Surface Contamination
4.8
4.7,3 Disposal of Contaminated Equipment
Ouality Assurance and Calibration
18
18
19
5.0 RESTRICTED AREA MARKTNGS AND ACCESS CONTROL . 19
1.0 |I{TRODUCTIOI{
8y application dsted August 23, 1991, and supplements dated Decamber 13 and 17'
f ggi, January t 3 and ipril 7, 1gg2, Umotco Mi:':crals Corporation (Umetcol requested
renewal of source Material License SUA-I358 for the white Mesa Uranium Mill, which is
located in San Juan County, Utah. By letter dated March 29, 1994, Umetco r€quostod
transfer of the ricense ana a change in ownership of the miil to Energy Fuels Nuclear, lnc.
(EFN). on May 2s.Jgg+, the lice--nse was smonded to change designation of the licensee
to EFN. ln ths acquisition agr€om€nt between EFN and Umetco' EFN agreed to abide by '
all commitm€nts and representations made to NRC by Umetco.
with this license r€n€wal, NRC wilt be authorizing continr.nd mill op€rations under the
performance-Based License conditim (PBLC) format. under Performance-Bassd Licensing,
the licensae has the Lurden of ensuring the proper implernentation of the PBLC' The
licensee may:
Make changes in the facitity or process, as presented in the application,
Make changes in the procedures pr€s€nted in the aoplication, or
Conduct tests or experiments not presented in the application, without prior
NRC approval, if the licensee ensures that tho following conditions ars met:
The changs, test, or experiment do€s not conflict with any
requiremeit specifically stated in the license (excluding material
referenced in the Perfoimance-Basod License Conditionl, or impair the
licensee,s ability to mo€t all applicable NRC regulations.
There is no degradation in the ess€ntial safety or €nvironm€ntal
commitments in the license application, or provided by the approved
reclamation Plan.
The changs, test, or experiment is consistent with NRC's conclusions
regarding actions analyzed and selected in the EA'
Otherwise, the licensee is required to submit an application for a license
amendment from NRC. The licensee's d€t€rminations whethor tho above conditions
are satisfied wilt by made by a safety and Environmental Review Panel (sERfl'
The SERP shall consist of a minimum of three individuals. one member of the
SERP shall hcve expertise in management and shall bo responsible for managerial
and financial approval changes: one member shall have expertise in operations
and/or coNtruction and shall have exp€rtass in implementEtion of any changes; and
one member shall bo the cofporate radiation saletY officer or equivalent' Additional
;n"rU"t" may be included inthe SERP a3 appfopriate, to address technical asp€cts
in several ar€8s, such as health physics, sutface water hydrology' spocific earth
sci€nces, and others. Temporary members, or p€rman€nt members Oth€r than th€
three identified abovs, maY be consultants'
1
(1)
tzt
(3)
EFN,s proposed programs were also evaluated against NRC regulations as specified in
1O CFR Parts 20 and 40, and appropriate NRC staff guidance.
2.O AUTHORIZEDACTIVITIES
EFN is curr€ntly authorized for commercial operation of the White Mesa mill' By license
condition, yeltowcake production cannot exceed 4380 tons p€r year'
2.1 Facilitv Descriotion
The White Mesa mill is located in San Juan County, Utah, approximately 9.5 kilometers
(6 miles) south of Blanding, Utah (see Figure 2.1). Maior mill features include the mill
buildings, tailings impoundments, 8n ore stockpile area, and a small sampling plant which
is used-infrequently io determino th€ uranium content of tolled oros. The ore is initially
processed in the main mill building, which contains a semi'autogonous grinding (SAG) mill,
an acid leach circuit, and a counter curr€nt decantation (CCDI circuit. A separate building
houses the two solvent extraction circuits, one for uranium and one for vanadium' The
uranium-bearing solution is returned to th€ mill building where it is precipitated, dried, and
barrelled. A reproduction of th€ g€neralized flow chart for uranium milling is included as'
Figure 2.2.
The mill occupies approximately 2O hectares (ha! (50 acres) and the tailings system
another 1g2 ha (450 acres). The tailings system consists of four partially below-grade,
synthetically-lined disposal cells.
2.2 Ooerations
Operations at the White Mesa mill begin with the weighing, sampting and.stockpiling of ore
received from varioug mines. Mine oie, as welt as stockpiled and crushed or€, is then fed
to ths sAG mill. The ground ore is stored as a w€t sturry in two mechanically-agitated
storage tanks. The subsequent processing involves two-st8g€ acid leactring, followed by
.
the recovery of uranium-bearing pregnant-solution in the CCD system. Tailings are slunied
by pipeline to tho lined impoundments.
The uranium is rscovered from the pregnant solution through a conv€ntional solvent
€xtraction system. Vanadium, when ricovered, is stripped from the barren uranium
raffinate using a soparato solvent oxtraction circuit'
FACILITY ORGAT{IZATIOil ANO ADMINTSTRATIVE PROCEDURES3.O
3.1 Oroanization
EFN, th€ op€rator of the white Mesa mill, has its corporate headquarters located in
D€nv€r, Colorado.
'The
corporate office supplies any n€cessary support to the mill staff'
Milling op€rations are managed from an office located at the site'
submitted revised organizational charts for full
(Figure 3.1). During both modes of operation'
3
By l€tt€r dated December 13, 1996, EFN
operational and standby modes at the mill
Ore Stocirpiles
Atmospher':
Crushing and
Grinding Circuit
Dust Collection
_->iA:
iY
Thickening _---'.NaCl ---r
i
Eanen
Strip
I
I
I
Pregnaht rStriP i
Y
Acid
Leaching
ccD
Washing
Circuit
i
Il.tl
Tailings lmpoundment
H2S04<-- NaClO3
Steam
i NH3
I
I
i
I
Precipitation
and
Thickening
IBanen I
I
I
a+
i teactr I,_J
!t
Optional
to
Vanadium
Recovery
Atmosphere
A
I
i Wet Scrubbing t
Yellorrcake
Producl
Figure 2.2 White Mesa urenium Mill, Generalized Process Flow Diagram
(modified from NRC, 1979)
5
I Extraction i
-
t-r, 1_i Baneni l Pregnant
Organic : I Organic:ll ;Y
-ni
I
I
II---lli
I
I
Pregnant Leach i
Solution
-
Solvent i
6t
=oi,
o
c,
=!^= oqAL J
,
,J)lg.lI 16ll;E I
Ei.l
-_-lr99llfrEll;gll=0, II =6 I
l5E I
oSr
; =.8*=9Icc4ociiil!': tr
=- IEO
gJ
Figure 3.1 White Mesa Uranium Mill, Organizational Chart
1.
cover alt asp€cts of mill operations. EFN committed to reviewing th€s€ procadures
annually.
Atthough the licensee committed to reviewing the SOPs on an annual basis, they did not
stats that the RSO will perform and document this review nor that the appropriate SOPs
will be avaitable to workers in their milt work areas. ln accordance with rocomm€ndations
in Regulatory Guide 8.31, EFN is currontly required under SUA-1358 to m€otthese
conditions, and will continu€ to be so required.
The licensee has stated that any non-routin€ maintenance sctivity which may, by the
det€rmination of the RSO, exceed 25 percent of the 1O CFR Part 2O limits requires a
Radiation Work parmit (Rwp). The RSO will provide a monthly updated listing of thosa
ar€as that may exceed this criteria to th€ Maintenance Superintendent and Mill
Superintendent. This listing will be used as a guide by the mill staff; however, all
non-routine activiti€s require review by the RSO.
An RWP will be obtained in the following mann€r:
The Maintenance Superintendent, Mill Superintendent, or their designee, will define,
in writing, th€ no€d for the non-routine activiti€s. The request will addross tho
specific work location(s), the estimated work duration, the type of work to be
performed, and the personnel to be utilized. This information will be included in
the RWP.
The RSO, or designee, will review tho RWP to ansure that the proposed work will
not prossnt a health hazard to th€ employee(s) involved, and will give written
approval. The complated RWP will define (1) time limitations for iob performance,
(2I th6 personnel protectiv€ equipment to be us€d, and (31 the monitoring
surveillance needed for the activity.
All supervisors will be given training in and copies of the requirements for using
RWPs, with ths original permit remaining on file for five Y€ars.
Any supervisor fotrnd to bo knowingly and willfully violating these procedures will
be issued a written waming, and the situation will be reviewed by appropriate
managem€nt for remedial action.
The staff conctudes that tho proposed program is in accordance with the recsnmondations
contained in Regulatory Guide 8.31, and is, therefore, acceptable.
lnsoections and Audits3.5
3.5.1 lnepccdonr
EFN,s proposod program for radiation safety inspections is extensive. The op€rating mill
foreman, or his aeiiines, will perform and document a daily visual surveillance of all mill
aroas to insure propir implementation of good radiation safety practices. On a weekly
basis, the radiation safety staff will perform and documont an inspection of all work and
3.6 Radiation Safetv Trainino
EFN stated that th€ purpos€ of an in-house radiation safety training program is (1)to place
in proper p€rspoctive, for the employ"", in. potential short and long-term radiation hazards
associated with thelou, rzr io acquaini'thaemproyee with the practices instituted by
rnanagom€nt to k€€p occupational exposures ALAha;.and (3) to snsurg that the employee
has an understandini iuotd initialty .rid or", the duration of their employment) of the
raJiation procadures which should be followed'
The licensee assured that each p€rson, upon reporting for employment at the mill' will
receive instruction in mill and personnel safety, including radiological protection
procedursg, lrorn a qualified instructor. The instruction will include on-the-iob
demonstrations of propor safety precautions, and m€asur€s to b€ taken to minirnize
radiation .rp*rrrJ. tiach empioyee will also be provided a safetY msnuEl' which covers
radiation safety "nJ :nJr"trial safety ptoceOut"s, including personalhygiene instructions
for uss of monitoring'"J;.;iV tquipr"nt and procedures for handling spills and
maintaining clean working conditions. Each employee will be required to pass a written
test addreJsing their undJrstanding of radiation safety and hygiene'
The employe€'s understanding and r€tontion of proper practic€3 will be verified by the
A-- ^^+ 6Yl:ff;ff1",",i""*ork tocation tnrougi peiioJi"?ti"t,i. !l !* :.1p91"."^.df.:*i,::T,t::::ffiilil';:ffi#ilil;; ;;; ;';""0""'' thev wlr receive rYil?llYruction rrom
ffiffiI,;;;:'ffi, i*.ir,. ,riri'u! repeated untir satisfactorv ret€ntion is
- )- . -^- ) --.| rLr raar rlil"'H""ffi J"i] "o
"
-ii":;oi il;'',s ;J,".:,i n g',' i r r be 9 9nd u9t e d a nd
-the :::''::-:::: t o
to ensure that each emproyee understands thi appricabre radiation protection practices.
tn acdition, EFN stated that I poftion of the monthly mill salety meeting will bs set aside
for discussion of radiation protection procedures, a-nd that on€ monthly meeting p€r year
will bo sat aside for reindoctrination oi tft" mill staff in radiation protection' Each
emproyee win bs tested annuaily by the RSO on th€ir undorstanding of radiation protoction
as it rorstss to tnei, ;Lu. lrr *i"*iror, *il be required to periodicaily attend specific
training courses in riOi"tion "nA
inOu"trial protection, so that they will bo better able to
p-"iai and evaluate specific iobrelated Uaining'
The ricensee arso st8td that tr8ining of on-site contractors would occur prior to the
conduct of thcir work. The training will consist of topics similar to thoss used for newly
hired employecs. Complete details oi tf," contont of all in-house training' including
contractor trainlm, weie submitted as Appendix F to the renewal application'
The staff has determined that the radiation safety training progfam proposed by the EFN is
in accordance with the staff guidance spe,:ified in Regutatory Guide 8.31, and is'
therefote, eccePtaHo
11
suspend yeltowcake drying and packaging operations if the effluent control equipment is
not functioning as designed. EFN is required to op€rate in accordance with the provisions
of Appendix A.
The staff corrctudos that the mill ventilation and effluent control program is acceptable.
4.2 ln-Plant Monitorino Data
Airborne gross alpha (uranium) samples are collected monthly from 26 rnill areas, while 5
additional locations in the yellowcake process arsa ars sampled weokly during mill
op€ratiorur. During mill operations from 1988 to 199O, at which tims 23 aroes wera
sampled, the highest annual averago concentration was less than 20 percent of the
maximum permissible concontrstion (MPC). During mill operations in 1995, area
conc6ntrations were less than 25 percent of the derived air concentrstion (DACI at all
sampling locations €xcopt for the yellowcake dryer and packaging encloswes, yellowcake
packaging, and the SAG mill. EFN posted these areas as Airborne Radioactivity Areas.
Radon daughter concontralions are measured ,U Zr locations throughout the mil! on a
monthly basis. From 1988 to 199O, the highest employee oxposuro to radon daughters
was 26 p€rcont of the maiimum permissible €xposuro at th€ SA.G mill. Concentrations
measured during 1995 were lower than those observed duririg previous op€rating periods,
which EFN attributss to modifications made to the mill demist€r systom and improved mill
ventilation systoms.
EFN conducts beta-gamma survoys on a quarterly basis at 26 locations throughout the mitl
complex. Exposure ratos sinco 1985 have ranged from less than 2 mR/week up to 125
mR/week, measured in the oro storage area in 1985. Ambient gamma levels observed in
1g95 were 15 mR/week. EFN has posted the yellowcake storage yards, th€ top floor of
ths y€llowcaks calciner, tho ore stockpile area, the solvent oxtraction feed lines, the
solvent ol6racto{ mix tanks, and th6 calcium fluoride storage ar€as as Radiation Areas.
4.3 Parsonnel Monitorino Data
Employees are required to record on a daily time card the amount of timo sp€nt in areas
monitored lor uranium dust snd radon progsny. Details concerning the methods used by
EFN to monitor for airborne uranium and radon are discusssd in Section 4.5.1 . Using the
monitored air corrcentrations and the employee time card information' oxposure levels for
employees arc calculated.
Porsonnel €xposur€ records are retained onsite and are accessible only to the radiation
safety staff and the individuat employee. lndividuals othor than tfle radiation safety staff
can obtain a copy of an employee's oxposure history only with the employee's signed
cons€nt to thet elfect.
13
stat6 of op€ration of both process and effluent control equipment a rd ventilation
conditions wilt be maintained along with area sampling results.
yellowcako catciner and packaging operators ars required to wear individual air
samplers onc6 per week. ln addition, mill operating and maintenance personnel
working in processing areas where the potential exposure is proiected to exceed 25
perceni of i O CFR Pirt 2O limits for uranium dust will be monitored with individual
air samplers on a periodic basis to establish typical uranium dust exposures for
these individuals. lndividuat air samplers consist of a sampling pump and lapel filter
holder capable of sampling at a rate of two lpm for eight hours.
b. Radon prog€nY
The licensee stated that radon progony will be measured on a monthly basis at tho
23 locations used for air particulat€ sampling, with weekly sampling in areas that
exceed 25 percent of a working level during production periods. The modified
Kusnstz sampling and analysis procedura will be utilized to determane radon
concsntrations.
The staff finds that the proposed program for airborn€ particulate monitoring is in
accordance with Regulatory Guide 8.30, and is, therefore, acceptable.
4.5.2 lnternal Erposurc to Radiotctivity
personnel tirne in the monitored areas is recorded on a daily timo card by the employee.
Using this information, and the r€sp€ctive area airborn€ concontrations, an employee
u*priur" record is developed. When routine work is performed, aslr€ssment of an
individual.s 6xposure to airborne natural uranium and radon daughtars are calculated using
the methods described above. Ouarterty breathing zon€ samples using portable samplers
are collscted to assute reliability of this procedure.
When non-routino maintenance work is performed, sccurate time records aro kept to
calculate sxposur€s to naturel uranium. Ereathing zone samplos are taken using portable
samplers to assur€ accurtte Essgssm€nt of exposures during non-routino work
assignments.
EFN proposar to review the observed time sp€nt in each arsa where routino uiork is
performed. Tho review will be recorded and the accuracY of the observation reviewed
quartorly, or when maior Chsnge3 are made in iob assignments.
lf an employee reaches an sction level of 25 percent of the DAC based on th€
time-weighied exposure over a period of one quarter, the RSO will institutc an
investigaiion of the work record and exposure history to identify any proHem 8roas. !f
problem eraas 8re notad, coriective moasut€s will be taken to onsure that tho exposure is
as low as is reasonably achievable.
15
(3) engineering controls, (4) respirator selection, (5) fit testing, donning, and wearing of
respirJtors, (51 maint€nance, storago and exchange requirem€nts, (7) th€ circumstances
under which an employ€€ can leave a hazardous area, (8) emergency respirator us€,
(g) the regulations for respirator use, and (10) adrjicional training requirements for
supervisors,
The NRC staff finds that tho proposed respiratory prot€ction program, as presented in
Appendix F of the renewal application, is in accordance with staff guidanco as specified in
Regulatory Guide 8.15 and is, therefora, acceptable.
4.6 Bioassav
EFN has statod that urinatysis will routinsty be performed on those employees that aro
(1 ) exposed to airborne yellowcake or involved in maintontnce tasks in which yellowcake
dust may be produced, or l2l routinely exposed to airborne uranium ore dust. Specifically,
routine biweekly urinalysis testing witt be performed on those employees who have worked
in yellowcake packaging, yetlowcake precipitation, the grind area, ore feed area, and
sample prsparation room. Basetine urinalysis will be performed on employeas who have
been working on assignrnents that require a radiation work permit, or for any individual
that may have been exposed to airborne uranium or ore dust concentrations that exceed
25 percent of the DAC level.
A detailed procedure for collection, preparation and analysis of urine samples was
submitted under Section 1.4, "Radiation Protection Procedures Manual," to Appendix D of
the renewal application. EFN will perform the analyses in-house using a lower limit of
detection of 5 ug/I. Bioassay laboratory surfaces will be decontaminated to less than 25
disintegrations per minute (dpml alpha per 1OO cm2. EFN will use 25 percent of all
submitied samples for quality control (OC) checks. ln addition, spikes and blanks will
accompany th€ ssmples, and the analysis will be performed by using fluorometric
techniques. Ten peicent of all samples, including the OC spikes, blanks and duplicates,
will be sont to a contractor laboratory for analysis in order to compars results. EFN
committed to following tho action levels presented in Regulatory Guide 8.22.
ln-vivo body counting for lung burden of natural uranium or U-235 will not be rotrtinely
conducted. Monitoring by an in-vivo body counter witl be done at the discretion of the
BSO.
The staff concludes th8t tho bioassay program proposed by EFN is in accordance with
Rogulatory Guide 8.22, and is, therefore, acceptable.
4.7 Contamination Control
4.7.1 Pcrconnd Contemlnation
personnel working within the mill area will be provided with change room, shower and
laundry facilities. Employees working in the yellowcake product 8reas or who perform
maintenance on equipment from theJe ar€as will be provided coveratls and will be required
to change and shower prior to leaving the mill. Employees will also be required to monitor
t7
4.8 Qualitv Assurance and Calibration
Administrative procedures (Aps) are used by the licensee to provide uniform guidance and
consistency to mill activities. APs cover the sampling and calibration procedures which
ars an integral part of the qualitY assuralrce program at the mill. APs will be reviewed
annually anl updated as necessary to incorporate advances in technology and to prevent
systsmatic €rrors in sampling, monitoring and analyses'
Appendices D and E of the EFN renewat application delineate the curront proposed
ra?iation protection and environmental monitoring procedures. Written oporating
pio""our"" are detaiLJin &penoix G for mill operations. Each procedure includ€s tho
quality assuranco actions *tricn mult bo takon in order to properly evaluate mossuroment
,""t lqr""'and effectiveness of the procedure and specifies the typ€ of equipment needed
to carry out th€ actions.. Each piece of equipment is described along with its specified
calibration frequency, check-out procedure, and specifications for normal oporation'
Section 4 of Appeniix f is designated as the EFN Ouality Assurance Program' All
sampling, ,ecording, inspectionlnd review methc'ds are documented and detailed'
EFN has committed to calibrating all radiation monitoring equipment at least semi-annualli,.
and alt air sampling equipment ai least quarterty. ln addition, all equipment will be checked
prior to use to snsure that it is operating correctly'
The staff concludes that the quality assuranco program proposed by EFN is in accordance
with stafl policy as specified in Regutatory Guides 4.15 and 8'31, and is' therefore'
acceptable.
5.oRESTRICTEDAREAMARKINGSANDAccESScoNTBoL
The mill and tailings ar€a is lenced and posted with 'Restricted Aros' signs in accordance
with lo cFR 20.1902. During oporetiom, the mill normallY will run sovg! days a we€k'
twenty-four hourg a day. All visitors will be required to register at tho office and will not
u. perinined insidathe'plant rEstricted area without pfop€f authorization and escort'
Contractors having worl assignmen6 will be given a security, s8futy' and radiation
protection orientgiion prior to porforming their dutios without 6t'cort'
The staff corrcludes thst the above markings and access control procedures are adequate'
A license condition will be issued which ex--empts the'licensee from the requirements of
Section 2O.19O2(e) of 1O CFR Part 20 for aroas within the mill, provided thatall ontrances
to tho mill are conspltuously posted in accordance with Seaion 2O.19o2(el and with the
words, 'ANy AREA wlTHlni ixe mu MAY gONTAIN RADI9ACTIyE MATERIAL"
The proposed program for restricted.area markings and accolttt control is acceptable'
6.0EuEHoEItIcYPRocEDUREsANDPRE\/EI{TATIVEiiEAsuREs
EFN classified a sp€ctrum of pot'entiat mill accidents based on th€ir severity (in terms of
potential impgct to health, saiety, and the environment) and their probability of
occurr€nce. Given . tp""iti" severity level (e.g., 'insignificant') and probability (e'9"
19
suffici6nt funds are available to complete the reclamation. Additionally, the amount of the
sursty should be adjusted to racognize any increases or decreases in liability resulting from
inflation, changes in engineering plans, or oth€r conditions affecting cost.
The surety for the White Mesa mill is carried by Umetco, undor an agreement between
EFN and Umetco. The current surety amount of 91O,915,647 was reviewed and approved
by NRC in August 1996. EFN will be required by license condition to maintain a financial
sur6ty arrang€rn€nt in accordance with the requirements of Criterion 9. The surety
requiiementi will be reviewad at least annually by NRC to assuro that the funds and the
surety arrsng€ment 8re acceptable.
Following financial difficulties in February 1995, EFN agreed to voluntarily revise its surety
amount to cover reclamation and decomrnissioning costs for the site in its currsnt state.
EFN is pursuing this action in two phases, with the first having been completed in June
19gS with NRC's approval of a revised surety emount of approximately 910.5 million. ln
this initial phasa, EFN reviewed all maior reclamation cost cent€rs, considering th€ then
current level of development and disturbance at the site. ln the second phase, EFN is
reviewing all elements of the site reclamation plan and will, if necessary, revise the earlier
cost 6sti;ate. The licensee submitted its revised site reclamation plan by letter dated
February 28, 1997, for NRC review and approval.
1O.O INSPECTION HISTORY
NRC has conducted routin€ announced, routine unannounced, and r€activ€ inspections of
EFN's White Mesa uranium mill since the renewal of SUA-I358 on September 26, 1985.
l4 inspections have been conducted since that date, in which 8 total of 1 9 violations were
cited, the highest of which was of Swerity Levet lV. A discussion of inspection and
enforcem€ni actions, including severity of violations is provided in NUREG-1600 (NRC,
July 1gg5). Minor violations are cited at sev€rity Level lV and maior violations are citad at
Severity Level l. Typically. Severity Level lV violations are cited for not performing
required surv€ys or-incomploto documontstion. Atl cited violations have beon acceptably
addresssd and corrective measures onacted by the licensee. A summarY of the inspection
history for the facility since September 1985 is provided in Table 1O.1. Severity Level V
violations were elimated with the revision to tho NRC's enforcement policy in June 1995.
TAELE TO.1
SUMMARY OF NRC INSPECTIONS AT
ENERGY FUELS NUCLEAR, INC.'S
WHTTE MESA URANIUM MILL
T OF SEVERITYDATE TYPE. VIOTA- LEVEL COMMENTS/RESULTS
TIONS
1/14-16/97 A o
1t23-25t96 A 1 tv Change in mill circuit without NRC approval.
Violation Closed.
21
TABLE 10.1
SUMMARY OF NRC INSPECTIONS AT
ENERGY FUELS NUCLEAR, INC.'S
WHITE MESA URANIUM MILL
* OF SEVERITYDATE TYPE. VIOLA. LEVEL COMMENTS/RESULTS
TIONS
4/1 1-r3/88 U 2 lv Portions of tailings cells not wetted or
stabilized as required by 10 CFR Part 4O
Appendix A; Lab surfaces for bioassay sample
analyses not surveyed for removablo alpha
contamination. Violations Cloced
3t16-18t87 U 2 lv, v Occupational exposure calculations not
documented; Tailings cell not marked as
authorizad disposal site. Violations Closed
5/1 9-2r /86 U 4 A[ lv Airbome radioactivity arsas not post€d; RWP
not issued for non-routino maintonance work;
Lapel sampling results not used to calculate
oxposuros; Occupationat exposure calcula-
tions not documented. Violations Closed
10t4t85 R 2 !V Required training not given for tailings
impoundment inspections; Site inspections
not performed in required manner. Violations
Cloc€d
' A = Routine Announced; R = Reactive; U = Routine Unannounced
On July 2, 1996, the Commission approved increasing the license torm for qualified
uranium recovsry licensees from the currant five-year period to a ton-y€ar period. As
discussed in SECY-96-1 12 (issued on May 21, 19961, tho crit€ria to be used in
determining whether a licensee is 'qualified' are as follows:
(1) the licensee must have perform€d w€ll;
Ql the license€ must have a succ$sfut inspection recotd, with no violations
mora s€rious than Severity Level lV;
(3) the licenseo must have had no serious operational problems or r€ports during
the previous two Years; and
(4) the license in question must currontty have a specific term of renewal
(uranium mills currently undergoing reclamation would not meet this criteria).
Based on its review, the staff finds that EFN is a qualified licensee, and therefore, a
t€n-y€ar license term is appropriate.
23
D. The licensee shall maintain records of any changes made pursuant to this
condition until licenso t€rmination. These records shall include written
safoty and environmental evaluations, made by the SERP, that provids the
basis for determining changes are in compliance with the requirements
referred to in part A of tnis condition. The ticensee shall furnish, in an
annual report to NRC, a desCription of Such changos, tests, or experiments,
including a summary of the safety and environmental evaluation of each. ln
addition, the licensse shall annraity subrnit to th€ NRC changed pages to the
Operations plan and Reclamation. Ptan of th€ approved license application t6
reflect changes.made under this cundition'
The licensee shall submit to NRC by March 3t, t 9gz. for review. the standard
operating procedures (SOPs) needed to implement this licenss condition. The
ticensee-snalt not imp6ment any provision of this license condition until NRC has
found the proposed SOPs acceptablo.
SOps shall be established and followed for alt operational process activitios
involving radioactive materiats that are handled, processed, or stored. SOPs for
operatio-nal activities shalt enumerate pertinent radiation safety practices to b€
followed. Additionalty, written procedures shall be established for non-operationa!
activities to include in-plant and environmental monitoring, bioassay analyses, and
instrument calibrations. An up-to-dato ccpy of each written procedure shall be kept
in the mill area to which it applies.
All written piocedures for both op€rational and non-operational activities shall be
rsviswad and approved in writing by the RSO before implementstion and whenever
a change in procedure is proposCO to 6nsur€ that proper radiation protoction
principLs are being applied.'ln addition, the RSO shall perform a documented
ieview of all existing operating proceduros at least annually.
The licsru€o is hereby exempted from the requirements of Section 2O.1902(e) of
tO CFR 20 lor areas within ihe facility, provided thst all €ntranc63 to tho facility are
conspicuo6ly poltod in eccordance with Section 20.19o2(el and with the words'
.Any area wiihin this facilitv m8Y contain radioactive material.'
The licensee shall maintain an NRC'approved linancial surety arrarqement'
consirtcnt with 10 CFR 4Cl, Appendix A, Criteria 9 ard 10, adequato to covor tho
estimctrd costl, if accomplbhed bV a third party, for decommissioning and
decontaminstion ol the mitt and mill site, for reclamation of any tailings or w8st€
dispoSal Ito8S, gramd-watsr r€storation as warranted and for the long-term
surieillance fee] Within three months of NRC approval of a revisod
reclamation/decommissioning plan, the licensee shalt submit, for NRC review and
;;;"";i: ; proposeO revisid io ttre financial sufotv arrangem€nt if estimated costs
in ths newly approved plan exceed th€ amount covered in ths existing financial
'sur€ty. The revised suiety shall then be in effect within 3 months of written NRC
approval.
25
REFERENCES
U.S. Nuclear Regulatory Commission INRCI, May 21, 1996, "Ten-Y€ar License Terms for
Uranium Recovery Licensees," SECY'96'1 12.
NRC, July 1995, "General Statement of Policy and Procedures for NRC Enforc€ment
Actions (Enforcement Policy)," Office of Enforcement, NUREG-1600.
NRC, August 1988, "Bioassays at Uranium Mills,' NRC Regulatory Guide 8.22, Rev. 1.
NRC, May 1987, "Guidelines for Decontamination of Facilities and Equipment Prior to
Release for Unrestricted Use or Termination of Ucenses for Byproduct, Source, or Special
Nuclear Matorial,' NRC Division of Fuel Cycle, Medical, Academic and Commercial Use
Safety.
NRC, June 1983, "Health Physics Surveys in Uranium Mills,' NRC Regulatory Guide 8.30.
NRC, May 1983, "lnformation Relevant to Ensuring That Occupational Radiation Exposures
at Uranium Mill Will Be As Low As ls Reasonably Achievab!6,' NRC Regulatory Guide
8.31.
NRC, January 1983, "Hydrologic Design Criteria For Tailingi Retention System,' NRC
Staff Technical Position WM-8201.
NRC, October 1980, 'Operational lnspection and Surveillance of Embankment Retention
Systems for Uranium Mill Tailings,' NRC Regulatory Guide 3.1 1.1.
NRC, May 1979, "Finat Environmental Statement: Related to Operation of White Mesa
Uranium Project, Energy Fuels Nuclear, lnc.,' NUREG-O556, Office of Nuclear Material
Safety and Safeguards.
NRC, February 1979, 'Ouality Assurance for Radiological Monitoring Programs (Normal
Operationsl - Effluent Streams and the Environment,' NRC Regulatory Guide 4.15.
NRC, December 1977, 'D€sign, Construction and tnspection of Embankment Retention
Systoms for Uranium Mills,' NRC Regulatory Guide 3.11.
NBC, October 1976, 'Acceptable Programs for Respiratory Protection,' NRC Regulatory
Guide 8.15.
27
a Encl osure 4
l{RC Source }laterial License t{o. SUA-1358
NRC FORM 374
r;.94)
Licensee
Energy Fuel s l{ucl ear , I nc .
6425 S. HighraY 191
P.0. Box 789
Blanding, Utah 84511
U.S. NUCLEAR REGULATORY COMMISSION
NI{TERIALS LICENSE
3. License Number
4. Expiration Date
5. Docket m
Reference No
7. Chemical and/or PhYsical
Form
Any
prce I op -9-- "oot
8. MaximumAmount that Ucensee
May Possess at AnY Onc Time
UnderThis License
Unl imited
pursuanr ro the Atomic Energy Act of 1954, as amended. rhe Energy Reorganization Act of 197"1 tPublic Law 93{38)' and ritle l0' code
Federal Regularions. ctrapter i pans 30. 31. 32. 33. 3.1. 35. 16. 39. i6. and 70. and in reliance on sratemeots and representations heretofore ma
by the licensee. a license is hereby issued authorizing the licensee ro rec.eive, acquire. possess, and ransfer byproduct. source, and special nuclt
mrterial designated below; to use such material for'the purpose(s) and ar ttre ptace(s) designated berow: to deliver or transfer such material
persons aurhorized to receive it in accordance *irtr ttre reiuladons ofthe applicable Part(s). This license shall be deemed to contain the conditic
speciiied in Secrion lg3 of the Atomic Energy lct or igs+. as amended, and is subjecr ro all applicable rules. regulations. and orders of t
Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below'
40-
6. Byproduct. Source. and/or
Spicial Nuclear Material
Natural Uranium
SECTIOil
9.1
Adml ni strative Conditions
The authorized Place of use
milling facility, locrted in
shall be the I lcensee's llhite l{esa uranium
Srn Juan CountY, Utah.
All rritten notlces rnd reports to the t{RC requtred under this license, rll
the excepgon of in.iiini-ina irint-notiitcations under l0 cFR 20.2202 and
t0 cFR {0.G0 requi;i;g-ierepfione-iiotiiiirtion, shall be addressed to the
Chief, Urantur neiirliy-Aii[gtt,. Oirition-of yistr ]lanagement, gffice of
Nucleir l{aterial Safety and Safeguards'
Incident and eyent notlfications that re9!1I-e !:1.pltql. notificatlon shall
6li-iiAi-to ttri ric Operatlons Center at (301) 816-s100.
The llcensee shall conduct operatlons ln.acco(angg rtth stat!.Sn!l:
;H#Hi;li#; and conditions lirl.iniia-in ttti Ilcense reneral loRl.icatil;iliffi'[i-iiitli-aiiio nrguit-ii;-i69i, is revi ::g..bl 'uh*t'H-**9fiHiii$"ii"ilit.r dated Ausust-ii,-rggr, as-reyised by-submtttals dated
ffiil;i- rtl' .na
-niii i-il- r g9i;-,i.y6 b;i i2, r?:{' . !t1l-1l. llei:. :::T:::iil"ii'gei'lni"i.ill;i !i''i!6r, it iil ": !:t!I^t'::T:I'::1-:v.l:l:::[:lie ili"iol"igii'j";;i ffi ilii.,iui"iriirl'ngiii,*it, exclpt rhere superseded
by ltcLnse condltions below.
tlhenever the rord "Yi I I '
denote a requlrement.
is used in the above referenced documents, it sha
NRC approval, and subJect to the
of this condltion:A.The licensee may, rithout Prior
conditlons sPecified ln Part B
NRC FORM 374A
(7-94)
U.S :LEAR REGULATORY COMMISSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
(l) l,lake changes
app'l i cati on.
Licensc Numbcr
suA- l3s8
Dockct or Rc&reoce *rfflgeat
in the facility or process' as presented in the
etyfind.Env ndividual4 One'member oft ind shfr be resPonsible
aig€&t one.r shall have
rictlsa,;tnd sh!([ have
ooert*{dnal ch!!!es; and, onenalfety off{ier (CRS0) or's?fiIntt.
B.
(2) l,lake changes in the procedures presented in the application'
(3) Conduct tests or experiments not presented ln the application'
The licensee shall file an appltcation for an amendment to the license,
uni.st-the following conditions are satisfied'
( I )
ii::ili$iOunfs'iffi Hh6,lq,;iiH!}ilihiii "'
( 2 )
I!ffid?,E T:'li:'i I :t. l: :l;, i::im€ill, llo'il' If, :"'n"'
appr@a recl amati on pl an. Ua
c.r r,. h n s e e' s dlb). t ffi-),,( d{4^r t - a o r Qi' s ol I I I i9 n
H:,fr :';ff :',f &*tim-i'{ffiir'-:,tl$;.i't3lltit,rh.shal tte made bYl
SERP!-cfial I cdnri s
the SE3P slall., lra're,
ror flr{ilaqeritrf',rnd r
i :i i ;i lHtE !l; I i;:.ffiffi ffi ;xffi ffi i' : : :l'H,n13'",
i:l;li;:iffi, ln :r"rr,::iil.!i:qli:hPdlilii:, :lrtii;;i*::
iiti Lri'difrilH ffi riiil:fiii#, $] ffi :l' I n :' .n ] : :' I lrl: :
specifled indivt
D. The llcensee shall malntain records of any changes made pursuant to
this condition unfil license iermination.- Thesi records shall include
rrltten safely ini environ*niii eviluattons, made by-the SERP' thlt
;;;;id; ite-6isii-roi oete*ining-ctlngg: ari in compllance with the
;;qriiements-ieferreO to in Part-B of [nis condltlon. The licensee
shall turniih,-in'ln-.nnrii t.pori 1o.NRC, a descriptlon. of such
changes, tests, or experimeniif-in.irAing'a surmary'of the safety and
environmental evaluailon or"eiirr. --in-aaiition, the I lcensee shall
annualty suUrntl io-itre NRC ch;ilig.niSit to thi 0peratlons-Plan and
Reclamatlon P'lan of the appiovei ttteise appltcation to reflect change:
made under this conditlon.
NRC FOFM 3744 U.S. NT .EAF REGULATORY COMMISSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
Lrcensc Number
suA- 1358
Dockct or Refercncc Numbcr
40-8681
9.5
March 14 1997
Addi tlonal ly,ten-procedures sh:1i be establlshed for non-operational
The licensee shall subntlt to the NRC by April 30' 1997' for review, the
standard operatlng procedures (S0Ps) needed to implemen! this license
condition. The licbnsee shall not implement any provision of this Iicense
condition until NRC has found the proposed SQPs acceptable.
The licensee shall maintain an l{RC-approved financial surety arrangement,
consistent with l0 CFR 40, Appendix A, Criteria 9 and 10, adequate to cover
the estimated costs, if accomplished by a third party, for decormissioning
and decontamination of the mill and mill site, for reclamation of any
tailings or waste disposal areas, ground-rater restoration as warranted and
for thi long-tenn surveillance fee. Iithin three months of t{RC approval of
a revised r[clanratlon/deconrlsslonlng plan, the llcensee shall suhnit' for
NRC revier and approval, a proposed revision to the financlal surety
airangement if eitimated coits-in the nerly_approved plan exceed the amount
ioverla in the exlsting financial surety. The revised surety shall then be
in effect rithln 3 months of written t{RC approval.
Annual updates to the surety amount, requi!"ed !I t0 CFR 40, Appendix A,
Criteria'9 and 10, shal'l be- submitted to the ilRC at least 3 months-Prlgr !9-the anniversary dite which ts deslgnated as June 4 of each y!!r.. If the NR(
has not approvid a proposed revision to the surety coverage 30 days prior_tc
ihe expirition date'of'the exlsting surety arrangement, the.licensee shall
eitend'the existing surety arrangenent for I year. Along with each proposed
revision or annual-update, the licensee shall submit supporting
documentation shorinb a breakdonr of the costs and the basis for the cost
estimates rith adJusirnents for inflatlon, maintenance of a minimum
15 percent contingency fee, changes in engineering p1ans, activities
per?ormed and any-othlr conditlons affecting estimated costs for site
tlosure. The ba-sts for the cost estlmate ls the NRC approved
ieiiimation/deconmlssloning plan or t{RC approved revisions to the.pl1n. .If,pieviously brovlded gutdanie'entltled 'Retbrnrended Outline for Site Specific
iieclamatl6n' and Strbillzatlon Cost Estlmates' outllnes the mlnimum
conslderatlons used by the NRC in the revlew of slte closure estimates.
Reciamatlon/decornlss-lonlng plans and annual updates should follor this
outl I ne.
The currently approved surety instrument, Irre-vocable Letter of Credit t{o.
SoOoiiOte, iisuli by The BanL of Ner York in favor of the NRC, as amended,
l{ay i0, tgg+, to tnllude a Standby Trust Agreementr lttlll be-continuously
maintained bi U|'|ETCO tn an amount-not less than t10,915,467 for.the purpose
oi complylng-rith l0 CFR rt0, Appendix A, Criteria 9 and 10, until a
replacement ls authorized by the tlRC.
Standard operating procedures shall be established and follored for all
opiratlonai proceis' activities involving radloactive materlals that are
trinaiia, prolessed, or stored. SOPs foi operational actlvities shall
enumeraie' pertinent radiation safety-practices. to be follored.
Additlonaliy. written procedures shall be establlshed for non-
9.6
actlvities i6 tnclude in-plant and environmental rnonitoring, bioassay
NFC FOFN1 3744
,:.9.1)
U.S. N. -EAR REGULATORY COMMISSION
NIATERIALS LICENSE
SUPPLEMENTARY SHEET
Docket or Refcrcncc Numb.r
40-8681
Liccnse Number
suA- 1358
March 14, 1997
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 wrltten procedures for both operational and non-operatlonal activities
shall be reviewed and approved in rritlng by the radiation safety officer
(RS0) before implernentation and rhenever a change in procedure is proposed
to ensure that proper radiation protection principles are being applied. Ir
addition, the RSO shall perforn a documented revier of all existing
operating procedures at least annually.
Before engaging in any activity not previously assessed by the
licensee shall administer a cultural resource inventory. All
associated with the proposed development rill be completed in
ltRC, the
di sturbances
compl i ancerith the l{ational Historic Preservation Act (as amended) and its
implementing regulations (36 CFR 800), and the Archaeological Resources
Protection Act (as amended) and its implementing regulations (43 CFR 7).
In order to ensure that no unapproved disturbance of cultural resources
occurs, ioy work resulting in the discovery of previously unknown cultural
artifacts shal'l cease. The artifacts shall be inventoried and evaluated in
accordance rith 36 CFR Part 800, and no dlsturbance shall occur until the
ljcensee has received authorlzation fron the NRC to proceed.
The licensee shall avoid by proJect design, rhere feasible, the
archeological sites deslgnated 'contr{butlng' in the report submttted by
letter dited July 28, 1988. l{hen it is not feasible to avoid a site
designated 'contributing' ln the report, the licensee shall institute
recovery progran for that site based on the research design submitted by
a
b
datr
Utai
recovery progran for that site based on the research deslgn suDmrx,Eeo D
letter from C. E. Baker of Energy Fuels Nuclear to ilr. ilelvin T. Smith,
State Historic Preservation 0fflcer (SHP0), dated April 13, l98l'
The licensee shall recoyer through archeologlcal excavatlon all
'contributing' sites ltsted ln the report rhlch are located ln or within
100 feet of Sorror .reas, stockpile lreas, constructlon areas, or the
perineter of the reclainred taillngs lmpoundment. Data recovery fieldwork al
bach stte neetlng these criterla iha'll be completed prior to the start of
any proJect related dtsturbance rithin 100 feet of the site, but analysis
and report preparatlon need not be complete.
AddltlonalIy, the llcensee shall conduct such testing as is required to
enable the Conmisslon to determine if those sites designated as
"Undetermined' in the report and located rithln 100 feet of present or knowt
future construction areai are of such slgnificance to warrant their
redeslgnation as'contrlbuttng.'In all cases, such testing shall be
coqleted before any aspect of the undertaking affects a slte.
Archeological contractors shall be approved in rriting by the Conmission.
The Cornnission will approye an archeological contractor rho meets the
mininum standards for a principal investigator set forth in 36 CFR Part 66,
Appendlx C, and rhose qualifications are found acceptable by the SHP0.
NRC FORM 37.1A
(7.S.)
10. I
10.2
10.3
10.4
U.S. .:LEAR REGULATOBY COMMISSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
suA- 1358
Dockct or Rcfetencc nrff-g5gl
9.8
March 14, 1997
itriii not Ue tranif.liei fiil the site without spggific prior-approval of
iii. xnC in the fonn-of a license amendment. The'licensee shall maintain a
;;,ril.i'relorO-oi all transfers made under the provisions of this
condi ti on.
4i
sECTror{ 10: on"$ionar .s'tb}, fla-}' (ffistri.E'
The mitt glductipn.rGWtons of powcake per vear'
The licensee is hereby authorized to possess byproduct material in the form
of uranium waste iaiiingi ind other uianium bypioduct raste..generated by the
ii..ni..ti milling-opeiitions authorized.by this license. .l{ill-!tlJ.tlS:.
9.9 The licensee is hereby exempted from the lgquiremnts of Section 20.1902 (e)
of l0 cFn-iirt 20 fofareas rithin the mill, provided-that all entrances to
the miii'-.re ionspicuousiy posted in accordante rith Section 20.1902 (e) and
with the ioiai, 'irny ..AITry HErnd \rr**ain
radioactive
m a t e r i
t. t i tt t *.*Y, I I !
*iti',:::t, :I; o[#mA, Ii i, i x l' ] nx', l[,,,. n.9. l0 ReIeas
accordaccordance rith\Sridel ines for Decontamination oTncll lf les an(I _tgurPmerrL;;i;;il-i.ii)-for-Unrestricted Use or Terminatio(.)f Licenses for
bri.lar.t;-$r[.^irt-Si.ii.i-rritear l'laterial,' $tE{!av 1987, or suitable
ai Lernative, {Socedq$aSproved by the }lRC pli.sf-t, atry/uch re lease'
iiiriiii'ffi1iffitI $;rff!r:r rr'n'
:Htntl.':,'.t::1fi.:9:tillfi ::,::$ts.,iN HlL' l::;[:]' r !l r g g+
and llay 23, 1995, rith the f,moitgflldifion:
A. The naxlmun ltft thlckness for materfals placed over tatlings-shall be
less than r-ieei ttrict. Subiequent lifts'shall be less than 2-feet
thtck. Each iiit-itrill be comjacted by tracktlg of heavy equlpment,
such as a cit'i:6,-ii i.itt I ttmes prior to plicenrent of subsequent
I i fts.
suhnittal dated t{ay 20, 1993, the Iicenset-UiproAuct materlal generated at licensed
to- the folloring condltions:
to 5000 cubic yards fron a single source'
In
is
in
accordance with the Ilcensee's
hereby authorized to d
situ leach facilities,dispose of
subject
I imited
I0.5
A. Disposal of waste is
NRC FORM 374A
{7-94)
10.5
r0.7
SECTIOi{
r1.I
11.2
U.S )LEAR REGULATORY COMM]SSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
Liccnsc Numbcr
suA- 1358
Dockct or Reference *"TFASA,
March 14 1997
B.All contaminated equipment shall be dismantled, crushed' or sectioned
i;'ri;i;ii. ,oii ipi.Li. Barrels containing waste other than soll or
iirag;i t[irr ue ehptied into the disposal irea and the barrels
;il;il|.- Earrels-cbntiining soil or iludges shall be verified to be
i;ii';;io"-io'aiipoiii. gairels not completelv full shall be fllled
rith tailings or soil.
C. AII raste shall be buried in Ce'll ilo. 3 un'less_prior written approval
ii-oUiiined fron the tlRC for alternate burial Iocations.
\The licensee (tuthorized to receive and-procerr-r@5..materials from the
alt iart (tnnr.l cnrilationrs lletroool ls. Iti inots, -fao(Dty in accordance
ll I i't n :' :trJ w(o:i :l'3 ll I' i,i' ffi A
H i, I l' ! I f, :', : :' n *i$x. I.ffif, ?, ?{ {#:. : : x I : E li i i : l,r : : ::
s sourcFf,arerlal rrom
accordattC rtth the
amended @ letters datedAl I ied Slgqill, lnc. cr
amendment\lequest date
D. AtI disposal activifies shall be documented. The documentatton shallv
i;:iii:{ii*6+$*F,}BF##,t-rl.*i:ii'ilfiIi":iilll.tt'.-xic S" ^/;
illHiilit rlhiltillf:
The llcensee shall rmpteknRtrd*rffint tana environmental rnonitoring
Droar.r soeclfled in secilon s.s-ii-itre-'ienewat application as revlsed rith
ltre-totloilng modtfications or additions:
A. Stack sampllng shall tnclude a determination of flor rate'
B.Surfrce rater sanples shall alto !9 analyzed seniannurll{-fll-total an<
;ill;il.;'i]i'.i,Ti:iz6l-ira-i[ - zio, -iit-tr the. except I 91^9I !!:il:ilii:; il;i: ir'rir,-},iii 6; '.rpted innuallr rbr. *al!::-:e91ryT!:
and analyzed as .6lrll -ii-iiai*ti ii'pta-it'lll-19!,P:.l1ken in place
lr'.1ii'.il.iiri-rniest a rater samplb ras not available'
c. Groundrater sampllng shall be conducted in accordance rith the
iequire*ents in' Licinse Condition ll'3'
NRC FORM 374A
(7.94)
1l .3
1l .4
MATERIALS LICENSE
SUPPLEMENTARY SHEET
U.S :LEAR REGULATORY COMMISSION i PAGE 7
Licensc liumbcr suA- l35g
D. The I icensee
Section 5 ofeffl uent and
Dockct or Rcfcrencc n"f0Tg6gl
March 14 199 7
shall utilize lorer limits of detection in accordance with
n.gutatory Guide {.14 (Revision l), for analysis of
envi ronmenta'l samPI es .
E. The inspections performed semiannual]y of the critical orifice assembly
comittlO to-in lhe suhnittal dated l,lirch 15, !989, tttl]J be
aoJumentea.- iiie-iriiicit orifice assembly shall be calibrated at least
ev.iy 2 years igainst a positive displacement Roots meter to obtain the
required cal ibration curve.
The Iicensee shall implement a groundwater detection monitoring program.to
iiii,'i-io''pi i i'ii to io qqtpw, ffi #Hliirl;.rlti.f 'ff:i :1,::?t :"' :,tffi3iil.:I'ln?t.'H[#l*i ]t,r, " submnt{d;y retter dated october 5,
1994, as m6difie$t/the following, ^ra^
0."'rn. ;;d;,..-rrr..; r;; au ponds ,i1;ehecked lgerrv. rf
iiqria}ir-eseqt, ii shall-be anai vzed for c|l1f,.t'^:yll1l:'.^
iii:*mlffih*k,i:ihliiiii:ffifl #*.i:ilii! Ii,,,.lH:ltda I
B l',#3:,'
:llffii*liil:,i[I:":il:t tlH.
c. rle r ft ::.i.Heffi Mffi;*1,";'?;,-1ili.;li;
submfrtid to t{Rc..{BNiery--\ / f,6 o
Ix:Is;'I ;lfr,ir.:li:1,ii':iiit
Il.ii:iini{fi ro cFn {c 6{,t
potassflurr nickEl, +d rlrir
be i ncl u[grd-rt th _ !h9_inY1,
al I Der{Datyzeo ror cnlorlqe'
sultrJPsuth samPling shallinS.{$rts submitted ln
!:fi ii:il;il ffi{#iul,i,x*sl#' #i.i :
ii,t,ir i:t,t,
I imits.
Durlng periods of standby, sampling frequencies^for area airborne uranium
;;piir6-iii[tn irti-"iii'i,.t-it itiucea'to quarterly, provided measured
levels rematn uei6i io peicint oi-tfie-oertvdo atr cirncbntratlon (DAc).-.If
these levelr.r...i iO [ircent oi itte DAC, the !a!Pling frequency should
ioiior the recoornendatibns in Regulatory Guide 8.30.
Calibratlon of in-ptant air and radiatlon monitorlng equlpment shall be
performed ., ,p.liiita in the littnit ttneial-aPpliiation' under section 3'
of the .Radiation Protectlon proieaui.s il.nu.l,h'with the exceptton that
in-plant air r.rptiG ;qripment.;h;it-Ue iaiiUiated at 'least quarterlv and
iir'iirpting equipnreit dtretks shall be documented.
11.5
NBC 3ORM 3744
, :-9j)
U.S.' .EAR REGULATORY COMMISSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
Liccnse )iumbct
Docket or Refertnce i
suA- 1358
40-8581
11.5
SECTI0N 12: Reporting Requirements
The Iicensee shall suhtit to ilRC for revieu, bJ June-30, 1997' a detai'led
rllriiition-piin-ioi-it. authorized tail ings disposal area which includes
the folloring:
rhich details methods to
of the tatlings area.
dewater and/or consol idate
final reclamation cover.
The Iicensee shall perfonn an annual ALARA audit of the radiation safety
program in accordante with Regulatory Guide 8.31.
t2.l
A. A post-operations interim stabilization plan
prlvent irind and rater erosion and recharge
B. A plan to detennine the best methodology-thl tailings cells prior to placement of
C. plan and cross-sectional viers of a final reclaatation cover which
aeiiiii ttre-io..iion ind elevatlon of taillngsr Ih. plan shall includr
details on cover thickness, physical characteristics of cover
,ii.riiIs, ;;oposeJ teitin6 bfcover nraterials (specifications and
quiitti .irliiii.l, tt. esltmated volumes of cover materials and their
availabil itY and location.
D. Detalled plans for placement of rock or vegetative cover on the final
reclairned'tatlings pile and nill site area.
E. A proposed implementation schedule for items A through D above rhich
aehinls the slquence of events and expected tlme ranges.
An analysls to show that the proposed type and.thtckness of
ii iaeoirate to provide attenuitibn of radon and is adequate
ionq:td*-itaUtilty, as rell as an analysls and proposal on
inA-ti* riqutreA i6 restore ground rater in conformance to
requi rennnts.
G. The llcensee shall lnclude a detailed cost analysis of each phase of
the recl.naifon-pian io-inciude contractor costs, proJected costs of
lnflation fi;a lion tt. ichedule-Pryposed in item E, a proposed
contingen.y-iost,-and ttre costs of' Iohg-term malntenance and
monitorl ng.
to
the
F.soil coverto assure
methodo'log
regul atory
EAR REGULATORY COMMISSION ,oGE 9 Ot 9 ooGES
,lNRC FOAM 3744
7-9J)
12.2
Liccnse Number
MATERIALS LICENSE
iuppueueNTARY sHEET
SUA- 13s8
-ir
ffii nctttence Numbcr
40-8681
adetaileddecorrmissioning.plantotheNRCatpitii"li'pi.nnli"]i;;i-;hiiidbrn of miII operatlons.
FOR THE NUCLEAR REGULATORY COIT{ISSIOT{
[rinium RecoverY Branch
oiriiion of Haste l{anagement
oiiili-iir-trucie.r tlateii al Safetv
and Safeguards
The I icensee
least twelve
shall submit
(12) months
"Guidel ines for Decontaminatigl 9l-11::lil::t,,:y Equipmentplil'"ii-iiiilii. roi unrestli:!:1.u':
o, r.rli',llli ii i}' ii;;';ii r9I.-BIIo-d,u"'t' Source'
;;'bp..i.t tiuil ear t{a{dri al "
l{ay 1987 revision
Enc'losure 5
Gt,tDFL:liES FclR oECOtlIAltlNATI0l'! 0F FACILIIIES pN0 Eol'! Fl',lENT
PRIOR TO RELEA:E FOR IINRESTRICTEO UST
OP TERI{tNATIOII OF LICENSES FOR EYPROOUCT. SOURCE,
OR SPECIAL T{UCLEAR HATERIAL
U.S. Nuclear Regulatory Conmission
Dlvision of Fuel Cycle, l{edica'l . Academic,
and Conmercla'l Use SafetY
t{ash i ngton. DC 20555
llay 1987
i
rhe :nstructions in thls eu'ide, in conjunctlon with 1661e l, specif.r therac'innr.lc'lides and radiation exposure rate I imits which should be ,rsec in
deconteF:'ination and surve_v of srrr'66g5 or prenises and ecuipment prior to
abandonnreni or release for unrestr':cted use. The limits in Tehle I rjo notapply to premis!s, cQuipment, or scrap ccntaining induced radioactivity forwhich the radlologlcal considerations pertinent to thelr use may bedifferent. The release of such facil ities or ilsrn5 f:.om requlatory cc.ntrol is
ccns idered on a cdse-by-case.
l. The llcensee shall make a reasonable effort to eliminate residual
contaminatlon.
2.
3.
Radloactlvity on equipment or surfaces shal I not t''e covered by paint,platlng, or other coverlng materlal unless tontamfnation leveis,.sdetermlned by a survey and r'focumented, are belov the I lmlts specif {ed inTable I prlor to the applicatlon of the coverlng. A reasonable effortmust be made to r:rinimlze the contamlnation prlor to use of any covering. -
The. radioactiyl!y on the interior surfaccs of plpes, draln I lnps, orductwork sha'll be deten'rined b.v maklng measurements'at al I r.raps i andother approprlate access point!. providpd that contaminailon at r.heselocailons ls lilely to be representative of contam'!natlon on the interior6r ?.h€ 9ipes, drain llnes, or ductwork. Surfaces of premises, ioufpment,0r scrap vhich are lil.ely to be contaminated but are of such ilze,construction, or location aS to make the surfrce inaccesSibie for purposesof measurspsTll shall be presumed r.o be contaminated {n excess of tire iimits
upon request, the conrn{ssion may authorlze a llcensee to relinquishpOSsession or contrnl of premisesr equipment, or scrap havlng surracescontiplinated xith naterlrls {n excess of the llm{ts speciflei. Thls rnayinc'lude, but vould not be limited to. speclal clrcumstances such as razinqof 9uildlngs,.transfer to premlses to another organlzatlon continulng xorkrith raCloactlYe nateritls. or conversation of ficilit{es to a 'long-ierm
storage or standby status. Such requests nust:
a. Provlde detailcd. specif{c lnfornation describtnqr the premises,
equlpnent or Scrap, radioactive conttmlFants, and the nature, extent,and deqrcc of residual surface contamlnatlon.
b. Provlde r detrlled health and safety analysls whlch reflects thrt theresldurl trEunts of materials on suiface ireas, toqether xlth otherconsideratlons srlch as prospectlve use of the premises, eoulpnent,or scrap, are unlikely to resu]t ln an unreasonable risk r.o thehealth and safetY of the publlc.
4.
5.Prior to release of premises for unrest-ri6g66 us8, r.frg 'licensee shall
mate a comprehensive radiatior survey which establ isl'ps that contaminatior: is
within the limiti tp*.ifi26 in Table l. A cop.v of the survey report shall he
flls( with the niviilon oe Fuel Cycle, Hedlcal-, Academic, and Cotnerc'ial tlse
Safeiy. fi. S. Nucrear Regulatorv eorrrnission, l{dshinqton, 0C 20555, and also
the Aimlnistrator of the-t{RC Re'elona'l 0ffice havlng jurlsdlction. The repor?-
inorfd be flleC at least -10 dayi prior to the planned date of abandonment.
The survey rePort shall:
a. ICentify the Premlses.
b. Show that reasonable effort has been made to ellm{nate residual
contaml na t I on .
c. Oescrlbe the scope of the survry and qeneral procedures folloxed'
d. State the flnd{nos of thc survey ln unlts speclfled tn ihe
lnstructiun.
Folloylno rev{ew of the repor'?.. the riQC will conSlder vlsltlng the
f ac I I i t i es to conf I rn the surve.Y
G,D
oan,
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o
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