DRC-2013-001152 - 0901a06880345627

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
January 22, 2013
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2013-0011b2
Harold Roberts
Executive Vice President and Chief Operatmg Officer
Energy Fuels Resources (USA) Inc
225 Union Blvd , Suite 600
Lakewood, CO 80228
RE- Radioactive Material License (RML) Number UT 1900479 Request for Information on
Proposed Alternate Feed Material from Dawn Mining
Dear Mr Roberts
On April 11, 2012 Energy Fuels Resources (EFR) submitted to the Utah Division of Radiation
Control (DRC) a request to amend RML 1900479 by adding a new Altemate Feed stock to the
approved list of altemate feed being processed at the White Mesa Uranium Mill This altemate
feed material is from the Dawn Mining Corporation's Midnite Mine located in the State of
Washington On November 8, 2012, representatives from Energy Fuels and Davm Mining met
with the DRC to discuss the proposed license amendment request It was decided m that
meeting that the review of the amendment request would be done by the DRC's contractor
URS Corp The following are comments and requested information from URS's review
"Application by Denison Mines (USA) Corp ('Denison') for an Amendment to State of Utah
Radioactive Materials License No 1900479 for the White Mesa Mill (the "Mill") from Davsm Mining
Corporation ("DMC") Midnite Mine to process an Altemate Feed Material (the "Uranium Material")
dated April 27, 2011, and
"State of Utah Radioactive Materials License No 1900479 April 27, 2011 Amendment Request to
Process and Altemate Feed Material from Dawn Mining Company, Transmittal of Supplementary
Information", Energy Fuels Resources (USA) Inc (EFR), dated December 5, 2012 [letter report]
URS has reviewed the Denison license amendment application and EFR's Supplementary
Information letter report identified above requesting authority to process altemate feed material
(Uranium Material) from the Dawn Mining Corporation Midnite Mine at the White Mesa
Uranium Mill The following general and specific comments and requests for additional
information have resulted from this review
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT »m4-4850
Telephone [phone] • Fax [phone] -TDD [phone]
www deq utah gov
Printed on 100% recycled paper
Page 2
GENERAL COMMENTS
1. Specific comments stated below address the Applicant's repeated statements that the
Uranium Matenal proposed to be processed in the White Mesa Mill has characteristics
that are within the envelope of material characteristics previously authorized to be
processed at the Mill
Once the specific comments stated below have been addressed, please review and
evaluate the correctness of conclusions stated throughout the text of the amendment
application that previously accepted or authonzed analyses, plans, programs,
procedures, practices, equipment, etc need not be extended or revised Justify each
new conclusion To the extent necessary, extend or revise previously accepted or
authonzed analyses, plans, programs, procedures, practices, equipment, etc and submit
them for the Division's consideration and approval
Previously accepted or authorized analyses, plans, programs, procedures, practices,
equipment, etc include (but are not necessarily limited to) the following:
a " . there will be no incremental public health, safety or environmental impacts
over and above previously licensed activities" stated on Page 11 of the
Amendment Request
b " it IS not expected that transportation impacts associated with the movement
of the Uraniiun Material by tmck from the Midnite Mine WTP facility to the
mill will be significant."
c ". the Uranium Material is stable under ambient environmental conditions and
does not require any special handlmg the TCLP data evidences that the
material does not readily leach and does not exhibit hazardous waste
charactenstics when exposed to more severe conditions than would be
anticipated on the ore storage pad" stated on page 13 of the Amendment request
d " there will be no new or incremental nsk of discharge to surface waters
resulting from the receipt and processing of Uranium Material at the Mill or the
disposition of the resulting tailings" stated on page 16 of the Amendment
Request
e "The existing air particulate monitormg program is equipped to handle all such
ores" stated on Page 16 of the Amendment Request
f " the Uranium Material will therefore poses less of a gamma and radon
hazard than other ores and altemate feed materials that have been processed or
licensed for processing at the Mill" stated on Page 16 of the Amendment
Request
g "Gamma exposure to workers will be managed in accordance with existing Mill
standard operating procedures" stated on Page 17 of the Amendment Request
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h "Radon exposures to workers will be managed in accordance with existing Mill
standard operations" stated on Page 17 of the Amendment Request
1 "The Mill can safely handle the Uranium Material in accordance with
existing Mill standard operating procedures" stated on Page 17 of the
Amendment Request
j "Existing monitoring programs are therefore adequate and no new monitoring
procedures are required" stated on Page 18 of the Amendment Request
k " there will be no deconmiissiomng, decontamination or reclamation impacts
associated with processing the Uraniiun Material, over and above previously
licensed Mill operations" stated on Page 18 of the Amendment Request
SPECIFIC COMMENTS
1 Pages 6 and 7, Section 2 6 1 of the Apnl 2011 DMC LAR Please justify by
providing documentation of the following parameter values stated in the narrative
a Uranium Matenal average uranium content of approximately 1 4% on a dry
weight basis
b High grade Arizona Strip breccia pipe uranium ore content ranging from 0 4%
to 2% U3O8 or higher
c Estimated average Thorium-232 content 0 005% on a dry weight basis
d Radium-226, Thonum-230, and Lead-210 concentrations of 24 1 pCi/L, 20 7
pCi/L, and 33 3 pCi/L, respectively
e Radium-226, Thorium-230, and Lead-210 concentrations of 825 pCi/L each in
Colorado Plateau ore with U3O8 content of 0 25%
2 Page 10, Section 3 3 3. Justify by fiimishing additional documentation the assertion
that "The five volatile organic compounds detected in the Uranium Material have
been attributed to laboratory contamination " ,
3 Page 17, Section 4 10 2(d) Estimate and document the range of "Derived Air
Concentration" values that might result from processing the proposed Uranium
Material State and justify the impact this range of DACs might have on estimated
worker exposures to airbome particulate matter
4 Tab (Attachment) 2, Page 5 of 11 Provide historical testing results to demonstrate
that the uranium content has averaged 0 18% on a wet basis
5 Tab 2, Page 7 of 11 Correct the discrepancies for Arsenic and Cadmium between
values in the columns and the values stated as the "Max"
Page 4
Tab 2, Pages 8, 9, and 10 of 11 Add columns to each table indicating allowable
concentrations for each analyte (e g , TCLP threshold values), where applicable
Tab 2, summary tables and Tab (Attachment) 4, Table 4 of the April 2011 DAR
LAR
a Compare the range of concentrations of the following constituents that could
occur in the Uranium Material with reported ranges of concentrations of the
same constituents present in Colorado Plateau uranium ores typical of those that
are accepted and processed at the Mill and/or are reported to be present in
typical uraniiun mill tailings m the Utah region (e g , Abdelouas 2006, Morrison
1991,Meisch 1963)
• Banum (Ba), and
• Beryllium (Be)
Information in Abdelouas 2006, based on data from Morrison 1991, allows the
followang comparison between the average chemical composition of uranium
mill tailings from different locations m Utah (for acid-leached uranium ores) and
the Dawn Mining Uranium Material
Analyte
Average Concentration in
Utah area uranium mill tailings
Analytical Results of Dawn WTP
Splids (p 9 of 11 of Attachment 2
of LAR)
Ba 1,010 ug/g 7,200-8,100 ug/g
(7,733 ug/g ave)
Be Not Reported 33 - 36 ug/g
(35 ug/g ave)
Information in Miesch 1963 (Table 2) allows the following comparison between
typical (mean) chemical compositions of uranium ore from a uranium mine
deposit and mill pulp samples from over 200 mine sites on the Colorado Plateau
and the DRC Mining Uranium Material
Analyte
Average Concentration in
Colorado Plateau Uranium
Ores and Mill Pulp Samples
Analytical Results of Dawn WTP
Solids (p 9 of 11 of Attachment 2 of
LAR)
Ba 550 - 750 ug/g 7,200-8,100 ug/g
(7,733 ug/g ave)
Be ~ 0 3 0- 0 4 ug/g 33 - 36 ug/g
(35 ug/g ave)
The above information suggests that concentrations of beryllium and banum in
the DRC Uranium Material appear to be somewhat elevated compared to
Colorado Plateau-denved ores that may have been processed at the Mill and/or
present in typical uranium mill tailings in the Utah area The same situation
may occur relative to one or more other altemate feed materials previously
accepted and processed at the Mill The implications of elevated Be levels m
the Uranium Material compared to ores and other altemate feed materials
Page 5
previously processed at the Mill and with respect to potentially applicable and
relevant persormel health criteria should be fiirther assessed
b Discuss and compare the range of concentrations of the constituents listed m
Specific Comment a above in the Uranium Material to potentially
applicable/relevant RCRA hazardous waste/characteristic waste limits, EPA-
recommended Soil Screening Levels (SSLs), including updated recommended
Risk-Based Concentration (RBC) levels (e g , EPA 2012) for various types of
soils issued by one or more EPA regional offices, relative to cunent, relevant
"action levels" established for protecting workers from exposure to elevated
levels of constituents in air, such as beryllium, etc , and/or other criteria as
may be appropriate
c Assess radiological and non-radiological impacts of releases from the facility to
other media (including release through air to adjacent uncontrolled lands)
attributable to concentrations in Uranium Material m excess of those previously
authorized for receipt and processing at the White Mesa mill Demonstrate that
the airbome effluent monitonng program is adequately designed and
implemented to ensure that acceptability of airbome releases to adjacent areas
will be known and reported
8 Discuss any additional requirements, activities, or measures that would be
implemented at the White Mesa Mill either during processing the Uranium Material,
or following its processing, due to potentially elevated concentrations of barium,
and beryllium) compared to applicable and relevant risk or health-based critena
(e g , ACGIH 8-hr average TLVs or other recommended action levels, as
appllcable) and/or compared to concentrations typically present m uranium ores
processed at the Mill and/or present in Utah-area uranium mill tailings (Abdelouas
2006, Morrison 1991, Meisch 1963) For example, evaluate and discuss (i) the
potential need for additional controls to limit individual exposures to elevated
beryllium, etc levels that may be present in dust that could be released from the
Dawn Uranium Material prior to, during, or following its processing, and (ii) the
possible need for implementing more aggressive air sampling and/or material
surface sampling criteria for elements such as beryllium
9 Tab 4 and Tab 5 Provide credentials and summarize the experience of the author of
these Technical Memoranda to demonstrate that the author is qualified to draw the
conclusions and make the recommendations contained in Tab 4, Section 6 and on
Tab 5, Pages 20 and 21 Provide documentation (signature) attesting that the author
has issued these memoranda
10 Tab 5, Sections 4 3 and 8 1 of the Apnl 2011 DAR LAR on pages 16- 20
a Provide historical testing results to demonstrate that the stated ranges of
concentrations of nitrates, chlorides, fluorides, sulfates, and ammonia have been
introduced into the uranium circuit at the White Mesa Mill, and
Page 6
b For review/documentation purposes, please provide an updated geomembrane
manufacturer's product performance sheet listing chemicals and their chemical
compatibility criteria for an HDPE geomembrane liner that is representative of
the HDPE liners installed in Cells 4A and 4B
11 Reference Section 4 6 and Section 8 1 of Attachment 5 to the LAR (Application by
Denison Mines (USA) Corp ('Demson') for an amendment to State of Utah
Radioactive Matenals License No 1900479 for the White Mesa Mill (the "Mill")
from Dawn Mining Corporation ("DMC") Midnite Mine to process an Altemate
Feed Matenal (the "Uranium Matenal") dated Apnl 27, 2011)
a Provide additional information, including reference citations, to justify and
support the identification of an appropriate revised range of values of the
distribution coefficient (Kd) for banum for representing conditions at the White
Mesa Mill Site, including the tailings environment m particular Provide a
discussion of how such a revised range of barium KdS impacts the potential for
barium to negatively affect groundwater beneath/downgradient of the tailings
cells into which processed Uranium Matenal residuals would be placed State
and justify how the range of pH observed and expected in White Mesa tailings
might affect the range of IQ values for barium for the processed Uranium
Material residuals introduced into the tailings
b Provide additional mformation and one or more reference citation(s) to support
the statement included in this section indicating that barium would be
sufficiently represented by monitoring (groundwater) for calcium
c Provide additional information regarding the need to add barium as an additional
monitoring parameter in the facility's groundwater monitoring plan, especially
given that, under acid conditions, some (otherwise) water-insoluble barium
compounds (e g , banum sulfate) may become soluble and move into
groundwater (e g , see US EPA, 1984), and given the Groundwater Quality
Standard value of 2 mg/1 included in UAC R317-006
Section 4 6 of the Request to Amend Radioactive Materials License, Denison
Mines USA Corp White Mesa Uranium Mill, San Juan County, Utah, and
Environmental Report includes a statement that the distribution coefficient (Kd)
for barium is 100 to 150,000 L/kg for sandy to clayey soil types and that
Denison therefore concludes that banum would be less mobile m groundwater
than calcium No reference sources are cited to support either the Ka range stated
or the conclusion made regarding the relative mobility of barium compared to
calcium, for conditions occumng at the White Mesa tailings Cells 4A and 4B
Kennedy et al (1992, Table 6 7), for example, lists a Kd value of 52 mL/g for
barium EPA 2012 (Section 4 11 and Exhibit C-4 of Appendix C) provides a
range of recommended Kd values for banum as a function of pH (e g , Kd = 52
mL/g at pH = 8 0, Kd = 41 mL/g at pH = 6 8, etc , with Kd values decreasing
with decreasing pH, the Kd value at pH = 4 9 is listed as 11 mL/g) Allison 2005
referenced several citations reporting soil/water Kd values of barium all less than
Page 7
10 L/kg, and cited several risk assessment studies that used Kd values ranging
from 11 to 52 L/kg By comparison, the UDEQ Statement of Basis for the
Groundwater Discharge Permit indicates assumes Kd values for calcium ranging
from 5 to 100 L/kg (i e , equal to or higher than those reported m the above
references for barium)
Additionally, EFR has not provided information to describe or substantiate how
the mobilization behavior for barium that may be expected to occur m the (e g ,
acidic) tailings and the near-field tailings embankment environment may differ
from, or be similar to, that of calcium EPA (1984), for example, reported that
barium, when present in the form of banum sulfate in soils, is not expected to be
very mobile because of the formation of water-insoluble salts and its inability to
form soluble complexes with humic and fiilvic materials, but noted, however,
that, under acid conditions, some of the water-insoluble barium compounds
(e g , barium sulfate) may become soluble and move into groundwater.
12 Filter Press Pilot Testing Report The report should include a log of all tests and test
results so that the Division can independently review and evaluate them
13 Filter Press Pilot Testing Report Page 3 Please discuss the relationship between the
equipment used to perform the pilot tests reported in the document reviewed and
that to be used in producing the filter cake that will actually be shipped to the White
Mesa Uranium Mill for processing as altemate feed material Describe differences
in equipment that might affect the physical or radiological [properties of the filter
cake shipped for processing Describe measures that will be taken and
documentation that will be provided to ensure that characteristics of filter cake
shipped to White Mesa will not diverge in a substantive way from those reported in
the pilot testing report
14 Filter Press Pilot Testing Report Page 4 The meaning of the phrase "extremely
competent" is not clear and should be revised to eliminate ambiguity and clearly
communicate the characteristics of the cake that was tested
15 Filter Press Pilot Testing Report Page 9, Table 3, and Laboratory Report The
contradictory results reported for Thorium-233 concentrations should be resolved
(page 9 and Table 3 indicate the Th-233 concentration to be 2 7 pCi/g while the
Laboratory Report (page 5 of 15) indicates 2 4 pCi/g
16 Filter Press Pilot Testmg Report Laboratory Report, Table 3 Describe how the
values of the parameter named "Solids - Calculated (Lab)" were determined
Provide calculations prepared for each value reported Explain the significance of
differences between values reported for "Solids - Calculated (Lab)" and for "Solids
- Field (Avg)"
Page 8
17 Filter Press Pilot Testing Report Laboratory Report Please provide documentation
and other evidence that identify relevant laboratory certifications held by Energy
Laboratories
SinccEely
lohn Hultquist,y§ection Manager
LLRW/Uranium Mill Licensing Section
JH URS/RJ/rj
Cc Jo Ann Tischler, Director, Compliance and Permitting
Page 9
REFERENCES
Abdelouas 2006
Allison 2005
Kennedy 1992
Meisch, 1963
Morrison 1991
DUSA 2011
EPA 2005
EPA 2012
NRC 1992
NRC 2003
"Uranium Mill Tailings Geochemistry, Mineralogy, and Environmental
Impact," m Elements, Vol 2, pp 335-341 December 2006 URL
http //gnews yyustl edU/elements/e2 6/e2 6 art abdelouas pdf
Partition Coefficients for Metals in Surface Water, Soil, and Waste U S
Environmental Protection Agency, Office of Research and Development,
Washington, DC (EPA/600/R-05/074) July 2005 URL
http //www epa gov/athens/publications/reports/Ambrose600R05074PartitionC
oefficients pdf
Residual Radioactive ([Contamination from Decommissioning-Technical Basis
for Translating Contamination Levels to Annual Total Effective Dose
Equivalent Final Report, NUREG/CR-5512, PNL-7794, Vol 1 October 1992
NRC ADAMS Accession No ML05222031 Available at URL
http //www nrc gov/about-nrc/regulatory/decommissioning/reg-guides-
comm/guidance html
Distribution of Elements in Colorado Plateau Uranium Deposits - A
Preliminary Report U S Geological Survey Bulletin 1147-E U S
Government Printing Office, Washington, D C 1963 URL
http //pubs usgs gov/bul/1147e/report pdf
"Mineralogical Residence of Alpha-Emitting Contamination and Implications
for Mobilization from Uranium Mill Tailings", in Journal of Contaminant
Hydrology 8 1-21
Request to Amend Radioactive Materials License Denison Mines (USA) Corp
White Mesa Uranium Mill San Juan County, Utah and Environmental Report
April 2011
U S Environmental Protection Agency (EPA) 2005 Midnite Mine Remedial
Investigation Report September 2005
Risk-Based Concentration Table - Generic Tables, Mid-Atlantic Risk
Assessment URL http //www epa gov/reg3hvmid/risk/human/rb-
concentrationtable/GenericTables/index htm
U S Nuclear Regulatory Commission (NRC) 1992 "Preparation of
Environmental Reports for Uranium Mills," Regulatory Guide 3 8, October
1992
U S NRC 2003 "Standard Review Plan (NUREG-1620) for Staff Reviews of
Reclamation Plans for Mill Tailings Sites Under Title II of The Uranium Mill
Tailings Radiation Control Act", NUREG-1620, June 2003