DRC-2012-002657 - 0901a06880346354

State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
December 4,2012
Harold Roberts
Executive Vice President and Chief Operating Officer
Energy Fuels Resources (USA) Inc
S.^tiZiS"° DRC-2012-002657
Subject. Comments from Review of "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 authonze processing of Sequoyah Fuels Corporation, Inc
('SFC') alternate feed matenal ('Uranium Material')" dated December 15, 2011
Dear Mr. Roberts.
The Division of Radiation Control (DRC) along with its consultant URS Corp , has reviewed the
formerly Denison Mines (USA) Corp , license amendment application identified above requesUng
authority to process alternate feed matenal (Uranium Material) from Sequoyah Fuels Corporation,
Inc at the White Mesa Uranium Mill The following comments and requests for additional
information have resulted from this review
GENERAL COMMENTS
1. Specific comments stated below address the Applicant's repeated statements that the
Uranium Matenal proposed to be processed in the White Mesa Mill has charactenstics that
are within the envelope of matenal characteristics previously authorized to be processed at
the Mill
a. Once the specific comments stated below have been addressed, please review and
evaluate the conectness of conclusions stated throughout the text of the
amendment application that "previously accepted or authorized analyses, plans,
programs, procedures, practices, equipment, etc need not be extended or revised
Justify each new conclusion To the extent necessary, extend or revise previously
accepted or authorized analyses, plans, programs, procedures, practices, equipment,
etc and submit them for the Division's consideration and approval
b. Previously accepted or authorized analyses, plans, programs, procedures, practices,
equipment, etc. include (but are not necessarily limited to) the following
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 2A\ 14-4850
Telephone [phone] • Fax [phone] -TDD [phone]
www deq Utah gov
Printed on 100% recycled paper
Page 2
• " there will be no incremental public health, safety or environmental impacts
over and above previously licensed activities" stated on Page 9 of the Amendment i
Request
• " there are no anticipated impacts to the environment above those already
anticipated in the existing environmental statements and environmental
assessments associated with the Mill's approved license " stated on Pages 9
and 13 of the Amendment Request
• " there will be no sigmficant incremental radiological impacts associated with
transportation of Uramum Material to the Mill, over and above other previously
licensed ores and altemate feed materials at the Mill" stated on Page 11 of the
Amendment Request
• "Existing accident response and spill response procedures are therefore sufficient
for management of potential transportation accidents or spills of the Uranium
Material " stated on Page 12 of the Amendment Request
• " the Uranium Material poses no additional hazards during transport above
previously licensed activities" stated on Page 12 of the Amendment Request
• " the receipt and processing of Uranium Material at the Mill will not have any
incremental impacts on groundwater over and above existing licensed operations"-^
stated on Page 16 of the Amendment Request
• " there will be no incremental [surface water] impacts over and above
previously licensed activities" stated on Page 17 of the Amendment Request
• "The existing air particulate momtonng program is equipped to handle all such
ores and altemate feeds" stated on Page 17 of the Amendment Request
• " the Uranium Material will therefore pose a comparable or lower gamma and
radon hazard as other ores and altemate feed materials that have already been
processed or licensed for processing at the Mill" stated on Page 17 of the
Amendment Request
• "Gamma exposure to workers will be managed in accordance with existing Mill
standard operating procedures" stated on Page 18 of the Amendment Request
• "Radon exposures to workers will be managed m accordance with existing Mill
standard operating procedures" stated on Page 18 of the Amendment Request.
• "The Mill can safely handle the Uramum Material in accordance with existing
Mill standard operating procedures" stated on Page 18 of the Amendment Request
• "Existing monitoring programs are therefore adequate and no new monitoring
procedures are required" stated on Page 19 of the Amendment Request
• " there will be no decommissioning, decontamination or reclamation impacts
associated with processing the Uranium Material, over and above previously
licensed Mill operations" stated on Page 19 of the Amendment Request
Several internal references appear, on the basis of pages presented in the amendment
request, to be inconect, either because the respective title pages are missing or the
Page 3
referenced material was not submitted Such is the case with internal references to
Attachment Dl Table 1, Attachment DlCii, Attachment Dlciii, Attachment Dlciv, and
Attachment E4a
Please correct these internal referencing problems in the revised amendment
request and submit currently missing referenced attachments (if any).
SPECIFIC COMMENTS
3a Reference Section 4.3 of the December 15, 2011 Apphcation for Amendment to
Authorize Processing of Sequoyah Fuels Corporation Altemate Feed Material
(Amendment Request)
Please define the range of time over which delivered Uranium Material might
remain in storage at the Mill within the SuperSaks, State how the integrity of the
SuperSaks might degrade over the time in storage and the increased potentialfor
radioactive releases with time. Estimate potential exposure of workers and the
environment due to the Uranium Material storage and from potential radioactive
releases from the storage area resulting from potential loss of integrity of the
Supersaks,
3b. Reference Sections 4.9 and 4 10 of the December 15, 2011 Amendment Request
Please clarify the intent of the statements in Section 4,9 of the Amendment
Request on gamma radiation and the discussion of radon and gamma impacts.
Comment on the levels of gamma emissions expected after Th'228 has
established equilibrium with Th'232,
3c. The radon discussion in Section 4.9 refers to radon-220, but the context indicates a
reference to radon-222 would have been more appropriate The gamma discussion
refers to Rn-226[sic], when the' intent appears to have been Rn-222 The
discussion of gamma emissions from the thorium decay series includes a reference
to Th-238[sic] and a statement that gamma emissions from the thorium series will
be low because of the disequilibnum between Th-232 and Th-228 While the
statement about the disequilibnum is conect when considering mill operations and
worker exposures, it is not true for longer term exposures from the tailings cell
Thorium-228 will essentially come into equilibnum with Th-232 within a few
decades The intent of the statements on gamma radiation emissions needs to be
clarified The potential gamma emissions from the tailings cell after Th-228 has
come into equilibrium with Th-232 needs to be discussed
Please provide information on expected gamma radiation and radon emission
rates from the Uranium Material as delivered to the White Mesa site in its
Page 4
existing form (contained in Supersaks), Demonstrate that such data support the
conclusions presented in Section 4.10 that gamma radiation levels and radon
levels associated with the Uranium Material are within levels associated with
other ores and alternate feed materials processed in the past or which the Mill is
or has been licensed to process.
3d Section 4 10 of the Amendment Request indicates that gamma-radiation and radon
levels associated with the SFC Uranium Material are within levels of gamma-
radiation and radon levels associated with other ores and altemate feed materials
processed or licensed for processing at the Mill in the past, and that gamma and
radon exposures to workers will be managed in accordance with existing Mill
standard operating procedures However, data for supporting those conclusions
could not be located in Denison's Amendment Request or the associated
attachments Prior information on these parameters obtained by SFC at the Gore,
Oklahoma facility, including projected or actual radon concentrations in the area
around the dewatered raffinate sludge materials stored in Supersaks at the
Sequoyah Gore facility dewatered sludge storage area is available and may fiilfill
this need (e g , see SFC 2004, SFC 2006, and NRC 2005 )
Reference Table 1 and the laboratory analysis reports in the "Radioactive Material
Profile Record, Dewatered Raffinate Sludge, February 2010" in Attachment 2 and
Attachment 4
According to the Radioactive Material Profile Record submitted by Demson, Th-
232 levels in the dewatered raffinate sludge (SFC Uranium Material) samples
tested by Outreach Laboratory ranged from 1,060 to 4,990 pCi/g Th-232 (weighted
average of 2,385 pCi/g)
Information in Abdelouas 2006, based on data from Momson 1991, NCRP 1993
and Cardarelli undated, allows the following comparison between the average
analytical results for uranium mill tailings from different locations in Utah (for
acid-leached uranium ores) and the SFC Uranium Material*
Analyte
Average Concentrations in
Uranium Mill Tailings or
Concentration Range in
Uranium Ores
Analytical Results of
Dewatered Raffinate Sludge
as Furmshed in Attachment 2
Th-230 Avg Concentration -873
pCi/g (32,300 Bq/kg)-
Monticello acid pile,
uranium mill tailings from
acid-leached ores)
16,200-74,400 pCi/g
Th-232 Concentration Range -0.2
to 2 2 pCi/g (8 to 80 Bq/kg)
- typical uranium ores
1,060 to 4,990 pCi/g
(weighted average of 2,385
pCi/g)
Page 5
ELI 2005 also reported the following analytical results for two samples obtained
frorn the SFC Uranium Material (dewatered sludge matenal) stored at the Gore,
OK SFC facility m July 2005
Analyte
Concentrations (Results reported on dry weight basis,
Received samples had -50% moisture content))
Th-230 30,900 pCi/g and 60,500 pCi//g)
Th-232 454 pC/g and 679 pCi/g
The above information suggests that concentrations of Th-230 and Th-232 in the SFC
Uranium Material appear to be elevated compared to their average level in Utah area
uranium mill tailings for acid-leached ores (likely typical of those that may have been
processed at the White Mesa Mill), and relative to the range of Th-232 levels found in
typical uranium ores, respectively. The same situation may occur relative to one or more
other altemate feed materials previously accepted and processed at the Mill The potential
for higher concentrations of Th-230 and Th-232 present in dust derived from the SFC
Uranium Material dunng processing and/or in dust from the resulting tailings to represent
a pathway for radiation exposures should be fiirther evaluated The implications of
potential exposures from these higher thorium concentrations (both Th-230 and Th-232) in
the SFC Uramum Material vsath respect to compliance with potentially applicable and
relevant personnel health criteria should be further assessed
Compare the range of Th'230 and Th'232 levels (in pCi/g) that could be expected
to occur in the SFC Uranium Material to the range of Th-230 concentrations
and Th'232 concentrations in Colorado Plateau uranium ores typical of those
that are accepted and processed at the Mill and/or that are present in typical
uranium mill tailings in the Utah region (e,g,, NCRP 1993; Abdelouas 2006;
Morrison 1991; Mei^ch 1963),
Provide information on specific additional radiological protection requirements
that may be implemented at the White Mesa Mill when processing the SFC
Uranium Material, including but not limited to, additional protections/controls
for limiting exposures to mill workers from increased radon emission and
associated radon daughter inhalation exposure levels [Note: The data in Table 1,
information provided in Attachment 2 furnished by Denison, and other available
data indicate that the SFC Uranium Material could have considerably higher
Th-230 and Th'232 levels than typical Colorado Plateau uranium ore-derived
uranium mill tailings in the Utah area and typical uranium ores, respectively
(e,g,, Abdelouas 2006; Morrison 1991; Meisch 1963; NCRP 1993; Cardarelli
undated.
3e Information in Abdelouas 2006, based on data from Momson 1991, allows the
following comparison between the average chemical composition of uranium rhill
Page 6
tailings from different locations in Utah (for acid-leached uranium ores) and the
SFC Uranium Material
Analyte
Average Concentration in
Utah area uranium mill
tailings
Analytical Results of
Dewatered Raffinate Sludge
as fumished in Attachment 2
As 74 ug/g 3,030 ug/g
Pb 158 ug/g 1,010 ug/g
Ba 1,010 ug/g 4,150 ug/g
Be Not Reported 18 7 ug/g
Information in Miesch 1963 (Tables 2 and 3) allows the following comparison between
typical (mean) chemical compositions of uranium ore from a uranium mine deposit and
mill pulp samples from over 200 mine sites on the Colorado Plateau and the SFC Uranium
Material*
Analyte
Average Concentration in
Colorado Plateau Uranium
Ores and Mill Pulp Samples
Analytical Results of
Dewatered Raffinate Sludge
as fiimished in Attachment 2
As 120 ug/g 3,030 ug/g
Pb 31-90 ug/g 1,010 ug/g
Ba 550 - 750 ug/g 4,150 ug/g
Be -03 0-04 ug/g 18 7 ug/g
Additionally, ELI 2005 also reported the following analytical results for two samples
obtained from the SFC dewatered sludge material stored at the Gore, OK SFC facility in
July 2005
Analyte
Concentrations (Results reported on dry weight basis,
Received samples had -50% moisture content))
As 1,370 ug/g and 1,470 ug/g
Page 7
Pb 101 ug/g and 165 ug/g'
Ba 190 ug/g and454ug/g^
Be 2 3 ug/g and 2 9 ug/g
Additionally, a sample of the raw raffinate sludge collected from Basin 1 of Clarifier A at
the Gore, Oklahoma facility in the RCRA Facility Investigation (RFI) contained 1,350
ug/g arsenic, 515 ug/g lead, 2,750 ug/g banum, and 4 12 ug/g beryllium.
The above information suggests that concentration of arsenic, beryllium, barium, and
(possibly) lead in the SFC Uranium Material appear to be elevated compared to Colorado
Plateau-derived ores that may have been processed at the Mill and/or present m uranium
mill tailings in the Utah area. The same situation may occur relative to one or more other
altemate feed materials previously accepted and processed at the Mill The implications of
elevated As, Be, and/or Pb levels in the Uranium Material compared to ores and other
altemate feed materials previously processed at the Mill and with respect to potentially
applicable and relevant personnel health criteria should be fiarther assessed
L Compare the range of concentrations of the following constituents that could
occur in the Uranium Material with reported ranges of concentrations of the
same constituents present in Colorado Plateau uranium ores typical of those that
are accepted and processed at the Mill and/or present in typical uranium mill
tailings in the Utah region (e,g,, Abdelouas 2006; Morrison 1991; Meisch 1963):
• Arsenic;
• Barium;
• Beryllium; and
• Lead,
ii Discuss and compare the range of concentrations of the constituents listed in
Specific Comment 2,c above in the Uranium Material to potentially
applicable/relevant RCRA hazardous waste/characteristic waste limits, EPA-
recommended Soil Screening Levels (SSLs), including updated recommended
Risk-Based Concentration (RBC) levels (e.g., EPA 2012) for various types of
soils issued by one or more EPA regional offices; relative to current, relevant
"action levels" establishedfor protecting workers from exposure to elevated
levels of constituents in air, such as beryllium, etc,,,; and/or other criteria as
may be appropriate.
' Note The reported values compare to a value of 1,010 ug/g Pb for a sample of the dewatered sludge reported in
Table 1 fumished by Denison
^ Note The reported values compare to a value of 4,150 ug/g Ba for a sample of the dewatered sludge reported in
Table 1 fumished by Denison
Pages
HL Assess radiological and non-radiological impacts of releases from the facility to
other media (including release through air to adjacent uncontrolled lands)
attributable to concentrations in Uranium Material in excess of those previously
authorized for receipt and processing at the White Mesa mill. Demonstrate that
the airborne effluent monitoring program is adequately designed and
implemented to ensure that acceptability of airborne releases to adjacent areas
will be known and reported,
iv. Discuss any additional requirements, activities, or measures that would be
implemented at the White Mesa Mill either during processing the Uranium
Material, or following its processing, due to potentially elevated concentrations
of arsenic, barium, beryllium, and/or possibly lead) compared to applicable and
relevant risk or health-based criteria (e,g,, ACGIH 8-hr average TL Vs or other
recommended action levels, as applicable) and/or compared to concentrations
typically present in uranium ores processed at the Mill and/or present in Utah-
area uranium mill tailings (Abdelouas 2006; Morrison 1991; Meisch 1963), For
example, evaluate and discuss the potential need for additional controls to limit
individual exposures to elevated arsenic, beryllium, lead, etc.levels that may be
present in dust that could be released from the SFC Uranium Material prior to,
during, or following its processing; the possible need for implementing more
aggressive air sampling and/or material surface sampling criteria for elements
such as beryllium and lead.
3f Section 6 0 of Attachment 4 indicates that" . One Uranium Material sample collected
dunng 1994 and one collected dunng 2003 were analyzed for RCRA TCLP constituents
No analyzed contaminant exceeded its respective TCLP threshold for RCRA toxicity
charactenstic as defined in Table 1 of 40 CFR Part 261 24(b) " However tlie sample
tested in 1994 using the TCLP procedures was apparently a sample of raw raffinate sludge,
not the dewatered raffinate sludge (Uranium Material) contemplated for processing at
White Mesa Additionally, the sample of Uranium Material tested in 2003 is not
descnbed, but appears to be sample ID MISC raff-filter press only leachate, SF03-278,
which was extracted using the '7-day Distilled Water Leachate Test Procedures" in Texas
Admimstrative Code (TAC) Chapter 335, Secfion 335 521 (d), rather than using the TCLP
procedure Because the extract derived from the 2003 dewatered sludge sample appears to
have been obtained using distilled water, the extract results cannot be directly compared to
TCLP regulatory levels (see also discussion below) The implications of using these
different test methods and the use of raw vs dewatered sludge sample, and the degree of
relevance of each set of test results with regard to comparison of the test results to TCLP
regulatory thresholds, and expected conditions at the White Mesa facility, need to be
clearly stated
Section 6 3 9 of NRC 2009 indicates the following* ". To demonstrate compliance with
10 CFR Part 40, Appendix A, Criterion 6(7), SFC addressed nonradiological hazardous
constituents of the byproduct matenal in the Draft Conective Actions Report (CMS),
dated October 27, 1997 In the CMS report. Section 2 5 and Tables 1 and 2 summarize
source and soil sampling results Treatability studies, including conducting the toxicity
characteristic leaching procedure (TCLP) extraction of sludges, were performed, as well as
Page 9
metal analyses Subsequent to the TCLP extraction, the results indicated that the raffinate
sludge [is] not charactenstically hazardous "
According to Table 1 m Appendix 2, the analytical results reported under the column
heading "Dewatered Sludge Leachate" are the result of testing using the "7-day Distilled
Water Leachate Test Procedures" included m Texas Administrative Code (TAC) Chapter
335, Section 335 521 (d) According to TAC Rule 335 507, the relevant "standard"
against which test results from such testing should be compared when assessing the
(in)solubility of a constituent is the applicable groundwater MCL for that constituent, as
listed in Table 3 of Appendix 1 of TAC Rule 335.521 (d)
The TCLP Procedure (Method 1311) is much more widely recognized and accepted than
the method (See TAC 2012) that was used (7-day Distilled Water Leachate Test
Procedures, TAC, Chapter 335, Section 335.521 (d)) for classifying the (in)solubility of
the dewatered raffinate sludge material based on the resulting leachate analytical results.
Rationale needs to be provided to support the test method that was employed, rather than
using the TCLP Procedure, since the latter procedure, for example, uses an acidic
extractant that is more representative of the acidic conditions that exist in the tailings
environment It therefore has not been demonstrated why the analytical data provided for
the "Dewatered Sludge Leachate" (6th column of Table 1 in Attachment 2) would be
considered representative of the conditions that the processed sludge material residuals
would be exposed to if the dewatered sludge were to be processed at the Mill
L Provide additional information regarding the selection of the test method used in
extraction testing of the SFC Uranium Material instead of using the Toxicity
Characteristic Leaching Procedure (TCLP) Method 1311, Discuss and qualify
the comparisons between analytical results for the dewatered sludge leachate
presented in Table 1 compared to applicable regulatory thresholds (e,g,, EPA or
Utah Drinking Water Standard MCLs vs, the TCLP Regulatory Levels that are
listed in Table 1), Revise the text in Section 6,0 of Attachment 4 to correctly state
the specific test methods that were usedfor analyzing each specific type of sludge
sample tested (e,g,, one TCLP test in 1994 on a raw sludge sample; Texas
Administrative Code 7-day distilled water leachate test in 2003 on a dewatered
sludge sample),
iL Perform TCLP testing using EPA Method 1311 for representative sample of
raffinate sludge material proposedfor processing at the White Mesa facility.
Demonstrate that the raffinate sludge material is not hazardous waste using
results of this additional TCLP testing. Submit results of this additional TCLP
testing for the Division *s considerations in demonstrating that the material is not
hazardous waste, and in demonstrating compliance with 10 CFR40, Appendix A,
Criterion 6(7) requirements relating to nonradiological hazardous constituents
present in the sludge materials,
HL Provide additional information to justify the appropriateness of using the
procedure in Texas Administrative Code (TAC) Chapter 335, Section 335,521 (d)
> for testing the Uranium Material, instead of using Method 1311, Toxicity
Characteristic Leaching Procedure, referenced in 40 CFR Part 261, Appendix II,
for classifying the SFC Uranium Material for potential processing at the MilL
Demonstrate that data from this testing of the SFC Uranium Material, which
Page 10
involved the use of distilled water as the extractant, would be considered relevant
and representative of the (acidic) liquid conditions that exist within the tailings
disposal cells at the Mill site,
iv. Provide additional information on appropriate regulatory threshold levels that
should be listed in Table 1 and used for evaluating/comparing the analytical
results as reported for the Dewatered Sludge Leachate and/or the "Dewatering
Filtrate" in Table 1;
V. Provide additional information on the specific analytical method and the nature
of any matrix involved in the analytical testing done with regard to the
"Dewatering Filtrate" results provided in Table 1,
3g The analytical report for the "Dewatering Filtrate" (5^ column of Table 1 in Attachment 2)
specifies "Other" as the matrix involved in the testing. From the information provided it is
unclear as to the specific testing method and/or specific charactenstics of any matrix that
was involved in this particular testing campaign Additional information needs to be
provided regarding these testing details to allow the relevance of the resulting data to the
proposed altemate feed processing request to be determined
Explain whether the holding time requirement specified in EPA SW-846for
mercury (28 days or less) having been exceeded for the analytical tests for
mercury completed on the "Dewatered Sludge", "Dewatering Filtrate", and
"Dewatered Sludge Leachate" (4^ through 6^^ columns of Table 1 in Attachment
2) invalidates these mercury test results. Alternatively, provide justification for
the acceptability of any of the reported mercury analytical results.
3h Footnotes in Table 1 of Attachment 2 indicate that the dewatered sludge samples were
obtained in May 2003 The analytical laboratory reports for mercury for this dewatered
sludge testing included in Attachment 2 also indicate that the samples were obtained on
May 1, 2003, but were submitted for laboratory analysis in October 2003 and were
analyzed for mercury content on 11/11/2003 This information indicates that the EPA
SW-846 (Chapter 3) -specified holding time requirement for mercury analyses of 28 days
or less was not met for the three mercury analytical results provided
Reference Table 4 in "Review of Chemical Contaminant m SFC Uramum Matenals to
Determine the Potential Presence of RCRA Characteristic or RCRA Listed Hazardous
Waste, December 15, 2011 in Attachment 5 and Sections 4 5 1 and 4.10 in the December
15, 2011 Amendment Request, and Attachment 4
Please correct or provide additional discussion of Table 4 in Attachment 5 and
correct errors or inconsistencies in information presented in that table. As a
result of any changes made to Table 4, please revise the conclusions in Section
4,5.1 (first paragraph, last sentence) of the amendment request and Attachment
5, Section 10,0, item 4, if necessary.
Page 12
compared to calcium, for conditions occumng at the White Mesa tailings Cells 4A and 4B
Kennedy et al (1992, Table 6 7), for example, lists a Kd value of 52 mL/g for barium
EPA 2012 (Section 4 11 and Exhibit C-4 of Appendix C) provides a range of
recommended Kd values for barium as a function of pH (e g , Kd = 52 mL/g at pH = 8 0,
Kd = 41 mL/g at pH = 6 8, etc , with Kd values decreasing with decreasing pH, the Kd
value at pH = 4 9 IS listed as 11 mL/g ) Allison 2005 referenced several citations reporting
soil/water Kd values of barium all less than 10 L/kg, and cited several risk assessment
studies that used IQ values ranging from 11 to 52 L/kg. By companson, the UDEQ
Statement of Basis for the Groundwater Discharge Permit indicates assumes Kd values for
calcium ranging from 5 to 100 L/kg (i e , equal to or higher than those reported in the
above references for barium)
Additionally, Energy Fuels Resources, Inc , has not provided information to descnbe or
substantiate how the mobilization behavior for barium that may be expected to occur in the
(e g , acidic) tailings and the near-field tailings embankment environment may differ from,
or be similar to, that of calcium. EPA (1984), for example, reported that barium, when
present in the form of barium sulfate in soils, is not expected to be very mobile because of
the formation of water-insoluble salts and its inability to form soluble complexes with
humic and fulvic materials, but noted, however, that, under acid conditions, some of the
water-insoluble banum compounds (e g., barium sulfate) may become soluble and move
into groundwater
Please provided information to describe or substantiate how the mobilization
behavior for barium that may be expected to occur in the (e,g,, acidic) tailings
and the near-field tailings embankment environment may differ from, or be
similar to, that of calcium.
If you have any questions please contact John Hultquist, at 801-536-4250
Sincerely,
Rusty Lundberg, Director
Utah Division of Radiation Control
RL/JHjh
Cc Jo Ann Tischler, Energy Fuels Resources, Inc
Page 11
3i Attachment 5, Table 4 appears to have many enors or inconsistencies Column C gives the
range of constituent concentrations and Column D shows the average concentration In
some cases, the average concentration m Column D is outside the range given in Column
C For example, the average cadmium concentration m Column D is lower than the
minimum value in Column C, while the average aluminum concentration is above the
maximum Coliunn C value
The percentages in Table 4, Column I appear inconect Footnote 8 explains that the
Column I values are meant to express the Column H values as percentages, but the
calculation is inconect For example, aluminum changes from 3,154 ppm to 3,806 ppm,
but the percentage change is shovm as 0 065% in Column I. If changes are made to Table
4, the conclusions in Section 4 5.1 (first paragraph, last sentence) of the amendment
request and Attachment 5, Section 10 0, item 4 (which state that processing the SFC
Uramum Material will affect the concentrations in the tailings by no more than a fraction
of one percent) need to be reassessed and revised if necessary
Reference Section 9.2 of Attachment 5 ("Review of Chemical Contaminants in SFC
Uranium Material to Determine Worker Safety and Environmental Issues and Chemical
Compatibility at the EnergyFuels Resources, Inc , White Mesa Mill")
L Provide additional information, including reference citations, to justify and
support the identification of an appropriate revised range of values of the
distribution coefficient (K^ for barium for representing conditions at the White
Mesa Mill Site, including the tailings environment in particular. Provide a -
discussion of how this revised range of barium K/s was used to assess the
potentialfor barium to impact groundwater beneath/downgradient of the tailings
cells into which processed SFC* raffinate sludge residuals would be placed,
iL Provide additional information and one or more reference citation(s) to support
the statement included in this section indicating that barium would be
sufficiently represented by monitoring (groundwater) for calcium,
HL Provide additional information regarding the need to add barium as an
additional monitoring parameter in the facility's groundwater monitoring plan,
especially given that, under acid conditions, some (otherwise) water-insoluble
barium compounds (e,g,, barium sulfate) may become soluble and move into
groundwater (e,g,, see US EPA, 1984), and given the Groundwater Quality
Standard value of 2 mg/l included in UACR317'006,
3j Section 9.2 of Attachment 5 ("Review of Chemical Contaminants in SFC Uranium
Material to Determine Worker Safety and Environmental Issues and Chemical
Compatibility at the Energy Fuels Resources, Inc , White Mesa Mill") includes a statement
that the distribution coefficient (IQ) for barium is 100 to 150,000 L/kg for sandy to clayey
soil types and that Energy Fuels Resources, Inc , therefore concludes that barium would be
less mobile in groundwater than calcium No reference sources are cited to support either
the Kd range stated or the conclusion made regarding the relative mobility of banum
Page 13
REFERENCES:
Abdelouas 2006 "Uranium Mill Tailings Geochemistry, Mineralogy, and Environmental
Impact,"inElements, Vol 2, pp. 335-341 December 2006 URL
http*//gnews wusXl edu/elements/e2 6/e2 6 art abdelouas pdf
Allison 2005 Partition Coefficients for Metals in Surface Water, Soil, and Waste U S.
Environmental Protection Agency, Office of Research and Development,
Washington, DC (EPA/600/R-05/074). July 2005 URL
http //www epa gov/athens/publications/reports/Ambrose600R05074PartitionC
oefficients.pdf
Cardarelli undated "Attachment 1- Occupational Exposure Assessment Modeling" to NIFC
(National Interagency Fire Center) Redbook, Radiation Document URL
http //www nifc gov/policies/red book/doc/RadiationDocument.pdf
ELI 2005
Kennedy 1992
Meisch, 1963
Morrison 1991
NRCP 1993
SFC 2004
SFC 2006
Energy Laboratory, Inc (ELI) July 19, 2005 Analytical Report for Two
Samples of Sequoyah Fuels Corporation Dewater Raffinate Sludge Material
(Note Samples tested had 50% moisture content, all analytical results were
reported on a dry weight basis).
Residual Radioactive Contamination from Decommissioning - Technical Basis
for Translating Contamination Levels to Armual Total Effective Dose
Equivalent Final Report, NUREG/CR-5512,PNL-7794, Vol 1 October 1992
NRC ADAMS Accession No ML05222031 Available at URL
http //www nrc gov/about-nrc/regulatory/decommissioning/reg-guides-
Comm/guidance html
Distnbution of Elements in Colorado Plateau Uranium Deposits - A
Preliminary Report U S Geological Survey Bulletin 1147-E U S
Government Pnnting Office, Washington, D C . 1963 URL
http //pubs usgs gov/bul/1147e/report pdf
"Mineralogical Residence of Alpha-Emitting Contamination and Implications
for Mobilization from Uranium Mill Tailings", m Journal of Contaminant
Hydrology 8 1-21
NCRP Report No 118. Radiation Protection in the Mineral Extraction
Industry August 1993.
Sequoyah Fuels Corporation 2004 Applicants Environmental Report for
Raffinate Sludge Dewatering Project Enclosure 1 to Amendment Request for
Raffinate Sludge Dewatenng Project (ADAMS Website. Accession No
ML0401504631), dated January 7, 2004
Sequoyah Fuels Corporation 2006 Sequoyah Fuels Corporation, Docket - 40-
8027 Request for Additional Information for Environmental Review of
Proposed Reclamation Plan Letter to NRC dated December 8, 2006 ADAMS
Website Accession No ML080180115
Page 14
TAC 2012 Texas Administrative Code (TAC) 2012 Title 30, Part 1, Chapter 335,
Subchapter R, Rule §335 507, et seq
EPA 1984 US Environmental Protection Agency (EPA) 1984 Health Effects
Assessment for Barium Prepared for the Office of Emergency and Remedial
Response, US Environmental Protection Agency, Washington, DC Cincinnati,
OH, US Environmental Protection Agency, Office of Health and
Environmental Assessment, Environmental Cnteria and Assessment Office
(EPA 540/1-86-021)
EPA 2012 Risk-Based Concentration Table - Genenc Tables, Mid-Atlantic Risk
Assessment URL* http.//www epa gov/reg3hwmd/risk/human/rb-
concentration_table/Generic_Tables/indexhtm
NRC 1992 US Nuclear Regulatory Commission (NRC) 1992 "Preparation of
Envirorunental Reports for Uramum Mills," Regulatory Guide 3 8, October
1992
NRC 2003 U S NRC 2003. "Standard Review Plan (NUREG-1620) for Staff Reviews of
Reclamation Plans for Mill Tailings Sites Under Title II of The Uranium Mill
Tailings Radiation Control Act", NUREG-1620, June 2003
NRC 2005 "Sequoyah Fuels CorporaUon - Matenals License No SUB-1010-
Environmental Assessment of Raffinate Sludge Dewatering Project (TAC
LU0061)" January 12, 2005 NRC ADAMS Website Accession No
ML050120184
NRC 2009 Final Safety Evaluation Report for the proposed reclamation plan for the
Sequoyah Fuels Corporation Site in Gore, Oklahoma, Matenals License No
SUB-1010, Docket No 40-8027, Sequoyah Fuels Corporation US Nuclear
Regulatory Commission, Office of Federal and State Materials and
Environmental Management Programs, April 20, 2009 NRC ADAMS
Website Accession No. ML090260323