DRC-2013-003361 - 0901a068803d0007

II DRC-2013-003361 n
GRAND CANYON TRUST
[e-mail]
via Certified U.S. Mail and Email
Re: Comments regarding Utah Division of Radiation Control's Proposed Licensing Action to
Amend State of Utah Radioactive Material License No. UT 1900479 to Authorize the Receipt and
Processing ofAlternate Feed Material from Dawn Mining Corporation's Midnite Mine.
Dear Mr. Lundberg:
The Grand Canyon Trust ("Trust") submits the following comments regarding Utah
Division of Radiation Control's ("Utah DRC") proposed licensing action to amend State of Utah
Radioactive Material License No. UT 1900479 to authorize Energy Fuels Inc. ("Energy Fuels")
to receive and process alternate feed material from Dawn Mining Corporation's Midnite Mine.
The Trust incorporates the technical comments of Jim Kuipers submitted on behalf of the Trust
into this document. As the following discussion indicates, the Trust is concerned that the
proposed license conditions do not adequately protect public and environmental health from the
hazards of fugitive dust from the Midnite Mine alternate feed material. The Trust looks forward
to working with Utah DRC to ensure that the conditions ultimately placed in License No. UT
1900479 protect public and environmental health to the maximum extent possible, and fully meet
the standards set forth in the Utah Radiation Control Rules.
I. Identity of Commenting Party
The Grand Canyon Trust is a non-profit corporation with offices in Flagstaff, Arizona,
and Moab and Salt Lake City, Utah. The mission of the Trust is to protect and restore the
Colorado Plateau - its spectacular landscapes, flowing rivers, clean air, diversity of plants and
animals, and areas of beauty and solitude. The Colorado Plateau includes the town of Blanding,
Utah, the White Mesa Mill site, and the larger area surrounding the site that is impacted by the
Mill's operation. One of the Trust's goals is to ensure that the Colorado Plateau is a region
characterized by vast open spaces with restored, healthy ecosystems, and habitat for all native
fish, animals, and plants. To accomplish this, the Trust advocates for adequate regulation of
existing industry across the Colorado Plateau. The Trust's board, staff, and members use the
Rusty Lundberg
Director
Utah Division of Radiation Control
PO Box 144850
Salt Lake City, Utah 84114-4850
[e-mail]
October 21, 2013
area that is impacted by the White Mesa Mill for quiet recreation (including hiking, biking,
fishing, rafting and camping), scientific research, aesthetic pursuits, and spiritual renewal. Many
of the Trust board, staff, and members live in Utah, and thus pollution in Utah adversely affects
their health, quality of life, recreational pursuits, and aesthetic sense. The Trust and its members
have a protectable legal interest Jn} ensuring that Utah DRC regulates the White Mesa Mill to the
maximum extent required, ^by, law. -,«' ^ x
II. The Existing Fugitive Dust Controls at the Mill Are Insufficient
A. The Fugitive Dust Controls Do Not Satisfy4he Best Available Control Technology Standard
In violation of the Utah Air QualitycRules, the Approval Order does not contain best
available control technology tb ebntropfngitive dust from the Mill. Utah Admin. Code R307-
401-8(1) states that the Director will issue an approval order if "the degree of pollution control
for emissions to include fugitive dust emissions and fugitive dust, is at least best available
control technology (BACT")". The Utah Supreme Court has found that if a control technology is
operating or permitted for similar operations, the permitting authority should consider the
technology available and consider it in its BACT analysis. Utah Chapter of the Sierra Club v.
Air Quality Board, 2009 UT 76 \ 46.
In 2011, Utah DAQ was presented with evidence of industry standards for controlling
fugitive dust that far exceed the controls currently in place at the Mill. In its comments on Utah
DAQ's Approval Order to Add a Baghouse, to Allow Alternate Fuel Usage, and to Incorporate
Work Practice Standards, DAQE-ANO 112050018-11, the Ute Mountain Ute Tribe submitted the
fugitive dust control plans for both the Moab Project and the Crescent Junction Project as
evidence of technology that should be considered as BACT in Utah DAQ's fugitive dust control
technology for the Mill.
Utah DAQ's subsequent unjustified decision to not adopt controls as stringent as those in
place at the Moab Project and the Crescent Junction project - both of which were demonstrated
as "available" by the Ute Mountain Ute Tribe - violates the BACT requirements, is basis for the
vacature of the Approval Order, and indicates the inadequacy - both legal and practical - of the
current fugitive dust controls in place at the Mill. The inadequacies of Utah DAQ's approval
order does not satisfy Utah's duty to implement the authority derived from the its Agreement
State authority. Technology properly identified as BACT must be required in order for License
No. UT 1900479 to be amended to allow receipt, storage, processing, placement, and permanent
disposal of the alternate feed materials from Midnite Mine.
B. The Fugitive Dust Controls Do Not Satisfy the Low As Reasonably Achievable Standard
The fugitive dust emitted from the Mill contains radioactive elements and thus risks
exposing the public to doses of radiation. Pursuant to Utah Admin. Code, each licensee "shall
use, to the extent practical, procedure and engineering controls based upon sound radiation
protection principles to achieve occupational doses and doses to members of the public that are
as low as reasonably achievable ("ALARA"). Utah Admin. Code R313-15-101(2). ALARA is
defined as:
"making every reasonable effort to maintain exposures to radiation as far below the dose
limits as is practical, consistent with the purposes for which the licensed or registered
activity is undertaken, taking into account the state of technology, the economics of
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improvements in relation to state of technology, the economics of improvements in
relation to benefits to the public health and safety, and other societal and socioeconomic
considerations, and in relation to the utilization of nuclear energy and licensed or
registered sources of radiation in the public interest." Utah Admin. Code R3013-12-3.
The ALARA standard is similar to the BACT standard in that both require regulators to
ensure available technologies are implemented. See Utah Chapter of the Sierra Club v. Air
Quality Board, 2009 UT 76 % 46. Where available technologies are actually being used at the
Moab and Crescent Junction Project sites that could reduce fugitive emissions, the current
fugitive dust controls in place at the Mill do not meet the ALARA standard. The use of more
stringent fugitive dust control plans at both the Moab Project Site (Attached as Exhibit 1) and the
Crescent Junction Project Site (Attached as Exhibit 2) indicate that emissions reductions based
on these technologies are "reasonably achievable" at the Mill. Utah Admin. Code R3013-12-3.
thus, it is incumbent upon DRC to perform a meaningful analysis of the benefit that requiring
similar technology would have on public and environmental health, and of the economics of
requiring such technologies to be instituted at the Mill. DRC's failure to do so thus far is a
violation of the Utah Rules designed to protect against radiation exposure.
III. Fugitive Dust From the Mill Threatens Public and Environmental Health
The U.S. Geological Survey (USGS) Scientific Investigations Report 2011-5231 ("USGS
Report") documents off site, downwind deposition of fugitive uranium dust emissions
originating from uncovered stockpiles at the White Mesa Mill. Exposure to those emissions and
that deposition by people, plants, wildlife and livestock threatens public health, safety and the
environment. By documenting deposition of fugitive dust from the mill, the USGS report
demonstrates that existing, ongoing operations of the White Mesa Mill lack requirements
necessary to protect public health, safety, and the environment from exposure to fugitive
uranium dust emissions and deposition originating from uncovered stockpiles at White Mesa
Mill.
The USGS Report documents elevated uranium in soil sediment and vegetation near the
mill. It reports "...U concentration(s) from the stream-sediment samples ranged from 1.5 to 16.2
parts per million (ppm). The highest U concentration measured in the local background samples
(fig. 31), which ranged from 1.8 to 3.6 ppm, was equaled or exceeded in 8 of the 28 stream
sediment samples." USGS Report at 51. It reports elevated uranium in big sagebrush located
near the White Mesa Mill; "U concentration in the plant-tissue samples from sagebrush ranged
from 1.3 to 171 ppm (dry weight)." USGS Report at 58. It reports elevated vanadium
concentration in plant tissue; vanadium (V) would expected to be present in Colorado Plateau
uranium ore delivered to the mill. USGS Report at 63. It reports "concentration in the plant
tissue samples ranged from 9 to 582 ppm (dry weight), and its spatial distribution in the plant
tissue samples was simi-lar to the U distribution." USGS Report at 63.
The USGS Report establishes that elevated uranium in soil and elevated uranium and
vanadium in vegetation is highest downwind of the White Mesa Mill, indicating that windblown
uranium ore is being transported and emitted off site from uncovered stockpiles onto downwind
land and vegetation. For big sagebrush samples, "[T]he highest concentrations of U were found
in plant tissue samples collected from regions north, south, and east of the mill site, and the
lowest U concentrations were found west, northwest, and southwest of the mill site" and "[P]lant
3
s
samples with elevated V concentrations consistently were found north-northeast east, and south
of the mill site, indicating offsite transport in the predominant wind directions." USGS 5231 at
58 and 63. The report continues:
Wind data collected from 2000 to 2008 at the Blanding airport (National Oceanic and
Atmospheric Administration, 2010), located about 6 km north of the mill, offers insight
into the likely U source for the observed spatial distribution of U in the plant tissue
samples (fig. 40). The predominant wind direction during the nine-year monitoring
period was from the south-southwest (SSW) at an azimuth of about 200 degrees (fig. 41).
This could explain the anomalous U concentra-tions detected in plant tissue samples
col-lected to the north and northeast of the mill site. Furthermore, some of the highest
wind speeds, exceeding 4 meters per second (m/s) were from westerly directions
(azimuth 200 to 340 degrees), providing an explanation for the anomalous U
concentrations east of the mill site with the predominant direction from the SSW (205
degrees). USGS Report at 58, 63.
Uranium fugitive dust emissions and deposition from White Mesa Mill to areas
downwind threatens public health, safety, and the environment. Potential human exposure
pathways to uranium and other contaminates emitted as fugitive dust include (1) inhalation of
uranium dust emitted from the mill, or deposited from the mill and re-mobilized through soil
disturbance or wind; (2) ingestion of water contaminated by uranium dust deposited in
ephemeral washes adjacent to the mill; (3) ingestion of meat from wildlife or livestock that
ingest uranium contaminated vegetation and soil near the mill.
Uranium fugitive dust emissions from White Mesa Mill also present exposure pathways
to wildlife. In its Scientific Investigations Report 2010-5024, USGS details biological pathways
of exposure and ecotoxicity values for uranium and associated radionuclides for the Colorado
Plateau near Grand Canyon, an area whose ecology and biological diversity is similar to lands
near White Mesa Mill. The report states that
"[T]he utilization of subterranean habitats (burrows in uranium-rich areas, burrows in
waste rock piles or reclaimed mining areas, mine tunnels) in the seasonally variable but
consistently hot, arid environment is of particular concern in the segregation areas.
Certain species of reptiles, amphibians, birds, and mammals spend significant amounts of
time in burrows where they can inhale or ingest uranium and other radionuclides through
digging, eating, preening, and hibernating. Herbivores may also be exposed though the
ingestion of radionuclides that have been aerially deposited on vegetation." USGS 5024
at 287.
Even non-uranium bearing fugitive dust threatens physical injury to the public as a cause
of chronic lung disease, asthma, and other lung related illnesses; a cause of hazardous conditions
on public rights of way; and a detractor of property values in areas nearby the emissions source.
Each of these problems associated with fugitive dust is magnified by the fact that the fugitive
dust in this case contains uranium, and thus poses an even greater threat to human and
environmental health - one that will endure on the Colorado Plateau for years to come.
The inhalation of U3O8 bearing fugitive dust has caused systemic toxicity that can result
in long-term damage to organs. See, e.g., MH Henge-Napoli, E Ansoborlo, M Claraz, J-P Berry
4
and M-C. Cheynet, Role of alveolar macrophages in the dissolution of two different industrial
uranium oxides in Cellular and Molecular Biology 42(3), 413-420,1996; GN Stradling, JW
Stather, SA Gray, JC Moody, M Ellender, A Hodgson, D Sedgwick, N Cooke Metabolism of
uranium in the rat after inhalation of two industrial forms of ore concentrate: the implications
for occupational exposure in Human Toxicology 6, 385-393,1987 (Measuring 12% U3O8 deposit
in lungs after 360 days following inhalation); H.B. Wilson, G.E. Sylvester, S. Laskin, CW.
LaBelle, J.K. Scott, H.E. Stokinger, Relation ofparticle size offyOs dust to toxicity following
inhalation by animals. ]nA.M.A. Archives of Industrial HealthW, 11-16,1955 (Documenting
kidney and lung damages associated with inhalation of small particle sized U3O8 dust).
The ongoing problem of off-site deposition of radioactive materials, particularly in light
of the adverse health effects of U3O8 exposure, confirms the need for DRC to address and
mitigate the off-site fugitive dust deposition problem documented in the USGS report.
Importantly, this problem will be exacerbated by Energy Fuels' proposal on how to handle the
alternate feed materials from the Midnite Mine. Thus, the License Amendment at issue here
represents an opportunity for Utah DRC to institute meaningful regulation and control of fugitive
dust at the Mill as required by Utah law.
IV. Standards
A. Utah Radiation Control Rules
The general purpose of Utah's Radiation Control Rules is "to ensure maximum protection
of the public health and safety to all persons at, or in the vicinity of, the place of use, storage, or
disposal." Utah Admin. Code R313-12-2. Adhering to these principles, the Director shall
approve an amendment to a radioactive material license if "the Director determines that... (b) the
applicant's proposed equipment, facilities, and procedures are adequate to minimize danger to
public health and safety or the environment.. .and (d) the issuance of the license will not be
inimical to the health and safety of the public." Utah Admin. Code R313-22-33 (standards
applied to license amendments by Utah Admin. Code R313-22-39). For this reason, the Utah
Rules give the Director the discretion to "impose upon a licensee or registrant requirements in
addition to those established in the rules that the Director deems appropriate or necessary to
minimize any danger to public health and safety or the environment." Utah Admin. Code R
R313-12-54. Moreover, each licensee "shall use, to the extent practical, procedure and
engineering controls based upon sound radiation protection principles to achieve occupational
doses and doses to members of the public that are as low as reasonably achievable ("ALARA").
Utah Admin. Code R313-15-101(2). Each of these standards governs Utah DRC's decision of
whether to amend Utah Radioactive Material License No. UT 1900479, and what controls to
require that the licensee institute, which includes the management of fugitive dust at the Mill.
A. Prior Fugitive Dust Standards Instituted at the Mill
To meet its ALARA standard of 1250 mrem per year, Denison instituted specific controls
to protect Mill workers, the general public, and the environment from unnecessary exposure
from alternate feeds stocks placed on the ore pad. Specifically, as part of the license renewal
process, Denison informed Utah DRC that it had instituted the following controls for fugitive
dust from alternate feed material with U3O8 content that exceeds that of Colorado Plateau-
derived ore: first, "[hjigh grade alternate feed materials typically with 1.0% U3O8 or greater are
usually received at the Mill and stored in drums or other containers;" second, "(alternate feed
5
materials that are received in bulk and that have higher risk of public or occupational exposure
than Arizona Strip ores such as may result from high radioactivity and/or fine dry particles
relative to Arizona Strip ores have been covered by less radioactive materials while stored on the
Mill's ore pad." Utah Division of Radiation Control, Safety Evaluation Report for the Denison
Mines White Mesa Mill 2007 License Renewal Application, October 2011 at 10. These two
control measures - neither of which allows for alternate feed material to be left uncovered on the
ore pad - are a component of fugitive dust control technology that should be considered ALARA
for the Mill.
V. The Characteristics of the Alternate Feed and Climate Conditions at the Mill Combine
to Necessitate Strict Fugitive Dust Control Measures
As a primary matter, the high uranium content of the alternate feed material increases the
threat to public and environmental health posed by off-site deposition of fugitive dust. The
alternate feed material contains a higher percentage of U3O8 than is present in Colorado Plateau
derived uranium ores. URS Professional Solutions, LLC, Safety Evaluation Report for the
Amendment Request to Process an Alternate Feed Material at White Mesa Mill from Dawn
Mining Corporation Midnite Mine, Washington State, August 2013 at 9 (hereinafter URS SER).
In typical Colorado Plateau-derived uranium ores, the range of U3O8 contents varies from .015%
to 0.30%. Id. at 10. The average U3O8 concentration of particularly high grade uranium mined
at the Arizona 1 uranium mine in the Arizona Strip averaged between 0.56% and 0.66%. Id. The
U3O8 of the alternate feed material is estimated to be 1.5%. Id. at 9.
The alternate feed material is vulnerable to wind blown deposition due to climate
conditions at the Mill Site. The climate in the vicinity of the Mill is semi-arid with annual
precipitation of approximately 12 inches, and a low average humidity. Id. at 16. Wind speeds at
the Mill average approximately 13 miles per hour with the prevailing wind blowing to the south
of the Mill. USGS Report at 64. High wind events of gusts over 25 miles per hour occur at the
Mill site. Denison Mines (USA), Environmental Report, February 28, 2007 at 16.
The affidavit of Robert Nelson - the Site Manage from the Dawn Mining Company -
does not consider the difference in climate and wind condition between the Pacific Northwest
and Southern Utah. Mr. Nelson's assertion that the alternate feed "is not prone to degrading to
fine dust sized particles" is unsupported by evidence, and does not account for the marked
difference in humidity, and wind speeds between the two sites. Indeed, even URS notes in its
Safety Evaluation Report for the Amendment that "weather conditions at the Mill Site are dryer
than at the Midnite Mine Site, and possibly higher wind speeds coupled with low humidity levels
may lead to differences in behavior of uranium material with regard to its susceptibility to
degrade to a finer dust sized particle than would be expected from ores or other alternate feeds."
URS SER at 16.
For this very reason, Utah DRC proposes to impose two license conditions that are
intended to control fugitive dust from the alternate feed. Radioactive Materials License Number
UT 1900479 Amendment #06 at 10.20. The first condition requires that "Dawn Mining Uranium
Material stored (stockpiled) at the Mill Site longer than 14 days shall be covered with a durable
geomembrane cover resistant to damage by ultraviolet (UV) radiation and sufficient ballast shall
be placed over the cover to prevent wind uplift of the cover during peak wind conditions at the
site. Id. at 10.20 (A) (1). The second condition mandates that "[i]f at any time, visible dust is
observed to be originating from Uranium Material stored on site, the EFRI RSO or his or her
6
authorized representative shall take actions within 30 minutes to stop the generation of visible
dust." Id. at 10.20 (A) (2). The Trust applauds DRC for imposing conditions to attempt to
address the fugitive dust issue. Regrettably, neither of these license conditions meet the
standards established in the Utah Rules, nor do they even comport with prior commitments made
by Denison to Utah DRC to control fugitive dust from the processing of alternate feed at the Mill.
VI. The Proposed License Conditions Do Not Protect Public and Environmental Health
Utah DRC's proposed license conditions are inadequate to protect public and
environmental health from the risks associated with fugitive dust. First, license condition one,
which allows the alternate feed material to be left uncovered for up to fourteen days, does not
protect public or environmental health from fugitive dust resulting from high wind events
occurring on days zero to thirteen. As discussed below, the monitoring provision does not
compensate for this inadequacy due to (1) the lack of 24-hour monitoring at the Mill and (2) the
fact that fugitive dust is not always visible to the naked eye, particularly at night. Moreover, the
fourteen-day condition in the license amendment proposal is inconsistent with the SER for the
mill, which suggested that the alternate feed material would be covered if left on the ore pad for
any duration of time. See URS SER at 42 ("with implementation of the proposed new license
condition requiring that: (1) Uranium Material stored at the Mill Site be covered with a durable,
UV-tolerant geomembrane and ballast shall be applied over the geomembrane to prevent wind
uplift of the geomembrane... the UDRC has determined that no significant adverse effects on
public health or the environment are expected to result from implementing the proposed action").
Thus, URS's conclusion that the geomembrane provision is adequate to protect public health and
safety cannot apply to the license conditions that now - without explanation - include a fourteen
day window in which the alternate feed material can be left uncovered.
Under the ALARA standard, the public benefit of continuous cover in conjunction with
meaningful monitoring would outweigh the economic burden on Energy Fuels. As discussed
above and as the Trust's technical expert, Jim Kuipers, attests in his comments, fugitive dust
from uranium operations has numerous adverse health and environmental impacts. Energy Fuels
has recognized that the processing of alternate feed necessitates the stockpiling of those materials
over time in order to accumulate enough material to justify processing. Given this, is likely that
the alternate feed material will sit on the ore pads for more than fourteen days. Thus, it will not
impose a significant additional burden on Energy Fuels to cover the material from the first
moment it arrives on the mill site; indeed, Energy Fuels will have to cover the material
eventually. In light of the public health and environmental benefits resulting from covering the
material, an ALARA analysis will result in the conclusion that cover should be required
immediately.
The second license condition is inadequate to protect public and environmental health
and safety for three reasons. First, the Mill does not have a person capable of observing visible
dust on staff twenty-four hours a day, seven days a week. In order to render this condition
adequate to protect public and environmental health, the condition must be supplemented by a
requirement that an air quality monitor be on the Mill site twenty-four hours a day. In the
absence of such a condition, there is a possibility that visible dust could be present at the Mill for
up to several days without any mitigation measures being instituted. Second, the license
condition does not protect public and environmental health against the impacts of PM2 5, which is
not visible to the naked eye. As the Trust's technical expert, Jim Kuipers, attests, a percentage of
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the fugitive dust emanating from the alternate feed material will be fine grained, small diameter
particles that are invisible to the human eye. This is precisely why air quality monitoring is an
essential component of any fugitive dust control plan for the Mill. A standard based on visible
emissions does not protect public and environmental health against the adverse effects of small
diameter particle dust. Finally, even dust visible to the naked eye is not visible at night. Thus,
the second license condition does not ensure protection from visible fugitive dust as soon as the
sun sets.
The Trust suggests that Utah DRC utilize this opportunity to revisit its fugitive dust
controls for the Mill. First, Utah DRC should mandate the fugitive dust controls suggested by
Jim Kuipers in his technical comments. Second, Utah DRC should revisit the proposed license
conditions in light of the Trust's concerns. Ultimately, the Trust looks forward to Utah DRC re-
crafting the two license conditions to be protective of public and environmental health, and to
fully comport with the ALARA standard as required by law. Thank you for your consideration
of these concerns.
Respectfully submitted this 21st Day of October, 2013.
ANNE MARIAH TAPP
Attorney for Grand Canyon Trust et al.
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Exhibit 1
GJO-2002-301-TAR
GJO-MOA 1.7-1
Moab Project
Moab Project Site
Fugitive Dust Control Plan
March 2002
Prepared for U.S. Department of Energy Grand junction Office
under DOE Contract Number DE-AC 13-96GJ87335.
Approved for public release; distribution is unlimited.
GJO-2002-30I-TAR
GJO-MOA 1.7-1
Moab Project
Moab Project Site
Fugitive Dust Control Plan
March 2002
Prepared for
U.S. Department of Energy
Idaho Operations Office
Grand Junction Office
Work Performed Under DOE Contract Number DE-AC 13-96GJ87335
Task Order Number MAC02-16
GJO-MOA 1.7-1
Contents
1.0 Introduction 1
1.1 Site Location 1
1.2 Site History 1
1.3 Climatology 2
1.4 Regulatory Requirements 2
1.5 Environmental Monitoring 7
2.0 Site Source Information 9
2.1 Site Ownership and Physical Location 9
2.2 Source Information 9
3.0 Description of Fugitive Dust Emission Activities 13
4.0 Description of Fugitive Dust Emission Controls On-Site 15
4.1 High Potential Source Areas 15
4.2 Moderate Potential Source Areas 15
4.3 Low Potential Source Areas 15
4.4 Standards, Action Levels, and Response Actions 16
4.5 Best Management Practices 17
5.0 Description of Fugitive Dust Emission Controls Off-Site 21
6.0 References 23
Figures
Figure 1. Area Location Map for the Moab Site 3
Figure 2. Site Features Map for the Moab Site 5
Figure 3. Location Map for the Moab Site Fugitive Dust Sources 11
Figure 4. Air Particulate Monitoring Locations 19
Tables
Table 1. Summary of Fugitive Dust Controls for the Moab Site 16
Table 2. Fugitive Dust Standards, Action Levels, and Response Actions 17
Appendix A Material Safety Data Sheets
DOE/Grand Junction Office
March 2002 Moab Project Site Fugitive Dust Control Plan
Page 111
GJO-MOA 1.7-1
End of current text
Moab Project Site Fugitive Dust Control Plan
Page iv
DOE/Grand Junction Office
March 2002
GJO-MOA 1.7-1
1.0 Introduction
(The State of Utah, Division of Air Quality rules for the control of fugitive dust and emissions)
(require that all sources whose activities or equipment have the potential to produce fugitive or)
(airborne dust, must prepare and implement a Fugitive Dust Control Plan.)Accordingly, this
Fugitive Dust Control Plan (Plan) is prepared to address the control of fugitive and airborne dust
emissions from the Moab Project Site (Moab Site) located in Moab, Utah. Specifically, this Plan
complies with the State of Utah rules for controlling fugitive dust emissions as specified in the
Utah Administrative Code (U.A.C.) R307-205, Emission Standards; Fugitive Emissions and
Fugitive Dust. This Plan has been prepared to address activities and operations conducted by the
U.S. Department of Energy's Grand Junction Office (DOE-GJO) at the Moab Site. The primary
objective of this plan is to formulate a strategy for controlling, to the greatest extent practicable,
fugitive or airborne dust emissions at the Moab Site. This will be accomplished by identifying
specific sources and activities which have the highest potential to produce or generate fugitive or
airborne dust emissions. This plan describes the engineering controls necessary to minimize and
control dust emissions from those sources and activities. This plan is prepared to address the
control of fugitive dust emissions at the Moab site which are a result of current DOE activities.
As necessary, the scope of this plan will be revised to reflect changes in DOE's dust control
strategy as site conditions or activities may change in the future.
1.1 Site Location
(The Moab Site is a former uranium-ore-processing facility located approximately 3 miles)
(northwest of the city of Moab in Grand County^ UtahjFigure 1). The Moab Site is irregularly
shaped; a uranium mill tailings pile occupies much of the western portion of the site. The Moab
Site is bordered on the north and southwest by steep sandstone cliffs. The Colorado River forms
the southeastern boundary of the site. U.S. Highway 191 parallels the northern site boundary, and
State Highway 279 crosses the western portion of the property. Arches National Park is located
adjacent to the northern site boundary, and Canyonlands National Park is located approximately
12 miles to the southwest. The Union Pacific Railroad traverses a small section of the site just
west of Highway 279, then enters a tunnel and emerges several miles to the southwest. Moab
Wash runs in a southeasterly direction through the center of the site and joins with the Colorado
River. The wash is an ephemeral stream that flows only after precipitation or during snowmelt.
The entire site covers approximately 400 acres of which 130 acres are covered by the tailings
pile. Figure 2 shows the major physiographic features of the Moab Site.
1.2 Site History
Originally, the property and facility were owned by the Uranium Reduction Company (URC)
and were regulated by the Atomic Energy Commission, predecessor agency to DOE. In 1956,
URC began operation of the Moab mill. In 1962, the Atlas Minerals Corporation acquired URC
and operated the mill until operations ceased in 1984. Between 1956 and 1984, uranium mill
tailings were disposed of on site in an unlined impoundment. Decommissioning of the mill began
in 1988; between 1989 and 1995, an interim cover was placed on the impoundment. In 1996,
Atlas proposed to reclaim the tailings pile for permanent disposal in its current location.
However, Atlas declared bankruptcy in 1998, and subsequently, the U.S. Nuclear Regulatory
Commission (NRC) appointed Pricewaterhouse Coopers (PwC) as the trustee of the Moab Mill
Reclamation Trust and licensee for the site. Ownership and responsibility of the Moab Site was
effectively transferred from PwC to DOE by passage of the Floyd D. Spence National Defense
DOE/Grand Junction Office
March 2002
Moab Project Site Fugitive Dust Control Plan
Page 1
GJO-MOA 1.7-1
Authorization Act (H.R. 5408, 2001). This act further designates that the Moab Site undergo
remediation in accordance with Title I of the Uranium Mill Tailings Radiation Control Act of
1978 (UMTRCA; 42 U.S.C. 7912) (as amended). The DOE-GJO took possession of the Moab
Site on October 24, 2001.
1.3 Climatology
The climate of the Moab region is semiarid. Average annual temperature is approximately
14 degrees Celsius (°C) (57 degrees Fahrenheit [°F]). January is the coldest month, averaging -
1°C (30°F), and July is the warmest month, averaging 28°C (82°F). Extreme temperatures have
ranged from -28°C (-18°F) in January 1963 to 44°C (111°F), which has occurred more than once
(in July 1953 and on earlier occasions). Temperatures of 32°C (90°F) or higher occur about
100 days per year, with about 80 percent of those occurring during June, July, and August.
Temperatures below freezing 0°C (32°F) occur on the average of 123 days of the year with about
80 percent of those occurring during November through February. The effects of high
temperature on human comfort are moderated by the low relative humidity, which is often less
than 50 percent during the daytime hours.
Average annual precipitation at Moab is 20 centimeters (cm) (8 inches), distributed
approximately equally among the seasons with slight peaks during the spring and fall. Potential
evapotranspiration (about 127 cm [50 inches] per year) greatly exceeds annual precipitation.
Mean pan evaporation (about 140 cm [55 inches] per year) and lake evaporation (about 97 cm
[38 inches] per year) also greatly exceeds the total annual precipitation.
Low humidity in the region limits fog occurrences (visibility less than 0.5 kilometer [km]
[0.3 mi]) to fewer than 10 days per year. Thunderstorms occur about 40 days per year. Hail
occurs approximately 3 days per year.
Prevailing winds in the Moab region are southeasterly. Cold air drainage at the Moab Site can
occur from the northwest under very stable conditions. The probability of a tornado is very
small. One tornado with wind speeds of 160 km/hour (hr) (100 miles/hr) would be expected only
once in approximately 100,000 years (NRC 2001).
1.4 Regulatory Requirements
This Fugitive Dust Control Plan is prepared in response to State of Utah, Division of Air of
Quality regulations for the control of fiigitive dust, as found in Section R307-205 (U.A.C.,
September 2001). Dust control plans are required to minimize fugitive dust on-site from various
types of pits, yards, and storage areas. The Fugitive Dust Rule (R307 - 309 U.A.C.) also
addresses storage and handling of aggregate materials, construction / demolition activities,
mining activities, and tailings piles and ponds. The portion of the Fugitive Dust Rule that
specifically applies to the Moab Site is found at R307-205-6(l-2), and requires that "... any
person owning or operating an existing tailings operation where fugitive dust results from
grading, excavating, depositing, or natural erosion or other causes in association with such
operation shall take steps to minimize fugitive dust from such activities." This site specific
Fugitive Dust Control Plan will be submitted to the Executive Secretary for the Utah Air Quality
Board in Salt Lake City, Utah, for approval, and will be updated and revised as necessary to
reflect dust controls which correspond to current and on-going site activities and operations.
Moab Project Site Fugitive Dust Control Plan /
Page 2
DOE/Grand Junction Office
March 2002
GJO-MOA 1.7-1
» » »»
Crescent
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Green f \ Railroad
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National O ft Q 2. (8 Park
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Salt
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; Grand
^Junction UTAH COLORADO
Moab
U.S. DEPARTMENT OF ENERGY
GRAND JUNCTION OFFICE COLORADO
Regional Location Map
OATE PREPARED
February 1, 2002 X0005600-01
n \moa\999\0004\04\001\x00O56\x00O560O apr reynoidm 2/1/2002 10 21
Figure 1. Area Location Map for the Moab Site
DOE/Grand Junction Office
March 2002
Moab Project Site Fugitive Dust Control Plan
Page 3
2 a
B O
o 3
,0
Union Pacific
Railroad
1 VmoaV999tOa04\04VO01Vx000Sax000560O spr smltw 2/15/2002,1131
Arches National Park
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Borrow
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Borrow
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Tail ngs Pile
0
10C0
USTEPREPARED
Matheson Wetlands Preserve
(Utah Department of Wildlife Re
N
esources)
1000 Feet
— — Estimated Extent of Top of Tailings Pile
— — Property Boundary
Estimated Extent of Base of Tailings Pile
Northwest Borrow Area
Northeast Borrow Area
U.S. DEPARTMENT OF ENERGY
GRAND JUNCTION OFFICE, COLORADO
Moab Site Features Map
Moab, Utah
raw
February 15, 2002 X0005600-04 2 o >
Figure 2. Site Features Map for the Moab Site
GJO-MOA 1.7-1
1.5 Environmental Monitoring
In addition to the implementation of physical dust controls, the DOE-GJO has developed and
implemented an environmental air monitoring program for the Moab Site. This environmental air
monitoring program consists of sampling airborne particulates, radon, and direct gamma
radiation at various locations along the site perimeter and at various off-site locations.
Background monitoring locations also have been established to provide ambient air quality data.
The background or ambient air quality data will be compared to air quality data collected from
the on-site monitoring locations, for the purposes of determining compliance with various DOE
Orders, and Federal and State air quality regulations.
As part of DOE's environmental air monitoring and fugitive dust control strategy, a
meteorological monitoring station has been established at the Moab Site. Wind speed and wind
direction data collected from this monitoring station will be used to determine when site-specific
action levels have been exceeded and specific dust controls (e.g., the application of dust
suppression techniques) must be initiated. In addition, personnel certified in reading opacity
measurements in the State of Utah will also be used to determine when active dust control
measures should be initiated, and when specific dust generating activities (i.e., excavating,
hauling, grading, etc.) should be discontinued.
In addition to complying with the State of Utah Fugitive Dust Rule, this Fugitive Dust Plan is
consistent with the intent of complying with various DOE Orders. U.S. Department of Energy
(DOE) Order 5400.1, General Environmental Protection Program, specifies that effluent
monitoring and environmental surveillance be conducted to determine the effect of DOE
activities upon ".. .on-site and offsite environmental and natural resources," and to ".. .verify
compliance with applicable Federal, State, and local effluent regulations and DOE Orders."
Similarly, DOE Order 5400.5, Radiation Protection of the Public and the Environment, requires
that DOE control and monitor radiological exposures from its facilities and activities.
(Thephysical form of the radioactive contaminants (i.e., uranium mill tailings) at the Moab Sitels)
primarily best described as a fine-grained, sand-like material, which is highly susceptible to wind)
(erosion.)Consequently, one of DOE's major objectives at the Moab Site is to control and contain
the off-site transportation of radiological contaminants resulting from the erosive forces of wind
and storm water. This Fugitive Dust Control Plan outlines DOE's strategy for controlling
airborne dust emissions and minimizing/controlling the off-site transport of mill tailings resulting
from wind erosion.
DOE/Grand Junction Office
March 2002
Moab Project Site Fugitive Dust Control Plan
Page 7
GJO-MOA 1.7-1
2.0 Site Source Information
2.1 Site Ownership and Physical Location
As required by the Utah Division of Air Quality, the following site-specific source information is
provided:
1) Name of Operation—-Moab Site Project, formerly known as the(Atlas Mining
(Corporation Uranium MilE)
2) Owner/Operator Information—U.S. Department of Energy, Grand Junction Office.
2597 B3/4 Road, Grand Junction, Colorado, 81503. DOE Contact: Joel Berwick (970)
248-6020. On-Site Contact: Irwin Stewart (435) 259- 5131.
3) Physical Address of Operations—1871 N. Highway 191, Moab, Utah, 84532.
4) UTM Coordinates or Longitude/Latitude of Operations:
Latitude: 38 degrees, 36 minutes, 17.53329 seconds - North
Longitude: 109 degrees, 35 minutes, 23.47893 seconds - West
Elevation: 3977.624 US feet above MSL
2.2 Source Information
Type of Material Processed or Disturbed—The materials of concern with respect to fugitive
dust emissions at the Moab Site are residual uraniun^mill tailings and unstable native soils/sand.
Although the former Atlas mill is no longer active, (a total of approximately 11.8 million tons ot
vuranium mill tailings and surface contaminated soils remain on site) The majority of the mill
tailings are contained within an on-site tailings pile, the footprint of which covers approximately
136 acres. An interim cover of the tailings pile was completed in 1995. Soils from on-site borrow
areas were used as the source of material for the temporary cover. Some of the soils used for the
cover are contaminated with low-level residual radioactive contamination resulting from
previous milling activities conducted at the site. A portion of the cover was seeded in 1999;
however, presently, there is no established vegetative growth on the cell.
(The majority of materials on the surface of the tailings pile consist of poorly consolidated soils,)
land therefore is considered to be a "high-potential" source of fugitive dust emissions at the Moab
^iteJSimilarly, the two on-site borrow areas (i.e., the north west and the north east borrow areas)
are essentially void of any plant or vegetation cover; the soils are poorly consolidated, and are
considered to be major sources for fugitive dust emissions at the Moab Site (Figure 3).
Combined, the tailings pile and the two borrow areas comprise approximately 40 percent of the
total land surface of the Moab Site. The remainder of site is not considered to be a significant
source of fugitive dust emissions due to: 1) The low level of past disturbances in these areas; 2)
The low levels and quantity of contaminated soils identified within these areas; 3) The low
levels of anticipated activity occurring in these areas; and, 4) A greater percentage of vegetative
cover present within these areas.
DOE/Grand Junction Office
March 2002
Moab Project Site Fugitive Dust Control Plan
Page 9
GJO-MOA 1.7-1
Source areas identified as a "moderate-potential" consist of areas that have been partially
disturbed in the past (approximately 20 percent of the total site area); however, soils and surface
sediments in these areas are typically better consolidated and are more stabile due to varying
degrees of vegetative cover. If these areas prove to be a source for fugitive dust emissions in the
future, appropriate control measures will be implemented.
Most of the "low-potential" areas are found along the site perimeter and consist of steep, rocky
terrain (i.e., sandstone slopes and cliffs) in the west, and wetland/river bottom areas along the
south and eastern margins of the site boundary. Typically, there is little to no activity occurring
or planned in these areas, nor have these areas been disturbed by past milling activities. The
"low-potential" areas comprise approximately 40 percent of the total site area. Consequently,
DOE does not anticipate that these areas will be a significant source of dust emissions from the
facility, and no controls are planned for these areas.
Length/Duration of Construction Project—The DOE is in the process of evaluating remedial
action alternatives for the mill tailings currently stockpiled at the Moab Site. Depending upon
which remedial action alternative is ultimately selected, DOE's responsibility for monitoring and
controlling fugitive dust emissions from this site will range in duration from approximately three
to eleven years.
Description of Processes/Site Activities—Currently, the activities occurring at the Moab Site
include: 1) Site characterization (including radiological assessments, surveying, environmental
sampling and monitoring, biological surveys, etc.); 2) Site stabilization (securing unsafe
conditions/structures/utilities); 3) Implementing fugitive dust and storm water controls; 4) Waste
management activities (cleaning up oil spills, consolidating drums and petroleum products,
addressing excess chemical inventory, etc.); 5) Site security (fence installation/repair, postings,
barricades, etc.); and, 6) Installation of a Construction Office and an equipment staging area.
Moab Project Site Fugitive Dust Control Plan
Page 10
DOE/Grand Junction Office
March 2002
2 2
S3 O
3 3
£3
a'
NW
, Borrow
Area Pon
Borrow
Area
Tailings
Pile
°
1000
Matheson Wetlands Preserve
Utah Department of
ildlife Resources)
N
Areas with highest potential for fugitive
dust emmissions: major disturbance,
high activity, and low vegetation cover.
Areas with moderate potential for fugitive
dust emmissions: moderate disturbance,
activity, and some vegetation cover.
Areas with low potential for fugitive
dust emmissions: minimal disturbance,
activity, and highest percentage of
vegetation cover.
Moab Wash Corridor
1000 Feet
Prevailing
Wind Direction
SE
r\moa\999\0004W)4\001\x00056Vx0005600.apr smilhw 2/15/2002. 11:30
U.S. DEPARTMENT OF ENERGY
GRAND JUNCTION OFFICE. COLORADO
Fugitive Dust Classification Areas
Moab, UT
DATE PRFPARt-D
February 15, 2002 X0005600-03
Figure 3. Location Map for the Moab Site Fugitive Dust Sources
)
GJO-MOA 1.7-1
3.0 Description of Fugitive Dust Emission Activities
A description of the on-site activities which may contribute to, or generate fugitive dust
emissions at the Moab Site are discussed below:
Site Characterization—DOE is currently in the process of performing various types of
environmental characterization activities at the Moab Site. These activities include: radiological
characterization, surface and ground water monitoring, radon and direct gamma radiation
monitoring, environmental air/particulate monitoring, meteorological monitoring, floodplain and
wetlands assessment and delineation, threatened and endangered species surveys and critical
habitat identification, and various engineering studies and surveys. Most of these types of
activities are non-intrusive and result in little to no fugitive dust emissions. Vehicles, used to
transport personnel and equipment from one location to another, may result in minimal
generation of fugitive dust.
Interim and Initial Remedial Actions—DOE will be engaged in various remedial efforts to
mitigate immediate threats to the environment (i.e., ground water). Specifically, an Initial
Remedial Action will be initiated during the summer months of 2002 while the Interim Action
may be initiated in 2003. Activities associated with these remedial actions will necessitate the
use of heavy equipment for clearing and grading purposes. These actions will have the potential
to generate moderate levels of fugitive dust emissions.
Site Stabilization Activities—DOE will be securing a former mill building and associated
structures (i.e., pump houses, electrical breaker panels, electrical transmission and distribution
systems, etc.) that were left behind by the Atlas Milling Corporation. Many of these structures
were left in an unsafe condition and need to be stabilized with the increased level of activity at
the site. Although the mill buildings will be eventually demolished, all structures and
appurtenances will simply be secured (i.e., buildings will be locked, live utilities will be de-
energized, etc.) for the present time. These activities may also include the installation or repair of
site fences, installing signs and postings, and setting up various site boundaries and barricades.
The stabilization activities planned for the near future will not result in significant fugitive dust
emissions.
Implementation of Fugitive Dust and Storm Water Runoff Controls—DOE recognizes that
mill tailings and residual contaminated soils are especially vulnerable to wind and storm runoff.
In an effort to contain these contaminants and prevent their migration off-site, establishing
fugitive dust and storm water runoff controls is a priority for DOE. Implementation of these
controls will necessitate the use of heavy equipment to construct or strengthen berms, construct
sediment retention basins, dig borrow ditches, install culverts, apply dust suppressant materials,
etc.; however, fugitive emissions expected as a result of these activities are expected to be
minimal.
Waste Management Activities—DOE will be performing various housekeeping activities at the
site, which will include the consolidation of various materials. These activities will consist of
consolidating miscellaneous fuels, drums of used oil and lubricants, and cleaning up
miscellaneous spills and leaks that have accumulated near the maintenance shop over the years.
For safe storage and to prevent the spread of contaminants into the environment, petroleum
contaminated soils will be excavated and placed into a Best Management Practice Area (BMPA)
Moab Project Site Fugitive Dust Control Plan
March 2002
DOE/Grand Junction Office
Page 13
GJO-MOA 1.7-1
along with other consolidated waste materials. Any on-site wastes requiring special handling or
management will be identified and addressed by DOE's waste management policy and
procedures developed specifically for the Moab Project Site.
The BMPA will be a bermed temporary storage area that will be constructed with a polyethylene
liner. Materials will be temporarily stored at this location until a permanent disposal option has
been defined. The construction of this area and the removal and excavation of various petroleum
contaminated soils will involve the use of heavy equipment. Moderate fugitive dust emissions
can be expected from these activities.
Establishing Construction Office and Equipment Staging Areas—DOE is in the process of
setting up construction office and support trailers, various storage facilities, a decontamination
pad, and an equipment staging area. To complete this task, mobile office buildings will be set-up
on-site, security fencing and gates will be installed, and utilities will be extended to the new
facilities. This effort will require the use of heavy equipment; however, the duration is relatively
short-term, and is not expected to result in significant fugitive dust emissions.
Moab Project Site Fugitive Dust Control Plan
Page 14
DOE/Grand Junction Office
March 2002
GJO-MOA 1.7-1
4.0 Description of Fugitive Dust Emission Controls On-Site
The fugitive dust emission controls to be used at the Moab Site are discussed for each of the
potential source areas. All sources of fugitive dust emissions at the Moab Site are related to site
activities and site conditions. The routine operation of heavy equipment (until remediation
occurs) is not considered to be a significant source of emissions at this site.
4.1 High Potential Source Areas
Certain portions of the Moab Site are considered to be significant sources of fugitive dust
emissions, and require more active controls than other areas. These areas are characterized by:
loose, poorly consolidated sediments, poor vegetative cover, high levels of previous disturbance,
high levels of future/anticipated activity or disturbance, or areas with significant residual
radioactive contamination remaining. Because both the native soils and uranium mill tailings
possess a sand-like texture, these materials can easily become airborne given sufficient climatic
conditions (i.e., low soil moisture content, sufficient wind speeds, etc.). Consequently, DOE has
designated these areas as having the highest priority in their dust control strategy. Cumulatively,
these high-potential areas comprise approximately 40 percent of the total site surface area. The
specific "high-potential" source areas and the planned dust controls to be implemented for each
of these areas are summarized Table 1.
4.2 Moderate Potential Source Areas
Other portions of the Moab Site are considered to be moderate sources of fugitive dust emissions
and will require a less aggressive approach to dust control. These areas are characterized my
more stable soil conditions, a greater percentage of vegetative cover, lesser quantities of
radiologically contaminated materials, and moderate levels of activity. As shown in Figure 3,
these areas are found mostly in the north east and north central portions of the Moab Site.
Cumulatively, these moderate-potential areas comprise approximately 20 percent of the total site
surface area. A summary of the anticipated dust control measures to be used in these areas is
found in Table 1.
4.3 Low Potential Source Areas
Approximately 40 percent of the site is considered to be a low potential source for fugitive dust
emissions. These areas include the river bottom and wetland areas along the eastern and southern
site boundaries; the Moab Wash corridor; the sandstone cliffs and rocky slopes along the
southern and western site boundaries; and the Highway 191 and 279 corridors. These areas are
designated as having a low potential for fugitive dust emissions because there is very little
surface disturbances in these areas; some areas contain dense vegetative cover; these areas are
relatively uncontaminated; and/or there is little to no activity occurring in these areas. No dust
controls are planned for these areas, as shown in Table 1.
Moab Project Site Fugitive Dust Control Plan
March 2002
DOE/Grand Junction Office
Page 15
GJO-MOA 1.7-1
Table 1. Summary of Fugitive Dust Controls for the Moab Site
Fugitive Dust Source
Dust Controls
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High
Potential
Areas
Tailings Pile
(Top)
Tailings Pile
(Side Slopes)
Northeast
Borrow Area
Northwest
Borrow Area
Site Roads
Moderate
Potential
Areas
North and east
portions of
Moab Site
Low
Potential
Areas
Moab Wash
Corridor
River bottom/
wetland
areas
(south/east)
Sandstone
slopes/ cliffs
(east/south)
Highway 191
and 279
corridors
(east and
north)
4.4 Standards, Action Levels, and Response Actions
Table 2 outlines the applicable regulatory standards and action levels relative to controlling
fugitive dust emissions at the Moab Site, and the appropriate response actions to be implemented
once it is determined that standards or actions levels have been exceeded.
An air particulate monitoring network has been implemented at the Moab Site in accordance
with DOE Order 5400.5, Radiation Protection of the Public and Environment and DOE's
Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental
Surveillance (DOE 1991). As per the Moab Site Project Environmental Air Monitoring Sampling
and Analysis Plan (DOE 2002), air quality monitoring data are routinely collected and reviewed
to ensure compliance with DOE Orders and applicable federal and state air quality regulations.
Air particulate sample locations are shown in Figure 4.
Moab Project Site Fugitive Dust Control Plan
Page 16
DOE/Grand Junction Office
March 2002
GJO-MOA 1.7-1
Table 2. Fugitive Dust Standards, Action Levels, and Response Actions
Standard /
Site-Specific Action Level Method of Determination Response Action
Opacity cannot exceed 20 percent
at any on-site location or source
(R307-309 U.A.C.). DOE's goal at
the site boundary is 0 percent
opacity.
Visual observation by a Certified
Opacity Reader
(EPA Method 9 - Visual
Determination of Opacity
Emissions from Stationary
Sources)
Initiate immediate dust control
measures as outlined in Table 1.
Cease all dust generating
activities.
Sustained Wind Speeds Exceeding
20 rnph (miles per hour).
(EPA Method 9 - Visual
Determination of Opacity
Emissions from Stationary
Sources)
Real time meteorological
monitoring.
Monitor visible emissions, Cease
all dust generating activities if
necessary to maintain 20 percent
opacity or less. If needed, initiate
immediate dust control measures
as outlined in Table 1.
Cannot exceed public exposure
standards (DOE Order 5400.5)
Analysis of filters collected by
continuous air samplers.
Reassess dust control plan and
controls
4.5 Best Management Practices
The following Best Management Practices (BMPs) will also be followed to help minimize and
control dust emissions at the Moab Site to the greatest extent possible:
Roads—All onsite traffic will be restricted to specific designated roads. Off-road travel will only
be authorized on a case-by-case basis (e.g., access to a remote monitoring well, etc.). Traffic on
the tailings pile will be restricted to designated roads to minimize disturbance of previously
treated/stabilized areas. Traffic speed will also be restricted to an appropriate level on all
designated roads. All designated roads will be considered as high potential dust source areas, and
as such, will be a priority for dust controls utilizing magnesium/calcium chloride, watering, or
gravel.
Hours of Operation—This Plan will be in effect during all hours of operation at the Moab Site.
During non-business hours, there will be no activities generating dust; therefore, dust control
actions will restricted to hours of operation only. However, as a best management practice, if
high winds are evident at the close of a business day (or immediately prior to a weekend,
holiday, etc.), site personnel should evaluate vulnerable areas and implement controls as
appropriate to minimize off-hours emissions.
Use of Chemical Suppressants—Use of various chemical dust suppressants (e.g., surfactants,
salt-based soil conditioners, etc.) shall be done in accordance with the recommended end-uses
for those products. Site personnel shall not exceed the manufacturer recommended application
rates. Material Safety Data Sheets (MSDSs) for all dust suppressant materials used at the Moab
Site shall be reviewed and approved by the Environmental Services organization. Prior to
application, site personnel shall determine and evaluate if the use of the dust suppressant could
interfere with other site monitoring activities, or cause other harm to the environment (e.g.,
runoff into critical habitat for threatened or endangered fish). The MSDSs for dust suppressants
to be used at the Moab Site are included in Appendix A.
Moab Project Site Fugitive Dust Control Plan
March 2002
DOE/Grand Junction Office
Page 17
GJO-MOA 1.7-1
End of current text
Moab Project Site Fugitive Dust Control Plan
Page 18
DOE/Grand Junction Office
March 2002
GJO-MOA 1.7-1
)
Bar M Chuckwagon
(Background Location)
Arches . , Entrance
Utah Division of Wildlife Resources
Moab
Site
• Radio Particulate Air Monitoring Location
Site Boundary
Highway
Streets
• • • • Railroad
River
6°
0°
Portal RV Park
City of
Moab
Moab Waste
Water Plant Moab Golf Club (Background Location)
Kane Creek Road
Location
2 Miles
U.S. DEPARTMENT OF ENERGY
GRAND JUNCTION OFFICE, COLORADO
Air Monitoring Locations
Moab, Utah
OATE PREPAREO
February 15, 2002 X0005600-02
n \moaV999\0004\04\001\x00056\x0005600 apr d50849 2/1^2002 14 31
Figure 4. Air Particulate Monitoring Locations
Moab Project Site Fugitive Dust Control Plan
March 2002
DOE/Grand Junction Office
Page 19
GJO-MOA 1.7-1
5.0 Description of Fugitive Dust Emission Controls Off-Site
To minimize the potential for off-site releases or emissions, the following controls will also be
implemented:
Decontamination and Tracking Pad—Prior to leaving designated contamination areas at the
Moab Site, all vehicles and equipment will be thoroughly washed and decontaminated at a
decontamination pad using a high pressure water wash. This practice should minimize the
potential for any off-site tracking of sediment or contaminants.
Covered Loads—Any trucks hauling materials off-site shall be tarped and covered to minimize
the loss of materials in-transit / off-site. All loads shall be inspected to ensure that they are
properly covered prior to departure.
Spill Response—In the event of a spill or release of contaminated materials off-site, the spilled
materials will be immediately contained and cleaned up. Emergency spill response actions are
outlined in Section 13.0 of the Moab Site Project Health and Safety Plan (DOE 2001).
Moab Project Site Fugitive Dust Control Plan
March 2002
DOE/Grand Junction Office
Page 21
GJO-MOA 1.7-1
End of current text
Moab Project Site Fugitive Dust Control Plan
Page 22
DOE/Grand Junction Office
March 2002
GJO-MOA 1.7-1
6.0 References
Grand Junction Office, Moab Site Project Environmental Air Monitoring Sampling and Analysis
Plan, February 2002, GJO-2001-274-TAR, MAC-MOA 1.6-1, Grand Junction, Colorado
, 2001, Moab Site Project Health and Safety Plan, December 2001, GJO-2001-281-TAR,
MAC-MOA 1.3 (continuously updated), Grand Junction, Colorado
U.S. Department of Energy (DOE) Order 5400.1, General Environmental Protection Program
, DOE Order 231.1, Environment, Safety, and Health Reporting
, DOE Order 5400.5, Radiation Protection of the Public and the Environment
, Environmental Regulatory Guide for Radiological Effluent Monitoring and
Environmental Surveillance, DOE/EH-0173T, January 1991
U.S. Nuclear Regulatory Commission, Final Environmental Impact Statement Related to
Reclamation of the Uranium Mill Tailings at the Atlas Site, Moab, Utah, NUREG-1531, Vol.1
C.2, March 1999, Washington, DC
Utah Administrative Code (U.A.C.), R307-205-6: Emission Standards: Fugitive Emissions and
Fugitive Dust, September 2001, Salt Lake City, UT
, R313-15-301: Standards for Protection Against Radiation, Dose Limits for
Individual members of the Public, September 2001, Salt Lake City, UT
DOE/Grand Junction Office
March 2002
Moab Project Site Fugitive Dust Control Plan
Page 23
GJO-MOA 1.7-1
End of current text
Moab Project Site Fugitive Dust Control Plan
Page 24
DOE/Grand Junction Office
March 2002
APPENDIX A
Material Safety Data Sheets for Dust Suppressants Used at the
Moab Project Site
MATERIAL SAFETY DATA SHEET
PRODUCT NAME: CALCIUM CHLORIDE, LIQUID
CAS NUMBER: 10043-52-4 HBCC MSDS NO. CC06000
HILL BROTHERS CHEMICAL CO.
1675 No. Main Street
Orange, California 92667 Telephone No: 714-998-8800
Outside Calif: 800-821-7234
CHEMTREC: 800-424-9300
9^ OW^ B
Revision issued: 8/12/93 Supercedes: 5/27/92 First issued: 12/01/85
IMPORTANT! Read this MSDS before use or disposal of this product. Pass along the information to
employees and any other persons who could be exposed to the product to be sure that they are aware of the
information before use or other exposure. This MSDS has been prepared according to the OSHA Hazard
Communication Standard [29 CFR 1910.1200). The MSDS Information Is based on sources believed to be
reliable. However, since data, safety standards, and government regulations are subject to change and tne
conditions of handling and use. or misuse are beyond our control, HILL BROTHERS CHEMICAL COMPANY
makes no warranty, either expressed or implied, with respect to the completeness or continuing accuracy
ol the information contained herein and disclaims all liability for reliance thereon Also, additional
information may be necessary or helpful for specific conditions and circumstances of use. it is the user's
responsibility to determine the suitability of this product and to evaluate risks prior to use, and then to
exercise aoorooriate precautions for protection of employees and others.
SECTION I - PRODUCT IDENTIFICATION
SYNONYMS / COMMON NAMES: CALCIUM CHLORIDE, LIQUID
CHEMICAL FAMILY / TYPE: INORGANIC SALT
DOT PROPER SHIPPING NAME: N/A
DOT HAZARD CLASS / I.D. NO.: N/A
REPORTABLE QUANTITY: N/A
NFPA RATING: HEALTH - 1; FIRE - 0: REACTIVITY - 0
nonsignificant l=siiqht 2=Moderate 3=Hiqh 4-=Extreme
SECTION II - HAZARDOUS INGREDIENTS
CAS Exposure Limits (TWAs) In Air
Chemical Name Number % ACGIH TLV OSHA PEL Other'
CALCIUM CHLORIDE 10Q43-52-4 24-^0 N/A N/A N/A
SECTION 111 - PHYSICAL AND CHEMICAL PROPERTIES
Physical State: LIQUID pH: 9-10 Melting Point/Range: N/A
Appearance/Color/Odor: CLEAR LIQUID, ODORLESS
Boiling Point/Range: N/A Solubility In Water: 100%
Vapor Pre33ure(mmHg): N/A Specific Gravlty(Water = 1): 1.347 60_°F
Molecular Weight: 110.99 Denslty(Alr = 1): N/A
% Volatlles: N/A How to detect thi3 compound: N/A
SECTION IV - FIRE AND EXPLOSION
Flash Point: Not flammable . Autolgnltlon Temperature: Not flammable
Lower Explosive Limit: N/A Upper Explosive Limit: N/A
Product/Trade Name : CALCIUM CHLORIUh, LICJUIU
103
SECTION IV - FIRE AND EXPLOSION-CONTINUED
Unusual Fire and Explosion Hazards: N/A
Extinguishing Media: N/A Special Fireflghtlng Procedures: N/A
SECTION V - REACTIVITY
Stability: Stable Hazardous Polymerization: Will not occur
Conditions to Avoid: N/A
Materials to Avoid: Metals will slowly corrode In aqueous solutions. Boric acid and caJclum oxide
are Incompatible.
Hazardous Decomposition Products: None
SECTION VI - HEALTH HAZARDS
Routes of Exposure: Calcium chloride can affect the body If It Is Ingested or if It comes In contact with
the eyes or skin.
Summary ot Acute Health Hazards:
INGESTION: Causes Irritation of mouth and stomach.
INHALATION: Causes Irritation of nose and throat.
SKIN: Causes mild irritation.
EYES: Causes irritation and possible transient corneal injury.
Carcinogenicity Lists: NO NTP: NO IARC Monograph: NO OSHA Regulated: NO
Summary of Chronic Health Hazards: N/A
Effects of Overexposure: Possible superficial burns and transient corneal injury.
Emergency and First Aid Procedures:
INGESTION: If swallowed will cause nausea and vomiting. If victim is conscious, have victim drink water
or milk. If victim is unconscious or having convulsions, do nothing except keep vicum warm -- call for
medical help.
INHALATION: Move to fresh air; if discomfort persists, get medical attention
SKIN: If necessary, remove contaminated clothing and shoes. Flush affected areas with plenty of water.
EYES: Promptly flood with water and continue washing for at least 15 minutes. Consult an
ophthalmologist.
Medical Conditions Generally Aggravated by Exposure: N/A
SECTION VII - PRECAUTIONS FOR SAFE HANDLING AND USE
Steps To Be Taken In Case Material Is Released Or Spilled: Dike the spilled liquid, and either
pump back into original container or cover with clay-type substance for absorption.
Handling and Storing Precautions: Store at ambient temperature. Prevent possible eye and skin
contact by wearing protective clothing and equipment.
Waste Disposal Methods: Add to large volume of water. Stir in light excess soda ash. (Add slaked
lime in presence of fluoride.) Decant and neutralize In second container with 6M-HCL Route to sewage
plant Use as landfill sludge. Notify local sewage plant and solid waste authority.
Other Precautions: N/A
SECTION VIII - CONTROL MEASURES
Respiratory Protection: N/A Ventilation: N/A
Protective Clothing: Employees should be provided with and use impervious clothing, rubber gloves.
and rubber boots. - -
Eye Protection: Employees should be provided with and required to use splash-proof safety goggles
where there is any possibility of calcium chloride contacting the eyes.
Oth?r Protective Clothing c Equipment: N/A
Work/Hyglenlc Practices: Avoid contact with the eyes, skin, and mucous membranes.
N/A - Not Applicable Page 2 of 2
,V.,.;
Envirotac II is at work in
Afghanistan aiding
Operation Enduring
Freedom
Stabilizing Runways,
Landing Pads & More1
(Download/Print a MSDS copy from the References tab)
Material Safety Data Sheet
Envirotac II ®
H«"Cj,i - i
SECTION 01 IDENTIFICATION
Manufacturer Environmental Products and Applications, Inc
Address 10722 Arrow Route, Suite 116
Roncho Cucamonga, CA 9t730
Date Prepared 07-30-87
Emergency Phone # [phone]
Product Trade Nunc Envirotac II'
SECTION 02 HAZARDOUS INGREDIENTS
Hazardous Components This product is non-hazardous under OSHA Howard Communication Standard 29 CI R 1910 1200
Chemical Family Vinyl acrylic copolymer
Product Solids- 39 43% (active solids)
SECTION 03 PHYSICAL/CHEMICAL CHARACTERISTICS
State
Appearance and Color
pH
Boiling Point
Melting Point
Vapor Pressure
Vapor Density
Solubility in Water
Specific Gravity
Evaporation Rate
Liquid
Milky White
5 0 to 9 5
212F/100C Water
32F/0C Water
(mm Hg)l7mg Hg@20C/68F Water
< 1 Water
Dilatable
(H20=l) I Oto 1 2
(Butyl Acetate=l) < 1 Water
* 1
SECTION 04 FIRE AND EXPLOSION HAZARD DATA
Unusual Hazards Material can splatter above 212F. Dried product can bum
Extinguishing Media Use extinguished media appropriate for surrounding fire
Unusual Fire & Explosion Hazards None Known
Specific Fire Fighting Procedures Wear self-contained breathing apparatus and full protective gear
SECTION 05 REACTIVITY DATA
Stability Stable (Avoid temperatures above 350F and open flames)
Hazardous Polymerization Will not occur
Materials to Avoid' None Known
Hazardous Decomposition Products Thermal decomposition may yield acrylic monomers or \inyl acetate monomer
SECTION 06 HEALTH HAZARD DATA
ROUTES OF EXPOSURE:
Inhalation Inhaling vapor or mist can cause headaches, nausea and irritation of the nose, throat and lungs
Ingestion Yes
Eye Contact. Slightly irritating to eyes
Skin Contact* Irritating to skin upon repeated or prolonged contact.
EMERGENCY & FIRST AID PROCEDURES:
1 of 2 2/8.02 1 33 PM
-IIV1IUU11. II OUll «JU»UIH*.V.l wvsivvyg "j^/nnp //www envirotac coramsdb htm
Inhalation Move subject to fresh air
Eye and Skin Contact Flush eyes with a large amount of water for at least fifteen minutes See a physician if irritation persists
Ingestion If swallowed, dilute by giving 2 glasses of water to dnnk Consult a physician Never give anything by
ACUTE;CHRONIC (or carcinogenic): None established
SECTION 07 PRECAUTIONS FOR SAFE HANDLING AND USE
Steps to be taken in case material ts released of spilled Dike and contain spill with inert material (i e , sand, earth) Cov
Waste Disposal Method Coagulate by the stepwise addition of ferric chloride acid and lime Collect clear super maten
Precautions to be taken in handling and storage. Handle with protective gloves and store at temperatures above freezing
SECTION 08 CONTROL MEASURES
Respiratory Protection None indicated under normal conditions of use
Local Exhaust If needed to control mist.
Mechanical (General) N/A
Protective Gloves* Use gloves impervious to water and soap
Eye Protection. Use chemical splash goggles
Other Protective Clothing N/A
Work/Hygienic Practices N/A
10 2 5 35 Abate Abatement Abatement Abates Abating Acetate Acetate-Acrylic Acidulated acre Acryl
comprized Conditioned Conditioner Conditioning Constructing Construction Consultants Consulting C
Envtrosnot Envixo-snot Envirotac Envirotack envirowise Enviro- Wise Enz>me Enzymes Equiped equ
Lab laboratories Laboratory land Land Landfill Landfills landing Landing landings lands Lane Lane La
penzoil Penzsuppress PenzsuppressD Performed Performing Performs Permazyme Petro Petrobond P
Soapstock Soapstock Sod Soded Soding Soil Soiloc SOILOC-MQ Soils SoilSement Soil-Sement sokle
Send mail to [e-mail] with questions about Envirotac II or comments about this vvcb site.
Copyright© 2001 Environmental Products & Applications, Inc.
Last modified: 2/7/02
2 of 2 2/8/02 1 33
Received Jan-29-02 04:26pm from 9702487682 - MACTEC-ERS ^(^29^20021 3141PM MACTEC-ERS
A »|WNn> Tmd,m.A tl tit SHMMM* '/MM £l. Mft
page 8
NO.2£6 P.S'9./0l
SOIL STABILIZATION PRODUCTS COMPANY, INC,
P.O. Box 2779, Merced, CA 95344
Phone: [phone] or (800) 523*9992
Fax: [phone] E-mail: [e-mail]
Webpage: httpj/www.sspco.com
SO(L SEAL
CONCENTRATE
Effective Date: January 1, 2001
PRICE LIST
Number of Drums
1 - 9
10-49
SO - 199
200 and up
Number of Gallons
55 - 495
550 - 2,695
2,750 - 10,945
11,000 and up
Price Per Gallon
511.00
510.70
510.40
FACTORY
QUOTE
Prices quoted above are F.O.B. our Pico Rivera warehouse and are subject to change without notice.
PO$Wt* Fax Note 7671
Pnon$ <i
Pftt i
6063.S9
SOIL SEAL Is a registered trademark of the Soil Seal Corporation
Ref: January 1,200\
TOTAL P.01
ma-m-uz NUN 10:44
WS-TOP* Ouit Control Agent and Road Stabillur
V. UJ
- * rrr.. ™ . ——
• PHYSICAL' HAZARD WARNING: Not applicable * * fLAftMBLE: NO IF YES, UNDER WICK CONDITIONS: S •
SENSITIVITY TO > STATIC 01 SOURCE: No ; MECHANICAL IMPACT: No
FLAMMABLE LIMITS (X BY VOL.}: UEL: Mot applicable LCI: Not applicable E • FLASHPOINT (METHOD): Not applicable
C •
T • AUTO IQHUCM TEMPERATURE: Not applicable
1 * )
0 * HAZARDOUS COMBUSTION PRODUCTS: Not applicable
R • I
* MEANS OF EXTINCTION: Utter spray, carbon dioxide, dry chemical. As this material is virtually non-flaanable, use proper
V * equipment to fight surrounding fire.
* Mil flBJBHKlM WMi Wow I
SPECIAL FIRE FIGHTING PROCEDURES: Firefighters should wear full protective equipnent and use normal f I ref j oh ting
procedures.
TOXICOLOGICAL PROPERTIES <*
0
N
VI
HEALTH HAZARD WARNING: Irritant.
ROUTES OF ENTRY > SKIN CONTACT: X SKIN ABSORPTION; EYE CONTACT: X INHALATION: INGESTION:
EFFECTS OF ACUTE EXPOSURE: This material may be irritating to the skin and eyes on contact. If inhaled it may also be
irritating to the.respiratory tract.
IRRITANCY OF PRODUCT: Skin/eye irritant.
EFFECTS of CHRONIC EXPOSURE: Not applicable
SENSITIZATION TO PRODUCT: Not applicable
CARCINOGEN; REPRODUCTIVE EFFECTS:
TERATOGENICITY: MUTAGENICITY:
SYNERGISTIC MATERIALS: None known
MEDICAL CONDITIONS AGGRAVATED: None
} BRIEF DESCRIPTION: Not applicable
>
)
k|wwn |
PAGE 2 OF t
HHK-uq-u^ nun lo.'m r. Ud.
CODE 1 "ATRIAL SA/ETT DATA SHEET
WILLY INDUSTRIES, INC PACE 1 Of 4
PRODUCT INFORMATION
PRODUCT NAME: DUS-TOP Oust Control Agent
and Road Stab!liter
PRODUCT NUMBER: Not applicable
(UIUFACTURERS NAME: Rellly Ucndover
a Division of Reilly industries, Inc.
ADDRESS: 1510 Market Square Center
151 North Delaware Street
Indianapolis Indiana 46204
EMERGEN CT TELEPHONE NUMBER: 317-247-8141
CHEMICAL MAKE: Not applicable •
*
SYNONYMS; Hot applicable •
*
CAS NUMBER: Not applicable MOLECULAR WEIGHT; Not applicable •
*
CHEMICAL FORMULA: Not applicable DOT NUMBER: Not regulated «
PRODUCT USE: Dust control. IMO: Hot regulated *
HEALTH: 1 FLAMHABILITY: 0 REACTIVITY: 0 «
SUPPLIER INFORMATION: Reilly Industries, Inc HAZARD CODEC 0 - NONE; 1 • SLIGHT; 2 » MODERATE; 3 * SEVERE; 4 - EXTREME)*
MAZAROOUS INGREDIENTS
I | | EXPOSURE LIMITS
S * HAZARDOUS INGREDIENTS | CAS # | CONCENTRATIONS |
E • l ) (X) | OSHA PEL I
c 1 Li i i i •
T • Magnesium chloride | 7786-30-3 | 28 - 34 | Not applicable J Not applicable |28O0 mg/kg (rat) ; Not *
I * II | | javaUable »
I LD 50 (ORAL>/LC 50 •
ACGIK TLV 1 *
O •
N *
e
ll *
«z====^«~===-=-~=—> PHYSICAL DATA <•«
pH: 7
iSSSSSSanzssss:
VAPOR PRESSURE: Not applicable *
»
FREEZING POINT: *13 F SPECIFIC GRAVITY: 1.30 i 69 F *
$ • PHYSICAL STATE: SOLID LIQUID X GAS
E * I
C * ODOR A APPEARANCE: Clear liquid.
T •
I * I SOLUBILITY (WATER): Kisctble *
O • ODOR THRESHOLD: Not available DENSITY: SeApccific gravity. «
R * \ EVAPORATION RATE: Not available VAPOR DENSITY: Not available *
* MELTIHG POINT: Not applicable i ( •
1" • ' I COEFFICIENT OF WATER/OIL DISTRIBUTION: Not available e
* BOILING POINT: 244.6 F «
inmiiMnintntttasnainuum: »> REACTIVITY DATA R< 9 WMW9MMM9M*M*»?JiM slal WITS CSS
S * PHYSICAL (REACTIVITY) HAZARD WARNING: Not applicable
E •
C « STABLE: Yea IF NO, UNDER WHICH CONDITIONS:
T * \
I * INCOMPATIBILITIES Mildly corrosive to metals.
o • r
N • REACTIVE: No IF YES, UNDER WHAT CONDITIONS:
IV * HAZARDOUS DECOMPOSITION PRODUCTS: tf evaporated to dryness, and heated to e minimum of 500 C, HCI vapors could be liberated.
1
Suggested Application Rates of Soil Sea! Concentrate
33
CD O
GPA=GotanspeiAcw
$/Sq Fl c D&on per spoors /oof ol xjgy&slBtJgaiott per ooo GPA
150 —
130 —
110 ^3
a
to 90 a a
to to
I to 70 — to to to to SI 73
I to
50 2 I 13 to
2 5 30.—
10 REVEGETATiON-
HYDROSEED1NG
W/5EED MULCH & FERTILIZE*
DUST
ABATEMENT
EROSION
CONTROL
SOLSBTOQRP
SOIL SEAL
CORPOfUTrOH
SoS SwJ Cu|M*n tec aonducM «dmna IBBOKBT/ aad Md kMrv to ordar It
tf««jrtkin* t*> bantitt xA !M> S*i1 CvKxMt. Tin jmtnrwtVjn anrf npnw
paw**a*d hi Wi bioahtj* w bMd on VioftlBcti J" J itoavBi tftctotiCBf fcriuwtorft
a*vHvtfi tl HM> VIM «lpfvAaQ.-ilafvpri3BrtMB9B or IndwOBMt ifr roads puvn^Mtfp
nfVBIB^ Fnrtv(» VM9 vtbnt^bM •njaatiojatfcQt vw^MMd in DJ UUIMB rat
>—i»fcd tj —»v »mr Howl —put u i«»r»il.« »> w liiXifcr.
WsfrMxiledbyx
SOtSMBIJZATON FTOOUCTS COMFttfiY, MG.
PA Box 2778, Uflic#d, CA 8S344
SOIL SEAL APPLICATION —
WHAT IS SOIL SEAL?
SOIL SEAL la a soil stabilizer which prevents erosion by creating a large mass of stabilized soil not easily
disturbed by wind and water. SOIL SEAL penetrates the soil surface and forms an excellent cohesive bond
between the soil particles. It can be used as a sole treatment in combating dusting and soil erosion, or
it can be used as a tackifjer in hydroseeding and hydromulching applications. SOIL SEAL is a non-toxic,
non-corrosive, non-flammable auxiliary soil chemical formulated to provide safe and economical surface
soil stabilization, The SOIL SEAL solution may ba applied over vegetation or seeded areas without harmful
affects.
APPLICATION PROCEDURES
SOIL SEAL can be applied by nearly all types of equipment designed to apply liquids, ranging in size from
small garden sprayers up to large hydroseeding trucks end water trucks. In ell cases, the equipment should
be capable of distributing the material in a uniform pattern, applying the solution in large droplets instead
of fine mists.
Once the application rate of the concentrate in gallons par acre has been established, the dilution of the
concentrate with watar can begin. The standard dilution ratio is 30 gallons of water per gallon of SOIL
SEAL The normal turbulence of adding water to the mixing tank will provide adequate mixing of the solution.
Further agitation is not required. Pour the SOIL SEAL concentrate into the mixing tank with no more than
50% of the water required for its proper mixture already in the tank. Add the remaining water after the
concentrate has been added. For loading material, you can use one of several methods: 6 gallon buckets,
elevating the drum up to the height of the fill hole by use of a front-end loader or fork lift, or setting up a
sump pump or trash pump that can move a fairly thick liquid. Always hose down any spillage that occurs
while loading the concentrate into the truck.
Suggested clothing far your crew is disposable uniforms or old clothes and old shoes. If any of the crew
wear eye glassses, safety goggles can be used to protect glasses from ovsrspray. This is perttcularly
important on windy days. For clean-up of clothing and equipment, use a water wash to clean up this water-
base product.
When possible, try to schedule application of the product when wind conditions are below 5 rnph. Tne
SOIL SEAL product Is applied in multiple spray passes to minimize runoff of the solution and to maximize
penetration. The full amount of solution planned for application to a specific area should be applied in e
continuous series of spray passes frt is not possible to apply part of the product on 8 second day to a partially
treated area as the existing product would already be cured and would inhibit penetration of the second
application]^ Curing time can range from a few hours In hot summer weather to 24 hours or more during
periods of high humidity or cold weather. Allow a 24 to 36 hours drying period for the treated area to
develop maximum crust strength.
CfllJTW Care must ba exercised ca prevent damage that can result from Improper application of SOIL SEAL Each sice should
be evaluated pnor to application for factors such as wind spaed and tfrecdon. Equipment, vehicles, buildings end other Items on-
sita which require protection from overspray should be moved or properly prccacwd pnor to tha SOIL SEAL application.
The proper application of SOIL SEAL Is essential to its perfarrrranca. Tha cwnsr and consulting engineer should Insure that the
application crew is thoroughly familiar with all technical data and installation instructions for tha SOIL SEAL produce The seller.
Tha Sail Seabiliraocn Products Company, is nac responsible for produce application or suparvision of the SOIL SEAL application.
Received Jan-29-02 04.26pm from 9702487682 - MACTEC-ERS . J .29. cQQZ 5: rfCPfl rWCTEC-EFS page 5
F.5 s
SECTION OS' REACTIVITY DATA
STABILITY
HAZARDOUS POLYMERIZATION
CONDITIONS AND MATERIALS TO AVOID:
HAZARDOUS DECOMPOSITION PRODUCTS:
SECTION 08: HEALTH HAZARD DATA
Stable under Normal Conditions
Will Not Occur
N/A
If Involved In a fire, dried film capable of burning giving off
oxides of carbon/nitrogen.
ROUTES OF FYPDRURF-
Inhalation
Absorption
Ingestion
Eye Contact
Skin Contact
Vapor or mist can cause headache, nausea, and irritation of the nose, throat and
lungs.
Contact-yes; Absorption-unlikely.
Yes
Slightly Irritating to eyes,
Irritating to skin upon repeated or prolonged contact.
FMFRGPNCY A FIRST AID PROOFDURES;
Inhalation Move subject to fresh air.
Eye and Skin Contact Flush eyes with a large amount of water for at least 15 minutes. See a
physician If Irritation persists. Wash affected skin areas with soap and
water.
Ingestion If swallowed, dilute by giving 2 glasses of water to drink. See a physician.
Never give anything by mouth to an unconscious person.
SECTION Q7; PRECAUTIONS FOR SAFF MAMOLIMfl ANn MRP [
STEPS TO RE TAKEN IN CASE MATFRIA! ts RR EASED OR SPILI FO: Keep spectators away. Floor may be
slippery. Use care to avoid falling. Dike and contain spill with inert material (e.g., sand, earth) Transfer liquid to
containers for recovery or disposal and solid diking material to separate containers for disposal. Keep spills and
cleaning runoffs out of municipal sewers and open bodies of water.
WASTE DISPOSAL METHOD: Coagulate the emulsion by the stepwise addition of ferrio chloride and then lime.
Remove the clear supernatant liquid and flush to a chemical sewer. Incinerate the solids and contaminated diking
material at a permitted facility In accordance with local, state and federal regulations.
PRECAUTIONS TO BE TAKFN IN HANDLING & STORAflF: Proper ventilation and keep from freezing.
SECTION PR: CONTROL MEASURES
RESPIRATORY PROTECTION
LOCAL EXHAUST
MECHANICAL (General)
PROTECTIVE GLOVES
EYE PROTECTION
OTHER PROTECTIVE CLOTHING
WORK/HYGIENIC PRACTICES
None should be required. Use OSHA/NIOSH-approved respirator
in poorly ventilated areas.
If needed to control mist or vapor.
Is expected to be satisfactory.
Use gloves Impervious to water and soap.
Safety Glasses and available eye bath.
N/A
N/A
5031.SS
SOIL SEAL is a registered trademark of Soil Seal Corporation
Page 2 of 2 Ref: 5/21/99
Received
JAI
age 6
reived Jan-29-02 04-26pm from 9702487682 -> MACTEC-ERS page 4
. Jfill.19.2Q0c 3:40PM MfiCTEC-EFS NO. 266 P. 4'3
TntOmrJutif
lollt
SQIL STABILIZATION PRODUCTS COMPANY, INC.
P.O. Box 2779, Merced, CA 95344
Phone: [phone] or [phone]
Fax: [phone] E-mail: [e-mail]
Environmentally Appropriate Product Technologies
for Pavements, Dust Control, Erosion Control & Soil Stabilization
MATERIAL SAFETY DATA SHEET
SOIL SEAL® CONCENTRATE
MSDS # 7701
Reviewed: 01/04/99
SECTION 01; IDENTIFICATION
INFORMATION FURNISHED BY:
ADDRESS.
DATE PREPARED:
EMERGENCY PHONES:
PRODUCT OR TRADE NAME;
SECTION 03: HA7ARHQUS INGRFDfPNTfi
Soil Stabilization Products Company, Inc.
P.O. Box 2779, Merced, CA 95344
01/04/99
[phone] or [phone]
SOIL SEAL Concentrate
Components % by Wt £ASJ
ACRYLIC POLYMER + 46-48% Non Haz
WATER 54-52% Non Haz
AMMONIA .2% Max 7664-41-7
SECTION 03: PHYS1CAUCHEM1CAL CHARACTERISTICS
OSHA PF1-
NE
NE
NE
AC.GIH TLV
NE
NE
25 ppm
BOILING POINT
MELTING POINT
VAPOR PRESSURE (mm Hg)
VAPOR DENSITY (Air» 1)
SOLUBILITY IN WATER
APPEARANCE & COLOR
SPECIFIC GRAVITY (H20 - 1
EVAPORATION RATE (Butyl Acetate = 1)
>212° F
N/A
Same as water
<1
Dilutable
GEeenish Liquid with slight ammoniacal odor
1.06
<1
SECTION 04: FIRE AND EXPLOSION HA7ARF> DATA,
FLASH POINT (Method Used)
FLAMMABLE LIMITS
EXTINGUISHING MEDIA
SPECIAL FIRE FIGHTING PROCEDURES
UNUSUAL FIRE FIGHTING pf*OCpD|JRE.S
None (TCC)
Not Applicable
Not Applicable
Not Applicable
Product will not burn but may splatter if temperature
exceeds boiling point. Polymer films are capable of giving
off oxides of carbon/nitrogen.
5051.SS
SOIL SEAL is a registered trademark of Soil Seal Corporation
Page 1 of 2 Ref: 5/21/99
ceived Jan-29-02 04:26pm from 970243/oS; - MACTEC-ERS
JflN.29.S0Q2 3:39PM rttCTEC-EPS _N0. 266. J3. 3'9.
page 3
SOIL SEAL" - A PROVEN PERFORMER
WHEN YOU NEED TO HOLD SOIL WHERE IT BELONGS
When you need to stop dusting, erosion and siltation.
or over twenty years, this unique copoly-
mer formulation ho* been setting the
standord for soil surface stabilization.
SOIL SEAL* has been specified tor trie
mast environmentally sensitive sites by
agencies sucn as The National Park Service,
the Forest service and tne Environmental Prc-
tectton Agency. When SPA remedial action
clean-ups or Superfund sites need reliable
dust control, erosion control or protection of
hydroseeding and hydromulchlng applied*
t'ons, SOIL SSAl* fits the bill.
While the environmental acceptability of SOIL
SEAL* is an outstanding attribute for projects
where environmental cleanliness Is carefully
reviewed, the durability and cost - •AY#cf/V#-
newof the treatment Is equally Important. For
cgenaes or industries with a requirement to
control large expenses ot bare soil, pcrticlly
vegetated land, mine and mill failings, or
new'y planted seed on erosive sells or steep
slcpes, coif - 0ff»ctiv»n*is mutt be a priority
concern.
Why Is SOIL SEAL5 Unique
In Effectiveness and Unique
In Durability?
'•ere are three primary natural erosive forces
at work with which c soil surface stabilizer
must contend • wind, water end sun Wheher
the goal Is to control dust or to stop wind end
water emotion, an effective treatment must
oe well integrated with the soil TO rcid aga'nst
high winds, ram impact end heavy sheet -
flow of wafer, The treatment also needs to be
resistant to the erosive force of tne sun, ultra -
viola* degradation. The patented nigh grace
copolymer formulation of the SOU SE Al* prod-
uct meets tha thrse forces of nature head -
on with three unique copcoihtias. use of the
high grade copolymer base allows SOILSBAL*
to be highly diluted with water forpenetro'lon
during apciicatlcn, yet stli: abfe to polymerize
and form a cohesive matrix within tha soil
once the water evaporates Spectof addi-
tives further improve me ability of the SOIL
SEAL* solution to first penetrate the soli mete-
rtcis cn.d then to harden for maximum hold-
ing power PENETRATION and HOLDING
POWER • two of the Ihrea unique factors,
Cheeper polymers may br'efly hold against wind and wafer, but the sun (force number three)
passes final judgement When It comes to an environmentally acceptable base material that
Is effective for sci surface stabilization, a pure acrylic copolymer Is unsurpessed in Its resistance
to breakdown under ultraviolet eoosjre SOIL SEAL* is formulated with a pure aerytio base,
allowing for max.mum dilution, maximum penetration and durability. We have single treat-
ments s*iil prov dmg dust con"ci and ercsien control over four years after application
SOIL SEAL* PROMOTES VEGETATION!
if ycu want to w-eeo an crea of Para earth *|n control' end free of vegetation, first oppiy an
appropriate pre • emergen* he'eoae. Otherwise, nc'urally dispersed seed will be given a
major bcost in effectiveness as tne soil surface is hsla m place by The SOIL SEAL* treatment,
providing a staple garmmc'-on oec SOIL SEAL* is fcmJofed to reinforce the colllty of the soli
surface to snea sheer vote' flow ye' s»U* be permecole to the gradual moisture Infiltration
needed to s^ooor: vegetation
sQt a more derive ooproocn to revogetanan. SOIL S5AL* is state - cf • the • art cs a tackifier for
less. T.uicn one soil.' SOIL SEAL* r.a been elective in promoting vege'don cn neor vertical,
crumohng slopes turning the"* green with growing gross cover. Vv*en success of o
revegetoricr. program U cincC'. SOIL SEAL* is your best insuronce.
DUST CONTROL AND V/ATER CONSERVATION
Federal PN*J teg-Jctlcr, - and lo :c* county end city regulations tor tne contra! of fugitive dust
o e puting p *-i»sgre or c^on^ witn a lot of disturbed ground to hold |n place Agencies,
'ndus**1/. developed crc cC'""cc»ors con ceil on SOIL SSAL1 to provide a dollar saving
alternative to Inetective spray t, eotmenrs one to provide o water - conserv'ng alternative
to daily cus' conrroi watering
PRODUCT APPLICATIONS:
BARE EARTH
I 1 fhiv Conhni ft ll|ow tUtfid Moliili/nfmO
EZ31 injkio Control for IcmpoKiry ft
K".imonr:rti Closure- Cuf»'.
CT! Moirii».f ionc«v oi I IMHUH'. ft
Uin/il ot WOy.'.
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SOIL SEAL* Easy to Apply, Environmentally Acceptable, Tenacious In Holding Soil In Place.
SOIL seAL* Is a registered tradamork of th* Soil Seal Corporation
" Copyjijht 1990 SSPCO.
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Ca// Toil Free at 1 ($00) 523-9992
P.O. Box 2779, Merced, CA 95344 [phone] Fax [phone]
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Featuring: A patented h,gn grade copolymer formulation tor soil
surface stabilization. This product sets the standard for
durability, envro.nmental acceptability and ease of
aool'Carion. • SOIL
SEAL Erosion Control
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* Irritation. Wash all clothing and exposed ereaa of the body twice with soap and water.
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RESPIRATORY (SPECIFY): KIOSH approved cheaieal cartridge respirator, if necessary.
OTHER (SPECIFY): Ute protective equipment es condl jtions nocet
PERSONAL HYGIENE PRACTICES: Contact lenses should] not be worn when handling thla material. Oo not smoke or eat in areas •
where thi* a*teriat it handled. Wash hands thoroughly before eating or smoking. *
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ENCIMEENUG CONTROLS: All operations should be conducted in well-ventilated conditions. Local exhaust ventilation should *
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•
LEAK AM SPILL PROCEDURE: For smell spills use suitable absorbent material and eollect for later disposal. For large e
spills the area nay require diking to contain the spill. Material can then be collected (eg. -
suction) for later disposal. Wear protective equipment as needed during clean-up. After •
collection of material flush area with water. *
•
WASTE DISPOSAL METHOD: Dispose of the material in accordance with standard practice for disposal of potentially hazardous *
materials as required by applicable federal, state, or local laws. Wear protective equipment as *
necessary. *
*
HANDLING PROCEDURES AND EQUIPMENT: Protect containers against physical damage. Wear protective equipment as necessary when *
performing maintenance on contaminated equipment. *
STORAGE REQUIREMENTS: Store in dry, well ventilated area. Keep ewoy fron strong acids. *
SPECIAL SNIPPING INFORMATION: Chemicals. NOI (OUS-TOP*" Dust Control Agent and Road Stabilizer), Non-Hatardous * • ««••••••*••••••••»•»••••••••••••••••••••••••••#••*•*•••••••••••*
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"FOR CjJEMICAL EMERGENCY-
Spill, Leak, Fife, Exposure, or Accident
Call CHEKTREC - Day or Night
600-424-9300
Toil tm in ttt UiS.f Pucrtp Rico, Virgin islands,
and Canada. Fog calli originating outside the U.S.:
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SECTION 313 SUPPLIES NOTIFICATION^ this product conta]
the following, toxic chcaicel* subject to the reporti>
requirements of section 313 of the Emergency Plarfiirejl
end Ccomjnity Right-To-Know Act of 1986 end of 40 CFRJ
CAS #
Not eppl.
Based upon the criteria set forth in section 34 through 36
of the Controlled Products Regulation* -of Canada this Product
it classified as:
Not applicable
CHEMICAL NAME
Mot applicable
X BY WEIGHT
Not appl.
PREOUJTIOiaaY STATEMENT i PLEASE NOTE that-the infonaajtion contained herein is furnished without warranty of any kind.
Users should consider these data only as a supplement to other Information gathered by them and
must make independent determinations of suitability and completeness of information from all
sources to assure proper use, and disposal of these materials and the safety and health of
employees and customers.
PREPARATION INFORMATION
£ •
C * Prepared under the direction of Paul H. Rivers Ph.O.,-Director of Corporate Environmental Affairs
T * /
I * PHONE NLJNBER 317-247-8141
0 »
N * OATE: Decanter 7, 1992 • Original date of issue: April 18, 1990 a
PACE 4 OF 4
/
Exhibit 2
DOE-EM/GJ1235-2006
Office of Environmental Management - Grand Junction
UMTRA Project
Crescent Junction Project Site
Fugitive Dust Control Plan
July 2006
Work Performed Under DOE Contract No. DE-AC01-02GJ79491
for the U.S. Department of Energy Office of Environmental Management.
Approved for public release; distribution is unlimited
gNTQg
dTES
U.S. Department
of Energy
DOE-EM/GJ1235-2006
Moab UMTRA Project
Crescent Junction Site
Fugitive Dust Control Plan
July 2006
Work Performed by S.M. Stoller Corporation under DOE Contract No. DE-AC01-02GJ79491
for the U.S. Department of Energy Office of Environmental Management, Grand Junction,
Colorado
Contents
Page
1.0 Introduction 1-1
1.1 Site Location 1-1
1.2 Site History 1-4
1.3 Purpose and Need 1-4
1.4 Climatology 1-5
1.5 Regulatory Requirements 1-5
1.6 Environmental Monitoring 1-5
2.0 Site Source Information 2-1
2.1 Site Ownership and Physical Location 2-1
2.2 Source Information 2-1
3.0 Description of Fugitive Dust Emission Activities 3-1
4.0 Description of Fugitive Dust Emission Controls On-Site 4-1
4.1 High-Potential Source Areas 4-1
4.2 Moderate-Potential Source Areas 4-1
4.3 Low-Potential Source Areas 4-1
4.4 Standards, Action Levels, and Response Actions 4-2
4.5 Best Management Practices 4-3
5.0 Off-Site Fugitive Dust Emission Controls 5-1
6.0 References 6-1
Figures
Figure 1-1. Location of Crescent Junction Disposal Site 1-2
Figure 1-2. Site Map 1-3
Figure 1-3. Monitoring Locations at and Adjacent to Crescent Junction, Utah 1-7
Figure 3-1. Disposal Cell Sequence Profile 3-2
Tables
Table 4-1. Summary of Fugitive Dust Controls for the Crescent Junction Site 4-2
Table 4-2. Fugitive Dust Standards, Action Levels, and Response Actions 4-3
Appendix
Appendix A Material Safety Data Sheets for Dust Suppressants Used at the Crescent
Junction Site
Page in
End of current text
CJ—Fugitive Dust Control Plan
Doc No XO184000
Page iv
US Department of Energy
July 2006
1.0 Introduction
The State of Utah Division of Air Quality rules for the control of fugitive dust and emissions
require that all sources whose activities or equipment have the potential to produce fugitive or
airborne dust must prepare and implement a Fugitive Dust Control Plan. Accordingly, this
Fugitive Dust Control Plan (Plan) addresses the control of fugitive and airborne dust emissions
from the Crescent Junction Site of the Moab, Utah, Uranium Mill Tailings Remedial Action
(UMTRA) Project, located approximately 1.5 miles northeast of Crescent Junction, Utah.
Specifically, this Plan complies with the State of Utah rules for controlling fugitive dust
emissions as specified in the Utah Administrative Code (U.A.C.) R307-309, "Fugitive Emission
and Fugitive Dust Rule."
This Plan has been prepared to address activities and operations conducted by the U.S.
Department of Energy (DOE) to construct a disposal cell and emplace uranium mill tailings at
the Crescent Junction Site. The primary objective of this plan is to formulate a strategy for
controlling, to the greatest extent practicable, fugitive or airborne dust emissions at the Crescent
Junction Site. This will be accomplished by identifying specific sources and activities that have
the highest potential to produce or generate fugitive or airborne dust emissions. This plan
presents the engineering controls necessary to minimize and control dust emissions from those
sources and activities. As necessary, the scope of this plan will be revised to reflect changes in
DOE's dust control strategy as site conditions or activities change.
1.1 Site Location
The Crescent Junction Disposal Site is located approximately 1.5 miles east of the intersection of
U.S. Highway 191 (US-191) and Interstate 70 (1-70) and north of the Union Pacific Railroad. It
is about 30 miles north of Moab, 20 miles east of Green River, and approximately 6 miles west
of Thompson Springs (see Figure 1-1).
The disposal site is located within portions of Sections 26 and 27, T21S, R19E, Salt Lake
Principal Meridian (SLPM) (see Figure 1-2). The majority of the area that will be used for the
repository and site activities is in the NE1/4 of Section 27 and NW1/4 of Section 26; a portion of
the cell will extend into Sections 22 and 23.
DOE withdrew land from the U.S. Bureau of Land Management (BLM) for a mill tailings and
contaminated material repository and ancillary facilities (e.g., construction management trailers,
parking, vehicle wash, construction water pond). An estimated 400 acres will be impacted by
disposal activities. Once the disposal cell is completed, DOE will retain permanent ownership of
the repository, a buffer area, and access to the repository; the remaining acreage will be returned
to the BLM. The area that will be permanently withdrawn from other uses is approximately
200 acres.
The Crescent Junction Disposal Site is surrounded on three sides by land administered by BLM.
The talus slopes of the Book Cliffs delineate the northern boundary. To the east and west, the
surrounding areas are basically flat, and drainage is generally to the south and west toward the
Green River. To the south, the Union Pacific Railroad bounds the property. Farther south is
County Road 175 (CR-175) and 1-70. There are no active commercial establishments present in
the immediate area. The former Crescent Junction gas station and restaurant, now vacated, are
located approximately 1.5 miles southwest of the site at the interchange of 1-70 and US-191.
US Department of Energy
July 2006
CJ—Fugitive Dust Control Plan
Doc No X0184000
Page 1-1
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F/gt/re 7-7. Location of Crescent Junction Disposal Site
CJ—Fugitive Dust Control Plan
Doc No XO184000
Page 1-2
U S Department of Energy
July 2006
U S Department of Energy
July 2006
CJ—Fugitive Dust Control Plan
Doc No X0184000
Page 1-3
One residence is located approximately 0.25 mile south of 1-70. Thompson Springs,
approximately 6 miles to the east, has fewer than 50-full time residents. No rivers or major
drainages are present on the withdrawn disposal site property.
1.2 Site History
The Crescent Junction Disposal Site area was historically public land administered by the BLM.
It contains a cattle grazing allotment that is currently used and oil and gas leases that are
undeveloped. BLM has designated the area as access limited to existing roads. The general area
is used by wildlife for forage, nesting, and hunting by various raptors and as a wildlife migratory
corridor. Prairie dogs, raptors, bighorn sheep, antelope, chukars, and a variety of small mammals
and birds (e.g., antelope squirrel, horned lark) remain in the area part of the year or migrate
through the area.
The Crescent Junction location was identified as a disposal site during the Environmental Impact
Statement and Record of Decision process in 2005. Ownership and responsibility of the mill
tailings at the Moab Site were transferred to DOE by passage of the Floyd D. Spence National
Defense Authorization Act for Fiscal Year 2001 (Public Law 106-398). This act further
designates that the Moab Site undergo remediation in accordance with Title I of the Uranium
Mill Tailings Radiation Control Act of 1978 (UMTRCA; 42 U.S.C. 7912, as amended).
1.3 Purpose and Need
Contaminated materials associated with the former Atlas Minerals Mill at the Moab UMTRA
Site will be transported to the Crescent Junction Disposal Site and placed in a repository that will
be secure from human intrusion. This action will result in the removal of tailings materials at the
existing tailings pile, all surface contamination, and contamination from vicinity properties,
totaling approximately 12 million cubic yards (16 million tons) of contaminated materials.
The majority of contaminated materials will be transported from the Moab UMTRA Project Site
in containers by rail over the existing Cane Creek Branch of the Union Pacific Railroad. The
containers will be offloaded adjacent to the southern border of the Crescent Junction Disposal
Site, at which point they will be conveyed by truck to the disposal cell. Material that is too large
for transport by container on rail cars will be transported to the disposal site by covered truck on
US-191.
The disposal cell footprint will be excavated to a depth of approximately 20 feet. The final
footprint configuration has not yet been determined. Contaminated materials will be placed and
compacted in layers. Dust will be controlled through use of construction water. After all
materials are transported, the pile will be covered with rock/soil materials. Surrounding areas
will be reclaimed with native seed mixes approved by BLM, and all areas not necessary for
future access or study will be released back to the BLM.
Typical site activities will include a controlled access area with active tailings deposition, vehicle
washing and decontamination stations, a pond for construction water, temporary field offices,
vehicle maintenance and storage areas, a radiological control area to check worker radiation
levels, worker parking, and soil stockpile areas.
CJ—Fugitive Dust Control Plan
Doc No X0184000
Page 1-4
U S Department of Energy
July 2006
1.4 Climatology
The climate (based on Moab) of the Crescent Junction region is semiarid. Average annual
temperature is approximately 57 °F. January is the coldest month, averaging 30 °F, and July is
the warmest month, averaging 82 °F. Extreme temperatures have ranged from -18 °F in
January 1963 to 111 °F, which has occurred more than once (in July 1953 and on earlier
occasions). Temperatures of 90 °F or higher occur about 100 days per year, with about
80 percent of those occurring during June, July, and August. Temperatures below freezing
(32 °F) occur on the average of 123 days of the year with about 80 percent of those occurring
during November through February. The effects of high temperature on human comfort are
moderated by the low relative humidity, which is often less than 50 percent during the daytime
hours.
Average annual precipitation at Moab is 8 inches, distributed approximately equally among the
seasons with slight peaks during the spring and fall. Potential evapotranspiration of 50 inches per
year greatly exceeds annual precipitation. Mean pan evaporation (about 55 inches per year) and
lake evaporation (about 38 inches per year) also greatly exceed the total annual precipitation.
Thunderstorms occur about 40 days per year. Hail occurs approximately 3 days per year.
Prevailing winds in the region are southeasterly. Cold air drainage at the site can occur from the
northwest under stable conditions. The probability of a tornado is minimal. One tornado with
wind speeds of 100 miles per hour would be expected only once in approximately 100,000 years
(NRC 1999).
1.5 Regulatory Requirements
This Plan is prepared in response to State of Utah Division of Air Quality regulations for the
control of fugitive dust, as found in Section R307-205 (U.A.C., September 2001). Dust control
plans are required to minimize on-site fugitive dust from storage and handling of aggregate
materials, construction/demolition activities, mining activities, and tailings piles and ponds. The
portion of the regulations that specifically applies to the Crescent Junction Site (R307-205),
requires that "... any person owning or operating an existing tailings operation where fugitive
dust results from grading, excavating, depositing, or natural erosion or other causes in
association with such operation shall take steps to minimize fugitive dust from such activities."
This site-specific Plan will be submitted to the Executive Secretary for the Utah Division of Air
Quality in Salt Lake City, Utah, for approval and will be updated and revised as necessary to
reflect dust controls that correspond to current and on-going site activities and operations.
1.6 Environmental Monitoring
In addition to the implementation of physical dust controls, DOE has developed and
implemented an environmental air-monitoring program for the Crescent Junction Site. This
environmental air monitoring program consists of sampling airborne particulates, radon, and
direct gamma radiation at various locations along the site perimeter and at various off-site
locations. Background monitoring locations have been established to provide ambient air quality
data. The background or ambient air quality data will be compared to air quality data collected
from the on-site monitoring locations for the purposes of determining compliance with various
DOE orders and federal and state air quality regulations.
U S Department of Energy
July 2006
CJ—Fugitive Dust Control Plan
j Doc No X0184000
Page 1-5
As part of DOE's environmental air monitoring and fugitive dust control strategy, a
meteorological monitoring station has been established at the Crescent Junction Site. Wind speed
and wind direction data collected from this monitoring station will be used to determine when
site-specific action levels have been exceeded and specific dust controls (e.g., the application of
dust suppression techniques) must be initiated. In addition, personnel certified in reading opacity
measurements in the State of Utah will determine when active dust control measures should be
initiated and when specific dust generating activities (i.e., excavating, hauling, grading, etc.)
should be discontinued.
In addition to complying with the State of Utah Fugitive Dust Rule, this Plan is consistent with
the intent of complying with various DOE orders. DOE Order 5400.1, General Environmental
Protection Program, specifies that effluent monitoring and environmental surveillance be
conducted to determine the effect of DOE activities upon ".. .on-site and offsite environmental
and natural resources," and to ".. .verify compliance with applicable Federal, State, and local
effluent regulations and DOE Orders." Similarly, DOE Order 5400.5, Radiation Protection of the
Public and the Environment, requires that DOE control and monitor radiological exposures from
its facilities and activities.
The physical form of the radioactive contaminants (i.e., uranium mill tailings) to be transferred
from the Moab Site is primarily best described as a fine-grained, sand-like material that is
susceptible to wind erosion. Consequently, one of DOE's major objectives at the Crescent
Junction Site is to control and contain the off-site transport of radiological contaminants resulting
from the erosive forces of wind and storm water. This Plan outlines DOE's strategy for
controlling airborne dust emissions and minimizing/controlling the off-site transport of mill
tailings resulting from wind erosion.
A summary of air monitoring program at Crescent Junction consists of
• Five air monitoring stations to measure radon and gamma.
• One residential monitoring location approximately 1.5 miles south of the disposal cell for
radon, direct gamma, and radioparticulates (thorium-230, polonium-210, radium-226, and
total uranium in microcuries per milliliter).
Off-site air monitoring stations for radon, direct gamma, and radioparticulates consists of
• A meteorological monitoring station near Crescent Junction.
• Residential and exterior air monitoring stations for radon, gamma, radioparticulates, and
indoor direct gamma monitoring at one location in Thompson Springs.
Data collection instruments that will be used for the air-monitoring program are
• Thermoluminescent dosimeter (TLD) badges
• Radon TrackEtch cups
• Particulate sampler
Figure 1-3 presents the locations of air monitoring instruments.
CJ—Fugitive Dust Control Plan
Doc No X0184000
Page 1-6
US Department of Energy
July 2006
Thompson Springs
25 Section Numbe
N\MoM999V0020»1»02W01M5\X0ie4500mxd smtthw 7/10/2006 10 32 52 AM
Figure 1-3. Monitoring Locations at and Adjacent to Crescent Junction, Utah
End of current text
CJ—Fugitive Dust Control Plan U S Department of Energy
Doc No XO184000 July 2006
Page 1-8
2.0 Site Source Information
2.1 Site Ownership and Physical Location
As required by the Utah Division of Air Quality, the following site-specific source information is
provided:
1) Name of Operation— Crescent Junction Site of Moab UMTRA Project
2) Owner/Operator Information—U.S. Department of Energy Grand Junction office.
2597 B3/4 Road, Grand Junction, Colorado 81503. DOE Contact: Donald R. Metzler,
Federal Project Director [phone]. Plan Contact: Ed Baker [phone].
3) Physical Address of Operations—1.5 miles northeast, Crescent Junction, Utah.
4) UTM Coordinates or Longitude/Latitude of Operations:
Latitude: 38 degrees, 57 minutes, 79 seconds - North
Longitude: 109 degrees, 48 minutes, 0.1 seconds - West
Elevation: 5,130 U.S. feet above MSL
2.2 Source Information
Type of Material Processed or Disturbed—The materials of concern with respect to fugitive
dust emissions at the Crescent Junction Site will be residual uranium mill tailings and
contaminated native soils/sand. Approximately 16 million tons of uranium mill tailings and
contaminated soils will be removed from the Moab site and transported to the Crescent Junction
repository site. The majority of materials will be poorly consolidated soils that are considered to
be a "high-potential" source of fugitive dust emissions.
The points of potential emissions are the transfer point for transported material to site haul
trucks, the dumping of material into the disposal cell, and the active disposal material surface in
the cell. Another major point of potential emissions is the stockpiled soil removed from the
disposal cell. Combined, the disposal cell and stockpiled native material will constitute
approximately 80 percent of the total land surface of the Crescent Junction Disposal Site. The
remainder of the site is not considered to be a significant source of fugitive dust emissions
because of (1) The low level of past disturbances in these areas, (2) the low level of anticipated
activity occurring in these areas, and (3) The percentage of vegetative cover present within these
areas.
Source areas identified as a "moderate-potential" consist of areas that will be moderately
disturbed and temporarily stabilized, such as the office trailer staging area, access road, rail spur,
and construction water pond areas (approximately 10 percent of the total site area). Soils and
graveled surface in these areas are typically better consolidated and more stable because of
varying degrees of vegetation or rock cover. If these areas prove to be a source for fugitive dust
emissions in the future, appropriate control measures will be implemented.
U S Department of Energy
July 2006
CJ—Fugitive Dust Control Plan
Doc No X0184000
Page 2-1
Most of the "low-potential" areas are located along the site perimeter and consist of vegetated
rangeland on the margins of the site boundary. Typically, little to no activity is occurring or is
planned in these areas. The "low-potential" areas constitute approximately 10 percent of the total
site area. Consequently, DOE does not anticipate that these areas will be a significant source of
dust emissions from the facility, and no controls are planned for these areas.
Length/Duration of Construction Project—DOE is in the process of evaluating disposal action
alternatives. Depending upon which disposal alternative is ultimately selected, DOE's
responsibility for monitoring and controlling fugitive dust emissions from this site will range in
duration from approximately 10 to 20 years.
Description of Planned Activities—Contaminated materials associated with the former Atlas
Minerals Mill at the Moab UMTRA Project Site will be transported to the Crescent Junction
Disposal Site and placed in a repository of approximately 420 acres, which will be secure from
human intrusion. The repository consists of the disposal cell (approximately 200 acres), soil
stockpile areas, and support facilities for offices, rail road spur, roads, and construction water
pond.
The planned action will result in the removal of tailings materials from the Moab tailings pile,
associated surface contamination, and contaminated material from vicinity properties, for a total
volume of approximately 12 million cubic yards of contaminated materials.
The majority of contaminated materials will be transported from the Moab UMTRA Project Site
in sealed containers by rail over the existing Cane Creek Branch of the Union Pacific Railroad.
They will be offloaded adjacent to the southern border of the Crescent Junction Disposal Site, at
which point they will be conveyed in sealed containers by truck to the disposal cell. Material that
is too large for transport by container on rail cars will be transported to the disposal site by
covered truck along US-191.
The disposal cell footprint will be excavated to a depth of approximately 18 to 25 feet. The final
footprint configuration has not been determined. Contaminated materials will be placed and
compacted in layers. Dust will be controlled through use of construction water and/or dust
palliatives. After all materials are transported, the pile will be covered with rock materials.
Surrounding areas will be reclaimed with native seed mixes approved by BLM, and all areas not
necessary for future access or study will be released back to BLM.
Responsible Individuals
Donald R. Metzler, DOE Federal Project Director [phone]
Ken Karp, Contractor Project Manager [phone]
Jim Erickson, Contractor Site Manager [phone]
Ed Baker, Environmental Compliance Lead [phone]
If a subcontractor is selected and assumes dust control responsibilities, the State of Utah will be
notified.
CJ—Fugitive Dust Control Plan
Doc No X0184000
Page 2-2
U S Department of Energy
July 2006
3.0 Description of Fugitive Dust Emission Activities
Descriptions of the on-site activities that may contribute to or generate fugitive dust emissions at
the Crescent Junction Site are presented in the following text.
Types of Activity—DOE is currently in the process of performing various types of
environmental characterization activities at the Crescent Junction Site. These activities which
will provide a baseline of conditions prior to construction, include surface and ground water
monitoring, radon and direct gamma radiation monitoring, environmental air/particulate
monitoring, meteorological monitoring, and various engineering studies and surveys. Most of
these activities are non-intrusive and result in little-to-no fugitive dust emissions. Vehicles, used
to transport personnel and equipment from one location to another, may result in minimal
generation of fugitive dust.
Implementation of Fugitive Dust and Storm Water Runoff Controls During
Construction—DOE recognizes that disturbed soils, mill tailings, and residual contaminated
soils are especially vulnerable to wind and storm runoff. In an effort to contain these
contaminants and prevent their migration off the site, establishment of fugitive dust and storm
water runoff controls is a priority for DOE. Implementation of these controls will necessitate the
use of heavy equipment to construct support facilities, construct the disposal cell, construct
sediment retention basins, excavate borrow ditches, install culverts, apply dust suppressant
materials, etc. However, fugitive emissions anticipated as a result of these activities are expected
to be minimal in conjunction with extensive dust suppression activities. Whenever possible, \
construction will be phased, and each phase will include reclamation and/or permanent
stabilization. Soils will be excavated and stockpiled.
Establishing Support Offices, Access Road, and Railroad Staging Areas—DOE plans to
construct a potable water line, construction office and support trailers, and an access road in
2006. In the next 2 years power and construction water utilities will also be installed, and a
railroad staging area will be constructed. To complete these tasks, mobile office buildings will be
set up on the site, security fencing and gates will be installed, and utilities will be extended to the
new facilities. This effort will require the use of heavy equipment for a relatively short-term
duration and is not expected to result in significant fugitive dust emissions.
Preliminary Plans for Construction of Disposal Cell—The disposal cell footprint will be less
than 150 acres in size. Approximately 12 inches of topsoil-like material will be stripped and
stockpiled from the cell and support facilities. The cell will be excavated to a depth of 18 to
25 feet, and excavated material will be placed around the perimeter to construct the buttress area.
Excavation and deposition of tailings material will proceed sequentially to minimize the size of
the working area that will be exposed to wind and water erosion.
Disposal Cell Activities— Cell construction will be phased in subsections to minimize disturbed
areas and the size of soil stockpiles at any given time. Figure 3-1 presents the disposal cell
sequence profile. The cell cover will be an engineered mixture of various materials. Although
more detailed information is available in the Final Environmental Impact Statement, and
specifics may change as the design progresses, the following information is a general description
of the planned cover structure. After the tailings are placed, a compacted heavy clay borrow
U S Department of Energy
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U S Department of Energy
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layer (1.5 feet thick) will be placed over the tailings as a radon barrier. A capillary break,
consisting of sand and gravel (0.5 feet thick) will be placed over the.radon barrier. This would be
topped with a soil water storage layer (3 feet thick on the sides; 3.5 feet thick on the top), then a
vegetated layer. The vegetated layer on the top of the cell would be seeded in a 0.5-foot-thick
soil/rock admixture; on the side slopes, it would consist of a 1-foot-thick rock layer with soil fill.
Support structures, trailer staging areas, loadout areas, and most of the access roads will be
removed and reclaimed following installation of the final section of the cover,.
Waste Management Activities—For safe storage and to prevent the spread of contaminants into
the environment, petroleum-contaminated soils will be excavated and placed into a Best
Management Practice Area (BMPA) along with other consolidated waste materials. Any on-site
wastes requiring special handling or management will be identified and addressed by DOE's
waste management policy and procedures. The BMP A will be a bermed temporary storage area
that will be constructed with a polyethylene liner. Materials will be temporarily stored at this
location until a permanent disposal option is defined. The construction of this area and the
removal and excavation of various petroleum-contaminated soils will involve the use of heavy
equipment. Moderate fugitive dust emissions can be expected from these activities.
U S Department of Energy
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CJ—Fugitive Dust Control Plan US Department of Energy
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4.0 Description of Fugitive Dust Emission Controls On-Site
Fugitive dust emission controls to be used at the Crescent Junction Site are presented for each of
the potential source areas. All sources of fugitive dust emissions at the Crescent Junction Site are
related to site activities and site conditions. The routine operation of heavy equipment is not
considered to be a significant source of emissions at this site because of planned mitigation
measures.
4.1 High-Potential Source Areas
Certain portions of the Crescent Junction Site are considered to be potentially significant sources
of fugitive dust emissions and will require more active controls than other areas. These areas are
characterized by loose, poorly consolidated sediments; poor vegetative cover, and high levels of
future/anticipated activity or disturbance. Because both the native soils and uranium mill tailings
possess a silt/sand-like texture, these materials can easily become airborne given sufficient
climatic conditions (i.e., low soil moisture content, sufficient wind speeds). Consequently, DOE
has designated these areas as the highest priority in its dust control strategy. Cumulatively, these
high-potential areas consist of approximately 40 percent of the total site surface area. Table 4-1
presents the specific high-potential source areas, generally associated with the disposal cell,
rail/truck transfer station, and site work roads, and the planned dust controls to be implemented
for each of these areas.
4.2 Moderate-Potential Source Areas
Other portions of the Crescent Junction Site are considered to be moderate sources of fugitive
dust emissions and will require a less aggressive approach to dust control. These areas are
characterized by more stable soil conditions, a greater percentage of vegetative cover, lesser
quantities of radiologically contaminated materials, and moderate levels of activity. These areas
are located mostly around the disposal cell in areas used for short-term stockpiling of excavated
native material. Cumulatively, these moderate-potential areas constitute approximately
20 percent of the total site surface area. Table 4—1 presents a summary of the anticipated dust
control measures to be used in these areas.
4.3 Low-Potential Source Areas
Approximately 40 percent of the site is considered to be a low-potential source for fugitive dust
emissions. These areas include the trailer support area, railroad support area, main access road,
construction water pond, and relatively undisturbed areas. These areas are designated as having a
low potential for fugitive dust emissions because there is little continuing surface disturbances in
these areas and some areas contain vegetative cover. After the initial construction and
stabilization with dust palliative, gravel, or vegetation, the potential for fugitive dust is low.
Minimal or no dust controls are planned for these areas (see Table 4—1).
US Department of Energy
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Table 4-1. Summary of Fugitive Dust Controls for the Crescent Junction Site
Fugitive Dust Source
Dust Controls
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High
Potential
Areas
Active
Disposal Cell
Rail/Truck
Transfer Area
Tailings Pile
(Inactive sites)
Buttress
Material Area
Capped/Final
Surface Area
Site Work
Roads
Moderate
Potential
Areas
Excavated
Material
Stockpile
Areas
Utility
Corridors
Low
Potential
Areas
Trailer Support
Area
Railroad
Support Area
Main Access
Road
Construction
Water Pond
and Vegetated
Areas
4.4 Standards, Action Levels, and Response Actions
Table 4—2 presents the applicable regulatory standards and action levels relative to controlling
fugitive dust emissions at the Crescent Junction Site, and the appropriate response actions to be
implemented once it is determined that standards or actions levels have been exceeded.
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US Department of Energy
/ July 2006
An air particulate monitoring network has been implemented at the Crescent Junction Site in
accordance with DOE Order 5400.5, Radiation Protection of the Public and the Environment
and DOE's Environmental Regulatory Guide for Radiological Effluent Monitoring and
Environmental Surveillance (DOE 1991). Air-quality monitoring data are routinely collected and
reviewed to ensure compliance with DOE orders and applicable federal and state air quality
regulations. Air particulate sample locations are shown in Figure 1-3.
Table 4-2 Fugitive Dust Standards, Action Levels, and Response Actions
Standard/
Site-Specific Action Level Method of Determination Response Action
Opacity cannot exceed 20 percent
at any on-site location or source
(U.A.C. R307-309). DOE's goal at
the site boundary is 0-percent
opacity.
Visual observation by a Certified
Opacity Reader
(EPA Method 9, "Visual
Determination of Opacity
Emissions from Stationary
Sources")
Initiate immediate dust control
measures as outlined in Table 4-1.
Cease all dust-generating activities.
Sustained wind speeds exceeding
20 miles per hour
(EPA Method 9, "Visual
Determination of Opacity
Emissions from Stationary
Sources")
Real time meteorological
monitoring.
Monitor visible emissions; cease all
dust-generating activities if necessary to
maintain 20-percent opacity or less If
needed, initiate immediate dust control
measures as outlined in Table 4-1.
Cannot exceed public exposure
standards (DOE Order 5400 5)
Analysis of filters collected by
continuous air samplers.
Reassess Fugitive Dust Control Plan
and controls
4.5 Best Management Practices
The following best management practices will also be followed to help minimize and control
dust emissions at the Crescent Junction Site to the greatest extent possible:
Roads—All on-site traffic will be restricted to specific-designated roads. Off-road travel will
only be authorized on a case-by-case basis (e.g., access to a remote monitoring well). The main
access road will be gravel, treated with dust palliative or paved. Traffic on the active tailings pile
will be restricted to designated roads to minimize disturbance of previously treated/stabilized
areas. Traffic speed will also be restricted to an appropriate level on all designated roads. All
designated roads will be considered as high potential dust source areas and, as such, will be a
priority for dust controls using magnesium/calcium chloride, watering, or gravel.
Hours of Operation—This Plan will be in effect during all hours of operation at the Crescent
Junction Site. During non-business hours, there will be no activities generating dust; therefore,
dust control actions will be restricted to hours of operation only. However, as a best management
practice, if high winds are evident at the close of a business day (or immediately prior to a
weekend, holiday, etc.), site personnel should evaluate vulnerable areas and implement controls
as appropriate to minimize off-hours emissions.
Use of Dust Palliatives or Chemical Suppressants—Various chemical dust suppressants
(e.g., surfactants, salt-based soil conditioners, polymers) shall be used in accordance with the
recommended end uses for those products. For temporary dust control, a polymer may be used
U S Department of Energy
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for stabilization prior to revegetation. Site personnel shall not exceed the manufacturer
recommended application rates. Material safety data sheets (MSDSs) for all dust suppressant
materials used at the Crescent Junction Site shall be reviewed and approved by the Compliance
and Health and Safety organizations. Prior to application, site personnel shall determine and
evaluate if the use of the dust suppressant could interfere with other site monitoring activities.
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U S Department of Energy
July 2006
5.0 Off-Site Fugitive Dust Emission Controls
To minimize the potential for off-site releases or emissions, the following controls will also be
implemented:
Decontamination and Tracking Pad—Prior to leaving designated contamination areas at the
Crescent Junction Site, all vehicles and equipment will be thoroughly washed and
decontaminated at a decontamination pad using a high-pressure water wash. This practice should
minimize the potential for any tracking of sediment or contaminants off the site.
Covered Loads—Tailings material will be transported primarily to the disposal site in sealed
containers on flatbed rail cars. At the rail staging area, the containers will be transferred to haul
trucks for final transport to the disposal cell. A minor portion of oversized contaminated material
will be transported entirely by truck. All trucks hauling materials shall be covered with tarps to
minimize the loss of materials in transit and on the site. All loads shall be inspected to ensure
that they are properly covered prior to departure from both the Moab project Site and the rail
staging area.
Spill Response—In the event of a spill or release of contaminated materials off site, the spilled
materials will be immediately contained and cleaned up. Emergency spill response actions are
outlined in Section 6.0 of the Moab UMTRA Project Health and Safety Plan (DOE 2006).
U S Department of Energy
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U S Department of Energy
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6.0 References
DOE (U.S. Department of Energy), 1991. Environmental Regulatory Guide for Radiological
Effluent Monitoring and Environmental Surveillance, DOE/EH-0173T, January.
, 2006 (continuously updated), Moab UMTRA Project Health and Safety Plan, DOE-
EM/GJ1085-2006, Grand Junction, Colorado.
, DOE Order 5400.1, General Environmental Protection Program.
, DOE Order 231.1, Environment, Safety, and Health Reporting.
, DOE Order 5400.5, Radiation Protection of the Public and the Environment.
NRC (U.S. Nuclear Regulatory Commission) 1999. Final Environmental Impact Statement
Related to Reclamation of the Uranium Mill Tailings at the Atlas Site, Moab, Utah,
NUREG-1531, Vol. 1, Washington, DC
Public Law 106-398, 2001. Floyd D. Spence National Defense Authorization Act for Fiscal
Year 2001.
U.A.C. (Utah Administrative Code), 2001. R307-205,: Emission Standards: Fugitive Emissions
and Fugitive Dust, September, Salt Lake City, Utah.
, R313-15-301, Standards for Protection Against Radiation, Dose Limits for Individual
members of the Public, September 2001, Salt Lake City, Utah.
UMTRCA 42 United States Code 7912.
U S Department of Energy
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U S Department of Energy
July 2006
Appendix A
Material Safety Data Sheets for
Dust Suppressants Used at the Crescent Junction Site
1. Calcium Chloride
2. Dust Bond
3. Envirotac II
4. Magnesium Chloride
5. Soil Seal
6. SoilTac
Material Safety Data Sheet
Revision Issued: 8/19/2003 Supercedes: 8/25/2000 First Issued: 12/01/85
Section I - Chemical Product And Company Identification
Product Name: Calcium Chloride, Liquid
CAS Number: 10043-52-4 HBCC MSDS No. CC06000
HILL BROTHIR^^/^
\> 1923J 1675 NORTHMAN STREET • ORANGE. CALIFORNIA92867-3499
*frSAItTlV [phone] * FAX. [phone]
tttp /hillbrothersiccm
1675 No. Main Street, Orange, California 92867
Telephone No: 714-998-88001 Chemtrec: 800-424-9300
Section II - Composition/Information On Ingredients
Exposure Limits (TWAs) in Air
Chemical Name CAS Number % ACGIH TLV OSHA PEL STEL
Calcium Chloride 10043-52-4 24-40 N/A N/A N/A
Section III - Hazard Identification
Routes of Exposure: Calcium chloride can affect the body if it is ingested or if it comes
in contact with the eyes or skin.
Summary of Acute Health Hazards
Ingestion: Causes irritation of mouth and stomach.
Inhalation: Causes irritation of nose and throat. Additional effects may include shortness
of breath.
Skin: Causes mild irritation. Additional effects may include blisters or sores. • *
Eyes: Causes irritation and possible transient corneal injury. Tearing may occur.
Summary of Chronic Health Hazards: May cause perforation of the nasal septum and
nosebleeds. Contact with heated product can cause thermal burns with resultant corneal
injury.
Effects of Overexposure: Possible superficial burns and transient corneal injury.
Medical Conditions Generally Aggravated by Exposure: N/A
Section IV - First Aid Measures
Ingestion: If swallowed will cause nausea and vomiting. If victim is conscious, have
victim drink water or milk. If victim is unconscious or having convulsions, do nothing
except keep victim warm GET MEDICAL ATTENTION.
Inhalation: Move to fresh air; if discomfort persists, GET MEDICAL ATTENTION.
Skin: If necessary, remove contaminated clothing and shoes. Flush affected areas with
plenty of water for at least 15 minutes.
Calcium Chloride, Liquid 1
Eyes: Promptly flood with water and continue washing for at least 15 minutes. Consult
an ophthalmologist.
Section V - Fire Fighting Measures
Flash Point: Not flammable Autoignition Temperature: Not flammable
Lower Explosive Limit: N/A Upper Explosive Limit: N/A
Unusual Fire and Explosion Hazards: N/A
Extinguishing Media: This product is non-flammable.
Special Firefighting Procedures: Avoid breathing corrosive vapors; keep upwind. Dike
area to prevent runoff and contamination of water sources.
" ^ Section VI - Accidental Release Measures
Dike the spilled liquid, and either pump back into original container or cover with clay-
type substance for absorption.
Section VII - Handling and Storage
Store at ambient temperature. Prevent possible eye and skin contact by wearing
protective clothing and equipment.
Section VIH - Exposure Controls/Personal Protection
tiinmuuKm»i»u»miuiiijm»^~..-.i«i..«|.^.|lfif i| «iiii.u«ni.i-1rmu'i4<tM»HKmji.>.uj.i«rti«m-niimi .»«nu!in ii.»«.fr-r^nlfl?pi.-...jii»i.i.nrijiijiiij;iiii»LiimiM»i.»i»iuu nm«
Respiratory Protection: N/A
Ventilation: Use local exhaust in enclosed areas. Natural ventilation for outdoor areas.
Protective Clothing: Employees should be provided with and use impervious clothing,
rubber gloves, and rubber boots.
Eye Protection: Employees should be provided with and required to use splash-proof
safety goggles where there is any possibility of calcium chloride contacting the eyes.
Other Protective Clothing or Equipment: N/A
Work/Hygienic Practices: Avoid contact with the eyes, skin, and mucous membranes.
Wash hands thoroughly with soap and water before eating, drinking, smoking or using
toilet facilities. Do NOT place food, coffee or other drinks in the area where dusting or
splashing of solutions is possible. *
Section IX - Physical and Chemical Properties j
Physical State: Liquid pH: 5-9
Boiling Point/Range: 113°C for 30%
Melting Point/Range: N/A Solution; 115°C for 34.7% Solution;
118°C for 37.5% Solution
Appearance/Color/Odor: Clear to straw colored liquid, odorless
Solubility in Water: 100% Vapor Pressure(mmHg): N/A
Specific Gravity(Water=l): 1.3 @ 60°F (for
30% Solution); 1.35 @ 60°F (for 34.7% Molecular Weight: 110.99
Solution); 1.39 @ 60°F (for 37.5% Solution)
Vapor Density(Air=l): N/A % Volatiles: 70% for 33 Be: 65.3% for
Calcium Chloride, Liquid 2
37.4 Be; 62.5% for 40 Be
How to detect this compound : N/A
Section X - Stability and Reactivity
Stability: Stable Hazardous Polymerization: Will not occur
Conditions to Avoid: N/A
Materials to Avoid: Metals will slowly corrode in aqueous solutions. Keep away from
galvanized iron, aluminum, and tin. Boric acid and calcium oxide are incompatible.
Hazardous Decomposition Products: If liquid completely dries from fire, thermal
decomposition products may include toxic and corrosive fumes of chlorine and hydrogen
chloride. Product may react with some metals (aluminum, zinc, tin, etc.) to release
flammable hydrogen gas.
Section XI - Toxicological Information
N/A
Section XII - Ecological Information
V MHH1HW IIIIHHWM jrt>«wnwflaij:
N/A
Section XIII - Disposal Considerations
Add to large volume of water. Dispose of in accordance will local, state and federal
regulations.
r Section XIV - Transport Information
DOT Proper Shipping Name: N/A
DOT Hazard Class/ I.D. No.: N/A
Section XV - Regulatory Information
Reportable Quantity: N/A
NFPA Rating: Health -1; Fire - 0; Reactivity - 0
0=lnsignificant l=Slight 2=Moderate 3=High 4=Extreme *
Carcinogenicity Lists: No NTP: No IARC Monograph: No OSHA Regulated:"No
Section XVI - Other Information
Synonyms/Common Names: Calcium Chloride-Liquid
Chemical Family/Type: Inorganic Salt
Sections changed since last revision: V, Vm, DC, X, XJU
IMPORTANT! Read this MSDS before use or disposal of this product. Pass along the
information to employees and anv other persons who could be exposed to the product to
be sure that they are aware of the information before use or other exposure. This MSDS
has been prepared according to the OSHA Hazard Communication Standard [29 CFR
1910.1200]. The MSDS information is based on sources believed to be reliable.
However, since data, safety standards, and government regulations are subject to change
and the conditions of handling and use, or misuse are beyond our control, Hill Brothers
Chemical Comuanv makes no warranty, either exnressed or irm>lied. with resDect to the
Calcium Chloride, Liquid 3
completeness or continuing accuracy of the information contained herein and disclaims
all liability for reliance thereon. Also, additional information may be necessary or helpful
for specific conditions and circumstances of use. It is the user's responsibility to
determine the suitability of this product and to evaluate risks prior to use, and then to
exercise appropriate precautions for protection of employees and others.
Calcium Chloride, Liquid 4
MATERIAL SAFETY DATA SHEET
PflOOUCr NAME-
DUST BOND'
MANUFACTURER:
D*DEalULSIONS,mCt
370 PARK AVENUE EAST
P.O. BOX 1706
MANSFIELD, OH 44901
PHONE: M19) S2&4088
(419) S22-S440
FAX: [phone]
NFPA CLASSIRCATIQN
0 s" LEAST HEALTH
1= SLIGHT FIRE
2 *» MODERATE REACTIVITY
3 = HIGH
4 = EXTREME
SECTION I - COMPONENT DATA
CNEMICAL COMPONENTS %WT
Pefroteotn Ftesin CAS46474&047 '
and/or 64742-11-6 and/or6474334-3 60+
Emursrfiers and Water 40
SECTION n - PHYSICAL DATA
CHEMICAL NAME: Petroleum hydrocarbon in
w»Wn emufcstort.
BOILING POINT fF): 212°
VAPOR PRESSURE (mmHg @ 20°C): Same as
Water.
VAPOR DENSTTY (AfR = t): Same as Water.
SOLUBILITY IN WATER; Readftydisp^rsaile.
SPECIFIC GRAVTTY (Hjdol): Approx. 1.
VOLATILE (BY WT.): nO.
EVAPORATIVE RATE (WATER = 1): Svne as
Water.
pH INFORMATION: 4.5-6.5.
APPEARANCE AND ODOR: Yefow^rown color,
no obtocSonable Odor.
SECTION Ul - FIRE * EXPLOSION HAZARD
DATA
FLASH POINT (°F): N/A
METHOD USED: C.Q.C.
FLAMMABIUTY LIMITS (K VOL): N/A
AUTCMGNmON TEMPERATURE (°F): N/A
LELtN/A UEL: N/A
EXTINGUISHING MEDIA: COj, Foam, Dry
Ctwmicai, WafBffbg.
SPECIAL RRE FIGHTING PROCEDURES:
Dense smoto may result Proper protocfivs
eqixprnentirtduOingsel^cxxitair^
apparatus should be worn.
SECTION IV -REACTIVITY DATA
STABtt.rrr (CONDmONSTOAVOlD): Material
instable. Avoid ten^«ralureabovo1800F and
INCOMPATIBILITY (MATERIALS TO AVOID):
Strong oxkfzerssueh as hydrogen peroxide,
bromine and chromic add.
HAZARDOUS DECOMPOSITION PRODUCTS:
Carbon monoxide and carbon dxxtide from
burryng. Oxides of nfaxjenandsuJIurrnay
HAZARDOUS POLYMERIZATION: N/A
SECTION V- HEALTH HAZARD DATA
PRIMARY ROUTERS) OF ENTRY: SHn contact
eyas, inhalation, ingestion.
EFFECTS OF EXPOSURE:
INHALATION: Protonged extreme exposure
to high conoanbafions of mist may causa
branchial or lung inflation.
StON CONTACT: 1ARC has determined that
bam ofosfrnflar to those under the
classificaSon CAS number64742-04-7or
64742-11-6 or64742-34-3 may cause
carcinogenic effects trt laboratory animals
through direct contact with their skin tor long
periods of-time. Our errxssifed base oils,
property handed as outlined tii 1MB MSDS, are
not expected to have any harmful effedsto
EYE CONTACT: May cause rnSdinftafjea
INGESTION: May cause trraafion of the
EXPOSURE LIMITS:
CHEMCAL OSHA PSI 8 HOUR/TWA OTP »BC
OOMPON&ftS fctofaol fcngfrei USTCD USTCQ
OSMfet NO YES
SECTION VI-EMERGENCY & FIRST-AID
PROCEDURES
INHALATION: Remove exposed parson to tresh
air.
SKIN; Wash exposed area wjtfi soap and water.
EYES: Flush with wafer for 15 minutes. Cal
physician.
INGESTION: CaB physician imrnediatery.
SECTION VII - SPECIAL HANDLING
INFORMATION
VENTILATION TYPE REQUIRED: Local if
necessary to maintan-* afiowabte PEL
(pem*safrteexj>csurer^orUV(t^^
limit value),
RESPIRATORY PROTECT10N(«pecify iype):
Use NIOSH/MSHA certified respirator with
organio vapor cartridge ff vapor concentration
nwrandn uciniKiStbte exposure inuL
PROTECTIVE GLOVES: 08 resistant
EYE PROTECTION: Chemical safety
OTHER PROTECTIVE EQUIPMENT: None.
SECTION VIO - SPILL, LEAK* DISPOSAL.
PROCEDURES
ACTION TO TAKE FOR SPILLS (USE
APPROPRIATE SAFETY EQUIPMENT):
Absorb in vamrieuB*. dry sand, maiHt, or
sirnQar material and oppose of art accordance
with Federal State* and Local regutafions.
WASTE DISPOSAL METHOD: Material is not
SECTION K - SPECIAL PRECAUTIONS:
PRECAUTIONS TO BETAKEN IN HANDLING.
AND STORAGE:
Avoid prolonged or repeated contact wBh stdn
or breathing of vapors, mists, orturnes.
Launder conlaiiunated dcflhtog before reuse.
Keep container? fightty cfosed. Avoid strong
oxkJfeera. EftrrinateeJI sources of ignition
such as flames or sparks.
SECTION X - TRANSPORTATION DATA
D.O.T. INFORMATION: Not regulated.
HAZARDOUS MATERIAL PROPER SHIPPING
NAME: N/A
HAZARD CLASS: N/A
IDENTIFICATION NUMBER: N/A
EPA HAZARDOUS WASTE NUMBER: N/A
SECTION XI - ENVIRONMENTAUSAFETY
REGULATIONS
SECTION 313 (TITLE III SUPERFUND
AMENDMENT AND REAUTHORIZATION
ACT): Thfe product does not contain any
chemk^suciecttoihereporDng
reauireniBntsolSec^313ofTHtenfc4tr^
Superfund AmenAnems and Reauthorization
Act of 19B6 and 40 CFR Part372.
iwnra^Tiotiic&tt-Aira MrjwB/s^T>«»«jro^Tic«isr*^
OftMPUB).
6£CAUSETHEMM«XM^SToR«6^ USEM^ Ot^^
FOR LOSS. QAMAOg OR EXPENSE FffOM "ffiE HWOUNO. STORAGE, USB OR DSPOSAL OF THE PftQOUCT. -
Superset 02/01/Di
Revised 02/01 A%
a^€nvironmental
•Products &
Tippli cations. Inc.
PO Box 786, Gilbert, RZ 85299-0786
Phone [phone] Fax: [phone]
€mall !nfb@€nvirotac com Website- uuujuj.envirotac com
"Protecting Our €nvironm&nt From Che Ground Up"
Envirotac II®
Material Safety Data Sheet (page 1/4)
Vinyl Acetate / Acrylic Copolymer
1. CHEMICAL PRODUCT AND COMPANY IDEITICATION
Envirotac II9 Soil Stabilizer / Dust Palliative
MSDS Date: 3/22/00
COMPANY IDENDIFICATION Vermillion's Environmental Products & Applications, Inc. (EP&A, Inc.)
PO Box 786, Gilbert, Arizona 85299-0786
Envirotac® is a registered trademark of Vermillion's Environmental Products and Applications, Inc.
EMERGENCY TELEPHONE NUMBERS HEALTH EMERGENCY [phone]
SPILL EMERGENCY [phone]
2. COMPOSITION/INFORMATION ON INGREDIENTS
No CAS REG NO WEIGHT (%)
1 Acrylic copolymer Not Hazardous. 39-43
2 Individual residual monomers Not Required <0.1
3 Aqua ammonia 1336-21-6 <1 0
4 Water 7732-18-5 " ^57-61
See SECTION 8, Exposure Controls / Personal Protection
3. HAZARDS IDENTIFICATION
Primary Routes of Exposure Inhalation, Eye Contact and Skin Contact
Inhalation Inhalation of vapor or mist can cause the following: -headache -nausea -irritation of nose, throat,
and lungs
Eye Contact Direct contact with material can cause the following: -slight irritation
Skin Contact Prolonged or repeated skin contact can cause the following: -slight skin irritation
4. FERST AID MEASURES
Inhalation Move subject to fresh air.
Eye Contact Flush eyes with water. Consult a physician if irritation persists.
Skin Contact. Wash affected skin area thoroughly with soap and water. Consult a physician if irritation persists.
Ingestion If swallowed, give 2 glasses of water to drink. Consult a physician. Never give anything by
mouth to an unconscious person.
5. FIRE FIGHTING MEASURES
Flash Point Noncombustible
Auto-ignition Temperature Not Applicable »
Lower Explosive Limit Not Applicable /
Upper Explosive Limit. Not Applicable
Unusual Hazards Material can splatter above 100C/212F. Dried product can burn.
Extinguishing Agents Use extinguishing media appropriate for surrounding fire.
Personal Protective Equipment. Wear self-contained berating apparatus (pressure-demand NIOSH approved or
equivalent) and full protective gear.
6. ACCIDENTAL RELEASE MEASURES
Personal Protection Appropriate protective equipment must be worn when handling a spill of this material. See
SECTION 8, Exposure Controls/Personal Protection, for recommendations. If exposed to
material during clean-up operations, see SECTION 4, First Aid Measures, for actions to
follow.
Procedures Keep spectators away. Floor may be slippery; use care to avoid falling. Contain spills
immediately with inert materials (e.q. sand, earth). Transfer liquids and solid diking material
to separate suitable containers for recovery or disposal.
CAUTION Keep spills and cleaning runoff our of municipal sewers and open bodies of water.
7"i,02
Envirotac IP
The environmental Solution for Soli Stabilization (Dust Si €rosion Control)
^Environmental PO BOX 786, Gilbert, AZ 85299-0786
|L p , y. r- Phone- [phone] Fax- [phone]
J||prrOOUCC5 Ql €mail: lnrb@€nvirotac com UUebslte. wiuiu.envirotac com
PRpplicationS. Inc. "Protecting Our Environment:From the Ground Up"
Envirotac II®
Material Safety Data Sheet (page 2/4)
7. HANDLING AND STORAGE
Storage Conditions Keep from freezing; material may coagulate. The minimum recommended storage
temperature for this material is 1C/34F. The maximum recommended storage
temperature for this material is 49C/120F.
Handling Procedures Monomer vapors can be evolved when material is heated during processing operations.
See SECTION 8, Exposure Controls/Personal Protection, for types of ventilation
required.
8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Exposure Limit Information
No CAS REG NO WEIGHT (%)
1 Acrylic copolymer Not Hazardous 39-43
2 Individual residual monomers Not Required <0.1
3 Aqua ammonia. 1336-21-6 .... <1.0
4 Water 7732-18-5™™""""57-61
Comp. EP&A. Inc. OSHA ACGIH
No. Units TWA STEL TWA STEL TWA STEL
1 None None None None None None
2 a a a a. a. a
3 j?pm 25 b 35 b ."..* None™.™"™""'35 b™™™™™"25 b....! ""..35 b
4 None None None None None None
a. ...Not Required
b. ... As Ammonia
Respiratory Protection A respiratory protection program meeting OSHA 1910.134 and ANSI Z88.2
requirements or equivalent must be followed whenever workplace conditions
warrant a respirator's use. None required if airborne concentrations are
maintained below the exposure limit listed in 'Exposure Limit Information'.
For airborne concentrations up to 10 times the exposure limit, wear a properly
fitted NIOSH approved (or equivalent) half-mask, air-purifying respirator. Air
purifying respirators should be equipped with NIOSH approved (or equivalent)
ammonia/methylamine cartridges and N95 filters. If oil mist is present, use
R95 or P95 filters. . *
Eye Protection Use safety glasses with side shields (ANSI Z87.1 or approved equivalent). Eye
protection worn must be compatible with respiratory protection system
employed.
Hand Protection The glove(s) listed below may provide protection against permeation. Gloves
of other chemically resistant materials may not provide adequate protection: -
Neoprene
Engineering Controls (Ventilation)...Use Local exhaust ventilation with a minimum capture velocity of 100 ft/min.
(0.5 m/sec.) at the point of vapor evolution. Refer to the current edition of
Industrial Ventilation: A Manual of Recommended Practice published by the
American Conference of Governmental Industrial Hygienists for Information
on the design, installation, use, and maintenance of exhaust systems.
Other Protective Equipment: Facilities storing or utilizing this material should be equipped with an eyewash
facility.
7-V02
Envirotac IP
The environmental Solution For Soil Stabilization (Dust & €rosion Control)
.Environmental P° S°X 78°. Gilbert, AZ 85299-0786
D 1 u r Phone- [phone] Fox- [phone]
I rOOUCtS & €mQ,l |[e-mail] Website ujujuj.envirotoc.com
flppljCations. InC "Protecting Our Environment from the Ground Up"
Envirotac II®
Material Safety Data Sheet (page 3/4)
9. PHYSICAL AND CHEMICAL PROPERTIES
Appearance Milky
Color White
State Liquid
Odor Characteristic Ammonia odor
PH ....... 5.0 to 9.5
Viscosity 1500 CPS Maximum
Specific Gravity (Water = 1) 1.0 to 1.2
Vapor Density (Air = 1) <1 Water
Vapor Pressure 17 mm Hg @ 20°C/68°F Water
Melting Point 0°C/32°F Water
Boiling Point 100°C/212°F Water
Solubility in Water Dilatable
Percent Volatility 57to 61% Water
Evaporation Rate (Bac = 1) <1 Water
The physical and chemical data given in Section 9 are typical values for this product and are not intended to be
product specifications.
See Section 5, Fire Fighting Measures
10. STABILITY AND REACTIVITY
Instability This material is considered stable. However, avoid temperatures above
177C/350F, the onset of polymer decomposition. Thermal decomposition is
dependent on time and temperature
Hazardous Decomposition Products Thermal decomposition may yield acrylic monomers.
Hazardous Polymerization Product will not undergo polymerization.
Incompatibility There are no known materials which are incompatible with this product.
11. TOXICOLOGICAL INFORMATION
Acute Data No Toxicity data are available for this material.
The information shown in SECTION 3, Hazards Identification, is based on the toxicity profiles for
a number of acrylic emulsions that are compositionally similar to this product. Typical data are*
Oral LD50 rat >5000 mg/kg
Dermal LD rabbit ...>5000 mg/kg *
Skin irritation rabbit ....practically non-irrupting ,<:
Eye irritation rabbit ...inconsequential irrational
12. ECOLOGICAL INFORMATION
No Applicable Data
13. DISPOSAL CONSIDERATIONS
Procedure Coagulate the emulsion by the stepwise addition of ferric chloride and lime. Remove the clear
supernatant and flush to a chemical sewer.
Landfill or incinerate remaining solids in accordance with local, state and federal regulations.
14. TRANSPORT INFORMATION
US DOT Hazard Class NONREGULATED
Envirotac IP
The environmental Solution for Soil Stabilization (Dust <S Erosion Control)
/
Environmental PO Sox 786. Gilbert, AZ 85299-0786
||lLp , . «- Phone [phone] Fox- [phone]
•oouccs ^* €moll lnfo@€nvi rotac.com Website: UJUJUJ envirotac.com
fipplicationS. Inc. "Protecting Our environment: from Che Ground Up"
Envirotac Ii®
Materral Safety Data Sheet (page 4/4)
15. REGULATORY INFORMATION
Workplace Classification .This product is considered non-hazardous under the OSHA Hazard Communication
Standard (29CFR 1910.1200).
This product is not a 'controlled product' under the Canadian Workplace Hazardous Materials Information System
(WHMIS).
SARA TITLE 3: Section 311/312 Categorizations (40CFR 370) This product is not a hazardous chemical
under 29CFR 1910.1200, and therefore is not covered by Title IH of SARA
SARA TITLE 3: Section 313 Information (40CRF 372) This product does not contain a chemical which is
listed in Section 313 at or above de minimis concentrations.
CERCLA Information (40CFR 302.4). Releases of this material to air, land, or water are not reportable to the
National Response Center under the Comprehensive Environmental Response, Compensation,
Liability Act (CERCLA) or to state and local emergency planning committees under the
Superfund Amendments and Reauthorization Act (SARA) Title III Section 304.
Waste Classification When a decision is made to discard this material as supplied, it does not meet RCRA's
characteristic definition of ignitability, corrosively, or reactivity, and is not listed in 40 CFR
261.33. The toxicity characteristic (TC), however, has not been evaluated by the Toxicity
Characteristic Leaching Procedure (TCLP).
United States All components of this product are in compliance with the inventory listing requirements of the
U.S. Toxic Substances Control Act (TSCA) Chemical Substance Inventory.
Pennsylvania Any material listed as "Not Hazardous" in the CAS REG NO column of SECTION 2,
Composition/Information On Ingredients, of this MSDS is a trade secret under the provisions of
the Pennsylvania Worker and Community Right-to-Know Act.
16. OTHER INFORMATION
HMIS Hazard Ratings .HEALTH = 1, FLAMMABILITY = 0, REACTIVITY = 0.
PERSONAL PROTECTION: See Section 8, Exposure Controls/Personal Protection for
recommended handling of material as supplied; check with supervisor for your actual use
condition.
Scale: 0 = Minimal, 1 = Slight, 2 = Moderate, 3 = Serious, 4 = Severe
* = Chronic Effects (See Section 3, Hazards Identification)
HMIS is a registered trademark of the National Paint and Coatings Association.
ABBREVIATIONS ACGIH American Conference of Governmental Industrial Hygienists
OSHA. Occupational Safety and Health Administration k
TLV Threshold Limit Value
PEL .'.Permissible Exposure Limit
TWA Time Weighted Average
STEL Short-Term Exposure Limit
BAc Butyl acetate
^ 1 Bar denotes a revision from previous MSDS in this area
The information contained herein relates only to the specific material identified Vermillion's Environmental Products and Applications, Inc
believes that such information is accurate and reliable as of the date of this material safety data sheet, but no representation, guarantee or
warranty, expressed or implied, is made as to the accuracy, reliability, or completeness of the information Vermillion's Environmental Products
and Applications, Inc urges persons receiving this information to make their own determination as to the information's suitability and
completeness for their particular application
7^,02
Envirotac IP
Tha Environmental Solution for Soil Stabilization (Dust& Eros/on Control)
MAGNESIUM CHLORIDE Page 1 of 7
MSDS Number: M0156 ***** Effective Date: 11/04/04 ***** Supercedes: 03/28/02
MSDS Material Safety Data SheeTJ
From: MalHrtckrodt BakerJne.
222 Rod School Larto
Philltpsburg, NJ 09865
f 1 MaUincfcrodt
k i ' CHEMICAL JXBafcer
Erawaofwy TotephoM: 40S"«S>-aiSl
CHEMTffEC: 1-8W-424-W&0
NAJCOAI Re*po<t*9 In Caiwda
CAKUTEC: *l3.«tt-««*
0-l_Jd« UJS.4rtd Canada
Chemtt«:
"NOTE: CHEWT^TCANUTEC andVtotowl"
R^sporce Q*f#t flroergerey numbers to b*
uMd criV r ii* *v*« efi*fr»_a6*m»r9*na>»»
ifworvmg a spii ktaK, ftr#. expesuce or __o*3ttrtl
Involving chemicals.
All ftcan-ftrnefgency quiwilon& should be directed to Customer Service (I-80Q-S-B2-2537) lor asslmareo.
MAGNESIUM CHLORIDE
1. Product Identification
Synonyms: Magnesium chloride, hexahydrate; Magnesium chloride, 6-hydrate, crystal
CAS No.: 7786-30-3 (Anhydrous); 7791-18-6 (Hexahydrate)
Molecular Weight: 203.30
Chemical Formula: MgC12 6H20
Product Codes:
J.T. Baker: 2444, 2448, 2449, 2450, 4003, 5183
Mallinckrodt: 12131, 5910, 5933, 5954, 5956, 5958, 5960, 7550, 7791
2. Composition/Information on Ingredients
Ingredient CAS No Percent Hazardous
Magnesium Chloride 7786-30-3 98 - 100% Yes
3, Hazards Identification
Emergency Overview
ht1p://ww.jtbaker.corr^ 7/20/2006
MAGNESIUM CHLORIDE Page 2 of 7
CAUTION! MAY BE HARMFUL IF SWALLOWED.
SAF-T-DATA^ Ratings (Provided here for your convenience)
Health Rating: 1 - Slight
Flarnmability Rating: 0 - None
Reactivity Rating: 1 - Slight
Contact Rating: 1 - Slight
Lab Protective Equip: GOGGLES; LAB COAT; PROPER GLOVES
Storage Color Code: Green (General Storage)
Potential Health Effects
Inhalation:
Inhalation of dust may cause mild irritation to the mucous membranes.
Ingestion:
Since magnesium salts are slowly absorbed, abdominal pain, vomiting and diarrhea may be
the only symptoms. However, if elimination is blocked by bowel blockage or other reasons,
CNS depression, lack of reflexes, hypocalcemia (deficiency of calcium in the blood) may
occur.
Skin Contact:
No adverse effects expected but may cause minor skin irritation.
Eye Contact:
No adverse effects expected but dust may cause mechanical irritation.
Chronic Exposure:
No information found.
Aggravation of Pre-existing Conditions:
No information found.
4. First Aid Measures
Inhalation:
Remove to fresh air. Get medical attention for any breathing difficulty.
Ingestion:
Give several glasses of water to drink to dilute. If large amounts were swallowed, get
medical advice.
Skin Contact:
Remove any contaminated clothing. Wash skin with soap and water for at least 15 minutes.
Get medical attention if irritation develops or persists.
Eye Contact:
Wash thoroughly with running water. Get medical advice if irritation develops.
Note to Physician:
IV administration of calcium gluconate will partially reverse the effects of acute magnesium
toxicity. Ventricular support with calcium chloride infusion and mannitol forced diuresis
has also been successful.
http://www.jtbaker.com/msds/englishhtml/MO 156.htm 7/20/2006
MAGNESIUM CHLORIDE Page 3 of 7
5. Fire Fighting Measures
Fire:
Not considered to be a fire hazard.
Explosion:
Not considered to be an explosion hazard. At room temperature the addition of magnesium
chloride to furan-2-peroxycarboxylic acid, will cause the acid to explode.
Fire Extinguishing Media:
Use any means suitable for extinguishing surrounding fire.
Special Information:
In the event of a fire, wear full protective clothing and NIOSH-approved self-contained
breathing apparatus with full facepiece operated in the pressure demand or other positive
pressure mode.
6. Accidental Release Measures
Ventilate area of leak or spill. Wear appropriate personal protective equipment as specified
in Section 8. Spills: Sweep up and containerize for reclamation or disposal. Vacuuming or
wet sweeping may be used to avoid dust dispersal.
7. Handling and Storage
Keep in a tightly closed container, stored in a cool, dry, ventilated area. Protect against
physical damage. Isolate from incompatible substances. Containers of this material may be
hazardous when empty since they retain product residues (dust, solids); observe all
warnings and precautions listed for the product. . -*
8. Exposure Controls/Personal Protection
Airborne Exposure Limits:
None established.
Ventilation System:
A system of local and/or general exhaust is recommended to keep employee exposures as
low as possible. Local exhaust ventilation is generally preferred because it can control the
emissions of the contaminant at its source, preventing dispersion of it into the general work
area. Please refer to the ACGIH document, Industrial Ventilation, A Manual of
Recommended Practices, most recent edition, for details.
Personal Respirators (NIOSH Approved):
For conditions of use where exposure to dust or mist is apparent and engineering controls
are not feasible, a particulate respirator (NIOSH type N95 or better filters) may be worn. If
http ://www.jtbaker .com/msds/englishhtml/MO 15 6.htm 7/20/2006
MAGNESIUM CHLORIDE Page 4 of7
oil particles (e.g. lubricants, cutting fluids, glycerine, etc.) are present, use a NIOSH type R
or P filter. For emergencies or instances where the exposure levels are not known, use a
full-face positive-pressure, air-supplied respirator. WARNING: Air-purifying respirators do
not protect workers in oxygen-deficient atmospheres.
Skin Protection:
Wear protective gloves and clean body-covering clothing.
Eye Protection:
Use chemical safety goggles. Maintain eye wash fountain and quick-drench facilities in
work area.
9. Physical and Chemical Properties
Appearance:
Colorless flakes or crystals.
Odor:
Odorless.
Solubility:
167g/100ml water @ 20C (68F)
Density:
1.57
pH:
5% in water is neutral to litmus.
% Volatiles by volume @ 21C (70F):
0
Boiling Point:
Not applicable.
Melting Point:
118C (244F)
Vapor Density (Air=l):
No information found.
Vapor Pressure (mm Hg):
No information found.
Evaporation Rate (BuAc=l):
No information found.
10, Stability and Reactivity
Stability:
Stable under ordinary conditions of use and storage. By strong ignition is converted into
oxy chloride.
Hazardous Decomposition Products:
When heated to decomposition it emits corrosive hydrochloric acid vapor. When heated to
temperatures above 300C (572F) it emits toxic fumes of chlorine gas.
Hazardous Polymerization:
Will not occur.
Incompatibilities:
http ://www.jtbaker.com/msds/enghshhtml/MO 156.htm 7/20/2006
MAGNESIUM CHLORIDE Page 7 of 7
makes no representation as to its comprehensiveness or accuracy. This document is
intended only as a guide to the appropriate precautionary handling of the material by
a properly trained person using this product. Individuals receiving the information
must exercise their independent judgment in determining its appropriateness for a
particular purpose. MALLINCKRODT BAKER, INC. MAKES NO
REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED,
INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE WITH
RESPECT TO THE INFORMATION SET FORTH HEREIN OR THE PRODUCT
TO WHICH THE INFORMATION REFERS. ACCORDINGLY, MALLINCKRODT
BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAMAGES RESULTING
FROM USE OF OR RELIANCE UPON THIS INFORMATION.
**************************************************
Prepared by: Environmental Health & Safety
Phone Number: [phone] (U.S.A.)
http://www.jtbaker.com/msds/englishhtml/M0156.htm 7/20/2006
9
<\ fl(»jiewrcd TrauViirarx j/
Sutl SlBlilLculran f*mdudn Ci , inc
SOIL STABILIZATION PRODUCTS COMPANY, IN
P.O. Box 2779, Merced, CA 95;
Phone: [phone] or (800) 523-9<
Fax: [phone] E-mail: info@sspco.c
Environmentally Appropriate Product Technologi
for Pavements, Dust Control, Erosion Control & Soil Stabilizath
MATERIAL SAFETY DATA SHEET
SOIL SEAL® CONCENTRATE
I. PRODUCT IDENTIFICATION
PRODUCT OR TRADE NAME:
INFORMATION FURNISHED BY:
ADDRESS:
DATE PREPARED:
EMERGENCY PHONE #:
Chemical Family
DOT Shipping Name
DOT Status
II. OSHA REGULATED INGREDIENTS
SOIL SEAL® Concentrate
Soil Stabilization Products Company, Inc
P.O. Box 2779, Merced, CA 95344
January 9, 2006
[phone] or [phone]
Acrylic Polymer product In water
Acrylic Polymer product in water
Not regulated
ingredients
ACRYLIC POLYMER
WATER
AMMONIA
CAS#
Non Haz
Non Haz
7684-41-7
OSHA PEL ACGIH TLV
NE
NE
NE
NE
NE
25 ppm
Approx. % bv Wt
46-48%
54-52%
0.2% Max
NOTE: See section XII for other regulatory information
III. PRECAUTIONARY INFORMATION
• Product is not considered hazardous under normal conditions.
• Diiect contact of product with eyes can cause irritation.
• Prolonged or repeated contact with skin may cause irritation.
IV. EMERGENCY and FIRST AID PROCEDURES
Eye Contact
Skin Contact
Inhalation
Ingestion
Fire
Spill
Flush eyes immediately with water for at least "-5 minutes. Consult a physician tf irritatx
persists.
Wash affected skin areas with soap and water. Wash contaminated clothing before reuse.
Move subject to fresh air.
If swallowed, dilute by giving 2 glasses of water to drink. See a physician. Never give anythir
by mouth to an unconscious person.
Product is non-flammable in the liquid state. Use water spiay, foam, dry chemical of carbc
dioxide on dried product.
Collect and remove using inert absorbent. Contain spill entering sewers. Notify appropnat
agencies
5051.SS Soil Seal is a registered trademark of Soil Seal Corporation
Page 1 of 3
Ref11/09/06
v. PHVSICAL CHARACTERISTICS
Physical State Milky liquid
Boiling Point *200* F
Weight per gallon 8.85 lbs./gal.
Solubility in Water Dilutable
VI. PERSONAL PROTECTION EQUIPMENT
Eyes Wear chemical safety goggles to reduce the potential for eye contact. Eye wash fountain should be availabi
Skin Us© impermeable chemical gloves and wear appropriate protective cothing. Launder contaminated clothit
before reuse.
Respiratory Respiratory protection is not normally required. Use NlOSH/MSHA approved respirator if conditions wanar
Ventilation Standard industrial ventilation is recommended.
VII. FIRE PROTECTION
Flash Point
Extinguishing media.
Non-flammable
Non-flammable in Liquid state. Use water spray, foam, dry chemical or carbon dioxx
on dried product.
Unusual Fire and Explosion Hazard Personnel exposed to product of combustion should wear self-contained breathir
apparatus and full protective equipment. Containers exposed in a fire should be coolt
with water to prevent vapor pressure buildup leading to a rupture.
VIII. REACTIVITY INFORMATION
Stability Stable under normal conditions
Incompatibility Not Established
Hazardous Decomposition Combustion of the dried product can give off oxides of carbon and nitrogen.
Hazardous Polymerization Will not occur.
IX. EFFECT OF OVEREXPOSURE
Eye contact with liquid may cause irritation.
Repeated or prolonged skin contact with liquid may cause irritation.
No expected effects.
. '-yes
Skin
Inhalation
Chronic No anticipated effects. This product does not contained regulated levels of NTP, IARC or OSHA lists
carcinogens.
Existing Health Conditions Affected by Exposure - No know effects on other illnesses.
5051.SS Soil Seal is a registered trademark of Soil Seal Corporation
Page 2 of 3
Ref 1/09/06
X. SPILL and DISPOSAL INFORMATION
Small Spills Should be contained using absorbent material, such as clay, soil or any commercially available absorbent.
Large Spills Should be diked to prevent further movement and reclaim into recovery of salvage drums for disposal.
Disposal This product does not meet the definition of hazardous waste under the U. S. EPA Hazardous Waste
Regulations 40 CFR 261. Consult your state or local authorities for proper disposal in the event more
restrictive requirements apply.
XI. STORAGE Protect from freezing - product stability may be affected.
XII. REGULATORY INFORMATION
TOSCA This product meets the compositional requirements of the Toxic Substances Control Act and contains
only chemical ingredients that are listed on the TOSCA inventory.
SARA Title III, Sec. 313 This product does not contain toxic chemical(s) at or above the de minimus concentrations
* subject to the reporting requirements of Section 313 of Title ill of the Superfund Amendments
and Reauthorization Act of 1986(SARA) and 40 CFR part 372.
5051 .SS
b
Soil Seal is a registered trademark of Soil Seal Corporation
Page 3 of 3
Ret 1/09/06
* « • i
SOU-WORKS. LLC
681 N Monterey St, #101
Gilbert, Arizona 85233 Phone [phone] Fax [phone]
www Soiltac com InfolfSoiltac.com
SOIL-TAG®
Soil Stabilizer &
Dust: Control Agent
MATERIAL SAFETY DATA SHEET
PRODUCT NAME
MANUFACTURER
TELEPHONE NUMBER
ONLINE INFORMATION
EMERGENCY TELEPHONE NUMBERS
REVISION DATE
SECTION 1 - MATERIAL IDENTIFICATION
SOILTAC*
*SOILTAC is a registered trademark of Soilworks, LLC
Soilworks, LLC
681 North Monterey Street, Suite 101
Gilbert, Arizona 85233-8318 USA
www soilworks com
800-545-5420
www Soiltac com
800-545-5420 (National & International)
March 2006
EMERGENCY OVERVIEW
PHYSICAL FORM
COLOR
ODOR
HAZARDS
EXTINGUISHING MEDIA
C.A.S. CHEMICAL NAME
SYNONYMS
CHEMICAL FAMILY
EMPIRICAL FORMULA
INTENDED USE
REVISION NOTES
%
Mobile liquid
White (transparent once cured)
Mild
There are no known health hazards
The product will only burn after the water it contains is dnven off
Mixture
Soil stabilizer, soil stabilization agent, soil solidifier, soil amendment, soil additive, soil crusting agent,
dust control agent, dust inhibitor, dust palliative, dust suppressant, dust retardant
Vinyl Acetate Copolymer Emulsion
Mixture
Soil stabilization, soil solidification, fugitive dust control, dust suppression, dust abatement, tackifier,
dust abatement, PM10 and PM2s air quality control and erosion control
None
SECTION 2 - INGREDIENTS
CAS Number and Chemical Name
50-65
50-35
<05
Vinyl Acetate Copolymer
7732-18-5 Water
108-05-04 Vinyl Acetate Monomer
The composition is a trade secret Contains no other components or impurities which will influence the classification of the product
SECTION 3 - HEALTH HAZARDS
ROUTES OF EXPOSURE
Eye Contact k
Skin Contact f
Ingestion
Inhalation
EXPOSURE STANDARDS
See Section 2 for exposure standards on ingredients. Maintain air contaminant concentrations in the workplace at the lowest
feasible levels Minor components will migrate into the container headspace Levels in excess of the TLV's or PEL's can accumulate
in non-vented container headspaces Open drums in a well ventilated space The pnncipal volatile component is water Minor
volatile components are identified in Section 2 "Ingredients"
HEALTH HAZARDS
There are no known health hazards
TARGET ORGANS
None known
SIGNS AND SYMPTOMS OF EXPOSURE (Acute effects)
There are no known signs or symptoms of exposure
SIGNS AND SYMPTOMS OF EXPOSURE (Possible Longer Term Effects)
No known effects
MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE
None known
EGSA*) <X£
SRSTSSTSSTT EraitonCc
Soiltac9 soil stabilizers oust control Agent - modified 3/28/06 printed 3/28/2006 • [Page 10 of 13]
SOU-WORKS, LLC
681 N Monterey St, #101
Gilbert, Arizona 85233
Phone [phone] Fax [phone]
www.Soiltac com lnfo(3>Soiltac com
SOIL-TAG
Soil Stabilizer &
Dust Control Agent
SECTION 4 - FIRST AID
EYE CONTACT
Rinse immediately with plenty of water
SKIN CONTACT
Remove contaminated clothing and shoes Wash affected area with soap and water
INHALATION
Move patient to fresh air. If breathing has stopped or is labored give assisted respiration (e g mouth-to-mouth). Supplemental
oxygen may be indicated Seek medical advice Prevent aspiration of vomit Turn victim's head to the side
INGESTION
If swallowed, call a physician immediately Remove stomach contents by gastric suction or induce vomiting only as directed by
medical personnel Never give anything by mouth to an unconscious person
SECTION 5 - FIRE AND EXPLOSION DATA
FLASH POINT (closed cup) No Data
UPPER EXPLOSION LIMIT (UEL) No Data
LOWER EXPLOSION LIMIT (LEL) No Data
AUTOIGNITION TEMPERATURE No Data
FIRE HAZARD CLASSIFICATION (OSHA/NFPA) Non-Combustible
EXTINGUISHING MEDIA
The product will only burn after the water it contains is driven off For dry polymer use water or carbon dioxide Product does not
burn Aqueous solution is not flammable
SPECIAL FIRE FIGHTING PROCEDURES
No special procedures required The product, as distributed, is noncombustible
UNUSUAL FIRE AND EXPLOSION HAZARDS
When dried polymer burns, water (H20), carbon dioxide (C02), carbon monoxide (CO) and smoke are produced
SECTION 6 - ACCIDENTAL RELEASE MEASURES
CONTAINMENT TECHNIQUES (Removal of ignition sources, diking etc)
Stop the leak, if possible Ventilate the space involved
CLEAN-UP PROCEDURES
Wear suitable protective equipment If recovery is not feasible, admix with dry soil, sand or non-reactive absorbent and place in an
appropnate chemical waste container Transfer to containers by suction, preparatory for later disposal Place in metal containers for
recovery or disposal Flush area with water spray. Wash contaminated property (e g , automobiles) quickly before the material dries
For large spills, recover spilled matenal with a vacuum truck.
OTHER EMERGENCY ADVICE
Spilled polymer emulsion is very slippery Use care to avoid falls A film will form on drying Remove saturated clothing and wash
contacted skin area with soap and water. Product imparts a milky white color to contaminated waters Foaming may result. Sewage
treatment plants may not be able to remove the white color imparted to the water
SECTION 7 - HANDLING AND STORAGE
STORAGE
Keep away from oxidizers Avoid freezing temperatures during storage
Minimize contact with atmosphenc air to prevent inoculation with microorganisms *
HANDLING ,
Use only in well-ventilated areas Avoid contact with eyes Avoid breathing vapors Avoid contact with skin When using, do not
eat, drink or smoke
OTHER PRECAUTIONS
No special precautions required.
SECTION 8 - PERSONAL PROTECTION / EXPOSURE CONTROLS
EYE PROTECTION
Chemical safety glasses
HAND PROTECTION
Rubber Gloves. The breakthrough time of the selected glove(s) must be greater than the intended use period
RESPIRATORY PROTECTION
Not required under normal use
PROTECTIVE CLOTHING
No specific recommendation
ENGINEERING CONTROLS
Maintain air concentrations in work spaces in accord with standards outlined in Sections 2 and 3.
Soiltac® son stabilizer & Dust control Agent - modified 3/28/06 prmted-3/28/2006 - [Page 11 of 13]
SOIL.UJORKS LLC
681 N Monterey SL, #101
Gilbert, Arizona 85233
Phone [phone] Fax [phone]
www Soiltac com InfotSSoiltac com
SOIL-TAG®
Soil Stabilizer &
Dust Control Agent
WORK AND HYGIENIC PRACTICES
Minor components will migrate into the container headspace Levels in excess of the exposure limits can accumulate in non-vented
container headspaces Under normal conditions of use in a well-ventilated space, the concentration of minor components in the
workplace air will not exceed the exposure limits.
SECTION 9 - TYPICAL PHYSICAL AND CHEMICAL PROPERTIES
PHYSICAL FORM
COLOR
ODOR
PH
VAPOR PRESSURE
VAPOR DENSITY (Air = 1)
BOILING POINT
SOLUBILITY IN WATER
SPECIFIC GRAVITY (Water = 1)
MOLECULAR WEIGHT
Mobile liquid
White (transparent once cured)
Mild
4 0-6 0
18 65 (mm Hg at 21 °C (70°F))
Of water vapor
>100 00°C (>212 00°F)
Completely (100%) (until cured)
1.04-1 10
Mixture
SECTION 10 - STABILITY AND REACTIVITY
CHEMICAL STABILITY
Stable at ambient temperatures Coagulation may occur following freezing, thawing or boiling
CONDITIONS TO AVOID (if unstable)
Not applicable
INCOMPATIBILITY (Materials to Avoid)
Mineral acids (i e sulfuric, phosphoric, etc) Alkalis (i e Sodium or Potassium Hydroxide etc.)
HAZARDOUS DECOMPOSITION PRODUCTS (from burning, heating, or reaction with
other materials).
Depending upon formulation conditions (such as pH>7), the level of acetaldehyde may increase as a result of hydrolysis of residual
vinyl acetate monomer Carbon Monoxide in a fire Carbon Dioxide in a fire Aldehydes Acetic Acid
HAZARDOUS POLYMERIZATION
Will not occur
CONDITIONS TO AVOID (if polymerization may occur)
Not applicable
SECTION 11 - TOXICOLOGICAL PROPERTIES
ACUTE ORAL TOXICITY
No Data
ACUTE DERMAL TOXICITY
No Data
ACUTE INHALATION TOXICITY
No Data
Components Vinyl Acetate Monomer LC50 (1 h) 5,656 ppm Species- Rat
OTHER ACUTE EFFECTS
No Data
CHRONIC/SUBCHRONIC DATA
This product contains small amounts of vinyl acetate monomer ACGIH evaluated vinyl acetate (1993) as an A3 Animal
Carcinogen Available evidence suggests that the agent is not likely to cause cancer in humans except under uncommon or unlikely
routes of exposure The International Agency for Research on Cancer (IARC) published a monograph on vinyl acetate (1995) In
this monograph IARC indicates "there is inadequate evidence in humans for carcinogenicity of vinyl acetate. There is limited
evidence in expenmental animals for carcinogenicity of vinyl acetate" Normally, this lack of conclusive evidence would place a
substance in the IARC Category 3 classification (Not classified as a human carcinogen) However, because vinyl acetate is
metabolized to acetaldehyde, which has an IARC 2 6 (Possibly carcinogenic to humans) classification, it also has been listed under
Category 2B
SECTION 12 - ECOLOGICAL INFORMATION
ECOTOXICITY
Common Name
Green Algae
Fathead Minnow
Rainbow Trout
ENVIRONMENTAL FATE
No Data
ADDITIONAL INFORMATION
No Data
Species
Raphidocelus Subcapitata
Pimephales Promelas
Oncomynchus Myklss
Test
96-hr chronic LC50
96-hr acute LC50
96-hr acute LC50
Result
>1,000
>1,208
>1,000
Concentration
Undiluted
Undiluted
Undiluted
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SSSTSStSal Erosion Control
=G5A Soiltac®son stabilizers Dust control Agent - modified-3/28/06 printed 3/28/2006 - [Page 12 of 13]
SOIL.HIORKS. LLC
681 N Monterey St, #101
Gilbert, Arizona 85233
Phone [phone] Fax [phone]
www Soiltac com lnfo(S>Soiltac.com
SOIUTAC
Soil Stabilizer &
Dust Control Agent
SECTION 13 - DISPOSAL CONSIDERATIONS
WASTE DISPOSAL
Comply with all Federal, State and Local Regulations For small quantities (less than 100 gallons) Disposal to municipal or industrial
wastewater treatment plants is normally acceptable Obtain approval from these authorities before disposal The product does
impart a white, milky color to water, which may not be removed or sufficiently diluted by the treatment facility The product may also
cause foaming when agitated The product can be chemically or biologically degraded. For large quantities Disposal through
licensed waste disposal facilities is suggested The product can be incinerated, though chemical or biological treatment is sufficient
Chemical precipitation/coagulation can be used to facilitate removal of solids (consult manufacturer for detailed procedure) NOTE
As supplied or diluted, product material (foam included), when splashed on automobiles or other personal property, is difficult to
remove if allowed to dry
SECTION 14 - TRANSPORT INFORMATION
DOT NON-BULK SHIPPING NAME
DOT BULK SHIPPING NAME
IMO SHIPPING DATA
ICAO/IATA SHIPPING DATA
CFR
IMDG
CTC
Refer to Bill of Lading - Not DOT Regulated // Keep From Freezing // Not dangerous goods
Refer to Bill of Lading
Refer to Bill of Lading
Refer to Bill of Lading - Not IATA Regulated // Keep From Freezing // Not dangerous goods
Not Regulated // Keep From Freezing // Not dangerous goods
Not Regulated // Keep From Freezing // Not dangerous goods
Not Regulated // Keep From Freezing // Not dangerous goods
SECTION 15 - REGULATORY INFORMATION
TOXIC SUBSTANCES CONTROL ACT (TSCA)-
All components are included in the EPA Toxic Substances Control Act (TSCA) Chemical Substance Inventory
TOXIC SUBSTANCE CONTROL ACT (TSCA) 12(b) COMPONENT(S)
None
OSHA Hazard Communication Standard (29CFR1910.1200) hazard class(es)
None
EPA SARA Title III Section 312 (40CFR370) hazard class
None
EPA SARA Title III Section 313 (40CFR372) toxic chemicals above "de minimis" level are
Vinyl Acetate Monomer
US. California Safe Drinking Water & Toxic Enforcement Act (Proposition 65)
WARNING! This product contains a chemical known in the State of California to cause cancer Acetaldehyde
WHMIS HAZARD CLASSIFICATION
None
WHMIS INGREDIENT DISCLOSURE LIST
None
WHMIS SYMBOLS
None
EINECS / ELINCS MASTER INVENTORY (EU)
Included on EINECS inventory or polymer substance, monomers included on EINECS inventory or no longer polymer
DSL (Canada)
Included on inventory •*
AICS (Australia)
Included on inventory
ENCS (Japan)
Included on inventory
ECL (South Korea)
Included on inventory
SEPA (China)
Included on inventory
SECTION 16 - OTHER INFORMATION
HMIS Rating
Health
Flammability
Physical Hazard
Soiltac® soil stabilizers Dust control Agent - modified 3/28/06 pnnted:3/28/2006 - [Page 13 of 13]