DRC-2011-007747 - 0901a0688029acfe

DEC 2011
Division fif
Watio!! Control
December 15, 2011
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: Application by Denison Mines (USA) Corp. ("Denison") for an amendment to State of Utah
Radioactive Materials License No. 1900479 for the White Mesa Uranium Mill (the "Mill") to authorize
processing of Sequoyah Fuels Corporation, Inc. ("SFC") alternate feed material (the "Uranium
Material")
Dear Mr. Lundberg:
We are pleased to enclose with this letter two copies of an application to amend the Mill's Radioactive Materials
License No. 1900479 to authorize receipt and processing of the Uranium Material as an alternate feed material
primarily for the recovery of uranium and disposal of the resulting tailings in the Mill's tailings impoundments as
lie.(2) byproduct material.
The Uranium Material must be removed from the SFC, Inc. facility under a schedule established by the United
States Nuclear Regulatory Commission pursuant to the facility's Site Decommissioning Plan. Please contact us
as to the anticipated timeframe required for DRC to review this application.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
'^^o Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Katherine A. Weinel
OENISOJ)JJ
MINES
December 15, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: Application by Denison Mines (USA) Corp. ("Denison") for an amendment to State of Utah
Radioactive Materials License No. 1900479 for the White Mesa Uranium Mill (the "Mill") to authorize
processing of Sequoyah Fuels Corporation, Inc. ("SFC") alternate feed material (the "Uranium
Material")
Dear Mr. Lundberg:
We are pleased to enclose with this letter two copies of an application to amend the Mill's Radioactive Materials
License No. 1900479 to authorize receipt and processing of the Uranium Material as an alternate feed material
primarily for the recovery of uranium and disposal of the resulting tailings in the Mill's tailings impoundments as
11 e.(2) byproduct material. .
The Uranium Material must be removed from the SFC, Inc. facility under a schedule established by the United
States Nuclear Regulatory Commission pursuant to the facility's Site Decommissioning Plan. Please contact us
as to the anticipated timeframe required for DRC to review this application.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
~~
r. Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Katherine A. Weinel
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
3. ANALYTICAL RESULTS FOR TOXICITY CHARACTERISTICS.
(Please transcribe results on the blank spaces provided. Attach additional sheets ifneeded, indicate range or worst-case results).
See Attachment 01, tables 1 and 2
Metals (circle one): Total (mg/kg) or TCLP (mg/l) Organics (circle one):Total (mg/kg) or TCLP (mg/I)
Lead
Barium
Mercury
Cadmium
Zinc
Chromium
Copper
ND -Analyte not detected
4. ANALYTICAL RESULTS FOR REQUIRED PARAMETERS:
(Please transcribe results on the blank spaces provided. Attached additional sheets if needed).
SoilpH~ Paint Filter No Free Liquid Pass
Liquids Test (PasslFail)
5. IGNITABILITY (40 CFR 261.21 [a][2].[4].)
Cyanide nla Not detected
Released mg/kg
Sulfide nla
Released
Flash Point not applicable Op °c Is the material a RCRA oxidizer? Y ~
5. CHEMICAL COMPOSITION
Not detected
mg/kg
(List all known chemical components and circle the applicable concentration dimensions. Use attachments to complete, if necessary.)
See Attachment 01, tables 1 and 2
Chemical Component Concentration
___ %mglkg
___ %mg/kg
___ %mg/kg
Chemical Component Concentration
_____________ %mg/kg
_____________ %mg/kg
_____________ %mg/kg
Halogenated Organic Compounds (HOC) (Sum of the list ofHOCs) mg/kg
E. REQUIRED CHEMICAL LABORATORY ANALYSIS. Generator must submit results of analyses of samples of the material. Results are
required from a qualified laboratory for the following analytical parameters unless nonapplicability of the analysis for the material can be stated
and justified in attached statements. Attach all analytical results and QAlQC documentation available. (CAUTION: PRIOR TO ARRANGING
FOR LABORATORY ANALYSIS, CHECK WITH DENISON AND LABORATORY REGARDING UTAH LABORATORY
CERTIFICATIONS.)
FOR ALL MATERIAL TYPES: CHEMICAL ANALYSIS: Soil pH (9045), Paint Filter Liquids Test (9095), Reactivity (cyanide and sulfide).
1. MINIMUM ADDITIONAL ANALYTICAL REQUIRED FOR:
a. Non-RCRA Waste (Non Mixed Waste e.g., LLRW, NORM): TCLP including the 32 organics, 8 metals, and copper (Cu) and zinc
(Zn).
2. REQUIRED RADIOLOGICAL ANALYSES. Please obtain sufficient samples to adequately determine a range and weighted average of
activity in the material. Have a sufficient number of samples analyzed by gamma spectral analysis for all natural isotopes such that they
support the range and weighted average information for the material that will be recorded in item D.I. If Uranium, Thorium, or other non-
gamma emitting nuclides are present in the material, have at least (1) sample evaluated by radiochemistry to determine the concentration of
these additional contaminants in the material.
See Attachment 01civ.
Generator or Contractor Initials: ~
Page 3 of4
sfc rmpr sequoyah fuels dewatered sludge. doc February 2010
RADIOACTIVE MATERIAL PROFILE RECORD
Sequoyab Fuels Corporation
dewatered raffinate sludge
February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
a. The process by which the material was generated.
Sequoyah Fuels Corporation chemically converted uranium ore concentrates to uranium
hexafluoride. This process included two primary purification steps: digestion followed by
solvent extraction. Digestion occurred by dissolving the uranium in nitric acid. The resulting
slurry was subjected to solvent extraction using tributyl phosphate diluted with n-hexane.
Process conditions were controlled to extract uranium into the organic phase. The milling
impurities remain in the aqueous phase, a dilute nitric acid mixture termed raffinate.
The aqueous raffinate stream is primarily a solution of nitric acid, metallic salts, and trace
quantities of uranium and radioactive transformation products of natural uranium, primarily
Th-230 and Ra-226. The aqueous raffinate stream was combined with spent sodium
hydroxide from nitrous oxide scrubber systems and waste sodium carbonate solutions. The
untreated raffinate stream from solvent extraction was pumped to an impoundment and
allowed to cool. Anhydrous ammonia was added to the raffinate solution to convert the dilute
nitric acid to ammonium nitrate. The addition of the anhydrous ammonia also increased the
pH of the raffinate solution causing the metallic salts and trace quantities of uranium, thorium,
and radium to precipitate and settle out in the impoundments as raffinate sludge. The treated
raffinate solution was decanted to another impoundment for further treatment with barium
chloride to remove trace levels of radium through co-precipitation. This precipitate was
periodically combined with the raffinate sludge in the other impoundments.
The raffinate sludge was transferred by slurry to other storage ponds as necessary. The final
treated raffinate solution was stored in surface impoundments prior to use as an ammonium
nitrate fertilizer.
b. Available process knowledge of the material.
The raffinate sludge was accumulated and stored in several impoundments on site, including
Clarifier A basins and Pond 4. No other materials were combined with the stored sludge.
The raffinate sludge was eventually consolidated to Clarifier A basins to support
decommissioning Pond 4 and dewatering of the raffinate sludge.
The raffinate sludge was slurried from Clarifier A basins and processed through a 225 psi
filter press to remove entrained water. The dewatered sludge was placed in one cubic yard
polypropylene bags. The bags are stored on site.
Page 1 of5
sfc rmpr dewatered sludge d1.doc February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
"I,
Parametee Raw Raw SludgeiJ/~, Dewatered
Sludgeb LeachateC
;;;: Sludged
";iiO'
Ag , 476 J,!g/g ! 0.011 mg/l "'~ <90.8 mg/kg i
Al f 3 J,!g/g ! 461 mg/l ; 160000 mg/kg !
As 65650 J,!g/g 0.177 mg/l 3030 mg/kg
Ba 26000 J,!g/g 0.129 mg/l 4150 mg/kg
Be 2 J,!g/g I 0.018 mg/l j 18.7 mg/kg I
Ca I 30000 J,!g/g I 5.48 mg/l 114000 mg/kg I
Cd , 11 J,!g/g 1 0.042 mg/l, <267 mg/kg I
Co 28 J,!g/g 0.541 mg/l k,; 133 mg/kg
Cr 217 J,!g/g 0.129 mg/l i/, 605 mg/kg (
Cu 561 J,!g/g 11.2 mg/l 'I') 2360 mg/kg
Fe 50700 J,!g/g 0.149 mg/l 164000 mg/kg
Hg No analysis No analysis 1.41 mg/kg
K 2785 J,!g/g 9.98 mg/l 7740 mg/kg
Li , 31 J,!g/g ! 1.06 mg/l I; <2.67 mg/kg I
Mg I 3015 J,!g/g I 55.9 mg/l ;; 7190 mg/kg I
Mn I 621 J,!g/g I 23.9 mg/li 1930 mg/kg i
Mo i 5145 J,!g/g I 2.44 mg/l ::; 10700 mg/kg i
Na 8565 J,!g/g 523 mg/l :,) 7480 mg/kg
Ni 473 J,!g/g 10.3 mg/l 1660 mg/kg
p 5531lg/g 11.5 mg/l ,i, 19600 mg/kg
Pb 411 J,!g/g 0.449 mg/I:1 1010 mg/kg
Sb 36 J,!g/g <0.06 mg/l ';;; 78.4 mg/kg
Se <16 J,!g/g 0.214 mg/l 'I,'; 348 mg/kg
Sr 644 J,!g/g ! 4.83 mg/l ~x 1210 mg/kg I
TI I 32 J,!g/g i 0.258 mg/l 5860 mg/kg i
V 3305 J,!g/g ! 0.374 mg/l <1.60 mg/kg I
Zn 297 J,!g/g 6.94 mg/l';; <751 mg/kg
F 23118 J,!g/g No analysis i;;i\ No analysis
N03(N) 42400 J,!g/g No analysis [ii:; No analysis
NH3(N) No analysis No analysis I~ No analysis
V-total 7050 J,!g/g I No analysis 19400 J,!g/g
Th-230 No result No analysis 16200 pCilg
Ra-226 ; 189 pCilg I No analysis 219 pCilg I
a Metals by EPA Method 6010
Dewatered' ~ Dewatering Sludge Filtratee
Leachatef rY
<0.007 mg/l ! <0.320 mg/l;;
10.3 mg/l ! 28.8 mg/l 'f
0.686 mg/l 0.461 mg/l
0.671 mg/l <0.100 mg/l r~
<0.002 mg/l I <0.100 mg/l .Ii':
1260 mg/l I 925 mg/l ~fl
0.141 mg/l <0.100 mg/l ,i,
0.464 mg/l 0.711 mg/l
<0.010 mg/l <0.240 mg/l
0.326 mg/l 0.745 mg/l
3.57 mg/l <0.140 mg/l
<0.0004 mg/1 ! <0.0002 mg/1
3740 mg/l 203 mg/l
0.820 mg/ll 0.464 mg/l
265 mg/ll 152 mg/l
50.6 mg/l i 66.2 mg/l
42.0 mg/l i 13.3 mg/l
1260 mg/l 346 mg/l
2.69 mg/l 8.86 mg/l
0.20 mg/l <0.54 mg/l
<0.008 mg/l <1.36 mg/l
<0.008 mg/l <0.220 mg/l
0.182 mg/l <0.200 mg/l
2.63 mg/ll 2.81 mg/l
0.030 mg/ll 0.418 mg/l
1.00 mg/ll 0.320 mg/l ,i
4.5 mg/l 2.92 mg/l
No analysis No analysis
3060 mg/l No analysis
2880 mg/l No analysis
774 J,!g/l 4.67 J,!g/l
1520 pCill 80.1 pCill
50.0 pCill ! 7.06 pCill
b Sample ID SDOOI-SD004, March 1994; results are average ofSDOOl-SD004 [Chain-of-Custody (CoC) E-0278-94]
TCLP
Regulatory
Levelg
5.0 mg/l
---
5.0 mg/l
100 mg/l
---
---
1.0 mg/l
---
5.0 mg/l
---
---
0.2 mg/l
---
---
---
---
---
---
---
---
5.0 mg/l
---
1.0 mg/l
---
---
---
---
---
---
---
---
---
---
C Sample ID SD005, March 1994; 40 CFR 261 Appendix II "Method 1311 Toxicity Characteristic Leaching Procedure" [CoC E-0278-94]
d Sample ID MISC raff-filter press only, May 2003 [CoC SF03-278]
e Sample ID MISC (Raffinate Filtrate), May 2003 [CoC SF03-129]
f Sample ID MISC raff-filter press only leachate, May 2003; 30 Texas Administrative Code Chapter 335 Subchapter R Appendix 4 "7 -day Distilled
Water Leachate Test Procedure" [CoC SF03-278]
g 40 CFR 261.24, Table 1 -Maximum Concentration of Contaminants for the Toxicity Characteristic.
Page 4 of5
sfc rmpr dewatered sludge d1.doc February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
c. The basis of hazardous material or waste determinations.
Attachment D 1 ci
Basis for the Selection of Constituentsl
The RCRA Facility Investigation required contamination
characterization for those constituents found in 40 CFR Part 261
Appendix VIII and Part 264 Appendix IX.
SFC identified potential Appendix VIII and Appendix IX
contaminants at the Site utilizing EPA's RFI guidance document
(EPA 530/SW-89-031), herein referred to as the guidance
document. Specifically, List 4 (Industry Specific Monitoring
Constituents) of Volume 1 of the guidance document indicated
those constituents which may be present at a site based on the
site's particular industrial classification.
Samples specified in the RFI Workplan for comprehensive analysis
were analyzed for those Appendix VIII and Appendix IX
constituents specified in the guidance document for the mining
industry, the inorganic chemicals industry and the non-ferrous
metals industry, with the following exceptions:
Metals analysis conducted by Method 6010 (SW-846) provided
results for two (2) additional metals which are not listed
in the guidance document. The two metals (calcium and
molybdenum) were included based on their potential presence
in some of the Site process materials.
1 Sequoyah Fuels Corporation, Final RCRA Facility Investigation Workplan, Section 1.5.4 Comprehensive List of
Constituents, October 31, 1994 (Revised January 4, 1995).
Page 1 of9
sfc rmpr dewatered sludge d1cLdoc February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
c. The basis of hazardous material or waste determinations.
Attachment D 1 ci
Table 3. Comprehensive List of Constituents
Phenols and Organic Acids
Benzoic acid 1 4,6-Dinitro-o-cresol
Benzyl alcohol 2,4-Dinitrophenol
2-sec-Butyl-4,6-dinitrophenol 1,4 2-Methyl-4,6-dinitrophenol
4-Chloro-3-methylphenol 1 2-Nitrophenol
2-Chlorophenol 4-Nitrophenol
Cresol (methyl phenols) Pentachlorophenol
2-Cyclohexyl-4,6-dinitrophenol 1,4 Phenol
2,4-Dichlorophenol Tetrachlorophenols
2,6-Dichlorophenol Trichlorophenols
2,4-Dimethylphenol
Phthalate Esters
Benzyl butyl phthalate Di-n-butyl phthalate 1
Bis(2-ethylhexyl)phthalate Dimethyl phthalate
Diethyl phthalate Di-n-octyl phthalate
Nitroaromatics and Cyclic Ketones
Dinitrobenzene 1 Isophorone
2,4-Dinitrotoluene Naphthoquinone
2,6-Dinitrotoluene ritrobenzene
Page 4 of9
sfc rmpr dewatered sludge d1cLdoc
Page 1 of 6
1
February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
E. CHEMICAL AND HAZARDOUS CHARACTERISTICS
2. DESCRIPTION AND HISTORY OF MATERIAL
c. The basis of hazardous material or waste determinations.
Attachment D 1 ci
Table 3. Comprehensive List of Constituents
Page 3 of
Base/Neutrals
Acenaphthene 4-Chlorophenyl phenyl ether Heptachlor 2
Acenaphthylene Chrysene Heptachlor epoxide 2
Acetophenone 4,4'-DDD 2 Hexachlorobenzene
Aldrin 2 4,4'-DDE 2 Hexachlorobutadiene
Aniline 4,4'-DDT 2 Hexachlorocyclopentadiene
Anthracene Dibenz(a,j)acridine 1 Hexachloroethane
4-Aminobiphenyl Dibenz(a,h)anthracene Indeno(1,2,3-cd)pyrene
Aroclor-1016 Dibenzofuran Isophorone
Aroclor-1221 Di-n-butyl phthalate Methoxychlor 2
Aroclor-1232 1,3-Dichlorobenzene 3-Methylcholanthrene
Aroclor-1242 1,4-Dichlorobenzene Methyl methanesulfonate
~roclor-1248 1,2-Dichlorobenzene 2-Methylnaphthalene
Aroclor-1254 3,3'-Dichlorobenzidine Naphthalene
Aroclor-1260 Dieldrin 2 I-Naphthylamine
Benzidine 1 Diethyl phthalate 2-Naphthylamine
Benzo(a) anthracene p-Dimethylaminoazobenzene 2-Nitroaniline
Benzo(b)fluoranthene 7,12-Dimethylbenz(a)anthracene 3-Nitroaniline
Benzo(k)fluoranthene a-,a-Dimethylphenethylamine 4-Nitroaniline
Benzo(g,h,i)perylene Dimethyl phthalate Nitrobenzene
Benzo(a)pyrene 2,4-Dinitrotoluene N-Nitroso-di-n-butylamine
ex-BHC 2 2,6-Dinitrotoluene N-Nitrosodimethylamine
~-BHC 2 Diphenylamine ~-Nitrosodiphenylamine
b-BHC 2 1,2-Diphenylhydrazine N-Nitrosodipropylamine
y-BHC 2 Di-n-octyl phthalate ~-Nitrosopiperidine
Bis(2-chloroethoxy)methane Endosulfan I 2 Pentachlorobenzene
Bis(2-chloroethyl)ether 1 Endosulfan II 2 Pentachloronitrobenzene
Bis(2-chloroisopropyl)ether Endosulfan sulfate 2 Phenacetin
Bis(2-ethylhexyl)phthalate Endrin 2 Phenanthrene
4-Bromophenyl phenyl ether Endrin aldehyde 2 2-Picoline
Butyl benzyl phthalate Endrin ketone 1 Pronamide
Chlordane 2 Ethyl methane sulfonate Pyrene
6
4-Chloroaniline Fluoranthene 1,2,4,5-Tetrachlorobenzene
l-Chloronaphthalene 1 Fluorene 1,2,4-Trichlorobenzene
2-Chloronaphthalene 2-Fluorobiphenyl 1,4 Toxaphene 2
Page 6 of9
sfc rmpr dewatered sludge d1ci.doc February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
F. CHEMICAL AND HAZARDOUS CHARACTERISTICS
3. DESCRIPTION AND HISTORY OF MATERIAL
c. The basis of hazardous material or waste determinations.
Attachment D 1 ci
Table 3. Comprehensive List of Constituents
Volatiles
!Acetone 1,1-Dichloroethene
!Acrolein trans-1,2-Dichloroethene
!Acrylonitrile cis-1,3-Dichloropropene
Benzene trans-1,3-Dichloropropene
Bromochloromethane 1 1,4-Difluorobenzene 1
Bromodichloromethane Ethanol 1
4-Bromofluorobenzene 1 Ethylbenzene
Bromoform Ethyl methacrylate
Bromomethane 2-Hexanone
2-Butanone (MEK) Iodomethane 1
Carbon disulfide Methylene chloride
Carbon tetrachloride 4-Methyl-2-pentanone
Chlorobenzene Styrene
Chlorodibromomethane 1,1,2,2-Tetrachloroethane
Chloroethane Toluene
2-Chloroethyl vinyl ether 1, 1, 1-Trichloroethane
Chloroform 1,1,2-Trichloroethane
Chloromethane 1 Trichloroethene
Dibromomethane 1 Trichlorofluoromethane
1,4-Dichloro-2-butane 1,2,3-Trichloropropane
Dichlorodifluoromethane Vinyl acetate
1,1-Dichloroethane Vinyl chloride
1,2-Dichloroethane Xylene
Page 6 of 6
Will not be provided because constituent is not listed in either
40 CFR 261, Appendix VIII or 40 CFR 264, Appendix IX.
2 Analytical results for organochlorine pesticides will
not be provided.
Will be provided and is in addition to the metals specified in the
RFI guidance document.
Will not be provided because laboratory method does not normally
provide result.
Page 9 of9
sfc rmpr dewatered sludge d1cLdoc February 2010
USPCI
_ A Subsidiary of
111111' Union Pacific Corporation
Analytical Services
4322 South 49th West Avenue
Tulsa, OK 74107-6100
918/446-1162
918/445-0945 Fax
SAMPLE IDENTIFICATION: 50000493
CUSTOMER IDENTIFICATION: SD-14
PROJECT NUMBER: RFI
REPORT NUMBER: 9078
DATE SAMPLED: 01/25/95
TYPE OF MATERIAL: SLUDGE
16 Feb 95 PAGE
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
DATE SUBMITTED: 01/26/95
DATE COMPLETED: 02/16/95
REFERENCE PRACTICAL
13
~PA~R~A=M~E~T~ER~ ___________ =ME~T~H~O.:.=D:...-.-_ QUANTITATION LIMIT =RE:=:..:S=U:..=iL~T _____ _
Mercury (Total) SW 7471 0.01 mg/kg 0.34 mg/kg
Volatiles
Acetone SW 8240 0.1 mg/kg BDL mg/kg
Acetonitrile SW 8240 0.1 mg/kg BDL mg/kg
Acrolein SW 8240 0.1 mg/kg BDL mg/kg
Acrylonitrile SW 8240 0.1 mg/kg BDL mg/kg
Benzene SW 8240 0.005 mg/kg BDL mg/kg
Bromodichloromethane SW 8240 0.005 mg/kg BDL mg/kg
Bromoform SW 8240 0.005 mg/kg BDl. mg/kg
2-Butanone SW 8240 0.1 mg/kg 0.3 mg/kg
Carbon disulfide SW 8240 0.005 mg/kg BDL mg/kg
Carbon Tetrachloride SW 8240 0.005 mg/kg BDL mg/kg
Chlorobenzene SW 8240 0.005 mg/kg BDL mg/kg
Ch1oroethane SW 8240 0.005 mg/kg BDL mg/kg
2-Chloroethyl vinyl ether SW 8240 0.01 mg/kg BDL mg/kg
Chloroform SW 8240 0.005 mg/kg BDL mg/kg
Chlorodibromomethane SW 8240 0.005 mg/kg BDL mg/kg
1,4-Dichloro-2-butene SW 8240 0.1 mg/kg BDL mg/kg
Dichlorodifluoromethane SW 8240 0.005 mg/kg BDL mg/kg
1,1-Dichloroethane SW 8240 0.005 mg/kg BDL mg/kg
1,2-Dichloroethane SW 8240 0.005 mg/kg BDL mg/kg
l,l-Dichloroethene SW 8240 0.005 mg/kg BDL mg/kg
trans-l,2-Dichloroethene SW 8240 0.005 mg/kg BDL mg/kg
1,2-Dichloropropane SW 8240 0.005 mg/kg BDL mg/kg
cis-1,3-Dichloropropene SW 8240 0.005 mg/kg BDL mg/kg
BDL = BELOW QUANTITATION LIMIT % REC = PERCENT RECOVERY (T) = TOTALS
J = VALUE REPORTED BELOW QUANTITATION LIMIT
OUf Mission:
Provide the highest quality laboratory management services that conSistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
USPCI
_ A Subsidiary of
(11111. Union Pacific Corporation
Analytical Services
4.122 South 49th West Avenue
Tulsa, OK 74107-6100
918/446-1162
918/445-0945 Fax
SAMPLE IDENTIFICATION: 50000493
CUSTOMER IDENTIFICATION: SD-14
PROJECT NUMBER: RFI
REPORT NUMBER: 9078
DATE SAMPLED: 01/25/95
TYPE OF MATERIAL: SLUDGE
PARAMETER
trans-l,3-Dichloropropene
Ethyl methacrylate
2-Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
1, 1, 1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1,1, I-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Trichlorofluoromethane
1,2,3-Trichloropropane
Vinyl acetate
Vinyl chloride
Total xylenes
Semivolatiles
Acenaphthene
Acenaphthylene
Acetophenone
Aldrin
4-Aminobiphenyl
Aniline
Anthracene
REFERENCE
METHOD
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8240
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
16 Feb 95 PAGE 14
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
DATE SUBMITTED:
DATE COMPLETED:
PRACTICAL
01/26/95
02/16/95
OUANTITATION LIMIT RESULT
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDIJ mg/kg
0.05 mg/kg 0.08 mg/kg
0.05 mg/kg BDL mg/kg
0.01 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
0.01 mg/kg BDL mg/kg
0.005 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
BDL = BELOW QUANTITATION LIMIT % REC = PERCENT RECOVERY (T) = TOTALS
J = VALUE REPORTED BELOW QUANTITATION LIMIT
OUf Mission:
Provide the highest quality laboratory management services that consistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
USPCI
_ A Subsidiary of
'lilli' Union Pacific Corporation
Analytical Services
1:'>22 SOllth 49th West Avenue
Tulsa, OK 71107-6100
918/446-1162
918/415-0945 Fax
SAMPLE IDENTIFICATION: 50000493
CUSTOMER IDENTIFICATION: SD-14
PROJECT NUMBER: RFI
REPORT NUMBER: 9078
DATE SAMPLED: 01/25/95
TYPE OF MATERIAL: SLUDGE
16 Feb 95 PAGE
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
DATE SUBMITTED: 01/26/95
DATE COMPLETED: 02/16/95
REFERENCE PRACTICAL
15
P~A~R=A~M~E~TE~R~ _____________________ M=E~T~H=O=D~ __ OUANTITATION LIMIT R=E=S=U~L~T~ ________ __
Aroclor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aloc1or-1260
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Benzo(a)pyrene
Benzyl alcohol
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC (Lindane)
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
Chlordane
4-Chloroaniline
2-Chloronaphthalene
2-Chlorophenol
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
2 mg/kg
2 mg/kg
2 mg/kg
2 mg/kg
2 mg/kg
2 mg/kg
2 mg/kg
0.05 mg/kg
0.05 mg/kg
0.05 mg/kg
0.2 mg/kg
0.05 mg/kg
0.4 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
0.2 mg/kg
1 mg/kg
0.4 mg/kg
0.2 mg/kg
0.2 mg/kg
BDL mg/kg
BDL mg/kg
DDL mg/kg
EDL mg/kg
EDL mg/kg
EDL mg/kg
EDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
DDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
DDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
DDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
BDL mg/kg
EDL == BELOW QUANTITATION LIMIT % REC = PERCENT RECOVERY (T) == TOTALS
J = VALUE REPORTED BELOW QUANTITATION LIMIT
OUf Mission:
Provide the highest quality laboratory management services that consistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
USPCI
_ A Subsidiary of
'11111' Union Pacific Corporation
Analytical Services
4322 South 19th West Avenue
Tulsa, OK 74107-6100
918/446-1162
918/,1<15-0945 Fax
SAMPLE IDENTIFICATION: 50000493
CUSTOMER IDENTIFICATION: SD-14
PROJECT NUMBER: RFI
REPORT NUMBER: 9078
DATE SAMPLED: 01/25/95
TYPE OF MATERIAL: SLUDGE
REFERENCE
16 Feb 95 PAGE
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
DATE SUBMITTED:
DATE COMPLETED:
PRACTICAL
01/26/95
02/16/95
16
PARAMETER METHOD QUANTITATION LIMIT RESULT
4-Chlorophenyl phenyl ether
Chrysene
2-Methylphenol
3-and 4-methylphenol
4,4' -DDD
4,4' -DDE
4,4' -DDT
Dibenz(a,h)anthracene
Dibenzofuran
Dibenz(a,e)pyrene
Di-n-butylphthalate
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-Dichlorophenol
Dieldrin
Diethyl phthalate
p-Dimethylaminoazobenzene
7, 12-Dimethylbenz(a)anthracene
1,1-Dimethylphenethylamine
2,4-Dimethylphenol
Dimethylphthalate
4,6-Dinitro-2-methylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
0.2 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.4 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
1 mg/kg BDL mg/kg
1 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
BDL = BELOW QUANTITATION LIMIT % REC = PERCENT RECOVERY (T) = TOTALS
J = VALUE REPORTED BELOW QUANTITATION LIMIT
OUf Mission:
Provide the highest quality laboratory management services that consistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
USPCI
_ A Subsidiary of
'lilli' Union Pacific Corporation
Analytical Services
4322 South 49rh West Avenue
Tulsa, OK 74107-6JOO
918/446-1162
918/445-0945 Fax
SAMPLE IDENTIFICATION: 50000493
CUSTOMER IDENTIFICATION: SD-14
PROJECT NUMBER: RFI
REPORT NUMBER: 9078
DATE SAMPLED: 01/25/95
TYPE OF MATERIAL: SLUDGE
REFERENCE
16 Feb 95 PAGE
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
DATE SUBMITTED:
DATE COMPLETED:
PRACTICAL
01/26/95
02/16/95
18
PARAMETER METHOD OUANTITATION LIMIT RESULT
2-Naphthylamine
2-Nitroaniline
3-Nitroaniline
4-Nitroaniline
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodimethylamine
N-Nitrosodipheny1a.mine
N-Nitrosodipropylamine
N-Nitrosopiperidine
Pentachlorobenzene
Pentachloronitrobenzene
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
2-Picoline
Pronamide
Pyrene
1,2,4,5-Tetrachlorobenzene
2,3,4,6-Tetrachlorophenol
Toxaphene
1,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2, 4, 6-Trichlorophenol
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
0.2 mg/kg BDL mg/kg
1 mg/kg BDL mg/kg
1 mg/kg BDL mg/kg
0.4 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
1 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 rng/kg BDL mg/kg
0.2 rng/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
1 mg/kg BDL mg/kg
0.4 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.05 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
0.2 mg/kg BDL mg/kg
BDL = BELOW QUANTITATION LIMIT % REC = PERCENT RECOVERY (T) TOTALS
J = VALUE REPORTED BELOW QUANTITATION LIMIT
OUf Mission:
Provide the highest quality I~boratory management services that consistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
USPCI
_ A Subsidiary of
"1111' Union Pacific Corporation
Analytical Services
4322 South 49th West Avenue
Tulsa, OK 74107-6100
918/446-1162
918/445-0945 Fax
SAMPLE IDENTIFICATION: 50000493
CUSTOMER IDENTIFICATION: SD-14
PROJECT NUMBER: RFI
REPORT NUMBER: 9078
DATE SAMPLED: 01/25/95
TYPE OF MATERIAL: SLUDGE
16 Feb 95 PAGE
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
DATE SUBMITTED: 01/26/95
DATE COMPLETED: 02/16/95
REFERENCE RECOVERY
3
P~~AR=A~M~E~T~E~R ______________________ ~ME~T~H~O~D~ __ =L=IM=I~T~S~(~%~) _______ RESULT C%)
Volatiles-Surrogates
1,2-Dichloroethane-d4
Toluene-d8
Bromofluorobenzene
Semi volatiles-Surrogates
2-Fluorophenol
d5-Phenol
dS-Nitrobenzene
2-Fluorobiphenyl
2,4,6-Tribromophenol
d14-Terphenyl
SW 8240
SW 8240
SW 8240
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
SW 8270
76 -114
88 -110
86 -115
21 -100
10 -94
35 -114
43 -116
10 -123
33 -141
D indicates sample was diluted to a concentration in which surrogates
cannot be accurately measured. The value listed reflects the dilution
factor. Some compounds may be run less dilute for better detection.
81
89
80
72
88
83
83
89
64
I indicates interference of surrogate compound, recoveries indeterminable.
Surrogate recoveries flagged as either high (H) or low (L) indicates
sample results may be biased either high or low respectively, and the
sample results should be considered as estimates.
OUf Mission:
Provide the highest quality laboratory management services that consistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
L
USPCI
- A Subsidiary of 'lilli' Union Pacific Corporation
Analytical Services
4322 SOllth 49th West Avenue
Tulsa, OK 7·1107-6100
918/446-1162
918/445-0945 Fax
SONNY EIDSON
SEQUOYAH FUELS
P.O. BOX 610
GORE OK 74435
QA/QC Report
Cross Reference
Project Name: RFI
USPCI SAMPLE
50000491
50000492
50000493
50000494
50000495
50000496
Our Mission:
ID CUSTOMER ID
SD-13
SD-13 DUP
SD-14
SD-15
SD-IS DUP
SD-16
Provide the highest quality laboratory management services that consistently meet or exceed customer
needs and regulatory requirements at competitive costs while enhancing shareholder value.
CA/QC REPORT
METALS· SOIL
MATRIX SPIKE: 50000496
CC FILE 10: 50000497
PARAMETER
MERCURY
BLANK
RESULTS MG/L
BOL
SAMPLE
RESULTS MG/L
0.00048 HG
MG/L UNIT VALUES ARE BASED ON DIGESTATE CONCENTRATION
SPIKE LEVEL
RESULTS MG/L
0.0100
SPIKE I SPIKE II
RESULTS MG/L RESULTS MG/L
0.0109 0.0100
* = OUT OF ac LIMIT BDL = BELOY DETECTION LIMIT
RECOVERY
I
104.3%
RECOVERY AVERAGE
11 RECOVERY DIFFERENCE
95.4% 99.9% 8.5%
METHOO M.CTRl
CONTROL RECOVERY
0.0098 98.0%
+ = INSTRUMENT SPIKE (QC ACCEPTABLE LIMIT IS 75-125%)
QA/QC REPORT
VOLATILES BY GC/MS -SOIL
METHOO CONTROL ac FILE 10: 50000497
BLANK SAMPLE SPIKE LEVEL SPIKE I SPIKE II RECOVERY RECOVERY QC LIMITS
PARAMETER RESULTS UG/KG RESULTS UG/KG UG/KG RESULTS UG/KG RESULTS UG/KG I II RPD RPD X REe
1,1·0ichloroethene BOL BOL 40 48 47 120% 118% 2 35 0-234
Methylene chloride BOl BOL 40 45 45 106% 105% 1 29 0-221
trans-1,Z-Oichloroethene BOl BOL 40 45 45 113% 112% 1 15 54-156
1,1-0ichloroethane BOL BOL 40 44 43 109% 108% 1 13 59-155
Chloroform BOL BOl 40 45 45 114% 113% 0 15 51-138
1,1,1-Trichloroethane BDL BOl 40 45 45 112% 112% 0 17 52-162
Carbon tetrachloride BOL BOL 40 49 48 123% 119% 3 8 70-140
Benzene BOL BOL 40 43 42 109% 106% 2 19 37-151
1,2-0ichloroethane BOL BOl 40 48 47 119% 118% , 18 49-155
Trichloroethene BOl BOL 40 45 45 114% 112% 2 11 71-157
1,Z-Oichloropropane BOL BOl 40 45 43 111% 108% 3 38 0-210
Bromodlchloromethane BOL BOl 40 46 45 114% 112% 1 18 35-155
cis-1,3-0ichloropropene BOL BOl 40 45 44 113% 110% 3 47 0-227
Toluene BOL BOl 40 44 43 110% 107"10 3 17 47-150
trans-1,3-0fchloropropene BOL BOL 40 39 38 97% 94% 3 16 17-183
1,1,2-Trichloroethane BOl BOl 40 49 50 122% 123% 1 16 52-150
Tetrachloroethene BDL BOL 40 41 39 102% 96% 5 13 64-148
Chlorodibromomethane BOL BOL 40 48 47 119% 116% 2 16 53-149
Chlorobenlene BOL BOL 40 45 43 111% 107% 3 20 37-160
Ethylbenzene BDL BDL 40 47 44 116% 110% 5 21 37-162
Bromoform BOL BOL 40 49 46 121% 114% 5 19 45-169
1,1,2,2-Tetrachloroethane BOL BOL 40 55 53 136% 130% 5 17 46-157
BOL = BELOW DETECTION LIMITS NIS = NOT IN SPIKE MIX # = OUT OF QC LIMITS o = DETECTABLE
QA/QC REPORT
VOLATILES BY GC/MS -SOIL MATRI)( SPIKE: 50000382 ac FILE ID: 50000497
BLANK SAMPLE SP IKE lEVEL SPlICE I SPIKE II RECOVERY RECOVERY QC LIMITS
PARAMETER RESULTS UG/KG RESULTS UG/KG UG/KG RESULTS UG/KG RESULTS UG/KG I II RPO RPO % REC
1,1-0ichloroethene BOL BOL 40 49 51 124% 127% 3 35 0-234
Methylene chloride BoL BOL 40 53 56 102% 110% 7 29 0-221
trans-1,2-0ichloroethene BOL BOL 40 41 39 101% 97% 5 15 54-156
1,1-Dichtoroethane BoL BoL 40 44 43 110% 108% 2 13 59-155
Chloroform BOL BOL 40 49 48 123% 120% 2 15 51-138
1,1,1-Trichloroethane BOL BOL 40 50 49 125% 122% 2 17 52-162
Carbon tetrachloride BOL BOL 40 59 60 148% # 150% # 1 8 70-140
Benzene BOL BOL 40 43 42 107"10 106% 1 19 37-151
1,2-0fchloroethane BOL BOL 40 55 55 138% 138% 1 18 49-155
Trichloroethene BOL BOL 40 77 76 192% # 190% # 1 " 71-157
1,2-0ichloropropane BOL BDL 40 44 43 111% 106% 4 38 0-210
Bromodichloromethane BOL BDL 40 S1 48 127"1. 120% 6 18 35-155
cis-1,3-0ichloropropene BoL BOL 40 43 41 108% 102% 6 47 0-227
Toluene BOL BOL 40 42 41 104% 101% 3 17 47 .. 150
trans-l,3-0ichloropropene BOL BOL 40 37 35 93% 88% 5 16 17-183
1,1,Z-Trichloroethane BOL BOL , 40 45 38 113% 96% 16# 16 52-150
Tetrachloroethene BOL BOL 40 44 45 110% 111% 1 13 64-148
Chlorodibromomethane BoL BOL 40 54 54 136% 135% 1 16 53-149
Chlorobenzene BOL BOL 40 42 41 106% 102% 3 20 37~160
Ethyl benzene BOL BOL 40 46 45 116% 113% 3 21 37~162
Bromoform BOl BOL 40 56 54 140% 135% 3 19 45~169
1,1,2,2-Tetrachloroethane BOL BOL 40 4 1 10% # 1% # 157# 17 46-157
BOL = BELOW DETECTION LIMITS NIS = NOT IN SPIKE MIX # = OUT OF QC LIMITS o = DETECTABLE
QA/QC REPORT
SEMIVOLATILE SOIL
METHOD CONTROL
QC FILE 10: 50000497
BLANK SAMPLE SPlICE LEVEL SPlICE I SPIKE II RECOVERY RECOVERY AVERAGE
PARAMETER RESULTS MG/KG RESULTS MGIICG RESULTS MG/KG RESULTS MG/KG RESULTS MGIICG I II RECOVERY DIFFERENCE
4-NJTROPHENOL # BOL SOL 1.60 1.52 1.45 94.8% 90.8% 92.8% 4.3%
2,6-DINITROTOLUENE BOL BOL 0.80 0.80 0.87 100.1% 108.8% 104.5% 8.3%
2,4'DINITROTOLUENE # BOL SOL 0.80 0.81 0.63 101.3% 103.8% 102.6% 2.4%
O(ETHYL PHTHALATE SOL BOL 0.80 0.86 0.80 107.1% 100.0% 103.6% 6.9%
4-CHLOROPHENYL PHENYL ETHER BOL BDL 0.80 0.80 0.94 100.5% 117.1% 108.8% 15.3%
FLUORENE BOL BDL 0.80 0.91 0.96 114.1% 120.0% 117.0% 5.1%
4,6-DINITRO-2-METHYLPHENOL BOL BOL 1.60 1.72 1.64 107.4% 102.7% 105.0% 4.5%
N-NITROSO-OI-PHENYLAMINE BOL BOl 0.80 0.43 0.45 54.0% 56.0% 55.0% 3.6%
4-BROMOPHENYL PHENYL ETHER BOl BDL 0.80 0.91 0.90 114.0% 112.3% 113.2% 1.5%
HEXACHLOROBENZENE BOL BOL 0.80 0.95 0.92 118.9% 114.7% 116.8% 3.6%
PENTACHLOROPHENOL # BOL BOL 1.60 1.61 1.53 100.8% 95.3% 98.1% 5.6%
PHENANTHRENE BOL BOL 0.80 0.85 0.83 106.8% 104.3% 105.6% 2.4%
ANTHRACENE BDl BDL 0.80 0.89 0.89 111.7% 111.7% 111.7% 0.0%
OI-N~BUTYL PHTHALATE BOl BOL 0.80 0.86 0.82 107.3% 102.5% 104.9% 4.6%
PYRENE # BOL BOL 0.80 0.90 0.79 112.0% 98.2% 105.1% 13.1%
BENZO(A)ANTHRACENE BOL BDL 0.80 0.81 0.74 101.3% 92.2% 96.7"1. 9.4%
CHRYSENE BOl SOL 0.80 0.90 0.82 112.7% 103.1% 107.9% 8.9%
BIS(2-ETHYlHEXYL) PHTHALATE BOl BOL 0.80 0.96 0.89 119.8% 111.5% 115.6% 7.2%
OI-N-OeTYL PHTHALATE BOl BOL 0.80 1.01 1.14 126.6% 142.3% 134.5% 11. 7%
BENZO(B)FLUORANTHENE BDl BOL 0.80 0.89 0.92 111.8% 115.0% 113.4% 2.8%
BENZOCK)FlUORANTHENE BOL BOL 0.80 1.18 1.22 147.3% 152.8% 150.1% 3.7"1.
BENZO(A)PYRENE BOL BOL 0.80 0.97 0.99 121.8% 123.8% 122.8% 1.6%
INDENO(1,2,3-cd)PYRENE BOL BOL 0.80 1.07 1.00 133.2% 124.7% 129.0% 6.6%
OIBENZO(A,H)ANTHRACENE BOl BOL 0.80 1.00 0.96 124.9% 120.4% 122.6% 3.6%
BENZO(G,H,I)PERYlENE BDl BDL 0.80 1.10 1.05 137.4% 131.2% 134.3% 4.6%
# = sw 846 SPIKE CMPD. ; BOl = Below Detection limits; NIS = Not in Spike Mix; * = Out of QC Limits i D = Detectable
QA/QC REPORT
SEMIVOLATILE SOIL
MATRIX SPlICE: 50000491
QC FILE 10: 50000497
BLANK SAMPLE SPIKE lEVEL SPIKE I SPIKE II RECOVERY RECOVERY AVERAGE
PARAMETER RESULTS MG/KG RESULTS MG/KG RESULTS MG/KG RESULTS MG/KG RESULTS MG/KG I II RECOVERY DIFFERENCE
PHENOL # BOL BOL 1.60 0.89 0.92 55.9% 57.6% 56.r'( 3.0%
BIS(2-CHLORO-ETHYL)ETHER BOL BDL 0.80 0.75 0.75 94.2% 94.3% 94.3% 0.2%
2-CHLOROPHENOL # BOL BOL 1.60 0.62 0.71 38.9% 44.2% 41.5% 12.7%
1,3-0JCHLOROBENZENE BOL BOL 0.80 0.92 0.85 115.1% 106.9% 111.0% 7.4%
1,4-01CHLOROBENZENE # BOl BOL 0.80 0.91 0.98 114.1% 122.6% 118.4% 7.2%
BIS(2-CHlORO-iSOPROPVl)ETHER BoL BoL 0.80 0.88 0.87 109.5% 109.2% 109.4% 0.2%
N-NITROSO-OI-N-PROPYLAMINE # BOl BOL 0.80 0.00 0.00 0.0% * 0.0% * 0.0% * 0.0%
HEXACHLOROETHANE BOl BOL 0.80 0.78 0.76 97.4% 95.2% 96.3% 2.3%
NITROBENZENE BoL BOl 0.80 0.93 0.87 116.1% 108.8% 112.5% 6.5%
ISOPHORONE BoL BOL 0.80 1.02 1.00 127.9% 124.7% 126.3% 2.6%
2-NITROPHENOl Bol BOL 1.60 0.32 0.36 19.9% * 22.7% * 21.3% * 13.3%
2,4-DIMETHYLPHENOL BOL BOl 1.60 1.36 1.31 84.9% 81.8% 83.4% 3. rio
BIS(Z-CHLOROETHOXY)METHANE BOL BOL 0.80 0.84 0.82 104.5% 102.9% 103.7% 1.5%
2,4-0ICHLOROPHENOL BoL BOl 1.60 0.63 0.69 39.6% 43.0% 41.3% 8.1%
1,2,4-TRICHlOROBENZENE # BOL BOL 0.80 0.94 0.98 117.7% 123.0% 120.3% 4.5%
NAPHTHALENE BOL BOl 0.80 0.84 0.85 105.6% 106.4% 106.0% 0.8%
HEXACHLOROBUTADJENE BOL BOL 0.80 0.84 0.80 104. "r.4 99.7% 102.2% 4.8%
4-CHLORO-3-METHYLPHENOL # BOL BOL 1.60 1.40 1.40 87.5% 87.3% 87.4% 0.2%
HEXACHLOROCYCLOPENTADIENE BOL BoL 0.80 0.28 0.26 35.5% 32.1% 33.8% 10.0%
2,4f 6-TRICHlOROPHENOL BOl BOL 1.60 0.25 0.31 15.8% * 19.3% '* 17.6% * 19.8%
2-CHlORONAPHTHAlENE BOl BOL 0.80 0.89 0.87 111.1% 108.8% 109.9% 2.1%
DIMETHYL PHTHALATE BOL BOL 0.80 0.86 0.85 107.7% 106.3% 107.0% 1.2%
ACENAPHTHYLENE BOL BOL 0.80 0.93 0.94 115.n~ 117.3% 116.5% 1.3%
ACENAPHTHENE # BOL BOl 0.80 0.85 0.85 106.3% 106.3% 106.3% 0.0%
2,4-0INITROPHENOl BOl BOL 1.60 0.03 0.00 1.7% 0.0% * 0.8% 200.0%*
# = sw 846 SPIKE CMPO. ; BOL = Below Detection Limits; NIS = Not in Spike Mix; * = Out of QC Limits; 0 = DetectabLe
QAlQe REPORT
SEMIVOLATILE SOIL
MATRIX SPIKE: 50000491
QC FILE 10: 50000497
BLANK SAMPLE SPIKE lEVEL SPIKE I SPIKE II RECOVERY RECOVERY AVERAGE
PARAMETER RESULTS HG/KG RESULTS HG/KG RESULTS HG/KG RESULTS MG/KG RESULTS MG/KG I II RECOVERY DIFFERENCE
4-N ITROPHENOL # BOL BoL 1.60 0.03 0.03 2.0% 1.9% 2.0% 6.3%
2,6-DINITROTOLUENE BOL BOL 0.80 0.80 0.80 100.0% 100.4% 100.2% 0.4%
2,4-DINITROTOLUENE # BOL BOL 0.80 0.79 0.78 99.1% 97.7% 98.4% 1.4%
OIETHYL PHTHALATE BOL BOL 0.80 0.97 0.96 120.9% * 119.6% * 120.2% * 1.1%
4-CHLOROPHENYL PHENYL ETHER BOL BOL 0.80 0.91 0.92 113.7"1. 114.5% 114.1% 0.7%
FLUORENE BOL BOL 0.80 0.96 0.97 119.4% 121.5% * 120.4% 1. rio
4,6-DINITRO-2-METHYLPHENOL BOL BOL 1.60 0.14 0.15 8.9% 9.6% 9.3% 7.0%
N-NITROSO-DI-PHENYLAMINE BOL BOL 0.80 0.39 0.42 49.1% 52.4% 50.8% 6.6%
4-BROMOPHENYL PHENYL ETHER BOL BDL 0.80 0.92 0.95 114.5% 118.5% 116.5% 3.5%
HEXACHLOROBENZENE BOL BOL 0.80 0.95 0.96 118.8% 119.6% 119.2% 0.7%
PENTACHLOROPHENOL # BOL BOL 1.60 0.16 0.16 10.0% * 10.2% * 10.1% * 2. rio
PHENANTHRENE BOL BoL 0.80 0.96 0.86 119.4% 107.3% 113.4% 10. rio
ANTHRACENE BOL BOL 0.80 0.90 0.92 112.1% 115.0% 113.6% 2.6%
OI-N-BUTYL PHTHALATE BOL BOL 0.80 0.86 0.93 107.3% 116.2% 111.8% 7.9%
PVRENE # BOL BOl 0.80 0.90 0.90 112.7% 112.7"1. 112.7% 0.0%
SENZO(A)ANTHRACENE BOl SOL 0.80 0.82 0.84 103.1% 105.0% 104.1% 1.8%
CHRYSENE BOL BoL 0.80 0.95 0.90 '18.2% 112.7"1. 115.4% 4.7%
BIS(Z-ETHYLHEXYl) PHTHALATE BOl BOL 0.80 1.04 1.05 130.6% 130.7"1. 130.6% 0 .. 1%
DI-N-OCTYL PHTHALATE BOL BOL 0.80 1.12 0.93 139.9% 116.2% 128.0% 18.5%
BENZO(S)FLUORANTHENE BOL BOL 0.80 0.91 0.93 113.9% 116.1% 115.0% 1.9%
BENZO(K)FLUORANTHENE BOl SOL 0.80 1.17 1.23 145.9% 154.1% 150.0% 5.5%
BENZO(A)PVRENE BDl BDL 0.80 0.99 1.01 124.3% 126.1% 125.2% 1.4%
JNDENO(1,2,3-cd)PVRENE BOL BOL 0.80 1.06 0.78 131.9% 97.5% 114.7% 30.0%
OIBENZO(A,H)ANTHRACENE BOL BOL 0.80 0.99 1.01 123.9% 126.2% 125.1% 1.9%
BENZO(G,H,I)PERYlENE BOL BOL 0.80 1.09 1. 12 136.0% 140.5% 138.2% 3.3%
# = SW 846 SPIKE CMPO. SOL = Below Detection limits; HIS = Not in Spike Mix * = Out of QC Limits; 0 = Detectable
,~ ~ ...... d ~.~.~ Client: Scquoyah Fuels Corp.
Outreach Client Project: SF03-129
Laboratory Lab Numbcr: 20030367
311 North Aspen Date Reported: 6/2/03
Broken Arrow, OK 74012 Date Received: 5/13/03 [phone]
FAX [phone] Page Number: lof4
... t\nalytical Report
Method Result Units DL Prep Anal)'sis Analyst
Date Date
Lab 10: 20030367-()1
Client JD: 1\HSC (Raffinate Filtrate)
Date Sampled: 5/6/03 1:00:00 PM
Matrix: Water
Radiochemical Analyses
Ra-226 8M 7500 Ra (M) 50;0 +/-4.16 pCi/1 1.72 5119/03 5/20/03 SO
Th-230 LANLER200M 145 +/-6.95 mgll 3.76 5/19/03 S/19l03 RE
Uranium ASTMD 5174M 774 ugll 1 5119/03 5120/0] RE
InOl-ganics Analyses
Ammonia (N) EPA 350.3 2880 mg/I 32 5/16/03 5/16/03 RT
Nitrate (N) SM4500-N03-D 3060 mg/I 15 5/13/03 RT
5:45:00 PM
Phosphorus SM4500-P04-D 0.20 mgll 0.1 5/l9/03 RT
Metals Analyses
Aluminum EPA6010B 10.3 mgll 0.220 5/19/03 5120/03 RE
Antimony EPA6010B BDL mgll 0.008 5119/03 5/19103 RE
ll\.rsenic EPA 60 lOB 0.686 mgll 0.007 5/19/03 5/19/03 RE
Barium EPA6010B 0.671 mg!1 0.007 5/19/03 5/19103 RE
Beryllium EPA6010B BDL mgll 0.002 5119/03 5/19103 RE
Cadmium EPA 60 lOB 0.141 mgll 0.044 5/19/03 5120/03 RE
Calcium EPA6010B 1260 mg/l 4.04 5/19/03 5/20/03 RE
Chromium EPA 60 lOB BDL mgtI 0.010 5/19/03 5119103 RE
Cobalt EPA6010B 0.464 mgil 0.110 5/19/03 5/20/03 RE
Copper EPA6010B 0.326 mgll 0.004 5/19/03 5/19103 RE
Iron EPA 60l0B 3.57 mg/l 0.066 5/19/03 5120/03 RE
Lead EPA 6010B BDL mg/l 0.008 5/19/03 5J19/03 RE
Lithium EPA 60 lOB 0.820 mg/I 0.022 5/19103 5/20/03 RE
Magnesiulll EPA6010B 265 mg/l 0.707 5119/03 5/20/03 RE
Manganese EPA6010B 50.6 mg/l 0.303 5/19/03 5/20103 RE
Mercury EPA 7470A BDL mgll 0.O(lO4 5/20/03 5/20/03 RE
Molybdenum EPA6010B 42.0 mg/l 0.033 5/19/03 5120/03 RE
Nickel EPA 60 lOB 2.69 mgll 0.006 5119/03 5120/03 RE
Potassium EPA6010B 3740 mg/I 3.74 5119/03 5/20/03 RE
Selenium EPA 6010B 0.182 mg/I 0.006 5/19/03 5/19103 RE
Silver EPA6010B BDL mg/I 0.007 5119103 5/19103 RE
BDl." Below Dctect.ion T ,imit
,~ Client: Sequoyah Fuels Corp.
Client Project: Raffinate Dewatering ~' •.• '~ Lab Number: 20050975 ~!"f'
Date Reported: 3113/06
Outreach Date Received: 1212/05
Laboratory Page Number: 20f3
311 North Aspen
Broken Arrow, OK 74012
[phone]
FAX [phone] Analytical Report
Method Result Units DL Prep Analysis Analyst
Date Date
Th-232 LANLER200M 2360 +/-443 pCi/g 73 3/6/06 3/7106 RE
Uranium ASTM D 5174M 8750 ug/g 0.990 12/21105 1112/06 MD
Lab ID: 20050975-05
Client ID: SD260
Date Sampled: 11/14/051:20:00 PM
Matrix: Soil
Radiochemical Analyses
Ra-226 SM 7500 Ra (M) 266 +1-5.71 pCi/g 0.567 12/20/05 12/27/05 SO
Th-228 LANL ER200 M 450 +/-192 pCi/g 119 3/6/06 3/7/06 RE
Th-230 LANLER200 M 44500 +/-1900 pCi/g 1580 3/6/06 3/7/06 RE
Th-232 LANL ER200 M 2120 +1-393 pCi/g 90 3/6/06 3/7/06 RE
Uranium ASTM D 5174M 7080 ug/g 0.833 12/21105 1112/06 MD
Lab ID: 20050975-06
Client ID: SO 261
Date Sampled: 11/14/05 1:30:00 PM
Matrix: Soil
Radiochemical Analyses
Ra-226 SM 7500 Ra (M) 367 +/-6.55 pCi/g 0.601 12/20105 12/27/05 SO
Th-228 LANL ER200 M 1080 +/-268 pCi/g 100 3/6/06 3/7/06 RE
Th-230 LANLER200M 61800 +/-2070 pCi/g 1460 3/6/06 3/7/06 RE
Th-232 LANL ER200 M 2800 +/-424 pCi/g 87 3/6/06 3/7106 RE
Uranium ASTM D5174M 7730 ug/g 0.806 12/21/05 1112/06 MD
Lab ID: 20050975·07
Client ID: SD262
Date Sampled: 11114/051 :35:00 PM
Matrix: Soil
Radiochemical Analyses
Ra-226 SM 7500 Ra (M) 180 +/-4.27 pCi/g 0.617 12/20/05 12/28/05 SO
Th-228 LANL ER200 M 1110 +/-332 pCi/g 175 3/6/06 3/7/06 RE
Th-23 0 LANL ER200 M 74400 +/-2700 pCi/g 1840 3/6/06 3/7/06 RE
Th-232 LANL ER200 M 4990 +/-671 pCi/g 72 3/6/06 3/7/06 RE
Uranium ASTM D5174M 8070 ug/g 0.909 12/21/05 1112/06 MD
Lab ID: 20050975·08
Client ID: SD263
Date Sampled: 11/14/051 :45:00 PM
Matrix: Soil
Radiochemical Analyses
BDL = Below Detection Limit
AFFIDAVIT OF JOHN H. ELLIS
I, John H. Ellis, being duly sworn according to law, depose and state as follows:
1. I am presently employed as the President for Sequoyah Fuels Corporation
("SFC") at the company's Gore, Oklahoma facility. In that capacity I am responsible for
senior project management oversight for implementation and execution of reclamation
activities at SFC's Gore facility, operation of facility equipment and systems,
implementation and oversight of decommissioning activities, and related activities
including waste management. My experience with SFC dates back to 1992 when I was
first employed at the company's Gore, Oklahoma facility. I have personal knowledge of
the raw materials used, the production processes employed, and the waste handling
procedures followed at SFC's Gore facility.
2. SFC proposes to ship to Denison's White Mesa Mill in Blanding Utah, the
following material: dewatered raffinate sludge, for processing as alternate feed materials.
All of the proposed alternate feed materials are secondary products or waste streams
produced in the conversion of uranium or the decommissioning of uranium conversion
equipment at facilities owned and operated by SFC, and contains no materials or wastes
from any other source.
3. The raffinate sludge consists of precipitated and settled soil, rock particles,
metals, and radionuclides removed from the yellowcake feed (uranium) during the
purification process at the SFC facility. No wastes from any other source are combined
with the raffinate sludge. The raffmate sludge was passed through a filter press to remove
water thus creating the dewatered raffinate sludge.
AFFIDAVIT OF JOHN H. ELLIS (continued)
4. I have reviewed and am familiar with the Utah Hazardous and Solid Waste
Regulations R315-2-10 and R315-2-11 and the Code of Federal Regulations Title 40
Section 261.31 through 3 3 (the "Regulations") in the form attached hereto as Exhibit A.
Based on the processing steps employed in SFC's uranium conversion facility, the
proposed alternate feed materials do not contain any of the listed wastes enumerated in
the Regulations.
5. Based on my knowledge of waste management at SFC's facilities, the
proposed alternate feed materials have not been mixed with wastes from any other source,
which may have been defined as or which may have contained listed wastes enumerated
in the Regulations.
6. Specifically, the proposed alternate feed materials do not contain
hazardous wastes from non-specific sources (Utah RCRA F type wastes) because (a)
SFC does not operate any processes which produce the types of wastes listed in Section
261.31 of Title 40 of the Regulations, and (b) SFC has never accepted, nor have the
proposed alternate feed materials ever been combined with, wastes from any other source
which contain Utah RCRA F type wastes as defined therein.
7. Specifically, the proposed alternate feed materials do not contain
hazardous wastes from specific sources (Utah. RCRA K type wastes) because SFC does
not operate any of the processes which produce the types of wastes listed in Section
261.32 of Title 40 of the Regulations, and (b) SFC has never accepted, nor have the
proposed alternate feed materials ever been combined with, wastes from any other source
which contain Utah RCRA K type wastes as defined therein.
w, .... -....
PROTOCOli FOR J.)ETERMINING WHETHER ALTER.~ATE FEED MAtE~UA.LS ARE L:r~TED HAZARDOUS WASTESl
kbVEMBER 16;:1999 : !' . ~ I ! . ~ I :. .
1. SOURCE INVESTIGATION. I I: : !
I /. : I
Perform a good faith investigatif:ml{a "Source Investigation" or "S1")2 regarding whether
any listed hazardous wastes3 ar~ Ibcated at the site frQln which alternate feed materia14
("Materiaf') originates (the "Sitt?')i This investiga~ion will be conducted in confomlance
with EP A guidance~ and the I ektent of infomlatiQn required will vary with the
circlUllstances of each case. Fpllpwing are ex~ples of investigations that would be
considered satisfactory under !EPA guidance and this Protocol for some selected
-• 1 ~ . sltuatlons: f 1· Ii,
• Where the Material i~ 9r has been gen~rated from a known process under the
control of the generato* (a) an affidavjt, certificate, profile record or similar i I; i document from the G.erl:'erator or Site ~~ager, to that effect, together "vith (b)
a Material Safety n:at~ Sheet ("MSD~") for the Material~ limited profile
! I i
; ~ i . ! j. .1
; I ! ! ! 'i
1 This Protocol reflects the procedures t~at!~wm be fol1ow~d by lHl understanding betvleea-tl>le U~h
Dhrislea sf g~llie. and Hai!aroous 'Haste, I)eptutmeat ef );;R"I~eat&[ Q\l~li~u]).gQn .;w tRe "gmte") ~ f t i
atl4 International Uranium (USA) Corp~ration ('~ruSA"): for determining whether alternate feed • I . materials proposed for processing at the "'!bite Mesa Mill are: (or contain) listed hazardous wastes. It is
based on current Utah and EPA rules and $p ~ guidance Wlde'r!the Resource Conservation and Recovery
Act ("ReRA"), 42 U.S.C. §§ 6901 et seqt !This Protocol wi~l be changed as necessary to reflect any
pertinent changes to RCRA rules or EPA g4idance. ~ i
! iii
2 This investigation will be perforrn.ed by! rqSA, by the enti~ responsible for the site from which the
Material originates (the "Generator')t or b~ a pombination of ~~e two.
3 Attachment 1 to this Protocol provides! a I· summary of th~ I different classifications of ReM listed j ; I
hazardous wastes. 1 I :
I ! : i
4 Alternate feed materials that are primarylor:intennediate products of the generator of the material (e.g.,
'~green" or "black" salts) are not RCRA 4L~ecbndary materials'? or "solid wastes," as defmcd in 40 CFR
6 d I I .' 2 1, an are not covered by this Protocol.. " . t
5 EPA guidance identifie$ the followinJ sburces of site~ ~hd waste-specific information that may,
depending on the circumstances, be cons~dc~ed in such an investigation: bazardous waste manifests,
vouchers, bills of lading, sales and inventory records, mat~rilll safety data sheets, storage records,
sampling and analysis reports, accid~nt!; reports, site! ;investigation reports, interviews with
enlployees/former employees and formerl0fners/operators, ;spiU reports, inspection report.c; and logs,
permits, and enforcement orders_ See e.g., r1!Fed. Reg~ 18805 ~Apri129" 1996).
I r .
I ! I ! i r
I
!' ;'
3U396141 r l .
I
~, , .. , ' . , ..
l--ROt'OCOL FOR D(.T£RMlNING WUE"fU,ER AtTF.:RNATF.l~£ED MA T"ERIAJ .... S A.RE LISTED HA7.ARDOUS 'VASTES
3.
;
! ~ 1;
Material is not a listed haiardous waste, has mad~ a '~contained-outn detemlination6 with
respect to the Materia1 or lias concluded the Mate3al or Site is not subject to RCRA. ~ i! i ! If yes to either qu.estioll, pl~oceed to Step ~. ;:
1 1: ~ ! If no to both questions, pro,ceed to Step 6·1 ': i!
PROVIDE INFORMAT~ON TO NRC ~ri JAB,
j I ., :1 ill ~ ~
a. If specific inform,arion ~xists to suppo~ a c~ndtusiou that the Material is not, and does
not contain, any listed tlazardous was~e~ ~te(hati9Hal: Uraniam (UaA:) Gerporation
f!!WSA!!) will provide a d~scription of tile Sourc~ Investigation to NRC and/or the State
of Utah Department of ErivironmentaI Qpalirr, ~ivjsion of Solid and Hazardous Waste
(the "State"), together with an affidavit explaHiing \vhy the Material 15 not a listed
l :, 11 .fiazardous waste. ! i: 1
i .: !l
b. Alternatively, if the appropriate regulatory! authority with RCRAjurisdiction over the
Site agrees in writing wit~ the generatoT)~ deterriiination that the Material is not a listed
hazardous waste, makes a bontained-out dete~i1i~tion or determines the Material or Site
( I JI
is not subject to ReRA., roSA will prov~de d,oc'#nentation of the regulatory a.uthority's
determination to NRC and the State. ruSAjm~¥ rely on such detemlination provided
that the State agrees the CO~clllsions of th6 regulatbry authority were reasonable and made
in good faith. Ii: ! 1\
~ ;
Proce.ed to Step 4. I!
I
II
"[
" ;!
l 'I
I I f 1\
6 EPA explains the "'contained-out" (~lSO referred to Js Uc~nta~ed-in") principle as follows: 1 1 j II
In practice, EPA has applied ~he contrined-inlprin4ipl~ to refer to a process where a site-
specific determination is made that concentrations ofh~dous constituents in any given
volume of envrronnlental m6dia are low en6ugh :to determine that the media does not
• j. H ~'c()ntain" hazardous waste. ! Typically, these so-caU¢d Ucontained-in" (or ~'contained-
outHJ detemlinations do ndt mean that no hazardous constituents arc present in
environmental media but s~ply that the Iconcenlr4tions of hazardous constituents
present do not warrant management of the mepia a~ h~krdous waste.
I : -n
EP A has not, to dat~, issued definitive guidaAce' to estkblish the concentrations at which
contained-in detemlinations may be made. As noted ~bove, decisions that media do not
or no longer contain hazardous waste are I t.ypicall~ made on a case-by--casc basis
considering the risks posed bt the conWninat~d media!
63 Fed. Reg. 28619-, 28621-22 (May ~6, 199&) (Phase!W I~D~bel!mb1e).
l !: I I
i
I
30396l.1 31
I I
ill " ..... " • ~ ., ....
PROTOCOl, FOR DET£RMl~lNG WUETHER .t\.LT£R."'lA·n~ FEf:~ MA1'~RIALS ARE LISTED HAZARJ)()US WASTES
7.
hazardous waste. Similarly, if tIle ¥aterial i!S ~ prbcess waste and has been mixed with a
listed hazardous waste, it is a listed.hazardo*slwaste under the RCRA "mixture rule." If
the Material is an Environmental Mediunl,7 it carniot be a listed hazardous waste by direct
listing or wlder the ReRA" umixture rule. ,,8 ! If the Material is a process waste but is not
known to be from a listed source or" to be mix~d with a listed waste, or if the Material is
an Environmental Medium, pr~ceed to Ste~s 17 ~ough II to detemline whether it is a
listed hazardous waste. .; I I .~
l "
If yes. proceed to Step 12. I
If 11 0, proceed to Step 7. I .; I [ .
DOES MATERIAL CONTAIt'l ANY PO~~NT~LY LISTED
FIAZARDOUS CONSTITUENTS? !!: I i -:
Based on the Source Investig~tion (and, if ~pplicable) Confirmation and Acceptance
Sampling), determine whether the Material Co~taiDS any hazardous constituents listed in
the then most recent version of40 CFR 26~, !Appendix VII (which identifies hazardous
constituents for \vhich F .. and K-listed wastes -dvere listed) or 40 CFR 261.33(e) or (f) (the • j
P and tJ listed wastes) (collectively "Potenti~l~y Listed Hazardous Constituents"). If the
Material contains such constituents, a soured evaluation is necessary (pursuant to Steps 8
through 11). If the Materiai does !!Q! ~~ntain any Potentially Listed Hazardous
Constituents~ it is not a listed hazardous i~aste. The Material also is not a listed
hazardous waste it: where appli~able, COnfi&riatiqn and Acceptance Sampling results do
not reveal the presence of any "newn Pot~ntially Listed Hazardous Constitu.ents (Le.,
constituents other than those :that have ~ already been identified by the Source
Investigation (or previous ConfirnlationlAGc~ptance Sanlpling) and detennined not to
originate from a listed source). . I I :
If yes, proceed to Step 8. i 1
I i
.! i If no, proceed to Step 16.
II ;
f I
! ! I I I i ; . I: .'
7 The term uEnvironmental Media" means'so11s, groundlo~ surface water and sediments.
8 The "mixture rule" applies only to' nlixtUres 'of listed ~~r4ous wastes and other "solid wastes.l
> See
40 CFR § 26L3(a)(2)(iv). The mixture rule does"' ~()t :applY to mix.tures of listed wastes and
Environmental Media, because Env1foruncutal Media a~c not "solid wastesn under ReRA. See 63 Fed. i I I . Reg. 28556, 28621 (May 26, 1998).' !! :
) ,
303961.1 5
i ! .! "I i t I
whether they would otherwise have been considered to contain listed or characteristic
hazardous· wastes. Since the Uranium Material contains greater than 0.050/0 source
material, it is exempt from RCRA, regardless of its process history or constituents, and
no further RCRA analysis is required. Further, the Uranium Material has been classified
as 11e.(2) byproduct material by NRC under 40 CFR 261.4(a)(4). 11e.(2) byproduct
material is exempt from RCRA, and for this reason also the Uranium Material is exempt
from RCRA.
Nevertheless, because the Alternate Feed Guidance has not yet been revised to reflect
this position recognized by NRC in the Molycorp TER, and because it is not necessary to
rely on the NRC's classification of the Uranium Material as 11 e.(2) byproduct material
(which in fact should be considered determinative of this issue) the remainder of this
memorandum will demonstrate that, even if the Uranium Material were not considered
source material or 11 e.(2) byproduct material, and as such exempt from RCRA, the
Uranium Material would not, in any event, contain any RCRA listed hazardous wastes,
as required under the Alternate Feed Guidance as currently worded.
2.1 Description of Process which Generated the Uranium Material
This yellowcake conversion process included two primary purification steps: digestion
followed by solvent extraction. Digestion occurred by dissolving the uranium in nitric
acid. The resulting slurry was subjected to solvent extraction using tributyl phosphate
diluted with n-hexane. Process conditions were controlled to extract uranium into the
organic phase. The milling impurities remained in the aqueous phase, a dilute nitric acid
mixture termed raffinate.
The aqueous raffinate stream is primarily a solution of nitric acid, metallic salts, and
trace quantities of uranium and radioactive decay products of natural uranium, primarily
Th-230 and Ra~226. The raffinate stream also contained trace quantities of Th-232,
which is often found in natural uranium ores. The aqueous raffinate stream was
combined with spent sodium hydroxide from nitrous oxide scrubber systems and waste
sodium carbonate solutions. The untreated raffinate stream from solvent extraction was
pumped to an impoundment and allowed to cool. Anhydrous ammonia was added to the
raffinate solution to convert the dilute nitric acid to ammonium nitrate. The final treated
raffinate solution was stored in surface impoundments prior to use as an ammonium
nitrate fertilizer.
Generation of Raffinate Sludge
The addition of the anhydrous ammonia also increased the pH of the raffinate solution
causing the metallic salts and trace quantities of uranium, thorium, and radium to
precipitate and settle out in the impoundments as raffinate sludge.
Per the Radioactive Material Profile record ("RMPR"), the chemical reagents used in the
above processes included:
• nitric acid
• tributyl phosphate
• n-hexane
• anhydrous ammonia
3
• barium chloride
• spent sodium hydroxide
• waste carbonate solutions
• recovered weak acids
The presence of residuals of some of these compounds and/or their reaction byproducts
would be expected in the Uranium Material, as discussed in the sections below.
The raffinate sludge was transferred by slurry to other storage ponds as necessary. The
raffinate sludge was accumulated and stored in several impoundments on site, including
Clarifier A basins and Pond 4. No other materials were combined with the stored sludge.
The raffinate sludge was eventually consolidated in the Clarifier A basins to support
decommissioning of Pond 4 and dewatering of the raffinate sludge.
Treatment of Raffinate Solution Phase
The treated raffinate solution was decanted to another impoundment for further
treatment with barium chloride to remove trace levels of radium through co-precipitation.
The radium co-precipitate was periodically combined with the raffinate sludge in the
other impoundments.
Preparation and Packaging of Dewatered Sludge
The raffinate sludge was slurried from Clarifier A basins and processed through a 225
psi filter press to remove entrained water. The dewatered sludge was placed in one-
cubic-yard polypropylene bags. Approximately 11,000 tons (wet weight basis) or 5,000
tons (dry weight basis) or 11,500 bags are stored on site awaiting final recycling or
disposal. Based on past experience with similar materials, the quantities could be
underestimated. The Mill license amendment therefore contemplates up to
approximately 150 percent of those quantities.
3.0 Basis and Limitations of this Evaluation
The Uranium Material to be processed at the Denison White Mesa Mill consists solely of
the dewatered raffinate sludge currently stored on site at the Facility.
Physical and chemical properties of the raffinate sludge have been determined at
different times to support site characterization activities and treatability studies. The
results of those determinations were described in several reports prepared subject to the
authority of the State of Oklahoma Department of Environmental Quality and/or the NRC
in the process of site decommissioning including the RCRA Facility Investigation Report
(RFI) and the Site Characterization Report (SCR).
As discussed in Section 2.0, above, the Uranium Material contains greater than 0.05%
source material, and is exempt from RCRA, regardless of its process history or chemical
composition, and no further RCRA analysis is required. Also, the Uranium Material has
been classified as 11e.(2) byproduct material by NRC under 40 CFR 261.4(a)(4).
Because 11 e.(2) byproduct material is exempt from RCRA, for this reason also the
Uranium Material is exempt from RCRA. The following evaluation of characterization
4
• Wastes from wood preserving (F032, F034, and F035)
• Petroleum refinery wastewater treatment sludges (F037 and F038)
• Multi-source leachate (F039)
There were no processes conducted at the site which fall under the category of "K" listed
hazardous wastes from specific sources and designated in the following 13 categories:
• Wood preservation (K001)
• Inorganic pigment manufacturing (K002 -K008)
• Organic chemicals manufacturing (K009-K030, K083, K085, K093-K096, K103-
K105, K107-K118, K136, K149-K151, K156-K159, K161, K174-K175, K181)
• Inorganic chemicals manufacturing (K071 , K073, K106, K176-178)
• Pesticides manufacturing (K031-K043, K097-K099, K123-K126, K131-K132)
• Explosives manufacturing (K044-K047)
• Petroleum refining (K048-52, K170-K172)
• Iron and steel production (K061-K062)
• Primary aluminum production (K088)
• Secondary lead production (K069, K100)
• Veterinary pharmaceuticals manufacturing (K084, K1 01-K1 02)
• Ink formulation (K086)
• Coking (K060, K087, K141-K145, K147-K148)
The Uranium Material does not contain any "P" or "U" listed wastes as it contains no
discarded commercial chemical products, off-specification species, container residues,
and spill residues thereof. Any chemicals used in the conversion process and treatment
process which generated the raffinate sludge/Uranium Material were used for their
intended purpose and are not waste materials.
5.1 Volatile Organic Compounds
The analytical results for the total VOCs in indicated that two ketone compounds, 2-
butanone (also called methyl ethyl ketone) and 2-hexanone, were reported at very low
concentrations in the samples for total analysis. 2-butanone was reported at 0.3
milligrams per kilogram ("mg/kg"). 2-hexanone was reported at 0.08 mg/kg.
Review of the site operational history, processes and chemicals, indicated that neither of
these compounds were used or present on the Site. Neither of the compounds has
been associated directly or indirectly with the Facility's processes, nor result from the
breakdown of chemicals which are associated with the process. Both of these ketones
are common laboratory solvents and extractants and multiple laboratory pathways exist
that could introduce them during the sample preparation and analytical processes.
Ketones, including 2 butanone, are present in a number of commonly used supplies in
labs and field sampling programs, including marker pens, label adhesives, and cleaners.
Extensive experience at RCRA, CERCLA, and FUSRAP remediation sites indicates that
ketones, including 2 butanone and 2-hexanone, which are common laboratory solvents
and analytical standards, are consistently present due to laboratory influences or field
sample contamination, and are often not actually site contaminants. The presence of 2-
hexanone may also be an impurity in the n-hexane used in SFC's extraction process.
9
5.4.1 Aluminum
Aluminum wastes may be associated with only one RCRA listing, P006, if they resulted
from disposal of aluminum phosphide commercial chemical products, off-spec
commercial chemical products, or manufacturing chemical intermediates. Aluminum
phosphide is used as an insecticide and fumigant, and in semiconductor manufacturing.
There is no reason this compound would be present as a chemical product, off-spec
product or manufacturing byproduct on the Site. Aluminum is a natural constituent in
some uranium ores and would be present in trace levels in precipitates from the
conversion process at the Site. The P006 listing does not apply to the SFC Uranium
Material.
5.4.2 Antimony
Antimony wastes may carry the following K listings if they resulted from the specific
industries listed here:
K021 fluoromethane production
K161 dithiocarbamate production
K177 antimony oxide speculative accumulation
None of the above operations or processes was ever conducted at the SFC facility.
Antimony is a natural constituent in some uranium ores and would be present in trace
levels in precipitates from the conversion process at the Site. None of the K listings are
applicable to SFC Uranium Material.
5.4.3 Arsenic
Arsenic wastes can carry RCRA listing U136, P011, or P012 if they resulted
(respectively) from the disposal of cacodylic acid, arsenic trioxide, or arsenic pentoxide
commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Cacodylic acid is used as an herbicide for
grasses and tree thinning, as a soil sterilizer, and as a chemical warfare agent. Arsenic
trioxide is used in production of pigments, enamels aniline colors, and decolorizing
glass. It is also used in formulation of insecticides, herbicides, rodenticides, sheep dip
products and wood and hide preservatives. Arsenic pentoxide is used in producing
arsenates, insecticides and weed killers, for dyes, printing and glass coloring, and in
formulation of metal adhesives. There is no reason this any of these compounds would
be present as chemical products, off-spec products or manufacturing byproducts on the
Site.
Arsenic wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
F032, F034, F035
F039
K031
K060
K084, K101, K102
K161
K171, K172,
wood treating
leachates from multi-source landfills
cacodylic acid production
coking
veterinary pharmaceuticals
dithiocarbamate production
petroleum refining
12
K177 antimony or antimony oxide production
None of the above operations or processes was ever conducted at the SFC facility.
Arsenic is a natural constituent in tantalum and tin ores processed at the Site. It is a
natural constituent in some uranium ores and would be present in trace levels in
precipitates from the conversion process at the Site. None of the F or K listings are
applicable to the Uranium Material.
5.4.4 Barium
Barium may be associated with one RCRA listing, P013, if it resulted from the disposal
of barium cyanide commercial chemical products, off-spec commercial chemical
products, or manufacturing chemical intermediates. Barium cyanide is used in metal
finishing and electroplating. There is no reason barium would be present as a chemical
product, off-spec product, or manufacturing byproduct on the Site.
Barium chloride was added to one of the water treatment impoundments to co-
precipitate radium from the decanted raffinate solution and the precipitated barium
sludges were periodically combined with raffinate sludge/Uranium Material in other
impoundments. Residual barium is present as a byproduct of the raffinate solution
treatment and the P013 listing does not apply to the Uranium Material.
5.4.5 Beryllium
Beryllium may be associated with one RCRA listing, P015, if it resulted from the disposal
of commercial chemical beryllium powdered products, off-spec commercial chemical
products, or manufacturing chemical intermediates. Beryllium is present as a
commercial pure product in only a few industrial applications such as nuclear reactor
operations, neutron source generators, solid rocket propellants, and inertial guidance
systems. There is no reason beryllium would be present as a chemical product, off-
spec product or manufacturing byproduct on the Site.
Beryllium is a natural constituent in uranium ores, and concentrates and would be
present in trace levels in precipitates from the conversion process at the Site. The P015
listing does not apply to the Uranium Material.
5.4.6 Cadmium
Cadmium wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
F006 electroplating
F039 leachates from multi-source landfills
K061 steel furnaces
K064 copper production
K069 lead smelting
K177 antimony or antimony oxide production
None of the above operations or processes was ever conducted at the Site. Cadmium is
a natural constituent in some uranium ores and would be present in trace levels in
13
precipitates from the conversion process at the Site. None of the F or K listings are
applicable to Uranium Material.
5.4.7 Calcium
Calcium wastes can carry RCRA listing U032 or P021 if they resulted (respectively) from
the disposal of calcium chromate or calcium cyanide commercial chemical products, off-
spec commercial chemical products, or manufacturing chemical intermediates. Calcium
chromate is used in the manufacture of pigments, oxidizers, catalysts, medicines,
glazes, colored glass, inks and paints. It is also used in anodizing, engraving, etching,
dyeing and finished metal cleaning. Calcium cyanide is used as a rodenticide/fumigant
for grain and fruit production and storage, in gold leaching operations, and in chemical
synthesis of other cyanides. There is no reason any of these compounds would be
present as chemical products, off-spec products or manufacturing byproducts on the
Site.
It is a natural constituent in some uranium ores and would be present in trace levels in
precipitates from the conversion process at the Site. and therefore the U032 and P021
listings do not apply to the Uranium Material.
5.4.8 Chromium
Chromium wastes can carry RCRA listing U032 if they resulted from the disposal of
chromic acid commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Chromic acid is used in the manufacture of
pigments, oxidizers, catalysts, medicines, glazes, colored glass, inks and paints. It is
also used in anodizing, engraving, etching, dyeing and finished metal cleaning. There is
no reason this compound would be present as chemical product, off-spec product or
manufacturing byproduct on the Site.
Chromium wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
P006
P019
F035
F037, F038
F039
K002, K003
electroplating
aluminum coating
wood treating
petroleum refining
leachates from multi-source landfills
chrome pigment production
None of the above operations or processes was ever conducted at the Facility.
Chromium is a natural constituent in some uranium ores and would be present in trace
levels in precipitates from the conversion process at the Site. None of the For K listings
are applicable to Uranium Material.
5.4.9 Cobalt
Cobalt is a natural constituent in uranium ores and natural uranium concentrates and
would be present in trace levels in precipitates from the conversion process at the Site.
Cobalt wastes are not listed under RCRA.
14
selenide are used for cold blackening and decorative finishes of metals. Selenium
disulfide is used in medical preparations. Selenourea is methylated to make protective
glass coatings. There is no reason either of these compounds would be present as
chemical products, off-spec products, or manufacturing byproducts on the Site.
Selenium is a natural constituent in some uranium ores and would be present in trace
levels in precipitates from the conversion process at the Site, and the U and P listings
are not applicable to Uranium Material.
5.4.22 Silver
Silver may be associated with RCRA listings P099 and P104 if it resulted from the disposal of silver
potassium cyanide or silver cyanide as commercial chemical products, off-spec commercial
chemical products, or manufacturing chemical intermediates. There is no reason any of
these compounds would be present as chemical product, off-spec product or
manufacturing byproduct on the Site.
Silver is a natural constituent in some uranium ores and concentrates and would be
present in trace levels in precipitates from the conversion process at the Site, and the U
and P listings are not applicable to Uranium Material.
5.4.23 Sodium
Sodium wastes can carry RCRA listing U236 if they resulted from the disposal of
dimethyl biphenyl diyl bis(azo)bis amino hydroxyl tetrasodium salt commercial chemical
products, off-spec commercial chemical products, or manufacturing chemical
intermediates, which are used in research chemistry and biochemistry. They may also
carry RCRA listings POS8, P10S or P106 if they resulted from the disposal (respectively)
of sodium fluoroacetic acid sodium salt, sodium azide, or sodium cyanide commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Fluoroacetic acid sodium salt is used primarily as a rodenticide. Sodium
azide is used in diagnostic medicine, and as an explosive in air bag inflators. Sodium
cyanide is used in manufacture of dyes, pigments, nylon, insecticides, and chelating
compounds. It is also used in gold and silver extraction, metal treating and cleaning and
ore flotation. There is no reason any of these compounds would be present as chemical
product, off-spec product or manufacturing byproduct on the Site.
Sodium wastes may carry the RCRA listing K161 if they resulted from dithiocarbamate
production. No organic synthesis was ever conducted at the Facility. Sodium is present
as a residual of spent sodium hydroxide added to the process during pH adjustment
generation of the Uranium Material and remains in precipitates from the conversion
process at the Site. The K161 listing is not applicable to SFC Uranium Material.
5.4.24 Strontium
Strontium is the 14th most common element in the earth's crust and can be expected to
be a natural constituent in some uranium ores and a trace constituent in some natural
uranium concentrates. It can be expected to be present in trace levels in precipitates
from the conversion process at the Site. Strontium wastes are not listed under RCRA.
18
5.4.25 Thallium
Thallium wastes can carry the following RCRA listings if they resulted from the disposal
of commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates listed below.
U214 thallium (I) acetate
U215 thallium (I) carbonate
U216 thallium chloride
U217 thallium (I) nitrate
P114 selenious acid dithallium salt
P115 sulfuric acid dithallium salt
Thallium carbonate is used as an analytical standard, and in production of synthetic
diamonds. Thallium chloride is used as a chlorination catalyst and as a sun lamp
radiation monitor. Thallium nitrate is used to produce green-fire pyrotechnics and as an
analytical laboratory standard. Selenious acid and its salts are used for blackening and
decorative finishing of product metals. Sulfuric acid dithallium salt is used in ant-killer
mixtures. There is no reason any of these compounds would be present as chemical
product, off-spec product or manufacturing byproduct on the SFC site. Thallium acetate
is used in ore flotation but was not used at the Facility.
Thallium wastes may carry RCRA listing K178 if they resulted from the manufacture of
ferric chloride as a byproduct from titanium dioxide production. No ferric chloride
processing was ever conducted at the Facility. It is a natural constituent in some
uranium ores and would be present in trace levels in precipitates from the conversion
process at the Site. The K178 listing is not applicable to the Uranium Material.
5.4.26 Vanadium
Vanadium wastes can carry RCRA listing P120 if they resulted from the disposal of
vanadium pentoxide (black flake) commercial chemical products, off-spec commercial
chemical products, or manufacturing chemical intermediates. There is no reason
vanadium compounds would be present as chemical products, off-spec products, or
manufacturing byproducts on the Site.
Vanadium is a constituent of natural ores and concentrates and would be present in
trace levels in precipitates from the conversion process at the Site. The K178 listing is
not applicable to the Uranium Material.
5.4.27 Zinc
Zinc wastes can carry RCRA listings U249, P121, P122, or P205 if they resulted from
the disposal (respectively) of low concentration zinc phosphide, zinc cyanide, high
concentration zinc phosphide, or zinc dimethyl dithiocarbamate (UZiram") commercial
chemical products, off-spec commercial chemical products, or manufacturing chemical
intermediates. Zinc phosphides and Ziram are used solely as rodenticides. Zinc
cyanide is used in metal plating, as an insecticide and as a chemical reagent. There is
no reason any of these compounds would be present as chemical product, off-spec
product, or manufacturing byproduct on the Site.
19
AMMONIA
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely Hazardous F List
UList P List
NONE
NONE
NONE
FLUORIDE
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely Hazardous F List
U List PList
U033
Carbonic difluoride,
Carbon oxyfluoride,
Carbonyl fluoride
U075
Dichlorodifluoro
methane
U134
Hydrogen fluoride
P043
Diisoproplyfluorophosp
hate
P056
Fluorine
P057
2-fluoroacetamide
P058
Fluoroacetic acid
sodium salt
NONE
TABLE 1 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON-METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
NONE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Used in organic synthesis for addition of
carbon groups to other structures.
Used as refrigerant in air conditioners,
and direct contact freezing. Used in
plastics manufacture, and as solvent and
blowing agent.
Catalyst in refinery alkylation,
isomerization, condensation,
dehydration, and polymerization
processes. Used for organic and
inorganic flourination reactions,
production of fluorine gas and aluminum
fluoride, some uranium leaching
processes, and as additive to solid rocket
propellant.
Insecticide
Production of metallic fluorides and
fluorocarbons, fluoridation compounds
for toothpaste and water treatment.
Primarily as a rodenticide.
Primarily as a rodenticide.
NONE
Page 1
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. Fluoride is present as a residual from the conversion of
yellowcake to uranium hexafluoride in the SFC process.
Hydrogen fluoride present in the sludge is a result of process
use, not disposal, of the product.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No F Listings
No K Listings
INORGANIC NITRATES2
Commercial Chemicals Commercial Chemicals
Acutely Toxic Acutely Hazardous
UList P List
NONE
NONE
PHOSPHORUS
Commercial Chemicals Commercial Chemicals
Acutely Toxic Acutely Hazardous
U List P List
U087
O,O-diethyl S-methyl
dithiophosphate
U145
Lead phosphate
U189
Phosphorus sulfide,
Phosphorus trisulfide
U249
Zinc phosphide
POO6
Aluminum phosphide
P039
Phosphorodithioic acid
0,0 diethyl S-[2-
e(thylthio) ethyl diethyl]
ester (malathion)
P040
O,O-diethyIO-pyrazinyl
phosphate
P041
Diethyl-p-nitrophenyl
phosphate (parathion)
P043
Diisopropylfluorophosp
hate (DFP)
P062
Hexaethyl
tetraphosphate (HETP)
P085
Octamethy
TABLE 1 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON-METALS IN SFC DEWATERED SLUDGE
Non-Specific Specific Industrial Uses and Sources ofU or P Listed Element Is This Listing Applicable to
Sources Sources or Compound SFC Sludge?
F List KList
No U Listings
No P Listings
NONE No F Listings
NONE No K Listings
Non-Specific Specific Industrial Uses and Sources of U or P Listed Element Is This Listing Applicable to
Sources Sources or Compound SFC Sludge?
F List KList
Synthesis of pesticides, chemical warfare agents. No. There would be no reason for this compound to be present as pure
product, byproduct, or off-spec product on site.
Used as a stabilizing agent additive in plastic formulation. No. There would be no reason for this compound to be present as pure
product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents. No. There would be no reason for this compound to be present as pure
product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents, used as No. There would be no reason for this compound to be present as pure
rodenticide. product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents, No. There would be no reason for this compound to be present as pure
insecticide, fumigant, semiconductor technology. product, byproduct, or off-spec product on site.
Fruit fly insecticide. No. There would be no reason for this compound to be present as pure
product, byproduct, or off-spec product on site.
Synthesis of thionazin insecticide, fungicide, namtatocide, No. There would be no reason for this compound to be present as pure
chemical warfare agents. product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents. No. There would be no reason for this compound to be present as pure
Insecticide and acaicide. product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents. No. There would be no reason for this compound to be present as pure
product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents; contact No. There would be no reason for this compound to be present as pure
insecticide product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents. No. There would be no reason for this compound to be present as pure
Systemic insecticide toxic to plant-chewing insects. product, byproduct, or off-spec product on site.
Page 2
diphosphoramide
(schradan)
P096
Hydrogen phosphide
(phosphine)
P094
Phosphorodithioic acid
0,0 diethyl S-
etheylthio) ethyl diethyl]
ester
PI09
Tetraethyl
dithiopyrphosphate
(TEDP or sulfotepp)
PIll
Diphosphoric acid
tetraethyl ester
Pl22
Zinc phosphide
NONE
TABLE 1 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON-METALS IN SFC DEWATERED SLUDGE
Organic chemical synthesis, doping agent for No. There would be no reason for this compound to be present as pure
semiconductors, polymerization initiator, condensation product, byproduct, or off-spec product on site.
polymerization catalyst.
Synthesis of pesticides, chemical warfare agents, thion No. There would be no reason for this compound to be present as pure
pesticides. product, byproduct, or off-spec product on site.
Insecticides, chemical warfare agents. No. There would be no reason for this compound to be present as pure
product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents, No. There would be no reason for this compound to be present as pure
incendiary weapons, stabilizer for organic peroxides. product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare agents, used as No. There would be no reason for this compound to be present as pure
rodenticide. product, byproduct, or off-spec product on site.
No F Listings
K037 Wastewater treatment sludges from the production of No. SFC material is not from this industry. Also it is present primarily
disulfoton. as an accessory metal in uranium ores and concentrates, which are not
listed waste sources.
K038 Wastewater from the wsshing and stripping of phorate No. SFC material is not from this industry. Also it is present primarily
as an accessory metal in uranium ores and concentrates, which are not
listed waste sources.
K039 Filter cake from the filtration of diethylphosphorodithioic No. SFC material is not from this industry. Also it is present primarily
acid in the production of phorate as an accessory metal in uranium ores and concentrates, which are not
listed waste sources.
K040 Wastewater treatment sludges from the production of No. SFC material is not from this industry. Also it is present primarily
phorate as an accessory metal in uranium ores and concentrates, which are not
listed waste sources.
Page 3
ALUMINUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
POO6
Aluminum
phosphide
NONE
ANTIMONY
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
U List Hazardous
PList
NONE
NONE
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
Insecticide, fumigant, semiconductor
manufacturing.
---
NONE ---
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
---
---
K02I
Spent catalyst from
fluoromethane production
K161
Purification solids, baghouse dust
and floor sweepings from
dithiocarbamate acids production
KI77
Slag from production or
speculative accumulation of
antimony or antimony oxides
Page 1
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No. SFC material is not from this industry. Also,
antimony is present ptimarily as an accessory metal in
the tungsten ores, which is not a listed waste source.
No. SFC material is not from this industry. Also,
antimony is present primarily as an accessory metal in
the tungsten ores, which is not a listed waste source.
No. SFC material is not from this industry. Also,
antimony is present primarily as an accessory metal in
the tungsten ores, which is not a listed waste source.
ARSENIC
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
U136
Dimethyl arsenic
acid
(cacodylic acid)
POll
Arsenic trioxide
POl2
Arsenic
Pentoxide
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
F List KList
Used as herbicide for Johnson grass on
cotton, in timber thinning, as a soil
sterilizing agent, and as a chemical
warfare agent.
Used in production of pigments, aniline
colors, ceramic enamels, and decolorizing
glass, insecticides, herbicides,
rodenticides, wood and hide preservatives,
and sheep dip.
Used in production of aresenates,
insecticides, dyeing and printing, weed
killers, and colorization of glass. Also
used in metal adhesives.
F032
Wastewater from wood
preserving processes using
creosote and pentachlorophenol
F034
Wastewater from wood
preserving processes using
creosote and pentachlorophenol
F035
Wastewaters from wood
preserving processes using
inorganic preservatives
F039 ---
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
K021 ---
Spent catalyst from
fluoromethane production
K031 ---
Byproduct salts from MSMA and
cacodylic acid production
K060 ---
Ammonia sti11lime sludge from
coking
K084 ---
Wastewater sludge from
veterinary phannaceutical
yroduction
KIOI ---
Distillation tar residues from
veterinary phannaceutical
production
Page 2
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also
arsenic is present primarily as an accessory metal in the
uranium ores and concentrates, which are not listed
waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
BARruM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
U List Hazardous
P List
NONE
PO 13
Barium Cyanide
NONE
BERYLLIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
Beryllium ---POl5
Beryllium powder
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
KI02 ---
Residue from decolorization of
veterinary pharmaceuticals
Kl61 ---
Purification solids, baghouse dust
and floor sweepings from
dithiocarbamate acids production
K171 Spent hydrotreating catalyst ---
from petroleum refining
KI72 ---
Spent hydrorefining catalyst from
petroleum refining
KI77 ---
Slag from production or
speculative accumulation of
antimony or antimony oxides
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
Used in metallurgy and electroplating.
---
NONE ---
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
Beryllium powder is used in the aerospace
industry, as a neutron reflector in nuclear
reactor shielding, solid rocket fuel, and in
X-ray tubes. Also used in alloys and parts
in gyroscopes, guidance system
components, instrumentation and controls
such as solenoids, relays, and switches.
---
NONE ---
Page 3
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site. Barium resulted from addition of barium
chloride for radium removal in the SFC sludge.
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
There would be no reason for powdered beryllium to be
present as pure product, byproduct or off-spec product at
SFC.
No F Listings
No K Listings
COPPER
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
U List Hazardous
P List
NONE
P029
Cuprous or
Cupric Cyanide
CADMIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
P List
NONE
NONE
Non-Specific
Sources
F List
NONE
Non-Specific
Sources
F List
FOO6
Wastewater sludge from
electroplating
F039
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
Used in metallurgy and electroplating,
insecticides, anti-foulants in paints,
catalysts in organic synthesis ..
---
NONE ---
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
---
---
---
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
K06I ---
Steel electric furnace emission
control dust/sludge
K064 ---
Acid plant blowdown thickener
slurry/sludge from primary copper
production blowdown
K069 ---
Emission control dust/sludge from
secondary lead smelting
KI77
Slag from production or
speculative accumulation of
antimony or antimony oxides
Page 4
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site. Copper is present primarily as an accessory
metal in uranium ores and concentrates, which are not
listed waste sources.
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
CALCIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
U032
Calcium chromate
P021
Calcium cyanide
CHROMIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
P List
U032
Chromic acid or
calcium salt of
chromic acid
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
F List KList
Used as a pigment, corrosion inhibitor,
oxidizing agent, battery depolarizer, coatin
g for light metal alloys.
Rodenticide, fumigant for greenhouses,
flour mills, grain, seed, and citrus trees,
gold leaching, and synthesis of other
cyanides.
NONE ---
NONE ---
Non-Specific Specific Industrial Uses and Sources ofU or P
Sources Sources Listed Element or Compound
F List KList
Used in manufacture of pigments,
oxidizers, catalysts, medicines, ceramic
glazes, colored glass, inks, paints, plating,
anodizing, engraving, plastic etching, and
textile dyeing, and metal cleaning.
FOO6 ---
Wastewater treatment sludge from
electroplating
FO 19 Wastewater treatment ---
sludge from chemical coating of
aluminum
F035 ---
Wood treating wastewater
F037 ---
Refinery oil/water separator solids
F038 ---
Refinery secondary oil/water
separator solids
F039 ---
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
Page 5
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings.
No K Listings.
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No P Listings
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
KOO2 ---
Wastewater treatment sludge from
production of chrome yellow
pigment
KOO3 ---
Wastewater treatment sludge from
production of chrome molybdate
orange pigment
KOO4 ---
Wastewater treatment sludge from
production of zinc yellow pigment
KOO5 ---
Wastewater treatment sludge from
production of chrome green
pigment
KOO6 ---
Wastewater treatment sludge from
production of chrome oxide green
pigments
KOO7 ---
Wastewater treatment sludge from
production of iron blue pigments.
KOO8 --
Oven residue from production of
chrome oxide green pigments
K048 ---
Petroleum refining dissolved air
flotation ("DAF") solids
K049 ---
Petroleum refining slop oil
emulsion solids
K050 ---
Heat exchanger bundle cleaning
sludge form petroleum refining
K05I ---
Petroleum refining API separator
solids
K061 ---
Steel electric furnace emission
control dust/sludge
K062 ---
Iron and steel manufacturing
pickle liquor
K069 ---
Emission control dust/sludge from
secondary lead smelting
K086 ---
Solvent, caustic and water wash
sludges from ink formulation
Page 6
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources ..
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources ..
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
COBALT
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
PList
NONE
NONE
NONE
IRON
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
NONE
NONE
LEAD
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
U List Hazardous
P List
U 144
lead acetate
U 145
lead phosphate
U146
lead subacetate
PllO
Tetraethyllead
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
K090 ---
Emission control dust or sludge
from ferrochromium silicon
production
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
---
---
NONE ---
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
---
---
NONE ---
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
Textile dyeing, chrome pigments, gold
cyanide leaching, lab reagent, hair dye.
May be present as antifoulant in paints,
waterproofing, varnishes.
Stabilizing agent added to plastic resins.
Deco10rizing agent added to sugar
solutions in food products.
Synthesized solely as a gasoline
anti-knock additive.
Page 7
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
Is This Listing Applicable to
SFC Sludge?
No U Listings.
No P Listings.
No F Listings.
No K Listings.
Is This Listing Applicable to
SFC Sludge?
No U Listings.
No P Listings.
No F Listings.
No K Listings.
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
F035 ---
Wood treating wastewater
F037 ---
Refinery oiVwater separator solids
F038 ---
Refinery secondary oiVwater
separator solids
F039 ---
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
KOO2 ---
Wastewater treatment sludge from
production of chrome yellow
pigment
KOO3 ---
Wastewater treatment sludge from
production of chrome molybdate
orange pigment
KOO5 ---
Wastewater treatment sludge from
production of chrome green
pigment
K046 ---
Wastewater treatment sludge from
production of lead based
explosive initiators
K048 ---
Petroleum refining dissolved air
flotation ("DAF") solids
K049 ---
Petroleum refining slop oil
emulsion solids
K05I ---
Petroleum refining API separator
solids
K052 Petroleum refining leaded ---
tank bottoms
K06I ---
Steel electric furnace emission
control dust/sludge
K062 ---
Iron and steel manufacturing
pickle liquor
K064 ---
Acid plant blowdown thickener
slurry/sludge from primary copper
production blowdown
Page 8
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also lead is
present primarily as an accessory metal in the tantalum
ores, which is not a listed waste source.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
PI96
Manganese
dimethyldithio
carbamate·
NONE
MERCURY
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
U List Hazardous
PList
UI51
Mercury metal
Hg
P065 Mercury
Fulminate
P092
Acetato-O-
phenyl mercury
or
phenyl mercuric
acetate
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Primarily as a pesticide.
---
NONE ---
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
Dental amalgams, organic and inorganic
reaction catalyst, cathodes for chlorine/
caustic production cells, mirror coating,
vapor and arc lamps, nuclear power
reactors, boiler fluids. Also present in
instruments and used in extractive
metallurgy.
Due to relatively high detonation velocity,
used primarily as an explosive initiator in
military explosives. Too unstable for most
other uses.
Used as a fungicide, anti-mildew agent,
and as a topical spennicide
---
K071 ---
Brine purification muds from
mercury cell chlorine production
KI06 ---
Wastewater treatment sludge from
mercury cell chlorine production
Page 10
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
No. SFC material is not from this industry. Also it is
present primarily as an accessory metal in uranium ores
and concentrates, which are not listed waste sources.
MOLYBDENUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
P List
NONE
NONE
NICKEL
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
P List
NONE
P073
Nickel carbonyl
P074
Nickel Cyanide
POTASSIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
NONE
P098
Potassium
cyanide
P099
Potassium silver
cyanide
Non-Specific
Sources
F List
NONE
Non-Specific
Sources
F List
FOO6
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
---
NONE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
Electroplated nickel coatings, reagent
chemical
Metallurgy, electroplating
---
Wastewater treatment sludge from
electroplating
NONE ---
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
F List KList
---
Extraction of gold and silver from ores,
reagent in analytical chemistry,
insecticide, fumigant, electroplating.
Silver plating, bactericide, antiseptic.
NONE
K161 Dithiocarbamate production
Metam-sodium
Purification solids, baghouse dust
and sweepings form
dithiocarbamate production.
Page 11
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No K Listings
RADIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
NONE
NONE
SELENIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
U204
Selenious acid
or
selenium dioxide
U205
Selenium sulfide
or selenium
disulfide
PI03
Selenourea
P114
Selenious acid
dithallium salt,
Selenious acid
dithallium salt,
Thallium
selenide,
Thallium
selenite,
Ancimidol
NONE
SILVER
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
---
NONE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Selenious acid and its salts are used for
cold blackening of metal parts for model
building and decorative finishes.
Preparation of topical dennal and scalp
medications.
Production of dimethyl selenourea for
safety glass coatings
Selenious acid and its salts are used for
cold blackening of metal parts for model
building and decorative finishes.
---
NONE ---
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
Page 12
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
STRONTIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
NONE
NONE
THALLIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
U214
Thallium (1)
acetate
U215
Thallium (I)
Carbonate
U216
Thallium chloride
U217
Thallium (1)
nitrate
P114
Selenious acid
dithallium salt,
Thallium
selenide,
Thallium
selenite,
Ancimidol
P115
Sulfuric acid
dithallium salt
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
---
NONE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
High specific gravity solutions for ore
flotation.
Laboratory standard for analysis for
carbon disulfide, synthesis of artificial
diamonds.
Chlorination catalyst, sun lamp monitors.
Analytical standard, green-fire
pyrotechnics.
Selenious acid and its salts are used for
cold blackening of metal parts for model
building and decorative finishes.
Pesticide, ant-killer
---
Kl78 ---
Residues from manufacturing and
storage of ferric chloride from
acids from titanium dioxide
production
Page 14
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. SFC material is not from this industry. Also,
thallium is present primarily as an accessory metal in the
tantalum ores, which is not a listed waste source.
THORIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
PList
NONE
NONE
NONE
VANADIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
NONE
PI20
Vanadium
pentoxide
NONE
ZINC
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
P List
U249
Zinc phosphide
(10 wt. % orless)
PI21
Zinc cyanide
PI22
Zinc phosphide
(greater than I 0
wt. %)
P205
Zinc dimethyl
dithiocarbamate,
Ziram
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
---
NONE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
---
---
NONE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
Rodenticide
Metal plating, chemical reagent,
insecticide.
Rodenticide
Fungicide, accelerator in rubber synthesis.
---
KI61 Rodenticide
Ziram pesticides
Page 15
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No K Listings
Is This Listing Applicable to
SFC Sludge?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. SFC material is not from this industry. Also, zinc
is present primarily as an accessory metal in the
tantalum ores, which is not a listed waste source.
ZIRCONIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
PList
NONE
NONE
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN SFC DEWATERED SLUDGE
Specific Industrial Uses and Sources ofU or P
Sources Listed Element or Compound
KList
---
---
NONE
Page 16
Is This Listing Applicable to
SFC Sludge?
No U Listings
No P Listings
No F Listings
No K Listings
Technical Memorandum
To: David C. Frydenlund
Company: Denison Mines (USA) Corp.
From: Jo Ann Tischler
Date: December 15, 2011
Re:
CC:
Review of Chemical Contaminants in
Sequoyah Fuels Uranium Material to
Determine Worker Safety and
Environmental Issues and Chemical
Compatibility at the White Mesa Mill Project #:
1.0 Introduction
This report summarizes the characterization of the Sequoyah Fuels Corporation ("SFC")
Uranium Material (the "Uranium Material"), also referred to as the dewatered raffinate
sludge to be transported from the SFC Gore, Oklahoma facility, to determine whether
processing the Uranium Material at the Denison Mines (USA) Corp. ("Denison") White
Mesa Mill (the "Mill") may pose any worker safety or environmental hazards, or may be
incompatible with the Mill's existing tailings system. The results will provide information
to Denison to determine the requirements, if any, for changes to worker safety practices,
or potential incompatibilities to the Mill for the processing of Uranium Material as an
alternate feed material. This report will also provide comparison of constituents of the
Uranium Material and the Denison groundwater ("GW") monitoring program to identify
any constituents which are not covered under the Denison GW monitoring program and
whether these additional parameters need to be added to the sampling requirements.
The following questions were considered for the evaluation of potential safety and
environmental hazards and compatibility with the Mill's tailings system and GW
monitoring requirements:
1) Will any constituents of the Uranium Material volatilize at the known
conditions on the Mill site or in the Mill circuits? If so, will they create any
potential environmental, worker health, or safety impacts?
2) Will the Uranium Material or any of its constituents create a dust or off-gas
hazard at the known conditions on the Mill site or in the Mill circuit? If so, will
they create any potential environmental, worker health, or safety impacts?
3) Will any constituents of the Uranium Material react with other materials in the
Mill circuits?
4) Will any constituents of the Uranium Material create any impacts on the
tailings system?
5) Does the Uranium Material contain any constituents that are not present in
the current Mill GW monitoring program and not sufficiently represented by
the Mill's groundwater monitoring analyte list and need to be added to the
analyte list?
1
6) What, if any, limitations on feed acceptance criteria or added operational
controls are recommended in connection with processing the Uranium
Material at the Mill?
An evaluation of the regulatory status of the Uranium Material relative to the Resource
Conservation and Recovery Act ("RCRA") regulations is provided in a separate technical
memorandum.
2.0 Basis and Limitations of This Evaluation
The Uranium Material to be processed at the Mill consists solely of the dewatered
raffinate sludge currently stored on site at the Gore Facility.
The following contamination evaluation is based on:
The evaluation in this memorandum is based on information from the following sources:
1. SFC RCRA Facility Investigation Report ("RFI") (1997).
2. Current and historic SFC Uranium Material analytical data.
3. Interviews with Sequoyah Fuels personnel in March 2010.
4. Denison Protocol for Determining Whether Alternate Feeds Are Listed
Hazardous Wastes (Denison, November 1999).
5. Radioactive Material Profile record ("RMPR") for the SFC Uranium Material
(February 2010).
6. Basis of Hazardous Material and Waste Determinations from the RMPR
(February 2010)
7. Affidavit of John Ellis, SFC President (June 2010).
8. Current technical literature from the internet and other sources on performance of
liner materials
3.0 Site History and Background
The SFC Gore, Oklahoma facility (the "Facility" or the "Site") is a former uranium
conversion facility that operated from 1970 to 1993. The facility was constructed and
operated by SFC, as a subsidiary of Kerr-McGee Nuclear Corporation. In 1983 Kerr-
McGee Nuclear Corporation split into Quivira Mining Corporation and SFC, which
maintained control of the Gore Facility. SFC was sold to General Atomics Corporation in
1988 and continued to operate the facility until 1993.
From 1970 to 1993, the facility chemically converted uranium ore concentrates
(yellowcake) to uranium hexafluoride under U.S. Nuclear Regulatory Commission
("NRC") Source Materials License Number SUB-1 01 O. From 1987 to 1993, the facility
also converted depleted uranium hexafluoride into depleted uranium tetrafluoride in a
different circuit. The Uranium Material consists only of residuals from the conversion of
natural uranium yellowcake to uranium hexafluoride.
3.1 Description of Process which Generated the Uranium Material
This yellowcake conversion process included two primary purification steps: digestion
followed by solvent extraction. Digestion occurred by dissolving the uranium in nitric
2
acid. The resulting slurry was subjected to solvent extraction using tributyl phosphate
diluted with n-hexane. Process conditions were controlled to extract uranium into the
organic phase. The milling impurities remained in the aqueous phase, a dilute nitric acid
mixture termed raffinate.
The aqueous raffinate stream is primarily a solution of nitric acid, metallic salts, and
trace quantities of uranium and radioactive transformation products of natural uranium,
primarily Th-230 and Ra-226. The aqueous raffinate stream was combined with spent
sodium hydroxide from nitrous oxide scrubber systems and waste sodium carbonate
solutions. The untreated raffinate stream from solvent extraction was pumped to an
impoundment and allowed to cool. Anhydrous ammonia was added to the raffinate
solution to convert the dilute nitric acid to ammonium nitrate. The final treated raffinate
solution was stored in surface impoundments prior to use as an ammonium nitrate
fertilizer.
Generation of Raffinate Sludge
The addition of the anhydrous ammonia also increased the pH of the raffinate solution
causing the metallic salts and trace quantities of uranium, thorium, and radium to
precipitate and settle out in the impoundments as raffinate sludge.
Per the RMPR, the chemical reagents used in the above processes included:
• nitric acid
• tributyl phosphate
• n-hexane
• anhydrous ammonia
• barium chloride
• spent sodium hydroxide
• waste carbonate solutions
• recovered weak acids
The presence of residuals of some of these compounds and/or their reaction byproducts
would be expected in the Uranium Material, as discussed in the sections below.
The raffinate sludge was transferred by slurry to other storage ponds as necessary. The
raffinate sludge was accumulated and stored in several impoundments on site, including
Clarifier A basins and Pond 4. No other materials were combined with the stored sludge.
The raffinate sludge was eventually consolidated in the Clarifier A basins to support
decommissioning Pond 4 and dewatering of the raffinate sludge.
Treatment of Raffinate Solution Phase
The treated raffinate solution was decanted to another impoundment for further
treatment with barium chloride to remove trace levels of radium through co-precipitation.
The radium co-precipitate was periodically combined with the raffinate sludge in the
other impoundments.
Preparation and Packaging of Dewatered Sludge
3
The raffinate sludge was slurried from Clarifier A basins and processed through a 225
psi filter press to remove entrained water. The dewatered sludge was placed in one
cubic yard polypropylene bags. Approximately 11,000 tons (wet weight basis) or 5,000
tons (dry weight basis) or 11,500 bags are stored on site awaiting final recycling or
disposal.
4.0 Assumptions Regarding White Mesa Mill Processing of the Uranium Material
This evaluation was based on the following process assumptions:
1. The Mill will process the Uranium Material in the main circuit either alone or in
combination with natural ores or other alternate feeds.
2. The Uranium Material will be delivered to the Mill by truck in SuperSaks of
approximately 0.95 tons each, and approximately 21 bags per truckload. The
bags will be shipped in truck trailers with poly-lined bottoms and sides, either
box-style trailers, or flatbed style trailers with sidewalls and tarp covers.
3. The Supersaks will be unloaded from the trucks onto the ore pad for temporary
storage until the material is scheduled for processing.
4. The Uranium Material will be added to the circuit in a manner similar to that used
for the normal processing of conventional ores and other alternate feed
materials. It will either be dumped into the ore receiving hopper and fed to the
SAG mill, run through an existing trommel or grizzly, before being pumped to
Pulp Storage, or may be fed directly to Pulp Storage.
5. The Mill does not anticipate any significant modifications to the leaching circuit or
recovery process areas for the processing of the Uranium Material.
6. The Uranium Material may be processed in combination with other approved
alternate feed materials.
7. Tailings from processing of the Uranium Material will be sent to Cell 4A or Cell
4B or a comparable new tailings cell.
5.0 Chemical Composition of the Uranium Material
Physical and chemical properties of the raffinate sludge have been determined at
different times to support site characterization activities and treatability studies. The
results of those determinations were described in several reports prepared subject to the
authority of the State of Oklahoma Department of Environmental Quality and/or the NRC
in the process of site decommissioning, including the RCRA Facility Investigation Report
(RFI) and the Site Characterization Report (SCR).
SFC determined the list of constituents for analyses based on the US EPA May 1989
Interim Final RCRA Facility Investigation Guidance (the "RFI Guidance"). Analyses were
conducted for the constituents specified in the RFI Guidance for the mining industry, the
inorganic chemicals industry, and the non-ferrous metals industry, with the following
exceptions:
1. Analyses were performed for two additional metals, calcium and molybdenum,
beyond those listed in the RFI Guidance
2. Analysis was not performed for organochlorine pesticides. Pesticides were not
produced, stored in bulk, spilled or disposed at the Facility. Organochlorine
4
pesticides would only be present in site soils at residual levels typical of their
intended end use.
3. Samples were not analyzed for dibenzo(c,g) carbazole, dibenzo (a,h) pyrene,
dibenzo (a,i) pyrene and chloroacetaldehyde. None of these compounds were
produced, used or stored at the Facility nor are they breakdown products from any
chemicals used at the Facility.
The selection of constituents, numbers of samples, and characterizations enumerated
above were approved by and performed subject to the authority of the State of
Oklahoma Department of Environmental Quality and/or the NRC in the process of site
decommissioning. Characterization of the Uranium Material comprised nine analyzed
samples from the locations and conditions identified in Table 1.
The sampling was representative of a continuous process stream under the control of
the generator from a process which did not vary appreciably over time and was accepted
by the Oklahoma Department of Environmental Quality and the NRC as indicated by
these agencies' approval of the respective closure plan documents developed based on
the characterization. All analyses were performed by laboratories possessing State of
Oklahoma and/or NELAC certification for the analyses performed.
As a result, these studies provide sufficiently representative characterization to assess
the regulatory status, worker safety environmental hazards, and chemical and
processing properties of the Uranium Material.
5
dewatered filtrate would also contain 23,118 mg/kg of fluoride. This level is well within
the level present in other alternate feeds already approved for processing at the Mill,
such as the Fansteel alternate feed material, which contained concentrations ranging up
to 396, 000 mg/kg.
5.2.2 Metals
The three Uranium Material samples were analyzed for total metals, total alkali metals,
and total alkaline earth metals. According to the sampling results, 26 non-radioactive
metals and metalloids were present in the Uranium Material. These constituents can be
categorized based on their elemental characteristics and chemical properties as indicated
in Table 2.
Table 2: Classes of Metals in SFC Uranium Material
Class Component of the Uranium Material
Alkali Metals Lithium, Sodium, Potassium
Alkaline Earths Barium, Beryllium, Calcium, Magnesium,
Strontium
Cadmium, Chromium, Cobalt, Copper,
Transition Metals Iron, Manganese, Mercury, Molybdenum,
Nickel, Silver, Thallium, Vanadium, Zinc
Other Metals Aluminum, Lead
Metalloids Antimony, Arsenic, Selenium
With the exception of barium, all species listed in Table 2, above, are natural
constituents in uranium ores, are expected to be present in uranium concentrates
(yellowcake) processed at the Facility, and are expected to be present in sludges
precipitated from yellowcake impurities. Barium was introduced as barium chloride,
which was added to the raffinate solution for co-precipitation of radium.
The Uranium Material samples were not analyzed for their actual mineral composition,
that is, the compound form(s) in which each constituent is present. However, sufficient
process knowledge of the Facility process exists to reasonably assess the forms for
each constituents, as discussed under each class constituent, below.
Based on knowledge of the Gore plant process and pond treatment process, some
conclusions can be drawn about the mineral form of the metals identified in the
characterization analyses. These are discussed in the remainder of section 5.2.2 below.
None of the incompatibilities described below or in Table 3 are applicable to the
components as they will be present in the Uranium Material. None of the components
will be present in pure/reduced metal form or as pure metal oxides. None of the
fluoridated, sulfite, or cyanide, compound or hydroxylated (caustic forms) of the alkali
metals or alkaline earths are expected to be present. None of the components will be
exposed to any of the incompatible agents identified in the table.
Alkali Metals
The alkaline earths metals, lithium, sodium, and potassium are natural constituents in
uranium ores, are expected to be present in uranium concentrates (yellowcake)
8
processed at the Facility, and are expected to be present in sludges precipitated from
yellowcake impurities. All of the components are expected to be present in inert hydrate,
chloride, sulfate, or other soluble salt forms, compatible with the aqueous solutions in the
Mill's acid digestion and feed circuit. In addition, since all the constituents entered the
process in mineralized forms and were further reacted with mineral acids, none will be
present in pure or reduced metal form. Because the Uranium Material is approximately
pH neutral, none of the alkaline earths will be present in alkali hydroxide (caustic) forms;
all will have been precipitated as other salts or complexes. Since the pond materials are
wet or dewatered sludges that have not been fired or calcined, none of the alkaline
earths will be present as oxides.
Alkaline Earths
The alkali metals, beryllium, calcium, magnesium, and strontium, whether or not they
have been analyzed in specific ores processed at the Mill, are natural constituents in
uranium ores, are expected to be present in uranium concentrates (yellowcake)
processed at the Facility, and are expected to be present in sludges precipitated from
yellowcake impurities. E.g. strontium, while not specifically analyzed for in ores at the
Mill, is the 14th most abundant metal in the earth's crust and can be expected to be
present in natural soils, natural ores and product concentrates from natural ores. All of
the components are expected to be present in inert hydrate, chloride, sulfate, carbonate,
or other soluble salt forms, compatible with the aqueous solutions in the Mill's acid
digestion and feed circuit. Because the Uranium Material is approximately pH neutral,
none of the alkali metals will be present in hydroxides (caustic) forms; all will have been
precipitated as other salts or complexes. In addition, since all the constituents entered
the process in mineralized forms and were further reacted with mineral acids, none will
be present in pure or reduced metal form. Since the pond materials are wet or
dewatered sludges that have not been fired or calcined, none of the metals will be
present as oxides.
Barium is present as a result of the barium chloride added to the raffinate solution for co-
precipitation of radium prior to discharge at the Facility. Barium was used to form inert
non-reactive precipitates with radium.
Transition Metals
The transition metals, cadmium, chromium, cobalt, copper, iron, manganese, mercury,
molybdenum, nickel, silver, thallium, vanadium, zinc are expected to be present in
uranium concentrates (yellowcake) processed at the Facility, and are expected to be
present in sludges precipitated from yellowcake impurities. All of the components are
expected to be present in inert hydrate, chloride, sulfate, or other soluble salt forms,
compatible with the aqueous solutions in the Mill's acid digestion and feed circuit. In
addition, since all the constituents entered the process in mineralized forms and were
further reacted with mineral acids, none will be present in pure or reduced metal form.
Since the pond materials are wet or dewatered sludges that have not been fired or
calcined, none of the metals will be present as oxides.
Other Metals
The other metals, aluminum and lead are expected to be present in uranium
concentrates (yellowcake) processed at the Facility, and are expected to be present in
9
which comprises the Uranium Material because they were not anticipated to be present
above trace levels. The Mill has handled nitrate compounds in the Mill circuit and
tailings system with no adverse process, environmental, or safety issues.
Fluorides have been introduced into the Mill's circuit with natural ores and alternate
feeds at levels as high as 460,000 mg/kg. Fluorides were not analyzed in the dewatered
sludge which comprises the Uranium Material because they were not anticipated to be
present above trace levels. The Mill has handled fluoride compounds in the Mill circuit
and tailings system with no adverse process, environmental, or safety issues.
Ammonia was not analyzed in the dewatered sludge which comprises the uranium
material because it was not anticipated to be present above trace levels. Anhydrous
ammonia gas or high concentrations of ammonium hydroxide solutions are incompatible
with strong oxidizers, halogen gases, acids, and salts of silver and zinc. If trace
quantities of ammonia are present, they will not be present as anhydrous ammonia gas
or high concentration ammonium hydroxide and will not contact halogen gases at any
time in the Mill process. If traces of ammonia are present in the reactive form
(ammonium hydroxide) it will be at concentrations too low to react with the silver and
zinc already present in the Mill tailings, or with the moderate oxidizer that may be added
in the Mill acid leach circuit.
5.3.6 Organic Compounds
As discussed in Section 4.1, no semi-volatile compounds were detected in the Uranium
Material. The levels of two volatile organic compounds detected were so near the
practical quantitation limits that their detection was most likely due to laboratory
influences, not presence in the Uranium Material.
6.0 Potential Worker Safety Issues
The Uranium Material is expected to have an average moisture content of approximately
55 percent, which will minimize the potential for dusting. If required, normal dust
controls, including central vents to a scrubber system utilized at the Mill can be
implemented to minimize any worker exposure to dusts from unloading operations. In
addition, normal operations in this area require the use of worker personal protective
equipment for prevention of dust inhalation and skin exposure; therefore, normal worker
protections already in place will be sufficient to prevent exposure to any additional metal
oxides, sulfates, or nitrates during processing of the Uranium Material.
7.0 Radiation Safety
The Uranium Material is derived from natural uranium ores, or through contact of surface
or groundwater with these ores. The Uranium Material contains the same radionuclides
as natural ores; however the concentrations of the isotopes vary somewhat from natural
ores. The derived air concentrations, radiation protection measures, and emissions
control measures used for ores and other alternate feeds at the Mill are sufficiently
protective for the processing of the Uranium Material.
13
8.0 Potential Air Emissions Impacts
The introduction of a solid powder like the Uranium Material to any process may produce
two potential forms of air emissions: fugitive dusts, and/or hazardous gases.
Discussions in the previous sections demonstrate that engineering controls already in
place at the Mill will prevent the generation or dispersion of both of these types of
emissions. The Uranium Material will have a moisture content of approximately 55
percent, which will minimize dusting. In addition, the impurities will almost immediately
be converted to sulfates or other stable aqueous ionic forms, which are non-volatile and
produce no off gases.
Because the metals and ions in the Uranium Material are present at ppm levels, they are
not expected to generate a significant increase in load on the existing bag-house system
and air pollution control devices even if they reach the air control system as solids from
potential spills in the pre-leach area.
9.0 Potential Effects on Tailings System
9.1 Tailings Cell Liner Material Compatibility
The Uranium Material will be received as a moist solid filter cake from management of
aqueous pond materials at the Facility. A portion of this material may be insoluble in the
acid leach process at the Mill and therefore, the discharge sent to tailings may contain
some solid material ("sand"). The remainder of the Uranium Material will be soluble and
therefore be contained in the liquid phase after processing in the leach system. Tailings
from processing of the Uranium Material will be sent to one of two tailings cells at the
Mill, Cell 4A or Cell 4B or to a similarly designed new cell. The solutions from the
Uranium Material tailings will be recirculated through the Mill process for reuse. The
sands will be only a portion of the total mass of Uranium Material sent to the Mill from
the Site. However, assuming a worst case scenario that all of the solid material ends up
as sand in the tailings, it is estimated that for the main processing circuit, the additional
load to the tailings is minimal.
Cell 4A and 4B both have high-density polyethylene ("HOPE") liners. Cell 4A was
placed into service in October of 2008 and received conventional ore tailings sands and,
since July 2009, conventional ore tailings solutions. Cell 4B was authorized for use and
placed into service in February 2011, and has received conventional ore tailings
solutions. However, it can be assumed that over the life of these two tailings cells, each
will receive a comparable combination of tailings solutions and solids, from both
conventional ores and alternate feeds, as did tailings Cell 3. Hence, it is reasonable to
use known information on the composition of Cell 3, currently in the process of final
filling and closure, to represent the ultimate composition of either Cell 4A or 4B.
The constituents in the tailings sands and liquids resulting from the processing of
Uranium Materials are not expected to be significantly different from those resulting from
processing of conventional ores either in composition or in concentration of constituents.
Table 4 indicates that all of the constituents found in the Uranium Material have been
processed in the Mill's main circuit and/or the alternate feed circuit and are present in the
tailings system.
14
4. No constituent in the Uranium Material will raise the respective concentration in
tailings more than a fraction of a percent and, in some cases, the resulting
concentrations of constituents in tailings will be reduced.
5. There will be no significant incremental environmental impacts from the
processing of Uranium Material beyond those that are already anticipated in the
Environmental Impact Statements for the Mill.
6. Spill response and control measures designed to minimize particulate
radionuclide hazards will be more than sufficient to manage chemical hazards
from the constituents of the Uranium Material.
11
11.0 References
• Austin, G.T. Shreve's Chemical Process Industries, Fifth Edition. McGraw Hill.
New York 1984.
• Center for Disease Control, Toxicity Profiles, accessed at
http://www.atsdr.cdc.govlToxProfiles on 9/12/11
• Title 10 Code of Federal Regulations; Chapter I -Nuclear Regulatory
Commission, Part 40 -Domestic Licensing of Source Material: 40.4 -Definitions
(10 CFR 40.4)
• Title 10 Code of Federal Regulations; Appendix A -Nuclear Regulatory
Commission, Part 40 -Domestic Licensing of Source Material: 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 (10 CFR 40 Appendix A)
• Title 40 Code of Federal Regulations; Protection of the Environment, Part 261 -
Identification and Listing of Hazardous Waste: Subpart A, 261.4 -Exclusions:
Subpart B -Criteria for Identifying the Characteristics of Hazardous Waste and
for Listing Hazardous Waste.
• Gulec, S.B., C.H. Benson, and T. B. Edil, 2005. "Effect of Acid Mine Drainage on
the Mechanical and Hydraulic Properties of Three Geosynthetics", Journal of
Geotechnical and Geoenvironmental Engineering Vol. 131, No.8, ASCE, pp.
937-950.
• Mitchell, D.H., 1985. "Geomembrane Compatibility Tests Using Uranium Acid
Leachate", Journal of Geotextiles and Geomembranes, Vol. 2, No.2, Elsevier
Publishing Co., pp. 111-128.
• Notzl, H. Sequoyah Fuels Dewatered Tails Process Evaluation for Uranium
Recovery. October 8,2004
• US EPA Chemical Fact Sheets -accessed at www.epa.gov/chemfact on 10/6/10
• Sax, N. Irving and Lewis, Richard L. Sr. Hawley's Condensed Chemical
Dictionary, 11th Edition. Van Nostrand Reinhold. New York 1987.
18
Table 4 Comparison of Uranium Material to Tailings and Alternate Feeds
G H I
A C D Estimated F Cone. in Mill Increase in Mill Increase in Mill
Estimated B Cone. Range in Average Cone. in Mill E Mass in Mill Tailings after Tailings Cone. Tailings Cone. J
Average Cone. Estimated Mill Tailings before Tailings before Estimated Tailings after Uranium after Uranium after Uranium Cone. in Ores and
in Uranium Mass in Processing Processing Uranium Current Mass in Uranium Material Material Material Material Other Alternate Feed
Material (mg/L Uranium Uranium Material Material (mg/L Mill Tailings Processing Processing Processing Processing Materials (mg/L
Component or ppm)1 Material (tons)2 (mg/L or ppm)3A or ppm )38, 3C (tons)4 (tons)5 (ppm)6 (ppm)? (%)8 or ppm)9,10, 11
Aluminum (AI) 160,000 1,203.20 330-2,530 3,154 5,680 6,883.6 3,806 652.2 0.065 2,000-133,000
Antimony (Sb)'" 78.4 0.59 <20 20 36 36.6 20 0.2 0.000 0.01-120
Arsenic (As) 3,030 22.79 0.3-440 149 269 291.3 161 12.0 0.001 3.5-16,130
Barium (Ba)''' 4,150 31.21 0.021-0.1 28 50 81.6 45 17.1 0.002 21-43,000
Beryllium (Be) 18.7 0.14 0.347-0.78 1.00 2 1.9 1 0.1 0.000 1-105
Cadmium (Cd) 267 2.01 1.64-6.6 1.0 2 3.8 2 1.1 0.000 0.004-59,000
Calcium (Ca) 114,000 857.28 90-630 1,052 1,895 2,751.9 1,522 469.6 0.047 up to 217,000
Cobalt (Co) 133 1.00 14-120 83.0 149 150.5 83 0.2 0.000 9-350,400
Chromium (Cr)'" 605 4.55 1.0-13 24.0 43 47.8 26 2.4 0.000 8-16,000
Copper (Cu) 2,360 17.75 2,110-8,000 230 415 432.4 239 8.9 0.001 8-296,000
Iron (Fe) 164,000 1,233.28 1,080-3,400 2,608 4,697 5,930.3 3,279 671.1 0.067 up to 54,000
Lithium (Li) 2.67 0.02 1,080-3,401 17.2 31 31.0 17 -0.1 0.000 up to 810
Lead (Pb) 1,010 7.60 0.21-6.0 4 7 14.8 8 4.2 0.000 9-236,000
Magnesium (Mg) 7,190 54.07 1,800-7,900 4,938.00 8,893 8,947.4 4,947 9.4 0.001 1,020-43,400
Manganese (Mn) 1,930 14.51 74-222 444 800 814.2 450 6.2 0.001 172-3,070
Mercury (Hg) 1.41 0.01 0.0008-17.6 3.0 5 5.4 3 0.0 0.000 0.0004-14
Molybdenum (Mo) 10,700 80.46 0.44-240 143.0 258 338.0 187 43.9 0.004 12-17,000
Nickel (Ni)12 1,660 12.48 7.2-370 87 157 169.2 94 6.5 0.001 7-450,000
Phosphorus (P) 19,600 147.39 88.1-620 90.1 162 309.7 171 81.1 0.008 11,900-86,500
Potassium (K) 7,740 58.20 219-828 458.0 825 883.1 488 30.3 0.003 17-1,440
Selenium (Se)''' 348 2.62 0.18-2.4 1.0 2 4.4 2 1.4 0.000 0.02-710
Silver (Ag) 90.8 0.68 0.005-0.14 1.0 2 2.5 1 0.4 0.000 0.007-80
Sodium (Na) 7,480 56.25 1,400-10,000 5,828 10,496 10,552.5 5,835 6.9 0.001 up to 28,800
Detected in tailings, so
known to originate with
ores or other alternate
Strontium (Sr) 1,210 9.10 28,900-190,000 7 12 21.5 12 5.0 0.001 feeds,
Thallium (TI) 5,860 44.07 0.7-45 16 29 72.9 40 24.3 0.002 0.02-960
Vanadium (V) 1.6 0.01 136-510 264 475 475.5 263 -1.1 0.000 10-25,000
Zinc (Zn) 751 5.65 50-1,300 637 1,147 1,152.9 637 0.5 0.000 8-14,500
DRC Interrogatory , I .. Where Addressed in This .
Number· . Topic .ltegulatory ·Basis Document · Where Addressed in Other Documents' " . .,'
Environmental Analysis -Radiological and Section 1.0-1.4,2.3,2.5,4.1,
UAC R313-24-3-01AlOl Nonradiological impacts UAC R313-24-3 Attachment 5 ER Lic. App 3.1-3.10; ER Ce1l4B 9.0
ER Lic. App. 3.4.1-3.4.4, 3.5; Rec Plan 1.6; ER
Geology and Soils (Land) RG 3.8, Section 6.1.4.1 Section 4.1 Ce1l4B 6.0
ER Lic. App. 3.13.2.2, Figure 3.13-1; Dames
Exposure Pathways RG 3.8, Section 5.2.1 Section 4.1 and Moore 5.2; ER Ce1l4B 10.1
Liquid Effluents RG 3.8, Section 5.2.2 Section 4.1,4.6,4.8 Rec. Plan 2.2.3.2; Dames and Moore 5.2
GW Permit App. 2.6; Dames and Moore 2.7.4,
Airborne Effluents RG 3.8, Section 5.2.3 Section 4.1, 4.8 Dames and Moore 5.2
Direct Radiation RG 3.8, Section 5.2.4 Section 2.3,4.1,4.9,4.10 Dames and Moore 2.7.4
Effects of Sanitary and Other Waste
Discharges RG 3.8, Section 5.4 Section 4.1 Dames and Moore 5.4
Other Effects RG 3.8, Section 5.5 Section 4.1,4.2.2 Dames and Moore 5.5
NUREG-1620, Section
Hazard Assessment 4.3.3.1 Section 4.1, Attachment 4 GW Permit App. 2.6-2.7
NUREG-1620, Section
Exposure Assessment 4.3.3.2 Section 4.1 GW Permit App. 2.6-2.7
Accidents DG-3024, Section 6 Section 4.1, 4.2.3 ER Lic. App. 4.0
Mill Accidents Involving Radioactivity RG 3.8, Section 7.1 Section 4.1,4.4.1 ER Lic. App. 4.0
Other Accidents RG 3.8, Section 7.3 Section 4.1,4.2.3 ER Lic. App. 4.0
Summary of Annual Radiation Doses RG 3.8, Section 5.2.5 Section 4.1 ER Lic. App Tables 3.13-3, 3.13-4
Environmental Analysis -Impact on
UAC R313-24-3-01B/Ol Waterways and Groundwater UAC R313-24-3 Section 4.1, 4.6, 4.7 GW Permit App. 2.5-2.7; ER Ce1l4B 10.0
ER Lic. App. 3.7.1.1-3.7.1.3; Rec Plan 1.4.1-
Surface Water RG 3.8, Section 6.1.1 Section 4.1, 4.7 1.4.3, 1.7.5.5
Physical and Chemical Parameters (Ground
Water) RG 3.8, Section 6.1.2.2 Section 4.1,4.6, Attachment 4 GWDPTable2
UAC R313-24-3-01C/Ol Environmental Analysis -Alternatives UAC R313-24-3 Section 4.1, 4.14 ER Lic. App. 2.0-2.4
Alternatives to the Proposed Action RG 3.8, Section 10 Section 4.1,4.14 ER Lic. App 2.1, 2.4
Benefit -Cost Analysis RG 3.8, Section 11 Section 4.1,4.13 ER Lic. App. 5.0; Rec Plan Attachment C
UAC R313-24-3-01D/Ol Environmental Analysis -Long-Term Impacts UAC R313-24-3 Section 4.1,4.5.3,4.11 ER Lic. App. 5.0; ER Ce1l4B 14.0
Mill Decommissioning DG-3024, Section 8.1 Section 4.1,4.5.3 Rec. Plan 3.2.3,
Site and Tailings Reclamation DG-3024, Section 8.2 Section 4.1,4.5.3 Rec. Plan 3.2.1,3.2.2.;
Decommissioning and Reclamation RG 3.8, Section 9 Section 4.1,4.5.3 Rec. Plan Attachment A, 3.2.1, 3.2.2
DRC Interrogatory -Where Addressed in This ' .
, Number Topic '." llegulatory Basis -Document, ',Where Addressed in, Other Documents " " , .. • n
Decommissioning Plan for Land and NUREG-1620, Section
Structures 5.2.3 Section 4.1,4.5.3 Rec. Plan 3.2.1
Satisfied by ongoing compliance with mill
1 OCFR40.26( c )(2)-02/01 General License UAC R313-24-4 license
Satisfied by ongoing compliance with mill
10CFR40.31(H)-03/01 Application for Specific Licenses UAC R313-24-4 license
Corporate Organization and Administrative Satisfied by ongoing compliance with mill
Procedures DG-3024, Section 5.1 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Management Control Program DG-3024, Section 5.2 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Management Audit and Inspection Program DG-3024, Section 5.3 Section 4.1 , Section 4.12 license
Satisfied by ongoing compliance with mill
Qualifications DG-3024, Section 5.4 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Training DG-3024, Section 5.5 Section 4.1 ,4.4,4.10.2, 4.12 license
Satisfied by ongoing compliance with mill
Security DG-3024, Section 5.6 Section 4.1,4.12 license
Satisfied by ongoing compliance with mill
Quality Assurance DG-3024, Section 7 Section 4.1 license
Satisfied by ongoing compliance with mill
References DG-3024 Section 4.1 license
Satisfied by ongoing compliance with mill
1 OCFR40.4( c )-04/01 Terms and Conditions of Licenses UAC R313-24-4 Section 4.1 license
1 OCFR40.40.4 2 (K) (3 )(1)-Satisfied by ongoing compliance with mill
05/01 Expiration, Termination, Decommissioning UAC R313-24-4 Section 4.1 license
Satisfied by ongoing compliance with mill
10CFR40.61-06/01 Records UAC R313-24-4 license
1 OCFR40.65(A)(1 )-07/01 Effluent Monitoring Reporting Requirements UAC R313-24-4 Section 4.1 Rec. Plan 1.7.5.4
Mill Effluent Monitoring (Proposed
Operational Monitoring Program RG 3.8, Section 6.2.1.1 Section 4.1 Rec. Plan 1.7.5.4
Enviromental Radiological Monitoring
(Proposed Operational Monitoring Program) RG 3.8, Section 6.2.1.2 Section 4.1 Rec Plan 2.3.2.1 9 (c), (d); ER Ce1l4B 10.4
Meteorological Monitoring (Proposed Rec. Plan 1.1.1-1.1.3, 2.3.2.1(d), 1.7.5.6; ER
Operational Monitoring Program) RG 3.8, Section 6.2.3 Section 4.1 Ce1l4B 2.2
10CFR40.INTRODUCTIO Capacity of Tailings or Waste Systems Over
N-08/01 the Lifetime of Mill Operations UAC R313-24-4 Section 4.1,4.5.2 GW Permit App. 2.15.2.3
'nRC Interrogatory , Where Addressed 'in 'This "
Number' , To~ic· " ' ~egulatoi'y, Uasis" /'Ie", D()cument, " Where Ad4resse~ in, Qtherpocuments~ '7, ' , L
10CFR40APPENDIX A,
Introduction-09/01 Alternative Requirements UAC R313-24-4 Section 4.1 ER Lic. App 2.1-2.4
10CFR40 APPENDIX A, Permanent Isolation Without Ongoing
CRITERION 1-10/01 Maintenance UAC R313-24-4 Section 4.1,4.5.3 Rec Plan 3.2.3.1
NUREG-1620, Section
Slope Stability 2.2.3 Section 4.1,4.5.3 Rec Plan 3.3.6
NUREG-1620, Section
Settlement 2.3.3 Section 4.1,4.5.3 Rec Plan 3.3.6
NUREG-1620, Section
Liquidifacation Potential 2.4.3 Section 4.1,4.5.3 Rec Plan 3.3.6
10CFR40, APPENDIX A,
CRITERION 2-11101 Proliferation UAC R313-24-4 Section 4.1 Rec Plan 3.3.6
10CFR40, APPENDIX A,
CRITERION 3-12/01 Placement Below Grade UAC R313-24-4 Section 4.1 GW Permit App. 2.5 .1.5
10CFR40, APPENDIX A,
CRITERION 4-13/01 Location and Design Requirements UAC R313-24-4 Section 4.1 Rec. Plan 3.1
Site Location and Layout RG 3.8, Section 2.1 Section 4.1 Rec Plan 1.1, Figure 3.2-1; ER Lic. App 3.2
Site Area RG 3.8 Section 3.1 Section 4.1 Rec Plan 1.1, Figure 1-2, Figure 3.2-1
Geography DG-3024, Section 2.1.1 Section 4.1 Rec Plan 1.1-1.3
Land Use and Demographic Surveys (Land) RG 3.8, Section 6.1.4.2 Section 4.1 FES 2.5; ER Ce1l4B 3.0
Uses of Adjacent Lands and Waters RG 3.8, Section 2.2 Section 4.1 FES 2.5; ER Ce1l4B 3.0
ER Lic. App. Figure 3.9-1; FES 2.4.1.2; ER Cell
Population Distribution RG 3.8, Section 2.3 Section 4.1 4B4.0
Demography DG-3024, Section 2.1.2 Section 4.1 FES 2.4.1.2, 2.4.1.3, 2.4.2
Meteorology RG 3.8, Section 2.8 Section 4.1 Rec Plan 1.1,1.7.5.6; ER Ce1l4B 2.0
DG-3024, Section 2.2 Section 4.1 Rec Plan 1.1,1.7.5.6; ER Ce1l4B 2.0
RG 3.8, Section 6.1.3.1 Section 4.1 Rec Plan 1.1,1.7.5.6; ER Ce1l4B 2.0
Models (Air) RG 3.8, Section 6.1.3.2 Section 4.1 ER Lic App. 3.3.2
Geology and Soils RG 3.8, Section 2.5 Section 4.1 Rec Plan 1.6
DG-3204, Section 2.4.1 Section 4.1 Rec Plan 1.6
Seismology RG 3.8, Section 2.6 Section 4.1 Rec Plan 1.6.2.4, 1.6.2.5
DG-3024, Section 2.4.2 Section 4.1 Rec Plan 1.6.3,1.6.3.1, 1.6.3.2
NUREG-1620, Section Rec Plan 1.5.1.2,1.5.1.3, Figure 1.5-1,1.5-3;
Hydrological Description of Site 3.1.3 Section 4.1 ER Cell 4 B Appendix A
Surface Water (Hydrology) RG 3.8, Section 2.7.2 Section 4.1 GWDP I.F.10
DRC lnterrogatory ' '" .. Where Addressed in This '
'Number ' Topic Regul~tory Basis' Document· ,', Where Addressed in Other Documents , '" ' , " ,
DG-3024, Section 2.3.2 Section 4.1 GWDP I.F.I0
NUREG-1620, Section
Flooding Determinations 3.2.3 Section 4.1 GW Permit App. 2.13
Surface Water Profiles, Channel Velocities, NUREG-1620, Section
and Shear Stresses 3.3.3 Section 4.1 GW Permit App. 2.4
Ground Water (Hydrology) RG 3.8 Section 2.7.1 Section 4.1 Rec Plan 1.5.1.2, 1.5.1.3, Figure 1.5-1, 1.5-3
DG-3024, Section 2.3.1 Section 4.1 Rec Plan 1.5.1.2, 1.5.1.3, Figure 1.5-1, 1.5-3
Radiological Surveys RG 3.8, Section 6.1 Section 4.1 ER Cell4B 10.3-10.4
NUREG-1620, Section Section 4.1,4.5.1, Attachment
Site and Uranium Mill Tailings Characteristics 2.1.3 5 Rec. Plan 2.2
NUREG-1620, Section
Disposal Cell Cover Engineering Design 2.5.3 Section 4.5.3 GW Permit App. 2.7.2.4; Rec Plan 3.2.2.1
NUREG-1620, Section
Design of Erosion Protection Covers 3.5.3 Section 4.5.3 GW Permit App. 2.7.2.4; Rec Plan 3.2.2.1,3.3.5
UAC R313-24-4,
10CFR40, APPENDIX A, NUREG-1620 section
CRITERION SA(l)-14/01 Groundwater Protection Standards 4.2.3 Section 4.1, 4.6 GWDP LA Table 1, I.B, I.C Table 2, I.E
CRITERION SA(2)-IS/01 Liner UAC R313-24-4 Section 4.1,4.6 GWDP I.D.2, I.E.8 (c), I.E.7(f)
10CFR40, APPENDIX A, Exemption from Groundwater Protection
CRITERION SA(3)-16/01 Standards UAC R313-24-4 Section 4.6 Rec. Plan 2.3.1.1 (a)
10CFR, APPENDIX A,
CRITERION SA(4)-17/01 Prevent Overtopping UAC R313-24-4 Section 4.1 Rec Plan 2.2.3.1,2.2.3.2
10CFR APPENDIX A,
CRITERION SA(S)-18/01 Dikes UAC R313-24-4 Section 4.1 Rec Plan 2.2.3.1,2.2.3.2
10CFR APPENDIX A, Cover and Closure at End of Milling
CRITERION 6(1)-19/01 Operations UAC R313-24-4 Section 4.1,4.5.3 GW Permit App. 2.19
NUREG -1620, Section
Radon Attenuation 5.1.3.1 Section 4.1, 4.5.3 GW Permit App. 2.19; Rec Plan 3.3.2
NUREG-1620, Section
Gamma Attenuation 5.1.3.2 Section 4.1,4.5.3 GW Permit App. 2.19; Rec Plan 3.3.2
NUREG-1620, Section GW Permit App. 2.19; Rec Plan 3.3.6,3.3.8; ER
Cover Radioactivity Content 5.1.3.3 Section 4.1,4.5.3 Cell4B Figure 13
10CFR40, APPENDIX A,
CRITERION 6(2)-20/01 Verify Effectiveness of Final Radon Barrier UAC R313-24-4 Section 4.1,4.5.3 Rec Plan. 3.2, 3.2.3.1; GW Permit App. 2.19.4
10CFR40, APPENDIX A,
CRITERION 6(3)-21101 Phased Emplacement of Final Radon Barrier UAC R313-24-4 Section 4.5.3 Rec Plan. 3.2,3.2.3.1; ER Ce114B Table 5
'nRC Int,errogatory " ,Where Addressed'in'This '
" Number' Topic ", "" ,'R.egula,tory :Basis,' , ' ,Inoc'ument " Where Ad4ressed in, Other Uocuments'
10CFR40, APPENDIX A, Elevated Raduim Concentrations in cover
CRITERION 6(5)-23/01 Materials UAC R313-24-4 Section 4.5.3 GW Permit App. 2.19; Rec Plan 3.3.6,3.3.8
NUREG-1620, Section GW Permit App. 2.19; Rec Plan 3.3.6,3.3.8; ER
Cover Radioactivity Content 5.1.3.3 Section 4.1 ,4.5.3 Ce114B Figure 13
10CFR40, APPENDIX A, Concentrations of Radionuc1ides other than
CRITERION 6(6)-24/01 Radium in Soil UAC R313-24-4 Section 4.5.3 GW Permit App. 2.19; Rec Plan 3.3.5
Background Radiological Characteristics RG 3.8, Section 2.1 Section 4.1 Lie. App. 3.13.1; ER Ce114B 9.0
10CFR40, APPENDIX A,
CRITERION 6(7)-25/01 Nonradiological Hazards UAC R313-24-4 Attachment 5 Dames and Moore 3.3.1; ER Ce114B 9.0
Regional Nonradiological Characteristics RG 3.8, Section 2.11 Section 4.1 Dames and Moore 3.3.1; ER Ce114B 9.0
Concentrations of Nonradiocative Wastes RG 3.8, Section 5.3 Section 4.5.1, Attachment 5 Dames and Moore 3.3.1 ; ER Ce114B 9.0
10CFR40, APPENDIX A,
CRITERION 6A(l)-26/01 Completion of Final Radon Barrier UAC R313-24-4 Section 4.5.3 Rec Plan. 3.2,3.2.3.1; GW Permit App. 2.19.4
10CFR40, APPENDIX A,
CRITERION 6A(2)-27/01 Extending Time for Milestones Performance UAC R313-24-4 Section 4.5.3 Rec Plan. 3.2,3.2.3.1; GW Permit App. 2.19.4
10CFR40, APPENDIX A, Accepting Uranium Byproduct Material from
CRITERION 6A(3)-28/01 Other Sources During Closure UAC R313-24-4 Section 4.5.3 License Condition 9.11
10CFR40, APPENDIX A, Preoperational and Operational Monitoring
CRITERION 7-29/01 Programs UAC R313-24-4 Section 4.1 Rec Plan 2.3.2
10CFR40, APPENDIX A,
CRITERION 8-30/01 Effluent Control During Operations UAC R313-24-4 Section 4.1 GW Permit App. 2.15
Gaseous and Airbourne Particulate Materials DG-3024, Section 4.1 Section 4.1 GW Permit App. 2.15
Liquids and Solids DG-3024, Section 4.2 Section 4.1 GW Permit App. 2.15
Contaminated Equipment DG-3024, Section 4.3 Section 4.1 GW Permit App. 2.15
Sources of Mill Wastes and Effluents RG 3.8, Section 3.4 Section 4.4 GW Permit App. 2.15; Dames and Moore 3.3
Control of Mill Wastes and Effluents RG 3.8, Section 3.5 Section 4.4 GW Permit App. 2.15; Dames and Moore 3.4
Sanitary and Other Mill Waste Systems RG 3.8 Section 3.6 Section 4.1 GW Permit App. 2.15; Dames and Moore 3.5
Effluents in the Environment RG 3.8, Section 5.1.2 Section 4.1 GW Permit App. 2.15; Dames and Moore 3.3
Effluent Control Techniques DG-3024, Section 5.7.1 Section 4.1 GW Permit App. 2.15; Dames and Moore 3.3
External Radiation Exposure Monitoring
Program DG-3024, Section 5.7.2 Section 4.1 GW Permit App. 2.15
Airborne Radiation Monitoring Program DG-3024, Section 5.7.3 Section 4.1 GW Permit App. 2.15; ER Lie. App 3.3.2
Exposure Calculations DG-3024, Section 5.7.4 Section 4.1 Rec. Plan Attachment F
DRC Interrogatory Where Ad~ressed in' This
Number Topic ' .~egul~tory '~asis ' Document 'ii. Where Addressed in. Other Documents
Bioassay Program DG-3024, Section 5.7.5 Section 4.1 Rec Plan 3.2
Contamination Control Program DG-3024, Section 5.7.6 Section 4.1 Rec Plan 3.2
Airborne Effluent and Environmental GW Permit App. 2.9; Rec Plan 2.3; Dames and
Monitoring Programs DG-3024, Section 5.7.7 Section 4.1 Moore 3.3; ER Ce114B Appendix C
Groundwater and Surface Water Monitoring GWDP I.E, I.F; Rec Plan 2.3.1.1; ER Ce114B
Programs DG-3024, Section 5.7.8 Section 4.1 10.2
Control of Windblown Tailings and Ore'" DG-3024, Section 5.7.9 Section 4.1 Rec Plan 3.2.3.1
10CFR40, APPENDIX A,
CRITERION 8A-31/01 Daily Inspections UAC R313-24-4 Section 4.1 Rec Plan 2.3.2.2(a)
10CFR40, APPENDIX A,
CRITERION 9-32/01 Financial Surety Arrangements UAC R313-24-4 Section 4.5.3 Surety 2010
Financial Assurance DG-3024, Section 8.3 Section 4.5 .3 Surety 2010
NUREG-1620, Section
Maintaining Financial Surety 4.4.3(10) Section 4.5.3 Surety 2010
10CFR40, APPENDIX A,
CRITERION 10-33/01 Costs of Long-Term Surveillance UAC R313-24-4 Section 4.5.3 Surety 2010
Duty to Apply for a Groundwater Discharge
UAC R317-6-6.1-34/01 Permit UAC R313-24-4 Section 4.1, 4.6 GWDPIV.D
UAC R317-6-6.3-35/01 Groundwater Discharge Permit Application UAC R313-24-4 Section 4.1,4.6 GWDPIV
UAC R317-6.6.4-36/01 Issuance of Discharge Permit UAC R313-24-4 Section 4.1, 4.6 GWDPIV
UAC R317-6-6.9-37/01 Permit Compliance Monitoring UAC R313-24-4 Section 4.1, 4.6 GWDP III
Examination of Compliance and Monitoring NUREG -1620, Section
Program 4.3.3.4 Section 4.1,4.6 GWDP I.F.1
UAC R317-6-6.10-38/01 Background Water Quality Determination UAC R313-24-4 Section 4],4.6 GWDP I.B; ER Lic App. 3.7.3.2 (c)
Commencement and Discontinuance of
UAC R317-6-6.10-39/01 Groundwater Discharge Operations UAC R313-24-4 Section 4.6 GW Permit App. 2.19
UAC R317-6-6.12-40/01 Submission of Data UAC R313-24-4 Section 4.6 GWDP I.F.1
Reporting of Mechanical Problems or
UAC R317-6-6.13-41/01 Discharge System Failures UAC R313-24-4 Section 4.6 GWDP I.G; GW Permit App 2.15
UAC R317-6-6.10-42/01 Correction of Adverse Effects UAC R313-24-4 Section 4.6 GWDP I.G
NUREG-1620, Section
Corrective Action Assessment 4.3.3.3 Section 4.6 GWDPI.G
UAC R317-6-6.10-43/01 Out-of-Compliance Status UAC R313-24-4 Section 4.6 GWDP I.G
Procedure When a Facility is Out-of-
UAC R317-6-6.10-44/01 Compliance UAC R313-24-4 Section 4.6 GWDP I.H
DRC Interrogatory Where Addressed in This ..
Number Topic Regula~ory ~a:sis Document
UAC R317-6-6.10-45/01 Groundwater Discharge Permit Transfer UAC R313-24-4 Section 4.6
Notes:
If not stated otherwise, section number refers to section in the license amendment application, not its attachments.
References:
GWDP -"Ground Water Discharge Permit UGW370004". July 14, 2011
ER Ce1l4B -"Environmental Report in Support of Construction Tailings CeIl4B".
Revised and Resubmitted September 11, 2009
GW Permit App. -"Permit Renewable Application. State of Utah Ground Water
Discharge Permit NO. UGW370004". September 1,2009
Rec. Plan -"Reclamation Plan White Mesa Mill Blanding, Utah. Radioactive Material
License NO. UT1900479 Revision 4.0". November 2009
ER Lic. App. -"White Mesa Uranium Mill License Renewal Application. State of Utah
Radioactive Materials License No. UTI 900479". Volume 4 of5 (Environmental Report).
February 28, 2007
Dames and Moore -"Environmental Report. White Mesa Uranium Project. San Juan
County, Utah for Energy Fuels Nuclear, Inc". Prepared by Dames and Moore. January 30,
1978
FES -"Final Environmental Statement related to operation of White Mesa Uranium
Project. Energy Fuels Nuclear, Inc". May 1979.
Surety 2010 -"Revised Cost Estimates for Reclamation of the White Mesa Mill and
Tailings Management System". November 232010.
License Condition -"Utah Department of Environmental Quality Division of Radiation
Control Radioactive Material License". License #UTI900479. June 2010
Where Addressed in Other Documents·
GWDPIV.L