DRC-2018-006521 - 0901a06880866cf1

DRC-2018-006521 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

July 5, 2018

Sarah Fields
Program Director, Uranium Watch
P.O. Box 1306
Monticello, UT 84535
RE: Response to Email dated June 22, 2018
Vanadium Processing at the White Mesa Mill

Dear Ms. Fields:
The Division of Waste Management and Radiation Control has completed its review of your June 22,
2018 email wherein you asked two questions regarding vanadium recovery at the White Mesa Uranium
Mill. The Division provides the following responses. Question #1 has two parts while Question #2 has
only one part.
Question 1, Part 1: The processing of the effluents for vanadium would put additional chemicals into
the waste stream going back into the ponds.
Division Response: According to the 2007 Radioactive Material License Renewal application, Volume 1, Sections 4.1.10 and 4.1.11, the White Mesa Mill uses the same processes and chemicals for
both uranium and vanadium recovery.

Question 1, Part 2: The liquid effluents that would be processed for vanadium only currently fall under the definition of 11e.(2) byproduct material. They are not defined as "ore." The definition of 11e.(2) byproduct material is the wastes from the processing of ore for its source material content.
Considering that the effluents are not ore and they will not be processed for their source material
content at the Mill, how will the waste stream from the processing of the effluents for vanadium be legally defined, pursuant to the Atomic Energy Act and Nuclear Regulatory Commission (NRC) and Environmental Protection Agency?
(Over)

Division Response: As documented in Section 2.4.1.4 of the 1978 Environmental Report for the White Mesa Uranium Project, the uranium ores found in the Morison Formation of the Colorado Plataea also
have recoverable concentrations of vanadium. You are correct that the vanadium in the solution would
be considered 11e.(2) byproduct material. However, recovering vanadium does not change the 11e.(2)
byproduct material designation of the process fluid and tailings sands because the primary purpose of
processing the ore was for uranium (i.e., source material). Vanadium recovery is a secondary purpose. The Nuclear Regulatory Commission (NRC), in its NUREG 0706 Vol. III, Final Generic Environmental
Impact Statement on Uranium Milling Pgs. T-7 and T-8, recognized vanadium recovery as a secondary
purpose when it referred to the recovered vanadium as byproduct material from the uranium recovery
process at the White Mesa Mill.
Question 2: Was the processing of the mill liquid effluents for vanadium (without accompany removal
of uranium) ever evaluated in any of the Mill's environmental assessments?

Division Response: Yes. Vanadium recovery has been evaluated in the White Mesa environmental
assessments. Two examples are the 1978 Environmental Report for the White Mesa Uranium Project and the NRC’s NUREG-0706, Final Generic Environmental Impact Statement on Uranium Milling.

If you have any questions, please call Ryan Johnson at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/RMJ/ka

c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department Scott Hacking, P.E., DEQ District Engineer