DRC-2004-001121 - 0901a068809be154

DRAFT
Utah Division of Radiation Control
Ground Water Quality Discharge permit
Statement of Basis
For a
Uranium Milling Facility
At White Mesa, South of Blanding, Utah
Owned and Operated by
International Uranium (USA) Corporation
Independen ce Plaza, Suite 950
1050 lTth Street
Denver, Colorado 80265
December 1,2004
Purpose
The purpose of this Statement of Basis (SOB) is to describe technical and regulatory basis toproposed permit requirements found in a Ground Water Quality Discharge pirmit No.
UGW370004, (hereafter Permit) for the International Uranium (USA) Corporation (hereafter
IUC) uranium mill facility located about six miles south of Blanding, Utatr-on White Mesa inSections 28,29,32, and 33, Township 37 South, Range 22East,Satt tat<e Base and Meridian,
San Juan County, Utah.
Introduction and Historv
The White Mesa uranium mill was constructed in 1979-1980 and licensed under federal
regulations by the Nuclear Regulatory Commission (NRC), Source Material License SUA-135g(hereafter NRC License). Initially, the facility consisted of the mill works and one tailings
disposal cell, Cell 2, which was completed in May, 1980 (2182D'Appolonia Consulting
Engineers Report, p. 3-l). In June, 1981 construction of a wastewater storage pond, Cell l, wascompleted (ibid., p. 1-l). Construction of a second tailings cell, Cell 3, was completed inSeptember, 7982 (3/83 Energy Fuels Nuclear Report, p. 1-2). Finally, tailings disposal Cell 44was completed in January, 1990 (5l28l99IUC Groundwater Information Report, p. A-ll).
However, Cell 44 has not been used yet for tailings disposal, but instead foi storage of raffinate(personal communication, Mr. Harold Roberts).
Groundwater at White Y:.u is primarily found in twp aquifers: a shallow unconfined or perched
aquifer, and a deep underlying confined aquifer. The shallow aquifer is found almost entirely inthe Cretaceous-age Burro Canyon Formation, where groundwater is perched on top of theunderlying Jurassic-age Brushy Basin Member of the Morrison Formation. The Brushy Basin
Member is about 200 - 400 feet thick and consists of low permeability shale and mudstone in theBlanding area (Hintze, p. 200). At White Mesa,IUC estimates that the Brushy Basin member is
about 295 feetthick (7194 Titan Environmental Report, Fig. 1.2). From information provided byIUC, the geologic contact between these two formations is found at a depth of about 78 to l4g '
feet below ground surface (bgs, see 9t6lO2IUC map submittal). The water table in the perched
aquifer is found at shallower depths, and discharges to seeps and springs along the margin ofWhite Mesa. Upgradient of the mill site, the perched aquiier is usid f* a.irtirg water, stock
I
Statement of Basis DRAF'T December 1,2004
watering, and irrigation. Downgradient of the mill site, the perched aquifer supports stockwatering and some wildlife habitat.
The deep confined aquifer under White Mesa is found in the Entrada and underlying NavajoSandstones. IUC estimates the top of the Entrada Sandstone at the site is found at a Aeptn tfmore than 1,150 feet bgs (7l94Titan Environmental Report ,Fig.2.3). This deep aquifer ishydraulically isolated from the shallow perched aquifer by at least two (2) shale members of theMorrison Formation, including the Brushy Basin t-295 feet thickl and the Recapture [- 120 feetthickl Members (ibid., Fig. 1.2). Other formations are also found between the perched and deepconfined aquifers, that also include many layers of thin shale interbeds that contribute tohydraulic isolation of these two groundwater systems, including: the Morrison Formation
Westwater Canyon [- 60 feet thick], and Salt Wash I- 105 feet ttrictl Members, and theSummerville Formation [- 100 feet thick] (ibid.). Artesian groundwater conditions found in thedeep Entrada./Navajo Sandstone aquifer also reinforce this concept of hydraulic isolation fromthe shallow perched system. Regionally, the deep confined aquifer is the primary drinking watersupply, and must be protected from pollution sources. A few miles south bf the mill site the UteMountain Ute community depends on this deep confined aquifer for drinking water supply.
Between 1979 and 1997 the initial groundwater monitoring program approved by NRC for thefacility examined up to l3 wells and 20 different chemical and iadiological contaminants; Iargelycollected on a quarterly basis. In 1997 , after examination of the histori-cal data, the NRC reducedthe monitoring program to six (6) point of compliance (POC) wells in the perched aquifer, allfound a short distance south of Tailings Cells 3 and 44. These include IU-C wells MW-5, MW-I l, MW-12, MW-14, MW-15, and MW-17. At the same time the NRC reduced the number ofanalytical parameters to four (4) contaminants that the NRC considered dependable indicators oftailings cell leakage: chloride, nickel, potassium, and uranium. This is the same quarterly
monitoring program recently used by IUC to demonstrate compliance with its NRC License.
Under the NRC approved program IUC uses an intra-well control chart method to determinecompliance. This method compares recent groundwater quality results in each individual pOC
well with a control limit for each analye. In practice, control limits are calculated individuallyfor each monitoring well and analyte, based on historical or background data that has not beenaltered or influenced by the activity in question (EpA, February, tggg, pp. 7-l andT-12).Determination of non-compliance occurs when a recent concentration exceeds its individualcontrol limit on the control chart (ibid. ,7-5). Information provided by IUC shows that controllimits were established under the NRC License for four urulyt.r, chloride, nickel, potassium,
and uranium (9l94Titan Environmental Report, Appendix B). Since l9l9,theMill has notreceived any violation under its NRC approved groundwater monitoring program. To verify thisapparent compliance, the Executive Secretary has required submittut ofun historical BackgioundGround water Quality Report, pursuant to part I.H.3 of the permit.
In May, 1999ruC and the Utah Division of Radiation Control (DRC) commenced an annualsplit sampling program for groundwater monitoring wells at the White Mesa facility. Thisprogram was comprehensive in that it included all monitoring wells at the facility completed inthe shallow aquifer (not just POC wells), and a large number of groundwater contaminints,including: heavy metals, nutrients, general chemistry analyes, *diologi.r, and volatile organiccompounds (VOCs).
Statement of Basis DRAF'T December 1,2004
During the May, 1999 split sampling event excess chloroform concentrations were discovered inmonitoring well MW-4, which is not a NRC POC well, found along the eastern margin of the
site. Because these concentrations were above the State Ground Water euality Standard
(GWQS), the DRC initiated enforcement action against IUC on August 23,lggg thru issuance of
a Groundwater Corrective Action Order, which required completion of: l) a contaminant
investigation report to define and bound the contaminant plume, and2) a groundwater corrective
action plan to clean it up. Repeated groundwater sampling by both IUC and DRC have
confirmed the presence of chloroform in concentrations that exceed the State GWeS along the
eastern margin of the site in wells that appear to be upgradient or cross-gradient from the tailingscells. Other VOC contaminants have also been detected in these samples. After installation oi
20 new monitoring wells at the site, groundwater studies appear to have defined the eastern and
southern boundaries of the chloroform plume. IUC believes the source of this contamination
was caused by laboratory wastewater disposal activities that pre-dated mill operation. While the
exact number and location of all the potential chloroform sources is still not yet resolved, an
experimental long-term pump test was initiated in April, 2OO3 to investigate one possible cleanup
methodology.
While the contaminant investigation and groundwater remediation plan are not yet complete, the
DRC believes that additional time is available to resolve these requirements based on thefollowing factors: 1) hydraulic isolation found between the shallow and deep confined aquifers,2) the large horizontal distance and the long groundwater travel times betwein the existing
groundwater contamination on site and the seeps and springs where the shallow aquifer
discharges at the edge of White Mesa, and 3) lack of human exposure for these strallow aquifer
contaminants along this travel path. Upon completion of the contaminant investigation and
before approval of the groundwater remediation plan, the DRC will provide a public commentperiod and hearing to inform the local community of the planned cleanup actions and receive
comments thereon.
With all this as a backdrop, the NRC delegated its uranium mill regulatory program to the State
of Utah, effective August 16,2004. As a result, the DRC is the primary rlgutatory authority for
the IUC White Mesa mill for both radioactive materials and groundwater piotection. Shortiy, theexisting NRC Source Materials License will be converted to a State Radioactive Materials
License (RlvII-). In this process, this proposed Permit will replace the groundwater protection
provisions of the NRC Source Materials License.
After review of the existing design, construction, and operation of the IUC facility; and after
consideration of the requirements in both the Utah Water Quality Act (Utah Code Annotated 19-5) and the Ground Water Quality Protection Regulations (Utah Administrative Code R3l7-6),
the DRC has determined that a number of changes and enhancements are required in order to
meet State requirements for groundwater protection. These changes are discussed in detail
below.
Maior Permit Requirements
1. Groundwater Classification (Part I.A and Table 1) - was assigned by the Executive
Secretary on a well-by-well basis after review of groundwater quality characteristics for
the shallow aquifer at the IUC White Mesa site. A well-by-well approach was selected
by the Executive Secretary in order to acknowledge the spatial variiuitity of groundwater
J
Statement of Basis DRAFT December 1,2004
quality at the IUC facility, and afford the most protection to those portions of the shallow
aquifer that exhibited the highest quality groundwater. Details regarding this
classification at the IUC facility are discussed below:
A. TDS Background Concentrations - the Executive Secretary has established a
general policy that allows groundwater classification to be based on a statistical
construct of the mean total dissolved solids (TDS) concentration plus the second
standard deviation (X+2o). Using a well-by-well approach, this X+2o value
would be derived from available data from each individual well. Inherent in this
approach is the assumption that the TDS data used for this basis is composed
solely of data representative of background or natural conditions at the site, and
not groundwater quality altered by the facility in question.
In determination of the background TDS concentrations, the Executive Secretarytypically considers concentration trend or time series analysis. Spatial analysis of
the data may also be considered to evaluate proximity of the r"pon"d
concentrations to possible contamination sources. Increasing contaminant trends
in individual wells, spatial contaminant distribution patterns, and other statistical
considerations may be used to identify the presence of man-caused groundwater
pollution at the site. These types of evaluations are especially important at
existing facilities that pre-dated the 1989 promulgation of the CWep rules; such
as the IUC White Mesa site.
Evaluations of this kind will be submitted shortly by IUC in the Background
Groundwater Quality Report (part I.H.3), and reviewed by the Executive
Secretary. Pending this submittal, the Executive Secretary has decided to base thewell-by-well groundwater classification on the average TDS concentration
available, and omit any consideration of concentration variance. This approach isconservative, in that it will result in a generally lower concentration basiJ for theclassification decision. At some future date, when such evaluations are available
and found acceptable by the Executive secretary, the background rDS
concentrations will be revised, and the Permit re-opened and modified, pursuant
to Part tV.N.2 or 3 of the Permit.
wi - IUC
has demonstrated that four (4) existing wildlife ponds at the White Mesa facility
discharge water to the shallow aquifer, that in turn has created two (2) local
groundwater mounds; one (l) each at the Northern and Southern Wildlife ponds
(see 10/15/02ruc submittal, water level map). The existence of these
groundwater mounds has been confirmed by the Executive Secretary thru both
independent water level measurements and preparation of a water table contour
map for the White Mesa facility for the September,2OO2 split sampling event (see
Attachment 1, below).
The quality of water maintained in these wildlife ponds is likely high, in that it isderived from Recapture Reservoir. Water from this reservoir is conveyed to theIUC facility via a buried pipeline, where part of the supply is used in milling
operations, and another part is diverted to the wildlife ponds to support aquaticlife and habitat for migrating waterfowl (personal communication, Mr. Harold
Roberts, IUC). No lining system was constructed under any of the wildlife ponds(ibid.). As a result, the wildlife ponds provide a nearly constant source of highquality recharge to the shallow aquifer at the site. Therefore, it is possible th-at
B.
Statement of Basis DRAFT December 1,2004
this recharge has significantly improved localized water quality conditions in the
shallow aquifer; thereby encouraging a wide variability in quality conditions.
This and other sources of water quality variation give rise to the need for well-by-well protection of groundwater quality at this site.
C. TDS Basis for Classification - one key element in determination of groundwater
class is the TDS content of the groundwater, as outlined in the CWQp Rules, see
Utah Administrative Code (UAC), R317-6-3. Groundwater quality data collected
by both IUC and the DRC show the shallow aquifer at White Mesa has a highly
variable total dissolved solids (TDS) content, ranging from about 600 to over
5,300 mg/l (see Attachment 2, below).
Using all available TDS data, and after calculation of average TDS concentration
for 33 wells including both POC and temporary wells, the Executive Secretary
determined that 16 wells at the facility appear to exhibit Class II or drinking water
quality groundwater. Seventeen (17) other wells appear to exhibit Class III orlimited use groundwater at the site. For details, see Attachment2,below.
Close review of the available data shows that the historical IUC data, the recent
IUC split sampling data, and the corresponding DRC split sample results are
largely comparable, with a few exceptions. In the case of historical IUC well
MW-19, the IUC historical TDS data (l}t79 thru 5/99) produced an average TDS
that was significantly lower than the average TDS based on the recent DRC orIUC split sampling data (5199 thru9102). Because the older IUC data are
conservatively lower, the Executive Secretary chose to rely on the older IUC TDS
data to determine groundwater class for well MW-19.
D. GWOS Basis for Classification - another key element in determination of
groundwater class is the presence of naturally occurring contaminants in
concentrations that exceed their respective GWQS. In such cases, the Executive
Secretary has cause to downgrade aquifer classification from Class II to Class trI
(see UAC R317-6-3.6). Historic IUC data and more recent split sampling data
suggest that several groundwater contaminants may be found with concentrations
above their respective GWQS in a number of wells at the site. These wells and
parameters from recent split sampling are summari zed, in Attachment 3, below.
Some of these wells with excess contaminant concentrations are associated with
the on-going chloroform investigation at the east margin of the site (see 8t23lgg
Ground Water Corrective Action Order). With regard to historic excess
concentrations found at the site, the NRC previously deemed these to be of naturalorigin. While some or all of these excess concentrations may be natural, theExecutive Secretary has not yet fulry evaluated the available data.
For this and other reasons, the Executive Secretary has required IUC to evaluate
groundwater quality data from the existing wells on site, and prepare and submit
for approval a Background Groundwater Quality Report, in Part t.U.3 of tf,"Permit. After review and approval of this report the Executive Secretary may
determine the origin of these excess contaminant concentrations, and an
appropriate groundwater classification(s) for the White Mesa facility.
Water2.
historic groundwater quality data has been collected by
facility. In some cases, these data extend back about 25
IUC for many wells at the
years to September, 1979.
Statement of Basis DRAFT December 1,2004
However, the Executive Secretary has not yet completed an evaluation of the historic
IUC data, particularly with regards to data quality, and quality assurance issues. Such an
examination needs to include, but is not limited to: justification of any zero
concentration values reported, adequacy of minimum detection limits provided
(particularly with respect to the corresponding GWeS), adequacy of laboratory and
analytical methods used, consistency of laboratory units of reporting, internal consistency
between specific and composite types of analysis (e.g. major ions and TDS),
identification and justification of concentration outliers, and implications of concentration
trends (both temporal and spatial).
During the review conducted to date, several groundwater quality issues came to the
attention of the Executive Secretary that also need to be addressed and resolved by thePermittee in the Background Groundwater Quality Report. Some of these issues, include
the following:
Rece lVe - recent
DRC split-sampling of groundwater atthe IUC facility has found that several
contaminants exceeded their respective GWQS during one or more of the four (4)
split sampling events conducted by the DRC between May, 1999 and,september,
2002. With regards to those wells considered for tailings cell monitoring, the
contaminants with excess concentrations include the following (see Atta;hment 3,below):
l) Manganese (MW-3, MW-14, MW-32 [formerly TW4-17])
2) Nitrate (MW-4),
3) Selenium (MW-l, MW-4, MW-15, MW-17), and
4) Uranium (MW-3, MW-4, MW-14, MW-15, MW-17, and MW-lg).
The exceedances found in well IvtW-4 appear to be related to the chloroform
contamination. While the remaining exceedances may be due to natural causes,
the Executive Secretary has not fully evaluated the available data, and has
therefore required IUC to perform this evaluation.
Wells - while recent
A.
B.
groundwater quality data from the last lS-months suggests a stable or decreasing
trend, the long-term uranium concentrations for the last l1 to 15 years indicate an
increasing trend exists in three (3) downgradient wells at the IUC facility,including: Mw-14, Mw-15, and MW-17 (Attachment4,below). IUC Lelieves
that the cause for these increasing uranium trends is due to geochemical changes
brought on by the effects of the groundwater mound created by the nearbywildlife ponds. While evidence to substantiate this has yet to be provided to and
approved by the Executive Secretary, the exact cause for these long-term
increasing trends is currently unknown, and may be due to a variety of factors that
deserve further study and explanation.
Downgradient uranium Spatial concentration High - the same three (3)
downgradient wells that exhibit a long term increasing uranium trend are alsofound near a spatial concentration high, located downgradient of Tailings Cell 44.A fourth well, MW-3 is also found inside this concentration high and eiceeds the
State GWQS (30 ug/l). For details, see the uranium isoconceniration map based
on September,2002 DRC split sampling results in Attachment 5, below bnc
6
C.
Statement of Basis DRAFT December 1,2004
map U238-9-02.sO. As shown there, well MW-14 represents the maximum
uranium concentration during the September,2002 split sampling event (56.7
ug/l). It is interesting to note that the average linear groundwateivelocity
(hereafter velocity) found in well MW-14 is one of the highest on site, 62
feetlyear (l0ll9l04 Hydro Geo Chem,Inc [HGC] Report, Table l). Furthermore,
well MW-14 appears to be located on an apparent preferred groundwater flow
path found between it and well MW-l1 which has the highest velocity at the site,
135 feetlyear (ibid., and Attachment |2,DRC groundwater velocity contour mapgwfl owrate. srf, below).
Two other uranium concentration high points exist at the White Mesa site where
uranium exceeds the State GWQS, including IUC wellsTW4-L9 andTw4-ll (see
Attachment 5, DRC mapU238-9-02b.srf). However, these two wells appear to be
associated with the chloroform contamination plume.
The cause for the uranium concentration highs found downgradient of Cell 44 and itscoincidence with an apparent preferred groundwater flow path is unknown at this time,
and may be due to a variety of factors that deserve furtheritudy. These observations andothers indicate that great care must be taken by the Executive Secretary in determinationof background groundwater quality for the compliance monitoring wells at the site; in
order to ensure that any GWCL established by Permit has not been affected by historicfacility operations. As a result, a detailed evaluation of these and other ground waterquality concerns was added to the Permit in Part I.H.3 (Background Groundwater eualityReport). After submittal of this report and resolution of these and other groundwater
quality issues, an agreement can be reached regarding descriptive grounJwater quality
statistics and determination of background groundwater quality at ihe IUC faciliiy. Atthat point, the Permit will be re-opened and the background groundwater concentrations
and related compliance limits modified, see discussion below.
Because Part I.H.1 of the Permit calls for installation of several new monitoring wells
around the tailings cells, background groundwater quality will also need to be determined
for these monitoring points. To this end, Part I.H.4 was created to require IUC to collect
at least eight (8) quarters of groundwater quality data, and submit a seiond report for
Executive Secretary approval to establish background groundwater quality foi thesewells. Upon approval of this report, the Executive Secretary will r"-tp"n the permit andestablish groundwater classifications, background ground water quality concentrations,
and compliance limits, as appropriate and authorized by part IV.N.2 una:.
3. Ground Water Compliance Limits (Part I.C.l) - the GWQP Rules provide for the
determination of Ground Water Protection Levels (GWPLs) to be used as early-waming
indicators of impending groundwater pollution. Under this approach, compliance isdetermined after comparison of groundwater quality monitoring results with the GWpLsin each well and for each parameter. Said GWPLs are set in the permit after
determination that the particular contaminant is detectable in groundw ater atthe facility,its corresponding GWQS, and its analytical Minimum Detecti,on Limit (MDL). As
provided in the GWQP Rules, these GWPLs are calculated as outlined in Table 1, below.
Because background groundwater quality at the IUC facility has not yet been approved,
the Executive Secretary cannot determine if any contaminant is naturllly occurring and
therefore detectable or undetectable for purposes of selecting GWpLs in each well.
Consequently, the Executive Secretary will initially assign t[e GWpLs as if they were
7
Statement of Basis DRAFT December l,2OO4
"undetectable". After submittal and Executive Secretary approval of the existing well
Background Ground Water Quality Report, pursuant to Part I.H.3, the permit can be re-
opened and the GWPLs modified, see discussion below. Accordingly, the GWpLs set
today in Table 2 of the Permit were calculated by use of the classification factors, being
0.25 and 0.5 times the GWQS for class tr and III groundwater respectively.
Table 1. General Ground water Protection Level Determinations
l) BG = background concentration2) MDL = minimum detection limit
During a meeting of August 12,2OO3,IUC staff expressed a concern with this approach
in that it does not recognize spatial variability of groundwater quality in the aquifer.
Accordingly, ruC asked the Executive Secretary to downgrade the aquifer classificationsfor the White Mesa Facility, from Class II to Class III, in order to ensure that a large
enough factor is used in determination of the GWPL, so that natural temporal variations
in groundwater quality at each well do not cause unnecessary non-compliance under thePermit. At the heart of this concern is the need to avoid false positive violations of theGWPLs assigned under the Permit; unnecessary groundwater monitoring and analytical
costs; unneeded enforcement efforts; and undue public concern.
The Executive Secretary acknowledges these concerns, and in an effort to address them
has arrived at an alternative approach to groundwater quality compliance that will
recognize natural variations and still protect the groundwater resource. This approach
incorporates the use of Ground Water Compliance Limits (GWCL) on a well-by-well
basis, instead of GWPLs. Under the GWQP Rules, groundwater quality compliance is
determined in a step-wise fashion, as follows [see UAC R317-6-6.16(,{) and iB)1:A. Accelerated Monitoring [UAC R317-6-6.16(4,)l - if the concentration of a
contaminant in any sample exceeds the Permit limit, then the Permittee is requiredto initiate more frequent groundwater quality monitoring to determine the
compliance status of the facility. Because this section generically refers to a"permit limit" and not specifically to the GWPLs defined in UAC R317-6-4, the
Executive Secretary has the latitude to use another basis to determine a maximum
contaminant concentration for groundwater quality compliance purposes at apermitted facility.
This maximum contaminant concentration is referred to in the IUC permit as a
Ground Water Compliance Limit (GWCL), and will be defined as the mean
concentration plus the second standard deviation (X+2o). This GWCL will bedefined on a well-by-well basis for each key indicator parameter required for
groundwater quality monitoring at the IUC facility. On a statisticalbasis, and
after collection of a sufficient number of samples, the Xf2o concentration
corresponds to the 957o upper confidence limit; which equates to a2.5Vo (0.025)
probability of any parameter in any well falsely exceeding its GWCL during anygiven sampling event.
Groundwater
Class
TDS
Limit
Groundwater Protection Levels
Undetectable Contaminant
(greatest ofl
Detectable Contaminant
(greatest oOII1.25 * BG ('0.25 * GWOS MDL (,)1.25 * BG 0.25 * GWOSm1.25 * BG 0.5 * cwos MDL 1.5 * BG 0.5 * GWOS
Statement of Basis DRAFT December 1,2004
ance status tUAC R317-6-6.16(B)l - the IUC facility will beB.
considered to be out of compliance when two (2) consecutive groundwater quality
samples exceed the respective GWCL (X+2o concentration) for each well andcontaminant in question. On a statistical basis, and after collection of a sufficientnumber of samples, this equates to a O.O62Vo (0.O25l probability that any givenwell and parameter will twice, consecutively, falsely eiceed its;espectiveGWCL'.
Pursuant to these considerations, Table 2 of thePermit has been structured to provide themean concentration, the standard deviation, and the GWCL (X+2o) for each ctmpliancemonitoring well and monitoring parameter required at the facility. The ExecutiveSecretary believes that this approach will protect the local groundwater resource, in thatit: l) recognizes the heterogeneity in groundwater quality apparent at the White Mesasite by assigning ClCI,s on a well-by-well and contaminant specific basis, andZ)allowsfor natural temporal variation in the groundwater quality by use of the x+2o
concentration limit.
It is important to note that the X+2o concentration for each compliance monitoring welland contaminant must be based on the natural variance of groundwater quality at thatlocation, and not on concentrations that have been altered iy man thru p;llution. Thisissue is especially important for facilities that pre-existed the GWep Rules, which wereadopted in 1989. For this reason, the Permit requires IUC to prepare and submit for
lPProval a Background Groundwater Quality Report for existing monitoring wells at thefacility (see Part I.H.3). After review and approval of this report, the Executive Secretarywill determine the mean concentration, standard deviation, and X+2o GWCL for eachwell and contaminant listed in the Permit. In the meantime, the Executive Secretary hasset the GWCL concentrations in Table 2 of this Permit as the GWPL concentrationsdetermined by the formulas outlined in Table 1, above. Three (3) exceptions to thisinclude chloride, sulfate, and TDS, which have no corresponding GW(iS and thereforerequire pre-determination of background concentrations fo. "u"h p*u-it". and well.Consequently, the GWCL for these three (3) parameters will be determined later afterapproval of the Background Groundwater Quality Report required by part I.H.3 of thePermit. The Executive Secretary recognizes that the fractions approach used to set theGWCLs in this Permit does not account for natural variations in groundwater quality.Hence, false positives in the groundwater monitoring data may occur until theBackground Groundwater Quality Report, required by Part I.H.3 is submitted, approvedby the Executive secretary and the GWCLs ri-established in the permit.
_ the process of selecting thegroundwater quality monitoring parameters for the permit includid examination ofseveral technical factors. Each of these is discussed below.
A. Feedstock Materials - one source of contaminants that may be discharged fromthe White Mesa facility is the number and type of contaminants that -tt, occurin feedstock materials processed at the mill. During early operation of i-he White
Mesa mill, it is anticipated that uranium ores were pri-*ify derived from two (2)main sources: strata-bound deposits of the Colorado Plateau region, and solutionbreccia pipe deposits from the Arizona Strip. Natural contaminants known to
I The Executive Secretary recognizes that this probability for a false positive result applies to a given parameter in agiven well, and that the probability for false poiitires is Ligher when considering a group of wells that are sampledfor collection of parameters in the same monitoring event.
9
4.
Statement of Basis DRAFT December 1,2004
occur in these uranium ore deposits have been determined by the U.S.Environmental Protection Agency (EpA), as summarized in Table 2, below (EpA,
1995, p. l1). From this research it appears that 12 metals are common to theuranium ores processed by the IUC white Mesa facility. consequently, all ofthese metals have been listed in Table 2 of the Permit as groundwater compliancemonitoring parameters.
B.
Table 2. RaDle z. Re L ranium Ore Contaminants Near White Me*, (l)
Ore Source Known Contaminants
Colorado Plateau
(strata-bound)
Arsenic Lead Silver
Chromium Molybdenum Vanadium
Cobalt Nickel Zinc
Copper Selenium
Arizona Strip (solution
breccia pipes)
Copper sulfides Lead sulfides
kon sulfides Zinc sulfidesFootnote: l) DatafromEpA, tOlS, p. tt
Other contaminants may also have been added to the tailings waste via processingof alternate feedstocks authorized by the U.S. Nuclear Regulatory Commission(NRC). However, any evaluation made to date by the ExJcutive Secretaryregarding the number or types of contaminants that might be present in thLsealternate feed materials has not been considered here for inclusion as groundwater
compliance monitoring parameters.
Process Reagents - another source of contaminants that could be discharged togroundwater from the facility include mill process reagents. Information
provided by EPA for acid leach processing at.orr"rtioral uranium mills hasbeen combined with process information from IUC in Table 3, below. euantitiesof reagents actually used by IUC at the White Mesa mill are listed in Table 3 inbold face type. Daily volumes of reagents actually used by IUC are summarized
and ranked in Table 4, below. From this information it is Llear that the tailingswastewater disposed at the IUC White Mesa mill should have an extremely lJwpH, and contain significant quantities of sodium, chloride, ammonia, and
kerosene.
Source Term Abundance - some limited historic wastewater quality sampling andanalysis has been done at the IUC White Mesa tailings cells. Some of this workincluded pre-construction laboratory bench top testirig by IUC to estimate thepossible contaminants that might be discharged in the tailings wastewgter. TheNRC also published other estimates of expected tailings wastewater Jhemistry.
Several historical samples of the tailings effluent have been collected and
analyzed by both the NRC and IUC to determine the chemical properties of thetailings wastewater for a limited number of parameters (see Atiachment 6, below).Little information is available regarding organic contaminants in the tailingseffluent. All information available to the DRC is summarized in Table 5,6elow.
C.
l0
Statement of Basis DRAFT December l,2OO4
Footnotes:
Table 3. Summary of White Mesa Milli Processes
Table 4. Ranki ofeanlcng ot Reported White Mesa Mill Reasen
Reagent
Daily Consumption
(lb/dav)
Sulfuric acid (HzSOr)392,000
Chlorides (NaCl)15,000
Soda Ash (NazCOr)r0,000
Sodium chlorate (NaClOr)6,000
Ammonia 2,000
Kerosene t,596
Flocculants 600
Amines (uraniu4 extraction solvent)84
1 ) For additional information on common acid leach circuit processes at conventional uranium mills, see EpA, 1995, pp. 22-25.2) Total daily pounds used of each reagent at the ruc white Mesa uranium mill is listed in brackets [], as prwide d, in the 5t2gl99IUC report, p. A-8, Table A-l and the l/30/78 Dames and Moore Report, p. 3-5 and Plates 3.2-l (uranium miiling fiocess), 3.2-2 (copper rccovery), and,3.2-3(vanadium recovery). Both of these documents detail usi of manganese oxioe [30,000 lt/day] in three process steps, including: I ) uranium oreoxidation, 2) uranium leaching and clarification, and 3) copper r"ior"ry (leachingj. However, ur" of.anguoese oxide was listed in theseoriginal mill documents as an option in case the prefened oiidizer, sodlum chlorite, was not available or was not economic. History of the millshows that concerns about price or availability oi sodium chlorate never materialized, hence manganese oxide was never used in any of these
- three process (personal communication, Mr. Harold Roberts, llAStM).3) Also known as the uraniferous ion stabilization step (EpA, lgg5,pp. b-25).4) Total "organic" used daily = 1,680 lb/day, of which kerosene is reported to b e 95vo (ibid.). DRC staff then assumed that remainder of the"organic" used in the solvent extraction circuit = amine t)?e compounds used for anionic solvent extraction in the kerosene carrier (ga ft/day).5) IUC reports only ammon-ia (NH3) used in the yellowcake precipitation step t5/28l9t ruC report, p. A-g, Table A- I a,,d lt3olTgDames and MooreReport, p' 3-5 and Plate 3.2-t (uranium milling process)1. Ho*"u"., oo"" i, an aqueous form, the ammonia likely occurs as ammonia hydroxidein solution.6) Copper recovery was once envisioned for the white Mesa mill (lt3ot78 Dames and Moore Report, pp. 3-6 and1 ,and plate 3.2-2), however itwas never implemented (personal communication, Mr. Harold Roberts, l0/15/04).7) vanadium recovery information for White Mesa mill from ll3ol78 Dames and Moore Report, pp. 3-7 to 10, and plate 3.2-3.
ts*
I and Reasents Added
Process Step Actua and Potential Contaminants AddedUranium
Milling
Operations (l)
Ore Oxidation Sodium chlorate (NaClO3)
[6,000lb/davl @)
Uranium
Leaching and
Clarification G)
Sulfuric acid (H2SOa)
[392,000 tb/day] @)
Flocculants [600 lb/day] (2)
Solvent
Extraction
Secondary amines with
aliphatic side chains [84
lb/dayl(a)
High molecular weight tri-alkyl
amines
Quaternary ammonium
compounds
Kerosene [1,596 lb/davl (a)Tributyl phosphate modifier Long chain alcoholsPregnant Liquor
Strippins
Chlorides (NaCl) U5,000
Ib/dayl (2)Sulfates
Yellowcake
Precipitation
Ammonia hydroxide
(NHjOH) I2.0fi) tb/davl (5)
Sodium hydroxide (NaOH)
Copper
Recoverv (6)
Vanadium
Recovery 0)
Redox / pH
Adiustment
Sodium chlorare (NaClO3)
[6,000lb/davl @)
Solvent
Extraction
Kerosene [1,596 lb/day] (a)Secondary amines with aliphatic
side chains t84 lb/davl (a)
Pregnant Liquor
Stripping
Soda Ash (NazCOr)
solution [10,0(X) cwes t,r
lbtdaylQ)
Vanadium
Precioitation
Ammonia hydroxide
(NHIOH) [2,0fi) lb/davl (5)
ll
* From Table 3, above.
Statement of Basis
Table 5. Summar
NRAFT
of Estimated and Measured
December l,2OO4
Statement of Basis DRAFT December 1,2004
State
GwQS
(mclL)
1979TUC
Bench-top
Estimate(l)
(mg/L)
I98O NRC
Generic
EIS
Estimate@)
(milL)
September, 1980 - March, 2003
IUC / NRC Tailings Wastewarer Samples(3)
Reported Concentrations Avg/
GWQS
Ratio
Min.
(milL)
Max.
(milL)
Average
furs[L\
Std. Dev.
(metL)
Sample
CountContaminant
Sodium N/a 4,900 200 I,40C 10,00(5.808.7 3,072.|C 19Strontium43.e t4 1.4 4.74 4 1.8Thallium0.002 o.7 45 16.0 20.54 8 7,989.1Iin22,0N <5 <5 5 #DM0!JTitanium1506.5 33.3 t9.t ll.7c I 0.13Uranium0.03 2.5 5.C 154 93.6 4t.2A t]3,120.6Vanadium0.06 24C 0.1 t36 510 263.1 111.91 t7 4,385.3Zinc59C80501300640.C 598.48 5 128.7Zirconium2.38.5 12.2 12.oc 14rsgJQJagalJPLilU
Gross Alpha 15 250,00c 14,000 189,000 120,493 50,345.1 l5 8,032.9Gross Beta 74 116,000 68,942 35,918.8 l5 #DIV/O!Lead-210 2.C 68C 20,7U 3,385 4,660.1 t7 1,692.6Thorium-230 18 3,65C 76,64C 21.748 15,394.8 l8 1,209.2Thorium-232 16 49 t2 81 27.9 T2 5.4Polonium-210 1.0 t,4tc 1,41 r.4tc I 1,410Radium-226 4C 1,69C 1,027 497.21 15Radium-228 1.9 t.1.9 #DIV/O!ITotal Radium 5 42 1,700 942 553 l9l 188.4
$EJS| LKLL_ y*U-9_s JJL&LU
Acetone 70c 28 514 t92 278.41 3 0.3Benzene55<5 <5 22-butanone (I\GK)4,000 l1 15.13 13.38 2.13 .,0.003Carbon Disulfide 70(IC t(l6 #DIV/O!I 0.02Carbon tetrachloride 5 <5
6
5 <5 23hloroform7C16.84 10.28 5.77 0.15I ,l -Dichloroethane ila 5 <5 <51,2-Dichloroethane 5 <5 5 <5 2Dichloromethane51Cl1l0.s o.7t 2 2.1Tetrahydrofuran46n-a n-a n-a n-a n-a n-aToluene1,000 <5 6.2:< 5.62 2Vinyl chloride <10 <10 <10 2Xylene (total)10,00c <5 5 5 2WtBenzo(a)pyrene I 02 <lu <10 2B is(2-ethylhexyl)phthalate 6.0 I I I 0.2hrysene48<10 <10 <10 2Diethyl phthalate 5,000 <10 l8.l l8.l 0.004DimethylphthalateN/a 2.i 2.1 2.7 3Di-n-butylphthalare 70c 1.08 1.08 1.08 3 0.002Fluoranthene28Ct010<102-Methylnaphthalene 4 l0 <10 <10 2Naphthalene1002.44 2.44 2.44 0.024Phenol4,000 <10 38.4 38.4 .,0.01Footnotes:
I ) From May' 1979 NRC Final Environmental statement, p. 3-- l I , Table 3. I . original concentrations reported in units of gn/liter, converted here to mg/riter.2) From September, 1980 NRC Final Generic EIS, p. M-5, Table M.3. original"?r".rtotion, 1"p^ry.q'ir rrir, or-ugrr"r, converted here to mglI.3) Based on samples collected by IUC and the u.s. NRC between septembir, rqao u; Ivlur.t, 2003. For details see Attachment 6" below.
l3
Statement of Basis T}RAFT December 1,2004
From this information it appears that the pre-construction laboratory testing
under-estimated the actual concentration of several contaminants that *ould
accumulate over time in the tailings wastewater, including: ammonia, chloride,
fluoride, TDS, arsenic, cadmium, iron,lead, mercury, sodium, uranium,
vanadium, and zinc. In some cases these estimates under-predicted the average
measured concentrations by 3-orders of magnitude, e.g., mercury, molybdentin,
uranium, and vanadium. Other pre-construction estimates over-predicied the
average measured concentrations, including: silica, barium, calcium, manganese,
and gross alpha. These concentration differences are indicative of either
variability of the feedstocks input to the White Mesa mill, the variability of themilling process itself, and/or recycling of process fluids from Cell I back into the
milling process combined with the effects of seasonal evaporation. In order to
better define the tailings wastewater source term concentrations and
characteristics, the Executive Secretary has added a requirement to the permit in
Part I.E.8 to mandate periodic sampling and analysis of this wastewater.
Review of the available data shows that many of the tailings wastewater
contaminants have had an average concentration that was 5O-times greater or
more than the corresponding GWQS, including (see bold values in iable 5,
above): ammonia (N), 16 heavy metals (arsenic, beryllium, cadmium, chromium,
cobalt, copper, iron, lead, manganese, mercury, molybdenum, nickel, thallium,
uranium, vanadium, and zinc), fl uoride, gross alpha, lead-Z 10, thorium-23 0,polonium-210, and total radium. of these, ammonia has been introduced as a
reagent in the milling process. of the 16 heavy metals, l l appear to be derived
from the Colorado Plateau ore feedstocks, including: arsenic, chromium, cobalt,
copper, iron, lead, molybdenum, nickel, uranium, vanadium, and zinc (see Table2, above). Manganese is also a common contaminant in Colorado Plateau ores(personal communication, Mr. Harold Roberts, lofigto4). The beryllium,
cadmium, fluoride, mercury, and thallium concentrations seen in thL IUC tailingswastewater in excess of 50-times the respective GWeS, appear to be derived
from Arizona Strip ores and alternate feed materials (ibid.). Based on their
elevated source term concentrations, all of these contaminants should be
considered as potential groundwater monitoring parameters for the White Mesafacility.
As for organic contaminants that might be found in the tailings wastewater,
kerosene is probably the most significant in terms of IUC's reported daily mill
consumption, about 1,600lb/day, see Tables 3 and 4, above. Kerosene is a
mixture of many petroleum distillates, generally composed of hydrocarbons in the
range of Ce to C16 (Risher and Rhodes, p. 105). Researchers who have studied
environmental releases of kerosene to groundwater have recommended use of
several groundwater monitoring parameters, including: benzene, toluene, xylenes
(ortho, meta, and para), ethylbenzene, naphthalene, etc (Thomas and Delfino, p,96). These VOCs generally constitute the most soluble components of kerosene(Deutsch and Longmire, chp. 10, p. l9). of these .ompourds, all have been
detected in groundwater at IUC in the area associated with the on-going
chloroform investigation, with the exception of ethylbenzene, see discuision
below. It is also important to note that these and other aromatic hydrocarbons
commonly comprise about l0-207o of the total content of kerosene, (Risher and
Rhodes, p. 105). on its own merits, naphthalene has been found to constitute
t4
Statement of Basis DRAFT
D.
December l,2OO4
about 37o of kerosene by volume (ibid., p. r07). Based on this information, theExecutive Secretary has decided to add four (4) of these VOCs as groundwater
monitoring and compliance parameters in Table 2 of the permit: binzene,
toluene, xylenes (total), and naphthalene.
contaminant Mobility - during selection of the groundwater monitoring
parameters to be required by the permit, it is important to consider a
contaminant's ability to travel in a groundwater environment. For most
contaminants this is controlled by its soil-water partitioning (Ie) coefficient.
Ideally these IQ values are determined independently for each permitted facility,using laboratory or field-scale tests with site-specific groundwater and soilsand/or aquifer materials. In cases where site-specifi" Iq info.mation is not
available, the Executive Secretary has set a precedence of using the lowest K6values available in theliterature to represent the site in question. A summary ofliterature IQ values is found in Attachments 7 and g, bel,ow.
l) Anionic Contaminants - anions generally exhibit very low Ie values and
need to be considered as groundwater monitoring parameters at the IUCfacility. These anions include: chloride, fluoride, and sulfate. Chloride iscurrently a groundwater monitoring parameter required under the NRC
Iicense, and has been included as a compliance monitoring parameter inTable 2 of the Permit.
Fluoride, as mentioned above, has been found in the tailings wastewaterwith an average concentration that is more than 400-ti-"slt, respective
GWQS, and therefore is also included as a GWCL parameter.
Sulfate is a byproduct of the large daily volumes of sulfuric acid used inthe uranium leaching stage of milling (see Table 3, above, and EpA, 1995,p.22). As a parent contaminant, sulfuric acid is the most predominant
reagent used in the mill where it is consumed at a rate of 3T2,OOO lb/day
(see Table 4, above). Accordingly, sulfate is extremely abundant in theIUC tailings wastewater with an average concentration of almost 65,000mg/l (see Attachment 6, below). At this average level, sulfate is more thanl4-times more abundant in the tailings wastewater than chloride, which
has been a historical groundwater monitoring parameter under the NRC
license.
2) Heavy Metals - of the heavy metals known to exist in uranium ores, allwere found to have a lowest literature IQ value of less than 2.}llkg, with
the exception of lead (4.5 r/kg) and vanadium (50 l/kg), see Attach-m ent7,below. However, after consideration of the high acid conditions found in
the tailings wastewater, with an average pH otl.g3, all these heavy metals
could easily stay in solution and not partition on aquifer materials. To
date, no information has been provided by IUC regarding site-specific Ie
data for White Mesa soils and rock. Neither has any quantitativL, site-specific information been submitted regarding the bulk or trace mineral
composition of soils and bedrock at the site that could provide buffering
capacity for any low-pH tailings solutions. consequently, the Executiv-e
Secretary believes it is not appropriate to eliminate uny of the uranium orerelated heavy metals as groundwater complirn"" -onitoring parameters.
Therefore, 14 ore related metals were included in the permit as GWCL
15
Statement of Basis DRAFT December 1,2004
parameters, including: arsenic, chromium, cobalt, copper, iron, lead,
manganese, molybdenum, nickel, selenium, silver, uranium, vanadium,
and zinc.
Four (4) other heavy metals found in the IUC tailings wastewater appear
to be derived from Arizona Strip ores and altemate feed materials,including: beryllium, cadmium, mercury, and thallium. All four (4) of
these metals have average tailings wastewater concentrations in excess of
5O-times the respective GWeS, ranging between 126-times (beryllium) to7,988-times (thallium), see Attachment 6, below. Literature lowle values
for these four (4)metals also vary widely, ranging from 0.0 l/kg (thallium)to322l&g (mercury). Again, based on the high acid environment known
to exist in the tailings wastewater and the unknown buffering potential
expected in the subsurface formations, the Executive Secretary believes itprudent to include all of these four (4) metals as GWCL parameters in thePermit (Table 2).
In the future, IUC may provide additional site specific information
regarding contaminant K4 values, and soil and aquifer geochemical
composition and buffering capacity information as a part of the
contaminant transpoft modeling report required by part I.H.l l. Afterreview and approval of this supporting information and the report, the
Executive Secretary will re-evaluate the need to retain all heavy metals
listed above as GWCL parameters.
- at least five (5) volatile
organic contaminants (voc) have been found in the tailings wastewater,
including acetone, 2-butanone (methyl ethyl ketone or IvIEk1, chloroform,
naphthalene, and toluene (see Attachment 6, below). None of these
contaminants exceeded their respective GWes. However, relatively
significant concentrations of acetone were detected.
The possible source term for naphthalene and toluene may be the largedaily volumes of kerosene used in the solvent extraction circuit, see iables
3 and 4 above. Research by others has found that aromatic hydrocarbons,
such as benzene and related compounds (toluene, xylenes, etc.),
commonly constitute l0-207o of kerosene fuel oil (Risher and Rhodes, p.105). By itself, naphthalene has also been found to constitute about 3% ot
kerosene by volume (ibid., p. 107). Naphthalene and toluene have also
been found to have low K6 values, 0.39g and 0.009 rJKg,respectively (see
Attachment 8). These data support the use of naphthalene and toluenl asgroundwater compliance monitoring parameters under the permit.
As for the remaining tailings wastewater vocs, the source term may be
wastewater from the mill's on-site laboratory, which began operation in1977,but did not begin to discharge to Tailings cell t untit June, l9g0(9l30l99IUC Report,p. 6). These remaining voc's also have very lowliterature I(6 values of 0.001, 0.015, and0.o24 uKg for acetone, z-
butanone, and chlorofofin, respectively.
3)
L6
Statement of Basis T}RAFT December 1,2004
Unfortunately, the IUC voc data in question is not considered
representative of actual field wastewater conditions in the tailings disposal
cells, for several reasons, including
a) Single sample - the data availabre is derived from only I sample
collected from the slimes drain, and may not be representative of
concentrations in all the tailings cells over the operating history of
the facility (see Attachment 6, page 2),
b) Unknown Sample Date - no sample date was provided for the IUC
sample. consequently, it is difficult to know just when in the
history of the facility the sample was collected, and
c) Missing Sample Information - no information was available
regarding how the sample was collected, preserved, and analyzed.
Based on this lack of source term characteization,the Executive Secretary
took a conservative approach and has required all five (5) of these voC's
as GWCL parameters in Table 2 of the permit. Furthermore, a compliance
schedule item has been added to the permit to require IUC to better
characteize the tailings wastewater quality conditions, see parts I.E.g andI.H.5.
vorarrre urgarucs .r.ouno rn srte (iroundwater _ 13 volatile compounds
have been found in detectable concentrations in IUC groundwater since
4)
May, 1999, see Attachment 9, below. Of these, 12 were organic
compounds including: six (6) chlorinated solvents, five (5) petroleum
distillates, and one (1) non-chlorinated organic solvent (tetrahydrofuran).of these 12 vocs, all appear to have very low I(a values, ranging from
0.009 (tetrahydrofuran) to 0.398 (naphthalen e) rJKg, and would therefore
be very mobile in a groundwater environment, see Attachment g.
consequently, if any of these contaminants have potential to be found
wastewaters generated at the IUC facility, they should be considered asGWCL parameters under the permit.
a) Chlorinated Solvents - the source term for the chlorinated solvents
may have been pre-operational laboratory wastewaters discharged
to septic tank leachfields at the mill site. Since about June, l9g1
these wastewaters have been discharged to Tailings cell l. of
these six (6) chlorinated solvents, three (3) have bien found withgroundwater concentrations that exceed their respective GWeS,including: chloroform, carbon tetrachloride, urd di.hloromethane
(see Attachments 3 and 10, below). In order to ensure an adequate
characteization is completed and to better coordinate groundwater
monitoring for both the tailings cells and the chloroform
investigation, all three of these chlorinated vocs were included asgroundwater monitoring parameters in Table 2 of thepermit.
b) Petroleum Distillates - for the five (5) petroleum distillates
detected in site groundwater, alr are aromatic hydrocarbons, withfour (4) derivatives of benzene (benzene, toluene, xylene, and
1,2,4-timethylbenzene), and one ( I ) polynuclear aromatic
(naphthalene). As discussed above, the source term for these
t7
Statement of Basis DRAFT December 1,2004
compounds may be small quantities of kerosene found in
laboratory wastewater discharged historically to septic tank
leachfields . Large quantities of kerosene are also used in the mill's
solvent extraction circuit and are discharged to the tailings cells.
ofthese five (5), only one (l), benzene, has been found in excess
of its 5 ug/l GWQS (see Attachment 10, below). For reasons
discussed above, toluene, and naphthalene were added to the
Permit as groundwater monitoring parameters. However, because
benzene and xylene are also related to kerosene, and have been
detected in groundwater at the facility; these compounds have also
been added as GWCL parameters in Table 2 of the permit. For the
time being 1,2,4-timethylbenzene was omitted as a monitoring
parameter. However, should it be necessary it can be added to the
Permit later under provisions found in part IV.N.3.
Tetrahydrofuran - detectable concentrations of tetrahydrofuran(TIf) have been found in four (4) wells at the facility, including
up gradient well MW-l, and downgradient wells MW_2, MW_3,
and MW-12 (see Attachment 10, below). Two (2) of these wells
have TIIF concentrations that exceed the State GWeS (46 ugll),
including upgradient well MW-l and downgradient well MW_3(ibid.). The two (2) other downgradient wells, MW-2 and MW_12,
exhibited detectable TIIF concentrations that did not exceed the
GWQS.
As a part of the chloroform contaminant investigation, DRC staff
asked IUC to evaluate possible sources of rtIF at the facility
(1122102 DRC Request for Additional Information, p. 3) In
response, IUC claimed that this organic solvent may have been
derived from PVC glues and solvents used during construction of
the PVC well casings found in several monitoring wells at the
facility (l2l20l02IUC ktter, p.z). This claim appears consistent
with the occurrence of rrIF in both up and downgradient wells.
However, further evaluation is required to determine why three (3)
other IUC wells installed at the same time do not exhibiidetectable
TIIF concentrations, including lateral gradient well MW-4, and
downgradient wells MW-5, and MW-ll.
TF{F is a contaminant of concern, in that one of its major use is as
a Grignard reagent in the synthesis of motor fuels (National
Library of Medicine [NLM] Hazardous substances Data Bank).
Therefore, it may be possible that TFIF is a trace contaminant in
petroleum products such as kerosene, which is used in large
quantities at the white Mesa mill (see Table 3, above). Further,
TIIF has unique chemical properties in that it is soluble in both
water and hydrocarbons. Because it has a high water solubility,
TFIF may be a very mobile groundwater contaminant.
During preparation of the Permit, IUC offered to: 1) continue
monitoring TFIF in all the monitoring wells at the facility, 2)
include TFIF as part of the routine tailings wastewater sampling
c)
t8
Statement of Basis DRAFT
s)
December 1,2004
and analysis, 3) submit a work plan for additional study and 4)
complete the study and report the results thereof to resolve this
issue. Accordingly, a condition has been added to the permit,s
compliance schedule in part I.H.19. If after review and approval
of this report, the Executive Secretary determines that Tff is not a
result of mill operations, then the permit will be re-opened and
modified to remove it as a groundwater compliance monitoring
parameter (Table 2).
- ruC has detected five (5)semi-voc contaminants in tailings cell wastewater, including: bis(2-ethylhexyl)phalate; diethyl phthalate; dimethylphthalate; di_n_
butylphthalate; and phenol (see Attachment 6, below). Four (4) of thesecompounds may be mobile in groundwater environments, based on their
estimated I(6 values, including: diethyl phthalate (0.07 UKg);
dimethylphthalate (0.0a UKg); di-n-butytphthalate (0.16 Ukg); and
phenol (0.016 uKg), see Attachment 8, below. However, none of thesesemi-voc contaminants were included as compliance monitoring
parameters in the Permit, for the following reasons:
a) Several voc contaminants have already been proposed as
compliance monitoring parameters that have lowei I(a values than
the semi-voc parameters in question. Examples of these include,
but are not limited to: acetone, chloromethane, dichloromethane,
and toluene. consequently, these voc parameters should be
detected at the compliance monitoring well before any arrival ofthe semi-VOC contaminants.
b) Focusing on the voc contaminants will streamline groundwater
monitoring efforts and reduce associated sampling and analysis
costs for both IUC and the Executive Secretary,
c) The Executive Secretary can add new compliance monitoring
parameters at any time, if needed to protect human health and the
environment, pursuant to part IV.N.3 of the permit.
semi-vocs Found in site Groundwater - only one (l) split sampling
event included analysis of semi-voc parameters, May, iqqq. ou.ing thisevent which was conducted as a part of the chloroform investigation,inly
one (1) semi-voc contaminant was detected in the IUC set of
groundwater samples at the white Mesa facility, including: Bis(2-
ethylhexyl)phthalate. unfortunately, a problem with a laboratory blank
forced the DRC to discount all its split sample results for this parameter.Follow-up sampling for semi-vocs was not undertaken by DRC staff,primarily because the voc contaminants detected are known to generally
be much more mobile in groundwater environments. The Executive
Secretary will continue with this approach to semi-voC contaminants as
compliance monitoring parameters under the permit.
_ the transformations or decay ofcontaminants that would alter the physical properties or reduce the concentration
6)
t9
E.
of contaminants found in the tailings wastewater is another key consideration in
Statement of Basis DRAFT December 1,2004
F.
selection of contaminants for groundwater monitoring. In cases where a
contaminant is transformed to a reaction or decay product, it may be preferable tomonitor groundwater quality for the degradation products insteai of the parentcontaminant. Several tailings wastewater contaminants were examined with
respect to their persistence in groundwater environments. Each of these
parameters are discussed below:
l) Nitrate and Nitrite - both of these compounds are oxidation or degradation
products of ammonia, which is one of the top six (6) reagents adalo
during the milling process (see Table 4, above). As anions, both nitrate
and nitrite are readily mobile in groundwater environments. For these
reasons, Nitrate + Nitrite (as N) was added to the list of groundwater
compliance monitoring parameters in Table 2 of thepermit.
2) Chloroform Daughters - chloroform has been found both in the tailings
wastewater (see Attachment 6) and in shallow groundwater primarilyin
the area of the chloroform investigation (see Atiachment 3) at the site. As
a result, the Executive Secretary has added this volatile organic compound(VOC) to the list of required groundwater monitoring parameters in Table
2 of the Permit. Under anaerobic conditions, chloroform is degraded to
dichloromethane (or methylene chloride) and then to chlorome-thane lseePankow and Cherry, p. 80). Both of these daughter products have low soilIQ values of 0.10 and 0.06 rJKg, respectively (see Attachment g). For
these reasons, all three (3) of these vocs have been required for
groundwater monitoring at the facility after addition to Table 2 of the
Permit.
Detectability - the ability of common environmental laboratory equipment andtechnology to detect and quantify contaminant concentrations in groundwater isanother important issue to consider when selecting parameters foi groundwater
compliance monitoring. Executive Secretary review has found thai standar dized.,EPA approved laboratory methods are available to provide minimum detectionlimits that are lower than the Gwes discussed below for each compliancemonitoring parameter.
5.urouno water Uualtty Standards (Permit Table 2) - the Executive Secretary hasdetermined GWQS for each of the groundwater compliance monitoring parameters listedin Table 2 of the Permit. The source or reference foieach of these coniaminant,s GWeSis discussed below.
Nutrients and Inorganics
A' Ammonia (as N) - the 25 ug/l ad-hoc GWQS found in Table 2 of thepermit wasderived from a 30 ug/l EPA final drinking water lifetime health advisory (LHA)for ammonia (NH3) [see EpA, Summer, 2oo2,p. g]. This value was thenconverted to an equivalent concentration for ammonia as nitrogen (NH3 as N), asfollows:
NH3 (as N) GWQS = NH3 cWeS * Atomic Weight of N
Atomic Weight of NH3
= 30 mgl * t4.OO67 I U4.OO67 + 3 x 1.0079)l
= 30 mgl x 14.0067 I t7.O3O4
= 24.67 mg/I, round to 25 mg/|.
20
Statement of Basis DRAFT
B. Fluoride - the 4.0 mg/l value is a promulgated Gwes under the Utah GwepRules found in UAC R3l7_6_2,Table l.
C' Nitrate + Nitrite (as Nitrogen) - the 10 mg/l GWQS comes directly from the utahGWQP Rules found in UAC R3l7_6_Z,taUte t. -
Metals
D' Arsenic - the 50 ug/l GWQS comes from the utah Gwep Rules found in uACR3l7-6-2, Table 1. However, the EpA drinking water final maximumconcentration limit (MCL) has been recently changed to l0 ug/l (see EpA,Summer, 2002,rt 8). At some point in the iuture,"the Executive Secretary mayre-open the Permit and revise this GWQS accordingly, pursuant to part IV.N.1.
December I,2004
from the Utah GWQP Rules found in UACThallium - all of these GWeS come
R3I7-6-2,Table 1.
md/ri
E.
F.
lium
cobalt and Iron - the ad-hoc GWes for these two (2) metals, 730 andl1,000ug/f respectively, were derived from the tap water concentration limits found inthe EPA Region 3 Superfund Risk Based c-oncentration (RBC) Tabre. This EpAreference is available on the Internet at
G' Manganese - the 800 ug/l ad-hoc GWQS was derived from an ad-hoc drinkingwater LHA provided by EpA Region g (see rt4looEpA Region g letter, p. l). Inturn, this LHA was based on the most current reference dose (RfD) in the EpAIntegrated Risk Information System (IRIS) database.
H' Molvbdenum and Nickel - the ad-hoc GWQS of 40 and 100 ug/I, respectively,were derived from EPA final LHA for these metals (see EpA, -Su*"., 2002,p.8).
I' Uranium - the 30 ug/l ad-hoc GWQS was derived from a final EpA drinkingwater MCL (see EpA, Summer, 2002,p. g). This MCL was re-affirmed by theunited states court of Appeals on February 25,2003 (see District of columbiaCircuit, Docket No. 01_102g, etc, p.4g).
J' Vanadium - an ad-hoc GWQS of 60 ug/l was calculated by DRC staff with theassistance of Mr. Bob Benson, EPA Region 8 drinking *ui., toxicologist using anEPA RfD for vanadium pentoxide (vzos) of 9 ugrkgrday (see 7flgr96\tahDepartment of Environmental Quality IDEQI Inlormation Needs Summary, Tablel, Footnote 5).
K' Zinc - the 5,000 ug/l ad-hoc GWQS comes directly from the Utah GWep Rulesfound in UAC P.3l7-6-2, Table 1. However, the final EpA drinking water LHAis currently 2,000 ug/l (see EpA, Summer,2002,p. 9). Consequeniiy, theExecutive Secretary at some point may re-open the Permit ura uoiusi'the zincGWQS accordingly, pursuant to part IV.N.i.
Radiologics
L' Gross Alpha - this 15 pci/l GWQS is directly from rhe utah Gwep Rules foundin UAC R3l7-6-2, Table 1.
21
Statement of Basis DRAFT
VOC Contaminants
M' Acetone - the 0.7 mgll (700 ug/l) ad hoc GWQS was derived from lifetime healthadvisory calculations by Utah DWQ staff, with the assistance of Mr. Bob Benson,EPA Region 8 Drinking Water Program Toxicologist. For additional details, seethe August 8,1994 DwQ Report (pp. 3-5 and Attichment l). This 700 ug/l valuewas based on an oral exposure reference dose (RfD) from the EpA IntegratedRisk Information System (IRIS) database of 0.1 mgtkgtday. This same'ad hocGWQS has been used at another lle.(2) waste aisfosat racitity in utah.
December 1,2004
rbon - the GWQS valuesfor all of these contaminants came from the Utah GWQP Rules found in UACR3l7-6-2,Table l.
Met ndN lene - these
N.
o.
a.
ad hoc GWQS are based on final ffe O.ir . J4mg/l or 4,000 ug/ll; chloromethane t0.03 mg/l or 30 ug/ll; and naphthalene [0.1mg/l or 100 ug/ll, see EpA, Summer, 2OO2(pp.2,5, and6).
P' Chloroform -previously the Executive Secretary relied on an EpA drinking waterMCL for total trihalomethanes, which includes thloroform and 3 other VoCcontaminants, to establish an ad hoc Gwes for chroroform (0.g mgfl). However,recently DRC staff became aware of a new and discrete chloroform RfDestablished in the EPA IRIS database. ^ylh the help of EpA Region g toxicologystaff, an ad hoc drinking water LHA of 0.7 ugllwas established for chloroform onthe basis of the compound's non-cancer risk (see 5129103 EpA memorandum).Later this value was approved for use at the IUC White Mesa facility by the UtahDWQ gee 6ltllO3 DWe Memorandum).
_ this ad hoc GWeS was derived from afinal EPA drinking water MCL (see EpA, Summer, 2002,i.3).
R' Tetrahydrofuran - the 0.046 mgt @6 ugll) ad hoc GWes for tetrahydrofuran(Tffi) is based on an ad hoc EPA Region 8 drinking water LHA (see g/24tgg
EPA Region 8 memorandum). In turn, the EpA adloc LHA was based on aprovisional oral cancer slop factor of 7.68-3 mglkglday. From calculationsprovided by EPA Region 8, three values of cancer riskand corresponding TFIFconcentrations were determined, as summari zed in Table 6, below. After reviewof these data, the Executive Secretary has determined that the mid-range vatue, +Oug/I, is appropriate as an ad hoc TFIF GWQS for the IUC White Mesa-site, basedon the following findings:
l) Groundwater Classification - the shallow aquifer consists of acombination of Class II (drinking water quuiity; and Class trI (limited usequality), and
2) Lack of Current Use for Drinking Water - review of nearby groundwater
use has shown that no existing groundwater supply wells oi springs arecurrently found downgradient of the IUC faciliiy on White tvtesa itratexclusivery use the sharow aquifer for drinking water.
22
Statement of Basis DRAFT
Table 6. Summary of Tetrahydrofuran
Cancer Riskrsk And GWQS Concentrations
Cancer Risk
TIIF Concentration (r)
(mell)(uell)
1:10,000 0.46 ms.fi 460
l:100,000 0.046 46
1:1,000,000 0.0046 4.6
December 1,2004
Footnote:l)From8l24l99EPA Region 8 memorandum by Robert Benson.
6.torin
Table 7. Su
_ recent water table contourmaps of the shallow aquifer have identified a significant westerly component togroundwater flow at the white Mesa facility, sei Attachment l, below. This change ingroundwater flow directions appears to be the result of wildlife pond seepage andgroundwater mounding discussed above. As a consequence, ,"* g.ound*ut".monitoring wells are necessary at the IUC facility, particularly along the western marginof the tailings cells. New wells are also needed ior Discharge Minimization Technology(DI\4T) purposes that provide discrete monitoring of each tailings cell, as discussedbelow. During meetings in August, 2003 andFebruary, zo}4,ruc p.oposed theinstallation of these new groundwater monitoring wells near the tailings cells, assummarized in Table '7. Later,IUC submitted a map to confirm the locations of thesenew wells, see Attachment 11, below:
o IUC Monitorins Welt T.oeefinnc
Well ID Approximate Location
MW-23 Near southwest corner of Tailines Cell 3
MW-24 Near southwest corner of Tailings Cell I
MW-25 Near southeast corner of Tailings Cell 3
MW-26 Near northeast corner of Tailings Cell2
(existing chloroform investigation well TW4_ I 5)
NNV-27 Near northeast corner of Tailings Cell I
MW-28 Near mid-point of south dike at Tailings Cell I
MW-29, MW-
30. and MW-31
Spaced approximately equidistant on south dike of
Tailings Cell2
MW-32 Near southeast corner of Tailings Cell2
(existing chloroform investigation well TW4-1 7)
These general locations were found acceptable. If after review of the hydrogeologic
Ieqort required by Part I.H.2 of the Permit, the Executive Secretary determines additionalinformation is needed, IUC will be asked to provide more informuiior. The short 60-daycompliance schedule for IUC to install the new wells after Executive Secretary approvalof the plan was set in order to expedite both the collection of groundwater qualityinformation from these new wells, and preparation and submittal of the new wellBackground Groundwater euality Report (part I.H.4).
23
7 ' Revised Hydrogeologic Report (Part I.H.2) - after installation of the new monitoringwells required by Part I.H.1, it will be important to evaluate the new hydrogeologic
information collected, and consider it in context with existing informaiion collected todate at the facility. In order to ensure evaluation is done andlasily tracked by both IUCand DRC, the Executive Secretary added this requirement to Part I.H.2. At a minimum,the following types of hydrogeologic information will be included in the RevisedHydrogeologic Report:
A. Monitoring Well As-Built Information - including geologic logs, well completion
diagrams, and aquifer hydraulic analysis as required by part t.F.S of the pernnit,
B. Revised Structural Contour Map - of the geologic contact between the Brushy
Basin Member of the Morrison Formation, and the overlying Burro Canyon
Formation.
C' Aquifer Saturated Thickness Map - including a contour map to illustrate the localdistribution of the thickness of the perched aquifer.
D' Water Table Contour Map - based on groundwater elevation measurements of allwells and piezometers at the site to illustrate local groundwater flow directions.
E' Historic Aquifer Permeability Data - aquifer permeability data collected from thenew monitoring wells needs to be evaluated in context with existing slug and/oraquifer pump test analysis to determine if any preferred groundwater flowpathways exist.
F' Multi-well Aquifer Test Results - long-term any new multi-well aquifer testingdone to determine local hydraulic properties, iniluding permeability, needs to beincluded. One purpose of this testing would include detirminutionif anypreferred directions of groundwater flow exist at the facility, i.e., aquifeipermeability heterogeneity and anisotropy.
G. Aquifer Permeability Distribution Map - based on all reliable and representative
aquifer permeability available to date, IUC will provide a contour map toillustrate the distribution of permeability of the perched aquifer at the site.
If after review of the Revised Hydrogeologic Report it is determined that additionalinformation is needed, the Executive Secretary *itt ask IUC to provide it.
Statement of Basis
tailings cells.
T}RATT December 7,2004
8.Cells Operations Limits and prohibited Disc
these requirements have been added to the permit to confirm th.t "rt), t t.(e byproductmaterial, including various wastes listed by NRC, may be disposed oi in the Mili,s
9.DesiConstruction (Parts 1.D.1 and 2) -information pioria"a Uy fUC shows that Taitings Cells1,2, and 3 were constructed more than 2O yeariago, as summarized in Table g, below:
24
Dates
Tailings
Cell Completion Date Reference
I June 29, 1981 5128199 IUC Groundwater Informatinn Rennrt n A-t 1
2 May 3, 1980 2|&2D'Aopolonia Ensineers Consfrnctinn Rpnnrr n ?-l
3 September 15, 1982 3/83 Enersv Fuels Nuclear Cnnsfrrrctinn Pcnnrt n | -,)
4A November 30, 1989 8/00 ruC Construction Bgport, p. I
Statement of Basis DRAFT
Table 8. Su of Taili Cell
December 1,2004
After review of the existing design and construction and consultation with the DWe, theExecutive Secretary has determined that the Discharge Minimization Technology (DMT)required under the GWep Rules tuAC R3r7-6-6.4rcx:lt for IUC disposar cells r, 2,and 3 that pre-dated the 1989 GWQP Rules will be defrnei by the current or existingdisposal cell construction, with a few modifications. This approach is reasonable,practical, and acceptable for the following reasons:
A' Existing Conditions - Tailings Cells 1, 2, and3 have been in existence in theircurrent state for more than 20 years. Over the course of this time, a significantamount of tailings have been disposed in Cells 2 and 3.
B' Current Stage in Design Life - Tailings Cell2 has nearly reached its maximumwaste height and capacity, in that temporary soil cover has been advanced over99.8vo of the disposal cell. As a resuli, theiemaining disposal capacity in cell 2is only about 5,000 dry tons out of 2,352,000 dry tons of iotal design capacity(personal communication Harold Roberts, IUC) . At Tailings CeI1, about 67Voof the total design capacity has already been used (1,g25,000 out of ),725,000dry tons total), and temporary soil cover has been advanced over about 4OVo of thecell (ibid.).
C' Retrofit Construction Impractical - due to the advanced age of the disposal Cells2 and 3 and their near-full capacity, little can be done to retrofit, re-construct, ormodify the under liner systems.
The improvements required under DMT for Tailings Cells 1,2 and3 will focus onchanges in monitoring requirements, and on improirements to facility closure, if needed.The goal for these changes is to ensure that potential wastewater losses are minimizedand local groundwater quality is protected. there changes include:
D.Improved Groundwatgr Monitoring - improvements to the existing monitoringwell network are needed to meet the following performance goals:
l)Earllz Detection - the ability to detect a release as early as practicable isimportant, and is accomplished by locating wells immldiaLly adjacent toand downgradient of each disposal cell. T-o satisfy this requirement the
!1ec1tive Secretary has required three new DMT monitoring wells (MW_24,NNV-27, and MW-28)be installed immediately adjacent to cell l, seePart I.H.1.
Dis-crele Monitoring - the ability to individually monitor each disposal cellat the facility is also important to allow the Executive secretary to pinpoint the source of any groundwater contamination that might be detected.The DMT monitoring wells required for cell I in part I.H.I will help meet
2)
25
Statement of Basis DRAFT
E.
December 1,2004
this requirement. Also, IUC will be required to install three (3) additionalmonitoring wells between cell 2 and3 to allow discrete monitoring ofCell2 (MW-29, MW-30, and MW-31).
urperattonat unanges ano tmproved Operations Monitoring - changes to disposalcell operation that can increase efforts to minimiz" pot*ilul seepage losses. andseepage losses, and
lhereby improve protection of local groundwat"r quility are also important.
Related requirements for monitoring are also added to confirm that these changes
are in place and are actively being used by IUC. Examples of some of these
changes include:
1) Maximum Waste and Wastewater Pool Elevations - imposed in part I.D.3 forall the tailings cells and Roberts Pond to require that ruC continue to ensurethat impounded wastes and wastewaters are held and maintained over aflexible membrane liner (FML).
Z) - required for Tailings Cells 2 and,3in Part I.D.3(b) to ensure that IUC provides constant pumpinglfforts tominimize the accumulation of leachates over the FML, and thereby minimizepotential FML leakage to the foundation and groundwater. This requirement
was immediately imposed in the Permit for Cell 2, because IUC is alreadyactively dewatering that cell. Imposition at cell 3 was delayed by theExecutive Secretary in response to IUC arguments that premature slimes drainpumping poses a risk that the layer will plug with sulfati salts during tailingscell operation, and not be available for slimes de-watering when IUC is readyto advance a cover over the tailings cell. Such untimely loss of the slimesdrain layer would greatly complicate and delay cover ctnstruction, and in turnincrease the overall potential for leachates to be released from the final wasteembankment. Details as to an appropriate average wastewater head in theslimes drain layer at both cells 2 and 3 are to be proposed by IUC and
approved by the Executive Secretary in developmeni of a DMT Monitoring
Plan required by Part I.H.l3 of the iermit.
3) Feedstock Storage - in order to constrain and minimize potential generation ofcontaminated stormwater or leachates the Permit requires IUC to iontinue itexisting practice of [see part I.D.3(d)]: l) limiting open air storage offeedstock materials to the historical storage area found along the iasternmargin of the mill site (as defined by the survey coordinates found in permit
Table 5), and 2) maintaining water-tight contain eized,storage of feedstockmaterial found anywhere else at the IUC facility.
4) Mill Site Reagent Storage - is of potential concern for groundwater quality inthe event that reagent storage tank leaks or spills could-release contaminantsto site soils or groundwater. In an effort to prevent this possible problem, andprovide proper spill prevention and control, part I.D.3(ejrequirei IUC to
demonstrate that it has adequate provisions for spill response, cleanup, andrepofting for reagent storage facilities, and to include these in the StormwaterBest Management Practices Plan. Content of this plan is stipulated in part
I.D.8, and submittal and approvar of the plan required under part I.H.l7.
At new facilities, the performance goal for secondary containment shourdinclude prevention of spills from contacting the ground surface. During
26
Statement of Basis DRAFT December 1,2004
discussion with IUC, the company responded that this was impractical in thatthe existing reagent storage facilities had been in existence for decades.Further, IUC contended that: 1) secondary containment had been designedand constructed at each of the existing reagent storage facilities, albeitltearthen lined, 2) an.y soils affected byspills could be easily excavated anddisposed in the tailings cells shoula a spitt occur, 3) after removal of the soilsaffected by major spills, new construction could becompleted to replace andrestore the secondary containment; which at that time co;ld meet thi newperformance criteria for prevention of ground contact, and 4) any requiredimprovements for chemical reagent storage should focus on changesiooperational and/or spill response measures, and not on re-design o..e-construction of these facilities. Because the IUC facility is a pre_existingoperation under the Ground water euality protection nlgutaiions, DRC staffagreed with these arguments, and wrote the requirementsif part I_D.3(e)accordingly. However, should any of the existing reagent storage facilities bere-built, provisions were added to the Permit to rJquirE the highir standard atre-construction, that being secondary containment that would prevent contactof any spill with the ground surface.
F. _€oversystem design andconstruction needs to be evaluated in order to ensure that infiltration into thetailings waste is minimized and groundwater quality protected during the post-closure period. To this end, Part I.H.11 of the Permiirequires IUC to submit anInfiltration and Contaminant Transport Modeling report ior Executive Secretaryreview and approval. After review of this report, thi Executive Secretary willdetermine 1f any changes are need in the proposed cover system. Minimum coversystem performance criteria are stipulated in Part I.D.6 of ihe permit.
10. _during review of the existingtailings cell design and construction the il;;*" s;retary iound that constructiondocumentation for Tailings Cell 1 is limited to one (1) as-built report dated February,1982by D'Appolonia Consulting Engineers (p. 3-1). In this r"po.t the as-builtinformation is limrted to only a topogiaphic map of the cell 1 tioo. p.io, to EMLinstallation (ibid., Fig. 12). Authors of it " r"poi state that they were involved inconstruction of Cell 2, andthat Tailings Cell 1 construction was done by the previouswhite Mesa owner, Energy Fuels Nuclear (EFN). No other c"Ii"r-iuilt information isavailable, nor is there any documentation of any Cell I construction quality assurance /quality control. DRC field inspections have confirmed the existence of an earthen dike atthe south margin of Cell 1 and a FML liner inside this cell. Without any otherinformation, the Executive Secretary has assumed that the Cell I construction largelyfollowed the cell's original design found in a June, 1979D'Appolonia Engineers Report.From IUC plan maps the Executive Secretary estimated ttre ciit I footprint area to beabout 57 acres.
As for Tailings Cells 2 and 3, as-built reports were found and reviewed by DRC staff;findings from which are found in a June)7,2oooDRC Memorandum. These reviewsresulted in a summary description of the liner technology for these two (2) disposal cells,as outlined in Part I.D.l(b) and (c) of the Permit. n'rom iuc plan maps ihe ExecutiveSecretary estimated the footprint area to be about 68 and 55 acres foicetts 2 and3,respectively.
27
Statement of Basis DRAFT December 1,2004
engineering design for Tailings Cell 4,A ir found inl*o u-et.o vt-**rc corporation(hereafter Umetco) reports dated August, 1988 and April 10, 19g9. Cell 44 construction
From this review it appears that the design and construction of all three (3) existingtailings cells consists of a single PVC FML liner and a limited leak detection systemunder the primary liner comprised of a single pipe at the toe of th. r;rih;; dike within apermeable sand layer that extends across the celi floor. While outdated, this constructionappears to have been common technology for the time (1980-19g2). Since then, EMLtechnology has greatly advanced both in materials used, designs produced, constructionmethods practiced, and quality assurance / quality control measures applied. Moderndesigns include multiple_FMls (e.g., primary, secondary, tertiary, etc), and a leachateremoval system over and multiple leak detection layers under the primary FML. Sucha{v$9ed designs provide effective leachate head clntrol at the primary FML, therebyminimizing leakage rates and providing sensitive leak detection; and eificient leakagecollection and removal systems. In cases where facilities have deployed modern wastecontainment and leak detection / control technology, the Executivi Secretary has allowed
the leak detection system to be the primary meanJof compliance determination for thefacility.
However, this is not case for the existing tailings cells at IUC. Therefore, for purposes ofdefining the DMT standard for IUC, the Execuiive Secretary is left with only one option,that of improving detection of potential tailings cell leakageby installation of discretemonitoring wells' To this end, IUC has agreed to install elght (8) new monitoring wellsimmediately adjacent to the tailings cells,is follows (see.ittachment 11, below):
A. Tailings Cell 1 - wells NNV-24,NNV_27,and MW_2g,
B. Tailings Cell 2 - wells NNV-2I,MW-30, and MW_31, and
C. Tailings Cell 3 - wells NNV-23 and MW_25.
11.
was completed on or about November 30, 19g9, see Tible g, above. Later, fuCcompleted an as-built report and submitted it for Executive Secretary review (see g/00IUC Tailings Cell44.Construction Report). Review of the engineering design and as-built reports , shows that an improvemint was made to the leak detectiln syj"- in cell4A, compared to the older cells, in that a secondary FML was installed immediatelyunderneath the leak detection piping system. Unfortunately, this secondary FML wasvery limited in horizontal extent, in that it was only 2-feet *ia", than the gradedtrenchfor each leak detection pipe (8/88 Umetco Report, sheet c4-3). As a result, very largeareas exist between the-leak detection pipes where the primary EML has no underlyingmembrane to divert leakage to the detection pipe. Consequently, ggVo ofthe Cell4Afloor area does not hSve a secondary FML present to divert leakage to the leak detectioncollection pipes (6/27100 DRC memorandum, p. l0). As a result, the existing design andconstruction of this disposal cell could allow a-significant volume of leakagJto escapeundetected and possibly contaminate underlying lroundwater resources.
However, unlike cells l, 2, and,3, cer 4.{ has a r2-inchcray liner under the primaryFML' Therefore, leakage- from the primary FML would necessarily have to penetrate andescape this clay layer before it could infiltrate the cell foundation anO possiblycontaminate underlying groundwater. While this clay liner represents a significantimprovement in facility tailings cell design, DRC ,"ri"* or tni as-built reiort, referenced
28
Statement of Basis DRAFT December 1,2004
ab-ove, found very little clay liner construction quality assurance / quality controlinformation to substantiate any in-place or fieldpermeability for this ctay tayer. es aresult, the DRC is unable to quantify the rate of any possible leakage from this clay layer,or confirm the degree of control this layer may have had on said leachate.
Despite this lack of information, Cell 4,{ has never been used for tailings disposal, butinstead was used only for storage and evaporation of vanadium process solutions (5l2gtolIUC cell4A Leak Detection Report, p. 1)-. uc has advised DRC staff that no tailingswaste or wastewater have been deposited in cell 4A since the early lgg0,s. This lack ofwaste disposal, and exposure of the FML to the elements has caused Cell 44 to fall intodisrepair over the years. DRC staff site visits between 1995 and 2003 haveobservedfailure of several FML panels on the interior sideslope; thereby exposing large areas ofthe sideslope subsoils' IUC acknowledges this oamage and th! general iir.""pui, of cell44.
In addition, the existing ITIRC License requires IUC to submit verbal and written reportswhen flow rates from the leak detection system exceed 1 gallon per minute (gp*) INRC9123102 License, Condition 11.3(D)1. In a tvtay 29,2}olietter,IUC notified the NRCthat LDS flows at Tailings Cell44 had exceeded the 1.0 gpm rate at Cell44. Based onthese findings, it appears that the FML has failed to contrli the process fluids maintainedacross the floor of Cell 44, thereby causing reliance on the clay sub-liner to preventcontact with the underlying sub-soils. Since that time IUC has begun the process ofremoving the materials once stored there, in preparation of reJining the celt prior to re-use.
The raffinates and salts once stored in Cell 44. may have similar chemical characteristicsas the uranium raffinate in the Mill, in that the uunudir- raffinate is derived from theoutfall of the uranium extraction circuit in the IUC milling process (5l2gtgg ruCGroundwater Information Report,p. A-7 and Figure B-D: -conr"quently,
these fluidsmay contain significant concentrations of many contaminants of concern, including: IowpH fluids, heavy metals, uranium, high sulfates and rDS levels, and organiccontaminants.
considering the FML damage acknowledg?d by IUC, the general state of disrepairdiscussed above, and the lack of tailings *ra, aisposea tJdate; major i.pror.L.nts inthe design and construction of Cell 4A=are warranted prior to re-use of the cell. For thisreason, the existing Cell 44 design and construction were not approved in part I.D of thePermit' IUC has also agreed and Part I.H.14 of the Permit has been crafted to requiresubmittal of a Cell 4A contaminant removal schedule for Executive Secretary approval,which would include periodic progress reports of said contaminant removal.Requirements are also provided for tUC t-o complete removal of all fluids and salts storedthere, the FML liner and LDS layer, and any contaminated underlying clay or sub-soils,pursuant to Part I.H.14. Furthermore, if IUC desires to reconstruct and re-line Cell 44,the Permit also requires IUC to submit new engineering design and specifications for cell44 that meet BAT design and construction requi..*"rrir, urJ.""ur. prio, apfrorut,pursuant to Part LH.l5.
12._ this pond wasyvrrs wroriginally installed as a part of the initial Mill;rrst.u.xo, upproved by the NRC, and is
i::::j"l*:"::i!:1t"1of lh: miil site a shorr distance east of cll r. rhis pond
29
u yvt rLwas designed as an emergency catchment basin for major tank failure or process upsetfrom the mill' In May,2}02IUC made the decision to clean out the existing pond and
Statement of Basis
Faci
mes
T}RAT'T December 1,2004
replace the former Hypalon liner with a new High Density polyethylene (HDpE)membrane' To date, no IUC engineering design or as-buijt drawinls have been providedfor re-construction of the Roberts Pond, Uut ruC has committed tolrovide thisinformation in the near future. A brief description of the EML retrofit construction wasprovided in a February L9,20O4IUC email, details of which are outlined below:
A. The Roberts Pond is reratively small, less than 0.4 acres in size.
B' After 25 years of service the Hypalon liner in the Roberts pond was removed andreplaced with a single membrane, 60 mil HDpE liner.
C' After remoyll of the former Hypalon FML, IUC conducted radiological surveyswith both field instruments and uranium soil sampling and analysis"to determinesoil areas with concentrations that were above .,background,,.
D' Contaminated soils were excavated and moved to the ore storage pad for re-processing in the mill.
E' Foundation preparation included gleaning the sub-grade to remove oversize rock,rolling the sub-grade with a smooth drum roller, .uLirg pond sideslopes to removeoversize rock or other material, installation of a geotextile material over the entirefootprint as a protective layer under the FML.
F' Construction quality assurance / quality control (QA/QC) measures performedincluded three (3) destructive tests on FML seams (1 per 500 linear ieet),followed by air pressure tests and vacuum box tests where needed.
Without having reviewed the IUC As-Built report, the Executive Secretary cannotapprove either the design or the construction of the re-built pond. Howevlr, theExecutive Secretary has decided to accept the pond as it is, regulate it under the permit,
including imposition of DMT monitoring requirements, baseJon the following findings:
1) The Roberts pond is small in size, about 0.4 acres, compared to thetailings cells, and
2) The Roberts Pond is used to store intermittent wastewater flows, andtherefore may not be a constant head source
3) At the time mill site decommissioning, detailed radiologic surveys will beconducted of the entire area, and contaminated soils removed ani placedfor disposal in the tailings cells. All of these activities are regulated by theExecutive Secretary under the Radioactive Materials License
Therefore, Part I.H.l8 has been added to the Permit's compliance schedule to requiresubmittal of an As-Built report to document the recent aesign and re-construction. Afterreview of this report, the Executive Secretary will determini if additional measures arenecessary to protect public health and the environment. Such changes, if needed, wouldbe implemented as a part of the Reclamation plan required by the License.
13.
30
3) - in lieu of major engineeringdesign or construction changes, several new operational requirements *l.e i-"posed bythe Permit to minimize the potential for releasi of contaminants to ,rr. g."rrJri;;f..;the tailings cells and facilities at the mill site, including:
A.
added so as to require
Statement of Basis
ilin
DRAFT December 1,2004
control systems inside the slimes drain access pipe for both Tailings Cells 2 and 3.The intent of this requirement is to ensure thatihe average wastewater head in thislayer is maintained as low as reasonably achievable, and thereby minimizeleakage from the primary FML. Determination of the wastewater level that meetsthis criteria will be made uy ru_9 and approved by the Executive Secretary later asa part of the DMT Monitoring Plan, puriuant to Part I.H.13. Similar head controlrequirements have been stipulated by the Executive Secretary for other facilities.B. _ this requirementapplies to all tailings cells at the ruC fucltity. rte Ututr Water eualityRegulations require a minimum 3-foot freeboard for wastewater impoundmentsthat treat 50,000 gailons or more per day tuAC R3r3-10.3(c)1. rub has reportedthat the tailings disposal system is expected to average 335 gallmin, whichequates to a daily rate of 482,400 galtday (5t28lgg IUC Groundwater InformationReport, p. A-9). Assuming that this rate is evenly distributed between all Cells 1,2, and 3, this flow would equate to a daily rate of 160,800 galtday/cell, which iswell above the 50,000 galtday limit estabiished by State ruie. As a result, the 3-foot minimum freeboard limit applies to the IUCiailings cells, and such arequirement-was stipulated in ParlI.D.2of the Permit. The Executive Secretaryrecognizes that the NRC License already requires IUC to make an annualdetermination of the minimum freeboard required at the tailings cells to controlthe Potential Maximum Precipitation (PMP). This annual evaluation includescalculations to determine the necessary freeboard required in the tailings cells tocontrol any upslope run-off that could impinge on the tailings area, anjwouldhave to be maintained behind the tailings Ait"r. Consequently, the State,s 3-footfreeboard requirement imposed in Part i.o.z ir designed to compliment and notreplace the existing License freeboard requirement.
C. _ during review of theIUC design and as-built reports it was clear that Thilings Cells I and,2share acommon dike, and Cells 2 and 3 share a dike in common. The constructionoriginally approved by the NRC and the IUC design and as-built reports providedshow different elevations for the top of the FML liner at both the north and southsides of each.of these intervening dikes. Consequently, it appears possible forwaste to be disposed at an elevation where the FML does noi exist. The originalNRC approval stipulated that tailings material was to be deposited only to the topof the EML (personar communication, Mr. Harold Roberts, l0/ r5to4). Tocontinue this.restriction and prevent unacceptable tailings placement above theFML, an additional performance criteria was added to the irermit to require thatthe final tailings waste elevation,tefore cover system emplacement, always bebelow the maximum FML liner elevation in .u"il dirposaicell. Although Cell I iscurrently used for process wastewater storage and noi for tailings solids disposal,this requirement would still apply at Cell I at some future time when under thecurrent NRC approved reclamation plan requires Cell I be used for disposal ofdemolition debris from the mill and decommissioning wastes from the mill site.
ID 2)l - as discussed above,
discrete groundwater monitoring wells around each tailings cell as a means to
lrl,lfy the_ DMT requirements of the Gwep Rures tuAC"R3l7-6-6.4(c)(3)1.DMT performance srandards stipulated in part t.o.i(a)(z) of the p".-it ."qui.",3t
D.
Statement of Basis DRAFT December l,2OO4
-hi storically feedstockmaterials for the mill have been stored under open-air conditions in an
IUC to operate and maintain the tailings cells in such a manner as to preventgroundwater conditions in any nearby wells from exceeding the Groundwatercompliance Limits established in Tabre 2 of thepermit
E' Roberts Pond lPart I.D.3(c).1 - as described above, Iittle documentation has beenprovided by IUC regarding the design and construction of this mill sitewastewater catchment pond. This pond, is about 0.40 acres in size, and foundapproximately 180 feet west of the mill building and about 200 feei:teast of thenortheast corner of Tailings Cell 1 (see 612210r tuc Response, Attachment K,Site Topographic Map, Revised 6tol). This wastewater pond apparently receivesperiodic floor drainage and other wastewaters from the mill, is irequentty empty,and was re-lined with a new FML in May, 2002.
In order to minimize any seepage release from this wastewater pond, theExecutive Secretary has determined that an appropriate DMT operations standardwould be two-fold:
l) A stipulation that IUC maintain a minimal wastewater head in this pondbased on a 2-foot freeboard and a l-foot additional operating limit. Sincethe top of FML in this pond is about 5,626 feet above ,r.un-r"u level (ftamsl),the maximum operating solution limit in the Roberts pond was setin the Permit at 5,624 ft amsl. Because the lowest point on the EML isfound at 5,618 ft amsl, this would allow the pond to be operated with a 5-foot maximum head, and
2) At the time of mill site closure IUC will excavate and remove the liner,berms, and all contaminated subsoils in compliance with un upf.ou"d finalReclamation Plan under the Radioactive Materials License (heieinafterReclamation Plan). Since the Executive Secretary now has AgreementState status for uranium mills, the DRC will closely examine "
decommissioning of this pond at the appropriate time.
F. _ for new facilities, theGWQP Rules require that a potential air.t,urging f*ility meet BAT requirements.At other permitted facilities, BAT for waste s-torige areas has been defined asstorage over a hardened concrete or asphalt surfaCe. For existing facilities thatpredated the GWep Rules, less stringent design requirements, c-alled DMTstandards, are imposed [see UAC R317 -6-6.4(qi. For the IUC facility, theExecutive Secretary has decided to define DMT ior the feedstock storage area byrestricting the locations where this activity can be done, and by requirini thatcertain feedstock materials be maintainedin water-tight containers, as dlscribedDelow.
1)
area found along the eastern margin of the milisite. In order to minimizethe potential for groundwater and surface water pollution at the facility,the Executive secretary has decided to restrict feedstock storage to theexisting area, thereby constraining the size and location of these activitiesin the future. The Executive Secretary determined that this approach toDMT is appropriate, not onry because the practice has a historicarprecedence, but also because IUC has a commitment under the
32
Statement of Basis DRAFT December l,2OO4
Best Available for 4) - thissection has been added to the Permit to ensure that all new construction, modificatilrrqr crr rruw L\rllsLluu[IUIl, Ilrogulcauon, or
:.T:ll:i :l li*" or.wastewater disposat, treatment, or storage facilities requires
:::Tl,ji1:f;nsiyering.plans and specifications and prior #;;i;;;;rffi."ri.*and approval. In these plans and specifications the Permittee is required to demonstratehow the Best Available Technology (BAT) requirements of the Gwep Rules have been
Radioactive Materials License to decommission and decontaminate thisarea at the time of closure, in accordance with a July 7,2000 rucReclamation Plan. During preparation of the Permii, IUC staff explainedthat this reclamation plan includes radiologic soil surveys of uranium todetermine the depth to which excavation would be conducted, andcontaminated soils removed and disposed of in the tailings cells.Although DRC staff has yet to review and evaluate the content the IUCReclamation Plan, we anticipate this would be done as a part of the nextLicense renewal, scheduled for sometime on or near March 37,2007.
State plane coordinates for the Feedstock Storage Area are defined inTable 5 of the Permit, as a means to constrain rrih... open-air storage canbe done. These coordinates were initially estimated Uy OnC staff from aJune, 200r rUC topographic map (ibid.), and later refined by IUC in aFebruary 19,2004 email.
Designation of only one (1) open-air feedstock storage area will alsofacilitate IUC and DRC c-ompriance inspections by allowing readyidentification of feedstocks stored at the mill site.
2) Containerized Storage for Feedstock - during Permit preparation it wasagreed that if IUC chose to store feedstock materials *yrh"." else at thefacility, other than the feedstock storage area defined in permit Table 5,that this storage would be conducted onty in closed, water-tight containers.This more stringent requirement is appropriate in order to pr6tect theseother areas from contamination by contaCt stormwater runoff or feedstockleachates that might be generated by open-air storage.
3) Alternate Feedstock Storagq - IUC will be required to obtain anamendment to its Radioactive Materials License before it will beauthorized to receive and process any new alternate feed materials. Thisallows the Executive Secretary prior opportunity to review each licenseamendment application and determine if any splcial storage precautions
are needed to protect groundwater quality, public hearth uro it "environment.
G. s".ondary cortuir-ert fo. ch"-i.ul R"agert Sto.age lpurt I.D.3(")l _
significant quantities of chemical r"ugentr *" ,tor"d on the mill site for use in theuranium milling process. In order to minimize the potential for discharge tonative soils and groundwater, a DMT performance standard was added to thissection of the permit to require IUC to continue to maintain secondarycontainment around exiting storage areas and to require that any ,"* t.replacement storage facilities meet current BAT standards. Resolution of thisrequirement should be provided by IUC after submittal of the DMT MonitoringPlan required by parr I.H.13.
14.
JJ
15.
Statement of Basis DRAFT December 1,2004
met. After Executive Secretary approval a Construction Permit may be issued, and the
Ground Water Discharge Permit modified.
Definition of l1e.(2) Waste (Part LD.5) - this definition was added to the Permit for
purposes of clarity, as it regards prohibited discharges defined in Part I.C.1(c). The
Executive Secretary has determined that constraining the types of contaminants
authorized for disposal is consistent with discharge minimization and groundwater
quality protection. Regulatory definition of 11e.(2) waste is found in Section I le.(2) of
the U.S. Atomic Energy Act, L954, as amended, and includes: "the tailings or wastes
produced by the extraction or concentration of uranium or thoriumfrom any ore
processed primaily for its source material content". In addition to mill tailings solids
and wastewaters, the NRC considers other process related wastes to also be l1e.(2) by-
product material, including (see3l7l03 NRC letter):
A. Solid waste from facility office buildings,
B. Spent chemicals used in ongoing process operations, including laboratory
chemicals used for ore assay,
C. Virgin chemicals intended for use at the facility, but not consumed in process
operations, including laboratory chemicals intended for use in ore assay,
D. Non-uranium bearing structural or other debris found in alternate feedstock
materials accepted for on-site processing.
E. Contaminated groundwater from the on-going chloroform groundwater corrective
action project at the facility. This wastewater has been deemed as 11e.(2) waste
in that it originated from on-site disposal of spent laboratory chemicals used for
ore assay.
Post-Closure Performance Requirements (Part I.D.6) - currently a Reclamation Plan has
been approved by the NRC under the existing License. Soon the NRC License will be
converted to a State License as a part of the Agreement State transfer process. At the
time of the next License renewal, scheduled for sometime around March, 2007, DRC
staff will re-examine the Reclamation Plan for content and adequacy. New requirements
were added to the Permit at this time to ensure that the final reclamation design provided
adequate performance criteria to protect local groundwater quality. This is appropriate,
as discussed above, in that the cover system design and construction is the only means
available to the Executive Secretary to improve the existing facility and protect
underlying groundwater resources, if determined necessary. These new performance
criteria will also guide the infiltration and contaminant transport modeling to be done
shortly by IUC in response to requirements found in Part I.H.l 1. To this ind, three (3)
requirements were added to ensure that the cover system for each tailings cell will be
designed and constructed to:
A. Minimize the infiltration of water into radon barrier and underlying tailings waste,
B. Prevent the accumulation of leachates within the tailings that might create a
bathtub effect and thereby spill over the maximum elevation of the FML inside
any disposal cell; thereby causing a release of contaminants to the environment,
and
C. Protect groundwater quality at the compliance monitoring wells by ensuring that
contaminant concentrations there do not exceed their respective GWQS or GWCL
defined in Part LC.l and 'table 2.
16.
34
17.
Statement of Basis DRAFT December 1,2004
To provide consistency with the performance criteria stipulated by the Executive
Secretary at other lle.(2) disposal operations, a2}O-year minimum performance period
was required for all three (3) of these criteria.
Facility Reclamation Requirements (Part I.D.7 and I.H.l1) - Part I.D.7 has been added to
the Permit to provide the Executive Secretary an opportunity to ensure that:
A. The post-closure performance requirements for the tailings cell cover system in
Part I.D.6 is fully and adequately integrated into the Reclamation Plan. Because
DRC evaluation of this Reclamation Plan will be done at the time of the next
License renewal, scheduled on or around March, 2007; part I.H.l I has been
added to the Permit to require that IUC complete an infiltration and contaminant
transport model of the final tailings cell cover system to demonstrate the long-
term ability of the cover to protect nearby groundwater quality. As a part of this
cover system performance modeling required by Part I.H.1 1, the Executive
Secretary will determine if changes to cover system are needed to ensure
compliance with the Part I.D.6 performance criteria.
B' All other facility demolition and decommissioning activities outlined in the
Reclamation Plan will be done in a manner adequate to protect local groundwater
quality. Issues or concerns to be considered and resolved include, but are not
limited to:
1) Identification, isolation, and authorized disposal of any un-used chemical
reagents held in storage at the mill site at the time of closure.
Demolition, excavation, removal, and authorized disposal of all
contaminated man-made structures, including, but not limited to:
buildings, pipes, power lines, tanks, access roads, drain fields, leach fields,
fly-ash disposal ponds, feedstock storage areas, mill site wastewater
storage ponds, solid waste disposal landfills, and all related appurtenances.
Excavation, removal, and authorized disposal of all contaminated soils
found anywhere outside of the tailings cells at the facility.
Through this process the Executive Secretary aims to ensure that DMT has been
adequately established for both the final tailings cell cover system and reclamation of thefacility.
18. Stormwater Management and Spill Control Plan (Parts I.D.8 and I.H.17) - one aspect ofDMT is preventing and controlling contaminated stormwater and chemical spills irommill site activities. In July, 2001 IUC provided the DRC a draft copy of a Juiy 17 ,2OOlSpill Management Plan. Said plan included a section on stormwater management.
During a meeting in February,2004IUC explained that they had submitted this plan for
NRC approval. IUC also submitted a copy of the plan to DRC on July 17 ,2OOl and later
provided a second copy, which contained additional minor revisions on April 26,2004.
Subsequent DRC research found that the July 17, 2001 draft plan had not yet been
approved by the NRC. Currently, DRC staff are in review of this plan and will provide
colnments to IUC shortly. With respect to this issue, IUC and DRC reached the
following agreements:
A- IUC is an existing facility under the GWQP Rules. Therefore, the existing
stormwater management system and chemical I reagent storage facilities would be
accepted "as is" under the Permit.
35
2)
3)
B. In the future, any construction of new reagent storage facilities or major re-
construction of existing facilities will meet current BAT design and operation
standards.
C. Re-construction of reagent storage facilities may be required by the DRC after amajor spill or catastrophic failure of existing storage faiilities, pursuant to the
Permit re-opener provisions in part tV.N.3.
D. IUC will revise both plans submitted to take into account and resolve anyExecutive Secretary comments, and re-submit a final Stormwater Management
and Spill Control Plan for approval. The final plan will establish acceptable
operational, maintenance, monitoring, and reporting requirements for itormwater
management and spill prevention and control. The final plan will also provide
specific actions to prevent, respond to, control, and remediate spills of ihemical
reagents at the mill site.
To this end Part I.D.8 was added to the Permit to require IUC to conduct its activities incompliance with an approved Stormwater Managemint and Spill Control plan. part
I.H.17 was added to require IUC to submit a final version of tiis plan for Executive
Secretary approval.
19- Routine Groundwater Compliance Monitoring (Part I.E.1) - this section prescribes themonitoring requirements for groundwater monitoring wells at the facility, including
upgradient, downgradient, and lateral gradient wells. Some of the speciiic requireirents
are described below:
Statement of Basis DRAFT December l,2OO4
A.lvronrronng rrequency lparts r.E.l(a and b) and I.G.ll - routine groundwater
quality monitoring is commonly done on a quarterly basis (4+imes/year).
a and
rly basis (4+imes/year).
However, the Executive secretary may allow a reduced frequency of routinegroundwater sampling if site specific groundwater conditions warrant [see UACR317-6-6.16(AX2)1. For certain sites where groundwater velocities have beenfound as low as one to two feet per year, the Executive Secretary has approved asemi-annual sampling frequency (2-times/year) in order to avoid statistiialproblems such as auto-correlation, and allow a better measure of natural
groundwater quality variations.
During preparation of the permit,IUC submitted a March 25,2004Hydro GeoChem (HGC) letter and a January 30,2oo3 HGC groundwater velocity report
wherein IUC suggested that local groundwater velocity at White Mesa was about
1.1 to 2.8 feetlyear. Detailed DRC review found the January 30, 2003 HGC
analysis to be based on an area between the tailings cells and Ruin Spring, and notfocused on each individual monitoring well at the facility (see 9tz7l04 DRCMemorandum).
on october 15,2004 a conference call was held between DRC staff and
representatives of IUC and HGC. During this call, DRC staff asked that
additional work be done to determine local groundwater velocity at eachmonitoring well at the site, where velocity would be calculated on well specifichydraulic conductivity and hydraulic gradient data. On this same date,IUC staff
proposed that there be two (2) different frequencies of routine groundwater
monitoring at White Mesa, as follows:
36
Statement of Basis DRAFT December 1,2004
o semi-annual (2 timeslyear) where groundwater velocity is less than l0
feet/year, and
o Quarterly (4 times/year) where groundwater velocity is equal to or greater
than 10 feetlyear.
Latet IUC provided an October 19, 2O04HGC letter report that revised previous
HGC groundwater velocity calculations by providing well specific values. After
review of this HGC report, DRC staff found four (4) tailingi wells at the White
Mesa facility exhibit local groundwater flow velocity equal to or greater than l0
feetlyear, including (see I ll23l04 DRC Memorandum, Tables I ind2):
o cross-gradient wells: MW-26 (14 feettyear) and lvrw-32 (19 feet tyear).
Previously these wells were named rw4-15 and rw4-17, respectivlly, and
o Downgradient wells: MW-l I (135 feet/year) and MW-l 4 (62 feettyear)
All other existing IUC tailings cell monitoring wells were found with local
groundwater velocities of less than l0 feetlyear (ibid.). Based on this
information, the Executive Secretary has agreed to accept IUC's proposal for two(2) different routine groundwater monitoring schedules ut th" facitity, based on
the following findings:
l) Areas of high groundwater velocity deserve more frequent sampling in
order to rapidly detect contamination and remediate iiearlier *ttlt"it eproblem is smaller and closer to the source. To do otherwise is not
protective of groundwater quality resources, and serves only to make theproblem more expensive before it is discovered and corrected.
2) At ruc wells where groundwater velocity is equal to or above l0
feetlyeat, groundwater will travel more than 2.5 feetbetween quarterly
sampling events. At the highest velocity tailings well, MW-l L(135
feetlyear), groundwater at this downgradient location will travel about 34
feet between quarterly sampling events. The Executive Secretary believes
that this provides sufficient reaction time to confirm any contaminant
exceedance and regain control thereof.
3) At IUC wells where groundwater velocity is less than l0 feetlyear,
groundwater will travel less than 5 feet between each semi-annual
sampling event. At the tailings well with the lowest velocity, Mw-l
(0-026 feet/year) groundwater at this upgradient location wiil travel a very
short distance between each semi-annual sampling event (0.01 feet), and
auto-correlation will likely occur. Despite this statistical drawback, theExecutive Secretary believes that semi-annual sampling at this and other
low velocity locations is protective of the environment.
4) Above and beyond these baseline frequencies, the permit contains
provisions for accelerated groundwater monitoring to confirm the presence
of groundwater contamination, see Part I.G.l. Under these requirements,
IUC is mandated to accelerate its monitoring frequency when any
pollutant in any well exceeds its respective GWCL in Table 2 of the
Permit. For those wells with a semi-annual baseline frequency, quarterly
accelerated monitoring is required. For wells with a quarterty baseline
schedule, monthly accelerated sampling is required. In summary, a single
37
Statement of Basis T}RAF'T December 1,2004
exceedance in a single well will result in a much higher sampling
frequency in order to confirm the apparent problem, and puriuant to part
I.G.1, this accelerated monitoring will continue until the Executive
Secretary can determine the compliance status of the facility.
5) If groundwater contamination is detected and confirmed in the future,
technology ispvailable to control the contamination, and even reverse itsflow and thereby contain it near its source.
6) IUC owns and controls a large area of land downgradient of the tailings
cells where it can control public access to groundwater. Further, the *"pt
and springs found at the edge of White Mesa where the public could be
exposed to contaminated groundwater are even more removed from the
tailings cells. These long distances appear to provide ample reaction time
to detect and confirm the presence of contamination, and design and
implement corrective actions to regain control of said releases, should they
occur.
B. Monitoring Parameters lPart I.8.1(c)'l - both field and laboratory parameters arespecifically identified to ensure compliance. The need for laborat-ory analysis for
the Table 2 compliance parameters is self-evident. Certain other groundwater
quality parameters were added to assist in interpretation of g"n"ra1 geochemical
conditions present in the aquifer, including the major anions and caiions. Due to
the limited information available and uncertainty in the characteizationof the
tailings cells contaminant source terms, a broad suite of VOCs are also required
under the Permit (EPA Method 8260). In general, many VOC parameters may bekey indicators of groundwater pollution, in that they are man-made and are
mobile in groundwater environments, see discussion above.
C. Special Provisions lPart I.E.1(d)l - during review of the data from several split
sampling events since May, 1999, cerr.ain quality assurance issues have been
identified by the Executive Secretary. In order to ensure that these issues are
resolved in the future, special provisions have been added to the Permit to draw
attention to them.
Groundwater Head Monitoring (Part I.E.2) - certain wells and piezometers exist at theIUC facility that are completed in the shallow aquifer, but are not listed in Table 2 ascompliance monitoring wells for the tailings cells. These include five (5) piezometers
associated with the wildlife ponds (P-l thru P-5), two (2) existing wells outside the IUC
restricted area (MW-20 and.NNV-22), and several wells related to the chloroform
investigation. Currently these chloroform investigation wells include MW-4A, TW4-l
thru TW4-l4,TW4-76, TW4-18, and TW4-19, but may change as the investigation andcoffective action project progresses. Depth to groundwater or head monitoring is
required of these wells in order to maximize our understanding of local grounJwater flowdirections at the facility. To this end, a requirement was added to do thii extra headmonitoring at these existing wells and piezometers at the same frequency as the
compliance monitoring wells.
nd Con O - in order to provide an
20.
2t.
adequate monitoring well network, the Permit requires that a number of new monitoring
wells be installed, see Part I.H.1. To ensure that these new wells are properly located andconstructed, certain performance criteria have been added to the Permit in this section.
38
23.
Statement of Basis DRAFT December 1,2004
22- Monitoring Procedures for Wells (Part I.E.4) - this section has been added to the permit
to provide general performance criteria for groundwater sampling. Most important of
these is the requirement that all groundwater monitoring comply *ltt a quality assurance(QA) plan, such as will be submitted by IUC for Execuiive Secietary upprorui, pursuant
to Part I.H.6. In order to comply with requirements found in the C*ep nules [UACR317-6-6.3(I) and (L)1, ruC will need to submit its existing QA plan to ensure that it isconsistent with EPA guidance found in the RCRA Ground Water Monitoring Technical
Enforcement Guidance (TEGD) document (EpA, 1936).
s I.8.5. I.LH.9) - asdescribed below, monitoring of the contact seeps and springs at the "ag" of Wt ite Mesais important because these locations are where the shaliow iquifer discharges, and henceform points of exposure for wildlife and the public for any groundwater contamination
that may be released from the facility. This monitoring wilinot replace the compliancewell monitoring required by Part I.E.1, which will provide a much earlier warning of arelease. Instead, the seep and spring monitoring is designed to compliment the IUC
monitoring well data, and confirm that activities at the IUC facility huu" not adversely
impacted local surface water quality. Under the requirements of these two (2) sections ofthe Permit this sampling and reporting will be completed on an annual basis.
Determination of those seeps or springs selected for sampling will be completed afterExecutive Secretary approval of the White Mesa Seep and Spring Sampling Reportrequired by Part I.H.9. Commencement of this annual surface water monitoring will thenbegin after modification of the Permit accordingly.
r-rMr rerrormance stanoarO wtonttonng (Part LE.6 and I.H.l3) - Part I.E.6 stipulates themonitoring requirements needed to demonstrate compliance with the DMT p"*o..rrun""
standards set forth in Part r.D.Z and,3 of the permit, as summarized below:
A. Tailines Cell I - including weekly wastewater pool level monitoring to determine
compliance with the minimum freeboard requirement in Part 1.D.2. Again, if themaximum wastewater pool elevation is exceeded, IUC is required to immediately
notify the Executive Secretary under the provisions of Parts t.f.3 and I.G.3.
Quarterly depth to groundwater and groundwater quality sampling and analysis is
also required from three (3) discrete monitoring wells immediately adjacent toCell 1. DMT compliance is maintained at Cell I when the groundwatlr quality in
these three (3) monitoring wells does not exceed their respeitive GWeS in Table
2 of the Permit. In the event that any groundwater contaminant in these wells
exceeds a GWQS, IUC will be required to report the non-compliance pursuant toParts I.G.1 and2. A compliance schedule requirement has been added to part
I.H.l to ensure the DMT monitoring wells are installed properly at Cell l.
B. Tailings Cells 2 and 3 - including weekly wastewater pool elevation and slimes
drain water level monitoring. DMT compliance is maintained when the water
levels in the wastewater pools and in the slimes drain layers are below their
respective maximums specified in Part I.D.2. In the event that either of these
wastewater levels exceeds the requirements, IUC is required to report them
immediately to the Executive Secretary in accordance with Part I.F.3 and I.G.3.
C- Roberts Pond - including weekly monitoring of wastewater levels in the Roberts
Pond at the mill site to verify that the wastewater head is maintained so as toprovide the minimum 2-foot freeboard required by paft I.D.3(c).
24.
39
25.
Statement of Basis DRAFT December 1,2004
D. Feedstock Storage Area - including weekly monitoring to ensure that:
l) Bulk feedstocks are located and stored only inside the approved Feedstock
Storage Area, and that
2) Containerized feedstocks located outside the approved Feedstock Storage
Area are maintained in closed, water-tight containers.
In order to ensure that IUC provides appropriate monitoring equipment, and adequate
operation and maintenance procedures for DMT monitoring, a compliance schedule
requirements has been added to Part I.H.13 to require submittal and approval of a DMT
Monitoring Plan.
On-site Chemicals Inventory and Reporting (Parts I.E.7. I.F.7. and I.H.10) - much of the
discussion above regarding determination of groundwater monitoring parameters is
intimately related to the type of ore or feedstock material being processed, and the types
and concentrations of chemicals used on-site in the milling process, on-site laboratory,
etc. For this reason, the Executive Secretary has determined it critical to maintain an
inventory of chemicals in storage and used at the facility in order to determine at some
future date the appropriate parameters that should be considered both for characterization
of the tailings cells wastewaters, and for groundwater monitoring parameters.
To this end, monitoring requirements were added to Part I.E.7 to require IUC to maintain
a current chemical inventory on site. The Executive Secretary recognizes that some
chemicals may be used at such a small rate that they do not constitute a potential risk to
groundwater quality. In order to address this issue, an annual consumption rate of 100
kg/yr was specified. Using this provision, IUC need not inventory those compounds
whose annual consumption is less than this amount.
Reporting requirements for this inventory were also added to Part I.F.7, where IUC will
be required to submit a report at the time of Permit renewal, i.e., 180 days before
expiration of the current Permit.
The Executive Secretary has determined it important to establish a baseline inventory of
historical and current chemicals used at the facility. To this end, a new Permit
requirement was added to the Permit's compliance schedule in part I.H.l0.
Tailings Cell Wastewater Ouality Monitoring. Reporting. and Sampling Plan (Parts I.E.8.
I.F.8. and I.H.5) - after review of the historic tailings cell wastewater quality samples
collected to date by IUC, it appears that IUC's tailings wastewater sampling and analysis
has been focused on process control and not environmental considerations (see
Attachment 6, below). Historically, IUC has not been required to conduct any
comprehensive analysis of this tailings wastewater for environmental purposes.
Consequently, the available data are limited both in the number of samples and
parameters. Little information is also available regarding quality assurance issues for
said sampling and analysis. In light of this situation a new requirement has been added to
the Permit to require a comprehensive and routine examination of tailings wastewater
quality for environmental purposes. To facilitate this, a compliance schedule item was
added to Part I.H.5 to require IUC to submit a plan for Executive Secretary approval for
routine tailings cell wastewater monitoring. The purpose of this sampling plan is to
identify the distinct sources of tailings wastewater that will be sampled (wastewater pool,
slimes drain, etc), standardize all sampling and analytical procedures, and provide an
26.
40
Statement of Basis DRAFT December 1,2004
outline for compliance with all related monitoring and reporting requirements in Parts
I.E.8 and I.F.S of the Permit.
This approach of annual sampling assumes that over several years a sufficient number of
samples will be available to adequately describe the average chemical conditions of these
wastewaters.
Further, the approach in Part I.8.8 also specifies that the samples be collected in August,
at the peak of the evaporation season in order to measure the highest contaminant
concentrations in the system.
Other approaches to sampling frequency could have been used, such as: l) a minimum
number of days of mill operation, 2) sampling after a change in feedstocks processed, or
3) multiple samples for each season of the year, etc. However, all of these have
drawbacks, in that they: l) ignore the dynamics of local weather conditions which
change from year to year, 2) ignore processing schedule dynamics which are also
variable, 3) require more samples to be collected, 4) mandate tedious monitoring and
reporting to document and justify the frequency used, and 5) result in increased sampling
costs with little apparent benefit. In the end, the Executive Secretary chose a simple
approach of one (1) annual sample from each tailings wastewater source to be collected
when contaminant concentrations should be highest.
The information generated by this routine monitoring will also be helpful in the on-going
chloroform contaminant investigation. In an April ll,2}02 Technical Information
Request, DRC staff asked IUC to fully characteize the contaminants in this wastewater,
and allow the State to collect split samples in this process (ibid., pp. 15-16). The need for
this characterization was discussed with IUC in meetings of April 17 and,24,2002. In
the latter meeting, IUC agreed to sample and analyze the tailings wastewater for a
comprehensive suite of contaminants, including, but not limited to: metals, VOCs, Semi-
VoCs, etc. It was also agreed that a sampling plan would be submitted for DRC
approval before sampling began. Later,IUC provided a May 3l,2OO2 work plan for this
sampling. DRC staff reviewed the sampling plan and requested additional information in
a July 3,2002 email. Because discussions about the content of this sampling plan are on-
going, Part I.H.5 has been added to the Permit to require IUC to submit a tailings cell
wastewater sampling plan for Executive Secretary approval.
Pending completion of this sampling plan, on August 12,2O03IUC voluntarily submitted
results of several grab samples collected from the tailings cells in March, 2OO3,which are
summarized in Attachment 6, below. Preliminary DRC review shows the following:
1) IUC samples were collected from impounded wastewaters in Tailings Cells I and
3 and analyzed for a partial list of the analyes previously agreed to in the plan,
including: major ions, nutrients, metals, and radiologics,
2) No sampling was conducted of impounded wastewater at either Tailings Cells 2
or 4,{ because no exposed solution was available at the time of sampling (March,
2003),
3) No samples were collected from the slimes drain layers or leak detection systems
in Cells 2,3, or 4A,
4) No analysis was made for any VOC or Semi-VOC contaminants in any sample.
This March,2003IUC data may be used at sometime in the future by the Executive
Secretary in his review of routine monitoring data to be collected under the Permit. In
4t
Statement of Basis DRAFT December 1,2004
the meantime, the Permit will require routine monitoring in order that a defensible and
representative characteization of tailings wastewater quality be completed.
Part I.E.S of the Permit also requires IUC to provide 30-day prior notice, so as to allow
the Executive Secretary an opportunity to collect split samples of these tailings cell
wastewaters. DRC staff intend to periodically conduct such split sampling as a means of
verification of IUC' s tailings wastewater characteization.
Reporting requirements in Part LF.8 mandate that IUC report the annual tailings
wastewater quality results with the 3'd quarter groundwater monitoring report, due each
year on December 1. This section also requires that the content of these reports be
similar to the quarterly groundwater monitoring reports, by providing the field data
sheets, copies ofthe laboratory reports, a quality assurance evaluation and data
validation, and reporting in electronic format, pursuant to Part I.F.l(a), (b), (d), and (e).
27. Groundwater Reporting Requirements (Part I.F.1 and Table 6) - this section was added to
the Permit to provide a schedule for reporting and to detail the types of routine quarterly
groundwater monitoring data required. The schedule provided in Table 6 of the Permii
allows IUC 45 days after the end of each quarter to submit the required information.
Most of the data requirements are self-explanatory, but are specifically listed in the
Permit to assist IUC in providing complete submittals. The list of required information
will also provide a guide for the types of information that must be considered in
preparation of the Groundwater Monitoring Quality Assurance Plan, required by Part
r.H.6.
In addition, the Executive Secretary has required the submittal of quarterly water table
contour maps to emphasis the need to understand groundwater flow directions at thefacility. Pursuant to Part IV.N.3, these contour maps will allow the Executive Secretary
to require new compliance monitoring wells should it be discovered that groundwater
flow directions have changed.
A section has also been added to require IUC to provide the groundwater quality results
in an electronic format, which will allow the Executive Secretary ready access to the
information and will speed review of the data.
28.tine D ui 2 and I.G.3) -PartlF.2has been u g
related to the DMT standards specified in Part I.E.6, including wastewater pool
elevations in all three (3) tailings cells, slimes drain head for Tailings Cells2 and 3, and a
summary table of weekly wastewater levels measured by IUC at the Roberts Pond in themill site area.
In the event that IUC discovers an upset condition, where the DMT performance standard
has been violated, they are required to notify the Executive Secretary within 24-hours of
discovery (verbal) and 5 days (written) of the problem. Examples of these types of
problems, include, but are not limited to:
o Excess wastewater head at any of the tailings cells or the Roberts Pond,
o Excess leachate head in the slimes drain layer at Tailings cells 2 or 3;
DMT Performance Upset Reports (Part I.F.3) - this requirement was added to the permit
for clarification purposes to distinguish this reporting from the routine DMT performance
reporting to be submitted quarterly under Part LF.2. Examples of DMT failures that need
29.
42
30.
31.
33.
34.
35.
32.
Statement of Basis DRAFT December 1,2004
to be reported under this section include, but are not limited to: excess wastewater pool
elevations in Tailings Cellsl, 2,3, and the Roberts Pond; excess slimes drain leachate
heads at Tailings Cells 2 and 3; bulk feedstock materials stored outside the approved
storage area; and leaking containers of altemate feedstock materials, etc.
Other Information (Part I.F.4) - in the event that the Permittee omits information, or
discovers incorrect information was reported, this section provides a timeline by which
IUC must correct or complete the respective report.
Groundwater Monitoring Well As-Built Reports (Part I.F.5) -this section has been added
to the Permit to provide specific guidelines on what kinds of information are required for
monitoring well as built reports. The Executive Secretary deems it necessary to provide
these details, in light of the need for additional monitoring wells at the facility, as
mandated by Part I.H.l of the Permit.
Part of the requirements mandated here require the geologic log for each monitoring well
be prepared by a Professional Geologist licensed by the State. This requirement was
added in order to comply with the recent Professional Geologist Licensing Act, enacted
by the Utah State Legislature in 2002, and the attending Professional Geologist Licensing
Rules (UAC Rl56-76). The requirement that the survey coordinates for each monitorint
well be prepared by a Utah licensed land surveyor or engineer was added to the permit in
order to ensure accuracy for the survey coordinates reported.
Accelerated Monitoring Status (Part I.G.l) - this section of the Permit is taken almost
verbatim from the GWQP Rules in UAC R317-6-6.16(4). It requires the Permiuee to
accelerate the frequency of monitoring in the event that any pollutant in any well exceeds
its corresponding GWCL, as defined in Table 2 of the Permit, and to continue that
accelerated monitoring frequency until such time as the Executive Secretary can
determine the compliance status of the facility. Because semi-annual and quarterly
groundwater monitoring have been defined as the routine frequencies in Part I.E.l, this
accelerated monitoring status would require quarterly and monthly groundwater quality
sampling, respectively.
Violation of Permit Limits (Part I.G.2) - this section is taken almost verbatim from the
GWQP Rules, found in UAC R3l7-6-6.16(B).
ailure echnol Permit
- this section of the Permit is taken almost verbatim from the GWQP Rules found in
UAC R317-6-6.16(C)
Facility is Out-of-Compliance (Parts I.G.4 and I.H.l6) - general requirements to address
facility out-of-compliance status are found in Part I.G.4 of the Permit, which is taken
almost verbatim from the GWQP Rules (UAC R317-6-6.17). This section of the permit
references the ability of the Executive Secretary to require immediate implementation of
the Contingency Plan to regain and maintain compliance with the Permit, should the
Permittee fail to act [see Part I.G.4 (d)]. Such Executive Secretary action is authorized by
the GWQP Rules IUAC R317-6-6.17(.4,)(4)]. This plan is also required as a part of a
Permit application in the GWQP Rules tuAC R3l7-6-6.3(N)1. To date, IUC hasn,r
submitted a Contingency Plan for Executive Secretary approval. The overall goal for this
plan is to provide the necessary actions for IUC to re-gain compliance in several areas
regulated by the Permit, including: groundwater quality, limitations or prohibitions on
contaminants discharged to the tailings cells, and./or Discharge Minimization Technology
performance standards (e.g. tailings cell solids and wastewater elevations, slimes drain
43
Statement of Basis DRAFT December 1,2004
operation, etc). For this reason a compliance schedule item in Part I.H.16 has been added
to the Permit to require IUC to provide a final plan for Executive Secretary approval.
36. Accelerated Monitoring Status for New Wells (Part I.G.5) - this section was added to the
Permit to clarify that compliance monitoring of the new tailings cell monitoring wells
required by Part I.H.1 does not begin until after Executive Secretary approval of the
Background Groundwater Quality Report required by Part I.H.4. As a result, IUC will
not be required to accelerate their monitoring frequency, as per Parts I.G.1 (Probable Out-
of-Compliance), or I.G.2 (OuGof-Compliance), until after approval of this report.
37. Groundwater Monitoring Ouality Assurance Plan (Part I.H.6) - the GWQP Rules require
that the Permit application include several information items regarding quality assurance
and quality control for groundwater monitoring [UAC R3l7-6-6.3(I) and (L)]. Part of
this requirement mandates that groundwater sampling conform to the EPA RCRA
Ground Water Monitoring Technical Enforcement Guidance (TEGD) document (EPA,
1986). Prior to the May, 1999 split sampling event, IUC provided a Groundwater Quality
Assurance Project Plan to the DRC (3/90 ruC Groundwater QA Project Plan, Rev. 2).
However, this plan was written for purposes of the NRC radioactive materials license,
and did not specifically rely on the EPA RCRA TEGD (ibid., p. 3). In order to provide
IUC the opportunity to modify their existing plan to conform to the State requirements, a
new compliance schedule item was added to Part I.H.6 of the Permit, which mandates a
revised plan be submitted for Executive Secretary approval. After review and approval
of this modified plan, the Permit will be re-opened and modified to require that all future
groundwater sampling comply with the new plan.
38. Monitoring Well Remedial Construction and Repair Report (Part I.H.7) - during several
sites visits and four (4) split groundwater quality sampling events since May, 1999, DRC
staff have noted the need for remedial construction, maintenance, or repair at several
monitoring wells at the IUC facility, including:
A. Well Development - 16 of the existing monitoring wells at the IUC facility fail to
produce clear groundwater in conformance with the EPA RCRA TEGD. The
observed groundwater turbidity appears to be the product of incomplete well
development, and poses a potential for bias of the groundwater quality analytical
results, particularly for metals and nutrients. Consequently, the Executive
Secretary has determined it necessary to require IUC to develop these wells in
order to ensure they meet the EPA RCRA TEGD turbidity criteria of 5
nephelometric turbidity units (NTU), to the extent reasonably practicable.
B. Protective Surface Casinqs: Piezometers - in response to a DRC request for
additional hydrogeologic information, IUC installed five (5) piezometers at the
White Mesa facility in December,200l (518102 Hydro Geo Chem Report, p.l).
While no protective steel surface casings were called for in the original approved
installation plan, it is important to protect these piezometers because they are used
for groundwater head monitoring under Part I.8.2. The lack of protective casing
poses a problem because the l-inch diameter PVC piezometer casings could be
easily broken by surface activities. Also, PVC is prone to degradation by
ultraviolet light, and could be easily degraded.
In order to ensure that the monitoring wells are properly repaired and developed in a
timely manner these requirements have been added to part I.H.I.
44
39.
Statement of Basis DRAFT December 1,2004
40.
Monitoring Well MW-3 Verification. Retrofit or Reconstruction Report (Part I.H.8) -during recent split sampling events and after review of available well MW-3 as-built
information, DRC staff have found several problems with the construction of this well,
including:
A. Missing Geologic Log - review of the MW-3 well as-built diagram shows that no
geologic log was provided at the time of well installation (7l94Titan
Environmental Report, Appendix A, as-built diagram). consequently, it is
impossible to ascertain if the screened interval was adequately located across the
base of the shallow aquifer, i.e., at or below the upper contact of the Brushy Basin
Member of the Morrison Formation.
B. Lack of Filter Media - well MW-3 was constructed without any filter media or
sand pack across the screened interval.
C. Excessively Long Casing Sump - a 9 or lO-foot long non-perforated section of
well casing was constructed at the bottom of this well.
D. Poor Positioning of Well Screen Apparent - about 2 week after installation of
well MW-3, mill staff found the well to be dry (ibid., Appendix A,9a4179).
However, in late September,lgTg mill staff measured the static water level at a
depth of 83.4 ft (ibid., Appendix 8,9125179). Recent DRC water level
measurements show that the water table surface is found at a similar depth, 83.6
feet below the water level measuring point (ft bmp, 919102). After consideration
of the well's measuring point stickup, 1.95 feet, the September,2OOZ water level
was only about 5.3 feet above the base of the well screen. This well construction
and water table depth poses a problem in that at the IUC purge rate of 2 gallons
per minute (gpm), the well is rapidly purged dry and IUC is unable to complete
both purging and sample collection in one continuous process.
Arguments have been made by IUC that the well screen in MW-3 was properly set based
on the local geology found there. However, no geologic or geophysical logs exist to
support this assertion. Consequently, the Executive Secretary has determined it
necessary to verify, retrofit or reconstruct this well. Key to this mandate is the
requirement to determine the total saturated thickness of the aquifer at well MW-3, which
will require determination of the depth of the upper contact of the Brushy Basin Member
of the Morrison Formation at this location. This can be done either by geophysical
logging and/or drilling of a confirmation boring in the immediate vicinity of the well.
After determination of the complete saturated thickness of the aquifer at well MW-3, the
Permittee is required to retrofit or re-construct the well to ensure the well screen fully
penetrates the saturation. Thereafter, a new well as-built report must be submitted. After
approval of the replacement well, if needed, the Executive Secretary may require
plugging and abandonment of the former well. The Permittee is also required to provide
at least a7-day notice of all field activities, so as to allow the Executive Secretary to
observe these activities and participate in decisions regarding the fate of well MW-3.
white Mesa Seeps and springs Sampling Report (Part I.H.9) - in a February 7, zooo
request for information, IUC was asked to provide a hydrogeologic study of the contact
seeps and springs found at the edge of White Mesa (see2l7l00 DRC Request for
Information, p. 13). The purpose of this study was to establish background groundwater
flow and water quality conditions at these discharge points, and included a request for:
45
Statement of Basis T}RAFT December 1,2004
A. Land Survey - of the seeps/springs,
B. Water Table Contour Map - of both the IUC monitoring wells and the contact
seeps/springs, and
c. Groundwater ouality sampling - and analysis of said seeps/springs.
IUC responded to portions of this request in a September 8, 2000 submittal. Later the
DRC renewed its request for survey coordinates for these seeps and springs in a March
20,2001letter to IUC (3120101 DRC Request for Information, p. 6). Subsequently, IUC
provided survey coordinates for three (3) contact seeps at the edge of White Mesa,
including elevation data (917101 ruC letter, attached spreadsheets).
Subsequently, other parties expressed interest and concern in the groundwater hydrology
and water quality of these seeps and springs at the edge of White Mesa, including the
Moab office of the Bureau of Land Management (BLM), and White Mesa band of the
Ute Mountain Ute Tribe (Ute Tribe). In June, 2002theDRC proposed a collaboration
between the BLM, Ute Tribe, IUC and DRC to study the hydrogeology of the white
Mesa contact seeps and springs. In subsequent discussions it was agreed that: l) the Ute
Tribe, with BLM assistance, would complete a detailed reconnaissance of all the seeps
and springs found downgradient of the IUC tailings cells at the edge of White Mesa, 2)
IUC would provide a land survey to accurately locate and determine the elevation of all
the seeps and springs identified by the Ute Tribe, and 3) DRC would provide analytical
services for the groundwater quality samples collected.
Later, on September 20,2002 DRC and Ute Tribe staff conducted a preliminary field
survey of seeps and springs in the area, and located six (6) different discharge points at
the edge of White Mesa, all of which appear to be hydraulically downgradient of the IUCfacility. These seeps and springs are summarizedinTable r0, below.
Table 10. Kn White Mesa Perime
l) Generalized compass direction and approximated distance from estimated center of IUC Tailings Cell l.
During a May 21,2003 conference call between BLM, Ute Tribe,IUC and DRC staff
several other aspects of this hydrogeologic study were discussed, including: goals and
objectives of the study, need for an upgradient reference seep, field and laboratory
parameters to sample and analyze, field sampling equipment and methods, data quality
assurance measures needed, and capability for split sampling. At the conclusion of this
46
. llnown wtute ter Seeps and Sprines as of Seotember- 2OO2
Seep or
Spring
Name
USGS 7.5
Minute
Quadrangle
Approximate Location Relative to
IUC Tailinss Cells (1)
Approximate Map LocationDirectionDistance (ft)
Entrance
Seep
Black Mesa
Butte
East 4,700 -300 ft E., 0 ft S., NW Comer,
Sec. 34, T. 37 S., R.228.
Westwater
Seep
Black Mesa
Butte
West 5,200 -1,000 ftB.,2O0 ft S., NW Corner, Sec.
32,T.37 S., R. 22E.
Cottonwood
Seep
Black Mesa
Butte
Southwest 9,400 -1,500 ft N, 2,200 ft W., SE Corner,
Sec. 31, T.37 S., R.22E.
Ruin Spring Black Mesa
Butte
Southwest 13,000 -2,200ftE.,1,200 ft S., NW Corner,
Sec. 8, T. 38 S., R.228.
Corral Seep Big Bench South 16,200 -300 ft 8.,I,200 ft N., SW Corner, Sec.
10, T. 38 S., R.22 E.
Tank Seep Big Bench Southeast 21,400 -2,300 ft N.,400 ft W., SE Corner, Sec.
15, T. 38 S., R. 22 E.
Statement of Basis DRAFT December 1,2004
42.
meeting, the parties agreed to convene again after the Ute Tribe completed its detailed
field survey of White Mesa seep and spring locations. On July l,2}03,the Ute Tribe
reported that the field survey was about half done (7lll03 Ute Tribe email). To date, it is
unknown if the Ute Tribe field survey has been completed.
After all of these considerations, the Executive Secretary has determined it appropriate
for IUC to bear the responsibility for this study, by adding a Permit requirement for a
White Mesa Seeps and Springs Sampling Report in Part I.H.9. This is done not only to
ensure IUC participation, but to accelerate completion of the study, and provide timely
resolution of concerns held by local citizens and tribal members regarding the potential
for pollution from the tailings cells to adversely affect nearby surface water quality.
A provision has also been added to Part I.H.9 to allow the Executive Secretary to re-open
and modify the Permit after approval of said sampling report, in particular Parts I.E.5 and
I.F.6. The purpose of this action is to allow the collection of background groundwater
head, flow, and water quality data during the operating life of the facility. This is
important in that these seeps and springs form points of exposure for wildlife and the
public where offsite groundwater contamination could be discharged. By way of
clarification, it is not the Executive Secretary's intent to use this seep and spring
sampling in lieu of compliance monitoring well sampling at the facility. Instead, it is to
be used to complement that data collected from wells at the IUC facility, with the intent
of establishing background water quality conditions at these surface water locations.
Recently IUC initiated its own sampling of Ruin Spring and sampled Cottonwood Spring
on one occasion when water was available. At the time these samples were collected,
these were the only seeps and springs IUC considered to have sufficient flow to allow
sampling. Results of this sampling have yet to be reviewed by the DRC.
Deep Supply Well Plugging and Abandonment Plan (Part I.H.12) - after review of
available well completion information, IUC was informed that the construction of a deep
supply well, WW-2,located hydraulically upgradient of the mill site, was inadequate, in
that it failed to provide an annular seal that would isolate the deep confined aquiier from
the shallow unconfined aquifer (see2l7l00 DRC Request for Additional information, pp.
7-9). This same DRC request also asked that this problem be investigated for all other
deep supply wells at the IUC facility (ibid., p. 9). In response IUC agreed to consider
several alternatives for well WW-2 at the time of mill decommissioning (9/8/00 ruC
Response, p.20). To this end, a new condition was added to the Permit in Part I.H.12 to
require submittal of a work plan within I year of Permit issuance that would apply to all
the deep supply wells at the facility. This mandate also provides: l) a performance
objective to ensure that both physical and hydraulic barriers are constructed in the deep
supply wells at the time of plugging and abandonment to prevent hydraulic
communication between the shallow unconfined and the deep confined aquifers, and2) a
requirement that the provisions of the approved plugging and abandonment plan on or
before decommissioning of the uranium mill.
Facility DMT Monitoring Plan (Part I.H.l3) - as described above, the Executive
Secretary in issuance of this Permit has reviewed the existing engineering design and
construction, determined the DMT design and performance standards (Parts I.D.l and
I.D.3), established DMT monitoring criteria (Part I.E.6), and established DMT reporting
requirements (Part \.F.2). However, the Executive Secretary has not yet had the
opportunity to review and approve the specific activities, procedures, and equipment that
IUC will use to monitor and verify DMT compliance. In order to provide for this
41.
47
43.
Statement of Basis DRAFT December 7,2004
opportunity, Part I.H.l3 has been added to the Permit. Facilities that need to be
examined in this plan include, but are not limited to: various wastewater level criteria for
Tailings Cells 1, 2,3 and the Roberts Pond; the Feedstock Storage Area restrictions, and
secondary containment for mill site reagent storage.
Relatively short timeframes have been provided in order to accelerate IUC's
implementation of DMT. Provisions have also been included in Part I.H.13 to allow the
Executive Secretary to re-open and modify the Permit, so as to include all necessary
monitoring procedures and equipment.
Tailings Cell4.{ Reconstruction Schedule and Report (Part I.H.14) - as discussed above
the Executive Secretary has determined it necessary to require IUC to continue to
complete its removal of the contaminated materials and liner system in existing tailings
Cell4,{. Over the past two (2) years IUC has been removing the raffinates and salts that
have been stored in the cell, and disposing of them in tailings Cell 3. To ensure that this
process is completed in a timely manner, a requirement has been added to Part I.H.14 to
require IUC to submit a contaminant removal schedule for completion of this work for
Executive Secretary approval. This new requirement also mandates periodic progress
reports, and a final completion report that is to be submitted after contaminant removal is
finished, for Executive Secretary approval. It is anticipated that adequate contaminant
removal will include removal of all fluids, any residual salts or solids, the FML liner
system, any underlying LDS, and all contaminated clay sub-liner and any contaminated
sub-soils. During Permit preparation, it was agreed that IUC will perform a radiologic
survey and/or uranium laboratory analysis ofthe clay sub-liner and ifnecessary any
underlying soils found under Tailings Cell 4A to determine the total extent of any clay
sub-liner or subsoil contamination. This approach is justified, in that under oxidizing or
acidic conditions uranium is expected to by highly mobile in soils. Consequently, the
Executive Secretary believes that uranium soil concentrations can be used as a tracer to
estimate the vertical penetration of contaminants in the raffinates and salts once stored in
Cell 4,{. No approval of the final contamination removal report will be issued until the
Executive Secretary is satisfied that any contaminants potentially released to the clay sub-
liner or sub-grade soils via the FML leakage discussed above, have been adequately
recovered and placed back into appropriate engineering control.
Tailings Cell4,{ Redesign and Reconstruction (Part I.H.l5) - although somewhat
redundant with the provisions of Part I.D.4, this requirement has been added to
emphasize the need for Executive Secretary approval before any re-construction of
tailings Cell4,{, including: soil foundation or sub-base preparation, liner construction, or
leak detection system construction. This section also allows the Executive Secretary to
re-open and modify the Permit to add any necessary design, construction, operation,
monitoring or reporting requirements for the revised cells.
Executive Secretary Findings Regarding Existing Facility Requirements - the GWQP
Rules mandate that the Executive Secretary may issue a Permit for a facility that was
constructed before adoption of the GWQP Rules in 1989, i.e., an "existing" facility, that
certain provisions are met by the applicant, including [UAC R3l7-6-6.a(C)]:
" . . .l. the applicant demonstrates that the applicable class TDS limits, ground
water quality standards and protection levels will be met;
2. the monitoring plan, sampling and reporting requirements are adequate
to determine compliance with applicable requirements;
44.
45.
48
Statement of Basis DRAFT December 1,2004
3. the applicant utilizes treatment and discharge minimization technology
commensurate with plant process design capability and similar or
equivalent to that utilized by facilities that produce similar products or
services with similar production process technology; and,
4. there is no curuent or anticipated impairment of present andfuture
beneficial uses of the groundwater."
After consideration of the above discussion, the Executive Secretary believes the GWQP
Rule requirements have been or will be met by the provisions of the draft Permit, as
described below:
A. Applicable TDS Limits. GWOS. and GWPLs - the draft Permit establishes both
GWQS and GWCLs for all related contaminants known to exist in the tailings
wastewater effluent. On an interim basis, the GWCLs assigned herein were based
on the factoring approach allowed in the GWQP Rules. Later, after completion
and approval of the existing well Background Groundwater Quality Report (Part
I.H.3), the Executive Secretary will establish a GWCL based on descriptive
statistics (X+2o) for all compliance parameters in Table 2 in eachmonitoring
well. Future compliance monitoring at the facility will verify if ruC continues to
meet these GWCLs at each well. If at sometime, one of more wells exceed its
GWCL for TDS or any other Table 2 contaminant, enforcement action will be
taken to ensure local groundwater quality is restored.
B. Monitoring Plan. Sampling and Reporting Requirements - groundwater
monitoring at the facility is adequate in that all related contaminants known to
exist in the tailings effluent at elevated concentrations have been selected for
compliance sampling, and respective GWQS and GWCL have been established.
DMT monitoring requirements have also been determined for each potential
contaminant source at the facility. Although a certain number of monitoring wells
need to be installed, and groundwater compliance and DMT monitoring plans
need to be finalized and approved, the Executive Secretary has required these
activities to be completed and the missing plans submitted for approval. Upon
approval of these activities, completion by IUC, and submittal and approval of the
required monitoring plans, the Executive Secretary will re-open and modify the
permit to incorporate all necessary requirements. At that point, the approved
monitoring plans will become enforceable appendices to the Permit, and the
Permit will be complete in terms of providing adequate monitoring and reporting.
C. Satisfactory DMT - the review conducted herein has identified those aspects of
existing facility design and construction that do not meet current standards. In
turn, the Permit specifies new monitoring and operational improvements to
minimize the potential for discharge of contaminants to native soils and
groundwater from several potential sources at the facility, including the tailings
cells, wastewater ponds, feedstock storage areas, etc.
D. Impairment of Beneficial Uses of Groundwater -This determination will be made
by the Executive Secretary after IUC completes two major efforts: 1)
Improvements to the existing monitoring well network, including addition of new
wells to provide more discrete and more rapid detection of potential seepage
release from the tailings cells, and establishment of an approved groundwater
monitoring quality assurance plan to enhance reliability of reported monitoring
49
Statement of Basis
Attachments (11)
F:/. . ./IUCgwpSOB2f.doc
File: IUC Ground Water Permit
LBM:lm
DRAFT December 1,2004
results, and?) Submittal of a Background Groundwater Quality Report to provide
a comprehensive evaluation of local groundwater quality conditioni. Afte;
review of this report, the Executive Secretary will re-open the permit and modifythe GWCLs to reflect natural groundwater conditions, br may take enforcement
actions as necessary to protect local groundwater quality and all related current orfuture beneficial uses of groundwater. In either caie, a public review and
comment period will be provided, either for a modified Permit, or at the time ofapproval of any groundwater corrective action plan that may be required.
With regards to possible future groundwater quality impairment, infiltration,
groundwater flow, and contaminant transport modeling will be provided by IUC
to predict future compliance by the facility. The Permit requires that these typesof models be used to evaluate the existing NRC approved Reclamation plan for
the facility, and stipulates minimum performance criteria for the same. If themodeling indicates that these minimum performance criteria will not be met, then:
1. changes to the tailings cell cover design will be implemented by the
Executive Secretary in the Reclamation Plan under the State License, and
2. The input values to these models will become the design basis for the final
engineering design, specifications, and construction parameters for the
cover system at the reclaimed facility.
50
Statement of Basis DRAFT December 1,2004
References
D'Appolonia Consulting Engineers, Inc., February, 1982, "Construction Report Initial phase -Tailings Management System White Mesa Uranium Project Blanding, Utah Energy FuelsNuclear Inc- Denver, Colorado", unpublished consultants report, approxim ately ipp.,6tables, l3 figures,4 appendices.
Dames & Moore, January 30,1978, "Environmental Report White Mesa Uranium project SanJuan County, Utah for Energy Fuels Nuclear, Inc., unpublished consultants report,approximately 549 pp., 9 appendices.
Deutsch, W. and P. Longmire, February, 1997, "Pract-ical Applications of Groundwater
Geochemistry", National Ground Water Association r"-ir- proceedings, Denver, CO,approximarely 988 pp.
Energy Fuels Nuclear, Inc., March, 1983, "Construction Report Second phase Tailings
Management System White Mesa Uranium Project Energy Fuels Nuclear, Inc.,i
unpublished company report, 18 pp., 3 tables, 4 figures, 5 appendices.
Hem, J.D., 1985, Study and Interpretation of the Chemical Characteristics of Natural Water",3tdEdition, USGS Water Supply paper 2254,264 pp.
Hintze, L.F., 1988, Geologic History of Utah, Brigham young
Special Publication 7, 202 pp.
University Geology Studies
Hydro Geo Chem, Inc., May 8, z\Oz,letter report of as-built details for monitoring wells andpiezometers at the IUC White Mesa uranium mill, unpublished consultants report fromStewart J. Smith to Michelle Rehmann, includes May 9, 2002 transmittal letter by DavidC. Frydenlund of International Uranium Corporation to William J. Sinclair,2 pp.
Hydro Geo Chem, Inc., January 30, 2003,"Site Hydrogeology and Estimation of GroundwaterTravel Times in the Perched Zone White Mesa Uranium Mill Site Near Blanding, I]tah,,,unpublished consultants report, l8 pp., 2 tables, 7 figures.
Hydro Geo Chem, Inc., March 25,2004, untitled letter from Stewart Smith to Harold Roberts, 4pp.
Hydro Geo Chem, Inc., October 19,zo14,letter report from Stewart Smith to Harold Roberts onwell specific groundwater average linear velocity, 3 pp., 1 table, 2 figures; includes anOctober 20,z}}4lnternational Uranium (USA) Corporation transmiital letter from DavidC. Frydenlund to Loren Morton, I p.
lnternational Uranium Corporation, March, 1990, "White Mesa Mill's Ground Water eA project
Plan, Rev. 2", unpublished company plan, I7 pp.,includes February 24,l9gg transmittalletter from Michelle R. Rehmann to william J. Sinclair,z pp.
Internati onal urani um corporation, May 2g, lggg, "Groundw ater Informati on
Mesa Uranium Mill Blanding, I]tah", unpublished company report, 113
figures, 8 attachments.
5l
Report White
pp.,12 tables, 15
Statement of Basis DRAFT December 1,2004
International Uranium Corporation, September 30, 1999, "Chloroform Source Assessment
Report", unpublished company report by Michelle Rehmann, 13 pp.,2 figures, and2
appendices.
International Uranium Corporation, August, 2000, "Construction Report Tailings Cell44. White
Mesa Uranium Mill - Tailings Management System", unpublished company report, 13
pp.,2 figures, 12 attachments, 14 photographs.
International Uranium Corporation, September 8, 2000, "Groundwater Information Report
Revision Package", unpublished company report, 31 pp., 11 attachments, includes
September 8, 2000 transmittal letter from David C. Frydenlund to William J. Sinclun,2
pp.
International Uranium Corporation, June 22,200l, "March 20,2001TIDEQ Letter and Request
for Additional Site Hydrogeology Information in Response to IUSA September 8, 2000
Revised Groundwater Information Report; Groundwater Discharge Permit for White
Mesa Mill; Followup to May 11, 2OOllatter from David C. Frydenlund to William J.
Sinclair", unpublished company response, 20 pp.,14 attachments.
International Uranium Corporation, July 17,2007, "Draft Spill Management Plan, Groundwater
Discharge Permit Application for White Mesa Mill", includes three plans: 1) July 17,
2001 Stormwater Best Management Practices Plan,l pp.,4 figures, 1 table, and}
Appendices (Appendix 1: July 17,2001 :Spill Prevention, Control, and Counteffneasures
for Chemicals and Petroleum Products", 14 pp.,6 tables, 2 figures; and Appendix 2:
4pri129,1998 "Emergency Response Plan", l5 pp.,4 exhibits, 2 appendices, I figure, I
table).
International Uranium Corporation, September 7 ,2O0l, "Updated Topographic Map,
Groundwater Discharge Permit Application for White Mesa Mill", unpublished company
letter from Harold R. Roberts to William J. Sinclair, I p., includes map and 4
spreadsheets.
International Uranium Corporation, May 31,2002, "Pond Solution Sampling Workplan White
Mesa Uranium Mill Site Near Blanding, IJtah", unpublished company work plan, 4 pp,
includes May 31, 2002 transmittal letter from Michelle Rehmann to William J. Sinclair, 2
pp.
lnternational Uranium Corporation, September 6,2002, "Transmittal of Brushy Basin Contour
Map, White Mesa Mill Site Utah DEQ Notice of Violation and Groundwater Corrective
Action Order IIDEQ Docket No. UGQ-20-01 of August 23, 1999", transmittal letter (2
pp.) and unpublished company contour map.
lnternational Uranium Corporation, October 15,2002, "'Water Level Map and Resolution of
Increasing Water Levels Observed in MW-4, Utah DEQ Notice of Violation and
Groundwater Corrective Action Order, TIDEQ Docket No. UGQ-20-01 of August 23,
1999", unpublished company submittal, 2 pp.,1 map, 50 pages of water level data.
52
Statement of Basis DRAFT December l,2OO4
International Uranium Corporation, December 2O,2002, "November,2OO2 l,etter from Utah
Department of Environmental Quality to International Uranium Corporation Regarding
November,200l Split Sampling Results for the White Mesa Uranium Mill", unpublished
company response, 4 pp.,2 attachments.
International Uranium Corporation, August 3l,2004, "International Uranium (USA) Corporation
Source Material License No. SUA-1358 White Mesa Mill, Blanding, Utah Semi-Annual
Effluent Monitoring Report for Period January 1,2004 through June 30, 2004",
unpublished company monitoring report, 3 pp., 7 attachments, includes transmittal letter
from Ron Berg to Mr. Dane Finerfrock, 2 pp.
International Uranium Corporation, October 17,2003, "September 16,2003lrtter from the Utah
Department of Environmental Quality, Division of Water Quality to International
Uranium (USA) Corporation", unpublished company response, 3 pp., 2 attachments.
Intemational Uranium Corporation, February 19,2004, "Supporting Information for GWDP",
email correspondence from Harold Roberts to Loren Morton, I p. 3 attachments.
National Library of Medicine,Hazardous Substances Data Bank, part of the Toxnet System,
found on the internet at: http://toxnet.nlm.nih.gov/.
Pankow, J.F. and J.A. Cherry, 1996, Dense Chlorinated Solvents and Other DNAPLs in
Groundwater, Waterloo Press, Portland, Oregon, 522 pp.
Risher, J.F. and S.W. Rhodes, June, 1995, "Toxicological Profile for Fuel Oils", U.S.
Department of Health and Human Services, Public Health Service, Agency for Toxic
Substances and Disease Registry, 231pp.,2 appendices, found on internet at:
www. atsdr.cdc. eov/toxprofi les/tp75-c3.pdf.
Thomas, D. and J.J. Delfino, Fall, 1991, "A Gas Chromatographic / Chemical Indicator
Approach to Assessing Groundwater Contamination by Petroleum Products", Ground
Water Monitoring Review, National Ground Water Association, pp. 90-100.
Titan Environmental Corporation, July, 1994, "Hydrogeologic Evaluation of White Mesa
Uranium Mill", unpublished consultants report, approximately 51 pp., 5 tables, 19
figures, T appendices.
Titan Environmental Corporation, September,1994, "Points of Compliance White Mesa
Uranium Mill", unpublished consultants report, l3 pp., 1 table, 4 figures, 3 appendices.
Umetco Minerals Corporation, April 10, 1989, "Cell 4 Design", unpublished company report,
includes: 1) April 10, 1989 letter from Curtis O. Sealy to Edward F. Hawkins, I pp., with
60 pp. of technical response materials, and2) August, 1988 Umetco Minerals
Corporation "Cell4 Design Tailings Management System", unpublished company report,
17 pp.,2 attachments, and 2 appendices.
Umetco Minerals Corporation and Peel Environmental Services, January, 1993, "Groundwater
Study White Mesa Facility Blanding, IJtah", unpublished company and consultants
report, approximately 54 pp., 5 appendices.
53
Statement of Basis DRAFT o December 1,2004
Umetco Minerals Corporation, June, l994,"Groundwater Study l994Update White Mesa
Facility Blanding, IJtah", unpublished company report, 5l pp., 6 appendices.
United States Code of Federal Regulations, Title 10, Chapter 1 - Energy, "Domestic Licensing
of Source Material", Part 40 (10 CFR 40), Appendix A "Criteria Relating to the
Operation of Uranium Mills and the Disposition of Tailings or Wastes Produced by the
Extraction or Concentration of Source Material From Ores Processed Primarily for Their
Source Material Content", available on the internet at: http://www.nrc.gov/reading-
rmldoc -coi lecti on s/cfr/.
United States Court of Appeals, District of Columbia Circuit, February 25,2003, Docket Nos.
0l-1028, 01-1033, 01-1034, and 0l-1037, City of Waukesha; Village of Sussex Water
Commission; Radiation, Science & Health; Nuclear Energy Institute, Inc.; and the
National Mining Association versus Environmental Protection Agency,49 pp., available
on the Internet at: http://www.epa.gov/newsr:oom/headline 022603.htm, and at
http://pacer.cadc.uscourts.gov/docs/common/opinions/200302/01-l028a.pdf
United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document, Office of Solid Waste and
Emergency Response, OSWER-9950.1, 208 pp., 3 appendices.
United States Environmental Protection Agency, February, 1989, "Statistical Analysis of
Ground-Water Monitoring Data at RCRA Facilities, Interim Final Guidance", Office of
Solid Waste, approximately 146 pp.
United States Environmental Protection Agency, January, 1995, "Technical Resource Document
Extraction and Beneficiation of Ores and Minerals Volume 5 Uranium", EPA 530-R-94-
O32, 7 4 pp., 3 appendices.
United States Environmental Protection Agency, Region 8, August 24,1999, "Toxicity of
Tetrahydrofuran", unpublished agency memo from Robert Benson, Ph.D. to Loren
Morton, Utah DEQ, I p.,2 attachments.
United States Environmental Protection Agency, January 4,2000, technical correspondence
letter from Mr. Robert Benson, EPA Region 8 drinking water program toxicologist to Loren
Morton, Utah Division of Radiation Control, 2 pp.
United States Environmental Protection Agency, Summer,2002 "Drinking Water Standards and
Health Advisories", EPA 822-R-02-038,12 pp., available on the Internet at
http : //www. epa. oov/waterscience/drinkinq/standards/dwstandards. pdf.
United States Environmental Protection Agency, Region 8, May 29,2003, "Lifetime Health
Advisory and Cancer Risk for Chloroform", unpublished agency memorandum from
Robert Benson, Ph.D. to Loren Morton, Utah DEQ, 2 pp.
United States Nuclear Regulatory Commission, May, 1979,"Final Environmental Statement
Related to Operation of White Mesa Uranium Project Energy Fuels Nuclear, Inc., Docket
54
Statement of Basis DRAFT December 1,2004
No. 40-8681", NUREG-0556, Office of Nuclear Material Safety and Safeguards,
approximately 290 pp.
United States Nuclear Regulatory Commission, September, 1980, "Final Generic Environmental
Impact Statement on Uranium Milling Project M-25, Appendices G-V", NUREG-0706,
Vol. I[, Office of Nuclear Material Safety and Safeguards, approximately 238 pp.
United States Nuclear Regulatory Commission, September 23,2002, "Source Material License
No. SUA-1358, Docket No. 040-8681, Amendment No. 22", agency license to
International Uranium Corporation for Uranium Mill at White Mesa, Utah, 11 pp.
United States Nuclear Regulatory Commission, March 7,2003, "Response to Questions in
January 14,2003 Letter from William Sinclair", agency response letter from Paul H.
Lohaus to William J. Sinclair, 3 pp.
Utah Department of Environmental Quality, July 18,1996, "Information Needs Summary for
Atlas Corporation Moab Uranium Mill Ground Water Contaminant Investigation Report
and Ground Water Corrective Action Plan, as found in the Utah Ground Water Quality
Protection Regulations (UAC R317-6-6.15)",24 pp., found as an attachment to a
September 12,1996 Utah Division of Radiation Control letter from William J. Sinclair
and Don A. Ostler to Richard E. Blubaugh, 6 pp.
Utah Division of Radiation Control, February 7, 2000, "Ma], 1999 ruC Groundwater
Information Report: DRC Request for Additional Information Related to Site
Hydrogeology", unpublished agency request, 2 pp. transmittal letter, includes Utah
Division of Radiation Control technical information request of February 7, 2OO0
"Request for Additional Information Related to Site Hydrogeology", 18 pp., 2
attachments.
Utah Division of Radiation Control, June2l,2000, "International Uranium Corporation White
Mesa Uranium Tailings Facility: Engineering Design and As-Built Reports; Staff
Findings, Conclusions, and Recommendations", unpublished agency technical
memorandum, 29 pp., 5 attachments.
Utah Division of Radiation Control, March 20,200l, "September 8, 2000IUC Revised
Groundwater Information Report: Ground Water Discharge Permit Application for White
Mesa Mill: Request for Additional Site Hydrogeology Information", unpublished agency
requost for information, 10 pp., 3 attachments.
Utah Division of Radiation Control, June 7, 200l, "October 4,2000IUC and HGC Investigation
of Elevated Chloroform Concentrations in Perched Groundwater at the White Mesa
Uranium Mill Near Blanding, Utah: August 23, L999 Utah Division of Water Quality
Notice of Violation and Groundwater Corrective Action Order; Docket No. UGW20-01:
Request for Additional Information.", unpublished agency information request, 12 pp., 8
attachments.
Utah Division of Radiation Control, October 26,20Ol, "September2l,2OOl NRC Draft
Environmental Assessment Regarding Maywood New Jersey FUSRAP Site: IUC White
55
Statement of Basis DRAFT December 1,2004
Mesa Uranium Mill Near Blanding, IJtah", unpublished agency comment letter from
William J. Sinclair to Melvyn Leach, U.S. NRC, 5 pp.
Utah Division of Radiation Control, November 15,2001, "Recent Meetings and Conference Call
with International Uranium Corporation Regarding Hydrogeologic Conditions at White
Mesa Mill, October 4, 18, and24,2001", unpublished agency technical memorandum, 16
pp.,3 attachments.
Utah Division of Radiation Control, April 1 I , 2002, "November 9, 2001 IUC Update Report on
Ongoing Chloroform Investigation at White Mesa Uranium Mill; August23,1999
Division of Water Quality Notice of Violation and Groundwater Corrective Action Order,
Docket No. UGW20-01: Request for Additional Information", unpublished agency
information request, 18 pp., 5 attachments.
Utah Division of Radiation Control, July 3, 2002, "IIJC: 5l3ll02 Tailings Pond Wastewater
Sampling Workplan - DRC Comments", unpublished agency comments, email
transmittal from Loren Morton to Harold Roberts, 2 pp.
Utah Division of Radiation Control, November 22,2002, "November, 2001 Groundwater Split
Sampling Event at IUC White Mesa Uranium Mill Near Blanding, Utah: Utah DEQ
Request for Additional Information", unpublished agency information request, 4 pp.,7
attachments.
Utah Division of Radiation Control, April 30, 2003, "November,200l Split Sampling Event at
IUC White Mesa Uranium Mill: DRC Staff Review and Conclusions", unpublished
agency memorandum report, 44 pp.,7 tables, 29 attachments.
Utah Division of Radiation Control, September 16,2003, "December 20,2002IUC Response
Regarding Recent Detection of Tetrahydrofuran Concentrations in Groundwater at the
White Mesa Uranium Mill: Request for Work Plan", unpublished agency information
request, 3 pp.,2 attachments.
Utah Division of Radiation Control, November 12,2003, "October 17,2003IUC Response to
September 16,2003 DRC Request for Work Plan; TIIF Contamination of Several
Monitoring Wells at White Mesa Uranium Mill: Request for Work Plan", 5 pp, 5
attachments.
Utah Division of Radiation Control, November 26,2003, "fUC: Groundwater Protection Level
Statistics and Accelerated Monitoring Frequency", email correspondence from Loren
Morton to David Frydenlund,2pp.
Utah Division of Radiation Control, September 21, 2004, "Review of IUC Report - 'Site
Hydrogeology and Estimation of Groundwater Travel Times in the Perched Zone White
Mesa Uranium Mill Site Near Blanding,IJtah', January 30,2003 by Hydro Geo Chem,
Inc.", unpublished agency technical memorandum,6 pp.,4 figures, T tables.
Utah Division of Radiation Control, November 23,2004, "Review of Hydro Geo Chem Inc
Report - Report on Perched ZoneWater Movement, White Mesa Uranium Mill Site Near
56
Statement of Basis DRAFT December 1,2004
Blanding, Utah, October 20,2004", unpublished agency technical memorandum,4 pp.,2
tables, 5 figures.
Utah Division of Water Quality, August 8,1994, "Basis for Revised Ground Water Protection
Levels: New Parameters and Revised Shallow Ground Water Quality Statistics",
unpublished staff report, 39 pp., 23 attachments.
Utah Division of Water Quality, August 23, 1999, "Notice of Violation and Groundwater
Corrective Action Order; Docket No. UGW20-01: Request for Additional Information.",
unpublished agency order and information request,12 pp., 8 attachments.
Utah Division of Water Quality, June 12, 2OO3, "Chloroform Standard for White Mesa Mill
Corrective Action", unpublished agency memorandum from Don Ostler to Bill Sinclair, I
p-
Utah Division of Water Quality, September L6,2003, "December 2O,2OO2IUC Response
Regarding Recent Detection of Tetrahydrofuran Concentrations in Groundwater at the
White Mesa Uranium Mill: Request for Work Plan", unpublished agency information
request from William J. Sinclair to Harold Roberts, 3 pp., 2 attachments.
Ute Mountain Ute Tribe, July l, 2003, "White Mesa Seep Sampling", unpublished tribal email
from Scott Clow to Loren Morton,2 pp.
57
DRAFT
ATTACHMENT 1
Utah Division of Radiation Control
Water Table Contour Maps
For the September, 2002 Split Sampling Event
At the IUC White Mesa Uranium Mill
Near Blanding Utah.
DRC Surfer Maps: 9-02h.srf, 9-02h_b.srf, and 9-02h_c.srf,
and DRC spreadsheet GWHEADJ(LS, tabsheet 9-02
DRAFT
ATTACHMENT 2
Utah Division of Radiation Control
Summary of Shallow Aquifer TDS Concentrations
At the IUC White Mesa Uranium Mill
Near Blanding Utah.
DRC Spreadsheet GWclass.xls, tabsheets Sum, HistSum, and HistSumELI
I}RAFT
ATTACHMENT 3
Utah Division of Radiation Control
Summary of IUC Wells and Parameters
That Exceed their Respective GWQS
At the IUC White Mesa Uranium Mill
Near Blanding Utah.
(based on DRC/IUC split sampling results)
DRC spreadsheet GWclass.xls, tabsheet Exceed
DRAFT
ATTACHMENT 4
Utah Division of Radiation Control
Time Series Concentration Graphs of
Natural Uranium Contamination in
IUC White Mesa Mill
Groundwater Monitoring Wells
MW-14, MW-15, and MW-17
From August 3L,2W4IUC Semi-Annual Effluent Monitoring Report,
Groundwater Statistical Analysis by Shewhart-Cusum Method June 30, 2004 Section
DRAFT
ATTACHMENT 5
Utah Division of Radiation Control
Shallow Aquifer Uranium 238 Isoconcentration Map
For the September,z0Dz Groundwater Split Sampling Event at the
IUC White Mesa Uranium Mill Facility
Near Blanding, Utah
DRC Surfer Contour Maps: U238-9-02.srf and U238-9-02b.srf
DRC Excel spreadsheet U-238.x1s, tabsheet 9-02
T}RAFT
ATTACHMENT 6
Utah Division of Radiation Control
Summary of IUC Tailings Cells
Historic Wastewater Quality Data
From the White Mesa Uranium Mill
Near Blanding Utah.
DRC spreadsheet TailsWQ.xls, tabsheet NewSum
T}RAFT
ATTACHMENT 7
Utah Division of Radiation Conhol
Summary of Literature Values for
Soil-Water Partitioning (I(6) Coefficients for Metals
DRC spreadsheet 1 lE2KdSum.xls
Tabsheet: Metals
DRAFT
ATTACHMENT 8
Utah Division of Radiation Control
Summary of Literature Values for
Organic Carbon Panitioning Coefficients (K*)
Soil-Water Partitioning (I(6) Coefficients for Organics
DRC spreadsheet I lE2KdSum.xls
Tabsheet: Org-Koc
I}RAFT
ATTACHMENT 9
Utatr Division of Radiation Control
Summary of Detectable Organic Contaminants
Found in Utah DRC Split Groundwater Samples
Colleted from the IUC White Mesa Uranium Mill Site
From May, 1999 thru September,2D2
DRC spreadsheet Splitsum.xls
Tabsheet: Organics
DRAFT
ATTACHMENT 10
Utah Division of Radiation Control
Summary of Groundwater Quality
Split Sampling Results
For Selected Volatile Organic Contaminants
From the IUC White Mesa Uranium Mill,
May, 1999 thru September, 2ffi2
DRC spreadsheets: Benzene.xls, CTC.xls, and THF.xls
Tabsheets: HistSum
DRAFT
ATTACHMENT 11
International Uranium CUSA) Corporation
April 16,2004
Proposed Groundwater Monitoring Well Iocation Map
Received bY the
Utah Division of Radiation Control
On April 20,2004.
DRAFT
ATTACHMENT 12
Utah Division of Radiation Control
Groundwater VelocitY Contour MaP
(based on IUC velocitY data)
From November 23,2@4
Utah Division of Radiation Control
Memorandum, Figure 2
and
DRC Spreadsheet: flow velocity2.xls
DRAFT
IUC White Mesa Mill
Flow VelocitY Contour MaP
November 2004
lnterpolation Method: Krlging (omnl-directional)
2,574,0m 2,575,000 2,t6'000 2,577,W 2'576'0(x) 2'57c'wu
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Figure 2
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