DRC-2005-001121 - 0901a0688080cc71

JoN M. tlsMAN, rR
GARYHERBERT
Lieutenant Govemor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
November 18,2005
David C. Frydenlund, Vice President and General Council
International Uranium (USA) Corporation
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Subject: Radioactive Materials License llT l9OO479: Review of the July 1 through December 31,2004,
Semi-Annual Environmental Monitoring Effluent Report for the White Mesa Uranium Mill,
International Uranium (USA) Corporation
Dear Mr. Frydenlund:
On March l,2}}5,Intemational Uranium (USA) Corporation (ruSA) transmitted the July I through December
31,2004, Semi-Annual Environmental Monitoring Effluent Report for the White Mesa Uranium Mill to the
Division of Radiation Control (DRC) for review. Except for the Groundwater Monitoring which was reviewed
separately; this letter presents the results of this review with respect to past data and license requirements.
Gas Stack EfIluent Monitorine
The system was in standby during this reporting period and no effluent gas stack sampling occurred.
Air Particulate Sampline
All air particulate sampling results for the reporting period were less than the concentrations specified in the
radioactive materials license and l0 CFR Part 20, Appendix B and no adverse trends were identified.
Direct Radiation
Ambient gamma exposure rates were below the 10 CFR 20.1301 limits required by the license.
Environmental Radon
Section 2.1 of the effluent report states that instead of direct measurement of the radon-222 flux at the facility
boundaries using TLDs, "computational methods" are used to demonstrate compliance with the requirements of
10 CFR 20.1302 (b) (1). This could not be verified since the effluent monitoring report did not include this
data. Mill personnel confirmed that the effluent monitoring report did not contain this data since the data is part
of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) report.
The DRC requests the licensee provide the "computational methods" that are used to demonstrate compliance.
In addition, the DRC request's that future Semi-Annual Effluent Monitoring reports include the data, data
calculations, and a discussion ofthe results.
168 North 1950 West . PO Box 144850 . Salt lake City, UT 841 14-4850 . phone [phone]. fax [phone]
T.D.D. (801) 5364414. www.deq.unh gov
Page2
Soil Monitorine
S"-pt" t""rtts f"r the reporting period were comparable to those taken in prior years and indicated no adverse
trends.
Vegetation Monitoring
Sample results for the reporting period were comparable to those taken in prior years and indicated no adverse
trends.
Surface Water Monitorins
The analytical results from surface water samples collected in Cottonwood Creek during this reporting period
remained consistent with prior sampling events.
The Westwater Creek remained dry during 2004, therefore no samples were required by the License.
Groundwater Monitoring
As stated previously, the groundwater monitoring reports are transmitted separately in accordance with the
Groundwater Discharge Permit UGW370004.
Conclusions
Based upon DRC review of the White Mesa Mill, Blanding Utah, Semi-Annual Effluent Monitoring Report for
the period of July 1,2004 through December 31,2004, the DRC concludes that the environmental ictivities
presented in the report are in accordance with license requirements. The DRC has determined that the licensee
had collected the required environmental monitoring samples as specified in the license. The environmental
monitoring sample results included in the report were lower than the effluent release limits specified in the
license, and no adverse trends were apparent when compared to past data.
In addition, the DRC would propose a change to the environmental effluent monitoring requirements. Based
upon review of the many years of the analytical results of the vegetative sampling andihe Aifficutty in obtaining
sufficient vegetative material for samples, especially during drought conditions, the DRC would piopose thatIUC entertain the replacement of vegetation sampling with the addition of two new air-monitoring stations. As
identified on the facility diagram attached to this letter, the two proposed locations are downwind from the millin the prevailing wind direction. These two locations would identify and quantify any airborne particulates
from the tailing ponds or from the ore storage pad.
Finally, the DRC requests the licensee submit the "computational methods" used and how compliance is
demonstrated with these calculations, and a response to our proposal regarding the two air monitoring stations.Also, the DRC requests future Semi-Annual Effluent Monitoring reports include the computational riethod,
data calculations, and a discussion of the results. If you have any questions or comments, please contact me at(801) s36-42s0.
Sincerely,
{i/,L
'John Hultquist
LlWUranium Mills Section Manager
JIVCMIVch
Attachment
CC: Ronald E. Berg,International Uranium (USA) Corporation
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,o* r. )'MAN, rR.
Governor
GARY HERBERT
Lieutenant Governor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
TO:
FROM:
DATE:
File
Dean Henderson
April26,2005
MEMORANDTIM
4ft Ouarter 2004
MWl4 at0.066mgll-
NIWI5 at0.0440mgtL
SUBJECT: State of Utah Radioactive Material License No. UT1900479
International Uranium Corporation (ruC)
White Mesa Mill, Blanding, Utah
Semi-Annual Effluent Monitoring Report for 3'd and 4ft Quarter 2004
Groundwater Monitoring
This is a review of the groundwater monitoring data reported for the Semi-Annual Effluent Monitoring
Report for 3'd and 4e Quarter 20&1.
Miss Transposed Data
Potassium (K) concentration reported in Laboratory Analytical Reports (LAR) for monitor well MW5 for
both the 3'd and4fr quarters of 2OO4 were transposed incorrectly to Table V in the Report. The LAR for
MW5 for the 3'd quarter reported a K concentration of 7270 ug/L and transposed it toTable V (converting
from uglt- to mg/L) as 72.70 mg/L and should be7.2O7 mglL. The LAR for MW5 for the 4ft quarter
reported a K concentration of 8830 ug/L and transposed it to Table V (converting from ug/L to mg/L) as
88.30 mgll- and should be 8.830 mgtL 4h Quarter 2004.
Elevated Uranium Concentrations
Elevated uranium concentrations that exceeded the Utah groundwater quality standard of 0.030 mg[L:
3'd Ouarter 2004
NrWl4 at0.066mgtL
MW15 at0.0440mg[-
Duplicate Sample
I\{W13A is a duplicate groundwater sample for monitor well MWl1. Comparing the data for MWl1 and
168 North 1950 West. Po Box 1u14850. Salt Lake City, UT 84114-4850. phone (801) $6-a50. fax [phone]
T.D.D. (801) 5364414. www.deq.utah.gov
Page 2
MW13A for the 3'd quarter 2004 chloride, potassium, nickel, and uranium were within l07o (nickel and
uranium were below detection levels); for the 4e quarter 2004 chloride and potassium were greater than
20Vo (20.I and 31.9 Eo rcspectiyely), and nickel and uranium were below detection levels. The above data
is presented in a Table attached to this memorandum. In addition, there is no QA/QC Summary Report for
the groundwater analysis for the 4h quarter 2004.
Conclusions and Comments
IUC needs to be informed of incorrectly transposing K concentrations from the LARs to tables in the
Report.
Elevated uranium concentrations exceeding the Utah gtoundwater quality standard (UGQS) in monitor
wells MWl4 and MWl5 is a concern. In feature groundwater monitoring events continue to show uranium
concentrations exceeding the UGQS in these or other wells corrective action may be in forced.
IUC needs to submit the missing QA/QC Summary Report for the groundwater analysis for the 4fr quarter
2C[,4.ln addition, give an explanation why the grcater than20%o difference in concentrations for chloride
and potassium in the duplicate sample (MW13A) for MW11 for the 4ft quarter 2004 sampling event.
It should be noted that feature Semi-Annual Groundwater Effluent Monitoring Reports will follow the
reporting requirements in the IUC Groundwater Discharge Permit (Permi| Permit No. UGW3700M. This
Permit was in force as of March 8, 2005.
F:\IUC\effluent.doc
IUC Groundwater Analysis
Semi-Annua! Effluent Report
Compare Duplicate Samples
Duplicate
Parameter Well
with in %(ms/l)MWl1 *MW13A
3rd Quarter
Chloride 34.2 33.3 2.6
Potassium 7.27 6.56 9.8
Nickel <0.05 <0.05
U-Nat <0.001 <0.001
4th Quarter
Chloride 29.5 20.1 31.9
Potassium 7.69 9.29 20.8
Nickel <0.05 <0.05
U-Nat <0.001 <0.001
of