DRC-2013-004489 - 0901a06880417050

CrrrCouRT 235 South 30oEast
Salt Lake City, Utah 84111
fn: 801.532.3t141 rax 801.532.3414 rott Free:877.532.3441THE REPORTING CROUI'
October 24,2413
Shairose Falahati
Division of Radiation Control
PO Box 144850
Salt Lake city, uT 84114-4850
DRC Public Hearing (Salt Lake l0l9ll3) on CD
t0t2v20t3
DRC Public Hearings
Dear Ms. Falahati:
Enclosed please find the original transcript in the matter referenced above. The original transcript is being
sent to your offrce for safekeeping until trial or other disposition of the case.
Sincerely,
t\h"ntr Dr*ru^
Stephanie Wimmer
CitiCourt, LLC
Re:
COPY OF TRANSCRIPT
Reporter's transcript of electronically recorded:
DRC-2013-004489
PUBLIC HEARING
DIVISION OF
RADIATION CONTROL
STATE OF UTAH
Conference Room 1015
195 North 1950 West.
Salt Lake City, Utah
October 9, 2013 - 2:00 p.m.
THE REPORTING GROUP PH: 801.532.3441 FAX: [phone] TOLL FREE: 877.532.3441
ClTlCoURT 236 South 300 East
Salt Lake City, Utah 84111
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October 9, 2013 - 2:00 p.m. - Salt Lake City, Utah
P R O C E E D I N G S
MR. ANDERSON: Welcome and good afternoon.
My name is Craig Anderson. I'll be the presiding
officer for the hearing this afternoon. This is the
time and the place scheduled for the informal public
hearing on Energy Fuels' application for an amendment
to its 11e(2) byproduct license UT1900479. As noted
in the public notice that has been posted on the
DRC's Web site and also published, this is the time
and the place to receive public comments and
questions.
At this point in the hearing I would open
the floor to anyone who'd like to make comments on
the proposed amended license, and then we'll move on
to the question part of the proceeding. So does
anybody have any comments they'd like to make at this
point.
Yes, Ms. Fields?
MS. FIELDS: I'm going to submit more --
some comments later, particularly after this
proceeding, and we still have a couple of weeks. My
name is Sarah Fields. I'm with Uranium Watch in
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Moab, Utah, and I've had some interest in the White
Mesa Mill for a number of years. And I just want to
make a few procedural comments.
I think there was too little time between
the submittal of the questions and the hearing. And
just this morning I received a copy of the letter
which indicated to me that some -- some of my
questions were not relevant to the licensing action,
vague, or maybe they didn't all fit -- fit this,
these categories, but maybe were seeking legal
interpretations or were not specifically relevant to
the proceedings. So it would have been helpful to
have that before.
It would be also helpful to have known and
have had a little bit more information, because
questions that were very relevant to me, or
significant to me, have now been taken off the table
for this, for this hearing. And I have some
objections to that, but it will get us through some
of this more quickly, and there's still some relevant
things to go over.
One thing regarding making comments. I
noticed that some of the documents, as they were
posted on the DRC Web site, it was not possible to
copy and then paste sections of the documents, or I
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had difficulty with that. And when you're making
comment on a document, it's really handy to be able
to copy a section, paste it into your comments so you
can indicate that you're making a comment on the
section so that the staff, or whoever's reviewing the
comments, doesn't have to go back to the original
document, and they know precisely what you're
referring to. And it takes time to type that in, so
having a PDF that you can copy -- copy from and paste
in is really handy.
I think most of my comments would happen
after this, and hopefully some of my issues will
be -- I'll get some additional information to make
more informed comments. Thank you.
MS. LOCKHART: Can I just respond to that
a little bit? I know that this is a comment period,
but I wanted to -- it's not in that letter that you
received, Sarah, but we do plan on addressing some
things, notwithstanding the -- I guess you would call
them objections. So maybe the best thing to do on
some of those is to hold off until the end and see
what's left over for you.
And I would also agree that we learned
that ten days was not enough. That's why we wanted
to kind of experiment with this before we put it into
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rules. So that's the first lesson today.
MS. FIELDS: Oh, okay, good.
MR. ANDERSON: Are there any other
comments? Well, I guess we can move on to the rest
of the agenda in the proceeding today. As a
preliminary matter, a 45-day public comment period
began on September 5th, 2013, and notice was
published on the DRC Web site, published in the Salt
Lake Tribune, Deseret News and the San Juan Record.
Copies of the amended license, proposed amended
license, Statement of Basis and Safety Evaluation
Report are also on the department's Web site and
available for inspection at the department's office.
In addition, written comments will be accepted until
the close of business on October 21st, 2013.
This hearing is undertaken for the purpose
of meeting the Nuclear Regulatory Commission's state
delegation requirements under 10 U.S. Code,
§2021(o)(3)(A), and the purpose of this informal
hearing is to receive comments and questions that
have previously been submitted in advance regarding
the application for the amended license. Staff from
the Division of Radiation Control, URS, the
Division's contractor, and representatives of the
Applicant, Energy Fuels, are present and available
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today to answer any questions that you may submit.
The scope and comments on the questions
will be limited to the matters that are relevant to
the application for an amendment, and any comments or
questions and responses received this afternoon will
be included in the record for the amendment. There
has been a sign-in sheet that's been circulated
around. I guess I'm the last to sign it, so -- I
spoke too soon. So if you haven't already signed in,
please do so.
This hearing is being recorded and a
transcript will be made available at a time and date
after the hearing and will also be included in the
record for the amended permit. Are there any
questions before we begin?
MR. ZODY: Could I make just a brief --
MR. ANDERSON: Yes. Mr. Zody?
MR. ZODY: -- comment? This is Michael
Zody. I'm legal counsel for Energy Fuels. In
responding to some of the procedural issues, in terms
of the time frame, while ten days is -- is a somewhat
tight time frame, Energy Fuels is here, is prepared
to answer the questions. The questions have been
submitted as the Agency had requested. There's ample
time today to deal with the questions, and so we do
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not feel there's any prejudice to anyone resulting
from the ten days, and we're prepared to go forward.
MR. ANDERSON: Thank you. Any other
comments before we begin? Hearing none, I will now
call the hearing to order and open the hearing to
receive questions.
MS. LOCKHART: Well, in fact we do have
the questions, and I think probably the procedure
should be just to start through Sarah's. This
isn't -- (inaudible) I'm sorry. Why don't you come
on forward. I guess we'll just turn it over to John
to begin answering questions. I think it's our hope
that we have something of a dialogue here of not just
reciting answers, but frankly, we're going to start
with reciting answers because that's what the
opportunity to review your questions presents for us.
MR. HULTQUIST: Thank you, Laura. My name
is John Hultquist. I'm the licensing manager within
the Division of Radiation Control for low-level waste
in uranium mills in the State of Utah.
And Sarah, I believe your first question
that was submitted as part of your packet was
regarding the application, and your question was:
"Are these materials 'ore,' as contemplated by the
Atomic Energy Act of 1946, as subsequently amended by
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the AEA of 1954, and the Uranium Mill Tailings
Radiation Control Act of 1978? If so, what is the
basis for the DRC's determination?"
Originally, when I looked back at the
licensing application for us to become an agreement
state, these same questions were asked by you to the
NRC. And so I'd like to refer you to Paul Lohaus,
who is the Director of the Office of State and Tribal
Programs, whose letter dated January 15th, 2004 to
you in response to those two questions -- would you
like to --
MS. FIELDS: Well, I don't have a copy of
that.
MR. HULTQUIST: Okay.
MS. FIELDS: That letter with me, so --
MR. HULTQUIST: Okay. Would you like me
to summarize it just briefly? Basically the NRC said
no, the AEA does not (inaudible) Uranium Mill
Tailings Radiation Control Act of '78, it was, and
that alternate feed is ore, and as any natural or
related material that may be mined and treated for
the extraction of its constituents or any other
matter for which source material is extracted, a
licensed uranium or thorium mill, is essentially what
it said. But I'll let you go back to that.
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MS. FIELDS: So is that a regulation that
interprets the -- the Atomic Energy Act?
MR. HULTQUIST: You'll have to ask the
NRC.
MS. FIELDS: Okay, so you're relying
solely on the -- whatever the NRC's interpretation
is?
MS. LOCKHART: Sarah, I don't want to -- I
don't want to limit it to that. I wanted to give you
a preliminary response, but we will be treating your
questions as comments, and I think that they do fit
that.
MS. FIELDS: Okay, because I didn't think
you were going to respond to that.
MS. LOCKHART: I realize that.
MS. FIELDS: I mean, the first question I
have that you indicated you'd respond to would be
1.3, so maybe we can just go to the questions that --
MS. LOCKHART: And we can get to those
documents.
MS. FIELDS: After looking at your letter
today, I just went through the comments and kind of
indicated which ones you would not be responding to.
MS. LOCKHART: Today.
MS. FIELDS: In this.
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MS. LOCKHART: We will be responding to
them.
MS. FIELDS: In this hearing. And so I
guess -- so we don't get it -- probably the best
thing would be to stick to that.
MS. LOCKHART: I think it best just to
concentrate on the ones that have factual matters
anyway, so let's go forward.
MR. HULTQUIST: Okay, so we've got to
push, yeah. Mr. Anderson, if I may just reiterate
for everyone to please always speak directly into the
microphone since we're recording this. And if you
want a transcript that doesn't have a lot of gaps in
it, please speak into the microphone so it's all
going to be heard on the recording.
MS. LOCKHART: I'd like to add to that
that you should say your name, too. My name is Laura
Lockhart, which I failed to do. I'm with the
Attorney General's Office representing DRC.
MR. LUNDBERG: And my name is Rusty
Lundberg, the Director of the Division of Radiation
Control.
MS. FIELDS: And my name is Sarah Fields
with Uranium Watch.
MR. HULTQUIST: Okay. So back to question
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1.3. It is: "Why has Energy Fuel Resources submitted
an application for a license amendment to process
uranium material from the Midnite Uranium Mine?"
Simply, the alternate feed request must be
approved by the director in accordance with license
condition 10.1(c), which is in the radioactive
materials license.
MS. FIELDS: So although other ore this --
can be processed at the mill without a license
amendment, this ore needs a license amendment?
MR. HULTQUIST: Correct. Conventional
ores from mines do not require a license amendment.
And that covers two questions that you had previously
asked in this submittal document.
MS. FIELDS: Okay.
MR. HULTQUIST: But yes, all alternate
feeds require approval from the director. You'll
have to -- someone will have to help me as to which
one's next.
MS. FIELDS: Just a moment. I think
skipping through to 9, where I think the next
questions are that have to do with the alternate feed
amendment, I think the first question is at 9.1.
MR. HULTQUIST: Okay. I agree with you.
9.1 is: "How does the DRC monitor the shipments of
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alternate feed that are received at the White Mesa
Mill?"
Typically, that's done through our
inspectors, who go out to the site on a quarterly
basis. And if a shipment happens to be there at the
time they are there, they will often look at it, both
by visual observations of the shipment coming in and
then also the paperwork associated with that
shipment. In addition -- I'm sorry, go ahead.
MS. FIELDS: Oh. Do you look at all the
paperwork for all the shipments of alternate feed or
just maybe what happens to be coming in at the time
of an inspection?
MR. HULTQUIST: If the DRC staff are out
there and a shipment comes in, generally -- a number
of things, but generally they will look at the
paperwork associated with that shipment. Other
shipments that have arrived in between those
inspection times, they might review some point -- at
some point during the year when they go out and
conduct some other inspections, or if they're looking
at materials that arrive at the site in one of the
inspection modules.
Do they look at all of them? No. We
usually just look at a sampling of the paperwork for
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a few of them. Does it hit all of the alternate
feeds or all the conventional ores? I'd probably
have to say I seriously doubt it, but we do a spot
check on just some of the shipments that come in, and
if things look okay, then we move on to other items
in the inspection. If there's questions, then that
gets asked of the licensee.
I believe the next question is 9.2: "How
does the DRC determine the amount of alternate feed
that is being or has been received at the White Mesa
Mill from any one source?"
And I'm going to say that for this
particular Dawn Mining amendment request, the
condition lists the amount that they will be able to
receive from this license amendment, and the DRC, at
future times, will inspect against that quantity. It
will be the licensee's responsibility to track the
amount that comes in their door as received and
processed. We will look at it at future dates during
the inspection process.
MS. FIELDS: But have you done that for
other -- is that a consistent program that you have,
that you know how much material has come from any one
alternate feed source over the years?
MR. HULTQUIST: We have things we're
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working on with the licensee currently with the
renewal, the 2007 license renewal, is to actually get
a quantity for those alternate feeds that will remain
in the license after the license renewal application
has been reviewed and out to public comment, et
cetera, to put a quantity, or amount, in those
conditions that the NRC approved prior to us becoming
an agreement state.
The DRC feels it's important to know what
that quantity is, and we think it's the licensee's
responsibility to give us that information so we can
put it in the license.
Okay. Your next question, 9.3: "How does
the DRC determine whether the amount of material
received and processed at the mill from a specific
alternate feed source is less than or equal to the
amount of material that was approved for receipt and
process at the mill -- excuse me -- processing at the
mill from that source?"
Again, NCR was the holder of this license,
and I'm not sure if all the alternate feeds had a
quantity value associated with them. And I might
defer this to the licensee at this point, because
they were the ones that were dealing with these
previous license amendments with the NRC. But what
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we do, at the end of the year we ask them how much
material has been processed. And they give us those
numbers, and that gets put out on the State of the
Environment Report that's on our Web page, and it
usually comes out towards the end of the year.
Now, I'd clarify that it doesn't talk
about any one source. It just talks about the amount
of alternate feed in total that was processed for
that year. So I don't know if Jo Ann or Harold or
somebody wants to comment on that as far as the
amount processed in quantities. We have those
numbers because of the license renewal and the
modeling that we're doing for the renewal process, so
that information's going to be available here soon.
MS. FIELDS: Okay.
MR. ROBERTS: I will go ahead and respond
to that. My name is Harold Roberts. I'm Executive
Vice-President and Chief Operating Officer of Energy
Fuels Resources. To the best of my knowledge, some
of the earlier alternate feed amendments issued by
the NRC during the early phases of the alternate feed
program did not have specific maximum quantities of
material assigned to those amendment requests.
The newer amendment requests that
primarily had been authorized by the State of Utah,
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when we submit the applications we do specify a
maximum quantity of material to be received and
processed under that license amendment. So there are
maximum quantities of material that are specified in
the newer alternate feed amendments.
MR. HULTQUIST: Okay, thank you.
MS. FIELDS: As a follow-up question, has
the DRC gone back and looked at the license
applications and the license amendments to determine
if there was a specific amount, whether tons, cubic
yards or drums -- because some of the material comes
in drums -- to see if there was a specific amount
that was approved? Because I know some of them
did -- some of the license applications or approvals
did specify a certain amount of material that would
be coming from a specific site, say Camco or Allied
Signal, I think, now Metropolis. I think there were
maybe some specific amounts identified. I just
wondered if you have looked through those license
applications and approvals -- which are part of the
licensee approval, the applications are part of the
source material license -- to see what was committed
to in the applications.
MR. HULTQUIST: That's correct, they are
part of the license, and some of it we will go back
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and look. Some of if we're asking the licensee to
come up with those numbers and look themselves. Some
of them go pretty far back, and the records that we
were given from the NRC -- I'm not trying to make
excuses, but the records that were given to us were
not in very good shape. They're all by ML numbers.
They have no topical things. They're just on CDs.
And there's hundreds and hundreds of documents, and I
can't tell which one goes to Amendment 19, 17, 2, 3,
5 or 6.
And so in 2007, in this license renewal
amendment, we are asking them to give us those
quantities, and if we -- some of them are going away.
As you know, some of them they never received. They
finished with the project, so they're getting taken
off. So I don't feel it's necessary to go back and
find out what those quantities were. But the ones
that are staying on there, yes, we will know what
those quantities are.
MS. FIELDS: Right, and some of the
earlier documents, the pre-'99 documents, are --
yeah, they're paper copies in boxes. And some of
those boxes are right there in your office today,
so --
MR. HULTQUIST: Yes. We had to go get
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them. Yes, we understand where they are.
MS. FIELDS: So I think maybe you'll be
able to identify some of those early applications,
particularly for the Camco and the Metropolis, to be
able to follow up on that. Thank you.
MR. HULTQUIST: Okay, the next question,
9.4: "How does the DRC determine that the material
received at the mill has the same physical and
chemical characteristics as the material that was
approved by the NRC or the DRC for receipt and
processing? What type of verification is required?
What kind of sampling of the material is required?"
Any material that's brought into that site
is subject to sampling, either by the DRC or at the
request of the DRC. If the samples are collected by
the DRC, we would be looking at basically a grab
sample from the material on the ore storage pad, and
then we would analyze that for radiologics, RCRA
constituents, metals and volatile organic compounds,
VOCs.
MS. FIELDS: So you don't require any type
of sampling?
MR. HULTQUIST: Well, the initial sampling
is done with the characterization of the amendment
request, as part of the amendment request.
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MS. FIELDS: Well, when you have an
amendment request in the '90s, 20 years ago, and
you're receiving material right now, and perhaps
there were a number of different types of materials
that were approved, there -- a lot happens in
20 years at the facility. I'm specifically thinking
about the ore -- I guess it's pronounced Cameco, but
it's in Ontario, Canada. So it's possible that some
of that material would not necessarily be exactly the
type of waste that comes later --
MS. LOCKHART: Sarah --
MS. FIELDS: -- and I -- and I wonder, and
this, I guess, has to do with cumulative impacts and
how you approach the whole alternate feed program,
because it is really a regulatory program. It's an
NRC/DEQ program. And this, this new license
amendment, is just another aspect of that program, so
I'm trying to get an understanding, a better
understanding of the program.
And as I went over it, just questions I
should have asked a long time ago seem to pop up
about how -- how the verification works over the
years, because even this material they're going to
ship to the mill over a period of at least ten years.
And maybe at the source end there might be different
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processes, so you might end up with a little bit
different material, and you would need to have at
least sampling once a year or some kind of sampling
program to verify that changes haven't been made over
the years.
MS. LOCKHART: Are you talking about
alternate feeds other than the one that's being
proposed here?
MS. FIELDS: Well, I guess I was trying to
get at your -- the program that you have and how you
handle alternate feed, how you verify, how you sample
the physical and chemical characteristics over time,
because some of these approvals are over years. It's
not like you approve it and then within the next year
or two the material's been shipped, but it's over
time. I'm wondering how -- how you verify that the
material that was characterized and sampled
originally may -- may change over the years.
Sometimes you get waste, and okay, you
have a specific amount of waste from a specific site.
But sometimes the waste is continually being
generated, and that's what will be here with the --
with this Midnite Mine material. It's being
generated throughout, for the next maybe ten years.
And some of the other material is
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continually being generated. It's not like it's a
cleanup of one site. You got your ponds, you got
this, you sample the material and that's it. But
some -- if you have a continual process of the waste
being generated, then you need a continual sampling
and verification program over time, you know. That's
what -- that's just -- I was trying to get at, you
know, what type of program, and you have given me
some information about that.
MR. LUNDBERG: If I may just add to that.
This is Rusty Lundberg. The standard actually is, in
terms of the waste management arena, is that if you
have an ongoing process that generates waste that's
consistent in that process, and you don't do anything
to adjust that waste generation process -- and this
carries over into the RCRA world as well -- is that
it's only if you go to change that waste generation
process, if you're doing something different, that
you would have relied upon that original
characterization to work from, that's when you're
required or it's more prudent to be able to go back
and reevaluate whether the waste characterization,
the makeup of the waste has changed enough that there
would be additional considerations that need to be
made for its ultimate disposition.
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So it's actually more of the standard that
when you have ongoing waste generation, you rely upon
that original characterization and then look at any
changes that happen in that waste generation process.
And that's been a standard for 20, 30 years plus
here.
MS. FIELDS: Okay. Okay, thank you.
MR. HULTQUIST: The next question, 9.5, I
believe: "What information is received by the DRC
regarding (1) the amount of waste from the processing
of alternate feed from each source of material, and
(2) the physical and chemical characteristics of the
waste?"
Well, as you probably know, the license
application for alternate feeds contain the physical,
radiological and chemical characteristics of the
waste. We receive, on an annual basis, the amount of
conventional ore and alternate feeds that were
processed during the calendar year. So that takes
care of the amount of waste from processing of
alternate feeds.
This information, again, is provided to
the public in the State of the Environment Report put
out by this Agency under the Land section, so that's
where that information is.
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MS. FIELDS: But you -- it's more of a
generic thing. The amount of waste is just a total
amount of waste -- I mean a total amount of waste, or
the total amount of alternate feed that's processed.
MR. HULTQUIST: Okay, maybe we should
clarify. When you say amount of waste from
processing, are you talking about the amount of
material that goes out to the tailing cells as waste
or as byproduct material?
MS. FIELDS: Yeah. Do you -- do you --
MR. HULTQUIST: No.
MS. FIELDS: You just look at the amount
of material that's being processed?
MR. HULTQUIST: That is processed, yes.
MS. FIELDS: And so more or less it's the
same amount going out to the tailings?
MR. HULTQUIST: Harold? Jo Ann?
MS. FIELDS: The amount of material that's
processed minus the amount of uranium plus the
processing fluids equals the tailings; right?
MR. HULTQUIST: Correct.
MS. FIELDS: That's kind of the --
MR. HULTQUIST: You've answered your
question.
MS. FIELDS: -- the general formula.
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MR. HULTQUIST: Okay.
MS. FIELDS: But you don't keep track of
all the physical and chemical characteristics of the
waste that's being deposited?
MR. HULTQUIST: The byproduct material
that goes out to the tails, we do take samples as
part of the groundwater discharge permit on an annual
basis.
MS. FIELDS: Okay.
MR. HULTQUIST: Those slimes are
characterized for chemical constituents. I don't
think it does RADs. It does gross alpha. Thank you.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: Okay, 9.6: "Does the DRC
have data on the cumulative amount of radiological
and chemical constituents in the tailings as a result
of the disposal of wastes from the processing of
alternate feed? If so, where is this information?"
Yes. Again, I just mentioned it's in the
groundwater permit as required by part I.E.(10) of
the Tailings Cell Waste Water Quality Monitoring. On
an annual basis, the licensee collects samples and
those are provided to us.
MS. FIELDS: Thank you.
MR. HULTQUIST: That information is in our
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office. 9.7: "Does the licensee keep track of where
the tailings from the processing of alternate feed
material are disposed of?"
As the licensing agent, I'm going to
generally say yes, they do. The licensee knows which
tailing cell is receiving tails. Therefore, when
processing material, the licensee knows which cell is
receiving the byproduct material.
MS. FIELDS: But not any specific part of
the cell?
MR. HULTQUIST: Jo Ann or Harold? Will
you -- I can't answer that, to be honest with you.
MR. ROBERTS: I'll respond to that. This
is Harold Roberts. It's almost impossible to tell
specifically in one of the active tailing cells to
where a specific alternate feed would be disposed of.
The tailings material goes out there normally in a
form of a slurry, part solution, part solids, and
that's discharged into the tailing cell. So there's
a high degree of mixing in the tailing cell when
those materials are discharged. So I guess the
answer is no, we can't tell specifically, exactly
where each alternate feed is disposed of.
MS. FIELDS: Thank you.
MR. HULTQUIST: Okay. On to Section 10,
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which has to do with the Safety Evaluation Report, or
the SER. 10.1: "Does the DRC believe that the
required Environmental Analysis should be limited to
the four items listed in the SER? If so, why? If
not, what other Environmental Analysis should be
undertaken?"
The SER has considered and evaluated the
four items listed in 42 U.S.C.2021(o)(3)(C) in the
Environmental Impact Analysis, and considers these
items to constitute a sufficiently comprehensive
framework for evaluating potential environmental
impacts resulting from the proposed action. The DRC
believes the list of items to be consistent with all
available applicable NRC guidance State of Utah
requirements, applicable environmental impact
assessable protocols.
And notwithstanding those, the DRC
evaluation includes other additional items such as
the ability of the current mill operating and
radiological practices to safely accommodate the
temporary storage and processing of the alternate
feed material, disposal of the process residuals in
the design tailing cells without increasing potential
impacts to the environment and/or increasing
potential exposures to workers and the public. Also
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assessing the need for implementing additional
protective measures, if any, to mitigate against such
potential increases -- increased environmental
impacts or exposures.
So yes, we consider those four as a
starting point, but that's just the starting point.
There might be other things we need to ask regarding
environmental impacts or releases that we would like
in addition to those four.
MS. FIELDS: Do you look at cumulative
impacts? Like, this is another alternate feed
material, so do you look at cumulative impacts of
disposal of alternate feeds like --
MR. HULTQUIST: Well, it would be -- in
part of the evaluation, when you're looking at that,
you're looking at what they've currently disposed of,
how are they compatible with what's in the tails, how
are they going to handle this, if it's any different
than what they would do with conventional ores or
other alternate feed materials.
If this particular material is identical
to, say, Colorado Plateau ore, then I would say that
they have practices, procedures in place that are
adequate for the protection of the environment and
public health.
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MS. FIELDS: But you're not looking at the
cumulative impacts, environmental impacts from the
processing and disposal of all the other alternate
feeds?
MR. HULTQUIST: Well, that's not in the
scope of this license amendment request, to go back
and look at all the other alternate feeds.
MS. FIELDS: Well, in a way it is, because
there are -- various statements were made in the
application. And I'd have to go back specifically
into the SER, but it said that this did not go beyond
the environmental impacts associated with the
processing of the other materials.
MR. HULTQUIST: Correct.
MS. FIELDS: But there's -- maybe this
goes in the comment, or maybe I have an additional
question about that, because the reality is, is that
most of the alternate feed did not undergo any kind
of Environmental Analysis. The vast majority of all
the alternate feed was not subject to an analysis of
the health, safety or environmental impacts
associated with that because the NRC didn't do an
analysis. So the cumulative impacts, I think, are
important, but you can't really do that -- I guess
this is more a comment, so...
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MS. LOCKHART: Yeah, I think that's right,
and I think we need to reserve it for the comment
response document. But is there anything that Energy
Fuels would like to add on that, on cumulative
impacts generally? That's a repeated issue for
Ms. Fields. Not now, anyway.
MR. HULTQUIST: We're on Section 11 now,
or question 11. It still has to do with the Safety
Evaluation Report. 11.1 is: "Why does Table 1
provide the uranium concentration in milligrams per
kilogram and the other radionuclides in pico Curies
per gram?"
The concentration units are typically used
in the scientific community. Simple as that. When
an analysis is done for uranium, it's usually done in
a mass concentration. The other radionuclides are
typically done in an activity or concentration. So
that's the simple answer. Also, the results that the
licensee provided to us were in those units, so we
provided them as they were provided to us.
MS. FIELDS: I know in the letter from
Ms. Lockhart -- oh, oh, sorry -- for 11.2, they
didn't seem to -- the staff maybe didn't understand
my question, so maybe I could go over about what my
question was about Table 1. And I guess I didn't
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frame my question very well.
MR. HULTQUIST: Go right ahead.
MS. FIELDS: Okay. So I don't -- I'm
looking at Table 1, which is the Range of
Radionuclide Concentrations for DMC Uranium Material,
2010 Analytical Results. So I see for -- the minimum
for thorium-242 is .66 pico Curies per gram, and then
for thorium-228 it's .93 pico Curies per gram. So
the thorium-228 is a little bit above that. And it's
my understanding that -- that they are, if it's an
equilibrium thorium, you can determine the
thorium-232 content by measuring thorium 228.
However, when you go to the maximum, the
maximum amount of thorium-232 is 21.4 pico Curies per
gram, but the thorium-228 is only 1.50. So that is
just way less than thorium-232, and it just seemed
like there was a discrepancy. It seems like the
thorium-228 should be equal to or greater, at the
maximum levels, than 232, because you go to the
minimum and it's a little bit above, but then you go
to the maximum and it's just way, way down at the
bottom. And I -- I -- it was hard for me to
understand that. It didn't make sense to me why the
minimum -- the maximum thorium-228 should be so low
as compared to 232. That was my question.
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MR. HULTQUIST: Yeah. I think the number
on the -- at the table is incorrect, the 21.4 for the
232 for the max. We'll have to get back with you and
make sure what it is from the laboratory results.
MS. FIELDS: Oh, okay, because one or the
other is --
MR. HULTQUIST: It's probably -- my guess,
it's probably 2.1, but I need to be clear. Let me
go -- we need to go look at that. But looking at the
other ones in the other table, they're in much better
agreement. So I'm thinking that the 21.4 for the max
on the thorium-232 on that table is incorrect.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: If you have the SER with
you, there's a Table 2.
MS. FIELDS: Yeah.
MR. HULTQUIST: It also lists those
thorium isotopes, thorium-228, 230 and 232, and those
give you the lab results from those three treatment
plant samples. And you can see the one is 1. -- for
thorium-232, it's 1.14. The next one is .66, as
you've mentioned, and then the other one is .71. So
I don't think the average or the max can be 21.4, so
we'll correct that.
Okay. Question 11.3: "Table 1 includes in
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lead-210, the product of uranium-238 decay. Why does
Table 1 not include lead-208, the end of the thorium
chain?"
Lead-208 concentrations in the mine is not
considered because lead-208 is a stable isotope of
lead, and is therefore not appropriate for reporting
of this. We're not using this as thorium for -- it's
the uranium we're retrieving. And I believe the
analytical results for total lead are reported
elsewhere in the SER, I believe Table 11, which, if
it was stable lead, would report it as a metal, so
therefore referencing you to the other table.
Okay. 11.4: "Table 1 fails to include the
radon emissions from the uranium material. Why is
that?"
Information on the radon emissions from
the uranium material is not considered. The primary
radionuclides parents for radon generation,
assuming -- I'm assuming you're referring to
radon-222. There are several radon isotopes out
there, but I assume you mean radon -- when you say
radon, you're assuming radon-222 from the decay of
radium-226 in your question, and those are from
thorium-230 and radium-226.
Concentration of these radionuclide
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parents in the material are within the range of
concentrations of the radionuclides in typical
Colorado Plateau ore. In other words, they're at the
same concentrations as what we would typically see in
Colorado ores if they were coming in.
For this reason, previous environmental
analyses take care of that issue regarding radon. We
would assume to see the same amount of radon being
generated from this material as we would Colorado
ores, which have already been analyzed in the
original EIS for this radioactive materials license.
MS. FIELDS: But you would have additional
radon emissions from the thorium-232.
MR. HULTQUIST: Which has -- radon-219 has
a 55-second half-life.
MS. FIELDS: Yeah. Yeah, I think it's
radon-220.
MR. HULTQUIST: 220, excuse me. So its
availability is very short. The impacts would be
minimal.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: 11.5: "Why does the SER
fail to identify the other radium isotopes that are
included in total uranium?"
Again, the analytical testing of the four
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samples of filter press kick produced from the
dewatering filter press pilot testing conducted in
2011 included the analysis for the following
radionuclides: 226, radium-226, radium-228.
Analytical results reported in Table 6 of
the SER indicate that the radium concentrations in
the sample were low, ranging from .07 to .2 pics per
gram, and radium-228 concentrations were also low,
all reported concentrations below or less than .2
pico Curies per gram. And we've -- so those are
reported. They're very low concentrations. These,
again, are in typical ranges you would see in
Colorado Plateau's -- Plateau ores that have been
analyzed originally in the license. They're actually
lower than what we would see typically in Colorado
Plateau ores.
MS. FIELDS: Except that Colorado Plateau
ores don't contain thorium-232 in their progeny,
normally.
MR. HULTQUIST: They contain some.
MS. FIELDS: I haven't -- I don't think
that they contain any appreciable amounts of
thorium-232 in the progeny of thorium-232. They
contain 230, but that's because of the uranium.
MR. HULTQUIST: Right, but we're talking
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about the radium-226 and 228.
MS. FIELDS: Yeah.
MR. HULTQUIST: Here in this question.
Those concentrations, the radium-228 concentration is
very, very low.
MS. FIELDS: So it's not included,
basically, because it's so low?
MR. HULTQUIST: Well, we've included them
in the report.
MS. FIELDS: Under total? Under total?
MR. HULTQUIST: Well, we gave you the
radium-226. I believe it's in the --
MS. FIELDS: So it would be included under
total radium?
MR. HULTQUIST: Yes.
MS. FIELDS: So you have 226 and then you
have total radium?
MR. HULTQUIST: Right. There's a
difference of about 10 or 15 pico Curies per gram
there.
MS. FIELDS: So the total would include --
but you didn't identify the other as -- when you go
total radium, you don't say that includes 226 to,
what, 228 and 224, I guess because that -- that
information wasn't included in the application,
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because you probably took most of this from the
application.
MR. HULTQUIST: John, would you like to
add anything?
MR. LLEWELLYN: What we included in the
Safety Evaluation Report was data submitted in the
license application. There were radium-228 results
reported from 2010 testing of the dewatered sludge
from the centrifuge system, and those are in this
response, 36 to 41 pico Curies per gram total radium,
and radium-226, 22.8 to 25.7 pico Curies per gram.
So that addresses total radium and radium-226, total
radium encompassing all, all radium isotopes.
MS. FIELDS: Yeah, I just -- for
someone -- a member of the public just looking at
that, they wouldn't know where the other radium came
from. Radium-226 you have identified, and then there
is an appreciable amount of radium from the other
material, because -- from the samples. So even
though there doesn't seem to be a lot of thorium-232,
the radium from that 232 is an appreciable part of
the total radium. But you -- it just seems like you
should throw that in. Well, that's a comment I can
make in my comments. Thank you.
MR. HULTQUIST: Okay. 11.6: "Has the DRC
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evaluated and compared the radionuclides that will
remain in the uranium material and other alternate
feeds after processing?"
The concentration of 226, thorium-230,
thorium-228, thorium-232, are expected to be at the
same as those present in the material resulting from
the processing. Again, we're taking out the uranium,
so these materials will go to tails, so I would
expect them to be in approximately the same
concentrations when they arrive as when they go out
to the tails.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: Section 12, we're still on
the Safety Evaluation Report. We're talking about
Table 3: "Table 3 provides information regarding the
concentrations of total uranium, radium-226, and
thorium-230 in the uranium material versus average
acid leached ore-derived uranium mill tailings in
Utah."
Question 1 -- or excuse me -- 12.1: "Table
3 only considers radium-226 but does not include the
radium concentrations from the decay of thorium.
Shouldn't Table 3 also include the radium
concentrations from 228, radium-228, and radium-224
and the total concentrations from all uranium
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isotopes in the comparison of the uranium material
and the typical Utah uranium mill tailings?"
And I'm going to refer you back to our
response to 11.5.
MS. FIELDS: Well, there is an appreciable
amount of radium coming from the thorium, but you
didn't compare that amount with -- I mean, this is in
the uranium material, and this Table 3 does not
compare that with the typical Utah uranium mill
tailings. So I just wondered why that wouldn't be,
because it does provide an appreciable amount of
radium going into the tailing impoundment.
MR. HULTQUIST: Can you help me out with
your question and what you mean by "typical Utah
uranium mill tailings"?
MS. FIELDS: Well, you've -- you've --
someone else has identified the typical Utah uranium
mill tailings with the thorium-230 uranium total,
uranium-2 -- oh, 2308, and radium-226. And I
wondered, well, why they didn't compare -- make the
comparison with 232 with -- and then with the radium,
because after all, there is a lot of radium coming
from that 232. If you have total radium for one of
the samples as 35.8 and the amount of radium from 226
at 22.8, you have, I guess, 13.
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MR. HULTQUIST: Approximately 10 to 15
pico Curies per gram of radium-228.
MS. FIELDS: Per gram. But considering
that you have a smaller amount, maybe, of
thorium-228, I just wondered why you didn't compare
that with typical Utah uranium mill tailings.
MR. LLEWELLYN: John Llewellyn, URS. That
could be done. It certainly could be presented. The
radium -- the radium issuing from thorium-232,
it's -- the amounts and the activities would be
dictated by the activities of thorium 232. And in
Table 2 of the SER, thorium-232 levels are reported 1
to 1.14, maybe .7, pico Curies per gram. And I think
the best way to review those concentrations is by
comparing them to what you might find in thorium-232
in typical uranium ores. And that's addressed in the
next question.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: Okay, 12.2: "Table 3
contains a comparison between the uranium material
constituents in the average acid-leached ore-derived
uranium mill tailings in Utah. Why has the DRC not
included a comparison of the thorium-232 and
thorium-228 concentrations for the uranium materials
and the average acid leach ore in Utah?"
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Information from the NCRP 1993 document
indicates that thorium-232 concentrations in natural
uranium ores vary with geographic location and
typically range from approximately 8 to 80 becquerels
per kilogram. And to convert becquerels to
kilograms, we use a conversion factor of 0.027 pico
Curies per becquerel kilogram. So therefore, this
range is approximately equivalent to 0.2 to 2.2 pics
per gram of thorium-232 for typical uranium ores,
which is what we've shown in this material to
contain. It's sitting right around 1.4, I believe.
Since most uranium ores are considered to
be in equilibrium, secular equilibrium, uranium ores
would be expected to exhibit similar ranges of
thorium-228 concentrations. This range of
thorium-232 and 228 concentrations is comparable to
that reported for the DMC -- Dawn Mining Company --
uranium material. And that goes back to that Table 1
and Table 2 in the SER.
And our justification is that for --
regarding these concentrations, they've been
previously analyzed during other ores or the EIS that
was done in 1979 for the -- from the NRC with respect
to this facility. So we're saying that this material
is in the scope of something that was already
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analyzed, or within the envelope of something -- of
an assessment that was already done. Therefore, it
doesn't have to be done again.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: We're on to Section 13.
Here we're referring to Table 5 of the SER: "Table 5
is a comparison of the radionuclide activity
concentrations in proposed uranium material in
previous alternate feeds. Table 5 summarizes the
concentrations of the uranium material as compared
with Colorado Plateau ores and alternate feed
material. Table 5 relies to a great extent on the
information in the W.R. Grace application. That
application was submitted to the NRC in April of
2000, over 13 years ago."
Question 13.1: "Has the DRC reviewed the
W.R. Grace application of April of 2000 and the
licensee amendment approval documents? If so, when
did the DRC review that application and approval
documents?"
And the answer is no, the DRC has not
reviewed the Grace application of April 2000.
The next question is 13.2: "Did the NRC
conduct an Environmental Analysis of the receipt,
processing and disposal of W.R. Grace material?"
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The answer is yes, the NRC conducted an
Environmental Analysis, documented in the
December 20th, 2000 Technical Evaluation Report which
accompanied the license amendment 17. The Technical
Evaluation Report refers to the following
environmental and technical information submitted by,
at the time, International Uranium -- or IUSA during
this evaluation process. And there's five letters
here. April 12th, 2000, the W.R. Grace application
amendment request; April 24th, 2000, IUSA letter
transmitting -- help me out, who provided me this
information -- the RMRP?
UNIDENTIFIED SPEAKER: Radioactive
Material Profile Record.
MR. HULTQUIST: Profile Record, thank you.
April 26, 2000, the IUSA response letter regarding
thorium management and tailings; May 5th, 2000 IUSA
response letter regarding tailings capacity; and
last, December 18th, 2000 IUSA submittal of thorium
management Standard Operating Procedure receipt
through disposal.
MS. FIELDS: Maybe I didn't make clear
what I considered to be an Environmental Analysis. I
should have indicated Environmental Analysis under
the National Environmental Policy Act, which the NRC
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is subject to. The NRC does Environmental Impact
Statements. I mean, there's an Environmental Impact
Statement for the White Mesa Mill, and then it does
environmental assessments for, sometimes, for the
license renewal and for some of the license
amendments.
So when I meant [sic] Environmental
Analysis, I didn't mean a technical analysis. It's
my understanding from the documentation that the NRC
did no environmental review and they -- it was
categorically excluded under 10 C.F.R.§51.22(c)(11),
and, in fact, most of the alternate feed material
license amendments were categorically excluded. That
means they did no environmental assessment.
MR. HULTQUIST: Okay.
MS. LOCKHART: Why don't you correct me if
I'm wrong, but I think what you're saying is -- well,
first, what John is saying, he identified the
analysis that we looked at, which, I think, is
probably the most important thing for the purposes of
this license amendment. With respect to what is
required under federal law, that's not something we
can get into today.
MS. FIELDS: Well, what is required -- I'm
not arguing whether -- or stating whether it was
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required or not. It's the question of whether it was
done or not. If they get -- if they give themselves
a categorical exclusion, that means they don't do an
Environmental Analysis. They don't do an EA. So
that means that they didn't do an Environmental
Analysis, so...
MR. HULTQUIST: Maybe to help with this
question in 13.2, let's just go to the next question.
MS. FIELDS: Yeah, okay.
MR. HULTQUIST: Because I think that's
really where the heart is -- you're out on this one,
is whether or not they received the material or not.
In my understanding, the licensee has not received
any W.R. Grace materials. So all of these questions
about what the NRC did is kind of moot, because
there's not any of that material at this facility.
So can we move on?
MS. FIELDS: But the licensee is -- and in
this table they're using that information as part of
the range of material that -- it is in the range of
Colorado Plateau ores and alternate feed rate of
material concentrations as if it is applicable to the
White Mesa Mill. And I question any reliance on that
information because I -- I don't -- the mill has not
received the material. It's never been -- so it's
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not been processed. And since it's been 13 years, I
doubt if that material will ever come. It's probably
already been cleaned up and sent to another facility.
So I really question using -- how that
data is relevant to this license amendment. I think
if you're looking for a maximum average and maximum
amounts of various materials, whether it's radium,
thorium, lead, U-natural, that it should relate to
material that's actually been disposed of at the
mill, such as the Linde and the Heritage.
MS. LOCKHART: Are we moving from question
to comment here, Sarah?
MS. FIELDS: Well, yeah, that -- I mean --
MS. LOCKHART: I think we need to move
along.
MS. FIELDS: And that was why I asked
these questions, because I don't think it should be
in the -- it is a comment, yes.
MS. LOCKHART: I expect we'll be seeing
that again.
MS. FIELDS: Yeah, it goes to a comment.
True.
MS. LOCKHART: Let's go on to 13.4.
MR. HULTQUIST: Okay. Well, it's kind of
the same question in regards to the 2007 license
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renewal application, condition 10.1 that talks about
the W.R. Grace materials being removed from the
license. So some of these questions might go away or
resolve your issue with us using W.R. Grace as an
analogy. It was still something that was approved by
the NRC, but I'm sure there's other ones that might
be more appropriate.
13.5: "Has the DRC reviewed the
applications and approvals for the license amendments
and license conditions associated with the processing
of alternate feeds? If so, which applications and
approvals has the DRC reviewed and when did these
reviews take place?"
As described in license condition 10.9,
the DRC reviewed and authorized the licensee to
receive and process source material from Ponds 2 and
3 of the FRMI-Muskogee facility located in Muskogee,
Oklahoma. And Sarah, you're well aware of that
because you provided comments regarding this. And
then in addition, the DRC is doing this Dawn Mining
amendment request. Those are the two that the DRC
has reviewed and processed. One has been approved.
One is currently under the public comment process.
MS. FIELDS: But I guess you've indicated
before that you haven't reviewed all the applications
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and approvals for the NRC amendments?
MR. HULTQUIST: Is that what you were
asking here? Did we go back and review the NRC's
approval to alternate feeds material? The answer to
that would be no.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: And then the last one that
we're currently reviewing as well, which I'm sure
you're aware about, is the Sequoia Fuels Corporation
alternate feed request that's currently ongoing and
is under the review process. That information is on
the Denison -- or the DRC's Web page under IUC
Denison/Sequoia Fuels.
13.6: "What is the justification for
comparing the uranium material with materials that
have not, and may not, ever be processed at the
uranium mill -- at the White Mesa Mill?" Excuse me.
Whether or not the feed material was
received and processed, the Environmental Analysis
that takes place as part of approving these things is
what we're looking at. Are there things there that
need to be looked at, those additional requirements
or SOPs or things that may be outside that we need to
look at in addition to what -- those four items we
talked about in an earlier response. And so whether
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or not the material comes into the site and gets
processed is irrelevant to us. It's what was out
there, what's been approved, and are they analogous
to what they're asking for now or is it something
different? And if it's really out of the ballpark,
then are there things that we need to ask that
weren't asked from other ones?
Okay. This is kind of a catch-all for
Section 14. It's other questions regarding the SER,
and this is 14.1. "The SER, page 12, indicates the
thorium-232 specific activity. However, the total
thorium activity for the thorium decay chain is
usually the sum of the thorium-232 and thorium-228
activity. Why did the DRC not include the
thorium-228 activity?"
John, I'm going to put that one in your
court. It goes back to question 12.2.
MR. LLEWELLYN: John Llewellyn, URS. It's
the same content, the question, as 12.2. The 12.2
does give some context comparing thorium-232 levels
in typical uranium ores to this Dawn Mining material.
MR. HULTQUIST: And I believe, if I'm
right, doesn't the table have the thorium-228
activity? Table 3 does.
MS. FIELDS: Table 6 on page 12 does, and
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it's just...
MR. LLEWELLYN: Table 2 of the SER
presents isotopic data for thorium-228, thorium-232
and thorium-230.
MR. HULTQUIST: So again, I think the
thorium-228 activity is included in the SER.
14.2: "What is the amount and activity of
alternate feed materials containing thorium-232 and
its decay products from the -- from material that
have actually been processed at White Mesa?"
The SER prepared to support the Dawn
Mining uranium material alternate feed license
amendment request evaluated and compared the ranges
of thorium-232 concentrations in the Dawn Mining
material in ores, uranium ores that have been
processed at the mine. So we looked at the Dawn
Mining uranium material and we looked at conventional
ores, and these concentration ranges are similar.
And therefore we would assume that the
evaluations for those, whether it be a technical
evaluation report, environmental assessment or other
documents prepared by the NRC, are adequate in the
envelope or in the scope of this amendment request.
The radionuclides, the constituents, the
concentrations, the activities are very similar to
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conventional ores.
MS. FIELDS: So you did conclude that the
thorium-232, 238 activity was similar to conventional
ores at the Colorado Plateau?
MR. LLEWELLYN: John Llewellyn, USRA. I
assume you mean thorium-228?
MS. FIELDS: Yeah, I mean 232 plus 228.
MR. LLEWELLYN: 232, right.
MS. FIELDS: Because it's usually added
together as total thorium.
MR. LLEWELLYN: Right. Well, that's from
the thorium-232 decay chain, and those values in
Table 2 are, as John Hultquist stated, they are
comparable to the range of thorium-228, thorium-232
levels you would see in typical uranium ores.
MS. FIELDS: In typical Colorado Plateau
ores? Because you don't have that comparison in your
table.
MR. LLEWELLYN: Thorium-232 and
thorium-228 levels in ores will vary according to
geographic location, geology, type of deposit. But
typically, for the type of ores that we're
processing, stratabound uranium deposits are all
front deposits, and I would say even uranium Arizona
ores, these levels are expected to be comparable.
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MR. HULTQUIST: We indicated back on
another answer that most of those ores have thorium
somewhere between .2 and 2.2, maybe 2.5 pico Curies
per gram for thoriums. And that's what these results
show as well, that it's right in the middle of that,
right around 1-and-a-half, 1.1, 1.2.
MS. FIELDS: Yeah, but when you -- but
when you compared, there was a comparison Table 3
between the uranium mill material and typical Utah
uranium mill tailings, you didn't give a comparison
of the thorium-232 or the total thorium. You just --
it's not part of what -- any comparison. There's no
-- I don't see any comparison in any of the tables.
And, I mean, my understanding is that
Colorado Plateau ore really doesn't have much
thorium-232. I mean, most of the thorium, the waste
produced that has come to the mill, has come from --
with thorium -- has come from New Jersey because of
the processing of monazite sands. And there were
issues before because of the discrepancy between high
thorium -- the content -- content waste 232 to 228 in
Colorado Plateau ores. So it would be nice to have a
table or better information, and actually, comparison
with the kinds of Plateau ores that were processed at
the mill.
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MR. HULTQUIST: Okay. 14.3: "Has the DRC
reviewed the White Mesa Mill Standard Operating
Procedures for high thorium content ore management?
Has DRC determined whether the uranium material will
trigger the use of this SOP? If not, why not?"
The high thorium content ore management
SOP is not relevant to this license amendment or
applicable to the Dawn Mining uranium material, since
the concentrations of uranium isotopes are well
within typical conventional ores.
14.4.
MS. FIELDS: Could I have a follow-up
question?
MR. HULTQUIST: Sure, go ahead.
MS. FIELDS: So is there a level of
thorium content that would trigger the use of the
SOPs for high thorium content ore management? Is
there a specific cutoff point? I mean have you --
MR. HULTQUIST: I'd have to refer to the
licensee because I don't have it memorized in my mind
as to what the SOP actually says.
MS. FIELDS: I mean, have you reviewed
those Standard Operating Procedures?
MR. HULTQUIST: Yes, we have seen them,
yes.
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MS. FIELDS: So you know --
MR. HULTQUIST: You're asking me if
there's a specific trigger in the SOP. I don't
recall. I would have to pull the SOP and look.
MS. FIELDS: But you've determined that
that wouldn't be --
MR. HULTQUIST: It wouldn't be applicable
to this license amendment because of the thorium
concentrations in this material.
MS. FIELDS: Is low, that it wouldn't be
considered high-thorium content material?
MR. HULTQUIST: Yes.
MS. FIELDS: Do you know what high would
be?
MR. HULTQUIST: Well, if I'm looking at
these materials, and typically thorium concentrations
are around the 1 to 2 pico Curies per range, I'm not
going to consider that high.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: Question 14.4: "The SER,
page 12, states: "Demonstration that the uranium,
radium and thorium activity concentrations of the
uranium material are below the maximum range of
previously-approved conventional ores and alternate
feed materials indicates that radon levels resulting
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from the processing of uranium material are expected
to be within the range for which the existing
approved controls and monitoring programs are
currently established and considered appropriate.
Did the DRC also evaluate the range of materials that
have actually been processed at the mill, not just
the previously-approved alternate feed?"
John? (Pause) I'm going to say again, the
concentrations that are provided in the application
from Dawn Mining are within the range of conventional
ores, whether it be Colorado or Arizona strip.
Therefore, any additional analysis regarding
alternate feeds aren't necessary.
MS. FIELDS: Thank you.
MR. HULTQUIST: 14.5: "The DRC refers to
approved conventional ores. Does the DRC approve
conventional ores for processing at the mill?"
No. That is, as stated in response to
question 1.2, the DRC does not approve conventional
ores. This statement was incorrect in the SER.
MS. FIELDS: Thank you.
MR. HULTQUIST: 14.6: "The UCA and the
Atomic Energy Act require the assessment of the
radiological impacts to the public health from the
processing of the uranium material. However, I am
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unable to find such an assessment. There is no
discussion of -- of how exactly the processed
material will be regulated under the applicable
regulations, or now, exactly the radon and other
radionuclides will be controlled over the life and
long-term care of processed uranium material. There
is no discussion of the health risks from the radon
and other radionuclides associated with the
transportation, storage, loading, processing,
disposal, perpetual care of the uranium material and
its processing wastes.
"Where exactly in the SER does the DRC
assess the radiological impacts to the public health
from the transportation, storage, loading,
processing, disposal and perpetual care of the
uranium material and its processing wastes?"
Again, this material is very similar to
conventional ores. We relied partially on the fact
that the ranges are typical, are within the scope of
what this facility does. The original EIS back in
1979 provided them with the analysis, with the
environmental assessment of taking ores and
processing them. These are in the same ranges as
what you would -- that EIS would allow them to do.
Therefore, those assessments have been made.
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14.7, we're talking about the Safety
Evaluation Report. Excuse me. The safety evaluation
report at Table 7 provides information regarding
derived air concentrations from ores and selected
alternate feed. However, Table 7 does not explain
what exactly the numbers in the table actually
measure. Table 7 includes columns identified as UF4,
K4 [sic], regen material and calcined material, but
it does not indicate the source or nature of those
materials.
"Please explain what DAC means and what
the numbers in Table 7 measure."
In the R31315 definition, derived air
concentration, or DAC, means the concentration of a
given radionuclide in air, which, if breathed by the
referenced man for a working year of 2,000 hours
under conditions of light work, results in an intake
of one annual limit of intake (ALI). For purposes of
these rules, the condition of light work is an
inhalation rate of 1.2 cubic meters of air per hour
for 2,000 hours in a year.
So the DAC values in Table 7 are derived
limits intended to control chronic exposure and are
used in the analysis of airborne particulate
exposures to workers. Table 7 presents DAC values
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for radionuclides developed for the uranium material
from Dawn Mining based on applicable regulations and
mill procedures and that take into account the
specific radionuclide makeup of the Dawn Mining
material. And the units in those DAC values are
micro-Curies per milliliter.
14.8: "What is the source and nature of
the UF4, K4 regen material and calcined material?
How much of each of these materials has been
processed at the mill?"
For UF4 material, the processing tons is
914. For the KF material, the total processed is
5,646. For the regen materials, total process is
535 tons, and the calcined material is 16,934 tons.
And that's from '99 to present. These materials, the
UF4 and the KF, are naturally uranium-bearing
material residuals from Cameco Corporation's Port
Hope facility. The regen material and calcined
material are naturally uranium-bearing residuals from
Comeco's Blind River conversion facility. The four
materials were approved by NRC for processing as
alternate feeds at the mill under amendment 9 to
source material license SUA1358. Do I need to repeat
any of those for you?
MS. FIELDS: No, I think I --
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UNIDENTIFIED SPEAKER: It's in the
transcript.
MR. HULTQUIST: Yeah, but let her have
them if she needs them.
MS. FIELDS: Okay, thank you.
MR. HULTQUIST: All right. "Please
identify the dates of the applications, license
amendments and Environmental Analysis or analysis
associated with the processing and disposal of the
UF4, K4, regen materials and calcined materials."
IUSA submitted the license amendment
application on June 4th, 1998. The NRC conducted an
Environmental Analysis as documented in the
November 2nd, 1998 Technical Evaluation Report which
accompanied license amendment 9. The technical
evaluation report refers to the following
environmental technical information, and there's a
bunch of dates. Do you want them or can you get them
out of the transcript?
MS. FIELDS: Yeah, I think I can get that.
I think I already have -- yeah, I can get that.
MR. HULTQUIST: Okay.
MS. FIELDS: But as a point, a TER is not
an Environmental Analysis. An Environmental Analysis
would -- and I'm sorry I wasn't more specific,
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because under the National Environmental Policy Act,
where you do an analysis of the environmental impacts
from the licensing action, and this also -- there was
no Environmental Analysis for that, either. A TER is
some -- they do -- the NRC often does a Technical
Evaluation Report and then they do their
Environmental Analysis, an EIS or an EA, or they do a
categorical exclusion. But a TER is not an
Environmental Analysis under NRC regulation.
MR. HULTQUIST: Okay, thank you. The only
other thing I would add is the NRC issued license
amendment 9 on November 2nd, 1998.
MS. FIELDS: Oh, yeah. I'm sorry, as I
went through that, I was not more specific.
MR. HULTQUIST: No, I think you were very
specific. You've asked for all of those details.
MS. FIELDS: Yeah, but as far as what
constitutes an Environmental Analysis under NRC
regulation, I was not specific. It's under their
part 51 regulation.
MS. LOCKHART: And you're going to be
providing information about why that is -- you
believe that's the case? Because I don't want our
silence to be interpreted as an agreement with that,
that's all.
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MS. FIELDS: Yeah, that -- that's true. I
mean, it's a question.
MS. LOCKHART: That's all we need.
UNIDENTIFIED SPEAKER: If I may, that's
what I was going to get to as well, to help us
clarify what -- if you're identifying gaps or
activities that were not conducted by NRC when they
had the regulatory jurisdiction, it would be nice to
know what kind of context you're expecting that for
carryover for us as an agreement state. I don't want
you to answer that now. We would need to look for
that kind of context for what you're bringing up.
MS. FIELDS: Right, and we're all learning
on this question-and-answer process as to how to
write better questions and how to give good answers.
So we're all -- this is our first, first experience
with this. It's my first experience, so I'm
learning, too.
MR. HULTQUIST: Okay. 14.9: "The SER,
page 14, states the concentrations of thorium-232 and
its decay products are negligible, and its decay
products are negligible and can be ignored. What are
the concentrations of thorium in decay products from
the uranium material and other feed materials
processed at the mill? Compare the half-lives and
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health impacts of the -- excuse me -- compare the
half-lives and health impacts of the decay products
of uranium with those of thorium decay products.
What is the basis for discounting the health risks
from thorium-232 and its decay products?"
Again, I'm going to say these
concentrations of thorium-232 and their decay series
are in line with conventional ores. That analysis
was done in the EIS back in 1979, so it's already an
analyzed condition with what the material consists of
with this amendment requirement, or request.
MS. LOCKHART: Let me just say briefly, on
14.10, you'll remember that that's one of the ones
that we said was not relevant. But John,
nonetheless, has an answer for you.
MR. HULTQUIST: Yes, I still want to
answer this one, because I think, Sarah, you should
be able to answer this yourself. I don't mean to be
blunt, but if you've got a vehicle that has 200
millirem per hour at any one point on the outer
surface and you're right next to it, I'm assuming
that person is right next to it, you have to make
some assumptions that he, that that person, is right
up against that contact, and that actual shipping
container has 200 MR on -- per hour, and that person
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would only have to be there half an hour.
But that will never happen. That 200
millirem is a standard. It's a limit. It doesn't
mean that's what's in the conveyance. All
radionuclides are -- shipments are going to have
different exposure rates. But if you want to take
the theoretical aspect of your question, then it
would be a half an hour that they would receive the
100 millirem if they were next to that, right next to
it in contact with the surface. If they were right
next to it and they were a distance away, then it's a
lower number than 100. Does that make sense?
MS. FIELDS: Yes, thank you.
MR. HULTQUIST: But again, it's a
transportation issue, and that's what DOT allows them
to have on contact at the surface.
MS. FIELDS: Right, thank you.
MR. HULTQUIST: And most licensees or
shippers don't even come close to that number,
because if DOT stops them and it exceeds, then they
get fined.
Okay, 14.11: "Were the White Mesa Mill
tailings cells 4A and 4B designed contemplating the
disposal and perpetual storage of wastes from the
processing of material other than natural ores? If
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so, please identify the specific design elements in
cell 4A and 4B that were developed in anticipation of
the disposal of waste from the processing of
materials other than natural ores from the Colorado
Plateau."
Each amendment request submitted to the
DRC includes an analysis of the compatibility of the
proposed alternate feed with the tailing systems.
The analysis considers the currently known chemical
composition of the tailings, which we get from those
annual sampling events, which reflects the presence
of residuals from previously alternate feeds and
compares that composition to the proposed alternate
feed.
The design of the tailing cell is
compatible with the radiological and chemical
constituents of the uranium material from Dawn
Mining. The evaluation to date has not identified
any potential chemical reactions in the tailing
systems.
MS. FIELDS: Thank you.
MR. HULTQUIST: 14.12. "Please identify
and describe the specific design elements for the
construction of the cell 4 and 4B that would
anticipate the disposal of radiological and chemical
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constituents found in the uranium material."
I don't believe this is relevant to the --
to the amendment request. The design elements
anticipated have been selected based on constituents
and tailings waste fluids from the conventional mill
at the White Mesa Mill. We know what's going in
there, so those geomembranes, the liners, the leak
detection systems, they're all best-available
technology, state-of-the-art containment systems and
bankments.
"How long after closure of the cells 4A
and 4B will it take to move -- remove free-standing
liquids from the cells such that the liquids would no
longer provide a source of leakage from the tailings
impoundments into the surrounding soils and
groundwater?"
This question, I'm sorry, is outside the
scope of this amendment request. We don't know how
long those cells will -- the life will be, the
dewatering of them, et cetera. It's outside the
scope of this amendment request. They could fill up
in two years and we could have them dewatered in six.
They could take ten years to fill up. We don't know.
That's why it's not relevant to the amendment
request.
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14.14: "Which radiological and chemical
constituents present in the uranium material have
been found in excess of groundwater standards in the
monitoring wells at the White Mesa Mill?"
Again, the mill's quarterly groundwater
monitoring reports are available on the DRC Web site,
and they contain a tabulation of every analyte in any
groundwater monitoring well that has exceeded its
respective groundwater concentration limit for that
monitoring period. Many of these analytes are found
in natural background water as well as in natural
ores and the uranium material. So I hope that
answers your question.
MS. FIELDS: Yeah, I'll --
MR. HULTQUIST: They're out there.
MS. FIELDS: So I guess there's probably a
number of them, I mean, because -- so it's just my --
my duty to take a look. Thank you.
MR. HULTQUIST: 14.15: "Has the DRC
reviewed the amount and nature of contaminates in the
previously-approved alternate feeds to determine
whether groundwater discharge would need to be
revised in order to detect the constituents in an
alternate feed that are not found in Colorado
Plateau's ores?"
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Again, to me, this question is outside the
scope of this license amendment. However, to answer
your question, the answer is yes. The DRC, as part
of its review of Fansteel, was an example. That
material required the discharge permit to go out to
public comment because we added some things and made
some modifications to it. This one we do not have
to. They are all already analyzed, or a surrogate is
being analyzed, for the Dawn Mining material.
14.16: "Has the DRC determined the
chemical compatibility of the contaminates in the
previously-approved alternate feeds to determine the
types of chemical reactions that would occur in the
tailing cells as a result of disposing of the
contaminates in the tailings impoundment?"
Again, each amendment request submitted to
the DRC includes an analysis of the compatibility of
the proposed alternate feed materials, both the
chemical and radiological constituents in that feed
material and what's already in the tails. So we look
at that and we determine if there might be or could
be a reaction with the composition. Is it neutral?
Are they the same? Is there anything that's unusual
about them? And to date, we have not identified any
potential chemical reactions in the tailing cells.
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14.17: "The SER states repeatedly that the
radiological and chemical constituents in the uranium
material are similar to ores in alternate feed
materials previously processed at the mill. However,
the SER often compares the constituents with those in
alternate" --
MS. FIELDS: "Feed."
MR. HULTQUIST: "Alternate feed" --
sorry --
MS. FIELDS: I left out a word.
MR. HULTQUIST: -- "alternate feed
approved for processing, but not necessarily
processed at the mill. Why does the SER not limit
its similarity analysis to feed materials that have
actually been processed?"
Again, for this alternate feed material,
the radiological chemical constituents are within the
previously-analyzed condition from the assessment
done in 1979, the EIS that was done in 1979 for
conventional ores.
14.18: "The SER refers to the Occupational
Safety and Health Administration regulations."
I'm just going to go on to the response.
The reference, though, in the SER is in error. It
should be MSHA, the Mine Safety and Health
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Administration. The mill is subject to the
regulation enforcement of the Mine Safety and Health
Administration as a result of a tri-party agreement
between USNRC, MSHA and OSHA. MSHA conducts
inspections at least semiannually at the mill. The
content and status of the -- excuse me -- the content
and status of all MSHA citations from the previous
licensed performance period have been provided to the
DRC, or formerly to the NRC, with each license
renewal application.
15. "The SER" -- can we just go to the
question?
MS. FIELDS: I guess.
MR. HULTQUIST: "Has the DRC taken into
consideration the fact that elevated levels of
radionuclides have been associated with the disposal
of wastes from the processing of alternate feed
materials in a White Mesa Mill tailings impoundment?"
And the DRC is aware of the U.S.
Geological Survey's published report of an assessment
of potential migration of radionuclides in trace
elements from the White Mesa Mill. We provided a
preliminary review of our findings and we shared them
with the public on July 9th, 2012. That meeting was
held in Blanding. Currently, our actions are being
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taken. As part of the license renewal application,
some of those things will be incorporated into the
renewal, and those reviews and discussions are
ongoing with the licensee at this point.
MS. FIELDS: Just a little follow-up. I
think I -- one thing I was referring to was the
recent Subpart W July 2013 Monthly Radon Flux
Monitoring Report from cell 2 where they identified
an area where waste from the processing of alternate
feed material had been disposed of in cell 2, and
they identified that as an area of increased radon
emissions because cell 2 is releasing radon above the
regulatory standard because it's being dewatered, so
you don't have the waters attenuating the radon
releases within the cell at this time.
So this is the first that I've known of
any documentation or example or -- of an area in a
tailings cell where the wastes from alternate feed
was producing elevated levels of radon emissions as
compared to other parts of the tailings impoundment.
And this is something Energy Fuels has found.
And what that means to me is that this
alternate feed that was disposed of, I mean the
tailings, had radon -- radium and other radionuclides
above the level of ordinary tailings from Colorado
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Plateau ores. And I think a copy of -- I submitted a
copy with my questions.
MR. HULTQUIST: Yes, did you.
MS. FIELDS: So I think that that is an
issue with any processing with any material, any
alternate feed application, including this, that
sometime down the line the waste might be a source of
increased radon emissions that would result in
noncompliance. And this is the situation now. So
there's obviously some difference between the
radionuclides disposed of from this alternate feed
and the radionuclides from the tailings from Colorado
Plateau ore. And this is really a new issue that's
come up because of the dewatering.
MR. HULTQUIST: Well, Sarah, could I ask
you a further question about your statement there?
Do you know for a fact that alternate feed materials
that were processed and the tails that went out from
that alternate feed are actually sitting within the
top four or five feet of cell 2?
MS. FIELDS: I don't know. I'm just
basing this --
MR. HULTQUIST: Well, you're making an
accusation that --
MS. FIELDS: -- on statements -- no. This
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is what -- this is what Energy Fuels found, and it's
the statements -- the statement is in their -- their
document. I -- I didn't make this statement. I
didn't go out -- I can't go out there and measure
anything. I don't know the history of each. But
they found elevated levels in that area. They found
elevated levels where the slurry line was.
MR. HULTQUIST: Right, I understand. I'm
just saying that conventional ores with the radium
concentration can still produce a radon flux that is
greater than the 20 pico Curies per meter per second
that's required by Subpart W, so --
MS. FIELDS: Right, I'm aware --
MR. HULTQUIST: -- so the action that the
licensee has to take --
MS. FIELDS: -- aware that --
MR. HULTQUIST: -- is to meet that
compliance limit. Dawn Mining materials will not be
going in cell 2 because it is closed. So that
particular question regarding cell 2 and Subpart W
and the radon flux coming off there is not relevant
to this license amendment, because those tails are
going to go into either 4B or 4A or some other cell
down the road. And radium coming from conventional
ores can still create a flux that is greater than
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what alternate feeds do. It depends on how it's
handled, how much water is in the system, how close
it is to the surface and how much cover they have.
So I would just like to say that because
it's in cell 2 and that cell has an interim cover on
it and it's being closed and dewatered, that is not
relevant to this license application where this
material is going to be processed and put in other
tailing cells.
MS. FIELDS: Well, you may --
MR. HULTQUIST: And I hope the licensee
gets those concentrations down.
MS. FIELDS: -- you answered my question.
I asked you if you take that into consideration, and
I guess you have considered that. Thank you.
MR. HULTQUIST: Which one are we on? I'm
sorry.
UNIDENTIFIED SPEAKER: 15.2.
MS. FIELDS: 5.2, sorry.
MR. HULTQUIST: "Has the DRC taken into
consideration -- taken into consideration the fact of
the disposal of materials from the tailings
impoundments by wind and other natural forces?"
Yes. The SER considers factors that --
the dispersal of materials from tailings
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impoundments. The facility has BAT operations
monitoring and maintenance plans that are approved to
keep the dust from being generated coming off the
tails. They use best-available technology standards
in their groundwater discharge permit. They're
inspected on a daily basis. If there's -- if there's
dispersal materials coming off there, there are
certain requirements that they're to do out of their
SOPs to water them down, put applicant water or salt
agents, what have you, to minimize the amount of dust
leaving the tailing cells. They need to do that on
their ore storage pad as well.
MS. FIELDS: Thank you.
MR. HULTQUIST: So we feel that their
current SOPs and their operation plans cover the
release of materials both from the ore pad and the
tailings cells.
"What are the radiological constituents
that will be disposed of in the tailings impoundment
from the processing of the uranium material that are
different from the radiological constituents that
would be disposed of from the processing of Colorado
Plateau's ore at the mill" -- excuse me -- "Colorado
ores at the mill?"
None.
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MS. FIELDS: Thank you.
MR. HULTQUIST: "Do the EIS and
Environmental Assessment (EA) for the White Mesa Mill
operation evaluate the health, safety and
environmental impacts from the receipt, storage,
processing, disposal and long-term storage related to
the processing of alternate feed materials? If so,
please identify the documents and sections that
contain such evaluation."
I think we've kind of kicked this one down
a couple of times, but again, the license renewal
application of 1991 contemplates the alternate feed
material being processed at the mill, and so does the
application of 2007. The NRC alternate feed guidance
and the mill's radioactive material license
anticipate the potential for processing of alternate
feeds in conventional uranium mills specifically by
requiring the submission of a license amendment
containing an environmental report for the use in an
Environmental Analysis specific to each proposed
alternate feed. In other words, they have to come in
and get a license approved -- license amendment
approved from the director.
15.5: "Has the DRC conducted an evaluation
of the cumulative impacts of the receipt, storage,
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processing, disposal and long-term storage related to
the processing of alternate feed materials at the
White Mesa Mill?"
Cumulative impacts are evaluated during
inspections and sampling over the course of time by
way of the licensee's environmental monitoring plan
and the groundwater discharge permit.
MS. FIELDS: Thank you.
MR. HULTQUIST: Believe it or not, folks,
we're almost done with her questions.
MS. FIELDS: Last question.
MR. HULTQUIST: 16.1: "Does the DMC" --
Dawn Mining Corp -- "have a general or a specific
license to transfer the uranium material from the
Midnite Mine to the White Mesa Mill?"
I'm going to let Energy Fuels respond to
this one because I think I've done enough talking for
the last hour or so. So if one of you wouldn't mind
taking that.
MR. FRIEDLAND: David Friedland, Senior VP
and general counsel at Energy Fuels. The answer is
Dawn Mining has all the approvals required to
transfer the materials. The Midnite Mine site is
regulated under CERCLA management under EEP
jurisdiction at this point, and no specific licenses
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are needed for -- in addition to that regulatory
authority in order to transfer the materials from
that site to the White Mesa Mill.
MS. FIELDS: I have a question. Is that
an opinion of the EPA in Washington? I mean, has the
EPA --
MS. LOCKHART: This is -- this is a legal
question, but let's go with it. If you'll take a
look at CERCLA §121(e), you'll see that there's an
exemption from having to obtain any federal permits
or licenses for CERCLA activities that are conducted
on site.
MS. FIELDS: Because I did call the EPA
and they said they didn't know and they would look
into it.
MS. LOCKHART: I'm sure somebody in EPA
knows.
MS. FIELDS: Okay.
MR. LUNDBERG: Sarah, this is --
MS. FIELDS: So I just wondered if you'd
really looked into that and talked to the EPA or --
or the State of Washington.
MS. LOCKHART: My request to you would be
that you provide, in your comments, some context that
shows how that is an enforcement issue that we should
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be managing. I don't see that it is, so let's do it
in that context.
MS. FIELDS: Okay, yeah, I'll do further.
Thank you very much for your patience.
MR. LUNDBERG: Just if I -- this is Rusty
Lundberg. Before you finish, just to clarify that
last point, when you said you talked to EPA, are you
talking EPA Region 10 --
MS. FIELDS: Yes.
MR. LUNDBERG: -- out of Seattle that has
jurisdiction over the State of Washington?
MS. FIELDS: Right, right. Not Region 8,
Region 10, yeah.
MR. LUNDBERG: But I wanted to make sure
you weren't referring to the Department of Ecology,
making them the EPA in Washington. You're talking
about U.S. Environmental Protection Agency?
MS. FIELDS: EPA Region 10, yes.
MR. LUNDBERG: Okay, thank you.
UNIDENTIFIED SPEAKER: Do people want a
break?
MR. HULTQUIST: Maybe we can -- next, in
terms of order of proceedings, would be the questions
from Grand Canyon Trust. So how do you wish to
proceed? Would you like to go ahead or do you want
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to take a break before you start?
MS. TAPP: This is Anne Mariah. Either
way is fine. I don't anticipate that these will take
a long time.
MR. HULTQUIST: Do you have a preference,
staff?
UNIDENTIFIED SPEAKER: Let's go.
MR. HULTQUIST: Okay, we're going to go
ahead. So Anne Mariah, do you want to introduce
yourself and proceed?
MS. TAPP: Yeah. I'm Anne Mariah Tapp.
I'm an attorney for the Grand Canyon Trust, and
again, I apologize for being late. My computer
managed to die earlier today, and I've been trying to
deal with that, so my apologies for that. But I am
prepared to go ahead. It seems like several of the
questions got folded into --
MS. LOCKHART: I think there's going to be
a lot of similarities.
MR. HULTQUIST: Yeah, so --
MS. LOCKHART: You're pointing to that
letter?
MS. TAPP: To this letter.
MS. LOCKHART: Really, only one?
MS. TAPP: One, okay, perfect.
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MS. LOCKHART: I remember three.
MS. TAPP: Great, yeah, so we can just
proceed with you all's response to those.
MR. HULTQUIST: Okay. Question number 1
is: "What testing did the Utah Division of Radiation
Control perform evaluating the compatibility of the
liners of cells 4A and 4B with the alternate feed
material proposed to be accepted from the Midnite
Mine site? What were the results of that testing?"
The -- I guess initially the answer to
that general question is no, there was no specific
testing to the materials. However, these materials,
the radiums, the radiologic constituents, the
chemical constituents, are very similar to what you
would see in what byproduct material goes out to
these tails.
So cell 4 and cell 4B were -- went through
our process with the DRC, and they were constructed
of 60-mill high-density polyethylene HDPE flexible
geomembrane. Both cells include a double 60-mill
HDPE membrane with a leak detection system. These
liner systems are designed and consistent with BAT --
best available technology -- design criteria for
waste containment facility liner systems.
In other words, when we spec these systems
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out, they're supposed to contain these types of
materials. That's why they build them. Specific
testing, though, again, regarding the chemical
compatibility with the specific uranium material was
not done on these liners.
MS. TAPP: Okay, thank you.
MR. HULTQUIST: And I have some more
specifics here about that HDPE, so I don't know if
it's really necessary to go into them.
Number 2: "What testing will be undertaken
to determine whether the groundwater protection
standards for barium contained in 10C FAR, Part 40,
Appendix A, criterion 5(c) are being met at the
mill?"
Currently, no analysis of groundwater
samples for barium will be performed. The existing
groundwater monitoring program conducted at the mill
site is deemed adequate for monitoring the potential
impacts of groundwater resulting from the disposal of
residuals resulting from processing of the Dawn
Mining uranium material.
MS. TAPP: To clarify, can I --
MR. HULTQUIST: Uh-huh.
MS. LOCKHART: He was going to add
something. Isn't there -- I mean, there's something
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that stands in the place of barium, essentially.
MR. HULTQUIST: Yes. I'm going to get on
to the issue about barium and the salt that it --
that's created in the solutions. But if you want to
go ahead and ask your question.
MS. TAPP: Sorry.
MR. HULTQUIST: Also, as described in the
SER, the DMC uranium material barium is present as
barium sulfate. The solubility of barium sulfate is
cold water -- excuse me -- in cold water is .022
milligrams per liter, and in concentrated, sulfuric
acid is .025 milligrams per liter. Once in the mill
circuit, barium sulfate would remain as barium
sulfate due to its low -- very low solubility in
concentrated sulfuric acid.
At the listed concentration of sulfide in
the tailing solutions, 67,600 milligrams to
87,100 milligrams in cell 4A, a change in the ambient
barium concentration in the tailings solutions to .02
milligrams per liter due to the placement of this
uranium material would be expected to be very, very
negligible.
Would that suffice, or would you like some
more?
MS. TAPP: No, I think -- just out of --
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this is kind of a practical question. Just out of
curiosity, what would the burden on you all be to
institute some kind of barium monitoring? Just what
would that look like in terms of --
MS. LOCKHART: The difficulty that we'd
have, according to what John just said, is that we
would have to have a basis for that, and so -- for
requiring them to do that. And if there is
essentially zero expectation that it would end up in
the groundwater, it would be pretty tough for us to
justify that. And I'm saying that as an "if," so if
you --
MR. HULTQUIST: Maybe, more specifically
to get to your concerns, there's other surrogates or
there are other analytes that we monitor for that's
going to be out in front with the leak than barium,
so it's the last of our worries. There's other
things that we have in place that we can see long
before barium would ever get there.
MS. TAPP: Okay.
MR. HULTQUIST: So we feel those are
adequate to protect the health and safety and the
environment.
MS. TAPP: And that appendix A, criterion
5 does impose a groundwater standard; correct?
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MR. HULTQUIST: Uh-huh.
MS. TAPP: But I'm just, again, just
clarifying for myself, but there is no --
MR. HULTQUIST: Right, but we did not
include -- we did not include that table or all of
those analytes in the groundwater discharge permit
because that's a federal regulation and we have our
state groundwater quality rules.
MS. TAPP: Right. Okay, thank you.
MR. HULTQUIST: I don't have 4. I thought
we were --
MS. LOCKHART: You thought that was that?
MS. TAPP: Oh, it's not that many left.
MR. HULTQUIST: Sorry, I don't know why
it's not there. Okay, 4: "What regulatory action has
been taken to address and eliminate the off-site
deposition identified in the USGS report dated
February 8th, 2007?"
Again, practical steps. We're working
with the licensee in the 2007 renewal application to
implement some of those things, to revise them from
our monitoring plan, a couple of additional air
stations and things, and we're working with them to
take care of those things. Our findings are out on
the Web, and you can see what we've decided to
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include and some things we said well, we're not real
sure about those. But there are some things that we
can do with -- in the renewal that address the
off-site migration.
MS. TAPP: Right, and the timing of the
implementation of those steps is?
MR. HULTQUIST: Whenever we can get that
SER done and the mill dose run done, and get the
draft back to them, the addendum that should come
out. I'm hoping by the end of this year we should
have something out to the public and the draft
license showing those changes and whatnot.
MS. TAPP: Okay, thank you.
MR. HULTQUIST: But if you want to see
what the DRC looked at as far as that USGS report,
that's on our Web page.
"How would the chalk-like composition of
Midnite Mine material" -- or excuse me -- "Midnite
Mine alternate feed materials exasperate the outside
deposition problems identified in the USGS report?"
Again, the stuff going into the tails we
feel the licensee has a handle on. One of the things
we put in this new license condition 10.20 is that
they cover this material when it's on the ore storage
pad. If it's going to sit out there for anything
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longer than seven days, I believe is what the
language says, that they will put a cover over it,
because we realize this stuff is brick-like, and if
it does decompose, it's going to be a very fine,
light material. It's not going to be big chunks of
ore typically sitting on the pad. So we've added
that condition that they cover it.
MS. TAPP: And our concern is the
seven-day -- I had 21 days in my head, but seven-day
window doesn't adequately account for high winds that
could occur in that seven-day period. So we're
concerned about the adequacy of that in terms of
protecting downwind communities and the environment
from the impacts of that dust. So just to put that
out there.
MR. HULTQUIST: Okay, point well taken. I
know the Standard Operating Procedures for them is to
water that material down. They have a water truck
that goes around the ore storage pads, so if there's
high winds, then they need to get their water truck
out and get that moisture content out to minimize the
dispersion.
MS. TAPP: Right, and I think that the
language in some of the conditions in the air quality
permit, again, if I recollect correctly, are a little
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bit loose in terms of "as deemed necessary," "as
appropriate." And a little bit we're just also
concerned about the ability -- about the practical
enforceability of those types of language in the
permit.
MR. HULTQUIST: Okay.
MS. LOCKHART: Did you say air quality
permit?
MR. HULTQUIST: Yes.
MS. TAPP: Right, I understand that we're
not in here for --
MS. LOCKHART: No, I just wanted to
understand.
MR. HULTQUIST: I'm going to put that on
the licensee. Do you want to talk about your
practical operations out there and what you see when
winds kick up?
MR. ROBERTS: Yeah. This is Harold
Roberts again. Let me address specifically the Dawn
Mining material. You know, we've got a requirement,
once it is on the ore pad for a certain number of
days, to cover that material. And initially, the
material, when it's received on site, will have a
very high or relatively high moisture content. So
the possibility of any windblown material coming off
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of that until it dries out is very, very remote.
So the time period given before we need to
cover the material will, you know, we feel, be
adequate to ensure that the material is still
relatively high moisture content, and thus not be
susceptible to windblown material leaving the ore
pad.
MR. HULTQUIST: I can't remember, did we
have seven days or 14 days?
MR. ROBERTS: 14.
MR. HULTQUIST: 14, okay.
MS. TAPP: We're splitting the difference
there, 7 and 21.
MR. HULTQUIST: Well, for some reason when
I said 7, I thought that's not right. We agreed on
something else, I think. And again, I think the
Agency's being proactive here. They've never been
asked to put a cover on there, and I think there's
some justification to say they shouldn't have to.
But it can sit out there for a fair amount of time,
and this material is not in big chunks.
It can -- when it's dumped, it could break
apart and become fines and then be transported. So
we're sensitive to that issue, and that's why we
thought 14 was reasonable. If winds pick up before
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then, then they should be applying water on it, get
that moisture content back up to minimize the
dispersion. Or they can just cover it before then if
they want, if they know they're not going to process
it. But we'd like to give them some flexibility as
well.
MS. TAPP: Right, and just given that this
isn't normal dust, it isn't road dust, we feel that
there should be more stringent controls and that
perhaps more than -- or less than a 14-day window is
justified, given the content of the alternate feed
material and the high-uranium content with them.
MR. HULTQUIST: Okay, thank you. "What
periods of time can these tailings be exposed without
a water cover? Will a 1-meter water cover be
required at all times for these tails? Please
describe dusting and radon emission impacts that can
occur when the waste from processing these -- waste
from processing these wastes are not covered."
Again, the liquid levels in cells 4A and
4B, there's a certain level in which we can't exceed
for freeboard limits regarding storm events, et
cetera. So they're typically maintained at a level
of approximately 4.8 to 5.8 feet below the top of the
geomembrane liner in each cell.
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Now, right now, one's receiving liquids
and the other one's receiving tails, so -- and
they're very low down in the bottom of the cells, so
to speak. The groundwater discharge permit also
specifies a minimal freeboard of three feet, and so
there, at certain times, maybe later, the tails or
the beach areas might dry out. At that point, then
they need to apply water to them to keep those dusts
down. Again, part of their operating procedures are
to, if they see visible dust, then they need to go
apply applicants, either water or salt water type, to
form a crust on those tails. But we can't just cover
the whole thing in water, so to speak, or liquids,
because there has to be a freeboard there for storm
event calculations. We don't want to create a
greater mess than what could happen if we overflowed
the cells.
I think over the time, their Standard
Operating Procedures that they have in place, whether
it's this Dawn Mining material or alternate feeds or
other alternate feeds or Colorado strip or Arizona
materials, they're adequate. So unless Harold wants
to add any more to the SOPs and what you guys do out
there.
They do keep records of their dust
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suppression, their water use, whether it's on the
tails or whether it's in the ore storage pad area.
We review those during our inspections to see that
they are being applied. I don't -- I don't think the
staff looks at whether it's a high-wind day or not,
just that effort's being made to put water on those
areas.
MS. TAPP: Thank you.
MR. HULTQUIST: I'll turn it back over to
you. I think that's the end of the questions.
MR. ANDERSON: That concludes all of the
written questions that have been submitted. So if at
this point in the proceedings, again, we're
proceeding informally, if there are any other
questions or comments, I suppose they can be
submitted. If not, we'll move to close the hearing.
John?
MR. HULTQUIST: I just wanted to add one
thing. Sarah, do you know if the tribe is going to
attend the meeting next week down in Blanding? I'm
surprised they're not here, so I was just questioning
whether or not you knew what the status is with them.
MS. FIELDS: I don't know. I think, like
everybody, like many government agencies, they're --
they have --
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MR. HULTQUIST: They're shut down?
MS. FIELDS: No, they're not shut down,
but they have funding issues, so I really don't know.
There's a possibility -- I will attend. I know I've
tried to get other people out to attend, so I've made
some efforts to get -- to encourage people.
MR. HULTQUIST: Well, we've sent it to
them and we didn't hear a response, so I wasn't sure.
MS. FIELDS: Well, you might follow up
with them and --
MS. TAPP: They're aware of the --
MR. HULTQUIST: Of the meeting?
MS. TAPP: They're aware of the meeting.
I am unsure -- the shutdown has impacted them in odd
ways, and -- but I believe that you can expect
comments. And to be clear, I'm not speaking for the
tribe in any way, but they're aware of the meeting.
I don't know whether they're going to attend, but
they are --
MR. HULTQUIST: Okay. Or they might just
decide to provide written comments, which is fine. I
was just used to seeing them around the table, so I
was just wondering if something was -- something was
amiss.
MR. ANDERSON: John, just for the record,
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it may be worthwhile to repeat the time and the date
of the next meeting.
MR. HULTQUIST: Okay. The public meeting
will be held October 16th at 5:00 p.m. at the
Blanding Arts and Events Center, and we will be
taking written as well as oral comments. It will not
be a time for cross-examination. It will just be an
opportunity for local residents to take -- to make
oral comments or provide us with written comments if
they so desire.
MR. ANDERSON: And then written comments
will be accepted through the close of business
through October 21st; is that correct?
MR. HULTQUIST: That is correct.
MR. ANDERSON: I think that concludes our
business today, so with no further ado, I'll declare
the hearing closed.
MS. FIELDS: Thank you.
MS. TAPP: Thank you all for your time.
(The proceedings were concluded.)
* * *
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REPORTER'S CERTIFICATE
STATE OF UTAH )) ss.
COUNTY OF SALT LAKE )
I, Kathy H. Morgan, Registered Professional Reporter and Notary Public in and for
the State of Utah, do hereby certify:
That on October 22nd, 2013, I transcribed an electronic recording at the request of Shairose Falahati;
That the testimony of all speakers was
reported by me in stenotype and thereafter transcribed, and that a full, true, and correct
transcription of said testimony is set forth in the preceding pages, ACCORDING TO MY ABILITY TO HEAR AND
UNDERSTAND THE RECORDING PROVIDED;
That the original transcript was sealed and delivered to Shairose Falahati for safekeeping.
I further certify that I am not kin or
otherwise associated with any of the parties to said cause of action and that I am not interested in the outcome thereof.
WITNESS MY HAND AND OFFICIAL SEAL this
24th day of October, 2013.
_____________________________
Kathy H. Morgan, CSR, RPRNotary Public
Reporter's transcript of electronically recorded: P U B L I C H E A R I N G D I V I S I O N O F R A D I A T I O N C O N T R O L S T A T E O F U T A H Conference Room 1015195 North 1950 West.Salt Lake City, Utah October 9, 2013 - 2:00 p.m.
Sheet 1
2
1 October 9, 2013 - 2:00 p.m. - Salt Lake City, Utah
2
3 P R O C E E D I N G S
4
5 MR. ANDERSON: Welcome and good afternoon.
6 My name is Craig Anderson. I'll be the presiding
7 officer for the hearing this afternoon. This is the
8 time and the place scheduled for the informal public
9 hearing on Energy Fuels' application for an amendment
10 to its 11e(2) byproduct license UT1900479. As noted
11 in the public notice that has been posted on the
12 DRC's Web site and also published, this is the time
13 and the place to receive public comments and
14 questions.
15 At this point in the hearing I would open
16 the floor to anyone who'd like to make comments on
17 the proposed amended license, and then we'll move on
18 to the question part of the proceeding. So does
19 anybody have any comments they'd like to make at this
20 point.
21 Yes, Ms. Fields?
22 MS. FIELDS: I'm going to submit more --
23 some comments later, particularly after this
24 proceeding, and we still have a couple of weeks. My
25 name is Sarah Fields. I'm with Uranium Watch in
3
1 Moab, Utah, and I've had some interest in the White
2 Mesa Mill for a number of years. And I just want to
3 make a few procedural comments.
4 I think there was too little time between
5 the submittal of the questions and the hearing. And
6 just this morning I received a copy of the letter
7 which indicated to me that some -- some of my
8 questions were not relevant to the licensing action,
9 vague, or maybe they didn't all fit -- fit this,
10 these categories, but maybe were seeking legal
11 interpretations or were not specifically relevant to
12 the proceedings. So it would have been helpful to
13 have that before.
14 It would be also helpful to have known and
15 have had a little bit more information, because
16 questions that were very relevant to me, or
17 significant to me, have now been taken off the table
18 for this, for this hearing. And I have some
19 objections to that, but it will get us through some
20 of this more quickly, and there's still some relevant
21 things to go over.
22 One thing regarding making comments. I
23 noticed that some of the documents, as they were
24 posted on the DRC Web site, it was not possible to25 copy and then paste sections of the documents, or I
4
1 had difficulty with that. And when you're making
2 comment on a document, it's really handy to be able
3 to copy a section, paste it into your comments so you
4 can indicate that you're making a comment on the
5 section so that the staff, or whoever's reviewing the
6 comments, doesn't have to go back to the original
7 document, and they know precisely what you're
8 referring to. And it takes time to type that in, so
9 having a PDF that you can copy -- copy from and paste
10 in is really handy.
11 I think most of my comments would happen
12 after this, and hopefully some of my issues will
13 be -- I'll get some additional information to make
14 more informed comments. Thank you.
15 MS. LOCKHART: Can I just respond to that
16 a little bit? I know that this is a comment period,
17 but I wanted to -- it's not in that letter that you
18 received, Sarah, but we do plan on addressing some
19 things, notwithstanding the -- I guess you would call
20 them objections. So maybe the best thing to do on
21 some of those is to hold off until the end and see
22 what's left over for you.
23 And I would also agree that we learned
24 that ten days was not enough. That's why we wanted
25 to kind of experiment with this before we put it into
Division of Radiation Control Public Meeting * October 9, 2013
5
1 rules. So that's the first lesson today.
2 MS. FIELDS: Oh, okay, good.
3 MR. ANDERSON: Are there any other
4 comments? Well, I guess we can move on to the rest
5 of the agenda in the proceeding today. As a
6 preliminary matter, a 45-day public comment period
7 began on September 5th, 2013, and notice was
8 published on the DRC Web site, published in the Salt
9 Lake Tribune, Deseret News and the San Juan Record.
10 Copies of the amended license, proposed amended
11 license, Statement of Basis and Safety Evaluation
12 Report are also on the department's Web site and
13 available for inspection at the department's office.
14 In addition, written comments will be accepted until
15 the close of business on October 21st, 2013.
16 This hearing is undertaken for the purpose
17 of meeting the Nuclear Regulatory Commission's state
18 delegation requirements under 10 U.S. Code,
19 §2021(o)(3)(A), and the purpose of this informal
20 hearing is to receive comments and questions that
21 have previously been submitted in advance regarding
22 the application for the amended license. Staff from
23 the Division of Radiation Control, URS, the
24 Division's contractor, and representatives of the25 Applicant, Energy Fuels, are present and available
Sheet 2
6
1 today to answer any questions that you may submit.
2 The scope and comments on the questions
3 will be limited to the matters that are relevant to
4 the application for an amendment, and any comments or
5 questions and responses received this afternoon will
6 be included in the record for the amendment. There
7 has been a sign-in sheet that's been circulated
8 around. I guess I'm the last to sign it, so -- I
9 spoke too soon. So if you haven't already signed in,
10 please do so.
11 This hearing is being recorded and a
12 transcript will be made available at a time and date
13 after the hearing and will also be included in the
14 record for the amended permit. Are there any
15 questions before we begin?
16 MR. ZODY: Could I make just a brief --
17 MR. ANDERSON: Yes. Mr. Zody?
18 MR. ZODY: -- comment? This is Michael
19 Zody. I'm legal counsel for Energy Fuels. In
20 responding to some of the procedural issues, in terms
21 of the time frame, while ten days is -- is a somewhat
22 tight time frame, Energy Fuels is here, is prepared
23 to answer the questions. The questions have been
24 submitted as the Agency had requested. There's ample
25 time today to deal with the questions, and so we do
7
1 not feel there's any prejudice to anyone resulting
2 from the ten days, and we're prepared to go forward.
3 MR. ANDERSON: Thank you. Any other
4 comments before we begin? Hearing none, I will now
5 call the hearing to order and open the hearing to
6 receive questions.
7 MS. LOCKHART: Well, in fact we do have
8 the questions, and I think probably the procedure
9 should be just to start through Sarah's. This
10 isn't -- (inaudible) I'm sorry. Why don't you come
11 on forward. I guess we'll just turn it over to John
12 to begin answering questions. I think it's our hope
13 that we have something of a dialogue here of not just
14 reciting answers, but frankly, we're going to start
15 with reciting answers because that's what the
16 opportunity to review your questions presents for us.
17 MR. HULTQUIST: Thank you, Laura. My name
18 is John Hultquist. I'm the licensing manager within
19 the Division of Radiation Control for low-level waste
20 in uranium mills in the State of Utah.
21 And Sarah, I believe your first question
22 that was submitted as part of your packet was
23 regarding the application, and your question was:
24 "Are these materials 'ore,' as contemplated by the25 Atomic Energy Act of 1946, as subsequently amended by
8
1 the AEA of 1954, and the Uranium Mill Tailings
2 Radiation Control Act of 1978? If so, what is the
3 basis for the DRC's determination?"
4 Originally, when I looked back at the
5 licensing application for us to become an agreement
6 state, these same questions were asked by you to the
7 NRC. And so I'd like to refer you to Paul Lohaus,
8 who is the Director of the Office of State and Tribal
9 Programs, whose letter dated January 15th, 2004 to
10 you in response to those two questions -- would you
11 like to --
12 MS. FIELDS: Well, I don't have a copy of
13 that.
14 MR. HULTQUIST: Okay.
15 MS. FIELDS: That letter with me, so --
16 MR. HULTQUIST: Okay. Would you like me
17 to summarize it just briefly? Basically the NRC said
18 no, the AEA does not (inaudible) Uranium Mill
19 Tailings Radiation Control Act of '78, it was, and
20 that alternate feed is ore, and as any natural or
21 related material that may be mined and treated for
22 the extraction of its constituents or any other
23 matter for which source material is extracted, a
24 licensed uranium or thorium mill, is essentially what
25 it said. But I'll let you go back to that.
Division of Radiation Control Public Meeting * October 9, 2013
9
1 MS. FIELDS: So is that a regulation that
2 interprets the -- the Atomic Energy Act?
3 MR. HULTQUIST: You'll have to ask the
4 NRC.
5 MS. FIELDS: Okay, so you're relying
6 solely on the -- whatever the NRC's interpretation
7 is?
8 MS. LOCKHART: Sarah, I don't want to -- I
9 don't want to limit it to that. I wanted to give you
10 a preliminary response, but we will be treating your
11 questions as comments, and I think that they do fit
12 that.
13 MS. FIELDS: Okay, because I didn't think
14 you were going to respond to that.
15 MS. LOCKHART: I realize that.
16 MS. FIELDS: I mean, the first question I
17 have that you indicated you'd respond to would be
18 1.3, so maybe we can just go to the questions that --
19 MS. LOCKHART: And we can get to those
20 documents.
21 MS. FIELDS: After looking at your letter
22 today, I just went through the comments and kind of
23 indicated which ones you would not be responding to.
24 MS. LOCKHART: Today.25 MS. FIELDS: In this.
Sheet 3
10
1 MS. LOCKHART: We will be responding to
2 them.
3 MS. FIELDS: In this hearing. And so I
4 guess -- so we don't get it -- probably the best
5 thing would be to stick to that.
6 MS. LOCKHART: I think it best just to
7 concentrate on the ones that have factual matters
8 anyway, so let's go forward.
9 MR. HULTQUIST: Okay, so we've got to
10 push, yeah. Mr. Anderson, if I may just reiterate
11 for everyone to please always speak directly into the
12 microphone since we're recording this. And if you
13 want a transcript that doesn't have a lot of gaps in
14 it, please speak into the microphone so it's all
15 going to be heard on the recording.
16 MS. LOCKHART: I'd like to add to that
17 that you should say your name, too. My name is Laura
18 Lockhart, which I failed to do. I'm with the
19 Attorney General's Office representing DRC.
20 MR. LUNDBERG: And my name is Rusty
21 Lundberg, the Director of the Division of Radiation
22 Control.
23 MS. FIELDS: And my name is Sarah Fields
24 with Uranium Watch.
25 MR. HULTQUIST: Okay. So back to question
11
1 1.3. It is: "Why has Energy Fuel Resources submitted
2 an application for a license amendment to process
3 uranium material from the Midnite Uranium Mine?"
4 Simply, the alternate feed request must be
5 approved by the director in accordance with license
6 condition 10.1(c), which is in the radioactive
7 materials license.
8 MS. FIELDS: So although other ore this --
9 can be processed at the mill without a license
10 amendment, this ore needs a license amendment?
11 MR. HULTQUIST: Correct. Conventional
12 ores from mines do not require a license amendment.
13 And that covers two questions that you had previously
14 asked in this submittal document.
15 MS. FIELDS: Okay.
16 MR. HULTQUIST: But yes, all alternate
17 feeds require approval from the director. You'll
18 have to -- someone will have to help me as to which
19 one's next.
20 MS. FIELDS: Just a moment. I think
21 skipping through to 9, where I think the next
22 questions are that have to do with the alternate feed
23 amendment, I think the first question is at 9.1.
24 MR. HULTQUIST: Okay. I agree with you.25 9.1 is: "How does the DRC monitor the shipments of
12
1 alternate feed that are received at the White Mesa
2 Mill?"
3 Typically, that's done through our
4 inspectors, who go out to the site on a quarterly
5 basis. And if a shipment happens to be there at the
6 time they are there, they will often look at it, both
7 by visual observations of the shipment coming in and
8 then also the paperwork associated with that
9 shipment. In addition -- I'm sorry, go ahead.
10 MS. FIELDS: Oh. Do you look at all the
11 paperwork for all the shipments of alternate feed or
12 just maybe what happens to be coming in at the time
13 of an inspection?
14 MR. HULTQUIST: If the DRC staff are out
15 there and a shipment comes in, generally -- a number
16 of things, but generally they will look at the
17 paperwork associated with that shipment. Other
18 shipments that have arrived in between those
19 inspection times, they might review some point -- at
20 some point during the year when they go out and
21 conduct some other inspections, or if they're looking
22 at materials that arrive at the site in one of the
23 inspection modules.
24 Do they look at all of them? No. We
25 usually just look at a sampling of the paperwork for
Division of Radiation Control Public Meeting * October 9, 2013
13
1 a few of them. Does it hit all of the alternate
2 feeds or all the conventional ores? I'd probably
3 have to say I seriously doubt it, but we do a spot
4 check on just some of the shipments that come in, and
5 if things look okay, then we move on to other items
6 in the inspection. If there's questions, then that
7 gets asked of the licensee.
8 I believe the next question is 9.2: "How
9 does the DRC determine the amount of alternate feed
10 that is being or has been received at the White Mesa
11 Mill from any one source?"
12 And I'm going to say that for this
13 particular Dawn Mining amendment request, the
14 condition lists the amount that they will be able to
15 receive from this license amendment, and the DRC, at
16 future times, will inspect against that quantity. It
17 will be the licensee's responsibility to track the
18 amount that comes in their door as received and
19 processed. We will look at it at future dates during
20 the inspection process.
21 MS. FIELDS: But have you done that for
22 other -- is that a consistent program that you have,
23 that you know how much material has come from any one
24 alternate feed source over the years?25 MR. HULTQUIST: We have things we're
Sheet 4
14
1 working on with the licensee currently with the
2 renewal, the 2007 license renewal, is to actually get
3 a quantity for those alternate feeds that will remain
4 in the license after the license renewal application
5 has been reviewed and out to public comment, et
6 cetera, to put a quantity, or amount, in those
7 conditions that the NRC approved prior to us becoming
8 an agreement state.
9 The DRC feels it's important to know what
10 that quantity is, and we think it's the licensee's
11 responsibility to give us that information so we can
12 put it in the license.
13 Okay. Your next question, 9.3: "How does
14 the DRC determine whether the amount of material
15 received and processed at the mill from a specific
16 alternate feed source is less than or equal to the
17 amount of material that was approved for receipt and
18 process at the mill -- excuse me -- processing at the
19 mill from that source?"
20 Again, NCR was the holder of this license,
21 and I'm not sure if all the alternate feeds had a
22 quantity value associated with them. And I might
23 defer this to the licensee at this point, because
24 they were the ones that were dealing with these
25 previous license amendments with the NRC. But what
15
1 we do, at the end of the year we ask them how much
2 material has been processed. And they give us those
3 numbers, and that gets put out on the State of the
4 Environment Report that's on our Web page, and it
5 usually comes out towards the end of the year.
6 Now, I'd clarify that it doesn't talk
7 about any one source. It just talks about the amount
8 of alternate feed in total that was processed for
9 that year. So I don't know if Jo Ann or Harold or
10 somebody wants to comment on that as far as the
11 amount processed in quantities. We have those
12 numbers because of the license renewal and the
13 modeling that we're doing for the renewal process, so
14 that information's going to be available here soon.
15 MS. FIELDS: Okay.
16 MR. ROBERTS: I will go ahead and respond
17 to that. My name is Harold Roberts. I'm Executive
18 Vice-President and Chief Operating Officer of Energy
19 Fuels Resources. To the best of my knowledge, some
20 of the earlier alternate feed amendments issued by
21 the NRC during the early phases of the alternate feed
22 program did not have specific maximum quantities of
23 material assigned to those amendment requests.
24 The newer amendment requests that25 primarily had been authorized by the State of Utah,
16
1 when we submit the applications we do specify a
2 maximum quantity of material to be received and
3 processed under that license amendment. So there are
4 maximum quantities of material that are specified in
5 the newer alternate feed amendments.
6 MR. HULTQUIST: Okay, thank you.
7 MS. FIELDS: As a follow-up question, has
8 the DRC gone back and looked at the license
9 applications and the license amendments to determine
10 if there was a specific amount, whether tons, cubic
11 yards or drums -- because some of the material comes
12 in drums -- to see if there was a specific amount
13 that was approved? Because I know some of them
14 did -- some of the license applications or approvals
15 did specify a certain amount of material that would
16 be coming from a specific site, say Camco or Allied
17 Signal, I think, now Metropolis. I think there were
18 maybe some specific amounts identified. I just
19 wondered if you have looked through those license
20 applications and approvals -- which are part of the
21 licensee approval, the applications are part of the
22 source material license -- to see what was committed
23 to in the applications.
24 MR. HULTQUIST: That's correct, they are
25 part of the license, and some of it we will go back
Division of Radiation Control Public Meeting * October 9, 2013
17
1 and look. Some of if we're asking the licensee to
2 come up with those numbers and look themselves. Some
3 of them go pretty far back, and the records that we
4 were given from the NRC -- I'm not trying to make
5 excuses, but the records that were given to us were
6 not in very good shape. They're all by ML numbers.
7 They have no topical things. They're just on CDs.
8 And there's hundreds and hundreds of documents, and I
9 can't tell which one goes to Amendment 19, 17, 2, 3,
10 5 or 6.
11 And so in 2007, in this license renewal
12 amendment, we are asking them to give us those
13 quantities, and if we -- some of them are going away.
14 As you know, some of them they never received. They
15 finished with the project, so they're getting taken
16 off. So I don't feel it's necessary to go back and
17 find out what those quantities were. But the ones
18 that are staying on there, yes, we will know what
19 those quantities are.
20 MS. FIELDS: Right, and some of the
21 earlier documents, the pre-'99 documents, are --
22 yeah, they're paper copies in boxes. And some of
23 those boxes are right there in your office today,
24 so -- 25 MR. HULTQUIST: Yes. We had to go get
Sheet 5
18
1 them. Yes, we understand where they are.
2 MS. FIELDS: So I think maybe you'll be
3 able to identify some of those early applications,
4 particularly for the Camco and the Metropolis, to be
5 able to follow up on that. Thank you.
6 MR. HULTQUIST: Okay, the next question,
7 9.4: "How does the DRC determine that the material
8 received at the mill has the same physical and
9 chemical characteristics as the material that was
10 approved by the NRC or the DRC for receipt and
11 processing? What type of verification is required?
12 What kind of sampling of the material is required?"
13 Any material that's brought into that site
14 is subject to sampling, either by the DRC or at the
15 request of the DRC. If the samples are collected by
16 the DRC, we would be looking at basically a grab
17 sample from the material on the ore storage pad, and
18 then we would analyze that for radiologics, RCRA
19 constituents, metals and volatile organic compounds,
20 VOCs.
21 MS. FIELDS: So you don't require any type
22 of sampling?
23 MR. HULTQUIST: Well, the initial sampling
24 is done with the characterization of the amendment
25 request, as part of the amendment request.
19
1 MS. FIELDS: Well, when you have an
2 amendment request in the '90s, 20 years ago, and
3 you're receiving material right now, and perhaps
4 there were a number of different types of materials
5 that were approved, there -- a lot happens in
6 20 years at the facility. I'm specifically thinking
7 about the ore -- I guess it's pronounced Cameco, but
8 it's in Ontario, Canada. So it's possible that some
9 of that material would not necessarily be exactly the
10 type of waste that comes later --
11 MS. LOCKHART: Sarah --
12 MS. FIELDS: -- and I -- and I wonder, and
13 this, I guess, has to do with cumulative impacts and
14 how you approach the whole alternate feed program,
15 because it is really a regulatory program. It's an
16 NRC/DEQ program. And this, this new license
17 amendment, is just another aspect of that program, so
18 I'm trying to get an understanding, a better
19 understanding of the program.
20 And as I went over it, just questions I
21 should have asked a long time ago seem to pop up
22 about how -- how the verification works over the
23 years, because even this material they're going to
24 ship to the mill over a period of at least ten years.25 And maybe at the source end there might be different
20
1 processes, so you might end up with a little bit
2 different material, and you would need to have at
3 least sampling once a year or some kind of sampling
4 program to verify that changes haven't been made over
5 the years.
6 MS. LOCKHART: Are you talking about
7 alternate feeds other than the one that's being
8 proposed here?
9 MS. FIELDS: Well, I guess I was trying to
10 get at your -- the program that you have and how you
11 handle alternate feed, how you verify, how you sample
12 the physical and chemical characteristics over time,
13 because some of these approvals are over years. It's
14 not like you approve it and then within the next year
15 or two the material's been shipped, but it's over
16 time. I'm wondering how -- how you verify that the
17 material that was characterized and sampled
18 originally may -- may change over the years.
19 Sometimes you get waste, and okay, you
20 have a specific amount of waste from a specific site.
21 But sometimes the waste is continually being
22 generated, and that's what will be here with the --
23 with this Midnite Mine material. It's being
24 generated throughout, for the next maybe ten years.
25 And some of the other material is
Division of Radiation Control Public Meeting * October 9, 2013
21
1 continually being generated. It's not like it's a
2 cleanup of one site. You got your ponds, you got
3 this, you sample the material and that's it. But
4 some -- if you have a continual process of the waste
5 being generated, then you need a continual sampling
6 and verification program over time, you know. That's
7 what -- that's just -- I was trying to get at, you
8 know, what type of program, and you have given me
9 some information about that.
10 MR. LUNDBERG: If I may just add to that.
11 This is Rusty Lundberg. The standard actually is, in
12 terms of the waste management arena, is that if you
13 have an ongoing process that generates waste that's
14 consistent in that process, and you don't do anything
15 to adjust that waste generation process -- and this
16 carries over into the RCRA world as well -- is that
17 it's only if you go to change that waste generation
18 process, if you're doing something different, that
19 you would have relied upon that original
20 characterization to work from, that's when you're
21 required or it's more prudent to be able to go back
22 and reevaluate whether the waste characterization,
23 the makeup of the waste has changed enough that there
24 would be additional considerations that need to be25 made for its ultimate disposition.
Sheet 6
22
1 So it's actually more of the standard that
2 when you have ongoing waste generation, you rely upon
3 that original characterization and then look at any
4 changes that happen in that waste generation process.
5 And that's been a standard for 20, 30 years plus
6 here.
7 MS. FIELDS: Okay. Okay, thank you.
8 MR. HULTQUIST: The next question, 9.5, I
9 believe: "What information is received by the DRC
10 regarding (1) the amount of waste from the processing
11 of alternate feed from each source of material, and
12 (2) the physical and chemical characteristics of the
13 waste?"
14 Well, as you probably know, the license
15 application for alternate feeds contain the physical,
16 radiological and chemical characteristics of the
17 waste. We receive, on an annual basis, the amount of
18 conventional ore and alternate feeds that were
19 processed during the calendar year. So that takes
20 care of the amount of waste from processing of
21 alternate feeds.
22 This information, again, is provided to
23 the public in the State of the Environment Report put
24 out by this Agency under the Land section, so that's
25 where that information is.
23
1 MS. FIELDS: But you -- it's more of a
2 generic thing. The amount of waste is just a total
3 amount of waste -- I mean a total amount of waste, or
4 the total amount of alternate feed that's processed.
5 MR. HULTQUIST: Okay, maybe we should
6 clarify. When you say amount of waste from
7 processing, are you talking about the amount of
8 material that goes out to the tailing cells as waste
9 or as byproduct material?
10 MS. FIELDS: Yeah. Do you -- do you --
11 MR. HULTQUIST: No.
12 MS. FIELDS: You just look at the amount
13 of material that's being processed?
14 MR. HULTQUIST: That is processed, yes.
15 MS. FIELDS: And so more or less it's the
16 same amount going out to the tailings?
17 MR. HULTQUIST: Harold? Jo Ann?
18 MS. FIELDS: The amount of material that's
19 processed minus the amount of uranium plus the
20 processing fluids equals the tailings; right?
21 MR. HULTQUIST: Correct.
22 MS. FIELDS: That's kind of the --
23 MR. HULTQUIST: You've answered your
24 question. 25 MS. FIELDS: -- the general formula.
24
1 MR. HULTQUIST: Okay.
2 MS. FIELDS: But you don't keep track of
3 all the physical and chemical characteristics of the
4 waste that's being deposited?
5 MR. HULTQUIST: The byproduct material
6 that goes out to the tails, we do take samples as
7 part of the groundwater discharge permit on an annual
8 basis.
9 MS. FIELDS: Okay.
10 MR. HULTQUIST: Those slimes are
11 characterized for chemical constituents. I don't
12 think it does RADs. It does gross alpha. Thank you.
13 MS. FIELDS: Okay, thank you.
14 MR. HULTQUIST: Okay, 9.6: "Does the DRC
15 have data on the cumulative amount of radiological
16 and chemical constituents in the tailings as a result
17 of the disposal of wastes from the processing of
18 alternate feed? If so, where is this information?"
19 Yes. Again, I just mentioned it's in the
20 groundwater permit as required by part I.E.(10) of
21 the Tailings Cell Waste Water Quality Monitoring. On
22 an annual basis, the licensee collects samples and
23 those are provided to us.
24 MS. FIELDS: Thank you.
25 MR. HULTQUIST: That information is in our
Division of Radiation Control Public Meeting * October 9, 2013
25
1 office. 9.7: "Does the licensee keep track of where
2 the tailings from the processing of alternate feed
3 material are disposed of?"
4 As the licensing agent, I'm going to
5 generally say yes, they do. The licensee knows which
6 tailing cell is receiving tails. Therefore, when
7 processing material, the licensee knows which cell is
8 receiving the byproduct material.
9 MS. FIELDS: But not any specific part of
10 the cell?
11 MR. HULTQUIST: Jo Ann or Harold? Will
12 you -- I can't answer that, to be honest with you.
13 MR. ROBERTS: I'll respond to that. This
14 is Harold Roberts. It's almost impossible to tell
15 specifically in one of the active tailing cells to
16 where a specific alternate feed would be disposed of.
17 The tailings material goes out there normally in a
18 form of a slurry, part solution, part solids, and
19 that's discharged into the tailing cell. So there's
20 a high degree of mixing in the tailing cell when
21 those materials are discharged. So I guess the
22 answer is no, we can't tell specifically, exactly
23 where each alternate feed is disposed of.
24 MS. FIELDS: Thank you.25 MR. HULTQUIST: Okay. On to Section 10,
Sheet 7
26
1 which has to do with the Safety Evaluation Report, or
2 the SER. 10.1: "Does the DRC believe that the
3 required Environmental Analysis should be limited to
4 the four items listed in the SER? If so, why? If
5 not, what other Environmental Analysis should be
6 undertaken?"
7 The SER has considered and evaluated the
8 four items listed in 42 U.S.C.2021(o)(3)(C) in the
9 Environmental Impact Analysis, and considers these
10 items to constitute a sufficiently comprehensive
11 framework for evaluating potential environmental
12 impacts resulting from the proposed action. The DRC
13 believes the list of items to be consistent with all
14 available applicable NRC guidance State of Utah
15 requirements, applicable environmental impact
16 assessable protocols.
17 And notwithstanding those, the DRC
18 evaluation includes other additional items such as
19 the ability of the current mill operating and
20 radiological practices to safely accommodate the
21 temporary storage and processing of the alternate
22 feed material, disposal of the process residuals in
23 the design tailing cells without increasing potential
24 impacts to the environment and/or increasing
25 potential exposures to workers and the public. Also
27
1 assessing the need for implementing additional
2 protective measures, if any, to mitigate against such
3 potential increases -- increased environmental
4 impacts or exposures.
5 So yes, we consider those four as a
6 starting point, but that's just the starting point.
7 There might be other things we need to ask regarding
8 environmental impacts or releases that we would like
9 in addition to those four.
10 MS. FIELDS: Do you look at cumulative
11 impacts? Like, this is another alternate feed
12 material, so do you look at cumulative impacts of
13 disposal of alternate feeds like --
14 MR. HULTQUIST: Well, it would be -- in
15 part of the evaluation, when you're looking at that,
16 you're looking at what they've currently disposed of,
17 how are they compatible with what's in the tails, how
18 are they going to handle this, if it's any different
19 than what they would do with conventional ores or
20 other alternate feed materials.
21 If this particular material is identical
22 to, say, Colorado Plateau ore, then I would say that
23 they have practices, procedures in place that are
24 adequate for the protection of the environment and25 public health.
28
1 MS. FIELDS: But you're not looking at the
2 cumulative impacts, environmental impacts from the
3 processing and disposal of all the other alternate
4 feeds?
5 MR. HULTQUIST: Well, that's not in the
6 scope of this license amendment request, to go back
7 and look at all the other alternate feeds.
8 MS. FIELDS: Well, in a way it is, because
9 there are -- various statements were made in the
10 application. And I'd have to go back specifically
11 into the SER, but it said that this did not go beyond
12 the environmental impacts associated with the
13 processing of the other materials.
14 MR. HULTQUIST: Correct.
15 MS. FIELDS: But there's -- maybe this
16 goes in the comment, or maybe I have an additional
17 question about that, because the reality is, is that
18 most of the alternate feed did not undergo any kind
19 of Environmental Analysis. The vast majority of all
20 the alternate feed was not subject to an analysis of
21 the health, safety or environmental impacts
22 associated with that because the NRC didn't do an
23 analysis. So the cumulative impacts, I think, are
24 important, but you can't really do that -- I guess
25 this is more a comment, so...
Division of Radiation Control Public Meeting * October 9, 2013
29
1 MS. LOCKHART: Yeah, I think that's right,
2 and I think we need to reserve it for the comment
3 response document. But is there anything that Energy
4 Fuels would like to add on that, on cumulative
5 impacts generally? That's a repeated issue for
6 Ms. Fields. Not now, anyway.
7 MR. HULTQUIST: We're on Section 11 now,
8 or question 11. It still has to do with the Safety
9 Evaluation Report. 11.1 is: "Why does Table 1
10 provide the uranium concentration in milligrams per
11 kilogram and the other radionuclides in pico Curies
12 per gram?"
13 The concentration units are typically used
14 in the scientific community. Simple as that. When
15 an analysis is done for uranium, it's usually done in
16 a mass concentration. The other radionuclides are
17 typically done in an activity or concentration. So
18 that's the simple answer. Also, the results that the
19 licensee provided to us were in those units, so we
20 provided them as they were provided to us.
21 MS. FIELDS: I know in the letter from
22 Ms. Lockhart -- oh, oh, sorry -- for 11.2, they
23 didn't seem to -- the staff maybe didn't understand
24 my question, so maybe I could go over about what my25 question was about Table 1. And I guess I didn't
Sheet 8
30
1 frame my question very well.
2 MR. HULTQUIST: Go right ahead.
3 MS. FIELDS: Okay. So I don't -- I'm
4 looking at Table 1, which is the Range of
5 Radionuclide Concentrations for DMC Uranium Material,
6 2010 Analytical Results. So I see for -- the minimum
7 for thorium-242 is .66 pico Curies per gram, and then
8 for thorium-228 it's .93 pico Curies per gram. So
9 the thorium-228 is a little bit above that. And it's
10 my understanding that -- that they are, if it's an
11 equilibrium thorium, you can determine the
12 thorium-232 content by measuring thorium 228.
13 However, when you go to the maximum, the
14 maximum amount of thorium-232 is 21.4 pico Curies per
15 gram, but the thorium-228 is only 1.50. So that is
16 just way less than thorium-232, and it just seemed
17 like there was a discrepancy. It seems like the
18 thorium-228 should be equal to or greater, at the
19 maximum levels, than 232, because you go to the
20 minimum and it's a little bit above, but then you go
21 to the maximum and it's just way, way down at the
22 bottom. And I -- I -- it was hard for me to
23 understand that. It didn't make sense to me why the
24 minimum -- the maximum thorium-228 should be so low
25 as compared to 232. That was my question.
31
1 MR. HULTQUIST: Yeah. I think the number
2 on the -- at the table is incorrect, the 21.4 for the
3 232 for the max. We'll have to get back with you and
4 make sure what it is from the laboratory results.
5 MS. FIELDS: Oh, okay, because one or the
6 other is --
7 MR. HULTQUIST: It's probably -- my guess,
8 it's probably 2.1, but I need to be clear. Let me
9 go -- we need to go look at that. But looking at the
10 other ones in the other table, they're in much better
11 agreement. So I'm thinking that the 21.4 for the max
12 on the thorium-232 on that table is incorrect.
13 MS. FIELDS: Okay, thank you.
14 MR. HULTQUIST: If you have the SER with
15 you, there's a Table 2.
16 MS. FIELDS: Yeah.
17 MR. HULTQUIST: It also lists those
18 thorium isotopes, thorium-228, 230 and 232, and those
19 give you the lab results from those three treatment
20 plant samples. And you can see the one is 1. -- for
21 thorium-232, it's 1.14. The next one is .66, as
22 you've mentioned, and then the other one is .71. So
23 I don't think the average or the max can be 21.4, so
24 we'll correct that.25 Okay. Question 11.3: "Table 1 includes in
32
1 lead-210, the product of uranium-238 decay. Why does
2 Table 1 not include lead-208, the end of the thorium
3 chain?"
4 Lead-208 concentrations in the mine is not
5 considered because lead-208 is a stable isotope of
6 lead, and is therefore not appropriate for reporting
7 of this. We're not using this as thorium for -- it's
8 the uranium we're retrieving. And I believe the
9 analytical results for total lead are reported
10 elsewhere in the SER, I believe Table 11, which, if
11 it was stable lead, would report it as a metal, so
12 therefore referencing you to the other table.
13 Okay. 11.4: "Table 1 fails to include the
14 radon emissions from the uranium material. Why is
15 that?"
16 Information on the radon emissions from
17 the uranium material is not considered. The primary
18 radionuclides parents for radon generation,
19 assuming -- I'm assuming you're referring to
20 radon-222. There are several radon isotopes out
21 there, but I assume you mean radon -- when you say
22 radon, you're assuming radon-222 from the decay of
23 radium-226 in your question, and those are from
24 thorium-230 and radium-226.
25 Concentration of these radionuclide
Division of Radiation Control Public Meeting * October 9, 2013
33
1 parents in the material are within the range of
2 concentrations of the radionuclides in typical
3 Colorado Plateau ore. In other words, they're at the
4 same concentrations as what we would typically see in
5 Colorado ores if they were coming in.
6 For this reason, previous environmental
7 analyses take care of that issue regarding radon. We
8 would assume to see the same amount of radon being
9 generated from this material as we would Colorado
10 ores, which have already been analyzed in the
11 original EIS for this radioactive materials license.
12 MS. FIELDS: But you would have additional
13 radon emissions from the thorium-232.
14 MR. HULTQUIST: Which has -- radon-219 has
15 a 55-second half-life.
16 MS. FIELDS: Yeah. Yeah, I think it's
17 radon-220.
18 MR. HULTQUIST: 220, excuse me. So its
19 availability is very short. The impacts would be
20 minimal.
21 MS. FIELDS: Okay, thank you.
22 MR. HULTQUIST: 11.5: "Why does the SER
23 fail to identify the other radium isotopes that are
24 included in total uranium?"25 Again, the analytical testing of the four
Sheet 9
34
1 samples of filter press kick produced from the
2 dewatering filter press pilot testing conducted in
3 2011 included the analysis for the following
4 radionuclides: 226, radium-226, radium-228.
5 Analytical results reported in Table 6 of
6 the SER indicate that the radium concentrations in
7 the sample were low, ranging from .07 to .2 pics per
8 gram, and radium-228 concentrations were also low,
9 all reported concentrations below or less than .2
10 pico Curies per gram. And we've -- so those are
11 reported. They're very low concentrations. These,
12 again, are in typical ranges you would see in
13 Colorado Plateau's -- Plateau ores that have been
14 analyzed originally in the license. They're actually
15 lower than what we would see typically in Colorado
16 Plateau ores.
17 MS. FIELDS: Except that Colorado Plateau
18 ores don't contain thorium-232 in their progeny,
19 normally.
20 MR. HULTQUIST: They contain some.
21 MS. FIELDS: I haven't -- I don't think
22 that they contain any appreciable amounts of
23 thorium-232 in the progeny of thorium-232. They
24 contain 230, but that's because of the uranium.
25 MR. HULTQUIST: Right, but we're talking
35
1 about the radium-226 and 228.
2 MS. FIELDS: Yeah.
3 MR. HULTQUIST: Here in this question.
4 Those concentrations, the radium-228 concentration is
5 very, very low.
6 MS. FIELDS: So it's not included,
7 basically, because it's so low?
8 MR. HULTQUIST: Well, we've included them
9 in the report.
10 MS. FIELDS: Under total? Under total?
11 MR. HULTQUIST: Well, we gave you the
12 radium-226. I believe it's in the --
13 MS. FIELDS: So it would be included under
14 total radium?
15 MR. HULTQUIST: Yes.
16 MS. FIELDS: So you have 226 and then you
17 have total radium?
18 MR. HULTQUIST: Right. There's a
19 difference of about 10 or 15 pico Curies per gram
20 there.
21 MS. FIELDS: So the total would include --
22 but you didn't identify the other as -- when you go
23 total radium, you don't say that includes 226 to,
24 what, 228 and 224, I guess because that -- that25 information wasn't included in the application,
36
1 because you probably took most of this from the
2 application.
3 MR. HULTQUIST: John, would you like to
4 add anything?
5 MR. LLEWELLYN: What we included in the
6 Safety Evaluation Report was data submitted in the
7 license application. There were radium-228 results
8 reported from 2010 testing of the dewatered sludge
9 from the centrifuge system, and those are in this
10 response, 36 to 41 pico Curies per gram total radium,
11 and radium-226, 22.8 to 25.7 pico Curies per gram.
12 So that addresses total radium and radium-226, total
13 radium encompassing all, all radium isotopes.
14 MS. FIELDS: Yeah, I just -- for
15 someone -- a member of the public just looking at
16 that, they wouldn't know where the other radium came
17 from. Radium-226 you have identified, and then there
18 is an appreciable amount of radium from the other
19 material, because -- from the samples. So even
20 though there doesn't seem to be a lot of thorium-232,
21 the radium from that 232 is an appreciable part of
22 the total radium. But you -- it just seems like you
23 should throw that in. Well, that's a comment I can
24 make in my comments. Thank you.
25 MR. HULTQUIST: Okay. 11.6: "Has the DRC
Division of Radiation Control Public Meeting * October 9, 2013
37
1 evaluated and compared the radionuclides that will
2 remain in the uranium material and other alternate
3 feeds after processing?"
4 The concentration of 226, thorium-230,
5 thorium-228, thorium-232, are expected to be at the
6 same as those present in the material resulting from
7 the processing. Again, we're taking out the uranium,
8 so these materials will go to tails, so I would
9 expect them to be in approximately the same
10 concentrations when they arrive as when they go out
11 to the tails.
12 MS. FIELDS: Okay, thank you.
13 MR. HULTQUIST: Section 12, we're still on
14 the Safety Evaluation Report. We're talking about
15 Table 3: "Table 3 provides information regarding the
16 concentrations of total uranium, radium-226, and
17 thorium-230 in the uranium material versus average
18 acid leached ore-derived uranium mill tailings in
19 Utah."
20 Question 1 -- or excuse me -- 12.1: "Table
21 3 only considers radium-226 but does not include the
22 radium concentrations from the decay of thorium.
23 Shouldn't Table 3 also include the radium
24 concentrations from 228, radium-228, and radium-22425 and the total concentrations from all uranium
Sheet 10
38
1 isotopes in the comparison of the uranium material
2 and the typical Utah uranium mill tailings?"
3 And I'm going to refer you back to our
4 response to 11.5.
5 MS. FIELDS: Well, there is an appreciable
6 amount of radium coming from the thorium, but you
7 didn't compare that amount with -- I mean, this is in
8 the uranium material, and this Table 3 does not
9 compare that with the typical Utah uranium mill
10 tailings. So I just wondered why that wouldn't be,
11 because it does provide an appreciable amount of
12 radium going into the tailing impoundment.
13 MR. HULTQUIST: Can you help me out with
14 your question and what you mean by "typical Utah
15 uranium mill tailings"?
16 MS. FIELDS: Well, you've -- you've --
17 someone else has identified the typical Utah uranium
18 mill tailings with the thorium-230 uranium total,
19 uranium-2 -- oh, 2308, and radium-226. And I
20 wondered, well, why they didn't compare -- make the
21 comparison with 232 with -- and then with the radium,
22 because after all, there is a lot of radium coming
23 from that 232. If you have total radium for one of
24 the samples as 35.8 and the amount of radium from 226
25 at 22.8, you have, I guess, 13.
39
1 MR. HULTQUIST: Approximately 10 to 15
2 pico Curies per gram of radium-228.
3 MS. FIELDS: Per gram. But considering
4 that you have a smaller amount, maybe, of
5 thorium-228, I just wondered why you didn't compare
6 that with typical Utah uranium mill tailings.
7 MR. LLEWELLYN: John Llewellyn, URS. That
8 could be done. It certainly could be presented. The
9 radium -- the radium issuing from thorium-232,
10 it's -- the amounts and the activities would be
11 dictated by the activities of thorium 232. And in
12 Table 2 of the SER, thorium-232 levels are reported 1
13 to 1.14, maybe .7, pico Curies per gram. And I think
14 the best way to review those concentrations is by
15 comparing them to what you might find in thorium-232
16 in typical uranium ores. And that's addressed in the
17 next question.
18 MS. FIELDS: Okay, thank you.
19 MR. HULTQUIST: Okay, 12.2: "Table 3
20 contains a comparison between the uranium material
21 constituents in the average acid-leached ore-derived
22 uranium mill tailings in Utah. Why has the DRC not
23 included a comparison of the thorium-232 and
24 thorium-228 concentrations for the uranium materials25 and the average acid leach ore in Utah?"
40
1 Information from the NCRP 1993 document
2 indicates that thorium-232 concentrations in natural
3 uranium ores vary with geographic location and
4 typically range from approximately 8 to 80 becquerels
5 per kilogram. And to convert becquerels to
6 kilograms, we use a conversion factor of 0.027 pico
7 Curies per becquerel kilogram. So therefore, this
8 range is approximately equivalent to 0.2 to 2.2 pics
9 per gram of thorium-232 for typical uranium ores,
10 which is what we've shown in this material to
11 contain. It's sitting right around 1.4, I believe.
12 Since most uranium ores are considered to
13 be in equilibrium, secular equilibrium, uranium ores
14 would be expected to exhibit similar ranges of
15 thorium-228 concentrations. This range of
16 thorium-232 and 228 concentrations is comparable to
17 that reported for the DMC -- Dawn Mining Company --
18 uranium material. And that goes back to that Table 1
19 and Table 2 in the SER.
20 And our justification is that for --
21 regarding these concentrations, they've been
22 previously analyzed during other ores or the EIS that
23 was done in 1979 for the -- from the NRC with respect
24 to this facility. So we're saying that this material
25 is in the scope of something that was already
Division of Radiation Control Public Meeting * October 9, 2013
41
1 analyzed, or within the envelope of something -- of
2 an assessment that was already done. Therefore, it
3 doesn't have to be done again.
4 MS. FIELDS: Okay, thank you.
5 MR. HULTQUIST: We're on to Section 13.
6 Here we're referring to Table 5 of the SER: "Table 5
7 is a comparison of the radionuclide activity
8 concentrations in proposed uranium material in
9 previous alternate feeds. Table 5 summarizes the
10 concentrations of the uranium material as compared
11 with Colorado Plateau ores and alternate feed
12 material. Table 5 relies to a great extent on the
13 information in the W.R. Grace application. That
14 application was submitted to the NRC in April of
15 2000, over 13 years ago."
16 Question 13.1: "Has the DRC reviewed the
17 W.R. Grace application of April of 2000 and the
18 licensee amendment approval documents? If so, when
19 did the DRC review that application and approval
20 documents?"
21 And the answer is no, the DRC has not
22 reviewed the Grace application of April 2000.
23 The next question is 13.2: "Did the NRC
24 conduct an Environmental Analysis of the receipt,25 processing and disposal of W.R. Grace material?"
Sheet 11
42
1 The answer is yes, the NRC conducted an
2 Environmental Analysis, documented in the
3 December 20th, 2000 Technical Evaluation Report which
4 accompanied the license amendment 17. The Technical
5 Evaluation Report refers to the following
6 environmental and technical information submitted by,
7 at the time, International Uranium -- or IUSA during
8 this evaluation process. And there's five letters
9 here. April 12th, 2000, the W.R. Grace application
10 amendment request; April 24th, 2000, IUSA letter
11 transmitting -- help me out, who provided me this
12 information -- the RMRP?
13 UNIDENTIFIED SPEAKER: Radioactive
14 Material Profile Record.
15 MR. HULTQUIST: Profile Record, thank you.
16 April 26, 2000, the IUSA response letter regarding
17 thorium management and tailings; May 5th, 2000 IUSA
18 response letter regarding tailings capacity; and
19 last, December 18th, 2000 IUSA submittal of thorium
20 management Standard Operating Procedure receipt
21 through disposal.
22 MS. FIELDS: Maybe I didn't make clear
23 what I considered to be an Environmental Analysis. I
24 should have indicated Environmental Analysis under
25 the National Environmental Policy Act, which the NRC
43
1 is subject to. The NRC does Environmental Impact
2 Statements. I mean, there's an Environmental Impact
3 Statement for the White Mesa Mill, and then it does
4 environmental assessments for, sometimes, for the
5 license renewal and for some of the license
6 amendments.
7 So when I meant [sic] Environmental
8 Analysis, I didn't mean a technical analysis. It's
9 my understanding from the documentation that the NRC
10 did no environmental review and they -- it was
11 categorically excluded under 10 C.F.R.§51.22(c)(11),
12 and, in fact, most of the alternate feed material
13 license amendments were categorically excluded. That
14 means they did no environmental assessment.
15 MR. HULTQUIST: Okay.
16 MS. LOCKHART: Why don't you correct me if
17 I'm wrong, but I think what you're saying is -- well,
18 first, what John is saying, he identified the
19 analysis that we looked at, which, I think, is
20 probably the most important thing for the purposes of
21 this license amendment. With respect to what is
22 required under federal law, that's not something we
23 can get into today.
24 MS. FIELDS: Well, what is required -- I'm25 not arguing whether -- or stating whether it was
44
1 required or not. It's the question of whether it was
2 done or not. If they get -- if they give themselves
3 a categorical exclusion, that means they don't do an
4 Environmental Analysis. They don't do an EA. So
5 that means that they didn't do an Environmental
6 Analysis, so...
7 MR. HULTQUIST: Maybe to help with this
8 question in 13.2, let's just go to the next question.
9 MS. FIELDS: Yeah, okay.
10 MR. HULTQUIST: Because I think that's
11 really where the heart is -- you're out on this one,
12 is whether or not they received the material or not.
13 In my understanding, the licensee has not received
14 any W.R. Grace materials. So all of these questions
15 about what the NRC did is kind of moot, because
16 there's not any of that material at this facility.
17 So can we move on?
18 MS. FIELDS: But the licensee is -- and in
19 this table they're using that information as part of
20 the range of material that -- it is in the range of
21 Colorado Plateau ores and alternate feed rate of
22 material concentrations as if it is applicable to the
23 White Mesa Mill. And I question any reliance on that
24 information because I -- I don't -- the mill has not
25 received the material. It's never been -- so it's
Division of Radiation Control Public Meeting * October 9, 2013
45
1 not been processed. And since it's been 13 years, I
2 doubt if that material will ever come. It's probably
3 already been cleaned up and sent to another facility.
4 So I really question using -- how that
5 data is relevant to this license amendment. I think
6 if you're looking for a maximum average and maximum
7 amounts of various materials, whether it's radium,
8 thorium, lead, U-natural, that it should relate to
9 material that's actually been disposed of at the
10 mill, such as the Linde and the Heritage.
11 MS. LOCKHART: Are we moving from question
12 to comment here, Sarah?
13 MS. FIELDS: Well, yeah, that -- I mean --
14 MS. LOCKHART: I think we need to move
15 along.
16 MS. FIELDS: And that was why I asked
17 these questions, because I don't think it should be
18 in the -- it is a comment, yes.
19 MS. LOCKHART: I expect we'll be seeing
20 that again.
21 MS. FIELDS: Yeah, it goes to a comment.
22 True.
23 MS. LOCKHART: Let's go on to 13.4.
24 MR. HULTQUIST: Okay. Well, it's kind of25 the same question in regards to the 2007 license
Sheet 12
46
1 renewal application, condition 10.1 that talks about
2 the W.R. Grace materials being removed from the
3 license. So some of these questions might go away or
4 resolve your issue with us using W.R. Grace as an
5 analogy. It was still something that was approved by
6 the NRC, but I'm sure there's other ones that might
7 be more appropriate.
8 13.5: "Has the DRC reviewed the
9 applications and approvals for the license amendments
10 and license conditions associated with the processing
11 of alternate feeds? If so, which applications and
12 approvals has the DRC reviewed and when did these
13 reviews take place?"
14 As described in license condition 10.9,
15 the DRC reviewed and authorized the licensee to
16 receive and process source material from Ponds 2 and
17 3 of the FRMI-Muskogee facility located in Muskogee,
18 Oklahoma. And Sarah, you're well aware of that
19 because you provided comments regarding this. And
20 then in addition, the DRC is doing this Dawn Mining
21 amendment request. Those are the two that the DRC
22 has reviewed and processed. One has been approved.
23 One is currently under the public comment process.
24 MS. FIELDS: But I guess you've indicated
25 before that you haven't reviewed all the applications
47
1 and approvals for the NRC amendments?
2 MR. HULTQUIST: Is that what you were
3 asking here? Did we go back and review the NRC's
4 approval to alternate feeds material? The answer to
5 that would be no.
6 MS. FIELDS: Okay, thank you.
7 MR. HULTQUIST: And then the last one that
8 we're currently reviewing as well, which I'm sure
9 you're aware about, is the Sequoia Fuels Corporation
10 alternate feed request that's currently ongoing and
11 is under the review process. That information is on
12 the Denison -- or the DRC's Web page under IUC
13 Denison/Sequoia Fuels.
14 13.6: "What is the justification for
15 comparing the uranium material with materials that
16 have not, and may not, ever be processed at the
17 uranium mill -- at the White Mesa Mill?" Excuse me.
18 Whether or not the feed material was
19 received and processed, the Environmental Analysis
20 that takes place as part of approving these things is
21 what we're looking at. Are there things there that
22 need to be looked at, those additional requirements
23 or SOPs or things that may be outside that we need to
24 look at in addition to what -- those four items we25 talked about in an earlier response. And so whether
48
1 or not the material comes into the site and gets
2 processed is irrelevant to us. It's what was out
3 there, what's been approved, and are they analogous
4 to what they're asking for now or is it something
5 different? And if it's really out of the ballpark,
6 then are there things that we need to ask that
7 weren't asked from other ones?
8 Okay. This is kind of a catch-all for
9 Section 14. It's other questions regarding the SER,
10 and this is 14.1. "The SER, page 12, indicates the
11 thorium-232 specific activity. However, the total
12 thorium activity for the thorium decay chain is
13 usually the sum of the thorium-232 and thorium-228
14 activity. Why did the DRC not include the
15 thorium-228 activity?"
16 John, I'm going to put that one in your
17 court. It goes back to question 12.2.
18 MR. LLEWELLYN: John Llewellyn, URS. It's
19 the same content, the question, as 12.2. The 12.2
20 does give some context comparing thorium-232 levels
21 in typical uranium ores to this Dawn Mining material.
22 MR. HULTQUIST: And I believe, if I'm
23 right, doesn't the table have the thorium-228
24 activity? Table 3 does.
25 MS. FIELDS: Table 6 on page 12 does, and
Division of Radiation Control Public Meeting * October 9, 2013
49
1 it's just...
2 MR. LLEWELLYN: Table 2 of the SER
3 presents isotopic data for thorium-228, thorium-232
4 and thorium-230.
5 MR. HULTQUIST: So again, I think the
6 thorium-228 activity is included in the SER.
7 14.2: "What is the amount and activity of
8 alternate feed materials containing thorium-232 and
9 its decay products from the -- from material that
10 have actually been processed at White Mesa?"
11 The SER prepared to support the Dawn
12 Mining uranium material alternate feed license
13 amendment request evaluated and compared the ranges
14 of thorium-232 concentrations in the Dawn Mining
15 material in ores, uranium ores that have been
16 processed at the mine. So we looked at the Dawn
17 Mining uranium material and we looked at conventional
18 ores, and these concentration ranges are similar.
19 And therefore we would assume that the
20 evaluations for those, whether it be a technical
21 evaluation report, environmental assessment or other
22 documents prepared by the NRC, are adequate in the
23 envelope or in the scope of this amendment request.
24 The radionuclides, the constituents, the25 concentrations, the activities are very similar to
Sheet 13
50
1 conventional ores.
2 MS. FIELDS: So you did conclude that the
3 thorium-232, 238 activity was similar to conventional
4 ores at the Colorado Plateau?
5 MR. LLEWELLYN: John Llewellyn, USRA. I
6 assume you mean thorium-228?
7 MS. FIELDS: Yeah, I mean 232 plus 228.
8 MR. LLEWELLYN: 232, right.
9 MS. FIELDS: Because it's usually added
10 together as total thorium.
11 MR. LLEWELLYN: Right. Well, that's from
12 the thorium-232 decay chain, and those values in
13 Table 2 are, as John Hultquist stated, they are
14 comparable to the range of thorium-228, thorium-232
15 levels you would see in typical uranium ores.
16 MS. FIELDS: In typical Colorado Plateau
17 ores? Because you don't have that comparison in your
18 table.
19 MR. LLEWELLYN: Thorium-232 and
20 thorium-228 levels in ores will vary according to
21 geographic location, geology, type of deposit. But
22 typically, for the type of ores that we're
23 processing, stratabound uranium deposits are all
24 front deposits, and I would say even uranium Arizona
25 ores, these levels are expected to be comparable.
51
1 MR. HULTQUIST: We indicated back on
2 another answer that most of those ores have thorium
3 somewhere between .2 and 2.2, maybe 2.5 pico Curies
4 per gram for thoriums. And that's what these results
5 show as well, that it's right in the middle of that,
6 right around 1-and-a-half, 1.1, 1.2.
7 MS. FIELDS: Yeah, but when you -- but
8 when you compared, there was a comparison Table 3
9 between the uranium mill material and typical Utah
10 uranium mill tailings, you didn't give a comparison
11 of the thorium-232 or the total thorium. You just --
12 it's not part of what -- any comparison. There's no
13 -- I don't see any comparison in any of the tables.
14 And, I mean, my understanding is that
15 Colorado Plateau ore really doesn't have much
16 thorium-232. I mean, most of the thorium, the waste
17 produced that has come to the mill, has come from --
18 with thorium -- has come from New Jersey because of
19 the processing of monazite sands. And there were
20 issues before because of the discrepancy between high
21 thorium -- the content -- content waste 232 to 228 in
22 Colorado Plateau ores. So it would be nice to have a
23 table or better information, and actually, comparison
24 with the kinds of Plateau ores that were processed at25 the mill.
52
1 MR. HULTQUIST: Okay. 14.3: "Has the DRC
2 reviewed the White Mesa Mill Standard Operating
3 Procedures for high thorium content ore management?
4 Has DRC determined whether the uranium material will
5 trigger the use of this SOP? If not, why not?"
6 The high thorium content ore management
7 SOP is not relevant to this license amendment or
8 applicable to the Dawn Mining uranium material, since
9 the concentrations of uranium isotopes are well
10 within typical conventional ores.
11 14.4.
12 MS. FIELDS: Could I have a follow-up
13 question?
14 MR. HULTQUIST: Sure, go ahead.
15 MS. FIELDS: So is there a level of
16 thorium content that would trigger the use of the
17 SOPs for high thorium content ore management? Is
18 there a specific cutoff point? I mean have you --
19 MR. HULTQUIST: I'd have to refer to the
20 licensee because I don't have it memorized in my mind
21 as to what the SOP actually says.
22 MS. FIELDS: I mean, have you reviewed
23 those Standard Operating Procedures?
24 MR. HULTQUIST: Yes, we have seen them,
25 yes.
Division of Radiation Control Public Meeting * October 9, 2013
53
1 MS. FIELDS: So you know --
2 MR. HULTQUIST: You're asking me if
3 there's a specific trigger in the SOP. I don't
4 recall. I would have to pull the SOP and look.
5 MS. FIELDS: But you've determined that
6 that wouldn't be --
7 MR. HULTQUIST: It wouldn't be applicable
8 to this license amendment because of the thorium
9 concentrations in this material.
10 MS. FIELDS: Is low, that it wouldn't be
11 considered high-thorium content material?
12 MR. HULTQUIST: Yes.
13 MS. FIELDS: Do you know what high would
14 be?
15 MR. HULTQUIST: Well, if I'm looking at
16 these materials, and typically thorium concentrations
17 are around the 1 to 2 pico Curies per range, I'm not
18 going to consider that high.
19 MS. FIELDS: Okay, thank you.
20 MR. HULTQUIST: Question 14.4: "The SER,
21 page 12, states: "Demonstration that the uranium,
22 radium and thorium activity concentrations of the
23 uranium material are below the maximum range of
24 previously-approved conventional ores and alternate25 feed materials indicates that radon levels resulting
Sheet 14
54
1 from the processing of uranium material are expected
2 to be within the range for which the existing
3 approved controls and monitoring programs are
4 currently established and considered appropriate.
5 Did the DRC also evaluate the range of materials that
6 have actually been processed at the mill, not just
7 the previously-approved alternate feed?"
8 John? (Pause) I'm going to say again, the
9 concentrations that are provided in the application
10 from Dawn Mining are within the range of conventional
11 ores, whether it be Colorado or Arizona strip.
12 Therefore, any additional analysis regarding
13 alternate feeds aren't necessary.
14 MS. FIELDS: Thank you.
15 MR. HULTQUIST: 14.5: "The DRC refers to
16 approved conventional ores. Does the DRC approve
17 conventional ores for processing at the mill?"
18 No. That is, as stated in response to
19 question 1.2, the DRC does not approve conventional
20 ores. This statement was incorrect in the SER.
21 MS. FIELDS: Thank you.
22 MR. HULTQUIST: 14.6: "The UCA and the
23 Atomic Energy Act require the assessment of the
24 radiological impacts to the public health from the
25 processing of the uranium material. However, I am
55
1 unable to find such an assessment. There is no
2 discussion of -- of how exactly the processed
3 material will be regulated under the applicable
4 regulations, or now, exactly the radon and other
5 radionuclides will be controlled over the life and
6 long-term care of processed uranium material. There
7 is no discussion of the health risks from the radon
8 and other radionuclides associated with the
9 transportation, storage, loading, processing,
10 disposal, perpetual care of the uranium material and
11 its processing wastes.
12 "Where exactly in the SER does the DRC
13 assess the radiological impacts to the public health
14 from the transportation, storage, loading,
15 processing, disposal and perpetual care of the
16 uranium material and its processing wastes?"
17 Again, this material is very similar to
18 conventional ores. We relied partially on the fact
19 that the ranges are typical, are within the scope of
20 what this facility does. The original EIS back in
21 1979 provided them with the analysis, with the
22 environmental assessment of taking ores and
23 processing them. These are in the same ranges as
24 what you would -- that EIS would allow them to do.25 Therefore, those assessments have been made.
56
1 14.7, we're talking about the Safety
2 Evaluation Report. Excuse me. The safety evaluation
3 report at Table 7 provides information regarding
4 derived air concentrations from ores and selected
5 alternate feed. However, Table 7 does not explain
6 what exactly the numbers in the table actually
7 measure. Table 7 includes columns identified as UF4,
8 K4 [sic], regen material and calcined material, but
9 it does not indicate the source or nature of those
10 materials.
11 "Please explain what DAC means and what
12 the numbers in Table 7 measure."
13 In the R31315 definition, derived air
14 concentration, or DAC, means the concentration of a
15 given radionuclide in air, which, if breathed by the
16 referenced man for a working year of 2,000 hours
17 under conditions of light work, results in an intake
18 of one annual limit of intake (ALI). For purposes of
19 these rules, the condition of light work is an
20 inhalation rate of 1.2 cubic meters of air per hour
21 for 2,000 hours in a year.
22 So the DAC values in Table 7 are derived
23 limits intended to control chronic exposure and are
24 used in the analysis of airborne particulate
25 exposures to workers. Table 7 presents DAC values
Division of Radiation Control Public Meeting * October 9, 2013
57
1 for radionuclides developed for the uranium material
2 from Dawn Mining based on applicable regulations and
3 mill procedures and that take into account the
4 specific radionuclide makeup of the Dawn Mining
5 material. And the units in those DAC values are
6 micro-Curies per milliliter.
7 14.8: "What is the source and nature of
8 the UF4, K4 regen material and calcined material?
9 How much of each of these materials has been
10 processed at the mill?"
11 For UF4 material, the processing tons is
12 914. For the KF material, the total processed is
13 5,646. For the regen materials, total process is
14 535 tons, and the calcined material is 16,934 tons.
15 And that's from '99 to present. These materials, the
16 UF4 and the KF, are naturally uranium-bearing
17 material residuals from Cameco Corporation's Port
18 Hope facility. The regen material and calcined
19 material are naturally uranium-bearing residuals from
20 Comeco's Blind River conversion facility. The four
21 materials were approved by NRC for processing as
22 alternate feeds at the mill under amendment 9 to
23 source material license SUA1358. Do I need to repeat
24 any of those for you?25 MS. FIELDS: No, I think I --
Sheet 15
58
1 UNIDENTIFIED SPEAKER: It's in the
2 transcript.
3 MR. HULTQUIST: Yeah, but let her have
4 them if she needs them.
5 MS. FIELDS: Okay, thank you.
6 MR. HULTQUIST: All right. "Please
7 identify the dates of the applications, license
8 amendments and Environmental Analysis or analysis
9 associated with the processing and disposal of the
10 UF4, K4, regen materials and calcined materials."
11 IUSA submitted the license amendment
12 application on June 4th, 1998. The NRC conducted an
13 Environmental Analysis as documented in the
14 November 2nd, 1998 Technical Evaluation Report which
15 accompanied license amendment 9. The technical
16 evaluation report refers to the following
17 environmental technical information, and there's a
18 bunch of dates. Do you want them or can you get them
19 out of the transcript?
20 MS. FIELDS: Yeah, I think I can get that.
21 I think I already have -- yeah, I can get that.
22 MR. HULTQUIST: Okay.
23 MS. FIELDS: But as a point, a TER is not
24 an Environmental Analysis. An Environmental Analysis
25 would -- and I'm sorry I wasn't more specific,
59
1 because under the National Environmental Policy Act,
2 where you do an analysis of the environmental impacts
3 from the licensing action, and this also -- there was
4 no Environmental Analysis for that, either. A TER is
5 some -- they do -- the NRC often does a Technical
6 Evaluation Report and then they do their
7 Environmental Analysis, an EIS or an EA, or they do a
8 categorical exclusion. But a TER is not an
9 Environmental Analysis under NRC regulation.
10 MR. HULTQUIST: Okay, thank you. The only
11 other thing I would add is the NRC issued license
12 amendment 9 on November 2nd, 1998.
13 MS. FIELDS: Oh, yeah. I'm sorry, as I
14 went through that, I was not more specific.
15 MR. HULTQUIST: No, I think you were very
16 specific. You've asked for all of those details.
17 MS. FIELDS: Yeah, but as far as what
18 constitutes an Environmental Analysis under NRC
19 regulation, I was not specific. It's under their
20 part 51 regulation.
21 MS. LOCKHART: And you're going to be
22 providing information about why that is -- you
23 believe that's the case? Because I don't want our
24 silence to be interpreted as an agreement with that,25 that's all.
60
1 MS. FIELDS: Yeah, that -- that's true. I
2 mean, it's a question.
3 MS. LOCKHART: That's all we need.
4 UNIDENTIFIED SPEAKER: If I may, that's
5 what I was going to get to as well, to help us
6 clarify what -- if you're identifying gaps or
7 activities that were not conducted by NRC when they
8 had the regulatory jurisdiction, it would be nice to
9 know what kind of context you're expecting that for
10 carryover for us as an agreement state. I don't want
11 you to answer that now. We would need to look for
12 that kind of context for what you're bringing up.
13 MS. FIELDS: Right, and we're all learning
14 on this question-and-answer process as to how to
15 write better questions and how to give good answers.
16 So we're all -- this is our first, first experience
17 with this. It's my first experience, so I'm
18 learning, too.
19 MR. HULTQUIST: Okay. 14.9: "The SER,
20 page 14, states the concentrations of thorium-232 and
21 its decay products are negligible, and its decay
22 products are negligible and can be ignored. What are
23 the concentrations of thorium in decay products from
24 the uranium material and other feed materials
25 processed at the mill? Compare the half-lives and
Division of Radiation Control Public Meeting * October 9, 2013
61
1 health impacts of the -- excuse me -- compare the
2 half-lives and health impacts of the decay products
3 of uranium with those of thorium decay products.
4 What is the basis for discounting the health risks
5 from thorium-232 and its decay products?"
6 Again, I'm going to say these
7 concentrations of thorium-232 and their decay series
8 are in line with conventional ores. That analysis
9 was done in the EIS back in 1979, so it's already an
10 analyzed condition with what the material consists of
11 with this amendment requirement, or request.
12 MS. LOCKHART: Let me just say briefly, on
13 14.10, you'll remember that that's one of the ones
14 that we said was not relevant. But John,
15 nonetheless, has an answer for you.
16 MR. HULTQUIST: Yes, I still want to
17 answer this one, because I think, Sarah, you should
18 be able to answer this yourself. I don't mean to be
19 blunt, but if you've got a vehicle that has 200
20 millirem per hour at any one point on the outer
21 surface and you're right next to it, I'm assuming
22 that person is right next to it, you have to make
23 some assumptions that he, that that person, is right
24 up against that contact, and that actual shipping25 container has 200 MR on -- per hour, and that person
Sheet 16
62
1 would only have to be there half an hour.
2 But that will never happen. That 200
3 millirem is a standard. It's a limit. It doesn't
4 mean that's what's in the conveyance. All
5 radionuclides are -- shipments are going to have
6 different exposure rates. But if you want to take
7 the theoretical aspect of your question, then it
8 would be a half an hour that they would receive the
9 100 millirem if they were next to that, right next to
10 it in contact with the surface. If they were right
11 next to it and they were a distance away, then it's a
12 lower number than 100. Does that make sense?
13 MS. FIELDS: Yes, thank you.
14 MR. HULTQUIST: But again, it's a
15 transportation issue, and that's what DOT allows them
16 to have on contact at the surface.
17 MS. FIELDS: Right, thank you.
18 MR. HULTQUIST: And most licensees or
19 shippers don't even come close to that number,
20 because if DOT stops them and it exceeds, then they
21 get fined.
22 Okay, 14.11: "Were the White Mesa Mill
23 tailings cells 4A and 4B designed contemplating the
24 disposal and perpetual storage of wastes from the
25 processing of material other than natural ores? If
63
1 so, please identify the specific design elements in
2 cell 4A and 4B that were developed in anticipation of
3 the disposal of waste from the processing of
4 materials other than natural ores from the Colorado
5 Plateau."
6 Each amendment request submitted to the
7 DRC includes an analysis of the compatibility of the
8 proposed alternate feed with the tailing systems.
9 The analysis considers the currently known chemical
10 composition of the tailings, which we get from those
11 annual sampling events, which reflects the presence
12 of residuals from previously alternate feeds and
13 compares that composition to the proposed alternate
14 feed.
15 The design of the tailing cell is
16 compatible with the radiological and chemical
17 constituents of the uranium material from Dawn
18 Mining. The evaluation to date has not identified
19 any potential chemical reactions in the tailing
20 systems.
21 MS. FIELDS: Thank you.
22 MR. HULTQUIST: 14.12. "Please identify
23 and describe the specific design elements for the
24 construction of the cell 4 and 4B that would25 anticipate the disposal of radiological and chemical
64
1 constituents found in the uranium material."
2 I don't believe this is relevant to the --
3 to the amendment request. The design elements
4 anticipated have been selected based on constituents
5 and tailings waste fluids from the conventional mill
6 at the White Mesa Mill. We know what's going in
7 there, so those geomembranes, the liners, the leak
8 detection systems, they're all best-available
9 technology, state-of-the-art containment systems and
10 bankments.
11 "How long after closure of the cells 4A
12 and 4B will it take to move -- remove free-standing
13 liquids from the cells such that the liquids would no
14 longer provide a source of leakage from the tailings
15 impoundments into the surrounding soils and
16 groundwater?"
17 This question, I'm sorry, is outside the
18 scope of this amendment request. We don't know how
19 long those cells will -- the life will be, the
20 dewatering of them, et cetera. It's outside the
21 scope of this amendment request. They could fill up
22 in two years and we could have them dewatered in six.
23 They could take ten years to fill up. We don't know.
24 That's why it's not relevant to the amendment
25 request.
Division of Radiation Control Public Meeting * October 9, 2013
65
1 14.14: "Which radiological and chemical
2 constituents present in the uranium material have
3 been found in excess of groundwater standards in the
4 monitoring wells at the White Mesa Mill?"
5 Again, the mill's quarterly groundwater
6 monitoring reports are available on the DRC Web site,
7 and they contain a tabulation of every analyte in any
8 groundwater monitoring well that has exceeded its
9 respective groundwater concentration limit for that
10 monitoring period. Many of these analytes are found
11 in natural background water as well as in natural
12 ores and the uranium material. So I hope that
13 answers your question.
14 MS. FIELDS: Yeah, I'll --
15 MR. HULTQUIST: They're out there.
16 MS. FIELDS: So I guess there's probably a
17 number of them, I mean, because -- so it's just my --
18 my duty to take a look. Thank you.
19 MR. HULTQUIST: 14.15: "Has the DRC
20 reviewed the amount and nature of contaminates in the
21 previously-approved alternate feeds to determine
22 whether groundwater discharge would need to be
23 revised in order to detect the constituents in an
24 alternate feed that are not found in Colorado25 Plateau's ores?"
Sheet 17
66
1 Again, to me, this question is outside the
2 scope of this license amendment. However, to answer
3 your question, the answer is yes. The DRC, as part
4 of its review of Fansteel, was an example. That
5 material required the discharge permit to go out to
6 public comment because we added some things and made
7 some modifications to it. This one we do not have
8 to. They are all already analyzed, or a surrogate is
9 being analyzed, for the Dawn Mining material.
10 14.16: "Has the DRC determined the
11 chemical compatibility of the contaminates in the
12 previously-approved alternate feeds to determine the
13 types of chemical reactions that would occur in the
14 tailing cells as a result of disposing of the
15 contaminates in the tailings impoundment?"
16 Again, each amendment request submitted to
17 the DRC includes an analysis of the compatibility of
18 the proposed alternate feed materials, both the
19 chemical and radiological constituents in that feed
20 material and what's already in the tails. So we look
21 at that and we determine if there might be or could
22 be a reaction with the composition. Is it neutral?
23 Are they the same? Is there anything that's unusual
24 about them? And to date, we have not identified any
25 potential chemical reactions in the tailing cells.
67
1 14.17: "The SER states repeatedly that the
2 radiological and chemical constituents in the uranium
3 material are similar to ores in alternate feed
4 materials previously processed at the mill. However,
5 the SER often compares the constituents with those in
6 alternate" --
7 MS. FIELDS: "Feed."
8 MR. HULTQUIST: "Alternate feed" --
9 sorry --
10 MS. FIELDS: I left out a word.
11 MR. HULTQUIST: -- "alternate feed
12 approved for processing, but not necessarily
13 processed at the mill. Why does the SER not limit
14 its similarity analysis to feed materials that have
15 actually been processed?"
16 Again, for this alternate feed material,
17 the radiological chemical constituents are within the
18 previously-analyzed condition from the assessment
19 done in 1979, the EIS that was done in 1979 for
20 conventional ores.
21 14.18: "The SER refers to the Occupational
22 Safety and Health Administration regulations."
23 I'm just going to go on to the response.
24 The reference, though, in the SER is in error. It25 should be MSHA, the Mine Safety and Health
68
1 Administration. The mill is subject to the
2 regulation enforcement of the Mine Safety and Health
3 Administration as a result of a tri-party agreement
4 between USNRC, MSHA and OSHA. MSHA conducts
5 inspections at least semiannually at the mill. The
6 content and status of the -- excuse me -- the content
7 and status of all MSHA citations from the previous
8 licensed performance period have been provided to the
9 DRC, or formerly to the NRC, with each license
10 renewal application.
11 15. "The SER" -- can we just go to the
12 question?
13 MS. FIELDS: I guess.
14 MR. HULTQUIST: "Has the DRC taken into
15 consideration the fact that elevated levels of
16 radionuclides have been associated with the disposal
17 of wastes from the processing of alternate feed
18 materials in a White Mesa Mill tailings impoundment?"
19 And the DRC is aware of the U.S.
20 Geological Survey's published report of an assessment
21 of potential migration of radionuclides in trace
22 elements from the White Mesa Mill. We provided a
23 preliminary review of our findings and we shared them
24 with the public on July 9th, 2012. That meeting was
25 held in Blanding. Currently, our actions are being
Division of Radiation Control Public Meeting * October 9, 2013
69
1 taken. As part of the license renewal application,
2 some of those things will be incorporated into the
3 renewal, and those reviews and discussions are
4 ongoing with the licensee at this point.
5 MS. FIELDS: Just a little follow-up. I
6 think I -- one thing I was referring to was the
7 recent Subpart W July 2013 Monthly Radon Flux
8 Monitoring Report from cell 2 where they identified
9 an area where waste from the processing of alternate
10 feed material had been disposed of in cell 2, and
11 they identified that as an area of increased radon
12 emissions because cell 2 is releasing radon above the
13 regulatory standard because it's being dewatered, so
14 you don't have the waters attenuating the radon
15 releases within the cell at this time.
16 So this is the first that I've known of
17 any documentation or example or -- of an area in a
18 tailings cell where the wastes from alternate feed
19 was producing elevated levels of radon emissions as
20 compared to other parts of the tailings impoundment.
21 And this is something Energy Fuels has found.
22 And what that means to me is that this
23 alternate feed that was disposed of, I mean the
24 tailings, had radon -- radium and other radionuclides25 above the level of ordinary tailings from Colorado
Sheet 18
70
1 Plateau ores. And I think a copy of -- I submitted a
2 copy with my questions.
3 MR. HULTQUIST: Yes, did you.
4 MS. FIELDS: So I think that that is an
5 issue with any processing with any material, any
6 alternate feed application, including this, that
7 sometime down the line the waste might be a source of
8 increased radon emissions that would result in
9 noncompliance. And this is the situation now. So
10 there's obviously some difference between the
11 radionuclides disposed of from this alternate feed
12 and the radionuclides from the tailings from Colorado
13 Plateau ore. And this is really a new issue that's
14 come up because of the dewatering.
15 MR. HULTQUIST: Well, Sarah, could I ask
16 you a further question about your statement there?
17 Do you know for a fact that alternate feed materials
18 that were processed and the tails that went out from
19 that alternate feed are actually sitting within the
20 top four or five feet of cell 2?
21 MS. FIELDS: I don't know. I'm just
22 basing this --
23 MR. HULTQUIST: Well, you're making an
24 accusation that --
25 MS. FIELDS: -- on statements -- no. This
71
1 is what -- this is what Energy Fuels found, and it's
2 the statements -- the statement is in their -- their
3 document. I -- I didn't make this statement. I
4 didn't go out -- I can't go out there and measure
5 anything. I don't know the history of each. But
6 they found elevated levels in that area. They found
7 elevated levels where the slurry line was.
8 MR. HULTQUIST: Right, I understand. I'm
9 just saying that conventional ores with the radium
10 concentration can still produce a radon flux that is
11 greater than the 20 pico Curies per meter per second
12 that's required by Subpart W, so --
13 MS. FIELDS: Right, I'm aware --
14 MR. HULTQUIST: -- so the action that the
15 licensee has to take --
16 MS. FIELDS: -- aware that --
17 MR. HULTQUIST: -- is to meet that
18 compliance limit. Dawn Mining materials will not be
19 going in cell 2 because it is closed. So that
20 particular question regarding cell 2 and Subpart W
21 and the radon flux coming off there is not relevant
22 to this license amendment, because those tails are
23 going to go into either 4B or 4A or some other cell
24 down the road. And radium coming from conventional25 ores can still create a flux that is greater than
72
1 what alternate feeds do. It depends on how it's
2 handled, how much water is in the system, how close
3 it is to the surface and how much cover they have.
4 So I would just like to say that because
5 it's in cell 2 and that cell has an interim cover on
6 it and it's being closed and dewatered, that is not
7 relevant to this license application where this
8 material is going to be processed and put in other
9 tailing cells.
10 MS. FIELDS: Well, you may --
11 MR. HULTQUIST: And I hope the licensee
12 gets those concentrations down.
13 MS. FIELDS: -- you answered my question.
14 I asked you if you take that into consideration, and
15 I guess you have considered that. Thank you.
16 MR. HULTQUIST: Which one are we on? I'm
17 sorry.
18 UNIDENTIFIED SPEAKER: 15.2.
19 MS. FIELDS: 5.2, sorry.
20 MR. HULTQUIST: "Has the DRC taken into
21 consideration -- taken into consideration the fact of
22 the disposal of materials from the tailings
23 impoundments by wind and other natural forces?"
24 Yes. The SER considers factors that --
25 the dispersal of materials from tailings
Division of Radiation Control Public Meeting * October 9, 2013
73
1 impoundments. The facility has BAT operations
2 monitoring and maintenance plans that are approved to
3 keep the dust from being generated coming off the
4 tails. They use best-available technology standards
5 in their groundwater discharge permit. They're
6 inspected on a daily basis. If there's -- if there's
7 dispersal materials coming off there, there are
8 certain requirements that they're to do out of their
9 SOPs to water them down, put applicant water or salt
10 agents, what have you, to minimize the amount of dust
11 leaving the tailing cells. They need to do that on
12 their ore storage pad as well.
13 MS. FIELDS: Thank you.
14 MR. HULTQUIST: So we feel that their
15 current SOPs and their operation plans cover the
16 release of materials both from the ore pad and the
17 tailings cells.
18 "What are the radiological constituents
19 that will be disposed of in the tailings impoundment
20 from the processing of the uranium material that are
21 different from the radiological constituents that
22 would be disposed of from the processing of Colorado
23 Plateau's ore at the mill" -- excuse me -- "Colorado
24 ores at the mill?"25 None.
Sheet 19
74
1 MS. FIELDS: Thank you.
2 MR. HULTQUIST: "Do the EIS and
3 Environmental Assessment (EA) for the White Mesa Mill
4 operation evaluate the health, safety and
5 environmental impacts from the receipt, storage,
6 processing, disposal and long-term storage related to
7 the processing of alternate feed materials? If so,
8 please identify the documents and sections that
9 contain such evaluation."
10 I think we've kind of kicked this one down
11 a couple of times, but again, the license renewal
12 application of 1991 contemplates the alternate feed
13 material being processed at the mill, and so does the
14 application of 2007. The NRC alternate feed guidance
15 and the mill's radioactive material license
16 anticipate the potential for processing of alternate
17 feeds in conventional uranium mills specifically by
18 requiring the submission of a license amendment
19 containing an environmental report for the use in an
20 Environmental Analysis specific to each proposed
21 alternate feed. In other words, they have to come in
22 and get a license approved -- license amendment
23 approved from the director.
24 15.5: "Has the DRC conducted an evaluation
25 of the cumulative impacts of the receipt, storage,
75
1 processing, disposal and long-term storage related to
2 the processing of alternate feed materials at the
3 White Mesa Mill?"
4 Cumulative impacts are evaluated during
5 inspections and sampling over the course of time by
6 way of the licensee's environmental monitoring plan
7 and the groundwater discharge permit.
8 MS. FIELDS: Thank you.
9 MR. HULTQUIST: Believe it or not, folks,
10 we're almost done with her questions.
11 MS. FIELDS: Last question.
12 MR. HULTQUIST: 16.1: "Does the DMC" --
13 Dawn Mining Corp -- "have a general or a specific
14 license to transfer the uranium material from the
15 Midnite Mine to the White Mesa Mill?"
16 I'm going to let Energy Fuels respond to
17 this one because I think I've done enough talking for
18 the last hour or so. So if one of you wouldn't mind
19 taking that.
20 MR. FRIEDLAND: David Friedland, Senior VP
21 and general counsel at Energy Fuels. The answer is
22 Dawn Mining has all the approvals required to
23 transfer the materials. The Midnite Mine site is
24 regulated under CERCLA management under EEP25 jurisdiction at this point, and no specific licenses
76
1 are needed for -- in addition to that regulatory
2 authority in order to transfer the materials from
3 that site to the White Mesa Mill.
4 MS. FIELDS: I have a question. Is that
5 an opinion of the EPA in Washington? I mean, has the
6 EPA --
7 MS. LOCKHART: This is -- this is a legal
8 question, but let's go with it. If you'll take a
9 look at CERCLA §121(e), you'll see that there's an
10 exemption from having to obtain any federal permits
11 or licenses for CERCLA activities that are conducted
12 on site.
13 MS. FIELDS: Because I did call the EPA
14 and they said they didn't know and they would look
15 into it.
16 MS. LOCKHART: I'm sure somebody in EPA
17 knows.
18 MS. FIELDS: Okay.
19 MR. LUNDBERG: Sarah, this is --
20 MS. FIELDS: So I just wondered if you'd
21 really looked into that and talked to the EPA or --
22 or the State of Washington.
23 MS. LOCKHART: My request to you would be
24 that you provide, in your comments, some context that
25 shows how that is an enforcement issue that we should
Division of Radiation Control Public Meeting * October 9, 2013
77
1 be managing. I don't see that it is, so let's do it
2 in that context.
3 MS. FIELDS: Okay, yeah, I'll do further.
4 Thank you very much for your patience.
5 MR. LUNDBERG: Just if I -- this is Rusty
6 Lundberg. Before you finish, just to clarify that
7 last point, when you said you talked to EPA, are you
8 talking EPA Region 10 --
9 MS. FIELDS: Yes.
10 MR. LUNDBERG: -- out of Seattle that has
11 jurisdiction over the State of Washington?
12 MS. FIELDS: Right, right. Not Region 8,
13 Region 10, yeah.
14 MR. LUNDBERG: But I wanted to make sure
15 you weren't referring to the Department of Ecology,
16 making them the EPA in Washington. You're talking
17 about U.S. Environmental Protection Agency?
18 MS. FIELDS: EPA Region 10, yes.
19 MR. LUNDBERG: Okay, thank you.
20 UNIDENTIFIED SPEAKER: Do people want a
21 break?
22 MR. HULTQUIST: Maybe we can -- next, in
23 terms of order of proceedings, would be the questions
24 from Grand Canyon Trust. So how do you wish to25 proceed? Would you like to go ahead or do you want
Sheet 20
78
1 to take a break before you start?
2 MS. TAPP: This is Anne Mariah. Either
3 way is fine. I don't anticipate that these will take
4 a long time.
5 MR. HULTQUIST: Do you have a preference,
6 staff?
7 UNIDENTIFIED SPEAKER: Let's go.
8 MR. HULTQUIST: Okay, we're going to go
9 ahead. So Anne Mariah, do you want to introduce
10 yourself and proceed?
11 MS. TAPP: Yeah. I'm Anne Mariah Tapp.
12 I'm an attorney for the Grand Canyon Trust, and
13 again, I apologize for being late. My computer
14 managed to die earlier today, and I've been trying to
15 deal with that, so my apologies for that. But I am
16 prepared to go ahead. It seems like several of the
17 questions got folded into --
18 MS. LOCKHART: I think there's going to be
19 a lot of similarities.
20 MR. HULTQUIST: Yeah, so --
21 MS. LOCKHART: You're pointing to that
22 letter?
23 MS. TAPP: To this letter.
24 MS. LOCKHART: Really, only one?
25 MS. TAPP: One, okay, perfect.
79
1 MS. LOCKHART: I remember three.
2 MS. TAPP: Great, yeah, so we can just
3 proceed with you all's response to those.
4 MR. HULTQUIST: Okay. Question number 1
5 is: "What testing did the Utah Division of Radiation
6 Control perform evaluating the compatibility of the
7 liners of cells 4A and 4B with the alternate feed
8 material proposed to be accepted from the Midnite
9 Mine site? What were the results of that testing?"
10 The -- I guess initially the answer to
11 that general question is no, there was no specific
12 testing to the materials. However, these materials,
13 the radiums, the radiologic constituents, the
14 chemical constituents, are very similar to what you
15 would see in what byproduct material goes out to
16 these tails.
17 So cell 4 and cell 4B were -- went through
18 our process with the DRC, and they were constructed
19 of 60-mill high-density polyethylene HDPE flexible
20 geomembrane. Both cells include a double 60-mill
21 HDPE membrane with a leak detection system. These
22 liner systems are designed and consistent with BAT --
23 best available technology -- design criteria for
24 waste containment facility liner systems.25 In other words, when we spec these systems
80
1 out, they're supposed to contain these types of
2 materials. That's why they build them. Specific
3 testing, though, again, regarding the chemical
4 compatibility with the specific uranium material was
5 not done on these liners.
6 MS. TAPP: Okay, thank you.
7 MR. HULTQUIST: And I have some more
8 specifics here about that HDPE, so I don't know if
9 it's really necessary to go into them.
10 Number 2: "What testing will be undertaken
11 to determine whether the groundwater protection
12 standards for barium contained in 10C FAR, Part 40,
13 Appendix A, criterion 5(c) are being met at the
14 mill?"
15 Currently, no analysis of groundwater
16 samples for barium will be performed. The existing
17 groundwater monitoring program conducted at the mill
18 site is deemed adequate for monitoring the potential
19 impacts of groundwater resulting from the disposal of
20 residuals resulting from processing of the Dawn
21 Mining uranium material.
22 MS. TAPP: To clarify, can I --
23 MR. HULTQUIST: Uh-huh.
24 MS. LOCKHART: He was going to add
25 something. Isn't there -- I mean, there's something
Division of Radiation Control Public Meeting * October 9, 2013
81
1 that stands in the place of barium, essentially.
2 MR. HULTQUIST: Yes. I'm going to get on
3 to the issue about barium and the salt that it --
4 that's created in the solutions. But if you want to
5 go ahead and ask your question.
6 MS. TAPP: Sorry.
7 MR. HULTQUIST: Also, as described in the
8 SER, the DMC uranium material barium is present as
9 barium sulfate. The solubility of barium sulfate is
10 cold water -- excuse me -- in cold water is .022
11 milligrams per liter, and in concentrated, sulfuric
12 acid is .025 milligrams per liter. Once in the mill
13 circuit, barium sulfate would remain as barium
14 sulfate due to its low -- very low solubility in
15 concentrated sulfuric acid.
16 At the listed concentration of sulfide in
17 the tailing solutions, 67,600 milligrams to
18 87,100 milligrams in cell 4A, a change in the ambient
19 barium concentration in the tailings solutions to .02
20 milligrams per liter due to the placement of this
21 uranium material would be expected to be very, very
22 negligible.
23 Would that suffice, or would you like some
24 more? 25 MS. TAPP: No, I think -- just out of --
Sheet 21
82
1 this is kind of a practical question. Just out of
2 curiosity, what would the burden on you all be to
3 institute some kind of barium monitoring? Just what
4 would that look like in terms of --
5 MS. LOCKHART: The difficulty that we'd
6 have, according to what John just said, is that we
7 would have to have a basis for that, and so -- for
8 requiring them to do that. And if there is
9 essentially zero expectation that it would end up in
10 the groundwater, it would be pretty tough for us to
11 justify that. And I'm saying that as an "if," so if
12 you --
13 MR. HULTQUIST: Maybe, more specifically
14 to get to your concerns, there's other surrogates or
15 there are other analytes that we monitor for that's
16 going to be out in front with the leak than barium,
17 so it's the last of our worries. There's other
18 things that we have in place that we can see long
19 before barium would ever get there.
20 MS. TAPP: Okay.
21 MR. HULTQUIST: So we feel those are
22 adequate to protect the health and safety and the
23 environment.
24 MS. TAPP: And that appendix A, criterion
25 5 does impose a groundwater standard; correct?
83
1 MR. HULTQUIST: Uh-huh.
2 MS. TAPP: But I'm just, again, just
3 clarifying for myself, but there is no --
4 MR. HULTQUIST: Right, but we did not
5 include -- we did not include that table or all of
6 those analytes in the groundwater discharge permit
7 because that's a federal regulation and we have our
8 state groundwater quality rules.
9 MS. TAPP: Right. Okay, thank you.
10 MR. HULTQUIST: I don't have 4. I thought
11 we were --
12 MS. LOCKHART: You thought that was that?
13 MS. TAPP: Oh, it's not that many left.
14 MR. HULTQUIST: Sorry, I don't know why
15 it's not there. Okay, 4: "What regulatory action has
16 been taken to address and eliminate the off-site
17 deposition identified in the USGS report dated
18 February 8th, 2007?"
19 Again, practical steps. We're working
20 with the licensee in the 2007 renewal application to
21 implement some of those things, to revise them from
22 our monitoring plan, a couple of additional air
23 stations and things, and we're working with them to
24 take care of those things. Our findings are out on25 the Web, and you can see what we've decided to
84
1 include and some things we said well, we're not real
2 sure about those. But there are some things that we
3 can do with -- in the renewal that address the
4 off-site migration.
5 MS. TAPP: Right, and the timing of the
6 implementation of those steps is?
7 MR. HULTQUIST: Whenever we can get that
8 SER done and the mill dose run done, and get the
9 draft back to them, the addendum that should come
10 out. I'm hoping by the end of this year we should
11 have something out to the public and the draft
12 license showing those changes and whatnot.
13 MS. TAPP: Okay, thank you.
14 MR. HULTQUIST: But if you want to see
15 what the DRC looked at as far as that USGS report,
16 that's on our Web page.
17 "How would the chalk-like composition of
18 Midnite Mine material" -- or excuse me -- "Midnite
19 Mine alternate feed materials exasperate the outside
20 deposition problems identified in the USGS report?"
21 Again, the stuff going into the tails we
22 feel the licensee has a handle on. One of the things
23 we put in this new license condition 10.20 is that
24 they cover this material when it's on the ore storage
25 pad. If it's going to sit out there for anything
Division of Radiation Control Public Meeting * October 9, 2013
85
1 longer than seven days, I believe is what the
2 language says, that they will put a cover over it,
3 because we realize this stuff is brick-like, and if
4 it does decompose, it's going to be a very fine,
5 light material. It's not going to be big chunks of
6 ore typically sitting on the pad. So we've added
7 that condition that they cover it.
8 MS. TAPP: And our concern is the
9 seven-day -- I had 21 days in my head, but seven-day
10 window doesn't adequately account for high winds that
11 could occur in that seven-day period. So we're
12 concerned about the adequacy of that in terms of
13 protecting downwind communities and the environment
14 from the impacts of that dust. So just to put that
15 out there.
16 MR. HULTQUIST: Okay, point well taken. I
17 know the Standard Operating Procedures for them is to
18 water that material down. They have a water truck
19 that goes around the ore storage pads, so if there's
20 high winds, then they need to get their water truck
21 out and get that moisture content out to minimize the
22 dispersion.
23 MS. TAPP: Right, and I think that the
24 language in some of the conditions in the air quality25 permit, again, if I recollect correctly, are a little
Sheet 22
86
1 bit loose in terms of "as deemed necessary," "as
2 appropriate." And a little bit we're just also
3 concerned about the ability -- about the practical
4 enforceability of those types of language in the
5 permit.
6 MR. HULTQUIST: Okay.
7 MS. LOCKHART: Did you say air quality
8 permit?
9 MR. HULTQUIST: Yes.
10 MS. TAPP: Right, I understand that we're
11 not in here for --
12 MS. LOCKHART: No, I just wanted to
13 understand.
14 MR. HULTQUIST: I'm going to put that on
15 the licensee. Do you want to talk about your
16 practical operations out there and what you see when
17 winds kick up?
18 MR. ROBERTS: Yeah. This is Harold
19 Roberts again. Let me address specifically the Dawn
20 Mining material. You know, we've got a requirement,
21 once it is on the ore pad for a certain number of
22 days, to cover that material. And initially, the
23 material, when it's received on site, will have a
24 very high or relatively high moisture content. So
25 the possibility of any windblown material coming off
87
1 of that until it dries out is very, very remote.
2 So the time period given before we need to
3 cover the material will, you know, we feel, be
4 adequate to ensure that the material is still
5 relatively high moisture content, and thus not be
6 susceptible to windblown material leaving the ore
7 pad.
8 MR. HULTQUIST: I can't remember, did we
9 have seven days or 14 days?
10 MR. ROBERTS: 14.
11 MR. HULTQUIST: 14, okay.
12 MS. TAPP: We're splitting the difference
13 there, 7 and 21.
14 MR. HULTQUIST: Well, for some reason when
15 I said 7, I thought that's not right. We agreed on
16 something else, I think. And again, I think the
17 Agency's being proactive here. They've never been
18 asked to put a cover on there, and I think there's
19 some justification to say they shouldn't have to.
20 But it can sit out there for a fair amount of time,
21 and this material is not in big chunks.
22 It can -- when it's dumped, it could break
23 apart and become fines and then be transported. So
24 we're sensitive to that issue, and that's why we25 thought 14 was reasonable. If winds pick up before
88
1 then, then they should be applying water on it, get
2 that moisture content back up to minimize the
3 dispersion. Or they can just cover it before then if
4 they want, if they know they're not going to process
5 it. But we'd like to give them some flexibility as
6 well.
7 MS. TAPP: Right, and just given that this
8 isn't normal dust, it isn't road dust, we feel that
9 there should be more stringent controls and that
10 perhaps more than -- or less than a 14-day window is
11 justified, given the content of the alternate feed
12 material and the high-uranium content with them.
13 MR. HULTQUIST: Okay, thank you. "What
14 periods of time can these tailings be exposed without
15 a water cover? Will a 1-meter water cover be
16 required at all times for these tails? Please
17 describe dusting and radon emission impacts that can
18 occur when the waste from processing these -- waste
19 from processing these wastes are not covered."
20 Again, the liquid levels in cells 4A and
21 4B, there's a certain level in which we can't exceed
22 for freeboard limits regarding storm events, et
23 cetera. So they're typically maintained at a level
24 of approximately 4.8 to 5.8 feet below the top of the
25 geomembrane liner in each cell.
Division of Radiation Control Public Meeting * October 9, 2013
89
1 Now, right now, one's receiving liquids
2 and the other one's receiving tails, so -- and
3 they're very low down in the bottom of the cells, so
4 to speak. The groundwater discharge permit also
5 specifies a minimal freeboard of three feet, and so
6 there, at certain times, maybe later, the tails or
7 the beach areas might dry out. At that point, then
8 they need to apply water to them to keep those dusts
9 down. Again, part of their operating procedures are
10 to, if they see visible dust, then they need to go
11 apply applicants, either water or salt water type, to
12 form a crust on those tails. But we can't just cover
13 the whole thing in water, so to speak, or liquids,
14 because there has to be a freeboard there for storm
15 event calculations. We don't want to create a
16 greater mess than what could happen if we overflowed
17 the cells.
18 I think over the time, their Standard
19 Operating Procedures that they have in place, whether
20 it's this Dawn Mining material or alternate feeds or
21 other alternate feeds or Colorado strip or Arizona
22 materials, they're adequate. So unless Harold wants
23 to add any more to the SOPs and what you guys do out
24 there. 25 They do keep records of their dust
Sheet 23
90
1 suppression, their water use, whether it's on the
2 tails or whether it's in the ore storage pad area.
3 We review those during our inspections to see that
4 they are being applied. I don't -- I don't think the
5 staff looks at whether it's a high-wind day or not,
6 just that effort's being made to put water on those
7 areas.
8 MS. TAPP: Thank you.
9 MR. HULTQUIST: I'll turn it back over to
10 you. I think that's the end of the questions.
11 MR. ANDERSON: That concludes all of the
12 written questions that have been submitted. So if at
13 this point in the proceedings, again, we're
14 proceeding informally, if there are any other
15 questions or comments, I suppose they can be
16 submitted. If not, we'll move to close the hearing.
17 John?
18 MR. HULTQUIST: I just wanted to add one
19 thing. Sarah, do you know if the tribe is going to
20 attend the meeting next week down in Blanding? I'm
21 surprised they're not here, so I was just questioning
22 whether or not you knew what the status is with them.
23 MS. FIELDS: I don't know. I think, like
24 everybody, like many government agencies, they're --
25 they have --
91
1 MR. HULTQUIST: They're shut down?
2 MS. FIELDS: No, they're not shut down,
3 but they have funding issues, so I really don't know.
4 There's a possibility -- I will attend. I know I've
5 tried to get other people out to attend, so I've made
6 some efforts to get -- to encourage people.
7 MR. HULTQUIST: Well, we've sent it to
8 them and we didn't hear a response, so I wasn't sure.
9 MS. FIELDS: Well, you might follow up
10 with them and --
11 MS. TAPP: They're aware of the --
12 MR. HULTQUIST: Of the meeting?
13 MS. TAPP: They're aware of the meeting.
14 I am unsure -- the shutdown has impacted them in odd
15 ways, and -- but I believe that you can expect
16 comments. And to be clear, I'm not speaking for the
17 tribe in any way, but they're aware of the meeting.
18 I don't know whether they're going to attend, but
19 they are --
20 MR. HULTQUIST: Okay. Or they might just
21 decide to provide written comments, which is fine. I
22 was just used to seeing them around the table, so I
23 was just wondering if something was -- something was
24 amiss. 25 MR. ANDERSON: John, just for the record,
92
1 it may be worthwhile to repeat the time and the date
2 of the next meeting.
3 MR. HULTQUIST: Okay. The public meeting
4 will be held October 16th at 5:00 p.m. at the
5 Blanding Arts and Events Center, and we will be
6 taking written as well as oral comments. It will not
7 be a time for cross-examination. It will just be an
8 opportunity for local residents to take -- to make
9 oral comments or provide us with written comments if
10 they so desire.
11 MR. ANDERSON: And then written comments
12 will be accepted through the close of business
13 through October 21st; is that correct?
14 MR. HULTQUIST: That is correct.
15 MR. ANDERSON: I think that concludes our
16 business today, so with no further ado, I'll declare
17 the hearing closed.
18 MS. FIELDS: Thank you.
19 MS. TAPP: Thank you all for your time.
20 (The proceedings were concluded.)
21 * * *
22
23
24
25
Division of Radiation Control Public Meeting * October 9, 2013
93 1 2 REPORTER'S CERTIFICATE 3 4 STATE OF UTAH )) ss.5 COUNTY OF SALT LAKE ) 6 I, Kathy H. Morgan, RegisteredProfessional Reporter and Notary Public in and for7 the State of Utah, do hereby certify: 8 That on October 22nd, 2013, I transcribedan electronic recording at the request of Shairose9 Falahati; 10 That the testimony of all speakers wasreported by me in stenotype and thereafter11 transcribed, and that a full, true, and correcttranscription of said testimony is set forth in the12 preceding pages, ACCORDING TO MY ABILITY TO HEAR ANDUNDERSTAND THE RECORDING PROVIDED;13 That the original transcript was sealed14 and delivered to Shairose Falahati for safekeeping. 15 I further certify that I am not kin orotherwise associated with any of the parties to said16 cause of action and that I am not interested in theoutcome thereof.17 WITNESS MY HAND AND OFFICIAL SEAL this18 24th day of October, 2013. 19 20 21 22 23 _____________________________24 Kathy H. Morgan, CSR, RPRNotary Public25
Sheet 24
Division of Radiation Control Public Meeting * October 9, 2013
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 1 0.027 - able
0
0.027 [1] 40:6
0.2 [1] 40:8
02 [1] 81:19
022 [1] 81:10
025 [1] 81:12
07 [1] 34:7
1
1 [13] 22:10 29:9,25 30:4 31:
20,25 32:2,13 37:20 39:12
40:18 53:17 79:4
1.1 [1] 51:6
1.14 [2] 31:21 39:13
1.2 [3] 51:6 54:19 56:20
1.3 [2] 9:18 11:1
1.4 [1] 40:11
1.50 [1] 30:15
10 [8] 5:18 25:25 35:19 39:
1 43:11 77:8,13,18
10.1 [2] 26:2 46:1
10.1(c [1] 11:6
10.20 [1] 84:23
10.9 [1] 46:14
100 [2] 62:9,12
10C [1] 80:12
11 [3] 29:7,8 32:10
11.1 [1] 29:9
11.2 [1] 29:22
11.3 [1] 31:25
11.4 [1] 32:13
11.5 [2] 33:22 38:4
11.6 [1] 36:25
11e(2 [1] 2:10
12 [4] 37:13 48:10,25 53:21
12.1 [1] 37:20
12.2 [4] 39:19 48:17,19,19
12th [1] 42:9
13 [4] 38:25 41:5,15 45:1
13.1 [1] 41:16
13.2 [2] 41:23 44:8
13.4 [1] 45:23
13.5 [1] 46:8
13.6 [1] 47:14
14 [6] 48:9 60:20 87:9,10,
11,25
14.1 [1] 48:10
14.10 [1] 61:13
14.11 [1] 62:22
14.12 [1] 63:22
14.14 [1] 65:1
14.15 [1] 65:19
14.16 [1] 66:10
14.17 [1] 67:1
14.18 [1] 67:21
14.2 [1] 49:7
14.3 [1] 52:1
14.4 [2] 52:11 53:20
14.5 [1] 54:15
14.6 [1] 54:22
14.7 [1] 56:1
14.8 [1] 57:7
14.9 [1] 60:19
14-day [1] 88:10
15 [3] 35:19 39:1 68:11
15.2 [1] 72:18
15.5 [1] 74:24
15th [1] 8:9
16,934 [1] 57:14
16.1 [1] 75:12
16th [1] 92:4
17 [2] 17:9 42:4
18th [1] 42:19
19 [1] 17:9
1946 [1] 7:25
1954 [1] 8:1
1978 [1] 8:2
1979 [5] 40:23 55:21 61:9
67:19,19
1991 [1] 74:12
1993 [1] 40:1
1998 [3] 58:12,14 59:12
1-and-a-half [1] 51:6
1-meter [1] 88:15
2
2 [20] 17:9 22:12 31:15 34:7,
9 39:12 40:19 46:16 49:2
50:13 51:3 53:17 69:8,10,
12 70:20 71:19,20 72:5
80:10
2,000 [2] 56:16,21
2.1 [1] 31:8
2.2 [2] 40:8 51:3
2.5 [1] 51:3
2:00 [1] 2:1
20 [4] 19:2,6 22:5 71:11
200 [3] 61:19,25 62:2
2000 [9] 41:15,17,22 42:3,9,
10,16,17,19
2004 [1] 8:9
2007 [6] 14:2 17:11 45:25
74:14 83:18,20
2010 [2] 30:6 36:8
2011 [1] 34:3
2012 [1] 68:24
2013 [4] 2:1 5:7,15 69:7
20th [1] 42:3
21 [2] 85:9 87:13
21.4 [4] 30:14 31:2,11,23
21st [2] 5:15 92:13
22.8 [2] 36:11 38:25
220 [1] 33:18
224 [1] 35:24
226 [5] 34:4 35:16,23 37:4
38:24
228 [7] 30:12 35:1,24 37:24
40:16 50:7 51:21
230 [2] 31:18 34:24
2308 [1] 38:19
232 [11] 30:19,25 31:3,18
36:21 38:21,23 39:11 50:
7,8 51:21
238 [1] 50:3
24th [1] 42:10
25.7 [1] 36:11
26 [1] 42:16
2nd [2] 58:14 59:12
3
3 [10] 17:9 37:15,15,21,23
38:8 39:19 46:17 48:24
51:8
30 [1] 22:5
35.8 [1] 38:24
36 [1] 36:10
4
4 [4] 63:24 79:17 83:10,15
4.8 [1] 88:24
40 [1] 80:12
41 [1] 36:10
42 [1] 26:8
45-day [1] 5:6
4A [7] 62:23 63:2 64:11 71:
23 79:7 81:18 88:20
4B [8] 62:23 63:2,24 64:12
71:23 79:7,17 88:21
4th [1] 58:12
5
5 [6] 17:10 41:6,6,9,12 82:
25
5(c [1] 80:13
5,646 [1] 57:13
5.2 [1] 72:19
5.8 [1] 88:24
5:00 [1] 92:4
51 [1] 59:20
535 [1] 57:14
55-second [1] 33:15
5th [2] 5:7 42:17
6
6 [3] 17:10 34:5 48:25
60-mill [2] 79:19,20
66 [2] 30:7 31:21
67,600 [1] 81:17
7
7 [9] 39:13 56:3,5,7,12,22,
25 87:13,15
71 [1] 31:22
78 [1] 8:19
8
8 [2] 40:4 77:12
80 [1] 40:4
87,100 [1] 81:18
8th [1] 83:18
9
9 [5] 2:1 11:21 57:22 58:15
59:12
9.1 [2] 11:23,25
9.2 [1] 13:8
9.3 [1] 14:13
9.4 [1] 18:7
9.5 [1] 22:8
9.6 [1] 24:14
9.7 [1] 25:1
90s [1] 19:2
914 [1] 57:12
93 [1] 30:8
99 [1] 57:15
9th [1] 68:24
§
§121(e [1] 76:9
§2021(o)(3)(A [1] 5:19
A
ability [2] 26:19 86:3
able [6] 4:2 13:14 18:3,5
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 2 able - approved
21:21 61:18
above [4] 30:9,20 69:12,25
accepted [3] 5:14 79:8 92:
12
accommodate [1] 26:20
accompanied [2] 42:4 58:
15
accordance [1] 11:5
according [2] 50:20 82:6
account [2] 57:3 85:10
accusation [1] 70:24
acid [4] 37:18 39:25 81:12,
15
acid-leached [1] 39:21
Act [7] 7:25 8:2,19 9:2 42:
25 54:23 59:1
action [5] 3:8 26:12 59:3
71:14 83:15
actions [1] 68:25
active [1] 25:15
activities [5] 39:10,11 49:
25 60:7 76:11
activity [11] 29:17 41:7 48:
11,12,14,15,24 49:6,7 50:
3 53:22
actual [1] 61:24
actually [12] 14:2 21:11
22:1 34:14 45:9 49:10 51:
23 52:21 54:6 56:6 67:15
70:19
add [8] 10:16 21:10 29:4
36:4 59:11 80:24 89:23
90:18
added [3] 50:9 66:6 85:6
addendum [1] 84:9
addition [6] 5:14 12:9 27:
9 46:20 47:24 76:1
additional [9] 4:13 21:24
26:18 27:1 28:16 33:12
47:22 54:12 83:22
address [3] 83:16 84:3 86:
19
addressed [1] 39:16
addresses [1] 36:12
addressing [1] 4:18
adequacy [1] 85:12
adequate [6] 27:24 49:22
80:18 82:22 87:4 89:22
adequately [1] 85:10
adjust [1] 21:15
Administration [3] 67:22
68:1,3
ado [1] 92:16
advance [1] 5:21
AEA [2] 8:1,18
afternoon [3] 2:5,7 6:5
agencies [1] 90:24
Agency [3] 6:24 22:24 77:
17
Agency's [1] 87:17
agenda [1] 5:5
agent [1] 25:4
agents [1] 73:10
ago [3] 19:2,21 41:15
agree [2] 4:23 11:24
agreed [1] 87:15
agreement [6] 8:5 14:8
31:11 59:24 60:10 68:3
ahead [8] 12:9 15:16 30:2
52:14 77:25 78:9,16 81:5
air [7] 56:4,13,15,20 83:22
85:24 86:7
airborne [1] 56:24
ALI [1] 56:18
Allied [1] 16:16
allow [1] 55:24
allows [1] 62:15
all's [1] 79:3
almost [2] 25:14 75:10
alpha [1] 24:12
already [9] 6:9 33:10 40:
25 41:2 45:3 58:21 61:9
66:8,20
alternate [83] 8:20 11:4,16,
22 12:1,11 13:1,9,24 14:3,
16,21 15:8,20,21 16:5 19:
14 20:7,11 22:11,15,18,21
23:4 24:18 25:2,16,23 26:
21 27:11,13,20 28:3,7,18,
20 37:2 41:9,11 43:12 44:
21 46:11 47:4,10 49:8,12
53:24 54:7,13 56:5 57:22
63:8,12,13 65:21,24 66:12,
18 67:3,6,8,11,16 68:17
69:9,18,23 70:6,11,17,19
72:1 74:7,12,14,16,21 75:
2 79:7 84:19 88:11 89:20,
21
although [1] 11:8
ambient [1] 81:18
amended [6] 2:17 5:10,10,
22 6:14 7:25
amendment [45] 2:9 6:4,6
11:2,10,10,12,23 13:13,15
15:23,24 16:3 17:9,12 18:
24,25 19:2,17 28:6 41:18
42:4,10 43:21 45:5 46:21
49:13,23 52:7 53:8 57:22
58:11,15 59:12 61:11 63:
6 64:3,18,21,24 66:2,16
71:22 74:18,22
amendments [9] 14:25
15:20 16:5,9 43:6,13 46:9
47:1 58:8
amiss [1] 91:24
amount [38] 13:9,14,18 14:
6,14,17 15:7,11 16:10,12,
15 20:20 22:10,17,20 23:2,
3,3,4,6,7,12,16,18,19 24:
15 30:14 33:8 36:18 38:6,
7,11,24 39:4 49:7 65:20
73:10 87:20
amounts [4] 16:18 34:22
39:10 45:7
ample [1] 6:24
analogous [1] 48:3
analogy [1] 46:5
analyses [1] 33:7
Analysis [38] 26:3,5,9 28:
19,20,23 29:15 34:3 41:24
42:2,23,24 43:8,8,19 44:4,
6 47:19 54:12 55:21 56:
24 58:8,8,13,24,24 59:2,4,
7,9,18 61:8 63:7,9 66:17
67:14 74:20 80:15
analyte [1] 65:7
analytes [3] 65:10 82:15
83:6
Analytical [4] 30:6 32:9
33:25 34:5
analyze [1] 18:18
analyzed [7] 33:10 34:14
40:22 41:1 61:10 66:8,9
and/or [1] 26:24
ANDERSON [10] 2:5,6 5:
3 6:17 7:3 10:10 90:11 91:
25 92:11,15
Ann [3] 15:9 23:17 25:11
Anne [3] 78:2,9,11
annual [5] 22:17 24:7,22
56:18 63:11
another [4] 19:17 27:11
45:3 51:2
answer [17] 6:1,23 25:12,
22 29:18 41:21 42:1 47:4
51:2 60:11 61:15,17,18
66:2,3 75:21 79:10
answered [2] 23:23 72:13
answering [1] 7:12
answers [4] 7:14,15 60:15
65:13
anticipate [3] 63:25 74:16
78:3
anticipated [1] 64:4
anticipation [1] 63:2
anybody [1] 2:19
anyway [2] 10:8 29:6
apart [1] 87:23
apologies [1] 78:15
apologize [1] 78:13
Appendix [2] 80:13 82:24
applicable [7] 26:14,15
44:22 52:8 53:7 55:3 57:2
Applicant [2] 5:25 73:9
applicants [1] 89:11
application [28] 2:9 5:22
6:4 7:23 8:5 11:2 14:4 22:
15 28:10 35:25 36:2,7 41:
13,14,17,19,22 42:9 46:1
54:9 58:12 68:10 69:1 70:
6 72:7 74:12,14 83:20
applications [11] 16:1,9,
14,20,21,23 18:3 46:9,11,
25 58:7
applied [1] 90:4
apply [2] 89:8,11
applying [1] 88:1
appreciable [5] 34:22 36:
18,21 38:5,11
approach [1] 19:14
appropriate [4] 32:6 46:7
54:4 86:2
approval [5] 11:17 16:21
41:18,19 47:4
approvals [7] 16:14,20 20:
13 46:9,12 47:1 75:22
approve [3] 20:14 54:16,
19
approved [16] 11:5 14:7,
17 16:13 18:10 19:5 46:5,
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 3 approved - closure
22 48:3 54:3,16 57:21 67:
12 73:2 74:22,23
approving [1] 47:20
approximately [5] 37:9
39:1 40:4,8 88:24
April [6] 41:14,17,22 42:9,
10,16
area [5] 69:9,11,17 71:6 90:
2
areas [2] 89:7 90:7
arena [1] 21:12
aren't [1] 54:13
arguing [1] 43:25
Arizona [3] 50:24 54:11
89:21
around [6] 6:8 40:11 51:6
53:17 85:19 91:22
arrive [2] 12:22 37:10
arrived [1] 12:18
Arts [1] 92:5
aspect [2] 19:17 62:7
assess [1] 55:13
assessable [1] 26:16
assessing [1] 27:1
assessment [9] 41:2 43:
14 49:21 54:23 55:1,22
67:18 68:20 74:3
assessments [2] 43:4 55:
25
assigned [1] 15:23
associated [9] 12:8,17 14:
22 28:12,22 46:10 55:8
58:9 68:16
assume [4] 32:21 33:8 49:
19 50:6
assuming [4] 32:19,19,22
61:21
assumptions [1] 61:23
Atomic [3] 7:25 9:2 54:23
attend [4] 90:20 91:4,5,18
attenuating [1] 69:14
Attorney [2] 10:19 78:12
authority [1] 76:2
authorized [2] 15:25 46:
15
availability [1] 33:19
available [7] 5:13,25 6:12
15:14 26:14 65:6 79:23
average [5] 31:23 37:17
39:21,25 45:6
aware [8] 46:18 47:9 68:19
71:13,16 91:11,13,17
away [3] 17:13 46:3 62:11
B
back [22] 4:6 8:4,25 10:25
16:8,25 17:3,16 21:21 28:
6,10 31:3 38:3 40:18 47:3
48:17 51:1 55:20 61:9 84:
9 88:2 90:9
background [1] 65:11
ballpark [1] 48:5
bankments [1] 64:10
barium [13] 80:12,16 81:1,
3,8,9,9,13,13,19 82:3,16,
19
based [2] 57:2 64:4
Basically [3] 8:17 18:16
35:7
basing [1] 70:22
Basis [9] 5:11 8:3 12:5 22:
17 24:8,22 61:4 73:6 82:7
BAT [2] 73:1 79:22
beach [1] 89:7
become [2] 8:5 87:23
becoming [1] 14:7
becquerel [1] 40:7
becquerels [2] 40:4,5
began [1] 5:7
begin [3] 6:15 7:4,12
believe [14] 7:21 13:8 22:9
26:2 32:8,10 35:12 40:11
48:22 59:23 64:2 75:9 85:
1 91:15
believes [1] 26:13
below [3] 34:9 53:23 88:24
best [6] 4:20 10:4,6 15:19
39:14 79:23
best-available [2] 64:8
73:4
better [4] 19:18 31:10 51:
23 60:15
between [8] 3:4 12:18 39:
20 51:3,9,20 68:4 70:10
beyond [1] 28:11
big [2] 85:5 87:21
bit [7] 3:15 4:16 20:1 30:9,
20 86:1,2
Blanding [3] 68:25 90:20
92:5
Blind [1] 57:20
blunt [1] 61:19
both [4] 12:6 66:18 73:16
79:20
bottom [2] 30:22 89:3
boxes [2] 17:22,23
break [3] 77:21 78:1 87:22
breathed [1] 56:15
brick-like [1] 85:3
brief [1] 6:16
briefly [2] 8:17 61:12
bringing [1] 60:12
brought [1] 18:13
build [1] 80:2
bunch [1] 58:18
burden [1] 82:2
business [3] 5:15 92:12,
16
byproduct [5] 2:10 23:9
24:5 25:8 79:15
C
C.F.R.§51.22(c)(11 [1]
43:11
calcined [5] 56:8 57:8,14,
18 58:10
calculations [1] 89:15
calendar [1] 22:19
call [3] 4:19 7:5 76:13
Camco [2] 16:16 18:4
came [1] 36:16
Cameco [2] 19:7 57:17
Canada [1] 19:8
Canyon [2] 77:24 78:12
capacity [1] 42:18
care [6] 22:20 33:7 55:6,10,
15 83:24
carries [1] 21:16
carryover [1] 60:10
case [1] 59:23
catch-all [1] 48:8
categorical [2] 44:3 59:8
categorically [2] 43:11,
13
categories [1] 3:10
CDs [1] 17:7
Cell [24] 24:21 25:6,7,10,19,
20 63:2,15,24 69:8,10,12,
15,18 70:20 71:19,20,23
72:5,5 79:17,17 81:18 88:
25
cells [17] 23:8 25:15 26:23
62:23 64:11,13,19 66:14,
25 72:9 73:11,17 79:7,20
88:20 89:3,17
Center [1] 92:5
centrifuge [1] 36:9
CERCLA [3] 75:24 76:9,
11
certain [5] 16:15 73:8 86:
21 88:21 89:6
certainly [1] 39:8
cetera [3] 14:6 64:20 88:
23
chain [3] 32:3 48:12 50:12
chalk-like [1] 84:17
change [3] 20:18 21:17 81:
18
changed [1] 21:23
changes [3] 20:4 22:4 84:
12
characteristics [5] 18:9
20:12 22:12,16 24:3
characterization [4] 18:
24 21:20,22 22:3
characterized [2] 20:17
24:11
check [1] 13:4
chemical [20] 18:9 20:12
22:12,16 24:3,11,16 63:9,
16,19,25 65:1 66:11,13,19,
25 67:2,17 79:14 80:3
Chief [1] 15:18
chronic [1] 56:23
chunks [2] 85:5 87:21
circuit [1] 81:13
circulated [1] 6:7
citations [1] 68:7
City [1] 2:1
clarify [5] 15:6 23:6 60:6
77:6 80:22
clarifying [1] 83:3
cleaned [1] 45:3
cleanup [1] 21:2
clear [3] 31:8 42:22 91:16
close [5] 5:15 62:19 72:2
90:16 92:12
closed [3] 71:19 72:6 92:
17
closure [1] 64:11
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 4 Code - David
Code [1] 5:18
cold [2] 81:10,10
collected [1] 18:15
collects [1] 24:22
Colorado [21] 27:22 33:3,
5,9 34:13,15,17 41:11 44:
21 50:4,16 51:15,22 54:11
63:4 65:24 69:25 70:12
73:22,23 89:21
columns [1] 56:7
come [12] 7:10 13:4,23 17:
2 45:2 51:17,17,18 62:19
70:14 74:21 84:9
Comeco's [1] 57:20
comes [6] 12:15 13:18 15:
5 16:11 19:10 48:1
coming [11] 12:7,12 16:16
33:5 38:6,22 71:21,24 73:
3,7 86:25
comment [16] 4:2,4,16 5:6
6:18 14:5 15:10 28:16,25
29:2 36:23 45:12,18,21
46:23 66:6
comments [28] 2:13,16,
19,23 3:3,22 4:3,6,11,14 5:
4,14,20 6:2,4 7:4 9:11,22
36:24 46:19 76:24 90:15
91:16,21 92:6,9,9,11
Commission's [1] 5:17
committed [1] 16:22
communities [1] 85:13
community [1] 29:14
Company [1] 40:17
comparable [3] 40:16 50:
14,25
compare [6] 38:7,9,20 39:
5 60:25 61:1
compared [6] 30:25 37:1
41:10 49:13 51:8 69:20
compares [2] 63:13 67:5
comparing [3] 39:15 47:
15 48:20
comparison [11] 38:1,21
39:20,23 41:7 50:17 51:8,
10,12,13,23
compatibility [5] 63:7 66:
11,17 79:6 80:4
compatible [2] 27:17 63:
16
compliance [1] 71:18
composition [4] 63:10,13
66:22 84:17
compounds [1] 18:19
comprehensive [1] 26:
10
computer [1] 78:13
concentrate [1] 10:7
concentrated [2] 81:11,
15
concentration [14] 29:10,
13,16,17 32:25 35:4 37:4
49:18 56:14,14 65:9 71:
10 81:16,19
Concentrations [35] 30:
5 32:4 33:2,4 34:6,8,9,11
35:4 37:10,16,22,24,25 39:
14,24 40:2,15,16,21 41:8,
10 44:22 49:14,25 52:9
53:9,16,22 54:9 56:4 60:
20,23 61:7 72:12
concern [1] 85:8
concerned [2] 85:12 86:3
concerns [1] 82:14
conclude [1] 50:2
concluded [1] 92:20
concludes [2] 90:11 92:
15
condition [9] 11:6 13:14
46:1,14 56:19 61:10 67:
18 84:23 85:7
conditions [4] 14:7 46:10
56:17 85:24
conduct [2] 12:21 41:24
conducted [7] 34:2 42:1
58:12 60:7 74:24 76:11
80:17
conducts [1] 68:4
consider [2] 27:5 53:18
consideration [4] 68:15
72:14,21,21
considerations [1] 21:24
considered [8] 26:7 32:5,
17 40:12 42:23 53:11 54:
4 72:15
considering [1] 39:3
considers [4] 26:9 37:21
63:9 72:24
consistent [4] 13:22 21:
14 26:13 79:22
consists [1] 61:10
constituents [19] 8:22 18:
19 24:11,16 39:21 49:24
63:17 64:1,4 65:2,23 66:
19 67:2,5,17 73:18,21 79:
13,14
constitute [1] 26:10
constitutes [1] 59:18
constructed [1] 79:18
construction [1] 63:24
contact [3] 61:24 62:10,16
contain [9] 22:15 34:18,20,
22,24 40:11 65:7 74:9 80:
1
contained [1] 80:12
container [1] 61:25
containing [2] 49:8 74:19
containment [2] 64:9 79:
24
contains [1] 39:20
contaminates [3] 65:20
66:11,15
contemplated [1] 7:24
contemplates [1] 74:12
contemplating [1] 62:23
content [17] 30:12 48:19
51:21,21 52:3,6,16,17 53:
11 68:6,6 85:21 86:24 87:
5 88:2,11,12
context [5] 48:20 60:9,12
76:24 77:2
continual [2] 21:4,5
continually [2] 20:21 21:1
contractor [1] 5:24
Control [7] 5:23 7:19 8:2,
19 10:22 56:23 79:6
controlled [1] 55:5
controls [2] 54:3 88:9
Conventional [20] 11:11
13:2 22:18 27:19 49:17
50:1,3 52:10 53:24 54:10,
16,17,19 55:18 61:8 64:5
67:20 71:9,24 74:17
conversion [2] 40:6 57:
20
convert [1] 40:5
conveyance [1] 62:4
Copies [2] 5:10 17:22
copy [8] 3:6,25 4:3,9,9 8:
12 70:1,2
Corp [1] 75:13
Corporation [1] 47:9
Corporation's [1] 57:17
Correct [9] 11:11 16:24 23:
21 28:14 31:24 43:16 82:
25 92:13,14
correctly [1] 85:25
counsel [2] 6:19 75:21
couple [3] 2:24 74:11 83:
22
course [1] 75:5
court [1] 48:17
cover [13] 72:3,5 73:15 84:
24 85:2,7 86:22 87:3,18
88:3,15,15 89:12
covered [1] 88:19
covers [1] 11:13
Craig [1] 2:6
create [2] 71:25 89:15
created [1] 81:4
criteria [1] 79:23
criterion [2] 80:13 82:24
cross-examination [1]
92:7
crust [1] 89:12
cubic [2] 16:10 56:20
cumulative [9] 19:13 24:
15 27:10,12 28:2,23 29:4
74:25 75:4
Curies [14] 29:11 30:7,8,
14 34:10 35:19 36:10,11
39:2,13 40:7 51:3 53:17
71:11
curiosity [1] 82:2
current [2] 26:19 73:15
currently [9] 14:1 27:16
46:23 47:8,10 54:4 63:9
68:25 80:15
cutoff [1] 52:18
D
DAC [5] 56:11,14,22,25 57:
5
daily [1] 73:6
data [4] 24:15 36:6 45:5 49:
3
date [4] 6:12 63:18 66:24
92:1
dated [2] 8:9 83:17
dates [3] 13:19 58:7,18
David [1] 75:20
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 5 Dawn - equal
Dawn [19] 13:13 40:17 46:
20 48:21 49:11,14,16 52:8
54:10 57:2,4 63:17 66:9
71:18 75:13,22 80:20 86:
19 89:20
day [1] 90:5
days [8] 4:24 6:21 7:2 85:1,
9 86:22 87:9,9
deal [2] 6:25 78:15
dealing [1] 14:24
decay [13] 32:1,22 37:22
48:12 49:9 50:12 60:21,
21,23 61:2,3,5,7
December [2] 42:3,19
decide [1] 91:21
decided [1] 83:25
declare [1] 92:16
decompose [1] 85:4
deemed [2] 80:18 86:1
defer [1] 14:23
definition [1] 56:13
degree [1] 25:20
delegation [1] 5:18
Demonstration [1] 53:21
Denison [1] 47:12
Denison/Sequoia [1] 47:
13
Department [1] 77:15
department's [2] 5:12,13
depends [1] 72:1
deposit [1] 50:21
deposited [1] 24:4
deposition [2] 83:17 84:
20
deposits [2] 50:23,24
derived [3] 56:4,13,22
describe [2] 63:23 88:17
described [2] 46:14 81:7
Deseret [1] 5:9
design [6] 26:23 63:1,15,
23 64:3 79:23
designed [2] 62:23 79:22
desire [1] 92:10
details [1] 59:16
detect [1] 65:23
detection [2] 64:8 79:21
determination [1] 8:3
determine [9] 13:9 14:14
16:9 18:7 30:11 65:21 66:
12,21 80:11
determined [3] 52:4 53:5
66:10
developed [2] 57:1 63:2
dewatered [4] 36:8 64:22
69:13 72:6
dewatering [3] 34:2 64:
20 70:14
dialogue [1] 7:13
dictated [1] 39:11
die [1] 78:14
difference [3] 35:19 70:10
87:12
different [8] 19:4,25 20:2
21:18 27:18 48:5 62:6 73:
21
difficulty [2] 4:1 82:5
directly [1] 10:11
Director [5] 8:8 10:21 11:5,
17 74:23
discharge [7] 24:7 65:22
66:5 73:5 75:7 83:6 89:4
discharged [2] 25:19,21
discounting [1] 61:4
discrepancy [2] 30:17 51:
20
discussion [2] 55:2,7
discussions [1] 69:3
dispersal [2] 72:25 73:7
dispersion [2] 85:22 88:3
disposal [17] 24:17 26:22
27:13 28:3 41:25 42:21
55:10,15 58:9 62:24 63:3,
25 68:16 72:22 74:6 75:1
80:19
disposed [10] 25:3,16,23
27:16 45:9 69:10,23 70:
11 73:19,22
disposing [1] 66:14
disposition [1] 21:25
distance [1] 62:11
Division [4] 5:23 7:19 10:
21 79:5
Division's [1] 5:24
DMC [4] 30:5 40:17 75:12
81:8
document [6] 4:2,7 11:14
29:3 40:1 71:3
documentation [2] 43:9
69:17
documented [2] 42:2 58:
13
documents [10] 3:23,25 9:
20 17:8,21,21 41:18,20 49:
22 74:8
doing [3] 15:13 21:18 46:
20
done [19] 12:3 13:21 18:24
29:15,15,17 39:8 40:23
41:2,3 44:2 61:9 67:19,19
75:10,17 80:5 84:8,8
door [1] 13:18
dose [1] 84:8
DOT [2] 62:15,20
double [1] 79:20
doubt [2] 13:3 45:2
down [12] 30:21 70:7 71:
24 72:12 73:9 74:10 85:
18 89:3,9 90:20 91:1,2
downwind [1] 85:13
draft [2] 84:9,11
DRC [51] 3:24 5:8 10:19 11:
25 12:14 13:9,15 14:9,14
16:8 18:7,10,14,15,16 22:
9 24:14 26:2,12,17 36:25
39:22 41:16,19,21 46:8,12,
15,20,21 48:14 52:1,4 54:
5,15,16,19 55:12 63:7 65:
6,19 66:3,10,17 68:9,14,
19 72:20 74:24 79:18 84:
15
DRC's [3] 2:12 8:3 47:12
dries [1] 87:1
drums [2] 16:11,12
dry [1] 89:7
due [2] 81:14,20
dumped [1] 87:22
during [8] 12:20 13:19 15:
21 22:19 40:22 42:7 75:4
90:3
dust [7] 73:3,10 85:14 88:8,
8 89:10,25
dusting [1] 88:17
dusts [1] 89:8
duty [1] 65:18
E
EA [3] 44:4 59:7 74:3
each [9] 22:11 25:23 57:9
63:6 66:16 68:9 71:5 74:
20 88:25
earlier [4] 15:20 17:21 47:
25 78:14
early [2] 15:21 18:3
Ecology [1] 77:15
EEP [1] 75:24
efforts [1] 91:6
effort's [1] 90:6
EIS [8] 33:11 40:22 55:20,
24 59:7 61:9 67:19 74:2
either [5] 18:14 59:4 71:23
78:2 89:11
elements [4] 63:1,23 64:3
68:22
elevated [4] 68:15 69:19
71:6,7
eliminate [1] 83:16
elsewhere [1] 32:10
emission [1] 88:17
emissions [6] 32:14,16
33:13 69:12,19 70:8
encompassing [1] 36:13
encourage [1] 91:6
end [9] 4:21 15:1,5 19:25
20:1 32:2 82:9 84:10 90:
10
Energy [14] 2:9 5:25 6:19,
22 7:25 9:2 11:1 15:18 29:
3 54:23 69:21 71:1 75:16,
21
enforceability [1] 86:4
enforcement [2] 68:2 76:
25
enough [3] 4:24 21:23 75:
17
ensure [1] 87:4
envelope [2] 41:1 49:23
Environment [6] 15:4 22:
23 26:24 27:24 82:23 85:
13
Environmental [46] 26:3,
5,9,11,15 27:3,8 28:2,12,
19,21 33:6 41:24 42:2,6,
23,24,25 43:1,2,4,7,10,14
44:4,5 47:19 49:21 55:22
58:8,13,17,24,24 59:1,2,4,
7,9,18 74:3,5,19,20 75:6
77:17
EPA [9] 76:5,6,13,16,21 77:
7,8,16,18
equal [2] 14:16 30:18
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 6 equals - gross
equals [1] 23:20
equilibrium [3] 30:11 40:
13,13
equivalent [1] 40:8
error [1] 67:24
essentially [3] 8:24 81:1
82:9
established [1] 54:4
et [3] 14:5 64:20 88:22
evaluate [2] 54:5 74:4
evaluated [4] 26:7 37:1
49:13 75:4
evaluating [2] 26:11 79:6
Evaluation [19] 5:11 26:1,
18 27:15 29:9 36:6 37:14
42:3,5,8 49:21 56:2,2 58:
14,16 59:6 63:18 74:9,24
evaluations [1] 49:20
even [4] 19:23 36:19 50:24
62:19
event [1] 89:15
events [3] 63:11 88:22 92:
5
everybody [1] 90:24
everyone [1] 10:11
exactly [6] 19:9 25:22 55:
2,4,12 56:6
example [2] 66:4 69:17
exasperate [1] 84:19
exceed [1] 88:21
exceeded [1] 65:8
exceeds [1] 62:20
Except [1] 34:17
excess [1] 65:3
excluded [2] 43:11,13
exclusion [2] 44:3 59:8
excuse [10] 14:18 33:18
37:20 47:17 56:2 61:1 68:
6 73:23 81:10 84:18
excuses [1] 17:5
Executive [1] 15:17
exemption [1] 76:10
exhibit [1] 40:14
existing [2] 54:2 80:16
expect [3] 37:9 45:19 91:
15
expectation [1] 82:9
expected [5] 37:5 40:14
50:25 54:1 81:21
expecting [1] 60:9
experience [2] 60:16,17
experiment [1] 4:25
explain [2] 56:5,11
exposed [1] 88:14
exposure [2] 56:23 62:6
exposures [3] 26:25 27:4
56:25
extent [1] 41:12
extracted [1] 8:23
extraction [1] 8:22
F
facility [10] 19:6 40:24 44:
16 45:3 46:17 55:20 57:
18,20 73:1 79:24
fact [6] 7:7 43:12 55:18 68:
15 70:17 72:21
factor [1] 40:6
factors [1] 72:24
factual [1] 10:7
fail [1] 33:23
failed [1] 10:18
fails [1] 32:13
fair [1] 87:20
Fansteel [1] 66:4
far [5] 15:10 17:3 59:17 80:
12 84:15
February [1] 83:18
federal [3] 43:22 76:10 83:
7
feed [63] 8:20 11:4,22 12:1,
11 13:9,24 14:16 15:8,20,
21 16:5 19:14 20:11 22:
11 23:4 24:18 25:2,16,23
26:22 27:11,20 28:18,20
41:11 43:12 44:21 47:10,
18 49:8,12 53:25 54:7 56:
5 60:24 63:8,14 65:24 66:
18,19 67:3,7,8,11,14,16
68:17 69:10,18,23 70:6,11,
17,19 74:7,12,14,21 75:2
79:7 84:19 88:11
feeds [24] 11:17 13:2 14:3,
21 20:7 22:15,18,21 27:13
28:4,7 37:3 41:9 46:11 47:
4 54:13 57:22 63:12 65:
21 66:12 72:1 74:17 89:
20,21
feel [7] 7:1 17:16 73:14 82:
21 84:22 87:3 88:8
feels [1] 14:9
feet [3] 70:20 88:24 89:5
few [2] 3:3 13:1
fill [2] 64:21,23
filter [2] 34:1,2
find [3] 17:17 39:15 55:1
findings [2] 68:23 83:24
fine [3] 78:3 85:4 91:21
fined [1] 62:21
fines [1] 87:23
finish [1] 77:6
finished [1] 17:15
first [9] 5:1 7:21 9:16 11:23
43:18 60:16,16,17 69:16
fit [3] 3:9,9 9:11
five [2] 42:8 70:20
flexibility [1] 88:5
flexible [1] 79:19
floor [1] 2:16
fluids [2] 23:20 64:5
Flux [4] 69:7 71:10,21,25
folded [1] 78:17
folks [1] 75:9
follow [2] 18:5 91:9
following [3] 34:3 42:5 58:
16
follow-up [3] 16:7 52:12
69:5
forces [1] 72:23
form [2] 25:18 89:12
formerly [1] 68:9
formula [1] 23:25
forward [3] 7:2,11 10:8
found [8] 64:1 65:3,10,24
69:21 71:1,6,6
four [8] 26:4,8 27:5,9 33:25
47:24 57:20 70:20
frame [3] 6:21,22 30:1
framework [1] 26:11
frankly [1] 7:14
freeboard [3] 88:22 89:5,
14
free-standing [1] 64:12
FRIEDLAND [2] 75:20,20
FRMI-Muskogee [1] 46:
17
front [2] 50:24 82:16
Fuel [1] 11:1
Fuels [11] 5:25 6:19,22 15:
19 29:4 47:9,13 69:21 71:
1 75:16,21
Fuels' [1] 2:9
funding [1] 91:3
further [3] 70:16 77:3 92:
16
future [2] 13:16,19
G
gaps [2] 10:13 60:6
gave [1] 35:11
general [4] 23:25 75:13,21
79:11
generally [4] 12:15,16 25:
5 29:5
General's [1] 10:19
generated [6] 20:22,24 21:
1,5 33:9 73:3
generates [1] 21:13
generation [5] 21:15,17
22:2,4 32:18
generic [1] 23:2
geographic [2] 40:3 50:
21
Geological [1] 68:20
geology [1] 50:21
geomembrane [2] 79:20
88:25
geomembranes [1] 64:7
gets [4] 13:7 15:3 48:1 72:
12
getting [1] 17:15
give [10] 9:9 14:11 15:2 17:
12 31:19 44:2 48:20 51:
10 60:15 88:5
given [7] 17:4,5 21:8 56:15
87:2 88:7,11
got [6] 10:9 21:2,2 61:19
78:17 86:20
government [1] 90:24
grab [1] 18:16
Grace [8] 41:13,17,22,25
42:9 44:14 46:2,4
gram [14] 29:12 30:7,8,15
34:8,10 35:19 36:10,11
39:2,3,13 40:9 51:4
Grand [2] 77:24 78:12
great [2] 41:12 79:2
greater [4] 30:18 71:11,25
89:16
gross [1] 24:12
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 7 groundwater - known
groundwater [19] 24:7,20
64:16 65:3,5,8,9,22 73:5
75:7 80:11,15,17,19 82:10,
25 83:6,8 89:4
guess [19] 4:19 5:4 6:8 7:
11 10:4 19:7,13 20:9 25:
21 28:24 29:25 31:7 35:
24 38:25 46:24 65:16 68:
13 72:15 79:10
guidance [2] 26:14 74:14
guys [1] 89:23
H
half [2] 62:1,8
half-life [1] 33:15
half-lives [2] 60:25 61:2
handle [3] 20:11 27:18 84:
22
handled [1] 72:2
handy [2] 4:2,10
happen [4] 4:11 22:4 62:2
89:16
happens [3] 12:5,12 19:5
hard [1] 30:22
Harold [7] 15:9,17 23:17
25:11,14 86:18 89:22
HDPE [3] 79:19,21 80:8
head [1] 85:9
health [13] 27:25 28:21 54:
24 55:7,13 61:1,2,4 67:22,
25 68:2 74:4 82:22
hear [1] 91:8
heard [1] 10:15
hearing [15] 2:7,9,15 3:5,
18 5:16,20 6:11,13 7:4,5,5
10:3 90:16 92:17
heart [1] 44:11
held [2] 68:25 92:4
help [5] 11:18 38:13 42:11
44:7 60:5
helpful [2] 3:12,14
Heritage [1] 45:10
high [12] 25:20 51:20 52:3,
6,17 53:13,18 85:10,20 86:
24,24 87:5
high-density [1] 79:19
high-thorium [1] 53:11
high-uranium [1] 88:12
high-wind [1] 90:5
history [1] 71:5
hit [1] 13:1
hold [1] 4:21
holder [1] 14:20
honest [1] 25:12
hope [4] 7:12 57:18 65:12
72:11
hopefully [1] 4:12
hoping [1] 84:10
hour [6] 56:20 61:20,25 62:
1,8 75:18
hours [2] 56:16,21
However [7] 30:13 48:11
54:25 56:5 66:2 67:4 79:
12
hundreds [2] 17:8,8
I
I.E.(10 [1] 24:20
identical [1] 27:21
identified [11] 16:18 36:
17 38:17 43:18 56:7 63:
18 66:24 69:8,11 83:17
84:20
identify [7] 18:3 33:23 35:
22 58:7 63:1,22 74:8
identifying [1] 60:6
ignored [1] 60:22
Impact [4] 26:9,15 43:1,2
impacted [1] 91:14
impacts [25] 19:13 26:12,
24 27:4,8,11,12 28:2,2,12,
21,23 29:5 33:19 54:24
55:13 59:2 61:1,2 74:5,25
75:4 80:19 85:14 88:17
implement [1] 83:21
implementation [1] 84:6
implementing [1] 27:1
important [3] 14:9 28:24
43:20
impose [1] 82:25
impossible [1] 25:14
impoundment [5] 38:12
66:15 68:18 69:20 73:19
impoundments [3] 64:15
72:23 73:1
inaudible [2] 7:10 8:18
include [10] 32:2,13 35:21
37:21,23 48:14 79:20 83:
5,5 84:1
included [11] 6:6,13 33:24
34:3 35:6,8,13,25 36:5 39:
23 49:6
includes [6] 26:18 31:25
35:23 56:7 63:7 66:17
including [1] 70:6
incorporated [1] 69:2
incorrect [3] 31:2,12 54:
20
increased [3] 27:3 69:11
70:8
increases [1] 27:3
increasing [2] 26:23,24
indicate [3] 4:4 34:6 56:9
indicated [6] 3:7 9:17,23
42:24 46:24 51:1
indicates [3] 40:2 48:10
53:25
informal [2] 2:8 5:19
informally [1] 90:14
information [23] 3:15 4:
13 14:11 21:9 22:9,22,25
24:18,25 32:16 35:25 37:
15 40:1 41:13 42:6,12 44:
19,24 47:11 51:23 56:3
58:17 59:22
information's [1] 15:14
informed [1] 4:14
inhalation [1] 56:20
initial [1] 18:23
initially [2] 79:10 86:22
inspect [1] 13:16
inspected [1] 73:6
inspection [6] 5:13 12:13,
19,23 13:6,20
inspections [4] 12:21 68:
5 75:5 90:3
inspectors [1] 12:4
institute [1] 82:3
intake [2] 56:17,18
intended [1] 56:23
interest [1] 3:1
interim [1] 72:5
International [1] 42:7
interpretation [1] 9:6
interpretations [1] 3:11
interpreted [1] 59:24
interprets [1] 9:2
introduce [1] 78:9
irrelevant [1] 48:2
isn't [4] 7:10 80:25 88:8,8
isotope [1] 32:5
isotopes [6] 31:18 32:20
33:23 36:13 38:1 52:9
isotopic [1] 49:3
issue [9] 29:5 33:7 46:4 62:
15 70:5,13 76:25 81:3 87:
24
issued [2] 15:20 59:11
issues [4] 4:12 6:20 51:20
91:3
issuing [1] 39:9
items [7] 13:5 26:4,8,10,13,
18 47:24
IUC [1] 47:12
IUSA [6] 42:7,10,16,17,19
58:11
J
January [1] 8:9
Jersey [1] 51:18
Jo [3] 15:9 23:17 25:11
John [14] 7:11,18 36:3 39:
7 43:18 48:16,18 50:5,13
54:8 61:14 82:6 90:17 91:
25
Juan [1] 5:9
July [2] 68:24 69:7
June [1] 58:12
jurisdiction [3] 60:8 75:
25 77:11
justification [3] 40:20 47:
14 87:19
justified [1] 88:11
justify [1] 82:11
K
K4 [3] 56:8 57:8 58:10
keep [5] 24:2 25:1 73:3 89:
8,25
KF [2] 57:12,16
kick [2] 34:1 86:17
kicked [1] 74:10
kilogram [3] 29:11 40:5,7
kilograms [1] 40:6
kind [14] 4:25 9:22 18:12
20:3 23:22 28:18 44:15
45:24 48:8 60:9,12 74:10
82:1,3
kinds [1] 51:24
knowledge [1] 15:19
known [3] 3:14 63:9 69:16
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 8 knows - Mill
knows [3] 25:5,7 76:17
L
lab [1] 31:19
laboratory [1] 31:4
Lake [2] 2:1 5:9
Land [1] 22:24
language [3] 85:2,24 86:4
last [7] 6:8 42:19 47:7 75:
11,18 77:7 82:17
late [1] 78:13
later [3] 2:23 19:10 89:6
Laura [2] 7:17 10:17
law [1] 43:22
leach [1] 39:25
leached [1] 37:18
lead [4] 32:6,9,11 45:8
lead-208 [3] 32:2,4,5
lead-210 [1] 32:1
leak [3] 64:7 79:21 82:16
leakage [1] 64:14
learned [1] 4:23
learning [2] 60:13,18
least [3] 19:24 20:3 68:5
leaving [2] 73:11 87:6
left [3] 4:22 67:10 83:13
legal [3] 3:10 6:19 76:7
less [5] 14:16 23:15 30:16
34:9 88:10
lesson [1] 5:1
letter [11] 3:6 4:17 8:9,15 9:
21 29:21 42:10,16,18 78:
22,23
letters [1] 42:8
level [4] 52:15 69:25 88:21,
23
levels [12] 30:19 39:12 48:
20 50:15,20,25 53:25 68:
15 69:19 71:6,7 88:20
license [65] 2:10,17 5:10,
11,22 11:2,5,7,9,10,12 13:
15 14:2,4,4,12,20,25 15:
12 16:3,8,9,14,19,22,25
17:11 19:16 22:14 28:6
33:11 34:14 36:7 42:4 43:
5,5,13,21 45:5,25 46:3,9,
10,14 49:12 52:7 53:8 57:
23 58:7,11,15 59:11 66:2
68:9 69:1 71:22 72:7 74:
11,15,18,22,22 75:14 84:
12,23
licensed [2] 8:24 68:8
licensee [21] 13:7 14:1,23
16:21 17:1 24:22 25:1,5,7
29:19 41:18 44:13,18 46:
15 52:20 69:4 71:15 72:
11 83:20 84:22 86:15
licensees [1] 62:18
licensee's [3] 13:17 14:10
75:6
licenses [2] 75:25 76:11
licensing [5] 3:8 7:18 8:5
25:4 59:3
life [2] 55:5 64:19
light [3] 56:17,19 85:5
limit [6] 9:9 56:18 62:3 65:
9 67:13 71:18
limited [2] 6:3 26:3
limits [2] 56:23 88:22
Linde [1] 45:10
line [3] 61:8 70:7 71:7
liner [3] 79:22,24 88:25
liners [3] 64:7 79:7 80:5
liquid [1] 88:20
liquids [4] 64:13,13 89:1,
13
list [1] 26:13
listed [3] 26:4,8 81:16
lists [2] 13:14 31:17
liter [3] 81:11,12,20
little [9] 3:4,15 4:16 20:1
30:9,20 69:5 85:25 86:2
LLEWELLYN [11] 36:5
39:7,7 48:18,18 49:2 50:5,
5,8,11,19
loading [2] 55:9,14
local [1] 92:8
located [1] 46:17
location [2] 40:3 50:21
LOCKHART [34] 4:15 7:7
9:8,15,19,24 10:1,6,16,18
19:11 20:6 29:1,22 43:16
45:11,14,19,23 59:21 60:3
61:12 76:7,16,23 78:18,21,
24 79:1 80:24 82:5 83:12
86:7,12
Lohaus [1] 8:7
long [5] 19:21 64:11,19 78:
4 82:18
longer [2] 64:14 85:1
long-term [3] 55:6 74:6
75:1
look [23] 12:6,10,16,24,25
13:5,19 17:1,2 22:3 23:12
27:10,12 28:7 31:9 47:24
53:4 60:11 65:18 66:20
76:9,14 82:4
looked [9] 8:4 16:8,19 43:
19 47:22 49:16,17 76:21
84:15
looking [12] 9:21 12:21 18:
16 27:15,16 28:1 30:4 31:
9 36:15 45:6 47:21 53:15
looks [1] 90:5
loose [1] 86:1
lot [5] 10:13 19:5 36:20 38:
22 78:19
low [10] 30:24 34:7,8,11 35:
5,7 53:10 81:14,14 89:3
lower [2] 34:15 62:12
low-level [1] 7:19
LUNDBERG [10] 10:20,21
21:10,11 76:19 77:5,6,10,
14,19
M
made [8] 6:12 20:4 21:25
28:9 55:25 66:6 90:6 91:5
maintained [1] 88:23
maintenance [1] 73:2
majority [1] 28:19
makeup [2] 21:23 57:4
man [1] 56:16
managed [1] 78:14
management [7] 21:12
42:17,20 52:3,6,17 75:24
manager [1] 7:18
managing [1] 77:1
Many [3] 65:10 83:13 90:
24
Mariah [3] 78:2,9,11
mass [1] 29:16
materials [46] 7:24 11:7
12:22 19:4 25:21 27:20
28:13 33:11 37:8 39:24
44:14 45:7 46:2 47:15 49:
8 53:16,25 54:5 56:10 57:
9,13,15,21 58:10,10 60:24
63:4 66:18 67:4,14 68:18
70:17 71:18 72:22,25 73:
7,16 74:7 75:2,23 76:2 79:
12,12 80:2 84:19 89:22
material's [1] 20:15
matter [2] 5:6 8:23
matters [2] 6:3 10:7
max [3] 31:3,11,23
maximum [11] 15:22 16:2,
4 30:13,14,19,21,24 45:6,
6 53:23
mean [21] 9:16 23:3 32:21
38:7,14 43:2,8 45:13 50:6,
7 51:14,16 52:18,22 60:2
61:18 62:4 65:17 69:23
76:5 80:25
means [6] 43:14 44:3,5 56:
11,14 69:22
meant [1] 43:7
measure [3] 56:7,12 71:4
measures [1] 27:2
measuring [1] 30:12
meet [1] 71:17
meeting [8] 5:17 68:24 90:
20 91:12,13,17 92:2,3
member [1] 36:15
membrane [1] 79:21
memorized [1] 52:20
mentioned [2] 24:19 31:
22
Mesa [17] 3:2 12:1 13:10
43:3 44:23 47:17 49:10
52:2 62:22 64:6 65:4 68:
18,22 74:3 75:3,15 76:3
mess [1] 89:16
met [1] 80:13
metal [1] 32:11
metals [1] 18:19
meter [1] 71:11
meters [1] 56:20
Metropolis [2] 16:17 18:4
Michael [1] 6:18
micro-Curies [1] 57:6
microphone [2] 10:12,14
middle [1] 51:5
Midnite [7] 11:3 20:23 75:
15,23 79:8 84:18,18
might [13] 12:19 14:22 19:
25 20:1 27:7 39:15 46:3,6
66:21 70:7 89:7 91:9,20
migration [2] 68:21 84:4
Mill [58] 3:2 8:1,18,24 11:9
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 9 Mill - ores
12:2 13:11 14:15,18,19
18:8 19:24 26:19 37:18
38:2,9,15,18 39:6,22 43:3
44:23,24 45:10 47:17,17
51:9,10,17,25 52:2 54:6,
17 57:3,10,22 60:25 62:22
64:5,6 65:4 67:4,13 68:1,
5,18,22 73:23,24 74:3,13
75:3,15 76:3 80:14,17 81:
12 84:8
milligrams [6] 29:10 81:
11,12,17,18,20
milliliter [1] 57:6
millirem [3] 61:20 62:3,9
mills [2] 7:20 74:17
mill's [2] 65:5 74:15
mind [2] 52:20 75:18
Mine [11] 11:3 20:23 32:4
49:16 67:25 68:2 75:15,
23 79:9 84:18,19
mined [1] 8:21
mines [1] 11:12
minimal [2] 33:20 89:5
minimize [3] 73:10 85:21
88:2
minimum [3] 30:6,20,24
Mining [19] 13:13 40:17 46:
20 48:21 49:12,14,17 52:8
54:10 57:2,4 63:18 66:9
71:18 75:13,22 80:21 86:
20 89:20
minus [1] 23:19
mitigate [1] 27:2
mixing [1] 25:20
ML [1] 17:6
Moab [1] 3:1
modeling [1] 15:13
modifications [1] 66:7
modules [1] 12:23
moisture [4] 85:21 86:24
87:5 88:2
moment [1] 11:20
monazite [1] 51:19
monitor [2] 11:25 82:15
Monitoring [13] 24:21 54:
3 65:4,6,8,10 69:8 73:2
75:6 80:17,18 82:3 83:22
Monthly [1] 69:7
moot [1] 44:15
morning [1] 3:6
most [9] 4:11 28:18 36:1
40:12 43:12,20 51:2,16
62:18
move [7] 2:17 5:4 13:5 44:
17 45:14 64:12 90:16
moving [1] 45:11
MSHA [4] 67:25 68:4,4,7
much [8] 13:23 15:1 31:10
51:15 57:9 72:2,3 77:4
Muskogee [1] 46:17
must [1] 11:4
myself [1] 83:3
N
name [8] 2:6,25 7:17 10:17,
17,20,23 15:17
National [2] 42:25 59:1
natural [7] 8:20 40:2 62:25
63:4 65:11,11 72:23
naturally [2] 57:16,19
nature [3] 56:9 57:7 65:20
NCR [1] 14:20
NCRP [1] 40:1
necessarily [2] 19:9 67:
12
necessary [4] 17:16 54:
13 80:9 86:1
need [21] 20:2 21:5,24 27:
1,7 29:2 31:8,9 45:14 47:
22,23 48:6 57:23 60:3,11
65:22 73:11 85:20 87:2
89:8,10
needed [1] 76:1
needs [2] 11:10 58:4
negligible [3] 60:21,22 81:
22
neutral [1] 66:22
never [4] 17:14 44:25 62:2
87:17
new [4] 19:16 51:18 70:13
84:23
newer [2] 15:24 16:5
News [1] 5:9
next [20] 11:19,21 13:8 14:
13 18:6 20:14,24 22:8 31:
21 39:17 41:23 44:8 61:
21,22 62:9,9,11 77:22 90:
20 92:2
nice [2] 51:22 60:8
noncompliance [1] 70:9
none [2] 7:4 73:25
nonetheless [1] 61:15
normal [1] 88:8
normally [2] 25:17 34:19
noted [1] 2:10
notice [2] 2:11 5:7
noticed [1] 3:23
notwithstanding [2] 4:
19 26:17
November [2] 58:14 59:
12
NRC [30] 8:7,17 9:4 14:7,
25 15:21 17:4 18:10 26:
14 28:22 40:23 41:14,23
42:1,25 43:1,9 44:15 46:6
47:1 49:22 57:21 58:12
59:5,9,11,18 60:7 68:9 74:
14
NRC/DEQ [1] 19:16
NRC's [2] 9:6 47:3
Nuclear [1] 5:17
number [10] 3:2 12:15 19:
4 31:1 62:12,19 65:17 79:
4 80:10 86:21
numbers [6] 15:3,12 17:2,
6 56:6,12
O
objections [2] 3:19 4:20
observations [1] 12:7
obtain [1] 76:10
obviously [1] 70:10
Occupational [1] 67:21
occur [3] 66:13 85:11 88:
18
October [4] 2:1 5:15 92:4,
13
odd [1] 91:14
office [5] 5:13 8:8 10:19
17:23 25:1
officer [2] 2:7 15:18
off-site [2] 83:16 84:4
often [3] 12:6 59:5 67:5
okay [63] 5:2 8:14,16 9:5,
13 10:9,25 11:15,24 13:5
14:13 15:15 16:6 18:6 20:
19 22:7,7 23:5 24:1,9,13,
14 25:25 30:3 31:5,13,25
32:13 33:21 36:25 37:12
39:18,19 41:4 43:15 44:9
45:24 47:6 48:8 52:1 53:
19 58:5,22 59:10 60:19
62:22 76:18 77:3,19 78:8,
25 79:4 80:6 82:20 83:9,
15 84:13 85:16 86:6 87:
11 88:13 91:20 92:3
Oklahoma [1] 46:18
once [3] 20:3 81:12 86:21
One [33] 3:22 12:22 13:11,
23 15:7 17:9 20:7 21:2 25:
15 31:5,20,21,22 38:23 44:
11 46:22,23 47:7 48:16
56:18 61:13,17,20 66:7
69:6 72:16 74:10 75:17,
18 78:24,25 84:22 90:18
ones [8] 9:23 10:7 14:24
17:17 31:10 46:6 48:7 61:
13
one's [3] 11:19 89:1,2
ongoing [4] 21:13 22:2 47:
10 69:4
only [6] 21:17 30:15 37:21
59:10 62:1 78:24
Ontario [1] 19:8
open [2] 2:15 7:5
Operating [8] 15:18 26:19
42:20 52:2,23 85:17 89:9,
19
operation [2] 73:15 74:4
operations [2] 73:1 86:16
opinion [1] 76:5
opportunity [2] 7:16 92:8
oral [2] 92:6,9
order [4] 7:5 65:23 76:2 77:
23
ordinary [1] 69:25
ore [23] 8:20 11:8,10 18:17
19:7 22:18 27:22 33:3 39:
25 51:15 52:3,6,17 70:13
73:12,16,23 84:24 85:6,19
86:21 87:6 90:2
ore,' [1] 7:24
ore-derived [2] 37:18 39:
21
ores [50] 11:12 13:2 27:19
33:5,10 34:13,16,18 39:16
40:3,9,12,13,22 41:11 44:
21 48:21 49:15,15,18 50:1,
4,15,17,20,22,25 51:2,22,
24 52:10 53:24 54:11,16,
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 10 ores - processing
17,20 55:18,22 56:4 61:8
62:25 63:4 65:12,25 67:3,
20 70:1 71:9,25 73:24
organic [1] 18:19
original [5] 4:6 21:19 22:3
33:11 55:20
Originally [3] 8:4 20:18
34:14
OSHA [1] 68:4
other [55] 5:3 7:3 8:22 11:
8 12:17,21 13:5,22 20:7,
25 26:5,18 27:7,20 28:3,7,
13 29:11,16 31:6,10,10,22
32:12 33:3,23 35:22 36:
16,18 37:2 40:22 46:6 48:
7,9 49:21 55:4,8 59:11 60:
24 62:25 63:4 69:20,24
71:23 72:8,23 74:21 79:
25 82:14,15,17 89:2,21 90:
14 91:5
out [47] 12:4,14,20 14:5 15:
3,5 17:17 22:24 23:8,16
24:6 25:17 32:20 37:7,10
38:13 42:11 44:11 48:2,5
58:19 65:15 66:5 67:10
70:18 71:4,4 73:8 77:10
79:15 80:1 81:25 82:1,16
83:24 84:10,11,25 85:15,
21,21 86:16 87:1,20 89:7,
23 91:5
outer [1] 61:20
outside [5] 47:23 64:17,20
66:1 84:19
over [22] 3:21 4:22 7:11 13:
24 19:20,22,24 20:4,12,13,
15,18 21:6,16 29:24 41:15
55:5 75:5 77:11 85:2 89:
18 90:9
overflowed [1] 89:16
P
p.m [2] 2:1 92:4
packet [1] 7:22
pad [8] 18:17 73:12,16 84:
25 85:6 86:21 87:7 90:2
pads [1] 85:19
page [7] 15:4 47:12 48:10,
25 53:21 60:20 84:16
paper [1] 17:22
paperwork [4] 12:8,11,17,
25
parents [2] 32:18 33:1
part [21] 2:18 7:22 16:20,
21,25 18:25 24:7,20 25:9,
18,18 27:15 36:21 44:19
47:20 51:12 59:20 66:3
69:1 80:12 89:9
partially [1] 55:18
particular [3] 13:13 27:21
71:20
particularly [2] 2:23 18:4
particulate [1] 56:24
parts [1] 69:20
paste [3] 3:25 4:3,9
patience [1] 77:4
Paul [1] 8:7
Pause [1] 54:8
PDF [1] 4:9
people [3] 77:20 91:5,6
per [27] 29:10,12 30:7,8,14
34:7,10 35:19 36:10,11
39:2,3,13 40:5,7,9 51:4
53:17 56:20 57:6 61:20,
25 71:11,11 81:11,12,20
perfect [1] 78:25
perform [1] 79:6
performance [1] 68:8
performed [1] 80:16
perhaps [2] 19:3 88:10
period [7] 4:16 5:6 19:24
65:10 68:8 85:11 87:2
periods [1] 88:14
permit [11] 6:14 24:7,20
66:5 73:5 75:7 83:6 85:25
86:5,8 89:4
permits [1] 76:10
perpetual [3] 55:10,15 62:
24
person [3] 61:22,23,25
phases [1] 15:21
physical [5] 18:8 20:12 22:
12,15 24:3
pick [1] 87:25
pico [14] 29:11 30:7,8,14
34:10 35:19 36:10,11 39:
2,13 40:6 51:3 53:17 71:
11
pics [2] 34:7 40:8
pilot [1] 34:2
place [8] 2:8,13 27:23 46:
13 47:20 81:1 82:18 89:
19
placement [1] 81:20
plan [3] 4:18 75:6 83:22
plans [2] 73:2,15
plant [1] 31:20
Plateau [15] 27:22 33:3 34:
13,16,17 41:11 44:21 50:4,
16 51:15,22,24 63:5 70:1,
13
Plateau's [3] 34:13 65:25
73:23
please [9] 6:10 10:11,14
56:11 58:6 63:1,22 74:8
88:16
plus [3] 22:5 23:19 50:7
point [16] 2:15,20 12:19,20
14:23 27:6,6 52:18 58:23
61:20 69:4 75:25 77:7 85:
16 89:7 90:13
pointing [1] 78:21
Policy [2] 42:25 59:1
polyethylene [1] 79:19
ponds [2] 21:2 46:16
pop [1] 19:21
Port [1] 57:17
possibility [2] 86:25 91:4
possible [2] 3:24 19:8
posted [2] 2:11 3:24
potential [9] 26:11,23,25
27:3 63:19 66:25 68:21
74:16 80:18
practical [4] 82:1 83:19
86:3,16
practices [2] 26:20 27:23
pre-'99 [1] 17:21
precisely [1] 4:7
preference [1] 78:5
prejudice [1] 7:1
preliminary [3] 5:6 9:10
68:23
prepared [5] 6:22 7:2 49:
11,22 78:16
presence [1] 63:11
present [5] 5:25 37:6 57:
15 65:2 81:8
presented [1] 39:8
presents [3] 7:16 49:3 56:
25
presiding [1] 2:6
press [2] 34:1,2
pretty [2] 17:3 82:10
previous [4] 14:25 33:6
41:9 68:7
previously [5] 5:21 11:13
40:22 63:12 67:4
previously-analyzed [1]
67:18
previously-approved
[4] 53:24 54:7 65:21 66:12
primarily [1] 15:25
primary [1] 32:17
prior [1] 14:7
proactive [1] 87:17
probably [10] 7:8 10:4 13:
2 22:14 31:7,8 36:1 43:20
45:2 65:16
problems [1] 84:20
procedural [2] 3:3 6:20
procedure [2] 7:8 42:20
procedures [7] 27:23 52:
3,23 57:3 85:17 89:9,19
proceed [3] 77:25 78:10
79:3
proceeding [4] 2:18,24 5:
5 90:14
proceedings [4] 3:12 77:
23 90:13 92:20
process [19] 11:2 13:20
14:18 15:13 21:4,13,14,15,
18 22:4 26:22 42:8 46:16,
23 47:11 57:13 60:14 79:
18 88:4
processed [32] 11:9 13:
19 14:15 15:2,8,11 16:3
22:19 23:4,13,14,19 45:1
46:22 47:16,19 48:2 49:
10,16 51:24 54:6 55:2,6
57:10,12 60:25 67:4,13,15
70:18 72:8 74:13
processes [1] 20:1
processing [45] 14:18 18:
11 22:10,20 23:7,20 24:17
25:2,7 26:21 28:3,13 37:3,
7 41:25 46:10 50:23 51:
19 54:1,17,25 55:9,11,15,
16,23 57:11,21 58:9 62:25
63:3 67:12 68:17 69:9 70:
5 73:20,22 74:6,7,16 75:1,
2 80:20 88:18,19
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 11 produce - remember
produce [1] 71:10
produced [2] 34:1 51:17
producing [1] 69:19
product [1] 32:1
products [7] 49:9 60:21,
22,23 61:2,3,5
Profile [2] 42:14,15
progeny [2] 34:18,23
program [12] 13:22 15:22
19:14,15,16,17,19 20:4,10
21:6,8 80:17
Programs [2] 8:9 54:3
project [1] 17:15
pronounced [1] 19:7
proposed [10] 2:17 5:10
20:8 26:12 41:8 63:8,13
66:18 74:20 79:8
protect [1] 82:22
protecting [1] 85:13
protection [3] 27:24 77:
17 80:11
protective [1] 27:2
protocols [1] 26:16
provide [6] 29:10 38:11
64:14 76:24 91:21 92:9
provided [11] 22:22 24:23
29:19,20,20 42:11 46:19
54:9 55:21 68:8,22
provides [2] 37:15 56:3
providing [1] 59:22
prudent [1] 21:21
public [16] 2:8,11,13 5:6
14:5 22:23 26:25 27:25
36:15 46:23 54:24 55:13
66:6 68:24 84:11 92:3
published [4] 2:12 5:8,8
68:20
pull [1] 53:4
purpose [2] 5:16,19
purposes [2] 43:20 56:18
push [1] 10:10
put [14] 4:25 14:6,12 15:3
22:23 48:16 72:8 73:9 84:
23 85:2,14 86:14 87:18
90:6
Q
Quality [4] 24:21 83:8 85:
24 86:7
quantities [6] 15:11,22 16:
4 17:13,17,19
quantity [6] 13:16 14:3,6,
10,22 16:2
quarterly [2] 12:4 65:5
question [55] 2:18 7:21,23
9:16 10:25 11:23 13:8 14:
13 16:7 18:6 22:8 23:24
28:17 29:8,24,25 30:1,25
31:25 32:23 35:3 37:20
38:14 39:17 41:16,23 44:
1,8,8,23 45:4,11,25 48:17,
19 52:13 53:20 54:19 60:
2 62:7 64:17 65:13 66:1,3
68:12 70:16 71:20 72:13
75:11 76:4,8 79:4,11 81:5
82:1
question-and-answer
[1] 60:14
questioning [1] 90:21
questions [36] 2:14 3:5,8,
16 5:20 6:1,2,5,15,23,23,
25 7:6,8,12,16 8:6,10 9:11,
18 11:13,22 13:6 19:20
44:14 45:17 46:3 48:9 60:
15 70:2 75:10 77:23 78:
17 90:10,12,15
quickly [1] 3:20
R
R31315 [1] 56:13
Radiation [6] 5:23 7:19 8:
2,19 10:21 79:5
radioactive [4] 11:6 33:11
42:13 74:15
radiologic [1] 79:13
radiological [13] 22:16
24:15 26:20 54:24 55:13
63:16,25 65:1 66:19 67:2,
17 73:18,21
radiologics [1] 18:18
Radionuclide [5] 30:5 32:
25 41:7 56:15 57:4
radionuclides [16] 29:11,
16 32:18 33:2 34:4 37:1
49:24 55:5,8 57:1 62:5 68:
16,21 69:24 70:11,12
radium [28] 33:23 34:6 35:
14,17,23 36:10,12,13,13,
16,18,21,22 37:22,23 38:6,
12,21,22,23,24 39:9,9 45:
7 53:22 69:24 71:9,24
radium-224 [1] 37:24
radium-226 [11] 32:23,24
34:4 35:1,12 36:11,12,17
37:16,21 38:19
radium-228 [6] 34:4,8 35:
4 36:7 37:24 39:2
radiums [1] 79:13
radon [22] 32:14,16,18,20,
21,22 33:7,8,13 53:25 55:
4,7 69:7,11,12,14,19,24
70:8 71:10,21 88:17
radon-219 [1] 33:14
radon-220 [1] 33:17
radon-222 [2] 32:20,22
RADs [1] 24:12
Range [13] 30:4 33:1 40:4,
8,15 44:20,20 50:14 53:17,
23 54:2,5,10
ranges [6] 34:12 40:14 49:
13,18 55:19,23
ranging [1] 34:7
rate [2] 44:21 56:20
rates [1] 62:6
RCRA [2] 18:18 21:16
reaction [1] 66:22
reactions [3] 63:19 66:13,
25
real [1] 84:1
reality [1] 28:17
realize [2] 9:15 85:3
really [13] 4:2,10 19:15 28:
24 44:11 45:4 48:5 51:15
70:13 76:21 78:24 80:9
91:3
reason [2] 33:6 87:14
reasonable [1] 87:25
recall [1] 53:4
receipt [6] 14:17 18:10 41:
24 42:20 74:5,25
receive [7] 2:13 5:20 7:6
13:15 22:17 46:16 62:8
received [16] 3:6 4:18 6:5
12:1 13:10,18 14:15 16:2
17:14 18:8 22:9 44:12,13,
25 47:19 86:23
receiving [5] 19:3 25:6,8
89:1,2
recent [1] 69:7
reciting [2] 7:14,15
recollect [1] 85:25
Record [6] 5:9 6:6,14 42:
14,15 91:25
recorded [1] 6:11
recording [2] 10:12,15
records [3] 17:3,5 89:25
reevaluate [1] 21:22
refer [3] 8:7 38:3 52:19
reference [1] 67:24
referenced [1] 56:16
referencing [1] 32:12
referring [5] 4:8 32:19 41:
6 69:6 77:15
refers [4] 42:5 54:15 58:16
67:21
reflects [1] 63:11
regarding [17] 3:22 5:21 7:
23 22:10 27:7 33:7 37:15
40:21 42:16,18 46:19 48:
9 54:12 56:3 71:20 80:3
88:22
regards [1] 45:25
regen [5] 56:8 57:8,13,18
58:10
Region [4] 77:8,12,13,18
regulated [2] 55:3 75:24
regulation [6] 9:1 59:9,19,
20 68:2 83:7
regulations [3] 55:4 57:2
67:22
Regulatory [6] 5:17 19:15
60:8 69:13 76:1 83:15
reiterate [1] 10:10
relate [1] 45:8
related [3] 8:21 74:6 75:1
relatively [2] 86:24 87:5
release [1] 73:16
releases [2] 27:8 69:15
releasing [1] 69:12
relevant [12] 3:8,11,16,20
6:3 45:5 52:7 61:14 64:2,
24 71:21 72:7
reliance [1] 44:23
relied [2] 21:19 55:18
relies [1] 41:12
rely [1] 22:2
relying [1] 9:5
remain [3] 14:3 37:2 81:13
remember [3] 61:13 79:1
87:8
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 12 remote - sitting
remote [1] 87:1
remove [1] 64:12
removed [1] 46:2
renewal [14] 14:2,2,4 15:
12,13 17:11 43:5 46:1 68:
10 69:1,3 74:11 83:20 84:
3
repeat [2] 57:23 92:1
repeated [1] 29:5
repeatedly [1] 67:1
Report [23] 5:12 15:4 22:
23 26:1 29:9 32:11 35:9
36:6 37:14 42:3,5 49:21
56:2,3 58:14,16 59:6 68:
20 69:8 74:19 83:17 84:
15,20
reported [7] 32:9 34:5,9,
11 36:8 39:12 40:17
reporting [1] 32:6
reports [1] 65:6
representatives [1] 5:24
representing [1] 10:19
request [20] 11:4 13:13 18:
15,25,25 19:2 28:6 42:10
46:21 47:10 49:13,23 61:
11 63:6 64:3,18,21,25 66:
16 76:23
requested [1] 6:24
requests [2] 15:23,24
require [4] 11:12,17 18:21
54:23
required [12] 18:11,12 21:
21 24:20 26:3 43:22,24
44:1 66:5 71:12 75:22 88:
16
requirement [2] 61:11 86:
20
requirements [4] 5:18 26:
15 47:22 73:8
requiring [2] 74:18 82:8
reserve [1] 29:2
residents [1] 92:8
residuals [5] 26:22 57:17,
19 63:12 80:20
resolve [1] 46:4
Resources [2] 11:1 15:19
respect [2] 40:23 43:21
respective [1] 65:9
respond [6] 4:15 9:14,17
15:16 25:13 75:16
responding [3] 6:20 9:23
10:1
response [12] 8:10 9:10
29:3 36:10 38:4 42:16,18
47:25 54:18 67:23 79:3
91:8
responses [1] 6:5
responsibility [2] 13:17
14:11
rest [1] 5:4
result [4] 24:16 66:14 68:3
70:8
resulting [6] 7:1 26:12 37:
6 53:25 80:19,20
results [10] 29:18 30:6 31:
4,19 32:9 34:5 36:7 51:4
56:17 79:9
retrieving [1] 32:8
review [10] 7:16 12:19 39:
14 41:19 43:10 47:3,11
66:4 68:23 90:3
reviewed [11] 14:5 41:16,
22 46:8,12,15,22,25 52:2,
22 65:20
reviewing [2] 4:5 47:8
reviews [2] 46:13 69:3
revise [1] 83:21
revised [1] 65:23
risks [2] 55:7 61:4
River [1] 57:20
RMRP [1] 42:12
road [2] 71:24 88:8
ROBERTS [7] 15:16,17
25:13,14 86:18,19 87:10
rules [3] 5:1 56:19 83:8
run [1] 84:8
Rusty [3] 10:20 21:11 77:5
S
safely [1] 26:20
Safety [13] 5:11 26:1 28:21
29:8 36:6 37:14 56:1,2 67:
22,25 68:2 74:4 82:22
Salt [5] 2:1 5:8 73:9 81:3
89:11
same [11] 8:6 18:8 23:16
33:4,8 37:6,9 45:25 48:19
55:23 66:23
sample [4] 18:17 20:11 21:
3 34:7
sampled [1] 20:17
samples [8] 18:15 24:6,22
31:20 34:1 36:19 38:24
80:16
sampling [10] 12:25 18:12,
14,22,23 20:3,3 21:5 63:
11 75:5
San [1] 5:9
sands [1] 51:19
Sarah [12] 2:25 4:18 7:21
9:8 10:23 19:11 45:12 46:
18 61:17 70:15 76:19 90:
19
Sarah's [1] 7:9
saying [5] 40:24 43:17,18
71:9 82:11
says [2] 52:21 85:2
scheduled [1] 2:8
scientific [1] 29:14
scope [8] 6:2 28:6 40:25
49:23 55:19 64:18,21 66:
2
Seattle [1] 77:10
second [1] 71:11
section [8] 4:3,5 22:24 25:
25 29:7 37:13 41:5 48:9
sections [2] 3:25 74:8
secular [1] 40:13
see [20] 4:21 16:12,22 30:6
31:20 33:4,8 34:12,15 50:
15 51:13 76:9 77:1 79:15
82:18 83:25 84:14 86:16
89:10 90:3
seeing [2] 45:19 91:22
seeking [1] 3:10
seem [3] 19:21 29:23 36:
20
seemed [1] 30:16
seems [3] 30:17 36:22 78:
16
seen [1] 52:24
selected [2] 56:4 64:4
semiannually [1] 68:5
Senior [1] 75:20
sense [2] 30:23 62:12
sensitive [1] 87:24
sent [2] 45:3 91:7
September [1] 5:7
Sequoia [1] 47:9
SER [29] 26:2,4,7 28:11 31:
14 32:10 33:22 34:6 39:
12 40:19 41:6 48:9,10 49:
2,6,11 53:20 54:20 55:12
60:19 67:1,5,13,21,24 68:
11 72:24 81:8 84:8
series [1] 61:7
seriously [1] 13:3
seven [2] 85:1 87:9
seven-day [3] 85:9,9,11
several [2] 32:20 78:16
shape [1] 17:6
shared [1] 68:23
sheet [1] 6:7
ship [1] 19:24
shipment [5] 12:5,7,9,15,
17
shipments [5] 11:25 12:
11,18 13:4 62:5
shipped [1] 20:15
shippers [1] 62:19
shipping [1] 61:24
short [1] 33:19
Shouldn't [2] 37:23 87:19
show [1] 51:5
showing [1] 84:12
shown [1] 40:10
shows [1] 76:25
shut [2] 91:1,2
shutdown [1] 91:14
sic [2] 43:7 56:8
sign [1] 6:8
Signal [1] 16:17
signed [1] 6:9
significant [1] 3:17
sign-in [1] 6:7
silence [1] 59:24
similar [7] 40:14 49:18,25
50:3 55:17 67:3 79:14
similarities [1] 78:19
similarity [1] 67:14
Simple [2] 29:14,18
Simply [1] 11:4
since [4] 10:12 40:12 45:1
52:8
sit [2] 84:25 87:20
site [18] 2:12 3:24 5:8,12
12:4,22 16:16 18:13 20:
20 21:2 48:1 65:6 75:23
76:3,12 79:9 80:18 86:23
sitting [3] 40:11 70:19 85:
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 13 sitting - thorium-228
6
situation [1] 70:9
six [1] 64:22
skipping [1] 11:21
slimes [1] 24:10
sludge [1] 36:8
slurry [2] 25:18 71:7
smaller [1] 39:4
soils [1] 64:15
solely [1] 9:6
solids [1] 25:18
solubility [2] 81:9,14
solution [1] 25:18
solutions [3] 81:4,17,19
somebody [2] 15:10 76:
16
someone [3] 11:18 36:15
38:17
sometime [1] 70:7
Sometimes [3] 20:19,21
43:4
somewhat [1] 6:21
somewhere [1] 51:3
soon [2] 6:9 15:14
SOP [5] 52:5,7,21 53:3,4
SOPs [5] 47:23 52:17 73:9,
15 89:23
sorry [11] 7:10 12:9 29:22
58:25 59:13 64:17 67:9
72:17,19 81:6 83:14
source [15] 8:23 13:11,24
14:16,19 15:7 16:22 19:
25 22:11 46:16 56:9 57:7,
23 64:14 70:7
SPEAKER [6] 42:13 58:1
60:4 72:18 77:20 78:7
speaking [1] 91:16
spec [1] 79:25
specific [26] 14:15 15:22
16:10,12,16,18 20:20,20
25:9,16 48:11 52:18 53:3
57:4 58:25 59:14,16,19
63:1,23 74:20 75:13,25
79:11 80:2,4
specifically [8] 3:11 19:6
25:15,22 28:10 74:17 82:
13 86:19
specifics [1] 80:8
specified [1] 16:4
specifies [1] 89:5
specify [2] 16:1,15
splitting [1] 87:12
spoke [1] 6:9
spot [1] 13:3
stable [2] 32:5,11
staff [6] 4:5 5:22 12:14 29:
23 78:6 90:5
standard [11] 21:11 22:1,
5 42:20 52:2,23 62:3 69:
13 82:25 85:17 89:18
standards [3] 65:3 73:4
80:12
stands [1] 81:1
start [3] 7:9,14 78:1
starting [2] 27:6,6
state [13] 5:17 7:20 8:6,8
14:8 15:3,25 22:23 26:14
60:10 76:22 77:11 83:8
stated [2] 50:13 54:18
Statement [6] 5:11 43:3
54:20 70:16 71:2,3
statements [4] 28:9 43:2
70:25 71:2
state-of-the-art [1] 64:9
states [3] 53:21 60:20 67:1
stating [1] 43:25
stations [1] 83:23
status [3] 68:6,7 90:22
staying [1] 17:18
steps [2] 83:19 84:6
stick [1] 10:5
still [9] 2:24 3:20 29:8 37:
13 46:5 61:16 71:10,25
87:4
stops [1] 62:20
storage [13] 18:17 26:21
55:9,14 62:24 73:12 74:5,
6,25 75:1 84:24 85:19 90:
2
storm [2] 88:22 89:14
stratabound [1] 50:23
stringent [1] 88:9
strip [2] 54:11 89:21
stuff [2] 84:21 85:3
SUA1358 [1] 57:23
subject [4] 18:14 28:20 43:
1 68:1
submission [1] 74:18
submit [3] 2:22 6:1 16:1
submittal [3] 3:5 11:14 42:
19
submitted [13] 5:21 6:24
7:22 11:1 36:6 41:14 42:6
58:11 63:6 66:16 70:1 90:
12,16
Subpart [3] 69:7 71:12,20
subsequently [1] 7:25
suffice [1] 81:23
sufficiently [1] 26:10
sulfate [4] 81:9,9,13,14
sulfide [1] 81:16
sulfuric [2] 81:11,15
sum [1] 48:13
summarize [1] 8:17
summarizes [1] 41:9
support [1] 49:11
suppose [1] 90:15
supposed [1] 80:1
suppression [1] 90:1
surface [4] 61:21 62:10,16
72:3
surprised [1] 90:21
surrogate [1] 66:8
surrogates [1] 82:14
surrounding [1] 64:15
Survey's [1] 68:20
susceptible [1] 87:6
system [3] 36:9 72:2 79:
21
systems [7] 63:8,20 64:8,
9 79:22,24,25
T
table [45] 3:17 29:9,25 30:
4 31:2,10,12,15,25 32:2,
10,12,13 34:5 37:15,15,20,
23 38:8 39:12,19 40:18,19
41:6,6,9,12 44:19 48:23,
24,25 49:2 50:13,18 51:8,
23 56:3,5,6,7,12,22,25 83:
5 91:22
tables [1] 51:13
tabulation [1] 65:7
tailing [15] 23:8 25:6,15,19,
20 26:23 38:12 63:8,15,19
66:14,25 72:9 73:11 81:
17
Tailings [35] 8:1,19 23:16,
20 24:16,21 25:2,17 37:18
38:2,10,15,18 39:6,22 42:
17,18 51:10 62:23 63:10
64:5,14 66:15 68:18 69:
18,20,24,25 70:12 72:22,
25 73:17,19 81:19 88:14
tails [16] 24:6 25:6 27:17
37:8,11 66:20 70:18 71:
22 73:4 79:16 84:21 88:
16 89:2,6,12 90:2
talked [3] 47:25 76:21 77:7
talks [2] 15:7 46:1
TAPP [26] 78:2,11,11,23,
25 79:2 80:6,22 81:6,25
82:20,24 83:2,9,13 84:5,
13 85:8,23 86:10 87:12
88:7 90:8 91:11,13 92:19
Technical [9] 42:3,4,6 43:
8 49:20 58:14,15,17 59:5
technology [3] 64:9 73:4
79:23
temporary [1] 26:21
ten [6] 4:24 6:21 7:2 19:24
20:24 64:23
TER [3] 58:23 59:4,8
terms [6] 6:20 21:12 77:23
82:4 85:12 86:1
testing [8] 33:25 34:2 36:8
79:5,9,12 80:3,10
themselves [2] 17:2 44:2
theoretical [1] 62:7
Therefore [8] 25:6 32:6,
12 40:7 41:2 49:19 54:12
55:25
there's [29] 3:20 6:24 7:1
13:6 17:8 25:19 28:15 31:
15 35:18 42:8 43:2 44:16
46:6 51:12 53:3 58:17 65:
16 70:10 73:6,6 76:9 78:
18 80:25 82:14,17 85:19
87:18 88:21 91:4
they've [3] 27:16 40:21 87:
17
thinking [2] 19:6 31:11
thorium [29] 8:24 30:11,12
31:18 32:2,7 37:22 38:6
39:11 42:17,19 45:8 48:
12,12 50:10 51:2,11,16,18,
21 52:3,6,16,17 53:8,16,
22 60:23 61:3
thorium-228 [18] 30:8,9,
15,18,24 31:18 37:5 39:5,
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 14 thorium-228 - White
24 40:15 48:13,15,23 49:3,
6 50:6,14,20
thorium-230 [5] 32:24 37:
4,17 38:18 49:4
thorium-232 [33] 30:12,
14,16 31:12,21 33:13 34:
18,23,23 36:20 37:5 39:9,
12,15,23 40:2,9,16 48:11,
13,20 49:3,8,14 50:3,12,
14,19 51:11,16 60:20 61:5,
7
thorium-242 [1] 30:7
thoriums [1] 51:4
though [3] 36:20 67:24 80:
3
three [3] 31:19 79:1 89:5
throughout [1] 20:24
throw [1] 36:23
tight [1] 6:22
timing [1] 84:5
today [10] 5:1,5 6:1,25 9:
22,24 17:23 43:23 78:14
92:16
together [1] 50:10
tons [4] 16:10 57:11,14,14
took [1] 36:1
top [2] 70:20 88:24
topical [1] 17:7
total [25] 15:8 23:2,3,4 32:
9 33:24 35:10,10,14,17,21,
23 36:10,12,12,22 37:16,
25 38:18,23 48:11 50:10
51:11 57:12,13
tough [1] 82:10
towards [1] 15:5
trace [1] 68:21
track [3] 13:17 24:2 25:1
transcript [4] 6:12 10:13
58:2,19
transfer [3] 75:14,23 76:2
transmitting [1] 42:11
transportation [3] 55:9,
14 62:15
transported [1] 87:23
treated [1] 8:21
treating [1] 9:10
treatment [1] 31:19
Tribal [1] 8:8
tribe [2] 90:19 91:17
Tribune [1] 5:9
tried [1] 91:5
trigger [3] 52:5,16 53:3
tri-party [1] 68:3
truck [2] 85:18,20
True [2] 45:22 60:1
Trust [2] 77:24 78:12
trying [5] 17:4 19:18 20:9
21:7 78:14
turn [2] 7:11 90:9
two [5] 8:10 11:13 20:15
46:21 64:22
type [8] 4:8 18:11,21 19:10
21:8 50:21,22 89:11
types [4] 19:4 66:13 80:1
86:4
typical [15] 33:2 34:12 38:
2,9,14,17 39:6,16 40:9 48:
21 50:15,16 51:9 52:10
55:19
Typically [10] 12:3 29:13,
17 33:4 34:15 40:4 50:22
53:16 85:6 88:23
U
U.S [3] 5:18 68:19 77:17
U.S.C.2021(o)(3)(C [1]
26:8
UCA [1] 54:22
UF4 [5] 56:7 57:8,11,16 58:
10
ultimate [1] 21:25
unable [1] 55:1
U-natural [1] 45:8
under [21] 5:18 16:3 22:24
35:10,10,13 42:24 43:11,
22 46:23 47:11,12 55:3
56:17 57:22 59:1,9,18,19
75:24,24
undergo [1] 28:18
understand [6] 18:1 29:
23 30:23 71:8 86:10,13
understanding [6] 19:18,
19 30:10 43:9 44:13 51:
14
undertaken [3] 5:16 26:6
80:10
UNIDENTIFIED [6] 42:13
58:1 60:4 72:18 77:20 78:
7
units [3] 29:13,19 57:5
unless [1] 89:22
unsure [1] 91:14
until [3] 4:21 5:14 87:1
unusual [1] 66:23
up [15] 17:2 18:5 19:21 20:
1 45:3 60:12 61:24 64:21,
23 70:14 82:9 86:17 87:
25 88:2 91:9
Uranium [79] 2:25 7:20 8:
1,18,24 10:24 11:3,3 23:
19 29:10,15 30:5 32:8,14,
17 33:24 34:24 37:2,7,16,
17,18,25 38:1,2,8,9,15,17,
18 39:6,16,20,22,24 40:3,
9,12,13,18 41:8,10 42:7
47:15,17 48:21 49:12,15,
17 50:15,23,24 51:9,10 52:
4,8,9 53:21,23 54:1,25 55:
6,10,16 57:1 60:24 61:3
63:17 64:1 65:2,12 67:2
73:20 74:17 75:14 80:4,
21 81:8,21
uranium-2 [1] 38:19
uranium-238 [1] 32:1
uranium-bearing [2] 57:
16,19
URS [3] 5:23 39:7 48:18
USGS [3] 83:17 84:15,20
using [4] 32:7 44:19 45:4
46:4
USNRC [1] 68:4
USRA [1] 50:5
UT1900479 [1] 2:10
Utah [15] 2:1 3:1 7:20 15:
25 26:14 37:19 38:2,9,14,
17 39:6,22,25 51:9 79:5
V
vague [1] 3:9
value [1] 14:22
values [4] 50:12 56:22,25
57:5
various [2] 28:9 45:7
vary [2] 40:3 50:20
vast [1] 28:19
vehicle [1] 61:19
verification [3] 18:11 19:
22 21:6
verify [3] 20:4,11,16
versus [1] 37:17
Vice-President [1] 15:18
visible [1] 89:10
visual [1] 12:7
VOCs [1] 18:20
volatile [1] 18:19
VP [1] 75:20
W
W.R [7] 41:13,17,25 42:9
44:14 46:2,4
wanted [6] 4:17,24 9:9 77:
14 86:12 90:18
wants [2] 15:10 89:22
Washington [4] 76:5,22
77:11,16
waste [34] 7:19 19:10 20:
19,20,21 21:4,12,13,15,17,
22,23 22:2,4,10,13,17,20
23:2,3,3,6,8 24:4,21 51:16,
21 63:3 64:5 69:9 70:7 79:
24 88:18,18
wastes [7] 24:17 55:11,16
62:24 68:17 69:18 88:19
Watch [2] 2:25 10:24
Water [19] 24:21 65:11 72:
2 73:9,9 81:10,10 85:18,
18,20 88:1,15,15 89:8,11,
11,13 90:1,6
waters [1] 69:14
way [8] 28:8 30:16,21,21
39:14 75:6 78:3 91:17
ways [1] 91:15
Web [9] 2:12 3:24 5:8,12
15:4 47:12 65:6 83:25 84:
16
week [1] 90:20
weeks [1] 2:24
Welcome [1] 2:5
wells [1] 65:4
whatever [1] 9:6
whatnot [1] 84:12
Whenever [1] 84:7
whether [21] 14:14 16:10
21:22 43:25,25 44:1,12
45:7 47:18,25 49:20 52:4
54:11 65:22 80:11 89:19
90:1,2,5,22 91:18
White [17] 3:1 12:1 13:10
43:3 44:23 47:17 49:10
52:2 62:22 64:6 65:4 68:
Division of Radiation Control Public Meeting * October 9, 2013
Sheet 15 White - ZODY
18,22 74:3 75:3,15 76:3
who'd [1] 2:16
whoever's [1] 4:5
whole [2] 19:14 89:13
will [50] 3:19 4:12 5:14 6:3,
5,12,13 7:4 9:10 10:1 11:
18 12:6,16 13:14,16,17,19
14:3 15:16 16:25 17:18
20:22 25:11 37:1,8 45:2
50:20 52:4 55:3,5 62:2 64:
12,19,19 69:2 71:18 73:19
78:3 80:10,16 85:2 86:23
87:3 88:15 91:4 92:4,5,6,
7,12
wind [1] 72:23
windblown [2] 86:25 87:6
window [2] 85:10 88:10
winds [4] 85:10,20 86:17
87:25
wish [1] 77:24
within [11] 7:18 20:14 33:1
41:1 52:10 54:2,10 55:19
67:17 69:15 70:19
without [3] 11:9 26:23 88:
14
wonder [1] 19:12
wondered [5] 16:19 38:10,
20 39:5 76:20
wondering [2] 20:16 91:
23
word [1] 67:10
words [3] 33:3 74:21 79:
25
work [3] 21:20 56:17,19
workers [2] 26:25 56:25
working [4] 14:1 56:16 83:
19,23
works [1] 19:22
world [1] 21:16
worries [1] 82:17
worthwhile [1] 92:1
write [1] 60:15
written [6] 5:14 90:12 91:
21 92:6,9,11
Y
yards [1] 16:11
year [10] 12:20 15:1,5,9 20:
3,14 22:19 56:16,21 84:10
years [15] 3:2 13:24 19:2,6,
23,24 20:5,13,18,24 22:5
41:15 45:1 64:22,23
yourself [2] 61:18 78:10
Z
zero [1] 82:9
ZODY [4] 6:16,17,18,19