DRC-2019-017284 - 0901a06880baa5e9

FERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.corn
December 23, 2019
SENT VIA OVERNIGHT DELIVERY
ORC--.26c9— O 17Z5 Div of Waste Management and Radiation Control
DEC 3 0 2019
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Re: Application by Energy Fuels Resources (USA) Inc. ("EFRI") for an amendment to
State of Utah Radioactive Materials License No. 1900479 for the White Mesa Uranium Mill
(the "Mill") to authorize processing of Union Pacific Railroad ("UPRR"), Moffat Tunnel
alternate feed material (the "Uranium Material")
Dear Mr. Howard:
Attached pleased find two copies of an application to amend the Mill's Radioactive Materials
License No. 1900479 to authorize receipt and processing of the Uranium Material as an alternate
feed material primarily for the recovery of uranium and disposal of the resulting tailings in the
Mill's tailings impoundments as 1 le.(2) byproduct material.
These materials are the solids resulting from mechanical and inorganic treatment of native
groundwater pumped for dewatering of the Moffat Railroad Tunnel, conducted in Union Pacific
Railroad's ("UPRR") water treatment plant (the "WTP") in Winter Park, Colorado.
If you should have any questions regarding this amendment application, please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
ce: David Frydenlund
Mark Chalmers
Paul Goranson
Logan Shumway
Terry Slade Scott Bakken
December 23, 2019
SENT VIA OVERNIGHT DELIVERY
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www .energyfuels.com
Re: Application by Energy Fuels Resources (USA) Inc. ("EFRI") for an amendment to
State of Utah Radioactive Materials License No. 1900479 for the White Mesa Uranium Mill
(the "Mill") to authorize processing of Union Pacific Railroad ("UPRR"), Moffat Tunnel
alternate feed material (the "Uranium Material")
Dear Mr. Howard:
Attached pleased find two copies of an application to amend the Mill's Radioactive Materials
License No. 1900479 to authorize receipt and processing of the Uranium Material as an alternate
feed material primarily for the recovery of uranium and disposal of the resulting tailings in the
Mill's tailings impoundments as 1 le.(2) byproduct material.
These materials are the solids resulting from mechanical and inorganic treatment of native
groundwater pumped for dewatering of the Moffat Railroad Tunnel, conducted in Union Pacific
Railroad's ("UPRR") water treatment plant (the "WTP") in Winter Park, Colorado.
If you should have any questions regarding this amendment application, please contact me.
Yours very truly,
{d:CU(Jfr~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David Frydenlund
Mark Chalmers
Paul Goranson
Logan Shumway
Terry Slade
Scott Bakken
REQUEST TO AMEND
RADIOACTIVE MATERIAL LICENSE
ENERGY FUELS RESOURCES (USA), INC.
WHITE MESA URANIUM MILL
SAN JUAN COUNTY, UTAH
AND
ENVIRONMENTAL REPORT
for
Processing of
Alternate Feed Material
from
Union Pacific Railroad Moffat Tunnel
Prepared for:
Utah Department of Environmental Quality
Division of Waste Management nd Radiation Control
P.O. Box 144850
Salt Lake City, UT 84114-4850
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600,
Lakewood, CO 80228
December 2019
Energy Fuels Resources (USA) Inc.
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................................... 1
1.1 WHITE MESA MILL. ........................................................................................................................................... l
1.2 PROPOSEDACTION ............................................................................................................................................ l
1.3 PURPOSE OF ACTION ......................................................................................................................................... 1
1.4 AMENDMENT APPLICATION AND ENVIRONMENTAL REPORT ...................................................................................... 2
2.0 MATERIAL COMPOSITION AND VOLUME ..................................................................................... 2
2.1 GENERAL ......................................................................................................................................................... 2
2.2 HISTORICAL SUMMARY OF SOURCES ..................................................................................................................... 2
2.3 QUANTITY OF MATERIAL .................................................................................................................................... 3
2.4 RADIOCHEMICAL DATA ....................................................................................................................................... 3
2.5 PHYSICAL AND CHEMICAL DATA ........................................................................................................................... 3
2.6 COMPARISON TO OTHER ORES AND ALTERNATE FEED MATERIALS LICENSED FOR PROCESSING AT THE MILL ...................... .4
2.6.1 Ores and Alternate Feed Materials with Similar Radiological Characteristics ...................................... 4
2.6.2 Ores and Alternate Feed Materials with Similar Chemical/Metal Characteristics ................................. 4
3.0 REGULATORY CONSIDERATIONS ................................................................................................... 4
3.1 ALTERNATE FEED GUIDANCE ............................................................................................................................... 4
3.2 URANIUM MATERIAL QUALIFIES AS "ORE" ............................................................................................................ 4
3.3 URANIUM MATERIAL NOT SUBJECT TO RCRA ........................................................................................................ 5
3.3.1 General .................................................................................................................................................... 5
3.3.2 EFRI!UDEQ Listed Hazardous Waste Protocol ...................................................................................... 5
3.3.3 Application of the Listed Hazardous Waste Protoco/.. ............................................................................ 6
3.3.4 Radioactive Material Profile Record ....................................................................................................... 8
3.3.5 Conclusion ............................................................................................................................................... 8
3.4 URANIUM MATERIAL IS PROCESSED PRIMARILY FOR ITS SOURCE MATERIAL CONTENT .................................................... 8
4.0 AFFECTED ENVIRONMENT ............................................................................................................... 9
4.1 GENERAL ......................................................................................................................................................... 9
4.2 TRANSPORTATION CONSIDERATIONS ................................................................................................................... 11
4.2.1 Packaging and Mode of Transportation ................................................................................................ 11
4.2.2 Transportation Impacts ........................................................................................................................... 12
4.2.3 Transportation Accidents ....................................................................................................................... 13
4.3 STORAGE ....................................................................................................................................................•.• 14
4.3.1 Manner of Storage ................................................................................................................................. 14
4.3.2 Environmental Impacts Associated With Storage .................................................................................. 14
4.4 PROCESS ....................................................................................................................................................... 14
4.4.1 Mill Accidents and Emergency Response .............................................................................................. 15
4.5 COMPATIBILITY WITH EFRI MILL TAILINGS ........................................................................................................... 15
4.5.1 Physical Compatibility ........................................................................................................................... 15
4.5.2 Capacity and Throughput ...................................................................................................................... 16
4.5.3 Mill Tailings Closure and Reclamation ................................................................................................. 17
4.6 GROUNDWATER .............................................................................................................................................. 17
4.7 SURFACE WATER ............................................................................................................................................ 18
4.8 AIRBORNE RADIOLOGICAL IMPACTS .................................................................................................................... 19
4.9 RADON AND GAMMA IMPACTS .......................................................................................................................... 19
4.10 SAFETY MEASURES .......................................................................................................................................... 19
4.10./ General .............................................................................................................................................. 19
Request to Amend Radioactive Materials License
Energy Fuels Resources (USA) Inc.
4.10.2 Radiation Safety ................................................................................................................................ 19
4.10.3 Occupational Safety .......................................................................................................................... 20
4.10.4 Vehicle Scan ...................................................................................................................................... 20
4.11 LONG TERM IMPACTS ...................................................................................................................................... 21
4.12 OTHER OPERATIONAL CONSIDERATIONS .............................................................................................................. 21
4.13 ADDED ADVANTAGE OF RECYCLING .................................................................................................................... 21
4.14 CONSIDERATION OF ALTERNATIVES ..................................................................................................................... 21
5.0 CERTIFICATION ................................................................................................................................. 22
ATTACHMENTS
Attachment 1 Union Pacific Railroad Water Treatment Plant Location Map
Attachment 2 Radioactive Material Profile Record and Affidavit
Attachment 3 EFRI/UDEQ Protocol for Determining Whether Alternate Feed Materials are
RCRA Listed Hazardous Wastes
Attachment 4 Review of Chemical Contaminants in Union Pacific Railroad Uranium Material to
Determine the Potential Presence of RCRA Characteristic or RCRA Listed
Hazardous Waste
Attachment 5 Review of Chemical Contaminants in Union Pacific Railroad Uranium Material to
Determine Worker Safety and Environmental Issues and Chemical Compatibility
at the EFRI White Mesa Mill
Attachment 6 Cross Index to Utah DEQ Interrogatory Template for Review of License
Amendment Requests and Environmental Reports under UAC R313-24
Request to Amend Radioactive Materials License ii
Energy Fuels Resources (USA) Inc.
1.0 INTRODUCTION
1.1 White Mesa Mill
Energy Fuels resources (USA), Inc. ("EFRI") operates the White Mesa Uranium Mill (the
"Mill") located approximately six miles south of Blanding, Utah. The Mill processes natural
(native, raw) uranium ores and alternate feed materials. Alternate feed materials are uranium-
bearing materials other than natural ores, that meet the criteria specified in the United States
Nuclear Regulatory Commission's ("NRC's") Interim Position and Guidance on the Use of
Uranium Mill Feed Material Other Than Natural Ores (November 30, 2000) (the "Alternate
Feed Guidance"). Alternate feed materials are processed as "ore" at the Mill primarily for their
source material content. As a result, all waste associated with this processing is 1 le.(2)
byproduct material.
1.2 Proposed Action
This is a request for an amendment to State of Utah Radioactive Materials License No. UT
1900479 to authorize receipt and processing of certain uranium containing materials. These
materials are the centrifuge cake resulting from mechanical and inorganic treatment of native
groundwater pumped for dewatering of the Moffat Railroad Tunnel, conducted in Union Pacific
Railroad's ("UPRR") water treatment plant (the "WTP") in Winter Park, Colorado. For ease of
reference, the uranium-bearing material that results from this process, described further in
Section 2, is referred to herein as "Uranium Material".
1.3 Purpose of Action
The Uranium Material contains greater than 0.45% uranium on a dry basis. The WTP treats
pumped groundwater to remove metals and radionuclides prior to discharge of treated water to
the Fraser River. The WTP produces filtered solids which are then dewatered in a centrifuge to
produce a centrifuge cake that is packaged in closed drums for off-site recovery or disposal. The
Uranium Material consists of the centrifuge cake only.
Prior to 2019, UPRR periodically disposed of the Uranium Material at various off-site waste
disposal facilities. Because the Uranium Material contains elevated levels of naturally-occurring
radionuclides, Colorado Department of Public Health and the Environment ("CDPHE") required
in 2018 that UPRR apply for a Radioactive Materials License, and demonstrate that it ha:s
identified an off-site location suitable for disposal or recovery of radioactive material.
EFRI has been requested by UPRR to make this application to process the Uranium Material as
an alternate feed material at the Mill and to dispose of the resulting tailings in the Mill's tailings
management system as 1 le.(2) byproduct material. Approval of this application will:
1. allow the recovery of valuable uranium, a resource that would otherwise be lost to direct
disposal, and
2. allow UPRR to meet the requirement of the CDPHE to confirm a licensed off-site
destination for the Uranium Material.
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Reprocessing at the Mill will afford UPRR a cost-effective and productive mechanism for
managing the material generated.
1.4 Amendment Application and Environmental Report
This application is intended to fulfill the requirements of an application for an amendment to the
Mill's Radioactive Materials License set out in Utah Administrative Code ("UAC") R3I3-22-38
and includes the Environmental Report required by UAC R3I3-24-3 to be contained in such an
application.
For ease of review, this application contains a cross reference to the Utah Division of Waste
Management and Radiation Control's ("DWMRC's") Interrogatory Template for Review of
License Amendment Request and Environmental Report under UAC R313-24 that was provided
to EFRI. The cross reference is provided in a table format in Attachment 6.
2.0 MATERIAL COMPOSITION AND VOLUME
2.1 General
The Uranium Material was generated by treatment of natural groundwater from dewatering of
the Moffat railroad tunnel ("Moffat Tunnel"). The groundwater contains naturally occurring
radioactive material ("NORM") from contact with native rock, and picks up inorganic solids
particles as it passes through the tunnel. As a result, the groundwater requires treatment to meet
CDPHE discharge standards prior to release to the Fraser River.
2.2 Historical Summary of Sources
Groundwater is pumped from the Moffat Tunnel at approximately 200 gallons per minute
("gpm") for dewatering. Prior to discharge of the pumped water to surface receiving waters, it is
pre-treated by an ultrafiltration and centrifugation system to meet CDPHE standards for
radionuclides and inorganic constituents.
The Uranium Material was generated from a continuous process, as described below, driven by
the requirement to achieve discharge permit limits in the water released from the WTP to the
Fraser River. No other water sources or wastes are treated in the WTP.
The Uranium Material is comprised only of the centrifuged solids. No other materials or wastes
are added to the Uranium Material. The Uranium Material contains approximately 75-83%
moisture content (average 78% moisture) and contains up to 0.49% natural uranium on a dry
weight basis.
EFRI has been requested by UPRR to make this application to process the Uranium Material as
an alternate feed material at the Mill and to dispose of the resulting tailings in the Mill's tailings
management system as 1 le.(2) byproduct material, in an effort to provide UPRR with an option
for ultimate processing and disposal of the Uranium Material. By providing UPRR with the
option of processing the Uranium Material at the Mill, UPRR will be given the option of
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Energy Fuels Resources (USA) Inc.
recycling the Uranium Material for the recovery of valuable uranium, a resource that would
otherwise be lost to direct disposal.
2.3 Quantity of Material
The WTP will be required to operate indefinitely, as long as the Moffat Tunnel remains in
service. To date, Uranium Material produced since the start-up of the WTP has been removed
from the WTP site and disposed elsewhere. There is no current accumulated backlog of material
on site at the WTP. UPRR anticipates that the WTP will continue to produce a maximum of
approximately 100 tons per year on a wet basis, or approximately 25 tons per year on a dry basis,
indefinitely.
This application ant1c1pates that the Mill could potentially receive the Uranium Material
indefinitely. In order to accommodate potential future expansion of the Moffat Tunnel and a
range of dewatering rates, EFRI has anticipated dewatering and centrifuge cake production up to
twice the current rate, that is, a maximum of approximately 200 tons per year on wet basis and
50 tons per year on a dry basis. Therefore, this request for Amendment is for approval of up to
approximately 5,000 tons dry weight of Uranium Material, to ensure that all the Uranium
Material is covered by this Amendment.
2.4 Radiochemical Data
The Uranium Material consists of centrifuge dewatering solids from the treatment of naturally-
occurring groundwater. The Uranium Material contains approximately 0.5 percent natural
uranium and very low levels of other radionuclides, including thorium isotopes, which are
present at much lower levels than in other alternate feed materials. The derived air
concentrations ("DACs"), radiation protection measures, and emissions control measures used
for ores and other alternate feed materials at the Mill are sufficiently protective for the
processing of the Uranium Material.
As noted, the process history demonstrates that the Uranium Material results from the treatment
of native groundwater for the removal of metals and radionuclides. UPRR has estimated that the
current Uranium Material has a uranium content ranging from 0.45 to 0.49 dry weight % natural
uranium or 0.53 to 0.58 dry weight % U30s. Natural thorium content will likely range from
0.001 to 0.003 dry weight percent and may be expected to average approximately 0.002 dry
weight %. A more detailed radiological characterization of the Uranium Materials (see Section
4.9, below) is contained in the Radioactive Materials Profile Record ("RMPR") (Attachment 2).
The radionuclide activity concentration of the Uranium Material is comparable to Arizona Strip
ores and alternate feed materials which the Mill is currently licensed to receive (see Section
2.5.1, below).
2.5 Physical and Chemical Data
Physically, the Uranium Material consists of moist centrifuge cake containing residual amounts
of uranium and other metals. The chemical characterization data for the Uranium Materials is set
out in the RMPR (Attachment 2). As with the radionuclides and as discussed in more detail in
Section 4.4 below, all the chemical constituents in the Uranium Material have either been
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reported to be, or can be assumed to be, already present in the Mill's tailings system or were
reported in other licensed alternate feed materials, at levels generally comparable to or higher
than those reported in the Uranium Materials.
2.6 Comparison to Other Ores and Alternate Feed Materials Licensed for Processing at
the Mill
2.6.1 Ores and Alternate Feed Materials with Similar Radiological Cl1aracteristics
With an average uranium content of approximately 0.45 percent Unat (0.53 U30s), the Uranium
Material is comparable to an Arizona Strip ore. Arizona Strip ores typically average
approximately 0.6 percent U30s.
The estimated average content of total natural thorium ("Th-nat") of approximately 2.0 pCi/g is
far lower than normally encountered with most previously licensed alternate feed materials at the
Mill.
The Uranium Material will be handled at the Mill under the Mill's radiation safety program in a
manner appropriate for such materials.
2.6.2 Ores and Alternate Feed Materials with Similar Chemical/Metal Characteristics
The Uranium Material is physically and chemically comparable to previously-approved alternate
feed materials that the Mill has processed. As discussed in more detail in Section 4.5 below, all
the constituents in the Uranium Material have either been reported to be, or can be assumed to
be, already present in the Mill's tailings system or were reported in other licensed alternate feed
materials, at levels generally comparable to or higher than those reported in the Uranium
Material.
3.0 REGULATORY CONSIDERATIONS
3.1 Alternate Feed Guidance
The Alternate Feed Guidance provides that if it can be determined, using the criteria specified in
the Alternate Feed Guidance, that a proposed feed material meets the definition of "ore", that it
will not introduce a hazardous waste not otherwise exempted (unless specifically approved by
the EPA (or State) and the long-term custodian), and that the primary purpose of its processing is
for its source material content, the request can be approved.
3.2 Uranium Material Qualifies as "Ore"
According to the Alternate Feed Guidance, for the tailings and wastes from the proposed
processing to qualify as l le.(2) byproduct material, the feed material must qualify as "ore". NRC
has established the following definition of ore: Ore is a natural or native matter that may be
mined and treated for the extraction of any of its constituents or any other matter from which
source material is extracted in a licensed uranium or thorium mill. The Uranium Material is an
"other matter" which will be processed primarily for its source material content in a licensed
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uranium mill, and therefore qualifies as "ore" under this definition. Further, the uranium
concentration of the Uranium Material is greater than 0.05 percent on both a wet and dry basis,
and the Uranium Material is an ore, the entire mass of Uranium Material is therefore Source
Material.
3.3 Uranium Material Not Subject to RCRA
3.3.1 General
The Alternate Feed Guidance currently provides that if a proposed feed material contains
hazardous waste, listed under Section 261.30-33, Subpart D, of 40 CFR (or comparable RCRA
authorized State regulations), it would be subject to EPA (or State) regulation under RCRA.
However, the Guidance provides that if the licensee can show that the proposed feed material
does not consist of a listed hazardous waste, this issue is resolved. NRC guidance further states
that feed material exhibiting only a characteristic of hazardous waste (ignitability, corrosivity,
reactivity, toxicity) that is being recycled, would not be regulated as hazardous waste and could
therefore be approved for extraction of source material, unless it is a residue from water
treatment. The Alternate Feed Guidance concludes that if the feed material contains a listed
hazardous waste, the licensee can process it only if it obtains EPA (or State) approval and
provides the necessary documentation to that effect. The Alternate Feed Guidance also states that
NRC staff may consult with EPA ( or the State) before making a determination on whether the
feed material contains listed hazardous waste.
Subsequent to the date of publication of the Alternate Feed Guidance, NRC recognized that,
because alternate feed materials that meet the requirements specified in the Alternate Feed
Guidance must be ores, any alternate feed materials that contain greater than 0.05% source
material are considered source material under the definition of source material in 10 CFR 40.4
and hence exempt from the requirements of RCRA under 40 CFR 261.4(a)(4). See Technical
Evaluation Report, Request to Receive and Process Molycorp Site Material issued by the NRC
on December 3, 2001 (the "Molycorp TER"). As a result, any such alternate feed ores are exempt
from RCRA, regardless of whether they would otherwise have been considered to contain listed
or characteristic hazardous wastes. Since the Uranium Material contains greater than 0.05%
source material, it is exempt from RCRA, regardless of its process history or constituents, and no
further RCRA analysis is required.
Nevertheless, because the Alternate Feed Guidance has not yet been revised to reflect this
position recognized by NRC in the Molycorp TER, EFRI will demonstrate below that, even if
the Uranium Material were not considered source material, and as such exempt from RCRA, the
Uranium Material would not, in any event, contain any RCRA listed hazardous wastes or
characteristic hazardous wastes, as required under the Alternate Feed Guidance as currently
worded.
3.3.2 EFRI/UDEO Listed Hazardous Waste Protocol
In a February, 1999 decision regarding the Mill, the Atomic Safety and Licensing Board
Presiding Officer suggested there was a general need for more specific protocols for determining
if alternate feed materials contain hazardous components. In a Memorandum and Order of
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February 14, 2000, the full Commission of the NRC also concluded that this issue warranted
further staff refinement and standardization. Cognizant at that time of the need for specific
protocols to be used in making determinations as to whether or not any alternate feed materials
considered for processing at the Mill contained listed hazardous wastes, EFRI took a proactive
role in the development of such a protocol. Accordingly, EFRI established a "Protocol for
Determining Whether Alternate Feed Materials are Listed Hazardous Wastes" (November 22,
1999). This Protocol was developed in conjunction with, and accepted by, the State of Utah
Department of Environmental Quality ("UDEQ") (Letter of December 7, 1999). Copies of the
Protocol and UDEQ letter are provided in Attachment 3. The provisions of the protocol can be
summarized as follows:
a) In all cases, the protocol requires that EFRI perform a source investigation to collect
information regarding the composition and history of the material, and any existing
generator or agency determinations regarding its regulatory status;
b) The protocol states that if the material is known --by means of chemical data or site
history --to contain no listed hazardous waste, EFRI and UDEQ will agree that the
material is not a listed hazardous waste;
c) If such a direct confirmation is not available, the protocol describes the additional
chemical process and material handling history information that EFRI will collect and
evaluate to assess whether the chemical contaminants in the material resulted from listed
or non-listed sources;
d) The protocol also specifies the situations in which ongoing confirmation/acceptance
sampling will be used, in addition to the chemical process and handling history, to make
a listed waste evaluation;
e) If the results from any of the decision steps indicate that the material or a constituent of
the material did result from a RCRA listed hazardous waste or RCRA listed process, the
material will be rejected; and
f) The protocol identifies the types of documentation that EFRI will obtain and maintain on
file, to support the assessment for each different decision scenario.
The above components and conditions of the Protocol are summarized in a decision tree
diagram, or logic flow diagram, included in Attachment 3, and hereinafter referred to as the
"Protocol Diagram".
3.3.3 Application of the Listed Hazardous Waste Protocol
EFRI has conducted a RCRA evaluation of the Uranium Material and, specifically, applied the
Listed Hazardous Waste Protocol to the Uranium Material. A copy of the analysis is included as
Attachment 4. The analysis evaluated the following regulatory history to develop the
conclusions enumerated below.
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The components of the Uranium Material result either from naturally-occurring constituents of
the influent water to the WTP, inorganic solids from the Tunnel from use of the railroad over the
years that the groundwater has contacted the Tunnel or its geologic substrata, or from the non-
hazardous treatment agents added in the WTP which produced the centrifuge solids/Uranium
Material.
Prior to 2019, UPRR disposed of the centrifuge solids in off-site solid waste disposal facilities
licensed for the disposal of NORM material. In 2018 CDPHE required that UPRR apply for a
CDPHE radioactive materials license. UPRR has received License C01274-01 in 2019.
The Uranium Material, which has materially not changed in form or content since first being
produced in 2017, remains definitional source material as per 40 CFR Part 261.4, and is
explicitly exempt from regulation under RCRA. However, for the sake of completeness, EFRI
has required the following evaluation to confirm that even if the Uranium Material were not
exempt from RCRA, it is not and does not contain, what would otherwise be considered a
RCRA-listed waste, or a RCRA characteristic waste.
The Uranium Material has not been classified or treated as listed hazardous waste nor has it been
in contact with any listed hazardous wastes.
The RCRA analysis concluded that, based on the information that is available,
1. The Uranium Material would not be a RCRA listed hazardous waste because it is an ore
that has a natural uranium content of greater than 0.05 weight percent, is therefore source
material and, as a result, is exempt from regulation under RCRA.
2. Even if the Uranium Material were not source material, it would not be a RCRA listed
hazardous waste for the following additional reasons:
a) It was generated from a known process under the control of the generator, who has
provided the Affidavit declaring that the Uranium Material is not and does not
contain RCRA listed hazardous waste. This determination is consistent with Boxes I
and 2 and Decision Diamonds 1 and 2 in the EFRI/UDEQ Protocol Diagram;
b) No volatile organic compounds are used in the water treatment process that produced
the centrifuge solids, and no volatile organic compounds can be expected to be
present in the Uranium Material.
c) No semi-volatile organic compounds are used in the water treatment process that
produced the centrifuge solids. One semi-volatile organic compound was detected in
one sample, and not in the second sample. The compound does not result from a
RCRA listed waste source.
d) None of the metals in the Uranium Material samples came from RCRA listed
hazardous waste sources. This determination is consistent with Box 8 and Decision
Diamonds 9 through 11 in the EFRI/UDEQ Protocol Diagram.
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3. The Uranium Material, which is a residue from water treatment, does not exhibit any of
the RCRA characteristics of ignitability, corrosivity, reactivity, or toxicity for any
constituent. As a result, even if not exempt from RCRA under 40 CFR 261.4, the
Uranium Material would not be precluded under the Alternate Feed Guidance due to
RCRA characteristics.
3.3.4 Radioactive Material Profile Record
Furthermore, in order for EFRI to characterize the Uranium Material, UPRR has completed
EFRI's RMPR form, stating that the material is not RCRA listed waste. The certification section
of the RMPR includes the following text:
I certify that the material described in this profile has been fully characterized
and that hazardous constituents listed in 10 CFR 40 Appendix A Criterion 13
which are applicable to this material have been indicated on this form. I further
certify and warrant to EFRI that the material represented on this form is not a
hazardous waste as identified by 40 CFR 261 and/or that this material is exempt
from RCRA regulation under 40 CFR 261.4(a)(4).
3.3.5 Conclusion
Because the Uranium Material is an ore that contains greater than 0.05% source material, the
Uranium Material is exempt from RCRA under 40 CFR 261.4(a)(4). In addition, based on the
site history, the determinations by UPRR, and the analysis of the EFRI's chemical engineering
consultant, EFRI has also concluded that, even if not exempted from RCRA under 40 CFR
261.4(a)(4), the Uranium Material does not demonstrate a characteristic of hazardous waste, and
on the application of the Listed Hazardous Waste Protocol, Uranium Material from the Facility
would not be listed hazardous waste subject to RCRA.
3.4 Uranium Material is Processed Primarily for its Source Material Content
In its Memorandum and Order, February 14, 2000, In the Matter of International Uranium (USA)
Corp. (Request for Materials License Amendment), Docket No. 40-8681-MLA-4, the NRC
concluded that an alternate feed material will be considered to be processed primarily for its
source material content if it is reasonable to conclude that uranium can be recovered from the
Uranium Material and that the processing will indeed occur. The Uranium Material will be
processed for the recovery of uranium at the Mill. Based on the uranium content of the Uranium
Material, its physical and chemical characteristics, and EFRI's success in recovering uranium
from a variety of different types of materials, including materials that were similar to the
Uranium Materials, at the Mill, it is reasonable to expect that uranium can be recovered from the
Uranium Material. As a result, the Uranium Material is an ore that will be processed primarily
for the recovery of source material, and the tailings resulting from processing the Uranium
Material will therefore be 1 le.(2) byproduct material under the definition set out in 10 CFR 40.4.
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4.0 AFFECTED ENVIRONMENT
4.1 General
The Mill is a licensed uranium processing facility that has processed to date over 5,000,000 tons
of uranium-bearing conventionally mined ores and alternate feed materials primarily for the
recovery of uranium, with the resulting tailings being permanently disposed of as 1 le.(2)
byproduct material in the Mill's tailings management systems. Environmental impacts associated
with such previously licensed Mill operations have been thoroughly evaluated and documented
in the past. See, for example:
• the original 1979 Final Environmental Statement ("FES") for the Mill,
• Environmental Assessments ("EAs "), dated 1985 and 1997,
• an EA for the Mill's reclamation plan dated 2000,
• EAs for alternate feed materials dated 2001 and 2002, in each case prepared by the NRC,
• the Safety Evaluation Report for the Receipt, Storage and Processing of Fansteel
Alternate Feed Material prepared by DWMRC,
• the Safety Evaluation Report for the Receipt, Storage and Processing of Dawn Mining
Alternate Feed Material prepared by DWMRC,
• the Safety Evaluation Report for the Receipt, Storage and Processing of SFC Alternate
Feed Material prepared by DWMRC, and
• The Technical Evaluation and Environmental Assessment Report prepared in in
connection with the 2018 Radioactive Materials License Renewal for the Mill, prepared
byDWMRC.
The Uranium Material will also be processed as an alternate feed material at the Mill for the
recovery of uranium and the resulting tailings will be permanently disposed of in the Mill's
tailings management system as 1 le.(2) byproduct material, in a similar fashion to other
conventionally mined ores and alternate feed materials that have been processed or licensed for
processing at the Mill.
Accordingly, this Environmental Report will focus on the various pathways for potential
radiological and non-radiological impacts on public health, safety and the environment and
determine if the receipt and processing of the Uranium Material would result in any potential
significant incremental impacts over and above previously licensed activities.
The pathways that are analyzed are the following:
a) potential impacts from transportation of the Uranium Material to the Mill;
b) potential impacts from radiation released from the Uranium Material while in
storage at the Mill;
c) any chemical reactions that may occur in the Mill's process;
d) any potential reactions or inconsistencies with the existing tailings or tailings
facilities;
e) potential impacts on groundwater;
f) potential impacts on surface water;
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g) potential airborne radiologic impacts;
h) potential radon and gamma impacts; and
i) worker health and safety issues.
These potential pathways will be discussed in the following sections of this document. The
findings below will demonstrate that, because all the constituents in the Uranium Material have
either been reported to be, or can be assumed to be, already present in the Mill's tailings
management system or were reported in other licensed alternate feed materials, at levels
generally comparable to or higher than those reported in the Uranium Material, the resulting
tailings will not be significantly different from existing tailings at the facility. As a result, there
will be no incremental public health, safety or environmental impacts over and above previously
licensed activities.
Processing of the Uranium Material involves no new construction, no additional use of land, no
modification of the Mill, main circuit, alternate feed circuit, or tailings management system of
any significance. The Uranium Material contains no new chemical or radiological constituents
beyond those already processed in ores and approved alternate feed materials, or already known
or expected to be present in the tailings management system. As a result, there are no anticipated
impacts to the environment via any of the above pathways, above those already anticipated in the
existing environmental statements and environmental assessments associated with the Mill's
approved license, which have addressed, among other issues and requirements:
• Geology and soils,
• Liquid effluents,
• Airborne effluents,
• Direct radiation,
• Management of sanitary wastes,
• Human and ecological receptor hazard assessment,
• Mill accidents,
• Transportation accidents,
• Groundwater impacts,
• Surface water impacts,
• Mill decommissioning,
• Land, structures, site and tailings reclamation,
• Internal inspection program,
• Corporate organization and management,
• Radiological protection training,
• Security,
• Quality assurance for all phases of the milling program,
• Operational effluent monitoring,
• Operational radiological monitoring,
• Meteorological monitoring,
• Capacity of tailings system over the lifetime of the Mill operations,
• Permanent isolation of tailings including slope stability, settlement, and liquefaction
potential,
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• Consideration of below-grade disposal of tailings,
• Tailings design requirements including site location and layout, site area, geography, land
use and demographic surveys, use of adjacent lands and waters, population distribution,
demography, meteorology, air models, geology and soils, seismology, hydrologic
description of the site, surface water, flooding determination, surface water profiles,
channel velocities, shear stresses, groundwater hydrology, radiological surveys, site and
uranium mill tailings characteristics, disposal cell cover engineering design, and design
of erosion protection covers,
• Groundwater protection standards,
• Liner construction,
• Prevention of overtopping,
• Dike design, construction, and maintenance,
• Cover and closure at end of operations including radon attenuation, gamma attenuation,
and cover radioactivity content,
• Effectiveness of final radon barrier including verification and reporting,
• Radium in cover materials,
• Radionuclides other than radium in soils,
• Non-radiological hazards,
• Completion of final radon barrier,
• Preoperational and operational monitoring programs,
• Effluent control during operations including gaseous and airborne particulates, liquids
and solids, contaminated equipment, sources and controls of Mill wastes and effluents,
sanitary and other Mill waste systems, effluents in the environment, effluent control
techniques, external radiation monitoring program, airborne radiation monitoring,
exposure calculations, bioassay program, contamination control program, airborne
effluent and environmental monitoring program, groundwater and surface water
monitoring program, control of windblown tailings and ore,
• Daily tailings inspections,
• Financial surety,
• Costs of long-term surveillance,
• Application for a groundwater discharge permit,
• Groundwater permit compliance monitoring,
• Background groundwater quality determination,
• Submission of data,
• Reporting of mechanical problems or discharge system failures,
• Correction of adverse effects, and
• Out of compliance status and procedures.
4.2 Transportation Considerations
4.2.1 Packaging and Mode of Transportation
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The drummed Uranium Material from the Facility will be loaded into closed containers (trailers)
at the WTP and transported by road to the Mill.
The Uranium Material will be shipped as Radioactive LSA I (low specific activity) Hazardous
Material as defined by the Department of Transportation ("DOT") regulations. UPRR will
arrange with a material handling contractor for the proper marking, labeling, placarding,
manifesting and transport of each truckload of the Uranium Material. Shipments will be tracked
by the shipping company from the Facility until they reach the Mill. Each shipment will be
"exclusive use" (i.e., the only material on each vehicle will be the Uranium Material).
The containers and trucks involved in transporting the Uranium Material to the Mill site will be
surveyed and decontaminated, as necessary, prior to leaving the WTP. The containers and trucks
will be decontaminated again, as necessary, prior to leaving the Mill site.
In the maximum conservative case, UPRR will ship 5 trucks in a day 5 to 6 times per year
4.2.2 Transportation Impacts
For the following reasons, it is not expected that transportation impacts associated with the
movement of the Uranium Material by truck from the Facility to the Mill will be significant:
a) Radiological Matters
The transport of radioactive materials is subject to limits on radiation dose rate measured at the
transport vehicle as specified in the US Code of Federal Regulations. The external radiation
standards for these shipments are specified in 10 CFR 71.47 sections (2) and (3) as less than 200
millirems per hour ("mrern/h") at any point on the outer surface of the vehicle, and less than 10
mrem/h at any point two meters from the outer lateral surfaces of the vehicle. All exclusive use
trailer trucks will be scanned by UPRR prior to departure from the WTP to ensure that these
limits are satisfied. From a radiologic standpoint, the Uranium Material is within the bounds of
other ores and alternate feed materials licensed for processing at the Mill. The Uranium Material
will be transported in sealed drums in covered exclusive use box-style trailers, in a similar
fashion to other alternate feed materials, and as a result there will be no significant incremental
radiological impacts associated with transportation of Uranium Material to the Mill, over and
above other previously licensed ores and alternate feed materials at the Mill or from licensed
activities at other facilities in the State of Utah.
b) Traffic Volume Matters
(i) Comparison to Licensed Mill Operations
Section 4.8.5 of the 1979 FES for the Mill noted that during the operations period, when area
mining was at expected peak levels, approximately 68 round trips on local highways would be
made by 30-ton ore trucks to the Mill per day (see the 1978 Dames and Moore Environmental
Report for the Mill, p. 5-34). In contrast, the maximum quantity of Uranium Material to be
produced per year may be expected to be transported in a total of approximately 10 truckloads in
total per year, with a truckload containing one 20-ton container, loaded with sealed drums, If all
the material to be shipped annually shipped were transported in one day, the maximum
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additional truck traffic generated will be no greater than 10 trucks per day or approximately one
truck per 2.5 hours for one day per year.
In addition, based on a licensed yellowcake capacity of 4,380 tons U30s per year (Mill license
condition 10.1) a maximum of approximately 8,760,000 pounds of yellowcake would require
shipment from the Mill to conversion facilities. This would require approximately 183-275 truck
shipments from the Mill per year (based on 40-60 drums per truck, 800 lbs. per drum), or one
truck every one to two days based on a seven day work week ( one truck every day or so, based
on a five-day work week). In contrast, the entire volume of yellowcake to be produced from
processing the Uranium Material is expected to be transpo1ted in approximately two truckloads
over the entire life of the project. These frequencies are minimal in comparison to the estimated
yellowcake transport frequency at licensed capacity. Moreover, during the period of
transportation of the Uranium Material to the Mill, EFRI does not expect that ore deliveries and
alternate feed material deliveries from all other sources together with the Uranium Material
would, in total, exceed the truck transportation associated with licensed capacity.
After leaving the WTP, the shipments may travel any of several routes into Utah. The likely
route will be from the WTP via US Highway 40 to Interstate Highway 70, and west on Interstate
Highway 70 into Utah, then onto Utah State Highway (SH) 191 north of Blanding and south on
SH 191 to the Mill.
(ii) Comparison to Existing Truck Traffic on US Highway 191
The trucks will travel over Utah Highway 191 either north or south of the Mill, to reach the
Mill.
Based on information from the State of Utah Department of Transportation ("UDOT") traffic
analysis reports Traffic on Utah Highways 2016 (with factors for types of truck traffic) accessed
at the UDOT web page on February 3, 2019, on average during 2016, 544 multi-unit trucks
traveled daily on segments of US Highway 191 north of the Mill. Based on the 2017 UDOT
truck traffic information, the maximum of 10 additional trucks per day traveling this route to the
Mill during the limited period anticipated for shipment of the Uranium Material represents an
increased traffic load of approximately 2 percent for no longer than one day per year or one truck
per day for approximately ten days per year. Therefore, the truck traffic to the Mill from this
project is expected to be an insignificant portion of existing truck traffic on US Highway 191 and
well within the level of truck traffic expected from normal Mill operations.
4.2.3 Transportation Accidents
As discussed in Section 2.3 and Attachment 5, the Uranium Material has a uranium content and
radioactivity levels comparable to Arizona Strip ores and previously'...approved alternate feed
materials, and contains no additional constituents beyond those associated with other ores or
alternate feed materials previously transported to the Mill. The Uranium Material will be
transported in sealed drums contained in 20-ton transport containers. Therefore the Uranium
Material poses no additional hazards during transport above previously licensed activities.
Existing accident response and spill response procedures are therefore sufficient for management
of potential transpmtation accidents or spills of the Uranium Material.
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4.3 Storage
4.3.1 Manner of Storage
Trucks arriving at the Mill site will be received according to existing Mill procedures. The sealed
drums will be unloaded from the trucks onto the ore pad for temporary storage until the material
is scheduled for processing.
4.3.2 Environmental Impacts Associated With Storage
Because the Uranium Material does not significantly differ in radiological activity from other
ores and alternate feed materials, and because the Uranium Material will be stored in sealed
drums on the Mill's ore pad pending processing, there will be no environmental impacts
associated with the Uranium Material over and above those associated with other drummed
alternate feed materials handled at the Mill on a routine basis. Experience at the Facility has
determined that the Uranium Material is stable under ambient environmental conditions and does
not require any special handling.
4.4 Process
The Uranium Material will be introduced to the process in either the alternate feed circuit or in
the main circuit either alone or in combination with other conventional ores or other alternate
feed materials. Because the material is moist with 75 to 90 % moisture content, it is not expected
to produce dust upon emptying of drums or introduction into the Mill process. The material will
be processed through existing acid leach, solid liquid separation and solvent extraction circuits
for the recovery of uranium values. The leaching process will begin either in the main circuit
leach tanks with the addition of sulfuric acid, or in the alternate feed circuit. The solution will be
advanced through the remainder of the Mill or alternate feed circuit with no significant
modifications to either the circuit or the recovery process anticipated. The only wastes or
effluents to be generated from processing the Uranium Material are solutions or solids to be
transferred to the Mill's existing tailings management system.
Since no significant physical changes to the Mill circuit and no new process chemicals will be
necessary to process this Uranium Material, no significant construction impacts beyond those
previously assessed will be involved. Recovery of additional contained metals is not anticipated
at this time.
As with other alternate feed materials, a Standard Operating Procedure ("SOP") specific to
processing of the Uranium Material, addressing processing procedures, personnel safety and
radiation or other exposure monitoring will be developed and reviewed by the Mill's Safety and
Environmental Review Panel ("SERP'), and Mill personnel will be trained in the approved SOP
prior to processing of the Uranium Material.
The effects of introducing the Uranium Material into the Mill's process and tailings were
reviewed by EFRI' s consulting chemical process engineer. The consulting engineer's Technical
Memorandum is included as Attachment 5. Table 5 in this Technical Memorandum provides
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comparisons of the concentrations of all known constituents of the Uranium Material to the
tailings and other previously processed ores and alternate feed materials. As discussed in
Section 4.5 below, and in Attachment 5, the existing tailings system and tailings management
system controls are adequate for management of any tailings generated from the Uranium
Material.
4.4.1 Mill Accidents and Emergency Response
As discussed in Section 2.4 and Attachment 5, the Uranium Material has a uranium content and
radioactivity levels comparable to Arizona Strip ores, and previously-approved alternate feed
materials, and contains no additional constituents beyond those associated with other ores or
alternate feed materials previously transported to the Mill. Therefore the Uranium Material
poses no additional hazards during storage, processing or disposal of tailings. As discussed in
Attachment 5, the Uranium Material will not introduce any new hazardous constituents, and
processing will not require the introduction of any new processing chemicals. Existing
emergency response and spill response procedures are therefore sufficient for management of
potential accidents or spills of the Uranium Material on the Mill site.
4.5 Compatibility with EFRI Mill Tailings
4.5.1 Physical Compatibility
The Uranium Material will be received as moist solid cake from centrifugation in the WTP. All
the non-uranium components of the material will eventually be discharged to the Mill's tailings
management system. Cell 3 and Cell 4A are currently the active tailings cells at the Mill and
either could receive tailings from the Uranium Material. However, because filling of Cell 3 is
nearing completion, tailings from the Uranium Material will more likely be placed in Cell 4A.
The evaluations in this application and its attachments are therefore based on placement of
tailings in Cell 4A.
The solutions from the Uranium Material tailings will be recirculated through the mill process
for reuse of the acidic properties in the solution. The solids will be only a portion of the total
mass of Uranium Material. However, assuming a worst case scenario that all of the solid
material ends up in the tailings, it is estimated that for the main processing circuit, the additional
load to the tailings is minimal (Attachment 5, Tables 4-1 and 4-2). It is expected that the
concentration of the majority of constituents in tailings will decrease after the Uranium Material
is deposited in the tailings impoundments.
Based on Tables 4-1 and 4-2, barium concentrations in Cell 4A may increase up to 2 mg/kg over
the current level of 0.1 mg/kg in Cell 4A. Again, it should be noted, that the barium level in the
Uranium Material is 110 times lower than that of certain other alternate feed materials previously
approved and processed at the Mill, such as Molycorp Mountain Pass drummed material.
Cell 4A, which has been in service since October of 2008, has received tailings solids and
solutions primarily from conventional ore processing together with a small volume from
alternate feed material processing. Cell 48, placed into service in February 2011, currently
serves as an evaporation pond and receives only solutions at this time. Cell 4A has primary and
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secondary high-density polyethylene ("HDPE") flexible membrane liners, a geosynthetic clay
underliner, and a leak detection system design, selected specifically to meet current standards for
uranium mill tailings management.
The constituents in the tailings resulting from processing the Uranium Material are not expected
to be significantly different from those in the conventional ores either in composition or in
concentration of constituents. The Technical Memorandum on Worker Safety, Environmental
Issues and Chemical Compatibility (the "Safety and Compatibility Technical Memorandum",
Attachment 5) indicates that all of the constituents found in the Uranium Material have
previously been processed in the Mill's circuits and managed in the Mill's tailings system.
The Safety and Compatibility Technical Memorandum identified that the components of the
Uranium Material are not expected to have any adverse effect on the Mill processing system or
the tailings cells. As described in Attachment 5, it is expected that most of the metal and non-
metal impurities entering the leach system with the Uranium Material will be converted to sulfate
ions, precipitated, and eventually discharged to the tailings management system.
Every metal and non-metal cation and anion component in the Uranium Material already exists
or can be assumed to exist in the Mill's tailings management system, is already addressed in the
Mill's groundwater monitoring program, or both. A summary of the anticipated tailings
composition before and after the Uranium Material is processed is presented in the Safety and
Compatibility Technical Memorandum Attachment 5.
Every identified component in the Uranium Material has been:
1. detected in analyses of the tailings management system;
2. detected in analyses of alternate feed materials licensed for processing at the Mill; or
3. detected in process streams or intermediate products when previous alternate feed
materials were processed at the Mill;
at concentrations that are generally comparable to the concentrations in the Uranium Material.
However, even if the Uranium Material were to contain some constituents at significantly higher
concentrations, due to the limited quantity of Uranium Material, any such increase in the
concentration of any analyte in the Mill's tailings management system would not be expected to
be significant. The estimated effect on tailings management system composition is discussed in
the attached technical memorandum.
The constituents in the Uranium Material are expected to produce no incremental additional
environmental, health, or safety impacts in the Mill's tailings system beyond those produced by
the Mill's processing of natural ores or previously approved alternate feed materials.
4.5.2 Capacity and Throughput
The amount of tailings that would potentially be generated from processing the Uranium
Material is equivalent to the volume that would be generated from processing an equivalent
volume of conventional ore. Processing of the Uranium Material will have no effect on the
capacity of the tailings management system over the lifetime of the Mill operations beyond that
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of processing a similar amount of natural ore. The WTP, as described above, may be expected to
ship a total of approximately 5,000 tons of Uranium Material to the Mill over its lifetime. This
volume is well within the maximum annual throughput rate and tailings generation rate for the
Mill of 720,720 tons per year. EFRI has updated the Tailings Capacity Review, a copy of which
is available for review at the Mill. The Tailings Capacity Review confirms that there is more
than adequate capacity to accommodate the tailings from the Uranium Material. Additionally,
the design of the existing tailings management system has previously been approved by the Utah
DWMRC (Cells 4A and 4B), and EFRI is required to conduct regular monitoring of the leak
detection systems and of the groundwater in the vicinity of the tailings management system to
detect any potential leakage should it occur. A copy of the updated Tailings Capacity Review is
available for review at the Mill.
4.5.3 Mill Tailings Closure and Reclamation
Processing of the Uranium Material will have no effects beyond those identified in the approved
ERs, ESs, and Reclamation Plans for tailings operational management and closure. The
Uranium Material will have no effect on existing approved plans for decommissioning of the
Mill, buildings, land or structures, or reclamation of the site. The Uranium Material will have no
effect on tailings design components addressing permanent isolation of tailings, slope stability,
settlement or liquefaction of reclaimed tailings, or design features addressing disposal cell covers
or erosion protection.
Because radionuclide content is within the ranges associated with other ores and alternate feed
materials approved for processing at the Mill, there will be no effect on radon attenuation,
gamma attenuation or cover radionuclide content. Because it will not affect cover design at
closure and reclamation, there will be no effect on the final radon barrier design or its method of
emplacement, radium concentration in cover materials, or other cover radionuclide content.
Processing of the Uranium Material will have no effect on completion of the final radon barrier
or on the timetable for completion of reclamation. Processing of the Uranium Material will not
require the acceptance of uranium byproduct material from other sources during closure.
Because processing the Uranium Material will have no effect on reclamation and closure design,
construction or timing, it will have no effect on existing and approved financial surety estimates
or arrangements, and will not require any changes to costs of long-term surveillance.
4.6 Groundwater
In the 1997 EA, NRC staff concluded that, for a number of reasons, groundwater beneath or in
the vicinity of the Mill site will not be adversely impacted by continued operation of the Mill.
Because the Mill's tailings management system are not impacting groundwater, the receipt and
processing of Uranium Material at the Mill will not have any incremental impacts on
groundwater over and above existing licensed operations.
EFRI meets the State of Utah Groundwater Protection Standards by complying with the Mill's
current Groundwater Discharge Permit ("GWDP"). The Mill initially applied for a GWDP in
2005. The current version was approved in March 2019. The primary groundwater protection
standard in UAC R313-24-4 is a design standard for surface impoundments used to manage
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uranium and thorium byproduct material. The design of the Mill's Cell 4A, which will receive
tailings from processing the Uranium Material, has been approved by DWMRC as meeting Best
Available Technology Requirements for the liners and other components of the containment
system.
The GWDP established points of groundwater monitoring compliance, a compliance monitoring
program, and agreed to the establishment of intra-well background for comparison with
groundwater compliance limits. The GWDP further established requirements for submission of
field and laboratory monitoring data, reporting of mechanical problems or discharge system
failures, correction of adverse effects, assessment of corrective actions, and notification,
reporting and procedures during any out-of-compliance status. Since the issuance of the initial
GWDP, the Mill has not sought to discontinue the GWDP.
All constituents identified in the Uranium Material, are already present or can be assumed to be
present in the Mill's tailings management system, are already included in the Mill's groundwater
monitoring program, or both.
Chemical and radiological make-up of the Uranium Material is similar to other ores and alternate
feed materials processed at the Mill, and their resulting tailings will have the chemical
composition of typical uranium process tailings, for which the Mill's tailings management system
was designed. As a result, the existing groundwater monitoring program at the Mill will be
adequate to detect any potential future impacts to groundwater.
As a result, there will be no incremental impacts over and above previously licensed activities.
4.7 Surface Water
There will be no discharge of Mill effluents to local surface waters. All Mill process effluents,
and analytical laboratory liquid wastes will be discharged to the Mill's tailings management
system for disposal by evaporation. Runoff from the Mill and facilities is directed to the tailings
management system. Sanitary wastes are discharged to State-approved leach fields. Since there is
no plausible pathway for Uranium Material to impact surface water, and, as indicated in Semi-
Annual Effluent Reports filed by the Mill to date, there is no indication of the Mill impacting
surface waters, then there will be no incremental impact to surface waters from any airborne
particulates associated with processing the Uranium Material.
The Uranium Material will be transported to the Mill in closed steel drnms in exclusive use
trucks. Upon introduction into the Mill circuit, the Uranium Material will be processed in a
similar fashion as other ores and alternate feed materials. The Uranium Material will be moist,
with an average moisture content of 78% and is not expected to produce dust during unloading or
introduction into the Mill process. There will therefore be no new or incremental risk of
discharge to surface waters resulting from the receipt and processing of Uranium Material at the
Mill or the disposition of the resulting tailings.
Finally, as the chemical and radiological make-up of the Uranium Material are sufficiently
similar to natural ores and other alternate feed materials and the tailings resulting therefrom, that
the existing surface water monitoring program at the Mill will be adequate to detect any potential
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impacts to surface water. As a result, there will be no incremental impacts over and above
previously licensed activities.
4.8 Airborne Radiological Impacts
The chemical and radiological make-up of the Uranium Material will not be significantly
different from natural ores and other alternate feed materials that that have been licensed for
processing at the Mill in the past. The existing air particulate monitoring program is equipped to
handle all such ores and alternate feed materials.
4.9 Radon and Gamma Impacts
As discussed in Section 2 above, the uranium content and radioactivity levels of the Uranium
Material is comparable to Arizona Strip ores and previously approved alternate feed materials.
In fact, the Ra-226 concentrations are much lower than Arizona Strip ores. Therefore, Rn-222
emanations from the Uranium Material will be significantly lower than from the same quantity of
ores. Also, the gamma fields from the U-nat chain are derived primarily from Ra-226, which is
very low, less than 12 pCi/g. Therefore, the gamma from the U-nat chain in the Uranium
Material will be low. The natural thorium is also very low relative to Arizona Strip ores,
averaging 0.002%. Overall, the Uranium Material will therefore pose a lower gamma and radon
hazard as other ores and alternate feed materials that have already been processed or licensed for
processing at the Mill.
4.10 Safety Measures
4.10.1 General
During unloading of the Uranium Material drums onto the ore pad, while the Uranium Material
is being stored in drums on the ore pad pending processing, while feeding Uranium Material into
the Mill process and while processing the Uranium Material and disposing of and managing the
resulting tailings, the Mill will follow existing Mill SOPs in addition to an SOP to be developed
specific to the Uranium Material, as discussed below.
4.10.2 Radiation Safety
a) Existing Radiation Protection Program at the Mill
The radiation safety program which exists at the Mill, pursuant to the conditions and provisions
of the Mill's Radioactive Materials License, and applicable State Regulations, is adequate to
ensure the protection of the worker and environment, and is consistent with the principle of
maintaining exposures of radiation to individual workers and to the general public to levels As
Low As Reasonably Achievable ("ALARA"). Employees will be provided with personal
protective equipment including full-face respirators, if required. In addition, all workers at the
Mill are required to wear personal Optically Stimulated Luminescence ("OSL") badges or the
equivalent to detect their exposure to gamma radiation.
b) Gamma Radiation
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Gamma radiation levels associated with the Uranium Material are within levels of gamma
radiation, or in fact lower than those, associated with other ores and alternate feed materials
processed or licensed for processing at the Mill in the past. Gamma exposure to workers will be
managed in accordance with existing Mill SOPs.
c) Radon
Radon levels associated with the Uranium Material are within levels of radon associated with
other ores and alternate feed materials processed or licensed for processing at the Mill in the
past. Radon exposures to workers will be managed in accordance with existing Mill standard
operating procedures.
d) Control of Airborne Contamination
The Uranium Material will be moist with a moisture content of 75 to 90%. While stored on the
ore pad, the uranium material will remain within the drums used for transport. The Uranium
Material will be stored in an area on the ore pad separate from regular traffic and marked as
Uranium Material.
Dust suppression techniques will be implemented, if required, while the Uranium Material is
being introduced into the Mill process. Once in the Mill process, the Uranium Material will be in
a dissolved form, and no special dust suppression procedures will be required. As is the practice
at the Mill for other alternate feed materials, the DAC to be used in any analysis of airborne
particulate exposure to workers will be developed specifically for the Uranium Material, based
on applicable regulations and Mill procedures, in order to take into account the specific
radionuclide make-up of the Uranium Material. The Mill has safely received and processed
alternate feed materials with comparable concentrations of the radionuclides contained in the
Uranium Material, under previous license amendments, and can safely handle the Uranium
Material in accordance with existing Mill standard operating procedures.
4.10.3 Occupational Safety
The primary focus of safety and environmental control measures will be to manage potential
exposures from radionuclide particulates. Response actions and control measures designed to
manage particulate radionuclide hazards will be more than sufficient to manage chemical hazards
from the metal oxides (see the conclusions of the Safety and Compatibility Technical
Memorandum in Attachment 5).
4.10.4 Vehicle Scan
As stated in Section 4.2.1 above, the shipments of Uranium Material to and from the Mill will be
dedicated, exclusive loads. Radiation surveys and radiation levels consistent with applicable
DOT regulations will be applied to the exclusive use vehicles. For unrestricted use, radiation
levels will be in accordance with applicable values contained in the NRC Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material, U.S. NRC, April,
1993. If radiation levels indicate values in excess of the above limits, appropriate
decontamination procedures will be implemented.
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4.11 Long Term Impacts
The Uranium Material is comprised of similar chemical and radiological components as already
exist in the Mill's tailings cells. Existing monitoring programs are therefore adequate, and no
new monitoring procedures are required. As a result, there will be no decommissioning,
decontamination or reclamation impacts associated with processing the Uranium Material, over
and above previously licensed Mill operations.
4.12 Other Operational Considerations
Processing of the Uranium Material will not require changes to corporate organization or
administrative procedures, management control programs, management audit and inspection
programs, staffing levels or staff qualifications. Processing will not require modifications to the
Mill's existing security procedures.
4.13 Added Advantage of Recycling
UPRR has expressed its preference for use of recycling and mineral recovery technologies for
the Uranium Material for three reasons: 1) for the environmental benefit of reclaiming valuable
minerals; 2) for the added benefit of reducing radioactive material disposal costs; and 3) for the
added benefit of minimizing or eliminating any long term contingent liability for the waste
materials generated during processing.
UPRR has noted that the Mill has the technology necessary to process materials for the
extraction of uranium and to provide for disposal of the 1 le.(2) byproduct material, resulting
from processing primarily for the uranium, in the Mill's existing tailings management system. As
a result, UPRR will contractually require EFRI to recycle the Uranium Material at the Mill for
the recovery of uranium.
4.14 Consideration of Alternatives
This application is in response to a request by UPRR for disposal/processing options for solids
produced from removal of radionuclides and metals from groundwater at the WTP, in order for
UPRR to comply with the conditions of its CDPHE license. The Mill is a facility that has been
requested to provide these services, because it is licensed to process materials for the recovery of
uranium and is licensed to create, possess and dispose of byproduct materials that are similar to
the Uranium Material. Given that removal of the Uranium Material to an offsite facility is
required to meet the WTP's license conditions, the only options are as to which offsite facility
the Uranium Material will ultimately be sent for reprocessing or disposal. UPRR has determined
that the Mill is the only off-site facility capable of re-processing the Uranium Material.
Therefore, the alternative to processing/disposal at the Mill would be direct disposal. If direct
disposal is utilized, the value of the recoverable uranium in the Uranium Material would not be
realized.
Pae 21
Energy Fuels Resources (USA) Inc.
5.0 CERTIFICATION
This application and Environmental Report has been submitted as of December 23, 2019 by
ENERGY FUELS RESOURCES (USA) INC.
By:
Pa e22
ATTACHMENT 1
Union Pacific Moffat Tunnel Facility Information
t[afittrati On Tre·atme ~nt~P-Foeess. I nstalle.a-2tl'4 7
Influent Turbidity
Sample
Tunnel
Discharge ••-•
195 gpm
Coagulant
40,000 gallon
Equal'ization
Tahk wrth 3
Hr Detent ion
at 205 gprn
10 m
Clarified OAF
return flow to
equalization
basin
Backwash
Flow
Treated Water
Turbidity Sample
Treated Water Discharged l
to Fraser River
Dissolved
Air
Flotation
(OAF)
Solids
Slurry
1-2%
Reclaimed Water
CA RS
AMTA/AWWA © 1
g-Majbr Construction
Tunnel
Discharge
195 gpm
Influent Turbidity
Sample l
Temporary Settling Tanks
40,000 gallon
Eguallzation
Tank with 3
Hr Detention
at 205 gpm
Coagulant
Backwash Flow!
Dissolved Solids
Air Slurry Clarified OAF
10 gpm return flow to
• equalization
1
-Flotation 1-2%
basin (OAF)
Treated Water
Turbidity Sample
Treated Water Discharged
to Fraser River
Reclaimed Water
Sludge
AMTA/AWWA © 2
Ka11roaa unaerpass
(16'-0" Clearance)
Turn right into Old Town
Winter Park. Do not
pass through key
access entrance station.
Turn (left/east) at
second traffic light
Lakota Resort sign
will be on the
ATTACHMENT 2
Radioactive Material Profile Record and Affidavit
4/3/2019
'RADIOACTIVE MATERIAL PROFILE RECORD
'fame and Title of Person Completing Form: Jonathan Reed, PE Phone: [phone]
Original Submission: Y __x_ N ___ ; Revision# NIA Date of Revision: _ __...N __ /=A ___________ _
Generator Name: Union Pacific Railroad Generator/Feed Stream#: ___ N-/A ____ ; Volume of Feed Material 60-100 tons/year
Contractor Name: ____ N,../A....._ __ __,, Feed Stream Name: Centrifuge Cake_, Delivery Date: ____ N'"""""/A., ___ _
Check all appropriate boxes:
Licensed Y _x_ N_ CDPHE License Number CO 1274-01 pending. Union Pacific Railroad (UPRR) is seeking a CDPHE
Radioactive Material License. UPRR is currently in tlie process of finalizing the license application process and anticipates license
approval no later than the next 2-5 months.
NORM/NARM X; LLRW _; MW_; MW Treated_; MW Needing Trtmt _;DOE_; Ile. (2) _;
A. CUSTOMER INFORMATION:
GENERAL: Please read carefully and complete this form for one feed stream. This information will be used to determine how to
properly manage the material. Should there be any questions while completing this form, contact Energy Fuels Resources (USA)
Inc.'s ("EFRI's") Manager of Compliance and Licensing at 303.389.4132. MATERIALS CANNOT BE ACCEPTED AT EFRJ'S
WHITE MESA MILL UNLESS THIS FORM JS COMPLETED. If a category does not apply, please indicate. This form must
be updated annually.
1. GENERATOR INFORMATION
EPA ID# NIA EPA Hazardous Waste Number(s) (ifapplicable) _______ N __ /A=-------
Mailing Address: __ 1400 W 52nd Avenue, Denver, CO 80221 ________ _
Phone: _(303) 405-5072__ Fax: __ [phone] ____ _
Location of Material (City, ST): ___ Winter Park, co _____ _
Generator Contact: Steven Preston _____ _ Title: __ Senior Supervisor _____ _
Mailing Address (if different from above): _Same as above _______________ _
Phone: Same as above ____ _ Fax: Same as above ------
B. MATERIAL PHYSICAL PROPERTIES (Should you have any questions while completing this section, contact EFRJ's Manager
of Compliance and Licensing at 303.389.4132.)
I. PHYSICAL DATA (Indicate percentage of material that will pass through the following
grid sizes, e, g, 12" 100%, 4" 96%, l" 74%, 1/4" 50%, 1/40" 30%, 1/200" .5%) No Data
2. DESCRIPTION: Color Dark Brown Brown/Multi_ Odor_ Odorless X
Liquid_ Solid_ Sludge X Powder/Dust
3. DENSITY RANGE: (Indicate dimensions) S.G. 65-85 lb. /ft3 lb. lyd3
4. GENERAL CHARACTERISTICS (% OF EACH)
1/200"
12"
4"
l"
1/4"
1/40"
_57%
GRADATION OF
MATERIAL:
100% -
95%
_90%0
84% -
65%
Soil __ Building Debris __ Rubble __ Pipe Scale __ Tailings __ Process Residue_ X _ Concrete __
Plastic/Resin __
Other constituents and approximate % contribution of each: 100% Inorganic Industrial Wastewater Treatment Plant
Residuals /)
Generator or Contractor Initials: ----~-----
Page 1 of7
Radioactive Material Profile Record
5. MOISTURE CONTENT: (For soil or soil-like materials).
(Use Std Proctor Method ASTM D-698 or equivalent) Low Moisture Content: 75 %
High Moisture Content: 83 %
Average Moisture Content: estimated 78%
DESCRIPTION OF MATERIAL Attach a description of the material (as Attachment B.6) with respect to its physical
composition and characteristics such as geotechnical or engineering information (for example, if information is available
regarding percent [%] sands, clay or debris). No official geotecbnical or engineering information is available. The
material is dark brown or gray, with a clay-like consistency. A photograph of the waste material is included in
Attachment B.6.
C. RADIOLOGICAL EVALUATION
1. MATERIAL INFORMATION. For each radioactive isotope listed below, obtain sufficient samples to adequately determine
a range and weighted average of activity in the material. If Uranium, Thorium, or other non-gamma emitting nuclides are
present in the material, have at least (1) sample evaluated by radiochemistry to determine the concentration of these
additional contaminants in the material. EFRI's license assumes daughter products to be present in equilibrium. Add isotope
information as necessary for the proposed alternate feed material. Analytical data packages, including quality control
information, MUST be included for all data summarized below (as Attachment C. J).
Isotope
Pb210
U Nat (U238+235+234)
Th228
Th230
Th232
Rad226
Rad228
ND -Analyte not detected.
(Please Circle)
Composite Sample lDCi/2)
ND
1470.1
1.52
11.7
ND
11.7
ND
' Others,(f.lease Specify)
Grab Samole (oCi/2)
ND
1410.6
1.58
11.28
2.06
11.8
2.06 ·~.~1 -'\/.,! )
2. Y N Is the radioactivity contained in the feed material Low-Level Radioactive Waste as defined in the Low-Level
Radioactive Waste Policy Amendments Act of 1985 or in DOE Order 5820.2A. Chapter III? If yes, check "LLRW"
block on line 3 of page 1.
3. Y (pending)LICENSED MATERIAL: Is the feed material listed or included on an active Nuclear Regulatory Commission or
Agreement State license?
(If Yes) TYPE OF LICENSE: Source _X_; Special Nuclear Material __ ; By-Product __ ; Norm_; NARM __ ;
LICENSING AGENCY: Colorado Department of Public Health and the Environment
LICENSE NUMBER: CDPHE License Number CO 1274-01 pending. Union Pacific Railroad (UPRR) is seeking
a CDPHE Radioactive Material License. UPRR is currently in the process of finalizing the license application
process and anticipates license approval no later than the next 2-5 months.
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
Please attach a description of the material to this profile ( as Attachment D.1 a through f). Include the following as applicable:
a. The process by which the material was generated. Including available process knowledge of the material.
b. The basis of hazardous material determination or waste characterization determinations.
c. A list of the chemicals and materials · or commingled with the material.
Generator or Contractor Initials:
Page 2 of7
Radioactive Material Profile Record
d. A list of any and all current or former applicable EPA Hazardous Waste Numbers.
e. A list of any and all applicable land-disposal prohibition or hazardous-waste exclusions, extensions, exemptions,
effective dates, variances or delistings.
f. Attach any product information or Material Safety Data Sheets associated with the material.
If a category/description listed in a through f above does not apply, describe why it does not.
Please describe the history, and include the following:
The waste material is generated from the treatment of groundwater flowing through a railroad tunnel. The
groundwater contains naturally occurring radioactive material (NORM) from the Rocky Mountains and
picks up inorganic solids particles as it passes through the tunnel. Upon entering the treatment plant, the
groundwater is treated first by the addition of a coagulant, aluminum chlorohydrate (SDS attached, chemical
name Ca/chem CC2000),following by direct filtration in an ultrafiltration membrane system. Backwash
water from the ultl'aflltration membrane system containing coagulated solids is pumped through a dissolved
air flotation system where a very small amount of1" ge11eration dish soap (<0.001% by volume, SDS
attached) is added to assist in thickening of the solids via flotation. The thickened solids are further
dewatered using a centrifuge in conjunction with a very small amount of polymer, <0.001% by volume,
(Zetag 120L, SDS attached), which is added to the thickened solids prior to addition to the centrifuge. The
waste has about 75-90% moisture content and 0.13-0.14% uranium. The generation of the waste is a
continuous process, driven by the requirement to achieve NPDES permit limits in the water discharged from
the treatment plant back to the Fraser River. The waste does not exceed any TCLP limits designating it as
possessing the RCRA toxicity characteristic, nor is it reactive or flammable;, therefore it is not a RCRA
characteristic hazardous waste.
(Please Circle)
Y €)was this material mixed, treated, neutralized, solidified, commingled, dried, or otherwise processed at any time after
generation?
Y ~ Has this material b_een transported or otherwise removed from the location or site where it was originally generated?
Y @ Was this material derived from (or is the material a residue of) the treatment, storage, and/or disposal of hazardous
waste defined by 40 CFR 261?
Y @ Has this material been treated at any time to meet any applicable treatment standards?
2. LIST ALL KNOWN AND POSSIBLE CHEMICAL COMPONENTS OR HAZARDOUS WASTE CHARACTERISTICS
The generator may use its knowledge of processes and materials to in lieu of analytical data EXCEPT as required by Section 3.
Any "yes" response will require the submission of appropriate analytical data with this RMPR ( as Attachment D. 2).
y N y N y N
General Metals Metals (cont'd)
Listed Waste X Arsenic -TCLP* X Nickel-Total* X
"Derived-From" HW X Barium -TCLP* X Selenium-Total* X
Characteristic Cadmium -TCLP* X Silver-Total* X -
Reactive -CN X Chromium -TCLP* X Thallium -Total* X
Reactive Sulfide X Lead-TCLP* X Tin-Total* X
I®itable X Mercury -TCLP* X Uranium-Total* X
Corrosive X Selenium -TCLP* X Vanadium-Total* X
Toxic (as determined by TCLP analysis) X Silver -TCLP* X Zinc -Total* X
Or2anics Arsenic -Total* X Miscellaneous
voes X Barium -Total* X Explosives X
SVOCs X Beryllium-Total* X Pyrophorics X
Pesticides X Cadmium-Total* X Infectious X
Herbicides X Chromium-Total* X Chelating Agents
Dioxins v--... X Cobalt-Total* X Residue from WWT Plant X
Generator or Contractor Initials; w
Page 3 of7
Radioactive Material Profile Record
(not biologically active,
industrial treatment plant
treatinf! inorf!anic material)
PCBs X Coooer -Total* X Anions
Solvents X Iron -Total* X Fluoride"' X
Alcohols X Lead -Total* X Nitrate* X
Fuel X Manganese -Total"' X Nitrite* X
Oil X Mercurv-Total"' X Sulfate* X
Phenolics X Molybdenum -X Sulfide* X
Total*
* Analytical data are required for these constituents regardless of generator knowledge of process or materials.
Generator or Contractor Initials:
Page4 of7
Radioactive Material Profile Record
3. REQUIRED ANALYTICAL RESULTS. Generator must submit results of analyses of samples of the material. Results are
required from a qualified laboratory for the following analytical parameters. Attach all analytical results and QA/QC
documentation available (as Attachment D.3). (CAUTION: PRIOR TO ARRANGING FOR LABORATORY ANALYSIS,
CHECK WITH EFRI REGARDING UTAH LABORATORY CERTIFICATIONS.) Please summarize results on the blank
spaces provided.
Analyte TCLP·Range or Maximum (mg/L)
-Arsenic ND/ND
Barium l.46/1.50
Beryllium NA
Cadmium ND/ND
Chromium ND/ND
Cobalt NA
Copper NA
Iron NA
Lead ND/ND
Manganese NA
Mercury ND/ND
Molybdenum NA
Nickel NA
Selenium ND/ND
Silver ND/ND
Thallium NA
Tin NA
Uranium NA
Vanadium NA
Zinc NA
Fluoride NA
Nitrate NA
Nitrite NA
Sulfate NA
Sulfide NA
ND = Not Detected NA-Not analyzed
Additional Required Analytical Information:
pH (liquids only):_8.03 __
Grab/Composite
Paint Filter Liquids Test (Please Circle):S Fail
Free Liquid Present (Please Circle): Yes ®
Is the material a RCRA oxidizer? (Please Circle): Yes®
4. PRE-SHIPMENT SAMPLES OF MATERIAL TO EFRI
-
Total Concentration Range or Maximum
(mg/kg)
-Grab/Composite i. ..
10.0/10.9
276/311
ND/ND
ND/ND
ND/ND
6.40/7.31
114/128
22,200/30,200
144/164
377/431
l.15/1.28
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
4,530/4,890
31.7/34.8
426/485
4.14/5.30
ND/ND
ND/ND
74.7/87.9
ND/ND
Once permission has been obtained from EFRI, and unless amenability samples have previously been sent to EFRI, please
send 5 representative samples of the material to EFRI. A completed chain of custody form must be included with the
sampling containers. These samples will be used to establish the material's incoming shipment acceptance parameter
tolerances and may be analyzed for additional parameters. Send about two pounds (one liter) for each sample in an air-tight
clean glass container via United Parcel Post (UPS) or Federal Express to:
Energy Fuels Resources (USA) In?., Attn: a1 pie Control, 6425 S. Highway 191, P.O. Box 809, Blanding, UT 84511
Phone: [phone]
Generator or Contractor Initials:
Page 5 of7
Radioactive Material Profile Record
5. LABO RA TORY CERTIFICATION INFORMATION. Please indicate below which of the following categories applies to
your laboratory data.
a. All radiologic data used to support the data in item C. l. must be from a certified laboratory.
_X_UTAH CERTIFIED. The laboratory holds a current certification for the applicable chemical or radiological
parameters from the Utah Department of Health insofar as such official certifications are given.
__ GENERATOR'S STATE CERTIFICATION. The laboratory holds a current certification for the applicable chemical
parameters from the generator's State insofar as such official certifications are given, or
__ GENERATOR'S STATE LABORATORY REQUIREMENTS. The laboratory meets the requirements of the
generator's State or cognizant agency for chemical laboratories, or:
If using a non-Utah certified laboratory, briefly describe the generator state's requirements for chemical analytical
laboratories to defend the determination that the laboratory used meets those requirements, especially in terms of
whether the requirements are parameter specific, method specific, or involve CLP or other QA data packages.
b. For analytical work done by Utah-certified laboratories, please provide a copy of the laboratory's current certification
letter for each parameter analyzed and each method used for analyses required by this form.
c. For analytical work done by laboratories which are not Utah-Certified, please provide the following information:
State or Other Agency Contact Person Generator's State Telephone Number
Lab Contact Person Laboratory's State Telephone Number
E. CERTIFICATION
GENERATOR'S CERTIFICATION: I also certify that where necessary those representative samples were or shall be provided
to EFRI and io qualifit:<l laburalurit::s for the analytical re:mlts reported herei..1. I also certify that the frlformation provided on this
form is complete, true and correct and is accurately supported and documented by any laboratory testing as required by EFRI. I
certify that the results of any said testing have been submitted to EFRI. I certify that the material described in this profile has
been fully characterized and that hazardous constituents listed in 10 CFR 40 Appendix A Criterion 13 which are applicable to this
material have been indicated on this form. I further certify and warrant to EFRI that the material represented on this form is not a
hazardous waste as defined by 40 CFR 261 and/or that this material is exempt from RCRA regulation under 40 CFR 261.4(a)(4).
The Generator's responsibilities with respect to the material described in this form are for policy, programmatic, funding and
scheduling decisions, as well as general oversight. The Contractor's responsibilities with respect to this material are for the day-
to-day operations (in accordance with general directions given by the Generator as part of its general oversight responsibility),
including but not limited to the following responsibilities: material characterization, analysis and handling; sampling; monitoring;
record keeping; reporting and contingency planning. Accordingly, the Contractor has the requisite knowledge and authority to
sign this certification on behalfof itself, and as agent e Generator, on behalf of the Generator. By signing this certification,
the Contractor is signing on its own behalf and o the Generator.
Generator's or Contractor's Signature -,e,.,:....c:...,G...1,,,.-..__ ___ _
(Sign for the above certifications).
Title_Manager, Environ Field Ops Date 3&tt.2/!f
Print Name oflndividual Signing above: _Steven L. Preston _________ _
Generator or Contractor Initials:
Page 6 of7
4/3/2019
List of Documentation Required With the Submission of This RMPR
\ttachment B.6-Waste Photograph [Description of Physical Attributes of the Material included in body of
submission.]
Attachment C.1 -Radiological Analysis -Data Packages (including all pertinent Quality Control Data)
Attachment D. l a through f-Material generation process history and description [Included in body of submission.]
Attachment D.2 -Analytical data (including all pertinent Quality Control Data) for all yes answers
Attachment D.3 -Analytical Data (including all pertinent Quality Control Data) for total and TCLP metals and anions
[Included in body of submission. J
Attachment D.4-Safety Data Sheets for·chemicals used in the process: CalChem CC2000, Zetag 120L and
Seventh Generation Dish Soap
Page 7 of7
EXHIBIT C
FORM OF AFFIDAVIT
AFFIDAVIT OF STEVEN L. PRESTON
I , Steven L. Preston, being duly sworn according to law, depose and state as follows:
1. I am presently employed as the Manager, Environmental Field Operations for
Union Pacific Railroad ("UPRR") at the company's Winter Park Industrial Wastewater
Treatment facility (the "IWT Facility"). In that capacity, I am responsible for managing the
subcontracted Facility operations and maintenance. My experience with the IWT Facility dates
back to April 2017 when the facility began processing wastewater. I have personal knowledge of
the raw materials used, the production processes employed, and the waste handling procedures
followed at the Winter Park IWT Facility. I am also familiar with the hazardous waste
regulations set out in U.S. Code of Federal Regulations, Title 40261, Subpart D, as amended by
the U.S. Federal Register August 6, 1998.
2. UPRR proposes to ship to Energy Fuels' White Mesa Mill near Blanding Utah,
uranium-bearing materials for processing as alternate feed materials. All of the proposed
alternate feed materials consist of uranium containing semi-solids as product from the Facility's
wastewater treatment and sludge recovery operations in the United States and other countries and
contain no materials or wastes from any other source.
3. The uranium-bearing materials consist of semi-solid metals containing wastewater
treatment facility sludges, which accumulated over a period up to one year at the IWT Facility.
The sludges were produced by UPRR's wastewater treatment process. For purposes of this
affidavit, the sludges and associated materials shall be "Material."
4. Based on the processing steps employed in the wastewater treatment and sludge
recovery operation that generated the Material, the Material does not contain any of the listed
wastes enumerated in U.S. Code of Federal Regulations, Title 40 261, Subpart Das amended by
the U.S. Federal Register August 6, 1998.
5. Based on my knowledge of waste management at the IWT Facility, the Material
has not been mixed with wastes from any other source, which may have been defined as or
which may have contained listed wastes enumerated in U.S. Code of Federal Regulations, Title
40 Section 261, Subpart Das amended by the U.S. Federal Register August 6, 1998.
6. Specifically, the Material does not contain hazardous wastes from non-specific
sources (U.S. RCRA F type wastes) because (a) to the extent that the IWT Facility may generate
the types of wastes listed in Section 261.31 of Title 40 of the U.S. Code of Federal Regulations,
UPRR has not commingled such wastes with the Material; and (b) UPRR has never accepted at
the IWT Facility, nor has the Material ever been combined with, wastes from any other source
which contain U.S. RCRA f' type wastes as defined therein.
7. Specifically, the Material does not contain hazardous wastes from specific sources
(U.S. RCRA K type wastes) because (a) UPRR does not opei:ate any of the processes which
produce the types of wastes listed in Section 262.31 of Title 40 of the U.S. Code of Federal
Regulations, and (b) UPRR has never accepted at the IWT Facility, nor has the Materiai ever
been combined with, wastes from any other source which contain U.S. RCRA K type wastes as
defined therein.
8. Specifically, the Material is not U.S. RCRA P or U type waste as defined in
Section 261.33 of Title 40 of the U.S. Code of Federal Regulations because (a) it is not and does
not contain manufactured or formulated commercially pure grade chemicals, off spec
commercial chemical products or manufacturing chemical intermediates, residues from
containers that held commercial chemical products or manufacturing chemical intermediates, or
any residue or contaminated soil, water or other debris resulting from a spill cleanup of any of
the foregoing, in each case as listed in Section 261.33, and (b) UPRR has never accepted, nor has
the Material ever been combined with, wastes from any other source which contain U.S. RCRA
P or U type wastes as defined therein.
9. Finally, the Material has been regulated by the Colorado Department of Public
Health & Environment as source material under 6 CCR 1007-1, PART 18: Licensing
Requirements for Uranium and Thorium Processing. As such, the radiological portion of the
Material is excluded from the definition of hazardous waste under the Resource Conservation
and Recovery Act to the extent set forth therein and in regulations and guidance from the U.S.
ission and U.S. Environmental Protection Agency.
Sworn to and subscribed before me
this~ day ofll.{iJ, 2019
My Commission Expires: -'~D~~~_q_,...._a~®---9_· ---
Attachment B.6
Waste Material Photograph
Attachment C.1
Radiological Analysis -Data Packages
kit=l• I Laboratories LLc
PO Box :;o112 Chndeston. SC 29417
21MO S..1·1aQe Rond Cha1teston. SC 29~07
P a~~ 656.8171
F 84!.i.J66.11 78
'
Page I of 13
a member of The GEL Group INC
August 06, 2018
Kira Peterson
CDMSmith
555 17th Street, Suite 500
Denver, Colorado 80202
Re: Radiochemistry Analyses
Work Order: 454139
Dear Kira Peterson:
GEL Laboratories, LLC (GEL) appreciates the opportunity to provide the enclosed analytical results for the
sample(s) we received on July 09, 2018. This original data report has been prepared and reviewed in accordance
with GEL's standard operating procedures.
Our policy is to provide high quality, personalized analytical services to enable you to meet your analytical needs
on time every time. We trust that you will find everything in ~rder and to your satisfaction. If you have any
questions, please do not hesitate to call me at (843) 556°8111, ext. 4778.
Purchase Order: GELPI8-0635
Enclosures
Sincerely,
~~( rryG-,. __ _
Tay1~r Cannon for
Hope Taylor
Project Manager
•
gal.com
Page 2 of 13
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 -[phone] -www.gel.com
Certificate of Analysis Report
for
CDMMOOI CDM Smith
Client SDG: 454139 GEL Work Order: 454139
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
• * Analyte is a Tracer compound
0 Analyte is a surrogate compound
U Analyte was analyzed for, but not detected above the :MDL, MDA, MDC or LOO.
UI Gamma Spectroscopy-Uncertain identification
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless qualified on the Certificate of Analysis.
The designation ND, if present, appears in the result column when the analyte concentration is not detected above
the limit as defined in the 'U' qualifier above.
This data report has been prepared and reviewed in accordance with GEL Laboratories LLC
standard operating procedures. Please direct any questions to your Project Manager, Hope Taylor.
Reviewed by
GEL LA BORA TORIES LLC
2040 Savage Road Charleston SC 29407 -[phone] -www.gel.com
Certificate of Analysis
Report Date: August 6, 2018
Company;
Address:
Contact:
Project:
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
CDMSmith
555 17th Street, Suite 500
Denver, Colorado 80202
Kira Peterson
Radiochemistry Analyses
Winter Park Material Grab
454139001
Sludge
02-JUL-18 15:00
09-JUL-18
Client
Parameter Qualifier Result
Rad Gamma Spec Analysis
DL
Gammaspec, Gamma, Solid (Standard List) "Dry Weight Corrected"
. Lc:ad-210 U ND 33.4
Radium-226 ll.8 0.399
Radium-228 2.06 0,605
Th,,rium-228 1.58 0.334
Jm-230 11.8 0.399
·1..~, mm-232 2.06 0.605
Uranium-234 11.8 0.399
Uranium-235 98.8 1.94
Uranium-238 1300 13.6
The following Prep Methods were performed:
Method Description
Dry Soil Prep Dry Soil Prep GL-RAD-A-021
The following Analytical Methods were performed:
Method Description
I DOE HASL 300, 4.5.2.3/Ga-01-R
Notes:
Column headers are defined as follows:
DF: Dilution Factor
DL: Detection Limit
Le/LC: Critical Level
PF: Prep Factor
RL: Reporting Limit
RL
Analyst
CXB7
MDA: Minimum Detectable Activity
MDC: Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 3 of 13
Project:
Client ID:
CDMMOOI18
CDMMOOI
Units PF DF Analyst Date Time Batch Method
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
Date
07/09/18
Time
1412
RXF2 08/01/18 0716 1780600
Prep Batch
1780496
Analyst Comments
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 -[phone] -www.gel.com
Certificate of Analysis
Report Date: August 6, 2018
Company:
Address:
Contact:
Project:
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
CDMSmith
555 17th Street, Suite 500
Denver, Colorado 80202
Kira Peterson
Radiochemistry Analyses
Winter Park Material Composite
454139002
Sludge
02-JUL-18 15:00
09-JUL-18
Client
Parameter Qualifier Result DL
Rad Gamma Spec Analysis
Gammaspec, Gamma, Solid (Standard List) "Dry Weight Corrected"
Lead-210 U ND 45.9
Radium-226 11.7 0,446
Radium-228 UI ND 1.20
Thorium-228 1.52 0.395
'fl-·'•Jm-230 11.7 0.446
,m-232 UI ND 1.20
Uranium-234 11.7 0.446
Uranium-235 98.4 2.18
Uranium-238 1360 17.4
The following Prep· Methods were performed:
Method Description
Dry Soil Peep Dry Soil Prep GL-RAD-A-021
The following Analytical Methods were performed:
Method Description
I DOE HASL 300, 4.5.2.3/Ga-01-R
Notes:
Column headers are defined as follows:
DF: Dilution Factor
DL: Detection Limit
Le/LC: Critical Level
PF: Prep Factor
RL: Reporting Limit
RL
Analyst
CXB7
MDA: Minimum Detectable Activity
MDC: Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 4 of 13
Project:
Client ID:
CDMM00118
CDMMOOl
Units PF DF Analyst Date Time Batch Method
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
Date
07/09/18
RXF2 08/01/18 0716 1780600
Time Prep Batch
1412 1780496
Analyst Comments
GEL LA BORA TORIES LLC
2040 Savage Road Charleston, SC 29407 -[phone] -www.gel.com
QC Summa!:! Renort Date: August 6, 2018 CDMSmith Page 1 of 4
555 I 7th Street, Suite 500
Denver, Colorado
Contact: Kira Peterson
Workorder: 454139
Parmname NOM Sam~le Qual QC Units RPD% REC% Range Anlst Date Time
Rad Gamma Spec
Batch 1780600
QC1204065828 454139001 DUP
Lead-210 u 12.0 u 12.5 pCi/g NIA N/A RXF2 08/01/18 08:29
Radium-226 11.8 11.7 pCi/g 0.51 (0%-20%)
Radium-228 2.06 2.67 pCi/g 26.1 (0%-100%)
Thorium-228 1.58 1.53 pCi/g 2.9 (0%-100%)
Thorium-230 11.8 11.7 pCi/g 0.51 (0%-20%)
Thorium-232 2.06 2.67 pCi/g 26.1 (0%-100%)
Uranium-234 11.8 11.7 pCi/g 0.51 (Oo/o-20%)
Uranium-235 98.8 106 pCi/g 6.56 (0%-20%)
Uranium-238 1300 1440 pCi/g 9.93 (Oo/o-20%)
QC1204065829 LCS
Americium-241 488 533 pCi/g 109 (75o/o-125%) 08/01/18 08:29
Cesium-137 172 173 pCi/g 101 (75o/o-125%)
Cobalt-60 127 123 pCi/g 96.6 (75%-125%)
Lead-210 5600 pCi/g
Page 5 of 13
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 -[phone] -www.gel.com
QC Summa!l'.
Workorder: 454139 Page 2 of 4
Parmname NOM Sam~le Qu.al QC Units RPD%, REC% Range Anlst Date Time
Rad Gamma Spec
Batch 1780600
Radiwn-226 u -0.511 pCi/g RXF2 08/01/18 08:29
Radium-228 u -0.564 pCi/g
Thoriwn-228 u 0.131 pCi/g
Thorium-230 u -0.511 pCi/g
Thorium-232 u -0.564 pCi/g
Uranium-234 u -0.511 pCi/g
'ium-235 u -0.544 pCi/g
Uranium-238 u -29.2 pCi/g
QC1204065827 MB
Lead-210 u -1.74 pCi/g 08/01/18 07:17
Radiu.m-226 u -0.00436 pCi/g
Radium-228 u 0.0656 pCi/g
Thorium-228 u 0.0364 pCi/g
Thorium-230 u -0.00436 pCi/g
Thorium-232 u 0.0656 pCi/g
Uranium-234 u -0.00436 pCi/g
Page 6 of 13
GEL LA BORA TORIES LLC
2040 Savage Road Charleston, SC 29407 -[phone] -www.gel.com
QC Summary
Workorder: 454139 Page 3 of 4
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Rad Gamma Spec
Batch 1780600
Uranium-235 u -0.0732 pCi/g RXF2 08/01/18 07:17
Uranium-238 u 0.235 pCi/g
Notes:
The Qualifiers in this report are defined as follows:
<
>
BD
FA
H
Analyte is a Tracer compound
Result is less than value reported
Result is greater than value reported
Results are either below the MDC or tracer recovery is low
Failed analysis.
Analytical holding time was exceeded
Value is estimated
K Analyte present. Reported value may be biased high. Actual value is expected to be lower.
L Analyte present. Reported value may be biased low. Actual value is expected to be higher.
M M if above MDC and less than LLD
M REMP Resuit > MDC/CL and < RDL
NIA RPD or %Recovery limits do not apply.
Nl See case narrative
ND
NJ
Q
R
u
UI
UJ
UL
X
y
I\
h
Analyte concentration is not detected above the detection limit
Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
One or more quality control criteria have not been met. Refer to the applicable narrative or DER.
Sample results are rejected
Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.
Gamma Spectroscopy--Uncertain identification
Gamma Spectroscopy--Uncertain identification
Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.
Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
Other specific qualifiers were required to properly define the results. Consult case narrative.
RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry.
Preparation or preservation holding time was exceeded
Page 7 of 13
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 -[phone] -www.gel.com
QC Summary
Workorder: 454139 Page 4of 4
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
NI A indicates that spike recovery limits do not apply when sample concentration exceeds spike cone. by a factor of 4 or more or %RPD not applicable.
" The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than
five times (SX) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of+/-the
RL is used to evaluate the DUP result.
• Indicates that a Quality Control parameter was not within specifications.
For PS, PSD, and SDIL T results, the values listed are the measured amounts, not final concentrations.
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
Page 8 of 13
Page 9 of 13
Product; Dry Weight
Radiochemistry
Technical Case Narrative
CDM Smith (CDMM)
SDG #: 454139
Prepuation Method: Dry Soil Prep
Preparation Procedure: GL-RAD-A-021 REV# 23
Preparation Batch; 1780496
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID#
454139001
454139002
Client Sample Identification
Winter Park Material Grab
Winter Park Material Composite
The samples in this SDG were analyzed on an "as received" basis.
Data Summary:
There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration, instrument controls and process controls where applicable.
Product; Gammaspec, Gamma, Solid (Standard List)
Analytical Method; DOE HASL 300, 4.5.2.3/Ga-01-R
AnaMjcal Procedure; GL-RAD-A-013 RTIV# 27
Analytical Batch; 1780600
PrepRratjon Method; Dry Soil Prep
PrepHrntion Procedure; GL-RAD-A-021 REV# 23
Prepar-atjon Batct1; 1780496
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID#
454139001
454139002
1204065827
1204065828
1204065829
Client Sample IdentificRtion
Winter Park Material Grab
Winter Park Material Composite
Method Blank (MB)
454139001(Winter Park Material Grab) Sample Duplicate (DUP)
Laboratory Control Sample (LCS)
The samples in this SDG were analyzed on a "dry weight" basis.
Data Summary;
There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration, instrument controls and process controls where applicable.
Page 10 of 13
Qualifier Information
Qualifier
UI
Reason
Results are considered a false
positive due to low abundance.
Certification Statement
Analyte Sample Client Sample
Radium-228 454139002 Winter Park Material
Composite
Thorium-232 454139002 Winter Park Material
Composite
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
I
, GEL Laboratories, LLC [!J... Laboratories LLC 2040 Savage Road
gel.com Chemistry I Radiocllernistry I RadlolJloaasay I Specially Analyfics Cl1a.rleston, SC 29407
of I
Chain of Custod and Anal ical Re uest Phone: [phone]
·-=-~-., ·-· L • -~ • ''3 Fill(; (843_)766-1-178
~s~P'~i.~, ·. Sample-Ali~lysis·Re!u~ed_ (5l (Fill'in "tb!_nuin~~ofcon~iners for ea~h}st}:i~
:-.: .... ~.,·
\ ~
Date
-s-1~
2
~ 9r3'.:>~-~~-z~o
Cf) cg'c) \.I~ 2-
·~~dJ111s.,.oi~-~o......._
•Date Collected
•Tim~
Collected
QC 1 · Fiel-d 1 ·s.mple.
F.11• IJJ ~!IW('l
SL
~L
'.¢.h'.~-oi\Cu,stoqt;Sig11a!µr~ , .. ' -..,. I
Time Received by (signed) Date Time
5k;>
2
Should-this
·slllDple be
'CO~lf~cd!.
• f ~;t ~ ..::-.
~i ....... ·:;:: C g_
-~ :; i , . ., .
. 3 ... ... as. .O· i:·
,:: s ~
4
1
~
TAT'Requei.erl! l'lonn~: z_ Rush: ___ Spedf.y:
Fax Results:
Addirional Remarh:
<-J!reseFVatfvej'')'ll_e:@
0,omm.~o'.ts,
Not~;;~rl:o/~leds
requirfd,for sample
specifi'c!QU
(Subject.to Surcturfge)
Levcl4
3 3 For lab Recelving Use Only: Custod))__Seal J111act? [J Yes _[ ] No Cooler Temp: °C
''*:ffp,:,si;;jilj!;f1,ij,.ef!!g,q/fd,ef!fjy"t!!Jlffe#ii{s, S£~ S"am.J!'ei:R~~efpt.'&i./J.pi819j~rm{(S.Rfl;) -----------. . . ~~~Cpll~tjn ~e'7..oile: '[ l~ [') P~6i:fic'. 'n _c;cu,ga1 ·Ji KO\!ll!aj'n -~9\ll~
I.) Chain of Custody Number= Clicul Dclcm1ined
2.) QC Codes: N• Nomial Sainplc, TB-Trip Blank, FD• Field Duplienlc, ED •Equipment Blonk, MS• Matrix Spike Samph,, MSD • Mau-ix Spike Duplicolc SomFlc, G • Grab, C•Composilc
3.) Field Fillcrcd: For liquid matrices, indicate wilh a -Y -for )"5 lhc sample was field fill<red or -N • for sample was llOl field f;l\ercd.
,) Mau-ix Codc-s: DW=Drinking Water, GW=Groundwoler, SW-Surface Waler, WW=Waslc Water, W=Watcr, ML=Misc Liqdd, SO=Soil, SD•Sedimenl, SlrSludgo, SS-Solid Waste, 0-0il, l'=Fihc,·, l'=Wipe, U=Urinc. f;::Fccal, N-Nasal
S.J Sample Analysis Requested: Analylinl meLl1od requested (i.e. 82608, 60l0Bn470A) nnd number of conl:lincr,; provided for ,ach (i.e .• ~2608 -3, 6010817470A -1).
6.) PrcseCV'.itive T)11c: IL\.• Hydrochloric Acid, NI • Nitric Acid, SU -Sodium Hydroxide. SA..,. Sulfuric Acid, AA• Ascorbic ~\cid, HX__. He."1s1111c:~ ST• Sodium Thiosulfatc, 1f no prcscrv.Jtive is added • leave field blank
:::!! .
cf =i:Oiff'"muun ,..,~ , .. -,,-•a-~ .. m;..~Gbrtmllum. -. ~-· .. fb'=,.Lea1i "• ~"t--" ·-~ ......... •;...;,c·
=Ml· ,• ~~ -e:rcuey
§~::S~teitiµm_
Ag=·Silver ·-•· :-V-.· ••
MR= Mis __ ~~~-s
:R~inemls
r.r Characteristic .Hazards
' ... ktrlrnliiiil<in,tllb)~
C0 -= Cl'lII:osfve
RE=Reactive
ITSCAR~l11ted I P€B=·?i~e8
. biphen:yJs
(F;K,P w,d U-lisied wastes.)
Waste code(s):
.er/ Ullllllown
(Le.: Hig/r/&111 pH. asb~los, beryllium. irriumrs, other
misc. -heallh luwuds, 'etc.)
Desci,·iption:
' a I Laboratories 1.LC
' SAMPLE RECEIPT & REVIEW FORM
CUent:
Received By: Dote .Received:
Courier OU1cr
Currier and Trucking Number fil/Z?
Suspulcd Hamrtl lnfomintlon i!l £ •If Net Counts> I OOcpm on sampl~s not mnrkcd "rndioaclivc·, conluct tho Rorliolion Sufety Group for further
:>< inveltlgotiOCL
Shi d as n DOT 1:hurdous?
COC/Somplcs mu.rked or classified as
mdloac.Uvc?
Is pocko ·, COC, ontVor S11111plc• nuui(ed HAZ'/
Snmple Receipt Crilcrlo
1 Shipping containen, received i111act and
scaled?
2 Ch.uln of custody documents included
wilh shl menl?
3
4 0311)1 check performed and passed on IR
1cmpcrature gun?
5 Sumple containers inlact and sculed?
6 S~mplc.1 requiring chemical preservation
ut proper pH?
7 Do any samples require Volatile
An11lysis?
8 Samples received within holding time?
9 Sample ID's on COC match ID's on
bottles?
10 ~:::e~i;e on COC mntch dole & time
Number of containers received match 11 number indicated on COC?
12 An: snmplc conllliners ldcnlllieble 11s
GEL rovldcd?
13 COC fonn is properly signed in
cell uishc:d/n:cci~d sections?
Comm,::nls (Use Conlinu.atl.ou Fonn if needed)!
-~-;L
J
:11111~001e.rve1I"-(Observed Counts· A.n:a Background Counts): ~~.c..,r,,
Rnd2 Rad 3
If yes. sale 1.;riu bolow, and contact 11!,, O.EL Safety Croup.
Flumm11blc Foreign Soil RCRA Asbe&ios Beryllium Other.
Conunenis/Quallllcrs (Required for Non-Confonnlng Items)
Clcclc Applla>blc: Scnls broken Dnm:iaeo conuliner Lultlng c,,nUul\O' Other (describe)
Pn:scrvaUoc, Method: \Vet Ice kc Pncks Dry ice
•a11 lffllPernlllru nte n..'Cordcd In Celsius
01her.
TEMP: ;t_. 2-.
Circle Appllcobl<: Scnls broken DorMacd con1oiner IJ:>lclna con1alner 0.hcr (dCfflibo)
S111~lc JD'J Md Coc,ralocn AffeC'lcd:
If Yes, Are Encores or Soil Kits present? Yes __ No_ (If yes, lnkc 10 VOA Freezer)
Do VOA vials contain acid preservation? Yes No_N/A, (If unknown. select No)
OA vials free ofheadspace? Yes No_ N/A
Sample ID's and containers affected:
SA11'4'lcJD'1 ond con1olnerS af(c,:1cd:
Smnplc 10'1 nrrect<J:
S;,q,lc ID's .rrc.:1cd:
PM (or PMA) review: lnilla\1 ___ :J1M&--_._'-'-=-----Dote _ _,'-1-:.....;.-i-:...u..--Pug<: __ I _ or_\_
GL-CHL-SR-001 Rev 5
Page 12 of 13
List of current GEL Certifications as of 06 August 2018
State Certification
Alaska 17-018
Arkansas 88-0651
CLIA 42D0904046
California 2940
Colorado SC00012
Connecticut PH-0169
Delaware SC00012
DoD ELAP/ ISOI 7025 A2LA 2567.01
Florida NELAP E87156
Foreign Soils Permit P330-15-00283,P330-15-00253
Georgia SC00012
Georgia SDW A 967
Hawaii SC00012
Idaho Chemistry SC00012
Idaho Radiochemistry SC00012
Illinois NELAP 200029
Indiana C-SC-01
Kansas NELAP E-10332
Kentucky SDWA 90129
Kentucky Wastewater 90129
Louisiana NELAP 03046 (AI33904)
Louisiana SDW A LA180011
Maryland 270
Massachusetts M-SC012
Michigan 9976
Mississippi SC00012
Nebrnska NE-OS-26-13
Nevada SC000122018-l
New Hampshire NELAP 205415
New Jersey NELAP SC002
New Mexico SC00012
New York NELAP 11501
North Carolina 233
North Carolina SDWA 45709
North Dakota R-158
Oklahoma 9904
Pennsylvania NELAP 68-00485
Puerto Rico SC00012
S. Carolina Radiochem 10120002
South Carolina Chemistry 10120001
Tennessee TN 02934
TexasNELAP Tl04704235-18-13
UtahNELAP SC000122018-26
Vermont VT87156
Virginia NELAP 460202
Washington C780
West Virginia 997404
Page 13 of 13
Attachment D.2
Analytical data
Steve Preston
Union Pacific Railroad
1400 W. 52nd Ave.
1-unedcan Wes ~ Denver, Co 80221
Ar4ALVTIC/I.L LABORATORIES
RE: Union Pacific Railroad / Moffat Treatment Residuals Testing
Dear Steve Preston: Lab Set ID: 1806483
3440 South 700 West
Salt Lake City, UT 84119 American West Analytical Laboratories received sample(s) on 6/21/2018 for the analyses
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
presented in the following report.
American West Analytical Laboratories (AW AL) is accredited by The National
Environmental Laboratory Accreditation Program (NELAP) in Utah and Texas; and is
state accredited in Colorado, Idaho, New Mexico, Wyoming, and Missouri.
All analyses were performed in accordance to the NELAP protocols unless noted
otherwise. Accreditation scope d~cuments are availaple upon request. If you have any
questions or concerns regarding this report please feel free to call.
The abbreviation "Surr" found in organic reports indicates a surrogate compound that is
intentionally added by the laboratory to determine sample injection, extraction, and/or
purging efficiency. The "Reporting Limit" found on the report is equivalent to the
practical quantitation limit (PQL). This is the minimum concentration that can be
reported by the method referenced and the sample matrix. The reporting limit must not be
confused with any regulatory limit. Analytical results are reported to three significant
figures for quality control and calculation purposes.
Thank You,
Approved by:
Laboratory Director or designee
Report Date: 7/6/2018 Page 1 of33
All analyses applicable lo lhc CWA, SDWA, and RCRA DI':: pcrfonncd in nccordoncc Lo NE LAC prolocols. Pertinent snmpling ir1formolion is localed on the at111chcd COC, Confidential Business lnformntion: This report is pro~·idcd for lhc c:<clushe use oflhe
addressee, Pri\'ilcges or subsequent l1se of lhe nmne of t1iis company or any member of ils slnff, or reproduction of lhis report in connection wiLh the od,;ertisemenr, promotion or sale of any producl or process, or in connection wid1 the re-publication of this report
3440 South 700 West
Steve Preston
Union Pacific Railroad
1400 W. 52nd Ave.
Denver, Co 80221
RE: Union Pacific Railroad/ Moffat Treatment Residuals Testing
Dear Steve Preston: Lab Set ID: 1806483
Salt Lake City, UT 84119 American West Analytical Laboratories received sample(s) on 6/21/2018 for the analyses
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
presented in the following report.
American West Analytical Laboratories (AW AL) is accredited by The National
Environmental Laboratory Accreditation Program (NELAP) in Utah and Texas; and is
state accredited in Colorado, Idaho, New Mexico, Wyoming, and Missouri.
All analyses were performed in accordance to the NELAP protocols unless noted
otherwise. Accreditation scope documents are available upon request. If you have any
questions or concerns regarding this report please feel free to call.
The abbreviation "Surr" found in organic reports indicates a surrogate compound that is
intentionally added by the laboratory to determine sample injection, extraction, and/or
purging efficiency. The "Reporting Limit" found on the report is equivalent to the
practical quantitation limit (PQL). This is the minimum concentration that can be
reported by the method referenced and the sample matrix. The reporting limit must not be
confused with any regulatory limit. Analytical results are reported to three significant
figures for quality control and calculation purposes.
Thank You,
Approved by:
Laboratory Director or designee
Report Date: 7/6/2018 Page I of33
All a'l"lfrc:s oppll .. blc lo lhcCIVA, SOWA. and RCRA ore P'rfom,cd in ...,ord•••~ lo N6LAC pn,ooeol~ Pettin<n111.11>1pllng lnronnotlon is loeoll!d oo Ille oUocht<I COC. Coof>dcnliol BIiii nm lnfonn.11ion, n,;. n,po:t ls provided fer !he e,o:lll<iro ""'orlho
oddt<sleo. Privilcg<>s or subrcqu<nt IIIO or Ibo """" or lhil <OftlPMl' or M)' mombor of ios 11111T, or rcprodlicl!oq or U,i, 1<poc1 in ooonc<lion w.1111 tho •dvcl\UCl!lal~ ll"'fl'Odon or ,.i, or "'IY p<WUCI or p<oeeu or i11 C<M111tcdon wilh lho r<·p!lbliCAtloo or 11111 ,cport
(or "'IY purpo>e o!ht, !hon for lbo oddtc,wc will be 8Tlftl«i only°" cooro,t Thi, company 1<cop1$ no ,apoo,lbillty e,<cepl t'ot lliodoc P'rfom,,nccoClrupc.oJon ••di•• 1111.olysi, In llocd follh MCI uconlini·to ih< 1ulcs oflbo lt!ldo Dlld of odrno<>.
INORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project: Union Pacific Railroad/ Moffat Treatment Residuals Testing
Lab Sample ID: 1806483-001
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results TOTAL METALS
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
Salt Lake City, UT 84119 Aluminum mg/kg-dzy 6/25/2018 845b 7/3/2018 1239h SW60l0D 4,770 72,000
Arsenic mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 9.54 10.0
Barium mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 17.2 276
Phone: [phone] Beryllium mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 7.63 < 7.63
Cadmium mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 3.24 <3.24
Toll Free: [phone] Calcium mg/kg-dry 6/25/2018 845h 7/3/2018 1410h SW60100 477 9,180 B
Fax: [phone] Chromium mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 38.1 < 38.l
e-mail: [e-mail] Cobalt mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 5.15 6.40
Copper mglkg-diy 6/25120.18 845h 6125/20.18 1529h SW6020B 59.l 114
web: www.awal-labs.com Iron mg/kg-dry 6/25/2018 845h 7/3/2018 1344h SW6010D 715 22,200
Lead mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 24.8 144
Magnesium mg/kg-dry 6/25/2018 845h 7/3/2018 1410h SW6010D 477 4,840
Kyle F. Gross Manganese mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 15.3 377
Laboratory Director Mercury mg/kg-dry 6/27/2018 1743h 6/28/2018 803h SW7471B 0.169 1.15
Molybdenum mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 76.3 < 76.3
Jose Rocha Nickel mg/kg-dzy 6/25/2018 845h 6/.lS/1018 1529h SWtiU208 76.3 < 76.3
QA Officer Potassium mg/kg-dry 6/25/2018 845h 7/3/2018 1410h SW60l0D 477 5,030
Selenium mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 32.4 < 32.4
Silver mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 5.72 < 5.72
Sodium mg/kg-dry 6/25/2018 845h 7/3/2018 1410h SW60l0D 477 953
Thallium mg/kg-dry 6/25/2018 845h 6/25/2018 1529h SW6020B 15.3 < 15.3
Tin mg/kg-dry 6/25/2018 845b 7/3/2018 1410h SW60100 47.7 <47.7
Uranium mg/kg-dry 6/25/2018 84Sh 6/25/2018 1600h SW6020B 14.3 4,530
Vanadium mg/kg-dry 6/25/2018 845h 7/3/2018 1410h SW60l0D 2.38 31.7
Zinc mg/kg-dry 6/25/2018 845h 6/25/2018 1529b SW6020B 191 426
B -The method blank was acceptable, as the method blank result is less than 10% of the lowest reported sample concentration.
Report Date: 7/6/2018 Page 2 of 33
All ,n,l)"IO& opplkoblc lo !lie CWA, SDWA. and RCRA oro perfomlcd in oe<ardon,c IO Nill.AC prolD<O!t. Pof1in<nl wmpllng lnloono~on it lo<11i<d co lh, oUoth<d CDC. Coofi<l,nwl 8111inc&s lnfon1111lon: This roport i, provided for lhe exclusive use of lhe
•dd1cuco. PrMIC{l:cS or n1bkiqucot \lJ(I of dio l\llnc ortnit-,omJ)My or ;m)' mom be, of K.J it arr, or ,cprocfoolion of lhl1 rapor1 in C'OMcicllon ,Yilh lhcr odvc.niJcmC'fll, promotion or 111lt or :my ptOdiK't or p,mccu, o, fn ;.oar:Kn;Uon ffllh 1M R"-p.:,blle1tfoo of thi1 repon
fciranv DUn>e>s,c,clhcrt.hDn for lhc AdW'CJta \\111 be a-11n1~ on\v gn con1oct. Thls con10MV occe:DU no ,c.suo~slbllitv ""at fo« the duo ocrfonn1ncc.or inmec:1ion Md/or1DAlvll:1 Jn '-'OCXI (ailh .1nd ueonflnu to tho IU!c.s·orlbo lmdc: &ad of SCrlc:nce.
INORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project: Union Pacific Railroad/ Moffat Treatment Residuals Testing
Lab Sample ID: 1806483-002
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results TOTAL :METALS
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
Salt Lake City, UT 84119 Aluminum mg/kg-dry 6/25/2018 845h 7/3/2018 1241h SW60l0D 4,830 79,300
Arsenic mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW60208 9.67 10.9
Barium mg/kg-dry 6/25/2018 845h 6/25/20 I 8 1532h SW6020B 17.4 311
Beryllium mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW60208 7.73 < 7.73 Phone: [phone] Cadmium mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW6020B 3.29 <3.29
Toll Free: [phone] Calcium mg/kg-dry 6/25/2018 845h 7/3/2018 1412h SW60I0D 483 10,100 B
Fax: [phone] Chromium mg/kg-dry 6/2S/2018 845h 6/25/2018 1532h SW60208 38.7 <38.7
e-mail: [e-mail] Cobalt mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW60208 5.22 7.31
Copper mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW6020B 59.9 128
web: www.awal-labs.com Iron mg/kg-dry 6/25/2018 845h 7/3/2018 1346h SW6010D 725 30,200
Lead mg/kg-dry 6/25/2018 845b 6/25/2018 1532h SW6020B 25.1 164
Magnesium mg/kg-dry 6/25/2018 845h 713/2018 1412h SW6010D 483 5,300
Kyle F. Gross Manganese mg/kg-dry 6/25/2018 845b 6/25/2018 1532h SW6020B 15.5 431
Laboratory Director Mercury mg/kg-dry 6/27/2018 1743h 6/28/2018 805h SW7471B 0.157 1.28
Molybdenum mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW6020B 77.3 <77.3
Jose Rocha Nickel mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW6020B 77.3 <77.3
QA Officer Potassium mg/kg-dry 6/2512018 845h 7/3/2018 1412b SW60l0D 483 5,530
Selenium mg/kg-dry 6/2S/2018 845h 6/25/2018 1532h SW6020B 32.9 <32.9
Silver mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW6020B 5.80 < 5.80
Sodium mg/kg-dry 6/25/2018 845h 7/3/2018 1412h SW60!0D 483 1,110
Thallium mg/kg-dry 6/25/20 I g 845h 6/25/2018 1532h SW6020B 15.5 < 15.5
Tin mg/kg-dry 6/25/2018 845h 7/3/2018 1412h SW6010D 48.3 < 48.3
Uranium mg/kg-dry 6/25/2018 845h 6/25/2018 1603h SW6020B 14.5 4,890
Vanadium mg/kg-dry 6/25/2018 845h 7/312018 1412h SW6010D 2.42 34.8
Zinc mg/kg-dry 6/25/2018 845h 6/25/2018 1532h SW6020B 193 485
B -The method blank was acceptable, as the method blank result is less than 10% of the lowest reported sample concentration.
Report Date: 7/6/2018 Page 3 of33
IIII Gt1:>l)<>< .. ppllcoblc to die CWA, SOWA, 011d RCRA .,, p:rfonucd In xGON!.,,ce to NEI.AC protocolJ; rc,~11<.'n< s.,mpUu3 inrormatim, ia loc,led 0,1 ihc auachcd COC, Confidential Bu,incss 111r111111111on; Thi, n:jl<ll1 i& providod (or Ille ad-1ro llfOoflhc
add=oce. P1Ml<J1C1 ofsubtcQU<tll u,e or d,, """" of lhlt <Offlfl""Y or If!)' m<mbcr ~ 1 .. w.rr, or reproducllon or lhi, report In "'""«!loll wtlh lbt ,d,-.rtiwncnt, promoJJon o, Ale or Olly p1oduct o, p o«<<, or in ooMCctloa ,riJJ, JJ10 f'Collllbl~ of d,i, report
for "''Y purpose olher ill.Oil for the ad«oS!<O "Ill t,,., 11on1<d Cllll)'0 011 co111KL ThlJ comp,ny ,mp11 no ._ibili~· except for lhc due pc,(...,,.... or in1{'CCl""1 ond/oc ,noli·•l< in good r.;u, llld oc,oof10g lo lhc rules or lhe trade Md or rcic:ncc.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
INORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project: Union Pacific Railroad / Moffat Treatment Residuals Testing
Lab Sample ID: 1806483-001
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results TCLP METALS Method 1311
TCLP Prep Date: 6/26/2018 2050h Date Date Method Reporting Analytical
Compound Units Prepared Analyzed Used Limit Result Qual
Arsenic mg/L 6/28/2018 1313h 6/29/2018 1234h SW6020B 0.0100 < 0.0100
Barium mg/L 6/28/2018 1313h 6/29/2018 1234h SW6020B 0.0500 1.46
Cadmium mg/L 6/28/2018 1313h 6/29/2018 1234h SW6020B 0.00350 <0.00350
Chromium mg/L 6/28/2018 1313h 6/29/2018 1234h SW6020B 0.0200 < 0.0200
Lead mg/L 6/28/2018 1313h 6/29/2018 1234h SW6020B 0.0500 < 0.0500
Mercury mg/L 6/2812018 1640h 6/29/2018 1052h SW7470A 0.0100 < 0.0100
Selenium mg/L 6/28/2018 1313h 6/29/2018 1234h SW6020B 0.0100 < 0.0100
Silver mg/L 6/28/2018 1313h 6/.!9/2018 1234h SW6020B 0.0100 < 0.0100
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-Iabs.com
Ky]e F. Gross
Laboratory Director
Jose Rocha
QA Officer
INORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project: Union Pacific Railroad / Moffat Treatment Residuals Testing
Lab Sample ID: 1806483-002
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results TCLP METALS Method 1311
TCLP Prep Date: 6/26/2018 2050h Date Date Method Reporting Analytical
Compound Units Prepared Analyzed Used Limit Result Qual
Arsenic mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.0100 < 0.0100
Barium mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.0500 1.50
Cadmium mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.00350 < 0.00350
Chromium mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.0200 < 0.0200
Lead mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.0500 < 0.0500
Mercury mg/L 6/28/2018 1640h 6/29/2018 1054h SW7470A 0.0100 <0.0100
Selenium mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.0100 < 0.0100
Silver mg/L 6/28/2018 1313h 6/29/2018 1237h SW6020B 0.0100 <0.0100
Report Date: 7/6/2018 Page 5 of33
All anDlysos applicable to lhc CWA, SDW A. and RCRA ArC perform~ in a.:cordancc lo NE LAC prolocols. Pertinent 111mpling infonnolion is locDLcd oo. lhe attached COC, Confidenli11I BusU'lei, ln(u1ma1M>n: This rq,on Is p:ovld:d (o, lfu: cxclU$.i,·c use orlhc
1.ch!raseio:. Privilagcs of sublcqotnl me of lb8 naMO of this company or any member of its stDff, or roprocfDcllon of this riport in conruiction with tho advertisement, promotion or solu of any produc·l or proccs~ or in connr.ction \\'ilh the rt-pubfi~rion of lhts repon.
for any purpc,5e other lhan for lhe addrasec: "·itl be ll'&"lcdoal~· oa cootacl, This C<Jmpany accepts no re&p001ibi1ity cxcopl rorthc due perfoRMnQCI of inspection Qfld/or i\O.alycis Ml good fa~ Md qccordi"J to lhc Nlc:1 o(tho trade DJ1d ohck:noc:.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
Client:
Project:
Lab Sample ID:
INORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-001
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results
Date Date Method Reporting
Compound Units Prepared Analyzed Used Limit
Ammonia ( as N) mg/kg-dry 6/26/2018 705h 6/26/2018 904h E350.1 117
Chloride mg/kg-dry 712/2018 1942h E300.0 0.473
Flashpoint Of 6/26/2018 1100h SWIOIOA 25.0
Fluoride mg/kg-dry 7/2/2018 1942h E300.0 0.473
Nitrate/Nitrite (as N) mg/kg-dry 6/22/2018 1239h E353.2 0.0473
pH@25°C pH Units 6/21/2018 1835h SW9045D 1.00
Sulfate mg/kg-dry 7/212018 1942h E300.0 3.55
Sulfide mg/kg-dry 6/2212018 652h SM4500-S2-D 0.142
$ -Method 1-0-lOA is not an approvedprocedure for solid malertals.
web: www.awal-labs.com & -Analysis is performed on a I: J DJ water extract/or soils.
H -Sample was received outside of the holding time.
Kyle F. Gross
Laboratory Director Compound
Date
Analyzed
Jose Rocha
QA Officer
Paint Filter 6/21/2018 1711b
H-Sample was received outside of the holding time.
Method
Used
SW9095B
•,l
Analytical
Result
no free liquids
Analytical
Result Qua)
245
6.39 &
>200 $
4.14 &
< 0.0473 &
8.11 H
74.7 &
< 0.142 &
Qual
II
Report Date: 7/6/2018 Page 6 of 33
All an,lysc,.ppllcable lo iii• CWA, SDWA, and RCRA an> po,fonnod in acc:ordanco IO Nlil.AC proiocol,. Pcrtioenlson1pling infonnation i, loc:111:d on i!ie allochod COC. ConrKltnUol Bll8in,..Jnfomt11Joo: This n:port la provided roe thomcclud,~ u,, of tho
addn:ssaa. Privileges of su'b«queot usc of the 11A1Ue of dlls COIDJl'"'Y or any member or ils Slllf, or Rpro<lucll<>n or lhis A port In connection wilh lho advertisemen~ promOllon "'sole of Ill)' Jl"Od11<I or l)NICC:IS. or in conocellon wilh lbc "'11Vbl><,tion o( this ,.port
fnr nnv numrv;:e nthr.r lhnn rlV' IN!. Md~ fflll M onmtrrl nnh• ,m cnnt~t Thit ~nanv 11cc11nb1 nn rcitnnn.<lhililv e'Xl:lenl ror lhe fflle nerl'nrmance nf irunrctlon and/oranoJv.ds 1n ROod taiih 111d acmnflne IO lN) NIQoflM 1t*5o anti of~
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
Client:
Project:
Lab Sample ID:
INORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-002
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results
Date Date Method Reporting
Compound Units Prepared Analyzed Used Limit
Ammonia (as N) mg,'kg-dry 6/26/2018 705h 6/26/2018 905h E350.I 112
Chloride mg,'kg-dry 7/2/2018 1959h E300.0 0.471
Flashpoint "F 6/26/2018 I IOOb SWJOIOA 25.0
Fluoride mg,'kg-dry 7/2/2018 1959b E300.0 0.471
Nitrate/Nitrite (as N) mg/kg-dry 6/22/2018 1242h E353.2 0.0471
pH@25° C pH Units 6/21/2018 1835h SW9045D 1.00
Sulfate mg,'kg-dry 7/2/2018 1959h E300.0 3.53
Sulfide mg/kg-dry 6/22/2018 652h SM4500-S2-D 0.141
$ -Method JO JOA is not an approved procedure/or solid materials.
web: www.awal-labs.com &-Analysis ispeiformed on a 1:1 D!waterextractforsoi/s.
H -Sample was received outside a/the holding time.
Kyle F. Gross
Laboratory Director Compound
Date
Analyzed
Jose Rocha
QA Officer
Paint Filter 6/21/2018 171 !h
H -Sample was received outside of the holding time.
Method
Used
SW9095B
Analytical
Result
no free liquids
Analytical
Result Qual
342
8.77 &
>200 $
5.30 &
< 0.0471 &
8.03 H
87.9 &
< 0.141 &
Qua!
H
Report Date: 7/6/2018 Page 7 of3 3
All 1111f)-J¢1 """1Jcoble 10 Ibo CWA, SOW A, and RCRA w pc1'°"11cd In ""°'1llneo 10 Nill.AC p<01000l1. PciCinenl >mtpllnJ lnfonnallon 11 loc•lcd on tho Olloohod COC. Conlldm1i,I 8"1mC1J ln(onn11io~; This ,.poll ii pn,vid«l (or ihc =lush'O uie o(lhc
oildte,;;oo, J>,i.ii.,.. of Sl.lbk<pmc .,.. 9'1bo """"' or chi, ,...,,,...l' « "1)' member of ju 1t1tr, o, rcpn,d,,<1lon o( dds r,port In -«Ion "'"' lhc od,·crti.somcn~ pro,notl~ o, 111, crony pro,locl or pn,ca,. o, k, ""1D<Cllon wlih Ibo «·pubHciulon or thls report
, .. OIi)' ...._ Gdlor .,,.., '°' ~ ~ ... m bo ,,. .. u.1 Oftl)• oc, <onl:icl. Thlt c,omplll)' ICl>Cj]IJ.., rc,pom11,m.,. OXCfJl( rortho duo pcd"o"1l>OCO or ln:lpcctlon ... d/or ... ry,it in IJOOO foill1 ond ICCOldi .. to Ibo nolcs otlho ln>lk llld 4r lal)lonco.
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moft'a'.t Treatment Residuals Testing
1806483-00lB
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h Test Code: 8081-S-3546
Analytical Results Organochlorine Pests TCL GC/ECD Method 808IB/3546
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Analyzed: 6/29/2018 1415h
Units: µg/kg-dry
Compound
4,4'-DDD
4,4'-DDE
4,4'-DDT
Aldrin
alpha-BHC
alpha-Chlordane
beta-BHC
delta-BHC
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan sulfate
Jose Rocha Endrin
QA Officer Endrin aldehyde
Endrin ketone
gamma-BHC
gamma-Chlordane
Heptachlor
Heptachlor epoxide
Methoxychlor
Toxaphene
Surrogate Units: µglkg-dry
Surr: Decachlorobiphenyl
Surr: Tetrachloro-m-xylene
Extracted: 6/25/2018 1200h
Dilution Factor: 1 Method:
CAS Reporting
Number Limit
72-54-8 9.42
72-55-9 9.42
50-29-3 9.42
309-00-2 9.42
319-84-6 9.42
5103-71-9 9.42
319-85-7 9.42
319-86-8 9.42
60-57-1 9.42
959-98-8 9.42
33213-65-9 9.42
1031-07-8 9.42
72-20-8 9.42
7421-93-4 9.42
53494-70-5 9.42
58-89-9 9.42
5566-34-7 9.42
76-44-8 9.42
1024-57-3 9.42
72-43-5 23.5
8001-35-2 47.1
CAS Result Amount Spiked %REC
2051-24-3 26.4 47.10 56.0
877-09-8 19.9 47.10 42.3
@ -High RPD due to suspected sample non-homogeneity or matrix lnte,ference.
1 -Matrix spike recovery Indicates matrix lnte,ference. The method is in control as indicated by the LCS.
Ge/-Penneation Chromatography (GPC) Cleanup, method 3640A, 11tilizedfor this sample.
SW8081B
Analytical %TIC
Result Qual Qualily
< 9.42 ',@
<9.42
< 9.42
<9.42
< 9.42
< 9.42
< 9.42
<9.42
<9.42
< 9.42
< 9.42
<9.42
<9.42
<9.42
<9.42 ',@
<9.42
<9.42
< 9.42
<9.42
<23.5 ',@
< 47.1
Limits QuRI
10-180
10-135
Report Date: 7/6/2018 Page 8 of33
All onolyie, opplicablo 10 II« CWA, SDW A, orul. RCR.O. ore p«roro,cd in occordoncc 10 IIELAC prolo<ol,. Per!i11<ftl ...,,piing infom10aon I, locat<d on lho olloch<~ COC. Confod<nlial B••i•= Jnfono,don: 1bit 1<po,1 l1 pro,ld<d f01 Ilic <><lush-...,. of lhe ~ Pffl'l"=Fof 1u~~cnt ~ or1ho ~~o of~lJ~p-.,·~-!'!!~~~~rWI ".".'='-~-~~-~~·!~~-~~·;.1~.~c~~!~1i~~~ ~~~-~-~~~~~~'~!:1,~~ !.~~~~.!!~ .. ~~!:~!!!lion or lbisroport
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-002B
Client Sample ID: Winter Park Material Composite
ANALv11cAL LAeoR•ron,u Collection Date: 6/20/2018 1400h
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Received Date: 6/21/2018 1055h Test Code: 8081-S-3546
Organochlorine Pests TCL GC/ECD Method 8081B/3546 Analytical Results
Analyzed: 6/29/2018 1800h
Units: µg/kg-dry
Compound
4,4'-DDD
4,4'-DDE
4,4'-DDT
Aldrin
alpha-BBC
alpha-Chlordane
beta-BBC
delta-BBC
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Endrin aldehyde
Endrin ketone
gamma-BBC
gamma-Chlordane
Beptachlor
Beptachlor epoxide
Methoxychlor
Toxaphene
Surrogate Units: µwlcg-dry
Surr: Decachlorobiphenyl
Surr: Tetrachloro-m-xylene
Extracted: 6/25/2018 1200h
Dilution Factor: 1
CAS
Number
72-54-8
72-55-9
50-29-3
309-00-2
319-84-6
5103-71-9
319-85-7
319-86-8
60-57-1
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-93-4
53494-70-5
58-89-9
5566-34-7
76-44-8
1024-57-3
72-43-5
8001-35-2
Method:
Reporting
Limit
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
9.37
23.4
46.9
CAS Result Amount Spiked % REC
2051-24-3
877-09-8
0
40.3
46.86
46.86
0
86.0
Gel-Permeation Chromatography (GPC) Cleanup, method 3640A, utilized/or this sample.
SW808IB
Analytical
Result
< 9.37
< 9.37
<9.37
< 9.37
<9.37
<9.37
< 9.37
< 9.37
<9.37
< 9.37
<9.37
<9.37
< 9.37
< 9.37
< 9.37
< 9.37
<9.37
<9.37
< 9.37
<23.4
<46.9
Limits
10-180
10-135
S -Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.
%TIC
Qual Quolily
s
Report Date: 7/6/2018 Page 9 of33
All lW!ylct oppllcablo 10 lho C\VA, SOW A, nl RCRA &1c_por(OC1110d in oc<Olll"'1« to NE LAC p,v<o<ols. l'<d!aa,1 ....,prms lnformOlioa h lo<olcd oa die~ COC. Confodcn~al llu,Jo.., fllfamMllon: TIii> "'flOll ls po,lclnl fa, die c.qfu,i,,o 111e ol'lbc
..i.s.-. PrivUoso oCsubscqoonl 111< of lhona111e of lhlJcampa,)"«•nt member of lu 11arr: orttpC"Odl>etlonof Chh 1CJ10t1 In _ion""" lho od=i-_ ptOIIIOlloom """or Ml)' P••lucl'«P'O(ffS. or ln-iloa willl llN lll~oflhi• l"J'O'I
for Ill)' j!Ul!IOSCOlbcr d,1111 r« lhoaddroaoo "ill bo -l«lonb' on <<•UocL 'lllis~.acctpll no ,-.,ibililf c,cc(III fot lho cm.,..ronnanc< ofwpottlonaod.'ot10ol)ctb in 11<1od faith and according ro lhollll1:5oflbc ,,..,.1111<1 or.clc~
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-00IB
Client Sample ID: Winter Park Material Grab
•N,.,v,1cA1. L.eoRATOAIEs Collection Date: 6/20/2018 1400h
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Received Date: 6/21/2018 1055h Test Code: 8081-S-3546
Analytical Results Organochlorine Pests TCL GC/ECD Method 8081B/3546
Analyzed: 6/29/2018 1415h Extracted: 6/25/2018 1200h
Units: µg/kg-dry Dilution Factor: 1 Method:
CAS Reporting
Compound Number Limit
4,4'-DDD 72-54-8 9.42
4,4'-DDE 72-55-9 9.42
4,4'-DDT 50-29-3 9.42
Aldrin 309-00-2 9.42
alpha-BHC 319-84-6 9.42
alpha-Chlordane 5103-71-9 9.42
heta=BHC 319-85-7 9.42
delta-BHC 319-86-8 9.42
Dieldrin 60-57-1 9.42
Endosulfan I 959-98-8 9.42
Endosulfan II 33213-65-9 9.42
Endosulfan sulfate 1031-07-8 9.42
Endrin 7?.-20-8 9.42
Endrin aldehyde 7421-93-4 9.42
Endrin ketone 53494-70-5 9.42
gamma-BHC 58-89-9 9.42
gamma-Chlordane 5566-34-7 9.42
Heptachlor 76-44-8 9.42
Heptachlor epoxide 1024-57-3 9.42
Methoxychlor 72-43-5 23.5
Toxaphene 8001-35-2 47.l
Surrog11te Units: µwk:g-dry CAS Result Amount Spiked %REC
Surr: Decachlorobiphenyl 2051-24-3 26.4 47.10 56.0
Surr: Tetrachloro-m-xylene 877-09-8 19.9 47.10 42.3
@ -High RPD due to suspected sample non-homogeneity or matrix interference.
1 -Matrix spike recovery indicates matrix interference. The method is in control as indicated by the LCS.
Gel-Permeation Chromatography (GPC) Cleanup, method 3640A, utilized/or this sample.
SW8081B
Analytical o/.TIC
Result Qual Quality
<9.42 ',@
< 9.42
< 9.42
<9.42
<9.42
< 9.42
< 9.42
<9.42
<9.42
<9.42
<9.42
<9.42
< 9.42
<9.42
< 9.42 ',@
< 9.42
< 9.42
< 9.42
<9.42
<23.5 ',@
<47.l
Limits Qual
10-180
10-135
Report Date: 7/6/2018 Page 8 of33
All analyse, npplic11ble lo lhc CWA, SOWA. and RCRA GR perfom,ed in acc:onhmce 10 NELAC protocols. Pertinent .!l1m1plin1 infonnation is localed on the alioched COC. Confidunlial Business Inrorru11Lion: This report ispro~jded (or aheexclusi,•e use ortbc
addressee. Pri\'ileges or subsequent use or lhc name of lhis coropony Of 1ny mc:n,bcr of its staff, or ro~lion or this report in connccllon wilh lhc advertisement, promotion or sale or tn)' producl or procews, or in conneclioo with the n:-p,bliutioo of (hi& report
ror ooy pu~ olhcr lh1m for the addm,ee wjll be gnintcd only on coo_lDC.L Thls e;ompnny accepl5 no tc$JK1ft.libilily excepl for lhc due perfonmmcc or in,pection und/or MDl)•sis fo. good foiLh and 11ccording to the rules ofUu, trade and or science.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-00IE
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8081-W-TCLP
TCLP Pesticides by GC/ECD Method 8081B/131 l/35IOC
Analyzed: 7/3/2018 2250h
Units: mg/L
Compound
alpha-Chlordane
Chlordane, total
Endrin
gamma-BHC
gamma-Chlordane
Heptachlor
Heptachlor epoxide
Methoxychlor
Toxaphene
Extracted: 7/3/2018 1431h TCLP Prep Date: 7/2/2018 1200h
Dilution Factor: 1 Method: SW8081B
CAS Reporting Analytical
Number Limit Result
5103-71-9 0.000100 <0.000100
57-74-9 0.00100 <0.00100
72-20-8 0.000100 < 0.000100
58-89-9 0.000100 < 0.000100
5566-34-7 0.000100 < 0.000100
76-44-8 0.000100 < 0.000100
1024-57-3 0.000100 < 0.000100
72-43-5 0.000100 < 0.000100
8001-35-2 0.00125 < 0.00125
%TIC
Qual Qu1llly
Kyle F. Gross Surrogate Units: mg/L CAS Result Amount Spiked %REC Limits Qual
Laboratory Director
Jose Rocha
QA Officer
------------------------Surr: Decachlorob iphenyl
Surr: Tetrachloro-m-xylene
2051-24-3
877-09-8
0.000576 0.0007500
0.000427 0.0007500
76.8 15-149
56.9 I 1-120
Report Date: 7/6/2018 Page 10 of33
All oul)1!:S=lclblc 10 lhoC'\YA,SDWI\. ood RCAA .,.pofonuc<I In ,._dan<c1<>NELI\C ,roto<ob. P<fllnNIIS411!plU11 lnfom,.OC., ii locokdon lhcllllihod COC. Conndcnliol lllillncu~ '111111oporil1proridod r«lhceo«IOl!m.,.oflhe """""-P · ot~111JG oldl<-ollhl1<<•>1Jll'lY or llll)'lncmbcrofi0111fT,«10JN~tlono(t1,i, 1~ in «>r1111<1ion ,.;11, lllo od,erti_,,,.~ p<OfflOII"""' Mltolany poduciOt JIIO<'ffl,,O<ln (1)MO<lion wit!, 11,o,.,pul,liealloo of Otis roport ror ooy ~ Iha ro, Ibo addtffloo ,.,u ti. lf*llnl aal)· on CIGlllqol. Tbh <'1fflP"'>' a<ttplo no r41por11ilillil)' .-pi for lhc due po,formmo or ln,pcction IIICIIG1-1)'Cii la &ood r.i!h one! oocordlns to rho ni1 .. oflbo l1od< ml or oolroco.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.a~al-labs.com
ORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project:
Lab Sample ID:
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-002E
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8081-W-TCLP
TCLP Pesticides by GC/ECD Method 8081B/131 l/3510C
Analyzed: 7/3/2018 2313h
Units: mg/L
Compound
alpha-Chlordane
Chlordane, total
Endrin
gamma-BHC
gamma-Chlordane
Heptachlor
Heptachlor epmd:de
Methoxychlor
Toxaphene
Extracted: 7/3/2018 1431h TCLP Prep Date:
Dilution Factor: 1 Method:
CAS Reporting
Number Limit
5103-71-9 0.000100
57-74-9 0.00100
72-20-8 0.000100
58-89-9 0.000100
5566-34-7 0.000100
76-44-8 0.000100
1024-57-3 0:000100
72-43-5 0.000100
8001-35-2 0.00125
7/2/2018 1200h
SW8081B
Analytical
Result
< 0.000100
< 0.00100
< 0.000100
< 0.000100
<0.000100
< 0.000100
<' 0.000100
< 0.000100
< 0.00125
%TIC
Qua) Qoolity
Kyle F. Gross Surrogate Units: mg/L CAS Result Amount Spiked %REC Limits Qual
Laboratory Director
Jose Rocha
QA Officer
--------------------------Surr: Decachlorobiphenyl
Surr: Tetrachloro-m-xylene
2051-24-3
877-09-8
0.000565 0.0007500
0.000423 0.0007500
75.3 15-149
56.4 11-120
Report Date: 7/6/2018 Page II of33
All """lp<s tpjJllcablo lo lb< CIYA, SOWA, oncl RCRA {IIC pcrfo<mcd in 111:eord,nco oo NllLAC pffllO<Ols. Pcrti0<nl somj1llot inrom,oUon IJ looo!al oo 111, m,ched COC. Con lld<nd.ol n..i ... unro.,.olion: Tll ls t0port 1, p,ovi~ ro, Ibo OX<lusl• .. ...., or tho
~-PrivlloSC"S or ...t..q,,,n1 "'' orah, ..,,. o( t11h """P'Wlf "' ony member of !lo ,106; or 1<plod,x1l<a1 of lhlt n,po11 in oonoc,Uon wllb 010 od,erth<m,,t, l''""l"~°" or >II• or In)' Jll'lldii<l or pr<XQJ, or in oonn,,o~on wllh aho ro-P"l>!lc«loo o(11>,, n:port
fa, tiny"""'°"'"°'" Ihm fo< 11,c O<!~l\"1>'"' wlll bo (!r>lllod Mly on eonta<L Thi> oon1p:iny ocoo'pl!< no mQIOIISibllilycxcepl ro, lho duo porfo11110n« oflmpcod01t cndlor 01101 ,i. in ~ood rolth and 11<eo<dlno IO Iha niJe, ord,o lt<ldo ond ohol-.
3440 South 700 West
SaltLakeCity, UT 84ll9
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-00lB
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results
Test Code: 8082-S-3546
PCBs by GC/ECD Method 8082A/3546
Analyzed: 6/25/2018 907h
Units: µg/kg-dry
Compound
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Surrogate Units: µg,'kg-dl)'
Surr: Decachlorobiphenyl
Extracted: 6/22/2018 1103h
Dilution Factor: I Method:
CAS Reporting
Number Limit
12674-11-2 118
11104-28-2 118
11141-16-5 118
53469-21-9 118
12672-29-6 118
11097-69-1 118
11096-82-5 118
CAS Result Amount Spiked %REC
2051-24-3 12.3 23.51 52.2
SW8082A
Analytical %TIC
Result Qual Quality
< ll8
< ll8
< ll8
< 118
< 118
< ll8
< 118
Limits Qual
10-180
Kyle F. Gross Surr: Tetrachloro-m-xylene 877-09-8 20.8 23.51 88.4 10-145
Laboratory Director Sulfuric acid cleanup method 3665A utilized for this sample.
Jose Rocha
QA Officer
Report Date: 7/6/2018 Page 12 of33
All onolYJ<• oppllcablc lo Iii• CWA, SOWA, and RCM •~ p,:rfonnad in .. ,onl>nc410 NliLAC pr<>IO<>OI,. Pcnloi!nt ,,uupling lnronn,Uo,, 1, loco1<d on lh, allochtd COC. Confid,1111,1 8~"""Jnform11ion: Thi, n:port ia piorld<d r..-lhc C)l<UJ,lvc we of tho
~. PrM!c300 of.a,~ IDO ol' lho ftlfflO ol'lhllcomp"'y or 1IIY mtml>ot ol'ila n.orr, or n:p,oductlon or lhia iq,011 In <00n«Uon 1.Jth lh, odveotlsernrn~ Jl<onrotlon ot $010 olQII)' prodlicl or ~-tu, or in eonnoc1lon with lllo 1o-public01ion of this report
(0< ony P<il'l>OSO other lh9'I ro, tho~ "1R bo pt111od on!)• on -1. TIiis _,l""l' OC«r,\S no r-'1>1111)' <>~Cpl fo, lhc duo po,fonn:u,co ol in>i><<ll.on nrtd/or 111111)~11 "'-i;ood foiilh .. d mordin1 IO Clio rulu ofiho' tfl>do 1t1d or >Cl once.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-002B
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8082-S-3546
PCBs by GC/ECD Method 8082A/3546
Analyzed: 6/25/2018 919h
Units: µg/kg-dry
Compound
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Surrogate Units: µgikg-dry
Surr: Decachlorobiphenyl
Extracted: 6/22/2018 1103h
Dilution Factor: 1 Method:
CAS Reporting
Number Limit
12674-11-2 118
11104-28-2 118
11141-16-5 118
53469-21-9 118
12672-29-6 118
11097-69-1 118
11096-82-5 118
CAS Result Amount Spiked %REC
2051-24-3 12.7 23.51 54.1
SW8082A
Analytical %TIC
Result Qual Quality
< 118
< ll8
< 118
< 118
< 118
< 118
< 118
Limits Qual
10-180
Kyle F. Gross Surr: Tetrachloro-m-xylene 877-09-8 50,8 23,51 216 10-145 s
Laboratory Director S -Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.
Jose Rocha
QA Officer
Su/ji1ric acid cleanup method 3665A 11tilizedfor this sample.
Report Date: 7/6/2018 Page 13 of33
All analyscu1pplicable lo lhc CWA, SOWA, Md R.CRA Jlfe perfonucd in accord11nce to NELAC protocols. Pertinent sPtnpling infonnotion is loct:iled oo the auucbcd COC. ConfidenUal Business Jnfonnnlion: This ropon is provided (or lho exclush'a ure-of lhi;.
llddressee. Privilegos o(,ubsequentwic orlha nPme of thi9 company or any membt,r or it.I staff. or reproduction or lhis rvport 01. coRm:ction ,vilh the advertisement, promotfon or 11le of any product or proceu, or in connection wjth lhe re•publicodon Df lhl.s rtpart
rnr Anv nmnn.tr. nlhP.r1hAn rn:r 1hr. ftrMl"fl,;zllf'r: will hn omntM nnl1< {VI f'nnlArt 'Thi, t'.llnlnrrnv ltl""""'"l,;z nn l'Pra"1tv1,;zihi1itv P,'rP.nl f'M"th..i rfm• nP.r-f'nmmnr,. nri'""""'"JU\n 01nrt/nrannh,ci, in onnrt (nilh 11nrt Ar.rnTrtinu tn IM n1l11.,nf'lh11. tnirtn AM nf,riP.nrP.
3440 South 700 West
SaltLakeCity, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-00IB
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8151-S
Herbicides D-List by GC/ECD Method 8151A/3550C
Analyzed: 6/28/2018 1800h
Units: µg/kg-dry
Compound
2,4,5-TP
2,4-D
Surrogate
Surr:DCAA
Uoits: µg/kg-dry
Extracted: 6/26/2018 641h
Dilution Factor: 1 Method: SW8151A
CAS Reporting Analytical %TIC
Number Limit Result Qua! QuoUly
93-72-1 23.5 <23.5
94-75-7 47.0 <47.0
CAS Result Amount Spiked %REC Limits Qual
19719-28-9 98.1 112.9 86.9 10-144
Report Date: 7/6/2018 Page 14 of33
All onal) ... 'fll!lli»blo IO lhc CWA, SOW A. and RCRA ...,.pct!Offllcd In accordoncc to Nl!LAC plOIO<Ols. Prltinc111 i.amplloa lofonnwpc, i& locoied oo llie """""'d CDC. Ccw1r111tftllal D!,oiotu lnlonullon: Tbl• ropo11 la p<OYldcd far flloC<Ch,si1't ... or d,c -. Pti~Ucauof 111brcqurn1 IISO orlli< """"'0C,lhh-1p111y or Ill')" mcmborof!l11Utr, orrq,roduellon of lhhtcpOlt 1n-.occuor1 1Yllh 1h: odffnll<ffl<II~ pr,,mc,,lonat .W. or...,, pn>clocl or ~ or ln..._lio<l,dlh Ibo "1'"111ltadon orlli~ ""°" l'Ot Ill)' put]lQle oClior 0.... for Ibo oddffl.1cc ,.;11 bo 111nlcd onty oo -...,~ This ""'111"")" ....... "° '"flO!Ulb!lllr c:.utpt ror dlO doo pononnonc:e of iNpcclion aod/or ... IJ•sl.l 111 p,od f oid, ad l«Ol'lllna ,o Ibo 1111 ... or Ibo ~ and or~.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-002B
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8151-S
Herbicides D-List by GC/ECD Method 8151A/3550C
Analyzed: 6/28/2018 1913h
Units: µg/kg-dry
Compound
2,4,5-TP
2,4-D
Surrogate
Surr: DCAA
Units: µgtkg-dry
Extracted: 6/26/2018 641 h
Dilution Factor: 1 Method: SW8151A
CAS Reporting Analytical "/.TIC
Number Limit Result Qual Qualily
93-72-1 23.5 <23.5
94-75-7 46.9 <46.9
CAS Result Amount Spiked %REC Limits Qual
19719-28-9 78.3 112.7 69.5 10-144
Report Date: 7/6/2018 Page 15 of33
All anplyses applicable lo the CWA, SDWA, nnd RCRA are ~rfomicd in nccordonoc lo NE LAC proloools. Pertinent s11.mpling infonnolion is located oo lhe aUachcd COC. Confidential Blllinetslnfonnnlfon: This report is pro9ided fOJ" I.he exclusive use of lbo addresseo. Privileaes ohubill!qucnt use of lhc n11.nu1 of I.his ,D1npony or llny member of its st;:iff, or reproduction of this mport in conn"ction wilh lhe a.dn·rtisernent, pn;,mDtion orsah, of any product Or" proce!is, or in connection 'l't'ith the re-public:otion of lhis n,port r .... r nnu n11nV'la• nth ... 1h.,,,. '"" , .... ~.t,1-.,.,..~ u,.;11 ha,...., .. ...,,.. ..,,..I,;,..., ,.,...,1.,,.• 'J"'l.,j., .,,....,.,,. ... , "'"'""'" .,,. r .. .-.. ....... :1.:1:,., ,...,_.,_, ,.,,_ ,,._ .... __ _,. _______ ,. :----6:----.11-----•·-:-:_ ---.1 i".:,1.. --.1 -----.1:--•-11..---L--.f',I.. • .__..,_ •• .I -If--!---
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-00 lE
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8151-W-TCLP
Herbicide TCLP List GC/ECD Method 8151 A/ 1311/351 OC
Analyzed: 7/5/2018 1917h
Units: mg/L
Compound
2,4,5-TP
2,4-D
Surrogate
Surr: DCAA
Units: m~L
Extracted: 7/3/2018 658h TCLP Prep Date: 7/2/2018 1200h
Dilution Factor: 1 Method: SW8151A
CAS
19719-28-9
CAS
Number
93-72-1
94-75-7
Reporting
Limit
0.00100
0.00100
Result Amount Spiked %REC
0.0121 0.01500 80.5
Analytical
Result
< 0.00100
< 0.00100
Limits
10-177
%TIC
Qua! Quality
Qual
Report Date: 7/6/2018 Page 16 of33
All oru1ly .. 11pplloablo IO ltlo CWA. SOWA, ••d RCRA ••• pcrt'onn,d in occonloncc 10 NElAC p'°""a11, l'<tdncn! , .. nplinsforQffllatian b lac:11<d oa die auoched COC. Canfod<ntlal Burlnou lnfomallon: This ropon Is p,orlckd fw lhen<hnl,·•-of lbc llddr....._ Prlvi\CSCI of ,.,bo<,quenl = o( &ho ._ or lhl,comp-,y « Ill)' mcmboror iU >tofT, or rcpiodixllon o( 0,ls ffpol1 in conn«tlon "Ill, Ilic od1•cnlsemen1, p<ontOU0/1 or oo.lc or QR)' prod"'I Ot p<OCetS, 0/ In -,noclion 1Ti1h llto la•J)"btictlioo or lllis roporl
for OIi)' purpose Olh<r Ilion fo, do, oddt<.,.. mll.bo lfllllc<I o,,1)-an-l Thll oon,p1111y oc<opta no .. ._ibilil)'c"'cp< for Lh< due pctfonnoncc of intpcction ond/or ,nolysb In GQOcl rollh nnd oc00<dln1 IO lhc ru1 .. oflhc Ind< ood of Kien\\C,
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-Iabs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
ORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project:
Lab Sample ID:
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-002E
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8151-W-TCLP
Herbicide TCLP List GC/ECD Method 8151A/1311/3510C
Analyzed: 7/5/2018 2029h
Units: mg/L
Compound
2,4,5-TP
2,4-D
Surrognte
Surr: DCAA
Units: mg/L
Extracted: 7/3/2018 658h
Dilution Factor: 1
CAS
Number
93-72-1
94-75-7
TCLP Prep Date:
Method:
Reporting
Limit
0.00100
0.00100
CAS Result Amount Spiked %REC
19719-28-9 0.0139 0.01500 92.4
7/2/2018 1200h
SW8151A
Analytical
Result
< 0.00100
< 0.00100
Limits
10-177
%TIC
Qua) Quallly
Qual
ReportDate: 7/6/2018 Page 17of33
All analy3ea applicable to the CWA, SOWA, 1:md RCRA m perfom1ed in accordance to NELAC protocols. Pertinent sllll\pling inronnnlion is locnted on the att~ched COC. Confidential Businca!I Jnformalion: This report is pro~·ided for lhc ~elusive \IJe of the
addre,.seu. PriviJcaes of 5'.tbsequent me of tho nrune cf lhis company or m1y member of iLB stoff, or rej1f0dt,i:.tlon or lhi1 report in connect.ion with lhc Pdvertisemenl, promotion or !Ille of any product or procas, Of in connection wJlh the re~publicntion oflhis report
(nr rnw nllmnRP. nlher lhnn fnr thP. arldrt'CV.P. will ht-. PTHnlM nnlv nn ,rnntn~I Thi 11. ,rnmnrmv Jlf"l'Pnilr~ ,.,<nnndhilitv IP'l."l'Pffl rnr lh.-r-l11P rll'rfnnnnnf'P nf in<inPrtinn nnrUn.,. nnnh1111iv in onnA rnllh <1nr4 .,.,.nrtlino tn II..-n,I,." nr11.P H'flrlP nntl nf'u,i""""'
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-00lB
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8270-S-3546
SVOA TCL List by GC/MS Method 8270D/3546
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Analyzed: 6/25/2018 2019h
Units: µg/kg-dry
Compound
1,1 '-Biphenyl
1,2,4,5-Tetrachlorobenzene
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
Kyle F. Gross 2,6-Dinitrotoluene
Laboratory Director 2-Chloronaphthalene
2-Chlorophenol
Jose Rocha 2-Methylnaphthalene
QA Officer 2-Methylphenol
2-Ni troaniline
2-Nitrophenol
3&4-Methylphenol
3,3 '-Dichlorobenzidine
3-Nitroaniline
4,6-Dinitro-2-methylphenol
4-Bromophenyl phenyl ether
4-Chloro-3-methylphenol
4-Chloroaniline
4-Chlorophenyl phenyl ether
4-Nitroaniline
4-Nitrophenol
Acenaphthene
Acenaphthylene
Acetophenone
Extracted: 6/22/2018 1621h
Dilution Factor: 1
CAS
Number
92-52-4
95-94-3
58-90-2
95-95-4
88-06-2
120-83-2
105-67-9
51-28-5
121-14-2
606-20-2
91-58-7
95-57-8
91-57-6
95-48-7
88-74-4
88-75-5
91-94-1
99-09-2
534-52-1
101-55-3
59-50-7
106-47-8
7005-72-3
100-01-6
100-02-7
83-32-9
208-96-8
98-86-2
Method: SW8270D
Reporting Analytical %TIC
Limit Result Qual QuaUty
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
3,160 <3,160
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
4,710 < 4,710
3,160 < 3,160
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
4,710 < 4,710
3,160 < 3,160
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
Report Date: 7/6/2018 Page 18 of 33
AU 111alyseJ 1pplH:1blc to lhe CWA, SOWA, and RCRA arc performed in acc01dance to NH LAC prolocols. Pertinent HJT1pling infom,ption j5 loca1A::d on lhe oUoched COC. Conlidcnlial Businc:g Jnrann111ion: Thlr-1<1port ii piovidcd for lhe c,._«clu1h11 use or lhe
oddtusc Ptiv[lesc• of aub.!eqncnt a.sc of Ute nilmc of this comptu1y or my membor of ka sralT, or ~p(od\ic1ion or this RpOrt in conn:ction with tho advertisement, promotion or aa1o of any pnxtuot or proc.oss, or in con~ction wilh ihe re..pub11ctiion of lhis Bport
for any pur-po,k other than ror lhc niJdrcn«i \till be grunted only aa coalacl Tb.is company accepls no raparu.ibilit)• c"''P~ Cor Uic duo perfonnance oC im1pection and/or .a.oqlytiJ i.n good failh IIDd ~Ofllin,g. to the rulcaofUlo O'odc and of ,o.lrnce.
Lab Sample ID: 1806483-00lB
Client Sample ID: Winter Park Material Grab
Analyzed: 6/25/2018 2019h Extracted: 6/22/2018 1621h
Units: µg/kg-dry Dilution Factor: 1 Method: SW8270D
CAS Reporting Analytical %TIC
Compound Number Limit Result Qual QueUty
Anthracene 120-12-7 1,600 < 1,600
Atrazine 1912-24-9 1,600 < 1,600
Benz( a )anthracene 56-55-3 1,600 < 1,600
Benzaldehyde 100-52-7 11,800 < 11,800
3440 South 700 West Benzo( a)pyrene 50-32-8 1,600 < 1,600
Salt Lake City, UT 84119 Benzo(b )fluoranthene 205-99-2 1,600 < 1,600
Benzo(g,h,i)perylene 191-24-2 1,600 < 1,600
Benzo(k)fluoranthene 207-08-9 1,600 < 1,600
Phone: [phone] Bis(2-chloroethoxy)methane 111-91-1 1,600 < 1,600
Toll Free: [phone] Bis(2-chloroethyl) ether 111-44-4 1,600 < 1,600
Fax: [phone] Bis(2-chloroisopropyl) ether 108-60-1 1,600 < 1,600
e-mail: [e-mail] Bis(2-ethylhexyl) phthalate 117-81-7 1,600 < 1,600
Butyl benzyl phthalate 85-68~7 1,600 < 1,600
web: www.awal-labs.com Caprolactam 105-60-2 3,770 < 3,770
Carbazole 86-74-8 1,600 < 1,600
Chrysene 218-01-9 1,600 < 1,600
Kyle F. Gross Dibenz( a,h)anthracene 53-70-3 1,600 < 1,600
Laboratory Director Dibenzofuran 132-64-9 1,600 < 1,600
Diethyl phthalnte 84-66-2 1,600 < 1,600
Jose Rocha Dimethyl phthalate 131-11-3 1,600 < 1,600
QA Officer Di-n-butyl phthalate 84-74-2 1,600 < 1,600
Di-n-octyl phthalate 117-84-0 1,600 < 1,600
Fluoranthene 206-44-0 1,600 < 1,600
Fluorene 86-73-7 1,600 < 1,600
Hexachlorobenzene 118-74-1 1,600 < 1,600
Hexachlorobutadiene 87-68-3 1,600 < 1,600
Hexachlorocyclopentadiene 77-47-4 1,600 < 1,600
Hexachloroethane 67-72-1 1,600 < 1,600
Indeno( 1,2,3-cd)pyrene 193-39-5 1,600 < 1,600
Isophorone 78-59-1 1,600 < 1,600
Naphthalene 91-20-3 1,600 < 1,600
Nitro benzene 98-95-3 1,600 < 1,600
N-Nitrosodi-n-propylamine 621-64-7 1,600 < 1,600
N-Nitrosodiphenylamine 86-30-6 1,600 < 1,600
Pentachlorophenol 87-86-5 1,600 < 1,600
Phenanthrene 85-01-8 1,600 < 1,600
Report Date: 7/6/2018 Page 19 of33
All anolyxt GJ]jlll"lllo lo di< CWA, SDWA, and RCRA ""'pcrfom1cd in 4cco,d;an«> 10 NE.LAC ptolb<Ols. P<rti,.ni,,:n,pling infom,otion it locoled 011 lllo Olloch<d COC. Conr.donUal Bwlnm lnlbrm,1101>1 This ropon ir l)IVridcd for lh• CJ<clusll'<' we of lho Gddrosk'C. Privileges of Nb:Jcqvcnt nse of the nllfflO orthi, comp.in)· or 111y mc:wbC'ro(il.1 ,11,a: or n:production of lhi, rcpo,rt.in COLtnectlon whh lhc cd'fcrtlxmcnt. pn,:motlon or uh~ or GIi.)' product or procot. or in ~c,.Uot1 with the rc-pu.blic..ation otlhis report
1 .... -.. , .... -... ..... L. .... , ...... r ... ,1. .......... -.......... .;u '-__ ,_., -"· ...... _ ........... : •..... __ __.. ... _,,_ .. ,. _,.._.-..,.n.11; ... ----r-,.,._ ....... -·'-""'""' ,..,., .. ~i-...... , __ ••• ..;."' n,vvl rl'lhh ,uvl ..... ,.,.,,.rru, ,,, 1h .. n.J .... ,.,ro, .. ~ nnr"I nr.-; .. ft,.,..
3440 South 700 West
Salt Lake City, UT 84119
Lab Sample ID: 1806483-00lB
Client Sample ID: Winter Park Material Grab
Analyzed: 6/25/2018 2019h Extracted: 6/22/2018 1621h
Units: µg/kg-dry Dilution Factor: 1
Compound
Phenol
Pyrene
CAS
Number
108-95-2
129-00-0
Method:
Reporting
Limit
1,600
1,600
Surrogate Units: µg/kg-dry CAS Result Amount Spiked %REC
Surr: 2,4,6-Tribromophenol
Surr: 2-Fluorobiphenyl
Surr: 2-Fluorophenol
Surr: Nitrobenzene-d5
Surr: Phenol-d6
Surr: Terphenyl-dl4
118-79-6
321-60-8
367-12-4
4165-60-0
13127-88-3
1718-51-0
2,490 6,281 39.7
1,240 3,140 39.6
2,380 6,281 37.8
1,190 3,140 37.8
2,760 6,281 43.9
1,260 3,140 40.1
Phone: [phone] Gel-Permeation Chromatography (GPC) Cleanup, method 3640A, utilized for this sample.
ToJl Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
SW8270D
Analytical
Result
< 1,600
< 1,600
Limits
10-237
17-179
10-186
10-166
10-194
10-265
%TIC
Qual Quality
Qual
Report Date: 7/6/2018 Page 20 of33
All an.iy,.. oppll03blo lo U,o CWA, SOWA, 111d RCRA.,..pcrfomrod fn DO<atdonco lO N'lil.AC p,oiocols. Pertin<nt<ort\plio1in[om11tion is locolcd on llrc ,n.ched COC. Confodcntlol BU<lnca, lnforma!lon: Thi, n:portialJ(Ovidcd (wlbcC<Clu,l\'O.,. of lhe
D<ldre<-. Pri•ilcSC< orsulnequonl USC of d,o -o( dds comp:viy O< ony membor of iU , .. rr, or Rp<vducllon or lhiJ ICpotl m oOM«llon will\ lhe advortborn"'~ p,omo~O<I O< •Oi< or Ill)' prodocl o, ptOffl&, 0, a,~ ,.;o, Ibo ro-p,blkllioo or dliaroport
ror "Ill' purpo<o oillor lhon for tho ~-nill bo, 1P1ni.d ooly on oootxl Thb 00<0Plll1)" oc<opls 110 rcspon,lblllty c,o:cpl (or lho duo p<ri'Df1TI411G< or infl'O(llnn ood/or ona\)"11 in aood roilh on<l o<cordio, IO lllo n,!ta o(d>c, ltldo llld o( ,ckt,oo.
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-002B
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8270-S-3546
SVOA TCL List by GC/MS Method 8270D/3546
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Analyzed: 6/25/2018 2041h
Units: µg/kg-dry
Compound
1,1'-Biphenyl
1,2,4,5-Tetrachlorobenzene
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
Kyle F. Gross 2,6-Dinitrotoluene
Laboratory Director 2-Chloronaphthalene
2-Chlorophenol
Jose Rocha 2-Methylnaphthalene
QA Officer 2-Methylphenol
2-Nitroaniline
2-Nitrophenol
3&4-Methylphenol
3,3 '-Dichlorobenzidine
3-Nitroaniline
4,6-Dinitro-2-methylphenol
4-Bromophenyl phenyl ether
4-Chloro-3-methylphenol
4-Chloroaniline
4-Chlorophenyl phenyl ether
4-Nitroaniline
4-Nitrophenol
Acenaphthene
Acenaphthy Jene
Acetophenone
Extracted: 6/22/2018 1621h
Dilution Factor: 1
CAS
Number
92-52-4
95-94-3
58-90-2
95-95-4
88-06-2
120-83-2
105-67-9
51-28-5
121-14-2
606-20-2
91-58-7
95-57-8
91-57-6
95-48-7
88-74-4
88-75-5
91-94-1
99-09-2
534-52-1
101-55-3
59-50-7
106-47-8
7005-72-3
100-01-6
100-02-7
83-32-9
208-96-8
98-86-2
Method: SW8270D
Reporting Analytical %TIC
Limit Result Qual Qualily
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
3,150 < 3,150
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
4,700 <4,700
3,150 <3,150
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
4,700 < 4,700
3,150 < 3,150
1,600 < 1,600
1,600 < 1,600
1,600 < 1,600
Report Date: 7/6/2018 Page21 of33
All onolyses opplicable lo lhe CWA1 SDWA, and RCRA nre perfom1ed in accord:mce to NELAC protocols. Pertinent :,pmpling inforrnuUon is localed on lhe allo.chi:d COC, Confidential BusinessJnl'onnalion: This n,port is provided for lho exclusi,·e use of lhe
addressee. Prl\'ilQges of subsequenl use of du:: ntune of lhis compQny or any member orits 1110Cf, or reproduction o£1his report in ~nncclion wilh lhc ndvertimt1ent, promolion or sale of any prodw:L or procMS, or tn conoec~on wilh lhe re~blit:ation of lhis report rnr ""v nurrvw"' nlhPrihqn rnrth ... nrlA,.,.111="' ,._-ill'-nrnnt .. A nnlu ,.,, ....... 1 ... t Tl,;.,.,.,..,.,.,...,"., .,.,.aY11 .. "" ...,....,,.".,;i..il;,., ----1 """"'"'".I,.,.-..!"-~ .. -.... -t: .... ..._,,,; __ --.11 ...... _ .. 1, ... ; .. :----.1 " .. :,L --.1 ____ .... :--•-1\.. -·•--_s-,1. ............ ..1 .. r ... : ___ _
Lab Sample ID: 1806483-00ZB
Client Sample ID: Winter Park Material Composite
Analyzed: 6/25/2018 2041h Extracted: 6/22/2018 1621h
Units: µg/kg-dry Dilution Factor: I Method: SW8270D
CAS Reporting Analytical %TIC
A merican W est Compound Number Limit Result Qual Qualli,
ANALYTICAL L•&oAATORIES
Anthracene 120-12-7 1,600 < 1,600
Atrazine 1912-24-9 1,600 < 1,600
Benz(a)anthracene 56-55-3 1,600 < 1,600
Benzaldehyde 100-52-7 11,800 < 11,800
3440 South 700 West Benzo( a)pyrene 50-32-8 1,600 < 1,600
SaltLakeCity, UT 84119 Benzo(b )fluoranthene 205-99-2 1,600 < 1,600
Benzo(g,h,i)perylene 191-24-2 1,600 < 1,600
Benzo(k)fluoranthene 207-08-9 1,600 < 1,600
Phone: [phone] B is(2-chloroethoxy )methane 111-91-1 1,600 < 1,600
Toll Free: [phone] Bis(2-chloroethyl) ether 111-44-4 1,600 < 1,600
Fax: [phone] Bis(2-chloroisopropyl) ether 108-60-1 1,600 < 1,600
e-mail: [e-mail] Bis(2-ethylhexyl) phthalate 117-81-7 1,600 < 1,600
Butyl benzyl phthalate 85-68-7 1,600 < 1,600
web: www.awal-labs.com Caprolactam 105-60-2 3,760 < 3,760
Carbazole 86-74-8 1,600 < 1,600
Chrysene 218-01-9 1,600 < 1,600
Kyle F. Gross Dibenz( a,h )anthracene 53-70-3 1,600 < 1,600
Laboratory Director Dibenzofuran 132-64-9 1,600 < 1,600
Diethyl phthalate 84-66-2 1,600 < 1,600
Jose Rocha Dimethyl phthalate 131-11-3 1,600 < 1,600
QA Officer Di-n-butyl phthalate 84-74-2 1,600 < 1,600
Di-n-octyl phthalate 117-84-0 1,600 < 1,600
Fluoranthene 206-44-0 1,600 2,890
Fluorene 86-73-7 1,600 < 1,600
flexachlorobenzene 118-74-1 1,600 < 1,600
flexachloro butadiene 87-68-3 1,600 < 1,600
Hexachlorocyclopentadiene 77-47-4 1,600 < 1,600
flexachloroethane 67-72-1 1,600 < 1,600
Indeno(l ,2,3-cd)pyrene 193-39-5 1,600 < 1,600
Isophorone 78-59-1 1,600 < 1,600
Naphthalene 91-20-3 1,600 < 1,600
Nitro benzene 98-95-3 1,600 < 1,600
N-Nitrosodi-n-propylamine 621-64-7 1,600 < 1,600
N-Nitrosodiphenylamine 86-30-6 1,600 < 1,600
Pentachlorophenol 87-86-5 1,600 < 1,600
Phenanthrene 85-01-8 1,600 < 1,600
Report Date: 7/6/2018 Page 22 of33
AU ••rib'.., >911ll<ablo IO tho CW A. SOW A. ,nd RCRA .,.. 11«foml<d In ~ IO NB LAC prviooo1~ "'11inoou;mplinJ inf"""llion 1• laco~d oo lho allochocl COC. CO<\fldmllal a..incu lnromudon: This rq,on la pioric5ccl A>r dlo .,.,hlll, .. 111< of \ho llddrcsxc. 1'1Mlcg<1orsubfcq!lffll 11SO oflhi:""""' oflhlscomplO.f or ony mcmb<t of k.u11rr. or r<podl,<tion of Ibis R1'0fl In ...,_don wilh 1he1dvortncmc1ll, p<OfflOli.., o, ..i. of II!)' pn,duct o, pn><ffl,O< .,_.,..ll«I with lho "'1"'b!lctaooofllll1 ropon
ror any ouri-Olher·lh., tor lb>~ ,.,u bo c,w,l<dO<llyO<lcon...._ lbls """'l'M!Y IIC«flll no r<q,or,s.olllty o.W<J!C ror lho doc""''"""'"'° or infPCdion oncllo< ... l)'li, Iii F)Od rolth IOd e«ordi"I IO tho 1111 .. orlhc nlo Md°'"''-
3440 South 700 West
Salt Lake City, UT 84119
Lab Sample ID: 1806483-002B
Client Sample ID: Winter Park Material Composite
Analyzed: 6/25/2018 2041h Extracted: 6/22/2018 1621h
Units: µg/kg-dry Dilution Factor: 1
Compound
Phenol
Pyrene
CAS
Number
108-95-2
129-00-0
Method:
Reporting
Limit
1,600
1,600
Surrogate Units: µg/kg-dry CAS Result Amount Spiked %REC
Surr: 2,4,6-Tribromophenol
Surr: 2-Fluorobiphenyl
Surr: 2-Fluorophenol
Surr: Nitrobenzene-d5
Surr: Phenol-d6
Surr: Terphenyl-d14
118-79-6
321-60-8
367-12-4
4165-60-0
13127-88-3
1718-51-0
2,310 6,267 36.9
1,170 3,133 37.4
2,170 6,267 34.6
1,070 3,133 34.3
2,460 6,267 39.2
1,200 3,133 38.4
Phone: [phone] Gel-Permeation Chromatography {GPC) Cleanup, method 3640A, 11ti/izedfor this sample.
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
SW8270D
Analytical
Result
< 1,600
2,530
Limits
10-237
17-179
10-186
10-166
10-194
10-265
%TIC
Qua! Quality
Qual
Report Date: 7/6/2018 Page 23 of33
All .,.,l)...,opplir#c 10d>cCWA, SDWA, 11111 RCI\A Gl'Opcf(om,cd In ~lo !{El.ACpn,locOI<. Pntl~ ..,.pllttsforocm,u.,, l1 lo<•1<d011 thclli«hod COC. ConlldonUol 8 .. h!ffl ln(onnalloft: Thlu q,ottflpro•ldcd fotlho<1«hi11'.,-orlho ~~:!:'!'!.~~!~~U:C~lho...,~~~~.~-~"'!~.'.~°'lts~~.., ~f.111!•~'!'.:=~u.,,_wllltth•~!•n•~. ~~'!' ~1,ot~-~·"'~'!'"'~!""'"!lh ~'!'l"'~kffi,qott i, roport
American West
ANALYTICAL llBOflATORl flf
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
ORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project: Union Pacific Railroad/ Moffat Treatment Residuals Testing
Lab Sample ID: 1806483-00lE
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8270-W-TCLP-3511
TCLP SVOA by GC/MS Method 8270D/1311/3511
Analyzed: 6/27/2018 2000h
Units: mg/L
Compound
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dinitrotoluene
2-Methylphenol
3&4-Methylphenol
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Extracted: 6/27/2018 1137h
Dilution Factor: 1
CAS
Number
95-95-4
88-06-2
121-14-2
95-48-7
118-74-1
87-68-3
67-72-1
TCLP Prep Date: 6/26/2018 2050h
Method: SW8270D
Reporting Analytical %TIC
Limit Result Qual Qu•lity
0.0471 <0.0471
0.0471 <0.0471
0.0471 < 0.0471
0.0471 < 0.0471
0.0471 < 0.0471
0.0471 <0.0471
0.0471 < 0.0471
0.0471 <0.0471
Nitrobenzene
Kyle F. Gross Pentachlorophenol
98-95-3
87-86-5
0.0471 <0.0471
0.0471 <0.0471
Laboratory Director Pyridine
Jose Rocha
QA Officer
110-86-1 0.0471 < 0.0471
Report Date: 7/6/2018 Page 24 of33
/\II 1nalysc, opplicoblc lO ""'CWA, SDWA, and R(!M ""' pc,rormod In 1<eo,donee to Nill.AC pro!O<ols, Pertinent mnplfng inlormo~oa i, locoled 0111ho 111oel\cd COC. Conf1Ck111iol Buiin=lnfonnolxin; Thi, n:port la pro,ld,d fD< !be =lusl\'O us< of tho ~ PritJilcgcs of JUbecqvent use oC&h_a NM11 or chis c:ompM)' or any member orili al40: or rcproduclkm or c.hiJ ropora in oonncclion with lllo advcnisement. promotion or ,a.le or ony prochid. or PR>CC:l$i. or In conncclion ~·llh lhi: ~.1blkodora or Olis rq,ort
ror any purpose odicrlbao for !he odcu.s-will be srant<d ooly an coal1Cl Thi, <0mp"")l oc<cp1S no ,._.ibmty c,m:pl for 11,o 4uo pcrfonn,nr»or ia,p«llon .. dlonaoly,11 io good roit/1111'.d eccording IO lh•NI .. ofiho trod, IUld o(Klcn<o.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Lab Sample ID: 1806483-00 IE
Client Sample ID: Winter Park Material Grab
Analyzed: 6/27/2018 2000h Extracted: 6/27/2018 1137h TCLP Prep Date: 6/26/2018 2050h
Units: mg/L Dilution Factor: 1 Method: SW8270D
Surrogate Units: mg/L CAS Result Amount Spiked %REC Limits Qual
Surr: 2,4,6-Tribromophenol 118-79-6 0.0499 0.04711 106 10-310
Surr: 2-Fluorobiphenyl 321-60-8 0.0262 0.02356 111 10-230
Surr: 2-Fluorophenol 367-12-4 0.0201 0.04711 42.6 10-120
Surr: Nitrobenzene-d5 4165-60-0 0.0262 0.02356 111 10-253
Surr: Phenol-d6 13127-88-3 0.0184 0.04711 39.2 10-110
Surr: Terphenyl-d14 1718-51-0 0.0317 0.02356 135 10-255
Report Date: 7/6/2018 Page 25 of33
All analyse& 11pplicabl11 lo the CWA, SDWA, and RCRA .are perfonued Ill ncc:ordance ro NELAC prol.oco1s, Pertinent sampling inrormotion is locoledoo the atlllched COC, Confidential Business Infonnation: This report irs proviikd for lho excluain use or1he
addmsee, Privileses oCaubaequmt use ofd11: nantc of this compi:m;· or Ins member of its stuff, or reprodu.clion of this mport ll\ conneGtion with I.be advertisement, promotion or sale o! qny product or proces1t or in CQnnection with lite Rl·JJUblicalion of lhis report
fm ADV DUmO&e other lhM ror lhe 11ddressec will be 1mmtcd on1v on tenta.c:t This comDnnv ncccol.s no rc;;tffflfJJibltitv exccnl for lhe due oerfnminncc orimmedion end/nT annlV!lill in l!Ood raith and ncoordina In the rul!!A nfthe 1mde and orl!Cience
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
ORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project:
Lab Sample ID:
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-002E
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h Test Code: 8270-W-TCLP-35 l 1
Analytical Results TCLP SVOA by GC/MS Method 8270D/1311/3511
Analyzed: 6/27/2018 2022h
Units: mg/L
Compound
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dinitrotoluene
2-Methylphenol
3&4-Methylphenol
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Extracted: 6/27/2018 1137h TCLP Prep Date: 6/26/2018 2050h
Dilution Factor: 1 Method: SW8270D
CAS
Number
95-95-4
88-06-2
121-14-2
95-48-7 ·
Reporting
Limit
Analytical
Result
Yo TIC
Qua! Qunllly
Nitrobenzene
Kyle F. Gross Pentachlorophenol
Laboratory Director Pyridine
118-74-1
87-68-3
67-72-1
98-95-3
87-86-5
110-86-1
0.0491
0.0491
0.0491
0.0491
0.0491
0.0491
0.0491
0.0491
0.0491
0.0491
0.0491
< 0.0491
< 0.0491
< 0.0491
<'0.0491
<0.0491
< 0.0491
< 0.0491
< 0.0491
< 0.0491
<0.0491
< 0.0491
Jose Rocha
QA Officer
Report Date: 7/6/2018 Page 26 of33
All analyse, applicable to the CWA, SDW A, and RCRA ore perfonued in occord,nco to NELAC proioCOls. Portinen\ sampling information is localed oa lhe .Uached COC. Coofidcnlial B111ines., fn(o(11)otion: This rtpolt i, provldod for the cxclu.,i, .. u,o of tho
11dd1c:nco. Privileges of subsequent us~ of the nM1e of th)j COfllJJM)' or ony tntnibct otiu staff, or reproduction or thi, rq,ort in con.a cation ,vjlh tho adrfflilfflltttl, promDtton or sale of ID)• J)f'Oduct Ot process, or in oonnccltion "ith &Jio co•publicr1tlon o(lhis report
foe ony l"lrpose other thaa for lho ,ddtos,.. ,,ill be iJUll\cd oaly on eoalA<l Tult «lmpony accepts oo ro,pon,ibnity t><ept ro. tho duo perfotmance o£ia.,poction and/or m,1ly1i, in rood fliUI ond accordins to thollllcs ordlo 1r1tdo IOd or 1eicnoo.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Lab Sample ID: 1806483-002E
Client Sample ID: Winter Park Material Composite
Analyzed: 6/27/2018 2022h Extracted: 6/27/2018 1137h TCLP Prep Date: 6/26/2018 2050h
Units: mg/L Dilution Factor: 1 Method: SW8270D
Surrogate Units: mg/L CAS Result Amount Spiked %REC Limits Qual
Surr: 2,4,6-Tribromophenol 118-79-6 0.0326 0.04907 66.4 10-310
Surr: 2-Fluorobiphenyl 321-60-8 0.0247 0.02453 IOI 10-230
Surr: 2-Fluorophenol 367-12-4 0.0129 0.04907 26.2 10-120
Surr: Nitrobenzene-d5 4165-60-0 0.0251 0.02453 103 10-253
Surr: Phenol-d6 13127-88-3 0.0129 0.04907 26.2 10-110
Surr: Terphenyl-d 14 1718-51-0 0.0261 0.02453 107 10-255
ReportDate: 7/6/2018 Page27of33
All •nofy,o, oppfioobl< 10 ihoCWA, SOW,',, ond !\CR.A .,. p<r{orrooJ in 00<0rd>ncc lo Nl!LAC p<olo«ll<s P«tiocnl sampflng lnronolllion l:o lonl<d oo cl,o 1lloch<d COC. C011Rdondol 811.1ln"" !ntl,m,.llon: Thia «poll ls p!Qvfckd for lho """luol« use of Che ~~~:.~t!~.~!!~~~~:::~~~·~.r.:: !L~~.t'~~r.o::·::r./:12t ~!~~~~~~.~:!. ~~~f~ --~~~.=-~~.::.lb_~ =!=~~~~~.~~:~az~tc~:!::~~1~}:t~~°"~~~~:~?t!~:aoo 11r~iircpon
American W ~st
AN Al YTICAL LA.B0IIAT0Fl1E8
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail; [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
ORGANIC ANALYTICAL REPORT
Client: Union Pacific Railroad Contact: Steve Preston
Project:
Lab Sample ID:
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-00lA
Client Sample ID: Winter Park Material Grab
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h Test Code: 8260-S
Analytical Results VOAs TCL List by GC/MS Method 8260C
Analyzed: 6/23/2018 132h
Units: µg/kg-dry Dilution Factor: 0.99 Method: SW8260C
CAS Reporting Analytical %TIC
Compound Number Limit Result Qual Quollly
1, 1, I-Trichloroethane 71-55-6 9.36 < 9.36
1, 1,2,2-Tetrachloroethane 79-34-5 9.36 < 9.36
1, l ,2-Trichloro-1,2,2-trifluoroethane 76-13-1 9.36 < 9.36
1, 1,2-Trichloroethane 79-00-5 9.36 < 9.36
1, 1-Dichloroethane 75-34-3 9.36 < 9.36
1, 1-Dichloroethene 75-35-4 9.36 < 9.36
1,2,3-Trichloro benzene 87-61-6 9.36 < 9.36
1,2,4-Trichlorobenzene 120082-1 9.36 <9.36
1,2-Dibromo-3-chloropropane 96-12-8 23.4 <23.4
1,2-Dibromoethane 106-93-4 9.36 <9.36
1,2-Dichlorobenzene 95-50-1 9.36 <9.36
1,2-Dichloroethane 107-06-2 9.36 <9.36
1,2-Dichloropropane 78-87-5 9.36 <9.36
1,3-Dichlorobenzene 541-73-1 9.36 <9.36
1,4-Dichlorobenzene 106-46-7 9.36 <9.36
1,4-Dioxane 123-91-1 234 <234
2-Butanone 78-93-3 46.8 <46.8
2-Hexanone 591-78-6 23.4 <23.4
4-Methyl-2-pentanone 108-10-1 23.4 <23.4
Acetone 67-64-1 46.8 <46.8
Benzene 71-43-2 9.36 < 9.36
Bromochloromethane 74-97-5 9.36 <9.36
Bromodichloromethane 75-27-4 9.36 <9.36
Bromoform 75-25-2 9.36 <9.36
Bromomethane 74-83-9 23.4 <23.4
Carbon disulfide 75-15-0 9.36 <9.36
Carbon tetrachloride 56-23-5 9.36 <9.36
Chlorobenzene 108-90-7 9.36 <9.36
Chloroethane 75-00-3 9.36 <9.36
Report Date: 7/6/2018 Page 28 of33
All analyses applicltbl1: lo lhcCWA, SDWA, and RCRA wcperfonned in ,c;i;ordonce lo NRLAC proLocols. Pertinent sampling infonnoLion lJ 1DC41ed on the llttachcd COC. Confidi:ntial Busin~ lnronn1\ion; This rcpon irprovidcd ror lhe ~IUlff'Curootlho
addressee,. Privilege5 of subsequent use of lhci name of thi, comp DO)' Of GQ)' mcmbor or ilB Sllfl', or Rl'producdon o_( lhi, report in connection ,'nlh lh, Ddvertisement, promotiol' or sQ(\} or WI)' producl o., proc~ or in conDtctlon with.lht re:•publlo.arioA or this repmt
for QD)' pul"J)OK other 1h1n for &he oddreasee wjll be gr.nlcd ODly oo coolAOl lhi1 oompany 11cctpb no te1ponstbiUly Q:Cept for lbc due pc:rfortn11nce of inspection 411d/or llllolysi3 iu good rarlh and according 10 \llQ. ndea oflhc uadc mid or Jeiencc.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Lab Sample ID: 1806483-00lA
Client Sample ID: Winter Park Material Grab
Analyzed: 6/23/2018 132h
Units: µg/kg-dry Dilution Factor: 0.99 Method: SW8260C
CAS Reporting Analytical
Compound Number Limit Result
Chloroform 67-66-3 9.36 <9.36
Chloromethane 74-87-3 23.4 <23.4
cis-1,2-Dichloroethene 156-59-2 9.36 <9.36
cis-1,3-Dichloropropene 10061-01-5 9.36 <9.36
Cyclohexane 110-82-7 9.36 <9.36
Dibromochloromethane 124-48-1 9.36 <9.36
Dichlorodifluoromethane 75-71-8 9.36 < 9.36
Ethyl benzene 100-41-4 9.36 <9.36
Isopropylbenzene 98-82-8 9.36 < 9.36
m,p-Xylene 179601-23-1 9.36 < 9.36
Methyl Acetate 79-20-9 23.4 <23.4
Methyl tert-butyl ether 1634-04-4 9.36 < 9.36
Methylcyclohexane 108-87-2 9.36 < 9.36
Methylene chloride 75-09-2 23.4 <23.4
o-Xylene 95-47-6 9.36 < 9.36
Styrene 100-42-5 9.36 < 9.36
Tetrachloroethene 127-18-4 9.36 < 9.36
Toluene 108-88-3 9.36 <9.36
trans-1,2-Dichloroethene 156-60-5 9.36 <9.36
trans-1,3 -Dichloropropene 10061-02-6 9.36 < 9.36
Trichloroethene 79-01-6 9.36 <9.36
Trichlorofluoromethane 75-69-4 9.36 < 9.36
Vinyl chloride 75-01-4 4.68 <4.68
Surrogate Units: µg,'kg-dry CAS Result Amount Spiked %REC Limits
Smr: I ,2-Dichloroethane-d4 17060-07-0 232 234.1 98.9 51-170
Surr: 4-Bromofluorobenzene 460-00-4 261 234.1 112 50-140
Surr: Dibromofluoromethane 1868-53-7 236 234.1 101 50-140
Surr: Toluene-dB 2037-26-5 251 234.1 107 50-140
Internal standard areas were 011tside of the QC limits. Reanalysis of sample yielded similar results indicating matrix interference.
Sampling and analytical preparation performed by method 5030A modified for analysis of soil samples collected in 2 or 4 oz jars.
%TIC
Qual Quolll)'
Quill
Report Date: 7/6/2018 Page 29 of33
All on,lyscs oppllcoblc co lhcCWA, SOWA, ood RCRA .,..pr,fono,d ln acwd•n« ,o Nlil.AC pn>IO<O!s. P«tir,cn1 son1pllns lnrorm,Hon ii locu1<don 11,c llll.ochcd COC. r .. r«i,nU~\ Busines, lnfon11t1ion: Thlrn:poll ilpn,1,ded(ordi, """twi,·•usoof llio
11.ddtt-&$«\. PrhtUcse1 ot'tubttqucnl u1c of (bi:.,, riMlo ur '11\J con1p,nny or ciny mcmbtr of its slQO: Of roprOCIDGtion of \11~ rq,ort In oonnec1ion ,vfth O,ic. odt'Cithtcncat.i pi:orno<ion or ul, or Mr ptOdiKI or proc,tJS. or ln <:Of'lncc1i011 ·whh Iha n:-pub1{C3rl °'" of lhi1 n:porl
fftf ar,v n11~ n,hv thitn kit Ow: cddtu.'ICc will be m111cd anl,· oo conJact. Th.ts c.omoanv 11cccol,!: no ~IblHI\' nc-eot (o, tho duo ocrfonnain« of~ "'1.dfOf 11J1alysls jn aood rlllh and o«ordl~g to tho rule&: oru~ lrOde Doti of science.
3440 South 700 West
Salt Lake City, UT 84 ll 9
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-002A
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date: 6/21/2018 1055h
Analytical Results
Test Code: 8260-S
VOAs TCL List by GC/MS Method 8260C
Analyzed: 6/23/2018 152h
Units: µg/kg-dry
Compound
1, 1, I-Trichloroethane
1, 1,2,2-Tetrachloroethane
1, l ,2-Trichloro-1,2,2-trifluoroethane
1, 1,2-Trichloroethane
1, 1-Dichloroethane
1, 1-Dichloroetbene
1,2,3-Trichlorobenzene
1,2,4-Trichlorobenzene
l,2-Dibromo-3-chloropropane
1,2-Dibromoethane
1,2-Dichlorobenzene
1,2-Dichloroethane
1,2-Dichloropropane
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,4-Dioxane
2-Butanone
2-Hexanone
4-Methyl-2-pentanone
Acetone
Benzene
Bromochloromethane
Bromodichloromethane
Bromofonn
Bromomethane
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
Dilution Factor: 0.99
CAS
Number
71-55-6
79-34-5
76-13-1
79-00-5
75-34-3
75-35-4
87-61-6
120-82-1
96-12-8
106-93-4
95-50-1
107-06-2
78-87-5
541-73-1
106-46-7
123-91-1
78-93-3
591-78-6
108-10-1
67-64-1
71-43-2
74-97-5
75-27-4
75-25-2
74-83-9
75-15-0
56-23-5
108-90-7
75-00-3
Method:
Reporting
Limit
9.33
9.33
9.33
9.33
9.33
9.33
9.33
9.33
23.3
9.33
9.33
9.33
9.33
9.33
9.33
233
46.6
23.3
23.3
46.6
9.33
9.33
9.33
9.33
23.3
9.33
9.33
9.33
9.33
SW8260C
Analytical
Result
< 9.33
< 9.33
< 9.33
< 9.33
< 9.33
< 9.33
< 9.33
<9.33
<23.3
<9.33
<9.33
<9.33
< 9.33
<9.33
<9.33
<233
<46.6
<23.3
<23.3
<46.6
< 9.33
< 9.33
<9.33
<9.33
< 23.3
< 9.33
< 9.33
<9.33
< 9.33
%TIC
Qua! Quality
Report Date: 7/6/2018 Page 30 of 33
All ..,.lpe11ppr.col>lo 101ho CWA, SOWA • ...S RCRA aro pet(Offllcd in occo<d111ce to NllU.C pn,loeols. Pcrlioc,t un1pUns lnfoimofion lslocoi<d on lhc ,11,clicJ COC. conr.dcntitl l!u,in= Jnfomiotlon: This report is pro•lded (or dio oxcluri, .. UJc oflhe
addm.,cc. Pli,lkij.,of-.booqi,c,uu,ooCll!o n,mc ofll,bcomp1111Y oriln)• mcmbtrot111,101T,orn:producllon oflhis ,apon in <0nnmloo wilh \ho od,cni><m•n~ p1omoi(on otsoloof"")' pn,ducto, ptoOCS;, or n conotodoo wllh d" n:-publiotioo o(ll,i, report r« 111l' Pl'l'pQ<• othor lhon fa, !be~ will be grtillkd onb• on COGlkL 'Iltlt •om pony a<upi. no n:,pc,111ibm~· ,xo,p1 fo< d,o du• ll"'f•""'••• ar lcupi,ctlon ,nd/or anoly,i, lo Fed l'ollb ,.d om>Jdl"i to \ho rula1 or lho lrod< and ar ,ci•-
Lab Sample ID: 1806483-002A
Client Sample ID: Winter Park Material Composite
Analyzed: 6/23/2018 152h
Units: µg/kg-dry Dilution Factor: 0.99 Method: SW8260C
CAS Reporting Analytical %TIC
Compound Number Limit Result Qual Quollly
Chloroform 67-66-3 9.33 < 9.33
Chloromethane 74-87-3 23.3 < 23.3
cis-1,2-Dichloroethene 156-59-2 9.33 < 9.33
cis-1,3-Dichloropropene 10061-01-5 9.33 < 9.33
3440 South 700 West Cyclohexane 110-82-7 9.33 < 9.33
Salt Lake City, UT 84119 Dibromochloromethane 124-48-1 9.33 < 9.33
Dichlorodifluoromethane 75-71-8 9.33 < 9.33
Ethyl benzene 100-41-4 9.33 < 9.33
Phone: [phone] lsopropylbenzene 98-82-8 9.33 < 9.33
Toll Free: [phone] m,p-Xylene 179601-23-1 9.33 < 9.33
Fax: [phone] Methyl Acetate 79-20-9 23.3 <23.3
e-mail: [e-mail] Methyl tert-butyl ether 1634-04-4 9.33 <9.33
Metbylcycloh.exane 108-87-2 9.33 < 9.33
web: www.awal-labs.com Methylene chloride 75-09-2 23.3 <23.3
a-Xylene 95-47-6 9.33 < 9.33
Styrene 100-42-5 9.33 <9.33
Kyle F. Gross Tetrachloroethene 127-18-4 9.33 <9.33
Laboratory Director Toluene 108-88-3 9.33 <9.33
trans-1,2-Dichloroethene 156-60-5 9.33 < 9.33
Jose Rocha trans-1,3-Dichloropropene 10061-02-6 9.33 <9.33
QA Officer Trichloroethene 79-01-6 9.33 < 9.33
Trichlorofluoromethane 75-69-4 9.33 < 9.33
Vinyl chloride 75-01-4 4.66 <4.66
Surrogate Units: µg/kg-dry CAS Result Amount Spiked %REC Limits Qual
Surr: 1,2-Dichloroethane-d4 17060-07-0 261 233.1 112 51-170
Surr: 4-Bromofluorobenzene 460-00-4 292 233.1 125 50-140
Surr: Dibromofluoromethane 1868-53-7 250 233.1 107 50-140
Surr: Toluene-dB 2037-26-5 270 233.l 116 50-140
Sampling and analytical preparation performed by method 5030A modified for analysis of soil samples collected in 2 or 4 oz jars.
Report Date: 7/6/2018 Page 31 of 33
All aru,ty,c.1 OPP,lic:iblc to the CWA, SDWA,i1\d RC!lA Are perfofflled in ftCCOfdancc lo NBLAC protocols. Portincnl ,amplin1 infonnaLion is Jocolod on thn attached CDC. Conlid;ntiel Business lnfomutlon; This ropon ls provided (ortheaclwiTeU.st of the
11d~ Priv,tog:es o( subsequent ,\Se of Lho nmn1 o( chis comp111y or any member 0£ its litaff, or reproduction oC lhis re part in connecllon with the advertisemet1l, promoti<Jn or sa1c of Clf1)' product o: ptOC'CI$., or In conne,Uon ,,llh the te•public;etion of this re pore
,. --,_ -----. -'' --•'---,. __ ,._. _.3.3 ____ ••• 1111. ____ ,_.a --•·· -----•--• 'l"L!-----·-· -----•--------~:1..:1: ... -···-• , __ ,L-"··-----"'----·-.. r :..,,... •• ,: .. -__ _., ____ ,,,.,.,: .. : .... --..1 , .. :1l. ...... _ .... J,.t: .... ,.,. 15.. .... ,.~ ... r,a. .. ....,,._ • ..A.,.1-~ ... r,.
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad / Moffat Treatment Residuals Testing
1806483-001D
A rnerican Vi.lest Client Sample ID: Winter Park Material Grab
ANurncAf l..aouToA1Ea Collection Date: 6/20/2018 1400h
3440 South 700 West
Salt Lake City, UT 84119
Phone: {801) 263-8686
Toll Free: [phone]
Fax: {801) 263-8687
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Received Date: 6/21/2018 1055h
Analytical Results
Test Code: 8260-W-TCLP
TCLP VOAs by GC/MS Method 8260C/131 l/5030C
TCLP Prep Date: 6/27/2018 1850h Analyzed: 6/29/2018 858h
Units: mg/L Dilution Factor: 20 Method: SW8260C
Compound
1, 1-Dichloroethene
1,2-Dichloroethane
1,4-Dichlorobenzene
2-Butanone
Benzene
Carbon tetrachloride
Chlorobenzene
Chloroform
Tetrachloroethene
Trichloroethene
Vinyl chloride
CAS
Number
75-35-4
107-06-2
106-46-7
78-93-3
71-43-2
56-23-5
108-90-7
67-66-3
127-18-4
79-01-6
75-01-4
Reporting
Limit
0.0400
0.0400
0.0400
0.200
0.0200
0.0400
0.0400
0.0400
0.0400
0.0400
0.0200
Analytical %TIC
Result Qual Quality
< 0.0400
< 0.0400
< 0.0400
< 0.200
< 0.0200
< 0.0400
< 0.0400
<0.0400
< 0.0400
< 0.0400
< 0.0200
Surrogate Units: mg/L CAS Result Amount Spiked %REC Limits Qual
Surr: l,2-Dichloroethane-d4 17060-07-0 1.10 1.000 110 72-151
Surr: 4-Bromofluorobenzene 460-00-4 I.I I 1.000 11 I 80-152
Surr: Dibromofluoromethane I 868-53-7 1.05 1.000 105 72-135
Surr: Toluene-dB 2037-26-5 1.06 1.000 106 80-124
The pH of the sample was >2. Analysis was performed.within the 7 day holding lime.
Report Date: 7/6/2018 Page 32 of 33
All an1ty .. , applic1blo 10 U,c CWA, SOWA, 11>1 RCRA 01< p<rrormcd In aocordon« 10 NB LAC protoools. Portln<nt umpllns inrorm.tlon is lo<oltd on II,• allachcd COC. Confld<nij•l BUlinco loromwloo: Thi, n:port ii JMOVidcd fo, lbccxctllli1'<> wuf the
ilddn'J...._ Privflqes or subs<quent we of a,c """"' of dtls c:ocnpooy Ot 111'1)' member or iu 11ocr, or rcp,odllctlon or UII, "'])Ort ln oonncc~on "ith tho odvatiscmc:o~ pn,mo~on or sole or OIi)' product or proccs,, or In <OMC<tion whh tho r<·publlootlon of this report
for any pu!)XM other th•n for lho Add,os,ce ,rill be snr,tcd only on conw.t '!111, <0mpony oooepls no rupoiwbmty "'""'Pl ror the duo porfomi1ncc or wpec:1io.n and/or 111.>trsl• io (IOOd r,lth ...i o<<on!lnJ "' the nilc.s al' lhc godo aod or.,,....,.
3440 South 700 West
Salt Lake City, UT 84119
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Client:
Project:
Lab Sample ID:
ORGANIC ANALYTICAL REPORT
Union Pacific Railroad Contact: Steve Preston
Union Pacific Railroad/ Moffat Treatment Residuals Testing
1806483-002D
Client Sample ID: Winter Park Material Composite
Collection Date: 6/20/2018 1400h
Received Date:
Analytical Results
6/21/2018 1055h Test Code: 8260-W-TCLP
TCLP VOAs by GC/MS Method 8260C/1311/5030C
Analyzed: 6/29/2018 956h
Units: mg/L
Compound
l, 1-Dichloroethene
1,2-Dichloroethane
1,4-Dichlorobenzene
2-Butanone
Benzene
Carbon tetrachloride
Chlorobenzene
Chlorofonn
· 1 'etrachloroethene
Trichloroethene
Vinyl chloride
Surrogate Units: mg/L
Surr: l,2-Dichloroethane-d4
Surr: 4-Bromofluorobenzene
Surr: Dibromofluoromethane
Surr: Toluene-d8
Dilution Factor: 20
CAS
Number
75-35-4
107-06-2
106-46-7
78-93-3
71-43-2
56-23-5
108-90-7
67-66-3
127-18-4
79-01-6
75-01-4
TCLP Prep Date:
Method:
Reporting
Limit
0.0400
0.0400
0.0400
0.200
0.0200
0.0400
0.0400
·0.0400
0.0400
0.0400
0.0200
CAS Result Amount Spiked %REC
17060-07-0 1.10 I.ODO 110
460-00-4 1.10 1.000 110
1868-53-7 1.06 1.000 106
2037-26-5 1.06 I.ODO 106
The pH of the sample was >2. Analysis was performed within the 7 day holding time.
6/27/2018 1850h
SW8260C
Analytical
Result Qual
< 0.0400
< 0.0400
<0.0400
< 0.200
<0.0200
<0.0400
< 0.0400
<0.0400
<0.0400
<0.0400
< 0.0200
Limits Qual
72-151
80-152
72-135
80-124
%TIC
Quality
Report Date: 7/6/2018 Page 33 of33
AU omlJ1101 •P1'Hcoblo 10 the, CW/\, SOWA, and RCRA Ct< pcrfom,od in 1<<ordan«> IO Nl!I..AC p<olOCOl~ Portlnw sampfins intorm,~m, i, iocoll:d oa tt .. •tt0<hcd COC. ConM,nll1I Busin ... lnfonnotlon: This rtpo~ , pnwldcd ror d .. ...tuJi•~ 1110 of !ho a~. P,hil"8ti or .sub.ac~CIQI woof u,c ~o or 0,1, C"tfCr1P111)' or q • me1nbc;r of lta JU1fr, or l"t'ptoductlon or tbiJ nrpon In con1)1:(:1lon ,vlth lhc Mvearli!SGfflenl~ p,omotion or !Ille or t.ny pmducl or proceu,. or ln OOl\m:ction. wi\h fho ~-,ublic.it>On or '1:lis report
"•• _.. --.. ly. •• A--1-,(.,. .. ~.a-• . ..;11 L,. _., ..... .,,.1.,. -__ ..,., 'Tl.;.,_ ... _, ofl,.,..,..,p .. t'I --ta,:t: ... ~ ,....,.._,...,..\ r.,_.111,..+i, .. ...,.,Jn.,.,,11,n"" or i"'fl'll!"rllnn .-rlftwMt'll\''llb rn 9IVJd faith ~ &econlin11 l0 tliCI rulCIOr\hti tn:ldC and Oftclent4.
Attachment D.4
Safety Data Sheets
cc 2000
California Aluminum CMmlcals
SAFETY DATA SHEET
OSHA HCS (29 CFR 1910.1200)
. -':-t.(: ;• r~1,•1-! j-1~l~·,,;1n.:~;,, ~-11·1 ,,·ci,;J,',l····,,1,:· I ) 1,'1;J I I( .. 1;;,: 1,· --. ..
,• --· ----·. . -.
Product Identifier
Chemical Name
CASNo.
Trade Name
Product Code
Aluminum Chlorohydrate Solution
12042-91-0
cc 2000
None
Relevant Identified uses of the substance or mixture and uses advised against
Identified Use(s) Water Treatment Chemical
Uses Advised Against None
Company Identification
Telephone
Fax
Emergency telephone number
Emergency Rhone No.
California Aluminum Chemicals LLC
241 Spenker Avenue
Modesto, CA 95354
[phone]
[phone]
CMEMTREC 2-4 hr. (800) 42-4-9300; Not classified as
dangerous for transport.
,::,:,. .. .-(;·)'''·> ··1 ·· ;,,:1·r 1~· 1rJ·, I r•1:,1c ·' ,·,(: 1\11 • . --. . • ' _'. \ ... , .. '.: ~-... ! ~ I I ~ _(. -\ I I • ' -• -• • -• ----
Classification of the substance or mixture
OSHA HCS (29 CFR 1910.1200)
Label elements
Hazard Symbol
Signal word(s)
Hazard Statement(s)
Precautionary Statement(s)
Other hazards
Not classified as dangerous for supply/use.
None
None
None
Avoid contact with skin and eyes.
Wear protective gloves/eye protection.
IF INHALED: Get medical advice/attention if you feel unwell.
IF ON SKIN: Wash with plenty of soap and water. If irritation (redness, rash,
bllsterlng) develops, get medical attention.
IF IN EYES: Rinse cautiously with water for several minutes. Remove
contact lenses, If present and easy to do. Continue rinsing. If Irritation
develops and persists, get medical attention.
IF SWALLOWED: Call a POISON CENTER or doctor/physician if you feel
unwell.
None
; • ; C I J .' .: . , l1', J ·I,°}: I 1 1 · J ·' IJ 11' I I I:'.',,":. ~-1, ) ,· 1.• I,' I· ' I ' ':.I,'' ' '
--
H1%8fdoua tng-redlanf(a) %wt.· :l ,CAS 1No. H~r~,c:Ja-..1fJ_ca_U9n
Aluminum Chlorohydrate 50 12042-91-0 Not classified as dangerous for supply/use.
Water 50 7732-18-5 Not classified as dangerous for supply/use.
Revision: January 20, 2019 Page: 116
C@J_CHEM cc 2000
C.llfornla Alumlnum Charnlcllla
Addltlonal Information -Substances in the product which may present a health or environmental hazard, or which have been assigned
occupational exposure limits, are detailed below: None
· 1--1' I ' l• :)·\I . • . j 1·: I . '-. : I ,-: ' 1-. '. '11 l ' , -. . . -.
• • -• .., ' • I • ''.· -·_ -.. ~!' I ---, .. , ... ' • . •
a
Description of first aid measures
Inhalation
Skin Contact
Eye Contact
Ingestion
Most Important symptoms and effects, both acute and
delayed
Indication of any Immediate medical attention and
special treatment 'needed
Get medical advice/attention if you feel unwell.
Wash affected skin with soap and water. If Irritation (redness, rash,
blistering) develops, get medical attention.
Rinse cauliously with water for several minutes. Remove contact
lenses, If present and easy to do. Continue rinsing. If irritation develops
and persists, get medical attention.
Call a POISON CENTER or doctor/physician if you feel unwell.
None
IF SWALLOWED: Immediately call a POISON CENTER or
doctor/physician.
-·i-•,,·;ji(<-1 ,.-, .; ·11 ~1:..\l;!Tc)~l.::l,'f,."i1if~;.-f \ul~~--:: · ---· -· . .. ·-· . ....:. . ----.
Extinguishing Media
-Suitable Extinguishing Media
-Unsuitable Extinguishing Media
Special hazards arising from the substance or
mixture
Advice for fire-fighters
Non-combustible. As appropriate for surrounding fire.
None anticipated.
Combustion or thermal decomposition will evolve toxic and irritant
vapours.
A self contained breathing apparatus and suitable protective clothing
should be worn In fire conditions. Keep containers cool by spraying
with water If exposed to fire.
-· ·J· •1("1' -.. (< 1j11):"·1-~ u,-'-1-1· ·11 -1 ~ 11· ·,-1,1-• ,. · -. ---· · · • I ' , , I ' • 4 ° \ • : I •) l ~ • o -~' ' \ ) • , ' -( :. \ • , -'\ f • ' 0
'• • ~ • , • I I -•
Personal precautions, protective equipment and
emergency procedures
Environmental precautions
Methods and material for containment and cleaning up
Reference to other sections
Additional Information
Precautions for safe handling
Avoid contact with skin and eyes. Wear protective gloves/eye
protection.
Prevent liquid entering sewers, basements and work pits. Avoid
release to the environment.
Cover spills with inert absorbent material. Transfer to a container for
disposal or recovery.
None
None
Avoid contact with skin and eyes.
Conditions for safe storage, Including any Incompatibilities
Revision: January 20, 2019 Page: 2/6
Calltornla Aluminum Chamlcal•
-Storage temperature
-Incompatible materials
Specific end use(s)
cc 2000
Keep in a cool, well ventilated place. Store at temperatures not
exceeding 50"C / 122 "F. Protect from sunlight.
This product should be stored away from sources of strong heat,
oxidizing chemicals.and reducing agents.
Water Treatment Chemical
~ -j . ' ' ' I· I ,' : I ' -: ( -I 1-, 111 ~ 1: .~; (J l,' ~I: {" l ' -f j; I -, : l (' '; . ': -I . 1. I I ' ,: f' J ,I, • . . . ~ . . .
Occupational Exposure Limits
--
SUBSTANCE. CAS:No.
Aluminum Chlorohydrate, as Al 12042-91-0
-m Total Particulate; CR) Respirable Particulate
Recommended monitoring method
Exposure controls
Appropriate engineering controls
Personal protection equipment
Eye/face protection -Skin protection (Hand protectl6n/ Other)
0
Respiratory protection
8
Thermal hazards
Environmental Exposure Controls
(8,hrJWA) (81'.EL)
PEL TLV P,EL TLV
.(OSHA) (ACGIH) (OSHA) (ACGIH) ..Note:
15 mg/m3 m 1 mg/m3 <R> 5 mg/m3<R> ----
NIOSH 7013 (Aluminum and compounds, as Al)
Not normally required.
Wear protective eyewear (goggles, face shield, or safety glasses).
Wear suitable gloves if prolonged skin contact Is likely. Check with
protective equipment manufacturer's data.
Normally no personal respiratory protection is necessary. In case of
insufficient ventilation, wear suitable respiratory equipment. Check with
protective equipment manufacturer's data.
Not normally required. Use gloves with insulation for thermal protection,
when needed.
Avoid release to the environment.
J:1, ··'I< I,' " ·1:11i:.11,>.1· "~•'l~i' c).i ~l,1,II•/-,, ·:·i 1:1:,: t'I:
. . -
Information on basic physical and chemical properties
Appearance
Color.
Odor
Odor Threshold (ppm)
pH (Value)
Melting Point ('C) / Freezing Point ('C)
Bolling point/boiling range ('C):
Flash Point (°C)
Evaporation Rate
Flammability (solid, gas)
Explosive Limit Ranges
Revision: January 20, 2019
Liquid
Almost colourless to pale yellow
None
Not available
4-5
-5.5 (22 °F)
100 'C (212 °F)
Non-combustible
Similar to water
Not applicable
Non-combustible
Page: 3/6
C@JCHEM cc 2000
Caltrornla Alumlnum CIMmlcal•
Vapor pressure (Pascal)
Vapor Density (Alr=1)
Density (g/ml)
Solubility (Water)
Solubility (Other)
Partition Coefficient (n-OctanoVwaler)
Auto Ignition Point (°C)
Decomposition Temperature (°C)
Kinematic Viscosity (cSI)
Explosive properties
Oxidizing properties
Other information
Reactivity
Chemical stability
Posslbillty of hazardous reactions
Conditions to avoid
Incompatible materials
Hazardous decomposition product(s)
Exposure routes: Inhalation, Skin Contact, Eye Contact
Aluminum Chtorohydrate <CAS No. 12042·91-0):
Acute toxicity
Irritation/ Corroslvlty
Sensitisation
Repeated dose toxicity
Carcinogenicity
~T.P :;
No.
Mutagenlclty
Toxicity for reproduction
Reproductive toxicity
Other Information
IARC
No.
Similar lo water
Similar to water
1.34
Miscible
Not available
Not available
Non-combustible
Not available
Similar lo water
Not explosive
Not oxidising
Not available
Stable under normal conditions.
Stable.
None anticipated.
Incompatible materials.
Substances that react with water or aluminum.
None anticipated.
Oral LOSO= 9187 mg/kg (Rat)
Dermal LOO = >2000 mg/kg (Rat)
Unlikely to cause eye Irritation. Unlikely to cause skin Irritation.
It is not a skin sensitiser.
Not to be expected.
It Is unlikely to present a carcinogenic hazard to man.
No. No. No.
Negative
Negative
Not to be expected
None known.
_,:, · f-1,' .r·: :(d, I.\ ', 11·,:·',. ,.·1 .,·.);1,1,I'·' P(tl,', -
Ecotoxlclty
Short term
Long Term
Persistence and degradability
Bloaccumulative potential
Mobility In soil
Results of PBT and vPvB assessment
Other adverse effects
Revision: January 20, 2019
LC50 (96 hr): 609 mg/I (Fathead minnow)
LC50 (48 hour): 397 mg/L (Daphnia magna)
Not available.
Not readily biodegradable.
The product has no potential for bioaccumulation.
Not available.
Not classified as PBT or vPvB.
Not available.
Page: 4/6
C@J-CHEM cc 2000
Caltrornl• Aluminum CMmlc:ala
Waste treatment methods Disposal should be in accordance with local, state or national
legislation. Consult an accredited waste disposal contractor or the
local authority for advice.
-:1-i ::,,~1:· i':l ~;1·1d 1·1 I . I, I I .I,',.,. •1 I, -
...._ . . .
U.S. DOT
UN number
Sea transport
IIMDGl
Air transport
(ICAO/IATAl
Proper Shipping Name
Transport hazard class(es)
Packing group
Environmental hazards
Special precautions for user
Not classified as dangerous for transport.
Transport in bulk according to Annex II of MARPOL73/78 and the lBC Code: Not applicable
f .-. :J:t~'· lr. J,'. 1.;. ;f,, ,uJ -: • ,: ;: , .. 11;1 , 1:1,1,,·· ·d ,,., · -,. ; ----,. .. -. -_ --' -----' .
Safety, health and environmental regulations/legislation specific for the substance or mixture:
TSCA (Toxic Substance Control Act) -Inventory Status: All components llsted or polymer exempt.
Designated Hazardous Substances and Reportable Quantities (40 CFR 302.4):
Chemical Name CASNo. Typical .%wt.
None
SARA 311/312-Hazard Categories: None
RQ (Pounds)
0 Fire O Sudden Release O Reactivity 0 Immediate (acute) 0 Chronic (delayed)
SARA 313 -Toxic Chemicals (40 CFR 372):
--~ :Che~lcal Nante_" .2.,;,,~-,:.,:cf -·:,,. CAS No.
None
SARA 302 -Eictremely Hazardous Substances (40 GFR 359):
~~~t:i-•.roJ~I.Namf'!f. c_ :.._:--c~s No. Typical %wt.: . __ " 'i.Jf!Q (~oUnds) · -,d
None
California Proposition 65 List:
Chemical Name -cASNo.
None
: 1-, ' 't · I·' . -: '' "' I ,-I•.' 1-I I 1,· . .. , I'
The following sections contain revisions or new statements: 1-16.
Date of preparation: April 27, 2015
Hazard Statement(s) and Risk Phrases Listed In: SECTION 2:/ SECTION 3:
Hazard Statement(s)
-None.
Training advice: None.
Revision: January 20, 2019
Type of ,:oxlclty
Page: 5/6
@CHEM cc 2000
Callfomla Alumlnum ChamlCIII•
Disclaimer: We believe the statements, technical information and recommendations contained herein are reliable, but they are
given without warranty or guarantee of any kind. The information contained in this document applies to this specific material as
supplied. It may not be valid for this material if it is used in combination with any other materials. It Is the user's responsibility to
satisfy oneself as to the suitability and completeness of this information for the user's own particular use.
Revision: January 20, 2019 Page: 6/6
SAFETY DATA SHEET
Issue date 20 September 2016
seventti::·
generation.
FMOOOOOl-00.3, FMOOOOOl--01.5, FMOOOOOl--02.S, FMOOOOOl--03.3
This product Is packaged for retail sale and intended for consumer use. The U.S. OSHA Hazard Communication Standard {29 CFR 1910.1200) does not apply to
"consumer products" as defined by the U.S. Consumer Product Safety Act and Federal Hazardous Substances Act, Including consumer products used In the
workplace under typical duration and frequency of exposure as experienced by consumers when used for the Intended purpose. This Safety Data Sheet {SOS) Is
provided as a courtesy to assist with proper use and safe handling. Applicable consumer product use and safety Information Is provided on the product label and is
included for easy reference In Section 16 of this SOS. This SOS Is designed to cover both U.S. and Canada. Differences between U.S. and Canadian requirements are
noted where applicable.
Product Name
Synonyms
Product Use
Restrictions on Use
Manufacturer Name
Address
Emergency Telephone Number
Monday -Friday 8 am -5 pm ET (except holidays)
Outside these hours
Classification
U.S.
Canada
Ha.zard Category
Eye Damage/Irritation
'Signal Word
WARNING
Hazard Statement(s)
Causes eye Irritation
None r~ ... .._ .... ,
Dish Liquid, Dish Liquid Refill
Natural Dish Liquid, Natural Dish Liquid Refill
Hand DlshwashlnR
Follow directions on the product label
Seventh Generation, tnc.
60 Lake Street, Burlington, VT 05401, USA
U.S., <:anada
l-800-2U-4279
1-800-255-3924 (ChemTel)
This product Is considered hazardous under the 2012 OSHA Hazard Communication Standard {29 CFR
1910.1200).
This product is considered hazardous under the WHMIS 2015.
Category 2B
Precautionary Statement(s) -General -Consumer Products
If medical advice is needed, have product container or label at hand.
Keep out of reach of children.
Read label before use.
Precautionary Statement(s) -Prevention
Wash hands thoroughly after handling.
Page 1 of 6
SAFETY DATA SHEET
•"\ seventn··
generation ..
Precautionary Statement(s) • Response
If In eyes: Rinse cautiously with water for several minutes. Remove contact lenses, If present and easy to do. Continue rinsing.
If eye Irritation persists: Get medical advice/attention.
Precautionary Statement(s) • Storage
None
Precautionary Statement(s) -Disposal
None
Hazards not otherwise identified
None known
Percent Ingredients with unknown acute toxicity
0% of the product consists of ingredients of unknown acute oral toxicity. Refer to Section 3.
Regardless of hazard classification, Seventh Generation discloses all intentionally added Ingredients and, If applicable incidental ingredients :!1% on the consumer
product label.
Ingredient Function CASNumber Concentratlon1 LDS02
aqua (water) diluent 7732-18-5 30%-100% Not applicable
sodium lauryl sulfate cleaning agent 151-21-3 10%-30% 1288 mg/kg
glycerin foam stabilizer 56-81-5 1%-3% >12600 mg/kg
lauramlne oxide deaning agent 70592-80-2 1%-3% >2000 mg/kg
caprylyl/myrlstyl glucoslde deaning agent 68515-73-1 & S1% >2000mg/kg 110615-47-9
magnesium chloride viscosity modifier 7786-30-3/7791-18-6 S1% >2000 mg/kg
citric acid pH adjuster 77-92-9 S1% 3000 mg/kg
essential oils & botanical extracts• fragrance mixture S1% >2000 mg/kg
benzisothlazollnone preservative 2634-33-5 S1% 1020 mg/kg
methyllsothlazolinone preservative 2682-20-4 S1% >100 mg/kg
• Free & Clec1r: not applicable.
•Lavender Flower & Mint: cananga odorata (ylang ylang) flower oil, citrus aurantlfolla (lime) oll, citrus aurantium dulcls (orange) oil, lavandula hybrlda (lavandln) oil,
mentha plperlta (peppermint) oil, mentha vi rid is (spearmint) leaf oil. d-llmonene Is a component of these essential oils.
*Clementine Zest & Lemongrass: canarlum luzonlcum (elemll gum nonvolatlles, citrus aurantlum bergamia (bergamot) fruit oil, citrus aurantium dulcis (orange) oil,
citrus nobilis (mandarin orange) peel oil, cymbopogon schoenanthus (lemongrass) oll, tangelo oll. d-Limonene Is a component of these essentlal oils.
•Fresh Citrus & Ginger: canarium luzonlcum (eleml) gum nonvolatiles, cedrol, clnnamomum zeylanicum (cinnamon) bark extract, citrus aurantlfolia (lime) oil, citrus
aurantlum amara (bitter orange) oil, citrus aurantium bergamia (bergamot) fruit oil, citrus aurantlum dulcis (orange) oil, citrus llmon (lemon) peel oil, corlandrum
sativum (coriander) fruit oil, elettaria cardamomum (cardamon) seed oll, eugenla caryophyllus (clove) leaf oil, myristlca fragrans (nutmeg) kernel oil, pelargonlum
graveolens (geranium) flower oll, zlnglber offlclnale (ginger) root oil. d-Limonene is a component of these essential oils.
•Lavender Flower & Lime: cananga odorata (ylang ylang) flower oil, citrus aurantlfolla (llme) all, citrus aurantlum dulcls (orange) oll, lavandula hybrida (lavandin) oll,
mentha plperita (peppermint) all, mentha vlrldis (spearmint) leaf oil. d-Limonene Is a component of these essential oils.
1 Where ranges are shown, the exact concentration has been withheld as a trade secret.
2 LOSO Acute oral toxicity (rat) -This is a value provided by the raw material supplier or scientific literature. It Is not a value generated by Seventh Generation by
testing using rats. Seventh Generation uses alternative, non-animal based methods and scientific literature to determine the safety classification of our products
and their Ingredients.
f~~r ·,,Tfi':~:.,<~...._ :-~~---~~-:-, -.-. -.---.--. -. -.-.,-. ::ll •~r--~i ~-'.l ~·'.l.'=.J __ ,.ll!tun:tJ.J!!!.:.~~-L--~' -. ··-~-~s~__:_..,.,_ -, ------· -·-·-"---~--=--Y..-___ .....,_ _. _____ _.f
Page 2 of 6
SAFETY DATA SHEET seventrr·
generation
Eye Contact Flush eyes with water Immediately after contact. Call a physician if irritation develops or persists.
Skin Contact Rinse thoroughly with water if skin contact occurs. Call a physician if irritation develops or persists.
Ingestion Drink 4-8 ounces of water or milk immediately. If prolonged nausea or pain occurs call a doctor.
Inhalation No need for first a id Is expected.
Notes to Physician Treat symptomatically.
Most Important symptoms and effects Acute exposure may result in eye irritation.
0
Suitable Extinguishing Media As appropriate for surrounding fire. Use water, dry chemical, carbon dioxide or foam.
Unsuitable Extinguishing Media Not available.
Specific Hazards arising from the chemical mixture Not available.
Hazardous Combustion Products Not available.
Protective Equipment and Precautions for Firefighters Fire fighters should wear full protective clothing and self contained breathing apparatus as for
surrounding fire.
Personal Precautions
Industrial Setting Wear appropriate personal protective equipment (refer to Section 8).
Environmental Precautions Avoid entry into lakes, streams, ponds or public waterways.
Methods for Containment and Cleaning Up
Household Setting Small spills and leaks may be cleaned up and disposed of in normal household trash or diluted and
disposed of via sewer.
Before attempting clean up, refer to hazard data given. Material may be slippery lf spilled and wet.
Industrial Setting Prevent spill from entering a waterway. Stop spill at source and contain material. Dispose liquid in
accordance with all applicable local, state, and federal regulations. Small amounts may be flushed to
sewer.
Safe Handling
Household Setting Use as directed on product label.
Industrial Setting Wear appropriate personal protective equipment (refer to section 8).
KEEP OUT OF REACH OF CHILDREN AND PETS.
Safe Storage Store in original container and keep container closed when not in use.
Avoid freezing.
Storage Incompatibilities None known.
Exposure Limits None known.
Engineering Controls Not applicable.
Personal Protective Equipment (PPE)
Household Setting No special precautions necessary as long as product Is used as directed.
Industrial Setting
Respiratory Protection None required under normal conditions. General ventilation required.
Eye Protection Goggles or other protective eye wear may be worn for protection.
Skin Protection Gloves may be worn for protection.
Hygiene Measures Handle in accordance with good industrial hygiene and safety practice.
Page 3 of 6
SAFETY DATA SHEET
Physical State
Color
Clarlty
Odor
Odor Threshold
pH
Meltlng Point
Freezing Point
lnltlal Bolling Point and Bolling Range
Flash Point
Evaporation Rate
Upper Exploslve limit (UEL)
Lower Explosive Limit (LEL)
Vapor Pressure (mmHg)
Specific Gravity (H20 = 1)
Relative Density
Vapor Density (Air = 1)
Solubllity In Water
Partition Coefficient: n-octanol/water
Viscosity
voe (weight%)
Reactivity
Chemical Stablllty
Posslblllty of Hazardous Reactions
Conditions to Avoid
Incompatible Materials
Household Setting
Industrial Setting
Hazardous Decomposition Products
Potential Route(s) of Exposure
Effects of Acute Exposure
Oral Toxicity
Dermal Toxicity
Inhalation Toxicity
Eye Contact
Skin Contact
Component Information
Effects of Chronic Exposure
Sensitization
Carcinogenicity
NTP
IARC
Liquid.
light amber
Clear
seventh:: generation .
Unfragranced: Characteristic of the ingredients. Fragranced: Characteristic of the ingredients.
Not available.
7.9-8.1
Not available.
Not available.
Not available.
Not available. Aqueous Solution.
Not available.
Not applicable.
Not applicable.
Not available.
l.01-1.04
Not available.
Not available.
Miscible
Notavallable.
Not available.
Not avallable.
None known.
Stable.
None known.
None known.
In general, cleaning products should not be mixed with other household chemicals, unless specifically
provided for in the use directions.
None known.
None known.
Eyes. Skin. Ingestion.
LOSO >5000 mg/kg, calculated based on ingredients.
Not available.
Not available.
MIid Irritant, based on in-vitro data.
Non-Irritant, based on Human Repeat Insult Patch Test (HRIPT).
Refer to section 3 for ingredient LOSO (acute oral).
Not expected to have chronic health effects.
Does not Indicate a potential for allergic contact sensitization, based on Human Repeat Insult Patch Test
(HRIPT).
Not expected to have chronic health effects.
No Ingredients Listed
No Ingredients Listed
Page4of6
SAFETY DATA SHEET
OSHA
Reproductive Effects
Teratogenlcity
Mutagen lefty
Target Organ Effects
rttloo:0.2: Ecolo Jcalilbformatlon
Ecotoxiclty
Persistence and Degradablllty
13loaccumulative Potential
Moblllty In Soil
Environmental Fate
Product Waste
Household Setting
Industrial Setting
Callfo~nia Hazardous Waste Code
Connecticut Hazardous Waste Code
Michigan Liquid Waste Code
Washington Hazardous Waste Code
Empty Packaging
U.S. DOT
U.S. States
Waste
Canadian TOG (Surface Transport)
IMDG (Marine Transport)
IATA (Air Transport)
U.S.
Toxic Substances Control Act (TSCA)
California Prop 65
California Air Resources Board (CARB)
No Ingredients listed
Not expected to have chronic health effects.
Not expected to have chronic health effects.
Not expected to have chronic health effects.
Not expected to have chronic health effects.
Not available.
This product Is biodegradable, based on OECD 301B.
Not applicable.
Not available.
No adverse effects expected.
seventti::-
generat1on .
Any disposal must be in compliance with applicable local, state, provincial and federal Jaws and
regulations.
Product residues In the bottle may be discarded in trash, or dlluted with water and disposed via sewer.
When used as directed, the product i~ septic-safe.
When disposed as waste In Its original form, this product Is not considered hazardous waste under
Federal regulations, however regulations may vary by state or province and may designate it as
hazardous waste. Check with your local waste and waste water authorities. We are aware of the
following state waste classifications:
561
CT04
029L
WT02
Offer empty container for recycling. If recycling I Is not available, discard In trash.
Not regulated.
See U.S. DOT for finished product classiflcation for transport.
Regulated in some states If the product is disposed of in Its original form as waste by commercial
users/handlers. Refer to Section 13. for applicable state waste codes.
Not regulated.
Not regulated.
Not regulated,
This product complies with the Inventory requirements of the U.S. Toxic Substances Control Act (TSCA).
This product is not subject to the labeling requirements of California's Proposition 65.
Not applicable.
Page 5 of 6
SAFETY DATA SHEET
Canada
Domestic Substances List (DSL)
Right to Know
Other
seventtf:
generation
This product complies with the inventory requirements under Canada's Domestic Substances List (OSL} or
Non-Domestic Substances List (NDSL) or is otherwise in compliance with the New Substances Notification
NSN) reaulations or exemptions.
Regardle.ss of hatard classification, Seventh Generation discloses all Intentionally added ingredienb and,
If applicable Incidental ingredients ;;:1% on the product label. Please refer to Section 3. of this SDS for
in11redlent llstina.
Fragrances used In this product comply with applicable lnternatlonal Fragrance Association (IFRA)
auldance.
Hazardous Materials Identification System (HMIS) Rating
Legend: 4-Severe, 3-Serious, 2-Moderate, l·Slight, 0-Minimal
National Fire Protection Association (NFPA) Rating
Consumer Product Label Information
HOW TO USE
Dispense into sink or directly onto sponge. Wash dishes and rinse thoroughly. NOT FOR USE IN AUTOMATIC DISHWASHERS.
KEEP OUT OF REACH Of CHILDREN. If product gets into eyes, flush thoroughly with water. If swallowed, drink plenty of water,
Prepared by Seventh Generation Inc.
Issuing Date 20 September 2016
Revision Date 20 September 2016
Revision Note Revised Sections 2., 3., 9., 12. and 16.
Please note: This product Is manufactured and marketed for consumer use and should be used as directed on the product label for the Intended purpose. Seventh
Generation warrants that this product conforms to our standard specification when released to the market and when used according to directions. To the best of
our knowledge, the information contained herein Is accurate. However, we do not assume any liability whatsoever for the accuracy or completeness of the
Information contained herein. Final determination of the suitability of any product Is the sole responsibility of the user. All products may present unknown hazards
and should be used with requisite caution. Although certain hazards are described herein, we cannot guarantee that these are the only hazards that exist.
Other abbreviations used In this document:
DOT -(U.S.) Department ofTransportation
EPA-(U.S.) Environmental Protection Agency
IARC-lnternatlonal Agency for Research on Cancer
NTP -(U.S. Department of Health and Human Services) National Toxicology Program
OSHA -(U.S.) Occupational Safety and Health Administration
TDG -(Canadian) Transport of Dangerous Goods
WHMIS-(Canadian) Workplace Hazardous Materials Information System
End of Safety Data Sheet
Page 6 of6
Cl•BASF
We create chemistry
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
1. Identification
Product identifier used on the label
Zetag® 120L
Recommended use of the chemical and restriction on use
Recommended use*: Drilling fluid additive
Page: 1/9
(30710124/SDS GEN_US/EN)
~ The "Recommended use" identified for this product Is provided solely to comply with a Federal requirement and is not part of
the seller's published specification. The terms of this Safety Data Sheet (SOS) do not create or infer any warranty, express or
implied, Including by incorporation into or reference in the. seller's sales agreement.
Details of the supplier of the safety data sheet
Company:
BASF CORPORATION
100 Park Avenue
Florham Park, NJ 07932, USA
Telephone: [phone]
Emergency telephone number
CHEMTREC: 1-800-424-9300
BASF HOTLINE: [phone]-HELP (4357)
Other means of identification
Chemical family: polyacrylamide, anionic dispersed in: light mineral oil
2. Hazards Identification
According to Regulation 2012 OSHA Hazard Communication Standard; 29 CFR Part 1910.1200
Classification of the product
Skin Corr./lrrit.
Eye Dam./lrrit.
Label elements
Pictogram:
2
28
Skin corrosion/irritation
Serious eye damage/eye irritation
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
Signal Word:
Warning
Hazard Statement:
H320
H315
Causes eye irritation.
Causes skin irritation.
Precautionary Statements (Prevention):
P280 Wear protective gloves.
Page: 2/9
(30710124/SDS GEN US/EN)
P264 Wash with plenty of water and soap thoroughly after handling.
Precautionary Statements (Response):
P305 + P351 + P338 IF IN EYES: Rinse cautiously with water for several minutes. Remove
P303 + P352
P332 + P313
P337 + P311
P362 + P364
contact lenses, if present and easy to do. Continue rinsing.
IF ON SKIN (or hair): Wash with plenty of soap and water.
If skin irritation occurs: Get medical advice/attention.
If eye irritation persists: Call a POISON CENTER or doctor/physician.
Take off contaminated clothing and wash it before reuse.
Hazards not otherwise classified
If applicable information is provided in this section on other hazards which do not result in
classification but which may contribute to the overall hazards of the substance or mixture.
3. Composition / Information on Ingredients
According to Regulation 2012 OSHA Hazard Communication Standard; 29 CFR Part 1910.1200
CAS Number
64742-52-5
64742-47-8
68551-13-3
4. First-Aid Measures
Weight%
20.0 -< 50.0%
10.0-15.0%
1.0-5.0%
Description of first aid measures
General advice:
Chemical name
Distillates (petroleum), hydrotreated heavy naphthenic
Distillates, petroleum
Alcohols, C12-15, ethoxylated propoxylated
Immediately remove contaminated clothing.
If inhaled:
Keep patient calm, remove to fresh air, seek medical attention.
If on skin:
Wash affected areas thoroughly with soap and water. Seek medical attention.
If in eyes:
Immediately wash affected eyes for at least 15 minutes under running water with eyelids held open,
consult an eye specialist.
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
If swallowed:
Page: 3/9
(30710124/SDS GEN US/EN)
Immediately rinse mouth and then drink plenty of water, do not induce vomiting, seek medical
attention. Never induce vomiting or give anything by mouth if the victim is unconscious or having
convulsions.
Most important symptoms and effects, both acute and delayed
Symptoms: The most important known symptoms and effects are described in the labelling (see
section 2) and/or in section 11., Further symptoms and / or effects are not known so far
Hazards: No hazard is expected under intended use and appropriate handling.
Indication of any immediate medical attention and special treatment needed
Note to physician
Treatment: Treat according to symptoms (decontamination, vital functions), no
known specific antidote.
5. Fire-Fighting Measures
Extinguishing media
Suitable extinguishing media:
dry powder, foam, water spray
Unsuitable extinguishing media for safety reasons:
water jet
Additional information:
If water is used, restrict pedestrian and vehicular traffic in areas where slip hazard may exist.
Special hazards arising from the substance or mixture
Hazards during fire-fighting:
harmful vapours, nitrous gases, carbon oxides
Evolution of fumes/fog. The substances/groups of substances mentioned can be released in case of
fire. Spilled product is slippery underfoot. Very slippery when wet.
Advice for fire-fighters
Protective equipment for fire-fighting:
Wear a self-contained breathing apparatus.
Further information:
The degree of risk is governed by the burning substance and the fire conditions. Contaminated
extinguishing water must be disposed of in accordance with official regulations.
6. Accidental release measures
Personal precautions, protective equipment and emergency procedures
Use personal protective clothing. Keep people away and stay on the upwind side.
Environmental precautions
Do not discharge into drains/surface waters/groundwater.
Methods and material for containment and cleaning up
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
Page: 4/9
(30710124/SDS GEN US/EN)
Spills should be contained, solidified, and placed in suitable containers for disposal.
7. Handling and Storage
Precautions for safe handling
Keep away from sources of ignition -No smoking.
Protection against fire and explosion:
Take precautionary measures against static discharges.
Conditions for safe storage, including any incompatibilities
Further information on storage conditions: Freezing will affect the physical condition but will not
damage the materials. Thaw and mix before use Store in unopened original containers in a cool and
dry place. Avoid wet, damp or humid conditions, temperature extremes and ignition sources.
Protect from temperatures below: 0 °C
Protect from temperatures above: 40 °C
8. Exposure Controls/Personal Protection
Components with occupational exposure limits
Distillates, petroleum
Distillates (petroleum},
hyd retreated heavy
naphthenic
. ACGIH TLV TWA value 200 mg/m3 Non-aerosol (total
hydrocarbon vapor};
Application restricted to conditions in which there
are negligible aerosol exposures.
Skin Designation Non-aerosol (total
hydrocarbon vapor};
The substance can be absorbed through the skin.
OSHA PEL PEL 5 mg/m3 Mist ; PEL 500 ppm 2,000
mg/m3 ; TWA value 5 mg/m3 Mist ;
ACGIH TLV TWA value 5 mg/m3 lnhalable fraction ; ;
Exposure by all routes should be carefully
controlled to levels as low as possible.
' Included in the regulation, but with no data values
-See the regulation for further details
Personal protective equipment
Respiratory protection:
Wear a NIOSH-certified (or equivalent} organic vapour/particulate respirator.
Hand protection:
Chemical resistant protective gloves
Eye protection:
Tightly fitting safety goggles (chemical goggles} and face shield.
Body protection:
Impermeable protective clothing
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
Page: 5/9
(30710124/SDS GEN US/EN)
General safety and hygiene measures:
Handle in accordance with good industrial hygiene and safety practice. No eating, drinking, smoking
or tobacco use at the place of work.
9. Physical and Chemical Properties
Form:
Odour:
Odour threshold:
Colour:
pH value:
Melting point:
Boiling point:
Sublimation point:
Flash point:
Flammability:
Lower explosion limit:
Upper explosion limit:
Autoignition:
Vapour pressure:
Density:
Relative density:
Vapour density:
Partitioning coefficient n-
octanol/water (log Pow):
Self-ignition
temperature:
Thermal decomposition:
Viscosity, dynamic:
Solubility in water:
Solubility (quantitative):
Solubility (qualitative):
Evaporation rate:
Other Information:
10. Stability and Reactivity
Reactivity
liquid
mineral oil-like
No data available.
off-white
3.9-4.4
( 1 %(m), 25 cc)
not determined
> 100 cc
No data available.
> 93 °C
not highly flammable
For liquids not relevant for
classification and labelling. The lower
explosion point may be 5 -15 °C
below the flash point.
For liquids not relevant for
classification and labelling.
not determined
The product has not been tested.
The product has not been tested.
approx. 1.1 g/cm3
( 20 °C)
No data available.
No data available.
Study scientifically not justified.
not self-igniting
No decomposition if stored and handled as
prescribed/indicated.
not determined
dispersible
No data available.
No data available.
Value can be approximated from
Henry's Law Constant or vapor
pressure.
if necessary, information on other physical and chemical
parameters is indicated in this section.
No hazardous reactions if stored and handled as prescribed/indicated.
Corrosion to metals:
No corrosive effect on metal.
Oxidizing properties:
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
not fire-propagating
Chemical stability
The product is stable if stored and handled as prescribed/indicated.
Possibility of hazardous reactions
Page: 6/9
(30710124/SDS GEN US/EN)
No hazardous reactions when stored and handled according to instructions.
The product is chemically stable.
Conditions to avoid
Avoid extreme temperatures. Avoid freezing. Avoid all sources of ignition: heat, sparks, open flame.
Incompatible materials
reactive chemicals
Hazardous decomposition products
Decomposition products:
Hazardous decomposition products: No hazardous decomposition products if stored and handled as
prescribed/indicated.
Ttwrrr1i:il decqmpQs_it_ion:
No decomposition if stored and handled as prescribed/indicated.
11. Toxicological information
Primary routes of exposure
Routes of entry for solids and liquids are ingestion and inhalation, but may include eye or skin
contact. Routes of entry for gases include inhalation and eye contact. Skin contact may be a route
of entry for liquefied gases.
Acute Toxicity/Effects
Acute toxicity
Assessment of acute toxicity: Virtually nontoxic after a single ingestion.
Oral
Type of value: LD50
Species: rat
Value: > 2,000 mg/kg
Irritation / corrosion
Assessment of irritating effects: Irritating to eyes and skin.
Skin
Species: rabbit
Result: Irritant.
Eye
Species: rabbit
Result: Irritant.
Sensitization
Assessment of sensitization: Based on the ingredients, there is no suspicion of a skin-sensitizing
potential.
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
Aspiration Hazard
No aspiration hazard expected.
Chronic Toxicity/Effects
Repeated dose toxicity
Page: 7/9
(30710124/SDS GEN US/EN)
Assessment of repeated dose toxicity: Based on our experience and the information available, no
adverse health effects are expected if handled as recommended with suitable precautions for
designated uses. The product has not been tested. The statement has been derived from the
properties of the individual components.
Genetic toxicity
Assessment of mutagenicity: Based on the ingredients, there is no suspicion of a mutagenic effect.
Carcinogenicity
Assessment of carcinogenicity: The whole of the information assessable provides no indication of a
carcinogenic effect.
Reproductive toxicity
Assessment of reproduction toxicity: Not expected to cause reproductive toxicity (based on
composition).
Teratogenicity
Assessment of teratogenicity: No teratogenic effects reported.
Other Information
The product has not been tested. The statement has been derived from substances/products of a
similar structure or composition.
Symptoms of Exposure
The most important known symptoms and effects are described in the labelling (see section 2)
and/or in section 11., Further symptoms and/ or effects are not known so far
12. Ecological Information
Toxicity
Toxicity to fish
LC50 > 100 mg/I, Fish
Persistence and degradability
Assessment biodegradation and elimihatlon (H20)
The polymer component of the product is poorly biodegradable.
Bioaccumulative potential
Assessment bioaccumulation potential
Based on its structural properties, the polymer is not biologically available. Accumulation in
organisms is not to be expected.
Mobility In soil
Assessment transport between environmental compartments
No data available.
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
lnfonnation on: Anionic polyacrylamide
Adsorption to solid soil phase is expected.
Additional Information
Other ecotoxicological advice:
Page: 8/9
(30710124/SDS GEN US/EN)
The product has not been tested. The statements on ecotoxicology have been derived from products
of a similar structure and composition.
13. Disposal considerations
Waste disposal of substance:
Dispose of in accordance with national, state and local regulations. It is the waste generator's
responsibility to determine if a particular waste is hazardous under RCRA.
Container disposal:
Dispose of in a licensed facility. Recommend crushing, puncturing or other means to prevent
unauthorized use of used containers.
14. Transport Information
Land transport
USDOT
Sea transport
IMDG
Air transport
IATA/ICAO
Not classified as a dangerous good under transport regulations
Not classified as a dangerous good under transport regulations
Not classified as a dangerous good under transport regulations
15. Regulatory Information
Federal Regulations
Registration status:
Chemical TSCA, US released / listed
EPCRA 311/312 (Hazard categories): Refer to SOS section 2 for GHS hazard classes applicable
for this product.
State regulations
State RTK
NJ
PA
CAS Number
64742-47-8
64742-47-8
Chemical name
Distillates, petroleum
Distillates, petroleum
Safety Data Sheet
Zetag® 120L
Revision date : 2018/08/30
Version: 4.0
Page: 9/9
(30710124/SDS GEN US/EN)
64742-52-5 Distillates (petroleum), hydrotreated heavy naphthenic
Safe Drinking Water & Toxic Enforcement Act, CA Prop. 65:
WARNING: This product can expose you to chemicals including ACRYLAMIDE, which is known to
the State of California to cause cancer and birth defects or other reproductive harm. For more
information, go to www.P65Warnings.ca.gov.
NFPA Hazard codes:
Health: 2 Fire: 1 Reactivity: 0 Special:
HMIS Ill rating
Health: 2 Flammability: 1
16. Other Information
SOS Prepared by:
BASF NA Product Regulations
SDS Prepared on: 2018/08/30
Physical hazard: 0
We support worldwide Responsible Care® initiatives. We value the health and safety of our
employees, customers, suppliers and neighbors, and the protection of the environment. Our
commitment to Responsible Care is integral to conducting our business and operating our facilities in
a safe and environmentally responsible fashion, supporting our customers and suppliers in ensuring
the safe and environmentally sound handling of our products, and minimizing the impact of our
operations on society and the environment during production, storage, transport, use and disposal of
our products.
Zetag® 120L is a registered trademark of BASF Corporation or BASF SE
IMPORTANT: WHILE THE DESCRIPTIONS, DESIGNS, DATA AND INFORMATION CONTAINED
HEREIN ARE PRESENTED IN GOOD FAITH AND BELIEVED TO BE ACCURATE, IT IS
PROVIDED FOR YOUR GUIDANCE ONLY. BECAUSE MANY FACTORS MAY AFFECT
PROCESSING OR APPLICATION/USE, WE RECOMMEND THAT YOU MAKE TESTS TO
DETERMINE THE SUITABILITY OF A PRODUCT FOR YOUR PARTICULAR PURPOSE PRIOR
TO USE. NO WARRANTIES OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING
WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, ARE
MADE REGARDING PRODUCTS DESCRIBED OR DESIGNS, DATA OR INFORMATION SET
FORTH, OR THAT THE PRODUCTS, DESIGNS, DATA OR INFORMATION MAY BE USED
WITHOUT INFRINGING THE INTELLECTUAL PROPERTY RIGHTS OF OTHERS. IN NO CASE
SHALL THE DESCRIPTIONS, INFORMATION, DATA OR DESIGNS PROVIDED BE CONSIDERED
A PART OF OUR TERMS AND CONDITIONS OF SALE. FURTHER, YOU EXPRESSLY
UNDERSTAND AND AGREE THAT THE DESCRIPTIONS, DESIGNS, DATA, AND INFORMATION
FURNISHED BY OUR COMPANY HEREUNDER ARE GIVEN GRATIS AND WE ASSUME NO
OBLIGATION OR LIABILITY F.OR THE DESCRIPTION, DESIGNS, DATA AND INFORMATION
GIVEN OR RESULTS OBTAINED, ALL SUCH BEING GIVEN AND ACCEPTED AT YOUR RISK.
END OF DATA SHEET
ATTACHMENT 3
EFRI/UDEQ Protocol for Determining Whether Alternate Feed Materials Are
RCRA Listed Hazardous Waste
Oi:Mi£ R. Oown~
~r•.:.111r
St~1te ()f Ltal1
D L i1 A RT\~ i.: :-,., T o:: =S\' :RO\.'.'.-~ L , .. ~ .. '\:_ C): 'A:.:~ ~-
[)[V:.-:; :o:-,: Uf SOLil) A:'\D f-i.),,l.-\R.l>OI . .'.~ WAS:-c
211H l.;01ti~ 1460 Wc~l r O Ch1,c I 448KCI
Salt lnke Cit)·. Utah 84 l 14~&1!0
(~I) S3&-51 ?0
(1101) ill•6715 F~
(IOI) 516-4414 TD 0.
WW\" tll!,\,JWlt:.UL115 Web
D~cember 7 1 l 999
M. Li11dsay Ford
Parsons, Behle and Latimer
One Utah Center
201 Soutb Main Street
Suite 1800
Post Office Box 45898
Salt Lake City, Utah 84145-0898
RE: Protocol for Determining Whether Alternate Feed Materials are Listed Hazardous
Wastes
Dear Mr. Ford:
On November 22, 1999, we received the final protocol to be used by International Uranium
Corporation (IUSA) in determining whether alternate feed materials proposed for processing at
the White Me$11 Mill are listed haz.ardous wastes. We. appreciate the effort that went into
preparing this procedure and feel that it will be a useful guide for IUSA in its alternate feed
detenninations.
As was discussed. please be advised that it is IUSA's responsibility to ensure that the alternate
feed materials used are not listt:d hazardous wastes and that the use ofthi:1 protocol cannot be
1.&Sed as a defense if listed haz.ardous waste is somehow processed at the White Mesa Mill.
Thank you again for your corporation. If you have any question11, please contact Don VerbH::a .-:.t
538-6170.
Sincerely,
-~' "'-v (~ .. • ;lj.r .,,..1,,r""-"
ruus R. Do , ~ecutivc Secretary
Utah Solid and Hazardous Waste Control Board
c: Bill Sinclair, Utah Division of Radiation Control
f . lSHW\ffWDIDVDIICA\Wl'\whilcmo,,,,. 1Ypd
(jnC' \ •1.ail r.:..:,nu
!~ 1 3u•!t."1 ~(sin Sir~ft
:;u,ic 1900
1•0~: Office &iot ~fdH
Siu t.aile c,iy. t.:,:ih
4~\.;S..(•8?N
r~:ophn~• 101 sn.:214
r,,,..11,mile: 901 Sl6-61 \I
Don Verbica
r-Par-;ons
Behle & , I Latimer ~ ~ ~
~ 1•,orcss;oM~
l.~W CIJRPU~4TI~~
November 22, 1999
Utah Divisioo of Solid & Hazardous Waste
288 North 1460 West
Salt Lake City, Utah
Dear Don:
Re: Protocol for Determining Whether Alternate Feed Materials are
Listed Hazudom Wastes
I am pleased to present the final protocol to be used by [nternational Uranium
(USA) Corporation (0 nJSA'') in determining whether alternate feed materials propQSed for
processing at the White Mesa Mill are listed hazardous wastes. AJso attached is a red-lined
ven;ioo of the protocol reflecting final changes a1ade to the document based on our last
discussion with you as well as some minor editorial changes from our final read-through of
the document Wo appreciate the thoughtful input of you and Scott Anderson in
developing this protocol. We understand the Division concurs that materials determined
not to be listed wastes pursuant to this protocol are not listed hazardous wastes.
We also recognize the protocol does not address the situation where, after a material
has been determined not to be a listed hazardous waste under the protocol, new umefutable
information comes to light that indicates the material is a listed hazardous waste. Should
such. an eventuality arise, we understand an appropriate response. if any, would need to be
Worked OUt OD a casewby-case basis.
)03101.1
:Jon Vc:-:,ii:a
CLah Divtsion of Solid & ffa2ardm1s \Vaste
'.\"ovember 22, 1999
Page Two
Thank you again for your cooperation on this matter. Please call me if you have
a11y questions.
cc: (with copy of final protocol only)
Dianne Nielson
Fred Nelson
Brent Bradford
Don Ostler
Loren Morton
Bill Sinclair
David Frydenlund
David Bird
Tony Thompson
]0310?.t
Very truly yours,
Parsons Behle & Latimer ~~
M. Lindsay Ford
Protocol for Determining if ..AJternate feed Material is a Listed_ Hazardous Vvaste
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• SI • Ei.p"onc:Jfa1 -.hi no! r~rec:1
• SAP~fr qip!c:cb~
• Confumalioo,'Acc•pl=e
~l~ Results fl opplco-
blel
VE.S
NO
fl
Cvllduct Ong<:)rlQ
Conlkmofion ond
Accep~nce
Sompli,g end use 1'8$11• ~ reeva)uote
1\'tietier Moferf::,:S
Ole listed hazardous
wastes.
~slisled
HmacJt/S W:>sles
flQ"l'I ol",;1 t.t:Jlef,'.l'l I HN
PROTOCOi. FOR DETER.l\iU~I:"'G WHETHER
AL tER..'lA'fE FEED :VlATERIALS ARE L(STED HAZARDOUS WASTES'
NOVEMBER 16, 1999
1. SOURCE INVES1'[GAT10N.
Perfonn a good faith investigation (a "Source Investigation" or "Sl")2 regarding whether
any listed hazardous wastes3 are located at the site from which alternate feed materiai'
("Material .. ) originates (the •·sitt,"). This investigation will be conducted in coafonnance
with EPA guidance' and the extent of information required will vary with the
circumstances of each case. Following are examples of investigations that would be
considered satisfactory under EPA guidance and this Protocol for some selected
situations:
• Where the Material is or has been generated from a known process under the
control of the generator: (a) an affidavit, certificate, profile record or similar
document from the Generator or Site Manager, to that effect, together with (b)
a. Material Safety Data Sheet ("MSDS'j for tho Material. limited profile
sampling, or a material composition determined by the generator/operator
based on a process material balance.
1 This Protocol reflects the procedures that will be followed by International Uranium (USA)
Corporation ("[USA'') for detcnnining whether alternate Cccd materials proposed for procesaing at the
White Mesa Mill are (or contain) listed hazardous ~stcs. It is based on current Utah and EPA rules and
:EPA guidance under the Resource Conservation and Recovery Act ("R.CRA .. ), 42 U.S.C. §§ 6901 et seq.
This Protocol will be changed as necessary to reflect any pertinent changes to R.CRA rules or EPA
guidance.
2 This investigation will be performed by tuSA, by the entity responsible for the site from which the
Material origmates (the "Oeoarator"), or by a ~ombination of the two.
3 Attachment l to this Protocol provides a sununary of the diffcn:nt classifications of RC.RA lmed
hazardous wutea.
4 Alternate feed materials that an primary or intermediate products of the generator of the material le. g ..
"'green." or "blaok" salta) me not R.CRA '"secondary materials" or .. solid wastes:• as defined in 40 CF R.
261, and are not ~vercd by chis Protocol.
S EPA guidance identifies the following sources of ai~-1111d WL1tc-specific infonnation that may,
dopendintr on the circumstances. be considered in such an inYcatigation: ha1..ardous waste manifests,
vouch'-'fl, bills of ladina. 11•les and inventory n:corda, material safety data sheets, ston1e records,
samplina and analysis, repora. accident reports, 11itc investigation rei:iorts, interviews Wlth
c.mployees/(ormar employees and former owners/operators, spill reports, inspection reports and ,ogs.
permits, and enforcement orders. See e.g .. 61 fed. Rea. J 8805 (April 29, L996).
143176.1
PttOTOC.:Ol H)k 0E1'EIOll:'\l/lir; WHETHF.R ~L.T£R,'\'.,,TE 1"£.£0 ~1.-\Tf:I\ULS AR£ LrsTtD H,\lARIJl,)L'S WASTES
• Where specific infonuation exists about the generation process ;md
management of the Material: (a) an affidavit, certificate, profile record or
similar document from rhc Generator or Site Manager, to that effect, together
with. (b) an MSDS for the Matcmal, limited profile sampling data or a
preexisting investigation perfom1ed at the Site pursuant to CERCLA. RCRA
or other state or federal environmental laws or programs.
• Where potentially listed processes are known to have been conducted at a Site,
an investigation considering the following sources of infonnation: site
inv~tigalion reports prepared under CERCLA, RCRA or other state or federal
environmental laws or programs (e.g .. an RI/FS, ROD, RFI/CMS, hazardous
waste inspection report); interviews with pcrsoas possessing knowledge about
the Material and/or Site; and review of p11blicly available documents
concerning process activities or the history of waste generation and
management at the Site.
• If material from the same source is being or has lk9en. accepted for direct
disposal as l lc.(2) byproduct material in an NRC•rcgu..lated facility in the
State of Utah with the consent or acquiescence of the State of Utah, the Source
Investigation performed by such facility.
Proceed lo Step 2.
2. SPECIFIC INFORMA 110N OR AGREEMENT/DETERMINATION BY
RCRA REGULATORY AUTHORITY THAT MATERIAL IS MQI A
LISTED HAZARDOUS WASTE?
a. Determine whether specific information from the Source Invcstigatioo exists about the
generation and management of the Material to support a conclusion that the Material is
not {and docs not contain) any listed hazardous waste. For example, if specific
information exists that the Material was not generated by a listed waste $OUl'Ce and that
the Material has not been mixed with any listed wastes, the Material would not be a listed
hazardous waste.
b. Alternatively, determine whether the appropriate state or federal authority with RCRA
jurisdiction over the Site agrees in writing with the generator's determination that tbe
Material is not a listed hazardous waste, has made a '·contained-out'' detcnnination' w1th
respect to the Material or has concluded the Material or Site is not subject to llCRA.
6 EPA explains the "conta.ined--OUt" (also referred to as "contained-in") prineiplc M follows:
[n practice, EPA hal •pplicd the containcd·•n principle to rof'cr to a process whore a site.
specific dctcrmi.rtation is made that concentrations of hazardous constituents in any given
(footnote continued on next page)
20176 I 2
PROTO( 01. FOK DHER~u~·•~G Wll[Tll£R AL t'ER."l.ni Fr.r.o ,\.L\ Tf.RIALS AA£ LISTED HALARDOlS \V ,\!) n:s
lfyes to E!ither que.stio,i, proceed to Step J.
lf 110 to botlt questions. proceed to Step 6.
3. PROVIDE INFORMATION TO l'll'RC AND CTAH.
a. lf specific information exists to support a conclusion that the Material is not, and docs
not contain, any listed hazardous waste, IUSA will provide a description of the: Source
Investigation to !'ffi.C and/or the State of Utah Department of Environmental Quality,
Division of Solid and Hazardous Waste (the "State"), together with an affidavit
explaining why the Material is not a listed hua.rdous waste.
b. Alternatively, if the appropriate r~gulatory authority with RCRAjurisdiction over the
Site agrees in writing with the generator's determination that the Material is not a listed
hazardous was~ makes a contained'"°ut detmninatioa. or determines the Material or Site
is not subject to RCRA, [USA will provide documentation of the regulatory authority's
determination to NRC and the State. IUSA may rely on such determination provided
that the State a.grees the conclusions of the regulatory authority were reasonable and made
in good faith.
Proceed to Step 4.
4. DOES STATE OF tn'AB AGREE THAT ALL PREVIOUS STEPS HAVE
BEEN PERFORMED IN ACCORDANCE WITH THIS PROTOCOL?
Determine whether the State agrees that this Protocol has been properly followed
(including that proper decisions were made at each decision point). The State shall
review the infonnation provided by 1USA in Step 3 or 16 with reasonable speed and
advise IUSA if it believos IUSA has not properly followed this Protocol in detennining
(footnote continued Jiom previous page)
volume of environmental media are low enough to dctcnninc that the media do~ not
"contain" hazardoua wuto. TypicaUy, these so-4:alled ucontained-in" [or .. contained·
out"] dcu:nninauona do not mean that no hlzardoU$ constitu.ents are present in
environmental media but sunply that the concentrations of hazardous constituents
presant do noc warrant mamgemcnt of th~ m~dia u hazardous waat.c. . ..
EPA has not, to date, issued dcfmitivc guidance to establish the conoentrations at which
contained-in detammations may be made. As noted above, decisions that media do not
or no longer coacain hazardous waste are typically made on :i case-by-case basis
comidcring the risks posed by the contaminated media.
63 Fed. Ileg. 28619, 21621-22 (May 26, 1998) (Phase IV LOR. pnamble).
243176.1 3
PROTOCOi. FUR Dt:·rrn.",\l.'i[:'.'oG WUl:'.Tll£K AL n:R."iA I£ fl::1::1) ::Vt.4.T£1U.4.U A.KE LIS1'£U HALAKOOl.S W 4..:i I l!>
that the Material is not listed hazardous waste, specifying the particular al.'eas ot
deficiency.
If this Protocol bas not been properly followed by IUSA in ruaking its detcnnination that
the Material is not a listed hazardous waste, then lUSA shalt redo its analysis in
accordance with this Protocol and, if justified, resubmit the information described in Step
3 or 16 explaining wby the Material is not a listed hazardous waste. The State shall
notify lUSA with reasonable speed if the Slate still believes this Protocol has not been
followed.
If yes. proceed to Step J.
lfno, proceed to Step 1.
5. MATERIAL IS MQ'.[ A LISTED HAZARDOUS WASTE.
The Material is not a listed hazardous waste and l10 further sampling or evaluatton is
necessary in the following circumstances:
• Where the Material is determined not to be a listed hazardous wme
based on specific information about the generation/management of the
Material QB. the appropriate RCRA regulatory authority with
jurisdiction over the Site agrees with the generator's determination that
the Material is not a listed HW, makes a contained~out determination.
or concludes the Material or Site is not subject to RCRA (and the State
agrees the c::onclusions of the regulatory authority were reasonable and
made in good faith) (Step 2); or
• Where the Material is detcmnncd not to be a listed hazardous waste (in
Steps 6 through ll, 13 or 15) and Confumation/Acceptance Sampling
arc dc:tcnnined not to be necessary (under Step 17).
6. IS MATERIAL A PROCESS WASTE ~~OWN TO BE A LISTED
HAZARDOUS WASTE OR TO BE MIXED WITH A LISTED
HAZARDOUS WASTE?
24J87CI.I
Based on the Source l.nvestigation, determine whether the Material is a process waste
known to be a listed baurdous waste or co be mixed with a listed hazardous waste. If the
Mat.erial is a process waste and is from a listed hazardous waste source, it is a liste.d
hazardous waste. Similarly, if the Material is a process waste and has been mixed with a
listed hazardous waste, it is a listed hazardous waste wider the RCRA .. mixture rule." ff
4
PA.UTOC.OL FOK DETER~tl:'il:"iG WHETHER AL T[R..'\ATE J:'££0 M,, rtR.l,\l~S ,\RF. Lr~Tf:D HAT.AROQLS W"sn:s
the ~aLerial is an Environmental Medium/ it cannot be a listed hazardous waste by direc:
listing or under the RCRA "mjxturc rule."~ [f the Material is a process waste bul is not
knoWtl to be from a listed source or to be mixed with a listed waste, or if the Material is
an Environmental Medi~ proceed to Steps 7 through ll to dctenninc whether it is a
listed hazardous waste.
q yes, proceed to Step 12.
If no, proceed ta Step 7.
7. DOES MATERIAL CONTAIN ANY POTENTIALLY LISTED
HAZARDOUS CONSTITUENTS?
Based on the Source Investigation (and. if applicable, Confirmation and Acceptance
Sampling), determine·whcther the Material contains any hazardous constituents listed in
the then most recent version of 40 CFR 261, Appendix VII (which identifies hazardous
constituents for which F-and K-listed wastes were listed) or 40 CFR 261.JJ(e) or (f) (the
P and U listed wastes) (collectively "Potentially Listed Hazardous Constituents"). lf the
Material contains such comtituents, a source evaluation is ncccssary (pursuant to Steps 8
through 11). It the Material docs n<11 contain any Potentially liated Hazardous
Constituents, it is not a listed huardous : waste. The Ma:crial also is not a listed
hazardous waste i( where applicable, Confirmation and Acceptance Sampling results do
not reveal the presence of any "new" Potentially Listed Hazardous Constituents (i.e .•
constituents other than those that have already been identified by the Source Investigation
(or previous Con.finnati.on/Acceptance Sampling) and detennincd oot to originate from a
listed soua;e).
If yes, proceed to Step 8.
If no, proceed lo Step J 6.
8. IDENTIFY POTENTIALLY LISTED WASTES.
Identify potentially listed hazardous wastes ("Potentially Listed Wastes'') based on
Potentially Listed Hazardous Constituents detected in the Material, i.e., wastes which are
listed for any of the PotentiaJly Listed Hazardous Constituents detected in the Matenal, as
7 The tcnn "Environmental Media" means sods, ground or surface water and sedimentll.
8 The "mixture rule" applies only to mixtures of listed hazardous wastes and other "solid wastes." Se1tt
40 CFR. § 26 t .J(a)(l)(iv). The mixture rule docs, not apply ro mixtwcR or lisrcd wastes and
Environmental Media. beca.use E.nvirODJDental Media are not ''solid wastes .. under R.CRA. See 63 fed.
Reg. 28556, 28621 (May 261 1998).
14317G.I 5
PROTQCOl, FOR l>tTF.I\Ml:\ t:-.C \'v' IU!Tll£k AL T£R.",\ TE HtO :\1,, Tr.RIAL.!,, Aiu; LIS'l'A1.l.t HAZ"RJ)O(..S W,,s H.'i
identified in the then most current version of 40 CFR 261 Appendix VU or 40 CFR
261.JJ(c) or (t)." With respect to Potentially Listed Hazardous Constituents identified
through Confirmation and/oc Acceptance Sampling, a source evaluation (pursuanL to
Steps 8 through l l) is uccessary only for "new" Potentially Listed Hazardous
Constituents (i.e., constituents other than those that have already been identified by the
Source investigation (or previous Confirmation/Acceptance Sampling) and determined
not to originate from a listed source).
Procud to Step 9.
9. WERE ANY OF THE POTENTIALLY LISTED WASTES KNOWN TO BE
GENERATED OR. MANAGED AT SITE?
Based on information .from the Source rnvestigation. determine whether any of the
Potentially Listed Wastes identified in Step 8 are known to have been generated or
managed at the Site. lbis dctcm1ination involves identifying whether any of the spccl.fic
or non-specific sources identified in the K-or F-lists has ever bc:cn conducted or located
at the Site, whether any waste from such processes has been. managed at the Site, aud
whether any of tho P-or U-listed commercial chemical pioducts has ever been used,
spilled or managed there. In particular, this determination should be based on the
following EPA criteria:
Solvept Lisdna (FQ01-F00S)
Under EPA guidance. "to detennine if solvent constituents contaminating a waste
are RCRA spcnt solvent FOOl-FOOS wastes, the [site manager] mu.st know if:
• The solvents are sper,t and cannot be rewed witlwrll reclamation or
cleaning.
• The solvent& were used e.rcliui.vely for their ~olvent properties.
• The solvents are spent mixtures and blends that contained, before use,
a total of JO percent or more (by volume) of the sol\lents listed in
FOOi, F002, F004, and FOOS.
lf the solvents contained in the [wastes] are RCRA listed wastes, the
(wastes) are RCRA hazardous waste. When the [site manager) does not
have guidance infonuation oo the use of the solvents and their
cbaracteristics before use. the [wastes] cannot be classified as containing a
9 For example, if the Material contains tetrachloroethylcme, the following would be Potentially Listed
Wutcs: FOOl, F002, F024, K019. K020, K150, Kl5l or U210. See 40 CFI. 261 App. VII.
l4ll97fl I 6
PROT0(.'01.. Fl)R DF.TF.R:\11'.'1\:-.c·; \.\'H f;THEH ALTl:'.:R.'iATT. rr.F.O M,\Tr.Rl1'LS ARE Ll~TED HAJ'.AROOl S \V.\.~Tf:S
listed spent solvent." ie The person perfonning the Source l.avcstigation
will make a good faith effort to obtain infom1ation on any solvent use at
the Site. If solvents were used at the Site. general industry standards for
solvent use in effect at the time of use wdl be considered in dctenuining
whether those solvents contained 10 percent or more of the solvents listed
in FOO l, F002, F004 or FOOS.
K-Llsted Wastes and F-Llsted Wastes Other Than F001-F005
Under EPA guidance, to detmni.ne whether K wastes and F wastes other than
FOOl-FOOS arc RCRA listed wastes, the gcnentor "must know the generatio"
process infonnation (about each waste contained .in the RCRA waste) described in
the listing. For example, for [wastes] to be identified as containing KOOl wastes
that are described as •bottom sediment sludge from the treatment of wastewaters
from wood preserving processes that use crt.asote and/or pentachlorophenot.· the
[site manager] must know th~ manufacturing process that generated the wastes
(treatment of wastcwaters from wood preserving process), fecdstocb used in the
process (t:reosote and pentacbJorophenol). and tho process identification of the
wastes (bottom sediment sludge).''11
P~ and U-Llsted Wastes
EPA guida11ce provides that "P and U wastes cover only unused and unmixed
commercial chemical products, particulady spilled or off-spec products. Not
every waste co.ataining a P or U chemical is a hazardous waste. To determine
whether a [waste] contains a P or U waste, the [site: manager} must have dirccr
evidence of product use. In particular, the [site manager] should ascertain, if
possible, whether the chemicals are:
+ Discarded (as dcacribcd in 40 CFR 261.2(a)(2)).
• .Either off-spec commercial products or a commercially sold grade.
• Not used (soil contaminated with spilled unused wastes is a P or U
waste).
10 Management of Investigation-Derived Wastes During Site Inspections, EPA/S40/G•9t/009, May 199 l
(emphasis added).
11 Management of Investigation-Derived Wastes During Site Inspections, EPA/S40/0-9 l/009, May 1991
(emphasis added).
7
l'ROTOCOL H)t( D£T£RM1Sl!1iG WH£1'11£K Al.TER~A TF r,·r r:n MATF:RIALS ARE LISTED HAZAJlUOl !> W .\S n:s
• The sole active ingredient in a fonnulation.":2
If Potentially Listed Wastes were known to be generated or managed at the Site, further
evaluation is necessary to detennine whether these wastes were disposed of or
commingled with the Material (Steps 10 and possibly 11). If Potentially Listed Wastes
were not known to be generat"d or managed at tbe Site, then infonnation concerning the
soUJ"ce of Potentially Listed Hazardous Constituents in the Material wiJl be considered
"unavailable or inconclusive" and, wider EPA guidance;1 the Material will be assumed
not to be a listed hazardous waste.
12 Management of Investigation-Derived Wastes During Site laspections, EPA/S40/Gn9l/009, May
1991.
ll EPA guidance consistently provides that, where infoJmAtion c.onceming the origin ot a waste is
unavailable or inconclwsive, the waste may be usumcd not to be a listed hazardous waste. See e.g.,
Memorandum from Timo~ Fields (Acting Assistant Administrator for Solid Waste & Emergency
Response) to RCRNCERCLA Senior Policy Managers regudina ~anagcmeut of Remediation Waste
Under RCRA." datc:d October l4, 1998 ('-where a facility ownC"rlopcmtor mabs a good faith effort to
determine if a material is a listed hazardous waste but cannot make such a determination because
docwncntation regarding a som-ce of contamination, r.ontaminant, or waste is U1U1Vatlable or
inconclusiv~, EPA has stated that one may assume the source, contaroioant, or wash: is not hsted
baz.ardous waste"); NCP Preamble. S5 Fed. R.cg. 8758 (Much 8, 1990) (Noting that ''it is often
necessary to know the oriain of the waste to determine whether it is a listed waste and that, if such
docu1ner,1ation iJ lacking, the lead agtJncy may as~ume Jt ;, "°' a listed wa.ste): Preamble to proposed
Hazardous Waste Identification llule, 61 Fed. Reg. 18805 (April 29, 1996) ("Facility owner/operators
should make a good faith eft'ort to determine whether media were contaminated by hazardous wastes md
ascertain the dates of placement. The Agency believes that by usins avadablc sitew and waste-specific
infonnation ... facility owncrloperatom would typically be able to make these determinations. However,
as discussed earlier in tha preamble of today's proposal, if information is not availabltt or inconclusive.
facility owurloperaton ...., g~Mrally as.rum~ that the material contaminating IM ,,,~dia were not
hazardou.r W41'tn."); Preamble to LOR. Phase IV Rulo. 63 Fed. R.ea. 28619 (May 26, 1998) (" /\s
discussed iA the April 29, 1996 proposal, the Agency continues to believe I.bar, if illformatlon is nor
avaiJab/s or ilra,ncltaiw. it u p,rera.lly r-etUonable 10 a.riUJM thal contaminated .foils do not c:ontam
untreated leazardou, W4Sta ••• "); and Memorandu1n t'rom John H. Skinner {Director. EPA Office of
Solid Waste) to David Wagoner (Director, EPA Air and Waste Management Division, Region VlO
regarding "Soils fiom Missouri Di0x1n S1tcs," dated January 61 1984 ("The aiwyses indicate the
prcsenee of a. number of toxic, compow,ds in many of the soil sample& taken from various 51tes .
However, the presence of these toxicanta in the soil docs oot automatically make the soil a RCRA
hazardous waste. The oriain o(lhe tox.icants mu.~t be known in order to determine that they arc denved
from a listed hazardous wane(s). If tl1e u.act origin of th, lo~nts ii not known, the soils cannot bt
(footnote continued on next page)
20176.1 8
PROTOC"Ot fOR t>tTEHM1M~C Wm:nu:R ALH:ll.'i.lo.rt fEF.D M..\TtRlALS AR.£ L1sn::o H..u.AKDOL!i W~T~
If yes, proceed to Step JO.
[f,,o, proceed to Step 16.
10. WERE LISTED WASTES KNOWN TO BE DISPOSED OF OR
COM.'\DNGLED WITS MATERIAL?
If listed wastes identified in Step 9 were lmown to be generated at the Site. determine
whether they wen, known to be disposed of or commingled with the Material?
if yes, proceed to Step 12.
If no, proceed lO S~p J J.
11. ARE THERE ONE OR MORE POTENTIAL NON-LISTED SOURCES OF
LISTED HAZARDOUS WASTE CONSTITUENTS?
In a sicuaci.on where Potentially Listed Wastes were known to have been
generated/managed at the Site, but the wastes were not known to have been disposed. of
or commiDgled with the Material. detonnine whether there are potential non~listed
sources of Potentially Listed Hazardous Coostituontl in the Material. If not, unless the
State agrees otherwi.s~ the constituents will be assumed to bo from listed solU'Ces
(proceed to Step 12). If so, the Material will be assumed not to be a listed hazardous
waste (proceed to Step 16). Notwithstanding the existence of potential non .. listed sources
at a Site, the Potentially Listed Hazardous Constituents in the Material will be comidered
to be from the listed source(s) i( based on the relative proximity of the Material to the
listed and non-listed sourcc(s) and/or information. concerning waste managemeat at the
Site, the evidence is compelling that the listed source(s) is the source of Potentially Listed
Hazardous Constituents in the Material.
If yes. proceed to Step 16.
If no. proceed to Step 12.
12. MATERIAL IS A LISTED IUZARDOCS WASTE.
The Material is a listed hazardous waste under the following circumstances;
(foomote continued from prcviOIIS page)
considered RCRA. hazardo.u wv,tes unless they exhibit one ·or more of the characteristics of huardou~
") WIL"ile ..• •
24)176.1 9
• [f the Material is a process wa.llte and is known to be a listed hazardous
waste or to be mixed with a listed hazardous waste (Step 6),
• rr Potentially Listed Wastes were known to be generated/managed at
the Site and to be disposed ofi'commiugled with the Material (Step LO)
(subject to a .. contained-out" determination in Step 13), or
• If Potentially Listed Wastes were known to be generated/managed at
the Site, were not known to be disposed of!commingled with the
Material but there are not any potential non-listed sources of the
Potentially Listed Hazardous Constituents detected in the Material
(Step L l) (subject to a "contained-out'' determination in Step 13).
Proceed to Step 1 J.
13. HAS STATE OF UTAH MADE A CONTAINED-OUT DETERMINATION.
If the Material is an Environmental Medium, and:!
• the level of any listed waste constituents in the Material is .. de minimis'•; or
• all of the listed waste constituents or classes thereof are already present jn the
White Mesa Mill's tailings ponds as a result of processing conventional ores
or other alternate feed materials in concentrations at least as high as found m
the Materials ·
the State of Utah will consider whether it is appropriate to make a contained-out
determination with respect to the Material.
If tile Stale maka a contatnld-t>UJ detenninatior,, proceed to Step 16.
If tht! State doe.s not make a contained-out determination, proceed to Step I 4.
14. IS lT POSSmLE TO SEGREGATE LISTED HAZARDOUS WASTES
FROM OTHER MATERIALS?
24Jl76.l
Determine whether there is a reasonable way to segregate material that is a listed
hazardous waste from alternate feed material& that arc not listed hazardous wastes that
will be sent to nJSA's White Mesa Mill. For example, it 01ay be possible to isolate
material from a certain area of a remediation site and exclude that material from Materials
that will be sent to the White Mesa Mill. Alternatively. it may be possible to increase
lO
..
sampling frequency and exclude mate1ials with respect to which. the increased sampling
identifies constituents which have been attributed to hsted hazardous waste.
lf yes, proceed to Slep I 5.
lf no, proceed to Step 11.
JS. SEPARATE LISTED HAZARDOUS WASTES FROM MATERJALS.
Based on the method of segregation detennincd under Step 141 materials that are listed
hazardous wastes are separated from Materials tbat will be sent to the White Mesa Mill.
For materials 11,at or~ listed hazardous wastes, proceed to Step I 2.
For Materials to be .senl to the White Mesa Mill, proceed to Step Id.
16. PROVIDE INFORMATION TO NRC ~ UTAH.
' I
If tho Material docs not contain any Potentially Listed Hazardous Constituents (as ·
determined in Step 7). where information concerning the source of Potentially Listed
Hazardous Constituems in the Material is •"unavailable or inconclusivc11 (as determined i.n
Steps 8 through 11), or where the State of Utah has made a contained-out determination
with respect to the Material (Step J 3), the Material will be assumed not to be (or contain)
a listed hazardous waste. [n such circumstances, nJSA will submit the following
documentation to NR.C and the State: ·
• A description of the Source Investigation;
• An ex.planation of why tho Material is not a. listed hazardous waste.
• Whore applicable, an explanation of wby Confirmation/Acceptance
Sampling bu been deter.mined not to be necessaiy in Step 17.
• If Confumation/~tance Sampling has been determined necessary
in St• 17 • a copy of IUSA's'; and the Gencntor's Sampling and
Analysis Plans. .
• A copy of Confinn.a.tion and Acccptanc.c Sampling results, i C
applicable. ruSA will submit these results only if they identify the
presence of '"new"' Potentially .Listed Hazantous Constituents (as
defined in Steps 7 and 8).
Proceed to Step 11.
17. ARE SAMPLING RESULTS OR DATA REPRESENTATIVE?
l~lll76.I
Determine whether the sampling result$ or data fiom the Source Investigation ( or, where
applicable. Confirmation/ Acceptance Sampling results) arc representative. The pUiposc
of this step ) is to detcmninc whether Confumation and Acceptance Sampling (or
l1
P~oHJCl)L fOR DETER.\11NJ:'(G WUt:TUER AI.Tf.R:-i,\Tf. f£f.U M..t.T£R!AL.S ARE LISTED HA2.ARD01,;S '" .. ~ rr.s
continued Confirmation and Acceptance Sampling) are necessary. Ir the sampling resu:t-.
or data are representative of all ~aterial dostincd for the White Mesa Mil~ based on the
ex.tent of sampling conducted. the nature of the Material and/or the nacurc of the Site
(e.g., whether chemical operations or waste disposal were known to be conducted at the
Site), future Confinnation/ Acceptance Sampling. will c.ot be necessary. If the sampling
results ate not representative: o( all Material destined for the White Mesa Mill, then
' additional Confim1atioa/Acccptanee sampling n;iay be appropriate. Con6nnation and
Acceptance Sampling will be required only where it is reasonable to expect that
additional sampling will detect addit;onal contaminants not already detected.. For
ex.ample:
• Where the Material is segregated 'from Environm.ental Media, e.g., the
Material is containerize~ there is a high probability the sampling results or
data from the Source Investigation arc representative of the Material and
Confinnation/Acceptance Sampling would not be required .
• I
• Where IUSA will be accepting Mat~rial ftom a discrete portion of a Site, e.g ..
a stoxago pile or other defined ar~ and adequate sampling c.baracterizM the
area of conccm for radioactive and chemical cootaminants, the sampling for
that area would be considered representative and Confirmation/ Acceptance
sampling wowd not be required. : :
I
• Where Material will be received from a wide area of a Site and the Site has
been carefully characterized for radi6active contaminants, but not chemical
contaminants, Confirmation/ Acceptan~e sampling would be required.
• Where the Site was not used for industrial activity or disposal be.fore or after
uranium material disposal, and the Site has been adequately charactemed for
radioactive and chemical contaminants. the, existing sampling would be
comidered sufficient and Confirmation/Aooeptance sampling would not be
•• :_.1 I rcquuiwu. . j
' • Where lilted wutes were known to bc1disposed of on the Site and the limits of
the area where listed wastes I were managed. is not known,
Confinnatiou/Acceptance sampling· would be required to ensure that listed
wutes ani not shipped to ruSA (sec Step 14).
If ya, procud to Step 4. i
If no, procud to Step 18.
18. DOES STATE OFIITAH AGREE THAT ALL PREVIOUS STEPS HAVE
BEEN PERFORMED IN ACCORDANCE WiiTH THIS PROTOCOL?
243176.l
.
Determine whether the State agrec8 that tJiia i Protocol bu been properly followc:d
(in<:luding that proper decisions were made at ;each decision point). The State shall
12
PROTOCOL 1•UR. OETtR~l'\'JNc; WHT.THr.R AL n :l'\'A.TE: FEF.:D :\-(,\1"£.l<VJ..S AA£ LISTEO UAZ.-.RDOt:S \'t'."~u:s
19.
20.
24]1176.1
I review the information provided ~y IUSA in Step 16 with rea.~onable speed and advise
fUSA 1f it believes [USA has not ~roperly followed this Protocol in determining that tbc
Material is not listed hazardous waste, specifyjng the particular areas of deficiency.
ff this Protocol has not been propc~ly followed by nJSA rn making its determination that
the Material is not a listed bazih-dous waste, :l~en IUSA shall redo its analysis ia
accQrdancc with this Protocol and, ljf justified, resubmit the information described in Step
16 explaining why tbe Material i~ not a listed hil2ardous waste. The State shall notify
1USA with reasonable speed if the State stillbelie;v.es this Protocol has not been followed.
If yes, proceed to Step 19. ·l '.
If no, proceed to Step l.
MATERIAL rs NOT A LISTE~ HAZARDOUS w ASTE, BUT
CONFIRMATION AND ACCEPTANCE SAMPLING ARE REQUIRED.
The Material is 1,1.0t a listed hazardlus waste~ but ~onfirmation and Acceptance Sampling
are required. as detmnined necess~ under Step ~ 7.
j ' Proceed to Step 20.
1
1 , I · ; ! l
CONDUCT ONGOING CONITION AND ACCEPTANCE SAMPLING. . '..
I ·
Confirmation and Acceptance S pling :will ! rionrinue until determined no longer
necessary under Step l7. Sucb s~pling w.ill be ponductcd pursuant to a Sampling and
Analysis Plan ("SAP'') that specifies the &eciuency and type of sampling required. If
such sampling does not reveal ani ••new" Potentially Listed Hl7.&l'dous Constituents (as
de.fined in Steps 7 and 8), further ~valuation ia m,t necesJary (~ indicated in Step 7). If
such sampling reveals the presenc~.of1'new" conatitumib, Potentially Listed Wastes musr
be identified (Step 8) and evaluated (Steps 9 through J 1) to dotcmnino whether the new
COl\$titucnt is m>ZJL a listed hazard~ waste soured. Generally, in each case, the SAP will
specify sampling comparable to t~e level and frc4tucncy of sampling petfonned by other
facilities iI1 the State of Utah that dispose of. t 1 e.(2) byproduct material. either directly or
tbat msulll &om proc-,itt1 alt~m~te feed ~leriali.
Proceed to Step ?. I ; ! [
' . , ,
II I' '' 11
13
" '1 I I
I .. ·•
I
ii
11
1 J
H
Attachment l
Summary of RCRA Listed Hazardous Wastes
There are three different categories oflisted hazardous waste under RCRA:
• F•listed wastes from non-specific sources (40 CFR § 261.Jl(a)): These wastes
include spent solvents (F001-F005), specified wastes Crom clectropJating operarions
(F006-F009). specified wastes from metal heat treating operations (FOLO..F012),
specified. wastes from chemical conversion coating of aluminum. (F019), wastes from
th.e production/manufacturing of specified, chlorophenols, ch1orobel17Ales, and
chlorinated aliphatic hydrocarbons (FO l 9-F.028), specified wastes from wood
preservin1 processes (F032-F035), specified wastes from petroleum refinery primary
and secondary oiVwater/solids separation sludge (F037-F038), and Je~bate resulting
from the disposal of more than one listed h~ous waste (F039).
• K-li.sted wastes from specific .sources (40 CPR § 261.31): These include specified
wastes from wood prescrvation1 inorg3:Jlic pigment procluctionw orpnic cbcm1cal
production, chlorine productiori, pesticide production, petroleum refining. iron and
steel production, copper productio~ primary· and &econdary lead smelting. primary
zinc production. primary aluminum reduction. fe.rroalloy production. veterinary
pharmaccu~cal production, ink formulation an~ coking.
. ' i I • p. and U-li:std commercial ch~1nical pr.oduc,ts (40 CFR § 161.33): These include
commercial chemical products. 1or manufacturing chemical intermediates having the
generic name listed in the ••p0 or "lf' list of wastes, container residlla, and residues
in soil or debris resulting from a spill of these· materials.1 "The phrase 'commercial
chemical product or manufacturing chemical! intermediate ... ' refers to a chemical
substance which is manufactured or fonnulated for commercial or manufacturing use
which consists of the commercially pure gra~e of the chanical, any technical gr.ides
of the chemical that arc produced or marketed. and all formulations in which the
chemical is the sole active ingredient. ! It doe.s not refer to a material, such as a
manufacturing process wute, that contains any!ofr.he [P-or U-listed substanccs]."1
• ' I
Appendix Vll to 40 CPR part 261 identifies the bazardo~ constituents for which the F-and K·
listed wastes were listed. ! ! ! :
l I
• i
; t
I ' I .
I ! I ' ! . I'
l P-listcd wastes are identified as "acutely hazardous wastes" and uc subject to additioml management
conttols wider RCRA. 40 CFR § 261.33(e) (1997). U-l'isted ~es are identified as "toxic wastes." [fl.
§ 261.JJ(t). '
2 40 CFR. O 261.JJ(d) note (1997). j i .
I .. '
l•Jl76.1 Ii
1 I ! . , I
Mi~lQCI o. l.;nvilt
l'ieYDfflDI
Dianne R t-.icl5nn, Ph.O, J;,:oc,u,.ve D11~1:1or
Di:nnis R. DownK
01Tl!~hlr
State of Utal1
DEPARTMENT OF E~VIRON~li~TAL QUALTTY
DIVISION OF SOLID AJ.'.;0 HAZAROOt:S WASTE
2~8 North 1460 \Vcsl
1'.0. Box I '14~11(l
Snit Lnkt. Cil)', Utah 84114-411110
(IJOI) 538-6170
(801) 538-671~ fall
[phone] i L) I'.>.
W\Y\V, t.l~l\ .Sl11l1!.Ul.U$ Web
o~ct:mber 7, l 999
M. Lindsay Ford
Parsons, Behl~ and Latim~r
One Utah Center
201 Soutb Main Street
Suite 1800
Post Office Box 45898
Salt Lake City, Utah 84145-0898
RE: Protocol for Determining Whether Alternate Feed Materials are Listed Huardous
Wnstcs
Dear Mr. Ford:
On November 221 1999, we received the final protocol to be used by International Uraniu111
Corporation (IUSA) in determining whether altemate feed materials proposed for processing at
the White Mesa Mill are listed hazardous wastes. We appreciate the effort that went into
preparing this procedwe and feel that it will be a useful guide for IUSA in its altemate feed
detenninatiom;.
As was discussed, please be advised that it is IUSA's responsibility to ensure that the alternate
feed materials used are not listed hazardous wastes and that the use of this protocol cannot be
used as a defense if listed hazardous waste is somehow processed at the White Mesa Mill.
Thank. you again for your corporation. If you have any question~. please contact Don Vcrbica at
538-6170.
Sincerely,
-kL_
(,4(,,,'.,(,,/ ~-~ £.i~",,,...l',lt~ ruus R. ools1 fucecutive Secretary
Utah Solid and Hazardous Waste Control Board
c: Bill Sinclair. Utah Division of Radiation Control
F. \SHW\HWO\DV1!Jt8(('.A\ W 11\wtillCllte~.,llpCI
/
. '
PftOTOC04 Ff>R DETF..RM~~G WHETHER
ALTJi:R."lATE FEED MA'X'lt~SAR.E LTSTED HAZARDOUS WASTES1
. . ~ l
OVEMBER 16; 1999 t . I
SOURCE INVESTIGATION. l ; :
Perform a good faith investigatilnr(a. 0Sourc~ rn~dstigation° or '1Sl .. )1 reg~ding whether
any listed hazardous wa!ites3 arJ located at the site from which alternate feed material"
C'Material") originates (the "Sitt'')l This investigaiion will be conducted in confom1ance
"_'ith EPA guidance.s and thcj C· .te~t of info~1ation r~qu.ire~ ~ill vary witll the
cll'cumstances of each case. Fo~owmg are exan;iples of mvestxgatLons that would be
considered satisfactocy under rp A guidance ~1d this Protocol for some selected
situations: t :
• Where the Material is or has been gonb~ated from a known pfQeess under tbe
control of the generalo~: (a) an a~fida~f ~ c;ertif(cate, prolite record or ~lat
document from the ~brator or Site ~~ager, to that effect, together Wlth (b)
a Material Safety 9at~ Sheet (uMSD~ .. ) for the Materi~I, limited profile
i I i
l i '.;
~ i I 1 This Protocol reflects e t at. will e followed b an uaderstatulieg hetween lhe ~'h
Div:isiea ef SeliQ a~ '.V-aste, l>e;.enmac ef l!rw~eam, QYoUt,c ("DSQ" er the "State")
• International Uranium (USA) Corpbnltion ("WSA") : for determining whether alternate feed
materials proposed for processing at the WiJu(e Mesa Mill are; (or contain) listed hazardous wastes. It is
based on current Utah and BPA, rules and EP~ guidance unde.r:the Resource Conservation and Recovery
Act (04RCRA")1 42 U.S.C. §§ 6.901 ct seql lfhis Protocol wi\1 be changed as necessary to reflect any
pertinent ohanses to RCRA rules or EPA awidance. . i
2 This investigation will be performed byl itls~ by the entf ~ responsible for the site ft'om which rhe
Mllterial originates (the "Generator''), or bY. a ~ombination of die two . . :
3 Attachment l to this Protocol provides a summary of th~ I different classifications of RCRA listed
hazardous wastes. :
4 Alternate feed materials that are primary 1inteonediate products of the generator of the material (e.g.,
··green'" or .. black" salts) are not RCRA .. ccbndary materials'~ or "solid wastes,° as defined in 40 CFR
261, and are not covered by this Protocol. l ; j
5 EPA guidance identifies the foUowin~ slurces of site-and waste-specific infonnation that may,
depending on the oircumstanccs, be con&idch:d in such an investigation: hazardous waste manifests,
vouchers, bills of lading, sales and inv ht6ry records, ,nat~al safeJ.y data sheet$, storage records,
sampling and analysis reports, acc'id ntf reports, site I ;investigation reports, interViews with
cmployccs/fonncr employees and fonner ownemlop~tors, ;spill reports, inspection reports and logs,
permits, and enforcement orders. See e.g., ll Fed. Reg. 1880S rApril 29, 1996).
JOJ9C'll,l
I i I ! i I
PROTOCOL FOR DET<R"II.ING W1<t·rHER ALTERNATE lrO MATERIALS ARE Lt~r<o !fA7.AtUIOIJS W..-r,s
sampling, ot· a material coJposition de::tem1incd by the generator/operator
based on a process material bJ{ance.
• Where specific il1forrnationll exists about .the generation process aod,
management of the Material~! (a). an affidavit, certificate, ptofile record or
similar doewnent from tile Gipera~or or' Site Manager, to tbaf etfectJ. taiether
with .Cb? ~ MSJ?S .ror the 1~ateriaL l~ted profile sampling ~a or l
prccx:1stma 1nvest\galion p~rfonn~ at the Sste pursuant to CERCLA, RCRA
or other st~fe or federal envirofunental laws or programs.
2.
JOJ96l.l
• Where potentially listed procJses nre known to have been conduc,ted at a Site,
an investigation consideringl'.tl\e following sources of information: site
inve~tigition r~orts prepared ~\nder CERCLA, RCRA or other state or federal
environmental laws or programs (e.g .. an IU/FS, ROD, RPI/CMS. bazardous
waste inapection rcmort); intet:yiews with persons possessing knowledge about
the Material and/or Site; ~d reviow of publicly available documents
concerning process activitic~ or the history of waste generation and
management at the Site. I:
• If material .from the same sJbe is being or has been accepted for direct
disposal as 1 le.(2) byproduct; material in an NRC~regulated facility i11 the
State of Utah with the consent jar acquiescence of the State of Utah, the Somce
Investigation performed by su~h facility.
Proceed to Step 2. I~
!' t
SPECIFIC INFORMATION OR AGREEMENT/DET.£RMINATI0N BY
RCRA REGULATORY AUTHORITYjiJ'~T MATERIAL IS NOT A
LISTED HAZARDOUS WAS'l'E? I:
a. Determine whether specific informatiQ~ from the Source Investigation exists about the
generation and management of the Matdat to support a conclusion that tb,e Material is
not (and does not contain) noy listed l!hazar~ous waste. For example, if specific
information exists that tlic Matex:inl was not generated by a listed waste source and that
the Material has not been mixed with any liisted wastes, the Material would not be a listed
hazardous waste. ';
b. Alternatively, determine wh.cther tbe a~pi'opriate state or f~deJ'II authority with J,lCRA
jurisdiction over tb.c Site agrees in writifag· with the generator's determination that the
1: •
I
I•
I! : .. •·
Ii
!1
I; -
l'ROTOCOL FOi\ J)£T£~MINING Wt1£'fU~R Ar.TF;RNA1T.l~£ED MATERfAI..S AR! l..lSTED HAMRDOUS WASTES
; I ~ ;
J.
I : ' Material is not a listed hazardous waste, ~as ma4~ a .. contained~out" determination' with
respect to the Material or l{as concluded t?e M_ateiial or Site is not su,bject to RCRA.
Ifye~· to either q1,estlo,,1 p>f ceed to St,,p J. ;. :I
If no to hotll questions, proceed lo Step 6.L 1 I
J I I PQOVIDE INFORMf\T 1oN TO NRC . ~ , AH.
a. If specific information exists to suppoi a c~nc}usion that the Material is not, and does
not contain, any listed Hazardous was~e. Qltewatienal UraRiYR'I fUSA) C.0i:peratl&&
~IDSA!!} will provide a description of th'e So~c». Investigation to NRC and/or the State
of Utah Department of Btiv.ironmental Qµality, Division of Solid and Ha?.ardous Waste
(the .. State"), together with an @ffidavit cxplatHing why the Material is not a listed
h37cardous wa~. I I ; J
b. Alternatively, if the ap~ropriate reg1,1latory!a11 ority with RCRAjuri.sdiction over the
Site agreM in writing witlt, the generalor'~ dete '. ination that the Material is not a listed
hazardous waste, makes a bontained-out dcterm~tion or detennines the Material or Site
is not subject to RCRA, IUSA will pro\ride documentation of the regulatory authority's
detemlination to NRC antl the State. WSAl m~~ rely on such determination provided
that the St.ate agrees the co~clusions of th~ re~lJ\0ry authority were reasonable and made
in good faith. 1 I · I
l Proceed to Step 4. ' • I i !
I I
6 EPA explains tho "contained-out" (also n,6,aed to ~• "c~nta~od-in") ¢nciple as follows:
rn practice, EPA has applied ~e contained~injprin~iplb to refer to a process where a site·
specific determination is ma<f:e that conccnlra{jons of,bardo~s constituents in any given
volume of environmental media are low enJugh .to ~etcnn.ine that the media does not
"cnntuin" hazardous WU. te. j•t'ypically. these SO .. Clll~fd "contained-in" [or "conta.ined-
out"j detenninatjons do ndt m~ that 1"10 hazardous constituenu arc present in
environmental media 'bul simply that the lconccn1rlltions Qf hazardous constituents
d I • JI _ do prcaent o not warrant ma~gementofthc 1ncdia_ a~ h~r us waste ....
m> A. ~s ll~ to date, i~11ed ~efinitive auida~cc :to ~bllsh the ~nceutrations ~t which
QOntamcd~1n deu,nni_nationa fAY be made. As no.ted ~bov~ decisions that media do n~t
oc n~ l~ger ~ntam bazar~ou.s wute .nrel typ1~a!l, made on a case-by~c basis
c;ons1dcno,g ·t~ nsk.s posed by the contaminated !Iltdla
63 Fed. llc1. 28619-, 211621•12 (May 26, 1998) (Pbu~JV r:o~ reamble).
J0)961.l 3
l'ROTOCOL ~0KD1:'.:f£HM1NING WH~:THER ALTF.Ri'I/ATE FEED MA'f.ERlAlS ARE LIS'r£0 HAZ/\IU>OIJS WASTES
4.
s.
6.
30l96U
. .i
DOES STATE OF UTAH'. AGREE THAT;kril PREVIOUS STEPS HAVE
BEEN PERFORMED IN.ACCOR.DANCE Wl:tH THIS PROTOCOL?
. I :1
Determine whether the s;tate agrees rhat ;tlµs .;Protocol hn.s been properly followed
(including that proper de~isions were made. jat ~ach decisio11 point). The State shall
review the information provided by IUSA in)Step·~ or 16 tweMtJtly w1th rcasopablc sgced
and advise IlJSA if it b'elieves IUSA ~ no1t properly followed this Protocol in
determining that the Material is not listed.h : do~s waste, specifying the particular areas
of deficiency. . : I j
I '
If this Protocol has not been properly follow~(\ by[IUSA in making its detennination that
the Material is not a listed hazardous w~sie, then lUSA shall redo its analysis in
accordance with this Proto(?Ol and, if justified, ~csµbmit the information described in Step
3 or 16 explaining why the Material is not a U~led hazardous waste. The State shall • I o
notify IUSA premptly with reasonable speed ff the State still believes this Protocol has
I :• not been followed. j ::j
If yes, proceed to Step 5. / :
1
If 110, proceed to Step J _ ;
1
.;i
MATEIUAL IS NOT A LISTED HAZARDOUS WASTE.
The Material is not a listed hazardous wasiel an~ no further sampling or evaluation is
necessary in the, following circumstances: ! I =,I
• Where the Material is determined.loot to be a listed hazardoUB waste
based on specific information abo~t th~] generation/management of the
Material QR th~ appropriate RCRiA! regii1atory authority with
jurisdiction over the Site agrees "iith th~ generatox"s determination that
lhe Material is not a listed HW, niaR:es.a contained-out detennination,
or concludes the Material or Site ~ hot/~bject to RCRA (and the State
agrees the concl~sions of the reg~1~01
1
-authority were, reasonable and
made in good faith) (Step 2); or j !
+ Where the Material is detemlined:npt ti be a listed hazardous waste (in
Steps 6 through 11, 13 or l S) andjCpnfF1ation/Acccptancc Sampling
arc determined not to be necessary {un4er Step l 7).
! I ·.;
IS MATERIAL A PRociss w ASTE KNOwi,r TO BE A LISTED
HAZARDOUS WASTE OR T.O 'BE ~,
1 r· HA LISTED
HAZARDOUSWASTE?i I :(
I ,,
Based on the Source mve~tigation, determipe w~ether the Material is a process waste
known to be a listed hazardous waste or to b~ ~x"d witb a listed hazardous waste. If the
Material is a process waste and is from a-Ii ted;' hazardous waste source, it is a listed
• I ..
!
4 'I
I
l)ROTOCOT, F()R DETERMlNlNC WHETHEll AL.n:R.'lA'CI:'. FEF.D, MA1'ERIALS AR£ LlSTEO HAZARDOUS W~STES
7.
. .
i ; i .:
h.v..ardous waste. Similarly, if the Material (is~ pihc~ss waste and has been mixed with a
listed hazardous waste, it is a listedJ'laZal'do~slwaste under the RCRA ''mixture rule." lf
the Material is an Enviro~cutal Medium,' it ~ann.'ot be a listed hazardous waste by direct
listing or under the RCRA .. mixture rule."8 l lf the Material is a process waste but is not
known to be from a listed source or to be m 6t witb a listed waste~ or iftl1e Material is
an Environmental Medium, proceed to Ste s through l 1 to deternrine whether it is a
listed hazardous waste. ; ;i
i
ff yes. proceed to Step 12. ;
If 110. proceed to Step 7.
• I ,
HAZARDOUS CONSTITUENTS? I ·; DOES MATERIAL CONTAI~ ANY P01 NTIALLY LISTED
~ l . :
Based on the Source Investigation (and, if applicable, Confinnation and Acceptance
Sampling), detcnnine whether the Material ~htaips any hazardous constituents listed in
the then most recent version of40 CFR 261, ~ppendix VII (which identifies hazardous
constituents for which F-and K-listed wostei ,ere listed) or 40 CFR 261.JJ(e) or (f) (the
P and U listed wastes) (collectively 11PotentirlJy Listed Hazardous Constituents"). If the
Material contains such constitu~nts, a sour ~val~ation is necessary (pUISuant to Steps 8
th.rough 11 ). If the Material does W!! 6ntain any Potentially Listed Hazardous
Constituents, it is not a listed hazardous ~aste. The Material also is not a listed
hazardous waste i( where appli~ble, Confi iqn and Acceptance Sampling results do
not r~veal the presence of any. .. new'i Potfjially Listed H~ardo~s Constituents (i.e.,
constituents other than those :that have ~ already been identified by the Source
Investigation (or previous Confimlation/Adceptance Sampling) and determined not to
originate from a listed source). I ,
q y~. proceed to Step 8. : !
If no, proceed to Step 16.
' .,
.. •,
7 l11e term .. Environmental Media" means· so1ls, ground ~ surface water and sediments.
8 The "mixture rule" applies only to mixtures ·of listed ~ r4ous wastes and other "solid wastes.•· See
40 CFR § 261.3(a)(2)(iv). Th.e mixture rule does qoL :apply to mixtures of listed wastes and
Environmental Media, because Enviiorun*ntal Media e not :·soHd wastes" under RCRA. Se.e 63 fed.
Reg. Z8S56, 28621 (May 26, 1998). 1 1 •
303961.l 5
.,
'I I
' I ..
l'ROTOCOL FOR DET£RMINlNC WHt;THEll Al.TE.RNA.Tit F.F;EI) MATERIALS AR£ L1$TF..D HAZARDOUS WAST£S
8.
9.
. .
?:
i= i , I
IDENTIFY POTENTIALLY LISTED WASTES. I I
Identify potentially listed hazardbus wastes: (''~otentially Listed Wastes") based on
Potentially Listed Hazardous Consiituents detected in the Material, i.e., wastes which are
listed for any of the Potentially Lis~d Hazardous Constituents detected in the Materials as
identified in the then most current version 10f 40 CFR 26 l Appendix VJI or 40 CFR
26I.33(e) or (t).9 With respect tojPotcntially Li'.sted Hazardous Constituents idefltified
through Confinnation and/or .Acceptance Sampling, a source evaluation (pUISuant to
Steps 8 through 11) is necoss~ only for ,!11new .. Potentially Listed Hazardous
Constituents (i.e., constituents oth~r th1,tt those that have ftM already been identified by
the Source Iovestigation (or Jtrevious Confmnatioo/Acceptance Sampling) and
determined not to originate from a listed source). :
I •
Proceed to St~p 9. I: '
WERE ANY OF THE POTENTrl4LLY LISTED WASTES KNOWN TO BE
Gl!:NERATED OR MANAGED AT SITE? ·!
Based on infonnatiun from the J~uree Investiiation, detemrine whether any of tho
Potentially Li$ted Was~ identifi~d in Step · 8 are kQown to have been generated or
l'l1anaged. at the Sito. This deter;mirlation involves !identifying whether at1y of the specific
or n~n-,eciffo sources identified iq. the K-O! ·p .. li_sts has ever been conducted or .located
at the S1te, whether any wasto froth such processes has been managed at the Site, and
whethw any of the p .. or u .. ti.sted I commercial chemical products has ever been used,
spilled or managed there. In paiticular, this detennination should be based on the
following BP A criteri.a: 1 : :
Solvent Listings lFQOt .. FQOS)
Under EPA guidance, 4'to determine if solvent constituents contaminating a waste J •
are RCRA spent solvent FOO 1-FOOS wastes, the [site manager] must know if: 1· ';
• T
1
he ~olvents are spent Jand cannot: b~ !reused witlioalt rec/{IT11.ation or
c eamng. ..
• The solvents were r1secl ~clusively,for Jheir solvent properties.
1. : • The solvents are spent mwu,·es and blends that contained, before iue,
a total of l O percent of· more (by V(?f ume) of tlie solvents listed in
FOOl, F002, F004, and Fpos. . :
• ·1
9 For example, if tho Material aontai"' tenlelby~ ~• following would be Potenm.Jly Listed
Wastes: FOOi, F002, F024. K019. K020, K1Sd,·KI5l or U2l0: Se.e 40 CFR 261 App. VII. ,. ;.
]; . . r!
PROTOCOl. FOR D£T[RM1NING WHETHER A.tTJijA'fl:: FEED MATERIALS AU L1sn;o fiAZMDOUS WA!iTts
! 1,
I .'j I • • I
If the solvents containbd Ti'. the (wa~te~J are RCRA listed wastes, the
I , ' [ wastes] are RCRA hazard us waste. · Vi7il1en the [site manager] does not
have guidance iofonn~ti~·r on the ; u~e of the solvents and their
charc1cteristics before us~ t~e [wastes) :cawiot be classified as containing a
listed spent solvent."10 I The person per~nning the Sou.roe Investigation
will make a good faith !!ffott to o.btain i#ormation on any solvent use at
the Site. If solvents wei;e u~ed at the Site, general industzy §tandards for
solvent u,se in effect at the time of use w.ill be considered in determining
whether those solvents ~Qntlined 10 percent or more of the solvents listed
in FOO 1. FOQZ. E004 or FOOS. =
-List a t s and M !w 1ste.s an F001-S
I ~ :t Under EPA guidance, to d tennioe whe er K wastes and F wastes other than
FOOl~F005 are RCRA list ' wastes, ~ 'generator "must know the getteration
process i,ifonnation (ab~ut Jach waste contained in the RCRA waste) described in
the listing_ For exampl~, fo~ [wastes] ~o ~·e identified as containing R.:001 waste$
that are described as 'bottom sediment sl~'dgc from the treatment of wastewaters
~m wood preserving Pf<>Ct{sses that u~e ·r,eosote and/ or pentachlorophcnol, • the
[site manager} must lcnow ~o rnanufact1.r,ng process that generated the wastes
(treatment of wastewaters ~,m wood preserving process), feedstocks used in the
process (creosote and pentabhlorophenoij; and the process identification of the
wastes (bottom scdimen~aludl· ge)."u JI Ji
P-Md U-Ltsted Wastes : : : j
EPA guidance provides (tha. "P and 4 1astes cover only unused and unmixed
commercial chemical prod~cts1 pnrticul3tlY spilled or off-spec products. Not
every waste containing a P b1 r U chemical is a hazll{dous waste. To determine I I whether a [waste] contains f P or U ~ast~. tne [site manager] must have direct
evidence of product us~. ,. particu1¥, " [site manager] should ascertain, if
possible, whether the ch~michls arc: j i
• Discarded (as described ih 40 CFR. i61 12(a)(2)). . 1 .. , l
• Either off-spec commecctal products or.;a commercially sold grade.
·I :
I i
r ,,
10 Mat1agement of Investigation-Derived Wast
(emphasis added). '
I ' During Site Inspections, EPNS40/G-91/009, May 1991
: ·J 11
1 L Management of Investigation-Derived Wat
( emphasis added).
D~g s,te '1t~tions, EPA/540/G~9l/009, May 1991
I • ,: I:
•• I· , : I II
11\1 (\Ill, I 1
l~ROTOC.Of .. FOR DF.Ttlt.'111\'IN'G WttF,THER AI.T.ERNl/>.TE FEED MATF.RI/\LS AlU: Las·r.t:o HAZA~OOUS WASTES
I . ~
] I ~
• Not used (soil contamiu~ted wjth spilJed unused wastes is a P or U
waste). ! I . !j:
• The sole active ingredien· in a fonnula(~on.''12
I :•
If Ille llll6WOf le lite ~iea ill thief""' J ¥M, ~Qt'3l!jgl)y Listed Wasl!§ »'ffl known
to be generated or managed at th~ Site.j ful'therJ evaluation is necessary to detenninc
whether these wastes were dispose~ of or; comm~gled with the Material (Steps l O and
possibly 11). If the ae&v,or is t1e,:I.If Poie.tltiallyl Listed Wastes were not known to be
gtgcratcd or managed at the Site. t~e.n inf onnatidn concerning the source of Potentially
Listed Hazardous Constituents in I the Material! will be considered "unavailable or
inconclusive'' and, under EPA guiddnce, IJ ltbe Material will be assumed not to be a listed
hazardous waste. ..
' I
' I I I' I,
12 Management of Investigation-Derived W~tes During Site Inspections. EPA/540/G-91/009, May
1
t
9
3
9
£
1
p. A 'd · t1 'd h ;ih J~ tJ . th . . f . gu1 ance cons1stcn y prov1 cs t a~ ,-ere uuorma 19n concenung e ong111 o a waste rs ™*
mavailablc or inconclusive, the waste may be assumed ~ l o. be a listed hazaroous waste. See e.g.,
Memorandum from Timothy Fields (Acting ~ssistant A~strator for Solid Waste & Emergency
Response) to RCRA/CERCLA Senior Policy · anag6rs rcgari:ling •fManagemcnt of Remediation Waste
Under RCRA," dated October 14, 1998 ("Wh~ re a f~llity otner/operator makes a good faith effort to
determine if a material is a listed huardowt wastJ but cannot make such a dctennination because
documcnc.tion regarding a sow-cc of contamination, cobtaminant, or waste is unavailable or
inco11clusive, EPA has stated that one may kssume the sohrcc, contaminant, or waste is not listed
hazardous waste"); NCP Preamble, SS Ped! Reg. l 8758 (E' arch 81 1990) (Noting that uit is often
necessary to know the origin of the waste tol detertjune wb' thct it is a listed waste and that, If such
documentation la lacking, the lead agency m~ anu~e it is ~ ot o listed waste); Preamble to proposed
Hazardous Waste Identification Rule, 61 Fed1 Reg. i 880S (,f'.priJ 29, 1996) ("Facility owner/operators
should make a good faith effort to determine etberlmcdia w.~e contaminated by hazardous wastes and
ascertain the dates of placement. 1be Agcncr belieyes that ~y using available site-and waste-specific::
infonnation ... facility owner/operators would!~ically be ab{e to make these determinations. However,
as discussed earlier in the preamble of today'd prop~sal. if information, ls not available of inconclusive,
facilily ownerlapsraton m")' genero.lly ass·Jie 11,(l! the material co,i1aminaling the media we.re not
haza,-do111 wa.riu:-,; Preamble to LPR Pht IV lRule, 61, Fed. Reg. 28619 (May 26, 1998) (" As
disoussed in the April 29, 1996 proposal, th Ag~~y c'ontirues to l;,elieve that, if in[onnatl'on is not
available or inconclu1lve, it Ls generally reaf nabl1 to assu~e lhat contaminatell 90/11 do not contair,
imtttoted hazardous wastes ... "); and Mem+randum from John H. Skinner (Director, EPA Office of
Solid Waste) to David Wagoner (Director. ~A Air :md ~ste Management Division. Region VU)
regarding ••soils from Missouri Dioxin Sit~\1
11 da~d Jan 6, 1984 (''The analyses indicate the
presence of a number of toxic compounds in many of t c soil samples take~ from various sites.
However, Ille presence of these toxicanu in rhe ~il does f Qt automatically umke the soil a R.CRA
(footnote contin".;d on next page) I :
ol • 'I
l'ROTOCOI, FOR 0ETERMlNl~G WHi.TH£R ALTERNA.Tt 1'):tO.:\fATl;RIALS ARE LIS'fEl> ~AlWOL:S WA.SH:S Ji . !!
10.
11,
12.
1! !l' ~! ff yes, proceed to Step J 0. : ; 1 • JI
If no. proceed to Step I 6. \ ~ J.I : ~I
WERE LISTED WASTE$ KNOWN T8 BE DISPOSED OF OR
COMMINGLED WITH MATElifAL? i t; !'.
If listed wastes identified in Step i were! J~wn !to be generated at the Site, detennine
whether they were known to be disrlosed of Ji co ingled with the Material?
If yes, proceed to Step 12. : i : I
If 110, proceed to Step L J. 1 ; ;
• I I I ' I
ARE THERE ONE OR MORE POTENTl.'~_:i ON-LlSTED SOURCES OF
LISTED HAZARDOUS WASTEkONSTf1
TU.JtJ NTS? : i Ii
In a situation where P~tcntial y Li~teci v,.astes were known to h~vc been
generated/managed at the Site, but I e wast~s wer.c not known to have been di:,posed of
or commingled with the Material, deteimirie .J.hether there are potential non-listed
sources of Potentially Listed Ha.zatidous Co~stitu&its in the Material. If not, unless the
State agrees otherwise, the const~1uents! 9ill b~ assumed to be from listed sources
(proceed to Step 12). If so, the ~~eri~ w.iJl b1! ~sumed not to ~e a Iis~ hazardous
waste (proceed to Step 16). Notw1tlistan~nslithe Cl(astcnce of potential non-bstcd soW'ces
at a Site, the Potentially Listed Hukdous:Canstiti>.ents in the Material will be considered
to be from the listed sourcc{s) if, ~ased o,n fhc r~~ative proximity cf the Material to the
listed and non~listed so\lI'Cc.{s) and,for infonfatiorli conccnii~g waste managetnent at the
Site, the evidence is compelling that the listed sow!ce(s) is the source of Potentially Listed
Haurdous Constituents in the MateHaJ. : i 1
If yes, proceed to Step 16.
l·
I l lf ,,o, proceed to Step J 2.
MATERIAL IS A LISTED HAZ ,· ous:WASTE. . I I
The Material is a listed hazardous W.~tc ~dJ·the
1
01lowing circumstances: . , I • I I , : i
;
I (footnote continued &om previous page)
' I I I
hazardous wast1:;. The origin of the toxicants E: ust be: ~wn h order to detennine that they are derived
from a listed hazardous waste(s). ff the exac •orig/,,'.oi,.~he" lx-icants ts not know,t. the soils cannot be
considered RCRA hazardous waste.f unless tt, 'y exlu"'9it '. nc I more of the characteristics of hazardous ""' . . warn~ ... ,. ,
303961.\
I •.
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9! I . I
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I . ' I. PROTQCOl. FOR 0£TER!\11NlNG W11t·1·H~K A.t..-rt.RNA1'£ FEED MAT£RfAl.S ARE LJSTED HAZARDOUS WASTES
• lftho Material is a process waste:~d iij known to be a listed hazardous
waste or to be mixed with a listed bazatdous waste (Step 6),
13.
14.
30)961 .I
• If Potentially Listed Waste~! wte lmown to be aetually
generated/managed at the Site and to t•e disposed of/commingled with
the Material (Step 10) (subject to a ,Ji:omained~ut" determination in
Step 13), or :: !'
• If Potentially Listed Wastes· w "e known to be a6l11ally
generated/managed at the Site, we4+ not known to be disposed
of/conuningled with the Material but there are not any potential non-
1 tsted sources of the Potentially tisted Hazardous Constituents
detected in the Material (Step ll) '(subject to a ''contained-out''
determination in Step 13).
Proceed to Step J 3.
HAS STATE 011' UTAH MADE A CONT~r-OUT DETERMINATION.
If the Material is an Environmental Mcdiumt .and; I;
• the level of any listed waste constituents in the Material is "de minimis,' ; or
• all of the listed waste constituents or Jasses tnereof arc already present in the
White Mesa MilPs tailings ponds as ];result of processing conventional ores
or other alternate feed materials in codcentrations at least as high as found in
the Materials I
the State of Utah will consider whether it is
1
nppropriate to make a contai1ted-out
determination with respect to the Material
Q'the State mahs a co11tained-01,t detennination, f~oceed to Step 16.
If tlie State does not make a contained-out detenn · ,1atlo11, proceed to Step 14.
' I .. ' IS IT POSSIBLE TO SEGREGATE LISTED ZARDOUS WASTES
FROM OTHER MATERIALS?
Determine whether there is a reasonable way o segregate material that is a listed
hazardous wasle from alternate feed materials th : t are not listed hazardous wastes that
will be sent to IUSA"s White Mesa Mill. For lxample, it may be possible to isolate
material from a certain area of a remediation site atd exclude that material from Materials
10
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Plto·rocoL. FOR O&TF.RMINlNG Wt1ETHEK ALTE1t."4A'I'£ FEED MA1"('£RI/\I .. S ARE LISTED HAZARDOUS WASTis
: I
that will be sent to the White Mesa Mill. >Jtte atively, it may be possible to incl'ease
sampling frequency and exclude materials wi:tb. f.pspcct to which the increased sampling
identifies constituents which have been attribJte1ito listed hazardous waste.
15.
16.
17.
303C/61.I
I I
If yes, proceed to Step 15. ! I
If 110, proceed to Slep 11. ! I'
SEPARATE LISTED HAZARDOUS WAS~E! FROM MATERIALS.
I I! Based on the method of segregation detennh_l.ed pnder Step 14, materials that are listed
hazardous wastes are separated from Materials tb'l will be sent to the White Mesa Mill
I •.•
For materials that ore listed hazardous wast~, ptoceed to Step 12.
For Materials to be .vent to the 'White Mesa MiJl, J/roceed to Step 16.
i Ii
PROVIDE IN.FORMATION TO NRC AND Ol'AH.
If the Material docs not contain any Pote~tia-~ly Listcd Hazardous Constituents (as
dctennined in Step 7), where information c~nCF,ming the source of Potentially Listed
Hazardous Coustitucnts in the Material is .. unavailable or jnconclusivc" (as determined in
Steps 8 thcough 11), or where the State of Uiah r,u made a contained-out determination
with respect to the Material (Step 13), the Material will be assumed not to be (or contain)
a listed hazardous waste. 1n such circ~tarices, 1USA will submit the following
docwnentation to NRC and the State: l l:
• L
• A description of the Source fnvestigat~n;
• An explanation of why the MateriaJ is!~ot a listed hazardous waste.
I l.
• Where applicable, an explanation ofi why Confirmation/Acceptance
Sampling has been detennined notjto fie necessary in Step 17.
• If Confumadon/ Acceptance Sampling! has been determined necessary I .,. in Step 17 • a copy of IUSA's and,;the Generator's Sampling and
Analysis Plans. I f!
• A copy of Confinnatiou and ! AJccptance Sampling results, if
applicable. RJSA will submit tht;Se [results only if they identify the
presence of .. new'' Potentially l}i$t~ Haurdous Constituents (as
defined in Steps 7 and 8). ! l I . Proceed to Step 17. I i
ARE SAMPLING RESULTS OR DATA Rb.p I· SENTATIVE? ~T II Det-ennine whether tho sampling results or d,a from tbc Source Investigation (or, where
applicable, Confinnalion/Accoptancc Samp~lg rlta) a<e representative. n,., puq,ose
11 I
I I !
·!
" .
Pl\OTOCOL FOR 0ET£RMININC WHETHERALTtRNATF.: FF.ED 1¥(,\T~l\f,\l,.t; ARP. L15T£D 6/\l.AROOUS W..UTD
' I :I :
)03961.1
. . !I :
of t~tls step ) is to_ detem1ine whether q;on?~ation and Acceptance S~pling (or
contmued Conflnnanon and Acceptance SaJJiiplmg) are necessary. If the sampling results
or data are representative of all Material destined! for the White Mesa Mill, based on the
extent of sampling conducted, the nature of the! Material and/or the nature of the Site
(e.g., whether chemical operations or waste1~sposal were known to be conducted at the
Site), future Confirmation/Acceptance Sampling ~ill not be necessary. If the sampling
results are not representative of all Materihl desti(led for the White Mesa Mill, then
additional Confumation/ Acceptance samplihg rriay be appropriate. Confirmation and
Acceptance Sampling will be required o;ty irhcre it is reasonable to expect lhat
additional sampling will detect additionan contaminants not already detected. For
example: ii !
• Where the Material is segreg~ted µ-om Environmental Media, e.g.. the
Material is containerized. there i~ a tygh probability the sampling results or
data from. the Sour~ Investiga.~ion l)ro representative of the Material and
Confinnat1on/ Acceptance Samplihg would not be required.
• Where IUSA will be;accepting JaterilJ from a discrete portion of a Site, e.g.,
a storage pile or other defined ax'fa. abd adequate sampling characterized the
area of concern for radioactive and o~emical contaminants, the sampling for
that area would be considered rlepresentatlve and Confirmation/Acceptance
sampling would not be required. ·i I
• ~c Material will be ~eceived'I fro~· a ~dct area o,f a Site and 'th~ Site ~s
been carefully charactcnzed forl rad1oactivc eontamuwit$1 but not chenucal
contaminants, Confumation/ Acc~tanJe sampling would be rv.quired.
• Where the Site was not used for ~ndudtriat activity or disposal before or 41fter
uranium material disposal, and tlie Site has been adequately characterized. for
radioactive and chemical cont~ts, the existi11g sampling would be
considered sufficient and Confit· atitnl Accq>tance sampling would not be
required.
• Where listed wastes were known beJdisposed of on the Site and the limits of
the area where listed w~stes I were managed is not known,
Confirmation/Acceptance sampli:ng ~ould be required to ensure that listed
wastes are not !ihipped to IUSA (see Step 14). I I
ff yes, proceed to Step 4. :I !
If no, proceed to Step J 8. ·
!
I
1 ;
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l .
.PROTOCOL. fO"-DETtRMININC WHETHER AL TEP.NATE FEED MA'l'RRIALS AR.E LISTED HAZARl>OUS WAS TES
18. DOES S1ATE OF UTAH AGREE THAT ~L PREVIOUS STEPS HAVE
BEEN PERFORMED IN ACCORDANCE,WITH THIS PROTOCOL?
Detennine whether the State agrees that this Protocol has been properly followed
(including that proper decisions were madd at each decision point). The State shaU
review the infom1ation provided by nJSA in ;Step 16 prempt,ly with reasonable speed and
advise IUSA if it believes IUSA has not prdperly followed this Protocol in determining
that the Material is not listed hazardous ;waste, specifying the particular areas of
deficiency. I
If th.is Protocol has not been properly follow~ by IUSA in making its determination that
the Material is nt,,t a listed hazardous w~te. then IDSA shall redo its analysis in
accotdanco with this Protocol and, ifjustifie4, resubmit the i1lfoonation descnoed in Step
16 explaining why the 'Material is not a listed hazardous waste. The St.i-o .shall notify
IUSA l'f8!flPl1Y with reasonable speed if the State stUl believes this })rotocol has not becu
followed.
If yes, proceed to Step 19.
If 110, proceed to Step 1.
19. MATERIAL IS NOT A LISTED HAZARDOUS WASTE, BUT i CONF.mMATION AND ACCEPTANCE SAMPLING ARE REQUIRED.
The Material is not a listed hazardous wastc.lbut Coafumation and Acccptanc~ Sampling
are required, as determined necessary under ~tep 17.
Proceed to Step 20. /
I
20. CONDUCT ONGOING CONFIRMATION AND ACCEPTANCE
SAMPLING.
Confumation and Acceptance Sampling will continue until detennined no longer
necessary under Step 17. Such sampling will be conducted pursuant to a Sampling and
Analysis Plan ('"SAP") that specifies the fr~uency and type of sampling required. If
such sampling does not re\leal any "new•• '.Pbtentially Listed Hazardous Constituents (as
defined in Steps 7 and 8), further cvaluatioJ is not necessary (as indicated in Step 7). If
such sampling reveals the prcsco.cc of"new''; constituents, Potentially Listed Wastes must
be identified (Step 8) and evaluated (Steps 9 through 11) to determine whether the new
constituent is from a listed hazardous waste ~ource. Gcncntlly, in each CMC, the SAP will
specify sampling comparable to the l~el ~d frequency of flampling perfonned by other
facilities in the State of ~tab that d~pose ofj 11~.(2) byproduct material, either directly or
that results fi'otn processing altemate feed tnatenafs. !
PrQCeed to Step 7. .:
I
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' ., I
I Attachment 1 I
Summary ofR.CRA Listed Hazardous Wastes I I I
I There are three different categories of listed !1azardous waste under RCRA:
I
• F-listed wastes from ,ion-specific sources (40 CFR § 261.3l(a)): These wastes
include spent solvents (F001-F005), sp~cified wastes from electroplating operations
(F006-F009), specified wastes from O?-etal heat treating operations (FOLO-FOl2),
specified wastes from chemical 'conv~rsion coating of aluminum (FOI 9), wastes from
the, production/manufacturing of spc~ified chlorophenols, chlorobenzenes, and
chlorinated aliphatic hydrocarbons (FO l 9-F028), specified wastes from wood
preserving processes (F032-F035), specified wastes lron1 petroleum refinery primary
and secondary oil/water/solids separation sludge (F037-F038), and leachate resulting
from the disposal of more than one Jistc~ hazardous waste (F039).
• K-listed waszes from specljlc sources (40 CFR § 261.32): These include specified
wastes from wood preservation, inorghnic pigment production. organic chemical
production, chlorine production, pesticiae production, petroleum refining, iron and
steel production, copper production, primary and secondary lead smelting, primary
zinc production, primary alwoinwn reduction. fcnoalloy production. veterinaxy
pnarmaceutical production, ink fonnulatjon and coking.
• p. and U-/isted commercial chemical p,roducts (40 CFR § 261.33); These include
commercial chemical products, or manufacturing chemical intennediates having the
generic name listed in the "P" or ••v• lii;t of wastes, container residues, and residues
in soil or debris resulting ft0m a spill o'f these materials.• ··nte phrase 'commercial
chemical product or manufacturing chemical intermediate ... • refers to a chemical
substance which is manufactured or formulated for conunercial or manufacturing use
which consists of the commercially pure grade of the chemical, any technical grades
of the chemical that are produced or marketed, and all fonnulations in which the
chemical is the sole active ingredient. . It does not refer to a material, such as a.
manufacturing process waste. that contains any of the [P-or U-listed substances]. "1
Appendix VIl to 40 CFR part 261 identifies the hazardous constituents for which the F-and K-
listed wastes were listed. · ·
..
'I
I
1 P-listed wastes are identified as "acutely hazardous wastes'' and are subject to additional management
controls under RCRA. 40 CFR § 261 .33(e) {1997). {!1listed wastes are identified as "toxic wastes.~ kl,
§ 261.JJ(f). ; I •
2 40 CFR § 261.JJ(d) note (1997).
Protocol for Determining if Alternate l Jd Material is a Usfed Hazardous Vvaste
8
I -!.,..s It.JI! K>N s
'·.. 11• 11•1 ~1 :t•SW.lll""
'.11 .. t9l•t••.:t9t'•.;r1
...
~a,.11ce ~~lot'
I•! <J-ot,10,:, l,:,.;a;s,
Ill e,ntirq '7,1'?<'.C,
~OI
Cl~ CO'npQS lr.:.-
ln'o,rr,cllcl\ CII S."JJl"-
olnp r.toto lf-::m
Ql_"(iad,;,1
JI I J!._ !I iC.flt• I~ l,:a.J t1"-"h:.:"d p~j ~=-
L•' •"~(.J(~l '.tJtlitt• :A!'!O U,l
:,,.--., • v\ !ic> ·~•?S ~ r~· E»:O-"U".or• .:.<
t•••(t\0,1r.rl.
• rr ·a.· Dlc,wlde to Noc: ardcl 1'd-c
• S1
• Alfldo',-i tiy ~JSA u Gtnelclor
e,oloirii'lg 'M1r noS Md >I"/ II 'b. • P'(llllde lo 1GC c:nd.'cr Uart:
• L'Xu.-nen'1:01 llait regiJl:Jby
OlAtloflv
" , , ~'"' , ,. Sr..,... · Ui:•:," ,cr..e,;11 QI .:.NII! t.191> I.Iii
~-"'J" • ... , , 1•!u..,1AAr•:"t~I IJ•t
,., •n1:t11t, 1:,1,;-JJDn:x,..s.t;..c~.,., ~
h;U'•H• «) l:1117-'l.llpl: 'l!I QI ~tlDIGft;, ldrg
r, 11r~ ,..~•11, a, in 40 r>A 161.JJl,!I Q 111 (P
t ... 11 ""'as•sl
r, .tr,,i,:,1, , g"'<J1ilrBfer ·• Ji:1.."0ldou. ~ -.tildl oe ,.-,,,.t h nn; o1 ft>~ li;luO llar:, rir:ru! Ce,~'I
,~.,.,m1,ir-e1Jct.eo(bf~,;,. cenlllrnlD•
·'ll A• rep:wt.-:,r, S.-.,.-C:,:nr( GS ainll«f'II .t0 Oil
7~ I •°U1Y.l ,,r1,QC.H1'111 33fl!!•:t (II.
r ..... 1 .. a,-,. -r,illely~pry•bu ac.. ttwts:.11.arn....,..jC:l'I
~ .. ,. ,t.,wto {l' • tlP.«.
l ._..,., ,,.-.. ,ut."ifd.1..: "''"'"' M,etu-ds....,c1n•.?tU
-~
~ ftJ 11K: o-d'or ~
• SI
• Elip"onohl ""nos r~
• S,,h,CIA)!cci>~J
• ~Acce,ploru
hT'c>'ll,g Ra,111 ~ oppllco-
bl!II
\'ES
NO
II -cGlldii:t ong<*lg I
Conlllmoion O"ld
Acceptance
Scmpfir,g end use
19SU'ils roceer.i'uola
\<ffl81hel Maetl:J:S
oc Isled haroldous
~
S.,.019 llshd
Holorc·::1.~ \\'osleS I J4W fen> [jlt',21 t.t:,ie,;.::>'i
Technical Memorandum
To: David C. Frydenlund From: Jo Ann Tischler
Company: Energy Fuels Resources (USA), Inc. Date: July 27, 2019
Re: Review of Chemical Contaminants in Union
Pacific Uranium Material to Determine the
Potential Presence of RCRA Characteristic or
RCRA Listed Hazardous Waste
CC:
1.0 Introduction
This report summarizes the characterization of the Union Pacific Railroad ("UPRR") Moffat
Tunnel Uranium Material (the "Uranium Material"), also referred to as the "centrifuge cake" or
"centrifuge solids" to determine whether or not the Uranium Material is or contains any listed or
characteristic hazardous waste as defined by the Resource Conservation and Recovery Act
("RCRA"). The results of this characterization will provide information for Energy Fuels
Resources (USA), Inc. ("EFRI") to determine the requirements necessary for an amendment to its
White Mesa Uranium Mill ("Mill") State of Utah Radioactive Materials License No. UT1900479
(the "License") to permit the processing of the Uranium Material as an alternate feed material at
the Mill.
In accordance with the definitions in the Atomic Energy Act, as amended, and 10 Code of Federal
Regulations ("CFR") 40.4, ores with natural uranium content of 0.05 weight percent or higher are
classified as source material and, as per 40 CFR Part 261.4, are exempt from regulation under
RCRA. As summarized in the Radioactive Material Profile Record ("RMPR"), the Uranium
Material has a uranium content of approximately 0.45 to 0.49 dry weight percent natural
uranium (0.53 to 0.58 dry weight percent U30s). This Uranium Material is therefore source
material, and is categorically exempt from RCRA.
Although the Uranium Material is exempt from regulation under RCRA, EFRI nonetheless
requires a due diligence evaluation of potential materials to be processed, to assess:
1. Whether the material is, or contains, any hazardous constituents that would be regulated
as RCRA listed hazardous waste, if the Uranium Material were not categorically exempt
from RCRA as a uranium ore or 1 le.(2) byproduct material or a categorically exempt
solid waste.
2. Whether the material contains any constituents that could generate a worker safety or
environmental hazard under the conditions under which it will be processed at the Mill.
3. Whether the material contains any constituents that would be incompatible with the
Mill's tailings management system.
1
This memorandum provides the evaluation of the regulatory status of the Uranium Material
relative to RCRA. Evaluation of potential safety and environmental hazards, and compatibility
with the Mill's tailings management system are provided in a separate memorandum.
2.0 Site History and Background
The Uranium Material was generated by treatment of groundwater from dewatering of the Moffat
railroad tunnel ("Moffat Tunnel"). The groundwater contains naturally occurring radioactive
material ("NORM") from contact with native rock, and picks up inorganic solids particles as it
passes through the tunnel. As a result, the groundwater requires treatment to meet Colorado
Department of Public Health and Environment ("CDPHE") discharge standards prior to release to
the Fraser River.
Groundwater is pumped from the Moffat Tunnel at approximately 200 gallons per minute
("gpm") for dewatering. Prior to discharge of the pumped water to surface receiving waters, it is
pre-treated by an ultrafiltration and centrifugation system to meet CDPHE standards for
radionuclides and inorganic constituents.
The Uranium Material was generated from a continuous process, as described below, driven by
the requirement to achieve discharge permit limits in the water released from the water treatment
plant ("WTP") to the Fraser River. No other water sources or wastes are treated in the WTP.
The Uranium Material is comprised only of the centrifuged solids. No other materials or wastes
are added to the Uranium Material. The Uranium Material contains approximately 75-90%
moisture content and 0.13-0.14% natural uranium on a wet basis or up to 0.49% natural uranium
on a dry basis.
A chronology of the site history is listed below.
2008 to 2016
2017
2017
2017 through 2018
2018
2019
2019
Moffat Tunnel water characterization sampling
Treatment plant constructed
Beginning of dewatering and treatment
Centrifuge solids (Uranium Material) was collected in shipping
containers and disposed at off site waste management locations
UPRR submits application for CDPHE radiological materials license for
Uranium Material
Centrifuge solids are drummed for eventual transfer to EFRI
Anticipated receipt of CDPHE license for Uranium Material
NRC' s Alternate Feed Guidance currently provides that if a proposed feed material contains
hazardous waste, listed under Section 261.30-33, Subpart D, of 40 CPR (or comparable RCRA
authorized State regulations), it would be subject to EPA (or State) regulation under RCRA.
However, the Guidance provides that if the licensee can show that the proposed feed material
does not consist of a listed hazardous waste, this issue is resolved. NRC guidance further states
that feed material exhibiting only a characteristic of hazardous waste (ignitability, corrosivity,
reactivity, toxicity) that is being recycled, would not be regulated as hazardous waste and could
therefore be approved for extraction of source material. The Alternate Feed Guidance concludes
that if the feed material contains a listed hazardous waste, the licensee can process it only if it
obtains EPA (or State) approval and provides the necessary documentation to that effect. The
Alternate Feed Guidance also states that NRC staff may consult with EPA (or the State) before
making a determination on whether the feed material contains listed hazardous waste.
2
Subsequent to the date of publication of the Alternate Feed Guidance, NRC recognized that,
because alternate feed materials that meet the requirements specified in the Alternate Feed
Guidance must be ores, any alternate feed materials that contain greater than 0.05% source
material are considered source material under the definition of source material in 10 CPR 40.4
and hence exempt from the requirements of RCRA under 40 CPR 261.4(a)(4). See Technical
Evaluation Report Request to Receive and Process Molycorp Site Material issued by the NRC on
December 3, 2001 (the "Molycorp TER"). As a result, any such alternate feed ores are exempt
from RCRA, regardless of whether they would otherwise have been considered to contain listed
or characteristic hazardous· wastes. Since the Uranium Material contains greater than 0.05%
source material, it is exempt from RCRA, regardless of its process history or constituents, and no
further RCRA analysis is required. Further, the Uranium Material has been classified as 1 le.(2)
byproduct material by NRC under 40 CPR 261.4(a)(4). lle.(2) byproduct material is exempt
from RCRA, and for this reason also the Uranium Material is exempt from RCRA.
Nevertheless, because the Alternate Feed Guidance has not yet been revised to reflect this
position recognized by NRC in the Molycorp TER, the remainder of this memorandum will
demonstrate that, even if the Uranium Material were not considered source material or 1 le.(2)
byproduct material, and as such exempt from RCRA, the Uranium Material would not, in any
event, contain any RCRA listed hazardous wastes, as required under the Alternate Feed Guidance
as currently worded.
2.1 Description of Process Which Generated the Uranium Material
The Uranium Material consists of the centrifuge solids from the WTP, as described below.
Upon entering the treatment plant, the groundwater from tunnel dewatering is treated first by the
addition of a coagulant, Calchem CC2000 aluminum chlorohydrate, followed by direct filtration
in an ultrafiltration membrane system. Backwash water from the ultrafiltration membrane system
containing coagulated solids is pumped through a dissolved air flotation system where a very
small amount of 7th generation dish soap ( <0.001 % by volume) is added to assist in thickening of
the solids via flotation. The thickened solids are further dewatered using a centrifuge. A small
amount of Zetag 120L polymer, <0.001 % by volume, is added to the thickened solids before the
solids enter the centrifuge.
During major construction, e.g. rail extension or tunnel expansion, an additional settjng step is
added upstream of the treatment plant. Settling tanks are used in this situation to settle
construction related particulate matter. No other treatment chemicals are added.
Per the process description provided by UPRR for production of the centrifuge cake, the chemical
reagents used in the above processes included:
• Calchem CC2000 Aluminum chlorohydrate used as coagulant
• Seventh Generation dish soap used as a thickener for flotation
• Zetag 120L hydrocarbon polymer to enhance centrifugation
The presence of residuals or reaction byproducts from these compounds would be expected in the
Uranium Material, as discussed in the sections below.
Schematic flow sheets depicting the process which produced the Uranium Material during normal
operations and construction periods, are provided in Figures 1 and 2.
3
3.0 Basis and limitations of this Evaluation
The Uranium Material to be processed at the EFRI White Mesa Mill consists solely of the
centrifuged solids from the WTP.
Physical and chemical analyses have been performed at different times to characterize the raw
water to be treated, to evaluate performance of the WTP, or to characterize the centrifuge solids
for off site management.
For development of treatment requirements prior to WTP construction, raw water from the
Moffat Tunnel West Portal was analyzed quarterly from 2008 through 2016 for metals and other
inorganic parameters.
Centrifuge solids, as well as intermediate streams in the WTP, were analyzed for a limited
number of organic and inorganic parameters during the WTP startup period in 2017.
Subsequent to discussions with EFRI in 2018, UPRR collected additional samples which were
analyzed for a full suite of parameters by a Utah certified laboratory. UPRR collected a first
sample representing short term centrifuge performance and Uranium Material composition by
sampling centrifuge cake from one day's operation. Four additional samples were collected over
a two week period of operation, and composited, to represent Uranium Material composition over
time.
The evaluations are summarized in the table below.
Summary of UPRR Moffat Analyses
Sample Sampling/ Analysis Analyses Number of
Name/Laboratory Date(s) Composite
Samples
American West June 2018 VOCs, SVOCs, 1 random sample
Analytical Laboratories pesticides, herbicides, accumulated over
Centrifuge Cake TCLP (metals and one day's run, and
Characterization organics), major ions, 1 composite of 4
total metals, ammonia additional samples
and nitrate N, over two weeks
radionuclides run.
WTP Startup Solids April 2017 Total metals, TCLP Approximately 10
Characterization metals, TCLP samples from
organics throughout the
WTP. (Not every
sample was
analyzed for every
parameter)
Moffat Tunnel West 2008 through 2016 Major ions, dissolved 119 (not every
Portal Raw Water metals, total metals, sample was
Monitoring cyanide, uranium analyzed for every
parameter)
4
As discussed in Section 2.0, above, the Uranium Material contains greater than 0.05% source
material, and is exempt from RCRA, regardless of its process history or chemical composition,
and no further RCRA analysis is required. The following evaluation of characterization data is
provided to demonstrate that even if the Uranium Material were not categorically exempt from
RCRA, it is not and does not contain RCRA listed hazardous waste.
The sampling was representative of a continuous process stream under the control of the
generator from a process which did not vary appreciably over time.
The various analyses addressed a full range of volatile organic compounds ("VOCs"),
semivolatile organic compounds ("SVOCs'), pesticides, arochlors and other compounds that
could potentially have reached groundwater, or centrifuge solids, from natural and man-made
sources. Analyses provided with the RMPR were performed by laboratories possessing State of
Utah and/or NELAC certification for the analyses performed. As a result, these studies provide
sufficiently representative characterization to assess the regulatory status, worker safety
environmental hazards, and chemical and processing properties of the Uranium Material.
The following RCRA evaluation is based on information from the following sources:
1. Current Moffat Uranium Material analytical data 2018
2. TestAmerica analyses April 2017
3. Raw water influent data provided by UPRR for sampling from 2008 through 2016
4. Material Safety Information Sheet for Insoluble Mineral Fraction provided by UPRR,
2019
5. Correspondence and discussion with UPRR personnel throughout 2018 and 2019.
6. EFRI Protocol for Determining Whether Alternate Feeds Are Listed Hazardous Wastes
(EFRI, November 1999).
7. RMPR for the UPRR Uranium Material (March 2019).
8. Basis of Hazardous Material and Waste Determinations from the RMPR (March 2019)
9. Affidavit of Steven L. Preston UPRR Environmental Field Operations Manager (April 2,
2019).
EFRI has developed a "Protocol for Determining Whether Alternate Feed Materials are Listed
Hazardous Wastes" (November 22, 1999) ("the Protocol"). The Protocol has been developed in
conjunction with, and accepted by, the State of Utah Department of Environmental Quality
("UDEQ") (Letter of December 7, 1999). Copies of the Protocol and UDEQ letter are provided
in Attachment 2 of this Report. The RCRA evaluation and recommendations in this Report were
developed in accordance with the Protocol.
4.0 Application of Protocol to Uranium Material
4.1 Source Investigation
Several of the information sources enumerated above were used to perform the Source
Investigation indicated in Box 1 of the flow diagram (the "Protocol Diagram") that forms part of
the Protocol.
The following sections describe the status of the Uranium Material relative to RCRA
Characteristic and RCRA Listed Hazardous Waste regulations, and relative to the specific
parameters identified in the EFRI/UDEQ Hazardous Waste Protocol. Although alternate feed
materials are being recycled to recover uranium and hence are permitted to contain constituents
5
that may be considered RCRA characteristic wastes in other circumstances, for completeness, this
Report also determines whether or not the Uranium Material contains any such constituents.
4.2 Determination Methods in the EFRI / UDEQ Protocol
4.2.1 Regulatory History of the UPRR Uraniwn Material
Prior to 2019, UPRR disposed of the centrifuge solids in off-site solid waste disposal
facilities licensed for the disposal of NORM material. In 2018 CDPHE required that
UPRR apply for a CDPHE radioactive material license. UPRR has applied for the
license, which is expected to be in place in 2019, prior to shipment of any Uranium
Material to EFRI.
The Uranium Material, which has materially not changed in form or content since first being
produced in 2017, remains definitional source material as per 40 CFR Part 261.4, and is explicitly
exempt from regulation under RCRA. However, for the sake of completeness, EFRI has required
the following evaluation to confirm that even if the Uranium Material were not exempt from
RCRA, it is not and does not contain, what would otherwise be considered a RCRA-listed waste,
or a RCRA characteristic waste.
The Uranium Material has not been classified or treated as listed hazardous waste nor has it been
in contact with any listed hazardous wastes.
4.2.2 Evaluation of Potential RCRA Listin~ Associated with Specific Contaminants
For potential aJternate feeds that are not exempt from RCRA, the Protocol describes additional
steps EFRI will take to assess whether contaminants associated with any potential RCRA waste
listings are present, and the likelihood that they resulted from RCRA listed hazardous wastes or
RCRA listed processes. These steps include tabulation of all potential listings associated with
each known chemical contaminant in the material, and the review of chemical process and
material/waste handling history at the site to assess whether the known chemical contaminants in
the material resulted from listed or non-listed sources. This evaluation is described in Box 8 and
Decision Diamonds 9 through 11 in the Protocol Diagram.
If the results of the evaluation indicate that the contaminants are not listed waste, the Protocol
specifies an additional assessment of whether the data on which this determination was made is
sufficiently representative, or whether an ongoing acceptance sampling program should be
implemented, and a similar evaluation performed on any new constituents identified during
acceptance sampling.
In the case of the Uranium Material, Steps 9 through 11 are not required as indicated by the
statements provided in the Affidavit of Steven Preston of UPRR. However, for the sake of a
thorough due diligence evaluation, Steps 9 through 11 were completed, and the results are
presented below.
4.0 RCRA Review of Chemical Constituents
Determination of whether the Uranium Material is, or contained, potential RCRA-listed waste
included consideration of source history provided by UPRR, and through communications with
6
UPRR personnel and contractor personnel from January 2018 to date, as well as the analytical
efforts summarized in Section 3.0 above.
4.1 Overview
As discussed below, the components of the Uranium Material result either form naturally-
occurring constituents of the influent water to the WTP, or from the non-hazardous treatment
agents added in the WTP which produced the centrifuge solids/Uranium Material.
The Uranium Material does not contain any "P" or "U" listed wastes as it contains no discarded
commercial chemical products, off-specification species, container residues, and spill residues
thereof. Any chemicals used in the WTP which generated the Uranium Material were used for
their intended purpose and are not waste materials. None of the chemicals used in treatment
were associated RCRA hazardous wastes.
There were no processes conducted at the site which fall under the category of "F" listed
hazardous wastes from non-specific sources as designated in the following seven categories:
• Spent solvent wastes (FOOi-FOOS)
• Wastes from electroplating and other metal finishing operations (F006-F012, F019)
• Dioxin-bearing wastes (F020-F023 and F026-F028)
• Wastes from the production of certain chlorinated aliphatic hydrocarbons (F024, F025)
• Wastes from wood preserving (F032, F034, and F035)
• Petroleum refinery wastewater treatment sludges (F037 and F038)
• Multi-source leachate (F039)
There were no processes conducted at the site which fall under the category of "K" listed
hazardous wastes from specific sources designated in the following 13 categories:
• Wood preservation (KOOl)
• Inorganic pigment manufacturing (K002 -K008)
• Organic chemicals manufacturing (K009-K030, K083, K085, K093-K096, KI03-Kl05,
KI07-K118, K136, Kl49-K151, K156-Kl59, K161, Kl74-K175, Kl81)
• Inorganic chemicals manufacturing (K071, K073, KI06, Kl 76-178)
• Pesticides manufacturing (K031-K043, K097-K099, Kl23-Kl26, Kl31-K132)
• Explosives manufacturing (K044-K047)
• Petroleum refining (K048-52, Kl 70-Kl 72)
• Iron and steel production (K061-K062)
• Primary aluminum production (K088)
• Secondary lead production (K069, K 100)
• Veterinary pharmaceuticals manufacturing (K084, K101-K102)
• Ink formulation (K086)
• Coking (K060, K087, K141-K145, Kl47-K148)
Evaluation of RCRA listings associated with the inorganic ions and metals analyzed in the
Uranium Material is provided in attached Tables 1 and 2 respectively. The single SVOC
identified in one of the two samples analyzed, is evaluated in Table 3.
7
4.2 Volatile Organic Compounds
The Uranium Material consists of solid residuals, centrifuge cake, from treatment of groundwater
from tunnel dewatering. No voes were used in the treatment unit. No voes would be
anticipated, and none were detected, in the Uranium Material.
43 Semivolatile Organic Compounds
One SVOe, fluoranthene, was detected in one of the two samples of the centrifuge solids. The
ReRA listings associated with fluoranthene, KOOl, K022 and K035 apply to fluoranthene from
wood treating, creosote manufacture, coking, or phenol/acetone production. As mentioned above,
none of these processes were conducted on the WTP site. Fluoranthene is a common multi-ring
asphaltic compound present in paving materials, roadbeds, roofing material and other common
construction materials and may have been introduced from one of these sources. Alternatively
the compound may have been introduced with the naphthenic distillates added before
centrifugation. .
The single potential ReRA listing associated with the fluoranthene, which is not applicable to the
Uranium Material, is documented in attached Table 3.
4.4 Non-Metal Inorganic Compounds
AW AL analytical results in the Uranium Material indicate that low levels of ammonia as nitrogen
("ammonia as N"), chloride, fluoride, and sulfate are present in the Uranium Material. Moffat
Tunnel raw water analyses indicate that each of these analytes, except ammonia as N, is present
in the raw water influent to the WTP. Nitrate/nitrite nitrogen was analyzed and not detected in the
Uranium Material.
Ammonia as N was introduced with the non-hazardous dish detergent used as a thickener in the
dissolved air flotation step. Neither the detergent nor the process are associated with any ReRA
hazardous waste listings. Evaluation of potential ReRA listings associated with the remaining
inorganic analytes, and why they are not applicable to the Uranium Material, is provided in detail
in the attached Table 1.
Inorganic nitrate/nitrite and inorganic ammonia nitrogen have also been analyzed in the raw water
influent samples, but not detected in the Uranium Material. Inorganic nitrate/nitrite compounds
and inorganic ammonia nitrogen are not associated with any ReRA hazardous waste listings,
therefore, these analytes have not been included in Table 1.
4.5 Metals
Analytical results indicate that the metals aluminum, arsenic, barium, calcium, cobalt, copper,
iron, lead, magnesium, manganese, mercury, molybdenum, nickel, potassium, sodium, vanadium,
and zinc were present in the Uranium Material.
No ReRA listings are associated with cobalt, iron, magnesium, or molybdenum. Evaluation of
potential ReRA listings associated with the remainder of the analyzed metals, and why they are
not applicable to the Uranium Material, is provided in detail in the attached Table 2.
8
4.6 Summary of RCRA Listed Waste Findings
Based on the information presented above, none of the constituents in the Uranium Material
would be indicative of RCRA listed hazardous waste, even if the Uranium Material were not
already exempt from RCRA as source material. Review of the analytical data, the, process
history, and raw water characterization confirms that all of the constituents in the material are
consistent with those expected to result from the WTP described in Section 2.0
5.0 RCRA Characteristics
The Uranium Material is a centrifuged dewatered moist solids from inorganic groundwater
treatment. As a result it would not be ignitable, corrosive, or reactive per the RCRA definitions
of these characteristics. A Uranium Material sample collected during 2017 was analyzed for
eight RCRA TCLP metals and 31 RCRA TCLP organic compounds. Two Uranium Material
samples collected during 2018 were also analyzed for eight RCRA TCLP metals and 8 RCRA
TCLP organic compounds. In all samples collected over both sampling events, no analyzed
constituent exceeded its respective TCLP threshold for RCRA toxicity characteristic as defined in
Table 1 of 40 CFR Part 261.24(b). Therefore, the test results confirm that that the Uranium
Material does not have the RCRA characteristic of toxicity. These results are summarized in the
attached Table 4.
Two Uranium Material samples collected during 2018 were tested for corrosivity. No samples
exhibited a pH of 2.0 or lower, or a pH of 12.5 or higher. These results confirm that the Uranium
Material does not have the RCRA characteristic of corrosivity.
The Uranium is not an oxidizer, an ignitable compressed gas, or a solid that can cause a fire and
sustain combustion. In addition, two samples of Uranium Material collected during 2018 were
tested for flash point. The sample did not exhibit a flash point of <140°F. These results confirm
that the Uranium Material does not have the RCRA characteristic of ignitability.
The Affidavit from Steven Preston of UPRR affirms that the Uranium Material has never been
classified for shipment or off-site management as a RCRA characteristic waste. This is consistent
with the source of the constituents and the WTP that produced the Uranium Material.
As discussed in the introduction to this report, the Uranium Material is exempt from regulation
under RCRA; however, even if it were classified as a characteristic hazardous waste, alternate
feed materials are permitted to contain RCRA characteristic wastes under NRC' s Alternate Feed
Guidance (10 CFR 40, Appendix A).
Based on all of the above information, the Uranium Material is not a RCRA characteristic
hazardous waste.
6.0 Conclusions and Recommendations
In summary, the following conclusions can be drawn from the RCRA analysis of the analytical
data and information presented above:
1. The Uranium Material is not a RCRA listed hazardous waste because it is an ore that has
a natural uranium content of greater than 0.05 weight percent, is therefore source material
and, as a result, is exempt from regulation under RCRA.
9
2. Even if the Uranium Material were not source material, it would not be a RCRA listed
hazardous waste for the following additional reasons:
a) It was generated from a known process under the control of the generator, who has
provided the Affidavit declaring that the Uranium Material is not and does not
contain RCRA listed hazardous waste. This determination is consistent with Boxes I
and 2 and Decision Diamonds 1 and 2 in the EFRI/UDEQ Protocol Diagram;
b) No VOCs are used in the water treatment process that produced the centrifuge solids,
and no volatile organic compounds can be expected to be present in the Uranium
Material.
c) No SVOCs are used in the inorganic mineral process that produced the centrifuge
solids. One semi-volatile organic compound was detected in one sample, and not in
the second sample. The compound does not result form a RCRA listed waste source.
d) None of the metals in the Uranium Material samples came from RCRA listed
hazardous waste sources. This determination is consistent with Box 8 and Decision
Diamonds 9 through 11 in the EFRI/UDEQ Protocol Diagram.
3. The Uranium Material does not exhibit any of the RCRA characteristics of ignitability,
corrosivity, reactivity, or toxicity for any constituent.
10
8.0 References
• Austin, G.T. Shreve's Chemical Process Industries, Fifth Edition. McGraw Hill. New
York 1984.
• Title 10 Code of Federal Regulations; Chapter I -Nuclear Regulatory Commission, Part
40-Domestic Licensing of Source Material: 40.4 -Definitions (10 CFR 40.4)
• Title 40 Code of Federal Regulations; Protection of the Environment, Part 261 -
Identification and Listing of Hazardous Waste: Subpart A, 261.4 -Exclusions: Subpart B
-Criteria for Identifying the Characteristics of Hazardous Waste and for Listing
Hazardous Waste.
• Sax, N. Irving and Lewis, Richard L. Sr. Hawley's Condensed Chemical Dictionary, 111h
Edition. Van Nostrand Reinhold. New York 1987.
11
ATTACHMENT 4
Review of Chemical Constituents in Moffat Tunnel Uranium Material to Determine the
Potential Presence of
RCRA Characteristic or RCRA Listed Hazardous Waste
Technical Memorandum
To: David C. Frydenlund From: Jo Ann Tischler
Company: Energy Fuels Resources (USA), Inc. Date: December 23, 2019
Re: Review of Chemical Contaminants in Union
Pacific Uranium Material to Determine the
Potential Presence of RCRA Characteristic or
RCRA Listed Hazardous Waste
CC:
1.0 Introduction
This report summarizes the characterization of the Union Pacific Railroad ("UPRR") Moffat
Tunnel Uranium Material (the "Uranium Material"), also referred to as the "centrifuge cake" or
"centrifuge solids" to determine whether or not the Uranium Material is or contains any listed or
characteristic hazardous waste as defined by the Resource Conservation and Recovery Act
("RCRA"). The results of this characterization will provide information for Energy Fuels
Resources (USA), Inc. ("EFRI") to determine the requirements necessary for an amendment to its
White Mesa Uranium Mill ("Mill") State of Utah Radioactive Materials License No. UT1900479
(the "License") to permit the processing of the Uranium Material as an alternate feed material at
the Mill.
In accordance with the definitions in the Atomic Energy Act, as amended, and 10 Code of Federal
Regulations ("CFR") 40.4, ores with natural uranium content of 0.05 weight percent or higher are
classified as source material and, as per 40 CFR Part 261.4, are exempt from regulation under
RCRA. As summarized in the Radioactive Material Profile Record ("RMPR"), the Uranium
Material has a uranium content of approximately 0.45 to 0.49 dry weight percent natural
uranium (0.53 to 0.58 dry weight percent U30s). This Uranium Material is therefore source
material, and is categorically exempt from RCRA.
Although the Uranium Material is exempt from regulation under RCRA, EFRI nonetheless
requires a due diligence evaluation of potential materials to be processed, to assess:
1. Whether the material is, or contains, any hazardous constituents that would be regulated
as RCRA listed hazardous waste, if the Uranium Material were not categorically exempt
from RCRA as a uranium ore or 1 le.(2) byproduct material or a categorically exempt
solid waste.
2. Whether the material contains any constituents that could generate a worker safety or
environmental hazard under the conditions under which it will be processed at the Mill.
3. Whether the material contains any constituents that would be incompatible with the
Mill's tailings management system.
1
This memorandum provides the evaluation of the regulatory status of the Uranium Material
relative to RCRA. Evaluation of potential safety and environmental hazards, and compatibility
with the Mill's tailings management system are provided in a separate memorandum.
2.0 Site History and Background
The Uranium Material was generated by treatment of groundwater from dewatering of the Moffat
railroad tunnel ("Moffat Tunnel"). The groundwater contains naturally occurring radioactive
material ("NORM") from contact with native rock, and picks up inorganic solid as it passes
through the Tunnel. As a result, the groundwater requires treatment to meet Colorado Department
of Public Health and Environment ("CDPHE") discharge standards prior to release to the Fraser
River.
Groundwater is pumped from the Moffat Tunnel at approximately 200 gallons per minute
("gpm") for dewatering. Prior to discharge of the pumped water to surface receiving waters, it is
pre-treated by an ultrafiltration and centrifugation system to meet CDPHE standards for
radionuclides and inorganic constituents.
The Uranium Material was generated from a continuous process, as described below, driven by
the requirement to achieve discharge permit limits in the water released from the water treatment
plant ("WTP") to the Fraser River. No other water sources or wastes are treated in the WTP.
The Uranium Material is comprised only of the centrifuged solids. No other materials or wastes
are added to the Uranium Material. The Uranium Material contains approximately 75-90%
moisture content and 0.13-0.14% natural uranium on a wet basis or up to 0.49% natural uranium
on a dry basis.
A chronology of the site history is listed below.
2008 to 2016
2017
2017
2017 through 2018
2018
2019
2019
Moffat Tunnel water characterization sampling
Treatment plant constructed
Beginning of dewatering and treatment
Centrifuge solids (Uranium Material) was collected in shipping
containers and disposed at off site waste management locations
UPRR submits application for CDPHE radiological materials license for
Uranium Material
Centrifuge solids are drummed for eventual transfer to EFRI
UPRR receives CDPHE license for Uranium Material
NRC' s Alternate Feed Guidance currently provides that if a proposed feed material contains
hazardous waste, listed under Section 261.30-33, Subpart D, of 40 CFR (or comparable RCRA
authorized State regulations), it would be subject to EPA (or State) regulation under RCRA.
However, the Guidance provides that if the licensee can show that the proposed feed material
does not consist of a listed hazardous waste, this issue is resolved. NRC guidance further states
that feed material exhibiting only a characteristic of hazardous waste (ignitability, corrosivity,
reactivity, toxicity) that is being recycled, would not be regulated as hazardous waste and could
therefore be approved for extraction of source material unless it is a residue from water treatment.
The Alternate Feed Guidance concludes that if the feed material contains a listed hazardous
waste, the licensee can process it only if it obtains EPA (or State) approval and provides the
necessary documentation to that effect. The Alternate Feed Guidance also states that NRC staff
2
may consult with EPA (or the State) before making a determination on whether the feed material
contains listed hazardous waste.
Subsequent to the date of publication of the Alternate Feed Guidance, NRC recognized that,
because alternate feed materials that meet the requirements specified in the Alternate Feed
Guidance must be ores, any alternate feed materials that contain greater than 0.05% source
material are considered source material under the definition of source material in 10 CPR 40.4
and hence exempt from the requirements of RCRA under 40 CPR 261.4(a)(4). See Technical
Evaluation Report Request to Receive and Process Molycorp Site Material issued by the NRC on
December 3, 2001 (the "Molycorp TER"). As a result, any such alternate feed ores are exempt
from RCRA, regardless of whether they would otherwise have been considered to contain listed
or characteristic hazardous· wastes. Since the Uranium Material contains greater than 0.05%
source material, it is exempt from RCRA, regardless of its process history or constituents, and no
further RCRA analysis is required.
Nevertheless, because the Alternate Feed Guidance has not yet been revised to reflect this
position recognized by NRC in the Molycorp TER, the remainder of this memorandum will
demonstrate that, even if the Uranium Material were not considered source material, and as such
exempt from RCRA, the Uranium Material would not, in any event, contain any RCRA listed or
characteristic hazardous wastes, as required under the Alternate Feed Guidance as currently
worded.
2.1 Description of Process Which Generated the Uranium Material
The Uranium Material consists of the centrifuge solids from the WTP, as described below.
Upon entering the treatment plant, the groundwater from tunnel dewatering is treated first by the
addition of a coagulant, Calchem CC2000 aluminum chlorohydrate, followed by direct filtration
in an ultrafiltration membrane system. Backwash water from the ultrafiltration membrane system
containing coagulated solids is pumped through a dissolved air flotation system where a very
small amount of 7th Generation dish soap (<0.001% by volume) is added to assist in thickening
of the solids via flotation. The thickened solids are further dewatered using a centrifuge. A small
amount of Zetag 120L polymer, <0.001 % by volume, is added to the thickened solids before the
solids enter the centrifuge.
During major construction, e.g. rail extension or tunnel expansion, an additional settling step is
added upstream of the treatment plant. Settling tanks are used in this situation to settle
construction related particulate matter. No other treatment chemicals are added.
Per the process description provided by UPRR for production of the centrifuge cake, the chemical
reagents used in the above processes included:
• Calchem CC2000 Aluminum chlorohydrate used as coagulant
• Seventh Generation dish soap used as a thickener for flotation
• Zetag 120L hydrocarbon polymer to enhance centrifugation
The presence of residuals or reaction byproducts from these compounds would be expected in the
Uranium Material, as discussed in the sections below.
3
Schematic flow sheets depicting the process which produced the Uranium Material during normal
operations and construction periods, are provided in Figures 1 and 2.
3.0 Basis and Limitations of this Evaluation
The Uranium Material to be processed at the EFRI White Mesa Mill consists solely of the
centrifuged solids from the WTP.
Physical and chemical analyses have been performed at different times to characterize the raw
water to be treated, to evaluate performance of the WTP, or to characterize the centrifuge solids
for off site management.
For development of treatment requirements prior to WTP construction, raw water from the
Moffat Tunnel West Portal was analyzed quarterly from 2008 through 2016 for metals and other
inorganic parameters.
Centrifuge solids, as well as intermediate streams in the WTP, were analyzed for a limited
number of organic and inorganic parameters during the WTP startup period in 2017.
Subsequent to discussions with EFRI in 2018, UPRR collected additional samples which were
analyzed for a full suite of parameters by a Utah certified laboratory. UPRR collected a first
sample representing short term centrifuge performance and Uranium Material composition by
sampling centrifuge cake from one day's operation. Four additional samples were collected over
a two week period of operation, and composited, to represent Uranium Material composition over
time.
The evaluations are summarized in the table below.
Summary of UPRR Moffat Analyses
Sample Sampling/ Analysis Analyses Number of
Name/Laboratory Date(s) Composite
Samples
American West June 2018 VOCs, SVOCs, 1 random sample
Analytical Laboratories pesticides, herbicides, accumulated over
Centrifuge Cake TCLP (metals and one day's run, and
Characterization organics), major ions, 1 composite of 4
total metals, ammonia additional samples
and nitrate N, over two weeks
radionuclides run.
WTP Startup Solids April 2017 Total metals, TCLP Approximately 10
Characterization metals, TCLP samples from
organics throughout the
WTP. (Not every
sample was
analyzed for every
parameter)
Moffat Tunnel West 2008 through 2016 Major ions, dissolved 119 (not every
Portal Raw Water metals, total metals, sample was
Monitoring cyanide, uranium analyzed for every
parameter)
4
As discussed in Section 2.0, above, the Uranium Material contains greater than 0.05% source
material, and is exempt from RCRA, regardless of its process history or chemical composition,
and no further RCRA analysis is required. The following evaluation of characterization data is
provided to demonstrate that even if the Uranium Material were not categorically exempt from
RCRA, it is not and does not contain RCRA listed or characteristic hazardous waste.
The sampling was representative of a continuous process stream under the control of the
generator from a process which did not vary appreciably over time.
The various analyses addressed a full range of volatile organic compounds ("VOCs"),
semivolatile organic compounds ("SVOCs'), pesticides, arochlors and other compounds that
could potentially have reached groundwater, or centrifuge solids, from natural and man-made
sources. Analyses provided with the RMPR were performed by laboratories possessing State of
Utah and/or NELAC certification for the analyses performed. As a result, these studies provide
sufficiently representative characterization to assess the regulatory status, worker safety
environmental hazards, and chemical and processing properties of the Uranium Material.
The following RCRA evaluation is based on information from the following sources:
1. Current Moffat Uranium Material analytical data 2018
2. TestAmerica analyses April 2017
3. Raw water influent data provided by UPRR for sampling from 2008 through 2016
4. Material Safety Information Sheet for Insoluble Mineral Fraction provided by UPRR,
2019
5. Correspondence and discussion with UPRR personnel throughout 2018 and 2019.
6. EFRI Protocol for Determining Whether Alternate Feeds Are Listed Hazardous Wastes
(EFRI, November 1999).
7. RMPR for the UPRR Uranium Material (March 2019).
8. Basis of Hazardous Material and Waste Determinations from the RMPR (March 2019)
9. Affidavit of Steven L. Preston UPRR Environmental Field Operations Manager (April 2,
2019).
EFRI has developed a "Protocol for Determining Whether Alternate Feed Materials are Listed
Hazardous Wastes" (November 22, 1999) ("the Protocol"). The Protocol has been developed in
conjunction with, and accepted by, the State of Utah Department of Environmental Quality
("UDEQ") (Letter of December 7, 1999). Copies of the Protocol and UDEQ letter are provided
in Attachment 2 of this Report. The RCRA evaluation and recommendations in this Report were
developed in accordance with the Protocol.
4.0 Application of Protocol to Uraniwn Material
4.1 Source Investigation
Several of the information sources enumerated above were used to perform the Source
Investigation indicated in Box 1 of the flow diagram (the "Protocol Diagram") that forms part of
the Protocol.
The following sections describe the status of the Uranium Material relative to RCRA
Characteristic and RCRA Listed Hazardous Waste regulations, and relative to the specific
parameters identified in the EFRI/UDEQ Hazardous Waste Protocol. As the Uranium Material is
5
a residue from a water treatment facility, were it not exempt from RCRA as source material, it is
not permitted to contain constituents that may be considered RCRA characteristic wastes. For
completeness, this Report also determines whether or not the Uranium Material contains any such
constituents.
4.2 Detennination Methods in the EFRI / UDEQ Protocol
4.2.1 Regulatory History of the UPRR Uranium Material
Prior to 2019, UPRR disposed of the centrifuge solids in off-site solid waste disposal
facilities licensed for the disposal of NORM material. In 2018 CDPHE required that
UPRR apply for a CDPHE radioactive materials license. UPRR received License CO
1274-01 in 2019.
The Uranium Material, which has materially not changed in form or content since first being
produced in 2017, remains definitional source material as per 40 CFR Part 261.4, and is explicitly
exempt from regulation under RCRA. However, for the sake of completeness, EFRI has required
the following evaluation to confirm that even if the Uranium Material were not exempt from
RCRA, it is not and does not contain, what would otherwise be considered a RCRA-listed waste,
or a RCRA characteristic waste.
The Uranium Material has not been classified or treated as listed hazardous waste nor has it been
in contact with any listed hazardous wastes.
4.2.2 Evaluation of Potential RCRA Listings Associated with Specific Contaminants
For potential alternate feed materials that are not exempt from RCRA, the Protocol describes
additional steps EFRI will take to assess whether contaminants associated with any potential
RCRA waste listings are present, and the likelihood that they resulted from RCRA listed
hazardous wastes or RCRA listed processes. These steps include tabulation of all potential
listings associated with each known chemical contaminant in the material, and the review of
chemical process and material/waste handling history at the site to assess whether the known
chemical contaminants in the material resulted from listed or non-listed sources. This evaluation
is described in Box 8 and Decision Diamonds 9 through 11 in the Protocol Diagram.
If the results of the evaluation indicate that the contaminants are not listed waste, the Protocol
specifies an additional assessment of whether the data on which this determination was made is
sufficiently representative, or whether an ongoing acceptance sampling program should be
implemented, and a similar evaluation performed on any new constituents identified during
acceptance sampling.
In the case of the Uranium Material, Steps 9 through 11 are not required as indicated by the
statements provided in the Affidavit of Steven Preston of UPRR. However, for the sake of a
thorough due diligence evaluation, Steps 9 through 11 were completed, and the results are
presented below.
5.0 RCRA Review of Chemical Constituents
Determination of whether the Uranium Material is, or contained, potential RCRA-listed waste
included consideration of source history provided by UPRR, and through communications with
6
UPRR personnel and contractor personnel from January 2018 to date, as well as the analytical
efforts summarized in Section 3.0 above.
5.1 Overview
As discussed below, the components of the Uranium Material result either from naturally-
occurring constituents of the influent water to the WTP, from inorganic solids from the tunnel, or
from the non-hazardous treatment agents added in the WTP which produced the centrifuge
solids/Uranium Material. Like the dissolved constituents of influent water to the WTP, any solids
from the Tunnel would consist of materials from natural sources, such as sediments or soils, and
are not from RCRA listed waste sources.
The Uranium Material does not contain any "P" or "U" listed wastes as it contains no discarded
commercial chemical products, off-specification species, container residues, or spill residues
thereof. Any chemicals used in the WTP which generated the Uranium Material were used for
their intended purpose and are not waste materials. None of the chemicals used in treatment
were associated RCRA hazardous wastes.
There were no processes conducted at the site which fall under the category of "F" listed
hazardous wastes from non-specific sources as designated in the following seven categories:
• Spent solvent wastes (F001-F005)
• Wastes from electroplating and other metal finishing operations (F006-F012, F019)
• Dioxin-bearing wastes (F020-F023 and F026-F028)
• Wastes from the production of certain chlorinated aliphatic hydrocarbons (F024, F025)
• Wastes from wood preserving (F032, F034, and F035)
• Petroleum refinery wastewater treatment sludges (F037 and F038)
• Multi-source leachate (F039)
There were no processes conducted at the site which fall under the category of "K" listed
hazardous wastes from specific sources designated in the following 13 categories:
• Wood preservation (KOOl)
• Inorganic pigment manufacturing (K002 -K008)
• Organic chemicals manufacturing (K009-K030, K083, K085, K093-K096, K103-K105,
K107-K118, K136, K149-K151, K156-K159, K161, K174-K175, K181)
• Inorganic chemicals manufacturing (K071, K073, K106, K176-178)
• Pesticides manufacturing (K031-K043, K097-K099, K123-K126, Kl31-K132)
• Explosives manufacturing (K044-K047)
• Petroleum refining (K048-52, Kl 70-Kl 72)
• Iron and steel production (K061-K062)
• Primary aluminum production (K088)
• Secondary lead production (K069, KlOO)
• Veterinary pharmaceuticals manufacturing (K084, K101-K102)
• Ink formulation (K086)
• Coking (K060, K087, K141-K145, K147-K148)
Evaluation of RCRA listings associated with the inorganic ions and metals analyzed in the
Uranium Material is provided in attached Tables 1 and 2 respectively. The single SVOC
identified in one of the two samples analyzed, is evaluated in Table 3.
7
5.2 Volatile Organic Compounds
The Uranium Material consists of solid residuals, centrifuge cake, from treatment of groundwater
from tunnel dewatering. No VOCs were used in the treatment unit or are expected in the tunnel.
No VOCs would be anticipated, and none were detected, in the Uranium Material.
5.3 Semivolatile Organic Compounds
One SVOC, fluoranthene, was detected in one of the two samples of the centrifuge solids. The
RCRA listings associated with fluoranthene, KOOl, K022 and K035 apply to fluoranthene from
wood treating, creosote manufacture, coking, or phenol/acetone production. As mentioned above,
none of these processes were conducted on the WTP site. Additionally, wood treating was not
conducted in the tunnels and any residuals from pre-treated wood used for railroad ties or
structures are not RCRA listed wastes. Fluoranthene is a common multi-ring asphaltic compound
present in paving materials, roadbeds, roofing material and other common construction materials
and may have been introduced from one of these sources. Alternatively the compound may have
been introduced with the naphthenic distillates added before centrifugation.
The single potential RCRA listing associated with the fluoranthene, which is not applicable to the
Uranium Material, is documented in attached Table 3.
Semivolatile constituents associated with fuels, lubricants, and soot from the transit of railroad
equipment are not RCRA listed wastes. No other semi-volatile constituents were identified.
5.4 Non-Metal Inorganic Compounds
AW AL analytical results in the Uranium Material indicate that low levels of ammonia as nitrogen
("ammonia as N"), chloride, fluoride, and sulfate are present in the Uranium Material. Moffat
Tunnel raw water analyses indicate that each of these analytes, except ammonia as N, is present
in the raw water influent to the WTP. Nitrate/nitrite nitrogen was analyzed and not detected in the
Uranium Material.
Ammonia as N was introduced with the non-hazardous dish detergent used as a thickener in the
dissolved air flotation step. Neither the detergent nor the process are associated with any RCRA
hazardous waste listings. Evaluation of potential RCRA listings associated with the remaining
inorganic analytes, and why they are not applicable to the Uranium Material, is provided in detail
in the attached Table 1.
Inorganic nitrate/nitrite and inorganic ammonia nitrogen have also been analyzed in the raw water
influent samples, but not detected in the Uranium Material. Inorganic nitrate/nitrite compounds
and inorganic ammonia nitrogen are not associated with any RCRA hazardous waste listings,
therefore, these analytes have not been included in Table 1.
5.5 Metals
Analytical results indicate that the metals aluminum, arsenic, barium, calcium, cobalt, copper,
iron, lead, magnesium, manganese, mercury, molybdenum, nickel, potassium, sodium, vanadium,
and zinc were present in the Uranium Material.
8
No RCRA listings are associated with cobalt, iron, magnesium, or molybdenum. Evaluation of
potential RCRA listings associated with the remainder of the analyzed metals, and why they are
not applicable to the Uranium Material, is provided in detail in the attached Table 2.
Metal constituents associated with fuels, lubricants, soot, and track erosion from the transit of
railroad equipment are not RCRA listed wastes.
5.6 Summary of RCRA listed Waste Findings
Based on the information presented above, none of the constituents in the Uranium Material
would be indicative of RCRA listed hazardous waste, even if the Uranium Material were not
already exempt from RCRA as source material. Review of the analytical data, the, process
history, and raw water characterization confirms that all of the constituents in the material are
consistent with those expected to result from tunnel dewatering or from the WTP as described
above.
6.0 RCRA Characteristic<;
The Uranium Material is a centrifuged dewatered moist solids from inorganic groundwater
treatment. As a result it would not be ignitable, corrosive, or reactive per the RCRA definitions
of these characteristics. A Uranium Material sample collected during 2017 was analyzed for
eight RCRA TCLP metals and 31 RCRA TCLP organic compounds. Two Uranium Material
samples collected during 2018 were also analyzed for eight RCRA TCLP metals and 8 RCRA
TCLP organic compounds. In all samples collected over both sampling events, no analyzed
constituent exceeded its respective TCLP threshold for RCRA toxicity characteristic as defined in
Table 1 of 40 CFR Part 261.24(b). Therefore, the test results confirm that the Uranium Material
does not have the RCRA characteristic of toxicity. These results are summarized in the attached
Table 4.
Two Uranium Material samples collected during 2018 were tested for corrosivity. No samples
exhibited a pH of 2.0 or lower, or a pH of 12.5 or higher. These results confirm that the Uranium
Material does not have the RCRA characteristic of corrosivity.
The Uranium is not an oxidizer, an ignitable compressed gas, or a solid that can cause a fire and
sustain combustion. In addition, two samples of Uranium Material collected during 2018 were
tested for flash point. The sample did not exhibit a flash point of <140°F. These results confirm
that the Uranium Material does not have the RCRA characteristic of ignitability.
The Affidavit from Steven Preston of UPRR affirms that the Uranium Material has never been
classified for shipment or off-site management as a RCRA characteristic waste. This is consistent
with the source of the constituents and the WTP that produced the Uranium Material.
As discussed in the introduction to this report, the Uranium Material is exempt from regulation
under RCRA; therefore, even if it exhibited characteristics of hazardous waste, it would still be
permitted alternate feed material under under NRC's Alternate Feed Guidance (10 CFR 40,
Appendix A).
Based on all of the above information, the Uranium Material is not a RCRA characteristic
hazardous waste.
9
7.0 Conclusions and Recommendations
In summary, the following conclusions can be drawn from the RCRA analysis of the analytical
data and information presented above:
1. The Uranium Material is not a RCRA listed hazardous waste because it is an ore that has
a natural uranium content of greater than 0.05 weight percent, is therefore source material
and, as a result, is exempt from regulation under RCRA.
2. Even if the Uranium Material were not source material, it would not be a RCRA listed
hazardous waste for the following additional reasons:
a) It was generated from a known process under the control of the generator, who has
provided the Affidavit declaring that the Uranium Material is not and does not
contain RCRA listed hazardous waste. This determination is consistent with Boxes I
and 2 and Decision Diamonds I and 2 in the EFRI/UDEQ Protocol Diagram;
b) No VOCs are used in the water treatment process that produced the centrifuge solids,
and no volatile organic compounds can be expected to be present in the Uranium
Material.
c) No SVOCs are used in the inorganic mineral process that produced the centrifuge
solids. One semi-volatile organic compound, fluoranthene, was detected in one
sample, and not in the second sample. If present, it did not result from wood treating.
Even if it resulted from pre-treated railroad ties, that source is not a RCRA listed
source. The compound does not indicate a RCRA listed waste.
d) None of the metals in the Uranium Material samples came from RCRA listed
·hazardous waste sources. This determination is consistent with Box 8 and Decision
Diamonds 9 through 11 in the EFRI/UDEQ Protocol Diagram.
3. The Uranium Material does not exhibit any of the RCRA characteristics of ignitability,
corrosivity, reactivity, or toxicity for any constituent.
10
8.0 References
• Austin, G.T. Shreve's Chemical Process Industries, Fifth Edition. McGraw Hill. New
York 1984.
• Title 10 Code of Federal Regulations; Chapter I -Nuclear Regulatory Commission, Part
40 -Domestic Licensing of Source Material: 40.4 -Definitions ( 10 CFR 40.4)
• Title 40 Code of Federal Regulations; Protection of the Environment, Part 261 -
Identification and Listing of Hazardous Waste: Subpart A, 261.4 -Exclusions: Subpart B
-Criteria for Identifying the Characteristics of Hazardous Waste and for Listing
Hazardous Waste.
• Sax, N. Irving and Lewis, Richard L. Sr. Hawley's Condensed Chemical Dictionary, 1 J1"
Edition. Van Nostrand Reinhold. New York 1987.
11
INORGANIC CHLORIDES'
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely Hazardous FList
UList PList
U216
Thallium chloride
P033
Cyanogen chloride
P095
Carbonic dichloride
(phosgene)
NONE
FLUORIDE
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely Hazardous FList
UList PList
U033
Carbonic difluoride,
Carbon oxyfluoride,
Carbonyl fluoride
U075
Dichlorodifluoro
methane
U134
Hydrogen fluoride
P043
Diisoproplyfluorophosp
hate
P056
Fluorine
P057
2-fluoroacetamide
TABLE 1 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON-METALS IN URANIUM MATERIAL
Specific Industrial Uses and Sources of U or P Listed Is This Listing Applicable to Uranium Material?
Sources Element or Compound
KList
Chlorination catalyst, sun lamp monitors. No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
the WTP site or in the tunnels.
Organic synthesis, tear gas, warning agent in No. There would be no reason for this compound to be
fumigant gases. present as pure product, byproduct, or off-spec product on
the WTP site or in the tunnels.
Used in organic synthesis for production of No. There would be no reason for this compound to be
urethanes, plastics and pesticides. Formerly present as pure product, byproduct, or off-spec product on
used as choking agent in combat gas. the WTP site or in the tunnels.
No F Listings
NONE No K Listings
Specific Industrial Uses and Sources of U or P Listed Is This Listing Applicable to Uranium Material?
Sources Element or Compound
KList
Used in organic synthesis for addition of carbon No. There would be no reason for this compound to be
groups to other structures. present as pure product, byproduct, or off-spec product on
the WTP site or in the tunnels. Fluoride was present as a
constituent of raw groundwater influent to treatment.
Used as refrigerant in air conditioners, and direct No. There would be no reason for this compound to be
contact freezing. Used in plastics manufacture, present as pure product, byproduct, or off-spec product on
and as solvent and blowing agent. the WTP site or in the tunnels. Fluoride was present as a
constituent of raw groundwater influent to treatment.
Catalyst in refinery alkylation, isomerization, No. There would be no reason for this compound to be
condensation, dehydration, and polymerization present as pure product, byproduct, or off-spec product on
processes. Used for organic and inorganic the WTP site or in the tunnels. Fluoride was present as a
flourination reactions, production of fluorine gas constituent of raw groundwater influent to treatment.
and aluminum fluoride, some uranium leaching
processes, and as additive to solid rocket
propellant.
Insecticide No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
the WTP site or in the tunnels. Fluoride was present as a
constituent of raw groundwater influent to treatment.
Production of metallic fluorides and No. There would be no reason for this compound to be
fluorocarbons, fluoridation compounds for present as pure product, byproduct, or off-spec product on
toothpaste and water treatment. the WTP site or in the tunnels. Fluoride was present as a
constituent of raw groundwater influent to treatment.
Primarily as a rodenticide. No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
the WTP site or in the tunnels. Fluoride was present as a
constituent of raw groundwater influent to treatment.
Page 1
POS8
Fluoroacetic acid
sodium salt
NONE
SULFATES
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely Hazardous FList
UList PList
NONE
NONE
NONE
TABLE 1 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON-METALS IN URANIUM MATERIAL
Primarily as a rodenticide. No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
the WTP site or in the tunnels. Fluoride was present as a
constituent of raw groundwater influent to treatment.
No F Listinl!;S
NONE No K Listings
Specific Industrial Uses and Sources of U or P Listed Is This Listing Applicable to Uranium Material?
Sources Element or Compound
KList
No U Listings
No P Listings
No F Listings
Kl31 No. Uranium Material is not from this industry. Sulfates
Dimethyl sulfate in was present in raw groundwater influent to treatment, and in
wastewater from the the detergent used as thickener in the floatation unit.
reactor and spent sulfuric
acid from the acid dryer
from the production of
methyl bromide
Page 2
ALUMINUM
Conunercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
NONE
P006
Aluminum
phosphide
ARSENIC
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
Ul36
Dimethyl arsenic
acid
(cacodvlic acid)
POii
Arsenic trioxide
P012
Arsenic
Pentoxide
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
FList KList
-
Insecticide, fumigant, semiconductor
manufacturing.
NONE -
NONE -
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
FList KList
Used as herbicide for Johnson grass on
cotton, in timber thinning, as a soil
sterilizing agent, and as a chemical
warfare agent.
Used in production of pigments, aniline
colors, ceramic enamels, and decolorizing
glass, insecticides, herbicides,
rodenticides, wood and hide preservatives,
and sheep dip.
Used in production of arsenates,
insecticides, dyeing and printing, weed
killers, and colorization of glass. Also
used in metal adhesives.
F032
Wastewater from wood
preserving processes using
creosote and pentachlorophenol
F034
Wastewater from wood
preserving processes using
creosote and pentachlorophenol
F035
Wastewaters from wood
preserving processes using
inorganic preservatives
F039 ·-
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
Page 1
Is This Listing Applicable to Uranium Material?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. Aluminum is present
in raw water influent and in pre-filtration coagulant.
No F Listings
No K Listings
Is This Listing Applicable to Uranium Material?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
K021 -
Spent catalyst from
fluoromethane production
K031 -
Byproduct salts from MSMA and
cacodvlic acid production
K060 -
Ammonia still lime sludge from
coking
K084 --
Wastewater sludge from
veterinary pharmaceutical
production
K!Ol -
Distillation tar residues from
veterinary pharmaceutical
production
Kl02 -
Residue from decolorization of
veterinary pharmaceuticals
K161 --
Purification solids, baghouse dust
and floor sweepings from
dithiocarbamate acids production
Kl 71 Spent hydrotreating catalyst --
from petroleum refining
K172 --
Spent hydrorefining catalyst from
oetroleum refining
Kl76
Baghouse filters from the
production of antimony oxide,
and intermediate metals.
K177 --
Slag from production or
speculative accumulation of
antimony or antimony oxides
Page 2
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Arsenic
originated in raw water influent to treatment.
No. Uranium Material is not from this industry.
Arsenic originated in raw water influent to treatment.
BARIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
P013
Barium Cyanide
NONE
CALCIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U032
Calcium chromate
P021
Calcium cyanide
NONE
COPPER
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
P029
Cuprous or
Cupric Cyanide
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
-
Used in metallurgy and electroplating.
-
NONE -
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Used as a pigment, corrosion inhibitor,
oxidizing agent, battery depolarizer, coatin
g for light metal alloys.
Rodenticide, fumigant for greenhouses,
flour mills, grain, seed, and citrus trees,
gold leaching, and synthesis of other
cvanides.
--
NONE --
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
-
Used in metallurgy and electroplating,
insecticides, anti-foulants in paints,
catalysts in organic synthesis ..
-
NONE --
Page 3
Is This Listing Applicable to Uranium Material?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. Barium originated in
raw water influent to treatment.
No F Listings
No K Listings
Is This Listing Applicable to Uranium Material?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. Calcium originated in
raw water influent to treatment.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No F Listings.
No K Listings.
Is This Listing Applicable to Uranium Material?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. Copper originated in
raw water influent to treatment.
No F Listings
No K Listings
LEAD
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
U 144
lead acetate
U 145
lead phosphate
Ul46
lead subacetate
PIIO
Tetraethyl lead
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
FList KList
Textile dyeing, chrome pigments, gold
cyanide leaching, lab reagent, hair dye.
May be present as antifoulant in paints,
waterproofing, varnishes.
Stabilizing agent added to plastic resins.
Decolorizing agent added to sugar
solutions in food products.
Synthesized solely as a gasoline
anti-knock additive.
F035 --
Wood treating wastewater
F037 -
Refinery oil/water separator solids
F038 -
Refinery secondary oil/water
separator solids
F039 --
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
K002 -·-··
Wastewater treatment sludge from
production of chrome yellow
pigment
K003 --
Wastewater treatment sludge from
production of chrome molybdate
orange pigment
KOOS --
Wastewater treatment sludge from
production of chrome green
pigment
K046 --
Wastewater treatment sludge from
production of lead based
explosive initiators
K048 -
Petroleum refining dissolved air
flotation ("OAF') solids
Page4
Is This Listing Applicable to Uranium Material?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. .
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
MANGANESE
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
P196
Manganese
dimethyldithio
carbamate
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
K049 -
Petroleum refining slop oil
emulsion solids
K051 -
Petroleum refining API separator
solids
K052 Petroleum refining leaded ·-
tank bottoms
K061 ·-
Steel electric furnace emission
control dust/sludge
K062 ...
Iron and steel manufacturing
pickle liquor
K064 -
Acid plant blowdown thickener
slurry/sludge from primary copper
oroduction blowdown
K069 --
Emission control dust/sludge from
secondary lead smelting
K086 --
Sol vent, caustic and water wash
sludges from ink formulation
KJOO --Waste solution from acid leaching
of emission control dust/sludge
from secondarv lead smelting
K176
Baghouse filters from the
production of antimony oxide,
and intermediate metals.
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
·-
Primarily as a pesticide.
--
NONE --·
Page 5
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
ori2inated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment. waste
sources.
No. Uranium Material is not from this industry. Lead
originated in raw water influent to treatment.
Is This Listing Applicable to Uranium Material?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. Manganese originated
with raw water influent to treatment.
No F Listings
No K Listin2s
MERCURY
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
Ul51
Mercury metal
Hg
P065 Mercury
Fulminate
P092
Acetato-0-
phenyl mercury
or
phenyl mercuric
acetate
NICKEL
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
P List
NONE
P073
Nickel carbonyl
P074
Nickel Cyanide
Non-Specific
Sources
FList
NONE
Non-Specific
Sources
FList
F006
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Dental amalgams, organic and inorganic
reaction catalyst, cathodes for chlorine/
caustic production cells, mirror coating,
vapor and arc lamps, nuclear power
reactors, boiler fluids. Also present in
instruments and used in extractive
metallurgy.
Due to relatively high detonation velocity,
used primarily as an explosive initiator in
military explosives. Too unstable for most
other uses.
Used as a fungicide, anti-mildew agent,
and as a topical spermicide
·-
K071 ··-
Brine purification muds from
mercury cell chlorine production
Kl06 -·
Wastewater treatment sludge from
mercury cell chlorine oroduction
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
--
Electroplated nickel coatings, reagent
chemical
Metallurgy, electroplating
-· Wastewater treatment sludge from
electroplating
NONE -·
Page 6
Is This Listing Applicable to Uranium Material?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No F Listings
No. Uranium Material is not from this industry.
Mercury originated with raw water influent to treatment.
No. Uranium Material is not from this industry.
Mercury originated with raw water influent to treatment.
Is This Listing Applicable to
SFC Sludge?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. Uranium Material is not wastewater treatment
sludge from electroplating.
No K Listings
POTASSIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
P098
Potassium
cyanide
P099
Potassium silver
cyanide
NONE
SODIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U236
3,3'-[(3,3'-
dimethyl[ 1,1 ' -
biphenyl]-4,4' -
diyl)bis(azo)bis[5-
amino-4-hydroxy ]-,
tetrasodium salt
P058
Fluoroacetic acid
sodium salt
P105
Sodium azide
PI06
Sodium Cyanide
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
--
Extraction of gold and silver from ores,
reagent in analytical chemistry,
insecticide, fumigant, electroplating.
Silver plating, bactericide, antiseptic.
K161 Dithiocarbamate production
Metarn-sodium
Purification solids, baghouse dust
and sweepings form
dithiocarbamate production.
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
-
Rodenticide
Air bag inflator, intermediate in explosive
manufacture, preservative in diagnostic
medicines.
Manufacture of dyes, pigments, nylon,
chelating compounds, insecticides,
fumigants. Extraction of gold and silver
from ores, electroplating, metal cleaning,
heat treatment, ore flotation.
Page 7
Is This Listing Applicable to
Uranium Material?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No F Listings
No. Uranium Material is not from this industry.
Potassium originated with raw water influent to
treatment.
Is This Listing Applicable to Uranium Material?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
NONE
VANADIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
PList
NONE
Pl 19
Ammonium
vanadate
Pl20
Vanadium
pentoxide
NONE
ZINC
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U249
Zinc phosphide
(10 wt.% or less)
Pl21
Zinc cyanide
P122
Zinc phosphide
(greater than I 0
wt.%)
P205
Zinc dimethyl
dithiocarbamate,
Ziram
NONE
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
K161 Dithiocarbamate production
Metam-sodium
Purification solids, baghouse dust
and sweepings form
dithiocarbamate production.
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
-·-
Intermediate in production of vanadium
oxide. Used in DeNOx catalysts for
emissions controls, and to produce
ceramic colorants.
Used in steel ceramics industries. Used in
inorganic and organic synthesis in dye,
paint, varnish, glass, pesticides, and ink
manufacture.
NONE
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Rodenticide
Metal plating, chemical reagent,
insecticide.
Rodenticide
Fungicide, accelerator in rubber synthesis.
-
Kl61 Rodenticide
Ziram pesticides
Page 8
No F Listings
No. Uranium Material is not from this industry.
Sodium originated with raw water influent to treatment.
Is This Listing Applicable to Uranium Material?
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels. Vanadium originated
with raw water influent to treatment.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No F Listings
No K Listings
Is This Listing Applicable to Uranium Material?
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels ..
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on the WTP site or in the tunnels.
No F Listings
No. Uranium material is not from this industry. Zinc
originated with raw water influent to treatment.
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
Page 9
FLUORANTHENE
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely Hazardous
U List PList
Ul20
None
TABLE 3: SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 AND APPENDIX VII
ASSOCIATED WITH ORGANICS IN URANIUM MATERIAL
Non-Specific Specific Sources Industrial Uses and Sources of U or P Is This Listing Applicable to Uranium Material
Sources KList Listed Element or Compound
FList
Present in coal, coal tar, coal slag, road No. Not used or stored as a reagent or product.
asphalt, and roofing tar. Likely present from road material runoff, which is
not a RCRA-listed source.
Present in coal, coal tar, coal slag, road No P Listings. Likely present from road material
asphalt, and roofing tar. runoff, which is not a RCRA-listed source.
F034 Present in coal, coal tar, coal slag, road No. No creosote or wood treating operations.
asphalt, and roofing tar. Compounds from pre-treated railroad ties are not a
RCRA-listed source. Likely present from road
material runoff, which is not a RCRA listed source.
KOOi, K022, K035 Present in coal, coal tar, coal slag, road No. No wood treating, creosote, coking or
Wood treating wastes; asphalt, and roofing tar. phenol/acetone operations. Compounds from pre-
wastes from distillation treated railroad ties are not a RCRA-listed source.
of phenol/acetone from Likely present from road material runoff, which is
cumene; sludges from not a RCRA-listed source.
production of creosote
Page 1
1
Table 4
Maximum TCLP Versus RCRA TCLP Characteristic Limits
RCRA Toxicity TCLP Maximum Analytical TCLP Maximum
Characteristic Metals and Result in Uranium Material Analytical Result in TCLP Threshold Limit
Organics 2017 Uranium Material 2018 {mg/L)
Arsenic (As) <0.5 <0.0100 5.0
Barium (Ba) 1.4 1.5 100.0
Cadmium (Cd) 0.0040 J <0.0350 1.0
Chromium (Cr) 0.0091 J <0.0200 5.0
Lead (Pb) 0.056 J B <0.0500 5.0
Mercury (Hg) <0.0020 <0.0100 0.2
Selenium (Se) <0.10 <0.0100 1.0
Silver (Ag) 0.0082 J <0.0100 5.0
Chlordane <0.0050 <0.0001 0.03
Endrin <0.0005 <0.0001 0.02
gamma-BHC (Lindane) <0.00050 <0.0001 0.4
Heptachlor <0.00050 <0.0001 0.0
Methoxychlor <0.0010 <0.0001 10.0
Toxaphene <0.020 <0.00125 0.5
2,4,5-TP <0.010 <0.0010 1.0
2,4-D <0.040 <0.0010 10.0
Benzene <0.010 NA 0.5
2 Butanone <0.10 NA 200.0
Carbon tetrachloride <0.010 NA 0.5
Chlorobenzene <0.010 NA 100.0
Chloroform <0.010 NA 6.0
1,4-Dichlorobenzene <0.010 NA 7.5
1,2-Dichlorobenze <0.010 NA 0.5
1,2-Dichloroethene <0.010 NA 0.5
1, 1-Dichloroethylene <0.010 NA 0.7
Tetrachloroethene <0.010 NA 0.5
Trichlroethene <0.010 NA 0.5
Vinyl Chloride <0.010 NA 0.2
2,4-Dintirotoluene <0.050 NA 0.13
Hexachlorobenzene <0.050 NA 0.13
Hexachlorobutadiene <0.050 NA 0.5
Hexachloroethane <0.050 NA 3.0
m+p Cresol <0.050 NA 400.0
Nitrobenzeile <0.050 NA 2.0
o-Cresol <0.050 NA 200.0
Pentachlorohenol <0.25 NA 100.0
Pyridene <0.10 NA 5.0
2,4,5-Trichlorophenol <0.050 NA 400.0
2,4,6-Trichlorophenol <0.025 NA 2.0
NOTES:
1. TCLP threshold limit values are established in 40 CFR 261.24 Table 1.
2. TCLP Analytical results are maximum from 2017 TestAmerica and 2018 AW AL laboratory data.
3. All TCLPs results, except barium, were below detection limits in all samples.
4. B indicated analyte was ientified in the blank sample; J indicates it is tentatively identified.
ATTACHMENT 5
Review of Chemical Constituents in Moffat Tunnel Uranium Material to Determine
Worker Safety and Environmental Issues and Chemical Compatibility at the EFRI White
Mesa Mill
TECHNICAL MEMORANDUM
To: David C. Frydenlund, Kathy Weinel From: Jo Ann Tischler
Company: Energy Fuels Resources (USA) Inc. Date: December 23, 2019
Re: Review of Chemical Contaminants in Union
Pacific Railroad Uranium Material to
Determine Worker Safety and Environmental
Issues and Chemical Compatibility at the White
Mesa Mill
1.0 Introduction
This report summarizes the characterization of the Union Pacific Railroad ("UPRR") Moffat
Tunnel Uranium Material (the "Uranium Material"), also referred to as the "centrifuge cake" or
"centrifuge solids", to determine whether processing the Uranium Material at the Energy Fuels
Resources (USA), Inc. ("EFRI") White Mesa Mill (the "Mill") may pose any worker safety or
environmental hazards, or may be incompatible with the Mill's existing tailings management
system. The results will provide information to EFRI to determine the requirements, if any, for
changes to worker safety practices, or potential incompatibilities to the Mill for the processing of
Uranium Material as an alternate feed material. This report will also provide comparison of
constituents of the Uranium Material and the EFRI groundwater ("GW") monitoring program to
identify any constituents which are not covered under the EFRI GW monitoring program and
whether these additional parameters need to be added to the sampling requirements.
The following questions were considered for the evaluation of potential safety and environmental
hazards and compatibility with the Mill's tailings management system and GW monitoring
requirements:
1) Will any constituents of the Uranium Material volatilize at the known conditions on
the Mill site or in the Mill circuits? If so, will they create any potential environmental,
worker health, or safety impacts?
2) Will the Uranium Material or any of its constituents create a dust or off-gas hazard at
the known conditions on the Mill site or in the Mill circuit? If so, will they create any
potential environmental, worker health, or safety impacts?
3) Will any constituents of the Uranium Material react with other materials in the Mill
circuits?
4) Will any constituents of the Uranium Material create any impacts on the tailings
management system?
5) Does the Uranium Material contain any constituents that are not present in the current
Mill GW monitoring program and not sufficiently represented by the Mill's
groundwater monitoring analyte list and need to be added to the analyte list?
6) What, if any, limitations on feed acceptance criteria or added operational controls are
recommended in connection with processing the Uranium Material at the Mill?
An evaluation of the regulatory status of the Uranium Material relative to the Resource
Conservation and Recovery Act ("RCRA") regulations is provided in a separate technical
memorandum.
1
2.0 Basis and Limitations of This Evaluation
The following contamination evaluation is based on:
The evaluation in this memorandum is based on information from the following sources:
1. Current Moffat Uranium Material analytical data 2018.
2. TestAmerica analyses April 2017.
3. Raw water influent data provided by UPRR for sampling from 2008 through 2016.
4. Material Safety Information Sheet for Insoluble Mineral Fraction provided by UPRR,
2019.
5. Correspondence and discussion with UPRR personnel throughout 2018 and 2019.
6. EFRI Protocol for Determining Whether Alternate Feed Materials Are Listed Hazardous
Wastes (EFRI, November 1999).
7. RMPR for the UPRR Uranium Material (March 2019).
8. Basis of Hazardous Material and Waste Determinations from the RMPR (March 2019).
9. Affidavit of Steven L. Preston UPRR Environmental Field Operations Manager (April 2,
2019).
3.0 Site History and Background
The Uranium Material was generated by treatment of groundwater from dewatering of the Moffat
railroad tunnel ("Moffat Tunnel"). The groundwater contains naturally occurring radioactive
material ("NORM") from contact with native rock, and picks up inorganic solids particles as it
passes through the tunnel. As a result, the groundwater requires treatment to meet Colorado
Department of Public Health and Environment ("CDPHE") discharge standards prior to release to
the Fraser River.
Groundwater is pumped from the Moffat Tunnel at approximately 200 gallons per minute ("gpm")
for dewatering. Prior to discharge of the pumped water to surface receiving waters, it is pre-treated
by an ultrafiltration and centrifugation system to meet CDPHE standards for radionuclides and
inorganic constituents.
The Uranium Material was generated from a continuous process, as described below, driven by the
requirement to achieve discharge permit limits in the water released from the water treatment plant
("WTP") to the Fraser River. No other water sources or wastes are treated in the WTP.
The Uranium Material is comprised only of the centrifuged solids. No other materials or wastes
are added to the Uranium Material. The Uranium Material contains approximately 75-90%
moisture content and 0.13-0.14% natural uranium on a wet basis or up to 0.49% natural uranium
on a dry basis.
A chronology of the site history is listed below.
2008 to 2016
2017
2017
Moffat Tunnel water characterization sampling
Treatment plant constructed
Beginning of dewatering and treatment
2
2017 through 2018
2018
2019
2019
Centrifuge solids (Uranium Material) was collected in shipping
containers and disposed at off site waste management locations
UPRR submits application for CDPHE radiological materials license for
Uranium Material
Centrifuge solids are drummed for eventual transfer to EFRI
UPRR receives CDPHE license for Uranium Material
The Uranium Material results specifically from the centrifugation of precipitates from inorganic
treatment of pumped groundwater, as discussed below.
3.1 Description of Process which Generated the Uranium Material
Upon entering the treatment plant, the groundwater from tunnel dewatering is treated first by the
addition of a coagulant, Calchem CC2000 aluminum chlorohydrate, followed by direct filtration in
an ultrafiltration membrane system. Backwash water from the ultrafiltration membrane system
containing coagulated solids is pumped through a dissolved air flotation system where a very small
amount of 7th generation dish soap (<0.001 % by volume) is added to assist in thickening of the
solids via flotation. The thickened solids are further dewatered using a centrifuge. A small amount
of Zetag 120L polymer, <0.001 % by volume, is added to the thickened solids before the solids
enter the centrifuge.
During major construction, e.g. rail extension or tunnel expansion, an additional settling step is
added upstream of the treatment plant. Settling tanks are used in this situation to settle construction
related particulate matter. No other treatment chemicals are added.
Per the process description provided by UPRR for production of the centrifuge cake, the chemical
reagents used in the above processes included:
• Calchem CC2000 Aluminum chlorohydrate used as coagulant
• Seventh Generation dish soap used as a thickener for flotation
• Zetag 120L hydrocarbon polymer to enhance centrifugation
The presence of residuals or reaction byproducts from these compounds would be expected in the
Uranium Material, as discussed in the sections below.
Schematic flow sheets depicting the process which produced the Uranium Material during normal
operations and construction periods, are provided in Figures 1 and 2.
4.0 Assumptions Regarding White Mesa Mill Processing of the Uranium Material
This evaluation was based on the following process assumptions:
1. The Mill will process the Uranium Material in either the main circuit or alternate feed
circuit alone or in combination with natural ores or other alternate feed materials.
2. The Uranium Material will be delivered to the Mill by truck in 200 liter (55 gallon) drums.
The drums will be shipped in closed cargo containers, such as Container Express (Conex),
Sea Box, Intermodal Containers (IMCs) or the equivalent.
3
3. The drums will be unloaded from the trucks onto the ore pad for temporary storage until
the material is scheduled for processing. Drums may be stored until sufficient material is
received on site for processing.
4. The Uranium Material will be added to the circuit in a manner similar to that used for the
normal processing of conventional ores and other alternate feed materials.
5. The material is a dewatered moist material with high water content. It is not expected to
generate dust during unloading or during feed to the Mill.
6. The Mill does not anticipate any significant modifications to the leaching circuit or
recovery process areas for the processing of the Uranium Material.
7. Cell 3 and Cell 4A are currently the active tailings cells at the Mill, and either could receive
tailings from the Uranium Material. However, because filling of Cell 3 is nearing
completion, tailings from the Uranium Material will more likely be placed in Cell 4A. The
evaluations in this attachment are therefore based on placement of tailings in Cell 4A. For
purposes of comparison, calculations of concentration changes in the tailings management
system have been prepared both for Cell 3 and Cell 4A.
5.0 Chemical Composition of the Uranium MateriaJ and PotentiaJ Effects in the Mill Process
5.1 Composition
The Uranium Material to be processed at the EFRI White Mesa Mill consists solely of the
centrifuged solids from the water treatment plant.
Physical and chemical analyses have been performed at different times to characterize the raw
water to be treated, to evaluate performance of the WTP, or to characterize the centrifuge solids for
off site management.
For development of treatment requirements prior to WTP construction, raw water from the Moffat
Tunnel West Portal was analyzed quarterly from 2008 through 2016 for metals and other inorganic
parameters.
Centrifuge solids, as well as intermediate streams in the WTP, were analyzed for a limited number
of organic and inorganic parameters during the WTP startup period in 2017.
Subsequent to discussions with EFRI in 2018, UPRR collected additional samples which were
analyzed for a full suite of parameters by a Utah certified laboratory. UPRR collected a first sample
representing short term centrifuge performance and Uranium Material composition by sampling
centrifuge cake from one day's operation. Four additional samples were collected over a two week
period of operation, and composited, to represent Uranium Material composition over time.
The evaluations are summarized in the table below.
4
Table 1
Summary of UPRR Moffat Analyses
Sample Sampling/ Analysis Analyses Number of
Name/Laboratory Date(s) Composite
Samples
American West June 2018 VOCs, SVOCs, 1 random sample
Analytical Laboratories pesticides, herbicides, accumulated over
Centrifuge Cake TCLP (metals and one day's run, and
Characterization organics), major ions, 1 composite of 4
total metals, ammonia additional samples
and nitrate N, over two weeks
radionuclides run.
WTP Startup Solids April 2017 Total metals, TCLP Approximately 10
Characterization metals, TCLP samples from
organics throughout the
WTP. (Not every
sample was
analyzed for every
parameter)
Moffat Tunnel West 2008 through 2016 Major ions, dissolved 119 (not every
Portal Raw Water metals, total metals, sample was
Monitoring cyanide, uranium analyzed for every
parameter)
The sampling was representative of a continuous process stream under the control of the generator
from a process which did not vary appreciably over time.
The various analyses addressed a full range of volatile organic compounds ("VOCs"), semivolatile
organic compounds ("SVOCs"), pesticides, arochlors and other compounds that could potentially
have reached groundwater, or centrifuge solids, from natural and man-made sources. Analyses
provided with the RMPR were performed by laboratories possessing State of Utah and/or NELAC
certification for the analyses performed. As a result, these studies provide sufficiently
representative characterization to assess the regulatory status, worker safety environmental hazards,
and chemical and processing properties of the Uranium Material.
The Uranium Material is a dewatered product of insoluble minerals precipitated from physical and
inorganic treatment of native groundwater. The material exhibits a relatively neutral to slightly
alkaline pH of 8.0.
The drums, containing the centrifuge cake, will be opened and fed to the Mill process in an
appropriate manner to minimize dust, both for the purposes of worker safety and environmental
protection. As mentioned above, the moist centrifuge cake is not expected to produce dust during
unloading or introduction in the Mill process.
The solid portion of the Uranium Material consists primarily of the inert silica based sediments
precipitated from the dewatering water, along with percent levels of natural materials from the host
rock such as iron, calcium and potassium, and aluminum residual from the inorganic water
treatment steps in the WTP that removed the radionuclides and other inorganic analytes prior to
water discharge.
5
The majority of the minerals will be converted to sulfate forms in the leach system. The soluble
sulfate forms are stable and non-reactive and will be removed from the circuit in post-leach steps
and discharged to the Mill's tailings management system.
All the non-uranium components of the material will eventually be discharged to the tailings
management system. Components that are removed as tailings solids will be discharged to Cell 4A
or Cell 3, as discussed above. Process solutions will be discharged to whichever of the basins are
being used for evaporation of Mill solutions at the time of processing.
All the known Uranium Material components in their anticipated mineral states are compatible
with, or will be converted by reaction with either aqueous sulfuric acid or carbonate, either of which
may be used for leaching the Uranium Material, and with any other chemicals and materials to
which they may be exposed in the Mill following the leach circuit. It should be noted that, other
than the uranium compounds, and moderate levels of mineral cations from the host rock, all other
constituents are present at very low levels in the Uranium Material.
Individual components in the Uranium Material have been grouped into classes of constituents, and
discussed below.
5.2 Organic Constituents
5.2.1 Volatile Organic Compounds
The Uranium Material was produced from mechanical and inorganic treatment of native
groundwater. No VOCs were expected to be present in the groundwater, and none were introduced
in the WTP. No VOCs were identified in the Uranium Material.
5.2.2 SemiVolatile Organic Compounds
No SVOCs were expected to be present in the groundwater, and none were introduced in the WTP.
One SVOC, fluoranthene, was identified in one of the two samples of the Uranium Material at
0.289 mg/kg (0.000029 % ) and was not detected in the other sample. The compound may have
been introduced with the naphthenic distillates added before centrifugation. Alternatively, it may
have resulted from pre-treated railroad ties. In any case, the compound is non-reactive and, if
actually present, is at far too low a concentration to have any effect in the Mill process. The Mill
has processed hundreds of thousands of tons of alternate feed materials, such as the Ashland
alternate feed materials, containing fluoranthene with no adverse effects to the Mill or the tailings
management system.
53 Inorganic Constituents
Analyses of inorganic constituents is provided in the analytical reports included with the RMPR
and summarized in Attachments D.1 of the RMPR.
53.1 Non-Metal Inorganic Compounds
As discussed above, the Uranium Material resulted from inorganic treatment of native water. The
primary non-native analytes in the Uranium Material result from the moderate levels of treatment
additives added to the WTP. Low levels of treatment materials were added to the WTP. Nitrogen
is expected to be present at trace to low levels from the treatment additives in the WTP.
6
AmmoniaasN
Ammonia nitrogen is present at low levels in the methylisothioazolinone preservative in the
Seventh Generation dish soap used as a thickener for the dissolved air flotation ("DAF") step in the
WTP.
Ammonia nitrogen was present in the Uranium Material at a maximum of 294 mg/kg (0.029% ).
The level of ammonia nitrogen is too low to have any measurable effect on the Mill process. The
Mill was designed and licensed to handle 100% anhydrous ammonia for use in downstream
processes following leaching. The trace ammonia nitrogen in the Uranium Material
inconsequential in comparison.
Fluorides
Fluoride was present at trace levels in the groundwater influent to the WTP, and was identified in
the centrifuge solids/Uranium Material at less than 5 mg/kg.
Fluorides have been introduced into the Mill's circuit with natural ores and alternate feed materials
at levels as high as 460,000 mg/kg. The Mill has handled fluoride compounds in the Mill circuit
and tailings management system with no adverse process, environmental, or safety issues.
Chlorides
Chloride was present in the influent water to the WTP and is a component of the CalChem
aluminum chlorohydrate coagulant and a low level constituent of the Seventh Generation dish soap
used as a thickener. Chloride has been introduced into the Mill with other alternate feed materials,
at concentrations ranging up to 89,900 mg/kg. The Mill has handled chloride compounds in the
Mill circuit and tailings management system with no adverse process, environmental, or safety
issues.
In conclusion, all of the anions in the Uranium Material have been introduced into the Mill at levels
greater than those identified in the analytical data and assay data. A summary of the anion content
of previous alternate feed materials, and the source of the feed information, has been tabulated in
the attached Table 5.
5.3.2 Metals
As mentioned above, data from analyses in 2018 was used to characterize the inorganic constituents
in the Uranium Material. These constituents can be categorized based on their elemental
characteristics and chemical properties as indicated in Table 2.
Table 2: Classes of Metals in UPRR Uranium Material
Class Component of the Uranium Material
Alkali Metals Sodium, Potassium
Alkaline Earths Barium, Calcium, Magnesium
Chromium, Cobalt, Copper, Iron, Manganese,
Transition Metals Mercury, Molybdenum, Nickel, Vanadium,
Zinc
Other Metals Aluminum, Lead
7
I Metalloids J Arsenic
None of the incompatibilities described below or in Table 3 are applicable to the components as
they will be present in the Uranium Material. None of the components will be present in pure or
concentrated reduced metal form or as pure or concentrated metal oxides. None of the fluoridated,
sulfite, or cyanide, compound or hydroxylated (caustic) forms in Table 3 of the alkali metals or
alkaline earths are expected to be present. None of the components will be exposed to any of the
incompatible agents identified in the table.
Alkali Metals
The alkali metals, sodium, and potassium, were present in influent water to the WTP. Sodium is
frequently the alkaline ionic end of commercial detergents and soaps, which are frequently sodium
alkyl sulfate compounds. Sodium was a trace component of organic sodium lauryl sulfate dish
soap added to the WTP during dissolved air floatation.
The alkali metals are expected to be present in the Uranium Material and were identified at a
maximum of 0.1 and 0.53 percent, respectively. They are expected to be present in mineral silicate
and salt forms in the sediments contained in the centrifuge solids. The Mill routinely processes
alternate feed materials with higher levels of these cations; for example, Fansteel ("FMRI")
alternate feed material contained 13,000 mg/kg (1.3 percent) sodium. Sodium is also present in
several of the reagents used in the Mill at even higher concentrations than the Uranium Material or
alternate feed materials.
Alkaline Earths
The alkaline earth metals, barium, calcium, and magnesium were present in the influent to the WTP
and all are expected to be present in the centrifuge solids. Magnesium was also introduced as a
trace component of Seventh Generation dish soap added to the WTP during dissolved air flotation.
Barium, calcium and magnesium together comprise less than 16,000 mg/kg (1.6 percent) of the
mass of Uranium Material, with barium at a maximum of 311 mg/kg, calcium at a maximum of
10,100 mg/kg, and magnesium at a maximum of 5,300 mg/kg.
As described above, none of the alkaline earths will be present as pure metals or metal oxides.
Hazards associated with pure metals and pure oxides are not applicable and will not be discussed
further.
All other compound and complex forms of the alkaline earths anticipated in the Uranium Material
are compatible with either acid leach or alkaline leach solutions and any other process chemicals
to which they may be exposed in the Mill circuit. They will be removed as sulfates or other
insoluble salts, and discharged to the tailings management system. They do not pose any
incompatibility hazards in the Mill process.
Transition Metals
The transition metals, chromium, cobalt, copper, iron, manganese, mercury, molybdenum, nickel,
vanadium, and zinc were present at varying levels in the influent water to the WTP. All are
expected to be present in the centrifuge solids produced, at the WTP and are consistent with the
low levels detected in the AW AL data. They are expected to be present in carbonate, silicate and
other mineral forms in the sediments removed in the WTP, but not as pure metals or oxide forms.
8
Hazards associated with pure metals and high concentration oxides of these metals are not
applicable and will not be discussed further.
All other compound and complex forms of the transition metals anticipated in the Uranium Material
are compatible with acid leach solutions, and any other process chemicals to which they may be
exposed in the Mill circuit. Their very low levels will be removed as sulfates, and discharged to the
tailings management system. They do not pose any incompatibility hazards in the Mill process.
Other Metals
Aluminum was introduced to the WTP as a component of the aluminum chlorohydrate coagulant
added to the WTP. Aluminum was present at a maximum of 7.6 percent in the A WAL 2018
samples of the Uranium Material.
The AW AL data shows lead present in the Uranium Material at very low levels, on average 139
mg/kg (0.014 percent). Lead was present in the influent water to the WTP, and was not introduced
in any of the WTP additives.
Manufacturers' Safety Data Sheet ("SDS') and National Institute for Occupational Safety and
Health ("NIOSH") safety hazard information indicate that the metals aluminum and lead and their
lower oxides, are incompatible with strong oxidizers, halogen gases, and some acids. Aluminum
and lead will be present as mineral salt and silicate forms in the centrifuge solids. Neither of these
metals will be present as pure metals or as metal oxides. Both will be converted to sulfates once
reacted with sulfuric acid. Hazards associated with pure metals or metal oxides are not applicable
and will not be discussed further.
All other compound and complex forms of these two metals are compatible with acid leach
solutions and any other process chemicals to which they may be exposed in the Mill circuit. They
will be dissolved or precipitated as sulfate salts, and discharged to the tailings management system.
They do not pose any incompatibility hazards in the Mill process.
The Mill has previously processed alternate feed materials with comparable or higher levels of
aluminum, ranging up to 13 percent aluminum, with no incompatibility issues in the Mill process.
The Mill has processed alternate feed materials with substantially higher levels of lead, such as the
Molycorp lead-iron filter cake alternate feed with up to 23.6 percent lead, with no adverse effects
to workers, the Mill process or the environment.
Metalloids
The metalloid, arsenic, was present in influent water to the WTP. Arsenic was identified at a
maximum of 11 mg/kg in the Uranium Material.
Arsenic is expected to be present in mineral forms, not as pure metal or oxides, and the minimal
concentrations of arsenic identified in the available data are too low to be of any concern in the
Mill circuit. Hazards associated with pure metals and oxides will not be discussed further.
All other compound and complex forms of arsenic that could be potentially present in the Uranium
Material are compatible with acid leach solutions and any other process chemicals to which they
may be exposed in the Mill circuit. They will be removed as sulfates or other insoluble salts, and
discharged to the tailings management system. They do not pose any incompatibility hazards in
the Mill process.
9
6.0 Potential Worker Safety Issues
The Uranium Material is a moist cake, expected to have an average moisture content of
approximately 78%. The Mill is equipped with drum-emptying equipment at several locations, in
both the main circuit and alternate feed circuit, and Mill personnel are experienced in the use of
several different mechanisms to empty drums contents with a wide range of handling properties.
As mentioned above, the Uranium Material is not expected to produce dusting during unloading or
introduction to the Mill process.
7.0 Radiation Safety
The Uranium Material consists of centrifuge dewatering solids from the treatment of naturally-
occurring groundwater. The Uranium Material contains approximately 0.5 percent natural uranium
and very low levels of other radionuclides, including thorium isotopes, which are present at much
lower levels than in other alternate feed materials. The derived air concentrations ("DACs"),
radiation protection measures, and emissions control measures used for ores and other alternate
feed materials at the Mill are sufficiently protective for the processing of the Uranium Material.
8.0 Potential Air Emissions Impacts
Discussions in the previous sections demonstrate that the Uranium Material is too moist to generate
a dust impact during drum unloading or feed to the Mill, based on its moisture content of
approximately 78%. Engineering controls already in place at the Mill will be sufficient to prevent
the generation or dispersion of particulate emissions. In addition, once introduced into the Mill,
the constituents in the material will almost immediately be converted to sulfates or other stable
aqueous ionic forms, which are non-volatile and produce no off gases.
Because the metals and ions in the Uranium Material are present at ppm levels or fractional percent
levels, they are not expected to generate a significant increase in load on the existing demisters or
air pollution control devices systems.
9.0 Potential Effects on Tailings Management System
9.1 Tailings Cell Liner Material Compatibility
9.1.1 Effect on Tailings Composition
The Uranium Material will be received as drummed moist solids removed from the centrifuge in
the WTP. Tailings from processing of the Uranium Material will be sent to one of the active tailings
cells at the Mill, Cell 3 or Cell 4A. Subsequent to the closure of Cell 3 tailings could be sent to
Cell 4B or to a similarly designed new cell, depending on the timing of material shipments, and the
status of the cells of the tailings management system at the time of receipt. For the purposes of this
assessment, it has been assumed that the tailings from the Uranium Material will be transferred to
either Cell 3 or Cell 4A.
The solutions from the Uranium Material tailings will be recirculated through the Mill process for
reuse. The solids will be only a portion of the total mass of Uranium Material sent to the Mill from
the Facility. However, assuming a worst case scenario that all of the solid material ends up in the
10
tailings management system, the additional load to the tailings management system will be
minimal.
Cell 4A was placed into service in October of 2008 and received conventional ore tailings solids
and, since July 2009, conventional ore tailings solutions. Cell 4B was authorized for use and placed
into service in February 2011. Cell 4B, to date, has been used only as an evaporation pond. Hence,
for this analysis, it is reasonable to use known information on the composition of Cell 4A and/or
Cell 3.
Cell 3 is a mature cell, later in its operational life cycle, and contains a larger volume/mass of
tailings, and relatively higher concentrations of most constituents than newer cells. Cell 4A is a
newer cell, early in its operational life, and contains a lower volume/mass of tailings and relatively
low concentrations of most constituents. As mentioned earlier in Sections 4.0 and 9.1, the filling
of Cell 3 is nearing completion and the majority, or all, of the tailings from the Uranium Material
is most likely to be placed in Cell 4A. However, Cell 3 provides an approximate representation of
the relative concentrations of constituents that can be expected to be seen in Cell 4A later in its
operating life. Therefore, for comparison purposes, the effect of the Uranium Material on the
concentrations in the tailings management system was prepared for both Cell 4A and Cell 3.
The constituents in the tailings solids and liquids resulting from the processing of Uranium Material
are not expected to be significantly different from those resulting from processing of conventional
ores or previously approved alternate feed materials. The Uranium Material contains generally
lower concentrations of every constituent than has been received in previously approved alternate
feed materials, in many cases two or more orders of magnitude lower than other alternate feed
materials. Tables 4-1 and 4-2, which provide the potential tailings composition Cells 4A, and Cell
3, respectively before and after processing of the Uranium Material, indicate that all of the
constituents found in the Uranium Material have been processed in the Mill's main circuit and/or
the alternate feed circuit and are present in the tailings system.
As described above, it is expected that most of the metal and non-metal components entering the
leach system with the Uranium Material will be converted to sulfate ions, and eventually discharged
to the tailings management system.
Every metal and non-metal cation and anion component in the Uranium Material already exists in
the Mill's tailings management system and/or is analyzed under the GW monitoring program.
Every component in the Uranium Material has been:
1. detected in analyses of the tailings management system;
2. detected in analyses of alternate feed materials licensed for processing at the Mill; or
3. detected in process streams or intermediate products when previous alternate feed materials
were processed at the Mill; at concentrations that are generally comparable or higher than
the concentrations in the Uranium Material.
As can be seen from Tables 4-1 and 4-2, the very low levels of most constituents in the Uranium
Material are estimated to reduce the resulting concentrations in the tailings management system, in
some cases significantly. A few constituents are estimated to raise the current concentration in Cell
4A or Cell 3 by no more than a few mg/kg.
Based on the calculations in Table 4-1, the concentrations of aluminum, iron, mercury, lead, and
barium will increase most notably in the tailings cells after processing the Uranium Material.
11
Aluminum and iron are expected to result in the largest increases in concentrations, of 613 and 189
mg/kg, respectively in Cell 4A. Aluminum and iron are common constituents of the Mill's tailings
and of many natural sands, rock and ore, regardless of source and are components of the natural
background media of the Mill itself. They are expected to remain relatively inert in the conditions
of the tailings management system regardless of concentrations. The Mill has processed thousands
of tons of natural ores with far greater levels of residual iron and aluminum.
With respect to barium, the Mill has previously processed Uranium Materials, specifically the
Molycorp material, with barium concentrations as high as 3.6% or 100 times higher than is present
in the Uranium Material. As discussed in the 2004 and later GWDP SOB documents, and in the
2011 Dawn Mining license amendment application, barium has a strong tendency to precipitate to
inert solid in the presence of the high levels of sulfate as exist in the tailings solutions. Also, as
discussed in these documents, barium's geochemical behavior is well represented by calcium,
which is monitored in the tailings solutions and groundwater monitoring program.
The Mill has processed alternate feed materials from uranium/lead precipitation pond solids, such
as the Molycorp alternate feed material, with lead concentrations as high as 26% lead, or nearly
2,000 times greater than is present in the Uranium Material. Lead is also present in natural uranium
ores and is the ultimate decay product of uranium and thorium. That is the tailings management
system was designed to contain lead in any proportion.
Mercury is the metal with the single lowest concentration in any cell at any time, and ranges from
6 orders of magnitude (1 million times) lower than the other metals, to 9 orders of magnitude (1
billion times) lower than the major ions, in tailings solutions. The complexity of tailings solutions
composition, and the analytical laboratory's need to perform high dilutions to achieve reportable
results of the higher concentration analytes, makes it difficult to achieve dependably reproducible
results for very low concentration species like mercury. As a result, mercury concentrations have
ranged over three orders of magnitude ( I ,000 times) in Cell 3 and two orders of magnitude ( 100
times) in Cell 4. The simple arithmetic average value used in the calculations for each of the two
cells may not be representative of the actual range of mercury concentrations in the respective cell
solutions.
However, regardless of the apparent theoretical increase in mercury concentrations in either cell,
the resulting estimated concentrations are still minutely small compared to all the other
constituents, specifically 0.2 mg/kg in Cell 3 and 0.01 mg/kg in Cell 4A. Additionally, mercury
is monitored in both the tailings solutions and the groundwater monitoring program. Therefore,
the resulting concentration of mercury in the tailings, after processing the Uranium Material, is not
a concern.
Additionally, over its operating life, Cell 4A is expected to receive up to 1.9 million tons of tailings
solids from ores and alternate feed materials, and the eventual resulting concentration of any of the
constituents discusses above will be much lower than indicated in Table 4-1.
As a result of the factors discussed above, the resulting concentrations of aluminum, barium, iron,
lead or mercury in the tailings, after processing the Uranium Material, are not a concern.
9.1.2 Liner Resistivity and Suitability
As discussed above, the majority, or all, of the tailings from the Uranium Material is expected to
be placed in Cell 4A. For the purpose of completeness, the evaluation below addressed both Cell
3 and Cell 4A.
12
Cell 3 was constructed with a polyvinyl chloride ("PVC") membrane liner. Cell 4A (as well as
Cell 4B) has a high-density polyethylene ("HDPE") liner.
Mitchell ( 1985) studied the chemical resistivity of both PVC and HDPE at a pH range of 1.5 to 2.5
standard units using sulfuric acid. This study concluded that PVC performed satisfactorily under
these conditions, HDPE performed better, and both were structurally stable under these acidic
conditions. Haxo, et. al. (EPA 1991) evaluated the performance of PVC (swell as other vinyl and
polyethylene liner materials) in leachate solutions containing metals, salts and volatile
hydrocarbons, such as chloroform. Although most of the materials softened during the first 12
months of exposure, due to the normal wetting process when exposed to solutions, the PVC and
some of the ethylene materials subsequently re-hardened and recovered and retained their tensile
properties for the long term performance.
According to Gulec, et al. (2005), a study on the degradation of HDPE liners under acidic
conditions (synthetic acid mine drainage), HDPE was found to be chemically resistant to solutions
similar to the tailings solutions at the Mill. Battelle Laboratories (Farnsworth and Hymas, 1989)
studied the performance of five synthetic geomembrane liner materials in a complex synthetic
solution at elevated temperatures of 90°C (194°F), containing high levels of anions, including
ammonia nitrogen, chloride, fluoride, and sulfate ions, along with over 20 of the same metals and
metal oxides found in the Mill's tailings and the Uranium Material. In the post-immersion
stress/break tests after 120 days exposure, HDPE was determined to be the best performing material
of all those tested.
It can be concluded that the PVC liner of Cell 3 and the HDPE liners of Cell 4A are suitable for the
chemical and mineral composition of tailings expected from the Uranium Material in the sulfuric
acid conditions to be encountered in the tailings management system
9.1.3 Conclusions Regarding Tailings Management System Effects
The constituents in the Uranium Material, are expected to produce no incremental additional
environmental, health, or safety impacts in the Mill's tailings management system beyond those
produced by the Mill's processing of natural ores or previously approved alternate feed materials.
Since the impacts of all the constituents on the tailings management system are already anticipated
for normal Mill operations, and permitted under the Mill's license, they have not been re-addressed
in this evaluation.
10.0 Groundwater Monitoring Program
The chemical and radiological make-up of the Uranium Material is similar to other ores and
alternate feed materials processed at the Mill, and their resulting tailings will have the chemical
composition of typical process tailings from the ores and previously approved feeds, for which the
Mill's tailings management system was designed.
Specifically, each of the constituents of the Uranium Material
• is monitored under the Mill's current GWDP, or
• has been evaluated in the environmental evaluations for one or more previously approved
alternate feed materials, and it has been determined that one or more analytes monitored
under the GWDP is an effective indicator for the constituent.
13
As a result, the existing groundwater monitoring program at the Mill will be adequate to detect any
potential future impacts to groundwater for any constituent in the Uranium Material.
11.0 Conclusions and Recommendations
The majority of constituents in the Uranium Material are present at lower levels than the majority
of alternate feed materials and even some natural ores previously processed at the Mill. While
elevated levels of a few constituents in the Uranium Material may be present, no additional material
management requirements during handling and processing will be needed.
Based on the foregoing information, it can be concluded that:
1. All the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, already present in the Mill tailings management system or were reported in
other alternate feed materials processed at the Mill, at levels generally comparable to those
reported in the Uranium Material.
2. All the constituents in the Uranium Material have either been reported to be, or can be
assumed to be, previously introduced into the Mill process, with no adverse effects to the
process, or worker health and safety.
3. All the known impurities in the Uranium Material have either been reported to be, or can
be assumed to be, previously introduced into the Mill tailings management system, with
no adverse effects to the tailings management system, or human health and safety.
4. .,iThe Uranium Material will reduce the respective concentrations of most constituents in
tailings. For several constituents whose concentration may be expected to increase in the
short term, these concentrations are not a concern to the tailings solution stability, system
integrity, or groundwater quality for the reasons discussed in Sections 9.0 and 10.0, above.
5. There will be no significant incremental environmental impacts from the processing of
Uranium Material beyond those that are already anticipated in the Environmental Impact
Statements for the Mill.
6. Spill response and control measures designed to minimize particulate radionuclide hazards
will be more than sufficient to manage chemical hazards from the constituents of the
Uranium Material.
14
12s.O References
• Austin, G.T. Shreve's Chemical Process Industries, Fifth Edition. McGraw Hill. New
York 1984.
• Chemical Rubber Company CRC Handbook of Chemistry and Physics, 68'" Edition.
• Denison Mines (USA) Corp [Energy Fuels Resources (USA) Inc.] Amendment Request to
Process an Alternate Feed Material at White Mesa Mill from Dawn Mining Corporation
Midnite Mine April 2011
• Title 10 Code of Federal Regulations; Chapter I -Nuclear Regulatory Commission, Part
40-Domestic Licensing of Source Material: 40.4 -Definitions (10 CFR 40.4)
• Title IO Code of Federal Regulations; Appendix A -Nuclear Regulatory Commission, Part
40 -Domestic Licensing of Source Material: Criteria Relating to the Operation of
Uranium Mills and the Disposition of Tailings or Wastes Produced by the Extraction or
Concentration of Source Material From Ores Processed Primarily for Their Source
Material Content (10 CFR 40 Appendix A)
• Farnsworth, R.K. and C.R. Hymas, August 1989 The Compatibility of Various Polymeric
Liner and Pipe Materials with Simulated Double-Shell Slurry Feed at 900C. Pacific
Northwest Laboratory, US. Department of Energy, Battelle Memorial Institute
• Gulec, S.B., C.H. Benson, and T. B. Edil, 2005. "Effect of Acid Mine Drainage on the
Mechanical and Hydraulic Properties of Three Geosynthetics", Journal of Geotechnical
and Geoenvironmental Engineering Vol. 131, No. 8, ASCE, pp. 937-950.
• Mitchell, D.H., 1985. "Geomembrane Compatibility Tests Using Uranium Acid Leachate",
Journal of Geotextiles and Geo membranes, Vol. 2, No. 2, Elsevier Publishing Co., pp. 111-
128.
• US EPA Chemical Fact Sheets -accessed at www .epa.gov/chemfact on 2/17 /19
• Sax, N. Irving and Lewis, Richard L. Sr. Hawley's Condensed Chemical Dictionary, 1 P"
Edition. Van Nostrand Reinhold. New York 1987.
• US EPA Chemical Fact Sheets -accessed at www.epa.gov/chemfact on 211 7/ 19
• Utah Department of Environmental Quality, Statement of Basis for White Mesa Mill
Groundwater Permit 12/1/2004
15
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Concentration chemical form? these incompatible agents?
Chemical Reported
Component Symbol (mg/kg) Incompatibilities
Aluminum Al 11,000 As A'203 -chlorine trifluoride, hot chlorinated As di-aluminum trioxide Sulfuric acid only. Al203 will not be
rubber, acids, oxidizers present at greater than 1%, and will
be consumed by the overabundance
of sulfuric in the leach system.
As Al -Strong oxidizers and acids, No None present except sulfuric acid. Al
halogenated hydrocarbons is not present as reduced Al, but as
aluminum oxide.
" As pure powder -varies No --
As Al salts and alkyls -varies No. Aqueous solutions on ly --·~ -
Ammonia NH4 190 Strong oxidizers, halogens, acids, salts of No. Will only be present as None present except sulfuric acid.
silver and zinc ammonium oxides, hydrates. NH4 will only be present at low levels
as ammonium oxides and hydrates.
Arsenic As 11 As metal and inorganic compounds -strong Yes. As inorganic salts No. None present except moderate
oxidizers, bromine azide oxidizers only, if used.
As organic compounds -varies No. ---
As AsH3 (arsine) -strong oxidizers, chlorine, No. No. Mild oxidizer only if used.
nitric acid
Barium Ba 550 As Barium oxides -reacts with water to form Will be in oxide form. No.
hydroxides; reacts with N204, hydroxylamines,
S03, H2S
Calcium Ca 13,000 As Ca oxides -react with water No. Water only.
As Ca hydroxides -react with water No. No.
As CaS04 -diazomethane, aluminum, No. Water only.
phosphorous, water
As CaSi03 or CaOSi02 -none listed No. ----
Chloride c1-110 As inorganic salts -none. As phosphorus Only as trace inorganic salts. Not as No.
pentachloride -magnesium oxide phosphorus pentachloride.
Cobalt Co 20 As CoO-none No. --
Copper Cu 860 As CuO -acetylene, zirconium No. No.
Fluoride F 20,000 Varies with compound form. As inorganic Yes. --
salts -none
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Concentration chemical form? these incompatible agents?
Chemical Reported
Component Symbol (mg/kg) Incompatibilities
Iron Fe 20,000 As Fe20 3 -calcium hypochlorite, carbon No. No.
monoxide, hydrogen peroxide
As Fe2(S04)a -decomposes at high No. No.
temperature
As As2Fe20 6 -decomposes on heating to No. No.
yield fumes of arsenic and iron
Lead Pb 6,100 As PbO -strong oxidants, aluminum powder, No. No. None present except moderate
sodium; also decomposes on heating to form oxidizers only, if used.
lead fumes
Magnesium Mg 4,200 As MgC03 -acids, formaldehyde No. None present except sulfuric acid. No
issues: Mg will not be present in the
carbonate form.
As MgO -chlorine, trifluoride, phosphorus No. No.
pentachloride
Manganese Mn 4,400 As Mn(OH)a MN203, MnO -none No. --
Mercury Hg 0.88 As metal and inorganic compounds -No. Will be present as oxide only. No.
acetylene, ammonia, chlorine dioxide, azides,
calcium, sodium carbide, lithium, rubidium,
copper
As organic compounds -strong oxidizers No. No.
such as chlorine gas
Molybdenum Mo 4.8 As metal -strong oxidizers No. No. Moderate oxidizers only, if used.
As soluble compounds -varies Yes. __ ,_
=
Nickel Ni 150 As NiO-iodine, H2S No. No.
Potassium K 7,200 As KCN -strong oxidizers (such as acids, No. No.
acid salts, chlorates, and nitrates).
As KOH -acids, water, metals, halogenated No. No. None present except water and
hydrocarbons, maleic anhydride. Will not be sulfuric acid. No issues. K20 will
present in these forms. only be present at low (less than
percent) levels. -
Sodium Na 13,000 As Na2AIF6 -strong oxidizers No. No. Moderate oxidizers only, if used
As NaN3 -acids, metals, water No. No. None present except sulfuric
acid. No issues: Na will not be
present as sodium azide (NaN3)
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Concentration chemical form? these incompatible agents?
Chemical Reported
Component Symbol (mg/kg) Incompatibilities
As Sodium bisulfate (dry product) -heat No. No.
As NaCN -strong oxidizers (such as acids, No. No.
acid salts, chlorates, nitrates) .. -·
As NaF -strong oxidizers No. No.
As Sodium fluoroacetate -none reported No. --
As NaOH -water, acids, flammable liquids, No. No. None present except sulfuric
organic halogens, aluminum, tin, zinc, acid. No issues: NaO will be present
nitromethane at extremely low levels.
As sodium metabisulfite -heat No. ----
Sulfate S04 18,000 As calcium sulfate -Diazomethane, aluminum, Will only be present in inorganic salt Water only.
phosphorus, water form.
As ferrous sulfate -alkalies, soluble No. No.
carbonates, oxidizing materials
As ferrous sulfate -carbon steel, brass, nylon No. No.
Vanadium V 18 As dust or fume -lithium, chlorine trifluoride No. No.
Zinc Zn 180 AsZnO-none No. --
Note: None of the above incompatibilities are applicable to the components as they will be present in the Uranium Material. None of the components will be
present in pure/reduced metal form or as pure high concentration metal oxides. None of the components will be exposed to any of the incompatible agents
identified in the table.
Sources: NIOSH Pocket Guide to Chemical Hazards accessed September 2018; Wiley Guide to Chemical Incompatibilities Richard Pohanish & S. Greene 2009
Table 4-1 Comparison of Uranium Material to Tailings and Alternate Feed Materials -Cell 4A
A H I
Estimated C D F G Difference between Increase in
Average B Cone. Range in Estimated E Mass in Mill Cone. in Mill Column G and D Mill Tailings
Cone. in Estimated Mill Tailings Average Cone. in Estimated Tailings after Tailings after (Incremental Cone. after
Uranium Mass in before Mill Tailings before Current Uranium Uranium Increase in Mill Uranium
Material Uranium Processing Processing Analyte Mass Material Material Tailings Cone. after Material
(mg/kg or Material Uranium Material Uranium Material in Mill Tailings Processing Processing Uranium Material Processing
Component ppm)1 (tons)2 (mg/Lor ppm)3A (mg/Lor ppm)38• 3c (tons)4 (tons)5 (ppm)s Processing) (ppm)7 (%)B
Inorganic Nitrogen ,u 293.5 1.47 31-9133 3,410 2,046 2,047.5 3,384 -25.8 -0.8
Chloride 7.6 0.04 4530-10,100 6,489 3,893 3,893.4 6,435 -53.6 -0.8
Fluoride 4.7 0.02 0.3-2,030 962.6 578 577.6 955 -7.9 -0.8
Aluminum (Al) 75,650 378.25 1,510 1,510 906 1,284.3 2,123 612.7 40.6
Arsenic (As) 10.5 0.05 60.5-626 143 86 85.9 142 -1.1 -0.8
Barium {Ba) 294 1.47 0.10 0.10 0.06 1.5 3 2.4 2428.9
Calcium (Ca) 9,640 48.20 445-707 604 362 410.4 678 74.7 12.4
Cobalt (Co) 6.9 0.03 9.44-41 27.0 16 16.2 27 -0.2 -0.6
Copper (Cu) 121 0.61 99.2-683 428 257 257.5 426 -2.5 -0.6
Iron (Fe) 26,200 131.00 2280-5320 3,350 2,010 2,141.0 3,539 188.8 5.6
Lead (Pb) 139 0.70 5.27-16.4 12 7 7.7 13 1.1 9.0
Magnesium {Mg) 5,070 25.35 2,230-7,030 4,064.00 2,438 2,463.8 4,072 8.3 0.2
Manganese (Mn) 384 1.92 112-307 187 112 113.9 188 1.6 0.9
Mercury (Hg) 1.22 0.01 0.0008-0.015 0.004 0.002 0.008 0.014 0.0101 287.2
Potassium (K) 5,280 26.40 558-2020 1,138.0 683 709.2 1,172 34.2 3.0
Sodium {Na) 1,110 5.55 5,980-17,600 9,880.0 5,928 5,933.6 9,808 -72.5 -0.7
Vanadium (V) 33.3 0.17 237-1,090 732 439 439.1 726 -5.8 -0.8
Zinc (Zn) 456 2.28 142-406 250,900 150,540 150,542.3 248,830 -2069.8 -0.8
Notes to Table 4:
1. The concentration in the Uranium Material is from 2018 AWAL Laboratory data. Values reported as less than(<) were used as reported.
2. Estimated mass in the Uranium Material is calculated by multiplying column B by an assumed 5,000 dry tons of Uranium Material.
3. Cell 4A Mill tailings range and average concentrations were taken from Mill tailings samples to date, as summarized in the Annual Tailngs Characterization Report
except for Al and Ba. These metals were analyzed by AWAL Laboratories in additional samples collected in 2019.
4. Estimated current mass in Mill tailings Cell 4A is approximately 600,000 dry tons.
5. Mass in Mill tailings after Uranium Material processing is calculated by adding columns B and E.
6. The concentration in Mill tailings after Uranium Material processing is calculated by dividing column F by 605,000, which is the existing volume of tailings in
Cell 4A of 600,000 dry tons plus the assumed 5,000 dry tons of Uranium Material.
7. The increase in Mill tailings concentration after Uranium Material processing (ppm) shows the increase (decrease) in concentration of each constituent in the
Mill's tailings, stated in ppm of the total mass of tailings in Cell 4A, which is calculated as the difference between column G and column D.
8. The increase in Mill tailings concentration after Uranium Material processing is the ratio of Column D to Column H expressed in %
9. The concentration in other alternate feeds represents some selected concentrations for constituents found in characterization data for other alternate feed
materials licensed for processing at the Mill, for comparison purposes.
10. Inorganic nitrogen shown here is ammonia nitrogen.
11. Sources of data for cations in other feeds is provided in Table 5.
12. All organic results except fluoranthene were non-detect. Fluoranthene was ND in one of two sample and 0.29 mg/kg in the other.
J
Cone. in Ores and
Other Alternate
Feed Materials
(mg/kg or ppm)9
350,000
89,900
460,000
2,000-160,000
3.5-16,130
21-36,200
up to 217,000
9-350,400
8-296,000
up to 164,000
9-236,000
1 ,020-43,400
172-3,070
0.0004-14
17-7,740
13,000
10-25,000
8-14,500
Table 4-2 Comparison of Uranium Material to Tailings and Alternate Feed Materials -Cell 3
A H
Estimated C D F G Difference between
Average B Cone. Range in Estimated E Mass in Mill Cone. in Mill Column G and D
Cone. in Estimated Mill Tailings Average Cone. in Estimated Tailings after Tailings after (Incremental
Uranium Mass in before Mill Tailings before Current Uranium Uranium Increase in Mill
Material Uranium Processing Processing Analyte Mass Material Material Tailings Cone. after
(mg/kg or Material Uranium Material Uranium Material in Mill Tailings Processing Processing Uranium Material
Component ppm)1 (tons)2 (mg/Lor ppm)3A (mg/Lor ppm)3B, 3C (tons)4 (tons)5 (ppm)s Processing) (ppm)7
Inorganic Nitrogen'v 293.5 1.47 29-10,600 6,945 18,166 18,167.5 6,932 -13.5
Chloride 7.6 0.04 2,460-115,000 26,545 69,434 69,433.8 26.491 -53.7
Fluoride 4.7 0.02 0.6-46,500 5,873 15,362 15,362.0 5,861 -11 .9
Aluminum (Al) 75,650 378.25 330-2530 1,827 4,779 5,157.1 1,968 140.6
Arsenic (As) 10.5 0.05 0.87-489 120.6 315 315.5 120 -0.2
Barium (Ba) 294 1.47 0.021-0.1 0.048 0.13 1.6 0.6 0.6
Calcium (Ca) 9,640 48.20 148-887 488 1,276 1,324.7 505 17.4
Cobalt (Co) 6.9 0.03 4.44-120 62 162 162.2 62 -0.1
Copper (Cu) 121 0.61 9.72-3,000 589 1,541 1,541.3 588 -1 .0
Iron (Fe) 26,200 131 .00 262-15,400 5,543 14,499 14,629.8 5,582 38.8
Lead (Pb) 139 0.70 15.8-20.5 9.6 25 25.8 10 0.2
Magnesium (Mg) 5,070 25.35 1,910-84,400 18,031 47,164 47,189.0 18,004 -26.8
Manganese (Mn) 384 1.92 82-5,690 1,435 3,754 3,755.4 1,433 -2.17
Mercury (Hg) 1.22 0.01 0.0024-0.873 0.173 0 0.459 0.2 0.002
Potassium (K) 5,280 26.40 133-6657 2,223 5,815 5,841.1 2,229 5.58
Sodium (Na) 1,110 5.55 2, 120-59,800 22,600 59,115 59,120.4 22,556 -43.58
Vanadium (V) 33.3 0.17 5.6-10,300 1,880 4,918 4,917.7 1,876 -3.7
Zinc (Zn) 456 2.28 142-406 2,100 5,493 5,495.3 2,097 -3.4
Notes to Table 4:
1. The concentration in the Uranium Material is from 2018 AWAL Laboratory data. Values reported as less than(<) were used as reported.
2. Estimated mass in the Uranium Material is calculated by multiplying column B by an assumed 5,000 dry tons of Uranium Material.
3. Cell 3 Mill tailings range and average concentrations were taken from Mill tailings samples to date, as summarized in the Annual Tailngs Characterization Report
Values for Al and Ba were taken from Utah SOB for initial Utah GW Discharge Permit
4. Estimated current mass in Mill tailings Cell 3 is approximately 2,615,700 dry tons based on Mill tailings cell capacity estimate 2019.
5. Mass in Mill tailings after Uranium Material processing is calculated by adding columns B and E.
6. The concentration in Mill tailings after Uranium Material processing is calculated by dividing column F by 2,617,900, which is the existing volume of tailings in
Cell 3 of 2,615,700 dry tons plus the assumed 5,000 dry tons of Uranium Material.
7. The increase in Mill iailings concentration after Uranium Material processing (ppm) shows the increase (decrease) in concentration of each constituent in the
Mill's tailings, stated in ppm of the total mass of tailings in Cell 3, which is calculated as the difference between column G and column D.
8. The increase in Mill tailings concentration after Uranium Material processing is the ratio of Column D to Column H expressed in %
9. The concentration in other alternate feeds represents some selected concentrations for constituents found in characterization data for other alternate feed
materials licensed for processing at the Mill, for comparison purposes.
10. Inorganic nitrogen shown here is ammonia nitrogen.
11. Sources of data for cations in other feeds is provided in Table 5.
12. All organic results except fluoranthene were non-detect. Fluoranthene was ND in one of two sample and 0.29 mg/kg in the other.
I
Increase in
Mill Tailings
Cone. after J
Uranium Cone. in Ores and
Material Other Alternate
Processing Feed Materials
(%)a (mg/kg or ppm)9
-0.2 350,000
-0.2 89,900
-0.20 460,000
7.7 2,000-160,000
-0.2 3.5-16,130
1,168.2 21-36,200
3.6 up to 217,000
-0.2 9-350,400
-0.2 8-296,000
0.7 up to 164,000
2.6 9-236,000
-0.1 1,020-43,400
-0.151 172-3,070
1.14 0.0004-14
0.25 17-7,740
-0.19 13,000
-0.2 10-25,000
-0.2 8-14,500
Table 5
Selected Chemicals Present in Alternate Feed Materials
Chemical Value in Supporting or Additional Source
Tailings Table 4 for Information
Concentration in Other
Alternate Feed
Materials
Aluminum 94,000 mg/kg Fansteel Metals Resources pond FMRI application
alternate feed material 2013
160,000 mg/kg
Sequoyah Fuels Corporation pond SFC application
alternate feed material 2011
Ammonia Used as Mill reagent at A 108,000 pound (31,000 gallon) Mill process
Nitrogen 100% anhydrous. inventory of 100% anhydrous description, 1991
ammonia is used to prepare RMLrenewal
concentrated ammonia solutions application and
introduced into the yellowcake 2007 RML renewal
precipitation area. Ammonia in this application
form is added far downstream of
feed area and is never in contact
with ores or feeds. (These
concentrations far exceed those of
the alternate feed.)
Barium 36,244 mg/kg 3.62 % in Molycorp Mt. Pass Molycorp
drummed material alternate feed characterization
data in amendment
request December
2000.
Chloride 89,900 mg/kg Maximum sample from Molycorp ITLC table from
ponds alternate feed, 89,900 mg/kg December 2000
Molycorp
Amendment
Request
Fluoride 460,000 mg/kg Honeywell/Converdyne/ Allied MSDS for CaF2
Signal alternate feed, up to 2% U, product.
98% calcium fluoride and fluoride
impurities (48% or 480,000 mg/kg F
based on all being as CaF2)
Lead 236,000 mg/kg Molycorp Pond materials 236,000 to Molycorp
262,000 mg/kg (23% to 26%) lead amendment
request December
2000
Attachment 6
Cross Index to DWMRC Interrogatory Template for Review of License Amendment
Requests and Environmental Reports under UAC R313-24
Cross Index to UAC R3 '.4 Interrogatory Template
DRC Interrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addressed in Other Documents
Environmental Analysis -Radiological and Section 1.0-1.4, 2.3, 2.5, 4.1,
UAC R313-24-3-01A/Ol Nonradiological impacts UAC R313-24-3 Attachment 5 ER Lie. App 3.1-3.1 O; ER Cell 4B 9.0
ER Lie. App. 3.4.1-3.4.4, 3.5; Rec Plan 1.6; ER
Geology and Soils (Land) RG 3.8, Section 6.1.4.1 Section 4.1 Cell 4B 6.0
ER Lie. App. 3.13 .2.2, Figure 3.13-1; Dames
Exposure Pathways RG 3.8, Section 5.2.1 Section 4.1 and Moore 5.2; ER Cell 4B 10.1
Liquid Effluents RG 3.8, Section 5.2.2 Section 4.1, 4.6, 4.8 Rec. Plan 2.2.3.2; Dames and Moore 5.2
GW Permit App. 2.6; Dames and Moore 2.7.4,
Airborne Effluents RG 3.8, Section 5.2.3 Section 4.1, 4.8 Dames and Moore 5.2
Direct Radiation RG 3.8, Section 5.2.4 Section 2.3, 4.1, 4.9, 4.10 Dames and Moore 2. 7.4
Effects of Sanitary and Other Waste
Discharges RG 3.8, Section 5.4 Section 4.1 Dames and Moore 5 .4
Other Effects RG 3.8, Section 5.5 Section 4.1, 4.2.2 Dames and Moore 5 .5
NUREG-1620, Section
Hazard Assessment 4.3.3.1 Section 4.1, Attachment 4 GW Permit App. 2.6-2.7
NUREG-1620, Section
Exposure Assessment 4.3.3.2 Section 4.1 GW Permit App. 2.6-2.7
Accidents DG-3024, Section 6 Section 4.1, 4.2.3 ER Lie. App. 4.0
Mill Accidents Involving Radioactivity RG 3.8, Section 7.1 Section 4.1, 4.4. I ER Lie. App. 4.0
Other Accidents RG 3.8, Section 7.3 Section 4.1 , 4.2.3 ER Lie. App. 4.0
Summary of Annual Radiation Doses RG 3.8, Section 5.2.5 Section 4.1 ER Lie. App Tables 3.13-3, 3.13-4
Environmental Analysis -Impact on
UAC R313-24-3-01B/Ol Waterways and Groundwater UAC R313-24-3 Section 4.1, 4.6, 4.7 GW Permit App. 2.5-2.7; ER Ce114B 10.0
ER Lie. App. 3.7.1 .1-3.7.1.3; Rec Plan 1.4.1-
Surface Water RG 3.8, Section 6.1.1 Section 4.1, 4.7 1.4.3, 1.7.5.5
Physical and Chemical Parameters (Ground
Water) RG 3.8, Section 6. I .2.2 Section 4.1, 4.6, Attachment 4 GWDPTable2
UAC R313-24-3-01C/01 Environmental Analysis -Alternatives UAC R313-24-3 Section 4.1, 4.14 ER Lie. App. 2.0-2.4
Alternatives to the Proposed Action RG 3.8, Section 10 Section 4.1, 4.14 ER Lie. App 2.1 , 2.4
Benefit -Cost Analysis RG 3.8, Section 11 Section 4.1, 4.13 ER Lie. App. 5.0; Rec Plan Attachment C
UAC R313-24-3-01D/Ol Environmental Analysis -Long-Term Impacts UAC R313-24-3 Section 4.1, 4.5.3, 4.11 ER Lie. App. 5.0; ER Cell 4B 14.0
Mill Decommissioning DG-3024, Section 8.1 Section 4.1, 4.5 .3 Rec. Plan 3.2.3,
Site and Tailings Reclamation DG-3024, Section 8.2 Section 4.1, 4.5.3 Rec. Plan 3.2.1, 3.2.2.;
Decommissioning and Reclamation RG 3.8, Section 9 Section 4.1, 4.5.3 Rec. Plan Attachment A, 3.2. I, 3.2.2
Cross Index to UAC R3 !4 Interrogatory Template
DRC lnterrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addressed in Other Documents
Decommissioning Plan for Land and NUREG-1620, Section
Structures 5.2.3 Section 4.1, 4.5.3 Rec. Plan 3.2.1
Satisfied by ongoing compliance with mill
10CFR40.26(c)(2)-02/0l General License UAC R313-24-4 license
Satisfied by ongoing compliance with mill
10CFR40.31(H)-03/01 Application for Specific Licenses UAC R313-24-4 license
Corporate Organization and Administrative Satisfied by ongoing compliance with mill
Procedures DG-3024, Section 5.1 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Management Control Program DG-3024, Section 5.2 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Management Audit and Inspection Program DG-3024, Section 5.3 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Qualifications DG-3024, Section 5.4 Section 4.1, Section 4.12 license
Satisfied by ongoing compliance with mill
Training DG-3024, Section 5.5 Section 4.1, 4.4, 4.10.2, 4.12 license
Satisfied by ongoing compliance with mill
Security DG-3024, Section 5.6 Section 4.1, 4.12 license
Satisfied by ongoing compliance with mill
Quality Assurance DG-3024, Section 7 Section 4.1 license
Satisfied by ongoing compliance with mill
References DG-3024 Section 4.1 license
Satisfied by ongoing compliance with mill
10CFR40.4(c)-04/0l Terms and Conditions of Licenses UAC R313-24-4 Section 4.1 license
I0CFR40.40.42(K)(3)(1)-Satisfied by ongoing compliance with mill
05/01 Expiration, Termination, Decommissioning UAC R313-24-4 Section 4.1 license
Satisfied by ongoing compliance with mill
10CFR40.61-06/01 Records UAC R313-24-4 license
10CFR40.65(A)(l)-07/01 Effluent Monitoring Reporting Requirements UAC R313-24-4 Section 4.1 Rec. Plan 1.7.5.4
Mill Effluent Monitoring (Proposed
Operational Monitoring Program RG 3.8, Section 6.2.1.1 Section 4.1 Rec. Plan 1.7.5.4
Enviromental Radiological Monitoring
(Proposed Operational Monitoring Program) RG 3.8, Section 6.2.1.2 Section 4.1 Rec Plan 2.3.2.l 9 (c), (d); ER Cell 4B 10.4
Meteorological Monitoring (Proposed Rec. Plan l.l.1-1.1.3, 2.3.2.l(d), 1.7.5.6; ER
Operational Monitoring Program) RG 3.8, Section 6.2.3 Section 4.1 Cell 4B 2.2
l0CFR40.INTRODUCTI0 Capacity of Tailings or Waste Systems Over
N-08/01 the Lifetime of Mill Operations UAC R313-24-4 Section 4.1, 4.5.2 GW Permit App. 2.15 .2.3
Cross Index to UAC R3 '.4 Interrogatory Template
DRC Interrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addressed in Other Documents
10CFR40APPENDIX A,
Introduction-09/01 Alternative Requirements UAC R313-24-4 Section 4.1 ER Lie. App 2.1-2.4
10CFR40 APPENDIX A, Permanent Isolation Without Ongoing
CRITERION 1-10/01 Maintenance UAC R3 l 3-24-4 Section 4.1 , 4.5.3 Rec Plan 3.2.3.1
NUREG-1620, Section
Slope Stability 2.2.3 Section 4.1, 4.5.3 Rec Plan 3.3.6
NUREG-1620, Section
Settlement 2.3.3 Section 4.1, 4.5 .3 Rec Plan 3.3.6
NUREG-l 620, Section
Liquidifacation Potential 2.4.3 Section 4.1, 4.5 .3 Rec Plan 3.3.6
10CFR40, APPENDIX A,
CRITERION 2-11/01 Proliferation UAC R313-24-4 Section 4.1 Rec Plan 3.3.6
10CFR40, APPENDIX A,
CRITERION 3-12/01 Placement Below Grade UAC R3 l 3-24-4 Section 4.1 GW Permit App. 2.5.1.5
10CFR40, APPENDIX A,
CRITERION 4-13/01 Location and Design Requirements UAC R313-24-4 Section 4.1 Rec. Plan 3. l
Site Location and Layout RG 3.8, Section 2.1 Section 4.1 Rec Plan 1.1, Figure 3.2-1; ER Lie. App 3.2
Site Area RG 3.8 Section 3.1 Section 4.1 Rec Plan 1.1, Figure 1-2, Figure 3.2-1
Geography DG-3024, Section 2.1.1 Section 4.1 Rec Plan l. 1-1.3
Land Use and Demographic Surveys (Land) RG 3.8, Section 6.1.4.2 Section 4.1 FES 2.5; ER Cell 4B 3.0
Uses of Adjacent Lands and Waters RG 3.8, Section 2.2 Section 4.1 FES 2.5; ER Cell 4B 3.0
ER Lie. App. Figure 3.9-1; FES 2.4.1.2; ER Cell
Population Distribution RG 3.8, Section 2.3 Section 4.1 4B 4.0
Demography DG-3024, Section 2.1.2 Section 4.1 FES 2.4.1.2, 2.4.1.3, 2.4.2
Meteorology RG 3.8, Section 2.8 Section 4.1 Rec Plan 1.1, 1.7.5.6; ER Cell 4B 2.0
DG -3024, Section 2.2 Section 4.1 Rec Plan 1.1, 1.7.5.6; ER Cell 4B 2.0
RG 3.8, Section 6.1.3.1 Section 4.1 Rec Plan 1.1 , 1.7.5.6; ER Cell 4B 2.0
Models (Air) RG 3.8, Section 6.1.3.2 Section 4.1 ER Lie App. 3.3 .2
Geology and Soils RG 3.8, Section 2.5 Section 4.1 Rec Plan 1.6
DG-3204, Section 2.4.1 Section 4.1 Rec Plan 1.6
Seismology RG 3.8, Section 2.6 Section 4.1 Rec Plan 1.6.2.4, l .6.2.5
DG-3024, Section 2.4.2 Section 4.1 Rec Plan 1.6.3, 1.6.3.1, 1.6.3.2
NUREG-1620, Section Rec Plan 1.5.1.2, 1.5.1.3, Figure 1.5-1 , 1.5-3;
Hydrological Description of Site 3.1.3 Section 4.1 ER Cell 4B Appendix A
Surface Water (Hydrology) RG 3.8, Section 2.7.2 Section 4.1 GWDP I.F.10
Cross Index to UAC R3 !4 Interrogatory Template
DRC Interrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addressed in Other Documents .•
DG-3024, Section 2.3.2 Section 4.1 GWDP I.F.10
NUREG-1620, Section
Flooding Determinations 3.2.3 Section 4.1 GW Permit App. 2.13
Surface Water Profiles, Channel Velocities, NUREG-1620, Section
and Shear Stresses 3.3.3 Section 4.1 GW Permit App. 2.4
Ground Water (Hydrology) RG 3.8 Section 2.7 .1 Section 4.1 Rec Plan 1.5.1.2, 1.5.1.3, Figure 1.5-1, 1.5-3
DG-3024, Section 2.3.1 Section 4.1 Rec Plan 1.5.1.2, 1.5.1.3, Figure 1.5-1, 1.5-3
Radiological Surveys RG 3.8, Section 6.1 Section 4.1 ER Cell 4B 10.3-10.4
NUREG-1620, Section Section 4.1, 4.5 .1, Attachment
Site and Uranium Mill Tailings Characteristics 2.1.3 5 Rec. Plan 2.2
NUREG-1620, Section
Disposal Cell Cover Engineering Design 2.5.3 Section 4.5.3 GW Permit App. 2.7.2.4; Rec Plan 3.2.2.1
NUREG-1620, Section
Design of Erosion Protection Covers 3.5.3 Section 4.5.3 GW Permit App. 2.7.2.4; Rec Plan 3.2.2.1, 3.3.5
UAC R313-24-4,
10CFR40, APPENDIX A, NUREG-1620 section
CRITERION SA(l)-14/01 Groundwater Protection Standards 4.2.3 Section 4.1, 4.6 GWDP I.A Table 1, I.B, I.C Table 2, I.E
CRITERION 5A(2)-15/0l Liner UAC R313-24-4 Section 4.1, 4.6 GWDP I.D.2, I.E.8 (c), I.E.7(f)
10CFR40, APPENDIX A, Exemption from Groundwater Protection
CRITERION 5A(3)-16/0l Standards UAC R313-24-4 Section 4.6 Rec. Plan 2.3.1.1 (a)
lOCFR, APPENDIX A,
CRITERION 5A(4)-17/01 Prevent Overtopping UAC R313-24-4 Section 4.1 Rec Plan 2.2.3.1, 2.2.3.2
lOCFR APPENDIX A,
CRITERION SA(S)-18/01 Dikes UAC R313-24-4 Section 4.1 Rec Plan 2.2.3.1, 2.2.3.2
lOCFR APPENDIX A, Cover and Closure at End of Milling
CRITERION 6(1)-19/01 Operations UAC R313-24-4 Section 4.1, 4.5 .3 GW Permit App. 2.19
NUREG -1620, Section
Radon Attenuation 5.1.3.1 Section 4.1, 4.5 .3 GW Permit App. 2.19; Rec Plan 3.3.2
NUREG-1620, Section
Gamma Attenuation 5.1.3.2 Section 4.1, 4.5.3 GW Permit App. 2.19; Rec Plan 3.3.2
NUREG-1620, Section GW Permit App. 2.19; Rec Plan 3.3.6, 3.3.8; ER
Cover Radioactivity Content 5.1.3.3 Section 4.1, 4.5.3 Cell 4B Figure 13
10CFR40, APPENDIX A,
CRITERION 6(2)-20/01 Verify Effectiveness of Final Radon Barrier UAC R313-24-4 Section 4.1, 4.5.3 Rec Plan. 3.2, 3.2.3.1; GW Permit App. 2.19.4
10CFR40, APPENDIX A,
CRITERION 6(3)-21/01 Phased Emplacement of Final Radon Barrier UAC R313-24-4 Section 4.5.3 Rec Plan. 3.2, 3.2.3.1; ER Cell 4B Table 5
Cross Index to UAC R3 !4 Interrogatory Template
OR{,; lnterrogat,ry Where A~~~ Th.i_s
Nwn~ 'ro_pic R~1d.aU>cy ~ t)Qt~nt Wb(!re A~ w Other D~nts
10CFR40, APPENDIX A, Elevated Raduim Concentrations in cover
CRITERION 6(5)-23/01 Materials UAC R313-24-4 Section 4.5.3 GW Permit App. 2.19; Rec Plan 3.3.6, 3.3.8
NUREG-1620, Section GW Permit App. 2.19; Rec Plan 3.3.6, 3.3.8; ER
Cover Radioactivity Content 5.1.3.3 Section 4.1, 4.5.3 Cell 4B Figure 13
10CFR40, APPENDIX A, Concentrations of Radionuclides other than
CRITERION 6(6)-24/01 Radium in Soil UAC R313-24-4 Section 4.5.3 GW Permit App. 2.19; Rec Plan 3.3.5
Background Radiological Characteristics RG 3.8, Section 2.1 Section 4.1 Lie. App. 3.13.1; ER Cell 4B 9.0
10CFR40, APPENDIX A,
CRITERION 6(7)-25/01 Nomadiological Hazards UAC R313-24-4 Attachment 5 Dames and Moore 3.3.1; ER Cell 4B 9.0
Regional Nomadiological Characteristics RG 3.8, Section 2.11 Section 4.1 Dames and Moore 3.3.1; ER Cell 4B 9.0
Concentrations of Nomadiocative Wastes RG 3.8, Section 5.3 Section 4.5.1, Attachment 5 Dames and Moore 3.3.1; ER Cell 4B 9.0
10CFR40, APPENDIX A,
CRITERION 6A(l)-26/01 Completion of Final Radon Barrier UAC R313-24-4 Section 4.5.3 Rec Plan. 3.2, 3.2.3.1; GW Permit App. 2.19.4
10CFR40, APPENDIX A,
CRITERION 6A(2)-27/0l Extending Time for Milestones Performance UAC R313-24-4 Section 4.5.3 Rec Plan. 3.2, 3.2.3.1; GW Permit App. 2.19.4
10CFR40, APPENDIX A, Accepting Uranium Byproduct Material from
CRITERION 6A(3)-28/0l Other Sources During Closure UAC R313-24-4 Section 4.5.3 License Condition 9 .11
10CFR40, APPENDIX A, Preoperational and Operational Monitoring
CRITERION 7-29/01 Programs UAC R313-24-4 Section 4.1 Rec Plan 2.3.2
10CFR40, APPENDIX A,
CRITERION 8-30/01 Effluent Control During Operations UAC R313-24-4 Section 4.1 GW Permit App. 2.15
Gaseous and Airbourne Particulate Materials DG-3024, Section 4.1 Section 4.1 GW Permit App. 2.15
Liquids and Solids DG-3024, Section 4.2 Section 4.1 GW Permit App. 2.15
Contaminated Equipment DG-3024, Section 4.3 Section 4.1 GW Permit App. 2.15
Sources of Mill Wastes and Effluents RG 3.8, Section 3.4 Section 4.4 GW Permit App. 2.15; Dames and Moore 3.3
Control of Mill Wastes and Effluents RG 3.8, Section 3.5 Section 4.4 GW Permit App. 2.15; Dames and Moore 3.4
Sanitary and Other Mill Waste Systems RG 3.8 Section 3.6 Section 4.1 GW Permit App. 2.15; Dames and Moore 3.5
Effluents in the Environment RG 3.8, Section 5.1.2 Section 4.1 GW Permit App. 2.15; Dames and Moore 3.3
Effluent Control Techniques DG-3024, Section 5.7.1 Section 4.1 GW Permit App. 2.15; Dames and Moore 3.3
External Radiation Exposure Monitoring
Program DG-3024, Section 5.7.2 Section 4.1 GW Permit App. 2.15
Airborne Radiation Monitoring Program DG-3024, Section 5.7.3 Section 4.1 GW Permit App. 2.15; ER Lie. App 3.3.2
Exposure Calculations DG-3024, Section 5.7.4 Section 4.1 Rec. Plan Attachment F
Cross Index to UAC R3 !4 Interrogatory Template
DRC Interrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addressed in Other Documents
Bioassay Program DG-3024, Section 5.7.5 Section 4.1 Rec Plan 3.2
Contamination Control Program DG-3024, Section 5.7.6 Section 4.1 Rec Plan 3.2
Airborne Effluent and Environmental GW Permit App. 2.9; Rec Plan 2.3; Dames and
Monitoring Programs DG-3024, Section 5.7.7 Section 4.1 Moore 3.3; ER Cell 4B Appendix C
Groundwater and Surface Water Monitoring GWDP LE, 1.F; Rec Plan 2.3.1.1; ER Cell 4B
Programs DG-3024, Section 5.7.8 Section 4.1 10.2
Control of Windblown Tailings and Ore DG-3024, Section 5.7.9 Section 4.1 Rec Plan 3.2.3.1
IOCFR40, APPENDIX A,
CRITERION SA-31/01 Daily Inspections UAC R313-24-4 Section 4.1 Rec Plan 2.3.2.2(a)
10CFR40, APPENDIX A,
CRITERION 9-32/01 Financial Surety Arrangements UAC R3 l 3-24-4 Section 4.5.3 Surety 2010
Financial Assurance DG-3024, Section 8.3 Section 4.5.3 Surety 2010
NUREG-1620, Section
Maintaining Financial Surety 4.4.3(10) Section 4.5.3 Surety 2010
10CFR40, APPENDIX A,
CRITERION 10-33/01 Costs of Long-Term Surveillance UAC R313-24-4 Section 4.5.3 Surety 2010
Duty to Apply for a Groundwater Discharge
UAC R317-6-6.l-34/0l Permit UAC R313-24-4 Section 4.1, 4.6 GWDPIV.D
UAC R317-6-6.3-35/0l Groundwater Discharge Permit Application UAC R313-24-4 Section 4.1, 4.6 GWDPIV
UAC R317-6.6.4-36/0l Issuance of Discharge Permit UAC R3 l3-24-4 Section 4.1, 4.6 GWDPIV
UAC R317-6-6.9-37/0l Permit Compliance Monitoring UAC R313-24-4 Section 4.1, 4.6 GWDP III
Examination of Compliance and Monitoring NUREG -1620, Section
Program 4.3.3.4 Section 4.1, 4.6 GWDP LF.l
UAC R317-6-6.10-38/0l Background Water Quality Determination UAC R313-24-4 Section 4.1, 4.6 GWDP LB; ER Lie App. 3.7.3.2 (c)
Commencement and Discontinuance of
UAC R317-6-6.10-39/0l Groundwater Discharge Operations UAC R313-24-4 Section 4.6 GW Permit App. 2.19
UAC R317-6-6.12-40/0l Submission of Data UAC R3 l3-24-4 Section 4.6 GWDP LF.I
Reporting of Mechanical Problems or
UAC R317-6-6.13-41/0l Discharge System Failures UAC R313-24-4 Section 4.6 GWDP LG; GW Permit App 2.15
UAC R317-6-6.10-42/0l Correction of Adverse Effects UAC R313-24-4 Section 4.6 GWDPI.G
NUREG-1620, Section
Corrective Action Assessment 4.3.3.3 Section 4.6 GWDPLG
UAC R317-6-6.10-43/0l Out-of-Compliance Status UAC R313-24-4 Section 4.6 GWDPI.G
Procedure When a Facility is Out-of-
UAC R317-6-6.10-44/01 Compliance UAC R3 l 3-24-4 Section 4.6 GWDPLH
Cross Index to UAC R3 !4 Interrogatory Template
DR(: Interrogatory Where Add~w. in This
NUJJiber Topic Regulatory Basis Document
UAC R317-6-6.10-45/0l Groundwater Discharge Permit Transfer UAC R313-24-4 Section 4.6
Notes:
If not stated otherwise, section number refers to section in the license amendment application, not its attachments.
References:
GWDP -"Ground Water Discharge Permit UGW370004". July 14, 2011
ER Cell 4B -"Environmental Report in Support of Construction Tailings Cell 4B".
Revised and Resubmitted September 11, 2009
GW Permit App. -"Permit Renewable Application. State of Utah Ground Water
Discharge Permit NO. UGW370004". September 1, 2009
Rec. Plan -"Reclamation Plan White Mesa Mill Blanding, Utah. Radioactive Material
License NO. UT1900479 Revision 4.0". November 2009
ER Lie. App. -"White Mesa Uranium Mill License Renewal Application. State of Utah
Radioactive Materials License No. UT1900479". Volume 4 of 5 (Environmental Report).
February 28, 2007
Dames and Moore -"Environmental Report. White Mesa Uranium Project. San Juan
County, Utah for Energy Fuels Nuclear, Inc". Prepared by Dames and Moore. January 30,
1978
FES -"Final Environmental Statement related to operation of White Mesa Uranium
Project. Energy Fuels Nuclear, Inc". May 1979.
Surety 2010 -"Revised Cost Estimates for Reclamation of the White Mesa Mill and
Tailings Management System". November 23 2010.
License Condition -"Utah Department of Environmental Quality Division of Radiation
Control Radioactive Material License". License #UT1900479. June 2010
Where Addressed in Other Documents
GWDPIV.L