DRC-2014-006563 - 0901a068804b59a3

DRC-2014-006563
Residuals Management Plan
for the Midnite Mine Water Treatment Plant
Revision 10 >4%
Midnite Mine
Superf und Site
November 1,2013
•4
Prepared For
Newmont USA Ltd.
6363 South Fiddler's Green Circle
Greenwood Village, Colorado 80111
and
Dawn Mining Company
P.O. Box 250
Ford, Washington 99013
Prepared By:
Worthington Miller Environmental, LLC
201 Linden Street, Suite 301
Fort Collins, Colorado 80524
TABLE OF CONTENTS
1.0 INTRODUCTION 1
2.0 PRIMARY ALTERNATIVE: CURRENT WTP PROCESS AND PROCESSING OF
SLUDGE AT ENERGY FUELS 6
2.1 Facility Description 6
2.2 Residuals Handling 7
2.3 Containers 7
2.4 Transportation 7
2.5 Off-Site Rule Verification 8
2.6 Cost Estimate 8
3.0 CONTINGENCY ALTERNATIVE: DISPOSAL AT THE RICHLAND FACILITY 9
3.1 Facility Description 9
3.2 Residuals Handling 10
3.3 Containers 10
3.4 Transportation 11
3.5 Off-Site Rule Verification 12
3.6 Cost Estimate 12
4.0 POST-2014 ALTERNATIVE ONE: MODIFICATION OF WTP PROCESS TO
REMOVE URANIUM THROUGH ION-EXCHANGE WITH OFF-SITE ION-EXCHANGE
RESIN PROCESSING 13
4.1 Option Description 14
4.2 Materials Handling and Transport 15
4.3 Cost Estimate 15
4.4 Off-Site Rule Verification 16
5.0 POST-2014 ALTERNATIVE TWO: MODIFICATION OF WTP PROCESS TO
REMOVE URANIUM THROUGH ION-EXCHANGE WITH ON-SITE ION-EXCHANGE
RESIN PROCESSING 17
5.1 Option Description 18
5.2 Materials Handling and Transport 19
5.3 Cost Estimate 19
5.4 Off-Site Rule Verification 20
6.0 SUMMARY 21
7.0 REFERENCES 22
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LIST OF TABLES
Table 1. Options Summary
LIST OF FIGURES
Figure 1. Key 2014 Activities Decision Chart
Figure 2. RMP Decision Chart Post-2014
LIST OF ATTACHMENTS
ATTACHMENT 1 US ECOLOGY RICHLAND MATERIALS
1.1 Water Treatment Plant Residuals "Waste Profile"
1.2 US Ecology Low-Level Radioactive Waste Generator Registration
1.3 Washington State Site Use Permit
1.4 US Ecology Radioactive Materials License
1.5 US Ecology Waste Acceptance Criteria
1.6 WDOH concurrence regarding WTP residuals status as source material,
12/20/10 e-mail from Mike Elsen and 12/31/08 letter from WDOH
1.7 NRC Director's Decision, dated March 26,1999
ATTACHMENT 2 RESIDUALS TRANSPORTATION PLAN FOR THE MIDNITE MINE WATER
TREATMENT PLANT
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LIST OF ACRONYMS
CD Consent Decree
CERCLA Comprehensive Environmental Response Compensation and Liability Act
DMC Dawn Mining Company
DOT United States Department of Transportation
EPA United States Environmental Protection Agency
ESD Explanation of Significant Difference
NRC United States Nuclear Regulatory Agency
NWIC Northwest Interstate Compact
RML Radioactive Material License
RMP Residuals Management Plan
ROD Record of Decision
RTP Residuals Transportation Plan
SDs Settling Defendants
SOW Statement of Work
UAO Unilateral Administrative Order
WTP Water Treatment Plant
WDOH Washington Department of Health
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1.0 INTRODUCTION
On November 7, 2008, Region 10 of the United States Environmental Protection Agency (EPA)
issued to Newmont USA Limited (Newmont) and Dawn Mining Company (DMC) a Unilateral
Administrative Order (UAO) for Phase I Remedial Design and Remedial Action, EPA Docket No.
Comprehensive Environmental Response Compensation and Liability Act (CERCLA) -10-2009-0026
(UAO; EPA, 2009) with an attached Statement of Work (SOW) (EPA, 2008). The subsequent
Consent Decree (CD) with its associated Statement of Work (CD-SOW) which became effective on
January 17, 2012 incorporates the requirements of the UAO into the CD.
As part of the prescribed Phase I Remedial Design and Remedial Action, the SOW requires the
submission of a draft Residuals Management Plan (RMP) to address disposal of residual materials
(sludge) from the water treatment plant (WTP) at the Midnite Mine, near Wellpinit, Washington.
Specifically, SOW requirements for the RMP are as follows:
Manage Residuals (Record of Decision (ROD) Section 12.2.3)
In compliance with the ROD (including Section 12.2.3) and applicable regulations, Respondents shall
manage all residuals generated by water treatment. Continued disposal of WTP residuals at the Dawn Mill
would require amendment of the Mill License, which may not be possible in time for the stan of water
treatment in spring 2009. Respondents shall implement necessary modifications to the WTP necessary to
dispose of WTP residuals (sludge) at a commercial low-level radioactive waste facility (LLRW facility), and
dispose of WTP residuals in this manner unless and until arrangements for alternative disposal in
accordance with the ROD, the UAO, and this SOW are approved by EPA.
In accordance with the Schedule of Deliverables, Respondents shall submit a draft Residuals Management
Plan (RMP) for WTP residuals (sludge) disposal at a commercial low-level radioactive waste facility (LLRW
facility). The RMP shall identify applicable regulations for transport and disposal, disposal facility
requirements and WTP changes which will be needed to comply with facility disposal requirements.
For WTP changes necessary to meet disposal facility requirements (e.g. the addition of a filter press,
containerizing or solidification of residuals) the RMP shall include for EPA review and approval a plan and
schedule for pilot testing, submittal of design changes to EPA (see Section 3.4), and for implementation of
changes in water treatment and waste management practices necessary for residuals disposal at a LLRW
facility to commence when WTP operations resume no later than May 1, 2009. The RMP shall describe
how the resulting WTP residuals will comply with facility requirements and include cost estimates for system
modifications and unit costs for transport and disposal. Required treatment system changes shall comply
with the ROD and shall not adversely affect the now and pit drawdown rates, discharge water quality or
worker health and safety.
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The RMP shall also clearly indicate whether Respondents intend to evaluate other changes to the water
treatment process, such as the addition of an ion-exchange step, as provided in the ROD for purposes of
reducing overall costs. If so, the plan shall include for EPA review and approval a description of and
proposed schedule for the evaluation in accordance with Section 2.1.5 of this SOW, including a schedule for
submitting a draft treatability testing plan, reports, and design recommendations. Optional treatment system
changes shall comply with the ROD and shall not adversely affect the flow and pit drawdown rates,
discharge water quality, or worker health and safety.
In accordance with the ROD and SOW for the UAO, DMC submitted an initial draft RMP to EPA on
December 30, 2008. After receiving comments from EPA and the Spokane Tribe of Indians, DMC
submitted a revised draft RMP on April 10, 2009 (Miller Geotechnical Consultants, 2009). DMC
submitted another iteration of the draft RMP on March 11, 2011. EPA requested an update to the
RMP during a meeting in June 2011. A revised draft RMP submitted on August 8, 2011 responded
to this request. Additional information has been obtained after the August 2011 submittal which
necessitated a subsequent revision submitted on January 15, 2013. EPA provided comments on the
January 2013 revision and a subsequent revision incorporating changes was submitted on
March 22, 2013. In the March 4, 2013 comment letter from EPA, it was required that the RMP be
updated on an annual bases by November 1 of each year. This RMP revision has been developed to
meet that requirement and presents the disposal options that will be used in 2014 and the
alternatives that could be employed in subsequent years.
With this revised RMP, DMC and Newmont USA Limited, the Settling Defendants (SDs), propose a
staged approach to manage WTP sludge, utilizing two short-term alternatives and two additional
alternatives that could be used in the future. The SDs request that EPA approve this RMP as
consistent with the ROD and authorize the SDs to proceed with residuals management in
accordance with this plan. The proposed four alternatives are as follows:
Primary Alternative - Current WTP Process and Processing of Sludge at Energy Fuels
(formerly Denison): The primary alternative is to have Energy Fuels process the WTP sludge for
its source material content at the White Mesa Mill near Blanding, Utah. Energy Fuels has applied to
the State of Utah for an amendment to its Radioactive Material License (RML) to specifically permit
receipt and processing of the Midnite Mine WTP sludge. The State of Utah provided preliminary
approval of the amendment pending public comments, and final approval is anticipated by the end
of2013.
Management of WTP sludge by processing at Energy Fuels is a preferred alternative and it is
potentially an option for as long as the White Mesa Mill remains in operation, which could be many
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years. This alternative requires minimal change to the existing WTP facility operation, minimizes
additional worker exposure, and has the lowest cost. While final approval to allow Energy Fuels to
accept the material has not been granted by the State of Utah, it is anticipated that the license
amendment will be finalized before the 2014 water treatment season and will allow for the
material to be taken to the White Mesa Mill. Although processing by Energy Fuels is likely a viable
alternative, the SDs are prepared for the contingent action of taking the residuals to the US Ecology
facility near Richland, Washington, if necessary as discussed below and propose that other
alternatives be considered in the future as needed.
Contingency Alternative - Disposal at the US Ecology facility at Richland. Washington: The
contingency alternative is disposal of WTP sludge at US Ecology's Richland facility. This is the
disposal method that was utilized from May 2011 through July 2011, and the Richland facility is
expected to be available for disposal over the long-term. The facility does have a limit on the
amount of uranium that can be received; however, communications with WDOH and site personnel
indicate increasing this limit could be accomplished. As recognized in the ROD and the subsequent
UAO, other treatment alternatives should be and are being investigated and proposed for EPA
approval in this revised RMP. Nevertheless, the Richland facility would remain available on an
emergency basis if, for unforeseen reasons, none of the other alternatives were available.
Post-2014 Alternative One - Modification of Current WTP Process to Remove Uranium Using
Ion-Exchange with Off-Site Ion-Exchange Resin Processing: The first longer term alternative
which could be used after 2014 is to modify the existing WTP system by adding an ion-exchange
component to the WTP process and would require construction of new facilities. This component
would selectively remove uranium from the mine water before the chemical precipitation step
which produces sludge needing disposal. By removing uranium from the mine water before the
sludge is produced, the sludge would not have uranium concentrations in excess of
0.05 percent (%) and therefore would meet the requirements for disposal at the US Ecology facility
in Grand View, Idaho. Disposal costs at the Grand View facility are more cost-effective than at the
US Ecology Richland facility.
Under this alternative, the ion-exchange resin loaded with uranium would be transported to the
Cameco Resources (Cameco) Smith Ranch ISL Central Processing Plant in Wyoming for processing.
The process would remove the uranium from the resin and the resin would be transported back to
the Midnite Mine for subsequent use. Cameco has authority to accept ion-exchange resin from
water treatment facilities. Cameco completed a technical evaluation of the resin from the pilot scale
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testing program and has concluded that they can process the resin. The SDs are in negotiations
with Cameco for this alternative. However, those negotiations have not progressed to the point
where it is reasonable to proceed with the construction of the facilities on site to implement this
alternative. The design of the mobile ion-exchange system has been finalized. The CDs will
continue to work with Cameco to obtain an agreement and will construct the necessary
infrastructure to implement this alternative when the agreement has been reached and when it is
determined prudent given the viability of the option to deliver the residuals to the White Mesa Mill.
Post-2014 Alternative Two - Modification of WTP Process to Remove Uranium Using
Ion-Exchange with On-Site Ion-Exchange Resin Processing; The second long-term alternative
that could be implemented after 2014 is to modify the WTP process to remove uranium using
ion-exchange with on-site resin regeneration. This process, which has long been used in the
uranium industry and has been pilot tested at the WTP, would produce two waste streams—a low
volume, source material waste with uranium concentrations above 0.05%, and a high volume
effluent sludge waste (resulting from chemical precipitation treatment of water from which
uranium has been removed) with uranium concentrations below 0.05%. It is assumed that the low
volume source material waste would be disposed of at the US Ecology Richland facility.
The high volume effluent sludge waste resulting from chemical precipitation treatment of water
from which uranium has been removed would be disposed of at the US Ecology facility in Grand
View, Idaho. Disposal costs at the Grand View facility are more cost-effective than at the Richland
facility and a cost savings can therefore be realized, as compared to long-term disposal of all WTP
sludge at the Richland facility.
This alternative is not as attractive as the other alternatives as it requires the most change to the
existing WTP process, has the potential greatest exposure to workers, presents the most technical
and regulatory challenges, and is not as cost-effective as processing by Energy Fuels, or utilizing
Cameco for off-site resin regeneration. However, this alternative can be constructed and
implemented on-site and would be largely within the SDs' operational control, with minimal
reliance on third-party contractors. A preliminary design of this facility has been completed. This
added level of operational control would assure EPA and the SDs of a viable, long-term option for
management of WTP residuals.
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It is recognized that this alternative would require an explanation of significant difference (ESD)
before it could be implemented. The SDs have provided EPA with information to support the ESD
and will continue to support that effort to optimize sludge management alternatives.
In summary, it is believed that a decision from a the State of Utah to amend Energy Fuels' license
allowing for processing of the sludge will be made in the near future and well before the beginning
of the 2014 water treatment season. Therefore, the primary option for the near term is to take the
residual material to the White Mesa Mill for processing. If for some reason that option is not
available, the sludge would be taken to the US Ecology facility in Richland in 2014. Two additional
option were identified that could be implemented after 2014. These options include the use of an
ion-exchange system to selectively remove uranium from the mine water prior to chemical
precipitation. The mobile ion-exchange system would involve processing the loaded resin at the
Cameco facility in Wyoming while the fixed system would process the resin on-site. These options
would be implemented in the future if it is determined they are necessary and if the required
regulatory and contractual agreements could be obtained. Figures 1 and 2 show the key items that
are planned for 2014 and the decision process flow diagram for sludge management in the near
future. The four alternatives are described in more detail in the following sections.
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2.0 PRIMARY ALTERNATIVE: CURRENT WTP PROCESS AND PROCESSING
OF SLUDGE AT ENERGY FUELS
The primary alternative the SDs propose is to continue the current WTP process and have the WTP
sludge processed for its source material content by Energy Fuels (formerly Denison) at its White
Mesa Mill near Blanding, Utah. Energy Fuels has applied to the State of Utah for an amendment to
its Radioactive Material License (RML) to specifically permit receipt and processing of the Midnite
Mine WTP sludge. The State of Utah has provided preliminary approval of the amendment pending
public comments and final approval is anticipated by the end of 2013.
The contractual agreement between the SDs and Energy Fuels will not result in payments from
Energy Fuels to the SDs for the uranium produced from processing the WTP sludge. Costs for
transportation, processing, and storage are provided in Section 2.6.
2.1 Facility Description
Energy Fuels' White Mesa Mill was constructed in 1979 and first processed conventionally-mined
uranium\vanadium ores in May 1980. The mill is licensed to receive uranium ores in bulk,
therefore, WTP residuals shipments may be transported in bulk without other packaging. The mill
uses sulfuric acid leaching and a solvent extraction process to extract and recover uranium. The
White Mesa Mill operates under RML No. UT 1900479, which is administrated by the Utah
Department of Environmental Quality (DEQ), Division of Radiation Control (DRC) through the
US Nuclear Regulatory Commission (NRC) Agreement State Program. The mill is licensed to
process an average of 2,000 tons per day of ore and produce 8.0 million pounds of triuranium
octoxide (U3O8) per year. The White Mesa Mill is also licensed to process alternate feed materials -
uranium-bearing materials derived from other facilities or material from US government cleanup
projects. The WTP residuals will be processed as an alternate feed ore stock in the mill with all
resulting process tailings reporting to the licensed tailings disposal cells. The resultant tailings are
classified as Byproduct Material as defined under Section lle.(2) of the Atomic Energy Act, as
amended.
Based on currently available information, Energy Fuels may be able to receive and process WTP
sludge for a period of at least 20 years and possibly longer.
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2.2 Residuals Handling
The WTP will use the same process and will be operated in the same manner as in the past. A filter
press is currently being constructed and will be in place to dewater the sludge before it is shipped
to Energy Fuels. A certified radioactive materials transport carrier (Carrier) will be contracted to
maintain multi-axle dump trailers on site for loading of the WTP sludge. The Carrier's trailers will
be backed into the WTP building and the filter pressed solids will be conveyed directly into the
trailer bed.
The Carrier will be notified when the trailer will meet its capacity and will pick up the trailer for
transportation to the White Mesa Mill. The Carrier will maintain an empty second trailer on site to
allow for continued loading of the WTP residuals. If practicable, an additional trailer, also referred
to as a "pup" trailer, which would be of lesser capacity than the primary trailer, may be used in
addition to the primary trailer for each trip to the White Mesa Mill to increase transportation
efficiency.
Once the trailer, and pup if used, are filled to capacity, tarps will be tightly secured to completely
cover the trailer openings. The trailers are then scanned by a trained radiation technician for
radiation exposure rates and removable contamination as per 49 Part 173.441. The Carrier drives
the trailer(s) to the White Mesa Mill, where offloading and trailer decontamination are performed
as per Energy Fuels' RML and SOPs. The trailers then return empty directly to the Midnite Mine for
the next trip cycle. Details regarding the material transportation and the certified Carrier are
addressed in the Residuals Transportation Plan (RTP), included as Attachment 2 to this RMP.
2.3 Containers
The SDs will transport the WTP residuals from the WTP to the White Mesa Mill in bulk via tightly
tarped end-dump or side-dump trailers using a certified contract carrier (Carrier) and in
accordance with the RTP, included as Attachment 2 to this RMP.
2.4 Transportation
The material is to be transported as a uranium ore with natural uranium, which is US Department
of Transportation (DOT) non-fissile Class 7 radioactive LSA-1 material in exclusive use shipments.
All transportation will be in accordance with the CD and all applicable state and federal
transportation laws, rules, and regulations and the RTP (Attachment 2). The WTP residuals are
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processed for their source material content and are a uranium ore. In addition, the White Mesa Mill
is in Utah, a member of the Northwest Interstate Compact (NWIC) on Low-Level Radioactive Waste
Management. Therefore, transportation of the WTP residuals for processing and disposal of the
process tailings does not require NWIC approval (per a telephone conversation October 12, 2010
with Mr. Mike Garner, executive director of NWIC).
2.5 Off-Site Rule Verification
The acceptability of the White Mesa Mill to receive the WTP residuals will be confirmed with EPA
Region 8 prior to shipping. Recent discussions with Energy Fuels indicated that they have had
off-site rule verification by EPA earlier this year and it is not anticipated that there will be any
issues with this determination.
2.6 Cost Estimate
Costs associated with processing and disposal of the WTP residuals at the White Mesa Mill are
primarily related to transportation and a processing fee. A processing fee of $50/ton has been
suggested by Energy Fuels. In addition, transportation costs of the WTP residuals is estimated to be
$150/ton, based on the transport of ores from the Dawn Mill to the White Mesa Mill in 2009.
Assuming approximately 750 tons/year, transportation and disposal of the WTP residuals at the
White Mesa Mill will cost approximately $150,000 per year.
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3.0 CONTINGENCY ALTERNATIVE: DISPOSAL AT THE RICHLAND FACILITY
The SDs disposed of WTP residuals at the US Ecology Richland facility in 2011. Disposal at the
Richland facility is available as a contingency disposal option if disposal at Energy Fuels is not
available. The WTP residuals contain greater than 0.05% natural uranium and are considered
uranium ores and Source Material as per 10 CFR Part 810.3. Therefore, these materials are
specifically exempted from the Resource Conservation and Recovery Act (RCRA) under 40 CFR Part
261.4 and are not listed as hazardous waste as defined by RCRA 40 CFR Part 261.3. In addition,
based on analytical test results, these materials do not exhibit the characteristics of hazardous
waste, including toxicity, ignitability, corrosivity, or reactivity. As a result, these materials are not
classified as mixed waste. Concurrence from Washington Department of Health that the WTP
residuals are Source Material (e-mail dated December 20, 2010 from Mike Elsen) is included in
Attachment 1. Source Material is explicitly permitted material included as item 6B of the US
Ecology Richland facility RML (WN-I019-2). Attachment 1 also provides the US Ecology Richland
facility "Waste Acceptance Criteria."
The SDs do not anticipate utilizing the Richland facility, as occurred in 2011, for disposal of all the
residuals from the WTP. The SDs recognize, however, that the Richland facility will be used in 2014
if disposal at Energy Fuels is not available.
3.1 Facility Description
The US Ecology Richland facility site is located 23 miles northwest of Richland, Washington on
approximately 100 acres in the federal Hanford Nuclear Reservation, which is leased to the State of
Washington. This facility has been in operation since 1965 and accepts Class A, B, and C LLRW from
the NWIC and Rocky Mountain Compact states.
Shipping requirements and containers to transport the WTP residuals from the WTP to the
Richland facility are discussed in the RTP (Attachment 2). DMC has submitted a "Waste Profile" and
a "Radioactive Waste Generator Registration" form to US Ecology (Attachment 1). A Site Use Permit
(G1166) has been granted by the Washington Department of Ecology (WDOE) (Attachment 1). This
Site Use Permit and Radioactive Waste Generator Registration constitute the required approvals to
allow US Ecology to accept the WTP residuals, apart from EPA concurrence. Each shipment will be
accompanied by a Radioactive Waste Shipment Certification and a Waste Manifest. Copies of these
forms are included in the RTP (Attachment 2).
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3.2 Residuals Handling
Because the Richland facility is not licensed as a bulk facility, the WTP residuals must be packaged
and cannot be delivered in bulk via covered dump trailers. WTP residuals will be packaged in
woven polypropylene flexible intermediate bulk containers or similar packaging as described in
Section 3.3.
Recent discussion with WDOH and US Ecology personnel indicate that sludge dewater with a filter
press can be disposed of at the Richland facility without the addition of stabilizers such as Petroset,
which was required for the sludge that was dewatered with the centrifuge in 2011.
A certified radioactive materials transport carrier (Carrier) will be contracted to maintain a
multi-axel flat bed or enclosed trailer on site for loading of the WTP residuals. The Carrier's trailer
will be loaded with the containers as they are produced. The Carrier will be notified when the
trailer will meet its capacity and will pick up the trailer for transportation to the Richland facility.
The Carrier will deliver an empty trailer to the site when arriving at the site to transport the full
trailer. If practicable, a second trailer of equal or lesser capacity, also referred to as a "pup" trailer,
may be added to the primary trailer for each trip to the Richland facility to increase transportation
efficiency.
Once the trailer, and pup, if used, are filled to capacity, the trailers will be scanned by trained
radiation technician for radiation exposure rates and removable contamination as per 49 CFR
Part 173.441. The Carrier will drive the trailer(s) to the Richland facility, where offloading will be
performed as per US Ecology's RML (Attachment 1) and SOPs. The trailers then return empty
directly to the Midnite Mine for the next trip cycle.
3.3 Containers
The SDs will transport the WTP solid from the WTP to the US Ecology Richland facility in PacTek
LiftPac™ Lift Bags or similar containers. The containers are woven polypropylene flexible
intermediate bulk containers for the shipping, handling, and storing products and are IP-1 certified.
The containers have an open duffel top with a zipper or web tie closure, flat bottom design, with a
polyethylene or similar liner and webbing lift loops. If a different container is used, the
characteristics will be comparable to those described above and will meet all necessary DOT
requirements and requirements of the US Ecology Richland facility RML. US Ecology has received
approval from WDOH to receive the WTP residual solids soft sided packaging (Attachment 1).
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3.4 Transportation
The WTP residuals are to be transported as US Department of Transportation (DOT) non-fissile
Class 7 radioactive LSA-1 material in exclusive use shipments. All transportation will be in
accordance with the ROD, the CD, all applicable state and federal transportation laws, rules, and
regulations and the RTP (Attachment 2). Because the WTP residuals are being managed within
Washington, a member of the Northwest Interstate Compact on Low-Level Radioactive Waste
Management (NWIC), no prior approval from the NWIC is required.
Transportation of the WTP residuals to the US Ecology Richland facility would be governed by DOT
regulations and the Richland facility RML (Attachment 1). The license requirements for shipping
are included in license conditions 29, 30, 31, and 32 of the Richland facility RML. Details of the
transportation plan to ship the WTP residuals to the Richland facility are documented in the RTP
(Attachment 2).
The filled containers, also referred to as packages, will each be stenciled with the words identified
below in letters greater than 3 inches in height as per 49 CFR Part 183.427(6)(vi):
RADIOACTIVE-LSA, RQ
WAC CLASS AU
DMC-MM
MM-YYYY-#
The unique identification number (mm-yyyy-#) corresponds to the month and year in which the
package was filled and a sequential number denoting the nth package filled that operating year
(e.g., the 23rd bag filled in 2011, which was filled in May would be labeled 5-2011-23). This labeling
meets the requirements of the US Ecology Richland facility RML Conditions 26 and 27 and the
Washington Administrative Code (WAC) 246-249-060.
Each package will be scanned by a trained radiation technician for radiation exposure rates and
removable contamination as per 49 CFR Part 173.441 to verify that the applicable DOT exclusive
use requirements for transportation are met. Once scanned, the Carrier is given the completed
shipping papers, as well as specific instructions regarding the shipment controls during transport.
The Carrier then applies the appropriate placarding and drives the trailer(s) using a single-axel or
multi-axel tractor truck to the Richland facility.
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3.5 Off-Site Rule Verification
40 CFR Part 300.440(a)(4) requires determination of:
...the acceptability under this section of any facility selected for the treatment, storage, or disposal of
CERCLA waste. EPA will determine if there are relevant releases or relevant violations at a facility prior to
the facility's initial receipt of CERCLA waste. A facility which has previously been evaluated and found
acceptable under this rule (or the preceding policy) is acceptable until the EPA Regional Office notifies the
facility otherwise pursuant to 300.440(d).
The acceptability of the US Ecology Richland facility under the requirements of 40 CFR
Part 300.440(a)(4) has been confirmed with Kevin Schanilec, the Off Site Rule Coordinator for EPA
Region 10 via e-mail on March 20, 2013. The continued acceptability of the US Ecology Richland
facility to receive the WTP residuals will be confirmed with EPA Region 10 less than 60 days prior
to shipping.
3.6 Cost Estimate
Costs associated with direct disposal of the WTP residuals at the Richland facility are primarily
related to transportation and the disposal fee. The disposal fees for LLRW vary based primarily on
the size and therefore number of containers in which the waste is packaged and the overall cap on
fees that the facility can charge on an annual basis. The disposal costs, including packaging and
containers, are estimated at approximately $200 per cubic foot. The average annual sludge
production is estimated to be average approximately 750 tons per year depending on the total
amount of water to be treated. The calculated bulk density of the sludge dewatered with the filter
press is approximately 69 pounds per cubic foot (lbs/ft3). The total volume to be disposed would
average approximately 22,000ft3 with an associated disposal cost of approximately $4.4 million.
Transportation costs would be approximately $34.00 per ton and would add approximately
$25,500 per year. Therefore, transportation and disposal of the WTP residuals at the Richland
facility would cost roughly $4.4 million per year, if all WTP residuals were disposed of there. The
allowable annual income for the US Ecology Richland facility is approximately $6 million.
Therefore, it is possible that the total cost could be less if there are other parties disposing of
significant volumes of material at the site.
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4.0 POST-2014 ALTERNATIVE ONE: MODIFICATION OF WTP PROCESS TO
REMOVE URANIUM THROUGH ION-EXCHANGE WITH OFF-SITE
ION-EXCHANGE RESIN PROCESSING
The ROD recognized that sludge disposal would be expensive and that it would therefore, be
appropriate to consider ion-exchange and other uranium removal steps to produce a lower volume
of source material wastes with higher concentrations of uranium. The ROD states:
Because disposal of the sludge at a low-level radioactive waste disposal facility is costly and the availability
of such facilities may change over time, treatability testing may be performed to assess the addition of an
ion-exchange or other uranium removal step to the water treatment process. If the addition of ion-exchange
or alternative step would change the waste designation of sludge to allow less costly disposal without
significantly increasing overall costs, the water treatment process may be altered to incorporate such
technology.
Accordingly, the first long-term alternative that could be implemented after 2014 is to modify the
WTP process to remove uranium using ion-exchange. The ion-exchange process induces the
removal of dissolved uranium in the mine water via adsorption on ion-exchange resin prior to the
chemical precipitation step in the water treatment process. After the resin has become loaded with
uranium, the resin is processed to remove the uranium and is regenerated to allow the resin to be
placed back into the system as the process is repeated. This alternative would involve removal of
uranium from the mine water on site with the uranium-loaded resin transported off-site for
uranium removal and resin regeneration. The alternative to regenerate the resin on-site to produce
two primary waste streams is discussed below. It is noted that spent resin (resin that can no longer
be used in the process) will also be a waste stream.
Under this alternative, the ion-exchange resin loaded with uranium would be transported to the
Cameco Resources uranium processing facility in Wyoming for processing. The facility would
remove the uranium from the resin and then the resin would be transported back to the Midnite
mine for subsequent use. Cameco has authority under their current license with the Nuclear
Regulatory Agency (NRC) to accept ion-exchange resin from water treatment facilities. Cameco has
concluded that processing loaded resin from the mine is compatible with their process based on
testing the loaded resin from the pilot scale test program to determine if there are any constituents
that might be on the resin that could adversely impact their process. The SDs are in negotiations
with Cameco for an agreement to support this alternative. It is unknown when or if the contractual
agreement will be completed. This alternative could be implemented in the future when shipment
Residuals Management Plan for the 13
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WME, LLC
November 1, 2013
to Energy Fuels is no longer available. This option would require the construction of the mobile
ion-exchange facility. The design of the facility has been completed and approved.
While details of any agreement with Cameco have not been defined, preliminary discussion
indicates that Cameco charges fees for processing and storage of the uranium. There will also be a
cost for transportation; however this amount is unknown at this time.
4.1 Option Description
Ion exchange vessels would be loaded with resin designed to selectively remove uranium from the
influent water at the up-stream side of the WTP. The ion-exchange columns would be mounted in
trailers and processed as shown on the mobile system ion-exchange system design. Water would
be pumped through the columns and uranium removed from the water. The water that has passed
through the ion-exchange columns would then be treated to remove other constituents using the
same water treatment technology as is currently being used at the existing WTP. Once the resin in
the ion-exchange columns becomes saturated with uranium, the resin in the trailer tanks would be
removed from the site and transported to the Cameco facility in Wyoming for processing and resin
regeneration. The regenerated resin in the trailer mounted system would then be returned to the
site for continued use. The design of the mobile ion-exchange system has been completed and
approved by the EPA. Construction of the facility would be necessary and would take
approximately 6 months for completion.
The uranium removed from the resin would be incorporated into Cameco's uranium recovery
process to produce a product that Cameco will sell.
Water that has been stripped of uranium as a result of the ion-exchange process would be treated
to remove other constituents using the same technology as is currently being used in the WTP. This
would occur in either the existing WTP or in the new facility after it is designed, permitted and
constructed. The waste from the post ion-exchange portion of the WTP would result in an effluent
sludge with a uranium concentration of less than 0.05% as determined in the Pilot Scale Evaluation
(Tetra Tech, 2009). This effluent sludge resulting from chemical precipitation of waste from which
uranium has been removed would be acceptable for disposal at the Grand View facility after it is
dewatered with a filter press.
Pursuant to 42 U.S.C. Section 9621(e), the SDs will comply with the substance of applicable NRC and
WDOH regulations. Separate permitting by the NRC and/or WDOH should not be required. (See
Residuals Management Plan for the 14
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
NRC Director's Decision, dated March 26,1999, attachment 1.7, and December 31, 2008 letter from
M. Elsen to E. Hale, included as Attachment 1.6). The regulations applicable to ion-exchange with
off-site resin regeneration are the same as the regulations applicable to the current WTP process
and disposal. Thus, this option will not impose any additional regulatory burden on EPA or the SDs.
As with any change to the WTP process, specific updated health and safety plans will be required.
4.2 Materials Handling and Transport
The loaded resin material will be classified as a loaded ion-exchange resin with residual uranium
(natural), which is classified by the US Department of Transportation (DOT) as non-fissile Class 7
radioactive LSA-1 material in exclusive use shipments. All transportation will be in accordance
with the ROD, the CD, all applicable state and federal transportation laws, rules, and regulations,
and the RTP (Attachment 2).
The remaining effluent sludge from the chemical precipitation portion of the WTP would be
shipped to the US Ecology Grand View, Idaho facility in bulk via tightly tarped end-dump or
side-dump trailers using a certified contract carrier (Carrier) and in accordance with the RTP
(Attachment 2).
4.3 Cost Estimate
Costs associated with this alternative include costs for the ion-exchange system, costs associated
with handling and transportation of the loaded resin and return of the regenerated resin,
processing costs charged by Cameco, and disposal of the remaining effluent sludge resulting from
chemical precipitation of waste from which uranium has been removed. The SDs currently
estimate the cost to construct the mobile ion-exchange system including- the trailers is
approximately $1.5 million.
Costs to transport the resin to and from the Cameco facility and the costs for processing have yet to
be finalized, however, based on initial discussion with Cameco, the total cost to the SDs is
anticipated to be about $150,000 to $200,000 per year for transportation and processing the resin.
Costs to operate the ion-exchange system are estimated to be approximately $170,000 per year for
replacement resin as discussed in Tetra Tech, 2010 although the frequency at which resin would
need to be replaced will not be known until the system is in operation. The cost for disposal and
transportation of the effluent sludge is estimated to be $200,000 per year. Waste disposal costs
were estimated based on conversations with US Ecology. Disposal costs for spent resin, assuming it
Residuals Management Plan for the 15
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
can be disposed of at the Grand View facility, would be included in the costs associated with effluent
sludge disposal as the disposal volume for resin would be insignificant compared to the effluent
sludge volumes. The total costs for this alternative would be approximately $1.5 million for capital
costs and approximately $520,000 to $570,000 annually for operation and disposal costs.
4.4 Off-Site Rule Verification
40 CFR Part 300.440(a)(4) requires determination of:
...the acceptability under this section of any facility selected for the treatment, storage, or disposal of
CERCLA waste. EPA will determine if there are relevant releases or relevant violations at a facility prior to
the facility's initial receipt of CERCLA waste. A facility which has previously been evaluated and found
acceptable under this rule (or the preceding policy) is acceptable until the EPA Regional Office notifies the
facility otherwise pursuant to 300.440(d).
Based on communications with US Ecology, their Grand View, Idaho facility will be able to accept
the effluent sludge that has been dewatered with a filter press. Once an agreement has been
reached to take loaded resin to the Cameco facility for processing, SDs will initiate the offsite rule
verification process for the Grand View facility.
Residuals Management Plan for the 16
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
5.0 POST-2014 ALTERNATIVE TWO: MODIFICATION OF WTP PROCESS TO
REMOVE URANIUM THROUGH ION-EXCHANGE WITH ON-SITE
ION-EXCHANGE RESIN PROCESSING
As with the other long-term option, this option would use ion-exchange technology to selectively
remove uranium from the mine water prior to the chemical precipitation portion of the WTP
process to produce a lower volume of source material waste to reduce the costs associated with
sludge disposal. As modified to use ion-exchange, the WTP would produce two primary waste
streams—a low volume of source material wastes with high concentrations of uranium and a high
volume of effluent sludge resulting from chemical precipitation of waste from which uranium has
been removed containing less than 0.05% uranium. Spent resin would also require disposal. The
low volume source material waste and spent resin with uranium concentrations greater than
0.05% would be disposed of at the US Ecology Richland facility near Richland, Washington. The
effluent sludge and spent resin with uranium concentrations less than 0.05% would be disposed of
at the US Ecology facility in Grand View, Idaho.
Ion-exchange technology has been used in the uranium industry for decades to produce source
material with high uranium concentrations. Pilot scale testing in 2009 (Tetra Tech, 2009)
confirmed that uranium can be selectively removed from the waste water stream in the Midnite
Mine WTP using ion-exchange prior to addition of lime and precipitation of the other metals.
Technology for stripping and precipitation is proven and used extensively, and DMC has experience
from its own milling operations with the relevant technologies to do this. Additional pilot testing
work was conducted in 2012 to support finalizing a design of these components (MWH, 2012). This
proven method would be used in a multi-step process which would consist of: concentrating
uranium on to the resin, stripping the uranium from the resin, precipitating uranium from the
stripped solution and dewatering the high uranium concentration source material waste. The 60%
design of this system has been submitted to EPA (MWH, 2013). However, the design has not been
finalized or approved and the facility would need to be built; therefore implementation of this
alternative would take 6 months to a year.
This option is considered as a long-term option for residuals management for two reasons. First,
this option minimizes long-terms costs as compared to long-term disposal of all residuals at the
Richland facility as the cost for disposal at the Grand View facility for the bulk of the sludge is an
order of magnitude less expensive if off-site sludge processing as proposed at Energy Fuels or
Residuals Management Plan for the 17
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November 1, 2013
offsite resin regeneration as proposed at Cameco becomes unavailable. Second, this option
maximizes the SDs and EPA's operational control of all aspects of the residuals management
process, with minimal reliance on third-parties beyond the SDs or EPA's control.
5.1 Option Description
Ion exchange vessels would be constructed and loaded with resin to selectively remove uranium
from the influent water at the up-stream side of the WTP. Water would be pumped through the
columns and uranium removed from the water. The water that has passed through the
ion-exchange columns would then be treated to remove other constituents using the same water
treatment technology as is currently being used. The 60% design of this process facility has been
submitted to EPA (MWH, 2013).
Once the resin in the ion-exchange columns becomes saturated with uranium, the resin would be
flushed and the uranium stripped from the resin. The solute would be treated to precipitate the
uranium and subsequently treated to obtain a source material waste suitable for disposal at the
Richland facility. A dedicated filter press would be installed to process the source material sludge
for acceptance at the Richland facility. Pilot testing work was conducted in 2012 to support
finalizing a design of these components (MWH, 2012). This information was used for scale up and
plant design.
The waste from the post ion-exchange portion of the WTP (chemical precipitation step) would be a
sludge with a uranium concentration of less than 0.05% (Tetra Tech, 2009, MWH, 2012). This
effluent sludge would be acceptable for disposal at the Grand View facility after it is dewatered with
a filter press.
It is estimated that only a small volume of high uranium concentration source material waste
(10,000 pounds or about 100 cubic feet) would be produced annually, as presented in the Pilot
Scale Evaluation Report (Tetra Tech 2010). The amount of effluent sludge is estimated to be
approximately the same as the amount of sludge currently produced without an ion-exchange
circuit or approximately 750 tons per year with solids content of approximately 30% after the
residuals have been processed through the filter press. Pursuant to 42 U.S.C. Section 9621(e), the
SDs will comply with the substance of applicable NRC and WDOH regulations. Separate permitting
by the NRC and/or WDOH should not be required. (See NRC Director's Decision, dated March 26,
1999, attachment 1.7, and December 31, 2008 letter from M. Elsen to E. Hale, included as
Attachment 1.6). The regulations applicable to ion-exchange, stripping of the resin, and producing
Residuals Management Plan for the 18
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1,2013
a high concentration uranium source material waste are the same as the regulations applicable to
the current WTP process. Thus, this option will not impose any additional regulatory burden on
EPA or the SDs. As with any change to the WTP process, specific updated health and safety plans
will be required. EPA has indicated that an explanation of significant difference (ESD) process
would be required for this alternative.
5.2 Materials Handling and Transport
The source material waste would be packaged in 55-gallon drums or other suitable containers and
shipped to the US Ecology Richland facility. Transportation would be accomplished using the
procedures as discussed in the RTP for shipment of residuals to the Richland facility. It is estimated
that approximately ten to twelve 55-gallon drums of source material waste would be produced on
an annual basis.
The remaining effluent sludge would be shipped to the US Ecology Grand View facility in bulk via
tightly tarped end-dump or side-dump trailers using a certified contract carrier (Carrier) and in
accordance with the RTP (Attachment 2).
5.3 Cost Estimate
Costs associated with this alternative include costs for the ion-exchange system, costs associated
with stripping and processing the source material waste, disposal of the source material waste, and
disposal of the remaining effluent sludge. The SDs currently estimates that the ion-exchange
system including the holding ponds as detailed in the 60% design would cost approximately
$6 million.
Costs to operate the ion-exchange system are estimated to be approximately $170,000 per year for
replacement resin as discussed in Tetra Tech, 2010 although the frequency at which resin would
need to be replaced will not be known until the system is in operation. Disposal costs for this resin,
assuming it can be disposed of at the Grand View facility, would be included in the costs associated
with effluent sludge disposal as the disposal volume for resin would be insignificant compared to
the effluent sludge volumes. Costs for disposal of the source material waste is estimated to be
approximately $75,000 per year based on costs for disposal at the Richland facility experienced in
2011, and the cost for disposal and transportation of the effluent sludge at the Grand View facility is
estimated to be $220,000 per year. Waste disposal costs were estimated based on conversations
Residuals Management Plan for the 19
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WME, LLC
November 1, 2013
with US Ecology. The total costs for this alternative would be approximately $6 million for capital
costs and approximately $465,000 per year for operation and disposal costs.
5.4 Off-Site Rule Verification
40 CFR Part 300.440(a)(4) requires determination of:
...the acceptability under this section of any facility selected for the treatment, storage, or disposal of
CERCLA waste. EPA will determine if there are relevant releases or relevant violations at a facility prior to
the facility's initial receipt of CERCLA waste. A facility which has previously been evaluated and found
acceptable under this rule (or the preceding policy) is acceptable until the EPA Regional Office notifies the
facility otherwise pursuant to 300.440(d).
The acceptability of the US Ecology Richland facility under the requirements of 40 CFR
Part 300.440(a)(4) has been confirmed with Kevin Schanilec, the Off Site Rule Coordinator for EPA
Region 10 via e-mail on March 20, 2013. The continued acceptability of the US Ecology Richland
facility to receive the WTP residuals will be confirmed with EPA Region 10 less than 60 days prior
to shipping.
The acceptability of the US Ecology facility to accept the effluent sludge will be pursued when this
alternative becomes viable, but the waste stream appears to meet all requirements for disposal at
US Ecology's Grand View facility in Idaho.
Residuals Management Plan for the 20
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WME, LLC
November 1, 2013
6.0 SUMMARY
This revised RMP sets forth a comprehensive plan for managing WTP residuals based on current
information. The SDs propose four alternatives for short- and long-term management of WTP
residuals.
The primary option that will be used for residuals management in both the short-term and the long-
term is to take the residual material to the Energy Fuels White Mesa Mill for processing. This
alternative should be available beginning in 2014 and may remain available for many years
thereafter, depending on the operational life of Energy Fuels' White Mesa Mill.
Two additional alternatives exist that could be used after 2014. These alternatives include
ion-exchange with off-site ion-exchange resin processing at Cameco, and ion-exchange with on-site
resin processing and production of high concentration source material wastes and a remaining
effluent sludge. Both of these alternatives could be implemented after 2014 if necessary. Both of
these alternatives would require the construction of additional facilities on site. The design of the
mobile ion-exchange system for the off-site regeneration alternative has been approved. The fixed
ion-exchange system design is at the preliminary level. The off-site regeneration alternative would
require the completion of an agreement with Cameco and the on-site regeneration alternative
would require an ESD. It is anticipated that it would take 6 months to a year to have either of these
option operational.
The Contingency Alternative (disposal at the Richland facility) is available as both a short- and
long-term option. However, disposal of all WTP residuals at the Richland facility is far less
cost-effective than the other proposed alternatives. Nevertheless, this option will remain available
for use on an emergency basis. A summary of the costs and a brief description of the major
advantages and disadvantages for each alternative are included in Table 1.
The SDs request that EPA approve this RMP as consistent with the ROD and authorize the SDs to
proceed with residuals management in accordance with this plan.
Residuals Management Plan for the 21
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WME, LLC
November 1, 2013
7.0 REFERENCES
Advanced Environmental Sciences, Inc. (AES), 2013. Mobile Ion-Exchange 60 Percent System
Design. March 18.
Miller Geotechnical Consultants, 2009. Residuals Management Plan. April 10.
MWH, 2012. Pilot Scale Test Results for Uranium Removal Using Anionic Exchange Resins and
Chemical Precipitation. December 31.
MWH, 2013. Intermediate (60 Percent) Design Report, Ion Exchange Treatment System, March 15.
Tetra Tech, Inc. (Tetra Tech), 2010. Midnite Mine Ion-Exchange Treatability Testing Data Report
Revision 2. Prepared for Dawn Mining Company and Newmont USA Limited. June 28.
Tetra Tech, Inc. (Tetra Tech), 2009. Treatability Testing Plan: Pilot Scale Testing of Uranium
Removal Using Anionic Exchange with Conventional Strong-Base Resins Revision 3.
Prepared for Dawn Mining Company and Newmont USA Limited. August 5.
United States Environmental Protection Agency (EPA), 2008. Statement of Work (SOW) for Interim
Water Management. Office of Environmental Cleanup EPA Region 10.
United States Environmental Protection Agency (EPA), 2009. Unilateral Administrative Order (AO)
for Remedial Design and Remedial Action. EPA Docket No. CERCLA-10-2009-0026.
United States Environmental Protection Agency (EPA), 2011. Statement of Work for the Remedial
Design and Remedial Action for the Midnite Mine Superfund Site, Appendix B to the RD/RA
Consent Decree. April.
Residuals Management Plan for the 22
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WME, LLC
November 1, 2013
Table 1
Options Summary
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
Table 1. Options Summary
Sludge Processing at
Energy Fuels
Estimated Costs
$150,000/Year
processing fee
($50 per ton processing +
$150 per ton transportation)
Advantages
Minimal additional
equipment (only Filter
Press). Less potential worker
risk or water treatment
plant effluent risks.
Disadvantages
Uncertain in long-term.
Approval from Utah pending
public comments.
Offsite IX Processing,
Effluent Sludge Disposal at
Grand View
$1,500,000 capital costs
Estimate $150,00 to
$200,000/yr for processing
and transporting resin
$170,000 / Year,
resin replacement
$200,000 / Year,
transport and effluent
sludge disposal at Grand View
Less equipment and less
potential worker and water
treatment plant effluent
risks than on-site
regeneration.
Potentially viable in long-
term since comercial
business model with Cameco
has been identified.
Agreement with Cameco is
not final, but expected.
Additional equipment
required on site.
On-Site IX Regeneration,
Effluent Sludge Disposal at
Grand View
$6,000,000 capital costs
$170,000/Year,
resin replacement
$75,000 / Year,
source material disposal
$200,000 / Year,
effluent sludge disposal
at Grand View
More long-term certainty.
Most new equipment and
greatest potential worker
risk. ESD necessary.
Whole Sludge Disposal
Richland
$25,000 / Year,
transport
$4,400,000 / Year,
disposal costs
No additional equipment,
low water risk, approved
and available long-term.
Exorbitantly expensive.
Notes:
Assumes treatment volume of60,000,000 gal/yr, Approx. 750 tons of chemical precipitant sludge (whole or effluent sludge) produced per year
Approximately 1150 cubic feet or 38 ton of resin will need to be replaced each year for IX options
10,000 pounds or 90 cubic-feet of source material waste per year for on-site regeneration option
Figures
Residuals Management Plan for the WME, LLC
Midnite Mine Water Treatment Plant, Rev. 10 November 1, 2013
Figure 1. 2014 Residuals Management Decision Chart
Is there an
agreement,
permits and
approval in
place with
Energy Fuels?
YES
Proceed with Primary
Alternative: Disposal at
Energy Fuels
Proceed with
Contingency
Alternative:
Disposal at
Richland
NO
Figure 2. RMP Decision Chart
Post-2014
i >
Regular review of options
and continue to request &
support ESD
YES Implement Primary
Alternative
NO
Construction/use of Fixed
IX System
YES
NO
YES
NO
Implement First Post-2014
Alternative
Implement Second Post-
2014 Alternative
Implement Contingency
Alternative*
*Note: Contingency alternative could also be
implemented if infrastructure for available
alternatives are not in place. This process will be
followed every year as conditions change.
Attachment 1
US Ecology Richland Materials
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
Attachment 1
US Ecology Richland Materials
1.1 Water Treatment Plant Residuals "Waste Profile"
1.2 US Ecology Low-Level Radioactive Waste Generator Registration
1.3 Washington State Site Use Permit
1.4 US Ecology Radioactive Materials License
1.5 US Ecology Waste Acceptance Criteria
1.6 WDOH concurrence regarding WTP residuals status as source material, 12/20/10 e-mail
from Mike Elsen and 12/31/08 letter from WDOH
1.7 NRC Director's Decision, dated March 26,1999
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
Attachment 1
US Ecology Richland Materials
1.1 Water Treatment Plant Residuals "Waste Profile"
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1,2013
RADIOACTIVE MATERIAL PROFILE RECORD
Generator Name: Dawn MlpiBgCg»PHiT. LLC Generator 8:MMWTP, Volnmc nf Feed Mttofal 2S0bm/nsr
Contractor Nam a: , Feed Stream Name: , Delivery Daft: - April 1.2011
Check appropriate boxes: Licensed Y No: XX. NORM/NARM ; LLRW ; MW ; MW Treated ; MW Needing Trtmt ; DOE ; lie.(Z)
Original Submission: Y XX N_ Revision* DaecfRevisioa:
Name and Title of FOton Completing Form: Robert Wdiaa -Mtdalte M»?T 9*** M*«tfr P^wc tSfl^l 25»-<SIl
A. CUSTOMER INFORMATION:
GENERAL: Please read carefully and complete this form for one feed stream. This information will be used to determino how to properly
manage the material. Should there be any questions while completing this form, contact Denison Mines (USA) Corp. ("Denison")
Environmental Management at 303.628.7798. MATERIALS CANNOT BE ACCEPTED AT DBNISON'S WHITS MESA MILL UNLESS
THIS FORM IS COMPLETED. If a category does Dot apply, please indicate. This ftrm most be updated annually.
1. GENERATOR INFORMATION
EPAIDtf WAP980973753 EPA Hazardous Waste Numbers) (if applicable)
Mailing Address: P.O. Box 250. Ford. WA 99013
Phone: fS0»> 258^511 Fax: fS0»V25E4512
Location of Material (City, ST): miles west of WeIloiait.WA
Generator Contact: Robert Nation Tide:.
Mailing Address (if different from above): Same as above
Phone: Same as above
lie Manager
Fax: Samaai abov
MATERIAL PHYSICAL PROPERTIES (Should you have any questions while completing this section, contact Denison Environmental
Management at 303.628.779S.
PHYSICAL DATA (Indicate percentage of material that will pass through tho following
grid sizes, 3g,12.» Ugj%, 4" 96% 1" 74%, 1/4" 50% 1/40" 30% 1/200' .5%)
»Attached
DESCRIPTION: Color Brown/MuWJL Odor Odorless X_
Liquid Solid XX_ Sludgo_ Powder/Dust
GRADATION OF
MATERIAL:
12"
4"
I"
1/4"
1/40"
1/200"
_100%
_95%
_90%
_84%
_6S%
57% DENSITY RANGB: (Indicate dimensions) 5&2 - 74.9 S.G. IbJH* Ib^rd3
GENERAL CHARACTERISTICS (% OF EACH)
Soil Building Debris Rubble Pipe Scale Tailing Process Residue X Concrete Plastic/Resin.
Other coosn'tnents and approximate % contribution of each: WTP Solids 100%
MOISTURE CONTENT: (For soil or soil-like materials).
(Use Std Proctor Method ASTM D-698) Optimum Moisture Content %
^ee Attached) Average Moistnre Content: %
Moisture Content Range: %
6. DESCRIPTION OF MATERIAL (Please attach a description of the material with respect to its i
This description can be attached separately or included with the attachment for Item D.l.) Sea-Attached _
dtion and characteristics.
Generator or Contractor Initials:
Radioactive Material Profile Record
t required to be listed below and do not require manifesting. (Use
RADIOLOGICAL EVALUATION
I. MATERIAL INFORMATION. For each radioactive isotope associated with the material, please list the following herniation. Deoison's
license assumes daughter products to be present in equilibrium,
additional copies of this form if necessary).
Weighted
Isotopes Concentration Range Average
(pCl/g) (pCI/g)
a. Th-338 2.04 to 3.67 L22 b.
c. Pb-210 SSA to_9*8_ _333 d.
e, , Ra-Toial 65.2 to 1173 39.1 £
Isotopes Concentration Range
(pO/g)
Tb-230 34,6 to $13.
Th-232 139 to_ 231
Ra-326 403 to 723
Weighted
Average
(pCi/g)
20-7
m
24.1 ND - Analyte not delected.
Y ® Is the radioactivity contained In the feed material Low-Level Radioactive Waste as defined in the Low-Level Radioactive Waste
Policy Amendments Act of 1985 or in DOE Order 5820.2A, Chapter EI? (Please Circle) If yes, check "LLRW" block on line 3
of page l.
Y © LICENSED MATERIAL: Is the feed material listed or Included on an active Nuclear Regulatory Commission or Agreement
State license? (Please Circle)
(If Yes) TYPE OF LICENSE: Source ; Special Nuclear Material ; By-Product ;Norm ; NARM ;
LICENSING AGENCY:
D CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL igjcaarfcacheth
Please attach a description of the material to this profile. Include the following as applicable: The process by which the material was
generated. Available process knowledge of the material The basis of hazardous material or waste determmations. A list of the chemicals
and materials used in or commingled with the material; a list of any and ail applicable EPA Hazardous Waste Numbers, current or former;
and a list of any and all applicable land-disposal prohibition or hazardous-waste exclusions, extensions, exemptions, effective dates,
variances or delistings. Attach the most recent or applicable analytical results of the material's hazardous-waste characteristics or
constituents. Attach any applicable analytical results involving the composition of the material. Attach any product information or
Material Safety Data Sheets associated with the materiaL If a category on mis Material Profile Record does not apply, describe why it does
not
Please describe the history, and include the following:
Y ® Was this material mixed, treated, neutralized, solidified, commingled, dried, or otherwise processed at any time after generation?
Y ® Has this material been transported or otherwise removed from the location or site where it was originally generated?
Y © Was this material derived from (or is the material a residue of) the treatment, storage, and/or disposal of hazardous waste defined by
40 CFR 261?
Y ® Has this material been treated at any time to meet any applicable treatment standards?
2. LIST ALL KNOWN AND POSSIBLE CHEMICAL COMPONENTS OR HAZARDOUS WASTE CHARACTERISTICS
a. Listed HW
d. Cyanides
g. Pesticides
j. Explosives
m. Organics
p. Igui table
s. Antimony
v. Nickel
y. Alcohols
bb. Cadmium
ee. Mercury
hh. Benzene
kk. Fluoride
on. Chelating Agents.
00 (N)
2L
2L
2L
x
X*
b.
e.
n.
q-
t.
pp. Other Known or Possible Materials
"Derived-From"HW
Sulfides
h. Herbicides
k. Pyrophorics
Phenolic*
Corrosive
Beryllium
w. Thallium
2. Arsenic
cc Chromium
ft Selenium
iL Nitrate
II. Oil
oo. Residue from
water treatment
of Chemicals
00 (N)
X 00
x*
x
Toxic
Dioxins
PCBs
Solvents
Infectious
Reactive
Copper
Vanadium
aa. Barium X
dd. Lead
gg. Silver
1). Nitrite
mm. Fuel
c.
f.
I
1.
o.
r.
u.
x.
(N)
X
_2£
Tin chemical ccmponent Identified above wtth an X* ItuBcattt that the WTP solids were net testedfir this component but process knowledge InOatts that
these component! would net btpresent in tht WTPf
Generator or Contractor Initials: REN
Radioactive Material Profile Record
ANALYTICAL RESULTS FOR TOXICITY CHARACTERISTIC^^ftoasi^&anscribe results on the blank spaces provided. Attach
additional sheets if needed, indicate range or worst-case results). Se^attachedJ^
Metals (circle one): Total (mg/kg) or (^P(mg^> Organics (circle one):Total (mg/kg) or XC^Jx^T)
ND <*ite attached)
ND
ND
ND
Lead
Barium
Mercury
Cadmium
Zinc
Chromhim
Copper
ND - Anaryte not detected
ANALYTICAL RESULTS FOR REQUIRED PARAMETERS: (Please transcribe results on tho blank spaces provided. Attached
additional sheets if needed).
NP
ND
Sofl pH 9.09-9,26 SU Paint Filter No Free Liquid P
Liquids Test (Pass/Fail)
Cvanide NO Not detected NP Sulfide NO Not detected NP
Released mg/kg Released mg/kg
IGNlTABILTrY (40 CFR 261 Jl(a][2].[4].)
Flash Point >95 *P Is the material a RCRA oxidizer? Y ®
7. CHEMICAL COMPOSITION (IJstjIlJaiown chemical components and circle the applicable concentration dimensions. Use attachments
to complete, if necessary.) Suattached^
Chemical Component Concentration Chemical Component
.%mg/kg
mg/kg
%mg/kg
Concentration
% rag/kg
% rag/kg
% mg/kg
Halogenated Organic Compounds (HOC) (Sum of the list of HOCs) mg/kg
REQUIRED CHEMICAL LABORATORY ANALYSIS. Generator must submit results of analyses of samples of the material Results are
required from a qualified laboratory for the following analytical parameters unless nonapplicabDity of die analysis for the material can be stated
and Justified in attached statements. Attach aU analytical results and QA/QCdocurnentanonavai^ (CAUTION: PRIOR TO ARRANGING
FOR LABORATORY ANALYSIS, CHECK WITH DENISON AND«LABORATORY REGARDING UTAH LABORATORY
CERTIFICATIONS.)
FOR ALL MATERIAL TYPES: CHEMICAL ANALYSIS: Soil pH (9045), Paint Filter Liquids Test (9095): Reactivity (cyanide and sulfide).
1. MINIMUM ADDITIONAL ANALYTICAL REQUIRED FOR:
a. Non-RCRA Waste (Non Mixed Waste e&, LLRW, NORM): TCLP including the 32 organics, 8 metals, and copper (Co) and zinc
(Zn).
2. REQUIRED RADIOLOGICAL ANALYSES. Please obtain sufficient samples to adequately determine a range and weighted average of
activity in the material. Have a sufficient number of samples analyzed by gamma spectral analysis for all natural isotopes such that they
support the range and weighted average information for the material that will be recorded in item D. 1. If Uranium, Thorium, or other non-
gamma emitting nuclides are present in the material, have at least (1) sample evaluated by radiochemistry to determine the concentration of
these additional contaminants in the materia.
Generator or Contractor Initials: REN
Radioactive Material Profile Record
3. PRE-SHIPMENT SAMPLES OF MATERIAL TO DENISON
Once permission has been obtained from Denison, and unless amenability samples have previously been sent to Denison, please send 5
representative samples of the material to Denison. A completed chain of custody form must be included with tho sampling containers.
These samples will be used to establish the material's incoming shipment acceptance parameter tolerances and may be analyzed for
additional parameters. Send about two pounds (one liter) for each sample in an air-tight clean glass container via United Parcel Post (UPS)
or Federal Express to:
Denison Mines (USA) Corp, Attn: Sample Control, 6425 S. Highway 19!, P.O. Box 809, Blending, UT 84511
Phone:[phone]
4. LABORATORY CERTIFICATION INFORMATION. Please indicate below which of the following categories applies to your laboratory
data.
a. All radiologic data used to support the data in item Ci. must be from a certified laboratory.
X UTAH CERTIFIED. The laboratory holds a current certification for the applicable chemical or radiological parameters from the Utah
Department of Health insofar as such official certifications are given.
GENERATOR'S STATE CERTIFICATION. The laboratory holds a ouront certification for the applicable chemical parameters from
the generator's State insofar as such official certifications an given, or
GENERATOR'S STATE LABORATORY REQUIREMENTS. The laboratory meets the requirements of the generator's State or
cognizant agency for chemical laboratories, or
If using a non-Utah certified laboratory, briefly describe the generator state's requirements for chemical analytical laboratories to
defend the determination that the laboratory used meets those requirements, especially in terms of whether the requirements arc
paiameter specific, method specific, or involve CLP or other QA data packages. Note: When process or project knowledge of this
feed material is applied, additional analytical results may not be necessary to complete Section B. D.2. D.5. or D.6. of this form.
b. For analytical work done by Utah-certified laboratories, please provide a copy of the laboratory's current certification letter for each
parameter analyzed and each method used for analyses required by this form.
a For analytical work done by laboratories which are not Utah-Certified, please provido the following information:
Stale or Other Agency Contact Person Generator's State Telephone Number
Lab Contact Person Laboratory's State TelephooeNumbcr
F. CERTIFICATION
GENERATOR'S CERTIFICATION: I also certify that where necessary those representative samples were or shall be provided to Denison and
to qualified laboratories for the analytical results reported herein. I also certify that the information provided on this form is complete, true and
correct and is accurately supported and documented by any laboratory testing as required by Denison. I certify that the results of any said
testing have been submitted to Denison. I certify that the material described in this profile has been fully characterized and that hazardous
constituents listed in 10 CFR 40 Appendix A Criterion 13 which are applicable to this material have been indlcatrxi on this form. I further
certify and warrant to Denison that the material represented on Ibis form is not a hazardous waste as defined by 40 CFR 261 and/or that this
material is exempt from RCRA regulation under 40 CFR 261/4(aX4).
The Generator's responsibilities with respect to the material described in thb form are for policy, programmatic^ funding and scheduling
decisions, as well as general oversight. The Contractor*3 responsibilities with respect to mis material are for the day-to-day operations On
accordance with general directions given by the Generator as part of its genera] oversight responsibility), including but not limited to the
following responsibilities: material characterization, analysis and handling: sampling; monitoring; record keeping; reporting and contingency
planning. Accordingly, the Contractor has the requisite knowledge and authority to sign this certification on behalf of itself, and as agent for the
Generator, on behalf of tho Generator. Bysigning this certification, the Contractor is signing on its own behalf and on behalf of the Generator.
Generator's or Contractor's signntirrc f, Ar lr
(Sign for the above certifications). i
Print Name of Individual Signing above: Robert B. Nelson
Jiite-Vice Pres. ft Gen Mgr Date Nov. 16.2010
RADIOACTIVE MATERIAL PROFILE RECORD ATTACHMENTS
B.l. PHYSICAL DATA: Soluble salts will not have solids characteristics in the mill process
or in the tailings. As shipped, these materials will be dry, coarse, granular solids (see
attached photos). No grain size data is available.
B.5. MOISTURE CONTENT: 25% to 45% solids by weight, will pass paint filter test
(ASTM 9095, Paint Filter Test, found in EPA document EPA SW-846, Test Methods for
Evaluating Solid Wastes, Physical/Chemical Methods; Third Edition, September, 1986,
as revised, December, 1987.) Solids are soluble under acidic conditions and will not
have solid density\moisture content characteristic properties as a component of the
tailings.
B. 6. DESCRIPTION OF MATERIAL: The Uranium Material is light grey to light brown in
color and odorless. The material is consolidated chemical precipitates, no grain sized
distribution data are available. The material is a relatively dense pressed filter cake and
does not exhibit free moisture or drainage of retained liquid. Photo 1 at the bottom of
these attachments depicts a sample of the Uranium Material develop from pilot filter
press tests on the WTP solids.
C. l RADIOLOGICAL EVALUATION
Uranium is present in the thousands of pCi/g and Thorium is present in the range of 10's
of pCi/g, based on eight years of historical anlyses (2002-2009) of the WTP solids for
uranium and die testing of three samples collected in 2010 (WTPS-1, -2, -3) for the other
radionuclides (Gross Alpha, Gross Beta, Pb-210, Ra-226, Th-228, Th-230, Th-232). The
measured radionuclide activity concentrations for the uranium material at 15% solids
have been used to describe the range of concentrations expected for the uranium
materials at 25% to 45% solids developed the new filter press to be installed for the 2011
operating season. Uranium values present representative values from the last 8 years of
testing. See analytical data presented in response to Item D.l, below.
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
D. 1 DESCRIPTION AND HISTORY OF MATERIAL
The plant feed is a combination of water pumped from two uranium mine pit lakes from
the inactive Midnite Mine. Water from the pit lakes, which contain primarily metals,
sulfate, and uranium, are pumped into the WTP at a rate of approximately 450 gallons per
minute. The WTP is a conventional lime treatment high-density sludge process in which
the metals and uranium are precipitated out in the lime treatment process. Historically,
the final WTP solids has contained on average 0.18 wet weight percent uranium (0,21
wet weight percent U308) at an average historical solids content of 15 percent when
produced using centrifuges for dewatering. However, the centrifuges are to be replaced
with a hydraulic filter press in 2011, increasing the percent solids of the final Uranium
Material to between 25% and 45% resulting in a proportional increase in weight percent
uranium estimated to be between 0.3 and 0.55 wet weight percent uranium (0.35 and 0.65
wet weight percent U308).
The plant is typically operational from early May through the end of October and
operates 24 hours per day, four days per week. Barium chloride is added to the influent
water upstream of the neutralization tanks for removal of radium. The lime slurry is
added to the second of three neutralization tanks for metals precipitation. At the
discharge of the third neutralization tank, an anionic water soluble polymer (Neo
Solutions NS-68S2) is added as a coagulant during clarification. The stream is sent to
one of two clarifiers and the sludge drawn from the bottom and currently sent to a
centrifuge for dewatering. As mentioned above, the centrifuge will be replaced in 2011
with a plate filter press, and solids content is expected to increase to 25 to 45 percent.
The WTP solids decant is sent to the clarifier overflow tank, where it is pH adjusted to
between 6.5 and 9.0 using sulfuric acid, and a polyacrylic scale inhibitor are added prior
to discharge. Neither the sulfuric acid nor anti-scalant are introduced to the sludge
generation process and therefore are not considered in the determination of tailings
compatibility or worker safety and environmental hazards analyses.
Once dewatered, the pressed WTP solids will fall directly from the filter press into the
bed of the transport vehicle when the dewatering is complete. The transport truck is
housed within the WTP building and remains on site until it is covered with a dedicated
tight tarp and the material hauled to the off site for disposal or processing. From 1992
through 2007, the WTP produced between 1.05M lbs and 9.3M lbs per year of treatment
solids (average 4.8M lbs or 69,760 cubic feet at 15% solids).
The WTP solids, also referred to as the Uranium Material, has been tested for natural
uranium for the past eight years (2002-2009). In addition, three samples were collected
in 2010 from this year's production of WTP solids (WTPS-1, -2, -3). The 2010 samples
were analyzed for the following RCRA characteristic and listed hazardous waste
properties: total uranium, total mercury, total metals, TCLP metals and mercury, Lead-
210, isotopic thorium, total alpha emitting radium, volatile organic compounds
("VOCs"), semi-volatile organic compounds ("SVOCs"), diesel range organics ("DRO"),
gas range organics ("GRO"), pesticides, herbicides, inorganics (reactive cyanides and
reactive sulfides), and ignitibility. These data are summarized in the tables below.
The Uranium Material, which contains more than 0.05% uranium, is definitional source
material as per 40 CFR Part 261.4 and is explicitly exempt from regulation under RCRA.
However, for the sake of completeness, the "Protocol for Determining Whether Alternate
Feed Materials are Listed Hazardous Wastes" (November 22, 1999), developed by
Denson Mines in conjunction with, and accepted by, the State of Utah Department of
Environmental Quality ("UDEQ") (Letter of December 7, 1999) was applied to these
data. Based on this evaluation, the uranium materials does not contain any listed or
characteristic hazardous wastes. See Review of Chemical Contaminants in Dawn Mining
Company (DMC) Midnite Mine Uranium Material to Determine the Potential Presence
of RCRA Characteristic or RCRA Listed Hazardous Waste, Tetra Tech. November 2010.
D.3 & D.4 ANALYTICAL RESULTS FOR TOXICITY CHARACTERISTICS
See Summary Tables Below.
D.7 CHEMICAL COMPOSITION
See Summary Tables Below.
Uranium Material Organics and Pesticides Analyses, RCRA Toxicity Characteristics (TCLP)
Organothlorlne Pastkkles • Method SW8081A - TCIP leachate
Gamma-BHC (lindane) mg/l <0.0001 <0.0001 <0.M01
Heptachlor mgA <0.0001S <0.0001S <0.00015
Heptachlor Epoxide ng/L <0.0O0079 <0.000079 <O.O00079
Gamma-Chlordana mg/l <0.000078 <a00007S <0.00007S
Alpha-Chlordant «0.00009 <0.00OO9 <0.00009
Endrin mg/l <0.000096 <0.00009G <0.000096
Mcthoxythlor mg/l <0n0039 <O.C0O39 <0.00039
Toxaphene mg/l_ cO.OOSl <onosi <0.0051
Chlordane mg/l <0MU <0.0011 <0.00U
Chlorlnatad Harblcidai - Method SW8151A - TCIP leachate
2,4-0 M»A <1.6 <1.6
Silvex Mg/l-<0.12 <U2 <0.12
GC/MS Semlvelatllw - Method SW8270O • TOP leachate
Pyridine mg/L <0.02 <0.02 <0.02
1,4-Okhlorobeniene mg/l <0D2 <0.02 <0.02
2-Mathvlphenol |o Crasol) ng/L <0.02 <0.02 <0.02
3+4-Methylpln,nol (m+p Ccesol) mg/l <0.02 <0 02 <0.02
Hexachloroethane mg/l <0.02 c0.02 <0.02
Nitrobentene mg/L cO.02 <0.02 <0.02
Hexachlorobutadlene mg/l <0.02 <0.02 <0.02
2,4,6-Tfichlorophenol mg/l <0i)2 <0.02 <0.02
2,4.5-Trichloroprienol mg/l <0.02 <0.02 •cO.02
2,4-Oinitrotoluenc mg/l <0.02 <0.02 <0.02
Hexachlorobeiuene mg/l <0 02 cO.02 <0.02
Pentachlorophenol mg/l <0.043 <0.O43
GC/MS VotatHei • Method SW82S0_25B • Leachate
Vinyl Chloride Mg/l <0.S3 <0.83 <0&i
1^4)lehic*oethene*_ Mg/l <0.83 <0.S3 <0.S3
2-Butanone (Methyl Ethyl Keytone) MgA <8.3 <8J <8.3
Chloroform MS/l <0.83 <0.83 <0.83
Carbon Tetrachloride <0.83 <0.83 <0.83
1.2-Qlctuoroetriane Mg/l <0.83 <0.83 <0.83
Bwuene <0.83 <0.83 <0.83
Trichloroethene* MgA 2,7 BJ 1,5 8J <0.83
Tetrachloroethene* M&/1 <0.83 <0.83 <0.83
Chlorobenzene Mg/l <033 <0.83 <0.83
Inorganics - Method SW 846_7.3.1 (Cyanide) & _7.3.2 [Sulfide). SW904SC (pH)
Reactive Cyanide ng/xg <0.1 <0.1
Reactive Sulfide mg/SL <S0 <50 <50
Solid pH In Water g25'C PH 9.09 9.19 9.26
Ignltabllity • Method 5W1010A
lgnjtabiltty-9S'C U u
BsThls flag is i»ed when the anatyte Is detected In the associated method blank as well as in the sample. It Indicates probable blank
contamination and warns the data user. This flag shad be used for a tentatively Identified compound (TIC) as well as for a positively
identified target compound.
J-Thls flag indicates an estimated value. This flag is used as follows: (1) when estimating a concentration for tentatively Identified
compounds (Ties) where a 1:1 response is assumed; (2) when the mass spectral and retention time data Indicate the presence of a
compound that meets the volatile and seml-colatile GC/MS Identification criteria, and the result is less than the reporting limit (RL)
but greater than the method detection limit (MOl); (3) when the data Indicate the presence of a compound that meets the
Identification criteria, and the result Is less than the Rl but greater than the MDl; and (4) the reported value is estimated.
TUPAC compounds ending in "ethane" are equivalent to 'ethylene*.
lb TETRA TECH
Historic Total WTP Uranium Material Testing Data
Date
Initial Composite
Sample
U-nat
<ma/kg)
Annual Composite
Sample
Ra-226 U-nat
MM.
Ra-226
4/1/2003 11,100 5.7 9,700 5.3
4/1/2004 9,060 7.6 8,600 2.4
4/1/2005 12,900 14 19,000 11
4/1/2006 5,200 4.3 11,200 9.1
4/2/2007 2,700 4.7 12,000 24.2
4/9/2008 19,000 5.1 13,500 10.8
5/20/2009 8.7
Count
Max 19,000 8.7 19,000 24
Min 2,700 4.3 8,600
Avg 9,993 7.2 12,154 10
Data from Dawn Mining Annual Environmental Reports unless noted
All results are presented on a dry weight basis
lb TETRATECH
Uranium Material Metals Analysis for RCRA Characteristics
Sample
ID
Sample
Date
Arsenic Barium
m9/L mg/L
Cadmium
m9/L
Chromium
m9/L
Lead
mg/L
Mercury
mg/L
Selenium
mg/L
Silver
mg/L
2002 <0.05 <10 <0.1 <0.5 <0.5 <0.02 <0.1 <0.5
2003 <0.5 <10 0.2 <0.5 <0.5 <0.02 <0.1 <0.5
2004 <0.5 <10 <0.1 <0.5 <0.5 <0.02 <0.1 <0.5
2005 <0.5 <10 <0.1 <0.5 <0.5 <0.02 <0.1 <0.5
2006 <0.5 <10 0.25 <0.5 <0.5 <0.02 <0.1 <0.5
2007 <0.5 <10 <0.1 <0.5 <0.5 <0.02 <0.1 <0.5
2008 <0.5 <10 <0.1 <0.5 <0.5 <0.02 <0.1 <0.5
5/20/2009 <0.5 <10 <0.1 <0.5 <0.5 <0.02 <0.1 <0.5
9/17/2009 <0.06 0.083 <0.005 <0.01 <0.04 <0.0002 <0.06 <0.01
9/19/2009 <0.04 0.16 0.019 <0.01 <0.04 <0.0002 <0.04 <0.01
9/23/2009 <0.04 0.12 0.011 <0.01 <0.04 <0.0002 <0.04 <0.01
10/6/2009 <0.1 0.066 0.03 0.03 <0.08 <0.0002 0.2 <0.02
WTPS-1 4/13/2010 <0.1 <1 <0.05 <0.1 <0.03 <0.002 0.051 <0.1
WTPS-2 4/13/2010 <0.1 <1 <0.05 <0.1 <0.03 <0.002 0.054 <0.1
WTPS-3 4/13/2010 <0.1 <1 <0.05 <0.1 <0.03 <0.002 0.054 <0.1
Count 15 15 15 15 15 15 15 15
Min <0.04 0.066 <0.005 <0.01 <0.03 <0.0002 <0.04 <0.01
Max <0.1 <10 <0.05 <0.5 <0.5 <0.02 0.2 <0.5
40 CFR Part 261.24
PASS? Yes
100
Yes
1
Yes Yes Yes
0.2
Yes Yrs Yes
2
It TETRA TECH
Uranium Material Analyses
Target Analyte Units'
Results
WTPS-1 | WTPS-2 | WTPS-3 Average
Total Uranium - Method SW6020A
Total Uranium mg/kg
mg/L
15,000
2,475
16,000
2,640
15,000
2,475
15,333
2,530
Total ICP Metals - Method SW6010B
Arsenic mg/kg
mg/L
<5.9
<0.97
<5.9
<0.97
<5.7
<0.94
<5.8
<0.96
Barium mg/kg 8,100 7,900 7,200
mg/L 1,337 1,304 1,188
7,733
1,276
Beryllium mg/kg 33 36 36
mg/L 5.4 5.9 5.9
35
5.8
Cadmium mg/kg 40 43
mg/L 6.6 7.3 7.1
42
7.0
Calcium mg/kg 15,000 16,000 16,000
mg/L 2,475 2,640 2,640
15,667
2,585
Chromium mg/kg 19 20 19
mg/L 3.1 3.3 3.1
19
3.2
Cobalt mg/kg 1,200 1,200 1,100
mg/L 198 198 182
1,167
193
Copper mg/kg 160 180 170
mg/L 26 30 28
170
28
mg/kg 690 740 740
mg/L 114 122 122
723
119
Lead mg/kg 18 19 17
mg/L 3.0 3.1 2.8
18
3.0
Manganese mg/kg 110,000 110,000 96,000
mg/L 18,150 18,150 15,840
105,333
17,380
Molybdenum mg/kg <5.8 <6.0 <5.7
mg/L <0.96 <0.99 <0.94
<5.8
<0.96
Nickel mg/kg 1,700 1,800 1,800
mg/L 281 297 297
1,767
292
Selenium mg/kg 25 26 26
mg/L 4.1 4.3 4.3
26
4.2
Silver mg/kg 11 12
mg/L 2.0 1.8
11
1.9
Thallium mg/kg <580 <600 <570
mg/L <96 <99 <94
<583
<96
Tin mg/kg <29 <30 <29
mg/L <4.8 <5.0 <4.8
<29
<4.8
Vanadium mg/kg <5.8 <6.0 <5.7
mg/L <0.96 <0.99 <0.94
<5.8
<0.96
Zinc mg/kg 3,400 3,600 3,600
mg/L 561 594 594
3,533
583
Total Mercury - Method SW7471A
Total Mercury mg/kg <0.19 <0.2 <0.19 <0.19
Total Mercury mg/L <0.031 <0.033 <0.031 <0.031
3
It TETRA TECH
Uranium Material Analyses
Target Analyte Units WTPS-1
Results
WTPS-2 WTPS-3 Average
GC/MS Total Volatile Organics - Method SW8260
Chloromethane MgAg <1.1 <1.2
mg/L <0.182 <0.198
<1.1
<0.182
<1.1
<0.182
Acetone 22 B 29 B
mg/L 3.6 4.8
33 B
5.4
28
4.6
Methylene Chloride Mg/kg 3.8 J,B 3.7 J,B
mg/L 0.6 0.6
5.8 J,B
1.0
4.4
0.7
2-Butanone MgAg <5.7 <5.9
mg/L <0.94 <0.97
<5.7
<0.94
<5.8
<0.96
Tetra hydrofuran <7.2 <7.4
mg/L <1.19 <1.22
<7.2
<1.19
<7.3
<1.20
Chloroform 1.7 J 2J
mg/L 0.28 0.33
1.2 J
0.20
1.6
0.27
Carbon Tetrachloride Mg/kg <1.3 <1.4
mg/L <0.21 <0.23
<1.3
<0.21
<1.3
<0.21
Benzene Mg/kg <0.94 <0.96
mg/L <0.155 <0.158
<0.93
<0.153
<0.94
<0.155
Toluene Mg/kg 2.2 J,B 1.9 J,B
mg/L 0.36 0.31
1.3J,B
0.21
1.8
0.30
m,p-Xylene Mg/kg <1.9 <1.9
mg/L <0.31 <0.31
<1.9
<0.31
<1.9
<0.31
o-Xylene Mg/kg <0.95 <0.97
mg/L <0.157 <0.160
<0.94
<0.155
<0.95
<0.157
Naphthalene Mg/kg <1.4 <1.4
mg/L <0.23 <0.23
<1.4
<0.23
<1.4
<0.23
GC/MS Total Semi-Volatile Organics - Method SW8270O
Pyridine Mg/kg <310 ^320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
1,4-dichlorobenzene Mg/kg <310 <320
mg/L <51.2 <S2.8
<320
<52.8
<317
<52.3
2-methylphenol Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
3+4-methylphenol Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
Hexachloroethane Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
Nitrobenzene Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
Hexachlorobutadiene Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
2,4,6-trichlorophenol Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
2,4,5-trichlorophenol Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
2,4-dinitrotoluene Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
Hexachlorobenzene Mg/kg <310 <320
mg/L <51.2 <52.8
<320
<52.8
<317
<52.3
Pentachlorophenol Mg/kg
mg/L
<490
<81
<500
<83
<500
<83
<497
<82
4
lb TETRATECH
Uranium Material Analyses
Target Analyte Units' in
Results
WTPS-1 WTPS-2 WTPS-3 Average
Gasoline Range Organics - Method SW8015B
Gasoline Range Organics mg/kg
mg/L
<0.38
<0.063
<0.35
<0.058
<0.39
<0.064
<0.37
<0.061
Diesel Range Organics - Method SW801SMB
Diesel Range Organics mg/kg
mg/L
<6.5
<1.07
<6.6
<1.09
<6.8
<1.12
<6.6
<1.09
Oil & Grease
Oil & Grease mg/kg
mg/L
<120
<20
<120
<20
<120
<20
<120
<20
Inorganics
Ammonia as N - Method
EPA350.1 mg/kg
mg/L
7.9
1.30
7.9
1.30
8.3
1.37 1.33
Nitrate/Nitrite as N -
Method EPA353.2
Revision 2
mg/kg
mg/L
3.1 3.2
0.51 0.53
3.1
0.51
3.1
0.52
Total Dissolved Solids -
EPA160.1 mg/kg
mg/L
26,000 26,000
4,290 4,290
27,000
4,455
26333.3
4345.0
Fluoride - Method
EPA300.0 Revision 2.1 mg/kg
mg/L
38 38
6.3 6.3
40
6.6
38.7
6.4
Chloride - Method
EPA300.0 Revision 2.1 mg/kg
mg/L
40 39
6.6 6.4 6.8
40
6.6
Sulfate - Method
EPA300.0 Revision 2.1 mg/kg
mg/L
17,000 17,000
2,805 2,805
17,000
2,805
17,000
2,805
Gross Alpha/Beta - GFPC
Gross Alpha
Gross Beta
pCi/g
PCi/g
4,310±690
4,870±780
4,830±770
4,780±760
5,440±870
4,860±780
4,860
4,867
Lead-210 - Liquid
Scintillation
Lead-210 PCi/g 33.1±8.0 34.7±8.4 32.0±7.8 33.3
Radium-226-GFPC
Radium-226 PCi/g 22.8±5.8 25.7±6.6 23.8±6.1 24.1
Total Alpha Emitting
Radium-GFPC
Total Radium pCi/g 39.7±10 41±11 36.6±9.4 39.1
Total Radium (duplicate
sample) pC'/g 35.8±9.2
Isotopic Thorium - Alpha
Spectroscopy
Th-228 PCi/g 1.24+0.99 1.50±0.74 0.93±0.67 1.22
Th-230 PO/g 20.4±3.8 21.4±3.9 20.4±3.7 20.7
Th-232 pCi/g 1.14±0.48 0.66+0.34 0.71±0.32 0.84
5
Attachment 1
US Ecology Richland Materials
1.2 US Ecology Low-Level Radioactive Waste Generator Registration
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
US Ecology Radioactive Waste
Generator Registration
(1)
(2)
Please Print or Type
Generator Name Pawn Mining Company
PO Box 250 Corporate
Billing
Address
City
Zip Code
Ford State Washington
99013 0250
(3)
(4)
(5)
(6)
(7)
(9)
Generating
Facility
Address
City
State
Midnite Mine Hater Treatment: Plane
6834 Ford Wallpinit Road
Wellpinit County steven8
Washington Zip Code 99040 6834
Generator Administrative Contact: Robert He 1 eon
Generator Administrative Title: Site Manager
Generator Telephone:
Working Hours ( S09 ) - 258 4511
Fax No. (_ J
After Hours Telephone:
( 509 ). 936 . 0688
E-Mail drocbobawildblue.net
Site Use Permit nurnber(s) G-\\t»L
Description of Business:
Uranium Mine - water treatment
Please indicate your 4 digit Standard Industry Code (SIC) here: 1094
(8) Will you be using the services of a broker in shipping wastes to US Ecology for disposal:
a No D Yes
Name of Broker: Broker Permit #
How much waste do you expect to ship during a typical 12 Month Period: to be deterrflayj
RETURN COMPLETED
FORM TO:
US ECOLOGY, DMC
Laura Lee Barry
1777 Terminal Drive
Richland, WA 99354
Fax [phone]
Signature
Print Name
Tide
Date
fcgflg*cr £r, /Jets* J
FOR OFFICIAL USE ONLY
Generator Number Assigned By Date
Attachment 1
US Ecology Richland Materials
1.3 Washington State Site Use Permit
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
SITE USE PERMIT
for the Commercial Low-Level Radioactive Waste Disposal Site
PERMIT NUMBER: G1166
ST
EXPIRATION DATE: 2/29/2012
Registrant: DAWN MINING COMPANY
PO BOX 250
FORD, WA 99013-0250
For Waste Generated in the State of: VVA
The person or organization to whom this certificate is issued must comply with applicable federal and state regulations
related to the safe management of low-level radioactive waste.
Permit Does Not Imply Approval
KCYUI0-2-78-G (2/93)
Attachment 1
US Ecology Richland Materials
1.4 US Ecology Radioactive Materials License
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
STATE OF WASHINGTON
DEPARTMENT OF HEALTH
OFFICE OF RADIATION PROTECTION
111 Israel Road St • PO Box 47827 • Olympia, Washington 98504-7827
TDD Relay Services: 1-800-833-6388
January 24, 2011
Michael R. Ault
Facility Manager
US Ecology, Inc.
1777 Terminal Drive
Richland, Washington 99354
Subject: Radioactive Materials License WN-IO19-2 Timely Renewal
Dear Mr. Ault:
Enclosed is your notice of timely renewal. This notice allows your facility to continue operating
under your current expired radioactive materials license WN-IO 19-2, until the department has
completed the renewal process of this license.
If you have any questions or concerns regarding this notice, please feel free to contact me or
Kristen Schwab.
Sincerely,
Mikel Elsen, Supervisor
Waste Management Section
cc: Kristen Schwab, DOH
State of Washington
Radioactive Materials License
Page 1 of 1
License Number: WN-I019-2
Amendment No. 39
US ECOLOGY WASHINGTON, INC.
1777 Terminal Drive
Richland, Washington 99354
Attention: Mike Ault
Facility Manager
In accordance with WAC 246-235-050 your application received in proper form on December
28, 2010, and additional clarifying information received January 14, 20, and 21, 2011, are
considered adequate as a timely request for renewal. Therefore, your existing license number, as
shown above, will not expire until the department has made a final determination regarding the
application.
The reviewer assigned to your license is Kristen Schwab, who can be reached by phone at 360-
236.3244, or by email at [e-mail]. If you have any questions regarding this
renewal, please contact either myself at 360-236-3241, or Kristen Schwab.
FOR THE STATE OF WASHINGTON, DEPARTMENT OF HEALTH
NOTICE OF TIMELY RENEWAL
Date: January 24, 2011
Mikel J. Els^n, Supervisor
Waste Management Section
State of Washington
Radioactive Materials License
Page 1 of 1
License Number: WN-IO 19-2
Amendment No. 37
US ECOLOGY WASHINGTON, INC.
1777 Terminal Drive
Richland, Washington 99354
Attention: Mike Ault
Facility Manager
Radioactive Materials License Number WN-1019-2 is adniinistratively amended as
follows:
License Condition 84 is added:
84. The licensee must comply with the initial inventory reporting requirement in 10
CFR 20.2207(h) for nationally tracked sources by the dates imposed in that
paragraph. The licensee must also comply with the reporting requirements for
transactions involving nationally tracked sources in 10 CFR § 20.2207. This
section includes the requirement to report any manufacture, transfer, receipt,
disassembly, or disposal of a nationally tracked source, otherwise allowed by this
license, by the close of the next business day after the transaction. A nationally
tracked source, as defined in 10 CFR § 20.1003, refers to a sealed source
containing a quantity equal to or greater than Category 1 or Category 2 levels of
any radioactive material listed in Appendix E to 10 CFR Part 20 - "Nationally
Tracked Source Thresholds."
FOR THE STATE OF WASHINGTON DEPARTMENT OF HEALTH
Date: January 26. 2009
Mike! J. Elsqfi Supervisor
Waste Management Section
State of Washington
Radioactive Materials License
Page 1 of 24
License Number: WN-1019-2
Pursuant to the Nuclear Energy and Radiation Control Act, RCW 70 98. and the Radiation Control Regulations, chapters 246-220 through
246-255 WAC, and in reliance on statements and representations heretofore made by the licensee designated below, a license is hereby
issued authorizing such licensee to transfer, receive, possess and use the radioactive matcnaj(s) designated below; and to use such
radioactive materials for the purposes) and at the place(s) designated below. This license is subject lo all applicable rules tod
regulations promulgated by the Slate of Washington Department of Health.
1. Licensee Name:
US ECOLOGY WASHINGTON, INC.
3. License Number:
WN-1019-2
Amendment in Entirety
Amendment 36
2. Address:
1777 TERMINAL DRIVE
RICHLAND, WASHINGTON 99354
Attn: Mike Ault, Facility Manager
4. Expiration Date:
31 January 2011
5. Reference Number(s):
6. Radioactive Material
(element and mass number).
7. Chemical and/or Physical Form.
6.A. Any radioactive material, 7.A. Dry packaged radioactive
excluding source material waste except as authorized
and special nuclear
material.
by this license.
8. Maximum quantity licensee may
possess at any one time.
8.A. 60.000 curies
(2.22 x1015 Bequerels).
6.B. Source material.
6.C. Special Nuclear Material.
7.B. Dry packaged radioactive
waste except as authorized
by this license.
7.C. Dry packaged radioactive
waste except as authorized
by this license.
8.B. 36,000 kilograms.
8.C. 350 grams of U235 or 200
grams of U233 or 200 grams
of plutonium or any
combination of these,
provided the sum of the
ratios of the quantities does
not exceed unity.
6.D. Any radioactive material. 7.D. Check and calibration
sources in any form.
8.D. 0.1 Curie
(3.7 x 109 Bequerels).
State of Washington
Radioactive Materials License
Page 2 of 24
License Number: WN-1019-2
Amendment 36
CONDITIONS
9. Authorized use.
A-C Radioactive waste may be received, transferred, stored, repackaged, and
disposed at a low-level radioactive waste disposal facility. The maximum
radioactivity and/or quantity of radioactive material indicated in items 8.A, 8.B, and
8.C apply only to above-ground activity.
For use as check and calibration sources.
The licensee shall not receive for disposal any waste containing Ra-226, H-3.
1-129, Tc-99, U-238, C-14. U-234, and Pu-239 once the following source term
limits have been reached:
9TA7$
1869
D.
10. A.
Radionuclide Total Site Limit (Curies)
Ra-226 464.60
1-129 5.98
Tc-99 55.10
U-238 1,547.7
C-14 5,090.00
U-234 335.4
Pu-239 4,510.00
B. Commencing January 1, 2006, the licensee shall not receive for disposal, any
waste containing H-3 in an unstable waste form once the following yearly source
term limit has been reached:
Radionuclide Yearly Limit (Curies)
H-3 (unstable waste form) 100.0 Curies
11. The authorized place of use is a low-level waste burial facility located in the southeast
comer of Section 9, Township 12 North, Range 26E W.M., Benton County, Washington,
Route 4 - U.S. DOE Hanford Reservation, Richland, Washington 99352, within the
boundary of the land area described in Sublease Agreement with the state of
Washington, dated July 29, 1965, as amended. For the purposes of this license, the
authorized place of use shall be referred to as the "facility."
State of Washington
Radioactive Materials License
Page 3 of 24
License Number: WN-I019-2
Amendment 36
12. Reference to the "department" in this license shall mean the Department of Health or
successor agency.
13. A. The licensee shall notify the department in writing within 30 days of the appointment
of a new Facility Manager, Assistant Facility Manager, Radiation Protection
Manager, or Assistant Radiation Protection Manager, describing how the appointee
meets or exceeds the minimum qualifications specified in the Facility Standards
Manual.
B. The licensee shall notify the department in writing 30 days prior to any change in the
licensee's corporate structure.
14. Upon receipt of a shipment, the licensee shall furnish to the department copies of all
shipment manifests received. The licensee shall furnish to the department, within 30
days of a specific written request, special reports consisting of selected information
contained on shipment manifests. By the tenth day of each month, the licensee shall
submit a report totaling the volume and activity of the waste received during the previous
month. In addition, a monthly facility receipt and burial activities report shall be submitted
by the licensee, no later than the fifteenth day of the following month to the Department of
Health, Supervisor, Waste Management Section. The report shall include the following
information for each shipment:
A. Name and address of the generators), broker (if any), and shipper.
B. Radionuclides and activity of each radionuclide in millicuries (total and by generator).
C. Grams of special nuclear material (total and by generator).
D. Mass (in kilograms) of source material received (total and by generator).
E. Class totals of volume and activity of Class A, B, and C waste entrenched (total and
by generator).
F. Volume of packages disposed with radiation readings at the surface of the disposal
container of:
£50 mr/hr
>50 mR/hr £200 mR/hr
>200 mR/hr £1 R/hr
>1 R/hr £10 R/hr
>10 R/hr £100 R/hr
>100 R/hr
and to the extent practicable:
State of Washington
Radioactive Materials License
Page 4 of 24
License Number: WN-IO 19-2
Amendment 36
G. Type and physical form of the waste.
H. Chemical form of the waste and solidrTication/stabilizatton/sorption agent used.
I. If an Engineered Concrete Barrier (ECB), or High Integrity Container (HIC) was
used (total and by generator).
J. Quantity and type of chelates in concentrations greater than 0.1 percent by weight
(total and by generator).
K. Type of secondary containment used (if any).
L. Volume of diffuse Naturally Occurring or accelerator produced radioactive
material received (total and by generator).
15. in addition to the record keeping requirements contained in WAC 246-250-600, the
licensee shall maintain a record for each shipment of waste disposed at the facility. As a
minimum, the record shall include:
A. The date of disposal of the waste.
B. The location of the waste in the disposal site.
C. The condition of the waste packages as received.
0. Any discrepancies between materials listed on the manifest and those received.
E. Any evidence of leaking or damaged packages or radiation or contamination levels
in excess of limits specified in United States Department of Transportation and
state of Washington regulations.
F. A description of any repackaging operations of any of the waste packages in the
shipment.
G. Type of secondary containment used (if any).
State of Washington
Radioactive Materials License
Page 5 of 24
License Number: WN-IO 19-2
Amendment 36
GENERAL PACKAGING CONDITIONS
16. All radioactive waste shall be packaged, loaded, received, and transported in accordance
with all applicable U.S. Department of Transportation regulations, U.S. Nuclear
Regulatory Commission regulations, state regulations, and the requirements of this
license. Nothing in this license shall in any way relieve the licensee from full compliance
with all applicable state and federal laws and regulations, including but not limited to the
Resource Conservation and Recovery Act of 1976, as amended, and the State
Hazardous Waste Management Statutes of 1976, as amended, and subsequently
enacted regulations.
17. Unless otherwise authorized, the licensee shall not receive for disposal any mixed low-
level radioactive waste. Mixed waste is defined as any radioactive material which is no
longer of use or value, and contains waste that either (A) is fisted as dangerous waste in
the state's Dangerous Waste Regulations, (B) causes the waste to exhibit any of the
dangerous waste characteristics identified in the state's Dangerous Waste Regulations,
(C) fulfills any of the "dangerous waste criteria" identified in the state's Dangerous Waste
Regulations, (D) listed as hazardous waste in Subpart D, 40 CFR Part 261, or (E) causes
the waste to exhibit any of the hazardous waste characteristics identified in Subpart C, 40
CFR Part 261.
18. Unless specifically authorized by the department, all radioactive waste shall be received
and buried in closed containers. Cardboard, corrugated paper, wood, and fiberboard are
prohibited burial containers.
19. All metal containers shall be secured by an intact heavy-duty closure device when
presented for disposal. Closure devices of open-head metal drums having 55-galtons or
greater capacity shall be secured by bolts having 5/8 inch or larger diameters. The
shipper of any DOT 7A Type A container must maintain on file complete documentation
of tests and an engineering evaluation or comparative data showing that the construction
methods, packaging design, and materials of construction comply with that specification.
20. Radioactive waste shall be packaged in such a manner that waste containers received at
the facility do not show:
A. Significant deformation.
B. Loss or dispersal of contents.
C. An increase in the external radiation levels as recorded on the manifest, within
instrument tolerances.
State of Washington
Radioactive Materials License
Page 6 of 24
License Number: WN-I019-2
Amendment 36
D. Degradation due to rust or other chemical action which results in a loss of
container integrity
21. Void spaces within the radioactive waste and between the waste and its package shall be
reduced to the maximum extent practicable. Unless specifically approved by the
department, void spaces within all waste packages shall be less than 15 percent of the
total volume of the disposal package, provided the disposal package is not a high integrity
container nor contains activated metals that are too large to put into high integrity
containers. For Class B and Class C waste packages containing activated metals, voids
shall be reduced to the extent practicable and shall be demonstrated to be structurally
stable by any of the methods discussed in WAC 246-249-050(2Xa). This documentation
shall be submitted to the department prior to disposal, and shall be kept on file by the
licensee.
22. Waste shall not contain, or be capable of generating, toxic gases, vapors, or fumes during
transportation, handling, or disposal.
23. No pyrophoric, hazardous, dangerous, or chemically explosive materials or materials
which could react violently with water or moisture or when subject to agitation shall be
accepted for disposal.
24. Waste or packaging shall not contain any liquid except as authorized by this license.
25. In order to keep doses as low as reasonably achievable (ALARA), the licensee shall not
receive shipments of radioactive material unless appropriate lining devices of sufficient
length have been provided and securely attached to containers and palletized shipments
within a cask.
26. The licensee shall not accept radioactive waste unless each waste package has been:
A. Classified in accordance with Appendix A of this license and the most recent
version of the "Low-Level Waste Licensing Branch Technical Position on
Radioactive Waste Classification," issued May 1983 by the U.S. Nuclear
Regulatory Commission.
B. Marked as either Class A stable, Class A unstable. Class B, or Class C, as defined
in Appendix A of this license and the most recent version of the "Low-Level Waste
Licensing Branch Technical Position on Radioactive Waste Classification," Issued
May 1983 by the U.S. Nuclear Regulatory Commission.
State of Washington
Radioactive Materials License
Page 7 of 24
License Number: WN-IO 19-2
Amendment 36
C. Marked with a unique package identification number, clearly visible on the
package, that can be correlated with the manifest for that particular shipment.
D. Stabilized, when required by this license, in accordance with criteria contained in
the most recent version of the Technical Position on Waste Forms," issued May
1983 by the U.S. Nuclear Regulatory Commission, and procedures that are
described in approved vendor topical reports. Only those stabilization media
approved by the department and listed in Appendix C to this license, or High
Integrity Containers approved by the department and listed in Appendix D to this
license may be used. Stability may also be achieved using engineered barriers in
the disposal unit. Specific approval by the department is required prior to
construction of any newly designed or redesigned engineered barrier. Only those
engineered barriers listed in Appendix E of this license are approved for use at the
facility.
27. The classification and package identification marking required by Condition 26 is in
addition to any marking or labeling required by U.S. NRC or U.S. DOT, and shall consist
of lettering 1/2 inch high or greater in a durable contrasting color to the background
surrounding the lettering. The classification marking shall be visible on the same side as
the radioactive marking or label and in close proximity (within six inches). Waste
packages marked "Radioactive," "Limited Quantity," or "Radioactive LSA" need only one
classification marking, whereas waste packages labeled White I, Yellow II, or Yellow III
shall have classification markings in close proximity (within six inches) to each label.
Waste materials shipped in casks shall have the classification markings visible on the
outside of the cask.
28. The licensee may possess SNM that has not been disposed of at the facility, subject to
the following restrictions and all other conditions of this license:
A. No single package shall contain more than 100 grams of U-235, or 60 grams of U-
233, or 60 grams of Pu, or any combination thereof, such that the sum of the ratios
of the quantity of each SNM radionuclide to the quantities specified herein exceeds
unity. Compliance with this requirement shall be determined by the following
formula:
B. No single package shall contain more than 15 grams of any combination of U-235,
U-233, and Pu, per cubic foot of the total volume. To the extent practicable, the
SNM will essentially be uniformly distributed throughout the waste package.
grams containing U-235 + grams containing U-233 + grams containing Pu = <1
100 60 60
State of Washington
Radioactive Materials License
Page 8 of 24
License Number: WN-I019-2
Amendment 36
SPECIFIC WASTE FORM REQUIREMENTS
29. Except as allowed under this license, untreated liquids and wet sludges are not allowed
for disposal. Liquids shall be rendered non-corrosive (4<, pH <11) prior to treatment.
Acceptable treatments are stabilization or solidification, depending on waste class. Wet
sludges and slurries, such as evaporator bottoms, shall be non-corrosive and shall be
treated by stabilization or solidification. Ion exchange media shall not be treated by
sorption.
30. Liquids, ion exchange resins, or filter media treated by stabilization shall be processed in
accordance with a process control program using an approved stabilization medium (see
Appendix C). The resulting waste form shall contain no detectable free-standing liquid
and shall meet the stability requirements of Condition 26. "No detectable free-standing
liquid" is defined to be as little free-standing and noncorrosive liquid as is reasonably
achievable, but in no case shall the liquid exceed 1.0% of the volume of the waste when
the waste is in a disposal container designed to ensure stability, or 0.5% of the volume of
waste processed to a stable form.
31. Liquids treated by solidification shall be processed in accordance with a process control
program using an approved solidification medium (see Appendix B). The resulting waste
form shall contain no detectable free-standing liquid. "No detectable free-standing liquid"
is defined to be as little liquid as is reasonably achievable, but in no case shall it exceed
more than 0.5 percent (by volume) of liquid per container.
32. Except as specifically provided in this license, the licensee shall not accept for disposal,
any liquid radioactive waste packaged in sorbent material.
33. Incidental and unintentional liquids entrained in solid material may be received, provided
that:
A. (1) The dry material contains less than 0.1 volume percent of liquid within the
package, or
(2) If a process control program (PCP) is used to verify the amount of liquids, the
dry material must contain less than 0.5 volume percent of liquids within the
package and;
B. Sufficient approved sorbent material (see Appendix F) is used and layered to
absorb the incidental and unintentional liquids.
State of Washington
Radioactive Materials License
Page 9 of 24
License Number: WN-IO 19-2
Amendment 36
34. Waste containing biological (excluding animal carcasses, which are considered in
Condition 35). pathogenic, or infectious material or equipment (e.g., syringes, test tubes,
capillary tubes) used to handle such material, shall be treated to reduce, to the maximum
extent practicable, the potential hazard from the non-radiological materials. The inner
waste container shall be a metal container meeting DOT 7A performance specifications
(see Condition 19) and shall be lined with a minimum 4 mil plastic liner which shall be
sealed. The inner waste container shall be placed in an outer metal container meeting
DOT 7A performance specifications with a heavy duty closure device (see Condition 19)
and shall have a capacity at least 40 percent greater than the inner container. The void
between inner container and outer container shall be completely filled by approved
sorbent material and the outer container must be sealed. Only sorbents approved by the
department shall be allowed (see Appendix F).
35. Animal carcasses containing, or contained in, radioactive materials shall be packaged in
accordance with the following requirements: the biological material shall be layered with
absorbent and lime and placed in a metal container meeting DOT 7A performance
specification, having a heavy duty closure device (see Condition 19). The inner container
shall be closed and placed in a metal container meeting DOT 7A performance
specification with a heavy duty closure device, having a capacity at least 40 percent
greater than the inner container. The void between the inner container and the outer
container shall be completely filled by approved sorbent material and the outer container
must be sealed. Only sorbents approved by the department (except Perlites) shall be
used (see Appendix FV
36. Waste in gaseous form must be packaged at a pressure that does not exceed 1.5
atmospheres at 20°C. Total activity shall not exceed 100 curies (3.7 x 1012 Bqs) per
container. Class A gaseous waste shall be contained within U.S. DOT specification
cylinders. Class A gaseous waste contained in hermetically sealed glass ampules, tubes,
or sealed sources are exempt from the requirement for the specification cylinder provided
that they are packaged in containers meeting DOT 7A specifications, having a heavy duty
closure device (see Condition 19) and with sufficient sorbent material to prevent breakage
and rupture of its contents. Specific approval of the department is required if the gaseous
waste is Class B or C. Only sorbents approved by the department shall be used (see
Appendix F).
37. Class A ion exchange and filter media containing radionuclides with half-lives greater than
five years, the total package concentration of which is one microcurie (3.7 x 104 Bqs) per
cubic centimeter or greater, except Cobalt 60 having a concentration of 50 microcuries
per cubic centimeter or greater, shall:
State of Washington
Radioactive Materials License
Page 10 of 24
License Number: WN-I019-2
Amendment 36
A. Meet the stability requirements of Condition 26 and shall contain no detectable
free-standing liquid. "No detectable free-standing liquid" is defined to mean as
little liquid as reasonably achievable, but in no case shall the liquid exceed 1.0% of
the volume of the waste when the waste is in a disposal container designed to
ensure stability, or 0.5% of the volume of waste processed to a stable form. Other
Class A ion exchange and filter media which are classified as unstable shall
contain no more liquid than 0.5% by volume of the waste.
B. The calculations of concentrations of isotope activity will adhere to the "sum of
fractions being equal to or less than unity rule" for ion exchange resins and filter
media containing isotopes with half-lives greater than five years, with the exception
of Cobalt 60.
38. Radioactive waste containing radium and/or transuranic radionuclides, as described in
Appendix A. is acceptable, provided that the radium and transuranic radionuclides are
essentially evenly distributed within an homogenous waste form. The receipt and
disposal of waste in which the radium or transuranic radionuclides are not evenly
distributed (components, or equipment primarily contaminated with radium or transuranic
radionuclides), or radium or transuranic radionuclides in excess of Class A limits, requires
the specific approval of the department. Radioactive waste packaged in accordance with
License Condition 39 is exempt from this condition.
39. Radioactive consumer products, the use and disposal of which is exempt from licensing
control (see WAC 246-232), may be received for disposal without regard to concentration
limits of Appendix A. provided the entire unit is received and is packaged with sufficient
sorbent material so as to preclude breakage and rupture of its contents. Only sorbents
approved by the department shall be used (see Appendix F).
This condition allows the disposal of such consumer products as intact household or
industrial smoke detector units containing Americium-241 foils, and radium or other
radioactive materials incorporated into self-luminous devices and electron tubes.
Documentation that the consumer product was manufactured under a U.S. Nuclear
Regulatory Commission exempt license shall accompany each shipment made under this
condition. Waste packaged in accordance with this license condition shall be Class A
unstable, and the words "Condition 39" shall be noted on the manifest or other
documentation accompanying the waste package.
40. Incinerator ash which is classified as Class A waste according to Condition 26 shall be
solidified, granular, or treated in such a manner as to be rendered nondispersible in air,
exclusive of packaging.
State of Washington
Radioactive Materials License
Page 11 of 24
License Number: WN-IO 19-2
Amendment 36
41. Wastes containing a concentration of oil in excess of ten percent by weight are not
authorized for burial. Dilution by solidification or stabilization media shall not be allowed
in determining the waste composition. "Oil" means an organic liquid which is immiscible
in water, the disposal of which is not regulated under RCRA or the state hazardous waste
regulations.
42. Until alternative waste management techniques such as incineration or recycling become
generally available, waste liquids which have a pretreatment concentration of chelating
agents in excess of 0.1 percent by weight shall be treated by either solidification or
stabilization, and placed into an Engineering Concrete Barrier (ECB). Prior to receipt of
any chelate waste in excess of 1.0 percent by weight, the generator must notify the
licensee of the intent to ship such material for disposal. The notification shall consist of
telephone and written notification to the Facility Manager prior to shipment. Dilution by
solidification or stabilization media shall not be allowed in determining waste composition.
"Chelating agent" means amine polycarboxylic acids (e.g., EDTA, DTPA).
hydroxy-carboxylic acids and polycarboxylic acids (e.g., citric acid, carbolic acid, and
gluconic acid), the disposal of which is not regulated under RCRA or the state hazardous
waste laws. Additionally, the licensee shall record the three-dimensional location of the
ECBs containing these wastes
43. The licensee shall not accept for disposal any neutron source (e.g., polonium 210,
americium 241, radium 226 in combination with beryllium or other target) unless the
generator has notified the licensee of the intent to ship such source to the licensees
disposal facility. The notification shall consist of telephone and written notification to the
Facility Manager prior to shipment. The notification shall indicate the isotope, activity,
form of the source, a description of the packaging utilized, radiological data, and
anticipated date of arrival. Additionally, a copy of the written notification must accompany
the shipment made under this license condition.
44. The licensee is exempt from the timely inspection requirements of WAC
246-221-160(2Xa) and (3)(a), provided the requirements of the Facility Standards Manual
and Conditions 45 through 48 of this license are met.
45. Waste shipments shall not be accepted at the facility unless accompanied by the
following (a single shipment shall consist of not more than one vehicle or one tractor with
legal trailers) attached):
A. Shipment manifest approved by the department.
RECEIPT. ACCEPTANCE. AND INSPECTION CONDITIONS
State of Washington
Radioactive Materials License
Page 12 of 24
License Number: WN-I019-2
Amendment 36
B. Washington State Patrol or Washington State Utilities and Transportation
Commission vehicle inspection certificate, or a current visible Washington State
90-day vehicle inspection seal.
C. Current certification Form RHF-31, properly executed by a representative of the
shipper/generator of the waste, in accordance with requirements of Washington
State Rules and Regulations for Radiation Protection, WAC 246-249-030.
D. Copies of any specific approval or variance granted by the department for
disposal.
E. Upon departmental request, other permits or documentation required under this
license, or state or federal law or regulation.
46. Waste shipments shall not be accepted by the facility unless the accompanying Form
RHF-31 is stamped as received, and initialed by an authorized representative of the
department. (This individual may be the licensee, when designated by telephone
notification and confirming letter from the department.)
47. Upon acceptance for disposal of each waste shipment, the licensee shall:
A. Acknowledge receipt of the waste as soon as practicable, but no later than seven
days following its acceptance for disposal, by returning a signed copy or equivalent
documentation of the shipment manifest to the shipper. The shipper to be notified
by the licensee is the one last possessing the waste and transferring it to the
licensee.
B. Indicate on the returned copy of the shipment manifest, shipping papers, or
equivalent documentation any discrepancy between noted waste descriptions
listed on the manifest or papers and the waste materials received in the shipment.
C. Notify the shipper and the department when any shipment or part of a shipment
has not arrived 60 days after the separate copy of the shipment manifest or
shipping papers was received by the licensee.
0. Maintain copies of completed shipment manifests, including annotations of
discrepancies found in accordance with Condition 47.B.
E. Maintain records in accordance with in WAC 246-250-600.
State of Washington
Radioactive Materials License
Page 13 of 24
License Number: WN-I019-2
Amendment 36
48. Any shipment in which there is evidence that any radioactive material is missing, or that
the waste packages have been tampered with or damaged in transit, shall be received by
the licensee and safely stored pending notification to the department. The licensee shall
not dispose of such packages unless authorized by the department.
49. The manifest for each package of waste received for disposal shall list all radionuclides
greater than 3,700 kBq (100 microcuries).
50. Packages containing radioactive material shall not be stored above ground for a period
greater than ninety days from the date of the department's release of the packages.
Packages shall be stored in such a manner as to maintain radiation exposures as low as
reasonably achievable. Retention of packaged waste above ground for not more than
three working days does not constitute storage.
51. Unless otherwise specifically authorized by the department, the licensee is not authorized
to open any package containing radioactive material at the facility, except for the
A. For purposes of repairing, repackaging, or overpacking leaking containers or
containers damaged in transport in the event the material is to be disposed, or
returned to the generator if required for the protection of the health and safety of
the employees or the environment.
B. For purposes of inspection and waste confirmation in the presence of a
department inspector for compliance with Title 246 WAC, other applicable federal
and state regulations, and conditions of this license.
C. For purposes of returning outer shipping containers.
The licensee shall use and maintain a facility, in accordance with the Facility Standards
Manual, where the above operations can be safely conducted.
52. By June 1. 2006 the licensee snail dispose of all Class B, and C waste in a secondary
containment system which has been reviewed and approved by the department. In
addition, waste packages containing any of the following radionuclides, H-3,1-129, C-14,
Tc-99, U-238, U-234, and Pu-239, shall be disposed in accordance with procedures
approved by the department. Secondary containment shad be used for all packages that
exceed the predetermined levels contained in these procedures, and the Faculty
BURIAL OPERATIONS CONDITIONS
following:
State of Washington
Radioactive Materials License
Page 14 of 24
License Number: WN-IO 19-2
Amendment 36
Standards Manual. Levels shall be established such that at least 90% of the allowable
future source term activity for each listed isotope is placed in secondary containment. The
effectiveness of these procedures shall be evaluated annually and reported in the Facility
Utilization Report required by License Condition 71:
53. Class B and C waste packages stabilized with bitumen shall be backfilled immediately
after waste placement. Sufficient backfill material shall be placed around each container
to cover all sides around the packages.
54. Accumulations of waste packages, with an SNM Mass ratio (SNM Mass/ Package
Mass) that exceeds 0.0002 (1/5000), in quantities specified in this license, shall be
disposed so that there is a minimum of eight inches of soil or a minimum of four feet of
non-SNM-bearing waste in all directions from any other accumulation of packages
containing SNM in quantities specified in this license, with an SNM Mass ratio that
exceeds 0.0002.
55. Class B, and C waste packages must be disposed at a minimum depth of five meters
(16.5 feet) below the natural grade of the trench, as defined in the Comprehensive Facility
Utilization Plan.
56. All discrete radium 226 must be disposed in an engineered concrete barrier (ECB) at a
minimum depth of 23 feet below the natural grade of the trench, as defined in the
Comprehensive Facility Utilization Plan.
57. All burial trenches or disposal units shall be in a controlled area surrounded by a chain
link fence, eight feet high, and topped with barbed wire.
58. Thirty days prior to commencement of construction of any new disposal unit, the licensee
shall submit to the department a detailed engineering plan for the trench in accordance
with the provisions of the Facility Standards Manual, or a statement that the proposed
trench will be designed and constructed in accordance with Condition 60 of this license.
59. By June 30, 2006, the licensee shall submit, for approval by the department an updated
Comprehensive Facility Utilization and Engineering Plan which encompasses the
proposed site conditions for the expected lifetime of the facility. The Plan shall discuss, at
a minimum, the reasoning for the choice of design, and shall include detailed drawings
and calculations sufficient to support the conclusions reached. Changes to the Plan must
be submitted to the department for review and approval. The plan shall be updated and
submitted for approval by the department every five years.
SITE DESIGN AND CONSTRUCTION CONDITIONS
State of Washington
Radioactive Materials License
Page IS of 24
License Number: WN-I019-2
Amendment 36
60. Until an the updated Comprehensive Facility Utilization and Engineering Plan required by
Condition 59 is approved by the department, the licensee shall construct new disposal
units in accordance with the March 6,1991 department-approved Comprehensive Facility
Utilization Plan. Document 200-DOC-001, Rev. 3.
61. A. Upon completion of the construction of any new trench, submit to the department
two copies of the trench construction report. The report shall include, at a
minimum, as-built drawings, daily and final inspection reports, laboratory and field
soil test results, and a description of any problems encountered during
construction, in order to demonstrate that the construction of the disposal unit is in
compliance with applicable plans and specifications contained in the approved
Facility Utilization Plan.
B. 30 days prior to use of any new trench, notify the department in writing of the intent
to physically place waste in the trench.
62. The dimensions of burial trenches shall not exceed a width of 150 feet (46 meters), a
depth of 50 feet (15.24 meters), or a length of 1000 feet (305 meters) without specific
documented approval from the department. Measurements shall be referenced to natural
grade as established in the March 6,1991 department-approved Comprehensive Facility
Utilization Plan.
63. Until an agreement is secured with agencies controlling adjacent lands, which meets the
requirements of Condition 74 IK) of this license, disposal units constructed after the
effective date of this license shall be placed at least 100 feet away from the North, South,
and West subleasehold boundaries. The set-back distance for the East boundary shall
be no less than 50 feet.
64. The licensee shall perform an exposure pathway analysis of the site closure plan within
180 days of a department-approved closure plan. The licensee shall verify that the
proposed closure actions remain within the acceptable parameters developed and
established by the Environmental Impact Statements (EIS) "Comprehensive Exposure
Pathway Analysis". The verification shall include air, soil, ground water, vegetation, fauna,
burrowing animals, and human impacts. Additionally, the analyses shall be reviewed and
updated as necessary every four years subsequent to the approval of the pathway
analyses. Upon completion of the review, the licensee shall submit a copy of the review
to the department. This requirement is in addition to the requirements found in WAC 246-
250-060(1). Within 120 days of completion of the pathway analysis report, the licensee
ENVIRONMENTAL MONITORING AND SURVEY CONDITIONS
State of Washington
Radioactive Materials License
Page 16 of 24
License Number: WN-IO 19-2
Amendment 36
shall submit to the department the licensee's evaluation and analysis of the report with
respect to the environmental monitoring programs. The analyses shall clearly identify and
differentiate between the roles performed by the natural disposal site characteristics and
design features in isolating and segregating the wastes. The analyses shall clearly
demonstrate that there is reasonable assurance that the exposure to humans from the
release of radtoactivity will not exceed the limits set forth in WAC 246-250-170.
65. The licensee shall conduct an environmental monitoring program capable of detecting the
potential contribution of radioactive material from the site to the environment. The
program shall include collection of samples and analyses at frequencies specified in the
Facility Standards Manual (FSM). The licensee shall coordinate sampling schedules with
the department to provide, when possible, duplicate samples on a prearranged
frequency. A comprehensive annual report of all sample analyses, with statistical trend
analyses and discussions of all anomalous results and actions taken, specification of the
quantity of each of the principal contaminants released to unrestricted areas in liquid and
in airborne effluents during the preceding year, wind rose for the facility, depth to water,
and depth to bottom, Ph, as well as non-radiological contaminants specified in the FSM.
for all groundwater wells, ventilation exhaust samples taken from the inspection facility,
and comparisons of onsite groundwater wells and U.S. DOE groundwater wells in the
vicinity of the facility shall be forwarded to the department by June 1 of each year. The
report shall be submitted in general accordance with the department's document entitled
"Recommended Content and Format for Annual Environmental Reports." Deviations in
the reporting format must be approved by the department. In addition, the licensee shall
report immediately any environmental monitoring results in excess of reporting levels
specified in the Facility Standards Manual.
66. The licensee shall conduct an experimental monitoring program designed to determine
the extent and modes of migration of disposed waste into the unsaturated zone, in
accordance with procedures specifically approved by the department. Annual reports
shall be made to the department by June 1 of each year. The results of the program shall
be discussed in the annual Environmental Monitoring Report required by license
Condition 65.
67. The licensee shall, within 90 days of filling each disposal unit, closed after the effective
date of this license, erect interim disposal unit monuments upon which the following
information shall be displayed in a legible manner
TRENCH AND SITE CLOSURE CONDITIONS
State of Washington
Radioactive Materials License
Page 17 of 24
License Number: WN-I019-2
Amendment 36
A. Total activity of radioactive material, in curies, excluding source and special
nuclear materials, total amount of source materials in kilograms, and total amount
of special nuclear material in grams.
B. Trench number or disposal unit designation.
C. Date of opening and closing of the disposal unit.
D. Volume of waste contained in the disposal unit.
E. Coordinates of the disposal unit.
The erection of interim monuments may be omitted if permanent monuments, required by
Condition 73. are scheduled to be erected within six months of completion of the disposal
unit.
68. The licensee shall initiate closure and stabilization measures as each trench is filled and
covered in accordance with the schedule and performance criteria defined in the Final
Environmental Impact Statement for the Commercial Low-Level Radioactive Waste
Disposal Site, Richland Washington, dated May 28, 2004.
69. The licensee shall conduct closure and stabilization operations in accordance with the
most recent department-approved Comprehensive Facility Utilization Plan and the Facility
Closure and Stabilization Plan required by Condition 74 as each trench is filled and
covered.
70. In addition to the requirements of Condition 69. the licensee shall design and construct
interim disposal unit caps in accordance with the specifications contained in the Facility
Standards Manual. Interim disposal unit caps shall be established within 3 months of
completion of a disposal unit, or as described in the Comprehensive Facility Utilization
Plan approved by the department.
71. The licensee shall submit a facility utilization report to the department by June 30 of each
year. The report shall provide:
A. Identification of each disposal unit and description of all waste emplaced during
the previous calendar year. A three-dimensional identification to describe the
disposal location of each Class B, and C package of waste including the location
of engineered barriers used to provide structural stability, and the disposal location
of those wastes containing oils or chelates shall also be provided. The location of
Class A waste shall be tracked three-dimensionalry within 50 feet horizontally and
within 10 feet in the vertical plane.
State of Washington
Radioactive Materials License
Page 18 of 24
License Number: WN-I019-2
Amendment 36
B. Percent of utilization for each operating stable and unstable trench or disposal unit
filled during the previous calendar year.
C. Annual aerial photograph of the leasehold.
D. Summary, by waste class, of activities and quantities of radionuclides disposed.
E. A summary of disposal unit maintenance activities.
F. Any instances in which observed site characteristics were significantly different
from those described in the application for the license.
G. The remaining capacity of the disposal facility and each open disposal unit.
H. A summary of each disposed radionuclide and its activity.
I. An updated source term for the facility that covers all waste disposed during the
previous year.
J. A summary of waste packages that have been placed in secondary containment
K. The volume of diffuse Naturally Occurring and Accelerator produced Radioactive
Material (NARM) disposed.
L An evaluation of waste disposed in secondary containment during the previous
year.
M. Any other information the department may require.
As radioactive material buried may not be transferred by abandonment or otherwise,
unless specifically authorized by the department, the expiration date of this license
applies only to the above-ground activities and to the authority to bury radioactive material
wastes at the location specified in Condition 11. The license continues in effect, and the
responsibility and authority for possession of buried radioactive material wastes continues
until the department finds that the plan established for preparation of the facility for
transfer to another person or custodial agency has been satisfactorily implemented in a
manner to reasonably assure protection of the public health and safety and the
environment, and the department takes action to terminate the licensee's responsibility
and authority under this license. Ail requirements for environmental monitoring, site
inspection, maintenance, and site security continue whether wastes are being buried or
not.
State of Washington
Radioactive Materials License
Page 19 of 24
License Number: WN-IO 19-2
Amendment 36
73. All trenches or disposal units shall be conspicuously marked with permanent, stable
monuments at each end, consistent with the approved site closure plan required by
Condition 74. Permanent monuments shall be designed to stand erect, well above the
grade of the final trench cover, and in a manner which will not allow them to be covered or
obscured by drifting sand during the institutional control period. Inscriptions shall be
made so as to endure and remain legible well beyond the institutional control period. The
permanent monuments shall be inscribed with the following information:
A. Total activity of radioactive material, in curies, excluding source and special
nuclear materials, total amount of source material in kilograms, and total amount of
special nuclear material, in grams, in the trench.
B. Trench number or other means of identifying the disposal unit.
C. Date of opening and closing the disposal unit.
D. Volume of waste in the disposal unit
E. Coordinates of the stable and unstable disposal units, including disposal unit depth
and depth of cover at closure.
This same information shall be reported to the Department of Health and the Department
of Ecology within 30 days of closure of each trench or disposal unit.
74. Upon approval of the Trench Cap Design required by License Condition 68. the licensee
shall review and update the July 1996 Facility Closure and Stabilization Plan within one
year, and shall review and update the plan as necessary every four years thereafter. A
copy of this review shall be submitted to the department upon completion of the review.
The facility closure and stabilization plan shall address how the licensee meets or plans to
meet the following requirements:
A. Bury all waste in accordance with the requirements of the license.
B. Dismantle, decontaminate (as required), and dispose of all structures, equipment,
and materials that are not to be transferred to the site custodian.
C. Document the arrangements and the status of the arrangements for orderly
transfer of site control and for long-term care by the government custodian. Also
document the agreement, if any, of state or federal governments to participate in,
or accomplish, performance objectives. Specific arrangements to assure
availability of funds to complete the site closure and stabilization plan shall be
documented.
State of Washington
Radioactive Materials License
Page 20 of 24
License Number: WN-IO 19-2
Amendment 36
D. Direct gamma radiation levels from buried wastes shall be essentially background at
any accessible above-ground location, as determined by evaluation of
environmental data from the licensee, the U.S. Department of Energy, and its
contractors.
E. Demonstrate by measurement and model during operations and after site closure
that concentrations of radioactive material which may be released to the general
environment in ground water, surface water, air, soil, plants, or animals will not result
in any member of the public receiving an annual dose exceeding an equivalent to 25
millirems (0.25 mSv) to the whole body, 75 millirems (0.75 mSv) to the thyroid, and
25 millirems (0.25 mSv) to any other organ.
F. Render the site suitable for surface activities without resort to custodial care
exceeding vegetation control, minor maintenance, and environmental monitoring.
No active ongoing maintenance shall be necessary. Final conditions at the site must
be acceptable to the government custodian and compatible with its plan for the site.
G. Demonstrate that all trench elevations are above water table levels, taking into
account the complete history of seasonable fluctuations.
H. Eliminate the potential for erosion or loss of site or trench integrity due to factors
such as ground water, surface water, wind, subsidence, and frost action. All slopes
shall be sufficiently gentle to prevent slumping or gullying. The surface shall be
stabilized to minimize erosion, settling, or slumping of caps.
I. Demonstrate that permanent trench markers are in place, stable, and keyed to
benchmarks. Identifying information shall be clearly and permanently marked as
required by Condition 67 of this license.
J. Compile and transfer to the department complete records of site maintenance and
stabilization activities, trench elevation and locations, trench inventories, and
monitoring data for use during custodial care for unexpected corrective measures
and data interpretation.
K. Maintain a buffer zone to provide space to stabilize slopes, incorporate offsite
surface water management features, assure that any future excavation on adjoining
areas shall be evaluated for the potential to compromise trench or site integrity, and
provide working space for unexpected mitigating measures, if needed, in the future.
The buffer zone may be within the subleasehold or on adjacent land, provided
written agreements are secured with persons owning or controlling adjacent lands,
which shall allow the licensee or custodial agency the required access and actions.
State of Washington
Radioactive Materials License
Page 21 of 24
License Number: WN-IO 19-2
Amendment 36
L. Provide a secure passive site security system (e.g., a fence) that requires
minimum maintenance.
M. Stabilize the site in a manner to minimize environmental monitoring requirements
for the long-term custodial phase, and develop a monitoring program based on the
stabilization plan.
N. Investigate the causes of any statistically significant levels of radioactive or
hazardous materials in environmental samples taken during operation and
stabilization. In particular, any evidence of unusual or unexpected rates or levels
of radionuclide migration in or with the ground water shall be analyzed, and
corrective measures implemented.
O. Eliminate the need for active water management measures, such as a sump or
trench pumping and treatment of water to assure that wastes are not leached by
standing water in the trenches.
P. Evaluate present and proposed activities on adjoining areas to determine their
impact on the long-term performances of the site, and take reasonable action to
identify and minimize the effects.
75. Upon completion of Phase II of Trench Cap construction, the licensee shall develop
specific procedures, and implement a program, approved by the department, which is
designed to study (A) erosion of soils onto and off of the facility, (B) methods of
revegetation of closed trenches, and (C) subsidence of trenches, in accordance with
criteria established by the department. Once approved, the licensee shall submit annual
reports to the department by October 31 which discusses the results of the program.
76. Upon closure of each disposal unit, the licensee shall submit to the department a
summary of:
A. All radionuclides and associated activities disposed in that trench.
B. Waste class totals by volume and activities.
C. Disposal locations and volume of chelates disposed.
D. A summary, to the extent practical, of the physical and chemical forms disposed.
State of Washington
Radioactive Materials License
Page 22 of 24
License Number: WN-I019-2
Amendment 36
77. Notwithstanding other requirements of this license or the sublease, one year prior to the
anticipated transfer of the licensee's facility and buried radioactive waste to another
person (including an agency of the state or federal government), the licensee shall submit
a final version of the facility closure plan, including a schedule for implementation of all
remaining plan elements prior to transfer, and a description of the mechanics of orderly
transfer in coordination with the transferee.
78. By June 30 of each year, the licensee shall submit the following financial documentation
to the department:
A. A copy of its financial report or a certified financial statement and Security and
Exchange Commission (SEC) Form 10K.
B. A copy of its financial or surety arrangements for closure and stabilization of the
disposal facility.
C. A copy of personnel and nuclear liability insurance held for the facility.
79. The licensee shall submit to the department a copy of site surveillance fees paid, within
45 days after the end of each calendar quarter.
80. The licensee shall conduct a quality assurance/quality control program in accordance with
US Ecology Quality Assurance Manual, and Quality Assurance Procedures Manual QA-
MA-2. Changes to these documents shall be submitted to the department within 30 days
of the change.
81. The licensee shall comply with the requirements set forth in Order dated
November 29, 2005, signed by Gary Robertson, Director, Office of Radiation
Protection, and made a part hereof by this reference. The licensee shall comply
with any new requirements issued subsequent to date of original Order.
82. Effective 4 April 2008:
The licensee shall comply with the requirements described in the Administrative
Amendment to this license and the document (NRC ORDER EA-07-305, with
attachments, dated 5 December 2007) entitled "Fingerprinting and Criminal
History Records Check Requirements for Unescorted Access to Certain
Radioactive Material". Those requirements listed in the U.S. Nuclear Regulatory
Commission Order (Implemented in accordance with the due dates given in the
"Timeline Attachment" to the 5 March 2008 Administrative Amendment cover
letter), shall be instituted as required as part of the licensee's Trustworthiness
and Reliability component of the Increased Controls requirements.
FINANCIAL ASSURANCES
State of Washington
Radioactive Materials License
Page 23 of 24
License Number: WN-IO 19-2
Amendment 36
By 3 Jury 2008, the licensee shall provide under oath or affirmation, to the state of
Washington Department of Health and to the Nuclear Regulatory Commission, a
certification that the Trustworthiness and Reliability Official is deemed
trustworthy and reliable by the licensee as required in paragraph B.2 of the U.S.
Nuclear Regulatory Commission (NRC) Order EA-07-305, published in the Federal
Register on December 13, 2007 [72 FR 70901].
All fingerprints obtained by the licensee pursuant to this requirement must be
submitted to the NRC for transmission to the U.S. Federal Bureau of Investigation
(FBI). Additionally, the licensee's submission of fingerprints shall also be
accompanied by a certification, under oath and affirmation, of the trustworthiness
and reliability of the licensee's Trustworthiness and Reliability Official as
required by paragraph B.2 of NRC Order EA-07-305.
The licensee shall complete implementation of the fingerprinting requirements by
1 October 2008. The licensee shall notify the state of Washington Department of
Health and the U.S. Nuclear Regulatory Commission when they have achieved full
compliance with the requirements described in the NRC Order. The notification
shall be made within twenty-five (25) days after full compliance has been
The licensee shall notify the state of Washington Department of Health and the
U.S. Nuclear Regulatory Commission within 24 hours if the results from a
criminal history records check indicate that an individual is identified on the FBI's
Terrorist Screening Data Base.
83. Except as specifically provided by this license, the licensee shall possess and use
radioactive material described in Conditions 6, 7, and 8 of this license in accordance with
statements, representations, and procedures contained in the documents listed below.
The department's "Rules and Regulations for Radiation Protection," Title 246 WAC, shall
govern the licensee's statements in applications or letters, unless statements are more
restrictive than the regulations. Any change to the documents listed below shall require
departmental approval in the form of an amendment to this license.
A. Application and cover letter dated January 7,1997.
B. Facility Standards Manual, dated February 2003; Superseded by License
achieved.
Condition 83.D.
C. Administrative amendment incorporating increased controls, dated November 30.
2005.
State of Washington
Radioactive Materials License
Page 24 of 24
License Number: WN-IO 19-2
Amendment 36
D. US Ecology Washington, Inc. Facility Standards Manual dated September 2006;
Superseded by License Condition 83.F.
E. Letter and attachments dated March 29, 2007 RE: request to revise disposal
limits for SNM and addition of requirement to dispose of Radium 226 sources in
F. Letter and attachments dated December 20, 2007 RE: request to: eliminate
experimental monitoring of vadose tritium and radon , solar still tritium, and radon
in air, suspend vadose vapor sampling and groundwater sampling of hazardous
constituent until after completion of the MTCA investigation; change gamma
composite of air filters from monthly to quarterly; change tritium in air sampling
from continuous to continuous for 30 days each quarter, change soil sampling
from quarterly to once every 3 quarters; change vegetation sampling from
quarterly to annually; change groundwater sampling from quarterly to once every
3 quarters; change all environmental TLDs to quarterly; change personal
dosimetry exchange form quarterly to semi-annually; reduce vendor audits from
every three years to every five years.
G. US Ecology Washington, Inc. Facility Standards Manual dated December 2007.
H. Administrative amendment; RE: adding new IC requirements for
fingerprinting and criminal history checks.
ECBs.
FOR THE STATE OF WASHINGTON DEPARTMENT OF HEALTH
Date: March 5. 2008
Mike! J. Elsen, Supervisor
Waste Management Section
APPENDIX A
WASTE CLASSIFICATION TABLE
Paga 1 of 4
STA7$
18B9
License Number: WN-I019-2
Amendment 36
RADIONUCLIDES CONCENTRATION LIMITS IN CURIES/CUBIC METER*
Table 1 (long-lived)
C-14
C-14 in activated metal
NI-59 in activated metal
Nb-94 in activated metal
Tc-99
1-129
Class A
£0.8
£8
£22
£0.02
£0.3
£0.008
Class C
£8
£80
£220
£0.2
£3
£0.08
Alpha emitting Transuranic
radionuclides with half-lives
greater than five years
Radium 226
Curium 242
CONCENTRATION LIMITS IN NANOCURIES/GRAM
£10
£10
£2,000
£100 with specific
departmental approval
£100 with specific
departmental approval
£20,000 with specific
departmental approval
Plutonium 241 £350 £3,500
APPENDIX A
WASTE CLASSIFICATION TABLE
Page 2 of 4
STAff
s
License Number: WN-I019-2
Amendment 36
RADIONUCLIDES
Table 2 (short-lived)
Total of all with half-life
less than 5 years
H-3
Co-60
Ni-63
Ni-63 in activated metal
Sr-90
Cs-137
CONCENTRATION LIMITS IN CURIES/CUBIC METER**
Class A Class B Class C
£700
£40
£700
£3.5
£35
£0.04
£1
• with specific departmental
approval
•
£70
£700
£150
£44
£700
£7000
£7000
£4600
Curies/cubic meter is equivalent to microcuries/cubic centimeter
• There are no limits established for these radionuclides in Class B or C wastes. Practical
considerations such as the effects of external radiation and internal heat generation on
transportation, handling, and disposal will limit the concentrations for these wastes. These
wastes shall be Class B unless the concentrations of other nuclides in Table 2 determine the
Waste to be Class C independent of these nuclides.
WASTE CLASSIFICATION TABLE
APPENDIX A
Page 3 of 4
License Number: WN-IO 19-2
Amendment 36
Notel.
Note 2.
Note 3.
Note 4.
Unless specifically restricted elsewhere in the license, the concentration of a
radionuclide or radionuclide mixture may be averaged over the volume (or mass)
of the waste and, if used, the solidification agent or matrix. The concentration of
radionuclides in filters encapsulated with a solidification agent or matrix shall be
averaged over the volume of the filter, not the solidification agent. The volume
(mass) of packaging containers, liners or overpacks shall not be included in this
calculation, nor shall the volume (mass) of the waste mixture be artificially
increased by the addition of heavy, nondispersible solids or objects even if
considered as waste. Further guidance is provided in "Low-Level Waste Licensing
Branch Technical Position on Radioactive Waste Classification," May 1983, or
successor documents issued by the U.S. Nuclear Regulatory Commission.
The waste is Class A if none of the listed radionuclides is present. Waste
packaged in accordance with Condition 39 of this license shall be Class A unstable
and the words "Condition 39" shall be noted on the manifest or other
documentation accompanying the waste package.
There are no Class B values for Table 1 radionuclides; their presence classifies
the waste as either Class A or Class C according to their concentrations.
The waste class for mixtures of the listed radionuclides is determined by deriving
for each radionuclide the ratio between its concentration in the mixture and its
concentration limit in the table of this license and adding the resulting ratio values
for each radionuclide group. All limits used in the calculations must be for the
same waste class. The sum of the ratios for each radionuclide group must be
equal to or less than 1.0, or the waste is the next higher classification than that
used for the calculation.
If Class C limits are used in the calculation and the sum of ratios for either group
exceeds 1.0, the waste is not acceptable for near-surface disposal without prior
written approval from the department.
APPENDIX A
WASTE CLASSIFICATION TABLE
Page 4 of 4
License Number: WN-I019-2
Amendment 36
Note 5. If radioactive waste contains a mixture of radionuclides, some of which are listed
on Table 1, and some of which are listed on Table 2, classification shall be
determined as follows:
A. If the concentration of a nuclide listed in Table 1 does not exceed the Class
A limit, the class shall be that determined by the concentration of nuclides
listed in Table 2.
B. If the concentration of a nuclide listed in Table 1 exceeds the Class A limit,
but does not exceed the Class C limit, the waste shall be Class C, provided
the concentration of nuclides listed in Table 2 does not exceed the Class C
value.
Note 6. If concentrations for any single radionuclide exceed the Class C values in the
table, the waste is not acceptable for near-surface disposal under this license.
3TAT>
1889
APPENDIX B
APPROVED SOLIDIFICATION MEDIA
Page 1 of 1
8TA7$ 35
J88»
License Number: WN-IO 19-2
Amendment 36
Only approved solidification media can be used. Approved solidification media are:
1. Atcor Cement
2. Aquaset I and II
3. Aztech (General Electric)
4. Bitumen* (Waste Chem and ATI)
5. Chem-Nuclear Cement
6. Concrete (Structural)
7. Delaware Custom Media
8. Dow Media
9. Envirostone
10. LN Technologies Portland
Cement Formula for Oils
11. Pacific Nuclear Portland Cement
12. Petroset I and II
13. Safe T Set
14. SEG (Westinghouse - Hittman)
Cement
15. Petroset -H
16. Aquaset -H
17. EMC Cement
18. Other solidification media and
processes which have been
approved by U.S. NRC and/or the
department.
*Note: For waste types that require solidification, both oxidized bitumen and straight
distilled are acceptable.
"Solidification" means a resultant waste form which is a free-standing solid and primarily
relies upon a chemical reaction or encapsulation to contain the liquid. Approved
stabilization media may also be used as solidification agents without conducting tests
necessary to verify stability, provided the resulting waste form is a free-standing solid.
It is the responsibility of the person processing the waste into a solid form to adhere to a
quality control program to verify the waste form is appropriate. If a material can also be
used as a sorbent, the restrictions noted for its use in Appendix F shall apply to its use as
a solidification agent.
APPROVED STABILIZATION MEDIA
APPENDIX C
Page 1 of 1
License Number: WN-I019-2
Amendment 36
Only approved stabilization media may be used. Approved stabilization media are:
1. Aztech (General Electric)
2. Bitumen* (Waste Chem)
3. Concrete**
4. Dow Media (Vinyl Ester Styrene)
5. Veri Solidification Process
6. Other stabilization media and processes which have been reviewed and approved by
U.S. NRC and the department as meeting waste form stability criteria.
'Note: Oxidized Bitumen only.
"Concrete, when used as an encapsulation medium around a small volume of radioactive
material; e.g., a sealed source centered in a 55-gallon drum containing concrete, shall have a
formulated compressive strength greater than or equal to 2500 psi.
APPENDIX D
CERTIFICATES OF COMPLIANCE FOR
HIGH INTEGRITY CONTAINERS
8
1889
Page 1 of 2
License Number: WN-IO 19-2
Amendment 36
Only those High Integrity Containers which have been approved by the department and used in
accordance with the Certificate of Compliance (C of C) may be used. Approved High Integrity
Containers are:
C of C Number
WN-HIC-01
WN-HIC-02
WN-HIC-03
WN-HIC-04
WN-HIC-05
WN-HIC-06
WN-HIC-07
WN-HIC-08
WN-HIC-09
WN-HIC-10
WN-HIC-11
WN-HIC-12
WN-HIC-13
Manufacturer
Pacific Nuclear
Nuclear Packaging
Chichibu Cement
Chichibu Cement
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Nuclear Packaging
Package
Identification
Number
DSHS-HIC-TMI-01
DSHS-HIC-EA-50
DSHS-HIC-SFPIC 200L
DSHS-HIC-SFPIC 400L
DSHS-HIC-EA 142-A
DSHS-HIC-EA 50-A
DSHS-HIC-EA 140-A
DSHS-HIC-EA 190-A
DSHS-HIC-EA 210-A
DSHS-HIC-EA 50-C
DSHS-HIC-EA 140-C
DSHS-HIC-EA 142-C
DSS-HIC-EA 190-C
APPENDIX D
CERTIFICATES OF COMPLIANCE FOR
HIGH INTEGRITY CONTAINERS
58
Page 2 of 2
License Number: WN-IO 19-2
Amendment 36
C of C Number
WN-HIC-14
WN-HIC-15
WN-HIC-16
WN-HIC-17
WN-HIC-18
Manufacturer
Nuclear Packaging
(SEG) LN Technologies
(SEG) LN Technologies
(SEG) LN Technologies
(SEG) LN Technologies
Package
Identification
Number
DSHS-HIC-EA 210-C
DSHS-HIC-LN 179-H
DSHS-HIC-LN 131-H
DSHS-HIC-LN 118-H
DSHS-HIC-LN 96-H
Other High-Integrity Containers which have been specifically approved by the department.
APPENDIX E
CERTIFICATES OF COMPLIANCE FOR
ENGINEERED BARRIERS
Page 1 of 1
License Number: WN-IO 19-2
Amendment 36
Only those Engineered Barriers approved by the department and/or NRC and used in
accordance with the Certificate of Compliance (C of C) may be used. Approved Engineered
Barriers are:
C of C Number Issued To
WN-EB-01 US Ecology Washington, Inc.
WN-EB-02 US Ecology Washington, Inc.
STA7*
1889
Other Engineered Barriers which have been specifically approved by the department.
APPENDIX F
APPROVED SORBENTS
Page 1 of 1
License Number: WN-I019-2
Amendment 36
Only those absorbents listed below have been approved by the state of Washington,
Department of Health, Division of Radiation Protection, (department) for use in packaging and/or
processing of incidental or unintentional radioactive liquids in accordance with License Condition
33.
Absorbency efficiencies and quantity of absorbent required vary. In all cases, it ie the
responsibility of the waste generator and/or packager to determine the efficiency and proper
proportions of absorbent for incidental or unintentional liquids being absorbed. Note: Enough
absorbent materials must be provided to absorb at least twice the volume of radioactive liquid
contents.
B.
Media
Clay Materials
1.
2.
3.
4.
5.
6.
7.
8.
Speedi Dri
Hi Dri
Florco
FlorcoX
Instant Dri
Safe T Sorb
Opalex
Moltan Plus
Diatomaceous Earths
1. Superfine
2. Floor Dry
3. Celetom
4. Safe N Dri
5. Solid-A-Sorb
6. Xtrasorb- 248
Perlite
1.
2.
3.
4.
5.
Chemsii 30
Chemsil 50
Chemsii 3030
Dicaperl HP200
Dicaperi HP500
Others
1. Dicalite Dicasorb
2. Petroset
3. Petroset II
4. Aquaset
5. Aquaset II
6. Safe T Set
7. SP-100
8. SP-400
9. Large Grain Superabsorbent crystals
* Note: Perlite products shall not be used for packaging animal carcasses.
Attachment 1
US Ecology Richland Materials
1.5 US Ecology Waste Acceptance Criteria
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
US Ecology Richland, Washington Facility
Waste Acceptance Criteria
The Richland facility disposes of Class A, B and C Low Level Radioactive Waste (LLRW) from
Northwest and Rocky Mountain Compact states. Naturally Occurring and Accelerator
Produced (NARM) and exempt radioactive material from any geographic location can also be
accepted.
This summary is intended for initial waste
acceptability screening only. It is the
generator's responsibility to comply with
U.S.DOT (49 CFR) requirements and other
applicable regulations prior to waste shipment.
Accepted Wastes:
• LLRW generated in the Northwest
Compact region (Oregon, Washington,
Idaho, Montana, Wyoming, Utah, Alaska,
Hawaii) & Rocky Mountain Compact region
(Nevada, Colorado, New Mexico)
• NARM or Exempt Waste
Basic Requirements for Disposal:
• All waste must be properly packaged in
closed containers.
• All waste must be classified in accordance
with 10 CFR 61, Washington Administrative
Code (WAC) 246-249 and the current NRC
"Low-Level Waste Licensing Branch
Technical Position on Radioactive Waste
Classification"
• Class B and C waste must meet 10
CFR 61 & WAC 246-249 stability
requirements
• All generators disposing of waste at the
facility must first obtain:
S A generator number
S A site use permit (issued by Washington
Department of Ecology)
•/ An export permit (for Rocky Mountain
Compact waste only)
Prohibited Wastes:
• Mixed waste
• Waste that contains or is capable of
generating toxic gases, vapors or fumes
• Wastes containing pyrophoric, hazardous,
dangerous or chemically explosive
materials or materials which could react
violently with water or moisture or when
subjected to agitation
• Wastes containing unprocessed liquids
• Wastes containing special nuclear material
(SNM) > 350 grams of U-235 or 200 grams
of Pu or U-233 (total amount of SNM
limited to unity)
• Wastes containing oil> 10% by weight
Please call or e-mail our professional customer service team if you have any questions:
[phone] Mike Ault: LLRW Disposal [e-mail]
[phone] Chuck White: NARM Disposal [e-mail]
Attachment 1
US Ecology Richland Materials
1.6 WDOH concurrence regarding WTP residuals status as source material, 12/20/10 e-mail
from Mike Elsen and 12/31/08 letter from WDOH
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1,2013
Lifitj/um Cimail - Midnite Mine Material Rad proti...
Subject: FW: Midnite Mine Material Rad profile and LLRW Generator Registration
Chad,
Here is the WDOH concurrence. Provided the material does not qualify as mixed waste it is
acceptable at USEW.
If you have any questions do not hesitate to call.
Mike
From: Elsen, Mike (DOH) fmailto:Mike.Elsen@.DOH.WA.GOV1
Sent: Mon 20-Dec-10 2:24 PM
To: Mike Ault
Cc: Stoffel, Dorothy (DOH); [e-mail]; Murphy, Sean J (DOH)
Subject: FW: Midnite Mine Material Rad profile and LLRW Generator Registration
Mike-
This is in response to our conversation today regarding the acceptability of the
sludge from the Dawn Mining Company- Midnite Mine at your facility. The
material from the Midnite Mine was considered Source Material when DOH
regulated the facility. Attached is our letter to the USEPA when we terminated the
license for the Midnite Mine. The letter states that the license was issued for the
production of source material incidental to the treatment of contaminated water at
the Midnite Mine.
Provided that the material meets all requirements of your radioactive materials
license WN-1019-2 the material is acceptable for disposal at your facility as
source material and not 11(e)(2) material. Please let me know if you have any
questions.
httpsV/mail.google.com/mail/?ui=2&ik...
Oman - Midnite Mine Material Rad proti..
Mike
From: Mike Ault rmailto:MAULT©.usecology.com1
Sent: Monday, December 20, 2010 12:21 PM
To: Elsen, Mike (DOH)
Subject: FW: Midnite Mine Material Rad profile and LLRW Generator Registration
From: Chad Hyslop
Sent: Fri 17-Dec-10 2:07 PM
To: Mike Ault
Cc: Laura Lee Barry
Subject FW: Midnite Mine Material Rad profile and LLRW Generator Registration
Can you please review? Also please note (below) that Toby requests a
concurrence indicating we believe we can accept this material.
Thx,
Chad
From: Toby Wright rmailto:[e-mail]
Sent: Friday, December 17, 2010 9:14 AM
To: Chad Hyslop
Subject Midnite Mine Material Rad profile and LLRW Generator Registration
Chad;
httpK//mail.google.com/mail/?ui=2&ilc.. 4/5
STATE OF WASHINGTON
DEPARTMENT OF HEALTH
OFFICE OF RADIATION PROTECTION
111 Israel RoadSE * PO Box 47827 • Olympia, Washington 98504-7827
TDD Relary Services: 1-800-833-6388
December 31,2008
Ms. Elly Hale, Project Manager
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 900
Seattle, Washington 98101-3140
Dear Ms. Hale:
This is to follow up on our letter to you dated October 15, 2008. In that letter, we stated:
The NRC, from which DOH has delegated regulatory authority for radioactive material, stated its
position clearly about radioactive materials licensing at CERCLA sites in a 1999 Directors
Decision, DD-99-07. In this decision, NRC cites the permit exemption section of CERCLA, 42
U.S.C.A. 9621(e)(1), which provides: "(n)o Federal, State, or local permit shall be required for
the portion of any removal or remedial action conducted entirely onsite, where such remedial
action is selected and carried out in compliance with this section." As an Agreement State, it is
our obligation to regulate radioactive material consistent with the practices of NRC. In light of
the above, DOH intends to terminate the state of Washington radioactive materials license (WN-
10390-1) for the water treatment plant license on December 31,2008."
The purpose of this letter is to notify you that effective January 1, 2009, the state of Washington
radioactive materials license WN-I0390-1, which is issued to Dawn Mining Company for the
production of source material incidental to the treatment of contaminated water at the Midnite
Mine, is terminated. From discussions with you, it is our understanding that the U.S. EPA is
ready to take over the regulation of radioactive material at the Midnite Mine as of January 1,
2009.
Ms. Elly Hale, Project Manager
Page Two
Attached is a copy of the license amendment which terminates the state of Washington
radioactive materials license as well as our letter to John Mudge, President of Dawn Mining
Company, notifying him of the terminated license. If you should have any questions, do not
hesitate to contact me.
Mikel J. Elsen, Supervisor
Waste Management Section
Enclosures
cc: Alice Blado, AAG
Dorothy Stoffel, DOH
Bob Nelson, DMC
John Mudge, DMC
Rudy Peone, Spokane Tribe of Indians
Sincerely,
State of Washington
Radioactive Materials License
Page 1 of 1 Page
License Number WN-I0390-1
Amendment No. 3
Dawn Mining Company
5326 Uranium City Road
Ford, Washington 99013
Attention: Robert Nelson, General Manager
In accordance with the Department of Health letter dated December 31, 2008, your state of Washington
Radioactive Materials License Number WN-I0390-1 is hereby TERMINATED.
FOR THE STATE OF WASHINGTON DEPARTMENT OF HEALTH
Date December 31. 2008
Mikel J. Elsen; Supervisor
Waste Management Section
Attachment 1
US Ecology Richland Materials
1.7 NRC Director's Decision, dated March 26,1999
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
DD-99-07
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
Carl J. Paperiello, Director
In the Matter of
The United States Army Corps of Engineers
Docket No. N/A
(10C.FR. 2.206)
DIRECTOR'S DECISION UNDER 10 CFR § 2.206
I INTRODUCTION
On October 15, 1998, Thomas B. Cochran, Ph.D., Director, Nuclear Program, Natural
Resources Defense Council (NRDC) and James Sottile, IV, Caplin & Drysdale, Chartered, filed
a petition on behalf of NRDC (the "petitioner") addressed to L. Joseph Callan, Executive
Director for Operations, U.S Nuclear Regulatory Commission (NRC) The petition requests
that NRC exert authority to ensure that the Corps of Engineers' handling of radioactive
materials in connection with the Formerly Utilized Sites Remedial Action Program (FUSRAP) is
effected in accord with a properly issued license and all other applicable requirements.
II. BACKGROUND
During the 1940s, 1950s, and 1960s, the Manhattan Engineer District and the Atomic
Energy Commission performed work at a number of sites throughout the United States as part
of the nation's early atomic energy program. Although many of the sites were cleaned up under
guidelines in effect at the time, residual contamination remains at many of the sites today. The
contaminants at these sites involved primarily low levels of uranium, thorium, and radium, with
their associated decay products. The U S Department of Energy (DOE) began FUSRAP in
-2-
1974 to study these sites and take appropriate cleanup action. By 1997, DOE had identified 46
sites in the program and had completed remediation at 25 sites with some ongoing operation,
maintenance, and monitoring being undertaken by DOE. Remedial action was planned,
underway, or pending final closeout at the remaining 21 sites.
On October 13, 1997, Congress passed the 1998 Energy and Water Development
Appropriations Act,1 which transferred administration of FUSRAP to the U S Army Corps of
Engineers (the Corps or USACE) and appropriated $140,000,000 to the Corps for the
completion of FUSRAP activities. The language in the law reads as follows:
For the expenses necessary to administer and execute the Formerly Utilized
Sites Remedial Action Program to clean up contaminated sites throughout the
United States where work was performed as part of the nation's early atomic
energy program, $140,000,000, to remain available until expended: Provided,
that the unexpended balances of prior appropriations provided for these activities
in this Act or any previous Energy and Water Development Appropriations Act
may be transferred to and merged with this appropriation account, and
thereafter, may be accounted for as one fund for the same time period as
originally enacted.2
The legislative history behind this provision offers little guidance regarding the details of
the Corps' new involvement. The Conference Committee report states that "(t)he conferees
have agreed to transfer the Formerly Utilized Sites Remedial Action Program (FUSRAP) to the
Corps of Engineers, and funding for this program is contained in Title I of the bill."3 The House
Appropriations Committee report indicates that this change stems from concerns over the cost
1Energy and Water Development Appropriations Act, 1998, Pub. L. No. 105-62, 111
Stat. 1326(1997)
2 Id,
3 H.R. Conf. Rep. No. 271, 105th Cong., 1st Sess., 85 (1997).
-3-
of the FUSRAP program under DOE. The Committee report concludes that "(c)learly, the
problem must be in the contract management and contract administration function performed
by the Department of Energy and the management and operating contractors who actually
subcontract for most of the cleanup work."4 Finally, citing the Corps' efforts under the Formerly
Used Defense Sites (FUDS) program, the report indicates that there are significant cost and
schedule efficiencies to be gained by".. having the Corps of Engineers manage the
Department of Energy's FUSRAP program as well."5
Given the lack of guidance in the legislative history, two members of Congress sought to
clarify the law's intent through subsequent correspondence. In a November 6, 1997, letter to
Energy Secretary Federico Pena and Defense Secretary William Cohen, Senator Pete
Domenici and Representative Joseph McDade indicated, among other things, that:
Transfer of the FUSRAP program to the U.S. Army Corps of Engineers makes
management, oversight, programming and budgeting, technical investigations, designs,
administration, and other such activities directly associated with the execution of
remediation work at the currently eligible sites a responsibility of the Corps of Engineers.
It should be emphasized that basic underlying authorities for the program remain
unaltered and the responsibility of DOE [emphasis added].
The Energy and Water Development Appropriations Act for fiscal year 1999 (FY99), P.L.
105-245, continued the Corps' involvement as the implementing agency for the FUSRAP In
particular, the 1999 Act provided that response actions by the United States Army Corps of
Engineers under FUSRAP shall be subject to the administrative, procedural, and regulatory
provisions of the Comprehensive Environmental Response, Compensation and Liability Act
H R Rep. No. 190, 105th Sess., 99 (1997).
Id.
-4-
(CERCLA) (42 U.S.C. 9601 et seq.), and the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 CFR, Chapter 1, Part 300. In addition, the 1999 Act provided that,
" .except as stated herein, these provisions do not alter, curtail or limit the authorities, functions
or responsibilities of other agencies under the Atomic Energy Act (42 U.S.C 2011 et seq.) .."6
To date, NRC has not regulated activities conducted under FUSRAP, including those
activities conducted by the Corps since the transfer of the program. The petitioner, however,
believes that NRC should regulate the Corps' FUSRAP activities, arguing that the
Appropriations Act did not purport to transfer authority over FUSRAP to the Corps. As such,
according to the petitioner, the Corps may not legally administer the program absent proper
oversight because, unlike DOE and (in most cases) DOE contractors, the Corps is not exempt
from the licensing requirements of the Atomic Energy Act (see 42 U.S.C. § 2014(s)) The
petitioner further indicates that DOE has publicly stated that it cannot extend its licensing
exemption for private contractors to the Corps and that DOE has no regulatory authority over
the Corps for the tatter's FUSRAP activities. The petitioner concludes that"... the Corps does
not have the legal authority to run FUSRAP without first obtaining a license from the NRC."
In support of its position, the petitioner notes that the institutional mission of the Corps is
not focused on the safety and security of the nation's nuclear activities. In addition, NRC's
failure to regulate the Corps' FUSRAP activities is claimed to be inconsistent with the intent of
the laws governing the utilization and cleanup of nuclear materials. Finally, the petitioner adds
that, with very few exceptions, Congress intended that no person should be permitted to handle
nuclear materials except in accordance with a license issued by NRC.
6Pub L. No. 105-245, Title I.
-5-
In a November 30, 1998, letter NRC informed the petitioner that the petition had been
received and was currently under review. On the same date, NRC forwarded the petition to the
DOE and the Corps for their comment. In a January 12, 1999, letter, the Chief Counsel for the
Corps, Robert M. Andersen, responded to NRC's request. DOE responded to NRC's request in
a January 14, 1999, letter from William J. Dennison, Assistant General Counsel for
Environment.
The Corps' Response
In its response, the Corps states that it is not required to obtain a license from NRC for
its FUSRAP activities. The Corps' response emphasizes that Congress directed the Corps to
conduct its FUSRAP activities pursuant to the CERCLA.7 The Corps' principal argument is that
no NRC license is required because of the federal permit waiver for on-site removal or remedial
actions in § 121(e)(1) of CERCLA. The Corps also believes that the AEA exempts FUSRAP
activity from NRC licensing. In its opinion, "Congress intended for USACE to fill the shoes of
the AEC successor agency responsible for FUSRAP cleanup, that is DOE, an agency not
considered a 'person' subject to licensing under the AEA." The Corps further posits that, in
transferring the FUSRAP program, Congress expressed no intent that the agency obtain an
NRC license for that activity and, instead, sought a seamless transition "unimpeded by
procedural requirements outside of CERCLA."
Nevertheless, the Corps commits to meeting the substantive requirements of both the
Atomic Energy Act (AEA) and CERCLA. It acknowledges that NRC license requirements may
742 USC §9601 et seq
-6-
apply to portions of FUSRAP response actions conducted off-site, beyond the scope of the
permit waiver. The letter concludes by acknowledging that the substantive provisions of NRC
regulations are applicable or relevant and appropriate requirements (ARARs) for many
FUSRAP response actions under CERCLA and, as such, the Corps will look"... to NRC for
guidance in interpreting and implementing these requirements on the sites."
DOE's Response
DOE's response differs in several respects from that of the Corps. On the matter of
DOE's continued involvement with FUSRAP and oversight of the Corps, the Department
"respectfully disagrees" with the Corps. According to its submittal, DOE is not authorized to
regulate the Corps' FUSRAP activities and cannot transfer its AEA authorities to the Corps. In
the Department's view, "(t)he transfer legislation did not make the Corps a DOE contractor, or
otherwise subject the Corps' activities to the control or direction of DOE." The letter also
indicates that DOE and the Corps are currently developing a memorandum of understanding
(MOU) to clarify their respective roles and responsibilities as a result of the legislative transfer.
Nevertheless, DOE believes that, with the exception of a few "administrative issues," there are
no remaining issues between the two agencies that should affect NRC's disposition of the
NRDC petition. The letter concludes that NRC should "evaluate the licensability of the Corps'
activities in the same manner as it would evaluate the activities of any other 'person' within the
meaning of the Atomic Energy Act." DOE defers to NRC on this question. The letter does not
contain a DOE position concerning the viability of the Corps' CERCLA argument.
III. DISCUSSION
-7-
The NRC staff has completed its evaluation of the petitioner's requests and the
responses from the Corps of Engineers and the Department of Energy. For the reasons
discussed below, the NRC denies the petitioners request insofar as it calls on NRC to require
the Corps to obtain a license for activities conducted at FUSRAP sites
CERCLA Permit Waiver
Pursuant to § 121(e)(1) of CERCLA "(n)o Federal, State, or local permit shall be
required for the portion of any removal or remedial action conducted entirely onsite, where such
remedial action is selected and carried out in compliance with this section."8 This provision
waives any NRC license requirements that would apply to the Corps' activities at FUSRAP sites
conducted pursuant to CERCLA.
The Corps argues that, because Congress specifically subjected FUSRAP sites to the
provisions of CERCLA in the 1999 Act, section 121(e)(1) applies to Corps' response actions at
FUSRAP sites. In developing regulations for the implementation of CERCLA, the
Environmental Protection Agency (EPA) addressed the § 121(e)(1) waiver provision for federal
agency CERCLA response actions in § 300.400(e) of the National Contingency Plan (NCP)
That provision states, in pertinent part:
''Permit requirements. (1) No federal, state, or local permits are required for on-site
response actions conducted pursuant to CERCLA sections 104, 106, 120, 121, or
122. The term on-site means the areal extent of contamination and all suitable
'See also. 10 CFR § 300.400(e).
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areas in very close proximity to the contamination necessary for implementation of
response actions "9
In the preamble of the final rule which proposed this section, EPA provided:
Proposed § 300.400(e)(1) states that the permit waiver applies to all on-site actions
conducted pursuant to CERCLA sections 104,106, or 122; in effect, this covers all
CERCLA removal and remedial actions (all "response" actions). However, a
number of other federal agencies have inquired as to whether this language would
reach response actions conducted pursuant to CERCLA sections 121 and 120. In
response, EPA has made a non substantive clarification of the applicability of the
permit waiver in CERCLA section 121(e)(1) to include on-site response actions
conducted pursuant to CERCLA sections 120 and 121 ... The addition of
CERCLA section 120 simply recognizes that the permit waiver applies to federal
facility cleanups conducted pursuant to CERCLA section 120(e), which are also
selected and carried out in compliance with CERCLA section 121.10
Section 121(e)(1) applies to federal agencies such as the Corps in this case The Corps may
take the role of "lead agency" in a CERCLA cleanup action. The NCP defines "lead agency" as
"the agency that provides the OSC/RPM to plan and implement response actions under the
NCP. EPA, the USCG, another federal agency, or a state .. . may be the lead agency for a
response action."11 The NCP also states that "Federal agencies listed in § 300.175 have duties
established by statute, executive order, or Presidential directive which may apply to federal
response actions following, or in prevention of, the discharge of oil or release of a hazardous
940 CFR 300.400(e)(1).
1055 Fed. Reg. 8666, 8689 (1990) ("National Oil and Hazardous Substances Pollution
Contingency Plan; Final Rule) (emphasis added). This change echoed EPA's intentions stated
in the proposed rule' "EPA proposes to state that on-site permits are not required for response
actions taken by EPA, other federal agencies. States, or private parties pursuant to CERCLA
sections 104, 106, or 122." 53 Fed. Reg. 51394, 51406 (1988) ("National Oil and Hazardous
Substances Pollution Contingency Plan; Proposed Rule) (emphasis added)
1140 CFR 300.5 (emphasis added). The definition goes on to state, "The federal agency
maintains its lead agency responsibilities whether the remedy is selected by the federal agency
for non-NPL sites or by EPA and the federal agency or by EPA alone under CERCLA section
120."
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substance, pollutant, or contaminant "12 The Corps, a branch of the U.S. Department of
Defense, is among the agencies listed 13 In the case of the FUSRAP program, Congress
specifically designated the Corps as the "lead agency" in passing the 1999 Appropriations Act.14
As the Corps acknowledges in its letter, the permit waiver in § 121(e)(1) has been rarely
addressed in the courts. In support of its position, the Corps does cite McClellan Ecological
Seepage Situation (MESS) v. Cheney, a case which held that a Resource Conservation and
Recovery Act (RCRA) permit was not required when activities which might otherwise require a
RCRA permit took place at a site only as part of a CERCLA removal or remedial action.15 In
McClellan, MESS, a citizens' group, filed suit against the Secretary of Defense, with regard to
cleanup actions being taken at McClellan Air Force Base, under RCRA and certain state laws.
MESS claimed, inter alia, that McClellan was required to obtain a RCRA permit for the
management of certain hazardous wastes on the base. The court held that an RCRA permit
was not required, because the remedial activities were taken pursuant to CERCLA. The court
relied on § 121(e)(1), stating, "Section 121(e) expressly provides that the activity does not have
to be separately permitted."16
1240 CFR 300.170.
13See 40 CFR 300.175(b)(4)(i).
14Pub. L. No. 105-245, Title I.
15763 F. Supp. 431 (E.D. Cal. 1989). This holding was later vacated on the basis of
subject matter jurisdiction. See McClellan Ecological Seepage Situation (MESS) v. Perry. 47
F.3d 325 (9th Cir. 1995).
16763 F. Supp. 431, at 435. The court went on to note in dicta that where there has
been treatment that requires a RCRA permit which is not associated with a remedial or removal
action under CERCLA, such a permit would be required. JcL
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The Corps also cites United States v. City of Denver to uphold this interpretation of
§121 (e)(1).17 In that case, the court held that CERCLA preempted a zoning ordinance which
was in actual conflict with EPA's remedial order The court stated, "[T]o hold that Congress
intended that non-uniform and potentially conflicting zoning laws could override CERCLA
remedies would fly in the face of Congress's [sic] goal of effecting prompt cleanups of the
literally thousands of hazardous waste sites across the country."18
In passing the 1998 and 1999 Appropriations Acts, Congress gave no indication that it
intended to suspend the waiver provision in §121 (e)(1) of CERCLA in the context of the Corps'
FUSRAP activities The 1999 Act does say: "Provided further, That, except as stated herein,
these provisions do not alter, curtail or limit the authorities, functions or responsibilities of other
agencies under the Atomic Energy Act (42 U.S.C. 2011 et seq.)..." In its letter, DOE points to
this language to support its argument that the Appropriations Act does not create any authority
for it to regulate the Corps. In doing so, DOE interprets the term "provisions" as referring to the
provisions of the Appropriations Act and not the provisions of CERCLA. The NRC staff agrees
with DOE on this point. While the language appears to indicate that the transfer of the program
to the Corps does not alter the extent of DOE and perhaps NRC authority under the AEA, there
is no specific indication that the language is intended to direct NRC to regulate the Corps'
administration of the FUSRAP program In particular, there is no evidence that in including this
phrase, Congress intended to limit the application of the §121 (e)(1) permit waiver to the Corps'
17100F.3d 1509 (10th Cir 1996)
18kl at 1513. The Corps cited Ohio v. USEPA. 997 F.2d 1520 (D.C Cir. 1993) in support
of its § 121(e)(1) position NRC would note that the case upholds a number of provisions in
EPA's 1990 revision of the NCP, including § 121(e)(1). However, the court's discussion centers
on EPA's definition of the term "onsite," and does not discuss the exemption provision, as a
whole, in detail.
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FUSRAP activities In fact, nowhere in the reports for either the 1998 or 1999 Acts or in the text
of the laws themselves did Congress give any hint that it intended NRC to regulate the Corps in
its administration of the FUSRAP program. Instead, the inclusion of the specific reference to
CERCLA suggests that Congress intended NRC to continue to refrain from regulating activities
under the FUSRAP program even after DOE's role was reduced or discontinued.
As DOE states in its letter, the Corps has "consistently expressed the view that its
authorities under the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA)..." are sufficient for the Corps' administration of the FUSRAP program. By the time
the 1999 Appropriations Act was passed, the Corps' administration of the FUSRAP program
under CERCLA was a matter of public record19 and NRC had not taken any steps to require the
Corps to obtain a license from NRC. If Congress had intended NRC to regulate the Corps'
activities at FUSRAP sites, it is likely that it would have specifically directed NRC to do so in
passing the 1999 Appropriations Act.
We note, however, that the waiver in §121 (e)(1) does not apply to off-site activities. To
the extent that NRC and U.S Department of Transportation (DOT) requirements apply to the
transportation, transfer and disposal of Atomic Energy Act material taken off of FUSRAP sites,
the Corps has committed to following applicable requirements, including those for transfer
under the AEA, shipment under the Hazardous Materials Transportation Act, 49 U.S.C. § 5101,
and NRC manifest requirements (e.g., 10 CFR §20 2006).20
19 See, e.g., Letter from Albert J. Genetti, Jr., U.S. Army Deputy Commander, U.S.
Army Corps of Engineers, to Mr Thomas B. Cochran and Ms. Barbara A Finamore, Natural
Resources Defense Council, May 20, 1998.
20While the Corps will be following NRC's requirements in this area, it is unlikely that any
specific NRC license requirements would apply to shipments from FUSRAP sites However,
-12-
NRC Authority Under UMTRCA
Many FUSRAP sites contain material over which NRC would have no regulatory
jurisdiction regardless of whether the Corps is the lead agency in implementing the program
and regardless of whether response actions by the Corps under the program are subject to
CERCLA. In particular, of the 21 sites at which remediation has not yet been completed, 12
sites contain residual material resulting from activities that were not licensed by NRC at the time
the Uranium Mill Tailings Act of 1978 (UMTRCA) became effective or at any time thereafter. As
defined by the UMTRCA, NRC does not have authority to regulate cleanup of covered residual
material resulting from an activity that was not so licensed.
The language of section 83 of the Atomic Energy Act (42 U.S.C. 2113(a)), was added to
that Act by UMTRCA. Section 83 a requires NRC to impose certain terms and conditions
relating to cleanup with respect to any "license issued or renewed after the effective date" of
section 83 for covered activities, and also imposes such terms or conditions on any such
"license in effect on the date of enactment" of the section. No such responsibility was imposed
upon NRC with respect to activities that were not under NRC license before the date of the
enactment of section 83, if they were not licensed thereafter.
Prior to the enactment of UMTRCA, neither the AEC nor the NRC had statutory
jurisdiction over residual material resulting from the processing of ore for source material. This
position was taken by the AEC after careful legal analysis, and was subsequently adopted by
the NRC when it succeeded to the AEC's regulatory functions. Though NRC exercised some
the staff will request that the Corps contact NRC if it plans to ship material that does not meet
one of the exemptions for a specific license in NRC regulations. See, e.g., 10 C.F.R. § 71.10.
-13-
control over such material in connection with licensed processing of ore for source material, it
did not exercise jurisdiction at inactive sites where no license was in effect. UMTRCA was
enacted because the Congress recognized that NRC did not have jurisdiction over radioactive
residuals resulting from the extraction of uranium or thorium from ore processed for its source
material content at inactive sites. This is evidenced by the floor remarks regarding the
amended version of H.R 13650, the bill that was enacted as UMTRCA Senator Hart
explained.
Although the NRC licenses active uranium mining and milling activities, existing law
does not permit the Commission to regulate the disposal of mill tailings once milling and
mining operations cease and the operating license expires. It is that authority to
regulate tailings after milling operations cease, that we propose be given to the NRC.21
Because the residual material at many FUSRAP sites was generated in activities that were not
licensed when UMTRCA was enacted, or thereafter, NRC today has no basis to assert any
regulatory authority over handling of the residuals at those sites
The NRC staff notes that many of the remaining sites (i.e., sites containing materials
other than mill tailings) also raise some significant jurisdictional questions in their own right. For
instance, a few of the sites may still be in legal possession of DOE even though the Corps is
conducting clean up at the site under FUSRAP. While the issue of possession appears to be a
matter of continuing discussion between the Corps and DOE, it is highly unlikely that NRC
would have authority to require a license for cleanup activities conducted at a site which
continues to be a DOE-owned or controlled site. In addition, the concentration of radioactive
material at some of the remaining sites may not be sufficient to trigger NRC license
requirements. While NRC does not have information sufficient to reach a final conclusion for
21124 Cong. Rec. S18,748 (October 13, 1978).
-14-
specific sites, it is the NRC staffs understanding that some of these sites may contain only
"unimportant quantities" of source material as defined under 10 CFR §40.13(a). If this is the
case, the amount of material at these sites would not be sufficient to implicate NRC license
requirements. Given the limitations of NRC jurisdiction under UMTRCA, the potential DOE
ownership issues, and the possibility that several sites may contain "unimportant quantities" of
source material, it is likely that the number of FUSRAP sites over which NRC may have
jurisdiction would be very small even absent the CERCLA permit waiver.
The Corps' Authority Under the Appropriations Act
In its response, the Corps states that the AEA also exempts FUSRAP activity from NRC
licensing because Congress intended the Corps to fill the shoes of DOE, an agency exempt
from NRC regulatory requirements under most circumstances. DOE disagrees with this
characterization, claiming that, for the most part, it has no role in the FUSRAP program at this
time (regulatory, contractual, or otherwise). As such, in DOE's view, the Corps cannot rely on
any exemption in the AEA to avoid regulation by NRC. Nevertheless, DOE acknowledges that
the transfer to the Corps did not completely eliminate the Department's involvement with
FUSRAP. While the issues have yet to be resolved, DOE may have responsibility for inventory
reporting of government-owned FUSRAP sites to the General Services Administration and may
be required to conduct post-cleanup monitoring at some sites after the Corps' clean up
activities cease.
DOE and the Corps are working on an MOU to address their disagreements regarding
the nature of the transfer of the FUSRAP program and their respective responsibilities under
-15-
the program. Until the disagreement has been resolved, either by the agencies or by further
direction from Congress, the NRC staff need not reach a conclusion on the matter
Nevertheless, in view of the clear applicability of CERCLA §121 (e)(1) to the Corps' activity at
FUSRAP sites, the staff does not believe that it would be appropriate to require the Corps to
obtain an NRC license for its activity at FUSRAP sites.
IV. CONCLUSION
In sum, Congress has given NRC no clear directive to oversee USACE's ongoing effort
under CERCLA to complete the FUSRAP cleanup project. Indeed, Congress has provided
NRC no money and no personnel to undertake an oversight role. In addition, Congress has
made it clear that the Corps is to undertake FUSRAP cleanup pursuant to CERCLA which
waives permit requirements for onsite activities. In these circumstances, we are disinclined to
read our statutory authority expansively, and to commit scarce NRC resources, to establish and
maintain a regulatory program in an area where, under Congressional direction, a sister federal
agency already is at work and has committed itself to following appropriate safety and
environmental standards.
Accordingly, I deny the petition insofar as it requests NRC to impose licensing and other
regulatory requirements on the Corps for that agency's handling of radioactive material at
FUSRAP sites. Both the permit waiver provision of CERCLA and the ambiguity regarding
DOE's role in the program lead me to the conclusion that NRC should not inject itself into the
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FUSRAP program at this time. Absent specific direction from Congress to the contrary, NRC
will continue to refrain from regulating the Corps in its clean up activities at FUSRAP sites.
-17-
As provided by 10 C.F R. § 2.206, a copy of this Decision will be filed with the Secretary
of the Commission for the Commission's review. The Decision will become the final action of
the Commission 25 days after issuance, unless the Commission, on its own motion, institutes
review of the Decision within that time.
Dated at Rockville, Maryland this 26th day of March, 1999
FOR THE NUCLEAR REGULATORY COMMISSION
Original Signed By
Carl J. Paperiello, Director
Office of Nuclear Material Safety
and Safeguards
Attachment 2
Residuals Transportation Plan for the Midnite Mine Water Treatment Plant
Residuals Management Plan for the
Midnite Mine Water Treatment Plant, Rev. 10
WME, LLC
November 1, 2013
Residuals and Ion-Exchange Resin
Transportation Plan
for the Midnite Mine
Water Treatment Plant
Prepared on Behalf of:
Newmont USA Ltd.
6363 South Fiddler's Green Circle
Greenwood Village, Colorado 80111
and
Dawn Mining Company
P.O. Box 250
Ford, Washington 99013
[phone]
Fax [phone]
Prepared for:
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Ernvlronme>nt-c3l Service's., Inc.
Prepared by:
227 Jefferson St.
Fort Collins, Colorado 80524
January 15,2013
Wright Environmental Services
Table of Contents
1 Introduction 1
1.1 Purpose and Objectives 2
12 Plan Organization 2
2 MATERIAL CHARACTERISTICS AND SHIPPING CLASSIFICATION 3
2.1 Material Characteristics 3
2.1.1 Residual Solids 3
2.1.2 Ion-Exchange Resins 3
2.2 Material Shipping Classification 3
2.2.1 Residual Solids 3
2.2.2 IX Resins 4
3 Transportation Carrier 5
4 TransporTation scenarios 6
4.1 Transportation Scenario 1: Dawn Millsite TDA-4 6
4.1.1 Shipping Containers 6
Transportation 6
4.1.2 6
4.1.3 Shipping Papers and Documentation 6
4.13.1 Shipping Papers 6
4.1.3.2 Off-Site Rule Verification 6
4.2 Transportation Scenario 2: Energy Fuels White Mesa Mill 6
4.2.1 Shipping Containers 6
Transportation 7
4.2.2 7
4.2.3 Shipping Papers and Documentation 7
4.2.3.1 Shipping Papers 7
4.2.3.2 Instructions to Carrier 7
4.2.4 Off-Site Rule Verification 7
4.3 Transportation Scenario 3: US Ecology Grand View Facility & Cameco's Wyoming Facility 7
4.3.1 Residual Solids 8
4.3.1.1 Shipping Containers 8
4.3.1.2 Transportation 8
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4.3.1.3 Shipping Papers and Documentation 8
4.3.2 IX Resins 8
4.3.2.1 Shipping Containers 8
4.3.2.2 Transportation 9
4.3.2.3 Shipping Papers and Documentation 9
4.4 Transportation Scenario 4: US Ecology Richland Facility 9
4.4.1 Shipping Containers 9
4.4.2 Transportation 10
4.4.3 Shipping Papers and Documentation 10
4.4.3.1 Shipping Papers and Manifests 10
4.4.3.2 Off-Site Rule Verification 10
5 REFERENCES 12
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LIST OF EXHIBITS
Exhibit A: Carrier Documents
A.1: Carrier DOT Hazardous Materials Transportation Certificate
A.2: Documentation:Contingency Plan (Emergency Response), Health and Safety Program, Security Plan
A.3: Dawn Mining Company Instructions to Carrier
A. 4: Example Bills of Lading for IX Resins
Exhibit B: Documentation for US Ecology Richland Facility
B. 1: Radioactive Waste Shipment Certification Form RHF-31 D
B. 2: Example Waste Manifest (NRC forms 540, 541)
Exhibit C: Documentation for Energy Fuels Inc. White Mesa Mill
C. 1: Example Shipping Papers
Exhibit D: Documentation for US Ecology Grand View Facility
D. 1: Land Disposal Restriction Form
D.2: Uniform Hazardous Waste Manifest
Exhibit E: Typical IX Resin Technical Data
DOWEX 21K XLT & RESINTECH SIR-1200
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1 INTRODUCTION
This Residuals and Ion-Exchange Resin Transportation Plan (RTP) is provided as a supporting document to the
Residuals Management Plan, which was prepared in accordance with the Statement of Work (SOW) for Interim
Water Management (U.S. Environmental Protection Agency [EPA], 2008) for the Midnite Mine Superfund Site in
accordance with the Unilateral Administrative Order (UAO) for Remedial Design and Remedial Action (EPA Docket
No. Comprehensive Environmental Response Compensation and Liability Act [CERCLAJ-10-2009-0026). The
subsequent Consent Decree (CD) with its associated Statement of Work (CD-SOW) incorporates the requirements
from the UAO into the CD. This plan has been prepared for Dawn Mining Company (DMC) and Newmont USA
Limited (Newmont) by Wright Environmental Services Inc.
As discussed in the RMP, four potential off-site disposal areas have been identified that would be utilized in
conjunction with the four different sludge management alternatives described in the RMP. The potential off-site
disposal areas include:
• DMC's Millsite TDA-4 in Ford, Washington
• Energy Fuels, Inc. (Energy Fuels) White Mesa Mill near Blanding, Utah
• US Ecology's Grandview Facility in Idaho and ion-exchange resin transportation to Cameco's Smith Ranch
ISL Central Processing Plant in Wyoming
• US Ecology's Richland Facility in Washington
The first disposal alternative, proposed as a short-term, interim disposal option only, is to continue the current WTP
process for direct disposal of WTP sludge in the Dawn Millsite Tailings Disposal Area 4 (TDA-4). Final closure of the
Dawn Millsite TDA has been delayed for reasons unrelated to past disposal of WTP sludge. Consequently, TDA-4
remains available as a viable, interim, short-term disposal option which is cost effective and has been approved by
both the EPA and the Washington Department of Health (WDOH). This alternative is available and will be utilized
through the 2013 treatment season. This alternative will not be available after 2013.
The second disposal alternative is to have the WTP residuals processed for their source material content by Energy
Fuels (formerly Denison Mines) at their White Mesa Mill near Blanding, Utah. The Energy Fuels White Mesa Mill is a
"licensed off-site facility;" its license is administrated by the Utah Department of Environmental Quality (UDEQ),
Division of Radiation Control (DRC) under the U.S. Nuclear Regulatory Commission (NRC) Agreement State
Program. At that time, DMC would seek permission from and coordinate with the EPA to implement the proposed
long-term disposal alternative and\or the other alternative, as appropriate.
The third alternative is to modify the existing WTP system by adding an ion-exchange component. This component
would selectively remove uranium from the mine water before the chemical precipitation step is used which produces
sludge needing disposal. By removing uranium from the mine water before the sludge is produced, the sludge would
not have levels of uranium in excess of 0.05 percent (%) and could therefore be disposed of at the US Ecology
facility in Grandview, Idaho, located 70 miles southeast of Boise, Idaho. This alternative is predicated on the
assumption that the uranium levels in the WTP residuals have been reduced using ion-exchange or similar method
as part of the WTP process. Disposal costs at the Grandview facility are more cost effective than at the US Ecology
Richland facility which is the only disposal option for the sludge with uranium in excess of 0.05%.
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Under this alternative, the ion-exchange (IX) resin loaded with uranium would be transported to the Cameco
Resources Smith Ranch ISL Central Processing Plant near Douglas, Wyoming for processing. The Cameco facility
would remove the uranium from the resin and regenerate the exchange capacity of the resin. Subsequently, the
resin would be transported back to the Midnite mine for re-use. Cameco's NRC radioactive materials license
specifically allows Cameco to accept loaded ion-exchange resins from water treatment facilities. This alternative
would be implemented after disposal at TDA-4 is no longer available and if reprocessing of the sludge is not available
at the Energy Fuels facility.
The fourth disposal alternative is to dispose of residuals at the US Ecology's facility in Richland, Washington. This
facility would be utilized for disposal of source material waste from the ion-exchange process. This facility could also
be used as a contingency for disposal of the entire waste stream from the water treatment plant.
This RTP addresses the transportation to each of these four potential disposal facilities.
1.1 Purpose and Objectives
The purpose of this RTP is to describe the shipping program and the requirements for transporting the WTP residuals
and IX resin from the Midnite Mine WTP in accordance with the requirements of Section 12.2.3 of the ROD (EPA,
2006). The objective of this RTP is to ensure that the WTP residuals and IX resins are appropriately transported in
accordance with the UAO, SOW, and ROD, as well as state and federal requirements.
1.2 Plan Organization
Section 2 presents the physical and radiological characteristics and the shipping classification of the WTP residuals
and IX resins, which are used as the basis for determining the U.S. Department of Transportation (DOT) shipping
requirements under 49 CFR Part 170 through Part 173. Section 3 presents the information regarding the selected
material transport carrier. Section 4 presents the requirements for the shipping to the four potential disposal facilities
based on the material DOT classification developed in Section 2. Referenced materials are included in specific
exhibits to this RTP.
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2 MATERIAL CHARACTERISTICS AND SHIPPING CLASSIFICATION
2.1 Material Characteristics
2.1.1 Residual Solids
Based on years of analytical testing on the WTP residuals, these materials contain greater than 0.05 percent natural
uranium and are considered Source Material as per 10 CFR Part 810.3. Therefore, these materials are specifically
exempted from the Resource Conservation and Recovery Act (RCRA) under 40 CFR Part 261.4 and are not listed as
hazardous waste as defined by RCRA 40 CFR Part 261.3. In addition, based on analytical test results, these
materials do not exhibit the characteristics of hazardous waste, including toxicity, ignitability, corrosivity, or reactivity.
These material are not classified as a mixed waste.
While the effluent sludge produced as part of the ion-exchange process described in the RMP would have uranium
concentrations less than 0.05 percent and would therefore not be considered Source Material, for the purposes of
this transportation plan, it is assumed that the effluent sludge would be transported using the more stringent
procedures required for Source Material.
2.1.2 Ion-Exchange Resins
IX resins to be used at the Midnite Mine are Type I or Type II strong base anionic exchange (SBAE) resins (MWH,
2011). SBAE resins equal or similar to Dowex 21K XLT or ResinTech SIR-1200 will be used. Based on initial
loading from bench scale testing with site-specific waters the IX resins will be loaded with uranium to approximately
30,000 mg/kg to 44,000 mg/kg (Tetra Tech, 2010) The resins have individual bead densities of approximately
1.08 g/mL and shipping weights of approximately 670 g/L or 42 lbs/ft3.
2.2 Material Shipping Classification
2.2.1 Residual Solids
The origin and radiological characteristics of the WTP residuals were used to establish the material transportation
classification as per DOT requirements. The radionuclides present are all derived from a natural uranium ore deposit
and have not been processed. The WTP residuals are classified as Source Material and meet the definition of Low
Specific Activity (LSA) material per 49 CFR 173.403 for shipping purposes. These residuals meet LSA group I
criteria (iii) for shipments to US Ecology of "Radioactive material excluding fissile material, for which the A2 value is
unlimited." These residuals also meet LSA group I (i) criteria for shipments to the Energy Fuels White Mesa Mill.
"uranium and thorium ores, concentrates of uranium and thorium ores, and other ores containing naturally
occurring radionuclides, which are intended to be processed for use of these radionuclides."
The proper shipping name for this material per 49 CFR 172.101 is Radioactive Material, LSA-I non-fissile, Class 7,
UN2912. The Washington Administrative Code classification of the material is Class A low level radioactive waste-
Unstable (AU).
The allowable conveyance activity for transportation of uranium ores and Source Material is unlimited as per 49 CFR
Part 173.427(e), Table 5. Uranium ores may be shipped unpackaged as per 173.427(c). All shipments will be
consigned as exclusive use, as defined in 49 CFR Part 173.403, which essentially means that a single consignor
having radiological training and resources appropriate for safe handling of the consignment has complete use and
oversight of the loading and unloading of the consignment. As per 173.427(a)(6)(v), the shipments are exempt from
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placarding requirements except for the labeling and marking requirements identified in 173.427(6)(vi), and external
contamination control limits per 173 443.
2.2.2 IX Resins
In order to classify the materials and develop the appropriate documentation for an IX resin shipment, the RSO or
properly trained designee will determine the expected activity and mass for each consignment. In many cases the
precise activity of a shipment is not known. Generally, this will be the case for virtually all environmental, operational,
and process samples. It is acceptable to estimate the expected activity of a consignment using historical or media
appropriate data to determine whether the consignment is a radioactive material The RSO or designee will
document the data and assumptions used to make this determination for each shipment. Based on historical
experience with uranium recovery operations using IX resins, the loaded IX resins contain sufficient amounts of
radionuclides to be classified as radioactive material, LSA-I non-fissile, Class 7, UN2912 as per 49 CFR 172.101. All
shipments will be consigned as exclusive use, as defined in 49 CFR Part 173403, which essentially means that a
single consignor having radiological training and resources appropriate for safe handling of the consignment has
complete use and oversight of the loading and unloading of the consignment.
Once the expected consignment activity and activity concentration is determined, the RSO or designee will consult
the limits contained in the table contained in 49 CFR §173.436, "Table of Exempt Material Activity Concentrations
and Exempt Consignment Activity Limits for Radionuclides". This table lists the concentration and activity limits for all
radionuclides. In order to meet the definition of radioactive material, a planned shipment must exceed both the
activity concentration limit and exempt consignment activity limit. If the shipment does not exceed both, it must be
shipped as a nonhazardous material and may not be shipped as a radioactive material.
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3 TRANSPORTATION CARRIER
CAST Transportation has been identified as the certified contract transportation carrier (Carrier) for WTP residual
shipments to third party facilities. DMC will continue to transport the WTP residuals to the Dawn Millsite as long as
that alternative is permissible. Documentation that the Carrier has and possesses current DOT Hazardous Materials
Certificate (Reg 051509 550 028RT), Contingency Plan, Health and Safety Program, Hazardous Materials Security
Plan, Interstate Commerce Commission Permit are provided in Exhibit A. The Carrier will transport the WTP
residuals from the Midnite Mine WTP according to their Policy and Procedure Manual.
The Carrier will be notified when the packages (tanker trailer for IX resins or trailer with Super SackSMype containers
for WTP residual solids) will meet capacity and will pick up the trailer for transportation according to the appropriate
scenario. No loading or unloading of the package(s) will be allowed between the Midnite Mine and designated
disposal site as per 40 CFR Part 173.441 (b)(1)(iii).
The Carrier will ensure that its drivers maintain the appropriate drivers certifications, endorsements, and emergency
response training. Emergency response to incidents or accidents during transport will be the responsibility of the
Carrier. The Carrier will adhere to the procedures and requirements identified in their Contingency Plan, Hazardous
Materials Security Plan, Health and Safety Program, and DMC instructions to the Carrier.
All work will be conducted in a manner to minimize worker contact with radioactive materials and comply with the As
Low As Reasonably Achievable (ALARA) principle, keeping radiation exposure as low as reasonably achievable. All
work will be performed in accordance with Washington State regulations and DOT hazardous material transportation
regulations, 49 CFR 171-180. Furthermore, the Carrier will maintain requisite insurance coverage at all times during
the contract period.
The carrier will be responsible for providing and posting the appropriate markings, labels and\or placards on the
transport vehicles going to the third party facilities.
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4 TRANSPORTATION SCENARIOS
4.1 Transportation Scenario 1: Dawn Millsite TDA-4
This disposal alternative, will continue as a short-term, interim disposal option only and involves direct disposal of
WTP sludge in the Dawn Millsite tailings disposal area 4 (TDA-4). This alternative is currently being implemented
and will be ongoing only through the 2013 treatment season. This alternative will not be available after 2013. After
2013, DMC would seek permission from and coordinate with the EPA to implement the proposed long-term disposal
alternative and\or the other alternative, as appropriate.
The WTP solids will continue to be shipped in accordance with the Dawn Millsite Radioactive Materials License
(RML) (WN-I043-2) in the same manner as they have been for the past 10 years.
4.1.1 Shipping Containers
The WTP residuals will be transported in the existing DMC exclusive-use 13 cubic yard dump truck, which has been
used for this purpose for the past 10 years.
4.1.2 Transportation
DMC's will drive the dump truck to the Dawn Millsite site once the truck is filled. Because the Dawn Millsite is located
close to the Midnite Mine and the transportation cycle time is less than a few hours, no secondary truck will be
required to allow continued operations and discharge of the WTP.
4.1.3 Shipping Papers and Documentation
4.1.3.1 Shipping Papers
DMC will perform the requisite scanning of radiation emanating from the loaded trailers as per 49 CFR 173.441.
Shipping papers will be completed for each shipment of packages and provided to the Carrier. An example shipping
paper is presented in Exhibit C.
4.1.3.2 Off-Site Rule Verification
This facility remains acceptable for receipt of the WTP residuals as confirmed with EPA Region 10.
4.2 Transportation Scenario 2: Energy Fuels White Mesa Mill
Under this scenario, the Midnite Mine WTP residuals will be loaded into tight-tarped dump trailers and driven to the
Energy Fuels White Mesa Mill, where they will be off loaded and managed in accordance with their RML (No. UT
1900479) and processed for their source material content.
4.2.1 Shipping Containers
The Carrier will maintain an end-dump or side-dump multi-axel trailer with a capacity of up to 80,000 pounds gross
vehicle weight (gvw) on site for loading of the WTP residuals. As described in Section 2.2 and as per 49 Part
173.427(c), the WTP residuals can be shipped in bulk and unpackaged. Secured tarpaulins will be used to protect
contents from weather and leakage.
The trailers will be hauled by single-axel or multi-axel tractor trucks and will comply with all federal regulations
including, but not limited to, 49 CFR Part 173.427(a)(6), 173.427(c), and 173.443. Each trailer is considered a single
consignment or shipping package. Based on the physical characteristics of the WTP residuals (i.e., high percent
solids and absence of free water), no bed liners are required, but may be used if deemed prudent by DMC.
Residuals Transportation Plan
January 15, 2013
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4.2.2 Transportation
A Carrier representative will be present following completion of trailer loading and will secure the tarpaulin and
transport the trailer to the Energy Fuels White Mesa Mill after external radiological measurements for contamination
and for exposure have been completed. The Carrier will deliver an empty trailer to the site to allow for continued
loading of the WTP residuals while transporting the full trailer. If practicable, a second trailer of equal or lesser
capacity, also referred to as a "pup" trailer, may be added to the primary trailer to increase transportation efficiency.
The Carrier will empty their trucks as directed by Energy Fuels. The trailers will then be covered, externally
decontaminated, and returned to the Midnite Mine for reloading. The unloading of the material, trailer
decontamination, and release of the trailers at the Energy Fuels White Mesa Mill will be performed in accordance
with the Energy Fuels RML and standard operating procures (SOP).
4.2.3 Shipping Papers and Documentation
4.2.3.1 Shipping Papers
DMC will perform the requisite scanning of radiation emanating from the loaded trailers as per 49 CFR 173.441.
Shipping papers will be completed for each shipment of packages and provided to the Carrier. An example shipping
paper is presented in Exhibit C.
4.2.3.2 Instructions to Carrier
The Carrier will be provided written instructions from DMC regarding the control of the material packages prior to
taking possession of the transportation packages as per 40 CFR Part 173.427(6). These instructions are included in
Exhibit A.
4.2.4 Off-Site Rule Verification
Should this alternative be required, the acceptability of the Energy Fuels White Mesa Mill to receive the WTP
residuals will be confirmed with EPA Region 8 less than 60 days prior to shipping.
4.3 Transportation Scenario 3: US Ecology Grand View Facility & Cameco's Wyoming
Facility
Under this alternative, DMC plans to ship the WTP residuals to the US Ecology Grand View RCRA treatment,
storage and disposal facility near Boise, Idaho. It is assumed that the WTP residual solids uranium and radionuclide
activity concentrations have been reduced through pretreatment of the influent water using IX or similar method to
meet the Grand View Waste Acceptance Criteria. The WTP residuals would be shipped in accordance with the
Grandview facility permits and RML. DMC will submit to US Ecology Grand View a Land Disposal Restriction Form
and a Uniform Hazardous Waste Manifest with each shipment to the Grand View facility. Examples of these forms
are included in Exhibit D.
In addition, this alternative involves transportation of loaded IX resins to Cameco Resources Wyoming uranium
recovery facility near Douglas, Wyoming for stripping of the uranium and regeneration of the IX resin's exchange
capacity. The stripped uranium would become part of Cameco's local uranium production stream and refined into
yellow cake (uranium oxide or U3O8). The resin stripping would be performed in discrete batches involving only the
resins from the DMC site, No intermixing of DMC's IX resins and Cameco's own IX resins would occur. The
regenerated DMC IX resins would be transported back to the DMC site for re-use.
Residuals Transportation Plan
January 15,2013
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4.3.1 Residual Solids
4.3.1.1 Shipping Containers
The Grand View facility is licensed as a "bulk" facility. Therefore, the WTP residuals will be transported in tarped
end-dump or side-dump trailers. The Carrier will maintain a multi-axel flat bed or enclosed trailer with a capacity of
up to 80,000 pounds gvw on site for loading of the filled containers of the WTP residuals as they are produced.
4.3.1.2 Transportation
The Carrier will maintain an end-dump or side-dump multi-axel trailer with a capacity of up to 80,000 pounds gross
vehicle weight (gvw) on site for loading of the WTP residuals. Secured tarpaulins will be used to protect contents
from weather and leakage.
The trailers will be hauled by single-axel or multi-axel tractor trucks and will comply with all federal regulations. Each
trailer is considered a single consignment or shipping package. Based on the physical characteristics of the WTP
residuals (i.e., high percent solids and absence of free water), no bed liners are required, but may be used if deemed
prudent by DMC.
The Carrier will deliver an empty trailer to the site to allow for continued loading of the WTP residuals while
transporting the full trailer. If practicable, a second trailer of equal or lesser capacity, also referred to as a "pup"
trailer, may be added to the primary trailer to increase transportation efficiency.
The trailers will be off loaded as directed by US Ecology Grand View personnel. The trailers will then be covered,
externally decontaminated, and returned to the Midnite Mine for reloading. The unloading of the material, trailer
decontamination, and release of the trailers at the Richland facility will be performed in accordance with the US
Ecology Grand View facility's RML and standard operating procures (SOP).
4.3.1.3 Shipping Papers and Documentation
DMC will perform the requisite monitoring of surface contamination per 173.443 and radiation emanating from the
loaded trailers as per 49 CFR 173.441. A Uniform Hazardous Materials Manifest will be completed by DMC and will
accompany each shipment. Examples of this manifest form is included in Exhibit D. In addition, DMC will provide
the Carrier with specific instructions for maintenance of the exclusive use shipment controls as per 40 CFR Part
173.427(6), emergency response guidance will be as per the Carrier's Contingency Plan. These instructions are
included in Exhibit A.
4.3.1.3.1 Off-Site Rule Verification
The acceptability of the Grand View facility will be confirmed with the EPA Region 10 Off-Site Rule coordinator
less than 60 days prior to shipping.
4.3.2 IX Resins
4.3.2.1 Shipping Containers
IX resin will be shipped from the Site using exclusive use1, liquid tight tanker multi-axel trailers.
' 49 CFR 1 73 403 - Definitions Exclusive use means sole use by a single consignor of a conveyance for which all initial, intermediate, and final loading and
unloading are carried out in accordance with the direction of the consignor or consignee The consignor and the carrier must ensure that any loading or
unloading is performed by personnel having radiological training and resources appropriate for safe handling of the consignment The consignor must provide
to the initial carrier specific written instructions for maintenance of exclusive use shipment controls, including the vehicle survey requirement of § 1 73 443
(c) as applicable, and include these instructions with the shipping paper information provided to the carrier by the consignor
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4.3.2.2 Transportation
The Carrier will provide exclusive use multi-axel tanker trailers for loading and transport of the IX resins. The trailers
will be hauled by single-axel or multi-axel tractor trucks and will comply with all federal regulations. Each trailer is
considered a single consignment or shipping package. The tanker will be loaded according to DMC's standard
operating procures (SOP).
The tanker trailers will be off loaded as directed by Cameco personnel according to Cameco's SOP. The trailers will
then be scanned, externally decontaminated as necessary, and returned to the Midnite Mine for reloading. The
unloading of the material, trailer decontamination, and release of the trailers at the Richland facility will be performed
in accordance with the US Ecology Grand View facility's RML and SOP.
4.3.2.3 Shipping Papers and Documentation
DMC will perform the requisite monitoring of surface contamination of radiation emanating from the loaded trailers as
per 49 CFR 173.441. A Bill of Lading will be completed for all shipments of IX resin to or from the Cameo Facility.
The Bill of Lading will include a description of material (Radioactive Material, UN2912, Low Specific Activity -1, ion-
exchange resin containing natural uranium), the IX resin slurry weight (lbs), the uranium weight (lbs), the
transportation classification of the IX resin (LSA, Exclusive Use Shipment) as well as the total activity of the
shipment in MBq and Ci. Example Bills of Lading for loaded and stripped IX resins are included in Exhibit A.
Further, DMC will provide the Carrier with specific instructions for maintenance of the exclusive use shipment
controls as per 40 CFR Part 173.427(6), emergency response guidance will be as per the Carrier's Contingency
Plan. These instructions are included in Exhibit A. Off-Site Rule Verification
4.3.2.3.1 Off-Site Rule Verification
The acceptability of the Cameco's Wyoming facility will be confirmed with the EPA Region 10. Because the Cameco
Facility does not routinely process hazardous substances from CERCLA sites and has not been subject to previous
Off-Site Rule approvals, EPA Region 10 would coordinate this review with the EPA Region 8 Office Off-Site Rule
coordinator, the Wyoming Department of Environmental Quality, Land Quality Division, and any local agencies that
regulate Cameco's Wyoming facility. This first-time verification could take between one to several months.
4.4 Transportation Scenario 4: US Ecology Richland Facility
The small volume Source Material waste stream from the ion-exchange process or the bulk sludge from the water
treatment plant could be disposed of at the US Ecology Richland Facility. The WTP residuals would be shipped in
accordance with the Richland facility RML No. WN-1019-2. DMC will submit to US Ecology a Radioactive Waste
Shipment Certification Form RHF-31 D and a Waste Manifest with each shipment to the Richland facility. Examples
of these forms are included in Exhibit B
4.4.1 Shipping Containers
The Richland facility is not licensed as a "bulk" facility. Therefore, the WTP residuals will be transported in IP-1
Certified Pac Tec Lift bags or similar containers for bulk sludge or 55-gallon drums or similar containers for the small
volume Source Material residuals from the ion-exchange process.
The lift bag containers are woven polypropylene flexible intermediate bulk containers (FIBC) for the shipping,
handling, and storing of dry, flowable products. The containers typically have an open duffel top with web tie closure,
flat bottom design, and a polyethylene or similar liner inserted and webbing lift loops.
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January 15,2013
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The filled containers, also referred to as packages, will each be stenciled with the words identified below in letters
equal to or greater than 1 inch in height as per 49 CFR Part 173.427(a)(6)(vi) and WAC 246-249-060:
RADIOACTIVE LSA-1
WAC Class AU
UN 2912
DMC-#
mm/dd/yyyy
The unique identification number (DMC-#) corresponds to the sequential package that was filled denoting the nth
package filled that operating year (i.e., the 23rd bag filled in 2011, would be labeled MDC-23).
The Carrier will maintain a multi-axel flat bed or enclosed trailer with a capacity of up to 80,000 pounds gvw on site
for loading of the filled containers of the WTP residuals as they are produced. The packages will be secured on the
flatbed and covered with a tight tarp or will be secured within the enclosed trailer to prevent shifting during transport.
If a different container is used, the characteristics will be comparable to those described above and will meet all
necessary DOT and US Ecology Richland facility RML requirements.
4.4.2 Transportation
A Carrier representative will be present following completion of trailer loading of and will secure of the tarpaulin and
transport the trailer to the US Ecology Richland facility after external radiological measurements for contamination
and for exposure have been completed. The Carrier will deliver an empty trailer to the site to allow for continued
loading of the WTP residuals while transporting the full trailer. If practicable, a second trailer of equal or lesser
capacity, also referred to as a "pup" trailer, may be added to the primary trailer to increase transportation efficiency.
The flatbed trailers will be off loaded as directed by US Ecology personnel. The trailers will then be covered,
externally decontaminated, and returned to the Midnite Mine for reloading. The unloading of the material, trailer
decontamination, and release of the trailers at the Richland facility will be performed in accordance with the Richland
facility's RML and standard operating procures (SOP).
4.4.3 Shipping Papers and Documentation
4.4.3.1 Shipping Papers and Manifests
DMC will perform the requisite monitoring of surface contamination per 173.443 and radiation emanating from the
loaded trailers as per 49 CFR 173.441. A Hazardous Materials Manifest (also known as NRC forms 540 and 541)
will be completed by DMC and will accompany each shipment. Examples of these manifest forms are included in
Exhibit B. In addition, DMC will provide the Carrier with specific instructions for maintenance of the exclusive use
shipment controls as per 40 CFR Part 173.427(6), emergency response guidance will be as per the Carrier's
Contingency Plan. These instructions are included in Exhibit A.
4.4.3.2 Off-Site Rule Verification
40 CFR Part 300.440(a)(4) requires determination of:
"...the acceptability under this section of any facility selected for the treatment, storage, or disposal of CERCLA
waste. EPA will determine if there are relevant releases or relevant violations at a facility prior to the facility's
initial receipt of CERCLA waste. A facility which has previously been evaluated and found acceptable under this
Residuals Transportation Plan
January 15.2013
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Wright Environmental Services
rule (or the preceding policy) is acceptable until the EPA Regional Office notifies the facility otherwise pursuant
to 300.440(d)."
The acceptability of the US Ecology Richland facility has been confirmed with Mr. Adam Baron, the EPA Region 10
Off-Site Rule coordinator. The acceptability of this facility to receive the WTP residuals will be confirmed with EPA
Region 10 less than 60 days prior to shipping.
Residuals Transportation Plan
January 15, 2013
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5 REFERENCES
MWH, 2012. Midnite Mine Superfund Site Revision 0 Pilot-Scale Test Results for Uranium Removal Using Anionic
Exchange Resins and Chemical Precipitation. Prepared for: Dawn Mining Company and Newmont USA
Limited. December 31, 2012.
Tetra Tech, 2010. Midnite Mine Ion-Exchange Treatability Testing Data Report Revision 2. Prepared for: Dawn
Mining Company and Newmont USA Limited. Section 2.2. June 28, 2010.
U.S. Environmental Protection Agency, 2008. Statement of Work (SOW) for Interim Water Management. Office of
Environmental Cleanup EPA Region 10.
U.S. Environmental Protection Agency, 2009. Unilateral Administrative Order (AO) for Remedial Design and
Remedial Action. EPA Docket No. CERCLA-10-2009-0026. 2009.
U.S. Environmental Protection Agency, 2010. Midnite Mine Superfund Site Spokane Indian Reservation Washington,
Record of Decision. Office of Environmental Cleanup EPA Region 10. September, 2006.
Wright Environmental Services, 2010. Residuals Management Plan for the Midnite Mine Water Treatment Plant.
December 29, 2010.
Residuals Transportation Plan
January 15, 2013
12
EXHIBIT A
CARRIER DOCUMENTS
A.1: Carrier DOT Hazardous Materials Transportation Certificate
A.2: Contingency Plan (Emergency Response), Health and Safety Program, Security Plan
A.3: Dawn Mining Company Instructions to Carrier
EXHIBIT A.1
CARRIER DOCUMENTS
Carrier DOT Hazardous Materials Transportation Certificate
UNITED STATES OF AMERICA
DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
HAZARDOUS MATERIALS
CERTIFICATE OF REGISTRATION
FOR REGISTRATION YEAR(S) 2012-2015
SOUTH PARK MOTOR LINES, INC., DBA, CAST TRANSPORTATION,
INC.
Attn: RANDY B. WITHROW
9850 HAVANA ST
HENDERSON, CO 80640-8443
This certifies that the registrant is registered with the U.S. Department of Transportation as required by
49 CFR Part 107, Subpart G.
This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this
document.
Reg. No: 051612 552 009UW Issued: 01/14/2013 Expires: 06/30/2015
Record Keeping Requirements for the Registration Program
The following must be maintained at the principal place of business for a period of three years from the
date of issuance of this Certificate of Registration:
(1) A copy of the registration statement filed with PHMSA; and
(2) This Certificate of Registration
Each person subject to the registration requirement must furnish that person's Certificate of Registration
(or a copy) and all other records and information pertaining to the information contained in the registration
statement to an authorized representative or special agent of the U. S. Department of Transportation upon
request.
Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement
must keep a copy of the current Certificate of Registration or another document bearing the registration
number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers
and semi-trailers not included) used to transport hazardous materials subject to the registration
requirement. The Certificate of Registration or document bearing the registration number must be made
available, upon request, to enforcement personnel.
For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and Hazardous
Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey Avenue, SE,
Washington, DC 20590, telephone [phone].
Registrant:
EXHIBIT A.2
CARRIER DOCUMENTS
Documentation: Contingency Plan (Emergency Response)
Health and Safety Program
Hazardous Materials Security Plan
TRANSPORTATION
January 15,2013
To whom it may concern:
This letter is certification that Cast Transportation has written, and trained our drivers on the Security
Plan and Risk Assessments in accordance with 75 FR 10974-10989 and 49 CFR 172.800, subparts H and I,
and 49 CFR 177.800. All Cast drivers are trained on Hazardous Materials per 49 CFR and also receive an
Emergency Response and Comprehensive Contingency Plan which contains procedur es and emergency
response phone numbers in case of a spill or release.
Michael Padllla
Safety Director
CAST Transportation
9850 Havana St
Henderson, CO 80640
303-534-6376
1-800-369-6374
HENDERSON
9850 Havana Street
Henderson, CO 80640-8443
[phone]
LARAMIE
217 South 1st Street
Laramie, WY 82070
[phone]
TRANSPORTATION
January 15, 2013
To whom it may concern:
This letter is certification that CAST Transportation has a Health and Safety Program. It is incorporated In
our Policy and Procedure manual and all drivers receive a copy and are trained on it during new hire
orientation.
Michael Padilla
Safety Director
CAST Transportation
9850 Havana St
Henderson, CO 80640
303-534-6376
1-800-369-6374
HENDERSON
9850 Havana Street
Henderson, CO 80640-8443
[phone]
LARAMIE
217 South 1st Street
Laramie, WY 82070
[phone]
EXHIBIT A.3
CARRIER DOCUMENTS
Dawn Mining Company Instructions to Carrier
Dawn Mining Company
Midnite Mine
Instructions to Hazardous Materials Carrier
The consignment material in each package is a US Department of Transportation (US DOT)
Class 7 radioactive material that qualifies as a Low Specific Activity as per 49 CFR 173.403.
rhe consignment material in each package is not a RCRA listed waste nor does it have RCRA
hazardous waste characteristics.
Once the Carrier takes possession of the consignment material package(s), rhe Carrier shall
maintain control of the package(s) at all rime. The carrier shall at all times avoid any and all
actions that will unnecessarily delay delivery or unnecessarily result in increased radiation levels
or radiation exposures to the transport workers or members of the general public as per 49 CFR
Part 174.427(6).
The Carrier shall not allow any loading or unloading of the consignment material package(s)
between the Midnite Mine and the final destination of the consignment material package(s). In
addition, the Carrier shall transport the consignment material in a safe and prudent manner such
that no leakage occurs from the shipment during normal transportation.
The Carrier shall comply with and implement the requirements and guidance identified in their
Emergency Response and Comprehensive Contingency Plan and Quality Assurance Plan as
appropriate.
EXHIBIT A.4
CARRIER DOCUMENTS
Example Bills of Lading for IX Resins
BILL-OF-LADING & LICENSED MATERIAL SHIPPING FORM
EMERGENCY CONTACT PHONE:
Loaded Ion-Exchange Resin Shipment Shipment Date.
From To
SHIPPER LICENSE NO. SHIPPER USDOTNO.
USDOT
SHIPPER HAZMAT REG. NO. SHIPPER
TELEPHONE NO.
HM
DESCRIPTION OF MATERIAL AND PACKAGING
Slurry
Weight (lbs)
Uranium
Weight (lbs)
CLASSIFICATION
Radioactive Material, UN2912, Low Specific Activity •
Ion-exchange resin containing uranium (natural)
Activity _MBq (. .Ci)
Cune (Ci) = 7 1 E-7 x grams of uranium (natural)
Megabecquerel (Mbq) = Ci x 3 7 E4
Low Specific Activity
(LSA)
Exclusive Use Shipment
Driver's Instructions:
The transport vehicle/tank must be surveyed prior to leaving the site and recorded on the
backside of this form.
The receiving party must be notified of your departure and when to expect your arrival
The tank must be inspected for leakage prior to leaving, halfway to the mine site and at the mine
site Any leakage found must be documented on the bottom of this form under comments and
reported to the radiation safety department
Dnvers's Signature Date
Comments
BILL-OF-LADING & LICENSED MATERIAL SHIPPING FORM
EMERGENCY CONTACT PHONE:
Stripped Ion-Exchange Resin Shipment Shipment Date.
From To
SHIPPER LICENSE NO. SHIPPER USDOTNO.
USDOT
SHIPPERHAZMATREG.NO. SHIPPER
TELEPHONE NO.
HM
DESCRIPTION OF MATERIAL AND PACKAGING
Slurry
Weight (lbs)
Uranium
Weight (lbs)
CLASSIFICATION
Radioactive Matenal, UN2912, Low Specific Activity -1,
Ion-exchange resin containing uranium (natural)
Activity _MBq (. .Ci)
Cune (Ci) = 7 1 E-7 x grams of uranium (natural)
Megabecquerel (Mbq) = Ci x 3 7 E4
Low Specific Activity
(LSA)
Exclusive Use Shipment
Driver's Instructions:
The transport vehicle/tank must be surveyed prior to leaving the site and recorded on the
backside of this form.
The receiving party must be notified of your departure and when to expect your arrival.
The tank must be inspected for leakage prior to leaving, halfway to the mine site and at the mine
site Any leakage found must be documented on the bottom of this form under comments and
reported to the radiation safety department.
Drivers's Signature Date
Comments
EXHIBIT B
DOCUMENTATION FOR US ECOLOGY RICHLAND FACILITY
B.1: Radioactive Waste Shipment Certification Form RHF-31 D
B.2: Example Waste Manifest (NRC forms 540 and 541)
EXHIBIT B.1
DOCUMENTATION FOR US ECOLOGY RICHLAND FACILITY
Radioactive Waste Shipment Certification Form RHF-31 D
RADIOACTIVE WASTE SHIPMENT CERTIFICATION FOR SHIPMENTS TO THE
COMMERCIAL RADIOACTIVE WASTE DISPOSAL FACILITY
OR RADIOACTIVE WASTE PROCESSOR
The following certification, completed as applicable, is made to the state of Washington:
Certification is hereby made to the state of Washington that the radioactive waste described on manifest/bill of lading No.
has been inspected and it has been determined that the materials are properly classified, described, packaged, marked, and labeled, and are in proper
condition for transportation according to the applicable federal and state regulations, laws, rules, and licenses.
The undersigned shall indemnify and hold harmless the state of Washington from any and all claims, suits, losses, charges, and expenses on account
of injuries to any and all persons whomsoever, and any and all property damage arising or growing out of or in any manner connected with this
shipment to the extent that the claims, suits, losses, charges, or expenses are caused in whole or in part by negligent acts or omissions of the
undersigned 1
Except for any violation of applicable state or federal statute or regulation or license condition respecting packaging and shipment, inspection and
acceptance of any item or container or material covered by this certification by the state of Washington or a duly authorized contractor shall release
the party who executed this certificate from any and all requirements of indemnification and hold harmless from injury or loss.
SECTION A:
GENERATOR. Dawn Mining ComPany
MA
PERMIT NUMBER:
VOLUME OF WASTE fN THIS SHIPMENT.
(Company or Agency Name)
BY TITLE _
(Printed Name)
SIGNATURE: DATED
SECTION B:
BROKFR No Bro^er Used
PERMIT NUMBER-
VOLUME OF WASTE IN THIS SHIPMENT-
SECTION C
CARRIER
VOLUME OF WASTE IN THIS SHIPMENT:
DOH RHF-31D
Updated 3/01
(Company Name)
BY- TITLE_
(Printed Name)
SIGNATURE: DATED-
(Company Name)
BY TITLE: DRIVER
(Printed Name)
SIGNATURE- DATED:
Federal government agencies entering into this certification are subject to all applicable federal law including, but not limited
to, the Federal Tort Claims Act and the Anti-Deficiency Act.
EXHIBIT B.2
DOCUMENTATION FOR US ECOLOGY RICHLAND FACILITY
Example Waste Manifest (NRC forms 540, 541)
APPROVED BY OMB: NO. 3150-0104
EXPDIf 8- 0V3ir»13
, Q"%tr tfm H««m>eafacl—i raauett 43 n
vtoM* to VH Ragenfe and FOtArftwtCT Sarvcu bMb <T-4F13| US **idMf R*.
* MM Oi NRC to atari MfcttM nqunmii ci F««nfl m VM toencira tar tM u*i taAtnvi
pwiUC JtaSVOOCi.oi frr>toiwT»iB»ltaiiiteoJwii.>«ftiih>oH>*wg'>w» W to m* Dwh Oftou ( * not frapav lomnty watO ONB nW rwntai. Dw NRC rmr **t sanriua v •pona. ana* a paia
NRC FORM 540
[I Z010I
U.S. NUCLEAR REGULATORY COMMISSION
UNIFORM LOW-LEVEL RADIOACTIVE
WASTE MANIFEST
SHIPPtNO PAPER
1 EMERGENCT TELEPHONE NUMBER in • Am COM}
ORGANIZATION
1 19 THIS AN *BACUMIVE USE" SHIPMENT!
YE* p NO
3 TOTAL MIUW Of
MCKAOBS IDCMTVI&D
ON TWU. MAMtfUT
4 DOES EPA RCQUUlTFn
WASTE REQUIRING A
MANIFEST ACCOWAMV
THtS SHlPHENP
If *V«*.' pmtto MM MIMI Norttov
-1
ft SHIPPER - NAMt AND FACltfTY
U3EP PCRMJI WJUBCH
COUICTOH
PHOCESSOH
GCNEHATUR T>Pt
a CARRIER • and AlUinftft
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NRC FORM M2 AND MSA
ADDITIONAL. INFORMATION
PAD* (51
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PAGE4SI
t CONSiONeC'NMmantfrw3H)Ao*BU
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I MANIFEST NUMBER
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10 CERTIFICATION
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AUTHORIZED SIGNATURE
11 U.t OCPARTVENI OFTRAN&POfllAnON OESCAlHnOH liwlubkraj praoar iliipptig nam. huM riaii UN fO nun«M 1& TOTAL WEUHT
Oft VOLUME
IB lOENTlHCATtON
NUMBER O*
PACKAGE
FOR CONSIONEE HOC ONLV
NRC FORM 540 (B-3010)
APPHQVED BY Plat. NO. 3150-0160
EXPIRES: 0t7S1/S013
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B u BM Rand* ano POLVPtfwcy Sena BrancM |T-5 fl3\ U.S. NWaar Rant**** Co
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don —1~r*~r » QioenQy <rfd OMD o It* NRC i
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Ewwor, end a pawaw ai wl t—ja—d to ••••wwtln in namiiiimn i•
NRC FORM 541
(MOID)
U.S. NUCLEAR REGULATORY COMMISSION
UNIFORM LOW-LEVEL RADIOACTIVE
WASTE MANIFEST
CONTAINER ANO WASTE DESCRIPTION
AddRJonaJ Nucktv Ragubuvv ComntbBkm {NRC) RauutromniiU toi Cartnil Trentf ar and
QlipaUDf RIBOMNS Walla
&SPOSAL COWTMltAa
1 MANIFEST TOTALS
NTT WASTE
VOLUME
ui.1!
NET WASTE
WUKMIT
tv>)
SPECIAL HUC1EAH MATERIAL luminal
ALL NUCLIDES
SOURCE
I
3 MANIFEST
PAGE OF PAGEJS)
4 &MPPfcRNAM£
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CONTAINER
fCMTireATtON
GEWSUTOH
ONUMBERfS)
.BNTAdwE* oesenf-
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0ISPOSAL CONTAINER DESCRIPTION
r» ]Q" —
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i ^ (uSvft*)
r~l (inSvVTvJ
WASTE DESCRIPTION FOR EACH WASTE TYPE IN CONTAINER
WASTE
ANO
CONTAINER
WEfOHT
(HQ)
PHYSICAL DESCRIPTION
"Z ' 11 SORBCKT
APPROXIMATE 50LIOiriCATtON
*ASTE STAB«U£ATlON
VOllMttS) IN MEttA
CONTAWEH (Saa Mats Jj
CHEMICAL DESCRjfT'ON
OiMiCAL FQAMr
CH£LAT1NCAC£KT CHELATING
AGENT
*F » 0 lit
RADIOLOOCAL DESCRIPTION
rVDA/CuAi. RAOtOpnXX>OES AND ACTIVITY (US*) ANU
CONTAMER TOTAL. OR COMAMSR TOTAL ACTtVfTV
AND RAOtONUCLfiE PERCENT
16
WASTE
CLASSOn-
CAT-ON
AS-CttoB« toto MJ-Ctn*
j ba tertnwad by --OP.*
MOTE 1* Cuntainar Pmuteitoi Cadai. fet tiwamiwl
3 Nnfe On** ur Pal
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74 OB
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NRC FORM 541 <B-»10)
EXHIBIT C.1
DOCUMENTATION FOR ENERGY FUELS WHITE MESA MILL
Example Shipping Papers
STRAIGHT BILL OF LADING
Shipper number:
Date Shipped:
Consignee (to) Shipper (from)
NAME Energy Fuels, Inc.
NAME Dawn Mining Co.
STREET
6425 South Highway 191, P.O. Box 809
STREET
5326 Uranium City Rd
2&1 CITY, STATE
Blanding, UT
ZD?
84511
CITY, STATE
Ford, WA
ROUTE
99013
Vehicle number
ESTIMATED CUBIC YARDS DOT Proper shipping name and description
Weight Rate
(Tons)
(SUBJECT TO CORRECTION)
CHARGES
(for Curiec
IMC only)
Sbipping Name: Radioactive Material-LSA 1 {non-fissile)
Hazard Class:
Identification Number:
Packaging:
Quantity:
Radionuclide^):
Form:
Transport Index:
Class 7
UN 2912
Bulk-Unpackaged
_TBqC_ Ci)
fJ-Nat, and associated decay chain
progeny
Solid (Unrefined Uranium Ore)
RECEIVED, subject to the-classification and lawfully filed tariffs if applicable, or the inrlividutlly determined rates In effect on the dace of the Issue of Bill of
Lading, the property described above in apparent goad order, except as noted (contents arn} conditions of packages unknown), marked, consigned, and destined
as indicated above which said carder (the word carrier being understood throughout, this contract as rneaniog any person or corporation in possession of the
properly under the contract) agrees to carry to the usual place of delivery at said destination, if on its route, otherwise parly at any time interested in all or any
said property, that every service to be performed heronder shall be subject to all the bill of lading terms and conditions in the governing classification cm the
dote of shipment
Shipper hereby certifies that he is familiar with all the bill of lading terms and conditions in the goveonmg classifications ami the said terms and conditions
are hereby agreed to by the shipper and accepted for himself and his assigns.
Special Instructions; This shipment of uranium ore has been consigned by Denison and is being shipped as an exclusive (sole) use shipment. Accordingly,
the contents of this shipment must be loaded at the Mine and unloaded at the Mil), absent any unloading 0r additional loading prior to delivery at the Mill.
The transportation conveyance trailer must be utilized only for uranium ore transport until such time (hat mill personnel coodueta survey of the interior
and exterior of (he trailer and dcterroiae that the trailer can be released for unrestricted use. All signage related to the radioactive material shipment must be
removed from the conveyance ttaOar.
Emergency Contact Phoae Number
Signature:
[phone]
Date
Received at White Mesa Mill on 20 _by
EXHIBIT D
DOCUMENTATION FOR US ECOLOGY GRAND VIEW FACILITY
D.1. Land Disposal Restriction Form
D.2: Uniform Hazardous Waste Manifest
EXHIBIT D.1
DOCUMENTATION FOR US ECOLOGY GRAND VIEW FACILITY
Land Disposal Restriction Form
US Ecology, Inc. Land Disposal Restriction Form
GENERATOR: EPA I.D. NUMBER:
WASTE STREAM or PROFILE NUMBER: MANIFEST DOC. NO. LINE NO..
WASTE IS A: Q WASTEWATER O NON-WASTEWATER O DEBRIS
NOTIFICATION FREQUENCY: Q ONETIME Q REQUIRED WITH EACH SHIPMENT
EPA WASTE CODES (from 40 CFR 268.40)
UHC's (Underlying Hazardous Constituents 40 CFR 268.48)? QNO I |Yes - List:_
A. • Restricted Waste Meets Treatment Standards (40 CFR 268.7(a) (3))
F The restricted waste identified above meets the treatment standards in 40 CFR 268.40 or Alternative LDR treatment standards
for contaminated soil 40CFR268.49 and can be landfill disposed without further treatment. I have attached all supporting
analytical data, where available.
I certify under penalty of law that I personally have examined and am familiar with the waste through analysis and
testing or through knowledge of the waste to support this certification that the waste complies with the treatment
standards specified in 40 CFR Part 268 Subpart D. I believe that the information I submitted is true, accurate and
complete. I am aware that there are significant penalties for submitting a false certification, including the possibility of
a fine and imprisonment.
B. • Restricted Waste Treated To Treatment Standards (40 CFR 268.7(b) (I) & 268.7 (b) (2))
The treatment residue, or extract of such residue, or the restricted waste identified above has been tested to assure that the
treatment residues or extract meet all applicable treatment standards in 40 CFR 268.40 and/or performance standards in 40
CFR 268.45.1 have attached all supporting analytical data, where available.
1 certify under penalty of law that I personally have examined and am familiar with the waste through analysis and
testing or through knowledge of the waste to support this certification that the waste complies with the treatment
standards specified in 40 CFR Part 268 Subpart D. I believe that the information 1 submitted is true, accurate and
complete. I am aware that there are significant penalties for submitting a false certification, including the possibility of
a fine and imprisonment.
C. • Restricted Waste With Technology Based Treatment Standards (40 CFR 268.7(b) (4))
F I certify under penalty of law that I personally have examined and am familiar with the treatment technology and operation of
the treatment process used to support this certification and that based on my inquiry of those individuals immediately
responsible for obtaining this information. I believe that the treatment process has been operated and maintained properly so
as to comply with the treatment standards specified in 40 CFR 268.40, without impermissible dilution of the prohibited waste.
I am aware that there are significant penalties for submitting a false certification, including the possibility of a fine and
imprisonment.
D. • Restricted Waste Decharacterized But Requires Treatment For UHC (40 CFR 268.9)
F 1 certify under penalty of law that the waste has been treated in accordance with the requirements of 40 CFR 268.40 to
remove the hazardous characteristic. This decharacterized waste contains Underlying Hazardous Constituents (UHC)
that require further treatment to meet the universal treatment standards. I am aware that there are significant
penalties for submitting a false certification, including the possibility of a fine and imprisonment.
E. • Restricted Waste Subject To Treatment (40 CFR 268.7(a) (2))
The restricted waste identified above must be treated to the applicable treatment standards in 40 CFR 268.40, or treated to
comply with applicable prohibitions set forth in Part 268.32 or RCRA Section 3004(d). I have attached all supporting analytical
data, where available.
F. • Hazardous Debris Subject To Treatment (40 CFR 268.45)
This hazardous debris identified above must be treated to the alternative treatment standards in 40 CFR 268.45.
G. • Restricted Waste Subject To A Variance or Extension (40 CFR 268.7(a) (4))
This restricted waste identified above is subject to a case by case exemption under 40 CFR 268.5, an exemption under 40 CFR
268.6 or a nationwide capacity variance under Subpart C of 40 C R 268, and is not prohibited from land disposal. LDR
prohibitions become effective on (date) for this restricted waste. The corresponding treatment standard(s) are
promulgated in 40 CFR 268.40.1 have attached all supporting analytical data, where available.
H. • Restricted Waste Managed In A "Lab Pack" (40 CFR 268.7(a) (9))
I certify under penalty of law that I personally have examined and am familiar with the waste and that the lab pack
contains only waste that have been excluded under appendix IV to 40 CFR Part 268 and that this lab pack will be sent to
a combustion facility in compliance with the alternative treatment standards for lab packs at 40 CFR 268.42(c). I am
aware that there are significant penalties for submitting a false certification, including the possibility of a fine and
imprisonment.
I certify and warrant that the information that appears on this form, and appended documents, is true and correct. I
have correctly indicated how my waste is to be managed in accordance with 40 CFR 268. My certification is based on
personal examination of the information submitted, or is based on my inquiries of those individuals responsible for
obtaining the information.
Authorized Signature Title Date
UHC list from 40 CFR Part 268.48 available upon request
EXHIBIT D.2
DOCUMENTATION FOR US ECOLOGY GRAND VIEW FACILITY
Uniform Hazardous Waste Manifest
Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039
UNIFORM HAZARDOUS
WASTE MANIFEST
1. Generator ID Number 2. Page 1 of 3. Emergency Response Phone 4. Manifest Tracking Number
5. Generator's Name and Mailing Address
Generator's Phone:
Generator's Site Address (if different than mailing address)
6. Transporter 1 Company Name US. EPA ID Number
7. Transporter 2 Company Name U.S. EPA ID Number
8. Designated Facility Name and Site Address
Facility's Phone:
U.S. EPA ID Number
9b. U.S. DOT Description (including Proper Shipping Name, Hazard Class, ID Number,
and Packing Group (if any))
10. Containers
No. Type
11. Total
Quantity
12. Unit
Wt.A/ol. 13. Waste Codes
14. Special Handling Instructions and Additional Information
5. GENERATOR'S/OFFEROR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged,
marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations. If export shipment and I am the Primary
Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.
I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true.
Generator's/Offerer's Printed/Typed Name Signature Month Day Year
16. International Shipments • Import to U.S. • Export from U.S.
Transporter signature (for exports only):
Port of entry/exit:
Date leaving U.S.:
17, Transporter Acknowledgment of Receipt of Matenals
Signature Month Day Year Transporter 1 Printed/Typed Name
Signature Month Day Year Transporter 2 Printed/Typed Name
18. Discrepancy
18a. Discrepancy Indication Space ~J Quantity • Fype Residue I I Partial Rejection
Manifest Reference Number:
• Full Rejection
18b. Alternate Facility (or Generator)
Facility's Phone:
U.S. EPA ID Number
18c. Signature of Alternate Facility (or Generator) Month Day Year
19. Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems)
20. Designated Facility Owner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a
Printed/Typed Name Signature Month Day Year
J I I
EPA Form 8700-22 (Rev. 3-05) Previous editions are obsolete. DESIGNATED FACILITY TO DESTINATION STATE (IF REQUIRED)
EXHIBIT E
TYPICAL IX RESIN TECHNICAL DATA
DOWEX 21KXLT & RESINTECH SIR-1200
Product Information
DOWEX 21KXLT
A Uniform Particle Size, High Capacity, Strong Base Anion Exchange Resin for Mineral
Processing Applications
Product Type Matrix Functional group
DOWEX* 21KXLT Type I strong base anion Styrene-DVB, gel Quaternary amine
Guaranteed Sales Specifications
Total exchange capacity, min. eq/L 14
Water content 50-60
Bead size distribution
Volume median diameter
Uniformity coefficient, max.
Lm
%
525-625
1.1
Typical Physical and Chemical Properties
Ionic form as delivered CI-
Total swelling (CI => OH), approx. 18-20
Whole uncracked beads, min. 90
Particle density, approx. g/mL 1.08
Shipping weight, approx. g/L
lbs/ft3
670
42
Recommended
Operating
Conditions
• Maximum operating temperature:
OH- form
CI- form
• pH range
• Bed depth, min.
• Flow rates:
Service/fast rinse
Backwash
Co-current regeneration/displacement rinse
Counter-current regeneration/displacement rinse
• Total rinse requirement
• Regenerant:
Type
Temperature
60°C (140°F)
100°C(212°F)
0-14
800 mm (2.6 ft)
5 - 60 m/h (2 - 24 gpm/ft2)
See figure 1
1 -10 m/h (0.4 - 4 gpm/ft2)
5-20 m/h (2 -8 gpm/ft2)
3 - 6 Bed volumes
NaCI/Carbonate
Ambient orupto50°C(122°F)
for silica removal
Organic loading, max. 3g KMnOVL resin
Page 1 of 2 * Trademark of The Dow Chemical Company
DOWEX Ion Exchange Resins
Form No 177-01893-1005
Typical properties
and applications
DOWEX 21K XLT type 1 strong base anion resin has excellent kinetics, excellent
regeneration efficiency and outstanding physical stability. The uniform sized beads give
maximum performance for all packed bed systems. DOWEX 21K XLT represents the state-
of-the-art in mineral processing resins.
Packaging 5 cubic foot fiber drums
Figure 1. Pressure Drop vs. Flow Rate
For DOWEX 21 Resins, CI, deg. F
21K 16/20
21K 16/30
21K XLT
P c Q in
2D:
5*i
•a
10 20 30 40
Flow (gpm/ft2)
50 60
Figure 2. Backwash Expansion vs. Flow Rate
For DOWEX 21 Resins, CI, deg F
120
100
in —. c c 80 n o
60 .c a. in x to a> 21K XLT 40
21K 16/30 20 21K 16/20
Flow (gpm/ft2)
DOWEX Ion Exchange Resins
For more information about DOWEX
resins, call the Dow Li uid Separations
business.
North America 1-800-4474369
Latin Amenca ([phone]
Europe ([phone]
Pacific [phone]
Japan [phone]
China [phone]
http //www dowex com
Warning Oxidizing agents such as nitnc acid attack organic ion exchange resins under certain conditions This could lead to
anything from slight resin degradation to a violent exothermic reaction (explosion) Before using strong oxidizing agents, consult
sources knowledgeable in handling such materials
Notice No freedom from any patent owned by Seller or others is to be inferred Because use conditions and applicable laws
may differ from one location to another and may change with time, Customer is responsible for determining whether products
and the information in this document are appropriate for Customer's use and for ensuring that Customer's workplace and
disposal practices are in compliance with applicable laws and other governmental enactments Seller assumes no obligation or
liability for the information in this document NO WARRANTIES ARE GIVEN, ALL IMPLIED WARRANTIES OF
MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXPRESSLY EXCLUDED
Page 2 of 2 Trademark of The Dow Chemical Company Form No 177-01893-1005
SIR 1200 SELECTIVE ANION EXCHANGE RESIN
TYPE ONE, CHLORIDE FORM
RESINTECH SIR-1200 is a high capacity, shock resistant, gelular Type One, strongly basic anion resin supplied in the chloride form as moist,
tough, highly uniform, spherical beads. ResinTech SIR-1200 is intended for use in special chemical processing and ionic removal applications.
Other ionic forms are available by special request.
FEATURES & BENEFITS
• HIGHLY UNIFORM PARTICLE SIZE
95% of all beads are in the minus 16 to plus 40 mesh range; giving a LOWER PRESSURE DROP while maintaining SUPERIOR
KINETICS.
• HIGH TOTAL CAPACITY
High total capacity allows greater capacity in applications where high levels of regeneration are used, or in one-time use
applications such as precious metal recovery and ionic removal.
• SUPERIOR PHYSICAL STABILITY
Over 93% sphericity combined with high crush strengths and highly uniform particle size provide greater resistance to bead
breakage due to mechanical, thermal or osmotic stresses.
HYDRAULIC PROPERTIES
Pressure Drop
v> 1
0 5 10 15 20 25 30
Flow Rate, gpm/sq.ft.
PRESSURE DROP
120
100
I »0
2
re
§ 60
CD
S 40 a>
a.
20
BACKWASH
Backwash Expansion
3>
0.0 1.0 2.0 3.0
Flow Rate, gpm/sq.ft.
4.0
The graph above shows the expected pressure loss per foot of bed After each cycle the resin bed should be backwashed at a rate that
depth as a function of flow rate at various water temperatures. expands the bed 50 to 75 percent. This will remove any
foreign matter or fines and reclassify the bed.
1 Resintech Plaza • 160 Cooper Road • West Berlin.NJ 08091 • Phone:[phone] • Fax:[phone] • E-mail:[e-mail] • Web Site:www.resintech.com
RESINTECH® SIR-1200
TYPICAL PROPERTIES OPERATING CAPACITY
Polymer Structure
Functional Group
Ionic Form, as shipped
Physical Form
Screen Size Distribution
+16 mesh
-40 mesh
pH Range
Sphericity
Uniformity Coefficient
Water Retention
CI Form
Solubility
Approximate Shipping Weight
CI Form
Total Capacity
CI Form
Styrene Crosslinked with DVB
R-N- (CH3)3
+X-
Chloride
Tough, Spherical Beads
16-45 Nominal
<2 Percent
<2 Percent
Oto 14
90+ Percent min.
Approx. 1.5
43 to 47 Percent
Insoluble
44 lbs cu. ft.
1.40 meq / mL min
SUGGESTED OPERATING CONDITIONS
Maximum Temperature
Salt form
Minimum Bed Depth
Backwash Rate
Regenerant Concentration*
Regenerant Flow Rate
Regenerant Contact Time
Regenerant Level
Displacement Rinse Rate
Displacement Rinse Volume
Fast Rinse Volume
Service Flow Rate
Fast Rinse Rate
170°F (75°C)
24 inches
50 to 75 % Bed Expansion
2 to 6 %
0.25-1.0 gpm / cu.ft.
At least 60 Minutes
4 to 10 lbs /cu.ft.
Same as Regenerant Flow
10 to 15 gal/cu.ft.
35-60 gal./cu.ft.
2-4 gpm / cu.ft.
Same as Service Flow Rate
The operating capacity of RESINTECH SIR-1200 for acid removal at
various regeneration levels when treating an influent with a con-
centration of 500 ppm, as CaC03, is shown in the following table.
Pounds
NaOH/ft3
10
Capacity Kilograms per cubic foot
HCI H2SO4 H2Si03 H2C03
11.3
12.8
14.3
15.5
14.0
16.3
13.3
20.0
14.7
17.3
19.5
22.2
18.6
19.8
21.6
22.2
APPLICATIONS
RESINTECH SIR-1200's high total capacity make it ideal for applica-
tions such as precious metal recovery, radwaste disposal and purifi-
cation of toxic waste streams. Its lower porosity also provides an
increased resistance to osmotic and physical shock.
RESINTECH SIR-1200's high total capacity and low swelling on re-gen-
eration provides maximum operating capacity in cartridge deionization
applications for all applications from ultra pure water to waste treat-
ment and precious metal recoveries.
"CAUTION.'DO NOT MIX ION EXCHANGE RESIN WITH STRONG OXIDIZING AGENTS. Nitric acid and other strong oxidizing agents can cause explosive reactions when mixed with organic
materials.such as ion exchange resins.
Material Safety Data Sheets (MSDS) are available for all ResinTech Inc.products.To obtain a copy.contact your local ResinTech sales representative or our corporate headquarters.
They contain important health and safety information.That information may be needed to protect your employees and customers from any known health and safety hazards associated with
our products.We recommend that you secure and study the pertinent MSDS for our products and any other products being used These suggestions and data are based on information we
believe to be reliable.They are offered in good faith.However we do not make any guarantee or warranty. We caution against using these products in an unsafe manner or in violation of any
patents;further we assume no liability for the consequences of any such actions.
RESINTECH is a registered trademark® of RESINTECH INC. SIR-1200062405