DRC-2025-001744

May 29, 2025
MEMORANDUM TO: Docket File WM-00068
THRU: Jeffrey E. Josey, Chief
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
FROM: Linda M. Gersey, Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
SUBJECT: NRC OBSERVATIONAL SITE VISIT AT THE GREEN RIVER DISPOSAL
SITE, UTAH
On May 7, 2025, a U.S. Nuclear Regulatory Commission (NRC) inspector conducted an
observational site visit at the U.S. Department of Energy’s (DOE) Green River Disposal site in
Emery and Grand Counties, Utah. This observational site visit was conducted in accordance
with the guidance provided in NRC Inspection Procedure 89060, “Department of Energy
Observational Site Visits.” The purpose of the site visit was to observe DOE’s routine annual
inspection at the Green River Disposal site. Enclosed to this memorandum is the NRC’s trip
report for this observational site visit.
In summary, DOE representatives conducted the annual inspection in accordance with the
instructions provided in DOE’s site-specific Long Term Surveillance Plan dated July 1998 for
the Grenn River Disposal Site and any deviances were documented appropriately. No
significant regulatory issues or safety concerns were identified during the site visit.
Docket No. WM-00068
License No. General license pursuant to 10 CFR 40.27
Enclosure:
NRC Trip Report
cc w/Enclosure:
H. Katz, DOE Site Manager
A. Wingate, State of Utah
CONTACT: Linda M. Gersey, DRSS/DIOR
817-200-1299
Signed by Josey, Jeffrey
on 05/29/25
Signed by Gersey, Linda
on 05/29/25
NRC OBSERVATIONAL SITE VISIT AT THE GREEN RIVER DISPOSAL SITE, UTAH, -
DATED MAY 29, 2025
DISTRIBUTION:
JMonninger, ORA
TBloomer, DRSS
NO’Keefe, DRSS
TLancaster, NMSS/DUWP/URMDB
BVonTill, NMSS/DUWP/URMDB
R4-DRSS-DIOR-DECOM
[e-mail]
[e-mail]
DOCUMENT NAME: NRC OBSERVATIONAL SITE VISIT AT THE GREEN RIVER DISPOSAL SITE, UTAH
ADAMS ACCESSION NUMBER: ML25142A403
 SUNSI Review
By: LMG
ADAMS:
 Yes ￿ No
￿ Sensitive
 Non-Sensitive
￿ Non-Publicly Available
 Publicly Available
Keyword
NRC-002
OFFICE HP:DRSS/DIOR SHP:DRSS/DIOR BC:DRSS/DIOR
NAME LGersey SAnderson JJosey
SIGNATURE /RA//RA//RA/
DATE 05/22/25 05/27/25 05/29/25
OFFICIAL RECORD COPY
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No. WM-00068
License No. General license pursuant to 10 CFR 40.27
Report No. WM-00068/2025-001
Licensee: U.S. Department of Energy
Facility: Green River Disposal Site
Location: Emery and Grand Counties, Utah
Date: May 7, 2025
Inspector: Linda M. Gersey, Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Approved By: Jeffrey E. Josey, Chief
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Attachment: Photographs taken at the Green River Disposal Site
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NRC Trip Report
1 Background
The Green River disposal site is located approximately 0.5 miles east of the Green River
and 1.5 miles southeast of the city of Green River, Utah. The site consists of an
engineered disposal cell and surrounding property where a former uranium mill and
tailings pile were previously located.
Union Carbide Corporation constructed the uranium mill in 1957 and operated the facility
from March 1958 through January 1961. The mill operated as an upgrading facility for
uranium ore. During its three years of operation, the mill processed 183,000 tons of ore
and generated an estimated 114,000 cubic yards of radioactive tailings, a predominantly
sandy material that covered about 9 acres to an average depth of 7 feet. Union Carbide
owned the mill site property until the State of Utah acquired ownership in 1988.
The processing site was remediated by the U.S. Department of Energy (DOE) from
November 1988 through September 1989, and all mill tailings and other contaminated
materials were stabilized in an onsite disposal cell. The cell also received contaminated
material from 17 vicinity properties. The area of the former tailings pile and all areas
disturbed at the site during remedial action were backfilled, graded to promote surface
drainage, and re-vegetated. The former processing site area has no current use. Several
of the mill buildings were cleaned up and remain on the site. These buildings are
abandoned and in disrepair. The DOE currently owns the disposal site, and the State of
Utah owns the rest of the adjacent former processing site property.
The Green River disposal site is classified as a Title I site under the Uranium Mill
Tailings Radiation Control Act of 1978. The DOE maintains long-term custody of the site
under the U.S. Nuclear Regulatory Commission’s (NRC’s) general license requirements
specified in 10 CFR 40.27. The Long-Term Surveillance Plan (LTSP) explains how DOE
will fulfill the general license requirements specified in 10 CFR 40.27. The current LTSP
is dated July 1998 (Agencywide Documents Access and Management System [ADAMS]
Accession No. ML17128A460). By letter dated August 20, 1998, the NRC accepted the
LTSP (ML032870067).
2 Site Status
The previous DOE annual inspection occurred on April 30, 2024 (at the time of the site
accompaniment, the report was not available in ADAMS). No changes were observed on
the disposal cell or associated drainage features. DOE inspectors identified several
minor maintenance issues that needed attention, such as replacement of faded
perimeter signs and removal of vegetation along the fence line. The 2024 DOE
compliance report states that these minor maintenance issues would be corrected
before the next inspection.
During late 2023 and early 2024, A1 Lithium/Blackston Minerals acquired land adjacent
to the disposal cell with the intent to extract lithium from between 6,000-10,000 feet
below ground surface and process it on their property as part of a pilot processing plant.
In March 2024, while drilling their exploration well, the company hit a high-pressure layer
which caused water to flow upward to the surface. The State of Utah and DOE were
contacted about the incident. The DOE provided the NRC inspector with a curtesy copy
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of the State of Utah’s November 25, 2024, memorandum to file which outlines their
investigation and findings of this incident. The State of Utah found that the incident was
caused by improper casing of the well and it was likely that contamination from past
uranium milling activities was transported to the surface. The water flowed from the well
water containment area to three former Department of Defense wastewater lagoons, but
did not reach a surface water body. The millions of gallons of water that reached the
surface likely dissolved any near surface uranium contamination and would be diluted to
a level that is not distinguishable from background. The State of Utah also concluded
that the well water that reached the former lagoons seeped into the contaminated near-
surface aquifer, and it is likely that the groundwater concentrations and flow pathways
will change from those previously established. At the time of the NRC site
accompaniment, the extent of the impact on groundwater contamination was not known
and whether it would contribute to the two groundwater plumes resulting from the tailings
cell.
The DOE stated that for future adjacent lithium extraction and site protection, more
robust institutional controls (ICs) are being assessed as part of the draft Groundwater
Compliance Action Plan (GCAP). One of the current IC’s is an Area of Concern which
limits completing wells in the aquifers from 0 to approximately 150 ft within the area of
the disposal cell. There was a quit claim deed on the A1 Lithium/Blackstone Minerals
property that limits use of groundwater but does not limit mining activities and thus the
DOE could not stop the company from drilling in the contaminated upper aquifer. If the
mining company constructs wells properly, there should be no concern of releasing the
residual groundwater contamination due to the depth of the mining operation and closed
aquifer systems. The company has not proceeded with drilling their production wells due
to lawsuits regarding the State issuance of water rights. The DOE stated they will remain
in contact with the State of Utah and the company for awareness of future activities.
The 1998 LTSP describes the post-closure groundwater monitoring in the uppermost
aquifer downgradient from the disposal cell. Four point-of-compliance (POC) monitoring
wells (0171, 0173, 0181, and 0813) were evaluated for concentrations of nitrate,
uranium, and sulfate, and were monitored for water levels. In 2024, concentrations of
routinely monitored analytes exceeded corresponding concentration limits in several
POC wells: nitrate in wells 0171 and 0173; sulfate in all wells except well 0813; and
uranium in well 0171. Based on data collected since 1998, trend analysis indicates
statistically significant increasing trends for several well-parameter combinations: sulfate
in wells 0173 and 0181 and uranium in wells 0171, 0173, and 0813.
Due to the exceedance of concentration limits in the four POC wells, the DOE has been
working on a compliance strategy in a revised GCAP. The DOE has installed an
additional 18 monitoring wells to determine the extent of the contamination and monitors
them annually in addition to the 4 POC wells. During 2011, the DOE submitted a revised
GCAP to the NRC that included these additional 18 monitoring wells. The NRC had
questions on the revised GCAP related to enforceable ICs of privately owned land down
gradient of the Green River site. The DOE’s ability to ensure public health and safety if
the landowner decided to drill a well is in question. The DOE recognized the need to
update the 2011 GCAP to address the NRC’s concerns and anticipates submittal to the
NRC in fiscal year 2029.
The NRC inspector noted that the 1998 LTSP had language that was out of date. For
example, the LTSP states that the DOE will assign a chief inspector that is a
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geotechnical engineer, a civil engineer, or an engineering geologist knowledgeable in
processes that could adversely affect the site; although in practice, the DOE assigns
inspectors who have the knowledge and training to assess site conditions. The DOE
stated that they document differences in actions stated in the LTSP and what is actually
done. The DOE also stated that they plan to update the LTSP at a future date and
incorporate these changes. Since none of the differences between the LTSP and the
actual actions are safety-significant, did not impact the integrity of the cell, and were
documented, the NRC inspector found this to be acceptable.
3 Site Observations and Findings (IP 89060)
Observation of Site Activities (Risk Module RM-01) and Public Doses, Effluent Release,
and Environmental Monitoring (Risk Module RM-02)
The NRC inspector accompanied the DOE and their contractors during the annual
inspection at the Green River Disposal Site on May 7, 2025. The DOE used an
inspection checklist which included issues from the previous inspection and actions to be
taken for any follow-up. The checklist also included the actions from the LTSP necessary
to verify the integrity of the disposal cell and to determine that public health and safety
were being maintained. The DOE began the inspection with a safety briefing on the site
status and site hazards, such as walking on unstable rock and the possibility of snakes
in the area. Two teams were formed to walk in separate directions around the site to
ensure visual coverage of the entire area.
The NRC inspector walked half of the total boundary with one of the DOE teams and
observed perimeter signs, the entrance sign on the main gate, a site marker, boundary
monuments, survey monuments, monitoring well heads, and quality control monuments.
Several perimeter signs needed to be replaced due to damage or fading and the
entrance sign needed to include the contact for the State of Utah. The DOE committed
to completing these actions before the next annual inspection. The NRC inspector
observed the erosion around the old water tower, which is located directly adjacent to
the DOE site boundary. The water tower is on state land and has been abandoned and
is in a derelict state. The DOE stated that they continue to monitor the erosion and if it
appears that the erosion could cause the water tower to fall, they will contact the State to
mitigate it.
The NRC inspector walked around the fence enclosing the tailings cell with the DOE
team. It was noted by the NRC inspector that the road near the east vehicle gate was
being used by A1 Lithium Blackstone/Minerals. Although the east gate is not required to
be posted, per the LTSP, the DOE stated they would consider posting it the same as the
main vehicle gate due to the increase in traffic. The DOE also noted that the weeds were
continuing to grow in the perimeter fence, and it was time to have them removed before
the fence lost its integrity. They committed to having all the weeds along the fence line
removed before the next inspection. The DOE also noted that weeds had been growing
between the disposal cell and the perimeter fence. The DOE stated that they would have
these removed at the same time the fence was being cleared of weeds.
The NRC inspector walked along the inside boundary of the disposal cell and over the
top to observe the integrity of the cell. The DOE noted the erosion on the north and
south apron of the cell had gotten worse since the last inspection. The DOE had brought
an engineer to the site to look at the erosion. The engineer stated that both areas
5
needed grading, filling, compacting, and wattles added to slow down the erosion from
rainwater. The DOE stated they would be discussing this with management to determine
when this work could be completed. The NRC inspector walked over the cell and
observed the site marker. The cell and site marker looked in excellent condition.
During the walkover of the disposal cell and perimeter of the site, the NRC inspector
took exposure readings using a RadEye G Survey Meter, Serial Number 31126. The
exposure readings were all at background levels and found to be 16-20 microRoentgen
per hour.
During the May 7, 2025, site accompaniment, the NRC inspector noted that the majority
of the maintenance issues had not been completed since the 2024 DOE inspection. The
DOE site manager and the DOE contractor were not able to provide reasons for not
completing the maintenance in a timely manner. The NRC inspector noted that failure to
complete the maintenance was not safety-significant since it did not impact the integrity
of the cell, although maintaining the perimeter signs and keeping the fence surrounding
the cell in good condition is important because of the increase in public interest adjacent
to the site. The DOE site manager and DOE contractors committed to ensuring that all
maintenance issues will be addressed prior to the 2025 annual inspection.
All markers, signs, monuments, fence line, and erosion areas were photographed by the
DOE, and all items that needed follow up before the next inspection were documented.
4 Conclusions
The DOE’s contractors conducted the annual inspection in accordance with the LTSP
and any deviances were documented appropriately. No significant regulatory issues or
safety concerns were identified during the site visit.
5 Meeting Summary
The inspector participated in a safety meeting with the DOE and its contractors prior to
the site visit. During this meeting, the participants discussed topics such as site status,
potential site hazards, hydration, and hot weather risks.
A final exit briefing was held with DOE at the end of the onsite accompaniment on
May 7, 2025.
6 Persons Contacted
H. Katz, DOE-LM Site Manager
M. Young, DOE-LM Site Manager
D. Atkinson, RSI-LMS Site Lead
J. Graham, RSI-LMS Site Lead
J. Manee, RSI-LMS Engineer
Attachment
Figure 1: Green River Disposal Site Marker on Top of Cell
Figure 2: Green River Disposal Site Perimeter Sign
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Figure 3: Green River Disposal Site SW Corner Apron Erosion
Figure 4: Green River Disposal Site NE Side slope