DRC-2013-004487 - 0901a06880416f22

Response Document
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing -Cross Examination Questions
October 9, 2013 (2PM to 5PM)
DRC-2013-004487
The following questions are submitted by Sarah Fields, on behalf of Uranium
Watch in anticipation of a hearing before a Presiding Officer in Salt Lake City, Utah,
on October 9, 2013.
APPLICATION
1. The April 2011 Application states that the Midnite Mine materials are going to be
processed as "ore."
1.1. Are these materials "ore," as contemplated by the Atomic Energy Act of 1946, as
subsequently amended by the AEA of 1954 and the Uranium Mill Tailings Radiation
Control Act of 1978? If so, what is the basis for the DRC's determination?
Response:
The terms "alternate feed material" and "ore" are not defined in the Commission's regulations:
however, the NRC guidance document, Regulatory Information Summary (RIS) 2000-23, "Recent
Changes to Uranium Recovery Policy" (web address:
http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2000/ri0
0023.html) defines these terms in the context of the NRC's uranium recovery program. RIS 2000-
23 defines "alternate feed material" as "material other than natural ore," while "ore" is defined as
"any natural or native matter that may be mined and treated for the extraction of any of its
constituents or any other matter from which source material is extracted in a licensed uranium or
thorium mill." The Commission adopted the staffs definition of "ore" in CLI-03-15 (11/13/03)
which was issued in response to the application of the Sequoyah Fuels Corporation for a materials
license amendment.
On page four of Utah's revised program description for the final application submitted by letter
dated July 18, 2003, Utah provides information indicating that it intends to follow the NRC
guidance in RIS 2000-23 for review of and making a decision on requests for receipt of alternate
feed materials by uranium mills. Utah stated that it will treat each application for alternate feed
material as a major amendment and will follow the licensing procedures described in the Utah
application. Utah's program is consistent with the NRC's program fSee letter dated January 15,
2004 from Paul H. Lohaus, Director, Office of State and Tribal Programs, to Sarah Fields
responding to a letter dated November 4, 2003 regarding Utah's Final Application for their
amended agreement for 1 le.(2) byproduct material).
'The term "unrefined and unprocessed ore" is defined at 10 CFR 40.3 as "ore in its
natural form prior to any processing, such as grinding, roasting or beneficiating, or refining."
While this definition addresses unrefined/unprocessed ore, it does not distinguish between such
ore and alternate feed material.
In the same referenced letter above, you asked; "Where is the descriptive "alternate feed materials"
or "processing of alternate feed materials" found in the Atomic Energy Act of 1954, as amended,
or any other statute implemented by the NRC staff?"
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing -Cross Examination Questions October 9, 2013
The NRC provided a response stating: "The Uranium Mill Tailings Radiation Control Act of 1978
(UMTRCA) amended the Atomic Energy Act of 1954 (Act) by adding and defining thc term
"lle.(2) byproduct material" as "the tailings or wastes produced by the extraction or concentration
of uranium or thorium from any ore processed primarily for its source material content." (emphasis
added). The terms "ore" or "any ore" are not defined in UMTRCA or the Act. As stated in our
response to Question 1 above, the Commission has adopted the staffs definition of "ore" which
includes "alternate feed material" at licensed uranium mills.
1.2. Is EFRI required to submit a request for a license amendment to process ore from a
new source of uranium ore from a mine owned by EFRI or any other mine owner?
Response:
No, conventional ores do not require a license amendment.
1.3. Why has EFRI submitted an Application for a license amendment to process the
Uranium Material from the Midnite Uranium Mine?
Response:
Alternate feed requests must be approved by the Director of the Utah Division of Radiation
Control as specified by License Condition (See RML UT1900479, License Condition 10.1C).
REGULATORY PROGRAMS
Item 2 through 8
Response
Legal questions and are outside the scope of this licensing action.
ALTERNATE FEED PROCESSING AND DISPOSAL
9. Questions regarding the receipt, storage, processing, and disposal of alternate feed?
9.1. How does the DRC monitor the shipments of "alternate feed" that are received at the
White Mesa Mill?
Response:
On-site inspections performed by DRC inspectors. If a shipment arrives when the inspector is on
site, they normally review the shipping papers and observe the condition of shipment at arrival.
9.2. How does the DRC determine the amount of alternate feed that is being or
has been received at the White Mesa Mill from any one source?
Response:
The license amendment for alternate feed from Dawn Mining identifies in the license condition the
amount they can receive and DRC will inspect against that quantity during future inspections.
However, for purposes of informing the public, the DRC reviews annual processing information
from the licensee regarding conventional ore and alternate feed material. The DRC is working
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing -Cross Examination Questions October 9, 2013
with the Licensee during the current License Renewal Application under review to provide
quantities for previously approved alternate feed material for inclusion in each specific license
condition regarding alternate feeds that are still being received at the facility.
\ 9.3. How does the DRC determine whether the amount of material received and
processed at the Mill from a specific alternate feed source is less than or equal to the
amount of material that was approved for receipt and processing at the Mill from that
source?
Response:
For the Dawn Mining alternate feed request, the total amount is identified in the proposed License
Condition (L.C. 10.20) and DRC will inspect against this quantity during future inspections. In
addition, see response to item 9.2 above.
9.4. How does the DRC determine that the material received at the Mill has the
same physical and chemical characteristics as the material that was approved by the
NRC or the DRC for receipt and processing? What type of verification is required? What
kind of sampling of the material is required?
Response:
Materials received at the mill are subject to sampling by the DRC or the DRC can request the
licensee collect samples and send them off for analysis. If samples are collected by the DRC, they
would consist of a grab sample(s) of the material on the ore storage pad, and analyzed for
radiologics, RCRA constituents, metals and volatile organic compounds (VOCs).
9.5. What information is received by the DRC regarding 1) the amount of waste
from the processing of alternate feed from each source of material and 2) the physical
and chemical characteristics of the waste.
Response:
The License Application request contains the physical, radiological and chemical characteristics of
the waste. The DRC receives on an annual basis the amount of conventional ore and alternate feeds
that were processed during the calendar year. This information is provided to the public in the
State of Utah Environmental Report. Please note, the information in the State's Environmental
Report does not distinguish each source of material. It only lists collectively conventional ore's
and alternate feed's.
9.6. Does the DRC have data on the cumulative amount of radiological and chemical
constituents in the tailings as a result of the disposal of wastes from the processing of
alternate feed? If so, where is this information available?
Response:
Yes, the groundwater permit (Part I.E. 10) Tailings Cell Wastewater Quality Monitoring - on an
annual basis, the Permittee shall collect wastewater quality samples from each wastewater source
at each tailings cell at the facility. This information provides concentration ranges for constituents
in the cell and is maintained in the DRC office.
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing -Cross Examination Questions October 9, 2013
9.7. Does the licensee keep track of where the tailings from the processing of
alternate feed material are disposed of.
Response:
In general terms yes, the Licensee knows which tailing cell is receiving tails, therefore, when
processing material the Licensee would know which cell is receiving the byproduct materials.
SAFETY EVALUATION REPORT
10. The SER, Section 1.5 (page 6). provides items that will be evaluated in the SER, in
accordance with Utah Code Annotated (UCA) R313-22-38 and R313-24-3. The SER
appears to limit the environmental analysis to the four listed items. The listed items
reflect, in part, the requirements for an environmental analysis for an Agreement State
11e.(2) byproduct material licensing action (42 U.S.C. § 2021(o)(3)(C)). However,
Section 2021(o)(3)(C) states that the environmental analysis shall include those four
items, it does not state that the environmental analysis should be limited to those items.
10.1. Does the DRC believe that the required environmental analysis should be
limited to the four items listed in the SER? If so, why? If not, what other environmental
analyses should be undertaken?
Response:
The SER provides an environmental analysis regarding the amendment request. Determination on
what environmental analysis should be undertaken is based on the specific amendment request that
is submitted by the Licensee. For alternate feed material the four items listed is a starting point.
The SER has considered and evaluated the four items listed in 42 U.S.C. § 2021(o)(3)(C)) in the
environmental impacts analysis and considers these items to constitute a sufficiently
comprehensive framework for evaluating potential environmental impacts resulting from the
proposed action. The DRC believes the list of items to be consistent with all available applicable
NRC guidance, State of Utah requirements, and applicable environmental impacts assessment
protocols. These considerations notwithstanding, the DRC's evaluation included other additional
items such as:
• Evaluating the ability of current mill operational and radiological protection practices to
safely accommodate the temporary storage, and processing of the alternative feed material,
and disposal of the process residuals in the designated tailings cells without increasing
potential impacts to the environment, and/or increasing potential exposure to workers or the
public; and
• Assessing the need for implementing additional protective measures, if any, to mitigate
against such potential increased environmental impacts/exposures.
11. The SER at Table 1 (page 8) provides information regarding the Range of
Radionuclide Concentrations in the DMC Uranium Material. The amounts for Uranium are
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
given in milligrams per kilogram (mg/kg); the amounts for thorium-228, thorium-230,
thorium-232, lead- 210, radium total, and radium-226 are given in pico Curies per gram
(pCi/g).
11.1. Why does Table 1 provide the uranium concentrations in mg/kg and the
other radionuclides in pCi/g?
Response:
These concentration units are typically used in the scientific community regarding these various
radionuclides (termed: conventional units). Uranium concentration is in mass units and other
radionuclides are based on radioactivity. Specifically, the uranium concentration units shown in
Table 1 are identical to those reported by the licensee in the License Amendment Request (the
units reported in the laboratory analyses).
11.2. It is our understanding that, if the thorium decay chain is in equilibrium, the amount
of Thorium-228 would be about the same as the thorium-232.
Why is the maximum amount of thorium-232 14.27 times higher than the maximum
thorium-228, where for the minimum levels of thorium-32 and thorium-2, the activity of
thorium-228 is .41 times that of thorium-232?
Response:
The DRC assumes that the question is in error and that it should read as follows:
It is our understanding that, if the thorium decay chain is in equilibrium, the amount of Thorium-
228 would be about the same as the thorium-232. Why is the maximum amount of thorium-232
1.31 times higher than the maximum thorium-228, where for the minimum levels of thorium-232
and thorium-228, the activity of thorium-228 is 0.82 times that of thorium-232?
The above ratios (calculated using the data presented in Table 2 of the SER) suggest approximate
equilibrium conditions for Th-232 and Th-228 concentrations in the DMC Uranium Material with
respect to the thorium decay series.
11.3. Table 1 includes lead-210, the product of uranium-238 decay. Why does Table 1 not
include lead-208, the end of the thorium decay chain?
Response:
Pb-208 concentrations in the DMC Uranium Material are not considered. Pb-208 is a stable
isotope of lead and is therefore not appropriate for reporting in this table. Analytical results for
total lead are reported elsewhere in the SER (e.g., Table 11).
11.4. Table 1 fails to include the radon emissions from the Uranium Material.
Why is that?
Response:
Information on radon emissions from the Uranium Material is not considered. The primary
radionuclide parents for radon generation (assuming radon refers to Radon 222) are Th-230 and
Ra-226. Concentrations of these radionuclide parents in the DMC Uranium Material are within
(below) the range of concentrations of thee radionuclides in typical Colorado Plateau ores (e.g., see
Table 2 of the SER). For this reason, previous environmental analyses completed for the
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processing of uranium ores at the mill are bounding (e.g., NRC 1979) for estimating radon
emissions from processing of the DMC Uranium Material.
t 11.5. Why does the SER fail to identify the other radium isotopes that are
included in "Total Radium."
Response:
Analytical testing of four samples of filter press cake produced from the dewatering filter press
pilot testing (testing conducted between September 16 through 23, 2011) included analysis for the
following radionuclide isotopes of radium: Radium-226 and Radium-228. Analytical results,
reported in Table 6 of the SER, indicates that radium-226 concentrations in the samples were low,
ranging from 0.07 to 0.2 pCi/g, and radium^S concentrations were also low (all reported
concentrations werebelow <0.2 pCi/g. r ^W&2C^ ^
Prior testing of centrifuge dewatered sludge from the DMC treatment system (2010) indicated the
following range of Radium-226 and Total Radium concentrations:
Radioisotope Range of Concentrations/Average
Concentration
Ra-226 22.8-25.7 pCi/g (Ave. 24.1 pCi/g
Total Radium 36.6-41 pCi/g (Ave. 39.1 pCi/g) ^ r$
The total radium and radium isotopic concentrations reported above for the DMC Uranium
Material are within (well below) the range of total radium and radium isotopic concentrations for
Colorado Plateau-type uranium ores typically processed at the Mill. For this reason, previous
environmental analyses completed for the processing of uranium ores at the mill are bounding
(e.g., NRC 1979) for estimating potential environmental impacts from radium in the DMC
Uranium Material. v , «. v ,
11.6. Has the DRC evaluated and compared the radionuclides that will remain in
the Uranium Material and other alternate feeds after processing?
Response:
Radionuclide constituents present in the DMC Uranium Material after processing (e.g, radium-
226; thorium-230; thorium-228; thorium -232; uranium) are expected to be the same as those
present in material resulting from processing of uranium ores. Concentrations of most of these
radionuclides in the DMC Uranium Material after processing are expected to be lower than those
in material resulting from processing of typical Colorado Plateau-type uranium ores, the possible
exception of uranium. However, as described in Section of the SER, the average U-nat content of
the DMC Uranium Material (1.5%) prior to processing is comparable to the range of U308
concentrations in ores mined at the Arizona 1 uranium mine in the Arizona Strip between 2010 and
2012, which averaged between approximately 0.56% and 0.66%, and is lower (SER, Table 4) than
the maximum U308 concentrations observed in ores mined during each of these three years (2.0 %
U308 [1.7% U-nat] to 2.8 % U308.
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
Radionuclide inventories in material resulting from processing of other alternate feed materials at
the mill are evaluated in other Safety Evaluation Reports prepared for other alternate feed material
license amendment requests or in Technical Evaluation Reports or other documents previously
prepared issued by the NRC.
12. Table 3 provides information regarding the Concentrations of Total Uranium,
Radium 226 and Thorium-230 in the Uranium Material vs. Average Acid Leached Ore-
Derived Uranium Mill Tailings in Utah.
12.1. Table 3 only considers radium-226, but does not include the radium concentrations
from the decay of thorium (radium-228 and radium-224). Shouldn't Table
3 also include the radium concentrations form radium-228 and radium-224 and the total
concentrations from all radium isotopes in the comparison of the Uranium Material and
"Typical Utah Uranium Mill Tailings"?
Response:
See Response to Review Comment No. 11.5 above.
12.2. Table 3 contains a comparison between the Uranium Material Constituents
and "Average Acid Leached Ore-Derived Uranium Mill Tailings in Utah." Why has the
DRC not included a comparison of the thorium-232 and thorium-228 concentrations for
the Uranium Material and the Average Acid Leach Ore in Utah?
Response:
Information in NCRP 1993 and Cardarelli (undated) indicates that Th-232 concentrations in
natural uranium ores vary with geographic location and typically range from approximately 8 to 80
Bq/kg. Using a conversion factor of 0.027 pCi/g per Bq/kg, this range is approximately equivalent
to 0.2 to 2.2 pCi/g of Th-232 for typical uranium ores. Since most uranium ores can be
considered to be in approximate secular equilibrium, uranium ores would be expected to exhibit a
similar range of concentrations of Th-228. This range of Th-232 and Th-228 concentrations in
typical uranium ores is comparable to that reported for the DMC Uranium Material (SER, Tables 1
and 2). For this reason, previous environmental analyses completed for the processing of uranium
ores at the mill are bounding (e.g., NRC 1979) with respect to Th-232 and Th-228 concentrations
in the DMC Uranium Material.
13. Table 5 is a Comparison of Radionuclide Activity Concentrations in Proposed
Uranium Material and Previous Alternate Feeds. Table 5 Summarizes the concentrations
of the Uranium Material as compared with Colorado Plateau Ores and Alternate Feed
Material. Table 5 relies to a great extent on the information in the W. R. Grace
Application. That application was submitted to the NRC in April 2000—over 13 years ago.
13.1. Has the DRC reviewed the W. R. Grace Application of April 2000 and the license
amendment approval documents? If so, when did the DRC review that application and
approval documents?
Response:
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
No, the DRC has not reviewed the Grace Application of April 2000.
13.2. Did the NRC conduct an environmental analysis of the receipt, processing, and
disposal of the W. R. Grace Material?
Response:
The NRC conducted an environmental analysis as documented in the December 20, 2000
Technical Evaluation Report (TER) which accompanied License Amendment 17. The TER refers
to the following environmental and technical information submitted by IUSA during the evaluation
process:
April 12, 2000 WR Grace Alternate Feed amendment request
April 24, 2000 IUSA letter transmitting RMPR
April 26, 2000 IUSA response letter regarding thorium mgmt. in tailings
May 5, 2000 IUSA response letter regarding tailings capacity
December 18, 2000 IUSA submittal of thorium management SOP, receipt through disposal
13.3. Has any of the W. R. Grace material been received at the White Mesa Mill for
processing?
Response:
To the DRC's knowledge, the answer is no.
13.4. Has the DRC received any documentation from EFRI or the generator and/ or
regulator of the W.R. Grace facility regarding when, or if, the W. R. Grace Material would
ever be shipped to the White Mesa Mill?
Response:
Based on information provided to the DRC during the 2007 License Renewal Application review,
the DRC is removing License Condition 10.1?
13.5. Has the DRC reviewed the applications and approvals for the license amendments
and license conditions associated with the processing of alternate feed? If so, which
applications and approvals has the DRC reviewed and when did these reviews take
place?
Response:
As described in License Condition 10.19, the DRC reviewed and authorized the Licensee to
receive and process source material from Ponds 2 and 3 of the FMRI's Muskogee Facility located
in Muskogee, Oklahoma, in accordance with statements, representations, and commitments
contained in the amendment requests and submittals to the Executive Secretary dated March 7,
2005, June 22, 2005, and April 28, 2006. [Applicable UDRC Amendment: 2 Signed June 13, 2006]
In addition, the Dawn Mining Amendment Request dated April 27, 2011, and associated
documents provided at the following web page:
http://www.radiationcontrol.utah.gov/Uranium_Mills/IUC/DenisonJUC/dawn_mining.html
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The approval is subject to the public comment period which is currently underway and closes
October 21, 2013. "
Lastly, the DRC is currently reviewing (using an outside contractor) another alternate feed request
to receive and process material from Sequoyah Fuels Corporation Inc., (SFC) which was received
back in December, 2011. See the following web page for more information:
http://www.radiationcontrol.utah.gov/TJranium_Mills/IUC/Denison_IUC/seq
13.6. What is the justification for comparing the Uranium Material with materials that have
not, and might not, ever be processed at the White Mesa Mill?
Response:
Whether or not alternate feed materials are received and processed at the White Mesa Mill, the
environmental analysis was performed and was approved by the regulatory agency. Comparing
alternate feeds allows staff to evaluate materials previously approved. This helps determine the
scope or "envelope" in which this material can be managed.
14. Other Questions regarding the SER.
14.1. The SER (page 12) indicates the thorium-232 specific activity. However, the total
thorium activity (for the thorium decay chain) is usually the sum of the thorium-232 and
thorium-228 activity. Why did the DRC not include the thorium-228 activity?
Response:
See Response to Reviewer Comment No. 12.2 above.
14.2. What is the amount and activity of alternate feed materials containing thorium-232
and its decay products from material that have actually been processed at White Mesa?
Response:
The SER prepared to support the DMC Uranium Material Alternate Feed Material License
Amendment Request evaluated and compared the range of thorium -232 concentrations in the
DMC Uranium Material to the range of thorium-232 concentrations in uranium ores that have been
processed at the mill. Evaluations of thorium-232 concentrations and concentrations of Th-232
progeny in other alternate feed materials processed at the mill are contained in other Safety
Evaluation Reports prepared for other alternate feed material license amendment requests or in
Technical Evaluation Reports, Environmental Assessments, or other documents previously
prepared by the NRC. jj .
14.3. Has the DRC reviewed the White Mesa Mill's Standard Operating Procedures for
High Thorium Content Ore Management? Has the DRC determined whether the Uranium
Material will trigger the use of this SOP? If not, why not?
Response:
The "High Thorium Content Ore Management SOP" referenced by the commenter is not
applicable for the DMC Uranium Material since the concentrations of thorium isotopes in the
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DMC Uranium Material are within (lower than) the range of thorium isotopic concentrations
present in ores processed at the mill.
14.4. The SER (page 12) states: "Demonstration that the uranium, radium, and thorium
activity concentrations of the Uranium Material are below the maximum range of
previously approved conventional ores and alternate feed materials indicates that radon
levels resulting from the processing of the Uranium Material are expected to be within the
range for which the existing approved controls and monitoring programs are currently
established and considered appropriate."
Did the DRC also evaluate the range of materials that have actually been processed at
the mill, not just the previously approved alternate feed?
Response:
Evaluations of radionuclide inventories in other materials alternate feed materials processed at the
mill are contained in other Safety Evaluation Reports prepared for other alternate feed material
license amendment requests or in Technical Evaluation Reports, Environmental Assessments, or
other documents previously prepared issued by the NRC. The ranges of concentrations of
radionuclides in various ores processed at the mill were evaluated in previous environmental
analyses completed for the processing of uranium ores at the mill are bounding (e.g., EIS 1979).
14.5. The DRC refers to approved "conventional ores." Does the DRC approve
"conventional ores" for processing at the mill?
Response:
No, as stated in response to question 1.2, the DRC does not approve conventional ores. This
statement was incorrect.
14.6. The UCA and the Atomic Energy Act require the assessment of the radiological
impacts to the public health from the processing of the Uranium Material. However, I am
unable to find such an assessment. There is no discussion of how, exactly, the processed
material will be regulated under the applicable regulations, or now, exactly, the radon and
other radionuclides will be controlled over the life and long-term care of processed
Uranium Material. There is no discussion of the health risks from the radon and other
radionuclides associated with the transportation, storage, loading, processing, disposal,
and perpetual care of the Uranium Material and its processing wastes.
Where, exactly, in the SER does the DRC assess the radiological impacts to the public
health from the transportation, storage, loading, processing, disposal, and perpetual care
of the Uranium Material and its processing wastes?
Response:
The SER assess the impacts in section 4.0 of the document. The ranges of concentrations of
radionuclides in various ores processed at the mill were evaluated in previous environmental
analyses completed for the processing of uranium ores at the mill are bounding (e.g., EIS 1979).
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14.7. The SER at Table 7 (page 13) provides information regarding Derived Air
Concentrations (DRCs) from Ores and Selected Alternate feed. Table 7 does not explain
what, exactly, the numbers in the table actually measure. Table 7 includes columns
identified as UF4, KF, Regen Material, and Calcined Material, but does not indicate the
source or nature of those materials.
Please explain what DAC means and what the numbers in Table 7 measure.
Response:
As defined in R313-15 Definitions; "Derived air concentration" (DAC) means the concentration of
a given radionuclide in air which, if breathed by the reference man for a working year of 2,000
hours under conditions of light work, results in an intake of one Annual Limit of Intake (ALI). For
purposes of these rules, the condition of light work is an inhalation rate of 1.2 cubic meters of air
per hour for 2,000 hours in a year. DAC values are given in Table I, Column 3, of Appendix B of
10 CFR 20.1001 to 20.2402, (2010), which is incorporated by reference."
DAC values are derived limits intended to control chronic occupational exposures and are used in
analyses of airborne particulate exposure to workers. Table 7 presents DAC values for
radionuclides developed for the DMC Uranium Material, based on applicable regulations and Mill
procedures, and that take into account the specific radionuclide make-up of the DMC Uranium
Material. The unit for the DAC values listed in Table 7 is uCi/ml.
14.8. What is the source and nature of the UF4, KF, Regen Material, and
Calcined Material? How much of each of these materials has been processed at the Mill?
Response:
UF4 and KF are natural uranium-bearing residuals from Cameco Corporation's Port Hope Facility,
and Regen Material and Calcined Material are natural uranium-bearing residuals from Cameco's
Blind River Conversion Facility. The four materials were approved by NRC for processing as
alternate feeds at the Mill under Amendment 9 to Source Material License SUA -1358.
The Mill has processed the following approximate quantities of each of these alternate feeds from
1999 to the present:
Alternate Feed Tons
UFz 914
KF 5,646
Regen Material 535
Calcined Material 16,934
Please identify the date of the application(s), license amendment(s), and environmental
analysis or analyses associated with the processing and disposal of the UF4, KF, Regen
Material, and Calcined Material.
Response:
IUSA submitted a license amendment application on June 4, 1998. The NRC conducted an
environmental analysis as documented in the November 2, 1998 Technical Evaluation Report
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which accompanied License Amendment 9. The TER refers to the following environmental and
technical information submitted by IUSA during the evaluation process:
June 4, 1998 Cameco Alternate Feed amendment request
September 14, 1998 IUSA letter transmitting additional chemical characterization,
MSDSs, and process histories
September 16, 1998 IUSA Fax
September 25, 1998 IUSA letter submitting Cameco affidavit regarding RCRA listed
waste
October 7, 1998 IUSA letter describing incinerator ash
October 8, 1998 IUSA letter response to two additional comments on chemical
composition
NRC issued License Amendment 9 on November 2, 1998.
14.9. The SER (page 14) states that the Concentrations of thorium-232 and its
decay products are negligible and its decay products are negligible and can be ignored.
What are the concentrations of thorium-232 and its decay products from the
Uranium Material and other feed material processed at the Mill? Compare the half-lives
and health impacts of the decay products of uranium with those of thorium decay
products. What is the basis for discounting the health risks from thorium-232 and its
decay products?
Response:
The SER prepared to support the DMC Uranium Material Alternate Feed Material License
Amendment Request evaluated and compared the range of thorium -232 concentrations in the
DMC Uranium Material to the range of thorium-232 concentrations in uranium ores that have been
processed at the mill. The ranges of concentrations of radionuclides in various ores processed at
the mill were evaluated in previous environmental analyses completed for the processing of
uranium ores at the mill are bounding (e.g., EIS 1979).
14.10. The SER (page 15) provides information re the external radiation standards for
transportation of the material and provides a standard of 200 mrem/hr at any point on the
outer surface of the vehicle.
How long would it take for a person next to a vehicle carrying radioactive materia! receive
the maximum dose of 100 mrem per year for off-site exposure from a uranium mill?
Response:
Certain assumptions would have to be made regarding the phrase "next to a vehicle carrying
radioactive material receive the maximum dose of 100 mrem per year. First the standard, 200
mrem/hr at any one point, is a limit, not necessarily what the external radiation level will be on the
outer surface of the vehicle. This limit is set by the Dept. of Transportation (DOT). For simplicity,
assuming the contents do generate external radiation on the surface of the vehicle, it would be 30
minutes or half an hour, if the individual was in contact with the outer surface of the vehicle.
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14.11. Were the White Mesa Tailings Cells 4A and 4B designed contemplating the
disposal and perpetual storage of wastes from the processing of material other than
natural ores? If so, please identify the specific design elements in Cells 4A and 4B that
were developed in anticipation of the disposal of wastes from the processing of materials
other than natural ores from the Colorado Plateau?
Response:
Each amendment request submitted to DRC includes an analysis of the compatibility of the
proposed alternate feed with the tailings system. The analysis considers the currently known
chemical composition of the tailings, which reflects the presence of residuals from previous
alternate feeds, and compares that composition to the proposed alternate feed. The design of the
tailing cells is compatible with the radiological and chemical constituents of the Uranium Material.
The evaluations to date on have not identified any potential chemical reactions in the tailings
system.
14.12. Please identify and describe the specific design elements for the construction of
Cells 4A and 4B that would anticipate the disposal of the radiological and chemical
constituents found in the Uranium Material?
Response:
Not relevant to the Amendment request. Design elements anticipate and have been selected based
on constituents in tailings waste fluids from the conventional mill at White Mesa Mill.
14.13. How long after closure of the Cells 4A and 4B will it take to remove free standing
liquids from the Cells, such that the liquids will not longer provide a source of leakage
from the tailings impoundments into the surrounding soils and ground water?
Response:
This question is outside the scope of the amendment request.
14.14. Which radiological and chemical constituents present in the Uranium Material have
been found in excess of ground water standards in the monitoring wells at the White
Mesa Mill?
Response:
The Mill's quarterly groundwater monitoring reports, available on the DRC website, contain a
tabulation of every analyte in any groundwater monitoring well that has exceeded its respective
GWCL for that monitoring period. Many of these analytes are found in natural background
groundwater, as well as in natural ores, and in the Uranium Material.
14.15. Has the DRC reviewed the amount and nature of contaminants in the previously
approved alternate feeds to determine whether Ground Water Discharge Permit would
need to be revised in order to detect the constituents in the alternate feed that are not
found in Colorado Plateau ores?
Response:
This question is outside the scope of this amendment request. However, to answer the questions,
yes, the DRC as part of its review of Fansteel alternate feed request.
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing -Cross Examination Questions October 9, 2013
14.16. Has the DRC determined the chemical compatibility of the contaminants in the
previously approved alternate feeds to determine the types of chemical reactions that
would occur in the tailing cells as a result of disposing of the contaminants in the tailings
impoundments?
Response:
Each amendment request submitted to DRC includes an analysis of the compatibility of the
proposed alternate feed with the tailings system. The analysis considers the currently known
chemical composition of the tailings, which reflects the presence of residuals from previous
alternate feeds, and compares that composition to the proposed alternate feed. The evaluations to
date on have not identified any potential chemical reactions in the tailings system.
14.17. The SER states repeatedly that the radiological and chemical constituents in the
Uranium Material are similar to ores and alternate feed materials previously processed at
the Mill. However, the SER often compares the constituents with those in alternate
approved for processing, but not necessarily processed at the Mill. Why does the SER not
limit its similarity analysis to feed materials that have actually been processed at White
Mesa? What differences in constituent analyses would be apparent if only processed
materials were considered?
Response:
These materials are well inside the envelope of previous environmental analysis (e.g., EIS 1979)
14.18. The SER refers to Occupational Safety and Health Administration regulations.
Which OSHA regulations are applicable to the White Mesa Mill and how are those
regulations enforced?
Response:
The reference to OSHA in the SER is in error. The Mill is subject to regulation and enforcement
by the Mine Safety and Health Administration ("MSHA") as a result of a tripartite agreement
between US NRC, MSHA and OSHA. MSHA conducts inspections at least semiannually at the
Mill. The content and status of all MSHA citations for the previous license performance period
have been provided to DRC (and formerly to NRC) with each license renewal application.
15. The SER discusses Long Term Impacts and concludes that the DRC "does not
anticipate any significant impacts on the reclamation, decommissioning, and
decontamination of the White Mesa facility, if the Uranium Material is processed as an
alternate feed." Currently White Mesa Mill Cell 2 was not in compliance with the
emissions limits in 40 C.F.R. Part 61 Subpart W, § 61.252(a), of 20 pico Curies per meter
squared for the calendar year 2012. Cell 2 no longer receives tailings, has an interim soil
cover, and is undergoing a process of dewatering. As a result of the non-compliance
EFRI is submitting monthly Subpart W compliance reports to the EPA and the Utah
Division of Air Quality, which administers and enforces Subpart W. The July 2013 Monthly
Radon Flux Monitoring Report for Cell 2 included an evaluation of possible causes of the
increases in radon flux from the impoundment. See Exhibit A. The July 2013 Report
states: "EFRI has identified the areas of elevated radon flux associated with known
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
sources of radiological contamination at or near the surface of the cell cover." EFRI found
that there were three specific locations associated with increase in radon emissions: 1)
the location associated with the former tailings discharge line, 2) the perimeter area near
the north of Cell 2 containing disturbed or windblown material, and 3) the location of
specific alternate feed tailings disposal with elevated radionuclide content.
This means that materials from the tailings have migrated off the pile and that the wastes
from the disposal wastes from the processing of alternate feed have elevated radionuclide
contents.
15.1. Has the DRC taken into consideration the fact that elevated levels of radionuclides
have been associated with the disposal of waste from the processing of alternate feed
material in a White Mesa tailings impoundment?
Response:
The DRC is aware of the U.S. Geological Survey published a report of an assessment of potential
migration of radionuclides and trace elements from the White Mesa Uranium Mill to the
surrounding areas. The DRC preliminary review findings were shared with the public in a July 9,
2012 meeting in Blanding. Current actions are being taken as part of the License Renewal
Application review.
15.2. Has the DRC taken into consideration the fact of the dispersal of materials from the
tailings impoundments by wind and other natural forces?
Response:
Yes, the SER considers factors that disperse materials from tailings impoundments.. The
materials settle out creating a buildup of solid materials from the base of the cell upward. Solution
levels in the cells vary depending on the operating schedule of the Mill and seasonal evaporation
rates (Cell 4A and Cell 4B BAT Operations, Monitoring and Maintenance Plan, July 2011). All
tailings cells, including Cells 4A and 4B, are operated and maintained to achieve Discharge
Minimization Technology and Best Available Technology Standards identified in the Ground
Water Discharge Permit.
All operational features in the tailings cells area are inspected daily for conditions of potential
concern, in accordance with the requirements listed in the most current version of the White Mesa
Mill Tailings Management Systems and Discharge Minimization Technology (DMT) Monitoring
Plan (e.g., see DUSA 2007). Estimates of tailings beach surface area and solutions pool area are
made, evidence of wind movement of tailings during these inspections is observed and
documented, and conditions which may require initiation of preventative dust minimization
measures are identified.
15.3. What are the radiological constituents that will be disposed of in the tailings
impoundment from the processing of the Uranium Material that are different from the
radiological constituents that would be disposed of from the processing of the Colorado
Plateau ores at the Mill?
Response:
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
None, Radium, Thorium, and a little bit of Uranium, along with Uranium series daughter products
will be the main constituents that are going to the tailings cells. As described in the SER, page 18,
every metal, non-metal cation and anion component in the Uranium Material already exists in the
the mill tailings system and/ or is analyzed under the Mills' Groundwater monitoring program.
15.4. Do the EIS and Environmental Assessments (EAs) for the White Mesa Mill
operation evaluate the health, safety, and environmental impacts from the receipt,
storage, processing, disposal, and long-term storage related to the processing of
alternate feed materials? If so, please identify the documents and sections that contain
such evaluations.
Response:
The license renewal application of 1991 contemplates and the license renewal application of 2007
addresses the processing of alternate feeds at the Mill. Moreover, NRC Alternate Feed Guidance,
and the Mill's Radioactive Materials License anticipate the potential for processing of alternate
feeds in conventional uranium mills, specifically by requiring the submission of an license
amendment containing environmental report information for use in an environmental analysis,
specific to each proposed alternate feed. That is, the Mill's license was not based on a blanket
analysis and blanket approval of alternate feed processing. The license incorporates the more
conservative requirement that the composition, issues and potential impacts of each alternate feed
be evaluated in a feed-specific individual environmental analysis.
15.5. Has the DRC conducted an evaluation of the cumulative impacts of the receipt,
storage, processing, disposal, and long-term storage related to the processing of
alternate feed materials at the White Mesa Mill?
Response:
Cumulative impacts are evaluated during inspections, sampling over the course of time by way of
the Licensee's Environmental monitoring plan, and the groundwater quality discharge permit.
16. NRC regulation (10 C.F.R. § 40.3) states: "A person subject to the regulations in this
part may not receive title to, own, receive, possess, use, transfer, provide for long-term
UW Questions for October 9 Hearing 20 White Mesa Mill Alternate Feed License
Amendment (UT1900479) September 30, 2013 care, deliver or dispose of byproduct
material or residual radioactive material as defined in this part or any source material
after removal from its place of deposit in nature, unless authorized in a specific or
general license issued by the Commission under the regulations in this part." Emphasis
added.
16.1. Does the DMC have a general or specific license to transfer the Uranium Material
from the Midnite Mine to the White Mesa Mill?
Response:
Ongoing reclamation and remediation activities at the Midnite Mine Superfund Site are being
conducted by Dawn Mining Company/Newmont USA, Limited (DMC/Newmont) with U.S.
Environmental Protection Agency oversight, pursuant to the Comprehensive Environmental
EnergyFuels Resources -Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October^ 2013
Response, Compensation and Liability Act ("CERCLA"). In 2006, the EPA adopted a Record of
Decision selecting its preferred remedy for the Midnite Mine Site. In 2012, the U.S. District Court
for the Eastern District of Washington approved a Consent Decree between the EPA,
DMC/Newmont and other parties detailing further requirements for completing remediation at the
Midnite Mine Site in accordance with CERCLA. Remedial actions are being conducted in
accordance with the terms of the ROD, the Consent Decree and numerous EPA-approved design
and work plans.
Prior to the EPA assuming jurisdiction at the site, DMC/Newmont had a license with the
Washington Department of Health (WDOH) through their agreement state program that regulated
the production and possession of the Uranium Material. WDOH terminated that license effective
December 31, 2008, and transferred management oversight to EPA under CERCLA. In
accordance with the Consent Decree, DMC/Newmont is still required to follow the substantive
requirements of the prior WDOH license. Pursuant to Section 121(e) of CERCLA (42 U.S.C.
9621 (e)) DMC/Newmont are not required to have additional permits or licenses for these
CERCLA-managed activities which would allow DMC/Newmont to transfer the Uranium Material
to the White Mesa Mill.
References:
Cardarelli, John (undated). "Attachment 1- Occupational Exposure Assessment Modeling" to
NIFC (National Interagency Fire Center) Redbook, Radiation Document. URL:
http://www.nifc.gov/policies/red_book/doc/RadiationDocument.pdf
NRC (Nuclear Regulatory Commission 1979. FINAL ENVIRONMENTAL STATEMENT
related to the Energy Fuels Nuclear, Inc., WHITE MESA URANIUM PROJECT (San Juan
County, Utah). Docket No. 40-8681. May 1979.
NRCP 1993. NCRP Report No. 118. Radiation Protection in the Mineral Extraction Industry.
August 1993.
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
The following questions are submitted by Anne Mariah Tapp on behalf of the Grand Canyon
Trust in anticipation of a hearing before a Presiding Officer in Salt Lake City, Utah, on
October 9, 2013.
Questions
1. What testing did the Utah Division of Radiation Control (DRC) perform evaluate the
compatibility of the liners of cells 4A and 4B with the alternate feed material proposed to be
accepted from the Midnite Mine site? What were the results of that testing?
Response:
As the Reviewer indicates, tailings from processing the Uranium Material will be disposed in Cell
4A, 4B (or newer cells that may be constructed during the period of processing - it is expected
that these newer cells would be constructed using equivalent technology to that used in Cells 4A
rmlhigh density polyethylene ("HDPE") flexible geomembrane. Both cells include a double 60-
trnl HDPE meml5nme linefwim" a leak detection and collection system. These liner systems are
designed consistent with best Available Technology (BAT )design criteria for waste containment
facility liner systems.
Specific testing to demonstrate chemical compatibility of the Uranium Material with the HDPE
geomembrane liners was not performed. However, manufacturer's material product performance
information, including a chemical resistivity list, was provided in an appendix to a license
amendment request submittals dated June 14, 2013. HDPE manufacturers generally do not include
specific metal cations in chemical resistivity lists since HDPE synthetic liners are generally
compatible (resistive to) metals, metal halide salts, and many other metal salts in all proportions.
Chemical compatibility testing indicates that HDPE geomembrane liners have a high resistance to
attack by chemical constituents, with the possible exception of unusually high concentrations of
oxidizing acids/certain strong (e.g. 75% to 100 % pure) acids (eg., nitric acid, fuming sulfuric
acid), certain gases or other liquids (e.g., 100% pure fluorine, 100% bromine gas or liquid, 100%
pure chloroform, 100% pure sulfur trioxide), and 100% pure toluene or xylene. HDPE
geomembranes are generally recognized as a Best Available Technology in the geosynthetics and
waste disposal facility industry. According to Gulec et al. (2005), a study on the degradation of
HDPE liners under acidic conditions (synthetic acid mine drainage), HDPE was found to be
chemically resistant to solutions similar to the tailings solutions at the Mill. High- density
polyethylene (HDPE) geomembranes have been used exclusively in landfill applications,
especially for bottom liners, because of their relatively high resistance to aggressive leachate
components (e.g., Rowe and Sangam 2002).
Generally, the concentrations of constituents identified in the tailings solids, feed materials or
process streams at the mill are at concentrations that are generally comparable to the
concentrations in the DMC Uranium Material. The constituents that will be added to the Mill
process are similar to conventional ores, and contain calcium, barium, and polymer due to the
addition of these constituents in the WTP process. These components are not expected to have any
adverse effect on the Mill processing system or to the liner systems in the tailings cells.
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
2. What testing will be undertaken to determine whether the groundwater protection standards
for barium contained in 10 CR Part 40, Appendix A, Criterion 5C are being met at the Mill?
Response:
No analysis of groundwater samples for barium will be performed. The existing groundwater
monitoring program conducted at the Mill Site is deemed adequate for monitoring the potential
impacts to groundwater resulting from disposal of residues resulting from processing of the DMC
Uranium Material.
The constituents in the sands and liquids resulting from processing the DMC Uranium Material are
not expected to be significantly different from those in the conventional ores either in composition
or in concentration of constituents. Also, as described in the SER, the DMC Uranium Material,
barium is present as barium sulfate (BaS04). The solubility of barium sulfate in cold water is 0.022
mg/L and in concentrated sulfuric acid is 0.025 mg/L (Weast 1987). Once in the EFRI Mill circuit,
barium sulfate would remain as barium sulfate due to its very low solubility in concentrated
sulfuric acid (0.025 mg/L). At the listed concentrations of sulfate in the tailings solutions (67,600
mg/L to 87,100 mg/L in Cell 4A), a change in the ambient barium concentration in the tailings
solutions (0.02 mg/L) due to placement of the Uranium Material residues to the tailings would be
expected to be very small to negligible. Therefore, given the strong tendency of barium to partition
to solids, especially in the presence of sulfate, the potential for barium to migrate to groundwater
from the tailings cells at the Mill in the event of a release from the tailings cells is considered to be
low. This generally supports the conclusion that barium would be expected to be less mobile than
calcium once solubilized and in the groundwater system. For this reason, barium will not be added
to the Permit as an additional groundwater monitoring compliance parameter. Should additional
information become available at a future date that would suggest that the degree of mobilization of
dissolved barium in the tailings pore-water environment is higher than anticipated, UDRC may
consider whether barium should be added to the Mill's groundwater compliance monitoring
program.
5. How would the talc-like composition of the Midnite Mine alternate feed materials exacerbate
off-site deposition problems identified in USGS report?
Response:
Eolian transport of dust from DMC Uranium Material temporarily stored on ore storage pads at the
mill site will be mitigated through the use additional measures that will be implemented for DMC
Uranium Materials that will be temporarily stored on-site. Specifically, the Division has added a
license condition to the White Mesa Mill Site RML that requires that Uranium Material stored
(stockpiled) at the Mill Site be covered with a geomembrane cover and sufficient ballast be placed
over the cover to prevent wind uplift of the cover during projected peak wind conditions at the site;
and (2) If at any time, visible dust is observed to be originating from Uranium Material stored on
site, that the Licensee's Radiation Safety Officer or his or her authorized representative take
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
actions within 30 minutes to stop the generation of visible dust from the stored DMC Uranium
Material.
Residuals resulting from processing of the DMC Uranium Material will be deposited to the tailings
Cell 4A or 4B (or a future, similarly constructed constructed cell) using the same procedures as
used for depositing tailings from processing of uranium ores. A portion of the DMC Uranium
Material may be insoluble in the acid leach process at the mill and therefore, the discharge sent to
tailings will contain some fraction of sandy solid material. The remainder of the Uranium Material
will be soluble and therefore be contained in the liquid phase after processing in the acid leach
system. It is expected that most of the metal and non-metal impurities entering the leach system
with the Uranium Material will be converted to sulfate ions, precipitated, and eventually
discharged to one of these tailings cells.
Process residuals from processing of the DMC Uranium Material would be pumped into the
tailings cells in a manner similar to tailings materials following processing of uranium ores. The
materials are pumped in a slurry either onto a protective rub sheet directly into the solution
contained in each cell, or onto pumped onto previously deposited tailings sand materials. The
materials settle out creating a buildup of solid materials from the base of the cell upward. Solution
levels in the cells vary depending on the operating schedule of the Mill and seasonal evaporation
rates (Cell 4A and Cell 4B BAT Operations, Monitoring and Maintenance Plan, July 2011). All
tailings cells, including Cells 4A and 4B, are operated and maintained to achieve Discharge
Minimization Technology and Best Available Technology Standards identified in the Ground
Water Discharge Permit.
All operational features in the tailings cells area are inspected daily for conditions of potential
concern, in accordance with the requirements listed in the most current version of the White Mesa
Mill Tailings Management Systems and Discharge Minimization Technology (DMT) Monitoring
Plan (e.g., see DUSA 2007). Estimates of tailings beach surface area and solutions pool area are
made, evidence of wind movement of tailings during these inspections is observed and
documented, and conditions which may require initiation of preventative dust minimization
measures are identified. Dust minimization measures taken or recommended are documented on
the Inspection Forms. Evaluations are reviewed on a weekly basis, or more frequently if
warranted, with review results used to direct dust minimization activities. The licensee regularly
sprays tailings solutions onto beached tailing areas, which helps result in the formation of a "crust"
over the exposed tailings. Other dust minimization activities include placing temporary soil cover
over exposed tailings areas in a phased manner as the tailings elevations approach interim final fill
grades These inspections and DMT Monitoring Plan requirements are designed to allow dust
mitigation measures to be undertaken if excessive wind movement of dust from the tailings area is
observed.
c-
6. What periods of time can these tailings be exposed without a water cover? Will a 1 meter water
cover be required at all times for these tails? Please describe dusting and radon emission impacts
that can occur when the waste from processing these wastes are not covered?
Response:
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
Liquid levels in tailings cells 4A and 4B are typically maintained at a level of approximately 4.8
to 5.8 feet below the top of the geomembrane liner in each cell, or lower, to ensure adequate
capacity in the cells to accommodate liquid generated a potential PMP at the site and the allow for
the estimated height of wave run-up. The Ground Water Discharge Permit also specifies a
minimum freeboard height of 3 feet in these tailings cells. As described in the Response to
Reviewer Comment No. 5 above, solution levels in the cells vary depending on the operating
schedule of the Mill and seasonal evaporation rates. The Response to Reviewer Comment No. 5
also describes dust mitigation measures that are undertaken to minimize dust generation from
exposed tailings.
EnergyFuels Resources-Dawn Mining Alternate Feed
Public Hearing-Cross Examination Questions October 9, 2013
References Cited:
Denison Mines (USA) Corp. (DUSA) 2007. "White Mesa Mill Tailings Management Systems and
Discharge Minimization Technology (DMT) Monitoring Plan", in Book #11. Environmental
Protection Manual, Appendix A to License Renewal Application. February 28, 2007.
Gulec, S.B., CH. Benson, and T. B. Edil, 2005. "Effect of Acid Mine Drainage on the
Mechanical and Hydraulic Properties of Three Geosynthetics", Journal of Geotechnical and
Geoenvironmental Engineering Vol. 131, No. 8, ASCE, pp. 937-950.
Rowe, K. R., and Sangam, H.P. 2002. " Review Article: Durability of HDPE Geomembranes",
in Geotextiles and Geomembranes, Vol. 20, 2002, pp. 77-95.
Weast, R.C (ed.) 1987. CRC Handbook of Chemistry and Physics, 68th edition.
Public Attendance Sheet
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MSOB, Conf. Room 1015
195 N 1950 W, Salt Lake City, UT 84114-4850
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October 9, 2013
Public Attendance Sheet
Utah Radiation Control
Hearing
MSOB, Conf. Room 1015
195 N 1950 W, Salt Lake City, UT 84114-4850
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