DRC-2016-012821 - 0901a068807b30d3

In Reply Refer To:
United States Department of the Interior
Bureau of Indian Affairs
Southwest Region
1001 Indian School Road, NW
Albuquerque, New Mexico 87104
360-Tribal Government Services
BIA-2018-00091
TAKE PRIDE IN AMERICA
CERTIFIED LETTER
Cynthia Howard
P.O. Box 140873
OCT 13 2017 �r�©l�m wj�
195 North 1820 West
Salt Lake City, Utah 84114-0873
Dear Ms. Howard:
UTAH ATTORNEY GENE.RAL ENVIRONfvlENT DIVISION
On October 11,2017, the Bureau oflndian Affairs (BIA), Southwest Regional Office (SWRO)
received your Freedom oflnformation Act (FOIA) request dated October 5, 2017, and assigned·
it control number BIA-2018-00091. Please reference this number on all future correspondence.
You requested the following:
"Task 5 Final Report December 16, 2016.doc with Appendix 5B Introduction
to the Use of Uranium and Radium Isotopes in Geochemical Forensic
Studies.doc, Appendix E UMUT and EFR Trip Report November and
December 2016.doc, Figure 1 Roadmap Level 1.doc, Figure 2a to 2c Flow
Chart for GWCL Modification and Challenges by the UMUT EDP.doc,
and Tables 1 to 4.doc."
We have classified you as an "other-use" requester. As such, we may charge you for some of our
search and duplication costs, but we will not charge you for our review costs; you are also
entitled to up to 2 hours of search time and 100 pages of photocopies (or an equivalent volume)
for free, 43 C.F.R. § 2.39. If, after taking into consideration your fee category entitlements, our
processing costs are less than $50.00, we will not bill you because the cost of collection would
be greater than the fee collected, 43 C.F.R. § 2.37(g).
We are writing today to respond to your request on behalf of the BIA, SWRO.
We have enclosed 78 pages, which are being released to you in its entirety.
We do not bill requesters for FOIA processing fe es when their fe es are less than $50.00, because
the cost of collection would be greater than the fee collected, 43 C.F.R. § 2.37(g). Therefore,
there is no billable fee for the processing of this request.
This concludes our response to your request. Should you have any questions regarding this
response, please contact Jean Buck-Curtis, FOIA Coordinator at [phone], or email,
[e-mail].
Sincerely,
Enclosure
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
REVIEW OF DOCUMENTS FROM WHITE MESA URANIUM MILL
FINAL REPORT-TASK 5 DELIVERABLE
Executive Summary
A review of reports and memos written by contractors to the operators of the White Mesa Mill
(currently Energy Fuels Resources (USA} Inc (EFR}, the Utah Department of Environmental
Quality (UDEQ) and the Ute Mountain Ute Tribe Environmental Programs Department (UMUT
EDP} concerning potential environmental effects from the Mill has been carried out. The
numerous concerns raised by the UMUT EDP can be divided into a few major topics related to
potential future health effects:
1. Tailing cells are currently leaking and have produced a multi-component plume that has
been detected in several monitoring wells as indicated by decreasing pH and increasing
concentrations of several other solutes.
2. Air blown dust from ore transport trucks and ore storage pads has contaminated surface
water and land areas to the east and northeast of the Mill.
3. Radon emissions from tailings cells exceed limits that are protective of human health.
4. Remediation of the effects of the above will be more costly than previously estimated
and the surety bond held in trust for the cleanup is insufficient.
The scope of the current contract and expertise available to US Consulting, Inc has necessitated
primary focus on item 1 above, preliminary evaluation of items 2 and 3 and a cursory review of
item 4.
Based on review of the documents examined to date, it is concluded that:
1. The available information suggests that observed pH decreases and increase of metals
concentrations in wells down gradient of the tailings cells are not necessarily due to
tailing cells leakage.
2. The leaks and repairs reported for Legacy Tailing Cells do not suggest that the cells are
not operating as designed. It cannot be stated that the tailings cells will not leak in the
future due to poor design, however, if they do leak, then reactive transport modeling
(ICTM) carried out so far suggests that a plume will not reach the aquifer within the 200
year regulatory period. It would be useful to run the ICTM for at least 1000 yrs; the
model is a useful tool for sensitivity analysis, which should be done with input from the
Tribe (as well as the State).
3. The available information suggests that air blown dust from the facility may have led to
levels of uranium concentration in Entrance Spring and stream sediments that are above
background levels. However, the alternative model proposed by EFR that the
contamination is from historic operations not associated with current Mill activity is also
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plausible and should be examined in more detail. Concerns about inadequate air
sampling procedures might be resolved by review of the maintenance records for the
High Volume Air Samplers.
4. Radon emissions from the tailings cells may have been overestimated by the UMUT EDP
staff due to improper model assumptions. Another potential hazard might be indicated
by odors detected by residents; plumes coming from the facility are observed and
reported anecdotally.
5. The impact on human health of reasonable worst-case scenarios involving the effects
described in items 1 to 4 above should be evaluated in a systematic risk assessment that
involves consideration of exposure pathways, epidemiologic data, sensitivity analysis
and community participation. Evaluation of the sufficiency of the surety bond should be
evaluated in light of such a risk assessment as well as cost analysis based on other
similar sites.
6. Communication between the Tribe, State and Federal Regulatory Agencies can be
improved by sensitivity to cultural issues. The Bureau of Indian Affairs can play a
valuable role in providing assurance to the Ute Mountain Ute Tribe that the concerns of
the Tribe are being reviewed and carefully evaluated.
As evidenced by the numerous Requests for Agency Actions (RAA) filed by the UMUT EDP, it is
clear that there is no simple way to resolve the areas of uncertainty and satisfy the concerns of
the Tribe with respect the long-term risk posed by the Mill facility. There is a large number of
complex technical issues that are important and a team of experts would be required to
provide a comprehensive evaluation of these issues. However, it is suggested that the Bureau
of Indian Affairs could act as an impartial party in bridging some of the gaps in the positions
held by the Tribe and the Mill owner. Several possible activities are suggested below that might
add additional data to reduce uncertainty, mitigate potential risks and create more trust
between the stakeholders.
1. Complete the analysis of potential role of pyrite oxidation as cause of pH decreases and
metal concentration increases in monitoring wells by measuring additional redox
couples in groundwater and more fully characterizing pyrite and iron oxide occurrences
in unsaturated zone. Additional PHREEQC modeling incorporating rate constants for
important reactions could be used to assess short-term effects associated with well­
purging.
2. Address concerns about wind borne contamination by better monitoring of radon
sources and wind velocity.
3. Address UMUT EDP concerns about Mill work practices including sampling and analysis
procedure by carrying out verification exercises with an independent laboratory.
4. Look at alternative conceptual models for the Integrated Contaminant Transport Model
5. Consider additional tracers such as isotopes for fingerprinting potential leaks from
tailings cells and setting Ground Water Compliance Limits.
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6. Allow the installation of 3 new wells as suggested by EFR to be placed in the perched
zone to characterize groundwater flow and direction in the area between MW-17 and
MW-22.
7. Carry out risk management analysis within framework of Monitored Natural Attenuation
to address concerns about long term risk.
8. Use the method developed by DOE's Innovative Technology and Remediation
Development program to get a consensus about what additional steps are needed to be
taken to evaluate potential leaks and off-site transport of radionuclides.
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Introduction: Overview and history of contract
Summary Timeline for Contract
Date Activity
December 20, 2014 Colin Larrick (UMUT EDP) provides document package to Chris
Banet at BIA
June 11, 2015 Initial contact between US Consulting and BIA (T ony
Zimmerman) to discuss potential contract with BIA
July 2, 2015 US Consulting receives UMUT package document and proposal
is submitted
April 4, 2016 Contract with US Consulting, Inc. is placed
June 6, 2016 Completion of Task 1-Initial Document Review
July 20, 2016 Telecon with Colin Larrick of UMUT EDP and receipt of first set
of new documents (see Attachment A)
July 26, 2016 Completion ofTask 2-Draft Report Outline
September 22, 2016 US Consulting visit to UMUT EDP offices in Towaoc and White
Mesa Mill Site (see Attachment B)
October 14, 2016 Telecon with Harold Roberts, EFR (see Attachment C)
November 2, 2016 Receipt of new documents on Rn monitoring from EFR
November 14, 2016 Submittal of Task 3 Draft Report to BIA
November 22, 2016 Project review meeting at BIA offices
November 30, 2016 Project Review Meeting at UMUT EPD in Towaoc, CO
December 1, 2016 Project Review Meeting at White Mesa with EFR staff
December 1-2, 2016 Sampling of off-site wells by Duke University student
December 15, 2016 Final project review meeting with BIA staff
December 22, 2016 Submittal ofT ask 5 Final Report to BIA
Document Review Process
This contract began on April 4, 2016 with the review of documents provided by the Ute
Mountain Ute Tribe Environmental Programs Department (UMUT EDP) through the Bureau of
Indian affairs. Approximately 70 documents comprised of more than 10,000 pages of data and
analyses were included in the data package received from the UMUT EDP. Under Task 1, an
initial document review was carried out in an attempt to identify which documents (Levell
Documents) defined the most important issues and which documents provided supporting
information. To do this, this initial document review identified the relationships between the
documents, identified the major regulatory actions and subjects important to this work, and
established a timeline describing the evolution of the regulatory and technical activities.
Regulatory actions include applications for the license for radioactive materials, groundwater
discharge permits, corrective action plans, air quality permits, and site closure plans.
Documents supporting these actions are submitted by the owner of the facility to the Utah
Department of Environmental Quality (UDEQ) . After submittal of the documents, the staff at
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UDEQ reviewed them and most often sent the document back to the mill Site owner with a
requests for additional information. A public review process allowed members of the
community to provide their comments on the adequacy of the submittals. After review of
these comments and submittal of revised versions of the original documents, the regulatory
action was completed by granting a license renewal or a water or air quality permit etc. In
general, the UMUT EDP submitted RAA (Request for Agency Actions) or other challenge to the
Utah courts based on their conclusions that the community participatory process was not
adequate and the current license and permits are not adequately protective of the health of the
Tribe members who live in nearby community of White Mesa.
Figure 1 is a Roadmap that describes the relationships between the most significant actions of
the Site owner, Regulator and the Ute Mountain Ute Tribe Environmental Programs Division
(defined as Level l in this report). Table 1 describes these Level l documents which include the
Requests for Agency Action that have been filed by the Tribe. The RAAs are based on Exhibits
that contain the technical justification of the challenges made by the UMUT EDP. Tables 2 and
3 describe the Exhibits for the RAAs concerning the Nitrogen Corrective Action Plan (dated
1/11/2013) and the Approval Order of March 3, 2011 (dated 3/31/2013) respectively.
Both Figure 1 and Table 4 also include an description of the main comments provided by the
Tribe regarding the Denison Mines USA Radioactive Materials License Renewal application of
2011 (referred to as 'UMUT Searchable Comments Letter'). This Level l document contains a
comprehensive description of the Tribe's concerns. An outline of the document in MS Word
Outline View is provided as Appendix 1 to this report. It describes the supporting information
contained in the Exhibits and also legal exchanges between the Tribe, the Utah Department
of Environmental Quality, and the Site owners. Table 4 describes the author, recipient, main
points and important references cited by the Exhibits in this document. Many of the same
documents are relevant to the RAA concerning the Dawn Mining Alternate Feed Amendment
Request (dated 8/11/2014).
Task 2 of this contract involved detailed document review and preparation of the outline for
the Draft Report. Document Road maps were prepared for major technical/regulatory areas
identified under Task 1. The documents were classified into the groups (Level 2) for the
purpose of constructing the Roadmaps which showed how they were related in both subject
matter and history:
• Radioactive Materials License Renewal (Table 4)
• Air Quality Issues
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• Nitrate Corrective Action Plan (Nitrogen CAP) (Table 2)
• Ground Water Discharge Permit (GWDP) (Appendix 2)
• Integrated Contaminant Transport Model (ICTM) (Appendix 2)
• Source Assessment Reports (SAR) (Appendix 3)
• Ground Water Compliance Limit (GWCL) Modifications and Pyrite Dissolution Studies
(Appendix 3)
• Ground Water Background Reports (Figure 2c)
• Tailings Cells Reports (Appendix 4)
In the list above, Level 2 documents are ordered to show subjects with more data at the
bottom and more integration at the top. In many cases, the same document contained
technical data that supported one or more subjects and there was overlap in the data used by
more than one Level 2 subject.
Appendices 2 to 4 describe how different documents are related to Level 2 subjects . Figure 2a
to 2c describe how Groundwater Background Reports and modifications to the Ground Water
Compliance Limits (GWCL) are related. Figure 2c describes the interactions between the Tribe,
Site owner and DEQ in revising the GWCLs. These appendices, tables and figures were
compiled prior to detailed review of the documents in order to keep track of the tremendous
amount of information relevant to the White Mesa Mill. They provide the foundation for the
current and any future work in this contract.
Background Information about the Site
The Ute Mountain Ute Tribe is a federally-recognized Indian tribe with lands located in
southwestern Colorado, northwestern New Mexico, and southeast Utah. There are two Tribal
communities on the Ute Mountain Ute Reservation: Towaoc, in southwestern Colorado, and
White Mesa, which is located in Utah within three miles of the White Mesa Mill ("WMM")
facility. The lands comprising the White Mesa community are held in trust for the Tribe and for
other individual Tribal member owners. Over the course of the last 30 years, the White Mesa
uranium mill has been managed by several companies including Uranium Fuels, Denison USA,
and its current owner, Energy Fuels Resources.
Currently the mill site includes five tailing cells which contain both liquid and solid wastes from
the operations of the mill facility or other materials that have been sent to the facility for
disposal. The tailings cells sit within the Burro Canyon Formation. The water table lies above the
contact with the underlying Brushy Basin Member of the Morrison Formation. The thickness of
the perched saturated zone has an average of about 35 feet; there are several springs along the
edge of the Mesa. The springs are used by livestock that roam the Mesa and perhaps by
members of the Ute Mountain Ute tribe. At one of the springs (Entrance Springs), willows and
other plants grow within a small canyon.
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As part of normal operating procedures, the owner of the mill is required to monitor water and
air quality in areas surrounding the mill facility. Approximately 30 monitoring wells have been
drilled into the Burro Canyon formation, which contains a perched water aquifer. Water
samples from these wells are analyzed for 38 chemical constituents. Maximum allowable
concentrations (Ground Water Compliance Limit (GWCL)) have been set for each of these
constituents in each of the wells that are based on a provisional background concentration and
considerations of protections of public health. The wells are sampled on an annual basis as part
of the standard procedure. Concentrations of four chemicals (chloride, pH, uranium, and
nitrate) are routinely measured. These constituents are considered to be leading indicators of
any potential leak from the tailing cells because they are present in high concentrations in the
cells and are considered conservative tracers. If any of the chemical constituents exceeds the
GWCL for more than two consecutive sampling events, then an out of compliance (OOC)
condition is declared and the well must be sampled on a quarterly basis. In addition, a Source
Assessment Report (SAR) must be prepared by the site owner to evaluate if the OOC is due to
the release from tailings cells. The evaluation includes examination of trends in concentration
of each of these constituents over time and mass balance calculations to see if the increase in
concentration is consistent with concentrations in the tailing cells and mixing volumes of
leakage with groundwater. The background concentration of the constituent is calculated on an
ongoing basis from the available time series of concentration. The Department of
Environmental Quality follows an EPA procedure to evaluate any trends in concentration over
time. This procedure allows for the increase of the GWCLs if it is determined that the available
data are consistent with such an increase in the estimated background concentration. The
adjustment of the GWCL is often contested by the UMUT EPD when the site owner has applied
for a renewal of the groundwater discharge permit for the site. The Tribe has argued that this
procedure will allow potential leakages from the tailing cells to be undetected. Of particular
concern is the decrease in pH and concommitment increase in concentrations of several metals
in some of the monitoring wells. The site owner has argued that the decrease in pH is due to
dissolution of pyrite in either the unsaturated or saturated parts of the Burro Canyon and is not
related to any leakage from the tailing cells. Evaluation of this variation in pH and other
groundwater solutes due to natural variation is a key element of this review. There is
disagreement over whether to include additional indicator solutes in routine ground water
quality measurement in the monitoring wells. Discussion of the use of new indicators such as
radium isotopes is included in this report.
The Tribe has argued that the liners in the legacy tailing cells are passed their expected lifetime
and that leakage is inevitable. In addition they maintain that the leak detection system will not
detect any leaks before a contaminated plume reaches the aquifer. The site owner has used a
reactive transport model to calculate how far a potential plume could travel during the 200
year regulatory period. According to these calculations, based on realistic failure modes for the
liner, groundwater velocities in the unsaturated zone, and the geochemical reactions between
uranium and rock matrix, a potential plume will not reach the aquifer during this period. The
Tribe has challenged the assumptions of this transport model. In particular, the Tribe feels that
the model does not account for potential fast paths in the aquifer or properly describes the
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chemical speciation of uranium and sorption capacity of the rock matrix. The Tribe has argued
that their interpretation of rising concentration trends for uranium, pH and other metals
demonstrates that the cells are leaking and a contaminant plume is spreading more rapidly
than the site owner has maintained. Discussion of the adequacy of this reactive transport
model is discussed in this report.
The material that is shipped to the mill for reprocessing comes in a variety of forms including
uranium mill tailings, residues from treatment plants, and other radioactive waste forms. Of
particular concerns are the dust and fine particulates associated with the uranium mill tailings.
These are shipped in large trucks along the highway and until three years ago the ore was not
covered. This material sits on pads at the facility until a sufficient amount is received to justify
operating the mill. There is evidence collected by the USGS and the Tribe suggesting that
uranium-containing dust is blown from the mill to the surrounding area. Relatively high
concentrations of uranium and vanadium have been measured in soils, water, and plants that
lie along dominant wind paths and in the ephemeral stream drainage basins that are connected
to Entrance Springs and several monitoring wells.
Focus on Current Concerns of the UMUT EDP
There are many concerns raised by the Tribe (see Appendix 1) that have not been addressed in
this report due to limitations in the size of this contract. Conversations with UMUT EDP and the
Site owner identified the most current concerns, and efforts in this contract have focused on
these issues. A teleconference with UMUT EDP staff was held on July 21, 2016 (Appendix A); a
field trip was taken to White Mesa on September 22, 2016 (Appendix B) and a teleconference
was held with staff from Energy Fuels Resources on October 14, 2016 (Appendix C). In addition,
a report written by a contractor to the Tribe (Geoi-Logic Associates, Inc) and the review of the
report prepared by the Utah Department of Environmental Quality were provided by the Tribe.
A discussion of the main points in the report and the Utah DEQ comments are found in
Appendix D. Based on these interactions and the data reports described in Tables 1 to 4 and
Appendices 1 to 4, the key technical issues were identified for this report. These are described
in the following sections as a series of questions; analyses of the technical issues and
recommendations follow. After the Draft Final Report (Task 3) for this project was submitted to
BIA, UMUT EDP and EFR staff, meetings were held with the stakeholders at the BIA office in
Albuquerque, NM, at the UMUT EDP office in Towaoc, CO and at the Mill Site in White Mesa for
review of the initial findings. In addition, a site visit at the Mill allowed me to view the tailing
cells, Mill and ore holding areas (see Appendix E) . This Final Report (Task 5) was prepared after
these meetings.
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I Key Technical guest ions: .. -·{Formatted: Font: 14 pt, Bold
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1. What are the most reliable indicators of potential leakage from the tailings cells?
2. Is transport of contaminants from leaking tailings cell to perc/red aquifer rapid enough
to tlrreaten healtlr of potentially exposed populations?
3. Could such a multicontaminant plume persist in tire environment for many generations,
constituting an incalculable risk?
4. What is tire importance of airborne releases of radionuclides and deposition on plants to
overall radiological dose to the population in the area?
Detailed Discussion of Key Questions
1. What are tire most reliable indicators of potential leakage from the tailings cells?
• UMUT EPD asserts that observed decreases in pH and increases in metals
concentrations in several wells down gradient from the tailings cells indicate leakage
from the tailings cells.
• UMUT EPD does not accept the method used by EFR (and accepted by Utah UDWMRC)
to set acceptable concentration levels in each of the monitoring wells (GWCLs). (see
Figure 2b). These levels are assumed by EFR to represent background concentrations of
key indicator solutes or waste components and as such are used to monitor for any
possible contaminant releases from the cells. Over the last few years these levels have
been rising in several monitoring wells. EFR argues that these changes are due to natural
background variations and the GWCLs should be adjusted as additional data describing
these variations are obtained over time. However, UMUTDP rejects this approach,
argues that it masks the actual trend of rising concentrations and that the GWCLs should
not be continually adjusted and allow EFR to avoid taking action to prevent or monitor
further (potential) leakage.
• UMUT EPD feels that there are very limited reliable data to establish the background
concentration of potential tracers and contaminants at the site. Many data collected in
surveys before the Mill started operations have been rejected due to poor OA/QC
procedures.
• UMUT EPD also feels that the suite of solutes measured in monitoring wells and relied
upon as early indicators of cell leakage is no longer adequate. Two of the indicators
(chloride and nitrate established in 1996) are now of limited use because of alternate
and historical sources for these solutes (ammonium sulfate and chloroform plumes). A
Corrective Action Plan is designed to control nitrate, and Cl and N03 have lost their
"canary in the coal mine" value near the cells.
• UMUT EPD argues that additional indicator solutes (besides Cl, N03, U, 504, U and pH)
should be measured routinely at points of compliance wells and that additional wells
such as MW-22 should be designated at compliance wells. Many of these additional
solutes would not be conservative tracers.
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• UMUT EPD feels that a review of the potential retardation of new (nonconservative)
indicator solutes is required but must be done on a site-specific basis. (Simple generic
Kds from the literature would not be sufficient).
• UMUT EDP feels that the Legacy Tailing Cells are beyond their design life and were built
according to standards that are now know to be inadequate. This supports their view
that the observed trends in pH and metals concentrations are indications of past and
current leakage.
Analysis: 1) Review of Geochemical Forensic Studies of Ground Waters
Two evaluations of geochemical forensic evidence relating to potential existence of
contaminant plumes emanating from the tailing cells have been carried out. They are
described in detail in Appendix SA and summarized briefly below. Hurst and Solomon (2008)
examined isotopic and trace metal signatures of several wells on the Mill Site (MW-1, 1B, 2, 3,
3A, 5, 11, 14, 15, 18, 19, 22 , 27, 29, 30, 31), Tailings Cells 1, 2 and 3, and Wildlife ponds (WP2
and WP3). The US Geological Survey (Naftz et al. 2011) examined similar isotopic and metals
signatures for a complementary set of wells and water sources outside of the Mill site. Table 1
in Appendix SA compares the sites evaluated and the interpretations presented for both
studies.
In general, the conclusions of the two studies are similar. Both studies conclude that it is
unlikely that elevated and increasing concentrations of uranium or other solutes observed in
several of the wells were related to leakage from the tailings cells. This was based on the fact
that 1) the isotopic signatures for oxygen and sulfur in aqueous sulfates in the wells are very
different from those in tailings cells, 2) with the exception of MW-19 and MW-27, oxygen and
hydrogen isotopes of water in those wells data do not indicate mixing between evaporated,
enriched surface water (from either the wildlife ponds or the tailings cells) and isotopically
lighter groundwater. In addition, the USGS study showed that the 234U/238U Activity Ratio for
all samples with U concentrations< 30 mcg/L range from 1.4 to 3.4, suggesting natural source
for the uranium. The 235Uj 238U Activity Ratio also suggested a natural source for the uranium in
all wells and surface water sources sampled. However, very few sources were sampled on the
Mill site for this study. In absence of such data, the UMUT EDP has challenged the Site owners
conclusion that there is no possibility of WMM-caused pollution of the wells because of the
distance from the facility.
Both studies suggest potential transient effects in the future. The studies indicate that the
shallow groundwater system is dynamic due to the presence of the wildlife ponds that recharge
the shallow aquifer and that changes in metals concentrations in the wells are likely to
continue to be observed without any leakage from the tailings cells. The presence of CFCs and
the absence of tritium in some waters suggests it takes infiltration water longer than 50 years
to travel through the vadose zone. The system away from wildlife ponds can be considered
recharge-limited and not permeability-limited. Active groundwater flow occurs vertically and
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horizontally, and if leakage from tailing cells occurs in the future, a contaminated plume is
likely to reach the water table.
Recommendations for additional forensic studies:
According to the UMUT EDP, there have been many changes in the site hydrology and
geochemistry since completion of the USGS study (Naftz, 2011). Many new monitoring wells are
in place, the flow system at the site has changed due to cessation of filling the wildlife ponds
and the initiation of corrective action for the nitrate plume, and advances in isotope
geochemical techniques have been made in the last 5 years. It is therefore recommended that:
1) the suggestions made by the USGS after the completion of their study be followed. These
included:
• additional use of uranium isotope ratios to evaluate source of uranium in monitoring
wells, dust and sediments, and
• use of sulfur, hydrogen and oxygen isotope studies of springs, additional wells and
ponds to determine sources of waters samples in wells near the UMUT Reservation such
as MW-22.
2) EFR work with Duke University, the UDEQ and the UMUT EDP to evaluate the use of
additional forensic tracers such as radium, boron and lithium isotopes and metal ratios. The use
of radium isotopes is described in Appendix SB and publications cited therein (see also Bryan et
al. 2012).
Analysis: 2) Dissolution of pyrite and 'natural variability' model.
The Site owners have argued that dissolution of pyrite is the cause for increase in acidity and
metals concentration at monitoring wells. The Site owner has measured iron concentration as
well as pyrite occurrence in a large number of wells in a way that provides some confidence in
their assertion that pyrite is present in sufficient amounts to supply acid to decrease pH and
mobilize metals. The UMUT EDP has based its objection to the 'natural variability model' on the
argument that insufficient oxygen is present in ground water to oxidize the pyrite and that all of
the pyrite in the unsaturated zone has already been oxidized (see Appendix D.)
Recommendations:
Oxygen partial pressure is not the best parameter to characterize the redox potential of an
aquifer. Other redox couples could be measured in the groundwaters and a more site-specific
model for oxidation of pyrite could be proposed. In addition, the sampling strategy used by the
site owner should be described in a way that demonstrates that a statistically valid sample has
been taken. The distribution of pyrite in the vadose and saturated zones could be characterized
more completely. Core samples from the unsaturated zone could be examined to estimate the
distribution of pyrite (and iron oxide). Information about large scale features within the Burro
Canyon that might lead to preferential fast paths should be incorporated into this description.
The Site owner has suggested that the redevelopment of many wells since 2011 leads to
introduction of oxygenated water into the saturated zone and oxidation of the pyrite. The rate
of pyrite oxidation could be limiting factor situation. A kinetic chemical speciation model could
be used to determine if this is a realistic scenario. The role of microbes in pyrite oxidation
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should also be considered since this would increase reaction rates. Several computer codes are
available that for closed system simulations including PHREEQC. It has been suggested
(Nordstrom et al. 2007 ) that the oxygen and sulfate isotope signature of sulfate might be used
to determine if pyrite oxidation is primarily controlled by oxidation by ferric iron from water or
by oxygen from air. Measurement of these isotopes in waters from wells with decreased pH
and comparing the isotopic signature to waters from the tailings cells and to wells where the pH
decline has not been observed might be useful. The utility of this approach will depend on the
relative contributions of sulfate from several sources including dissolution of gypsum as well as
oxidation of pyrite.
Analysis: 3) Procedure used to set Ground Water Compliance limits (GWCL)
The debates over the key indicators and the "natural variability" hypothesis enter the
regulatory sphere through the procedure used to set the Ground Water Compliance Limits for
each monitoring well. The Tribe argues that the GWCL (Ground Water Compliance Level) flow
chart used by the Site and the State to set Compliance Levels for metals at the monitoring wells
is not same as the EPA procedure upon which it is based. Specifically, they claim that it doesn't
have an "off ramp" to force a outcome other than raising the GWCL. Examination of the chart
from ffitefa-INTERA publications (eg. INTERA, �2010) confirms that this is true, however EFR
claims that the flow chart does have an "off ramp" that leads to a CA (Corrective Action).
When an OOC (Out of Compliance) condition happens, the Source Assessment Report is
required and that will lead to the either CA or a change in GWCL.
EFR feels that two accepted lines of evidence are used to justify raising the GWCL: the Utah
isotope study that says there is no leakage from cells and the pyrite oxidation 'natural
variability' hypothesis. The Tribe has argued that insufficient pyrite oxidation could occur to
lower the pH because there is not enough oxygen in the saturated aquifer. EFR argues that the
oxygen in saturated zone waters comes from stressing the wells. When they purge the wells,
the cone of depression allows air to mix with the water. The wells are screened above the
water line.
The State has accepted this as a "reasonable" idea. The main observations that support this
are:
• the decreases in pH are observed site-wide; effects in MW 18 (which is upgradient) and
MW-3 (down-gradient) are the most pronounced. The differences in the observed effect
at different wells might be due to changes in water levels which lead to changes in the
residence times of water along the flow path to the wells.
• the chloride plume is not seen upgradient where the pH is also decreasing.
The Tribe has countered with the following arguments: 1) the trends in pH and metals
concentrations observed in upgradient wells are consistent with the groundwater mound
observed near the Mill and 2) chloride is not a good indicator of leaking tailings cells because it
can be adsorbed by clays in the liners system or bedrock.
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The EFR staff feel the current procedure for setting the GWCLs is too conservative. The State
forces reevaluation of the GWCL every time there is an OOC, whereas the company would like
to have the GWCL revised every five years during license renewal. They would like to use the
calculated temporal trends in pH and metals concentration to calculate the future GWCL that
would be expected at that time. The State does not allow this and forces the company to do a
Source Assessment Report based on the previous GWCL.
Recommendations:
1. It would be useful to review the Ground Water Discharge Permit to see how Corrective
Action is triggered.
2. Although it is generally assumed that chloride is a conservative tracer, a literature review
should be conducted to identify relevant conditions under which this assumption is false.
Past leakage from Legacy of Tailing Cells as indication that the cells are beyond their design
life
In Exhibit H (Smith, 2011) of the Comments Regarding Denison Mines (USA) Corp Radioactive
Materials License Renewal (Hawkins et al. 2011), UMUT EDP presents arguments that the
design of the Legacy cells no longer conforms with current practice and that they have passed
their design life of 30 years. During 2009, a leak was detected in Cell #1, which led to extensive
repairs. The Tribe thinks that this leak was catastrophic and demonstrates that the cell linings
are failing. When the leak occurred, the Mill dropped the liquid levels in the cell and
photographed the damage beneath the liquid level. In the Tribes view, this shows that the cell
lining failed and the damage was not simply due to sunlight exposure. The Tribe asserts that
observed leaks demonstrate that that they leaking routinely, and must be replaced.
The Company has a different story: they feel that the leak detection system, although not as
sophisticated as that in the newer cells (#4a,4b) worked as designed and indicated that there
was (a small volume?) leak at a certain level. The Cell was drained below that level and they
couldn't find the leak so they just replaced a huge section of the liner with new materials. They
then refilled the tailings cell and there was no more leakage.
Because the waste at the site is a byproduct of uranium tailings (lle2 waste), the site will be
closed permanently at some time in the future. The Site Reclamation plan requires that Cell #1
be dug up and material placed in a newer cell for final closure at some time in the future. The
Site owner must clean all contaminated soils and put them in the tailing cells, including dust in
the area from all around the Mill. Then the site becomes a DOE legacy Site with a 1000 year
cover, no active maintenance and is supported by a Perpetual Care Fund.
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2. Could transport of contaminants from leaking tailings cell to perched aquifer be rapid
enough to threaten health of potentially exposed populations?
Review of Revised Infiltration and Contaminant Transport Model (ICTM)
Introduction-The purpose of the Infiltration and Contaminant Transport Model (ICTM)
The ICTM was developed to demonstrate the long-term ability of the tailings cells cover system
to adequately contain and control tailings contaminants and protect the groundwater quality of
the uppermost aquifer. The ICTM was required as part of Groundwater Discharge Permit
application. Specifically, it supported Denison Mines (USA) Corp.'s Ground Water Discharge
Permit (Permit No. UGW370004 revised version dated 20 January 2010).
A brief review of the results and the issues raised in review of the Infiltration and Contaminant
Transport Model are presented below. More details are found in Appendix 6 (Summary of
Issues Raised in Review of the Infiltration and Contaminant Transport Model (ICTM)).
Main Model Results and Issues
1. Model-Predicted Uranium Concentration: Uranium does not reach the bottom of the vadose
zone beneath Cells 2 & 3 during the 240-year transport timeframe. Adsorption of uranium onto
the surface of HFO present in the bedrock vadose zone limits the transport distance below the
liner. The depth at which the uranium concentration is approximately equal to the minimum
GWCL (0.0049 mg/L) is 2.3 meters (8 feet) below the liner system; a minimum of 10.5 meters
(34 feet) above the perched water table. Transport of the following trace elements was
modeled: arsenic, cadmium, copper, nickel, vanadium, and zinc. These solutes were also
predicted to migrate only a few meters below the liner.
2. Sensitivity analysis: Three values for several model parameter were selected for sensitivity
analysis; 3 scenarios-lower bound; base case and upper bound were identified. Input variables
incorporated into the sensitivity analysis included: 1) the source term solution chemistry of the
tailings pore water, 2) the maximum tailings saturated thickness during operations, 3) the
number of potential liner defects, 4) the acid neutralization potential of the bedrock (ANP)
vadose zone, and 4) the partial pressure of carbon dioxide gas within the bedrock vadose zone.
For the upper bound scenario the depth at which uranium approximately equaled the
minimum GWCL was 3.9 meters (compared to the base case of 2.3 meters) ..
3. Conservative nature of model assumptions: Many of the model assumptions can be
considered conservative in that they would tend to lead to overestimation of the transport of
uranium. These include:, 1) failure to include precipitation of gypsum and iron oxyhydroxides
as potential sinks for uranium, and 2) low estimates of the hydraulic head in the tailing cells.
The Site owner claims that the failure to include the presence of naturally occurring uranium or
other competing solutes in the aquifer is also a conservative assumption but doesn't explain
why this is so.
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Review by DRC
URS Professional Solutions reviewed the ICTM under contract to the Utah DEQ and requested
additional information, changes or corrections to a large number of items in the model report
(Round !Interrogatory). These issues were divided into the following topic areas: 1)
inconsistencies between the model and the revised reclamation plan, 2) comparisons of the
cover designs, sensitivity analysis, bathtub analysis, and radon emanation modeling, 3)
moisture storage capacity of the cover, 4) evaluation of flow through the tailing cell liners, and
5) contaminant transport modeling.
The responses by EFR to these requests are not available at this time. However, the URS review
appears to raise reasonable questions about the long term stability of the cover design
proposed by EFR. None of these questions, however, would appear to be fatal flaws in the
design and it is likely that EFR and the Utah DEQ will be able to reach an agreement on how to
satisfy these questions. Questions about the bathtub analysis involved detailed discussions of
geomechanics that are outside the scope of this work and are not discussed further. Similarly,
questions concerning the reclamation plan such as types, amounts, sources, methods of
application, estimated cost, and limitation of potential soil amendments are outside the scope
of this review. URS requests additional sensitivity calculations to bracket a wider range of
parameters used to evaluate flow through the tailings cell liners. Although this subject is
outside the scope of this reviewer's expertise, such calculations do not seem to be
unreasonable. Finally, the URS review requests additional data from new well bores to better
characterize the potential occurrence and distribution of fractures and on some on cemented
higher permeability intervals along the flow path from the potentially leaking tailing cell and the
aquifer. In addition, the reviewers request corrections to the statistics for two important
geochemical parameter ranges, namely the amount of hydrous ferric oxide and the acid
neutralization potential. The request to correct these ranges and new calculations for the
purpose of sensitivity analysis also seen reasonable. A full description of these issues is
contained in Appendix 6 (Outline and Summary of Issues in Review of the Revised Infiltration
and Contaminant Transport Model).
Review by UMUT (Geoi-Logicl
Although not directly reviewed in the Geo-Logic report, that report appears to take exception
with the acid neutralizing potential and sorption potential of rocks assumed in the model that
are present along the flow path to buffer the pH and to absorb uranium and other metals
should they be released from the tailing cells. In addition, although the ICTM is a one­
dimensional reactive transport model that only addresses transport from the tailings cell down
to the aquifer, the questions that both Geo-logic and Utah Department of Environmental
Quality raise are relevant to the question that appear to be most important, i.e. down gradient
migration of tailings cells contamination that could ultimately reach the UMUT Reservation.
Current relevance of the ICTM in regulations:
During the Site visit on December 1, the purpose and relevance of the ICTM for long term
performance was clarified. This model was specifically used In support of covl:!r tll:!sign <Hitl is
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not expected to predict site wide contamination. The 200 year modeling duration was chosen
to be consistent with the Atomic Energy Act Appendix A for tailings which require 200 year
minimum life but a 1000 year design life. The discussions with the State have moved beyond
discussions of the model because EFR has started a real test in Cell #2, which is in the first
phase of reclamation. A test section has been installed to see if the cover cross section is
performing as expected at Cell #2. There is a document in progress that describes this and it
should be released within one month. Previously, the Tribe expressed concern that the
assumptions of the pyrite oxidation model and the acid neutralization potential (ANP) that is
implicitly assumed in the ICTM are not consistent. EFR said that there is no reason for the ANP
to be consistent with the pyrite oxidation model because the ICTM calculations focused on the
unsaturated zone and the pyrite model focuses on the saturated zone
Recommendations
Although not designed for examination of contaminant plume development at the site, the
ICTM provides a framework for additional sensitivity analyses that could address many of the
concerns raised by both the Utah Department of Environmental Quality and the UMUT EDP.
This could be accomplished by using the model to investigate other potential flow paths that
would lead to more rapid down gradient transport of contaminants, a wider range of values for
the acid neutralizing potential and sorption capacity in the vadose zone and saturated zone,
representations of more conservative puncture models for the tailing cells liner as well as the
practicality of using other tracers as early indicators of leakage from the tailing cells.
Retardation of uranium and other contaminants of concern along potential flow paths from a
leaking tailings cell to the perched aquifer depends on aqueous speciation as well as
mineralogical content along the flow path. The information obtained in the pyrite and iron
oxide distribution studies described above should be examined to see if a model for distribution
of iron oxides can be constructed. Although the contractor to the Site owner assumed a certain
amount of iron oxide in their contaminant transport model, it was unclear if the concentration
was varied over a wide enough range in a sensitivity analysis. Examination of the input files
from the simulations would answer this question. In addition, it was argued that the presence
of bicarbonate complexes of uranium will drastically reduce the amount of potential sorption
onto clay and iron oxide surfaces. However, it has been demonstrated that these complexes
can sorb by specific sorption mechanisms such as inner-sphere complexes (Park et al., 1995).
Additional reactive transport simulations could be run which include additional sorbing species
and different concentrations of iron oxide sorption and clay iron exchange sites.
Additional confidence in the models of potential contaminant transport from the tailing cells to
the accessible environment could be obtained by using 2-D or 3-D transport models. Other
types of parametric sensitivity analyses could be carried out. For example, the retardation
factors consistent with a fractured dominated rock could be calculated and compared to those
with the current porous media assumption. These calculations would use a range of HFO
concentrations and additional sorhing urt�nyl .�rP.dP.s to r.;�lr.uliltP. effective Kds and alternate
models for retardation factors with variable assumptions about fracture surface area. The
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current modeling efforts should be continued to address the worst-case scenarios that are
proposed by the Tribe.
3. Could a multicontaminant plume persist in the environment for many generations,
constituting an incalculable risk?
If the model assumptions are correct and all processes are correctly represented , then the
ICTM calculations suggest that it is unlikely that such a plume will reach potentially exposed
populations within 240 years. However, the long term fate of such a plume as not been
established by the ICTM mode. The controversy around these results is similar to that present
for other contaminated surrounding DOE facilities or potentially contaminated sites around
proposed uranium mine sites. One approach to address the risk that might be present after
cleanup of such sites or to minimize future risks at proposed mine sites is through Monitored
Natural Attenuation (MNA). As originally defined by the USEPA (1999), MNA is:
" ... [t]he reliance on natural attenuation processes (within the context of a carefully controlled
and monitored site cleanup approach) to achieve site-specific remediation objectives within a
time frame that is reasonable compared to that offered by other more active methods. The
'n atural attenuation processes' that are at work in such a remediation approach include a
variety of physical, chemical, or biological processes that, under fa vorable conditions, act
without human intervention to reduce the mass, toxicity, mobility, volume, or concentration of
contaminants in soil or groundwater. Th ese in-situ processes include biodegradation; dispersion;
dilution; sorption; volatilization; radioactive decay; and chemical or biological stabilization,
transformation, or destruction of contaminants." (EPA 1999, page 3}
For inorganic constituents present at White Mesa, the most potentially important processes
include dispersion and immobilization (reversible and irreversible sorption, coprecipitation, and
precipitation.) Determining the existence and demonstrating the irreversibility of these
mechanisms are key components of a sufficiently protective monitored natural attenuation
remedy. The USEPA has published guidelines for the use of Monitored Natural Attenuation
(MNA) for a variety of contaminated sites (US EPA OSWER Directive 9200.4-17, 1997; USEPA,
2015).
Primary attenuation pathways for uranium are dilution and sorption, typically by iron
oxyhydroxides, however, other mineral phases can adsorb uranium. Uranium-contaminated
soils from surficial aquifers at two UMTRA sites (Riverton, Wyoming and Monticello, Utah) were
subjected to a series of selective extractions to determine the host mineral for uranium. In the
Riverton soils, about 14% of the uranium was associated with the poorly crystalline Mn-Fe
oxyhyroxides. The general order of U association was: refractory minerals > carbonates >
poorly crystalline Mn-Fe oxyhydroxides »crystalline Mn-Fe oxyhydroxides »readily
exchangeable surface sites. In contrast, at Monticello, the bulk of the uranium was associated
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with crystalline Mn-Fe-oxyhyroxides (15-60%) and carbonates (20-45%). (Bryan and Siegel,
1997)
Jove-Colon et al (2001) attempt to draw some general conclusion about limits to groundwater
migration of uranium in various hydro lithologies by summarizing the size of plumes at uranium
mill tailing sites . A variety of sources are considered including natural analogue, in situ
uranium leaching sites, and UMTRA Title I and Title II milling sites. The authors conclude that
most plumes (defined at the 20-40 ppb concentration isopleth) are less than 2 km in extent.
Although the estimates of plume extent are very inexact and the time periods are either very
short or very long and may not be relevant to MNA, the report contains information from and
references to over 30 case histories of uranium migration.
Recommendation
A MNA evaluation similar to that required by the EPA directives should be considered for
scenarios relevant to White Mesa. The MNA approach is a tiered process as follows (USEPA,
2015, page 26):
• Phase 1: Demonstration that the groundwater plume is not expanding.
• Phase II: Determination that the mechanism and rate of the attenuation process are
sufficient.
• Phase Ill: Determination that the capacity of the aquifer is sufficient to attenuate the
mass of contaminant within the plume and the stability of the immobilized contaminant
is sufficient to resist re-mobilization.
• Phase IV: Design of a performance monitoring program based on an understanding of
the mechanism of the attenuation process, and establishment of contingency remedies
tailored to site-specific characteristics. This phase in effect reflects recommendations in
the 1999 MNA guidance, but consolidated into a single, additional phase.
The heart of the MNA approach is the monitoring program. The goals of the programs are to
(USEPA, 2015, page 15):
• Demonstrate that natural attenuation is occurring according to expectations;
• Detect changes in environmental conditions (e.g., hydrogeologic, geochemical,
microbiological or other changes) that may reduce the efficacy of any of the natural
attenuation processes [footnote in original deleted];
• Identify any potentially toxic and/or mobile transformation products;
• Verify that the plume(s) is not expanding (either downgradient, laterally or vertically);
• Verify no unacceptable impact to downgradient receptors;
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• Detect new releases of contaminants to the environment that could impact the
effectiveness of the natural attenuation remedy;
• Demonstrate the efficacy of institutional controls that were put in place to protect
potential receptors; and
• Verify attainment of remediation objectives.
Although there is not a one-to-one correspondence between the MNA approach for DOE
contaminated sites and potential contamination of White Mesa, many of the elements of the
two sites are similar and the use of an accepted approach to guaranteeing the safety of
potentially exposed populations might provide assurance to the Tribe (see also Davis et al,
2011).
4. What is tire importance of airborne releases of radionuclides and deposition on plants
to overall radiological dose to tire population in the area?
There are 2 areas of concern with respect to air quality: 1) transport of dust particles produced
from the tailings transported to the site and as they are stored on pads at the site and 2) radon
release from tailing cells and transport to surrounding populations. The material that is shipped
to the mill for reprocessing comes in a variety of forms including uranium mill tailings, residues
from treatment plants, and other radioactive waste forms. Of particular concern is the dust and
fine particulates associated with the uranium mill tailings. These are shipped in large trucks
along the highway and until three years ago the ore was not covered. This material will sit on
pads at the facility until sufficient amount is received to justify operating the mill. There is
evidence collected by the USGS and the Tribe suggesting that uranium-containing dust is blown
from the mill to the surrounding area. Relatively high concentrations of uranium and vanadium
have been measured in soils, or water, and plants that lie along dominant wind paths and in the
ephemeral stream drainage basins that are connected to entrance Springs and several
monitoring wells (Naftz et al, 2011).
Analysis: Studies of uranium concentrations in sediments and plants
The USGS study (Nafatz et al. 2011) suggests that elevated uranium concentrations in Entrance
Springs may be the result of contamination by uranium/vanadium rich dust blown from either
the Mill pads or trucks delivering ore to the facility. This possibility is based on similarities in the
634Sulfate values in water samples from the wildlife ponds and the tailings cells and the fact
that Entrance Spring has high U concentrations and a relatively low 234U/238U Activity Ratio,
reflecting mixing with aerosols from the ore pads. In addition, oxygen and hydrogen isotopes of
water samples collected from Entrance Spring lie on an evaporative enrichment line relative to
water from Recapture Reservoir, which is the source of water for Mill operations.
Geochemical analyses of sediments in the area also support this hypothesis. Concentrations of
uranium and 41 other chemical constituents were measured in stream sediments collected by
the USGS from 28 sites in the ephemeral-stream channels draining the White Mesa mill.
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Elevated-U concentration (greater than estimated background concentrations of 1.8 to 3.6
ppm) were found in 7 sediment samples in three ephemeral drainages east of the eastern mill
boundary. In general, this area is downwind from the uncovered ore materials that are
stockpiled at the mill and are in the same general area as Entrance Spring. A sample (WM2-
S21) located approximately 1.2 km south of the mill site in an ephemeral drainage originating
within the mill boundaries, contained the highest U concentration (greater than 16 ppm)
measured in any of the sediment samples. Uranium concentrations at 20 other sites were
lower than the estimated background concentration.
Principal component analysis (PCA) was applied to the full data set of 41 analytes measured in
the 28 sediment sites. Three factors accounted for 76% of the variance in data set. One of the
factors characterized by relatively higher concentrations of Mo, As, S, Se, U, W, and Sb, was
proposed to represent contributions of U-ore material contained within the White Mesa mill
site. The locations of the six samples with high ore-migration scores are located primarily in the
ephemeral drainages directly east of the mill site, i.e. the same areas with elevated-U
concentrations in the ephemeral drainage watersheds. Tissue samples were collected from big
sagebrush in areas surrounding the White Mesa Mill site; elevated concentrations of U and V
were found in samples collected north-northeast, east, and south of the mill site, consistent
with offsite eolian transport in predominant wind directions. Appendix SA provides more
details of the results of the forensic studies.
There were some disagreement between the Utah DEQ and the UMUT EPD about
environmental air quality monitoring at the facility prior to relicensing. These include :
• High volume PM10 samples without speciation for radionuclides leading to
underestimation of radiological risk,
• Location of a "background" monitoring station to west of the Mesa that was not really
background location and then basing the reporting on flawed "background levels",
• Different operating procedures: the Utah DEQ monitors 24/7 and then pulls the filter for
analysis whereas the Tribe monitors for shorter periods. The Tribe does this because
they feel that the monitors are delicate and if loaded up too high with dust they will bog
down and not collect dust correctly (i.e. the motors burn out). Even though the Utah
DEQ QA procedure mandates replacement, the measurements are flawed according the
Tribe.
The Tribe feels that their position is supported by the results of the 2011 USGS study. That
study found a pattern of radionuclide migration to NE as indicated by elevated U and V
concentrations, however, the EFR air monitoring program didn't pick up this pattern (next to
ore pad, next to drying ovens) This is a likely source so the Tribe has doubts about the EFR
monitoring system. The Mill stockpiles multiple piles from diffe rent ores on the pad and
according to the Tribe they don't control the dust adequately. EFR has said the required
opacity measurements were enough to protect the environment but anecdotally, Tribal
members see plumes of dust from the ore pad. Finally, the existing Minor source Air Quality
Permit doesn't include all members of the radiological decay chain so the Tribe thinks the actual
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radiological risk is underestimated. This can only be addressed by modifying the definition of
the Source in the Permit.
EFR argues that the contamination is likely from historic operations not associated with current
Mill activity. Specifically, some dust probably comes from the Plateau Buying Station which was
a uranium ore buying station in the late 1970s. This was located north of the Mill site; by
current standards, this was not a well-regulated operation and could have led to dust pollution.
The high uranium in the sediments to the south of the site might be from ore from the
Cottonwood Mine that was transported along the road by the facility in the 1950 before the
county road was rerouted to its current location.
With respect to current sampling procedures, EFR says that their high volume dust monitors
are running at least 75% of the time each quarter according to regulations. In fact, they run
90% of the time as shown by their maintenance records. The maximum downtime at a
monitoring site would be six days according to their SOP.
Analysis: Radon Releases from Tailings Cells Cells #2 and #3
There are several issues related to radon releases from the tailings cells:
1) Reports of radon emissions greater that 20 pCi/m3 led to attempts to accelerate closure and
drying of Cell #2 by pumping slimes to Cell#3. This has resulted in higher releases of radon from
Cell#3 which exceed the 20 pCi release standard. EFR reports that averaged radon releases
from Cell#2 are below the Standard but UMUT EPD and Grand Canyon Trust challenge the way
the averages were calculated (mixing old and new data).
2) Radon emissions from Cells #4a,b are also in dispute. EFR has argued that the liquid barrier
covering the tailings reduces radon releases to essentially zero, therefore there is no need to
monitor Rn flux. UMUT EPD argues that because the cell contains significant amounts of
radium, emissions are much higher according to their conservative calculations. Additionally,
UMUT EPD argues that routine radium measurements are easy to make (based on common In
Situ Recovery industry operations) , and should be done in the liquid.
3) The Tribe, Energy fuels and the USEPA are in discussions about regulations concerning radon
emissions. The Tribe has been concerned that potential changes to NESHAP will affect
monitoring requirements for radon emissions from the tailing cells. In 2008, the EPA examined
potential amendments to the rule at the request of several NGOs. At the heart of the dispute is
whether solutions in tailing cells should be monitored routinely for radon emission.
The Tribe's model for radon emissions from evaporation ponds at the Mill indicates that
emissions are in excess of regulatory limits. Energy Fuels measurements, however, do not
show any exceedances at the perimeters of the tailings, with the exception of one cell (Cell #3)
that exceeded the Standard and currently is monitored on a monthly basis. A cover has been
added to reduce radon emissions, which are likely due to dewatering of the solids; EFR expects
that these exceedances will be only temporary.
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In Energy Fuels Resource's view, the Tribe inappropriately applied the radon model of Cohen
and Associates (Cohen, 2010). This model calculates radon emissions as a function of the
concentration of radium-226 and wave action for a liquid evaporation pond. The Tribe used
published gross alpha measurements instead of the radium measurements and wind action
data from a local (off-site) meteorology station. These two assumptions led to overestimates of
the radon emission for the following two reasons: 1) gross alpha radioactivity is not a good
proxy for radium activity in the acidic solutions in the tailing cells; most of the activity is due to
thorium-230, and 2) the model is not appropriate for the high viscosity solutions in the tailing
cell. In addition, EFR argues that the wind action predicted by the meteorology station is not a
good indicator for local conditions which tend to be more quiet than those at the station. The
wind velocity at the tailings cells is much lower than that measured at the wind monitoring
station which is a tower 1 meter tall. In addition, that location is 15 m above the tailing cell
surface. Even when there is a breeze at that elevation, the surface of the tailing cells is like a
"mirror".
Recommendations:
Many aspects of this topic are beyond the scope of the current contract and the core
competencies of LJS Consulting, Inc., therefore, only a few recommendations can be made. As
discussed above (Appendix SA, Review of Geochemical Forensic Studies of Ground Waters), it
has been proposed that additional isotopic studies using radium isotope s be initiated in
collaboration with Duke University. These can include analysis of dust samples from the air
quality monitoring stations to determine the source of the radiological components of the dust.
The Tribe's concerns about wind borne contamination could be addressed by better monitoring
of radon sources and wind velocity by:
• placing a Rn monitor at the cells and not at the Site perim�ter
• measuring Ra in the tailings so that Cohen's equation can be verified or applied to the
tailings solution.
• measuring wind velocity at the tailings pond to obtain more relevant wind velocities,
• doing an activity exposure assessment to see if dust is a problem when people are on
the reservation land, and
• doing exposure assessment that includes all pathways that could be important.
A potential hazard might be indicated by odors detected by residents .. When the wind shifts in
the evening, area residents say they can smell the acid tailings. EFR acknowledged this but did
not think it was health hazard; people were smelling organics from mill. These emissions needs
to be evaluated for potential health effects.
Es tablishing Trust Among Stakeholders: Application of the DOE ITRD Process
The White Mesa Mill site is characterized by complex site hydrogeology, poorly documented
pre-mill activities, a complex nature of the materials managed by the Site, lack of trust among
some of the stakeholders, cultural perspectives that impact the priorities of the Stakeholders
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and limited funding. As evidenced by the numerous Requests for Agency Actions (RAA) filed by
the UMUT EDP, it is clear that there is no simple way to resolve the areas of uncertainty and
satisfy the concerns of the Tribe with respect the long-term risk posed by the Mill facility.
There is a large number of complex technical issues that are important and a team of experts
would be required to provide a comprehensive evaluation of these issues. This situation is
similar to that found at many of the Legacy Sites within the DOE Complex. The Innovative
Treatment and Remediation Demonstration (ITRD) Program was initiated in 1993 by the DOE in
cooperation with the Environmental Protection Agency's Technology Innovation Office to
accelerate the implementation of innovative remediation technologies at these sites. The ITRD
Program was based on a public-private technology demonstration concept that improved
communications and teamwork among key participants. Government, industry, and regulatory
agencies were directly involved in assessing, implementing, and evaluating technologies.
The first step in the process is to establish a Technical Advisory Group (TAG) with participants
from site-specific government, industry, regulatory, and stakeholder groups, as well as technical
experts (in site specific conditions as well as potential remediation technologies). This
partnership allows a focused effort to define the problem, to identify paths to reach restoration
solutions and to provide resources to assess innovative approaches that need further
evaluation. Finding acceptable solutions that meet institutional, regulatory, public, and
technical requirements requires a team approach to address the many issues and tradeoffs that
arise in the search for the most optimal solution. The TAG performs this work through
meetings, conference calls, and individual efforts to explore particular issues.
Recommendations from the TAG are presented to DOE for implementation.
ITRD projects included sites with complex industrial soil and ground water contamination
problems. Contaminants at such sites include chlorinated solvents and petroleum products;
pesticides, polychlorinated biphenyls (PCBs), and dioxins; heavy metals; explosives; and
radionuclides. The program was very successful during the period 1999 to 2002. During
FY2000, for example, ITRD projects were carried out at several DOE facilities including the
Paducah Gaseous Diffusion Plant, the Oak Ridge Y-12 Plant, the Hanford Site, the Pantex Plant,
the Mound Plant, and Los Alamos National Laboratories. (Kelley et al. 2002; Siegel et al. 2003).
The projects involved initial screening of 30+ technologies to remediate contaminated soils and
groundwater, detailed evaluation of 12 different technologies, and planning or execution of
several pilot deployments. Active source removal, passive barriers, bioremediation and
monitored natural attenuation were evaluated for remediation of chlorinated solvents
(dissolved and DNAPL), explosives and radionuclides.
Summary: Activities to Reduce Uncertainty and Risk- a graded
approach
Due to the limited resources allocated for this project, only a preliminary understanding of all
the complex issues has been obtained by this contractor. The focus of this work has been Lo
obtain an overall understanding of the relationships among important technical and regulatory
23
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
issues and to make some preliminary recommendations on how to resolve some of the
disagreements among the stakeholders. The product of this current contract is not a list of
'magic bullets' to resolve these issues but rather it is to identify areas of uncertainty important
to the assessment and management of the risks associated with the operation of the White
Mesa Mill.
Based on reviews of documents supplied to LJS Consulting, Inc and discussions with staff from
the UMUT EDP, the UDEQ and Energy Fuels, several areas of technical uncertainty have been
identified and classified according the level of effort that would be required to resolve them.
These recommendations might change if additional reports are supplied to LJS Consulting, Inc in
the future. The recommendations are classified as:
• Level A: Issues that might be addressed with review of additional existing documents,
• Level B: Issues that might be addressed with additional modeling or new data analysis,
• Level C: Issues that might be addressed with collection of new data and analysis of
these data,
• Level D: Questions that are unlikely to be answered without significant expenditure of
resources that may be beyond the scope of the stakeholders or that may never be
answered due to irreducible uncertainties.
Level A: Issues that might be addressed with additional review of existing documents,
• Evaluation of application of Cohen and Associates model for radon emission from liquid
tailings cells.
• Review of the PHREEQC calculations done in the ICTM to evaluate the adequacy of the
sensitivity analyses, conservatisms of model assumptions and whether sufficient data
has been obtained to support a representative model of the site.
• Detailed review of Geo-Logic model for alternative hypothesis for natural variability.
This would include independent modeling using PHREEQC to determine if pyrite
dissolution can be occurring and caused the pH changes when using reasonable ANP
estimates.
Level B: Issues that might be addressed with additional modeling or new data analysis,
• Additional modeling -look at alternative conceptual models for the Integrated
Contaminant Transport Model:
o evaluate potential role of transport in fracture by parametric sensitivity analysis,
o conduct sensitivity analysis with reactive transport model,
o use additional geochemical data for both solutes and solids,
o run simulations for more than 200 yr.
Level C: Issues that might be addressed with collection of new data and analysis of this data,
• Completing the analysis of potential role of pyrite oxidation as a cause of pH decreases
and metal concentration increases in monitoring well by measuring additional redox
couples in groundwater and more fully characterizing pyrite and iron oxide occurrences
1n the unsaturated zone.
24
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
• Additional modeling with HP-1 using multiple alternative interpretations of data
obtained through geostatistical analysis of hydrological and mineral occurrence data.
• Addressing concerns about wind borne contamination by better monitoring of radon
sources and wind velocity.
• Determining the potential for using a Monitored Natural Attenuation approach at the
site.
• Proceeding with the installation of 3 new wells as suggested by EFR to be placed in the
perched zone to characterize groundwater flow and direction in the area southeast of
MW-17 , between MW-17 and MW-22.
• Doing an activity exposure assessment to see if dust is a radiological exposure problem
when people are on the reservation land.
• Doing an exposure assessment that includes all pathways that could be important to
human health. Including the estimated exposures in a complete health risk assessment
including doses-response relationships for contaminants of concern.
• Addressing UMUT EDP concerns about Mill work practices:
o water sampling-doing a verification exercise
o air monitor sampling -comparing the different SOWs used to industry standards
• Consider additional tracers for setting Ground Water Compliance Limits
o doing a scoping analysis of other potential tracers to evaluate their usefulness
relative to chloride.
o Evaluate using additional forensic isotopes and trace metals.
• Formulating a hydrological model that includes transient effects related to the draining
of the wildlife ponds, effects of ongoing remediation efforts and provides information to
the Tribe that addresses concerns about placement of new tailings cells close to the Site
Boundary in the future.
Level D: Questions that are unlikely to be answered without expenditure of resources
beyond the scope of the stakeholders or that may never be answered due to irreducible
uncertainties.
• Why do we think that the old tailing cells are still sound, years after their design life?
• How do we know cells are not leaking if the leak detection systems (LOS) are not
adequate?
• Prediction of the long term transport of contaminants from the tailing cells over time
periods that are consistent with cultural beliefs of the Ute Tribe.
Finally, it is suggested that the Stakeholders at White Mesa consider using the method
developed by DOE's Innovative Technology and Remediation Development program to
establish a consensus about what additional steps are needed to be taken to evaluate potential
leaks and off-site transport of radionuclides. In this effort, the Bureau of Indian Affairs might be
considered a neutral party that can do mediation. In this analysis, the participants would focus
25
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
on human health risk, consider importance of cultural issues, and introduce new technologies
when really relevant and cost effective.
26
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
LIMITATIONS STATEMENT
The opinions and recommendations presented in this report are based upon the scope of
services and information obtained through the performance of the services, as agreed upon by
US Consulting, Inc. and the party for whom this report was originally prepared. Results of any
inv�stigations, tests, or findings presented in this report apply solely to conditions existing at
the time LJS Consulting, Inc's investigative work was performed and are inherently based on
and limited to the data provided to LJS Consulting, Inc by that party and the limited resources
of the investigation activities as defined by the contract (labor hours and hourly rate). No
representation, warranty, or guarantee, express or implied, is intended or given. LJS Consulting,
Inc makes no representation as to the accuracy or completeness of any information provided by
other parties not under contract to LJS Consulting, Inc. to the extent that US Consulting, Inc.
relied upon that information. This report is expressly for the sole and exclusive use of the party
for whom this report was originally prepared and for the particular purpose that it was
intended. Reuse of this report, or any portion thereof, for other than its intended purpose, or if
modified, or if used by third parties, shall be at the sole risk of the user.
27
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
References:
Bryan, C. and Siegel, M. D., 1998. "Irreversible Adsorption of Uranium onto Iron Oxides: A
Mechanism for Natural Attenuation at Uranium-Contaminated Sites?" Proceedings of
Contaminated Soils and Groundwater-Analysis, Fate, Environmental qnd Public Health Effects,
March 8-12, 1998, Oxnard, CA.
Bryan, C.R., Siegel, M.D., Vinson, D.S., Vengosh, A., Raanan, H., and Dwyer, G.S., 2012. Use of
Radium isotopes to evaluate Uranium and Radium Sources and Behavior in New Mexico
Groundwaters: Examples from Three Sites, abstract Geological Society of America Rocky
Mountain Section Annual meeting, Albuquerque, NM, May 9 -12, 2012.
Davis, P., Heikoop, J. Longmire, P., Siegel, M. and Simmons,A., 2009. Uncertainties in the Ability
of Natural Attenuation to Reduce Uranium Migration from In Situ Uranium Recovery
Fields. SAND2009-0622 P. Sandia National Laboratories, Albuquerque, NM.
Cohen and Associates, 2010. Risk Assessment revision fo r 40 CFR Part 61 Subpart W-Radon
Emissions from Operating Mill Tailings, Task 5-Radon Emissions from Evaporation Ponds,
Letter Report for US EPA November 9, 2010.
EPA. 1999. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and
Underground Storage Tank Sites. OSWER Directive 9200.4-17P, Office of Solid Waste and
Emergency Response, Washington DC. (www.epa.gov/swerustl/directiv/d9200417.pdf)
EPA's 3-volume Monitored Natural Attenuation of Inorganic Contaminants in Ground Water;
http://www.epa .gov/n rmrl/pubs/600r10093/600r10093.pdf
Hawkins et al. 2011. Comments Regarding Denison Mines (USA) Corp. Radioactive Materials
License Renewal DRC-045. Letter to R. Lundberg, December 16, 2011.
Hightower M., Kuzio, K.A. Cheng W.and Siegel, M. D., 2001. Paducah Groundwater Project
Innovative Technology Review, SAND2001-1684P, Sandia National Laboratories, Albuquerque,
NM.
Hurst, T.G., and Solomon, O.K., 2008, Summary of work completed, data results, interpretations
and recommendations for the July 2007 sampling event at the Denison Mines, USA, White
Mesa Uranium Mill near Blanding, Utah.
INTERA. 2010. Background Groundwater Quality Report for Wells MW-20 and MW-22 for
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, INTERA, Inc. Report
dated June 1, 2010.
28
A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
ITRC (Interstate Technology & Regulatory Council). 2010. Attenuation Processes for Metals and
Radionuclides. APMR-1, Washington, D.C.: Interstate Technology & Regulatory Council,
Attenuation Processes for Metals and Radionuclides Team. www.itrcweb.org.
Jove-Colon, C .. Brady, P. V, Siegel, M.D., and Lindgren, E. R., 2001. "Historical Case Analysis of
Uranium Plume Migration", Soil and Sediment Contamination 10-1:71-115.
Kelley, M., Maffit, L., McClellan, Y., Siegel M.D. and Williams, C.V., 2002. Hanford 100-N Area
Remediation Options Evaluation Summary Report, SAND2002-1910P, Sandia National
Laboratories, Albuquerque, N M.
Naftz, D.L., Ranalli, A.J., Rowland, R.C., and Marston, T.M., 2011, Assessment of Potential
Migration of Radionuclides and Trace Elements from the White Mesa Uranium Mill to the Ute
Mountain Ute Reservation and Surrounding Areas, Southeastern Utah: U.S. Geological Survey
Science Investigations Report 2011-5231.
Nordstrom, O.K., Wright, W.G., M. Mast, M.A., Bove, D.J. and R.O. Rye (2007) Aqueous-Sulfate
Stable Isotopes-A Study of Mining-Affected and Undisturbed Acidic Drainage. Chapter EB of
Integrated Investigations of Environmental Effects of Historical Mining in the Animas River
Watershed, San Juan County, Colorado. Edited by S. E. Church, P. von Guerard, and S. E. Finger,
Professional Paper 1651, U.S. Geological Survey.
Park, S. W., Leckie, J. 0., and Siegel, M.D., 1995. Surface Complexation Modeling of Uranyl
Adsorption an Corrensite from the Waste Isolation Pilot Plant Site, SA ND90-7084, Sandia
National Laboratories, Albuquerque, NM.
Siegel, M.D., Cheng, W. C., and Krstich, M., 2003. Hanford 200 West Area DNAPL
Characterization Technology Review, SAND2003-0271P, Sandia National Laboratories,
Albuquerque, NM.
Smith, M. 2011. Letter Report Dated December 1, 2011 by RRD International Corp , Review of
Containment and Closure Issues, Denison USA/White Mesa Uranium Mill Relicensing
Application, Revision 5.0, Sept 2011. (Exhibit H in Hawkins, 2011).
Figures
Figure 1. Roadmap Level l
Figure 2a - 2c. Flow Charts for Modification of Ground Water Compliance Limits
Tables
Table 1. Level l documents which include the Requests for Agency Action that have been filed
by the Tribe.
Table 2. Exhibits for the RAAs concerning the Nitrogen Corrective Action Plan
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A16PX00696 White Mesa Mill Report-LJS Consulting, Inc., Task 5 Report
Table 3. Exhibits for Approval Order of March 3, 2011
Table 4. Author, recipient, main points and important references cited by the Exhibits to the
UMUT Comments Letter on Radioactive License Renewal Application.
Appendices
Appendix 1. Outline of UMUT EDP Searchable Comments Letter
Appendix 2: Roadmap of Groundwater Discharge Permit and ICTM Documents
Appendix 3. Roadmap of Documents Dealing with pH and Pyrite Dissolution
Appendix 4. Tailings Cells Reports
Appendix SA. Summary of Geochemical Forensic Studies at White Mesa
Appendix SB. Introduction to Use of Uranium and Radium Isotopes in Geochemical Forensic
Studies
Appendix 6. Summary of Issues Raised in Review of Revised ICTM
Appendix A. Teleconference Discussion with UMUT EDP July 21, 2016
Appendix B. US Consulting White Mesa Trip Report Sept 22 2016
Appendix C. Teleconference with EFR Staff on October 14, 2016
Appendix D. Review of Geo-Logic Report of August 2015
Appendix E. Trip Report: Meetings with staff from Ute Mountain Ute Tribe Environmental
Programs Department, November 30, 2016, Towaoc, CO, and Site Visit White Mesa Uranium
Mill and Meetings with Staff of Energy Fuels Resources (USA) Inc., December 1, 2016, White
Mesa, UT.
30
APPENDIX 58
Introduction to Use of Uranium and Radium Isotopes in Geochemical Forensic Studies
(abstracted from Bryan, C., Siegel. MD, and Heikoop, J., 2011.
Uranium and radium isotope activity ratios provide a useful tool for establishing the provenance
(source) of groundwater contamination. Moreover, even in areas where elevated concentrations of
these elements are naturally occurring, the activity ratios can provide information about the source
lithologies and hydrologic conditions, and potentially aid in establishing a treatment strategy. As mines
and tailings dumps are generally located in areas with elevated background levels of the metals being
mined, accurately distinguishing metals released due to mining from natural occurrences of these
metals can be difficult using only contaminant concentration values and conventional groundwater
geochemistry. Large volume mining and milling residues contain about 85% of the radioactivity ofthe
unprocessed uranium ore, primarily in the form of U radioisotopes, 230Th, Ra (226Ra and 222Ra), Rn
isotopes, and short-lived radioactive daughters further down the uranium decay chains.
Naturally occurring uranium consists dominantly of two isotopes, 238U (99.3%) and 235U (0.7%). These
isotopes undergo radioactive decay through a series of intermediate daughters to 206Pb and 207Pb,
respectively. Similarly, 232Th decays to 208Pb. Although 235U and 238U genera lly occur in nearly the same
proportion in nature, a third isotope, 234U, is produced as part of the 238U decay chain and its
concentration can vary greatly relative to the oth.er isotopes. Moreover, there are four different
isotopes of radium e23Ra, 224Ra, 226Ra, and 228Ra) that are produced in the 238U, 235U, and 232Th decay
chains, and the relative concentrations of these can vary greatly because of the differing chemistry of
their parents in the decay chains and also because of their widely varying half-lives. Some radium
isotopes have very short half-lives, making them useful in determining whether the parent isotopes are
coming from local sources or are being released from a distance source.
Within an undisturbed sample, after several half-lives of the longest-lived intermediate daughter, a
radioactive parent and its unstable daughters will reach secular equilibrium; the contribution of each
nuclide to the total activity will be the same. In naturally-occurring rocks, the absolute concentrations of
elements in the decay chains vary because of the variations in the half-lives, but the daughters in a given
decay chain are usua lly close to secular equilibrium. However, in groundwater systems, there are
commonly large differences in the activity levels of the parents and daughters in a decay chain. The
major reason for the difference in activities is the different elemental chemistry of Ra, U and Th (for
example, the much higher solubility of Ra than U, or the different redox-sensitive adsorption behavior of
U and Ra).
In general, concentrations of the daughters in a decay chain can vary by orders of magnitude and
isotopic ratios can cover a huge span. However, the activities of all the radionuclides in a decay chain
will be the same if secular equilibrium exists; therefore, it is convenient to compare the activities of the
radio nuclides rather than the actual concentrations. Of specific interest in the uranium and thorium
decay chains are be the 234U/238U activity ratio and the 224Ra/28Ra and 228Ra/26Ra activity ratios (ARs).
The isotope 234U (t112 = 246,000 years) is produced by decay of 238U via two intermediate daughters with
short half-lives, 234Th (t112 = 24 days), and 234Pa (t112 = 1.2 minutes). Because of the moderately long half­
life of 234U, it does not reach secular equilibrium with 238U for many hundreds of thousands of years. In a
closed system, the 234U/238U AR would be less than 1.0 as 234U ingrows, and would be 1.0 once secular
equilibrium is reached. It would never be greater than 1.0. However, in natural surface waters, the
1
ratio is generally between 1 and 2; in the oceans, for instance, it is fairly consistently about 1.15. In
natural groundwaters, the 234U/238U AR can be 10 or higher (Osmond and Coward, 1976).
It is clear that, although 234U and 238U are chemically identical and do not fractionate because of mass,
there are mechanisms by which enrichment of 234U in waters occurs. There are two primary causes for
this enrichment, both related to the radioactive decay of the parent, 238U, and ofthe intermediate
daughters, 234Th and 234Pa (Osmond and Coward, 1976). First, decay of the parent and intermediate
daughters damages the local crystal structure of the mineral in which 238U resided (the Slizard-Chalmers
effect). Because of the damage to the crystal lattice, the damaged areas are somewhat more soluble
that the undamaged areas, and preferentially dissolve and release 234U. Also, there is greater probability
that these 234U atoms have been converted to the more soluble uranyl ion due to the effects of
radiation-induced ionization. Second, decay of 238U can cause the displacement of the intermediate
234Th daughter (which rapidly decays to 234U) off crystal surfaces or out of the near-surface lattice into
the adjacent water by alpha-recoil processes. The amount of excess 234U relative to 238U is controlled by
234U decay, water/rock ratios, flow path length, and the amount of bulk rock dissolution in the aquifer. In
general, the much greater mass of uranium in the rock relative to the pore water means that the
234U/238U AR in the water is much more sensitive to the fractionation processes than the ratio in the
rock.
In dynamic or geochemically perturbed systems where mineral dissolution is occurring rapidly, 234U and
238U are released in amounts proportional to their abundance in the rock, and the 234U/238U AR in the
groundwater will be close to 1.0. In stable, near-equilibrium systems, the 234U/38U AR will be higher, as
the radiochemical fractionation due of alpha recoil and preferential dissolution of crystallographically
damaged regions are more significant. Moreover, in reducing systems, where uranium solubilities are
low, the alpha recoil effect begins to dominate 234U/238U AR values, resulting in higher values. For this
reason, it is common in groundwater studies for the 234U/238U AR to inversely correlate with uranium
concentration and to provide an indication of redox condition. In purely oxic groundwater systems,
234U/238U AR values can be used as a mixing indicator.
Values of 234U/238U AR have been used in several studies to provide insights into hydrologic conditions in
groundwater aquifers, in addition to the relatively common use of uranium series disequilibrium
methods to age-date groundwaters. Cowart and Osmond (1977) showed that uranium in groundwater
downdip of a uranium roll-front deposit (that is, in the reducing zone) was not only lower in uranium,
but also was relatively enriched in 234U. This was because precipitation of uranium at the roll-front is
non-selective, but at the reducing barrier, the accumulated uranium is preferentially releasing 234U into
the water. Coward and Osmond proposed that while elevated 234U/38U ARs do not necessarily indicate
an upstream accumulation of uranium, when coupled with an abrupt decrease in uranium
concentration, the two features might be a useful diagnostic for identifying uranium deposits.
Otton et al. (2010) used 234U/38U AR values to quantitatively apportion uranium in groundwater to
different sources in Fry Canyon, Utah. Fry Canyon is the site of an old copper/uranium mine, and
uranium tailings and associated ponds represent point sources for uranium contamination in local soil
and groundwater. They showed that the uranium tailings are undergoing active oxidation and mineral
dissolution, and uranium being released from the site has 234U/238U AR values near 1.0; fo ur wells at the
site had groundwater AR values averaging 0.939. Groundwater AR values from seven upstream waters
averaged 1.235. Elevated uranium concentrations in downstream monitoring wells, could, on the basis
of their AR values (�0.98 to 1.01) and on isotope mass balance constraints, be sourced dominantly (78-
87%) to site-derived uranium.
2
Similarly, Zeilinski et al. (2008) evaluated surface waters in an area west of Denver, Colorado with both
undisturbed uranium-rich bedrock and non-economic occurrences of uranium minerals, and several
uranium deposits that had previously been mined. They found that the 234U/238U activity ratios of acid
mine drainage (0.95 to 1.0) were distinct from those of local surface waters, which were greater than
1.05. Hence, even in an area with naturally elevated uranium, mine wastes produced a distinctive
isotopic signature that could be used for source attribution.
In a third study, Johnson et al. (2009) evaluated groundwater samples with elevated uranium near an
open municipal dump Tuba City, Arizona. It was suspected that the uranium was derived from an
upstream uranium mill tailings site, from which a groundwater uranium plume extends. However,
Johnson et al. were able to show that the elevated values were not derived from the upstream uranium
mill tailings site. Groundwater samples from the plume coming from the tailing site, had 234U/238U AR
values of about 1.0, as expected for a young source. However, the groundwaters with elevated uranium
near the dump had 234U/238U AR values of more than 1.5, indicating that the uranium could not have
come from the tailings contaminant plume. Johnson et al. concluded that the elevated uranium by the
dump was derived from cycling of uranium derived from weathering of reworked Chinle sediments in
the soil zone.
Radium isotopes
Radium isotopes are produced by radioactive decay of uranium and thorium parents (Figure 1).
Concentration of Ra is consistently controlled by its geochemical properties, primarily the properties
that control sorption, desorption, and ion exchange. Factors related to geology and climate that affect
the acidity, redox potential, degree of mineralization, and composition of ground waters, as well as their
potential residence time, can control sorption and thereby the occurrence pattern of the isotopes of Ra.
Radium in groundwater can be derived from multiple sources including (1) Ra in-growth via decay of the
dissolved Th parents in the solution; (2) dissolution from the aquife r minerals; (3) alpha-recoil from the
parent nucleus in the aquifer rocks and on the clay and oxide surface coatings; (4)
adsorption/desorption exchange with Ra adsorbed on the surface coating, clays, and oxides; and (5)
coprecipitation with and/or dissolution of secondary minerals (e.g., barite) (Vengosh et al, 2009).
However, direct ingrowth from thorium is generally negligible in fresh near-neutral water due to the
much lower solubility of thorium than radium, and dissolution is possible but ultimately is not favored in
fresh water systems because it is too slow relative to the half-lives of short-lived radium isotopes.
Radium isotopes are continuously released to groundwater contained in pore space of porous media or
within fractures in bedrock by alpha-recoil mechanisms from mineral surfaces or surface coatings
(Fleischer, 1980; Tricca et al., 2001); in extreme cases, this can the primary source of radium in
groundwater, and other sources of radium to water are negligible (Krishnaswami et al. 1982). Figure 1
describes some the pathways by which isotopes of radium, thorium and uranium ca n be partitioned
among water, surface and bulk rock reservoirs.
3
II-rill;/ Tlt-:.,·/lr: .... Nttr l1tlr.:. Ill t ;nrttlltiWrl!:'l
Figure 1. Systematics of radionuclide decay, sorption and releases along the 232Th (left) and 238U (right)
decay series. Major fluxes are indicated by bold arrows, minor fluxes by fainter arrows. Nuclides are
supplied to the water and surface coatings by alpha recoil of parents in the mineral; radionuclides in the
water and surface exchange by sorption/desorption. The mobile pool of radionuclides increases along
the decay chain. Long-lived radionuclides that are mobile such as 234U may not reach steady state in
cases where advection is important (from Porcelli and Swarzenski, 2003).
228Ra/2 26Ra ratios
The 228Ra/26Ra ARs can provide some insight into the source of radium as welt as the geochemical
processes that control its mobility. The 228Ra/226Ra AR is often considered to be equal to the average
Th/U activity ratio in the aquifer rocks (Dickson 1990); for igneous rocks, this would be in the range of 1
to 1.4, corresponding to a Th/U weight ratio of 3-4, the ratio of these elements in the earth's crust.
However, other rock types commonly vary from this range-for instance, carbonates are preferentially
enriched in uranium relative to thorium, and clastic rocks may be enriched in thorium, in trace minerals
resistant to chemical and physical weathering, relative to more readily leached uranium. Post­
depositional enrichment or depletion of these elements in the aquife r rocks could result in variations in
this ratio. Moreover, other processes can result in differences between the Ra isotopic composition of
the rocks and the water. Dissolution of Ra-containing minerals would result in low ratios of the short-
4
lived to long-lived Ra isotopes (e.g., low 228Ra/226Ra ARs) relative to the host aquifer rocks, given the slow
dissolution rate and relatively faster decay of the short-lived Ra isotopes. In contrast, combination of
the recoil process and decay of the dissolved radium isotopes and their ra pid adsorption would increase
the relative abundances of the short-lived Ra isotopes (i.e. higher 228Ra/26Ra ARs). 226Ra is enriched
relative to 228Ra in waters from a variety of rock types, but especially in the carbonate-rock-type aquifer
systems; this is likely due to the enrichment of U (relative to Th) in carbonate minerals. 238U is the
parent of 226Ra and 232Th is the parent of 228Ra. In samples from Paleozoic carbonates in the
midcontinental USA, 228Ra/26Ra activity ratios ranged from 0.06 to 1.48 in fluids and were similar to
ratios in the aquifer rocks (0.21-1.53) (Sturchio et al. 2001). Enrichment of 226Ra relative to 228Ra is also
common in water samples from clastic sedimentary rocks where post-depositional enrichment of U
relative to Th was likely. The high solubility of 238U relative to 232Th is the cause for its widespread
distribution, redistribution, and enrichment relative to background levels in numerous sedimentary
environments.
Vengosh et al. (2009) notes that Ra activity in groundwater is controlled by a balance between the recoil
process and adsorption on clay minerals and oxides. In studies of aquifers in the Middle East, the range
of 228Ra /226Ra activity ratios (0.7-3) in groundwater from a sandstone aquifer, and the high 224Ra /228Ra
and 223Ra /226Ra values suggest that the significant variation of Ra in the different aquifers is due to
adsorption. Vengosh et al. also suggest that a high 228Ra /226Ra ratio in groundwater could be derived
from either local source rocks with a higher Th/U ratio or differentiation in the rate of decay of the
parent 232Th and 23�h nuclides on old surface coatings (see Figure 1).
224Ra/28Ra activity ratios:
Diffe rences in 224Ra occurrence and isotope ratios depend upon geology of the principal aquifer and
effects of water chemistry and recoil of 224Ra (Figure 1). The activity ratio of 224Ra to 228Ra is generally
highest (median, 3.25) in the detrital sediments of the western United States (lower Tertiary/Cretaceous
sandstones and Quaternary alluvium. Ra is poorly soluble in these oxidizing and alkaline aquifer
systems but the concentrations of 224Ra are somewhat enhanced in solution relative to those of 228Ra.
This can be explained by alpha recoil of 224Ra from the Th-rich (228Ra-bearing) detrital sands in the
western United States. The process is analogous to "recoil enrichment" for the isotope 234U relative to
the parent isotope 238U (Osmond and Cowart, 1976). 224Ra might be most enriched by the physical recoil
mechanism relative to 228Ra in waters where Ra is sparingly soluble (oxic and moderately to strongly
alkaline waters, as in the western United States), whereas relative 224Ra enrichment is least where Ra is
soluble.
The concentration of 224Ra has regulatory and public health implications. 224Ra and its decay products
can contribute substantially to gross alpha-particle activity of water. The effectiveness of the use of
gross alpha-particle activity both as a standard in itself (15 pCi/L) and as a compliance-monitoring
"screen" for combined Ra has been shown to depend on the holding time between sample collection
and analysis because of the presence of 224Ra (Parsa, 1998; Szabo et al., 2005). The USEPA recommends
that gross alpha-particle activity be determined within 48 to 72 hours in order to account for the
presence of the short-lived alpha-particle-emitting isotopes such as 224Ra in regions where 228Ra is
known to be present (USEPA, 2000b).
5
B. EXPERIMENTAL METHOD
The majority of the activity of radium in groundwaters is 226Ra and 228Ra, and these can be measured
using readily available and relatively inexpensive techniques. In order to measure the activities of
radium isotopes in the samples, it is necessary to separate and concentrate the radium from the
groundwater samples. This is carried out by filtering a relatively large volume of well-water (20-40
liters) through columns filled with acrylic fibers coated with manganese oxide (Mn02). Radium is
strongly sorbed onto the manganese oxide, and is quantitatively extracted from the water. Following
extraction, the MnOrcoated fibers were removed from the columns, squeezed by hand to extract most
of the water, and then placed in sealed glass tubes to "incubate." Incubation allows the 226Ra in the
samples to reach secular equilibrium with its daughter, 222Rn (t1/2 = 3.8 days). Following an incubation
period of 3 weeks, the sample is attached to a RAD 7'M radon monitor, and the gas contained in the tube
is cycled repeatedly through the RAD 7. The activity of 222Rn is measured and quantified by comparison
with standards prepared in a similar fashion, and is used to indirectly determine the activity 226Ra. Note
that the RAD 7 can be obtained for less than $10K; this analytical procedure is easily within the reach of
most small businesses.
Once 226Ra has been determined, the fiber samples are re-analyzed to measure 228Ra, which is
determined indirectly, by measuring the gamma activity of its daughter 228Ac (tl/2 = 6.5 hours). The
Mn02 fibers are removed from the incubation tube, placed in a steel can and oven-dried overnight.
Then, the top is placed on the can and it is crushed in a laboratory press. The flattened sample is then
counted using a gamma spectrometer to determine the activity of 228Ac (338 and 911 KeV peaks were
used); once again the efficiency of the counting process was determined by comparison with 228Ra
standards made in exactly the same fashion as the samples. Again, gamma spectrometry is routinely
available at reasonable cost from many analytical labs.
Although radioisotopes are useful in establishing provenance of contaminants in groundwater, the data
must be combined with standard chemical analyses in order to provide the greatest understanding of
the system being evaluated. For each sample collected in this study, field measurements of
temperature, pH, total dissolved solids, and dissolved oxygen content should be collected, using hand­
held meters. Water samples should be collected and sent to an analytical laboratory (for cation and
anion analysis and for trace element analysis by ICP-MS.
References
Bryan, C., Siegel. MD, and Heikoop, J., 2011. Isotope Forensics for Groundwater Contamination: Support
for Environmental and Mining Industries, Isotope Forensics Project, White Paper, SAND2011-2911P,
Sandia National laboratories, Albuquerque, NM.
Cowart, J.B., and Osmond, J.K., 1977. Uranium isotopes in groundwater: Their use in prospecting for
sandstone-type uranium deposits, Journal of Geochemical Exploration, 8, 365-379.
Dickson, B.L, 1990. Chapter 4-2: Radium in groundwater. Th e Environmental Behavior of Radium, Vol.
1, International Atomic Energy Agency Technical Reports Series, 310, 335-372.
Fleischer, R.L, 1980. Isotopic disequilibrium of uranium: Alpha-recoil damage and preferential solution
effects. Science, 207, 979-981.
6
Krishnaswami, S., Graustein, W.C., Turekian, K.K., Dowd, J.F., 1982. Radium, thorium, and radioactive
isotopes in ground waters: Application to the in situ determination of adsorption-desorption rate
constants and retardation factors. Water Resources Research, 18, 1633-1645.
Osmond, J.K., and Cowart, J.B., 1976. The theory and uses of natural uranium isotopic variations in
hydrology. Atomic Energy Review, 14(4), 621-679.
Otton, J.K., Zeilinski, R.A., and Horton, R.J., 2010. Geology, geochemistry, and geophysics of the Fry
Canyon uranium/copper project site, southeastern Utah-Indications of contaminant migration. U.S.
Geological Survey Scientific Investigations Report 2010-5075, 39 p.
Parsa, B., 1998. Contribution of short-lived radionuclides to alpha-particle radioactivity in drinking water
and their impact on the Safe Drinking Water Act Regulations. Radioactivity Radiochemistry, 9, 41-
50.
Porcelli, D. and Swarzenski, P.W., 2003. The behavior of U-and Th-series nuclides in groundwater.
Reviews on Mineralogy and Geochemistry, 52: 317-361.
Sturchio, N.C., Banner, J.L., Binz, C.M., Heraty, LB., Musgrove, M., 2001. Radium geochemistry of
ground waters in Paleozoic carbonate aquifers, midcontinent U.S.A. Applied Geochemistry, 16, 109-
122.
Szabo, Z., dePaul, V.T., Kraemer, T.F., Parsa, B., 2005. Occurrence of radium-224 and comparison to that
of radium-226 and radium-228 in water from the unconfined Kirkwood-Cohansey aquifer system,
southern New Jersey. U.S. Geological Survey Scientific Investigations Report 2004-5224. [Available at
http:/ I pubs. usgs.gov I sir /2004/5224]
Tricca, A., Wasserburg, G.J., Porcelli, D., Baskaran, M., 2001. The transport of U-and Th-series nuclides in
a sandy unconfined aquifer. Geochimica Cosmochimica Acta, 65, 1187-1210.
U.S. Environmental Protection Agency, 2000. National Primary Drinking Water Regulations;
Radionuc/ides; Notice of Data Availability; Proposed Rule, 40 CFR Parts 141 and 142. EPA 815-2-00-
003, p. 21576-21628.
Vengosh, A., Hirschfeld, D., Vinson, D., Dwyer, G., Raanan, H., Rimawi, 0., AI-Zouri, A., Akkawi, E., Marie,
A., Haquin, G., Zaarur, S., Ganor, J., 2009. High naturally occurring radioactivity in fossil groundwater
from the Middle East. Environmental Science Technology, 43, 1769-1775.
7
APPENDIX E
TRIP REPORT
MEETINGS WITH STAFF FROM UTE MOUNTAIN UTE TRIBE
ENVIRONMENTAL PROGRAMS DEPARTM ENT
NOVEMBER 30,2016, TOWOAC, CO
AND
SITE VISIT WHITE MESA URANIUM MILL AND MEETINGS WITH STAFF OF
ENERGY FUELS RESOURCES (USA) INC.
DECEMBER 1, 2016, WHITE MESA, UTAH
SUMMARY
1. Purpose and Relevance of the Infiltration and Contaminant Transport Model (ICTM)
• Model was used in support of cover design and is not expected to predict site wide
contamination.
• The discussions with the State have moved beyond discussions of the model because
EFR has started a real test in Cell #2, which is in the first phase of reclamation.
• Review of Finai iCTM and Reclamation Plan would be useful to see how questions raised
in this contract have been resolved.
• Run the ICTM for full 1000 yrs; a useful tool for sensitivity analysis, which should be
done with input from the Tribe (as well as the State).
2.Air Quality Issues: Dust with Elevated Uranium and Vanadium, Radon and Odors
• EFR argues that the contamination is likely from historic operations not associated with
current Mill activity.
• The Tribe has expressed concerns that current air monitoring procedures for dust and
radon are not sufficiently protective.
• Energy Fuels Resources (EFR) says that their high volume dust monitors run 90% of the
time as shown by their maintenance records.
• The Company argues that the wind velocity used by UMUT EPD to calculate Rn
emanations from evaporation ponds was unrealistically too high.
• A potential hazard might be indicated by odors detected by residents; dust plumes and
plumes coming from the facility are observed and reported anecdotally.
• EFR acknowledged this but did not think it was health hazard; people were smelling
organics from mill. These emissions needs to be evaluated for potential health effects.
3. Cell #1 Failure and Future of Legacy Cells
• The Tribe asserts that the Legacy Cells such as Cell #1 are beyond their design life (30
yrs),that observed leaks demonstrate that that they leaking routinely, and must be
replaced.
• The Company feels that Cell#1 worked as designed; leak detection system indicated
that there was leak at a certain level, rather than search for leak, they replaced a huge
section of the liner with new materials.
• The Site Reclamation plan requires that Cell #1 be dug up and material placed in a
newer cell for final closure at some time in the futurewith a 1000 year cover, no active
maintenance and supported by a DOE Legacy Site Perpetual Care Fund.
4. Natural Variability, Pyrite Oxidation, pH Decreases and GWCLs
• The Tribe said that the GWCL (Ground Water Compliance Level) flow chart used by the
Site and the State to set Compliance Levels for metals at the monitoring wells is not
same as the EPA procedure upon which it is based. (it doesn't force a outcome other
than raising the GWCL. ) It would be useful to review the Ground Water Discharge
Permit to see how Corrective Action is triggered.
• EFR feels that two accepted lines of evidence are sufficient to justify raising the GWCL:
the Utah isotope study that says there is no leakage from cells and the pyrite oxidation
'natural variability' hypothesis.
• The State has accepted this as a "reasonable" idea. The main observations and
mechanisms that support this are:
o EFR argues that sufficient oxygen to oxidize pyrite in saturated zone waters
comes from stressing the wells.
o the decreases in pH are observed site-wide; effects in MW 18 (which is
upgradient) and MW-3 (down-gradient) are the most pronounced.
o the chloride plume is not seen upgradient where the pH is also decreasing.
• Potential follow-up work:
• Detailed review of Geo-Logic model for alternative hypothesis for natural
variability. This would include independent modeling using PHREEQC to
determine if pyrite dissolution can be occurring and caused the pH changes
when using reasonable ANP estimates.
• Work with Bureau hydrologist to evaluate alternative travel time estimates.
5. Cultural Issues
An underlying issue appears to be that the Tribe does not feel it is getting enough respect from
the different agencies including the State and the EPA ..
SUMMARY OF MAIN TOPICS DISCUSSED DURING SITE VISIT IN NOVEMBER-DECEMBER 2016
1. Purpose and Relevance of the Infiltration and Contaminant Transport Model (ICTM)
The purpose and relevance of the ICTM for long term performance was clarified. This model
was used in support of cover design and is not expected to predict site wide contamination. The
200 year modeling duration was chosen to be consistent with the Atomic Energy Act Appendix
A for tailings which require 200 year minimum life but a 1000 year design life. The discussions
with the State have moved beyond discussions of the model because EFR has started a real test
in Cell #2, which is in the first phase of reclamation. A test section has been installed to see if
the cover cross section is performing as expected at Cell #2. There is a document in progress
that describes this and it should be released within one month. Previously, the Tribe expressed
concern that the assumptions of the pyrite oxidation model and the acid neutralization
potential (ANP) that is implicitly assumed in the ICTM are not consistent. EFR said that there is
no reason for the ANP to be consistent with the pyrite oxidation model because the ICTM
calculations focused on the unsaturated zone and the pyrite model focuses on the saturated
zone
2.Air Quality Issues: Dust with Elevated Uranium and Vanadium, Radon and Odors
Both the Tribe and the USGS raised a concern that poor dust control on the site has led to
contamination of sediments northeast and south ofthe Site. EFR argues that the contamination
is likely from historic operations not associated with current Mill activity. Specifically, some
dust probably comes from the Plateau Buying Station which was a uranium ore buying station
in the late 1970s. This was located north of the Mill site; by current standards, this was not a
well-regulated operation and could have led to dust pollution. The high uranium in the
sediments to the south of the site might be from ore from the Cottonwood Mine that was
transported along the road by the facility in the 1950 before the county road was rerouted to
its current location ..
The Tribe has expressed concerns that current air monitoring procedures for dust and radon
are not sufficiently protective. They assert that the operating procedures for high volume dust
samplers leads to equipment fa ilure and they are considering changing to low volume samples.
They have calculated that radon emissions from the evaporation ponds exceed regulatory
standards.
Energy Fuels Resources (EFR) says that their high volume dust monitors are running at least
75% of the time each quarter according to regulations. In fact, they run 90% of the time as
shown by their maintenance records. The maximum downtime at a monitoring site would be six
days according to their SOP. In addition, The Company argues that the wind velocity used by
UMUT EPD to calculate Rn emanations from evaporation ponds was unrealistically too high.
The wind velocity at the tailings cells is much lower than that measured at the wind monitoring
station which is a tower 1 meter tall. In addition, that location is 15 m above the tailing cell
surface. Even when there is a breeze at that elevation, the surface of the tailing cells is like a
"mirror".
A potential hazard might be indicated by odors detected by residents .. When the wind shifts in
the evening, area residents say they can smell the acid tailings. EFR acknowledged this but did
not think it was health hazard; people were smelling organics from mill. These emissions needs
to be evaluated for potential health effects. The Tribe said that dust plumes and plumes
coming from the facility are observed and reported anecdotally.
3. Cell #1 Failure and Future of Legacy Cells
The Tribe thinks that the leak in 2009 from Cell #1 one was catastrophic and demonstrates that
the cell linings are failing. When the leak occurred, the Mill dropped the liquid levels in the cell
and photographed the damage beneath the liquid level. In the Tribes view, this shows that the
cell lining failed and the damage was not simply due to sunlight exposure. The Tribe asserts
that the Legacy Cells are beyond their design life (30 yrs),that observed leaks demonstrate that
that they leaking routinely, and must be replaced.
The Company has a different story: they feel that the leak detection system, although not as
sophisticated as that in the newer cells (#4a,4b) worked as designed and indicated that there
was (a small volume?) leak at a certain level. The Cell was drained below that level and they
couldn't find the leak so they just replaced a huge section of the liner with new materials. They
then refilled the tailings cell and there was no more leakage.
Because the waste at the site is a byproduct of uranium tailings (11e2 waste), the site will be
closed permanently at some time in the future. The Site Reclamation plan requires that Cell #1
be dug up and material placed in a newer cell for final closure at some time in the future. The
Site owner must clean all contaminated soils and put them in the tailing cells, including dust in
the area from all around the Mill. Then the site becomes a DOE Legacy Site with a 1000 year
cover, no active maintenance and is supported by a Perpetual Care Fund.
4. Natural Variability, Pyrite Oxidation, pH Decreases and GWCLs
The Tribe said that the GWCL (Ground Water Compliance Level) flow chart used by the Site and
the State to set Compliance Levels for metals at the monitoring wells is not same as the EPA
procedure upon which it is based. Specifically, they claim that it doesn't have an "off ramp" to
force a outcome other than raising the GWCL. Examination of the chart from lntera
publications confirms that this is true, however EFR claims that the flow chart does have an "off
ramp" that leads to a CA (Corrective Action) It would be useful to review the Ground Water
Discharge Permit to see how Corrective Action is triggered. When an OOC (Out of Compliance)
condition happens, the Source Assessment Report is required and that will lead to the either
CA or a change in GWCL.
EFR fe els that two accepted lines of evidence are used to justify raising the GWCL: the Utah
isotope study that says there is no leakage from cells and the pyrite oxidation 'natural
variability' hypothesis. The Tribe has argued that insufficient pyrite oxidation could occur to
lower the pH because there is not enough oxygen in the saturated aquifer. EFR argues that the
oxygen in saturated zone waters comes from stressing the wells. When they purge the wells,
the cone of depression allows air to mix with the water. The wells are screened above the
water line.
The State has accepted this as a "reasonable" idea. The main observations that support this
are:
• the decreases in pH are observed site-wide; effects in MW 18 (which is upgradient) and
MW-3 (down-gradient) are the most pronounced. The differences in the observed effect
at different wells might be due to changes in water levels which leads to changes in the
residence times of water along the flow path to the wells.
• the chloride plume is not seen upgradient where the pH is also decreasing.
5. Cultural Issues
An underlying issue appears to be that the Tribe does not feel it is getting enough respect from
the different agencies including the State and the EPA. For example, the Tribe feels that EPA
has not consulted with the Tribe sufficiently on NESHAP regulations for radon monitoring. They
planned a face-to-face consultation but the person writing the rule couldn't attend in person
because of health problems. This offended the Tribal Council even though that person
participated in consultation by telephone. Before all of the Tribe's questions could be
answered, the EPA started the public comment period and this prevents serious dialogue with
the Tribe, in the view of the Tribal Council.
6. Potential Follow-up work
1. Detailed review of Geo-logic model for alternative hypothesis for natural variability. This
would include independent modeling using PHREEQC to determine if pyrite dissolution can be
occurring and caused the pH changes when using reasonable ANP estimates.
2. Work with Bureau hydrologist to evaluate alternative travel time estimates.
3. Work with Bureau sociologist to evaluate problems with communication between tribe and
regulatory agencies. Th is wo uld involve interviews with the key participants and a trip to Salt
lake to talk to regulators.
4. Health effects: The Tribe feels that EPA did not want an exposure assessment done for this
site and wants to avoid looking at human health implications of the issues that the Tribe raises.
The Tribe feels that the health effects associated with the Monticello Mill are relevant to their
population. The information from that site should be reviewed to see if that is a valid
comparison.
5. Review of Finai iCTM and Reclamation Plan to see how questions raised in this contract have
been resolved.
• Run the ICTM for full lOOO yrs; why didn't they run it that long? It's a useful tool for
sensitivity analysis, which should be done with input from the Tribe (as well as the
State).
• Review of Reclamation Plan when it is available;
Notes fro m meeting with staff from Ute Mountain Ute Tri be Environmental
Programs Department
Towaoc, CO; November 30, 2016
Participants:
• Malcolm Siegel, US Consulting, Inc.
• Scott Claw, Environmental Programs Director, UMUT EPD
• Colin Larrick, Water Quality Program Manager
• Nancy Lauer, PhD candidate Duke University
• other UMUT EPD staff
Main topics:
1. Raising the GWCL:
The Tribe said that the GWCL flow chart is not same as EPA procedure; it doesn't have an "off
ramp" to force a outcome other than raise the GWCL. Examination of the chart from lntera
publications conforms that this is true, however EFR had a response: i.e. Two lines of evidence
are used to justify raising the GWCL: the Utah isotope study that says no leakage from cells and
and the pyrite 'natural variability' hypothesis.
2a. pH changes in wells as indicator of leaking cells:
The Tribe says that pyrite study is not sufficient to explain the pH changes in their monitoring
wells (the East and West wells). There are no pH changes in the Bayless well or Lyman private
wells, that have been monitored quarterly for the last two years.
The Tribe feels there is inconsistency in the assumptions about pyrite model and the acid
neutralization potential that is implicitly assumed in the ICTM. (I need to look at the Geo -Logic
report in more detail. However they said that there is no funds available for the contractor to
work with me or answer my questions.) Note: EFR said that there is no reason for the ANP to be
consistent with the natural variability model because the ICTM calculations focused on the
unsaturated zone and the pyrite model focuses on the saturated zone. I should compare the
values for ANP in saturated and unsaturated zones.
(However, ICTM may no longer be relevant because of the test that is the carried out on the
site as described in the notes.) However, I think that the I CTM could be modified to evaluate if
the metals changes in pH changes at the different wells could have occurred given different
assumptions about flowrates and the concentrations of sorbing sites along the flow paths.
2b. Comments on ICTM:
Tribe thought Reclamation Plan was revised in 2016 and wanted to know if this meant it was a
new ICTM? The Tribe that there was a 2015 Interrogatory and that the State did not feel that
the model had been fi nished and doesn't use the results. (See comments about the model and
the reclamation plan by EFR).
3. Airborne contaminants: dust, Radon, plume (odor)
Dust plumes:
Dust and U: Colin said that there were two main wind directions. The wind direction change
from day (SW) to evening (from N). They offer to show me the wind rose diagrams, (note: see
discussion with EFR confirm the change in direction and that they question if this was
responsible for high uranium in sediments to the South. When the wind shifts in the evening,
area residents say they can smell the acid tailings. (EFR acknowledged this but did not think it
was health hazard; people were smelling organics from mill. These emissions needs to be
evaluated for potential health effects.) The Tribe said that plumes are observed and reported
anecdotally. Th e Tribe has collected radionuclide data for some dust samples. This kind of data
could be used in evaluation of source of dust by isotopic forensics.
Rn emissions:
The Tribe defended their radon emission model. This is a developing issue: the EPA is basing its
renewal of the NESHAP (EPA 90.1} on White Mesa because this is the only mill facility in the
country. They said there is no radium 226 data on site available so gross alpha activity is a good
proxy for radium. The gross alpha is much higher now than in the data that was used in the
evaluation by the EPA.
NESHA P:
The EPA has not consulted with the Tribe sufficiently on NESHAP. When the King memo was
sent to the EPA, they include 20- 30 questions and EPA couldn't answer many of them. They
planned a consultation but the person writing the rule couldn't attend in person because of
health problems. This offended the Tribal Council. The person participated in consultation by
telephone and told Tribal Council that cells 1, 2 and 3 would be closed, and this has not
happened. Before all of the Tribes questions could be answered, the EPA started the public
comment period and this prevents serious dialogue with the Tribe. The Tribe is now waiting for
the OMB to comment on the proposed changes to the rule.
Cell 2 exceedances for Rn:
Due to the sampling schedule and reporting schedule for radon data it is possible that the
exceedance lasted for nearly 2 years. The mill remediation was simply a 1 foot cover over the
hotspots and the Tribe does not feel that this is sufficient.
4. Sampling practices
In the past ,the State had problems with the Mills' water sampling but now feels it's okay. This
is because they use dedicated pumps and split sampling procedures.
Air quality sampling is still a problem due to the debate over the proper way to run the
sampling motors. The Tribe is now considering using low volume sampling instead of high
volume sampling. The TRibe doesn't feel that there has been sufficient sampling of vegetation;
the State has resisted requests for more extensive sampling citing concerns over "denuding"
the Mesa.
5. Nitrate CAP issues and nitrate source assessment report.
The State assume the nitrate was from a leaking ammonium sulfate source and the Tribe does
not agree with this assumption. The Tribe is concerned that the Corrective Action Plan avoids
the need to determine the source of the chloride plume which is co-located with the nitrate
plume. There is no Source Assessment Report required chloride. The Tribe also feels that
nitrogen concentration used in the mass balance calculations is not correct. The site assumed
the nitrate was 20 mg/1 when it should be more than 1000 mg/L.
6. Legacy cells leak because they are old. (Cell #1)
The Tribe thinks that the leak in 2009 from Cell #1 one was catastrophic and demonstrates that
the cell linings are failing. The PVC pipe that was designed to catch leaks and only works if there
is a catastrophic leak. When this occurred, the Mill dropped the liquid levels in the cell and
photographed the damage beneath the liquid level. In the Tribes view, this shows that the cell
lining fa iled and the damage was not simply due to sunlight exposure.(The Company has a
different view of this event, see notes).
The Tribe is concerned about the potential residual contamination remaining beneath old
Roberts Pond, which was used as a catchment for run-off, spills, etc from Mill operations .. In
their view, Roberts Pond was excavated because of the lawsuit by Grand Canyon Trust which
claimed there were too many active cells on the Mill site. The material in Roberts Pond was
excavated to Cell #3. Roberts Pond was either unlined or poorly-lined as was revealed by a
gamma survey from the surface. A survey found damaged liner in some places. The Tribe is
concerned that verification sampling was not adequate and also that there may be a
groundwater mound in that area as suggested by the analysis by Geo-Logic ..
7. Water balance model:
The Tribe wants a water balance for the Mill which shows what amounts of water are being
used fo r processing, how much water goes into the aquifer, etc. They believe that the process
water is taken from the aquifer instead of Recapture reservoir. (However the site says this is no
longer true. During the drought when levels in the reservoir were low, they began using water
from the aquifer, but now they are using the reservoir water again.)
8. MNA: Colin asked if MNA had been applied to an unconfined aquifer on z Mesa of this size.
9. Comments on my Report
The Tribes' lawyer asked that 1) not use term "weight of evidence" because of legal implications
and 2) have 'robust qualifiers' for my conclusions.
Other notes:
An underlying issue appears to be that the Tribe does not feel it is getting enough respect from
the different agencies including the state and the EPA. This might be evaluated by the BIA
expert on tribal relations through interviews with key participants. I could help get this started
through a follow-up task.
List of follow-on activities.
1. Detailed review of Geo-Logic model for alternative hypothesis for natural variability.
Independent modeling using PHREEQC to determine if pyrite dissolution can be occurring and
caused the pH changes when using ANP estimates.
2. Work with Bureau hydrologist to evaluate alternative travel time estimates.
3. Work with Bureau sociologist to evaluate problems with communication between tribe and
regulatory agencies. This would involve interviews with the key participants and a trip to Salt
Lake to talk to regulators.
4. Health effects: The Tribe feels that EPA did not want an exposure assessment done for this
site and wants to avoid looking at human health implications of the issues that the Tribe raises.
The Tribe feels that the health effects associated with the Monticello Mill are relevant to their
population. The information from that site should be reviewed to see if that is a valid
comparison.
5. Review of Finai iCTM and Reclamation Plan to see how questions raised in this contract have
been resolved.
Notes from meeting with staff from Energy Fuels Resources (USA) Inc.
November 1, 2016; White Mesa, UT.
Participants:
• Malcolm Siegel, US Consulting, Inc.
• Harold Roberts, Exec VP, Energy Fuels Resources (USA) Inc.
• David Frdenlund, Sr. VP, General Counsel, Energy Fuels Resources (USA) Inc.
• Mark Chalmers, COO, Energy Fuels Resources (USA) Inc.
• additional participant from EFR
1. Response to UMUT EPD staff comments about the GWCL chart used by lntera:
The GWCL flow chart does have an "off ramp" that leads to a Corrective Action.
It would be useful to review the Ground Water Discharge Permit to see how Corrective Action
is triggered. When an OOC happens, the SAR is required and that will lead to the either CA or a
change in GWCL.
2. Natural variability debate:
Stewart Smith (HydroGeochem) developed the pyrite argument.
The oxygen in saturated zone waters comes from stressing the wells. When they dewater the
wells, the cone of depression allows air to mix with the water. The wells are screened above the
water line. The State has accepted this as a "reasonable" idea. The main arguments in favor of
this are:
• the decreases in pH are observed site-wide; effects in MW 18 (which is upgradient) and
MW-3 (down-gradient) are the most pronounced. The differences in the observed effect
at different wells might be due to changes in water levels which leads to changes in the
residence times of water along the flow path to the wells.
• the chloride plume is not seen upgradient where the pH is also decreasing.
The Mill owner feels the current procedure for setting the GWCLs is too conservative. The State
forces reevaluation of the GWCL every time there is an OOC. The company would like to have
the GWCL revised every five years during license renewal. They would like to use the trend in
pH and metals concentration to calculate the future GWCL that would be expected at that time.
The State does not allow this and forces the company to do a Source Assessment Report based
on the previous GWCL.
3. Purpose of the ICTM
This model was used in support of cover design and not expected to predict contamination site­
wide. The 200 year time was chosen to be consistent with the Atomic Energy Act Appendix A
for tailings which require 200 year minimum life but a 1000 year design life. The model resulted
in a better design for the cover and the Company is now in agreement with the State. One of
the parameters that needed to be examined was the permeability of both cover and the liner in
order to prevent a 'bathtub' effect. The calculations carried out described chemical reactions in
Tailing Cells 1, 2 and 3 in which the acid reacts with carbonate and sulfate and "gums up" the
flow path. The discussions with the State have moved beyond discussions of the model because
they have started a real test in Cell #2 which is in the first phase of reclamation. A test section
has been installed to see if the cover cross section is performing as expected at Cell #2. The
Company is ready to sign a SCA Stipulated Consent Agreement with the State to prove that the
cover works. Before this, there was a lot of debate about how to do a sensitivity analysis that
includes a reasonable worst-case scenario. To resolve this debate, the Company said" let's do a
test already." There is a document in progress that describes this and it should be released
within one month.
4. Travel time debate
The Company fe els that travel times across the site are on the order of 1000 years and not 1
year. A horizontal borehole were drilled near MW-22 and many cores were evaluated to look
for evidence of fracture by Stewart Smith; there was no evidence for fractures. There is no
single document that describes site-wide hydrology. Stewart Smith has done a lot of work on
this and calculates travel times the edge of the site of about 1000 years. The offer by the
Company to drill three new wells should result some of the questions about fast paths and flow
directions. (I should work with the tribe to select the sites for the new wells.)
5. Debate with State about compliance indicators
In the 10+ years since the State took over responsibility for the site from the NRC, the scope of
compliance monitoring has changed from 7 wells with 4 indicators to 30 wells with 40
indicators. Currently the State tacitly accepts 4 indicators at the compliance wells but this is not
official stance; the State still looks at all 40 indicators that are measured but relies mostly on
chloride. The report by University of Utah is used to justify the "natural variability" argument.
6. Reclamation plan.
Because the waste at the site is a byproduct of uranium tailings (11e2 waste) the site is closed
permanently at some time in the future. The Site owner must clean everything and put it in the
tailing cells including dust in the area from all around the mill. The cover is designed for a 1000
year life and then the site becomes a DOE legacy Site where there is no active maintenance and
is supported by a Perpetual Care Fund.
7. Monitored natural attenuation
MNA might be considered for final remediation of the chloroform plume but is not currently
the subject of discussion.
8. Air quality issues: Origin of "contaminated" dust observed by USGS
• Some dust probably comes from the Plateau Buying Station which was a uranium ore
buying station in the late 1970s. This was located north of the Mill site; by current
standards, this was not a well-regulated operation and could have led to dust pollution.
• The suggestion that uranium dust came from trucks that were not covered is not true.
The trucks have been covered since the 1980s but work practices may not have been
strict enough. In response to the USGS Report, EFR cleaned up the work areas while not
admitting that the dust observed was their responsibility. The cleanup standards used
by the site are more conservative than what is required (5-15} which means clean up
must be to 5 pCi of radium in the first 15cm soil that. The Company cleans the soil
such that all radionuclides are equivalent to 5 pCi radium even though the Site area is
not residential. Actually the Site is recreational so exposure is not continuous. Details
are found in lOCFR 40 partlGA.
• The high uranium in the sediments to the south of the site might be from ore from the
Cottonwood Mine that was transported along the road by the facility in the 1950 before
the county road was rerouted to its current location.
• Dust monitoring procedures: EFR says that the monitors are running at least 75% of the
time each quarter according to regulations. In fact, they run 90% of the time as shown
by their maintenance records. The maximum downtime at a monitoring site would be
six days according to their SOP.
• Air quality is regulated by 3 overlapping standards. NRC standards are mandated by the
State fo r all radionuclides except radon. In addition the EPA has superimposed radon
requirements NESHAP, onto the requirements for air quality monitoring of tailings.
• The Minor Source permit from the State deals with particulates (PM10], NOX, SOX, ie.
nonrads.
• On site monitoring: the NRC mandates on-site monitoring at 28 locations for natural U,
radium-226, thorium-230, lead-210, radon, gamma and thorium 232 in alternate feed
materials. 10CFR20 B says this is sufficient for all radionuclides . The site ALARA is 25%
of the NRC requirements.
• The Company added stations to monitor as a result of the USGS study but more
important at closure the site has to clean up the whole area to background levels.
(MARSIMM approach).
• The Company has concerns about reported fraud at USGS Laboratory and they doubt
the results of the sagebrush monitoring.
9. Air Quality -Radon emissions
• The Company argues that the wind velocity used by UMUT EPD to calculate Rn
emanations from evaporation ponds was unrealistically too high. The wind velocity at
the tailings cells is much lower than that measured at the wind monitoring station which
is a tower 1 meter tall. In addition, that location is 15 m above the tailing cell surface.
Even when there is a breeze at that elevation, the surface of the tailing cells is like a
"mirror".
• The Grand Canyon Trust lawsuit concerns Cell#3 where they claimed there have been
past radon violations. They based their lawsuit on the fact that data from multiple
sampling events were mixed in calculating the Rn emission. This happened because
there was a initial violation of >21 pCi and then the site remediated the area where they
could place a cover on hotspots. Then the Site measured that area and found that
emissions were sufficiently low; they used that value to recalculate average which was
then below the limit of 20 pCi. The regulation requires only one measurement per year
and if multiple measurements are taken over time, then average for the results must be
reported. The Grand Canyon Trust sued because the Site didn't remeasure all the (27?)
sample monitoring sites on the cell.
10. Evidence that Legacy Cells (#1,2,3} are in really bad shape:
The Tribe asserts that the legacy Cells are beyond their design life (30 yrs},that observed leaks
demonstrate that that they leaking ro utinely, and must be replaced. In 2009, a leak was
detected in Tailings Cell #1 which has a single liner and a PVC pipe to collect leaks. As
mentioned in the above report from the meeting with the Tribe, the Tribe described the event
as a 'catastrophic' leak that shows that the liner needs to be replaced. The Company has a
different story: they feel that the leak detection system, although not as sophisticated as that
in the newer cells (#4a,4b) worked as designed and indicated that there was (a small volume?)
leak at a certain level. The Cell was drained below that level and they couldn't find the leak so
they just replaced a huge section of the liner with new materials. They then refilled the tailings
cell and there was no more leakage. The Site Reclamation plan requires that Cell #1 be dug up
and material placed in a newer cell for final closure at some time in the future.
Summary of Observations from Site Tour: (no photographs were allowed)
1. Tailings Cell #1-evaporation pond with process water. The surface of the pond is five ft or
more below the road.
2. Tailing Cell #2 -all solid; platform cover on part and other parts mushy. This helped me
understand the issues behind the Grand Canyon Trust lawsuit.
3. Tailing cell 3-an evaporation pond with a smooth surface
3. Tailing cells 4a and 4 b: "Mirror images" separated by a dike of earth excavated from the cell.
4. Ore storage pads were empty.
5. Wash station to decontaminate the ore trucks when they are ready to leave the site requires
multiple washings and scanning.
6. Alternate waste fo rms: the waste from Midnight Mine is a precipitate from water treatment
that is shipped and stored as bricks in double sacks; each sack costs about $1000. I saw many
diffe rent drums having a different waste forms. The disposal of any new alternate waste form
must be approved by an amendment to the Site license. The State regulates and protects the
new waste forms in contrast to what the Tribe says.
Additional work to suggest:
• Run the ICTM for full 1000 yrs; why didn't they run it that long? It's a useful tool for
sensitivity analysis, which should be done with input from the Tribe (as well as the
State).
• Review of Reclamation Plan when it is available; I should get help in areas that I am not
expert. This would be more relevant than the unguided review that I did.
• Review of Geo-logic Report and discussion with the author.
• Meet with UDEQ to get their perspective.
• Make a project for a UNM MPH practicum student on sociological -health aspects ofthe
project:. exposure assessment with cultural view.
I RELATED DOCUMENTS . I
PPS Dawn Mining
Alternate Feed
Amendment
Request 7/10/14.,
Exhibit 'A' ...... ....
(probably docs of
1/11/13, 12/16/11
and 3/31/11) and
comments of
11/13/13.
Exhibits A-G (see Table 2 'List of Exhibits
RAA N03 CAP')
Exhibits A-T (see attached Table 4
'Summary of Exhibits UMUT
Comments'),
� ..
RAA Exhibits 1 to 3 (see attached Table 3
'Summary of Exhibits RM Air dust')
�
�
...
�
..__
I RESPONSE BY UMUT AG ENCIES l
I
PETITION TO INTERVENE IN
SUPPORT OF REQUEST FOR
AGENCY ACTION
Re: License Amendment 7
8/11/2014; (Keller)
(UMUT1)
ACTION
Re: Nitrate CAP
1/11/2013; (Keller)
(UMUT2)
\ICY
...... .....
I
"'I UMUT Comments
Regarding Denison Mines
(USA) Corp. Radioactive .....
Materials License Renewal .....
DRC-045
12/16/2011; (Hawkins)
(UMUT3)
REQUEST FOR AGENCY ACTION in
Matter of Approval Order-�
Modification Add a .....
Baghouse ... Fuei .. Standards
3/31/2011; (Claw) (UMUT4)
II Fi.q ure 1. Level l Road Map II
I ACTIONS BY UTAH AG ENCIES l
DRC approval (July 10, 2014 ) License
Amendment 7: Radioactive Material
License Number UT 1900479 (Dawn
Mining Alternate Feed Amendment
Request)
I
I
Director of DRC on
December 12, 2012,
approving the Nitrate CAP
at the White Mesa
Uranium Mill
Denison Mines (USA) Corp.
Radioactive Materials License
I
I
Renewal and Safety Evaluation
Report for Th e Denison Mines
White Mesa Mill 2007 License
Renewal Application
Utah Division of Air Quality Approval Or
March 3, 2011 granting a Modification t
der of
oAdd a
ge and to Baghouse, to Allow Alternative Fuel Usa
incorporate Work Practice Standards.
Figures 2a to 2c. Flow Charts for Modification of Ground Water Complia nce Limits
2a. Partial Roadmap for Groundwater Background Reports
2b. Groundwater Data Preparation and Statistical Process Flow for Calculating Groundwater
Protection Standards White Mesa Mill Site, San Juan County, Utah (from Revised Background
Groundwater Quality Report: Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill
Site, San Juan County, Utah, October 2007/'
2c. Flow Chart for GWCL Modification and Challenges by the UMUT EDP
Revised Background Groundwater Quality Report: Existing
Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site,
San Juan County, Utah, October 2007.
File: Revised_bgqr10262007t Revised Background Report.pdf
Wells: MW-1, MW-2, MW-3, MW-5, MW-11, MW-12, MW-
14,MW-15, MW-17, MW-18, MW19, MW-26, and MW-32
l
Evaluation of Available Pre-Operational and
Regional Background Data, 11/7/2007
File: Revadden11_162007PREOPPGW.pdf
Wells: MW-1, MW-2, MW-3, MW-4 and MW-5
Revised Addendum: Background
Groundwater Quality Report: New
Wells For Denison Mines (USA)
Corp.'s White Mesa Uranium Mill
Site, San Juan County, Utah (April
30, 2008}.
File: Bgq_report42008_revised.pdf
Wells: (MW-3A, MW-23, MW-24,
MW-25, MW-27, MW-28, MW-29,
MW-30, and MW-31
Background Groundwater Quality
Report for Monitoring Wells MW-
20 and MW-22, 6/1/2010
File: DUSA Background Report­
MW20&MW-22.pdf
Wells: MW-20 and MW-22
Figure 2a. Partial Road Map for Existing, Regional and Pre-Operational Groundwater
Background Reports
I>MI!'SS ��em:!IY (;i)']�$'l?rt� (TDE-on:· •: �-��� B�:or Lo. c��c�)
Od�edlo n urri Ot D ala Qualiferl
Cr.tt! � :Ill� ·::or'I'Jn'.-.o?
Figure 2b. Groundwater Data Preparation and Statistical Process Flow for Calculating Groundwater Protection Standards White Mesa Mill
Site, San Juan County, Utah (Part 1)
cl [>11.J Se15 � 8:11: PI0!8l0 IOerU!
Ellremt Value� A� ��ce���� "' Bati<Qro�� Rep::.rt_ Exlrerre v ak>e'
At Le<�SI 8 D:ll3 Polrt� ROlt'n:llrln!(l 1'-----••l Dot�rmr-,e Percent;ge Nor..OetE<tsin Remooir,inq I Oat�
L"rr.l Tr� ;tO I'll' Oota
Loo-t-�:,rrn:ol or No•rn•rl Ctrapro W•k ��:aao'nt P!im His1'-',lrdlr'�
use Non-Par.rflelrle stillt>ll<�
Groundwater Data Preparation and Statistical Process Flow for Calculating Groundwater Protection Standards White Mesa Mill Site, San
Juan County, Utah (Part 2-Fig 2b)
Uge Prot�abUtly Plots to Determne 1r Cohen's or Mchsons 1.4 eillod
Mean and Slandard
Calc\Jiate Descrl;rlle stallS11CS �BriO Tables In Ba�qound Reporb
for Trends usirg LeaS:
Rto g rt!S siOn
i..IOWar:l Trend?
Use Noo-Par.n191nt SUillillcS
Calcliate Upper Predlcton umn (Hghest His!DricaiV ofue)
Screen rorTrends Using Ka>da� Tau
UIIWil'dTrend?
·r:�!��-�i:?� :o·.-.·� •. (:�·� �;, y�·::· � � �
-�
.: r.":"':"'c: i>���-j
Groundwater Data Preparation and Statistical Process Flow for Calculating Groundwater Protection Standards White Mesa Mill Site, San
Juan County, Utah (Part 3-Fig 2b)
Ci!J.'1J � GofttLdli"'..n • �
�T�nd? l"f<<ra T"'"ro,
<;�<II� GVICL<M•� ·231�)
Figure 19 ---��.:_
Groundwater Data Preperation and Statistical Process Flow for Calculating Groundwater jntR:&l" Protection Sta ndards, White Mesa Mill Site, San Juan County, Utah ��=-
Groundwater Data Preparation and Statistical Process Flow for Calculating Groundwater Protection Standards White Mesa Mill Site, San
Juan County, Utah (Part 4-Fig 2b)
Monitoring well were classified as either old or new and data
describing water quality changes over time were examined to
estimate background concentration. The Groundwater Background
reports establish the pre-mill baseline concentrations for reference.
The baselines are used to establish initial Ground Water Compliance
Limits (GWCL).
Out of Compliance (OOC} finding for a monitoring well is reported. An OOC
finding means that concentrations of key parameters (pH, U, S04, N03 or
other metals) is higher than the GWCL for that well for 2 sampling events.
Source Assessment Report evaluates if leakage from tailings cell is responsible for
OOC. Statistical analysis of sequential water quality analyses is carried out to
determine if a trend in concentrations of key parameters is observed .
•
Ground Water Compliance
Limit is revised upward
based on EPA Guidance.
UMUT EDP challenges the revised GWCL and claims that increases
in metals concentrations and decreases in pH are due to leakage
from the tailings cells.
Site owner claims that dissolution of pyrite in saturated zone
causes decrease in pH both down gradient and upgradient of
the site and associated increase in metals concentrations are
due to natural variability.
UMUT challenges 'natural variability' based on lack of pyrite in
unsaturated zone and lack of oxygen in saturated zone available to
oxidize existing pyrite. UMUE EDP requests that additional indicator
solutes be monitored on routine basis
Figure 2c. Flow Chart for GWCL Modification and Challenges by the UMUT EDP
Table 1. Summary of Road map Level l Documents
Date Document Title Author/Recipient Main points Referenced by:
Refers to: Document
#
8/11/2014 PETITION TO INTERVENE IN From: H. Michael II. Tribe has legal interests in Amendment Ref to: 1. License
SUPPORT OF REQUEST FOR Keller (Special 7. DRC's approval of License Amendment 7 (to
AGENCY ACTION Counsel Ute Amendment 7, is contrary to applicable Radioactive Material
Contesting the Utah Division of Mountain Ute law, is arbitrary and capricious and License Number UT
Radiation Control's ("DRC") Tribe) beyond the tolerable limits of reason, .. 1900479).
decision approving the July 10, To: Utah DEQ failure and refusal to properly evaluate 2. PPS Summary,
2014 License Amendment 7: the environmental impacts of .. or License Amendment,
Radioactive Material License to .. minimizes danger to public health and July 10, 2014.
Number UT 1900479 (also safety or the environment ... require EFRI 3. CAP N03 RAA?
referred to as the Dawn Mining to address ongoing and uncontrolled 4. UMUT comments
Alternate Feed Amendment contamination and serious operational on RML Renewal
Request) deficiencies at the WMM facility) prior to (12/16111)
issuing License Amendment 7. 5. UMUTs 'extensive
Request: public comments of
1) determinations in response to Tribes October 13, 2013' comments at PPS be reversed and vacated 6. 'Exhibit A?'-, 2) approval of License Amendment 7 be probably 2-4 above.
reversed and remanded to DRC that DRC
only renew the RML after EFRI has
addressed their concerns ..
1/11/2013 REQUEST FOR AGENCY From: Michael Contests the Decision, signed by the Exhibit A: December
ACTION -In the Matter of: Keller (Special Director of DRC on December 12,2012, 16,2011 RML
Stipulation and Consent Order, Counsel Ute approving the Nitrate CAP at the White Comments
Docket No. UGW12-04, Mountain Ute Mesa Uranium Mill ("WMM") and Exhibit B: April 2012
Regarding Approval and Tribe) responses to the Tribe's public comments. Letter
Stipulations fo r the Energy Fuels To: Utah DEQ " DRC has also issued determinations in Exhibit C:August
Resources (USA) Inc. May 7, the Public Participation Summary (and in 2012 Nitrate CAP
2012 Corrective Action Plan fo r support of the Nitrate CAP) that are not Comments
Nitrate, White supported by substantial evidence when Exhibit D: Stipulated
Me sa Mi ll viewed in ligh t of the whole record, that Consent Agreement,
2
are arbitrary and capricious, and that are Docket No. UGW12-
) beyond the tolerable limits of reason." 03
In its December 2011 RML Comments, Exhibit E:October
the August 2012 Nitrate CAP Comments, 2012 Letter
and the April 2012 and October 2012 Exhibit F: Initial List
Letters, the Tribe has provided DRC of Factual
(Exhibits A, B, C, and E) a detailed Inaccuracies
analysis of its concerns with groundwater Exhibit G: Excerpt
contamination at the WMM facility. from Tailings Cell 1
Repair Photographs
12/16/2011 Comments Regarding Denison From: Celene II. Regulatory issues Referred by: RAA
Mines (USA) Corp. Hawkins III(A) groundwater contamination; N03 CAP (Table 2)
Radioactive Materials License Associate General III(B) air deposition/surface Refers to: Exhibits A
Renewal DRC-045 (a.k.a Counsel contamination; and -T. (see Table 3)
UMUT Searchable Comment Ute Mountain Ute III(C) special contamination issues with
Letter) Tribe and H. alternative feed materials.
Michael Keller N(A) DUSA's reclamation plan not
Special Counsel protective health ofUte'.
Ute Mountain Ute N(B) RML Renewal fails to provide
Tribe/ adequate surety.
To: Rusty
Lundberg
Director
Utah Division of
Radiation Control
3/31/2011 REQUEST FOR AGENCY From: S. Claw, UMUT contests AO of 3/2111 to Ref to: 1. USGS
ACTION in Matter of Approval UMUT EPD authorize mod to add Baghouse, alt fuel report (Ex L
Order of March 3, 2011 granting To: Utah Air usage and work practice stds. UMUT3). 2. multiple
a Modification to Add a Quality Board It fails to comply with Clean Air Act and amendments to AOs.
Baghouse, to Allow Alternative other Utah regs. 3. DAQ Memo in
Fuel Usage and to incorporate 1. Work Practice Stds for Control Response to
W ark Practice Standards. Fugitive Dust Comments
2. Provisions insufficient to minimize (2/24/20 11)
fugitive dust and protect tribe. 4. Exhibit 1: Moab
3. no BACT for fugitive dust control Site Dust Plan (2002)
3
4. Feb 24 memo not address Tribe's 5. Crescent Junction
comments Dust Plan (7 /2006)
5. DAQ does have authority to regulate 6. Work Practice Stds
this for Control of
Fugitive Dust (no
date)
4
Table 2. List of Exhibits Supporting RAA Nitrate CAP
Exhibit
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Title
Comments Regarding Denison Mines (USA) Corp. Radioactive
Materials License Renewal DRC-045
April 2012 Letter: Letter from Scott Clow to Rusty Lundberg Re:
Fo llow Up on Groundwater Issues; Denison Mines (USA) Corp.
Radioactive Ma terials License Renewal DRC-045
August 2012 Nitrate CAP Comments: Comments Regarding
Denison Mines (USA) Corp., White Me sa Uranium Mill
Corrective Action Plan, UG W12-04
Stipulated Consent Agreement, Docket No. UGW12-03
October 2012 Letter: Letter from Scott Clow to Rusty Lundberg
Re: Transfe r Action and New Groundwater Enforcement Action
UG W1 2-03, White Mesa Uranium Mill
Initial List of Factual Inaccuracies: "extensive list of the fa ctual
inaccuracies contained in the Public Participation Summary"
Excerpt from Tailings Cell 1 Repair Photographs DMT Performance
Standards Monitoring Report and Cell 4A BAT Performance Standards
Monitoring Report for the 2nd Quarter of2012 (August 22, 20 12) [hereinafter
"DMT Report"]. Page 427 of Appendix 5. (Repair Photographs)
--·-------
i
5
Table 3. Summary Documents Supporting 'RAA Air Quality/dust'
Date Document Title Author/Recipient Main points Referenced by:
Refers to:
Document #
3/31111 Exhibit B: Request for Agency From: Scott Clow UMUT UMUT contests AO of 3/211 1 to Ref to: 1. USGS
Action EPD authorize mod to add Baghouse, alt report (Ex L in
In the Matter of: Approval Order-To: Utah DEQ Air Quality fuel usage and work practice stds. UMUT3).
Modification to Add a Baghouse, Board It fails to comply with Clean Air Act 2. multiple
to Allow Alternative Fuel Usage and other Utah regs. amendments to AOs.
and to Incorporate Work Practice 1. Work Practice Stds for Control 3. UMUT EPD
Standards-Denison Mines (USA) Fugitive Dust memo of June 2007
Corporation, White Mesa Mill. 2. Provisions insufficient to minimize re: dust event.
fugitive dust and protect tribe. 4. 9/4/2007 UMUT
3. no BACT for fugitive dust control letter to DAQ re:
4. Feb 24 memo not address Tribe's human health threat
comments of dust.
5. DAQ does have authority to 5. DAQ memo of
regulate this. 2/24111 response
Requests: 6. Exhibits 1-3
1) AQ rescind March AO below
2) acknowledge jurisdiction for dust
control
3) Review USGS report for off-site
migration
4) undertake and require BACT
analysis by DUSA
5) revise AO to require that work stds
provide monitoring etc of dust.
2/24/2011 DAQ Memo in Response to Need to obtain
UMUT Comments
3/2002 Exhibit 1: Moab Project Site USDOE Idaho Operations Fugitive Dust Control Plan (Plan) to Fugitive dust
Fugitive Dust Control Plan Office Grand Junction address the control of fugitive and standards and action
GJ0-20020301-TAR, GJO-MOA Office airborne dustemissions from the Moab levels.
1.7-1 Project Site (Moab Site) Moab, Utah.
7/2006 Exhibit 2: Crescent Junction Dust DOE Office of Fugitive Dust Control Plan (Plan) Numerous DOE,
Plan; DOE-EM/GJ1235-2006 Environmental addresses the control of fugitive and NRC, docs, MSD
6
Management -Grand airborne dust emissions from the sheets fo r dust
Junction Crescent Junction Site of the Moab, suppressants.
Utah, Uranium Mill Tailings Remedial Fugitive dust
Action (UMTRA) Project, located standards and action
approximately 1.5 miles northeast of levels.
Crescent Junction, Utah.
No date Exhibit 3: White Mill Mesa DUSA? 2.5 page document that refers to 10 Approval Order
Work Practice Standards for and 15% opacity limits used to DAQE-
Control of Fugitive Dust: Ore monitor activities and data recording AN0112050008-08
Receipt and Front Loader requiments.
Operations
7
Table 4. Summary OfExhibits UMUT Comments
Date Document Title Author/Recipient Main points Referenced by:
Refers to:
Document #
1. 4/6/2011 Exhibit A: Government-to-1. From: A. Smith 1. Migration of Fugitive Dust Refto: 1. Stipulated
2. 1112/11 Government Correspondence, (DEQ) 2. Insufficient regulation of radon Consent Agreement
3. 11/5/11 UMUT/DEQ To: R. Jenks (Ute 3. Tailing cell failures and (9/30/11).
Tribe)(wrong inadequate leak detection system 2. CAP for N03
Tribe) 4. Inadequate closure plan 3. Infiltration and
2. From: S. Claw 5. Inadequate financial security (at Contaminant
(UMUT EP) Transport Modeling
To: A. Smith least an order of magnitude. Plan.
(DEQ) 4. Reclamation Plan
3 .from: A. Smith (doc 3 answers doc2)
(DEQ) to: S. Claw
(UMUT EPD)
3/31/11 Exhibit B: Request fo r Agency From: Scott Claw UMUT contests AO of 3/2111 to Ref to: 1. USGS
Action IN the Matter of UMUT EPD authorize mod to add Baghouse, alt report (Ex L
Approval Order Modification to To: Utah DEQ Air fuel usage and work practice stds. below). 2. multiple
Add a Baghouse, to Allow Quality Board It fa ils to comply with Clean Air Act amendments to
Alternative Fuel Usage and to and other Utah regs. AOs.
Incorporate Work Practice 1. W ark Practice Stds for Control 3. DAQ Memo in
Standards Denison Mines (USA) Fugitive Dust Response to
Corporation White Mesa Mill 2. Provisions insufficient to minimize Comments
fugitive dust and protect tribe. (2/24/20 11)
3. no BACT for fugitive dust control 4. Exhibit 1: Moab
4. Feb 24 memo not address Tribe's Site Dust Plan
comments (2002)
5. DAQ does have authority to 5. Exhibit 2
regulate this Crescent Junction
Dust Plan (2006)
6. Exhibit 3. Work
Practice Stds fo r
Control of Fugitive
8
Dust
Exhibit C: Identification of From: UMUT EPD EDP: assessment indicates that Refers to:
Potential Tailings Cell Influence To: Utah DRC contamination originating from the
in Groundwater at White Mesa tailings cells is present in the
Mill groundwater at the southern
boundary of the Mill's monitoring
network. DUSA's groundwater travel
time of 0.33-0.43 feet per year is not
scientifically supportable due to
indications of modem water in the
well
2/1 1199 Exhibit D: February 11, 1999 From: Sinclair; Dir 1. For more than a decade, DRC has Letters to IUC on
Letter to David C. Frydenlund of DRC documented its concerns about 118/99 and 1121/99.
(VP DUSA) To: David C. groundwater contamination resulting Knight Piesold
Frydenlund (VP from potential seepage from the modeling reports of
DUSA) tailings impoundments at the WMM. 11123/98 and
2. DRC's concern that DUSA was 12/3 1198.
not using "smoking gun" leakage
parameters such as "ammonia,
nitrate, nitrite, molybdenum and
sulfate" during the groundwater
monitoring (emphasis supplied.
1. Tailings liner systems Cells 1,2,3
inadequate; models used inadequate
w/o sensitivity analysis of
performance.
2.LDS inadequate to detect all but
catastrophic leaks.
3 . fracture flow potential decrease
travel time from leak to perched
aquifer from 1300 yr to a few weeks
under worst case conditions.
4. GW Monitoring program inadequate
because it doesn't test for relevant
9
organics and inorganics likely present
fr om acid leach processing of uranium
ores and Ashland 2 FUSRAP material.
No date; Exhibit E: Chloride Citations From: DUSA chloride, nitrate, and nitrite are Refers to several
just table To: DRC primary indicators of tailing cell docs: 1981 to 2010.
leakage
6/27/2000 Exhibit F: June 27, 2000 Memo FROM: Loren unlikely that any leak detection
to Dane Finerfrock Morton, DRC system exists under Cell 1 and
To: Dane stating that the system under Cells 2
Finerfrock and 3 is "grossly inadequate").
Contains 9 specific problems that
DRC wanted IUC to address.
12/16/2011 Exhibit G: EPD Review of CAP From UMUT EPD Review finds CAP for Nitrate (and Cl)
To: DRC (part of to be deficient because it isn't
review ofDUSA protective of pH and environment,
RMLR) have permanent effe ct and ensure that
discharge achieves GW Quality stds or
ACACLs.
12/1/2011 Exhibit H: RRD Letter From M. Smith, The liners in Tailings Cells 1, 2, and Numerous
RRD· ' 3 have passed their useful life. references to
To: C. Hawkins l.The thin, 30-mil polyvinyl chloride literature from
UMUT ("PVC") liners on Tailings Cells 1, 2, 1990s to 2010 from
and 3 were not best available industry studies of
technology when they were installed liners, barriers, and
in the late 1970s. cost analysis of
2. this type of thin PVC liner cannot remediation.
last 30 years in an acidic Section 2.5 referred
environment. to numerous places
3. the liners in Tailings Cells 1, 2, as basis for
recommendations and 3 have been further in UMUT II.a.l.i. compromised by the placement of Comments incompatible alternative feed
material in the cells.
4. the capping ? cost estimate
($1 7. 7M?) that Dension uses is too
10
low by a factor of 2.5 to 5 based on
comparison with other similar
facilities and 2 cost estimating
methods.
2/27/2008 Exhibit I: DOE Letter Re: 2035 From:M. Owen WMU Mill operates under NRC
DOE Receipt (Closure) DO E-LM license and regulated by Utah which is
To: House, UMUT an NRC Agreement state. DOE-LM
will take over in 2035.
9/30/20 11 Exhibit J: Amended Stipulated Signed by D. 1. described events from 1127/2009 to
Consent Agreement, September Frydenlund 8/25/20 11.
30,2011 (DUSA) and R. 2.requires DUSA to submit CAP for
Lundberg (UWQB) N03 with 3 phases of activity by
11/30/2011 for approval by Utah
Water Quality Board.(UWQB)
12116/20 11 Exhibit K: Description of the From: UMUT 2 deep supply wells in Navajo Fm; NV
White Mesa Water System EDP Fm begins at 900 ft; ; static water table
to: DRC (part of in wells is about 450 ft.
review ofDUSA
RMLR)
2011 Exhibit L: USGS Report (on USGS Report Tribe uses report to support assertions:
disc) 1. U and V has migrated east of WMM
Naftz, D.L., Ranalli, A.J., Rowland, fa cility
R.C., and Marston, T.M., 2011, 2. offs ite migration begins with Assessment of Potential Migration of airborne dust and spread as washed Radionuclides and Trace Elements from
the White Mesa Uranium Mill to the Ute down drainages.
Mountain Ute Reservation and 3. concern that this contaminates
Surrounding Areas, Southeastern Utah: vegetation, livestock and endangers U.S. Geological Survey Science human health. Investigations Report 201 1-523 1. Abstract ofUSGS report says: 1)
young age of water indicates local
recharge of shallow aquifer including
'potential' from seepage from
constructed wetlands wildlife refuge
ponds near the mill. 2) Water in
Entrance Spring may come from
Recapture Reservoir used on site and
11
by Blanding field irrigation after
evaporation. 3) Sulfur isotopes indicate
potential contamination link between
cells and refuge ponds could be related
to aerosols transport; .4) U isotope
data indicate mill is not source of
uranium in any site monitored but U-
isotopes indicate the aeolian transport
of small particles from ore storage
pads and uncovered ore trucks could
occur but only at that site. 5) Entrance
Spring is distinguished: highest [U],
[Se, V], U-isotope ratios not consistent
with natural sources. Plants downwind
of mill had elevatedU and V,
indicating offs ite transport. 6)[U] in
GW is not good indicator of
contamination because it is affected by
local sources, evaporation but soils and
vegetation may be better indicator of
offs ite migration.
7/6/2012 Exhibit L: DRC Review DRC review of Summarizes 9 USGS To Exhibit L
presentation USGS report 2012 recommendations: DRC agrees with 7
USGS Report of them, disagrees with 1 and partial
070612 agrees with 1.
11116/2011 Exhibit L: USGS presentation on Wed2 6whitemesa Summary ofUSGS report and To: Exhibit L
USGS studies Ranalli, Larrick, comparison to results of well studies at
WREQC team Wind River UMTRA site.
12116/2011 Exhibit M: Bioavailability, From: UMUT EPD Basis of Tribes demand for monitoring IAEA (20 1 O)trf172,
Bioaccumulation and Food Chain to: DRC (part of for airborne samples a ground level. Thomas (1995,
Transfer of Airborne review of DUSA Food chain transfer ofU-series U-238; 1997, 1999)-Arctic
Radionuclides RMLR) Ra-226, Pb-2 10; Po-210.; air borne studies. NM EID
dispersion of dust fr om tailings. Tribal (1986) study of
members traditionally harvest wildlife livestock near
and plants for consumption and mines and tailings.
12
2/24/20 11 Exhibit N: Response Memo (AO) From: M Maung
Response to comments on DAQ/DEQ
DAQE-IN01120500 18-10, To: Denison White
Comments fr om public comment Mesa Source Fi ie
period from various people
including the Tribe.
3/2/2011 Exhibit 0: Approval Order From : Heying
Modification to add a baghouse, (Exec Sec Utah Air
to allow alternate Fuel usage and Quality Board and
incorporate work standard Dir DAQ)
practices. To: Tischler
(DUSA)
ceremonies. What is likely does under
different scenarios? Relevance of
Thomas studies and NM EID study
from 1986?.
AO documents work practices
standards to control fugitive dust
See IUCIUGW for location and initial
permitting of the White Mesa facility:
www .radiationcontrol. utah.gov!Uraniu
m Mills/IUC/Denison IUCIUGW ren ---
ewal.html
Clear objections from Tribe based on
concern about fugitive dust emission
and response from DAQ which
rejected the Tribal requests ..
Fugitive dust emissions controlled by
Workplace practices.
1) opacity at emission points 10% to
20%.
2) PMlO at various emission points
3) Fugitive from roads and equipment
in operations areas < 20% opacity
4) unpaved roads and operational areas
Thomas refs are
incomplete. see also
IAEA srsl9
Refers to:
0. Exhibit 0 (draft)
1. UAC R307-410
modeling
thresholds for air
dispersion
modeling
2. State ofUtah
RadMat License
UT 19004 79 for
stack testing
emissions
3. UAC-19-2-
107(2)(d)
inspections
4. Final
Environmental
Statement Related
to Operation of
White Mesa
Uranium Project
Energy Fuels
Nuclear, Inc. 1979
R307-401-8
40CFR Part 60
Appendix A,
Method 9:
observations of
emissions.
13
kept moist to keep opacity < 20%.
5) record kept fo r cleaning paved roads
6) requirements made by Exec
Secretary. (M. Cheryl Heying).
12116111 Exhibit P: Deficiencies in From: UMUT EP 1. determine why the monitoring did By:UMUT
DUSA's Environmental To: DRC re: not detect the airborne migration of Comments B.2.a p.
Monitoring Program comments of Radioactive Material 16.
DUSA RML 2. Provides initial technical
Renewal comments on improvements to the
semi-annual effluent monitoring
program. Failures: water and soil
sample location; air sample location;
estimate of background; not enough
rads isotopes; poor QAJQC/SOP
systems; bias and nonobjective
monitoring program.
3. provides refs on bio-uptake of rads
Various Exhibit Q: Brown Letter with 1. From: Herbert UMUT Comment Letter: DRC's by: UMUTC.1.a
1999: Attachments (DRC) concern with liner incompatibility p19
1: 4/16/99 CERCLA off-site rule (OFR) To: Nielson (DRC) with alternative feed materials. to: 1. Knight
2: 4/7/99 determination 2. From: Sinclair Summary: DRC wants IUSA to get Piesold (1998)
3: 3/9/99 (DR C) GW discharge permit. Methodology fo r
4: 2/11199 To: T. Brown Letters deal with: Calculation of Flux
5: 1/21199 (EPA-8) 3: alternate feed materials concerns Through the Cell
6: 2/12/99 3-6: other letters 4: GW protection from potential Liner, Dec 31,
between IUSA, seepage 1998.
DRC, consultant, 5: DRC questions validity of 2. Titan
Utah AG office. assumption in model for Cell 3 lining Environmental
system Report (1994)
6: Consultant to IUSA defends Hy drogeologic
modeling : 1300 y travel time from Evaluation of White
liner to perched water zone. Mesa Uranium Mill
12/16/20 11 Exhibit R: Particular Concerns From: UMUT EPD 1. DUSA is Not Properly Monitoring
with Alternative Feed Material Disbursement of Components ofthe
-
14
Alternative Feed Material
2. Alternative Feed Material is More
Susceptible to Wind Dispersion than
Other Licensed Materials at the WMM
Facility.
3. DUSA is Not Properly Modeling the
Dose Assessment of Alternative Feed
Material.
3/28/2003 Exhibit S: Sampling Memo : To: H. Roberst (VP 1. Dissolved VOC contaminant plume Refers to:
Sampling Results from Passive Int. Uranium Corp) in Wells but not DNAPL 1) 5/3/02 rue PDP
Diffusion Bag Samplers, August From: WJ Sinclair 2) VOC analytic methods Sampler Work Plan
14,2002 GW Split Sampling (DEQ/DRC). improvement needed: MDLs for 6 2) DRC worksheets
Event at rue WMU Mill: DRC VOCs need to be implemented to PDBagags.xls
Results, Findings and Request for allow determination whether State (missing),
Action GWQS had been exceeded.
3) need to add 3 new VOCs to list
4) a THM compound is not really there
5) request continued cooperation in
characterization and cleanup of a the
VOC plume.
12/16/11 Exhibit T: Reclamation Plan From: UMUT EPD 1. Reclamation Plan Provisions for Ref by:UMUT
Deficiencies I Reclaiming Cell 1 Are Insufficient Ref to:
Clay liner insufficient 1. Attachment A,
Storm water sediments basin leads Plans and
to water seepage into waste. Technical
2. Storm Water Discharge Channel Specifications fo r
West of Cell 1 Violates the Storm Reclamation fo r
Water Management Plan and Risks White Mesa Mill
Contaminating Westwater Creek Facility, Blanding
with Radioactive Material from the Utah
Mill Yard 2. RRD Letter
3. Reclamation Plan Needs (Exhibit H above)
Clarification on Placement of 3. Storm Water
15
Contaminated Soil
a. all contaminated soils should go
into the last operational tailings
disposal cell.
b. require that all contaminated soil
be placed in the last operational
tailings disposal cell
c. It should be clear exactly where
the contaminated soils, raffinate
crystals from Cell 1 and other
radioactive materials are to be
disposed of permanently.
Reclamation Plan 5.0 offers too
much flexibility in the locations of
radioactive material disposal
4. Scoping Survey Is Insufficient
a. 90% of the facility unscanned at
best
b. should be conducted across the
entire facility and adj acent property
such as the highway right of way not
only in areas expected to be
contaminated .
c. relies on antiquated data to
determine the radium "background"
as 0.93 pCi/g fr om 16 years of
monitoring conducted during the
1980's and 1990's when
5. Soil Sampling Plan is Insufficient
a. 30m x 30m grid sampling , 10%
effective scoping survey , averaged
over "any" 1OOm2 are not defensible
because of infinite number of
potential calculations for compliance
assessment.
Management Best
Practices Plan
4. White Mesa
Mill Tailings
Reclamation,
Sediment Basin
Design, sheet
REC-3,MWH,
09/2011
16
6. Animal Intrusion Analysis is
Weak
a. reclaimed cell caps will likely
become good habitat once again.
17
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