DRC-2013-002482 - 0901a0688038f2af

ENERGYFUELS
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600
Lakewood, CO, US, 80228
303 974 2140
www energyfuels com
Mr. Rusty Lundberg
June 14, 2013
VIA EMAIL AND OVERNIGHT DELIVERY
Director of the Utah Division of Radiation Control \ /
State of Utah Department of Environmental Quality ^ :" ^
195 North 1950 West "DRC-2013-002482"
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill - RML UT1900479
April 27,2011 Request to Amend Radioactive Materials License to Allow Processing of
Alternate Feed Materials from Dawn Mining Company's Midnite Mine Water
Treatment Plant ("WTF')
Response to January 22,2013 and January 23,2013 Utah Division of Radiation Control
Requests for Information
Dear Mr. Lundberg:
This letter responds to the Division of Radiation Control's ("DRC's") two Requests for Information
("RFIs") dated January 22, and 23, 2013 regarding Energy Fuels Resources (USA) Inc.'s. ("EFRI's")
April 27, 2011 Request to Amend (the "April 2011 Amendment Request") the White Mesa Mill's (the
"Mill's") Radioactive Materials License UT 1900479 (the "RML" or the "License") to allow processing
of alternate feed material from Dawn Mining Company (the "Uranium Material"). DRC provided one
general comment and 17 specific comments in the RFI dated January 22, 2013, and one additional
specific comment in the RFI dated January 23, 2013. This letter addresses the comments from both
RFIs. For ease of review, each of DRC's comments is provided verbatim below in italics, followed by
EFRI's response.
General Comment 1
Specific comments stated below address the Applicant's repeated statements that the Uranium Material
proposed to be processed in the White Mesa Mill has characteristics that are within the envelope of
material characteristics previously authorized to be processed at the Mill.
Once the specific comments stated below have been addressed, please review and evaluate the
correctness of conclusions stated throughout the text of the amendment application that previously
accepted or authorized analyses, plans, programs, procedures, practices, equipment, etc. need not be
extended or revised. Justify each new conclusion. To the extent necessary, extend or revise previously
accepted or authorized analyses, plans, programs, procedures, practices, equipment, etc. and submit
them for the Division's consideration and approval.
?:i:J~ ~I!;~ERGYFUELS
VIA EMAIL AND OVERNIGHT DELIVERY
June 14,2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill -RML UT1900479
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
April 27, 2011 Request to Amend Radioactive Materials License to Allow Processing of
Alternate Feed Materials from Dawn Mining Company's Midnite Mine Water
Treatment Plant ("WTP")
Response to January 22, 2013 and January 23, 2013 Utah Division of Radiation Control
Requests for Information
Dear Mr. Lundberg:
This letter responds to the Division of Radiation Control's ("DRC's") two Requests for Information
("RFls") dated January 22, and 23, 2013 regarding Energy Fuels Resources (USA) Inc.'s. ("EFRI's")
April 27, 2011 Request to Amend (the "April 2011 Amendment Request") the White Mesa Mill's (the
"Mill's") Radioactive Materials License UT1900479 (the "RML" or the "License") to allow processing
of alternate feed material from Dawn Mining Company (the "Uranium Material"). DRC provided one
general comment and 17 specific comments in the RFI dated January 22, 2013, and one additional
specific comment in the RFI dated January 23, 2013. This letter addresses the comments from both
RFls. For ease of review, each of DRC's comments is provided verbatim below in italics, followed by
EFRI's response.
General Comment 1
Specific comments stated below address the Applicant's repeated statements that the Uranium Material
proposed to be processed in the White Mesa Mill has characteristics that are within the envelope of
material characteristics previously authorized to be processed at the Mill.
Once the specific comments stated below have been addressed, please review and evaluate the
correctness of conclusions stated throughout the text of the amendment application that previously
accepted or authorized analyses, plans, programs, procedures, practices, equipment, etc. need not be
extended or revised. Justify each new conclusion. To the extent necessary, extend or revise previously
accepted or authorized analyses, plans, programs, procedures, practices, equipment, etc. and submit
them for the Division's consideration and approval.
N:\WMM\Alternate Feeds\Dawn Mining Midnight Mine\Response to Jan 2013 DRC Comments\Responses DCF redIines
6. 10. 13\Response to DRC comments Dawn Mining 6. 10. 13.doc
Letter to Rusty Lundberg
June 14,2013
Page 2 of35
EFRI Response to General Comment 1
EFRI has reviewed the data provided in the April 2011 Amendment Request, the supplemental submittal
of filter press test information, and supplemental data provided in, or as attachments to, the responses
included herein. Based on this review, EFRI maintains that the Uranium Material does not pose
substantially different or greater hazards than other feed materials already approved, and in most
instances poses significantly less hazards than other materials handled safely at the Mill for the reasons
discussed below.
All data and additional evaluations continue to indicate that the Uranium Material is simpler and more
benign in chemical and radiological composition than many previously approved alternate feed materials
that the Mill has processed, as described in the April 2011 Amendment Request. All the constituents in
the Uranium Material have either been reported to be, or can be assumed to be, already present in the
Mill's tailings system or were reported in other licensed alternate feed materials, at levels comparable to
or higher than those reported in the Uranium Material. The focus of the analysis in the April 2011
Amendment Request is on any difference that may necessitate changes to the existing approved
programs. The storage and processing of the Uranium Material will not introduce new constituents or
new constituent forms (dissolved, particulate or gaseous) or create significantly new human or
environmental exposure risks that have not already been addressed by previous submittals and approvals
by appropriate authorities (US Nuclear Regulatory Commission ("NRC") or DRC).
Based on this review, and because the Uranium Material does not pose substantially different or
greater hazards than other feed materials already approved, as addressed in the application and the
enclosed responses to these comments, EFRI maintains that the Mill can safely handle the Uranium
Material in accordance with existing Mill controls and standard operating procedures. Additionally,
EFRI maintains that the existing monitoring programs are adequate and no new monitoring procedures
are required.
Previously accepted or authorized analyses, plans, programs, procedures, practices, equipment, etc.
include (but are not necessarily limited to) the following:
a. H ••• there will be no incremental public health, safety or environmental impacts over and
above previously licensed activities" stated on Page 11 of the Amendment Request.
EFRI General Response to General Comment la
Please review the responses to comments listed below. The discussions, data and calculations in the
April 2011 Amendment Request and the responses to these comments demonstrate that:
• No new hazardous constituents will be introduced to the Mill, the tailings system, groundwater
or air (RMPR, response to Specific Comment 2),
• There will be no additional environmental or worker safety impacts due to increased levels of
constituents previously introduced into the Mill (response to Specific Comments 6, 7, 8, 10)
• There will be no additional transportation impacts (response to General Comment 1 b)
• The Uranium Material requires no special handling and will create no additional impacts on the
Letter to Rusty Lundberg
June 14,2013
Page 3 of 35
ore pad (response to General Comment 1c),
• The Uranium Material:
o Produces no additional impacts to surface water (response to General Comment 1d)
o Produces no additional impacts to groundwater (response to General Comment, 11)
o Produces no additional risks to air (response to General Comment Ie)
o Produces no increased radiation hazard (responses to General Comments If, g, h,
Specific Comments 1,3,4)
o Produces no impacts or changes to Decontamination and Decommissioning, or to
Reclamation (response to General Comment 1k)
Therefore, based on review of the April 2011 Amendment Request and supplemental information in
this response letter, EFRI maintains that the statements in the April 2011 Amendment Request, that
there will be no incremental public health, safety or environmental impacts over and above previously
licensed activities is justified.
b. " ... it is not expected that transportation impacts associated with the movement of the
Uranium Material by truck from the Midnite Mine WIP facility to the mill will be
significant. "
EFRI Response to General Comment lb.
The transportation considerations assessed for shipping the Uranium Material are presented in Section
4.2 of the April 2011 Amendment Request. Two aspects of transportation are considered, radiological
matters and traffic matters. As stated in Section 4.2.1 of the application, the estimated range of truck
shipments would be from 2 to 73 trucks per year, with the highest number of trucks expected in the
two years of construction of the Remedy. This equates to a maximum of two trucks in any given week
on average. Section 4.2.2(a) of the April 2011 Amendment Request addresses radiological
considerations. Specifically, the April 2011 Amendment Request states the following.
"The transport of radioactive materials is subject to limits on radiation dose rate
measured at the transport vehicle as specified in the US Code of Federal Regulations.
The external radiation standards for these shipments are specified in 10 CFR 71.47
sections (2) and (3) as less than 200 millirems per hour ("mremlhr") at any point on the
outer surface of the vehicle, and less than 10 mremlhr at any point two meters from the
outer lateral surfaces of the vehicle. All exclusive use trailer trucks will be scanned by
Dawn Mining Company prior to departure from the Midnite Mine Water Treatment Plan
(" WIP" ) facility to ensure that these limits are satisfied."
In addition, the application commits that;
"All applicable requirements of 49 CFR Part 172 and Part 173 will be met, and the
selected transport company will have all the required training and emergency response
programs and certifications in place. "
Letter to Rusty Lundberg
June 14,2013
Page 4 of35
Therefore, the shipment of the Uranium Material will comply with all applicable federal safety standards
for transportation of Class 7 radiological materials. As such, EFRI re-asserts that the transportation of
the Uranium Material by truck from the Midnite Mine WTP facility to the Mill will have no significant
transportation related radiological impacts.
The primary transportation corridors in Utah are illustrated in Figure 1 to this response letter. The
Uranium Material will travel through Utah south on Highway 15, east on Highway 70 and then south to
the Mill on Highway 191. Section 4.2.2(b) of the April 2011 Amendment Request addresses traffic
impact considerations for this route. The analysis identifies that the original 1979 Final Environmental
Statement (FES) and 1978 Environmental Report contemplated the transportation impacts associated
with approximately 68 round trips on local highways by 30-ton ore trucks to the Mill per day. In
addition, the FES contemplated approximately 183-275 truck shipments of yellowcake from the Mill per
year, which equates to one truck everyone to two days based on a seven day work week (one truck
every day or so, based on a five-day work week).
Sections 4.2.2(b )(ii) and (iii) of the April 2011 Amendment Request assesses the current truck traffic on
Interstate Highways 15, 70, and 191, which are the principal Utah roadways on which trucks carrying
the Uranium Material would reach the Mill. These sections identify that, based on 2009 data from the
Utah Department of Transportation (UDOT), an average of ten additional trucks per month traveling this
route to the Mill from May to October represents an increased traffic load of less than 2 one hundredths
of one percent (0.02%).
Further, based on the 2009 UDOT truck traffic information, an average of 10 additional trucks per
month traveling this route to the Mill from May to October represents an increased traffic load of less
than one half of one percent. This level of truck transportation volume is well below the level
contemplated in the original FES and represents a minute fraction of the existing truck volume on the
transportation route. Therefore, EFRI re-asserts that transportation impacts associated with the
movement of the Uranium Material by truck from the Midnite Mine WTP facility to the Mill are not
expected to be significant.
c. " ... the Uranium Material is stable under ambient environmental conditions and does not
require any special handling ... the TeLP data evidences that the material does not readily
leach and does not exhibit hazardous waste characteristics when exposed to more severe
conditions than would be anticipated on the ore storage pad" stated on page 13 of the
Amendment request.
EFRI Response to General Comment Ie.
As demonstrated by the testing results presented in Attachment 4 of the April 2011 Amendment
Request, the Uranium Materials passes the Toxicity Characteristic Leaching Procedure ("TCLP") test,
which was designed to simulate the leaching of solids within a landfill environment. The pH conditions
of the TCLP (pH between 3 and 5 S.U., depending on the material characteristics; EPA Method 1311)
are set to be representative of acidic chemical conditions within landfills and tend to be as or more
aggressive (lower pH) than, conditions experienced under ambient meteoric conditions to which the
Uranium Material would typically be exposed during storage (typically pH ~ 5.4; USGS, 2001).
Letter to Rusty Lundberg
June 14,2013
Page 5 of35
Therefore, these test data support the statement that "the material does not readily leach and does not
exhibit the hazardous waste characteristic of toxicity when exposed to more severe conditions than
would be anticipated on the ore storage pad" stated on page 13 of the April 2011 Amendment Request.
Additionally, the Uranium Material does not exhibit the hazardous characteristics of reactivity,
ignitability or COITosivity, as determined by the specific test results reported in the Radioactive Material
Profile Record ("RMPR") in Attachment 2 to the April 2011 Amendment Request.
Dawn Mining Company has produced and managed these materials for over a decade. This operational
experience also provides a factual basis supporting the above assertion. The Affidavit signed by the Site
Manager for Dawn Mining Company (provided as Attachment 2 to the April 2011 Amendment Request)
provides testimony, based on these years of first-hand experience, that these materials" .... will not yield
water during shipping or during dry open air storage nor will the proposed alternate feed material flow
when exposed to precipitation events or standard dust control measures by applying water through spray
application, and is not prone to degrading to fine dust sized particles". Therefore, EFRI has provided
quantitative and observational data to support this assertion and continues to maintain that, as stated in
Section 4.3.2 of the application, "the Uranium Material is stable under ambient environmental
conditions and does not require any special handling" and that "The TCLP data evidences that the
material does not readily leach and does not exhibit hazardous waste characteristics when exposed to
more severe conditions than would be anticipated on the ore storage pad."
d. " ... there will be no new or incremental risk of discharge to surface waters resulting from
the receipt and processing of Uranium Material at the Mill or the disposition of the resulting
tailings" stated on page 16 of the Amendment Request.
EFRI Response to General Comment Id.
Attachment 2 to the April 2011 Amendment Request provides a completed RMPR for the Uranium
Material. Table 6 of Attachment 5 to the April 2011 Amendment Request presents a comparison of
constituent concentrations in existing ores and other alternate feed materials processed at the Mill as
well as the range of constituent concentrations in the Uranium Material. These data indicate that the
Uranium Material constituents are present in concentrations within the range of ores and other alternate
feed materials which are already permitted to be processed at the Mill under the existing license.
The modes of potential impact to surface waters from Uranium Material delivery, storage, processing
and long-term disposal are from, 1) release of site surface runoff containing Uranium Material
contaminants, 2) discharge of other process liquid effluents containing Uranium Material contaminants
to surface water systems, and/or 3) airborne transport of Uranium Material particulates related to
delivery, storage and processing of these materials. As stated in Section 4.7 of the April 2011
Amendment Request, protection of surface water from potential impacts related to receiving, storage
and processing this Uranium Material will be accomplished through control of potential surface water
discharges using the Mill's existing storm water and liquid effluent controls. Specifically, storm water
runoff from the Mill and facilities, including the ore storage area where the Uranium Material will be
received and stored, is directed to the tailings impoundments through approved storm water controls
contained in the Stormwater Best Management Practices Plan for White Mesa Mill (EFRI, September
2012). These are the same controls used for storage of all other areas and alternate feed materials.
Letter to Rusty Lundberg
June 14,2013
Page 6 of 35
Since the Uranium Material is stable under ambient environmental conditions (see response to General
Comment 1c) and will not provide substantially different input to the ore storage area storm water than
is already contributed from conventional ores and other approved alternate feed materials, there is no
reasonable mechanism for new or incremental risk of discharge to surface waters resulting from the
receipt and processing of Uranium Material at the Mill or the disposition of the resulting tailings.
In addition, all other Mill process liquid effluents, laundry, and analytical laboratory liquid wastes that
could carry potential Uranium Material contaminants will be discharged to the Mill's tailings
impoundments for disposal using the existing appropriate and approved management systems as per
Condition 10.2 of the RML. Further, though the Uranium Material does not have an observed
propensity to generate dust (see Attachment 2 of the April 2011 Amendment Request, Affidavit Item
10), control of potential air transport of Uranium Material particulates from storage and handling will be
performed using standard approved dust control and worker protective equipment practices (see April
2011 Amendment Request Section 4.1O.2(d), p.17, Section 5.0, p.17,). Also, the Uranium Material will
have a moisture content of approximately 25 to 45 percent (see Attachment 2 of the April 2011
Amendment Request), which is 6 to 11 times greater than the minimum moisture content currently
contemplated for ores and feeds stored on the ore pad by the Mill's State of Utah Air Approval Order
("AO") for minimization of the potential dust generation. Given the factors above, EFRI maintains that
wind transport of Uranium Material particulates have no new or incremental risk of constituent
discharge or potential adverse impact to surface waters.
Therefore, EFRI has demonstrated and maintains that 1) the Uranium Material does not contain
constituents outside the range of materials already processed at the Mill, 2) the Uranium Material does
not exhibit leaching characteristics that will allow a significant potential to release constituents to site
runoff (see response to General Comment 1c, above), 3) experience with outdoor storage and
management of the Uranium Material establishes a reasonable basis for concluding storage on Mill site
ore pads will not require special handling (see Attachment 2 of the April 2011 Amendment Request),
and 4) that there are appropriate approved management systems for control site runoff and other liquid
effluents to protect surface water resources.
e. "The existing air particulate monitoring program is equipped to handle all such ores" stated
on Page 16 of the Amendment Request.
EFRI Response to General Comment Ie.
As stated in the April 2011 Amendment Request, the Uranium Material has little potential for generating
dust and particulates (Attachment 2 to the Amendment Request, Affidavit). The Mill's AO currently
limits dust potential by requiring in Part II.B.I.c that dusts from the ore loading areas may not exceed
15% opacity. At the current time, Part II.B.4.h of the AO contemplates that the moisture content of
materials handled by front-end loading operations and truck-dumping operations are not less than 4% by
weight during these operations.
As stated in Section 4.3.1 and Section 4.7 of the application, the Uranium Material, like conventional
ore, will be delivered by tarp-covered trucks, which will be unloaded onto the ore pad for temporary
storage pending processing as is currently done for conventional ores and some alternate feed materials.
Letter to Rusty Lundberg
June 14,2013
Page 7 of35
The Uranium Material will be unloaded and stored in a manner essentially identical to conventional ore.
In addition, the Uranium Material will be relatively moist, with an average moisture content of
approximately 25 to 45%, and has been thoroughly characterized (see Attachment 2 of the April 2011
Amendment Request). As mentioned in the response to General Comment Id, above, this moisture
content surpasses the current moisture requirement for ores and feeds in the Mill's AO by a factor of 6
to 11 times.
The existing environmental air monitoring system, required per License Condition 11.2 of the RML, and
summarized in Section 5.5 of the Mill's License Renewal Application (UMETCO 1991) has been
approved by the NRC and the State of Utah and meets the requirements identified in NRC regulatory
Guide 4.14 (NRC, 1980; Section 2).
The monitoring program referenced above includes high volume air sampling devices collecting
airborne radioparticulate data both upwind and downwind of the Mill. These environmental data are
compo sited regularly and analyzed quarterly, with results being reported semi-annually. These data are
assessed with respect to the 10 CFR 20, Appendix B, Table 2, Effluent Concentration Limits for
unrestricted areas, to ensure that site operational practices for controlling particulate radionuclides and
dust are protective of public health.
Similarly, the existing occupational health air monitoring program approved under License Condition
11.4 of the RML, and as described in the Technical Evaluation Report ("TER") for NRC License
Amendment 7 (US NRC August 1998), meets the requirements for monitoring particulate radionuclides
in uranium mills (NRC, 1979) and has been approved by DRC. The TER for the NRC License
Amendment 7 is included as Appendix A to this letter.
EFRI has assessed many factors in developing this April 2011 Amendment Request including the
adequacy of the existing stack emissions monitoring, fugitive emissions (dust) monitoring, and
environmental air particulate monitoring program. Since the Uranium Material constituent
concentrations are within the range of those for other ores and alternate feed materials already processed
at the Mill (see response to General Comment Id, above) and since this Uranium Material has no
propensity to generate abundant dust sized particles (Attachment 2 of the April 2011 Amendment
Request, Affidavit) and will be subject to routine dust control procedures during unloading, storage and
processing, EFRI concluded and maintains that the existing air monitoring program is equipped to
handle the Uranium Material.
f " ... the Uranium Material will therefore poses less of a gamma and radon hazard than
other ores and alternate feed materials that have been processed or licensed for processing
at the Mill" stated on Page 16 of the Amendment Request.
EFRI Response to General Comment If.
Attachment 2 of the April 2011 Amendment Request presents a complete RMPR for the Uranium
Material. Table 1, below, summarizes the ranges of radionuclide activity concentrations of the Uranium
Material as well as other alternate feed materials already approved for processing, and successfully
processed at the Mill. These data demonstrate that the primary gamma emitting radionuclide content
Letter to Rusty Lundberg
June 14,2013
Page 8 of35
(Uranium, Thorium and Radium) of the Uranium Material are below the maximum of the range of
relevant radionuclide activity concentrations of conventional ores and already-approved alternate feed
materials. Therefore, the gamma radiation and radon emissions from this Uranium Material will be
correspondingly less than other conventional ores and alternate feed materials that have been processed
or licensed for processing at the Mill. Consequently, EFRI maintains that the above references
statement is correct and that these data are sufficient to support this assertion.
Table 1. Comparison of Radionuclide Activity Concentrations in Proposed Uranium Material and
Previous Alternate Feeds
Range of Uranium Range of Colorado Source for Alternate Feed
Material Radionuclide Plateau Ores and Information
Radionuclide Activity Concentration! Alternate Feed
(pCi/g dry)2 Radionuclide Activity
Concentrations3,4
(pCilg dry)2
Ra-226 22.8 to 25.7 2,000 avg; 10,400 max W.R.Grace Application April 2000
Total Radium 36.6 to 41.0 1,190 max (Ra 228+Ra 226J Heritage Application July 2000
Th-228 0.93 to 1.50 2,000 avg.; 3,222 max W.R.Grace Agplication April 2000
Th-230 20.4 to 21.4 2,000 avg., 10,400 max. W.R.Grace Application April 2000
Th-232 0.66 to 1.14 8,000 avg.; 31,500 max. W.R.Grace Application April 2000
Pb-210 32.0 to 41.0 2,805 max. Based on 1 % U, conventional ores
Unat 15,000 mg/kg to 16,000 mg/kg 686,000 mg/kg Unat max? Mill lab monthly assays Cameco
UF4
Gross Alpha 431O±690 to 5440±870 7,600 max. Linde Application March 2005
22,400 conventional oress
Gross Beta 4780±760 to 4870±780 3,800 max. Linde Application March 2005
17,000 conventional ores6
1 Attachment 2 of the April 2011 Amendment Request (Radioactive Material Profile Record, p.2 of 11 and associated tables)
2 pCi/g unless otherwise noted
3 Selected concentrations for constituents found in characterization data for other alternate feed materials licensed for
processing at the Mill, for comparison purposes only.
4. Mined ores range from 0.1 % to higher than 1 % Some Arizona strip ores have ranged as high as 2% U30 g 0.7% U-nat).
Abundance of uranium daughters can be estimated from the assumption that ores are in secular equilibrium.
5, Estimated based on assumption of 1 % U30 g (0.85% U) at 2830 pCi/g and eight alphas in U-238 series, and neglecting the
contribution from U-235.
6, Estimated based on assumption of 1 % U30 g (0.85% U) at 2830 pCi/g and six betas in U-238 series and neglecting the
contribution from U-235.
7. Monthly average grade assays of Cameco UF4 have periodically been as high as 80.7% U30 g (68.6% U).
g. "Gamma exposure to workers will be managed in accordance with existing Mill standard
operating procedures" stated on Page 17 of the Amendment Request.
EFRI Response to General Comment 19.
As described in the response to General Comment If above, the radionuclide activity of the primary
gamma emitting radionuclides are below the maximum of the range of relevant radionuclide activity
concentrations of already approved alternate feed materials. Therefore, the potential gamma emissions
Letter to Rusty Lundberg
June 14,2013
Page 9 of 35
and potential worker exposure to gamma radiation will be within the range of those already
appropriately managed and monitored at the Mill. Consequently, EFRI maintains that the existing
standard operating procedures and controls are adequate to maintain all radiological exposures to
protective levels and levels that are as low as reasonably achievable (ALARA).
h. "Radon exposures to workers will be managed in accordance with existing Mill standard
operations" stated on Page 17 of the Amendment Request.
EFRI Response to General Comment lh.
Based on the information provided in the response to General Comment If, above, in which it is
demonstrated 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,
the resulting radon levels are expected to be within the range for which the existing approved controls
and monitoring programs are appropriate. Therefore, no change to the existing radon exposure controls
or the radiological monitoring program is necessary.
i. "The Mill ... can safely handle the Uranium Material in accordance with existing Mill
standard operating procedures" stated on Page 17 of the Amendment Request.
EFRI Response to General Comment Ii.
EFRI has reviewed the General Comments, the Specific Comments and all related responses included
herein. Based on this review and because the Uranium Material does not pose substantially different or
greater chemical or radiological hazards than conventional ores and other alternate feed materials
already approved, and generally poses lower hazards than other previously-handled conventional ores
and alternate feed materials, as addressed in the April 2011 Amendment Request and the enclosed
responses to these comments, EFRI maintains that the Mill can safely handle the Uranium Material in
accordance with existing Mill standard operating procedures.
J. "Existing monitoring programs are therefore adequate and no new monitoring procedures
are required" stated on Page 18 of the Amendment Request.
EFRI Response to General Comment lj.
EFRI has reviewed the General Comments, the Specific Comments and all related responses included
herein. Based on this review and because the Uranium Material does not pose substantially different or
greater hazards than conventional ores and other alternate feed materials already approved, as addressed
in the application and the enclosed responses to these comments, EFRI maintains that the existing
monitoring programs are adequate and no new monitoring procedures are required.
k. " ... there will be no decommissioning, decontamination or reclamation impacts associated
with processing the Uranium Material, over and above previously licensed Mill operations"
stated on Page 18 of the Amendment Request.
Letter to Rusty Lundberg
June 14,2013
Page 10 of 35
EFRI General Response lk.
As discussed in detail in the Mill's approved Reclamation Plan, the components of the decontamination
and decommissioning phase and reclamation phase of Mill closure are:
• Demolition of buildings, structures, and facilities (including Cell 1)
• Decontamination to free release standards of any equipment to be released from the site
• Disposal of all demolished structures and equipment in the Mill's tailings cells
• Decontamination of environmental media (on site and off site soil) to levels committed in the
Reclamation Plan
• Restoration of any potential groundwater contamination to groundwater compliance limits or
approved Alternate Corrective Action Compliance Limits
The long term-impacts that an alternate feed material could potentially have on the decontamination and
decommissioning phase, reclamation phase, or post-reclamation conditions are:
• Increase in volume of material in the tailings cells
• Addition of a new contaminant that cannot be managed or contained by the existing tailings
reclamation design
• Increase in concentration of a contaminant to a level that cannot be managed or contained by the
existing tailings reclamation design
• Contamination of soils or sediments requiring management at reclamation
• Change in nature of groundwater conditions requiring restoration at reclamation, to meet
applicable groundwater quality standards.
As discussed in the April 2011 Amendment Request and in the specific responses below, the Uranium
Material will produce none of these impacts because:
• The Uranium Material will not increase the volume of tailings. As discussed in the April 2011
Amendment Request, the Uranium Material will produce no greater volume of tailings than
would be produced from processing the same volume of ore. Processing of the Uranium
Material does not require the use of any new or modified equipment, hence no additional volume
of demolition material would be added to tailings.
• The Uranium Material does not contain any constituents that have not already been introduced to
the Mill's tailings system. The RMPR, analytical data, and technical memorandum in the April
2011 Amendment Request demonstrate that the sampling and analytical data are representative
of the Uranium Material, and the Uranium Material contains no new constituents. Processing of
the Uranium Material will not require the use of additional chemicals not already in use at the
Mill. Therefore processing of the Uranium Material will not introduce any new chemical
constituent that cannot be managed or contained by the existing tailings reclamation design.
• Processing of the Uranium Material will not increase the concentration of any contaminant to a
level that cannot be managed or contained by the existing tailings reclamation design. All
Letter to Rusty Lundberg
June 14,2013
Page 11 of 35
constituents present in the Uranium Material have already been introduced into the Mill at levels
higher than the levels present in the Uranium Material. Anticipated increases in barium levels in
tailings will have no effect on the integrity of the tailings liner.
• As discussed in the responses to general Comment Ie and Specific Comment 7, processing of
the Uranium Material will produce no additional mechanism for, or significant increase in,
airborne deposition in soils or sediments.
• As discussed in the response to Specific Comment 11, processing of the Uranium Material will
produce no additional pathway for, or increase in, any potential effects to groundwater.
Specifically, each constituent in the Uranium Material is either monitored under the Mill's
approved Groundwater Discharge Permit (GWDP"), or represented by a constituent monitored
in the GWDP, and the monitoring program required by the GWDP meets the requirements of
NRC Reg. Guide 4.14 and Utah groundwater regulations. Hence, processing of the Uranium
Material will not potentially change the nature of groundwater conditions in a way that requires
additional groundwater restoration at or before reclamation.
References for General Comment 1 a through k
Dames and Moore, 1978. Environmental Report White Mesa Uranium Project, San Juan
County, Utah.
Energy Fuels Resources (USA) Inc., 2012. Stormwater Best Management Practices Plan for
White Mesa Mill.
United States Nuclear Regulatory Commission (NRC), 1979. Final Environmental Statement
Related to Operation of White Mesa Uranium Project.
United States Environmental Protection Agency (EPA) Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods, Method 1311, Revision 0, July 1992.
Utah Division of Air Quality 2011. Air Approval Order Number DAQE-ANOl12050018-11
Specific Comment 1
Pages 6 and 7, Section 2.6.1 of the April 2011 DMC LAR: Please justify by providing documentation of
the following parameter values stated in the narrative:
a. Uranium Material average uranium content of approximately 1.4% on a dry weight basis.
EFRI Response to Specific Comment la
a. Attachment 2 of the April 2011 Amendment Request includes a completed RMPR. Page 9 of
the RMPR presents Uranium Material Analyses for RCRA Listed Hazardous Waste on a dry
weight basis. The first line of this table presents total uranium concentrations in three
Letter to Rusty Lundberg
June 14,2013
Page 12 of 35
representative samples of the Uranium Material from the 2010 treatment season (WTPS-1, -2, -
3). Uranium (U-nat) results range from 15,000 mg/kg to 16,000 mg/kg with an average of
15,333 mg/kg on a dry weight basis.
Based on the following calculations, these test results establish that the average U-nat content
of the Uranium Material is approximately 1.5% on a dry weight basis, rather than the 1.4%
stated in the original submittal. Included as Appendix B to this response letter is a revised
copy of the Amendment Request in redline format, including this correction.
15,333 mg/kg 7 Ix 106 mg/kg = 0.0153 kg/kg or 1.5%
b. High grade Arizona Strip breccia pipe uranium ore content ranging from 0.4% to 2% U308
or higher.
EFRI Response to Specific Comment Ib
Table 1 provides ore grade data on an annual basis for the Arizona 1 Mine as an example of a
typical Arizona Strip breccia pipe mine. The range and mean ore grade data for all years of the
Arizona 1 Mine operation (2010 to 2012) available at this time, is supplied in Table 1. Table
1 demonstrates that the ore grades have averaged 0.56% or higher every year during the life of
mine for all data available to date, with maximum grades exceeding 2% every year during the
life of mine for all data available to date.
Year
2010
2011
2012
Table 2
Summary of Arizona lOre Grades
(Dry Weight Basis)
Minimum Maximum
(%U30s) (%U30S)
0.18 2.4
0.14 2.0
0.22 2.8
Arithmetic
Mean
(%U3Os)
0.56
0.66
0.62
c. Estimated average Thorium-232 content 0.005% on a dry weight basis.
EFRI Response to Specific Comment Ic
Attachment 2 to the April 2011 Amendment Request includes a completed RMPR. Page 10 of the
RMPR presents Uranium Material Analyses for RCRA Listed Hazardous Waste in the top half of the
table, and radionuclide data in the bottom half of the table. The second to last line of this table
presents total Th-232 concentrations in three representative samples of the Uranium Material from the
2010 treatment season (WTPS-1, -2, -3). Thorium-232 results range from 0.66 ± 0.34 pCi/g to 1.14 ±
0.48 pCi/g with an average of 0.84 pCi/g on a dry weight basis.
Letter to Rusty Lundberg
June 14,2013
Page 13 of 35
Based on the following calculations, these test results establish that the average Th-232 content of the
Uranium Material is approximately 0.00076% on a dry weight basis, rather than the 0.005% stated in
the original submittal. Nonetheless, the statement that the Th-233 level in the Uranium Material is
well below the levels the Mill has been licensed to process in the past is justified. Included as
Appendix B to this response letter is a revised copy of the Amendment Request in redline format,
including this correction.
Th-232 specific activity) =1.1.xlO-7 Ci/g (1.1x105 pCi/g)
0.84 pCi/g 7 1. Ix 105 pCi/g = 0.0000076 or 0.00076%
lArgonne National Laboratory, EVS. Human Health Fact Sheet, August 2005 (hllp:/lwww.es.IIIII.SilVlt.lUb/dotfnl()rium.f)dO.
d. Radium-226, Thorium-230, and Lead-210 concentrations of24.1 pCiIL, 20.7 pCiIL, and 33.3
pCiIL, respectively.
EFRI Response to Specific Comment ld
Documentation has already been provided in the RMPR in Attachment 2 to the April 2011
Amendment Request. Page 10 of the RMPR presents Uranium Material Analyses for RCRA Listed
Hazardous Waste. The lower half of this of this table presents total Ra-226, Th-230 and Pb-210
concentrations in three representative samples of the Uranium Material from the 2010 treatment
season (WTPS-l, -2, -3). The far right hand column of this table presents the average concentrations
of these three isotopes from analytical testing on a dry weight basis.
e. Radium-226, Thorium-230, and Lead-210 concentrations of 825 pCiIL each in Colorado
Plateau ore with U30S content of 0.25%
EFRI Response to Specific Comment Ie
Per NRC Reg. Guide 3.59, the radionuclides in uranium ore are generally assumed to be in secular
equilibrium with U-238. Radium-226, thorium-230, and lead-210 concentration can be approximated
from U-nat content or ore grade, based on this assumption and the follow relationship:
Assuming the U-nat content is 84.8% of U30 8, and that the major contributor to activity is U-238, the
activity concentration of natural ore is approximately 12,350 Bq/g U (or 12,350 Bq/g x 27.0 pCilBq =
333,800 pCi/g U).
0.25% U30 8 x 84.8%U-nat x 12,350 Bq/g x 27.0 pCilBq = 708 pCi/g for each of the isotopes in
equilibrium with U-238.
This value is slightly lower than the approximate value of 825pCi/g (mistakenly typed as pCi/L) in
Section 2.6.1 of the April 2011 Amendment request. Nonetheless, the statement in that section that
the activities of Ra-226, Th-230 and Pb-21O of approximately 24.1 pCi/g, 20.7 pCi/g and 33.3 pCi Ig
Letter to Rusty Lundberg
June 14,2013
Page 14 of 35
(on a dry basis) are well below the activities associated with Colorado Plateau ores with grades of
0.25% U30 S is justified.
Specific Comment 2
Page 10, Section 3.3.3: Justify by furnishing additional documentation the assertion that "The five
volatile organic compounds detected ... in the Uranium Material have been attributed to laboratory
contamination ... "
EFRI Response to Specific Comment 2
Five Volatile Organic Compounds ("VOCs") were detected in the Uranium Material -four in the solids
samples and one in the TCLP leachate sample. Additionally, all five VOCs were detected in the
associated laboratory quality control blanks. Review of the site operational history, WTP processes, and
chemical history for the Midnite Mine WTP site, did not identify any potential source of these
constituents. There are no VOCs used in the mining processes or WTP processes and these chemicals
have never been used on the Midnite Mine WTP site or stored at the Midnite Mine WTP site. The
detections reported in the samples are not the result of Midnite Mine WTP site activities. The sample
results and laboratory quality control samples were reviewed in detail to determine the source of the
detections in the Uranium Material. Review of the analytical data indicated that the five VOCs were
detected in the laboratory quality control blanks, as presented in Table 3 and discussed below.
The table below summarizes the VOC detections in the laboratory quality control blanks.
Matrix
Reporting
Limit
Laboratory
Blank
VOCD t f
Table 3
I L b e ec Ions n a oratory QCBl k an s
Acetone Chloroform Methylene Toluene
ug/kg dry ug/kg dry Chloride ug/kg dry
ug/kg dry
Solid Solid Solid Solid
5 5 5 5
5.07 0.2* 1.95 1.57
Trichloroethene
ug/L
TCLP Leachate
5
3.3 J
* This detection is slightly below the method detection limit but was noted by the laboratory in correspondence which was
submitted in the April 2011 Amendment Request.
Acetone, chloroform, methylene chloride, toluene, and trichloroethene are common laboratory blank
contaminants. Methylene chloride and toluene are used as solvents in other organic analyses within the
laboratory (for example, toluene is used for herbicide analyses, and methylene chloride is used for
semivolatile organic analysis). Acetone is commonly used as a solvent for standards preparation and as
a cleaning agent for glassware. Chloroform is present in municipal water supplies and results from
chlorination of drinking water. Trichloroethene contamination is the result of standard volatilization,
Letter to Rusty Lundberg
June 14,2013
Page 15 of 35
cross-contamination from previous sample analysis, and contaminated laboratory chemicals used for
sample preparation.
These contaminants are spread throughout the laboratory environment quickly and easily due to their
extreme volatility. Because these solvents are ubiquitous in the laboratory environment they are often
detected in the VOC blanks as well as in the associated samples due to contamination present in the
laboratory environment.
The chloroform, methylene chloride, toluene and trichloroethene detections in the method blanks and
the Uranium Materials are all below the laboratory Reporting Limit ("RL") and are flagged "J";
estimated values. The sample data, showing the "J" values for these four compounds, are included as
Appendix C to this response letter. The values flagged as estimated or "J" values, are false positives,
caused by laboratory contamination as evidenced by their presence in the laboratory method blanks.
Method blank contamination is indicative of VOC presence in the laboratory.
The acetone detections reported in the blanks and the samples are not estimated and are reported at
levels above the RL; however, because acetone is used frequently in the laboratory the detections are
also indicative of laboratory contamination. The levels reported in the Uranium Material are reported at
concentrations routinely seen as the result of laboratory contamination. Industry practice for blank
contamination associated with common laboratory contaminants such as acetone is to consider sample
detections as false positives if the sample concentrations are less than 10 times the blank result,
particularly when interpreting data for VOCs for which there is no on-site source. In all of the Uranium
Material samples the acetone concentrations are less than 10 times the blank concentration, indicating
that the sample detections are the result of laboratory contamination.
Because there is no source for these VOCs at the Midnite Mine WTP site and because results associated
with method blank contamination are considered questionable, EFRI reasserts that these data are false
positives caused by laboratory artifacts.
Specific Comment 3
Page 17, Section 4.10.2(d): Estimate and document the range of "Derived Air Concentration" values
that might result from processing the proposed Uranium Material. State and justify the impact this
range of DACs might have on estimated worker exposures to airborne particulate matter.
EFRI Response to Specific Comment 3
The DACs for each Mill Area ("Circuit") involved in processing the proposed Uranium Material are
provided in Table 4, below, and compared with those for conventional ores and a number of other
alternate feed materials.
Section 4.1.2 of the Mill's approved Radiation Protection Manual addresses the factors taken into
account in calculation of DACs for alternate feed materials. In order to apply the procedures set out in
Section 4.1.2 of the Radiation Protection Manual to the calculation of specific DACs for specific
alternate feed materials, the Mill has developed an Excel spreadsheet for the calculation of such
Letter to Rusty Lundberg
June 14,2013
Page 16 of 35
DACs. Appropriateness of the assumptions and accuracy of use of the spreadsheet are confirmed by
an independent consultant as part of the Mill's ALARA audit process. The DACs listed in Table 4
result from use of the calculation spreadsheet and the following assumptions.
Conventional ores are assumed to have uranium daughter isotopes in secular equilibrium. Because
most alternate feed materials have been processed in one form or another prior to receipt at the Mill,
they are not assumed to have uranium daughter isotopes in secular equilibrium. As a result, DACs are
calculated separately for each alternate feed material for each applicable part of the Mill. In process
steps where conditions and material properties are the same for every feed (such as yellowcake
precipitation and packaging), the conventional ore DACs are applied to every alternate feed material.
Additional key assumptions are listed here:
• The DACs for inhalation of each radionuclide were taken from Appendix B of 10 CFR 20 for the
indicated solubility class;
• The assigned solubility classes for airborne alpha activity assume:
o conventional ores are insoluble,
o that 50% of dust in the leach area is from the precipitation area and 50% is from ore (due
to proximity),
o uranium is in soluble form in CCD, SX and Precipitation areas, and,
o yellowcake in the packaging area has mixed solubility based characteristics (from
Kalkwarf (1979))
• The DAC for tailings is adjusted for the recovery efficiency, nominally assumed at 95% (i.e.,
95% of uranium is recovered and the remaining 5% of the uranium and virtually all uranium
daughters remain with tailings);
'. Activity from the U-235 chain is not significant and can be, and is typically, ignored (see
discussion below); and
• Concentrations of Th-232 and its decay products are negligible and can be ignored.
Table 4
Derived Air Concentrations for Ores and Selected Alternate Feed Materials
Mill Area Dawn Conventional UF4 KF Regen Calcined Heritage
("Circuit") Mining Ore (based on Material Material
DAC Arizona Strip)
Ore 2.6E-1O 6.0E-ll 2.IE-1O 2.6E-1O 4.2E-1O l.3E-ll 4.4E-12
Leach 3.4E-1O 1.10E-1O 3.0E-1O 3.4E-1O 4.6E-1O 2.5E-ll 8.6E-12
CCD 3.9E-1O 1.2E-ll 2.9E-1O 3.9E-1O 4.2E-1O l.3E-ll 4.4E-12
SX 3.9E-1O 1.2E-ll 2.9E-1O 3.9E-1O 4.2E-1O 1.3E-ll 4.4E12
Precipitation 5.0E-1O 5.0E-1O 5.0E-1O 5.0E-1O 5.0E-1O 5.0E-1O 5.0E-1O
Packaging 2.2E-ll 2.2E-ll 2.2E-ll 2.2E-ll 2.2E-ll 2.2E-ll 2.2E-ll
Tailings 2.0E-ll l.7E-ll 1.7E-ll 1.7E-ll 1.7E-ll l.7E-ll 8.4E-12
As indicated in the Table 4 above, the Mill has processed ores and/or alternate feeds with DACs which
are lower (more restrictive) than the Dawn Mining Uranium Material by as much as two orders of
magnitude, depending on the plant area to which the DAC applies.
Letter to Rusty Lundberg
June 14,2013
Page 17 of 35
As a result, the existing radiation protection measures and standard operating procedures developed
for worker safety for the processing of natural ores and previous alternate feed materials are sufficient
for the processing of the Uranium Material. No additional personnel protective measures or safety
procedures will be required.
Specific Comment 4
Tab (Attachment) 2, Page 5 of 11: Provide historical testing results to demonstrate that the uranium
content has averaged 0.18% on a wet basis.
EFRI Response to Specific Comment 4
Attachment 5 to the April 2011 Amendment Request provides a Technical Memorandum by Tetra
Tech (April 27, 2011) titled Review of Chemical Contaminants in Dawn Mining Company Midnite
Mine (DMC) Uranium Material to Determine Worker Safety and Environmental Issues and Chemical
Compatibility at the Denison Mines White Mesa Mill. Table 3 of this Technical Memorandum
submitted with the April 2011 Amendment Request presents historical total WTP uranium material
testing data from 2003 through 2010.
These data show that natural uranium concentrations in the uranium material ranged from 19,000
mg/kg to 2,700 mg/kg on a wet weight basis. Historical analysis of the Uranium Material moisture
content identifies that gravimetric moisture content has ranged from approximately 79% to 87% on a
gravimetric basis and averaged 84.5% moisture (15.5% solids) between 2003 and 2008.
Table 3 of the April 2011 Amendment Request has been updated to show the measured moisture
content of the Uranium Material as produced from 2003 through 2008. In addition, this table has been
modified to present the maximum, minimum and average uranium concentration in the Uranium
Materials for this period on a wet weight basis. The percent uranium on a wet weight basis is
calculated by multiplying the dry weight uranium concentration by the percent solids as shown below:
Unat Cone. Dry Weight Basis (mg/Kg): 10,756 ( 2003-2008 Average)
Average Percent Solids (%): 15.5%
10,756 mg/kg x 0.155 = 1,667 mg/kg (wet weight basis)
1,667 mg/kg 7 Ix 106 mg/kg = 0.0017
0.0017 x 100 = 0.17%
U Conc. Wet Weight Basis (%): 0.17 %
The Uranium Material uranium concentration on a wet weight basis from 2003 through 2008 ranges
from 0.39% to 0.04% with an average of 0.17%, rather than the stated 0.18%.
Appendix D and Appendix E of this letter include an updated Table 3 for Attachment 5 of the April
2011 Amendment Request and a replacement page for Attachment 2, of the April 2011 Amendment
Request page 5 of 11 respectively.
Letter to Rusty Lundberg
June 14,2013
Page 18 of 35
Specific Comment 5
Tab 2, Page 7 of 11: Correct the discrepancies for Arsenic and Cadmium between values in the columns
and the values stated as the "Max".
EFRI Response to Specific Comment 5
The requested corrections have been made to Attachment 2 of the April 2011 Amendment Request
page 7 of 11 and a replacement page is included in Appendix F of this letter. In addition, Table 2 to
Attachment 4 of the April 2011 Amendment Request has been updated and a replacement page is
attached to this transmittal as Appendix G to this letter.
Specific Comment 6
Tab 2, Pages 8, 9, and 10 of 11: Add columns to each table indicating allowable concentrations for each
analyte (e.g., TCLP threshold values), where applicable.
EFRI Response to Specific Comment 6
The TCLP method simulates liquid flow thorough a solid material over time, such as water through
landfill material, waste rock, etc., which will result in leaching from the solid material into the liquid.
The method calls for the liquid solution to be sampled for constituents of concern, which are leached
from the solid. The resulting TCLP values are reported as concentration in the liquid leachate solution
and are reported in mg/L. If the TCLP extract contains anyone of the listed constituents in an amount
equal to or exceeding the concentrations specified in 40 CFR 261.24, the waste possesses the
characteristic of toxicity and may be a hazardous waste.
TCLP values specified in 40 CFR 261.24 have been added to the Attachment 2 of the April 2011
Amendment Request table on page 8 of 11 (Organics & Pesticides Analyses for RCRA Toxicity
Characteristics (TCLP)) as requested. The revised table from Attachment 2 of the April 2011
Amendment Request is included as Appendix H to this letter. However, the TCLP threshold values
have not been added to the Tables on pages and 9 and 10 of 11 (Uranium Material Analyses for RCRA
Hazardous Waste (Total Analyses)) as these Tables present concentrations of constituents in the solid
material and are reported in mg/kg. The TCLP threshold values (concentrations in leachates) are not
comparable to the total constituent values present in the Uranium Material solids.
The requested column indicating the TCLP threshold values have also been added Table 3 in
Attachment 4 of the April 2011 Amendment Request. The revised table has been included as Appendix
I of this letter.
It should be noted that source material, byproduct material, and special nuclear material are excepted
from the definition of hazardous waste, and are not subject to RCRA, even if they possess the
characteristics of hazardous waste [40 CFR 261.4(a)(4)].
Letter to Rusty Lundberg
June 14,2013
Page 19 of 35
Specific Comment 7
Tab 2, summary tables and Tab (Attachment) 4, Table 4 of the April 2011 DAR LAR:
a. Compare the range of concentrations of the following constituents that could occur in the
Uranium Material with reported ranges of concentrations of the same constituents present in
Colorado Plateau uranium ores typical of those that are accepted and processed at the Mill
and/or are reported to be present in typical uranium mill tailings in the Utah region (e.g.,
Abdelouas 2006; Morrison 1991; Meisch 1963):
• Barium (Ba); and
• Beryllium (Be)
Information in Abdelouas 2006, based on data from Morrison 1991, allows the following
comparison between the average chemical composition of uranium mill tailings from
different locations in Utah (for acid-leached uranium ores) and the Dawn Mining
Uranium Material:
Analytical Results of Dawn WTP
A verage Concentration in Utah Solids (p. 9 of 11 of Attachment 2 of
Analyte area uranium mill tailings LAR)
Ba 1,010 ug/g 7,200 -8,100 ug/g
(7,733 ug/g ave.)
Be Not Reported 33 -36 ug/g
(35 ug/g ave.)
Information in Miesch 1963 (Table 2) allows the following comparison between typical
(mean) chemical compositions of uranium ore from a uranium mine deposit and mill pulp
samples from over 200 mine sites on the Colorado Plateau and the Dawn Mining
Uranium Material:
A verage Concentration in Analytical Results of Dawn WTP
Colorado Plateau Uranium Solids (p. 9 of 11 of Attachment 2 of
Analyte Ores and Mill Pulp Samples LAR)
Ba 550 -750 ug/g 7,200 -8,100 ug/g
(7, 733 u~/g ave.)
Be -0.3 0-0.4 ug/g 33 -36 ug/g
(35 ug/g ave.)
The above information suggests that concentrations of beryllium and barium in the Dawn
Mining Uranium Material appear to be somewhat elevated compared to Colorado
Plateau-derived ores that may have been processed at the Mill and/or present in typical
uranium mill tailings in the Utah area. The same situation may occur relative to one or
Letter to Rusty Lundberg
June 14,2013
Page 20 of35
more other alternate feed materials previously accepted and processed at the Mill. The
implications of elevated Be levels in the Dawn Mining Uranium Material compared to
ores and other alternate feed materials previously processed at the Mill and with respect
to potentially applicable and relevant personnel health criteria should be further
assessed.
EFRI Response to Specific Comment 7a
As identified in Attachment 5, Table 6, Column A of the April 2011 Amendment Request (Cell 3
Historical Mill Tailings Composition and Uranium Material Comparison), Ba and Be concentrations in
alternate feed materials already approved and processed at the Mill have had concentrations higher than
those measured in the Uranium Materials. Specifically, Be concentrations in previous alternate feed
materials have ranged as high as 105 mg/kg (ppm) or three times higher than the upper range Be
concentrations in the Midnite Mine Uranium Material of approximately 36 mg/kg. Similarly, alternate
feed materials previously processed at the Mill have had Ba concentrations up to 43,000 mg/kg or an
order of magnitude higher than the upper range Ba concentration in the Uranium Material of
approximately 8,100 mg/kg. Therefore, there is no potential for a new or incremental increase in
personnel exposure risk from these constituents.
Barium chloride is used to treat radium in the Midnite Mine WTP influent water. In waters where
sulfate is present, radium is easily removed by addition of barium chloride: barium chloride dissolves
and in the presence of sulfate, the dissolved barium immediately re-precipitates as barium sulfate due to
its very low solubility (0.022 mg/L in cold water; Weast, 1987). Dissolved radium co-precipitates with
the barium sulfate (NEA & IAEA, 2002). In Midnite Mine WTP solids, Ba is present as barium sulfate
(BaS04). Once in the EFRI Mill circuit, barium sulfate will remain as barium sulfate due to its very low
solubility in concentrated sulfuric acid (0.025 mg/L; Weast, 1987).
The Be in the Uranium Material is derived from Be in uranium ores that has dissolved into the local
groundwater, which is then precipitated as part of the water treatment process described in the
application and Attachments 4 and 5 of the April 2011 Amendment Request. Lime softening is used at
the Midnite Mine WTP to precipitate heavy metals, including Be, with the metals precipitating in the
hydroxide form (Hendricks, 2006). In MMWTP solids, Be is present as beryllium hydroxide, Be(OH)z.
Be(OH)2 is insoluble in water but dissolves in sulfuric acid (NTP, 2011) forming beryllium sulfate,
BeS04 (Wiberg et al., 2001). Therefore, once in the EFRI Mill circuit, Be will be present as BeS04.
BeS04 is readily soluble in water (37 to 42.5 g/lOO mL) and has low solubility in concentrated sulfuric
acid (solubility does not exceed 2.5% in the range of 88 to 98 wt% sulfuric acid) (Walsh, 2009).
Analysis of tailings pore water in the Cell 2 slimes drain (MWH, 2010) indicates high sulfate
concentrations (60,600-74,000 mg/L) and low pH (3.11-3.28) conditions, indicating that BeS04
solubility in the tailings will be more comparable to the above-reported solubility in sulfuric acid.
Beryllium Toxicity
The low concentrations of Be in the Uranium Material do not pose a significant health and safety hazard.
The average measured Be concentration in the Uranium Material is between 33 and 36 parts per million
(ppm) as identified in Attachment 5, Table 6, Column B of the April 2011 Amendment Request. The
Letter to Rusty Lundberg
June 14,2013
Page 21 of 35
baseline Be concentration in the existing tailings is 0.5 ppm as identified in Attachment 5, Table 6,
Columns F and I of the April 2011 Amendment Request. The maximum estimated Be concentration in
mill tailings in Cell 4A during the ten year period evaluated would be 0.6 ppm as identified in
Attachment 5, Table 6, Column lOL of the April 2011 Amendment Request. The incremental
concentration attributable to the uranium material processing would be 0.1 ppm.
Beryllium is a toxic metal and a known carcinogen. The principal exposure pathways for beryllium from
Uranium Material are inhalation, ingestion and dermal contact. Inhalation can cause irritation to the
nose, throat, lungs and mucous membranes. In some individuals, possibly due to genetic factors, Be
may cause chronic beryllium disease ("CBD"), a hypersensitivity or allergic conditions causing
inflammation and fibrosis resulting in a restriction of the exchange of oxygen between the lungs and the
bloodstream (Materion, 2011). Beryllium can also be taken into the body by ingestion of water and food
or through the skin. Although skin absorption does not appear to be a major pathway, skin contact can
cause an allergic dermal response in sensitive individuals and skin contact with Be dusts can result in
sensitization (NIOSH, 2008). The solubility of the Be compound affects the toxicity. The more soluble
Be salts can cause irritant and allergic contact dermatitis. Delayed hypersensitivity dermal granulomas
may be caused by the less soluble forms of Be in contaminated wounds (Wambach, 2008).
The only potential complete exposure pathway at the Mill for members of the public is inhalation of
airborne particulate matter from the tailings. Engineered and administrative controls limit public access
at the Mill. The following analysis looks at public health limits from radioparticulates potentially
derived from wind transport of tailings particulates and assumes those levels of particulate transport with
the Be concentrations in the Uranium Material and subsequent tailings. These public exposure levels of
airborne Be are compared to the EPA reference concentration ("RfC") to assess the potential for adverse
public health impact from the Be in windblown tailings or uranium material.
The RfC, i.e., the concentration that is "likely to be without an appreciable risk of deleterious effects
during a lifetime", for Be is 0.02 !lg/m3 (EPA, 2013). Assuming a Th-230 concentration in the tailings
of 1,000 pCi/g and a 10 CFR 20 effluent limit of 2 x 10-14 !lCi/ml, the maximum allowable offsite
airborne particulate concentration attributable to tailings would be 40 !lg/m3. At the hypothetical
maximum off-site airborne particulate concentration of 20 !lg/m3, the maximum concentration of Be
attributable to the Uranium Material in those airborne particulates would be 2 x 10-6 !lg/m3 or a factor of
2,500 below the RfC. Therefore, processing the Uranium Material presents no significant risk to the
general public from Be in airborne particulates at levels that are protective from radiological
contaminants in all ores and tailings.
Occupational exposures might include skin, inhalation, and inadvertent ingestion. The concentrations of
Be in the Uranium Material and tailings solution are 36 ppm (Attachment 5, Table 6, Column B of the
April 2011 Amendment Request) and less than 1 ppm (Attachment 5, Table 6, Column lOL),
respectively. The New Hampshire Department of Environmental Services Beryllium Health
Information Summary notes that skin exposure to concentrated Be can result in allergic skin response
(NHDES,201O). Because of the very low concentrations in the Uranium Material and tailings, Be is not
likely to cause an allergic response from skin contact. The reported adverse effects on skin are generally
for the pure Be compounds or metal. In any case, the normally required personal protective equipment
Letter to Rusty Lundberg
June 14,2013
Page 22 of35
and safe work practices at the Mill facility would protect workers from direct contact with the Be in
uranium material, tailings, and mill process solutions.
Inadvertent ingestion is not likely to result in an individual exceeding the reference dose ("RID"). The
RID is an estimate of the daily oral intake for humans, including sensitive subgroups, that would not
result in "appreciable risk of deleterious effects during a lifetime" (EPA, 2013). The oral RID for Be is
0.002 mg/kg-day. Assuming a 70 kg adult worker and a Be concentration of 36 mg/kg in the uranium
material (Attachment 5, Table 6, Column B of the April 2011 Amendment Request), a worker would
have to "inadvertently" consume nearly 4 g of Uranium Material per day (0.002 mg/kg x 70kg adult +
36 mg/kg Be concentration = 4 g). The amount of uranium in the 4 g of Uranium Material (16,000
mg/kg [Table 5 of Attachment 5] = 0.016 gig x 4 g = 0.064 g = 64 mg Unat) far exceeds the regulatory
intake limit of 10 mg U-nat per week. As such, normal uranium mill work rules and existing controls
provide a reasonable assurance that neither the uranium nor the associated Be in the Uranium Material
would be inadvertently ingested at levels likely to cause significant occupational health risk.
The concentration of Be in workplace air resulting from Uranium Material airborne dust would be below
the OSHA Permissible Exposure Limit (PEL; 2 ).lg/m3) as long as the regulatory limits on airborne
uranium concentrations are met. The concentration of uranium material in airborne particulates that
would meet the 10 mg/week regulatory limit on intake.of oll1b le w'anium would be approximately 13
mg/m3 assuming a breathing rate of 1.2 m3/hour, a nonllal 40 hour work week and a uranium
concentration of 16,000 ppm. At 13 mg/m3 of soluble uranium the Be conoentration in airborne
particulates associated with the uranium material would be approximately 0.5 ~Lg/m a factor of 4
below the OSHA PEL of 2 ).lg/m3. It is unlikely that a worker would be exposed to airborne particulate
matter associated with the Uranium Material for 8 hours per day, 5 days per week. The concentration of
Be in tailings attributable to processing of the Uranium Material is estimated to be 0.1 ppm (Attachment
5, Table 6, Column 9M of the April 2011 Amendment Request); therefore, inhalation of tailings dust
would result in an even lower occupational exposure.
The above analysis demonstrates that there are no implications to potentially applicable and relevant
personnel health criteria from Be levels in the Uranium Material as compared to ores and other alternate
feed materials previously processed at the Mill. The existing controls and operating procedures that
have proven to be effective in maintaining radiological and non-radiological exposures from ores and
other alternate feed materials protective of public and occupational health will be equally effective for
the proposed Uranium Material.
References:
Hendricks, D.W. (2006). Water Treatment Unit Processes: Physical and Chemical. Boca Raton, Florida:
Taylor & Francis.
Materion. 2011. Beryllium Hydroxide Powder, Material Safety Data Sheet -No. D03. March 8, 2011.
MWH Americas (MWH). 2010. Revised Infiltration and Contaminant Transport Modeling Report,
White Mesa Mill Site, Blanding Utah. Prepared for Denison Mines. March.
Letter to Rusty Lundberg
June 14,2013
Page 23 of35
New Hampshire Department of Environmental Services (NHDES). 2010. Beryllium: Health
Information Summary (ARD-EHP-35). Accessed 4122/13 at
des .nh. gov /organization/commissioner/pip/factsheets/ard/ documents/ ard -eph -35. pdf
OECD Nuclear Energy Agency, International Atomic Energy Agency (Eds.). (NEA & IAEA). (2002).
Environmental Remediation of Uranium Production Facilities. Paris, France: OECD.
U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program
(NTP). (2011). Report of Carcinogens, Twelfth Edition.
U. S. Environmental Protection Agency (EPA). 2013. Integrated Risk Information System (IRIS).
Beryllium and compounds (CASRM 7440-41-7). Accessed at http://www.epa.gov/iris/subst/0012 htm
on 4120/13.
Walsh, K. (2009). Beryllium Chemistry and Processing. ASM International.
Wambach, P. F. and J. C. Laul. 2008. Beryllium health effects, exposure limits and regulatory
requirements. Journal of Chemical Health and Safety. Volume 15, Number 4.
Weast, R.c. (ed.). 1987. CRC Handbook of Chemistry and Physics, 68th edition.
Wiberg, N., Holleman, A.F. and E. Wiberg (Eds.). (2001). Inorganic Chemistry.
b. Discuss and compare the range of concentrations of the constituents listed in Specific
Comment a above in the Uranium Material to potentially applicable/relevant RCRA
hazardous waste!characteristic waste limits, EPA-recommended Soil Screening Levels
(SSLs), including updated recommended Risk-Based Concentration (RBC) levels (e.g., EPA
2012) for various types of soils issued by one or more EPA regional offices; relative to
current, relevant "action levels" established for protecting workers from exposure to
elevated levels of constituents in air, such as beryllium, etc ... ; and/or other criteria as may
be appropriate.
EFRI Response to Specific Comment 7b
The RCRA characteristic hazardous waste concentrations are based on the TCLP, and the
concentration thresholds in 40 CFR 261 Characteristic D List are TCLP values. The TCLP limit for
barium is 100 mglL. As described in the Technical Memorandum in Attachment 5 of the April 2011
Amendment Request, based on analytical testing, the Uranium Material does not exhibit the TCLP
characteristic for barium as defined in Table 1 of 40 CFR Part 261.24(b) (Table 3). No TCLP limit
has been established for beryllium.
The following table was extracted from the USEP A Pacific Southwest Region 9 Risk Screening Level
("RSL") Tables as updated in November 2012. (No comparable regulatory levels were identified for
Region 8.) The Soil Screening Levels ("SSLs") presented are based on an assumption of a post-
Letter to Rusty Lundberg
June 14,2013
Page 24 of 35
remediation industrial use scenario, carcinogenic target risk levels of 1 in one million (lxlO-6) and a
non-cancer hazard index of 1. The assumption of industrial use is extremely over conservative for the
Mill site which, in post-reclamation condition, will be transferred to the US Department of Energy for
oversight in perpetuity.
No carcinogenic target risk levels have been proposed for barium. As shown in the table, barium is
present in the Uranium Material at levels more than 20 times lower than the lowest SSL, that is, the
SSL based on a non-carcinogenic hazard index of 1.
Beryllium is present in the Uranium Material at a level 190 times lower than the SSL associated with
the acceptable chronic/cancer risk and approximately 55 times lower than the lowest SSL associated
with an acceptable non-carcinogenic risk.
Table 5
EPA Soil Screening Levels
Non-
Uranium Ingestion Inhalation Carcinogeni Ingestion Dermal Inhalation carcinogen
Material SL Dermal SL SL cSL SL SL SL ic SL
(mg!kg) TR=1.0E-6 TR=1.0E-6 TR=1.0E-6 TR=1.0E-6 HQ=1 HQ=1 HQ=1 HI=1
(mg/kg) (mg/kg) (mgIkg) (mg/kg) (mg!kg) (mg!kg) (mg/kg) (m2/lq~)
Barium 8,100 No limit No limit No limit No limit No limit
(8.IE+3) proposed proposed proposed proposed 2.0E+05 proposed 3.0E+06 1.9E+05
Beryllium
and 36 No limit No limit No limit
Compounds (3.6E+1) proposed proposed 6.9E+03 6.9E+03 2.0E+03 proposed 1.2E+05 2.0E+03
The concentration of barium and beryllium relative to occupational exposure guidelines is discussed in
detail in the response to Specific Comment 7 a, above. As concluded in that response, no additional
protective measures beyond those already in place at the Mill will be required.
c. Assess radiological and non-radiological impacts of releases from the facility to other media
(including release through air to adjacent uncontrolled lands) attributable to concentrations
in Uranium Material in excess of those previously authorized for receipt and processing at
the White Mesa mill. Demonstrate that the airborne effluent monitoring program is
adequately designed and implemented to ensure that acceptability of airborne releases to
adjacent areas will be known and reported.
As discussed in the April 2011 Amendment Request and in these Responses to Comments there are no
concentrations of in the Uranium Material of any constituent in excess of the concentrations in
alternate feed materials previously licensed for receipt and processing at the Mill. The airborne
effluent monitoring program which has been designed to comply with the requirements of Reg. Guide
4.14, and which has been in place during the processing of those previously approved alternate feed
materials, are appropriate for the Uranium Material.
Letter to Rusty Lundberg
June 14,2013
Page 25 of 35
Specific Comment 8
Discuss any additional requirements, activities, or measures that would be implemented at the White
Mesa Mill either during processing the Uranium Material, or following its processing, due to potentially
elevated concentrations of barium, and beryllium) compared to applicable and relevant risk or health-
based criteria (e.g., ACGIH 8-hr average TLVs or other recommended action levels, as applicable)
and/or compared to concentrations typically present in uranium ores processed at the Mill and/or
present in Utah-area uranium mill tailings (Abdelouas 2006; Morrison 1991; Meisch 1963). For
example, evaluate and discuss: (i) the potential need for additional controls to limit individual
exposures to elevated beryllium, etc ... levels that may be present in dust that could be released from the
Dawn Uranium Material prior to, during, or following its processing; and (ii) the possible need for
implementing more aggressive air sampling and/or material surface sampling criteria for elements such
as beryllium.
The concentration of barium and beryllium relative to occupational exposure guidelines is discussed in
detail in the response to Specific Comment 7a, above. As concluded in that response, no additional
protective measures beyond those already in place at the Mill will be required.
Specific Comment 9
Tab 4 and Tab 5: Provide credentials and summarize the experience of the author of these Technical
Memoranda to demonstrate that the author is qualified to draw the conclusions and make the
recommendations contained in Tab 4, Section 6 and on Tab 5, Pages 20 and 21. Provide documentation
(signature) attesting that the author has issued these memoranda.
EFRI Response to Specific Comment 9
The resume of the author of these Technical Memoranda is attached as Appendix J to this letter. Also
attached as Appendix K to this letter are copies of the memoranda signed by the author.
Specific Comment 10
Tab 5, Sections 4.3 and 8.1 of the April 2011 DAR LAR on pages 16-20:
a. Provide historical testing results to demonstrate that the stated ranges of concentrations
of nitrates, chlorides, fluorides, sulfates, and ammonia have been introduced into the
uranium circuit at the White Mesa Mill; and
EFRI Response to Specific Comment lOa
The following table summarizes levels of five specific constituents which have been introduced into
the Mill with previous alternate feed materials.
Letter to Rusty Lundberg
June 14,2013
Page 26 of 35
Table 6
Chemicals Present in Alternate Feeds
Chemical
Nitrates
Chloride
Fluoride
Sulfate in
Mill (Section
4.3)
Sulfate III
Tailings
(Section 8.1)
Ammonia
Value in Amendment
Request Tab 5, Section 4.3
or 8.1
350,000 mg/kg
89,900 mg/kg
460,000 mg/kg
300,000 mg/kg
No value listed in Tab 5,
Section 4.3 or Section 8.1.
No value listed in Tab 5,
Section 4.3 or Section 8.1.
Supporting or Additional
Information
35% (350,000 mg/kg) in Cameco
Regen Product alternate feed
Maximum sample from Molycorp
ponds alternate feed, 89,900 mg/kg
Honeywell/Converdyne/ Allied Signal
alternate feed, up to 2% U, 98%
calcium fluoride and fluoride
impurities (48% or 480,000 mg/kg F
based on all being as CaF2)
A 4.8 million pound (1.4 million
gallon) inventory of 93% (930,000
mg/kg) sulfuric acid is introduced into
the CCD and pre-leach steps during
conventional ore processing. (These
concentrations far exceed those
identified in Tab 5, Sections 4 .3 and
8.1 of the April 2011 Amendment
Request.)
64,900 to 267,000 mg/L in Cell 4A
solutions.
119,000 to 134,000 mg/L in Ce1l4B
solutions.
A 108,000 pound (31,000 gallon)
inventory of 100% anhydrous
ammonia is used to prepare
concentrated ammonia solutions
introduced into the yellowcake
precipitation area during conventional
ore processing. Ammonia in this form
is added far downstream of feed area
and is never in contact with ores or
feeds. (These concentrations far
exceed those identified in Tab 5,
Sections 4 .3 and 8.1 of the April
2011 Amendment Request.)
Source
Section II of Regen
Product MSDS, in
Appendix L of this
letter.
TILC table (in
Appendix M of this
letter) from
December 2000
Molycorp
Amendment Request
MSDS for CaF2
product, in Appendix
N of this letter.
Mill process
description, 1991
RMLrenewal
application and 2007
RMLrenewal
application
2012 Annual
Tailings Cells
Wastewater
Sampling Report, in
Appendix 0 of this
letter.
Mill process
description, 1991
RMLrenewal
application and 2007
RMLrenewal
application
b. For review/documentation purposes, please provide an updated geomembrane
manufacturer's product performance sheet listing chemicals and their chemical
Letter to Rusty Lundberg
June 14, 2013
Page 27 of35
compatibility criteria for an HDPE geomembrane liner that is representative of the
HDPE liners installed in Cells 4A and 4B.
EFRI Response to Specific Comment lOb
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. Cells 4A and 4B are constructed of 60 mil high
density polyethylene ("HOPE") manufactured by GSE and installed by Geosyntec Inc. The
manufacturer's material product performance information, including a chemical resistivity list, is
provided in Appendix P. Manufacturers generally do not include specific metal cations in chemical
resistivity lists since synthetic liners are generally compatible (resistive to) metals, metal halide salts,
and many other metal salts in all proportions.
Specific Comment 11
Reference Section 4.6 and Section 8.1 of Attachment 5 to the LAR (Application by Denison Mines (USA)
Corp. ('Denison ') for an amendment to State of Utah Radioactive Materials License No. 1900479 for
the White Mesa Mill (the "Mill") from Dawn Mining Corporation ("DMC") Midnite Mine to process an
Alternate Feed Material (the "Uranium Material") dated April 27, 2011):
a. Provide additional information, including reference citations, to justify and support the
identification of an appropriate revised range of values of the distribution coefficient (Kd)
for barium for representing conditions at the White Mesa Mill Site, including the tailings
environment in particular. Provide a discussion of how such a revised range of barium
KdS impacts the potential for barium to negatively affect groundwater
beneathldowngradient of the tailings cells into which processed Uranium Material
residuals would be placed. State and justify how the range of pH observed and expected
in White Mesa tailings might affect the range of Kd values for barium for the processed
Uranium Material residuals introduced into the tailings.
b. Provide additional information and one or more reference citation(s) to support the
statement included in this section indicating that barium would be sufficiently
represented by monitoring (groundwater) for calcium.
c. Provide additional information regarding the need to add barium as an additional
monitoring parameter in the facility's groundwater monitoring plan, especially given
that, under acid conditions, some (otherwise) water-insoluble barium compounds (e.g.,
barium sulfate) may become soluble and move into groundwater (e.g., see US EPA,
1984), and given the Groundwater Quality Standard value of 2 mg/l included in UAC
R317-006.
Section 4.6 of the Request to Amend Radioactive Materials License, Denison Mines USA
Corp. White Mesa Uranium Mill, San Juan County, Utah, and Environmental Report
includes a statement that the distribution coefficient (Kd) for barium is 100 to 150,000
L/kg for sandy to clayey soil types and that Denison therefore concludes that barium
Letter to Rusty Lundberg
June 14,2013
Page 28 of35
would be less mobile in groundwater than calcium. No reference sources are cited to
support either the Kd range stated or the conclusion made regarding the relative mobility
of barium compared to calcium, for conditions occurring at the White Mesa tailings Cells
4A and 4B. Kennedy et al. (1992; Table 6.7), for example, lists a Kd value of 52 mUg for
barium. EPA 2012 (Section 4.11 and Exhibit C-4 of Appendix C) provides a range of
recommended Kd values for barium as afunction of pH (e.g., Kd = 52 mUg at pH = 8.0,
Kd = 41 mUg at pH = 6.8, etc ... , with Kd values decreasing with decreasing pH; the Kd
value at pH = 4.9 is listed as 11 mUg.) Allison 2005 referenced several citations
reporting soil/water Kd values of barium all less than 10 Ukg, and cited several risk
assessment studies that used Kd values ranging from 11 to 52 Ukg. By comparison, the
UDEQ Statement of Basis for the Groundwater Discharge Permit indicates assumes Kd
values for calcium ranging from 5 to 100 Ukg (i.e., equal to or higher than those
reported in the above references for barium).
Additionally, EFR has not provided information to describe or substantiate how the
mobilization behavior for barium that may be expected to occur in the (e.g., acidic)
tailings and the near-field tailings embankment environment may differ from, or be
similar to, that of calcium. EPA (1984), for example, reported that barium, when
present in the form of barium sulfate in soils, is not expected to be very mobile because of
the formation of water-insoluble salts and its inability to form soluble complexes with
humic and fulvic materials, but noted, however, that, under acid conditions, some of the
water-insoluble barium compounds (e.g., barium sulfate) may become soluble and move
into groundwater.
EFRI Response to Specific Comment 11a, b, and c
Introduction of the Uranium Material into the Mill's tailings impoundments would substantially increase
the amount of barium currently stored (See response to Specific Comment 7). Barium is present in
Midnite Mine WTP solids at concentrations in the range of 7,200 -8,100 ug/g with barium present
primarily as barium sulfate. Barium sulfate is one of the most insoluble sulfate salts: the solubility of
barium sulfate in cold water is 0.022 mg/L and in concentrated sulfuric acid only increases to 0.025
mg/L (Handbook of Chemistry and Physics, 68th Edition). Geochemical modeling with the
PHREdoxEQulibrium ("PHREEQC") modeling tools using this solubility data and the geochemical
conditions present in the Mill tailings (average tailings sulfate concentration of 65 gIL) predicts that
barium from the Uranium Material will remain stable in the tailings impoundment as the solid phase
barium sulfate, and would not be expected to dissolve. Given the low solubility of barium sulfate,
especially in the presence of sulfate, there is, therefore, no reasonable potential for barium to migrate
from the tailings into groundwater.
A search of available literature regarding barium distribution coefficients (~), including the references
provided in DRC's comment, above, revealed that the barium ~ can range from 0.3 to 164,000 Llkg for
a variety of geologic materials, with lower values (less than 2,800 Llkg) being more typical for soils and
sediments, and lower ~ values measured with decreasing pH (Table 7).
Letter to Rusty Lundberg
June 14,2013
Page 29 of35
EFRI's request to amend the RML (Denison, 2011) indicated barium Kd values in the range of 100-
150,000 Llkg for sandy to clayey soils (Lintott and Tindall, 2007). Detailed review of this reference
indicates that the high ~s reported in this reference are for pure clay. ~s on the order of 1-390 Llkg
were measured for three sandy loams, and all tests were performed at a pH range of 7.7-8.3. Rai et aL
(1984) provide a range in ~ for sediments from 530-2,800 mL/g at pH 8. The references provided by
UDEQ (Kennedy et aI., 1992, EPA, 2002 and Allison, 2005) all indicate barium ~s in the range 1-52
mLlg, with ~ decreasing with decreasing pH. Thibault et aL (1990) reports ~s in the range of 0.3-9.3
mLlg, also with ~ decreasing with decreasing pH.
Considering the low solubility of barium sulfate, there is no reasonable expectation that barium would
be released from the tailings into groundwater. Further, the range in barium ~ has considerable overlap
with the range in calcium ~ (as reported in the DRC Statement of Basis for the Groundwater Discharge
Permit ("GWDP"): 5 -100 Llkg). Given the comparable ~s for calcium and barium, if a hypothetical
change in geochemical conditions were to occur causing the groundwater barium concentration to
increase, a concomitant increase in calcium concentration would also be expected to occur. Therefore,
barium does not need to be added to the list of analytes that is to be monitored at the site and that
groundwater calcium concentration can be used as an indicator of barium concentrations: if an
increasing trend in calcium concentration is observed, analysis for barium may, at that time, be
considered.
Further, the Mill monitors for a number of other dissolved constituents, such as chloride, fluoride, and
sulfate, each of which is an anion that is expected to have a higher mobility in groundwater than a cation
such as barium. These anions can be used as indicators of potential tailings cell seepage, and because of
their mobility, as 'early warning' indicators for less mobile constituents such as barium. Chloride in
particular is a conservative solute that is not retarded with respect to groundwater flow. As discussed in
Davis and DeWiest (1966) "All chloride salts are highly soluble, so chloride is rarely removed from
water by precipitation except under the influence of freezing or evaporation. Chloride is also relatively
free from effects of exchange, adsorption, and biological activity. Thus, if water once takes chloride into
solution, it is difficult to remove the chloride through natural processes."
Table 7. Literature Search of Barium ~s
Material pH Kd Reference
Clay 7.7-8.3 -1 -164,000 Llkg Lintott & Tindall, 2007
Sandy Loam 7.7-8.3 1-390 LIk& Lintott & Tindall, 2007
Sediment 8 530-2,800 mL/g Rai et aL (1984)
HFO Not specified 1.8-3.7 mL/g Allison et al. (2005); Table 7
Soil Not specified 11-52 mLig Allison et aL (2005); Appendix
A
Soil Not Specified 52 mLiK Kennedy et aL (1992)
Soil 4.9-8.0 11-52 Llkg EPA (2002); Exhibit C-4*
Sand 4.8 0.4-0.5 mL/g Thibault et aL (1990)
Smectite Clay 7.5-7.8 0.3-9.3 mLig Thibault et aL (1990)
* EPA (2002) provIdes pH-dependent ~ values; values shown III table are for the two extreme pHs prOVIded.
Letter to Rusty Lundberg
June 14,2013
Page 30 of35
REFERENCES:
Allison, J.D. and T.L. Allison. 2005. Partition Coefficients for Metals in Surface Water, Soil, and Waste.
U.S. Environmental Protection Agency, Office of Research and Development, Washington, DC
(EPN600/R-OS/074). July.
Davis, S.N. and R. J. M. DeWiest. 1966. Hydrogeology. John Wiley and Sons, 463 p.
Denison Mines (USA) Corp (Denison). 2011. Request to Amend Radioactive Materials License Denison
Mines (USA) Corp. White Mesa Uranium Mill San Juan County, Utah and Environmental
Report. Prepared for Utah Department of Environmental Quality. April.
Kennedy, W.E. and D.L. Strenge. 1992. Residual Radioactive Contamination from Decommissioning -
Technical Basis for Translating Contamination Levels to Annual Total Effective Dose
Equivalent. Final Report, NUREG/CR-SSI2, PNL-7794, Vol. 1. October.
Lintott, D. and M. Tindal. 2007. Estimation of a Generic Adsorption Coefficient Kd for Barium.
Prepared for BC Upstream Petroleum Environmental Task Group. July 3.
Rai D, Zachara JM, Schwab AP, et al. 1984. Chemical attenuation rates, coefficients, and constants in
leachate migration. Vol. I: A critical review. Palo Alto, CA: Electric Power Research Institute, 6-
1 to 6-6. Report EA-3356.
Thibault, D.H., M.1. Sheppard and P.A. Smith. 1990. A Critical Compilation and Review of Default Soil
Solid/Liquid Partition Coefficients, ~, for use in Environmental Assessments. Atomic Energy of
Canada AECL-lO 125.
United States Environmental Protection Agency (USEPA). 2002. Supplemental Guidance for
Developing Soil Screening Levels for Superfund Sites. OSWER 9355.4-24. December.
Weast, R.C. (ed.). 1987. CRC Handbook of Chemistry and Physics, 68th edition.
Specific Comment 12
Filter Press Pilot Testing Report: The report should include a log of all tests and test results so that the
Division can independently review and evaluate them.
EFRI Response to Specific Comment 12
The Filter Press Pilot Testing Report, which was included in the December 2012 Supplemental
Information (the "Report"), was developed for the EPA to assess technologies to reduce the waste
volumes trucked from the Midnite Mine to disposal facilities. In June 2010, a dewatering test was
performed on the Midnite Mine WTP sludge using a bench-scale plate filter. In order to provide
additional detail regarding topics such as the percent solids of final filter cake, sizing of the sludge
Letter to Rusty Lundberg
June 14,2013
Page 31 of 35
steady head tank, and number of press cycles per day, a pilot-scale filter press was leased and operated
and the resulting filter cake analyzed, as described in the Report.
All relevant data collected in the field and from the laboratory are included in the Report text or tables
which were submitted in December 2012. The tables present the tests performed, the test conditions,
parameters, durations and the results of those tests. As described in the Report, field determination of
percent dry solids was performed using a Seiko Moisture Analyzer, model DSH-50-1O. Because the
analyzer directly reports the percent solids, little intermediate data (% moisture, tare weight, etc.) were
recorded. The difference in analyses between the Seiko analyzer and the laboratory results is due to the
much longer drying time specified by the laboratory analytical method. No additional logs or data are
available or necessary to understand or review the tests performed.
Specific Comment 13
Filter Press Pilot Testing Report: Page 3: Please discuss the relationship between the equipment used to
perform the pilot tests reported in the document reviewed and that to be used in producing the filter cake
that will actually be shipped to the White Mesa Uranium Mill for processing as alternate feed material.
Describe differences in equipment that might affect the physical or radiological [properties of the filter
cake shipped for processing. Describe measures that will be taken and documentation that will be
provided to ensure that characteristics of filter cake shipped to White Mesa will not diverge in a
substantive way from those reported in the pilot testing report.
EFRI Response to Specific Comment 13
The tests presented in the Report develop a reasonable range of Uranium Material characteristics and
properties (e.g., moisture, density, metals and radionuclide content) that encompass and reasonably
bound the material variability expected due to differences in filter equipment between the pilot test and
full scale operations. The Uranium Material density ranged from 1.16 glcc (72.4 Ib/ft3) to 1.34 glcc
(83.6Ib/ft3) and moisture content varied from 59.3% to 65.4%.
There are no significant differences between the pilot-testing equipment and full-scale equipment, with
the exception of the equipment size. Both the pilot-and full-scale presses use membrane squeeze and
similar pressures for the membrane squeeze and residual material slurry feed. It is estimated that
approximately 10 filter press runs will be performed per each approximate 20 cubic yard shipment. A
Seiko (or similar) field moisture analyzer will be used to test for moisture content of the filter cake.
Composite filter cake field moisture content will be measured on a minimum of three filter press runs
per shipment. Grab samples from the selected filter press runs will be compo sited and an average
moisture content determined for each shipment from this composite sample. The number of filter press
run samples used for each composite sample and the measured moisture content will be recorded on the
attached Filter Press Moisture Content log sheet and a copy of the sheet will provided with the shipping
papers of each shipment. If significant variability in composite moisture content is observed (Le., greater
than 15% moisture content between filter press runs) or if the moisture content is greater than 70%, filter
cake will be tested more frequently for moisture content prior to shipping.
Letter to Rusty Lundberg
June 14,2013
Page 32 of35
Specific Comment 14
Filter Press Pilot Testing Report: Page 4: The meaning of the phrase "extremely competent" is not
clear and should be revised to eliminate ambiguity and clearly communicate the characteristics of the
cake that was tested.
EFRI Response to Specific Comment 14
The phrase " ... extremely competent, ... " on page 4 of the referenced report is intended to indicate that
the materials are dry, hard, and difficult to break with hand pressure. It is proposed that this clarification
is sufficient and that the Report not be re-issued with this minor modification.
Specific Comment 15
Filter Press Pilot Testing Report: Page 9, Table 3, and Laboratory Report: The contradictory results
reported for Thorium-233 concentrations should be resolved (page 9 and Table 3 indicate the Th-233
concentration to be 2.7 pCi/g while the Laboratory Report (page 5 of 15) indicates 2.4 pCi/g
EFRI Response to Specific Comment 15
We believe that the Th-230 results are correct as stated in the report. The laboratory report on page 5 of
the Report shows a Th-230 concentration of 2.7 pCi/g and a minimum detectable concentration of 2.4
pCi/g.
Specific Comment 16
Filter Press Pilot Testing Report: Laboratory Report, Table 3: Describe how the values of the
parameter named "Solids -Calculated (Lab)" were determined. Provide calculations prepared for
each value reported. Explain the significance of differences between values reported for "Solids -
Calculated (Lab)" andfor "Solids -Field (Avg)".
EFRI Response to Specific Comment 16
The values of the "Solids -Calculated (Lab)" were determined by taking 1 00% and subtracting the
Percent Moisture (laboratory reported value). For example, Test #2, Table 3.0, the laboratory result for
percent moisture was 63.5%, subtracting from 100, the percent solids would be 36.5%.
The calculations for each test on Table 3 are as follows :
• Test #2 100% -63.5% (laboratory reported percent moisture) = 36.5% (calculated percent solids)
• Test #3 100% -65.4% (laboratory reported percent moisture) = 34.6% (calculated percent solids)
• Test #5 100% -59.3% (laboratory reported percent moisture) = 40.7% (calculated percent solids)
• Test #6 100% -64.1 % (laboratory reported percent moisture) = 35.9% (calculated percent solids)
Letter to Rusty Lundberg
June 14,2013
Page 33 of35
As stated on page 4, second paragraph, "The difference in analyses between the Seiko analyzer and the
laboratory results is due to the much longer drying time specified by the laboratory analytical method."
The Seiko analyzer uses an automatic mode to determine when a sample is dry by measuring the
difference in weight over a period of time. This automatic mode can be adjusted to allow a longer
drying time.
Specific Comment 17
Filter Press Pilot Testing Report: Laboratory Report: Please provide documentation and other evidence
that identify relevant laboratory certifications held by Energy Laboratories.
EFRI Response to Specific Comment 17
Attached to this letter as Appendix Q, are the following documents identifying relevant certifications
held by Energy Laboratories related to testing performed for the Uranium Material studies.
• National Environmental Laboratory Accreditation Program (NELAP based on accreditation by
State of Florida)
• EPA Region VIII, Drinking Water Contaminants
• Utah Environmental Laboratory Certification Program
Specific Comment 18
Tab (Attachment) 5, Table 6: Please verify the accuracylcorrectness of calculations and/or explain as
appropriate (in a revised updated version of Section 8.0 of Attachment 5) the significance of
computational results listed for certain constituents in Table 6 of Attachment 5 to the April 27, 2011
Amendment Request. The projected percentages of the total mass in the tailings disposal cells after
completion of processing of the Uranium Material (processing of shipments of the DMC Uranium
Material periodically received over a 10-year period) contributed by some constituent inventories (e.g .,
barium, copper, manganese, silver, beryllium, calcium, etc ... ) appear to be relatively high.
EFRI Response to Specific Comment 18
Attachment 5, Table 6 of the April 2011 Amendment Request has been reviewed and the
accuracy/correctness of the calculations have been verified. Although the projected percent total
contributed to the tailings of the constituents mentioned by the reviewer are between 5 and 100 percent,
the estimated mass contributed to the tailings from these constituents is less than 0.02% of the estimated
mass in the tailings cell. Revised text for Section 8 of Attachment 5 of the April 2011 Amendment
Request is included as Appendix R of this letter.
References
NRC,1979 US Nuclear Regulatory Commission (NRC). Regulatory Guide 8.21, Health Physics
Surveys for Byproduct Material at NRC Licensed Uranium Processing and Manufacturing Plants.
Revision 1. October, 1979.
Letter to Rusty Lundberg
June 14,2013
Page 34 of35
NRC,1980 US Nuclear Regulatory Commission (NRC). Regulatory Guide 4.14, Radiological
Effluent And Environmental Monitoring At Uranium Mills. Revision 1. April, 1980.
USGS, 2001 US Geological Survey, Environmental Canada Climate Information Branch, National
Water Conditions. pH of Precipitation for November 26-December 23, 2001.
J11Lp:/lwaler.us_ .gov/nwc!NWC/pWhllul/ph.hunJ
Letter to Rusty Lundberg
June 14,2013
Page 35 of35
If you have any questions, please contact me at [phone].
~UJY~
ENERCY FUELS RESOURCES (USA) INC.
JoAnn Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Ryan Johnson, Utah DRC
Ronnie Nieves
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
Figure
Appendix A
Technical Evaluation Report For NRC License Amendment 7
TECHNICAL EVALUATION REPORT
DOCKET NO. 40-8681 LICENSE NO. SUA-1358
DATE: August 21,1998
LICENSEE: International Uranium (USA) Corporation
FACILITY: White Mesa Uranium Mill
PROJECT MANAGER: James Park
TECHNICAL REVIEWER: Duane Schmidt
SUMMARY AND CONCLUSIONS:
As part of its corrective actions taken in response to a Notice of Violation (NOV) issued by NRC
on August 12, 1997, International Uranium (USA) Corporation (IUC) requested an amendment
to Source Material License No. SUA-1358 for the White Mesa uranium mill. By letter dated
December 3,1997, IUC requested approval of a proposed modification to the in-plant air
monitoring program committed to in its approved license application. IUC provided additional
information by letter dated March 23, 1998, in response to comments received from the NRC
staff.
The staff has reviewed IUC's proposal and found it acceptable with slight modifications. These
modifications were discussed with IUC and agreed to in a telephone call on July 20, 1998.
DESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:
By letter dated December 3, 1997, IUC requested an amendment to SUA-1358 to modify
in-plant air monitoring commitments made in its approved license application. IUC's request
was part of its corrective actions taken in response to an NOV issued by the NRC on August
12,1997, as a result of the staffs routine inspection of the White Mesa mill on July 15-17,1997.
By letter dated March 23, 1998, IUC provided additional information in response to a
February 13, 1998, written request from the NRC staff.
By its submittals, IUC proposed that License Condition 11.4 of SUA-1358 be revised, in part, to
require that (1) annual air samples be taken, during operational periods, in routinely or
frequently occupied areas and analyzed for gross alpha radioactivity, and (2) isotopic analyses
of operational mill feed or production product be performed for natural uranium, thorium-230,
radium-226, and lead-210 to assess the composition of air particulates.
Depending on the results of the isotopic analyses, derived air concentration (DAC) values would
be determined for different mixtures of radionuclides, with the result that various areas in the
mill would have a DAC value applied that is most appropriate for the radionuclide mixture likely
to be present in air samples in that area. IUC considers that the mill site can be separated into
Enclosure 1
four areas for this purpose: (1) the ore handling and storage area, where uranium and its
progeny is expected to be in equilibrium; (2) the uranium precipitation circuit, where only soluble
uranium is expected to be present; (3) the uranium drying, packaging, and calciner area, where
only uranium in a moderately insoluble form would be present; and (4) the tailings area, where
uranium and its progeny would be present in disequilibrium, as separation has been attained.
IUC stated that approval of its proposed modifications will result in the collection of more
meaningful isotopic data than that currently collected, and at a reduced expense to the
company.
TECHNICAL EVALUATION:
Currently, in its approved license application, IUC has committed to taking an annual
eight-hour, in-plant airborne radioactivity sample and analyzing the sample for natural uranium,
thorium-230, radium-226, lead-210, and polonium-210. In accordance with License Condition
No. 11.4, IUC is authorized to eliminate this annual sample, during extended periods of mill
standby, if routine airborne sampling show levels below ten percent of the appropriate 10 CFR
Part 20 limits.
At issue in the licensee's proposal is an appropriate method for performing measurements to
determine the isotopic composition of the airborne radioactive particul~tes in plant areas to
which workers are, or may be, exposed. As a result of the uranium extraction process in the
mill, the concentrations of the airborne radioactive particulates are expected to vary around the
mill. Appropriate area-specific DACs (based on the mixture of radionuclides present) can be
used (1) to determine whether measured air particulate concentrations (often gross alpha
measurements) are acceptable, and (2) in the determination of worker radiation exposures.
These determinations are necessary primarily for the licensee to ensure compliance with the
worker dose limits of 10 CFR Part 20, Subpart C.
IUC believes that the ability to sample much larger quantities of the mill feed or product
materials would provide at least as accurate information regarding the radionuclide composition
of potential airborne contaminants as does the current air sampling method. The NRC staff
agrees that the larger sample sizes possible with the proposed method should improve the
validity of the results on radionuclide composition.
The staff also considers that the sampling of the mill feed materials should allow for the early
identification of materials that are significantly different, in terms of radionuclide composition,
from natural ores processed at the mill, an issue of some importance considering the
processing of alternate feedstock materials. As a result, IUC would be able to evaluate the
need for changes to DAC values for various areas of the plant commensurate with the material
being processed. Thus, the NRC staff concludes that the proposed approach should be valid
for the purpose of determining DAC values for the different areas of the mill. The staff cautions
that the use of this approach depends on accurate determinations, in advance, of how the
isotopic composition of the mill feed and product may impact the isotopic composition of air
particulates in the different mill areas.
2
A second issue with the proposed license amendment is the appropriateness of the proposed
approach for extended periods of mill standby. IUC did not specifically address this issue in its
submittals. However, during mill standby, there would be no mill feed or product to sample.
Thus, it appears to the NRC staff that, if isotopic results are needed for DAC or dose
calculations during periods of standby, the licensee can make use of previously determined
values, or base calculations on other knowledge of the likely airborne contaminants during
standby conditions. Such an approach would generally be acceptable.
Finally, approval of this request will not impact the regular weekly and monthly in-plant radiation
monitoring conducted by IUC.
Therefore, the staff finds IUC's proposed approach to be acceptable. However, the staff
considers that an annual analysis of mill feed or product materials may not be frequent enough,
in light of IUC's past and anticipated future processing of various alternate feed materials in
addition to natural uranium ore. Therefore, the staff will require that IUC perform an isotopic
analysis of mill -feed or product materials any time a new feed material is introduced into the mill
process. IUC agreed to this modification by telephone on July 20, 1998.
RECOMMENDED LICENSE CHANGE:
License Condition 11.4 of SUA-1358 will be modified, in part, as follows:
Annually, the licensee shall collect, during mill operations, a set of air samples covering
eight hours of sampling, at a high collection flow rate (Le., greater than or equal to 40
liters per minute), in routinely or frequently occupied areas of the mill. These samples
shall be analyzed for gross alpha. In addition, with each change in mill feed material or
at least annually, the licensee shall analyze either the mill feed or production product for
U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the
fundamental constituent composition of air sample particulates.
[Applicable Amendment: 7]
ENVIRONMENTAL IMPACT EVALUATION:
Because this change in IUC's in-plant radiation monitoring program will not result in
(1) a significant change or increase in the types or amounts of effluents that may be released
offsite; (2) a significant increase in individual or cumulative occupational radiation exposure;
(3) a significant construction impact; or (4) a significant increase in the potential for or
consequences from radiological accidents, an environmental review was not performed since
actions meeting these criteria are categorically excluded under 10 CFR 51.22(c)(11).
3
Appendix B
Revised Amendment Request Text
REQUEST TO AMEND
RADIOACTIVE MATERIALS LICENSE
DENISON MINES (USA) CORPENERGY FUELS RESOURCES (USA)
INC .
WHITE MESA URANIUM MILL
SAN JUAN COUNTY, UTAH
AND
ENVIRONMENTAL REPORT
for Processing of
Alternate feed Material from
Sequoyah Fuels Corporation
Prepared for:
Utah Department of Environmental Quality
Division of Radiation Control
P.O. Box 144850
Salt Lake City, UT 84114·4850
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, S~ite 950,
Denver, CO 80285
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
April 2011 May 2013
Denisan MinesEnergy Fuels Resources (USA) ~Inc.
TABLE OF CONTENTS
1.0 INTRODUCTION ............................................................................................................................................. 1
1.1 White Mesa Mill ........................................................................................................................................ 1
1.2 Proposed Action ....................................................................................................................................... 1
1.3 Purpose of Action ..................................................................................................................................... 1
1.4 Amendment Application and Environmental Report ................................................................................. 1
2.0 MATERIAL COMPOSITION AND VOLUME ................................................................................................... 2
2.1 GeneraL .................................................................................................................................................... 2
2.2 Historical Summary of Sources ................................................................................................................ 3
2.4 Radiochemical Data ................................................................................................................................. 6
2.5 Physical and Chemical Data ............................................ , ........................................................................ 6
2.6 Comparison to Other Ores and Alternate Feed Materials Licensed for Processing at the Mill ................. 6
2.6.1 Ores and Alternate Feed Materials With Similar Radiological Characteristics ......................................... 6
2.6.2 Ores and Alternate Feed Materials With Similar Chemical/Metal Characteristics .................................... 7
3.0 REGULATORY CONSiDERATIONS .... , .......................................................................................................... 8
3.1 Alternate Feed Guidance ......................................................................................................................... 8
3.2 Uranium Material Qualifies as "Ore" ......................................................................................................... 8
3.3 Uranium Material Not Subject to RCRA ................................................................................................... 8
3.3.1 GeneraL .................................................................................................................................................... 8
3.3.2 EFRI/UDEQ Listed Hazardous Waste Protocol.. ...................................................................................... 9
3.3.3 Application of the Listed Hazardous Waste Protocol.. .............................................................................. 9
3.3.4 Analysis for RCRA Characteristic Waste ................................................................................................ 10
3.3.5 Radioactive Material Profile Record ....................................................................................................... 10
3.3.6 Conclusion .............................................................................................................................................. 10
3.4 Uranium Material is Processed Primarily for its Source Material Content .............................................. 10
4.0 ENVIRONMENT AFFECTED .................................................................................................................... 12+4·
4.1 GeneraL .............................................................................................................................................. 124+
4.2 Transportation Considerations ........................................................................................................... 124+
4.2.1 Packaging and Mode of Transportation .............................................................................................. 12+1-
4.2.2 Transportation Impacts ....................................................................................................................... 13:t.2
4.3 Storage ............................................................................................................................................... 144a
4.3.1 Manner of Storage .............................................................................................................................. 14+d
4.3.2 Environmental Impacts Associated With Storage ............................................................................... 14+3
4.4 Process .............................................................................................................................................. 144a
4.5 Compatibility with EFRI Mill Tailings ................................................................................................... 15-14
4.5.1 Physical Compatibility ........................................................................................................................ 1544
4.5.2 Capacity and Throughput ................................................................................................................... 16-1-a
4.6 Groundwater ....................................................................................................................................... 1S+e
4.7 Surface Water .................................................................................................................................... 17·1-6
4.8 Airborne Radiological Impacts ............................................................................................................ 1746
4.9 Radon and Gamma Impacts ............................................................................................................... 174-6
4.10Safety Measures ................................................................................................................................ 1 B+1
4.10.1 General .......................................................................................................................................... 18+7
4.10.2 Radiation Safety ............................................................................................................................ 184+
4.10.3 Occupational Safety ...................................................................................................................... 18+7
Request to Amend Radioactive Materials License
QeRiSGR-MffiesEnergy Fuels Resources (USA) ~Inc.
4.10.4 Vehicle Scan .................................................................................................................................. 19+8
4.11 Long Term Impacts .................................. " ........................................................................................ 19+8
4.120ther Information ............................................................................................................................... ~+8
4.13Added Advantage of Recycling .......................................................................................................... 19+8
4.14Consideration of Alternatives .............................................................................................................. 19+8
5.0 SiGNATURE .............................................................................................................................................. 20+9
6.0 REFERENCES ................................................................................................ .-......................................... f.12G
Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5
ATTACHMENTS
Midnite Mine Site Location
Radioactive Material Profile Record and Affidavit
DenisonEFRl/UDEQ Protocol for Determining Whether Alternate Feed Materials are RCRA Listed
Hazardous Wastes
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
Review of Chemical Contaminants in Dawn Mining Company Midnite Mine (DMC) Uranium
Material to Determine Worker Safety and Environmental Issues and Chemical Compatibility at the
DenisonEFRI Mines White Mesa Mill
Request to Amend Radioactive Materials License iI
1.0 INTRODUCTION
1.1 White Mesa Mill
J;)eAiSGn MiAesEnergy Fuels Resources (USA) Gefplnc. ("DenisenEFRI ") operates the White Mesa Uranium Mill (the
"Mill") located approximately six miles south of Blanding, Utah. The Mill processes natural (native, raw) uranium ores
and alternate feed materials. Alternate feed materials are uranium-bearing materials other than natural ores that
meet the criteria specified in the United States Nuclear Regulatory Commission's ("NRC's") Interim Position and
Guidance on the Use of Uranium Mill feed Material Other Than Natural Ores (November 30, 2000) (the "Alternate
Feed Guidance"). Alternate feed materials are processed as "ore" at the Mill primarily for their source material
content. As a result, all waste associated with this proceSSing is 11e.(2) byproduct material.
1.2 Proposed Action
This is a request for an amendment to State of Utah Radioactive Materials License No. UT 1900479 to authorize
receipt and processing of certain uranium containing materials. These materials are Water Treatment Plant ("WTP")
solids resulting from treatment of natural uranium mine storm water and ground water collected from Pit 3 and Pit 4 at
the Midnite Mine in Wellpinit, WA, an inactive uranium mine owned by the Dawn Mining Company ("DMC"). For ease
of reference, the uranium bearing material that results from this water treatment process described further in Section
2, is referred to herein as "Uranium Material".
1.3 Purpose of Action
The Uranium Material contains greater than 0.05% uranium on both a wet and dry basis. A radioactive materials
license issued by the Washington State Department of Health (WN-10390-1) was held for the Midnite Mine WTP
through December 31, 2008. After December 31, 2008, the license was terminated and the regulatory authority for
the Midnite Mine WTP facility and the Uranium Material was transferred to the U.S. Environmental Protection Agency
("EPA") as part of the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), also
known as Superfund. Through December 31, 2008, the Uranium Materials were processed offsite as an alternate
feed material at DMC's Uranium Mill near Ford Washington for its source material content. The processing facility at
the Dawn Mill has been decommissioned and processing of the Uranium Material is no longer possible at that
location. After December 31, 2008 the uranium material was and is currently accepted at the Dawn Mill tailings
disposal facility for direct disposal as source material in accordance with the United States Nuclear Regulatory
Commission (NRC) Guidance on Disposal of Atomic Energy Act Non-Section 11 e.(2) Byproduct Material in Tailings
Impoundments (November 2000). Following the 2010 operational season, direct disposal in the tailings
impoundment is no longer an option.
Denison EFRI has been requested by DMC to make this application to process the Uranium Material as an alternate
feed material at the Mill and to dispose of the resulting tailings in the Mill's tailings impoundments as 11 e.(2)
byproduct material. Approval of this application will allow the recovery of valuable uranium, a resource that would
otherwise be lost to direct disposal and will afford DMC a cost effective and productive mechanism for managing the
material generated as part of the Midnite Mine reclamation.
1.4 Amendment Application and Environmental Report
This application is intended to fulfill the requirements of an application for an amendment to the Mill's Radioactive
Materials License set out in Utah Administrative Code ("UAC") R313-22-38 and includes the Environmental Report
required by UAC R313-24-3 to be contained in such an application.
Request to Amend Radioactive Materials License
2.0 MATERIAL COMPOSITION AND VOLUME
2.1 General
The Midnite Mine Superiund Site ("Site") is an inactive open-pit uranium mine that is currently administrated by EPA
Region 10 under CERCLA, also known as Superiund. The Site EPA Identification Number is WA980978753. The
Site is located on the Spokane Indian Reservation in eastern Washington State, approximately 48 air miles northwest
of Spokane (Attachment 1). These lands are owned by the federal government and held in trust for the Spokane
Tribe of Indians ("Tribe") and individual tribal members.
Uranium was discovered on the site in 1954. The prospectors and several tribal members subsequently formed
Midnite Mines, Inc. and acquired the mining leases at the Site. Midnite Mines, Inc. subsequently joined with
Newmont Mining Company ("Newmont") to create DMC, with Newmont Mining Company as the 51 percent
shareholder and Midnite Mines, Inc. owning 49 percent. Newmont USA Limited is the corporate successor of
Newmont Mining Company and continues to be the majority shareholder of DMC.
The mine operated from 1954 until 1965, providing uranium under contracts with the United States Atomic Energy
Commission ("AEC"). The mine went into standby from 1965 and resumed mining in 1969. The ores were milled at
the Dawn Mill site, located near Ford, Washington. Mining was suspended in 1981 due to decreases in uranium
prices and never resumed. The Mine was regulated by several United States Department of the Interior ("USDOI")
agencies, including the U.S. Geological Survey, U.S. Bureau of Mines, and U.S. Bureau of Land Management
("BLM") Minerals Management Service. The Bureau of Indian Affairs ("BIA") represented the Tribe and individual
tribal allotment owners in matters related to leases and royalties.
An estimated 5.3 million tons of ore and proto-ore (Le. low-grade mineralized rock) and 33 million tons of waste rock
were removed from nine pits between 1955 and 1981. All but two of the mine pits have been backfilled. The last two
pits to be mined consisted of Pit 3 and Pit 4, these pits were not backfilled and remain open. Several reclaimed
waste rock piles remain on the mine property and an estimated 2.4 million tons of ore and proto-ore were stockpiled
and currently remain on the Site.
In the late 1970s, seeps with dissolved ore-derived constituents were observed at the toe of the largest waste rock
piles at the Midnite Mine. The BLM ordered DMC to construct a control pond (the Pollution Control Pond, or "PCP")
in 1979 to capture the seeps for evaporation. Following the suspension of mining in 1981, DMC began pumping
water from the PCP to the now inactive Pit 3 in response to growing quantities of water in the PCP and newly
identified seeps at the base of the largest waste rock pile. Since cessation of mining operations, mine site suriace
runoff water has been collected in engineered channels and diverted to the inactive open mining pit, Pit 3. In
addition, natural ground water from the ore zones of the pits has flowed into and accumulated in the two open mining
pits, Pit 3 and Pit 4, at the site. In February of 1985, DMC applied to the EPA for a National Pollution Discharge
Elimination System ("NPDES") permit to allow for the discharge of treated water from those pits and other waters
collected on the site. In September of 1986, the EPA issued DMC an NPDES permit.
In 1987 a Compliance Order was issued by EPA under the Clean Water Act ("CWA") NPDES program requiring DMC
to eliminate discharges of pollutants to waters of the United States in excess of the limits in the existing NPDES
Permit. Subsequently, DMC developed a seep collection and pumpback program that collected water from Site
drainages and returned them to the PCP and Pit 3. Existing seep and suriace water collection occurs at six specific
locations throughout the Midnite Mine Site as part of this seep collection and pumpback program including the PCP.
Pit 3 water consists of mine site waters collected and pumped from the seep collection and pumpback program,
direct precipitation and local mine suriace runoff in the immediate area of Pit 3, and natural ground water inflow from
the Pit 3 ore zones. The water that accumulates in Pit 4 consists of direct precipitation, groundwater inflow, and
suriace runoff in the immediate area of Pit 4. All waters collected in the seep collection and pumpback system are
derived from seeps from waste rock piles or suriace runoff at the Site. The seep collection and pumpback system
Request to Amend Radioactive Materials License 2
does not collect water from any areas that have ever been known to contain or currently contain any listed hazardous
wastes or from any operations other than the mining of natural uranium ores.
In 1988, a water treatment plant ("WTP") was constructed to treat the accumulating water in the open pits. The WTP
began treating water in 1992. The Washington Department of Health ("WDOH"), under the authority of the Nuclear
Regulatory Commission ("NRC") Agreement State Program, issued a Radioactive Materials License (WN-10390-1) in
1992 for the Uranium Material, which contains greater than 0.05% uranium. This License was terminated by the State
of Washington in December 31, 2008. Operation of the WTP since that time has been administrated by the EPA
under CERCLA.
There are no shop areas, petroleum tanks, or other sources of hydrocarbons at the mine site, with the exception of a
300 gallon diesel fuel tank for the Pit 4 pump, and a 300 gallon tank of gasoline for WTP equipment. The diesel fuel
tank and pump are located in secondary containment near Pit 4 with a maximum volume stored of 300 gallons and
the 300 gallon gasoline tank is located next to the WTP. These fuels are stored and managed separately from the
Uranium Material and have not impacted the Uranium Material in the past nor do they have a reasonable potential to
do so in the future. The constituents precipitated from the WTP influent are derived from flow of natural precipitation
through uranium mine waste rock and natural ore, collected surface runoff from natural materials, and natural ground
water inflow from the ore zones into one of the two remaining open pits, Pit 3 and Pit 4 as discussed above.
In 1998, EPA performed an Expanded Site Investigation (liES I") and scored the Site using the Hazard Ranking
System ("HRS") to determine the eligibility of the Site for inclusion on the National Priorities List (NPL). A Record of
Decision ("ROD") was signed on September 29, 2006, which established the Selected Remedy for the Site. Part of
the Selected Remedy for Operable Unit 1 (Mined Area and the Mining Affected Area, which includes Pit 3 and Pit 4)
included long-term treatment of contaminated seeps and pit water, with on-site discharge of treated water in
compliance with interim discharge limits. The Dawn Mill tailings facility is scheduled for reclamation in the near
future, and continued direct disposal of the Uranium Material at the Dawn Mill will not be allowed or possible beyond
the 2010 operating season. DMC desires to recycle the Uranium Material at the Mill in lieu of direct disposal as a
means to disposition of the material.
2.2 Historical Summary of Sources
The WTP is a conventional lime treatment high-density solids process in which the metals and uranium are
precipitated out in the treatment process, and includes addition of barium chloride for radium removal. A polymer
coagulant is added and the resultant slurry is settled and filtered to produce a solution free of solids for surface
discharge under the CWA NPDES program and EPA CERCLA program. The precipitate is currently centrifuged, and
the final solids contain on average 0.18 wet weight percent uranium (0.21 wet weight percent U30S) at an average
historical solids content of 15 percent. 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 0.63
wet weight percent U30s). As uranium ores and alternate feed materials are typically evaluated on a dry percent
U30S basis, the actual (dry) percent U30S of the Uranium Material is estimated to be approximately 1.4§ percent
U30S.
The WTP is typically operational from early May through the end of October and operates 24 hours per day, four
days per week. WTP influent is derived from approximately 400 gallons per minute ("gpm") influent from Pit 3 and
approximately 50 gpm influent from Pit 4. The pit waters are pumped to the WTP using positive displacement pumps
which are piped separately to the WTP through polyethylene piping. The WTP reagents are pre-mixed in individual
mixing tanks prior to addition to the treatment stream. The hydrated lime and flocculent are pre-mixed using makeup
water from Pit 4, while the barium chloride is mixed with potable water.
Request to Amend Radioactive Materials License 3
Barium chloride is added to the influent water stream, which is then mixed with approximately 90 gpm from the
clarifier bottoms (clarifier underflow) to increase the overall final WTP solids density. Then hydrated lime is added for
the precipitation of uranium and metals. Waters recovered from the dewatering process are also added back to the
process stream at this point. An anionic water soluble polymer (Neo Solutions, NS-6852) is subsequently added as a
coagulant to facilitate clarification.
This process stream is then sent to one of two clarifiers. The precipitated solids are drawn from the clarifier bottom
and, as mentioned previously, approximately 20% of the clarifier underflow (approximately 90 gpm) is pumped back
to the beginning of the process to increase overall WTP solids density. The liquid fraction of the remaining process
stream (approximately 360 gpm) is decanted from the top of the clarifier for further treatment and discharge
separately from the solids, while the remaining solids fraction from the clarifier underflow is sent to the centrifuge for
dewatering. The centrifuge will be replaced for the 2011 operating season with a hydraulic filter press as discussed
in more detail below. A more detailed description of this process is provided in the Technical Memoranda included in
Attachment 4.
The dewatered solids are currently transferred from the centrifuge to the transport truck via a discharge conveyor.
The transport truck is housed within the WTP building and remains in that location until it is hauled for final disposal,
thereby eliminating any opportunity for other waste materials to be introduced into the Uranium Material.
The time period from 2001-2008 is the most representative of treatment volumes processed in the WTP. Before this
time period, pit dewatering and other site activities increased the volumes treated. Therefore these are the years
used for this analysis.
From 2001 through 2008 the WTP process produced between 164,000 dry Ibs and 393,500 dry Ibs per year (or 82 to
194 dry tons per year) of treatment solids (average 294,700 dry Ibs or 147 dry tons). The maximum annual total
volume of Pit water treated was approximately 76.5 million gallons for the period of 2001 through 2008. Volumes
vary depending on how much preCipitation the site receives in a given year.
The plant will be modified for the 2011 operational season, and the centrifuges currently used for Uranium Material
dewatering will be replaced by a hydraulic filter press. It is expected that the same water soluble polymer will be
used for coagulation; however the polymer application rate may be increased from the current rate to improve the
dewatering characteristics of the solids. The Uranium Material solids percent is expected to increase from an
average of 15 weight percent solids to between 25 and 45 percent. The total wet concentrations of the constituents
present in the Uranium Material are expected to increase by 67 to 300 percent from the analytical values reported for
the current Uranium Material as a result of decreased water content due to dewatering with the filter press.
In addition, a Remedial Investigation/Feasibility Study (RI/FS) was completed on 9/30/05 for the Midnite Mine. The
Selected Remedy for the Site is Alternative 5a (Complete Pit Backfill with Passive Drains and Ex-Situ Water
Treatment) of the FS. Based on the FS and issued in the Record of Decision (ROD) as the Selected Remedy
("Remedy), Pits 3 and 4 will be backfilled, waste rock and proto-ore will be moved and capped, and a new passive
water collection system will be installed to capture groundwater from these and other backfilled pit areas. The
surface water management will be designed to divert surface flows around sources of contamination and therefore
minimize the volume of water to be treated after the Remedy is implemented. The eXisting WTP is located on a
waste rock pile that must be removed for the Remedy. Therefore, a new water treatment plant will be built before
construction of the Remedy begins. It is estimated that the construction will begin in the beginning of 2013 and will
require approximately 2 years ending at the end of 2014, and the new WTP must be capable of treating water at a
rate of 1,000 gpm year round for the construction phase. It is likely that the new WTP will be comparable to the
current treatment employed using lime and barium addition for removal of constituents from the feed water. This
higher design flow will allow for rapid dewatering of the pits during backfilling , as well as groundwater collection and
surface water collection treatment. After construction, it is expected that the flows will be reduced to an ultimate
annual value of 65 million gallons and will take an estimated 6 to 7 years to reach these reduced flows.
Request to Amend Radioactive Materials License 4
The water quality during construction is assumed to be the same composition as currently is captured and treated,
and it is expected that the water quality after implementation of the Remedy will be improved from current water
quality.
2.3 Quantity of Uranium Material
As discussed above, the WTP is expected to generate approximately 190 dry tons of Uranium Material per year.
This is based on a total flow rate of 450 gpm, four days per week for 6 months of the year into the WTP, with an
average dry concentration of 1.~ percent U30e. On an annualized basis, this equates to approximately a 180 gpm
continuous inflow rate into the WTP throughout the year. As part of the Remedy, a new water treatment plant will be
constructed over the two-year period commencing in 20131. During the two-year construction period, the new plant
will treat water at a rate of 1,000 gpm continuously throughout each of the two years. This represents an increase in
water flow from 180 gpm, on an annualized basis, to 1,000 gpm. Accordingly, during the two years of construction
the amount of Uranium Material to be produced will increase proportionately from approximately 190 dry tons per
year to approximately 1,000 dry tons per year, to accommodate drainage of Pits 3 and 4.
After the new plant has been constructed, the influent rates into the new plant are expected to revert to the pre-
construction rates resulting in the generation of approximately 190 dry tons of Uranium Material per year. This
annual amount is expected to be reduced annually over the next 6 to 7 years, ending in a steady state rate of
generation of approximately 18.3 dry tons of Uranium Material per year, indefinitely. The following table summarizes
the anticipated amounts of Uranium Material to be generated over the first ten year period.
Year Anticipated Quantity of Uranium
Material (tons)
1 190
2 190
3 996
4 996
5 190
6 155
7 121
8 87
9 52
10 18
1 O-year interim total 2995
Although the foregoing estimates are based on reasonable engineering calculations assumptions, experience has
demonstrated that for excavation remediation projects, such estimates typically underestimate the amounts of
materials ultimately produced. DeRiseREFRI , therefore, considers it to be appropriate to increase the foregoing
estimate by 50 percent, as was done for other alternate feed materials of this type.
Accordingly, this is a request for a license amendment to authorize the Mill to receive and process up to 4,500 dry
tons of Uranium Material, and to dispose of the resulting tailings as 11 e.(2) byproduct materials in the Mill's tailings
impoundments.
1 This is not to be confused with the modifications being made to the existing WTP in 2011, when the current centrifuges will be
replaced with a hydraulic filter press that is intended to reduce the water content of the Uranium Material.
Request to Amend Radioactive Materials License 5
2.4 Radiochemical Data
As noted, the process history demonstrates that the Uranium Material results from treatment of natural mine water
that is accumulated in inactive mine pits created during uranium mining. DMC has estimated that the current
Uranium Material has a uranium content of approximately 0.18 wet weight percent natural uranium (0.21 wet weight
percent U30s). The modifications to the WTP anticipated to occur in 2011 are estimated to increase the uranium
content to between 0.3 and 0.55 percent natural uranium (wet weight basis) or 0.35 and 0.65 wet weight percent
U30s). As uranium ores and alternate feeds are typically evaluated on a dry percent U30S basis, the actual (dry)
percent U30S of the Uranium Material is estimated to be approximately 1.~.§..percent U30S. These modifications to
the WTP are expected to increase the constituent concentrations by 67 to 300 percent. Thorium 232 content will
likely range from 0.0013 to 0.002 percent on a dry basis. A more detailed radiological characterization of the
Uranium Materials is contained in the Radioactive Materials Profile Record ("RMPR") (Attachment 2). The
radionuclide activity concentrations of the Uranium Material (on a dry basis) are consistent with higher-grade Arizona
Strip breccia pipe ores and a number of alternate feed materials which the Mill is currently licensed to receive as
previously approved by the NRC and Utah Division of Radiation Control ("DRC").
2.5 Physical and Chemical Data
Physically, the Uranium Materials are WTP solids with no free liquid, consisting of finely graded solids containing
residual amounts of uranium and other metals. The Uranium Material will be relatively moist, with an average
moisture content of approximately 55-75%. However, this moisture consists of chemically bound water of hydration,
and a minor amount of moisture held in capillary tension. That is, the Uranium Material contains little or no moisture
as free water or pore water. The water of hydration will remain chemically bound regardless of applied mechanical
forces. Just as the proposed filter press will not release the bound water in the WTP, forces from subsequent
handling, such as the pressure from vibration in transit or stacking on the ore pad, will not release the bound water in
those settings. The generator's information in the RMPR in Attachment 2 also attests that there is no free water
associated with these solids. Photo Number 1, attached to the RMPR, demonstrates the Uranium Material's ability to
maintain integrity of form with no seepage of free water, at the moisture contents described above.
The chemical characterization data for the Uranium Materials is also set out in the RMPR (Attachment 2). As with the
radionuclides and as discussed in more detail in Section 4.4 below, all the chemical constituents in the Uranium
Material have either been reported to be, or can be assumed to be, already present in the Mill's tailings system or
were reported in other licensed alternate feeds, at levels generally comparable to or higher than those reported in the
Uranium Materials.
2.6 Comparison to Other Ores and Alternate Feed Materials Licensed for Processing at the Mill
2.6.1 Ores and Alternate Feed Materials With Similar Radiological Characteristics
With an average uranium content of approximately 1.4.§% U30S, on a dry weight basis the uranium content of the
Uranium Material is comparable to a relatively high-grade Arizona Strip breccia pipe uranium ore, which typically
range from approximately 0.4% to 2% or higher U30S. However the uranium daughter products in the Uranium
Material are generally lower than for comparable Arizona Strip ores, resulting in the Uranium Material generally
having a lower radiological hazard.
The concentrations of Ra-226, Th-230 and Pb-210 are lower in the feed as a result of the lower concentrations in the
feed water to the treatment plant. The concentrations of these daughter products are lower in the feed water than the
concentrations typically found in ore due to the limited solubility in groundwater.
The estimated average content of Thorium 232 ("Th-232") is approximately G:OOaO.00076% on a dry basis. This is
well below the levels of Th-232 that the Mill has been licensed to process in the past. For example the average
Request to Amend Radioactive Materials License 6
concentrations of Th-232 in the W.R. Grace, Heritage and Maywood alternate feed materials are approximately
7.27%, 1.08% and 0.88% respectively.
The activities of Ra-226, Th-230 and Pb-210 of approximately 24.1 pCilL, 20.7 pCi/L and 33.3 pCi IL (on a dry basis)
are all well below the corresponding activities of 825 pCi/L, for each of those radionuclides, typically associated with
Colorado Plateau Ore of 0.25% U30a.
2.6.2 Ores and Alternate Feed Materials With Similar ChemicaUMetal Characteristics
The Uranium Material is simple and more benign in chemical composition than many previously approved alternate
feed materials that the Mill has processed. As discussed in more detail in Section 4.5 below, all the constituents in
the Uranium Material have either been reported to be, or can be assumed to be, already present in the Mill's tailings
system or were reported in other licensed alternate feeds, at levels generally comparable to or higher than those
reported in the Uranium Material.
Request to Amend Radioactive Materials License 7
3.0 REGULATORY CONSIDERATIONS
3.1 Alternate Feed Guidance
The Alternate Feed Guidance provides that if it can be determined, using the criteria specified in the Alternate Feed
Guidance, that a proposed feed material meets the definition of "ore", that it will not introduce a hazardous waste not
otherwise exempted (unless specifically approved by the EPA (or State) and the long term custodian), and that the
primary purpose of its processing is for its source material content, the request can be approved.
3.2 Uranium Material Qualifies as "Ore"
According to the Alternate Feed Guidance, for the tailings and wastes from the proposed processing to qualify as
11 e.(2) byproduct material, the feed material must qualify as "ore". NRC has established the following definition of
ore: "Ore is a 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 Uranium
Material is an "other matter" which will be processed primarily for its source material content in a licensed uranium
mill, and therefore qualifies as "ore" under this definition. Further, the uranium concentration of the Uranium Material
is greater than 0.05 percent on both a wet and dry basis, thereby causing the Uranium Material to also meet the
definition of source material.
3.3 Uranium Material Not Subject to RCRA
3.3.1 General
The Alternate Feed Guidance currently provides that if a proposed feed material contains hazardous waste, listed
under Section 261.30-33, Subpart D, of 40 CFR (or comparable Resource Conservation and Recovery Act ("RCRA")
authorized State regulations), it would be subject to EPA (or State) regulation under RCRA. However, the Guidance
provides that if the licensee can show that the proposed feed material does not consist of a listed hazardous waste,
this issue is resolved. NRC guidance further states that feed material exhibiting only a characteristic of hazardous
waste (ignitable, corrosive, reactive, toxic) that is being recycled, would not be regulated as hazardous waste and
could therefore be approved for extraction of source material, unless it is a residue from water treatment. The
Alternate Feed Guidance concludes that if the feed material contains a listed hazardous waste or in the case of a
water treatment residual, a characteristic hazardous waste, the licensee, can process it only if it obtains EPA (or
State) approval and provides the necessary documentation to that effect. The Alternate Feed Guidance also states
that NRC staff may consult with EPA (or the State) before making a determination on whether the feed material
contains hazardous waste.
Subsequent to the date of publication of the Alternate Feed Guidance, NRC recognized that, because alternate feed
materials that meet the requirements specified in the Alternate Feed Guidance must be ores, any alternate feed
materials that contain greater than 0.05% source material are considered source material under the definition of
source material in 10 CFR 40.4 and hence exempt from the requirements of RCRA under 40CFR 261.4(a)(4). See
Technical Evaluation Report Request to Receive and Process Molycorp Site Material issued by the NRC on
December 3, 2001 (the "Molycorp TER"). As a result, any such alternate feed ores are exempt from RCRA,
regardless of whether they would otherwise have been considered to contain listed or characteristic hazardous·
wastes. Since the Uranium Material contains greater than 0.05% source material, it is exempt from RCRA,
regardless of its process history or constituents, and no further RCRA analysis is required. Nevertheless, because
the Alternate Feed Guidance has not yet been revised to reflect this position recognized by NRC in the Molycorp
TER, DeRisoR EFRI will demonstrate below that, even if the Uranium Material were not considered source material
and as such exempt from RCRA, the Uranium Material would not, in any event, contain any RCRA listed or
characteristic hazardous wastes, as required under the Alternate Feed Guidance as currently worded.
Request to Amend Radioactive Materials License 8
3.3.2 DENISONEFRI/UDEQ Listed Hazardous Waste Protocol
In a February, 1999 decision regarding the Mill, the Atomic Safety and Licensing Board Presiding Officer suggested
there was a general need for more specific protocols for determining if alternate feed materials contain hazardous
components. In a Memorandum and Order of February 14, 2000, the full Commission of the NRC also concluded that
this issue warranted further staff refinement and standardization. Cognizant at that time of the need for specific
protocols to be used in making determinations as to whether or not any alternate feeds considered for processing at
the Mill contained listed hazardous wastes, DeAisoA EFRI took a proactive role in the development of such a
protocol. Accordingly, DOAisoA EFRI established a "Protocol for Determining Whether Alternate Feed Materials are
Listed Hazardous Wastes" (November 22, 1999). This Protocol was developed in conjunction with, and accepted by,
the State of Utah Department of Environmental Quality ("UDEQ") (Letter of December 7, 1999). Copies of the
Protocol and UDEQ letter are provided in Attachment 3. The provisions of the protocol can be summarized as
follows:
a) In all cases, the protocol requires that DeAisoA EFRI perform a source investigation to collect information
regarding the composition and history of the material, and any existing generator or agency determinations
regarding its regulatory status;
b) The protocol states that if the material is known --by means of chemical data or site history --to contain no
listed hazardous waste, DeAisoA EFRI and UDEQ will agree that the material is not a listed hazardous
waste;
c) If such a direct confirmation is not available, the protocol describes the additional chemical process and
material handling history information that DOAisoA EFRI will collect and evaluate to assess whether the
chemical contaminants in the material resulted from listed or non-listed sources;
d) The protocol also specifies the situations in which ongoing confirmation/acceptance sampling will be used,
in addition to the chemical process and handling history, to make a listed waste evaluation;
e) If the results from any of the decision steps indicate that the material or a constituent of the material did
result from a RCRA listed hazardous waste or RCRA listed process, the material will be considered to have
contained RCRA listed hazardous waste; and
f) The protocol identifies the types of documentation that DeAisoA EFBLwili obtain and maintain on file, to
support the assessment for each different decision scenario.
The above components and conditions of the Protocol are summarized in a decision tree diagram, or logic flow
diagram, included in Attachment 3, and hereinafter referred to as the "Protocol Diagram".
3.3.3 Application of the Listed Hazardous Waste Protocol
In independent chemical engineer from TetraTech, Inc. ("TetraTech") has conducted a RCRA evaluation of the
Uranium Material and, specifically, applied the Listed Hazardous Waste Protocol to the Uranium Material. A copy of
TetraTech's analysis is included as Attachment 4.
It was concluded that, based on the information that is available,
1. The Uranium Material is not a RCRA listed hazardous waste because it is an ore that has a natural uranium
content of greater than 0.05 weight percent, is therefore source material under 10 CFR 40.4 and, as a
result, is exempt from regulation under RCRA (40 CFR 261.4(a)(4)).
Request to Amend Radioactive Materials License 9
2. Even if the Uranium Material were not source material, it would not be a RCRA listed hazardous waste for
the following additional reasons:
a) It was generated from a known process under the control of the generator, who has provided the
Affidavit, included in Attachment 2, declaring that the Uranium Material is not and does not contain
RCRA listed hazardous waste. This determination is consistent with Boxes I and 2 and Decision
Diamonds 1 and 2 in the DenisonEFRIIUDEO Protocol Diagram;
b) The five volatile organic compounds detected at very low concentrations in the Uranium Material have
been attributed to laboratory contamination and are not actual contaminants in the Uranium Material;
and
c) None of the metals in the Uranium Material samples came from RCRA listed hazardous waste sources.
This determination is consistent with Box 8 and Decision Diamonds 9 through 11 in the
DonisonEFRI/UDEO Protocol Diagram.
3.3.4 Analysis for RCRA Characteristic Waste
3. The Uranium Material does not exhibit any of the RCRA characteristics of ignitability, corrosivity, reactivity,
or toxicity for any constituent, based on the Toxicity Characteristic Leaching Procedure ("TCLP") analysis
summarized in Attachment 2.
3.3.5 Radioactive Material Profile Record
Furthermore, in order for DenisonEFRI to characterize the Uranium Material, DMC has completed DenisonEFRI 's
RMPR form, stating that the material is not RCRA listed waste. The certification section of the RMPR includes the
following text:
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 indicated on this form. I further certify and warrant to DenisonEFRI that the material
represented on this form is not a hazardous waste as identified by 40 CFR 261 and/or that this
material is exempt from RCRA regulation under 40 CFR 261.4(a)(4).
3.3.6 Conclusion
Because the Uranium Material is an ore that contains greater than 0.05% source material, the Uranium Material is
exempt from RCRA under 40 CFR 261.4(a)(4). In addition, based on the site history, the determinations by DMC,
and the analysis of the independent chemical engineer from Tetra Tech, DenisonEFRI has also concluded that, even
if not exempted from RCRA under 40 CFR 261.4(a)(4), based on the application of the Listed Hazardous Waste
Protocol, the Uranium Material would not be listed hazardous waste subject to RCRA. Further, the Uranium material
does not possess any of the RCRA characteristics of ignitability, reactivity, corrosivity, or toxicity for any constituent
and therefore, were it not source material, it would not be a RCRA hazardous waste.
3.4 Uranium Material is Processed Primarily for its Source Material Content
In its Memorandum and Order, February 14, 2000, In the Matter of International Uranium (USA) Corp. (Request for
Materials License Amendment), Docket No. 40-8681-MLA-4, the NRC Commission concluded that an alternate feed
material will be considered to be processed primarily for its source material content if it is reasonable to conclude that
uranium can be recovered from the Uranium Material and that the processing will indeed occur. The Uranium
Material will be processed for the recovery of uranium at the Mill. Based on the uranium content of the Uranium
Material, its physical and chemical characteristics, and DenisonEFRl 's success in recovering uranium from a variety
of different types of materials, including materials that were similar to the Uranium Materials, at the Mill, it is
reasonable to expect that uranium can be recovered from the Uranium Material. As a result, the Uranium Material is
an ore that will be processed primarily for the recovery of source material, and the tailings resulting from processing
the Uranium Material will therefore be 11e.(2) byproduct material under the definition set out in 10 CFR 40.4.
Request to Amend Radioactive Materials License 10
Request to Amend Radioactive Materials License 11
4.0 ENVIRONMENT AFFECTED
4.1 General
The Mill is a licensed uranium processing facility that has processed to date approximately 4,000,000 tons of
uranium-bearing conventionally mined ores and alternate feed materials primarily for the recovery of uranium, with
the resulting tailings being permanently disposed of as 11 e.(2) byproduct material in the Mill's tailings impoundments.
Environmental impacts associated with such previously licensed Mill operations have been thoroughly evaluated and
documented in the past (see, for example, the original 1979 Final Environmental Statement ("FES") for the Mill,
Environmental Assessments ("EAs") for Mill license renewals dated 1985 and 1997, an EA for the Mill's reclamation
plan dated 2000, EAs for alternate feed materials dated 2001 and 2002, in each case prepared by the NRC) and a
Safety Evaluation Report prepared by UOEQ in connection with another alternate feed material. The Uranium
Material will also be processed as an alternate feed material at the Mill for the recovery of uranium and the resulting
tailings will be permanently disposed of in the Mill's tailings impoundments as 11 e.(2) byproduct material, in a similar
fashion to other conventionally mined ores and alternate feed materials that have been processed or licensed for
processing at the Mill.
Accordingly, this Environmental Report will focus on the various pathways for potential radiological and non-
radiological impacts on public health, safety and the environment and determine if the receipt and processing of the
Uranium Material would result in any potential significant incremental impacts over and above previously licensed
activities.
The pathways that are analyzed are the following:
a) potential impacts from transportation of the Uranium Material to the Mill;
b) potential impacts from radiation released from the Uranium Material while in storage at the Mill;
c) any chemical reactions that may occur in the Mill's process;
d) any potential reactions or inconsistencies with the existing tailings or tailings facilities;
e) potential impacts on groundwater;
f) potential impacts on surface water;
g) potential airborne radiologic impacts;
h) potential radon and gamma impacts; and
i) worker health and safety issues.
These potential pathways will be discussed in the following sections of this document. The findings below will
demonstrate that, because all the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, already present in the Mill's tailings system or were reported in other licensed alternate feeds, at
levels generally comparable to or higher than those reported in the Uranium Material, the resulting tailings will not be
significantly different from existing tailings at the facility. As a result, there will be no incremental public health, safety
or environmental impacts over and above previously licensed activities.
4.2 Transportation Considerations
4.2.1 Packaging and Mode of Transportation
The Uranium Material will be shipped in covered end-or side-dump haul trucks. The Uranium Material will be shipped
as Radioactive LSA 1 (low specific activity) Hazardous Material as defined by DOT regulations. OMC will arrange
with a materials handling contractor for the proper marking, labeling, placarding, manifesting and transport of each
shipment of the Uranium Material. Shipments will be tracked by the shipping company from the Midnite Mine until
they reach the Mill. OMC will ship approximately 25 trucks per year, or an average of one truck per week for the six
month annual operating period. The number of trucks per year could vary depending on the Uranium Material
Request to Amend Radioactive Materials License 12
production. The estimated range would be from 2 to 73 trucks per year, with the highest number of trucks expected
in the two years of construction of the Remedy.
The trucks involved in transporting the Uranium Material to the Mill site will be surveyed and decontaminated, as
necessary, prior to leaving the Midnite Mine for the Mill and again prior to leaving the Mill site.
4.2.2 Transportation Impacts
For the following reasons, it is not expected that transportation impacts associated with the movement of the Uranium
Material by truck from the Midnite Mine WTP facility to the Mill will be significant:
a) Radiological Matters
The transport of radioactive materials is subject to limits on radiation dose rate measured at the transport vehicle as
specified in the US Code of Federal Regulations. The external radiation standards for these shipments are specified
in 10 CFR 71.47 sections (2) and (3) as less than 200 millirems per hour (Umrem/h") at any point on the outer surface
of the vehicle, and less than 1 0 mremlh at any point two meters from the outer lateral surfaces of the vehicle. All
exclusive use trailer trucks will be scanned by DMC prior to departure from the Midnite Mine to ensure that these
limits are satisfied. All conveyances will be covered by tarpaulins or similar cover to prevent any migration of ore
dust while in transit. From a radiologic standpoint, the Uranium Material is within the bounds of other ores and
alternate feed materials licensed for processing at the Mill. The Uranium Material will be transported in covered end
or side dump haul trucks, in a similar fashion to other conventional ores, and as a result there will be no significant
incremental radiological impacts associated with transportation of Uranium Material to the Mill, over and above other
previously licensed ores and alternate feed materials at the Mill or from licensed activities at other facilities in the
State of Utah. All applicable requirements of 49 CFR Part 172 and Part 173 will be met, and the selected transport
company will have all the required training and emergency response programs and certifications in place.
b) Traffic Volume Matters
(i) Comparison to Licensed Mill Operations
Section 4.8.5 of the 1979 FES for the Mill noted that when area mining was at expected full operational levels,
approximately 68 round trips on local highways would be made by 30-ton ore trucks to the Mill per day (see the 1978
Dames and Moore Environmental Report for the Mill, p. 5-34). In addition, based on a licensed yellowcake capacity
of 4,380 tons per year (Mill license condition 10.1) a maximum of 8,760,000 pounds of yellowcake would require
shipment from the Mill to conversion facilities. This would require approximately 183-275 truck shipments from the
Mill per year (based on 40-60 drums per truck, 800 Ibs per drum), or one truck every one to two days based on a
seven day work week (one truck every day or so, based on a five-day work week). In contrast, on average, 25 truck
loads will be transported yearly from the Midnite Mine to the Mill during the period when the Water Treatment Plant is
operating (May to October), or at an approximate frequency of one truck per week from May to October. In addition,
the amount of yellowcake to be produced from processing the Uranium Material is expected to be transported in
approximately one truck load per year. This frequency is well within the estimated yellowcake transport frequency at
licensed capacity. During the period of transportation of the Uranium Material to the Mill, G9fIi&eAEFRI does not
expect that ore deliveries from all other sources WOUld, in total, exceed a small fraction of the truck transportation
associated with licensed capacity.
(ii) Comparison to Existing Truck Traffic on Interstate Highways 15 and 70
Based on information provided by the State of Utah Department of Transportation (UUDOT") on July 14, 2010, on
average during 2009, 2350 multi-unit trucks traveled south daily on Interstate 15 from Idaho into Utah. On average
between 740 and 6,518 multi-unit trucks traveled south daily on Interstate 15, across Interstate 50 to Interstate 70.
Based on the 2009 UDOT truck traffic information, an average of five additional trucks per month traveling this route
to the Mill from May to October represents an increased traffic load of less than 1/100 of one percent. For the
foregoing reasons, the truck traffic to the Mill from this project is expected to be an insignificant portion of existing
truck traffic through the state, and well within the level of truck traffic expected from normal Mill operations.
Request to Amend Radioactive Materials License 13
(iii) Comparison to Existing Truck Traffic on Highway 191
Based on information provided by the State of Utah Department of Transportation ("UDOT") on July 14, 2010, on
average during 2009, 1,628 multi-unit trucks traveled south on State Road 191 from Moab across the Grand County
line each day. On average between 285 and 610 multi-unit trucks per day traveled the stretch of State Road 191
south of Monticello, UT toward Blanding, UT. Based on the 2009 UDOT truck traffic information, an average of five
additional trucks per month traveling this route to the Mill from May to October represents an increased traffic load of
less than one quarter of one percent. For the foregoing reasons, the truck traffic to the Mill from this project is
expected to be an insignificant portion of existing truck traffic in the area, and well within the level of truck traffic
expected from normal Mill operations.
4.3 Storage
4.3.1 Manner of Storage
Trucks arriving at the Mill site will be received according to existing Mill procedures. The trucks will be unloaded onto
the ore pad for temporary storage of the Uranium Material pending processing. The Uranium Material will be stored in
a manner similar to conventional ore. Tarped haul trucks will enter the site, roll back the tarp covering and dump
their loads onto the ore pads as with conventional ore deliveries. The haul truck will then be cleaned and scanned for
free release as per approved Mill standard operating procedures.
4.3.2 Environmental Impacts Associated With Storage
Because the Uranium Material will be temporarily stored on the ore pad awaiting processing and because the
Uranium Material does not significantly differ in radiological activity from other ores and alternate feed materials,
gamma radiation and radon emanation from the Uranium Material will be minimal and within the levels associated
with other ores and alternate feed materials handled at the Mill on a routine basis. Experience at the Dawn Mill Site
has determined that the Uranium Material is stable under ambient environmental conditions and does not require any
special handling (item 10 of the Affidavit (Attachment 2)). The TCLP data evidences that the material does not readily
leach and does not exhibit hazardous waste characteristics when exposed to more severe conditions than would be
anticipated on the ore storage pad.
4.4 Process
The Uranium Material will be introduced to the process circuit either in the main circuit mixed with conventional ore,
or in the Mill's alternate feed circuit alone. If processed in the main circuit, the material will be processed through the
Mill's existing conventional ore acid leach, counter-current decantation and solvent extraction circuits for the recovery
of uranium values. The leaching process will begin in Pulp Storage with the addition of sulfuric acid. The solution will
be advanced through the remainder of the Mill circuits with no significant modifications to either the circuits or the
recovery process anticipated. If processed through the Mill's alternate feed circuit, no significant changes to that
circuit would be required. .Since no significant physical changes to the Mill circuits will be necessary to process this
Uranium Material, no significant construction impacts beyond those previously assessed will be involved. Recovery
of additional contained metals is not anticipated at this time.
The effects of introducing the Uranium Material into the Mill's process and tailings were reviewed by the independent
chemical process engineer from Tetra Tech. Tetra Tech's Technical Memorandum is included as Attachment 5.
Table 5 in the Technical Memorandum provides comparisons of the concentrations of all known constituents of the
Uranium Material to the tailings and other previously processed ores and alternate feeds.
Request to Amend Radioactive Materials License 14
4.5 Compatibility with .QeRi&enEFRI Mill Tailings
4.5.1 Physical Compatibility
The Uranium Material will be received as a precipitated solid from lime treatment of the WTP influent water. A
portion of this material may be insoluble in the acid leach process at the Mill and therefore, the discharge sent to
tailings may contain some solid material ("sand"). The remainder of the Uranium Material will be soluble and
therefore be contained in the liquid phase after processing in the acid leach system. The solids will be sent to an
active tailings cell at the Mill, e.g., Cell 4A, or Cell 4B. The solutions from the Uranium Material tailings will be
recirculated through the mill process for reuse of the acidic properties in the solution. The sands will be only a
portion of the total mass of Uranium Material sent to the Mill from the Midnite Mine site. However, assuming a worst
case scenario that all of the solid material ends up as sand in the tailings, it is estimated that for the main processing
circuit, the additional load to the tailings is minimal (Attachment 5, Table 5). It is expected that the percent increase
to the system is less than one percent for all components.
For the analysis presented in Attachment 5, it is assumed that the chemical composition of each active cell, Cell 4A
or Cell 4B, is represented by the composition of Cell 3 from the Statement of Basis for the Utah Groundwater
Discharge Permit for the Mill (November 29, 2004).
Cell 4A has a High-Density Polyethylene ("HOPE") liner. Cell 4A went into service in October of 2008 and contains
conventional ore tailings sands. Solutions from the Mill, starting in July 2009, have also been sent to Cell 4A. Cell
4B was recently constructed, with an HOPE liner system similar to Cell 4A and is expected to ultimately receive the
same materials as Ce114A. It is currently expected that future tailings cells will have similar construction.
The constituents in the sands and liquids resulting from processing the Uranium Material are not expected to be
significantly different from those in the conventional ores either in composition or in concentration of constituents.
Attachment 5, Table 5 indicates that based on a comparison of the Uranium Material to the tailings, all of the metal
constituents found in the Uranium Material are currently processed in the Mill's main circuit and are all natural
components of uranium ore with the exception of barium.
The constituents that would be added to the Mill process from processing the Uranium Material are similar to
conventional ores, absent of organic materials, and also contain additional calcium, barium, and polymer due to the
addition of these constituents in the WTP process. Tetra Tech identified that these components are not expected to
have any adverse effect on the Mill processing system or to the tailings Cells. As described in Attachment 5, it is
expected that most of the metal and non-metal constituents entering the leach system with the Uranium Material will
be converted to sulfate salts, precipitated, and eventually discharged to the tailings system.
Every metal and non-metal cation and anion component in the Uranium Material already exists in the Mill's tailings
system. A summary of the tailings composition before and after the Uranium Material is processed is presented in
Attachment 5, Table 6.
Every component in the Uranium Material has been:
1. detected in analyses of the tailings cells liquids;
2. detected in analyses of tailings cells solids;
3. detected in analyses of alternate feed materials licensed for processing at the Mill; or
4. detected in process streams or intermediate products when previous alternate feeds were processed at the
Mill;
at concentrations that are generally comparable to the concentrations in the Uranium Material. Due to the small
annual quantities of the Uranium Material, an increase in the concentration of any analyte in the Mill's tailings is not
expected to be significant.
Request to Amend Radioactive Materials License 15
The constituents in the Uranium Material, are expected to produce no incremental additional environmental, health,
or safety impacts in the Mill's tailings system beyond those produced by the Mill's processing of natural ores or
previously approved alternate feeds.
4.5.2 Capacity and Throughput
The amount of tailings that would potentially be generated is substantially smaller than the volume that would be
generated from processing an equivalent volume of conventional ore, as the Uranium Material consists of soluble
salts and minimal insoluble solids. Midnite Mine, as described above, may be expected to ship on average
approximately 300 dry tons per year of Uranium Material to the Mill. As the Mill's design capacity is approximately
2,000 dry tons per day, the total annual throughput of Uranium Material is a small fraction of one day's Mill capacity.
This volume is well within the maximum annual throughput rate and tailings generation rate for the Mill of 680,000 dry
tons per year. Additionally, the expected annual amount of uranium in the Material of approximately 84,000 Ibs (4,2
tons) of U30e is well within the Mill's licensed yellowcake capacity of 4,380 tons per year of U30a.
GeftisooEFRI proposes that, as has been the case for recent alternate feed license amendments approved by the
NRC and DRC, a condition should be added to the license amendment to the effect that the Mill shall not accept any
Uranium Material at the site unless and until the Mill's Safety and Environmental Review Panel (lOSER POI) has
determined that the Mill has sufficient licensed tailings capacity to permanently store:
a) all 11 e.(2) byproduct material that would result from processing all the Uranium Material,
b) all other ores and alternate feed materials on site; and
c) all other materials required to be disposed of in the Mill's tailings impoundments pursuant to the Mill's
reclamation plan.
4.6 Groundwater
In the 1997 EA, NRC staff concluded that, for a number of reasons, groundwater beneath or in the vicinity of the Mill
site will not be adversely impacted by continued operation of the Mill. Additionally, the design of the existing
impoundments has previously been approved by Utah DRC (Cells 4A and 4B), and GSAi&eAEFAI is required to
conduct regular monitoring of the impoundment leak detection systems and of the groundwater in the vicinity of the
impoundments to detect leakage should it occur.
Because the Mill's tailings cells are not impacting groundwater, the receipt and processing of Uranium Material at the
Mill will not have any incremental impacts on groundwater.
In any event, QeAiseREFRI has a groundwater monitoring program for the Mill. With the exception of barium, all
constituents identified in the Uranium Material are included in the groundwater monitoring program.
Barium will be introduced to the Mill's tailings cells with disposal of the tailings from the processing of the Uranium
Material. The chemistry of the tailings cells would limit the mobility of barium due to the abundance of sulfate in the
tailings cells. The insolubility of barium in the presence of sulfate is generally consistent regardless of the liquid
medium. That is, the solubility of barium sulfate in cold water is 0.022 mg/L and in concentrated sulfuric acid is 0.025
mg/L (Handbook of Chemistry and Physics, 68th Edition). 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) would be negligible. Therefore, given the strong tendency of barium to partition to solids,
especially in the presence of sulfate, there is no reasonable potential for barium to migrate to ground water from the
tailings cells at the Mill in the unlikely event of a leak in the tailings cells. Calcium Kd value in UDEQ Statement of
Basis for the permit (December 1,2004) contains published Kd values for calcium of 5 to 100 Ukg for sandy to clayey
soils. The Kd for barium is 100 to 150,000 Ukg for the same soil types indicating less mobility in groundwater and
Tetra Tech has therefore concluded that barium is sufficiently represented by monitoring for calcium and has
Request to Amend Radioactive Materials License 16
identified no technical reason to add barium to the list of constituents monitored in ground water in the vicinity of the
tailings cells.
Excluding barium, chemical and radiological make-up of the Uranium Material is similar to other ores and alternate
feed materials processed at the Mill, and their resulting tailings will have the chemical composition of typical uranium
process tailings, for which the Mill's tailings system was designed. As a result, the existing groundwater monitoring
program at the Mill will be adequate to detect any potential future impacts to groundwater.
As a result, there will be no incremental impacts over and above previously licensed activities.
4.7 Surface Water
There will be no discharge of Mill effluents to local surface waters. All Mill process effluents, laundry, and analytical
laboratory liquid wastes will be discharged to the Mill's tailings impoundments for disposal by evaporation. Runoff
from the Mill and facilities is directed to the tailings impoundments. Sanitary wastes are discharged to State-approved
leach fields. As a result, there is no plausible pathway for Uranium Material to impact surface water. Further, as
indicated in Semi-Annual Effluent Reports filed by the Mill to date, there is no indication of the Mill impacting surface
waters. There will therefore be no incremental impact to surface waters from any airborne particulates associated
with processing the Uranium Material.
Uranium Material will be transported to the Mill in covered exclusive-use trucks. Upon introduction into the Mill
circuit, the Uranium Material will be processed in a similar fashion as other ores and alternate feed materials. The
Uranium Material will be relatively moist, with an average moisture content of approximately 55-75%. This moisture is
bound water of hydration, and a minor amount of moisture held in capillary tension, that is not driven off by the high
pressure filter press. As attested to by the generator (Attachment 1), there is no free water associated with these
solids. This will minimize any potential for dusting while the Uranium Material is introduced into the Mill process. In
addition, standard procedures at the Mill for dust suppression will be employed if necessary. There will therefore be
no new or incremental risk of discharge to surface waters resulting from the receipt and processing of Uranium
Material at the Mill or the disposition of the resulting tailings.
Finally, as the chemical and radiological make-up of the Uranium Material are sufficiently similar to natural ores and
the tailings resulting therefrom, the existing surface water monitoring program at the Mill will be adequate to detect
any potential impacts to surface water. As a result, there will be no incremental impacts over and above previously
licensed activities.
4.8 Airborne Radiological Impacts
The chemical and radiological make-up of the Uranium Material will not be significantly different from natural ores
that have been processed at the Mill in the past. The existing air particulate monitoring program is equipped to
handle all such ores.
4.9 Radon and Gamma Impacts
As discussed in Section 2.5.1 above, the concentration of uranium in the Uranium Material is comparable to the
concentration of uranium in conventionally mined Arizona Strip breccias pipe ores. However, the Radon-222 activity
is much lower, being less than that associated with low-grade Colorado Plateau ores. In addition, the concentration
of Th-232 in the Uranium Material is low, and is lower than the concentration of Th-232 in a number of other alternate
feed materials that have been licensed for processing at the Mill. As a result, the Uranium Material contains
comparable concentrations of radium and other gamma-emitting radionuclides as natural ores and other alternate
feed materials licensed for processing at the Mill. The Uranium Material will therefore pose less of a gamma and
Request to Amend Radioactive Materials License 17
radon hazard than other ores and alternate feed materials that have been processed or licensed for processing at the
Mill.
4.10 Safety Measures
4.10.1 General
During unloading of the Uranium Material onto the ore pad, while the Uranium Material is being stored on the ore pad
pending processing, while feeding Uranium Material into the Mill process and while processing the Uranium Material
and disposing of and managing the resulting tailings, the Mill will follow its standard operating procedures for
occupational and radiological safety.
4.10.2 Radiation Safety
a) Existing Radiation Protection Program at the Mill
The radiation safety program which exists at the Mill, pursuant to the conditions and provisions of the Mill's
Radioactive Materials License, and applicable State Regulations, is adequate to ensure the maximum protection of
the worker and environment, and is consistent with the principle of maintaining exposures of radiation to individual
workers and to the general public to levels As Low As Reasonably Achievable ("ALARA"). Employees will be
provided with personal protective equipment including full-face respirators, if required. In addition, all workers at the
Mill are required to wear personal TLD badges or the equivalent to monitor their exposure to gamma radiation.
b) Gamma Radiation
Gamma radiation levels associated with the Uranium Material are expected to be within levels of gamma radiation
associated with other ores and alternate feed materials processed or licensed for processing at the Mill in the past.
Gamma exposure to workers will be managed in accordance with existing Mill standard operating procedures.
c) Radon
Radon levels associated with the Uranium Material are within levels of radon associated with other ores and alternate
feed materials processed or licensed for processing at the Mill in the past. Radon exposures to workers will be
managed in accordance with existing Mill standard operating procedures.
d) Control of Airborne Contamination
The Uranium Material is a fine-grained solid currently containing an average moisture content of approximately 85%.
After modification of the hydraulic filter press at the Midnite Mine Water Treatment Plant in 2011, the moisture
content will decrease to 55% to 75%. Dust suppression techniques will be implemented, if required, while the
Uranium Material is being introduced into the Mill process, although this may be unnecessary due to the relatively
high moisture content of the Uranium Material. Once in the Mill process, the Uranium Material will be in a dissolved
form, and no special dust suppression procedures will be required. As is the practice at the Mill for other alternate
feed materials, the Derived Air Concentration ("DAC") to be used in any analysis of airborne particulate exposure to
workers will be developed specifically for the Uranium Material, based on applicable regulations and Mill procedures,
in order to take into account the specific radionuclide make-up of the Uranium Material. The Mill has safely received
and processed alternate feed materials with higher concentrations of each of the radionuclides contained in the
Uranium Material, under previous license amendments, and can safely handle the Uranium Material in accordance
with existing Mill standard operating procedures.
4.10.3 Occupational Safety
The primary focus of safety and environmental control measures will be to manage potential exposures from
radionuclide particulates. Response actions and control measures designed to manage particulate radionuclide
hazards will be more than sufficient to manage chemical hazards from the metal oxides (see the conclusions of Tetra
Tech in Attachment 5).
Request to Amend Radioactive Materials License 18
4.10.4 Vehicle Scan
As stated in Section 4.2.1 above, the shipments of Uranium Material to and from the Mill will be dedicated, exclusive
loads. Radiation surveys and radiation levels consistent with applicable DOT regulations will be applied to the
exclusive use vehicles. For unrestricted use, radiation levels will be in accordance with applicable values contained in
the NRC Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material, U.S. NRC, May, 1987. If radiation levels
indicate values in excess of the above limits, appropriate decontamination procedures will be implemented.
4.11 Long Term Impacts
The Uranium Material is comprised of similar chemical and radiological components as already exist in the Mill's
tailings cells. Existing monitoring programs are therefore adequate, and no new monitoring procedures are required.
As a result, there will be no decommissioning, decontamination or reclamation impacts associated with processing
the Uranium Material, over and above previously licensed Mill operations.
4.12 Other Information
4.13 Added Advantage of Recycling
DMC has expressed its preference for use of recycling and mineral recovery technologies for the Uranium Material
for three reasons: 1) for the environmental benefit of reclaiming valuable minerals; 2) for the added benefit of
reducing radioactive material disposal costs; and 3) for the added benefit of minimizing or eliminating any long term
contingent liability for the waste materials generated during processing.
DMC has noted that the Mill has the technology necessary to process materials for the extraction of uranium and to
provide for disposal of the 11 e,(2) byproduct material, resulting from processing the Uranium Material primarily for the
recovery of uranium, in the Mill's existing tailings impoundments. As a result, DMC will contractually require
DORisoREFRI to recycle the Uranium Material at the Mill primarily for the recovery of uranium.
4.14 Consideration of Alternatives
This application is in response to a request by DMC for disposal/processing options in connection with the clean up
of the Midnite Mine. The Mill is a facility that has been requested to provide these services, because it is licensed to
process materials that are similar to the Uranium Materials for the recovery of uranium and is licensed to create,
possess and dispose of the resulting byproduct materials. Given that a decision to dispose of the Uranium Material at
an offsite facility is required, the only options are as to which offsite facility the Uranium Materials will ultimately be
sent for disposal. There are a limited number of facilities that are licensed to receive, store, process or dispose of the
Uranium Material. Alternatives to processing/disposal at the Mill would be direct disposal or processing at one of
these other facilities. If direct disposal is utilized, the value of the recoverable uranium in the Uranium Material would
not be realized.
Request to Amend Radioactive Materials License 19
5.0 SIGNATURE
This document was prepared by D9Ris9REFRI Mines (USA) Corp. on AJ*Il-27 Ma.y 20, 20142.
DeNISON MINeSEneray Fuels Resources (USA) ~INC.
By:
Jo Ann S. Tischler
Dir9sterManager, Compliance and PerFRittiRgLicensing
Request to Amend Radioactive Materials License 20
6.0 REFERENCES
United States Nuclear Regulatory Commission; Interim Guidance on Disposal of Non-Atomic Energy Act of 1954,
Section 11 e.(2) Byproduct Material in Tailings Impoundments, November 2000.
Utah Division of Radiation Control Ground Water Quality Discharge Permit Statement of Basis for a Uranium Mining
Facility at White Mesa, South of Blanding, Utah, November 29, 2004.
Request to Amend Radioactive Materials License 21
Appendix e
voe Data
Appendix D
Updated Table 3 for Attachment 5 of the April 2011 Amendment Request
[ it) TETRA TECH
Table 3. Historical Total WTP Uranium Material Testing Data
Initial eOrilp6si~e StudgeS3mple Annual C'Ompcfslte Sample
U~nat I Ra-2-26 M2l~re l;I-nat Ra-226
D~te (mg/~J (pCltg) lli.l (msikg) (pCl/g)
4/1/2003 11,100 5.7 83.6 9,700 5.3
4/1/2004 9,060 7.6 87.0 8,600 2.4
4/1/2005 12,900 14 86.4 19,000 11
4/1/2006 5,200 4.3 86.3 11,200 9.1
4/2/2007 2,700 4.7 84.3 12,000 24.2
4/9/2008 19,000 5.1 79.4 13,500 10.8
5/20/2009 8.7
4/13/2010 15,333
Count: 7 7 § 6 6
Max: 19,000 14 87.0 19,000 24
Min: 2,700 4.3 79.4 8,600 2
Avg: 10,756 7.2 84.5 12,333 10
~ M4fi:!~Mre~ Me~sured I
Avg ~ Sotl~i . ~ ~ Solids -..M!!l %$oJfds
U Cone. DOl Weight Basis (mglKg) 10,756 -19,000 -2,700 -
U Cone. Wet Weight Basis (mglKg) 1,667.2 15.5% 3,914 20.6% 424 15.7%
U Cone. Wet Weight Basis (%) 0.17% -0.39% -0.04% -
% solids e 100% -% MOIsture
U Cone. Wet WelRht 6asl~ Img/Kgl .. U Com:. Dry Weight BasIs x % solids
6
Appendix E
Replacement Page for Attachment 2 of the April 2011 Amendment Request
Radioactive Material Profile Record
B.1. 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 the testing of three samples collected in 2010 (WTPS-l, -2, -3) for the other radionuclides
(Gross Alpha, Gross Beta, Pb-2l0, 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.l 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 0.11& wet weight
percent uranium (0.a-t-20 wet weight percent U30g) at an average historical solids content of 15.2
percent when produced using centrifuges for dewatering. However, the centrifuges are to be replaced
with a hydraulic filter press in 20 1+J , 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 U30g).
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-6852) is added as a coagulant during
clarification. The stream is sent to one of two clarifiers and the sludge drawn from
Page 5 of 11
Appendix F
Replacement Page for Attachment 2 of the April 2011 Amendment Request
uranium Matenal Metals AnalYSIS Tor K\,,;KA I OXICI~ \,,;naraCtenStlCS t I \";Lt'1
Sample Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver
ID Sample Date mg/L mg/L mg/L mg/L mg/L mg/L , mg/L mg/L
2002 <0.05 <10 <0.1 <0.5 <0.5 <0.02 <0.1 'I <0.5
2003 <0.5 <10 0.2 <0.5 <0.5 <0.02 <0.1 I <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 I
WTPS-3 4/13/2010 <0.1 <1 <0.05 <0.1 <0.03 <0.002 0.054 <0.1 I
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 <0.54-<10 -<0.Q25 <0.5 <0.5 <0.02 0.2 <0.5
40 CFR Part 261.24 5 100 1 5 5 0.2 1 5
PASS? Yes Yes Yes Yes Yes Yes Yrs Yes -
Page 7 of 11
Appendix G
Replacement Page for Table 2 of Attachment 4 of the April 2011 Amendment Request
[ It) TETRA TECH
.,.,. ..... __ ~ _'''', ....................... I ............. "" ... , .... ~.." .....• _ .... __ _ .. _ ... -.,,_ ... -..... ,---.. ---'. __ .. -,
I Sample Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver
10 Sample Date mg/L mg/L mg/L mg/L mjl/L mg/L mg/L 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 <0.5+ <10 ~.25 <0.5 <0.5 <0.02 0.2 <0.5
40 CFR Part 261.24 5 100 1 5 5 0.2 1 5
PASS? Yes Yes Yes Yes Yes Yes Yrs Yes ..
Appendix H
Replacement Page for Attachment 2 ofthe April 2011 Amendment Request
Uranium Material Organic1i and Pesticides Analyses for RCRA Toxicity Characteristics.(TCLP)
I Results
Maximum
T8/11et Analyb! Units TaP W11'S-1 W11'S-2 W11'S-3 [ Formatted Table
Organochlorine Pesticides -Method SWBOB1A -TCLP leachate
Gamma-SHC (Lindane) mg/l 04 <0.0001 <0.0001 <00001.
See Next
Heptachlor mg/l Row <0.00015 <000015 <0,00015
Heptachlor Eooxide mg/l 0008 <0000079 <0.000079 <0.000079
Gamma-Chlordane mg/l 003 <0000078 <0000078 <0.000078
Alpha-Chlordane mRil 003 <0.00009 <0.00009 <000009
Endrin mRil 002 <0.000096 <0_000096 <0000096
Methoxychlor mg/l 100 <0.00039 <0.00039 <0.00039
Toxaphene mg/l .Q..2. <0.0051 <00051 <0,0051
Chlordane rrWl II 03 <O.OOll <00011 <0.0011
Chlorinated Htrblddti -Method SW81.51A -TClP leachate
2.4-0 I IJlVl I 100 <1.6 I <1.6 I <16
Silvex I /lg/l I 10 I <0.12 I <0.12 I <012
GC/MS Semlvol.tlles -Method SW8270D -TCLP leachate
Pyridine rrWl 50 <0.02 <0.02 <0.02
l.4-Dichlorobenzene mRil 7.5 <0.02 <0.02. <0_02
2-Methylphenol (0 Cresoil mg/l 200 <0.02 <0,02 <002
3+4-Methylphenol (m+D Cresoll m~/l 200 <0.02 <0102 <002
Hexachloroethane moll 3.0 <0.02 <0.02 <0.02
Nitrobenzene mg/l Ul <0.02 <0,02 <0.02
Hexachlorobutadiene m~l 0.5 <0.02 <0.02 <0.02
2A,6-Trlchlorophenol mg/l 2_0 <0.02 <0.02 <0.02
2.lIrS.j,lchtorophunal mg/l 400 <0.02 <0,02 <0,02
2.4-Dinitrotoluene mg/l 013 <002 <QQ2. <O.Q2
Hexachlorobenz.ene mg/l 013 <0.02 <0102 <002
Pentachlorophenol mRil 100 <0043 <0_043 <0.043
GCjMS Volatiles -Method SW8260 258 -leachate
Vinyl Chloride l\g/l 02 <0,83 <0.83 <0.83
1.1-Dlchloroethene· pg/l 0.7 <0.83 <083 <083
2-Butanone (Methyl Ethyl Key tone) uRil 200 <B.3 <8.3 <8.3
Chloroform Ug/l 6.0 <0.83 <0.83 <083
Carbon Tetrachloride ue/l 0_5 <0.83 <083 <083
l,2-Dichloroethane /lg/l 0.5 <083 <083 <0.83
Benzene pgfl 05 <0_83 <083 <083
Trichloroethene· Jl&ll 05 2-7 B.l L5 S.l <0_83
Tetrachloroethene· gIL ill <0.83 <083 <0.83
Chlorobenzene "g/l. 100 <0,83 <0,83 <0.83
Inorganics -Method SW 846_7.3.1 (Cyanide) & _7.3.2 (Sulfide),
SW9045C {pH)
Reactive Cyanide mg/kg N1A I <0 .. 1 <01 <01
Reactiye..5ulfide me/ke N A <SO <50 <SO
Solid pH In Water@ 25'C pH llf.p, I 9.09 j 9.19 9_26
!g~ll".bllity -Method SW1010A
Ignitabllity -95'C ·C I f':!../!', I u u u
Page 8 of II
Appendix I
Replacement Page for Attachment 4 of the April 2011 Amendment Request
Table 3. Uranium Material Organics and Pesticides Analyses for RCRA Toxicity Characteristics
(TCLP) (Uodated 2/28/13)
Results
Maximum
Target Analyte Units TClP WTPS-l WTPS-2 WTPS-3
Organochlorine Pesticides -Method SW8081A -TClP leachate
Gamma-BHC (Lindane) mg/L 0.4 <0.0001 <0.0001 <0.0001
See Next
Heptachlor mg/L Row <0.00015 <0.00015 <0.00015
Heptachlor EJloxide mg/l 0.008 <0.000079 <0.000079 <0.000079
Gamma-Chlordane mg/l 0.03 <0.000078 <0.000078 <0.000078
Alpha-Chlordane mg/L 0.03 <0.00009 <0.00009 <0.00009
Endrin mg/L 0.02 <0.000096 <0.000096 <0.000096
Methoxychlor mg/L 10.0 <0.00039 <0.00039 <0.00039
Toxaphene mg/L 05 <0.0051 <0.0051 <0.0051
Chlordane mg/L 0.03 <0.0011 <0.0011 <0.0011
Chlorinated Herbicides -Method SW81S1A -TeLP leachate
2,4-D I.Ig/L 10.0 <1.6 <1.6 <1.6
Silvex I.Ig/L 1.0 <0.12 <0.12 <0.12
GC/MS Semivolatiles -Method SW82700 -TClP leachate
Pyridine mg/L 5.0 <0.02 <0.02 <0.02
lA-Dichlorobenzene mg/L 7.5 <0.02 <0.02 <0.02
2-Methylphenol (0 Cresol) mg/L 200 <0.02 <0.02 <0.02
3+4-Methylphenol (m+p Cresol) mg/L 200 <0.02 <0.02 <0.02
Hexachloroethane mg/L 3.0 <0.02 <0.02 <0.02
Nitrobenzene mg/L 2.0 <0.02 <0.02 <0.02
Hexachlorobutadiene mg/L 0.5 <0.02 <0.02 <0.02
2,4,6-Trich lorophenol mg/L 2.0 <0.02 <0.02 <0.02
2A.s-Trich lorophenol mg/L 400 <0.02 <0.02 <0.02
2,4-Dinitrotoluene mg/L 0.13 <0.02 <0.02 <0.02
Hexachlorobenzene mg/L 0.13 <0.02 <0.02 <0.02
Pentachlorophenol mg/L 100 <0.043 <0.043 <0.043
GC/MS Volatiles -Method SW8260 258 -leachate
Vinyl Chloride I.Ig/L 0.2 <0.83 <0.83 <0.83
l,l-Dichloroethene* }.lg/l 0.7 <0.83 <0.83 <0.83
2-Butanone (Methyl Ethyl Key tone) IlE/L 200 <8.3 <8.3 <8.3
Chloroform !lg/L 6.0 <0.83 <0.83 <0.83
I Carbon Tetrachloride l!g/L 0.5 <0.83 <0.83 <0.83
1.2-Dichloroethane l!g/L 0.5 <0.83 <0.83 <0.83
Benzene I.Ig/L OS <0.83 <0.83 <0.83
Trichloroethene* I.Ig/L 0.5 2.7 B.J 1.5 B.J <0.83
Tetrachloroethene* JJg/L 0.7 <0.83 <0.83 <0.83
Chlorobenzene I.Ig/l 100 <0.83 <0.83 <0.83
Inorganics -Method SW 846_7.3.1 (Cyanide) & J.3.2 (Sulfide),
SW9045C (pH)
Reactive Cyanide mg/kg WA <0.1 <0.1 <0.1
Reactive Sulfide mg/kg N/A <50 <50 <50
Solid pH in Water @ 2S·C pH WA 9.09 9.19 9.26
Ignitability -Method SW1010A
!gnitability -9S·C ·C WA u u u
Appendix J
Resume of the Technical Memorandum Author
J. HUDSON, PE
Chemical Engineer
EDUCATION
BS, Chemical Engineering and Petroleum Refining, Colorado School of Mines, 1998
MS, Chemical Engineering, Washington State University, 2003
REGISTRATIONS/CERTIFICATIONS
Professional Engineer: Colorado (2009)
Professional Engineer: Wyoming (2009)
Professional Engineer: Montana (2009)
EXPERIENCE SUMMARY
Ms. Hudson has over 14 years of professional experience in process design engineering with a focus on
process design and water and waste water treatment design and remediation. Ms. Hudson has worked
extensively in the area of water treatment for mining, industrial, and municipal clients. She has experience
with feasibility studies, design and implementation of bench-scale and pilot-scale studies, and full scale water
treatment design and operation with the focus on water treatment technologies for metals removal for hard
rock mining related waters. She has experience with passive technologies such as in-situ bioreactor
treatment, conventional technologies including lime precipitation, clarification, and filtration, as well as
mechanical filtration and ion exchange processes. Her background includes an emphasis on plant and unit
process design for conventional mining as well as in-situ recovery operations.
PROJECT EXPERIENCE
• Feasibility Study for Potash Mine, Arizona. Process engineer for feasibility study for a Potash Mine to
determine the viability of the project. This project includes development of the bench-scale mine testing,
development of the front-end mine process preliminary design including process flow diagrams and
process and instrumentation diagrams and equipment specifications and sizing. In addition process and
domestic water treatment will be evaluated and preliminary design information developed along with a
site-wide water balance for the facility.
• In-Situ Recovery -Mining of Uranium, Cameco, North Butte and Highlands, Wyoming. Lead
process design engineer for a satellite uranium ion exchange recovery process plant design and support
engineering for uranium processing from in-situ recovery operation. Responsibilities included generation
of P&IDs, equipment sizing and specifications, preparation of bid documents, procurement support and
continued support to chosen contractor during construction activities.
• Bench-Scale Study for Mine Dewatering Treatment, Montana. Design engineer for a bench-scale
study using a High Recovery Membrane (HRM) system in conjunction with a proprietary and proven
Interstage Precipitation Reactor (IPR) process capable maximizing water recovery (>99%) and for
realizing stringent surface water quality discharge requirements in the state of Montana. With successful
water treatment, the discharge permit sought will be the first since these stringent surface water quality
discharge requirements were put into place in 1996.
• Feasibility Study for Uranium Mine Expansion, Cameco Resources, Saskatchewan, Canada.
Design engineer for the mine operational and contingency dewatering systems, development and review
of process flow diagrams and process and instrumentation diagrams, generation of required equipment
and ancillary piping and development cost estimate.
• Corrosion Control Plan and System Design, Crazy Mountain Ranch, Montana. Lead engineer for
development of corrosion control plan for control of lead under the EPA's Lead and Copper Rule in
employee drinking water supply in compliance with the Montana Department of Environmental Quality
drinking water program. Oversight and review of system design based on the accepted plan was also
provided on this project.
Tetra Tech Page 1
J. HUDSON, PE
• Drinking Water Treatment System Design, Hardin Rest Area, Montana. Lead engineer for
development and design of public water supply system at the Hardin, Montana Rest Area in compliance
with the Montana Department of Environmental Quality's drinking water regulation. Cost Estimate,
procurement assistance, contractor support and construction oversight were provided for implementation
of treatment system.
• Design of Chemical Feed System for Solution Mining Application, NGS Energy, Mississippi.
Design engineer for the chemical feed systems, including tank and piping sizing, system layout and
chemical distribution for a 3 MGD microfiltration system to treat brine solution from mining activities.
• Pilot Study for Removal of Uranium for an Acid Mine Water Treatment Facility, Superfund Site,
Washington State. Design engineer for the design, fabrication, and operation of a 1.6 gpm pilot scale
water treatment system for removal of concentrated uranium from a former uranium mine site for
determination of design parameters for full scale operation.
• Operations, Maintenance, and Monitoring (OM&M) Manual for Lime Treatment of Acid Mine
Drainage, Superfund Site, Washington State. Project engineer for the development of an OM&M
Manual for the continued operation for a lime treatment system for acid mine drainage as required by the
us EPA.
• Feasibility Study and Cost Analysis for Passive Bioreactor Treatment for Acid Mine Drainage, New
World Mining District, Cooke City, Montana. Lead Engineer for the investigation of alternative
treatment technologies for a remote abandoned mine site near Cooke City, Montana. Report included
evaluation of liquid and solid substrate bioreactors and cost analysis for pilot scale and full scale design
and implementation.
• Reverse Osmosis Acid Mine Water Treatment Facility, Beal Mountain, Anaconda, Montana. Design
engineer for the execution of the design and startup operations of a 0.5 MGD fully automated reverse
osmosis water treatment plant for an abandoned cyanide heap leach for the United States Forest Service.
Specific project experience involved equipment design and system procurement, process installation,
startup, troubleshooting and continued operations and maintenance support.
• Review of Ceramic Microfiltration System, Montana Department of Environmental Quality, Helena,
Montana. Lead engineer for technical review of a ceramic microfiltration system for a mine site for the
Upper Blackfoot Mining Complex (UBMC) east of Lincoln, Montana, including treatment feasibility and
design considerations as well as review of existing infrastructure to support proposed plant and plant
Operations and Maintenance Manual.
• Spill Prevention Control and Countermeasures Plan, Solix Biofuels, Fort Collins, Colorado. Lead
engineer for development of Spill Prevention Control and Countermeasures Plan as it applies to
production and control of non-native algae growth systems
• Drinking Water Reverse Osmosis Treatment Plant, Town of Milliken, Milliken, Colorado. Design
engineer for design of a 500 gallon per minute groundwater treatment plant for potable water using
reverse osmosis technology. Design involved fully automated process control of all equipment and
instrumentation, piping design, construction observation, plant startup and troubleshooting, operator
training and ongoing instrumentation calibration and maintenance.
• Acid Cheese Whey Treatment, Sinton Dairy, Colorado Springs, Colorado. Design engineer for
research and implementation of a solution for COD and TSS reduction in an acid cheese whey waste
stream. Design will save client over $300,000 per year in treatment costs currently paid to the POTW.
• Process Water Discharge Permit, Sterling Ethanol, LLC., Sterling, Colorado. Lead Engineer for
obtaining discharge permit for ethanol plant discharge water as required by the NPDES program. Project
includes interaction with state and local agencies as necessary and coordination with client and
contractors to obtain information pertinent to discharge.
Tetra Tech Page 2
Appendix K
Signed Technical Memorandum
[ Ie) TETRA TECH
Technical Memorandum
To: Jo Ann Tischler
Company: Denison Mines (USA) Corp.
From: Jen Hudson
Date: June 14, 2013
Re: Review of Chemical Contaminants in Dawn
Mining Company Midnite Mine (DMC)
Uranium Material to Determine Worker
Safety and Environmental Issues and
Chemical Compatibility at the Denison
Mines White Mesa Mill
------------------------------------------------------
....
J,~tN ~~ ~llCl~Q~'--
Project #: 114-181850/300
Introduction
This report summarizes the assessment of the Dawn Mining Company's ("DMC") water
treatment plant ('WTpn) solids ("Uranium Material") to be transported from the DMC Midnite
Mine, Wellpinit, Washington to determine whether processing the Uranium Material at the
Denison Mines (USA) Corp. ("Denison") White Mesa Mill (the "Mill") may pose any worker safety
or environmental hazards, or may be incompatible with the Mill's existing tailings system. The
results will provide information to Denison to determine the requirements, if any, for changes to
worker safety practices, or potential incompatibilities to the White Mesa Uranium Mill for the
processing of this Uranium Material as an alternate feed material. This report will also provide
comparison of constituents of the Uranium Material and the Denison groundwater ("GW")
monitoring program to identify any constituents which are not covered under the Denison GW
monitoring program and whether these additional parameters need to be added to the sampling
requirements.
The following questions were considered for the evaluation of potential safety and
environmental hazards and compatibility with the Mill's tailings system and GW monitoring
requirements:
1) Will any constituents of the Uranium Material volatilize at the known conditions on
the Mill site or in the Mill circuits? If so, will they create any potential environmental,
worker health, or safety impacts?
2) Will the Uranium Material or any of its constituents create a dust or off-gas hazard at
the known conditions on the Mill site or in the Mill circuit? If so, will they create any
potential environmental, worker health, or safety impacts?
3) Will any constituents of the Uranium Material react with other materials in the Mill
circuits?
4) Will any constituents of the Uranium Material create any impacts on the tailings
system?
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5) Does the Uranium Material contain any constituents that are not present in the
current Mill GW monitoring program and not sufficiently represented by the Mill's
groundwater monitoring analyte list and need to be added to the analyte list?
6) What, if any, limitations on feed acceptance criteria or added operational controls are
recommended in connection with processing the Uranium Material at the Mill?
An evaluation of the regulatory status of the Uranium Material relative to the Resource
Conservation and Recovery Act ("RCRA") regulations is provided in a separate technical
memorandum.
1.0 Basis and Limitations of this Evaluation
The Uranium Material to be processed at the Mill consists solely of the Uranium Material
produced from the existing DMC WTP. The Uranium Material was assessed to determine if it
was, or contained, a listed Hazardous Waste under RCRA. In addition, historical Uranium
Material data were reviewed and three solids samples were recently analyzed for the following
RCRA characteristic hazardous waste properties: total uranium, total mercury, total metals,
toxicity characteristic leaching procedure ("TCLP") metals and mercury, Lead-210, isotopic
thorium, total alpha emitting radium, volatile organic compounds ("VOCS"), semi-volatile organic
compounds ("SVOCs"), pesticides, herbicides, inorganics (reactive cyanides and reactive
sulfides), and ignitibility.
Information presented in Table 1 details potential incompatibilities and chemical hazards
associated with constituents within the Uranium Material. The historic water quality results of
the WTP influent are presented in Table 2. Historic Uranium Material Total concentration data
for uranium and radium-226 are presented in Table 3. Table 4 presents historic and current
Uranium Material Metals Toxicity Characteristic Leaching Procedure ("TCLP") analysis for
evaluation of RCRA characteristics; Table 5 includes Uranium Material Total analyses for
evaluation of RCRA listed hazardous waste properties; the comparison of the Uranium Material
and Mill tailings composition for Cell 4A or 48 is included in Table 6.
The following contamination evaluation is based on :
1. Current Midnite Mine WTP Uranium Material analytical data
2. Material Safety Data Sheet ("MSDS") for polymer in Midnite Mine Uranium Material
(Attachment 1)
3. Historic Midnite Mine Water Quality and Uranium Material analytical data
4. Radioactive Material Profile Record ("RMPR") for the DMC Midnite Mine Uranium
Material
5. Denison estimated composition data for tailings
6. Current technical literature from the internet and other sources on performance of liner
materials
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2.0 Site History and Background
The Midnite Mine Superfund Site ("Site") is an inactive open-pit uranium mine that is currently
administrated by the Environmental Protection Agency ("EPA") Region 10 under the
Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), also
known as Superfund. The Site EPA Identification Number is WA980978753.
The Site is located on the Spokane Indian Reservation in eastern Washington State,
approximately 48 air miles northwest of Spokane (Figure 1). These lands are owned by the
federal government and held in trust for the Spokane Tribe of Indians ("Tribe") and individual
tribal members.
Uranium was discovered on the site in 1954. The prospectors and several tribal members
subsequently formed Midnite Mines, Inc. and acquired the mining leases at the Site. Midnite
Mines, Inc. then joined with Newmont Mining Company ("Newmont") to create the DMC, with
Newmont Mining Company as the 51 percent shareholder and Midnite Mines, Inc. owning 49
percent. Newmont USA Limited is the corporate successor of Newmont Mining Company and
continues to be the majority shareholder of DMC (EPA, 2006).
The mine operated from 1954 until 1965, providing uranium under contracts with the United
States Atomic Energy Commission ("AEC"). The mine went into standby from 1965 and
resumed mining in 1969. The ores were milled at the DMC Mill site, located near Ford,
Washington. Mining was suspended in 1981 due to decreases in uranium prices and never
resumed . The Mine was regulated by several United States Department of the Interior
("USDOI") agencies, including U.S. Geological Survey, U.S. Bureau of Mines, and U.S. Bureau
of Land Management ("BLM") Minerals Management Service. The Bureau of Indian Affairs
("BIA") represented the Tribe and individual tribal allotment owners in matters related to leases
and royalties.
An estimated 5.3 million tons of ore and proto-ore (i.e., low-grade mineralized rock) and 33
million tons of waste rock were removed from nine pits between 1955 and 1981 . All but two of
the mine pits have been backfilled using waste rock. The last two pits to be mined consisted of
Pit 3 and Pit 4. These pits were not backfilled and remain open (EPA, 2006). Several
reclaimed waste rock piles remain on the mine property and an estimated 2.4 million tons of ore
and proto-ore were stockpiled and currently remain on Site.
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Seep and Surface Water Collection System
In the late 1970s, seeps with dissolved ore-derived constituents were observed at the toe of the
largest waste rock piles at the Midnite Mine. The BlM ordered DMC to construct a control pond
(the Pollution Control Pond, or "PCP") in 1979 to capture the seeps for evaporation. Following
the suspension of mining in 1981, DMC began pumping water from the PCP to the now inactive
Pit 3 in response to growing quantities of water in the PCP and newly identified seeps at the
base of the largest waste rock pile. Since cessation of mining operations, mine site surface
runoff water has been collected in engineered channels and diverted to the inactive open mining
pit, Pit 3. In addition, natural ground water from the ore zones of the pits has flowed into and
accumulated in the two open mining pits, Pit 3 and Pit 4, at the site. In February of 1985, DMC
applied to the EPA for a National Pollution Discharge Elimination System ("NPDES") permit to
allow for the discharge of treated water from those pits and other waters collected on the site.
In September of 1986, the EPA issued DMC an NPDES permit.
In 1987 a Compliance Order was issued by EPA under the Clean Water Act ("CWA") NPDES
program requiring DMC to eliminate discharges of pollutants to waters of the United States
above the limits in the existing NPDES Permit. Subsequently, DMC developed a seep
collection and pumpback program that collected water from Site drainages and returned them to
the PCP and Pit 3. Existing seep and surface water collection occurs at six specific locations
throughout the Midnite Mine Site as part of this seep collection and pumpback program
including the PCP. Pit 3 water consists of mine site waters collected and pumped from the seep
collection and pumpback program, direct precipitation and local mine surface runoff in the
immediate area of Pit 3, and natural ground water inflow from the Pit 3 ore zones. The water
that accumulates in Pit 4 consists of direct precipitation, groundwater inflow, and surface runoff
in the immediate area of Pit 4. All waters collected in the seep collection and pumpback system
are derived from seeps from waste rock piles or surface runoff at the Site. The seep collection
and pumpback system does not collect water from any areas that have ever been known to
contain or currently contain any listed hazardous wastes or from any operations other than the
mining of natural uranium ores.
In 1988, DMC built a water treatment plant at the Site to treat the accumulating water in the
open pits. In 1991, the BlM issued an order requiring DMC to dewater the open pits for
compliance with the NPDES permit issued in 1986, and in 1992 the WTP began treating pit
water. These waters contain primarily metals, sulfate, and uranium.
There are no shop areas, petroleum tanks, or other sources of hydrocarbons at the mine site
with the exception of a 300 gallon diesel fuel tank for the Pit 4 pump, and a 300 gallon tank of
gasoline for WTP equipment. The diesel fuel tank and pump are located in secondary
containment near Pit 4 with a maximum volume stored of 300 gallons and the 300 gallon
gasoline tank is located next to the WTP. These fuels are stored and managed separately from
the Uranium Material and have not impacted the Uranium Material in the past, nor do they have
a reasonable potential to do so in the future. The constituents precipitated from the WTP
influent are derived from flow of natural preCipitation through uranium mine waste rock and
natural ore, collected surface runoff from natural materials, and natural ground water inflow from
the ore zones into one of the two remaining open pits, Pit 3 and Pit 4 as discussed above.
5
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Water Treatment Plant Process Description
The WTP is a conventional lime treatment high-density solids process in which the metals and
uranium are precipitated out in the treatment process, and includes addition of barium chloride
for radium removal. A polymer coagulant is added and the resultant slurry is settled and filtered
to produce a solution free of solids for surface discharge under the CWA NPDES program and
EPA CERCLA program. The precipitate is currently centrifuged and the final solids contain on
average 0.18 wet weight percent uranium (0.21 wet weight percent U30 a) at an average
historical solids content of 15 percent. 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 0.63 wet weight percent
U30 a). As uranium ores are typically evaluated on a dry percent U30 a basis, the actual (dry)
percent U30 a of the Uranium Material is estimated to be approximately 1.4 percent U30 a.
The WTP is typically operational from early May through the end of October and operates 24
hours per day, four days per week. WTP influent is derived from approximately 400 gallons per
minute ("gpm") influent from Pit 3 and approximately 50 gpm influent from Pit 4. The pit waters
are pumped to the WTP using positive displacement pumps which are piped separately to the
WTP through polyethylene piping. The WTP reagents are pre-mixed in individual mixing tanks
prior to addition to the treatment stream. The hydrated lime and flocculent are pre-mixed using
makeup water from Pit 4 while the barium chloride is mixed with potable water.
Barium chloride is added to the influent water stream, which is then mixed with approximately
90 gpm from the clarifier bottoms (clarifier underflow) to increase the overall final WTP solids
density. Then hydrated lime is added for the precipitation of uranium and metals. Waters
recovered from the dewatering process are also added back to the process stream at this point.
An anionic water soluble polymer (Neo Solutions, NS-6852) is subsequently added as a
coagulant to facilitate clarification.
This process stream is then sent to one of two clarifiers. The precipitated solids are drawn from
the clarifier bottom and, as mentioned previously, approximately 20% of the clarifier underflow
(approximately 90 gpm) is pumped back to the beginning of the process to increase overall
WTP solids density. The liquid fraction of the remaining process stream (approximately 360
gpm) is decanted from the top of the clarifier for further treatment and discharge separate from
the solids, while the remaining solids fraction from the clarifier underflow is sent to the centrifuge
for dewatering. The centrifuge will be replaced for the 2011 operating season with a hydraulic
filter press as discussed in more detail below.
The dewatered solids are currently transferred from the centrifuge to the hauling truck via a
discharge conveyor. The transport truck is housed within the WTP building and remains in that
location until it is hauled for final disposal, thereby eliminating any opportunity for other waste
materials to be introduced into the Uranium Material.
The time period from 2001-2008 is the most representative of treatment volumes processed in
the WTP. Before this time period, pit dewatering and other site activities increased the volumes
treated. Therefore these are the years used for this analysis.
6
[ It) TETRA TECH
From 2001 through 2008 the WTP process produced between 164,000 dry Ibs and 393,500 dry
Ibs per year (82 to 194 dry tons per year) of treatment solids (average 294,700 dry Ibs or 147
dry tons). The maximum annual total volume of Pit water treated was approximately 76.5
million gallons for the period of 2001 through 2008. Volumes vary depending on how much
precipitation the site receives in a given year.
The plant will be modified for the 2011 operational season, and the centrifuges currently used
for Uranium Material dewatering will be replaced by a hydraulic filter press. It is expected that
the same water soluble polymer will be used for coagulation; however the polymer application
rate may be increased from the current rate to improve the dewatering characteristics of the
solids. The Uranium Material solids percent is expected to increase from an average of 15
weight percent solids to between 25 and 45 percent. The total wet concentrations of the
constituents present in the Uranium Material are expected to increase by 67 to 300 percent from
the analytical values reported for the current Uranium Material as a result of decreased water
content due to dewatering with the filter press. The dry concentrations should not change.
In addition, a Remedial Investigation/Feasibility Study (RI/FS) was completed on 9/30105 for the
Midnite Mine. The Selected Remedy for the Site is Alternative 5a (Complete Pit Backfill with
Passive Drains and Ex-Situ Water Treatment) of the FS. Based on the FS and issued in the
Record of Decision (ROD) as the Selected Remedy ("Remedy), Pits 3 and 4 will be backfilled,
waste rock and proto-ore will be moved and capped, and a new passive water collection system
will be installed to capture groundwater from these and other backfilled pit areas. The surface
water management will be designed to divert surface flows around sources of contamination
and therefore minimize the volume of water to be treated after the Remedy is implemented.
The existing WTP is located on a waste rock pile that must be removed for the Remedy.
Therefore, a new water treatment plant will be built before construction of the Remedy begins It
is estimated that the construction will begin in the beginning of 2013 and will require
approximately 2 years ending at the end of 2014, and the new WTP must be capable of treating
water at a rate of 1,000 gpm year round for the construction phase. The new WTP will be
comparable to the current treatment employed using lime and barium addition for removal of
constituents from the feed water. This higher design flow will allow for rapid dewatering of the
pits during backfilling, as well as groundwater collection and surface water collection treatment.
After construction, it is expected that the flows will be reduced to an ultimate annual value of 65
million gpm and will take an estimated 6 to 7 years to reach these reduced flows.
The water quality during construction is assumed to be the same composition as currently is
captured and treated, and it is expected that the water quality after implementation of the
Remedy will be improved from current water quality.
The estimated production of dry Uranium Material before during and after the Remedy is
implemented is projected to range from 996 tons per year during the two year construction
phase down to 2.8 tons after the remedy has become effective .
3.0 Assumptions Regarding White Mesa Mill Processing of the Uranium Material
This evaluation was based on the following process assumptions:
7
[ it:) TETRA TECH
a) The Mill will process the Uranium Material either in the main circuit mixed with conventional
ore or in the alternate circuit alone.
b) The Uranium Material will be delivered to the Mill in conventional covered end or side dump
haul trucks, which will be unloaded onto the Mill's ore pad. It will be temporarily stored on
the ore pad, similar to conventional ores, pending processing.
c) If the Uranium Material is processed in the Mill circuit, it will be added in a manner similar to
that used for the normal processing of conventional ores and other alternate feed materials.
It will either be dumped into the ore receiving hopper and fed to the SAG mill, run through an
existing trommel before being pumped to Pulp Storage, or may be fed directly to Pulp
Storage.
d) If the Uranium Material is processed in the alternate circuit, it will be dumped to the filter
cake acid tank.
e) The Mill does not anticipate any significant modifications to the leaching circuit or recovery
process areas for the processing of the Uranium Material.
f) The Uranium Material may be processed in combination with other approved alternate feed
materials.
g) Tailings from processing of the Uranium Material will be sent to Cell 4A, or Cell 48, or
potentially to subsequently-constructed tailings cells.
h) Tailings from the Mill circuit historically disposed of in Cell 3 will be sent to Cell 4A or Cell
48, and thereafter to sUbsequently-constructed tailings cells.
4.0 Chemical Composition of the Uranium Material
The characterization data and the RMPR provided include historical WTP influent water quality
data, historical Uranium Material analysis, and analysis of representative Uranium Material
samples in 2010. The 2010 Uranium Material analyses included three WTP solid samples
analyzed for radionuclides, recoverable metal values, RCRA regulated organic and inorganic
contaminants, diesel and gas range organics ("DRO" and "GRO") as well as for RCRA hazardous
waste characteristics. Radionuclide analyses included Lead-210, isotopic thorium, gross alpha
and beta, and total alpha emitting radium. Additional parameters including nutrients (ammonia
and nitrate/nitrite), and other non-metals were included in the analysis to assess compatibility
with existing tailings and process chemicals at the White Mesa Mill. The total uranium values
from the 2010 sampling results indicate average uranium concentration in the sludge to be
15,333 mg/kg (1.5 percent Uor 1.8 percent U30 e) on a dry basis and are consistent with the
historical uranium values for the Uranium Material.
The TCLP results, RCRA characteristic test results, and the total constituent values of the
Uranium Material were evaluated and presented in Technical Memorandum: 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, 2011).
As a result of the RCRA characteristic waste evaluation, it was concluded that the Uranium
Material does not exhibit any of the RCRA characteristics of ignitability, corrosivity, reactivity, or
toxicity for any constituent. The sampling results of the RCRA characteristic evaluation are
consistent with the constituents found in the total constituent evaluation.
8
[ It) TETRA TECH
The historical water quality data indicates that influent water parameters are relatively consistent
over the WTP operational history (Table 2). Based on process history of the source of the
Uranium Material organic constituents of any are not expected to be present and have not
historically been analyzed in the WTP influent, or the final Uranium Material; however,
comprehensive laboratory analysis of recent Uranium Material samples, including analyses for
organic compounds, is included in this report. The Uranium Material test results presented
herein are taken to be representative of the range of material characteristics of the Uranium
Material. As a result, these studies provide sufficiently representative characterization to assess
the regulatory status, worker safety environmental hazards, and chemical and processing
properties of the Uranium Material.
The list of constituents sampled for in the Uranium Material, included in Table 5 were generated
from the parameters in the White Mesa Mill groundwater permit and annual tailings
characterization program as appropriate to the Uranium Material.
4.1 Organic Constituents
The sampling results for the total volatile organic compounds in Table 5 indicate that acetone,
methylene chloride, and toluene were reported at very low concentrations in the three samples
for total analysis. Acetone was reported at concentrations ranging from 22 milligrams per
kilogram ("mg/kg") to 33 mg/kg with an average value of 28 mg/kg. Methylene chloride was
reported at concentrations ranging from 3.7 mg/kg to 5.8 mg/kg with an average value of 4.4
mg/kg. Toluene was reported at concentrations ranging from 1.5 mg/kg to 2.7 mg/kg with an
average value of 2.1 mg/kg. However all of these constituents were also detected in the
method blanks for the coinciding sample runs. Chloroform was detected in the three samples
just above the method detection limit ("MOL"). The method blank samples did indicate low levels
of total chloroform; however the detection of chloroform in the blank was below the MOL and
was therefore not reported by the laboratory, as stated in the email from laboratory personnel
Jeff Kujawa (Attachment 2). As indicated; chloroform , methylene chloride, and toluene were
therefore present due to laboratory interferences, and not present in the Uranium Material.
Trichloroethene (or trichloroethylene) was reported at very low concentrations from the TCLP
testing of only two of the Uranium Material samples with concentrations ranging from 1.5
micrograms per liter n.lg/L") to 2.7. ,",giL with an average concentration of 2.1 ,",giL However,
trichloroethene was detected in the leachate method blank at 3.3 ug/L which was above the
MOL, but below the reporting limit ("RL"). Two of the three associated samples had detectable
amounts less than the RL and less than 10 times the amount found in the method blank, so the
samples were qualified as "U", raising the concentration to the RL (5 ug/L).
Review of the site operational history, WTP processes and chemicals, as well as sample
collection, preservation and shipping methods did not identify any source of potential sample
contamination for these constituents.
Since these compounds were present in the method blank and there are no known sources for
these constituents from the Site or from the sampling preservation or shipping methods, their
detection is apparently due to laboratory influences, and does not indicate they are present in
the Uranium Material. These are common laboratory solvents and there are multiple laboratory
9
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pathways that could introduce them during analytical processes, including the use of methylene
chloride for extraction of SVOCs in other analytical procedures.
The sampling results for the total herbicides and total organochlorine pesticides (Table 5)
indicate that there was no detection of any of the constituents tested.
The sampling results for the total semi-volatile organic compounds in Table 5 indicate that there
was no detection of any of the constituents tested for. Therefore the results of the VOC and
SVOC analyses for the Uranium Material indicate that there are no volatile or semi-volatile
components present in the Uranium Material to be shipped to the White Mesa Mill.
ORO and GRO were analyzed to ensure that these components were not present in the
Uranium Material; test results are included in Table 5. The ORO and GRO results indicate no
detection of these constituents.
4.2 Inorganic Constituents
4.2.1 Non-Metal Inorganic Compounds
Five non-metal inorganic constituents were identified in the Uranium Material: ammonia,
nitrate/nitrite, fluoride, chloride, and sulfate. It was determined in the RCRA analysis that these
constituents are not hazardous compounds as contained in the Uranium Material.
The constituent with the highest concentrations in the Uranium Material was sulfate with a
concentration of 17,000 mg/kg in all three samples. All other constituents were present at much
lower levels with concentrations ranging from approximately 3 mg/kg to around 40 mg/kg.
4.2.2 Metals
The three Uranium Material samples were analyzed for total metals, total alkali metals, and total
alkaline earth metals. According to the sampling results, of the 20 non-radioactive metals and
metalloids analyzed in the Uranium Material, 14 were present including: barium, beryllium,
cadmium, calcium, chromium, cobalt, copper, iron, lead, manganese, nickel, selenium, silver, and
zinc. These constituents can be categorized based on their elemental characteristics and
chemical properties as follows:
Class Component of the Uranium Material
Alkaline Earths Barium Beryllium . Calcium
Cadmium, Chromium, Cobalt, Copper,
Transition Metals Iron, Manganese, Nickel, Silver, Zinc
Other Metals Lead
Metalloids Selenium
With the exception of barium, the metal species presented above are natural constituents in
uranium ores and surface and ground waters in contact with these ores at the Site. The source
for the barium is the barium chloride added to the water treatment process for removal of radium
from the influent water. Calcium is a natural constituent in the influent water to the treatment
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system; however, additional calcium is introduced into the Uranium Material by addition of lime
for metals precipitation.
The Uranium' Material samples were not analyzed for their actual mineral composition. As a
result, their exact compound forms have not been identified. Assumptions regarding their form,
based on process knowledge and prior experience with leached metal tailings, are discussed
below.
It should be noted that the chemical properties and reactvities discussed below for apply to
metals, hydroxides, or oxides in pure or high concentrations in dry or "neat" form, not to
precipitated salts or sludges in a wet matrix. These properties are discussed below for
completeness and conservatism of the assessment.
4.2.3 Potential Effects in Mill Process
The metals in the Uranium Material are expected to be in the form of metal hydroxides and
metal sulfates. The overall maximum mass contribution of 197 dry tons per year of Uranium
Material is not expected to have a significant effect on the concentrations of constituents in the
impoundments. Historical data for Cell 3 in 2004 at the White Mesa Mill are presented in the
Statement of Basis for the Utah Groundwater Discharge Permit for the Mill. The mass in Cell 3
at that time was estimated to be 1,769,000 dry tons of tailings material. Cell 3 is full and is no
longer able to accept process residuals from the Mill. The tailings from the Uranium Material to
be processed will be sent to either Cell 4A or Cell 4B or to a subsequently-constructed tailings
cell. It is assumed that the composition of the Cell 4A and Cell 4B tailings material will be
similar to Cell 3. Therefore the compositional data from Cell 3 has been used to determine the
impact of the Uranium Material to the tailings cells in the future. Table 5 presents the
comparison of estimated Mill tailings composition before and after processing of the Uranium
Material. The analysis assumed for the first two years, the treatment plant will be operated
under the existing historical conditions at an estimated 76.5 million gallons (MG) of water to be
treated with a sludge production of 29 dry tons of Uranium Material. The construction of the
Remedy is anticipated to begin in Year 3 and last for two years. The estimated volume treated
and sludge produced for Years 3 and 4 are 405 MG and 154 tons of dry Uranium Material
produced. Once construction is complete, it is estimated that treated flows will decrease from
the current value of 76.5 MG (yielding 29 dry tons per year of solids) to an ultimate value of 65
MG (yielding less than 25 tons per year of solids) over a 6 year period. For the current analysis
as detailed in Table 5, years 5-10 were estimates based on a reduction of 20 percent per year
of the difference between the existing flow (76.5 MG) and the ultimate flow (65 MG) annually.
The analysis compares the tailings composition before and after processing of the Uranium
Material on an annual basis for ten years. It is estimated that either Cell 4A or 4B will take
approximately this long to fill to capacity. The results indicate that the impact to the tailings cell
for the metals contained in the Uranium Material is minimal when comparing the overall quantity
to be processed. Over the ten year period, it is estimated that tailings from approximately 283
dry tons of Uranium Material in total will be added to the estimated total of 2.15 million tons of
tailings from current operations, which is equivalent to less than 1/1 ooth of one percent of the
total or the equivalent of a few hours of conventional ore production, that is, the contribution of
the Uranium Materials to the tailings system will be negligibly small.
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All sampled metals have been introduced into the milling process and impoundments at the Mill.
All analyzed radio-isotopes have already been introduced into the milling process at the Mill as
a result of processing uranium ores as presented in the historic data from cell tailings. All
constituents analyzed and detected in the Uranium Material except barium are natural
constituents in the mining and processing of uranium ores and therefore are expected to be
present at the Mill as a result of processing of uranium ores.
Most of the metal species resulting from natural ores in the Uranium Material are present at
parts per million ("ppm") levels or lower (or at percent levels in the highest case). The
concentrations of these constituents will be further reduced by introduction into the leach circuit,
where they will be present at fractional ppm levels or lower in large volumes of aqueous acid
solution. These constituents will be processed in the same manner as natural uranium ores
processed at the Mill and will be discharged to the Mill tailings system just as the uranium ores
currently are.
In addition to these constituents, barium chloride is added to the WTP feed water for radon
removal, calcium is added in the form of lime for metals precipitation of the WTP feed water,
and an anionic water-soluble polymer is added during the metals precipitation process at the
OMC WTP site and are discussed below.
The majority of the metal hydroxides, hydrates, and other mineral salts will be converted to
sulfate salt forms in the leach system. The insoluble forms will be precipitated with the solids
removed from the alternate feed circuit.
All the known Uranium Material components in their anticipated oxidation or mineral states are
compatible with aqueous sulfuric acid, which will be used for leaching the Uranium Material, and
all other chemicals and materials to which they may be exposed in the Mill.
Since the metals, hydroxides, hydrates and other salts are expected to be converted to
insoluble sulfates, it can be assumed that the non-uranium constituents that enter the leach
system will leave the leach system, proceed no further than the CCO step or Tank 11A or 11 B,
and be discharged from the circuit to the tailings.
Barium chloride is added to the WTP feed water to remove radium from the stream. The
average barium concentration in the feed is 7,733 ppm and is expected to be in the form of
barium sulfate. The data from Cell 3 indicate that barium has already been introduced into the
Mill process from other alternate feed materials, and the assumption is that barium will also be
present in the Cell 4A and 4B tailings from such other sources. Barium concentrations as high
as 43,000 ppm have been processed to date at the Mill with no adverse process, environmental,
or safety issues. Incompatible materials listed for barium sulfate include phosphorous and
aluminum. The barium will not be exposed to these materials, and the addition of sulfuric acid
at the Mill will not create any additional worker safety or environmental hazards.
Some of the metals and metal hydroxides, in dry forms or at high concentrations, are known to
decompose at high temperatures, breaking down into volatile oxide forms (such as As20 5
decomposing to a trioxide). However, as described above, the metals and metal hydroxides will
be short-lived in the process, as they will be converted into aqueous sulfates in the leach acid.
The metals and their hydroxides will not be exposed to any conditions that can produce
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gaseous byproducts. The sulfate forms are stable and non-reactive and will be precipitated from
the circuit in post-leach steps and discharged to the tailings system.
The polymer added for coagulation of the metal precipitates in the DMC sludge production
process is NeoSolution NS-6852. The polymer is a stable compound and in its pure form may
result in generation of heat upon addition of a strong oxidizing agent according to the MSDS
(Attachment 1). The polymer will be introduced to the circuit not as pure polymer, but primarily
bound within the precipitated solids from the WTP. Since there are no strong oxidizers in the
milling process, and the Uranium Material containing the polymer will be introduced immediately
into aqueous solutions in the leach circuit, the polymer will not cause any adverse reactions or
polymerization as a result of processing at the Mill. It is expected that the polymer will be
broken down into smaller inert organic molecules by the addition of acid, and will have the same
fate as other anionic polymers used in the Mill's clarifiers with no adverse effects to the Mill
process.
4.2.4 Alkaline Earth Metals
Metal oxides are more reactive in an acid leach system than metal hydroxides or metal sulfates.
Although the metal compounds will be primarily metal hydroxides and metal sulfates, the
chemical reactivity discussed below is focused on the reactivity of the metal oxides to provide
conservatism for the worker safety evaluation. Although in some circumstances, the
introduction of oxides of alkaline earths in sufficient quantities into an acid leach circuit has the
potential to result in unwanted excess chemical reactivity, this situation will not result from
processing the Uranium Material at the Mill for the reasons described below.
Manufacturer's MSDS and National Institute for Occupational Safety and Health ("NIOSH")
safety hazard information indicate that in pure form or high concentration the alkaline earths:
barium, beryllium, and calcium are reactive with water resulting in an exothermic (heat
generating) reaction if they are present as a pure or high concentration product (percent levels
or more).
The historical tailings data for Cell 3 indicate that barium has been introduced into the tailings
system, and it is assumed that tailings similar to the tailings historically sent to Cell 3 will now be
sent to Cell 4A and 48, and barium concentrations in Cell 4A and 48 will be comparable to Cell
3. For this analysis, historical Cell 3 barium concentrations were used. During processing of
the Uranium Material, calcium may be present at 15,667 ppm and barium and beryllium may be
present at 7,733 ppm and 35 ppm, respectively, in the ore feed area to the circuit (Table 6).
These constituents have been introduced to the Mill process in other feed materials in
concentrations as high as 217,000 ppm for calcium, 43,000 ppm for barium , and 105 ppm for
beryllium. The resulting increase in concentration to the tailings is 21.9 ppm for calcium, 0.049
ppm for beryllium, and 10.8 ppm for barium, or increases of 22.7 and 11 .2 percent for calcium
and barium, and an imperceptible 0.051 percent increase for beryllium, based on the
concentrations in Cell 3. These low levels will not pose a heat of reaction hazard with the water
rates in the dust control system. Any water reactivity will also be quenched immediately by the
large volume of sulfuric acid solution in the leach system. Pure or high concentrations of these
hydroxides in dry form can also decompose under heat to generate hazardous byproduct gases.
However, these materials will not be exposed to heating conditions during processing at the Mill.
As discussed above, the metals and metal oxides are expected to be converted into metal
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sulfate salts in the acid leach system and be precipitated with solids removed from the post
leach thickeners in the CCO circuit. These metals will be removed from the Mill process in the
CCO thickeners and then discharged to the tailings, and therefore will not be exposed to the
elevated temperatures further in processing of the uranium.
4.2.5 Transition Metals
Chemical behavior and incompatibilities for the transition metals vary, so they are discussed
individually in this section.
Although in some circumstances, the introduction of oxides of the transition metals in sufficient
quantities into an acid leach circuit has the potential to result in unwanted excess chemical
reactivity, this situation will not occur from processing the Uranium Material at the Mill for the
reasons described below.
Cadmium oxide is reactive with pure product magnesium and decomposes at elevated
temperature to release cadmium fumes. The metal compounds will be present as hydroxides
and sulfates and therefore there will be no pure metal magnesium for reaction with cadmium
oxide. Cadmium oxides are insoluble in water and soluble in and compatible with acids and
alkalis. They will be converted into sulfates in the acid leach system and will be precipitated and
discharged into the tailings and will not be subject to elevated temperatures during processing.
They do not pose any incompatibility hazards in the Mill process.
Chromium oxides are oxidizers themselves and are incompatible with combustible organic
materials due to the potential for ignition. However, chromium oxides will not be present and
the metal hydroxides will be precipitated and discharged into the tailings before the aqueous
streams are contacted with organic hydrocarbons in subsequent uranium concentration steps,
eliminating any contact with organic materials.
Cobalt oxides are insoluble in water and slightly soluble in and compatible with acids and
alkalis. They will be converted into sulfates in the acid leach system and will be precipitated and
discharged into the tailings. Cobalt oxides do not pose any incompatibility hazards in the Mill
process.
Cupric oxides are insoluble in water and soluble in acids, and toxic metal fumes may form when
heated to decomposition. However cupric oxides are only present at trace levels and will be
converted into sulfates in the acid leach system and discharged into the tailings and will not be
subject to elevated temperatures during processing. They do not pose any incompatibility
hazards in the Mill process.
Iron oxides are reactive with calcium hypochlorite, carbon monoxide gas, and hydrogen
peroxide. The Uranium Material will not be in contact with any of these materials at any time in
the Mill process.
Other compounds of iron, (i.e. chlorides and sulfates) are compatible with the solutions in the
leach circuit. They will be precipitated as sulfates or other insoluble salts, and discharged to the
tailings. They do not pose any incompatibility hazards in the Mill process.
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Manganese and its oxides are not soluble in water but are soluble in strong acids. They will be
converted to sulfates in the acid leach system, and will be precipitated and discharged to the
tailings. They do not pose any incompatibility hazards in the Mill process.
Nickel and its oxides are reactive and incompatible with gaseous iodine and hydrogen sulfide.
The Uranium Material will not be in contact with either of these materials at any time in the Mill
process and therefore do not pose any incompatibility hazards.
Silver oxide in pure or high concentration poses a fire and explosion risk in contact with organic
materials and ammonia. Silver oxides will not be in contact with organic materials or ammonia
at any time in the Mill process. Insoluble salts of silver will be precipitated with solids removed
from the post-leach thickeners in the alternate feed circuits and will be discharged to the tailings
and will proceed no further with the uranium through subsequent processing steps. Although
the Uranium Material contains trace amounts of ammonia, the concentrations are not sufficiently
high to create instability within the Uranium Material as delivered to the Mill. Also, within the
processing at the Mill, concentrated uranium brines are precipitated with ammonia at this later
phase, the insoluble silver salts will already have been removed from the process and the solids
sent to the tailings prior to the ammonia precipitation of uranium, and silver oxides will not come
into contact with the ammonia.
Zinc and its oxides are stable and insoluble in water, but soluble in most acids and bases at
ambient temperatures. They will be converted to sulfates in the acid leach system, and will be
precipitated and discharged to the tailings. They do not pose any incompatibility hazards in the
Mill process.
4.2.6 Other Metals
Although in some circumstances, the introduction of oxides of lead in sufficient quantities into
the acid leach circuit has the potential to result in unwanted excess chemical reactivity, this
situation will not result from processing the Uranium Material at the Mill for the reasons
described below.
Manufacturers' MSDS and NIOSH safety hazard information indicate that lead and its oxides
are incompatible with strong oxidizers, halogen gases, and some acids.
Oxidants are sometimes added to the leaching system at the Mill to improve uranium recovery
from some types of feeds . Sodium chlorate, the typical oxidizing agent used in the Mill's leach
circuit is a moderately effective oxidizer, but not considered a strong oxidizer. It is introduced in
a relatively dilute aqueous solution in the leach system. Lead is present in low concentrations in
the Uranium Material with an average value of 18 ppm. As a result, hazards associated with
reactions between lead oxides with strong oxidizers are not applicable to the processing of the
Uranium Material.
The Uranium Material will not be in contact with halogen gases at any time in the Mill process.
Lead oxides react strongly with strong mineral acids such as nitric and sulfuric acids. The
sulfuric acid added to the acid leach system is relatively dilute and not an oxidizing acid. These
oxides will be converted into sulfates in the acid leach system and precipitated with the solids
removed to the tailings.
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4.2.7 Metalloids
Although in some circumstances, the introduction of selenium oxides in sufficient quantities into
the acid leach circuit has the potential to result in unwanted excess chemical reactivity, this
situation will not result from processing the Uranium Material at the Mill for the reasons
described below.
Manufacturers' MSDS and NIOSH safety hazard information indicate that selenium and its
oxides are incompatible with strong acids, organic materials, and ammonia.
Selenium oxides in pure form or high concentrations pose a fire and explosion risk in contact
with organic materials and ammonia. Selenium oxides will not be in contact with organic
materials or ammonia at any time in the Mill process. Insoluble salts of selenium will be
precipitated with solids removed from the post-leach thickeners in the alternate feed circuit and
will be discharged to the tailings and will proceed no further with the uranium through
subsequent processing steps. Although the Uranium Material contains trace amounts of
ammonia, the concentrations are not sufficiently high to create instability within the Uranium
Material as delivered to the Mill. Also, within the processing at the Mill, concentrated uranium
brines are precipitated with ammonia at this later phase, the insoluble selenium salts will already
have been removed from the process and the solids sent to the tailings prior to the ammonia
precipitation of uranium, and selenium oxides will not come into contact with the ammonia.
4.3 Non-Metals
Nitrates have been introduced into the Mill's circuit with natural ores and alternate feeds at
levels as high as 350,000 mg/kg. The average nitrate concentration in the Uranium Material is
3.1 mg/kg. The Mill has handled nitrate compounds in the Mill circuit and tailings system with
no adverse process, environmental, or safety issues.
Chlorides have been introduced into the Mill's circuit with natural ores and alternate feeds at
levels as high as 89,900 mg/kg. The average chloride concentration in the Uranium Material is
40 mg/kg. The Mill has handled chloride compounds in the Mill circuit and tailings system with
no adverse process, environmental, or safety issues.
Fluorides have been introduced into the Mill's circuit with natural ores and alternate feeds at
levels as high as 460,000 mg/kg. The average fluoride concentration in the Uranium Material is
39 mg/kg. The Mill has handled fluoride compounds in the Mill circuit and tailings system with
no adverse process, environmental, or safety issues.
Sulfates have been introduced into the Mill's uranium circuit with natural ores and alternate
feeds at levels as high as 300,000 mg/kg. Sulfates are also generated by the reaction of
sulfuric acid with other metal cations in the acid leach system. The Mill has handled sulfate
compounds in the Mill circuit and tailings system with no adverse process, environmental, or
safety issues.
Ammonia was reported at very low levels, with an average value of 8.0 mg/kg. Anhydrous
ammonia gas in high concentrations of ammonium hydroxide solutions are incompatible with
16
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strong oxidizers, halogen gases, acids, and salts of silver and zinc. Ammonia is present as low
concentration aqueous ammonium salts (chlorides and sulfates) and as mineral complexes, and
will not be present as anhydrous ammonia gas or high concentration ammonium hydroxide.
The ammonium compounds will not contact halogen gases at any time in the Mill process.
While ammonia may be present in the reactive form (ammonium hydroxide) it will be at
concentrations too low to react with the silver and zinc already present in the Mill tailings, or with
the moderate oxidizer that may be added in the Mill acid leach circuit.
4.4 Organic Compounds
As discussed in Section 4.1, there was no detection of any organic compounds sampled for with
a reasonable degree of accuracy. Although the polymer added to the feed water in the water
treatment system is organic, analytical results indicate that there are no organic compounds
present in the Uranium Material as analyzed, and therefore there will be no effect on the Mill
processing as a result of organic compounds. The organic polymer is expected to decompose
in the Mill processing and will have no affect on the on the Mill processing.
5.0 Potential Worker Safety Issues
According to manufacturers' MSDS and the NIOSH literature (2007), the primary worker health
hazards from the metal oxides are associated with inhalation of dusts and fines. If inhaled in
pure or high concentrations in dry form, the oxide dusts of the lower metals are as hazardous as
those of uranium. However, the Uranium Material is expected to have an average moisture
content of approximately 25 to 45 percent, which will minimize the potential for dusting, and
which ensures that all metal oxides will be present in the Uranium material in hydrated, not dry,
form . If required, normal dust controls, such as water sprays, can be implemented to minimize
any worker exposure to dusts from unloading operations. In addition, normal operations in this
area require the use of worker personal protective equipment for prevention of dust inhalation
and skin exposure; therefore, normal worker protections already in place will be sufficient to
prevent exposure to any additional metal oxides, sulfates, or nitrates during processing of the
Uranium Material.
6.0 Radiation Safety
The Uranium Material is derived from natural uranium ores, or through contact of surface or
groundwater with these ores. The Uranium Material contains the same radionuclides as natural
ores; however the concentrations of the uranium daughters are much lower. The concentrations
of Ra-226, Th-230 and Pb-210 are lower in the feed as a result of the low concentrations in the
feed water to the treatment plant. The concentrations of these daughter products in the feed
water are lower than the concentrations typically found in ore due to the limited solubility in
groundwater. The derived air concentrations, radiation protection measures, and emissions
control measures used for the ores and alternate feeds at the Mill are sufficiently protective for
the processing of the Uranium Material.
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7.0 Potential Air Emissions Impacts
The introduction of a solid powder like the Uranium Material to any process may produce two
potential forms of air emissions: fugitive dusts, and/or hazardous gases. Discussions in the
previous sections demonstrate that engineering controls already in place at the Mill will prevent
the generation or dispersion of both of these types of emissions. The Uranium Material will
have a moisture content of approximately 25 to 45 percent, which will minimize dusting of finely
divided and powdered alternate feed materials. In addition, the impurities will almost
immediately be converted from volatile oxides to sulfates or other stable aqueous ionic forms,
which are non-volatile and produce no off gases.
Because the metals and ions in the Uranium Material are present at trace levels, they are not
expected to generate a significant increase in load on the existing bag-house system and air
pollution control devices even if they reach the air control system as solids from spills in the pre-
leach area.
In sum, the air emissions impacts from processing the Uranium Material will not be different in
any significant way from processing conventional ores at the Mill.
8.0 Potential Effects on Tailings System
8.1 Tailings Cell Liner Material Compatibility
The Uranium Material will be received as a precipitated solid from lime treatment of the WTP
influent water. A portion of this material may be insoluble in the acid leach process at the Mill
and therefore, the discharge sent to tailings may contain some solid material ("sand"). The
remainder of the Uranium Material will be soluble and therefore be contained in the liquid phase
after processing in the acid leach system. Tailings from processing the Uranium Material will be
sent to one of two tailings cells at the Mill, Cell 4A or Cell 4B or a subsequently-constructed cell.
The solutions from the Uranium Material tailings will be recirculated through the mill process for
reuse of the acidic properties in the solution. The sands will be only a portion of the total mass
of Uranium Material sent to the Mill from the Site. However, assuming a worst case scenario
that all of the solid material ends up as sand in the tailings, it is estimated that for the main
processing circuit, the additional load to the tailings will be minimal (Table 6).
Cell 4A and 48 both have high-density polyethylene ("HOPE") liners. Cell 4A went into service in
October of 2008 and contains conventional ore tailings sands. Solutions from the Mill, starting in
July 2009, are also sent to this Cell . Cell 4B was constructed and placed in to operation in
February of 2011 and is expected to receive the same type of materials as Cell 4A when
operational.
The constituents in the sands and liquids resulting from processing the Midnite Mine Uranium
Materials are not expected to be significantly different from those in the conventional ores either
in composition or in concentration of constituents. Table 6 indicates that when comparing the
Uranium Material to the tailings, all of the constituents found in the Uranium Material are
currently processed in the Mill's main circuit and/or the alternate feed circuit in other ores and
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alternate feed materials with the exception of copper. No information on the concentration of
copper in the ores or alternate feeds is currently available but copper is analyzed under the
groundwater monitoring program.
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 tailings cells. According to Gulec, et al. (2005), a study on the degradation of
HOPE liners under acidic conditions (synthetic acid mine drainage), HOPE was found to be
chemically resistant to solutions similar to the tailings solutions at the Mill. Mitchell (1985)
studied the chemical resistivity of PVC and HOPE at a pH range of 1.5 to 2.5 standard units
using sulfuric acid. This study concluded that PVC performed satisfactorily under these
conditions and HOPE performed better and was overall more stable under these acidic
conditions.
As described above, 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 the tailings system .
Every metal and non-metal cation and anion component in the Uranium Material already exists
in the Mill's tailings system and/or is analyzed under the GW monitoring program. A summary of
the potential tailings composition before and after processing the Uranium Material using
historical data for tailings Cell 3 is presented in Table 6 for projected tailings composition before
and after processing the Uranium Material using data for Cell 4A or 48.
Every component, except copper, in the Uranium Material has been:
1. detected in analyses of the existing tailings cells liquids;
2. detected in analyses of existing tailings cells solids;
3. detected in analyses of alternate feed materials that have already been licensed for
processing at the Mill; or
4. detected in process streams or intermediate products when previous alternate feeds were
processed at the Mill.
Generally the concentrations of constituents identified in the tailings liquids or solids, feed
materials or process streams at the mill are generally comparable to the concentrations in the
Uranium Material. Due to the small annual and total quantities of the Uranium Material, an
increase in the concentration of these analytes in the Mill's tailings is not expected to be
significant. A few constituents such as barium, beryllium, silver, manganese, copper, and
calcium are present in the Uranium Material and are either present in lower concentrations in
the ores and other alternate feeds at the mill or as in the case of copper, information on
concentration in the ore and other alternate feeds was not available. Although the percent
total of these constituents contributed from the Uranium Material to the Mill Tailings in the 10
year period seems high, between 5 and 100 percent of these constituents present in the tailings
is from the Uranium Material, the total contributed tons is less than one percent of the total mass
in the Tailings Cell.
The constituents in the Uranium Material are expected to produce no incremental additional
environmental, health, or safety impacts in the Mill's tailings system beyond those produced by
the Mill's processing of natural ores or previously approved alternate feeds. Since the impacts of
19
[ it) TETRA TECH
all the constituents on the tailings system are already anticipated for normal Mill operations, and
permitted under the Mill's license, they have not been re-addressed in this evaluation.
Groundwater Monitoring Program
One difference in the milling process of Uranium Material and disposal of tails in the tailings
cells at the Mill compared to processing conventional ore, is the introduction of barium to the
tailings cells. However, as discussed above barium is currently present in Cell 3, and has been
introduced at higher concentration than in the Uranium Material, from other alternate feed
materials. Barium is not a constituent that is monitored under the Mill's GWDP. Calcium is also
contained in the Uranium Material, but is found in conventional ores and it is monitored under
the Mill's GWDP. As discussed below, there is no need to add barium to the Mill's GWDP
monitoring program.
Barium will be introduced to the Mill's tailings cells with disposal of the tailings from processing
the Uranium Material. The chemistry of the tailings cells would limit the mobility of barium due to
the abundance of sulfate in the tailings cells. The insolubility of barium in the presence of sulfate
is generally consistent regardless of the liquid medium. That is, the solubility of barium sulfate in
cold water is 0.022 mg/L and in concentrated sulfuric acid is 0.025 mg/L (Handbook of
Chemistry and Physics, 68th Edition). 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) would be negligible. Therefore, given the
strong tendency of barium to partition to solids, especially in the presence of sulfate, there is no
reasonable potential for barium to migrate to ground water from the tailings cells at the Mill in
the unlikely event of a leak in the tailings cells. Calcium Kd value in UDEQ Statement of Basis
for the permit (December 1, 2004) contains published Kd values for calcium of 5 to 100 Llkg for
sandy to clayey soils. The Kd for barium is 100 to 150,000 Llkg for the same soil types
indicating less mobility in groundwater, and Tetra Tech has therefore concluded that barium is
sufficiently represented by monitoring for calcium and has identified no technical reason to add
barium to the list of constituents monitored in ground water in the vicinity of the tailings cells.
Excluding barium, chemical and radiological make-up of the Uranium Material is similar to other
ores and alternate feed materials processed at the Mill, and their resulting tailings will have the
chemical composition of typical uranium process tailings, for which the Mill's tailings system was
designed. As a result, the existing groundwater monitoring program at the Mill will be adequate
to detect any potential future impacts to groundwater.
Conclusions and Recommendations
While concentrated levels of certain constituents in the Uranium Material may be present, no
additional material management requirements during handling and processing will be required.
The Mill has successfully implemented processing of previous alternate feeds with similar or
higher concentrations of the constituents contained in the Uranium Material. For example, the
Mill has successfully processed and recovered uranium from uranium-bearing salts, calcium
fluoride precipitates, recycled metals, metal oxides, and calcified product, all of which posed
potential chemical reactivity and material handling issues comparable to or more significant than
those associated with this Uranium Material.
20
[ it:) TETRA TECH
Based on the foregoing information, it can be concluded that:
1. All the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, already present in the Mill's tailings system or were reported in other alternate
feeds processed at the Mill , at levels generally comparable to those reported in the Uranium
Material.
2. All the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, previously introduced into the Mill's process, with no adverse effects to the
process, or worker health and safety.
3. All the known impurities in the Uranium Material have either been reported to be, or can be
assumed to be, previously introduced into the Mill tailing impoundments, with no adverse effects
to the tailings system, or human health and safety.
4. There will be no significant incremental environmental impacts from processing Uranium
Material beyond those that are already anticipated in the Final Environmental statement and
subsequent Environmental Assessments for the Mill.
S. Spill response and control measures designed to minimize particulate radionuclide hazards
will be more than sufficient to manage chemical hazards from particulate metal oxides.
It should be noted that the Uranium Material originated entirely from the contact of sources of
environmental water (surface and or groundwater) with natural uranium ore. Every constituent in
the Uranium Material, except barium, is a constituent of natural uranium ore and is present in
the Uranium Material as a result of natural leaching from uranium ore. Every constituent in the
ore is already present in natural ores including the ores stored on the Mill's ore pad, and is
already present in the Mill circuit and tailings system.
Further, the total quantity of Uranium Material is very low. The entire annual volume of Uranium
Material to be shipped to the Mill constitutes only a small fraction of one day's processing in the
Mill. The entire volume of Uranium Material will make an insignificant contribution to the total
volume of tailings in the Mill's tailings system.
As discussed in the section on Effects on Tailings System, above, after processing of the
Uranium Material all constituents except beryllium, calcium and manganese, will have a de
minimis or no impact on the tailings composition, will create a slight reduction in the average
concentrations in the tailings cells, or will create a change that is within the range of increases
created by other alternate feeds.
Of the three whose impact may be detectable, manganese and calcium (a non-hazardous
nutrient in surface and groundwater), these constituents are already monitored under the Mill's
groundwater monitoring program. As discussed above, barium is well represented
geochemically by calcium which is already monitored in the Mill's groundwater monitoring
program.
Due to the above facts, specifically that the Uranium Material originated from natural ore and will
be shipped and processed at very low rates, the constituents in the Uranium Material could be
expected to have a negligible effect on the Mill process and the tailings system, and will have no
21
[ It) TETRA TECH
discernible environment or health and safety effects beyond the effects of natural ore
processing .
22
[ It] TETRA TECH
References
Midnite Mine Superfund Site. Spokane Indian Reservation Washington Record of Decision
(ROD), EPA Region 10, September 2006.
Gulec, S.B., C.H. 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.
Mitchell, D.H., 1985. "Geomembrane Compatibility Tests Using Uranium Acid Leachate",
Journal of Geotextiles and Geomembranes, Vol. 2, No.2, Elsevier Publishing Co., pp. 111-128.
NIOSH Pocket Guide to Chemical Hazards, Department of Health and Human Services:
Centers for Disease Control and Prevention, National Institute for Occupational Safety and
Health, September 2007, DHHS (NIOSH) Publication No. 2005-149.
CRC Handbook of Chemistry and Physics, 68th Edition, Weast, R.C., Astle, M.J ., Beyer, W.H.,
1987-1988.
23
[ It) TETRA TECH
T bl 1 a e fbT· ncompa I Iities an d Ch emlca IH d f C azar s or ompanents 0 fth U e ranlum M t . I a ena
Estimated
Concentration
Range in
Uranium Material
Chemical at 25% to 45%
Component Symbol Solids (ppm) Incompatibilities
Ammonia NH4 14-26 Strong oxidizers, halogens, acids, salts of silver and zinc
Barium Ba 14,667-26,400 As Barium oxides -reacts with water to form hydroxides; reacts with
N204, hydroxylamines, S03, H2S
Beryllium Be 63-114 As BeO -gives off toxic gases in fire
Cadmium Cd 77-139 As CdO -reacts with magnesium, decomposes on heating to form
cadmium fumes
Calcium Ca 28,417-51,150 As Ca oxides -react with water
-
As Ca hydroxides -react with water
As CaS04 -diazomethane, aluminum, phosphorous, water
II As CaSi03 or CaOSi02 -none
Chloride CI 72-130 Varies with compound form. As inorganic salts -none
Chromium Cr 36-64 As Cr02 -none
= As Cr03 -combustible materials (paper, wood, sulfur, aluminum,
plastics)
Cobalt Co 2,200-3,960 As CoO -none
Copper Cu 312-561 As CuO -acetylene, zirconium
Fluoride F 70-125 Varies with compound form. As inorganic salts -none
Iron Fe 1,311-2,360 As Fe203 -calcium hypochlorite, carbon monoxide, hydrogen peroxide
As Fe2(S04h -decomposes at high temperature
As AS2Fe20 s -decomposes on heating to yield fumes of arsenic and
iron
Lead Pb 34-61 As PbO -strong oxidants, aluminum powder, sodium ; also decomposes
on heating to form lead fumes
Manganese Mn 201,667-363,000 As Mn(OH)3MN20 3, MnO -none
Nickel Ni 3,208-5,775 As NiO-iodine, H2S
Nitrates NO, 6-10 None reported
Selenium Se 47-84 As SeO -none
Silver Ag 21-38 As AG20 -fire and explosion hazard with organic material or ammonia
Sulfate S04 31 ,167-56,100 As S04 compounds, see other compounds in this table
Zinc Zn 6,417-11,550 As ZnO -none
1
( it] TETRA TECH
T bl 2 H· t . w t Q I't f DMC WTP I fl t a e IS orlc a er ua tty 0 n uen
Aluminum Arsenic Cadmium Copper
location 10 Collection Date Ilgil I1g1l IlQ/l I1g/L
SW-39 (P IT-3) 2/25/1998 43 -280 -
SW-39 4/29/1998 46 -250 -
SW-39 7/22/1998 49 -260 -
SW-39 10/14/1998 61900 --20 U 46 -1000 U
SW-39 10/27/1998 48 -260 --
SW-39 11/15/1998 60500 --5 B 43 -1000 U
SW-39 12/10/1998 58600 --5 B 37 -1000 U
SW-39 1/25/1999 46 -230 -
SW-39 4/15/1999 34 -230 -
SW-39 4/21/1999 49900 -10 U 26 -210 -
SW-39 5/17/1999 50300 --5 B 34 -269 -
SW-39 6/15/1999 56200 --7 -33.3 -160 -
SW-39 7/27/1999 43 -230 -
SW-39 10/6/1999 49 -250 -
SW-39 12/12/1999 46800 -8 B 51 .8 --228 -
SW-39 1/27/2000 69 --200 -
SW-39 2/4/2000 92300 -100 U 70 B 200 B
SW-39 4/7/2000 20100 -1 B 25.6 -181 -
SW-39 4/17/2000 29 -240 -
SW-39 5/12/2000 44200 -1 B 49.5 --258 -
SW-39 6/7/2000 51 000 -7 B 56 .1 --313 -
SW-39 7/13/2000 68600 -6 B 58 --225 --
SW-39 7/20/2000 46 -300 -
SW-39 8/15/2000 97200 -10 B 82 -199 -
SW-39 9/14/2000 105000 -3 U 64 -190 -
SW-39 10/25/2000 63 -230 ~
SW-39 10/30/2000 98900 -5 U 81 -165 -
SW-39 1/17/2001 54 -200 --
SW-39 1/27/2001 76500 -5 U 57 -149 --
SW-39 4/6/2001 83 -770 --
SW-39 4/26/2001 61900 -3 U 71 -522 -
SW-39 7/5/2001 71 -630 -
SW-39 10/4/2001 69600 -10 U 80 -560 -
SW-39 2/7/2002 14900 -1 U 16 -95 --
SW-39 4/17/2002 12800 -10 U 20 -80 --
SW-39 7/11/2002 24000 -10 U 20 -180 --
SW-39 10/9/2002 36500 -10 U 40 -300 -
SW-39 1/15/2003 34800 -10 U 40 -290 -SW-39 4/24/2003 36500 --10 U 30 -260 -
Manganese
lead /Jg/l I1g/l Nickel Ilg/L Uranium ).Lg/l
86000 -
85000 -
90000 -
7 B 89700 --1810 -23688.2 -
95000 --
4 B 96400 --1790 -24632.7 --
5 -81000 -1650 -18140.9 -
85000 -
70000 -
2 U 62200 --20 U 12084.0 -
2 B 69200 -,-1310 -18021 .0 -
3.7 --82900 --1480 -17751.1 -
85000 -
95000 -
5.9 -79300 -1430 --18545.7 -
130000 -
20 U 120000 -2430 --2051 .0 -
3.1 --32200 -640 -11 334.3 -
46000 -
6.2 -62600 -1180 --10614.7 -
8.9 -70500 -1370 --
9 -95800 -1940 --
85000 -
10 -129000 -2620 -
15.1 -146000 -2800 -
140000 -
7 -146000 -2910 -
120000 ~
8 -121000 -2310 -
120000 -
7 -84200 -1700 -
110000 --
10 -118000 --2090 -24000.0 -
2 -31300 --658 -8850.0 -
10 U 30200 --550 -7430.0 --
10 U 53400 .-810 -11300.0 -
10 U 62200 -1110 -14800.0 -
10 U 57400 -1050 -12100.0 -
10 U 48600 --1100 -12000.0 -
2
pH TSS
Zinc 1l9/l S.U, mg/l
3500 -4.41 -2 U
3400 -4.26 -
3500 -4.09 -
3660 -4.45 -5 U
3700 -4.4 -
3600 -4.41 --5 U
3000 B 4.56 --14 B
3500 -4.64 --
3000 -4.76 -
2500 -4.1 3 -5 U
3000 -4.44 --5 U
3270 -4.26 --5 U
3400 -4.05 -
1100 -4.45 -
3210 -4.38 -5 U
5700 -3.91 -
5480 -4.04 -12 B
1410 -4.32 -8 B
1900 --4.37 -3 U
2500 -4.35 -5 U
2960 -4.1 -5 U
4220 -3.94 -5 U
3600 -3.85 -3 U
5720 -3.9 -5 U
6160 -4.06 -6 B
5700 -4.12 -3 U
6620 -4.34 -5 U
5000 --4.65 -3 U
4670 -4.51 --8 B
5100 -4.52 --3 U
3690 -4.32 -5 U
4600 -4.08 -3 -4400 -4.33 -5 -
1360 -4.49 _.
1130 -4.91 --10 U
1680 -4.4 --5 U
2310 -4.49 -0.05 U
2220 -4.49 -8 -
2390 -4.62 -5 U
Ra-226 (diss)
pCill
22 -
18 --
67.2 -
45.6 --
23 -
24 -
29 -
30 -
36 -
31 -
42 -
45 -
57 -
83 --
70 --
70 -
54 --
82 -
48 -
32.6 -
20.6 -
38.7 -
53 .9 -
40.8 -
40.3 -
Ra-226 (total)
pCill
22 -
18 -
67.2 --
45.6 -
23 -
24 -
29 -
30 -
36 -
31 -
42 -
45 --
57 --
83 -
70 -
70 -
54 -
82 --
48 -
32.6 -
20.6 -
38.7 -
53.9 -
40.8 -
40.3 -
3801 Automation Way, Suite 100
Fort Collins, Colorado 80525
Tel [phone] Fax [phone]
www tetra tech com
( Ii:] TETRA TECH
b Ta Ie 2. Historic Water Quality of DMC WTP Influent Continued
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
Location ID Collection Date ~g/L Jlg/L J.!g/L j.lg/L I.lg/L I.lg/L Jlg/L Jlg/L j.lg/L S.U. mg/L pC.ill pCi/1
SW-39 (PIT-3) 7/15/2003 44800 -10 U 40 -280 --10 U 68400 --1260 --14400.0 -2660 --4.26 --5 U 30.1 -30.1 -
SW-39 10/23/2003 42400 -10 -50 --260 -10 U 66800 --1270 -15900.0 -2680 -4.5 -5 U 21.6 --21 .6 -
SW-39 1/14/2004 53400 10 U 50 280 10 U 76700 1440 16400.0 3110 4.58 5 U 30 30
SW-39 4/23/2004 40300 10 U 50 180 10 U 55300 1080 12100.0 2520 4.5 5 U 37.5 37.5
SW-39 7/16/2004 49500 10 U 50 230 10 78400 1310 19100.0 2810 4.24 5 U 33.3 33.3
SW-39 10/13/2004 58700 10 60 230 10 U 80000 1550 17600.0 3350 4.5 5 U 22.8 22.8
SW-39 4/22/2005 35700 10 U 40 140 10 U 60900 1070 12400.0 2350 4.71 21 .3 21 .3
SW-39 7/14/2005 45900 10 U 40 150 10 U 76300 1230 16900.0 2700 4.41 5 U 24 24
SW-39 10/11/2005 46000 10 U 50 150 10 U 83000 1430 15800.0 2960 4.68 25.6 25.6
SW-39 4/20/2006 32300 10 U 30 150 10 U 43900 910 10200.0 1910 4.56 5 U 23.7 23.7
SW-39 7/13/2006 60300 10 U 30 180 10 U 49600 1180 11200.0 2400 4.23 5 U 31 .7 31 .7
SW-39 10/11/2006 40300 10 U 40 170 10 U 60800 1220 13100.0 2570 4.6 5 U 33.9 33.9
SW-39 4/19/2007 39500 10 U 33.8 137 10 U 56000 1080 12700.0 2950 4.56 10 U 20.5 20.5
SW-39 7/11/2007 47200 10 U 40.9 150 10 U 67700 1210 15400.0 2570 4.39 5 U 29.6 29.6
SW-39 10/4/2007 42700 10 U 48.2 159 10 U 64200 1340 14200.0 2980 4.52 5 U 28.3 28.3
SW-39 4/25/2008 37100 10 U 27.5 161 10 U 47400 1220 9770.0 2480 4.74 1 U 18.9 18.9
SW-39 7/22/2008 40700 10 U 44.8 162 10 U 49700 1420 12500.0 2750 4.31 4 27 27
SW-39 10/2/2008 45400 6.65 39.5 139 73100 1600 14400.0 2870 4.26 5 U 19 19
SW-39 4/27/2009 31400 <10 28.9 118 <10 45000 865 9160.0 1850 4.66 1
SW-39 7/10/2009 46200 <10 29.9 132 <10 76000 1170 14200.0 2430 4.4 3 34
SW-39 10/6/2009 36300 <10 40.2 133 <10 58500 1250 15400.0 2620 4.37 2 32
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
SW-39 (Pit 3) ~g/L J.lgfL J.!91L !!9/L j.lg/L !lg/L Jlg/L j.lg/L J,lg/L S.U. mglL pCill pC ill
Count (n) 45 42 60 60 41 60 45 38 60 60 48 43 45
Max 105,000 100 83 1,000 20 146,000 2,910 24,633 6,620 5 14 83 83
Min 12,800 1 16 80 2 30,200 20 2,051 1,100 4 0 18 18
Avg 49.891 10 46 271 9 79,147 1,397 14,215 3,223 4 5 37 37
Std Dev 20.343 15 16 207 3 28,429 575 4,539 1,243 0 3 17 17
2 x Std Dev 40,685 29 32 414 7 56,859 1,149 9,078 2,486 0 5 34 34
3
[ It) TETRA TECH
Table 2. Historic Water Quali~ of DMC WTP Influent Continued
pH TSS Ra-226 (diss) Ra-226 (total)
Location 10 Collection Date Aluminum Ilg/L Arsenic J,1g/L Cadmium )J.g/L Copper )J.g/L Lead ~g/L Manganese J,1g/L Nickel ~g/L Uranium )J.g/L Zinc 119/L S.U. m~/L pCi/1 pCi/1
SW-40 (PIT-4) 1/15/1998 5 U 6 -1100 -10 -6.22 -3 U 1.9 -1.9 --
SW-40 4/29/1998 4 U 10 --880 -7 -7.78 --3 --3 -
SW-40 7/22/1998 4 U 5 U 370 -2 U 6.79 --
SW-40 10/14/1998 80 B 10 U 2 U 10 U 2 U 262 --10 U 3280.0 --20 U 7.54 --5 U 1.78 --1.78 -
SW-40 10/27/1998 4 U 5 U 490 -6 -7.57 --
SW-40 11/15/1998 90 B 2 U 1 U 5 U 1 U 518 -10 U 3520.0 --10 B 7.1 --5 U 2.06 --2.06 -
SW-40 12/10/1998 120 B 2 U 0.4 U 10 B 0.4 U 505 -10 U 3810.0 -20 U 7.02 --5 U 3.23 --3.23 -
SW-40 1/14/1999 9 -4 U 630 -13 -6.81 --
SW-40 1/14/1999 120 B 2 U 0.4 U 2 U 0.4 U 574 -10 B 3820.0 -26 -6.85 --5 U 5.52 --5.52 -
SW-40 2/20/1999 210 -5 U 1 U 7 B 1 U 663 -20 B 3070.0 -30 B 6.92 --5 U 8.76 --8.76 -
SW-40 4/15/1999 3 U 5 --940 -29 -6.61 --
SW-40 4/21/1999 500 -2 U 0.4 U 3 B 0.4 U 649 -660 -1370.0 -60 B 7 --5 U 7.6 --7.6 -
SW-40 5/17/1999 90 B 2 U 0.4 U 3 B 0.4 U 764 -30 B 2420.0 -20 -7.43 --5 U 5.1 --5.1 -
SW-40 6/15/1999 120 B 1 B 0.2 B 2 B 0.2 U 747 -30 B 2830.0 -26 -6.99 --5 U 3.7 --3.7 -
SW-40 7/27/1999 4 U 6 --1000 -31 -6.79 --
SW-40 10/6/1999 4 U 4 U 460 -10 -7.16 --1.1 -1.1 -
SW-40 1/27/2000 4 U 4 U 860 -22 --6.74 -9.7 --9.7 -
SW-40 4/17/2000 4 U 9 --1000 -29 -6.04 --5 -8.6 -8.6 -
SW-40 7/20/2000 3 U 6 --300 -3 -7.07 -3 U 1.6 --1.6 -
SW-40 10/25/2000 4 U 11 --290 -2 U 6.72 -3 U 2.8 -2.8 -
SW-40 1/17/2001 4 U 40 --660 -2 U 5.36 -3 U 4.5 --4.5 -
SW-40 4/6/2001 4 U 5 --660 -16 -7.35 -3 U 4.3 -4.3 --
SW-40 7/5/2001 4 U 4 U 370 -2 U 6.96 -3 U 2.9 -2.9 --
SW-40 10/4/2001 100 U 10 U 10 U 10 U 10 U 710 -10 U 6000.0 -10 U 6.86 --10 U 4.1 -4.1 -
SW-40 2/7/2002 1 U 1 U 1 U 6 --1 U 1610 -55 -4770.0 -62 -6.47 -10 U 29.6 -29.6 -
SW-40 4/17/2002 100 -10 U 10 U 10 U 10 U 1640 -60 -2430.0 -90 -5.82 -10 U 21.1 --21.1 -
SW-40 7/11/2002 100 U 10 U 10 U 10 U 10 U 1250 -40 -3830.0 -50 --6.51 -5 U 4.2 --4.2 -
SW-40 10/9/2002 10 U 10 U 10 U 10 U 10 U 1040 -30 -5500.0 -40 -7.28 -5 U 3.3 --3.3 -
SW-40 1/15/2003 600 -10 U 10 U 10 U 10 U 2190 -70 -5600.0 -110 -6.63 -5 U 27.8 --27.8 I -
SW-40 4/24/2003 10 U 10 U 10 U 10 U 10 U 1280 -60 -3510.0 -60 -7.26 -5 U 8.6 --8.6 -
SW-40 7/15/2003 10 U 10 U 10 U 10 U 10 U 940 -30 -3430.0 -20 -7.66 --5 U 4.1 --4.1 -
SW-40 10/23/2003 10 U 10 U 10 U 10 U 10 U 490 -20 -4030.0 --20 -7.43 --5 U 2.3 --2.3 --
SW-40 1/14/2004 200 10 U 10 U 10 U 10 U 930 20 4740.0 20 6.83 5 U 2.8 2.8
SW-40 4/23/2004 100 U 10 U 10 U 10 U 10 U 880 30 4050.0 50 7.32 5 U 9.2 9.2
SW-40 7/16/2004 200 10 U 10 U 10 U 30 280 10 3720.0 60 7.19 5 U 1.7 1.7
SW-40 10/13/2004 100 U 10 U 10 U 10 U 10 U 150 10 U 4260.0 10 U 7 5 U 1.5 1.5
SW-40 4/22/2005 300 10 U 10 U 10 U 10 U 530 20 4880.0 30 6.74 6.4 6.4
SW-40 7/14/2005 2400 10 U 10 U 10 U 10 U 260 10 U 4520.0 410 7.57 5 U 2.3 2.3
SW-40 10/11/2005 100 10 U 10 U 10 U 10 U 210 10 U 5460.0 10 U 6.65 I 1.5 1.5
SW-40 4/20/2006 100 U 10 U 10 U 10 U 10 U 1360 60 1280.0 80 6.72 5 U 12.1 12.1
4
[ It] TETRA TECH
T bl 2 H· ·W a e Istorle ater Q r f DMC WTP I fl ua Ity 0 n uent C ontmued
Ra-226 Ra-226
Collection Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
Location 10 Date IJg/L J.L9lL ~g/L ~g/L J,lg/L IJglL UQIL Ilg/L IJ,glL S.U. mgfL pCiJl pCill
SW-40 (PIT-4) 7/13/2006 100 U 10 U 10 U 10 U 10 U 1370 40 2060.0 40 6.98 5 U 5.9 5.9
SW-40 10/11/2006 100 U 10 U 10 U 10 U 10 U 500 20 3060.0 30 7.64 5 U 1.8 1.8
SW-40 1/25/2007 100 10 U 10 U 10 U 10 U 600 20 3380.0 40 7.69 5 U 8 8
SW-40 4/19/2007 100 U 10 U 10 U 10 U 10 U 821 26.1 2660.0 31.6 7.7 10 U 5 5
SW-40 7/11/2007 100 U 10 U 10 U 10 U 10 U 445 14.4 2410.0 13 7.14 5 U 1.9 1.9
SW-40 10/4/2007 100 U 10 U 10 U 10 U 10 U 128 10 U 2960.0 10.9 7.1 5 U 0.9 0.9
SW-40 4/25/2008 100 U 10 U 10 U 10 U 10 U 767 29.8 2200.0 36.9 8.36 5 U 7.3 7.3
SW-40 7/22/2008 17.4 10 U 10 U 10 U 10 U 201 10 U 1930.0 10 U 7.01 2 1.3 1.3
SW-40 10/2/2008 10 U 1.18 1 U 1 U 90.5 2.25 3420.0 10 U 8.45 5 U 0.57 0.57
SW-40 4/27/2009 <100 <10 <10 <10 <10 606 34.2 2150.0 43 6.90 <1
SW-40 7/10/2009 <100 <10 <10 <10 <10 177 <10 2310.0 <10 7.48 2 2.2
SW-40 10/6/2009 <100 <10 <10 <10 <10 116 <10 3100.0 <10 6.92 1 1.2
Summary
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
SW-40 (Pit 4) IJg/L 1-l9/L IJg/L I-lg/L J.lglL ua/L IJ,g/L IJ,g/L ua/L S.U. mgJL pCi/1 pC ill
Count (n) 34 34 49 49 33 52 35 37 50 52 40 44 46
Max 2,400 10 10 40 30 2.190 660 6.000 410 8 10 30 30
Min 1 1 0 1 0 91 2 1.280 2 5 2 1 1
Avg 191 8 6 8 8 697 44 3,453 36 7 5 6 6
Std Dev 410 4 4 5 6 438 109 1.185 59 1 2 6 6
2 x Std Dev 820 7 8 11 11 877 217 2"369 118 1 4 13 12
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
j.1Q/l j.1Q/L IJ.Q/l IJ,g/l 1J9/l ua/l _ua/l ug/l IJ,g/l S.U. mg/l pCi" pCi/1
COMBINED
Count (n) 79 76 109 109 74 112 80 75 110 112 88 87 91
Max 105,000 100 83 1 LOOO 30 146,000 2,910 24,633 6,620 8 14 83 83
Min 1 1 0 1 0 91 2 1.280 2 4 0 1 1
AVQ 28,501 9 28 153 8 42,724 805 8,906 1,774 6 5 21 21
Std Dev 29JOO 11 23 202 5 44.432 803 6,350 1,838 1 2 20 20
2 x Std Dev 58,200 22 46 403 9 88,864 1,607 12.700 3.677 3 5 40 40
5
[ It) TETRA TECH
T bl 3 HO t ° ITt I WTP U a e IS orlca oa ramum M t ° IT f a erla es 109 Ota a
Initial Composite Sludge Sample Annual Composite Sample
~
U-nat Ra-226 Moisture U-nat Ra-226
Date (mg/kg) (pCI/g) (%) (mg/kg) (pCi/g)
4/1/2003 11,100 5.7 83.6 9,700 5.3
4/1/2004 9,060 7.6 87.0 8,600 2.4
4/1/2005 12,900 14 86.4 19,000 11
4/1/2006 5,200 4.3 86.3 11,200 9.1
4/2/2007 2,700 4.7 84.3 12,000 24.2
4/9/2008 19,000 5.1 79.4 13,500 10.8
5/20/2009 8.7
4/13/2010 15,333
Count: 7 7 6 6 6
Max: 19,000 14 87.0 19,000 24
Min: 2,700 4.3 79.4 8,600 2
Avg: 10,756 7.2 84.5 12,333 10
Avg. Measured Measured
Avg % Solids Max % Solids Min % Solids
U Cone. Dry Weight Basis (mg/Kg) 10,756 19,000 2,700
U Cone. Wet Weight Basis (mg/Kg) 1,667.2 15.5% 3,914 20.6% 424 15.7%
U Cone. Wet Weight Basis (%) 0.17% 0.39% 0.04%
% solids = 100% -% Moisture
U Cone. Wet Weight Basis (mg/Kg) = U Cone. Dry Weight Basis x % solids
6
[ It:] TETRA TECH
Table 4. U Material Metals A __________________________________ nal . for RCRA Ch terisf ys IS _ _ _ _ _ _ _ __ _ __ _ _ _ _ _ _ _ _
Sample Sample Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver
ID Date mg/L mg/L mg/L mg/L mglL mg/L mg/L mgl(
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 I 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 5 100 1 5 5 0.2 1 5
PASS? Yes Yes Yes Yes Yes Yes Yrs Yes -----
7
( it;) TETRA TECH
Tab e 5. Uranium Material ARalyses f or RCRA Listed Hazardous Waste
Laboratory Results calculated
Target Analyte 11) Units WTP5-1 WTP5-2 WTP5-3 Average
Total Uranium -Method SW6020A
Total Uranium mg/kg 15.000 16.000 15,000 15J 333
TotallCP Metals -Method SW6010B
Arsenic mg/kg <5.9 <5.9 <5.7 <5.8
Barium mg/kg 8,100 7.900 7,200 7,733
Beryllium mg/kg 33 36 36 35
Cadmium mg/kg 40 44 43 42
Calcium mg/kg 15.000 16,000 16,000 15.667
Chromium mg/kg 19 20 19 19
Cobalt mg/kg 1.200 1,200 1,100 1.167
C0pper mg/kg 160 180 170 170
Iron mg/kg 690 740 740 723
Lead mgJkg 18 19 17 18
Manganese mg/kg 110,000 110,000 96,000 105,333
Molybdenum mg/kK <5.8 <6.0 <5.7 <5.8
Nickel mg/kK 1,700 1,800 1,800 1,767
Selenium mg/kK 25 26 26 26
Silver mg/kg 11 12 11 11
Thallium mg/kg <580 <600 <570 <583
Tin mg/kg <29 <30 <29 <29
Vanadium mg/kg <5.8 <6.0 <5.7 <5.8
Zinc mg/kg 3,400 3.600 3,600 3,533
Total Mercury -Method SW7471A
Total Mercury mg/kg <0.19 <0.2 <0.19 <0.19
GC/MS Total Volatile Organics -Method SW8260
Chloromethane )!g/kg <1.1 <1.2 <1.1 <1.1
Acetone )!g/kg 22 B 29 B 33 B 28
Methylene Chloride jJC/kg 3.8J,B 3.7 J.B 5.8 J,B 4.4
2-Butanone )!g/kg <5.7 <5.9 <5 .7 <5.8
Tetrahvdrofuran Ilg/kg <7.2 <7.4 <7.2 <7.3
Chloroform )!g/kg 1.7J 2J 1.2J 1.6
Carbon Tetrachloride Ilg/kg <1.3 <1.4 <1.3 <1.3
Benzene \.!g/kg <0.94 <0.96 <0.93 <0.94
Toluene )!g/kg 2.2 J,B 1.9 J,B 1.3 J,B 1.8
m,p-Xylene ~lg/kg <1.9 <1.9 <1.9 <1.9
o-Xylene !-Ig/kg <0.95 <0.97 <0.94 <0.95
Naphthalene ~llfJkg <1.4 <1.4 <1.4 <1.4
111 All values as reported by ALS Laboratory as dry weight values
8
( It) TETRA TECH
T bl a e 5. u ramum M . IA aterla nalyses f RCRA L' d H or Iste d azar ous w aste C r on mue d
Laboratory Results ~ Calculated
Target Analyte Un1ts11) WTP5-1 WTP5-2 WTPS-3 Average
GC/MS Total Semi-Volatile Organics -Method SW8270D
Pyridine j.!g/kg <310 <320 <320 <317
l,4-dichlorobenzene ~g/kg <310 <320 <320 <317
2-methylphenol j.!g/kg <310 <320 <320 <317
3+<'1-melhylp'he nol Jlg/kg <310 <320 <320 <317
Hexachloroethane Jlg/kg <310 <320 <320 <317
Nitrobenzene pg/kg <310 <320 <320 <317
Hexachlorobutadiene j.!g/kg <310 <320 <320 <317
2A.6-rrichlorophenol I!g/kg <310 <320 <320 <317
2,4,5-trichlorophenol Jlg/kg <310 <320 <320 <317
2,4-dinitrotoluene _ Ilg/kg <310 <320 <320 <317
Hexachlorobenzene J.!g/kg <310 <320 <320 <317
Pentachlorophenol ~lg/kg <490 <500 <500 <497
Gasoline Range Organics -Method SW8015B
Gasoline Range Orga nics mg/kg <0.38 <0.35 <0.39 <0.37
Diesel Range Organics -Method SW8015MB
Diesel Range Organics mg/kg <6.5 <6.6 <6.8 <6.6
Oil & Grease
Oil & Grease mg/kg <120 <120 <120 <120
Inorganics
Ammonia as N -Method EPA3S0.1 mg/kg 7.9 7.9 8.3 8.0
Nitrate/Nitrite as N -Method EPA3S3.2
Revision 2 mg/kg 3.1 3.2 3.1 3.1
Total Dissolved Solids -EPA160.1 mg/kg 26,000 26,000 27,000 26333.3
Fluoride -Method EPA300.0 Revision 2.1 mg/kg 38 38 40 38.7
Chloride -Method EPA300.0 Revision 2.1 mg/kg 40 39 41 40
Sulfate -Method EPA300.0 Revision 2.1 mg/kg 17,000 17,000 17,000 17,000
Gross Alpha/Beta -GFPC
Gross Alpha pCi/g 4,310±690 4,830±770 S,440±870 4,860
Gross Beta pCi/g 4,870±780 4,780±760 .4,860±780 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/E 22.8±S.8 2S.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) pCi/g 3S.8±9.2
!sOlOp,c Thorium -Alpha Spectroscopy
Tb-228 pCi/g 1.24±0.99 1.S0±0.74 0.93±0.67 1.22
Th-230 pCi/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
(1) All values as reported by Al5 Laboratory as dry weight values
9
Cqm(!!!nol1t
IIc.\Ihmo
Ammonl. (IIH.)
"'IonIc {lUll
Barium (BII
Be~lIIum(B_!
Cldmlum ICdl
C.tcltirn real
COhDlI (Co)
Cllromlum IC~
Chiorldl:lC.lt
Coeear!Cu!
FIt/orld'IFl iMn (rol
Lllrcl(Pbl
M.ngllllml IM!'l
Ma~""rY:ftltll
Molyb<\onllrll (Mill
Nlck.IOm
Imr<llu {NO~,
S~lnlllll," (SQ
SIl\(OI!~1
Sulfat_ (50.=)
Thllllum IT II
Till Sit!
Vonldhun.lYl
l lnofZn}
TOIaI Seloctod COinPollcnlll
Tol., Tailings Cell Masa
Mltlnllo MInI) Urnl1l1un Mat.)rl~l Comp_ollUIOIl Cell 3 Compoalllon In 20(1'-eaullno rorCOll4A (or4Bj Yo., 1
u
Estimated F
C Hlatorleal E Eslimated G H 1K
A B Ellimated Maximum Esllmated Cone. Average Cone. Estimated eaUmated Annual I lJ Mass In Cell 4A (or
Cone. In Ores and Range In Average Cone. In Annuol Ma •• ln Range In Cell 3 11\111 In Cell 3 Mill Mass In Cell 3 Mass In Cell 4A or Cone. In Cell 4A Estimated Mass 4B) Mill Tailings ifter
Oilier Allemat. F .. o!d. Uranium Matarlal Url nlum Materlll Uranium T.lllngs solution Tailings solution Mill Tailing. 4B Mill Tailings (or4B) Mill In Uranium Uranium Material
I",pm" --..!!!!U(?L-J lnglkg}' r.I.,~iUl !Ions)' . (mglL. or ppln)' j,mJlIL or DDml' 2004 (ton.)' (Iona)' Taillngl (ppm)' Mat.rlal (tons}' Processing (tona)"
U 0 2Jl.51~ 192 340 Ala 192.0 0.000 4\.3
100-730 79·8:' GO 0002 3·1~.\l!lU 3.131 5.539 6732 3131.0 0002. 673 2
3.5-16.130 U U 0 I) 8-4dO 149 264 32Q 149,0 0000 320
.1..00f3.000 7~0<HI 100 7J3J q\23 002J.o , 00' 0035 ~.O 00 1.52 15
"10~ 3J>3Il J!I OWl a 34/-U,78 05 o BB 0:1 OJ, 0007 Ot
0,0114-111' 40-0\.4 4'1 oem 164~6 ;34 60 07 3<4 0.0011 or
U]) 10 2f7.0C!f 1 MOG-Itl 000 U667 ~oeB 90~3o 3SB 651 791 3680 3.09 fl22
· 9-350.400 1.IW-'_200 1,161' 0 230 14-120 607 107 13.r 607 01.30 -,-33
8-16,000 '!J.2D 1l< 0004 10-1;3 62 11 UI 11,2 O,~ 13
07~9,900 39 .. 1 40 0000 2.110-<3000 4,608 D_IS? 9lIIl.l 4606.0 0008 ~.I
Unknown leO-180 170 0033 Ullknown 00 0.0 D.Ol3 00
3-460.000 38-40 31l ? 0 008 002-4.'140 1.6116 2,998 3Jiit.4 10050 O,1./OIl ~~
up '" ot6.mJO li9lJ.7~O ns 0-,012 1,oBO-3.400 2.212 3913 415:6 22120 0.1~2 475 7
!I·2J!) 0lI;l 17-19 fU 0 004 021-$ 0 3 I> 0.6 3.U 0004 06
~12-:1.O10 96000·1 '0_000 105 333 20 ~I 74-222 146 ~..8 31 4 1400 20.8 ~,
00004-14 U U 0 00008-176 35 6 Ot! 36 0000 on
12-17.000 U U 0 044-240 676 !/3 11 .4 528 0.000 Il~
1·450000 , 700-1.800 1167 Ua4lI 72-370 83 147 176 830 0.:1411 10 2
I"!. :I00.a<IO 31'32 3.1 a 001 24 2J\ 42 52 ~.O O.OOOG 112
002-710 :1's·211 ?a (t005 018-24 14 25 0,3 1 ~ 000!;1 0.3
0007-1l0 11-12 11 0002 0005-0.14 · 01 02 00 01 OOO~ 00
24-3110,000 17.009 17,000 :'-349 28,900-190,000 64,914 114.833 13958,6 049'~,0 3..3.19 IJP59 9
Ow.-soo U u 0 07-45 16 28 3<11 160 0000 3,4
20.9lJO-',6.000 U \) 0 ~ 5 9 1.1 5.0 0,000 11
10-25.000 U U a 136-510 263 46S-W~ 21l3.0 0.000 SS5
8-14,500 3 '100:)601) 3.5" 06516 50-1 .300 641 1.134 137.0 641 0 0.696 1:111:.
311.2
2-15OOIl,0 2tfiOJ{l2
• • As5\,,~a 2W,< rcdu\:! Ilf\ per year lor 5 years "(lIn hISIQIkc.tJ( ml'lXllllllul II!\lUIII (11I\l 11ln~ per I'llilrJ to ('11111 fUfIlC<iV lJIIinjQ\U 0' 18 lon& per year dly umnlum m~lel1al
The concenlralion in other allemate feeds represents some selecled concentrations for conslitu.nls found in characterizalion dala for other alternate feed materials licensed for processing al /he Mill, for comparison purposes
The range in the Uranium Materiel is based on three sempling events for the DMC WTP solids
3 The estimated average concentralion in Uranium Malerial has been calculated as the mean "alue reported
4, Esumated mass in the Uranium Malerial is calculated by assuming 197 tons dry annually from historical values
5 Mill tailings range and average concentra~ons were laken from Mill tailings samples to date, as summarized in Table 5 of the draft Slatement of Basis for the Utah Groundwater Discharge Permit for the Mill (November 29,2004)
6 Estimated curren' mass in Mill tailings is calculated by mul~plying the estimated average concentration in the Mill tailings in Column F by 1,769,000 d/y tons of tailings reported in the Mill's aclive Tailings Cell No.3
7 The baseline eslimated annual mass in Mill tailings for cell4A or 48 is calculaled by mulliplying (he estimated mass in Cell 3 (Column G) by the ratio of Cell4A (or 48) total mass capacily of 2,150,000 dry tons 10
capacily or Cell 3 of 1 ,769.000 dry tons as of November 29, 2004 and dividing it by ten years as the estimated time to nil cell 4A (or 48)
8 The baseline concentration In Cell4A (or 4B) Mill tailings is calculaled by dividing Column H by 215,000 d/y tons as the assumed annual mass addition of tailings 10 the Cell wi/hout !he Uranium Material
9 Year 1 and Year 2 eslimated mass in the Uranium Material is assumed to be equal 10 Column D historical values
10 The mass in Mill tailings after Uranium Malerial processirlO I. cnlcula~ d "'1 Q Cling the lotallailings mass from the previ .. )'"ar 1<1 !<ill ' /III:J~i'JI\U\ 1f\!J 'II 1lIDJ' alld&d In IJI~ rtJ!Tlmt yenr
1L
Cone. In Cell 4A (or
4B) Mill Tailings
liter Uranium
Material Proeenlng
IPpm)"
l&lO
31306
1~O,O
7.1
0.5
~A
:J1l23
81.8
62
4G07.4
U2
16ge..l}
2212..4
3.0
2~2 5
3.5
52 B
B4.6
2·\-0
1,4
0.1
64920.5
la o
SO
2l13..0
84.4.1
11 The concentration in Cell4A (or 4B) Mill tailings after Urnn:um .tatol1lll prccmos,,~ is calculated by dividing the Mass in Co1l ~A «'. 48) I/~I If llilil/ 10' Innl V= "i IIII! to' 'OlIn.JlDlj.., nut .. inC'" 4A {or f,!lIIDl ~'II'I Vllln In\ M ~BI is processed
12 The increase in baseline Mill tailings con centra lion aner ur~nlum MI((jf1l11 DU)c!t",ing is calculated by subtracting basel FOnt I!!rBllOfl (COkJ!I1'1 II r(~ It., OQ.'lCeIIIUIl~ III C I -Ij>. (or 481 f"t~r urDl~um MIIler!1l n~!U(lg for IIiaI )031,
1M
Inerll.s. in Baseline I~"I
Tailings Cone. Alter
Uranium Mlterill
P...-•• IIIfIIPProi"
0.0
0.'1
D,G
71
0.0
0.0
14.3
1\
0.0
0.6
0..2
-0.2
0.4
0.0
965
0.0
00
1.6
0.0
0,0
0.0
6.5
0.0
0.0
00
3.1
13 The Year 3111111 Yllu' l epw0.>6'1lIllr. s~ma\ed mass in toe Uranium Material is assumed to be 5 times /he lI'1lQIIrll iT1 CO'\lfl1n 0 I>!l~ on IIl!i eJll~I.ulI":MlI"'u (':'W UOIIIUUIa bo 1,0lY.)1II11f11dt 7 """till of Ih yoill' 1100 450 aPll11o< U.e remaining 5 months
14 The Year 5 ougil YelU )0 nl'fK"~1I ate estimated mass in the Uranium Material is assumed to be reduclld 1I0!Tllh /llfiKIIIIlIl1l rv.~ ~Qluo pa')"$8; I~ tlW /lolll r .. mooy ... bIMI 01 C1Iy Ur.'lrtJum o!.ttIM4112G% educl4Qn pelf O.(J "n 2 years of construction.
15 The Eslima~ MIlIUl IIUrm'liom MIII"rial over 10-Year Period is the Cumulative Contribution from /he UranlUlll Moler .lp 1M blll,ngs
16, The Esllmated Mass in Cell4A (or 4B) Mill tailings over lO-year period afier Uranium Materiel processing is 1I1e total cumulative mass eonlribution from including Uranium Material to the taili~gs
17. The apprOXimate percent total conlributed from Uranium Material is the 1 O-year contr1bution to the tailings trom the Uranium Material.
Componenl
Acelone
AmmonIa INH.)
Arsenic Aa)
BlarliJm~BI)
liIorylllum {BO)
C.dml"", (CeI)
Calcium IC,!
Cobalt (Co)
~hromium ICrl
ChlarldelCI!
Co~erICu!
Fluorld.!FI
lro~ 1ft
lUdll'b)
MllInanolla t!4nl
Mercury (HilI
"llllybdClllum IMol
NlchalWII
Nltrales (NOll
SelenIum (Sa
Sliver Ag)
Sllifale I SQ.-I
ThQII ijm 11
TIn 18m
VonadiumM
llnc (2n)
TaUI! SlIhlCllllJ COlnDOllonlA
Total T4Illng8 C~I"M.ua
Vftar 2 Y~OI 3 (Conn) Y,,~r 4 (conal)
2L 3L
2K Conc. In Cell 4A (or 2M 3K Cone. In Cell 4A (or 3M 4K 2J Malia In Cell 4A (or 4B) Mill Tllllngs loe'ouo In Baoellno MIll 3J Masl In Cell 4A (or .. BI Mill Tailings Ine.retl In Baullno AliI 4J Ma •• In Cell4A (or Estimated Mass 4B) Mill Tailings a/ler after UranIum Tlillngs Conc. After Eatl mated Mass 4B) Mill Tailings after after UranIum Tailings Cone. After Estimated Mass 4B) Mill Tailings aftor
In Uranium Uranium Malenll Material Processing UranIum Mlterlal in Uranium Uranium Materlll Malerlal Procelslng UranIum Malerlal in UranIum Uranium Material
MlllQrIlUllOns)' PltH10Ulng (10"1)'" fIlP/n) , ProcoulnglllPOI)IJ Material {lons)1I Plllceninallolli/" Ippml" Plo~tulng (ppmlu Material (tons)" ProcesBing (Ions)"
0-1100 828 1020 00 0000 1238 191.0 -(l.1 0000 1651
0002 13<1G.3 3130.0 .()~ 0.006 2011l$ 3129.9 1 1 O.OOB 28927
0.000 Wll 149.0 uo OJXlO 001 146.0 -<II 0.000 1281
1.52 3 1 7.1 l ' 8087 111 17.2 172 6067 192
0.007 0.2 M 00 0037 04 Oli 0' 0.037 0.5
O.OOB 15 3.4 00 0.044 23 35 0 1 0.044 30
309 154 ..; sa3 '-.3 16.344 2S90 0402.11 34.11 16.344 :;!\5";!
0.230 2611 61.B 1 I 12.17 ,(0.8 6-3.3 28 1.217 551
0.004 H 02 QO 0.020 40 62 00 0.020 54
0.008 19815 4607·4. -06 0.04, 29727. 4606.5 ., 5 0042 39630
0.033 01 0:2 0.2· 0 177 02 04 0.( 0.177 04
O.OOB rnJ!I 1694 B -0.2 0.040 lCi933 1604.6 ,0.5 0.040 1457.8
0.142 "5f 4 22\2 A O,~ 0764 11278 2212.9 09 0.754 1904 I
0.004 1.3 3 0 0,0 0019 20 30 0.0 0.019 26
20 B 1043 2425 00.5 10111165 2456 380,6 234.6 109 B85 3008
0.000 ~6 _ <J.t> 00 --2..Q.Q.O __ 2:1" .--:l.S 00 0.000 r-30
0000 7.27 5?-f1 0,0 o CIOO 341 526 0.0 0.000 454
0.;;148 364 B4.6 1.6 1.643 561 869 39 1843 758
0.0006 10 3 240 0 0 0003 155 24.0 00 0.003 lOll
0.0051 OJl 14 0..0 0027 00 1.5 0 1 0.027 1 J
0.002 00 01 D.II 0011 01 01 0 0 0.011 0.1
3.349 279197 64920.5 6.5 17 735 ~1l!!M 0 64929.7 157 17.735 S58Gt1 2
0.000 6 11 16.0 00 0 000 103 16.0 0.0 0.000 138
0.000 ~7 ~.O 00 0000 :!2 fLO DO 0.000 43
0 000 1131 263.0 0.0 0.000 1696 262-9 ·0.'1 0000 ZlO.:l
0.696 2770 644.1 3.1 3tJaa 41!l1l. 6.411.1 77 3.686 580.0
302 160 a 1600
I ~3DOOII~ l!<I522O.4 8603803
•• A.~u!Oo 20% radllellOf\ per year lor Ii years II(lIn t.~IQtlCII! m9Xllllliin lolltl15 (100 toor. per YlIllf) 1o 1>IfIII rl)mnlW hlillm~lC/ of 1B rons per year dry \l1~UIII rnahl'll!I
The concentration in other alternate feeds represBnts some selected concenlretions for conslHuenls found in characterization data for other alternate feed matenals licensed lor processing at the Mill, for comparison pUlPoses
2 The range in the Uranium Material is based on Ihree sampling evenls for the DMC WTP solidS.
3 The esUmaled avarage concenlralion in Uranium Materiel has been calculated as Ihe mean value reported
4. Estimated mass in tile Uranium Materiel is calculated by assuming 197 tons dry annually from hislorical values
5. Mililailings range and average concentrations were taken from Mililailings samples to date. as summarized in Table 5 of Iha draft Slalement of Basis for the Ulah Groundwater Discharge Permit for iIle Mill (November 29.2004)
6 Eslimated current mass in Mililailings is calculated by multiplying the estimated average concantration in the Mill tailings in Column F by 1,769.000 dr)llons of ta ilings reported in Ihe MiII·s active Tailings Cell No 3
7 The baseline estimated annual mass in Mill tailings for cell 4A or 48 is calculated by multiplying the eslimated mass in Cell 3 (Column G) by Ihe ratio of Cell 4A (or 4B) total mass capacity of 2,150,000 dl)' tons to
capaCity of Cell 3 of 1.769,000 dl)' tons as Of November 29, 2004 and dividing it by ten years as the estimaled time 10 fill cell 4A (or 48)
The baseline concenlration in Cell4A (or 48) Mill tailings Is calculated by dividing Column H by 215.000 dry tons as Ihe assumed annual mass addition of lailings to the Cell wilhaullhe Uranium Malerial
Year 1 and Year 2 aslimated mass in Ihe Uranium Material is assumed 10 be equal to Column D hislorical values
10 The mass in Mil WMIl' Iillut I.Inrfllull ~'6tB(l1! OfPtcsllloll 'r$ call;>f.#tol/ \IV '~fIII tit;} lOIallu .ngs mot" //'0lIl Ihe fIICVKXllI yllBf \110 lOIDI.,rl~11IonIll ~ ~1I!Sj IImtM Ir. IIIe CU'filtIll1!M
4L
Conc. In Cell 4A (or
4B) Mill Tlllinga
after UranIum
Malerial Procelsing
(ppm)"
1919
3129 6 141r.e
7.2.3
0.6
3/j
41 30
64 0
8.:1
-'\Il00 1
05
1694 " 2213 1
3.1
4~9 6
3.6
5'2.8
681
~4 0
1 5
0.1
6·001..:1
160
50
26Z.1l
1l50.9
11 The conceniratiollill roe .(A (0I 4f:\) Milllilllt~g Q~,,(Ul1lwum MQIQl1nl ~rqq)1 rlQ hI::.;.~(1d by ;vi:l'ng II", ';ruIn c.. 4). (0' ~8} \II 141 I1'lllr:MlY\'az bV U IllW CtJII'..JIJJllv tn$.1n ClJI 'f" (or 4\;\) tailings aller Uranium Malenal is processed.
12 The increase in ~alle'Jn ',~fl u""'IIs concoolrnhQO o1lQI" ll!un·uI" ~'"lqrt~11lI"OClI>81!1OO ITi Cll\Gu ,!l<l tTl WUltnCWtg Wl6r>f"!ln CICrlCO''1tml'lI.'I (C".ctalrrlll '1WIl11 t:IIIll:Otnu·otCII In C~II ~A IIlI" 'I EI}ltltbl UI r.tllll Material processing far thai year.
13 The Year 3 and Yqm ~ IIPP'O.Iln:IIIl M DIaD mt:$1r\ O\lrOlIlIIlTlIMlalltllltl /WOIU d \0 1lO61illM'~ Ihl nm:>""I'n CollJillll C 1I~G!lIh.f/lllton~~ il1CUIISud ~o"Nlianl~ to ~ 1 O:lO OP'" 1(It" I nlMln oflhe year and 450 gpm for Ihe remaining 5 months
14 The Year 51hroUgtt Vatu 1;), M".xlnlIJIIIOlllinUlIDd mWi10 lit I Ie UCimolm Mallll1Jti II ~d 10 Ii<Iloouce!1 rom \llp rI\lllCl11UI1lll'NOIlCoI "1111/ ..... )'I1orlo 1"""'11.' ICIIIlild ~'Q' 01 wy U~nillnl WUlOft~1 (20 %reduclion per year) afier 2 yea", of construction
15. The Estimated Mass in Uranium Material over 10-Year Period is Ihe Cumula~ve Conlribution from the Uranium Malerial to the tailings
16 The Eslimaled Mass in Cell4A (or 48) Mill tailings over 10-year period afier Uranium Malerial processing is lhe tolal cumulative mass conlribullan from including Uranium Material 10 the lailings
17. The approximate percent total conlributed from Uranium Malerial is the 1 O-year contribulion (0 Ihe tailings Irom the Uranium Malerial.
4M
(h':.O. &In Ba.eline Mill
Tailings Conc. After
UranIum Malerl.1
Ploeo .. I"1J IPIII")"
·0 1 _,4
-01
22 3
01
0 1
45.0
3.3
0.1
_10
0..5
0.6
1.1
0.1
3030
00
0.0
5.1
0.0
0 1 aD
203
00
0.0
-01
0.9
Component
i'lco1o)1Q
Ammon'. (Nll..l
~tllc!AlIJ
8lLrlwn IDa}
El"'l/Ilurntal!!
C.~",lu'lI lC~}
~1('lum (C~1
Cobali(Co)
ChrumJu", ICrI
Chloride ell
CfEellf"lCul
fluorldg IF)
I1M'I'oj
1..~~fPb
M.ngln<tt«> Mn
~m:"'Y-'H91
MoJyl,dolillAI (Moj
NlckDI NI)
NII,.lo'jNO-IC}
SOlo.nIUJl'l'180)
SllYur(Ag)
Sulliia (80.=)
flonlllum (TIl
nn Sn
lI.nDd/um VI
ZJrlG IZn!
TotAl S"loJrtetfCom~!!l\ol\'-
TOUlI T~illo9' Cull Mass
Yoarli " .. at 6 Year 7
5L GL 7L
5K Conc. In Cell4A lor 5M 6K Conc. In Cell4A lor 6M 7K Conc. In C.II 4A lor
5J Mass In Cell4A lor 46) Mill Tllllngs I"cr ue> In Baseline flllJI 6J Mass In Cell 4A lor 46) Mill Tlillngs Incr •••• 10 B •• ollno Mill 7J Mas. In Cell 4A lor 4B) Mill Tailings
Eatlmated Ma&s 4BI Mill Tailings alter .fter Uranium Tailings Cone. After Estimated Mass 46) Mill Tailings alt.r after Uranium Tailingo Conc. After Estimated Mass 4B) Mill Tailings after after Ur.nlum
in Uranium Uranium Material M.terlal Processing Uranium Mlterial In Uranium Uranium Materill Malerial Processing Uranium Malerial in Uranium Uranium Material
li1otur1al (tons)" PruCUIIlnq I\On.," IPpml" Pro ... llrn" !llllm}" MDler1aJ ltonal" Pl"Oeus\n1! !IOnl'" (ppm)" Proc •• slnQ (ppm)" Material (tons)" Processing (IOnsl1D
DOOO 2064 191.9 ·0.1 oono 'l~71 '91.9 -C.t 0000 2620
0002 :t:lSE 1\ 31~8 1 2. 0.001 4039 a 31300 ·10 0.001 .en21
0000 1602 14B.9 01 00lI0 11)2:> 1<W 9 -01 0.000 2242
I 5~ 20.7 19.3 HI.) 12.5 220 t70 17.0 0(17 zao
OUO'/ 06 OG 0.1 0.000 U.7 D.G 0.1 0.004 Dli o OOB 38 Hi 01 0,007 ,I> 3.5 0 1 0.005 52
3,09 4375 406.9 38.11 2.53 !lUI:! 402.3 3«3 L97 60113
0.230 684 636 29 0186 BIIi 63.1 2 • ..& 0-1(7 0.0
0.004 67 62 0.0 0,003 81 U 00 0.002 l!~
O.OOB 4\1$ 7 4006.3 17 0.006 5944 4 ~QOI).6 -15 O.ODS B23S:!
0033 05 0." O~ 0.027 ali 04 0 4 0021 01)
0006 18222 1694.4 -O.tl 0.000 .18111 16114.6 ·0.0 0005 26M 1
0142 2379.8 2213.0 10 0 • .117 28555 .27.12.8 OB 0.091 :13312
O.OO~ 33 3.0 00 OOG3 39 ;'0 0 0 OOO~ ".0
20.8 439.0 408.2 2t1H 110 487" m .l ~17 132 5320
0000 38 --3.5 0.0 O.OOIJ 45 3.5 00 0000 5 3
0.000 568 528 00 [) 0011 OB' 52.8 00 0000 7$5
0349 940 B7.4 4~ 02BG :1l1 86.11 J!) 0.~22 130 2
0.0000 25.8 240 00 00005 31 D 240 00 o 00Q.1 361
0.0031 1.6 1.5 0 1 0.01142 19 tro 01 0.0033 '2 QOOa 01 0.1 0.0 0 002 02 0 1 00 0.001 02
3'3~a 696281 649315 17.5 274 837873 64929.5 155 2.14 !i771,~O
0.000 172 16.0 0.0 0.000 206 16U 1'10 0.000 2~.'
OO.Ilj:t 54 5.0 0,0 o,nao 66 50 00 0 000 7~
UOOO 2S21 2629 ·01 0.000 m3 2629 -0.1 J.DOO 395 B
0.6116 69B 5 649.6 no 0 570 &::!b \) 6~8 6 713 0.444 9752
302 ~H 193
I 10754105 '!2lI0435 3 :~~46
•• Assumll20% re<hlll1iQIJ per year 'Qr 5 years !tonl OitIlo,lcal'm!ul'!lIIIll WVI!I~ (100 Ions per YfUll) Ig firm! ,mllC!lIy ~~tlnllIto of 1 6 1~1\ll per year my IImnlllan malollnl
1 The concentration in a!her allemate feeds represents some selected concenlralians for consliluents found in characterization data for other alternate feed materialalicensed lor processing at the Mill. for comparison purposes
2 The range in !he Uranium Material is based on three sampling evenls for Ihe DMC WTP solids.
3 The eslim.ted average concentralian in Uranium Material has been calculated as the mean value reported
4 EsUmaled mass In the Uranium Material is calculated by assuming 197 tons dry annually from historical values
5 Mililailings range and average concenlralians were taken from Mill tailings samples 10 date, as summanzed in TaDle 5 of the draft Stalement of Basis for !he Ulah Groundwaler Discharge Permit for !he Mill (November 29, 2004)
6 Estimaled current mass In Mill tailings Is calculaled by multiplying the esUmated average concentration in the Mill lailings in Column F by 1.769.000 dry Ions of tailings reported in the MiII's aclive Tailings Cell No ~
7 The baseline estimated annual mass in Mill tailings for cell 4A or 48 is calculated by mulliplying the estimated mass in Cell 3 (Column G) by the ratio of Cell 4A (or 48) total mass capacity of 2.150.000 dry tans to
capacity of Cell 3 of 1.769.000 dry Ions as of November 29.2004 and dividing iI by ten years as the estimated lime to fill cell4A (or 48)
The baseline concentration in Cell4A (or 48) Mill tailings is calculated by dividing Column H by 215.000 dry tons as Ihe assumed annual mass addition of tailings to the Cell without the Uranium Material
9 Year 1 and Vear 2 estimated mass in the Uranium Material is assumed to be aquallo Column D historical values
10 The mass in Mil lruj,r~ "tier UIlIW MOII/lmt ClCIIU~lQ Is C1!ICUlII' d bV 1UId'~ lt10 to' I 11ll11ftO:t rna".: (,nm Iha previOUS year 10 lhc 10~118d!1111Q.1Il11ll1 ~ rnM!i aoqnd II,I~ CWTenl year.
Material Processing
(ppm)"
191.9
3HlO 1
10\90
162
0.6
36
398 1
63,0
1i.2
41i06 7
0.3
1(j9~ 6
2212.0
30
353.4
3.5
~8
l3!J.!i
2-0\,0
15
0 1
Mono
160
50
262:9
047 8
11 The concenlratiQn In C!I'I ~A (0."19) MI~ r,jII'~l1l~ 11110' UraIIi.I'!\' lhlll!~' gil ealedIIIQO by dlv<llri9 thn WI~a In Cell4A (or ~B) "'Ifll'lmrg for Inlll yII/Il t>y IrlITICj:Ili ClmIJ.Q!Iv mass in cell4A (or 48) tailings afler Uranium Material is processed.
12. The increase in lInJii1lmo '''~lla~ r;m,c(lrllonlill~ nn r Uflt,w, Pl;;I<l~nl (l'bedu'lg ~CiiU:UlriI&'d bV .ubIm.c1lrl1] ~1l1lH ine cancenlf6l1Ol1 (Column \) trotn c:onconlfilt.o(ll!l('Alll-4i1 (or 48) afler Uranium Material processing for that year
13. The Vear ~ and Year 4 QPil mnlll t!$\:"I:1\ ''111U in \~. Ut;Jr..sm MalanJI ussolllllulQ1lc! t.ti'll&:S 1110 ~",ol.lnl In Column D ba~" <It'll"" flJIUroD~oa IN:((t8?:OO I\Qw 11"001/10 \I> I>() .000 gpm tar7 months of the year and 450 gpm for the remaining 5 months
14 The Year 5 through Year 10 approximate estimated mass in the Uranium Malerial is assumed to be reduced from the maximum histoncal value per year 10 the frnal remedy estimate of dry Uranium Material (20 %reduction per year) afler 2 years of conslructian
15 The Eslimaled Mass in Uranium Material over 10-Vear Period is Ihe CumulaUve Contribution from Ihe Uranium Material to Ihe tailings
16 The Eslimaled Mass in Cell4A (or 48) Mililailings over 10·year period afier Uranium Malerial processing Is Ihe total cumulative mass contribution from including Uranium Maleria! to !he tailings
17. The approximate percenl talal contributed from Uranium Malerial is the 1 O·year contribulion to the tailings from the Uranium Malerial.
7M
Inc ... lle In BIsello" Mill
railings Conc. After
Uranium Material
Proceuing (ppm)"
..(11
-0.9
00
15.2
0.1
0,'
307
23
00
1.3
0 3
·0.4
O.B
0.0
2074
0.0 --0,0 as
0.0
01
0.9
I!U
00
0.0
-01
118
Componelll
A~.tOl1o
IImmol)1~ (NH,)
ArsonIc /As)
B.,lOm al)
Ollrylllum egol
ClldJl~~m Cdl
Calcium ICal
CabAn (Cc)
ClIr!ll1\1um C.
CtllollUI CI
E.$!per (Cu)
AUorillolFl
Iron (FQ)'
l llid Pb
I,"".nJ)1lno .. Mn
~1'rvutyIHvl , -Mo1yb~nnum (Mo)
~1r.~ol(NI
Nllrales (NOx)
s.r",,'um (Se)
sn"", lA."' 90lWe 150,=)
~lum(TI! !!!!JSn
IIQna.dlllmlVl
ZI!,c{ln)
Tou l Soledad Components
Tollll Tailings Cell Mas8
yoar 8 YO-'I.'I/ ~ ariD
SL 9L lDL
8K Conc. In Cell 4A (or 8M 9K Conc. In Cell 4A (Dr 9M 10K Conc. In Cell4A (Dr
8J Mass In Cell 4A (or 4B) Mill Talilngi IllC .... UO In BDGL\lInft Mill 9J Maas In Cell 4A (or 4B) Mill Taillngl Incre .. e in Baseilne Mff1 10J Ma .. In Cell 4A (or 48) Mill Tailings
Estimated Mass 48) Mill Talllngl after after Uranium Taillnga Cone. Aner Estimated Mass 4B) Mill Tailing. aner arter Uranium Tailing. Conc. After Estimated Mass 4B) Mill Tailings aner after Uranium
in Uranium Uranium Material Materl.' Processing Uranium Mltari.' in Uranium Uranium Materi.I Material Procelslng UranIum Material In Uranium Uranium Material Mato".1 Processing
""lGY1,,' (Iona)" Protontno (lOI\I)'" IpJ)lTIl" Processing (ppm)" Material (tons)" Procea.'ng /tona,lO (ppm)!> Procco.llou (p",,1I" MQlJlr1l1 (tons11' Plru:t!!I~lnD (lonol' lel!ml" o.OIlu 3302 191.9 -QI 0.000 371.5 192.0 00 0.000 4128 lOU
CI 0(11 53653 31302 -08 0.000 ijO~8 b-3130.2 -08 0 000 67317 3130 3
O.O'.KI 256 3 149.0 (1 0 0000 28~ 3 1490 0.0 U.000 3204 '4e 0
0.70 237 13.7 13.7 042 241 i2.~ 12..( 0.14 :.I/,)1 113
0 003 10 0.6 01 0,002 II 0.6 0_1 0 001 12 0.6
0,004 60 35 0.1 0.002 67 35 01 0001 74 3.5
1,'11 68IJ II 305.7 '(,7.7 0.85 7608 393.'-25.1 O.2{l 840 2 390 7
0.105 1oBO 62.B 2.1 0.063 1211 62,6 lJ1 11.022 1:M'2 1l2.~
0002 107 62 0.0 0001 12 1 6Z 0.0 0000 134 D.2
(} 004 79259 46068 ·1.2 0.002 89166 48089 -11 0001 99073 <10070
0.016 05 03 0 3 0.009 05 0.3 0,3 o.ooa 05 0.2
(/.003 29155 1694.5 -0.4 0.002 3279.9 16948 .o c D.Cell 36444 IGlJ4 7
0065 3806 B 2212.7 0,7 0.039 42625 2212,8 0,6 0.013 4758. f 2212Ji
0 0112 52 3.0 0.0 0.001 59 30 0,0 oJ)OQ 65 3.U
9,5 5729 333.0 107.0 5.7 610.0 315 ? 169,2 2 0 6433 2092
0 000 60 3.5 0.0 0.000 68 35 0.0 0,000 75 3,5 .-1022 ~28 113.5 5~.a 0 000 908 52 B 0.0 0.000 0.0 0.00(1
0 159 1482 86,1 31 O.OgG 11m·' Ulj.U 28 0.033 1840 856
0.0003 41'3 24,0 0 0 0.0002 46A 24.0 0.0 0,0001 516 2'4.0
0.002.3 25 1.4 00 0.0014 V) l.d 0.0 00005 31 1 4
0.001 0.2 01 O,~ 0.001 02 0 1 0.0 0.000 02 0 1
1.53 1117040 64926.5 12.5 0.92 125661 4 640?.li 3 113 0,32 1:mi>1f1 !\ 64924.7.
0.000 27 5 160 00 0.000 31.0 16 j} 0.0 0.000 3>1 " 16 Q
0.000 81i I/O 00 0.000 97 5])' 00 O.o:m 108 50
D.IlOa 452.4 262,9 ·0 I 0000 506,9 26U1 .01 0.000 5655 262,9
0.318 11133 647.1 fl.! 0192 1251.3 6465 !>.!i 0088 13892 6460
13 8 63 29
I 17204683 1935476,7 215ll'~1T
A&$ulJ)!i 20110 f<ldUclf\1t1 per year for 5 years Irol/l hl~II\~ rn"xlrmll/lliWtll~ (100 10M bal'jlO fJO.llI remed . ~, y uftlrrllill:! Of 1 e Ions per year dry uranium mutcrlol,
1 The concentration in other altemale feeds represenls some selecled concenlrations for constituents found in characterization data for other altemate feed malerials licensed for processing allhe Mill, for comparison purvoses
2. The range in Ihe Uranium Material is based on three sampling events for Ihe DMC WTP solids.
3 The estimated average concenlraUOn in Uranium Material has been calculated as the mean value reported
4 Estimaled mass in the Uranium Matenal is ca'cu'.'ed by assuming 197 tons dry annually from historical values
5 Mill tailings range and average concenlralions were taken Irom Mill tailings sampl.s to dale, as summarized in Table 5 of the draft Statement of BaSis for the Utah Groundwater Discharge Permit for the Mill (November 29, 2004)
6 Estimated current mass in Mill tailings is calculated by mulliplylng Ihe estimated average concentration in the Mill tailings in Column F by 1.769.000 dry tons ol lailings reported in the Mill's active Tailings Cell No 3
7. The baseline estimated annual mass in Mill tailings for cell 4A or 48 is calculated by mulliplying the estimated mass in Cell 3 (Column G) by the ralio of Cell 4A (or 48) lotal mass capacity of 2.150,000 dry Ions to
capacity of Cell 3 of 1,769,000 dry tans as of November 29,2004 and dividing il by ten years as the eslimated time to fill cell 4A (or 48)
B The baseline concentralion In Cell4A (or 48) Mili leil'lngs is calculated by dividing Column H by 2",5.000 dry tons as the assumed annual mass addillon of tailings 10 the Cell without the Uranium Malerial
9. Year 1 and Year 2 estimated mass in lhe Uranium Material is assumed 10 be equal to Column D historical values
10. The mass in Mill tailings afier Uranium Material processing IS calculated by adding the total tailings mass from the previous year to Ihe total addilional tailings mass added In the current year
11 The concentration in Cell4A (or 48) Mliliailings after Uranium Material processing is celculated by dividing the Mass in Cell4A (or 48) Mill tailings lor that year by the total cumulative mass In cell 4A (or 4B) tailings after Uranium Material is processed
12 The increase in basaline Mill tailings cO'~"lv ,ail U,III\IIJfI\ Malerial p;oc"'~hill i!I eIIIcuID d by sublrac~ng b8lehne WtIOOnllnUDII (Column I) from the concentration in Cell 4A (or 4B) after Uranium Material f"OC1l"'''IllIi:! !1~11 VCDt.
13 The Year 3 and Year 4 approximate Dlillmull/dn 111~ ~1ha Lltur.um Matelllli IlPUIn d lobo 5 times Ihe amount eI Co/ulnl, 0 billiOClOl\ the eslimaled increased flow Ireated to be 1,000 gpm for 7 months oflhe )'O;or_~bI:IllP tl ler llle remaining 5 monlhs
14 The Year 5 through Year 10 approxilTtlll ,.,*n\llle;j In "~ 1M Uranium Mnlllftllt' alll.l.Im .. d!tt be reduced from tM I InUtn 1\10'01'''''' value per year to the final remedy estimate at dry Uranium Material (20 %IL..JtJC!lotl I ~.n r 2 years at constructon
15 The Estimated Mass in Uranium Malerial over 10·Year Period Is Ihe Cumulalive Contribution from Ihe Uranium Material 10 the tailings
16 The Estimated Mass in Cell 4A (or 48) Mill tailings over 1 O-year period afier Uran,um Malerial processing is the lolal cumulative mass contribution from including Uranium Maleriallo the lailings
17, The approximate percenllotal contribuled from Uranium Material is Ihe 10·year contribution to Ihe lailings from Ihe Uranium MaleriaL
10M
I_til I in Ba.ellne ""fl
Taillngl Conc. After
Uranium Mate"al
Pto<ellima IPpm)"
00
-OJ
0 0
II I
O()51
0,\
22 7
17
00
.\ 0
02
·0 3
0':6
0.0
Hill 2
O.D ---0,0
2,6
0,0
00
0.0
I D.?
0.0
0,0
·0,1
50
Comoonent
Acetone
Ammonia (NH.I
Arsenic IAsl
svtum (811
aeryilium (Bal
C«dJllluIu (ceS
Calcium (CII
CoballlCo)
chramlum ler)
Chloride ICt)
COl'per ICu)
Fluoride IF)
,ran (Fet
Lead (Pb)
i'IIlnAlnese (M")
fJlercury (H91
Molybdenum (Mo)
Illcl<eIINIl
Nitrate .. tNOxj
Selenium (Sol
Sillier/AD)
Sulfite 'SO.~)
fhalllum (Til
Tin IS")
Vanadium IVI
~Inc (Zn)
TotaJ Salected Components
Total Tailin!!.s Cell Mass
Final
u
Estimated Mass In
N Cell4A (or 4B) Mill
-ElIlhnlled Maau,1n T IlInU' over 1Q-yllar P
Uranium Mlterlll Period Aftlr Unlnlum Percent T alai
over 10-yoar M.te~.1 Proco .. lng Contrlbuted'rom
Period (tona)" (tons)" Uranium Matlrlal"
0.0 412.6 0.000%
0.0 6731.7 0.000%
0.0 3;:0.4 0.000%
24.2 24.2 10U%
0 1 1.2 9.24%
0 1 7 <1 1.77%
49.0 8~(l.2 5.83%
3.6 1342 272%
0 1 13.4 0.444%
01 9907.3 0.001%
0.5 O,1,i 100%
0.1 31>44 4 0.003%
2';1 4758 ; 0.048%
a I 6.5 0.865%
3,2!1 4 6413 51.2%
0.0 75 0.000%
0.0 113.5 0.000%
55 1640 3.00%
'OJ) 51,6 0.019%
01 a1 263%
0.0 0.2 13.79%
53.2 139616.3 0.03B%
00 34.4 0.000%
O.Q 10.8 0_000%
.00 56llS 0000%
11.0 1309 2 0.795%
4795 00223%
2150479.5
•• AAom1{l ~ 10<1,,(;110/1 per year for 5 years [Tarn 1,I/i1Ofg,1 "1"~1I ITjlln levels (190 tons per year) to finallllmedy estimate of 18 tons per year dry uranium material
The concentration in other aile male feeds represents some selected concentrations for consliluents found in characterizalion data for other alternate feed male rials licensed for processing at the Mill. for comparison pu
2. The range in the Uranium Material is based on three sampling events for lhe DMC WTP solids
3 The estimated average concentration in Uranium Material has been calculated as the mean value reported.
4 Eslimatod mass in the Uranium Material is calculated by assuming 197 Ions dry annually from historical values
5 Mill tailings range and average concentrations were takan from Mill tailings samples to dete. as summarized in Table 5 of the draft Statement of Basis for the Utah Groundwaler Discharge Permit for the Mill (November
6 Estimated current mass In Mililailings Is calculated by multiplying Ihe estimated average concentration in the Mill tailings in Column F by 1,769,000 dry tons of tailings reported in the Mill's aclive Tailings Cell No 3
7_ The baseline estimated annual mass in Mill tailings for cell 4A or 4B is calculated by multiplying Ihe estimated mass in Cell 3 (Column G) by the ralio of Celi 4A (or 4B) total mass capacity of 2,150,00(
capacity of Cell 3 of 1,769,000 dry tons as of November 29, 2004 and dividing it by ten years as the estimated time to fill cell 4A (or 4B)
e The boseline concentraUon in Cell 4A (or 4B) Mill tailings is calculated by dividing Column H by 215,000 dry tons as the assumed annual mass addilion of tailings to the Cell without the Uranium Material
9. Year 1 and Year 2 eslimaled mass in the Uranium Matenal is assumed to be equal to Column D histOrical values
'0. The mass in Mililailings a~er Uranium Material processing is calculated by adding the lotaltailings mass from the previous year to the loial additions I tailings mass added in the current year
l' The concenlration in Cell4A (or 4B) Mill tailings after Uranium Material processing is calculated by dividing the Mass in Cell 4A (or 4B) Mill tailings for thai year by the lolal cumulative mass in cell4A (or 4B) tailings aftel
12 The increasa in baseline Mill tailings concentration after Uranium Material processing i$ calculated by sublracttng baselina concentration (Cotumn I) from the concentration in Cell4A (or 4B) after Uranium Material proce
13 The Year 3 and Year4 approximate estimated mass in the Uranium Material is assumed to be Slimes the amounl in Column 0 based on the estimated increased flowtrealed to be 1.000 gpm for 7 months 01 the year,
'4 The Year 5 through Year 10 approximate estimaled mass in the Uranium Materiel is assumed to be reduced from the maximum hislorical value per year to the final remedy estimate of dry Uranium Material (20 '¥oradu"
, 5 The Estlmaled Mass in Uranium Material over 1 a-Year Pariod is the Cumulative Contribution from the Uranium Material 10 the tailings
16 The Estimated Mass in Cell4A (or 4B) Mill tailings over' O·year period after Uranium Material processing Is the total cumulative mass contribution from including Uranium Material to the tailings
17. The approximale percent tolal contributed from Uranium Material is the la-year contribulion to the taltings from the Uranium Material.
( It) TETRA TECH
Attachment 2 -Email from Jeff Kujawa
From: Jeff Kujawa [[e-mail]]
Sent: Friday, August 20,2010 6:41 PM
To: Hudson, Jen
Subject: Chlorofonn in 1007337 -WTP Sludge
Here is what I was able to get back from Salt Lake.
All result a'e flagged with a J indica ing all estimate because it is below the PQL.
The samples were only 27% soljd mean.ing all the results are getting multiplied by a factor of almost 4.
T ha l COl.l ld be cau ioo the number to' look' bigher than it is.
Chloroform occasionally gets into the water/ail' in the building and could conceivably be causing the
contamination, There are trace amounts in the blank at a level about half that of the uncorrected samples
(0.2 ug/Kg) but the result was less than the MDL of 0.291. Hopefully this is helpful.
How was your customer experience? Please SJ~I,-g __ ~~_~YI.Je~dback,
Jeff Kujawa
PROJECT MANAGER
ALS I Enviromental
225 Commerce Drive
Fort Collins, CO 80524
PHONE: + 1 970490 1511
FAX: + 1 970490 1522
www.alsglobal.com
oJ, please con sider the environment before printing this email.
*****************************************************************************
The infonnation contained in this email is confidential. If the reader is not the intended recipient then
YOLI lDust Doti fy the euder i lmedia(e ly by return email and then delete all copies of this email. You
mu l not copy, djstribute, print or otherwise u. e the information. Email may be stored by the Company
to support operational activities. AU information will be held in accordance with the Company's Privacy
Policy wb'ich can be Found 00 the C mpany s website -www.campQelI.com.~u.
*****,l<**lIC*************,***,*****'!c*********'*************************************
Attachment 3 of the Compatibility Memorandum
The OC Pest has low recovery for Endrln in the LCS and LCSD at 53% and 57%. The LCL is 60%
The Herbicide analysis has low surrogate recoveries for sam pIes 1007337-1, 1007337-2 and 1007337-3
at 38%,10% and 34%. The LCL is 57%.
We will document the excursion in the case narratives.
How was your customer experience? Please send us your feedback.
Jeff Kujawa
PROJ ECT MANAGER
ALS I EnviromentaJ
225 Commerce Drive
Fort CoJllns, CO 80524
PHONE: + 1 970490 1511
FAX: + 1 970 490 1522
www.alsglobal.com
tA Please consider the environment before printing this email.
******~**********************************************************************
The information contained in this email is confidential. If the reader is not the intended recipient
then you must notify the sender immediately by return email and then delete all copies of this
( it ) TETRA TECH
II
Tel fax
Technical Memorandum
To: Jo Ann Tischler
Company: Denison Mines (USA) Corp.
From: Jen Hudson
Date: June 14, 2013
Re: Review of Chemical Contaminants in Dawn ' I \ I
Mining Company (DMC) Midnite Mine Je.J" Vl I 1 ~A ~ucib<9 J
Uranium Material to Determine the ~
Potential Presence of RCRA Characteristic
or RCRA Listed Hazardous Waste Project #: 114-181850/300
This report summarizes the characterization of the Dawn Mining Company ("DMC") Uranium
Material (the "Uranium Material"), also referred to as the Water Treatment Plant ('WTP") solids
to be transported from the DMC Midnite Mine, Wellpinit, Washington, to determine whether or
not the Uranium Material is or contains any listed or characteristic hazardous waste as defined
by the Resource Conservation and Recovery Act ("RCRA"). The results of this characterization
will provide information to Denison Mines (USA) Corp. ("Denison") to determine the
requirements necessary for an amendment to its White Mesa Uranium Mill ("Mill") State of Utah
Radioactive Materials License No. UT1900479 (the "License"), to permit the processing of the
Uranium Material as an alternate feed material at the Mill.
In accordance with the definitions in the Atomic Energy Act, as amended, and 10 Code of
Federal Regulations ("CFR") 40.4, ores with natural uranium content of 0.05 weight percent or
higher are classified as source material and, as per 40 CFR Part 261.4, are exempt from
regulation under RCRA. As summarized in the Radioactive Material Profile Record, the
Uranium Material has historically had an average uranium content of approximately 0.18 wet
weight percent uranium (0.21 wet weight percent UaOs), 1.2 dry weight percent natural uranium
(1.4 dry weight percent UaOs). This Uranium Material is therefore source material, and is
categorically exempt from RCRA.
Although the Uranium Material is exempt from regulation under RCRA, Denison nonetheless
requires a due diligence evaluation of potential materials to be processed, to assess:
1. Whether the material is, or contains, any hazardous constituents that would be regulated
as RCRA listed hazardous waste, if the Uranium Material were not categorically exempt
from RCRA as a uranium ore or a categorically exempt solid waste.
2. Whether the material contains any constituents that could generate a worker safety or
environmental hazard under the conditions under which it will be processed at the Mill.
3. Whether the material contains any constituents that would be incompatible with the Mill's
tailings system.
This memorandum provides the evaluation of the regulatory status of the Uranium Material
relative to RCRA. Evaluation of potential safety and environmental hazards, and compatibility
with the Mill's tailings system are provided in a separate memorandum.
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1. Site History and Background
The Midnite Mine Superfund Site ("Site") is an inactive open-pit uranium mine that is currently
administrated by the U.S. Environmental Protection Agency ("EPA") Region 10 under the
Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), also
known as Superfund. The Site EPA Identification Number is WA980978753.
The Site is located on the Spokane Indian Reservation in eastern Washington State,
approximately 48 air miles northwest of Spokane (Figure 1). These lands are owned by the
federal government and held in trust for the Spokane Tribe of Indians ("Tribe") and individual
tribal members.
Uranium was discovered on the site in 1954. The prospectors and several tribal members
subsequently formed Midnite Mines, Inc. and acquired the mining leases at the Site. Midnite
Mines, Inc. then joined with Newmont Mining Company ("Newmont") to create the DMC, with
Newmont Mining Company as the 51 percent shareholder and Midnite Mines, Inc. owning 49
percent. Newmont USA Limited is the corporate successor of Newmont Mining Company and
continues to be the majority shareholder of DMC (EPA, 2006).
The mine operated from 1954 until 1965, providing uranium under contracts with the United
States Atomic Energy Commission ("AEC"). The mine went into standby from 1965 and
resumed mining in 1969. The ores were milled at the Mill site, located near Ford, Washington.
Mining was suspended in 1981 due to decreases in uranium prices and never resumed. The
Mine was regulated by several United States Department of the Interior ("USDOI") agencies,
including U.S. Geological Survey, U.S. Bureau of Mines, and U.S. Bureau of Land Management
("BLM") Minerals Management Service. The Bureau of Indian Affairs ("BIA") represented the
Tribe and individual tribal allotment owners in matters related to leases and royalties.
An estimated 5.3 million tons of ore and proto-ore and 33 million tons of waste rock were
removed from nine pits between 1955 and 1981. All but two of the mine pits have been
backfilled using waste rock. The last two pits to be mined consisted of Pit 3 and Pit 4, these pits
were not backfilled and remain open (EPA, 2006). Several reclaimed waste rock piles remain
on the mine property and an estimated 2.4 million tons of ore and proto-ore were stockpiled on
Site during active mining operations.
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1.1 Seep and Surface Water Collection System
In the late 1970s, seeps with dissolved ore-derived constituents were observed at the toe of the
largest waste rock piles at Midnite Mine. The BlM ordered DMC to construct a control pond
(the Pollution Control Pond, or "PCP") in 1979 to capture the seeps for evaporation. Following
the suspension of mining in 1981, DMC began pumping water from the PCP to the now inactive
Pit 3 in response to growing quantities of water in the PCP and newly identified seeps at the
base of the largest waste rock pile. Since cessation of mining operations, mine site surface
runoff water has been collected in engineered channels and diverted to the inactive open mining
pit, Pit 3. In addition, natural ground water from the ore zones of the pits has flowed into and
accumulated in the two open mining pits, Pit 3 and Pit 4, at the site. In February of 1985, DMC
applied to the EPA for a National Pollution Discharge Elimination System ("NPDES") permit to
allow for the discharge of treated water from those pits and other waters collected on the site.
In September of 1986 DMC was issued a NPDES permit.
In 1987 a Compliance Order was issued by EPA under the Clean Water Act ("CWA") and in
conjunction with the NPDES permit requiring DMC to eliminate discharges of pollutants to
waters of the United States. Subsequently, DMC developed a seep collection and pumpback
program that collected water from Site drainages and returned them to the PCP and Pit 3 and
mixed with the accumulating water from surface water runoff as described previously. Seep and
surface water collection occurs at six specific locations throughout the Midnite Mine Site as part
of this seep collection and pumpback program including the PCP. Pit 3 waters consist of mine
site waters collected and pumped from the seep collection and pumpback program, direct
precipitation and local mine surface runoff in the immediate area of Pit 3, and natural ground
water inflow from the Pit 3 ore zones. The water that accumulates in Pit 4 consists of direct
precipitation, groundwater inflow, and surface runoff in the immediate area of Pit 4. All waters
collected in the seep collection and pumpback system are derived from seeps from waste rock
piles or surface runoff at the Site. The seep collection and pumpback system does not collect
water from any areas that have ever been known to contain or currently contain any listed
hazardous wastes.
In 1988, DMC built a water treatment plant at the Site to treat the accumulating water in the
open pits. In 1991 the BlM issued an order requiring DMC to dewater the open pits and treat
for metals, uranium and sulfate removal in the water treatment plant for compliance with the
NPDES permit and in 1992 the WTP began treating pit water.
There are no shop areas, petroleum tanks, or other sources of hydrocarbons at the mine site
with the exception of a 300 gallon diesel fuel tank for the Pit 4 pump, and a 300 gallon tank of
gasoline for WTP equipment. The diesel fuel tank and pump are located in secondary
containment near Pit 4 with a maximum volume stored of 300 gallons, and the 300 gallon
gasoline tank is located next to the WTP. These fuels are stored and managed separately from
the Uranium Material and have not impacted the Uranium Material in the past nor do they have
a reasonable potential to do so in the future. The constituents precipitated from the WTP
influent are derived from flow of natural precipitation through uranium mine waste rock and
natural ore, collected surface runoff from natural materials, and natural ground water inflow from
the ore zones into one of the two remaining open pits, Pit 3 and Pit 4 as discussed above.
A Remedial Investigation/Feasibility Study (RI/FS) was completed on 9/30/05 for the Midnite
Mine. The Selected Remedy for the Site is Alternative 5a (Complete Pit Backfill with Passive
Drains and Ex-Situ Water Treatment) of the FS. Based on the FS and issued in the Record of
[ It;) TETRA TECH
Decision (ROD) as the Selected Remedy ("Remedy), Pits 3 and 4 will be backfilled, waste rock
and proto-ore will be moved and capped, and a new passive water collection system will be
installed to capture groundwater from these and other backfilled pit areas. The surface water
management will be designed to divert surface flows around sources of contamination and
therefore minimize the volume of water to be treated after the Remedy is implemented. The
existing WTP is located on a waste rock pile that must be removed for the Remedy. Therefore,
a new water treatment plant will be built before construction of the Remedy begins It is
estimated that the construction will require approximately 2 years and the new WTP must be
capable of treating water at a rate of 1,000 gpm year round for the construction phase. It is
likely that the new WTP will be comparable to the current treatment employed using lime and
barium addition for removal of constituents from the feed water. This higher design flow will
allow for rapid dewatering of the pits during backfilling, as well as groundwater collection and
surface water collection treatment. After construction, it expected that the flows will be reduced
to an ultimate annual value of 65 million gpm and will take an estimated 6 to 7 years to reach
these reduced flows.
The water quality during construction is assumed to be the same composition as currently is
captured and treated, and it is expected that the water quality after implementation of the
Remedy will improved from current water quality.
1.2 Water Treatment Plant Process Description
The WTP is a conventional lime treatment high-density solids process in which the metals and
uranium are precipitated out in the treatment process, and includes addition of barium chloride
for radium removal. A polymer coagulant is added, and the resultant slurry is settled and filtered
to produce a solution free of solids for surface discharge under the EPA CERCLA program and
NPDES permit issued to DMC. The precipitate is currently centrifuged and the final solids
contain on average 0.18 wet weight percent uranium (0.21 wet weight percent U30 a) at an
average historical solids content of 15 percent. 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
U30 a). The wet weight concentrations of the constituents present in the Uranium Material are
expected to increase by 67 to 300 percent from current values as a result of dewatering with the
filter press. The total constituent mass will remain equal to or less than the amount currently
produced as discussed herein. No other material changes to the physical or chemical
processes of the WTP are planned. Therefore, no other significant changes to the chemical
composition of the Uranium Material are expected to occur.
The WTP is typically operational from early May through the end of October and operates 24
hours per day, four days per week. WTP influent is derived from approximately 400 gpm
influent from Pit 3 and approximately 50 gpm influent from Pit 4. The pit waters are pumped to
the WTP using positive displacement pumps which are piped separately to the WTP through
polyethylene piping. The WTP reagents are pre-mixed in individual mixing tanks prior to
addition to the treatment stream. The hydrated lime and flocculent are pre-mixed using makeup
water from Pit 4 while the barium chloride is mixed with potable water.
The powdered barium chloride is pre-mixed at a ratio of 500 pounds (Ibs) of barium chloride to
1,200 gallons of potable water. This barium chloride solution is then injected directly into the Pit
[ it] TETRA TECH
3 influent line in the WTP at rates from 170 milliliters per minute ("ml/min") to 1BO ml/min for the
400 gpm inflow for precipitation of radium. The Pit 3 influent then discharges into the first of
three agitation tanks for mixing. Added to this agitation tank is approximately 90 gpm, or
roughly 20% of the total process stream, from the clarifier bottoms (clarifier underflow) to
increase the overall final Uranium Material density.
This first agitation tank then gravity feeds into a second agitation tank where hydrated lime is
added for the precipitation of uranium and metals. The hydrated lime solution is added to the
second agitation tank as needed to achieve a target pH of 9.B to 9.9 standard pH units prior to
clarification. The second agitation tank gravity feeds to a third agitation tank for additional
mixing, which in turn gravity feeds to the neutralization surge tank.
The neutralization surge tank receives two influent streams. The primary influent stream is the
flow from the third agitation tank, described above. The secondary influent stream is the liquid
collected from the dewatering process (currently centrifuge, which will be replaced by a
hydraulic filter press system in 2011). Waters removed by the dewatering process are collected
in the concentrate surge tank and pumped to the neutralization surge tank. At the discharge of
the neutralization surge tank, an anionic water soluble polymer (Neo Solutions, NS-6B52) is
added as a coagulant to facilitate clarification.
The neutralization surge tank discharge is currently sent to one of two clarifiers. Pit 4 water is
higher in pH and significantly lower in metals and radionuclide concentrations than the Pit 3
water (See Table 1) and therefore requires less initial treatment. As a result, the remaining
portion of the Pit 4 influent stream not used for reagent make up is pumped directly to the
clarifiers. The precipitated solids are drawn from the clarifier bottom and, as mentioned
previously, approximately 20% of the clarifier underflow (approximately 90 gpm) is pumped back
to the first agitation tank to increase overall Uranium Material density. The liquid fraction of the
remaining BO% of the process stream (approximately 360 gpm) is decanted from the top of the
clarifier (clarifier decant) for final pH adjustment and addition of scale inhibitor for direct surface
discharge, while the remaining solids fraction from the clarifier underflow is sent to the
centrifuge for dewatering. The centrifuge will be replaced for the 2011 operating season with a
hydraulic filter press as discussed in more detail below.
The clarifier 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 ("anti-scalant") is added prior to
discharge. Neither the sulfuric acid nor anti-scalant added to the final plant discharge water are
introduced to the solids generation process and therefore do not become components of the
Uranium Material.
The dewatered solids are currently transferred from the centrifuge to the hauling truck via a
discharge conveyor. The transport truck is housed within the WTP building and remains in that
location until it is hauled for final disposal, thereby eliminating any opportunity for other waste
materials to be introduced into the Uranium Material.
From 2001 through 200B the WTP processed produced between 1.05 million ("Mil) Ibs and 2.5
M Ibs per year of Uranium Material at 15% solids (average 1.9 M Ibs at 15% solids). This is
equivalent to 164,000 to 393,500 dry tons of annual solids produced. The average annual total
volume of Pit water treated is approximately 55.5 million gallons for the period of 2001 through
200B. Volumes vary depending on how much precipitation the site receives in a given year.
[ It) TETRA TECH
The plant will be modified for the 2011 operational season and the centrifuges currently used for
Uranium Material dewatering will be replaced by a hydraulic filter press. It is expected that the
same water soluble polymer will be used for coagulation; however the polymer application rate
may be increased from the current rate to improve the dewatering characteristics of the solids.
The Uranium Material solids percent is expected to increase from an average of 15 weight
percent solids to between 25 and 45 percent, resulting in an estimated lower average volume of
sludge production while the total dry weight production will remain in the range of 82 tons to 197
tons annually. No material changes to the physical or chemical processes of the WTP are
planned aside from the increased flows to the new plant as discussed above. Therefore, no
other significant changes to the chemical composition of the Uranium Material are expected to
occur.
2. Basis and Limitations of this Evaluation
The Uranium Material to be processed at the Denison White Mesa Mill consists solely of the
solids to be produced from the existing DMC WTP. The characterization of the Uranium
Material is based on assessment of the mine site historical operations, the origins and handling
of the waters treated in the WTP, assessment of the WTP influent water quality, assessment of
the treatment process and process chemicals, analysis of representative Uranium Material
samples in 2010 as well as assessment of historical Uranium Material analysis for a limited suite
of parameters.
Three Uranium Material samples collected in 2010 were tested for radionuclides, recoverable
metal values, RCRA regulated organic and inorganic contaminants, diesel and gas range
organics (ORO and GRO) as well as for RCRA hazardous waste characteristics. Radionuclide
analyses included Lead-210, isotopic thorium, gross alpha and beta, and total alpha emitting
radium . Additional parameters including nutrients (ammonia and nitrate/nitrite), and other non-
metals were included in the analysis to assess compatibility with existing tailings and process
chemicals at the White Mesa Mill and presented in Technical Memorandum: Review of Chemical
Contaminants in Dawn Mining Company (DMC) Midnite Mine Uranium Material to Determine the
Potential Worker Safety and Environmental Issues and Chemical Compatibility at the Denison
Mines White Mesa Mill. The historical water quality data indicates that influent water parameters
are relatively consistent over the WTP operational history (Table 1). The total uranium values
from the 2010 sampling results indicate average uranium concentration in the sludge to be
15,333 mg/kg (1.5 percent) corresponding with the historical values for uranium.
Organic constituents have not historically been analyzed in the WTP influent, or the final
Uranium Material; however, comprehensive laboratory analysis of recent WTP solid samples is
included in this report. The recent Uranium Material test results are taken to be representative
of the material characteristics over the WTPs operating life, as the characteristics have not
varied widely across different periods of WTP operation. As a result, these studies provide
sufficiently representative characterization to assess the regulatory status, worker safety
environmental hazards, and chemical and processing properties of the Uranium Material.
Table 2 presents the results of 2009 and 2010 toxicity characteristic leaching procedure
("TCLP") analyses for the eight RCRA metals. Table 3 presents testing results of the Uranium
Material for RCRA hazardous waste characteristics including organochlorine pesticides,
chlorinated herbicides, volatiles and semi-volatiles, and for corrosivity, reactivity and ignitability.
Table 4 presents total analyses of the Uranium Material for uranium, 20 metals, total volatile and
[ It) TETRA TECH
semi-volatile organics, gasoline range organic and diesel range organics, inorganic parameters
including ammonia and nitrate plus nitrite as well as gross alpha beta.
The following contamination evaluation is based on :
1. Midnite Mine Superfund Site Record of Decision
2. Current Midnite Mine Uranium Material analytical data
3. Historic Midnite Mine Water Quality and Uranium Material analytical data
4. Denison estimated tailings compositional data for tailings
5. Denison Protocol for Determining Whether Alternate Feeds Are Listed Hazardous
Wastes (Denison, November 1999).
6. Radioactive Material Profile Record for the Dawn Mining Company Midnite Mine
Uranium Material (September 2010)
7. Affidavit of Robert Nelson, Midnite Mine Site Supervisor (Attachment 2 -October 2010).
Denison has developed a "Protocol for Determining Whether Alternate Feed Materials are
Listed Hazardous Wastes" (November 22, 1999) (the "Protocol"). The Protocol has been
developed in conjunction with, and accepted by, the State of Utah Department of Environmental
Quality ("UDEQ") (Letter of December 7, 1999). Copies of the Protocol and UDEQ letter are
provided in Attachment 2 of the License Amendment Application. The RCRA evaluation and
recommendations in this Report were developed in accordance with the Protocol.
3. Application of Protocol to Uranium Material
3.1 Source Investigation
Several of the information sources enumerated above were used to perform the Source
Investigation indicated in Box 1 of the flow diagram (the "Protocol Diagram") that forms part of
the Protocol.
The following sections describe the status of the Uranium Material relative to RCRA
Characteristic and RCRA Listed Hazardous Waste regulations, and relative to the specific
parameters identified in the Denison/UDEQ Hazardous Waste Protocol. Although alternate feed
materials may contain RCRA characteristic wastes, for completeness, this Report also
determines whether or not the Uranium Material contains any characteristic wastes.
3.2 Detennination Methods in the Denison I UOEQ Protocol
3.2.1 Regulatory History of the Midnite Mine Uranium Material
As mentioned in Section 1.0 of this Report, DMC applied to the EPA for a NPDES permit in
February of 1985 to allow for the discharge of treated water from the open pits (Pits 3 and 4)
and other waters collected on the Site. In September of 1986, the EPA's Region 10 issued
DMC an NPDES permit (WA 002572-1), which was administered by the State of Washington.
In 1987 a Compliance Order was issued by EPA under the Clean Water Act requiring DMC to
eliminate discharges of pollutants to waters of the United States. Subsequently, DMC
developed a seep collection and pumpback program that collected water from Site drainages
and returned them to a pollution control pond and Pit 3.
In 1988, DMC built the WTP at the Midnite Mine to treat the accumulating water in the open pits.
However, the treatment plant was not operated until approximately four years later. In 1991 the
[ ii;] TETRA TECH
BLM issued an order requiring DMC to dewater the open pits for compliance with the NPDES
permit issued in 1986, and in 1992 the WTP began treating pit water.
The Washington Department of Health, under the authority of the Nuclear Regulatory
Commission ("NRC") Agreement State Program, issued a Radioactive Materials License (WN-
10390-1) in 1992 for possession of the Uranium Material. This License was terminated by the
State of Washington on December 31,2008. Operation of the WTP is currently administered by
the EPA under CERCLA.
In 1998, EPA performed an Expanded Site Investigation and scored the Site using the Hazard
Ranking System to determine the eligibility of the Site for inclusion on the National Priorities List
("NPL"). The Site was included in the NPL and a Record of Decision ("ROD") was signed on
September 29, 2006, which established the Selected Remedy for the Site. Part of the Selected
Remedy for Operable Unit 1 (Mined Area and the Mining Affected Area, which includes Pit 3
and Pit 4) included treatment of seep collection system waters and the pit waters, with on-site
discharge of treated water in compliance with interim discharge limits (EPA, 2006).
The Uranium Material generated from the treatment of these mine waters were processed off
site at the Dawn Uranium Mill ("Dawn Mill") for their source material content under the Dawn Mill
License (WN-1043-2) from 1992 until the mill was decommissioned in 2001 . Following mill
decommissioning, the solids were placed directly in the Dawn Mill tailings facility (License
Conditions 9.B, and Conditions 28 through 33). The Uranium Material are currently being
disposed of at the Tailings Disposal Area 4 ("TDA-4") at the Dawn Mill Site. However, per the
ROD , alternate disposal of the Uranium Material is required starting in 2011 due to mandated
reclamation of the tailings facility.
The Rod states that the Uranium Material may be disposed of at a licensed off-site disposal
facility, or additional treatment, such as ion exchange for uranium removal to modify solids
characteristics, may be implemented for alternative disposal options. The Dawn Mill tailings and
reclamation materials are not included in the materials to be sent to the White Mesa facility, only
newly generated Uranium Material from the Midnite Mine.
The Uranium Material, which has materially not changed in form or content since first being
produced in 1992, remain definitional source material as per 40 CFR Part 261.4, and is explicitly
exempt from regulation under RCRA. However, for the sake of completeness, Denison has
required the following evaluation to confirm that even if the Uranium Material were not exempt
from RCRA, it is not and does not contain, a RCRA-listed waste, nor does it contain any
characteristic wastes.
3.2.2 Evaluation of Potential RCRA Listings Associated with Specific Contaminants
For potential alternate feeds that are not exempt from RCRA, the Protocol describes additional
steps Denison will take to assess whether contaminants associated with any potential RCRA
waste listings are present, and the likelihood that they resulted from RCRA listed hazardous
wastes or RCRA listed processes. These steps include tabulation of all potential listings
associated with each known chemical contaminant at the site, and the review of chemical
process and material/waste handling history at the site to assess whether the known chemical
contaminants in the material resulted from listed or non-listed sources. This evaluation is
described in Box 8 and Decision Diamonds 9 through 11 in the Protocol Diagram.
[ It] TETRA TECH
If the results of the evaluation indicate that the contaminants are not listed waste, the Protocol
specifies an additional assessment of whether the data on which this determination was made is
sufficiently representative, or whether an ongoing acceptance sampling program should be
implemented, and a similar evaluation performed on any new constituents identified during
acceptance sampling.
In the case of the DMC Uranium Material, Steps 9 through 11 is not required as indicated by the
statements provided in the Affidavit of Robert Nelson (Attachment 1). However, for the sake of
a thorough due diligence evaluation, Steps 9 through 11 were completed , and the results are
presented below.
4. Chemical Contaminants
The chemical contamination profile reported for the DMC Uranium Material includes historic
WTP influent water quality data (Table 1), limited historical testing of the Uranium Material
(Table 2), and three Uranium Material samples collected during the 2010 WTP operations
period. These 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 analyses were performed to determine whether the Uranium
Material is classified as a listed waste under RCRA and to determine the RCRA characteristics
for processing and disposal considerations at the Mill.
A summary of the RCRA listed hazardous waste findings for metal analytes is provided in Table
4 of this Report.
Determination of whether the Uranium Material is listed according to RCRA regulations included
consideration of the source history and the total constituent analytical values from material
sampling analyses presented in Table 4. The Uranium Material has not been classified or
treated as listed hazardous waste nor has it been in contact with any listed hazardous wastes
as attested to in Attachment 2 of the License Application Amendment (Affidavit of Robert
Nelson, October 2010).
There were no processes conducted at the site which fall under the "F" listed hazardous wastes
from non-specific sources and designated in the following seven categories:
• Spent solvent wastes (F001-F005)
• Wastes from electroplating and other metal finishing operations (F006-F012, F019)
• Dioxin-bearing wastes (F020-F023 and F026-F028)
• Wastes from the production of certain chlorinated aliphatic hydrocarbons (F024, F025)
• Wastes from wood preserving (F032, F034, and F035)
• Petroleum refinery wastewater treatment sludges (F037 and F038)
• Multi-source leachate (F039)
There were no processes conducted at the site which fall under the "K" listed hazardous wastes
from specific sources and designated in the following 14 categories:
• Wood preservation (K001)
[ ii:] TETRA TECH
• Inorganic pigment manufacturing (K002 -K008)
• Organic chemicals manufacturing (K009-K030, K083, K085, K093-K096, K103-K105,
K107-K118, K136, K149-K151, K156-K159, K161, K174-K175, K181)
• Inorganic chemicals manufacturing (K071, K073, K106, K176-178)
• Pesticides manufacturing (K031-K043, K097-K099, K123-K126, K131-K132)
• Explosives manufacturing (K044-K047)
• Petroleum refining (K048-52, K170-K172)
• Iron and steel production (K061-K062)
• Primary aluminum production (K088)
• Secondary lead processing (K069, K100)
• Veterinary pharmaceuticals manufacturing (K084, K1 01-K1 02)
• Ink formulation (K086)
• Coking (K060, K087, K141-K145, K147-K148)
• Military munitions
The Uranium Material does not contain any lOp" or IOU" listed wastes as there have been no
discarded commercial chemical products, off-specification species, container residues, and spill
residues thereof. Any chemicals used at the WTP are used for their intended purpose and are
not waste materials.
4.1 Volatile Organic Compounds
The sampling results for the total VOCs in Table 4 indicate that acetone, methylene chloride,
and toluene were reported at very low concentrations in the three samples for total analysis.
Acetone was reported at concentrations ranging from 22 milligrams per kilogram ("mg/kg") to 33
mg/kg with an average value of 28 mg/kg. Methylene chloride was reported at concentrations
ranging from 3.7 mg/kg to 5.8 mg/kg with an average value of 4.4 mg/kg. Toluene was reported
at concentrations ranging from 1.5 mg/kg to 2.7 mg/kg with an average value of 2.1 mg/kg.
However all of these constituents were also detected in the method blanks for the coinciding
sample runs . Chloroform was detected in the three samples just above the method detection
limit ("MOL"). The method blank samples did indicate low levels of total chloroform; however
the detection of chloroform in the blank was below the MOL and was therefore not reported by
the laboratory as stated in the email from laboratory personnel Jeff Kujawa (Attachment 3). As
indicated; chloroform, methylene chloride, and toluene were therefore present due to laboratory
interferences, and not present in the Uranium Material.
Trichloroethene (or trichloroethylene) was reported at very low concentrations from the TCLP
testing of only two of the Uranium Material samples with concentrations ranging from 1.5
micrograms per liter C'I.Jg/L") to 2.7. ~g/L with an average concentration of 2.1 ~g/L. However,
trichloroethene was detected in the leachate method blank at 3.3 ug/L which was above the
MOL, but below the reporting limit ("RL"). Two of the three associated samples had detectable
amounts less than the RL and less than 10 times the amount found in the method blank, so the
samples were qualified as "U", raising the amount to the RL (5 ug/L). That is, trichloroethene
was identified in the results due to laboratory interferences, and is not present in the Uranium
Material.
Review of the site operational history, WTP processes and chemicals, as well as sample
collection, preservation and shipping methods did not identify any source of potential sample
contamination for these constituents. Since these compounds were present in the method
blank and there are no known sources for these constituents from the Site or from the sampling
[ It) TETRA TECH
preservation or shipping methods, their detection is apparently due to laboratory influences, and
does not indicate they are present in the Uranium Material. These are common laboratory
solvents and there are multiple laboratory pathways that could introduce them during analytical
processes, including the use of methylene chloride for extraction of SVOCs in other analytical
procedures.
4.2 Semi-Volatile Organic Compounds
The sampling results for the total semi-volatile organic compounds in Table 4 indicate that there
was no detection of any of the constituents tested for and are consistent with plant operations
and activities historically conducted at the mine site.
4.3 Other Non-Metal Inorganic Compounds
The sampling results for Ammonia, Nitrate/Nitrite, and Fluoride indicate low levels of these
constituents in the Uranium Material. Historic water quality sampling data indicate that all three
of these constituents are present in the feed water to the WTP as presented below.
Istorie W Q ater f S I uality or e eeted Parameters
Fluoride Ammonia N itrate/N itrite
(mg/L) (mg/L) as N (mg/L)
Min 0.2 0.02 0.01
Max 5.0 0.1 46.0
Avg 1.2 0.1 4.3
Count 25 4 154
4.3.1 Ammonia as N
In general, nitrogen (ammonia, nitrate/nitrite) compounds may carry the following RCRA listings:
P002, P007. P008, P009. P020, P024, P027 . P031, P034. P041. P042, P044, P045. P046.
P047, P048. P066. P069. P070, P071, P076, P077. P078, P081. P082, P084, P089, P097,
P101, P112, P119, P128, P185, P189, P191 . P194. P197, P198, P203. U003, U005, U009,
U010, U011. U012, U014. U021. U026, U035. U049, U058, U059, U073, U091, U092. U093,
U095. U105, U106, U110, U111, U149. U150. U152, U155. U158. U163. U167, U168, U169,
U170, U171. U172, U173, U174. U176, U177, U178, U179, U180, U181, U185. U194, U206,
U217, U221, U222, U234, U236, U237, U271, U328. U353, U394, and U404 if they resulted
from the disposal of commercial chemical products, or manufacturing of chemical intermediates
associated with each hazardous waste number. There is no reason that any of these
compounds would be present as chemical product, off-spec product, or manufacturing
byproduct on the Site.
Nitrogen wastes may carry the following F or K listings if they resulted from the specific
industries listed here:
F004, F005
K060, K144
K011. K013-014. K025, K104, K111-116
Spend Solvent Wastes
Coking
Organic Chemical Manufacturing
[ It;) TETRA TECH
None of the above operations or processes was ever conducted at the Midnite Mine. It is
present in the Uranium Material as an impurity precipitated during the water treatment process
and none of the F or K listings are applicable to the Uranium Material.
Ammonia compounds may be present in the Uranium Material as a trace residue from the
historical use of blasting caps during mining operations, or as a result of nitrogen rich windblown
soils from nearby agricultural operations in the area of the Site. Nitrogen is also naturally
occurring in the surface water and groundwater seeps due to the natural nitrogen cycle in which
nitrogen in the atmosphere is converted in the soils initially to ammonium and further converted
into nitrate and nitrite. These nitrogen constituents are incorporated into the surface water and
groundwater systems resulting in detectable amounts of ammonia and nitrate/nitrite.
4.3.2 Nitrate/Nitrite as N
Nitrate/nitrite compounds may be present in the Uranium Material as a trace residue from the
historical use of blasting caps during mining operations, or as a result of nitrogen rich windblown
soils from nearby agricultural operations in the area of the Site. Nitrogen is also naturally
occurring in the surface water and groundwater seeps due to the natural nitrogen cycle in which
nitrogen in the atmosphere is converted in the soils initially to ammonium and further converted
into nitrate and nitrite. These nitrogen constituents are incorporated into the surface water and
groundwater systems resulting in detectable amounts of ammonia and nitrate/nitrite.
4.3.3 Chlorides
Chlorides may carry RCRA listings U216, P033 or P095 if they resulted from the disposal of
thallium chloride, cyanogen chloride, or carbonic chloride as commercial chemical products, off-
spec commercial chemical products, or manufacturing chemical intermediates.
Thallium chloride is used as a catalyst in chlorination reactions, and as a radiation sensor in
applications such as control on sun lamps. Cyanogen chloride is used in organic synthesis, as
an active agent in tear gas, and as a warning agent (due to odor warning properties) in
fumigation gases. Phosgene is used widely in synthesis for addition of carbon groups to larger
structures, particularly in manufacture of isocyanate intermediates, other polymers, and
pestiCides. It was formerly used in chemical warfare agents as a choking agent. There is no
reason that any of these compounds would be present as chemical product, off-spec product, or
manufacturing byproduct on the Site.
None of the above RCRA listings applies to the chlorides present in the WTP pits. Chlorides
are naturally present as trace contaminants in many transition metal and rare earth ores, and
the addition of barium chloride to the influent Pit 3 water may contribute minimal amounts of
chlorides. This is the most likely source of the chlorides in the Uranium Material. Chlorides
from ore sources are not associated with any RCRA hazardous waste listings.
4.3.4 Fluorides
Fluorides may carry RCRA listings U005, U033, U075, U134, U121, U120, P043, P056, P057,
P058 if they resulted from the disposal of acetamide, carbonic difluoride,
dichlorodifluoromethane, fluoranthene, hydrofluoric acid, trichlorofluoromethane,
diisopropylfluorophosphate (DFP), fluorine, fluoroacetamide, or fluoroacetic acid .
( it) TETRA TECH
None of the above RCRA listings applies to the chlorides present in the WTP pits. Fluorides are
naturally present as trace contaminants in many transition metal and rare earth ores. This is the
most likely source of the fluorides in the Uranium Material. Fluorides from ore sources are not
associated with any RCRA hazardous waste listings.
4.3.5 Sulfates
Sulfates can carry RCRA listing U103 if they resulted from the disposal of dimethyl sulfate
commercial chemical products, off-spec commercial chemical products, or manufacturing
chemical intermediates. Dimethyl sulfate is used in organic synthesis as a methylating agent for
production of amines, phenols, and polyurethanes adhesives. There is no reason ditnethyl
sulfate would be present as chemical product, off-spec product, or manufacturing byproduct on
the Site.
Sulfates can also carry RCRA listing P115 if they result from the disposal of thallium sulfate
commercial chemical products, off-spec commercial chemical products, or manufacturing
chemical intermediates. Thallium sulfate is used as a rodenticide and pesticide, in the measure
of ozone content in gases, and as an indicator in testing for iodine in the presence of chlorine.
There is no reason thallium sulfate would be present as chemical product, off-spec product, or
manufacturing byproduct on the Site.
Neither of the above RCRA listings applies to the sulfates present in the WTP pits. As indicated
in the historic process information from Site, sulfates resulted from the metal sulfates in the
influent from the pits, which are not associated with any RCRA hazardous waste listings.
4.4 Metals
A summary of the RCRA evaluation findings for the metal analytes identified in the Uranium
Material is provided in Tables 2, 3 and 4 of this report.
The three 2010 samples were analyzed for total metals and results indicate that 14 metals:
barium, beryllium, cadmium, calcium, chromium, cobalt, copper, iron, lead, manganese, nickel,
selen ium, silver, and zinc were present in the Uranium Material.
All of the metals are known to be constituents of uranium ores with the exception of barium,
which is added to the treatment process for radon removal. Residues from processing of
uranium are not RCRA listed hazardous wastes.
Barium may be associated with one RCRA listing, P013, if it resulted from the disposal of
barium cyanide commercial chemical products, off-spec commercial chemical products, or
manufacturing chemical intermediates. Barium cyanide is used in metal finishing and
electroplating. There is no reason barium would be present as a chemical product, off-spec
product, or manufacturing byproduct on the Site.
Barium chloride is added in the water treatment plant to precipitate out the radium from the
influent water from Pit 3 and Pit 4. It is therefore an impurity precipitated out during the water
treatment process and the P013 listing does not apply to the Uranium Material.
[ it:] TETRA TECH
4.5 Summary of RCRA Listed Material Findings
Based on the information presented above, none of the constituents in the Uranium Material
would be indicative of RCRA listed hazardous waste, even if the Uranium Material were not
already exempt from RCRA as source material.
5. RCRA Characteristics
Three Uranium Material samples collected during the 2010 operational period were analyzed for
RCRA TCLP including Organochlorine Pesticides, Chlorinated Herbicides, SVOCs, VOCs,
Inorganics, Metals, and Mercury (Tables 2 and 3) as well as the RCRA characteristics
corrosivity, ignitibility, and reactivity. In addition, four samples from 2009 were analyzed for
TCLP metals (Table 3).
These test results demonstrate that the Uranium Material is not ignitable, corrosive, or reactive
per the RCRA definitions of these characteristics. No organic or inorganic contaminant
exceeded its respective TCLP threshold for RCRA toxicity characteristic as defined in Table 1 of
40 CFR Part 261.24(b) (Table 3) with the exception of trichloroethene. The laboratory results
indicate that this constituent was detected at a concentration of 2.7 ~g/L in WTPS-1 and 1.5 ~
gIL in WTPS-2 but not in WTPS-3. However, trichloroethene was also detected in the leachate
method blank at 3.3 ug/L which was above the MOL, but below the adjusted RL of 5 ~g/L.
Though detected, these laboratory QA results indicate that the compound is not likely present in
either of the samples. Regardless, the results are two orders of magnitude below the regulatory
action level of 0.5 mg/L (500 IJg/L) for trichloroethylene and, therefore, this constituent does not
exhibit RCRA characteristic concentrations.
Therefore, the test results indicate that that the Uranium Material does not have the RCRA
characteristic of toxicity. The Affidavit from the Midnite Mine Site Supervisor (Attachment 1)
affirms that the Uranium Material has never been classified for shipment or off-site management
as a RCRA characteristic waste. This is consistent with the source of the constituents and the
treatment process used to develop the OMC Uranium Material. The historic solids testing data
from 2001 to 2009 (Table 2) and the historic water quality data for the same period (Table 1)
show relatively consistent results in the constituents and concentrations in the plant feed water.
As discussed in the introduction to this report, the Uranium Material is exempt from regulation
under RCRA; however, even if it were classified as a characteristic hazardous waste, alternate
feed materials are permitted to contain RCRA characteristic wastes under NRC's Alternate
Feed Guidance (10 CFR 40, Appendix A).
Based on all of the above information, the OMC WTP Uranium Material is not a RCRA
characteristic hazardous waste.
6. Conclusions and Recommendations
In summary, the following conclusions can be drawn from the RCRA analysis of the Site
information presented above:
[ It) TETRA TECH
1. The Uranium Material is not a RCRA listed hazardous waste because it has a natural
uranium content of greater than 0.05 weight percent, is therefore source material and, as
a result, is exempt from regulation under RCRA.
2. Even if the Uranium Material were not source material, it would not be a RCRA listed
hazardous waste for the following additional reasons:
a) It was generated from a known process under the control of the generator, who has
provided an Affidavit declaring that the Uranium Material is not and does not contain
RCRA listed hazardous waste. This determination is consistent with Boxes 1 and 2
and Decision Diamonds 1 and 2 in the Denison/UDEQ Protocol Diagram;
b) The five volatile organic compounds detected at very low concentrations in the
Uranium Material have been attributed to laboratory contamination and are not actual
contaminants in the DMC uranium Material;
c) None of the metals in the Uranium Material samples came from RCRA listed
hazardous waste sources. This determination is consistent with Box 8 and Decision
Diamonds 9 through 11 in the Denison/UDEQ Protocol Diagram.
3. The Uranium Material does not exhibit any of the RCRA characteristics of ignitability,
corrosivity, reactivity, or toxicity for any constituent.
[ it) TETRA TECH
7. References
Midnite Mine Superfund Site. Spokane Indian Reservation Washington Record of Decision
(ROD), EPA Region 10, September 2006.
Title 10 Code of Federal Regulations; Chapter I -Nuclear Regulatory Commission, Part 40 -
Domestic Licensing of Source Material: 40.4 -Definitions (10 CFR 40.4)
Title 10 Code of Federal Regulations; Appendix A -Nuclear Regulatory Commission, Part 40 -
Domestic Licensing of Source Material: Criteria Relating to the Operation of Uranium Mills and
the Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source
Material From Ores Processed Primarily for Their Source Material Content (10 CFR 40
Appendix A)
Title 40 Code of Federal Regulations; Protection of the Environment, Part 261 -Identification
and Listing of Hazardous Waste: Subpart A, 261.4 -Exclusions: Subpart B -Criteria for
Identifying the Characteristics of Hazardous Waste and for Listing Hazardous Waste.
[ It;) TETRA TECH
Table 1. Historic Water Qual ity of DMC WTP Influent
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
Location ID Collection Date J,lg/L u9/L ~lg/L J,lg/L J,1g/L J,1g/L J,1g/L J,1g/L J,1g/L S.U. mg/L .pCill pCrl1
SW-39 (PIT-3) 2/25/1998 43 I __ 280 --86000 -3500 -4.41 --2 U 22 -22 --, SW-39 4/29/1998 46 -250 -85000 --3400 -4.26 -18 -18 -
SW-39 7/22/1998 49 --260 --90000 --3500 -4.09 --
SW-39 10/14/1998 61900 -20 U 46 -1000 U 7 B 89700 -1810 -23688.2 -3660 --4.45 -5 U 67.2 -67.2 --
SW-39 10/27/1998 48 --260 --95000 -3700 -4.4 -
SW-39 11/15/1 998 60500 -5 B 43 --1000 U 4 B 96400 --1790 -24632.7 -3600 -4.41 -5 U
SW-39 12/10/1998 58600 -5 B 37 --1000 U 5 --81000 --1650 -18140.9 -3000 B 4.56 -14 B 45.6 -45.6 -
SW-39 1/25/1999 46 --230 -85000 -3500 -4.64 -
SW-39 4/15/1999 34 --230 --70000 -3000 -4.76 -
SW-39 4/21/1999 49900 --10 U 26 --210 -2 U 62200 -20 U 12084.0 -2500 -4.13 -5 U 23 -23 -
SW-39 5/17/1999 50300 -5 B 34 --269 -2 B 69200 -1310 --18021.0 -3000 -4.44 -5 U 24 -24 -
SW-39 6/15/1999 56200 -7 -33.3 --160 -3.7 -82900 -1480 -17751 .1 -3270 -4.26 -5 U 29 -29 -
SW-39 7/27/1999 43 --230 -85000 -3400 -4.05 -
SW-39 10/6/1999 49 -250 -95000 -1100 --4.45 -
SW-39 12/12/1999 46800 -8 B 51 .8 --228 -5.9 --79300 -1430 -18545.7 -3210 --4.38 -5 U 30 --30 -
SW-39 1/27/2000 69 -200 --130000 -5700 --3.91 -
SW-39 2/4/2000 92300 -100 U 70 B 200 B 20 U 120000 -2430 -2051.0 -5480 -4.04 -12 B 36 --36 -
SW-39 4/7/2000 20100 -1 B 25.6 -181 -3.1 --32200 -640 -11334.3 -1410 --4.32 -8 B 31 -31 -
SW-39 4/17/2000 29 --240 -46000 -1900 -4.37 -3 U
SW-39 5/12/2000 44200 -1 B 49.5 -258 -6.2 -62600 -1180 -10614.7 -2500 -4.35 -5 U 42 --42 -
SW-39 6/7/2000 51000 -7 B 56.1 --313 -8.9 -70500 -1370 -2960 -4.1 --5 U 45 --45 -
SW-39 7/13/2000 68600 -6 B 58 --225 -9 -95800 -1940 -4220 --3.94 -5 U 57 -57 -
SW-39 7/20/2000 46 -300 -85000 -3600 --3.85 -3 U
SW-39 8/15/2000 97200 -10 B 82 -199 --10 -129000 -2620 --5720 ~-3.9 -5 U 83 -83 -
SW-39 9/14/2000 105000 --3 U 64 -190 -15.1 -146000 -2800 --6160 -4.06 -6 B 70 -70 --
SW-39 10/25/2000 63 -230 -140000 --5700 -4.12 -3 U
SW-39 10/30/2000 98900 -5 U 81 -165 -7 -146000 -2910 -6620 -4.34 -5 U 70 -70 -
SW-39 1/17/2001 54 -200 -120000 -5000 -4.65 -3 U
SW-39 1/27/2001 76500 -5 U 57 -149 -8 -121000 -2310 -4670 -4.51 -8 B 54 --54 -
SW-39 4/6/2001 83 --770 -120000 -5100 -4.52 -3 U 82 -82 -
SW-39 4/26/2001 61900 -3 U 71 -522 -7 -84200 -1700 -3690 -4.32 -5 U
SW-39 7/5/2001 I 71 630 110000 4600 4.08 3 --------
SW-39 10/4/2001 69600 -10 U 80 --560 --10 -118000 --2090 --24000.0 -4400 --4.33 -5 -48 -48 -
SW-39 2/7/2002 14900 --1 U 16 -95 --2 -31300 -658 --8850.0 -1360 -. 4.49 --32 .6 -32.6 -
SW-39 4/17/2002 12800 --10 U 20 -80 -10 U 30200 -550 -7430.0 -1130 -4.91 --10 U 20 .6 --20.6 -
SW-39 7/11/2002 24000 -10 U 20 -180 --10 U 53400 --810 -11300.0 -1680 --4.4 --5 U 38.7 -38.7 -
SW-39 10/9/2002 36500 -10 U 40 --300 --10 U 62200 --1110 -14800.0 --2310 --4.49 -0.05 U 53.9 -53.9 -
SW-39 1/15/2003 34800 --10 U 40 -290 --10 U 57400 -1050 -12100.0 -2220 -4.49 --8 -40 .8 -40 .8 -
SW-39 4/24/2003 36500 -10 U 30 -260 -10 U 48600 -1100 -12000.0 --2390 -4.62 --5 U 40 .3 --40.3 --
( ii:) TETRA TECH
Table 1. Historic Water Quality of D MCWTP Influent C ontinue d
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
Location 10 Collection Date J.19/L J.19/L J.19/L J.19/L ug/L ug/L LLg/L ug/L ug/L S.U. mg/L pCi/1 pCi/1
SW-39 (PIT-3) 7/15/2003 44800 -10 U 40 -280 -10 U 68400 -1260 --14400.0 -2660 -4.26 -5 U 30.1 --30.1 -
SW-39 10/23/2003 42400 -10 -50 --260 -10 U 66800 -1270 -15900.0 -2680 --4.5 -5 U 21 .6 --21 .6 -
SW-39 1/14/2004 53400 10 U 50 280 10 U 76700 1440 16400.0 3110 4.58 5 U 30 30 ..
SW-39 4/23/2004 40300 10 U 50 180 10 U 55300 1080 12100.0 2520 4.5 J:: U 37.5 37.5 ...,
SW-39 7/16/2004 49500 10 U 50 230 10 78400 1310 19100.0 2810 4.24 5 U 33.3 33.3
SW-39 10/13/2004 58700 10 60 230 10 U 80000 1550 17600.0 3350 4.5 5 U 22.8 22.8
SW-39 4/22/2005 35700 10 U 40 140 10 U 60900 1070 12400.0 2350 4.71 21 .3 21 .3
SW-39 7/14/2005 45900 10 U 40 150 10 U 76300 1230 16900.0 2700 4.41 5 U 24 24 .
SW-39 10/11/2005 46000 10 U 50 150 10 U 83000 1430 15800.0 2960 4.68 25.6 25.6
SW-39 4/20/2006 32300 10 U 30 150 10 U 43900 910 10200.0 1910 4.56 5 U 23.7 23.7
SW-39 7/13/2006 60300 10 U 30 180 10 U 49600 1180 11200.0 2400 4.23 5 U 31 .7 31 .7
SW-39 10/11 /2006 ~ 40300 10 U 40 170 10 U 60800 1220 13100.0 2570 4.6 5 U 33.9 33.9
SW-39 4/19/2007 I 39500 10 U 33.8 137 10 U 56000 1080 12700.0 2950 4.56 10 U 20.5 20.5
SW-39 7/11/2007 47200 10 U 40.9 150 10 U 67700 1210 15400.0 2570 4.39 5 U 29.6 29.6
SW-39 10/4/2007 42700 10 U 48.2 159 10 U 64200 1340 14200.0 2980 4.52 5 U 28.3 28.3
SW-39 4/25/2008 37100 10 U 27.5 161 10 U 47400 1220 9770.0 2480 4.74 1 U 18.9 18.9
SW-39 7/22/2008 40700 10 U 44.8 162 10 U 49700 1420 12500.0 2750 4.31 4 27 27
SW-39 10/2/2008 45400 6.65 39.5 139 73100 1600 14400.0 2870 4.26 5 U 19 19
SW-39 4/27/2009 31400 <10 28.9 118 <10 45000 865 9160.0 1850 4.66 1
SW-39 7/10/2009 46200 <10 29.9 132 <10 76000 1170 14200.0 2430 4.4 3 34
SW-39 10/6/2009 36300 <10 40.2 133 <10 58500 1250 15400.0 2620 4.37 2 32
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
SW-39 (Pit 3) 119/L J.19/L J.19/L J.19/L ug/L ug/L ug/L Ilg/L J.lg/L S.U. mg/L pCi/1 pCi/1
Count (n) 45 42 60 60 41 60 45 38 60 60 48 43 45
Max 105,000 100 83 I 1,000 20 146,000 ! 2,910 24,633 6,620 5 14 83 83
Min 12,800 1 16 80 2 30,200 20 21 051 1,100 4 0 18 18
Avg 49,891 10 46 271 9 79,147 1,397 14,215 3,223 4 5 37 37
Std Dev 20~343 15 16 207 3 28,429 575 4,539 1,243 0 3 17 17
2 x Std Dev 40,685 29 32 414 7 56,859 1,149 9,078 2,486 0 5 34 34
[ It:) TETRA TECH
T bl a e 1. Historic Water Quality of DMC WTP Influent Continued
Ra-226 Ra-226
Collection Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
Location ID Date Ilg/L Ilg/L Ilg/L Ilg/L J,lg/L Ilg/L Ilg/L Jlg/L Ilg/L S.U. mg/L pCi/1 pCi/1
SW-40 (PIT -4) 1/15/1998 5 U 6 -1100 --10 --6.22 -3 U 1.9 --1.9 --
SW-40 4/29/1998 4 U 10 --880 -7 -7.78 3 -3 --
SW-40 7/22/1998 4 U 5 U 370 -2 U 6.79 -
SW-40 10/14/1998 80 B 10 U 2 U 10 U 2 U 262 -10 U 3280.0 -20 U 7.54 -5 U 1.78 -1.78 -
SW-40 10/27/1998 4 U 5 U 490 -6 -7.57 --
SW-40 11/15/1998 90 B 2 U 1 U 5 U 1 U 518 -10 U 3520.0 -10 B 7.1 -5 U 2.06 -2.06 -
SW-40 12/10/1998 120 B 2 U 0.4 U 10 B 0.4 U 505 -10 U 3810.0 -20 U 7.02 -5 U 3.23 -3.23 -
SW-40 1/14/1999 9 --4 U 630 -13 -6.81 -
SW-40 1/14/1999 120 B 2 U 0.4 U 2 U 0.4 U 574 --10 B 3820.0 -26 -6.85 -5 U 5.52 -5.52 -
SW-40 2/20/1999 210 -5 U 1 U 7 B 1 U 663 -20 B 3070.0 --30 B 6.92 -5 U 8.76 -8.76 -
SW-40 4/15/1999 3 U 5 -940 -29 -6.61 -
SW-40 4/21/1999 500 -2 U 0.4 U 3 B 0.4 U 649 -660 -1370.0 -60 B 7 -5 U 7.6 -7.6 ~
SW-40 5/17/1999 90 B 2 U 0.4 U 3 B 0.4 U 764 -30 B 2420.0 -20 -7.43 -5 U 5.1 -5.1 -
SW-40 6/15/1999 120 B 1 B 0.2 B 2 B 0.2 U 747 -30 B 2830.0 -26 -6.99 -5 U 3.7 -3.7 -
SW-40 7/27/1999 4 U 6 -1000 -31 -6.79 -
SW-40 10/6/1999 4 U 4 U 460 -10 -7.16 -1 1 -1.1 -
SW-40 1/27/2000 4 U 4 U 860 -22 -6.74 -9.7 -9.7 -
SW-40 4/17/2000 4 U 9 -1000 -29 --6.04 -5 -8.6 -8.6 -
SW-40 7/20/2000 3 U 6 -300 -3 -7.07 -3 U 1.6 -1.6 -
SW-40 10/25/2000 4 U 11 -290 -2 U 6.72 -3 U 2.8 -2.8 -
SW-40 1/1712001 4 U 40 -660 -2 U 5.36 -3 U 4.5 -4.5 -
SW-40 I 4/6/2001 4 U 5 -660 -16 --7.35 -3 U 4.3 -4.3 -
SW-40 7/5/2001 4 U 4 U 370 --2 U 6.96 -3 U 2.9 -2.9 -
SW-40 10/4/2001 100 U 10 U 10 U 10 U 10 U 710 -10 U 6000.0 -10 U 6.86 -10 U 4.1 -4.1 -
SW-40 2/7/2002 1 U 1 U 1 U 6 -1 U 1610 -55 -4770.0 -62 -6.47 -10 U 29.6 -29.6 -
SW-40 4/17/2002 100 -10 U 10 U 10 U 10 U 1640 -60 -2430.0 -90 -5.82 -10 U 21.1 -21.1 -
SW-40 7/11/2002 100 U 10 U 10 U 10 U 10 U 1250 --40 -3830.0 -50 -6.51 --5 U 4.2 -4.2 -
SW-40 10/9/2002 10 U 10 U 10 U 10 U 10 U 1040 --30 --5500.0 -40 -7.28 -5 U 3.3 -3.3 --
SW-40 1/15/2003 600 --10 U 10 U 10 U 10 U 2190 --70 -5600.0 -110 -6.63 -5 U 27.8 -27.8 -
SW-40 4/24/2003 10 U 10 U 10 U 10 U 10 U 1280 --60 -3510.0 -60 -7.26 -5 U 8.6 -8.6 -
SW-40 7/15/2003 10 U 10 U 10 U 10 U 10 U 940 --30 -3430.0 -20 --7.66 -5 U 4.1 -4.1 -
SW-40 10/23/2003 10 U 10 U 10 U 10 U 10 U 490 -20 -4030.0 --20 --7.43 -5 U 2.3 -2.3 -
SW-40 1/14/2004 200 10 U 10 U 10 U 10 U 930 20 4740.0 20 6.83 5 U 2.8 2.8
SW-40 4/23/2004 100 U 10 U 10 U 10 U 10 U 880 30 4050.0 50 7.32 5 U 9.2 9.2
SW-40 7/16/2004 200 10 U 10 U 10 U 30 280 10 3720.0 60 7.19 5 U 1.7 1.7
SW-40 10/13/2004 100 U 10 U 10 U 10 U 10 U 150 10 U 4260.0 10 U 7 5 U 1.5 1.5
SW-40 4/22/2005 300 10 U 10 U 10 U 10 U 530 20 4880.0 30 6.74 6.4 6.4
SW-40 7/14/2005 2400 10 U 10 U 10 U 10 U 260 10 U 4520.0 410 7.57 5 U 2.3 2.3
SW-40 10/11/2005 100 10 U 10 U 10 U 10 U 210 10 U 5460.0 10 U 6.65 1.5 1.5 :
SW-40 4/20/2006 100 U 10 U 10 U 10 U 10 U 1360 60 1280.0 80 6.72 5 U 12.1 12.1
( It] TETRA TECH
T bl 1 H· . W a e Istorlc ater Q r f DMC WTP I fl t C f d ualty 0 n uen on mue
Ra-226 Ra-226
Collection Aluminum Arsenic Cadmium Copper I Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
Location ID Date J.L9/L J.L9/L J.Lg!L j.lg/L I J,1g/L J,1g/L J,1g/L J,1g/L J,1g/L S.U. mg/L pC ill pCi/1
SW-40 (PIT-4) 7/13/2006 100 U 10 U 10 U 10 U 10 U 1370 40 2060.0 40 6.98 5 U 5.9 5.9
SW-40 10/11/2006 100 U 10 U 10 U 10 U 10 U 500 20 3060.0 30 7.64 5 U 1.8 1.8
SW-40 1/25/2007 100 10 U 10 U 10 U 10 U 600 20 3380.0 40 7.69 5 U 8 8
SW-40 4/19/2007 100 U 10 U 10 U 10 U 10 U 821 26.1 2660.0 31.6 7.7 10 U 5 5
SW-40 7/11/2007 100 U 10 U 10 U 10 U 10 U 445 14.4 2410.0 13 7.14 5 U 1.9 1.9
SW-40 10/4/2007 100 U 10 U 10 U 10 U 10 U 128 10 U 2960.0 10.9 7.1 5 U 0.9 0.9
SW-40 4/25/2008 100 U 10 U 10 U 10 U 10 U 767 29.8 2200.0 36.9 8.36 5 U 7.3 7.3
SW-40 7/22/2008 17.4 10 U 10 U 10 U 10 U 201 10 U 1930.0 10 U 7.01 2 1.3 1.3
SW-40 10/2/2008 10 U 1.18 1 U 1 U 90.5 2.25 3420.0 10 U 8.45 5 U 0.57 0.57
SW-40 4/27/2009 <100 <10 <10 <10 <10 606 34.2 2150.0 43 6.90 <1
SW-40 7/10/2009 <100 <10 <10 <10 <10 177 <10 2310.0 <10 7.48 2 2.2
SW-40 10/6/2009 <100 <10 <10 <10 <10 116 <10 3100.0 <10 6.92 1 1.2
Summary
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
SW-40 (Pit 4) J,1g/L J,1g/L J,1g/L J,1g/L J,1g/L J,1g/L J,1g/L J,1g/L ll9lL S.U. mg/L pC ill pCi/1
Count (n) 34 I 34 49 49 33 52 35 37 50 52 40 I 44 46
I Max 2L400
,
10 10 40 30 2,190 660 6,000 410 8 10 30 30
Min 1 1 0 1 0 91 2 1,280 2 5 2 1 1
Ayg 191 8 6 8 8 697 44 3A53 36 7 5 6 6
Std Dey 410 4 4 5 6 438 109 1! 185 59 1 2 6 6
2 x Std Dey 820 7 8 11 11 877 217 2,369 118 1 4 13 12
Ra-226 Ra-226
Aluminum Arsenic Cadmium Copper Lead Manganese Nickel Uranium Zinc pH TSS (diss) (total)
J,1g/L Jl9/L Jl9/L Jl9/L J.L9/L Jl9/L J.L9/L j.1g/L Jl91L S.U. mg/L pC ill pCi/1
COMBINED
Count (n) 79 76 109 109 74 I 112 80 75 110 112 88 87 91
Max 105,000 100 83 1,000 30 I 146,000 2,910 24,633 6,620 8 14 83 83
Min 1 1 0 1 0 91 2 1,280 2 4 0 1 1
Ayg 28,501 9 28 153 8 42,724 805 8,906 1,774 6 5 21 21
Std Dey 29,100 11 23 202 5 44,432 803 6J 350 1,838 1 2 20 20
2 x Std Dey 58,200 22 46 403 9 88,864 1,607 12,700 3,677 3 5 40 40
[ It:] TETRA TECH
Table 2. U ----Material Metals Analvsis for RCRA Ch - - -
t ...
,
Sample Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver
10 Sample Date mg/L mg/L mg/L mg/L mg/L mg/L mg/L 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 <01 <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 <0.5 <10 <0.25 <0.5 <0.5 <0.02 0.2 <0.5
40 CFR Part 261.24 5 100 1 5 5 0.2 1 5
PASS? Yes Yes Yes Yes Yes Yes Yrs Yes
[ Ii:] TETRA TECH
Table 3. Uranium Material Organics and Pesticides Analyses for RCRA Toxicity Characteristics
(TCLP)
;.. Results
Maximum I Target Analyte Units TCLP WTPS-l WTPS-2 WTPS-3
Or&.anochlorine Pesticides -Method SW8081A -TCLP Leachate
Gamma-BHC (Lindane) mg/L 0.4 <0.0001 <0.0001 <0.0001
See Next
Heptachlor mg/L Row <0.00015 <0.00015 <0.00015
Heptachlor Epoxide mg/L 0.008 <0.000079 <0.000079 <0.000079
Gamma-Chlordane mg/L 0.03 <0.000078 <0.000078 <0.000078 -Alpha-Chlordane mg/L 0.03 <0.00009 <0.00009 <0.00009
Endrin mg/L 0.02 <0.000096 <0.000096 <0.000096
Methoxychlor mg/L 10.0 <0.00039 <0.00039 <0.00039
Toxaphene mg/L 0.5 <0.0051 <0.0051 <0.0051
Chlordane mg/L 0.03 <0.0011 <0.0011 <0.0011
Chlorinated Herbicides -Method SW81S1A -TCLP Leachate
2,4-D ~g/L 10.0 <1.6 <1.6 <1.6 -
Silvex j.lg/L 1.0 <0.12 <0.12 <0.12
GC/MS Semivolatiles -Method SW8270D -TCLP Leachate
Pyridine mg/L 5.0 <0.02 <0.02 <0.02
l,4-Dichlorobenzene mgfL 7.5 <0.02 <0.02 <0.02
2-Methylphenol (0 Cresol) mg/L 200 <0.02 <0.02 <0.02
3+4-Methylphenol (m+p Cresol) mg/L 200 <0.02 <0.02 <0.02
Hexachloroethane mgfL 3.0 <0.02 <0.02 <0.02
Nitrobenzene mg/L 2.0 <0.02 <0.02 <0.02
Hexachlorobutadiene mg/L 0.5 <0.02 <0.02 <0.02
2,4,6-Trich lorophenol mg/L 2.0 <0.02 <0.02 <0.02
2,4,5-Trich lorophenol mg/L 400 <0.02 <0.02 <0.02
2,4-Dinitrotoluene mg/L 0.13 <0.02 <0.02 <0.02
Hexachlorobenzene mgfL 0.13 <0.02.. <0.02 <0.02
Pentachlorophenol mg/L 100 <0.043 <0.043 <0.043
GC/MS Volatiles -Method SW8260 2SB -Leachate
Vinyl Chloride .Ilg/L 0.2 <0.83 <0.83 <0.83
1,1-Dichloroethene* ug/L 0.7 <0.83 <0.83 <0.83
2-Butanone (Methyl Ethyl Keytone) Ug/L 200 <8.3 <8.3 <8.3
Chloroform JJ,g/L 6.0 <0.83 <0.83 <0.83
Carbon Tetrachloride JJ,g/L 0.5 <0.83 <0.83 <0.83
l,2-Dichloroethane Ug/L 0.5 <0.83 <0.83 <0.83
Benzene JJ,g/L 0.5 <0.83 <0.83 <0.83
Trichloroethene* JJ,g/L 0.5 2.7 B,J 1.5 B,J <0.83
Tetrachloroethene* ~g/L 0.7 <0.83 <0.83 <0.83
Chlorobenzene .Ilg/L 100
,
<0.83 <0.83 <0.83 I
Inorganics -Method SW 846_7.3.1 (Cyanide) & _7.3.2 (Sulfide),
SW904SC (pH)
Reactive Cyanide mg/k-& N/A <0.1 <0.1 <0.1
Reactive Su Lflde mg/kg N/A <50 <50 <50
Solid pH in Water @ 25'C pH N/A 9.09 9.19 9.26
Ignitablllty -Method SW1010A
Ignitability -95'C 'c N/A U U U
[ It ) TETRA TECH
T bl 4 U a e ramum M t " IA a ena na vses f RCRA L" t d H or IS e azar d ous W t as e
Laboratory Results .~lculaf,d
Target Analyte II) Units WTP5-1 WTP5-2 WTP5-3 AVerClge
Total Uranium -Method SW6020A
Total Uranium mg/kg 15,000 16,000 15,000 15,333
TotallCP Metals -Method SW6010B
Arsenic mg/kg <5.9 <5.9 <5.7 <5.8
Barium mg/kg 8,100 7,900 7,200 7,733
Beryllium mg/kg 33 36 36 35
Cadmium mg/kg 40 44 43 42
Calcium mg/kg 15,000 16,000 16,000 15,667
Chromium mg/kg 19 20 19 19
Cobalt mg/kg 1,200 1,200 1,100 1,167
Copper mg/kg 160 180 170 170
Iron mg/kg 690 740 740 723
Lead mg/kg 18 19 17 18
Manganese mg/~g 110,000 110,000 96,000 105,333
Molybdenum mg/kg <5.8 <6.0 <5.7 <5.8
Nickel mg/kg 1,700 1,800 1,800 1.767
Selenium mg/kg 25 26 26 26
Silver mg/kg 11 12 11 11
Thallium mg/kg <580 <600 <570 <583
Tin mg/kg <29 <30 <29 <29
Vanadium mg/kg <5.8 <6.0 <5.7 <5.8
Zinc mg/kg 3,400 3,600 3,600 3,533
Total Mercury -Method SW7471A
Total Mercury mg/k,g <0 .19 <0 .2 <0.19 <0.19
GC/MS Total Volatile Organics -Method SW8260
Chloromethane l1g/kg <1.1 <1.2 <1.1 <1.1
Acetone l1gfkg 22 B 29 B 33 B 28
MethyJene Chloride Ilg/kg 3.8 J,B 3.7 J,B 5.8J,B 4.4
2-Butanone l1g/kg <5.7 <5.9 <5.7 <5.8
Tetra hyd rofu ra n Ilg/kg <7.2 <7.4 <7.2 <7.3
Chloroform tLg/kg 1.7J 2 J 1.2 J 1.6
Carbon Tetrachloride Ilg/kg <1.3 <1.4 <1.3 <1.3
Benzene JIg/kg <0.94 <0.96 <0.93 <0.94
Toluene llg/kg 2.2 J,B 1.9 J,B 1.3 J,B 1.8
m,p-Xylene llg/kg <1.9 <1.9 <1.9 <1.9
o-Xylene l1gfkg <0.95 <0.97 <0.94 <0.95
Naphthalene Ilg/kg <1.4 <1.4 <1.4 <1.4
11) All values as reported by ALS Laboratory as dry weight values
[ It) TETRA TECH
Tab e 4. u f ramum Material Analyses or R CR A Listed Hazardous Waste Cont'd
Laboratory Results Calculated
Target Analyte Unlts,11 WTP5-1 WTPS-2 I WTP5-3 Average
GC/MS Total Semi-Volatile Organics -Method SW8270D
Pyridine !!g/kg <310 <320 <320 <317
1,4-dichlorobenzene !!g/kg <310 <320 <320 <317
2-methylphenol !!g/kg <310 <320 <320 <317
3+4-methylphenol .l!g/kg <310 <320 <320 <317
Hexachloroethane }tg/kg <310 <320 <320 <317
Nitrobenzene ~g/kg <310 <320 <320 <317
Hexachlorobutadiene }tg/kg <310 <320 <320 <317
2,4,6-trichlorophenol ~g/kg <310 <320 <320 <317
2"4,5-trichlorophenol llg/kg <310 <320 <320 <317
2,4-dinitrotoluene llg/kg <310 <320 <320 <317
Hexachlorobenzene llg/kg <310 <320 <320 <317
Pentachlorophenol llg/kg <490 <500 <500 <497
Gasoline Range Organics -Method SW8015B
Gasoline Range Organics mg/kg <0.38 <0.35 <0.39 <0.37
Diesel Range Organics -Method SW8015MB
Diesel Range Organics . mg/kg <6.5 <6.6 <6.8 <6.6
Oil & Grease I
Oil & Grease mg/kg <120 <120 <120 <120
Inorganics
Ammonia as N -Method EPA350.1 mg/kg 7.9 7.9 8.3 8.0
Nitrate/Nitrite as N -Method EPA353.2
Revision 2 mg/kg 3.1 3.2 3.1 3.1
Total Dissolved Solids -EPA160.1 mg/kg 26,000 26,000 27,000 26333.3
Fluoride -Method EPA300.0 Revision 2.1 mg/kg 38 38 40 38.7
Chloride -Method EPA300.0 Revision 2.1 mg/kg 40 39 41 40
Sulfate -Method EPA300.0 Revision 2.1 mg/kg 17,000 17,000 17,000 17,000
Gross Alpha/Beta -GFPC
Gross Alpha pCi/g 4,310±690 4,830±770 5,440±870 4,860
Gross Beta pCi/g 4,870±780 4,780±760 4,860±780 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±1O 4l±11 36.6±9.4 39.1
Total Radium (duplicate sample) pCi/g 35.8±9.2
I$otopic Thorium -Alpha Spectroscopy
Th-228 pCi/g 1.24±0.99 1.50±0.74 0.93±0.67 1.22
Th-230 pCi/g 20.4±3.8 21.4±3.9 20.4±3.7 20.7
Th-232 pCi/g 1. 14±0.48 0.66±O.34 0.71±0.32 0.84
11) All values as reported by Al5 Laboratory as dry weight values
Appendix L
MSDS Sheet for Regeneration Product
v 0 v", <0 'J "4..< IJ '....... r _ • _ ." ~ -. ..-... ••
Issue Date : June 30. 1998
Revision Date: Not Applicable
MATERIAL SAFETY DATA SHEET
" ~. )!~~:"', _.,:V ':~~:: .. ~~: "'!0." ",'~' ''''' .. ''\:' .;,/~ 'i.~ DlfI -, ,~.; -.'" ,,-,,~ -d ':'ANlt . sE:~ . ::,<:',; jC.~,:~ ~"_ v" '." SECTJONl~·PRP ... CT.IDENm'lP .. fI'I N,.. ,.1) , -~_ :l'.\.s~-; ,~" :.-~ ...... ;~~'_~'r .. ~.lo ... _ .; ... ......,' t;i:.·' ," .... ~.. ..' ___ -... ". r _.r. .-... __ '"" i
Product Name: Regeneration Product I Product Code: UN 2912
Manufacturer: C~ Corporation P.O. Bmt 1539 Bliod River, Ontario POR lBO
Emergeoc)'PhoneNo: [phone] (Cameco Security)
Contact: Manager, Blind River Opcntims
Product Usc: Rcgmer.dion product is produced from refining uranium ore c:onccntratcs to unWUIIl trioxide. Modified organic
degradation products form when tributyl phosphate and moselle solvent mixture contacts IUtric acid at elevated temperatures.
These organic: pl'OChwts arc subsequently reeovcnd in I sodium carbonate solution, which is acidifiM with nitric acid tD form a
waxy organic material, known as rcgeorzation product. Regeneration product contains uranium which can be cconmnically
reeovered at liceoced haDdJ.iDg facilities.
..
Molecular Weight: Not applicable.
NFPA RATING: Health: 2 1 Flammability: 1 I Rl:acti\'ity: 1
Specific Hazards: Radioactive Matcnal (Low Specifu: Activity), COITOsive,~diur
PIN No.: UN 2912
1?~·:,!·;fi'!;~~:'~"~~::-9·:~'~·;>';:--;:}~')-X .• ~'.~:::~,:~" t' :'{';~sif~:~:" "':"::·'Wm':~J.;:: .~.: ,;::' . :":': h .' ',:"
... ':' . " !~~r)!~~~!'!;!"y,t!:.~.~;~~:.:;~~~~;,~;~;..:r::::~~"~";i~:~ ;~~<" .. Y CnON'!' .. ~~ G ..' :~.. 'L:t~ .... ;, : ... 1 :~~:~:;~¢,!!$?~t~".~·:"..;~t~:.;.~::;~c;~~:':.:;.-:~~;*; ... :~,::!"~r·~)~·;'l::#+~!'~" r<-".;; ... ,;: .... ' ..... :.~!~.Q ..... ~:~.::::; .. ,::_.:·4 r .. _ .... ~: .,.: . .:~;;.:~~. j': , .. -•
Ingredient Quantity CASNwnbets Exposure Limits
Major Compoocnts:
Uranium (radiologil;a1 type F) 5-30% AECB FFOL22S-S 2.5 X lO~ Bq ALI
Nitric Acid (HN03) 35% strength 7697-37-2 ACGrn: TLV-1WA: 2 ppm lINO,
Kcroseoe (Norpar 13 or CI2-CI4) <10-1. 64771-72-8
Tributyl Phosphate (TBP) <3% 126.73-8 Acorn TWA: 0.2 ppm or 2.2 m'{/ml TBP
Dibutyl Phosphate (DBP) 20-70010 107-66-4 ACGnI TWA: 1 ppm; STEL: 2 ppm DBP
Monobulyl Phospbate (MBP) 0.1-1%
But)'ric Acid (CH,(CHJ:zCOOH) 20-50-1. 107-92-6
Propionic Acid (CH]C~COOH) 5-20% 79-09-4
Acetic Acid (CH3COOH) 2-10% 64-19-7 ACOIH TWA: 10 ppm; 15 ppm CH)COOH
Formic Acid (HeOOH) <5". 64-18·6 ACGllI TWA: 5 ppm; 10 ppm HCOOH
Looser Carbon Chain CarboxylU; <5% AU-AnDual Limit ofIntab
Acids from Kerosene Dearadation TL V-Threshold Limit V due:
1W A-Time Weighed Average concentratIon
Nitrated and Nitro Organics (similar to <5% of II r.bcmial in air fot an 8 hour work day
carboxylic acids) or 40 hour work \\Uk.
STEL-Sbort Tcnn Exposure Limit
~$~i)'1-;?~t;:~:::'i.: .. ;1~1"{':~1(.#.':C!': •• .,.,.-:: .. :~"!:r :..~~"::.:~ ... ):~,:' ::~:..;.~\.:~ :_'h"';"_~:~"'~':';)~,. '~~.~-.:}:. .. .:w;_f: ... :r ."-; .••• , •••••••••• -..... -...... -, " .~.n.'~.M ...... , < -.... ,<.~ ' ... ···>'·'SE~Nm"~ll¥SIC~D~'J'A ............. "1 • :~~j~f:E~~?~:.;:;:~~~~~~~t~~~:~~·:~~::~~~~~!~~:"::t;·4::'; ~:.~ _:' ... !~ ",_ ;~:-: IQ:" , .. :-.. ~': +'~ •• !.~ :; .. ~.,~ '.<:':~::' .... :':,
Physical State: Gas -Liqu.id: .x Solid: X
Page 1 of 4
U l::t.l U ~ / \1 0 " LV v (} •• J '" 1."'1......lr,. 0 V .J J 'J 'J 'J .... .,
Appearance and Odour. Regeneration product Vules from a light yellow-brown coloured waxy solid to a dark brown senti-liqUid
. materi8I with the consistency of molasses. A liquid phase may be present, which contain nitric acid or residual TBP and. kerosene
solvent. The material will have the rancid odour from propionic acid.
Vapour Pressure (rmn Hg): 13.7 at 20 ae (TBP) Density (gIan] at 2S 0C): Range from 0.76 to 1.06 f!ic;m3
11.4 at 20 Q C (acetic acid) for kerosene llDd dibutyl phosphate respect1Yely. The
10 11 4 ° C (propioaic acid) other major regeneration product compoucots have
0.43 at -7 a C (butyric acid) densities within this range.
<1 at 20°C (kcroseue, OBP)
4S at 20c e (20.40% strength nitru; acid)
FrcezingIMelting Point (ac): 16°C (acetic acid) Solubility in WatJ:z (20De): Componeots ofregcnerated
-4 c C (kc:roseoe) product arc WlItc:r soluble to a varying extent
-S.soC (butyric ac:id)
Boiling Point (DC): Ruges from USDC aDd 225°C for acetic acid pH: less than pH 1 due to residual HNO] in regeneration
and Iccroseae n:spec;tively. The other regeoeratioo product product
compouods have boiling poiD1s within this tcmpc:r1ltuR nnge.
Relative Vapour Density (Air=1): Raogcs from 2.1 for acctH: acid to 7.2 fordibutyl phosphate aad 9.2 furtributyl phosphate.
~+l~m:r~~U7l~.~a~~~~;f,~~:Sf£no~{rY.F·:FIRE?AmJ~mIJoSIQN~1iDilAT.ii:',::::,::".c~:~.~'" ;
~f;~~:_:~~~~~:.~~~~g~4<~)i!\j~~~~; .. o:· . .i~ .. : .:" ~ I 6;;~\'-=:~_"~:.4'" ~~ .. ,.'.~ .• ':\..: ... :,:~ -•. -.. ;..-: ~-'·~a ~ •• :'~~' .. : ... , ..... ::.+ ._;.'~ ~·:·.i:':~ "; -.
Flammable: XYcs_ No
If)'1:5, under wbat conditims: R.egeneratiOQ produa has a low flammability hazard. F1ashpoim depends OIl composition of the
product, but nmgcs from 120 to 140QC. Volatile componcDts may have flash points at lower tempcratur'cs.
Extinpishing Media: If the product is in coabIct with fue, use wiler spray to cool exposed surfaces aod to protect personnel.
Isolate the fuel supply from the fire. Use foam Of' dry chemical or carom dioxide to extinguish the fi~. Avoid spraying water
directly into the storage vessels to avoid over flowing the container. Heat generated from the fire will produce combustible
vapours. The liquid or vapour will c:ollect in low lying areas. travel some distance along the ground to an ignition source.
Flash Point (0C) and Method: 39°C (acetic: acid); 54DC (propiooic acid); 7rC (butyric acid); 83 Q C (kerosene), 157°C (OBP),
160°C (TBP) by the Pcasky-Martens Closed Cup ASTM D.93 and 0-92. Flash point fm-rejalCtBtion product is 120 to 140°C.
Explosion Data: Regcoeration product may ignicc when exposed to heat or with direct flame contact.
Special Procedures: Not applicable.
Sensitivity to MeclJaniW Impact: Not applicable.
Sensitivity to Static Di5chargc: Rcgeucntioa product may ignite when exposed to a static discharge. I
·~~).·~~;m· ~t«~~·, . ,~; ·';.~';;~··~~:j :;!;;r ~ .. ;, .~:'": .. ; ... ; ~:i( ~ .. : ,.:'.: , .. ~;, .~.~:.,.,,:,;. :.; K '. ' .. :. :'" .... , ~ # ... . . ..... . . ; ~ .. .
, .~. <' •. *,,'~'~."-.; "',··v.;,· .•• ,·,,, ~, ~S.Ett O~~ ·'~GTIVrI'f.·DA:TA: ';~~"~';' '''".L; .. ··:G .. ')r ... ~:j:-;': .. ·,.·\·~ --••• , .... ~.<' .' '. .... , .. ' " ~ . . ... . ., L:~~.{·~.:~~",~~~,,~'~.<:~·it~;~;~~:":''':'~:~1~::~';J2'·~~.·, ....... , .. ,.... ... ~!.~ ~.: ~ ! ..... ::.~:.~~-_ .... ~_ .•••. '-: .;~ •. "" .. : .
Stable X Yes -No
If NO, UDder wbid1 amditioos7 .
Hazardous Polymerization will occur?: -Yes XNo
Decomposition Products: Regeneration product is a ~ of organics (alkanes, phosphAte esters, carboxylic acids, nitrated
organic). Decomposition products of RNO,. Ditratc and nitro orpnics arc carbon dioxide (CO:z,), clIIbon monoxide (CO) and
oxide.! ofDib'Ogen (NO, NO:z,) which are toxic. The phosphate esteIs will decompose to phosphorous o"idcs (eg. P~OIO)'
Incompatibility with other substances: X Yes_ No
If yes, wbich ones: Strong Oxidizing chemicals (ie. hydrogen peroxide) will rea&:t with the organics. Alkaline solutions will react
J with the I'Csidual RNO, in t.bc regeneration product, generating beat from neutralization of the: residual acid.
Page 2 of 4
Appendix M
TIle Table for Molycorp Amendment Request
--... --- ---~ ---Total Threshold Limit Concentration (TTl_l Analysis on Dry-Weight Basis
Unoxldlzed Lead\lron Residue
Table 1
Investigallon of PrtX:>ess Ponds, MolycolJl, 100 .• folovember 6, 1995
----~ .. r='
I
t-J
C'
= =
:s:: o =
= 00
Col.
~
= :z o CJ :x-
I:"'""
I:"'"" :x-=-
--3
t:r'l
I:"'""
-..J
~
U1
-..J
-..J
~
-..J -. c;ro.
-0
=
c;ro.
Appendix N
MSDS for CaFz Product
SENT BY:Xerox Telecopier 7020 : 5-11-93 9:41AM
co: Don Sparling, Plant Manager
Energy Fuels
6425 south Highway 163
Blanding, UT 84511
Muril Vincelette, V.P. operations
Enargy Fuels NuclQar r Inc.
ons Tabor center, Suite 2500
1200 Seventeenth Str&at
Denver, co 80202
E. W. Shortride, OperationB Mgr.
UMETCO
P. O. BOX 1029
Grand Junction, CO 81502
32-l 303 595 0930:# 6
DMC0000126
SENT BY:Xerox Telecopier 7020 ; 5-11-93 9:42AM 32-; 303 595 0930:# 7
ALLIED ASSAYS OF MATERIAL TO PRESENT "TOLL MILL"
LOT NUMBER % U
1 1. 71g
2 1. 773
3 1. 860
4 1.791
5 1. 874
6 1. 770
7 1. 970
8 1. 855
9 1. 739
10 2.126
11 1.946
12 2.230
13 1. 895
14 1.670
15 1. 713
16 1. 723
17 1.653
18 2.112
19 1.653
20 1.969
21 2.160
22 1. 759
AVG. % U = 1. 862
DMC0000127
SENT BY:Xerox Telecopier 7020
1'~./~' DKS ....... .'
GFR V
PIr.
11l-111/ [J!2/Let2 ,
,4:; 0.0;.5
ED.. 0.2
eel O. OJ I
Cr ;(.2D
1'~ ;./0
H, <~.O()Oi!
: /)7 (). :J Z
5 ... -<~,~~J
:.
• •. i _ •• ~~_._
: 5-11-93 : 9:45AM : 32~ 303 595 0930:#14
~ h. . ~ trrV 7-~r ~~ aMJLa~~~
s tel.
s. C>
/00
/. ()
5. 0
5.0
O. Z
5,0
/,0
/GD5
DMC0000134
Appendix 0
2012 Annual Tailings Characterization Data
Celli
Ch emlca I d R d' I I Ch an a 10 ogles t . f arac ens ICS
Constituent 1987 2003 2007 2008 2009 I 2010 2011 2012 2012 (Avg) (Avg) I
~ ~I >= = (resample*l
Major Ions (111l!!l)
Carbonate <5 <1 ND ND <1 <1 <1 <1 NS
Bicarbonate <5 NA ND ND <1 <1 <1 <1 NS
Calcium 630 307 483.8 604 635 711 577 426 NS
Chloride 8000 6728 37340 9830 20700 7440 33800 78000 NS
Fluoride <100 3005 31.72 0.3 0.4 28.4 69.2 62.9 NS
Magnesium 7900 5988 21220 6550 16200 5410 14300 16000 NS
Nitrogen-Ammonia 7800 3353 10628 5250 15200 8120 12900 9750 NS
Nitrogen-Nitrate <100 41.8 269.4 64.9 142 58 212 556 NS
Potassium NA 647 5698 1880 4140 1840 4510 9750 NS
Sodium 10000 8638 62600 13200 39000 16700 29500 41700 NS
Sulfate 190000 63667 287600 118000 232000 107000 182000 158000 NS
pH (s.u.) 0.70 1.88 0.80 1.53 1.15 2.73 2.23 1.9 NS
TDS 120000 94700 357400 131000 140000 130000 216000 342000 NS
Conductivity (umhos/cm) NA NA NA NA 365000 110000 112000 136000 NS
~etals (ug/l) ,
Arsenic 440000 121267 849000 271000 436000 74400 299000 25500 NS
Beryllium 780 475 2262 500 410 338 1270 3180 NS
Cadmium 6600 3990 29320 8790 9120 2940 13700 30700 NS
Chromium 13000 6365 29940 6760 18700 5620 22700 12100 NS
Cobalt 120000 NA 88240 23500 97500 16200 56000 53100 NS
Coooer 740000 196667 881000 360000 168000 125000 483000 885000 NS
Iron 3400000 2820000 13480000 3280000 2390000 3400000 8940000 840000 NS
Lead <20000 3393 27420 11200 10600 9240 23600 17000 NS
Manganese 140000 162500 990200 206000 723000 173000 735000 1560000 NS
Mercurv NA NA ND ND 7.61 7.2 61.4 117 NS
I Molybdenum 240000 50550 415600 106000 142000 35300 235000 434000 NS
Nickel 370000 36950 40860 32000 156000 27500 43700 15000 NS
Selenium <20000 1862 15420 13000 14800 5220 11600 8090 NS
Silver <5000 NA 1559.2 449 558 155 1110 4310 NS
Thallium 45000 NA 407.8 165 387 193 560 13 NS
Tin <5000 NA 6512 1240 2290 263 1500 <100 NS
Uranium 105000 134517 788600 416000 578000 159000 838000 1450000 NS
Vanadium 280000 348000 2208200 1200000 773000 752000 2500000 1940000 NS
Zinc 1300000 NA 642940 476000 229000 171000 398000 811000 NS
Radiologies (pCi/I)
Gross Alpha NA 169333 29380 21900 16500 11300 3610 12600 NS
VOCS (uWl)
Acetone 35 NA 66.5 110 710 260 80 310 NS
Benzene <5 NA ND ND <1 <1 <1 <1 NS
Carbon tetrachloride <5 NA ND ND <1 <1 <1 <1 NS
Chloroform 8 NA 6.7 6.6 16 4.9 13 19 NS
Chloromethane NA NA ND 9.4 11 4.4 3.6 4.0 NS
MEK NA NA ND ND 120 65 <1 200 NS
Methylene Chloride 11 NA ND ND 2.0 <1 <1 2 NS
Naphthalene <10000 NA <10 ND 1.1 5.4 2 3 NS
Tetrahydrofuran NA NA 150 <20 <100 <10 <500 2.9 NS
Toluene <5 NA ND ND <1 <1 <1 <1 NS
Xylenes <5 NA ND ND <1 <1 <1 <1 NS
SVOCS (uiLL) 1 'r
---1.2.4-Trichlorobenzene NA NA NA NA <50 <10 <10 <33.3 <10
1.2-Dichlorobenzene NA NA NA NA <50 <10 <10 <33.3 <10
1 ,3 -Dichlorobenzene NA NA NA NA <50 <10 <10 <33.3 <10
l.4-Dichlorobenzene NA NA NA NA <50 <10 <10 <33.3 <10
1-Methylnaphthalene NA NA I NA NA <50 <10 <10 <33.3 <10
2,4,5-Trichlorophenol NA NA I NA NA <50 <10 <10 <33.3 <10
2,4,6-Trichlorophenol NA NA NA NA <50 <10 <10 <33.3 <10
2,4-Dichlorophenol NA NA NA NA <50 <10 <10 <33.3 <10
2,4-Dimethylphenol NA NA NA NA <50 <10 <10 <33.3 <10
2,4-Dinitroghenol NA NA NA NA <250 <20 <20 <67.7 <20
2,4-Dinitrotoluene NA NA NA NA <50 <10 <10 <33.3 <10
CellI
Ch emlca an ·8 100gIca d R d· I I Ch aractenstIcs
Constituent 1987 2003 2007 2008 2009 2010 2011 2012 2012 (Avg) (Avg) II (resample*)
Major Ions (mWI) I
2,6-Dinitrotoluene NA NA NA NA <50 <10 <10 <33.3 <10
2-Chloronaphthalene NA NA NA NA <50 <10 <10 <33.3 <10
2-Chlorophenol NA NA NA NA <50 <10 <10 <33.3 <10
2-Methylnaphthalene NA NA NA NA <50 <10 <10 <33.3 <10
2-Methvlphenol NA NA NA NA <50 <10 <10 <33.3 <10
2-Nitrophenol NA NA NA NA <50 <10 <10 <33.3 <10
3&4-Methylphenol NA NA NA NA <22 <10 <10 <33.3 <10
3,3 '-Dichlorobenzidine NA NA NA NA <100 <10 <10 <33.3 <10
4,6-Dinitro-2-methvlphenol NA NA NA NA <250 <10 <10 <33.3 <10
4-Bromophentl phenyl ether NA NA NA NA <50 <10 <10 <33.3 <10
4-Chloro-3-methylphenol NA NA NA NA <50 <10 <10 <33.3 <10
4-Chlorophenyl phenyl ether NA NA NA NA <50 <10 <10 <33.3 <10
4-Nitrophenol NA NA NA NA <250 <10 <10 <33.3 <10
Acenaphthene NA NA NA NA <50 <10 <10 <33.3 <10
Acenaphthylene NA NA NA NA <50 <10 <10 <33.3 <10
Anthracene NA NA NA NA <50 <10 <10 <33.3 <10
Azobenzene NA NA NA NA <50 <10 <10 <33.3 <10
Benz(a)anthracene NA NA NA NA <50 <10 <10 <33.3 <10
Benzidine NA NA NA NA <100 <10 <10 <33.3 <10
Benzo(a)ovrene NA NA NA NA <50 <10 <10 <33.3 <10
Benzo(b)f1uoranthene NA NA NA NA <50 <10 <10 <33.3 <10
Benzo(g,h,i)perylene NA NA NA NA <50 <10 <10 <33.3 <10
Bonz.o(k)JJuoTlllIlhcnc NA NA NA NA <50 <10 <10 <33.3 <10
B i s(2-chl oroethox y ) methane NA NA NA NA <50 <10 <10 <33.3 <10
Bis(2-chloroethyl) ether NA NA NA NA <50 <10 <10 <33.3 <10
Bis(2-chloroisopropyl) ether NA NA I NA NA <50 <10 <10 <33.3 <10
Bis(2-ethvlhexvl) phthalate NA NA r NA NA <50 27 <10 37.7 <10
Butyl benzyl phthalate NA NA , NA NA <50 <10 <10 <33.3 <10
Chrysene NA NA NA NA <50 <10 <10 <33.3 <10
Dibenz(a,h)anthracene NA NA NA NA <50 <10 <10 <33.3 <10
Diethvl ohthalate NA NA NA NA 170 <10 <10 <33.3 <10
Dimethyl phthalate NA NA NA NA <50 <10 <10 <33.3 <10
Di-n-butyl phthalate NA NA NA NA <50 <10 <10 <33.3 <10
Di-n-octyl phthalate NA NA NA NA <50 <10 <10 <33.3 <10
Fluoranthene NA NA NA NA <50 <10 <10 <33.3 <10
Fluorene NA NA NA NA <50 <10 <10 <33.3 <10
Hexachlorobenzene NA NA NA NA <50 <10 <10 <33.3 <10
Hexachlorobutadiene NA NA NA NA <50 <10 <10 <33.3 <10
Hexachlorocyclopentadiene NA NA NA NA <50 <10 <10 <33.3 <10
Hexachloroethane NA NA NA NA <50 <10 <10 <33.3 <10
Indeno(l,2,3-cd)pyrene NA NA NA NA <50 <10 <10 <33 .3 <10
Isophorone NA NA NA NA <50 <10 <10 <33.3 <10
Naphthalene NA NA NA NA <50 <10 <10 <33.3 <10
Nitrobenzene NA NA NA NA <50 <10 <10 <33.3 <10
N -Ni trosodimeth ylamine NA NA NA NA <50 <10 <10 <33.3 <10
N-Nitrosodi-n-propylamine NA NA NA NA <50 <10 <10 <33.3 <10
N -Ni trosodipheny lamine NA NA NA NA <50 <10 <10 <33.3 <10
Pentachlorophenol NA NA NA NA <250 <10 <10 <33.3 <10
Phenanthrene NA NA NA NA <50 <10 <10 <33.3 <10
Phenol NA NA NA NA <50 <10 <10 <33.3 <10
Pyrene NA NA NA NA <50 <10 <10 <33.3 <10
Pyridine NA NA NA NA <50 <10 <10 <33.3 <10
I Historic values reported for Gross Alpha from 1987 and 2003 are total gross alpha reported in pCilL. All other gross alpha data are reported as
Gross Alpha minus Rn & U.
CeJl3
Ch emlca an a 10 og 'lea d n d' I I Ch t '1' arac ens ICS
2003 2007 =
Constituent 1987 (Avgt (Avg) 2008 2009 2010 2011 2012
I Ma.ior Ions (mdI) -
Carbonate NA <1 ND ND <1 <1 <1 <I
Bicarbonate <5 NA ND ND <1 <1 <1 <1
Calcium 300 418 887 478 628 560 200 591
Chloride NA 2460 15965 15400 17200 3470 40400 8880
Fluoride <100 667 42,8 1.4 0.6 54.8 64.1 2300
Magnesium 5400 3386 15767 13100 17100 2500 22100 5680
Nitrogen-Ammonia 13900 1302 13867 9010 21600 2650 6470 6840
Nitrogen-Nitrate <100 20 102 44 142 26 261 64
Potassium NA 254 6657 4760 3820 782 2590 1190
Sodium 5900 3198 25583 22900 28600 5620 47900 6660
Sulfate 180000 33400 173667 167000 214000 40400 197000 80000
pH (s.u.) 0,82 2.28 1.60 1.79 1.4 2.18 1.27 2.4
TDS 189000 51633 228500 193000 I 243000 56200 296000 120000
Conductivitv (umhos/cm) NA NA NA NA 304000 59800 86400 80300
Metals (ugll) -
Arsenic 163000 32867 256500 489000 ND 52900 263000 4340
Beryllium 540 430 913 840 905 206 1570 678
Cadmium 2600 1958 9260 15400 ND 1960 12200 3460
Chromium 12000 3742 14883 12800 ND 3360 22800 10900
Cobalt 48000 NA 82783 57000 ND 13000 76000 76100
Copper 360000 87333 505000 345000 ND 89000 768000 379000
Iron 2100000 1278333 4874500 4400000 5970000 1460000 1.02E+7 3400000
Lead <20000 2507 9647 16900 ND 17200 16700 1860
Manganese 82000 144000 496833 313000 ND 101000 587000 3110000
Mercury ND NA ND 16 ND <4 30.9 9,6
Molybdenum 52000 I 12250 122167 209000 14 21300 96200 790
Nickel 170000 20917 131833 241000 ND 23800 75_800 150000
Selenium <2000 910 5856 10200 ND 3080 6900 2460 -
Silver <2500 NA 305 1010 ND 101 792 1850
Thallium 4700 NA 446 1200 ND 190 518 1080
Tin NA NA 1090 1070 ND 155 325 <100
Uranium 118000 67833 332333 636000 3690 180000 458000 835000
Vanadium 210000 158333 935000 1130000 ND 692000 2370000 836000
Zinc 590000 NA 748833 515000 ND 134000 726000 652000
Radiologies (pCiII) I
Gross Alpha NA 1015831 16533 21700 17000 4030 11100 1530
I VOCSluWI.) ,
Acetone 28 NA 80 100 67 37 330 64
Benzene <5 NA ND ND <1 <1 <1 <1
Carbon tetrachloride <5 NA ND ND <1 <1 <1 <1
Chloroform 6 NA ND II 4,2 2.6 31 2
Chloromethane NA NA ND ND 1.4 1.8 3.5 1
MEK NA NA ND ND <1 <1 67 <20
Methylene Chloride 10 NA ND ND <1 <1 7.4 <1
Na{Jhthalene <10000 NA ND <10 <1 2.1 1.2 <1
Tetrah ydrofuran NA NA 150 <20 <100 <10 <10 <1
Toluene <5 NA ND ND <1 <1 <I <1
Xylenes <5 NA ND ND <1 <1 <1 <1
SY~CS (ugIL) I ~ ~-
1.2.4-Trichlorobenzene NA NA NA NA <11 <10 <10 <10
1.2-Dichlorobenzene NA NA NA NA <11 <10 <10 <10
1,3-Dichlorobenzene NA NA NA NA <11 <10 <10 <10
l.4-Dichlorobenzene NA NA NA NA <11 <10 <10 <10
I-Methyl naphthalene NA NA NA NA <11 <10 <10 <10
2.4,5-Trich1orophenol NA NA NA NA <11 <10 <10 <10
2.4.6-Trichlorophenol NA NA NA NA <11 <10 <10 <10
2.4-DichloroQhenol NA NA NA NA <11 <10 <10 <10
2.4-Dimethylphenol NA NA NA NA <11 <10 <10 <10
2.4-Dinitrophenol NA NA NA NA <53 <20 <20 <20
2.4-Dinitrotoluene NA NA NA NA <11 <10 <10 <10
2.6-Dinitrotoluene NA NA NA NA <11 <10 <10 <10
Cell 3
Ch emlca an a to og lea d R d· 1 j Ch t . f arac ens ICS
2003 2007 I Constituent 1987 (Av~) (AvId 2008 2009 2010 2011 2012
I
Ma.ior Ions (mWI1 j
2-Chloronaphthalene NA NA NA NA <11 <10 <10 <10
2-Chlorophenol NA NA NA NA <11 <10 <10 <10
2-Methvlnaphthalene NA NA NA NA <11 <10 <10 <10
2-Methylphenol NA NA NA NA <11 <10 <10 <10
2-Nitrophenol NA NA NA NA <11 <10 <10 <10
3&4-Methvlphenol NA NA NA NA <11 <10 <10 <10
3.3'-Dichlorobenzidine NA NA NA NA <21 <]0 <10 <10
4,6-Dinitro-2-methylphenol NA NA NA NA <53 <10 <10 <10
4-Bromophenvl phenvl ether NA NA NA NA <11 <10 <10 <10
4-Chloro-3-methylphenol NA NA NA NA <11 <10 <10 <10
4-ChloroIJhenyl phenyl ether NA NA NA NA <11 <10 <10 <10
4-Nitrophenol NA NA NA NA <5 3 <10 <10 <10
Acenaphthene NA NA NA NA <11 <10 <10 <10
Acenaohthylene NA NA NA NA <11 <10 <10 <10
Anthracene NA NA NA NA <11 <10 <10 <10
Azobenzene NA NA , NA NA <11 <10 <10 <10
Benz(a )anthracene NA NA NA NA <11 <10 <10 <10
Benzidine NA NA NA NA <21 <10 <10 <10
Benzo(a)pyrene NA NA NA NA <11 <10 <10 <10
1~\)nul(b)HuoraUlhcJlc NA NA NA NA <11 <10 <10 <10
BenzoCg.h,i)perylene NA NA NA NA <11 <10 <10 <10
Benzo(k)tluoranthene NA NA NA NA <11 <10 <10 <10
Bis(2-chloroethoxy)methane NA NA NA NA <11 <10 <10 <10
Bis(2-chloroethyl) ether NA NA NA NA <11 <10 <10 <10
Bis(2-chloroisopropyl) ether NA NA NA NA <11 <10 <10 <10
Bis(2-ethvlhexyl) phthalate NA NA NA NA <11 10.6 <10 <10
Butyl benzyl phthalate NA NA NA NA <11 <10 <10 <10
Chrysene NA NA NA NA <11 <10 <10 <10
Dibenz(a,h)anthracene NA NA NA NA <11 <10 <10 <10
Dicth yl Jlh[lltllmc NA NA NA NA <11 <10 <10 <10
Dimethvl phthalate NA NA NA NA <11 <10 <10 <10
Di-n-butyl phthalate NA NA NA NA <11 <10 <10 <10
Di-n-octyl phthalate NA NA NA NA <11 <10 <10 <10
Fluoranthene NA NA NA NA <11 <10 <10 <10
Fluorene NA NA NA NA <11 <10 <10 <10
Hexachlorobenzene NA NA NA NA <11 <10 <10 <10
Hexachlorobutadiene NA NA NA NA <11 <10 <10 <10
Hexachlorocyciopentadiene NA NA NA NA <11 <10 <10 <10
Hexachloroethane NA NA NA NA <11 <10 <10 <10
Indeno( 1 ,2.3-cd)pyrene NA NA NA NA <11 <10 <10 <10
Isophorone NA NA NA NA <11 <10 <10 <10
Naphthalene NA NA NA NA <11 <10 <10 <10
Nitrobenzene NA NA NA NA <11 <10 <10 <10
N -Ni trosodimeth ylamine NA NA NA NA <11 <10 <10 <10
N-Nitrosodi-n-propvlamine NA NA NA NA <11 <10 <10 <10
N-Nitrosodiphenylamine NA NA NA NA <11 <10 <10 <10
Pentachlorophenol NA NA NA NA <53 <10 <10 <10
Phenanthrene NA NA NA NA <11 <10 <10 <10
Phenol NA NA NA NA <11 <10 <10 <10
Pyrene NA NA NA NA <11 <10 <10 <10
Pyridine NA NA NA NA <11 <10 <10 <10
Historic values reported for Gross Alpha from 1987 and 2003 are total gross alpha reported in pCi/L. All other gross alpha data are
reported as Gross Alpha minus Rn & U.
Cel14A
eIDlca an a o oglca Ch I dRill I 1 Ch aracterIstics
Constituent 2009 2010 2011 I "'2012
Major Ions (mWIt,... II
Carbonate <1 <1 <1 <1
Bicarbonate <1 <1 <1 <1
Calcium 627 598 558 591
Chloride 4650 7350 5870 4980
Fluoride 0.3 21.6 30.6 43
Magnesium 3250 4940 4720 2230 I
Nitrogen-Ammonia 3140 5230 4930 1540
Nitrogen-Nitrate 28 52 44 27
Potassium 980 1440 1450 558
Sodium 5980 11300 11400 7130
Sulfate 67600 87100 267000 64900
pH (s.u.) 1.40 1.99 1.73 1.2
TDS 81400 107000 108000 76000
Conductivity (umhos/cm) 131000 101000 82100 78100
Metals (U2/1)
Arsenic 626000 109000 86600 60500
Beryllium 296 215 323 167
Cadmium 1920 3670 2190 844
Chromium 3220 7500 5900 5990
Cobalt 9440 26500 22500 22900
Copper 99200 168000 181000 433000
Iron 2360000 2920000 3390000 3190000
Lead 5360 11800 11000 5270
Manganese 178000 209000 131000 112000
Mercurv 1.19 <4 15.2 2.4
Molybdenum 24300 43800 24200 58200
Nickel 17100 40900 43500 41300
Selenium 4620 5810 4460 1310
Silver 78 193 216 127
Thallium 162 350 410 250
Tin 257 378 319 169
Uranium 118000 217000 153000 91000
Vanadium 918000 1090000 730000 237000
Zinc 142000 224000 286000 200000
Radiolo2ics (pCi/I)
Gross Alpha 8910 3400 8290 16300
VOCS(uWL) --
Acetone 60 55 100 25
Benzene <1 <1 <1 <1
Carbon tetrachloride <1 <1 <1 <1
Chloroform 4.0 8.5 10 <1
Chloromethane 3.4 5.5 7.9 <1
MEK <1 <1 <1 <1
Methylene Chloride <1 <1 <1 <20
Naphthalene 1.8 <1 <1 <1
Tetrah'ydrofuran <100 <10 <10 1.36
Toluene <1 <1 <1 <1
Xylenes <1 <1 <1 <1
SVOCS (ueIL)
1,2,4-Trichlorobenzene , <11 <10 <10 <10
1.2-Dichlorobenzene <11 <10 <10 <10
1,3-Dichlorobenzene <11 <10 <10 <10
l,4-Dichlorobenzene <11 <10 <10 <10
1-Methylnaphthalene <11 <10 <10 <10
2,4,5-Trichlorophenol <11 <10 <10 <10
2,4,6-Trichlorophenol <11 <10 <10 <10
2,4-Dichlorophenol <11 <10 <10 <10
2,4-Dimethylphenol <11 <10 <10 <10
Cell4A
Ch emlca an d R d· I I Ch a JO 02lca aracterIstIcs
Constituent 2009 2010 2011 2012
Maior Ions (DI2II)
2A-Dinitrophenol <53 <20 <20 <20
2,4-Dinitrotoluene <11 <10 <10 <10
2.6-Dinitrotoluene <11 <10 <10 <10
2-Chloronaphthalene <11 <10 <10 <10
2-Chlorophenol <11 <10 <10 <10
2-Methylnaphthalene <11 <10 <10 <10
2-Methylphenol <11 <10 <10 <10
2-Nitrophenol <11 <10 <10 <10
3&4-Methylphenol <11 <10 <10 <10
3.3'-Dichlorobenzidine <21 <10 <10 <10
4,6-Dinitro-2-methylphenol <53 <10 <10 <10
4-Bromophenyl phenyl ether <11 <10 <10 <10
4-Chloro-3-rllctll1'lnhenol <11 <10 <10 <10
4-Chlorophenyl phenyl ether <11 <10 <10 <10
4-Nitrophenol <53 <10 <10 <10
Acenaphthene <11 <10 <10 <10
Acenaphthylene <11 <10 , <]0 <10
Anthracene <II <10 <10 <10
Azobenzene <11 <10 <10 <10
Benz( a)anthracene <11 <10 <10 <10
Benzidine <21 <10 <10 <10
Benzo(a)pyrene <11 <10 <10 <10
Benzo(b )fluoranthene <11 <10 <10 <10
BCIJ20(/.!.ll,.i)pcn,ltmc <11 <10 <10 <10
Benzo(k)fluoranthene <11 <10 <10 <10
Bis(2-chloroethoxy)methane <11 <10 <10 <10
Bis(2-chloroethyl) ether <11 <10 <10 <10
Bis(2-chloroisopropyl) ether <11 I <10 <10 <10
Bis(2-ethylhexyl) phthalate <11 19.6 <10 <10
Butyl benzyl phthalate <11 <10 <10 <10
Chrvsene <11 <10 <10 <10
Dibenz(a,h)anthracene <11 <10 <10 <10
Diethyl phthalate <11 <10 <10 <10
Dimethyl phthalate <11 <10 <10 <10
Di-n-butyl phthalate <11 <10 <10 <10
Di-n-octyl phthalate <11 <10 <10 <10
Fluoranthene <11 <10 <10 <10
Fluorene <11 <10 <10 <10
Hexachlorobenzene <11 <10 <10 <10
Hexachlorobutadiene <11 <10 <10 <10
Hexachlorocyc!opentadiene <11 <10 <10 <10
Hexachloroethane <11 <10 <10 <10
Indeno(1,2,3-cd)pyrene <11 <10 <10 <10
Isophorone <11 <10 <10 <10
Naphthalene <11 <10 <10 <10
Nitrobenzene <11 <10 <10 <10
N-Nitrosodimethylamine <11 <10 <10 <10
N-Nitrosodi-n-propylamine <11 <10 <10 <10
N-Nitrosodiphenylamine <11 <10 <10 <10
Pentachlorophenol <53 <10 <10 <10
Phenanthrene <11 <10 <10 <10
Phenol <11 <10 <10 <10
Pyrene <11 <10 <10 <10
Pyridine <11 <10 <10 <10
Ce1l4B
Ch I emIca an d R d" I I Ch a lO og lea t "f arac ens ICS
Constituent 2011 2012
Major Ions (mgII)
Carbonate <1 <1
Bicarbonate <1 <1
Calcium 570 580
Chloride 8290 8170
Fluoride 26.7 23.3
Magnesium 3910 4500
Nitrogen-Ammonia 5220 5580
Nitrogen-Nitrate 39 42
Potassium 1370 1650
Sodium 9050 11700
Sulfate 134000 119000
pH (s.u.) 1.87 1.5
TDS 98000 128000
Conductivity (umhos/cm) 76900 86900
Metals (ug/l)
Arsenic 67400 80000
Beryllium 311 356
Cadmium 1990 2540
Chromium 6860 8280
Cobalt 17800 29300
Copper 193000 340000
Iron 2960000 3580000
Lead 9960 11600
Manganese 128000 148000
Mercury 13.7 2.6
Molvbdenum 21400 27600
Nickel 33900 50500
Selenium 4670 4470
Silver 137 169
Thallium 237 368
Tin 196 215
Uranium 133000 171000
Vanadium 660000 783000
Zinc 191000 270000
Radiologies (pCiIl)
Gross Alpha 8590 13600
VOCS (ug/L)
Acetone 130 94
Benzene <1 <1
Carbon tetrachloride <1 <1
Chloroform 9.4 4
Chloromethane 8.5 8
MEK <1 <1
Methylene Chloride <1 <1
Naphthalene <1 <1
Tetrahydrofuran <10 Il.l I Toluene <1 <1
Xylenes <1 <1
I SVOCS (ug/L) ,
1,2.4-Trichlorobenzene <10 <10
1.2-Dichlorobenzene <10 <10
1,3-Dichlorobenzene <10 <10 ,
1.4-Dichlorobenzene <10 <10
I-Methvlnaphthalene <10 <10
2.4,5-Trichlorophenol <10 <10
2.4.6-Trichlorophenol <10 <10
2,4-Dichlorol'henol <10 <10
2.4-Dimethvlphenol <10 <10
2.4-Dinitrophenol <20 <20
Ce1l4B
Ch I eDllca an 10 o,g ca d Rad' I I Ch t . f arac ens ICS
Constituent 2011 2012
Major Ions (mWI)
2,4-Dinitrotoluene <10 <10
2,6-Dinitrotoluene <10 <10
2-Chloronaphthalene <10 <10
2-Chlorophenol <10 <10
2-Methylnaphthalene <10 <10
2-Methvlphenol <10 <10
2-Nitrophenol <10 <10
3&4-Meth~ll2henol <10 <10
3,3 '-Dichlorobenzidine <10 <10
4,6-Dinitro-2-methylphenol <10 <10
4-Bromophenyl phenyl ether <10 <10
4-Chloro-3-methYlphenol <10 <10
4-Chlorophenyl phenyl ether <10 <10
4-Nitrophenol <10 <10
Acenaphthene <10 <10
Acenaphthylene <10 <10
Anthracene <10 <10
Azobenzene <10 <10 I
Benz(a)anthracene <10 <10
Benzidine <10 <10
Benzo( a)pyrene <10 <10
Benzo(b )fluoranthene <10 <10
Benzo(g,h,i)perylene <10 <10
Benzo(k)fluoranthene <10 <10
Bis(2-chloroethoxy)methane <10 <10
Bis(2-chloroethyl) ether <10 <10
Bis(2-chloroisopropyl) ether <10 <10
Bis(2-ethvlhexvl) phthalate 410 19
Butyl benzyl phthalate <10 <10
Chrvsene <10 <10
DibenzI a,h)anthracene <10 <10
Diethyl phthalate <10 <10
Dimethyl phthalate <10 <10
Di-n-butvl phthalate <10 <10
Di-n-octvl phthalate <10 <10
Fluoranthene <10 <10
Fluorene <10 <10
Hexachlorobenzene <10 <10
Hexachlorobutadiene <10 <10
Hexachlorocvclopentadiene <10 <10
Hexachloroethane <10 <10
Indeno( 1.2.3-cd)pyrene <10 <10
Isophorone <10 <10
Naphthalene <10 <10
Nitrobenzene <10 <10
N-Nitrosodimethylamine <10 <10
N-Nitrosodi-n-propylamine <10 <10
N-Nitrosodiphenylamine <10 <10
Pentachlorophenol <10 <10
Phenanthrene <10 <10
Phenol <10 <10
Pvrene <10 <10
Pyridine <10 <10 ,
Appendix P
GSE Material Performance Information
Appendix Q
Energy Laboratories, Inc. Certifications
Certification
Begin
Parameter Method(s) Date End Date Status
200.8 7/1/2012 6/30/2013 Reciprocal
SM3112B 7/1/2012 6/30/2013 Reciprocal
Mercury 245.1 7/1/20:12 6/30/2013 Reciprocal
Selenium 200.8 7/1/2012 6/30/2013 Reciprocal
Thallium 200.8 7/112012 6/30/2013 Reciprocal
Group:,lnorganlcs • ','
300.0 7/1/2012 6/30/2013 Reciprocal
Fluoride 4500-F C 7/112012 6130/2013 Reciprocal
GrQIJP: 5ynthetlc,'Orgs!'Iic ConWrTIlMnts~Phase II
Carbofuran 531.1 7/1/2012 6/30/2013 Reciprocal
Olbromochloropropane. 504.1 7/1/2012 6/3012013 Reciprocal
Ethylene dibromide 504.1 7/1/2012 6/30/2013 Reciprocal
GrouD~ Svntheflc'Organlc Contaml nants Phase V
DiQual 549.2 7/1/2012 6130f2013 Reciprocal
Glyphosate 547 7/1/2012 6/30/2013 Reciprocal
Oxamyl 531.1 7/1/2012 6/30/2013 Reciprocal
Group: Volatile Organic Contaminants
1 1. 1-TrfChloroelhane 524.2 7/1/2012 6/30/2013 Reciprocal
1, 1. 2-Trichloroethane 524.2 7/1/2012 6/30/2013 Reciprocal
1, 1·DlchloroethYlene 524.2 7/1/2012 6/30/2013 Reciprocal
1. 2, 4-Trich/orobenzene 524.2 7/1/2012 6/30/2013 Reciprocal
1, 2-Dichlorobel)Z.ene 524.2 7/1/2012 6/30/2013 Reciprocal
1. 2-Dichloroethane 524.2 7/1/2012 6/30/2013 Reciprocal
1, 2-Dlchloropropane 524.2 7/1/2012 6/30/2013 Reciorocal
1. 4-Dichlorobenzene 524.2 7/1/2012 6130/2013 Reciprocal
Benzene 524.2 7/1/2012 6/30/2013 Reciprocal
Carbon Telrachloride 524.2 7/1/2012 6/30/2013 Reciprocal
Ohlorobenzene 524.2 7/1/2012 6130/2013 Reciprocal
CIs-1 , 2-dichloroelhylene 524.2 7/1/2012 6/30/2013 RecJprocal
DTchloromethaoe 524.2 7/1/2012 6/30/2013 Reciprocal
Ethylbenzene 524.2 7/1/2012 6/30/2013 Reciprocal
Styrene 524.2 7/1/2012 6/30/2013 Reciprocal
Telractiloroethylene 524.2 7/1/2012 6/30/2013 Reciprocal
Toluene 524.2 7/1/2012 6/30/2013 Reci!:!rocal
Trans-1.2-dichloroethylene 524.2 7/1/2012 6/30/2013 Reciprocal
Trichloroethylene 524.2 7/1/2012 6/30/2013 Reciprocal
Vinyl Chloride 524.2 7/1/2012 6/30/2013 Reciprocal
Xylenes 524.2 7/1/2012 6/30/2013 Reciprocal
GrouplJ~adloCherrilcal·Contim)lffilnts
Gross Alpha EPA 900.0 10111201 1 411212014 Full
Gross Beta EPA 900.0 10/1/2011 4/1212014 Full
Radium-226 EPA 903.0 10/1/2011 4/12/2014 Full
Radium-228 Ra-05 10/1/2011 4112/2014 Full
200.8 7/1/2012 6/30/2013 Reciprocal
Uranium Sm 7500-U C 7/1/2012 6/30/2013 Reciprocal
Radioactive Strontium 90 EPA 905.0 10/1/2011 4112/2014 Full
Tritium EPA 906.0 10/1/2011 4112/2014 Full
Cesium-134 EPA 901.1 10/1/2011 4/12/2014 Full
lodine-131 -EPA 901 .1 10/112011 4112/2014 Full
Gamma Emitters EPA 901.1 10/1/2011 4/1212014 Full
G16u·pfcMlcro.bloIOgl~I_Oori ilm{i1ants .
\ ~ . , ,. . . ..
9223 B Colilerta (Detect) 9/23/2010 9/23/2013 Full
9223 B Colilert QuantiTray~ (Count) 9/23/2010 9/23/2013 Full
Total Coliforms 9221 O"MTF, P-A Broth (Detect) 9/23/2010 9/23/2013 Full
9223 B""o Colilert (Detect) 9/23/2010 9/23/2013 Full
9223 B QUBll\iTrayd'CCount) 9/23/2010 9/23/2013 Full
E. coli 9221 D->F .,e,. (Detect & Count) 9/23/2010 9/23/2013 Full
Heterotrophic Plate Count SimP late" (Count) 9/23/2010 9/23/2013 Full
Fecal CoHforms 9221 O_>EB (Detect) 9/23/2010 9/23/2013 Full
a -Drinking Water -Total Coliform Rule 40 CFR 141.21
b-Source Water -Surface Water Treatment Rule 40 CFR 141.74
c-Ground Water -Ground Water Rule 40 CFR 141.402
d-Source Water· Long Term 2 Enhanced Surface Water Treatment Rule (L T2) 40 CFR 136.3
The expiration date for each parameter is listed in the tables above. -Certification will remain in effect for
the specifie~-period, under the conditions that the laboratory follow the specified methods and that
Water Supply Proficiency Testing CPT) samples are ana1yzed by the 'laboratory for each of the above
listed parameters with acceptable resu1ts at a frequency of once per year. It is the laboratory's
responsibility to request reciprocal certification beyond the scope in the table above.
If you have comments or questions, please contact Marcie Tidd, Region 8 Drinking Water Laboratory
Certification Program Manager, at 303-312-7764.
Sincerely,
9vL~~ vJ~
Judith Wong
Assistant Regional Administrator
Office of Technical & Management Services
State of Utah
Department of Health
Environmental Laboratory Certification Program
Certification is hereby granted to
Energy Laboratories Incorporated -Casper
2393 Salt Creek Highway
Casper, WY 82601
Has conformed with the
2009 TNI Standard
Scope of accreditiation is limited to the
State of Utah Accredited Fields of Accreditiation
Which accompanies this Cerlificate
EPA Number: WY00002
Expiration Date: 6/30/2013
Certificate Number: WY000022012-3
-AJ., J(~ ~n M. Atkinson, Ph.D, HClD
Director, Unified State laboratories: Public Health
!J ~ UTAH DEPARTMENT OF
Continued accredited status depends on successful ongoing particitpation in the program. .,,. HEALTH
EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012·3 Page 2 of \0
Energy Laboratories Incorporated· Casper Start Date Expires AS
Program/Matrix: CWA (Non Potable Water)
Barium 7/1/2012 6/30/2013 FL
Beryllium 7/112012 6/30/2013 FL
Boron 7/112012 6/30/2013 FL
Cadmium 7/112012 6/30/2013 FL
Calcium 7/112012 6/30/2013 FL
Chromium 7/112012 6/30/2013 FL
Cobalt 7/112012 6/30/2013 FL
Copper 7/112012 6/30/2013 FL
Lead 7/112012 6/30/2013 FL
Manganese 7/112012 6/30/2013 FL
Mercury 7/112012 6/30/2013 FL
Molybdenum 7/112012 6/30/2013 FL
Nickel 7/112012 6/30/2013 FL
Potassium 7/112012 6/30/2013 FL
Selenium 7/112012 6/30/2013 FL
Silver 7/112012 6/30/2013 FL
Sodium 7/112012 6/30/2013 FL
Strontium 7/112012 6/30/2013 FL
Thallium 7/112012 6/30/2013 FL
Thorium 7/112012 6/30/2013 FL
Tin 7/112012 6/30/2013 FL
Titanium 7/112012 6/30/2013 FL
Uranium 7/112012 6/30/2013 FL
Vanadium 711/2012 6/30/2013 FL
Zinc 7/112012 6/30/2013 FL
Method EPA 245.1
Mercury 7/1/2012 6/30/2013 FL
Method EPA 245.7
Mercury 7/1/2012 6/30/2013 FL
Method EPA 300.0
Bromide 7/1/2012 6/30/2013 FL
Chloride 7/112012 6/30/2013 FL
Fluoride 7/112012 6/30/2013 FL
Nitrate as N 7/112012 6/30/2013 FL
Nitrate-nitrite 7/112012 6/30/2013 FL
Nitrite as N 7/112012 6/30/2013 FL
Orthophosphate as P 7/112012 6/30/2013 FL
Sulfate 7/112012 6/30/2013 FL
Method EPA 353.2
Nitrate-nitrite 7/1/2012 6130/2013 FL
Method EPA 900
Gross-alpha 7/112012 6/30/2013 FL
Gross-beta 7/112012 6/30/2013 FL
Method EPA 903
Radium-226 7/112012 6/30/2013 FL
Method HACH 8000
Chemical oxygen demand 7/112012 6/30/2013 FL
!J ~ UTAH DEPARTMENT OF
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
www.health.utah.gov/els/labimp/ ~r.HEALTH
EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012·3 Page 3 of I 0
Energy Laboratories Incorporated -Casper Start Date Expires
Program/Matrix: CWA (Non Potable Water)
Method SM 2320 B
Alkalinity as CaC03
Method SM 2340 B
Total hardness as CaC03
Method SM 2510 B
Conductivity
Method SM 2540 C
Residue-filterable (TOS)
Method SM 2540 D
Residue-nonfilterable (TSS)
Method SM 3112 B
Mercury
Method 8M 3114 B
Arsenic
Selenium
Method SM 4500·CI-B
Chloride
Method SM 4500·F-C
Fluoride
Method SM 4500-H+ B
pH
Method SM 4500·NH3 G
Ammonia as N
Method SM 4500·N02-B
Nitrite as N
Method SM 4500·804-E
Sulfate
Method SM 5310 C
Total organic carbon
Method SM 7500·U C
Uranium
!J \t. UTAH DEPARTMENT OF ~r. HEALTH
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/112012 6/30/2013
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/112012 6/30/2013
7/112012 6/30/2013
7/112012 6/30/2013
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/1/2012 6/30/2013
7/112012 6/30/2013
7/1/2012 6/30/2013
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
www.health.utah.90v/els/labimp/
AB
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EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012·3 Page 4 of 10
Energy Laboratories Incorporated -Casper Start Date Expires AS
Program/Matrix: ReRA (Non Potable Water)
Method EPA 1664A
Total recoverable petroleum hydrocarbons (TRPH) 7/1/2012 6/30/2013 FL
Method EPA 1664A (HEM)
Oil & Grease 7/1/2012 6/30/2013 FL
Method EPA 3010A
Preparation/Extraction 7/1/2012 6/30/2013 FL
Method EPA 3510C
Preparation/Extraction 7/1/2012 6/30/2013 FL
Method EPA 5030
Preparation/Extraction 7/1/2012 6/30/2013 FL
Method EPA 6010A
Arsenic 7/1/2012 6/30/2013 FL
Method EPA 6010B
Arsenic 7/1/2012 6/30/2013 FL
Barium 7/112012 6/30/2013 FL
Cadmium 7/112012 6/30/2013 FL
Chromium 7/112012 6/30/2013 FL
Lead 7/112012 6/30/2013 FL
Selenium 7/112012 6/30/2013 FL
Silver 7/112012 6/30/2013 FL
Method EPA 6020
Arsenic 7/1/2012 6/30/2013 FL
Barium 7/112012 6/30/2013 FL
Cadmium 7/112012 6/30/2013 FL
Chromium 7/112012 6/30/2013 FL
Lead 7/1/2012 6/30/2013 FL
Mercury 7/112012 6/30/2013 FL
Selenium 7/112012 6/30/2013 FL
Silica as Si02 7/1/2012 6/30/2013 FL
Silver 7/112012 6/30/2013 FL
Method EPA 7470A
Mercury 7/1/2012 6/30/2013 FL
Method EPA 8015B
Diesel range organics (ORO) 7/1/2012 6/30/2013 FL
Gasoline range organics (GRO) 7/1/2012 6/30/2013 FL
Method EPA 8260B
1,1,1,2-Tetrachloroethane 7/1/2012 6/3012013 FL
1,1,1-Trichloroethane 7/1/2012 6/30/2013 FL
1,1,2,2-Tetrachloroethane 7/1/2012 6/3012013 FL
1,1,2-Trichloroethane 7/1/2012 6/3012013 FL
1 , 1-Dich loroethane 7/1/2012 6/30/2013 FL
1 , 1-Dich loroethylene 7/1/2012 6/30/2013 FL
1 ,1-Dichloropropene 7/1/2012 6/30/2013 FL
1,2,3-Trichlorobenzene 7/1/2012 6/30/2013 FL
1,2,3-Trichloropropane 7/1/2012 6/30/2013 FL
1,2,4-Trichlorobenzene 7/1/2012 6/30/2013 FL
..!J \t. UTAH DEPARTMENT OF
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
~r.-HEALTH WWN.health.utah.gov/els/labimpl
EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012·3 Page 5 of 10
Energy Laboratories Incorporated -Casper Start Date Expires
Program/Matrix: RCRA (Non Potable Water)
1,2,4-Trimethylbenzene 7/1/2012 6/30/2013
1 ,2-Dibromo-3-chloropropane (DBCP) 7/1/2012 6/30/2013
1 ,2-Dibromoethane (EDB, Ethylene dibromide) 7/1/2012 6/30/2013
1 ,2-Dichlorobenzene (o-Dichlorobenzene) 7/1/2012 6/30/2013
1 ,2-Dichloroethane (Ethylene dichloride) 7/1/2012 6/30/2013
1,2-Dichloropropane 7/1/2012 6/30/2013
1,3,5-Trimethylbenzene 7/1/2012 6/30/2013
1,3-Dichlorobenzene 7/1/2012 6/30/2013
1,3-Dichloropropane 7/1/2012 6/30/2013
1,4-Dichlorobenzene 7/1/2012 6/30/2013
1-Chlorohexane 7/1/2012 6/30/2013
2,2-Dichloropropane 7/1/2012 6/30/2013
2-Butanone (Methyl ethyl ketone, MEK) 7/1/2012 6/30/2013
2-Chloroethyl vinyl ether 7/1/2012 6/30/2013
2-Chlorotoluene 7/1/2012 6/30/2013
2-Hexanone 7/1/2012 6/30/2013
4-Chlorotoluene 7/1/2012 6/30/2013
4-Methyl-2-pentanone (MIBK) 7/1/2012 6/30/2013
Acetone 7/112012 6/30/2013
Acetonitrile 7/112012 6/30/2013
Acrolein (Propenal) 7/1/2012 6/30/2013
Acrylonitrile 7/112012 6/30/2013
Allyl chloride (3-Chloropropene) 7/1/2012 6/30/2013
Benzene 7/1/2012 6/30/2013
Bromobenzene 7/1/2012 6/30/2013
Bromochloromethane 7/1/2012 6/30/2013
Bromodichloromethane 7/1/2012 6/30/2013
Bromoform 7/1/2012 6/30/2013
Carbon disulfide 7/112012 6/30/2013
Carbon tetrachloride 7/112012 6/30/2013
Chlorobenzene 7/1/2012 6/30/2013
Chlorodibromomethane 7/1/2012 6/30/2013
Chloroethane (Ethyl chloride) 7/1/2012 6/30/2013
Chloroform 7/112012 6/30/2013
Chloroprene (2-Chloro-1 ,3-butadiene) 7/1/2012 6/30/2013
cis-1,2-Dichloroethylene 7/1/2012 6/30/2013
cis-1,3-Dichloropropene 7/1/2012 6130/2013
Dibromomethane (Methylene bromide) 7/1/2012 6/30/2013
Dichlorodifluoromethane (Freon-12) 7/1/2012 6/30/2013
Diethyl ether 7/1/2012 6/30/2013
Ethyl acetate 7/112012 6/30/2013
Ethyl methacrylate 7/112012 6/30/2013
Ethylbenzene 7/1/2012 6/30/2013
Hexachlorobutadiene 7/1/2012 6/30/2013
lodomethane (Methyl iodide) 7/1/2012 6/30/2013
Isobutyl alcohol (2-Methyl-1-propanol) 7/1/2012 6/30/2013
Isopropyl benzene 7/1/2012 6/30/2013
Methyl bromide (Bromomethane) 7/1/2012 6/30/2013
Methyl chloride (Chloromethane) 7/112012 6/30/2013
!J \:.. UTAH DEPARTMENT OF ~tHEALTH
4431 South 2700 West· Taylorsville, UT 84119' phone [phone] • fax [phone]
www.health.utah.gov/els/labimp/
AB
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EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012-3 Page 6 of I 0
Energy Laboratories Incorporated -Casper Start Date Expires
Program/Matrix: RCRA (Non Potable Water)
Methyl tert-butyl ether (MTBE) 7/1/2012 6/30/2013
Methylene chloride (Dichloromethane) 7/1/2012 6/30/2013
Naphthalene 7/112012 6/30/2013
n-Butylbenzene 7/1/2012 6/30/2013
n-Propylbenzene 7/1/2012 6/30/2013
Propionitrile (Ethyl cyanide) 7/1/2012 6/30/2013
sec-Butyl benzene 7/1/2012 6f30/2013
Styrene 7/1/2012 6/30/2013
tert-Butylbenzene 7/1/2012 6f30/2013
Tetrachloroethylene (Perchloroethylene) 7/1/2012 6/30/2013
Toluene 7/1/2012 6/30/2013
trans-1,2-Dichloroethylene 7/1/2012 6/30/2013
trans-1,3-Dichloropropylene 7/1/2012 6/30/2013
trans-1,4-Dichloro-2-butene 7/1/2012 6/30/2013
Trichloroethene (Trichloroethylene) 7f1/2012 6/30/2013
Trichlorofluoromethane (Fluorotrichloromethane, Freon 11) 7/1/2012 6/30/2013
Vinyl acetate 7/112012 6/30/2013
Vinyl chloride 7/112012 6/30/2013
Xylene (total) 7/1/2012 6/30/2013
Method EPA 9020
Total organic halides (TOX) 7/1/2012 6/30/2013
Method EPA 9040
pH 7/112012 6/30/2013
!J \:.. UTAH DEPARTMENT OF
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
WNW. health. utah .gov/els/labimpl
~r. HEALTH
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EPA Number: WYOOOO2 Attachment to Certificate Number: WY000022012.3 Page 7 oflO
Energy Laboratories Incorporated -Casper Start Date Expires AB
Program/Matrix: RCRA (Solid & Hazardous Material)
Method EPA 1311
Toxicity Characteristic Leaching Procedure Metals 7/1/2012 6/30/2013 FL
Toxicity Characteristic Leaching Procedure Volatiles 7/112012 6/30/2013 FL
Method EPA 30508
PreparationlExtraction 7/1/2012 6/30/2013 FL
Method EPA 3550A
PreparationlExtraction 7/1/2012 6/30/2013 FL
Method EPA 5035
PreparationlExtraction 7/1/2012 6/30/2013 FL
Method EPA 60108
Antimony 7/1/2012 6/30/2013 FL
Arsenic 7/112012 6/30/2013 FL
Barium 7/112012 6/30/2013 FL
Cadmium 7/112012 6/30/2013 FL
Chromium 7/112012 6/30/2013 FL
Lead 7/112012 6/30/2013 FL
Selenium 7/112012 6/30/2013 FL
Silver 7/112012 6/30/2013 FL
Method EPA 6020
Arsenic 7/112012 6/30/2013 FL
Barium 7/112012 6/30/2013 FL
Cadmium 7/112012 6/30/2013 FL
Chromium 7/112012 6/30/2013 FL
Lead 7/112012 6/30/2013 FL
Selenium 7/1/2012 6/30/2013 FL
Silver 7/112012 6/30/2013 FL
Method EPA 7471A
Mercury 7/1/2012 6/30/2013 FL
Method EPA 80158
Diesel range organics (DRO) 7/1/2012 6/30/2013 FL
Gasoline range organiCS (GRO) 7/1/2012 6/30/2013 FL
Method EPA 82608
1,1,1,2-Tetrachloroethane 7/1/2012 6/30/2013 FL
1,1,1-Trichloroethane 7/1/2012 6/30/2013 FL
1,1,2,2-Tetrachloroethane 7/1/2012 6/30/2013 FL
1,1 ,2-Trichloroethane 7/112012 6/30/2013 FL
1,1-Dichloroethane 7/1/2012 6/30/2013 FL
1,1-Dichloroethylene 7/1/2012 6/30/2013 FL
1,1 -Dichloropropene 7/1/2012 6/30/2013 FL
1,2,3-Trichlorobenzene 7/1/2012 6/30/2013 FL
1,2,3-Trichloropropane 7/1/2012 6/30/2013 FL
1,2,4-Trichlorobenzene 7/1/2012 6/30/2013 FL
1,2,4-Trimethylbenzene 7/1/2012 6/30/2013 FL
1 ,2-Dibromo-3-chloropropane (DBCP) 7/1/2012 6/30/2013 FL
1 ,2-Dibromoethane (EDB, Ethylene dibromide) 7/1/2012 6/30/2013 FL
1 ,2-Dichlorobenzene (o-Dichlorobenzene) 7/1/2012 6/30/2013 FL
1 ,2-Dichloroethane (Ethylene dichloride) 7/1/2012 6/30/2013 FL
!J ~ lTfAH DEPARTMENT OF
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
www.health.utah.gov/els/labimp/ ~r.HEALTH
EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012·3 Page 8 of 10
Energy Laboratories Incorporated -Casper Start Date Expires
Program/Matrix: RCRA (Solid & Hazardous Material)
1,2-Dichloropropane 7/1/2012 6/30/2013
1,3,5-Trimethylbenzene 7/1/2012 6/30/2013
1,3-Dichlorobenzene 7/1/2012 6/30/2013
1,3-Dichloropropane 7/1/2012 6/30/2013
1 A-Dichlorobenzene 7/112012 6/30/2013
2,2-Dichloropropane 7/1/2012 6/30/2013
2-Butanone (Methyl ethyl ketone, MEK) 7/1/2012 6/30/2013
2-Chloroethyl vinyl ether 7/1/2012 6/30/2013
2-Chlorotoluene 7/1/2012 6/30/2013
2-Hexanone 7/1/2012 6/30/2013
4-Chlorotoluene 7/1/2012 6/30/2013
4-Methyl-2-pentanone (MIBK) 7/1/2012 6/30/2013
Acetone 7/112012 6/30/2013
Acetonitrile 7/112012 6/30/2013
Acrolein (Propenal) 7/1/2012 6/30/2013
Acrylonitrile 7/112012 6/30/2013
Allyl chloride (3-Chloropropene) 7/1/2012 6/30/2013
Benzene 7/112012 6/30/2013
Bromobenzene 7/1/2012 6/30/2013
Bromochloromethane 7/1/2012 6/30/2013
Bromodichloromethane 7/1/2012 6/30/2013
Bromoform 7/112012 6/30/2013
Carbon disulfide 7/112012 6/30/2013
Carbon tetrachloride 7/112012 6/30/2013
Chlorobenzene 7/1/2012 6/30/2013
Chlorodibromomethane 7/1/2012 6/30/2013
Chloroethane (Ethyl chloride) 7/1/2012 6/30/2013
Chloroform 7/112012 6/30/2013
Chloroprene (2-Chloro-1 ,3-butadiene) 7/1/2012 6/30/2013
cis-1,2-Dichloroethylene 7/1/2012 6/30/2013
cis-1,3-Dichloropropene 7/1/2012 6/30/2013
Dibromomethane (Methylene bromide) 7/1/2012 6/30/2013
Dichlorodifluoromethane (Freon-12) 7/1/2012 6/30/2013
Diethyl ether 7/1/2012 6/30/2013
Ethyl methacrylate 7/112012 6/30/2013
Ethylbenzene 7/1/2012 6/30/2013
Hexachlorobutadiene 7/1/2012 6/30/2013
lodomethane (Methyl iodide) 7/1/2012 6/30/2013
Isobutyl alcohol (2-Methyl-1-propanol) 7/1/2012 6/30/2013
Isopropylbenzene 7/1/2012 6/30/2013
Methyl bromide (Bromomethane) 7/1/2012 6/30/2013
Methyl chloride (Chloromethane) 7/112012 6/30/2013
Methyl tert-butyl ether (MTBE) 7/1/2012 6/30/2013
Methylene chloride (Dichloromethane) 7/1/2012 6/30/2013
Naphthalene 7/112012 6/30/2013
n-Butylbenzene 7/1/2012 6/30/2013
n-Propylbenzene 7/1/2012 6/30/2013
Propionitrile (Ethyl cyanide) 7/1/2012 6/30/2013
sec-Butyl benzene 7/1/2012 6/30/2013
!i \:.. UTAH DEPARTMENT OF ~t HEALTH
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
www.health.utah.gov/els/labimp/
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EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012·3 Page 9 of 10
Energy Laboratories Incorporated -Casper Start Date Expires
Program/Matrix: RCRA (Solid & Hazardous Material)
Styrene 7/1/2012 6/30/2013
tert-Butylbenzene 7/1/2012 6/30/2013
Tetrachloroethylene (Perch loroethylene) 7/1/2012 6/30/2013
Toluene 7/112012 6/30/2013
trans-1,2-Dichloroethylene 7/1/2012 6/30/2013
trans-1,3-Dichloropropylene 7/1/2012 6/30/2013
trans-1,4-Dichloro-2-butene 7/1/2012 6/30/2013
Trichloroethene (Trichloroethylene) 7/1/2012 6/30/2013
Trichlorofluoromethane (Fluorotrichloromethane, Freon 11) 7/1/2012 6/30/2013
Vinyl acetate 7/1/2012 6/30/2013
Vinyl chloride 7/1/2012 6/30/2013
Xylene (total) 7/112012 6/30/2013
Method EPA 9023
Extractable organics halides (EOX) 7/1/2012 6/30/2013
Method EPA 9045C
pH 7/1/2012 6/30/2013
!J ~ UTAH DEPARTMENT OF ~,..HEALTH
4431 South 2700 West· Taylorsville, UT 84119 • phone [phone] • fax [phone]
WNW. health. utah.gov/elsllabimpl
AB
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EPA Number: WYOOOO2 Attachment to Certificate Number: WYOOOO22012-3 Page 10 of J 0
Energy Laboratories Incorporated -Casper Start Date Expires
Program/Matrix: SDWA (Potab/e Water)
Method Brooks/Blanchard Ra-228
Radium-228 7/1/2012 6/30/2013
Method EPA 200.8
Uranium 7/1/2012 6/30/2013
Method EPA 900.0
Gross-alpha 7/1/2012 6/30/2013
Gross-beta 7/1/2012 6/30/2013
Method EPA 901.1
Gamma Emitters 7/1/2012 6/30/2013
Method EPA 903
Radium-226 7/1/2012 6/30/2013
Method EPA 905
Strontium-gO 7/112012 6/30/2013
Method EPA 906
Tritium 7/112012 6/30/2013
Method EPA Ra-Q5
Radium-228 7/1/2012 6/30/2013
Method Radon in Drinking Water
Radon-222 7/1/2012 6/30/2013
Method SM 7500-U C
Uranium 7/1/2012 6/30/2013
The Utah Environmental Laboratory Certification Program (ELCP) encourages clients and data users to verify the most current certification letter
for the authorized method.
The analytes by method which a laboratory is authorized to perform at any given time will be those indicated in the most recent certificate letter.
The most recent certification letter supersedes all previous certification or authorization letters. It is the certified laboratory's responsibility to
review this letter for discrepancies. The certified laboratory must document any discrepancies in this letter and send notice to this bureau within
15 days of receipt. This certificate letter will be recalled in the event your laboratory's certification is revoked .
.!J ~ UTAli DEPARTMENT OF ~t HEALTH
4431 South 2700 West· Taylorsville, UT 84119' phone [phone]' fax [phone]
WNW. health. utah .gov/elsJlabimpl
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Appendix R
Revised Text for Section 8 of Attachment 5 of the April 2011 Amendment Request
8.0 Potential Effects on Tailings System
8.1 Tailings Cell Liner Material Compatibility
The Uranium Material will be received as a precipitated solid from lime treatment of
the WTP influent water. A portion of this material may be insoluble in the acid leach
process at the Mill and therefore, the discharge sent to tailings may contain some
solid material ("sand"). The remainder of the Uranium Material will be soluble and
therefore be contained in the liquid phase after processing in the acid leach system.
Tailings from processing the Uranium Material will be sent to one of two tailings
cells at the Mill, Cell 4A or Cell 4B or a subsequently-constructed cell. The solutions
from the Uranium Material tailings will be recirculated through the mill process for
reuse of the acidic properties in the solution. The sands will be only a portion of the
total mass of Uranium Material sent to the Mill from the Site. However, assuming a
worst case scenario that all of the solid material ends up as sand in the tailings, it is
estimated that for the main processing circuit, the additional load to the tailings will
be minimal (Table 6).
Cell 4A and 48 both have high-density polyethylene ("HDPE") liners. Cell 4A went
into service in October of 2008 and contains conventional ore tailings sands.
Solutions from the Mill, starting in July 2009, are also sent to this Cell. Cell 4B was
constructed and placed in to operation in February of 2011 and is expected to
receive the same type of materials as Cell 4A when operational.
The constituents in the sands and liquids resulting from processing the Midnite
Mine Uranium Materials are not expected to be significantly different from those in
the conventional ores either in composition or in concentration of constituents.
Table +-.6...indicates that when comparing the Uranium Material to the tailings, all of
the constituents found in the Uranium Material are currently processed in the Mill's
main circuit and/or the alternate feed circuit in other ores and alternate feed
materials with the exception of copper. No information on the concentration of
copper in the ores or alternate feeds is cUlTentLy available but coppel is ana lyzed
under the groundwater monitori ng program.
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 tailings cells. 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. Mitchell (1985)
studied the chemical resistivity of PVC and HDPE at a pH range of 1.5 to 2.5 standard
units using sulfuric acid. This study concluded that PVC performed satisfactorily
under these conditions and HDPE performed better and was overall more stable
under these acidic conditions.
As described above, 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 the tailings system.
Every metal and non-metal cation and anion component in the Uranium Material
already exists in the Mill's tailings system and/or is analyzed under the GW
monitoring program. A summary of the potential tailings composition before and
after processing the Uranium Material using historical data for tailings Cell 3 is
presented in Table 6 for projected tailings composition before and after processing
the Uranium Material using data for Ce1l4A or 4B.
Every component exceJ)t copper, in the Uranium Material has been:
1. detected in analyses of the existing tailings cells liquids;
2. detected in analyses of existing tailings cells solids;
3. detected in analyses of alternate feed materials that have already been licensed
for processing at the Mill; or
4. detected in process streams or intermediate products when previous alternate
feeds were processed at the Milt
Generallv the concentrations of constituents id n 'fled in the ,ilings liquids or
solids, feed materials or process streams at the mill are i
at concentrations that are generally comparable to the concentrations in the
Uranium Material.-. -_Due to the small annual and total quantities of the Uranium
Material, an increase in the concentration of ~these analyte~ in the Mill's tailings
is not expected to be significant. A few constituents such as barium, beryllium.
silver, manganese. copper. and calcium re presen in the Uranium Material and are
either present in lower concentrations in the ores and other alternate feeds at the
mill or as jn the case of coppel , in or mation on concentration in the ore and other
alternate feeds was nat <wa llable. Although he percent lata1 of these con ti Lllents
c{)J1tl'ibuted from the Uranium Material to the Mill Tailings in the 1-0 year period
seems high , between 5 and lOG percent of these constituents presentin the tailings
is from th Uranium Materi al. the total con I'ibuted tons is less than one percent of
the total mass in the Tailings Cell.
The constituents in the Uranium Material, i-are expected to produce no incremental
additional environmental, health, or safety impacts in the Mill's tailings system
beyond those produced by the Mill's processing of natural ores or previously
approved alternate feeds. Since the impacts of all the constituents on the tailings
system are already anticipated for normal Mill operations, and permitted under the
Mill's license, they have not been re-addressed in this evaluation.
Groundwater Monitoring Program
One difference in the milling process of Uranium Material and disposal of tails in the
tailings cells at the Mill compared to processing conventional ore, is the introduction
of barium to the tailings cells. However, as discussed above barium is currently
present in Cell 3, and has been introduced at higher concentration than in the
Uranium Material, from other alternate feed materials. Barium is not a constituent
that is monitored under the Mill's GWDP. Calcium is also contained in the Uranium
Material, but is found in conventional ores and it is monitored under the Mill's
GWDP. As discussed below, there is no need to add barium to the Mill's GWDP
monitoring program.
Barium will be introduced to the Mill's tailings cells with disposal of the tailings
from processing the Uranium Material. The chemistry of the tailings cells would
limit the mobility of barium due to the abundance of sulfate in the tailings cells. The
insolubility of barium in the presence of sulfate is generally consistent regardless of
the liquid medium. That is, the solubility of barium sulfate in cold water is 0.022
mg/L and in concentrated sulfuric acid is 0.025 mg/L (Handbook of Chemistry and
Physics, 68th Edition). 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) would be negligible. Therefore,
given the strong tendency of barium to partition to solids, especially in the presence
of sulfate, there is no reasonable potential for barium to migrate to ground water
from the tailings cells at the Mill in the unlikely event of a leak in the tailings cells.
Calcium Kd value in UDEQ Statement of Basis for the permit (December 1, 2004)
contains published Kd values for calcium of 5 to 100 Llkg for sandy to clayey soils.
The Kd for barium is 100 to 150,000 Llkg for the same soil types indicating less
mobility in groundwater, and Tetra Tech has therefore concluded that barium is
sufficiently represented by monitoring for calcium and has identified no technical
reason to add barium to the list of constituents monitored in ground water in the
vicinity of the tailings cells.
Excluding barium, chemical and radiological make-up of the Uranium Material is
similar to other ores and alternate feed materials processed at the Mill, and their
resulting tailings will have the chemical composition of typical uranium process
tailings, for which the Mill's tailings system was designed. As a result, the existing
groundwater monitoring program at the Mill will be adequate to detect any
potential future impacts to groundwater.
Conclusions and Recommendations
While concentrated levels of certain constituents in the Uranium Material may be
present, no additional material management requirements during handling and
processing will be required. The Mill has successfully implemented processing of
previous alternate feeds with similar or higher concentrations of the constituents
contained in the Uranium Material. For example, the Mill has successfully processed
and recovered uranium from uranium-bearing salts, calcium
fluoride precipitates, recycled metals, metal oxides, and calcified product, all of
which posed potential chemical reactivity and material handling issues comparable
to or more significant than those associated with this Uranium Material.
Based on the foregoing information, it can be concluded that:
1. All the constituents in the Uranium Material have either been reported to be, or
can be assumed to be, already present in the Mill's tailings system or were reported
in other alternate feeds processed at the Mill, at levels generally comparable to
those reported in the Uranium Material.
2. All the constituents in the Uranium Material have either been reported to be, or
can be assumed to be, previously introduced into the Mill's process, with no adverse
effects to the process, or worker health and safety.
3. All the known impurities in the Uranium Material have either been reported to be,
or can be assumed to be, previously introduced into the Mill tailing impoundments,
with no adverse effects to the tailings system, or human health and safety.
4. There will be no significant incremental environmental impacts from processing
Uranium Material beyond those that are already anticipated in the Final
Environmental statement and subsequent Environmental Assessments for the Mill.
5. Spill response and control measures designed to minimize particulate
radionuclide hazards will be more than sufficient to manage chemical hazards from
particulate metal oxides.
It should be noted that the Uranium Material originated entirely from the contact of
sources of environmental water (surface and or groundwater) with natural uranium
ore. Every constituent in the Uranium Material, except barium, is a constituent of
natural uranium ore and is present in the Uranium Material as a result of natural
leaching from uranium ore. Every constituent in the ore is already present in natural
ores including the ores stored on the Mill's ore pad, and is already present in the
Mill circuit and tailings system.
Further, the total quantity of Uranium Material is very low. The entire annual
volume of Uranium Material to be shipped to the Mill constitutes only a small
fraction of one day's processing in the Mill. The entire volume of Uranium Material
will make an insignificant contribution to the total volume of tailings in the Mill's
tailings system.
As discussed in the section on Effects on Tailings System, above, after processing of
the Uranium Material all constituents except beryllium, calcium and manganese, will
have a de_minimis or no impact on the tailings composition, will create a slight
reduction in the average concentrations in the tailings cells, or will create a change
that is within the range of increases created by other alternate feeds.
Of the three whose impact may be detectable, manganese' and ca lcium (a non-
hazardous nutrlent ~surface and groundwaterl Lhese constituents are already
monitored under the Mill's groundwater monitoring program. As discussed above,
barium is well represented geochemically by calcium which is already monitored in
the Mill's groundwater monitoring program.
Due to the above facts, specifically that the Uranium Material originated from
natural ore and will be shipped and processed at very low rates, the constituents in
the Uranium Material could be expected to have a negligible effect on the Mill
process and the tailings system, and will have no discernible environment or health
and safety effects beyond the effects of natural ore processing.